https://religionsmn.carleton.edu/files/original/22bee1ecf0b29e83d7196848b13b7809.pdf 66059776c6b1da00419830c1640b4d67 PDF Text Text NATIONAL REGISTER BULLETIN Technical information on the the National Register of Historic Places: survey, evaluation, registration, and preservation of cultural resources U.S. Department of the Interior National Park Service Cultural Resources National Register, History and Education Guidelines for Evaluating and Documenting Traditional Cultural Properties �The mission of the Department of the Interior is to protect and provide access to our Nation's natural and cultural heritage and honor our trust responsibilities to tribes. This material is partially based upon work conducted under a cooperative agreement with the National Conference of State Historic Preservation Officers and the U.S. Department of the Interior. Cover photographs: Many traditional cultural properties are used for practical purposes by those who value them. This sedge preserve in northern California, for example, is tended and harvested by Porno Indian basketmakers as a vital source of material for making their world famous baskets. The preserve was established at Lake Sonoma by the U.S. Army Corps of Engineers. (Richard Lerner) This bedrock mortar in central California plays an essential role in processing Black Oak acorns. (Theodoratus Cultural Research) �NATIONAL REGISTER BULLETIN GUIDELINES FOR EVALUATING AND DOCUMENTING TRADITIONAL CULTURAL PROPERTIES BY PATRICIA L. PARKER Cultural Anthropologist and Archeologist, American Indian Liaison Office National Park Service and THOMAS F. KING Senior Archeologist and Director of the Office of Program Review, Advisory Council on Historic Preservation (formerly) Consultant, Archeology and Historic Preservation (currently) U.S. DEPARTMENT OF THE INTERIOR NATIONAL PARK SERVICE NATIONAL REGISTER, HISTORY AND EDUCATION NATIONAL REGISTER OF HISTORIC PLACES 1990; REVISED 1992; 1998 �TABLE OF CONTENTS I. Introduction 1 II. Traditional Cultural Values in Preservation Planning 5 III. Identifying Traditional Cultural Properties Establishing the level of effort Contacting traditional communities and groups Fieldwork Reconciling Sources 6 6 7 8 9 IV. Determining Eligibility Step-by-Step Step One: Ensure that the entity under consideration is a property Step Two: Consider the property's integrity Step Three: Evaluate the property with reference to the National Register Criteria Step Four: Determine whether any of the National Register criteria considerations (36 CFR 60.4) make the property ineligible 11 11 12 12 V. Documenting Traditional Cultural Properties General Considerations Completing Registration Forms 19 19 22 VI. Conclusion 23 VII. Recommended Bibliography and Sources 24 VIII. Appendix I, A Definition of "Culture" 26 IX. Appendix II, Professional Qualifications: Ethnography 27 X. Appendix III, List of National Register Bulletins 28 14 �I. INTRODUCTION WHAT ARE TRADITIONAL CULTURAL PROPERTIES? The National Register of Historic Places contains a wide range of historic property types, reflecting the diversity of the nation's history and culture. Buildings, structures, and sites; groups of buildings, structures or sites forming historic districts; landscapes; and individual objects are all included in the Register if they meet the criteria specified in the National Register's Criteria for Evaluation (36 CFR 60.4). Such properties reflect many kinds of significance in architecture, history, archeology, engineering, and culture. There are many definitions of the word "culture," but in the National Register programs the word is understood to mean the traditions, beliefs, practices, lifeways, arts, crafts, and social institutions of any community, be it an Indian tribe, a local ethnic group, or the people of the nation as a whole.1 One kind of cultural significance a property may possess, and that may make it eligible for inclusion in the Register, is traditional cultural signifi- cance. "Traditional" in this context refers to those beliefs, customs, and practices of a living community of people that have been passed down through the generations, usually orally or through practice. The traditional cultural significance of a historic property, then, is significance derived from the role the property plays in a community's historically rooted beliefs, customs, and practices. Examples of properties possessing such significance include: • a location associated with the traditional beliefs of a Native American group about its origins, its cultural history, or the nature of the world; • a rural community whose organization, buildings and structures, or patterns of land use reflect the cultural traditions valued by its longterm residents; • an urban neighborhood that is the traditional home of a particular cultural group, and that reflects its beliefs and practices; • a location where Native American religious practitioners have historically gone, and are known or thought to gotoday, to perform ceremonial activities in accordance with traditional cultural rules of practice; and • a location where a community has traditionally carried out economic, artistic, or other cultural practices important in maintaining its historic identity. A traditional cultural property, then, can be defined generally as one that is eligible for inclusion in the National Register because of its association with cultural practices or beliefs of a living community that (a) are rooted in that community's history, and (b) are important in maintaining the continuing cultural identity of the community. Various kinds of traditional cultural properties will be discussed, illustrated, and related specifically to the National Register Criteria later in this bulletin. 1 For a detailed definition, see Appendix I. Numerous African Americans left the South to migrate to the Midwest. The A.M.E. Church (on left) and District No. 1 School remain in Nicodemus Historic District in Nicodemus, Kansas, which was declared a National Historic Landmark by the Secretary of the Interior in 1976. (Clayton B. Fraserfor the Historic American Buildings Survey) 1 �PURPOSE OF THIS BULLETIN Traditional cultural values are often central to the way a community or group defines itself, and maintaining such values is often vital to maintaining the group's sense of identity and self respect. Properties to which traditional cultural value is ascribed often take on this kind of vital significance, so that any damage to or infringement upon them is perceived to be deeply offensive to, and even destructive of, the group that values them. As a result, it is extremely important that traditional cultural properties be considered carefully in planning; hence it is important that such properties, when they are eligible for inclusion in the National Register, be nominated to the Register or otherwise identified in inventories for planning purposes. Traditional cultural properties are often hard to recognize. A traditional ceremonial location may look like merely a mountaintop, a lake, or a stretch of river; a culturally important neighborhood may look like any other aggregation of houses, and an area where culturally important economic or.artistic activities have been carried out may look like any other building, field of grass, or piece of forest in the area. As a result, such places may not necessarily come to light through the conduct of archeological, historical, or architectural surveys. The existence and significance of such locations often can be ascertained only through interviews with knowledgeable users of the area, or through other forms of ethnographic research. The subtlety with which the significance of such locations may be expressed makes it easy to ignore them; on the other hand it makes it difficult to distinguish between properties having real significance and those whose putative significance is spurious. As a result, clear guidelines for evaluation of such properties are needed. In the 1980 amendments to the National Historic Preservation Act, the Secretary of the Interior, with the American Folklife Center, was directed to study means of: preserving and conserving the intangible elements of our cultural heritage such as arts, skills, folklife, and folkways... The German Village Historic District in Columbus, Ohio, reflects the ethnic heritage of 19th century German immigrants. The neighborhood includes many simple vernacular brick cottages with gable roofs. (Christopher Cline) and to recommend ways to: This bulletin has been developed as one aspect of the Service's response to the Cultural Conservation report and preserve, conserve/and encourage the Secretary's direction. It is inthe continuation of the diverse traditional prehistoric, historic, ethnic, tended to be an aid in determining and folk cultural traditions that un- whether properties thought or alleged derlie and are a living expression of to have traditional cultural signifiour American heritage. (NHPA 502; cance are eligible for inclusion in the National Register. It is meant to assist 16 U.S.C. 470a note) Federal agencies, State Historic PresThe report that was prepared in re- ervation Officers (SHPOs), Certified sponse to 502, entitled Cultural Conser- Local Governments, Indian Tribes, vation, was submitted to the President and other historic preservation practiand Congress on June 1,1983, by the tioners who need to evaluate such Secretary of the Interior. The report properties when nominating them for recommended in general that tradiinclusion in the National Register or tional cultural resources, both those when considering their eligibility for that are associated with historic prop- the Register as part of the review proerties and those without specific prop- cess prescribed by the Advisory erty referents, be more systematically Council on Historic Preservation unaddressed in implementation of the der 106 of the National Historic PresNational Historic Preservation Act ervation Act. It is designed to suppleand other historic preservation aument other National Register guidthorities. In transmitting the report, ance, particularly How to Apply the Nathe Secretary directed the National tional Register Criteria for Evaluation Park Service to take several actions to and Guidelines for Completing National implement its recommendations. Register of Historic Places Forms. It Among other actions, the Service was should be used in conjunction with directed to prepare guidelines to asthese two Bulletins and other applisist in the documentation of intangcable guidance available from the Naible cultural resources, to coordinate tional Register, when applying the the incorporation of provisions for the National Register Criteria and preparconsideration of such resources into ing documentation to support nomiDepartmental planning documents nations or determinations that a and administrative manuals, and to given property is or is not eligible for encourage the identification and inclusion in the Register. documentation of such resources by This Bulletin is also responsive to States and Federal agencies. the American Indian Religious Free- �dom Act (AIRFA) of 1978, which requires the National Park Service, like other Federal agencies, to evaluate its policies and procedures with the aim of protecting the religious freedoms of Native Americans (Pub. L. 95341 2). Examination of the policies and procedures of the National Register suggests that while they are in no way intended to be so interpreted, they can be interpreted by Federal agencies and others in a manner that excludes historic properties of religious significance to Native Americans from eligibility for inclusion in the National Register. This in turn may exclude such properties from the protections afforded by 106, which may result in their destruction, infringing upon the rights of Native Americans to use them in the free exercise of their religions. To minimize the likelihood of such misinterpretation, this Bulletin gives special attention to properties of traditional cultural significance to Native American groups, and to discussing the place of religion in the attribution of such significance. The fact that this Bulletin gives special emphasis to Native American properties should not be taken to imply that only Native Americans ascribe traditional cultural value to historic properties, or that such ascription is common only to ethnic minority groups in general. Americans of every ethnic origin have properties to which they ascribe traditional cultural value, and if such properties meet the National Register criteria, they can and should be nominated for inclusion in the Register. This Bulletin does not address cultural resources that are purely "intangible"—i.e. those that have no property referents—except by exclusion. The Service is committed to ensuring that such resources are fully considered in planning and decision making by Federal agencies and others. Historic properties represent only some aspects of culture, and many other aspects, not necessarily reflected in properties as such, may be of vital importance in maintaining the integrity of a social group. However, the National Register is not the appropriate vehicle for recognizing cultural values that are purely intangible, nor is there legal authority to address them under 106 unless they are somehow related to a historic property. The National Register lists, and 106 requires review of effects on, tangible cultural resources—that is, historic properties. However, the attributes that give such properties significance, such as their association with historical events, often are intangible in nature. Such attributes cannot be ignored in evaluating and managing historic properties; properties and their intangible attributes of significance must be considered together. This Bulletin is meant to encourage its users to address the intangible cultural values that may make a property historic, and to do so in an evenhanded way that reflects solid research and not ethnocentric bias. Finally, no one should regard this Bulletin as the only appropriate source of guidance on its subject, or interpret it rigidly. Although traditional cultural properties have been listed and recognized as eligible for inclusion in the National Register since the Register's inception, it is only in recent years that organized attention has been given to them. This Bulletin represents the best guidance the Register can provide as of the late 1980s, and the examples listed in the bibliography include the best known at this time.2 It is to be expected that approaches to such properties will continue to evolve. This Bulletin also is meant to supplement, not substitute for, more specific guidelines, such as those used by the National Park Service with respect to units of the National Park System and those used by some other agencies, States, local governments, or Indian tribes with respect to their own lands and programs. 