I broke into a sweat upon waking up from a fever dream the other night:

Fresh off his victory with the East Wing of the White House, President Trump announces further upcoming improvements:

Gettysburg Battlefield Casino and Resort

Cemetery Ridge will be upgraded with a Resort and Casino, including a 100 foot tower, from which the entire Battlefield can be seen.  Slot machines will be added to the Cyclorama, so that Patriots can play with special blue or grey tokens while observing the battlefield enactment.

Statue of Miss America

From New York Harbor, visitors can see a renewed 21^st century Statue of Liberty, more becoming of America’s beauty – short dress and heels, bigger boobs, and a smile. Oh, and not copper colored but white, as God intended.

Mount Rushmore Trump Tribute

President Trump’s visage will be the only one to be seen on Mount Rushmore. To paraphrase The Princess Bride: “Have you ever heard of Washington, Jefferson, Lincoln, and Roosevelt? Morons!”

Linked-In Misery

Shortly after the demolition of the East Wing of the White House, I committed a cardinal sin by posting about it on Linked-In. Actually, multiple sins. First, I let my heart rule my head on the post. Never a great idea for social media. Secondly, I usually shy away from topics that are likely to get widely discussed by others. My happy place is that lonely dirt road that no one else travels. Finally, Linked-In is not built for long form discussion. It’s not even built for discussion.  Replies get buried down below.  Anyone coming in fresh can get lost in the thread.  Like it’s click-bait cousin Facebook, Linked-In thrives on controversy, and now apparently AI slop featuring kittens riding dogs and the like. Not to mention the ubiquitous corporate ads.

The post got a lot of clicks, some supportive, and some dismissive. Probably par for the course. The main post and related comments I provided on the East Wing are attached, should you feel an urge to read them.  If I were you, I wouldn’t bother. However, it did lead to a brief exchange that forms the subject of this blog. Thanks goes to Allyson Brooks, the Washington State Historic Preservation Officer and an outstanding preservation warrior.

After I noted that nothing is safe after the demolition of the East Wing, she quickly responded (correctly) that “You (Ira) know very well that no historic building or site is safe. It is all consultation.”  After the dust had settled on the Linked-In imbroglio, it got me thinking. Given the weakness in the current federal historic preservation laws, just how is it that anything gets preserved?

What the Laws Say

A quick review.  The National Historic Preservation Act of 1966 establishes the National Register; Section 106 of the Act requires consideration of the effects Federal Actions have on historic properties through project construction, funding, licensing, etc. Nothing in the National Register requires protection to properties that are listed therein. Nothing in Section 106 guarantees protection of historic properties. As of the Summer of 2025, approximately 2,500 National Register Listed Properties have been removed from the list, the vast majority from loss. These are just from the listed properties and does not include those lost that were determined eligible for listing in the National Register but not listed.  This is against a backdrop of over 100,000 listed National Register properties. I am leaving out National Monuments designated under the Antiquities Act of 1906. There are currently 129, most of which are protected.  It was the mother of all losses, the 1963 demolition of New York’s Pennsylvania Station, that spurred the passage of the act in the first place.

Section 106 is usually wrapped within the umbrella National Environmental Policy Act (NEPA) and its processes, so when you hear about an Environmental Impact Statement or Environmental Assessment, it almost always embeds a Section 106 review. Categorical Exclusions (the third of the NEPA actions) sometime contains a Section 106 review.  And finally, within my world of DOT, there is a parallel law within the USDOT code referred to as Section 4(f). It requires USDOT (in my case FHWA) to demonstrate that there is no prudent and feasible alternative to “using” (the technical term for whacking and similar to an adverse effect) a historic resource in a project. Putting Section 106 and 4(f) side by side is one way we at the DOT drive ourselves crazy as there is a lot of overlap, but significant differences, and both have to be applied generally to historic resources. Leave it suffice to note that 4(f) sets a higher bar than Section 106, but again FHWA is particularly adept at demonstrating that there is no prudent and feasible alternative to use, especially with regard to historic bridges. The bottom line is that protection is not assured.

Many states also have historic preservation legislation, but none that I know of guarantee preservation, especially for properties that are privately owned. There is a 20% tax credit for rehabilitation of historic properties under the Internal Revenue Code, Section 47. Local ordinances in the form of Historic Architectural Review Boards (HARBs) exist within the NHPA, but again, these do not guarantee preservation, although HARBs do exercise a lot more control. Unfortunately, not many municipalities have them.

We live in a country where private property rights are highly valued. This condition permits historic properties that are privately owned to be altered or demolished by the owner using their funds and resources, with very little legal recourse. In fact, there is a whole cottage industry of lawyers whose only purpose is to prevent governments and public institutions from “taking” historic properties, i.e., impinging on the property rights of owners.  Privately owned historic properties may be eligible for the National Register, but can only be listed with the permission of the owner. But within this rule lies the seed of historic property protection.

Historic Preservation and Soft Power

I live in New Cumberland, Pennsylvania, a small town of around 8,000 with a small downtown.  I like living there for a number of reasons, but this is no Colonial Williamsburg. There are a handful of historic properties that are eligible for listing in the National Register, but none of these are listed. The three local landmarks are the Iron Bridge (built in 1936), the West Shore Theatre (1940), and the Public Library (founded in 1976 in a building that was built in 1819). For various reasons none of these are on the National Register, although all are older than 50 years.  Yet each one is highly valued and treated with respect as the cultural places they are.  The Theatre was closed several years ago and nearly abandoned, but community support and funding led to its restoration and re-opening in 2022.  It won a Preservation Pennsylvania Award for Public Impact in 2024. The Bridge is a steel truss and nothing particularly special, except it is the namesake for several business around town and an annual music festival. It is in pretty good shape currently. There are no plans to replace it that I’m aware of, but I swear there would be hell-to-pay if that were to occur.  The Library’s core is a 19^th century farmstead, which has been heavily modified and added to over the years, but again the family associated with the property, the Benjamins, are very much part of the historic fabric of the community, and central to the story of the town. The building is owned by the borough, and it is very much protected and cherished.

All three of these places live in the netherworld of not quite National Register, but small “h” historic. It is possible that someday, they may become Historic. Standards change and comparable properties may become increasingly rare. But for now, they are protected – not by any set of Federal or State or Local laws, but by community interest and support.

A few miles down the road is the 1887 Sheepshead Bridge. Built by the Phoenix Bridge Company, the 114-foot Pratt through truss connects Cumberland and York Counties across the Yellow Breeches Creek. It is National-Register eligible.

In January, 2020, the bridge was closed to traffic and not considered repairable to be reopened for vehicular traffic.  Typically, this is the death knell of historic bridges that can no longer meet a transportation need. However, with the active support of the local community and the West Shore Historical Society, prospects for the bridge improved considerably.  In 2022, the project was awarded a $1.4m PennDOT Transportation Alternatives Set-Aside Grant, along with an addition $600k in PennDOT funding.  With this commitment, the bridge will be rehabilitated for bicycle and pedestrian use and after restoration will be put back on its original location. Upon project completion, estimated for the Spring of 2026, ownership of the bridge will be transferred to the West Shore Historical Society.

Historic Bridges.org rated this bridge 9/10.  As noted above, being historic, even being highly historic (not a technical term, as all eligible properties are on an equal footing legally, but not practically) does not offer protection or preservation. Yet, this particular bridge is being preserved, through a combination of public interest and support, and special funding provided by PennDOT.  One might suggest that it was only money that made the difference.  The reality is more complicated.

PennDOT and Historic Bridges

I am dwelling on historic bridges here because this property type is the one I most frequently encountered while working at PennDOT, and in many ways the most frustrating.  Bridges are part of the transportation infrastructure and Pennsylvania is an old state. This means that there are a lot of historic bridge here. At the same time, the transportation infrastructure needs to function for its citizens, and when a bridge is no longer safe to cross because it can’t handle the loads of modern trucks or is too narrow for two lanes or otherwise functionally obsolescent, it is the responsibility of PennDOT to do something. From an engineering perspective, the simplest thing is to replace the bridge with a new one which will meet load requirements, allows at least two lanes of traffic, and is cost effective.  The Section 106 consultation requirements (usually the project has Federal Funds) or 4(f) requirements (even with state funds there is an equivalent State 4(f) called Section 2002), would suggest a rehabilitation might be recommended instead of a replacement, which stands in contradiction to the elegant engineering solution.

Any bridge project – historic or not – will greatly affect the local community.  Simple bridge replacements can close a crossing for months. Bigger ones can take years. Public involvement and coordination with stakeholders is crucial and necessary, and preserves whatever good will PennDOT has in the local community. By the way, this is the same community that owns cars and trucks and pays licensing fees and buys fuel, all of which funds PennDOT.  And they have long memories and they vote for their state representatives and senators that oversee PennDOT. You catch my drift?

Within all that discussion and coordination, if there is a historic bridge involved that’s on the table, too. More often than not, the fate of the historic bridge depends on the degree of local support for that bridge. (This also holds for other historic properties as well.)  In some communities and regions, there is much greater interest and support for historic properties than in other areas.  If you drew a straight line between Erie and Philadelphia, that would pretty much define a gradient of historic property (and bridge) support with a high in the east and diminishment as you traveled west and north. This is excepting enclaves like State College and Pittsburgh.

What is in play, then? Bridges that are under consideration for replacement have usually been posted for weight. By the time a bridge is being considered for replacement, large trucks including ambulances and fire engines have been prevented from using that bridge. When there are other routes in a redundant system, this presents less of a problem, although response times to fires and other emergencies is a real consideration. When there is no other route to a home that may need, say heating oil, this can make that home unlivable. Never a good thing.

If the bridge can be rehabilitated to lift the load restrictions, rehabilitation can suit the project need. Sometimes this can be done. Sometimes not. If it can, then the question of costs comes into play. I have great respect for civil engineers. Give them enough money and they can do practically anything.  But PennDOT is a public agency and has a responsibility to spend prudently.  It is then when the question of whether a rehabilitation that may last 30 years and costs as much as a replacement that may last 75-100 years bumps up against the prudent part of prudent and feasible. Which argument prevails?

I do not wish to portray this as some David versus Goliath or good versus evil dynamic. I have seen some spectacular bridges lost and some questionably significant bridges saved.  I have seen some PennDOT administrators unwilling to fully embrace Section 106 and 4(f) and some local communities using the bridge project as the tool to achieve local planning, totally disinterested in the actual historicity of the property.  Finally, and this is an important point, there is no slide rule plug in a number answer for whether a bridge should be saved or not. Frequently, the decision revolves around a matter of degrees – can the community live with a weight restriction? Is a new bridge a need or a wish? Would a cheaper rehabilitation that lasts 30 years be good enough for now?  Could the bridge be closed without significant loss of access? And for local communities that might need to freight the 5% or 10% of the cost of a new bridge- tens or hundreds of thousands of dollars – can they afford to make that decision now? Oh, and for any local community that has more than 2 families, there’s going to be a pro-replacement contingent and an anti-replacement contingent. Unanimity of local opinion only happens in North Korea.

It’s in this soup that community support for a historic bridge, or frankly any historic property, plays out. If the local community is strongly in favor of a historic property, the decision needle moves a few degrees one way. If few people care, the decision needle moves a few degrees the other way. And in those cases where a rehabilitation is feasible and possible prudent, those few degrees can make the difference between save and lost. Earlier, I mentioned the ability for private landowners to block a national register listing on their historic property. A national register listing still means something. It’s not nothing.  And although FHWA and PennDOT (receiving federal funds) will treat a listed property the same as a determined property, in the local community a listed property is much more visible, has more cachet, and is woven more tightly into the historic fabric, i.e., the community’s local story and narrative than a mere determination. And let’s remember that PennDOT’s primary mission is to maintain an efficient and modern system to move people and goods.  Almost as important is the need to not piss off the local communities in which its projects are done.

The Larger Picture

I’ve been using PennDOT and 4(f) and historic bridges to talk in some detail on how things can be preserved. Even outside of DOT (no 4(f)) and bridges as a property type, I do believe that the principles of community interest and support remain. Local community support for historic properties is what preserves them in the face of progress, modernity, late stage capitalism, what have you.  Laws and regulations provide the pathway when there is sufficient time and consideration given to public input as strongly suggested in NEPA and Section 106. Laws and regulations alone do not protect historic properties. As corny and flip as it sounds, people organized in groups, people who learn about and care about the history of their community – these are the ones that protect historic properties. Lyndon Johnson and Congress didn’t wake up one day and pass the National Historic Preservation Act because they felt like it. The law was passed because other people, lots of people, were screaming over the loss of Pennsylvania Station and other important historic places.

Would the loss of the East Wing bring a similar response and result as was done in 1966? I don’t know. It was 59 years ago. Times were different.  The political landscape was different. Then, historic preservation was much more of a Republican ideal, with roots in Teddy Roosevelt.  The Democratic ideal might have been characterized more by urban renewal and Robert Moses. We are more mobile now than ever. It’s harder to have a sense of place when you don’t put down roots anywhere.

Still, as a species I believe we are rooted in story. It is perhaps the only way we make sense of the world. The sense of place and its associated story is what we crave, whether our family has been there 5 generations or moved in last year.  We can adopt places just as we adopt families if we don’t have ready access to a rooted past.  Perhaps the East Wing was just my macguffin to get to the larger question of how and why do we protect any historic places at all, given the inherent weakness in current laws and regulations. If we can learn about our history and about our historic places, we can care about them. If we can care about them, we can take the time and energy to protect them. Not just against federal project impacts, but against rampant development, not just against something happening a thousand miles away, but at home in your own community.

The Senate Committee on Energy and Natural Resources is planning on having a hearing on the National Historic Preservation Act the last week of October (potentially 10/29). On October 19^th, I sent the following to Senator David McCormick of Pennsylvania, who is on the Senate Committee.

Senator McCormick,

I am writing you regarding the National Historic Preservation Act (of 1966).  My observations are informed by a 40 year career as a professional archaeologist who has worked with the NHPA for most of that time.  I was employed by the Pennsylvania Department of Transportation and the Maryland State Highway Administration; my experience was largely with Section 106 of the NHPA.  I am currently retired from PennDOT.  Please note that my comments are my own and do not reflect the views of PennDOT or Maryland SHA.

In the nearly 60 years since its passage, the goals of the NHPA are unchanged.

