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 [graphic] National Register Bulletin Guidelines for Evaluating and Registering Archeological Properties

U.S. Department of the Interior, National Park Service

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IV. EVALUATING THE SIGNIFICANCE OF ARCHEOLOGICAL PROPERTIES

NATIONAL REGISTER CRITERIA

The quality of significance in American history, architecture, archeology, engineering and culture is present in districts, sites, buildings, structures, and objects that possess integrity of location, design, setting, materials, workmanship, feeling, association, and:

A. that are associated with events that have made a significant contribution to the broad patterns of our history; or
B. that are associated with the lives of persons significant in our past; or
C. that embody the distinctive characteristics of a type, period, or method of construction, or that represent the work of a master, or that possess high artistic value, or that represent a significant and distinguishable entity whose components may lack individual distinction; or
D. that have yielded, or may be likely to yield, information important in prehistory or history.

A National Register property must meet at least one of the above National Register criteria; it may meet more than one. Each criterion that is checked on the nomination form must be fully justified. For example, if a Civil War battlefield qualifies under Criteria A and D, then both the battle and its importance and the important information that archeological investigations would likely yield need to be addressed.

Properties nominated to the National Register under Criteria A, B, or C often contain archeological deposits. For example, a nineteenth-century farmstead (including the main houses and outbuildings) that qualifies for listing under Criteria A, B, or C may have intact archeological deposits. In many cases, however, these deposits are undocumented. In such cases, the preparer should clearly note the potential for archeological deposits in the text of the nomination. Unless the significance of the property is justified under Criterion D, Criterion D should not be checked on the nomination form. Once additional studies are done to document the archeological information retained from the site, then the nomination form should be amended to add Criterion D.

In a case, such as that noted above, the archeological deposits need not relate to the significance of the documented standing structures. For example, the Henderson Hill Historic District in West Virginia is a large nineteenth-century farm complex eligible under A, B, C, and D. The archeological component of the farm itself has not been evaluated but three Woodland period mounds on the property are likely to yield important information. If additional documentation were to be added to demonstrate the information potential of the nineteenth-century archeological deposits, both significant contexts (the relevant, nineteenth-century historic context, and the Woodland period) should be justified.

CRITERIA CONSIDERATIONS

Unless certain special requirements (known as the criteria considerations) are met, moved properties; birthplaces; cemeteries; reconstructed buildings, structures, or objects; commemorative properties; and properties that have achieved significance within the past 50 years are not generally eligible for the National Register. The criteria considerations, or exceptions to these rules, are found in How to Complete the National Register Registration Form and How to Apply the National Register Criteria for Evaluation.

The National Register criteria considerations are:

A. A religious property may be eligible if it derives its primary significance from architectural or artistic distinction or historical importance.

B. A property removed from its original or historically significant location can be eligible if it is significant primarily for its architectural value or it is the surviving property most importantly associated with a historic person or event.

C. A birthplace or grave of a historical figure may be eligible if the person is of outstanding importance and if there is no other appropriate site or building directly associated with his or her productive life.

D. A cemetery may be eligible if it derives its primary significance from graves of persons of transcendent importance, from age, from distinctive design features, or from association with historic events.

E. A reconstructed property may be eligible when it is accurately executed in a suitable environment and presented in a dignified manner as part of a restoration master plan and when no other building or structure with the same associations has survived.

F. A property primarily commemorative in intent can be eligible if design, age, tradition, or symbolic value has invested it with its own historic significance.

G. A property achieving significance within the last 50 years may be eligible if it is of exceptional importance

Note: if a property is an integral part of a district or site that meets the criteria, then do not apply the criteria considerations to the individual property. For example, a nomination for an archeological district consisting of archeological sites, some above-ground ruins, several standing structures, and two historically associated cemeteries need not address the criterion consideration for cemeteries because the two cemeteries are an integral part of the district. For more information on cemeteries and burial places, see the National Register bulletin Guidelines for Evaluating and Registering Cemeteriesand Burial Places. A cemetery that is nominated under Criterion D for information potential does not need to meet Criteria Consideration D.

EVALUATING PROPERTIES IN CONTEXT

The National Register bulletin How to Apply the National Register Criteria for Evaluation, recommends the following sequence for evaluation:

1. Categorize the Property;

2. Determine which historic context(s) the property represents;

3. Determine whether the property is significant under the National Register Criteria;

4. Determine if the property represents a type usually excluded from the National Register.;

5. Determine whether the property retains integrity.

There are a few things to keep in mind when following this sequence. Historic contexts usually have been developed in some form for the identification of properties. It is possible, though, that the contexts will need to be further developed for evaluation. The assessment of integrity is the final step in the sequence and should not be used as an initial step with which to screen properties.

Since decisions regarding the evaluation of properties involves placing properties in historic contexts, the more that is known about a given context, the better the evaluation decisions about particular properties will be. Evaluation decisions can be made on the basis of incomplete data, but it is wise not to make them without some information on historic contexts, significance, and their component property types. A decision that a given property is not significant should never be made without access to a reasonable body of data on relevant historic contexts, since such an uninformed decision may result in the property's destruction without attention to its historic values.

When an evaluation must be made without a firm understanding of the relevant historic contexts, however, it should be made on the basis of as much relevant data as it is possible to accumulate. There should be full recognition that it may result in the destruction of a property that might later be found to be very significant, on the basis of complete survey results, or in the investment of money and other resources in a property later found to lack historic value.

A statement of significance, whether designed to show that a property is or is not significant, should be developed as a reasoned argument, first identifying the historic context or contexts to which the property could relate, next discussing the property types within the context and their relevant characteristics, and then showing how the property in question does or does not have the characteristics required to qualify it as part of the context.

In order to decide whether a property is significant within its historic context, determine:

. the facet of history of the local area, state, or the nation that the property represents;

. whether that facet of pre-contact or post-contact history is significant;

. whether it is a type of property that has relevance and importance in illustrating the historic context;

. how the property illustrates that history; and

. whether the property possesses the physical features necessary to convey the aspect of pre-contact or post-contact history with which it is associated.

LOCAL CONTEXT

The level of context of archeological sites significant for their information potential depends on the scope of the applicable research design. For example, a late Mississippian village site may yield information in a research design concerning one settlement system on a regional scale, while in another research design it may reveal information of local importance concerning a single group's stone tool manufacturing techniques or house forms. It is a question of how the available information potential is likely to be used.

STATE CONTEXT

Pre-contact and many early colonial sites are not often considered to have "State" significance, per se, largely because States are relatively recent political entities and usually do not correspond closely either to Native American political territories or cultural areas or to U.S. lands prior to statehood. Numerous sites, however, may be of significance to a large region that might geographically encompass parts of one, or usually several, States. Pre-contact resources that might be of State significance include regional sites that provide a diagnostic assemblage of artifacts for a particular cultural group or time period or that provide chronological control (specific dates or relative order in time) for a series of cultural groups.

NATIONAL CONTEXT

A property with national significance helps us to understand the history of the nation by illustrating the nationwide impact of events or persons associated with the property, its architectural type or style, or information potential. It must be of exceptional value in representing or illustrating an important theme in the history of the nation. Awatovi Ruins in Navajo County, Arizona, is an example of a pre-contact site of national significance. Designated a National Historic Landmark in 1966, Awatovi, meaning "high place of the bow," was one of the largest and most important of the five villages of Tusayan. Settled during the late twelfth century, it was the site of at least two thriving Hopi villages. A post-contact site that is of national significance is Mission Santa Ines in Santa Barbara County, California. This National Historic Landmark represents one of the most intact physical records of a colonial mission institution in the western United States. Archeological information recovered from Mission Santa Innes can shed light on the history of this diverse mission community and the relationship of this Spanish colony to world economic networks. (See the previous section, "What if an archeological property is nationally significant?")

THE IMPORTANCE OF SMALL OR OVERLOOKED SITES

Archeological properties which obviously stand out within the landscape, such as the ruins of southwestern pueblos and the mounds and earthworks of the mid-continent, may clearly convey their significance simply because they are visible. It is no surprise that archeologists have spent a lot of energy on researching and writing about these salient sites (e.g. Tainter and Tainter 1996:7). However, it is clear from many studies that small sites also yield important information. Many of the arguments made by Talmage and others (1977) in "The Importance of Small, Surface, and Disturbed Sites as Sources of Significant Archeological Data" still hold. For example, demonstrating the significance of small sites on the Colorado Plateau, Alan Sullivan (1996) has looked at the evidence of wild-resource production from two non-architectural sites along eastern south rim of the Grand Canyon. The most obvious features at these sites are piles of fire-cracked rocks. Several things suggest that these are production locations-the form of the rock piles, paleobotanical contents, and patterned artifacts, including manos and metates and Tusayan Grayware. There are no fragments of trough metates, a form associated with maize processing. In the Upper Basin trough metates are found exclusively at architectural sites. Sullivan (1996:154) surmises that "these patterned differences in metate form support the hypothesis that the role of wild resources in Western Anasazi subsistence economies has been underestimated" because our economic models are based on data skewed toward consumption rather than production locales and assemblages.

Sullivan states that archeologists have been remiss in not fully evaluating the contexts of subsistence remains. Because we have focused all our attention on sites of food consumption (the large Pueblo sites with architecture) rather than on sites of production (including these small sites), we have misinterpreted the role of wild resources among the Western Anasazi. The editors (Tainter and Tainter 1996:17) of a recent volume summarize his point this way:

Sullivan makes the important suggestion that we have misunderstood Puebloan subsistence because we have focused our research on locations where food was consumed (pueblos) rather than locations where it was produced. The latter may be small, ephemeral artifact scatters. Many archaeologists overlook the importance of these small sites [See also Sullivan, Tainter, and Hardesty 1999; Tainter 1998].

