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INSIGHTS

THE MANY FACES OF CRM


Cinderella's Choice: The Emerging Role of the State Historic Preservation Office in Cultural Resource Management

David Snyder



"During the mid-1970s, when the pandemonium of the new archaeology's birth rites finally abated, archaeologists suddenly awoke to the realization that the discipline had changed dramatically. No longer were granting agencies and universities archaeology's major sources of financial support. Instead, federal agencies (e.g., the Forest Service, the Bureau of Reclamation, the National Park Service, the Army Corps of Engineers), state and local governments, and even private industries were funding the lion's share of American archaeology. Some investigators lamented this proliferation of contract research as an unwelcome expansion of the salvage ethic in archaeological research with all of the drastic compromises in quality that term connotes, while others hailed the new development as an unprecedented opportunity for scientific advance--if new archaeologists could make the necessary organizational and methodological adjustments. It is now becoming clear that the latter appraisal, though not yet completely substantiated, seems to be more accurate" (The Framework of Cultural Resource Management in the United States: The Problem of Quality Control, In Conservation Archaeology: A Guide for Cultural Resource Management Studies, p. 1, M. G. Schiffer and G. J. Gumerman, eds., 1977).

During the past 20 years, increases in the number of cultural resource management (CRM) reports completed under the regulations implementing the National Historic Preservation Act of 1966, as amended, has led to increased responsibility for the state historic preservation office (SHPO) as one of the key players in carrying out these projects. I contend that this responsibility is also increasing the SHPO role in archaeology and among professional archaeologists, superseding in many ways the role of academic-based research. Unfortunately, increasing responsibility has not always come with increasing authority to ensure the control of quality for this research.

Before launching into my thesis, I want to clarify that I speak only for myself from personal observations, and that I am a new kid on the block, having only worked as a reviewer in the Ohio Historic Preservation Office for four years. My job responsibilities are to manage the review of Section 106 projects where there is a potential for impact to archaeological sites. I have worked in CRM for almost 20 years beginning as an undergraduate at the University of Washington and continuing as a graduate student at Southern Illinois University at Carbondale where I received my Ph.D. in 1989. I owe much of my success and dedication to the excellence of my training, but if I seem somewhat overzealous in my concern for archaeology, I would also have to attribute that to those same professors (you know who you are). I have worked professionally for more than 15 years in academic, contract, and SHPO settings. My education and training is in archaeology as a subfield of anthropology with emphasis in CRM. I will direct most of my comments to archaeological concerns in the remainder of this discussion.

Ideally, the SHPO staff would provide a sounding board for professionals in the historic preservation community, offering technical advice focused on compliance with the regulations for the National Historic Preservation Act. Under this act, federal agencies would employ historic preservation specialists, including professional archaeologists, to ensure that the agency fully considered its impacts on any property which may be eligible for inclusion in the National Register of Historic Places. And many agencies do employ historic preservation specialists. In this ideal world, the academic community would assume the primary responsibility for education (including ethical considerations), training, establishment of standards, and oversight to ensure that standards are indeed met.

Out of necessity, the SHPO is burdened with much of the responsibility for compliance (the federal agency role) and is placed in a central role with much of the responsibility for education, training, establishment of standards, and oversight. In my view, this increased responsibility is an attempt to fill a vacuum left by the academic community and not the usurpation of responsibility by the SHPO. This situation is further exacerbated because the SHPO lacks authority to govern the conduct of CRM archaeology, and, as the lowest paid personnel in the professional preservation community, the SHPO lacks many of the resources of the academic community to undertake these added responsibilities.

Some background information on the extent of CRM work in Ohio provides a useful starting point to support my contentions. The Ohio SHPO, and its staff of 26 (1995 level), is involved with a wide range of preservation programs and activities including, but not limited to, technical assistance to private and public sectors, historic preservation planning, oversight of the federal certified local government program and grants, public education, development of the state plan, review of tax act projects, review of National Register of Historic Places nominations, management of files containing the state inventories of National Register properties, architectural properties and archaeological sites, maintaining an archive of CRM reports, and review of Section 106 (federal agency projects). The Ohio SHPO staff answer about 200 telephone calls every working day (we even answer calls on weekends, holidays, and at home). Our files contain primary documentation on more than 100,000 properties. Eight persons are responsible for Section 106 reviews. We are required to respond to approximately 10,000 pieces of correspondence annually. This correspondence comprises more than 2,500 separate undertakings with more than 1,000 of these involving ground disturbance and new construction (i.e., archaeology). Each year we review about 250 archaeological reports which contain information on surveys of more than 20,000 acres and provide primary documentation for more than 1,000 identified archaeological sites. The reports also provide findings of further investigations at several core sites. These numbers have grown steadily from 1985 through 1995; given the fact that a large portion of construction activities in Ohio is still not regulated for archaeology, and there is still no counterpart in Ohio to Section 106, it is reasonable to think that these numbers could, and should, go even higher. Finally, we find that the number of reports paid for by private industry in complying with federal regulations is rapidly increasing--approaching about 50 percent of the reports we review annually.

