Click on an agency page, below, for cultural resources / archaeology / historic preservation compliance contact information. 

State and Federal Agencies are required to consult with SHPO and Indian Tribes under state and federal laws (see Home tab). Agencies are also encouraged to consider the tribal perspective and tribal values in planning their projects. Talk to Tribes early. Mutual respect and trust can build partnerships that lead to innovative ideas and solutions.

Agencies should review the guidance  at the bottom of the page - it clearly describes what should be included in your initial consultation letter. 

INITIATING CONSULTATION

The initial consultation letter must summarize all of the information that is critical to the consultation and review process. State agencies with delegated authority to consult on federal undertakings (generally for the use of federal funds or "pass through grants") should state this delegation of authority in the initial Section 106 consultation letter to SHPO, Tribes, and other consulting parties. Letters to Tribes from federal and state agencies should also inquire whether the Tribe has any concerns regarding historic properties of traditional, religious, cultural or historical importance to their community within the project area.

All initial consultation letters, unless otherwise agreed to through programmatic agreements or other coordination with SHPO and Tribes, should be on agency letterhead, and letters should include the following:

• A description of the project (including all planned actions), definition of the project are including the area of potential effects (APE), the nature and extent of the proposed impacts (i.e., type of disturbance, spatial extent, vertical depth), and the agency's efforts to identify historic properties and obtain and consider the view of affected local governments, Indian Tribes, the public and other interested parties. Also identify all consulting parties. [Note that surveys requiring AAA permits are also subject to review by ASM, and SHPO will coordinate with ASM, land-managing agencies and other consulting parties, as appropriate.]  For architectural properties, indicate whether the proposed action is an addition, replacement, repair, or demolition.

  • • If portions of the APE/project area were previously surveyed, the letter should indicate whether those surveys meet current professional standards pursuant to SHPO Guidance Point No. 5.

    • A separate map of the current APE/project area must be included with the consultation letter if the APE differs from that depicted on the map in the survey report. For example, the APE as defined and consulted on by the Corps is sometimes much smaller than that described and/or depicted in the report; the agency should include a map showing their APE and explain the difference in the letter.

• A description of the cultural resources that might be impacted directly, indirectly, or cumulatively by those actions. An evaluation of the eligibility of those resources for inclusion in the Arizona or National Register of Historic Places (ARHP, NRHP), including a determination of Register-eligibility by the responsible federal agency.

  • • Although consultants are usually asked by agencies to make recommendations regarding Register eligibility, which can be helpful to the agency and SHPO, it is the federal agency's responsibility to submit their official determination of eligibility and request SHPO concurrence.

    • Should there be a disagreement between the federal agency and the SHPO on eligibility, the final authority is the Keeper of the National Register. 

    • For state agency projects, the determination of, and final authority on eligibility to the ARHP, is the State Historic Preservation Officer. That is, the state agency recommends eligibility but does not make a determination.

• An evaluation of the potential for a federal undertaking or a state plan to directly, indirectly, or cumulatively affect Register-eligible properties. The potential for visual, auditory, and atmospheric effects of an undertaking on historic properties must be evaluated. Specifically indicate if the federal undertaking or state plan will or will not affect Register eligible properties (aka "historic properties").

• A finding of effect for the project by the lead agency. Appropriate findings are: No Historic Properties Affected, No Adverse Effect, or Adverse Effect. There can be only one finding of effect for a given undertaking/plan, even if it consists of multiple projects or phases.

• A description of the alternatives evaluated and treatment or mitigation proposed. This should include alternatives identified during the National Environmental Policy Act ( NEPA) analysis process (for federal projects), as well as any alternatives specifically designed to avoid or reduce impacts to Register-eligible cultural resources. Some examples include: realigning a road to avoid demolishing a historic property, installation of overhead rather than underground transmission lines in a given area to avoid physically impacting an archaeological site, or adaptive reuse rather than demolition of a building.

  • • The discussion of treatment or mitigation measures should include those that were considered but not chosen, and the reasons for selecting the preferred measure.

    • Alternative actions (including avoidance) considered, and the proposed treatment of any Register-eligible properties in order to reduce the potential adverse effects of the undertaking on those properties, should be discussed. 

• Letters to SHPO should include a summary of Tribal consultation efforts, including consultation on identifying Traditional Cultural Properties, sacred sites, traditional use areas, etc., government-to-government consultation with tribes should be clearly articulated. Indicate which Tribes participated in consultation, and describe the process (for example, phone calls, letters, meetings, field visits, emails, etc.). If tribal responses are received after consultation with SHPO, please send copies of all letters of concern to SHPO.

• Requested action on the part of the SHPO or THPO; that is, request for concurrence with definition of the APE, concurrence on determination(s) of eligibility, concurrence on finding of effect, etc.).

Please feel free to contact your SHPO reviewer at any time to review the process or discuss the undertaking, results, and recommendation. [Click on the SHPO tab at the top of the page to find the appropriate staff member for your agency.]