Kelly Spradley-Kurowski: This is just a really basic slide to show primarily people not within the National Park Service, but I would suspect that maybe some within it wiykd like clarification of that sort of mysterious and wondrous journey that park nominations go through from the park to the actual listing stage. The key difference of course is just that the Federal Preservation Office takes a part normally placed by the SHPO in non-federal nominations. It serves as the nominating authority. We still involve the SHPO in their review and comment role and we rely on their knowledge of their states resources quite a lot. I see every nomination from every unit of the National Park Service and I hope to be able to give you sort of an overview of what I see from the parks recently regarding landscapes and give you some examples of the success that we’ve had in bridging some of these concerns.
I should point out that, although I sometimes am able to sit in on early discussions of park nominations, I usually come in at the end. I’m not privy to discussions of how concepts were formed or how nominations were structured at the early stages most of the time. If that team in particular I’ve worked closely with on a lot of these nominations has anything to add about early discussions I would encourage you to speak up.
In fiscal year 2013, I saw forty-four park National Register nominations or additional documentation documents. Some of them are still being processed in the 45 day clock system. A couple of them are still in kind of a review and comment stage but the basic structure of them is in place. Roughly two-thirds of them were for entire parks. Nearly half of those have used a landscape based approach or have been heavily influenced by recent a cultural landscape inventory or cultural landscape report in the preparation of the document. This is a list of all of those nominations that I’ve just mentioned. They’re coming from everywhere as I think we’ve gotten the sense from the previous presentations today. They’re coming from rural and urban environments. Some back in the heart of DC. They’re coming from inland and maritime locations. In fact it’s becoming quite rare from what I see for a park nomination or additional documentation not to reference the development of the landscape or to have a landscape component of some sort, particularly if the documentation is for an entire park.
Beth Byrd, Jill Cowley, Betsy Ingleheart, and Susan Dolan have done a very good job at explaining some of the challenges that I frequently see in nominations and incorporating the two programs. I hope that I can give you a few examples of some solutions that we’ve come up with to give the National Register program what it needs while using the landscape information effectively. As I go through these, I encourage everyone to remember that I’m talking about the current NR form and the current structure that we have. It’s just to give you an idea of what’s been coming in and what we’ve done to work with what we have. Hopefully we can refine these processes and make them better. Resource counting has been discussed extensively today. Saint-Gaudens is a very good example, the one that Betsy discussed. I hope that I can give you a couple more.
Beth previously mentioned the challenges that we encounter from the rules for counting resources that encourage counting groups and small scale resources as one contributing resource. Also not counting plant and vegetative materials unless they have some kind of cultural significance that can be attached. What we’ve been able to do so far is try to treat Section 7, where the actual resource count is recorded, a bit differently from Section 7 where the narrative is discussed. Betsy alluded to how this has been done with the historic associated feature.
Concept. This is the definition in larger print than the one that we were able to see on the slide from the Saint-Gaudens site. Essentially it just shows you how it is generally defined in the nominations whether in a footnote or in the text of Section 7. It’s starting to actually gain a little traction outside of the north east region now. Other nominations and regions have seen how it has been used in the northeast and they’ve appreciated the value it’s had. We’re starting to see it come in from a few other areas as well. These are two examples of where it has been used. The Salem Maritime National Historic Site Historic District photograph you see on the left is still in the process but I think we’re only dealing with a couple of technical things to wrap it up so I feel okay showing it to you. This is how we often see it used for this fence attached to the public stores building. It’s a small scale resource. It’s not one that typically would be counted individually in a National Register nomination.
On the right is a photograph of the Jones family and the ruins of their house in Biscayne National Park. This is the Jones Family Archaeological District. The Jones family, for those who don’t know, was responsible for settling areas of Biscayne National Park and preserving them and making sure they were entered into the National Park system. The remnants of their occupation of these two Key’s, Porgy Key and Totten Key, include archaeological sites. They include some key lime groves that the family had raised. They include ruins of other types of sites as well. In the nomination itself we only had two contributing resources. It was the site of Porgy Key and the site of Totten Key. They were listed as two archaeological sites. Each one had a number of associated features within them whether they were small scatters of artifacts throughout the site or whether it was on the larger side like the ruins of the house. Each one of those associated features was described and their contribution to the site significance was accounted for. But, then Section 5 only lists two contributing sites.
Betsy mentioned that Saint-Gaudens had used it successfully to list vegetative features as historic associated features and that’s the only one off the top of my head that I can think of, but Betsy may be able to give you some more ideas. I have felt certainly that it is a step in the right direction. It doesn’t necessarily have to be the end of the steps, but it’s a step toward actually recognizing that we need to bridge the two programs. I’m hopeful for the use of this in the future.
Additional documentation boundary changes are very common to park units, primarily due to the preponderance of historic and cultural units that we have. By law these are entered into the National Register upon authorization. This may or may not mean that National Register documentation is done at that time, but for today let’s assume that we’re talking about parks who’ve had some level of National Register documentation completed in the past and are now submitting updated documentation. The new document will usually be intended to incorporate the old material and include discussions of new resources and very frequently landscapes that need to be added.
Our biggest concern when this is done is that the new documentation is absolutely crystal clear as far as what is being added and what was previously listed. The new resources might include a single cultural landscape that has been mentioned as one site. Sometimes, as was the case here at C & O Canal National Historic Park, varied component landscapes may have been identified through landscape initiatives in the past and each one of these will be counted as one site. Within those sites there will be National Register countable resources such as buildings and structures. There will also be historic associated features. We are making sure that each one is very, very clear as to which category it falls into and each one is addressed equally. This documentation is still in process but we’ve had very good discussions at early stages with the park, with the regional cultural landscape staff and with the register staff here at WASO. I think that we have identified a good way to proceed with this.
Finally, complexity is an issue that we all are dealing with and it really overlaps with additional documentation and boundary changes. The complexity increases with park wide documentation primarily due to guidance in Appendix Q of the Cultural Resource Management Guideline. For historic and cultural units this advises parks to complete one National Register form for the entire park, taking into account all areas, periods and levels of significance whether they’re related to each other or not. In this way the register form, of course, becomes a much more efficient management tool. It also creates a massive web of complexity that we all have to somehow sit down and untangle in order to understand things.
These are photographs from three of the landscape character areas identified as the Herbert Hoover National Historic Site in Iowa. It was administratively listed in 1966 and then the first National Register documentation was completed in 1978. In 1995 a landscape report identified six landscape character areas that dealt with multiple periods within Hoover’s life, the commemorative period after his death, and the potential for prehistoric resources within the park boundary. These were used to structure the format of the nomination. Within each area the National Register countable resources, the spatial organization, land use, circulation and views and vistas were all discussed. Then we had to also make sure we dealt with the previously listed resources.
There were some listed in 1978 that had since been destroyed or lost. A few that had changed status. So this was an extraordinary complex document to get through. It took a few versions. We had to go back and forth a few times, but ultimately it was a successful listing that I think was listed in October or November of this year. The use of the landscape character area allowed us to frame and structure a really complex site into manageable chunks and it really helped us to understand the site development over time much more effectively.
So, that is a very quick overview of the issues that I frequently see. I am happy to report that in all cases so far we have worked very closely with the National Register Program, the preparer, the park, the region to try to overcome these challenges. I’m very hopeful for the future.