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Last Updated: Friday, February 3, 2012 11:30 AM


Exhibit 2.8 HISTORIC PROPERTY SURVEY REPORT (HPSR) FORMAT AND CONTENT GUIDE

Exhibit 2.8 PDF version here.

Introduction

NARRATIVE HPSR FORMAT
  • Title page
  • Summary of Findings
  • Project Description
  • Summary of Identification Efforts
  • Public Participation
  • Properties Identified
  • Findings
    • HPSR to File or
    • HPSR to SHPO
  • No Historic Properties Affected Finding (as appropriate)
  • Findings for State-owned Properties
  • CEQA Impact Findings
  • Informal Views
  • Exhibits
  • Maps
  • Back-up Reports
  • Other Attachments

Don’t forget the transmittal letter for HPSRs to SHPO or THPO.

The Historic Property Survey Report (HPSR) is the summary document Caltrans uses as its consultation and decision-making document. Under Section 106 PA [1] , Caltrans uses it to request SHPO’s concurrence on determinations of eligibility or ineligibility for properties within the project APE that were evaluated as part of the project. It also is used to document Caltrans findings when there are no historic properties within the project APE, no historic properties affected, or no adverse effect with standard conditions, as explained below.

Use the “HPSR to SHPO” (State Historic Preservation Officer) whenever the findings include resources within the APE that have been evaluated as part of the project, regardless of the eligibility determination.

Caltrans uses the “HPSR to File” findings when there are no properties (regardless of eligibility) within the APE. Note, however, that the “HPSR to File” may be used when Keeper previously made a determination on, or SHPO previously concurred on, a property’s eligibility or ineligibility, the determination is still valid, and the Keeper or SHPO letter is attached. Caltrans uses the “HPSR to SHPO” to consult with SHPO on the eligibility of properties while the “HPSR to File” documents a decision made in-house for Section 106 compliance.

The HPSR also may document a Finding of No Historic Properties Affected as well as a Finding of No Adverse Effect with Standard Conditions (when using an ESA to protect a property or the project is a rehabilitation project that meets the Secretary of the Interior’s Standards for Treatment of Historic Properties [Standards])

The HPSR documents completion of the identification phase, completion of National Register eligibility evaluation of the resources within the project APE, and, when relevant, a Finding of No Historic Properties Affected or No Adverse Effect with Standard Conditions. Attach the technical study reports to the HPSR as supporting documentation. Use summary sections in the HPSR to refer to the attached supporting documents for full technical details. Provide sufficient information on cultural resource studies in the HPSR summaries so that the reader clearly can understand the reasoning behind Caltrans’ determinations of eligibility and, if applicable finding of effect. See Exhibit 2.18 for information on what needs to be in these summaries.

General HPSR Format

The HPSR may follow either a narrative format or the “short form” format included at the end of this exhibit. The HPSR short form, which is intended for use with the Section 106 PA, is available in electronic format through the Headquarters Cultural & Community Studies Office (CCSO) and on-line at the Division of Environmental Analysis website. The HPSR short form may be used when the project is simple or not large in scope or number of evaluated resources, or there are no properties within the APE. If a project is large, complex or controversial, however, it is recommended that the HPSR be prepared in narrative format instead of using the short form. Whichever format is used, be sure to include the following information as necessary in the appropriate HPSR.

Title Page

Identify project by Caltrans district, county, route, post mile limits, and EA. A brief descriptive title, such as "Minor Widening on Route 53 between Fern Creek and Matador Road," also may be used. Include the report author’s name and any co-authors as necessary.

The title page identifies the project by:

  • Name and type of investigation in a brief descriptive title, such as “Minor Widening on Route 53 between Fern Creek and Matador Road”
  • County, route and post-miles
  • Expense Authorization

The page also includes:

  • Name, title, location and signature of the Caltrans Branch Chief (EBC) for whom the report was prepared. The EBC’s signature on the title page indicates approval and acceptance of the document
  • Name, title and signature of the Caltrans Professionally Qualified Staff (PQS) or consultant PQS who prepares the report, along with the address for the PQS
  • Name, title and signature of the Caltrans Professionally Qualified Staff (PQS) who reviews the report for approval, along with the address for the PQS
  • Month and year HPSR was prepared (appears at bottom of page) If a consultant PQS prepares the HPSR, the project contract number should appear below the Expense Authorization number

If the HPSR short form is used, the title page is not necessary. The signatures appear at the end of the short form.

