Cultural Resources in Wilderness Management

Wilderness management plans identify actions to be taken to preserve and improve the unique qualities of a particular wilderness. The cultural resource specialist works closely with the wilderness management team to ensure that cultural resources are considered in developing management plans and to establish appropriate levels of preservation for wilderness cultural resources.

This section of Archeological and Other Cultural Resources and Wilderness discusses common issues concerning management of cultural resources in wilderness areas that must be addressed when establishing appropriate levels of preservation.

Cultural Resources Legal Considerations

Wilderness cultural resources and treatments can contribute to and detract from other features of wilderness character, sometimes both simultaneously. However, until specifically identified during the development of the Wilderness Basics Building Block as degrading other qualities of wilderness, cultural resources within the boundaries of that wilderness are accorded the same consideration as park cultural resources located outside the boundaries (NPS Management Policy 1.4.2, 1.4.4 (2006)), and any further actions must comply with NEPA and NHPA. Legal mandates pertaining to historic preservation also remain applicable within wilderness but generally are administered in a way that preserves the area's wilderness character.

As decisional documents, wilderness management plans, resource management plans, and other plans pertaining to wilderness comply with NEPA, NHPA and other Federal laws, regulations, Executive Orders, and policies pertaining to cultural resources and human connections with the environment. Management decisions should be thoroughly documented.

Appropriate Levels of Cultural Resource Preservation

Just as an interdisciplinary team develops criteria for prioritizing cultural resources for planning purposes, appropriate levels of preservation must also be established for management purposes. When consistent with management goals or ANILCA, wilderness managers may maintain and improve cultural resources. (A number of unique provisions within the Alaska National Interest Lands Conservation Act (ANILCA) apply only to park units in Alaska, including wilderness areas within those units. Historic and non-historic buildings in Alaskan wilderness may be maintained for use and replaced if needed, for example.)

In general, the range of potential uses for cultural resources must be consistent with the Wilderness Act. For example, in wilderness areas:

• Cabins or other types of buildings cannot be rented to the public;

• Cultural resources cannot be preserved in anticipation of administrative needs in the future; and

• Cultural resources cannot be used to house formal museums, living history demonstrations, artist in residence use, summer camps, or any other residential use.

Any proposal to actively manage wilderness cultural resources must take into account both cultural resource values and contributions to wilderness character. Preservation of many cultural resources, particularly archeological resources and cultural landscapes, involves treatment of artifacts or individual elements. Preservation of ethnographic resources or cultural landscapes may not focus on tangible objects, but on preserving traditional practices or knowledge. The National Historic Preservation Act recognizes a range of actions that constitute historic preservation that include preservation of information about the cultural resource as well as preservation of the fabric of the resource (NHPA, Section 301(8)).

Depending on circumstances, and on a case by case basis, wilderness cultural resources may be preserved, rehabilitated, restored, reconstructed, relocated, or allowed to decay. Documentation of the cultural resources should always be carried out prior to any preservation activities. Before any decision about the continuing state of identified cultural resources in a wilderness area is implemented:

• The planning process must comply with all Federal laws, regulations, Executive Orders and policies related to cultural resources and human connections with the wilderness.

• Documentation consistent with the Secretary of the Interiors Standards is completed.

• A rigorous Minimum Requirements Analysis must be conducted.

More detailed discussion of considerations, caveats, and limitations for wilderness cultural resource management may be found in guidance produced by the NPS Wilderness Leadership Council for RM 41 - Wilderness Stewardship, (scheduled to be posted Winter 2017). Cultural Resources in Wilderness: Guidance for Considering and Managing Cultural Resources as Other Features of Value provides extensive wilderness-appropriate interpretations of treatment options for wilderness cultural resource management.

Documentation

Documentation is the act or process of inventory, identification, evaluation, and recording of the historic, archeological, architectural, and/or cultural value(s) fundamental to management and preservation of cultural resources. It may be the most appropriate form of preservation for particular cultural resources within a wilderness. Friends groups or other groups associated with the park or wilderness that wish to preserve cultural resources of note should be encouraged to consider the preservation of information as one of the most lasting memorial actions.

Depending on the resource, one of the following documentation standards may apply:

• Secretary of the Interior's Standards for Architectural and Engineering Documentation;

• Secretary of the Interior's Standards for Archeological Documentation;

• Secretary of the Interior's Standards for the Treatment of Cultural Landscapes.

