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Thursday, November 24, 2016

RE-ANNOUNCING: THE HERITAGE AFTER TRUMP AWARD


Back on November 11, I announced creation of the “Heritage After Trump” award. Two weeks having passed, and a few loose ends having been gathered together, I want to post about it again and encourage everyone who’s interested to consider competing for the US$1,000.00 award.

Below is what I said on November 11.

Suppose that the Trump/Pence administration is successful in doing away with U.S. environmental impact assessment laws and regulations, including the National Environmental Policy Act (NEPA) and the National Historic Preservation Act (NHPA). We have no more environmental assessments or impact statements, no more Section 106 review, no more State or Tribal Historic Preservation Officers, no more Advisory Council on Historic Preservation or National Register of Historic Places. Of course, this probably isn’t what the TrumpPencers will do – instead they’ll just bully the government’s employees into making the laws meaningless – but for simplicity’s sake suppose everything gets swept away. 

Suppose further that the voters turn the rascals out after a few years, and we are in a position to rebuild a national program of cultural heritage impact assessment and management. What should we do?

For reasons that I’ve discussed in more books and journal articles than anybody cares to recall, I don’t think we ought just to put the “old” systems back in place. We ought to recognize that those systems have deficiencies, some of which actually make them more vulnerable than they need be to attack by Trump-types, while some simply make them not very helpful in protecting the aspects of the environment to which people attach cultural value. 

So, I’m offering a thousand bucks (US$1,000) to the person, consortium, group, organization, gang, or crowd that produces the best written description of the cultural heritage program the United States should put in place once the Trump phenomenon has run its course. 

“Best” means that the program is:

·         Inclusive both in terms of the tangible and intangible environmental variables it addresses and the people, communities, and groups whose values are addressed;

·         Minimally bureaucratic – not relying more than absolutely necessary on government oversight bodies and documentation;

·         Consultative – involving open but results-oriented dialogue among participants;

·         Simple enough to make it accessible to and usable by ordinary citizens;

·         Open to use by and for all kinds of citizens;

·         Just and equitable in its treatment  of people, other life-forms, and communities;

·         Reasonable in terms of time and financial costs imposed on all involved; and

·         Balanced in relation to other needs, values, and priorities.

Describe your proposed program in ten typewritten pages or fewer, and send it as an attachment to email to TomKing106@Gmail.com. 

Proposals will be judged by a small team of knowledgeable people that I’m currently assembling, and the award will be announced and made on inauguration day, January 20th, 2017.

That remains the description of the competition. I’ve now assembled a small group of experts – none of them members of the existing historic preservation, environmental impact assessment, or “cultural resource” establishment, and all thoughtful, wise people – to help me judge entries and select a winner. Should there not be a winner, the thousand bucks will go to a charity selected by the judges. To safeguard their privacy, I’m not going to reveal the names of the judges.

Based on what I’ve seen so far being bandied about on Facebook by people thinking about the prize, I think I need to stress that you should NOT think of existing institutions as immutable or necessary. About the only thing I can think of that’s good about The Trumpeting is that it may blow away a lot of stuff that’s impeded our having a world-class cultural heritage program. Among the stuff that may get blown away, for good or ill, are the State and Tribal Historic Preservation Officers, the Advisory Council on Historic Preservation, the Section 106 process, the Council on Environmental Quality and its regulations, large chunks of the Environmental Protection Agency, and hunks of the National Park Service. I suggest that you not assume any of these to be necessary parts of your imagined heritage program. Think outside the box.


The deadline for submissions – to give the judges time to cogitate on and discuss them, is January 1st, 2017.  So you have a month and change; good thinking!

Monday, November 14, 2016

CRM and the Rise of the T-Rump

No, I’m not going to accuse cultural resource management, that quaint and probably soon-to-vanish professional practice, of causing or even much facilitating the successes of Donald Trump and his merry band. I think, though, that before this dismal moment passes and everybody moves on to other fields of endeavor, we ought to think about whether and how CRM practice has reflected the broad social phenomena that made Trump’s victories (thus far) possible.

Many commentators are commenting – rather too late – that Trump’s rise was not wholly a matter of racism, sexism, xenophobia, and selfishness, though obviously all those played their parts, and will continue to. Trump also tapped into a strong and not-unjustified feeling in what’s left of the U.S. middle class that the nation’s elites are scornful of the concerns, beliefs, values and fears of “the common people.” Those who voted for him will doubtless soon find out that the T-Rump is even more scornful, but he looked different, he looked like he’d shake things up, kick some ass, and a lot of people – about a quarter of those eligible to vote, apparently, and a strategically situated almost half of those who actually voted – thought that some elite ass needed kicking.

