Library of COALEX Research Reports

COALEX Research Reports are the products of research and analysis conducted on specific issues relating to the regulation of Surface Mining Control and Reclamation Act of 1977. The research is conducted in response to requests for information from State Regulatory Authorities, under a cooperative agreement between the Office of Surface Mining (OSM) and the Interstate Mining Compact Commission (IMCC).

COALEX refers to the Library of Surface Mining Materials maintained by OSM in LEXIS-NEXIS and is a major source for the research.

Each Report includes a list of resources which were sent as attachments to the individual who requested the research. To obtain a copy of the attachments or to obtain any additional information, contact Joyce Zweben Scall by phone at 202-686-9138 or by email at JZScall@aol.com.

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COALEX STATE COMPARISON REPORT - 239

December, 1992 (Revised: February, 1993)

Ernest F. Giovannitti, Director
Bureau of Mining and Reclamation
Pennsylvania Department of Environmental Resources
209 Executive House Building
P.O. Box 8461
Harrisburg, Pennsylvania 17105-8461

TOPIC: HISTORIC AND ARCHAEOLOGIC RESOURCES

INQUIRY:What provisions have the states made to carry out the requirements of OSM regulations 780.31(a) and (b) relative to historic and archaeological resource protection? Please ask the IMCC member states the following questions:

1. Have you hired staff or outside contractors with expertise in historical or archaeological resource assessment?
   1. How many?
   2. Type of expertise?
   3. What do they do
2. Do you provide funding to your State Historic Preservation Office (SHPO) to carry out historical or archaeological site assessment? If yes, what level of service is provided by the SHPO?
   
3. Do you have an interagency agreement with your SHPO relative to historic or archaeological resource protection? If yes, please summarize respective roles and responsibilities.
   
4. What level of protection [avoidance, mitigation (minimize impacts), documentation (site surveys), enhanced documentation (artifact recovery)] under your permitting and enforcement programs is provided for the following:
   1. Historic/archaeological sites which are listed on or eligible for listing on the National Register of Historic Places (NRHP).
   2. Historic/archaeological sites which are known but not listed/eligible for listing on NRHP. Do you have criteria for defining "known" sites?
   3. Sites or areas where there is a high probability of finding archaeological resources. Do you have criteria for defining "high-probability" sites?
5. If a permit applicant owns the property to be mined (including the historic or archaeological resources on the property), how does this affect the responses to question 4 above?

SEARCH RESULTS: Twelve IMCC member states, including two non-coal states, responded to the survey. The responses to the questionnaire follow; a table summarizing the responses to questions 1, 2, 3 and 5 appears at the end.

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ALABAMA

1. Have you hired outside staff or contractors: No. We consult with the Alabama HistoricalCommission.
   1. Number of the Ala. Hist. Comm. staff:
      1. 1 - State Historic Preservation Officer
      2. 1 - Chief of Administration
      3. 5 - Professional Archaeologists
      4. 10 - Cultural Resource Coordinators
   2. Expertise:
   3. What do they do: Professional archaeologists review requests for evaluations and recommend and/or approve site assessments conducted by contracted archaeologists. Archaeologists also manage site owned cultural and historical sites. Cultural Resource Coordinators make on-ground inspections for site assessments.
2. Do you fund SHPO: No.
   Level of service provided by SHPO: N/A.
   
3. Do you have an interagency agreement with SHPO: No.
   
4. Level of protection under permitting and enforcement:
   1. Sites on NRHP: Avoidance.
   2. Criteria for defining "known" sites: Avoidance or mitigation. "Known" sites have been surveyed by other archaeologists or have sub-surface structures present.
   3. Criteria for defining "high-probability" sites: A Phase I Study (Cultural Assessment) is required. "High probability" sites are any elevated areas near a water supply, and are prevalent over most of the state.
5. If permit applicant owns property to be mined: The property is treated the same as any other.

