This is a very helpful and informative essay written by someone who is clearly very experienced with the complexity of urban archaeology. I would like to offer a perspective about these issues from New York City as although there are no projects that are truly analogous in both the scale and scope of the archaeology of the Crossrail Project, we do have similar projects from a construction standpoint (see New York City Department of Environment 2013 and MTA 2013).

In New York, such projects are subject to Federal, State, and City environmental review legislation which incorporates a similar process to what Carver describes. However, under these statutes the ultimate determination of what occurs to archaeological resources is made by the governmental agency that oversees the project and is not considered by the legislative branch (NYC LPC 2002). Usually this process proceeds without issue, but there is an inherent conflict of interest as the agency that is ultimately responsible for decisions about archaeological mitigation, is also often responsible for the completion of the construction. The most egregious example of what can happen is the Federal African Burial Ground project. In this case, the General Services Administration, a Federal agency that was charged with building a courthouse, did not alter their project plans after the discovery of a Colonial era burial ground for people of African ancestry until community protests and very unusual legislative involvement forced change (Howard University Press et al, 2009, Vol 1, Chapter 1). Another key methodological difference is that I do not know of any archaeological project in New York City that has used risk management analysis as Carver recommends and it is something to consider for future mega-infrastructure projects in New York City. However, we now lack the retrospective data about how archaeology has impacted projects from a project management perspective. Therefore, if we wished to proceed, we would need to determine if we can create this dataset or at least begin a practice of collecting such data for current and future projects (Louis Berger 2004).

Clearly though, the best test of the planning process is when significant archaeological resources are actually discovered and there are two recent projects that involved many of the issues noted by Carver. One is the construction of the new South Ferry subway station and subway tunnel in Battery Park, Lower Manhattan (sadly, the station is now closed because of damage sustained during Hurricane Sandy.) Significant archaeological resources were found including portions of the 18^th century Battery. The other project is the expansion of the World Trade Center site, also in Lower Manhattan, where a late 18^th century merchant ship was found. In both projects, archaeology was considered in the early planning stages and the initial archaeological predictive modeling tuned out to be accurate (Louis Berger 2003 and AKRF 2009). Another similarity is that archaeological monitoring was the methodology that was chosen and elaborate protocols were adopted before either project occurred that considered as many contingencies as possible. Even so, there were challenging points in both projects and, as Carver noted often occurs, the professional working relationships between the governmental agencies overseeing the projects, the project managers, the construction managers, the reviewing governmental agencies, and the archaeologists were key in how those challenges were met. Ultimately though, archaeology was completed for both projects and more is now known about 18^th century New York than was previously (ARKF et al 2012 and AKRF 2009- the final archaeological report for the World Trade Center project is pending).

Finally, I recommend that a media strategy be developed in the planning stages especially for prominent construction projects. The discovery of significant archaeological resources during such projects can result in international media attention as occurred for both of the projects mentioned above (See Harris 2005 for example). This attention can be very sudden, intense, and come at a time when the archaeological team is apt to be exhausted from hours in the field. Having a strategy in place that has considered the potential significance of what may be found, that uses accessible language, and that has been vetted by the project stakeholders can be very beneficial in ensuring a rapid, accurate, and yet measured response. This planning is worthwhile as the press can be beneficial in multiple ways such as making more of the public aware of specific archaeological discoveries and helping to ensure that sufficient resources are indeed provided for the appropriate completion of the archaeology at a time when funds may be needed for other parts of the project. For example, there is a project in Lower Manhattan to fully reconstruct the streets which involves replacing sewers, water lines, and electrical lines. At the end of the multi-year project, businesses and residents should have better services but in the meantime, they are subject to many inconveniences which are reported in the local press. Stories about the archaeological discoveries have provided a counterbalance to those stories and resulted in positive community relations for the project (Schuldenrein 2011).

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