Section 106 of the National Historic Preservation Act requires federal agencies to consider the effects of their undertakings on historic properties. For CRM managers, that translates into a specific set of field documentation requirements that must be met for projects to move forward.
This guide focuses on the field recording side of Section 106 — what your crews need to document, how to document it, and the common pitfalls that delay projects.
The Section 106 Process (Quick Review)
For those who need a refresher, the Section 106 process has four steps:
- Initiate the process — Determine if the undertaking has the potential to affect historic properties
- Identify historic properties — Survey the Area of Potential Effects (APE)
- Assess adverse effects — Determine if the undertaking will adversely affect identified properties
- Resolve adverse effects — Negotiate measures to avoid, minimize, or mitigate adverse effects
Steps 2 and 3 are where field recording lives. Your survey documentation needs to be thorough enough to support both the identification of historic properties and the assessment of effects.
Field Documentation Requirements
Area of Potential Effects (APE) Documentation
Before shovel hits dirt, document the APE itself:
- APE boundaries on project maps with GPS coordinates
- Current land use and conditions — photos showing ground surface visibility, vegetation, topography
- Disturbance assessment — areas of prior ground disturbance that affect the potential for intact deposits
- Access constraints — areas you couldn't survey and why
Survey Coverage Documentation
SHPO reviewers need to verify that your survey was adequate. Document:
- Transect intervals with GPS tracks or waypoints
- Shovel test pit (STP) locations with coordinates
- STP results — stratigraphy, depth, artifacts, soil descriptions
- Areas of no access with explanation
- Survey methods — pedestrian survey intervals, STP spacing, screening methods
Site Recording
For any site identified during survey:
- Site boundaries — GPS coordinates for a polygon, not just a center point
- Site type and cultural affiliation — based on observed artifacts and features
- Artifact inventory — types, counts, materials, temporal indicators
- Feature documentation — descriptions, measurements, photos, and plan drawings
- Integrity assessment — depositional context, disturbance
- NRHP eligibility recommendation — and the criteria supporting it
Photo Documentation
Photos are evidence. For Section 106 work, minimum photo documentation includes:
- Overview of the APE from multiple directions
- Representative ground surface conditions
- Each STP profile (if deeper than surface)
- All identified sites — overview and detail shots
- Features, diagnostic artifacts, and significant observations
- Anything that supports your integrity assessment or eligibility recommendation
Common Pitfalls That Delay Projects
Pitfall 1: Inconsistent STP Documentation
When crews record STPs differently — different soil terminology, different depth measurement conventions, different levels of detail — the SHPO reviewer questions the entire survey.
Prevention: Use standardized digital forms with dropdown menus for soil descriptions and required fields for all STP data. When every STP looks the same in the report, reviewers trust the data.
Pitfall 2: Inadequate Negative Evidence
"No sites were identified" isn't enough. You need to demonstrate why you believe no sites are present. This requires:
- Documentation of subsurface testing results (even negative STPs)
- Ground surface visibility estimates
- Disturbance evidence
- Geomorphic context
If your report says "no sites" but your documentation doesn't show the work that supports that conclusion, expect a request for additional information.
Pitfall 3: GPS Data Quality Issues
SHPO offices increasingly want GIS data — site boundaries, STP locations, survey coverage areas. Problems arise when:
- Coordinates are in inconsistent formats or datums
- Site boundaries are single points instead of polygons
- STP locations don't match the reported spacing on the map
- GPS data was post-processed inaccurately
Prevention: Use field data tools that capture GPS automatically in a consistent format. Build your GIS deliverables from the same data your crews collected, not from a separate manual process.
Pitfall 4: Late SHPO Coordination
The most avoidable delay: not coordinating with the SHPO early enough. Many SHPOs have specific requirements for:
- Survey methodology (STP spacing, depth, screening)
- Form formats and content
- Digital submission requirements
- Tribal consultation needs
Contact the SHPO during project planning, not after the survey is complete.
Pitfall 5: Poor Photo-Record Linkage
"Photo 47 shows the north profile of Unit 3" — but Photo 47 isn't labeled, isn't GPS-tagged, and looks like every other soil profile on the project.
When photos aren't clearly linked to specific records, features, and locations, they lose their evidentiary value. Digital field recording that ties photos directly to records eliminates this problem.
Digital Tools for Section 106 Field Recording
The documentation requirements for Section 106 are well-suited to digital field data collection:
- Standardized forms ensure consistent recording across crews
- Automatic GPS captures coordinates for every record without manual entry
- Photo integration ties images directly to STPs, features, and sites
- Required fields prevent incomplete documentation
- Real-time data access lets PIs review field data before the crew leaves the site
- Export flexibility generates SHPO-format reports and GIS data from the same dataset
FieldTap includes Section 106-ready field recording forms with SHPO-compliant exports, GPS-tagged photos, and standardized data entry. Built specifically for CRM firms. Start a free trial.