Just posted on Academia.edu (45) Discussion: The Voice of the People: Traditional Cultural Places and National Register Bulletin 38 - Academia.edu: an excerpt from an ebook I'm composing for my granddaughter Olivia (Livy) King, about the life times, and career of her late grandmother, Patricia L. Parker. It deals with the origins of National Register Bulletin 38 on "traditional cultural places."
Bulletin 38
Let’s
rewind, Livy, to the early and mid-1980s. Pat was focused on caring for your
father and finishing her dissertation, and starting to do contract work for the
Park Service.
My
life at the Advisory Council had been dominated by several heavy-duty Section
106 cases having little or nothing to do with the interests that Pat and I
shared. Demolition of the Hudson’s Department Store in Detroit was one, and the
Helen Hayes Theater on Broadway in New York was another – the latter a case in
which the New York Times characterized a letter from me as “the
plaintive wailings of an embattled bureaucrat.” And my ACHP colleagues and I
were doing what we could to fight off the Reagan Administration’s efforts to
eviscerate the National Historic Preservation Act, particularly Section 106 and
the SHPOs. And if possible to make good use of the Reaganauts’ populism.
Populism?
Yes. I don’t know how the word will be used when you read this, Livy, but back
in the day, it was something that sort of kind of made common cause (at least
rhetorically) between people like me and people like Reagan.
Wikipedia
(I hope you still have Wikipedia) says “populism…”
“…refers to a range
of political stances that emphasize the idea of ‘the people’ and often
juxtapose this group against ‘the elite’. The term developed in the 19th
century and has been applied to various politicians, parties, and movements
since that time, although has rarely been chosen as a self-description.”
A
few years before, in his plywood house on the midden spilling down to the shore
in Mechchitiw Village, Chief Chitaro William had handed me a beautiful conch
shell. Pat had translated as he’d said that when I got back to Washington DC,
to the White House (I think he conflated the two), I should keep this conch
shell – used to call people together in the wuut to discuss weighty
topics – to remind me always to listen to the voice of the people.
I’d
tried to do that, and Pat kept reminding me to. I held onto the thin hope that
the populism of Ronald Reagan and his people could somehow be made to amplify
the “voice of the people” embodied in the conch that sat over my desk at the
ACHP[1].
We’ve learned a lot since the 1980s, Livy, and you’ll learn more in the
years to come. Wikipedia now wisely distinguishes between right-wing and
left-wing populism:
“Both right-wing
populism and left-wing populism object to the perceived control of liberal
democracies by elites; however, populism of the left also objects to the power
of large corporations and their allies, while populism of the right normally
opposes immigration…”
I’m a left-wing populist, and so was my boss at the ACHP, Bob Garvey.
Ronald Reagan, we now know, was very much a right-wing populist, and his heirs
– Donald Trump and his compatriots in this country, Boris Johnson in the United
Kingdom, Jair Bolsonaro in Brasil – have pushed right-wing populism to the
point of fascism, and sullied its name.
But none of this was apparent in the 1980s. Cock-eyed optimists like me
imagined that we could build populist bridges with Reagan’s people, and we
tried to do so, without utterly selling our souls.
In
about 1986, about the time your grandma became a “real” Park Service employee, two
cases presented themselves that were all about “the people” versus “elites” and
that seemed to make pretty obvious points precisely at the intersection of
Pat’s and my concerns. One was an urban case – Poletown in Detroit, Michigan;
the other was a quintessential rural, Native American case, the San Francisco
Peaks in Arizona.
Poletown
was an ethnic Polish, mostly Catholic, low-income neighborhood, the wage
earners mostly autoworkers, that had grown up around a Dodge plant (Dodge Main)
built in Detroit’s early 20th century heyday. By the 1980s the plant
had closed, overtaken by automation. The city government, headed by the
charismatic Mayor Coleman Young, had negotiated a deal whereby the U.S.
Department of Housing and Urban Development (HUD) would help the City acquire
and demolish Dodge Main – which had been found
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Coincidentally,
there was a proposal to repair and expand a ski facility on the San Francisco
Peaks, a mountain in New Mexico controlled by the U.S. Forest Service – and a
single mountain, despite its plural name. The Peaks comprised one of the four
corners of the Navajo World, and to the Hopi and Zuni are the home of powerful
Katsina – spirit beings who control the universe. But just as HUD and Detroit
could pretend that the only thing “historic” involved in their proposed
demolition of Poletown was Dodge Main,
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Pat
and I decided we couldn’t let this sort of thing continue.
The
timing was tricky. Ronald Reagan was in the White House; his Secretary of the
Interior, James Watt, had his flunkies leaning on the Park Service and Advisory
Council to keep them and those pesky environmental and historic preservation
laws from “obstructing development[2].”
The general attitude of the historic preservation bureaucracy when confronted
with a challenge in those days (and these) was summed up in a widely quoted
comment by ACHP General Counsel John Fowler: “Pass for now; the risk is too
great.”[3]
But
there was, maybe, an angle. However false it may have been, there was Reagan’s
self-perception as a populist, a man of the people. His recently-installed
Chair of the ACHP, Cynthia Grassby-Baker, made similar noises, as did her
Vice-Chair, Dr. Robert Johns. Several Reagan appointees to the ACHP were quite
solidly populist in their leanings, and reasonable people besides. There
should, Pat and I thought, be a basis for appealing to them to favor taking
care of places that ordinary people, ordinary communities, cared about.
