NPS-28: CULTURAL RESOURCE MANAGEMENT GUIDELINE

The national park system is composed largely of parks established for the significance of their resources. In creating the National Park Service, Congress directed it to preserve these resources. Resource preservation is the paramount charge to park managers and the focus of park operations.

A park's resources may vary widely. Few parks established primarily for their cultural values lack natural resources, and nearly all parks established for their natural resources also have cultural resources. At Yellowstone National Park, Old Faithful Inn is a national historic landmark. Indiana Dunes National Lakeshore contains both a national historic landmark (Bailly Homestead) and a national natural landmark (Cowles Bog). Cultural landscapes always comprise both natural and manmade elements. Museum collections, whether they contain cultural or natural items, are managed as cultural resources. Many ethnographic resources are natural objects or features.

Sometimes cultural and natural resource interests conflict, as when unwanted vegetative growth threatens to impair a historic structure's integrity or intrudes upon a cultural landscape. Safety, accessibility, and other operational concerns often enter the resource preservation equation. The most important management measures directly affecting cultural resources are controlled by park superintendents. With understanding of their parks' purposes, NPS policies, and the resources in their custody, managers can respond effectively to competing pressures and needs and good resource management can take place.

Standards

• Pending planning decisions, cultural resources are preserved and protected in their existing forms.

• Every treatment project is supported by an approved proposal, plan, or report appropriate to the proposed action.

• The appropriate level of Section 106 compliance is accomplished before executing a treatment project.

• Sufficient lands and interests in lands are acquired to ensure protection of cultural resources associated with a park's purpose.

A. Visitor Experience

A park, according to standard dictionary definitions, is a tract of land set aside for public recreational use. If resource preservation were the sole objective or an end in itself, Congress would have established something other than parks and a park service to manage them. Instead, in the 1916 act creating the NPS, it directed that the special resources in these reserved lands be conserved for public enjoyment then and thereafter.

The legal mandate to both conserve and provide for public enjoyment seems to hold potential for conflict. In fact, the Service's primary responsibility is clear. It may provide for public enjoyment of park resources only "in such manner and by such means as will leave them unimpaired for the enjoyment of future generations." In other words, preservation takes precedence.

The NPS will continue to provide campgrounds, roads, picnic areas, visitor centers, hiking trails, and concession facilities and services to help visitors enjoy park resources. In planning for needed facilities and in providing for visitor use activities, good managers will not subordinate resource preservation to "better" visitor experiences. Rather, they will ensure that visitor facilities and activities are compatible with the preservation of resources and with an atmosphere conducive to their appreciation.

1. Interpretation

Interpretation, the public face of the National Park Service, can be a powerful tool for the preservation of cultural resources. To make it serve this purpose, interpreters must be well-versed in both the significance of their parks' resources and the Service's policies, standards, and guidelines for managing them. By communicating why resources have been set aside and should be preserved along with the "park story," interpreters can enlist more stewards in their protection. (See the Interpretation Guideline [NPS-6], particularly Chapter 1, "Role and Responsibility of Interpretation," for further discussion of this topic.)

This sort of interpretation should not be limited to visitors. Interpretation directed to NPS employees can increase awareness of the centrality of resource preservation to the national park system. This, in turn, can foster a stronger preservation ethic within the Service by developing a better understanding of what it is trying to accomplish and why. Interpretation directed to and involving park neighbors and others, including indigenous people, with special interests in parks can foster mutual respect, help build partnerships, and contribute to achieving preservation goals.

