Here's the paper I'm scheduled to present next week in Beijing at the World Archaeological Intercongress on Heritage Management in East and Southeast Asia. I'm grateful to WAC and the Institute of Archaeology in the Chinese Academy of Social Sciences for the invitation to do so.
Cultural Heritage, Environmental Impact Assessment, and People
Abstract: Environmental impact assessment (EIA) is the procedure by which the impacts of proposed construction and land-use projects are assessed and – in theory – made to influence development decisions. Cultural heritage tends to be poorly considered in EIA. Much of the blame lies with cultural heritage professionals. We tend to focus our energy on inscribing places in formal lists, and on debates about the formal interpretation of such places. We are too wrapped up in promoting the selective presentation and management of places that governments recognize as significant, and we too easily facilitate development schemes by excavating and thus removing sites that lie in their way. Most importantly we fail to engage the people of our countries, who alone have the power to redirect destructive development. We fail to engage them by failing to respect them and the places that they think are significant. Instead we insist that they respect our evaluations of places and our plans for management. We come to be seen as elitist, and as junior partners in the very development projects that destroy heritage. As junior partners we are easily ignored when conflicts arise between development and heritage, and the people who should be our allies in pushing back against destruction find us irrelevant to their concerns. We need to reconsider our priorities, and our methods of pursuing them.
Introduction: Assessing Environmental Impacts and Cultural Heritage
It is no secret that development projects of all kinds – housing and agricultural schemes, dams, highways, rail lines – do injury to the environment, however justified they may be on economic, social, and even environmental grounds. One has to destroy in order to build; it is in the nature of the enterprise. To control such damage, since the early 1970s virtually every national government, and such nongovernmental organizations (NGOs) as the World Bank, have put in place procedures for “environmental impact assessment” (EIA). The reason for such procedures is summed up in the Confucian’ maxim: “If you do not consider the future, you will be in trouble when it comes near.” Governments and funding bodies should consider what damage a project is likely to do before they decide whether and how to go forward with it. This is not to say that damaging projects should not be undertaken: only that if we know what damage is likely to occur, perhaps we can do things to keep it from happening, to reduce its severity, or make up for the damage somehow.
Of course, among the aspects of the environment that can be damaged by modern activities are what we call “cultural heritage.” We in this conference can probably all agree that potential impacts on cultural heritage should be closely examined in the course of EIA, that alternatives to damaging activities should be considered, that steps should be taken to avoid or reduce the damage. In general terms, the world’s people seem to agree; most communities react badly to actions that they perceive as damaging to their cultural heritage, and most governmental guidelines for EIA indicate that impacts on cultural heritage should be considered in planning.
Often, however, when EIA is performed on proposed projects, not much attention is paid to cultural heritage. EIA analysts merely list affected historic monuments or places included in the World Heritage List, and assert that these will be taken care of by following whatever standard procedures governments have put in place. Often the people and communities whose heritage is most at risk are poorly engaged in the process of EIA, their heritage values are poorly considered in planning, and the steps taken to mitigate impacts – decided on by project proponents and governments, if indeed any such steps are taken – are inadequate or even irrelevant to the people whose heritage is affected.
In my experience there are several common, interrelated reasons that cultural heritage is not addressed well in EIA. In this paper I want to outline some of these problems, and suggest steps that we might take to solve them.
Problem One: What is Cultural Heritage?
Different people conceptualize cultural heritage in different ways, and this complicates its consideration in EIA. In my own experience in the United States and the Pacific islands, and in reading the international literature, I find that cultural heritage is variously defined to include – or exclude (among other things) –
• Monuments, archaeological sites, and cultural landmarks;
• Traditional ways of using the land and its resources;
• Culturally important plants and animals;
• Stories, songs, philosophy and language;
• Traditional forms of subsistence;
• Traditional ways of life;
• Religious and cultural practices;
• Objects of material culture (artifacts, antiquities);
• Art forms, and
• Books, manuscripts, and other literary products.
