SECTION 106 AND SECTION 110 CONSULTING

For 36 years, Brockington has helped our clients comply with Section 106 and Section 110 of the National Historic Preservation Act (NHPA). We are also experienced in integrating these studies with the National Environmental Policy Act (NEPA) of 1969. We see ourselves as consultants first. We work with our clients and agencies to shepherd reports through complex processes such as permit applications, and we develop solutions and paths forward when unexpected situations arise. Our extensive knowledge of and experience with the laws, the procedures, and the agencies involved allows us to consult with permit applicants to avoid potential pitfalls.

Archaeologists expose the remains of a house structure during data recovery investigations at the Villa site in South Carolina.
Archaeologists expose the remains of a house structure during data recovery investigations at the Villa site in South Carolina.

CASE STUDY SECTION 106 AND SECTION 110 CONSULTING

VILLA DATA RECOVERY

Brockington’s data recovery investigations at the Villa site encompassed the sites of the former plantation’s enslaved community, the ruins of the main house, the gardens, and several auxiliary structures. Previous archaeological investigations at these sites had shown they were eligible for listing in the National Register of Historic Places. Proposed construction would adversely affect the sites, so a Memorandum of Agreement was developed with the US Army Corps of Engineers and the State Historic Preservation Officer to mitigate these adverse effects and to complete the Section 106 process. Brockington’s data recovery investigations were the key outcome of this mitigation.

PHASE I ARCHAEOLOGICAL SURVEY

For each Phase I archaeological survey, we begin by reviewing information for known sites, historic aerials and maps, soil surveys, and LiDAR data. Shovel testing and pedestrian surveys at specified intervals are the foundation of archaeological surveys. We coordinate with state and tribal authorities to ensure our approaches meet their standards. To expedite coverage, we routinely use GPS and GIS technology for land navigation and mapping. When appropriate, we can also employ underwater surveys or remote sensing, including GPR, magnetometers, metal detectors, and drones.

In some situations, Phase I reconnaissance surveys may be conducted as due diligence to help refine project planning. Our survey reports include recommendations on National Register of Historic Places (NRHP) eligibility and assessments of proposed undertakings' effects on NRHP-eligible resources. We make extra efforts to gather enough data at the Phase I survey level to ensure our NRHP significance assessments are solid, ultimately saving time and cost for our clients.

Archaeologist James Page excavates a shovel test at a newly identified site during cultural resources surveys of 21 tracts in the Mississippi Delta
Archaeologist James Page excavates a shovel test at a newly identified site during cultural resources surveys of 21 tracts in the Mississippi Delta

CASE STUDY PHASE I ARCHAEOLOGICAL SURVEY

MISSISSIPPI PHASE I SURVEYS

Brockington conducted cultural resources surveys of 21 tracts in the Mississippi Delta. This work was done as Section 106 compliance related to NRCS Environmental Quality Incentives Program (EQIP) applications for land forming practices. The project required complex logistics that considered local weather, landowner needs, and NRCS personnel. We conducted local, state, and regional archival research, individual field investigations of each project tract, and met state reporting standards. We utilized a no collection strategy, and recorded and analyzed all artifacts in the field. All fieldwork was expedited and completed ahead of schedule, to allow maximum time for landowners to farm the properties.

PHASE II ARCHAEOLOGICAL TESTING

Phase II testing is sometimes necessary when a site may be eligible for the NRHP, but not enough data has yet been obtained to make a definitive eligibility determination. Phase II investigations usually include more expansive archival research, including title searches for historic sites. Archaeological field methods can involve close-interval shovel testing, probing, metal detecting, GPR or other remote sensing, 1-by-1 meter or 1-by-2 meter hand excavation units, or heavy machinery scraping. Deep testing involves specialized methods when archaeological deposits may be present greater than one meter below the surface. Floodplains often include alluvial or colluvial sediments, which could contain deeply buried archaeological deposits. Likewise, deep deposits are often present in historic urban settings. Geomorphological studies can identify soils that could contain cultural deposits. Methods for deep testing involve coring, hand excavation using setbacks, power augering, or mechanical trenching. The choice of technique depends on project area conditions; safety is also a primary consideration during deep testing.