A small collection of those asses, I think, comprise those of CRM practitioners, both in government and in the “industry.”

CRM has become a very elitist enterprise – maybe always has been. This will doubtless be disputed by the rough-tough archaeologists in its ranks, but I think it’s obvious. Although the laws under which we work were certainly enacted in the expectation that they would be good for the people who vote and pay taxes, CRM practitioners, on the whole, are concerned only with finding, documenting, and maybe occasionally preserving buildings, sites, districts, structures and objects that meet esoteric criteria promulgated by a small coterie of professionals in the National Park Service. To many if not most practitioners, how local people feel about those places is irrelevant; what matters is whether a professional thinks they meet the criteria. Similarly, it doesn’t much matter how regular people feel about a proposed project’s; what matters is what an agency official and a State Historic Preservation Officer decide about whether and how the criteria of adverse effect apply.

So you think your farm, or your neighborhood, is culturally important and worth preserving? Well, maybe OK, but only if you can persuade the State Historic Preservation Officer (SHPO) that it is. Value your view down the street or across the valley? Sorry, it’s not part of what the SHPO or the National Park Service thinks makes the street or valley eligible for the National Register, so we can’t deal with it.

It cuts both ways, of course. Not much interested in preserving 20th century tract houses or blocks and blocks of warehouses? Sorry, they’re eligible for the National Register so we really need to preserve them – or at least go through a lot of tedious processes before taking them down. Don’t want to preserve those inefficient, ugly old windows? Sorry, they’re part of the historic fabric. Think it was maybe a mistake to build that brutalist addition on the old courthouse? Too bad, it’s on the Register now, so we gotta keep it.

And if you’re culturally invested in something that’s not a building, site, district, structure or object, you’re utterly out of luck. Value your multi-generation cattle-ranching lifestyle? Tough; your damn cows are tearing up landscapes that need to be made safe for hikers from the city, and sad to say, your lifestyle just isn’t eligible for the National Register. Want to protect free-ranging burros or wild carp? Sorry, they’re not “places,” so we can’t deal with them.

Of course, we elite federal and state officials and pricy consultants will “consult” with the unwashed masses, but only about stuff that fits into our world-view, according to our systems. And we have come to understand “consultation” not to mean dialogue or discussion, but simply “informing,” “educating,” “listening” and getting “input” – all of which can then be ignored.

All this is, as some wise pundits have lately pointed out, exactly the kind of behavior that makes people become sick of the authorities and prepared to toss the bums out – regardless of who or what replaces them.


If we survive the rampage of the T-Rump (I doubt if we will, perhaps at all), I hope we can take some lessons and apply them to all our endeavors, including those that involve us with “cultural resources.” We need to recognize that everybody’s got culture, whose “resources” are only sometimes the kinds of things that CRM professionals appreciate, but all of which deserve consideration. And that professional values don’t by default trump (sic) those of other people. And that the “consultation” we say we do isn’t consultation at all if it’s not dialogue, aimed at achieving some kind of meeting of the minds. 

All minds.

Friday, November 11, 2016

The “Heritage After Trump” Award

Suppose that the Trump/Pence administration is successful in doing away with U.S. environmental impact assessment laws and regulations, including the National Environmental Policy Act (NEPA) and the National Historic Preservation Act (NHPA). We have no more environmental assessments or impact statements, no more Section 106 review, no more State or Tribal Historic Preservation Officers, no more Advisory Council on Historic Preservation or National Register of Historic Places. Of course, this probably isn’t what the TrumpPencers will do – instead they’ll just bully the government’s employees into making the laws meaningless – but for simplicity’s sake suppose everything gets swept away. 

Suppose further that the voters turn the rascals out after a few years, and we are in a position to rebuild a national program of cultural heritage impact assessment and management. What should we do?

For reasons that I’ve discussed in more books and journal articles than anybody cares to recall, I don’t think we ought just to put the “old” systems back in place. We ought to recognize that those systems have deficiencies, some of which actually make them more vulnerable than they need be to attack by Trump-types, while some simply make them not very helpful in protecting the aspects of the environment to which people attach cultural value.

