Continuing Resolution Funding Historic Preservation Programs at FY 2008 Level. On September 30, 2008, President Bush signed into law a continuing resolution (HR 2638) funding most government agencies, including the Department of the Interior and the National Park Service, at FY 2008 levels until March 6, 2009. The continuing resolution was needed because Congress did not pass 12 annual appropriation bills by the end of the 2008 Federal fiscal year (FY). The FY runs from October 1 through September 30.
Preserve America Program. As a result of last year’s Preserve America Summit, the DOI and the Advisory Council on Historic Preservation (ACHP) assembled a 10 person expert panel to evaluate the current federal historic preservation program and make recommendations. Their first meeting was May 8. Their report is to be released this fall. None of the panel members is an archaeologist. Under the Preserve America program, every three years federal agencies, including the ACHP, are to submit progress reports to the President on their efforts to identify, protect, and use historic properties in their ownership. Agencies have until the end of FY 2008 (Sept. 30) to submit their progress reports. The ACHP’s report is due by Feb. 19, 2009. At a recent meeting reporting on the status of these reports hosted by the ACHP, senior federal officials discussed the need to have a clear set of updated standards for professional qualifications in historic preservation, including archaeology. The Secretary of the Interior’s professional qualification standards date to 1983 http://www.nps.gov/history/local-law/arch_stnds_9.htm. Revision of the standards was proposed in 1997http://frwebgate4.access.gpo.gov/cgi-bin/PDFgate.cgi?WAISdocID=75019312460+0+1+0&WAISaction=retrieve, but not promulgated as a final rule.
Revolutionary War and War of 1812 Project. After years of research and collaboration, the “Report to Congress on the Historic Preservation of Revolutionary War and War of 1812 Sites in the United States” was completed and recently presented by the National Park Service to Congress http://www.nps.gov/pub_aff/rev1812/preserve.htm. For additional information, go to http://home.nps.gov/applications/release/Detail.cfm?ID=799.
2008 American Battlefield Protection Program(ABPP) Grants Pertaining to Ohio. Civil War Preservation Trust (in Arkansas, Florida, Georgia, Kentucky, Louisiana, Mississippi, Missouri, New Mexico, Ohio, Oklahoma, Tennessee, Virginia, and West Virginia), $95,000. Provide detailed GIS mapping data for 30 Civil War battlefields identified by the Civil War Sites Advisory Commission (http://www.nps.gov/history/hps/abpp/battles/tvii.htm) as among the most significant and most endangered. This data will help identify parcels that are currently unprotected, and clarify priorities for land protection. Ohio Civil War battlefields are Buffington Island and Salineville (the site of Morgan’s surrender).
Great Lakes Historical Society, $18,000. The 1813 Battle of Lake Erie swung the tide of the fighting on the Great Lakes during the War of 1812 in favor of the United States. Define the boundaries of the battlefield through an underwater archeological survey of the naval engagement. The condition of any remaining resources will be assessed.
Ohio Historic Preservation Office, $45,000. Update inventory and survey data collected for nine Revolutionary War and War of 1812 battlefields in Ohio (Revolutionary War - Fort Laurens, Pickaway Settlements, Lichtenau, Gnadenhutten, and Crawford’s Defeat; War of 1812 - Fort Meigs I, Fort Meigs II, Dudley’s Defeat, and Battle of Lake Erie). This project will build upon surveys conducted by the OHPO for the ABPP in 2002.
The Colonel Charles Young Home National Historical Site Study Act (HR 6616), http://thomas.loc.gov/cgi-bin/query/z?c110:H.R.6616, was introduced in the House of Representatives by Rep. Hobson (R-Springfield, Ohio) on July 24, 2008, and referred to the House Committee on Natural Resources. H.R. 6616 directs the Secretary of the Interior to conduct a study of the Colonel Charles Young Home in Xenia, Ohio, and other associated locations (none are in Ohio) to determine if those locations should be included as a unit of the National Park System, to include those locations if the Secretary concludes that they meet the criteria for inclusion, and for other purposes.
New National Park Service (NPS) Technical Brief on Archeology and Civic Engagement.Archeology can play an important role in efforts to strengthen communities and promote public dialogue, particularly as archeological projects increasingly involve the communities in which they occur and various stakeholders. This new technical brief provides explanations of civic engagement and social capital as well as case studies and suggestions for ways that archeologists can participate in these efforts. NPS Technical Briefs can be found at http://www.nps.gov/archeology/pubs/techBr/index.htm.
