Statement_of_Work_IDIQ_2015.pdf

PERFORMANCE WORK STATEMENT FOR THE

PERFORMANCE OF PHASE 1A/B ARCHEOLOGICALSURVEYS OF

NRCS FUNDED PROJECTS IN NEW YORK STATE

July 2014

PERFORMANCE WORK STATEMENT FOR THE

PERFORMANCE OF PHASE 1A/B SURVEYS OF NRCS FUNDED PROJECTS

IN NEW YORK STATE

GENERAL

I. GENERAL INFORMATION AND SCOPE OF WORK.

The scope of this contract is to obtain professional services for the performance of cultural resources management functions in New York State. The NRCS will use the results of activities under this contract to satisfy a portion of compliance requirements under: 1) the National Historic Preservation Act of 1966 as amended; 2) the National Environmental Policy Act of 1969; 3) NRCS General Manual Chapter 420, Part 401 - Archeological and Historic Properties (Cultural Resources); and 4) related historic preservation requirements and procedures.

The Contractor shall provide all personnel, equipment, tools, materials, supervision, and other items and services necessary to perform the work as defined in the Performance Work Statement (PWS) except as specified in 20TUUUUSection III BU UUU20T. The contractor shall perform to the standards in this contract.

A. OBJECTIVES AND PRODUCTS REQUIRED.

1. Objectives: The primary objective of this solicitation is to procure professional services for some cultural resources compliance activities on projects throughout New York State. The NRCS anticipates that this contract will provide the technical expertise required under Section 106 of the National Historic Preservation Act to make a recommendation of effect for review and comment by the State Historic Preservation Officer (the SHPO) and federally recognized Indian nations when appropriate.

2. Products required include:

a) Phase 1A/B survey reports containing recommendations for finding of effect for all NRCS undertakings referred to the contractor.

B. LOCATION AND SETTING.

1. Projects included under this contract are located throughout New York State and can occur in a range of environmental settings.

2. At least one contract will be awarded. NRCS reserves the right to award more than one contract.

C. PROJECT DESCRIPTION.

1. Projects included under this contract can include any one of over 150 conservation practices used in New York to conserve soil and water resources as well as other ground disturbing activities as authorized by federal laws.

Descriptions of conservation practices can be found at 20TUUUUhttp://www.nrcs.usda.gov/wps/portal/nrcs/detailfull/national/technical/cp/ncps/?cUUU

UUUid=nrcs143_026849UUUU20T.

http://www.nrcs.usda.gov/wps/portal/nrcs/detailfull/national/technical/cp/ncps/?cid=nrcs143_026849 http://www.nrcs.usda.gov/wps/portal/nrcs/detailfull/national/technical/cp/ncps/?cid=nrcs143_026849

NRCS FUNDED PROJECTS IN NEW YORK STATE

July 2014

2. Note that only practices that are ground disturbing must be evaluated for effect under this contract. See 14TAppendix A14T for a listing of ground disturbing practices.

II. PERSONNEL AND CONTRACTOR CAPABILITIES.

A. PERSONNEL STANDARDS.

1. PRINCIPAL INVESTIGATOR.

a) RESPONSIBILITY. The contractor shall provide a principal investigator who will be responsible for the performance of the work and validity of the material presented in all investigation reports. In the event of a court challenge, the Principal Investigator may be called upon to testify on behalf of the Government in support of his/her findings at Government expense, at established Government rates.

b) QUALIFICATIONS. The principal investigator will meet the Secretary of Interior’s Standards and Guidelines for Archaeologist as published in 36 CFR Part 61. The name of this person and an alternate(s) who shall act for the contractor when the principal investigator is unavailable shall be designated in writing to the contracting officer.

c) AUTHORITY. The principal investigator or alternate shall have the full authority to act for the contractor on all contract matters relating to daily operation of this contract.

d) AVAILABILITY. The principal investigator or alternate shall be available by phone during normal duty hours to discuss any issues relating to the work required by the contract with the contracting officer.

2. CREW CHIEFS. All crew chiefs and other supervisory personnel will meet the Secretary of Interior’s Standards referenced in 20TUUUUPart II.A.1UUUU20T.

3. EMPLOYEES. All contractor personnel will carry identifying information that includes the company name and the employee name.

B. CONTRACTOR CAPABILITIES. The Contractor must provide or demonstrate access to the following capabilities.

1. The Contractor shall have adequate field, laboratory, and data processing equipment, including capture of information with geospatial technology such as GPS, to conduct all phases of work within the amount of time specified in 20TUU

UUPartUUU U U U IVUUUU20T of this work statement.

2. The Contractor shall have access to adequate facilities for analysis, treatment, and storage of specimens and records likely to be obtained from this contract. This does not include such specialized facilities as pollen, geo-chemical, radiological laboratories, but does include facilities sufficient to properly preserve or stabilize specimens for any subsequent analysis.

NRCS FUNDED PROJECTS IN NEW YORK STATE

July 2014

3. The contractor will be required to document their internal facilities or formal arrangements with other entities that allow for permanent curation of specimens when landowner permission is granted. Specific identification of facilities for permanent curation is required. Curation procedures described in the NYAC Standards will be followed.

C. QUALITY CONTROL.

1. ESTABLISH AND MAINTAIN QUALITY CONTROL PLAN. The contractor shall establish and maintain a complete Quality control Plan to ensure the requirements of the contract are delivered as specified. One copy of the contractor’s Quality Control Plan shall be provided to the contracting officer as part of the contractor’s proposal. An updated copy must be provided to the contracting officer on the contract start date and if changes occur.

2. CONTENT. The plan shall comply with the requirements of FAR Clause 52- 246-4, Inspection of Services-Fixed Price, which is incorporated in UUUUSection EUUUU of the contract. The plan shall include the following:

a) INSPECTION SYSTEM. An inspection system covering all the services specified in the PWS. It must specify how work done by employees will be supervised for various activities covered by this contract. The title of the individual(s) responsible for the inspections must be provided as well.

b) IDENTIFICATION AND PREVENTION. The methods for identifying and preventing defects in the quality of service performed before performance becomes unacceptable.

c) RECORDS. On-site records of all inspections conducted by the contractor and necessary corrective action taken. This documentation shall be made available to the Government during the term of the contract.

