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Cultural Resource Management:

The Importance of Consultation

Carly L. Ryther

ANTY 451 Dr. MacDonald

University of Montana

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Abstract

In the first phase of the National Historic Preservation Act ‘s Section 106

process one must ascertain the area of effect of the project and then consult with a

state historic preservation officer (SHPO), a tribal historic preservation officer

(THPO)(if the project takes place on the reservation or involves a traditional

cultural place), involve the public, as well as other consulting parties. I believe that

this is where most case studies show a lack of consultation and a lack of

involvement with all of the consulting parties and the public. In this paper I will

examine three case studies, in three different states, each with different consulting

strategies. By examining these case studies I can illustrate why consultation and

public involvement should not be an overlooked or undervalued aspect in cultural

resource management projects.

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Introduction

As a part of cultural resource management laws and practices, the National

Historic Preservation Act (NHPA) Section 106 process helps to ensure the

protection of historic resources that could be affected in a federal undertaking. As a

part of the NHPA Section 106 process, initiating consultation and involvement with

SHPOs, THPOs, other consulting parties, and the public are all essential in

preserving and protecting historical resources.

The goal of this paper is to explain why consultation and involvement are

important to the cultural resource management process, using the examples of the

three case studies to show where consultation and involvement were beneficial,

where they made mistakes in consultation and involvement, and how consultation

and public involvement could be improved in future cultural resource management

projects.

The case studies I intend to use are the construction of the Foley Square

federal building and courthouse in New York City, New York, the widening of Route

4 in Crow Creek Reservation, Buffalo County, South Dakota, and the First African

Baptist Church Cemetery in Philadelphia, Pennsylvania. I chose these case studies

specifically because they each have flaws, some major, and they can inspire future

solutions for consultation and public involvement. The one common denominator

in these case studies is that each site contained human remains.

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Another reason why I chose these case studies was to show that there are

other impacted communities besides Native Americans in the NHPA process. In the

New York and Pennsylvania case studies the human remains that were uncovered

were African American. Some of the issues in those case studies stem from the fact

that the consulting firms didn’t consult effectively with the impacted culture or

didn’t involve the public enough with information or participation opportunities. I

know that in most of the western United States cultural resource management

professionals are more aware of involving Native American tribes. However, on the

east coast cultural resource management professionals are less aware of this

involvement but I believe some of the strategies in consulting with THPOs should

apply to other communities of impact.

In using all three case studies we are able to see the differences in state

historic preservation guidelines, the differences in how the consulting firms decided

how to handle their projects, the differences in how the impacted communities were

or were not consulted and how they responded to the lack of involvement, the

difference in how the consulting firms dealt with public involvement in their

projects.

Important Federal and State Guidelines

In order to examine the three case studies, it is important to review their

respective state cultural resource identification guidelines. Section 106 of the NHPA

requires Federal agencies to take into account the effects of their undertakings on

historic properties, and give the ACHP an opportunity to comment. The historic

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preservation review process is outlined in regulations issued by ACHP. The

responsible Federal agency must first determine whether it has an undertaking that

that could affect historic properties. Historic properties are properties that are

included in the National Register of Historic Places or that meet the criteria for the

National Register. If there are historic properties found then the agency must

identify the appropriate SHPO or THPO to consult with during the process. The

agency should also plan to involve the public and contact other potential consulting

parties. If the agency determines that it has no undertaking, or that its undertaking

has no potential to affect historic properties, the agency has no further Section 106

obligations.

If the agency's undertaking could affect historic properties, then the agency

must determine the scope of work and proceed (SOW) to identify historic properties

in the area of potential effect (APE). The agency should then review background

information, consult with the SHPO or THPO, obtain information from

knowledgeable affiliations, and conduct additional studies if it is necessary.

Districts, sites, buildings, structures, and objects listed in the National Register are

considered. Any unlisted properties are supposed to be evaluated against the

National Park Service's published criteria (NPS, 2013), with consultation with the

SHPO or THPO and any Native American tribe or Native Hawaiian organization that

may attach religious or cultural importance to them.

