Moving PennDOT Forward

Rummaging through my files as I was researching a panel presentation on university partnerships, I stumbled across this missive from the last century, 1997 to be exact. Although it is an artifact from the time, I did find it interesting that some of the concepts presented are still relevant today, in particular the need to put creative mitigation under an overall strategic plan.  And although it has PennDOT firmly in the cross-hairs, I think it can apply to any agency that has Section 106 responsibilities. In that spirit, I am offering it for your amusement.  

Archaeology and Historic Resources – Creative Mitigation and Integrated Program Management

Under NEPA and Section 106 of the National Historic Preservation Act, the Department of Transportation must ensure that its Federal-Aid projects consider their effects on historic sites and properties eligible for the National Register of Historic Places.  Similar requirements are found under the counterpart State History Code and Act 120. In the 30 years that these laws have been in effect, PennDOT has aggressively fulfilled its responsibilities and can take credit for much of what is known archaeologically in Pennsylvania, as well as numerous examples of sympathetic design with the historic built environment.

The Challenge Ahead

Despite a strong effort in compliance – reflected in the approximately 250 cultural resource studies conducted each year, dozens of archaeological and historical mitigation efforts, and expenditures of $6-12 million a year – there are some notable deficiencies.  Most archaeological sites are eligible for the National Register for the important information they contain, yet most archaeological mitigation projects, i.e. data recovery excavations, do not yield knowledge and understanding commensurate with the efforts made to gain that information. Second, valuable information that is gleaned from individual sites and individual projects is not being fully communicated to either the technical community or to the public at large. Third, a site-specific or project-specific focus on archaeological or historical resources generally fails to support a regional perspective or context, so that all of the history becomes local and does not inform the broader pattern.  Fourth, avoidance and mitigation have substituted for preservation, with the frequent result that extraordinary measures to avoid harm to important historic properties are negated by later non-PennDOT development activities.

The problems enumerated above are not PennDOT’s alone, but are reflective of National trends and concerns.  To a greater or lesser degree, all Federal agencies and their State Counterparts are being faced with the same challenges.  Most of these agencies have evolved responses to these challenges in the same incremental, methodical, and unreflective way.  Environmental compliance is the cost of doing business, in our case maintaining and improving the transportation system.  All costs above the minimum are excessive.  Because the project is the irreducible unit of measure and the only fiscal unit, cultural resource activities must be confined to the project.  Finally, all non-construction costs – design and environmental studies – are a potential embarrassment to be hidden from nosy legislators and constituents.

The Cultural Resource Management (CRM) field has not escaped criticism either. The 25 year-old promise of an enlightened public-private partnership to enrich our cultural heritage has gone unfulfilled.  Instead, the entire arena of Cultural Resources has become one of fragmented and competing interests: academic researchers, preservationists, CRM firms, Native American Groups, local historical societies, State Historic Preservation Offices, the Agency, and the Agency’s own technical specialists and managers.  Academic archaeologists still ignore the reality that CRM funds virtually all archaeological work in the United States, instead training their students to become university professors for a shrinking teaching job market.  For-profit CRM firms complete synthetic archaeological or historical research as a non-profit activity, if at all, since compliance not research is the product paid for by clients.   Agency and SHPO staffs are usually locked into a zero-sum game of how much fieldwork is enough.   In this mix, the general public has been left out to sit on the sidelines, and, even if aware of the ensuing debates, left to ponder the relevance and value of CRM to society.

Climbing Out of the Box

PennDOT has an unprecedented opportunity to reflect on and rethink the status of CRM as it is currently implemented.  The upcoming re-engineering of cultural resources in May will necessarily lead to re-evaluations of processes, both internal and external. Efficiencies most certainly will be found, both in time saved and costs.  However, if the battle cry is “Better, faster, cheaper!” then there is a risk that only two parts will be addressed, unless there is a clear effort to make CRM betterwithin the Department.  In this context, better is not merely the outcome of faster and cheaper. “Better” can and must be an effort to address all of the above-listed  deficiencies.  Ironically, a single-minded focus just on a better CRM within PennDOT may be the surest and quickest path to a more cost effective program.

The Department must shift its thinking in two ways to accomplishing this re-engineering successfully.  First, PennDOT must embrace a new ethic of preservation, increased historical knowledge, and outreach, and abandon its current ethic of compliance, avoidance, and mitigation.  Second, PennDOT must embrace a program-wide perspective and abandon its project-by-project myopia.  The second shift in thinking is the tool to accomplish the first.

Deming astutely observed that you cannot improve what you do not measure.  In the current climate, PennDOT does measure compliance, avoidance, and mitigation, and success in a project is judged by how well these three are done.  However, these are short-sighted goals that are purely process focused.  Section 106 is a process, but to focus only on the process is to box ourselves into narrow thinking and miss the larger points.   We comply and consult.  We redesign to avoid historically important sites, only to lose these sites to fast-food restaurants and housing projects.  We mitigate by recordation, but the bridge is taken down and no one other than the preparer, the reviewer, and the SHPO will ever read the report or use the information.  We conduct a data recovery excavation, analyze the artifacts, write up the report, but the site is destroyed and few people other than a handful of experts understands what was learned or why.

It is time to start measuring what is important, instead of measuring process. Can we preserve historic resources, so that they will be there for our children and our children’s children to enjoy? Can our bottom line be increased understanding of our past, measurable as scientific knowledge?  And can we communicate this newly gained understanding, both to the research community and to the public at large, measured in heightened public awareness and interest in our past?  As a public agency, funded with public monies, dare we do otherwise?

