Archaeological finds during construction are not uncommon, especially in urban settings where centuries of American history and Native American relics may lie buried a few feet below the surface.
As an example, the recent discovery of long buried crypts during a routine water main replacement project in New York City’s Washington Square Park should serve as a reminder to developers and their contractors that a review of archaeological records should be an important part of their due diligence prior to beginning construction, according to CBRE Valuation & Advisory Services group.
In the U.S., builders are obligated to report archaeological finds if the project requires a federal, state, or occasionally local permit, license or funding that triggered compliance with historic preservation laws, according to Cris Kimbrough, Ph.D., PMP, an archaeologist and managing director at CBRE Telecom Advisory Services. If archaeological resources are identified during construction/development for a project that has gone through the federal/state/local historic preservation process, all work must stop until further preservation measures can be determined and completed.
The State Historic Preservation Office (SHPO) maintains records on identified archaeological resources in each state. In addition, museums and colleges/universities may also have records, but these are most often registered with the SHPO or held in lieu of SHPO archaeological files. These files are not accessible to the public and can only be viewed by qualified individuals—usually a qualified archaeologist or other historic preservation specialist.
Most states have a project review process wherein staff at the SHPO reviews the project plans and their files to determine if there are any potential direct or indirect impacts to historic and archaeological resources. If there are, SHPO may request archaeological or other studies be completed prior to construction. Native American tribes also maintain archaeological and other traditional cultural properties records, but access to these files is almost always restricted. Tribes are consulted regarding their cultural resources as part of the federal historic preservation process, and most state preservation processes.
If artifacts are discovered as part of the pre-development review process, then additional archaeological surveys may be required. The federal process dictates that impacts to historic and archaeological resources should be avoided, minimized, and mitigated in that order.
“Developers often talk about losing a project to SHPO, but often it is just a matter of working through the process and being creative,” said Kimbrough.
Archaeological due diligence is usually not a part normal of Phase I or Phase II Environmental Site Assessments. Builders should be aware of federal/state/local historic preservation laws and comply. An initial project review with the SHPO, when required, involves hiring qualified environmental and cultural resource management consultants who understand at a high level what the applicable historic preservation processes are.
For additional information contact Cris Kimbrough at WhitePlainsculturalresources@cbre.com.