NATIONAL PARK SERVICE First Annual National Park Service Historic Preservation Conference

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*John Bond could not attend the conference, but submitted this paper for inclusion in this report.

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Hopefully, what I shall be saying about the relations between the Mid-Atlantic Region and the Denver Service Center will be regarded not as a list of gripes, but as an expression of some concerns with which we would like to acquaint representatives from the Service Center. Realizing that a major objective of this conference is to provide an open forum for bringing about a more effective execution of our historic preservation responsibilities and opportunities at the Park, Region, Service Center, and Washington levels, I should like to share with you some of my concerns and those of my colleagues in the Mid-Atlantic Region.

A. Communications

It is customary to rationalize most of the problems we have as resulting from poor communications. I think there is real justification in this rationalization, particularly as it involves the Denver Service Center-Mid-Atlantic Region relationships. I am sure that many problems or misunderstandings result from our not talking enough or not talking effectively with each other. I certainly realize that communication has to be in both directions and will admit that much of what I shall be saying should have been said before this time. While it is easy to say that the representative from Denver should have continued to touch base with the Regional Office and the Park, it is incumbent upon the Regional Professional to be equally responsible in keeping communication open.

There have been communications breakdowns that have frustrated us in the Region and in some instances managers in the Park. Notable along this line, is the manner in which we are notified of a proposed visit of a DSC representative to a given park. Too often the memorandum is received too late for anyone in Region to arrange to join the DSC representative in the Park. Sometimes, the information is received after the individual has come and gone. For example, there was a recent case where a DSC representative visited one of our Parks, made recommendations regarding restoration work going on there and committed the Park to doing certain things, including expenditure of funds. The Regional Office, the Superintendent and his key staff knew nothing about the proposal until it had been written and partially executed. If the DSC representative had touched base with the right person in Region, or in the Park, he could have gotten a more complete picture of what had transpired and what provisions, if needed, had been made to handle the matter of his concern.

B. Coordination of Efforts and Activities within the Service Center and with Regional and Park Staffs

There is a real need for more effective coordination of the efforts and activities within the Denver Service Center and Region and Park Staffs. As an example, sometimes we become aware of the Denver Service Center project involving one of our parks only after the report has been distributed by the Service Center for our review. Recently we received review copies of Environmental Assessments for Sewage Treatment Facilities in one of our Parks. Included in the assessment was an archeological evaluation of alternative sites. The non-Service Archeologist selected to do this is a competent professional and we take no exception to his being selected. The point is that the Regional Archeologist was not consulted as a co-evaluator of the investigator nor was he asked if archeological studies had been previously made of the areas involved. In a similar situation a study was contracted by the Denver Service Center for an archeological survey of an entire Park, one of our larger natural parks. The Regional Archeologist has been trying for years to get such a survey accomplished and had certain objectives he hoped to realize in this survey. The Region learned of the survey in the process of reviewing a study done by the investigator for one of the sewage treatment areas. Ordinarily formulation of a research project is a joint effort between the Park, Region and Denver Service Center. The Regional Archeologist who is quite familiar with the archeological resources in this park certainly could have given the investigator some direction. Subsequent to the by-chance learning of this project, the Regional Archeologist met with the consultant and shared with him his knowledge of the area. As a result of Regional involvement, late as it may have been, we feel the Park is receiving something closer to its needs.

Further in the area of coordination, there appears to be inadequate cross discipline in the reviewing of contracts and the specifications as they may effect historic buildings. It is discouraging to find specifications, for example, calling for the use of Portland cement on historic brick walls such as at Fort McHenry. It would seem that the professional reviewing this could have gotten that proposal deleted in the contract.

C. Scheduling the Volume of Work

Because research has been so closely related to construction, those areas having little or no construction have extreme difficulty getting badly needed research programmed. We realize, however, in this fiscal year $250,000.00 has been programmed service-wide for non-construction related research. Considering that this amount has to be spread throughout the Service and the tremendous overhead cost of a Denver Service Center project, that amount doesn't go very far. We would certainly hope that there could be a substantial increase in funds for non-construction projects and that more of this money be made available to the Regional Office for accomplishing under the supervision by Regional Professionals.

D. Professional Control during Execution and Review of Denver Service Center Product

An example of what I am talking about can be found in a recent Environmental Assessment for a sewage treatment plant at Shenandoah. The assessment contained standard sections that appear in many such assessments. One section in particular regards archeological and cultural resources. Using the standard phrase "In the unlikely event that archeological, historical, or paleontological resources . . ." the assessment infers that these resources are unlikely to be found, while in appendix B (archeological investigation) the professional investigator noted that the particular site under consideration was the most likely one to have cultural resources. The point is made here to emphasize the danger in using such standard phrases and not using an interdisciplinary review approach. Another example could be found in the plans for the fire detection system at the Moore House at Yorktown. The detection unit, looking similar to the bottom of a pie plate, is placed insenitively near the center of the ceiling. If the plans were properly executed in the first place it would not be necessary for Region and Park to point out these deficiencies. We realize, however, that there will be differences in opinions due to subjective element which is often involved. But, we in the Region are concerned with the tendency of some researchers, both historical architect and historians, to pursue their own interest without due regard to the needs of the Park as expressed on the 10-238. If there is any deviation from the initial proposal, it should be thoroughly discussed with the Park Superintendent or his representative and the appropriate professional in the Regional office. Furthermore, we would encourage a higher degree of collaboration as a project develops so as to avoid a misunderstanding at the end of the study.

E. Historic Structures Report-Reconciliation of Differences in Professional Judgments and Interpretation between DSC, Region and the Park

We have experienced some difficulty in reconciling different points-of-view, especially with regards to historic structures reports. First of all, we recommend a concerted effort be extended by all parties to resolve these differences satisfactorily before the historic structures report reaches the final stage. If these differences can not be so resolved, then the Region's position should become a vital part of the report and it should be a matter of record so that the different points of view may be jointly evaluated. Also, the Region should receive copies of all review comments regarding historic structures reports and research reports. This would enable the Region to determine if all comments are adequately considered before the report is put into final form. It should be emphasized that the Regional Director, for whom the work is being done, is the official having the authority to approve or reject the report.

F. Funding and Staffing

Many DSC projects are insufficiently funded to cover all aspects of a given project. Consequently, there is the necessity for the Regional Office to "bail out" DSC with funds and personnel. In a current project at Fort McHenry, there was no provision in the contract for archeological investigation. Yet, in the restoration of the Fort Walls archeological investigation was quite important to establish the drainage system behind the wall. Fortunately, the Regional and the Park together had two employees who were qualified to undertake this investigation. The contract should have allowed for this when the elements of the contract were established.

G. Master Plans and Interpretive Prospects and Their Inadequate Consideration of Policy

These documents often contain proposals that are obvious contradictions of current policy, or are not in keeping with current preservation philosophy. For example, proposals often call for unnecessary reconstruction or restoration of a building to a frozen period of history. We in Region must realize, also, that we sometimes get caught up in making similarly invalid proposals.