My focus here is on the thousands of reports, covering hundreds of thousands of acres, and containing primary documentation of many thousands of sites, which have been reviewed by this office since 1975. All this information is available for research to professional archaeologists, but, as I discuss below, there are continuing questions about the quality of some of these data. In contrast, I am aware of research projects conducted by professional archaeologists throughout Ohio that are not directly linked to CRM, resulting in the identification of several hundred sites, but this information is seldom submitted to this office. It is also my impression that there is ongoing research conducted at several major sites during any one year outside of CRM projects. That is, the overwhelming majority (90 percent) of newly identified sites reported to this office come to us through CRM projects. On the other hand, it is my impression that the numbers of excavation programs at significant sites are roughly equal in comparing CRM work to non-CRM work. Reports and papers for non-CRM work often lag several years behind the work, but until reported, this information is generally not available to professional archaeologists. Clearly, CRM work has provided and continues to provide the overwhelming bulk of new data on archaeology.

Cumulatively, data from CRM projects contribute new and important information for understanding the archaeological record in Ohio. Surveys conducted along corridors provide data on variability in the archaeological record crossing a wide range of environmental zones, the vast majority of these studies are the result of CRM work. For example, in north-central Ohio, survey along a 100 km corridor for the proposed reroute of U.S. Route 30 has resulted in the identification of more than 3,300 sites. These kinds of surveys provide valuable data on the variability of the archaeological record, and, these kinds of large studies are increasing in compliance with federal regulations involving coordination with the SHPO. Corridor studies need to provide comparative data from different areas for applicability in current theoretical models, but there are questions concerning the data from some CRM studies. Are the sites plotted accurately and precisely? With large numbers of people working on these projects, do we have sufficient quality control to know that the work is comparable? It is not uncommon for us to request corrections to maps in CRM reports to show scale, north arrow, site boundaries, and relevant geographic features. The numbers of artifacts reported in tables and site descriptions frequently do not add up. Are the data reliable? Furthermore, there is a pressing need to synthesize these new data to assess quality control, to identify areas where improvements can be made, and to begin exploring the potential these data hold for our understanding of prehistory. However, the SHPO has neither the authority nor the resources to tackle this problem.

Data from CRM projects also contribute directly to understanding specific problems in prehistory. For example, data on Late Archaic-and Hopewell-period occupations were recovered from excavations of a site in southern Ohio that would be destroyed by highway construction. This is one of very few Middle Woodland sites with limited occupation span focused on domestic activities which has been studied, and the study benefited directly and immediately from academic-based research at a Hopewell-period hamlet site located in central Ohio. The site in the highway construction project was originally identified during a reconnaissance survey, and based on similarities to the earlier study, the contract archaeologists, the reviewers in this office, and the agency archaeologists readily agreed that additional work was needed. This study has added dramatic new information on changing lifeways during the Late Archaic period through Middle Woodland period, and convincingly shows what is possible when CRM work is fully integrated into the different spheres of archaeology.

Unfortunately, with limited resources, not all our efforts have happy endings. A suburb of a major metropolitan area has started construction for an industrial park. In spite of extended efforts by this office, the U.S. Army Corps of Engineers ruled that construction of the bridge over a major river and floodplain was not part of the site development and thus facilitated the initiation of construction activities that will result in the destruction of more than a dozen important archaeological sites, some with significant Middle Woodland assemblages. These sites were reported in the late 1970s, about the same time as the plans for the industrial park were made public. In almost 20 years of project planning, no comprehensive effort to study these sites was made; no grants were written, no field schools were proposed. Numerous professional archaeologists advocated the need for studies. We have pushed to have studies completed before construction proceeds, making appeals to concerns for future generations. But, at a meeting, a state senator summed up prevailing perceptions cogently when he asked me why no work had been done if these sites were so important.

While new findings are exciting, the responsibilities and daily grind require a great deal of work. At times I am sure that all reviewers in SHPO offices wonder whether it is worth the set-backs, criticism, and personal attacks from the archaeological community. Pressure from political and private spheres is even more harsh. Reviewers are expected to be able to simultaneously translate archaeological concerns into theoretical, strategic, and common language and terms. It would not be unusual for me to have to provide technical comments on the appropriateness of a survey sampling strategy, explain to professional archaeologists why and under what conditions shovel testing is to be used, and explain a SHPO position to a church minister who wants to build an AIDS shelter but needs an environmental review including an archaeological survey--all before my first cup of morning coffee.

