National Park Service

U.S. Department of the Interior

Vanishing Treasures Program

Intermountain Region

Pacific West Region

Intermountain Cultural Resource Management 

Professional Paper No. 75

Preservation and Management Guidelines 

for Vanishing Treasures Resources

PRESERVATION AND MANAGEMENT GUIDELINES 

FOR

VANISHING TREASURES RESOURCES

A ruins preservation program is essential to provide a last defense against

the loss of these tangible symbols of America’s heritage.

An effective program can preserve the integrity, information and special

meanings that these places hold for this and future generations.

(1997 Draft Ruins Preservation Guidelines)

John M. Barrow

The Vanishing Treasures Program

Intermountain Region, National Park Service

United States Department of the Interior

2009
2009, Vanishing Treasures Program, National Park Service, 

United States Department of the Interior, Santa Fe, New Mexico
FORWARD

These Guidelines are written from the broadest possible perspective, as if a park were to plan to 

initiate treatment programs for the first time and have sufficient resources available to address 

perceived problems in an idealized manner. Such a comprehensive approach would focus on major preservation projects being implemented over a multi-year time frame, all laid out in a logical 

planning process. In the real world of everyday needs and realities, where small amounts of incremental funding are requested and must be used in limited time frames, it will be impossible to 

start at page one of the Guidelines and follow along step by step, achieving all planning agendas 

prior to moving forward through the process. Also it must be recognized that sites now receiving 

focus or attention have likely already received treatments. Vanishing Treasures (VT) sites are in a 

dynamic process including changes affecting the resource and changes which have been wrought 

by our predecessors. Because actions will most likely be taken without benefit of thorough research or all assessments being accomplished which fully inform a planning and implementation 

team, a less than perfect process is inevitable.

The goal of following and using the Guidelines should be one in which slowly but surely the 

blanks are filled in over time. In a case-by-case basis, an evaluation of what is needed will direct 

the lead person to ensure that key parts of the process are in place and that whatever action is 

taken does not preclude the need to eventually get to those missing pieces. This is simply the reality of working within the confines of a federal bureaucracy and all the aspects of funding and time 

constraints associated. Ultimately the responsibility falls to the Superintendent to make decisions 

regarding actions to be taken.

A great danger lurks when the Guidelines are not followed. The obvious example is when something appears to be, or is, in fact, falling down. There may be a rush to repair the particular 

feature, to put it back as quickly as possible because of what we think the public expects to see. 

Some of the most important questions may not be asked in the hurry to get pieces back in place 

or to reconstruct sections. Responsible personnel will utilize these Guidelines and, thinking 

of the long-term best interests of the resources, will always pause and ask the most important 

questions before taking action. Those questions are within the context of these Guidelines. With 

Vanishing Treasures resources, sometimes treatments should be the last resort. In fact some sites, 

such as those well protected inside cliffs, are best left alone. The Vanishing Treasures Program 

expects resource personnel to refer to the Guidelines and use them to develop complete and 

comprehensive preservation and documentation programs. If resources are not available to accomplish all steps at a given intervention, then make plans to get that part accomplished as soon 

as possible. If we are able to leave those following us with a better record than we have received, 

then we can say we have advanced our preservation mandate. 
Vanishing Treasures Resources

Acknowledgements

Acknowledgements

A Vanishing Treasures work group met in Santa Fe in July of 2007 and launched a 

plan to prepare these Guidelines. The 2007/08 authorship/editing/review-working 

group included:

John “Jake” M. Barrow, staff, VT Program, IMSF, Managing Editor and Contributor

Brad Traver, Tonto National Monument, VT Leadership Committee Chair

Virginia Salazar-Halfmoon, Manager, VT Program, IMSF 

Randy Skeirik, staff, VT Program, Montezuma Castle National Monument

Preston Fisher, staff, VT Program, Mesa Verde National Park 

Jim Bradford, Anthropology Program Manager, IMSF

Jim Trott, archeologist, IMSF

Jill Cowley, Cultural Landscape Program, IMSF

Paul Chattey, Historic Preservation Program Manager, IMSF

Jake Barrow, with assistance from Jim Trott, prepared a first draft which was sent 

out to the working group for review and solicitation of additional comment. In 

January 2008 following that review, the revised document was sent out to the field 

(Vanishing Treasures personnel in parks) to solicit broad comment. Thanks goes to 

all those who sent comments. Jake Barrow took the lead in editing and preparing the 

final document incorporating field comments. Layout assistance was provided by 

Randy Skeirik. Thanks to Bob Hartzler for comments on the History section. Bob 

Spude provided a comprehensive review and continued editorial advice. Dick Sellars 

reviewed the history section. During the late fall of 2008, the Guidelines were sent out 

to a select group of partners for peer review. We greatly appreciate this review and 

comments from Anne Oliver, Larry Nordby, Frank G. Matero, Pamela Jerome, Doug 

Porter and R. Brooks Jeffery Finally, copy-editing was provided by Gail Snyder. Any 

references to personnel, their contact information and FTP or HTML sites is based 

on time of publication data. The document was final edited, formatted and submitted 

in March of 2009.

An early version of this document-The Draft 1997 Guidelines- were written, edited 

and prepared by Todd Metzger, Glen Henderson, Larry Nordby, Adrienne Anderson, Scott Travis, David Yubeta, Sayre Hutchinson and Terry Morgart, with editorial 

assistance provided by: Steve Mitchelson, Fauzia Francis and Greg Glassco. They 

have been expanded, clarified and revised, although the initial philosophy of preservation remains largely the same.

All photographs and figures are courtesy of the National Park Service. Thanks to Rebecca Carr, Jeremy Moss, Gary Brown, Preston Fisher, Khaleel Saba, Wendy Bustard, 

Avigail Charnov and Randy Skeirik for submitting photographs from various collections. 
Preservation and Management Guidelines

Preface ii

PREFACE

In 1997, the Draft Ruins Preservation Guidelines were initiated but never finalized and 

published. In July of 2007, a working group (listed in acknowledgments) met in Santa Fe, 

New Mexico to address this issue. The group reconvened in April of 2008. These Guidelines represent a reformatting, editing and expansion of the original 1997 document. They 

reflect ideas which emerged from the 2007 Santa Fe meeting, input from the field, peer 

review and follow-up discussions in 2008.

The 1997 draft, which was prepared by personnel from the Vanishing Treasures Initiative, 

drew heavily on earlier works that are identified in the History section of the Appendix. 

The 1997 version presented information on ruins preservation theory and practice. This 

version of the Guidelines continues the discussion on the evolution of current theory and 

practice. In the National Park Service, the preservation of cultural resources, including 

archeological sites and ruins, is guided by Directors Orders 28 and 28A, and by the Secretary of the Interior’s Standards for the Treatment of Historic Properties (Appendix K.) 

The Guidelines presented here expand on those documents because of the special nature 

of ruins preservation, archeological site management and the unique needs of the special 

places identified as Vanishing Treasures (VT) Resources.

These Guidelines should be viewed as one road map that provides a route among many to 

achieve preservation goals. Planning procedures are critical to an orderly process of longterm preservation. The Guidelines are intended to be based on process, oriented toward 

results rather than detailed prescriptive specifications. They abstract from the specific and 

presume a level of professionalism to be applied by the practitioner. The Guidelines themselves fill the body of the text, while supporting and background information is available 

in the Appendices. It is anticipated that the document will also be made available online, 

with links available to connect to in-depth background information, examples and other 

resources. In this way, specialists may be contacted and prescriptive examples of work already accomplished can be accessed to serve as models. The planning procedures are like 

steps along the way and each step is intended to have several benchmark examples from 

the field. Partners and non-NPS personnel working on VT resources will be expected to 

apply pertinent aspects of these guidelines, but the primary responsibility for ensuring that 

the Guidelines are used is within the Service.

Three VT parks (Mesa Verde National Park, Chaco Culture National Historical Park and 

Grand Canyon National Park) are recognized as World Cultural Heritage Sites and therefore pertinent excerpts from relevant International Charters and doctrinal documents are 

also included in the Appendices. These documents also provide additional philosophical 

underpinnings for treatment approaches.

As has happened with past guidelines, these will eventually be superseded as perceptions, 

knowledge and needs evolve. Hopefully, they will assist today’s managers and practitioners to ensure that the high quality of expert knowledge and workmanship necessary to 

preserve the very special category of resources identified in the Vanishing Treasures Program will continue into the future.

TABLE OF CONTENTS

SECTION I

 Vanishing Treasures Parks Map

Introduction ..........................................................................................................................1

Mission and Program Goals ................................................................................................4

Definitions of Vanishing Treasures Resources..................................................................5

Resource Prioritization ........................................................................................................7

Guideline Summary.................................................................................................... 8

SECTION II

Preservation Guidelines for Vanishing Treasures Resources

Assembling a Multi-Disciplinary Team........................................................................... 12

 Archival Research and Planning ...................................................................................... 14

 Documenting and Analyzing the Resource.................................................................... 16

 Developing Alternatives for Resource Preservation .................................................... 18

 Selecting and Reviewing the Preferred Alternative(s) for Resource Preservation.... 20

 Designing the Selected Preservation Treatment............................................................ 22

 Implementing the Selected Preservation Treatment .................................................... 24

 Post-Treatment Maintenance and Management........................................................... 26

 Preservation Emergencies ................................................................................................ 28

 Summary Check List ........................................................................................................ 30

SECTION III

Appendices: 

 Vanishing Treasures Program Charter ............................................................................ 36

 Vanishing Treasures Leadership ...................................................................................... 44

 Vanishing Treasures Funding Process............................................................................. 45

 Preservation Priorities....................................................................................................... 46

 Terminology........................................................................................................................ 49

 Management and Monitoring; Structural Evaluation Guideline................................. 51

 A Brief History of National Park Service Management of 

 Archeological Sites in the Southwest.......................................................................... 61

 Selected Readings .............................................................................................................. 97

 Information about Museum Responsibilities................................................................. 99

 Consultation Guidelines: Section 106 and Tribal Consultation ................................ 100

Policy, Standards and Guidelines for Historic Preservation 

 in The National Park Service..................................................................................... 112 

 Historic American Building Survey............................................................................... 131

Relevant Excerpts from National and International Charters,

 Declarations and Codes............................................................................................. 136

 Facility Management Software System (FMSS)........................................................... 148

 Safety Program ................................................................................................................. 150

I

INTRODUCTION
Vanishing Treasures Resources

Vanishing Treasures Parks vii Preface
Preservation and Management Guidelines

Vanishing Treasures Parks ix

Arizona

Canyon de Chelly National Monument

Casa Grande Ruins National Monument

Coronado National Monument

Fort Bowie National Monument

Grand Canyon National Park

Montezuma Castle National Monument

Navajo National Monument

Organ Pipe Cactus National Monument

Petrified Forest National Monument

Saguaro National Park

Tonto National Monument

Tumacacori National Historical Park

Tuzigoot National Monument

Walnut Canyon National Monument

Wupatki National Monument

California / Nevada

Death Valley National Park

Joshua Tree National Park

Mojave National Preserve

Manzanar National Historic Site

Colorado

Colorado National Monument

Dinosaur National Monument 

 (also Utah)

Mesa Verde National Park

New Mexico

Aztec Ruins National Monument

Bandelier National Monument

Chaco Culture National Historical Park

El Malpais National Monument

El Morro National Monument

Fort Union National Monument

Gila Cliff Dwellings National Monument 

Pecos National Historical Park

Salinas Pueblo Missions National Monument

Texas

Big Bend National Park 

Fort Davis National Historic Site

Guadalupe Mountains National Park

Lake Meredith National Recreation Area

San Antonio Missions National Historical 

 Park

Utah

Arches National Park

Capitol Reef National Park

Canyonlands National Park

Glen Canyon National Recreation Area

 (also Arizona)

Golden Spike National Historic Site

Hovenweep National Monument

 (also Colorado)

Natural Bridges National Monument

Zion National Park

Wyoming

Fort Laramie National Historic Site

Preservation and Management Guidelines

Introduction 

Introduction

The arid west of the United States contains one of the nation’s richest, best preserved and most complete 

records of human history. The concentration and diversity of National Park Service archeological resources 

in the arid west are unique. By its very nature, an archeological site is constantly changing. Generally “ruins” 

have been damaged to some extent or even destroyed by natural forces, especially weather, and by human 

impacts. Because the record of the past is finite and non-renewable, such losses diminish our chances to 

study, understand and interpret critical parts of American history and likewise impact the ability of culturally-affiliated peoples to interact with these significant places; thus the general public’s enjoyment of park 

sites is reduced.