2 It is notable that most of these examples are unpublished manuscripts. The literature pertaining to the identification and evaluation of traditional cultural properties, to say nothing of their treatment, remains a thin one. These sandbars in the Rio Grande River are eligible for inclusion in the National Register because they have been used for generations by the people ofSandia Pueblo for rituals involving immersion in the river's waters. (Thomas F. King) �ETHNOGRAPHY, ETHNOHISTORY, ETHNOCENTRISM Three words beginning with "ethno" will be used repeatedly in this Bulletin, and may not be familiar to all readers. All three are derived from the Greek ethnos, meaning "nation;" and are widely used in the study of anthropology and related disciplines. Ethnography is the descriptive and analytic study of the culture of particular groups or communities. An ethnographer seeks to understand a community through interviews with its members and often through living in and observing it (a practice referred to as "participant observation"). Ethnohistory is the study of historical data, including but not necessarily limited to, documentary data pertaining to a group or community, using an ethnographic perspective. Ethnographic and ethnohistorical research are usually carried out by specialists in cultural anthropology, and by specialists in folklore and folklife, sociology, history, archeology and related disciplines with appropriate technical training.3 Ethnocentrism means viewing the world and the people in it only from the point of view of one's own culture and being unable to sympathize with the feelings, attitudes, and beliefs of someone who is a member of a different culture. It is particularly important to understand, and seek to avoid, ethnocentrism in the evaluation of traditional cultural properties. For ex3 For a detailed discussion of the qualifications that a practitioner of ethnography or ethnohistory should possess, see Appendix II. ample, Euroamerican society tends to emphasize "objective" observation of the physical world as the basis for making statements about that world. However, it may not be possible to use such observations as the major basis for evaluating a traditional cultural property. For example, there may be nothing observable to the outsider about a place regarded as sacred by a Native American group. Similarly, such a group's belief that its ancestors emerged from the earth at a specific location at the beginning of time may contradict Euroamerican science's belief that the group's ancestors migrated to North America from Siberia. These facts in no way diminish the significance of the locations in question in the eyes of those who value them; indeed they are irrelevant to their significance. It would be ethnocentric in the extreme to say that "whatever the Native American group says about this place, I can't see anything here so it is not significant" or "since I know these people's ancestors came from Siberia, the place where they think they emerged from the earth is of no significance." It is vital to evaluate properties thought to have traditional cultural significance from the standpoint of those who may ascribe such significance to them, whatever one's own perception of them, based on one's own cultural values, may be. This is not to say that a group's assertions about the significance of a place should not be questioned or subjected to critical analysis, but they should not be rejected based on the premise that the beliefs they reflect are inferior to one's own. EVALUATION, CONSIDERATION, AND PROTECTION One more point that should be remembered in evaluating traditional cultural properties—as in evaluating any other kind of properties—is that establishing that a property is eligible for inclusion in the National Register does not necessarily mean that the property must be protected from disturbance or damage. Establishing that a property is eligible means that it must be considered in planning Federal, federally assisted, and federally licensed undertakings, but it does not mean that such an undertaking cannot be allowed to damage or destroy it. Consultation must occur in accordance with the regulations of the Advisory Council (36 CFR Part 800) to identify, and if feasible adopt, measures to protect it, but if in the final analysis the public interest demands that the property be sacrificed to the needs of the project, there is nothing in the National Historic Preservation Act that prohibits this. This principle is especially important to recognize with respect to traditional cultural properties, because such properties may be valued by a relatively small segment of a community that, on the whole, favors a project that will damage or destroy it. The fact that the community as a whole may be willing to dispense with the property in order to achieve the goals of the project does not mean that the property is not significant, but the fact that it is significant does not mean that it cannot be disturbed, or that the project must be foregone. �II. TRADITIONAL CULTURAL VALUES IN PRESERVATION PLANNING Traditional cultural properties, and the beliefs and institutions that give them significance, should be systematically addressed in programs of preservation planning and in the historic preservation components of land use plans. One very practical reason for this is to simplify the identification and evaluation of traditional cultural properties that may be threatened by construction and land use projects. Identifying and evaluating such properties can require detailed and extensive consultation, interview programs, and ethnographic fieldwork as discussed below. Having to conduct such activities may add considerably to the time and expense of compliance with 106, the National Environment Policy Act, and other authorities. Such costs can be reduced significantly, however, by early, proactive planning that identifies significant properties or areas likely to contain significant properties before specific projects are planned that may affect them, identifies parties likely to ascribe cultural value to such properties, and establishes routine systems for consultation with such parties. The Secretary of the Interior's Guidelines for Preservation Planning empha- size the need for organized public participation in context development (48 FR 44717). The Advisory Council on Historic Preservation's Guidelines The Secretary of the Interior's Standards for Preservation Planning provide for Public Participation in Historic Pres- for the establishment of "historic contexts'7 as a basic step in any preservation planning process be it planning for the comprehensive survey of a community or planning a construction project. A historic context is an organization of available information about, among other things, the cultural history of the area to be investigated, that identifies "the broad patterns of development in an area that may be represented by historic properties" (48 FR 44717). The traditions and traditional lifeways of a planning area may represent such "broad patterns," so information about them should be used as a basis for historic context development. ervation Review (ACHP 1988) provide detailed recommendations regarding such participation. Based on these standards and guidelines, groups that may ascribe traditional cultural values to an area's historic properties should be contacted and asked to assist in organizing information on the area. Historic contexts should be considered that reflect the history and culture of such groups as the groups themselves understand them, as well as their history and culture as defined by Euroamerican scholarship, and processes for consultation with such groups should be integrated into routine planning and project review procedures. �III. IDENTIFYING TRADITIONAL CULTURAL PROPERTIES Some traditional cultural properties are well known to the residents of an area. The San Francisco Peaks in Arizona, for example, are extensively documented and widely recognized as places of extreme cultural importance to the Hopi, Navajo, and other American Indian people of the Southwest, and it requires little study to recognize that Honolulu's Chinatown is a place of cultural importance to the city's Asian community. Most traditional cultural properties, however, must be identified through systematic study, just as most other kinds of historic properties must be identified. This section of the Bulletin will discuss some factors to consider in identifying traditional cultural properties.4 ESTABLISHING THE LEVEL OF EFFORT Any comprehensive effort to identify historic properties in an area, be the area a community, a rural area, or the area that may be affected by a construction or land-use project, should include a reasonable effort to identify traditional cultural properties. What constitutes a "reasonable" effort depends in part on the likelihood that such properties may be present. The likelihood that such properties may be present can be reliably assessed only on the basis of background Honolulu's Chinatown reflects the cultural values and traditions of its inhabitants not knowledge of the area's history, ethonly in its architectural details but also in its organization of space and the activities nography, and contemporary society that go on there. (Ramona K. Mullahey) developed through preservation planning. As a general although not in4 For general guidelines for identification see the Secretary of the Interior's Standards and Guidelines for Identification (48 FR 44720-23), Guidelines for Local Surveys: A Basis for Preservation Planning (National Register of Historic Places bulletin) and Identification in Historic Preservation Review: a Decisionmaking Guide (ACHP/DOI1988). �variable rule, however, rural areas are more likely than urban areas to contain properties of traditional cultural importance to American Indian or other native American communities, while urban areas are more likely to contain properties of significance to ethnic and other traditional neighborhoods. Where identification is conducted as part of planning for a construction or land-use project, the appropriate level of effort depends in part on whether the project under consideration is the type of project that could affect traditional cultural properties. For example, as a rule the rehabilitation of historic buildings may have relatively little potential for effect on such properties. However, if a rehabilitation project may result in displacement of residents,"gentrification" of a neighborhood, or other sociocultural impacts, the possibility that the buildings to be rehabilitated, or the neighborhood in which they exist, may be ascribed traditional cultural value by their residents or others should be considered. Similarly, most day-to-day management activities of a land managing agency may have little potential for effect on traditional cultural properties, but if the management activity involves an area or a kind of resource that has high significance to a traditional group—for example, timber harvesting in an area where an Indian tribe's religious practitioners may continue to carry out traditional ceremonies—the potential for effect will be high. These general rules of thumb aside, the way to determine what constitutes a reasonable effort to identify traditional cultural properties is to consult those who may ascribe cultural significance to locations within the study area. The need for community participation in planning identification, as in other forms of preservation planning, cannot be over-emphasized. CONTACTING TRADITIONAL COMMUNITIES AND GROUPS An early step in any effort to identify historic properties is to consult with groups and individuals who have special knowledge about and in- terests in the history and culture of the area to be studied. In the case of traditional cultural properties, this means those individuals and groups who may ascribe traditional cultural significance to locations within the study area, and those who may have knowledge of such individuals and groups. Ideally, early planning will have identified these individuals and groups, and established how to consult with them. As a rule, however, the following steps are recommended: BACKGROUND RESEARCH An important first step in identifying such individuals and groups is to conduct background research into what is already recorded about the area's history, ethnography, sociology, and folklife. Published and unpublished source material on the historic and contemporary composition of the area's social and cultural groups should be consulted; such source material can often be found in the anthropology, sociology, or folklife libraries of local universities or other academic institutions. Professional and nonprofessional students of the area's social and cultural groups should also be consulted—for example, professional and avocational anthropologists