Cultural Resources Review & Compliance Process

The term, Cultural Resources, refers to places or things that are products of human behavior in the past and that exist in the present, including prehistoric and historic archaeological sites, historic buildings, structures, and other things resulting from human actions, and Traditional Cultural Places, which are places associated with the cultural practices or beliefs of a living community. Pima County requires that any development with a potential to impact cultural resources must take into account and mitigate the negative effects on cultural and historic resources.

Graphic by Bill SingletonAs defined in our Laws and Policies Section, comprehensive planning efforts, subdivision planning, and other development planning are subject to County policies, regulations, and codes regarding cultural and historic resources protection and preservation. Reviews to ensure cultural resources compliance are required during several phases of the development planning process, including Comprehensive Plan Amendments, Rezoning Requests, Site Analysis Reports, and Type II Grading and Paving Permits . Additionally, County Right of Way Use Permits , are subject to cultural resources requirements, as indicated in the Right of Way Use Permit application.

Cultural Resources as Part of the Development Services Review Process

All County Cultural Resources requirements must be met through the appropriate internal County review procedure to maintain consistency in the review process and to ensure fair and equitable application of County requirements.

All review submittals and applications must be submitted for Development Services review through the electronic review portal, Accela Automation. Please contact the Development Services Department for assistance in understanding the submittal requirements and review process. Cultural Resources staff will conduct an assessment of the cultural resources status of the proposed development property and to determine if any additional steps are necessary to meet County cultural resources requirements. Cultural Resources staff will review and respond directly in the Accela Automation review system with approval or a request for additional information, and/or conditions. In cases where additional cultural resources actions are required, the Cultural Resources staff can work with the applicant, or Consultant, to assist the applicant in meeting cultural resources requirements.

Comprehensive Plan Amendments

County review of Comprehensive Plan Amendments is necessary to ensure that subdivision developments take into account and mitigate the negative effects of development construction on cultural and historic resources. The County can include Comprehensive Plan policy statements regarding cultural resources and historic preservation in plan amendments to preserve and protect significant resources. In the case of Comprehensive Plan Amendment Requests, the developer will submit all relevant materials, including cultural resources documentation, to the appropriate contacts in Development Services Planning Division.

Rezoning Requests and Site Analysis Reports

Rezoning requests and Site Analysis Reports submitted in support of rezonings must comply with County cultural resources requirements. The current cultural resources status of a development property must be documented in the Site Analysis Report, including supporting documentation such as the Arizona State Museum Archaeological Records Check Form and/or documentation of cultural resources survey, or mitigation treatment conducted within the development property. Consult with Pima County Development Services for guidelines to meet these requirements. In the case of Rezoning Requests and Site Analysis Reports, the developer will submit all relevant materials, including cultural resources documentation, to the appropriate contacts in Development Services Planning Division.

Site Construction Permits (Type II Grading Permit)

Prior to issuing a Site Construction Permit (Type II grading permit) or in conjunction with Development Concept Permit (Development Plan) approval, Pima County cultural resources requirements must be met, as stipulated under Chapter 18.81 of the Pima County Zoning Code (Title 18.81.060.B.10). The Cultural Resources Office encourages the applicant to address these requirements as early as possible in the planning phase of the development to avoid construction delays. Avoidance of cultural and historic resources is the preferred strategy to mitigate construction impacts, and can be achieved easily by conveyance to the County of a Conservation Easement encompassing the threatened cultural resources. The Conservation Easement must be a legal, signed agreement between the property owner and/or developer and the County. The Conservation Easement will ensure protection of the resources in perpetuity and must “run with the land” and remain in effect regardless of changes in land ownership. The Conservation Easement must be graphically depicted on Plats and development plans and documented in plat notes and plan notations. Avoidance of cultural resources can also be documented on the Tentative Plat, with supporting plat notes, by incorporating the cultural resources within designated Common Areas or Open Space. The County can assist the Developer with the development of a Conservation Easement or dedicating cultural resources areas for avoidance on the Tentative Plat. . Grading permit applications are reviewed in Accela by cultural resources staff. However, the developer may choose to contact OSC cultural resources staff prior to submittal of application to obtain more information on the cultural resources requirements for a particular project.  

