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Tuesday, May 05, 2015

Don't Sweat the Small Stuff: Using 36 CFR 800.3(a)

Suppose you’re a federal official, or a contractor for a federal agency, with a piece of land to manage. Or maybe you’re a State Historic Preservation Officer (SHPO) consulting with such an agency.
Suppose you’re SURE that no historic properties, known or unknown, are likely to be affected by operations on the land – maybe because you’ve studied the place and consulted with everyone concerned and found nothing to be concerned about, maybe because the kinds of things being done there (say, routine maintenance) just doesn’t do any damage.
Suppose, as a result, you want to stop spending time doing standard NHPA Section 106 review on each and every operation (e.g. each building remodel or ditch-digging project, but don't know how.
What do you do?
I get this question pretty often, and people usually usually ask about negotiating a programmatic agreement (PA) or some other "program alternative." Which takes months or years to negotiate, bores everyone to tears, usually becomes dangerously bloated and subject to misinterpretation, and often, once in place, is simply (and understandably) ignored.
People, you don't have to go to so much trouble. Fixating on such things, I think, is an expression of an all-too-common distortion of​ the 106 review process, in which everybody agonizes over small, routine, pretty much insignificant issues and develops ponderous documents stipulating how they’ll be addressed.
The flip side of this distortion is ignoring the big, nasty issues and impacts and closing interested parties out of "consultation.” That last word usually defined as "getting the SHPO to approve our projects."
In other words, everybody sweats the small stuff and ignores the important cases where there are real issues to be resolved, of importance to real people.
There’s a simpler way to quit wasting time on reviewing routine, virtually-no-impact operations.
If a federal agency is really sure that its undertakings on a given facility have no potential to affect historic properties, then the agency and its helpers ought to look at 36 CFR 800.3(a). This section of the Section 106 regulations says that in initiating review of a proposed undertaking:
The agency official shall determine whether the proposed Federal action is an undertaking as defined in § 800.16(y) and, if so, whether it is a type of activity that has the potential to cause effects on historic properties. (underscore added)

It goes on to say:

 If the undertaking is a type of activity that does not have the potential to cause effects on historic properties, assuming such historic properties were present, the agency official has no further obligations under section 106 or this part. (underscore added)

In other words, the agency can -- unilaterally and without going through any particular process, conclude that -- say -- routine operations at the Fred Noonan Institute for Aerial Navigation have no potential for effect on historic properties, and hence do not require review under Section 106. Document that for the record and proceed with no further 106 work.

No PA, no exemption, no SHPO buy-in.

I have some caveats, of course:
1.    You need to be REALLY sure there's no potential for impact -- direct or indirect, or contributions to cumulative impact, on any and all kinds of historic properties.
2.    But of course, you may be wrong, so you need to provide somehow for cases where impacts DO arise.
3.    Time passes, history happens, change comes, so you probably ought to reconsider your finding from time to time.

Some have been known to argue that if an action-type (say, ditch-digging) has the theoretical, abstract potential for impact (You can never be SURE what's in the ground, or not, or whether there's something historic about Building 72 that nobody's noticed despite the fact that it was built in 2012), an action falling into that type must be reviewed. There is some intellectual legitimacy to this sort of argument, but it is truly an argument for devoting limited resources to BS debates, and -- as one wise Federal Preservation Officer who used Section 800.3(a) effectively once asked me, "Who the &^%$# is going to sue?"

So seriously, if you’re a federal agency official, or a consultant advising such an official, or an SHPO consulting with such an official, consider Section 800.3(a). Applied responsibly, it can save a lot of time and trouble, and allow you to apply your limited personnel and financial resources to cases that actually matter.

Monday, April 27, 2015

SHPOs Kill Trees, Don't They?

I've lately come upon two State Historic Preservation Officers (SHPOs) who insist that all correspondence with them be carried out via hard-copy letters and attachments -- no emails or attached electronic documents.

When I cornered a staff member of one of the offices and inquired about this seemingly retrograde and anti-environmental policy -- which wastes time and money, complicates digital file management, and requires the killing and processing of trees with all the attendant environmental impacts -- I was told that it was standard policy at most if not all SHPO offices, and necessary in order to maintain a "paper trail."