Summary of Findings

State the purpose of the document (e.g., to request SHPO concurrence on Caltrans’ determination(s) of National Register eligibility or ineligibility for evaluated cultural resources, and to document a proposed finding of “No Historic Properties Affected,” if applicable); and briefly summarize the results of cultural resource studies. This section is not necessary when the HPSR short form is used because the findings are summarized on the short form in Sections 7 or 8, as appropriate.

In order to minimize redundancy for Caltrans and SHPO and in the spirit of the federal Paperwork Reduction Act, if there are state-owned historical resources within the APE, state that the purpose of the HPSR also is to notify SHPO of Caltrans findings and, for buildings and structures request SHPO’s comments, on the National Register/State Historical Landmark eligibility or ineligibility of the state-owned resource(s), and if eligible, to add the eligible building(s) or structure(s) to the Master List of Historical Resources (Master List), pursuant to PRC §5024(d).

If the HPSR short form is used, the summary of findings is not necessary.

Project Description, Location and Area of Potential Effects

a) Describe the project concisely, including information on the actual physical impacts such as the horizontal and vertical extent of any ground disturbance.

b) Include a map showing the project's location (see item I below).

c) Provide a map of the area investigated, with the Area of Potential Effects (APE) delineated (see item H below).

Consulting Parties and Public Participation

Summarize coordination efforts and public comments received to date. If the project is simple, limit these to contacts (including form letter notifications) with local historical societies, Native Americans, governments, or other interest groups. Attach a phone log if appropriate. For projects involving ND/FONSIs or EIR/EISs, public involvement may include map displays or public hearings. Describe NEPA public involvement events that are expected as well as those that have occurred.

Summary of Identification Efforts

Include inventories, facilities, and persons consulted at a minimum, the following:

  • National Register of Historic Places and updates;
  • California Register of Historical Resources;
  • California Inventory of Historic Resources;
  • California Historical Landmarks;
  • The appropriate Information Center of the California Historical Resources Information System.

Note any other sources (human or archival) used, such as county assessor's records, historical society or museum archives, oral histories taken from property owners or old-timers, etc.

Briefly describe the results of the research.

Properties Identified

State whether or not there are any cultural resources within the APE. If cultural resources were identified within the APE, list them and provide pertinent information for each of them. Include concise but sufficient background and contextual information about the project area so that the reader can understand the significance (or lack of significance) of the evaluated resources. Refer to the supporting documentation, as warranted. Be sure to include summary information about National Register eligibility and whether a resource is a significant resource under CEQA. Note that Caltrans prepared documents state that a resource is eligible, while consultant prepared reports state that a resource appears eligible.

Include, as appropriate:

  1. Historic properties listed in the National Register.
  2. Historic properties previously determined eligible or not eligible for the National Register.
  3. Potentially eligible historic properties, referring to eligibility evaluations in attached supporting documentation.
  4. Properties which appear potentially eligible but for which further study is needed because evaluation was not possible (e.g., archaeological sites that require a test excavation to determine eligibility). However, this finding should not be used without District approval.
  5. Resources evaluated as not eligible for inclusion in the National Register, referring to relevant attached supporting documentation.
  6. State-owned historical buildings and structures to be added to the Master List per PRC §5024.
  7. Historical Resources for the purposes of CEQA (includes National Register and California Register listed and eligible properties, California Register listed or eligible (per State Historical Resources Commission determination) resources, resources identified as significant in surveys that meet Office of Historic Preservation standards, resources that are designated landmarks under local ordinances, and resources that meet the California Register criteria as outlined in PRC §5024.1)
  8. Resources that are not significant resources under CEQA

To facilitate SHPO’s ability to maintain the OHP's comprehensive, computerized inventories of eligible and not eligible resources, the identifying information for each resource needs to follow a specific format that includes the name of a property (if there is one), location information, the community the resource is in (or the nearest community) and the Map Reference number that is keyed to the APE map, and OHP’s historical resource status code, if available. For example:

