Ladies and Gentlemen,
One of the main reasons Amity Pueblo was desecrated lies with the archaeologist and project managers’ failure to provide an adequate records review and project description such that consultation could be meaningful and effective. In an effort to understand how Amity happened, in what ways different players are responsible, and what needs to change to avoid such crimes in the future, excerpts from the survey report and associated documents are provided below. The actual documents and locational data have been withheld. It should be noted that the supposed 1:24,000 scale map is of insufficient scale to evaluate APE boundaries within the actual cultural landscape and that the geographic coordinates defining the survey area are 900 feet West-Northwest of the project location of the project. Draw your own conclusions there...
The 1 page report:
Eagar pond and parking lot 11/11/2010 by Miles Gilbert
AZGFD proposes to level and develop for public fishing and parking approximately 6 acres. A cultural resources inventory survey of the APE was conducted by NRCS Cultural Resources Specialist Miles Gilbert and AZGFD Fish Specialist Kelly Meyer with the result that no cultural resources were found. An electronic query of AZSITE located site AZ Q: 15: 74 (ASM) a PIII rubblemound within 100m of the proposed APE. See attached 1:24,000 scale map. The proposed APE will avoid the site boundary by at least 100 feet. A finding of no historic properties affected is recommended for this project.
Ownership: Private No. of Cultural Resources Recorded: 0 Number of Isolated Finds: 0
YES, THAT IS THE ENTIRE SURVEY REPORT.
The resulting SHPO consultation letter offered no additional information:
To James Cogswell, Archaeologist Arizona State Historic Preservation Office
Dear Mr. Cogswell:
The USDA-Natural Resources Conservation Service (NRCS) is providing technical assistance for the Arizona Game and Fish Department (AZGFD) to level and develop for public fishing and parking The project is located and mapped on REDACTED. The archaeological inventory of the project area was conducted by Dr. Miles Gilbert with the assistance of AZGFD Fish Specialist Kelly Meyer in November 2010 and required two person days to complete. Fifteen meter (50 foot) survey transect intervals were employed in the survey. The UTM point locations of the APE were recorded with a Garmin Map 76 GPS instrument set on NAD '83. No cultural resources were found. An electronic query of AZSITE located Site AZ Q:15:74 (ASM) a PIII rubble mound within 100 meters of the proposed APE. The proposed APE will avoid the site by at least 100 feet. A finding of No Historic Properties Affected is recommended for this project.The Eagar Pond and Parking lot APE is located within the area of traditional interest of: The Hopi Tribe, The Pueblo of Zuni and The Navajo Nation. Copies of this report will be sent to each tribe. Please send your comments concerning this project to me at the address above. We would appreciate receiving your remarks within 30 days of receiving this letter.
Sincerely, Arizona State NRCS
A stamp at the bottom of the letter says:
No Historic Properties Affected
James Cogswell 3/7/11
Arizona State Historic Preservation Office
Arizona State Parks Board
I encourage readers to ask if a single-page summary report with incorrect and inadequate geospatial data and project information can constitute consultation and to draw their own conclusions regarding SHPO’s concurrence, AZGF’s failure to employ and so oversee their own cultural resource specialist, and FWS’ ultimate responsibility as lead agency.
You ask: was a single page summary report adequate ?
ReplyDeleteIn this situation, and at this location right next to a major Pueblo building, why would the number of pages in a report make any difference ? How much documentation does anyone really need to have, to know that a massive 10-acre construction next to a large Pueblo would have serious effects ? Not only were direct impacts to surrounding features and deposits a certainty during construction. Apparently nobody also thought of the long-term secondary effects of placing an unsupervised recreational facility at this spot - on the Pueblo's doorstep. Obviously, some of those recreationalists, sooner than later, would start messing with the Pueblo building after they had belted a few beers and were waiting for the fish to bite.
Plain and simple, this project was sited too close to the known Pueblo. So, to answer the question posed, I don't think the number of pages in the report is at all relevant here. One sentence should have done it: don't build a huge, unmanned and unsupervised recreational facility here - pick another place, without a big Pueblo sitting alongside it. This was a no-brainer.
Inadequate records review, blind surveyors, and inadequate or absent SHPO review....
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