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Celebrating National Accomplishments
Spring 1997, vol. 2(1)

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*  A Sense of Where We Are: One State's View of Federal Compliance Archeology

(photo) Archeologist excavating site in Springfield, Georgia.

"In the Southeast alone the number of recorded sites has gone from under 10,000 in 1970 to over 200,000 today [and] while modern field crews only rarely approach those of the New Deal era in size, the quantity and quality of the data far exceed that collected in earlier times."

David G. Anderson

by Joe Baker

No kidding, there I was just a few months back, a mid-level archeologist from the state historic preservation office seated at the front of a crowded municipal building meeting room, surrounded by the members of a township sewer and water authority, the township solicitor, a federal congressman, two state representatives, their respective staffs, and staffers from the offices of the commonwealth's U.S. senators. The township had, several months earlier, applied for two Corps of Engineers permits—for wetland encroachment and waterway obstruction—in order to run a water line to a community in dire need of dependable and safe drinking water. Our staff had reviewed the permit applications, as per the requirements of section 106 of the National Historic Preservation Act, and recommended an archeological survey based on our assessment of the topography, the soils, and the distribution of sites already recorded within the watershed. Somewhat reluctantly, the township paid for a consultant to conduct the survey, who encountered two stratified prehistoric sites—the first two clearly stratified floodplain sites in the watershed—both directly in the path of the proposed water line. We reviewed the consultant's report and recommended that the line be relocated to a less sensitive location or that the sites be assessed to see if they were important enough to be eligible for the National Register of Historic Places. Approximately a week after our review letter left the office, I found myself in the unfriendly confines of the township building attempting to explain the process, goals, and value of federal compliance archeology to the aforementioned audience. Tough crowd; it was a very long afternoon.

Whodunit: The Folly of Assigning Blame

Most of my colleagues in government, the private sector, and universities are well aware that the entire process of protecting our archeological heritage is at a critical crossroads. The 104th Congress came perilously close to "zeroing out" the Advisory Council on Historic Preservation, and federal and state political rhetoric decrying the very notion of protecting archeological sites is becoming commonplace. You have only to pay cursory attention to the diatribes on a variety of Web sites, or to backroom discussions at professional meetings, to realize that we have begun fighting among ourselves to pin the predicted downfall of compliance archeology on each other. The consultants blame the SHPOs for inefficiency, overregulation, lax enforcement, inexperience, and a variety of other sins too numerous to mention. The SHPOs and agency archeologists attack the consultants as mercenaries with little regard for the scientific and cultural value of the archeological record. The academicians fault SHPOs, agency staff, and the consultants for producing too little significant data for too much money. Government archeologists and consultants malign university departments for refusing to get their hands dirty with compliance work, for competing unfairly when they do, and for criticizing those on the front lines from the rarified air of academia. Meanwhile, as the bickering continues, urban and suburban sprawl, extractive industries, expanding infrastructure, looting, and natural processes threaten the nation's archeological heritage, and the taxpayers, through their legislators, are questioning the value of protecting it.

Clearly, it is time to band together as a profession, assess the accomplishments and shortcomings of the past 30 years, and strive to promote what we do well and improve what we don't. By expending our energy on deciding who is to blame for the hostility I encountered in that stuffy little township meeting room, we risk having a hand in the destruction of the past, and miss an opportunity to help save it.

The View from Here

Like many CRM archeologists, while I try to keep up with national issues and trends, I'm most familiar with the compliance archeology of my home state. I've been working as a SHPO review archeologist in Pennsylvania since 1989, a position that affords me a chance to see the results of virtually all compliance work. This work is conducted by 61 federal and state agencies, employing 107 different consulting firms in all of the state's varied physiographic regions, drainage basins, and ecological settings. The results of these investigations have improved our understanding of the past in some fundamental ways. The raw materials that constitute these improvements—site locations, technical reports, and collections—say much about the effort to preserve, manage, and protect the past in a typical eastern state.

