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Letters to the Editor

A point of information concerning the otherwise excellent article by Ferguson et al. about the Hopi Cultural Preservation Office (CPO) in the Working Together column in the spring edition of the SAA Bulletin.

Ferguson et al. note that the Hopi have concluded that all ancestral archaeological sites (which, in the Hopi view, comprises virtually all of the prehistoric sites in the Southwest) are traditional cultural properties of concern to the tribe. In their view this makes these sites eligible to the National Register of Historic Places under criterion a-- association with events that have made a significant contribution to the broad patterns of history--as well as criterion d--their potential to yield information important to our understanding of the prehistory of the region.

Ferguson et al. go on to note that regulatory agency archaeologists did not agree with this position but that

The CPO has been successful in convincing some parties to the consultation process that its definition of archaeological sites as traditional cultural properties is valid. This definition means, of course, that the Hopi now expect to be consulted about the mitigation plan for archaeological sites suffering adverse impacts.

As one of the regulatory agency archaeologists who did not agree with the Hopi position, I would like to point out two things. The first is that any archaeological site with specific ancestral links to the Hopi people--whether those links are established through Western scientific methods, e.g., the presence of protohistoric Hopi pottery or through Hopi oral tradition, e.g., sites that are named in Hopi songs or stories--are considered as eligible under criterion a because of their association with the history of the Hopi. But much more important, the Hopi already have the right, established in statute and regulation, to be consulted about mitigation plans for any archaeological sites that are of concern to them. It does not matter which criteria of eligibility to the National Register are found to apply; the Hopi are consulted whenever they wish to be.

Our decision not to accept the Hopi proposal that all archaeological sites be considered traditional cultural properties and therefore eligible to the National Register under criterion a was based on a number of factors--some of them philosophical, some owing to our training in Western scientific method, and some purely pragmatic. Among the pragmatic considerations is the structure of the Section 106 consultation process.

Under existing state and regional agreement documents in New Mexico and Arizona, most consultations concerning findings of effect and mitigation of any adverse effects to archaeological sites are resolved among the federal agencies, the state historic preservation officers, Native Americans, and other interested parties, and are not reviewed by the Advisory Council on Historic Preservation. If all archaeological sites were found to be eligible under criterion a, however, most cases where there would be effect to archaeological sites and all archaeological mitigation plans would be reviewed by the Council, adding an absolute minimum of 45 additional days to the consultation process for each undertaking.

We should consider for a moment the coincidence that the column about this issue appears in the same issue of the Bulletin as the reprinted letter from three powerfully placed Congressional Representatives to the Executive Director of the Advisory Council concerning the undue regulatory burden posed by compliance with Section 106 of the National Historic Preservation Act. The authors of this Congressional letter note that "While it is a concept largely foreign to most federal regulatory agencies, time is money to the private sector."

Loathe as I am to disagree with members of Congress, the concept "Time is money" is not foreign to those of us who work in regulatory agencies. Indeed, it is one with which we are intimately familiar since it is propounded to us dozens of times a day by angry individuals from the private sector.

Given that accepting the premise that all archaeological sites are eligible under criterion a as well as criterion d would not provide any additional protection to those sites, would not confer upon the Hopi any consultation rights that they did not already have, and would add considerable time delays to large numbers of undertakings at a time when Section 106 is already coming under threat because it is perceived as an undue regulatory burden, we declined to accept the Hopi argument, even though many of us acknowledge that it has merit.

Such a pragmatic stance may seem repugnant to some who view themselves as advocates for the long-delayed rights of Indian people to assert control over their heritage. But to those of us on the front lines of efforts to preserve the prehistory and history of all the people of this country, using a process that is currently at considerable risk, pragmatism is an absolute necessity. Archaeologists and Native Americans are natural allies--we are the two groups in this whole country most passionately committed to preserving archaeological sites, and there aren't very many of us. We can't afford to waste time squabbling with each other over things that do not contribute appreciably to the preservation of our prehistoric heritage. The real enemy is out there; he is driving a bulldozer; and he has the ear of Congress.

Lynne Sebastian
New Mexico State Archaeologist
Deputy State Historic Preservation Officer

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The SAA Action Alert on possible changes in historic preservation laws (SAA Bulletin, spring 1995) was a needed, but misdirected call to arms. The possible threat is not to historic preservation law, but to historic preservation law as we know it. This is not the "all or nothing" crisis Snow et al. would have us believe.

Reevaluation and revision of the historic preservation laws was inevitable sooner or later. It also may not be such a bad thing. Many of our colleagues have become complacent in their dealings with local government, and arrogant in their dealings with the general public. Educational outreach remains limited, and its application spotty. The elitist approach frequently taken can do more harm than good.

It is important that we understand the actual issues involved. Obviously Snow et al. believe the issue is one of historical preservation. They miss the point. The issue for members of congress and the general public is not historic preservation, but agency accountability, high-handed regulatory enforcement, and civil liberties.

It is in our own interests to accept, and even embrace, the principle of change, becoming part of the process influencing and directing developments. Condemning it outright simply shuts us out of the system and denies us a place at the table.

