Message #288:
From: AzTeC SW Archaeology SIG
To:   "'Matthias Giessler'" 
Subject: BLM Draft Colorado Protocol For Your Review
Date: Wed, 30 Jul


From: Brian W. Kenny

PLEASE NOTE: This message is available as a PDF file (60k) for printing 
a formatted version of the Draft.

[ Note to Jim Rhett -- You are correct that "we should not miss an
opportunity to improve the way we do business."  That is the rationale
and reason for the debate and commentary on the BLM PA.  Thus, whether by
phone, in person, by letter or by internet e-mail message, your bromides
"Chill, people!"  and "Change is always tough"seem entirely condescending
to professional colleagues who have an obligation to debate the merits of
the new BLM process.  At some point the BLM closes the "official" comment
period.  That's as it should be -- but -- professionally colleagues STILL
have the obligation to make their opinions about the PA known.  If the PA
remains controversial in the future, these professionals STILL have the
right to debate the PA and support and defend it, or, actively work to
have it voided.  Respectfully, this right and obligation exists
regardless of the current course or the completness of official
bureaucratic process -- it is called democracy in action and has
something to do with the First Amendment.  Furthermore, your colleagues
are not only colleagues, they are taxpayers.  You work for them.  If they
want more debate, even outside the official bureaucratic process, it is
their perrogative.   Might we venture that your concern should not be
with slowing the mill turning even a little...--  SASIG Ed. ]



From:  Jim Rhett


Fellow BLMer suggested I send you this note I circulated earlier today.

Date:  07/30/1997  10:25 am  (Wednesday) =20
From:  Jim Rhett
Subject:  Where's everyone been?


I'm sure WO will see all this sooner or later and provide better answers,
but let me try to slow the mill turning a little!  The National
Programmatic Agreement signed in March did go through a public review
comment process, with comments responded to, etc.  Neither the NPA, nor
the state Protocols (yet to be written in most states;

Colorado has a draft) would change any NEPA requirement or NEPA public
process.  The state Protocol is an administrative agreement between the
SHPO and BLM State Office (which will go out for public comment) under
the guidance of the National Agreement which will tell both agencies and
the public what the procedures are for 106 compliance.


Chill, people!


Date: Wed, 30 Jul 1997 13:54:40 -0600
From: Jim Rhett <
Subject:  Colorado DRAFT Protocol


In light of some of the stuff going around, I thought I'd attach our
draft Colorado Protocol for your review and comment.  (Much thanks to
Monica Weimer for the typing/editing, as well as contributions; and to
Susan Collins and her staff for their hard, if skeptical, work on a
document that (the BLM feels) will streamline our efforts
and give us, both more opportunity to shift our thin dollars from
bureaucracy to management and preservation.

Change is always tough (take that from an old boy new to the program),
but, we should not miss an opportunity to improve the way we do business.
There is still time to help drive the train.

Comments and questions may be sent to the Colorado SHPO, Rich Fike, or
myself.  Thanks!

Revised draft:  7/24/97

	
STATE PROTOCOL AGREEMENT BETWEEN
THE COLORADO STATE DIRECTOR OF THE BUREAU OF LAND MANAGEMENT AND THE
COLORADO STATE HISTORIC PRESERVATION OFFICER (SHPO)
REGARDING THE MANNER IN WHICH THE BUREAU OF LAND MANAGEMENT (BLM) WILL
MEET ITS RESPONSIBILITIES UNDER THE NATIONAL HISTORIC PRESERVATION ACT
(NHPA) AND THE NATIONAL PROGRAMMATIC AGREEMENT (NPA) AMONG THE BLM, THE
ADVISORY COUNCIL ON HISTORIC PRESERVATION (COUNCIL), AND THE NATIONAL
CONFERENCE OF STATE HISTORIC PRESERVATION OFFICERS (NCSHPO) 

This Protocol Agreement (Protocol) supplements the above-referenced NPA,
and pertains to Sections 106, 110(f) and 111(a) of the NHPA.  It
describes specific procedures regarding how the Colorado SHPO and the
BLM will interact and cooperate under the NPA. The goals of this
Protocol and the NPA are to enhance planning for and management of
historic properties under the BLM's jurisdiction or control and to
ensure appropriate consideration of historic properties outside BLM's
jurisdiction, but which may be affected by its actions.  Undertakings
involving non-federal lands for which BLM is considered the lead agent
shall be considered federal actions and will be subject to requirements
outlined in this Protocol. The following are the terms and conditions of
the Protocol.

