I got to work, sat down, opened my email, and took a sip of coffee. As I waited for my computer to boot up, I jotted down a short to-do list of tasks I needed to complete that day. Then, I opened my email and took another coffee sip
“You’ve got mail!” I’d received an email informing me that the Arizona state historic preservation office (SHPO) just issued new cultural resource management reporting guidelines. Anyone working in cultural resources, heritage conservation, or historic preservation knows we mainly write the reports for the SHPO because they’re the gatekeepers that can prevent or allow a project to move forward. Their guidelines are actually rules that we pretty much have to follow or have a good explanation why we didn’t do what they say.
Most of the new tips were irrelevant because my company already did that stuff. Most of the things we didn’t already do wouldn’t be too easy to add to our reports. But, some of the guidelines (which, of course, weren’t explained in detail) don’t make much sense.
After reading the new guidelines, I realized, once again, the state historic preservation rules create ambiguity that we CRMers are going to have to spend extra energy explaining to our clients.
Here are three things that aren’t clear in the new guidelines:
Assessing the Section 106 value of isolated artifacts- Why do we need to say isolated occurrences (IOs) aren’t eligible for listing in the National Register of Historic Places (NRHP)? If they were even worth considering for the NRHP, wouldn’t they be archaeological sites or historical buildings/ structures instead of IOs?
In Arizona, the criteria for archaeological sites vs. IOs are very clearly spelled out in the SHPO reporting standards. Isolated features (prehistoric or historical) fit the criteria of an archy site/ historical property. Isolated artifacts don’t. IOs dont fit the site/ historic property criteria under Arizona or Section 106.
So, what’s the confusion? Why waste the megabytes explaining the NRHP value of something that isn’t NRHP-eligible?
Including a UTM table appendix for new sites- This sounds dangerous. The SHPO already gets the shapefiles and coordinates of every GPS point we take out there. The new guidelines state that the UTM appendix should be in a form that can be easily redacted for Freedom of Information Act requests, but who’s going to make sure they’re redacted? SHPO or CRMers? If it is CRMers, why isn’t our shapefile information enough?
Our reports are part of the public domain. The general public and developers can ask for the reports and get an idea of the archy sites near a given location if they want. They can also pay for the exact locations if necessary so the SHPO can keep track of who asks for what and when they asked for it.
Why do we need to publish the exact location of the historic properties we’re trying to preserve? So NatGeo can bring a backhoe along and pillage another resource? I personally think publishing a UTM list in a public document is a bad idea.
Qualified archaeologist- This one kills me. They say a qualified archaeologist must conduct all fieldwork, but don’t specifically state what those qualifications are. I know what the State of Arizona considers a qualified archaeologist, but my clients don’t always know. This part of the guidelines puts our qualifications up for debate.
A developer may try to get around this one in a number of different ways and use this most recent guideline to support their use of an inadequate archaeologist. Or, CRM companies can hire undergrads with no experience as the field crew and simply have a PhD edit the report and take credit for the work (expanding a practice that is already widespread).
Why not just say, “fieldwork and reporting has to be completed by a Registered Professional Archaeologist (RPA)?
For those of you that object, the RPA, for all it’s faults, is the only thing we archaeologists have that says we know what we’re doing. Some may say its just a technicality and that there’s loads of good archaeologists that don’t qualify for the RPA. Actually, there aren’t tons of good archaeologists that can’t be RPAs. Also, there’s a bunch of crappy RPAs that shouldn’t be leading projects. I hate to say it, but the RPA is what it is. It’s up to us to make it better.
We CRMers create legal documents that are admissible in court. Would you hire a lawyer that hadn’t passed the bar? Or, a doctor that didn’t have a medical license? Then, why trust an archeologist that isn’t a registered professional?
Rather than complaining about the RPAs faults, we should work on improving it. For instance, we could make it mandatory that any RPA has at least 1-2 years of full time CRM supervisory experience. Or, create a standard test like the bar exam that we all have to pass, which would help grandfather in the old-timers.
What does the SHPO want?
The SHPO rewrote the guidelines less than 5 years ago. They just did it again last year. Why?
The new guidelines were probably created because so many CRMers and cultural resource management companies were cutting corners so close that their reports were inadequate. There were probably hundreds of underbid projects completed during the recession that didn’t have enough budget to do the right thing, so the CRMers cranked out crappy reports and called it good.
So, the SHPO got tired of it and issued the most recent edict.
If we don’t watch out and do more than the bare minimum, another reporting guidelines update will be coming soon.
I would really love to hear from you. If you have any questions or comments, write below or send me an email.
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I just came across this blog post, and have several relevant comments to make. First, isolates are evaluated for NRHP eligibility because of the wording in Section 106. Eligibility for the NRHP is not limited to sites. The text of section 106 includes the words : “The quality of significance in American history architecture, archaeology, and culture is present in districts, sites, buildings, structures, and OBJECTS of State and local importance that possess integrity of location, design, setting, material, workmanship, feeling, and association. . .”
Isolates do qualify as objects, and, therefore, must be evaluated for there NRHP eligibity. And, the one sentence needed to explain that isolates are not eligible for the NRHP does not take up megabytes.
Second, archaeology reports in most states and for the Federal government (and, I believe this is true of Arizona) are excluded from freedom of information/open government requests. That is why the only people allowed into the archive at ASM are employees of companies with valid permits (and students of the various universities who have permission from a qualified professor).
Having the UTMs in reports is a very good thing. It is called redundancy. What happens if something happens to the drive(s) containing the shapefiles? What happens if a limited number of shapefiles becomes corrupted and unreadable? The report provides a hard copy of that information.
Having the information in an appendix also allows the SHPO (or other agency) to easily release those portions of the reports to the public (where appropriate) without disclosing site location information (they can simply remove the appendix, and any maps that show site locations).
Thanks for writing a response to this older post. Since I wrote this post, I’ve learned several things about the SHPO guidelines in AZ that makes it a little more clear (the isolates conundrum you mentioned is one of these revelations). I also agree with the UTMs appendices and have done that for many reports in the past.
This post actually makes me cringe now that I’ve written it because I realized that I was working for good companies that were actually doing what the SHPO wanted. The rules changes were made because CRMers were cutting corners and not doing a good job. I never take any of the blog posts down from this website because I want the site’s visitors to transparently see how my thoughts, beliefs, and knowledge has changed throughout time. Thanks for commenting on this post. It makes me want to write a rebuttal to my initial talking points.