3. GOVERNMENT REVIEW. The Government will review the Contractor Quality Control Plan to determine if it is adequate. If the plan is adequate, the government will accept the plan. If the plan is not adequate as submitted, the deficiencies will be identified to the contractor in writing. The contractor shall correct all identified deficiencies and submit a corrected Contractor Quality Control Plan within ten (10) working days of contract start date, whichever is sooner.

D. QUALITY ASSURANCE (QA).

1. QUALITY ASSURANCE EVALUATORS. NRCS CRS shall monitor contractor performance and to inspect and accept or reject the services as required by the contract.

2 . GOVERNMENT EVALUATION. The Government will evaluate the contractor’s performance under this contract using the method of surveillance deemed appropriate. A Task Order Performance Evaluation shall be prepared for each order. (See Appendix B).

NRCS FUNDED PROJECTS IN NEW YORK STATE

July 2014

The contractor shall respond to any negative performance evaluation by completing Blocks 9 and 10 explaining: 1) why performance was unacceptable, 2) how performance will be returned to acceptable levels and 3) how recurrence of the problem will be prevented in the future.

3. PERFORMANCE EVALUATION MEETINGS. The principal investigator may be required to meet periodically with the NRCS Cultural Resources Specialist (CRS) and the contracting officer during the contract. Meetings shall be as often as necessary as determined by the contracting officer. However, if the contractor requests, a meeting will be held whenever a negative performance evaluation is issued. The meetings shall focus on performance and actual or potential problems. A mutual, good faith effort shall be made by all parties to resolve all issues. The contractor’s manager, contracting officer and CRS shall sign the written minutes of these meetings. Should the contractor not concur with the minutes, notice of non-concurrence shall be provided to the contracting officer.

This notice shall be in writing and provided within seven working days of receipt of the minutes.

4. GOVERNMENT COMMUNICATION. If the SHPO or any consulting parties contact the contractor directly regarding projects, the contractor will notify the NRCS and forward all relevant correspondence to the NRCS CRS. If the contractor has questions regarding projects, the contractor must contact the

NRCS CRS.

E. PRIVATE PROPERTY INTEGRITY. The Contractor will assume all responsibility for and take all precautions to prevent damage to property entered.

F. HUMAN SKELETAL REMAINS. If human skeletal remains are found during the course of an investigation, the contractor shall follow guidelines consistent with the New York State Level Agreement between the NRCS and the SHPO.

G. HOURS OF OPERATION AND SAFETY.

1. NORMAL HOURS. All work shall be conducted Monday through Friday between the hours of 7:30 AM and 6:00 PM, unless the contractor requests and receives permission from the Government to work outside these hours.

2. SAFETY. The Contractor is required to see that the work carried out under this contract conforms to all applicable federal and state safety provisions.

H. CONTACTING NRCS FIELD OFFICE. The contractor shall contact the appropriate NRCS personnel prior to initiating field work in order to inform him or her of the contractor’s proposed work schedule and operations. NRCS personnel will notify and obtain permission from landowners and will meet the contractor on site to identify areas impacted by project implementation.

I. DOCUMENTATION, MATERIALS AND RECORDS.

1. OWNERSHIP OF DATA AND MATERIALS. Title to all data recovered or generated under this work is vested in the Government. Artifacts and materials recovered from private lands are the property of the landowner and must be returned upon concluding the survey unless the landowner states in writing that he/she is donating the artifacts to a qualified curation facility.

NRCS FUNDED PROJECTS IN NEW YORK STATE

July 2014

2. DISSEMINATION OF DATA. Prior to completion of the contract, the contractor may provide for the dissemination of technical data through oral presentations. Prior to scheduling any such presentations, approval must be obtained from the Government. Any and all requests for data or information, beyond that detailed above, will be referred to the Government.

3. PUBLICATIONS. Final versions of the survey report will be considered publishable documents and may be published, with appropriate credits, by the government. Since all data generated by this contract is considered Government property, the Contractor will not be permitted to publish the results of the investigations during the course of performance of this contract, without prior approval by the Government.

III. DEFINITIONS.

A. STANDARD DEFINITIONS.

1. ACCEPTABLE QUALITY LEVEL (AQL). The maximum allowable error rate or variation from the quality standard the Government will accept.

2. DEFECTIVE SERVICE. A service or deliverable that does not meet the performance standard specified in the contract for a specific performance requirement.

3. PERFORMANCE REQUIREMENTS SUMMARY (PRS). A listing of the performance requirements under the contract that are to be evaluated by the Government, performance indicators for these requirements, performance standards for these requirements, monitoring methods to be used to determine if performance standards are met, maximum payment for meeting the acceptable quality level (AQL), and any deduction from payment for not meeting the AQL, or incentive for exceeding the AQL.

4. QUALITY ASSURANCE. Those actions taken by the Government to assure services meet the requirements of the Performance Work Statement (PWS).

5. CULTURAL RESOURCES SPECIALIST (CRS). A government person with responsibility for compliance by the NRCS with the National Historic Preservation Act.

6. QUALITY ASSURANCE PLAN (QAP). An organized written document used for quality assurance monitoring. The document contains specific methods to perform monitoring of the contractor.

7. QUALITY CONTROL. Those actions taken by a contractor to control the performance of services so that they meet the requirements of the PWS.

B. GOVERNMENT FURNISHED PROPERTY, MATERIALS AND SERVICES

1. GOVERNMENT FURNISHED MATERIALS. The Government will provide a description of each project and all maps relating to the project developed by NRCS. The Government will also provide soil survey data that includes soil survey map and soil descriptions for soils present in the area of potential effects.

NRCS FUNDED PROJECTS IN NEW YORK STATE

July 2014

2. GOVERNMENT FURNISHED SERVICES. The Government will designate NRCS field staff to meet the contractor on site at the start of fieldwork. Since the work will take place on private land, the Government will obtain access permission from the property owner.

C. CONTRACTOR FURNISHED ITEMS AND SERVICES

1. GENERAL. Except for those items or services specifically stated to be Government furnished in Section C-III B, the contractor shall furnish everything required for this performance work statement.

IV. SPECIFIC TASKS

A. CONTACTING NRCS FIELD OFFICE

1. TASK. The NRCS CRS will submit relevant project information via e-mail to the contractor along with a request for a complete Phase 1A/B survey, a Phase 1A survey, or a Phase 1B survey (alluvial/non-alluvial) including contact information for appropriate NRCS personnel at the county field office. Prior to initiating field work, the contractor will contact appropriate NRCS staff via email with copy to NRCS CRS to coordinate with him or her of the proposed work schedule and operations and to schedule a meeting with NRCS personnel at the project’s area of potential effects.

