I’m reviewing a report on an area’s “cultural resources” (by which the authors seem to mean archaeological stuff, with an occasional bow to old buildings), prepared in connection with an environmental impact assessment of a proposed land use project. Toward its end, as something of an afterthought, the report talks a little about whether the landscape within which lie the hundreds of “archaeological sites” it’s described might be a “traditional cultural property” (TCP) that’s eligible for the National Register of Historic Places.
The report was prepared by contractors working for the private company that proposes to build stuff all over the subject landscape, so predictably (given sad current practice) its authors do everything they can to downplay the area’s cultural significance – except to some extent the research significance of the “archaeological sites,” which they can be paid to dig up as “mitigation.” So, despite pretty vehement representations by tribes that value the landscape (and without consulting the tribes, the SHPO, or apparently anybody else), they say nope, it’s not a TCP.
Why? Because, they say:
TCPs … must exhibit long term use or sustained awareness by the community.
In other words, if the relevant community hasn’t “used” the property over the “long term,” and/or maintained some kind of unspecified “awareness” of it, the property is not a TCP.
Now, in this particular case it’s notable that nobody seems to have asked the tribes whether and how they “use” the landscape in question, or what “awareness” they have of its cultural significance (Archaeologists, after all, are experts, so they must just know this stuff through osmosis or something). In fact there are good reasons to think that tribal members are well aware of the landscape and its cultural character, and use it for both spiritual purposes and the education of youth. But never mind the particulars: does it make sense to say, in principle, that a community must continue to “use” a place, or be “aware” of specifics about it, in order for it to be a TCP, and eligible for the National Register as such?
Continuing Use
National Register Bulletin 38 (http://www.nps.gov/nr/publications/bulletins/pdfs/nrb38.pdf ), which (like it or not) is the National Register’s official word on the subject, says:
The fact that a property may have gone unused for a lengthy period of time, with use beginning again only recently, does not make the property ineligible for the (National) Register.
The Bulletin goes on to posit a situation in which a group revered a particular mountain in the past, but then was forcibly relocated to someplace where it could not readily access the mountain, and coerced into a religious conversion that caused them to ignore the mountain’s spiritual significance. It goes on to imagine the group now undergoing a cultural revival in which it seeks to reconstruct its relationship with the mountain, and concludes:
The fact that the contemporary use of the peak has little continuous time depth does not make the peak ineligible; the peak’s association with the traditional activity reflected in its contemporary use is what must be considered in determining eligibility.
So you don’t have to have “continuing use,” and let me add that it would be especially ironic (to put it mildly) for the federal government – which for many decades pursued policies of disconnecting tribes from their traditional religions and lands – to insist on “continuing use” as a prerequisite to recognizing a place’s cultural significance.
Sustained Awareness
But does the tribe or other group not at least have to be aware of the place in order for it to be significant? We didn’t think about this one in writing Bulletin 38, but it soon came up in practice, and I discussed it on pages 256-7 of Places That Count, my 2006 book on TCPs (http://www.amazon.com/Traditional-Cultural-Properties-Resource-Management/dp/0759100713) . As an example I looked briefly at Hopi and Zuni beliefs that their ancestors traveled all over the Southwest after their emergence into this world, guided, facilitated, and impeded by supernatural forces. The Hopi and Zuni have said that wherever their ancestors left evidence of their passing, that’s a TCP. They don’t know where all those places are, but they know them when they see them. Similarly, I quoted from an Australian case in which an aboriginal expert from one part of the country was able to recognize a place in an area he had never before visited, because of the way it is described in a traditional story, and thus know that (a) it was associated with a moiety not his own and (b) it was to be respected as such.
Clearly, a Hopi or Zuni elder cannot be said to have had “sustained awareness” of, say, archaeological site AZ-CIB-666P5 (if there is such a place), which he or she has never seen. But he or she knows that such places – with particular kinds of potsherds and masonry – are associated with the ancestors, and he or she knows that if he or she does visit it, there are things to be done to show respect – prayers, maybe an offering – and that one ought not mess the place up if one can help it. The aboriginal expert in the Australian case knew that there were things to do – maybe recite from a song, maybe refrain from picking things up – to respect the ancestral spirits of the moiety associated with the hitherto unvisited place. Are these associations sufficient to make such a place eligible for the National Register? I think so, though perhaps reasonable people can disagree. But surely it is clear that the mere fact that the Hopi don’t know precisely where each site associated with the ancestors is and what it looks like does not automatically make such sites ineligible for the Register; still less does it render them “not-TCPs.”
Unfortunately, the “continuing use” and “sustained awareness” criteria seem to be slipping into the practice of identifying (or trying hard not to identify) TCPs – spurred by the desire to avoid recognizing and dealing with such properties and to facilitate the projects of those who pay us CRM practitioners to make ostensibly objective and authoritative studies. If you want to use these criteria to help your client run roughshod over the cultural environment, that’s up to you, but please don’t pretend that you’re reflecting some widespread best practice or government guideline.
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.
Showing posts with label cultural resource management. Show all posts
Showing posts with label cultural resource management. Show all posts
Tuesday, November 01, 2011
Tuesday, September 06, 2011
The Lihir Islands: a Cultural Heritage/Resource Planning Model?
The latest issue (18:1, 2011) of the International Journal of Cultural Property (Cambridge University Press) contains a number of thought-provoking papers. One that should be of special interest to those involved in environmental impact assessment (EIA) and cultural resource management (CRM) is "Stepping Stones Across the Lihir Islands: Developing Cultural Heritage Management in the Context of a Gold-Mining Operation," by Nicholas Bainton, Chris Ballard, Kirsty Gillespie, and Nicholas Hall (pp. 81-110].
The Lihir Islands are in Papua New Guinea (PNG). Bainton and his colleagues provide a concise summary of how cultural heritage/resource management law and practice have developed in PNG in the post-colonial period, including their hopeful if rather tenuous relationship to national development schemes and the interests of extractive industries like gold mining. They then discuss their own experience with a particularly tricky relationship -- that between the traditional people of the gold-rich Lihir Islands and the mining company Lihir Gold Ltd. (LGL) At the center of this uneasy relationship is Ailaya, a cultural landscape of considerable spiritual significance to the Lihirians, around which mining has taken place and within which there are economic incentives to mine (i.e. there's gold in that thar landscape). The evident conflict between mining and preservation of the landscape has not been resolved, but the Lihirians and Stepwise Heritage and Tourism, the Australian company that engaged Bainton and his colleagues and drew financial backing from LGL, have taken significant-seeming steps toward creating a context in which to address this and other development/culture conflicts by developing the Lihir Cultural Heritage Plan, whose pidgin name translates as “A Plan for Social Stability and Harmony on Lihir.” The authors' discussion of how this plan was developed in active collaboration with (really BY) Lihirian communities is fascinating, and may provide something of a model that – with much adaptation – could be useful elsewhere. It was interesting to me that the Lihir initiative employed the popular Australian "footsteps" approach to planning, which I've seen referred to and described but never until now could quite get into my head. Bainton and his colleagues show how "footsteps" works, and it seems very sensible. It will be interesting to see how successful the Plan is at resolving the seemingly inevitable conflict between mining and the sanctity of Ailaya, but one of the Plan's heartening aspects is that it does not (apparently) focus on the sacred landscape in its own right, for its own sake, as we would tend to do if it were in the U.S. and treated as eligible for the National Register of Historic Places. Rather, as I understand it from this article, the Plan truly focuses on social stability and harmony on Lihir. In this broad context, management of Ailaya will inevitably play an important role, but not necessarily a determinative one, and not in isolation from the rest of what Lihirians value in their culture.