2. Accessibility

NPS Management Policies (5:14) prescribes "the highest feasible level of physical access for disabled persons to historic properties, consistent with the preservation of the properties' significant historical attributes." It sanctions "some impairment of some features" to provide access but directs that modifications "will be designed and installed to least affect the features of a property that contribute to its significance." The NPS, as a federal agency, is subject to the Architectural Barriers Act of 1968, Section 504 of the Rehabilitation Act, and their implementing regulations and guidelines. Thus, the Uniform Federal Accessibility Standards (UFAS; 41 CFR 19.6; 49 FR 31528) guide accessibility modifications to historic structures in the national park system. The procedures outlined in UFAS (UFAS 4.1.7) will be followed when preservation and accessibility interests conflict. Because park concessioners are private businesses acting as agents of the NPS, access to their facilities is governed by the Architectural Barriers Act, UFAS, and the Americans with Disabilities Act (ADA) of 1990 (P.L. 101-336) and its implementing ADA Accessibility Guideline (ADAAG). Where provisions of UFAS and ADAAG differ, the more stringent requirement will apply. The provisions of ADAAG also apply to those few in-park private commercial activities whose purpose is not primarily to serve park visitors; some activities carried out under the historic property leasing program may fall in this category.

Although UFAS and ADAAG address structures and their immediate environs, the spirit of the standards should also be applied in planning access to cultural landscapes, archeological sites, and historic trails, consistent with Management Policies (9:3). (See also Accommodation of Disabled Visitors at Historic Sites in the National Park System, 1983.)

B. Facilities

1. Park Design

Well-executed design sensitive to the cultural and natural environment is essential to protect cultural resources and their settings and to develop and maintain a harmonious overall park scene that meets contemporary needs. The goal of park design is to provide for new facilities or new or changing uses of historic properties while maintaining harmony and continuity with those special visual and cultural features that create a sense of time and place unique to each park.

While design standards like those in the Housing Design and Rehabilitation Guideline (NPS-76) and generic structure designs are intended to ensure a Service-wide quality level, project-specific design should reflect the cultural, regional, and aesthetic values of each location. Elements to be considered in the park design process, particularly when development takes place in or near cultural zones, include scale, texture, continuity of architectural style or tradition, physical and visual relationships, and consistency with the Secretary of the Interior's Standards for Treatment of Historic Properties and other management standards in this guideline. Properly executed design and development defers to the cultural landscape.

2. Maintenance Management, ICAP, and Preservation Maintenance

Continuing preservation maintenance is the stewardship key to protecting the integrity of cultural resources and the investments made to bring them to maintenance condition. Further, continuing preservation maintenance is the surest way to avoid large future outlays of project money. A well-planned and executed maintenance program is an essential part of a park manager's performance.

The NPS Maintenance Management (MM) program includes the planning, organizing, directing, and controlling of maintenance activities. The computerized implementation program, Maintenance Management System (MMS), also provides information to higher management levels, permitting accomplishments to be identified and needs to be articulated on a Service-wide basis.

The Inventory and Condition Assessment Program (ICAP) module of the Service's MM program provides those managing maintenance activities, including preservation maintenance, with information on a park's assets and their condition. The Historic Property Preservation Database provides work procedures. These tools enable managers to develop goals for a park's maintenance program, prepare a preventive maintenance program, set priorities, and allocate resources to achieve those goals based on objective information. ICAP also develops data for the MM program to identify major deficiencies hindering achievement of the park's goals. (For further information see the Inventory and Condition Assessment Program Reference Manual, 1993.)

Standards

• Each park implements the Inventory Condition and Assessment Program for all historic resources.

• Each park completes and follows its Historic Property Preservation Database work procedures; pending the completion of such procedures, preservation treatment is conducted according to the maintenance standards in Chapter 8 of this guideline.

• Each park prepares and implements an annual maintenance schedule identifying work to be done and funding and personnel needed.

• Housekeeping, routine, and cyclic work mitigating wear and deterioration are accomplished without altering the appearance or basic material of cultural resources.

• Repair or in-kind replacement of deteriorated features is undertaken to keep the existing appearance and function of cultural resources.

• Stabilization work necessary to protect damaged historic material from additional damage is accomplished.

• Action is taken to prevent damage to and minimize deterioration of museum objects by practicing preventive conservation or performing suitable treatments.