and folklorists who have studied the area. The SHPO and any other official agency or organization that concerns itself with matters of traditional culture—for example, a State Folklorist or a State Native American Commission—should be contacted for recommendations about sources of information and about groups and individuals to consult. MAKING CONTACT Having reviewed available background data, the next step is to contact knowledgeable groups and individuals directly, particularly those groups that are native to the area or have resided there for a long time. Some such groups have official repre- Federal agencies and others have found a variety of ways to contact knowledgeable parties in order to identify and evaluate traditional cultural properties. Generally speaking, the detail and complexity of the methods employed depend on the nature and complexity of the properties under consideration and the effects the agency's management or other activities may have on them. For example: • The Black Hills National Forest designated a culturally sensitive engineer to work with local Indian tribes in establishing procedures by which the tribes could review Forest Service projects that might affect traditional cultural properties; • The Air Force sponsored a conference of local traditional cultural authorities to review plans for deployment of an intercontinental missile system in Wyoming, resulting in guidelines to ensure that effects on traditional cultural properties would be minimized. • The New Mexico Power Authority employed a professional cultural anthropologist to consult with Native American groups within the area to be affected by the Four Corners Power Project. • The Ventura County (California) Flood Control Agency consulted with local Native American groups designated by the State Native American Heritage Commission to determine how to handle human remains to be exhumed from a cemetery that had to be relocated to make way for a flood control project. • The Utah State Historic Preservation Officer entered into an agreement with the American Folklife Center to develop a comprehensive overview of the tangible and intangible historic resources of Grouse Creek, a traditional Mormon cowboy community. • The Forest Service contracted for a full-scale ethnographic study to determine the significance of the Helkau Historic District on California's Six Rivers National Forest. �sentatives—the tribal council of an Indian tribe, for example, or an urban neighborhood council. In other cases, leadership may be less officially defined, and establishing contact may be more complicated. The assistance of ethnographers, sociologists, folklorists, and others who may have conducted research in the area or otherwise worked with its social groups may be necessary in such cases, in order to design ways of contacting and consulting such groups in ways that are both effective and consistent with their systems of leadership and communication. It should be clearly recognized that expertise in traditional cultural values may not be found, or not found solely, among contemporary community leaders. In some cases, in fact, the current political leadership of a community or neighborhood may be hostile to or embarrassed about traditional matters. As a result, it may be necessary to seek out knowledgeable parties outside the community's official political structure. It is of course best to do this with the full knowledge and cooperation of the community's contemporary leaders; in most cases it is appropriate to ask such leaders to identify members of the community who are knowledgeable about traditional cultural matters, and use these parties as an initial network of consultants on the group's traditional values. If there is serious hostility between the group's contemporary leadership and its traditional experts, however, such cooperation may not be extended, and efforts to consult with traditional authorities may be actively opposed. Where this occurs, and it is necessary to proceed with the identification and evaluation of properties—for example, where such identification and evaluation are undertaken in connection with review of an undertaking under 106— careful negotiation and mediation may be necessary to overcome opposition and establish mutually acceptable ground rules for consultation. Again, the assistance of anthropologists or others with training and experience in work with the community, or with similar communities, may be necessary. FIELDWORK Fieldwork to identify properties of traditional cultural significance involves consultation with knowledge8 The Helkau Historic District, in the Six Rivers National Forest of California, is eligible for inclusion in the National Register because of its association with significant cultural practices of the Tolowa, Yorok, Karuk, and Hoopa Indian tribes of the area, who have used the district for generations to make medicine and communicate with spirits. (Theodoratus Cultural Research) able parties, coupled with field inspection and recordation of locations identified as significant by such parties. It is often appropriate and efficient to combine such fieldwork with surveys to identify other kinds of historic properties, for example archeological sites and properties of architectural significance. If combined fieldwork is conducted, however, the professional standards appropriate to each kind of fieldwork should be adhered to, and appropriate expertise in each relevant discipline should be represented on the study team. The kinds of expertise typically needed for a detailed ethnographic study of traditional cultural properties are outlined in Appendix II. Applicable research standards can be found in Systematic Fieldwork, Volume 2: Ethnographic Analysis and Data Management. (Werner and Schoepfle 1986) CULTURALLY SENSITIVE CONSULTATION Since knowledge of traditional cultural values may not be shared readily with outsiders, knowledgeable parties should be consulted in cultural contexts that are familiar and reasonable to them. It is important to understand the role that the information being solicited may play in the culture of those from whom it is being solicited, and the kinds of rules that may surround its transmittal. In some societies traditional information is regarded as powerful, even dangerous. It is often believed that such information should be transmitted only under particular circumstances or to particular kinds of people. In some cases information is regarded as a valued commodity for which payment is in order, in other cases offering payment may be offensive. Sometimes information may be regarded as a gift, whose acceptance obligates the receiver to reciprocate in some way, in some cases by carrying out the activity to which the information pertains. It may not always, or even often, be possible to arrange for information to be sought in precisely the way those being consulted might prefer, but when it is not, the interviewer should clearly understand that to some extent he or she is asking those interviewed to violate their cultural norms. The interviewer should try to keep such violations to a minimum, and should be patient with the reluctance that those interviewed may feel toward sharing information under conditions that are not fully appropriate from their point of view. Culturally sensitive consultation may require the use of languages other than English, the conduct of �community meetings in ways consistent with local traditional practice, and the conduct of studies by trained ethnographers, ethnohistorians, sociologists, or folklorists with the kinds of expertise outlined in Appendix II. Particularly where large projects or large land areas are involved, or where it is likely that particularly sensitive resources may be at issue, formal ethnographic studies should be carried out, by or under the supervision of a professionally qualified cultural anthropologist. FIELD INSPECTION AND RECORDATION It is usually important to take knowledgeable consultants into the field to inspect properties that they identify as significant. In some cases such properties may not be discernible as such to anyone but a knowledgeable member of the group that ascribes significance to them; in such cases it may be impossible even to find the relevant properties, or locate them accurately, without the aid of such parties. Even where a property is readily discernible as such to the outside observer, visiting the property may help a consultant recall information about it that he or she is unlikely to recall during interviews at a remote location, thus making for a richer and more complete record. Where the property in question has religious significance or supernatural connotations, it is particularly important to ensure that any visit is carried out in accordance with appropriate modes of behavior. In some cases, ritual purification is necessary before a property can be approached, or spirits must be propitiated along the way. Some groups forbid visits to such locations by menstruating women or by people of inappropriate ages. The taking of photographs or the use of electronic recording equipment may not be appropriate. Appropriate ways to approach the property should be discussed with knowledgeable consultants before undertaking a field visit. To the extent compatible with the cultural norms of the group involved, traditional cultural properties should be recorded on National Register of Historic Places forms or their equivalent.5 Where items normally included in a National Register nomination or request for a determination of eligibility cannot be included (for ex- ample, if it is culturally inappropriate to photograph the property), the reasons for not including the item should be explained. To the extent possible in the property's cultural context, other aspects of the documentation (for example, verbal descriptions of the property) should be enhanced to make up for the items not included. If making the location of a property known to the public would be culturally inappropriate, or compromise the integrity of the property or associated cultural values (for example, by encouraging tourists to intrude upon the conduct of traditional practices), the "Not for Publication" box on the National Register form should be checked; this indicates that the reproduction of locational information is prohibited, and that other information contained in the nomination will not be reproduced without the permission of the nominating authority. In the case of a request for a determination of eligibility in which a National Register form is not used, the fact that the information is not for publication should be clearly speci- fied in the documentation, so that the National Register can apply the same controls to this information as it would to restricted information in a nomination.6 RECONCILING SOURCES Sometimes an apparent conflict exists between documentary data on traditional cultural properties and the testimony of contemporary consultants. The most common kind of conflict occurs when ethnographic and ethnohistorical documents do not identify a given place as playing an important role in the tradition and culture of a group, while contemporary members of the group say the property does have such a role. More rarely, documentary sources may indicate that a property does have cultural significance while contemporary sources say it does not. In some cases, too, contemporary sources may disagree about the significance of a property. Much of the significance of traditional cultural properties can be learned only from testimony of the traditional people who value them, like this old man being interviewed in Truk. (Micronesia Institute) 5 For general instructions on the completion of National Register documentation, see How to Complete the National Register of Historic Places Form. 6 Section 304 of the National Historic Preservation Act provides the legal authority to withhold National Register information from the public when release might "create a substantial risk of harm, theft, or destruction." For detailed guidelines concerning restricting access to information see the National Register bulletin entitled, Guidelines for Restricting Information About Historic and Prehistoric Resources. �Where available documents fail to identify a property as culturally significant, but contemporary sources identify it as such, several points should be considered. (a)Ethnographic and ethnohistorical research has not been conducted uniformly in all parts of the nation; some areas are better documented than others simply because they have been the focus of more research. (b)Ethnographic and ethnohistorical documents reflect the research interests of those who prepared them; the fact that one does not identify a property as culturally important may reflect only the fact that the individual who prepared the report had research interests that did not require the identification of such properties. (c) Some kinds of traditional cultural properties are regarded by those who value them as the loci of supernatural or other power, or as having other attributes that make people reluctant to talk about them. Such properties are not likely to be recorded unless someone makes a very deliberate effort to do so, or unless those who value them have a special reason for revealing the information—for example, a perception that the property is in some kind of danger. Particularly because properties of traditional cultural significance are often kept secret, it is not uncommon for them to be "discovered" only when something threatens them—for example, when a change in land-use is proposed in their vicinity. The sudden revelation by representatives of a cultural group which may also have other economic or political interests in the proposed change can lead quickly to charges that the cultural significance of a property has been invented only to obstruct or otherwise influence those planning the change. This may be true, and the possibility that traditional cultural significance is attributed to a property only to advance other, unrelated interests should be carefully considered. However, it also may be that until the change was proposed, there simply was no reason for those who value the property to reveal its existence or the significance they ascribe to it. Where ethnographic, ethnohistorial, historical, or other sources identify a property as having cultural significance, but contemporary sources say that it lacks such significance, the interests of the contemporary sources should be carefully considered. Individuals who have economic interests in the potential development of an area may be strongly motivated to deny its cultural significance. More subtly, individuals who regard traditional practices and beliefs as backward and contrary to the 7 For excellent examples of studies designed in whole or in part to identify and evaluate traditional cultural properties based on both documentary sources and the testimony of consultants, see Bean and Vane 1978; Carroll 1983; Johnston and Budy 1983; Stoffle and Dobyns 1982,1983; Theodoratus 1979. 