ARKANSAS

1. Have you hired outside staff or contractors: No.
   1. Number: N/A.
   2. Expertise: N/A.
   3. What do they do: N/A.
2. Do you fund SHPO: No funding provided.
   Level of service provided by SHPO: N/A.
   
3. Do you have an interagency agreement with SHPO: No.
   
4. Level of protection under permitting and enforcement:
   1. Sites on NRHP: Obtain approval and/or guidance from the SHPO.
   2. Criteria for defining "known" sites: No criteria for defining "known" sites.
   3. Criteria for defining "high-probability" sites: No criteria for defining "high-probability" sites; however, there have been cases when the SHPO has alerted the permit applicant that the proposed permit area is in a high-probability area. The Surface Mining and Reclamation Division (SMRD) required that the applicant satisfy the SHPO which resulted in an archaeological survey by the applicant. The applicant must provide a clearance letter from the SHPO in the application. If the SHPO has questions about the permit area, the applicant has usually cleared it by the time the permit application is submitted to the SMRD. It has the SMRD's experience that the applicant has proceeded with the archaeological survey rather than question the SHPO's request.
5. If permit applicant owns property to be mined: The applicant must satisfy the SHPO.

ILLINOIS

1. Have you hired outside staff or contractors: No, nor have we hired anyone in-house specifically or this purpose. However, one staff member has expertise and is utilized for cultural resource review.
   1. Number of in-house staff:One
   2. Expertise of in-house staff: This individual does not have formal educational training, but has "hands-on" experience with survey work during his tenure with a coal company.
   3. What does the in-house staff do:Primarily, respond to SHPO comments on permit applications and make determinations on the need for initial surveys or additional phase surveys.
2. Do you fund SHPO: No. SHPO receives funding through National Park Service. Level of service provided by SHPO:SHPO performs reviews of all permits, significant revisions and renewals by virtue of being a member of our interagency committee.
   
3. Do you have an interagency agreement with SHPO: The SHPO is a member of our interagency committee. They receive copies of all permit applications and are allowed to comment within 45 days. IDMM considers the SHPO comments prior to making its final permit decision.
   
4. Level of protection under permitting and enforcement:
   1. Sites on NRHP: All of the above options could be utilized. To date, most operators commit to survey work in lieu of avoidance. Surveys through Phase III have been required.
   2. Criteria for defining "known" sites: Our SHPO considers virtually every known site as potentially eligible. We have no definition of "known site".
   3. Criteria for defining "high-probability" sites: We have no definition of "high-probability" sites.
5. If permit applicant owns property to be mined: Has no impact. Compliance with the regulations still required.

INDIANA

1. Have you hired outside staff or contractors: No. We use in-house staff.
   1. Number of in-house staff: Two staff members under SHPO are paid by the Division of Reclamation (DOR). One additional professional archaeologist is an administrator at the DOR.
   2. Expertise of in-house staff: Historic and prehistoric archaeologists exceed requirements of the Society of Professional Archaeologists for their fields.
   3. What do the in-house staff do: Review all applications, maintain database, provide recommendations to Director of the DOR and to industry, review compliance field work and reports.
2. Do you fund SHPO: The DOR funds two positions. Level of service provided by SHPO: SHPO provides assessments and recommendations on the basis of information obtained from the applicant and any other available information. The applicant must provide sufficient information to make necessary assessments. SHPO may provide recommendations concerning the manner of which such information can be obtained.
   
3. Do you have an interagency agreement with SHPO: An agreement is currently being developed, which provides for the DOR to consult with the SHPO. Determinations requiring additional information and field work to discover unknown resources are made by the DOR as the Department of Natural Resources (DNR) director delegate. The DNR director is also the SHPO.
   