• All preservation maintenance work is consistent with the Secretary of the Interior's Standards for Treatment of Historic Properties and other management standards in this guideline and is carried out following applicable requirements of Section 106, 36 CFR Part 800, and the 1995 Servicewide Programmatic Agreement.

3. Energy Conservation and Historic Preservation

Law and regulation require that federal agencies reduce energy consumption. Following energy surveys, strategies for retrofitting historic structures and other structures containing museum property for energy conservation will be developed. The nature of energy reduction measures will be determined on a case-by-case basis. When energy conservation and historic preservation mandates conflict, means to ensure the preservation of historic material and character will be developed.

Because retrofit measures can cause irreparable damage to the material and character of historic structures, plans for such measures must be reviewed by a historical architect. Revised operating procedures and modifications to existing mechanical systems will be considered before measures involving intervention in historic material or affecting historic character.

Examples of concerns include the installation of storm windows and doors, which may impair a historic structure's character. Blown-in or foam insulation may cause excessive condensation in walls or be a health hazard and should not be used. (See the Department of the Interior's Energy Survey Manual [1979], Ch. M, p. 8.)

Any action that will affect the temperature, relative humidity, light, or air quality in a historic structure containing historic furnishings or other museum objects must be considered in light of the effect it will have on both the structure and its contents. When the preservation needs of a historic structure and its contents conflict, means of ensuring that neither are unacceptably compromised must be developed. A curator and a historical architect are the primary professionals charged with developing resolution alternatives in such situations. Such alternatives may take into account the relative portability of the structure's contents. A curator will always review plans for retrofitting projects when museum property is involved.

In reviewing proposed retrofit actions, historical architects and curators will consider whether (1) the evaluation of effect for compliance purposes is adequate; (2) the proposed action is planned and will be conducted in accordance with relevant management policies, guidelines, and standards; and (3) the proposal incorporates all feasible measures to minimize any adverse effects on cultural resources.

4. Commemorative Works and Plaques

A commemorative work or plaque will be placed in a park only when authorized by Congress or approved by the director (36 CFR 2.62) or the official to whom approval authority has been delegated. Review of a proposed commemorative work or plaque will consider such things as the appropriateness of the site and the design, inscription, and materials of the feature to ensure that it will be compatible with its setting and the park's purpose, accurate, and easily maintainable. (For further guidance see Management Policies, 9:17.)

C. Protection

The protection of people and the protection of resources are the primary concerns of park management. Both require careful planning. When conflicts between the two arise, good judgment is necessary to resolve them. Resolution should avoid actions compromising the integrity of cultural resources and their settings. Harmful or intrusive measures may often be obviated by changing existing or contemplated uses of resources or by restricting access to them.

1. Safety

"The saving of human life will take precedence over all other management actions" (Management Policies, 8:5). This unequivocal policy statement is the starting point for all planning and operations involving visitors and employees. Both the Management Policies and the Loss Control Management Program Guideline (NPS-50) recognize that public use of park resources sometimes involves elements of risk. Both recognize the need for management actions to limit risk to acceptable levels, consistent with acceptable levels of impact on cultural resources. Where modifications necessary to make a cultural resource safely accessible would unacceptably compromise its significant qualities, the resource will be closed to public access.

The Loss Control Management Program Guideline directs each park to have a documented safety program and outlines a methodology of inspection and hazard abatement. The principles of the risk assessment process outlined in the NPS Museum Handbook, Part I, Museum Collections (Chapter 9 [1996] and Appendix G [1996]), also apply to safety concerns. An objective risk assessment process involving loss control, cultural resource, and management expertise will help ensure that both safety and cultural resource concerns are carefully considered and that informed decisions are made.

