"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