Pima County Right of Way Use Permit

Construction within Pima County roadway rights of way to provide utilities and other infrastructure in support of development requires a Right of Way Use Permit.

Pima County Office of Sustainability & Conservation, Cultural Resources and Historic Preservation Division permitted staff will conduct a records check if the total project length is greater than 500 linear feet. Although required at the time of submittal of the permit application, the applicant may submit the project map and plans to Cultural Resources staff prior to submittal of the ROW permit application.
  • If, upon review, it is determined by permitted staff that no further archaeological investigation is needed in the project alignments, a cultural resources clearance (applicable to alignments within County-owned land) may be issued to the Pima County Department of Transportation.
  • If, upon review, it is determined by permitted staff that the project area requires an on-the-ground pedestrian survey, then an archaeological survey must be conducted by an Arizona Antiquities Act permitted archaeological consultant (or a registered architect as applicable). An Agency version of the archaeological survey report must be submitted to County Cultural Resources staff for review.

    • If the survey results in a finding of no archaeological or historic sites, or no sites affected on Pima County ROW, a cultural resources clearance (applicable to alignments within County-owned land) may be issued by permitted staff to the Pima County Department of Transportation.
    • If the field survey finds significant archaeological or historic sites, then the applicant will develop and implement an appropriate mitigation treatment plan (prepared by a permitted archaeological consultant) in accordance with professional standards and County Cultural Resources reviews. County Cultural Resources may consult with the State Historic Preservation Office. Permitted staff will issue a clearance letter (applicable to alignments within County-owned land) when compliance requirements have been met.
Addressing cultural resources requirements as early as possible in development planning is the best way to avoid project delays. The developer and/or permit applicant should allow time in development planning for the following steps. The guidelines below will assist the developer through the compliance review process to successfully meet County requirements and allow development projects to proceed. 

Step One – Records Check

  • Check records to determine if previously recorded cultural resources are in the project area
  • Assess the potential for finding intact cultural resources in the project area
  • Determine if cultural resources survey is needed
Office of Sustainability & Conservation, Cultural Resources and Historic Preservation Division staff will conduct a check of the records, which determine the next step in the process. For instance, if the project area has been surveyed within the last ten years and no cultural or historic resources were found, a cultural resources clearance can be issued. If the records check reveals that the project area has not been surveyed, the County may require cultural resources survey and mitigation, if necessary, before a clearance can be issued.

Step Two - Inventory

  • Cultural Resources Survey:  An on-the-ground inspection of the project area and all areas related to the project
  • Requires the services of a professional archaeologist or architect, or both, as needed
  • A report documents all cultural resources, or their absence, in the project area

The field survey, and any subsequent investigations or documentation that the County determines are needed to mitigate the effects of a project on archaeological and historical resources, shall be conducted by an archaeologist permitted by the ASM, or by a registered architect, as appropriate. Survey and subsequent investigations are subject to review and approval by Pima County and the State Historic Preservation Office (SHPO). A list of ASM permitted consultants is available at the ASM website: Archaeological Consultants Holding Arizona Antiquities Act Permits.

Step Three - Evaluation of Significance

The significance of cultural resources is defined by federal regulations (36 CFR 60.4) that are adopted into State law and County policies. 

National Register criteria for evaluation. "The quality of significance in American history, architecture, archeology, engineering, and culture is present in districts, sites, buildings, structures, and objects that possess integrity of location, design, setting, materials, workmanship, feeling, and association and

(a) that are associated with events that have made a significant contribution to the broad patterns of our history; or

(b) that are associated with the lives of persons significant in our past; or

(c) that embody the distinctive characteristics of a type, period, or method of construction, or that represent the work of a master, or that possess high artistic values, or that represent a significant and distinguishable entity whose components may lack individual distinction; or

(d) that have yielded, or may be likely to yield, information important in prehistory or history."

