Wetland mitigation banking is driven exclusively by regulation, and then largely under the Clean Water Act, with enabling legislation for preferrably mitigating transportation projects found originally in TEA-21.

I was under the impression that cultural resource mitigation, in the case of archaeology, typically involves the complete excavation and cataloguing of a site. I'm less familiar with an SHA's efforts at historical resource mitigation banking, but have heard about Georgia DOT doing some advance mitigation for transportation projects in the area of a historical Cherokee landmark. So, I suppose it is a practice with potential, thoguh I'm not certain how-driven by regulation inasmuch as a desire to avoid confrontation over planned projects with potential for controversy.

You are correct that there is little information on the practice of "banking" as a form of mitigation for impacts to cultural resources because there is very little, if any, happening. There are many practical reasons for this. While some may argue that you can't accurately recreate a wetland, you definitely can't create a historic or archeological site from scratch. There have been a few situations where "banking" has been proposed, and only one I know of where it has been implemented for a cultural resource. That is in Montana where a mile stretch of historic railroad grade was acquired by the DOT to be preserved and interpreted as a linear park to serve as mitigation for future projects which might affect limited sections of other historic railroads. However, in most cases it is difficult to predict ahead of time that you are preserving a resource with similar qualities as that being affected. By the way, the Tampa relocation and rehabilitation of about 30 historic structures
was not banking, but direct mitigation for impacts to those structures and their NHL district.

I will remain anonymous on this one. This is the most preposterous thing I've ever heard with regard to mitigating for adverse effects to archaeological sites. Perhaps there could be in very limited cases an application for adverse effects to historic structures, but this would be a negotiated mitigation anyway. Come on folks, either avoid the impact or pay the cost to mitigate it!

I wouldn't say "preposterous" so quickly. Perhaps, the preservation of cultural resources through any means is worthy of consideration no matter how "off the deep end" it may sound. If archeological sites are NOT protected UNLESS they are on public land - wouldn't any effort to save them be worthwhile? Who cares if you call it banking, mitigation, whatever, as long as the resource and public wind up benefitting. For large scale projects, banking (even for cultural resources) may be one of the best answers. Sure mitigation efforts through avoidance, minimization, data/artifact recovery, documentation, etc should always be implemented to the fullest extent practical. But who's to say that monies shouldn't be set aside to preserve or "bank" other important but threatened cultural resources on private lands...?

I've even heard of leaving the cultural resource intact and buried (under the road improvement) as the best option to preserve it - so I think there are many different perspectives on what may be the best answer...

Legalities aside, "banking" has merit, and it is not at all preposterous. It could be a combination of project-related data recovery, supplanted by acquisition of historic resources elsewhere for preservation. Granted, we (DOT) don't manage property. However, it may be legally possible to acquire sites from willing sellers and transfering management to the Archaeological Conservancy or a state agency. I'm sure there are wetland situations such as camas meadows with associated processing sites, for example,that could fulfull multiple "banking" objectives. Good discussion.

There have been cases in which BLM has entered into Section 106 agreements providing for land exchanges in which the agency acquires very significant archaeological sites while giving up not-so-good ones without any mitigation; that's not unlike mitigation banking. Similarly, of course, we pretty routinely agree to demolition of historic buildings in return for rehab of others, or even more general things like funding facade preservation programs. Granted, nobody's established a "bank" of historic properties that can be supported in lieu of doing something with threatened properties, but the general idea of trading properties is hardly preposterous.

I think TxDOT MAY be considering the concept of cultural resource banking in relation to mitigation for their proposed Trans-Texas Corridor projects. The contact at the SDOT would be Nancy Kenmotsu (512) 416-2626. Hope this helps.

I've never heard of banking in regards to cultural resources, but you might take a look at the Lakewood Heritage Center. http://www.lakewood.org/index.cfm?&include=/Culture/heritagecenter.cfm

The Heritage center has a "collection" of historic buildings from the 20th century. While the resources may have lost the integrity they had by being relocated, at least the structures and history has been preserved. The real trick would be to find communities willing to take on the responsibility for preserving such resources.

This is Mr. preposterous again. Call it mitigation what you folks are all talking about, but mitigation banking is not the right term. I don't see how it could work for prehistoric archaeological resources and would be a stretch for historic structures. Setting up a bank involves establishing mitigation and then setting up credits with the mitigation already in place that would be drawn upon whenever an unavoidable imapct is made to a site in the future. How do you set up a bank site that mitigates for impacts to lithic scatter sites, villages,and sites with human remains and funerary objects ahead of time. These impacts have to be dealt with on a site to site basis! So, if you had a mitigation bank would you propose the bank set up a prehistoric site with 100 projectile points, 25 human remains, 25 scared objects and then say that you can draw upon these credits when you impact another site with a roadway? It just doesn't make sense.