The Lihir Islands are in Papua New Guinea (PNG). Bainton and his colleagues provide a concise summary of how cultural heritage/resource management law and practice have developed in PNG in the post-colonial period, including their hopeful if rather tenuous relationship to national development schemes and the interests of extractive industries like gold mining. They then discuss their own experience with a particularly tricky relationship -- that between the traditional people of the gold-rich Lihir Islands and the mining company Lihir Gold Ltd. (LGL) At the center of this uneasy relationship is Ailaya, a cultural landscape of considerable spiritual significance to the Lihirians, around which mining has taken place and within which there are economic incentives to mine (i.e. there's gold in that thar landscape). The evident conflict between mining and preservation of the landscape has not been resolved, but the Lihirians and Stepwise Heritage and Tourism, the Australian company that engaged Bainton and his colleagues and drew financial backing from LGL, have taken significant-seeming steps toward creating a context in which to address this and other development/culture conflicts by developing the Lihir Cultural Heritage Plan, whose pidgin name translates as “A Plan for Social Stability and Harmony on Lihir.” The authors' discussion of how this plan was developed in active collaboration with (really BY) Lihirian communities is fascinating, and may provide something of a model that – with much adaptation – could be useful elsewhere. It was interesting to me that the Lihir initiative employed the popular Australian "footsteps" approach to planning, which I've seen referred to and described but never until now could quite get into my head. Bainton and his colleagues show how "footsteps" works, and it seems very sensible. It will be interesting to see how successful the Plan is at resolving the seemingly inevitable conflict between mining and the sanctity of Ailaya, but one of the Plan's heartening aspects is that it does not (apparently) focus on the sacred landscape in its own right, for its own sake, as we would tend to do if it were in the U.S. and treated as eligible for the National Register of Historic Places. Rather, as I understand it from this article, the Plan truly focuses on social stability and harmony on Lihir. In this broad context, management of Ailaya will inevitably play an important role, but not necessarily a determinative one, and not in isolation from the rest of what Lihirians value in their culture.
Monday, August 01, 2011
Reflections on a Visit to China, Part 1: Generalities
Introduction
With my wife, Pat Parker, I recently enjoyed a little under three weeks in the People’s Republic of China. At the invitation of the Chinese Academy of Social Sciences (CASS), Institute of Archaeology, I gave a paper in Beijing at the World Archaeological Congress (WAC) “Intercongress” on cultural heritage management in eastern and southeastern Asia, and we visited sites around Beijing, Xi’an and the mausoleum of emperor Qin shi Huangdi, often with the kind and knowledgeable assistance of Institute archaeologist Mr. Wang Renyu. On our own (with guides) we visited Hangzhou, Suzhou, Honcun, Xidi, Tongli, the Yellow Mountain Huangshan, and (briefly) Shanghai. I’m very grateful to Mr. Wang, CASS researcher Li Chunlin, Institute Deputy Director Prof. Chen Xingcan, and all their colleagues, as well as our China Odyssey guides, for making our visit a pleasurable and very educational one.
Three weeks in a country confers no expertise in its character, history, archaeology or culture, but there may be something to be said for first impressions, so I’m going to take this opportunity to offer a few reflections on our visit, for whatever they may be worth.
Environmental Matters
What they say about the air in Beijing is true. Within three days, the Navajo silver bracelet that Pat routinely wears had turned black (it cleaned up, though). Luckily (or maybe due to cloud seeding) there was then a thunderstorm and the sky turned clear and blue. But yes, pollution is a serious issue. However, there is apparently a serious effort underway to reduce emissions. For example, almost every rooftop seemed to sport a solar water heater. I saw few or no photovoltaic arrays, but lots of solar heating was going on. And while there are certainly too many gasoline and diesel vehicles on the (extensive and seemingly well-maintained) expressways, we also saw a vast number of bicycles, scooters, motorcycles and other vehicles driven by electricity, heavy use of public transport, and a lot of cars running on compressed natural gas.
As an inveterate recycler, I was charmed to see recycling bins almost everywhere, side-by-side with containers for non-recyclable trash, clearly labeled but often disguised as architectural forms compatible with historic structures, as rocks, as ancient urns, and in other clever ways. And lots and lots of people collecting discarded trash, moving huge piles of flattened cardboard boxes to collection points, and so on. The big cities we visited (e.g. Beijing, Shanghai) were remarkably clean, as big cities go.
I came away with no clear idea of how environmental impact assessment (EIA) is done. That it is done, somehow or other, was clear from, for example, an interesting paper at the Intercongress on archaeological survey and data recovery along a stretch of the humongous South-to-North Water Transfer Project (where, as here, “avoidance” of archaeological sites is apparently given precedence over excavation/destruction). Clearly studies are done and efforts are made to minimize and otherwise mitigate impacts, but it’s not clear to me how it happens, or what range of environmental variables are addressed. I’d like to know more.
Oh yes – and we rode the bullet train from Hangzhou to Shanghai the day after two similar trains collided not far away in Wenzhou City, and for what it’s worth, it was clean, pleasant, quiet, fully loaded with passengers, and really fast. And on time. I can’t testify to its safety, except to say that we survived, and enjoyed the ride.
Social-Cultural-Political Matters
We saw no particular evidence of oppression or repression (though there was no getting on Facebook, and one of the sites on which I routinely “click-to-donate” was blocked – doubtless because the donations go to Amnesty International). On the contrary, we were impressed at how many people we saw simply enjoying themselves – dancing, singing, and playing traditional instruments in the parks, in one case an apparently impromptu brass band of retirees playing patriotic music while people around them sang with seemingly unrestrained enthusiasm. We found people to be unfailingly gracious, friendly, and seemingly positive in their outlooks. And we were impressed at the volume of internal tourism we saw: thousands upon thousands of Chinese tourists crowding every historic or scenic site we visited, apparently having a good time and appreciating their country’s heritage. And having the disposable income to do so.
But in talking with some ordinary citizens, where language barriers permitted (neither Pat nor I, alas, speak Mandarin or any other Chinese dialect, and Rosetta Stone, while helpful, wasn’t enough), I was interested to encounter a lot of pretty frank expressions of unhappiness with corruption at high levels of government, inefficiencies, restraints on freedom of speech (especially as regards the Internet), and the growing gap between rich and poor. “Communism is dead,” one person volunteered; “all we have left is the Party.” And we crossed paths with one group of high Party officials getting the royal treatment at a couple of hotels where we stayed, to the disgruntlement of some around us. Of course, one could hear similar things expressed, and see similar kowtows to authority, in the U.S.
I couldn’t resist the impression, though – in the context of observing the incredible amounts of money being lavished on historic site development and internal tourism – that the government is pursuing a sort of bread and circuses policy: giving the people enough goodies to keep them off the streets, except when engaged in seemingly innocuous pursuits like tourism.
Cultural Heritage Management
Speaking of which: we were literally agog at the financial resources the PRC and its provincial governments are committing to aspects of cultural heritage/cultural resource management. At Xi’an, for example, the site of the Tang Dynasty (618-907 CE) Daming Palace – leveled hundreds of years ago and built over – has been cleared (relocating 100,000 or so people in the process) and developed as an archaeological park complete with a reconstructed monumental gatehouse, a scale model of the whole palace complex, an interactive archaeological museum (that even tries to explain field methodology!), and an Imax movie house showing relevant 3-D movies.
That’s before you leave town to go visit the first emperor, Qin shi Huangdi (aka Qin shi Huang, Qin Shihuangdi; 259-210 BCE) in his mausoleum, guarded by his terra cotta soldiers and horses. The terra cotta army as excavated so far is actually about a quarter mile from the mausoleum, in a very handsome park/museum complex incorporating the ongoing excavations. There are lots of soldiers, horses, and chariots, apparently, still to be uncovered, and who knows what else?
A quarter-mile away, the protected, still unexcavated mausoleum itself (bigger than the Great Pyramid of Khufu) and its extensive grounds have also become a park, with two museums under construction on the sites of major discoveries of burials, bronze chariots, armor, and other remarkable stuff. There are moves afoot to clear away nearby residential and industrial developments and expand the controlled area. All these developments are relatively recent; Mr. Wang showed me images from the early 20th century showing the whole area under agricultural use.
Xi’an is not unique in its attention to and investment in cultural and natural heritage sites. We saw similar investments being made in the interpretation and development of segments of the Great Wall, the Zhokoudian H. erectus site, river towns on the lower Yangtze, the Bund in Shanghai, and the Yellow Mountain Huangshan. All these places – most of them inscribed in the World Heritage List (and proudly advertised as such) were drawing vast, vast numbers of tourists, all paying fees for the privilege of visiting.