It is the decision of the SHPO, not the applicant, to request preliminary

consultation from the NPS. A preliminary consultation focuses on one or several

specific issues and it is not for the review of an entire project. NPS will then express

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a verbal response directly to the SHPO. Even when a preliminary consultation has

occurred, NPS advises applicants to submit their applications early so that any

disputed treatments can be resolved before work can begin. (NPS, 2013)

If questions arise about the eligibility of a given property, the agency may

seek a formal determination of eligibility from the National Park Service and the

Keeper of the National Register. If the agency finds that no historic properties are

present/affected and it can provide documentation to the SHPO or THPO to that

effect it may then continue with its undertaking. If the agency finds that historic

properties are present, they must proceed to assess possible adverse effects. The

agency, in consultation with the SHPO or THPO makes an assessment of adverse

effects on the identified historic properties based on criteria found in ACHP's

regulations. (ACHP, 2013) If the ACHP agrees that there will be no adverse effect,

then the agency may continue with the undertaking.

The agency consults to resolve adverse effects with the SHPO or THPO and

others, who may include Native American tribes and Native Hawaiian organizations,

local governments, permit applicants, and the public. The ACHP may participate in

consultation if there are significant impacts to important historic properties, there is

a potential for procedural problems, or there are concerns in regards to Indian

tribes or Native Hawaiian organizations.

Consultation usually results in a Memorandum of Agreement (MOA), which

outlines agreed-upon procedures that the agency will take to avoid, minimize, or

mitigate the adverse effects. If an MOA is agreed upon then the agency proceeds

with its project under the terms of the MOA. If consultation proves irreconcilable,

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then the agency or the SHPO or THPO or ACHP itself, can terminate the consultation.

The agency has to submit correct documentation to ACHP and request ACHP's

comments. The agency head must take into account ACHP's written comments in

deciding how to proceed but does not actually have to abide by them. (ACHP, 2013)

Public involvement is an absolute key ingredient in successful Section 106

consultation, and the views of the public should be sought and considered

throughout the process.

One common rule followed by all states is that an historic resource must be

at least fifty years old or be eligible for the National Register of Historic Places. For

the First African Baptist Cemetery in Philadelphia one should refer to the

Pennsylvania Archaeological Site Survey. (The State Museum of Pennsylvania and the

Bureau of Historic Preservation, Pennsylvania Historical and Museum Commission,

2008) This document is designed by the Section of Archaeology under the State

Museum of Pennsylvania and the Bureau of Historic Preservation, Pennsylvania

Historical and Museum Commission to show the criteria of the identification of

prehistoric and post-contact sites in Pennsylvania. This criterion follows the model

of: A) Associated with events of historical significance, B) Associated with persons of

historical significance, C) historical buildings identified through engineering and

architecture, and D) sites with information potential or data. (King, 2013)

In this case study there was the discovery of human remains, which should

be handled by abiding the Guidelines for Archaeological Investigations in

Pennsylvania (Bureau of Historic Preservation, 2008) standards for handling human

remains. Section 106 requires that the responsible Federal agency have to develop

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a plan for the treatment of any human remains that are located in the course of the

federal undertaking. The Pennsylvania Historical and Museum Commission has a

policy for treatment of human remains that includes notification of descendent

populations and negotiated plans for removal, study, and reburial of these remains.

Any project with the potential to encounter human remains should develop a plan

for their treatment prior to the commencement of fieldwork. (Bureau of Historic

Preservation, Pennsylvania Historical and Museum Commission, 2008)

The Guidelines for Identifying Cultural Resources: Bureau of Land Management

for Montana, North Dakota, and South Dakota Handbook (Ott, 2003) would be used

for the expansion of Route 4 on the Creek Reservation in South Dakota case study.

The only difference in what is considered a historical resource in the guidelines for

South Dakota is that there is mention on traditional cultural places as defined by

National Bulletin 38. Most guidelines for archaeological investigations for the east

coast do not mention traditional cultural places.

