John: We disagree yet again.  Provide a citation for any law or codified
regulation that says specifically that ALL material collected from an
excavation/mitigation MUST be curated, or even analyzed.  Subject
excavations routinely identify which component of a site is significant and
what is to be discarded as not significant to the research question, lacking
context, or to be sacrificed in order to obtain the most significant data
possible.  If the material (data) collected is part of the Section 106
consultation and identified as such, then yes it is to be held as part of
the permanent record.  Of course, the 106 consultation could stipulate what
material will be keep and what is to be discarded just as easily.  My point
was that the spending of public funds to keep every piece of undiagnostic
debitage or bottle cap found for perpetuity (or, in most cases, even to
provide an analysis of such material) is irresponsible for a 'guardian of
scarce (becoming scarcer) public dollars.   Further, my response was not
about the de-accessioning issue - it was regarding how much data and what
kinds of data should be collected and curated as part of a mitigation effort
(which I assume is directed by a well thought out research design).  Your
attention to the SOI's own guidance on treatment of archeological data
recovery:

"The primary focus of archeological documentation is on the data classes
that are required to address the specified documentation objectives. This
may mean that other data classes are deliberately neglected. If so, the
reasons for such a decision should be carefully justified in terms of the
preservation plan.
Archeological investigations seldom are able to collect and record all
possible data. It is essential to determine the point at which further data
recovery and documentation fail to improve the usefulness of the
archeological information being recovered. One purpose of the research
design is to estimate those limits in advance and to suggest at what point
information becomes duplicative. Investigation strategies should be selected
based on these general principles, considering the following
factors:
1. Specific data needs;
2. Time and funds available to secure the data; and
3. Relative cost efficiency of various strategies."
And from the oldie but goodie ACHP's Treatment of Archeological Properties
(almost repeated in the current Recommended Approach for Recovery... offered
during the Part 800 revisions):
"2.  Destruction of the property, without recovery of data, may be accepted
by the consulting parties as a regrettable but necessary loss in the public
interest.
If the data contained in the property can be used to fruitfully address
valuable research questions, the data should be recovered.  If the data
cannot be used, data recovery is not an appropriate use of public funds, and
should not be undertaken.
...[text deleted]...
On the other hand, there is no more reason to study every archeological
property than there is to read every cheap novel ever published.  If it
cannot be shown, after a reasonable good faith effort to do so, that a given
archeological property can be studied usefully to address important research
questions, it should not be studied at public expense."

And yes John - I do believe there are significant amounts of material
(curated artifacts) which should probably be deaccessioned.  But that is not
my personal call and it is being worked by others with the power to make
those decisions.

Stephen P. Austin

> -----Original Message-----
> From: Dendy, John [SMTP:[log in to unmask]]
> Sent: Thursday, December 30, 1999 8:42 AM
> To:   [log in to unmask]
> Subject:      Re: costs for large-scale mitigation
>
        "By law, if it's a federal project, it ALL gets curated.
> Do I hear from one more sector of the Army that we should de-accession
> excavated material? Chuck it? An alarming trend in military thought to say
> the least."
>
>         John Dendy
>         Dynamac Corporation
>         Fort Riley, KS