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Thu, 10 Nov 2011 09:48:12 -0500
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One of the penalties for the distance of historic preservation from the 
public. It continues to be the realm of the politically connected social 
elite and they scare off the general public.
the historical society is mostly society and minimally historical......

Anyone interested in maintaining historic preservation in the future must 
work now quickly to totally retool the current approach.

One thing that is certain- if you reach the public properly it is an 
unstoppable force. Whatever has been done is failing us and needs drastic 
total rebuild.....

Just a few thoughts.....

Get rid of the socialites as well as the professionals who simply protect 
their pay checks.....

Conrad

-----Original Message----- 
From: [log in to unmask]
Sent: Thursday, November 10, 2011 9:42 AM
To: [log in to unmask]
Subject: letter of concern re S. 02053, Mass bill threatens archaeological 
sites

Good morning,









  I am writing to bring your attention to proposed legislation in the 
Massachusetts State House, now in committee, that would restrict the 
authority of the Massachusetts Historical Commission oversight to only those 
sites listed on the State or National Register of Historic Place 
(http://www.malegislature.gov/Bills/187/Senate/S02053). ; This legislation, 
which is aimed at eliminating the MHC's authority to require mitigation for 
a single business property (MediTech; see 
http://www.medi-talk.com/tag/massachusetts-historical-commission) (see also 
http://www.bostonglobe.com/metro/2011/10/25/sides-differ-over-meditech-derailed-freetown-expansion-plan/AqhPlgYMVK0NGrwXowEfoO/story.html), 
would if passed eliminate oversight protection for nearly 140,000 historical 
and archaeological sights in Massachusetts that have been inventoried by the 
MHC but are not listed on the State or National Registers of Historic 
Places.  This includes some 12,000 known archaeological sites, and would 
also eliminate the protections afforded by MHC oversight of development 
involving state or federal funding, licensing, or permitting from 
archaeological sites that have not yet been identified.
  To date, there has been very little public notice of this bill, so I urge 
you to share this email with colleagues and to add your voice in opposition 
to this bill.  A copy of a letter of concern submitted by the Council for 
Northeast Historical Archaeology is copied below.

Sincerely,
Karen Metheny
Chair, Council for Northeast Historical Archaeology (www.cneha.org)







----------- 
The Council for Northeast Historical Archaeology


November 7, 2011
Senator KennethJ. Donnelly
RepresentativePeter V. Kocot
Chairmen, JointCommittee on State Administration and Regulatory Oversight

Dear SenatorDonnelly and Representative Kocot,

On behalf of theExecutive Board of the Council for Northeast Historical 
Archaeology and all ofour members, I wish to express our deep concern with 
proposed legislation thatwould remove critical protection from 
archaeological and historical sites inthe Commonwealth of Massachusetts. 
Specifically, the proposed bill, S. 02053, will eliminate key protections 
for archaeological andhistorical resources in the Commonwealth that are not 
on the State Register ofHistoric Places.  The proposednarrowing of state 
regulations and the elimination or restriction of stateoversight for 
construction or renovation projects that involve state or federalfunding, 
permitting, or direct involvement of a state or federal agencyimperils the 
Commonwealth’s historical and archaeological sites andresources.  Further, 
this proposalundermines the legislated function of the Massachusetts 
Historical Commissionas the permitting and oversight authority for mandated 
archaeological surveywithin the Commonwealth and as steward and manager of 
irreplaceable culturalresources.  Finally, the loss ofprotection for 
archaeological and historical resources in the Commonwealth willhave an 
adverse economic impact in Massachusetts through its effects on theheritage 
tourism industry.

Theproposed bill, S. 02053, would limit mandated state development review 
andoversight to only those archaeological and historical sites listed on the 
StateRegister of Historic Places and will consequently undermine the 
authority andeffectiveness of all previous reviews and recommendations for 
mitigation issuedby the MHC for historical and archaeological sites that 
have been evaluated andinventoried through the review process but are not on 
the State Register.  Passage of S. 02053 will disproportionatelyaffect 
archaeological sites in the Commonwealth for a number of reasons.  First, 
few archaeological sites arenominated for the State Register. There is 
little incentive for property owners to file for Registerstatus.  Existing 
tax creditsbenefit owners who are seeking to restore or rehabilitate extant 
structures,not owners of sites with below-ground archaeological resources. 
The number of archaeological andhistorical sites on the State Register of 
Historic Places (60,000 sites; see 
http://www.sec.state.ma.us/mhc/mhcstreg/streg.htm)represents barely one 
third of all sites in the MHC’s inventory (200,000archaeological and 
historical sites combined; see Massachusetts State HistoricPreservation Plan 
2011-2015 [2011]; http://www.sec.state.ma.us/mhc/).  Under the current 
proposal, anestimated 140,000 sites (historic buildings, structures, 
cemeteries, andarchaeological sites) will lose protections afforded to them 
through stateoversight and review because they are listed in the MHC’s 
inventory of sitesbut are not on the State Register of Historic Places. 
Crucially, some 8000 Native American archaeological sitesand 4600 
historical-period archaeological sites in Massachusetts willeffectively be 
removed from the oversight of the MHC if this bill ispassed.  Of equal 
concern, S. 02053will undercut the review process through which potential 
dangers to
as yetundiscovered archaeological sites are mitigated.  If passed, this 
legislation will undermine the MHC’sauthority and the Commonwealth’s 
mandated responsibility to protect culturalresources; further, it will place 
responsibility for site protection ormitigation in the hands of owners and 
builders, and it will leave residents ofthe Commonwealth in the unfortunate 
position of relying upon the goodintentions of owners and developers for the 
protection of irreplaceablecultural resources and heritage sites that belong 
collectively to all of theCommonwealth’s residents.

