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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.


John P. McCarthy, RPA said...

I don;t know, Tom. I've been doing this kind of work (CRM archaeology and architectural history) for a long time - not quite as long as you I admit. In any case, in general, I've seen more and more federal and state agencies take their responsibilities under both NEPA and NHPA increasingly seriously and take actions to make resource identification, consideration, and mitigation a routine part of their procedures. Yes, there is an inherent conflict of interest when agency staff and consultants are responsible for these processes, but that's where the SHPOs and ACHP come in to oversee and comment on findings and mitigation measures. It's far from a perfect system, I'll allow, but in the context of advanced capitalism, it's better than it might be.

Tom King said...

The "routine" character of it may be part of the problem; it seems to me that what's become routine is a very, very low common denominator. So the result is the appearance of doing NEPA and NHPA, that is, the FORM of NEPA and NHPA (as conceived by those practicing the low common denominator), but very, very little attention to the FUNCTIONS of the laws as originally conceived or as logically construed.

Anonymous said...

Thinking a little further about your post, Tom, I was reminded of a workshop on the management of non-profits that I attended where there were two representatives from an outfit called Cultural Resources Management - and no, it turned out, they were not archaeologist but people from the dance and performing arts world who helped small companies and theaters find and manage grants -

Tom King said...

Yep. We all dance in our own little circles, with our own chosen partners, and very seldom get a glimpse of the whole dance.