2. QUALITY STANDARD. The contractor will contact NRCS within three business days of receiving project information to schedule the meeting at the project site. If unable to reach the appropriate contact person, or schedule work within a reasonable timeframe, the contractor shall contact the NRCS CRS.

3. PAYMENT. No separate payment will be made for this task.

B. PHASE 1A, 1B, OR 1A/B CULTURAL RESOURCES SURVEY

1. TASK. The contractor will conduct the appropriate survey of the area of potential effects as identified by the NRCS including a full report. If shovel test pits are required, they will be excavated to the depth of ground disturbance for all projects including project areas where alluvial soils are present. (Note that all artifacts found during the field investigation are the property of the landowner. Consequently, the contractor must first obtain permission before permanently depositing the materials in a curation facility.)

The contractor will transmit copies of the draft report to the New York CRS. The draft report shall be submitted electronically.

2. QUALITY STANDARD. The contractor will supply NRCS with a Draft Report containing sufficient documentation for NRCS to make an informed determination of effect so that any reviewing parties can understand its basis.

This documentation shall follow standard report format and will include, at a minimum, the information described

NRCS FUNDED PROJECTS IN NEW YORK STATE

July 2014 in 36 CFR 800.11(d) or (e) depending on the finding. The NYSOPRHP Phase I Archaeological Report Standards found in Appendix C meet these standards and may be used. One copy of the draft report will be submitted in PDF format to the NRCS CRS according to the following schedule.

Size of Area of Potential

Effects Number of Days following Receipt of Project Information from NRCS

1A Survey 1B Survey 1A/B Survey Less than 15 Acres 14 30 30

15 Acres up to 30 Acres 14 45 45

30 Acres and Larger 14 60 60

3. PAYMENT. 50% payment will be made for this task.

C. PHASE 1A, 1B, or 1A/B SURVEY FINAL REPORT.

1. TASK. Upon making any necessary changes and/or additions to the Draft Report as requested by the NRCS CRS, seven (7) copies of the Final Report will be required. Four copies shall be bound and three shall be in .pdf format on a CD.

All reports will include color photos of project areas. Site forms shall be included as a separate appendix when appropriate. All copies shall be submitted to the NRCS CRS.

2. QUALITY STANDARD. Final report will be submitted within seven days of receiving comments from the NRCS and will contain all requested changes.

3. PAYMENT. 50% payment due to the contractor for the survey will be paid upon acceptance of the final report by the NRCS and receipt of final invoice from the contractor.

NRCS FUNDED PROJECTS IN NEW YORK STATE

July 2014

PERFORMANCE REQUIREMENTS SUMMARY (PRS)

Task Performance Standard Method of Monitoring

Acceptable Level of Quality

Email NRCS Field Office to schedule survey

Within 3 business days of receipt of project information.

Copy of email to NRCS CRS

Within 3 business days

Phase 1A/B Draft Report

Submission of Draft Report in required format within authorized performance time

Receipt and review of report

Receipt within performance time as authorized above with no more than 5 documentable errors/corrections

Phase 1A/B Final Report

Submission of Final Report in required format, within authorized performance time

Receipt and review of report

Receipt within performance time as authorized above with all changes/corrections made

NRCS FUNDED PROJECTS IN NEW YORK STATE

List of Appendix

Appendix A - Ground Disturbing Potential of Conservation Practices………..4 pages

Appendix B – Task Order Performance Evaluation Report ...……………………1 page

Appendix C - NYS Historic Preservation Office (SHPO) Standards ………… 23 pages

Appendix D – List of Contract Regions………………………………….………1 page

NRCS FUNDED PROJECTS IN NEW YORK STATE

APPENDIX A

NRCS FUNDED PROJECTS IN NEW YORK STATE

July 2014

Ground Disturbing Potential of Conservation Practices

(Note: Any practices that do not appear in the following table should be considered as ground disturbing.)

Code Name Rating 560 Access Road G 309 Agrichemical Handling Facility G

122 Agricultural Energy Management Plan – Headquarters - Written NG 124 Agricultural Energy Management Plan – Landscape – Written NG 710 Agricultural Secondary Containment Facility PG

311 Alley Cropping NG 366 Anaerobic Digester, Controlled Temperature G

316 Animal Mortality Facility G 575 Animal Trails and Walkways NG 310 Bedding G 314 Brush Management PG 322 Channel Vegetation PG 326 Clearing and Snagging G 360 Closure of Waste Impoundments PG

372 Combustion System Improvement PG 397 Commercial Fishponds G 317 Composting Facility PG 126 Comprehensive Air Quality Management Plan – Written NG 102 Comprehensive Nutrient Management Plan NG 327 Conservation Cover NG 328 Conservation Crop Rotation NG

138 Conservation Plan Supporting Organic Transition – Written NG 656 Constructed Wetland G 332 Contour Buffer Strips NG 330 Contour Farming NG 331 Contour Orchard and Other Fruit Area PG 340 Cover Crop NG 342 Critical Area Planting PG

589A Cross Wind Ridges NG 589B Cross Wind Stripcropping NG 589C Cross Wind Trap Strips NG 402 Dam G 348 Dam, Diversion G 324 Deep Tillage G 356 Dike G 362 Diversion G 432 Dry Hydrant PG 647 Early Successional Habitat Development/Management NG

374 Farmstead Energy Improvement NG

NRCS FUNDED PROJECTS IN NEW YORK STATE

6/16/2014

382 Fence (all other) PG 382 Fence (high-tensile) NG 386 Field Border NG 393 Filter Strip PG 394 Firebreak PG 396 Fish Passage G 398 Fish Raceway or Tank PG 512 Forage and Biomass Planting NG 511 Forage Harvest Management NG

106 Forest Management Plan – Written NG 490 Forest Site Preparation PG 666 Forest Stand Improvement NG 655 Forest Trails & Landings G 410 Grade Stabilization Structure G 412 Grassed Waterway G 548 Grazing Land Mechanical Treatment PG

110 Grazing Management Plan – Written NG 561 Heavy Use Area Protection PG 422 Hedgerow Planting PG 315 Herbaceous Weed Control NG 603 Herbaceous Wind Barriers NG 423 Hillside Ditch G