Archaeologist Scott Kitchens looks for evidence of the foundation of a house during archaeological testing at the Wright Family Park
Archaeologist Scott Kitchens looks for evidence of the foundation of a house during archaeological testing at the Wright Family Park

CASE STUDY PHASE II ARCHAEOLOGICAL TESTING

BLUFFTON PHASE II TESTING

Brockington conducted archaeological testing as part of the Town of Bluffton’s master plan for the Wright Family Park. This testing further explored an area that could represent the location of the former Squire Pope main house. Shovel tests produced burned historic artifacts, and trenches in the area of the former house’s foundation revealed a tabby walkway and a burned layer underlain by yellowish brown sandy loam. Plainly, after a fire at the site, the destroyed structure was demolished and cleared. Because of the low potential for intact piers or foundations from the former structure, and the low analytical yield of the burned artifacts, we did not recommend further analysis of the site. Archaeological testing is an important process even and especially when it does not produce major scientific revelations. The process provides certainty about a site’s potential for further research value, and allows our clients to make clear planning decisions.

PHASE III ARCHAEOLOGICAL DATA RECOVERY

We complete Phase III archaeological data recovery excavations when an NRHP eligible site cannot be avoided from adverse effects by a proposed undertaking. We start by preparing a data recovery plan or research design that balances our client’s needs and the reviewing agencies’ requirements. Data recovery methods usually involve large 2-by-2 meter hand excavated units, heavy machinery scraping, and feature excavation. Our labs have the capacity to process the large volume of artifacts typically associated with data recovery projects. In addition to artifacts, we typically collect feature soils and samples for specialized analyses and C-14 dating. Our data recovery reports often serve as standalone mitigation of adverse impacts, but when public outreach components are required, our HW Exhibits team can produce a wide variety of creative mitigation, including exhibits, books, websites, education programs, and lectures.

Archaeologists clean the magazine floor at a recently excavated earthen Civil War fortification in coastal Alabama
Archaeologists clean the magazine floor at a recently excavated earthen Civil War fortification in coastal Alabama

CASE STUDY PHASE III DATA RECOVERY

CIVIL WAR FORT IN ALABAMA

Brockington conducted data recovery excavations at an earthen Civil War fortification in coastal Alabama, designed as the strongest anchor fort in a defensive line protecting the City of Mobile. The fort was built by a labor force of over 500 enslaved African Americans. Brockington first identified the site in 2002 during a Phase I survey, followed by Phase 2 testing in 2003. Deep testing determined the main ammunition magazine and access tunnels were likely intact, though upper portions of the earthwork were leveled in 1961 for subdivision construction. In 2021 and 2022, Brockington used heavy equipment to conduct an extensive Phase III data recovery. After removing burned roof timbers and massive rubble fill, the team exposed the fort’s brick magazine with its heavy frame subfloor. The high water table provided excellent wood preservation. Archaeologists also excavated buried brick access tunnels with intact wooden floors, including tools and ammunition lost by workers and soldiers during the Civil War.

MILITARY STUDIES

Brockington’s military studies team includes archaeologists and historians who specialize in the study and management of military-related sites. We use specialized methods, including close interval metal detecting and submeter GPS receiver mapping, to document battlefields, fortifications, and bivouac areas. We’ve worked on military sites across the United States, from the Revolutionary War through the Cold War. While scholarly and scientific reporting of military sites is our primary focus, we recognize that military history is enormously popular with the general public. For their benefit, we provide museum exhibits, education programs, websites, and videos that highlight our nation’s unique military heritage.

Archaeologists James Page and Scott Butler use metal detectors along a lane cleared of vegetation and leaf litter to delineate the Confederate outpost position south of the battle.
Archaeologists James Page and Scott Butler use metal detectors along a lane cleared of vegetation and leaf litter to delineate the Confederate outpost position south of the battle.

CASE STUDY MILITARY STUDIES

BATTLE OF CONGAREE CREEK

Brockington conducted investigations at the site of the February 15, 1865, Battle of Congaree Creek to document the site’s Confederate earthworks and to define specific elements of the battlefield. These investigations were conducted ahead of the construction of a system of walking trails for a planned history park. We mapped the earthworks along the north bank of Congaree Creek, recording the parapet and ditches at each turn or inflection of these 1.65-kilometer long fortifications. We also prepared profiles or cross-sections of each segment of the works. Intensive metal detecting permitted the delineation of the Confederate outpost position south of Congaree Creek. These investigations demonstrate the integrity of the battlefield despite its agricultural uses, including the planting of timber, since the Civil War.

Scroll to Top