The following properties are eligible for inclusion in National Register and are historical resources under CEQA:

Name Address/Location Community OHP Status Code Map Ref. #
Smith House 451 Main St. Anywhere, CA 2 (MR #1)
Ortega Feed Store 10097 Highway 4 Anywhere (vic.), CA 2 (MR#5)

The following state-owned buildings and structures are eligible for inclusion in the National Register and to be included in the Master List pursuant to PRC §5024(d):

Name Address/Location Community OHP Status Code Map Ref. #
Edelberg House 496 Main St. Anywhere, CA 4 (MR #25)
Summit Maintenance Stn 10099 Highway 4 Anywhere (vic.), CA 4 (MR #6)

None of the following properties are eligible for inclusion in the National Register, nor are they historical resources under CEQA:

Name Address/Location Community OHP Status Code Map Ref. #
Able’s Prune Packing Plant 35 E. Canterbury St. Someplace, CA 6 (MR #1)
Melville Apts. 8012 S. Oceanview Dr. Someplace, CA 6 (MR #5)
Little River RR Viaduct Next to SR 43, KP 10.7 El Nido, CA 6 (MR #18)

Do not list properties that meet the criteria for Section 106 PA Attachment 4 (Properties Exempt from Evaluation). Instead include the appropriate paragraph as follows:

[Name of Caltrans architectural historian or qualified consultant architectural historian] , who meets the Professionally Qualified Staff Standards in Section 106 PA Attachment 1 as an Architectural Historian or above, has reviewed the project APE and confirmed that the only other properties present within the APE, including state-owned resources, meet the criteria for Section 106 PA Attachment 4 (Properties Exempt from Evaluation).

[Name of Caltrans archaeologist or qualified consultant archaeologist] , who meets the Professionally Qualified Staff Standards in Section 106 PA Attachment 1 as a Lead Archaeological Surveyor or above, has reviewed the project APE and confirmed that the only other properties present within the APE meet the criteria for Section 106 PA Attachment 4 (Properties Exempt from Evaluation).

Provide the site trinomial (e.g., CA-TRI-433) for each archaeological site covered in the document. As some Information Centers have a backlog in assigning trinomials, using a primary number is acceptable for those counties. However, every effort should be made to acquire a trinomial for evaluated archaeological sites.

The OHP Historical Resources Status Codes were revised in August 2003. Among other changes California Register listings and eligibility determinations have been added as extensions to the code. For example “1S” means a historic property individually listed in the National Register and also listed in the California Register, while “1CS” means a property individually listed in the California Register only. As of August 2003 status code “4” applies only to state-owned resources that are included in the Master List through the PRC §5024 compliance process. See the Office of Historic Preservation's (OHP) Historical Resources Status Codes for a full list of the codes.

Findings

Select the appropriate finding for the undertaking as a whole. Under the Section 106 PA, Caltrans is authorized to make eligibility determinations as assigned by FHWA. For state-owned resources, list which ones meet National Register/State Historical Landmark eligibility criteria, state that Caltrans requests SHPO’s comments under PRC §5024, and for National Register/State Historical Landmark listed/eligible buildings and structures, that SHPO add them to the Master List per PRC §5024(d).

If Environmentally Sensitive Areas (ESAs) are used to ensure that the project will have no adverse effect on evaluated resources (i.e. No Adverse Effect with Standard Conditions—ESA under the Section 106 PA), describe the ESA here or attach an ESA Action Plan. Include all restrictions on activities within the ESA, describe how the restrictions will be enforced (e.g., by placing the restrictions in the PS&E, fencing, monitoring construction, etc.), and include the name and appropriate PQS level of the Caltrans PQS who reviewed the ESA plan. Include any other relevant information to support the proposed finding. If using the HPSR short form, summarize the finding below the appropriately checked box and refer the reader to the appropriate attachment for more detailed information. 