Information about bills, legislators, the legislative process, etc., can be found at http://www.legislature.state.oh.us/. After June 30, 2009, bills not enacted into law need to be reintroduced and the legislative process begun anew when the 128th Ohio General Assembly convenes on July 1, 2009. We are monitoring the status of these bills and have prepared or are preparing written testimony on them should they come before the committees to which they have been assigned. The November election saw control of the Ohio House of Representatives go to Democrats. As a result, bills introduced by Democratic legislators will have a better chance of moving through the legislative process. Republicans retained control of the Ohio Senate.
Ohio House Bill HB 16/Senate Bill 336, establishing the Ohio Historical Society income tax contribution fund creating a matching grants program for history and historic preservation organizations in Ohio, for which the OAC would be eligible. The bill was introduced into the House by Rep. Chandler (D) on February 20, 2007, and assigned to the Ways and Means Committee. The companion bill, S 336, was introduced in the Senate by Sen, Wagoner (R) on May 12, 2008, and assigned to the Ways and Means and Economic Development Committee. Neither committee has held hearings on the bill. An effort will be made on Statehood Day (see below) to get the bills heard in committee. The Legislative Services Commission has prepared a bill and fiscal note and local impact analysis of HB 16.
OHB 69, permitting counties, townships, and combinations of counties, townships, and municipalities to adopt regulations establishing transfer of development rights (TDR) programs within their zoning codes or by joint agreement, was introduced by Rep. Larry Wolpert (R) on February 27, 2007. Conservation of historical and archaeological sites is one of the purposes for which TDR programs can be established. Transfer of development rights refers to a method for protecting land by transferring the "rights to develop" from one area and giving them to another.
HB 69 was assigned to the Local and Municipal Government & Urban Revitalization (LMGUR) Committee, which Rep. Wolpert chaired. Rep. Wolpert was term limited in 2008; he will not return to the Ohio House of Representatives. The LMGUR Committee did not hold hearings on the bill, and its future is in doubt. The Legislative Services Commission has prepared a bill and fiscal note and local impact analysis.
OHB 639, establishing procedures for the Ohio Civil Rights Commission to extend state recognition to Native American tribes, groups, and special interest groups, and to extend such recognition to the Shawnee Nation United Remnant Band, was introduced by Rep. Fred Strahorn (D) on November 19, 2008. Under the bill, a state recognized tribe is authorized to conduct business in Ohio for which it is authorized to do so under Federal law. However, state recognition could not be used for purposes of the Federal Indian Gaming Regulatory Act, which permits Indian tribes to operate certain types of gaming (gambling) establishments.
HB 639 was assigned to the State Government and Elections (SGE) Committee. Rep. Strahorn was term limited in 2008; he will not return to the Ohio House of Representatives. The SGE Committee has not held hearings on the bill, and its future is in doubt. The Legislative Services Commission has not prepared a bill and fiscal and local impact analysis of the bill.
Comments Regarding Proposed Archaeological Investigations at the Mid-Ohio Development Corporation’s (MODC) Proposed Ohio Department of Development’s Job Ready Site (JRS) Project at the Abandoned Wehrle Stove Company Site in Newark, Licking County, Ohio. At the invitation of the OHPO and the Newark Earthworks Center, on July 29, 2008, the OAC submitted comments to both parties regarding the need for archaeological investigations at the abandoned Wehrle Stove Company, formerly the site of a cemetery associated with the Newark Earthworks. We advised that it was only through careful and controlled scientific archaeological investigations that any remnants of the site could and should be identified, and advised the confirmation of the production of land mines and other munitions at the plant during WW II. If confirmed, we recommended that prior to undertaking archaeological investigations, a munitions and explosives of concern (MEC) survey be conducted over the area where archaeological investigations would be conducted to clear the site of munitions and explosives, and to delineate areas where archaeological investigations should be prohibited because of the presence of MEC. Furthermore, we advised that before archaeological investigations commenced, the archaeologists should be apprised of the location of all hazardous and toxic wastes present at the project site so appropriate precautions could be taken. We recommended that the archaeologists implement a health and safety plan for the environmental conditions present at the site, and that they demonstrate sufficient liability insurance and implementation of a health and safety plan including trenching and excavation, heavy equipment, personal protective equipment, and related programs that meet the relevant Occupational Safety and Health Administration’s standards. Subsequently, the MODC did not apply for the JRS grant, and the project appears to be on hold.