The latter argument is idiotic, of course; innumerable federal agencies maintain "paper trails" in electronic contexts. I can't remember the last time I had to file my tax returns on paper, for example, and the Advisory Council on Historic Preservation routinely corresponds electronically about Section 106 cases. But I wouldn't put it past the National Park Service to have demanded the maintenance of paper files by its Historic Preservation Fund (HPF) grantees.

Can anyone enlighten me about this? Do most SHPOs promote deforestation? Is it mandated by HPF grant administration policy?

NPS Plant/Mineral Gathering Regs Out for Comment

The National Park Service (NPS) has issued draft regulations dealing with tribal gathering of plants and minerals in units of the National Park System.  Everyone should examine the draft and comment on it, as I will. 

These regulations have been some thirty years in the making, and have been bitterly contested by people who apparently feel sure that tribes – despite having successfully managed the lands of North America for exponentially longer than has the U.S. government (if one can characterize government management as “successful”) – will wreak havoc on park resources.

Like every other regulation, this one is the product of many compromises. I think that on balance it’s a good piece of work, but there are certainly ways it can be improved, and devils to be ferreted out of the details.

Setting these regulations in place was one of the last things my late wife, Pat Parker, wanted to get done before retirement. She didn’t get to retire, but I hope the regulations on which she labored so long will soon be effective.

Please review the draft regs and comment – particularly if you’re an Indian tribe or someone who works with tribes. Below is the NPS press release on the draft's publication, which oddly does not provide the interested public with a way to access the draft itself. Here’s where you can find the draft:

National Park Service Proposes Regulation for Gathering Plants 
Rule covers members of federally-recognized American Indian tribes       
WASHINGTON – The National Park Service has proposed to modify the regulation governing the gathering of plants in national parks. The rule would allow members of federally recognized Indian tribes with traditional associations to areas within specific units of the National Park System to gather and remove plants or plant parts for traditional purposes. The gathering and removal allowed by the rule would be governed by agreements that may be entered into between the National Park Service and the tribes, and would also be subject to permits that identify the tribal members who may conduct these activities. The rule would prohibit commercial uses of gathered materials.
To be published Monday April 20 in the Federal Register, 36 CFR Part 2, Gathering of Certain Plants or Plant Parts by Federally Recognized Indian Tribes for Traditional Purposes, will be open for public comment for 90 days through Monday, July 20, 2015.
“The proposed rule respects tribal sovereignty and the government-to-government relationship between the United States and the tribes,” said National Park Service Director Jonathan B. Jarvis. “It also supports the mission of the National Park Service and the continuation of unique cultural traditions of American Indians.”
Many units of the National Park System contain resources important to the continuation of American Indian cultures. Indian tribes have actively sought the ability to gather and use plant resources for traditional purposes such as basketry and traditional medicines while ensuring the sustainability of plant communities in parks. At the same time, park managers and law enforcement officers need clear guidance regarding their responsibilities for enforcing park regulations with respect to the use of park resources by American Indians. The proposal provides an approach to plant collecting by members of federally recognized tribes that can be applied across the National Park Service.
In drafting the proposed rule, National Park Service staff met with or contacted more than 120 Indian tribes. Tribal consultation that followed indicates that the approach taken in the proposed rule would address the need for gathering while respecting tribal sovereignty.
Comments on the proposed rule should reference the National Park Service and Regulation Identifier Number (RIN) 1024-AD84, and can be submitted online through the Federal Rulemaking Portal:, which provides instructions for submitting comments; or by mail to: National Park Service, Joe Watkins, Office of Tribal Relations and American Cultures, 1201 Eye Street NW, Washington, DC 20005. The National Park Service will accept public comments on the proposed rule through Monday, July 20, 2015.

Comments and suggestions on the information collection requirements in the proposed rule should be sent to the Desk Officer for the Department of the Interior at OMB-OIRA by fax at (202) 395-5806 or by e-mail to Please provide a copy of your comments by e-mail or by mail to: Information Collection Clearance Officer, National Park Service, 1849 C Street, NW, Washington, DC 20240. Please reference “1024-AD84” in the subject line of your comments. You may review the Information Collection Request online at Follow the instructions to review Department of the Interior collections under review by OMB. Comments on the information collection requirements must be received by Wednesday, May 20, 2015. 

