Elizabeth C. Reetz, IAS Newsletter Editor, UI Office of the State Archaeologist
Newsletter of the Iowa Archeological Society, Issue 267, Vol. 76, No. 2, Summer 2026
Copyright: CC BY-NC-SA 4.0 (Attribution-NonCommercial-ShareAlike 4.0 International)
The term “Section 106” is deeply engrained in the Cultural Resources Management (CRM) profession that dominates contemporary archaeological study. Those with an interest in Iowa archaeology or historic preservation have probably heard the term, but relatively few understand all the nuances. Many people from the public at large are completely unfamiliar with the process. One of the reasons Section 106 is not often talked about despite being so integral to our work is that—it works. Like a building’s mechanical room, Section 106 quickly and efficiently keeps the historic preservation world quietly humming along—with all interested parties having a seat at the table when the process is done correctly.
Section 106 is critical to archaeological research and employment and has been since the late 1960s. Compliance with Section 106 accounts for approximately 60 percent of all CRM work in the US,[1] and the Advisory Council on Historic Preservation (ACHP) estimates that more than 90 percent of the archaeological excavations conducted in the US are done so pursuant to Section 106.[2] In Iowa, Section 106 compliance dominates the archaeological profession, and much of the archaeological knowledge we’ve built over the past nearly 60 years can be attributed to it.
Understanding Section 106 of the National Historic Preservation Act
Sixty years ago, President Lyndon B. Johnson signed the National Historic Preservation Act (NHPA) into law after it passed through both the senate and house with bipartisan, unanimous consent.[3] This legislation was a reaction to the rapid destruction of significant historical buildings and cultural sites following the post-World War II nationwide building boom that included Eisenhower’s Interstate Highway System and Kennedy’s Urban Renewal Program. Congress recognized the inadequacy of existing historic preservation laws and determined that preservation was integral to the public’s interest so that future generations could appreciate and enjoy our nation’s rich heritage.[4] Through the NHPA, Congress established the ACHP, the National Register of Historic Places (NRHP) managed and administered by the National Park Service (NPS), State Historic Preservation Offices (SHPO) and Officers, and the Section 106 process. In amendments passed in 1992, the NHPA authorized Native American Nations, Alaska Natives, and Native Hawaiian Organizations (hereinafter referred to as Tribes) to assume the functions of a Tribal Historic Preservation Officer (THPO) on Tribal lands, and through the law, Congress required agencies to consult with any Tribe that attaches religious and cultural significance to a property, regardless of whether the property sits on Tribal land.[5] This nation-to-nation relationship acknowledges Tribal sovereignty and government-to-government consultation between the US and federally recognized Tribes.
The NHPA is a statute—a formal, written law passed by Congress and signed by the president. The Section 106 regulations provide the procedures and details for implementing the statute through administrative rule 36 CFR Part 800. These regulations were promulgated in 1974 by the ACHP under the power given to it by Congress through the NHPA statute, and the ACHP in turn advises Congress on historic preservation matters. In other words, federal regulations such as Section 106 are under the jurisdiction of an executive agency and can be changed by an administration through rulemaking, while federal statutes are under the jurisdiction of Congress, who also define the authority and limits of federal agencies. A statute (in our example, the NHPA) establishes binding legal requirements, and regulations (here, we mean Section 106) cannot go against the statute that created them.
Section 106 mandates that federal agencies identify and assess the direct and indirect effects their undertakings have on historic properties through a review process and provide the ACHP with a reasonable opportunity to comment. As currently defined in the regulations, an undertaking is any project, activity, or program funded in whole or part under the direct or indirect jurisdiction of a federal agency, including those carried out by or on behalf of a federal agency; those carried out with federal financial assistance; and those requiring a federal permit, license, or approval.[6] This is why many state and local development projects fall under Section 106. Historic properties, as currently defined, are any historic or precontact archaeological site, building, structure, object, or historic district included in, or eligible for inclusion on the NRHP,[7] as well as properties of traditional religious and cultural importance to a Tribe and that meet National Register criteria.[8] The review process involves consultation between federal agencies and SHPO/THPOs, as outlined in the statute, and the regulations require agencies to involve project applicants and seek and consider the views of the public, state and local governments, and other interested parties. In essence, state and local governments, Tribes, and the public all have a voice regarding their local history, before any development occurs in their communities.
