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Review
Process

Step One – Records Check • Step
Two - Inventory • Step Three -
Evaluation • Step Four – Impact Assessment • Step
Five - Mitigation • Review Process – The Players • Planning
for Preservation • Coordinate and Communicate • Summary
of Points to Remember
back to Review & Compliance

Step One – Records Check
• Check records to determine
if previously recorded cultural resources are in the project area
• Assess the potential
for finding intact cultural resources in the project area
• Determine if cultural
resources survey is needed
The developer will request an official site records check from
the Arizona State Museum. The records check can be done quickly,
easily, and inexpensively. To request a site records check, contact
the Arizona State Museum Site Records Office at 520-621-2096.
The results of the records check will contribute to the determination
of the next step in the process by the Cultural Resources Office.
For instance, if the project area has been surveyed within the
last ten years and no cultural or historic resources were found,
the Developer can submit the records check form with the development
review materials for County review and a cultural resources clearance
can be issued. If the records check reveals that the project area
has not been surveyed, the County will require cultural resources
survey and mitigation, if necessary, before a clearance can be
issued.
Step Two - Inventory
• Cultural Resources
Survey: An on-the-ground inspection of the project area and
all areas related to the project
• Requires the services
of a professional archaeologist or architect, or both, as needed
• A report documents
all cultural resources, or their absence, in the project area
Cultural resources survey requires hiring a professional in archaeology
or architecture who meets the professional standards of Arizona.
Step Three - Evaluation
Apply the Criteria of Significance of the
National Register of Historic Places
• A – Associated
with significant events
• B – Association
with significant persons
• C – Associated
with a type, period, or method of construction…
• D – Information
important to history or prehistory
All cultural resources documented in a county project area are
evaluated for their eligibility to be listed in the National Register
of Historic Places.
• This is the nation’s honor role of places considered
to be important to the history of the American people at the national,
state, or local level.
• The criteria were developed
by the National Park Service and are used as a national standard.
• Any cultural resource that meets one or more of the criteria is considered “significant” and
is eligible for the National Register.
• Any cultural resource that is not eligible for the National Register
is not considered “significant” and usually requires no further
consideration. Exception: roadside shrines.
Step Four – Impact Assessment
Assess Impacts to National Register
eligible sites
• Will the proposed
project adversely affect the characteristics that make the site
eligible for listing?
• If yes, prepare mitigation
plan
• If a project will
not negatively affect a National Register eligible site, or the
project can be modified to avoid affecting the site, then a mitigation
plan is not needed and the project can continue
In such cases, a stipulation might be added; for instance, a conservation
easement identified to ensure protection of the cultural resource.
The preferred means of treating effects to, or impacts on, National
Register eligible sites is avoidance and preservation in place.
Avoidance is the quickest and cheapest way to deal with the problem
and the best way to protect and preserve cultural resources.
If that is not possible, or desirable, and a National Register
eligible cultural resource will be affected, then mitigation is
required.
Step Five - Mitigation
• Mitigation Plan: A
strategy for minimizing harm to National Register sites.
• Typical mitigation
options:
- restore/reuse/rehabilitate
- relocate
- record/research/recover
data
Mitigation means doing something to either preserve the actual
cultural resource itself or to recover information about the cultural
resource before it is destroyed through construction.
What is done to mitigate effects to the cultural resources will
depend on what the resource is, why it is important, and how it
will be affected.
The options can range in scope from a simple monitoring plan to
full scale excavation, analysis, curation, and report preparation.
Review Process – The Players
• Private developers
- you
• Cultural Resource
Office - us
• State Historic Preservation
Office - them
• Other State agencies
- ADOT, ASLD
• Federal government
- COE, EPA, USFWS
• Tribes – Tohono
O’odham, Yaqui, Apache, and others
• Public – TPCHC
and others
Throughout the review process, reports are generated by professional
archaeologists or architects, as applicable, and these reports
are reviewed by the Cultural Resources Office.
As mentioned, however, there are often other players in the review
process, including you.
As the developer, it is your responsibility to communicate
with us. In turn, it is our responsibility to be responsive to
your needs. For instance, we will ensure that if other reviewers
are involved, we coordinate with them so that your project gets
through the review process.
We will keep you informed and work to resolve any problems that
might arise. A primary responsibility of the Cultural Resources
Office is to see that county cultural resources requirements are
met, but we’re also here to assist you through the process
and to help you obtain the necessary approvals so that you can
successfully complete your project.
Planning for Preservation
• Project Review is
mandatory
• Required information
• What is the project?
• Where is it located?
• Who is doing the work?
• When will the work begin?
• Are state and/or federal permits necessary?
The bottom line is that we may have a lot to talk about regarding
your project.
It is important that we hear from you early in the project’s
planning stages so that if there are National Register eligible
properties that may be affected, we can quickly take steps to help
you mitigate effects.
The list of questions above includes the critical questions that
we will be asking about your projects.
Coordinate and Communicate
• Integrate preservation
planning into your project schedule – be proactive, not reactive
• Consult with us during
the design phase – early is better than late – allow
time for consultation
• Send your plans to
the appropriate county agency for each required review, and they
will forward the materials to us for review
• Keep us in the loop – design
changes, etc.
We can provide you with timely, professional advice regarding cultural
resources requirements. We can also advise you about the county
review process.
It is our responsibility to assist you in meeting the requirements
as much as it is our obligation to see that they are met.
Good communication and coordination are needed to make this happen.
Summary of Points to Remember
Here is a summary of important points and things to remember
that will allow us to assist you.
• Cultural Resources
have value
• County, state, and
federal law protect these values
• Consultation is mandatory
for development projects in Pima County
• There is an established
review process
• Other parties may
be involved in the review process
• Compliance takes time
and costs money
- Consult with us early in planning process – anticipate
- Provide us with
critical project information
- Coordinate compliance
with your project schedule
• Good communication
is the key to the review process
- Keep us
in the loop and we’ll keep your project on track

Flow Chart • Step
One – Records
Check • Step
Two - Inventory • Step Three - Evaluation • Step
Four – Impact Assessment • Step Five
- Mitigation • Review Process – The
Players • Planning for Preservation • Coordinate
and Communicate • Summary of Points to
Remember
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