NPS-28: CULTURAL RESOURCE MANAGEMENT GUIDELINE

According to the NPS Management Policies, "The National Park Service will conduct a coordinated program of basic and applied research to support planning for and management of park cultural resources." Such mission-related research can identify and evaluate historic properties, advance knowledge of ethnographic resources and their importance to Native Americans, provide background data on park issues, contribute to interpretive programs, help avoid adverse impacts, and develop technologies for treating, monitoring, and protecting cultural resources. Research will be accomplished with the participation and review of professionals in all disciplines concerned with its subject.

Standards

• Research is mission-related and supports cultural resource management and interpretation; research unrelated to NPS requirements is not undertaken or funded by the NPS (but may be conducted by qualified independent investigators).

• Research adequate to support planning and legal compliance precedes final decisions about the treatment of cultural resources and about park development or operational activities that might affect them.

• Research is interdisciplinary.

A. Research Methodology

1. Task Directive

The first step in developing a research strategy is the task directive, which serves as the contract between management and the researcher(s). To ensure that the research will be mission-related, the task directive clearly states its purpose and scope and spells out issues to be resolved. It identifies the research team and its consultants. It outlines the specific steps to be taken and products to be prepared. It defines the level of investigation (see next page). It sets time limits and projects a research budget required to deliver specified product(s).

NPS center and support office specialists, the state historic preservation officer (SHPO), and interested Native Americans should be consulted in preparing task directives for complex or controversial projects.

(For more detail see Chapter 4 of the Planning Process Guideline [NPS-2].)

2. Research Design

The research design states the goals, methodology, and explicit assumptions of the researcher(s). It can be incorporated into the task directive or prepared separately. It should briefly summarize existing knowledge of the topic, identify research questions, and discuss the rationale for addressing them. It should provide for interdisciplinary study where appropriate, clearly defining relationships between disciplines. It should delineate the physical extent of the area to be investigated and the amount of information to be gathered. The methods to be used, such as documentary research, oral history, field investigation, excavation, destructive investigation, and anthropological fieldwork, should be discussed, and the expected results should be presented.

The same parties consulted on the task directive should be invited to comment on the research design, especially traditionally associated communities.

(For more detail see the Secretary of the Interior's Standards and Guidelines for Archeology and Historic Preservation [Appendix C].)

3. Documentary Research

In most cases documentary research should precede field work. Research beyond published sources should be explicitly defined in the task directive in keeping with a level of investigation meeting management needs. Service-wide inventories should be reviewed for pertinent information, and the SHPO and other federal and state agencies, as well as private agencies and sources, should be consulted.

4. Field Investigations

The primary purposes of field investigations are to identify resources, define their exact locations, obtain descriptive data, determine their integrity and condition, and evaluate their significance. With proper compliance, they may entail reconnaissance, sampling, excavation, physical examination of material, or anthropological study at whatever level of investigation is prescribed in the task directive.

(For more information on surveys see the Secretary of the Interior's Standards and Guidelines for Archeology and Historic Preservation; National Register Bulletin 18, How to Evaluate and Nominate Designed Historic Landscapes; National Register Bulletin 24, Guidelines for Local Surveys: A Basis for Preservation Planning; National Register Bulletin 30, Guidelines for Evaluating and Documenting Rural Historic Landscapes; National Register Bulletin 38, Guidelines for Evaluating and Documenting Traditional Cultural Properties; a joint NPS-Advisory Council on Historic Preservation publication, Identification of Historic Properties: A Decision-Making Guide for Managers; and an NPS manual, The Archeological Survey: Methods and Uses. See Chapter 10 of this guideline for guidance on surveying park ethnographic resources.)

5. Report

Once the documentary research and field investigation (including physical examination) are completed, the photographs, drawings, material samples, field notes, data files, and construction files are analyzed and interpreted in preparation of the final report. These research products also become part of the park information base and should be used as foundations for future research. They should be managed as museum collections. (See Chapter 9 of this guideline for archival management standards.)

Copies of the draft report will be submitted for review and comment to the park and to subject matter experts in and outside the NPS for peer review. Copies should also go to the SHPO, associated Native American groups, and other knowledgeable and interested parties for review and comment, if appropriate. At this time, the researcher should give presentations or training courses on his or her findings to the park's staff. The researcher will incorporate appropriate review comments in the final report, which must be approved by the superintendent or regional director.

