If your project uses federal funds or needs a federal permit, or if it disturbs ground that could hold historic properties, you will likely need an archaeological survey. The Section 106 Applicant Toolkit ties that requirement to ground-disturbing work. The work moves in three phases, each needing agency or SHPO review. Each added phase adds time and cost, so early coordination matters.
TL;DR:
- State, local, and tribal rules can require surveys without a federal connection; build a feasibility stage compliance matrix listing approvals, agencies, and review steps.
- Phase I may end review if no historic properties are identified or affected; otherwise, Phase II tests eligibility, and Phase III addresses unavoidable adverse effects.
- A Streamlined Review Process may shorten timelines when SHPO concurs on identified historic properties, documentation supports No Adverse Effect, and records remain complete.
- Contact tribes and agencies before applying, share usable project maps, and seek input on site placement; late archaeological work can force costly redesign after engineering.
- Itemized proposals should tie costs to survey area, sensitivity, season, testing, and possible mitigation; contracts should allow changes as findings add phases.
Table of Contents
- What is an archaeological survey, and what triggers one?
- How do Phase I, II and III investigations work?
- Which survey methods and field techniques will you see?
- How does Section 106 consultation work with SHPOs, THPOs and tribes?
- How do you scope, procure, schedule and budget a survey?
- How does early coordination with tribes and agencies reduce risk?
- What do local, state and tribal rules add beyond Section 106?
- How should you communicate with the community and stakeholders?
- How do survey findings shape land use and master planning?
- How do you coordinate archaeological surveys with other assessments?
- A planner's view: treat archaeology as a managed deliverable
- Where can we help you plan around archaeological risk?
- FAQ
- Sources
What is an archaeological survey, and what triggers one?
An archaeological survey is a systematic inspection of land to locate and record archaeological resources. It differs from excavation in a way that matters to your budget: a survey identifies and documents, while data-recovery excavation removes material and is reserved for sites that cannot be avoided. Practical survey workflows combine background research, remote sensing, fieldwalking, geophysics, and targeted subsurface testing to find out what is on a parcel before anyone commits to a design.
The most common federal trigger is Section 106 of the National Historic Preservation Act. Requirements apply to ground-disturbing work such as utility trenches, foundation work and site grading when the project uses federal funds or requires federal permits. State and local rules can add their own triggers, which we cover later in this article.
Two concepts frame the scope of any review:
- Area of Potential Effects (APE): the geographic area where the project may directly or indirectly change historic properties. Agencies define it, and it sets the boundaries of the survey. The NPS Nationwide Programmatic Agreement guidance explains how it is used in review.
- Ground disturbance: grading, trenching, foundation work and utility installation all count. A small parcel with deep utility work can trigger review as readily as a large one.
Roles are worth settling early. The federal agency initiates Section 106. In practice, applicants may fund the studies, keep the records and coordinate the consultants, and they can help inform the APE by supplying existing information about the site. Be prepared to manage compliance tasks as part of the project team.
How do Phase I, II and III investigations work?
The process is staged so that further work can be informed by earlier findings. SHPO or agency review is needed before moving to the next phase.
Phase I, identification. Archaeologists conduct background research and survey to identify resources. The findings inform recommendations for next steps. ACHP's archaeology Q&A clarifies when archaeologists and consulting parties should be engaged at this stage. If no historic properties are identified or affected, the agency may determine that no further review is needed. Phase II, evaluation. Testing or targeted subsurface work assesses whether a site meets National Register criteria. Eligibility rests on criteria A through D and on sufficient testing under professional standards. Phase II testing is generally intended to evaluate significance, rather than serve as a full excavation. Phase III, mitigation or data recovery. This phase may apply when an adverse effect cannot be avoided. Options include data-recovery excavation, redesign to avoid the site, or other agreed mitigation. The appropriate approach depends on consultation and the circumstances of the project. 4. Decision points between phases. The agency and SHPO decide whether a site is eligible and whether the effect is adverse. Your schedule depends on how quickly reports are submitted and reviewed, so build review time into the calendar rather than assuming approvals are instant.