So, I’m offering a thousand bucks (US$1,000) to the person, consortium, group, organization, gang, or crowd that produces the best written description of the cultural heritage program the United States should put in place once the Trump phenomenon has run its course.

“Best” means that the program is:

·         Inclusive both in terms of the tangible and intangible environmental variables it addresses and the people, communities, and groups whose values are addressed;

·         Minimally bureaucratic – not relying more than absolutely necessary on government oversight bodies and documentation;

·         Consultative – involving open but results-oriented dialogue among participants;

·         Simple enough to make it accessible to and usable by ordinary citizens;

·         Open to use by and for all kinds of citizens;

·         Just and equitable in its treatment  of people, other life-forms, and communities;

·         Reasonable in terms of time and financial costs imposed on all involved; and

·         Balanced in relation to other needs, values, and priorities.

Describe your proposed program in ten typewritten pages or fewer, and send it as an attachment to email to TomKing106@Gmail.com.


Proposals will be judged by a small team of knowledgeable people that I’m currently assembling, and the award will be announced and made on inauguration day, January 20th, 2017.

Saturday, September 03, 2016

ENVIRONMENTAL PRACTICE Issue on "Cultural Resources"

The latest issue of Environmental Practice (18:3) – the journal of the National (U.S.) Association of Environmental Professionals – has just come out, focusing on “cultural resources” and with the dubious distinction of having me as its rather last-minute guest editor. It can be accessed at http://journals.cambridge.org/action/displayJournal?jid=ENP.

Articles include:

Wild Horses Are Cultural Resources, by Kathleen Hayden

Assessing Archaeological Resources, by Michael J. Moratto

Non-Disruption and Non-Emissions as Cultural Resources, by Ned Kaufman

Integrating Cultural Impact Assessments into Environmental Analysis, by Claudia Nissley

Religious Resources and Environmental Management in Ghana, by Victor Selorme Gedzi,Yunus Dumbe & Gabriel Eshun

Heritage Dispatches from the American Approaches of Hell: Public Housing, Historic Preservation, and Environmental Impact Analysis, by Fred L. McGhee

Cultural Heritage, Community Engagement, and Environmental Impact Assessment in Australia, by Ian Lilley

Credible Cultural Assessment: Applied Social Science, by Patricia A. McCormack

Indigenous Traditional Cultural Places in Environmental Impact Assessment: The Case of the Ch'u'itnu Watershed, by Heather Kendall-Miller and me

Impacts on Maritime Cultural Resources: Assessing the Invisible, by Sean Kingsley

The National Park Service Visual Resource Inventory: Capturing the Historic and Cultural Values of Scenic Views, by Robert G. Sullivan & Mark E. Meyer

Addressing the Public Outreach Responsibilities of the National Historic Preservation Act: Argonne National Laboratory's Box Digital Display Platform, by Daniel J. O’Rourke, Cory C. Weber & Pamela D. Richmond, and

Cultural Resources in Environmental Impact Assessment, by me (an introductory piece that wound up near the end of the issue, but who am I to quibble?).

Friday, September 02, 2016

Some Lessons From Appalachian Traditional Cultural Places

I’ve posted a paper on Academia.edu entitled Traditional Cultural Places in Appalachian Virginia and The Mountain-Valley Pipeline. It’s at www.academia.edu/s/d7c73268e4/traditional-cultural-places-in-appalachian-virginia-and-the-mountain-valley-pipeline.

I prepared the report at the request of the Greater Newport Rural Historic District Committee – whose National Register-listed district is one of several identified rural historic districts transected by the route of the proposed Mountain Valley Pipeline (MVP) across the Appalachians. My charge was specifically to see whether it looked like the districts involved are traditional cultural places” (or properties) – that is “TCPs” – per National Register Bulletin 38.

For those not directly affected by the proposed pipeline, the most interesting things about what I learned may be the following:

1.    I found the National Register nomination documentation to be largely unhelpful in figuring out whether the districts were TCPs;

2.    I also found it to be of little use in ascertaining whether the districts were “rural historic landscapes” per National Register Bulletin 30;

3.    In fact, I found the documentation to be unenlightening even about why the districts were viewed as districts; the documentation was overwhelmingly about the individual buildings, structures and sites within the districts, not about the districts as landscapes, or as the “concentrations” and “linkages” to which the Register’s definition of “district” refers.