10 best contemporary interests of the group that once ascribed significance to a property may feel justified in saying that such significance has been lost, or was never ascribed to the property. On the other hand, of course, it may be that the documentary sources are wrong, or that the significance ascribed to the property when the documents were prepared has since been lost. Similar consideration must be taken into account in attempting to reconcile conflicting contemporary sources. Where one individual or group asserts that a property has traditional cultural significance, and another asserts that it does not or where there is disagreement about the nature or extent of a property's significance, the motives and values of the parties, and the cultural constraints operating on each, must be carefully analyzed. In general, the only reasonably reliable way to resolve conflict among sources is to review a wide enough range of documentary data, and to interview a wide enough range of authorities to minimize the likelihood either of inadvertent bias or of being deliberately misled. Authorities consulted in most cases should include both knowledgeable parties within the group that may attribute cultural value to a property and appropriate specialists in ethnography, sociology, history, and other relevant disciplines.7 �IV. DETERMINING ELIGIBILITY: STEP BY STEP Whether a property is known in advance or found during an identification effort, it must be evaluated with reference to the National Register Criteria for Evaluation (36 CFR Part 60) in order to determine whether it is eligible for inclusion in the Register. This section discusses the process of evaluation as a series of sequential steps. In real life of course, these steps are often collapsed into one another or taken together. STEP ONE: ENSURE THAT THE ENTITY UNDER CONSIDERATION IS A PROPERTY Because the cultural practices or beliefs that give a traditional cultural property its significance are typically still observed in some form at the time the property is evaluated, it is sometimes perceived that the intangible practices or beliefs themselves, not the property, constitute the subject of evaluation. There is naturally a dynamic relationship between tangible and intangible traditional cultural resources, and the beliefs or practices associated with a traditional cultural property are of central importance in defining its significance. However, it should be clearly recognized at the outset that the National Register does not include intangible resources themselves. The entity evaluated must be a tangible property—that is, a district, site, building, structure, or object.8 The relationship between the property and the beliefs or practices associated with it should be carefully considered, however, since it is the beliefs and practices that may give the property its significance and make it eligible for inclusion in the National Register. Construction by human beings is a necessary attribute of buildings and structures, but districts, sites, and objects do not have to be the products of, or contain, the work of human beings in order to be classified as properties. For example, the National Register defines a "site" as "the location of a significant event, a prehistoric or historic occupation or activity, or a building or structure, whether standing, ruined, or vanished, where the location itself possesses historic, cultural, or archeological value regardless of the value of any existing structure."9 Thus a property may be defined as a "site" as long as it was the location of a significant event or activity, regardless of whether the event or activity left any evidence of its occurrence. A culturally significant natural landscape may be classified as a site, as may the specific location where significant traditional events, activities, or cultural observances have taken place. A natural object such as a tree or a rock outcrop may be an eligible object if it is associated with a significant tradition or use. A concentration, linkage, or continuity of such sites or objects, or of structures comprising a culturally significant entity, may be classified as a district. In considering the eligibility of a property that contains no observable evidence of human activity, however, the documentary or oral evidence for the association of the property with traditional events, activities or observances should be carefully weighed and assessed. The National Register discourages the nomination of natural features without sound documentation of their historical or cultural significance. STEP TWO: CONSIDER THE PROPERTY'S INTEGRITY In order to be eligible for inclusion in the Register, a property must have "integrity of location, design, setting, materials, workmanship, feeling, and association" (36 CFR Part 60). In the case of a traditional cultural property, there are two fundamental questions to ask about integrity. First, does the property have an integral relationship to traditional cultural practices or beliefs; and second, is the condition of the property such that the relevant relationships survive? INTEGRITY OF RELATIONSHIP Assessing the integrity of the relationship between a property and the beliefs or practices that may give it significance involves developing some understanding about how the group that holds the beliefs or carries out the practices is likely to view the property. If the property is known or likely to be regarded by a traditional cultural group as important in the retention or transmittal of a belief, or to the performance of a practice, the property can be taken to have an integral relationship with the belief or practice, and vice-versa. For example, imagine two groups living along the shores of a lake. Each group practices a form of baptism to mark an individual's acceptance into the group. Both carry out baptism in the lake. One group, however, holds that baptism is appropriate in any body of water that is available; the lake happens to be available, so it is used, but another lake, a river or creek, or a swimming pool would be just as acceptable. The second group regards baptism in this particular lake as essential to its acceptance of an individual as a member. Clearly the lake is integrally related to the second group's practice, but not to that of the first. 8 See How to Apply the National Register Cri- teria for Evaluation for discussion of property types. ) See How to Complete the National Register Form. 11 �INTEGRITY OF CONDITION Like any other kind of historic property, a property that once had traditional cultural significance can lose such significance through physical alteration of its location, setting, design, or materials. For example, an urban neighborhood whose structures, objects, and spaces reflect the historically rooted values of a traditional social group may lose its significance if these aspects of the neighborhood are substantially altered. In some cases a traditional cultural property can also lose its significance through alteration of its setting or environment. For example, a location used by an American Indian group for traditional spirit questing is unlikely to retain its significance for this purpose if it has come to be surrounded by housing tracts or shopping malls. A property may retain its traditional cultural significance even though it has been substantially modified, however. Cultural values are dynamic, and can sometimes accommodate a good deal of change. For example, the Karuk Indians of northwestern California continue to carry on world renewal rites, ancient ceremonies featuring elaborate dances, songs, and other ritual activities, along a stretch of the Klamath River that is now the site of a highway, a Forest Service Ranger Station, a number of residences, and a timber cutting operation. Specific locations important in aspects of the ceremony remain intact, and accommodation has been reached between the Karuk and other users of the land. The State Department of Transportation has even erected "Ritual Crossing" signs at locations where the Karuk religious practitioners cross the highway, and built shallow depressions into the roadway which are filled with sand in advance of the ceremony, so the feet of the practitioners need not be profaned by contact with man-made macadam. As this example shows, the integrity of a possible traditional cultural property must be considered with reference to the views of traditional practitioners; if its integrity has not been lost in their eyes, it probably has sufficient integrity to justify further evaluation. Some kinds of traditional cultural significance also may be retained regardless of how the surroundings of a 12 Cannonball Island, off Cape Alava on the coast of Washington State, is a traditional cultural property of importance to the Makah Indian people. It was used in the past, and is still used today, as a navigation marker for Makah fisherman, who established locations at sea by triangulation from this and other landmarks. It also was a lookout point for seal and whale hunters and for war parties, a burial site, and a kennel for dogs raised for their fur. (Makah Cultural and Research Center Archives) property may be changed. For example, the First African Baptist Church Cemetery in Philadelphia, rediscovered during archeological work in advance of highway construction in 1985, has considerable cultural significance for the congregation that traces descent from those interred in the Cemetery, and for Philadelphia's African American community in general, even though its graves had been buried under fill and modern construction for many decades. It should also be recalled that even if a property has lost integrity as a possible traditional cultural property, it may retain integrity with reference to some other aspect of significance. For example, a property whose cultural significance has been lost through disturbance may still retain archeological deposits of significance for their information content, and a neighborhood whose traditional residents no longer ascribe significance to it may contain buildings of architectural importance. STEP THREE: EVALUATE THE PROPERTY WITH REFERENCE TO THE NATIONAL REGISTER CRITERIA Assuming the entity to be evaluated is a property, and that it retains integrity, it is next necessary to evaluate it against the four basic National Register Criteria set forth in the National Register regulations (36 CFR Part 60). If the property meets one or more of the criteria, it may be eligible; if it does not, it is not eligible.10 CRITERION (A): ASSOCIATION WITH EVENTS THAT HAVE MADE A SIGNIFICANT CONTRIBUTION TO THE BROAD PATTERNS OF OUR HISTORY. The word "our" in this criterion may be taken to refer to the group to which the property may have traditional cultural significance, and the word "history" may be taken to include traditional oral history as well as recorded history. For example, Mt. Tonaachaw on Moen Island in Truk, Federated States of Micronesia, is in the National Register in part because of association with oral traditions about the establishment of Trukese society. "Events" can include specific moments in history of a series of events reflecting a broad pattern or theme. 