Monday, January 26, 2015

Understanding the Koch Brothers

I’ve long wondered how the Koch Brothers and the suckers they attract[1] could remain so rigorously true to their own self-interest, in the face of mounting evidence that they’re destroying the very planet on which we all live.  Enlightenment came when I learned  that the Kochs hang out and hold job interviews for their political lackeys in Palm Springs, California.

Palm Springs is built on and around Sec-he, a hot mineral spring and settlement of the Cahuilla Tribe.  In Cahuilla tradition, a powerful spirit named Tahquitz lives in an obsidian cave high in the mountains that tower above Sec-he.  Tahquitz come out now and then in the form of a blue light or comet and – consumes people’s souls!

So there we have it.  The Kochs are soul-free creatures possessed by Tahquitz, and so, quite likely, are their suckers.  They are zombie-like beings who cannot really be held accountable for their actions and beliefs. 

How we account for Tahquitz’ own motivations is a trickier problem, requiring more study.

[1] Who could resist referring to their political lackeys as Koch suckers?

Monday, January 12, 2015

Je Suis Dan Synder?

Can anyone help me understand the difference between cartoons mocking Mohammad and use of the name “Redskins” for an American football team? 

I’m not writing to excuse the assault on Charlie Hebdo, and I don’t mean to trivialize its consequences or implications by comparing it with the ongoing uproar over the name of Washington DC’s team.  I’m just trying to get my mind around how editorialists and other opinion makers can more or less simultaneously insist that we beneficiaries of Western Civilization stand in solidarity with the Charlie Hebdo staff (peace be upon them), and not with Dan Snyder, owner of the Redskins.  Are/were not both exercising the right of free speech, freed expression?  Have not both been assaulted (albeit in very different ways) by people who believe that they have the right not to be offended?

Does the difference lie in the nature of the assault?  Native Americans and others in the U.S. have used legal action and appeals to public opinion; the attackers of Charlie Hebdo used bullets and (earlier) firebombs.  That’s a valid distinction, surely, but does it justify us in ramping up editorial mockery of Islam – as is surely implied by the call for us all to “be Charlie," and not rationalize backing Snyder?  If somebody took out the Washington team's owner tomorrow, should we all start chanting “RedSKINS, RedSKINS?”

Or does the difference lie in the perceived basis for the offence?  Radical Islamists like those who attacked Charlie Hebdo apparently believe that they are acting on behalf of God/Allah himself when they do their dirty deeds, while Native Americans who object to the Redskins sobriquet base their objections on centuries of genocidal oppression.  Maybe that's a valid distinction, but it strikes me as a rather slippery one.  In an interesting coincidence, Muslims have been experiencing oppression by western colonial powers since about the same time Native Americans began to feel it – ca. 1492 AD.  And God/Allah is notoriously mum about his/her desires (except to some fundamentalist Christian mullahs, with whom he [definitely HE] apparently chats routinely), while history is by definition in the past.  The basis for rage among Islamists and some Native Americans in the present seems to come down simply to the fact that they are offended by what they view as disrespect for their spiritual/cultural beliefs.

So where do we draw the line?  Under what circumstances do we line up in support of free expression, and when do we support its suppression, whether through self-censorship or the acts of government?  I don’t deny that there are lines to be drawn; I self-censor myself all the time, and I imagine that so does anyone else who writes for public consumption.  But I worry about it, and I worry about populations and media that rally to slogans without thinking through their implications.  I’d be grateful for enlightenment.

Friday, December 26, 2014

Patricia L. Parker, 1943-2014

An expanded and corrected version of my recent Facebook posting.  Thanks to Emogene Bevitt, Pat Tiller and Cherie Lizarraga for improvements and corrections.