I.  RELATIONSHIP OF THIS PROTOCOL AGREEMENT TO OTHER AGREEMENTS

Relevant sections of the 1987 Colorado "Programmatic Agreement Among
U.S. Department of the Interior, Bureau of Land Management, Colorado,
and Advisory Council on Historic Preservation" (CPA) have been
incorporated into this Protocol.  As a result, the CPA is terminated. 
If any BLM office in Colorado fails to follow the process set forth in
this Protocol, it will comply with procedures at 36 CFR 800 regarding
individual undertakings.  Those procedures will remain in effect until
such time as a resolution is reached following procedures detailed in
Section IX (A), at which time this Protocol will again be in force.


SHPO and BLM agree that (1) BLM conducts continuing programs and carries
out specific undertakings that involve land disturbance and modification
of the built and natural environments, and; (2) BLM bears legal
responsibility for carrying out such undertakings consistent with the
National Historic Preservation Act (NHPA) and the National Environmental
Policy Act (NEPA), and that; (3) BLM's undertakings, including actions
assisted, licensed, permitted, approved, funded, or authorized by BLM,
being "undertakings" as defined in the Code of Federal Regulations [36
CFR 800.2(o)], are numerous, complex and far-reaching in their effects
on lands and properties in Colorado.  The following procedures will be
implemented by the BLM under this Protocol to fulfill its
responsibilities mandated by the above-mentioned laws and regulations.

II.  ADMINISTRATIVE INTERACTION AND REPORTING PROCEDURES

BLM will send project logs (Attachment A) to the SHPO at the time BLM
prepares its annual report to Congress, usually in November or December.
 BLM will also prepare a summary report that describes the implemented
actions taken in the previous fiscal year and actions that are
anticipated in the coming fiscal year. This report will be due to the
SHPO by June 30th of each year, and will include information as outlined
in Attachment B.  By July 30th of each year, the SHPO will prepare a
report that assesses the overall effectiveness of BLM's implementation
of this Protocol and makes recommendations for actions to be taken by
BLM.  The BLM will consider SHPO's assessments and recommendations for
future actions and will apply them to the plan for the following fiscal
year, as appropriate.  If SHPO is not satisfied with BLM's response,
dispute resolution procedures [Section IX (A), below] may be followed.  
All annual reports will be distributed to the BLM and SHPO.

The SHPO, the BLM State Director, BLM's Deputy Preservation Officer for
Colorado, and the BLM Colorado Cultural Resources Matrix Team will meet
annually in August, or more often as needed, to discuss pertinent
issues.  The Council will be invited to participate.  At the August
meeting, the SHPO and BLM will exchange information relevant to the
goals and objectives set forth in this Protocol.  Other meetings to
address emerging issues and their effects on historic properties may be
arranged as necessary.

III.  BLM AND SHPO INVOLVEMENT IN THE BLM STATE MANAGEMENT PROCESSES

BLM shall provide the SHPO the opportunity to participate at the
development stage and all subsequent phases of land use planning in
accordance with 43 CFR 1610.3 (Coordination with Other Federal Agencies,
State and Local Governments, and Indian Tribes).  BLM will provide the
SHPO with all land management plans (e.g., Resource Management Plans,
Cultural Resource Management Plans), special use plans (e.g., Fire
Management Plans) and appropriate NEPA documents.

IV.  COOPERATIVE PROGRAM DEVELOPMENT AND ACTIVITIES

A.  Data Sharing and Information Management 


1.  Reporting.   BLM will document all fieldwork.  BLM will submit to
the SHPO copies of all reports for historic property inventories and
site forms as soon as possible after completion of the work, but not
later than three months following completion of the fieldwork.  If a
final report will not arrive at the SHPO's office within the three month
deadline, the BLM will notify the SHPO in writing, and will include in
the correspondence the expected date of submission.

BLM will review the work of permitted contractors and will ensure that
Colorado State Report Guidelines and the Secretary of the Interior's
Standards and Guidelines (Secretary's Standards) are met in all
documentation.

All "backlog" documentation that exists in BLM files and which predates
the signing of this protocol may be submitted to the SHPO within twelve
months of the implementation of this protocol.  Elimination of the
backlog documentation is a condition of continuing field office
certification.