The Section 106 process is a maximum of four steps that begin in the early stages of project planning. You can learn more about the full process in more depth from the ACHP or Iowa SHPO. Simplified, the four steps are as follows: Step 1 initiates consultation, Step 2 identifies historic properties and evaluates whether those properties have significance and integrity for NRHP eligibility, Step 3 assesses adverse effects to all eligible historical properties, and Step 4 resolves those adverse effects, often leading to a legal agreement to ensure the process is completed. In Step 1, a lead federal agency is assigned and determines if a proposed action is an undertaking and, if so, whether that undertaking has the potential to affect historic properties. The agency identifies the SHPO/THPOs who should participate in the review, along with the applicant who applied for federal assistance for the project and any local governments or Tribes affected (collectively referred to as the consulting parties), and they make a plan to involve the public. Steps 2 through 4 involve all the consulting parties, and public involvement moves beyond planning to actionable activities.
Once a determination is made in Step 2, SHPO/THPOs have 30 days to review and either concur, object, or request more information. The federal agency must address the feedback or find a resolution through further consultation before moving forward. If a disagreement cannot be resolved, the ACHP may be invited to consult. Congress.gov notes that an estimated 85 percent of Section 106 reviews to determine eligibility are found to not involve historic properties, and the federal agency has no further obligations under Section 106.[9] Also, it has been noted that many projects advance considerably quicker than the 30-day statutory turnaround time.[10]
For the relatively small number of historic properties that meet NRHP criteria of significance which are present or affected by an undertaking, Step 3 proceeds to assess any adverse effects caused by the undertaking, as defined in 36 CFR 800.5(a)(1). Basically, an adverse effect is found if the undertaking alters directly (destruction, damage, removal, neglect, change in use) or indirectly (visual, audible, setting) any characteristics of the historic property that make it eligible for the NRHP. An adverse effect diminishes the property’s integrity, whether immediately, later in time, or even cumulatively. If there are no adverse effects, the federal agency again provides documentation to SHPO/THPO and consulting parties for a 30-day review where a lack of objection means the federal agency has completed their Section 106 obligations.
If there is an adverse effect, Step 4 is to resolve it by developing or considering alternatives or modifications to avoid, minimize, or mitigate the harm to the historic property. Statistics from across the nation indicate that just three percent or fewer of all Section 106 reviews require the full four-step resolution.[11] It’s in this step where consultation between the federal agency, SHPO/THPOs, interested parties, and particularly the local community, is critical to figure out ways to avoid or mitigate adverse effects. Often, avoidance or alternatives are the solution, and all negative impacts to historic properties are averted or greatly minimized. Some undertakings move into a mitigation that is agreed upon through consultation because destruction of a historic property cannot be avoided. This often involves documenting the historic property in as much detail as possible before it is destroyed or compromised, in accordance with a treatment plan created by the consulting parties.
In summary, the Section 106 process allows the consulting parties and the public to properly and efficiently assess an undertaking’s impacts and seek ways to avoid, minimize, or mitigate any adverse effects on historic properties. Section 106 does not dictate a preservation outcome or mandate that preservation has to happen but allows interested parties to weigh in and comment on projects that affect their local communities and ancestral lands in a way that balances preservation and development. The vast majority of undertakings are able to proceed with no adverse effects, because when the interested parties work together to make informed decisions, they often find economically viable project alternatives that avoid or minimize the impact to historic properties. Good consultation prevents conflicts, lawsuits, and the loss of important historic and cultural heritage.