The number of copies printed and distributed depends on the topic and park requirements. Minimum distribution is indicated in Appendix D; additional copies may be printed and distributed to other interested parties in and outside the NPS. (Publications distributed outside the Department of the Interior are generally subject to departmental review and approval via Form DI-550 before printing; printing coordinators are responsible for obtaining this approval.) The cluster coordinator lists the report in the NPS Cultural Resources Management Bibliography (CRBIB), a computerized, multidisciplinary inventory of professional reports, books, articles, and other publications addressing park cultural resources. Archeological reports should also be added to the Reports portion of the National Archeological Database. (For more information see the Cultural Resources Management Bibliography [CRBIB] User's Manual and the NADB User's Manual.)

Outside publication of reports in professional journals or books is encouraged.

Standards

• Research follows NPS procedures, including preparation of a task directive and research design, appropriate levels of documentary research and field investigation, and review and comment by the park and peer reviewers. The park superintendent or regional director approves all studies.

• Research conforms to the professional and ethical standards of related disciplines.

• Outside consultation and peer review provide opportunities for other professionals and interested parties to comment.

• An appropriate level of research precedes any NPS action that might reduce the research potential of cultural resources.

• Research results are timely and used to meet legal compliance and management decision requirements.

• Research designs provide for the confidentiality of sensitive information, including the location of archeological sites and sacred places and the names of local consultants.

• Final reports concerning history, historic structures, cultural landscapes, and museum objects generally conform in punctuation, footnote and bibliographic form, and other stylistic matters to the latest edition of A Manual of Style by the University of Chicago Press. (Footnotes are preferred, but endnotes are permissible.) Final reports in archeology are consistent with the style prescribed by the Society for American Archaeology. Formal reports in ethnography and cultural anthropology conform to the style prescribed by the American Anthropological Association.

• Final reports are reproduced in full and distributed within the timeframe established in the task directive. They and their findings are publicized in appropriate professional, technical, and popular publications and other media, with confidentiality ensured when appropriate.

• Object collections, field notes, sketches, plans, maps, photographs, computerized databases, and interview tapes and transcripts are properly curated and maintained as part of the park's museum collection and its information base, with confidentiality ensured when appropriate.

B. Resource Identification, Evaluation, and Registration

Section 110 of the National Historic Preservation Act requires park managers, in consultation with their SHPOs, to establish programs to locate, inventory, and nominate to the National Register of Historic Places all properties that appear to qualify. For archeological resources, the Service's systemwide archeological inventory program establishes requirements, standards, and priorities to assist parks in planning, programming, funding, and conducting archeological inventories. This program is tailored to the specific needs of each park cluster in a cluster-wide archeological inventory plan. (For further information see Chapter 6 and National Park Service's Systemwide Archeological Inventory Program [October 1992].)

Research to identify cultural resources should follow the research methodology described above.

Documentary research and field investigations help develop the park's inventory of cultural resources and the historic contexts for the area. The park's inventory includes all cultural resources (including those ineligible for the National Register) required for interpretation, planning, Section 106 and 110 compliance, resource protection, and monitoring. Historic contexts–historical themes delineated by time periods and geographic areas–are the frameworks within which individual resources can be evaluated. At Mammoth Cave National Park, for example, "Discovery and Early Uses of Mammoth Cave, 1798—1849" is a historic context. Once identified, cultural resources should be evaluated by applying the criteria of the National Register within historic contexts and listed in appropriate Service-wide inventories.

(For more information on historic contexts and evaluation, see the Secretary of the Interior's Standards and Guidelines for Archeology and Historic Preservation; National Register Bulletin 15, How to Apply the National Register Criteria for Evaluation; the NPS publication Revision of the National Park Service's Thematic Framework (1996); and specific state historic preservation plans.)

Properties believed eligible should be nominated to the National Register. In accordance with 36 CFR Part 60, parks will submit draft nominations to SHPOs and the NPS federal preservation officer, who will forward them to the National Register for review.

(For more information on nomination to the National Register, see the procedures in 36 CFR Part 60; the Secretary of the Interior's Standards and Guidelines for Archeology and Historic Preservation; National Register Bulletins 16A and 16B, Guidelines for Completing National Register of Historic Places Forms; and Appendix Q of this guideline.)

Historical parks of the national park system are automatically listed in the National Register upon their legal authorization. National Register nomination forms and boundary maps nevertheless must be prepared for them to document and delineate the resources contributing to their significance.