I was very impressed – mostly favorably – by all this investment, and all this interest. But the impression of bread and circuses continued to rattle around in my mind, and it generated another (though related) niggling worry as well. The history of China is characterized by a series of fairly autocratic imperial dynasties punctuated by peasant revolts. The uprising of 1989 that we associate with Tiananmen Square (where now a huge TV screen straddles the space, complicating assembly while inspiring with scenic and patriotic views but, I’m told, playing hell with the place’s feng shui) can be viewed as a recent unsuccessful example of the latter; the Cultural Revolution of 1966-76 was, in a twisted way, another such revolt. I had to wonder – viewing the magnificent cultural site developments, many of them seeming to glorify the imperial past (There’s a huge statue of Qin shi Huangdi – by all accounts not a very nice fellow – that greets visitors to the terra cotta army), and hearing people grumble about the rich/poor divide and the power of the Party – is the PRC government setting itself up for another revolt, and is “cultural heritage,” in the form of all these magnificent archaeological parks and similar developments, likely to become a target of revolutionary ire?
As it did, in many ways, during the Cultural Revolution. Countless times we were told: “There used to be a Buddhist shrine here, but during the Cultural Revolution….,” or “There was a handsome tablet here memorializing the ancestors, but during the Cultural Revolution….” I sat one day in the garden of a 19th century Qing Dynasty official, handsomely restored by his son in the early 20th century before he, the son (also a distinguished government official) was denounced and had to flee the country during the Cultural Revolution. The garden was classic – a complex of plantings, elaborate pavings, sculptures and stone constructions providing delightful vistas and enclaves. Many of the trees were marked with old marble slabs on which genus and species were inscribed in Chinese and Latin. I thought, “How beautiful, and erudite, and precious (in both senses of the word),” and – rather to my surprise – found myself kind of sympathizing with the Cultural Revolutionaries. I imagined them wondering, with sneering ire, where this aristocrat got off sitting around contemplating his beautiful garden and pondering the splendors of speciation when The People were suffering? It was an easy jump to imagining contemporary or near-future revolutionaries asking similar questions about massive investments in exhibiting the relics of past emperors.
Only after I’d left China did it occur to me to wonder whether anybody is pursuing the archaeology of the 700,000 workers said to have been involved in building Qin shi Huangdi’s mausoleum – along the lines of the recent exploration of the workers’ town associated with the Giza pyramids. It seems like some serious attention would be in order to the archaeology of the common people on whose labors the emperor (and every emperor) depended – both because it would be fascinating research and because it would convey a more populist, if not precisely communist, message to the visiting public about the glories of China’s past.
-- To be continued --
With my wife, Pat Parker, I recently enjoyed a little under three weeks in the People’s Republic of China. At the invitation of the Chinese Academy of Social Sciences (CASS), Institute of Archaeology, I gave a paper in Beijing at the World Archaeological Congress (WAC) “Intercongress” on cultural heritage management in eastern and southeastern Asia, and we visited sites around Beijing, Xi’an and the mausoleum of emperor Qin shi Huangdi, often with the kind and knowledgeable assistance of Institute archaeologist Mr. Wang Renyu. On our own (with guides) we visited Hangzhou, Suzhou, Honcun, Xidi, Tongli, the Yellow Mountain Huangshan, and (briefly) Shanghai. I’m very grateful to Mr. Wang, CASS researcher Li Chunlin, Institute Deputy Director Prof. Chen Xingcan, and all their colleagues, as well as our China Odyssey guides, for making our visit a pleasurable and very educational one.
Three weeks in a country confers no expertise in its character, history, archaeology or culture, but there may be something to be said for first impressions, so I’m going to take this opportunity to offer a few reflections on our visit, for whatever they may be worth.
Environmental Matters
What they say about the air in Beijing is true. Within three days, the Navajo silver bracelet that Pat routinely wears had turned black (it cleaned up, though). Luckily (or maybe due to cloud seeding) there was then a thunderstorm and the sky turned clear and blue. But yes, pollution is a serious issue. However, there is apparently a serious effort underway to reduce emissions. For example, almost every rooftop seemed to sport a solar water heater. I saw few or no photovoltaic arrays, but lots of solar heating was going on. And while there are certainly too many gasoline and diesel vehicles on the (extensive and seemingly well-maintained) expressways, we also saw a vast number of bicycles, scooters, motorcycles and other vehicles driven by electricity, heavy use of public transport, and a lot of cars running on compressed natural gas.
As an inveterate recycler, I was charmed to see recycling bins almost everywhere, side-by-side with containers for non-recyclable trash, clearly labeled but often disguised as architectural forms compatible with historic structures, as rocks, as ancient urns, and in other clever ways. And lots and lots of people collecting discarded trash, moving huge piles of flattened cardboard boxes to collection points, and so on. The big cities we visited (e.g. Beijing, Shanghai) were remarkably clean, as big cities go.
I came away with no clear idea of how environmental impact assessment (EIA) is done. That it is done, somehow or other, was clear from, for example, an interesting paper at the Intercongress on archaeological survey and data recovery along a stretch of the humongous South-to-North Water Transfer Project (where, as here, “avoidance” of archaeological sites is apparently given precedence over excavation/destruction). Clearly studies are done and efforts are made to minimize and otherwise mitigate impacts, but it’s not clear to me how it happens, or what range of environmental variables are addressed. I’d like to know more.
Oh yes – and we rode the bullet train from Hangzhou to Shanghai the day after two similar trains collided not far away in Wenzhou City, and for what it’s worth, it was clean, pleasant, quiet, fully loaded with passengers, and really fast. And on time. I can’t testify to its safety, except to say that we survived, and enjoyed the ride.
Social-Cultural-Political Matters
We saw no particular evidence of oppression or repression (though there was no getting on Facebook, and one of the sites on which I routinely “click-to-donate” was blocked – doubtless because the donations go to Amnesty International). On the contrary, we were impressed at how many people we saw simply enjoying themselves – dancing, singing, and playing traditional instruments in the parks, in one case an apparently impromptu brass band of retirees playing patriotic music while people around them sang with seemingly unrestrained enthusiasm. We found people to be unfailingly gracious, friendly, and seemingly positive in their outlooks. And we were impressed at the volume of internal tourism we saw: thousands upon thousands of Chinese tourists crowding every historic or scenic site we visited, apparently having a good time and appreciating their country’s heritage. And having the disposable income to do so.
But in talking with some ordinary citizens, where language barriers permitted (neither Pat nor I, alas, speak Mandarin or any other Chinese dialect, and Rosetta Stone, while helpful, wasn’t enough), I was interested to encounter a lot of pretty frank expressions of unhappiness with corruption at high levels of government, inefficiencies, restraints on freedom of speech (especially as regards the Internet), and the growing gap between rich and poor. “Communism is dead,” one person volunteered; “all we have left is the Party.” And we crossed paths with one group of high Party officials getting the royal treatment at a couple of hotels where we stayed, to the disgruntlement of some around us. Of course, one could hear similar things expressed, and see similar kowtows to authority, in the U.S.
I couldn’t resist the impression, though – in the context of observing the incredible amounts of money being lavished on historic site development and internal tourism – that the government is pursuing a sort of bread and circuses policy: giving the people enough goodies to keep them off the streets, except when engaged in seemingly innocuous pursuits like tourism.
Cultural Heritage Management
Speaking of which: we were literally agog at the financial resources the PRC and its provincial governments are committing to aspects of cultural heritage/cultural resource management. At Xi’an, for example, the site of the Tang Dynasty (618-907 CE) Daming Palace – leveled hundreds of years ago and built over – has been cleared (relocating 100,000 or so people in the process) and developed as an archaeological park complete with a reconstructed monumental gatehouse, a scale model of the whole palace complex, an interactive archaeological museum (that even tries to explain field methodology!), and an Imax movie house showing relevant 3-D movies.
That’s before you leave town to go visit the first emperor, Qin shi Huangdi (aka Qin shi Huang, Qin Shihuangdi; 259-210 BCE) in his mausoleum, guarded by his terra cotta soldiers and horses. The terra cotta army as excavated so far is actually about a quarter mile from the mausoleum, in a very handsome park/museum complex incorporating the ongoing excavations. There are lots of soldiers, horses, and chariots, apparently, still to be uncovered, and who knows what else?
A quarter-mile away, the protected, still unexcavated mausoleum itself (bigger than the Great Pyramid of Khufu) and its extensive grounds have also become a park, with two museums under construction on the sites of major discoveries of burials, bronze chariots, armor, and other remarkable stuff. There are moves afoot to clear away nearby residential and industrial developments and expand the controlled area. All these developments are relatively recent; Mr. Wang showed me images from the early 20th century showing the whole area under agricultural use.
