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INSIGHTS

THE MANY FACES OF CRM


Using National and State Databases to Demonstrate Value and Efficiency of Federal Archaeology Programs in the United States

Gary D. Shaffer


According to NADB-Reports online, archaeological evaluation studies make up just 13 percent of the identification studies nationwide. One might expect that more surveys take place to locate archaeological sites than to evaluate the significance of known sites. Not all surveys find archaeological resources; some surveys find sites that readily allow determinations of ineligibility for the National Register; and still other identification studies locate sites that agencies or other proponents of undertakings plan to avoid through project redesign.

On a comparative note, NADB-Reports records online 253 identification and 78 evaluation reports for Maryland. These numbers indicate that evaluation projects constitute 31 percent of the identification projects. Also, Maryland's review and compliance log shows that the mean annual number of archaeological evaluation reports for FY 1992 through FY 1995--27.8 (s.d. = 5.9, range = 22-36)--represents 39.3 percent of the mean annual number of identification reports for the same period--70.8 (s.d. = 13.6, range = 55-84).

While several factors could well be involved, these figures may indicate that Maryland's identification surveys more effectively locate sites that warrant additional field studies of significance. NADB-Reports, however, includes records on projects other than Section 106 or even CRM studies, so it is not prudent to put too much stock in the absolute differences between the NADB and state databases. Still, the national numbers of evaluation studies are less than those of identification surveys; and, based on the Advisory Council statistics, less than 5 to 7 percent of all federal undertakings require separate field evaluations of National Register eligibility.

The degree to which archaeological properties are found to be eligible for the National Register of Historic Places is of further interest. With respect to Section 106 reviews, the determination that a National Register-eligible archaeological site lies within a project's area of potential effects generally leads to findings of "adverse effect" or "no adverse effect" (36 CFR 800.5 and 800.9). Federal agencies that find their undertakings to have such effects must consult with the Advisory Council [36 CFR 800.5 (d) and (e)]. The Advisory Council estimates that in FY 1994 it reviewed under Section 106 some 700 federal projects involving effects of one kind or another on archaeological properties (Thomas McCulloch, 1996 personal communication). Given that 4,800 to 6,720 of the 96,000 undertakings in the same period entailed archaeological field studies for identification or evaluation, only about 10 to 15 percent of the initial Section 106 investigations discovered significant archaeological sites. Furthermore, the 700 projects with adverse or no adverse effects on significant archaeological resources represent less than one percent of all federal undertakings for FY 1994. The small proportion of federal undertakings involving National Register-eligible archaeological properties is clear.

At the state level for FY 1992 through FY 1995, Maryland's compliance log shows a mean annual number of adverse or no adverse effects on archaeological historic properties of 32.3 (s.d. = 23.6, range = 4-61). This figure represents 1.3 percent of all federal projects reviewed for the same period (mean = 2,457), thereby underscoring the limited proportion of federal undertakings involving significant archaeological sites. The Maryland data also indicate that 19 percent of the initial recommendations for field identifications of archaeological historical properties (mean = 174, for FY 1992-FY 1995) actually find sites eligible for the National Register. This amount--or the "success" rate in finding significant sites--is slightly higher than the national estimates of 10 to 15 percent.

It is difficult to examine precisely how often field evaluations determine that given archaeological sites are eligible for the National Register, because figures on identification and evaluation projects have been combined. The available data do reveal, however, that more evaluation studies take place than result in determinations of National Register eligibility. Queries of NADB-Reports online for the 50 states and the District of Columbia show 8,149 evaluation studies and 6,317 data recovery studies, the latter presumably of National Register sites. Figure 1 provides regional comparisons of the numbers of archaeological data recovery studies with evaluation projects. For four of the five former NPS regions, the amount of data recovery (range = 357-2,142 records/region) is less than or similar to the frequency of evaluation (range = 452-2,817 records/region). The somewhat higher than expected numbers of data recovery projects in NADB reflect several factors: the inclusion of archaeological projects undertaken for reasons other than compliance with Section 106 (e.g., Section 110 studies, state or locally mandated projects), variable interpretation of the worktype "data recovery study" during NADB-Reports data entry, and the temporary (between years 1987 and 1992) reduction in NADB-Reports worktype categories by the NPS. The provisions of a field for National Register determinations in future versions of NADB-Reports may prove useful.