C. Service-wide Inventories of Cultural Resources

As cultural resources are identified and evaluated, they should also be listed in the appropriate Service-wide inventories of cultural resources. Copies of these inventories should be shared with the SHPOs.

1. Cultural Landscapes Inventory (CLI)

The CLI is a computerized, evaluated inventory of all cultural landscapes in which the NPS has or plans to acquire any legal interest. Its purpose is to identify cultural landscapes in the system and provide information on their location, historical development, character-defining features, and management. The CLI assists park managers in planning, programming, and recording treatment and management decisions. CLI forms, including maps, drawings, and photographs, are maintained at the support offices and the parks.

2. Cultural Sites Inventory (CSI)–Archeology and Ethnography (under development)

Information documenting location, description, significance or cultural meaning, condition, threats to, and management requirements of park archeological and ethnographic resources is compiled and maintained for all parks. The CSI provides necessary information for resource planning, interpretation, preservation, and protection. Consultation is required with traditionally associated groups. Original documents and records, including field notes, forms, reports, maps, and other related materials, will be developed and maintained at the support offices or archeological centers and the parks. Data are entered into the CSI-Archeology's computerized database. The Ethnographic Resources Inventory (ERI) database is in the initial planning stages.

3. List of Classified Structures (LCS)

The LCS is a computerized, evaluated inventory of all historic and prehistoric structures having historical, architectural, or engineering significance in which the NPS has or plans to acquire any legal interest. Included are structures that individually meet the criteria of the National Register or are contributing elements of sites and districts that meet the Register criteria. Also included are other structures–moved, reconstructed, and commemorative structures, and structures achieving significance within the last 50 years–that are managed as cultural resources because of decisions reached through the planning process. The LCS assists park managers in planning, programming, and recording decisions of appropriate treatment. LCS forms, including attachments, will be maintained at the support offices and the parks. The LCS data base may also be maintained at the park. (For more information see the List of Classified Structures [LCS] User's Manual [1993] and Chapter 8.)

4. National Catalog of Museum Objects

The computerized National Catalog lists all cultural objects and natural history specimens that meet the criteria for museum objects in the national park system. Museum Catalog Records (Form 10-254) are completed and filed in the parks with copies to the Museum Management Program in the National Center for Cultural Resources Stewardship and Parnership Programs. The catalog record contains collection and property management, documentary, and research data for the museum objects. (For more information see the NPS Museum Handbook, Part II, Museum Records [rev. 1984]; and the NPS Automated National Catalog System User Manual [1987].)

5. National Register of Historic Places

Authorized by the National Historic Preservation Act of 1966 and administered by the NPS in the National Center for Cultural Resources Stewardship and Parnership Programs, the National Register is the nation's official list of districts, sites, buildings, structures, and objects in both public and private ownership that are significant in American history, architecture, archeology, engineering, and culture. The National Register includes historical areas of the national park system, properties designated by the Secretary of the Interior as national historic landmarks, properties nominated by SHPOs and federal preservation officers, and cultural properties on the World Heritage List. The NPS is required by law to survey, inventory, and nominate to the National Register properties of national, state, and local significance in its custody that meet the National Register Criteria for Evaluation and to document to National Register standards its historical areas administratively listed in the Register. NPS nominations and documentation are submitted through the NPS federal preservation officer. Cultural resource studies that establish historic contexts and describe and evaluate historic properties can form the basis of National Register nominations when this information is transferred to nomination forms.

Cultural resources should be removed from the National Register, following specified procedures, if research reveals that they did not or do not meet the Register criteria. When resources formerly listed on the National Register have lost their qualifying integrity, the CLI, CSI, and LCS should continue to reference them but indicate their ineligibility.

D. Procedures for Established Areas

Even long-established parks may not have completed inventories of cultural resources. For example, archeological resources may continue to be identified and require addition to the Cultural Sites Inventory. Parks administratively listed in the National Register may never have been documented on National Register forms. The possible presence of previously unstudied resource types such as cultural landscapes and ethnographic resources may require additional data collection, new historic contexts, and further field investigations to initiate the Cultural Landscapes Inventory and update the Cultural Sites Inventory. Museum collections typically continue to grow.

Standards

• Each park has its cultural resources identified and evaluated, and those eligible are listed in the National Register and other appropriate Service-wide inventories.

