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Monday, April 13, 2020


I’ve terminated my independent consulting firm (Thomas F. King PhD LLC, what a dippy name) and with gratitude become an employee of Algonquin Consultants, There are a number of reasons for this move, mostly having to do with my antiquity and my respect for Algonquin’s work.

I’ll continue to provide consulting services in heritage/cultural resource management and related stuff, but will do so through Algonquin and will have the assistance and collaboration of Algonquin’s talented staff. I'll reman physically embedded in the suburban DC swamp.

Friday, November 15, 2019

I Was an Unethical Jerk Back in 1980

I got a note awhile ago from a respected colleague – actually a series of notes, sniping at various things I’d written, and when I responded that s/he seemed to have gotten up on the wrong side of the bed, s/he revealed that his/her attacks were in retaliation for something I’d done in 1980. In that year, allegedly, I reviewed an archaeological research design by my colleague and pronounced it unworthy of an expenditure of federal dollars. But when the federal sponsor went ahead and funded the work, I praised the result. And – here was the crux – at no time did I contact my colleague to discuss the matter. This, he/she said, was deeply unethical on my part.

These kinds of allegations bother me, though I generally yawn at arguments about ethics. I was further bothered in this instance by the fact that I don’t remember the case. In 1980 I was about a year into my tumultuous decade as overseer of compliance with Section 106 of the National Historic Preservation Act (NHPA) for the Advisory Council on Historic Preservation (ACHP). I was busy with cases all over the country, and with oversight of three offices full of very dedicated civil servants – among many other duties.

I do recall that in that period, I suffered from the conceit that I might be able to influence U.S. government agencies to fund really responsible, well-formulated archaeological research to mitigate the impacts of their activities, so it’s quite likely that I was writing pretty critical reviews of the ostensible research designs that occasionally crossed my desk. Mea culpa for that.

But my colleague’s particular gripe seems to be that I didn’t contact her/him to discuss the matter. This is the element of her/his complaint that’s worth attention here, because it reflects not only on me 40 years ago but on every overworked, underpaid project reviewer at the ACHP and in State Historic Preservation Offices (SHPOs) and Tribal Historic Preservation Officers (THPOs) across the nation today. Was it unethical for me to give my colleague’s research design a raspberry without talking with her/him about it?

I’ll be happy to receive comments, but I’ll tell you what I think.

I think my colleague needs to recognize that my responsibility back in 1980 – and the responsibility of my equivalents in the ACHP, SHPOs and THPOs today – was and is first and foremost to the agencies who asked for our official comments. It was and is they who sought or seek our advice, and it’s to them that we need to provide it. And we need to provide it based on a rational review of the information in hand; it is not our responsibility to go nosing about to find out what is “really” going on. Arguably, in fact, it would have been quite improper – unethical, if you will – for me to have rung up my colleague and said “hey, colleague, your research design really stinks, but is something else going on that I should know about?” My colleague’s proposal should have stood on its own merits; it was not my job to ferret out the truth underlying its verbiage.

Reviewers in agencies like the ACHP, SHPO, and THPO have lots of stuff to do. Don’t expect them to give your paperwork the same loving care you lavish on preparing it.

Monday, June 11, 2018

Saying Goodbye to Dick and Sam

I was sorry to learn recently of the passing of Richard (Dick) Jenrette and Alexander (Sam) Aldrich, on April 22, 2018 and July 19, 2017 respectively.

Each man had many accomplishments; you can read Dick’s bio at and Sam’s at I knew them both as Chairmen of the Advisory Council on Historic Preservation during the turbulent 1980s. And yes, both wanted to be called by their first names.

Dick was appointed to the chair by President Jimmy Carter. The rather legendary founder and long-time head of the Wall Street investment firm Donaldson Lufkin Jenrette, Dick was a solid old-school preservationist from the Carolinas. He employed creativity and strategic sensibilities to do well on Wall Street, and he played important roles in the National Trust for Historic Preservation.

Dick and the Council’s Executive Director, the late Bob Garvey (also a Carolinian), saw eye-to-eye on most things, and they navigated the Council through the difficult transition into Ronald Reagan’s administration. Specifically, Dick – having been appointed only a short time before Reagan’s election and thus having time on the clock before the new president could replace him, politely declined the White House’s invitation to tender his resignation. He let it be known, though, that he would resign if the new president would appoint a replacement who – unlike Reagan’s Secretary of the Interior, James G. Watt – was not devoted to unraveling the last (then) twenty years or so of environmental and historic preservation law and regulation. The White House fulminated, but eventually agreed to appoint Sam.