The practical consequence: the Phase I findings can indicate whether further work may be needed. Use the report to inform your contingency planning.
Which survey methods and field techniques will you see?
Methods range from non-intrusive to intrusive. A well-scoped survey selects methods suited to the site and project. Knowing the options helps you read a consultant's proposal and ask sharper questions.
- Desk-based research: records searches, archival review and a check of recorded sites in GIS. This shrinks field time by pointing crews at the areas that matter, as the archaeological survey toolkit describes.
- Aerial and remote sensing: methods such as drone photogrammetry, LiDAR and orthophotos can help planners examine terrain features before fieldwork.
- Geophysical methods: ground-penetrating radar, magnetometry and resistivity can help identify possible buried features without digging. Anomalies are leads, not answers, and may call for follow-up testing.
- Surface survey (fieldwalking): crews walk the land in transects and record artifacts and features. It works best with good ground visibility. Dense vegetation or plowed fields can hide or scatter evidence, which affects when you should schedule fieldwork.
- Intrusive testing: shovel tests, auger probes and test units, used mostly in Phase II to judge integrity and eligibility. This is sample-based testing, which is different from full excavation.
- Construction monitoring: an archaeologist observes ground disturbance during construction, sometimes in addition to prior testing. Whether it is appropriate depends on the survey findings and project conditions.
Monitoring has contract consequences. Consider including a stop-work protocol for discoveries, a response procedure for the archaeologist, and clarity on who pays for delay. Our construction surveying team coordinates field work like this, and our surveying services page outlines the field survey types we handle.
Pro Tip: Ask every proposal to state which method it will use in which part of the parcel and why. A single method applied everywhere often means higher cost or lower confidence.
How does Section 106 consultation work with SHPOs, THPOs and tribes?
Section 106 requires federal agencies to consider effects on properties listed in or eligible for the National Register. The process looks for ways to avoid, minimize or mitigate adverse effects. It does not automatically halt projects, a point developers often miss when they fear the review.
The consultation parties set the pace of review:
- The federal agency is responsible for compliance and makes the findings.
- The State Historic Preservation Officer (SHPO) may review findings and provide input or concurrence, depending on the process.
- Tribal Historic Preservation Officers (THPOs) and federally recognized tribes are consulted on properties of religious and cultural significance to them. The NPS consultation guidance describes protocols involving SHPOs, THPOs, tribes and other interested parties.
- Consulting parties and the ACHP may take part where their interests or the agency's request call for it.
The review ends in one of three effect findings, and each changes your next steps:
- No Historic Properties Affected: the agency determines that no historic properties will be affected. This finding can conclude the review, subject to agency procedures.
- No Adverse Effect: properties are present, but the project will not diminish the qualities that make them eligible. Agreed conditions may apply.
- Adverse Effect: the project would harm qualities that make a property eligible. The parties negotiate resolution, typically through avoidance, minimization or mitigation.
A streamlined option may be available. The Streamlined Review Process can shorten timelines when the activity meets the process criteria, historic properties are identified with SHPO concurrence, and documentation supports a finding of No Adverse Effect. Qualifying means keeping clean records, so assemble documentation as the work proceeds, not at the end.
How do you scope, procure, schedule and budget a survey?
Treat the survey as a feasibility line item, not an afterthought. Four steps keep surprises small.
Scope it precisely. Define the APE, the deliverables and the submittals that go to the SHPO or agency. State whether Phase II testing or monitoring is likely. The applicant toolkit is the best starting reference for what the agency expects from you.
Hire for the right qualifications. Look for archaeologists with relevant cultural resource management experience and qualifications appropriate to the work. Tribal contractors can add real value: the ACHP's early coordination handbook notes that including them helps identify sensitive resources that standard surveys may miss.