Reaching informed decisions can be complex. For example, Navajo culture dictates that a hogan in which someone has died be abandoned. In time it will deteriorate and become a safety hazard. It will also become a cultural resource that is losing integrity. The loss control perspective would be to demolish the hogan. The normal cultural resource management perspective would be to stabilize it for preservation and public access. From an ethnographic perspective, either course would be inappropriate because it would interfere with a cultural tradition that should be respected. From this perspective the proper course would be to restrict public access and allow the hogan to deteriorate. This case illustrates the need for full knowledge of resources and interdisciplinary involvement in decision-making.

2. Physical Security

Providing for the physical security of cultural resources is an essential part of their stewardship. Prevention, the best form of protection, is the focus of an effective park crime prevention and physical security plan. In developing such plans and implementing designs, sensitivity to cultural and natural museum property, historic materials, character, and setting is vital. The installation of alarms, locks, fencing, and other security devices in archeological sites, cultural landscapes, and historic structures should follow careful consideration of their physical and visual impacts in consultation with historical architects, historical landscape architects, archeologists, and curators as appropriate. (For further guidance see the Law Enforcement Guideline (NPS-9), Section III, Chapter 7, and the NPS Museum Handbook, Part I, Museum Collections, Chapter 9.)

3. Law Enforcement

Because law enforcement and protection rangers carry the primary responsibility for enforcing laws and regulations in the parks, they must be kept aware of the protection needs of cultural resources. It is recommended that rangers complete the forty-hour Archaeological Resources Protection Act course. In addition, involving rangers in planning activities related to cultural resources will help them better understand their archeological resources protection responsibilities and help prevent or reduce risks to resources from criminal activity. (For further guidance see the Law Enforcement Guideline and the NPS Museum Handbook, Part I, Museum Collections, Chapter 9 [1996] and Appendix G [1996].)

4. Archaeological Resources Protection Act and Antiquities Act

The Archaeological Resources Protection Act (ARPA) authorizes a permit system for investigating archeological resources at least 100 years old on public and tribal lands. It also establishes penalties for excavating, removing, or damaging such resources without authorization. Resources removed and vehicles and equipment used in connection with a violation are subject to forfeiture. The act permits information about the location and nature of archeological resources to be kept confidential, as does Section 304 of the National Historic Preservation Act. Training in the act and its regulations should be given to rangers, archeologists, managers, and others involved in their enforcement and implementation. The act also calls for the establishment of a program to increase public awareness of the significance of archeological resources.

The Antiquities Act provides legal protection for archeological resources not covered under ARPA (generally, archeological resources less than 100 years old).

(For further guidance see the Law Enforcement Guideline; 43 CFR Part 7, Protection of Archaeological Resources; and 43 CFR Part 3, Preservation of American Antiquities.)

5. Emergency Management

From time to time emergencies arise in parks, centers, and other locations with cultural resources. Staffs must respond to avert disaster, protect life and property, and restore order with the goal of resuming normal operations as quickly as possible. Emergency operations plans (EOPs) can help them do so.

Managers should thoroughly consider the protection of cultural resources when preparing EOPs. EOPs should identify the potential threats to cultural resources and prescribe ways to mitigate against, respond to, and recover from them. Cultural resource specialists should be included on incident management teams. Staff responsible for EOP preparation and cultural resource protection should become familiar with the following policies, guidelines, and procedures as part of their planning efforts:

Departmental Manual, 485:1.1, "Safety Management."

Management Policies, Chapter 8, "Emergency Preparedness and Emergency Operations."

Loss Control Management Program Guideline for various safety and occupational health issues.

Museum Handbook, Part I, Museum Collections, Chapter 9, "Museum Collections Security and Fire Protection" (1996), and Chapter 10, "Emergency Planning."

6. Land Acquisition and Management

To best protect the cultural resources for which it is responsible, the NPS should have management control over a land base sufficient to prevent changing uses outside the sphere of management control from degrading the resources. Interests acquired can range from fee simple title to restrictive easements, depending on what is deemed necessary to accomplish preservation and protection goals. Park land protection plans will identify the lands and interests needed to protect cultural resources.