114 Integrated Pest Management Plan – Written NG 320 Irrigation Canal or Lateral G 388 Irrigation Field Ditch G 464 Irrigation Land Leveling G 430 Irrigation Pipeline G 552 Irrigation Regulating Reservoir G 436 Irrigation Storage Reservoir G 441 Irrigation System – Microirrigation G 442 Irrigation System – Sprinkler G 443 Irrigation System – Surface & Subsurface G 447 Irrigation System, Tailwater Recovery G

428B Irrigation Water Conveyance, Ditch and Canal Lining – Flexible Membrane

G

428C Irrigation Water Conveyance, Ditch and Canal Lining – Galvanized Steel

G

428A Irrigation Water Conveyance, Ditch and Canal Lining – Non-reinforced Concrete

G

449 Irrigation Water Management PG 118 Irrigation Water Management Plan – Written NG

460 Land Clearing G 453 Land Reclamation-Landslide Treatment G 455 Land Reclamation-Toxic Discharge Control G 543 Land Reconstruction, Abandoned Mined Land G

544 Land Reconstruction, Currently Mined Land G 466 Land Smoothing G 468 Lined Waterway or Outlet G 457 Mine Shaft & Adit Closing PG 482 Mole Drain G 484 Mulching NG 590 Nutrient Management NG

104 Nutrient Management Plan CAP NG 500 Obstruction Removal G

150 Oil Spill, Prevention, Control, and Countermeasure (SPCC) – Written NG 582 Open Channel G 783 Pathogen Management NG 595 Pest Management NG 516 Pipeline PG 378 Pond G

521C Pond Sealing or Lining – Bentonite Sealant PG 521A Pond Sealing or Lining – Flexible Membrane PG 521B Pond Sealing or Lining – Soil Dispersant PG 462 Precision Land Forming G 338 Prescribed Burning PG 528 Prescribed Grazing NG 533 Pumping Plant PG 550 Range Planting NG 562 Recreation Area Improvement PG 566 Recreation Land Grading & Shaping G 568 Recreation Trail & Walkway PG 554 Regulating Water in Drainage Systems NG 345 Residue and Tillage Management, Mulch till NG 329 Residue and Tillage Management, No-Till/Strip Till/Direct Seed NG 346 Residue Management, Ridge Till NG 344 Residue Management, Seasonal NG 643 Restoration and Management of Declining Habitats NG 391 Riparian Forest Buffer PG 390 Riparian Herbaceous Cover NG 555 Rock Barrier PG 558 Roof Runoff Structure PG 367 Roofs and Covers PG 570 Runoff Management System PG 798 Seasonal High Tunnel PG 350 Sediment Basin G 646 Shallow Water Management for Wildlife G 571 Soil Salinity Management-Nonirrigated NG 632 Solid/Liquid Waste Separation Facility G 572 Spoil Spreading G 574 Spring Development G

584 Stream Channel Stabilization G 578 Stream Crossing G 395 Stream Habitat Improvement & Management PG 580 Streambank & Shoreline Protection PG 585 Stripcropping NG 587 Structure for Water Control G 606 Subsurface Drain G 607 Surface Drainage, Field Ditch G 608 Surface Drainage, Main or Lateral G 609 Surface Roughening NG 600 Terrace G 610 Toxic Salt Reduction NG 612 Tree/Shrub Establishment PG 660 Tree/Shrub Pruning NG 620 Underground Outlet G 645 Upland Wildlife Habitat Management PG 472 Use Exclusion PG 635 Vegetated Treatment Area G 601 Vegetative Barrier NG 630 Vertical Drain G 312 Waste Management System PG 313 Waste Storage Facility G 634 Waste Transfer G 359 Waste Treatment Lagoon G 638 Water & Sediment Control Basin G 636 Water Harvesting Catchment G 642 Water Well G 355 Water Well Testing NG 614 Watering Facility PG 640 Waterspreading G 351 Well Decommissioning PG 658 Wetland Creation G 659 Wetland Enhancement G 657 Wetland Restoration G 644 Wetland Wildlife Habitat Management PG 380 Windbreak/Shelterbelt Establishment PG 650 Windbreak/Shelterbelt Renovation PG

Key: G = Ground Disturbing; PG = Potentially Ground Disturbing; NG = Not Ground Disturbing.

APPENDIX B

TASK ORDER PERFORMANCE EVALAUTION REPORT

1. CONTRACT NUMBER 2. TASK ORDER NUMBER

3. TO (Contractor and Manager's Name) 4. FROM (Name of NRCS CR)

5. DATES (YYYYMMDD)

a. PREPARED b. RETURNED BY CONTRACTOR c. ACTION COMPLETE

6. TASK ORDER EVALUATION

TASK

Met Quality Standard?

Y or N

If Quality Standard was not met, provide detail

Contact NRCS Field Office

Submission of Draft Report

Submission of Final Report

7. SIGNATURE OF CONTRACTING OFFICER

CONTRACTOR – ACKNOWLEDGMENT

8a. TO (Contracting Off icer) b. FROM (Contractor)

9. CONTRACTOR RESPONSE AS TO CAUSE, CORRECTIVE ACTION AND ACTIONS TO PREVENT RECURRENCE – IF QUALITY STANDARD WAS NOT MET. (Cite applicable Q.C. program procedures or new Q.C. procedures. Att ach continuation sheet(s) if necessary). IF ALL QUALITY STANDARDS ARE MET, NO RESPONSE IS REQUIRED.

10. SIGNATURE OF CONTRACTOR REPRESENTATIVE b. DATE (YYYYMMDD)

11. GOVERNMENT EVALUATION AND RECOMMENDED ACTION(Acceptance, partial acceptance, reflection. Att ach continuation sheet(s) if necessary)

APPENDIX C

1. Phase IA Literature Search and Sensitivity Assessment Guidelines

The goals of the Phase IA investigation are to inform subsequent testing strategies and to provide the contextual framework within which to interpret identified historic properties.

The SHPO requests that separate Phase IA Reports are submitted only when the Phase IA confirms disturbance in a large portion of the project area or when the project is in an urban setting and concurrence regarding the proposed testing strategy is sought. Otherwise, a combined Phase IA/IB Report is recommended.

A. Project Description

Concise discussion of the undertaking, including all associated impacts. This discussion is especially important when the Area of Potential Effect (APE) is different than the project boundaries. 1

B. Maps and Figures

All maps and figures must be clearly legible to the reader and include:

1. Project area/APE accurately delineated with a clean solid line.

Circled or generalized boundaries are not acceptable nor is the use of highlighter or marker. UPlease note that both the APE and theU

Uproject boundary must be delineated, if differentU.