Patricia Lee (“Pat”) Parker, Chief of the American Indian Liaison Office in the National Park Service, died on December 16, 2014 at Holy Cross Hospital in Silver Spring, Maryland.  Dr. Parker was 71 years old.
Born Patricia Lee Sires in 1943, Pat lost her father, Lt. Howard E. Sires, in 1945 when he and his Navy Liberator bomber crew went missing in action over the South China Sea.  Her mother, Billie Louise Schnebly, then married Navy Chief Petty Officer Griffith H. Parker, Jr., who gave his name to Patricia and her sister Charlotte.
Dr. Parker studied European and American History at the University of California, Berkeley, where she received her bachelor’s degree and a California teaching credential.  She was a popular high school teacher in Marin County, California for almost a decade before beginning graduate studies at San Francisco State University.  Married at the time to attorney John Hickman, she received a Master’s Degree in anthropology and took part in archaeological and historical studies in various parts of California.  Following a divorce, she undertook postgraduate studies in anthropology at the University of Pennsylvania. 
Dr. Parker’s dissertation research investigated the effects of successive colonial legal systems on traditional land law in Chuuk, now part of the Federated States of Micronesia.  She lived in Chuuk for two years, learned the Chuukese language, and became deeply involved with Micronesian peoples and cultures.  She and Thomas F. King, who she married in 1977, helped mediate disputes between the U.S. government and Chuukese villagers over construction projects that threatened the villages’ natural and cultural environments.  They also coordinated major ethnoarchaeological data recovery work done by the villages in advance of those projects that proceeded after  agreements were reached.
Returning to the mainland, Parker received her PhD in 1983 from the University of Pennsylvania.  She and King became the parents of their son Thomas Sires King, and Parker began work for the National Park Service’s Cultural Resource Management program.  Initially hired to help set up the “Certified Local Government” program of financial aid to local historic preservation programs, Parker led a series of national meetings to define needs and directions, drafted program regulations and administrative procedures, and oversaw the program’s launch.  She then turned to helping Indian Tribes and Native Hawaiian groups participate more fully in the federal historic preservation program, again coordinating meetings throughout the country.  These resulted in a report to Congress entitled Keepers of the Treasures, published in 1990.  Congress responded in 1992 with amendments to the National Historic Preservation Act that expanded and clarified roles in the national historic preservation program for tribes and Native Hawaiian organizations. 
Perceiving the need for better relations between the National Park Service and American Indian Tribes, whose ancestral lands the Service in part controls, Parker proposed creation of a national American Indian Tribal Liaison Office.  When the Office was created, she became its Chief, a position she held until her death.  
Dr. Parker was a tireless champion for Native American cultural interests within the Park Service and beyond.  She was instrumental in securing a homeland for the Timbisha Shoshone in Death Valley and in resolving many other long standing issues between American Indian tribes, Alaska Native, and Native Hawaiian organizations, and the National Park Service.  Dr. Parker selected Charles Wilkinson of University of Colorado, Boulder, a national expert on Indian Law and Public Land Law, to be the primary instructor for a series of intensive 2-day workshops on the foundations of Indian law and policy.  From 1997 to 2014, she and Wilkinson held some 30 workshops throughout the country, training close to 1,000 people.  While Park Service managers and senior staff were the primary beneficiaries, tribal speakers were always featured; many tribal members and other Federal agency senior staff were also included.  Participants gained, often for the first time, an understanding of the special legal, fiduciary, and historical relationships that exist between tribes and the U.S. government.
Parker led a cultural resources tribal working group within the Park Service to better coordinate and communicate the programs and resources available to American Indians, Alaska Natives and Native Hawaiians.  This working group developed a website to share this information with tribes at .  The working group also authored a series of Quick Guides to share core information on key Park Service programs and the essential legal framework of the National Historic Preservation Program.  The Quick Guides are posted on the tribal website.
Parker was also known for her co-authorship of National Register Bulletin 38, on how traditional cultural places can be eligible for listing in the National Register of Historic Places.  This bulletin clarified the fact that the Register’s criteria are inclusive enough to recognize places of traditional value to tribes and other communities.  Eligibility for the Register requires Federal agencies to take such places into account in planning land use projects, and to consult about management alternatives with the communities that value them.  
Parker maintained her concern with Micronesian affairs, helping the Freely Associated States of Micronesia establish and manage historic preservation programs with National Park Service assistance.  This and her other work with indigenous groups led her to serve as an advisor to the International Council on Monuments and Sites (ICOMOS), UNESCO, and the World Bank. 
At her death, Parker was deeply involved in long term efforts to create a Lakota-administered Tribal National Park on the South Unit of Badlands National Park, and to finalize regulations establishing procedures for tribal access to traditional plant resources in National Park units to which they are historically linked.  She was also working to improve U.S. government consultation practices with American Indian tribes, Alaska Native groups and Native Hawaiian organizations concerning Indian Sacred Site management and other matters. 
Outside of work, Parker was a dedicated gardening enthusiast, with an elaborate garden at her home in Silver Spring, and was active in local horticultural organizations.  Beds of bulb flowers whose import from Holland she organized still grace parks and other public spaces in Silver Spring and nearby Takoma Park.  She was also talented at needlework; friends and family members will enjoy her sweaters, caps, socks, and artistic cross-stich for years to come.  Late in life she became an enthusiastic watercolor artist.  Early and late she traveled extensively both on her own and with family members and friends, visiting her ancestral landscapes in Sweden as well as China, Turkey, Jordan, Egypt, Cuba, Spain, Mexico, Australia, Fiji, Peru, the United Kingdom, Canada, the island states and territories of Micronesia, and every U.S. state.  Her last trip, in 2013, was a crossing of the Atlantic aboard the tall ship Star Flyer from Spain to Barbados, observing a total solar eclipse in mid-ocean.
Dr. Parker is survived by her husband, Thomas F. King and her son Thomas Sires King, his wife Monica, and granddaughter Olivia I. King, as well as by siblings Charlotte A. Lizarraga, Griffith H. Parker III, and Stephen J. Parker and their families, stepchildren Rachel T. King, Joshua M. King, and Madera K. Clark, plus step-grandchildren Emma and Duncan King, Noah and Jacob Richards, and Kayla and Tanner Clark.  She was predeceased by her younger sister, Juliet L. Somers, whose children, Peter Dale Somers and Juliet Somers-Barnes, survive her with their children.
Memorials are being planned and will be announced. In lieu of flowers or other tangible expressions of condolence, donations to the Native American Rights Fund ( are welcome.