Overlooking the significance of small sites may skew our understanding of past lifeways as those sites not only receive less research attention, but also are destroyed without being recorded thoroughly because they are "written off" as ineligible for listing in the National Register. Such losses point up the need to continuously reexamine historic contexts and allow new discoveries to challenge our ideas about the past. The development of local, statewide, and national historic contexts is also important because these contexts are used to judge significance by developing research agendas for all types of sites. If no historic context exists which relates to a specific property, a site's significance may be difficult to distinguish and consequently, the site may be determined ineliglible and/or destroyed.

Evaluators of archeological properties using the National Register

Criteria should be aware of new discoveries and developments that affect historic contexts and take them into account during site evaluation.

It is also important to consider significance before considering integrity. At Fort Leonard Wood in Missouri, Smith (1994:96) developed a regional context through a combined cultural, historical, and landscape approach. The context assists in identifying sites that best represent the range and variety of culture history. Smith found that the most difficult part in devising such a context was the integration of the historic context with the archeological remains. Smith used site types as the key in an approach that could be used as a model for approaching the evaluation and management of common site types. In developing the context for the Fort Leonard Wood settler community, Smith identified different types of settlers with purposes ranging from subsistence to cash cropping and characterized associated sites according to their archeological visibility, signature, and sensitivity. Some sites, such as twentieth-century tenant sites, have high visibility, easily identified signatures, and low sensitivity. It would be important to examine some but by no means all of this common type of site. (See also Peacock and Patrick 1997 for a discussion of common site types and information potential). Other sites, such as those of early squatters, have very low visibility, low signatures (that is, they are difficult to identify), and very high sensitivity because they are extremely rare and would provide important information. Even a damaged site could address research questions if it were a less common type. In a region that is very poorly known, for example, the investigation even of deflated sites may yield information potential for 1) basic archeological questions about use of the region and 2) baseline data on site condition with which to evaluate other similar sites in the region.

EVALUATING ARCHEOLOGICAL PROPERTIES UNDER THE CRITERIA

The use of Criteria A, B, and C for archeological sites is appropriate in limited circumstances and has never been supported as a universal application of the criteria. However, it is important to consider the applicability of criteria other than D when evaluating archeological properties. The preparer should consider as well whether, in addition to research significance, a site or district has traditional, social or religious significance to a particular group or community. It is important to note that under Criteria A, B, and C the archeological property must have demonstrated its ability to convey its significance, as opposed to sites eligible under Criterion D, where only the potential to yield information is required.

CRITERION A: EVENT(S) AND BROAD PATTERNS OF EVENTS

Mere association with historic events or trends is not enough, in and of itself, to qualify under Criterion A-the property's specific association must be considered important as well. Often, a comparative framework is necessary to determine if a site is considered an important example of an event or pattern of events.

1. Identify the event(s) with which the property is associated. Generally for archeological properties this is demonstrated primarily through specific historic contexts. Archeological evidence supports the linkage. Event or events include:

. a specific event marking an important moment in American (including local) history (e.g., a battle, treaty signing, court decision); or
. a series of linked events or a historical trend (e.g., a military campaign, relocation of Native Americans to missions, establishment of a town, growth of a city's fishing industry, a major migration, establishment of a new cultural or political system, emergence of agriculture).

2. Document the importance of the event(s) within the broad pattern(s) of history. For example, the nomination of a Revolutionary War battle site, at a minimum, should include a discussion of the importance of the battle and its relevance to the Revolutionary War. Note that broad patterns of our history (including local history) are the same as what the National Register calls historic contexts, which are defined as relevant historic themes set within a time period and geographic region.

3. Demonstrate the strength of association of the property to the event or patterns of events. In order to do this, the property must have existed at the time of and be directly associated with the event or pattern of events. A mission built 50 years after the Pueblo Revolt would probably have no direct association with the Pueblo Revolt. A mission that was abandoned as a result of the Pueblo Revolt, on the other hand, would have a direct association.

4. Assess the integrity of the property. Under Criterion A, a property must convey its historic significance. For example, archeological properties must have well-preserved features, artifacts, and intra-site patterning in order to illustrate a specific event or pattern of events in history. Refer to the section "Aspects, or Qualities, of Integrity," on page 35 for an example of when a site would or would not be eligible under Criterion A due to integrity of setting.

Archeological sites that are recognized "type" sites for specific archeological complexes or time periods are often eligible under Criterion A. Because they define archeological complexes or cultures or time periods, type sites are directly associated with the events and broad patterns of history. In addition, archeological sites that define the chronology of a region are directly associated with events that have made significant contributions to the broad patterns of our history.

Properties that have yielded important information in the past and that no longer retain additional research potential, such as completely excavated archeological sites, must be assessed essentially as historic sites under Criterion A. Such sites must be significant for associative values related to: 1) the importance of the data gained; or 2) the impact of the property's role in the history of the development of anthropology/archeology or other relevant disciplines. Like other historic properties, the site must retain the ability to convey its association as the former repository of important information, the location of historic events, or the representation of important trends. For instance, a completely excavated pre-contact quarry site known to have been the only quarry site utilized by Native Americans in a northeastern state has revealed important information concerning the seasonal rounds of Native groups, and the procurement and reduction of local lithic materials. Information about how mining materials from this quarry functioned within the overall cultural system of the area and affected settlement and subsistence practices and the intact physical environment of the site convey its importance as the best example of pre-contact industry and commerce in this locale. The quarry is visible, located in a remote area, and maintains integrity of location, setting, feeling, and association. The site would be eligible at the local level of significance under Criterion A, but not D. The site may not be eligible at the state level of significance under Criterion A, as it may not exemplify an important quarry, comparatively, for the region.

photo of Charles Forte site Figure 6: Listed under Criteria A and D, the Charles Forte site (38BU51) is near Beaufort, South Carolina. The fort was built in 1562 and represents the first European occupation of South Carolina. (J.M. Rhett)

Some sites may be listed for their significance in the history of archeology. In Colorado, the first Basketmaker II rockshelter excavated is listed under Criterion A at the state level for archeology. House types and domestic features were identified archeologically here for the first time. The rockshelter, excavated in LaPlata County by Earle Morris in 1938, is also listed for Criterion D because at least half of the midden remains and there is likely to be information there on the transition from the Archaic to Basketmaker adaptations.

The Yamasee Indian towns in the South Carolina Low Country are eligible under Criterion A as well as D as part of the first Indian land reservation in South Carolina. The Yamasee played a key role in the defense of South Carolina against the Spanish from 1684 to 1715.

A cultural landscape which includes both traditional cultural places and archeological sites may be eligible under Criteria A and D for its significance in the areas of Ethnic Heritage and Archeology. In an example from California, a landscape containing a village site and additional cultural features, as well as natural features of oak groves and grasslands, demonstrates the management of hunted and gathered resources through burning to promote particular environments. One of several research questions identified concerned the relationship between inland and coastal sites in the region.

The Multiple Property Submission (MPS) "Precontact American Indian Earthworks, 500 BC - AD 1650" for Minnesota creates registration requirements for earthworks under Criteria A, B, C, and D. The following two examples demonstrate the requirements. Site X was first mapped in 1885 and contains more than 60 mounds and earthworks. A village site appears to be immediately associated with the site. Several of the mounds have looter's holes in them but the site has never been plowed. The site is still wooded and there is no recent development on or near the site. It is essentially in pristine condition. This site has excellent integrity of design, setting, materials, feeling, and association, and could therefore be nominated to the National Register under Criteria A, C, and D.

Site Y consisted of at least 225 earthworks and mounds and associated village site. It is the type site for a Late Pre-Contact context. However, the site has been extensively plowed, several factories have been built on it, and it is within an industrial park. Although the location of the mounds have been relocated using aerial photography and remote sensing, most have been destroyed. There is some evidence, however, that there are still some intact materials at the site. In this case, the site is not eligible under Criteria A or C because integrity of design, setting, and feeling are very poor and integrity of materials and association are merely acceptable. However it is eligible under Criterion D if the mound group and village are considered one site because together they still hold significant research potential.

A site determined eligible under Criteria A and D under this Multiple Property Submission cover document is eligible under Criterion A because it typifies a distinctive type of site that is part of the broader pattern associated with the emergence of agriculture along the margin of the eastern Plains and increasing population nucleation after circa 1100 A.D. For further examples of sites listed under Criterion A, see the "Summary of Significance" for Cannonball Ruins and Fort Davis under "Narrative Statement of Significance," in Section V of this bulletin.

CRITERION B: IMPORTANT PERSONS

In order to qualify under Criterion B, the persons associated with the property must be individually significant within a historic context. The known major villages of individual Native Americans who were important during the contact period or later may qualify under Criterion B. As with all Criterion B properties, the individual associated with the property must have made some specific important contribution to history. Examples include sites significantly associated with Chief Joseph and Geronimo.

1. Identify the important person or persons associated with the property. (For in-depth guidance on nominating a property under Criterion B, refer to the National Register bulletin Guidelines for Evaluating and Documenting Properties Associated with Significant Persons) "Persons significant in our past" refers to individuals whose activities are demonstrably important within a local, state, or national historic context. Under Criterion B, a property must be illustrative rather than commem-orative of a person's life. An illustrative property is directly linked to the person and to the reason why that person is considered to be important.In most cases, a monument built to commemorate the accomplishments of a judge, for example, important in this nation's history would not be eligible for listing in the National Register. (For exceptions to this general rule refer to the "Criteria Consideration F: Commemorative Properties" discussion in How to Apply the National Register Criteria for Evaluation) The courthouse where the judge worked and wrote his opinions, on the other hand, may be eligible under Criterion B.