“The Congress finds and declares that — the spirit and direction of the Nation are founded upon and reflected in its historic heritage; the historical and cultural foundations of the Nation should be preserved as a living part of our community life and development in order to give a sense of orientation to the American people;…”

The responsibilities of the Federal Government with regard to these goals are also unchanged.  Amongst other things, 

“It shall be the policy of the Federal Government, in cooperation with other nations and in partnership with the States, local governments, Indian tribes, and private organizations and individuals to — use measures, including financial and technical assistance, to foster conditions under which our modern society and our prehistoric and historic resources can exist in productive harmony and fulfill the social, economic, and other requirements of present and future generations;…”

My own experience has largely been with Section 106, one of the shortest Sections in the law. I can restate in its entirety here:

“The head of any Federal agency having direct or indirect jurisdiction over a proposed Federal or federally assisted undertaking in any State and the head of any Federal department or independent agency having authority to license any undertaking shall, prior to the approval of the expenditure of any Federal funds on the undertaking or prior to the issuance of any license, as the case may be, take into account the effect of the undertaking on any district, site, building, structure, or object that is included in or eligible for inclusion in the National Register. The head of any such Federal agency shall afford the Advisory Council on Historic Preservation established under Title II of this Act a reasonable opportunity to comment with regard to such undertaking.”

As far as transportation and other agencies are concerned, the main implementing regulation for Section 106 is 36CFR800, last revised in 2004. As implemented by Federal Agencies, what is important to know is that Section 106 and its regulation are procedural and not prescriptive.  Agencies must take into consideration the impacts their projects have on historic resources, but are not told how to implement. Secondly, within 36CFR800 is enormous flexibility to implement Section 106.  This flexibility is not limited to the Federal Agency level, but exists at the State level, for types of actions, and even within a specific action. Finally, the law and regulations put public input into the decisionmaking.  This does not mean that individuals or small groups are given the power to change or stop projects, but it does mean that all voices are meant to be heard.

Using the flexibility in existing law and regulations, at PennDOT we were able to streamline the Section 106 process to accomplish the following: by definition or by a quick check, most of the projects using Federal Funding were exempt from further Section 106 review. Section 106 was finished instantly or in a few days.  This was with the blessing of the Advisory Council on Historic Preservation, FHWA, the State Historic Preservation Officer, and other signatories to our agreement, which included Federally recognized Tribes.  A further slice of our projects were determined in-house to have No Effect or No Adverse Effect on historic resources.  Our findings were made public and unless there were objections from the State Historic Preservation Officer, were final.  Section 106 was finished in days or weeks, and well before the NEPA approval could be made.

Only those projects that had an adverse effect on historic resources– around 3% of all projects –   required more extensive consultation with other parties.  In 25 years at PennDOT, there wasn’t a single instance where this consultation held up a NEPA decision or held up construction.  It wasn’t just the up-front consultation that expedited conclusion of Section 106, but also the flexibility in Section 106 to find workable solutions. Sometimes engineers were able to avoid the adverse effect by redesigning the project. Sometimes archaeologists completed field excavations after NEPA approval but before construction.  And it is important to note that Section 106 does not require preservation of historic properties, although that could be an outcome.  In many cases, the action to address adverse effects involved recording and sharing local history, saving and re-using parts of historic buildings and structures, or protecting similar properties not in the project area, but at risk.  In all cases, costs to complete these mitigations were required to be reasonable and in each case, the benefit to the local community needed to be shown.  For PennDOT, all projects are local and benefit and impact real people.

Successful Section 106 implementation creates no noise, no angst, no blowback.  In 2025, PennDOT is expected to spend $4+ billion in Federal, State, and private funding on more than 1,200 highway and bridge projects. How many of these have come to your office as Section 106 problems?

There is no question that the regulations can be improved and updated, and over the 60 years of the Act, regulations have been regularly revised.  That said, the NHPA and Section in its current form provides PennDOT the tools to meet the goals of the Act in an efficient manner. Projects were never delayed, and in certain instances, design changes spurred by the Act led to improved and better projects, appreciated by the community in which they were built.

Today, I sent Department of Interior my comments (below) on the “interim final rule” on their Implementing Regulations for the National Environmental Policy Act.

Thank you for accepting comments on this proposed “interim final rule,” even though you state it is not necessary that you do so.  My comments reflect 30 years of experience as a NEPA practitioner and Section 106 specialist in transportation. I am not a lawyer.

I find it completely baffling what this “interim final rule” is. Is it regulatory, guidance, both, or neither?  You make repeated claims that this is not regulatory, that it is mere guidance and procedures. If they are binding, then they should have been put through the regular regulatory process.  If they are not binding, not legally binding, then you have made no improvements to the process you had before. I presume that you intend them to be procedures and guidance, which is why I am not providing any specific comments on any of the recommendations. I will leave it to the courts to sort out what follows the law and what does not, because it will be the courts that will have to clean up the mess you are creating. Lawsuits and court challenges are what have dogged DOI, with their lengthy delays. You are ensuring this continues.

Parallel to this “interim final rule” is the interim final rule for FHWA, FRA, and FTA.  Those provide minor changes to previous regulations under 234 CFR 771, and largely limit changes to what is required to conform to the Fiscal Responsibility Act of 2023 and the withdrawal of CEQ regulations in response to a Supreme Court Decision.  That interim final rule remains a useful regulatory tool for FHWA, FRA, and FTA actions, which have not weathered the controversy that other Federal Agencies have endured.  I would argue that strong and enforceable Federal regulations provide a predictable playing field for all actors. This point is demonstrated especially by FHWA, which not only spends many billions a year on transportation projects, but oversees many billions more in funding by state and local agencies.  While substantially different from the Department of Interior in that it is not a land-owning and managing agency (with a tiny exception of FHWA headquarters in DC), FHWA does have substantial impact across the nation in virtually every municipality.  That projects are delivered largely without controversy and in a timely way demonstrates the wisdom of firm regulatory oversight, while still maintaining great flexibility in implementation. Your protestations that the regulations themselves are the problem are simply not supported.

Yes, NEPA is a procedural law, but you have misrepresented it as merely a check-the-box process.  It is anything but. To quote Justice Sotomayor concurring in the same Seven Counties decision you are so fond of referencing, “NEPA requires agencies to prepare and publish a ‘detailed statement’ reviewing the environmental impact of any major federal action. 42 U. S. C. §4332. That ‘action forcing’ requirement serves dual purposes, ensuring both that an agency considers a project’s environmental consequences before deciding whether to approve it, and rendering the agency publicly accountable for environmental harms it decides to tolerate…The point, as this Court has recognized, is not merely that an agency produce a report but ‘that environmental concerns be integrated into the very process of decision-making.’…In that way, NEPA’s procedural requirements advance Congress’s aim that the Federal Government “use all practicable means [to ensure] that the Nation may . . . fulfill the responsibilities of each generation as trustee of the environment for succeeding generations.” (my emphasis)

The Department of Interior could have followed the lead of a sister agency and promulgated sensible regulations that follow the spirit and letter of NEPA. Instead, it has tried to thread the needle by issuing procedures and guidance that it intends to use as regulatory (?) but without the messy business of following the process for issuing regulations. In both the tone and tenor of this “interim final rule” and its purported guidance and procedures, the Department of Interior is bypassing public input and ramrodding a process that may or may not meet the letter and spirit of the National Environmental Policy Act, which still remains on the books. Who knows? I fear that this “interim final rule” is a preview of how DOI intends to consider its actions, significant or otherwise, to check-the-box in a rush toward a decision, the public and environment be damned.

This “interim final rule” should be withdrawn. You should restart with a regular regulatory process.

On June 4^th, the Transportation Research Board (TRB), an arm of the National Academy of Sciences, Engineering, and Medicine (NASEM) reorganized its Technical Advisory Council. The Committee for Historic and Archaeological Preservation in Transportation (AME60) was eliminated as were most of the Committees in its Group. AME60 was a hard-working and effective Committee. Its elimination is a self-inflicted error that will impact Transportation for a long time.

Recent History: A Recap

On June 4^th, the Transportation Research Board (TRB), announced a new structure for its Technical Activities Council, which is its meat and potatoes research arm. On June 3^rd, there were 181 active committees and additional sub-committees covering every nook and cranny in transportation.  On June 4^th, there were 100 committees and no subcommittees.  A number of Groups had their committees consolidated or eliminated.  It is the nature of TRB to constantly reinvent itself.  Efficiency in operation is always top of mind.  The last major reorganization was in 2019.

In the former Sustainability and Resilience Group (AM000), there were 19 total committees in 3 sections. Historic and Archaeological Preservation in Transportation (AME60) was in the Transportation and Society Section (AME00). In the new structure, AME60 and 2 other Committees were eliminated from the Transportation and Society Section. Both of the other Sections – Transportation Systems Resilience(AMR00) and Transportation & Sustainability (AMS00) – were completely eliminated. The remnant AME00 Committees were merged with remaining Policy and Organization Group (AJ000) Committees to form a new Organizations, Communities, and Legal Resources Group (AQ000).  This new Group hosts 16 of the remaining 36 Committees that were associated with AM000 and AJ000.  Only 5 of the 19 Committees in the former AM000 Group remain. AME60 is gone.

I cannot speak to the other Committees beyond Historic and Archaeological Preservation in Transportation: AME60 (formerly ADC50 and A1F05 before that).  Over the last 30+ years, I have been for a member of that Committee and a Friend of the Committee. I am well acquainted with its functioning.  

What is TRB and the Standing Committees?

 To quote a statement from a 2017 TRB handout:

The National Academies of Sciences, Engineering, and Medicine (NASEM) are private, nonprofit institutions that provide expert advice on some of the most pressing challenges facing the nation and the world. Our work helps shape sound policies, inform public opinion, and advance the pursuit of science, engineering, and medicine. The National Academies of Sciences, Engineering, and Medicine are the nation’s pre-eminent source of high-quality, objective advice on science, engineering, and health matters. Most of our work is conducted through seven major program areas: Behavioral and Social Sciences and Education, Earth and Life Studies, Engineering and Physical Sciences, Health and Medicine, Policy and Global Affairs, Transportation Research Board, and the Gulf Research Program.

Within NASEM, the Transportation Research Board (TRB):

provides innovative, research-based solutions to improve transportation. Part of the National Academies of Sciences, Engineering, and Medicine, TRB is a non-profit organization that provides independent, objective, and interdisciplinary solutions. TRB manages transportation research by producing publications and online resources. It convenes experts that help to develop solutions to problems and issues facing transportation professionals. TRB also provides advice through its policy studies that tackle complex and often controversial issues of national significance.

The machinery of TRB is its standing committees and task forces:

TRB fulfills its mission through the work of standing committees and task forces, which arenetworks of professional individuals who share an interest in a particular transportation topic.  With over 250 committees, most every transportation topic is represented in the standing committee structure.  Each committee holds regular meetings, disseminates research findings, and most importantly provides a forum for industry practitioners to discuss the issues facing the transportation industry today.

To cut to the chase, the TRB Committees are problem solvers. The Committee members are professionals, subject matter experts for each of the Committees. Within AME60, there were architectural historians and archaeologists, from federal, state and local government, academia, and the private consultant sector. Many had more than 10 years of professional experience in their respective fields. They are truly the best of the best. The strength of the Committee was in its regional diversity. Any of the 50 states could be represented, along with Federal agency perspectives, e.g. FHWA, FRA, FTA. This meant that a problem arising in one state could be assisted by a member from another state that had seen and addressed the same problem.  To the degree the issue was repeated in multiple states or at the national level, the Committee could use the collective knowledge and experience from across the country to find workable solutions.  States are the laboratories for implementing historic preservation law and policy, not just laboratories for democracy.

The culmination of these discussions- not just in Winter and Summer meetings but also on the listserv – was active participation in the NCHRP, the National Cooperative Highway Research Program.  Started in 1962, this program is administered by TRB, but State DOT’s select and fund the specific research projects.  Over the last 10 years, AME60 (previously ADC50) has successfully submitted and overseen multiple studies, ranging from workhorse bridges in rural historic districts, to Section 106 delegation programmatic agreement best practices, to effects and mitigation for highway noise on historic properties.  These were undertaken through the NCHRP 25-25 program, which identifies quick hits using modest budgets. Considering AME60 was competing with other TRB committees for the small pot of funding, it was clear that AME60 punched well above its weight.

The need for AME60

There is an old chestnut among engineers that archaeology and Section 106 holds up projects. Section 106 is the problem, at best an annoyance to be tolerated.  This is simply untrue.  The genius of Section 106 of the National Historic Preservation Act is its flexibility in implementation. Historic Preservation law and regulations are focused on process, public involvement, and intent. (See also Jeff Altschul’s 2025 article.) As such, they are not amenable to cookbook approaches.  In the hands of an expert, there is the flexibility to craft effective and tailored approaches to suit the situation.  I’ve likened Section 106 to a Maserati.  If you know how to drive it, it will outperform anything on the road. If you don’t, you are likely to crash.  Many state DOTs operate under statewide programmatic agreements that use Section 106’s flexibility and work exceedingly well.

Any state can look over its shoulder and copy another state’s best practices – call it an infection model for solutions. It doesn’t happen on its own. Committees like AME60 are the sources for these ideas, which are carried from member to member across the country.  In the annual Committee meetings, literally the room where it happens, the best ideas are shared from practitioners that have made them work in their respective states. I suppose you can buy this knowledge on the street from any of a number of consulting firms.  But the good will and common desire by historic preservation and archaeological professionals to make transportation programs more effective and efficient (not the same thing) provides the best environment for sharing successes. All of the members are unpaid, so essentially this is valuable knowledge given freely.

Having a topic-specific committee is important on two levels. First, it is the sine qua non for legitimacy.  It is being seen. In the land of civil engineers, having your own committee is proof that you are important.  Barring having your own committee, having a subcommittee is the next best thing. Secondly, The process of getting research funded, the NCHRP studies, requires that the proposal gets into a database by being forwarded by the Committees. If you are not at the table, you have little chance of getting your study offered, and hence little chance of it being supported.  Having your own committee gives you the opportunity to put forward research you think is important.  Lastly, being a member of a Committee confers certain rights and obligations. Committee memberships are limited in number.  Getting funding and permission to attend annual TRB meetings often rests on whether you are a member of a committee or not. If you are not attending the meeting because you are not on the committee (or because the committee does not exist), then there is less chance that you are in the room where it happens, etc., etc.

Whither Historic and Archaeological Preservation in Transportation?

AME60 is disbanded. For the reasons above, this is a mistake.  Many state DOTs do not have a problem with archaeology or historic preservation precisely because of the ideas brought forth and implemented by AME60. Historic preservation is well integrated into project design and construction.  There are few surprises. Section 106 issues rarely if ever slow down projects.  Usually funding issues are the culprits.  In some states, and with some agencies, Section 106 becomes a problem and a delay, but in these cases those agencies don’t take advantage of the skill sets of architectural historians and archaeologists to use the flexibility in Section 106. Essentially, agencies exist in one of two conditions. Either an agency efficiently takes advantage of the Section 106 flexibility or it doesn’t. For the ones that do, the heads of those agencies never hear about Section 106 problems. For the ones that don’t, those agency heads know only headaches and often lack the resources to fix them. TRB, AME60, and the NCHRP 25-25 program provide the remedy, but only if they’re around to do so.

If AME60 is not reconstituted, then where do archaeologists and historic preservation specialists do their work and be seen?  Again, with the civil engineering community, if you are not part of a committee, you become invisible. More importantly, your laws, your issues, your value to transportation becomes non-important, until you run into a problem with Section 106.