Xi’an is not unique in its attention to and investment in cultural and natural heritage sites. We saw similar investments being made in the interpretation and development of segments of the Great Wall, the Zhokoudian H. erectus site, river towns on the lower Yangtze, the Bund in Shanghai, and the Yellow Mountain Huangshan. All these places – most of them inscribed in the World Heritage List (and proudly advertised as such) were drawing vast, vast numbers of tourists, all paying fees for the privilege of visiting.
I was very impressed – mostly favorably – by all this investment, and all this interest. But the impression of bread and circuses continued to rattle around in my mind, and it generated another (though related) niggling worry as well. The history of China is characterized by a series of fairly autocratic imperial dynasties punctuated by peasant revolts. The uprising of 1989 that we associate with Tiananmen Square (where now a huge TV screen straddles the space, complicating assembly while inspiring with scenic and patriotic views but, I’m told, playing hell with the place’s feng shui) can be viewed as a recent unsuccessful example of the latter; the Cultural Revolution of 1966-76 was, in a twisted way, another such revolt. I had to wonder – viewing the magnificent cultural site developments, many of them seeming to glorify the imperial past (There’s a huge statue of Qin shi Huangdi – by all accounts not a very nice fellow – that greets visitors to the terra cotta army), and hearing people grumble about the rich/poor divide and the power of the Party – is the PRC government setting itself up for another revolt, and is “cultural heritage,” in the form of all these magnificent archaeological parks and similar developments, likely to become a target of revolutionary ire?
As it did, in many ways, during the Cultural Revolution. Countless times we were told: “There used to be a Buddhist shrine here, but during the Cultural Revolution….,” or “There was a handsome tablet here memorializing the ancestors, but during the Cultural Revolution….” I sat one day in the garden of a 19th century Qing Dynasty official, handsomely restored by his son in the early 20th century before he, the son (also a distinguished government official) was denounced and had to flee the country during the Cultural Revolution. The garden was classic – a complex of plantings, elaborate pavings, sculptures and stone constructions providing delightful vistas and enclaves. Many of the trees were marked with old marble slabs on which genus and species were inscribed in Chinese and Latin. I thought, “How beautiful, and erudite, and precious (in both senses of the word),” and – rather to my surprise – found myself kind of sympathizing with the Cultural Revolutionaries. I imagined them wondering, with sneering ire, where this aristocrat got off sitting around contemplating his beautiful garden and pondering the splendors of speciation when The People were suffering? It was an easy jump to imagining contemporary or near-future revolutionaries asking similar questions about massive investments in exhibiting the relics of past emperors.
Only after I’d left China did it occur to me to wonder whether anybody is pursuing the archaeology of the 700,000 workers said to have been involved in building Qin shi Huangdi’s mausoleum – along the lines of the recent exploration of the workers’ town associated with the Giza pyramids. It seems like some serious attention would be in order to the archaeology of the common people on whose labors the emperor (and every emperor) depended – both because it would be fascinating research and because it would convey a more populist, if not precisely communist, message to the visiting public about the glories of China’s past.
-- To be continued --
Sunday, May 01, 2011
On the Efficient Destruction of Historic Places: Don’t Question Significance
Preface:
In the interstices of my somewhat fragmented writing life, I’m working on a book that no publisher has agreed to touch, called something like “How To Destroy Historic Landmarks.” I figure that since I’ve written books for people who want to SAVE such places, it’s only fair that I offer something to the other side. This is how the manuscript begins:
You have a plan. Maybe for a new industrial complex, a wind farm, a solar plant. Maybe a prison, or a nuclear waste processing facility, a residential development, a pig farm. Maybe a logging operation, an apartment building, a natural gas pipeline, a railroad.
You start assembling the land for your project, and the financing. Maybe some of the land is owned, or controlled somehow, by the United States government. Or maybe you need some federal financing, or federally-guaranteed financing. Or maybe you need a federal permit of some kind. Or a permit from a local or state government. Or maybe you don’t, or maybe you don’t know. Or maybe your plan involves operations in a country other than the U.S., in which case – well, we’ll get to that.
You engage an architect-engineer firm to help you develop your plan. When you negotiate the A/E’s scope of work, one thing they say is that they’ll need to do an environmental impact assessment (EIA) – though they may call it an “environmental study,” or an “environmental assessment.” They may say you’ll need an “environmental site assessment,” and that’s a whole different thing; we’ll get to that, too.
But what’s this EIA thing? It’s a study, they tell you, designed to make sure your project won’t have any significant impacts on the environment. It’s required by law.
“Oh,” you say, looking at your lawyer, and she nods.
“So what’s to study?”
“Oh,” the A/E says, “endangered species, wetlands, floodplains, cultural resources.”
“What resources?”
“Cultural resources – that means historic landmarks, archaeological sites, things like that.”
You look at your lawyer and she shrugs her shoulders. You’re both thinking Mount Vernon, or the Taj Mahal, or Olduvai Gorge. There’s nothing like that on your property.
“It’s required,” the A/E says. “Got to get clearance. It’s usually just a formality.”
And thus you find yourself paying for a “cultural resources study” (though it may be called something else), the purpose of and need for which are not clear to you. And this study may lead you into some very strange worlds.
OK, skipping ahead because this issue has just come up in a project on which I’m consulting, I want today to compose something about how unwise it usually is for a project proponent to argue about the significance of a historic place – in standard US practice, its eligibility for the National Register of Historic Places – and solicit reader reaction. So…
Is It REALLY Historic?
Your consultants have found some places that you’ll have to dig up or knock down to build your project, that they say are “historically significant,” or “eligible for the National Register,” or maybe “potentially eligible.” Or maybe your consultants haven’t found these places but others – the local Indian tribe, the historical society, landowners, the Sierra Club – have drawn attention to them. These places may not look like anything to you: maybe a few piles of rocks, some sharp pieces of stone your consulting archaeologist gets all wet in the pants about and starts mumbling about “bulbs of percussion.” Maybe squiggles on an old map showing that there was once a homestead or a house of prostitution on the site; maybe a scruffy old building in which you wouldn’t house your ne’er-do-well son-in-law. Maybe some broken up fragments of pottery, or some bones. Maybe nothing at all but plants and trees, a rock outcrop and a slow-moving stream, but the tribe says it’s a “traditional cultural place” associated with some old story about weird mythological doings in some ancient dream time. “This place,” they say solemnly, “is eligible for inclusion in the National Register of Historic Places under Criterion A” – or B, C, or D.
Your inclination may be to say “this is a bunch of hooie; my consultant is trying to enrich himself by getting me to fund more studies” – or “these NIMBYs are making up something to encumber my project.” You may be right. You may also not be right, but let’s assume that you are. What happens if you say “Hell no, that place can’t be eligible for the National Register under any criteria; it’s all BS?” Politely, of course.
Well, as you may imagine, there’s a process for that, and quite a few permutations on the process. In essence you have to show why the place is not historic, to the satisfaction of the State Historic Preservation Officer (SHPO), maybe a Tribal Historic Preservation Officer (THPO), and if push comes to shove, to the Keeper of the National Register in the National Park Service. All this takes time, and probably more studies, so your consultant makes out like a bandit; he gets to dig around – in the ground or in archives or in the minds of old folks who remember what’s happened at the place – and all the time you’re paying him. And of course, he – the specialist – is the expert; you’re not, and he’s the guy who knows the SHPO, and maybe the tribes and the local preservation people; you don’t.
Of course, you can hire a new consultant to challenge your original consultant’s arguments, but then you’re likely to find yourself with two consultants arguing about something you don’t understand at all, and there’s no telling how long it will take to reach a decision – if one is ever reached. There’s not much you can do to control this process, other than to keep firing consultants and hiring new ones, and/or calling up your good buddy the governor to put pressure on the SHPO, or your Congressman to lean on the National Park Service – all of which strategies have their own downsides, at the very least requiring ratcheting up your campaign contributions.
