Frequently Asked Questions

Find quick answers to common questions about Cultural Resource Management below.

  • A cultural resource is any physical evidence of human activity that is 45 or more years old. This generally can include historic-period or prehistoric archaeological sites, or historic-period architectural or structural resources. For a deeper dive, please see our Resources Section.

  • A cultural resources assessment or inventory is a study performed by a qualified cultural resources professional (usually a consultant) to determine if cultural resources are present within a subject property or project site. Cultural resource tasks usually include:

    • research, 

    • fieldwork, 

    • consultation with local interest groups and Native American Tribes, 

    • and a report to present findings to the lead agency that is permitting your project. The agency makes a final determination based on review of the report. 

    If no cultural resources are present, your cultural resource responsibilities are concluded (unless something important that was not observed on the surface turns up during construction excavation). If cultural resources are present, they will require a significance evaluation to determine if the undertaking or project has potential to result in a significant adverse effect, which could represent a development constraint. Often we can complete a simple evaluation during the inventory; sometimes they require a separate study. Significance evaluations are addressed further, below. And for a full discussion of the requirements, please look at our Resources Section, or contact us with a specific scenario. 

  • When a permitting government agency requires it and when an exemption does not apply. Please see the question below to see when exemptions apply. Our Resources Section will explain exemptions in greater detail. Please contact us for a proposal or with any questions.

  • A negative or minimal findings cultural resources assessment usually takes about 4-6 weeks. If a cultural resource requiring evaluation is present, it may take longer. Please contact us to discuss things that could protract the process.

  • Every situation is different, but costs for a negative cultural resources assessment on a small parcel (20 acres or less) are rarely prohibitive. Please contact us for a proposal. We'll need the project location or a map, and the name of the lead agency, if available. 

  • A significance evaluation involves research, fieldwork, analysis, and writing to determine if a cultural resource identified during an assessment/inventory is eligible for any of the four National Register of Historic Places or California Register of Historical Resources listing criteria. A finding of no significance usually concludes your cultural resource responsibilities, although monitoring may still be necessary during construction. A finding of significance during evaluation would trigger a need to either avoid/preserve the significant resource, or a need to mitigate. For a complete explanation on how this study is carried out and to find out how mitigation works, please visit our Resources Section. Please contact us if you need an evaluation proposal or if you have questions. 

  • Cultural resource/archaeological/tribal monitoring is sometimes required during construction excavation. These types of monitoring will occur when there is sensitivity for significant buried cultural resources after an assessment and (if necessary) evaluations are complete.  Monitoring will take place if the cultural resources assessment report or the Native American Consultation recommend it and if the lead agency adopts monitoring as a condition of approval or as a mitigation. Please contact BCR Consulting for a monitoring proposal or if you have questions. 

  • Native American Consultation is meaningful government to government communication between a Tribe and Permitting Government Agency meant to determine potential for an action to result in adverse effects to important Tribal Cultural resources. Tribal Scoping is informal communication, usually between a property owner or consultant and a Tribe to find out if there are important Native American resources within a specific property. To understand the nuances, please see our Resources Section or contact us for a proposal or with questions. 

  • Many agencies allow a five-year shelf life for negative findings reports, as a general rule. This time period is not set in stone; updates are necessary due to changing conditions that can reveal, obscure, or destroy cultural resources. Since environmental conditions vary by region and resource durability varies by material and other factors, five years may be too long or too short. But when an assessment/inventory identifies resources, an update would be recommended for reports over two years old for projects being completed pursuant to Section 106 (federal rules), and five years old for projects being completed pursuant to CEQA (state and local rules). Here is the justification (including the Federal and CEQA angles):

    Based on Section 106 (federal) guidelines as interpreted by the California Office of Historic Preservation, “resources identified in field inventories that are more than two years old should be re-examined to determine site integrity and project effects” learn more. CEQA requires that “if the survey is five or more years old at the time of its nomination for inclusion in the California Register, the survey is updated to identify historical resources that have become eligible or ineligible due to changed circumstances…” (Public Resources Code §5024.1; learn more. This wording suggests that it is required to update surveys that have resources. However, the five-year threshold should also apply to properties with buildings that have turned 45 years old (i.e. become historic in age) since the previous study. Please contact us if you have a specific scenario you would like to discuss. 