Their standards for the treatment of human remain are that once a human

skeleton has been turned over to the state archaeologist or has been exhumed under

permit, it should be examined by a qualified skeletal analyst in a timely fashion in

order to determine its sex, age, and state of health and its racial, cultural, or ethnic

affiliation if possible. Records of the analysis must be kept on each individual and

included in the report to the state archaeologist. Once any human remains have

been identified as belonging to a modern tribe as a result of the skeletal examination

or the historical or archaeological evidence, the state archaeologist should contact

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the SHPO and THPO to discuss what to do with the remains and any associated

burial goods. (Bureau of Historic Preservation, 2008)

If the tribal representatives accept the remains for tribal reburial, the state

archaeologist will then deliver the remains to the parties involved. If those remains

that either are not claimed by the tribe or could not be identified as to belonging to a

tribe should be reburied in a cemetery designated by the Office of History. The

reburial of remains under the jurisdiction of the state archaeologist occur within

five years of being exhumed except in cases, like the discovery of mass burials or

large numbers of skeletons, where the process of identification will take longer or

where the remains are determined to be of scientific importance. In those cases, up

to five additional years can be taken before reburial is required. (ACHP, 2013)

The last case study of the construction of Foley Square’s courthouse and

federal building in New York City should have followed the Cultural Resource

Standards Handbook: Guidance for Understanding and Applying the New York State

Standards for Cultural Resource Investigations (The New York Archaeological Council

Standards Committee, 2000) that was prepared by the New York Archaeological

Council Standards Committee. Once again the standard for identifying a significant

historical resource are criterion A through D. Their treatment of human remains, if

discovered are a long the same lines as South Dakota’s treatment of human remains.

The difference here is that it is only treated as an archaeological site if the remains

are historic and the lineal families wish for them to be undisturbed or if it they are

prehistoric and require a consultation with local tribes, if there are any.

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Native American tribes, if involved, have the last say in how the remains are

handled, whether they remain buried there undisturbed or exhumed and allowed

for research or are returned to tribal lands. Ultimately these discussions between

tribal representatives and the consulting agency make or break the project. If the

tribal representatives do not wish for the remains to be disturbed the project cannot

move forward in that location. (ACHP, 2013) However, if the tribal representatives

and the consulting agency come to an agreement about the removal and reburial of

the remains then, the project can go on during its original timetable.

Manhattan Colonial Era Slave Burial Ground at Trinity Church, New York

Now that we’ve discussed the guidelines for cultural resource management

for the Pennsylvania, South Dakota, and New York case studies, we can now move

fully into the details of these case studies. The largest and, possibly, most highly

publicized case study is that of the Foley Square federal building site where the

largest colonial era enslaved African American burial ground was uncovered during

construction in 1991.

In this case the General Services Administration (GSA) was the agency on

site when the remains were uncovered. We’ve seen already that most guidelines for

conducting cultural resource management require that agencies include the

formation of a plan to properly treat human remains, if they are discovered, as a

part of their project plans. The agency in charge of this site had no plan in place to

handle human remains. (Henley Dean & Dwin Vaughn, 2003)

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GSA continued to plan a full remains retrieval of the site. As they began their

exhumation, they did not anticipate the scope of work that would be required at this

site; 420 persons were exhumed and there were still more to be uncovered. At the

same time that they were exhuming the human remains they were also continuing

with the construction at the site. This flagrantly flies in the face of how to protect

and preserve historic resources. At this point the blunders of the GSA had made it

into the public sphere of knowledge and the African American community of the

New York City area became very concerned that the remains of this hugely

important site were being mistreated and disrespected. They also felt, as a

community, disrespected by the GSA because upon finding the remains no one had

consulted any of the African American community in the area, experts in the African

diaspora to the United States, or even brought any African American archaeologists

to help with this exhumation.

After this slight, the African American community began to protest the sight

because not only had they not been consulted in any aspect of this project but, there

were many graves and remains that were destroyed by the construction process.

These protests drew a lot of attention to GSA and they halted work on the site as to

show some compliance to community wishes and to really assess the work ahead.