4. Level of protection under permitting and enforcement:
   1. Sites on NRHP: Joint approval of any impacts must be obtained from both SHPO and DOR. The means of addressing those proposed impacts are specific to property and part of the joint approval process.
   2. Criteria for defining "known" sites: The nature of known properties must be reported by the applicant. SHPO will then supply a determination on eligibility. Protective measures are not considered for properties that are not eligible for listing. A "known" site is one which is recorded at one of the state's records holding institutions, recorded in the SHPO's files, listed in a county history, depicted on a county atlas, recorded by a county historian, recorded by a local historical society, depicted on county soil survey maps, reported in documents of the Geological Survey, etc.
   3. Criteria for defining "high-probability" sites: DOR uses the guidelines found in Federal Directive TSR-7. Determinations are made from analysis of settlement and subsistence systems identified for the region and an examination of the relationships of topography, soils, etc. to know sites in the region. Probabilities are determined through a comparison to the characteristics of the area to be permitted.
5. If permit applicant owns property to be mined: Property ownership does not affect the requirement of the applicant to address the impacts of his operation.

KENTUCKY

1. Have you hired outside staff or contractors: No. However, the Department for Surface Mining Reclamation and Enforcement (DSMRE) hired qualified archaeologists.
   1. Number of in-house staff: Three.
   2. Expertise of in-house staff: N/A
   3. What do the in-house staff do: Review permit applications and coordinate with SHPO.
2. Do you fund SHPO: Yes.
   
3. Do you have an interagency agreement with SHPO: Yes. DSMRE entered into a Memorandum of Agreement (MOA) with the SHPO which includes funding. The MOA is currently being renegotiated in its entirety. The new MOA is expected to be in place by the end of February, 1993.
   
4. Level of protection under permitting and enforcement: DSMRE screens all proposed permit applications and determines on a case-by-case basis whether an initial reconnaissance survey of the proposed permit area is required to determine whether any potentially eligible historic or archaeological sites exist within the proposed boundaries.
   1. Sites on NRHP: A protection of mitigation plan is required for all listed and/or eligible sites. The scope and level of detail required for a protection and/or mitigation plan is determined site-by-site in consultation with the SHPO.
   2. Criteria for defining "known" sites: N/A
   3. Criteria for defining "high-probability" sites: If potentially eligible sites exist, the applicant is required to do further studies to determine whether the site is eligible.
5. If permit applicant owns property to be mined: Ownership of the property has no impact on how applicant addresses historic or archaeologic sites prior to mining.

MISSOURI

1. Have you hired outside staff or contractors: No.
   1. Number: N/A.
   2. Expertise: N/A.
   3. What do they do: N/A.
2. Do you fund SHPO: No.
   Level of service provided by SHPO: The assessments are performed by private consultants hired by applicants. The SHPO only reviews the report and issues its findings.
   
3. Do you have an interagency agreement with SHPO: No formal agreement. However, SHPO understands its role as the final authority on the adequacy of the permit application.
   
4. Level of protection under permitting and enforcement: Missouri requires all applicants to coordinate with SHPO and DNR. No permits are issued until SHPO approves.
   1. Sites on NRHP: Avoidance, or if that is not possible, a mitigation plan which meets the approval of the SHPO.
   2. Criteria for defining "known" sites: Site survey may be required if SHPO is not comfortable with available information.
   3. Criteria for defining "high-probability" sites: The SHPO determines the criteria. Surveys are usually required where a "high-probability" exists.
5. If permit applicant owns property to be mined: Does not affect the level of protection.

OHIO

Ohio Division of Reclamation (DOR) has promulgated rules and regulations on historic preservation/protection as effective as OSM regulations for surface, underground mining, and AML reclamation projects.