There is also a possibility TRB places remnant archaeologists and architectural historians into the Standing Committee on Environmental Compliance in Transportation Planning (AEP17).  AEP17 has some affinity to the former AEP70 – the Standing Committee on Environmental analysis and Ecology. AEP17 is the only remaining TRB Committee that encompasses environmental issues.  However, the mission of AEP70 appears different from the AEP17 mission.

TRB Standing Committee on Environmental Analysis and Ecology (AEP70) focuses on the integration of environmentally- and ecologically-sound principles in applied research, education, practice and policy associated with all modes of surface-based transportation.

Standing Committee on Environmental Compliance in Transportation Planning (AEP17) is concerned with research and innovation related to assessing federal, state, and local actions on the natural and human environments, including strategies to address all statutory requirements to improve and expedite planning, resource agency permitting, and environmental reviews.

In the former, the focus is on integrating environmental principles into transportation.  In the latter, the focus is jumping through regulatory hoops.  Not encouraging.  There will certainly be fewer seats available for archaeologists and historic preservation specialists.  They will be competing with other committee refugees for the ever shrinking slice of the research pie. The discussions would be thinner, the research thinner, the value to the greater transportation community thinner.

I hope that TRB reconsiders its decision and reinstates AME60. AME60 has a proven track record and has demonstrably helped transportation navigate federal laws and regulations when it is heard.  AME60 is an irreplaceable resource for both the state DOT’s and agencies that have a sufficient in-house historic preservation staff, but even more so for the state DOT’s and agencies that don’t.

Recently, I was at a banquet. The individual to my left got excited when they asked what I did and I replied I was an archaeologist. The conversation went as I might have expected. They always wanted to be an archaeologist when they were a kid. Check. Then they wanted to know what was my greatest find. Check.  Like the coward I am, I mumbled something about the 16^th century eyeglasses found on the I-95 dig near Philadelphia. A surprising and very cool artifact. I answered her questions politely but completely avoided the deeper point (not Clovis). Archaeologists and archaeology are not really about finds, or even artifacts. Sorry, Indy.

As a young adult, I also found archaeology and ancient history fascinating. Who didn’t?  However, my high school and college sights were set on aerospace engineering.  I was a product of the 1960’s, especially the space race, and was reasonably good in science and math. My father was an engineer.  The die seemed cast.  My encounter with college was humbling, very humbling. Anthropology became my life raft. After a course on Old World Prehistory, archaeology-specifically anthropological archaeology- became my north star.

It wasn’t the artifacts.  I had some modest coin and stamp collections as a kid, but they never really ensnared me. I am still not a collector, although I did have a brief fling with old radios.  I spent a summer at Monte Alban collecting pot sherds, one sherd at a time, one terrace at a time. Many thousands of sherds, lovingly carried down in rucksacks from the mountainside to the lab. Still, I had no real emotional attachment to these potsherds, these artifacts.

What caught me in the classroom and then in the field in Oaxaca were the big questions.  What was the origin of civilization? Where did agriculture come from? Who were the Neanderthals, and more importantly, if they showed up today in modern street clothes, would we be able to tell them apart from us on a crowded street?  After 150 years of intellectual scrutiny, we still don’t have definitive answers, but I do think we are getting closer to the Neanderthal question.

When I got to the field, even the smaller more mundane questions grabbed me. How did this site become this way; how did it form, and deform? Although the artifacts and environmental remains like seeds and pollen are the basic 1’s and 0’s of our information, what goes with what and when are critical questions in answering the question of what happened here.  At an individual site, we act like a bunch of Sherlock Holmes’s, looking for clues, free associations, datable material – anything to put the puzzle together. And Holmes had it easy.  If we are solving a jigsaw puzzle, we are doing so with most of the pieces missing and the remaining pieces damaged to some degree or another.  It is easy to find artifacts in a field. Ask any farmer.  It is much harder to accurately tell the story of a particular site, and by story I mean who lived there and how did they live, and when.

Archaeologists are largely storytellers, historians without texts in many cases. Science guides our pursuit. More precisely the scientific method. Hypothesis, data, test, analysis. More and more current archaeology relies on very sophisticated laboratory methods, in dating, botanical analysis, microscopic analysis of how stone tools were used, DNA, etc. But these are still only techniques and yield only data. 

The real science is piecing this all together to make a credible story, but one that can be challenged by further evidence. Real science is a process of throwing out ideas as hypotheses, gathering data to throw at the hypothesis and prove or usually disprove what is claimed.  In much of science, an experiment can be replicated and either supported or disproven.  In most cases, when an archaeological hypothesis is proposed, there is no way to replicate it. We don’t have time machines (and even if we did, there would be some serious ethical issues. Just ask any science fiction writer). So we are reduced to arguing by analogy, by finding comparable data, by finding parallels where they exist. We are often solving jigsaw puzzles for which there may be no other known copies nor any similar puzzles.

The individual sites and their stories become the building blocks to go after the bigger questions.  How did we evolve from small closely related groups of hunters and gatherers tens of thousands of years ago into complicated and stratified societies only a few thousand years ago? Is the concept of private property innate or something that evolved?  Is capitalism our natural state or is it something else? Are we innately competitive, innately cooperative, or both?  Even the question of what is a family is fair game? Our popular notion of the nuclear family with father, mother, children represents an eentsy, weentsy fraction of human experience. These stories are hard to tell, and because of that become highly contentious. We share that with science and increasingly with history. It does not stop us from trying.

Last April, I watched a session at the national archaeology meetings in April on Submerged Ancient Sites. In particular, several presenters discussed what may have been happening on a land bridge in the middle of Lake Huron called the Alpena-Amberley Ridge, 100 feet below the modern lake surface around 9,000 years ago. Yes, 9,000 years ago, this Ridge was indeed dry land. Using a multidisciplinary approach of remotely operated vehicle mapping, scuba excavations, artifact analysis, predictive modeling, and virtual world simulations informed by modern caribou hunters, these archaeologists were able to make a compelling argument for caribou hunting in this particular space, including the hunting strategy including specifics on the ground. This is archaeological critical thinking at its best. No other discipline could touch it.

Despite the difficulty in getting to answers, archaeologists ask these and other questions that no other field can answer or even try to answer.  We don’t have respondents; we don’t usually have written records; we don’t have all or most of the puzzle pieces. Sociologists and economists don’t see the full range of human behaviors and possibilities. Cultural anthropologists look at the here and now and generally don’t get to see societies changing over many generations.

We do have the two tools in our box other disciplines lack.  Journalists note that today’s news is tomorrow’s history.  But historians have at most 5,000 years of written history and only in a few select places.  Almost all of human history is unwritten, but this is our sandbox.  Our time zones are centuries and millennia – deep time.  With rare exceptions, like Herculaneum, we won’t be able to say what happened from one day to the next. We will go to the last Ice Age to look at cold weather adaptations.  We will go to Cahokia a thousand years ago and ask why? Deep time is a powerful tool.

Secondly, if we are grounded in anthropological thought and the concept of culture, we have at our disposal the variety of human experience across the globe for the last several centuries. It might not tell us how early farmers in the Southeast organized their marriages a thousand years ago, but it tells us what the range of possibilities might be. To the degree that human behavior is patterned and repetitive, this information give us some clues.  And like good cultural anthropologists we can be self-aware of our biases and prejudices in the application of science and analysis.

What are our big problems of today? Adapting to a rapidly changing climate? Increasing income inequality in our society and elsewhere that is destabilizing democratic rule? How do we bring back the family in an increasingly fractured and isolating society? What the hell is a family anyway? As a species, how do we adapt to rapidly changing technology, or more specifically, will AI kill us all and what can we do about it? Archaeology won’t solve these or other problems. It’s not designed that way.  But archaeology provides critical thinking and a frame for understanding these problems, and can point to many more examples where we as a species have been there before and how we dealt with those problems before.  We can help. I even have the conceit that if the US Administration had brought in archaeologists into the room after 9-11, bringing an understanding of the deep history of the Middle East, our approach to Afghanistan and Iraq might have been greatly different and much more successful.

As I was demolishing a pretty good carrot cake for dessert, I looked at the individual on my left at the banquet.  I wish I had the foresight and the words to tell them what I am saying here. Archaeologists can write fancy and use big words and explain big concepts, but we are notoriously bad at simple human communication.  There is an old joke amongst archaeologists on being anti-social.  We are anthropologists, but we like our respondents dead. That’s because we don’t have to talk with them or listen to them.  Like all caricatures, there’s an element of truth to it.  Today, we need all the critical thinking we can muster.  Archaeologists do this and bring stories of people who aren’t around to tell them. We do make the dead speak. Unlocking the past is not some academic exercise. Understanding where we came from provides the grounding for our future. Or as Robert Heinlein put it, “A generation which ignores history has no past – and no future.”

Last month at the SAA Meetings in Denver, the Society took a much-needed break from the never-ending chaos of the current Administration’s war on history and science to continue the Airlie House 2.0 effort.  Looking at the goals of this necessary effort, one almost sheds a nostalgic tear for those halcyon days.  Whether our profession survives the current onslaught remains to be seen. However, it is wise to prepare for the time after.  While this is not our version of Project 2028, for now it’s the best game in town.

The Thursday morning session was well attended, but under the circumstances I would have liked an overflowing room.  Here is the Session abstract.

Session Abstract

The passage of the National Historic Preservation Act of 1966 and both the culmination of a series of topical Airlie House seminars in 1974 and the culminating 1977 Airlie House Report set the course of cultural resource management (CRM) archaeology in the United States for the next 50 years. Now, 50 years later, the profession is transforming, guided by newer and amended laws and regulations, technological innovations, a curation crisis, and social issues such as climate change, environmental justice, and the rights of descendant communities. These changes are affecting how CRM archaeology is practiced, and, in recognition, a workshop sponsored by the Society for American Archaeology (SAA) and National Park Service was held in May 2024 in West Virginia. The workshop drew on the expertise of professionals nationwide and considered four major issues selected by SAA membership that will affect CRM archaeology in the coming decades. This SAA forum will summarize the major topics discussed and recommended action items proposed by the Airlie House 2.0 workshop, which, if implemented, will affect our profession in the coming decades. Membership participation in this SAA forum and implementing change is expected and welcomed.

After brief comments on the various themes from the discussants – Rebecca Hawkins, Karen Mudar, Alex Barker, and Signe Snortland, as well as moderator Kimball Banks – the floor was opened for questions and comments.  My impression from the Session was that the SAA was moving methodically on this, not rushing, and willing to review and revisit any and all positions.

When the SAA solicited for comments a year ago April, I took the opportunity to weigh in, but did not post my comments on my blog or anywhere else publicly.  The SAA reached out to its membership with a status report last October. 

In retrospect and taking in all that happened in Denver that week, I am sharing my comments below.  Most still seem relevant a year later, but where appropriate I am annotating – commenting on my comments, as it were.  Slides were provided by SAA in 2024.

Workforce Training and Careers

It has been my long experience in a career in cultural resources management that everything starts and ends with a trained an motivated workforce, so it is fitting to begin here.

There are a couple of premises that I hold to be true and that drive the discussion with regard to the question, “How do you build an archaeologist?”

1. The very first thing to know is that archaeology is both a profession and a trade.  You cannot build a good archeologist from the classroom only. Remember the term, “armchair archaeologist?”  Likewise someone very good in the field, unless a true savant, cannot have the grounding and theory and method gained from a classroom education to be truly useful. It takes both education (the professional side) and experience (the trade side).
2. The current model of getting an undergraduate education in anthropology and then graduate school with a field school somewhere in there and then starting as a field crew member and working your way up to Principal Investigator is suitable for a small fraction of potential archaeologists.
   • It takes too long.  Eight years, if you include 4 years of undergraduate, 2 years of graduate and then 2 years of practical experience.
   • It costs too much for the return.  College is no longer affordable and even PI salaries aren’t sufficient to cover the up-front costs.
   • It effectively blocks all but those with resourced families that can support this ascent.  And this plays into the racial disparities in familial wealth.  It is possible this alone could explain why archaeology is such a “white” profession.
3. This also disregards the inherent bias against compliance archaeology by the mainline university graduate programs, who continue to train Mesoamerican archeologists or any other cultural region other than the US, who have no useful education or training that would prepare them for a CRM career. More on that later.
4. There is a lot of talk about alternative pathways to building an archaeologist and I think this discussion is worthwhile. However, it is also treacherous insofar as any who wants to pursue this alternative pathway needs a clear understanding of what are the consequences of veering away from the traditional model, codified in the Secretary of Interior Standards.
   • SOI standards are at the minimum, a standard. And generally, they can be applied to an individual to determine whether that individual can meet that standard.
   • Once you agree that there can be an alternative pathway, it is essential that there be national agreement on what is required within that pathway.  And the more flexibility you give in that pathway, the more urgent the need to settle on a national standard of competence.
   • For any student seeking to become that professional archaeologist along this alternative pathway, there has to be a clear plan, i.e., what exactly they need to know and do to get there. Part of the attraction to establishing an alternative pathway is two-fold: less classroom and more OJT meaning less cost and time, and, more ways for entry from a different career.  Choices come with costs. It is inexcusable to tempt a potential candidate with an alternative and have them spinning their wheels because the specific requirements weren’t specific enough.  They think they are making progress toward that brass ring, but are actually veering off into the weeds.
   • If there is an alternative pathway, there has to be some adjudicating group that will certify that the candidate has indeed gotten there and meets those standards. The more flexibility you give in getting to professional qualifications, the more important this becomes.  For geologists or engineers, there are state boards that certify candidates professionally.  Buttressing these boards is an infrastructure of standards, training, and testing, not to mention legal licensing. 
   • Finally, you can’t put dead ends into the mix, meaning you cannot offer a progression from a field-based experience to a Crew Chief and then offer no way to advance to PI other than the traditional approach.  There may be individuals that don’t want to become Professional Archaeologists but want to remain as highly skilled technical workers, but for those that want to advance to Professional status, there has to be a non-traditional route to get there, from each stage of accomplishment.
5. SOI standards have a gaping hole. They do not require any knowledge of historic preservation law or practice, such as Section 106, or NEPA, nor frankly anything to do with consultation with groups that have interests in the projects, such as Native Americans. This needs to be addressed somewhere in the standards we would adopt.

Focusing on the traditional method of getting to professional status, there are several things that can be done to lessen the time required and lessen the economic burden.