From the late nineteenth century and continuing throughout the twentieth and into the twenty-first, the 

National Park Service and its predecessors have managed archeological sites. Over that time, several developments of note have shaped the way that we manage those sites. At the turn of the twentieth century, 

there was a great rush to discover and excavate sites, resulting in the exploitation and destruction of many 

resources. By the 1920s, the focus began to shift to site preservation and interpretation. By the end of 

the twentieth century, that shift was complete; site preservation and applied architectural conservation had 

replaced the damaging effects of excavation. Within the National Park Service, research archeology has 

become largely nondestructive, a transition that was accomplished with little, if any, consultation of culturally-affiliated peoples.

On the treatment side, it is relevant to note that the first such effort undertaken at Casa Grande in 1891 

attempted to address the same preservation challenges that we continue to face today. These challenges 

include site desecration/human impacts, surface erosion from weathering, basal erosion, wall capping, sheltering, structural stabilization and backfilling. In the early part of the twentieth century, excavation work 

and preservation treatments were typically not executed by the National Park Service but by others, such as 

the Smithsonian Institution and field schools associated with educational institutions. Unfortunately, much 

of what they did remains in the dark since records are scarce and focused on subjects unrelated to treatment 

details. That began to change with the creation of Southwest Monuments and the subsequent professionalization within the Service. In the 1930s, some who had started working in parks for these other entities were 

hired into the National Park Service as the preservation process was internalized; occurring in conjunction 

with the Depression-era New Deal Programs.

As a result of their early recognition of the fact that fragile earthen materials in exposed environments had 

special needs, the National Park Service put out a call to the scientific community for help. Beginning with 

that call, through the recommendations of the Directors Committee on Ruins Stabilization in 1940, to internally conducted research in the 1970s, the move toward the implementation of scientific methods in ruins 

stabilization has been in a state of continuing development resulting in substantial, beneficial consequences. 

In the 1960s during the Mission 66 Program and following the Historic Preservation Act of 1966, a new 

thrust of energy and attention became focused on cultural resources. A further influx of professionals began joining the NPS during Mission 66 and into the 1970s, following the passage of this act. By the 1990s, 

universities were cooperating with the NPS in research activities, the pursuit of solutions and in student 

training. Cooperative Ecosystem Studies Units (CESU), which is the mechanism/instrument through which 

most universities participate with the Service, has reinvigorated the use of scientific methods and extended 

Park Service capabilities. Modern technology has provided new tools to accomplish more and better work. 

Archeological site management has become a curriculum within the context of university preservation programs at the graduate level. 

With the passage of the Native American Graves Protection and Repatriation Act in 1990, the role and impact of consultation took on new meaning for southwest archeological sites as associated tribes and affiliated 

groups began to participate in the planning and decision-making processes. This and other important developments of the twentieth century have had a lasting impact on the way the National Park Service manages 

its archeological and ruins sites.
Vanishing Treasures Resources

 Introduction

Mandated to manage and preserve resources for future generations, the National Park Service is doing so, 

in part, through the VT Program. The idea for the VT Program started when staff at three Southwest parks 

began jointly to strategize ways to address preservation problems associated with ruins. The attrition of staff, 

the lack of funding and the need for training were central in the minds of those individuals. Those grass roots 

meetings developed into a ten-year Initiative, which in turn has now become a Program. Congress first allocated funds to the Vanishing Treasures Initiative in 1998, and since then has done so annually. The Program’s 

charter was finalized and signed in 2005 and then revisited for modification in 2008. In it, VT’s mission is 

defined as the preservation of sites while meeting the recreational, educational, and scientific needs of those 

who may benefit from visiting or studying these unique resources.

Ruins preservation entails the protection and maintenance of the features and components of an archeological site, including its cultural landscape, architecture and artifacts. These guidelines provide an outline 

of fundamental design and implementation standards for a ruins preservation program. Successful preservation will minimize the loss of important scientific information, preserve examples of past technologies 

and architecture, and enhance the interpretation and appreciation of American cultures. Site preservation 

reduces the rate of deterioration of site architecture and contents and associated cultural landscape features, 

including landforms and circulation features.

An important component of any preservation treatment program is site documentation and recording, which 

includes a wide range of activities aimed at collecting narrative and graphic data. There are two points of 

view in considering an approach for documentation: the analysis of current conditions which inform treatment, and the analysis of site findings or research which informs the anthropological record. These are not 

mutually exclusive but are usually conceived of separately since their purposes are distinct and separate. 

The methods for collecting the data have changed over time and continue to change with modern technological advances such as digital laser scanning. The Historic American Building Survey Program (HABS) is 

an early example of applied documentation strategy that has been utilized widely in National Parks. HABS 

prescribes four levels of documentation which have increasing complexity. This model is adaptable for VT 

resources. (See Appendix L.) HABS data collected from an archeological resource are both scientific and 

managerial. Data collection is a form of preservation. The anthropologist collects information that is analyzed, interpreted and preserved to contribute to the knowledge of a site and the people who inhabited it. 

The manager collects information to be used for conserving, managing, protecting and interpreting a site. 

Integrated ruins preservation documentation addresses both the scientific and managerial orientations in 

order to most effectively preserve fabric and values. Condition assessment and materials characterization 

can also yield anthropological information while the anthropological record yields information on the values inherent in a site and provides essential guidance in the selection of appropriate treatments and management strategies, so that these values can be preserved.

Documentation also addresses the potential loss of archeological information as a result of treatment actions, preserving a site’s future research potential. Therefore Vanishing Treasures’ use of the term ‘treatment’ 

is defined as not being limited to material intervention but also includes broad indirect actions, data recovery 

and documentation. Both architectural and overall site documentation must be conducted before, during 

and after the implementation of any direct action or treatment on an archeological resource. The documentation process must be planned, funded, scheduled, implemented and archived, according to appropriate 

standards. It must be recognized that documentation is a product of its time. Information gathered today is 

based on priorities, agendas and the knowledge base of the times. Future needs and capabilities can only be 

partially anticipated. The documentation accomplished today may well be insufficient for that future. 

The goal of preventing the loss of existing original material, and thus the research potential and value inherent in it, is approached through data retrieval before treatment, and through documentation of the repairs. 

In this manner, consecutively over time, assessments can be made regarding integrity and authenticity so 

that repair work and its efficiency can be evaluated in relation to the condition of the original. The decision 

to implement treatment at a site assumes that enough documentation has been collected to prioritize the site 

features to be treated. The information provided by preliminary site documentation will reveal whether the 
Preservation and Management Guidelines

Introduction 

site is threatened and requires treatment, has significance and integrity, contains interpretive and scientific 

information and is potentially eligible for, or is listed on, the National Register of Historic Places. This information will inform a recommendation by resource managers to park managers whether or not to intervene at 

a site. Then park management must incorporate park-wide priorities to systematically evaluate the request.

Once a need has been identified which could lead to a preservation treatment at a site and the background 

information has been gathered, these Guidelines can be used to plan actions that determine:

which preservation alternative should be considered, such as structural repairs, site modification, indirect off-site treatments, data recovery, etc. 

what type and level of documentation or data recovery is appropriate

what materials should or should not be used in the repair process, and how the repairs should be 

performed 

the appropriate forms and methods for documenting the treatment process

guidance for long-term management

Archeological site preservation is a specialized component of cultural resource management and historic 

preservation that incorporates perspectives of preservation, conservation and archeology. Each of these 

disciplines and other associated specializations brings a unique perspective to ruins preservation, its documentation process and the ultimate presentation of the resource. It is the integration of all perspectives that 

provides a balanced and relevant approach to documentation and preservation actions. Resource managers, archeologists and preservation specialists continue to develop a site and ruins preservation practice that 

involves minimal structural intervention and an emphasis on protection. Restoration or reconstruction is 

practiced only in a limited way that serves to preserve other features of high integrity. The practice seeks to 

preserve the scientific and heritage values inherent in the original construction materials by using compatible 

materials and techniques that characterize the original architecture and/or feature. Currently the process of 

excavating archeological sites is limited and the focus now has shifted to site preservation and the fulfillment 

of research requirements is accomplished ideally using non-destructive methods.

Archeological site preservation today emphasizes a series of activities which begin with assembling a team 

representing different disciplines to develop the preservation program. The team will direct and accomplish 

planning and research which leads to an analysis of the resources and a condition assessment. Assuming 

that a treatment program will be advanced, the team considers alternatives and ultimately evaluates them 

to arrive at a recommended approach. A scope of work or design for the treatment program will be drawn 

up and reviewed by the team. Once all is approved, especially in consultation, the treatment is undertaken. 

Long-term management of the resource will follow, which includes a monitoring component. 

These eight activities have been shaped by past preservation programs of sites we continue to work with 

today. The history of archeological site management by the NPS and its forebears (see Appendix G-History) illustrates a continuum of thought and action, both constructive and contrary. A review of the history 

informs us, and hopefully also prevents the need to repeat research efforts and to avoid errors of the past 

as well as to benefit from records of the successes. Throughout history, the Service has accomplished and 

learned a great deal which has not been recorded in a manner accessible to the public. Thus, some partners 

and sister agencies have not been able to benefit from this knowledge. The NPS has a responsibility to make 

information publicly available to benefit resources outside its immediate domain. 

Not all resources and projects are created equal. These Guidelines represent an approach to major site intervention. Small localized projects ultimately fit into larger programs, and they too must conform to the 

principles set forth, although sometimes in discreet and singular ways. Modest projects will entail scaleddown planning agendas. Off-trail and back-country sites not designated for interpretation should remain in 

a special category protected from public access to the extent practical and possible.

One continuous thread running through this process is the overriding concern and care manifested by the 

many individuals who have been charged with site stewardship over the past one hundred plus years. That 

stewardship has now been passed to us, and these Guidelines are presented as a benchmark of our times.

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Vanishing Treasures Resources

 Introduction

VANISHING TREASURES PROGRAM

MISSION:

Vanishing Treasures is a national program that vigorously pursues the preservation of 

architectural remains as a physical manifestation of the past and fosters and preserves 

the cultural connections.

PURPOSE:

• provides a proactive resource protection and preservation program which identifies and addresses specific geographic and cultural regions and ties cultural and 

traditional methods to the resource

• serves as a partner with local communities to cultivate and maintain the physical 

aspects of the culture

• provides technical assistance to communities for unique VT resources where 

technical assistance is not available

• ensures the continuity of traditional craftsmanship for future generations and 

develops and shares new preservation techniques and technologies
Preservation and Management Guidelines

Introduction 

VANISHING TREASURES PROGRAM

RESOURCE DEFINITION

Vanishing Treasures Resources are defined as a structure or grouping of structures that are in a 

ruinous state. For the purposes of Vanishing Treasures, a ruinous state is further defined by the 

following:

having exposed, intact, original material (earth, stone, wood, etc.) or incorporating 

original materials with treatments (i.e. interpreted backfills and encapsulated walls)

not being used for their original function but still representing that use

not adaptively being reused for another purpose

its occupation and utilization have been interrupted or discontinued for an extended 

period of time

are located in the arid West

is the resource, or a subset of the resources, for which the park was created;

is a National Historic Landmark or listed on (or eligible for listing on) the National 

Register of Historic Places 

Examples of Vanishing Treasures Resources:

architectural remains that have intact original material exposed at or above grade ( i.e. 

wall alignments, upright slabs, foundations, framing elements, bins, cists, constructed 

hearths)

sub-grade architecture exposed through excavation or erosion ( i.e. pit houses, dugouts, cists, foundations, etc.)