2. Discuss the importance of the individual within the relevant historic context(s). The person associated with the property must be individually significant and not just a member of a profession, class, or social or ethnic group. For example, a doctor who is known to have been important in the settlement and early development of a community would be important under Criterion B. A person who is known to have been a doctor but with no special professional or community standing would not be important under Criterion B.

3. Demonstrate the strength of association between the person and the property. Generally, properties should be associated with the activities, events, etc. for which the person is important. For example, the lab where a renowned scientist developed his inventions would be more strongly associated with the scientist than the apartment house where he lived. The importance or relevance of the property in comparison to other properties associated with the person should be addressed. Properties that pre- or post-date an individual's significant accomplishments usually are not eligible under Criterion B.

4. Address the property's integrity. Sufficient integrity implies that the essential physical features during its association with the person's life are intact. If the property is a site that had no material cultural remains, then the setting must be intact. Under Criterion B, archeological properties need to be in good condition with excellent preservation of features, artifacts, and spatial relationships. An effective test is to ask if the person would recognize the property. If "no," then integrity may be insufficient to qualify under Criterion B. Refer to "Aspects, or Qualities, of Integrity," in Section IV of this bulletin.

The Puckshunubbee-Haley Site in Madison County, Mississippi, is listed under both Criteria B and D as the residence site (without standing structures) of two significant individuals: Puckshunubbee, an important Choctaw chief from about 1801 to 1824, and pioneer Major David W. Haley, who purchased the chief's house after his death and was central to land negotiations with the Choctaw. This three-acre property also contains a Late Mississippian mound.

The farm site where a famous scientist lived for several years when she was a young woman is now in the middle of a modern day housing development. Several other properties associated with this scientist's career and her birthplace are already listed on the National Register. In addition, research and excavations have shown that the site is highly disturbed. This site would not be eligible under Criterion A, B, C, or D.

The Modoc Lava Beds Archaeological District in California is listed under Criteria A, B, and D. Under A, this 46,780-acre district is associated with the Modoc War of 1872-73 and contains places of traditional cultural significance to the Modoc people. Eligibility under B is for association with Captain Jack, the principal Modoc leader during the war, for the areas of significance: Ethnic Heritage: Native American, and Military. Important information under Criterion D is associated with chronology; settlement and subsistence; exchange relationships; military architecture; art and religion. The Modoc Lava beds were a major geographic crossroads for the far western United States. The role of the district's inhabitants in controlling the distribution of obsidian from the Medicine Lake Highland volcanic field is one of the specific research topics.

The Kukaniloko Birth Site in Hawaii is listed under A, B, and D for, "ARCHEOLOGY: Prehistoric; ETHNIC HERITAGE: Native Hawaiian; SOCIAL HISTORY; POLITICS-GOVERNMENT; and RELIGION.

Kukaniloko is a celebrated place set aside for the birth of high ranking chiefs, marked by large basalt stones. Once part of a larger religious complex, Kukaniloko continues to be visited by Hawaiians who occasionally leave offerings. It is associated with a number of prominent chiefs born there. The nomination states that important information may be gathered from the analysis of the boulders and petroglyphs, which are thought to have astronomical significance.

Criterion C: Design, Construction, and Work of a Master

To be eligible under Criterion C, a property must meet at least one of the following requirements: the property must embody distinctive characteristics of a type, period, or method of construction, represent the work of a master, possess high artistic value, or represent a significant and distinguishable entity whose components may lack individual distinction.

 

A Significant and Distinguishable Entity Whose Components May Lack Individual Distinction.
This portion of Criterion C refers to districts. For detailed information on districts, refer to the National Register bulletin How to Apply the National Register Criteria for Evaluation.

 

photo of Modoc Lava Beds Archaeological District
Figure 7: The bedrock mortars and rock alignment on a bedrock base mark a work area or former above-ground structure in the Modoc Lava Beds Archaeological District in Tulelake County, California, part of the Lava Beds National Monument. (Janet P. Eidsness)

The above requirements should be viewed within the context of the intent of Criterion C; that is, to distinguish those properties that are significant as representatives of the human expression of culture or technology (especially architecture, artistic value, landscape architecture, and engineering).

1. Identify the distinctive characteristics of the type, period, or method of construction, master or craftsman, or the high artistic value of the property. Distinctive characteristics of type, period, or method of construction are illustrated in one or more ways, including :

. The pattern of features common to a particular class of resources, such as a sugar mill with associated archeological remains that is representative of eighteenth-century Caribbean sugar mills;

. The individuality or variation of features that occurs within the class, such as the well-preserved ruins of an 1860s brewery that was designed and built to produce one type of ale;

. The evolution of that class, or the transition between the classes of resources, such as the well-preserved sites of four adjacent shipyards, each representing a different time period in clipper ship building.

photo Florida's New Smyrna Sugar Mill ruins
photo of Florida's New Smyrna Sugar Mill ruinsFigures 8 and 9: Florida's New Smyrna Sugar Mill ruins (bottom) (Florida State News Bureau) and Seven Towers Pueblo (above) nominated under the Great Pueblo Period of the McElmo Drainage Unit MPS in Colorado (Richard Fuller), are good examples of archeological properties with significant standing architectural and subsurface archeological components.

A master is a figure of generally recognized greatness in a field, a known craftsman of consummate skill, or an anonymous craftsman whose work is distinguishable from others by its characteristic style and quality. If a well-preserved, eighteenth-century pottery kiln site, such as the Mt. Sheppard, North Carolina pottery, illustrates how a particular type of exceptional pottery was produced by a renowned pottery manufacturer, then it would qualify under Criterion C.

High artistic value may take a variety of forms including community design or planning, landscaping, engineering and works of art. A property with high artistic value must (when compared to similar resources) fully express an aesthetic ideal of a particular concept of design. The well-preserved ruins of a building that was used as a hospital and still has intact walls covered with pictures and graffiti drawn by Civil War soldiers who stayed there would be eligible under Criterion C.

2. Discuss the importance of the property given the historic contexts that are relevant to the property and the applicability of Criterion C. Note that the work of an unidentified craftsman or builder is eligible if the work (usually a building or structure) rises above the level of workmanship of other similar or thematically-related properties. As a result, comparison with other properties is usually required to make the case of eligibility under Criterion C.

For example, a colonial plantation site may have standing buildings that are excellent examples of a rare form of colonial construction. To illustrate this, Colonial-period construction methods need to be discussed to a level of detail sufficient to demonstrate that the construction methods seen at the example plantation are rare.

3. Evaluate how strongly the property illustrates the distinctive characteristics of the type, period, or method of construction, master or craftsman, or the high artistic value of the property. For example, an archeological property with a standing structure that was used as a stage stop for the Butterfield Overland Mail service may qualify under Criterion A but not be eligible under Criterion C because the structure is not representative of the stage stops that were actually built to service the stages and mail carriers.

photo of Blythe IntagliosFigure 10: The Blythe Intaglios in California Represent a property with high artistic value. (Bureau of Land Management)
map of Yarmony Archaeological SiteFigure 11: At the multicomponent Yarmony Archaeological Site in Colorado, the 7000 year old Early Archaic pithouses (such as the one shown here) are exemplary buildings in their age, complexity of features, artifact associations, and physical integrity. This site is listed under Criterion C for architecture and Criterion D for archaeology. (Figure from Michael Metcalf and Kevin Black, Southwestern Lore 54(1) 1988)

4. Address the integrity of the property. To meet the integrity requirement of Criterion C, an archeological property must have remains that are well-preserved and clearly illustrate the design and construction of the building or structure. An exception to the above-ground rule is structures that were intentionally built below the ground. For example, many industrial complexes, such as brick manufacturing or mining sites, contain potentially significant architectural or engineering remains below ground. Another exception might be found at archeological sites that contained relatively intact architectural remains buried through either cultural or natural processes. Thus, well-preserved architectural remains that were uncovered by archeological excavation might be considered eligible under Criterion C. Refer to "Aspects, or Qualities, of Integrity" in Section IV of this bulletin.

A late Mississippian village that illustrates the important concepts in pre-contact community design and planning will qualify. A Hopewellian mound, if it is an important example of mound building construction tech-niques, would qualify as a method or type of construction. A Native American irrigation system modified for use by Europeans could be eligible if it illustrates the technology of either or both periods of construction. Properties that are important representatives of the aesthetic values of a cultural group, such as petroglyphs and ground drawings by Native Americans, are generally eligible.

The Beattie Mound Group in downtown Rockford, Illinois, is eligible under Criteria C and D for architecture and archeology. The mound group embodies distinctive characteristics of the earthwork type of construction in three forms: conical, linear, and turtle effigy. This group is unusual in representing a variety of forms in a small area. These mounds are part of the "Effigy Mound" tradition of the Upper Mississippi Valley, which dates from about A.D. 300-1100.

An archeological district in Colorado is listed at the state level of significance under Criteria C and D for architecture and archeology. The district contains at least 24 sites dating from A.D. 975-1150. These sites include rock shelters with coursed masonry features, rock shelters with wall alignments, rock shelters without architectural features, open masonry which incorporate boulders/rocks outcrops into room features, and mesa top sites with alignments. Research questions focus on the relationship of the district to related sites in the Four Corners region. As a frontier community established during a time of dynamic cultural change, this district may establish the extreme northern extension of an important culture area. The boundary contains a complete environmental profile from the mesa top downslope to the creek.

