3 Truths Behind TCP Management (Part 1)

    This is part one of a three-part series. 

    Despite the intent and strengths offered by the 1990 publication of National Park Service Bulletin 38 entitled "Guidelines for Evaluating and Documenting Traditional Cultural Properties", cultural resource managers are still challenged by tribal TCP management 27 years later. On one hand, it is no surprise that those with no previous TCP training and no previous first-hand knowledge of Native history and culture, are challenged by the topic.  On the other hand, who are those responsible for teaching about TCP management?  I used to think these deficits were related to age.  The term TCP was not coined until after much of the Boomer generation had already gone through college.  But, we are seeing other generations troubled with TCP management as well.  The evolution of TCPs has been all too slow for tribes. I have compiled a list of three topics, language, religion, and human remains, to help the multiple generations of resource managers navigate TCPs.

    For this, I provide historical context for each item as a way to understand the weight of tribal TCP management.   We take many of these things for granted yet the right to Native American languages, religion, and ancestral human remains are not inherent freedoms in the United States.  This is the first of a three-part series.  

1) Language

    Parker and King (1990) should've put Appendix II, Professional Qualifications: Ethnography in the front of Bulletin 38 because the cultural resource managers are rarely ethnographers in the public sector.  Much of the TCP information is handled by archaeologists, with little to no formal training in ethnography or TCPs.  Moreover, the very first qualification Parker and King list is language and the ability to speak another language.  There are still those that have worked with Tribes enough, to gain some proficiency in tribal languages.  Those archaeologists tend to be more successful than those who have no proficiency.  

    The relevance of language to Tribal TCPs is understanding the sounds and meanings of place names and significance statements pursuant to NHPA.  If one cannot understand at least some of the sounds or meanings, typically have place names associated.  If the cultural resource manager is not familiar with the sounds or the meanings within the language, they are not going to be able to fully capture significance pursuant to the National Historic Preservation Act.  The inability to effectively communicate meaning could have disastrous effects to resources and communities.  


"In the difference of language to-day lies two-thirds of our trouble ... Schools should be established, which children should be required to attend; their barbarous dialects should be blotted out and the English language substituted" (quoted in Atkins, 1887) 

    --1868 Federal Commission on making peace with Plains Indians

  It has been estimated that 155 indigenous languages are still spoken in the United States, however, 135 of those (87%) are moribund (spoken only by older generations with no transmission to younger generations) (Krauss 1992).  Krauss further estimated that 105 of those languages would be extinct by 2025 and 135 of those languages would be extinct by 2050.     

    From 1860 to 1980, with some existing today, Indian Boarding schools were the mechanism to change Native Americans into white, Christian, english-speaking, farming, landowners.  The first boarding schools occurred on-reservation, however, those were not as effective as the off-reservation schools such as the Carlisle Indian School created in 1879.  For 6 generations, native children were physically, emotionally and sexually abused at boarding schools across the continent.  Harsh punishments were given to children for speaking their language.  Kids were told to put rubber bands in their mouths while the teacher pulled the rubber band back to snap the kid's mouth.  Other punishments included washing mouths out with soap, whipping, spanking, and cracking rulers across hands.  These were routine punishments to assimilate Indians into American society.  The attitude of government officials at the time are best captured with the quote, "The language of the white man and the black man ought to be good enough for the red man" written by a commissioner of Indian Affairs in 1887.

     A BIA teacher in the early 1900s explained that the schools "went on the assumption that any Indian custom was, per se, objectionable, whereas the customs of whites were the ways of civilization. ... [Children] were taught to despise every custom of their forefathers, including religion, language, songs, dress, ideas, methods of living" (Albert H. Kneale, quoted in Reyhner, 1992

    It wasn't until 1990, that Native American languages would get some reprieve by the Native American Languages Act, which essentially recognized the importance of Native languages and a call to action to preserve them.  Although the law provided no dispensation for such activities, it did reflect a policy change within a government that had a long history of assimilationist policies towards Native Americans.  

     My maternal grandparents attended Indian Boarding Schools.  My maternal grandmother attended Chemawa Indian Boarding School as did her parents.  She described her punishments for speaking the language and was eventually pulled from Indian Boarding school by her grandmother, who didn't speak English at all.  My grandmother would have to take care of her younger siblings due to her own mother's ailing health.  She spoke our language to me as a child, but she hesitated to speak it outside the home, likely out of fear instilled by her boarding school experiences.  

