CERTIFIED MAIL – RETURN RECEIPT REQUESTED

Notice To: Cultural Resource Analysts, Inc.

119 West Summit Hill Drive
Knoxville, Tennessee 37902
Attn: Travis Hurdle – Director of Operations

Federal Land Management Agency: NPS – U.S. Dept. of the Interior

Southeast Region
Natchez Trace Parkway

Federal Land Manager: Mary Risser, Superintendent

Violation: Damage, alteration, or disturbance of archaeological resources

located on National Park Service (NPS) lands in violation of the
Archaeological Resources Protection Act of 1979 (16 USC 470ee,
36 CFR 2.1[a][6], and 43 CFR 7).

An investigation has revealed that Cultural Resource Analysts, Inc. (CRA) is responsible for damage to
archeological sites on the Natchez Trace Parkway adjacent to the proposed “Stephens Valley”
development. The damage, the excavation and removal of archeological resources that are over 100
years old, occurred between November 2nd and 4th of 2016 during an activity that was conducted
without a permit or a contract. The specific locations of the damaged sites are archaeological sites
40DV366, 40DV690, 40WM470, and 40DV691.

You have damaged archeological resources located on federal lands in violation of the Archaeological
Resources Protection Act of 1979 (ARPA, 16 USC 470aa-mm), 36 CFR 2.1(a)(6), and 43 CFR 7. The
total damages have been ascertained pursuant to the law in the amount of $15,024. The proposed
penalty amount is $15,024.

Archeological resources removed from the site are the property of the United States Government
and are to be returned in coordination with Natchez trace Parkway cultural resource specialist
Christina Smith. She can be reached at 662-840-7560 or Christina_Smith@nps.gov.

You have 45 days from the service of this notice to take one of the following actions:

• Seek informal discussions with the Federal Land Manager named in this notice to discuss
mitigation of the proposed penalty;

• File a petition for relief, stating the basis for your request to the Federal Land Manager;

• Accept the proposed penalty in writing or by making payment. Acceptance of the proposed
penalty shall be deemed a waiver of the Notice of Assessment and the right to request a
hearing; or

• Take no action and await the issuance of the Notice of Assessment.

Upon completion of the review of any petition, at the conclusion of the informal discussions, or upon
passage of 45 days if you take no action, I will, if appropriate, issue a Notice of Assessment. If one is
issued, you will have the right to a hearing before an Administrative Law judge of the Middle District
of Tennessee if you wish to appeal. I will advise you of the proper procedures for appealing the
Notice of Assessment in any Notice of Assessment that I issue.
You have the right to seek judicial review of any final administrative decision assessing a civil penalty.
All communication directed to the Federal Land Manager should be submitted to:

Mary Risser, Superintendent

2680 Natchez Trace Parkway
Tupelo, MS 38804

12/22/2017

X Laura Perdices
Laura Perdices
Administrative Officer
Signed by: LAURA PERDICES
Acting Superintendent with signature authority ___________ _
Superintendent Date
Natchez Trace Parkway

cc: David W. Morgan, Ph.D., NPS Southeast Regional Archeologist

Brad Bennett, NPS Acting Deputy Regional Director, Southeast

Owen Simcoe, US Park Ranger (Case Officer), Natchez Trace Parkway