Section 106 Efficiency in Iowa
In Iowa, Section 106 review is conducted by the SHPO in Des Moines, which is housed within the Iowa Economic Development Authority (IEDA). SHPO also manages Iowa’s Historic Preservation Tax Credit program, Certified Local Government (CLG) program, and NRHP submissions, and they maintain the Iowa Inventory on architectural and historical resources around the state. SHPO currently has more than 140,000 properties (historic structures, buildings, and objects recorded to date) documented in GIS, including those listed on the NRHP and those that are potentially eligible for listing, as well as 392 historic districts.[12]
Four SHPO staff members participate in Section 106 review. In Federal Fiscal Year (FFY) 2025, they received 1,929 submissions for 1,511 projects and reviewed 91 percent of those submissions within 30 days. Their average review timeline was around 13 days. About one percent (19 projects) of those FFY2025 reviews resulted in an agency determination of adverse effects.[13] Iowa SHPO also excels in consultation and community reach. They collaborate with more than 30 federal and state agencies, consult with dozens of Tribal Nations, and partner with the Iowa Department of Administrative Services, Iowa Department of Transportation (Iowa DOT), and Department of Natural Resources for technical assistance on federal projects and state-owned historic properties.[14] In FFY2025, SHPO had projects in all 99 Iowa counties, involving over 450 communities. They also work with over 90 CLG programs, which include both cities and counties across the state.[15] Iowa currently has the second largest number of CLGs in the nation and continues to grow.
Through a Programmatic Agreement between the Iowa Division of the Federal Highway Administration (FHWA), SHPO, Iowa DOT, and ACHP, the Iowa DOT also participates in Section 106 review and publishes a report assessing their efficiency and effectiveness every State Fiscal Year (SFY), from which the following information was compiled.[16] They consult on Section 106 matters with as many as 28 Tribal Nations and have active formal agreements with five Tribes. Through consultation, they developed the Minor Projects classification program in 2018 to streamline the Section 106 process. Minor Projects consist of low-impact situations such as intersection reconstruction or pavement replacement, and the reviews are completed in one to two days.
Cumulatively over SFY2023-2025, the Iowa DOT completed more than 1,760 Section 106 projects. They completed 70 percent of those projects as Minor Projects, which formed a higher percentage of Iowa DOT projects; however, pending issuance of the statewide historic bridge survey has resulted in a temporary increase in projects requiring full review. Projects where no historic properties were identified in the Area of Potential Effects (APE) comprised 18 percent of reviews, and projects where the project had no potential to cause effect or had no adverse effect on historic properties collectively totaled 22 percent of reviews. One percent of projects underwent reevaluation to collect more information, and only eight projects in a three-year span had adverse effects that required consultation for avoidance, alternatives, or mitigation.
It is important to note that Section 106 projects that end with a determination of no adverse effect or no potential to cause effect reach that conclusion because the consulting parties work together to find economically viable solutions to identify alternatives that do not impact the historic properties in the APE. The parties are also able to reflect on and notice where things could have gone wrong but did not, which helps them to contextualize future reviews. In short, no adverse effect determinations emphasize good planning and good advice stemming from an efficient and effective Section 106 process.
The Impact of CRM in Iowa
Economics
Nationally, CRM is a booming industry. Society for American Archaeology president, Chris Dore, calculates of the CRM industry in 2025 was worth over one billion dollars, with an estimated 60 percent of that revenue from Section 106-related work.[17] As much as 90 percent of the archaeology done in the US today is carried out in the field of CRM, and about 90 percent of all US archaeologists work in CRM.[18] Similarly, the ACHP estimates that more than 90 percent of all archaeological excavations conducted in the US are done so pursuant to Section 106.[19] Section 106 archaeology has yielded an enormous wealth of data on which most recent advances in the understanding of North American archaeology depend.[20] In FFY2020, it is estimated that CRM employed over 16,000 people, with archaeologists conservatively estimated as around 75 percent (equivalent to 12,000 full-time positions) of that labor force that also includes specialists in anthropology, earth sciences, history, architecture, landscape design, conservation, and collections management.[21] The industry also includes a cadre of supporting positions in contract management, administration, human resources, information technology, and other fields.[22] Relatedly, historic rehabilitation activity due to historic preservation efforts creates around 165,000 jobs each year.[23]
The CRM industry has been a longstanding and stable source of employment for professional archaeologists in Iowa. While it’s not possible to determine the exact number of organizations that currently conduct CRM work in Iowa, a few sources give us some insight, but these metrics may include overlap. For example, the American Cultural Resources Association (ACRA), a national network of professional firms and service partners representing the CRM industry and associated fields of study, currently has 70 member organizations that operate in Iowa. These organizations represent small businesses, CRM departments in environmental or engineering firms, government agencies, and universities that conduct CRM work.
