According to one historian Thomas (Tom ) King the US Army Corp made a some whoppers and he explains it well at this link http://nblo.gs/YhTde Probably would take a judge to make a decision on who is right but on the other hand professionals often disagree on bigger things.
Excerpt from full report below :
For full Gladesmen Study critique go to - http://nblo.gs/YhTde
(Mis)understanding TCPs
Although the authors of the report have apparently at least looked at National Register Bulletin 38, there is little evidence that they’ve tried very hard to understand it. Instead, it appears that they have cherry-picked concepts, and in some cases made them up, to support their conclusions.
In Chapter II, for example, on page 10, we are told that:
“(a)n identified historic property usually must be 50 years old to be considered a TCP.”
This implies that a place must first be “identified” as an historic property and then considered for TCP status if it is 50 years old. This of course stands the evaluation process on its head. A place is a TCP if it is regarded by people as important in sustaining their traditional cultural values; having recognized that it has this value, then one applies the National Register criteria and criteria considerations to see if it is Register-eligible. And of course, “50 years old” is a deeply simplistic gloss on the actual “Fifty-year rule” laid out in the Register’s criteria considerations.
The same paragraph characterizes the “integrity” of a TCP as referring to “a sustained, integral relationship to traditional cultural or beliefs” and a condition that is “sufficient to convey significance.” This may be a clumsy gloss on the Bulletin’s discussion of a TCP’s two kinds of integrity – integrity of association and integrity of condition – but if so it is a clumsy one indeed. The reference to a “sustained…relationship,” for example, is made up out of whole cloth, but neatly sets the authors up for their subsequent dismissal of eleven of the sites. The allusion to “convey(ing) significance” – another notion not derived from Bulletin 38 – helps the authors dismiss the significance of the sites based on their own perceptions (i.e. the perceptions of those to whom the sites do or do not convey things) – never mind those of the Gladesmen.
“Continuity” Claptrap - For full report go to - http://nblo.gs/YhTde
On the same page, we are told that:
“the most critical element in whether or not a property represents a TCP is its role in long term and continuous maintenance of a given culture” (emphasis added).
“Continuity” is a notion that has no basis whatever in Bulletin 38. The Bulletin succinctly says, on page 18, that “(t)he fact that a property may have gone unused for a lengthy period of time … does not make the property ineligible for the (National) Register.” Let alone ineligible to be a TCP. Continuity as a “critical element” – or indeed any kind of element – is something that has been made up to justify dismissing the significance of places from whose use people have been lately excluded. As many Indian tribes can testify, the fact that one has been made unable to maintain the traditional use of a place – through relocation, forcible exclusion, genocide, or other historical circumstance – by no means renders the place insignificant. Yet the authors of the Gladesmen study elevate their whole-cloth invention to the status of “most critical element” in determining whether a place is a TCP. They go on to explain:
“Because continuity in use plays such an important role in defining TCPs, changes in a property’s use or association through time can change the eligibility status of that property. If extensive changes or discontinuity in use occur through time, a site that has integrity may still be eligible for recording as a historic property…. But it would not maintain the necessary level of significance for recording as a TCP.”
This “important role” that the authors assign to “continuity in use” forms the basis for the rest of the study’s dismissive “analysis.” But it is a status assigned by the authors based on no stated authority, and it is directly inconsistent with the plain language of Bulletin 38. This “important role” that the authors assign to “continuity in use” forms the basis for the rest of the study’s dismissive “analysis.” But it is a status assigned by the authors based on no stated authority, and it is directly inconsistent with the plain language of Bulletin 38.
Inflating Misstatements - For full report go to - http://nblo.gs/YhTde
Perhaps following Hitler’s maxim that if you tell a big enough lie often enough it becomes the truth, the authors repeatedly reframe and elaborate on their misstatements. On page 103, Chapter VII, for instance, as they set about “identifying Gladesmen TCPs," they say that:
“(i)t is important to restate here that many properties associated with Gladesmen Culture may warrant recording as ‘historic properties’… but not all of these will meet the criteria for recording them (sic) as TCPs. The NRHP guidelines distinguish a TCP as a property that not only meets existing criteria as a historic property … but is also one that represents a continuing association with the (Gladesmen) culture whose primary importance is its role in maintaining cultural identity and practice.”