10 For general guidelines, see How to Apply the National Register Criteria for Evaluation. �For example, the ongoing participation of an ethnic or social group in an area's history, reflected in a neighborhood's buildings, streetscapes, or patterns of social activity, constitutes such a series of events. The association of a property with significant events, and its existence at the time the events took place, must be documented through accepted means of historical research. The means of research normally employed with respect to traditional cultural properties include ethnographic, ethnohistorical, and folklore studies, as well as historical and archeological research. Sometimes, however, the actual time a traditional event took place may be ambiguous; in such cases it may be impossible, and to some extent irrelevant, to demonstrate with certainty that the property in question existed at the time the traditional event occurred. For example, events recounted in the traditions of Native American groups may have occurred in a time before the creation of the world as we know it, or at least before the creation of people. It would be fruitless to try to demonstrate, using the techniques of history and science, that a given location did or did not objectively exist in a time whose own existence cannot be demonstrated scientifically. Such a demonstration is unnecessary for purposes of eligibility determination; as long as the tradition itself is rooted in the history of the group, and associates the property with traditional events, the association can be accepted. a Cahuilla Indian demigod who figures importantly in the tribe's traditions and is said to occupy an obsidian cave high in the canyon. CRITERION (C)(2): REPRESENTATIVE OF THE WORK OF A MASTER. CRITERION (O(l): 11 EMBODIMENT OF THE DISTINCTIVE CHARACTERISTICS OF A TYPE, PERIOD, OR METHOD OF CONSTRUCTION. A property identified in tradition or suggested by scholarship to be the work of a traditional master builder or artisan may be regarded as the work of a master, even though the precise identity of the master may not be known. This subcriterion applies to properties that have been constructed, or contain constructed entities—that is, buildings, structures, or built objects. For example, a neighborhood that has traditionally been occupied by a particular ethnic group may display particular housing styles, gardens, street furniture or ornamentation distinctive of the group. Honolulu's Chinatown, for example, embodies the distinctive cultural values of the City's Asian community in its architecture, landscaping, signage, and ornamentation. CRITERION (C)(3): POSSESSION OF HIGH ARTISTIC VALUES. A property made up of or containing art work valued by a group for traditional cultural reasons, for example a petroglyph or pictograph site venerated by an Indian group, or a building whose decorative elements reflect a local ethnic groups distinctive modes of expression, may be viewed as having high artistic value from the standpoint of the group. 11 Note: Criterion (C) is not subdivided into subcriteria (1), (2), etc. in 36 CFR Part 60.4. The subdivision given here is only for the convenience of the reader. CRITERION (B): ASSOCIATION WITH THE LIVES OF PERSONS SIGNIFICANT IN OUR PAST. Again, the word "our" can be interpreted with reference to the people who are thought to regard the property as traditionally important. The word "persons" can be taken to refer both to persons whose tangible, human existence in the past can be inferred on the basis of historical, ethnographic, or other research, and to "persons" such as gods and demigods who feature in the traditions of a group. For example, Tahquitz Canyon in southern California is included in the National Register in part because of its association with Tahquitz, In Trukese tradition, the Tonaachaw Historic District was the location to which Sowukachaw, founder of the Trukese society, came and established his meetinghouse at the beginning of Trukese history. The mountain, in what is now the Federated States of Micronesia, is a powerful landmark in the traditions of the area. (Lawrence E. Aten) 13 �CRITERION (C)(4): REPRESENTATIVE OF A SIGNIFICANT AND DISTINGUISHABLE ENTITY WHOSE COMPONENTS MAY LACK INDIVIDUAL DISTINCTION. A property may be regarded as representative of a significant and distinguishable entity, even though it lacks individual distinction, if it represents or is an integral part of a larger entity of traditional cultural importance. The larger entity may, and usually does, possess both tangible and intangible components. For example, certain locations along the Russian River in California are highly valued by the Porno Indians, and have been for centuries, as sources of high quality sedge roots needed in the construction of the Pomo's world famous basketry. Although the sedge fields themselves are virtually indistinguishable from the surrounding landscape, and certainly indistinguishable by the untrained observer from other sedge fields that produce lower quality roots, they are representative of, and vital to, the larger entity of Porno basketmaking. Similarly, some deeply venerated landmarks in Micronesia are natural features, such as rock outcrops and groves of trees; these are indistinguishable visually (at least to the outside observer) from other rocks and trees, but they figure importantly in chants embodying traditional sailing directions and lessons about traditional history. As individual objects they lack distinction, but the larger entity of which they are a part—Micronesian navigational and historical tradition—is of prime importance in the area's history. CRITERION (D): HISTORY OF YIELDING, OR POTENTIAL TO YIELD, INFORMATION IMPORTANT IN PREHISTORY OR HISTORY. Properties that have traditional cultural significance often have already yielded, or have the potential to yield, important information through ethnographic, archeological, sociological, folkloric, or other stud14 I Many traditional cultural properties look like very little on the ground. The small protuberance in the center of this photo, known to residents of the Hanford Nuclear Reservation in Washington State as Goose Egg Hill, is regarded by the Yakima Indians of the area as the heart of a goddess who was torn apart by jealous compatriots. They scattered her pieces across the landscape, creating a whole complex of culturally significant landforms. (Thomas F. King) ies. For example, ethnographic and ethnohistorical studies of Kaho'olawe Island in Hawai'i, conducted in order to clarify its eligibility for inclusion in the National Register, have provided important insights into Hawai'ian traditions and culture and into the history of twentieth century efforts to revitalize traditional Hawai'ian culture. Similarly, many traditional American Indian village sites are also archeological sites, whose study can provide important information about the history and prehistory of the group that lived there. Generally speaking, however, a traditional cultural property's history of yielding, or potential to yield, information, if relevant to its significance at all, is secondary to its association with the traditional history and culture of the group that ascribes significance to it. STEP 4: DETERMINE WHETHER ANY OF THE NATIONAL REGISTER CRITERIA CONSIDERATIONS (36 CFR 60.4) MAKE THE PROPERTY INELIGIBLE Generally speaking, a property is not eligible for inclusion in the Register if it represents a class of properties to which one or more of the six "criteria considerations" listed in 36 CFR 60.4 applies, and is not part of a district that is eligible. In applying the criteria considerations, it is important to be sensitive to the cultural values involved, and to avoid ethnocentric bias, as discussed below. CONSIDERATION A: OWNERSHIP BY A RELIGIOUS INSTITUTION OR USE FOR RELIGIOUS PURPOSES. A "religious property," according to National Register guidelines, requires additional justification (for nomination) because of the necessity to avoid any appearance of judgement by government about the merit of any religion or belief."12 Conversely, it is necessary to be careful not to allow a similar judgement to serve as the basis for determining a property to be ineligible for inclusion in the Register. Application of this criteria consideration to traditional cultural properties is fraught with the potential for ethnocentrism and discrimination. In many traditional societies, including most American Indian societies, the clear distinction made by Euroamerican society between religion and the rest of culture does not exist. As a result, properties that have traditional cultural significance are regularly discussed by those who value them in terms that have religious connotations. Inyan Karan Mountain, for example, a National Register property in the Black Hills of South Dakota, is sig- 12 How to Complete the National Register Form. �nificant in part because it is the abode of spirits in the traditions of the Lakota and Cheyenne. Some traditional cultural properties are used for purposes that are definable as religious in Euroamerican terms, and this use is intrinsic to their cultural significance. Kootenai Falls on the Kootenai River in Idaho, part of the National Register-eligible Kootenai Falls Cultural Resource District, has been used for centuries as a vision questing site by the Kootenai tribe. The Helkau Historic District in northern California is a place where traditional religious practitioners go to make medicine and commune with spirits, and Mt. Tonaachaw in Truk is an object of spiritual veneration. The fact that such properties have religious connotations does not automatically make them ineligible for inclusion in the Register. Applying the "religious exclusion" without careful and sympathetic consideration to properties of significance to a traditional cultural group can result in discriminating against the group by effectively denying the legitimacy of its history and culture. The history of a Native American group, as conceived by its indigenous cultural authorities, is likely to reflect a kind of belief in supernatural beings and events that Euroamerican culture categorizes as religious, although the group involved, as is often the case with Native American groups, may not even have a word in its language for "religion." To exclude from the National Register a property of cultural and historical importance to such a group, because its significance tends to be expressed in terms that to the Euroamerican observer appear to be "religious" is ethnocentric in the extreme. In simplest terms, the fact that a property is used for religious purposes by a traditional group, such as seeking supernatural visions, collecting or preparing native medicines, or carrying out ceremonies, or is described by the group in terms that are classified by the outside observer as "religious" should not by itself be taken to make the property ineligible, since these activities may be expressions of traditional cultural beliefs and may be intrinsic to the continuation of traditional cultural practices. Similarly, the fact that the group that owns a property—for example, an American Indian tribe—describes it in religious terms, or constitutes a group of traditional religious practitioners, should not automatically be taken to exclude the property from inclusion in the Register. Criteria Consideration A was included in the Criteria for Evaluation in order to avoid allowing historical significance to be determined on the basis of religious doctrine, not in order to exclude arbitrarily any property having religious associations. National Register guidelines stress the fact that properties can be listed in or determined eligible for the Register for their association with religious history, or with persons significant in religion, if such significance has "scholarly, secular recognition."13 The integral relationship among traditional Native American culture, history, and religion is widely recognized in secular scholarship.14 Studies leading to the nomination of traditional cultural properties to the Register should have among their purposes the application of secular scholarship to the association of particular properties with broad patterns of traditional history and culture. The fact that traditional history and culture may be discussed in religious terms does not make it less historical or less significant to culture, nor does it make properties associated with traditional history and culture ineligible for inclusion in the National Register. CONSIDERATION B: RELOCATED PROPERTIES. Properties that have been moved from their historically important locations are not usually eligible for inclusion in the Register, because "the significance of (historic properties) is embodied in their locations and settings as well as in the (properties) themselves" and because "one basic purpose of the National Register is to encourage the preservation of historic properties as living parts of their communities."15 This consideration is relevant but rarely applied formally to traditional cultural properties; in most cases the property in question is a site or district which cannot be relocated in any event. Even where the property can be relocated, maintaining it on its original site is often crucial to maintaining its importance in traditional culture, and if it has been moved, most traditional authorities would regard its significance as lost. Where a property is intrinsically portable, however, moving it does not 13 How to Complete the National Register Form. 14 For example see U.S. Commission on Civil Rights 1983; Michaelson 1986. 