We must keep current on recent advances in archaeological theory and method, but we are required to explain to the general public why we are recommending archaeological investigations. A village manager in northern Ohio was very irate about my recommendation for an archaeological survey in an area not previously surveyed for a sewer and housing development. He was not satisfied with my explanations that a major prehistoric village site from which human remains had been recovered was located on the same landform only a couple of kilometers to the west. And so, I was asked to explain my recommendation to the congressional representative's aid and a representative of the governor's economic development office. This is just one example of the implications of placing CRM workers and SHPO staff on the front lines in fighting for the future of archaeology; this is where the action is in terms of funding and influence over new legislation.

SHPO staff daily provide educational information and training, covering fundamental principles of archaeology for professional archaeologists. Given the massive amount of information we expect archaeologists to have mastered and the rapidly changing interpretations of theory and method, it is not surprising that considerable review and ongoing educational programs are needed. We devote considerable time and effort to helping professional archaeologists better communicate their findings and recommendations; at times the writing in reports is not up to professional standards. Too many in the academic community unfortunately expect students to master in a year what has taken them a lifetime to develop, and once the student leaves the classroom, the school has no continuing responsibility. The responsibility for continuing education and technical assistance, especially in compliance with Section 106, is left primarily to the SHPO, although in recent years, a growing number of programs and training are being offered by CRM firms. The Ohio SHPO has recently published guides and standards for recording architectural properties and archaeological sites, and we have been one of the principal authors in providing documentation and guidance in the treatment of human remains.

I am expected to know specific research questions for anywhere in Ohio and to provide specific site information off the top of my head to justify my recommendations. Yet, SHPO staff average about 20 percent to 40 percent less pay than assistant professors. We are not given any time for research or creative thought. We are not given any time to study different approaches. We are expected to absorb the newest information and apply sophisticated approaches to complex problems. If we stick to our guns and require shovel tests at 10 m intervals we are branded as narrow-minded and inflexible (but we do get the data necessary to complete reviews). If we try new approaches, we are branded as wishy-washy and inconsistent or, worse, that we are unfair. But we are not to take it personally.

There are problems in CRM archaeology that extend beyond the sphere of the SHPO, problems that require the attention, concern, and cooperation of the professional archaeological community. Who is responsible for policing contract archaeological work to ensure that the required and appropriate work is done? This SHPO does not currently have the authority to certify archaeologists; we do not make these professional standards, we can only recognize them. It will take a great deal of cooperation among many parts of the professional archaeological community to ensure that competent work is done by competent people. Likewise, we do not currently have the authority to determine ethics or to sanction archaeologists who violate ethical standards. We do not have the authority to set standards for curation. Are we required to keep every 50 years old or older piece of glass that we find? Are we required to keep every fragment of chert that may be an artifact? There are many more questions, including issues involving Native American concerns, than I have space to enumerate. Whatever the questions, we need to work together in arriving at workable solutions and answers, and in implementing them. The widely held perception that the staff of the SHPOs consist of second-class archaeologists limits the authority of the SHPO and its ability to work with other groups of professional archaeologists in seeking solutions to pressing problems.

CRM benefits from the involvement and central role of the SHPO. Perhaps the most important of these is a focus on stewardship of public resources. It is in our collective efforts to preserve and protect our most important sites, that we see the importance of the SHPO, and we see the archaeological community at its best. Recently, a developer proposed construction of a massive lake and resort in the valley immediately adjacent to Serpent Mound. At this time, it appears that this development is on hold, due to a vigorous letter-writing campaign. The Ohio SHPO asked for and received much support in addressing our concerns for this project. But, there will be other developments proposed for the Serpent Mound area and at other significant sites, too. It will take ongoing efforts and a continuing commitment to the stewardship of our significant sites to ensure their preservation for future generations. These resources do not belong to any one academic department. Their preservation requires statewide and regional efforts. Stewardship of archaeological sites at a statewide level provides the fundamental basis for CRM work.

Given the massive difference separating the amount of CRM work as compared to non-CRM work in archaeology today, it is not surprising that the SHPO has come to play a pivotal role. Most people working in archaeology today work in CRM projects and most projects require coordination with the SHPO. Increasingly, the SHPO is assuming responsibility for setting work standards and those who can fulfill them. Given current trends, it will be only a matter of time until the SHPO is also required to assume the responsibilities for establishing curational guidelines and standards for accrediting academic programs. Unless the academic community critically rethinks its role and accepts challenges of new responsibility, it will find itself in a secondary supporting role with much reduced credibility in the study of archaeology. As central players in CRM work, SHPOs are expected to find creative solutions to a host of problems, but they have limited authority or resources to develop and carry out these solutions. While real-world solutions seldom match the happily-ever-after endings of fairy tales, they do offer opportunities through choices. In the fairy tale, Cinderella's beauty is finally recognized when she tries on the glass slipper and the burden of her wicked stepmother and stepsisters is magically lifted from her shoulders. In CRM work we do not have a glass slipper, and the benefits for archaeology and scientific advance still depend on our choices and efforts in bringing about organizational changes which can best support a future for both archaeological research and the stewardship of significant cultural resources.

David Snyder is with the Ohio Historic Preservation Office

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