• Historic contexts are developed for each park to assist in cultural resource evaluation and park planning.

E. Baseline Research Reports

Baseline research reports provide information that can serve a variety of purposes, from planning to interpretation. These reports should be completed before more specialized studies are undertaken.

1. Archeological Overview and Assessment

This report describes and assesses the known and potential archeological resources in a park area. The overview reviews and summarizes existing archeological data; the assessment evaluates the data. The report assesses past work and helps determine the need for and design of future studies. It is undertaken in a park or regional geographical framework and may be a part of multi-agency planning efforts.

2. Archeological Identification/Evaluation Studies

These studies identify the locations and some of the characteristics of all or a sample of archeological resources in a particular area. Data on these resources are added to the computerized CSI-Archeology database. Sufficient data are then collected and analyzed to evaluate the resources for the National Register. Information about the locations of all known archeological resources, the areas surveyed, and the level of intensity of the survey are shown on each park's cultural resource base map. These studies are frequently linked with archeological overviews and assessments to resolve management and interpretive concerns.

3. Ethnographic Overview and Assessment

This basic report emphasizes the review and analysis of accessible archival and documentary data on park ethnographic resources and the groups who traditionally define such cultural and natural features as significant to their ethnic heritage and cultural viability. Limited interviews and discussions occur with the traditionally associated people in order to supplement and assess the documentary evidence and identify gaps in the available data. (See Chapter 10 for other studies.)

4. Cultural Affiliation Study

Using anthropological, archeological, ethnohistoric, historic, and other evidence, this study satisfies the need to identify cultural ties among past and present groups that used and may still use or relate to park resources and park natural and cultural resources, including museum objects.

5. Historic Resource Study (HRS)

A historic resource study (HRS) provides a historical overview of a park or region and identifies and evaluates a park's cultural resources within historic contexts. It synthesizes all available cultural resource information from all disciplines in a narrative designed to serve managers, planners, interpreters, cultural resource specialists, and interested public as a reference for the history of the region and the resources within a park. Entailing both documentary research and field investigations to determine and describe the integrity, authenticity, associative values, and significance of resources, the HRS supplies data for resource management and interpretation. It includes the preparation of National Register nominations for all qualifying resources and is a principal tool for completing the Cultural Landscapes Inventory and the List of Classified Structures. The HRS identifies needs for special history studies, cultural landscape reports, and other detailed studies and may make recommendations for resource management and interpretation.

HRSs will vary in scope depending on management needs. Relevant information readily available in other sources need not be included except by reference. Additional HRSs are appropriate to address themes, resource types, and other subject matter not originally covered. Although the HRS is interdisciplinary in character, the principal investigator is usually a historian.

6. Cultural Resources Base Map

A base map (or maps) depicts all known historic sites and structures, cultural landscapes, long-distance trails and roads, and archeological and ethnographic resources. As additional resources are discovered they should be mapped. Documented troop movement maps may be included for battlefield parks.

7. Park Administrative History

This history, of particular value to managers, planners, and interpreters, describes how a park was conceived and established and how it has been managed to the present day. The park's legislative history and important issues in planning, land acquisition, development, public relations, and other topics of ongoing management concern are emphasized. (For more detailed guidance see National Park Service Administrative History: A Guide [1991].)

8. Rapid Ethnographic Assessment Project (REAP)

This field study, initiated before or as part of the scoping for general management or other park plans, provides basic planning and program evaluation information. The ethnographer organizes a research team, which includes NPS and community representatives, to collect and analyze data within four months or in accord with the planning schedule. (REAP does not substitute for the more thorough ethnographic overview and assessment or traditional use study.)

9. Scope of Collection Statement

This is the basic curatorial planning document required for all parks. Evolving from legislation and planning documents specific to each park, it guides a park's acquisition and preservation of those museum objects that contribute directly to interpretation and understanding of its themes, as well as any additional objects that the NPS is legally mandated to preserve. It defines the purpose and significance of the park's museum and archival collections; sets limits on collection size and quality by defining subject matter, geographical location, and time period for additions; and considers uses of the collection. Parks that do not have museum or archival collections and do not intend to acquire museum objects must submit brief scope of collection statements to this effect. (For more detailed guidance see the NPS Museum Handbook, Part I, Museum Collections, Chapter 2 [1994] and Appendix E [1996].)

