The following comments were electronically submitted to the Adivsory Council on Historic Preservation. The OAC's Board of Directors, and the Education, Native American Concerns, and Government Affairs Committee's all had the opportunity to provide input.

July 13, 2008

Dr. Tom McCulloch

Office of Federal Agency Programs

Advisory Council on Historic Preservation

1100 Pennsylvania Avenue, N.W., Suite 803

Washington, DC 20004


Dear Dr. McCulloch:

Re. Draft ACHP Policy Statement “Using Archaeological Resources for Public Benefit, including Education and Heritage Tourism”

    The Ohio Archaeological Council is a private, nonprofit, charitable, scientific, and educational membership organization incorporated with the state of Ohio in 1975 to promote the advancement of archaeology in Ohio through research, education, and consultation with government agencies and the public.  We are pleased to have this opportunity to submit comments on the ACHP's draft policy statement on “Using Archaeological Resources for Public Benefit, including Education and Heritage Tourism.”

    Regarding the “use of the policy statement,” we believe that owners of archaeological sites, be they public or private, should be listed among those for whom the statement intends to provide guidance.  Because the vast majority of land in Ohio, as in the United States, is privately owned, and the vast majority of archaeological sites are located on private property, we believe the ACHP should encourage the private sector, as well as public agencies, to adopt this policy when considering opening archaeological sites for education and heritage tourism programs. 

    Regarding "balancing use of archaeological properties in tourism and education with privacy concerns," we believe “balance” should not result in permanently denying public access to archaeological sites on public land.  Completely denying such access is antithetical to the National Park Service's definition of "archaeological properties" used in the ACHP’s draft policy statement:  "the place or places where the remnants of a past culture survive in a physical context that allows for the interpretation of these remains" [italics added].  Native American and other ethnically affiliated archaeological sites that are permanently closed to public access are unavailable for the most meaningful type of interpretation, where direct, first-hand experience is attained.  The exclusivity implied by accommodation of religious interests would appear to be in violation of the constitutionally mandated separation of church and state.  We believe "balance" should be reflected in site interpretation or special and possibly restricted access on particular days of religious significance only when absolutely necessary.

    We believe the policy statement needs a stronger introduction.  The introduction should unequivocally endorse heritage tourism as an important way for people to connect with the living past and as a means of providing an economic context encouraging local communities to support the preservation and interpretation of archaeological properties, and archaeological research on those properties.  Furthermore, the introduction should more fully address the use of archaeological sites and the role of archaeologists in educating the public about science and culture.  In doing so, we suggest adding a separate subheading titled “Education and Archaeology” that complements the one for “Heritage Tourism and Archaeology.”

    In the section on “Heritage Tourism and Archaeology,” “other means of interpreting" archaeological sites should not be mentioned exclusively in the context of cases where access to the physical site is withheld (for reasons of responsible stewardship).  Sites do not interpret themselves, and the ACHP should encourage "electronic 'virtual' tours, exhibits, film, offsite interpretations, and other methods" as essential components for the interpretation of all sites.  Indeed, the ACHP should encourage that such interpretation be made available in multiple languages to facilitate international heritage tourism as exemplified in the UNESCO World Heritage site program.

    We recommend numbering the principles and their guidance.  It is easier to refer to “Principle 1” rather than a phrase or sentence describing it.

    We agree with the principles.  In particular, we believe the fourth principle, “Responsible public interpretation for education or tourism includes current scholarship,” is critically important, though we prefer the phrase “archaeological research” to “scholarship,” the latter of which we believe connotes academia to much of the public.  Much archaeological scholarship takes place outside academia, e.g., in a cultural resource management setting.   

    The guidance for the first principle includes the statement “The science of archaeology can foster a greater understanding of and appreciation for peoples and cultures of the past as well as the traditions, events and places valued by living peoples today.”  This is certainly true.  We suggest following this sentence with “It also fosters a better understanding of and appreciation for the work of scientists, the scientific process, and the role of science and scientists in modern society.”  Adding this sentence would amplify the message of using archaeology as an educational tool.

    Although we strongly agree with the fourth principle, we suggest the term “scholarship” be changed to “research from archaeological investigations.”   As stated above, we make this suggestion because we believe many people associate “scholarship” only with academia, and we want to convey the idea that other forms of current archaeological work or research, e.g., archaeological investigations conducted under the rubric of cultural resources management, often contribute to a better understanding of archaeological sites and should be included in “responsible public interpretation.” 

    The guidance for the fifth and final principle includes the statement “Both the excavation in the first place, as well as future stewardship of the archaeological site and resulting collections, needs to be determined prior to it being excavated as a part of a heritage tourism or public education program.”  This is true.  However, we are concerned that this sentence conveys the unintended message that “excavation equals archaeology, the goal of which is to amass collections of artifacts,” a message we believe the public should not be left with.  Leaving the public with this impression may encourage people to dig archaeological sites, perhaps for the sole purpose of acquiring collections, without proper supervision.  Furthermore, excavation is not the only form of participatory archaeology in which the public can be successfully engaged.  Many activities, including background research, geophysical survey, controlled surface collections, the processing of cultural materials, site monitoring and interpretation, etc., can be successfully undertaken as part of a participatory archaeology program.  Therefore, we suggest that the sentence be rewritten stating “Before the participatory archaeological activity is undertaken as part of a heritage tourism or public education program, it should be determined if the activity is appropriate.  The appropriateness of the activity should be determined by evaluating its impact against a site management plan.”

    Again, thank you for the opportunity to provide our comments. 


On behalf of the Ohio Archaeological Council,

Alan C. Tonetti


Chair, Government Affairs Committee

Ohio Archaeological Council

P.O. Box 82012

Columbus, OH 43202


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