ABSTRACT
It has been some time since a court of law last addressed the “reasonable and good faith effort” standard1 for the identification of historic properties under section 106.2 In Quechan Indian Tribe of the Fort Yuma Indian Reservation v. U.S. Department of the Interior,3 the District Court of Arizona did just that, and in doing so provided us with another useful touchstone for judging the adequacy of agency efforts to identify historic properties within an area of potential effects.