The Association of Iowa Archaeologists documents nearly 70 members in their “Fellow” category, meaning they actively engage in some sort of archaeological investigations in Iowa. They represent three universities, 18 private businesses, and five local, state, or federal agencies. Members of this organization developed and continually update professional and scientific standards for what is primarily (but not exclusively) Section 106-related report preparation, excavation, and curation of archaeological materials recovered in Iowa.
The University of Iowa Office of the State Archaeologist (OSA), which maintains the Iowa Site File online GIS and database (I-Sites), reports 58 separate organizations that regularly conduct Section 106 archaeology or review in Iowa currently have annual and monthly subscriptions. Governmental organizations with subscriptions include 11 Iowa and regional offices of federal agencies, three Iowa state agencies, four state and regional universities, and 12 Tribal Nations. Private businesses with licenses include 20 environmental or engineering firms that do CRM contracting and eight CRM-focused small businesses. Nine of these private businesses have headquarters or regional offices in Iowa, 12 have offices in the greater Midwest, and seven are from other US locations. Besides the aforementioned I-Sites subscribers, five Iowa local governments, 10 additional CRM firms, 25 environmental or engineering firms, one regional university, and six developers requested archaeological site searches from OSA to assist with occasional CRM compliance projects in Iowa in the past year. Thus, there were a total of 105 organizations carrying out Section 106 compliance in Iowa, including 69 different private businesses.
While organizations outside of Iowa bring in hundreds of employees to patron Iowa hotels, restaurants, and other businesses during their stays required to carry out Section 106 investigations, Iowa-based organizations and agencies also support a substantial workforce of professionals who live and work in across the state. Whether agencies or private businesses, almost all Iowa-based organizations doing Section 106 work have been operating for over 20 years. Many engineering firms were founded prior to the 1966 passage of the NHPA, while CRM-focused organizations still operating today sprang up each decade between the 1960s and 2000s. The workforce of these Iowa businesses is comprised of 81-100 percent permanent, full-time salaried employees, and almost all employ seasonal employees or interns.[24]
All of these organizations operating in Iowa collectively generate tens of millions of dollars in revenue, with several Iowa-based firms generating $1-5 million annually. While the larger Iowa-based engineering firms earn about 10-30 percent of their revenue from work pursuant to Section 106, at least seven smaller businesses with one to 25 employees rely on Section 106 for at least 90 percent of their work. Notably, from the 30-year period 1996-2025, OSA’s contract arm captured over $70 million in external funding associated with Section 106 work, which generated over $13 million in support of the facilities and administration pool at the University of Iowa.
Archaeological Research
As mentioned, an estimated 90 percent of all archaeology done in the US is pursuant to Section 106, and Iowa is no exception. Archaeologists who work for SHPO participate in all four steps of the review process, but most archaeologists serve as qualified specialists to identify, assess, interpret, and preserve archaeological sites affected by undertakings. As of this writing, Iowa has 32,697 recorded archaeological sites; notably only 1,362 of those sites were recorded prior to the passage of the NHPA in 1966.
About 95 to 99 percent of Section 106 work done annually in Iowa involves Phase IA desktop assessments and Phase I intensive surveys, contracted to help applicants with identifying historic properties (Step 2 as described above). While much of the public envisions archaeological work as an excavation, Phase IA and I work entail a lot of archival research to determine whether any historic properties are currently documented within the APE, what archaeological survey has been done previously, and the geographical and geological nature of the APE and the existing built environment within it. Archaeologists use systematic field methods to discover and document new archaeological sites, including pedestrian walkovers of plowed fields or—what sometimes feels like endless—lines of shovel test or auger pits dug and screened every 30 to 50 feet. If archaeologists find new sites or relocate previously recorded ones during Phase I survey, then they establish the site’s context and make recommendations for further study. If the site has integrity and may teach us something about the archaeological past we may not already know, Phase II archaeological testing is recommended.
This part of Step 2 is iterative, and the agency makes a determination on whether they can avoid impact to the newly identified historic properties or if they want to proceed with Phase II archaeological testing to evaluate whether those properties have significance and integrity for NRHP eligibility. If they proceed, Phase II work is typically short-term and small-scale. Archaeologists look for undisturbed features (non-portable or structural elements like storage pits, hearths, or foundation walls) or an artifact assemblage or density that may reveal new insights about the past, making the site eligible for the NRHP. If the site is deemed eligible for the NRHP, the Section 106 consulting parties work through Step 3 to determine if adverse effects will impact the site—and there may not be any adverse effects, meaning the project can proceed.