F. Abbreviated and Specific Resource Studies

In some instances, conditions may prevent the completion of a full baseline report or study. The research methodology described in this chapter should nevertheless be followed, with a task directive and research design defining the scope and conduct of the research. Partial completion of a standard baseline report is preferable to the development of a new study type. Moreover, studies that address specific management needs should be organized within the context of a full baseline study. For example, a study on mining at Death Valley should recognize other historical themes and resources and meet the standard of a historic resource study. HRSs can be done in phases, years apart, with appropriate conceptual and contextual organization. Special history studies, which usually focus on single themes to provide data for interpretation, should follow comprehensive studies addressing a park's full array of themes and resources. (Section 110 of the National Historic Preservation Act requires inventory and evaluation of all cultural resources–not merely the most prominent or interpretable.)

Oral history collection is often combined with historic resource studies, archeological research, and ethnographic studies. It should follow standard professional methodology. Special attention should be placed on obtaining release forms from those interviewed and on proper care and maintenance of tapes. These materials should become part of the park's museum collection. (See Collecting, Using, and Preserving Oral History in the National Park Service [Harpers Ferry Center, 1984].)

Studies addressing specific resources in greater detail, such as historic structure reports, cultural landscape reports, historic furnishings reports, ethnohistories, ethnographic reports, and archeological data recovery studies, are described in the specific resource chapters.

Standards

• Each park has completed all relevant baseline reports.

• Reports, studies and other narratives, documented maps, drawings, photographs, and museum records of park cultural resources are prepared with sufficient accuracy and coverage to meet relevant planning and management needs.

G. Physical Documentation and Material Analysis

The primary purpose of physical documentation and material analysis is to confirm and enlarge upon earlier findings regarding the integrity and historical associations of structures, landscapes, sites, and museum objects. This type of research also improves understanding of conditions aiding the development of treatment recommendations. It is also used to record the significant attributes of a cultural resource before its modification or demolition. (For more information see the Secretary of the Interior's Standards and Guidelines for Architectural and Engineering Documentation.)

All documentation and material samples generated by this type of research are primary resources and should be handled according to the provisions outlined in the Museum Handbook. Every effort should be made to use non-destructive methods of analysis before using destructive ones.

Standards

• Historic structures and cultural landscapes are recorded in historic structure reports and cultural landscape reports. Analysis of archeological sites is recorded in archeological project completion reports and analysis of museum objects in object examination reports.

• Material samples, field notes, photographs, and drawings are curated following established procedures and deposited in appropriate museum collections.

• Research results are promptly reported to interested parties.

H. Qualifications of Researchers

Examples of selective or quality-ranking factors for cultural resource specialists in the NPS appear in Appendix E. Minimal qualifications appear in OPM Handbook X-118.

Whenever possible, contracting for research should strive for the best-qualified researcher, not the lowest bid. For most kinds of research, the best-qualified researcher is most likely to be found through the request for proposals (RFP) process. This process requires a scope of work to define the research and evaluation criteria to rank the researchers. (For more detail see contracting procedures.)

Management Policies encourages cooperative relationships with recognized educational and scientific institutions and qualified individuals to promote research serving park management objectives. Independent research pertinent to the broader contexts within which park resources exist is also encouraged. NPS facilities and assistance will be made available to qualified scholars conducting NPS-authorized research as long as park operations will not be impeded or park resources impaired.

Standards

• All research, whether conducted by NPS personnel, contractors, cooperative researchers, or independent researchers, is conducted by fully qualified personnel and conforms to current standards of scholarship.

• All cooperative and independent research conforms to NPS policies and guidelines.

I. Funding and Staffing

Each park with a research program should have at least one person responsible for developing it, monitoring the research, and seeing that the results are implemented in park operations. While support office and center staff provide expertise, the park is ultimately responsible for its own program. Funding and staff (FTE) should therefore be allocated for this position.

Research may be conducted by NPS employees in centers, support offices, and parks. It may also be conducted by contractors and cooperating parties as noted above. Planning for research should take into account the relative benefits and costs of using staff and outside researchers.

Research projects should be properly programmed on Form 10-238 and justified in the park's resources management plan.

Standards

• Adequate money and staff are sought and obtained to manage and carry out the park's research program.

• All NPS-funded research is identified, justified, and approved in the park's resources management plan.

• Project budgets cover the costs of cataloging, stabilization, and initial storage for field records, maps, objects, and specimens that are project-generated.