You are correct in that the ECMs (earth covered magazines or sometimes
"igloos) at Wingate were considered for "artifact storage."  Incorrect in
that there was not a financial issue.  Climate control, accessibility of the
facility, the ability to manage and retrieve material from a thousand
separate ECMs, the cost of transferring material to Gallup, staffing costs,
environmental cleanup costs, addition of sprinkler systems (including the
laying of miles of water and water return lines), and ultimately - who would
pay for all of this?  The first offer (by the law) of these facilities
closed as part of BRAC was to other Federal agencies.  None stepped forward
for reuse as curation facilities.  The next offer must be to a local
redevelopment agency.  Part of Wingate is going to the redevelopment
authority, part is (supposedly) going to BLM, and part is currently being
used by BMDO as a test launch facility.  Wingate is not the only facility
that was closed that the NPS could have jumped on if they really wanted to
store material, there was the Detroit tank plant at one million square feet
in one building, the excess Savanna (IL) Army Depot (another facility with
ECMs), Seneca (NY) Army Depot (also ECMs), and others with just warehouses
and other buildings such as Lexington (KY) Depot, Jefferson (IN) Proving
Ground,  or the Indiana Ammunition Plant.  All came with a cost for
conversion and no Federal agency would step forward with a plan for curation
in these facilities. The facilities are typically more productive as local
redevelopment projects for manufacturing and other uses.  Now, if some
enterprising person (like yourself) wanted to contact the local
redevelopment authority and propose a business development use of these
facilities as an artifact curation facility, have the capital to do all of
the modifications required to make the facility meet the conditions of
36CFR79, and get a commitment from Federal agencies to send the material to
this repository (probably at the objection of individual states), you may
actually be able to pull it off.

Stephen P. Austin


-----Original Message-----
From: Mark Henderson [mailto:[log in to unmask]]
Sent: Wednesday, November 29, 2000 12:06 AM
To: [log in to unmask]
Subject: Re: Culling & Selling artifacts


"Dendy, John" wrote:
>
> Okay, just a reminder, anything done under an ARPA permit or in lieu of an
> ARPA permit or financerd by the federal government requires the "in
> perpetuity" curation and compliance with 36 CFR 79. Selling, culling, etc.
> cannot be permitted. Selective accession is about as far as anyone can go
> legally. We can, of course, limit our collection strategies, but our
> excavations must adhere to ARPA regs.
>
> John Dendy

I believe there is another often used (abused?) method of culling ARPA
materials found in 43 CFR 7.33 "Determination of loss or absence of
archaeological interest." This process takes place routinely (although
possibly not with strict adherence to the letter of the regulations)
when remaining archeological resources are damaged or destroyed after
archeological treatment has taken place.  My experience has been that
the lithic materials, glass and metal left after "treatment" projects
are sometimes substantial.  I have occaisionally been quizzed about this
by development project employees who wonder why the archeologists left
arrowheads, bottles and other "collectibles" on their completed
projects.  This is of course different from items that were targets for
collection, but were missed during treatment.
        On a slightly different tangent, I think there is often a
presumption
that we don't have storage space, based on economics, when we have
actually not activated ourselves on some opportunities to expand storage
capacity.  The military in the US has surplused thousands of war
material storage bunkers that by my reckoning have great potential for
archeological material bulk storage.  We have not lobbied effectively
for archeological adaptive re-use of these largely WWII and Cold War era
facilities as part of a National Repository System.  Over 12 years ago
for example some of us thought that Wingate Army Depot near Gallup New
Mexico with nearly 1,000 bunkers might make an ideal regional repository
as part of a National Archeological Repository system.  The major
obstacle I believe was not financial but conceptual.  That is the
established archeological interests saw this as a threat to the current
system of research repositories.  I perhaps very naively, believe that
there was, and maybe still is, opportunity to convert some of these
facilities as storage repositories, if there was consensus in the
archeological community that this was a reasonable idea.  The
establishment didn't like it for reasons that I can expand on if this
post promotes further discussion.  Let me say that I believe there were
Congressmen that would have been very supportive if they had seen
concensus. -Mark
Mark Henderson
Ely, Nevada