Disclosure of archaeological site locations to the public, especially
those that are on or considered eligible for the NRHP, is a violation of
Section 11(c) of 36 CFR 800. Site locations may not be disclosed when
there is a risk of invasion of privacy, a risk of harm to the historic
property, or if disclosure of the location would impeded the traditional
religious use of a site by practitioners. The lead federal agency is
also required, per Section 2 (1)(a) to ensure that all contractors meet
the Secretary of the Interior's standards for archaeology or
architectural history.
Daniel B. Davis
Archaeologist Coordinator
Kentucky Transportation Cabinet
Division of Environmental Analysis
200 Mero Street
Frankfort, KY 40622
(502) 564-7250
-----Original Message-----
From: HISTORICAL ARCHAEOLOGY [mailto:[log in to unmask]] On Behalf Of
David Rotenstein
Sent: Saturday, June 10, 2006 7:49 AM
To: [log in to unmask]
Subject: Site location disclosures to public & FCC
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=38
3193
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
_________________________________________
ACRA-L is a public listserv supported by the American Cultural Resources
Association (ACRA), a non-profit trade association, for the use of the
cultural resource management community. You do not need to belong to
ACRA
to subscribe to this list. As a result, opinions expressed on the list
do not necessarily represent the views of ACRA or of its members. For
more information on the list and to unsubscribe use the links below.
_______________________________________________
acra-l mailing list
[log in to unmask]
http://lists.nonprofit.net/mailman/listinfo/acra-l
|
