Permit Planning
At Brockington, many of our clients engage us to help them with permit application requirements for cultural properties requirements. We thus work very hard to identify the needs of each type of permit and how these requirements might vary among counties, states, and federal agencies.
For example, federal permits generally require archaeological and historic study to meet the requirements of the National Historic Preservation Act, Section 106. Corps of Engineers' permits, however, are guided by specific alternate regulations which have some slight differences with the standard 106 regulations. Corps' permits may have "stipulations" rather than extensive Memoranda of Agreement guiding the implementation of preservation or mitigation strategy. Knowledge of this may allow us to suggest the quickest approach for a particular situation.
Permits, certifications, and determinations of "consistency" under the federal Coastal Zone Management Act are interpreted in different ways by different states' enabling laws and regulations. It is crucial to know what types of information are needed, and when, by state agencies so that the permit applicant can proceed steadily through the process.
State permits are needed for grave relocation, and in most states these are administered by each county. We have worked in Georgia to help counties develop their processes for consideration of many issues; often our projects were the first since passage of a new Georgia statute protecting burial sites. Unmarked graves and Native American burials on private and state land are usually regulated by state law and are treated differently from each other and from marked cemeteries. For example, in Georgia, state law requires identification of graves as Indian or non-Indian. For Indian burials, there must be consultation with the Georgia Council on American Indian Concerns prior to disturbance (or if disturbance has already occurred).
Teaming with Engineers, Biologists, and Other Specialists
At Brockington and Associates, many of our projects are large and complex, and we work as part of a team with engineers, planners, biologists, and other specialists. We have learned the permit needs for all these areas of environmental analysis, and we know how to work together with the team members to meet most efficiently the requirements of archaeology and history.
For many federal permits, it can be shown that the archaeology and history work has been successfully concluded when Agreement Documents have been signed. These are called for in the National Historic Preservation Act, and they include Memoranda of Agreement, Programmatic Agreements, or other formal plans that show the negotiated agreement among the State Historic Preservation Officer, the permit applicant, and the permitting agency. Brockington and Associates has extensive experience in drafting, negotiating, and even procuring the signatures. Most of our Agreement Documents are drafted after a single short meeting and are rapidly finalized and executed. Sometimes however, on large and controversial projects involving various preservation groups, tribes, and agencies, consultations and negotiations can be extensive.
We have been involved in several such nationally prominent projects, and we are proud of the results we have obtained for our clients. We are also pleased that we were able to work with senior federal and state officials, tribal leaders, and preservation representatives in situations where all parties benefitted. We developed new instrument and we helped build good future working relationships for all parties involved.
Ken Anderson of Jordan, Jones, and Goulding, Inc. discusses possible roadway corridor locations with Mike Reynolds, historian in our Atlanta office.
Archaeologist Whitney Olvey completes a unit/level form as part of the recording of data at Silk Hope Plantation in Bryan County, Georgia.