2. North arrow.

3. Map title.

4. Map author.

5. Publication date.

6. Bar scale and other scales as appropriate.

7. Key.

C. Project Map

The project map must be of sufficient scale to be easily legible to the reader and must include:

1 As defined in 36 CFR Section 800.16(d) the "Area of Potential Effect means the geographic area or areas within which an undertaking may directly or indirectly cause alterations in the character or use of historic properties, if any such properties exist". Therefore an APE definition needs to consider any areas of direct construction impact as well as access roads, staging areas, utility lines or any other areas that the construction contractor may have access to in association with a project. It is also important to consider the indirect effects which may occur including increased access, increased erosion, increased run-off, deposition, etc. to adjacent areas. While it may not be possible to test areas not under the ownership of the applicant, the potential impact to such areas needs to be considered if the potential for archaeological sites is present.

* Please note this format guideline does not apply to New York State or Federal Agencies that have adopted report standards/formats specific to their programs, such as the NYS Department of Transportation and the Army Corps of Engineers. Please contact these agencies directly for more information about their reporting requirements.

1. Project area/APE limits clearly delineated.

2. North arrow.

3. Shovel test locations - The map key must distinguish between shovel tests that include prehistoric artifacts only, historic artifacts only and both prehistoric and historic artifacts. Please do not identify or number shovel tests in areas not subjected to testing.

4. Photo angles keyed to associated images.

5. Boundaries of prior disturbance, slope greater than 12-15 percent, and areas of permanent standing water.

6. Archaeological site boundaries.

7. Road names (both local and county/state/federal designations).

8. 911 or street addresses for structures within or immediately adjacent to the project area.

9. Map scale no smaller than 1” = 200’ – 1:2,400.

10. All maps and figures must be produced in patterns and colors that are clearly legible when photocopied.

11. Bar scale and other scales as appropriate.

12. Key.

D. Project Photographs

1. Photographs must be referred to as photographs and not as figures or plates.

2. Photographs must be 3.5” x 5” in size or larger.

3. Digital photographs must be printed on photo paper.

4. Photographs must be produced at a printer setting of a minimum of 600 dpi.

E. Background Research

1. Research must be focused on the project area.

2. Do not include GENERAL historic and prehistoric contexts.

3. The following items are required:

a. Past and present land uses and current conditions illustrated with project photographs.

b. Soils description - see Appendix B for required format.

c. USDA Soils Map.

d. Discussion regarding expectations for depth of cultural deposits. This discussion should thoroughly assess the potential for colluvial, alluvial or other deeply buried soils.

e. Sites within a one mile radius – see Appendix C for required format.

f. Historic maps - Please provide a concise overview of settlement pattern trends. A detailed written overview of each historic map is not necessary.

g. Other relevant background information as necessary.

F. Sensitivity Assessment

1. Prehistoric – this discussion must focus on the site types likely to be identified given the landform(s), environmental setting and the types of sites within one mile.

2. Historic - this discussion must be based on historic map research, regional histories and other relevant historical documents.

NOTE: Please do not include prior ground disturbance in your discussion of sensitivity.

G. Disturbance

1. Discussion of the type(s), depth and extent of disturbance. Common forms of disturbance include previous mining, grading, road cuts, etc.

where the original topsoil has been removed. UFilling and plowing areU

Unot considered disturbanceU.

2. Documentation of disturbance such as photographs, aerial photographs, soil boring logs, as built drawings, elevation records, etc. must be presented. If such evidence cannot be provided, shovel testing will be necessary to document the disturbance.

3. If soil boring logs are discussed in the body of the report they must be provided as an appendix.

4. Boundaries of areas not tested must be clearly delineated on the project area map and labeled with type of disturbance.

H. Testing Recommendations

1. Discussion regarding the testing strategy warranted for the Phase IB investigation.

2. For project areas characterized by multiple building and demolition episodes, please provide a composite Map Documented Structure (MDS) and standing structures map with the location of planned excavation units noted and a table summarizing potential archaeological resources organized by building lot.

3. Phase IB Field Investigation Guidelines

A. Date of testing, conditions (including season, ground visibility, weather) and description of crew (e.g. project director, crew chief, field tech, etc).

B. A complete description of the field methodology that includes a discussion of project impacts.

C. Subsurface Shovel Testing

1. Please follow the New York Archaeological Council Standards (1994), Section 2.3.2 with the exception of isolated find spots.

2. When artifacts are discovered in an isolated shovel test context, a minimum of eight (8) additional shovel tests at 1 m (3.3 ft) and 3 m (10

ft) intervals must be excavated. Eight radial tests should Unot Ube excavated when artifacts are found in two or more adjacent or nearby shovel tests since this technique is appropriate only for isolated finds and not for archaeological sites.

3. When the project area contains many widely dispersed positive shovel tests, please contact the SHPO to discuss additional testing techniques.

D. All measurements must be presented in both metric and English.

E. Please use the terms, shovel test, test unit and trench to describe the various types of excavation units.

F. If the project area includes a standing historic structure or an MDS within its boundaries, the shovel testing interval must be 7.5 m (25 ft) or less in the suspected yard area. When the location of the foundation is known, the first transect of shovel tests must be placed 1 m (3.3 ft) or less from the foundation.

G. Surface Survey

1. When plowed and disked strips are employed, the plowed areas must be a minimum of 3.3 m (10 ft) in width and each plowed strip must include a minimum of two walked transects.

2. Transect centerlines must be spaced 15 m (50 ft) or less apart.

3. Surface visibility must be 70% or greater.

4. It is not acceptable to surface survey corn fields when the corn is 15 cm

(6 in) or greater in height.

5. A limited subsurface shovel testing program is required to assess potential variability in depth of plowzone and other soil characteristics of the various landforms present within the APE.

6. When a project area contains many widely dispersed isolated artifacts, please contact the SHPO to discuss additional testing techniques.

H. Archaeological Site Description

1. Concise context statement describing the environmental and cultural setting.

2. Estimated site size (horizontal and vertical) based on artifact distribution, topography, etc. Site boundaries must illustrate maximum possible boundaries until closer interval testing is conducted.

Please note that the site boundaries for each site identified must be included on the project map so that the relationship of the site to the APE is clear.