Comments to the Ohio Power Siting Board (OPSB) Regarding Archaeological Sites and Wind Energy Projects. In September, comments were submitted to the OPSB regarding draft rules for siting wind farms. We found the rules simplistic, vague, and extremely difficult to work with, and recommended revision in consultation with the Ohio Historic Preservation Office. We commented that the draft rules were “significantly flawed and displays unfamiliarity with established, workable processes and procedures for considering the effects of government funded, permitted, licensed, and otherwise authorized projects on archaeological resources, and the work of the Ohio Historic Preservation Office.” The OPSB replied that it had a “long-standing working relationship with the State Historic Preservation Office as it pertains to cultural resources…and that the [OAC’s] concerns are addressed without making the proposed modifications to the rules.” The entire text of the OAC’s comments can be found at http://dis.puc.state.oh.us/TiffToPDf/A1001001A08I25B34457G52488.pdf.
American Battlefield Protection Program (ABPP) grants to Study Revolutionary War and War of 1812 Sites in Ohio. In 2008, the National Parks Service’s ABPP made grants to three organizations to study Revolutionary War and War of 1812 Sites in Ohio. The Ohio Historic Preservation Office received a grant to update survey and inventory data to their 2002 study of nine sites in Ohio (Fort Laurens  in Tuscarawas County, Pickaway Settlements Battle site  in Clark County, Lichtenau Massacre site  in Coshocton County, Gnadenhutten Massacre site  in Tuscarawas County, Colonel Crawford Battle [Crawford’s Defeat] site  in Wyandot County, Fort Meigs 1, Fort Meigs 2, and Dudley’s Defeat site  in Lucas County, and the Battle of Lake Erie  in Ottawa County). The study will be undertaken by a consultant. The Great Lakes Historical Society will conduct an underwater archaeological survey to help define the boundaries of the site and assess the integrity of any extant cultural resources related to the battle. The Civil War Preservation Trust will provide GIS mapping identifying unprotected parcels of land pertaining to Ohio’s only Civil War battlefield, the Battle of Buffington Island in Meigs County, and Morgan’s Surrender site in Salineville in Columbiana Coutny, and revise priorities for protecting the parcels. For further information see http://www.nps.gov/history/hps/abpp/index.htm.
State budget cuts are crippling the Ohio Historical Society (OHS). OHS recently announced that it faces a $1.2 million budget deficit as a result of the Governor’s most recent cut of 5.75%, which follows a 4.75% reduction in October of 2008. Since the state of Ohio faces a projected $7.3 billion-plus budget shortfall in FY 2009-2010 (July 1, 2009 – June 30, 2011), further reductions are likely. To address the budget crisis, OHS will close its historic sites and museums, including the Ohio Historical Center and the Ohio Historic Preservation Office, and furlough staff the week of March 28 - April 3, 2009. OHS is also increasing the number of historic sites that will be managed by local partners. Currently, half (29) of OHS’ 58 sites are operated through partnership agreements with local organizations or governments, and OHS is looking to add up to 10 more sites to this mix before June 30, 2009. These partnerships are increasingly important because of the combination of long-term state underinvestment in OHS and the recent budget crisis.
OAC Members Appointed to the Ohio Historic Site Preservation Advisory Board (OHSPAB). Recently, OAC Secretary Andrew Schneider and member Shaune Skinner were appointed to three-year terms on the 17-member OHSPAB by Governor Strickland. The OAC’s Board of Directors encouraged their nominations. OHSPAB’s duties include suggesting legislation to the Ohio Historical Society so it can fulfill its mission to locate, designate, restore, preserve, and maintain state historical and archaeological sites and artifacts; encourage the designation of suitable sites on the National Register of Historic Places and under related Federal programs; and provide general advice, guidance, and professional recommendations to the State Historic Preservation Officer in conducting a statewide survey of historic and archaeological sites, preparing a state historic preservation plan, and carrying out other duties and responsibilities of the State Historic Preservation Office. A majority of OHSPAB members must professionals in the disciplines of history, archaeology, architectural history, architecture, and historical architecture. Public members also sit on OHSPAB.