So
with the blessing of Chairman Grassby-Baker and Executive Director Garvey, Pat
and I got to work drafting ACHP guidelines to all federal agencies about how to
consider the effects of their actions on…
Well,
what to call them? What simple term could embrace both Poletown and the San
Francisco Peaks? And how could we link that term to the National Register, and
hence to the requirements of Section 106, without freaking out the Park Service
bureaucrats, who were every bit as risk-averse as Mr. Pass-for-now?
I
don’t remember how we came up with the term “traditional cultural property,”
except that it seemed like the minimum number of words we could use to capture
the notions of being – well, traditional, cultural, and a “property,” the last
word being the one favored in Park Service guidance and regulation to refer to
all the sorts of places (districts, sites, buildings, structures, objects) that
might be eligible for the Register[4].
However we fastened upon the name, and it stuck – now often referred to in
acronym as “TCP.”
What
the guidelines said was nothing earth-shattering. We just talked about how it
was important to avoid ethnocentrism – a narrow focus on how one’s own ethnic
group views things – when deciding whether a place valued by a different sort
of group might be eligible for the Register. We talked about how to apply each
of the criteria for Register eligibility – laid out in Park Service regulations
– to TCPs, and gave examples. We talked about how to study TCPs respectfully,
and we gave a lot of examples – including Mt. Tonaachaw.
Once
a government document is drafted, it has to be reviewed by others, to catch
errors or problems, and resolve disagreements, before it’s finalized. Since the
TCP guidelines were at this point an ACHP initiative, I circulated our draft to
federal agencies, tribes, and various organizations for comment. We got a fair
number of comments, reworked the text as needed, and then with Bob Garvey’s and
the Chairman’s blessing I put it before the full ACHP for review and (we hoped)
approval to be published.
And
the ACHP members did approve it – with one pivotal exception. Dale Lanzone, a
Park Service executive sitting for Secretary Watt, asked that the Council not
approve the document for publication. Considering the power of the Secretary’s
office, the Council members and leadership were duly swayed and tabled it.
As
I recall, Dale was pretty mealy-mouthed in the ACHP open meeting about why
Interior didn’t want the guidelines published, but he was unequivocal about the
Secretary’s opposition, so everything stalled and I went home to name still
another tree after Dale and take my axe to it[5].
Within
days, however, Pat and I were in Dale’s office, at his invitation[6],
and he made it clear that he had no issue with the substance of what we’d put
together. He just didn’t want it issued by the ACHP because really, it was
mostly about National Register eligibility, wasn’t it? So really, the National
Register should publish it, as one of its Bulletins.
Well.
I
recall having an argument with Pat about whether we should agree to Dale’s
proposition, but I don’t remember which of us took which side. By this time
Livy, your grandma and I had been married about ten years, we’d lived through
your dad’s earliest years, and we often could complete one another’s sentences.
But one of us said it was absurd for Dale to waltz in at the eleventh hour,
after all the work was done, and decide that Interior should take credit for
the document. It was probably I who took that position, though that’s not how I
remember it.
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And
besides – though I recall having to walk Chairman Cynthia back from fighting it
out with Interior over the matter – we really had no choice. Politically, all
the eggs were in Dale’s basket.
So
we went to work tinkering with the document – it didn’t take much – and the
result was National Register Bulletin 38: Guidelines for the Identification
and Documentation of Traditional Cultural Properties, first published in
1990[8].
A lot of ink has been
spilled about Bull38; it’s been cited in a fair amount of litigation, and it’s
been helpful, I think, to quite a few tribes and other indigenous groups trying
to preserve their special places[9]. It’s
helped environmental and historic preservation consultants prevail upon their
clients to pay attention to TCPs and consult with those who value them. In the
words of Penny Rucks, an ethnographic consultant in Nevada, “It made it
possible to slow the boat and sometimes welcome others on board[10].”
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[1]
The conch is shown on the cover of my boring textbook, “Cultural Resource Laws
and Practice” https://www.goodreads.com/book/show/6525161-cultural-resource-laws-and-practice
[2] My
association of the flunkies’ names with the trees I chopped down in our back
yard on Windsor Street seemingly had no effect on the flunkies, but it
motivated me.
[3]
Thanks for then-ACHP Senior Architect, the late John Cullinane for making it
widely quoted.
[4]
NPS now prefers “Places,” and that’s fine with me as it was with Pat.
[5] I
think this was about the third I’d axed in Dale’s name. I later worked for him
at the General Services Administration, and we got along famously. That’s
Washington.
[6] I
think he had invited us as the ACHP meeting was breaking up, and he made
reassuring noises. That didn’t stop me from chopping down his tree.
[7]
Jerry Rogers, in a comment on a draft of this book, says: “A lot of serendipity
was involved in this. I had been looking
for several years for a way to get that Administration to accept the concept of
“Ethnographic Landscapes” as described by Robert Melnick, and Bulletin 38
provided a way.” It’s getting way too deep in the weeds, but I dislike
“ethnographic landscapes” because they’re envisioned by professionals,
top-down, and what Pat and I were after was bottom-up, recognizing that
people’s values counted, regardless of how professionals construed them.
[9]
Non-indigenous communities have made much less use of it, which I – recalling
Poletown – think is very sad.
[10]
E-mail to me, 7/4/2020