If it’s a tribe or NIMBYs pushing the eligibility of the place, you can task your consultants to show that they’re wrong, but this tends to be a real loser. Think about it. The tribe or NIMBY is saying “This place is important because it’s associated with OUR cultural traditions or beliefs.” Your consultant is going to say “no it’s not?” On what grounds? Sure, the consultant may be able to show that there’s no scientific evidence that the cosmic snake Xbuttlesquirm emerged from the ground at the beginning of time and created Crooked Creek, but scientific evidence is irrelevant to the belief system of the tribe, and it’s in their belief system that the creek is (said to be) significant. And the NIMBYs, if they’re smart, will not hang their case on some historical fact that can be disproved (“Jesse James hid in this cave") but on a long-standing belief that has taken on cultural significance of its own (“We’ve all believed, for generations and generations, that Jesse James hid in this cave; it’s become an important part of our identity; it doesn’t matter whether he ever hid there; it’s been “Jesse’s Hideout” since my grandpa was a little sprout.”)
It is possible to get the SHPO to agree with you that the place isn’t eligible, but if the opposition knows what it’s doing there are ways for them to appeal the SHPO’s decision to the Keeper of the National Register in the National Park Service, and you have another delay. The Keeper almost always wants more information, more studies, hence more delay. And the Keeper, living in Washington DC, often asks questions that leave everyone scratching their heads. “What’s the boundary of the place,” for example, whether that makes any practical difference or not. Finally, the Keeper most times comes down on the side of eligibility.
And even if the Keeper goes along with you and says the place is not eligible, there are other laws the opponents can drag in that have nothing to do with Register eligibility; depending on the circumstances, they may have cases to make under NEPA, RFRA, AIRFA, NAGPRA, and maybe state or local law.
So, what to do? Smile, choke back your skepticism, and say “OK, we respect your point of view; we’ll treat everything as eligible.”
Why? Because, remember, the law doesn’t say you can’t destroy eligible, or listed, places; it simply says that you, and the federal agency involved, have to take the effects of doing so into account, following a specific set of procedures laid out in the ACHP’s regulations. So if you accept eligibility, accept the significance of the place, you next go to figuring out what effects you may have on it, and how adverse effects can be resolved. This may turn out not to be too hard. Maybe the effects will really be pretty mild, and you can find pretty easy ways to mitigate them.
True story: I was once involved in mediating a dispute between the U.S. Air Force and the Alaska SHPO over the proposed abandonment of a bunch of Nike Missile batteries and DEW-Line sites. The SHPO said they were historic; the Air Force said they weren’t; the parties were at loggerheads. My colleague and I (she was from the ACHP) asked the SHPO what she wanted done with the places. “Oh, she said, there’s one battery we’d like to make available to a city government to interpret, and we’d like some sort of encouragement to Native Communities to reuse the Dew-Line buildings.”
We turned to the Air Force: “Any problem with that?”
“No,” the Air Force responded, “but we still don’t think they’re eligible.”
In another case I’ve heard about, involving a pipeline over the shoulder of a mountain regarded as sacred by a tribe, after years of wrangling about the mountain’s eligibility for the Register, the effects of the project were resolved by holding a ceremony blessing the pipe, putting it into spiritual synchronicity with the mountain.
It’s not always that easy, but at least when you get to arguing about effects and how to resolve them, you’re on your turf, not the opposition’s. You control information on what’s feasible and what’s not; you can do studies to show what the visual or auditory or atmospheric impacts will be. And in the end, if push comes to shove, you can argue with the federal decisionmakers that there aren’t any feasible options and the public benefits of your project outweighs the damage it will cause. We’ll get to how you do that in the next chapter.
The bottom line here is: fighting over the significance of a place is usually a losing proposition for you. Yes, acknowledging its significance means you’re probably going to have to do SOMETHING to mitigate impacts on it, but the chances are that if you object to its significance you’ll STILL end up doing something; you’ll just take a lot longer to get to the decision about what to do, and spend a lot more money getting there. Plus you’ll so piss off the opposition – because you’re basically calling them liars and cheats, and/or denigrating their cultural values – that they’ll be less willing to deal with you than they’d be if you were more respectful, and more likely to try to stick you for outrageous mitigation measures.
One more point: there's a myth abroad in some parts of the world that if a place is eligible "only" under National Register Criterion "D" -- for containing significant data -- it can be readily dug up and gotten out of the way, while if it's aligible under Criterion "A" for association with significant events, it can't. This is flatly not true. The Criteria of eligibility don't define treatment; Criterion "D" sites aren't any more excavation-fodder than are Criterion "A" properties, and Criterion "A" places are no more inviolate than those given a "D" grade. What has to be preserved, as opposed to moved, dug up, knocked down or blown away, depends on what's negotiated among consulting parties, and ultimately on what the federal agencies involved decide is in the public interest. Your job is showing them that your project is more in the public interest than would be keeping the historic places inviolate. You'll do a better job of showing this, and get to the point of doing so quicker and at less cost, by accepting what people tell you about the eligibility of affected properties.
In the interstices of my somewhat fragmented writing life, I’m working on a book that no publisher has agreed to touch, called something like “How To Destroy Historic Landmarks.” I figure that since I’ve written books for people who want to SAVE such places, it’s only fair that I offer something to the other side. This is how the manuscript begins:
You have a plan. Maybe for a new industrial complex, a wind farm, a solar plant. Maybe a prison, or a nuclear waste processing facility, a residential development, a pig farm. Maybe a logging operation, an apartment building, a natural gas pipeline, a railroad.
You start assembling the land for your project, and the financing. Maybe some of the land is owned, or controlled somehow, by the United States government. Or maybe you need some federal financing, or federally-guaranteed financing. Or maybe you need a federal permit of some kind. Or a permit from a local or state government. Or maybe you don’t, or maybe you don’t know. Or maybe your plan involves operations in a country other than the U.S., in which case – well, we’ll get to that.
You engage an architect-engineer firm to help you develop your plan. When you negotiate the A/E’s scope of work, one thing they say is that they’ll need to do an environmental impact assessment (EIA) – though they may call it an “environmental study,” or an “environmental assessment.” They may say you’ll need an “environmental site assessment,” and that’s a whole different thing; we’ll get to that, too.
But what’s this EIA thing? It’s a study, they tell you, designed to make sure your project won’t have any significant impacts on the environment. It’s required by law.
“Oh,” you say, looking at your lawyer, and she nods.
“So what’s to study?”
“Oh,” the A/E says, “endangered species, wetlands, floodplains, cultural resources.”
“What resources?”
“Cultural resources – that means historic landmarks, archaeological sites, things like that.”
You look at your lawyer and she shrugs her shoulders. You’re both thinking Mount Vernon, or the Taj Mahal, or Olduvai Gorge. There’s nothing like that on your property.
“It’s required,” the A/E says. “Got to get clearance. It’s usually just a formality.”
And thus you find yourself paying for a “cultural resources study” (though it may be called something else), the purpose of and need for which are not clear to you. And this study may lead you into some very strange worlds.
OK, skipping ahead because this issue has just come up in a project on which I’m consulting, I want today to compose something about how unwise it usually is for a project proponent to argue about the significance of a historic place – in standard US practice, its eligibility for the National Register of Historic Places – and solicit reader reaction. So…
Is It REALLY Historic?
Your consultants have found some places that you’ll have to dig up or knock down to build your project, that they say are “historically significant,” or “eligible for the National Register,” or maybe “potentially eligible.” Or maybe your consultants haven’t found these places but others – the local Indian tribe, the historical society, landowners, the Sierra Club – have drawn attention to them. These places may not look like anything to you: maybe a few piles of rocks, some sharp pieces of stone your consulting archaeologist gets all wet in the pants about and starts mumbling about “bulbs of percussion.” Maybe squiggles on an old map showing that there was once a homestead or a house of prostitution on the site; maybe a scruffy old building in which you wouldn’t house your ne’er-do-well son-in-law. Maybe some broken up fragments of pottery, or some bones. Maybe nothing at all but plants and trees, a rock outcrop and a slow-moving stream, but the tribe says it’s a “traditional cultural place” associated with some old story about weird mythological doings in some ancient dream time. “This place,” they say solemnly, “is eligible for inclusion in the National Register of Historic Places under Criterion A” – or B, C, or D.
Your inclination may be to say “this is a bunch of hooie; my consultant is trying to enrich himself by getting me to fund more studies” – or “these NIMBYs are making up something to encumber my project.” You may be right. You may also not be right, but let’s assume that you are. What happens if you say “Hell no, that place can’t be eligible for the National Register under any criteria; it’s all BS?” Politely, of course.