Each of us academic and professional practitioners specializes in one or more of the above types of heritage. Most of us at this conference, in fact, specialize in a subdivision of the first type shown on my list: archaeological sites, which may also be thought of as historic places and/or landmarks. We understandably do not take responsibility for other kinds of cultural expression, other parts of the cultural environment. But here is the problem: we also often fail to inform those who plan and carry out EIA that we are not authorities on all aspects of cultural heritage. And we fail to recommend that they consult those who are authorities on cultural things other than archaeology, notably including the local people themselves. This results in assessments in which “cultural heritage” is equated entirely with monuments or archaeology, while the other aspects of culture are given little consideration or even ignored entirely. These aspects of the cultural environment may be just as worthy of protection as – even more worthy than – archaeological sites, and they may be much more the concern of local people, but if they are considered in EIA at all, they are often considered in spite of us rather than with our support.
Consider, for example, animals or plants that figure importantly in a community’s self-identity. I have been involved lately with the Okinawa dugong, significant in the beliefs of traditional Okinawans; the dugongs’ habitat is threatened by the proposed construction of a new U.S. military base. To those performing EIA on the project, the dugongs were simply animals of professional concern to biologists and natural resource managers. To the local people, however, the dugong is literally a sacred animal. Had it not been for legal intervention by Okinawan, Japanese, and U.S. environmental groups, and near-violent demonstrations on the project site by Okinawans, the cultural value of the dugongs and their habitat to the people of Okinawa would have been ignored in the military’s EIA and its decision making about the project.
Problem Two: The Limitations of Traditional Thinking About Cultural Heritage
EIA has developed as a widespread aspect of governmental and non-governmental planning only in the last half-century. The management of historic landmarks, monuments, and archaeological resources, of course, has a more venerable history, by some reckonings going back to the 10th century ACE and perhaps farther. Organized government systems for heritage management were being put in place in Europe by the early 19th century, and spread across the world with colonialism. So the ways archaeologists, architectural historians, and our close colleagues think about our aspects of cultural heritage were well set in place before EIA ever came on the scene. These ways of thinking feature the following more or less standard elements:
• A narrow focus on places: that is, buildings, other structures, monuments, and archaeological sites, and on portable antiquities;
• The compilation of official lists of heritage places, variously called registers, inventories, and schedules, among other things;
• An expectation that listed heritage places should be preserved unchanged in perpetuity;
• Little or no consideration given to places not on official lists, or regarded as eligible for them;
• Official governmental bodies that compile and maintain lists, and promote preservation;
• Laws and regulations aimed at protecting listed places to varying degrees, or at least at reserving to government the right to destroy them.
• More or less rigorous constraints on the private appropriation of heritage places, or of antiquities.
These standard elements are embedded not only in the legal systems of most nations, but in such international instruments as the World Heritage List. Even when we try to bend our minds around cultural things that are not archaeological sites and historic landmarks, we automatically apply our traditional ways of thinking. The UNESCO Convention for the Safeguarding of the Intangible Cultural Heritage, for example, directs that signatory nations compile lists of intangible cultural heritage, despite the inherent fluidity and evanescence of intangible culture.
When this list-based, hierarchical, bureaucratic and rather rigid system of thought intersects with EIA, it further narrows the scope of impact analysis. Not only does EIA come to represent archaeological sites and landmarks as the only culturally significant aspects of an affected environment, it tends to recognize as significant only those sites and landmarks that government has officially declared and listed as such. In the United States, for instance – to hold up only my own country as a sad example – if a local community fears that a place it holds to have cultural significance may be destroyed by government action and wants it considered in EIA, it must show that the place is eligible for the National Register of Historic Places. This requires the community to explain the place’s significance to government archaeologists and architectural historians, following technical regulations issued by the National Park Service and understood only by specialists. In most EIA documents in the United States, if a place has not been found to be eligible for the National Register, it is assumed to be of no significance, and can be destroyed with impunity. And cultural heritage that is not embodied in places – animals, plants, belief systems, traditional food – has almost no chance of being considered in EIA. This strikes me, at least, as a strange way for a grandly self-proclaimed democracy to consider its impacts on the cultural values of its people.