15 How to Complete the National Register Form. The fact that a property has religious connotations does not automatically disqualify it for inclusion in the National Register. This Shaker community in Massachusetts, for example, while religious in orientation, is included in the Register because it expresses the cultural values of the Shakers as a society. (Historic American Buildings Survey) 15 �Some traditional cultural properties may be moveable, like this traditional war canoe still in use in the Republic ifPalua. (Papua Historic Preservation Officer) destroy its significance, provided it remains "located in a historically appropriate setting."16 For example, a traditionally important canoe or other watercraft would continue to be eligible as long as it remained in the water or in an appropriate dry land context (e.g., a boathouse). A property may also retain its significance if it has been moved historically.17 For example, totem poles moved from one Northwest Coast village to another in early times by those who made or used them would not have lost their significance by virtue of the move. In some cases, actual or putative relocation even contributes to the significance of a property. The topmost peak of Mt. Tonaachaw in Truk, for example, is traditionally thought to have been brought from another island; the stories surrounding this magical relocation are parts of the mountains cultural significance. In some cases it may be possible to relocate a traditionally significant property and still retain its significance, provided the property's "historic and present orientation, immediate setting, and general environment" are carefully considered in planning and executing the move.18 At Lake Sonoma in California, for example, the U.S. Army Corps of Engineers relocated a number of boulders contain16 ing petroglyphs having artistic, archeological, and traditional cultural significance to protect them from inundation. The work was done in consultation with members of the local Porno Indian tribe, and apparently did not destroy the significance of the boulders in the eyes of the tribe.19 CONSIDERATION C: BIRTHPLACES AND GRAVES. Birthplaces and graves of famous persons are not usually eligible for inclusion in the Register as such. If the birthplace or gravesite of a historical person is significant for reasons other than its association with that person, however, the property can of course be eligible.20 Thus in the case of a traditional cultural property, if someone's birth or burial within the property's boundaries was incidental to the larger traditional significance of the property, the fact that it occurred does not make the property ineligible. For example, in South Texas, the burial site of Don Pedrito Jaramillo, a well documented folk healer who practiced at the turn of the century, has for more than seventy years been a culturally significant site for the performance of traditional healing rituals by Mexican American folk healers. Here the cultural significance of the site as a center for healing is related to the intangible belief that Don Pedrito's spirit is stronger there than in other places, rather than to the fact of his burial there. On the other hand, it is possible for the birth or burial itself to have been ascribed such cultural importance that its association with the property contributes to its significance. Tahquitz Canyon in southern California, for example, is in a sense the traditional "birthplace" of the entire Cahuilla Indian people. Its status as such does not make it ineligible; on the contrary, it is intrinsic to its eligibility. Mt. Tonaachaw in Truk is according to some traditions the birth- 16 How to Complete the National Register Form. 17 How to Complete the National Register Form. 18 How to Complete the National Register Form. 19 The location to which a property is relocated, and the extent to which it retains its integrity after relocation, must be carefully considered in judging its continued eligibility for inclusion in the National Register. See How to Complete the National Register Form for general guidelines. 20 How to Complete the National Register Form. �place of the culture hero Souwooniiras, whose efforts to organize society among the islands of Truk Lagoon are the stuff of Trukese legend. The association of his birth with the mountain does not make the mountain ineligible; rather, it contributes to its eligibility. CONSIDERATION D: CEMETERIES. Cemeteries are not ordinarily eligible for inclusion in the Register unless they "derive (their) primary significance from graves of persons of transcendent importance, from age, from distinctive design values, or from association with historic events."21 Many traditional cultural properties contain cemeteries, however, whose presence contributes to their significance. Tahquitz Canyon, for example, whose major significance lies in its association with Cahuilla traditional history, contains a number of cemeteries that are the subjects of great concern to the Cahuilla people. The fact that they are present does not render the Canyon ineligible; on the contrary, as reflections of the long historical association between the Cahuilla and the Canyon, the cemeteries reflect and contribute to the Canyon's significance. Thus the fact that a traditional cultural property is or contains a cemetery should not automatically be taken to render it ineligible. struction in no way diminishes the island's eligibility. CONSIDERATION F: COMMEMORATION. Like other properties, those constructed to commemorate a traditional event or person cannot be found eligible for inclusion in the Register based on association with that event or person alone.23 The mere fact that commemoration is involved in the use or design of a property should not be taken to make the property ineligible, however. For example, traditional meetinghouses in the Republic of Palau, included in the National Register, are typically ornamented with "story boards" commemorating traditional events; these derive their design from traditional Palauan aesthetic values, and thus contribute to the cultural significance of the structures. They connect the structures with the traditional history of the islands, and in no way diminish their cultural, ethnographic, and architectural significance. CONSIDERATION G: SIGNIFICANCE ACHIEVED WITHIN THE PAST 50 YEARS. Properties that have achieved significance only within the 50 years preceding their evaluation are not eligible for inclusion in the Register unless "sufficient historical perspective exists to determine that the property is exceptionally important and will continue to retain that distinction in the future."24 This is an extremely important criteria consideration with respect to traditional cultural values. A significance ascribed to a property only in the past 50 years cannot be considered traditional. As an example, consider a mountain peak used by an Indian tribe for communication with the supernatural. If the peak has been used by members of the tribe for many years, or if it was used by members of the tribe in prehistory or early history, it may be eligible, but if its use has begun only within the past 50 years, it is probably not eligible. 21 How to Complete the National Register Form. 22 How to Complete the National Register Form. 23 How to Complete the National Register Form. 24 How to Complete the National Register Form. CONSIDERATION E: RECONSTRUCTION. A reconstructed property—that is, a new construction that ostensibly reproduces the exact form and detail of a property or portion of a property that has vanished, as it appeared at a specific period in time—is not normally eligible for inclusion in the Register unless it meets strict criteria.22 The fact that some reconstruction has occurred within the boundaries of a traditional cultural property, however, does not justify regarding the property as ineligible for inclusion in the Register. For example, individuals involved in the revitalization of traditional Hawaiian culture and religion have reconstructed certain religious structures on the island of Kaho'olawe; while the structures themselves might not be eligible for inclusion in the Register, their con- Several hundred persons visit this shrine to Don Pedrito Jaramillo, curandero (faith healer), yearly to seek his healing spirit. (Curtis Tunnell, Texas Historical Commission) 17 �Tahquitz Canyon, in southern California, is included in the National Register because of its association with the traditions of the Cahuilla Indians. The ancestors of the Cahuilla came into this world from a lower one at the beginning of time, and an evil spirit, named Tahquitz, is believed to live in the upper reaches of the canyon. (Thomas F. King) The fact that a property may have gone unused for a lengthy period of time, with use beginning again only recently, does not make the property ineligible for the Register. For example, assume that the Indian tribe referred to above used the mountain peak in prehistory for communication with the supernatural, but was forced to abandon such use when it was confined to a distant reservation, or when its members were converted to Christianity. Assume further that a revitalization of traditional religion has be- 18 gun in the last decade, and as a result the peak is again being used for vision quests similar to those carried out there in prehistory. The fact that the contemporary use of the peak has little continuous time depth does not make the peak ineligible; the peak's association with the traditional activity reflected in its contemporary use is what must be considered in determining eligibility. The length of time a property has been used for some kinds of traditional purposes may be difficult to es- tablish objectively. Many cultural uses may have left little or no physical evidence, and may not have been noted by ethnographers or early visitors to the area. Some such uses are explicitly kept from outsiders by members of the group ascribing significance to the property. Indirect evidence and inference must be weighed carefully, by or in consultation with trained ethnographers, ethnohistorians, and other specialists, and professional judgements made that represent one's best, goodfaith interpretation of the available data. �V. DOCUMENTING TRADITIONAL CULTURAL PROPERTIES GENERAL CONSIDERATIONS Generally speaking, documentation of a traditional cultural property, on a National Register nomination form or in eligibility documentation, should include a presentation of the results of interviews and observations that systematically describe the behavior, beliefs, and knowledge that are germane to understanding the property's cultural significance, and an organized analysis of these results. The data base from which the formal nomination or eligibility determination documents are derived should normally include appropriate tape recordings, photographs, field notes, and primary written records. Obtaining and presenting such documentation can present special challenges, however. First, those who ascribe significance to the property may be reluctant to allow its description to be committed to paper, or to be filed with a public agency that might release information about it to inappropriate people. Second, documentation necessarily involves addressing not only the physical characteristics of the property as perceived by an outside observer, but culturally significant aspects of the property that may be visible or knowable only to those in whose traditions it is significant. Third, boundaries are often difficult to define. Fourth, in part because of the difficulty involved in defining boundaries, it is important to address the setting of the property. THE PROBLEM OF CONFIDENTIALITY Particularly where a property has supernatural connotations in the minds of those who ascribe significance to it, or where it is used in ongoing cultural activities that are not readily shared with outsiders, it may be strongly desired that both the nature and the precise location of the property be kept secret. Such a desire on the part of those who value a property should of course be respected, but it presents considerable problems for the use of National Register data in planning. In simplest terms, one cannot protect a property if one does not know that it is there. The need to reveal information about something that one's cultural system demands be kept secret can present agonizing problems for traditional groups and individuals. It is one reason that information on traditional cultural properties is not readily shared with Federal agencies and others during the planning and environmental review of construction and land use projects. However concerned one may be about the impacts of such a project on a traditional cultural property, it may be extremely difficult to express these concerns to an outsider if one's cultural system provides no acceptable mechanism for doing so. These difficulties are sometimes hard for outsiders to understand, but they should not be underrated. In some cultures it is sincerely believed that sharing information inappropriately with outsiders will lead to death or severe injury to one's family or group. As noted above, information on historic properties, including traditional cultural properties, may be kept confidential under the authority of 304 of the National Historic Preservation Act.25 This may not always be enough to satisfy the concerns of those who value, but fear the results of releasing information on, traditional cultural properties. In some cases these concerns may make it necessary not to nominate such properties formally at all, or not to seek formal determinations of eligibility, but simply to maintain some kind of minimal data in planning files. For example, in planning deployment of the MX missile system in Wyoming, the Air Force became aware that the Lakota Indian tribe in the area had concerns about the project's impacts on traditional cultural properties, but was unwilling to identify and document the precise locations and significance of such properties. To resolve this problem, Air Force representatives met with the tribe's traditional cultural authorities and indicated where they wanted to construct the various facilities required by the deployment; the tribe's authorities indicated which of these locations were likely to present problems, without saying what the nature of the problems might be. The Air Force then designed the project to minimize use of such areas. In a narrow sense, obviously, the Air Force did not go through the process of evaluation recommended by this Bulletin; no specific properties were identified or evaluated to determine their eligibility for inclusion in the National Register. In a broader sense, however, the Air Force's approach represents excellent practice in the identification and treatment of traditional cultural prop25 For details regarding maintaining confidentiality, see Guidelines for Restricting Information About Historic and Prehistoric Resources. 