4.    Luckily, some very interesting and helpful studies had been done quite outside the context of historic preservation, about the “cultural attachment” that people in the area feel for their landscapes. Applying the results of these studies to the districts, it became clear that they – or perhaps more likely a landscape embracing all or some of them – is indeed eligible for the National Register as a TCP.

Why does this matter, since most of the districts involved have either been listed on the National Register or authoritatively identified as eligible for it, hence entitling them to consideration under Section 106 of the National Historic Preservation Act? I think it matters in at least two ways:

First, when one looks at a “district” nomination and finds a list of specific buildings, structures and sites, with little or no treatment of the spaces around them, it’s pretty easy to design a new project – like a power line or pipeline – right through the district and think you’re having no adverse effect on it, because your project doesn’t knock down or dig up a “contributing” building, structure or site. You may give some consideration to things like visual effects, but only on those “contributing resources.” The whole idea of the “district” as an entity gets lost.

Second, when a district is characterized only with reference to its constituent buildings, structures and sites – with their significance defined, of course, by historians, architectural historians, and archaeologists – one has no basis for appreciating what makes the district important to the people who live there, work there, or otherwise experience the place. The significance of the district to the people who value it is effectively submerged. When a question arises about a planned project’s potential effects on the district, the concerns of those people can easily be denigrated, as long as one can assure the world that one is not going to muck with the architectural qualities of a building/structure, or the archaeological values of a site.

So – the lesson I take away from this experience, and that I suggest to others, is: if you’re interested in preserving a place that’s important to you, and are encouraged to nominate it to the National Register or offer some representation about its eligibility, think carefully about what you call the place. If you call it a “rural historic district,” you may wind up with something that doesn’t help you much in terms of ensuring that the values you ascribe to the place are given due attention. If you call it a rural historic (or cultural) landscape or TCP you’re probably better off, but even then, pay careful attention to how whoever compiles the documentation describes the place. “Preservation professionals” may automatically slip into architectural and archaeological modes of thought when assigned to describe the historic and cultural qualities of a place. If you use such professionals, somebody needs to be looking over their shoulders to remind them to attend to the spaces around the buildings, structures, and sites, and particularly to listen to the people.


And if you’re a preservation professional (or non-professional) responsible for writing up a place with reference to its National Register eligibility, get familiar with the “cultural attachment” literature – which has mostly been produced with little or no (or ill-advised) reference to historic preservation, but is very, very relevant. Several key sources are cited in my paper, which, again, can be found at www.academia.edu/s/d7c73268e4/traditional-cultural-places-in-appalachian-virginia-and-the-mountain-valley-pipeline

Thursday, September 01, 2016

A Traditional Cultural Place for All U.S. Citizens?


Traditional cultural places (TCPs – see https://www.nps.gov/nr/publications/bulletins/nrb38/) are ordinarily found eligible for the National Register of Historic Places because of their association with the traditional cultural values and believed histories of local communities, Indian tribes, Native Hawaiian groups, and other relatively localized groups. But the other day, someone asked me, more or less out of the clear blue sky, if I could imagine a place that would be a TCP for all citizens of these United States. I was frankly flummoxed. In a nation as diverse, even fragmented, as the U.S., could there be such a place?

Then I was privileged to attend a meeting of the National Mall Coalition (See www.nationalmallcoalition.org and https://www.facebook.com/NationalMallCoalition/?fref=ts) – a group that’s struggling to keep the National Mall in Washington DC as a place for use and enjoyment by all people, and to address its many management problems. And of course, I realized, with a smack to the head, that the National Mall is, precisely, a national TCP. Stretching from Capitol Hill past the Washington Monument to the Lincoln Memorial, and from the White House to the Jefferson, studded with monuments and memorials to great and not-so-great people and events in the nation’s shared history, home to multiple museums, including the National Museum of the American Indian (http://www.nmai.si.edu/) and now the National Museum of African-American History and Culture (https://nmaahc.si.edu/), the National Mall is, precisely – to paraphrase National Register Bulletin 38 – a place whose “significance (is) derived from the role the property plays in (the national) community's historically rooted beliefs, customs, and practices.” In all their chaotic, creative diversity.