If there are adverse effects, the consulting parties work through Step 4 to determine how to resolve those adverse effects through avoidance, alternatives, or mitigation. As mentioned, in Iowa, one percent or fewer projects reviewed annually have adverse effects to historic properties, and many of those that do end up finding some way through consultation to avoid impact or greatly minimize impact to the historic property. This is why the large-scale excavations that the public associates with archaeology are very rare. There are circumstances though when destruction of historic properties cannot be avoided, due to, for example, exorbitant costs or removal of a dangerous curve in a road that cannot be engineered in any other way. In archaeology, Phase III data recovery excavation is the most common method of mitigating damage to an archaeological site that otherwise cannot be avoided. These excavations are extensive, rigorous, and align with thoughtful research questions to help archaeologists gather as much data and information about the site as possible and build new knowledge of the past. Not only are these projects rare, but contractor liability, project timelines, and the need to keep the Section 106 process expedited mean that opportunities for volunteers to participate in these excavations are often not possible. However, Phase III data recovery usually includes a public outreach component where archaeologists share what they have learned through public publications, programming, and educational resources.
Section 106 compliance work, notably Phase III excavations, have contributed significantly to advancements in Iowa archaeology and to our collective knowledge of the past. The most notable advancement we can attribute to the passage of the NHPA is the Iowa laws protecting human remains and burial contexts passed in 1976. It was during extensive archaeological excavations in tandem with new US 34 highway construction in Mills County in the early 1970s when a Native American burial was discovered within the boundaries of a historic Euro-American cemetery being relocated outside of the new road alignment. While those of Euro-American descent were respectfully reburied, the Native American woman was placed in a box on a shelf in Iowa City for future study. Maria Pearson, Yankton Sioux, heard about this from her husband, an Iowa DOT engineer on the project, and famously visited Governor Robert D. Ray at the capitol in full regalia to demand a conversation about the injustice. Pearson and Ray worked with Don Wanatee (Meskwaki) and the new Iowa state archaeologist, Duane Anderson, to draft and codify the Iowa burial laws, which ultimately served as an example for the Native American Graves Protection and Repatriation Act (NAGPRA), passed into federal law in 1990. Since 2014, when Lara Noldner began as OSA Bioarchaeology Director, Section 106 consultation has resulted in the protection of 286 cemeteries from destruction by development.
Archaeologists and Tribes have participated in numerous Section 106 projects that have built our collective knowledge of Iowa’s ancient past. Ahead of construction for the Great River Road (US 61) in the early 1990s, archaeologists and Tribal Nations learned extensive information about Wever Terrace, a cluster of villages ancestral to the Iowa Tribe along the Mississippi River that yielded nearly 200,000 artifacts. Later that decade, archaeologists on the opposite site of the state confirmed the importance of corn agriculture starting 1,000 years ago during excavations at the Cowan Site, a rare Great Oasis culture farming hamlet in Woodbury County, prior to construction of the US 75 bypass around Sioux City. During the construction of a new wastewater treatment facility in Des Moines in 2010, archaeologists documented Iowa’s oldest-known houses and human burial from about 7,000 years ago at the Palace Site, an extraordinarily well-preserved and deeply buried site north of the Des Moines River. In 2016, OSA and the Iowa DOT worked with Tribal partners to excavate the Dixon Site in Woodbury County, balancing preservation with critical infrastructure needs. Riverbank stabilization was necessary to protect the roadway, while archaeological features and burials were in danger of eroding into the Little Sioux River. Also in the mid-2010s, during an expansion of US 20 in Woodbury County, archaeologists, Tribal historians, and the Iowa DOT collaborated to balance transportation needs while protecting cultural resources at sites near Correctionville after geoglyphs and villages ancestral to the Iowa, Dakota, Ponca, and Omaha Tribes were revealed prior to roadway expansion. The Iowa DOT created a documentary about this Section 106 collaboration, and recently, the City of Correctionville installed an archaeological interpretive display and sculptural pieces commemorating the project.