19 �erties. The Air Force consulted carefully and respectfully with those who ascribed traditional cultural significance to properties in the area, and sought to accommodate their concerns. The tribe responded favorably to this approach, and did not take undue advantage of it. Presumably, had the tribe expressed concern about such expansive or strategically located areas as to suggest that it was more interested in impeding the deployment than in protecting its valued properties the Air Force would have had to use a different approach. In summary: the need that often exists to keep the location and nature of a traditional cultural property secret can present intractable problems. These must be recognized and dealt with flexibly, with an understanding of the fact that the management problems they may present to Federal agencies or State Historic Preservation Officers may pale into insignificance when compared with the wrenching cultural conflicts they may present to those who value the properties. DOCUMENTING VISIBLE AND NON-VISIBLE CHARACTERISTICS Documentation of a traditional cultural property should present not only its contemporary physical appearance and, if known, its historical appearance, but also the way it is described in the relevant traditional belief or practice. For example, one of the important cultural locations on Mt. Tonaachaw in Truk is an area called "Neepisaram," which physically looks like nothing but a grassy slope near the top of the mountain. In tradition, however, it is seen as the ear of "kuus," a metaphorical octopus identified with the mountain, and as the home of "Saraw," a warrior spirit/barracuda. Obviously a nomination of "Neepisaram" would be incomplete and largely irrelevant to its significance if it identified it only as a grassy slope near the top of the mountain. PERIOD OF SIGNIFICANCE Describing the period of significance for a traditional cultural property can be an intellectual challenge, particularly where the traditions of a Native American or Micronesian group are involved. In such cases 20 there are often two different kinds of "periods." One of these is the period in which, in tradition, the property gained its significance—the period during which the Cahuilla people emerged from the lower world through Tahquitz Canyon, or the period when civilization came to Truk through the magical arrival of the culture-bearer Sowukachaw on Mt. Tonaachaw. Such periods often have no fixed referent in time as it is ordinarily construed by Euroamerican scholarship.26 To the Cahuilla, their ancestors simply emerged from the lower world at the beginning of human life on earth, whenever that may have been. A Trukese traditional authority will typically say simply that Sowukachaw came to Truk "noomw noomw noomw" (long, long ago). It is usually fruitless, and of little or no relevance to the eligibility of the property involved for inclusion in the National Register, to try to relate this sort of traditional time to time as measured by Euroamerican history. Traditional "periods" should be defined in their own terms. If a traditional group says a property was created at the dawn of time, this should be reported in the nomination or eligibility documentation; for purposes of National Register eligibility there is no need to try to establish whether, according to Euroamerican scholarship or radiocarbon age determination, it really was created at the dawn of time. The second period that is often relevant to a traditional property is its period of use for traditional purposes. Although direct, physical evidence for such use at particular periods in the past may be rare in the case of properties used by native American groups, it is usually possible to fix a period of use, at least in part, in ordinary chronological time. Establishing the period of use often involves the weighing of indirect evidence and inference. Interviews with traditional cultural authorities are usually the main sources of data, sometimes, supplemented by the study of historical accounts or by archeological investigations. Based on such sources of data it should be possible at least to reach supportable inferences about whether generations before the present one have used a property for traditional 26 Except, perhaps, by some of the more esoteric subfields of cosmology and quantum mechanics. purposes, suggesting that it was used for such purposes more than fifty years ago. It is seldom possible to determined when the traditional use of property began, however—this tends to be lost, as it were, in the mists of antiquity. BOUNDARIES Defining the boundaries of a traditional cultural property can present considerable problems. In the case of the Helkau Historic District in northern California, for example, much of the significance of the property in the eyes of its traditional users is related to the fact that it is quiet, and that is presents extensive views of natural landscape without modern intrusions. These factors are crucial to the medicine making done by traditional religious practitioners in the district. If the boundaries of the district were defined on the basis of these factors, however, the district would take in a substantial portion of California's North coast Range. Practically speaking, the boundaries of a property like the Helkau District must be defined more narrowly, even though this may involve making some rather arbitrary decisions. In the case of the Helkau District, the boundary was finally drawn along topographic lines that included all the locations at which traditional practitioners carry out medicine-making and similar activities, the travel routes between such locations, and the immediate viewshed surround this complex of locations and routes. In defining boundaries, the traditional uses to which the property is put must be carefully considered. For example, where a property is used as the Helkau District is used, for contemplative purposes, viewsheds are important and must be considered in boundary definition. In an urban district significant for its association with a given social group, boundaries might be established where residence or use by the group ends, or where such residence or use is no longer reflected in the architecture or spatial organization of the neighborhood. Changes in boundaries through time should also be taken into consideration. For example, archeological evidence may indicate that a particular cultural practice occurred within particular boundaries in the past, but the practice today may occur within dif- �ferent boundaries perhaps larger, perhaps smaller, perhaps covering different areas. The fact that such changes have taken place, and the reasons they have taken place, if these can be ascertained, should be documented and considered in developing a rationale for the boundaries identified in the nomination or eligibility documentation. DESCRIBING THE SETTING The fact that the boundaries of a traditional cultural property may be drawn more narrowly than they would be if they included all significant viewsheds or lands on which noise might be intrusive on the practices that make the property significant does not mean that visual or auditory intrusions occurring outside the boundaries can be ignored. In the context of eligibility determination or nomination, such intrusions if severe enough may compromise the property's integrity. In planning subsequent to nomination or eligibility determination, the Advisory Council's regulations define "isolation of the property from or alteration of the character of the property's setting" as an adverse effect "when that character contributes to the property's qualification for the National Register" (36 CFR 800.9(b)(2)). Similarly, the Council's regulations define as adverse effects "introduction of visual, audible, or atmospheric elements that are out of character with the property or alter its setting" (36 CFR 800.9 To assist in determining whether a given activity outside the boundaries of a traditional cultural property may constitute an adverse effect, it is vital that the nomination form or eligibility documentation discuss those qualities of a property's visual, auditory, and atmospheric setting that contribute to its significance, including those qualities whose expression extends beyond the boundaries of the property as such into the surrounding environment. Individual structures can have traditional cultural significance, like this Yapese men's house, used by Yapese today in the conduct of deliberations on matters of cultural importance. (Yap State Historic Preservation Office) 21 �COMPLETING REGISTRATION FORMS The following discussion is organized with reference to the National Register of Historic Places Registration Form (NPS 10-900), which must be used in nominating properties to the National Register. To the extent feasible, documentation supporting a request for a determination of eligibility should be organized with reference to, and if possible using, the Registration Form as well. Where the instructions given in the National Register bulletin entitled How to Complete the National Register Registration Form, are sufficient without further discussion, this is indicated. 1. Name of Property The name given a traditional cultural property by its traditional users should be entered as its historic name. Names, inventory reference numbers, and other designations ascribed to the property by others should be entered under other names/ site number. 2. Location Follow How to Complete the National Register Registration Form, but note discussion of the problem of confidentiality above. 22 3. Classification 9. Major Bibliographical References Follow How to Complete the National Register Registration Form. Follow How to Complete the National Register Registration Form. Where oral 4. State/Federal Agency Certification Follow How to Complete the National Register Registration Form. 5. National Park Service Certification To be completed by National Register. 6. Function or Use Follow How to Complete the National Register Registration Form. 7. Description Follow How to Complete the National Register Registration Form as appli- cable. It may be appropriate to address both visible and non-visible aspects of the property here, as discussed under General Considerations above; alternatively, non-visible aspects of the property may be discussed in the statement of significance. sources have been employed, append a list of those consulted and identify the locations where field notes, audio or video tapes, or other records of interviews are housed, unless consultants have required that this information be kept confidential; if this is the case, it should be so indicated in the documentation. 10. Geographical Data Follow How to Complete the National Register Registration Form as appli- cable, but note the discussion of boundaries and setting under General Considerations above. If it is necessary to discuss the setting of the property in detail, this discussion should be appended as accompanying documentation and referenced in this section. 11. Form Prepared By 8. Statement of Significance Follow How to Complete the National Register Registration Form. Follow How to Complete the National Register Registration Form, being care- Accompanying Documentation ful to address significance with sensitivity for the viewpoints of those who ascribe traditional cultural significance to the property. Follow How to Complete the National Register Registration Form, except that if the group that ascribes cultural significance to the property objects to the inclusion of photographs, photographs need not be included. If photographs are not included, provide a statement explaining the reason for their exclusion. �VI. CONCLUSION The National Historic Preservation Act, in its introductory section, establishes that "the historical and cultural foundations of the Nation should be preserved as a living part of our community life in order to give a sense of orientation to the American people"27 (16U.S.C470(b)(2)). The cultural foundations of America's ethnic and social groups, be they Native American or historical immigrant, merit rec7 ognition and preservation, particularly where the properties that represent them can continue to function as living parts of the communities that ascribe cultural value to them. Many such properties have been included in the National Register, and many others have been formally determined eligible for inclusion, or regarded as such for purposes of review under 106 of the Act. Federal agencies, State Historic Preservation Officers, and others who are involved in the inclusion of such properties in the Register, or in their recognition as eligible for inclusion, have raised a number of important questions about how to distinguish between traditional cultural properties that are eligible for inclusion in the Register and those that are not. It is our hope that this Bulletin will help answer such questions. 16U.S.C. 470(b)(2). 23 �VII. RECOMMENDED BIBLIOGRAPHY AND SOURCES FEDERAL STANDARDS AND GUIDELINES Advisory Council on Historic Preservation and National Park Service 1988 Identification of Historic Properties: a Decision making Guide for Managers. ACHP, Washington, DC. Advisory Council on Historic Preservation 1989 Public Participation in Section 106 Review: a Guide for Agency Officials. ACHP, Washington, DC. National Park Service 1983 Archeology and Historic Preservation; Secretary of the Interior's Standards and Guidelines. 