On several occasions recently, I've run into U.S. government agencies, construction project proponents, and their "cultural resource management" contractors who've complained that despite National Register Bulletin 38 (https://www.nps.gov/nr/publications/bulletins/nrb38/) and the literature associated with it (with which, almost universally, they do not seem to have acquainted themselves), they just can't figure out how to identify traditional cultural places (or properties). They never explain why.
A couple of days ago, though, somebody laid this rap on me in person, and I asked them what was so hard about it. WHY couldn't they figure it out?
"Well," was the response, "Bulletin 38 tells us all about how to EVALUATE TCPs, but it doesn't tell us how to RECOGNIZE them in the first place."
OK, as I told my interlocutor, and will repeat here for those who may share such puzzlement: YOU RECOGNIZE TCPS BY %$#@&* ASKING THE PEOPLE! You find out who may have interests in the area you're looking at, and you ASK THEM.
Got it? Is that so hard? TCPs aren't marked by stelae of significance, crumbs of culture. Their significance is lodged in the brains of people, the collective consciousness of communities, and it's those people and communities that can tell you whether a given district, site, building, structure, or object has it. They may not use archaeo-lingo or architect-speak, or recite National Register criteria, but if they value a place, they can probably tell you that they do, and then you can inquire about WHY they value it. If they say they value it because they want to sell it for a million bucks, that may suggest that it's not a TCP, but if they say things about their family's or tribe's or neighborhood's long-time connections to the place, then it probably IS a TCP, at least for those you're talking to. So then you consult with them and others to evaluate it per Bulletin 38.
I mean, seriously; you guys all have college educations; is this really so hard?