3. Site characteristics including period of significance, site type, etc.

4. Summary of artifact types and quantity in table format. Please refer to Appendix D for examples of artifact tables. Open and closed historic artifact dates should be provided when appropriate.

5. Artifact distribution and density maps. Please refer to Appendix E for examples of artifact maps.

6. Integrity. Please refer to National Park Service Bulletin, Guidelines for Evaluating and Registering Archeological Properties for a definition of integrity. National Park Service Bulletins may be found online at:

http://www.cr.nps.gov/nr/publications/bulletins.htm.

7. Direct and indirect impacts of the proposed project on identified sites.

8. Photographs or drawings of representative and diagnostic artifacts with a scale.

9. Repository of the artifact collection and project records.

10. Recommendations.

4. Appendices

A. Complete Shovel Test Records. Shovel test records must be submitted in table form. See Appendix F for suggested format.

B. SHPO Site Forms.

1. SHPO site forms must be included in the report.

2. A second, unbound copy of the site forms must be submitted with the

Phase I Report.

3. When noting the USGS Map, please reference only the quadrangle on which the site is located.

http://www.cr.nps.gov/nr/publications/bulletins.htm

C. Artifact Catalog. At minimum please include:

1. Phase of Survey

2. Shovel Test/Unit/Feature

3. Level

4. Depth (cm)

5. Description

6. Comments

7. Count

8. Weight (g) 9 Date Range

D. Please note that it is no longer necessary to include a Vita.

5. Report Format

A. 10 point font.

B. Single line spacing with a line between paragraphs.

C. One inch margins.

D. Comb binding is preferred. At least one half of the binding should be free of writing so that report number and county name can be placed on the binding by SHPO staff.

E. Double sided pages are preferred.

F. Appendices must be double-sided.

Additional Notes: Phase II and Phase III Investigations

1. Census and deed record information must be included and discussed in all Phase II historic site reports. Please summarize this information in tables. Please see Appendix G for suggested format.

2. Phase II Reports must contain a concise discussion of the sites(s) eligibility or non-eligibility for listing on the National Register that includes the rationale for the determination.

3. Mechanical stripping at the Phase II level of investigation should not be undertaken except in unusual circumstances and after consultation with the SHPO is completed.

4. A representative sample of test units, features and trenches must be illustrated with both photographs and profile and plan view drawings. Original field drawings are not acceptable since they are dark and difficult to read when presented as a photocopied or scanned image.

Please provide the line drawing and accompanying photograph on the same page.

5. Please provide copies of all radiocarbon dating analysis reports as an appendix. In the text of the report, please provide radiocarbon dates as a range of time, the laboratory sample identification number, and the type of material dated (wood, charcoal, corn, etc.). When presenting the radiocarbon dates please give both 1-sigma (68.3% confidence level) and 2-sigma (95.4% confidence level) ranges because all the dates within a range are equally valid. Example:

-2σ (-1σ [intercept] +1σ) +2σ. These time ranges can be obtained for free at:

Uhttp://depts.washington.edu/qil/calib/U. If several radiocarbon dates are presented, the SHPO recommends that they be displayed in table form.

6. The copy of the Phase III Report for the SHPO Library must be on acid free paper and must contain original photographs. Additionally, the Report must be provided on a CD in .pdf format.

7. Phase II and Phase III Reports must follow the Phase 1 Report formatting requirements outlined above in Section 5.

8. Updated SHPO site forms must be included in Phase II and Phase III Reports. A second, unbound copy of the site form(s) must also be submitted.

9. Please refer to National Park Service Bulletins, Guidelines for Evaluating and Registering Archeological Properties (2000) and How to Apply the National Register Criteria for Evaluation (1995) for guidance relating to National Register eligibility.

10. The SHPO requests that the following Human Remains Discovery Protocol be included in all relevant documents.

http://depts.washington.edu/qil/calib/

State Historic Preservation Office/ New York State Office of Parks, Recreation and Historic Preservation

Human Remains Discovery Protocol

In the event that human remains are encountered during construction or archaeological investigations, the State Historic Preservation Office (SHPO) requires that the following protocol is implemented:

● At all times human remains must be treated with the utmost dignity and respect. Should human remains be encountered work in the general area of the discovery will stop immediately and the location will be immediately secured and protected from damage and disturbance.

● Human remains or associated artifacts will be left in place and not disturbed. No skeletal remains or materials associated with the remains will be collected or removed until appropriate consultation has taken place and a plan of action has been developed.

● The county coroner and local law enforcement as well as the SHPO and the involved agency will be notified immediately. The coroner and local law enforcement will make the official ruling on the nature of the remains, being either forensic or archeological. If the remains are archeological in nature, a bioarchaeologist will confirm the identification as human.

● If human remains are determined to be Native American, the remains will be left in place and protected from further disturbance until a plan for their protection or removal can be generated.

The involved agency will consult SHPO and appropriate Native American groups to determine a plan of action that is consistent with the Native American Graves Protection and Repatriation Act (NAGPRA) guidance.

● If human remains are determined to be Euro-American, the remains will be left in place and protected from further disturbance until a plan for their avoidance or removal can be generated.

Consultation with the SHPO and other appropriate parties will be required to determine a plan of action.

Appendix A: Management Summary (Modified from the New York State Education Department’s 2004 Work Scope Specifications)

SHPO Project Review Number (if available):

Involved State and Federal Agencies (DEC, CORPS, FHWA, etc):

Phase of Survey:

Location Information Location:

Minor Civil Division:

County:

Survey Area (Metric & English)

Length:

Width:

Depth: (when appropriate) Number of Acres Surveyed:

Number of Square Meters & Feet Excavated (Phase II, Phase III only):

Percentage of the Site Excavated (Phase II, Phase III only):

USGS 7.5 Minute Quadrangle Map:

Archaeological Survey Overview Number & Interval of Shovel Tests:

Number & Size of Units:

Width of Plowed Strips:

Surface Survey Transect Interval:

Results of Archaeological Survey

Number & name of prehistoric sites identified:

Number & name of historic sites identified:

Number & name of sites recommended for Phase II/Avoidance:

Results of Architectural Survey

Number of buildings/structures/cemeteries within project area:

Number of buildings/structures/cemeteries adjacent to project area:

Number of previously determined NR listed or eligible buildings/structures/cemeteries/districts:

Number of identified eligible buildings/structures/cemeteries/districts:

Report Author(s):

Date of Report:

Appendix B: Project Area Soils.

