Park Cultural Resource Management
No. 2 Shaft-rockhouse, a historic structure and part of the Keweenaw NHL cultural landscape.
Cultural resources preserved and protected by the NPS reflect the breadth and depth of America's history and culture. Of the almost 400 parks in the NPS System, all contain cultural resources. Among them are archeological sites, ethnographic resources, cultural landscapes, historic structures, and museum collections. Park cultural resource management is carried out in the national parks in accordance with Federal law and policy to ensure that the NPS fulfills its stewardship responsibilities. The following information serves as a brief outline of cultural resource management in the NPS. Note that NPS compliance with the NHPA is spelled out in Director's Order 28 and the NPS Management Policies (pdf).
Relevant NHPA Sections
Section 106 of the National Historic Preservation Act of 1966 (NHPA) is one of the most important legal drivers of NPS cultural resource management. The Nationwide Programmatic Agreement (PA) signed in 2008 provides coordination between the NPS, the Advisory Council on Historic Preservation (ACHP), and the National Conference of State Historic Preservation Officers (NCSHPO) for the Section 106 compliance process. Section 106 and the PA connect with 36 CFR 800 (revised 2004), the ACHP regulations, which establish a process for Federal agencies to comply with Section 106. The NHPA, 36 CFR 800, and the PA thus provide the NPS with a roadmap to plan for and carry out undertakings to minimize harm to cultural resources.
Section 106 requires Federal agencies to take into account the effects of their undertakings on historic properties. It also requires Federal agencies to provide the ACHP with the opportunity to comment on such undertakings, if there is a potential to affect historic properties. As a result of Section 106 and 36 CFR 800, the NPS identifies and assesses the effects of planned undertakings, then consults with the appropriate parties. Proposed undertakings run the gamut from road construction, to rehabilitation of a historic structure, to archeological survey of a coastline, and more. Virtually any activity that involves work on, in, or around historic properties requires some level of compliance with Section 106.
Other sections of the NHPA also play essential roles in NPS cultural resource management. In brief, Section 110 identifies the broad historic preservation responsibilities of Federal agencies. It aims to ensure that they fully integrate historic preservation into their programs. (See Section 110 Guidelines.) Section 110(f) of the NHPA requires that Federal agencies exercise a higher standard of care when considering undertakings that may directly and adversely affect National Historic Landmarks. Section 111 enables Federal agencies to lease a historic property if the action will help to preserve it. Section 112 of the NHPA requires agency personnel or contractors responsible for historic resources to meet qualification standards established by the Office of Personnel Management in consultation with the Secretary of the Interior.
The Section 106 process at certain points parallels the processes of other Federal laws, such as the National Environmental Policy Act (NEPA). Remember, however, that compliance through Section 106 and NEPA are two entirely different and not interchangeable processes. Go here to view the NEPA & Section 106 discussion within the PA Toolkit.
Types of Cultural Resources
Section 106 applies to properties listed in or eligible for listing in the National Register of Historic Places. Please note that the National Register terminology differs from that of NPS management policies. When Section 106 consultation takes place, National Register terminology and the term "historic properties" will be used. Please refer to 36 CFR 800 and National Register publications for details.
The NPS manages several types of cultural resources. See the Glossary for specific definitions. Among them are:
National Register properties: The National Register lists sites, structures, buildings, districts, and objects. These places, however, are not necessarily the same as cultural resource types. An archeological collection, for example, cannot be listed on the National Register. See the National Register publications for more information.
Archeological Properties: Archeological properties include shipwrecks, forts, houses, kivas, workshops, lithic scatters, shell mounds, roadways, ceremonial spaces, petroglyphs and petrographs, among others.
Cultural Landscapes: Historic and ethnographic cultural landscapes include battlefields, streetscapes, suburbs, cities, plantation complexes, ceremonial areas, and more.
See the Guidelines for the Treatment of Cultural Landscapes for more information. For examples see the Quincy Cultural Landscape Report for Keweenaw NHL and Cultural Landscape Report for Bryce Canyon Lodge District and Historic National Park Service Housing District.
