tag:blogger.com,1999:blog-8788575.post4718290496499255428..comments2024-01-11T22:45:53.276-08:00Comments on Tom King's CRM Plus: What's Happened to the Update of National Register Bulletin 38?Thomas F Kinghttp://www.blogger.com/profile/00037819472341496713noreply@blogger.comBlogger5125tag:blogger.com,1999:blog-8788575.post-4329831680531275422015-12-14T16:09:27.392-08:002015-12-14T16:09:27.392-08:00Too Afraid -- Yes, they're petty tyrants becau...Too Afraid -- Yes, they're petty tyrants because they're two chickenshit to sit down with the National Park Service and its contractor, who happens to be the original author of the bulletin, and argue their case; instead they just say "Here is is, folks, our way or the highway." That's petty, that's tyrannical, that's arrogant, and it's deeply anti-collegial.<br /><br />Anonymous, you don't see TCP in regulation for the same reason you seldom see "boat" or "Queen Anne Cottage" or "Adena mound" in regulation. A TCP is simply a kind of place, like a boat or a cottage or a mound, that may or may not be eligible for the National Register. So just as we don't need to codify the eligibility of a boat, a cottage, or a mound, we don't need to codify the eligibility of TCPs. Plus, of course, most of the regulations were issued before "TCP" became a term of art. <br /><br />Chron, if it's the original Bull 38 language you want to see, that's available on the Web; just google National Register Bulletin 38. If you want to see the draft of the revision and FAQs before the ACHP got its pothooks on it, yup, you'll have an opportunity, though probably not an official one.Thomas F Kinghttps://www.blogger.com/profile/00037819472341496713noreply@blogger.comtag:blogger.com,1999:blog-8788575.post-50468885747871494212015-09-25T09:01:55.743-07:002015-09-25T09:01:55.743-07:00Will there be a time at the end of this process wh...Will there be a time at the end of this process when we will be able to read the original draft and compare it to the final document? Anonymousnoreply@blogger.comtag:blogger.com,1999:blog-8788575.post-41084811965578129782015-09-25T08:57:52.153-07:002015-09-25T08:57:52.153-07:00I wish I could read the original language. Will t...I wish I could read the original language. Will there ever be a time when that will be possible?Anonymousnoreply@blogger.comtag:blogger.com,1999:blog-8788575.post-51717983017653625322015-09-24T09:25:27.507-07:002015-09-24T09:25:27.507-07:00Thanks for updating everyone.
Can anyone explain...Thanks for updating everyone. <br /><br />Can anyone explain why the term Traditional Cultural Property (TCP) has never been codified in regulation ? The term does not appear anywhere in the regs - not in the 800 regs, not in the NR regs - yet it is used somewhere, every day of the week, as if it were a codified term. An NPS bulletin is nice, as is ACHP guidance. But neither of those agencies have ever seen fit to put "TCP" into unambiguous, regulatory circulation. Why not ? The only codified term we have is "property of traditional religious and cultural importance to an Indian tribe or Native Hawaiian organization" - this is the statutory terminology, which ironically, almost never gets used. We once used it in a draft MOA, and the SHPO actually asked why we were using a made-up term, instead of the "proper" term (TCP) that they assumed was in the regs. How does this happen ? Yes, I know the difference between TCP and the statutory term in the NHPA (1992 amendment). Why have neither been codified in regulation ? Anonymousnoreply@blogger.comtag:blogger.com,1999:blog-8788575.post-22832760922369736342015-09-22T17:37:44.280-07:002015-09-22T17:37:44.280-07:00Hello Tom,
I think that your point would be illu...Hello Tom, <br /><br />I think that your point would be illustrated if you wrote what you meant. How are the ACHP childish tyrants? Your post doesn't describe their behavior. Unless, not consulting with you qualifies.<br /><br />I admire your work and wish that I could be as outspoken. Thanks for the status update. Too Afraid to Speak Publiclynoreply@blogger.com