2.  Data exchange. The SHPO and BLM shall exchange information on a 
constant basis regarding the location and evaluation of historic
properties.  Each agency will assure that such locational information is
protected from unauthorized use.  The primary means of information
exchange will be through the development of an automated database,
managed by the SHPO.  BLM will assist the SHPO in developing the system
by providing financial, personnel, hardware and software resources, as
funding becomes available.

The SHPO will provide the BLM with automated cultural resources
information and with reasonable amounts of hard copy information not yet
available in the database, as requested by the BLM.  Charges may be
assessed and are subject to negotiation at the annual August meeting.   
 
   
3. Maintenance of files.  BLM and SHPO will support and maintain a
fully-compatible and up-to-date database.  The BLM and SHPO will
incorporate the results of project-specific surveys into the database as
the results are produced, and will review the database and the
organization of the data to update existing statewide historic contexts.
 The review and analysis will be performed by BLM and SHPO annually, in
time for the yearly meeting.

B. State-Level Historic Preservation Training 

The SHPO will assist the BLM in on-going training of field managers and
supervisors, as well as of cultural resources staff, on the NPA and
implementation of the Protocol.  Training resources might include, but
are not limited to:  the BLM "Handbook For Cultural Resource Inventory,
Evaluation and Mitigation" (Handbook, Attachment C), planning documents,
and statewide historic context documents.  Review of training needs will
occur on a yearly basis and will be conducted by the SHPO and BLM, in
time for discussion at the annual meeting.

 	C.  Public Outreach and Participation 

BLM will develop planning documents in support of public education and
community outreach, along with cooperative stewardship and site
protection, in consultation with SHPO.  BLM will strive to develop at
least one of these plans each year until completion. 

BLM will seek and consider the views of the public when carrying out the
actions under the terms of this Protocol.  BLM may coordinate this
public participation requirement and those of the NEPA and the Federal
Land Policy and Management Act of 1976 (FLPMA), along with other
pertinent statutes.  Interested parties shall be invited to consult in
the review process [Section VII (B) below] if they have interests in a
BLM undertaking or action on historic properties.  Such interested
parties may include, but are not limited to, local governments;
grantees, permittees, or owners of affected lands or land surfaces;
Indian Tribes; and other interested parties, as determined by the BLM
and SHPO.

V.  NATIVE AMERICAN PARTICIPATION

BLM will comply with the NHPA, American Indian Religious Freedom Act
(AIRFA), and the Native American Graves Protection Act (NAGPRA) if a
property is subject to those laws.  BLM will seek and consider the views
of an Indian tribe that is able to demonstrate a cultural affiliation
with Colorado historic properties.

VI. IDENTIFICATION AND EVALUATION OF HISTORIC PROPERTIES

A.  Identification

BLM will identify all historic properties and sacred sites on
BLM-administered lands and private lands where a BLM undertaking will
occur within Colorado.  BLM will ensure that project-specific surveys
and other efforts to identify historic properties are conducted in
accordance with appropriate professional standards, as defined in the
Secretary's Standards and the Handbook.

B.  Evaluation

During all inventories, BLM will ensure that historic properties
identified are evaluated in a manner consistent with the Secretary's
Standards, 36 CFR Part 60.4 and the Colorado State historic Contexts.

VII. REVIEW PARAMETERS 


Most of BLM's undertakings are routine in nature, and will normally be
permitted to proceed and will not await submission of appropriate
documentation to SHPO.  For other undertakings, as described in Section
VII (A), below, BLM will consult with SHPO prior to implementation of
the action.  BLM will discuss the issue with SHPO in cases where there
is any uncertainty. 	

A.  Review Thresholds

At a minimum, the BLM will request the review of the SHPO in the
following situations:

(1) non-routine interstate and/or interagency projects or programs;
(2) undertakings directly and adversely affecting National Register
eligible properties;
(3) undertakings that are determined by BLM, the SHPO or the Council to
be highly controversial (e.g., undertakings that receive unusual public
attention and/or involve conflict),
(4) land exchanges, land sales, Recreation and Public Purpose leases,
and transfers,
(5) when BLM professional staff possess limited regional experience,
until performance is mutually acceptable to BLM and SHPO.

