NPS-28: CULTURAL RESOURCE MANAGEMENT GUIDELINE

A. The Planning Process

Planning is a formal decision-making process, dynamic and continuous, to ensure that the missions of the National Park Service are accomplished. This requires that a number of interests, including those of cultural resource management, be considered. Effective planning identifies conflicting interests early and facilitates resolution of conflicts.

Planning includes a statement of mission, the definition of objectives, the identification of issues and opportunities, the collection and analysis of data, the development and evaluation of alternatives, and the selection of a preferred alternative. (For more details see the Planning Process Guideline [NPS-2].)

Statement of Mission

Definition of Objectives

Identification of Issues and Opportunities

Data Collection and Analysis

Development of Alternatives

Evaluation of Alternatives

Selection of Preferred Alternative

The goal of cultural resource planning in the national park system is to identify and preserve park cultural resources and provide for their appreciation by the public. It strives to integrate cultural resource concerns into broader NPS planning processes, to avoid or minimize harm to cultural resources, to identify the most appropriate uses for cultural resources, and to determine the ultimate treatment (preservation, rehabilitation, restoration, reconstruction/reproduction) or deliberate neglect or destruction for cultural resources. Development of Geographical Information Systems (GIS) helps planners identify and protect cultural resources while addressing other park concerns.

Planning responsibilities extend beyond cultural resources that relate to a park's establishing legislation or interpretive needs. Under Sections 106 and 110 of the National Historic Preservation Act, federal agencies must establish programs to identify, evaluate, and nominate to the National Register of Historic Places eligible properties under their control and manage such properties with due consideration for preservation of their cultural values. Under this mandate, planning responsibilities include not only nationally significant properties but also those that may be eligible because of their importance to a locality, state, or region.

Although planning is a decision-making process for managers, it must consider the concerns of others. Consultation with the Advisory Council on Historic Preservation and state historic preservation officers (SHPOs) is required by law and regulation. Regulations and Management Policies also require consultation with Native Americans and other concerned ethnic groups, other federal agencies, state and local governments, and other interested parties. While compliance with the National Historic Preservation Act addresses most cultural resource concerns, planners and managers must also comply with the National Environmental Policy Act. (See Chapter 5 for compliance with Section 106 of the National Historic Preservation Act, including special provisions for park plans.)

B. Planning Scopes

Planning can focus on a specific resource or resource type, address a major segment of a park, cover an entire park, or transcend park boundaries. The first type of planning results in action plans of the kind described in Chapters 6 through 10. Because parks are part of larger cultural environments, and because the Service's concern for cultural resource preservation extends beyond parks, the NPS has increasingly become involved in planning beyond park boundaries. NPS cultural resource specialists should participate actively in planning for national heritage corridors, partnership parks, national trails, and other joint ventures.

Standards

• Before planning commences, a comprehensive park inventory of cultural resources within the area to be affected is compiled.

• Planners, cultural resource specialists, and managers coordinate funding and schedules for research including schedules for planning.

• Planners, cultural resource specialists, and managers weigh the significance of cultural resources, their condition, their interpretive value, their research potential, the availability of data about them, and threats to them in determining their ultimate treatment and use.

• Planners, cultural resource specialists, and managers consult with and consider the views of the SHPOs, Advisory Council on Historic Preservation, other federal agencies, local governments, Native Americans and other concerned ethnic groups, and other interested parties as part of compliance with Section 106.

• Planners, cultural resource specialists, and managers consider cultural resource issues that may relate to lands outside park boundaries and participate actively in planning efforts by or involving neighboring jurisdictions.

C. Resources Management Plans

"Each park with cultural resources will prepare and periodically update a cultural resource component of the park's resources management plan, defining and programming the activities required to perpetuate and provide for the public enjoyment of those resources" (Management Policies 5:4).

The objectives of the cultural resource component of a resources management plan (RMP) are

(a) to summarize the cultural resource values and related mission and purposes of the park;

(b) to analyze the significance of resource management needs and problems and rank them in importance;

(c) to propose specific actions, including funding and staffing requirements, for dealing with the most important problems;

(d) to present a multi-year program to achieve measurable progress in accomplishing the proposed actions;

(e) to provide for an annual review and recording of accomplishments to measure the effectiveness of actions; and

(f) to provide a forum for an interdisciplinary approach to the park's resource management issues.

The resources management plan is part of a larger planning process described in the Planning Process Guideline. The RMP draws its major objectives from the park's comprehensive planning documents: the statement for management (SFM) and the general management plan (GMP). In turn, research and studies called for by the RMP may result in new knowledge that will influence the objectives and management needs previously defined in the SFM and GMP.

The RMP takes the resource management objectives a step further and describes a specific plan of action, which is used to prioritize requests for funding and to guide the expenditure of that portion of park base funds devoted to cultural resource management.

One of the objectives of the RMP is to foster integration of natural and cultural resource management actions in the park.

In addition to its introductory material, the RMP will contain

(a) a present resource status section summarizing and evaluating the condition and documentation of the park's cultural resources and major threats to them; and

(b) a resource management program section containing

(1) an overview that includes a summary of the major cultural resource issues, the strategies the park will use to address the most significant problems, and a discussion of unfunded needs;

(2) summary charts of structures, cultural landscapes, museum objects, archeological sites, and ethnographic resources; charts on personnel and funding; a list of currently funded actions; and a four-year priority listing of unfunded needs;

(3) individual project statements; and

(4) cultural resource documentation checklist.

A report of unfunded project and program needs will be submitted annually by March 31.