Name Soil Horizon Depth cm (in)

Color Texture, Inclusions

Slope

Drainage Landform

Ovid Silt Loam A 0-26 cm (0-10 in) B 26-53 cm (10-20 in) C 53-158 cm (20-60 in)

VDk GBrn Dk Brn RBrn

Si SiCl/ClLo Grl Lo

0-3 Well Glacial Lake Plain

KEY:

UShadeU: Lt - Light, Dk - Dark, V-Very UColorU: Brn – Brown, Blk – Black, Gry – Gray, GBrn – Gray Brown, StrBrn – Strong Brown, RBrn – Red Brown, YBrn – Yellow Brown USoilsU: Cl – Clay, Lo – Loam, Si – Silt, Sa – Sand UOtherU: / - Mottled, Grl – Gravel, Cbs – Cobbles, Pbs – Pebbles, Rts - Roots

Appendix C: Archaeological Sites within One Mile of the Project Area.

NYSOPRHP

Site #

Additional Site #

Distance from APE m (ft)

Time Period Site Type

A02925.000059 NYSM 3186 305 m (1000 ft) SE Early Archaic Camp

Appendix D: Artifact Table Examples.

Table 3. Mean Dates of Diagnostic Artifacts and Vessels from the Brown Site, A01142.000029.

Unit Horizon Total Artifacts

# Diagnostic Artifacts

Mean Date (Diagnostic Artifacts)

# Diagnostic Vessels

Mean Date (Vessels)

1 Ap 169 19 1846 10 1841

2 Ap 134 13 1854 9 1848

3 Ap 338 42 1851 15 1852

4 Ap 340 37 1852 11 1856

4 Pipe Trench 2 2 1810 2 1810

Table 4. Artifacts Recovered from the Brown Site, A01142.000029.

Functional Group Number of Artifacts (%)

0 (Unaffiliated) 127 (13%)

1 (Food Related) 325 (33%)

2 (Food Remains) 50 (5%)

3 (Architectural) 413 (42%)

6 (Clothing) 4 (<1%)

8 (Lighting) 8 (1%)

10 (Smoking) 32 (3%)

15 (Faunal) 24 (2%)

Table 8. Vessel Wares from the Brown Site, A01142.000029.

Type of Ware Material Type Number of Vessels (%)

Whiteware Refined Earthenware 37 (63%)

Ironstone Refined Earthenware 9 (15%)

Redware Utilitarian 4 (7%)

Stoneware Utilitarian 3 (5%)

Pearlware Refined Earthenware 2 (3%)

Yellowware Utilitarian 2 (3%)

Undifferentiated Refined Earthenware

Refined Earthenware 1 (2%)

Porcelain Porcelain 1 (2%)

Table 9. Decorations of Refined Earthenware Vessels from the Brown Site, A01142.000029.

Vessel Decoration Color(s) Number of Vessels (%)

Transfer Printed Blue, Black, Purple, Red, Wine 18 (31%)

“Flow” Transfer Printed Blue, Black 3 (5%)

Handpainted Blue, Red, Green/Black 5 (9%)

Sponge Decorated with Handpainting

Blue 1 (2%)

Sponge Decorated Green, Blue 2 (3%)

Annular Banding Blue, Brown/Blue 3 (5%)

Shell Edged – Unscalloped

Blue 1 (2%)

Shell Edged – Scalloped Blue 3 (5%)

Undecorated – 12 (20%)

Table 10. Brown Site (A01142.000029) Artifact Distribution.

Unit Unaffiliated Food Related

Food Remains

Architectural Clothing Lighting Smoking Faunal Remains

1 26 (15%) 43 (25%) 6 (4%) 84 (50%) 0 (0%) 0 (0%) 8 (5%) 2 (1%)

2 17 (13%) 55 (41%) 6 (5%) 50 (37%) 0 (0%) 0 (0%) 5 (4%) 1 (1%)

3 34 (10%) 118 (35%)

18 (5%) 141 (42%) 2 (1%) 3 (1%) 8 (2%) 14 (4%)

4 51 (15%) 108 (32%)

20 (6%) 138 (40%) 2 (1%) 5 (2%) 11 (3%) 7 (2%)

Prehistoric Artifact Categories

TU

TU

TU

TU

TU

TU

*6

TU

TU

TU

*9

TU

TU

TU

TU

TU

TU

TU

*16

Total Count

Chert Flakes 296 36 79 43 641 20 15 515 264 35 64 53 249 65 73 143 2,591 Retouched/Utilized Flks 4 1 4 1 5 3 2 2 1 2 9 1 2 37 Projectile Point Frags 1 1 3 2 1 2 10 Biface Frags 4 1 2 1 2 10 Cores/Core Frags 1 1 1 1 1 1 3 1 10 Hammerstones 4 1 1 1 7 Net Sinkers 1 1 1 1 4 Abraders 1 1 2 Fire Cracked Rocks 2 2 192 12 2 5 53 1 2 1 1 273 Total Artifacts 302 40 85 240 665 20 21 523 278 37 119 57 265 68 75 149 2,943

*Note TU 6,9 and 16 are 1x1 m (3.3x3.3ft) and all other test units are 1x2 m (3.3x6.6 ft)

Source: Perrelli, Douglas 2004 Phase 2 Archaeological Site Examination of the Washburn Site PIN

5034.98.121 Replacement of US Route 20 & NY Route 5 Bridge over Cattaraugus Creek. Cattaraugus Indian Reservation, Erie County, New York.

Archaeological Survey, SUNY-Buffalo.

Appendix E: Artifact Distribution Map Examples.

Source: Dean, Robert 2004 Phase 1 Cultural Resource Investigations: Proposed Darling Development

Town of Boston, Erie County, New York. Heritage Preservation & Interpretation Inc.

A ppendix E: A rtifact D istribution M ap

Source: Dean, Robert 2004 Phase 1 Cultural Resource Investigations: Proposed Darling Development, Town of Boston, Erie County, New York.

Heritage Preservation & Interpretation Inc.

A ppendix E: A rtifact D istribution M ap

Source: Grills, Brian and Nina Versaggi 2003 End-of-Field Summary Widow Smith Site (SUBi-2361) and Southport West Site (SUBi-2367)

Wellsburg Water Line Project, Towns of Ashland and Southport, Chemung County, New York.