While only 2,299 of the 15,982 sites in the Pennsylvania Archaeological Site Survey Files (about 14 percent) were recorded as a result of compliance archeology since 1966,1 that figure is quite deceptive. Pennsylvania has an enormous and enthusiastic community of avocational archeologists and private collectors, many associated with the Society for Pennsylvania Archeology and/or the Carnegie Museum's affiliate program. This amateur community has been actively recording sites in the state since the 1930s;2 thus the overwhelming majority of the list was recorded by non-professionals. But compliance archeology has only been conducted since 1966, and most of it in Pennsylvania dates from the early 1980s or later. Since 1980, consultants have recorded 25 percent of the new sites submitted to our office for inclusion in the PASS files. From 1990 to the present, 56 percent of the new sites have been registered by consultants working on compliance projects. From January of 1995 to December of 1996, of the 163 new sites entered in the PASS files, 125 of them (77 percent) came from compliance projects.3 This is a rather dramatic illustration of the changing face of archeology in Pennsylvania (and the United States), and the important role that compliance work plays in it. These consultant-recorded sites include every period from Paleoindian to the 20th century and every site type from tiny lithic scatters to multi-acre Woodland villages, to Colonial cemeteries, to 19th century farmsteads.

Approximately 2,277 technical reports document the results of investigations ranging from surveys of less than an acre to massive data recovery efforts. Without a doubt, most of the investigations conducted in Pennsylvania have been compliance projects. These reports are distributed to repositories at the Carnegie Museum in Pittsburgh and Temple University in Philadelphia, but by far the most complete collection is in the compliance report library at our office in Harrisburg.

To date, 807 collections, including hundreds of thousands of artifacts and their associated field records and photographs, have already been accessioned into the holdings of the state museum. Our best guess, arrived at by informally polling some of the federal agencies that have sponsored most of the work, indicates that this is certainly the very small tip of a very big iceberg.

For better or worse, it is evident that much of what we know about the archeology of Pennsylvania is a result of compliance projects, a statement that is probably true for many states.

Beyond sheer volume, compliance archeology in Pennsylvania has produced some of the most important research in the Middle Atlantic states, especially in the last 10 years. Consulting archeologists working in the state have made great strides in the areas of geoarcheology, site formation processes, and stratified site investigations. Pennsylvania currently has one of the best developed contexts for the evolution and development of alluvial landscapes in the East4 resulting for the most part from compliance projects. Monumental efforts at sites like Sandts Eddy5 and West Water Street6 have resulted in the discovery and investigation of buried components that date to the Middle and Early Archaic periods, changing forever our ideas about the relative scarcity of such sites and the notion of a Middle Archaic cultural hiatus.

Anyone driving anywhere in our state is aware that it is undergoing a wave of immense highway reconstruction and expansion projects, and some of these have added much to what we know about the distribution and function of many kinds of sites. The investigations associated with U.S. Routes 11 and 1579 and the Mon-Fayette Transportation Improvement Project10 have generated complementary data sets that become increasingly fine grained as the work moves from the reconnaissance of huge study corridors, through the assessment of a sample of sites from more intensively studied project alternatives, to the detailed pictures developed from a handful of data recovery excavations in preferred highway alignments. The investigation of important historic period sites like the First African Baptist Church Cemetery in Philadelphia11 or less well known sites like the Myers/Pickel Wagon Shop12 would never have occurred without the federal compliance program. In some ways, the real proof of the value of this compliance-generated data lies in the utilization by university-based researchers interested in every aspect of past human behavior from the evolution and development of complex societies13 to the technology and strategy of lithic procurement.14

A Pennsylvania perspective on the state of affairs in compliance archeology is the focus of an SAA symposium at the annual meeting in Nashville this year. The symposium will bring together some of the very best consulting archeologists and academic researchers working in the state for a frank discussion of where compliance archeology in Pennsylvania and the Middle Atlantic region has taken us and where we should go now.