Know your cost and schedule drivers:
- Survey area size
- Site sensitivity and known nearby sites
- Seasonality and ground visibility
- Likelihood of subsurface testing
- Potential for Phase III mitigation
Survey costs depend on region and scope. Ask consultants for itemized proposals tied to these drivers and plan for possible additional work if findings warrant it.
Write the contract to absorb change. Use change-order language for additional phases, payment terms tied to project decisions, and schedule allowances for SHPO and agency review. We fold this kind of planning into our feasibility studies so the risk is priced before land is bought.
Pro Tip: Put the archaeological review on the project schedule as its own tracked activity, with review periods visible. Accounting for review time can help reduce schedule surprises.
How does early coordination with tribes and agencies reduce risk?
A significant developer risk is starting archaeological work after design is finalized. Agency guidance published by USDA Rural Development emphasizes that early, pre-application coordination with agencies and tribes best avoids delays and preserves design flexibility. Integrating a sensitivity check into feasibility reduces redesign risk, because moving a road in concept costs little and moving it after engineering costs a lot.
Practices that work:
- Start outreach before the application, and share project maps in formats tribes and SHPOs can use, such as KMZ files.
- Invite tribal input on micro-siting, and consider tribal monitors where appropriate.
- Document every consultation contact in the administrative record.
- Add tribal contractors where practical. The early coordination handbook says early tribal coordination can expedite review and reduce conflict.
- Look for tribal and cultural interests in pre-application. NOAA's tribal landscapes guidance notes that tribal participation often leads to more accurate identification.
- Carry contingency for Phase II and III, and submit materials to the SHPO and agency promptly so avoidable hold-ups stay avoidable.
What do local, state and tribal rules add beyond Section 106?
Section 106 covers federal undertakings, but many projects face other layers of review, and a project with no federal nexus can still need survey work.
State requirements. Many states have their own historic preservation or environmental review laws that apply when state funds, state permits or state land are involved. Some states also protect burial sites and unmarked graves regardless of federal involvement. Your SHPO's office is the right first call to learn which laws apply to your parcel.
Local requirements. Cities and counties may add archaeological checks to zoning, subdivision or site plan approval, and some designate historic districts or require sensitivity reviews in mapped zones. These rules sit in the local code and are easy to miss if you only study federal law.
Tribal requirements. On tribal land, tribal historic preservation codes and THPO review apply, and they can differ from state processes in timing and documentation. Off tribal land, consultation with tribes with cultural ties to the area remains part of the federal process and good practice elsewhere.
The practical approach is a compliance matrix built during feasibility: list each approval, the agency that issues it, whether archaeological review is part of it, and the expected review process. Where requirements overlap, ask whether one survey can satisfy several reviewers. Where they conflict, resolve it early with the reviewing offices rather than at submittal. We can build that matrix as part of our feasibility studies.
How should you communicate with the community and stakeholders?
Archaeological findings can draw strong interest from neighbors, descendant communities, local historical groups and elected officials. A communication plan can help address questions and reduce the risk of misunderstandings about a finding.
Match your communication to the phase. During Phase I, a short notice to the planning office and key neighbors is usually enough. During Phase II, when crews are visibly digging test units, a brief explanation of what the work is and is not can help prevent rumors. If Phase III is likely, brief stakeholders before the news travels on its own.
Some principles hold throughout:
- Name one point of contact on the project team for questions.
- Be honest about sensitivity. Locations of sensitive sites are often kept confidential, so share what is appropriate and say plainly what is withheld and why.
- Respect consulting parties. Tribes and local preservation groups are partners in review, not audiences for announcements.
- Keep records. Log meetings, comments and your responses, since reviewers may ask for them.
Good communication also protects schedule. Proactive communication can help stakeholders understand a finding and raise concerns through the review process.
How do survey findings shape land use and master planning?
Survey results are design inputs, and the earlier they arrive, the more options you keep. A known site boundary may inform plans for a park, drainage corridor, buffer or open space. A cluster of sensitive areas may suggest a different road alignment or a phased build-out that develops clear parcels first.
Here is how findings typically influence the plan:
- Parcel layout: lots and building pads shift away from sensitive areas.