If the project uses the Secretary of the Interior’s Standards for the Treatment of Historic Properties (Standards) to ensure the project will had no adverse effect on historic properties (i.e. No Adverse Effect with Standard Conditions—Rehabilitation under the Section 106 PA), summarize how the project complies with the Standards and describe how that compliance will be ensured, such as review of plans and specifications at certain completion levels, monitoring during construction, etc. Include the name and appropriate PQS level of the Caltrans PQS who reviewed the work for compliance with the Standards. See Chapter 7 for more detailed information. If using the HPSR short form, summarize the finding below the appropriately checked box and refer the reader to the appropriate attachment for more detailed information. 

Findings of No Adverse Effect without Standard Conditions and Findings of Adverse Effect are not reported in the HPSR, but are including a separate Finding of Effect for the project. See Exhibit 2.9.

HPSR to File

For the following findings, the HPSR is filed in the District office, the district sends a copy to the Section 106 and History, Architecture, and Community Studies (Section 106) Branch Chief in CCSO, but the HPSR is not transmitted to SHPO for Section 106 purposes or to FHWA under NEPA delegation.

    • No properties requiring evaluation are present within the project APE. [This refers to properties exempt from evaluation pursuant to Section 106 PA Attachment 4. and because there is nothing there, as explained in the Properties Identified section of the HPSR].
    • Properties previously determined not eligible for the National Register in consultation with the SHPO, or formally determined not eligible by the Keeper of the National Register are present within the project APE. Copy of SHPO/Keeper correspondence is attached. [This assumes that appropriate Caltrans PQS confirmed the prior determinations of eligibility are still valid.]
    • Properties previously determined eligible for the National Register in consultation with the SHPO, or formally determined eligible by the Keeper of the National Register are present within the project APE, but will not be affected by the undertaking. Copy of SHPO/Keeper correspondence is attached. [This assumes that appropriate Caltrans PQS confirmed the prior determinations of eligibility are still valid.]
    • As assigned by FHWA, Caltrans has determined a Finding of No Historic Properties Affected, according to Section 106 PA Stipulation IX.A and 36 CFR 800.4(d)(1), is appropriate for this undertaking.

    HPSR to SHPO

    For the following findings, the District transmits the HPSR to SHPO and sends a copy to the Section 106 Branch Chief in CCSO, in CCSO’s role as FHWA under NEPA delegation:

    • As assigned by FHWA, Caltrans has determined that within the project APE there are properties that were evaluated as a result of the project that are not eligible for inclusion in the National Register within the project APE. Under Section 106 PA Stipulation VIII.C, Caltrans requests SHPO’s concurrence in this determination.
    • As assigned by FHWA, Caltrans has determined that within the project APE there are properties evaluated as a result of the project that are eligible for inclusion in the National Register within the project APE. Under Section 106 PA Stipulation VIII.C, Caltrans requests SHPO’s concurrence in this determination.
    • As assigned by FHWA, Caltrans has determined a Finding of No Historic Properties Affected, according to Section 106 PA Stipulation IX.A and 36 CFR 800.4(d)(1), is appropriate for this undertaking and is hereby notifying the SHPO of this finding.
    • As assigned by FHWA, Caltrans has determined a Finding of No Adverse Effect with Standard Conditions - ESAs, according to Section 106 PA Stipulation X.B(2) and 36 CFR 800.5(b), is appropriate for this undertaking and is hereby notifying the SHPO of this finding.
    • As assigned by FHWA, Caltrans has determined a Finding of No Adverse Effect with Standard Conditions – Rehabilitation, according to Section 106 PA Stipulation X.B(2) and 36 CFR 800.5(b), is appropriate for this undertaking and is hereby notifying the SHPO of this finding. _________[Name], who meets the Professionally Qualified Staff Standards in Section 106 PA Attachment 1 as Principal Architectural Historian, and has the appropriate education and experience, has reviewed the rehabilitation documentation and determined that the rehabilitation meets the Secretary of the Interior’s Standards for the Treatment of Historic Properties .

    HPSR: Tribal Lands, THPO Consultation or When FHWA Is Not Lead Agency

    The Section 106 PA does not apply to undertakings that occur on or affect tribal lands, or for consultation with Tribal Historic Preservation Officers (THPO). It also does not apply when FHWA is not the lead agency for the federal undertaking. When FHWA is the lead agency and the Section 106 PA covers that undertaking, other federal agencies (issuing permits or otherwise providing assistance) are not obligated to use the Section 106 PA to fulfill their Section 106 responsibilities. See Chapter 2 Section 2-2.1 and Exhibit 1.1 Stipulation I. For undertakings where the Section 106 PA does not apply, the narrative HPSR should be used. The consultation language needs to cite the appropriate sections of 36 CFR 800 and not the stipulations in the Section 106 PA.