Problem Three: Attitudes and Assumptions
When people conducting EIA seek to consider the cultural aspects of the environment, they understandably turn for advice to government’s cultural heritage authorities – ministries of culture, official archaeological surveys, agencies that maintain schedules or registers of cultural places and things. They assume that such authorities can advise them about – perhaps even provide them with a list of – significant cultural heritage that may be affected.
The cultural heritage authorities often have little understanding of EIA, but they do know their own programs, regulations, policies, and professional specialties. As far as they know, when they are asked to advise about cultural heritage, they are being asked to advise about what is on their lists, what they are officially responsible for, or what falls within the ambit of their professional expertise. They advise about archaeological sites, scheduled monuments, registered buildings. What they almost certainly do not advise about is how to interact with local people, local communities, to find out what they think is important and what they think ought to be done about it. That sort of engagement has never been part of the portfolio of most government heritage offices, and few of them are staffed, funded, trained or encouraged to promote such engagement.
Presuming that they now know what cultural heritage may be involved, the people conducting EIA duly report it and proceed to analyze environmental impacts without further consideration of culture. If local people and other interest groups then object – perhaps violently – to what they think the project will do to their heritage, it often comes as a surprise to the project’s proponents and their EIA specialists (and perhaps to the cultural heritage authorities as well).
Government, Culture, and People
This situation is fundamentally unfair and counter-democratic, and it undercuts our efforts to preserve cultural heritage. Surely it is true that only the citizens of our countries, only the people, have the power to redirect and control destructive development, but our traditional ways of managing heritage disconnects us from the people. By focusing attention only on the kinds of heritage that we understand and appreciate, we fail to engage the people. By failing to respect them and the things that they think are significant, by insisting instead that they respect our evaluations of heritage, our ways of discussing it, and our plans for its management, we cause ourselves to be seen as elitist and irrelevant to the people’s interests. This leaves us in a relatively powerless position when confronting the development projects that destroy heritage. We become, in essence, junior partners in such developments, and as such we are easily ignored when conflicts arise between development and heritage.
Ironically, failing to engage the people and address the heritage they value can also impede development projects. I have personally seen important, highly justified projects held up for years, at very high cost, and sometimes abandoned altogether, because of last-minute controversies over locally valued cultural heritage. These controversies often could have been avoided or efficiently resolved had affected people and communities been respectfully consulted, early in project planning.
I suggest that it is in everyone’s interests – the interests of governments, of archaeologists and other heritage professionals, of our institutions and agencies, of communities world-wide, and of the development community, to make EIA more sensitive to cultural heritage, broadly defined, and notably to the cultural values of local communities. Interestingly, a way to do this has been offered, not by us cultural heritage experts, but by biologists.
The Akwé: Kon Guidelines
The Secretariat of the Convention on Biological Diversity – a convention to which China and other Asian countries are signatories but my country, I am sorry to say, is not – has produced a sophisticated set of guidelines for considering cultural heritage in EIA. These guidelines are called “Akwé: Kon”(“Ahgwégoh”) a term in the language of the North American Mohawk tribe meaning “everything in creation.” They outline how to conduct social, cultural, and environmental impact assessments in concert with affected communities.
A government or NGO planning some form of land-use – say a dam, a highway, an agricultural or urban revitalization scheme, or a power plant – that is conscientiously following Akwé: Kon would actively and creatively engage local communities in every aspect of project planning. It would work with such communities to identify who speaks for different cultural interests. It would learn how to communicate with these groups, find out and record their concerns and negotiate ways to address those concerns. In doing so, it would make sure that affected groups have the financial and other resources necessary to participate fully in impact assessment and decision making. It would negotiate and put in place agreements with the communities about how the impacts of the project would be identified and considered. Following such agreements, it would conduct cultural impact studies addressing the project’s possible impacts on, for example:
…cultural heritage, religions, beliefs and sacred teachings, customary practices, forms of social organization, sys¬tems of natural resource use, including patterns of land use, places of cul¬tural significance, economic valuation of cultural resources, sacred sites, ceremonies, languages, customary law systems, and political structures, roles and customs.
