New TCP NR Bulletin draft available for public comment

[Laurie Sommers]

https://parkplanning.nps.gov/projectHome.cfm?projectId=107663 

Just started looking at this. It gives two folklorist driven examples:  Green River Drift and Taropn Springs Greektown HD.

Hope some of you will provide comments to NPS. 

[Virginia Siegel]

Wow! Finally! It’s been years since we were told we’d be able to comment! 

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Virginia Siegel

[Jeremy Wells]

There are a couple of sections in this revised bulletin (link to PDF) that could be a game changer in terms of moving away from the 50+ year-old positivist-empiricst paradigm that has long defined the National Register:

On page 31, at the top, in reference to how a TCP can be eligible for inclusion under criterion A of the NR, there is the following text:

"Sometimes, though, just when a traditional event took place may be unclear; in such cases, it may be impossible, and to some extent irrelevant, to document with certainty that the place in question existed when the traditional event occurred. For example, events as recounted by Native Americans, Hawaiians, and Pacific Islanders may have occurred in a time before the creation of the planet as demonstrated by the geological record. As long as the events are rooted in the history of the community, and by tradition associated with the place, the association should be accepted.”

This is REALLY important. What the revised bulletin is saying is that it no longer is necessary to objectively document the past using historical facts (!). If you can demonstrate that a community believes something is true/real/important, that’s sufficient. And, by extension, this evidence can consist of oral history and ethnographies and would not require the demonstration of facts rooted in the written record. Thee issue here (from the NPS’s perspective), however, is that this policy totally contradicts the other NR bulletins.

Here’s an example of how this could be operationalized, in practice. A few years ago, members of an African American neighborhood in Camden, NJ wanted to nominate a row house to the NR because the community believed that Martin Luther King, Jr. visited this place, and thus it is associated with the Civil Rights movement. The NJ SHPO said, “no” because the group nominating the building could not produce sufficient, objective (e.g., written) historical facts that established, beyond a doubt, that Dr. King did visit/stay in this house. If this revised TCP was in place when this nomination process was happening, the authors of the nomination could counter the NJ SHPO with the claim that it is federal government policy that "As long as the events are rooted in the history of the community, and by tradition associated with the place, the association should be accepted,” regardless of the ability to prove that these events can be “proven” to be objective facts. That’s potentially really powerful. 

And, on pages 41 and 42, the discussion of material integrity has the verbiage:

"Changes in materials may be consistent with the evolving nature of traditional building patterns and have little or no effect on traditional values ascribed to a place, or group of properties, by the traditional community. For example, the recent use of aluminum siding or artificial veneer stone for buildings where traditional forms and materials, such as brick, persist would not necessarily create a lack of integrity of materials.”

This is also a potential game changer because, if this revised TCP is accepted by the NPS, it would then become government policy that if you establish that a community finds a place, today, of historical importance, you can use this bulletin to get around issues that vernacular places have often been modified more recently and thus “lack integrity.” Again, this policy totally flies in the face of every single official NPS document, but there it is.

Would love others thoughts on this…

-Jeremy

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Jeremy C. Wells, Ph.D. • Principal (he/him)  240.258.8032  jer...@heritagestudies.org  heritagestudies.org  7304 Carroll Ave., #190, Takoma Park, MD 20912 (USA)