OAC’s Legislative Priorities. In the spring of 2008, the OAC’s Government Affairs Committee developed, and the Board of Directors approved, a set of legislative priorities. On several occasions in 2002, the OAC testified before the Ohio House Select Committee Studying the Effectiveness of Ohio’s Historical Programs and Partnerships. In this testimony, available on the OAC’s website, we asked the state legislature to address a number of issues. It did not do so. Some of these issues are reiterated in our priorities.
Enforcement and Clarification of Ohio Revised Code (ORC) Section 149.53: Impacts of Public Improvements on Archaeological and Historic Sites
ORC 149.53 states, in relevant part, “All departments, agencies, units, instrumentalities, and political subdivisions of the state shall cooperate with the Ohio historical society and the Ohio historic site preservation advisory board in the preservation of archaeological and historic sites and in recovery of scientific information from such sites and for such purposes shall, whenever practical, by contract or otherwise provide for archaeological and historic survey and salvage work during the planning phases, before work on a public improvement begins or at other appropriate times; and require that contractors performing work on public improvements cooperate with archaeological and historic survey and salvage efforts and notify the society or the board about archaeological discoveries.” As we testified to in 2002, state government and political subdivisions of the state generally ignore this law, and the Ohio Historical Society and the Governor-appointed Ohio Historic Site Preservation Advisory Board currently lack the ability to enforce it. No rules implementing the law exist. Enforcement of ORC 149.53 and clarification of how state government and political subdivisions of the state are to comply with it are needed.
Enactment of a State Environmental Protection Act (SEPA) or a State Historic Preservation Act
The OAC supports enactment of a SEPA, as proposed by the Ohio Environmental Council, or state historic preservation legislation. This would require the State and its political subdivisions to make reasonable and good faith efforts to identify important archaeological sites (as defined below) on private terrestrial and publicly owned terrestrial and submerged land in Ohio. An exception would be federal property. These efforts include measures to assess, avoid, minimize, and/or mitigate project impacts on such sites before project funds, licenses, and permits are approved by the state. These efforts would only occur on land that the State Historic Preservation Office determines:
1. Is a high or medium probability area for containing important archaeological sites; or
2. Contains archaeological sites recorded in the Ohio Archaeological Inventory; or
3. Contains important archaeological sites, defined as those sites that meet the criteria for evaluation for the National Register of Historic Places, the State Registry of Archaeological Landmarks, or locally designated landmarks. State law pertaining to public improvements affecting archaeological sites is contained in ORC 149.53, but this law is ignored and not being enforced (see above). State actions, including the funding, licensing, and permitting of projects proposed by local governments and the private sector likely to affect important archaeological sites, should require these efforts. This process would be similar to that of Section 106 of the National Historic Preservation Act.
Revision of ORC 1514: Industrial Minerals Mining Permits
Industrial minerals mining has a substantial impact on important archaeological sites because such mining, particularly quarry and open pit mining, is often located in the most extremely archaeologically sensitive environments: river valleys and stream terraces, and certain uplands. Presently, state law regulating industrial minerals mining does not allow the Ohio Department of Natural Resources (ODNR) to consider impacts on archaeological sites. ODNR officials have indicated that they will not consider such impacts until the General Assembly authorizes them to do so. A SEPA or State Historic Preservation Act, as defined above, would address this situation. The OAC asks the state legislature to revise ORC 1514 to require an applicant for an industrial mining permit to make a reasonable and good faith effort to identify such sites and assess, avoid, minimize, and/or mitigate the proposed mining’s impacts on such sites as a condition of the ODNR’s permit approval process.
Protection of Unmarked Human Burial Grounds and Abandoned Cemeteries
In 2002, the Ohio House Select Committee on Ohio’s Historical Programs and Partnerships recommended that the Ohio Historical Society develop a program to protect unmarked human burial grounds and abandoned cemeteries. The Ohio Historical Society, after holding a meeting of interested parties, recommended that such a program, though badly needed, should be the responsibility of a state agency, not a private, non-profit organization such as itself. The state of Ohio is one of the few states that do not provide adequate protection for unmarked human burial grounds and abandoned cemeteries. Preservation of abandoned cemeteries is also a legislative priority of the Ohio Townships Association. The OAC supports the enactment of legislation requiring the State Historic Preservation Office to develop and implement an unmarked human burial ground protection program, including creating an inventory of human burial places, and funding for its operation. We also support legislation protecting abandoned cemeteries.