All cultural resources documented in a county project area are evaluated for their eligibility to be listed in the National Register of Historic Places. This is the nation’s honor role of places considered to be important to the history of the American people at the national, state, or local level. Any cultural resource that is not eligible for the National Register is not considered “significant” and usually requires no further consideration.  Exception: roadside shrines.

Step Four – Impact Assessment

Assess Impacts to National Register eligible sites: Will the proposed project adversely affect the characteristics that make the site eligible for listing?
  • If yes, prepare mitigation plan
  • If a project will not negatively affect a National Register eligible site, or the project can be modified to avoid affecting the site, then a mitigation plan is not needed and the project can continue
In such cases, a stipulation might be added; for instance, a conservation easement identified to ensure protection of the cultural resource. The preferred means of treating effects to, or impacts on, National Register eligible sites is avoidance and preservation in place. Avoidance is the quickest and cheapest way to deal with the problem and the best way to protect and preserve cultural resources.

If that is not possible, or desirable, and a National Register eligible cultural resource will be affected, then mitigation is required.

Step Five - Mitigation

Mitigation Plan: A strategy for minimizing harm to National Register sites.
Typical mitigation options:
  • restore/reuse/rehabilitate
  • relocate
  • record/research/recover data
Mitigation means doing something to either preserve the actual cultural resource itself or to recover information about the cultural resource before it is destroyed through construction. What is done to mitigate effects to the cultural resources will depend on what the resource is, why it is important, and how it will be affected. The options can range in scope from a simple monitoring plan to full scale excavation, analysis, curation, and report preparation.


Throughout the review process, reports are generated by professional archaeologists or architects, as applicable, and these reports are reviewed by the Cultural Resources staff. As mentioned, however, there are often other players in the review process, including you. As the developer, it is your responsibility to communicate with us. In turn, it is our responsibility to be responsive to your needs. For instance, we will ensure that if other reviewers are involved, we coordinate with them so that your project gets through the review process. We will keep you informed and work to resolve any problems that might arise. A primary responsibility of our office is to see that county cultural resources requirements are met, but we’re also here to assist you through the process and to help you obtain the necessary approvals so that you can successfully complete your project.

Planning for Preservation

  • Project Review is mandatory
  • Required information 
  • What is the project?
  • Where is it located?
  • Who is doing the work?
  • When will the work begin?
  • Are state and/or federal permits necessary?

The bottom line is that we may have a lot to talk about regarding your project. It is important that we hear from you early in the project’s planning stages so that if there are National Register eligible properties that may be affected, we can quickly take steps to help you mitigate effects. The list of questions above includes the critical questions that we will be asking about your projects.

Coordinate and Communicate

  • Integrate preservation planning into your project schedule – be proactive, not reactive
  • Consult with us during the design phase – early is better than late – allow time for consultation
  • Send your plans to the appropriate county agency for each required review, and they will forward the materials to us for review
  • Keep us in the loop – design changes, etc.

We can provide you with timely, professional advice regarding cultural resources requirements. We can also advise you about the county review process. It is our responsibility to assist you in meeting the requirements as much as it is our obligation to see that they are met. Good communication and coordination are needed to make this happen.

Summary of Points to Remember

Here is a summary of important points and things to remember that will allow us to assist you.

  • Cultural Resources have value
  • County, state, and federal law protect these values
  • Consultation is mandatory for development projects in Pima County
  • There is an established review process
  • Other parties may be involved in the review process
  • Compliance takes time and costs money
  • Consult with us early in planning process – anticipate
  • Provide us with critical project information
  • Coordinate compliance with your project schedule
  • Good communication is the key to the review process
  • Keep us in the loop and we’ll keep your project on track
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Cultural Resources and Historic Preservation

201 N. Stone Ave., 6th FL
Tucson, AZ 85701

(520) 724-6940

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