Leveraging Cultural Resources Management to Mitigate Risk

While no one likes to consider the “worst-case scenario,” cultural resources management (CRM) teams focus on analyzing these concerns to anticipate challenges and avoid risk.  

A CRM team is utilized when a project site has the potential to contain items or data of historical, archeological, or cultural significance. Under the California Environmental Quality Act (CEQA), any building or archaeological site older than 45 years is potentially eligible for the California Register of Historical Resources and must be evaluated as a potential historic resource. 

There are several ways skilled CRM teams can gauge the probability of finding issues before they arise and avoid legal, financial, or regulatory repercussions for a project proponent.  

Analyzing for Historical Significance

CRM professionals exist in the space between developers, lead agencies, and historic stakeholders. To ensure success, these experts facilitate conversation between these groups, as well as inform and guide the project to a satisfactory resolution while protecting places of cultural significance.  

Determining historical significance is like a math problem – to be successful, you must show your work. If you only look at the current site or status (i.e., the “solution,” or result of the problem), it is easy to miss elements of significance. For example, if the site contains a dilapidated shed from 1960, it would be understandable to dismiss the structure and tear it down without considering the risk.  

However, determining cultural or historical significance requires following the trail back to the beginning (i.e., showing your work). What looks like a crumbling warehouse might be the last remaining building from a historically important industrial complex. Suddenly, this structure is historically significant, as well as legally protected under CEQA.  

Determining Eligibility by Applying Criteria

Determining the path forward after a potentially significant cultural find depends on what item or items were uncovered. For example, finding human remains has a very clear protocol involving state and federal officials. If the remains are of Native American heritage, additional provisions are triggered for locating descendants and treating the remains with proper decorum and respect.  

Other findings, while interesting, may not require remedial action. Items of significance are those that contain contextual data that researchers in the future can find useful. A single arrowhead discovered at a site, for example, may not require action if not discovered within the context of a broader archaeological site (also known as an isolate). On the other hand, a clay vessel discovered in the context of a historic trash heap may help define historical distribution patterns of pottery that may require documentation and further study. 

To be eligible for historic or cultural significance under CEQA, a site or structure generally must meet one of the following criteria:  

1. Must be associated with an important event
2. Must be associated with people of historical significance 
3. Must be the work of an architectural master 
4. Must contain the potential for historic or cultural data

CRM Methods and Guidance

CRM professionals begin their work by taking stock of the project site and the surrounding area. They visit the site to gain a sense of the scope of the project, note any features located nearby, as well as any significant findings in the vicinity. Then, they gather data and determine what steps should be taken in order to protect potential cultural resources and ensure legal responsibility.  

These experts have access to confidential records not available to the public (so as not to invite public disturbance to an archeological site with historic significance) to determine what events have taken place at a particular site. Additionally, they look at proximity to resources, such as a historic water source, to determine the probability of subsurface archaeological sites. 

CRM teams also rely heavily on archaeological and historical data. For example, if in their research it is discovered that a project site is located near three separate archeological sites, the probability of significant findings at the new site is higher. Other methods can include autonomous aerial drone surveys, geographic information system (GIS) usage, and more. 

Consultants analyze their findings to determine if action is necessary or if the discovery can simply be recorded. They may also prepare documentation, such as Environmental Impact Reports (EIR) or a Cultural Resource Assessment, to assist with regulatory compliance.   

Without CRM guidance, developers may assume there is no risk and begin building a multi-million-dollar project, only to discover a Native American burial ground or sensitive resource within their project boundary. When that happens, the development is immediately halted which can have serious adverse impacts on project finances, construction crews, and other valuable project assets. 

Investing in a third-party CRM consultant team helps avoid this problem, saving all parties time, money, and headaches.

The Importance of a CRM Team

Many factors must be considered to protect historic resources as well as clients and stakeholders. On-site monitors from third-party consulting firms can train construction crews regarding what to look for in a potential item or artifact.  

It is important to note that a determination that a site has historical or cultural significance does not necessarily mean work cannot be continued. Some findings may require little or no mitigation efforts, and if solutions are required, a CRM team can expedite the process of getting back to work. 

While it’s impossible to see through a building’s foundation or through the ground to precisely predict findings, CRM professionals are experts in anticipating the unknown to the best of their abilities. Although a project delay is frustrating, it is preferable – and less expensive – than unknowingly disturbing, destroying, or disregarding items of historical, archeological, or cultural significance.  

Firms like FirstCarbon Solutions (FCS) with an in-house CRM team can accurately and safely ascertain the probability of discovering significant items and determine the best remediation solutions, recommending solutions, alternatives, and mitigation programs to keep your project on track.  

FirstCarbon Solutions (FCS), an ADEC Innovation, comprises more than 100 individuals offering due diligence, technical analysis, planning, environmental compliance, permitting, and mitigation/monitoring services for public and private projects. FCS has more than 35 years of experience navigating the complexities of CEQA and securing project approvals. Contact us for a free consultation to learn more about how we can help with your specific requirements.