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Last Updated: Friday, February 3, 2012 11:30 AM
Exhibit 6.1 Cultural Resources Letter Report Format and Content
- Use of the Cultural Resources Letter Report
- Cultural Resources that Clearly Lack Significance
- Letter Report Format Peer Review and Approval
Narrative Letter Report Format
- Project Reference
- Project Undertaking
- Research Methods
- Background Research
- Description of Resource(s)
- Statement of Non-significance
When Caltrans has an undertaking on or affecting Tribal Lands, the Section 106 Programmatic Agreement (Section 106 PA) does not apply. In this situation, Caltrans uses the Cultural Resources Letter Report (Letter Report) to consider cultural resources that normally would be exempted under Section 106 PA Attachment 4. The Letter Report is used to justify that certain historical archaeological and built environment cultural resources are not eligible for inclusion in the National Register of Historic Places (National Register).
Caltrans also uses the Letter Report for projects that are federal undertakings but do not involve the Federal Highway Administration (FHWA). The Section 106 PA does not apply because FHWA is not involved. Examples of projects that are federal undertakings but do not involve FHWA include, but are not limited to projects for which Caltrans must obtain a permit from the U.S. Army Corps of Engineers or the U.S. Coast Guard, or projects in which Caltrans needs to perform work on U.S. Forest Service land.
It is not necessary to use the Letter Report for state-only projects affecting Tribal Lands unless there is a federal nexus as described above. There may be situations in which the District, at its discretion, would choose to use the Letter Report on state-only projects. However, in using the Letter Report to justify that certain cultural resources lack National Register significance, for CEQA purposes it also is necessary to include information on why the affected resources would not qualify as historical resources for purposes of CEQA.
The Letter Report is reserved for cultural resources that clearly lack significance either due to loss of integrity or the absence of historical associations or research values that would qualify the cultural resource as eligible for inclusion in the National Register of Historic Places or would make it a historical resource for purposes of CEQA. Section 106 PA Attachment 4 may be used for guidance to document that a resource clearly is not National Register eligible:
- When archaeological resources are the subject of the Letter Report, a Caltrans PQS archaeologist at the Lead Surveyor level or above or appropriately qualified consultant who meets the standards in Section 106 PA Attachment 1 completes the Letter Report.
- When the cultural resources in question are minor, ubiquitous or fragmentary infrastructure elements, or are less than thirty years old, a Caltrans PQS archaeologist at the Lead Surveyor level or above, Caltrans PQS at the Architectural Historian level or above or appropriately qualified consultant who meets the standards in Section 106 PA Attachment 4 completes the Letter Report.
- For built environment resources that are between 30 and 50 years of age, fifty years old or older and have been moved in the past fifty years, or fifty years old or older and have been altered, a Caltrans PQS at the Architectural Historian level or above or qualified consultant who meets the standards for Architectural Historian outlined in Section 106 PA Attachment 4 completes the Letter Report.
As this Letter Report follows standard Caltrans correspondence guidance, include the appropriate information as follows:
- Date: Enter the date the report is finalized (following required peer review).
- Project Reference: Indicate the district, county, route, post mile, project name, and expenditure authorization.
- Addressee: List the name title, office name and location of the Caltrans Environmental Branch Chief for whom the report was prepared.
- Evaluator/Author: A Caltrans PQS at the Lead Surveyor level or above, Caltrans PQS at the Architectural Historian level or above, or an appropriately qualified consultant, as appropriate, signs the Letter Report after peer review has been completed.
Include the following information in the body of the letter:
- Project Undertaking: Succinctly describe the scope and purpose of the undertaking, referring to the Historic Property Report (HPSR) for detailed descriptions.
- Research Methods: Describe sources consulted and field inspection methods. Refer to the project Archaeological Survey Report (ASR) or Historical Resources Evaluation Report (HRER) as appropriate to eliminate redundancies.
- Background Research: Discuss available information regarding the historical associations and use of the property and results of the research. If a detailed historical context or research discussion is necessary, the Letter Report is not appropriate.
- Description of Resource: For archaeological sites, briefly describe the physical remains present at the site and its condition vis-à-vis the seven aspects of integrity, but refer to the DPR 523 forms for detailed descriptions. For built environment resources briefly describe the property type, its date of construction, date moved, date of alterations, as appropriate (e.g., single-family residence built in 1977).
- Statement of Non-Significance: Provide a cogent statement of the reasons why this cultural resource is clearly not eligible for the National Register and also is not a historical resource under CEQA.
- Vicinity Map (unless provided in HPSR and identified as such)
- Project Location Map (Portion of USGS 7.5' quadrangle), unless provided in HPSR and identified as such
- Appropriate DPR 523 form(s).
As with all cultural resources documents, for historical archaeological resources Caltrans PQS certified at the Co-Principal Investigator—Historical Archaeology level or higher must peer review the draft Letter Report. For built-environment resources, Caltrans PQS certified at the Architectural Historian or higher must peer review the draft Letter Report. Peer reviewers in both disciplines should follow the guidelines in Exhibit 2.14: Guidelines for Peer Review of Cultural Resources Reports. Peer reviewers’ names should be kept on record and comments retained in the project files.
Only Caltrans PQS Co-Principal Investigator—Historical Archaeology or Architectural Historian level or higher may review Letter Reports for approval. The Caltrans PQS or consultant who prepares the final Letter Report signs, dates and includes the appropriate discipline, PQS level (as applicable) and District/Headquarters or affiliation. The Letter Report then is attached to the HPSR. When the Caltrans PQS reviewing the HPSR for approval and the DEBC both sign and date the HPSR, indicating their approval, the Letter Report is considered to be approved.