Native American architectural structures (i.e. Pueblos, cliff dwellings, cavates, hogans, 

wickiups, ramadas, corrals, earthen architecture, pre-historic trails, etc.)

Euro- and Asian-American architectural structures (i.e. missions and churches, convents, forts, ranch-farm structures/homesteads, mining structures, acequias, landscape 

features, designed gardens, kilns, etc.)

Examples of Non-Vanishing Treasures Resources:

sites with no exposed architecture or structural remains (i.e. collapsed, buried, 

mounded, or otherwise not evident)

archeological or other sites with no architectural remains (i.e. lithic scatters, dumps, 

camp sites, etc.)

Civilian Conservation Corps (CCC) and Civil Works Administration (CWA) buildings 

and features

historic structures that are regularly maintained, and/or adaptively used

structures in use as National Park Service facilities (i.e. administrative buildings, museums, trails, bridges, ditches, canals, etc.)

mineshafts or caves that do not have architectural/structural features

pictographs, petroglyphs, rock art, etc. (unless found closely related to architectural 

structures)

reconstructed structures (i.e. Aztec great kiva, Bents Old Fort)

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Preservation and Management Guidelines

Introduction 

RESOURCE PRIORITIZATION

Identifying A Prioritized List Of Vanishing Treasures Resources Requiring Treatment

Ranking treatment projects: Prior to planning or implementing any resource-specific 

preservation plans or treatments, it is critical that each Vanishing Treasures park develop 

a park-wide, prioritized list of VT resources requiring preservation treatment. Each park 

should structure its preservation program to develop a “short list” of resources requiring 

preservation treatment. Each park has unique mandates and resource requirements but 

the process should be the same (an example method and further guidance can be found 

in the Appendix D).

Research past records - acquire and evaluate existing data from inventories of all 

resources; evaluate the existing data to determine research needed to initiate planning and establish a list of resources recommended for treatment

Establish criteria - establish weighted criteria to be used in prioritizing resources 

using a multi-disciplinary approach and input from park area divisional programs 

(see Preservation Priority Matrix- Appendix D)

Document - collect information essential to identifying resources requiring 

treatment, creating “focused field studies” to provide architectural and condition 

information needed for prioritizing resources requiring treatment

Analyze - analyze resulting information in a format enabling prioritization of identified resources requiring treatment 

Prioritize - develop a priority list of resources requiring treatment

In any future surveys or resource inventories, it is useful to include architectural and 

condition documentation so that the resources can be evaluated for inclusion on the prioritized preservation treatment list. Facility Management Software System (FMSS) data 

should also be acquired when work is anticipated (Appendix N).

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II

PRESERVATION GUIDELINES
Vanishing Treasures Resources

10 Preservation Guidelines

GUIDELINE SUMMARY 

A Vanishing Treasures Resource Preservation Treatment Program

The focus of preservation treatment is on individual resources that are part of a larger cultural 

landscape. Intense analysis is required for each individual resource, including condition assessment, investigative studies, specialized analyses and archeological and architectural documentation. Preservation treatment programs require the multidisciplinary skills of specialists 

serving in a team. Inclusion of appropriate State Preservation authorities, American Indian 

tribes and local communities in the planning and review is essential. Integrating a planning 

process to initiate work and follow a deliberate course of action is required. These Guidelines 

constitute a planning process.

A preservation treatment program for a site can be applied in a process consisting of eight 

steps: 

1. Assembling a Multi-Disciplinary Team

2. Accomplishing Archival Research and Planning

3. Documenting and Analyzing the Resource 

4. Developing Alternatives for Resource Preservation

5. Reviewing and Selecting the Preferred Alternative(s) for 

 Resource Preservation 

6. Designing the Selected Preservation Treatment

7. Implementing the Selected Preservation Treatment

8. Conducting Post-Treatment Maintenance and Management

Vanishing Treasures Resources

12 Preservation Guidelines

Assembling a Multi-Disciplinary Team

The first and most important task of any preservation project is to identify all potential issues that 

may affect the understanding and treatment of a resource. One of the first steps in this process is to 

assemble a multi-disciplinary team with expertise in addressing those issues. The multi-disciplinary 

team may be fully assembled at the beginning of a project or it may begin with only a few key members. As the need for input from additional areas of expertise is identified later in the project, new 

members should be added to the team. It is assumed that the Superintendent will play a key role in 

the team and will take part intermittently as appropriate.

The specialists who might be needed in the multi-disciplinary team include: 

cultural resource managers

archaeologists

architectural conservators 

historical architects 

ruins preservation and maintenance staff

landscape architects

structural engineers

compliance specialists

geologists

soil scientists 

hydrologists

fire specialists

For a given resource preservation project, it is likely that some but not all of these specialists will 

be required on the team, depending on the type of resource and the preservation issues at hand. 

Many of these specialties are represented within the NPS and at Vanishing Treasures parks in 

particular. VT staff should be asked to participate. Some parks may not have any VT staff and 

they will rely either on resource staff or get assistance from Program staff. A list of VT positions at 

the VT parks as well as other resource staff routinely charged with preservation responsibilities is 

provided in an Appendix to the Intranet edition of the Guidelines which includes contact information for the personnel currently filling those positions. For other specialties, e.g. soil science and 

hydrology, it may be necessary to seek expertise outside of the NPS.

The primary role of the VT park employee initiating the project, or any other user of these guidelines, may be that of a project manager, providing input relating to his or her own area of expertise 

but also coordinating the work of the different team members, facilitating the exchange of information, and guiding the decision-making process. As project manager, the employee may also be 

responsible for quality control, fact checking, report writing and compilation, information dissemination, safety and so forth. 

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Preservation and Management Guidelines

Preservation Guidelines 13

Examples of Assembling Multi-Disciplinary Teams 

Recommended Not Recommended

Reach out to other disciplines in the park, 

nearby parks, parks with similar resources, 

and/or in regional offices as appropriate.

Assemble a team of colleagues who typically 

work together on similar issues and share 

similar ideas.

Assemble a planning team that includes the 

multiple disciplines required to provide a 

comprehensive approach.

Assemble just a few individuals to plan and 

do not include one or more disciplines 

needed to ensure that all aspects of the project development are explored.

The planning team ensures that all the big 

picture issues are considered such as cultural 

landscapes, maintenance, long range goals, 

resource protection, NAGPRA, other park 

priorities, interpretation, etc. 

The planning team only focuses on select 

issues related to the stabilization work and 

does not consider broader issues of park 

and resource context.
Vanishing Treasures Resources

14 Preservation Guidelines

Archival Research and Planning

Planning is an ongoing process in an organized, cohesive and applied Vanishing Treasures Program. Through planning, priorities are set and deliberate actions followed based on the detailed 

procedures indicated in the Guidelines. Planning is undertaken by a multi-disciplinary team and 

ensures that all management and legal requirements are met. Following these Guidelines constitutes engagement in a planning process. 

Archival research is one of the first actions undertaken which involves compiling and evaluating all 

available existing records pertaining to a resource. These include archeological records, preservation records (which may document reuse of building materials and previous areas of deterioration 

and repair), photographic records, management records (goals and objectives and previous decisions), previous specialized analyses and oral histories. Archival research may involve archivists 

and historical archeologists to investigate records appropriate to their disciplines. Physically 

verifying the results of records research should follow compilation of the existing information. The 

information gathered is used in the first steps of the planning process. 

Archival Research, Compilation of Existing Documentation and Preparation of Outline Resource 

History

Compile and organize all existing information relating to the resource. Components may include:

previous preservation actions and specialized analyses of materials 

lists of all material types of the resource, including original materials and those used in previous preservation treatments

previous archeological investigations, including unpublished field notes

all previous graphic and photographic documentation

oral histories by individuals with previous involvement at the resource 

construction histories of the architecture, including interventions 

management plans, directives, use and changes in use 

input from park staff, resource, interpretive and other 

input from State Historic Preservation Offices, culturally affiliated tribes and local communities on resource-specific concerns

examples of other planning processes which can be used for guidance

The products of this activity are:

a provenience or structure identification system that correlates all previously used systems 

for subsequent use, including incorporation into the FMSS system.

compiled existing archival and materials collection and curated materials

record of all previous work as baseline for subsequent studies and treatment

annotated inventory of data

annotated bibliography

record of input from the multi-disciplinary team

record of consultation communications

Develop, evaluate and outline resource history. Components may include:

preparing a current site description

preparing a current condition description

evaluating construction materials in collections and characterize the differences/similarities 

to on-site counterparts

recording changes in structure or room designations or numbering systems through time

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Preservation and Management Guidelines

Preservation Guidelines 15

appropriately tracing the archeological and stabilization histories of a structure

preparing a chronological listing of resource interventions including archeological and stabilization activities

documenting changes to original construction

verifying the results and findings taken from the records research by conducting review and 

resource survey on site

correlating previous interventions with a current condition description

The products of this activity are:

an outline of the resource history

a written description of the resource in its present condition today 

a summary of additions and alterations made to it through time, including exposition of previous 

preservation treatments applied to the resource and their effectiveness through time

identification of areas needing further research and evaluation

Examples of Archival Research and Planning Activities

Recommended Not Recommended

Search park files and pull together all documents, including historic photographs, that 

relate to a resource. Research external park 

resources such as regional and other archives 

for records.

Not fully accessing park files which may have 

varying systems of organization and control 

as personnel changes over time and filing 

systems often change.

Have specialists with expertise in relevant 

areas evaluate past treatments.

Past treatments are not fully evaluated or specialists are not involved in the evaluations and 

unqualified assumptions are made.

Conduct oral histories when records are not 

complete regarding recent resource treatments. (Employees both retired and those 

still employed can recall what took place on a 

site.)

Personnel such as recently retired individuals 

who may know details about what happened 

on a site are not contacted for oral histories.

Prepare a comprehensive written report to lay 

the foundation for future planning and decision making, and also to serve as the primary 

source and common knowledge base for the 

members of the multi-disciplinary team.

Do not prepare a comprehensive report 

but rely on memory, diverse files, handwritten notes, verbal communication, etc. to 

document the process and share information 

about it.

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Vanishing Treasures Resources

16 Preservation Guidelines

Documenting and Analyzing the Resource 

 

Documentation for Condition Assessment; and Research and Analysis of a Vanishing Treasures Resource

Documenting the resource may include, as deemed appropriate per priorities and dependent on its purpose: site maps, plans, elevations, photographic and other graphic imagery, material analysis, condition 

assessments, detailed architectural and archeological descriptions with structure specific preservation 

requirements and correlation of previous documentation with the current description. 

The purpose of the documentation must be clearly understood and established at the outset. Based on this 

purpose and the value of the resource, the relative complexity of the project and the logistical issues specific to the documentation strategies under consideration, an appropriate level of documentation shall be 

applied. The level of complexity shall be determined by the team. The focus of whether the documentation 

is solely directed toward anthropological research, condition assessment, or a combination of both will be 

decided by the team. Historic American Building Survey (HABS) levels I-IV exemplify the potential for the 

range of complexity (See Appendix L.) 

When extensive intervention, such as backfilling, is anticipated, the highest level of documentation is required. In the case where documentation is being planned as a research tool only, special requirements are 

designed into the program by the research archeologist on the planning team. These requirements respond 

to the purpose prescribed and focus specifically on that objective. In this case, research documentation 

may be supplemental to condition assessment documentation or, in some cases, it may stand alone. 