  • A desktop study/review (cultural resources records search and letter report with no field survey) can be a good way to perform due diligence to determine potential for cultural resource issues on your property. The records search will tell you if there are previously recorded resources on your property. It will also tell you if the property has already been assessed for cultural resources, and if the previous study is recent enough you may not need to do any additional cultural resources work. It's also possible that aerial research will show that the project was completely paved over after the historic era (less than 45 years ago). In that case, a records search could tell you whether or not there is potential for buried resources, but a field survey in a property with no visible sediment might be pointless and therefore unnecessary. Please contact us if you have a specific scenario you would like to discuss. 

  • The prehistoric era includes human activity before writing systems existed. It ends in a given region when writing is developed there and events become recorded. Information about cultural resources dating to the prehistoric era is derived from analysis of the material culture (physical objects, resources, and spaces that humans use), the study of customs of different cultures (i.e., ethnoarchaeology), and the study of early historic accounts of native cultures (i.e., ethnohistory). 

    The historic era begins in a given region when writing systems are developed there and events are recorded. Information about cultural resources from the historic era have the benefit of documents, manuscripts, and inscriptions that can help with analysis, but also may be subject to bias or inaccuracy. Pre-contact refers to the era before one culture came in contact with another. It often refers to groups before European contact. "Pre-contact" is sometimes used to replace "prehistoric" because of pejorative connotations and because it is often unclear if an indigenous group had made contact with a colonial group (or were otherwise effected by their presence nearby) prior to or after the earliest written accounts documenting said people. This replacement is not always appropriate because many pre-contact societies had writing systems before European contact. 

  • Potentially exempt projects are those that are consistent with either the development density established by existing zoning or a community plan, or with an existing general plan, for which an environmental impact report (EIR) was previously certified, with some exceptions. This is explored in greater detail in our Resources Section. and we can help if you have questions. 

  • BCR Consulting can complete work on publicly and privately funded projects pursuant to the California Environmental Quality Act (CEQA), Section 106 of the National Historic Preservation Act (NHPA), and the National Environmental Policy Act (NEPA).Key sectors serviced by BCR Consulting include:

    • Urban development and redevelopment, including city planning, housing, and urban renewal projects.

    • Private development, including commercial and residential construction.

    • Energy, including electrical transmission and distribution corridors, hydroelectric projects, solar projects, carbon capture, oil and gas.

    • Transportation, including highway and railroad construction, high speed rail,airport expansions, public transit projects, servicing such agencies as Federal Highways, California Department of Transportation (Caltrans), and Nevada Department of Transportation (NDOT).

    • Mining and resource extraction, including metal, mineral,and quarry mining, and reclamation projects.

    • Government and military,servicing federal(including the U.S. Department of Defense), state, and local agencies.

    • Land and water management, servicingsuch government agencies as Bureau of Land Management(BLM), U.S. Department of Agriculture (USDA-including U.S. Forest Service and others), National Parks, National Recreation Areas, California State Water Resources Control Board, the Environmental Protection Agency (EPA), and the California Department of Parks and Recreation.

    • Interdisciplinary projects, requiring collaboration among outside experts in our own fields (archaeologists, historians, architectural historians, GIS specialists and paleontologists) and those from outside fields (planners, engineers, environmentalscientists, biologists, geologists, and Native American representatives.

  • BCR Consulting was established by Principal David Brunzell in 2008 in a basement in Laverne, California. The economy was slow at that time and we struggled at first, but in 2009 we were awarded our first big project, a nearly 8,000-acre survey in the California City/Mojave area of Kern County. Cal City is too far to commute from Laverne, so Mr. Brunzell (with much-needed guidance and assistance from Mrs.Julia Zuker-Brunzell) and family moved to a field house with field staff to the picturesque and windy mountain community of Tehachapi. After a successful project and seven adventurous months there, BCR relocated to Julia’s hometown of Claremont, California and started marketing. We became a Limited Liability Company operating as an S Corporation in 2012 and have since grown steadily.

    BCR Consulting Principal David Brunzell has had a career in cultural resources since 1998, but his field school and first job in cultural resources were in 1994. Fun fact: our original name was “The Brunz Age” (coined by the great R. Chuck Ferguson) and we did a single job in Big Bear under that name in 2002. Lacking management experience, Mr. Brunzell took work at various companies to learn the ropes before embarking on this current adventure.