Change can be beneficial. We can harness it to revitalize American archaeology, perhaps reinvent it (what, after all is CRM?). Rather than engaging in panic attacks, we should be asking ourselves: What is the role of archaeology in American culture and society? Have we considered the effect our actions will have on ordinary Americans? Can we establish a meaningful dialogue with our critics? The SAA session "Finding Creative Solutions for Restructuring American Archaeology" (Cameron and Anyon) is a first step in the right direction.

Change will come. Whether it is good or bad is up to us.

Peter Y. Bullock
Office of Archaeological Studies
Museum of New Mexico

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Traditionally, Paleolithic rock art has been considered a phenomenon restricted to caves and, to some extent, rock shelters. Most of the finds made since the age of this art was properly recognized in 1879 by M. de Sautuola, upon his discovery of the Altamira ceiling, are located in France and Northern Spain, where some 300 sites are now known. However, since 1981 when the engraved horse of Mazuoco (Northern Portugal) was published, evidence has been accumulating that Upper Paleolithic art also exists in the open air. With the exception of a small schist outcrop in Southern France (the site of Fornois-Haut), all the relevant finds were made in the Iberian Peninsula, the most important of which, until now, being the site of Siega Verde (Ciudad Rodrigo, Spain) where research began six years ago and resulted in the identification of some 500 figures.

In November 1994, the Portuguese press publicized that a new cluster of open air Paleolithic rock art had been discovered in the Coa river valley, some 20 km. south of the above mentioned site of Mazuoco. This news was followed by the revelation that knowledge of such art had been acquired as early as 1992 by the IPPAR, the Portuguese government agency for the protection and management of cultural heritage. However, the discovery was kept secret for more than two years. In the meanwhile, the area witnessed the beginning of preliminary work for the construction of a large dam that, if continued, will flood the river and destroy the rock art.

Since the situation was exposed by the media (American readers can find more details in the December 27, 1994, issue of The New York Times, and the January 23, 1995, issue of Time, and in volume 21, no. 3, of La Pintura, the newsletter of the American Rock Art Research Association), Portuguese archaeologists have been campaigning for the construction of the dam to be halted, since the construction is still in a very initial sage and it is still possible to abandon it altogether. The suspension of the work would make it possible to undertake a thorough evaluation of the situation, including studies for alternative locations or configurations of the dam that would allow for the preservation of the site. This demand has received the support of the mission of experts sent by UNESCO, who were in the field in February 1995. Since then, it received also the support of the Portuguese President and of many influential political personalities. Opinion polls have also shown that such was the feeling of a large majority of the Portuguese public. However, both EDP, the electricity company that is building the dam, and the Portuguese government, have so far refused to halt the work, despite their previous commitment to comply with the recommendations of the UNESCO mission.

The campaign to save the site therefore continues. It is of the utmost importance that all possible pressure be exerted on the Portuguese government, because the Coa, given the extent of the site and the quality of the art, is not just one more in the string of sites discovered since 1981. Survey conducted since November 1994 has resulted in the recognition that the cluster found in 1992 at a place called Canada do Inferno is not isolated. Many others are already known. The site covers, at present, some 17 km. of the valley, and comprises, in a conservative estimate, thousands of motifs engraved in the numerous vertical schist surfaces made available by the local geology. These include mainly figures of animals (aurochs, horse, ibex, and deer), ca. 50-60 cm. long on average, but ranging in size from ca. 15 cm. to ca. 2.5 m. One large human portrait has also been identified. The majority of these engravings, executed with several different techniques, were made, according to the unanimous opinion of all Upper Paleolithic art experts that have already visited the site, during the Solutrean period, ca. 20,000 years ago. Some, however, may date from the Magdalenian, and examples of art from late Prehistoric times (engravings and paintings from the Chalcolithic and the Iron Age) are also known.

Our view of the environment in which Upper Paleolithic humans did their art is therefore changed forever. As most present hunter-gatherers, they must have done it mostly in the open, but it was mostly in the protected environment of caves that it survived well. The dry Mediterranean microclimate of the Coa valley is probably responsible for this miracle of preservation. As a result, we now have for the first time, the possibility of studying the relationship between Upper Paleolithic art and the natural landscape that humans inhabited and exploited, since the topography of the region from which the art comes has not changed significantly since 20,000 B.P.

This is a unique scientific opportunity, and simultaneously, a unique opportunity of economic development based on cultural resources for the impoverished part of Portugal where the site is located. Teachers and students of the local high school, the local wine producers, and many other local economic agents have realized this, and have played a vital role in the campaign to save this extraordinary part of the heritage of all humankind, which was recently described by archaeologist H. de Lumley, director of the French Museum of Natural History, in Paris, as far more important than, for instance, the well-known painted caves of Lascaux and Chauvet. Readers who agree with the campaign to save Coa site should write the Portuguese authorities and manifest their feelings, as have already done innumerable archaeologists from many countries. Statements should be addressed to the Portuguese authorities at the following addresses: Presidente da Republica, Palacio de Belem, 1300 Lisboa, and Primeiro-Ministro, Rua da Imprensa a Estrela, 8, 1200 Lisboa.

Joao Zilhao
University of Lisbon

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