(For detailed guidance on the development of the RMP, see Resources Management Plans: Planning and Software Manual, 1994.)

D. Planning and Cultural Resource Considerations

Specific cultural resources require special consideration in planning. Here are some perspectives to keep in mind during the planning process:

1. Archeological Resources

a. Areas proposed for ground-disturbing activities will be surveyed for archeological resources prior to site selection. Development will not begin until the archeologist has submitted an archeological clearance report and Section 106 compliance has been completed. Plans and project documents will provide for the recovery and care of any archeological resources or data discovered during a project (see 36 CFR 800.11).

b. Because subsurface remains are subject to increased deterioration after exposure and can present safety hazards, plans should prescribe the backfilling of all excavated sites not essential for interpretation or other purposes. Limits of excavation should be marked so that they may be recovered in the future.

c. In compliance with federal law, plans keep the locations of archeological sites confidential to protect them from looting and vandalism.

2. Cultural Landscapes

a. Plans should reflect respect for a landscape's period(s) of historical significance and the features, patterns, and relationships contributing to its significance. Planners should realize that there is a lack of baseline data and contextual information for cultural landscapes, so that a landscape's significance and character-defining features may need to be determined as part of the planning process.

b. Planners should consult the park's inventory of cultural resources to determine what resources might be affected by the planning exercise.

c. Planners should consult cultural landscape specialists.

d. Planners should consider the possible adverse effects of vegetation screening, ramps, waysides, signs, and changes in grade on cultural landscapes. New features should be characterized by compatible design, materials, and workmanship.

e. Planners should work with natural resource management specialists to ensure that natural resources are protected consistent with cultural resource objectives.

f. Decisions regarding public or administrative use of a cultural landscape– including the siting of new facilities, parking, etc.–should reflect knowledge of its condition and carrying capacity and the possible adverse effects of any required modifications.

3. Historic and Prehistoric Structures

a. Planners should consult the park's List of Classified Structures (LCS) to determine what structures might be affected by the planning exercise.

b. Plans should reflect respect for a structure's period(s) of historical significance and the features contributing to its significance and setting.

c. Decisions on the public or administrative use of a structure–its adaptive use or rehabilitation–should reflect knowledge of its condition and carrying capacity and the possible adverse effects of any required modifications for fire and life safety, accessibility, and climate control.

d. Materials that emit chemicals that are detrimental to structures and museum collections should be minimized.

4. Museum Objects (for more specific guidance see NPS Museum Handbook)

a. Plans for exhibit and storage spaces should address all preservation and protection standards and requirements. (See Director's Order 24, "Standards for NPS Museum Collections Management.")

b. Plans should address the installation of intrusion detection, fire detection, fire suppression, and environmental control systems appropriate to the nature of the museum collections and the structures housing them.

c. A structure's load capacity for museum and archival storage should be evaluated, especially in historic structures, by a structural engineer familiar with historic and modern buildings.

d. Facility planners should consider the provision of loading docks and double doors to storage spaces for large and heavy objects and receiving rooms for processing acquisitions. Freight elevators also facilitate the movement of objects in storage areas. Stairs should be avoided.

e. Museum and archival collections should have dedicated storage, separate from maintenance and other activities, above grade and outside floodplains, with security and fire protection systems and climate-control capabilities to provide a constant environment.

f. Planning must give priority to preventive conservation principles.

5. Ethnographic Resources

a. Plans should consider the privacy of traditional user groups and their desire to continue cultural activities without intrusion from visitors.

b. Visitor circulation and use patterns should avoid sacred places.

c. Tribal leaders and elders should be consulted regarding appropriate planning involving museum objects or lands they use or value.

d. The reasoning behind the need for and the nature of any ethnographic study must be explained in writing to the affected group before the study begins.

e. Groups selected by the NPS for ethnographic studies have the right to reject or modify the proposed research designs for such studies. For example, a Native American tribe may be willing to work with NPS scientists to ensure that plants harvested for traditional uses are not endangered or overharvested. This same group, however, may not see the need to share or detail the cultural uses to which the plants are put. Under such circumstances, no studies should be undertaken by the NPS, although an ethnographer should be available to assist in resolving possible conflicts.

Standards

• A resources management plan is prepared for each park and reviewed every two to four years.

• Each park assesses the adequacy of its cultural resource information base and proposes in its resources management plan to correct deficiencies.

• Areas affected by construction, human use, or natural forces have a cultural resources survey sufficient to develop an information base upon which alternatives avoiding or minimizing adverse effects can be planned.

• Cultural resource specialists are full members of planning teams addressing predominantly cultural parks and are, at a minimum, consultants to planning teams addressing other parks with cultural resources. When appropriate, Native American leaders are invited to serve as consultants.

• Proposals for actions that may affect cultural resources are advanced only if sufficient data have been gathered to assess the probable effects.

• Proposals for actions that may affect cultural resources are reviewed at the earliest possible point by cultural resource specialists to ensure that all feasible measures have been or will be taken to avoid or minimize resource impairment. Unavoidable adverse effects are mitigated in accordance with this guideline.

• Decisions concerning the treatment and use of cultural resources are made and recorded in the park's general management plan or development concept plan(s) and programmed for accomplishment through the park's resources management plan.

• Sections 106 and 110 of the National Historic Preservation Act have been complied with in accordance with the regulations of the Advisory Council on Historic Preservation (36 CFR 800) and "Guidelines for Federal Responsibilities under Section 110 of the National Historic Preservation Act" (53 FR 4728).

• In cases involving ethnographic resources and ethnographic museum objects, associated Native American and other ethnic groups are consulted and their concerns are taken into account.