Sunday, July 04, 2021


Well, here we go again. “Phases” in/of archaeological/cultural resources survey.

Yesterday morning (7/3/2021), a Facebook poster asked what kinds of technical training and experience she can get that would increase her value to potential archaeological employers. Responses were all over the map, ranging from getting to know about soils to English composition and beyond. One of the respondents wisely recommended that she take a field school, but went on to say: “preferably one that emphasizes aspects of all 3 phases.”

I knew what the poster meant by “3 phases,” but asked the dumb question anyway:


The answer, promptly provided by another commenter, was:

“a phase I is survey, phase II is evaluation, and phase III is data recovery/excavation.”

I have written in multiple editions of multiple textbooks and quite a few journal articles and Internet postings about how mind deadening, ill considered, and damaging this simplistic “phase–by–phase” notion is, ever since the 1980s when it was first (to my knowledge) advanced. Maybe I’ve not been clear enough, so let’s try it again.

First off, there is no law or government-wide regulation that calls for such “phases.” Though some government agencies and State Historic Preservation Officers (SHPOs) have written phasing, under various names, into their manuals and field procedures, that doesn’t make it law. What Section 106 of the National Historic Preservation Act (NHPA), via its regulations (36 CFR 800) does require is that agencies identify historic places (not just archaeological sites) subject to effect by their proposed undertakings, ascertain whether these places are eligible for the National Register of Historic Places (NRHP), and try to figure out ways to avoid, minimize, or otherwise mitigate impacts on such places.

So doesn’t that mean the same thing? No. Let’s look at what it does mean.


First, note that the law and regs aren’t about archaeology; they’re about historic properties, or more broadly cultural heritage. If one is interested only in archaeology, one can ignore this, but sooner or later one is likely to get tripped up by some other kind of “heritage” – for example landscapes, buildings, plants, animals, atmospheric conditions and social practices that people regard as culturally important. Or worse, one will not get tripped up, and will happily go on playing archaeologist, pretending that archaeology is the be-all and end-all of humanity’s cultural heritage, and usually thus conniving with the interests of those who would plow under that heritage in the interests of short-term profit. That strikes me as pretty reprehensible.


Turning to the “three-phase” definition, in the context of the NHPA’s requirements, what does it mean to identify historic places subject to effect by a proposed undertaking? Doesn’t that mean doing a survey?

Not necessarily. If you already know a great deal about the area(s) that may be affected, you may not need to do a survey; it may be a waste of time and money. But you do have to ascertain what you already do know about the area, and that’s why – one reason why – the Section 106 regulations call for “scoping:” sitting down with people who know about the area and figuring out what’s known and not known, and how to go about making the unknown known.

Based on scoping, you may decide to do one kind of field survey in one environment and another in another. You may decide that some areas don’t need to be surveyed at all. You may decide that some areas need to be probed in great detail using remote sensing, or forensic canines. You may decide that archaeological survey is irrelevant but architectural survey is needed. Or cultural landscape identification. And so on. Scoping is absolutely key to doing responsible historic property identification.

Scoping, and the consultation with interested parties that it must involve, tends to be neglected, if not ignored altogether, when one prescribes a “Phase I” survey following some standard system – which, in my experience, often involves merely walking transects across the area where direct effects are expected and maybe digging holes at specified intervals, all without talking to anybody who lives in or knows about the area.

This kind of walking and digging survey is usually useful – if at all – in places where direct physical impact is anticipated – the places that will be bulldozed or blown up or paved over by a project. But often the most important impacts are not physical, or not direct. Consider the visual impacts of a proposed array of solar panels or a field of wind turbines. Consider the social impacts of a highway reconstruction project on a nearby – or maybe not so nearby – low income or minority neighborhood. Consider the impacts of recreational boaters on a stretch of river held by an indigenous group to be spiritually sensitive, or where its members engage in traditional fishing. Does walking transects and digging test pits make sense in such a case? Probably not, but other measures probably are needed. This again is why sensitive, thoughtful scoping is vital, and short-circuiting it through the imposition of standardized survey prescriptions is irresponsible.