Creative Mitigation: The Magic Bullet

In the current climate of thought, these goals are difficult if not impossible to reach.  PennDOT’s activities are inherently destructive and only rarely offer an opportunity for actual preservation within a particular project.  And, as described above, only the largest EISs offer any opportunity to broaden interpretation, and provide something back for the community, as a brochure, poster, or lecture.  However, if we can liberate our thinking from a project-specific basis to a program perspective, then much more is possible.   If mitigation need not be directly linked to the project impacts, then indeed it would be possible to incorporate off-site preservation actions into a project.  A mitigation to one historic property being destroyed might be the purchase of an easement on another that could be preserved.  A bridge removal on one location might be mitigated by rehabilitation of second bridge on a different location.  If we can break out of the box of project action/project mitigation, and can be flexible and creative in our interpretation of mitigation, then we can reach the goals of preservation, increased knowledge, and public outreach.

Can creative mitigation be done?  Specifically, is it permissible under Section 106 and will it be supported by the SHPO and the Advisory Council on Historic Preservation, both of whom would need to sanction this approach?  In the current National dialogue, there is every indication that they would.  In Pennsylvania, the US Army Corps of Engineers recently signed a Memorandum of Agreement with both the SHPO and the Advisory Council to mitigate impacts to archaeological sites on a Wyoming Valley Flood Control project by contributing to a Geographic Information System Database initiative.  The Advisory Council recently executed an Agreement with a Federal Agency that mitigated impacts by funding university student scholarships.  The door is clearly open for creative approaches to mitigation.

Integrated Program Management

Once we accept the premise of a creative and possibly off-site mitigation strategy, then CRM within PennDOT can no longer be managed at the project level. It must be managed at a program level.  This is simultaneously liberating and challenging.  It is liberating because the goal now is to find the mitigation appropriate to the effect, whether it be on-site, in-kind elsewhere, or something entirely creative and new.  It is challenging because without the constraint of project location on each mitigation activity, mitigation themes and locations can get redundant, duplicated, or established without consideration of their cumulative positive effects.  If creative mitigations are integrated and managed as a program, addressing the new ethics of preservation, knowledge, and outreach as the driving goals of the program, then the challenge can be met.

Integrated Program Management(IPM) is the key to successfully folding mitigation activities into CRM in an efficient manner.  Potential adverse effects to historic properties would be mitigated by actions falling under one or more of the goals of preservation, knowledge, or outreach.  In consultation with the SHPO, FHWA, and others, and appropriate strategy could be developed and implemented.  Traditional mitigation actions could be considered and may be appropriate; however, the options can be greatly expanded.  Instead of a data recovery excavation on a site that is only being partially impacted, perhaps the appropriate mitigation would be a synthesis and publication on the prehistory of the region.  An eligible bridge that is closed and structurally unsound might be replaced to AASHTO standards, but another bridge of the same type on the State system might be rehabilitated instead.  In lieu of routine consultation and evaluation of 3R and 4R projects in a District, the Department might fund a middle school teaching module on the history of transportation of the area.  This flexible approach does not preclude standard treatments, developed through a series of Programmatic Agreements. 

IPM offers three extremely valuable additional benefits.  Small mitigations can be grouped and leveraged to a greater benefit, be it for preservation, knowledge, or outreach.  IPM can be used to fill gaps.  Finally, and possibly of greatest interest to any re-engineering, IPM can be used to fuel the kind of applied research that can result in more efficient identification and evaluation efforts.  This last point was not lost on the Corps of Engineers in their Wyoming Valley mitigation commitment, insofar as they fully expect to reap the benefits of the GIS in years to come when determining the need for future surveys in their jurisdictional area.

Although IPM would be the management tool for PennDOT, it would be guided by a preservation plan.  Such a plan would define preservation, increased knowledge, and outreach goals, and set guidelines and measurement for them.  It might become a biennial planning document that would set forth more specific objectives that IPM would implement.   The statutory authority for a Federal Agency to establish such a plan is clearly set forth in Section 110 of the National Historic Preservation Act; however, few agencies other than the National Park Service and the US Army have utilized its full provisions.

Developing the Public and University Partners

In order for PennDOT to fully embrace a Creative Mitigation IPM Program, the Department must extend its partnerships beyond the traditional SHPO and FHWA ring. Pennsylvania’s Universities are uniquely positioned to synthesize the history and prehistory of the State, and to undertake the kinds of special analyses that bring greater understanding. The university is also the appropriate training ground for cultural resource professionals.  It may be possible to sustain existing programs or kick-start new programs at institutions that can break away from ivory tower thinking.  Were several universities to partner with PennDOT, they could expect a steady stream of data, student support (as internships or scholarships), and funding for applied research.  For public universities, an association with a State Agency makes these institutions relevant to the larger public, which can be translated into public support. In return, PennDOT could expect this data to be digested into historical knowledge at low cost, as well as a ready laboratory for methodological and technical experimentation.

The other partnership is with the public, both in the historical and preservation community and with the public at large.  PennDOT is not in the public history business, but can find partners who are.  The syntheses that are developed from CRM studies can and must be translated into plain English and presented to a public that is truly eager for its heritage. This outreach can take many forms, as readable summaries, exhibits, lectures, symposia, re-enactments, site reconstructions, Internet Web sites, radio and television programs, books, magazines, or CD ROM.  Preservation activities that include purchase of historic properties or easements will need to be assisted by local historical groups who have the infrastructure to manage, maintain, and interpret these properties.  In return, PennDOT can look beyond the legal and regulatory requirements of CRM, and point with pride to the intrinsic value of its activities.

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