I understand that this blog is being used in some university CRM classes, so here's a little educational application.
The following quote is from a U.S. Department of the Interior, Bureau of Land Management environmental impact statement:
A Traditional Cultural Property (TCP) is an area of traditional importance that has been determined eligible for listing or has been listed on the National Register of Historic Places based on established definitions and criteria.
Relative to published U.S. government definitions, the above text is factually incorrect in at least two related ways.
Can you identify how it is erroneous?
For extra credit:
1. What are the public policy implications of these errors?
2. Why do you suppose BLM has perpetrated them?
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.
7 comments:
So what's the answer?
I thought MAYBE a few people would hazard guesses, but only David Dick has -- on my Facebook page rather than here -- and rather than just cough up the answers in response to the (quite insightful) musings of one correspondent, I think I'll just let all you multitudes stew, and use the question in the TCP class I teach in person.
Well, since there has been so much deafening silence on this one, I am going to throw out one issue that I see with the definition. A TCP can be a TCP regardless if it has been determined eligible for listing or is listed in the NRHP. A TCP exists outside of the Section 106 regulatory process and does not need the process to become a TCP.
I think that the extra credit questions are obvious if my observation is correct. It means that the agency and not the cultural group are given decisive authority in defining this property and therefore in considering it in the Section 106 process.
Definitely not the intention of the regulations. (Or, perhaps it was?)
Thank you, Annonymous. You're right on the money. First, even in the narrow-minded world of practice under the NHPA, a TCP doesn't have to be DETERMINED eligible for the Register; according to NR Bulletin 38, it merely has to BE eligible. Second, in the real world it doesn't even have to BE eligible for the Register in order to be a TCP, any more than a boat has to be eligible for the Register in order to be a boat, or a house has to be eligible for the register in order to be a house. If somebody ascribes traditional cultural value to a place it's a TCP for that person or group. If it meets the NR criteria (whether or not anybody formally evaluates it), then it's a National Register eligible TCP.
We can only speculate as to why BLM perpetrated its narrowminded misinterpretation, but my guess would be that it wants to avoid considering impacts on places that are important merely to people; it wants only to consider places that specialists in BLM, the SHPO, or NPS have blessed after full consideration of their sacred texts.
And, having been involved in Section 106 as a consultant and as an agency specialist, I am still continually amazed at how much the process seems to be one that is driven by special interests of the "experts" rather than by the citizens and individuals for whom we are spending tax dollars to "protect and preserve the past." Us "experts" need to keep in mind that this legislation and these regulations were not created for us. If we do not keep this in mind, we are little more than "special interest" sucking off the government teat at the expense of "We, the People."
Well said, Annon. And we wonder why there's not broader, deeper public support for historic preservation. I firmly believe that the only reason we haven't been pried off the public teat already is that we're such small potatoes, and so obscure, that nobody really notices what we do.
. . . . the only reason we haven't been pried off the public teat already is that we're such small potatoes, and so obscure, that nobody really notices what we do. . . . . .
You're kidding, right? Small potatos (Dan Quayle spelling) to whom?
We're talking about thousands of Fed/State/private sector jobs. Literally tens of millions of $ annually. Also add in the cost in terms of time that each nitiative (thousands annually) wait for happy resolution to the 106 process.
Small potatos to an archaeologist perhaps, but a gigantic, county fair winning spud to a paleontologist.
signed ~Dinosaur
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