The archeological remains of a seventeenth-century integrated iron production facility are important at the state level of significance as they represent the earliest example of this type of facility in the state. Road construction has disturbed only a portion of the site, however, the major activity areas are not discernable archeologically due to this disturbance. This site is not eligible under Criterion C as an example of the first phase in the evolution of iron production facilities in this locale, but may still be eligible under Criterion D if other areas of the site are intact enough to produce important information.

In Alaska, a cedar dugout canoe more than 29 feet long is listed as a structure and a site. Its historic function is Transportation/water-related; it is not currently in use. In fact, it was never finished by the Tlingit Indian(s) who began construction sometime before 1920. Because it is unfinished, it shows part of the construction process that would not be apparent in a finished canoe. It is an example of an early Northern type of Indian canoe with a distinctive profile. When it was listed in 1989, it was the only partially finished Native canoe of this type found in situ in southeast Alaska. The canoe is eligible under Criterion C as it embodies the distinctive characteristics of a type-the Northern canoe; and method of construction-the unfinished canoe retains construction elements usually lost in a completed canoe. The construction site itself is preserved as the tree stump from which the log was cut is intact and exhibits saw marks that help date the construction to no earlier than the late nineteenth century. The site has the potential to yield important information about the use of the forest by Tlingit peoples and about the construction of canoes during the last decades when they were being made. Archeological investigations at the site are likely to yield artifacts or features associated with manufacture.

photo of Leluh Ruins
Figure 12: Leluh Ruins, located on Leluh Island, Kosrae State, Federated States of Micronesia, includes massive basalt walls, high chief's compounds, a royal tomb and other sacred compounds, several streets, a canal system and extensive archeological deposits. The site is listed under Criteria A, C, and D as it is associated with the rise of complex society in the Pacific, contains a distinctive form of architecture in its stacked basalt prisms and blocks, and the associated archeological remains may address a wide range of important research questions. (R. Cordy)

 

CRITERION D: INFORMATION POTENTIAL

Criterion D requires that a property "has yielded, or may be likely to yield, information important in prehistory or history." Most properties listed under Criterion D are archeological sites and districts, although extant structures and buildings may be significant for their information potential under this criterion. To qualify under Criterion D, a property must meet two basic requirements:

. The property must have, or have had, information that can contrib- ute to our understanding of human history of any time period;

. The information must be considered important.

Nominations should outline the type of important information that a property is likely to yield as shaped by the applicable research topics. To do this, the property must have the necessary kinds and configuration of data sets and integrity to address important research questions.

 

 

There are five primary steps in a Criterion D evaluation.

1. Identify the property's data set(s) or categories of archeological, historical, or ecological information.
2. Identify the historic context(s), that is, the appropriate historical and archeological framework in which to evaluate the property.
3. Identify the important research question(s) that the property's data sets can be expected to address.
4. Taking archeological integrity into consieration, evaluate the data sets in terms of their potential and known ability to answer research questions.
5. Identify the important information that an archeological study of the property has yielded or is likely to yield.

Application of Criterion D requires that the important information which an archeological property may yield must be anticipated at the time of evaluation. Archeological techniques and methods have improved greatly even in the few decades since the passage of the National Historic Preservation Act. The questions that archeologists ask have changed and become, in many cases, more detailed and more sophisticated. The history of archeology is full of examples of important information being gleaned from sites previously thought unimportant. Because important information and methods for acquiring it change through time, it may be necessary to reassess historic contexts and site evaluations periodically.

Changing perceptions of significance are simply a matter of the normal course of all social sciences and humanities as they evolve and develop new areas of study. What constitutes "information important in prehistory or history" changes with archeological and historical theory, method, and technique.

Specific questions may change but there are a number of categories of questions that are used routinely to frame research designs in terms of anthropological observations of societies. Such general topics include but are not limited to: economics of subsistence, technology and trade; land use and settlement; social and political organization; ideology, religion, and cosmology; paleoenvironmental reconstruction; and ecological adaptation. In addition, a category of questions that relate to improvement to archeological methodology should be considered. For other general categories see the National Park Service Thematic Framework (NPS 1996), available at http://www.nps.gov/history/history/thematic.html.

Through the disciplined study of the archeological record and supporting information, archeologists can provide answers to certain important questions about the past that are unobtainable from other sources. Archeological inquiry generally contributes to our understanding of the past in three ways. It:

.describes, records, and reconstructs past lifeways across time and space;

. tests new hypotheses about past activities; and

. reinforces, alters, or challenges current assumptions about the past.

The Mt. Jasper Lithic Source in Coos County, New Hampshire, is listed under "ARCHEOLOGY: Prehistoric; and INDUSTRY," for its contribution to the understanding of lithic technology and, secondarily, for its contribution to understanding settlement and exchange patterns. The lithic source area contains places where a rare and high quality raw material was found, mined, and made into tools essential for survival by hunter-gatherers from ca. 7000 BC to A.D. 1500. The recovery of tools made from Mt. Jasper rhyolite at sites distant from the source shows it widespread use.

photo of Shenks Ferry Site Figure 13: The Shenks Ferry Site in Lancaster County, Pennsylvania, an important contact period village site, was excavated in the 1930s and 1970s. It was listed in the National Register in 1982 without additional excavations. (Archaeology Laboratory, WPMM, Harrisburg, Pennsylvania)

 

In the southern Idaho uplands, a large district significant at the state level encompasses the drainages of two creeks and represents 6000 years of occupation. Site types in this high desert sagebrush-grass-juniper environment include rockshelters and caves, rock art sites, campsites, lithic scatters, workshops, and rock alignments. Important research questions under Criterion D concern the arrival of the Shoshoni in southern Idaho, the relationship of the area people to the Fremont residents in Utah, and the function of various types of rock alignments.

The Big Sioux Prehistoric Prairie Procurement System Archeological District contains a representative sample of the best preserved elements of a hunting and gathering system in the northwest Iowa plains from 10,000 to 200 years ago. It includes large and small sites, plowed and unplowed, and material on all types of landforms in the river valley. This discontiguous district's 30 sites are stretched along 15 miles of river terraces and blufftops. They include: late base camps; deeply-buried early Archaic camps; and procurement sites from all pre-contact time periods. The nomination argues that there is a common bias toward emphasizing individual sites, especially large and spectacular sites. Small, temporarily occupied sites seem to be the first to fall out of research designs. Small sites may appear to produce little information because broad cultural patterns cannot be reconstructed from one small site. However, small sites, especially single-component sites may contain detailed information which is unobtainable from larger, multi-component sites. Without the context of a larger subsistence and settlement system, small sites may appear meaningless but in a well-developed context, their significance can be assessed realistically. Base camps must be connected with temporary sites in order to reconstruct the whole settlement system.

If archeological studies were conducted previously at a site, additional test excavation may not be required before preparing a National Register nomination. For example, the Shenks Ferry site in Lancaster County, Pennsylvania (a contact period village dating from the sixteenth century), was excavated in the early 1930s and in the 1970s and was listed in the National Register in 1982 without additional field investigations.

map of Camp Carondelet
Figure 14: Because the recorded surface manifestations were obvious at Camp Carondelet, Prince William County, Virginia, archeological excavations were not required to list this Civil War encampment under Criterion D. (Jan Townsend)

The patterning of artifacts and features on the ground surface of some properties may be sufficient to warrant nominating them to the National Register. If this is the case, then demonstrating the presence of intact subsurface artifact or feature patterning through test excavations may not be required. That is, there is no mandatory testing of sites to determine their significance. For example, Camp Carondelet in Prince William County, Virginia, the 1861-1862 winter camp of a Louisiana brigade, was listed in the National Register without excavations. This Civil War camp, which is evidenced by above-ground patterning of hut outlines, chimney falls, trash pits, roads, and rifle pits has sufficient surface information to justify a statement of significance. Field work included mapping the above camp features and noting the location of artifacts visible on the surface of the ground and in and around holes dug by relic hunters. Similarly, mounds or earthworks such as those of the Effigy Mound tradition of the Upper Mississippi Valley would not require intrusive testing for a convincing statement of significance to be argued based on analogy with similar excavated properties.

At the John Dickinson house, a National Historic Landmark located near Dover, Delaware, ground-penetrating radar was used to locate subsurface evidence of outbuildings, barns, and other features prior to the reconstruction of this eighteenth-century plantation's architecture (Bevan 1981). At Fort Benning, Georgia, electromagnetic, magnetic, and GPR investigations at the Creek town of Upatoi revealed highly patterned subsurface features interpreted as probably graves. The use of non-destructive techniques provided evidence of subsurface remains and raised the priority of site protection as a land management concern (Briuer et al. 1997).

Data Sets

Data sets, or data categories, are groups of information. Data sets are defined by the archeologist, taking into consideration the type of artifacts and features at the property, the research questions posed, and the analytical approach that is used. Whatever their theoretical orientation, all archeologists look at patterns in the archeological record. It is the evaluation or analysis of data sets and their patterning within the framework of research questions that yields information. Data sets can be types of artifacts (such as ceramics, glass, or tools), archeological features (such as privies, trash middens, or tailings piles), or patterned relationships between artifacts, features, soil stratigraphy, or above-ground remains. A graveyard, for example, might contain at least three data sets: the human remains, items buried with the deceased, and the arrangement of the graves within the cemetery.