Well, as you may imagine, there’s a process for that, and quite a few permutations on the process. In essence you have to show why the place is not historic, to the satisfaction of the State Historic Preservation Officer (SHPO), maybe a Tribal Historic Preservation Officer (THPO), and if push comes to shove, to the Keeper of the National Register in the National Park Service. All this takes time, and probably more studies, so your consultant makes out like a bandit; he gets to dig around – in the ground or in archives or in the minds of old folks who remember what’s happened at the place – and all the time you’re paying him. And of course, he – the specialist – is the expert; you’re not, and he’s the guy who knows the SHPO, and maybe the tribes and the local preservation people; you don’t.
Of course, you can hire a new consultant to challenge your original consultant’s arguments, but then you’re likely to find yourself with two consultants arguing about something you don’t understand at all, and there’s no telling how long it will take to reach a decision – if one is ever reached. There’s not much you can do to control this process, other than to keep firing consultants and hiring new ones, and/or calling up your good buddy the governor to put pressure on the SHPO, or your Congressman to lean on the National Park Service – all of which strategies have their own downsides, at the very least requiring ratcheting up your campaign contributions.
If it’s a tribe or NIMBYs pushing the eligibility of the place, you can task your consultants to show that they’re wrong, but this tends to be a real loser. Think about it. The tribe or NIMBY is saying “This place is important because it’s associated with OUR cultural traditions or beliefs.” Your consultant is going to say “no it’s not?” On what grounds? Sure, the consultant may be able to show that there’s no scientific evidence that the cosmic snake Xbuttlesquirm emerged from the ground at the beginning of time and created Crooked Creek, but scientific evidence is irrelevant to the belief system of the tribe, and it’s in their belief system that the creek is (said to be) significant. And the NIMBYs, if they’re smart, will not hang their case on some historical fact that can be disproved (“Jesse James hid in this cave") but on a long-standing belief that has taken on cultural significance of its own (“We’ve all believed, for generations and generations, that Jesse James hid in this cave; it’s become an important part of our identity; it doesn’t matter whether he ever hid there; it’s been “Jesse’s Hideout” since my grandpa was a little sprout.”)
It is possible to get the SHPO to agree with you that the place isn’t eligible, but if the opposition knows what it’s doing there are ways for them to appeal the SHPO’s decision to the Keeper of the National Register in the National Park Service, and you have another delay. The Keeper almost always wants more information, more studies, hence more delay. And the Keeper, living in Washington DC, often asks questions that leave everyone scratching their heads. “What’s the boundary of the place,” for example, whether that makes any practical difference or not. Finally, the Keeper most times comes down on the side of eligibility.
And even if the Keeper goes along with you and says the place is not eligible, there are other laws the opponents can drag in that have nothing to do with Register eligibility; depending on the circumstances, they may have cases to make under NEPA, RFRA, AIRFA, NAGPRA, and maybe state or local law.
So, what to do? Smile, choke back your skepticism, and say “OK, we respect your point of view; we’ll treat everything as eligible.”
Why? Because, remember, the law doesn’t say you can’t destroy eligible, or listed, places; it simply says that you, and the federal agency involved, have to take the effects of doing so into account, following a specific set of procedures laid out in the ACHP’s regulations. So if you accept eligibility, accept the significance of the place, you next go to figuring out what effects you may have on it, and how adverse effects can be resolved. This may turn out not to be too hard. Maybe the effects will really be pretty mild, and you can find pretty easy ways to mitigate them.
True story: I was once involved in mediating a dispute between the U.S. Air Force and the Alaska SHPO over the proposed abandonment of a bunch of Nike Missile batteries and DEW-Line sites. The SHPO said they were historic; the Air Force said they weren’t; the parties were at loggerheads. My colleague and I (she was from the ACHP) asked the SHPO what she wanted done with the places. “Oh, she said, there’s one battery we’d like to make available to a city government to interpret, and we’d like some sort of encouragement to Native Communities to reuse the Dew-Line buildings.”
We turned to the Air Force: “Any problem with that?”
“No,” the Air Force responded, “but we still don’t think they’re eligible.”
In another case I’ve heard about, involving a pipeline over the shoulder of a mountain regarded as sacred by a tribe, after years of wrangling about the mountain’s eligibility for the Register, the effects of the project were resolved by holding a ceremony blessing the pipe, putting it into spiritual synchronicity with the mountain.
It’s not always that easy, but at least when you get to arguing about effects and how to resolve them, you’re on your turf, not the opposition’s. You control information on what’s feasible and what’s not; you can do studies to show what the visual or auditory or atmospheric impacts will be. And in the end, if push comes to shove, you can argue with the federal decisionmakers that there aren’t any feasible options and the public benefits of your project outweighs the damage it will cause. We’ll get to how you do that in the next chapter.
The bottom line here is: fighting over the significance of a place is usually a losing proposition for you. Yes, acknowledging its significance means you’re probably going to have to do SOMETHING to mitigate impacts on it, but the chances are that if you object to its significance you’ll STILL end up doing something; you’ll just take a lot longer to get to the decision about what to do, and spend a lot more money getting there. Plus you’ll so piss off the opposition – because you’re basically calling them liars and cheats, and/or denigrating their cultural values – that they’ll be less willing to deal with you than they’d be if you were more respectful, and more likely to try to stick you for outrageous mitigation measures.
One more point: there's a myth abroad in some parts of the world that if a place is eligible "only" under National Register Criterion "D" -- for containing significant data -- it can be readily dug up and gotten out of the way, while if it's aligible under Criterion "A" for association with significant events, it can't. This is flatly not true. The Criteria of eligibility don't define treatment; Criterion "D" sites aren't any more excavation-fodder than are Criterion "A" properties, and Criterion "A" places are no more inviolate than those given a "D" grade. What has to be preserved, as opposed to moved, dug up, knocked down or blown away, depends on what's negotiated among consulting parties, and ultimately on what the federal agencies involved decide is in the public interest. Your job is showing them that your project is more in the public interest than would be keeping the historic places inviolate. You'll do a better job of showing this, and get to the point of doing so quicker and at less cost, by accepting what people tell you about the eligibility of affected properties.
Tuesday, March 15, 2011
Consultants: Finding a Donut Hole May Not Be In Your Client’s Best Interests
I’ve recently found myself reviewing a number of archaeological survey reports (usually mis-titled “cultural resource inventories”) prepared by consulting firms for agencies that propose to build things with the potential for churning up archaeological sites. I’ve been dismayed, though not especially surprised, to find a pattern of reportage that I have to think is designed to conceal potential archaeological problems and allow the consultants’ clients to find that their projects will have no effect on archaeological sites.
For example, in one case from southern California, construction is proposed on a bluff overlooking the ocean – a classic location for prehistoric occupation. The consultants’ report, in the section on “previous archaeological investigations,” presents a table showing all the archaeological sites previously recorded within a mile or so of the project location. A dozen or more – ranging from small deposits of mollusk shells, flakes, and fire-cracked rock to a large village/burial complex that’s been the source of considerable controversy over the years – lie within about 2-300 meters of the project location. The project location is completely covered by mid-20th century buildings, parking lots, sidewalks and landscaping. The consultants’ archaeologists duly walked the sidewalks and reported finding nothing. So, they reported, there’s nothing there and a finding of “no historic properties affected” is appropriate under Section 106. They say nothing about the topographic/environmental predictors of probable site location, and the fact that sites crowd the project location on every hand does not, it seems, suggest anything to them. And they evince no knowledge of the many cases in which more or less intact archaeological deposits and things like cemeteries have been found under modern buildings and landscaping.
In another case, from Oregon, the project site is a golf course on a riverbank, proposed for conversion to housing. The consultants’ report has a section on “ethnography” that is so general it fails to mention that tribes in the area tended to set up villages on riverbanks. In its section on “previous archaeological investigations” it reports one site, thought to have a lot of housepits and to be particularly important in understanding local prehistory, on the riverbank east of a sewer treatment plant; it fails to note that the proposed construction site is on the same riverbank, east of the same plant. From the project location map it appears that it’s maybe 150 to 200 meters from the sewage plant to the project site, so presumably the recorded site is somewhere on that intervening stretch of riverbank. Another possibly important site is reported just to the east; a bit of digging through the report and comparing it with Mapquest street maps reveals that it’s probably across the river from the project site, though the report doesn’t make this clear.