     Stigmas about speaking Native languages remains,  there is a sense of great fear that has been carried by Native Americans for 120 years.  Much of the cultural information contained in Native languages have been lost with the changing of Native cultures.  In addition to boarding school attendance,  another form of assimilationist policies specific to language, has been the physical removal of Native Americans from their traditional homelands.  Specific names, events and places have been lost because tribes were removed as a result of the Dawes Severalty Act of 1887 and the Indian Removal Act of 1830.  With the added economic pressures, further Native language deterioration has continued to occur.  

     How does this impact TCP management?  

    The connection to between language and TCP's as historic properties of religious and cultural significance pursuant to NHPA is nicely summarized by Fishman (1991) who wrote "The destruction of a language is the destruction of a rooted identity".  That is the destruction of language is the destruction of Native identity as it relates to the land and the resources.  

   While language is listed as a qualification for an ethnographer working with TCPs, in North America, this is easier said than done.  For management of TCPs, at least in Washington, federal agencies have relied heavily upon Tribes to supplement information for evaluation and identification.  While this seems the most logical and easiest method, knowing what we know about the disadvantaged history of Native languages, Tribes may not be in the best place to hold this responsibility on their own.  With little to know trained ethnographers knowledgeable in any Native language on staff in federal agencies, as suggested by Parker and King,  the burden is upon Tribes to transmit Native language information into a completely foreign language (i.e. English) paradigm.  This is assuming that most of this information is translatable, which is it most definitely not.  The risk of error is further loss of resources and consequently the strong possibility of further language loss.  

Where do we go from here?

 1. Professional standards: Professional cultural resource managers should have Native language training at the graduate level.  Washington State Bar now includes Indian law as part of its requirements for attorneys wishing to practice law in the state.  The Federal Government, held to its Tribal Trust Responsibility, should require that all professional archaeologists and anthropologists working under the National Historic Preservation Act of 1966, be held to a standard that would require a level of Native language proficiency in order to constitute a "reasonable and good faith effort" as stated under the law.

 2. Mitigation or Treatment:  Language loss needs to be integrated into the identification of adverse effects pursuant to NHPA.  The connection between TCPs and Native languages needs to be fully realized within the federal process.  Treatment of adverse impacts needs to be assessed by Tribes and funding needs to be identified for Tribal language revitalization efforts if avoidance of resource loss cannot occur.  

 3. Legislation: The Native American Languages Act needs to amended to be enforceable within the federal system.  

4. Advisory Council on Historic Preservation: The ACHP should be stressing the importance of integrating Native languages into the TCP management process.  This integration should not be assumed.  Tribal Cultural Resource Programs should not bear the sole burden of TCP protection, especially if federal agencies are not employing individuals trained in TCP management or have any Native language proficiency.  Language barriers are rampant, and if both Tribes and Federal agencies are not doing their due diligence to ensure the highest level of resource protection, then TCP management disasters will continue to occur.  


     Many of you may feel that my recommendations are too idealistic, stringent and unrealistic.  Even I am taken aback by these recommendations.  However, when I look at what has been endured by Tribes, in terms of culture and language loss, these are the only conclusions I can come to.  I may not like them myself.  The famous geologist Harlan Bretz did not like the conclusions he came to when first he discovered the cataclysmic floods known as the Missoula Floods, yet he could not deny them.  In no way, shape, or form do I compare myself to the renowned Harlan Bretz, yet I too, cannot deny the brevity our Tribal languages and resources face. At what point will we have mitigated our entire cultural history away to be placed in boxes in museums, filed away in cabinets, and shelved in libraries? Or, do we begin to truly account for impacts to TCPs as understood by tribes instead of what is merely comfortable for archaeologists?



  • I very much enjoy your blog and this post in particular – I was wondering when the other two parts might be coming out? I am having my class on Heritage Resource Management read this post and would like to assign your future posts on the topic of TCPs as well. Thanks…

    Matt Sanger
  • I really appreciate your effort on the cultural issues. Your example of Native American on language touched my heart.
    I agree with you 100%.

    Divya Shrivastava

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