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."
Oh.
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?
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:
Now THIS is the Tom King I know and respect.Give 'em hell Tom.Us anthropological types don"t make a hell of a lot of money,but we help preserve and document Native American culture and history. before you bulldoze them and fence them in on their own land and call them "reservations" Ron Melander
Nice post Tom, but what about "rediscovery" of TCPs. For example, the so-called "TCP survey." What is your take on "rediscovery?" Do you believe that a survey to find TCPs constitutes a "reasonable and good faith effort" or are such requests/demands unreasonable?
Thanks
Well, the problem in large part is due to the fact that the professionals trying to recognize/identify TCPS are archaeologists who are ill-equipped to conduct the research necessary. There in lies the problem, as we have discussed, and it is unlikely to change as long as archaeologists are in charge of all cultural resource management scoping.
The problem with those college educations that you mention is that people who often do environmental review work aren't being taught 1) the importance of talking to people in planning processes and 2) how to effectively do it. Lots of students in urban and regional planning programs learn stakeholder engagement techniques and the overall importance of understanding people's values and meanings in planning processes, but they usually don't work in environmental review. The problem is that for Section 106 and NEPA, the typical entry paths, in terms of college education, is architecture, history, historic preservation, archaeology, and environmental science/studies. There's no social science components here, except possibly for archaeology, which ought to have an ethnographic component, but lots of students don't get the exposure and go right into quantitative, processesorial archaeology without blinking an eye. (Again, not the students fault -- look at the curriculum design.) None of these fields are particularly people-centric, instead focusing on objects, archives, ecosystems, and biology. Students in most of these degree programs don't learn to talk to people because their programs don't require such courses and the faculty in these programs often don't specialize, research, or practice in community engagement techniques. (Why would they? No one requires it.)
For instance, in historic preservation (my world), although there is a token mention of "planning" in the National Council for Preservation Education's recommendations for curricula, they don't mention anything about stakeholder engagement, talking to people, or understanding laypeople's values, the values of the disempowered, or non-Western meanings. The other organizations who represent the fields I mentioned above similarly ignore these critical areas. No one inside the system is pushing for this to change, which speaks to me of apathy, unawareness, or just not wanting to take on the beast. A quote from Jean-Paul Sartre comes to mind: "Only the guy who isn't rowing has time to rock the boat." So the boat keeps going regardless of what's happening around it.
Whatever you call it -- heritage or cultural resources (obviously much broader than heritage) -- people are at the core of its meanings and concepts, but our policies, rules/laws/regulations, and educational systems largely fail to recognize this essential characteristic. More of us need to speak up about the need to change this, especially if you are in an area of leadership or help to set policy.
I agree with the above comments, but also think there's some perceived advantage for a project proponent to be befuddled. "Oh gee, this is just so hard! My tiny brain can't handle it, so I guess I'll just have to ignore it." And the affected publics are in no position to do anything about it, since the "authorities" in the agencies and SHPOs don't.
I'm puzzled by "Underpaid's" question. What do you mean by "rediscovery?" As for TCP surveys, they SHOULDN'T be necessary, but since we've developed an esoteric system for historic place evaluation built around the NR Criteria, they're often necessary in order to "translate" what the locals are concerned about into language that the SHPOs and National Register can understand. But that's what they should involve: translation. Asking people what (if anything) they're concerned about in the environment and, if that something seems like a TCP, organizing data on it with reference to the Register Criteria and Bull38. Plus, I'd say, trying to ascertain what people think ought to be done about potential effects on whatever it is that they value.
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