A condition assessment involves examining an architectural structure or feature, analyzing existing conditions, identifying preservation problems and the causes of those problems, evaluating conditions using a 

multi-disciplinary team approach and a range of technical specialists’ results in identifying conservation 

requirements and determining causes and effects of deterioration, as well as the effectiveness of previous 

preservation actions. Aspects of research documentation often are used in assessments since understanding rate of change from baseline condition as described by visual data becomes key to fabric treatment 

programs. Likewise, information gleaned from fabric investigation can well inform the anthropology, such 

as in the case of an assessment of decorated surfaces which might reveal a multiplicity of layers beneath the 

visible one.

Components of resource documentation, condition assessment and analysis are:

documentation of architectural features which have anthropological implications singularly or in 

context of others within the resource or to related resources (may be less detailed for condition 

documentation only)

identification of original, authentic material versus previous stabilization and repair material 

technical analysis and characterization of materials: stone, mortar, plaster, pigments, wood (including dendrochronology), earthen materials (adobe, mortar, plaster, etc.)

identification of significant pristine features, components and attributes of a resource to be preserved intact and without significant alterations

evaluation of deteriorating areas and determination of causes of deterioration (include in-puts from 

technical/research specialists as appropriate)

correlation of existing conditions with previous descriptions and actions using technical specialists 

and material testing methods as needed 

evaluating the effectiveness of previous actions and techniques by consulting with technical specialists 

evaluating previous management actions with regard to direct or indirect impacts 

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Preservation and Management Guidelines

Preservation Guidelines 17

The products of resource documentation, condition assessment and analysis are a written report and/or 

portfolio containing:

an analysis of findings which informs the study of the anthropology of a site (used only minimally in 

condition assessment documentation)

an assessment of potential threats and future impacts

a summary of current resource conditions and their probable causes, supplemented with base maps, 

photographs and other illustrations of current conditions (to establish a baseline) 

a summary of preservation issues and specialized requirements 

an evaluation of park management plan directives and their relation to resource preservation issues

a comparative collection of construction materials and curation of materials (if appropriate) 

preparation of Facility Management Software System (FMSS) planning documents based on recorded data for future maintenance needs

Examples of the Resource Documentation, Condition Assessment and Analysis Activities

Recommended Not Recommended

Performing needed documentation using the 

most appropriate tools and skills available to 

achieve a comprehensive product in direct 

relation to defined objectives and resource 

values.

Proceeding to document a resource without 

due consideration of purpose, values and 

resources available, resulting in information 

of little or no use.

Design the documentation to focus on the 

specific resource, taking into consideration 

the level of complexity appropriate as determined by team.

Design documentation with no defined objective in mind using formats adopted from 

other projects and not considered by team.

Documentation for the purposes of condition 

assessment will evaluate the entire history of 

the structure, including all treatments applied 

and establishing a baseline for future use.

Documentation which focuses on select 

aspects of a structure without considering 

others which are also of importance and is 

not recorded to establish a baseline for future 

referral.

Conditions of materials within a structure are 

fully evaluated, including comparative analysis, field evaluations and lab testing.

Material analysis is limited to field assessments and assumptions made by visual observation and not proven by scientific inquiry.

Documentation of a resource using FMSS 

input definitions in order that features can be 

put into the FMSS and the information gathered can serve to provide FMSS with accurate 

data.

Following previous designations for features 

which do not correlate with FMSS definitions; therefore documentation does not 

contribute to FMSS.

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Vanishing Treasures Resources

18 Preservation Guidelines

Developing Alternatives for Resource Preservation

This and the previous sections of these Guidelines essentially constitute the main elements of an Historic 

Structures Report (see Appendix Model HSR Table of Contents as defined in Directors Orders 28). By 

completing the defined work elements in these sections, one may assemble the results into one umbrella 

document as an HSR. This becomes very helpful in planning future work by formally establishing criteria. 

This step involves the investigation and evaluation of alternatives for preservation treatment of architectural fabric, both for the short and long term. Consideration of alternatives is important to ensure that a deliberative process has been followed. Deliberations can illuminate the thought process of the team, thereby 

dispelling future conflicts or second-guessing. 

Components of the investigation, evaluation and consideration of alternatives are:

identifying use, especially visitor use/impact , which includes visitor traffic through or on resources

identifying the preservation options, ranging from no treatment to extensive intervention, in concert 

with the multi-disciplinary team

reviewing resource conditions and probable cause-and-effect relationships

evaluating the efficiency, impact, reversibility, re-treatability and long-term maintenance implications 

of each proposed option 

incorporating long-term management goals, including consideration of the feasibility and reality of 

the proposal and its long-term viability 

soliciting input from partners, culturally affiliated tribes, concerned local communities and other 

stakeholders

evaluating the potential effects of proposed preservation actions on associated resource features and 

the adjoining landscape

correlating existing approved interpretive themes with desired outcome

The products of alternatives development in a written report include:

a written presentation of the range of options and alternatives ranging from no treatment to extensive intervention

an evaluation of the projected impacts, both positive and negative, on the resource, adjacent resources, associated landscape features, interpretive values, etc. 

a record of resource-specific and related concerns provided by stakeholder

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Preservation and Management Guidelines

Preservation Guidelines 19

Examples of the Process to Develop Alternatives 

Recommended Not Recommended

The multidisciplinary team develops or considers the full range of alternatives which may 

have been put together by project leads.

A few park personnel consider alternatives which have been provided by a limited 

team, possibly one employee who is driving 

the project.

Team members rigorously consider issues 

of resource integrity, condition, treatment 

history, maintenance requirements and other 

factors and their interrelation with each treatment alternative to render a comprehensive 

viewpoint.

Only the alternatives which appeal to some 

members of the deciding group are considered and recorded.

Make early contact with SHPO and tribal 

entities to foster cooperation and learn about 

their potential concerns, which could affect 

treatment plans.

Wait until design documents are complete 

before contacting SHPO and tribal entities
Vanishing Treasures Resources

20 Preservation Guidelines

Selecting and Reviewing the Preferred Alternative(s) for Resource Preservation

The activities associated with this decision-making stage are the review and selection of one or 

more preferred alternatives. This is done through a review process conducted by the multi-disciplinary team, including park management and staff. The evaluations will result in a recommended 

decision. The initial multi-disciplinary planning team usually will undertake this activity. Consultation will be conducted with the State Historic Preservation Office and should continue with 

common interest groups, such as culturally affiliated tribal governments and local communities 

who have an interest in the outcome. These groups collaborate on evaluating the recommendation 

package. 

For the purposes of Section 106 compliance with the Historic Preservation Act of 1966, a proposal 

of “no action” is not relevant to Vanishing Treasures resources since documentation is considered a treatment or “action.” However, documentation may be the only treatment selected as the 

preferred alternative. In the course of time, after archeological research and architectural documentation has been performed, a determination of “benign neglect” may be applicable, even to 

resources that possess research or interpretive values. “Benign neglect” is applied only if a specific 

management decision is made not to pursue further preservation actions. This determination may 

be made only after suitable archeological investigation has been performed which provides the 

pertinent scientific data to inform the decision. 

Components of the decision-making activity are:

reviewing alternatives in relation to park resources management goals, objectives and management plans 

selecting one or more preferred alternatives for resource preservation from among the suite 

of options developed in the “Alternatives” exercise

considering and evaluating the relationship between the selected preservation action and the 

following as pertinent or appropriate:

Preservation and Management Guidelines for Vanishing Treasures Resources

Pertinent sections within DO-28 and 28A 

The Secretary of the Interior’s Standards for the Treatment of Historic Properties

The Native American Graves Protection and Repatriation Act (NAGPRA)

Curatorial archives and records management issues

The National Historic Preservation Act (NHPA 106/110 Compliance) 

The National Environmental Policy Act (NEPA)

The Secretary of Interior’s Cultural Landscape Treatment Guidelines

Other specific laws, policy and directives

consulting with the SHPO, affiliated tribes and other stakeholders by presenting the preferred alternative(s) and evaluating the responses received

Products of this activity are:

a written summary of input from concerned parties or representatives of affiliated groups, 

with copies of correspondence appended

a written summary of the preferred alternative(s) and its level of compliance with applicable 

policies, guidelines and standards

identification of the selected preservation treatment alternative with supporting comments

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Preservation and Management Guidelines

Preservation Guidelines 21

Examples of the Process to Select from Alternatives, Making Decisions

Recommended Not Recommended

A multidisciplinary team working with management and consulting parties renders a 

decision selecting an alternative with its reasoning included.

A manager or other park personnel makes a 

unilateral decision about what they think is 

best for a resource without consideration of 

other input and without providing the reasoning for the selection.

Alternatives are measured against DO 28, 

NAGPRA and the Secretary of the Interior’s 

Standards, as well as pertinent parts of VT 

Guidelines, to ensure compliance with the 

intent as well as specific requirements where 

appropriate.

Alternatives are considered without evaluating how they fit into the intent and definitions 

provided by Policies, Guidelines and Standards.

Related tribal entities are contacted to ensure 

that input is received concerning alternatives. 

If necessary, an appointment is made and the 

tribal offices are visited to adequately transmit 

important information and receive feedback.

A letter is sent to the tribal entity informing them of the selected alternatives and, if 

a response is not received, the assumption is 

made that they are not interested or have no 

comment.
Vanishing Treasures Resources

22 Preservation Guidelines

Designing the Selected Preservation Treatment

This step will involve the development and design of the selected preservation treatment and the review of 

that design by the multi-disciplinary team; additional technical specialists may also be necessary. Following 

design review, a scope of work including specific design, implementation methods and material details is 

prepared. This may be done by one individual who has access to the team and all background documents 

and reports necessary to prepare the scope. The ultimate result of this step will be a comprehensive construction document package for the project. Should the intent be to contract the work to external private 

entities, special provisions are required as prescribed by Federal Acquisition Regulations (FAR). Early 

consultation with contracting personnel is recommended. 

Architectural documentation will have been accomplished prior to this stage which has provided the information needed to design the treatment. In the case where research documentation will be designed for a 

preservation treatment program, not all components and products below are relevant. The Facility Management Software System (FMSS) must be used and correlated throughout this process (see Appendix N).

Components of project design include:

designing specific preservation action(s), including additional documentation and specialized analyses 

involving technical specialists as appropriate. In documentation-only projects, the design will clarify the 

research objective by laying out research questions to be answered. 

selecting techniques and materials that are compatible with and characterize the original construction 

methods and existing structural material

identifying methods by which the proposed treatment will be identifiable from the original, authentic 

materials

creating a “construction document” or “research document” package based upon design and specialized analyses, as appropriate for a specific project including a design and scope-of-work 

estimating costs to accomplish all aspects of project work

considering and specifying policy and directive requirements, such as NAGPRA, DO 28, Secretary of 

the Interior’s Standards and VT Guidelines

considering and designing techniques for monitoring treatments over time, such as the installation of 

monitors or sensors

considering curatorial issues for the handling of artifactual materials 

producing illustrations, photographs and plans that visually describe the proposed work 

completing compliance with Section 106 of the National Historic Preservation Act and with the National Environmental Policy Act, if appropriate

incorporating an Inadvertent Discoveries Plan

incorporating a Safety Plan

evaluating the type, level and frequency of reporting to adequately document the project and associated changes to the resource

The products of this project design are:

construction document package including: design drawings and specifications; architectural documentation 

scope of work which covers details such as mortar, plaster, pigment specifications, wood species, 

stone type 

research documentation package which includes a written narrative explaining the anthropological 

agenda as defined by the team

an explanation of the type, level and frequency of reporting throughout the project and also the 

required contents of the final project report

all necessary design specifications and documents, including incorporation of technical specialists 

inputs, reports and findings

consultation and consideration of concerns of culturally-affiliated tribes

inclusion of curatorial issues in project design documents

documentation of “no action” decision, if appropriate

thorough detailed cost estimates for funding and staffing requirements

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Preservation and Management Guidelines

Preservation Guidelines 23

completed compliance with the National Historic Preservation Act, the National Environmental 

Policy Act and the Native American Graves Repatriation and Protection Act 

safety program built into the design package

an Inadvertent Discovery Plan (if the park does not already have one)

In a case in which documentation is the selected preservation treatment, special provisions and guidelines 

are required to accomplish that task. These are not defined as specifically herein as those for material treatment-oriented projects since research agendas are abstract by definition. In this case the archeological record of the resource and the archeologist of record will be required to provide a research design appropriate for the task. The documentation activity will be designed with a specific research objective established 

by the team under the guidance of the archeologist of record. The goal of such documentation is to further 

the knowledge base of the resource and increase understanding of the anthropological context of a site. 

