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INSIGHTS

THE MANY FACES OF CRM


Changing Directions: A Roundtable Discussion, Redux

Carol S. Weed and W. Kevin Pape


In anticipation of the 1997 SAA meeting's significant CRM component, the Insights column began a two-part article in the January 1997 SAA Bulletin. The article is devoted to the results of a roundtable discussion in which the participants explored a series of questions designed to probe the changing directions in CRM programs. The scope of the roundtable was presented in the earlier column. The roundtable discussants included: Ellen Armbruster (Federal Energy Regulatory Commission, Office of Pipeline Regulation, Environmental Review and Compliance Branch); Kurt W. Carr (Pennsylvania Historical and Museum Commission, Bureau of Historic Preservation); Susan Levitt (Columbia Gas Transmission Corporation, Construction Services, Environmental Project Manager); Daniel G. Roberts (John Milner Associates, West Chester, Pa.); and Lynne Sebastian (New Mexico state archaeologist).

The Roundtable (Part II)

Question 4:

What is the client and agency response to such weighted surveys? If Phase I surveys still need to be completed to deal with non-excluded classes of resources, then is the survey process truly being expedited, and is the measure reducing costs and review time?

Carr (November 26): Upland settings characterize the majority of projects and the majority of any given project area. Obviously no survey in these regions will result in lower costs. When other types of resources are predicted (farmsteads will probably be the most common), the reduced field investigations will usually, but not always, represent a savings to the agency.

Sebastian (November 27): Our problem with weighted surveys is coming up with the wherewithal to synthesize existing information in order to use that information as a basis for decisions about the future. Section 106 as practiced is totally reactive and case specificthere is no mechanism for synthesizing what we have learned from years of survey and excavation and using that information to inform our decisions about future surveys and excavation. In my experience, both agencies and clients want more sensible, scientifically defensible survey strategies that build on what we have learned so far. The issue is to be sure that such strategies are focused on and driven by good science and sound resource management and are not just a means of decreasing political pressure or hijacking cultural program dollars to benefit other agency programs.

Levitt (December 2): Any time that fewer shovel tests are placed in the ground, the client saves money. If that trend becomes strong enough there will be economic incentive to try to confine new impacts to areas where fewer significant resources are predicted to be found and where surveys are less expensive. In the long run, this would lead to less pressure on highly sensitive areas for businesses/agencies which routinely deal with Section 106 compliance. However, Section 106 has a reputation for crashing construction schedules and budgets. Therefore, industry/agencies must be assured that any innovative change is fully accepted by the state agency as well as the federal agencies who may also comment on the project. There may be significant hesitation to try a new approach. Implementation workshops should be made available if/when a SHPO makes a major revision to its regulations.

Roberts (December 2): I imagine that many agencies might think the "Watershed Model" is a good idea, since they will most likely be doing less archaeology in Pennsylvania, but I would also think that some federal agencies, being the entities that must comply with the provisions of the National Historic Preservation Act (NHPA), might be wondering if they will be in compliance on undertakings in the 19 watersheds called out for exclusion. Given the possibility that "late discoveries" might occur more often in Pennsylvania now, and given the possibility of increased litigation for being in non-compliance, the cost-effectiveness of implementation of the "Watershed Model" has not yet been determined.

Armbruster (December 4): When considering high and low probability areas, and prioritizing resources, one has to consider individual types of resources. However, I don't see how the Pennsylvania Historical and Museum Commission (PHMC) plan would streamline the section process for our applicants, here at the Federal Energy Regulatory Commission (FERC), unless upland sites were the only type of resource likely to be encountered in the area of potential effect (which may be the case in some small projects). We would still require some study/review to identify other types of resources.

Question 5:

If plans such as that put forth by the PHMC are acceptable, is it likely that agencies and clients will begin to accept other alternatives to traditional fieldwork strategies? For example, the OHPO recently proposed that a Phase III Data Recovery program of traditional fieldwork not be completed for a narrow waterline corridor which was passing through a National Register­listed site. Rather, OHPO recommended mitigation of adverse effects by analyzing pre-existing collections which had not been professionally evaluated and monitoring construction in areas likely to yield human burials. In this case, OHPO put forth the alternative to fieldwork. Would clients and agencies be accepting of such alternatives if they were put forth by consultants?

