In Consideration Of Archeologists Serving Industry, Cultural Resources and the Profession
William B. Butler and Charles M. Niquette
This paper was originally published on the American Cultural Resources Association (ACRA) website
ABSTRACT
Energy self-sufficiency has become a National priority and forthcoming energy development will be a major catalyst in transforming the way we engage in contractual archeological activities. Failure to efficiently serve the energy industry may result in the cultural resource laws being changed or over-ridden. Problems which hinder such efficiency include: time, lack of qualified archeologists, Federal, state and local bureaucratic ineptitude, the "granting of clearance" by unenlightened archeologists, lack of uniform field and report standards, and absence of adequate peer review. A solution to these problems focuses on the critical need for performance standards that can be agreed upon and adhered to by all who are involved in such archeological undertakings.
Paper presented to the 45th Annual Meeting of the Society for American Archaeology, Philadelphia. May 1-3, 1980
INTRODUCTION
This nation is faced with the problem of providing more energy for its people. The vast coal, uranium, oil, natural gas and oil shale resources in various sections of the United States will be increasingly exploited in the near future. Because such development is vitally important to this nation's future, there can be no doubt that intensified exploration and production of these energy resources will occur.
As archeologists, our concern must focus upon protecting the cultural resource base from this forthcoming energy development. If the archeological community fails to serve the energy industry in a timely and efficient manner, the existing cultural resource laws will be modified to our detriment. Neither we nor the people of the United States can tolerate any delay in our energy resource exploration and development.
For years the profession has tried to educate the public about the value of the irreplaceable archeological record. Unfortunately, we have succeeded in convincing only a small minority of the American people of the importance of these resources. When the vast majority of the nation's population cannot afford to drive their cars, buy manufactured products or even afford the luxury of heating their homes, energy production will be given priority over environmental concerns. Congress is currently in the process of creating an Energy Mobilization Board with the power to cut through red tape which might retard energy production (cf. Anderson, et al. 1979:91) Archeology may be identified as one component of that cumbersome red tape. The Interagency Archeological Services (lAS) has long taken the position that no project should be abandoned or unnecessarily delayed because of cultural resources. Mechanisms already exist to avoid such problems. However, it is apparent that these mechanisms require some "streamlining" if we are to avoid dismemberment of the cultural resource laws.
It is difficult to discuss the various cultural resource compliance problems that may hinder progress of energy production as being unrelated phenomena. Factors to be examined are interrelated and are potential sources of breakdowns in the historic preservation process. These include: (1) time, (2) the lack of qualified archeologists, (3) Federal, state and local bureaucratic ineptitude, (4) the "granting of clearances" by unenlightened archeologists, (5) the lack of uniform field and report standards, and (6) the absence of adequate peer review. Each of these factors will be discussed separately.
TIME
A major problem for the energy industry involves time schedules. Archeologists must be able to conduct literature reviews, surveys, testing, and, mitigation as quickly as possible in order to prevent the delay of energy related projects. Frequently, this has not been the case but the archeologists are not solely to blame. The officials of the energy industry must be convinced that lead time is critical to the timely completion of archeological compliance activities just as it is critical to their own activities.
Commonly, oil company energy leases are of a ten-year duration but the archeologists are habitually called in at the last moment. Delays are frequently blamed on the archeological profession despite the lack of lead time that is afforded. The number of drilling rigs are limited as are the number of rigs that may be available at a given time in a given area. The energy companies usually give approximately six months notice to acquire one and there is no reason why archeologist cannot be given at least this much notice. Even though the precise location of the well-pad may not be known six months in advance, the location within a 40-acre area is known. The cost for a survey of the 40 acres would be only slightly more expensive than a single location survey. In the case of mining activities, there is at least a two-year period between the application for a permit and its approval. In Montana this application may be reviewed for 240 days but if the archeology is incomplete, the application will be denied and the process must begin anew. We must convince the officials in the energy business that there will be no delays because of archeology. This is only possible if the profession is given the necessary lead time. Cooperation and communication between all of those involved is mandatory.