The Oregon project site, being a golf course, was a little more accessible than the California site, though its surface was obscured by turf. So the archaeologists walked transects across it and dug five or six test holes. In these they found a very light scatter of both prehistoric (flakes) and historic (bottle glass, etc.) artifacts. On the strength of this relatively negative data, they conclude that there’s nothing there.
Now, it may be that in both cases there really is nothing there, and undoubtedly it made the client happy in each case to learn that there were no archaeological impediments to the proposed project. The trouble, of course, is that this clean bill of health is not necessarily truthful. Prehistoric people, in my experience anyhow, were no respecters of site boundaries as defined by archaeologists (“No, no, Big Eagle, you can’t bury grandma over there; that’s outside the boundaries of site BS-2397!”). The presence of a “site” as defined by archaeologists simply means that people did stuff in the general area that produced something on that specific location that archaeologists can recognize. They may have done lots of other things in the broader area that archaeologists can’t recognize, or can’t recognize as well as they can other things. Burying dead people is one of those things. So the fact that your project footprint ju-u-ust misses the archaeologist-defined boundary of site BS-2397 doesn’t mean you’re not going to find grandma – maybe lots of grandmas – buried there. Or other things. And if the client doesn’t find out about those possible grandmas from your report, he or she may very well find out about them when they come up in a power shovel’s bucket. And living people start throwing things and seeking injunctions.
So, however much the client may want it, a determination that there’s nothing to worry about in a project area may not be in the client’s best interests. Such a determination can lull the client into thinking that all’s well, that he has nothing to worry about. Which is fine if it’s true, but a real problem if it’s not. And if there’s evidence that it’s not, and a consultant effectively covers it up, the consultant is setting the client up for a last-minute discovery situation that can be costly and embarrassing.
The reason to do background research in contract archaeology is not to find donut holes in which things can be built, but to make overall sense of what’s found in the transects fieldworkers walk and the test pits they dig. Contract archaeologists ought to take the results of background research, put them together with first-hand field observations, and give the client as realistic picture as possible of what archaeological problems his or her project may face. In the two cases I’ve outlined above, it seems obvious to me from the combination of topographic/environmental, ethnographic and archaeological data that the project sites may contain significant archaeological resources, and ought to be treated accordingly. My client may not be happy to have this advice from me, but he or she will be a lot less happy with a multi-million dollar work stoppage at the eleventh hour, and just may wonder why I didn’t mention the possibility early enough to let him or her do something about it.
For example, in one case from southern California, construction is proposed on a bluff overlooking the ocean – a classic location for prehistoric occupation. The consultants’ report, in the section on “previous archaeological investigations,” presents a table showing all the archaeological sites previously recorded within a mile or so of the project location. A dozen or more – ranging from small deposits of mollusk shells, flakes, and fire-cracked rock to a large village/burial complex that’s been the source of considerable controversy over the years – lie within about 2-300 meters of the project location. The project location is completely covered by mid-20th century buildings, parking lots, sidewalks and landscaping. The consultants’ archaeologists duly walked the sidewalks and reported finding nothing. So, they reported, there’s nothing there and a finding of “no historic properties affected” is appropriate under Section 106. They say nothing about the topographic/environmental predictors of probable site location, and the fact that sites crowd the project location on every hand does not, it seems, suggest anything to them. And they evince no knowledge of the many cases in which more or less intact archaeological deposits and things like cemeteries have been found under modern buildings and landscaping.
In another case, from Oregon, the project site is a golf course on a riverbank, proposed for conversion to housing. The consultants’ report has a section on “ethnography” that is so general it fails to mention that tribes in the area tended to set up villages on riverbanks. In its section on “previous archaeological investigations” it reports one site, thought to have a lot of housepits and to be particularly important in understanding local prehistory, on the riverbank east of a sewer treatment plant; it fails to note that the proposed construction site is on the same riverbank, east of the same plant. From the project location map it appears that it’s maybe 150 to 200 meters from the sewage plant to the project site, so presumably the recorded site is somewhere on that intervening stretch of riverbank. Another possibly important site is reported just to the east; a bit of digging through the report and comparing it with Mapquest street maps reveals that it’s probably across the river from the project site, though the report doesn’t make this clear.
The Oregon project site, being a golf course, was a little more accessible than the California site, though its surface was obscured by turf. So the archaeologists walked transects across it and dug five or six test holes. In these they found a very light scatter of both prehistoric (flakes) and historic (bottle glass, etc.) artifacts. On the strength of this relatively negative data, they conclude that there’s nothing there.
Now, it may be that in both cases there really is nothing there, and undoubtedly it made the client happy in each case to learn that there were no archaeological impediments to the proposed project. The trouble, of course, is that this clean bill of health is not necessarily truthful. Prehistoric people, in my experience anyhow, were no respecters of site boundaries as defined by archaeologists (“No, no, Big Eagle, you can’t bury grandma over there; that’s outside the boundaries of site BS-2397!”). The presence of a “site” as defined by archaeologists simply means that people did stuff in the general area that produced something on that specific location that archaeologists can recognize. They may have done lots of other things in the broader area that archaeologists can’t recognize, or can’t recognize as well as they can other things. Burying dead people is one of those things. So the fact that your project footprint ju-u-ust misses the archaeologist-defined boundary of site BS-2397 doesn’t mean you’re not going to find grandma – maybe lots of grandmas – buried there. Or other things. And if the client doesn’t find out about those possible grandmas from your report, he or she may very well find out about them when they come up in a power shovel’s bucket. And living people start throwing things and seeking injunctions.
So, however much the client may want it, a determination that there’s nothing to worry about in a project area may not be in the client’s best interests. Such a determination can lull the client into thinking that all’s well, that he has nothing to worry about. Which is fine if it’s true, but a real problem if it’s not. And if there’s evidence that it’s not, and a consultant effectively covers it up, the consultant is setting the client up for a last-minute discovery situation that can be costly and embarrassing.
The reason to do background research in contract archaeology is not to find donut holes in which things can be built, but to make overall sense of what’s found in the transects fieldworkers walk and the test pits they dig. Contract archaeologists ought to take the results of background research, put them together with first-hand field observations, and give the client as realistic picture as possible of what archaeological problems his or her project may face. In the two cases I’ve outlined above, it seems obvious to me from the combination of topographic/environmental, ethnographic and archaeological data that the project sites may contain significant archaeological resources, and ought to be treated accordingly. My client may not be happy to have this advice from me, but he or she will be a lot less happy with a multi-million dollar work stoppage at the eleventh hour, and just may wonder why I didn’t mention the possibility early enough to let him or her do something about it.
Friday, March 11, 2011
SHPOs: Wimping Out Doesn’t Help
I imagine it’s expectable, in these stressful times, but it seems to me that every time I’ve turned around lately, I’ve found another State Historic Preservation Officer (SHPOs) wimping out and letting an agency run roughshod over the Section 106 process and the (presumed) historic and cultural interests of his or her state’s citizenry. Recurrent issues include (but certainly aren’t limited to):
SHPOs, I realize that you’re under pressure; your staffs are being eviscerated, you get no help from NPS or the Advisory Council, your governor and legislature are on your backs, but for heaven’s sake, if you're going to accept any old piece of paper that anybody throws at you as evidence of compliance with Section 106, you're rendering the whole business -- and a large part of your existence -- meaningless. And you're not helping anyone. You’re not helping the agencies, or the taxpayers who pay for them, by nodding and winking at their violations of law and regulation; you’re undercutting the efforts of anyone in an agency who’s trying to promote effective compliance, and you’re setting the agencies up for successful litigation. You’re certainly not helping your states’ historic resources, or the citizens who care about them. Going along with BS “compliance” doesn’t help resolve the problems you’re facing; if anything it makes them worse. You’re helping make the Section 106 process worthless, and in the long (or maybe short) run that won’t help you or anybody else. If you can’t or won’t do your jobs, why don’t you just stop pretending to?
- Consulting firms contacting SHPOs and making/seeking (on the assumption that the SHPO awards such things) determinations of “no historic properties affected” or “no adverse effect,” sometimes based on the promised implementation of conditions, with no evidence that the responsible federal agency even knows what’s being determined and promised. This truly reduces the 106 process to a paperwork exercise, since there’s no reason to think that the consulting firm’s statements mean anything once the firm has collected its money and gone.