I understand that some federal agency undertakings are so simple and routine that they may not require this kind of scoping-based identification. It may be perfectly reasonable for an agency, or an SHPO, to say for example, “when considering the effects of a proposed powerline in Rockrim County, routinely conduct background research, surface survey, and testing along the right-of-way, and interview everyone who lives or works within sight of the proposed line about impacts on places of cultural importance to them.” In such a case you’re essentially saying that you know enough about Rockrim County to reasonably think that the measures outlined will be adequate. But when you’re not in this happy position you really need to do scoping. On the basis of which you can design and follow a scope of work for identification.

If you’re interested, you’ll find a fairly extended discussion of this kind of thing on pages 28 to 38 of my 2020 textbook, Cultural Resource Management: a Collaborative Primer for Archaeologists (Berghan Books New York/Oxford).


So what about “phase II evaluation?” Doesn’t evaluation always follow identification?

Again, not necessarily. First, of course, some things may already have been evaluated – though you always want to make sure that whatever it is has been evaluated from all the relevant perspectives: traditional cultural, architectural, archaeological, and so on. Or there may be no need for much evaluation. If you found that the undertaking just really isn’t going to affect very much of anything, then there’s little need to go to the trouble of evaluating anything – though some may insist on it as matter of procedural nicety or to build up their data files or to pad their pockets.

Or you may simply be able to take people’s word for it. If, say, a tribe says that the Rollicking River is a really important cultural place, the diplomatic (and truthful) thing to do may be to say okay, then it must be eligible for the National Register under 36 CFR 60.4(a). Somebody else – maybe your client – may question this assumption, and it may be necessary to ask more questions and develop more information, but you oughtn’t start out with the assumption that you’ve got to go through a formal evaluation process, and you certainly shouldn’t assume or imply that your evaluations of significance are as important as those of the people who value the place. Particularly, but not only, if those people comprise a federally recognized Indian tribe or a Native Hawaiian group.

What I think is especially reprehensible is the notion that a place is not significant, not eligible for the National Register, not entitled to consideration under Section 106, until some “professional” hired by an affected community has formally evaluated it, and perhaps ushered it through the Byzantine NRHP nomination process so loved by the National Park Service. It is not the responsibility of those whose cultural values are threatened by a project to demonstrate that the places they value are eligible for Uncle Sugar’s National Register. It is the responsibility of federal agencies, and those they license or permit, to ascertain what is significant, in respectful consultation with those to whom things may matter. This is the logical interpretation of federal responsibilities under President Nixon’s Executive Order 11593, but it seems to be happily ignored by many interpreting the laws today.

But I digress. My simple point is that yes, somebody has to figure out whether a threatened place is significant enough to be a subject of concern, but that does not mean that a hired archaeologist – or architectural historian, or “cultural resource management expert” – must go through some sort of standard process and make an authoritative decision in the matter. Evaluation is a complicated business, not reducible to a standardized “phase” of study.


This is where the “phased” interpretation of agency/client/consultant responsibility most especially leaves all four wheels spinning separately on the road. Look at the standard definition of “Phase III” – “Data Recovery/Excavation.” That’s the be-all and end-all. Never mind if your “Phase I” has identified a significant place – be it a township, a farmstead, a mountain, a forest, an urban neighborhood, the sound of the wind through the trees, a river, a population of marine mammals, fish, or horses – and never mind that your “Phase II” has concluded that yes, this place is eligible for the National Register. The only imaginable “Phase III” outcome is data recovery/excavation. Dig it up or otherwise extract data from it before it’s destroyed.

Does this make any kind of sense? Does it have anything to do with historic preservation? With “cultural resource management?” Is it even good archaeological practice? I don’t think so.

What do you think?



Leslie Perkins said...

Testing comments based on your FB post.

Unknown said...

Tom, you've outdone yourself with this exquisite description: "It is not the responsibility of those whose cultural values are threatened by a project to demonstrate that the places they value are eligible for Uncle Sugar’s National Register." And, that CRM practice needs a reminder of this is so, unfortunately, true.

Thomas F King said...

Thanks. I'm sort of amazed that such an obvious point should be misunderstood.