1. Have you hired outside staff or contractors: Ohio DOR hired a permanent full-time professional archaeologist in 1986. Applicants hire professional prehistoric and historic archaeologists (contracting firms) as well as historic architects to perform the Phase 1 (literature search), Phase 2 (field locational investigation), Phase 3 (historic property eligibility assessment), Phase 4 (mitigation) surveys when the DOR archaeologist requires historic/archaeological investigations. The DOR archaeologist and contracting archaeologists are qualified per the (1983) Secretary of Interior's Standards (for qualifications) and Guidelines (for survey reports). DOR AML projects also contract with professional archaeology firms to perform the Phase 1-4 surveys after the DOR archaeologist reviews them, if surveys are necessary.
   1. Number of in-house staff: Ohio DOR has one professional archaeologist.
   2. Expertise of in-house staff: Ohio DOR staff archaeologist has a Ph.D. in North American Prehistoric and Historic Archaeology with expertise in Ohio Valley and Columbia Plateau (Northwest America) archaeology and ethnohistory. The archaeologist has over 20 years of professional experience in the discipline, including, a decade of college and university teaching, six years with Ohio DOR, and two years as tribal archaeologist, Calville Reservation, Washington State. The Ohio DOR archaeologist has had his dissertation published, as well as numerous articles.
   3. What do the in-house staff do: Ohio DOR archaeologist researches, writes, and implements, historic preservation rules and regulations for surface, underground, AML reclamation, AML emergency and state no-cost AML projects. The archaeologist is charged with administering the archaeology program for all regulatory and AML projects. The archaeologist is in daily contact with SHPO on various projects, MOU's, mitigation strategies, program/policy procedure amendments, and technical matters. The archaeologist performs research at the Ohio Historical Society and county historical societies as well as on-site reviews, as necessary, to clear or delineate those survey areas that are "archaeologically sensitive". The archaeologist holds training sessions for DOR staff, contacting archaeologists and industry on various aspects of archaeology. He also is the facilitator of the Taskforce to reduce the costs of archaeology surveys for industry and obtain funding for the experiment to determine the effects of subsidence on subsurface archaeology sites in order to create an MOU on full coal recovery areas. The archaeologist also attends and participates in several professional meetings and OSM and Advisory Council Training courses conducted annually. In addition to several other duties, the DOR archaeologist conducts on-site meetings between DOR, SHPO, OSM (as necessary), contracting archaeologists and applicants on all Phase 4 mitigation projects (with an impressive record in cutting costs to applicants). The DOR archaeologist does not perform any surveys himself given the magnitude of his duties and responsibilities (not all of which are mentioned here).
2. Do you fund SHPO: Ohio DOR does not provide any funding to SHPO.
   Level of service provided by SHPO: Ohio SHPO is afforded comment on all surface and underground projects, provides technical assistance when required, and signs off on all AML federal (Section 106 NHPA) projects.
   
3. Do you have an interagency agreement with SHPO: Ohio DOR does have MOU's with SHPO for regulatory and AML archaeology programs. These MOU's are in the process of being updated and revised. Briefly, SHPO is afforded comment on all aspects of archaeology throughout the permitting process for all surface and underground operations. SHPO is provided with a copy of the Attachment 27 (surface) or 27A (underground) which contains archaeology related and project area data as well as a copy of the application map. SHPO provides comment within the 30 day comment period recommending clearance of a Phase I or II survey. Ohio DOR archaeologist performs research as described in #1c above. DOR informs the applicant the area is cleared of a full or partial survey is necessary. The applicant hires qualified archaeologists to perform the work, and both applicant and archaeologists are in routine communications with the DOR archaeologist who then review the survey reports and sends one copy to SHPO for their comment. If SHPO recommends additional investigation, the applicant may avoid the archaeological site and receive a conditional permit issuance or perform a high level survey, the scope of which is determined by the DOR archaeologist.
         AML projects follow the same process except the DOR archaeologist does not have the final word, SHPO does (SMCRA archaeology regulations vs NHPA Section 106, 110 law).
   