When the above review thresholds are met, the following process will be
undertaken.  After the inventory, BLM will submit the appropriate
documentation [inventory report, site forms, photographs, plans for
treatment or preparation of a Memorandum of Agreement (MOA)] to the
SHPO.  Along with the documentation, BLM will send one copy of the
concurrence cover letter in Attachment D to the SHPO.  The SHPO will
have ten working days to review the documentation.  If SHPO concurs with
BLM, the SHPO will sign and return the concurrence letter to the BLM. 

B.  Review Process

BLM will make determinations of eligibility according to 36 CFR Part
60.4 and effects according to criteria set forth in 36 CFR 800.9.  BLM
will confer with SHPO whenever questions about eligibility and/or effect
arise.  

BLM will provide documentation in the form of complete and accurate
Colorado OAHP site and isolated find forms, Limited Results Survey
Reports, or full-length inventory reports, as appropriate, to the SHPO,
on all projects and undertakings.  An informational letter (Attachment
D, informational) will accompany this documentation.  The SHPO may
comment on BLM's findings.  The BLM will consider the SHPO's comments.


Inventory will be documented following the Secretary's Standards, the
guidelines in the SHPO's "Cultural Resource Report Forms and Guidelines"
(Attachment E), and BLM's Handbook (Attachment C).  Prompt transmission
of this documentation will assure an updated database and will occur no
later than three months after completion of  fieldwork as described in
Part IV (A) (1) above.

If a historic property will be adversely affected, BLM will determine
whether an MOA or a Treatment Plan is appropriate, and will document
this in the concurrence letter (Attachment D, concurrence).  When an
adverse effect cannot be avoided through project redesign, BLM will
prepare and implement an MOA or Treatment Plan for each property, group
of properties, or class of properties that have been determined eligible
for inclusion in the NRHP.  The Treatment Plan or MOA will take into
account the national policies set forth in Section 2 of the NHPA, as
amended, the Secretary's Standards, along with the Council's "Treatment
of Archaeological Properties: A Handbook" and "Preparing Agreement
Documents".  BLM and SHPO will jointly prepare MOAs.   BLM will afford
the SHPO 10 working days in which to comment upon Treatment Plans. If
the SHPO and the BLM cannot reach agreement, dispute resolution
procedures will be followed [Part IX (A)].

C.  Auditing

Within six months after signing of this protocol, BLM and SHPO will meet
to review the implementation of this protocol.

BLM will conduct annual audits of each field office (Attachment F) to
determine:

(1) whether a qualified professional cultural resources staff is
present;
(2) whether undertakings are receiving cultural resource consideration;
(3) whether project documentation is completed and is being sent to SHPO
in a timely manner;
(4) whether cultural resources staff are making accurate professional
judgements;
(5) whether cultural resource identification, evaluation and treatment
has occurred before undertakings proceed;
(6) whether final reports of treatment are being completed and sent to
the SHPO;
(7) whether follow up monitoring, where necessary, is being completed.

D.  Discoveries

In the event that potentially eligible historic properties are
discovered during the course of ground disturbance and cannot be
avoided, work in the immediate vicinity of the discovery will cease. 
BLM will evaluate the site and, in consultation with the SHPO, select
the appropriate mitigation option.  The BLM will implement the
mitigation in a timely manner.  The process will be fully documented (in
reports, site forms and photographs), and the documentation will be
forwarded to the SHPO.  Large-scale projects will include a discovery
process in the treatment plan.

VIII.  STAFFING

A.  BLM will strive to hire professional staff that meet the Secretary's
Standards.

B.  State Certification

BLM-Colorado will ensure that expertise in prehistoric archaeology,
historic archaeology, industrial archaeology, historic architecture,
Native American coordination, public outreach/heritage education and
Traditional Cultural Properties (identification, evaluation and
treatment) is available to all BLM-Colorado staff.  If BLM determines
that it does not employ a staff member with a particular skill, it will
obtain that expertise for the purpose of determining National Register
eligibility, effects, and treatment for the cultural resources in
question.  The BLM may request the assistance of SHPO staff in such
cases or may obtain the necessary expertise through contracts, BLM
personnel from other states, or cooperative arrangements with other
agencies.  When personnel changes occur, e.g., staff specialists or
managers leave, a 90-day grace period will be allowed for filling
positions and training new personnel before field office certification
will be at risk. During the grace period, BLM will ensure that qualified
personnel are available to conduct the tasks outlined in this protocol.