Revise ORC 149.54 Clarifying When a Permit is Needed to Conduct Archaeological Investigations on State Land and Land Owned by a Political Subdivision of the State, and Increasing the Penalty for Archaeological Investigations on Such Land Without a Permit from the Ohio Historical Society from a Misdemeanor to a Felony.
In 1983, Amended House Bill 373 exempted state agencies and political subdivisions of the state from complying with 149.54 and the rule (Ohio Administrative Code 149-1-02) implementing it. This allows state agencies and political subdivisions of the state to authorize anyone to conduct archaeological investigations on public land without considering the person’s qualifications or requiring that the investigations be conducted according to industry standards and guidelines for such investigations adopted by the Ohio Historic Preservation Office. Furthermore, most state agencies and political subdivisions of the state do not have personnel qualified to determine when such permission should and should not be granted. The result is damage to and destruction of irreplaceable, publicly owned, archaeological sites and the scientifically important information they contain. The law needs to be clarified indicating when a permit is necessary and when it is not, who may issue such permits, etc. The penalty for violating 149.54 is a second-degree misdemeanor. Similar violations in most other states and on Federal lands are felonies. The state should increase the penalty for violations of ORC 149.54 to a felony in order to serve as stronger deterrent to looting archaeological sites on state land.
To the editor, The Columbus Dispatch
The Ohio Archaeological Council (OAC) is a nonprofit organization whose mission is to promote the advancement of archaeology in Ohio through research, education, and consultation with government agencies and the public. We have followed with interest the recent series of letters (11/12 and 11/21) and a Dispatch editorial (11/22) regarding Native American human remains and associated funerary objects in the care of the Ohio Historical Society (OHS). The Native American Alliance of Ohio considers the scientific study of these materials to be "racist" and calls on OHS to "return the human remains and grave goods to Ohio Native Americans for respectful reburial." We do not believe such an action is appropriate or legal.
The OAC supports the intent of the Native American Graves Protection and Repatriation Act (NAGPRA); to allow lineal descendants and culturally related federally recognized Indian tribes to claim the remains of their ancestors for culturally appropriate treatment, which may or may not include reburial. NAGPRA permits the repatriation of human remains and associated funerary objects when claimants establish a cultural relationship between themselves and the remains. Regulations concerning culturally unaffiliated human remains, those that cannot be linked to a family or modern Indian tribe, have not been finalized by the U.S. Department of the Interior. Human remains that are thousands of years old are not considered Native American for the purposes of NAGPRA, and are excluded from consideration for repatriation under this law. This makes sense. For example, studies of DNA from 2,000-year-old human remains recovered from a mound in Ross County and preserved by the OHS found biological relationships to Indian tribes as culturally diverse and geographically separated as the Apache in the southwest, the Micmac in the far northeast, the Yakama in the far northwest, and the Ojibwe of the Great Lakes region. To whom then would these remains be returned? Human remains of such antiquity are part of a broader human story and should be retained for scientific study and educational purposes.
The Dispatch stated that Rachel Tooker of the OHS said that when the regulations dealing with culturally unaffiliated remains are approved "the remains can be repatriated relatively quickly." If this accurately represents the position of the OHS, then the OAC is deeply concerned. We are even more concerned at the Dispatch's position that if the federal guidelines are not approved within the next year, OHS should begin working with people who may not be culturally affiliated with the human remains and associated funerary objects "to work out a plan for responsibly returning the remains."
Human remains are invaluable sources of information on biological, medical, and cultural aspects of human history. The funerary objects accompanying some ancient burials provide our only window onto the highest artistic achievements of these cultures. We trust that OHS will take its obligation to history seriously and protect the legacy of all Ohioans from an ill-considered and overly hasty repatriation that would result in the destruction of valuable scientific and cultural information. Returning human remains to people with no demonstrable connection to them would be irresponsible; and to do so in the absence of the federal regulations that are being written to deal with such cases could be illegal.