Carr (November 26): Practical alternatives to the standard Phase I, Phase II, or Phase III process are always welcome. I think it is important that we have a reasonable idea of the types of resources which are being lost/impacted, but alternative solutions to the management of resources are possible. Pennsylvania has negotiated similar types of mitigation measures as described for Ohio.

Sebastian (November 27): First, I would like to say that most of the resistance to alternative strategies that I have seen has come from CRM consultants and tribes, not from agencies or clients. Second, I would note that this example is a mitigation alternative and not an identification alternative, and that I, personally, am more comfortable with flexibility at the mitigation stage than I am at the identification stage. If you blow off whole chunks of the landscape at the identification stage, you really don't know what you are letting go; if you decrease the intensity of mitigation you have at least some idea of just what you are letting go. In part, this is a western biashere we say "survey is cheap" and tend to try to identify the whole universe of affected properties and then adapt to financial and other pragmatic constraints at the mitigation stage. I understand the survey isn't cheap where many of you work.

Levitt (December 2): As I stated above, I believe there will be a lot of hesitation to try anything new because of the uncertainty that the outcome will be accepted by all reviewing agencies. While the rules of Section 106 may be well understood by industry, the value judgment placed on resources and mitigation are not. Currently, industry complies with Section 106 more by rote than by real understanding. Changing the rote method will take time, but industry generally will favor the principle.

Roberts (December 2): The BHP may believe that by implementing its "Watershed Model" it is setting a trend that will be embraced in one fashion or another around the country. Maybe so, but I'm not sure this kind of initiative on the part of one SHPO office should be the trend-setter, particularly since its ramifications on federal agency compliance are still to be realized. Since the lead federal agency is the entity that must comply with NHPA on its undertakings, I have long wondered how the states have, willingly or unwillingly, usurped this responsibility. Who has produced guidelines for archaeological investigations in most every state? Who is implementing the "Watershed Model?" and why has the Advisory Council and/or the NPS not issued public comment on it? Who is recommending non-excavation mitigative strategy in Ohio? The answer in all cases is one or more SHPO offices. Rather than the states taking on a responsibility that is not theirs, why aren't the federal agencies assuming the responsibility that is theirs? Why is the Advisory Council not providing strong guidance and leadership to the federal agencies so that they do assume their responsibility? Why is one state like Vermont saying, in effect, "Hell no, lead federal agency, we won't do your job for you any more?" I believe that questions such as these are much more germane to what's happening with our national historic preservation program than the more narrowly defined issues revolving around Pennsylvania's "Watershed Model," although the latter is certainly one symptom of a system that, from my vantage point as a consultant who has worked primarily in the mid-Atlantic and New England regions for more than 20 years, needs to be looked at, and re-evaluated, very carefully.

Armbruster (December 4): I think that agencies and applicants will always welcome (in principle) alternatives to traditional fieldwork strategies, especially if they take less time and cost less money. The frustration for our applicants is how long the Section 106 process takes (and how much it costs), and that the schedule is so unpredictable. Applicants who express a willingness to experiment want to know that they won't be turned back half way through the process by one player or another.

The one thing I have found out about bureaucracies is that they are very conservative! Everything must be done according to regulation, and regulations are very hard to change. This is why, as a practical matter, it may be easier to introduce innovation at the state, rather than the federal level. The SHPOs' offices are smaller bureaucracies than the federal agencies, and SHPOs are dedicated to historic preservation by legislation and regulation, whereas federal agencies are dedicated first and foremost to their enabling legislation, which is generally not historic preservation.