IX. DISPUTE RESOLUTION PROCEDURES, AMENDMENTS, AND TERMINATION 

A.  Dispute Resolution Procedures

Should the BLM or the SHPO object, in writing, within 30 days, to an
action taken by the other party to this Protocol, they will consult to
resolve the objection.  If the dispute cannot be resolved, BLM and SHPO
will mutually determine a course of action.  Options might include
consultation with the National Preservation Board, the Council or
alternative dispute resolution procedures.  If alternative arrangements
are not mutually agreeable, the dispute will be referred to the Council.

B.  Amendments to the Protocol

The BLM or the SHPO may request amendment of this Protocol at any time,
whereupon the parties will consult to consider such amendment. 
Amendments will become effective upon signature of both parties and will
be attached hereto.

C.  Termination of the Protocol


The BLM or the SHPO may terminate this Protocol by providing ninety (90)
days written notice to the other party, providing that the parties
consult during this period to seek agreement on amendments or other
actions that would avoid termination.  Either may request the assistance
of State Director, the Preservation Board, and/or the Council.  In the
event of termination, the BLM will operate under the provisions of 36
CFR Part 800 as described in Section I.

X.  OTHER STATE-SPECIFIC PROCEDURES

BLM will follow procedures and adhere to policies detailed in BLM
Colorado Manual Guidance: the "Handbook for Cultural Resources
Inventory, Evaluation and Mitigation" (Handbook) and other supplemental
manual guidance, along with Colorado State forms and report standards. 
BLM and SHPO will jointly develop and revise handbooks and other
guidance as necessary.

XI.  ATTACHMENTS

Attachments may be added to this Protocol with the mutual approval of
the SHPO and the BLM.  Referenced attachments are:

A.  Example Project Log Page
B.  Outline of Topics Covered in Colorado BLM/SHPO Annual Report
C.  Handbook for Cultural Resources Inventory, Evaluation and Mitigation

D.  Cover Letters
E.  SHPO Cultural Resource Report Forms and Guidelines
F.	Auditing Form

BUREAU OF LAND MANAGEMENT




By	Date

COLORADO STATE HISTORIC PRESERVATION OFFICER




By	Date


	ATTACHMENT A: EXAMPLE PROJECT LOG PAGE

(NOTE: THE INFORMATION BELOW IS FICTITIOUS AND ONLY FOR EXAMPLE
PURPOSES)



NUMBER

WORK DONE BY

PROJECT NAME

LEGAL DESCRIPTION/QUAD

BLM ACRES

NON-BLM ACRES

SITES/IFS



SITES AVOI-DED

SITES MITI-GATED








IF*

NE*

E*




CR-050-RG-97-1 (N)

BLM

First Trail ROW

T11S R77W S. 4, 9

3.67

0












CR-050-RG-97-2 (P)

Metcalf

AT&I Communications Buried Cable

T17S R70W S. 17

2.8

5.9



5FN111-115

5FN116

1

0


CR-050-RG-97-3 (P)

BLM

Structure Removal

T49N R9E S.  14

.001

0



5CF335








CR-050-RG-97-4 (N)

Brechtel

MW Operating Company Well and Access

T1N R72W S.  24



8.34












ATTACHMENT B:  OUTLINE OF TOPICS TO BE COVERED IN THE COLORADO BLM/SHPO
ANNUAL REPORT


BLM-implemented actions taken in the previous fiscal year and actions
that are anticipated in the coming fiscal year

Review of the goals and objectives set forth in this Protocol

Emerging issues and their effects on historic properties

Results of the BLM and SHPO reviews of the database and the organization
of the data to update existing statewide historic contexts

Results of BLM and SHPO reviews of training needs

Progress on public participation and outreach plans

Results of field office audits

Statistics BLM sends to Congress (mutually agreed upon by BLM and SHPO)


ATTACHMENT C: HANDBOOK FOR CULTURAL RESOURCES INVENTORY, EVALUATION AND
MITIGATION


(This is Colorado BLM Manual Supplemental Guidance and is still under
review)

	ATTACHMENT D: COVER LETTERS

	INFORMATIONAL

	      United States Department of the Interior
	BUREAU OF LAND MANAGEMENT
	* RESOURCE AREA
	ADDRESS
	8100
	CO-0**

DATE


Dr. Susan Collins, Deputy State Historic Preservation Officer
Colorado Historical Society
1300 Broadway
Denver, CO  80203

Dear Dr. Collins:

PART I.  Project Description	County: 
Project Number:                     

The following undertaking is located in T* R*, Section * in * County. 
Project Name: *.  This undertaking involves *. 
Because this undertaking does not exceed any of the review thresholds
listed in Part VII (A) of the Protocol, this letter is for informational
purposes only.