Protection of cultural resources in newer, partnership parks calls for a variety of approaches including technical assistance to property owners and working with local planning and zoning authorities.

Archeological resources, historic structures, cultural landscapes, and submerged cultural resources on lands subject to easements, occupancy agreements, or state ownership should be maintained in a manner consistent with the purposes for which the lands or easements were acquired. Agreements for such properties needing stabilization or rehabilitation should contain provisions for bringing them to a maintenance condition and maintaining them to standard.

When a state maintains ownership of submerged lands in national parks, it generally also maintains ownership of submerged archeological and historic resources, including abandoned shipwrecks and hulks. These resources should be protected and maintained for scholarly research and public enjoyment. Agreements between the NPS and the state should specify how such state-owned resources are to be managed. For further guidance see the NPS's Abandoned Shipwreck Act Guidelines (55 FR 50116, Dec. 4, 1990; 55 FR 51528, Dec. 14, 1990; 56 FR 7875, Feb. 26, 1991).

7. Pest Management

Integrated pest management (IPM) is the environmentally sensitive NPS program for dealing with unwanted and destructive plant and animal pests, some of which threaten park cultural resources. Management Policies (4:13-14) makes clear that dealing with such pests is a balancing act requiring close cooperation between cultural resource and IPM specialists. The goal is always to avoid unacceptable harm to both cultural resources and their environment. Guidance in developing and implementing an IPM program is contained in the Natural Resources Management Guideline (NPS-77) and NPS Museum Handbook, Part I, Museum Collections (Chapter 5).

D. Fire Management

1. Structural Fire

A structural fire plan treating prevention, detection, and suppression, including special procedures for fighting fire in historic structures and structures housing museum property, is required for each park. Pre-suppression planning should be a cooperative effort involving all agencies that would be involved in fire suppression. Because the best-managed fire is the one that didn't happen, fire plans should stress fire prevention. Fire prevention planning should consider lightning protection systems. Fire detection and suppression systems are key ingredients in long-term planning for protecting cultural resources from fire. Fire-fighting procedures acceptable for most structures may need to be modified to ensure maximum protection of cultural resources. Staff charged with developing fire prevention and fire-fighting plans and cultural resource specialists should consult closely when plans for historic structures or those housing cultural resources are developed. They should consider the variety of sources historically causing fires in the types of structures for which the plans are being written and develop specific procedures and training for fighting them. Those in and outside the Service who will be called upon to fight fires should be made intimately familiar with the structures and their contents and be given frequent refresher orientations. Cooperative agreements with outside organizations should recognize the special conditions and requirements for fighting fires when cultural resources are involved.

Staff responsible for structural fire planning should become familiar with the following policies, guidelines, codes, and standards:

Management Policies, Chapter 5, "Fire Detection and Suppression," and Chapter 13, "Structural Fire Protection and Suppression."

Loss Control Management Program Guideline, Chapter 18, "Fire Safety."

Structural Fire Guideline (NPS-58), Chapter 13, "Historic Structures."

Museum Handbook, Part I, Museum Collections, Chapter 9 (1996) and Appendix G (1996).

NFPA 70, "National Fire Code."

NFPA 101, "Life Safety Code."

NFPA 910, "Recommended Practice for Protection of Libraries and Library Collections" (1991).

NFPA 911, "Recommended Practice for Protection of Museums and Museum Collections" (1991).

NFPA 913, "Recommended Practice for Protection of Historic Structures and Sites" (1987).

NFPA 914, "Recommended Practice for Fire Protection in Rehabilitation and Adaptive Reuse of Historic Structures" (1989).

2. Wildland and Prescribed Fires

With wildland and prescribed fires, as with structural fires, a paramount concern is resource protection, both cultural and natural. To ensure that fire management plans address cultural resource concerns, cultural resource specialists should participate in their preparation. In addition, staff charged with fire management should be informed about significant archeological sites whose locations are confidential. Plans should also make provision for archeological surveys to precede fire line construction, for protecting cultural landscape features, and for dealing with ethnographic concerns. Additionally, post-fire terrain rehabilitation for cultural resources may need to be included in follow-up activities. (For further guidance see the Fire Management Guideline [NPS-18], Executive Summary and Chapters 2 and 5.)

