Federal undertakings usually take one of four forms: Actions directly carried out by, or on behalf of, a federal agency. Actions carried out with federal financial assistance. Actions requiring a federal license, permit, or approval. Actions subject to state or local regulation administered pursuant to a delegation or approval by a federal agency. Federal undertakings usually take one of four forms: Actions directly carried out by, or on behalf of, a federal agency. Actions carried out with federal financial assistance. Actions requiring a federal license, permit, or approval. Actions subject to state or local regulation administered pursuant to a delegation or approval by a federal agency. A state or local government project that is undertaken without federal funding, licensing, or permits is not subject to Section 106 review, even if it affects historic properties. It may, however, be subject to state or local preservation regulations.
Overview• Introduction to VELCO• What are historic, architectural, archaeological and cultural resources?• Preparing for Assessments• Defining Area of Potential Effects (APE)• Identify and Evaluate• Data Collection Considerations• Determining Effects• Mitigation and Compliance• Post Construction Considerations
VELCO• Founded 1956 as nation’s first “transmission only” company • Assures competitive, equal access for energy providers and our owners• Owned by Vermont’s electric distribution utilities• Project work driven by federally enforceable reliability standards• Recent electric reliability projects include numerous substations and high-voltage transmission lines• VELCO’s transmission system includes: • Over 700 miles of transmission lines • 51 transmission facilities (substations, switching stations, etc) • 12,250 acres of managed ROW • 600 miles of fiber optic system
Preparing for an Archaeological Assessment• Comprehensive Project Understanding – Route alignment – Access constraints – Anticipated impacts – Schedule and budget• Have a clear understanding of the regulatory requirements – Understand the rules and regulations – Know the regulatory staff and SHPOs – Have a clear understanding of expectations and requirements• Evaluate archaeological consulting firms – Ensure availability of field crews – Relevant project experience – Review and understand overall approach – Develop a team
Section 106 Process• An "undertaking" means a project, activity, or program funded in whole or in part under the direct or indirect jurisdiction of a federal agency. "Federal" means under the jurisdiction of a federal agency• Make sure you know if your project requires a Federal undertaking and what Federal agency is the “Lead Agency”
Defining the Area of Potential Effects (APE)• Geographic area or areas within which an undertaking may directly or indirectly cause alterations to the character of historic sites and/or properties, if any such areas exist.• Seek input from project team in the development of the APE to ensure that it is accurate and will meet all project needs. – Include all project areas• Changes to the APE during permitting and/or construction can be costly and cause delays.
Identify and Evaluate• “Scoping” or “accessing information needs.”• Seek information from knowledgeable individuals, organizations and tribes.• Make a “reasonable and good faith effort” to identify historic properties.• Determine whether historic properties are eligible for the National Register.
Evaluate risk of encounteringarchaeological resources when making siting decisions
Data Collection Considerations• Use all project data to support archaeological SOW development/assessment – Environmental data – Accurate topographic information – Information from company files• Data collection must be phased so that it can “build” upon itself – Topographic surveys will support wetland and stream assessments – Wetland, stream and topographic information is then provided to archaeologists to support the sensitivity assessments – Resource assessment scheduling and data management is critical• Why is this important?– Develop a comprehensive and accurate SOW– Ultimately reduces costs and time associated with archaeological assessments
Cultural Resource Field Surveys• Level of effort – Time & Costs – Use company staff to support (e.g. reviews of access, etc.)• Field Work Considerations – Scheduling and field conditions – Access Constraints – Capabilities of work crews• Data collection – Develop standards – Accurate data is extremely important• Reporting & Management• Reviews of reports and other deliverables• Early and frequent coordination with regulatory agencies
Determining Effect• Consult with Lead Federal Agency – Comments from SHPO, tribes, regulators, and interested parties• Make finding – no historic properties affected or no adverse effect• Federal Agency (as appropriate) makes the final judgment• Document results• Involve the public and make findings available
Impact Mitigation• Seek agreements on how adverse effects will be resolved• Memorandum of Agreement executed upon signature of consulting parties• Negotiating Reasonable Permit Conditions• Consider on-going work practices associated with maintenance crews• Control and track commitments
Construction and Compliance• Managing Identified Cultural Resources• Project Trainings• Implement Impact Mitigation Measures – Matting, suitable ground conditions, etc.• Vehicular Barriers• Monitoring/Oversight• Reporting and Agency Inspections• Establish company procedures