Ethnographic Resources: Ethnographic sites include traditional use areas for ceremonies, housing, subsistence, and other elements of cultural life.
Historic Structures: Buildings and monuments, dams, millraces and canals, nautical vessels, bridges, tunnels and roads, railroad locomotives, rolling stock and track, stockades and fences, defensive works, temple mounds and kivas, ruins of all structural types, and outdoor sculptures are some types of historic structures.
Roles and Responsibilities
The PA specifies that the Superintendent, Park Section 106 Coordinator, and Cultural Resource Management (CRM) Team play integral roles in the Section 106 process as decision makers, parties in consultation, and keepers and distributors of communications and documentation. Parties involved in NPS cultural resource management include subject area specialists such as archeologists, architects, curators, historians, landscape architects, ethnographers, and others. Superintendents, facilities managers, and natural resource staff are among those at parks who need to know about cultural resource management but are not necessarily specialists. Their work, for example, may trigger Section 106 review if it has the potential to affect a historic property.
Regions and the NPS Directorate are also involved in park cultural resource management. Regional offices have their own Section 106 Coordinators. See the rest of the PA Toolkit for information on when regions or the Director become involved in the park Section 106 process.
Consulting parties include SHPOs, THPOs, federally recognized Indian tribes, Native Hawaiian organizations, local governments, nonprofit organizations, historic property owners, concessionaires, and any others with a vested interest in the park's cultural resources. Members of the public may comment on park planning, as well. See Working with PEPC of this guidance for help.Consulting parties may include individuals of the above list, as well as community members, visitors, historic preservation groups, professional associations, clubs, and others.
Elements of Park Cultural Resource Management
Adobe maintenance at Tumacacori.
The NPS has developed approaches and methodologies to preserve and protect cultural resources and to support planning. They all intersect with Section 106 and the PA. Ways the NPS executes its stewardship responsibilities include:
Parks conduct interdisciplinary research programs to create a base of information that represents their cultural resources and traditionally associated peoples in support of planning, management and operations. Research helps to ensure that cultural resources will be protected, preserved, treated, and interpreted because current knowledge is in place to support good treatment. That knowledge might include historical facts, property locations, or even technologies and methodologies for taking care of the resources. Research furthermore enables parks to consider and understand the view of others, such as traditionally associated peoples or members of the public.
See Adeline Hornbek and the Homestead Act: A Colorado Success Story, for an example of a historic research project applied to an educational Teaching with Historic Places lesson plan.
Identification and Evaluation
Parks do surveys to identify their cultural resources. The identification of cultural resources leads to their evaluation within their larger cultural, chronological, and geographical contexts. Inventories are the result.
The Beach Ridge Complex Survey at Cape Krusenstern NM is an example of an archeological survey to identify the locations and scope of sites.
The result of identification and evaluation programs are inventories that provide data for nominating resources to the National Register, general park planning and specific proposals, land matters, interpretation and education, and compliance with legal requirements. The NPS is responsible for the development and maintenance of inventories for cultural resources through the Archeological Sites Management Information System (ASMIS), the Cultural Landscapes Inventory (CLI), List of Classified Structures (LCS), and the National Catalog of Museum Objects.
See the List of Classified Structures online as an example of a NPS cultural resource inventory.
Evaluation and Categorization
These involve assessments of cultural resources to inform management decisions and determinations of eligibility using National Register Criteria (except for museum collections, which are not eligible for listing). Cultural resources might be nominated to the National Register as National Historic Landmarks, which have their own criteria beyond the standards for the National Register.
See sample nominations to the National Register to understand more about the process.
Treatment involves the care and maintenance of a cultural resource. Treatment might include stabilization, rehabilitation, documentation, restoration, survey or other actions that have some effect on the long-term preservation of a cultural resource. All treatment projects must be preceded by planning except in the case of emergencies, which have special protocols and restrictions.
See the Secretary of the Interior's Standards for the Treatment of Historic Properties for more information and adobe maintenance at Tumacacori NM as one example of a treatment.