Data sets that are known or expected to be represented at the property should be described. If the property is a district and there are multiple data sets (which is likely), then each of the kinds of data sets should be described. The data sets represented at each site may be presented in tabular form or in a matrix. The data sets described in this section must be consistent with the artifact and feature information included in the "Narrative Description" of the site. For example, if a chronology data set is described, then the property must have data (such as time-diagnostic artifacts) that can be used to address chronology. If there is a data set, or data sets, linked to a research topic of non-local exchange systems, for example, then there must be evidence of such activities represented in the archeological deposits.

Important Information and Research Questions

What are important questions in archeology? Even if a current list of important research questions existed(that archeologists could agree upon), the questions would still change as the discipline evolves and certain questions are answered and others are asked. Moreover, as research questions of the future cannot be anticipated, the kinds of data necessary to answer them cannot be determined with certainty. Thus, the research potential of a historic property must be evaluated in light of current issues in archeology, anthropology, history, and other disciplines of study (Ferguson 1977). The list of important research questions does not need to be lengthy or exhaustive. Examples of the kinds of research questions anticipated may be provided. A single important question is sufficient.

Theoretical positions on and pragmatic debates about important research questions are expressed at professional archeological conferences and in the professional literature and journals. For example, the Society for Historical Archeology sponsored a plenary session titled "Questions that Count in Archeology" at its annual meeting in 1987. This session addressed the issue of which theoretical frameworks or general research topics will generate the most important questions for post-contact archeology (e.g. Deagan 1988). From a theoretical viewpoint, Kathleen Deagan (1988:9), for example, makes the case that the questions that "count cannot be answered by either historical or archeological data alone, or through simple comparisons of two data categories." Rather than simply reinforcing other documentary sources, the interpretation of archeological evidence provides a supplementary and complementary record of the past. Other questions that count are those that apply archeological techniques to answering history-based questions about which there is inadequate documentation. In fact, to date, this has been post-contact archeology's most successful scholarly contribution (Deagan 1988:9). According to Deagan (1988:9), "other questions appropriate to the unique capabilities of historical archeology focus on understanding general cultural phenomena that transcend specific time and space."

A nomination should provide a clear link between the contexts, the research questions, and the data found at the property. Whatever the theoretical orientation of the archeologist, the connection between the archeological data and the important questions should be explicit in the National Register nomination.

One way to link archeological remains with research questions is through middle-range theories that connect the empirical world with generalized hypotheses (Leone 1988; Merton 1967; Binford 1977, 1981a, 1981b; Thomas 1983a, 1983b; South 1977,1988). The middle-range and general theories should follow from and be consistent with the information presented in the discussion of historic contexts.

As noted above, there is no set outline that must be followed in describing research questions within the narrative statement of significance. General theories and the more specific hypotheses that shape the research questions, for example, may be presented in the historic context discussion and simply referenced during the description of important research questions. The National Register nomination should include a clear and concise presentation of the required information. The specific format for doing this will be determined in large part by the nature of the archeological property and its information potential.

Archeologists have recognized the importance of comparative information from a regional data base in making effective eligibility decisions. This is especially true when dealing with large numbers of a common resource type that have not been evaluated, such as nineteenth-century farmsteads or stone circles. A regional perspective provides a logical framework in which to evaluate seemingly "mundane" or "redundant" historic properties (e.g., Hardesty 1990; McManamon 1990; Peacock and Patrick 1997; Smith 1990; Wilson 1990).

Preparing Multiple Property Submission cover documents may also help solve the problems encountered with the eligibility of "redundant" resources. The format of the multiple property document may serve as a research design that specifies significance, important information, documenting protocols and identification strategies for particular types of resources that are worthy of preservation. For instance, registration requirements specify eligibility requirements. (For further guidance on multiple property submissions, see the National Register bulletin How to Complete the National Register Multiple Property Documentation Form).

A good example of a regional study proposed in National Register documentation is the Multiple Property Submission, "Native American Archaeological Sites of the Oregon Coast." In the cover document, several sets of research topics and questions are presented at local, regional, and national scales of research. Topics used to evaluate the eligibility of individual sites include: how have Oregon Coast environments been occupied and/or used by Native Americans varied through space and time; when and how did coastal adaptations develop along the Oregon Coast; how did Oregon Coast settlement and subsistence change through time; when did ethnographic patterns first develop on the Oregon Coast; how did Euroamerican colonization affect Oregon Coast Native Americans and how did Native Americans affect the course of colonization; and questions related to general archeological method and theory.

Under each of these topics are more detailed questions. The Multiple Property Submission cover document recognizes that the study of individual sites creates the building blocks for regional models and ultimately for more general and broadly applicable archeological and anthropological method and theory. Regional research topics that can be addressed through the comparative study of individual sites include the following: 1) Changes in Oregon coast environments through time; 2) Antiquity of coastal adaptations; 3) Regional developments in settlement and subsistence; 4) Origins and development of ethnographic cultural patterns; and 5) Effects of European contact and colonization on Native Americans and their resources.

General topics of broad importance are addressed in a comparative framework. Four such topics are extensions of the regional questions. These are: 1) Environmental Change and Human Adaptations; 2) Coastal Adaptations and Maritime Cultural Ecology; 3) Cultural Complexity and its origins; and 4) "European radiation" and indigenous societies.When evaluating sites within a regional perspective, the following kinds of information should be presented:

. definition of the region or community under consideration;

. relative estimate of how many other similar properties were once located within the region;

. identification, where applicable, of surviving standing structures or sites;

. evaluation of level of archeological investigation of similar properties; and the

. outline of the documentary, ethnographic, or other supporting evidence related to the property.

To systematically evaluate properties, National Register nomination preparers often use an evaluation matrix, especially for pre-contact archeological properties. This approach to evaluation can also be particularly useful for evaluating the scientific or information potential of a post-contact archeological property. Donald L. Hardesty describes the development of a significance evaluation matrix in his 1988 publication, The Archeology of Mining and Miners: A View From the Silver State. Although Hardesty'sfocus is on mining properties, the process that Hardesty calls "a logical questioning framework" is applicable to all kinds of archeology properties (1990:48).

In Hardesty's evaluation matrix the vertical axis comprises key areas of research (such as demography, technology, economics, social organization, and ideology) while the horizontal axis describes three research levels (world system, region, and locality) where questions about the past may be addressed. The specific features of an evaluation matrix are determined taking into consideration the theoretical framework, middle range theories linking the data sets to the relevant research questions, the research questions or topics, and the data sets represented at the property. In this example, a post-contact archeological property would be eligible for the National Register if its archeological record contains information with sufficient integrity that can be used to address one of the topics within the evaluation matrix.If the information at the site cannot be used to address these research themes, then the property may not be eligible for the National Register.

Archeological properties that fall between the clearly eligible and the clearly ineligible are the most difficult to evaluate for inclusion in the National Register. Moreover, it is important to realize that professional archeologists, historians, and architectural historians may disagree on the eligibility of a particular historic property. In theory, given high quality, and often site-specific, archeological research designs and comprehensive historic contexts, questions of eligibility should be minimal. As with all scientific and humanistic endeavors, it is the quality and bias of the questions we ask that determines the nature of the answers we recover from the past.

An Evaluation Matrix for Mines
Research Domain World System Region

Locality

Demography Comparative data on patterns of mining frontier demography Patterns of occupation/ abandonment in district Reconstruction of household population
Technology Adaptive variety and change in industrial and appropriate technologies on the mining frontier Adaptive change in industrial technologies imported into district Reconstruction of mining/ milling technologies
Economics Adaptive patterns of economic production and distributions on the mining frontier Patterns of economic distribution and production within the district Reconstruction of household consumption and production
Social Organization Patterns of mining frontier social structure and change Patterns of "colony" social structure and ethnic relations Reconstruction of household status and ethnicity
Ideology Emergence of "syncretic" mining frontier ideology Interaction of Victorian and ethnic folk cultures Reconstruction of household ideology

 

OTHER SIGNIFICANCE CONSIDERATIONS

The following: Areas of Significance, Period of Significance, Significant Dates, Significant Person(s), Cultural Affiliation, Architect or Builder, are important for all nominations, whether Criteria A, B, C, or D are being applied. Criteria considerations are listed and discussed on pp. 19-20 under "National Register Criteria."

AREAS OF SIGNIFICANCE

For post-contact archeological properties enter "ARCHEOLOGY: Historic-Aboriginal" or " ARCHEOLOGY: Historic-Non-Aboriginal" or both. For pre-contact properties enter "ARCHEOLOGY: Prehistoric." In addition, enter any categories and subcategories about which the property is likely to yield important information and list them in relative importance to the property. For example, an Indian industrial school may have the following areas of significance: "ARCHEOLOGY: Historic-Aboriginal," "Education," and "Ethnic Heritage: Native American." If the school was of a special architectural design, then "Architecture" may also be added to the list. A pre-contact lithic source may have areas of significance "ARCHEOLOGY: Prehistoric" and "INDUSTRY." A paleo-Indian kill site may have the areas of significance "ARCHEOLOGY: Prehistoric" and "ECONOMICS" because there are no areas of significance specific to non-agricultural societies.

The ARCHEOLOGY Area of Significance has the subcategories noted above. Many archeological sites can be associated with a specific ethnic group, which also has subcategories. If this is the case, then enter

"ETHNIC HERITAGE: Asian,"
"ETHNIC HERITAGE: Black,"
"ETHNIC HERITAGE: European,"
"ETHNIC HERITAGE: Hispanic,"
"ETHNIC HERITAGE: Native American,"
"ETHNIC HERITAGE: Pacific Islander," or
"ETHNIC HERITAGE: Other."