Within the NPS, cultural resource specialists with expertise in documentation may be found at the park, regional, or national level. Each NPS region has a HABS/HAER/HALS coordinator who can assist in developing documentation projects for structures and installations. Contact information may be found on the HABS/HAER/HALS website.

Formulation of the documentation project should be entered in PMIS as soon as the need is identified.

Cultural Resource Treatments

The integrity of archeological resources is protected by the Archeological Resources Protection Act and the Antiquities Act but in particular cases decisions may be made to actively preserve other cultural resources. The Secretary of the Interior's Standards for Treatment of Historic Properties include four types of treatment that are briefly discussed here: preservation, rehabilitation, restoration, and reconstruction. The standards are not technical or prescriptive, but are intended to promote responsible preservation of cultural resources.

Each treatment regime may impact wilderness character on a short term or long term basis, both through the results of the treatment application and through the ways by which it is applied. All decisions must be thoroughly documented through a rigorous minimum requirements analysis.

Preservation is the act or process of applying measures necessary to sustain the existing form, integrity, and materials of a historic property. It emphasizes the retention of historic fabric through ongoing maintenance, and repair. It is the most conservative of the four treatments. Preservation aims to maintain ongoing integrity of a cultural resource.

Rehabilitation is the act or process of making possible a compatible use for a property through repair, alterations, and additions while preserving those portions or features which convey its historical, cultural, or architectural values. It emphasizes retention and repair of historic materials, with limited replacement of elements that are deteriorated for preservation of those portions of features that convey historical, cultural, or architectural values. Rehabilitation promotes the maintenance of the aspects that are of cultural significance.
Restoration is the act or process of accurately depicting the form, features, and character of a property as it appeared at a particular period of time by means of the removal of features from other periods in its history and reconstruction of missing features from the restoration period. It returns a historic property to its appearance during a specific time in the life of the property. Restoration may require significant onsite activity, including removal of parts, and construction of replacement parts, activities that may degrade other wilderness qualities.

Reconstruction is the act or process of depicting, by means of new construction, the form, features, and detailing of a non-surviving site, landscape, building, structure, or object for the purpose of replicating its appearance at a specific period of time and in its historic location. It re-creates a non-surviving cultural resource with all new materials. Any proposal to reconstruct historic properties within the boundaries of a wilderness must be carefully considered, as NHPA (and NEPA) are procedural laws and do not mandate a particular outcome for the Section 106 process, including reconstruction. These laws do not require reconstruction of cultural resources.

Passive Preservation, Relocation, and Demolition

Not all wilderness cultural resources may be actively managed, and some may not even be preserved. Depending on specific circumstances that include the nature of the cultural resource, management goals, feasibility, the anticipated continuing effects of climate change, or budgetary constraints, decisions may be made to allow or actually hasten the deterioration of cultural resources in an individual wilderness area. For example, a cultural landscape composed of agricultural fields may be returned to forest. These management actions are not forbidden by NHPA, but may be determined to be an adverse effect.

Decisions to allow cultural resources in wilderness to be altered are supported by the Secretary's Standards for Federal Agency Historic Preservation Programs. Decisions are finalized only after NHPA Section 110 inventory and identification of resources, a National Register Determination of Eligibility, documentation, and the Section 106 process are completed. Such decisions must be consistent with a Minimum Requirements Analysis, and NPS policy. If removal or no active management is determined by the NPS and the SHPO or THPO to be an adverse effect, a Memorandum of Agreement with the SHPO or THPO will be needed prior to implementation.

Passive Preservation may include no active management of a cultural resource beyond documentation. It is a purposeful decision to refrain from interfering with natural processes that promote loss of material integrity.

Relocation Cultural resources within wilderness may be relocated outside of wilderness boundaries in order to better preserve the resource or to improve wilderness character. The cultural resource may also be moved to another location within the boundary. Relocation may affect National Register eligibility status, although the cultural resource may continue to be an important park resource.

Demolition is the intentional destruction of a heritage resource. Removal may involve destruction or transportation of a heritage resource to a location outside of wilderness boundaries. Specific cultural resources may be found to strongly affect qualities of a particular wilderness in a negative manner, and passive preservation will not achieve a goal of integration with the landscape in a desirable amount of time. Removal justification may include visitor safety; standing structures that are not maintained can become structurally compromised, for example.