(Secretariat of the CBD 2004:13)
The scope of such studies would take into account:
(a) Possible impacts on continued customary use of biological resources;
(b) Possible impacts on the respect, preservation, protection and mainte¬nance of traditional knowledge, innovations and practices;
(c) Protocols (negotiated with communities);
(d) Possible impacts on sacred sites and associated ritual or ceremonial activities;
(e) Respect for the need for cultural privacy; and
(f) Possible impacts on the exercise of customary laws.
(Secretariat of the CBD 2004:14)
The government or NGO would carry out environmental assessments coordinated with the cultural assessments. These would “respect existing inherent land and treaty rights as well as legally established rights of indigenous and local communities” and “con¬tribute to the protection of the rights of indigenous and local communities by recognizing (their) distinct activities, customs and beliefs…” Such assessments would consider, among other more strictly eco-biological factors:
• areas of particular economic significance (as hunting areas and trapping sites, fishing grounds, gathering areas, grazing lands, timber harvesting sites and other harvesting areas);
• particularly significant physical features and other natural factors which provide for biodiversity and ecosystems (e.g. watercourses, springs, lakes, mines/quarries that supply local needs); and
• sites of religious, spiritual, ceremonial and sacred significance (such as sacred groves and totemic sites).
(Secretariat of the CBD 2004:16-17)
Coordinated social impact assessments would:
…. take into account gen¬der and demographic factors, housing and accommodation, employment, infrastructure and services, income and asset distribution, traditional systems and means of production, as well as educational needs, technical skills and financial implications… and evaluate …. tangible benefits to such communities, such as non-hazardous job creation, viable revenue from the levying of appropriate fees from beneficiaries of such developments, access to markets and diversification of income opportunities.
(Secretariat of the CBD 2004: 18)
Economic assessments would recognize that:
…changes to traditional practices for food production, or (that) involve the introduction of commercial cultivation and harvesting of a particular wild species (e.g. to supply market demands for particular herbs, spices, medicinal plants, fish, fur or leather) may lead to pressures to restructure traditional systems of land tenure or expropriate land, and to pressures on the sustainable use of biological diversity, in order to accommodate new scales of production. The ramifications of these kinds of changes can be far-reaching and need to be properly assessed, taking into account the value systems of indigenous and local communities. Likely impacts associated with the cultivation and/or commercial harvesting of wild species should also be assessed and addressed.
(Secretariat of the CBD 2004: 19-20)
The results of all these assessments would be brought back to the community and coordinated with its own planning, in a transparent, consultative manner, with provision made for the resolution of disputes (Secretariat of the CBD 2004:22-25).
Opting for Akwé: Kon
An EIA system based on Akwé: Kon would not discourage consideration of things like World Heritage sites and places or things listed in a national schedule or register, but it would recognize that those who are fixated on such places – that is, let’s admit it, many of us – constitute only one set of cultural stakeholders, whose values are not privileged over those of others, notably including local people. It would be significantly more democratic, more transparent, more inclusive than most existing systems. It would also, I think, produce a higher degree of predictability for development project proponents than they currently enjoy.
Adopting an Akwé: Kon based system would require administrative, legislative, and policy actions of different kinds, depending on the nation or NGO involved. In the U.S., unfortunately, it would require action by our legislative bodies, which is very unlikely to happen. In nations with less fossilized EIA and cultural heritage systems than ours, and among NGOs and even private-sector development proponents, there is probably much more hope.
I have no magic formula for replacing the world’s ineffective cultural heritage systems with something like Akwé: Kon, and I certainly have no wisdom to impart. My purpose here today is just to suggest that many of our existing systems for relating cultural heritage to EIA are self-defeating, and to suggest that we consider such creative alternatives as Akwé: Kon. I hope that WAC and other cultural heritage organizations, and the smart young people who are rising to leadership in such organizations, will undertake this consideration.