Other Areas of Significance include: AGRICULTURE, ART, COMMERCE, COMMUNICATIONS, COMMUNITY PLANNING AND DEVELOPMENT, CONSERVATION, ECONOMICS, EDUCATION, ENGINEERING, ENTERTAINMENT/RECREATION, EXPLORATION/SETTLEMENT, HEALTH/MEDICINE, INDUSTRY, INVENTION, LAND-SCAPE ARCHITECTURE, LAW, LITERATURE, MARITIME HISTORY, MILITARY, PERFORMING ARTS, PHILOSOPHY, POLITICS/GOVERNMENT, RELIGION, SCIENCE, SOCIAL HISTORY, TRANSPORTATION, AND OTHER. Each of these Areas of Significance, none of which have subcategories, are defined in the National Register bulletin How to Complete the National Register Registration Form.

Every effort should be made to use the listed "Areas of Significance." If none are applicable (except, of course, "Archeology."), then "Other" may be entered and the appropriate area(s) of significance described in the text. The use of the "Other" category, however, precludes analysis of the property in terms of the other properties listed in the National Register. Each of the areas of significance must be described in the narrative significance section, and, if the property is eligible under Criterion D, linked to the information potential of the property.

PERIOD OF SIGNIFICANCE

The period of significance for an archeological property is the time range (which is usually estimated) during which the property was occupied or used and for which the property is likely to yield important information if evaluated under Criterion D. There may be more than one period of significance. If the periods of significance overlap, then they should be combined into one longer period of significance. Periods of significance should be listed in order of importance relative to the property's history, the areas of significance, and the criteria under which the property is being nominated. The periods of significance must follow from the data presented in the narrative description and significance statements in the nomination.

For example, an antebellum plantation that was built in 1820 and burned in 1864 and has well preserved archeological deposits dating from 1820 to 1864 has a 1820-1864 period of significance. If the same property was reoccupied from 1870 through 1900 and this period is represented by intact archeological deposits, then the periods of significance are 1820-1864 and 1870-1900. If the same site was then occupied sporadically from 1910 to 1920 by transients and there are no archeological remains associated with this period of use, then the periods of significance are still 1820-1864 and 1870-1900.

If a portion of the same property was mined for gold from 1875 through 1880 and the remains of this mining activity are intact and well preserved, then the periods of significance will still be 1820-1864 and 1870-1900. If the mining activity extended from 1865 to 1875, then the property's period of significance would be 1820-1900. The subperiods of significance (i.e., 1820-1864,1865-1875, and 1870-1900) may be listed below the overall period of significance but, since subperiods are not coded into the National Register database, this is not required. The subperiods of significance, however, should be described in the narrative significance statement.

photo of Kalaoa Permanent House Site
photo of Kalaupap Leprosy Settlement, Hawaii
Figures 15 and 16: Archeological properties illustrate the diversity of a region's history. In Hawaii, for example, post-contact archeological properties include Kalaoa Permanent House Site (top) (ca. A.D. 1400-1800) (R. Cordy) and the Kalaupapa Leprosy Settlement (Bottom) (early twentieth century). (NPS)

 

SIGNIFICANT DATES

Significant dates are single years in which a special event or activity associated with the significance of the property occurred. A significant date is by definition included within the period of significance time range. The property must have historical integrity for all the significant dates entered. The beginning and closing dates of a period of significance are "significant dates" only if they mark specific events or activities related to the significance of the property. The dates should be listed in order of importance given the property's history and why it is significant. Martin's Hundred in Virginia has two significant dates: 1619, the year when it was established; and 1622, the year when it was almost completely destroyed in a Native American uprising (Nöel Hume 1982).

For archeological districts enter dates that relate to the significance of the district as a whole and not for individual resources unless the dates are also significant relative to the district. For many archeological properties, specific significant dates cannot be identified. If this is the case, enter "N /A." Radiocarbon, tree ring or other scientifically-determined absolute dates can be entered in this section. Note, however, that radiocarbon dates will be listed in the NRIS without their standard deviations.

SIGNIFICANT PERSON(S)

If an archeological property is being listed in the National Register under Criterion B (i.e., association with a significant person or persons), then this category should be completed. Enter the full name of the significant person, placing the last name first. If there is more than one significant person, list them in order of importance relative to the property's history. Do not enter the name of a family, fraternal group or organization. Enter the names of several individuals in one family or organization, only if each person made contributions for which the property meets Criterion B. Enter the name of a property's architect or builder only if the property meets Criterion B for association with that individual.

CULTURAL AFFILIATION

Cultural affiliation must be filled out when nominating a property under Criterion D. Cultural affiliation has been defined by the National Register to be "the archeological or ethnographic culture to which a collection of artifacts or resources (or property) belongs." For pre-contact archeological resources, "cultural affiliation" generally refers to a cultural group that is, in part, defined by a certain archeological assemblage and time period. For example, "Paleoindian," "Hopewell," "Hohokam," "Adena," and "Shoshonean" are commonly used cultural affiliation terms. Archeologists also commonly enter the archeological time period in this category; for example, "Early Archaic," "Late Woodland," and "Late Prehistoric," and "Proto-historic."

Archeologists who study the post-contact period usually are able to enter the ethnic identity of the group that occupied or used the property because the information is generally available through documents, oral histories, or comparative studies. For example, "Hawaiian," "Chemehuevi," Creek," "Irish-American," "Chinese-American," "African-American," "British," "Spanish," and "Dutch" are common cultural affiliation entries. Entries such as "Shaker" and "Mormon" are also used. When a historical property, such as a mining camp, cannot be linked to a specific cultural group, then the appropriate entry simply may be "Anglo-American" or "Euro-American" or even "American." Every effort should be made to complete the cultural affiliation section; however, if the cultural affiliation is unknown, enter "unknown."

ARCHITECT OR BUILDER

The name of the person(s) responsible for the design or construction of the property, if known, is entered in this category. The full name should be used. If the property's design derived from the stock plans of a company or government agency and are not credited to a specific individual, enter the name of the company or agency; for example, "Southern Pacific Railroad," "Sears," or "U.S. Army." Enter the name of property owners or contractors only if they were actually responsible for the property's design or construction. If the architect or builder is unknown, enter "unknown."

ASPECTS, OR QUALITIES OF INTEGRITY

The National Register criteria stipulate that a property must possess integrity of location, design, setting, materials, workmanship, feeling, and association. The National Register bulletin How to Apply the National Register Criteria for Evaluation directs that "integrity is the ability of a property to convey its significance" and "to retain historic integrity a property will always possess several, and usually most, of the aspects." (For further guidance, see How to Apply the National Register Criteria for Evaluation).

The evaluation of integrity is sometimes a subjective judgment, but it must always be grounded in an understanding of a property's physical features and how they relate to its significance. The retention of specific aspects of integrity is paramount for a property to convey its significance. Determining which of these aspects are most important to a particular property requires knowing why, where, and when the property is significant.

The importance of each of these aspects of integrity depends upon the nature of the property and the Criterion or Criteria under which it is being nominated. Integrity of location, design, materials, and association are of primary importance, for example, when nominating archeological sites under Criteria A and B. Design, materials, and workmanship are especially important under Criterion C. Location, design,materials, and association are generally the most relevant aspects of integrity under Criterion D. Integrity of setting within the site is important under Criteria A and B. Under Criteria C and D, integrity of setting adds to the overall integrity of an individual site and is especially important when assessing the integrity of a district. Integrity of feeling also adds to the integrity of archeological sites or districts as well as to other types of properties. Integrity of setting and feeling usually increases the "recognizability" of the site or district and enhances one's ability to interpret an archeological site's or district's historical significance.

Assessment of integrity must come after an assessment of significance:

Significance + integrity = eligibility.

To assess integrity, first define the essential physical qualities that must be present for the property to represent its significance.

Second, determine if those qualities are visible or discernible enough to convey their significance. Remember to consider the question of "to whom significance might be conveyed." For example, the significance of particular historic buildings may be apparent primarily to architectural historians but not to many individuals in the general public. Similarly, the significance of some properties may be apparent primarily to specialists, including individuals whose expertise is in the traditional cultural knowledge of a tribe. A property does not have to readily convey its significance visually to the general public; however, National Register documentation of the significance of a property should be written such that members of the general public can understand the property's significance and the physical qualities which convey that significance.

Third, determine if the property needs to be compared to other similar properties. This decision is made in light of the historic context(s) in which the property's significance is defined.

Finally, based on the significance and essential physical qualities, determine which aspects of integrity are vital to the property being nominated and whether they are present (See also the recommended sequence for evaluation under "Evaluating Sites in Context," in Section IV of this bulletin).

Solely meeting any aspect of integrity is not sufficient to meet eligibility requirements. For instance, just because most archeological sites retain integrity of location does not make them eligible. As the National Register bulletin How to Apply the National Register Criteria for Evaluation states,

To retain historic integrity a property will always possess several and usually most, of the aspects. The retention of specific aspects of integrity is paramount for a property to convey its significance. Determining which of these aspects are most important to a particular property requires knowing why, where and when the property is significant.