- Infrastructure siting: roads, utilities and stormwater facilities are routed to avoid deep trenching through identified resources.
- Phasing: unaffected areas proceed while review continues on others.
- Contingency planning: budgets and schedules carry reserves tied to the findings.
The USDA guidance emphasizes integrating sensitivity assessment into feasibility to help reduce redesign risk. That is where our master land planning work starts: the plan reflects what the land can hold before engineering locks in lines. For a visual plan to show reviewers where constraints shaped the design, planning submission visuals can help, and Visual Trick's guide to architectural CGI for planning submissions covers how developers prepare them.
How do you coordinate archaeological surveys with other assessments?
Archaeology rarely travels alone. Wetlands delineation, endangered species review, geotechnical borings, topographic survey, traffic studies and utility design all touch the same ground, and each field crew can disturb or inform the others.
Coordination practices that can help avoid inefficiencies:
- Share base data. Give the archaeologist your topographic and existing conditions survey so the APE and field plan use the same map. Our surveying services are one common source.
- Sequence fieldwork. Do archaeological identification before geotechnical borings and clearing, since borings and clearing disturb ground. Confirm vegetation conditions suit surface survey.
- Align reports. Reviewers of environmental documents often ask for cultural resource findings, so schedule the archaeology report to be ready when those reviews begin.
- Hold joint kickoffs. One meeting with the surveyor, engineer, environmental consultant and archaeologist catches conflicts in access, timing and boundaries.
- Track one master schedule that shows each review window and dependency.
Our survey project services are set up around this kind of coordination, so one team keeps the field work, design and permitting in step.
A planner's view: treat archaeology as a managed deliverable
In my view, every feasibility study should include an archaeological sensitivity screen and a modest survey allowance from the start, even when no federal trigger is obvious yet. Early review may help identify issues before lots are drawn and infrastructure is engineered.
Early intelligence changes real decisions: where parcels land, where pipes run, how much contingency the budget needs. The applicant should own this as a managed deliverable, coordinated across permitting, design and procurement, with one person accountable. In my experience, unclear responsibility for the review can contribute to delays.
— Jeremy Wenger
Where can we help you plan around archaeological risk?
If archaeological review could touch your land, the cheapest time to learn it is before you buy, design or break ground. We run feasibility studies that weigh property documents, zoning, infrastructure and site constraints, and coordinate survey and engineering work so cultural resource review fits your schedule instead of interrupting it. Our team can help you scope the survey, line up qualified specialists, build the contingency into your budget and keep every review window visible on one schedule.
Start with our feasibility services or browse everything we offer on our services page. When you are ready to talk through a parcel, book a feasibility call and bring your site documents.
FAQ
When is an archaeological survey required?
A survey is typically required when a project uses federal funds, needs a federal permit, or involves ground disturbance that could affect historic properties. Under Section 106, that includes work like grading, trenching and foundations. State and local rules may add triggers.
What is an archaeological survey?
It is a systematic inspection of land to find and record archaeological resources, using methods from records research to fieldwalking, remote sensing and limited subsurface testing. It differs from excavation because it identifies and documents rather than recovering large amounts of material. Practitioners describe combined workflows that move from least to most intrusive.
What is a Phase III archaeological survey?
Phase III is the mitigation or data-recovery stage, used when a project would adversely affect an eligible site. It may involve data-recovery excavation or alternatives such as avoiding the site through redesign. The NPS process places it after identification and evaluation, with agency or SHPO review before each step.
What are the different types of archaeological surveys?
Common approaches include desk-based research, aerial and remote sensing, geophysical survey, surface fieldwalking and intrusive testing such as shovel tests. Most projects combine several. Which ones you need depends on the parcel, the ground conditions and what earlier phases found.
Sources
- Section 106 Applicant Toolkit | Advisory Council on Historic Preservation
- Nps
- Rd
- EARLY COORDINATION WITH INDIAN TRIBES DURING PRE-APPLICATION PROCESSES