Education and Interpretation
Education and interpretation are products of cultural resource management activities. Exhibits, ranger programs, lesson plans, ranger tours, websites, pamphlets, trailside markers, books, or other media are all ways of creating a public benefit from cultural resources. Such products enable parks to communicate the significance of their resources, and the work they do to preserve and protect them, to a broad audience.
See For Kids as an example of an educational website with interpretive components.
Cultural resources are considered throughout the planning process, such as in General Management Plans, Special Resource Studies, and other plans that address the future of park resources. Planning considers the research potential of the resource, the level of intervention required by treatment alternatives, the availability of data and the terms of any binding restrictions, the concerns of traditionally associated peoples and other groups and individuals, among other factors. It serves to ensure that treatment of cultural resources are appropriate.
The PA specifies qualifications for the Park Section 106 Coordinator and the CRM Team designated by the Superintendent.
Park Section 106 Coordinator
The Superintendent designates at least one person to act as the Park Section 106 Coordinator. The Superintendent chooses the Section 106 Coordinator from the park staff, other NPS parks, NPS archeological and preservation centers, or the NPS Regional Office. The Section 106 Coordinator must have an appropriate combination of professional training and/or experience to carry out the responsibilities of the position.
The Superintendent designates a CRM team to fulfill and implement the requirements of the PA.
Criteria for the CRM team are:
- Subject matter experts appropriate to the resource types found in the park. The number of individuals on the CRM Team may vary from park to park as needed to represent all disciplines appropriate to the park's resources. The PA recommends multi-disciplinary reviews of proposed undertakings.
- Members of park staff or staff of other parks, NPS Regional Offices, NPS Centers, federally recognized Indian tribes, Native Hawaiian organizations, or others from the public or private sector.
The qualifications for the CRM Team are as follows:
- Federal employees must meet the qualifications for the applicable discipline as defined in Appendix E to NPS-28: Cultural Resource Management Guideline.
- Representatives of federally recognized Indian tribes may be traditional cultural authorities, elders, or others experienced in the preservation of tribal culture. These individuals are not held to Federal qualifications for cultural resource professionals, as per the PA. They are designated by the tribe.
- All other CRM Team members (contractors, advisors, SHPOs, or others from the public or private sector) must meet the Professional Qualification Standards in the Secretary of the Interior's Standards and Guidelines for Archeology and Historic Preservation.
The PA specifies that park staff, including Superintendents, must demonstrate periodic training in Section 106. Superintendents are required to report on training that they and their staff receive as part of their biennial reports. Training in Section 106 may be obtained through the NPS, ACHP, SHPOs/THPOs, Indian tribes, Native Hawaiian organizations, other Federal or state agencies, or private industry. The format is flexible. Check with your Regional Section 106 coordinator about opportunities in your area at the regional level, or with non-profit organizations or for-profit companies.
Training through DOI Learn
Courses in cultural resource management are available through DOI Learn. DOI Learn keeps a transcript for each student that will provide Superintendents with a record to meet their reporting requirements.
Agencies throughout the Federal government, including the NPS, offer cultural resource management training courses in Section 106 and related topics through DOI Learn. Search the Course Catalog for offerings. Courses are also announced through InsideNPS (intranet only). They may be specific to Section 106 or to its application within the management of specific cultural resource types. Some courses involve travel, but others are available online.
The PA Toolkit counts towards the training requirement. Students register in DOI Learn, review the content within this website, then return to DOI Learn and correctly answer 80 percent of the questions to receive credit. The PA Toolkit is listed in the course catalog as "Nationwide Programmatic Agreement Toolkit." See the Course Certificate page for details.
Training by the Advisory Council on Historic Preservation (ACHP)
The ACHP offers introductory and advanced level training in Section 106. Section 106 Essentials is a two-day course designed for those who are new to Section 106 review or those who want a refresher on its basic operation. The Advanced Section 106 Seminar focuses on the effective management of complex or controversial undertakings that require compliance with Section 106. Designed for experienced Section 106 users, the seminar focuses on the challenges of seeking consensus and solving adverse effects to historic properties. Visit the ACHP website for more information.
Training by the State Historic Preservation Officers (SHPO)
SHPOs also routinely provide Section 106 training. Check with the National Conference of State Historic Preservation Officers for more information.