- Agencies (or consulting firms) initiating 106 review by filing determinations of eligibility or effect (or petitioning the SHPO to award them with such determinations) without any prior consultation at all – thus eliminating the guts of the process.
- Determinations of effect that address only historic buildings when the project under “review” clearly has the potential for effect on archaeological sites, landscapes, and other kinds of properties that don’t happen to have four walls and a roof, with no evidence that anybody has considered these other kinds of properties.
- “Consultation” only with the SHPO, with no effort whatever to identify and engage other consulting parties.
- Unrationalized areas of potential effect (APE) – sometimes nonsensically big, sometimes absurdly small – that have nothing to do with the actual likely effects of the project.
- Evaluations of individual buildings that are in fact parts of complexes, without any attention to the overall context of which the building is a part. I’ve lately seen one whole federal installation that’s literally been picked to pieces, with each piece – judged solely on its own out-of-context merits – judged insignificant, even though the whole installation was almost certainly eligible for the Register.
SHPOs, I realize that you’re under pressure; your staffs are being eviscerated, you get no help from NPS or the Advisory Council, your governor and legislature are on your backs, but for heaven’s sake, if you're going to accept any old piece of paper that anybody throws at you as evidence of compliance with Section 106, you're rendering the whole business -- and a large part of your existence -- meaningless. And you're not helping anyone. You’re not helping the agencies, or the taxpayers who pay for them, by nodding and winking at their violations of law and regulation; you’re undercutting the efforts of anyone in an agency who’s trying to promote effective compliance, and you’re setting the agencies up for successful litigation. You’re certainly not helping your states’ historic resources, or the citizens who care about them. Going along with BS “compliance” doesn’t help resolve the problems you’re facing; if anything it makes them worse. You’re helping make the Section 106 process worthless, and in the long (or maybe short) run that won’t help you or anybody else. If you can’t or won’t do your jobs, why don’t you just stop pretending to?
Thursday, January 06, 2011
Contents: Wiley-Blackwell Companion to CRM
In response to requests (well, a request), here's the table of contents of the Wiley-Blackwell Companion to Cultural Resource Management, scheduled for publication in the UK and US this spring.
Introduction
Thomas F. King
Part I. General Classes of Cultural Resources
Chapter 1 – Studying and Evaluating the Built Environment
Kate Kuranda
Chapter 2 – Principles of Architectural Preservation
David Ames & Leila Hamroun
Chapter 3 – Archaeology of the Distant Past
Michael J. Moratto
Chapter 4 – Archaeology of the Recent Past
Thomas F. King
Chapter 5 -Geographies of Cultural Resource Management: Space, Place and Landscape
William M. Hunter
Chapter 6 - Culturally Significant Natural Resources: Where Nature and Culture Meet
Anna J. Willow
Chapter 7 – History as a Cultural Resource
Deborah Morse-Kahn
Chapter 8 - Portable Cultural Property: “This Belongs in a Museum?”
Wendy Teeter
Chapter 9 - "Intangible" Cultural Resources: Values are in the Mind
Sheri Murray Ellis
Chapter 10 – Religious Belief and Practice
Michael D. McNally
Chapter 11 - Language as an Integrated Cultural Resource
Bernard Perley
Part II. Special Types of Cultural Resources
Chapter 12 - Challenges of Maritime Archaeology: In Too Deep
Sean Kingsley
Chapter 13 - Historic Watercraft: Keeping Them Afloat
Susan B.M. Langley
Chapter 14 - Historic Aircraft and Spacecraft: Enfants TerriblesRic Gillespie
Chapter 15 - Studying and Managing Aerospace Crash Sites
Craig Fuller and Gary Quigg
Chapter 16 - Evaluating and Managing Technical and Scientific Properties: Rockets, Tang™, and Telescopes
Paige M. Peyton
Chapter 17 – Historic Battlefields: Studying and Managing Fields of Conflict
Nancy Farrell
Chapter 18 - Managing Our Military Heritage
D. Colt Denfeld
Chapter 19 - Linear Resources and Linear Projects: All in Line
Charles W Wheeler
Chapter 20 - Rock Art as Cultural Resource
Linea Sundstrom and Kelley Hays-Gilpin
Part III. Perspectives on Cultural Resource Management
Chapter 21 – Consultation in Cultural Resource Management: An Indigenous Perspective
Reba Fuller
Chapter 22 - A Displaced People’s Perspective on Cultural Resource Management: Where We’re From
David Nickell
Part IV. Legal, Administrative, and Practical Contexts
Chapter 23 – Cultural Resource Laws: The Legal Mélange
Thomas F. King
Chapter 24 – International Variety in Cultural Resource Management
Thomas J. Green
Chapter 25 – Consultation and Negotiation in Cultural Resource Management
Claudia Nissley
Chapter 26 – Being a U.S. Government Cultural Resource Manager
Russell L. Kaldenberg
Chapter 27 – Making a Living in Private Sector Cultural Resource Management
Tom Lennon
Chapter 28 - The Historic Built Environment: Preservation and Planning
Diana Painter
Chapter 29 – CRM and the Military: Cultural Resource Management at War
Michael K. Trimble and Susan Malin-Boyce
Chapter 30 - A Future for Cultural Resource Management?
Thomas F. King
Introduction
Thomas F. King
Part I. General Classes of Cultural Resources
Chapter 1 – Studying and Evaluating the Built Environment
Kate Kuranda
Chapter 2 – Principles of Architectural Preservation
David Ames & Leila Hamroun
Chapter 3 – Archaeology of the Distant Past
Michael J. Moratto
Chapter 4 – Archaeology of the Recent Past
Thomas F. King
Chapter 5 -Geographies of Cultural Resource Management: Space, Place and Landscape
William M. Hunter
Chapter 6 - Culturally Significant Natural Resources: Where Nature and Culture Meet
Anna J. Willow
Chapter 7 – History as a Cultural Resource
Deborah Morse-Kahn
Chapter 8 - Portable Cultural Property: “This Belongs in a Museum?”
Wendy Teeter
Chapter 9 - "Intangible" Cultural Resources: Values are in the Mind
Sheri Murray Ellis
Chapter 10 – Religious Belief and Practice
Michael D. McNally
Chapter 11 - Language as an Integrated Cultural Resource
Bernard Perley
Part II. Special Types of Cultural Resources
Chapter 12 - Challenges of Maritime Archaeology: In Too Deep
Sean Kingsley
Chapter 13 - Historic Watercraft: Keeping Them Afloat
Susan B.M. Langley
Chapter 14 - Historic Aircraft and Spacecraft: Enfants TerriblesRic Gillespie
Chapter 15 - Studying and Managing Aerospace Crash Sites
Craig Fuller and Gary Quigg
Chapter 16 - Evaluating and Managing Technical and Scientific Properties: Rockets, Tang™, and Telescopes
Paige M. Peyton
Chapter 17 – Historic Battlefields: Studying and Managing Fields of Conflict
Nancy Farrell
Chapter 18 - Managing Our Military Heritage
D. Colt Denfeld
Chapter 19 - Linear Resources and Linear Projects: All in Line
Charles W Wheeler
Chapter 20 - Rock Art as Cultural Resource
Linea Sundstrom and Kelley Hays-Gilpin
Part III. Perspectives on Cultural Resource Management
Chapter 21 – Consultation in Cultural Resource Management: An Indigenous Perspective
Reba Fuller
Chapter 22 - A Displaced People’s Perspective on Cultural Resource Management: Where We’re From
David Nickell
Part IV. Legal, Administrative, and Practical Contexts
Chapter 23 – Cultural Resource Laws: The Legal Mélange
Thomas F. King
Chapter 24 – International Variety in Cultural Resource Management
Thomas J. Green
Chapter 25 – Consultation and Negotiation in Cultural Resource Management
Claudia Nissley
Chapter 26 – Being a U.S. Government Cultural Resource Manager
Russell L. Kaldenberg
Chapter 27 – Making a Living in Private Sector Cultural Resource Management
Tom Lennon
Chapter 28 - The Historic Built Environment: Preservation and Planning
Diana Painter
Chapter 29 – CRM and the Military: Cultural Resource Management at War
Michael K. Trimble and Susan Malin-Boyce
Chapter 30 - A Future for Cultural Resource Management?
Thomas F. King
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