PART II.  Determination of Eligibility to the National Register of
Historic Places.

BLM has made the following determinations of eligibility and effect:


DETERMINATION OF ELIGIBILITY





DETERMINATION OF EFFECT ON HISTORIC PROPERTIES



SITE NUMBER

NOT ELIGIBLE

NEED DATA

ELIGIBLE

ELIGIBILITY CRITERIA

NO EFFECT

NO ADVERSE EFFECT

































A narrative discussing not eligible, need data, and eligible cultural
resources is attached.


BUREAU OF LAND MANAGEMENT, * RESOURCE AREA



BY	DATE


CONCURRENCE
	      United States Department of the Interior
	BUREAU OF LAND MANAGEMENT
	* RESOURCE AREA
	ADDRESS
	8100
	CO-0**

DATE


Dr. Susan Collins, Deputy State Historic Preservation Officer
Colorado Historical Society
1300 Broadway
Denver, CO  80203

Dear Dr. Collins:

PART I.  Project Description	County: 
Project Number:                     

The following undertaking is located in T* R*, Section * in * County. 
Project Name: *.  This undertaking involves *. 
This undertaking:




(1)   is a non-routine interstate and/or interagency project or program




(2)   directly and adversely affects a National Register eligible
property




(3)   has been determined by BLM, the SHPO or the Council to be highly
controversial




(4)   is one of the following:  a land exchange, land sale, Recreation
and Public Purpose lease, or transfer




(5)   has been analyzed by a BLM staff person with limited experience 




PART II.  Determination of Eligibility to the National Register of
Historic Places.

BLM requests your concurrence on the following determinations of
eligibility and effect:


DETERMINATION OF ELIGIBILITY





DETERMINATION OF EFFECT ON HISTORIC PROPERTIES




SITE NUMBER

NOT ELIGIBLE

NEED DATA

ELIGIBLE

ELIGIBILITY CRITERIA

NO EFFECT

NO ADVERSE EFFECT

ADVERSE EFFECT





































A narrative discussing not eligible, need data, and eligible cultural
resources, along with a draft ___ treatment plan/___MOA is attached.
Please review the enclosed documentation, then sign and return this
letter with your comments within ten working days.


BUREAU OF LAND MANAGEMENT, * RESOURCE AREA





BY	DATE





COLORADO STATE HISTORIC PRESERVATION OFFICER

____ Concur	____ Do Not Concur   




BY	DATE


COMMENTS:

























Enclosures
1. 	Site forms and statement of site significance/or reason for
site noneligibility.
2.	Cultural Resources Inventory Report
3.	Draft Treatment Plan or MOA

ATTACHMENT E: SHPO CULTURAL RESOURCE REPORT FORMS AND GUIDELINES


ATTACHMENT F: AUDITING FORM

	BUREAU OF LAND MANAGEMENT
	CULTURAL RESOURCES PROGRAM CERTIFICATION AUDITING FORM


FIELD OFFICE:  	* Field Office

AUDITOR(S):	Jim Rhett, Rich Fike

DATE:	

FISCAL YEAR:	


CRITERION

RATING1

COMMENTS


Is a qualified professional cultural resources staff present?






Are undertakings receiving cultural resource consideration?






Is project documentation completed and being sent to SHPO in a timely
manner?






Are cultural resources staff making accurate professional judgements?






Have cultural resource identification, evaluation and treatment occurred
before undertakings proceed?






Are final reports of treatment being completed and sent to the SHPO?






Is follow-up monitoring, where necessary, being completed?






Attach documentation as necessary.  Attachments might include cultural
resource log pages, NEPA registers, SHPO concurrence documents, and
monitoring reports.
1Rating scale is 1-10, with 10 being the highest possible rating.  Any
ratings under 5 could result in field office certification review.

9



10
* IF = Isolated Find; NE = Not eligible; E = Eligible


12