And I learned, too, that the National Mall suffers from many of the same sorts of conflicts that – sometimes inevitably, sometimes outlandishly – trouble other TCPs, especially largish landscapes. Just as at, say, the confluence of the Colorado and Little Colorado in the (National Register-eligible TCP) Grand Canyon (c.f. http://savetheconfluence.com/), there are conflicts between public use and quiet contemplation. Just as at innumerable TCPs administered by federal agencies across the country, the Mall is managed by an agency that can’t seem to get its arms around the fact that the public in all its diversity ought to have anything to say about its administration. The Mall’s open space is administered mostly by the National Park Service (NPS), which has apparently decided that keeping its grass green is the highest priority. This justifies NPS in giving the boot to events like the Library of Congress’s annual Book Festival (http://www.loc.gov/bookfest/), which used to attract (horrors!) shoe-clad readers to tromp on the tender shoots. Will the Smithsonian Folklife Festival (http://www.festival.si.edu/) be next? Only time and NPS will tell.

It also turns out that the National Mall, like other TCPs, suffers from being the subject of a National Register nomination whose documentation doesn’t attend to its traditional cultural significance. Indeed, the nomination apparently doesn't even give much consideration to the Mall’s organization as the “significant concentration, linkage, or continuity” that in theory makes it qualify as a historic district. (See https://www.nps.gov/nr/publications/bulletins/nrb15/). Allegedly, NPS doesn't even regard the L’Enfant and McMillan Plans that defined the Mall’s development in the 19th and early 20th centuries (https://www.nps.gov/nr/travel/wash/lenfant.htm) as crucial contributing elements to its current Register significance, and hence worthy of consideration in decision making.

And as usual with TCPs – and historic places generally – management of the National Mall seems to have little patience for real consultation with those who ascribe cultural value to it. Meetings, yes, letters full of nice words, sure, but actually sit down and hammer out compromises between, say, active public use and keeping the grass green? No. This was obviously a source of considerable frustration for Coalition members, whose expressions echoed those I’ve heard from Indian tribes, Native Hawaiian organizations, and citizens’ groups across the nation and around the world with reference to their own TCPs.

Finally, the National Mall – like other TCPs and despite lying right under the noses of Congress and the President – has serious unaddressed management problems, notably tour bus parking, vehicular congestion, and the danger of flooding -- not only by the Potomac River but, even more devastating, as was seen in 2006, by stormwater runoff from higher elevations into low-lying Constitution Avenue museums and public buildings. The Coalition has an intriguing plan for dealing with all three problems (http://www.nationalmallcoalition.org/innovation/resilience-to-ensure-the-future/); we can hope that someone in authority will give this plan the attention it deserves, but I’m told that only the Corps of Engineers – rightfully alert to such issues but powerless to do anything without a local request or congressional direction – has shown any leadership. At least it’s nice to be able to say something nice about the Corps for a change.

I’m told that NPS is considering a revised National Register nomination for the National Mall. Although I’m always dubious of the utility of such nominations, in this case it might be an opportunity to get serious attention to the Mall’s traditional cultural qualities, as a basis for its more rational management.


Sunday, August 14, 2016

US Fish and Wildlife Service "Cultural Resource Management Policy"

I know, my critics will say I'm on a roll and just can't stop myself. But gee, the hits just keep on coming.

Below, a letter that went out today to the Secretary of the Interior about what her minions in the Fish and Wildlife Service are up to. I do not expect it to accomplish anything; I may (or may not) get a letter from some dweeb in the Secretary's office thanking me for my input and assuring me that the Secretary and the Obama administration are so, so interested in public input, and then they'll pass the letter to another dweeb in Fish and Wildlife to file and forget. But one has to do SOMETHING.

And I know it's the same old thing. That damned brick wall just keeps standing there, taunting the head.

August 15, 2016
The Honorable Sally Jewell
Secretary of the Interior
1849 C Street, N.W.
Washington DC 20240

Madam Secretary:

I am writing to object in the strongest terms to something purporting to be the “policy” of your Fish and Wildlife Service (FWS) regarding “cultural resources,” posted recently on the Worldwide Web at https://www.fws.gov/policy/614fw1.html.

I am perhaps suffering under a misapprehension, but I thought that the Administrative Procedures Act required interagency and public review of such documents before their issuance. I see no evidence that this “policy” was subjected to such review, and cannot believe that if it had been, it would have survived to appear in its present form. As it stands, it appears to be almost deliberately designed to lead FWS officials into noncompliance with at least the National Environmental Policy Act (NEPA) and Section 106 of the National Historic Preservation Act (NHPA). I presume, however, that no ill intent was involved; rather, I suspect that a group of inexperienced and ill-educated FWS employees came up with what they thought was a good idea, and somehow got their superiors to sign off on it.