Examples of Preservation Design

Recommended Not Recommended

When there are structural issues present, consult with an engineer to inform final design 

(see Appendix F: Structural Engineers Evaluation Guideline).

Rely on local knowledge to deal with structural issues.

In cases where documentation is the selected 

treatment, the archeologist of record or the 

archeologist who is an expert on the resource 

and its subject culture prepares the research 

design in consultation with the team clarifying the research objectives.

Rely on someone other than the most knowledgeable archeologist to prepare a research 

design or assume that a standardized documentation system used at another resource or 

park can be adapted for this project with no 

clearly stated research objective.

Specify material types and use descriptive 

terms to identify materials for repair.

Use generic descriptions for materials such as 

“wood,” “stone” or “soil” rather than specifically identifying types, colors, species, mixes, 

etc. 

Design a safety program for the project following the VT Guidelines (see Appendix O: 

Safety Program).

Rely on the contractor or implementation 

team to supply a safety program.

Develop a material-specific identification 

system so that the new work can be distinguished from the original, authentic materials 

at a close range.

Rely only on documentation to identify the 

differences between the new work and the 

original, authentic material.

Design and review the selected treatment 

with the involvement of all appropriate members of the multi-disciplinary team, using past 

designs from other parks as templates for a 

general approach but tailoring the specifics to 

the resource at hand.

Design and review the selected treatment 

using only local knowledge and/or relying 

on the general design and specific approach 

used for preservation treatments of other 

resources.

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Vanishing Treasures Resources

24 Preservation Guidelines

Implementing the Selected Preservation Treatment

Prior to implementing preservation treatments or actions, all of the previous Guidelines tasks should have been 

addressed. The primary components of implementation are establishing records management and applying the 

treatment as designed. Should the project be a ‘documentation-only’ project, research design provided by the 

archeologist of record will inform and possibly take precedence over the components and products listed here. 

‘Documentation-only’ projects may not require the same analysis applied to treatment histories that material 

intervention-oriented projects require. The purpose of the documentation may be two-fold, both establishing a 

baseline of condition as well as exploring the archeological context. In this case, the multi-disciplinary team may 

increase capacity by coordinating the two activities in order to make the best possible use of resources. 

Components of Project Record Management are:

organizing all existing archeological, stabilization and other relevant preservation data into retrievable 

formats 

collecting additional data concerning the structure and its condition to fill information gaps, as necessary, 

including: mapping, photography, materials sampling, wood inventory, encoding selected data in compatible formats, and up-dating the record of the structure’s condition which was established at the outset of 

treatment

standardizing the terminology including that which defines provenience characteristics of the structure, 

ensuring that FMSS is taken into consideration

creating records that can be archived for guaranteed future availability

reporting which summarizes project development, implementation and results

establishing a change order or change in design process based on findings in the field during construction

Components of Implementing the Preservation Treatment are:

implementing the preservation action, involving appropriate technical specialists 

executing repairs using precise material selection, preparation and treatment techniques (these should be 

specified in the scope of work)

implementing the selected method of visual identification of treatment to distinguish repair from original

overseeing contractor(s) and/or NPS staff to ensure the stipulations of the construction documents are 

met

minimizing ground disturbing activities to reduce the likelihood of disturbing buried cultural materials

monitoring any necessary excavation or any ground-disturbing activities for archeological purposes

documenting all actions and activities that are undertaken using written notes, reports and photographs as 

appropriate

recording changes to the structure resulting from the treatment using photography, line drawings and 

written descriptions of the action in progress

documenting the work/man power and quantities of materials used during each step of the work

preparing and/or compiling final reports in appropriate formats, including project documentation and 

discipline-specific professional reports

incorporating updated information into appropriate national, regional and/or park data bases and appropriate preservation and architectural research databases, including FMSS

disseminating results to park and resource managers and integrating results into various park programs 

such as maintenance and interpretation

analyzing monitoring and maintenance protocols

The products of this activity include:

comprehensively compiled and curated records of all findings and materials recovered from the structure

adequately curated materials, artifacts and records

reports such as Resource Preservation Plans, Completion Report and/or Structure Preservation Guides or 

other appropriate preservation reports, including professional monographs that meet the needs of associated professions and management (various disciplines involved will produce specific reports)

recommendations for long-term management including resource monitoring and maintenance information packet , preservation plan or maintenance guide 

new interpretive and educational information to update visitor information programs

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Preservation Guidelines 25

Examples of Treatment Implementation 

Recommended Not Recommended

Secure masonry materials off-site that closely 

resemble the historic material and/or are of a 

similar character with the existing materials to 

maintain a compatible appearance of repair 

to original. Make repairs identifiable under 

close scrutiny or at a close range.

Reuse historic/pre-historic material, e.g. reconstituting mortars back into wall sections, 

attempting to replicate exactly what is original 

work, or making an overt effort to distinguish 

the repair work so that it is clearly noticeable 

from a distance.

Repair deteriorated wood sections or parts 

by splicing in new wood to replace only the 

deteriorated parts.

Replace entire pieces of wood that are in 

generally good condition except for localized 

areas of deterioration.

When resources are affected in projects such 

as backfilling, retrieval of architectural data 

will be accomplished.

Burying, altering or concealing a resource 

without adequate retrieval of architectural 

information.

Stop work when historic/prehistoric material and archeological discoveries may be in 

danger of being lost or destroyed.

Continue to work on resources that will potentially cause the loss of authentic material 

of high integrity or cause the loss of archeological evidence.

Maintain the character of features, architectural details, wall configurations, style and 

massing.

Change features or architectural details due to 

construction practices or other influences on 

job sites; simplify wall configurations to make 

maintenance easier in the future.

Document work in a manner that is universally retrievable.Document work in a manner that is proprietary and only retrievable by one person or 

only by specialized means.

Prepare a completion report and preservation 

management plan describing work accomplished, monitoring procedures and routine 

maintenance procedures.

Consider the work completed without leaving a record for future use that defines what 

was done or actions required to maintain the 

work accomplished.
Vanishing Treasures Resources

26 Preservation Guidelines

Post-Treatment Maintenance and Management

Once a project has been completed in the field, evaluations, maintenance and monitoring will be required. 

Immediately subsequent to the preservation intervention, management will begin to implement strategies 

to maintain the treated resource with new directives and also implement monitoring programs to determine if and when changes occur, which will dictate a need for future action. At suitable intervals after the 

work has been completed, evaluations of the effectiveness of the intervention should be made as part of the 

monitoring process. Post project activities consist of actions taken on a routine basis to monitor, protect 

and preserve the resource.

Components of this activity involve implementing a preservation plan for the resource which will include:

applying routine preservation maintenance work, monitoring and inspection of the structures and 

treatments

accomplishing general housekeeping maintenance

evaluating the effectiveness of treatments

inputting FMSS data

making decisions to facilitate long-range preservation, such as changing visitation patterns, closing resources to visitation or reducing access and increasing Archeological Resource Protection Act 

patrols

updating the park priority list of resources requiring preservation treatment based on new conditions

providing a description of the preservation process and the knowledge gained from the treatment 

process to the park interpretive program 

ensuring that all documents are accessible and retrievable as well as curated at WAAC and other pertinent facilities per archival guidelines (see Appendix I: Summary of Museum Responsibilities)

The products of this activity are:

implementation of the resource preservation plan developed in Guideline 7, including routine maintenance and monitoring (e.g. periodic photography, crack monitors and/or erosion monitors with 

monitoring schedules), and long-term data collection and analysis 

a written summary of the effectiveness of the treatment, updated as needed

updated priority list for other park resources with preservation requirements 

maintenance of resources in good condition/FMSS and ASMIS reporting

recommendations for new interpretive themes as might be appropriate based on discoveries or treatment programs 

publications (e.g. leaflet, brochure, article, monograph) for both internal and external audiences, if 

appropriate

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Preservation and Management Guidelines

Preservation Guidelines 27

Examples of Post-Project Maintenance and Management 

Recommended Not Recommended

Implement a preservation plan that includes routine maintenance and a monitoring component.Wait for future funding to implement a 

resource preservation plan.

Inform interpretation of work accomplished and findings in order for new 

information to be available to the public.

Perhaps because of timing or differing 

priorities (such as the concern that signs 

may have to be changed or brochures rewritten, or a seeming lack of interest), it is 

decided not to inform interpretation staff 

of work accomplished and knowledge 

gained.

Archive final documents digitally and as 

hard copies. Share with all participants as 

well as repositories such as WACC, TIC 

and library collections (see Appendix ISummary of Museum Responsibilities).

Project leader keeps final documents in 

personal space without disseminating.

Use monitoring to evaluate the effectiveness of treatments, including partial 

successes and failures by following procedures outlined in the resource preservation plan. Report on these so that others 

can benefit.

Monitor by visiting the resource and 

recalling features or treatments. Make assumptions from memory without documentation.

Re-evaluate park priorities after completing the project using knowledge gained 

from project and by reviewing completed 

work inventory updates.

Consider project complete and finished 

without relating it to other park resources 

and priorities in context.
Vanishing Treasures Resources

28 Preservation Guidelines

Preservation Emergencies

Chapter IX of the Programmatic Agreement with the Advisory Council for Historic Preservation 

addresses “Emergency Actions” and these guidelines must be followed.

An emergency is defined as a situation in which material failure or collapse is occurring or about to 

occur. In consultation with management and with professional input from knowledgeable personnel and/or VT engineering consultation, a decision may be made to take immediate action to forestall collapse. This action may be required for health and human safety, especially in the case where 

the public has access to walls and structures. Safety is of the highest importance and resources may 

be closed due to hazards. 

There are three levels of emergency. The first and highest is life and human safety. The second level 

is less critical but no less important, which is the imminent loss of historic original material but 

without human health and safety implications. The third level, which requires more management 

input to determine the need for action, is the imminent loss of non-historic repair material. Normally, this loss is not considered to be an emergency with regard to VT resources.

If a situation is deemed an emergency necessitating immediate action by the Superintendent, time 

can be very critical, making the following of normal Section 106 and consulting procedures impossible. Notification to the SHPO and other consulting parties is always advisable and, in the case 

of emergencies, it may be necessary to provide notification as soon as possible (within 24 hours) 

with appropriate follow-up. Actions taken to remedy the situation must be reversible and safely 

executed. They should not negatively impact the integrity of the structure. These actions usually 

take the form of trail closure, wall braces, temporary frames, sand bagging and temporary covers. 

Employees are not directed to take actions that put them in any danger but should contact trained 

professionals to implement emergency procedures if needed and if employee safety is a concern. 

Once the remedy has been taken and the wall or structure is reasonably secure, planning may be 

undertaken to get the project back into the normal procedures as outlined by these Guidelines. 

Depending on the particular situation and anticipated timing of more permanent action, Section 

106 and other consultation such as with tribal parties should be normalized as quickly as possible. 

In the case of inadvertent discovery of human burials, the park should follow its Inadvertent 

Discovery Plan. If the Plan is not in place, then immediate tribal consultation is required prior to 

applying any treatment that could affect the burial in any way. 
Preservation and Management Guidelines

Preservation Guidelines 29
Vanishing Treasures Resources

30 Preservation Guidelines

SUMMARY CHECK LIST

Preliminary planning

The following basic questions and series of actions summarize the Guidelines and can be 

used as a checklist:

□ Is the structure a VT resource? If yes, proceed.