While we have examined the annual frequency of various adverse effect determinations on significant archaeological properties, we have not yet seen how many of these projects actually involve data recovery excavation. One must realize that not all Section 106 projects found to involve adverse effects will necessitate such intensive study. The proponents of a construction project, for example, might abandon their plans for a number of reasons; or they might decide to redesign their projects to avoid archaeological impacts. Also, if rarely, consulting parties might decide that destruction of a National Register-eligible site is an appropriate, even if regrettable, "treatment" in the public interest. According to the Advisory Council (Thomas McCulloch, 1995 personal communication), there were at most 98 council reviews of archaeological data recovery plans for undertakings with various adverse effects in FY 1994. This, again, is less than 1 percent of all federal undertakings for the same period. Even if all such reviews led to archaeological excavations, relatively few federal projects ever entail large-scale excavations. In Maryland the mean annual number of data recovery reports for FY 1992 through FY 1995 is 3.8 (s.d. = 1.7, range = 2-6). This quantity represents only .2 percent of all annually reviewed federal undertakings and it underscores again the extremely limited proportion of federal undertakings that need expansive archaeological excavations.

Figure 1

Figure 1

Conclusion

This examination of federal archaeology, while brief and employing several estimated statistics, has incorporated multiple lines of evidence and has indicated several points:

* Only a small proportion (ca. 5 to 7 percent) of the large number of annual federal undertakings reviewed through the Section 106b process ever require archaeological fieldwork to locate sites or to assess site significance.

* Fewer of the more intensive evaluation studies are needed than the initial identification surveys; and these archaeological identification/evaluation projects appear to find significant archaeological sites for less than 1 percent of all annual federal undertakings.

* Consultation among participants in the Section 106 process leads to large-scale data-recovery excavations for a fraction of the yearly federal projects with significant archaeological properties.

The federal archaeology program serves a valuable function by forcing archaeologists to distinguish between sites with little research potential and significant sites worth studying for public benefit. This screening process also provides basic information on past human settlement, technology, and adaptations in geographical areas that archaeologists otherwise would rarely investigate. Furthermore, the presented statistics reflect the success of Section 106 in getting preservationists and developers to work together to avoid most impacts on important sites.

Given the minimal proportion of federal projects ever needing archaeological investigations, Section 106 archaeology should not be a heavy burden on federal agencies. Indeed, the federal government is getting a relative bargain from its regulatory process of preserving important archaeological information. Accurate monetary figures on the combined governmental and private costs of this archaeological program are, unfortunately, unavailable. Still, American archaeologists would be wise to communicate the small percentage of Section 106 field projects to Congress and the public.

In our conversations with legislators and their constituents, we should also indicate that the current historic preservation system could still benefit from some change. For example, a good deal of time may be wasted in the Section 106 review of the 93 to 95 percent of annual federal undertakings that need no archaeological field study. Additionally the NADB-Reports data showed certain regional differences in the relative numbers of identification and evaluation studies. Analysis of these data may reveal how to conduct more effective surveys to locate sites eligible for the National Register. Further, some monies spent on the many identification and evaluation projects that find no significant sites might be better used for the intensive study of important sites and research problems.

Efficiency could be increased if we better establish which projects are unlikely to affect significant archaeological sites and more routinely institute programmatic agreements or other measures to eliminate them from future review. As I pointed out in a paper at the SAA Annual Meeting of 1987, there should be more consideration of project size and estimated site density when deciding if surveys of lands with otherwise "high archaeological potential" truly would be fruitful. Also, it might be better to streamline Section 106 and comparable state statutes so that CRM archaeologists are charged not with protecting individual historic properties but with investigating significant research questions in select geographical areas threatened by development (cf., A. C. Goodyear et al., American Antiquity 43:159-173; T. F. King, 1977, Resolving a Conflict of Values in American Archaeology. In Conservation Archaeology: A Guide for Cultural Resource Management Studies, edited by M. B. Schiffer and G. J. Gumerman. Academic Press: New York). Such a change may lead to the loss of some archaeological information. However, this new focus could help preserve data that we are more likely to use to interpret past human behavior for larger professional and lay audiences.

Fine-tuning the "motors" of our governmental archaeology programs can only be in our best interest. American archaeologists must recognize that the costs of the few warranted archaeological studies can still be substantial for the individual agency or the private sponsor. Besides improving the methodological bases of current CRM archaeology, we should assist lawmakers in finding creative ways to pay for archaeology and to compensate private landowners for the archaeological studies they sometimes must fund. In the latter case, it would be worth supporting the provision of tax benefits to private individuals for public archaeology.

Finally, American archaeologists should employ the data presented here and readily available through additional searches of NADB online and state CRM databases to make the case for public support of archaeology. It is critical to emphasize the importance of our discipline as the only means to learn about most of human history. We also must provide readily understandable examples of the significance of archaeology, perhaps using the services of a mascot like Smokey the Bear as a friendly spokesman. If we fail to communicate the benefits of archaeology to the public, our governmental archaeological programs--no matter how efficient--may themselves become antiquities. *

The following individuals provided helpful assistance and useful comments: Ron Anzalone, Lloyd Chapman, Terry Childs, Beth Cole, Al Dekin, Dan Haas, Bob Harris, Eric Hertfelder, Lucinder Jones, and Tom McCulloch.

Gary D. Shaffer, Ph.D., is the Preservation Officer for Archaeological Services at the Maryland Historical Trust.


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