Archeologists use the word integrity to describe the level of preservation or quality of information contained within a district, site, or excavated assemblage. A property with good archeological integrity has archeological deposits that are relatively intact and complete. The archeological record at a site with such integrity has not been severely impacted by later cultural activities or natural processes. Properties without good archeological integrity may contain elements that are inconsistent with a particular time period or culture. For example, the contents of a thirteenth-century Native American trash pit should not contain artifacts indicative of a nineteenth-century American farmstead. Because of the complexity of the archeological record, however, integrity is a relative measure and its definition depends upon the historic context of the archeological property.

Aspects, or Qualities, of Integrity
Aspect/ Quality Definition
Location The place where the historic property was constructed or the place where the historic event occurred
Design The combination of elements that create the form, plan, space, structure, and style of a property.
Setting The physical environment of a historic property. Setting includes elements such as topographic features, open space, viewshed, landscape, vegetation, and artificial features.
Materials The physical elements that were combined or deposited during a particular period of time and in a particular pattern or configuration to form a historic property.
Workmanship The physical evidence of the labor and skill of a particular culture or people during any given perid in history.
Feeling A property's expression of the aesthetic or historic sense of a particular period of time.
Association The direct link between an important historic event or person and a historic property. Under D it is measured in the strength of association between data and important research questions.

 

Few archeological properties have wholly undisturbed cultural deposits. Often, the constant occupation or periodic reuse of site locations can create complex stratigraphic situations. Above-ground organization of features and artifacts may be used as evidence that below-ground patterning is intact. Because of the complexity of the archeological record and the myriad of cultural and natural formation processes that may impact a site, the definition of archeological integrity varies from property to property. For properties eligible under Criterion D, integrity requirements relate directly to the types of research questions defined within the archeologist's research design. In general, archeological integrity may be demonstrated by the presence of:

. Spatial patterning of surface artifacts or features that represent differential uses or activities;

. Spatial patterning of subsurface artifacts or features; or

. Lack of serious disturbance to the property's archeological deposits.

In addressing the presence of nineteenth-century farmsteads, archeologist John Wilson, for example, posed three sets of questions that are helpful in determining the potential archeological integrity of a given site or district (Wilson 1990):

. Are the archeological features and other deposits temporally diagnostic, spatially discrete, and functionally defined? Can you interpret what activities took place at the property and when they occurred?

. How did the historic property become an archeological site? Were the cultural and natural site formation processes catastrophic, deliberate, or gradual? How did these changes impact the property's archeological deposits?

. What is the quality of the documentary record associated with the occupation and subsequent uses of the property? Are the archeological deposits assignable to a particular individual's, family's, or group's activities?

Generally, integrity cannot be thought of as a finite quality of a property. Integrity is relative to the specific significance which the property conveys. Although it is possible to correlate the seven aspects of integrity with standard archeological site characteristics, those aspects are often unclear for evaluating the ability of an archeological property to convey significance under Criterion D. The integrity of archeological properties under Criterion D is judged according to important information potential. Archeological sites may contain a great deal of important information and yet have had some disturbance or extensive excavation (and, thereby, destruction). For example, sites that have been plowed may be eligible if it is demonstrated that the disturbance caused by plowing does not destroy the important information that the site holds.

photo of Gloucester Point, Virginia
Figure 17: Seventeenth-century foundations at Gloucester Point, Virginia help to demonstrate the archeological integrity of this district. (Virginia Research Center for Archaeology)
photo of Shea Site
Figure 18: At the Shea Site in North Dakota, the visibility of an exterior ditch and interior ditch (shown here) are evidence of the high integrity of this Northeastern Plains Village dating ca. A.D. 1400-1600. This site addresses questions of sedentism, defense, domestic plant use in the Red River region, and fluid cultural boundaries between the Plains and the Woodlands. (Michael Micholovic)

 

For example, survey has identified the first free African American settlement in the state, dating to the early nineteenth century. Few documentary records exist which document the site, therefore, most information about the settlement will be gained through archeological research. However, more than half of the site has been destroyed through previous development of the area. While the integrity of the site is questionable, the site may still be eligible under Criterion D for the important information it can provide about the free African American community in the state during this time period.

All properties must be able to convey their significance. Under Criterion D, properties do this through the information that they contain. Under Criteria A, B, and C, the National Register places a heavy emphasis on a property looking like it did during its period of significance. One of the tests is to ask if a person from the time or the important person who lived there, would recognize it. If the answer is "yes," then the property probably has integrity of materials and design. If the answer is "no," then the property probably does not. Keep in mind that the reason why the property is significant is a very important factor when determining what it is that the person should recognize. For example, if a plantation was best known for its formal and informal gardens and agricultural activities, then recognizable landscapes may be more important than recognizable buildings.

One of the most common questions asked about archeological sites and integrity is: Can a plowed site be eligible for listing in the National Register? The answer, which relates to integrity of location and design, is: If plowing has displaced artifacts to some extent, but the activity areas or the important information at the site are still discernable, then the site still has integrity of location or design. If not, then the site has no integrity of location or design.

A 17-acre multi-component camp site in the southeastern United States has been plowed continuously since 1965 to depths greater than the thickness of topsoil. Portions of some features remain intact and the property has horizontal integrity, with Archaic, Troyville and Plaquemine components somewhat co-mingled yet concentrated in different sections. The nomination states that "The nature and dispersion patterns of the artifacts from the various components indicate that the hill was primarily a scene of small scale and/or temporary activities. It was nevera large village occupied by numerous people. Therein lies a compelling reason for the site's importance." The site is significant in the lower Mississippi Valley partly because of the small scale occupation there. Small sites are not always evaluated because attention is paid primarily to large mound and village sites in the region. Important research questions would involve the relationship of this small hamlet/work camp to the larger mound sites and villages. The nomination points out specific research goals from the State archeological plan as well.

Sites that have lost contributing elements may retain sufficient integrity to convey their significance under Criterion D. For example, at a 25-acre mound site in the southeastern United States, of four mounds described in 1883, there is now one left associated with an extensive artifact scatter. Repeated surface collections were carried out to better understand the internal organization of the settlement. The nomination states that "On the basis of knowledge of similar sites, subsurface features such as cooking facilities, storage pits, and domestic habitations are likely to exist." One of the research domains likely to be addressed at this A.D. 600-1000 property, which was listed in 1995, concerns the study of the technology and social organization of craft production. The researchers expect to find evidence of rudimentary craft specialization in connection with the emergence of social inequality. At this major mound group, such crafts could have been used by the elite who could control access to or the production of craft items in support of their status.

LOCATION

The location of a property often helps explain its importance. Archeological sites and districts almost always have integrity of location. Integrity of location is closely linked to integrity of association, which is discussed below. Integrity of location would not necessarily preclude the eligibility of secondary or redeposited deposits in an archeological property. Integrity depends upon the significance argued for the property. Shipwreck sites best illustrate the subtleties of integrity of location.

EXAMPLES: The shipwreck comprises a ship that fought in a very important battle of the Civil War. Its significance is tied to only this battle.

. If the ship sank during the battle or in a place away from the battle site but the sinking was related to the battle, then the shipwreck still retains integrity of location under any of the criteria.

. If, for reasons unrelated to the battle, the ship sank in another location, then the shipwreck, no matter how intact it is, does not have integrity of location under Criterion A.

EXAMPLE: The above mentioned ship is also important because of its unique construction.

. If the ship's sinking is unrelated to its role in the Civil War, then the shipwreck may still be eligible for listing under Criterion C,because the location of the ship's sinking is unrelated to the importance of the ship's construction.

EXAMPLE: The shipwreck is a ship that was commanded by one naval officer from 1850 to 1870. It engaged in blockades, battles, and general transport. The naval officer is now recognized as one of the most important naval officers in the Civil War and an innovator of naval engagement techniques.

. No matter where the ship sank, it may still be eligible under Criterion B

Note that, as under Criterion A, integrity of location is usually a prerequisite under Criterion B. In this example, however, the property's significance is tied to an important naval officer and by nature, ships change location.

EXAMPLE: The shipwreck is a sailing ship that patrolled Maine's coast from 1840 to 1890. Its significance is tied to that function. It has statewide significance.

. If the ship later sank off Maine's coast or in an adjoining river or bay, then the ship has integrity of location under Criterion A.

. If the ship sailed to Florida in 1890 to serve as a private yacht and along the way sank off Cape Hatteras, then the ship does not have integrity of location under Criterion A.

EXAMPLE: Each of the above shipwreck examples have intact archeological deposits.

. If each of the shipwreck sites can yield important information through archeological investigations, then each, as a post-contact archeological site, has integrity of location under Criterion D .

EXAMPLE: The shipwreck is a ship that sank during a War of 1812 naval battle. Subsequent natural erosion and turbulence has since scattered the ship's structure and contents over at least a two square-mile area. Occasionally, divers find artifacts that are believed to be from the ship, but there is no discernable patterning of remains.

. The shipwreck has no integrity of location under any of the criteria, including Criterion D.

DESIGN

Elements of design include organization of space, proportion, scale, technology, ornamentation, and materials. It is of paramount importance under Criterion C and is extremely important under Criteria A and B. The word "design" brings to mind architectural plans and images of buildings or structures. Design, however, also applies to the layout of towns, villages, plantations, etc. For an archeological site, integrity of design generally refers to the patterning of structures, buildings, or discrete activity areas relative to one another. Recognizability of a property, or the ability of a property to convey its significance, depends largely upon the degree to which the design of the property is intact. The nature of the property and its historical importance are also a factor.

Under Criterion D, integrity of design for archeological sites most closely approximates intra-site artifact and feature patterning. For districts, inter-site patterning can be used to illustrate integrity of design.