So now a Gladesmen TCP must not only be eligible for the Register and “represent a continuing association” (whatever that means), but must have “maintaining cultural identity and practice” as its “primary importance.” How in the world is anyone supposed to ascertain whether a place meets all these new and inventive standards? Who, for instance, is supposed to decide whether a place’s role in “maintaining cultural identify and practice” is “primary?” As opposed to secondary, tertiary, or quaternary?
Note, too, the reference to “NRHP guidelines.” What guidelines are these? Certainly not Bulletin 38. The bibliography also refers to National Register Bulletin 15; if that bulletin provides advice upon which the authors base their assumptions, it would have been helpful for them to have provided a specific citation. But no, we are simply assured that New South’s case is grounded on “NRHP guidelines.”
The mysterious “guidelines” are referred to again on page 124, where we are told that:
“NRHP guidelines distinguish a TCP as a property that not only meets existing (as opposed, one imagines, to nonexistent) criteria as a historic property … but is also one that represents a continuing association whose primary importance is its role in maintaining cultural identity and practice.”
The authors go on to warn us that:
“(p)roperties will not meet TCP criteria if the continuity of their use has significantly changed over time, if they do not retain sufficient integrity, and, most importantly, if they do not contribute to maintaining Gladesmen Culture as a whole.”
Again, as far as I can tell, New South has made up these standards on the spot, out of thin air.
Who Sez?
But let’s assume just for a moment that there really is some National Register guideline that makes all those preposterous statements. How would one operationalize it? Notably, who is to determine whether the use of a place has “significantly changed?” Or whether it retains “sufficient” integrity? “Sufficient” relative to what? And who decides whether a place contributes to maintaining Gladesmen Culture, particularly “as a whole?” - For full report go to - http://nblo.gs/YhTde
Gladesman
Excerpt from full report below :
For full Gladesmen Study critique go to - http://nblo.gs/YhTde
(Mis)understanding TCPs
Although the authors of the report have apparently at least looked at National Register Bulletin 38, there is little evidence that they’ve tried very hard to understand it. Instead, it appears that they have cherry-picked concepts, and in some cases made them up, to support their conclusions.
In Chapter II, for example, on page 10, we are told that:
“(a)n identified historic property usually must be 50 years old to be considered a TCP.”
This implies that a place must first be “identified” as an historic property and then considered for TCP status if it is 50 years old. This of course stands the evaluation process on its head. A place is a TCP if it is regarded by people as important in sustaining their traditional cultural values; having recognized that it has this value, then one applies the National Register criteria and criteria considerations to see if it is Register-eligible. And of course, “50 years old” is a deeply simplistic gloss on the actual “Fifty-year rule” laid out in the Register’s criteria considerations.
The same paragraph characterizes the “integrity” of a TCP as referring to “a sustained, integral relationship to traditional cultural or beliefs” and a condition that is “sufficient to convey significance.” This may be a clumsy gloss on the Bulletin’s discussion of a TCP’s two kinds of integrity – integrity of association and integrity of condition – but if so it is a clumsy one indeed. The reference to a “sustained…relationship,” for example, is made up out of whole cloth, but neatly sets the authors up for their subsequent dismissal of eleven of the sites. The allusion to “convey(ing) significance” – another notion not derived from Bulletin 38 – helps the authors dismiss the significance of the sites based on their own perceptions (i.e. the perceptions of those to whom the sites do or do not convey things) – never mind those of the Gladesmen.
“Continuity” Claptrap - For full report go to - http://nblo.gs/YhTde
On the same page, we are told that:
“the most critical element in whether or not a property represents a TCP is its role in long term and continuous maintenance of a given culture” (emphasis added).