(Henley Dean & Dwin Vaughn, 2013) As a nation our history really emphasizes the

enslavement of African Americans in the South, but not much is known about

slavery in the North. The invisibility of slavery in the North is what makes this site

so very important not only to the community of African Americans in New York City,

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it is important for our national history to properly represent slavery in the entirety

of the United States.

The oversight of this project increased with the Advisory Council for Historic

Preservation (ACHP) and the community activists. The protests against GSA’s plan

continued not only with the community activists but, also politicians and scholars

who had become aware of the disappointing archeological work being done on the

most important colonial era slave site above the Mason-Dixon Line. The result of

this attention was a hearing in the House Subcommittee of Public Works where

many came to testify against the GSA and their treatment of the site and the human

remains.

After the hearing, several changes occurred in the project. The city switched

archaeologist firms to, physical anthropologist, Michael Blakey and his team and

students from Howard University, a historically African American university. This

was beneficial because African American scholars and students became involved in

their own history. The disadvantage of this situation is that many artifacts stayed

with GSA’s consulting agency while Howard University was in charge of the

forensics. Splitting the sites findings is detrimental to studying the sight as a whole

and communication between the two groups was lacking. The construction at the

site stopped entirely because the community activists lobbied President George

H.W. Bush to cease the destruction of their ancestral remains and appropriate $3

million to build a memorial there. By 1992 this site was listed under the National

Register of Historic Places because of its regional and national significance. (Joseph,

2004)

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GSA then proposed partial mitigation of adverse effects to the burial ground

by undertaking programs of data analysis, curation, and education, they were also

required to reinter the remains in a timely fashion. The ACHP has questioned

whether GSA truly fulfilled their mitigation requirements due to the length of time it

took to complete. The National Park Service (NPS) also voiced concerns over GSA’s

compliance with the research design, especially completion of the artifact analysis.

The NPS also noted that GSA failed to consult with NPS regarding the implication of

the proposed reburial on the integrity of the site and its status as a National Historic

Landmark. At the present, the remains were reinterred October 2003 following

activities planned by GSA to commemorate the site leading up to the reburial.

(Henley Dean & Dwin Vaughn, 2013) There is a documentary called Unearthing the

Slave Trade that really shows this project in detail and the problems it has had, that

is very helpful for anyone who wants to understand the project.

From this case study we can see that mistakes were made. First GSA and

their consulting agency should have had a plan of action ready for the possibility of

finding human remains and they were severely unprepared for this possibility.

Once the human remains were discovered site exhumation and construction

occurred at the same time causing destruction of historical resources and human

remains.

The agency did not consult with the community of descendants, experts in

African diaspora, or included African American archaeologists or Archaeology

students to participate in the excavation. After the site became the team at Howard

University’s responsibility, GSA lagged in completing their partial mitigation of

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adverse effects that occurred at the burial site under their jurisdiction. GSA also did

not consult the National Parks Service about the proposed reburial of remains that

were a part of a National Historic Monument. (Joseph, 2004)

A lot went wrong in the cultural resource management process here. This

site and its complications had a huge impact on the future of cultural resource

management. Many archaeologists would say that the result of the huge force of

community activism and media attention really enforced the process of including

descendent communities in salvage excavations, especially when human remains

are involved. Even though cultural resource management has changed to more

heavily emphasize the inclusion of descendent communities, we still see too many

cases where there is a lack of consultation. The result of this is that is becomes a

publicized blunder by cultural resource management professionals and the

community and public become very active in seeing mitigation done properly and at

the agency’s expense.

Philadelphia First African Baptist Cemeteries, Pennsylvania

The next case study is similar to the New York colonial slave burial ground,

The First African Baptist cemeteries rediscovered on Eighth and Tenth Street in

Philadelphia, Pennsylvania. I admit now that I knew about this site before I had ever

taken an archaeology class because I lived in the Philadelphia area and it became a

subject that lingered on the news for many months. These long forgotten

cemeteries were two of the first cemeteries to be the resting places for free African

Americans practicing religious freedom. The Eighth Street cemetery was in use

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from 1823 until 1842 and the Tenth Street cemetery was used from 1810 until