Lynn Simonelli, President
The Ohio Archaeological Council
J. (James M.) Heilman received the OAC Board's award for "Significant contributions to the advancement of Archaeology in Ohio." Heilman served as Curator of Anthropology for the Dayton Museum of Natural History (later the Boonshoft Museum of Discovery) from 1969 until 2000. In that capacity, he made significant contributions to archaeological research, preservation, public education, and the development of cooperative relationships with Native Americans. He directed archaeological investigations at sites in Darke, Greene, Miami, Montgomery, and Preble counties. His most notable work focused on the Incinerator Site, later to become famous as SunWatch Village . Between 1969 and 1992, he directed the investigation of SunWatch, which, due largely to his efforts, was preserved by the City of Dayton and ultimately recognized as a National Historic Landmark in 1990. Heilman was recognized in 1985 with the Public Education and Awareness Award from the Ohio Historic Preservation Office and the Ohio Historical Society. In 1989, the Ohio Arts Council / Ohio Humanities Council selected his work at SunWatch as their most exemplary project.
Bradley Lepper received the OAC's Public Awareness Award in recognition of significant contributions to the advancement of Archaeology in Ohio. The OAC Board cited Dr. Lepper's efforts toward the nomination of several Ohio Hopewell sites to the list of World Heritage sites as well as his regular column on Ohio Archaeology in the Columbus Dispatch as significantly increasing the public's awareness of Archaeology and Ohio's prehistoric heritage.
Dancey, W.S., and M.F. Seeman
2005 Rethinking the Cole Complex: a Post-Hopewellian Archaeological Unit in Central Ohio. In Woodland Period Systematics in the Middle Ohio Valley, R. Mainfort and D. Applegate, eds., pp. 134-149. University of Alabama Press, Tuscaloosa.
Lovejoy, C.O., R.S. Meindl, T.R. Pryzbeck, T.S. Barton, D. Kotting, and K.G. Heiple.
1977 The Palaeodemography of the Libben Site, Ottawa County, Ohio. Science 198:291-293.
Lovejoy, C.O., K.F. Russell, and M.L. Harrison.
1990 Long Bone Growth Velocity in the Libben Population. American Journal of Human Biology 2:533-541.
1987 Curt Prüfer: German Diplomat from the Kaiser to Hitler. Kent State University Press, Kent.
1963 The McConnell Site: A Late Palaeo-Indian Workshop in Coshocton County, Ohio. Cleveland Museum of Natural History, Scientific Publications, n.s. 2(2):1-51.
1966 The Mud Valley Site: A Late Palaeo-Indian Locality in Holmes County, Ohio. Ohio Journal of Science 66(1):68-75.
The Hopewell Cult. Scientific American 211(6):90-102.
1965 The McGraw Site: A Study in Hopewellian Dynamics. Cleveland Museum of Natural History, Scientific Publications, n.s. 4(1):1-144.
1967 Chesser Cave: A Late Woodland phase in the Hocking Valley, Ohio. In Studies in Ohio Archaeology, O. Prufer and D. McKenzie, eds., pp. 1-63. The Press of Western Reserve University, Cleveland.
1998 Response to David Brose on a Review of his South Park Village Report and Related Matters: Some Suggested Corrections. North American Archaeologist 19(3):197-199.
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Palaeo-Indians of Ohio. The Ohio Historical Society, Columbus.
Prufer, O.H., and D.H. McKenzie
1966 Peters Cave: Two Woodland Occupations in Ross County, Ohio. Ohio Journal of Science 66(3):233-253.
Prufer, O.H., and O.C. Shane, III
Blain Village and the Fort Ancient Tradition in Ohio. Kent State University Press, Kent.
Prufer, O.H., and N.L. Wright
1970 The Welling Site (33Co-2): A Fluted Point Workshop in Coshocton County, Ohio. Ohio Archaeologist 20(4):259-268.
Prufer, O.H., S.E. Pedde, and R.S. Meindl, eds.
2001 Archaic Transitions in Ohio & Kentucky Prehistory. Kent State University Press, Kent.
1971 Review of Blain Village. American Anthropologist 73(6):1402-1404.
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2006 Caves and Culture: 10000 Years of Ohio History. Kent State University Press, Kent.
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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