The proposedlegislation has negative, broad-reaching impact for many of the 
Commonwealth’scitizens, and we ask that you consider the following:

•S. 02053 will disproportionately affect Native American sites because so 
feware identified or preserved.  Itrequires applied technical effort to 
locate prehistoric archaeological sitesand list them the State and National 
Registers;
•S. 02053 will have a devastating effect on archaeological sites that are 
notlisted at the state and national levels because there is not yet 
enoughinformation about them to do so;
•S. 02053 reduces the power of local historical societies and towns that 
havelisted sites as locally important but have not yet completed the 
applicationprocess at the state and/or federal levels.  Massachusetts prides 
itself on the importance of local towngovernment, so it is important that 
communities be allowed to recognize,advocate for, and protect locally 
significant sites when they deem itnecessary;
•S. 02053 will undermine the intent of existing federal and state 
legislationthat makes federal and/or state funding, licensing, or 
permitting, or state orfederal agency involvement the trigger for site 
review; the National HistoricPreservation Act of 1966 and Massachusetts 
General Laws Chapter 9, sections26-27C, are written specifically to include 
sites that are not on the State or National registers;
•Given the role of the Commonwealth in reviewing development, issuing 
permits,and collecting fees, there is sufficient justification for continued 
stateregulatory influence;
•While the State Register of Historic Places is important, it does not list 
allof the places of historical importance to the residents of the 
Commonwealth.

The proposedchanges in S. 02053 will also have a detrimental impact to the 
economy.   The Commonwealth’s archaeologicaland historical resources are the 
basis for a growing and vital heritage tourismindustry, one that already 
generates significant revenues for local and stateeconomies across the 
country. Heritage tourism contributes jobs, raises income levels, increases 
taxrevenue, and contributes to overall economic wellbeing.  In 
Massachusetts, spending related toheritage tourism in 2002 was estimated to 
be 2.5 billion dollars (EconomicImpacts of Historic Preservation in 
Massachusetts,
http://www.sec.state.ma.us/mhc/mhcpdf/Economic_Impacts_2002.pdf).  This is 
not an insignificantcontribution, especially in light of the current 
recession.  The Commonwealth’s commitment to theprotection of its resources, 
or its failure to do so, will impact the vacationand recreational plans of 
residents and out-of-state visitors, as well as thoseof participants in the 
many educational, historical, and museum programs thatare built upon access 
to and enjoyment of those resources.

The Council forNortheast Historical Archaeology (CNEHA) is a non-profit 
educationalorganization with over 400 members in the eastern United States 
andCanada.  Our membership comprisesprofessional archaeologists, historians, 
educators, and cultural resourcespecialists.  The sole purpose ofthe Council 
is to stimulate and encourage the collection, preservation,advancement, and 
dissemination of knowledge gained through the study andpractice of 
historical archaeology. The Council specifically encourages fieldwork, 
collections research,conservation, education, and public outreach.  This 
organization was founded in 1966 by professional andavocational 
archaeologists and historians who were alarmed by the destructionand loss of 
historical and archaeological resources in the Northeast.  The Council 
evolved out of an awarenessof the need to preserve and protect the 
historical archaeological record and toshare that past with others.  It 
isthat awareness that compels us to now express our deepest concern for 
thefuture of archaeological and historical resources in the Commonwealth, 
and ourconviction that the protection of these important resources is 
jeopardized bythe proposed legislative changes.

We understandthat many in the Commonwealth of Massachusetts are confronted 
with difficultiesas a result of a poor economy, while others question the 
role of government andthe need for government regulation. Those acting on 
behalf of the Commonwealth must be far-sighted enough,however, to see that 
the state’s legislated role as steward and protector of all its many 
resources must not besacrificed.  S. 02053 is a misguidedattempt to 
streamline the development review process; the proposal isshort-sighted and 
will not only eliminate essential protections for theCommonwealth’s precious 
cultural resources but also adversely affect a powerfuleconomic engine in 
the form of heritage tourism.  Massachusetts residents would be better 
served by increasedefficiency and coordination in the development review 
process, not bylegislation that effectively abrogates the Commonwealth’s 
responsibility toprotect irreplaceable historical, archaeological, and 
cultural resources forits citizens.  We ask that thecommittee carefully 
weigh the effects of this proposed legislation, with fullunderstanding of 
the risks to the Commonwealth’s heritage resources and to itsalready fragile 
economy.  In short,we ask you to bring a thoughtful and responsible approach 
to the issue athand.  We urge you to vote against S.02053.

Thank you foryour time and consideration.

Sincerely,





Dr. KarenMetheny
Chair, Councilfor Northeast Historical Archaeology

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