Where We Ought to Be Going

If Pennsylvania's compliance archeology program is so successful, why were those folks in that township meeting room so upset? Bluntly put, because they thought it costs too much and because they had almost no idea what they were paying for, a common state of affairs in many parts of the country. The issues of the cost of compliance archeology and the limited dissemination of the results have to be successfully addressed if we are to answer the rather pointed questions being asked by the public, by their elected officials, and by federal land and program managers. And, as suggested earlier, we shouldn't waste too much time pointing accusatory fingers at each other; there's plenty of blame to go around.

While archeology by its labor-intensive nature will always be expensive, we can all work harder at minimizing costs. Tighter predictive modeling and project area assessment can result in fewer redundant surveys, and smaller, more tightly defined project areas. Negotiating easements and site avoidance, and working with engineers on the development of more sensitive project designs, can eliminate the need for some investigations altogether. Skilled volunteers and avocational archeologists may be able to play a larger role, and there are programs like the Forest Service's Passport In Time program that have already pioneered it. Dedicated funds, financed by small increases in permitting fees, could assist federal and state permittees in absorbing the costs of archeological investigations. Interagency agreements can help to channel and consolidate increasingly scarce agency resources into places where they can do the most good. Agencies, SHPOs, and consulting firms are all going to have to take long looks at their budgets, and eliminate unnecessary or duplicate costs. There are many other good suggestions for lowering the costs, but not the quality, of compliance archeology, and SHPO offices, agency archeologists, and consultants are all going to have to band together to address this issue. If we do not, I assure you that other solutions—solutions that will have devastating effects on the archeological record and our profession—will be imposed by constituencies that have the political power to do so and are not greatly troubled by the wholesale destruction of the past.

The problem of making the results of compliance archeology accessible to researchers and to the taxpayers is, perhaps, even more critical than the issue of costs. For at least a couple of very good reasons, it is quite likely that very few archeologists, and almost no members of the interested public, have ever heard of any of the truly landmark research I've cited above.

First, you can only find the technical reports on these projects in three repositories: Carnegie, Temple, and the SHPO office. They are not available electronically, and cannot be checked out of the repositories that keep them. Consequently they are very difficult for a professional or avocational researcher to access. In my opinion, a very large scale effort is warranted to make the results of compliance investigations available to researchers through electronic access and through all major research libraries. Without these data, some of the best minds in archeology today simply do not have access to the most current information, a state of affairs that would be regarded as intolerable in almost any other field of scholarly pursuit, and should be so regarded in ours.

Second, these are almost entirely very technical reports full of scholarly conventions, jargon, statistical analyses, inventories, and complex figures. While of great utility to professionals, they are bewildering at best to the average citizen, even to those with a real interest in archeology. For most of us, a project is complete when the collection and field records are curated and the final report is submitted. I submit that that's not good enough.

Like most of my professional brethren, I still find archeology to be just as fascinating as it was when I took my first undergraduate class. Judging by the popularity of television programs, videos, popular periodicals, and coffee table books on the subject, we're not the only people that feel that way. In the 12 days that we had our 1996 archeology month excavation at the City Island site in downtown Harrisburg, nearly 5,000 visitors stopped by for a look.

Every large-scale investigation for a public project deserves a publication, an exhibit, a video, or a presentation that is accessible to the public. We should all insist on it! None of us should ever get so jaded that we forget that archeology is first and foremost a satisfying and interesting pursuit, and when presented to the public in an accessible forum, it is irresistible. We don't need to save American archeology; if we just put it out there where people can see it, it will save itself!

Some Hopeful Signs

The angry rhetoric kept up in that township meeting room until 6 that evening. Finally a compromise was hammered out involving an easement to protect the bulk of both of the sites. The permits were secured, the water line proceeded on schedule, and everyone went home more or less satisfied.

In the end, we preserved two small links of the chain that binds all Americans to their predecessors, which is, after all, the aim of the federal compliance archeology program. Surely there's room for improvement, and we could all do with a bit less rancor and a bit more reason, but as the National Historic Preservation Act enters its fourth decade, Americans can take pride in how we care for our archeological heritage. Even in these difficult times, the system works, and the past is preserved for the future.