Question 6:

Finally, if the alternative strategies put forth by PHMC and OHPO are acceptable to all the parties involved, does this mean that we are sacrificing elements of our historical heritage because of economics? Will the compromises required by alternatives to traditional methods of inventory, recordation, and mitigation ever be acceptable to the future generations of archaeologists, architectural historians, historic preservationists, and cultural resource compliance officers who will be practicing in the compliance field in the future?

Carr (November 26): The word "sacrifice" is probably not appropriate. Archaeologists have always considered funding in relation to data needs. Investigators invariably reach the point where it is simply not cost effective to collect more "data" and we stop. In Pennsylvania, we feel that we have reached that point in some watersheds when it comes to collecting additional data on upland "lithic scatters." Future generations may wonder why we did not look at certain topographic settings and they may be appalled at our methods. They may even have to cut back further than we have. However, they will probably be more perplexed at why we conducted so many surveys (35% in Pennsylvania) that did not find sites than why we missed certain types of sites.

Sebastian (November 27): Yes, of course we are sacrificing elements of our heritage because of economics. We always have and we always will. What is critical is to recognize that we are making these decisions, to ensure that we devote our scarce time and money resources to those efforts that have the greatest pay-off for preservation, and to maximize the gain in knowledge and public benefit from the management choices that we make.

If we are doing less survey and less excavation, we need to target our efforts very carefully to maximize preservation of sites and recovery of data, and we need to depend more heavily on effective discovery procedures and cost-effective strategies such as monitoring and salvage.

We can't do everythingif we do our best to maximize the benefits and expedite the process, if we put preservation of the resources ahead of bureaucratic process, and if we stand firm in the face of political pressure on us to do things that are not in best interest of the heritage of the American people, then we will have done our best. Future generations of CRM professionals aren't going to approve of us no matter what we dohave we learned nothing from the parable of the Skeptical Graduate Student?

Levitt (December 2): I agree with Ms. Sebastian. Aboriginal and European settlement patterns probably overlap quite heavily in some areas, and modern habitation continues the trend, replacing the early European settlements. Too much preservation will cripple a society. Gary Larson might depict the extreme as purely vertical development over areas previously surveyed so that the rest may remain preserved until such time as an archaeologist might find funding to research a new area. Under Section 106 and under NEPA, a balance is sought between impact and preservation, economic desires and resource conservation. I think the proposal discussed in Mr. Pape's questions pursue that balance.

Roberts (December 2): Yes, it appears that we are "sacrificing elements of our historical heritage because of economics. Even the BHP has publicly characterized its "Watershed Model" as "policy, not science." However, this is nothing new, since there have always been trade-offs and compromises. The difference with the "Watershed Model" is the nature, degree, and timing of the trade-off. While I agree that preservation issues should not be the "be-all and end-all" in consideration of project effects, and that compromises are very much a part of the consultation process, if the states are the ones making all the compromises and decisions affecting the resource base, we will ultimately have an unworkable hodgepodge of procedures and interpretations across the country, with absolutely no consistency from state to state. God knows, there's precious little of that now. The time seems ripe for the Advisory Council and the National Park Service, if they can call a truce in their long-term territorial dispute, to exercise leadership by providing programmatic guidance to federal agencies and state historic preservation offices in their responsibilities under the National Historic Preservation Act.

Armbruster (December 4): Are we sacrificing elements of our historical heritage because of economics? Yes, have done and always will. The job of a federal agency is to balance competing interests. Historic preservation is not always going to come out on top. Do we also sacrifice our heritage because of egocentrism, ethnocentrism, and personal biases? Yes, of course. (It is amazing how many SHPOs in this country are very strongly biased toward prehistoric sites, regardless of the definition of "historic property" in the regulations.) We should not flatter ourselves to think that "traditional methods of inventory, recordation, and mitigation" will not be judged and found wanting by future scholars. The best that we can do for future generations is articulate clearly what our biases ad strategies are, and why, so they can understand what we did, even if they don't agree with it.

Kevin Pape is the associate editor for the Insights column. He and Carol Weed are both CRM consultants with Gray & Pape, Cincinnati, Ohio.

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