Saturday, November 29, 2014


My post on “Entitlement, Service, and Dreams” has gotten considerable response, particularly on Facebook, where I’ve been taken to task for allegedly hating archaeology.  I’m tempted to encourage my critics to learn to read English – I think I’ve been pretty clear about the fact that I like archaeology fine, and enjoy doing it.  My objection is to treating it as though it’s the be-all and end-all of culture.  More specifically, I object to duping the world – or at least those segments of it that pay for environmental impact assessment (EIA) and “cultural resource management” (CRM) into thinking that if the archaeological impacts of the Megazap Solar Energy Project or the Toxicleak Pipeline have been taken care of, impacts on the cultural environment are under control.   

This objection leads me to have little sympathy for schemes like the Registry of Professional Archaeologists, or for kids who want to get paid more than they now get for doing archaeology-masquerading-as-CRM (AMACRM).  They’re parts of the problem, and they distract us from seeking solutions.

Since the “Entitlement” post has attracted some attention, I thought I should refer readers to a paper I wrote several years ago about my own now-regretted role in creating archaeo-CRM in California – it’s most readily accessed at

And I think I should also acknowledge that my guilt is really bicoastal.

Around the time my co-conspirators and I wrote the guidelines that helped make archaeology the heart and soul of “cultural” impact assessment under the California Environmental Quality Act (CEQA), I also became involved as a co-plaintiff with the Dry Creek Band of Pomo in a fight to stop construction of Warm Springs Dam in the Russian River valley.  We failed, but I succeeded in making myself unemployable in California – even then, one simply did not sue the folks who paid the CRM bill.  Luckily for me, however, the late Marian White, one of the driving forces behind the New York Archaeological Council (NYAC) had engineered a grant to help NYAC coordinate the state’s academic institutions in their conduct of contract archaeology.  Marian and NYAC hired me to administer the program, and later brought in the late Gary Berg – a student, colleague, and friend of mine from California – to assist me.