1822. (Cotter, 1992)

The Tenth Street cemetery was first uncovered when ramps were being

constructed for the new Vine Street Expressway. Once discovered, archaeologist

Michael Parrington led the excavation from 1983 until 1984 under the contract with

the Redevelopment Authority of the City of Philadelphia with supplemental funding

from the Pennsylvania Department of Transportation, the Federal Highway

Administration, and the William Penn Foundation. The Eighth Street cemetery was

discovered in 1990 directly in the path of the new expressway, archaeologist John

McCarthy and his team undertook this excavation. Both archaeological recoveries

were done in accordance with federal historic preservation legislation under the

NHPA. (Jeppson, 2007)

The two cemeteries were a part of the two First African Baptist Church

congregations. The cemeteries collectively were in use from 1810 until 1842 and

during that time the city of Philadelphia saw a huge rise in the African American

population, swelling from 4,200 persons to 11,000. These cemeteries show the

growth in African American population due to freed slaves migrating north through

a fifty-year period of time.

The remains at both sites allowed archaeologists to observe the presence of

West African burial rituals in early to mid 19th century free African American

gravesites. (Parrington & Wideman, 1986) The remains also gave clues as to what

the quality of life were like for free African Americans during this time. They also

did some forensic work showing mother-infant mortality, prevalence of diseases,

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life expectancy, etc. All in all they were very exciting and important site in

archaeology.

What is most notable about the Tenth street site is how the consultation and

public involvement was accomplished. The sudden substantial archaeology

outreach program began with this project, very early for its time. The First African

Baptist Church is still extant and its congregants were contacted very early on in the

planning phase for both sites. The church and its congregants were, of course, very

interested and excited about this project and lent their extensive knowledge of the

history of the church to the researchers. During the first excavation from 1983 to

1984 a wooden viewing platform was built around the site for members of the

public to observe the archaeological work being done. (Cotter, 1992)

Detailed handouts were also made up and sent around the community and

local schools to notify them that they would like for the public to come and see the

work being done. Almost 3,000 people came to observe the site during this time,

many of them congregation members and schools. The Afro-American Historical

and Cultural Museum formed tours and platform interpretations of the work being

done for its museumgoers. A very popular article was published in Archaeology at

the same time a documentary about the sites, Ground Truth: Archaeology in the City,

came out.

The Eighth Street cemetery site, unfortunately, was not open for public

viewing because of its location pretty much smack-dab in the middle of a very busy

and under construction Vine Street Expressway. However, during the analysis of

the remains, the John Milner Associates opened their laboratory for more than 50

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groups, many of whom were from inner city schools, to observe some of the analysis

being done. The recovered collections were housed between the Afro-American

Historical and Cultural Museum as well as at the Atwater Kent Museum of

Philadelphia for an exhibit on urban archaeology called City Beneath Our Feet.

(Cotter, 2004)

The First African Baptist cemeteries were excavated around the same time as

the Manhattan Colonial Era Slave Burial Ground. Yet, when you compare them side-

by-side they couldn’t have been handled more differently. The first had a multitude

of dramas that severely impacted the archaeological site and was highly publicized

in a bad light during the course of the project. The second seemingly went off with

out a hitch. This is due to the correct implementation of national historic

preservation legislation and consulting and communicating to descendent

communities and the public.

By engaging the First African Baptist Church congregation the archaeologist

gained so much more knowledge about the history of their site than if they had just

stuck to historical documents related to the site. By engaging the public with the

excavation of Tenth Street site and the data analysis of the Eighth Street site they

brought a lot of good publicity for archaeology in the city and partnered with the

Atwater Kent Museum of Philadelphia and the Afro-American Historical and

Cultural Museum for added patronage.

1997 Widening of Route 4 Creek Reservation, South Dakota

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In 1997 the Bureau of Indian Affairs (BIA) proposed a reconstruction of an

eight-mile section of Route 4 that runs through the Crow Creek Reservation in South

Dakota. The BIA shared its plans for construction and that there would be historic

properties affected by said construction with the South Dakota SHPO. However,

earlier documentation at the SHPO showed that the BIA submitted an archaeological

data recovery report that stated no historic properties affected. (Standill, 2004)

Because of the conflicting nature of the reports the South Dakota SHPO requested

and ACHP investigation of the project.