Sam had Rockefeller family connections, and a long history of work in preservation in New York State, particularly in and around Saratoga Springs. He was charming, politically astute, and often a lot of fun to work with.

As head of the Advisory Council’s Section 106 shop, I was somewhat insulated from the Chairmen, but I very much respected both Dick and Sam. Dick oversaw our bruising encounters with the Department of Housing and Urban Development and the city governments of New York and Detroit over the Morosco Theater (New York) and Hudson’s Department Store (Detroit). We failed to achieve meaningful preservation of anything in either case – both buildings were demolished – but we tried hard to make sure that local preservation interests had such opportunities as realpolitik allowed to influence government decision-making. In the Morosco Theater case, one of my letters was accurately characterized in the media as “the plaintive wailings of an embattled bureaucrat;” in the Hudson’s case, Detroit mayor Coleman Young let my colleagues and me know in no uncertain terms that no honky bureaucrats were going to stand in the way of his redevelopment schemes. And he was right, but we in the trenches appreciated the support and insulation from the White House that Dick gave us.

Sam was much more part of my life, overseeing the rework of the Section 106 regulations and the complex struggle to keep the Department of the Interior from emasculating the Council, un-funding the State Historic Preservation Officers, and generally wreaking havoc with all aspects of federal historic preservation other than tax credits; those were OK, since they benefitted well-to-do property owners. It was also on Sam’s watch that we began serious interactions with Indian tribes. Highlights I remember are the Council meeting on the Navajo Reservation as guests of the Navajo Nation and our consultations with the National Congress of American Indians, Native American Rights Fund, and American Indian Movement about how tribal historic properties and concerns (notably about ancestral graves) should be addressed in Section 106 review. Though Sam had little personal acquaintance with tribal concerns, he had marched from Selma to Montgomery with Martin Luther King, and was unfailingly considerate and respectful of tribal and minority concerns.

Both Dick and Sam, of course, interacted with the Council staff through our inimitable executive director Bob Garvey, without whose energy, intelligence, and political wile nothing would have been possible.

Sam was eventually succeeded by Cynthia Grassby-Baker, who was very much part of the G.H.W. Bush administration. Though I – like my colleagues – was pretty dubious about Cynthia, it intrigued me that unlike Sam and Dick, she was not part of the traditional eastern preservation establishment. It was on Cynthia’s watch that the Council approved what was (under National Park Service auspices) to become National Register Bulletin 38, addressing the need to respect the significance of traditional cultural places. Bulletin 38 was in many ways a reflection of Reagan-era populism.

But Dick and Sam – with Bob – made it possible for the national historic preservation program to survive and thrive during the difficult years of the Reagan administration, and to maintain and improve a regulatory process built on broadly-defined multi-party consultation. I’ll remember them all with respect and admiration.

Sunday, June 03, 2018

The 2018 "To Bridge a Gap" Conference

I’m grateful to the Muscogee Nation and the USDA Forest Service – specifically The Mark Twain National Forest’s Daniel Cain – for making it possible for me to take part in the 17th(!) annual “To Bridge a Gap” conference, May 21-25, at the Muscogee Nation’s River Spirit Casino Resort on the bank of the Arkansas River in Tulsa, Oklahoma.

As I understand it, the conference began when a few members of multiple tribes and several Forest Service archaeologists decided there were mutual benefits in collaboration in cultural resource/heritage management and environmental issues, an forthwith began meeting to explore possibilities. The event has grown in all directions; this year it involved close to 400 people from many tribes, several federal agencies besides the Forest Service, and a good many people from consulting firms. Participation by high-level Forest Service management was impressive, with managers in active attendance from multiple Regional Offices and the Washington Office.  The Advisory Council on Historic Preservation was also well represented, as were several State Historic Preservation Officers. Tribal Historic Preservation Officers were everywhere.

Two things stood out for me.