□ Is it included in the List of Classified Structures (LCS)? 

If yes, is the LCS file up-to-date?

If not, take action to bring the file up-to-date. Contact the Regional LCS Coordinator.

□ Has the structure been listed on or determined to be eligible for listing on the National Register?

If not, consider a nomination.

If yes, is the Nomination complete and adequate?

If not, consider planning for a re-write.

Are conditions/changes such that the resource might be considered for de-listing 

as a VT resource?

□ Is the site located in a wilderness area?

If yes, special requirements restricting mechanized equipment and access will be 

in force.

□ Is a multi-disciplinary team assembled and ready to participate in planning?

□ Have both park-wide and site-specific priorities been set?

If not, develop a plan to prioritize the site of concern within the park context 

(see Matrix in Appendix D).

□ Is it an emergency? (If so, or for further clarification, see special procedures on 

page 28).

□ Is an Inadvertent Discovery Plan in place?

If not, take action to develop the Plan.
Preservation and Management Guidelines

Preservation Guidelines 31

SUMMARY CHECK LIST

Once the planning starts on a VT project, the following questions and actions are addressed:

Is the appropriate level of research, documentation, recording and consultation 

complete? What has been done and what more is needed? (Start a file with copies 

and notes defining the status of these subjects, including recommendations for what 

is needed.)

□ Site history, HABS/HAER recording, other forms of recording

□ Previous archeological investigations

□ Construction/treatment history

□ Current condition and condition history

□ Analysis of condition including causes and rate of change

□ Current and future threats identified

□ Management History: General Management Plan, Resource Management Plan, 

Historic Strutures Report

□ Oral histories

□ Interpretive Planning

□ Preliminary 106 and Tribal Consultation (NAGPRA)

A few fundamentals are:

□ Has use of the resource or its relationship to adjacent resources changed? 

□ Have park management intentions changed? 

□ Have planning documents been updated? 

After satisfactorily addressing the above subjects, determine desired condition and 

options for treatment by following these guidelines requiring the team to:

□ develop alternatives

□ render a decision and develop a scope of work

□ execute treatment

□ post-project planning

After the treatment has been implemented, responsibility for managing, monitoring 

and maintaining the site must be established with guidelines provided by the project 

team. Specific instructions include monitoring methods, maintenance requirements, 

material specifications and other site-relevant information necessary to preserve the 

site. A completion report will include this information. 
Vanishing Treasures Resources

32 Preservation Guidelines
Preservation and Management Guidelines

Preservation Guidelines 33

III

APPENDICES

TABLE OF CONTENTS FOR APPENDICES

Appendix A: Vanishing Treasures Program Charter .............................................................36

Appendix B: Vanishing Treasures Leadership 2005-2008....................................................44

Appendix C: Vanishing Treasures Funding Process..............................................................45

Appendix D: Preservation Priority Matrix .............................................................................46

Appendix E: Terminology ........................................................................................................49

Appendix F: Management and Monitoring; Structural Evaluation Guideline .................51

Appendix G: A Brief History of National Park Service Management of Archeological

 Sites in the Southwest.........................................................................................60

Appendix H: Selected Readings ...............................................................................................97

Appendix I: Summary of Museum Responsibilities ........................................................... 99

Appendix J: Consultation Guidelines: ..................................................................................100

 Section 106 ..........................................................................................................100

 Tribal Consultation.............................................................................................107

Appendix K: Policy, Standards and Guidelines for Historic Preservation in 

the National Park Service ..................................................................................112

 Secretary of Interior Standards.........................................................................114

 DO-28 ..................................................................................................................120

 Model HSR Table of Contents..........................................................................130

Appendix L HABS Documentation Standards ....................................................................131

Appendix M: Commentary and Excerpts from Other Relevant National and 

International Charters, Declarations and Codes ...........................................136

Appendix N: Facility Management Software System (FMSS)..............................................148

Appendix O: Safety Program....................................................................................................150
August 14, 2008

August 19, 2008

APPENDIX A

PROGRAM MANAGEMENT

IN THE

VANISHING TREASURES PROGRAM

CHARTER

Approved by:

_______________________________________ _________________

Mike Snyder Date

Director

Intermountain Region

 

_______________________________________ ___________________

Jonathan Jarvis Date

Director

Pacific West Region
Preservation and Management Guidelines

Vanishing Treasures Program Charter 37

VANISHING TREASURES PROGRAM

Mission:

Vanishing Treasures is a national program that vigorously pursues the preservation of architectural sites 

(often termed “ruins,” archeological and historic) in the arid lands of the West. 

Program Goals:

The goals of the Vanishing Treasures Program are for each VT Park to achieve a proactive and forwardthinking preservation program. Park management can achieve these goals by designating park staff, program support staff, coordinating with other park’s staff and requesting VT staff and/or partners to accomplish:

• Long-term plans and strategies to preserve resources

• Comprehensive resource inventory

• Determination of emergency/priority preservation treatment or documentation needs

• Completion of resources documentation 

• Projects which maintain and preserve resources

• Monitoring resources on a cyclic basis

• Communication of preservation efforts among parks and partners to share accomplishments and 

new techniques and technologies

Background:

The VT sites represent a record of human experience remarkable in depth of time, geographic extent and 

cultural diversity. These sites contain the remains of buildings or other architecture that is at least partially 

exposed above the ground surface. Such resources may derive from building traditions that incorporated a variety of materials, technologies, designs and symbolic expressions that represent a continuum 

of architectural experimentation in a unique and arid environment. The Vanishing Treasures Program 

is composed of 45 national parks and monuments within the Intermountain and Pacific West Regions 

of the National Park Service. States that contain VT parks include Arizona, Utah, Wyoming, Colorado, 

New Mexico, Texas and the southern areas of California and Nevada. Vanishing Treasures parks contain 

cultural and historic sites with above-ground architecture whose occupation and utilization has been interrupted or discontinued for an extended period of time. Initial counts of the number of known exposed 

resources approximate 12,700 with several times that many structures potentially existing that have not yet 

been recorded.

Vision Statement:

As the Vanishing Treasures effort transitioned from an initiative to a program in 2008, its mission is to be a 

proactive resource protection and preservation program which focuses on preserving Vanishing Treasures 

resources and ensuring the continuity of preservation skills for future generations. The VT Program will 

help lead the Vanishing Treasures parks in identifying needs and developing strategies to implement and 

sustain effective proactive preservation measures. Collaborative efforts in preservation will be encouraged at all levels. Opportunities for sharing resources, staff and expertise will be fostered and encouraged 

among VT parks, the goal being to bring the most expedient and effective methods of preservation to vanishing treasures in need. Additionally, new ideas will be investigated including creation of a Friends Group 

which would lead the way in external support, advocacy and fund-raising. With these new efforts and all 

current preservation goals, the VT Program Charter will set the stage for the next ten years of ruins preservation and connect VT efforts to the stewardship goal of the NPS Centennial Initiative.
Vanishing Treasures Resources

38 Vanishing Treasures Program Charter

VT Program Excellence, Professionalism, Policy and Regulation:

The VT Program will foster the application of the best possible approaches to resource documentation and 

preservation with an emphasis on continually improving these practices. It is explicitly recognized that 

the methods employed within the VT Program must be consistent with federal historic preservation laws, 

standards and practices. Indeed, the National Park Service has taken responsibility for providing leadership in preserving the nation’s cultural resources. The VT Program strives to be recognized as a service wide 

resource for expertise and information regarding preservation, particularly of masonry architecture. The Secretary of the Interior and the Advisory Council on Historic Preservation have the primary responsibility for 

overseeing and providing guidance for all preservation efforts; however, the National Park Service, in keeping 

with its mission and the spirit of stewardship and trusteeship it envisions, has the responsibility of protecting 

and preserving cultural resources under its jurisdiction. Accordingly, there are a number of existing historic 

preservation standards and guidelines that must be followed in the management of the VT Program. The 

Secretary of the Interior’s Standards (1982, 1983 and 1985) and the Advisory Council’s Handbook for the 

Treatment of Archaeological Properties (1986) are primary sources for providing technical guidance on cultural resource preservation. 

The National Park Service has also developed policies and guidelines that expand upon and clarify the Secretary of Interior’s Standards. These guidelines do not in all cases specifically address the unique architectural traditions involved in preservation in the American Southwest and thus the VT Program is developing 

and implementing its own Preservation and Management Guidelines to fill this need in Vanishing Treasures 

parks.

Maintaining the Accountability of Vanishing Treasures Funds and Positions:

The Vanishing Treasures Program accomplishes the preservation work for these fragile and irreplaceable 

sites through the combined efforts of the 45 VT parks, the Leadership Committee, the VT Program Manager 

and staff, along with partners and friends. Accountability is sustained through the Performance Management Information System (PMIS) and the Service wide Combined Call (SCC) processes. The combination 

of the SCC and PMIS ensures the two components of performance: accountability and accomplishments. 

Accountability is the ability to document the fact that allocated funds were encumbered as intended. Accomplishments are the measurable results of completed projects. The Pacific West and the Intermountain Region 

both participate in the IMR SCC process and as a multi-Region program, VT project lists are reviewed and 

approved by both Regional Directors. VT parks request base increases for permanent staff through the Operations Formulation System (OFS) following the procedures in place for the Intermountain or Pacific West 

region, depending on park location. 

In addition, VT resources must also be documented in the database programs of Archeological Sites Management Information System, ASMIS, Automated National Catalog System+, ANCS+ and Facility Management 

Software System (FMSS must be included to be eligible for funding support).

Annual Reporting:

The VT Program Manager and staff prepare an annual report on the accomplishments of the VT program. 

VT parks that receive project funding are required to provide an accomplishment report in the prescribed 

format upon project completion for inclusion in the annual report. The report includes feature articles that 

highlight major programmatic accomplishments or topics relevant to many parks and issues in a thematic format. The bulk of the report is organized on a state-by-state basis, identifying parks and projects in each state. 

Each VT Park receives copies of the report to share with Congressional delegations, state and local government, tribal organizations, other federal agencies, partners and friends. The report is a valuable tool to share 

project information and to account for VT work.

VT continues to realize success in preservation efforts due to the scope of the program remaining narrowly 

and specifically defined and consistently demonstrating accountability for the fidelity of its funds. The definition of a vanishing treasures resource receives review periodically to ensure the program continues to support and meet park preservation needs.
Preservation and Management Guidelines

Vanishing Treasures Program Charter 39

MANAGEMENT ENTITIES

The Program began as a “grass roots” program at only three parks, but upon sharing information, the staff 

from many parks found that similarities in resource types and structural preservation issues were common 

to a much larger group of parks. This realization led to growth in the VT Program representing far more 

parks and variety of architectural preservation needs than was initially envisioned. As a result, a mixture of 

program managers and technical staff members was given collateral duty assignments as part of an effort to 

organize and to function as self-directed workgroups created to accomplish the goals of the emerging Vanishing Treasures Program. Three entities were ultimately created from among employees at parks to ensure 

program direction, coordination, progress, technical support and accountability to support program efforts. These include (1) the Leadership Committee; (2) the Program Manager; and (3) technical program 

staff. In addition, ad-hoc Work Groups were brought together to address specific programmatic needs and 

functions. The defined roles of each of these entities are defined in the Charter for Program Management. 

The original management of the VT program through the organizational concept of a “self-directed work 

group” has no equivalent within the operations of the National Park Service. This fact, however, did not 

reduce expectations for accountability and productivity by VT park superintendents and their staff. Specifically, this has meant employing highly creative and entrepreneurial strategies to accomplish the goals and 

objectives of the Program, including guiding its course and direction, identifying and establishing priorities 

for fiscal and professional resources, securing operational funding, setting priorities for project development and insuring that standards are adhered to in terms of the work performed and the personnel hired. 