And one of the main things we did in the exciting year we spent in New York State – Gary in Albany, me in Buffalo – was to sue the U.S. Environmental Protection Agency (EPA), eleven cities across the state, and the State Historic Preservation Officer (SHPO) for violating Section 106 of the National Historic Preservation Act.

EPA was issuing grants to local governments to build sanitary sewer projects.  These projects naturally had the potential to mess up archaeological sites.  But EPA was “complying” with Section 106 simply by seeking “SHPO clearance,” and the SHPO – an office dominated by architectural historians – was cheerfully granting it, since the projects didn’t involve knocking down old buildings.

So, in the memorable words of an attorney/bureaucrat known to many of us, we “sued their eyes out.”  Raised the money, found a willing lawyer, filed suit.  And in the end, after a great deal of sturm und drang, reached a settlement with each local government in which they agreed to conduct archaeological surveys.

So just as in California, in New York I was at least in part responsible for generating the notion that archaeological survey is what you pretty much have to do if you’re planning a construction project.  And where our California guidelines had affected practice under CEQA, the New York case (Known as NYAC v. Train, Russell Train then being the EPA Administrator) helped make practice under Section 106 of NHPA equally archaeobiased.

So I’m partly responsible for the practices I deplore, and I suppose I’ve been trying ever since, in my various classes, publications, and practice, to make up for it by insisting that archaeology is NOT all there is to the cultural environment subject to effect by government actions.  I’ve promoted what seems to me the self-evident point that “cultural resources” include historic and cultural places that don’t contain a shred of archaeological evidence, and that aren’t necessarily old buildings either – places that communities value for their association with traditional beliefs, practices, and values.  And I’ve tried to remind people that culture can give value to things that aren’t places at all – wild animals, for instance, and fish, and birds.  That it can imbue water, plants, wind patterns, sounds and smells with cultural significance.  That culture can place great value on a dance form, a musical tradition, an indigenous language.  That “intangible” belief systems and traditional ways of life are inherently cultural.  And most importantly, that all these types of “resources” may be affected by governmental and government-regulated projects, and hence ought to be considered in EIA. 

I’ve failed.  That’s obvious in the abysmal state of EIA across the nation and worldwide, and it’s perhaps even more obvious – and galling – in the way so many of my colleagues go on practicing AMACRM, and encouraging their students to do the same.  

I don’t expect things to get better, and I don’t expect things to be improved by paying people more to do AMACRM, or by registering archaeologists as proficient in its practice.

Friday, November 28, 2014

Entitlement, Service, and Dreams

Some students in a university “cultural resource management “ (CRM) program were upset about my November 17 posting entitled “Contract Archaeology versus Plumbing,” (  In that post, I said that I didn’t see the registration of archaeologists, or increasing how well they’re paid, as a significant public policy issue.  The students invited me to visit their private chat page to explain myself, and I readily agreed. 

They asked me, in a nutshell, why I didn’t think “CRM” archaeologists ought to be registered like plumbers are, and make more money as a result.  Trying to be properly Socratic, I responded with a question.  What, I asked, is the social value of “CRM archaeology?”

I expected to get responses stressing how important it is to learn about the past, or take care of the environment, or control impacts on “cultural resources.”  These, I thought, might lead us into a fruitful discussion of just how these worthy interests are advanced by walking around on project sites looking for artifacts, digging holes, and in almost all cases assuring the world that proposed development projects won’t do any damage to those precious “resources.”  This, I figured, might lead on into a discussion of what “CRM” ought to be doing in order to advance such interests.

But the immediate responses I got were not at all what I expected.  Instead, they boiled down to: “The value of CRM archaeology is that it can (if if just will) pay me a good salary so I can support my family.”

Later on, I did get some rather more altruistic, less self-centered notes, but the opinion-setters in the group seemed to feel quite justified in saying that what they did was worth doing because it could, if they got paid well enough, make them comfortable.

