Since the list has had a lot of traffic on the Rogers Island burials, I
thought I would forward this information from ACRA-L for those who don't
subscribe. Yesterday I sent a few colleagues information that the FCC is
posting complete archaeological site reports on its public licensing and
antenna structure registration Web site. Yesterday I read an EA that was
just posted with several Georgia prehistoric sites clearly shown
(information included a fax from the Georgia SHPO with a quad sheet showing
all sites within what looks lie a one-mile radius of a proposed tower site
plus copies of the relevant archaeological site forms). The site forms,
etc. are at the tail end of the 150 page report.
You can download the EA at:
<http://wireless2.fcc.gov/UlsApp/AsrSearch/asrApplication.jsp?applKey=383193
5>
Go to the bottom of the page and select "1250967 NEPA 1 of 2" -- be advised
it's a massive PDF (10 meg.).
When I forwarded Tom King, et al. the information on the FCC making
available the specific locations of archaeological sites in environmental
assessments (EAs) posted for public review, I mentioned to Tom that I had
told the FCC that this was a bad idea back in May 2003 (see email quoted
below). There are more than 700 EAs available at the FCC Web site. Although
the one mentioned in yesterday's email was done by a professional who should
have known not to prepare a report for public dissemination with such
site-specific information, think about the hundreds of EAs filed by the
"environmental consultants" used by FCC licensees prior to the inception of
the silly PA. The standard operating procedure was to copy everything in the
SHPO files (if the SHPO was ever consulted) and stick it in the EA. This
includes archaeological site forms, quad sheets with all sites marked, etc.
Anyone who wants to get these files just needs to go to the FCC's Antenna
Structure Registration Web site and download the text-delimited database
files, import them into Access and query for all registrations subject to
NEPA review. Another way to access all of these EAs is to troll through the
FCC's Daily Digests published each Friday with the weekly list of
"Environmental Actions" scheduled under "Antenna Structure Registration
Service Information." The locations of archaeological sites around the
nation are available to anyone with a computer and a little patience. This
breach may be comparable to the Indian Trust fiasco that shut down DOI Web
sites for months.
As for Section 106 under the PA, I attended the Society for Industrial
Archaeology meeting last weekend and spoke with many folks doing work as
subconsultants on FCC projects. It seems that FCC created a growth industry
with the new PA whereby information collected by geologists, ecologists, and
real estate specialists in SHPO files is copied and sent to Secretary of the
Interior-qualified subconsultants who "review" the material and sign-off on
the new FCC Forms 620 & 621 without ever doing any site visits or verifying
that the information collected from the SHPO is valid or complete.
Here's the email from 2003 sent to Deputy Chief of the Wireless
Telecommunications Bureau Jeff Steinberg, senior attorney Dan Abeyta, and
then-FCC cultural resources technician Amos Loveday; perhaps someone might
want to ask the FCC why this was never followed-up on:
-----Original Message-----
From: David Rotenstein [mailto:[log in to unmask]]
Sent: Tuesday, May 27, 2003 2:38 PM
To: [log in to unmask]
Cc: Dan Abeyta; Amos Loveday; Marc Holma; Autumn Rierson
Subject: archaeological site locations in FCC EAs
Importance: High
Jeff,
I just downloaded the EA prepared for the Albemarle, VA, project for which
FCC released its Memorandum Opinion and Order (File No. 0000986878) and
noticed that the EA available at the FCC Web site has archaeological site
locations indicated in maps (EA, "Exhibit C") that may be downloaded by the
general public. Archaeological site locations should not be provided to the
general public because this information may lead to the destruction of sites
by looting.
You may wish to keep this issue in mind for future EAs published on the
Commission's Web site.
Regards,
David.
_________________________________________
David S. Rotenstein, Ph.D.
Consulting Historian
10308 Edgewood Avenue
Silver Spring, MD 20901
Phone: (301) 592-0646
Fax: (301) 592-0618
Mobile: (240) 461-7835
E-mail: [log in to unmask]
Web: http://www.dsrotenstein.com
_________________________________________
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