The archaeological investigation exposed ten archaeological sites that were

in the area of the construction project. The sites were reported to have been

associated with previously identified archaeological districts and a National Historic

Landmark. The BIA proceeded with archaeological data recovery at three of these

sites before it resolved National Register-eligibility issues, reached a finding of

either adverse or no adverse effect on historic properties, or consulted to develop

mitigation measures with the SHPO, the ACHP, or other consulting parties.

In addition to that whole mess are the outside reports that hundreds of

human remains were uncovered during the archaeological data recovery at three

Plains Village storage pits that were estimated to date back to the contact of the

affiliated tribes and European Americans. This discovery is thought to represent the

devastation of the local tribes from the introduction of non-native disease (e.g.

smallpox). (Standill, 2004)

The BIA had reported that it had conducted consultation with the Crow Creek

Reservation and three affiliated tribes about how to properly proceed with the

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removal and reinterring of the human remains. However, the persons identified by

the BIA as contacts for the Crow Creek Reservation and three affiliated tribes denied

any kind of notification or contact by the BIA.

This case, while not as highly publicized as the Manhattan Colonial Era slave

burial ground, has shown a great deal of poor cultural resource management. The

lack of communication or miscommunication between the BIA and the South Dakota

SHPO and THPO is truly unbelievable. The BIA’s reports were very inconsistent.

The BIA reported that there weren’t any historic properties affected and then there

were ten. This project just seems like a lot of misdirection by the BIA, who probably

had a tight schedule to adhere to and not an abundance of consideration for NHPA,

NAGPRA, and the state guidelines for cultural resource management. In those

aspects, I feel like this project actually was worse than the Manhattan Colonial Era

slave burial ground. For as poorly as the Manhattan CRM project went at least there

was some consideration and mitigation for historic properties that were affected

even if it was after the fact.

Conclusion

As we have seen by examining the cultural resource management procedures

in the three cases studies presented here, the consultation process is extremely

important. Poor consultation results in bad publicity for the agency disrespect

shown to lineal descendants and the communities that have been impacted by the

botched projects. The NHPA Section 106 process is in place so that federal agencies

have a guideline to follow to preserve history. It also mandates consultation with

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SHPO, THPO, and affiliated persons with the project. The problem encountered in

Manhattan and Crow Creek Reservation is the poor display of consultation. The

agencies did “consult” but it was not to the extent that a well-done CRM project

should be.

When consultation is done with the right way CRM projects run smoother.

Comparing the Philadelphia case study to Manhattan and Crow Creek Reservation

shows that it is possible to complete a CRM project with in depth consultation and

public involvement with out sacrificing a reasonable timetable for completion.

There should be no excuse for any agency to not consult to the best of their abilities.

Hopefully, in the future of CRM, there can be some modification to NHPA Section

106 and NPS consultation guidelines to hold agencies and cultural resource

management professionals to a higher standard of archaeology that includes a

stronger consultation and public involvement guideline.

It is incredibly important to include lineal descendants and the community in

archaeology projects. This involvement increases the knowledge and the possible

data archaeologists can collect from those sites. Encouraging community

participation can unlock historic documents that are not kept by the local

government and important oral traditions that have thrived since the past. The

history of past communities is part of how our present cultural identities are

formed.

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References

King, T. (2013). Cultural resource laws & practice. (4th ed.). Lanham, Maryland:

AltaMira Press.

Cotter, J. (1992). The buried past: An archaeological history of philadelphia.

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Henley Dean, L., & Dwin Vaughn, C. Department of the Interior, Advisory Council for

Historic Preservation. (2003). New york: Construction of foley square u.s.

courthouse and federal building, new york.

Standill, A. Bureau of Indian Affairs, Advisory Council for Historic Preservation.

(2004). South dakota: Widening of route 4, crow creek reservation, buffalo

county.

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consult.htm

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