As the inventor of such widely used cultural resource management (CRM) acronyms as "TCP" (traditional cultural property or place) and "APE" (area of potential effects), I'm pleased to announce promulgation of two more.
1. "MMD" stands for "mealy-mouthed drivel," that is, high-falutin language that means nothing (especially if not followed up in, or if contradicted by, a document's substantive provisions). Example (real language, with agency identity protected):
The Tribes and the agency shall, in a spirit of positive collaboration, effect goals in regards to the project, protection and preservation of natural and cultural resources, under the agency’s jurisdiction or control and for mutually creating a positive management strategy for maintaining properties that considers the preservation of their archaeological, historical, and cultural values and the avoidance of adverse effects in the light of the views of the Tribes.
2. "GSF" stands for "gratuitous statement of fact," wherein an agency clutters up a document by stating facts having nothing directly (or often even indirectly) to do with the subject of the document. These may note that the agency will obey a law or regulation (awfully good of them, yes?), or simply provide an extraneous bit of filler material. Example (again, real language, agency ID disguised):
The agency, in carrying out its responsibilities as the lead Federal agency for NHPA Section 106 compliance, has developed policies and procedures to help guide its planning and decision making as it affects historic and cultural properties.
I've recently reviewed two draft-final programmatic agreements (PAs) under Section 106 of the National Historic Preservation Act, almost every clause of which is made up of MMD and GSF. This creates a dense thicket of prose in which the substantive provisions, such as they are, get lost, and it's hard for even an experienced reader to pick out their strengths and weaknesses.
Please welcome MMD and GSF to the lexicon of CRM acronymology.
Tom King’s CRM Plus -- Ruminations on "cultural resource management," environmental impact assessment, and related esoteric topics, by a curmudgeon who seldom has anything good to say about anything.
5 comments:
As if we needed more!
Nice additional to CR Acronyms... I'll see how those go over at work on Monday...
Nice additional to the CR acronyms... I'll use those at work on Monday.
As an attorney focusing on the EIA processes required by CEQA and NEPA, I'm certainly familiar with MMD and GSF. I went into environmental law because of a deep concern for what's left of our natural (and cultural) environments. After almost 6 years of advocacty on behalf of developers, public agencies, and now concerned NGOs, I must agree that MMD and GSF contaminates many analyses, resulting in incoherent discussions of impacts and meaningless and unenforceable mitigation. EIA must be reclaimed to uphold and honor the laudable policies it is ostensibly required to serve.
So what kind of Acronym would something like this fall under? This was wording from a local growth management ordinance document(FEIR) that was going to supplement the General plan to facilitate close to 500 apt units being built in the remaining vacant lots( Ive, replaced the Agency's name with Local plan..etc):
"With the incorporation of the 'Local Plan' mitigation measures, impacts related to the extension of the 'Local Growth Management Ordinance' would continue to be less than significant with mitigation as identified in the 'Local Plan' EIR.”
"The 'Local Plan' EIR Mitigation measures:
None recommended. Existing Comprehensive plan policies provide appropriate protection."
The EIR reference to the Comprehensive plan is a phase 1 study over the whole City and admits that it is not feasible and no funding is available so therefore cannot be carried out. Is that BS to cover the BS? Does it fall somewhere in between the MMD and GSF or clearly out of the park?
Maybe that was a reasonable good faith effort???
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