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Case Study - Illinois

Statewide Programmatic Agreement for the Mitigation of Adverse Effects to Euro-American Tradition Archaeological Sites in the State of Illinois

Archaeological surveys of road-connected Euro-American sites in Illinois are made more efficient through a new statewide standard treatment. (Photo courtesy Illinois State Archaeological Survey). Archaeological surveys of road-connected Euro-American sites in Illinois are made more efficient through a new statewide standard treatment. (Photo courtesy Illinois State Archaeological Survey).


On August 30, 2011, the ACHP, Federal Highway Administration (FHWA), the Illinois Department of Transportation (IDOT) and the Illinois State Historic Preservation Officer (SHPO) executed a Programmatic Agreement (PA) that streamlines the Section 106 review process for Federal-Aid Highway projects affecting Euro-American archaeological sites. The streamlined process may be used to comply with Section 106 for undertakings classified as minor highway projects (that is, projects that qualify as Categorical Exclusions under the National Environmental Policy Act). Additionally, the Illinois SHPO must agree with IDOT, in writing, that:

  1. The affected sites are examples of the Euro-American Tradition (as defined in the PA);
  2. The affected sites are significant primarily for the information they may yield through data recovery and have little value for preservation in place; and
  3. The only historic properties potentially affected by the undertaking are archaeological sites.

Review of these projects is streamlined through (1) the delegation of responsibility to IDOT for the identification, evaluation and treatment of Euro-American Tradition sites in consultation with the Illinois SHPO and the Illinois State Archaeological Survey (ISAS); and (2) use of a “Standard Data-Recovery Plan for Euro-American Tradition Archaeological Sites” as the standard treatment for these types of sites. The PA requires that IDOT notify SHPO, Indian tribes, and when appropriate, other potential interested parties prior to concluding environmental review. If any of these parties objects or expresses concern about use of the standard treatment approach or if archaeological sites are determined likely to contain human remains or burials, the streamlined process will not be used. In such cases, FHWA and IDOT must go through the standard Section 106 review process (36 CFR 800.3-800.6) to conclude consultation.


FHWA and IDOT worked closely with the Illinois SHPO and the ACHP to develop and finalize this PA.  The streamlined approach, using a Standard Data Recovery Plan, works well in Illinois.  Because IDOT projects commonly occur in rural or once-rural settings, specific methodologies have been developed for the standard treatment of farmsteads. The Standard Data Recovery Plan outlines a methodology for the recovery of significant information from historic farmstead sites. Adjustments to this methodology may be made when other types of historic period Euro-American resources are investigated, such as urban residential areas or other, more specialized non-domestic sites. The PA allows for this by requiring close coordination with the SHPO to determine the appropriate use of the standard treatment. FHWA and IDOT sought comments on a draft of the PA from the public and federally-recognized Indian tribes with an interest in Illinois lands. They received no comments in response to this outreach. 

The PA is intended to supplement the amended Statewide PA for minor transportation projects which was executed among FHWA, IDOT, SHPO, and the ACHP in September 2010.


The PA was crafted to allow considerable streamlining of consultation for projects affecting only Euro-American Tradition archaeological sites. FHWA has built into the agreement a number of checks and balances to ensure that the PA applies only to non-controversial undertakings and sites that are of value primarily for the information they are likely to contain. The agreement also provides for the remote possibility that a Euro-American tradition archaeological site may be of value to an Indian tribe or another interested party, and in that case, it will go through the full Section 106 review process in accordance with the ACHP’s regulations.

The sites to be treated under this PA are generally the remains of small, rural farmsteads. Individually, these sites may contribute little information regarding historic settlement patterns, subsistence, and architecture of farming communities in Illinois. Through use of a standardized methodology, IDOT will be able to generate consistent and comparable information that can be readily synthesized and utilized in the preparation of overview studies. The PA requires that the results of these investigations be reported in accordance with the Secretary of Interior’s Standards and Guidelines. The results must also be made available to the general public through web postings, public and professional lectures; an annual report of site investigations; and through the publication of studies that synthesize the data recovered under the PA.   

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