4. . Level of protection under permitting and enforcement:
   1. Sites on NRHP: Ohio DOR, to date, has not dealt with a listed NRHP property on a surface, underground or AML mining operation. If, however, a listed property is encountered SHPO would be involved through comment, review of any mitigation plans, on-site meetings, etc. Any eligible NRHP property within a surface or surface affected underground application area is treated as follows: the applicant is given the option to avoid the eligible property with the boundaries flagged, and permit issuance conditioned, or if avoidance is not possible (usually due to economic reasons), the applicant must have a Phase 4 (mitigation) survey performed by qualified professionals after the DOR archaeologist and SHPO review and approve (usually with substantial realistic modifications) the mitigation plan. Mitigation on underground full coal recovery areas only applies to eligible standing historic structures. No archaeological surveys are currently performed on full coal recovery areas, except where surface impacts would occur. All AML archaeology projects fall under NHPA Section 106 and 110.
   2. Criteria for defining "known" sites: In the Ohio DOR application, an Attachment 27 and 27A, is sent to SHPO for review. One part requires SHPO to list all known sites within a 1.5 mile radius of the project area. Ohio DOR field staff also inform the archaeologist of obvious sites while performing reviews. Known sites usually have not had Phase 3 eligibility assessment studies performed on them. Ohio DOR provides the applicant, early in the application process, with the option of avoiding the known sites. If this is not possible then the applicant has the option of documenting the site (if known but not documented) to save money or contracting qualified archaeologists to document and assess the site's eligibility status. Criteria for a known site include previous documentation of a site filed at the SHPO, a site discovered during research or on-site reviews by the archaeologist of field staff, or a site brought to DOR of SHPO's attention by a local landowner collector or other public avenue.
   3. Criteria for defining "high-probability" sites: SHPO comment on a project area usually identifies those areas likely to be "archaeologically sensitive". The DOR archaeologist then performs research (literature and on-site reviews) to specifically clear or delineate survey areas since the date sent to SHPO, specifically the application map, fails to identify all types of disturbance within the project area (drill roads, primary, and secondary effects from previous mining, clearcut logging, etc.) Criteria used by the DOR archaeologist to identify "high probability" sites include disturbance to an area, topographic setting in relationship to other known and eligible sites, geological strata on steep slopes (conducive to rock over-hang/shelter formation), visibility (degree of site alteration), focus (quantity and quality of artifactual remains), on-site review, etc.
5. If permit applicant owns property to be mined: For Ohio DOR, if the applicant owns the project area, including the archaeological resources, he/she has to follow the procedure identified in #4 above. Ohio DOR does not make a distinction since the SMCRA archaeology rules and regulations do not make any distinction. The applicant must abide by the rules and regulations whether for archaeology, hydrology, blasting, etc. if he/she owns the project area or is leasing it form private landowners. There has not been one instance the DOR archaeologist is aware of (since he began in 1986 where an applicant has refused to do an archaeological survey when required regardless of whether the applicant owner the project area or was leasing it.

NORTH CAROLINA (Non-Coal)

1. Have you hired outside staff or contractors: No. North Carolina Department of Environment, Health and Natural Resources routes copies of the application to the North Carolina Division of Archives and History, Department of Cultural Resources.
   1. Number: N/A.
   2. Expertise: N/A.
   3. What do they do: They perform site inspections and comment as to whether there is a high probability for archaeological resources.
2. Do you fund SHPO: No. They have their own funding.
   Level of service provided by SHPO: N/A.
   
3. Do you have an interagency agreement with SHPO: We have a cooperative agreement to advise them of all new/proposed mine sites; then if the potential is high for archaeological resources, they contact the operator directly and handle the situation from there.
   
4. Level of protection under permitting and enforcement:
   1. Sites on NRHP: We adjust blasting limits and buffer zone widths when these structures are in close proximity to a mine.
   2. Criteria for defining "known" sites: Department of Cultural Resources does this and maintains an inventory.
   3. Criteria for defining "high-probability" sites: Department of Cultural Resources is responsible for this.
      
5. If permit applicant owns property to be mined: Conditions of the permit are still adjusted no matter who owns/operates the mine.