    For instance, instead of using a summary paragraph to cite properties exempt from evaluation under Section 106 PA Attachment 4, the HPSR needs to refer to the Letter Report (see Exhibit 6.1). The Letter Report is prepared by an appropriate PQS and is used when the Section 106 PA does not apply and there are properties in the APE 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.

    Because Findings of No Adverse Effect with Standard Conditions (either ESA or rehabilitation) are stipulations in the Section 106 PA, they may not be used when a project is on or affect tribal lands, for consultations with THPOs, when FHWA is not the lead federal agency or when other federal agencies, in issuing permits or providing assistance, choose not to use the provisions in the Section 106 PA. For these reasons Findings of No Adverse Effect and Findings of Adverse Effect are not reported in the HPSR, but are included a separate Finding of Effect for the project. See Exhibit 2.9.

    Follow the guidance elsewhere in this exhibit for all sections of the HPSR except for Properties Identified where the Letter Report is used instead of Section 106 PA Attachment 4, HPSR to File, and HPSR to SHPO.

    HPSR Findings Under Regular Section 106 Process

    Under the regular Section 106 process, the HPSR is filed in the District office, the district sends a copy to the Section 106 Branch Chief in CCSO and the HPSR is transmitted to SHPO/THPO for Section 106 purposes. The HPSR includes the one or more of following findings:

    • There are no cultural resources within the APE.
    • The only/only other properties within the APE 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, as described in the attached Letter Report prepared by ___________ (Name and indicate whether person is Caltrans or consultant architectural historian or archaeologist), who is a(n) _____________ (Indicate applicable PQS level and attach the Letter Report.) [Because the Section 106 PA does not apply, a Letter Report needs to be prepared. See Exhibit 6.1.]
    • Properties previously determined not eligible for the National Register in consultation with the SHPO/THPO, or formally determined not eligible by the Keeper of the National Register are present within the project APE. Copy of SHPO/THPO/Keeper correspondence is attached. [This assumes that appropriate Caltrans PQS confirmed the prior determinations of eligibility are still valid.]
    • Properties previously determined eligible for the National Register in consultation with the SHPO/THPO, or formally determined eligible by the Keeper of the National Register are present within the project APE, but will not be affected by the undertaking. Copy of SHPO/THPO/Keeper correspondence is attached. [This assumes that appropriate Caltrans PQS confirmed the prior determinations of eligibility are still valid.]
    • As assigned by FHWA and pursuant to 36 CFR 800.4(a) and (b), Caltrans has determined that the APE and the scope and level of the identification efforts are adequate for this undertaking, and requests SHPO/THPO’s concurrence in this finding.
    • As assigned by FHWA and pursuant to 36 CFR 800.4(c), Caltrans has determined that within the project APE there are properties evaluated as a result of the project that are not eligible for inclusion in the National Register within the project APE, and requests SHPO/THPO’s concurrence in this determination.
    • As assigned by FHWA and pursuant to 36 CFR 800.4(c), Caltrans has determined that within the project APE there are properties evaluated as a result of the project that are eligible for inclusion in the National Register within the project APE, and requests SHPO/THPO’s concurrence in this determination.
    • As assigned by FHWA and pursuant to 36 CFR 800.4(d)(1), Caltrans has determined a Finding of No Historic Properties Affected is appropriate for this undertaking, and is hereby notifying the SHPO/THPO of this finding.

    Concurrent State Compliance

    For federal undertakings, the HPSR serves as simultaneous documentation for Caltrans compliance with CEQA and, for state-owned resources, compliance with Public Resources Code (PRC) §5024. However, when the Caltrans project is not a federal undertaking (e.g., state-only projects), use the Historical Resources Compliance Report to demonstrate compliance with CEQA and PRC §5024; see Chapter 2 and Exhibit 2.15 .