I found this rather startling, and said so.  The reaction to this, on the whole, was not positive.  One fellow, who turned out to control access to the site and shortly excluded me from it, contributed to the discussion mostly by posting images of himself (I presume it was he) making ugly faces at me.  To this, higher education has evolved.

The notion that “X activity is good for society because it can (and should, dammit) make me comfortable” was so surprising to me that I began to wonder why my perceptions are so out of synch with those of the younger generation.  I try to resist geezer-talk (“Why, Sonny, back in my day…..”), but it had just never occurred to me to equate benefit for myself with benefit for society, and I had to think that this had something to do with the passage of generations.  “Back in my day” we distinguished between social benefit and personal gain, and rightly or wrongly took it for granted that (a) society didn’t owe us a living, but that (b) we owed society some kind of service.  As he often did, John F. Kennedy summed it up pithily: “Ask not what your country can do for you, but what you can do for your country.”  We might not all believe that our country was worth all that much devotion, but I think it used to be pretty widely believed that we had a responsibility to humanity, society, the world, the planet.  Conversely, I don’t think I ever used to hear or read anyone proposing that humanity, society, the world or the planet had any particular obligation to take care of us.

What, I wondered – and still wonder – has changed?  Is it rampant consumerism?  Or is it that we’ve become so fixated on civil rights that we’ve forgotten civil responsibilities?  Is it that every politician claims to be “fighting for YOU?” 

I don’t have an answer; I’m still puzzled, still mulling it over.  But the exchange with the students reminded me of one very specific policy decision, made back when I was a grad student, that I wondered about at the time, and still wonder about today.  That was the decision to end the draft.

Back in my day, sonny, it was understood that if nothing else, you (if you were male and reasonably fit) owed society, in the form of your country, a few years of service under arms.  Our country’s sad adventure in Southeast Asia made that understanding seem misguided, I suppose; whatever exactly the cause was, we gave up the draft in 1972. 

I wonder if throwing out the draft – perhaps combined with some of those other factors I alluded to earlier – led us toward thinking less and less about what we could/should/had to do for the country/society/the world.  Did this, in turn, lead us to flip the equation, conclude that – as my student interlocutors seem to believe – the world owes us a living?

I don’t know, but all this mulling made me particularly alert to an editorial in this morning’s Washington Post by David Ignatius about the “Franklin Project” at the Aspen Institute – see  The Franklin Project, according to its website, would “improve citizenship by giving every young person in America the opportunity to do a service year.” “Sometime between the ages of 18 and 28,” it goes on, “the young person would do a fully paid, full-time year of service in one of an array of areas from conservation to education and everything in between.” 

It’s not the draft; the proposal seems carefully formulated to emphasize the voluntary character of the “service year” – and that in itself is a bit surprising.  Have we become so disenchanted with the idea of service that we have to make it crystal clear that gee, kids, you don’t have to do this?  I guess we have.

But still, it seems to me like it wouldn’t be a bad idea to start discussing service, and obligation, and who really owes who what. 

All this led me back to thinking about CRM, and the environmental impact assessment (EIA) system within which it’s embedded.  As assiduous readers of this blog know, I think that system has become fatally corrupted.  It occurred to me that one basis for this corruption, and for the puzzling fact that most people involved in the system seem to accept it as natural, is precisely the premise that something is a good thing if it allows you to make a living – that it need meet no other standard, no other criterion.

This, in turn, led me to wonder whether something like national service might provide the answer that I’m never able to come up with when someone asks: “OK, King, so the EIA system is corrupted, what do you want to DO about it?”  I find myself dreaming of some sort of EIA Service that would assess the impacts of proposed construction and land use projects in the public interest, rather than in the interests of those paying for and profiting from them.  Putting people like my student interlocutors to work not for the change agents, and not just to enrich themselves and the companies that employ them, but for the public, the environment, the future. 

Probably a dumb idea, or at least an idea whose time has gone before it could come.  We are probably way, way too far down the road toward self-satisfaction and comfort-seeking for anything like this – or even the seemingly rather filmy notions of the Franklin Project – to gain traction.  But dreaming of such things helps fend off the depression that's generated by experiences like my encounter with the students, and for such dreams I’m thankful.