PENNSYLVANIA

1. Have you hired outside staff or contractors: No.
   1. Number: N/A.
   2. Expertise: N/A.
   3. What do they do: N/A.
      
2. Do you fund SHPO: Yes.
   Level of service provided by SHPO: Through a coordinated review process, the SHPO identifies if known historic or archaeologic resources exist or if there is a high probability of these resources existing.
   
3. Do you have an interagency agreement with SHPO: Pennsylvania is currently in process of developing an agreement.
   
4. Level of protection under permitting and enforcement:
   1. Sites on NRHP: Avoidance and mitigation.
   2. Criteria for defining "known" sites: SHPO usually asks for avoidance/mitigation. SHPO and the applicant communicate directly to work things out. There is no criteria for defining "known" sites.
   3. Criteria for defining "high-probability" sites: SHPO utilizing model to determine if a specific site has a high probability of containing archaeological resources. SHPO usually asks for a site survey. SHPO and applicant communicate directly to work things out.
5. If permit applicant owns property to be mined: Same level of protection provided except permit applicant and SHPO are usually more amenable to mitigation.

SOUTH CAROLINA (Non-Coal)

1. Have you hired outside staff or contractors: State has required third-party consultants to be retained by operator to conduct archaeological surveys.
   1. Number: 3-4
   2. Expertise: Specific expertise in conducting detailed archaeological surveys, mapping artifacts, and developing mitigation procedures.
   3. What do they do: See b. above.
2. Do you fund SHPO: N/A.
   Level of service provided by SHPO: N/A.
   
3. Do you have an interagency agreement with SHPO: N/A.
   
4. Level of protection under permitting and enforcement:
   1. Sites on NRHP: Operators are required to propose and implement methods to limit significant adverse effects on significant cultural or historic sites.
   2. Criteria for defining "known" sites: If sites are not considered eligible for listing, they generally are not considered "significant" for protection pursuant to the Mining Act.
   3. Criteria for defining "high-probability" sites: The South Carolina Land Resources Commission relies on the expertise and comments of the South Carolina Department of Archives and History to determine high-probability sites - generally investigate tracts greater than 50 acres.
5. If permit applicant owns property to be mined: From a permitting perspective, ownership vs leasing is not a factor for consideration. All requirements pursuant to the South Carolina Mining Act apply to all mine sites.

VIRGINIA

1. Have you hired outside staff or contractors: Yes.
   1. Number: Two.
   2. Expertise: Consulting Engineering firm subcontracts to archaeologist listed by the SHPO to investigate AML projects.
   3. What do they do: Conduct Phase I archaeological surveys and evaluate potential for historic significance.
2. Do you fund SHPO: No.
   Level of service provided by SHPO: N/A.
   
3. Do you have an interagency agreement with SHPO: Virginia is currently in the process of developing an interagency agreement with the SHPO.
   
4. Level of protection under permitting and enforcement:
   1. Sites on NRHP: SHPO would determine potential impact and recommend action regarding historic/archaeological site.
   2. Criteria for defining "known" sites: Provided by consultation with SHPO.
   3. Criteria for defining "high-probability" sites: Evaluation may be conducted by an archaeologist. No specific criteria.
5. If permit applicant owns property to be mined: Ownership of the property including the historic or archaeological resources on the property does not have any effect on the responses to Question 4 above.

WEST VIRGINIA

1. Have you hired outside staff or contractors: No. (See below.)
   1. Number: N/A.
   2. Expertise: N/A.
   3. What do they do: N/A.
2. Do you fund SHPO: Our agency has proposed the funding of two positions for the WV SHPO. Details concerning the type and level of service provided have not been finalized.
   Level of service provided by SHPO: N/A.
   
3. Do you have an interagency agreement with SHPO: WVDEP is in the process of finalizing an agreement with the SHPO which will detail both agencies' roles and responsibilities.
   