1. If we’ve learned anything since COVID it is that there is a useful role for remote learning. This was experimented through MOOC classes a decade ago, but we now know what we can teach remotely and what we cannot.
2. I would argue that any class that was traditionally taught as a survey in a large classroom is a prime candidate for remote learning.  Introduction to Anthropology, Introduction to Cultural Anthropology, Introduction to Archaeology, frankly any course that beings with the phrase “Introduction to….”  I am not saying these courses aren’t important, just that they aren’t necessary to take in person in a university setting.
3. We are already talking about bringing Community College students into universities as a cost-saving measure and as a pathway to an affordable university education.  Many of the courses that a Community College would offer are in the “Introduction to…” realm.
4. This is the opportunity for SAA and RPA and maybe a consortium of universities to assemble a core curriculum of introductory on-line courses that can be offered at any time and no cost to anyone.  If we can establish this curriculum with regards to minimum requirements, we can wipe a half dozen courses off the schedule, at the very least a full semester. For candidates with day jobs, this should be a godsend.
5. Going this route will also require a test of some type to ensure that the candidate has mastered the material.  Use the College Board as a model.

The trade aspect of learning is just as important. To that end, the traditional field school is inefficient, expensive, and non-standardized.  It may be time to bury the idea entirely.

1. Instead, hands-on experience could be gained through a trade union model – apprentice, journeyman, master. This is an opportunity, but there are some caveats:
   • In most trades, there is a union that takes responsibility for certifying the skill levels of its members.  (When I submitted my comments to SAA in 2024, I was unaware of unionization efforts for archaeological technicians. On Thursday afternoon, I heard a presentation from Freeman Stevenson, titled “The Return of Unions to the CRM Industry,” presented in the US Archaeology at the Crossroads Part I Symposium.  The long, hard effort toward unionization appears to be underway with the Teamsters. It remains to be seen if it catches fire.  I have no illusions that it will be easy. After all, virtually every effort at unionizing any sector of the economy took decades. Still, Stevenson and others give me hope.)
   • In this model, the unions set up off the job training and oversee it. (I confirmed with Stevenson that his efforts include this model of union training, currently housed in West Virginia.)
   • Work at any of these levels is paid work, through the terms of the contract. More skill means more pay.  Lower level trade members work under the supervision of a higher level. Archaeology has done training in this manner for decades, but we are loathe to call it that, since we are “professionals,” not plumbers. And we either grossly underpay our underlings, or not at all.
   • Industry is part and parcel of this arrangement. This is how they get trained workers. They offload the training and certification to the union.  Collective bargaining agreements manage the relationship.
   • Archaeology could unionize and set up an arrangement for training along these lines. (See comments above.) If they don’t, then following this trade union model (which I believe to be a good model for training), would require setting up some national or regional system for overseeing the training and certifications.
2. At the end of the line, there needs to be some certifying organization that would judge candidates, possibly at the levels of crew chief and Principal Investigator/Professional Archaeologist. Standards probably need to be national to allow movement between states.  There could be qualifiers for regional expertise built on top of the standards.

I haven’t spoken to some of the education that I consider essential to making a good professional archaeologist. That is coursework in cultural anthropology, especially political anthropology and, yes, anthropology of religion.  One of the shortfalls of current archaeological training is the overemphasis on practical field techniques over a strong grounding in anthropology.  Especially when working with descendant communities, a good anthropological background is invaluable. In the future archaeological environment, avoiding consultation with descendant communities is a non-starter.

Melding the professional and trade aspects will require some coordination. Schools like Drexel University already incorporate a strong internship practice within their programs. Aggressive merging of on-line classes, OJT, and a trade union model of apprenticeship could reduce the classroom component of professional training to 3-4 years (In my estimation), resulting in a Master’s Degree.  Overall, it may take a person the 6-8 years to get there, but they will be fully employed during most of it.

Will the academy go along with this? I doubt it. They haven’t to date and this disrupts their traditional models of education.  What I would say for land-grant institutions is this. “Not only have you received your charters from the Federal Government as well as much support, but also have built your institutions on land taken from the Indigenous Peoples that inhabited it earlier. You owe two debts in the telling of the history of this country, one to the public at large, and one to the original inhabitants. Archaeology is one method of telling a history that wasn’t written down or a history only told by the victors.  Establishing an archaeology program that doesn’t include the state you are in is simply negligence of duty.” SAA and RPA need to bring the full force of their influence on this point, not just to the university presidents and deans but the state legislatures that fund these institutions.

Is there an impending shortage of archaeologists or not?  I keep getting two different answers and I’m not sure everyone is speaking from the same data.  Altschul and Klein sounded the alarm 2 years ago in a deep dive of the future for the profession.  Yet at the SAA Meetings in NOLA, Chris Dore in Session 293: Transformations in Professional Archaeology, Industry Challenges for Cultural Heritage Consulting Firms in North America, strongly suggested the issue was overblown and there are sufficient archaeologists to meet future demand.  Can both views be correct?  I have my doubts.

Part of the problem may be on which data each argument rests.  Altschul and Klein seem wary of US Bureau of Labor Statistics data as showing the full picture, while Dore seems to rely heavily on that data. Dore also seems to accept that PhD’s generated from the academy will be suited to the CRM world.  My own anecdotal surveys show regional unevenness and unevenness in level of archaeologist.  Some parts of the country seem to be OK at the moment for supervisory archaeologists but are having trouble getting field crew. Other parts of the county see vice versa or any other combination.  So it is hard at the moment to see a national trend, whether there is one or not.  Perhaps the biggest difference is that Dore sees work declining in future years, while Altschul and Klein see an explosion shortly. (In any case, the recent wide-spread firings of Federal employees, including archaeologists and the intentional weaking of environmental and historic preservation laws and regulations may resolve the issue simply by eliminating the need for CRM studies, therefore eliminating the jobs.)

My own takeaway from this discussion is that we need to focus on the way we are currently producing archaeologists, which is inefficient, and socio-economically discriminatory.  I do believe the issue of field crew will be solved in the market. You have to pay people better to get folks who will work in that environment. Plain and simple.  It appears that this is starting to occur, but still there are gaps in matching a “trained” workforce with jobs.

A final thought. Bureau of Labor Statistics grossly underreports archaeology jobs, yet many universities rely on these numbers to gauge future student interest.  This is to our detriment.  As long as academia has a role in training future archaeologists, and I think they do, putting department after department at risk from dodgy numbers is a bad idea.  SAA and RPA need to be united in pushing the Labor Department hard in the direction of producing more accurate counting of the number of working archaeologists in the US. And they need to do this today. Having a certified and licensed category will point BLS in the right direction.

Diversity in the workforce (a good goal, regardless of what the current Administration thinks)

This continues to be a problem, but I do believe the underlying issue is the amount of family wealth needed to “front” a student through the long and expensive process to reach professional status. Otherwise, the student is likely to incur crushing student loan debt. Targeted scholarships and financial aid only goes so far and it probably unsustainable.  The only way to create diversity in the workforce is to radically cut the costs in time and money to get to professional status. I have offered some ideas above.  People aren’t stupid. You can be welcoming and accommodating ‘til the cows come home, but those economically disadvantaged won’t commit unless they can see a sustainable future in it.  And while better pay in the entry level field crew positions can help there, commensurate pay for professionals is also needed, not just in academia but in government and private employment.

Certification and licensing

I have written at some length about certification and licensing.  To summarize, we need to keep clear the difference between certification and licensing.  Organizations like SAA or RPA or state councils can certify. State or Federal Governments can license.  And while I do support certification at a regional level or national level, licensing should be a goal.  I think this will help with pay, respect (which translates to pay) especially within the private sector land of engineers, and clarity with regards to the Bureau of Labor Statistics.

I think licensing is much more important in cultural resources management than academia, but it wouldn’t hurt to have a segment within academia that are licensed.

Decolonizing-Engaging Descendent Communities

My first recommendation is that the word “decolonization” should be dropped.  It is not useful within the context of Airlie House 2.0 and CRM.  To me, it sounds like bumper sticker sloganeering.  It is designed to offend all but the true believers.  It invites the nativists in our country (an exquisitely choice term which really means the opposite of what it appears to mean) to jump down our woke throats and fight anything we might want to accomplish. Even within our group, we will waste a lot of time trying to define what it means and this is time wasted, when effort needs to be focused on doing. (Everything done since January 21^st vindicates this statement.)

Almost all CRM archaeology is conducted under Section 106, which is a Federal law administered by federal agencies, which are part of the United States Government.  Let me suggest a test. The next time you are in a project meeting with the design team and engineers, just casually suggest that we need to decolonize archaeology.  See what the response is.

There was a lot of good advice in the original Airlie House Report, produced in 1977, relevant to this topic. I think most of it has been ignored in the subsequent 47 years.  While there has been some advances in law and practice since then, it may be a good idea to start with Section 5: Archaeology and Native Americans, and proceed from there.

If 36CFR800 is the basis for most cultural resources management under Section 106, or Section 110 for federal land management, then the core singular point is this.  “As anthropologists, should it not be the archaeologists first responsibility to take into consideration living descendants of those cultures they study?” (their emphasis) (p.90)

There is a special role for consultation with Federally recognized Tribes in conducting compliance archaeology. It is specifically defined in 36CFR800.16
 
Consultation means the process of seeking, discussing, and considering the views of other participants, and, where feasible, seeking agreement with them regarding matters arising in the section 106 process. The Secretary’s “Standards and Guidelines for Federal Agency Preservation Programs pursuant to the National Historic Preservation Act” provide further guidance on consultation.
 
Most consultation takes place within a specific project and in that sense is limiting.  What is ultimately necessary for effective project consultation is building a trust relationship outside of projects.  Many state DOT’s and FHWA divisions have taken that extra step to build a working relationship and I think this is the way to move forward. And it takes respect, humility and hard listening to make it work.  The outcomes of these extra-project meetings and consultations can find value in program wide programmatic agreements.
 
If we can take a wider view of consultation, then some of these other issues will be addressed. We can sit down with the Federally recognized Tribes and figure out how to increase the number and presence of native archaeologists. But we would need to dig deeper and sit down with the Federally recognized Tribes and figure out what are the important questions to ask and what stories to tell.  Not on a project by project basis, but within the profession.  So ultimately, although this is a CRM exercise, the universities have to be willing to bring representatives from Federal Tribes into discussions of how and what to teach in archaeology. Only then will we be taking into consideration the living descendants of those we study.  Hiring one or two indigenous archaeologists to the faculty will not solve this problem, although it’s a good starting point. (See also, Bonnie Pitblado’s 2022 article in American Antiquity 87(3):217-235, On Rehumanizing Pleistocene People of the Western Hemisphere.)

Archaeological Collections, including Records

I don’t have all that much to add to this section, with one exception.  There is an inherent problem baked into the CRM process under NEPA.  The problem is a contracting and timing problem and is created when project schedules force the conclusions from a study to be produced before the collections are fully processed and designated for accessioning.  The NEPA decision depends on the conclusion of Section 106. It is almost always presumed that a draft executive summary serves as the results of Phase I or II investigations.  The design consultant and their archaeological team finishes their work, a NEPA decision is made, and then the contracts are closed out as the (obvious) work is completed.  However, if there are artifacts, a closed out contract doesn’t allow funds for the archaeological consultant to process or accession them.  And there is no obvious hammer to leverage over the consultant since processing the collections is rarely in the punch list of deliverables.  How could they, since it might not be completed until after the project is built years later?

Secondly, funding set aside for archaeology in the design stage is finite. It is spent in order – field work, essential lab work, executive summary, final report, artifact processing and curation.  Often field work and essential lab work consume the entire budget, so by the time the final report and artifact processing and curation is to be done, there is no funding.  Going back to the client and/or prime is out of the question. So the work doesn’t get done.

If there is a data recovery involved in the project, again there can be a contracting problem.  First, almost always there is a separate consultant involved due to the conflict of interest provisions related to NEPA.  The new consultant often acquires the collections from the Phase I or II and proceeds to Phase III.  As before, it may take years for the collections to be fully processed and accessioned and once the project has the ribbon cutting, the contracts are often closed. The total amount needed for curation is a tiny fraction of the total project cost, perhaps $100k versus $100m, so holding the contract open for such a small amount is difficult to sell.  Rarely have I seen adequate provisions set in the contract to reserve monies to complete the curation in a Phase III. It’s really hit and miss.

The Federal Agencies are often not much help. Archaeologists are rarely in the room when contracts are drawn up, and few agencies have the archaeological expertise to bring to bear even if someone thought to ask an archaeologist to help in putting the contract together.

Perhaps the only real solution is to set up a bond model for artifact curation, where the contractor puts up a bond solely for the processing of the artifacts and their ultimate curation.

CRM Archaeology Compliance

If we do the necessary work in fuller consultation with Federally recognized Tribes, we should expect to widen the range of questions we would want to ask from the archaeological record and expand and enrich the kind of stories we could tell.  If we lay the proper extra-project groundwork, we should also be able to achieve better project outcomes not just for those involved Tribes, but the larger society.

A specific comment regarding reporting and grey literature.  The traditional model of creating a standalone report with background (often boilerplate), setting, field methods (standardized), field results (including geospatial mapping and artifact catalog), interpretation, and results was born of the 20^th century. Maybe it’s time to leave it there.

A better way to envision a report is as a virtual document that is assembled for the reader, but the bits and bytes reside in different places.  Leave aside the background section and results and interpretation for the moment.  The setting could be pulled from a multi-layered environmental GIS, requiring only the delimiting of the project area as a polygon.  If the GIS is a cultural GIS, the known site information would be embedded automatically.  Field methods are generally standardized and usually reference guidelines. All that would need to be added are any exceptions to the methodology.  Field results belong in the cultural resources GIS, albeit at a much finer grain.  Every testing unit could be plotted in space, and linked to its stratigraphy and contents. The artifact catalog should reside in the state’s larger artifact collections catalog.  Photos, drawings, and the like could also be tied to units within the cultural resources GIS and reside there as well. What the reader would see is pulled from these various databases and linked through the common project identifier.  Instead of being written as a standalone set of data, each portion would be written once into their respective databases. When needed, they would come together into this “report.” A version of this could be found in the Digging I-95 effort.

The background section would also be pulled from another source. That would be the synthesis of the history of the region, or state.  Think of it like a Wiki-page that could include chronology, geography, themes, with regional syntheses (from Western and Indigenous perspectives), and research topics.  A model for this does exist in England, aka the East Midland Historic Environment Research Framework.

The point of establishing a Wiki-like environment is that it could be amended and modified one project at a time.  And it would replace any of the published state-level synthesis, titled, “The Archaeology of (fill-in-the-blank).” For the background section of a project “report,” the geographic location of the project would direct which section of the synthesis would be pulled.

The conclusions of the project, presumably stating what the important information was gained from the work, would be entered into the synthesis Wiki-site as new information, then pulled out again for the purposes of the “report.”  The important (Criterion D) information gathered from a project would always be within a context of what is known and clearly differentiated from it.  As much of the information contained within the Wiki-site would be available to the general public as could be done, recognizing that some of the information would remain sensitive.

There are several advantages to this approach. First, it would greatly standardize the collection of archaeological information.  It would also ensure the GIS and artifact catalog information would be entered into their respective databases up front, instead of chasing these data sets down after the fact, and either re-entering them, or figuring out how to translate field formats.  It would also lay bare what was learned from the project and presumably advance the state of knowledge one project at a time. And it would give the public a clearer view of that state of knowledge.