First, although the Forest Service – to say nothing of other agencies – still mostly hires archaeologists to fill its heritage program jobs, it’s clear that those in such jobs recognize that their responsibilities aren’t largely focused on taking care of, or digging, archaeological sites. There seemed to be widespread recognition that “heritage” involves people, communities, and all those aspects of the environment that people and communities value – water, plants, animals, landscapes, viewsheds and smellscapes, among others. My opening-session blather about traditional cultural places (TCPs) seemed positively old-hat, to me at least.

Second, I was impressed by the real sense of collegiality that everyone seemed to exude. I wasn’t in the executive sessions between tribes and regional offices, where perhaps some head-butting occurred, but in the public sessions there seemed to be a high level of mutual understanding and respect. During the magnificent meals that we all dug into three times each day, it looked to me like people from all the tribes, agencies and other entities were cheerfully breaking frybread together.

It rather astounded me that this was the 17th TBAG conference, and I’d known nothing about it before Dan Cain invited me to take part. It’s remarkable, and rather chastening, to learn that such a collaborative enterprise could have developed in this century, quite under my radar. But it was very, very encouraging, and I hope the participants go on to bigger and even better things next year and beyond.

Sunday, April 22, 2018

Crossing the Talbot Avenue Bridge

On April 21, 2018, I visited the Talbot Avenue Bridge in Silver Spring, Maryland. The bridge, which spans the CSX Railroad tracks, has for the last century been the main connection between the largely African-American community of Lyttonsville and the more upscale white neighborhoods across the tracks, as well as the Georgia Avenue corridor into the District of Columbia.
The gathering on the bridge

The occasion for my visit was the installation of a “pop-up park” on the bridge by my colleague and friend, historian David Rotenstein, who has made it his business to remind us here in liberal Montgomery County – and coincidentally in my birthplace, Decatur, Georgia – of our Jim Crow traditions. Perhaps a hundred people attended. David and his colleagues had affixed interpretive placards to the bridge rails, and there was a “conversation corner” where people could share stories about the bridge and their communities. There were speeches, by David and by elders of the African-American community. The elders talked of the role the bridge had played in the life of their community, as essentially their only connection with the outside world and the larger society and economy.

Why was the event staged? Because the century-old bridge will soon be demolished to make way for the “Purple Line,” a largely federally funded rapid transit project. Katherine Shaver’s September 24, 2016 story in the Washington Post tells the tale: see

Lyttonsville elder Charlotte Coffield (L) confers with 
David Rotenstein (R). The white taped line symbollically
represented the division between Black (B) and White (W) communities

A couple of the placards recounted the history of the Purple Line’s environmental impact assessment under Section 102(c) of the National Environmental Policy Act and Section 106 of the National Historic Preservation Act. In the course of this assessment, based on a consultant’s report, the bridge was found eligible for the National Register of Historic Places, but only as a work of engineering. Its sociocultural significance seems to have been entirely ignored.

I take it that the existing Talbot Avenue Bridge will be replaced by a modern structure capable of spanning the widened railroad tracks, so the connective tissue it represents will be maintained. And history has moved on; Montgomery County is no longer the segregated set of communities it once was (though in these difficult times, even here segregationist attitudes occasionally resurface). So maybe losing the bridge is no big deal. But damn, people, is it really right for a property like the Talbot Avenue Bridge to be evaluated for the National Register, and hence considered under Section 106, purely as a piece of engineering? Should its traditional cultural value not have been considered, leading in this case – perhaps – to a more respectful outcome?
Among the "popup park's" markers

I know, there’s King flapping his lips again about traditional cultural places. And this time after the fact. No argument; I just think it’s sad that once again Section 106 review – and NEPA review – of impacts on a place of cultural significance to a community has been short-circuited by narrowminded application of the National Register criteria. I guess I should be used to it by now.

Saturday, September 09, 2017

It’s Not Optional, Stupid

I’m involved in several Section 106 cases – that is, project reviews under Section 106 of the National Historic Preservation Act – in which federal agencies (or the project proponents who very often stand in for them) have declined to consider the possible eligibility of traditional cultural places (TCPs) for the National Register of Historic Places (NRHP). They generally excuse their lassitude by saying that it’s just too challenging or complex or demanding of thought to consider such places.

I just want to say to such folks – and to the State Historic Preservation Officers (SHPOs) and Tribal Historic Preservation Officers (THPOs) who may be flim-flammed by them – that it’s not optional, stupid.