It also includes creating and using workgroups to address specific programmatic needs and functions and 

communicating the results and achievements of the program to the NPS and Congress. Although originally 

created for a limited and narrowly-focused purpose, the Vanishing Treasures Program continues to foster 

increased focus on a national preservation agenda. 

This Charter identifies the role and function of a wider range of entities that play a part in the VT Program, 

including the VT parks themselves, staff from the IMR and PWR Regional Directorates, IMR State Coordinators and the PWR Desert Network Board and current and future VT Program staff.

LEADERSHIP COMMITTEE

Role and Function: 

The Leadership Committee (LC) reports to the Regional Directors (RD) of the Intermountain and Pacific 

West Regions (IMR and PWR, respectively), who provide strategic and policy direction to the Program. 

The LC is responsible, through the RDs, for guiding the direction of the Vanishing Treasures Program, essentially serving as the VT Program Board of Directors with staff support from the VT Program Manager 

and program staff. The LC provides recommendations to the RDs on strategies, policy, funding priorities 

and other matters that relate to administration of the program and is responsible for identifying fiscal and 

professional resources, recommending priorities for project development and communicating the results 

and achievements of the program to a wide and varied audience. The LC also is responsible for providing 

information to decision-makers in Washington and others. More specifically, the LC: 

promotes the accountability and integrity of the VT Program, in all facets of its operation 

and serves as the Program’s principal advocate, working through the IMR Deputy Assistant 

Regional Director, Cultural Resources (DARD, CR) and the PWR Chief, Cultural Resource 

Programs

annually reviews project funding criteria, project priorities and position priorities and, in 

conjunction with the IMR DARD, CR and the PWR Chief, Cultural Resources and submits 

prioritized lists to the Regional Directors for approval

ensures through the Program Manager that training, including that for preparing project proposals, is provided to VT parks as needed 

conducts business as a Board of Directors and assists in hiring the Program Manager and developing/approving her/his Annual Work Plan 

•

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•

•
Vanishing Treasures Resources

40 Vanishing Treasures Program Charter

coordinates and participates in trips to Washington to educate members of Congress and the 

NPS Directorate about issues affecting the VT Program when directed by the RD

periodically reviews and annually recommends changes to the RDs for the Vanishing Treasures 

Long-Range Plan

attempts to resolve any disputes that may arise regarding any aspect of the operation of the 

Program

maintains and, as necessary, updates an appeal process for questions regarding project or position prioritization

identifies strategies for leveraging funds, partnerships and personnel to best accomplish VT 

Program objectives

reviews the Charter every three years to insure that it remains a viable document governing the 

management of the Program

Selection and Tenure: 

The Leadership Committee consists of a total of nine members, including seven members drawn from 

among the Superintendents (or Deputy/Assistant Superintendents) of the 45 parks currently in the Vanishing Treasures Program. Two of these seven committee members will be elected to represent the fifteen VT 

parks in AZ; two will be elected to represent the twelve VT parks in WY, CO and UT; two members will be 

elected to represent the fourteen VT parks in NM and TX; and the final member shall be elected to represent the four current VT parks in California and Nevada. In the Intermountain Region (IMR), the DARDCultural Resources will involve the NPS State Coordinators to assist in the nomination of interested candidates from within each group of parks and to poll all of the VT Superintendents within those parks to elect 

Leadership Committee members. In the Pacific West Region, the Board of the Mohave Desert Network 

shall be responsible for nominating candidates and electing a Leadership Committee member to represent 

VT parks in CA and NV. 

While serving on the Leadership Committee, members will thus represent the entire group of parks from 

which they were elected and the best interests of the program, rather than their own individual park.

The Regional Directors from the IMR and PWR shall designate representation as standing members. The 

Regional Directors’ representatives are usually the highest ranking official for Cultural Resources in each 

region; such as the IMR DARD and the PWR Chief. The IMR DARD, Cultural Resources and the PWR 

Chief of Cultural Resources Programs shall serve as permanent members on the Leadership Committee. 

Their role is to represent their respective Regional Director (RD), carrying out that function pursuant to 

whatever guidelines pertain in their respective region.

To ensure continuity, all Superintendents of VT parks have the opportunity to participate in the Program’s 

management. To ensure that the Committee’s viewpoints remain fresh, the election of Leadership Committee members shall be for a term of three years and no member may stand for election for more than 

two consecutive terms. Elections of Leadership Committee members will be staggered in such a way that 

either two or three members will be elected each year.

Should a member of the Leadership Committee transfer to a position outside a VT Park, a new member 

from the same group of VT parks shall be elected to serve the remainder of the departing member’s term 

following the normal election process for that group of parks. 

Selection and Role of the Chair: 

The Leadership Committee will elect a Chair by majority vote from among its membership who shall serve 

a two-year term. The Chair of the Leadership Committee will organize and run meetings of the Committee. The Chair works with the IMR State Coordinators, the PWR Desert Network Board and the DARD, 

CR to ensure that all Program elections are carried out in a proper and timely manner. 

Meetings: 

The Leadership Committee will meet as often as necessary and as the availability of travel funding allows, 

but will target two meetings a year. The Chair will establish the date, location, agenda, purpose and length 

of the meetings and will notify members of such at least one month prior to the meeting date. Conference 

•

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•

•

•

•
Preservation and Management Guidelines

Vanishing Treasures Program Charter 41

calls or online conferencing may be used in lieu of face-to-face meetings if determined to be useful or 

prudent by the Chair. The content of these meetings will typically be determined by consensus; however 

any Leadership Committee member may ask that an item be added to the agenda or that a special meeting 

be convened. 

Leadership Committee meetings will be conducted by the Chair. A quorum of five members (for a committee of nine) must be present in order to conduct official business or take a formal vote on any issue. 

Generally, the Leadership Committee will operate by consensus; however, in the event that is not possible, 

decisions will be reached by simple majority vote of the members present. Voting on any issue will be conducted on a one-member, one-vote basis so that each group of parks will be on equal footing in decisionmaking affecting the VT Program. Minutes will be taken at all Leadership Committee meetings following 

protocols established by the Committee and shall be promptly transmitted to the IMR DARD-Cultural 

Resources, the PWR Chief of Cultural Resources and the Superintendents of all the VT parks. 

VANISHING TREASURES PROGRAM MANAGER

The Vanishing Treasures Program Manager is duty-stationed in Santa Fe with the Cultural Resource Program in the Intermountain Regional Office, Santa Fe, and provides day-to-day management and overall coordination of the Vanishing Treasures Program, thereby serving all of the VT parks. The Program Manager 

is accountable to the Leadership Committee members in their role as a Board of Directors, with a reporting 

responsibility to the IMR DARD, CR, and the PWR Chief, Cultural Resources. The IMR DARD CR will 

work with the Leadership Committee in the hiring process. The IMR DARD, CR will serve as the direct 

supervisor of the VT Program Coordinator.

Role and Function:

The Program Manager serves in a staff position to the Leadership Committee and participates in the annual meetings as in an ex-officio capacity. In addition, The Program Manager (PM) assists in arranging 

meetings and logistics, developing agendas and coordinating between the Leadership Committee and the 

work groups. The PM serves as the Vanishing Treasures Program agent for the SCC and OFS processes, 

including working through the Leadership Committee to submit recommendations to the IMR Regional 

Director for project funding and position priorities. On behalf of the Leadership Committee, the PC is 

responsible for communications throughout the Program through implementation of a VT Program Communications Plan. Working with the Leadership Committee, this position develops and manages Program 

training opportunities and organizes and chairs VT conferences approved by the RD. In addition, the VT 

Program Manager:

directs and coordinates services of other VT Program staff in conjunction with the Superintendent 

of their host park

coordinates with the superintendents of their host parks to mutually develop and sign off on performance standards, work plans, and performance appraisals for other VT Program staff

coordinates the membership and work of ad hoc work groups, as requested by the Leadership 

Committee 

develops and executes an Annual Work Plan

prepares and distributes the VT Program Annual Report

updates and distributes the Vanishing Treasures Program Handbook to all VT parks

as appropriate, brokers assistance between VT parks in terms of sharing expertise and equipment 

coordinates with the Leadership Committee to maintain necessary records in order to effectively 

document the accountability and integrity of the Program regarding the use of project and personnel funding

tasks individual Work Groups as directed by the Leadership Committee

manages the program

coordinates workshops, partnering opportunities with preservation agencies, tribes, non-profit 

organizations and universities

works to establish a Friend’s Group for the VT Program

•

•

•

•

•

•

•

•

•

•

•

•
Vanishing Treasures Resources

42 Vanishing Treasures Program Charter

OTHER VANISHING TREASURES PROGRAM STAFF

Role and Function: 

Park and Central based positions provide technical advice and assistance to the VT parks at the request of 

the individual park. These positions may be established by the Leadership Committee to address identified 

needs from the parks. Park requests for using the services of one or more VT Program staff members will 

be coordinated through the Program Manager in concert with the superintendent of the staff member’s 

host park. The host superintendent will be the direct supervisor for program-wide staff positions, which 

currently include a Historical Architect and a Structural Engineer. The host superintendent and the VT 

Program Manager will mutually develop and sign off on performance standards, work plans and performance appraisals for VT Program staff. The Exhibit Specialist/Architectural Conservator is duty-stationed 

in Santa Fe. The performance standards, work plan and performance appraisal are the responsibility of the 

VT Program Manager. VT Program staff serve in an ex-officio capacity on the VT LC.

VANISHING TREASURES AD HOC WORK GROUP

Role and Function: 

Ad hoc groups will be established on an “as-needed” basis by the Leadership Committee to address specific issues and needs of the VT Program, such as: 

evaluating, prioritizing and recommending project funding proposals (through the SSC process); 

and personnel intake or position conversion proposals (through the OFS process)

reviewing funding needs and evaluating alternative funding sources; 

providing technical review of special or multi-park projects 

The composition and number of ad hoc group members will be determined by the Leadership Committee 

in a manner that brings together the range of expertise needed to carry out tasks assigned to each group. 

The use of ad hoc groups will ensure participation by many more VT park staff members due to the limited 

term or involvement and the variety of issues to be addressed. 

Parks are encouraged to develop ad hoc groups to address multi-park issues. The VT Program staff can 

serve as advisors to the park ad hoc groups as requested. The VT Program Manager will serve as the point 

of contact for the park ad hoc groups. 

Communications, Contact and Guidance Received: 

The Ad Hoc Work Group reports to the Leadership Committee, through the Vanishing Treasures Program Manager, who serves as the single point of contact for program-specific issues and information and 

presents the recommendations of the Ad Hoc Work Group(s). If the task requires, the Work Group will 

generally operate by consensus. In the event that a unanimous opinion cannot be reached, a simple majority vote shall prevail with voting on any issue conducted on a one-member, one-vote basis. Minutes shall 

be kept of all Work Group meetings so that both majority and minority opinions will be documented. An 

executive summary of the minutes of Work Group meetings will be transmitted through the Program Manager to the Leadership Committee for their consideration. 

VANISHING TREASURES PARK UNITS

Role and Function: 

Superintendents of VT parks are responsible for assisting the VT Leadership Committee in communicating 

the goals, objectives and needs of the Vanishing Treasures Program to their respective congressional delegations. Park units submit project proposals and update personnel requests to the Leadership Committee 

•

•

•
Preservation and Management Guidelines

Vanishing Treasures Program Charter 43

as appropriate. Park superintendents and their appropriate staff participate on committees and in Work 

Groups and share their resources to further the mission of the Vanishing Treasures Program.

Park-level program managers and VT archeologists, masonry workers, exhibit specialists, etc. are responsible for developing projects focused on inventorying, assessing and treating VT resources within their 

parks. Parks requesting positions to perform VT preservation efforts can seek support from the VT LC 

as the position goes through the OFS process. Parks should allocate Vanishing Treasures funding for both 

projects and personnel pursuant to VT Program guidelines. VT parks, through their Superintendents, 

should communicate questions or concerns about any aspect of the Program to their respective elected 

representative on the VT Leadership Committee and/or to the VT Program Manager. 