For more information, contact Joe Baker, Pennsylvania Bureau for Historic Preservation, P.O. Box 1026, Harrisburg, PA 17108-1026, (717) 772-0925, fax (717) 772-0920.


1. Pennsylvania Archaeological Site Survey (PASS). Harrisburg: Pennsylvania Historical and Museum Commission, Bureau for Historic Preservation, 1996.

2. Custer, Jay F. Prehistoric Cultures of Eastern Pennsylvania. Anthropological Series Number 7. Harrisburg: Pennsylvania Historical and Museum Commission, Bureau for Historic Preservation, 1996.

3. Pennsylvania Archaeological Site Survey (PASS). Harrisburg: Pennsylvania Historical and Museum Commission, Bureau for Historic Preservation, 1996.

4. Vento, Frank J., and Harold B. Rollins. Genetic Stratigraphy, Paleosol Development, and the Burial of Archaeological Sites in the Susquehanna, Delaware, and Upper Ohio Drainage Basins, Pennsylvania. With sections by Michael Stewart, Paul Raber, and William Johnson. Harrisburg: Pennsylvania Historical and Museum Commission, Bureau for Historic Preservation, 1990.

5. Bergman, Christopher A., John F. Doershuk, Larry R. Kimball, and Veronica Riegel. Archaeological Data Recovery for Transcontinental Gas Pipeline Corporation's 6.79 Mile Leidy Natural Gas Pipeline Expansion, Sandts Eddy Site (36 Nm 12) Northampton Cty, Pa. With sections by Philip LaPorta, Lucinda McWeeney, Roger Moeller, and Joe Schuldenrein. Cincinnati: The Cultural Resources Program, 3D/Environmental, 1996.

6. Custer, Jay F., Scott C. Watson, and Daniel N. Bailey. Data Recovery Investigations of the West Water Street Site, 36 Cn 175, Lock Haven, Clinton County, Pennsylvania. Philadelphia: Kise, Franks, and Straw, 1994.

7. Miller, Patricia. Phase I Archaeological Survey Report and Phase II Workplans, Safer Highways for Economic Development Project, SR 0011, Section 003, TR 11 and 15, Snyder County, Pennsylvania. Centre Hall, PA: Archaeological and Historical Consultants, 1992.

8. Miller, Patricia. Archaeological Data Recovery: Sites 36 Sn 220 and 36 Sn 221 and Additional Phase II Archaeological Survey: Site 36 Sn 21, Safer Highways for Economic Development Project, SR 0011, Section 003, TR 11 and 15, Snyder County, Pennsylvania. Centre Hall, PA: Archaeological and Historical Consultants, 1995.

9. Taylor, Randolph K. Phase I Archaeological Investigations, SR 0011, Section 001, Perry County, Pennsylvania. East Orange, NJ: Lewis Berger and Associates, 1990.

10. Skelly and Loy Consultants. Predictive Model for Archaeological Site Location, Proposed Mon-Fayette Transportation Improvement Project, Allegheny, Washington and Fayette Counties, Pa. Monroeville, PA: 1995.

11. Parrington, Michael, Daniel G. Roberts, Stephanie A. Pinter, and Janet C. Wideman. The First African Baptist Church Cemetery: Bioarchaeology, Demography, and Acculturation, of Early 19th Century Philadelphia Blacks. Philadelphia: John Milner Associates Inc., 1989.

12. Basalik, Kenneth J. Phase II Archaeological Survey of the Myers/Pickel Wagon Shop, 36 La 1218, Hessdale, Strasburg Township, Lancaster County, Pennsylvania, SR 0022, Section 012 Intersection Improvement Project. North Wales, PA: CHRS Inc., 1996.

13. Stewart, R. Michael."Clemson's Island Studies in Pennsylvania: A Perspective." Pennsylvania Archaeologist, vol. 60, no. 1 (1990), 79-107.