The Section 106 regulations, at 36 CFR §800.4(c)(1), say:

….the agency official shall apply the National Register criteria … to properties identified within the area of potential effects that have not been previously evaluated for National Register eligibility.

Now, granted, it doesn’t say all properties – and there’s a pragmatic reason for that. Nobody can ever be sure they’ve even found all the properties in a given project’s area of potential effects that might be eligible for the NRHP. But for pity’s sake, the regulations also don’t say “apply the criteria only to those properties you find convenient.”

In each of the cases with which I’m currently dealing, one or more consulting parties have asserted that the place in question is an NRHP-eligible TCP, and in most cases they’ve put forward a good deal of evidence. As I read the regulations, these are clearly places to which the responsible (sic) federal agency must apply the NRHP criteria, in consultation with the SHPO and – if they’re exercising due diligence – other consulting parties. The agency may apply them poorly, stupidly, misguidedly or under the influence of politics, money, or drugs, but it is not permitted just to say “oh, that’s too hard so I won’t do it.”

I think the confusion on this point may arise from the fact that an agency is permitted to defer nominating a place under its jurisdiction to the NRHP – that is, filling out all the paperwork and formally proposing that it be solemnly inscribed in the list for ever and ever, world without end. But read my digits, people, determining eligibility and nomination are not the same animals! They’re done for different reasons, in different management contexts. Any agency historic preservation person ought to know that; any SHPO or THPO ought to know that. It’s absurd that this should even be an issue any more.

And please don't ask me, all owly-eyed, "what happens if people don't agree about eligibility. Sheesh!

Sunday, April 23, 2017

Supporting Science, Saving the Planet

I recently engaged in a Facebook exchange with astronomer Reed Riddle and astrophysicist Rebecca Oppenheimer about a widely circulated 4-minute video featuring pop-science superstar Neil DeGrasse Tyson ( ) – about the importance of science and how it must be supported. I thought it was a dreadful video: arrogant, condescending, simpleminded, insulting to its viewers, unlikely to do anything other than inflate Tyson’s already well-puffed ego and rub the tummies of those – like me – who already believe that science is vital to our survival. Reed and Rebecca patiently explained that I simply didn’t understand.

In the process of thus putting me in my place, they invited me to advise them about how I’d pitch a 4-minute video to the unwashed masses making the same point. I’ve thought a bit about this, and here’s my outline:

  1. Have the pitch-person be someone who’s more likely than Tyson to connect with the average Trump voter. I don’t know who that would be, because I’ve lost track of the world’s celebrities, but I’m sure such a person could be found.
  2. Make the following points:
    1. The world is in really serious trouble. We’ve got:
                                                              i.      Way too many people, and making more all the time;
                                                            ii.      A changing climate that’s reflected quite objectively in things like sea level rise and shrinking glaciers; we can argue about why it’s happening, but there’s no real question that it IS happening;
                                                          iii.      Far too many weapons of mass destruction, many in the hands of deeply untrustworthy parties;
                                                          iv.      Dangerous levels of social and economic inequality;
                                                            v.      Pollution that’s fouling the seas and land, and killing off our fellow residents on the planet; and
                                                          vi.      On and on and on…

    1. We humans may or may not be entirely responsible for all these crises, but we’ve certainly contributed to them all.
    2. Science bears a fair share of blame, for making overpopulation easy, for providing the comforts that have made it possible for us to add heat to the atmosphere and generate pollutants, for creating weapons of mass destruction and slow suffocation, etc.
    3. If we and our fellow residents are going to survive, we need to take action. All of us.
    4. What can we do?
                                                              i.      If you believe in a higher power, pray; ask forgiveness for what we’ve done, and beg for help.
                                                            ii.      Stop having so many babies.
                                                          iii.      Reduce, reuse, recycle, and
                                                          iv.      In the immortal words of Matt Damon (There’s one celebrity I remember), science the shit out of it. Although there are plenty of dangers in what may be portrayed as scientific solutions (Remember Fukashima and beware geoengineering), we need to put all options on the table and figure out which ones have the best chance for success with the least risk.
                                                            v.      This requires supporting science and science education.

Squeeze that into 4 minutes? I think it could be done, but doing so is beyond my technical capability.

There, Reed and Rebecca; another bit of poorly informed silliness for you to ignore. Though thanks, Reed, for the link to -- which I think rather makes my point.