“Continuity” is a notion that has no basis whatever in Bulletin 38. The Bulletin succinctly says, on page 18, that “(t)he fact that a property may have gone unused for a lengthy period of time … does not make the property ineligible for the (National) Register.” Let alone ineligible to be a TCP. Continuity as a “critical element” – or indeed any kind of element – is something that has been made up to justify dismissing the significance of places from whose use people have been lately excluded. As many Indian tribes can testify, the fact that one has been made unable to maintain the traditional use of a place – through relocation, forcible exclusion, genocide, or other historical circumstance – by no means renders the place insignificant. Yet the authors of the Gladesmen study elevate their whole-cloth invention to the status of “most critical element” in determining whether a place is a TCP. They go on to explain:
“Because continuity in use plays such an important role in defining TCPs, changes in a property’s use or association through time can change the eligibility status of that property. If extensive changes or discontinuity in use occur through time, a site that has integrity may still be eligible for recording as a historic property…. But it would not maintain the necessary level of significance for recording as a TCP.”
This “important role” that the authors assign to “continuity in use” forms the basis for the rest of the study’s dismissive “analysis.” But it is a status assigned by the authors based on no stated authority, and it is directly inconsistent with the plain language of Bulletin 38. This “important role” that the authors assign to “continuity in use” forms the basis for the rest of the study’s dismissive “analysis.” But it is a status assigned by the authors based on no stated authority, and it is directly inconsistent with the plain language of Bulletin 38.
Inflating Misstatements - For full report go to - http://nblo.gs/YhTde
Perhaps following Hitler’s maxim that if you tell a big enough lie often enough it becomes the truth, the authors repeatedly reframe and elaborate on their misstatements. On page 103, Chapter VII, for instance, as they set about “identifying Gladesmen TCPs," they say that:
“(i)t is important to restate here that many properties associated with Gladesmen Culture may warrant recording as ‘historic properties’… but not all of these will meet the criteria for recording them (sic) as TCPs. The NRHP guidelines distinguish a TCP as a property that not only meets existing criteria as a historic property … but is also one that represents a continuing association with the (Gladesmen) culture whose primary importance is its role in maintaining cultural identity and practice.”
So now a Gladesmen TCP must not only be eligible for the Register and “represent a continuing association” (whatever that means), but must have “maintaining cultural identity and practice” as its “primary importance.” How in the world is anyone supposed to ascertain whether a place meets all these new and inventive standards? Who, for instance, is supposed to decide whether a place’s role in “maintaining cultural identify and practice” is “primary?” As opposed to secondary, tertiary, or quaternary?
Note, too, the reference to “NRHP guidelines.” What guidelines are these? Certainly not Bulletin 38. The bibliography also refers to National Register Bulletin 15; if that bulletin provides advice upon which the authors base their assumptions, it would have been helpful for them to have provided a specific citation. But no, we are simply assured that New South’s case is grounded on “NRHP guidelines.”
The mysterious “guidelines” are referred to again on page 124, where we are told that:
“NRHP guidelines distinguish a TCP as a property that not only meets existing (as opposed, one imagines, to nonexistent) criteria as a historic property … but is also one that represents a continuing association whose primary importance is its role in maintaining cultural identity and practice.”
The authors go on to warn us that:
“(p)roperties will not meet TCP criteria if the continuity of their use has significantly changed over time, if they do not retain sufficient integrity, and, most importantly, if they do not contribute to maintaining Gladesmen Culture as a whole.”
Again, as far as I can tell, New South has made up these standards on the spot, out of thin air.
Who Sez?
But let’s assume just for a moment that there really is some National Register guideline that makes all those preposterous statements. How would one operationalize it? Notably, who is to determine whether the use of a place has “significantly changed?” Or whether it retains “sufficient” integrity? “Sufficient” relative to what? And who decides whether a place contributes to maintaining Gladesmen Culture, particularly “as a whole?” - For full report go to - http://nblo.gs/YhTde
Gladesman