Their superiors should seriously re-think their approvals.

The “policy” is so riven with errors and misleading statements that I cannot begin to take the time to identify them all, but let me just point out a few low points:

1.    Conflation of the NEPA term “cultural resource” with the NHPA term “historic resource.” “Cultural resources” are among the “unique characteristics” of a potentially affected area that the NEPA regulations at 40 CFR § 1508.27(b)(3) require an agency to consider in judging the significance of a proposed action’s potential effects. Since the term is not defined, one is left to assume that it means “resources” (useful things) whose value is somehow “cultural.” The term “historic resource” is also used without definition in 40 CFR § 1508.27(b)(3), apparently to mean “resources” that are somehow “historic” (i.e. old). The same term was defined more narrowly by Congress at Section 301(5) of the NHPA to mean places included in or eligible for the National Register of Historic Places maintained by your National Park Service (NPS).

The FWS “policy” conflates the terms, effectively saying that if something is not a NHPA historic resource – or an artifact or old document -- it is not a NEPA cultural resource, and therefore presumably need not be considered under either statute. Actual direction about how to recognize and deal with “cultural resources” is overwhelmingly oriented toward historic resources; after an initial mention, all other kinds of “cultural resources” are forgotten.

This defines rather substantial parts of the cultural environment out of existence. Apparently to whoever dreamed up the FWS “policy,” such cultural institutions as the hula in Hawai’i and the practice of decorating graves in the southeastern United States are not “cultural resources.” More directly relevant to the FWS mission, can one seriously say that bison are not cultural resources from the perspective of a Plains tribe? That salmon are not cultural resources for tribes of the Northwest? That wild horses and burros are not cultural resources despite Congress’ declaration in the Wild and Free-Ranging Horses and Burros Act of 1971 that they are “living symbols of the historic and pioneer spirit of the West?” That eagles are not cultural resources for a great many tribes, and indeed for the United States?

By essentially writing off any “cultural resource” that is not an “historic resource” (or maybe an artifact or document), your employees in FWS are excusing their agency from considering its impacts on cultural resources that are not pieces of real estate eligible for the National Register. I hope that you do not support such a narrow, crabbed interpretation of any Interior agency’s responsibilities.

2.    Exclusion of land acquisition from NHPA Section 106 review. The “policy” “reminds” readers that “land acquisition is not an undertaking with the potential to affect historic properties” – meaning that it does not require review under Section 106 of the NHPA and its regulations (36 CFR Part 800). Has this conclusion been embodied somewhere in formal Department of the Interior policy, as the notion that one should be “reminded” of it suggests? If, for example, cattle ranching is a traditional land use of long standing in Wildherd County, Nevada, such that many working ranches there may be eligible for the National Register, and if FWS proposes to acquire such ranches for purposes of improved sage grouse habitat management, can you seriously contend that this acquisition has no potential effect on historic properties? If so, I suggest that someone needs to lay out the logic on which such a contention is based, and subject it to public and interagency review.

3.    Bias in favor of “experts” and against the public. The “policy” asserts that “only a subject matter expert may identify a property as historic.” Based on some fairly substantial experience, I am not aware of any law, regulation, or even general policy guideline (other than the one discussed here) that could serve as a basis for this assertion. Expert opinion is sometimes needed to determine what is historic, but anyone can nominate something to the National Register or propose that something is eligible for it. Particularly with respect to “traditional cultural places” – a category of “resource” explicitly listed in the “policy” – NPS guidance stresses that evaluation must be done in close consultation with those who value such places, who are not ordinarily “subject matter experts” as defined in the “policy” (i.e. professional archaeologists, historians, etc.). The NHPA Section 106 regulations, at 36 CFR § 811,4(c)(1), requires that agencies “acknowledge that Indian tribes and Native Hawaiian organizations possess special expertise in assessing the eligibility of historic properties that may possess religious and cultural significance to them.” The geniuses who put together the FWS “policy” apparently think that such expertise exists only among members of tribes and Hawaiian groups who are also archaeologists, historians, or architectural historians.

Seriously, Madam Secretary, you are presumably paying people to put out stuff like the FWS “policy;” you really ought to insist that they do their jobs, and not leave it to unpaid outside critics like me to call them on their mistakes.

Please have your people withdraw the “policy” and rework in in consultation with people who have some idea what they are talking about, including relevant other federal agencies and the public.


Sincerely,

/s/ Thomas F. King