Cultural Resources Survey, Testing, and Evaluation
WRA supports project compliance with CEQA, NEPA, and National Historic Preservation Act (NHPA) Sections 106 and 110, by conducting cultural resources surveys and significance evaluations. Our approach begins with performing California Historical Resources Information System (CHRIS) records searches, outreach to the California Native American Heritage Commission (NAHC), and reviewing existing data to determine survey methodology, including whether or not subsurface survey is warranted. For projects requiring NHPA Section 106 compliance, WRA coordinates with you and the lead federal agency to develop an Area of Potential Effects map to ensure accurate survey coverage. We then conduct field surveys and document any archaeological or architectural resources identified. If resources are present and may be impacted by a project, WRA can evaluate their eligibility for the National Register of Historic Places (National Register) and California Register of Historical Resources (California Register), as applicable. If additional excavation is required to evaluate archaeological resource significance, WRA experts develop and implement archaeological testing programs, which may include plans, fieldwork, Native American coordination, laboratory analysis, and reporting. We document our surveys and testing in technical reports that meet the standards for and support compliance with CEQA and NHPA Sections 106 and 110, and include project-specific recommendations for management of cultural resources.
Native American Consultation
Consultation with Native American representatives is an important part of determining potential project impacts on cultural and tribal cultural resources for supporting compliance with CEQA, including California PRC Section 21080.3.1 (Assembly Bill 52), NEPA, and Section 106 of the NHPA. WRA has considerable experience consulting with and coordinating state and federal agency consultation with Native American tribes throughout California, Oregon, and Washington.
WRA believes that early outreach and comprehensive documentation are key to successful consultation and legally defensible documents. We provide the following Native American consultation services: search results from the NAHC; outreach letters; meeting coordination and documentation; on-site meetings; consultation logs; and tribal cultural resources CEQA sections.
Cultural Resources Sensitivity Analysis
Determining cultural resources sensitivity helps reduce overall regulatory compliance costs, including supporting CEQA Categorical Exemptions, by informing project site selection and design. WRA works with you to determine the appropriate level of analysis to meet your goals. WRA’s cultural resources sensitivity analyses review existing data to determine potential project impacts on archaeological and architectural resources, and can include any or all of the following: records searches of the CHRIS; review of the NAHC Sacred Lands File; review of ethnographic literature and maps, historic aerial photography, historic maps, and previous cultural resources reports; and desktop geoarchaeological analyses. We document the methods and results of sensitivity analyses in stand-alone reports that include expert opinion on overall cultural resources sensitivity and recommendations for project design and any additional regulatory requirements.
Construction Monitoring and Training
WRA provides responsive and practical solutions for clients in need of archaeological and tribal construction monitoring services to ensure regulatory compliance and clear communication with project construction teams. Our services include not only archaeological construction monitoring, but also helping coordinate and contract with Native American monitors, and cultural resources workforce trainings. WRA experts have worked with and coordinated with Native American tribes and monitors throughout the West Coast during project construction. We focus on site-specific approaches to required monitoring and comprehensive documentation. WRA provides training modules, handouts, and monitoring reports to document these efforts. We understand the often fast-paced construction environment and are dedicated to responsive communications and quick deliverable turnaround.
Archaeological Data Recovery
Archaeological data recovery may be required for CEQA and/or NHPA Section 106 compliance in instances where project impacts to known significant archaeological resources are unavoidable. WRA carries out all stages of this work, including data recovery plans, fieldwork, laboratory analysis and cataloguing, coordinating artifact curation, and data recovery reports. We help develop an approach with applicable lead agencies and Native American representatives to ensure that, as feasible, the data recovery mitigates the foreseen impacts to archaeological resources and helps avoid any unanticipated discoveries during project implementation.
Agreement Documents and Historic Property Treatment Plans
WRA has expert experience in developing and implementing NHPA Section 106 Memoranda of Agreements (MOA[s]) and Programmatic Agreements (PA[s]), including associated Historic Property Treatment Plans (HPTP[s]). We focus on helping facilitate early consultation with the lead agency and any interested Native American tribes to develop a collaborative approach and document that fulfills regulatory requirements. HPTPs are often required as accompaniments to agreement documents and serve to guide their implementation by providing context, proscribed methods, research design, and resource significance thresholds. WRA’s experts are well versed in authoring and implementing HPTPs and ensuring consistency with agreement documents and project design.