"There were more battles, skirmishes, and troop movements [in Tennessee] than in any other state except Virginia. And that, of course, is reflected in the potential number of sites. "
The Bureau of Land Management, responsible for about a third of the nation's real estate, introduced sweeping changes to its preservation process in March of 1997. The archeologists and preservation officers who outlined that process saw it as a logical progression in the agency's preservation program. To many outsiders, it was something else entirely. Once the agreement was signed, its supporters and detractors alike had to choose either to become a part of the new way of operating, or sit back and watch.
The following is an inside look at how the agreement has played out on the ground in the archeologically rich state of Arizona.
My attention first focused on the idea of BLM's new preservation agreement in early 1996, when Arizona SHPO James Garrison returned from a meeting of the National Conference of State Historic Preservation Officers. He explained the proposed streamlining, which would almost eliminate SHPO review, and asked me, as the BLM contact in the state historic preservation office, what I thought. Frankly, I was shocked. As we continued to discuss it, I began to examine my reaction.
The streamlining benefits of programmatic agreements have been recognized for years. An Arizona agreement, executed in 1985, already incorporated many such provisions; for example, reducing SHPO and Advisory Council on Historic Preservation involvement in case-by-case review of BLM undertakings.
So what was shocking?
Was it the sheer size of the affected area? BLM manages roughly 264 million acres, including about 14 million in Arizona, about 20 percent of the state. The pressure to exploit these lands is sometimes intense.
Was it the many important properties? In Arizona, these include two Clovis sites, Murray Springs and the Lehner Mammoth Kill Site (whose deterioration was the subject of an article in Science magazine) as well as everything from geoglyphs to mining towns, CCC camps to pueblos, rock shelters to petroglyph clusters.
Or was it just the usual, all-too-human resistance to CHANGE?
The answer was probably all of the above, and then some. The main issue seemed to be that the agreement largely eliminated the checks and balances at the foundation of the federal preservation program. In response to this concern, shared by many SHPOs, the final agreement included protocols tailored to each state's situation. The agreement, finalized after months of discussion, required BLM to train its managers, sign protocols with individual states, and other tasks.
The Arizona protocol, the first in the nation, does identify those undertakings that require case-by-case review by the SHPO; however, the heart of the document is the working relationship it outlines.
Under the protocol, BLM and the state preservation office meet at least annually to review work plans and discuss issues. We also meet as needed to discuss undertakings and talk about strategies; in several instances, these meetings have focused on undertakings that the SHPO will not review formally. In addition, BLM must summarize its preservation program in an annual report. I recently reviewed the first of these.
Has the new and improved process worked?
The report included all of the information requested by the SHPO and more (three pages of accomplishments and two pages of issues and needs). For perhaps the first time, this office has at least a nodding acquaintance with the full range of BLM's activities, which include educating the public as well as documenting and protecting sites.
The SHPO has not received a single expression of concern about the new process. On several occasions, individuals called about specific projects or properties, but in each case, when I relayed their concerns, I found that BLM was already addressing them.
For my part, I have tried to take advantage of opportunities to participate in BLM processes and projects, and to develop a better understanding of the spectrum of concerns that each BLM field office faces.
What have I learned?
First, BLM lands, their uses, and users vary tremendously. There are competing pressures to develop lands surrounding rapidly expanding metropolitan areas or to set them aside for recreation or conservation (urban sprawl vs. open space preservation). In other areas, mining reigns supreme. In far western Arizona, recreational use is intensive. Every winter over 175,000 people temporarily inhabit BLM lands in the vicinity of Quartzsite, Arizona, mostly in recreational vehicles. This may have a cumulative and indirect impact exceeding that of many construction projects; the management issues are truly staggering. Add to this mix hunting, hiking, off-roading, and ranching, and it's easy to see that serving all the customers of these lands inevitably leads to a balancing act that, for the most part, is not entirely satisfying to any of them. This sometimes produces intense conflict.
Second, largely through the required meetings with field managers and their staffs, we have developed a more personal and productive working relationship. As was hoped, we focus on places and issues, rather than process. We've begun to share our aspirations and work together to achieve them.
What does this mean?
The net result is that we have taken our eyes off the paper and are talking about the issues. Obviously, we could have made most of these changes at any time, without having to spell them out. The point is, we didn't. We did, and do, hold meetings and make field visits with other agencies; we have good working relations with most of our federal agency partners. But the agreement and protocol explicitly define these activities as the focus of BLM-SHPO interaction. As a result, the relationship itself has taken on much greater importance. All aspects of it have changed, I think, for the better.
What about BLM?
Clearly, the role of the SHPO in its program has changed. Participation is proactive; review is minimal.
What about the program itself?
BLM continues to consider the effects of its undertakings on historic properties, as it should. But one of the goals of the agreement, equal in importance to revamping the process mandated by section 106 of the National Historic Preservation Act, is moving preservation away from an environmental compliance task and towards its proper place as envisioned by the authors of section 110 (see sidebar). Has this happened? The annual report indicates some progress; however, a change in worldview must be reinforced if it is to become permanent.
Where do we go from here?
All is not rosy. The new process does not fit all situations. For example, most multiagency projects still require SHPO review according to 36 CFR part 800 (which triggers Advisory Council involvement). Projects funded by state grants require SHPO review under state law. To the dismay of most BLM offices in Arizona, the need for this kind of review has been higher than expected.
The state preservation office is increasingly concerned that, as BLM and other agencies work to accommodate multiple uses of public lands, the balance between preservation and recreation may be weighted too heavily in favor of the latter, with too few measures to protect historic properties. For example, most agencies do a good job of avoiding direct impacts to archeological sites and other historic properties when planning and building recreational trails; they seldom consider indirect impacts to those properties that may result from uncontrolled or uninformed visitation or increased vandalism of sites in previously inaccessible areas.
One of the strengths of the new process is also a potential weakness. As one BLM manager predicted, the time I spend on BLM-related preservation issues may have actually increased under the streamlined process. Further, if we are to achieve maximum benefit from the new process, it may continue to increase. The net effect, so far, has been positive, but there is a limit to SHPO staff resources.
Finally, I hope that all those who are concerned about preservation in general, or about a particular property, have not been disenfranchised. Hopefully, the fact that we have had few calls means that the BLM is being responsive. Concerns about a federal undertaking, first and foremost, should be directed to the agency; that is where the greatest opportunity for resolving conflicts lies. Nonetheless, there are occasions when the SHPO and the Advisory Council should both participate in consultation, to ensure that the views of all parties are considered. If local governments, avocational societies, tribes, and others hold the mistaken notion that the new process has closed this avenue, then we have failed them. Exclusion was no one's intent.
I feel positive about these changes; I hope others do too. If not, I hope they will come forward and make their concerns known.
For more information, contact Carol Heathington, Archeologist, Arizona State Historic Preservation Office, 1300 West Washington, Phoenix, AZ 85007, (602) 542-4009, fax (602) 542-4180, e-mail firstname.lastname@example.org.