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Maine Bulletin No. ME 180-13-1


                                                                                                                January 15, 2013

Subject: CPA – Managing Cultural Resources Workload

Purpose. To provide guidance for conservation planners with regard to the timing of cultural resources reviews. Planners need to initiate Section 106 historic preservation reviews early and should spread out their reviews throughout the year.

Expiration Date. September 30, 2013

Explanation. NRCS employees are encouraged to manage the cultural resources workload throughout the year. Federal Regulation requires all agencies to begin the Section 106 historic preservation review early in project planning. According to the Advisory Council on Historic Preservation (36 CFR 800.1[c]).

The agency official shall ensure that the Section 106 process is initiated early in the undertaking’s planning, so that a broad range of alternatives may be considered during the planning process for the undertaking.

Similary, NRCS’s national policy requires the identification and protection of cultural resources early in the conservation planning process (GM, Title 420, Part 401.20; National Environmental Compliance Handbook, Title 190, Part 610.25.C).

In an effort to manage the field office program workload, many of the cultural resources reviews are completed after ranking applications. This is understandable, but the Cultural Resources Specialist also needs adequate review time and State/Tribal Historic Preservation Officers must be allowed the full 30-day comment period granted by regulation (36 CFR 800.3). Therefore, conservation planners should, to the extent possible, complete cultural resources reviews prior to ranking applications, particularly for those applications likely to be funded. If field office employees believe a project will require a site visit or study by the Cultural Resources Specialist, please start the review process as early as possible.

Field offices are not expected to complete ME-CR-1 worksheets for every application, but for those likely to be funded in the present year or next year. Also, conservation planners are encouraged, after ranking the applications and after receiving the initial list of approved projects, to complete cultural resources reviews for a few more applicants. The additional applicants may be considered for contracts with newly available funds. By planning ahead, these extra projects would have completed Section 106 reviews and be “shovel-ready” for contracting.

As a reminder, the historic preservation review must be completed prior to the obligation of Federal funds (16 USC 470f). By taking proactive steps to manage the cultural resources workload in the field offices, NRCS will comply with the Section 106 process and provide the highest level of timely, Conservation Technical Assistance.

Contact. If you have any questions or concerns, contact Gary Shaffer, Cultural Resources Specialist, at 207-990-9566 or email

/s/  Juan C. Hernandez

State Conservationist