In late April, I had the privilege to attend the Society for American Archaeology Meetings, in Denver.  I wondered why I was attending not only this meeting but the Association of American Archaeologists (ATA) meeting on Tuesday and Wednesday prior.  I had been retired from PennDOT for 7 years and had recently ended my term as President of the Pennsylvania Archaeological Council.  What was I doing there? Fortunately, the answer awaited down in the bowels of the massive convention hotel, in a series of windowless rooms.

The ATA meeting always refreshes my batteries, and it is good to reconnect with professional colleagues, even if you are the only one in the room drawing a pension.  The mood in the room was not unlike that of a gathering storm.  Federal probationary employees were being terminated right and left, even those that had worked for a year or more and had come to FHWA, or FRA, or FTA service from lengthy service at state DOT’s, or consulting firms.  Permanent federal employees were being pushed out, but the DOGE reaper hadn’t pushed in the doors at FHWA, yet.  Yes, the mood in the room was like a gathering storm.  Typically at ATA meetings, it is larded with crisp, black humor.  It’s what archaeologists do, so that the meeting outwardly did not present as anything different from any other ATA meeting: playful abuse of the FHWA Preservation Officer, David Clarke (although David could only participate remotely due to one of many travel bans); preservation success stories, especially from the host state DOT; endless sidebar conversations over seemingly insoluble 106 problems, begging other state professionals for reaction, input, solutions.  This time, the conversation included queries over firings and who’s left in the offices, both at USDOT Agencies and at the Advisory Council.  The ATA chair had figured out how to hold a hybrid meeting on zoom. This was both good and bad. Good insofar as more archaeologists could attend. Bad insofar as the meeting was recorded and folks were talking on eggshells. The proverbial elephant in the room sat patiently in the corner as we conducted our business.

On Thursday, the SAA Meetings began in earnest. The elephant relocated, but did not leave.  Using the SAA Meeting App, I had booked a steady dose of “Whither Archaeology” sessions.  The membership was clearly alarmed over goings-on from the Federal Administration.  Everyone wanted some providential guidance on what to do, but none was forthcoming.  Opinions divided along classic lines.  In one camp, members argued for full-on resistance to Administration actions and executive orders, summarized by a t-shirt that appeared during the meetings- red with the image of an arm holding an upraised trowel and the message, “Resist.” Workers of the World Unite meets Orozco. For solutions, specificity seemed lacking.  The other camp argued care and caution.  Fighting back against the Administration required measured actions, to fight smart- legal action, avoiding DEI-tagged language, talk in code, etc. Again, for solutions, specificity seemed lacking.  Thursday was cry-in-your-beer day.

I had hoped the SAA leadership would seize the moment and provide some specific actions that membership could take. Thursday brought several sessions dealing directly with the existential crisis. Discussion, but not action. Thursday turned into Friday, with the main General Membership Meeting that evening. Again, no action. Discussions continued into Saturday with further discussions.  When the Meeting ended, we slow-walked our way to the airport and flew home.

In mid-March, I sent the Pennsylvania Archaeological Council my last President’s blog.  This one was unusual insofar as I focused on the Administration’s attacks on both history and science.  Nothing between mid-March and late April had altered my views, and even in mid-May, I believe the comments stand on their own. Here is an edited version (cleaned up only a little bit):

President’s Report

(My apologies for not talking about all of the different orders and initiatives from the current Administration that give me heartburn, such as climate policy, environmental policy, foreign policy, domestic policy, tax policy, Ukraine, USAID, Israel, DOJ, LGBTQ rights, immigrant rights, human rights, DOGE, general chaos, etc., etc. I need to focus.)

Let me open this post as clearly as I can. There is no Republican science. There is no Democratic science. There is no Republican history. There is no Democratic history.  There is science. There is history.  Now this may be easily misconstrued. History is after all written by the victors and there is history of Republicans and history of Democrats.  Still, one history doesn’t blot out another one. And any single history from a single perspective simply fails to tell the full story.

Science and history have been weighing on my mind lately for two reasons.  First, archaeology could be framed as history told through scientific methods and techniques. We rely on both. Secondly, the current Administration appears to be waging war on both science and history.  In the national scheme of things, we are a flyspeck, an afterthought, a trifle.  But I find it inescapable that the current Administration is waging war on us, whether they know it or not.

The anti-scientific position of the current Administration is documented in who they are selecting to lead the important national scientific and educational institutions (Kennedy, Jr. for HHS, McMahon for Education, etc.), severe and arbitrary cuts in indirect cost reimbursements for research, staffing cuts at Federal scientific agencies (with a particular vengeance toward climate science), and even word censorship that permeates national policy.  The anti-history position is commensurate. And by anti-history, I mean anti- any history other than white (usually male) protestant history, something more in favor a century ago.  The Advisory Council on Historic Preservation has been gutted. One anecdote summarizes DOGE’s Ministry of Truth’s approach toward history.  In the Pentagon’s purge of DEI-related materials from its memory banks, photos of military firsts for women, Blacks, and Hispanics were scrubbed.  And of course, the LGBTQ icon of WWII, the B-29 that dropped the atomic bomb on Hiroshima, the “Enola Gay.”

Under the guise of pushing back on DEI, I believe the current Administration’s goal is to erase the past, at least the past not in synch with its politics. Erase it to be able rewrite it to suit their needs and advance a particular political agenda. This is Authoritarianism 101.  Our job is to tell the past and expand on the telling, not erase it.

I could go on, but we don’t have time. Think for a moment on what the archaeological economy is built: the three-legged stool of academia, museums, and CRM.  Universities are already under attack for supposedly allowing antisemitic activities and DEI on campus.  Columbia is just the first and most prominent.  Understand that none of this has to do with actual antisemitism or diversity, equity, or inclusion policies or activities, and everything to with forcing universities to bow to the Administration’s power and Project 2025 goals. What does that have to do with us?  Check down some of the terms that are being scrubbed from national databases: anti-racism, cultural competence, cultural differences, cultural heritage, cultural sensitivity, culturally appropriate, historically, identity, indigenous community, intersectionality, multi-cultural, native American, race and ethnicity, sociocultural, socioeconomic, tribal, etc. 

Will our professional communication amongst each other be reduced to grunts and hand signals? And as universities feel the pinch from dried-up federal funding and pressure to give fealty to the current Administration, Departments like Anthropology will be even more at risk than they were a year ago.  The same holds for Museums.

CRM has proven to be the backstop of archaeological employment for nearly 50 years. Many good archaeologists, some who I know personally, have been fired from Federal government agencies for no cause other than being probationary. At the current pace, many others will be on the chopping block. The bigger threat will be the gutting of NEPA and Section 106, which governmentally can be done in ways other than Federal staffing reductions and changes to the law. CEQ regulations, which used to regulate NEPA are now just guidance. Large parts of 36CFR800 are not spelled out specifically in the National Historic Preservation Act, but have evolved and been adopted over the last 40 years. That and $3.50 will now get you a cup of coffee.  Two years ago, Terry Klein and Jeff Altschul declared an impending staffing shortfall in CRM.  Two years later, I guess we can thank the President for solving that problem, not by adding trained archaeologists, but by eliminating jobs.

What do we do?  In full confession, there have been days in the last 4 months where I just want to doomscroll, or curl up with a good scotch and binge-watch Ken Burns documentaries (Huey Long is still the gold standard and still relevant). That is not very helpful. So let me propose a few things:

1. Stay informed. As painful as it may be, the political and economic environment is rapidly changing, almost day to day. At the very least, be informed of changes to the Advisory Council, NEPA, Section 106, and any Federal Agency that you may work with. Lately, I have found that Linked-In has more information, especially through Allyson Brooks; Marion Werkheiser, Ellen Chapman and Cultural Heritage Partners PLLC; the SAA newsletters and e-mails.  Find reliable news sources that covers science and culture and follow them.
2. Stay engaged.  Whatever level of action you might have undertaken, please continue.  If protesting in the streets is your thing, great. If letter writing is more to your tastes, write. But there are two things we all could and should be doing. First, find out who your congressional representatives are in the House. Your Pennsylvania senators are John Fetterman and David McCormick.  Let them all know how you feel on specific executive orders that may be illegal under Article I, Section 9 of the Constitution, and proposed legislation.  Tell them the importance of both science and history and by extension, archaeology.  Secondly, talk to your friends and acquaintances, especially the ones that aren’t archaeologists. Make the case for why what you do is important and then ask them to write their representatives and tell their friends. (In discussions in Denver, it became clear that Job 1 for archaeologists is to explain to the public why what we do is important.)
3. Stay defiant but stay positive.  The current Administration wants you to submit to the new status quo as quickly as possible. You can choose to not submit, but to do so you need hope and a vision for a better future (another definition of hope). Don’t give up.  Perhaps Elie Weisel offered the best perspective, “The greatest evil in the world is not anger or hatred, but indifference.”

Introduction

For over 90 years, archaeologists in eastern North America have used the Archaic to denote a time period that preceded the Woodland period.  The Archaic is the kind of term that archaeologists love, because it has become a shorthand for a whole lot of things, not just chronologically.  It is also one of those words that could give offense.  So it is worth our time to take a deep dive into its meaning, its origins, and whether it is defensible as a concept or a word choice.

As archaeologists, we try to use terms in precise ways.  It allows us to use them economically, as a signal of greater underlying meaning. In the moment, we rarely think about why we pick one term over another to indicate an archaeological idea.  As archaeology has evolved as a discipline and as society has changed, some terms lose their meaning. Some become offensive. So we adapt.

Finally, it is very likely that little of what is presented below is new or original. Numerous authors have plowed this ground over the last 30 years, and I weighed whether or not raising these points again are worthwhile. Ultimately, I decided that since there seems to be no current conversation over the Archaic and one is worthwhile, here it is.

Archaic, what?

Some years ago, I was confronted at a Tribal Summit with the fact that archaeologists routinely refer to the period of North American archaeology that existed before European contact as “prehistoric.”  It was considered offensive insofar as it suggested indigenous peoples in North America did not have a history.  Duly noted. Since then, I’ve been more careful in using that particular term, preferring pre-contact, which is descriptive and flexible in that it doesn’t set a specific date to start the subsequent proto-historic or historic time periods.

More recently, I came across a Guide for Referencing Indigenous Communities put out by the New York Archaeological Council suggesting more respectful terminology. Among the critiqued terms were “Archaic” and “Woodland” as well as “prehistoric.”

It got me wondering. Why do we call the time period after Paleo-Indian and before Woodland “Archaic.” What are we actually describing here? And as an aside, why do we go from “Paleo-Indian” to “Archaic” to “Woodland?” It reminds me of the flip flap books, where the top is a penguin, the middle is a bear and the bottom is a rabbit.

I had spent my entire professional career happily oblivious to these and other questions.  The current moment seems to call for other thinking.

Archaic With a Small “a”

Where does the term “Archaic” come from? And more importantly, when we say something is “Archaic,” what are we suggesting?  Should we start at the beginning?  During the last quarter of the 18^th century and first quarter of the 19^th, Scandinavian historians and archaeologists developed  the Three-Age System, a sequence of three stages in the prehistoric past: Stone, Bronze, and Iron (Daniel 1967:79).  Christian Jurgensen Thomson, in 1816 the curator of the newly established National Museum in Copenhagen, organized the vast collections from the peat bogs, burial chambers, and kitchen middens of Denmark into three successive ages of Stone, Bronze, and Iron, as much to get his arms around the collections as to interpret them.  The Three-Age system has been properly described as the “cornerstone of modern archaeology.” (Macalister in Daniel 1967).

Following the publication of Origin of Species in 1859, there was a flurry of scientific and archaeological discoveries.  By the late 19^th century, anthropologists and archaeologists had landed on a theory of unilineal evolution, going from savagery through barbarism to civilization. While the Three-Age system was found to be unworkable in the new thinking – the Three-Age System being mainly about artifactual materials – the developed evolutionary stages incorporated technology, social organization, alphabets, speech, and writing and the presence or lack thereof (see Morgan 1877)

In the first decades of the 20^th century, unilineal evolution had been discredited.  Each new archaeological or ethnological discovery seemed to poke holes in the cultural progressions so carefully worked out 30 years earlier.  Replacing it was a school of anthropology, led by Franz Boaz and others, that played a much smaller theoretical game and focused on description and specific artifacts and behaviors. What we describe as culture change was subsumed under the study of culture processes.

By processes of culture we mean those factors which operate either toward the stabilization and preservation of cultures and their parts, or toward growth and change. Changes, in turn may consist either of increments, such as new developments, inventions, and learned traits acquired from outside; or of losses and displacements.  Beyond these, there are minor alterations or fluctuations that are neither particularly additive nor deductive, as when the wheel base of automobiles is shortened, or the floor is lowered, or the engine is placed behind. (p. 344) (Kroeber 1948).

For anthropology, the work was now devoted to finding and explaining invention versus diffusion.  Archaeology soon followed, explaining cultural change as a product of independent invention or of cultural contact with another society, adopting the new whatever. The culmination of an archaeological methodology to address this historical approach is the Midwestern (or McKern) Taxonomic System, introduced in the early 1930’s. But we are ahead of ourselves.

In North America, the use of the term “archaic” to describe either a stratigraphic level or culture can be traced to 1910 with the description of the lowest level of human remains in the Valley of Mexico and also used by Spinden to describe an archaic people of Nahua stock (Byers 1959:229).  In eastern North America, the term appears as early as 1919, but each example is in lower case and used somewhat generically as an adjective to describe the earliest stage of Algonkian occupation (of New York): 

The first or archaic occupation yields crude implements, such as large and clumsy arrow points, but occasionally very fine spear heads, many net sinkers… (Parker 1923:50)

Archaic could more innocently be ascribed as simply old.  Emerson and McElrath (2009) noted the neo-evolutionary roots of the term archaic, “the Archaic pattern is a reflection of a primitive stage in a cultural-neo-evolutionary sequence.  As noted above, the common meaning of the archaic label itself was inherent in the archaeological definition – to be archaic was to be technologically and socially primitive.” (p.26)  I agree that archaeologists in the 19^th century thought of ancient societies as being technologically and socially primitive. I also agree that archaeologists in the last half of the 20^th century through today likely associate the Archaic with a less technologically and socially advanced society. During this early 20^th century period, I believe that archaeologists and their anthropological theoreticians applied the term more as being really old, but not carrying the bulk of unilineal evolutionary baggage. For me, the tipoff is the small “a” use of the term as an adjective, not a noun.

Archaic with a Capital “A”

This all changes in 1932. William Ritchie described his excavations at Lamoka Lake, ascribing to its inhabitants, 

“an early level of culture based on hunting, fishing and gathering of wild foods, and lacking pottery, the smoking pipe and agriculture.” (Ritchie 1932b; 1980)

He labelled the traits associated with this culture as the Archaic, Archaic Algonkian, and Archaic Algonkian Period (Ritchie 1932a).

