I’ve sometimes wondered why archaeologists working under the National Historic Preservation Act (NHPA) seem to have such a hard time understanding that anything besides archaeological sites can be eligible for the National Register of Historic Places. The other day I was given a very broad hint.
I was reviewing a report by a “cultural resource” contractor in a state that will remain nameless; the report proposed development of a “cultural resource management plan,” and in the process tried to explain the National Register criteria (36 CFR 60.4).
He thought the criteria were found at 36 CFR 800.10, but oh well…..
There are, of course, four criteria; a place can be eligible if it’s –
- Associated with significant events or patterns of events in the past (the “A for association criterion”);
- Associated with significant historic people (the “B for big people criterion”);
- Characteristic of a type, style, school, etc. (the “C for cute building [or characteristics] criterion”) or
- Produced, or may produce, significant data (the “D for dig (or data) criterion”).
The fellow whose report I reviewed felt compelled to simplify, which is understandable, so he smushed the first two criteria together, left out the third, and retained the fourth, with a key change between the last two; his gloss on the criteria said that a place can be eligible for the Register if it’s –
- Associated with something significant in the past, and
- May contain significant data.
Well, obviously to any half-coherent reader of the English language, a whole screaming bunch. By substituting “and” for “or,” the guy transformed the whole National Register program into something aimed at preserving data. He made it seem like a place has to be likely to contain significant data in order to be eligible.
People, data are not what the NHPA is mostly about. As Congress wrote the law and as the National Park Service wrote the regulations, a place does not have to contain important data in order to be eligible for the Register. That’s elementary; that’s not even Historic Preservation 101, it’s Historic Preservation preschool. And yet there was a consultant who’d never learned it, and nobody was catching him on it, so he was free to utterly misinterpret the whole rationale for historic preservation. And by doing so, he was fixing it so only the kinds of places he was comfortable with had to be considered for Register eligibility. Never mind what anyone not of the archaeological persuasion – any Indian tribe, any Native Hawaiian group, any local historical society or architectural historian or traditional community – might value, and never mind what the laws and regulations say. And for this he was being paid as a CRM expert.
Look,folks, it’s “or,” not “and.” “Or,” “or,” “OR!” It’s been that way for almost fifty years – i.e. as long as there’s been a National Register. For heaven’s sake get it through your heads.