Infrastructure developments that contributed to our knowledge of historic-period archaeology are numerous. In the early 1990s, excavations in a road construction right-of-way in the Mines of Spain Recreation Area located intact features from a circa 1800 Meskwaki village, demonstrating their importance to the early lead mining era from 1788-1860. In Des Moines, the Southeast Connector project to improve traffic flow around downtown Des Moines in the 1980s and the construction of a new sewer route in the 2000s enabled archaeologists to document the location of Fort Des Moines, the foundational, historic origins of Iowa’s capital and largest city. To mitigate adverse impacts on sites stemming from improvements to US 151 in the mid-1990s-2000s, archaeologists chronicled innovations in 19th century dairy farming at the Bowen’s Prairie Historical District in Jones County. In West Branch, archaeologists located the Jesse Hoover Blacksmith Shop at Herbert Hoover National Historic Site to ensure it was not destroyed by the restoration of Penn Street in the 1970s, and they found artifacts likely belonging to a young Herbert. In 2013 in Iowa City, OSA recorded the transition of Iowa City from a Territorial-period outpost to a thriving, urbanized campus community during excavations prior to construction of the Voxman School of Music at the University of Iowa to replace the former music building damaged during the flood of 2008.
Beyond archaeology, Section 106 has contributed to our knowledge of Iowa history. As an example, before reconstruction in 2002, historians documented the importance of “The Seedling Mile,” the first stretch of rural concrete pavement laid in 1918-19 on the Lincoln Highway in Linn County, in part to help prove the benefits of concrete paving to improving road travel across the nation. In Delaware County, architectural historians recorded the importance of the Quaker Mill Dam, an early 20th century low head dam with unique design features, before it was demolished in 2017-18 to eliminate a severe public safety hazard and restore a stretch of the Maquoketa River. Recently, Lansing, Iowa and nearby communities rallied to help the Iowa DOT create a documentary about the historical importance and collective memory of the Black Hawk Bridge across the Mississippi River before it was demolished in 2025 after 94 years of service, prior to it becoming unstable and unsafe for vehicle traffic. This is a great example of a historic property that could not be saved, but community participation and input resulted in mitigation that helped to preserve and share their memory and knowledge.
Section 106 Works
A consultation process that involves multiple stakeholders is essential to preserving our historical sites and knowledge about the past. In the past, when unilateral decisions were made by either agency officials or applicants, historic properties were unnecessarily destroyed. This resulted in extensive project delays, litigation, significant added expenses, and even mistrust. A notable and well-documented example from Iowa occurred from about 1999-2009, when park leadership at Effigy Mounds National Monument (EFMO) ignored the Section 106 process entirely and commenced with building boardwalks throughout the park. This construction damaged Native American burial mounds and sacred areas, which would have been easily identified through Section 106. Tribes descendant to the area were infuriated and lost trust in EFMO and the NPS. The park made extensive staffing changes and has worked for over 15 years to rebuild their Tribal and community relationships. These compliance failures and resulting destruction were so egregious that the Department of the Interior centered EFMO has an example in an overhaul of their Section 106 staff training for employees nationwide.
Overall, the Section 106 process works, and it works most effectively and efficiently when the consulting parties collaborate on decision making and Tribes, local governments, and the public are involved to both share their knowledge about historic properties and speak to the best paths forward for their communities.
Footnotes
[1] Amanda Stratton, email message to author, August 17, 2026.
[2] “Section 106 Archaeology Guidance,” Advisory Council on Historic Preservation (ACHP), accessed August 19, 2026, https://www.achp.gov/Protecting-Historic-Properties/Section_106_Archaeology_Guidance.
[3] Alexandra Z. Levine, “Important Victory Won for Historic Preservation,” Natural Resources Journal 19, no. 2 (1979): 385-391, https://digitalrepository.unm.edu/nrj/vol19/iss2/10.
[4] “National Historic Preservation Act of 1966.” National Park Service, last modified February 10, 2025, https://www.nps.gov/subjects/archeology/national-historic-preservation-act.htm.