In his formulation of a Midwestern Taxonomic System, W. C. McKern more formally established a pattern named Archaic within the five-level taxonomy – focus, aspect, phase, pattern, and base (McKern 1939).  It is important to emphasize that in the McKern system, the focus was on “hierarchically ordered categories of morphologically similar associated component assemblages” (Schwartz 1996).  McKern notes specifically the focus on cultural traits rather than time or space in using the taxonomic system:

In brief, the archaeologist requires a classification based upon the cultural factor alone; temporal and distributional treatments will follow as accumulating data shall warrant. Moreover, the archaeological classification necessarily must be based upon criteria available to the archaeologist.” (p. 303).

The close scrutiny of cultural traits, especially those discoverable archaeologically, fits well into the anthropological theory of the time, that of invention and diffusion, and of core area.  The goal was to figure out, based on traits, where the component in an archaeological site fit in time and space, but more importantly, whether these traits found at this particular site were the result of invention (meaning part of the core area) or a result of diffusion.

As noted by numerous authors (Willey and Phillips 1958, Byers, 1959, Stoltman 1992, Emerson and McElrath 2009), by the 1940’s archaeologists had found that the concept of archaic was too useful to be left to mere taxonomic usage.

Because it now appears that this nonagricultural, nonpottery, hunter-fisher-collector pattern of culture may have been widespread in the eastern United States in early aboriginal times, the term “Archaic” is here adopted to designate this patter manifestation in Kentucky and Alabama.” (Webb and DeJarnette 1942:319)

Ford and Willey applied Archaic to the earliest known cultural horizon in the East.

The cultures of this period were “archaic” in the true sense; horticulture was lacking, pottery is either absent or makes it appearance later in the stage, and the abundance, variety and qualities of artifacts do not compare with the more complex later developments. On the other hand, the archaic cultures established a complex containing many elements which lasted on into later periods. This stage appears to provide a sort of foundation cultural pattern for the East into which new traits and complexes were intruded to form the later cultural stages. (Ford and Willey 1941:332)

Some archaeologists, Sears (1948) among them, found the Archaic concept difficult to fit into either the Midwestern Taxonomic System or into a cultural period.  Ironically, most seemed perfectly satisfied to adopt it into a unilineal cultural evolutionary stage, whether it was the earliest known culture in North America, or as a subsequent cultural period following Paleoindian inhabitants (see also Krieger 1953). Prior to effective chronological dating, there was even some disagreement as to whether the cultures so described as archaic were in fact old enough to warrant that moniker (Emerson and McElrath 2009:25). In the scrum over just what was the archaic, the contemporary anthropological goals of explaining culture change seemed to have been left aside.

The Periods They are a Changin’

A confession. I am a product of the New Archaeology. Where we trace our origins vary. Some put it with Walter Taylor’s 1948 A Study of Archaeology. Others with Leslie White’s 1959 The Evolution of Culture. The shot across the bow may have come in Willey and Phillip’s 1958 Method and Theory in American Archaeology, particularly the oft-cited statement that “American archaeology is anthropology or it is nothing” (p. 2). As unkindly, but not unfairly described by Emerson and McElrath (2009), this led to a stampede of hunter-gatherer interest within Archaic period studies, with perhaps the neo-evolutionary or multi-lineal evolutionary theory running far ahead of the data.  What was clear was the accepted narrative of the cultures living during the Archaic period having a post-megafauna but pre-agricultural hunter-gatherer adaptation to an evolving Holocene landscape.

Almost overnight, the conversation over the Archaic and it’s taxonomic problems were swept under the rug of adaptation, so much so that by the time I entered graduate school in 1976, the origin story of the “Archaic” was never spoken.  The McKern Taxonomic System was relegated to a few paragraphs in the history of archaeology, and lumped with the Boazian particularistic historical approach.  This little trick neatly severed the term Archaic and its time period utility, from any other context or cultural or trait-laden attributes.

Except for a few ne-er-do-wells and post-processualists, this terminological sleight-of-hand has stood unchallenged for 60 years.  An early foray into the newer thinking comes from John Witthoft, who in a piece from 1961, diverges from Sears’ characterization of the Archaic as “a basic culture-complex subject to slight variation over huge times and regions”(1971:97). Instead, Witthoft sees a vast and infinitely variable series of simple technologies, with space and time units often as small as county and century.” He leans toward an anthropological definition, characterizing the Archaic as “the community of a single hunting territory- the band or horde, or the larger community of intermarrying family hunting bands – the tribe in the sense of Australian ethnology.” Later on, he contrasts Archaic with Paelo-Indian’s specialization on large game to Archaic man occupying “every sort of ecological niche available in our temperate regions”(p.101).

By 1985, the Archaic had largely been defined in cultural ecological terms.

With the end of the Pleistocene between 11,000 and 9,000 B.P. a newly diversified biome and moderate climate was established over most of North America. Milder temperatures and the retreat of the ice permitted a more heterogeneous vegetation and fauna to replace the subarctic biotic regime characteristic of the Pleistocene.  Cultural adaptations to this environmental change are characteristic of the Archaic period.” (Raber 1985:11)

The general pattern suggested for the Archaic is, in summary, one of seasonal movement by small bands of hunter-gatherers through a series of base camps, hunting/butchering stations, and special-purpose camps adapted to a wide variety of animal and plant resources. The greater variety of subsistence pursuits is indicated in the archaeological record by a greater variety of site types, artifact types, and floral or faunal remains.” (p.12)

A decade later, archaeologists use the concept of the Archaic as a heuristic, encompassing a time period, a temperate forest hunting-fishing-gathering/collecting economy, and as a tool kit that includes ground stone tools, varied stemmed and notched projectile points, netsinkers, etc. (Raber et al. 1998:121-122).  Also importantly (and we will get back to this later), they note two main problems with the Archaic, namely: 1) Archaic cultural patterns of a hunting-fishing-gathering economy persist well into the Woodland Period, and 2) Early Archaic patterns are “fundamentally indistinguishable from those of the late Paleoindian period” (p.121). Other than a chronological fence line, how would you know you were in one Period or another?

The characterization of the Archaic as an adaptation carries through to the current syntheses.  In its popular iteration (Carr and Moeller 2015), the Archaic is defined as “an adaptation to a forest environment and involves a new set of tools” (p.74).  

They begin to exploit a wide variety of upland environments along smaller bands. In contrast to the Paleoindian period, the bands are less mobile, they do not cover large territories, and populations increase dramatically by the end of the period. In addition, bands begin to regionalize…The Archaic period ends with the appearance of a new and very distinctive set of artifacts. These include broad-bladed spearpoints/knives aptly called broadspears.” (p.74)

The ”professional” version (Bergman et al 2020) is largely the same. However, they do provide some additional context.  They note Ritchie is credited with introducing the term “Archaic” in 1932.

…it is the Archaic period for which archaeologists are able to define and describe specific settlement systems…In the Middle Atlantic region, at least until the 1970’s, a cultural/historical approach dominated the research of the Early and Middle Archaic periods.”(p.107)

In addition:

The Early and Middle Archaic periods mark the transition from the landscapes of the Late Pleistocene into the deciduous forests of the mid-Holocene…This is a time of increasing cultural regionalization, involving band-level societies participating in a foraging economy…The Early Archaic is characterized by a distinctive change in projectile point design associated with significant environmental changes beginning at about 10,000 BP.” (p.105)

the Early Archaic is frequently characterized as the first adaptation to a Holocene environment.”(p.107)

Not everyone was with the program.  Nearly 30 years ago, Jay Custer (1996) chose to create a taxonomy of cultural periods that did not include the Archaic (nor Woodland for that matter) as a lifeway.  While accepting the use of the Archaic strictly as a time period (8,000-1,500 BC), he notes:

The major complication in the use of the chronological system in Table 1 arises from the fact that the main period terms (Paleo-Indian, Archaic, and Woodland) have come to be associated not only with chronological periods, but with types of prehistoric lifeways as well. (p.19)

Custer’s solution for the taxonomy of cultural periods (p.21, Table 2) was :

Hunter-Gatherer I

Hunter-Gatherer II

Intensive Gathering-Formative

Village Life

Contact

This taxonomy was not widely adopted, but certainly begs the question, “Why not?”

When We Say Archaic, What Do We Mean Exactly?

Since its introduction over 90 years ago, archaeologists have used the term Archaic to denote a stage in unilineal evolution, a pattern in an asynchronous and spatially floating taxonomic system, a pejorative, a time period, and a cultural adaptation.   If there is something like a consensus, archaeologists would agree that in the Eastern United States at least, “The Archaic” is pre-ceramic, pre-agricultural, post-Pleistocene, and post-Paleoindian.  As a time period, “The Archaic” (in Pennsylvania) starts around 10,000 years ago and ends around 3,000 years ago in the Upper Ohio Valley and Susquehanna Drainage Basins and 2,800 years ago in the Delaware Drainage Basin (Carr et al 2020).   Finally, “The Archaic” is associated with a hunter-gatherer-collector adaptation to a deciduous forest environment.  While noting some difficulties pinning down the specifics of the Archaic, especially when it starts, when it ends, what changes from one period to the next, its use as a cultural adaptation has largely been uninterrupted for the last 60 years.

For argument’s sake, let’s drop the word choice “Archaic.” We’ll call this thing “Fred” instead.  And my apology to all the Freds out there who might take offense.  How well does Fred hold together as a time period, an adaptation, etc.? Let’s start with pottery.  We now know the earliest pottery in the Eastern United States was produced during the Late Fred by the Stallings Culture in southeastern Georgia. In Pennsylvania, you see a continuum of hard vessel manufacturing from steatite to steatite-tempered during the Late Fred to Early Woodland time periods. This also does not take into account vessels not made from stone or clay, but which functionally served that purpose (Stewart 2003:8-9).  Anderson and Sassaman bluntly state “The appearance of pottery…no longer marks the end of the Archaic (now Fred) and the beginning of the Woodland period as it once did (Anderson and Sassaman 2012:107).

OK, what about agriculture?  Implicit in the adoption of an agricultural economy was the notion of moving away from a hunter-gatherer-collector economy.  Unfortunately, the peoples of precontact Pennsylvania didn’t drop their spears, atlatls and collecting baskets on a Friday and pick up corn kernels and a hoe on a Monday.  In Pennsylvania, the “Three Sisters-“ corn, beans, and squash did not appear in the diet at the same time. Squash seems to have come first, around 5,400 BP, and domesticated independently from Mesoamerica (Hart and Asch Sidell 1997). Maize followed around 2,000 BP, then Beans a thousand years later.  Beyond the Three Sisters, sumpweed and chenopodum were domesticated during the Late Fred, and sunflower was introduced from the west also during the Late Fred. When pressed, I believe all archaeologists would concede the journey from wild plant collection to domestication was uneven and falling under a long trajectory, one which in Pennsylvania certainly started in the Fred.

The Fred serves as a time period, lasting approximately 7,000 years. It is twice as long as the subsequent Woodland period, and is probably longer than the earlier Paleoindian period, 16,000 BP to 9,900 BP (Carr et al 2020).  7,000 years is a long time, so archaeologists have subdivided the Fred into Early, Middle, and Late sub-periods. The distinctions between these sub-periods are largely heuristic (Bergman et al 2020:106) and as much rely on changes in projectile point typology as anything else. In Pennsylvania, we have the Transitional period, which either embeds within the Fred, or follows the Fred and precedes the Woodland, depending on who you are talking to.

As suggesting a really old time, Fred may have had some agency when first coined, but since then has been pushed aside by earlier and earlier periods, first Paleoindian, then pre-Paleoindian.  We are now talking earlier and earlier dates for entry into North America. No one is really blanching anymore if someone throws out a date of 30,000 years ago. The Fred seems positively youthful in this context.  Any adjective tag suggesting this period is very old seems to have lost its sting.

Lastly, we have the hunter-gatherer-collector adaptation.  This brings our focus into cultural ecological questions of diet, hunting and gathering strategies, sedentism and settlement, and social organization. Yet all we know of the Fred is that people were pre-agricultural.  The Kalahari Bushmen were pre-agricultural. So were the Northwest Coast Chiefdoms. Prior to 9000 years ago, all human societies were pre-agricultural.  A hunting-gathering-collecting adaptation was common and highly varied in our ethnological past. If you looked at the entirety of the California Indian societies, you would see a lot of diversity, but all of it would be put into the hunter-gatherer-collector bucket. So what I am saying is that although the Fred adaptation could reasonably be categorized as hunter-gatherer-collector, I don’t find it all that helpful.

Michael Stewart (2003) believes that taxonomy matters. I concur.

Any discussion or synthesis must begin with a consideration of how we have segmented regional prehistory (periods like Early and Middle Woodland), what we want these segments to mean (or what we think they mean), and the archaeological systematics that we have employed in their definition (primarily, the methods that we use for “telling time” on archaeological sites, especially those exposed at the surface…What is the point of periodization? What do we want these periods to be? Are they to be defined as times during which cultures exhibit common themes in lifestyle, or are they simply a way to chronologically organize our discussions of archaeological data, a common language that makes communication between researchers easier? In any case, using the periods as they now stand presents some real problems in terms of how we tell time (one aspect of archaeological systematics) and how we gauge and explain cultural change through time. (p.4-5)

I do believe he was referring to the Fred, as well as the Woodland, and Paleoindian periods.

Is the Fred Still Worth Keeping?

When one of our terms are challenged, we naturally give a harrumph and expend great effort in defending it, both its utility and pedigree.  This is not always wise.  To the degree we see ourselves as scientists, we should welcome any and all challenges to our word choices, and put the terms to that ultimate test of whether it economically conveys what it intends.  If it does, we should file that test in our memory banks. If it does not, we should sit down and rethink what it is we are trying to say so economically, but perhaps incorrectly.  If the term is offensive to one group or another, we should sit down again and more carefully evaluate our choice of words. Sometimes a simple adjustment can suffice, e.g. pre-contact for prehistoric.  However, even in this change, there is an implicit shift in thinking about what constitutes history.  So there actually may be no simple adjustments in language.  Words convey meaning, whether it is our intended meaning or not.

For argument’s sake, let’s keep the concept of a period that follows the Paleoindian and precedes the Woodland.  To continue for argument’s sake, let’s no longer call it the Archaic if we are asked to no longer do that.  Does a word swap, be it Fred or something possibly more descriptive (mid-Holocene?) solve our problem?  I have my doubts.

This period doesn’t have a clear beginning nor a clear end.  It continues to be characterized by what it is not (pre-ceramic) more than what it is characterized by.  Even within the cultural ecological paradigm, the period remains too long, too vague, too non-descriptive to really propel effective archaeological research or theorizing.

