Saturday, September 03, 2016

ENVIRONMENTAL PRACTICE Issue on "Cultural Resources"

The latest issue of Environmental Practice (18:3) – the journal of the National (U.S.) Association of Environmental Professionals – has just come out, focusing on “cultural resources” and with the dubious distinction of having me as its rather last-minute guest editor. It can be accessed at

Articles include:

Wild Horses Are Cultural Resources, by Kathleen Hayden

Assessing Archaeological Resources, by Michael J. Moratto

Non-Disruption and Non-Emissions as Cultural Resources, by Ned Kaufman

Integrating Cultural Impact Assessments into Environmental Analysis, by Claudia Nissley

Religious Resources and Environmental Management in Ghana, by Victor Selorme Gedzi,Yunus Dumbe & Gabriel Eshun

Heritage Dispatches from the American Approaches of Hell: Public Housing, Historic Preservation, and Environmental Impact Analysis, by Fred L. McGhee

Cultural Heritage, Community Engagement, and Environmental Impact Assessment in Australia, by Ian Lilley

Credible Cultural Assessment: Applied Social Science, by Patricia A. McCormack

Indigenous Traditional Cultural Places in Environmental Impact Assessment: The Case of the Ch'u'itnu Watershed, by Heather Kendall-Miller and me

Impacts on Maritime Cultural Resources: Assessing the Invisible, by Sean Kingsley

The National Park Service Visual Resource Inventory: Capturing the Historic and Cultural Values of Scenic Views, by Robert G. Sullivan & Mark E. Meyer

Addressing the Public Outreach Responsibilities of the National Historic Preservation Act: Argonne National Laboratory's Box Digital Display Platform, by Daniel J. O’Rourke, Cory C. Weber & Pamela D. Richmond, and

Cultural Resources in Environmental Impact Assessment, by me (an introductory piece that wound up near the end of the issue, but who am I to quibble?).

Friday, September 02, 2016

Some Lessons From Appalachian Traditional Cultural Places

I’ve posted a paper on entitled Traditional Cultural Places in Appalachian Virginia and The Mountain-Valley Pipeline. It’s at

I prepared the report at the request of the Greater Newport Rural Historic District Committee – whose National Register-listed district is one of several identified rural historic districts transected by the route of the proposed Mountain Valley Pipeline (MVP) across the Appalachians. My charge was specifically to see whether it looked like the districts involved are traditional cultural places” (or properties) – that is “TCPs” – per National Register Bulletin 38.

For those not directly affected by the proposed pipeline, the most interesting things about what I learned may be the following:

1.    I found the National Register nomination documentation to be largely unhelpful in figuring out whether the districts were TCPs;

2.    I also found it to be of little use in ascertaining whether the districts were “rural historic landscapes” per National Register Bulletin 30;

3.    In fact, I found the documentation to be unenlightening even about why the districts were viewed as districts; the documentation was overwhelmingly about the individual buildings, structures and sites within the districts, not about the districts as landscapes, or as the “concentrations” and “linkages” to which the Register’s definition of “district” refers.

4.    Luckily, some very interesting and helpful studies had been done quite outside the context of historic preservation, about the “cultural attachment” that people in the area feel for their landscapes. Applying the results of these studies to the districts, it became clear that they – or perhaps more likely a landscape embracing all or some of them – is indeed eligible for the National Register as a TCP.

Why does this matter, since most of the districts involved have either been listed on the National Register or authoritatively identified as eligible for it, hence entitling them to consideration under Section 106 of the National Historic Preservation Act? I think it matters in at least two ways:

First, when one looks at a “district” nomination and finds a list of specific buildings, structures and sites, with little or no treatment of the spaces around them, it’s pretty easy to design a new project – like a power line or pipeline – right through the district and think you’re having no adverse effect on it, because your project doesn’t knock down or dig up a “contributing” building, structure or site. You may give some consideration to things like visual effects, but only on those “contributing resources.” The whole idea of the “district” as an entity gets lost.

Second, when a district is characterized only with reference to its constituent buildings, structures and sites – with their significance defined, of course, by historians, architectural historians, and archaeologists – one has no basis for appreciating what makes the district important to the people who live there, work there, or otherwise experience the place. The significance of the district to the people who value it is effectively submerged. When a question arises about a planned project’s potential effects on the district, the concerns of those people can easily be denigrated, as long as one can assure the world that one is not going to muck with the architectural qualities of a building/structure, or the archaeological values of a site.