LACK OF QUALIFIED ARCHEOLOGISTS
The unavailability of archeologists in many western states may prompt the energy industry to attempt to exclude archeological compliance in energy searches. Under the present system, the implications of non-compliance for the energy company are serious and could cause a company to lose its lease. In such a situation, the financial costs are great and obviously, this slows down energy exploration. At present, there are barely enough archeologists in the west to provide industry with the necessary archeological services. In the next decade, demand will probably outstrip the supply of competent archeologists (provided the relevant cultural resource laws are still intact). In response to this situation, some would predict the development of a "service industry" of archeological technicians "who have no obligation whatsoever beyond the simple repair jobs they are called in to do' (Wendorf 1979:642). The Forest Service already approaches the issue of compliance with Executive Order 11593 by employing an army of technicians who are trained in a single 40-hour course in archeological survey. It would be a small step for the energy companies to save themselves, and ultimately the American people, a tremendous amount of money and time by following suit and handling their own compliance endeavors "in house" by unqualified individuals. In our opinion, this approach is extremely dangerous but it may be an inevitable solution.
BUREAUCRATIC INEPTITUDE
The Federal Government controls much of the land in the west and Federal agencies require private energy companies to complete an archeological investigation prior to new energy exploration. In order to conduct an archeological investigation on Federal land, individuals are required to possess a Federal Antiquities Permit. The past process for obtaining a permit (under the Antiquities Act of 1906) has been rather slow, but it did attempt to insure that high professional standards were realized and the permits were issued through an objective process. Under the new Archaeological Resource Protection Act of 1979 these safeguards may have been eliminated. The new act provides for the granting of such permits by each Federal agency. In addition, state governors may request that permits be issued to individuals. Although, the Department of the Interior is charged with the responsibility of issuing guidelines for permit qualifications, it remains to be seen how this new law will be interpreted and implemented.
Under the present system, an individual may possess Federal Antiquities Permit but still not be allowed access to Federal lands. Access is granted by each Federal agency. If the responsible agency does not approve of an individual's qualifications, access may not be granted. In many instances, there are individuals in positions of authority within the Federal and state governments who lack the experience and education necessary to make enlightened decisions regarding an archeologist's qualifications. Furthermore, there also exist some well known and top rated "Pinball Wizards" (Fitting 1979) who may refuse cooperation and/or access to so-called "outsiders." Commonly, these "Pinball Wizards" simply do not like "outsiders" working within the boundaries of their state and they hold the power to prevent their Kingdoms from being violated. These archeologists apparently believe that the state political boundaries are real and were recognized by the prehistoric inhabitants of this country. The new antiquities act uniform rules and regulations may give them power that may easily be abused.
Regardless of which Federal agency ultimately issues Antiquity Permits, it has been a time consuming process with permits usually granted to those who are qualified. If each agency issues their own permits and maintains the qualification standards, the process may not be jeopardized and it should speed up considerably.
Archeological experience in a region is an essential element of good archeology. After all, if one does not know the substantive and theoretical issues for an area, it is impossible to make enlightened decisions regarding National Register significance. The National Register of Historic Places criteria for significance (36CFR60.6(d)) is the theoretical and substantive knowledge of the discipline and nothing else. However, because of the present lack of qualified archeologists and the anticipated demand for such individuals, Federal and state agencies must devise a mechanism that will allow qualified "outsiders" a chance to show that they can do acceptable work in a particular area. This is necessary if we are to avoid an energy backlash (cf. LeBlanc 1976:76-77). "Pinball Wizard-like" attitudes simply cannot be tolerated. It is apparent that there is a demand for more archeologists who can competently work in a variety of geographical regions and archeological culture areas. If the archeological community is to serve the energy industry in a timely and efficient manner, the profession must realize that this demand will increase. We must anticipate this demand and be ready to meet the challenge.