Some have suggested dropping the idea of a period entirely and just refer to dates or date ranges when discussing archaeological sites and assemblages. While this certainly could be effective in many cases, it does not scratch my cultural ecological itch and seems like a step back into the Boazian world.  Stewart is again correct insofar as the choice of a period and the terminology to describe that period should be tooled to the kinds of questions one is concerned with, and might actually vary depending on those questions.  Whether you trot out the Transitional may well depend on whether your focus is on how cultures became the Woodland, rather than what people were doing some 2,000 years earlier.

For those of us still interested in cultural evolution and cultural ecological adaptations, dropping the old term could actually be liberating.  If we took away the one-to-one hunter-gatherer-collector association, we might actually be forced to look at the data and try to figure out what people were actually doing. Perhaps we could start scratching away at the wide variety of adaptations and localized histories to either tell that story or build a more compelling multi-lineal evolutionary one.  This might be the unintended missive from Emerson and McElrath (2009) and a gift from groups that find offense in the term.

Bibliography

Anderson, David G. and Kenneth E. Sassaman

2012    Recent Developments in Southeastern Archaeology. From Colonization to Complexity. SAA Press. Washington, DC.

Bergman, Christopher A., Kurt W. Carr, and J. M. Adovasio

2020    The Early and Middle Archaic Periods in Pennsylvania, In The Archaeology of Native Americans in Pennsylvania, edited by Carr et al, pp. 105-139. University of Pennsylvania Press, Philadelphia.

Byers, Douglas S.

1959    An Introduction to Five Papers on the Archaic State.  American Antiquity 24(3):229-232.

Carr, Kurt W., Christopher A. Bergman, Christina B. Rieth, Bernard K. Means, and Roger W. Moeller (editors)

2020    The Archaeology of Native Americans in Pennsylvania. University of Pennsylvania Press, Philadelphia.

Carr, Kurt W. and Roger W. Moeller

2015    First Pennsylvanian: The Archaeology of Native Americans in Pennsylvania. Pennsylvania Historical and Museum Commission, Harrisburg.

Custer, Jay F.

1996    Prehistoric Cultures of Eastern Pennsylvania. Pennsylvania Historical and Museum Commission, Harrisburg.

Daniel, Glyn

1967    The Origins and Growth of Archaeology. Thomas Y Crowell Company, New York.

Emerson, Thomas E. and Dale L. McElrath

2009    The Eastern Woodland Archaic and the Tyranny of Theory. In Archaic Societies: Diversity and Complexity Across the Midcontinent, edited by Thomas E. Emerson, Dale L. McElrath, and Andrew C. Fortier, pp. 23-38. SUNY Press, Albany.

Ford, James A. and Gordon R. Willey

1941    An Interpretation of the Prehistory of the Eastern United States, American Anthropologist 43(3, Pt. 1):325-363

Hart, John P. and Nancy Asch Sidell

1997    Additional Evidence for Early Curcubit Use in the Northern Eastern Woodlands East of the Allegheny Front. American Antiquity 62(3):523-537.

Kent, Barry C., Ira F. Smith, III, and Catherine McCann

1971    Foundations of Pennsylvania Prehistory. Anthropological Series of the Pennsylvania Historical and Museum Commission Number 1. Harrisburg.

Krieger, Alex D.

1953    New World Culture History: Anglo-America. In Anthropology Today: An Encyclopedic Inventory, A.L. Kroeber (ed.) pp. 238-264. University of Chicago Press, Chicago.

Kroeber, Alfred Lewis

1948    Anthropology. Race, Language, Culture, Psychology, Prehistory.  Harcourt, Brace and Company, New York.

McKern, W. C.

1939    The Midwestern Taxonomic Method as an Aid to Archaeological Culture Study. American Antiquity 4:301-313.

Morgan, Lewis Henry

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Parker, A. C.

1923    Outline of the Algonkian Occupation of New York. In “The Algonkian Occupation of New York.” Researches and Transactions of the New York State Archaeological Association 4(2): 49-80. Rochester, New York. 

Raber, Paul A. (preparer)

1985    A Comprehensive State Plan for the Conservation of Archaeological Resources, Volume II.Pennsylvania Historical and Museum Commission, Harrisburg.

Raber, Paul A. and Verna L. Cowin (editors)

2003    Foragers and Farmers of the Early and Middle Woodland Periods in Pennsylvania. Recent Research in Pennsylvania Archaeology Number 3. Pennsylvania Historical and Museum Commission, Harrisburg.

Raber, Paul A., Patricia E. Miller, and Sarah M. Neusius (editors)

1998a  The Archaic Period in Pennsylvania: Hunter-gatherers of the Early and Middle Holocene. Recent Research in Pennsylvania Archaeology Number 1. Pennsylvania Historical and Museum Commission, Harrisburg.

1998b  The Archaic Period in Pennsylvania: Current Models and Future Directions. In The Archaic Period in Pennsylvania: Hunter-gatherers of the Early and Middle Holocene. Edited by Raber et al., pp. 121-137. Pennsylvania Historical and Museum Commission, Harrisburg.

Ritchie, William A

1932a  The Algonkian Sequence in New York. American Anthropologist 34:406-14. Menasha.

1932b  The Lamoka Lake Site. Researches and Transactions of the New York State Archaeological Association 7(4). Rochester, NY.

1980    The Archaeology of New York State. 2^nd Edition. Harbor Hills Books, Harrison, NY.

Schwartz, B. K.

1996    The McKern Taxonomic System and Archaeological Culture Classification in the Midwestern United States: A History and Evaluation.  Bulletin of the History of Archaeology 6:1(3-9).

Sears, William H.

1948    What is the Archaic? American Antiquity 14:122-124.

Skinner, Alanson

1919    Exploration of Aboriginal Sites at Throgs Neck and Clasons Point, New York City. Contributions from the Museum of the American Indian, Heye Foundation 5:47-126. New York.

Stewart, R. Michael

2003    A Regional Perspective on Early and Middle Woodland Prehistory in Pennsylvania, In Foragers and Farmer of the Early and Middle Woodland Periods in Pennsylvania, edited by Paul A. Raber and Verna L. Cowin, pp. 1-33. Pennsylvania Historical and Museum Commission, Harrisburg.

Stoltman, James B.

1992    The Concept of Archaic in Eastern North America Prehistory. Revista de Arqueología Americana5:101–118.

Taylor, Walter W.

1948    A Study of Archaeology. American Anthropologist 50(2, Pt. 2) Memoir 69.

Webb, William S. and David L. DeJarnette

1942    An Archeological Survey of Pickwick Basin in the Adjacent Portions of the States of Alabama, Mississippi and Tennessee.  Smithsonian Institution Bureau of American Ethnology Bulletin 129. USGPO, Washington.

White, Leslie A.

1959    The Evolution of Culture. McGraw-Hill, New York.

Willey, Gordon R. and Philip Phillips

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Summary

In early October, the Register for Professional Archaeologists issued a revision to its categories for student/early career, registered Archaeologist, and registered professional archaeologist. They   found that some adjustments were necessary to close the gaps between categories and provide better clarity in how archaeologists can qualify for each category.  These revisions are fairly minor and within the scope of the effort, fairly reasonable.

That said, I believe that a more aggressive and radical approach to the categories is warranted and necessary.  Basically, we are facing a shortage of professional archaeologists to handle upcoming Section 106 work. (See Altschul and Klein 2022) This should challenge us all to take a fresh approach to minting professionals.  In wide-ranging conversations both in Pennsylvania and at the national SAA meeting, it has become clear that the two main barriers to having a larger professional pool are time and cost.  Time to check all the boxes for a BA, an MA, and 2 years of experience.  The cost should be self-evident if it requires 6 years of college and graduate school to reach the brass ring.

With all due respect to RPA and its sincere intentions to tweak the current categories, I offer a category model that tackles both progression and degree barriers.

Comments

Thank you for the opportunity to comment on the RPA’s proposed Registration Categories.  I believe RPA is one of the main voices, perhaps the best-positioned voice, to articulate what is and is not a professional archaeologist.  The National Park Service has laid out Professional Qualifications for an archaeologist, but these have not been updated, despite numerous attempts over the last 40 years. In addition, the NPS Qualifications are largely responsive to National Park needs, but have been adopted by numerous agencies and organizations for want of anything better at a national level.  The Society for American Archaeology seems largely disinterested. This leaves you.

In disclosure, in the past I have argued that the profession needs licensing and still continue to do so.  Basically, we are facing a shortage of professional archaeologists to handle upcoming Section 106 work. (See Altschul and Klein 2022) Initial Federal response appears to be to reduce or eliminate professional standards to allow more individuals to lead these studies.  Our profession is left in the unenviable position to be unable to point to any consistent National standards that are the minimum. Neither is there any licensing in any state, even though similar professions like geology, have that structure in place. (Not to mention law which is an important profession but arguably has lower education/experience requirements than archaeology to be proficient). We are in the Wild West whether we acknowledge it or not.

In order to make my comments, I have restructured the tables for each skill theme moving from student/early career through archaeologist, to registered professional archaeologist.  As a single table, it makes some sense, especially for those individuals that wish to join RPA and need to know which lane they should enter.This gets to the crux of what you is being proposed and how it will be used.  And this is where I am somewhat confused.  Under the Registration FAQ, there is a differentiation between  registered professional and registered archaeologist with respect to an advanced degree, but does not otherwise differentiate between the two with regard to whether each is an archaeologist.  Yet, there is a qualitatively differentiation of a registered professional from a registered archaeologist as someone having “advanced knowledge, academics, experience, and professionalism in Archaeology.” A registered professional is better than a registered archaeologist. But under the registered archaeologist Category, an archaeologist meets RPA professional standards and requirements for registration, but hasn’t completed the advanced degree.
 
Understand this confusion has nothing to do with skill or experience. We all know individuals that can dance around so-called professionals, but don’t have the advanced degree. And I think the structure of the registered archaeologist is a tacit acknowledgement of that. However, in our current times and situation, I believe this fuzziness is not useful.  And especially without national registration or licensing, a consumer of archaeological services is left on their own to figure out whether a registered archaeologist or registered professional will do the job. In a number of state and federal agencies, the selection of NPS standards settles the issue, but both private sector and governmental jobs have minimum requirements much below NPS standards, meaning registered archaeologists and registered professionals can compete for the same positions with the same levels of responsibility and for better or worse the same pay.  In a free-market, capitalist system this is what we’d want. Choice.  But with regard to the coming staffing crisis, it also invites chaos.
 
I would invite RPA to rethink and reframe its categories, not statically, but as a progression. Someone entering RPA as a student is unlikely going to stay as a student permanently.  Someone entering as a registered archaeologist may have aspirations to a registered professional, or not.  For these individuals, the Category standards act as a list of objectives. Perhaps, you do not have the resources or life situation that gets you to the professional category in one gulp.  Registered becomes an intermediary step, a safety island that can provide income and some status while pursuing or deciding whether to pursue a professional career.
 
If we reframe these categories as a progression, how do these “skill themes,” i.e. Education, Major, Experience, etc.,  perform for someone making a progression step-wise to a professional career?
 
Education
 
Even though you can become a registered archaeologist with a certification program or AA/AS degree, could you ever have been eligible for Student/Early Career being enrolled in those programs. It is not clear that accredited higher education institution covers an AA/AS degree or a certification program. Does the international equivalent cover certification or AA/AS degrees or just the BA or BS? It’s not clear.
 
Secondly, if you are a registered archaeologist, becoming a registered professional if you reached registered archaeologist through a certification program or AA/AS degree likely would require you to go back to college or university, a school that might or might not accept your AA/AS or certification credits.  There’s as good a chance you would regress back to Student, losing any educational training you would have received.
 
It may be suitable to set the education requirement for a registered professional at the advanced/graduate degree. Certainly, the NPS Qualifications for archaeologist requires the advanced degree. But archaeologist is the only Qualification that requires that advanced degree. All of the other NPS listed professions allow a BA/BS with experience to substitute. I’ll come back to that later.  And I will also note that a number of state and Federal agencies are dropping any degree requirements for many of their job openings.  Do not presume that archaeology will be unaffected.
 
Finally, it has become increasingly important for archaeologists working in real world situations in the US to have some background in Section 106, including Tribal consultaton, and public coordination, not to mention NEPA. Nothing in NPS standards requires any of this practical understanding of why most archaeology is done in the US or why it is so important to engage the local community and interested Tribal Nations.
 
Without being too specific, any registered archaeologist should have a minimum of 10 hours of Section 106 and NEPA training and another 10 hours of public outreach and Tribal coordination training. I think it would be hard to accept RPA’s Codes and Standards if you don’t know what they mean.
 
For a registered professional, whatever training is established for a registered professional vis a vis Section 106, NEPA, and public/Tribal coordination should be presumed.  In addition, a registered professional should also have the equivalent of a college course on historic preservation law and regulations, to include Section 106, but also NAGPRA, relevant Executive Orders, and NPS Guidance on the National Register, etc.  See Experience for additional practice.
 
Major
 
These requirements seem reasonable and thoughtful; how would they apply to the registered archaeology candidate who obtained their education through a certification program or AA/AS degree.  There are a handful of schools that offer an AA in Archaeology.  If the AA/AS must be in anthropology, archaeology, classics, etc., the skill theme should make that clear.   Otherwise, it might leave some candidates misdirected.

Experience
 
Looking at the RA standards for Experience, it would seem this is what a crew chief or field director would need at a minimum to be capable, but is this what RPA is aiming for? And the RPA standards require supervisory experience, but makes no mention of acquired practice under supervision, as in RA. Does the Experience standards presume they are additive? The other skill themes do not. My assumption is this skill theme is additive, but it should be spelled out.
 
Suggesting that being a principal investigator is how you meet this skill is a bit problematic in a progression model.  How do you become a principal investigator (PI) if being a registered professional archaeologist becomes the standard for being allowed to be a PI?  Many of us demonstrated our supervisory experience for NPS Qualifications by being crew chiefs and field directors under supervision of someone already qualified and therefore signing off on any piece of work.  Maybe my problem is with the use of the phrase “e.g., Principal Investigator or international equivalent.”  I also wonder if placing “bringing research to conclusion” belongs here or under Research Document, or whether Research Document is really what we want as a skill. Perhaps documented research ability is a better skill goal. Unless what is meant by “bringing research to conclusion” involves the logistical end of archaeology, meaning background research, field effort, cataloguing, and analysis, but not necessarily interpreting and writing up the results.
 
If these categories are a progression, then for a registered professional, it would be useful to state that this supervisory work is done under supervision of someone already a registered professional.
 
Research Document aka Demonstrated Research Ability
 
Reading between the lines on these categories in this skill theme, it appears to me that Research Document for the registered professional is a surrogate for the age-old question of demonstrated research ability, i.e. whether someone is capable to carry archaeological research to completion.  Half of the question is whether someone can think like an archaeologist? This is more realistically answered by whether they were able to navigate an advanced degree or not, which is largely drawn from the Education skill theme. The other half is physical proof in the form of a thesis, or, two technical reports. Can the person carry a specific project to completion, from what I read as drawing on actual archaeological site data.
 