E. Administration

1. Budget

The importance of a well-formulated budget program for cultural resources management cannot be overemphasized. Without proper funding, an effective cultural resource management program cannot be carried out. Program formulation entails completing clear, succinct Development/Study Package Proposal forms (Form 10-238). The Full Package Description and Package Justification/Consequences sections are especially important, for they are used to set funding priorities. In some instances, resources management plan project statements are written to contain all of the programming data required for 10-238s, given package numbers, and used as programming documents in place of 10-238s. In either case, resources management plans are the primary sources for data to support cultural resource management budget requests. Fiscal management and cultural resource staff members are available for consultation in preparing programming documents.

The sources for funding cultural resource management include base funding, the cultural resources preservation program, cultural cyclic maintenance, the backlog cataloging program, the museum collection preservation and protection program, the repair and rehabilitation program, regular cyclic maintenance, line-item construction, special emphasis programs, and lump sum construction. Donations also sometimes support cultural resource management activities. Understanding these fund sources and the types of projects for which they are appropriate is necessary in formulating an effective cultural resource management program. Budget staff and cultural resource personnel can provide information and guidance in this area.

2. Personnel

a. Recruitment

Cultural resource specialists are qualified professionals who initiate, make recommendations about, coordinate, carry out, and supervise cultural resource programs and research. In most cases, professionals with specific knowledge, skills, and abilities (KSAs) beyond the minimal qualifications in the Office of Personnel Management (OPM) Personnel Qualifications Standards Handbook (X-118) are sought for cultural resource positions. The goal is to match people with the best combination of knowledge, skills, and abilities to the specific positions being filled.

It is important that the recruiting manager describe with precision and clarity the professional qualifications needed for the position. The journey level for the following cultural resources professional positions is GS-11: historian, 170; archeologist, 193; landscape architect, 807; historical architect, 808; anthropologist, 190; curator, 1015; archivist, 1420. (For localized, small, and stable museum collections the journey level curator may be GS-9.) The better a position description is written, the more likely it is that there will be applicants with the needed knowledge, skills, and abilities. KSAs are, in effect, special qualifications. They are used within the merit promotion system and may be submitted to OPM in some cases when OPM is requested to recruit candidates. (See Appendix E for examples of qualifications that could be used as selective or quality ranking factors. For further information in formulating KSAs and selection factors, consult personnel staffing specialists.)

b. Training

Employees who treat or manage cultural resources must know and understand the cultural resource management policies adopted by the NPS. Managers, planners, maintenance staff, cultural resource specialists, interpreters, and others should receive policy training as soon as their duties involve dealing with cultural resources.

Because of the nature of cultural resources and the special skills needed to deal with them, specialized training is quite often needed to ensure that people working with them have the proper combinations of skills. A highly qualified carpenter may need training in ancient joinery techniques; an archeologist may need geographic information system skills to better and more accurately document sites; a curator may need computer skills to better manage and study collections. Skills development can be accomplished through formal training and workshops, mentoring relationships, on-the-job training, participation in the activities of trade and professional societies, and reading professional publications and periodicals. (See Essential Competencies for National Park Service Employees, 1996.)

Cultural resource training is available through a variety of sources including the NPS, American Association for State and Local History, National Trust for Historic Preservation, Association for Preservation Technology International, Society of American Archivists, museums, colleges and universities, and historical societies. (See also NPS Museum Handbook, Part I, Appendix C, "Professional Organizations and Societies," and the annual issue of CRM entitled "A Directory of Training Opportunities in Cultural Resources Management.") With the goal of increasing the quality of care resources receive, training should be encouraged and expanded. Whatever the nature of the training, it should be documented in employee records.