GRANTING CLEARANCE
Closely associated with what we refer to as the "Pinball Wizard" attitude is the "granting of clearance" by unenlightened archeologists. Too many archeologists are under the impression that they can "grant clearances" for a specific project. Nothing could be further from the truth. Granting clearances remains the responsibility of the Federal agency and the State Historic Preservation Officer. Archeologists are employed only to make objective evaluations, based upon their knowledge of the area. An archeologist who declares that all the sites he has located in a survey were found to meet the National Register criteria for significance has only to document his evaluation in reference to the theoretical and substantive concerns of an area. Furthermore, the archeologist who claims that some of the sites he found were not eligible must also document the reasons why the sites were not considered to be significant (cf. Sharrock and Grayson 1978). Many archeologists write off sites without documentation other than "Take my word for it; I'm a pro.". These kinds of recommendations are likely to stop the wheels of the compliance process and do not make any contribution to the discipline (cf. Butler 1979). This is insufficient and indicates the need for a unified set of standards for both report preparation and report evaluation.
REPORT STANDARDS
Although a set of minimal report and field standards may be promulgated, their implementation does not guarantee sound archeology. Evidence now being accumulated at lAS-Denver demonstrates that a great variety of such standards do exist. The junior author has found that 27 states have drafted such guidelines, and despite a wide discrepancy between the quality of such standards, it is evident that good archeology means more than "simply filling in the blanks." It is also possible for a report to meet the requirements of one set of standards of one state or one Federal agency but not those of another. A major problem with report standards focuses upon the tendency for minimum standards to encourage a minimum quality product. Despite this problem, there exists a great need to develop standards that all state and Federal agencies can agree upon and to which all archeologists can adhere (cf. Dincauze and Roberts 1977:10-14).
A unified set of standards would have the advantage of assuring that: (1) the data categories required for planning and management by both the Federal and state agencies can be satisfied by a single document, (2) that there would be a reduction or elimination in duplications of effort, (3) that the comparability of data generated from archeological investigations would be enhanced and, (4) that there would be a reduction in report rejections.
A major advantage would be the time saved from report rejections since everyone who conducts archeological activities will know exactly what is to be expected in their reports. Report rejection costs time and money for the agency involved, the archeologist and the energy development company for whom the work is being completed. Problems of inefficiency which can lead to a breakdown in the system are often caused by that information which contract reports do not contain or what they are not based upon. As the individual states develop their respective state historic preservation plans, reports on investigations done within those boundaries must be made consistent with these plans. Unfortunately, only one such plan presently exists. In the interim, until such plans are drafted and implemented, there is an obvious need for guidelines to streamline both the preparation and evaluation of archeological contract reports.
PEER REVIEW
Most Federal and state agencies conduct their own "in-house" report reviews. A problem arises when the in-house reviewers know less about the archeology than the report authors (cf. Skinner 1977:50-55). Moreover, even when qualified people are reviewing reports for a particular agency, they often do not have the staff expertise or time to do a thorough job. The lAS reviews reports (upon written request) for many Federal agencies. The lAS-Denver has, at times, fallen almost two months behind in its reviews simply because the staff size is not adequate for the workload. The single Federal or state archeologist stationed in "Outback Wyoming" may really be overworked (cf. Fitting 1976:26-28).
SOME SUGGESTED SOLUTIONS
A carefully formulated and comprehensive set of report standards would be a tremendous aid in the review process. To ensure the highest professional standards, we would also encourage that for contracts over $10,000.00, a set amount of money be budgeted for an outside and independent peer review such as that provided by the Society of Professional Archaeologists (which has been used only infrequently). A good review takes time and it has been our experience that unless you are willing to pay for a quality review, you rarely get one. A professional archeologist must be expected to produce a product that goes far beyond a set of minimal standards and he should not object to have a peer review his or her work. Let's applaud the good and damn the bad. Quality work would be ensured if an individual's access and permit to work on Federal lands could be revoked for inferior work. Archeologists are legally responsible for their work but far too frequently, the archeologists who are responsible are not held accountable.
In order to serve the energy needs of this nation, archeologists must be able to move quickly and efficiently. If we have well qualified archeologists that can meet and hopefully exceed minimal standards for reporting and whose work is commended by their peers, then why not produce a set of standards through which an archeologist could come closer to legally granting clearances? Federal and state agencies would still be responsible for the archeologist's recommendations but with such a standardized mechanism, we may be able to reduce paperwork, decrease bureaucratic delays, assist industry and still preserve the data base. The key to such a system lies in written report standards that are acceptable to all parties involved with cultural resource endeavors.