4. Level of protection under permitting and enforcement: The West Virginia Division of Environmental Protection's current procedures require the applicant to notify the WV SHPO of their proposed mining operation by submitting appropriate maps and a description of the operation. SHPO, in turn, reviews the proposal to identify known or probable historic or archaeological sites and issues a recommendation based on their findings. This recommendation may range from requiring a detailed site survey by an approved archaeologist, to not requiring any further information. The WVDEP requires the applicant to comply with the SHPO's request, which may include protection, documentation, or artifact recovery, before a mining permit is issued.
              In some cases, the SHPO is not specific as to what they are looking for, resulting in detailed site surveys being prepared on the entire proposed area. This is expensive for the applicant and tends to delay the final review and processing of an application.
   1. Sites on NRHP: N/A
   2. Criteria for defining "known" sites: N/A
   3. Criteria for defining "high-probability" sites: N/A
   5. If permit applicant owns property to be mined: This has no effect on permitting and enforcement.

Survey conducted by: Joyce Zweben Scall

TABLE OF RESPONSES

ALABAMA

Hire Staff or Contractor Application Ffee	Fund SHPO	Interagency Agreement (MOA)	Landowner Follows Same Rules
Outside: No In-house: No Other Dept.: N/A	Yes	No MOA	Yes

ARKANSAS

Hire Staff or Contractor Application Fee	Fund SHPO	Interagency Agreement (MOA)	Landowner Follows Same Rules
Outside: No In-house: No Other Dept.: N/A	No	No MOA	Yes

ILLINOIS

Hire Staff or Contractor Application Fee	Fund SHPO	Interagency Agreement (MOA)	Landowner Follows Same Rules
Outside: No In-house: Yes (1) Other Dept.: N/A	No	No MOA but work together	Yes

INDIANA

Hire Staff or Contractor Application Ffee	Fund SHPO	Interagency Agreement (MOA)	Landowner Follows Same Rules
Outside: No In-house: Yes (2) Other Dept.: N/A	Yes	MOA being developed	Yes

KENTUCKY

Hire Staff or Contractor Application Ffee	Fund SHPO	Interagency Agreement (MOA)	Landowner Follows Same Rules
Outside: No In-house: Yes (3) Other Dept.: N/A	Yes	Have MOA	Yes

MISSOURI

Hire Staff or Contractor Application Ffee	Fund SHPO	Interagency Agreement (MOA)	Landowner Follows Same Rules
Outside: No In-house: No Other Dept.: N/A	No	No MOA but work together	Yes

OHIO

Hire Staff or Contractor Application Ffee	Fund SHPO	Interagency Agreement (MOA)	Landowner Follows Same Rules
Outside: No In-house: Yes (1) Other Dept.: N/A	No	Have MOA	Yes

NORTH CAROLINA

Hire Staff or Contractor Application Ffee	Fund SHPO	Interagency Agreement (MOA)	Landowner Follows Same Rules
Outside: No In-house: No Other Dept.: Yes	No	Have MOA	Yes

PENNSYLVANIA

Hire Staff or Contractor Application Ffee	Fund SHPO	Interagency Agreement (MOA)	Landowner Follows Same Rules
Outside: No In-house: N/A Other Dept.: N/A	Yes	MOA being developed	Yes

SOUTH CAROLINA

Hire Staff or Contractor Application Ffee	Fund SHPO	Interagency Agreement (MOA)	Landowner Follows Same Rules
Outside: Yes* In-house: N/A Other Dept.: N/A *Outside contractors are hired by applicants	N/A	MOA being developed	Yes

VIRGINIA

Hire Staff or Contractor Application Ffee	Fund SHPO	Interagency Agreement (MOA)	Landowner Follows Same Rules
Outside: Yes In-house: N/A Other Dept.: N/A	No	MOA being developed	Yes

WEST VIRGINIA

Hire Staff or Contractor Application Fee	Fund SHPO	Interagency Agreement (MOA)	Landowner Follows Same Rules
Outside: No In-house: N/A Other Dept.: N/A	WVDEP is considering funding 2 positions	MOA being developed	Yes

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