Dear Mr. P. I agree that we haven't yet really been talking about "banking," but I'm not sure the idea is entirely beyond the pale. Imagine that somebody (say, the Archaeological Conservancy) promulgates a list of sites it would like to acquire. The Hugestate DOT then proposes a project that's going to knock out three sites of some kind, but it wants to move fast and not take the time to deal with them. Through 106 consultation HDOT, FHWA, and the other consulting parties establish that it would cost $1 million to dig them all, but that nobody really is all that excited about digging them. The 106 MOA then specifies that rather than digging them HDOT will donate $1 million to the Conservancy. Are there lots of practical impediments to doing something like this? Sure -- not least being the very real question of why HDOT should spend any money at all if nobody cares enough about the sites to dig them, but that's a question no matter how the money is spent. Is it beyond
possibility? I don't think so. Whether it's preposterous is, I suppose, in the eye of the beholder.

I agree with Mr. P and Tom. "Banking" cultural resources is really not practical. Cultural resources are essentially unique, impacts to one cannot really be mitigated through preservation of something else. OK, yes, each wetland is also unique, or section of habitat, or other natural resources, but there is enough similarity that "banking" is possible.

There may be some cultural resources where this is also true. Remember, we are entering the era where track housing and strip malls are reaching potentially historic status. If it is true that a cultural resource's value is not somehow unique, then maybe some type of banking has some merit.

This "banking" concept fits above-the-ground resources much better than archeological resources. But even with archeology, when routine mitigation (lithic scatter recovery, for instance) is becoming repetitious and contributing very little more to the body of knowledge, the money devoted to mitigation might better be spent studying and analyzing previous statewide lithic scatter recovery results and drawing some conclusions and producing a report. And perhaps identifying where study efforts need to be invested in the future.

With natural environment mitigation banking you are really trying to look at a regional system and to identify what--in the long term--a consolidated mitigation effort might do to sustain the resource system as opposed to a piece-meal replacement efforts. I think statewide historic bridge inventories and preservation planning is a better fit of the mitigation banking concept to cultural resources. Abandoned historic railroad lines, mining communities, certain industries, lumber camps, toll road facilities, and particular types of historic agriculture--i.e., silk worm, rice or early fish farms) are other applications. Situations where you know you are going to inevitably lose some of the individual resources within a type (system) to development, loss of integrity or deterioration over the years, or simply the inability to financially save them all. And where you have looked at the resource as a "statewide system of a type" (an inventory or context). Where would the mitigation
funds be best invested to preserve a viable representative historic remnant(s) of that type of resource that can best show and tell the next generations this resource--its history, the story of the people who were associated, the activity itself, and circumstance in which it existed? This type of long-term planned mitigation incorporates a lot of the "banking theory".

Mr. P returns! If a site's lithic scatter recovery would be considered repititious and would contribute very litle more to the body of knowledge, then I would venture to guess that it would not likely meet the criterion (typically crierion d. in 36 CFR 60.4) that is commonly used in determining its eligibility for the National Register and thus Section 106 would not apply. It seems the discussion up to this time has made some judgements that perhaps this alleged "banking" concept is not a good fit for archaeological resources. In practice, I cannot conceive how a tribal entity engaged in a Section 106 consultation would go along with a banking concept. Resolution of adverse effects would still be a case by case situtation and could not be addressed through banking. And remember, banking for wetlands ( to use a concept where banking has been implemented) still requires a mitigation sequencing process of avoiding and minimizing before you ever get to the point of drawing credits
from a wetland mitigation bank.

If folks could pry themselves out of their pits and forget the spurious equations of "cultural resource" with "archaeological site" and of "significance" with "research value," I think the validity of "banking" might be easier to grasp, PARTICULARLY with respect to tribal concerns. Imagine, for instance, that a tribe has a number of sites that it would really, really like to bring under its own protection -- major ancestral places, really vital spiritual places, and so forth. Imagine that it forms a program to acquire these sites, maybe bring them into trust. Imagine then that an agency that wants to destroy another site that's less vital to the tribe -- not of no importance at all, but one that's not likely to be preservable in the long run and that's just not as central to the tribe's identity as those in its "banking" program. Imagine that the agency can then contribute what it would otherwise pay to dig up the not-so-vital site to the tribe's site-banking fund, to be used to
acquire vital sites. We've done such things on a case-by-case basis, using site-acquisition and donation to tribes, and contributions to tribal cultural centers and museums, as ways of mitigating impacts on traditional cultural places; I don't see why -- in theory -- it couldn't be done programmatically.