Critical to this concept is the need to document and to make available through effective retrieval methods such information to all who are concerned with cultural resource investigations (McGimsey 1979:589; Somers 1979:330-332). If these data were well organized and were easily retrievable, the total cost and time required to perform literature searches (and ultimately the entire archeological process) could be reduced greatly. Many states have begun to computerize site locations and associated site information. All states should consider doing the same. The initial costs of such actions are small compared to the savings in both time and money that can be realized over a period of time.
In the senior author's travels around the United States, he has frequently heard pleadings from archeologists for a national computerized bibliography for archeological reports. Three years ago he submitted a formal proposal to the Department of the Interior requesting a computerized national bibliographic system for archeologists and cultural resource managers. At the present, the suggestion is still being "evaluated." Such systems could also be set up within each state. The archeologist of manager would be required to pay a fee for its use similar to that system used in real estate for access to a city's multiple listings. At a minimum the system would identify (by county) the existence and repository of archeological reports. It would be the task of the archeologist to read and interpret the reports, not that of the computer system. Furthermore, the system should encourage the users to be contributors to the bibliography. Similar systems have existed for several years to serve the needs of geologists, medical researchers, the biological sciences and even petroleum engineers. Why can't archeologists implement such a system?
In addition to report standards, competent peer reviews and computerized bibliographies, other steps must be taken to ensure greater efficiency and the highest professional standards possible. Similar to other fields such as the medical profession, we must actively police our own ranks and discourage shoddy archeology wherever it appears. We ask you to consider that a committee within the Society of Professional Archaeologists be organized and established as an archeological licensing agency. Licenses to practice archeology should be made mandatory for all those who conduct contract archeology. Licenses should be awarded on the basis of field experience, education, and most importantly, performance. For those just entering the field, requirements to receive a license should include an internship or apprenticeship program with a recognized and licensed professional archeologist. The licensing agency should also be responsible for monitoring the work of licensees by both field monitoring and report reviews. The licenses that are issued should be renewed regularly and applications evaluated on the basis of the recipient's performance. The idea for licensing archeologists is not new. It has been cussed and discussed in several professional meetings and publications that date back into the early 1970's. Maybe the time has come for the concept to be given some serious consideration.
CONCLUSION
Archeologists must be able to serve private industry in their exploration and production of energy for this nation. If we do not act quickly, the environmental laws will be changed or ignored. The Energy Mobilization Board will exist and those "Doubting Thomases" among you should note the outcome of the Tellico conflict. We must maintain and upgrade the standards for contract archeology while at the same time, streamline and modify our activities to avoid causing delays in energy production. While maintaining the highest standards for archeology, we must welcome all of those who are capable of meeting those standards. Written report standards are a key to ensure that each responsible agency gets what it needs for management purposes and peer review must be instituted to protect professional concerns.
Several individuals have expressed the idea that American archeology has recently experienced a "Kuhnian" revolution. However, Meltzer (1979:644-657) may be correct that the revolution has been one of method rather than a new metaphysic. Regardless of whether you agree with Meltzer, there has been a change in how we perceive archeology. The Binfordian hypothetico-deductive processual focus has had a minor impact on American archeology when compared to the effects of the cultural resource laws upon the discipline. This change may easily be overshadowed by the forthcoming energy boom and its effect upon the future of American archeology. Federal agency managers, the State Historic Preservation Officers and the profession must create mechanisms to do archeology in an efficient and timely manner. If this is not done, then each of us should be seriously looking for a new career. Archeology will be seen as a luxury that the Nation can ill afford. It is time to act together or there will be no stage left upon which to perform.
ACKNOWLEDGEMENTS
The authors acknowledge and appreciate the critical review of this paper by the professional staff of Interagency Archeological Services -Denver. In addition, comments and criticisms of an early draft by Mark Raab, John Beards ley, and Doug Scott were most valuable in the preparation of this paper. We are also grateful for the labors of Pat Kisling in her typing the many drafts of this paper. This work remains the product of the authors and they are solely responsible for its content.
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