[5] Amanda Sanchez, “When Consultation Becomes a Formality: The Rushed Rewrite of Section 106 and What It Means for Indigenous Sovereignty, “The Sovereign Brief 1, Special Issue (2026), https://www.linkedin.com/pulse/when-consultation-becomes-formality-rushed-rewrite-section-sanchez-gej1e/?trackingId=X1pSOM4o2lsHlBkGKIqt2Q%3D%3D
[6] “Section 106,” Iowa Economic Development & Finance Authority, accessed August 18, 2026, https://opportunityiowa.gov/community/historic-preservation/section-106.
[7] “Section 106 Archaeology Guidance – Terms Defined,” ACHP, accessed August 19, 2026, https://www.achp.gov/Section_106_Archaeology_Guidance/Terms%20Defined
[8] “National Historic Preservation Act, Section 106 A Quick Guide for Preserving Native American Cultural Resources,” US Department of the Interior, National Park Service, American Indian Liaison Office, Draft 2012, accessed August 18, 2026, https://growthzonecmsprodeastus.azureedge.net/sites/2385/2022/02/nhpa-section-106_nps.pdf
[9] Mark K. DeSantis, “Historic Properties and Federal Responsibilities: An Introduction to Section 106 Reviews,” CONGRESS.GOV, published May 5, 2023, https://www.congress.gov/crs-product/R47543
[10] “Section 106 Isn’t the Bottleneck—But It’s on the Chopping Block,” Cultural Heritage Partners, published November 3, 2025, https://culturalheritagepartners.com/section-106-isnt-the-bottleneck/
[11] Cultural Heritage Partners, “Section 106 Isn’t the Bottleneck.”
[12] Heather Gibb, email message to author, August 12, 2026.
[13] “State Historic Preservation Office Fact Sheet 2026,” Iowa Economic Development Authority. Document JG 02272026.
[14] “SHPO Fact Sheet 2026.”
[15] Heather Gibb.
[16] Brennan J. Dolan, “Section 106 Programmatic Agreement Annual Report, State Fiscal Year 2023,” Iowa Department of Transportation, Cultural Resources Section, Location and Environmental Bureau, Report on file at the University of Iowa Office of the State Archaeologist; Brennan J. Dolan, “Section 106 Programmatic Agreement Annual Report, State Fiscal Year 2024,” Iowa Department of Transportation, Cultural Resources Section, Location and Environmental Bureau, Report on file at the University of Iowa Office of the State Archaeologist; Brennan J. Dolan, “Section 106 Programmatic Agreement Annual Report, State Fiscal Year 2025,” Iowa Department of Transportation, Cultural Resources Section, Location and Environmental Bureau, Report on file at the University of Iowa Office of the State Archaeologist
[17] Amanda Stratton, email message to author, August 17, 2026.
[18] Jeffrey H. Altschul and Keith W. Kintigh, “American Archaeology at a Crossroads, “SAA Archaeological Record, November 2025, https://anthroctr.org/wp-content/uploads/2026/02/Altschul-Kintigh-2025.pdf
[19] ACHP, “Section 106 Archaeology Guidance.”
[20] Lynne Sebastian, “The Future of CRM Archaeology,” in Archaeology & Cultural Resource Management: Visions for the Future, eds. Lynne Sebastian and William D. Lipe, (University of New Mexico Press)
[21] Jeffrey H. Altschul and Terry H. Klein, “Forecast for the US CRM Industry and Job Market, 2022–2031, “ Advances in Archaeological Practice 10, no. 4. (2022): 355-370, https://doi.org/10.1017/aap.2022.18.
[22] Jeffrey H Altschul and Thomas C. Patterson, “Trends in Employment and Training in American Archaeology,” in Voices in American Archaeology, eds. Wendy Ashmore, Dorothy T. Lippert, Barbara J. Mills (University of Colorado Press, 2010), 291-316.
[23] Place Economics, Status of Historic Trades in America (PlaceEconomics for The Campaign for Historic Trades, 2022), https://historictrades.org/wp-content/uploads/2022/11/Campaign-for-Historic-Trades-10.31.2022.pdf.
[24] “American Cultural Resources Association Salary Survey, Midwest Western Region Report,” Vernon Research Group, published July 31, 2023, https://acra-crm.org/wp-content/uploads/2023/08/ACRA-2023-Midwest-Western-Report.pdf.
