Certification of Cultural Resources Personnel to Operate Under our Protocol Agreement with the California State Historic Preservation Officer
August 28, 2008
In Reply Refer To:
8100 (CA930)P
EMS Transmission: 8/28/08
Instruction Memorandum No. CA-2008-024
Expires: 9/30/2009
To: All Field Managers
All Field Office Archaeologists
From: State Director
Subject: Certification of Cultural Resources Personnel to Operate Under our Protocol
Agreement with the California State Historic Preservation Officer
Over the last several years, the issue of California BLM requiring our Cultural Resources personnel to have an advanced degree (Master’s) to work under our Protocol Agreement has been questioned by other BLM State Archaeologists, cultural resources employees within and outside our State, and from other agencies. We are the only BLM State that has this requirement. It was identified in our 1998 Protocol Agreement that our personnel would meet the Secretary of the Interior’s Professional Qualifications Standards that requires an advanced degree in archaeology. Office of Personnel Management cannot require this positive education requirement in advertising for our Cultural Resources/Archaeology positions.
Our existing Protocol is more reflective of other agencies and BLM nationally in applying professional standards for working under our Protocol and the National Programmatic Agreement (nPA). Our current 2007 Protocol states:
“….BLM is committed to employing a professional staff. In hiring new full time
professional staff, BLM will follow Section 112(a)(1)(B) of the NHPA and select
candidates that meet the Secretary of the Interior’s Professional Qualification Standards
or the education and experience standards set forth in the BLM Manual Series
8150.12.B.2.”
This means that professional standards for operating under the Protocol require a graduate degree or “formal education resulting in a bachelor’s degree in the appropriate discipline….plus at least 24 months of professional supervised experience including similar duties as proposed….”
Discussions with our Associate State Director, Deputy State Director for Resources, Personnel, and staff of the State Historic Preservation Officer were undertaken to determine how BLM will maintain a professional staff for operating under our Protocol Agreement, nPA, and the BLM 8100 Series Manual.
To be Certified to operate under our Protocol, an individual must:
- Meet the Secretary of the Interior’s Professional Qualification Standards or the education and experience standards set forth in the BLM Manual Series 8150.12.B.2.
- Be employed at a journey level position, GS-11 or 12.
- Receive Protocol training by the State Office.
- Be formally Certified by the State Director after review of qualifications of the individual.
BLM’s SCEP program in archaeology will be continued at the graduate level in order to better meet the Secretary of the Interior’s Standards. SCEP’s, as identified in our 2007 Protocol , will not operate under the Protocol without appropriate oversight of qualified professional cultural resources staff.
In the hiring of cultural resources personnel below the GS-193-11 journey level or under an intern, term, or temporary appointment, resumes shall be sent to the State Office for consideration of Provisional Certification to operate under the Protocol. The State Director must certify that individuals in these positions, especially at the GS-9 grade level and below, meet all professional standards. If professional standards and qualifications are met, these individuals can receive up to 2 year’s Provisional Certification from the State Director to operate under the Protocol.
Attached is a list of all personnel that are presently Certified to operate under our California Protocol.
If you have any questions, please contact Ken Wilson, State Archaeologist and Tribal Liaison at (916) 978-4648.
Signed by:
James Wesley Abbott
Associate State Director
Authenticated by:
Richard A. Erickson
Records Management
Attachment – California Certified Protocol Personnel (1 p)