The Public Archaeological Facility, SUNY-Binghamton

Source: Panamerican Consultants 2003 Phase 1 Cultural Resources Investigation for the Proposed Iroquois Central School

District Athletic Fields, Town of Elma, Erie County, New York.

Source: Panamerican Consultants 2004 Phase 1 Cultural Resources Investigation for the Proposed Iroquois Central School

District Athletic Fields, Town of Elma ,Erie County, New York.

Appendix F: Shovel Test Table Example.

STP# Depth (cm) Soil Description Artifact Summary

6.72 0-8 YBrn/ Brn SaSi, Grl 2-flakes, 1- blocky chert Frg.

8-31 YBrn/ GBrn/ Brn SiCl, Grl, Pbs 2-flakes

6.73 0-3 Lt Brn SiCl ---

3-36 Lt Gry Cl, Pbs ---

6.74 0-17 Gry SaSi, Grl, Pbs, Cbs, Rts 1-flake

17+ Root Impasse ---

6.75 0-16 Lt GBrn SiSa, Grl, Pbs, Dk Brn 8-flakes, 1-colorless glass

16-23 Lt GBrn SiCl, Grl, Pbs --- 23-36 Lt Gry ClSi, Grl, Pbs, Cbs, Dk Brn --- 36+ Cobbles ---

6.76 0-11 Brn Fine SiSa --- 11-39 Lt GBrn/ YBrn SiCl, Grl, Pbs ---

6.77 0-32 GBrn Fine SaSi 1-plastic wrapper 32-33 YBrn ClSi, Blk Cinders --- 33-65 YBrn ClSi, Cbs --- 65+ Rock Impasse ---

6.78 0-25 Brn SaSi, Pbs, Rts --- 25-26 Blk Coarse Sa --- 26-58 Brn/Dk Brn SaSi, Grl, Cbs 1-aluminum can (7 fl. oz., “Rolling Rock”, pull tab top) 58+ Cobbles ---

6.79 0-14 Brn SaSi, Grl, Pbs 1-mirrored glass, 1-blue transfer-printed whiteware

14-39 Dk YBrn Fine SiSa, Pbs --- 39-65 Brn Fine SiSa, Asphalt. --- 65+ Asphalt ---

6.80 0-48 Lt Gry SaCl, Pbs 1-brown bottle glass 48-60 GBrn SiCl, Pbs ---

6.81 0-7 GBrn SaSi --- 7-80 Gry/ GBrn SiCl, Talus Rocks 1 – slag 80-98 GBrn ClSi ---

6.82 0-24 Hard-packed GBrn SiLo, Grl, Pbs 1-Lt. green flat glass (window) 24-52 YBrn ClSi, Grl, Pbs ---

6.83 0-7 Brn ClSi, Grl, Pbs --- 7-25 Brn SiCl, Grl, Pbs 1-melted colorless glass (bottle) 25-41 Dk YBrn SaSi, Grl, Pbs ---

6.84 0-48 Brn ClSi 1-unid. ferrous metal 48-56 YBrn SiCl ---

6.85 0-22 GBrn SiLo, Grl --- 22-52 Brn SaSi ---

SHOVEL TEST KEY:

UShadeU: Lt - Light, Dk - Dark, V - Very UColorU: Brn – Brown, Blk – Black, Gry – Gray, GBrn – Gray Brown, StrBrn – Strong Brown, RBrn – Red Brown, YBrn – Yellow Brown USoilsU: Cl – Clay, Lo – Loam, Si – Silt, Sa – Sand UOtherU: / - Mottled, Grl – Gravel, Cbs – Cobbles, Pbs – Pebbles, Rts - Roots

Appendix G: Deed and Census Record Summary Table Examples.

Table 1. Summary of Deeds Research for the Brown Site, A01142.000029).

Date Grantor Grantee Acreage Sale Price

Deed liber:page

11/4/1819 Obadiah Cooper David Wallis 99 $1,300 LL:122

8/23/1842 Daniel B. Wallis Stephen Wallis 90 $2,250 76:261

4/3/1852 Stephen & Gratia Wallis Peter Lyon James Wolford

115 $5,750 83:287

4/1/1853 James Wolford Peter & Lavinia Lyon

Allen Holcomb 76.5 $4,200 85:295

9/1/1853 Allen & Nancy Holcomb Cornelius Acker 4 $800 89:638

8/1/1855 Cornelius & Betsey Ann Acker Joseph Chase [Sr.] 4 $1000 89:638

4/1/1861 Joseph A. Chase [Jr.] Maxon Chase

Hezekiah Porter 4 $461 102:303

10/17/1861 Betsey A. [Chase] Mosher Alvira Chase

Hezekiah Porter 4 $338 102:305

4/4/1864 Hezekiah & Euphama Porter Olive Brown 1 $450 109:211

6/1/1923 Jennie Brown Addie [Brown] Graves

Milo & Catherine Weldon

1 $1 224:74

10/15/1925 Milo & Catherine Weldon Ernest Wilkes 1 $75 225:167

Appendix G: Deed and Census Record Summary Table Examples.

Table 2. Summary of Census Research from the Brown Site, A01142.000029).

Census Date Name Listed Age

1820 (Federal) David Wallace 26-45 Unnamed Male under 10 Unnamed Male 18-26 Unnamed Male 26-45 Unnamed Female under 10 Unnamed Female 26-45

1850 (Federal) Stephen C. Wallace 31 Gratia Wallace 32 Laura Wallace 9 Mary Wallace 7 Eunice Wallace under 1 David Cooper 30

1855 (State) Joseph Chase 41 Betsey Ann Chase 39 Alvira Chase 16 Joseph A. Chase 11 Martha Chase 4 Maxon Chase 2

1860 (Federal) Betsey Ann Chase 42 Aloria [Alvira?] Chase 21 Joseph Chase 16 Maxon Chase 7

1865 (State) Henry H. Brown 46 Olive Brown 45 Adeline Brown 15 Emily J. Brown 5

1870 (Federal) Henry Brown 51 Olive Brown 49 Jane Brown 10

1875 (State) Henry Brown 57 Olive Brown 49 Jennie Brown 14

1880 (Federal) Henry Brown 63 Olive Brown 63

1892 (State) Henry Brown 72 Olive Brown 73 Jennie Brown 32

New York State Historic Preservation Office (SHPO) Phase I Condensed Report Format

(April 2005)

This format is acceptable for small acreage projects such as cell towers and well…