Records, Qualifications, and Project Schedule

The California Historical Resources Information System is the statewide archive of recorded archaeological sites, historic resources, and prior survey reports, held at regional Information Centers. A records search tells you what has already been recorded within a defined radius of your project and what previous studies exist, and it is the first step in nearly every California cultural resources scope.

The Information Centers relevant to our California offices:

Under the CHRIS Rules of Operation, Information Centers complete searches within 45 calendar days of a complete request. Projects crossing county lines may require separate requests and separate 45-day clocks at each center.

No, and this surprises people. Confidential archaeological information is available only to individuals who meet the Secretary of the Interior’s Professional Qualification Standards in archeology, architectural history, architecture, historic architecture, or history, the California State Personnel Board qualifications for Associate State Archaeologist or State Historian II, or California licensure as a Landscape Architect with additional experience approved by the State Historical Resources Commission, or who work under the supervision of someone in one of those categories. Landowners can access information for their own property with proof of ownership, and scholars and students have a separate path.

The mechanics are less onerous than they sound, but they do have to happen before the clock starts. A qualified individual files a CHRIS Information Access and Use Agreement with any one Information Center, and once established it is valid at all of them, with the issuing center circulating it to the others. Individual searches then go in on a separate Data Request form for each project. What catches schedules out is a firm with no qualified staff under agreement at all, because until that is in place there is no way to submit a request.

It is a request to the Native American Heritage Commission asking whether its Sacred Lands File contains a record of a Native American cultural resource within or near a project area. The Commission responds with either a positive or negative result and, in either case, a list of tribes to contact.

Two things to understand about it. A negative result means the Commission has no record, not that nothing is there, so it does not substitute for consultation or survey. And for a project taking the AB 130 infill exemption, a Sacred Lands Inventory request is a statutory condition of approval under Public Resources Code 21080.66(b)(4)(B)(v), not a discretionary step.

Turnaround is not published and varies. The Commission held a workshop in May 2026 reviewing the submission process, and no changes had been adopted as of August 2026, so treat the timing as unpredictable and plan the request early.

They are the federal minimum credentials for professionals doing historic preservation work, published in 1983 as part of the Secretary of the Interior’s Standards and Guidelines for Archeology and Historic Preservation at 48 FR 44716, 44738 to 44739, referenced in the National Historic Preservation Fund regulations at 36 CFR 61.4, and picked up by the Section 106 regulations at 36 CFR 800.2(a)(1). They cover five disciplines: archeology, history, architectural history, architecture, and historic architecture.

A citation note, since this one trips people. There is no Appendix A to 36 CFR Part 61 in the current regulations, though a great deal of published material still cites one. The standards live in the 1983 Federal Register notice, incorporated by reference.

The archeology standard requires a graduate degree in archeology, anthropology, or a closely related field, plus at least one year of full-time professional experience or equivalent specialized training, at least four months of supervised field and analytic experience in general North American archeology, and demonstrated ability to carry research to completion. A prehistoric or historic specialization requires an additional year of full-time experience at a supervisory level with resources of that period.

The standards say nothing about the title “Principal Investigator.” That designation comes from individual agencies and permitting programs, including the Bureau of Land Management, Caltrans, and county guidelines, each of which sets its own threshold on top of the federal standard.

These standards do practical gatekeeping in California. Both CHRIS records access and Caltrans Professionally Qualified Staff status rest on them, so a team without a qualified professional cannot obtain the records the analysis depends on.

Both of the agreements governing cultural resources on Caltrans projects were replaced effective December 6, 2024, and a good deal of published guidance still describes the superseded versions.

The Section 106 Programmatic Agreement superseded the 2014 first amended PA. The signatories are the Federal Highway Administration, the Advisory Council on Historic Preservation, the California SHPO, and Caltrans, with the Sacramento, San Francisco, and Los Angeles districts of the Army Corps of Engineers as invited signatories. All actions taken under the agreement must be conducted by or under the supervision of Caltrans Professionally Qualified Staff, and the agreement directs documentation in accordance with Caltrans Standard Environmental Reference Volume 2.

The Public Resources Code 5024 Memorandum of Understanding between Caltrans and the SHPO also took effect December 6, 2024, with a ten-year term, replacing the 2015 MOU. It delegates much of the SHPO’s routine PRC 5024 role to Caltrans, so projects with minimal potential to affect state-owned historical resources proceed without SHPO review. Review periods vary. Determinations of eligibility and certain effect findings get 30 days, and some findings bypass SHPO review entirely and appear only in annual reporting.

If your team is working transportation projects on 2014 PA assumptions, the procedures have changed.

The regulatory clocks are published and the fieldwork is not, so treat these two categories differently.

Documented clocks:

Survey duration and report turnaround are a different matter, and there is no authoritative source for either. Any number you see on a consultant’s website for those steps is that firm’s experience, and it should be labeled that way. Ask us about your specific project and we will give you a range based on the acreage, the access, the season, and the agency, and tell you what it depends on.

Six things, in roughly the order they cause trouble.

• AB 52 consultation has no conclusion deadline. The 14, 30, and 30-day clocks are all front-end. Conclusion requires agreement or a good-faith determination that agreement cannot be reached, and after *Koi Nation* an agency cannot shortcut that to hold a schedule without risking the approval.
• Documentation, more than the consultation itself. *Koi Nation* invalidated a mitigated negative declaration over failures to respond to tribal input, share survey results, document reasons for rejecting mitigation, and reflect consultation in the environmental document. Each is a paperwork failure with a full-restart consequence.
• Records access before records search. The 45-day CHRIS clock starts on a complete request submitted by someone with an Access and Use Agreement in place. Linear projects crossing county lines need a separate data request, and a separate 45-day clock, at each Information Center.
• Repository agreements for paleontological curation, which must be executed before ground disturbance and involve a third party with no obligation to accommodate your schedule.
• Human remains, the one unbounded risk. Work stops with no outer limit beyond the coroner’s two working days, and the process can end in mandatory on-site reinterment with a recorded easement, which encumbers the parcel permanently.
• CEQA exemption expectations. A client told that “exempt means fast” will be unhappy to learn that an AB 130 infill project carries a mandatory records search, a tribal cultural records search, a Sacred Lands Inventory request, a consultation process running up to 148 days, and tribal monitoring on request.