EXAMPLE: The archeological site was a large 1890s horse farm that had a main house and office, many outbuildings, a race track, and paddocks. The horse farm is most noted for the innovative layout of its buildings and structures. Because its site plan proved to be especially efficient, all later horse farms in the area adopted the same design for placement of their buildings and structures. Because of the increased efficiency, horse farming surpassed crop-based farming and has served as the economic base for the region since 1900.

. If only the foundation of the main house and adjacent archeological deposits still exist, then the archeological site does not have sufficient integrity to qualify under Criterion A (or Criterion B if the property was owned and operated by an important horse breeder). The site may still retain sufficient archeological data on 1890s settlement and consumer behavior to nominate it under Criterion D.

. If this archeological site encompasses the entire horse farm complex and its significance can be conveyed from the patterning of the remaining building and structure foundations and track, remnants of paddock fence posts, intact road beds, etc., then the horse farm site likely has sufficient integrity of design under Criteria A and D, and perhaps C. If the horse farm was built and operated by a renowned horse breeder, then the property would qualify under Criterion B.

Keep in mind that the reason why the property is significant is a very important factor. For example, if a plantation was best known for its formal and informal gardens and agricultural activities, then the integrity of the landscapes may be more important than the integrity of the buildings.

EXAMPLE: The site was a 1790s mill site. Above-ground ruins, including the millrace and mill foundation, are present. The mill was the village's first and only industry, and the village grew up around it.

. If the site is in a 1950s subdivision and the creek is gone, then this archeological site lacks sufficient integrity of design under Criterion A.

. If the mill site is located within a small, relatively intact 1790s village and its importance in the early development of the village is evident given its placement relative to the neighboring 1790s buildings and the still flowing creek, then the archeological site has sufficient integrity of design under Criterion A. If it were associated with a miller important in the establishment and early development of the village, then the site would qualify under Criterion B.

SETTING

Setting includes elements such as topographic features, open-space, views, landscapes, vegetation, manmade features (e.g., paths, fences), and relationships between buildings and other features.

Archeological sites may be nominated under Criterion D without integrity of setting if they have important information potential. For example, if a site has rich and well-stratified archeological deposits dating from the 1690s to the 1790s but is located under a modern parking lot and between two modern commercial buildings, it will still qualify under Criterion D. In this case, the setting does not detract from the information potential of the site.

If a site's or district's historical setting (or the physical environment as it appeared during its period of significance) is intact, then the ability of the site or district to convey its significance is enhanced. If the setting conveys an archeological site's significance, then the site has integrity of setting under Criteria A and B. In order to convey significance, the setting should:

. appear as it did during the site's or district's period of significance; and

. be integral to the importance of the site or district.

photo of LSU Campus Mounds Site
Figure 19: The LSU Campus Mounds Site (16EBR6) is located on the campus of Louisiana State University in Baton Rouge. The site dates from 3000 B.C. to 2000 B.C. and is nominated under Criterion D as it has the potential to conribute to our understanding of Archaic lifeways. Even though the site's setting does not have integrity because it is physically surrounded by LSU structures and buildings, limited investigations have shown that the mounds are extremely well preserved. (Chris Hays)

 

EXAMPLE: The archeological district encompasses an area occupied by a Native American tribe during the Late Woodland period. Fifteen fishing camps are located on points of land that jut into the large lake and three villages are on high knolls overlooking the lake. These fishing camps and villages together represent Native American occupation and exploitation of the lake during the Late Woodland period. The economy was based on fishing and local trapping. The fishing camps and villages are represented by below-ground archeological deposits.

. If the natural environment around the lake and on the knolls appears similar to its Late Woodland appearance and the visitor can easily understand the significance of the sites and their relationships to each other and the lake and the surrounding knolls and can appreciate the Late Woodland lifeways of the Native Americans who lived there, then the district is eligible for listing under Criterion A.

. If modern cabins and large residences are near most of the fishing camps, high-rise structures line much of the lake shoreline, a shopping center is located on one of the three villages, and small play-ground parks are atop the other two villages, then this district does not have sufficient integrity for listing under Criteria A. In this scenario, Criterion D might be questioned.

MATERIALS

According to the National Register bulletin How to Apply the National Register Criteria for Evaluation, "the choice and combination of materials reveal the preferences of those who created the property and indicate the availability of particular types of materials and technologies." Integrity of materials is of paramount importance under Criterion C. Under Criteria A and B, integrity of materials should be considered within the framework of the property's significance.

Under Criterion D, integrity of materials is usually described in terms of the presence of intrusive artifacts/ features, the completeness of the artifact/feature assemblage, or the quality of artifact or feature preservation.

photo of Madison Buffalo Jump State Monument
Figure 20: The Madison Buffalo Jump State Monument in Gallatin County, Montana, shown in this aerial photo, exhibits excellent integrity of setting. The area includes a site identified for communal buffalo drives by pre-contact peoples over a period of at least 4,000 years. The pristine physical environment enhances the site's ability to convey its significance. (Rocky Rothweiler)
photo of the Melting Furnace Site
Figure 21: The Melting Furnace Site, part of the Estellville Glassworks Historic District, is in Atlantic County, New Jersey. Cemented with limestone mortar, it was constructed of sandstone and aggregated stone. All four walls of this structure were once pierced with large arched openings in brick. The site displays integrity of workmanship because of its standing wall surface, showing the brick arched colonnade. (Karen DeRosa)

EXAMPLE: The archeological site is a battery built by the Confederates early in the Civil War to blockade the Potomac River, which was Washington, D.C.'s primary supply route. The battery was formed by an intricate pattern of earthen berms shored up by wooden planks. Wood was also used to line the magazines and provide level platforms for guns. The wood is now gone.

. If the battery consists of earthen berms and depressions which show the configuration of the original battery and the location of gun platforms, magazines, etc., then this site has integrity of materials and is eligible under Criterion A.

. If the battery's earthen berms and depressions are indistinct because of erosion or other factors, then the site does not have integrity of materials under Criterion A.

WORKMANSHIP

Workmanship "is the evidence of an artisan's labor and skill in constructing or altering a building, structure, object, or site." It can apply to the property as a whole or to its individual components. Most often, integrity of workmanship is an issue under Criterion C. Under Criteria A and B, integrity of workmanship is important if workmanship is tied to the significance of the property.

Under Criterion D, workmanship usually is addressed indirectly in terms of the quality of the artifacts or architectural features. The skill needed to produce the artifact or construct the architectural feature is also an indication at of workmanship. The importance of workmanship is dependent on the nature of the site and its research importance.

EXAMPLE: The archeological site was a late eighteenth-century glass house that produced a unique kind of glassware. Rare silicates and an unusual melting technique were used to produce the unusual characteristics of the glass. The individual glass items were prized for their high quality and decorative styles.

. If the furnaces are still evident and activity areas where the com- ponent were processed and formed into vessels are discernable, then the site may have integrity of workmanship and be eligible under Criterion C. If the glass maker and owner of the glass house is well-known, then the property may be eligible under Criterion B.

FEELING

A property has integrity of feeling if its features in combination with its setting convey a historic sense of the property during its period of significance. Integrity of feeling enhances a property's ability to convey its significance under all of the criteria.

. If the site itself is still intact, but it is now surrounded by housing subdivisions and commercial buildings, then the site does not have integrity of feeling under Criterion A.

EXAMPLE: The archeological property was an early 1900s railway stop. It was located in the desert at a point were the railroad crossed one of the region's primary cattle trials. There were two nearby springs, structures to load cattle onto the rail cars, and a hinged, wooden sidewalk that could be realigned to accommodate the shifting sands. Camp sites were situated on a nearby knoll and adjacent to one of the springs. The closest town was 30 miles away when the site was used. This remote railway stop was vital to the surrounding ranches whose economy was based on cattle ranching.

. If the site is still in a remote area of the desert, and what remains at the site evokes a feeling of early cattle ranching days, then the site has integrity of feeling under Criterion A. The presence of the springs, remnants of the cattle-loading structures, segments of the hinged sidewalk following the railway tracks, and scattered rock-lined hearths, tobacco tins, solder tin cans, broken glass, etc., in combination with the site's remoteness, conveys feelings of times past.

. If the site itself is still intact, but it is now surrounded by housing subdivisions and commercial buildings, then the site does not have integrity of feeling under Criterion A.

ASSOCIATION

According to the National Register bulletin How to Apply the National Register Criteria for Evaluation, "a property retains association if it is the place where the event or activity occurred and is sufficiently intact to convey that relationship to an observer." Integrity of association is very important under Criteria A and B. The association between a property and its stated significance must be direct under these two criteria.

Under Criterion D, integrity of association is measured in terms of the strength of the relationship between the site's data or information and the important research questions. For example, a site with well-stratified archeological deposits containing butchered animal remains has information on subsistence practices over time. There is a strong association between the site's information and questions on subsistence practices. How to Apply the National Register Criteria for Evaluation, should be consulted for additional guidance on evaluating integrity.

EXAMPLE. The archeological property is an 1830s Cherokee settlement located in Georgia. The event or broad pattern of events under Criterion A is the removal of the Cherokee to Oklahoma.

. If soldiers invaded the settlement in 1839, taking the Cherokee prisoners and moving them into camps before marching them to Oklahoma, then the property is directly associated with the removal of the Cherokee to Oklahoma. The site has integrity of association under Criterion A.

. If the property was abandoned in 1835 because of disease and the Cherokee moved to another settlement several miles away, then the property probably has no direct association with the removal of the Cherokee to Oklahoma. The site does not have integrity of association under Criterion A.

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