For the registered archaeologist, the Demonstrated Research Ability requirements could be less, or not. A thesis-equivalent document could be an actual (BA) thesis, or it could be an extended paper. If no thesis-equivalent document, then a technical report that would contain substantive data analysis directed toward an explicit archaeological research problem.  This seems no different from the registered professional standard, with the difference being two technical reports for the professional.
 
Could the technical report be a Phase I survey that identified an archaeological site? Could the two technical reports required for the professional standard be two Phase I reports?  This is not clear, but I don’t see any reason why definitionally, they couldn’t. And for that reason, I don’t necessarily agree with these standards, at least for the professional category.  For the registered category, I am not sure, but if RPA is representing the registered archaeologist as a professional without an advanced degree, I would say one Phase I archaeological survey report with a site would be insufficient as well. It really comes down to what skill set a registered archaeologist needs to demonstrate to RPA and to the public. And for that, I am unclear.
 
Sponsor
 
I think it is reasonable to have at least one reference from someone in the profession.  For the Student/Early Career, I think the emphasis should be on character, so a reference from the head of the program in which the student is enrolled, or in the case of an early career, a reference from someone familiar with their work in a supervisory capacity as either an RA, RPA, or someone meeting NPS Qualification would be sufficient.
 
For the registered archaeologist, I would drop the requirement that one of the references be from an RA or RPA member.  Seems cliquish, and it is not required at all in the registered professional category.  Someone familiar with their work and someone familiar with their character should be sufficient. Again, a professor from their degree program, and someone who has supervised them either as an RA, RPA or someone meeting NPS Qualifications (per the 2-year supervised experience skill theme).
 
I would absolutely require the same references for registered professional, unless the candidate was already an RPA member as a registered archaeologist. (Is that why none is required in the text?)
 
Other

Mostly OK as written, but I would put additional training in Section 106 and Tribal Consultation here.  In addition, I do think it appropriate to include a national exam, which should normalize the ways people come to be a registered archaeologist or registered professional.
 

Are These Categories Adequate to Meet the Profession’s Needs Going Forward?

If we are concerned with trying to build an alternate pathway for a professional archaeologist that does not require 4 years of college, plus a master’s degree, plus two years of experience, then the answer is no.  Until we manage to develop a way for students and workers to advance stepwise in the profession without requiring only the traditional pathway, we won’t be able to succeed.  Cost and time, and cost more than time, will limit our pool of potentially good archaeologists to only those with means and patience, and means more than patience.

Rethinking the Roles of the Registration Categories

Looking at the categories of registered archaeologist and registered professional, I have in mind the progression in most union trades, from apprentice to journeyman to master. Apprentice maps fairly well on to Student/Early Career.  Is it possible to imagine the categories of registered archaeologist and registered professional to be comparable to that of journeyman and master?  Both journeyman and master have definite roles.  Each requires education and experience and an exam.  Some working as a master has greater autonomy, often supervises journeymen, and can perform higher levels of planning and design.  To the degree that archaeology is a trade or practice, this model is reasonably applicable.

Since the majority of the need for RPA certified archaeologists comes from the private sector and government, I would propose a bifurcation of registered archaeologist versus registered professional along a scale of complexity of the archaeological research. A registered archaeologist could conduct background research, a Phase I survey, identify archaeological sites, process artifacts, analyze the results with respect to whether there is an archaeological site present or not and make a preliminary determination of whether the site would be eligible or potentially eligible for listing in the national register.  They would complete the necessary report or paperwork and sign off on it. They could supervise crew in both field and lab and supervise background research.  Under this scheme, most of the archaeological work conducted in the United States under Section 106 could be completed by registered archaeologists

Student/Early Career
 
I would revise the skill themes as follows for a Student or Early Career candidate (see Revised Table):
 
Track 1 or 2
Education and major: Currently enrolled in or having graduated from within the last two years in an accredited higher educational institution (community college, college, or university)  Anthropology, Archaeology, Classics, or another germane discipline with a specialization in archaeology from an accredited institution
 
Track 3
Education and major: A High School Diploma plus 60 hours of additional instruction/training* in archaeology, anthropology, classics, or other germane discipline with a specialization in archaeology, including culture history, method and theory. Introductory RPA-designated instruction.
 
For all Tracks
Experience: non required.
Demonstrated Research Ability: non required.
Sponsor: Two references, one of which may be from a professor familiar with the candidate’s work.
Other: Accept Register’s Code and Standards and Grievance Procedures

Registered Archaeologist

I would revise the skill themes as follows for a registered archaeologist

Track 1

• Education and Major: undergraduate degree (BA or BS) in Anthropology, Archaeology, Classics, or another germane discipline with a specialization in archaeology from an accredited institution.  Specializations, such as zooarchaeology, geoarchaeology, human osteology, and similar specializations are accepted as long as education and academic research included a focus on archaeology research topics.

Track 2

• Education and Major: AA/AS degree plus 250 hours of additional instruction/training in archaeology, anthropology, classics, or other germane discipline with a specialization in archaeology, including culture history, method and theory. (250 hours must include 60 hours in introductory RPA-designated instruction.) (250 hours is based on the assumption of 14 hours per college credit equivalent, or about 6 college courses.)

Track 3

• Education and Major: Student/Early Career RPA membership, plus 340 hours of additional instruction/training in archaeology, anthropology, classics, or other germane discipline with a specialization in archaeology, including culture history, method and theory. (340 hours is based on the assumption of 14 hours per college credit equivalent, or about 8 college courses.)

For all Tracks

• Experience: Two years of supervised experience within the archaeological field, of which 6 months must be in the lab, plus one year of supervisory experience both under a registered professional or NPS Qualified archaeologist
• Demonstrated Research Ability: Three technical reports written by the candidate which have identified archaeological sites, or two technical reports plus an authored chapter in another technical report and which have identified archaeological sites.
• Sponsor: (If not already RPA Student/Early Career) Two references, one of which may be from a professor familiar with the candidate’s work.
• Other: Accept Register’s Code and Standards and Grievance Procedures. 20 hours of combined training in Section 106 and public/Tribal coordination.  An exam covering the materials from the additional instruction/training

Registered Professional

I would revise the skill themes as follows for a registered professional, understanding that registered professionals can conduct all the work of a registered archaeologist, plus conduct work on Phase II and III projects, as well as prepare research designs, synthesize regional or thematic research and supervise and mentor registered archaeologists and students.

Track 1

• Education and major: Advanced/graduate degree (MA, MS, or PhD) or international equivalent (e.g., UK Level 7 or Bachelor Honors)In addition, a registered professional should also have the equivalent of a college course on historic preservation law and regulations, to include Section 106, but also NAGPRA, relevant Executive Orders, and NPS Guidance on the National Register, etc.
• Demonstrated Research Ability: Thesis or dissertation addressing an explicit archaeological research problem. Archaeological sites must have been identified during the analysis.

Track 2

• Education and major: RPA registered archaeologist, plus 1,100 hours of additional instruction/training in advanced archaeological topics, including culture history, method, and theory. RPA-approved university or continuing education courses as well as RPA-sponsored courses can be applied. RPA will provide a “faculty advisor” to registered archaeologists seeking to become a registered professional. (1,100 hours is based on the assumption of a graduate school 3 credit hour course taking about 135 hours of class and independent time. 1,100 hours would equate to roughly 8 courses).
• Demonstrated Research Ability: registered archaeologist, plus demonstrated ability to carry research to completion by a contribution through research and publication to the body of scholarly knowledge in the field of American archaeology

For all Tracks

• Experience: Two years of supervised experience within the archaeological field, of which 6 months must be in the lab, and 6 months in field excavation at a Phase II or Phase III site, plus two years of supervisory experience of which 1 year is in the field excavation at a Phase II or Phase III site, all under a registered professional or NPS Qualified archaeologist.
• Sponsor: (If not already a registered archaeologist) Two references, one of which may be from a professor familiar with the candidate’s work.
• Other: (If not already a registered archaeologist) Accept Register’s Code and Standards and Grievance Procedures. 20 hours of combined training in Section 106 and public/Tribal coordination.  The registered archaeologist exam covering the materials from the additional instruction/training

There are two large unknowns in my reformulated categories. First, I have put a marker for a great deal of additional training and instruction, much of which needs to be established and provided through the RPA. Some of this can be done in a webinar environment, much as remote college classes currently provide.  Some will likely need to be in person, especially some of the laboratory classes or field soil classes.  It’s a big ask, but if RPA wants to be the main arbiter of who is and is not an archaeologist, it will need to step up and develop, then offer this instruction.  Lastly, RPA will need to develop and probably administer a test of learned skills.

The other large ask is in mentoring and advising Track 2 and 3 registered archaeologists to registered professionals if they do not go to graduate school.  It is one thing to set up a list of training/courses/instruction that Track 2 and 3 registered professional candidates need to take. It’s another to ensure that those that aspire to this category can reasonably get there.  I have no idea of how many candidates there will be, but each one should get a “faculty advisor” to assist them. This should be from a pool of RPA archaeologists that are already supervising their field work and their supervisory activities.  I do not have a plan on how to set this up. All I know is that if there isn’t this component, Track 2 and 3 candidates won’t get there.

This is an ambitious program, but one that I believe could dig us out of the current labor crisis.  It seems that RPA would be the only national organization that could envision or implement such a program.  It’s worth a try.

I recently read through the August 8^th  Draft Program Comment on Accessible, Climate-Resilient, and Connected Communities, issued by the Advisory Council on Historic Preservation.  This was prompted by comments provided by the National Conference of State Historic Preservation Officers’ comments, the Society for American Archaeology’s comments, and the comments from the Washington State Historic Preservation Office.  There is no need to recapitulate the main arguments of NCSHPO or SAA, that the Advisory Council may have exceeded its authority in issuing these Program Comments. I am neither a regulatory attorney nor a Federal judge, so I leave those arguments to those better informed. That being said, there are additional reasons why the Advisory Council should withdraw this draft and rethink its approach.

Does the Program Comment or Programmatic Agreement Take Precedent?

The ”integration” with pre-existing program comments and programmatic agreements invites confusion.  Take Appendix C-1.4 Work on Bridges.  The Pennsylvania FHWA programmatic agreement covered this work in approximately the same manner with approximately the same result (no further 106 review), but would the Program Comment or the State Programmatic Agreement take precedent?  

Under II. Scope, C. Effect on Existing Agreements, a federal agency, in this case FHWA, has a choice to use existing 106 PA’s or this Program Comment.  It is not clear that this applies to all related undertakings or just the one project activity.  The federal agency could terminate the PA and follow the Program Comment or amend the existing PA.  Choice is good, right? These decisions will be made by managers, not experts in the dark arts of Section 106. Depending on how this is marketed to federal agencies, at the worst it will result in loss of precise tools for handling these minor projects that had the buy-in of the SHPO and other consulting parties (including tribes). At the best, it will result in extended internal discussions between managers and practitioners over why the Advisory Council would be selling the federal agency a bill of goods.  In the credibility racket this is a zero-sum game that benefits no one.

This is an anticipated result in each of the FHWA Divisions, leading to a patchwork of processes nationwide, not exactly the unifying intent of this draft Program Comment.  If there is one good thing to come out of this draft Program Comment, it might be a nudge to FHWA Divisions to execute effective programmatic agreements for minor activities, if none exists.

Archaeological Resources under our Feet

The authors of the Program Comment don’t really seem to understand how ground disturbance works. This was alluded to in the other previously referenced comment responses, but deserves a bit more here. In definitions, neither previously disturbed ground nor previously disturbed right-of-way seems to take into account situations within urban areas where there is a wealth of archaeological context right below the pavement.  As most archaeologists (qualified professionals, if you will) will tell you, relying on as-built drawings and plans for whether there are archaeological deposits right below the pavement is the surest and fastest way to perdition, if not unanticipated discoveries and delays – something these Program Comments wish to avoid.

In my previous life, working at a state DOT (Pennsylvania), we had an effective programmatic agreement that had an entire section devoted to activities that were unlikely to affect historic resources. We were able to exempt them with the stroke of a pen, actually many strokes of many pens.  That authority was placed in the hands of qualified professionals who had the education, training, and experience to check on the context as to whether potential archaeological resources could be present and whether that concern warranted further investigation. They were rarely wrong, something that expertise confers on someone. In addition, the exemptions made by staff were posted to the publicly accessible Project 106 PATH website in near real time.  Errors could be caught quickly and long before consequences. The SHPO had the authority to raise any concern on any project at any time for any reason. Again, this rarely happened.  As noted by others, these safeguards did not seem to be in the draft Program Comment. 

Alienating your Allies

One final point.  Let’s all agree that the goals of the ACHP’s Program Comment are admirable, that they wish to use the flexibility within Section 106 to streamline the process and at least not to be in the way of presumably virtuous projects.  Furthermore, let’s for the moment agree that what the ACHP is proposing is perfectly legal and would pass judicial scrutiny.  This still leaves a bitter taste in the mouths of state historic preservation officers and the archaeological community over process.  Section 106 is a process law, not a substance law.  Process reigns supreme, not results. You have an entire community of state SHPO’s who have fully committed their lives and sacred honor to that process. (There’s no fortune to be sacrificed here. Parents tell your children before they pick a major.) As a group, they are process nerds and as fully expert a collection of practitioners as you are going to find.  They are the ACHP’s natural allies, the one group that can back the Council with full authority within each of their jurisdictions, all 50 of them and territories.  And the Council has in one draft document, pulled the rug out from under them. They will not say this publicly. I am not a SHPO, though, and I say they have been disrespected in the one arena they care about most – process.

Archaeology and archaeologists are also treated as an afterthought, something archaeologists are used to, but more often from project managers.  This is another group that is a natural ally of the ACHP and although the SAA has come out currently as the main archaeological group to speak to the draft Program Comment, others are likely to follow. I also detect the underlying metallic taste in their mouths.  Why would the ACHP alienate two of the most important allies it has?  As my late mother would say, “Beats me, Lieutenant.”

As alluded to in other comments, state programmatic agreements seem the best tool to streamline Section 106 for these minor activities. The two main agencies that seem involved in the list of activities in the draft Program Comment are FHWA and HUD.   Maybe FEMA as well although the focus is buildings and transportation, not recovery.  Should FWHA be interested, it could work with ACHP to develop a specific template that could be shopped to each state FHWA Division, or execute an agency-wide programmatic agreement.  Given FHWA’s traditional deference to state divisions, I think the former is more practical.  With the support of FHWA and ACHP, needed state PA’s could be executed in approximately a year, faster than most PA’s.  I am less familiar with the modus operandi of HUD, but a template PA could also be useful.  State SHPO’s and other stakeholders would be the drivers of these agreements.  Streamlining 106 could be achieved, and the ACHP could start putting the toothpaste back into the tube.