48 FR 44716-42. National Park Service 1988 The Section 110 Guidelines: Guidelines for Federal Agency Responsibilities Under Section 110 of the National Historic Preservation Act. 53 FR 4727-46. National Park Service National Register bulletins: How to Apply the National Register Criteria for Evaluation How to Complete the National Register Registration Form Guidelines for Restricting Information About Historic and Prehistoric Resources PROFESSIONAL TECHNICAL MANUALS Bartis, P. 1979 Folklife and Fieldwork. American Folklife Center, Library of Congress, Washington, DC. 24 Langanese, L.L. and Celya Frank 1981 Lives: an Anthropological Approach to Biography. Navato. Chandler and Sharp, Inc. Stoffle, R.W., M.C. Jake, MJ. Evans and P.A. Bunte 1981 Establishing Native American Concerns in Social Impact Assessments. Social Impact Assessment 65/66:3-10, New York. Werner, O. and M. Schoepfle 1987 Systematic Fieldwork, Volumes I and II. Sage Publications. EXAMPLES Bean, Lowell J. and Sylvia B. Vane (eds.) 1978 Persistence and Power: A Study of Native American Peoples in the Sonoran Desert and the Devers-Palo Verde High Voltage Transmission Line. Report prepared by Cultural Systems Research, Inc., Menlo Park, CA for Southern California Edison Company, Rosemead, CA. Bean, Lowell J. and Sylvia B. Vane (eds.) 1979 Native Americans of Western Riverside County, California and the Devers-Mira Loma 500 kV Transmission Line Route (Lamb Canyon-Mira Loma Section). Report prepared by Cultural Systems Research, Inc., Menlo Park, CA, for Southern California Edison Company, Rosemead, CA. Bean, Lowell J. and Sylvia B. Vane (eds.) 1979 Allen-Warner Valley Energy System: Western Transmission System Ethnographic and Historical Resources. Report prepared by Cultural Systems Research Inc., Menlo Park, CA, for Southern California Edison Company, Rosemead, CA. Bean, Lowell J., Sylvia B. Vane, Michael Lerch and Jackson Young 1981 Native American Places in the San Bernardino National Forest, San Bernardino and Riverside Counties, California. Report prepared by Cultural Systems Research, Inc., Menlo Park, CA, for the USDA Forest Service, South Zone Contracting Office, Arcadia, CA (Contract No. 539JA9-0-212). Carroll, Charles H. 1982 An Ethnographic Investigation of Sites and Locations of Cultural Significance to the Navajo People to be Affected by PNM's Four Corners to Ambrosia to Pajarito 500 kV Transmission Project. Public Service Company of New Mexico, Albuquerque. Carroll, Charles H. 1983 The Ute Mountain Ethnographic Study. Public Service Company of New Mexico, Albuquerque. Carter, T. and C. Fleischhauer 1988 The Grouse Creek Cultural Survey: Integrating Folklife and Historic Preservation Field Research. American Folklife Center, Library of Congress, Washington, DC. Goldberg, S.K. and D.J. Theodoratus 1985 Cultural Resources of the Crane Valley Hydroelectric Project Area, Madera County, California. Volume I: Ethnographic, Historic, and Archaeological Overviews and Archaeological Survey. Report prepared by Info tec Research, Sonora CA, and Theodoratus Cultural Research, Fair Oaks, CA, for the Pacific Gas and Electric Company, San Francisco, CA. �Hufford M. 1986 One Space, Many Places: Folklife and Land Use in New Jersey's Pinelands National Reserve. American Folklife Center, Library of Congress, Washington, DC Johnston, James and Elizabeth Budy 1983 Lost Creek Canyon Native American Sites. National Register of Historic Places Eligibility Evaluation. Manuscript. USDA Forest Service, Lassen National Forest, CA. McCarthy, H. C. Blount, E. McKee and D.J. Theodoratus 1985 Ethnographic and Historic Survey for the Big Creek Expansion Project. Report prepared by Theodoratus Cultural Research, Fair Oaks, CA, for Southern California Edison Company, Rosemead, CA. National Park Service 1985 Promised Land on the Solomon: Black Settlement at Nicodemus, Kansas. National Park Service, Rocky Mountain Region. U.S. Government Printing Office, Washington, DC. Stoffle, Richard W. and Henry E Dobyns (eds.) 1982 Nuvagantu. Nevada Indians Comment on the Intermountain Power Project, Utah Section. Intermountain-Adelanto Bipole 1 Transmission Line. Ethnographic (Native American) Resources. Report submitted by the Applied Urban Field School, University of Wisconsin, Parkside, Kenosha, WI, to Applied Conservation Technology, Inc. Stoffle, Richard W. and Henry E. Dobyns (eds.) 1983 PauxantTuvip. Utah Indians Comment on the Intermountain Power Project, Utah Section. Intermountain-Adelanto Bipole I Transmission Line. Ethnographic (Native American) Resources. Report submitted by the Applied Urban Field School, University of Wisconsin, Parkside, Kenosha, WI, to Applied Conservation Technology, Inc. Stoffle, Richard W., et al. 1984 Toyavita Piavuhuru Koroin: Ethnohistory and Native American Religious Concerns in the Fort Carson-Pinon Canyon Maneuver Area. Report submitted by the Applied Urban Field School, University of Wisconsin, Parkside, Kenosha, WI, to the National Park OTHER Service. Association on American Indian Theodoratus Cultural Research, Inc./ Affairs Archaeological Consulting and 1988 American Indian Religious Research Services, Inc. Freedom. Special Supplement to 1984 Cultural Resources Overview of Indian Affairs, Number 116, New the Southern Sierra Nevada: An Ethnographic,Linguistic, Archaeologi- York, NY cal and Historical Study of the Sierra Loomis, O.H. National Forest, Sequoia National 1983 Cultural Conservation: the Forest, and Bakersfield District of the Protection of Cultural Heritage in the Bureau of Land Management. Report United States. American Folklife to the U.S. Department of AgriculCenter, Library of Congress, ture, Forest Service, South Central Washington, DC Contracting Office, Bishop CA. Michaelson, Robert S. Theodoratus, D.J., CM. Blount, 1986 American Indian Religious A.L. Hurtado, P.N. Hawkes and Freedom Litigation: Promise and Peril. M.Ashman Journal of Law and Religion 3:471978 Balsam Meadow Cultural 76. Resource Study: Ethnology and U.S. Commission on Civil Rights History. Report prepared by 1983 Religion in the Constitution: Theodoratus Cultural Research, A Delicate Balance. Clearinghouse Fair Oaks, CA, for Southern Publication No. 80, U.S. CommisCalifornia Edison Company, sion on Civil Rights, Washington, Rosemead, CA. DC Theodoratus, D.J. et al. U.S. Department of the Interior 1979 Cultural Resources of the 1979 American Indian Religious Chimney Rock Section, GasquetFreedom Act: Federal Agencies Task Orleans Road, Six Rivers National Force Report. Washington, DC. Forest. Report prepared by Theodoratus Cultural Research, Walker, Deward E., Jr. Fair Oaks, CA, for USDA Forest 1987 Protection of American Indian Service. Sacred Geography: Toward a Functional Understanding of Indian Theodoratus, D.J. Religion Focusing on a Protective 1982 Ethnographic Cultural Resources Investigation of the Big Creek- Standard of Integrity. Paper preSpringville-Magunden and Big Creek- sented at the Workshop on Sacred Geography, Harvard Center for the Rector-Vestal-Magunden TransmisStudy of World Religions, May 5-6, sion Corridors. Report prepared by Cambridge, MA. Theodoratus Cultural Research, Fair Oaks, CA, for Southern White, D.R.M. (ed.) California Edison Company, 1982 Proceedings of the First National Rosemead, CA. Conference of the Task Force on Cultural Resource Management. Woods CM. Edison Electric Institute, Washing1982 APS/SDG&E Interconnection ton, DC. Project Native American Cultural Resources: Miguel to the Colorado River and Miguel to Mission Tap. Report prepared by Wirth Associates, Inc., San Diego, CA, for San Diego Gas and Electric Company, San Diego, CA. York, Frederick F. 1981 An Ethnographic Survey of the Public Service Company of New Mexico's Proposed New Town Site and Its Environs. Human Environmental Resource Services Corporation, Anthropological Series Number 1, Albuquerque. 25 �VIII. APPENDIX I A DEFINITION OF "CULTURE" Early in this Bulletin a shorthand definition of the word "culture" is used. A longer and somewhat more complex definition is used in the National Park Service's internal cultural resource management guidelines (NPS-28). This definition is consistent 26 with that used in this Bulletin, and may be helpful to those who require further elucidation of the term. The definition reads as follows: "Culture (is) a system of behaviors, values, ideologies, and social arrangements. These features, in addition to tools and expressive elements such as graphic arts, help humans interpret their universe as well as deal with features of their environments, natural and social. Culture is learned, transmitted in a social context, and modifiable. Synonyms for culture include "lifeways," "customs," "traditions," "social practices," and "folkways." The terms "folk culture" and "folklife" might be used to describe aspects of the system that are unwritten, learned without formal instruction, and deal with expressive elements such as dance, song, music and graphic arts as well as storytelling." �IX. APPENDIX II PROFESSIONAL QUALIFICATIONS: ETHNOGRAPHY When seeking assistance in the identification, evaluation, and management of traditional cultural properties, agencies should normally seek out specialists with ethnographic research training, typically including, but not necessarily limited to: I. Language skills: it is usually extremely important to talk in their own language with those who may ascribe value to traditional cultural properties. While ethnographic fieldwork can be done through interpreters, ability in the local language is always preferable. II. Interview skills, for example: • The ability to approach a potential informant in his or her own cultural environment, explain and if necessary defend one's research, conduct an interview and minimize disruption, elicit required information, and disengage from the interview in an appropriate manner so that further interviews are welcome; and • The ability to create and conduct those types of interviews that are appropriate to the study being carried out, ensuring that the questions asked are meaningful to those being interviewed, and that answers are correctly understood through the use of such techniques as translating and back-translating. Types of interviews normally carried out by ethnographers, one or more of which may be appropriate during evaluation and documentation of a traditional cultural property, include: • semi-structured interview on a broad topic; • semi-structured interview on a narrow topic; • structured interview on a well defined specific topic; open ended life history/life cycle interview; and • genealogical interview. III. Skill in making and accurately recording direct observations of human behavior, typically including: • The ability to observe and record individual and group behavior in such a way as to discern meaningful patterns; and • The ability to observe and record the physical environment in which behavior takes place, via photography, mapmaking, and written description. IV. Skill in recording, coding, and retrieving pertinent data derived from analysis of textural materials, archives, direct observation, and interviews. Proficiency in such skills is usually obtained through graduate and post-graduate training and supervised experience in cultural anthropology and related disciplines, such as folklore/folklife. 27 �X. APPENDIX III LIST OF NATIONAL REGISTER BULLETINS The Basics How to Apply National Register Criteria for Evaluation * Guidelines for Completing National Register of Historic Places Form Part A: How to Complete the National Register Form * Part B: How to Complete the National Register Multiple Property Documentation Form Researching a Historic Property * Property Types Guidelines for Evaluating and Documenting Historic Aids to Navigation * Guidelines for Identifying, Evaluating and Registering America's Historic Battlefields Guidelines for Evaluating and Registering Historical Archeological Sites Guidelines for Evaluating and Registering Cemeteries and Burial Places How to Evaluate and Nominate Designed Historic Landscapes * Guidelines for Identifying, Evaluating and Registering Historic Mining Sites How to Apply National Register Criteria to Post Offices * Guidelines for Evaluating and Documenting Properties Associated with Significant Persons Guidelines for Evaluating and Documenting Properties That Have Achieved Significance Within the Last Fifty Years Guidelines for Evaluating and Documenting Rural Historic Landscapes * Guidelines for Evaluating and Documenting Traditional Cultural Properties * Nominating Historic Vessels and Shipwrecks to the National Register of Historic Places Technical Assistance Contribution of Moved Buildings to Historic Districts; Tax Treatments for Moved Buildings; and Use of Nomination Documentation in the Part I Certification Process Defining Boundaries for National Register Properties* Guidelines for Local Surveys: A Basis for Preservation Planning * How to Improve the Quality of Photographs for National Register Nominations National Register Casebook: Examples of Documentation * Using the UTM Grid System to Record Historic Sites The above publications may be obtained by writing to the National Register of Historic Places, National Park Service, 1849 C Street, NW, Washington, D.C. 20240. Publications marked with an asterisk (*) are also available in electronic form on the World Wide Web at www.cr.nps.gov/nr, or send your request by e-mail to nr_reference@nps.gov. 28 � Text A resource consisting primarily of words for reading. Examples include books, letters, dissertations, poems, newspapers, articles, archives of mailing lists. Note that facsimiles or images of texts are still of the genre Text. Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Identifier An unambiguous reference to the resource within a given context NationalRegisterBulletin38.pdf Title A name given to the resource National Register Bulletin 38 Subject The topic of the resource . Description An account of the resource National Register Bulletin 38 or "Guidelines for Evaluating and Documenting Traditional Cultural Properties gives the guidelines for evaluating if a site can be put on the National Register of Historic Places based on its "traditional cultural significance." Creator An entity primarily responsible for making the resource Patricia L. Parker and Thomas F. King Source A related resource from which the described resource is derived National Park Service Publisher An entity responsible for making the resource available U.S. Department of the Interior, National Park Service, National Register Publications Date A point or period of time associated with an event in the lifecycle of the resource 1998 Rights Information about rights held in and over the resource Public Domain Type The nature or genre of the resource Document Language A language of the resource English Format The file format, physical medium, or dimensions of the resource .pdf Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant United States NARF National Register Traditional Cultural Property