    Findings for State-Owned Properties

    When there are state-owned cultural resources in the APE, Caltrans needs to document compliance with PRC §5024, even when the project is a federal undertaking. To avoid redundancy, the HPSR also is used to document PRC §5024 compliance for a federal undertaking with state-owned properties. Caltrans may need to submit the HPSR to SHPO, pursuant to PRC §5024, even when the finding is “no historic properties affected” under Section 106. When the District sends the HPSR to SHPO under Section 106, it also notifies SHPO and, for buildings and structures, requests SHPO’s comments pursuant to the applicable sections of PRC§5024, both in the HPSR itself and in the transmittal letter. In addition to sending the HPSR and transmittal letter to the Section 106 Branch Chief in CCSO for Section 106 compliance, a copy of the transmittal letter also is sent to the Built Environment Preservation Services (BEPS) Branch Chief for concurrent PRC §5024 compliance documentation.

    See Environmental Handbook Chapter 2 Sections 2-7.9 and 2-9 and Exhibit 2.15 for the more information on what to include. The Sample HPSR short form in this exhibit also contains the range of findings that might apply.

    Findings of adverse effects to state-owned historic properties would not be included in the HPSR, but would be included in the Finding of Effect, see Exhibit 2.9.

    CEQA Impact Findings

    In order to minimize redundancy for Caltrans and to document compliance, CEQA impact findings may be included in the HPSR as a separate section. Consultation with SHPO is not required under CEQA. See Environmental Handbook Chapter 2 Section 2-9 and Exhibit 2.15 for the more information on what to include. The Sample HPSR short form in this exhibit also contains the range of findings that might apply.

    Findings of substantial adverse change would not be included in the HPSR, but would be included in the Finding of Effect, see Exhibit 2.9.

    Exhibits

    Include the following exhibits as applicable. If using the HPSR short form, these items are listed in “Section 6 List of Attached Documentation,” and attached to the short form.

    Location Map, Project Vicinity Map and APE Map

    Include, at minimum, a map showing project location and vicinity, and a project APE map illustrating the proposed project, upon which the APE limits have been delineated. If no cultural resources are present and a “HPSR to File” HPSR is used, the project APE map must simply be of sufficient scale to document the APE.

    If cultural resources are present, the project APE map must be of sufficient scale (200' scale is preferred) and have enough project detail to demonstrate the relationship of historic properties to the proposed project, especially important if the HPSR serves to document a Finding of No Historic Properties Affected or a Finding of No Adverse Effect with Standard Conditions. Clearly show the APE, the location of all properties discussed, the boundaries of any eligible or listed historic properties, and the boundaries of any ESAs used. Include a scale and north arrow.

    If there are historic properties, the APE map should be drawn to encompass the boundaries of any National Register listed or eligible properties (including previously determined eligible and newly evaluated as eligible properties). It is permissible to indicate an Area of Direct Impact (ADI), but the ADI must be entirely within the APE.

    Photographs and Other Exhibits

    Include other appropriate exhibits. Good clear exhibits and graphics are invaluable to demonstrate the arguments and decisions discussed made in the text.

    Photos and graphics, which illustrate the following, can enhance the HPSR’s effectiveness as a consultation tool:

    • Integrity (or lack of it) of cultural resource(s)
    • Integrity of setting for cultural resource(s),
    • Engineering plans,
    • Profiles and cross-sections which show the actual limits of project effects,

    SHPO's copy of the HPSR should either contain original photographs or scanned images that are clear when printed out.

    Attachments

    Include, as appropriate:

    • Archaeological Survey Report, Extended Survey Report, Archaeological Evaluation Report
    • Historical Resources Evaluation Report
    • Bridge Evaluation or appropriate Caltrans Historic Bridge Inventory sheet(s)
    • Test Excavation Report
    • Letters from historical societies, Native American groups, local governments, other special interest groups, and the SHPO, etc.
    • Phone logs that document consultation

    HPSR Preparation and Caltrans Approval

    Under the Section 106 PA the Caltrans PQS or a qualified consultant prepares the HPSR. HPSRs need at least three reviews:

    • Peer review of the draft HPSR by District or CCSO PQS, at the appropriate level for the contents of the HPSR
    • Review of the final HPSR for EBC approval District or CCSO PQS, at the appropriate level
    • Review and approval of the final HPSR by the EBC

    Because HPSRs perform different functions, depending on what stage of the Section 106 process is being documented, the Caltrans PQS certification level needed to conduct the peer review and review for approval will change. Chapter 2 Section 2-5.5 explains the reasons why certain HPSRs require a higher level of Caltrans PQS peer review, while Exhibit 2.11 Table C contains a chart with the various HPSRs findings and who is certified to conduct peer review and review for approval. However, Caltrans PQS at the level appropriate to the type of cultural resources in the APE must peer review and review for approval all attached documentation supporting Section 106 findings (e.g., ASRs, AERs, HRERs, etc.).

    After the draft HPSR has been peer reviewed and any necessary revisions are made, the Caltrans PQS or consultant who prepares the HPSR signs, dates the final HPSR and includes his/her discipline, PQS level (as applicable) and District/Headquarters or affiliation. The Caltrans PQS reviewing the HPSR for approval likewise signs, dates, and includes his/her PQS discipline, level and District. If the Caltrans PQS document preparer is certified at the appropriate level to conduct reviews for approval[2] , his or her signature on the final document also signifies review for EBC approval. The EBC signs and dates the HPSR to signify approval.

    NEPA Delegation

    As of July 2007, Caltrans has assumed all FHWA responsibilities for compliance under the National Environmental Policy Act (NEPA). This includes FHWA’s Section 106 responsibilities. Under NEPA delegation, the DEA-CCSO has assumed FHWA's responsibilities for purposes of compliance with Section 106. For NEPA Categorical Exclusions (NEPA C.E.), Caltrans was assigned that authority under U.S.C. 326. For the other NEPA compliance, Caltrans was assigned that authority under U.S.C. 327. Caltrans findings under NEPA delegation should reflect that Caltrans is making the finding, as assigned by FHWA. For instance, when making a finding of No Historic Properties Affected, the statement should read, “As assigned by FHWA, Caltrans has determined a Finding of No Historic Properties Affected, according to Section 106 PA Stipulation IX.A and 36 CFR 800.4(d)(1), is appropriate for this undertaking.”

    For more information on NEPA delegation, please refer to Chapter 38 of the Caltrans Standard Environmental Reference (SER). Section 106 findings that Caltrans makes now should reflect this.

    HPSR Short Form

    Caltrans has developed an HPSR short form template that may be used in conjunction with using the Section 106 PA. Using the short form is optional; using a narrative HPSR always is another option. The short form is best used for simple projects, such as

    • Projects that are not large in scope,
    • Projects that do not contain a large number of evaluated resources, or
    • Projects for which no cultural resources or properties are located within the APE

    Sections 3 through 10 contain the most frequently used statements and conclusions. One or more statement in these sections may apply, depending on the project. Statements that do not apply may be deleted.

    To ensure consistency and to facilitate faster reviews of the HPSR, the headings are write-protected, and different versions of the document can be saved under a different name using the “Save As” command in Microsoft Word. If a section is not applicable, the heading will remain and the “Not Applicable” box may be checked. Deleting most of the instructions and irrelevant statements can shorten the short-form. Since the short-form is in a table format in Word, to delete the irrelevant lines:

    • Highlight the row(s) of text or space to be deleted
    • On the menu, click on Table (or its appropriate icon), then
    • Click on “Delete,” and the lines should disappear

A sample of the HPSR short-form template appears on the following pages. The template appears to be very long because it contains the range most commonly used statements with the appropriate language for each finding; those that do not apply may be deleted for the reasons stated above.

Sample HPSR Short Form

Sample Form 1
Sample Form 2



[1] Programmatic Agreement Among the Federal Highway Administration, the Advisory Council on Historic Preservation, the California State Historic Preservation Officer, and the California Department of Transportation Regarding Compliance with Section 106 of the National Historic Preservation Act as it Pertains to the Administration of the Federal-Aid High-way Program in California.

[2] At a minimum Lead Archaeological Surveyor or Architectural Historian level or above; see Exhibit 2.11 Table C