In an effort to better conform to the federal regulations in 36 CFR Part 800.11, the State Historic Preservation Office (SHPO) will be making changes to the procedures for Section 106 consultation. Beginning July 1, 2020, applications for Section 106 consultation will only be accepted if the review of historic properties, both archaeological and architectural, has been completed by individuals meeting the applicable federal qualifications outlined in 36 CFR Part 61. The following information was also provided by SHPO:

Applications submitted on or after July 1, 2020 must include identification efforts as outlined under 36 CRF 800.4 completed by individuals meeting the applicable federal qualification(s). If an applicant fails to meet this standard, the application for consultation will be returned without comment for resubmittal with adequate documentation of identification efforts.

In addition to these changes, the Michigan SHPO is in the process of developing new Section 106 consultation forms that will be rolled out beginning July 1, 2020. There will be an adjustment period when the old forms will continue to be accepted through the end of 2020. Beginning on January 1, 2021 submissions on the old forms will be returned without comment for resubmission on the correct form. The Michigan SHPO will be rolling out educational initiatives to assist applicants with these changes.

This change will require firms with only Architectural Historians/Historians to partner with an Archaeologist for ground-disturbing projects and for Archaeologists to partner with Architectural Historians/Historians for projects potentially impacting architectural resources. Identification must be done by individuals meeting the applicable qualifications depending on the specific project.

ASTI is currently in the process of connecting with archaeological firms across the state to develop a working partnership.

36 CFR Part 800.11

36 CFR Part 61