So – the lesson I take away from this experience, and that I suggest to others, is: if you’re interested in preserving a place that’s important to you, and are encouraged to nominate it to the National Register or offer some representation about its eligibility, think carefully about what you call the place. If you call it a “rural historic district,” you may wind up with something that doesn’t help you much in terms of ensuring that the values you ascribe to the place are given due attention. If you call it a rural historic (or cultural) landscape or TCP you’re probably better off, but even then, pay careful attention to how whoever compiles the documentation describes the place. “Preservation professionals” may automatically slip into architectural and archaeological modes of thought when assigned to describe the historic and cultural qualities of a place. If you use such professionals, somebody needs to be looking over their shoulders to remind them to attend to the spaces around the buildings, structures, and sites, and particularly to listen to the people.

And if you’re a preservation professional (or non-professional) responsible for writing up a place with reference to its National Register eligibility, get familiar with the “cultural attachment” literature – which has mostly been produced with little or no (or ill-advised) reference to historic preservation, but is very, very relevant. Several key sources are cited in my paper, which, again, can be found at

Thursday, September 01, 2016

A Traditional Cultural Place for All U.S. Citizens?

Traditional cultural places (TCPs – see are ordinarily found eligible for the National Register of Historic Places because of their association with the traditional cultural values and believed histories of local communities, Indian tribes, Native Hawaiian groups, and other relatively localized groups. But the other day, someone asked me, more or less out of the clear blue sky, if I could imagine a place that would be a TCP for all citizens of these United States. I was frankly flummoxed. In a nation as diverse, even fragmented, as the U.S., could there be such a place?

Then I was privileged to attend a meeting of the National Mall Coalition (See and – a group that’s struggling to keep the National Mall in Washington DC as a place for use and enjoyment by all people, and to address its many management problems. And of course, I realized, with a smack to the head, that the National Mall is, precisely, a national TCP. Stretching from Capitol Hill past the Washington Monument to the Lincoln Memorial, and from the White House to the Jefferson, studded with monuments and memorials to great and not-so-great people and events in the nation’s shared history, home to multiple museums, including the National Museum of the American Indian ( and now the National Museum of African-American History and Culture (, the National Mall is, precisely – to paraphrase National Register Bulletin 38 – a place whose “significance (is) derived from the role the property plays in (the national) community's historically rooted beliefs, customs, and practices.” In all their chaotic, creative diversity.

And I learned, too, that the National Mall suffers from many of the same sorts of conflicts that – sometimes inevitably, sometimes outlandishly – trouble other TCPs, especially largish landscapes. Just as at, say, the confluence of the Colorado and Little Colorado in the (National Register-eligible TCP) Grand Canyon (c.f., there are conflicts between public use and quiet contemplation. Just as at innumerable TCPs administered by federal agencies across the country, the Mall is managed by an agency that can’t seem to get its arms around the fact that the public in all its diversity ought to have anything to say about its administration. The Mall’s open space is administered mostly by the National Park Service (NPS), which has apparently decided that keeping its grass green is the highest priority. This justifies NPS in giving the boot to events like the Library of Congress’s annual Book Festival (, which used to attract (horrors!) shoe-clad readers to tromp on the tender shoots. Will the Smithsonian Folklife Festival ( be next? Only time and NPS will tell.

It also turns out that the National Mall, like other TCPs, suffers from being the subject of a National Register nomination whose documentation doesn’t attend to its traditional cultural significance. Indeed, the nomination apparently doesn't even give much consideration to the Mall’s organization as the “significant concentration, linkage, or continuity” that in theory makes it qualify as a historic district. (See Allegedly, NPS doesn't even regard the L’Enfant and McMillan Plans that defined the Mall’s development in the 19th and early 20th centuries ( as crucial contributing elements to its current Register significance, and hence worthy of consideration in decision making.

And as usual with TCPs – and historic places generally – management of the National Mall seems to have little patience for real consultation with those who ascribe cultural value to it. Meetings, yes, letters full of nice words, sure, but actually sit down and hammer out compromises between, say, active public use and keeping the grass green? No. This was obviously a source of considerable frustration for Coalition members, whose expressions echoed those I’ve heard from Indian tribes, Native Hawaiian organizations, and citizens’ groups across the nation and around the world with reference to their own TCPs.

Finally, the National Mall – like other TCPs and despite lying right under the noses of Congress and the President – has serious unaddressed management problems, notably tour bus parking, vehicular congestion, and the danger of flooding -- not only by the Potomac River but, even more devastating, as was seen in 2006, by stormwater runoff from higher elevations into low-lying Constitution Avenue museums and public buildings. The Coalition has an intriguing plan for dealing with all three problems (; we can hope that someone in authority will give this plan the attention it deserves, but I’m told that only the Corps of Engineers – rightfully alert to such issues but powerless to do anything without a local request or congressional direction – has shown any leadership. At least it’s nice to be able to say something nice about the Corps for a change.

I’m told that NPS is considering a revised National Register nomination for the National Mall. Although I’m always dubious of the utility of such nominations, in this case it might be an opportunity to get serious attention to the Mall’s traditional cultural qualities, as a basis for its more rational management.