The Vanishing Treasures Annual Report helps to ensures that the accountability of VT program funds is 

maintained and shares the accomplishments of preservation in parks. VT park superintendent and staff 

are responsible for annually reporting to the Leadership Committee, through the Program Manager, how 

Program funds allocated to them have been used. Any preservation work accomplished on VT resources is 

also highlighted in the Annual Report. 

IMR DARD, CULTURAL RESOURCES, AND 

PWR CHIEF, CULTURAL RESOURCE PROGRAMS

Role and Function: 

These corresponding positions within the Intermountain and Pacific West Regions act in an advisory 

capacity on the Leadership Committee and serve as VT Program liaisons with their respective Regional Directors. They serve as ex officio non-voting permanent members of the Leadership Committee. The IMR 

DARD, CR serves as the direct supervisor of the VT Program Coordinator and is responsible for assuring 

that an adequate annual line item is maintained to cover program management and support costs.

STATE COORDINATORS (IMR) AND DESERT NETWORK BOARD (PWR)

Role and Function: 

In the Intermountain Region, NPS State Coordinators may play a role in the VT Program by assisting the 

IMR DARD, CR with the nomination and election of Leadership Committee members from the group of 

states they represent. In the Pacific West Region, the Mojave Desert Network Board is directly responsible 

for the election of a Leadership Committee member from the VT Parks in California and Nevada and 

for assisting the PWR, Chief Cultural Resource Programs with other VT Program related matters upon 

request. Both groups also assist the Leadership Committee with the education of their state’s congressional 

delegation and their staff regarding the goals, objectives and needs of the Vanishing Treasures Program.
Vanishing Treasures Resources

44 Vanishing Treasures Leadership 2005-2008

APPENDIX B

Vanishing Treasures Leadership Committees- 2005, 2006 and 2008

May 2005

Name Representing Start Date Term End Date

Ann Rasor Arizona Incumbent 1 year May 2006

Glenn Fulfer, Chair New Mexico Incumbent 1 year May 2006

John Lujan Texas Incumbent 1 year May 2006

Lee Baiza Arizona 5/25/2005 3 years May 2008

Bruce Noble CO/WY 5/25/2005 2 years May 2007

Corky Hays Utah 5/25/2005 3 years May 2008

Curt Sauer PWR Parks 5/25/2005 3 years May 2008

Sande McDermott IMR-DARD Permanent

Stephanie Toothman PWR-Chief CR Permanent

Virginia S-Halfmoon VT Prog Coord Perm-staff

2006-2007

Name Representing Start Date Term End Date

Lee Baiza, Chair Arizona 5/25/2005 3 years May 2008

Bruce Noble CO/WY 5/25/2005 2 years May 2007

Corky Hays Utah 5/25/2005 3 years May 2008

Brad Traver Arizona 1/24/2006 3 years May 2009

Kayci Cook Collins New Mexico 1/24/2006 3 years May 2009

Todd Brindle Texas 1/24/2006 2 years *Replaced

Darlene Koontz Texas 8/4/2006 1 year Aug. 2008

Curt Sauer PWR Parks 5/25/2005 3 years May 2008

Sande McDermott IMR-DARD Permanent

Stephanie Toothman PWR-Chief CR Permanent

Virginia S-Halfmoon VT Prog Coord Perm-staff

2007- 2008

Name Representing Start Date Term End Date

Lee Baiza Arizona 5/25/2005 3 years May 2008

Corky Hays Utah 5/25/2005 3 years May 2008

Brad Traver, Chair New Mexico 1/24/2006 3 years May 2009

Kayci Cook Collins New Mexico 1/24/2006 3 years May 2009

Curt Sauer PWR Parks 5/25/2005 3 years May 2008

Sande McDermott IMR-DARD Permanent

Stephanie Toothman PWR-Chief CR Permanent

Virginia S-Halfmoon VT Prog Coord Perm-staff
Preservation and Management Guidelines

Vanishing Treasures Funding Process 45

 APPENDIX C

Vanishing Treasures Funding Process

Vanishing Treasures (VT) Program project funds are obtained through the Service wide Comprehensive 

Call. The Intermountain Region (IMR) Financial Officer notifies parks of the years for which projects can 

be submitted. The IMR is maintaining a five-year list of prioritized projects which can be seen on the IMR 

Business and Technology, Financial Management, Service wide Comprehensive Call prioritized list. VT 

Project funding can be sought for treatment/documentation projects or condition-assessment projects. A 

completion report and project photos are required for project funds received. Portions of the completion 

report and photos are used in the VT Annual Report as a means of verifying appropriate use of funds and 

sharing information and techniques among parks and partners in the preservation community.

Criteria for projects, amount caps and number of projects per park can be seen on the intranet, IMR VT 

site or IMR Financial Management page. The project criteria and caps change occasionally at the recommendation from the VT project panel and in agreement with the VT Leadership Committee. It is incumbent upon the resource staff to stay current with funding changes.

A panel of experts from VT parks reviews all projects against the criteria and provides a score. The IMR 

budget staff designates the year the project will receive funding based on their project score; the desire is to 

fund the highest-ranked projects as the Region’s top priorities.

An appeal process does exist for parks that want additional consideration for their project’s ranking. In 

late August, a call for appeals goes out to the parks from the IMR Financial Officer. Parks are given two 

weeks to submit their appeal(s) which indicates the urgency of the project or relevant factors which may 

have been overlooked by the panel. The appeal(s) must be submitted to IMR Financial Officer and the VT 

program agent. The Financial Officer receives all appeals and prepares a list for review. In making their determination, a Steering Committee, composed of three superintendents and the Deputy Regional Director, 

reviews the project score, the park ranking of the project, statement of appeal(s) and statements from the 

program agent in making their determination.
Vanishing Treasures Resources

46 Preservation Priority Matrix

APPENDIX D

Preservation Priority Matrix

This Matrix can serve as a template or as an example of a priority-setting process. By putting scores against 

values, some of which are weighted and then added together, a sum can be arrived at which can be compared to other sums for other sites to give a numerical value. The Matrix is only meant to be a relative tool 

and one which needs to be adjusted for the particular resources. 

Preliminary information that is needed to establish a basis for priorities:

SITE:

Identifying name of site including Park or Monument name.

STRUCTURE:

Name of structure within a site.

ID NUMBER:

The identifying number of a site or structure being considered. ASMIS number: Archeological Survey

Management Inventory System which is the primary NPS numbering system for archeological sites.

In addition, states have their own numbering systems. Include all numbering systems here.

ELEMENT NUMBER:

A specific number which identifies a feature or individual unit within a structure or site.

TIME PERIOD:

The dates during which time the site or structure was occupied and used.

The date on which the site was established as a Monument or Park and preservation/interpretation was 

begun.

EXISTING AVAILABLE DOCUMENTATION:

List all available documentation which can be used for preservation planning purposes.
Preservation and Management Guidelines

Preservation Priority Matrix 47

Example of how a weighted matrix can be used to calculate values relatively:

Rating Factor Weight Score

National Register Status

3 -Listed; 2-Eligible; 1-Not Eligible; 0-Not evaluated

1

Historical Significance

3-Structure is nationally significant and has high importance to park; 

2-Structure is relatively important ; 1- Structure has minor role in 

history of park; 0- No importance to history of park

1

Documentation

3-No documentation is available; 2-Minimal and inadequate 

Documentation is available; 1-Adaquate documentation available;

0- Level 1 or 2 HABS-type documentation is available1

Architectural Significance

3-The structure has unique and representative features important to the 

Park; 2- Has some architectural significance; 1-Possesses little 

architectural value; 0- Has no architectural value

1

Current Physical Condition

3-Unsafe and dangerous condition; 2-Poor and deteriorating condition;

1- Structure in need of attention for preservation; 0-In good condition

3

Severity of Threats

3-Resource is threatened with loss unless action is taken in 1-2 years;

2-Moderate loss will occur if action is not taken in 5 years; 1- Normal

aging of resource occurring, no impacting factors; 0- Good condition,

being actively maintained

2

Access

3-Accessible to the public, on view; 2- Back country, accessible to public but requiring long hike; 1- Difficult to reach and not available to public; 0- Nearly inaccessible, 

hardly ever visited by resource personnel

1

Integrity

3-Very little or no alterations or treatments, with mostly original fabric 

remaining; 2-Some alterations have occurred and evidence of treatments exists; 1-

The structure has received major alterations or treatments and little original fabric can 

be seen; 0-Complete reconstruction

3

Interpretation

3-Plays a key role in the park’s interpretive themes; 2-Plays a secondary

role in the park’s interpretive themes; 1-Has a limited and minimal role in the park’s 

interpretive themes; 0-Has no role in the park’s interpretive themes

1

Use

3-Active use as part of an interpretive program, regularly visited; 

2-Sometimes visited but remote or difficult to access; 1-Backcountry 

site seldom visited by the public; O-Off-trail, backcountry, never visited

2

Treatment Decision

3-must be preserved; 2-Should be preserved; 1-May be preserved

0-May be treated with benign neglect

1

Total of values with multiples applied
Vanishing Treasures Resources

48 Preservation Priority Matrix

Additional factors which can impact the assignment of priorities:

Environmental Factors

Is the site within a recent wildfire perimeter?

Is the site being impacted by runoff?

Has the runoff visibly increased since the wildfire?

Is the upper watershed intact?

Do hydrophobic soils exist above or in the site?

Is there a large expanse of exposed bedrock directly above the site?

Is the site located under a natural pour-off or drainage?

Would a silicone drip line drop runoff threat from severe to moderate or low?

Would upper watershed treatments drop runoff threat from severe to moderate or low?

Overall Site Considerations

Does the site have any unique characteristics (early occupation, long-term occupation)?

Are unique features (plaster, rock art, wood elements and the like) threatened?

Has the site been burned over, exhibiting visible fire effects (oxidization, ash staining)?

Is there any alcove deterioration occurring that threatens features or architecture within the site?

Will the installation of excelsior or silt logs around features lower overall threats to site?

Study Unit Considerations

Does mortar erosion or basal stone deterioration threaten wall segment stability?

If this wall fails, will others be brought down with it?

Are there any severe cracks or leaning wall segments?

Site Location/Community Status 

Does this site have importance within a community setting?

Will the community aspect be compromised if this site is left to deteriorate?

Is the site easily accessible for stabilization treatments to occur?

Does a combination of any of the above factors exist?

Will any valuable information be lost if the site is not treated within three to five years?

If you have answered “YES” to a significant number of the above questions, then think seriously about giving the site a HIGH overall treatment priority (for any additional documentation or stabilization). Always 

consider if additional documentation (architectural documentation) instead of stabilization can be used as 

a form of treatment.

•

•

•

•

•

•

•

•

•

•

•

•

•

•

•

•

•

•

•

•
Preservation and Management Guidelines

Terminology 49

APPENDIX E

Terminology

Ruins Preservation Terminology – preservation/architectural terms, materials and techniques.

Amendment: An additive which when added to a material changes its properties, typically in conservation to improve durability, cohesion or adhesion. These are usually industrial chemicals and products but 

also may be organic natural products. Amendments have been used in VT resources to provide additional 

stability to earthen materials.

Authenticity: As used in the VT lexicon, this refers to the genuine qualities of the site, structure or feature. 

To be authentic, the aspect must be of high integrity. Reconstructions, reproductions and overly worked 

sites or features do not possess authenticity. The material fabric often reflects a true measure of an aspect 

of cultural history. The original historic or pre-historic fabric is authentic while repairs, reconstructions or 

restorations are not. Levels can apply, as a heavily worked site with some original materials might have low 

authenticity while a site with no or few interventions would have a high level of authenticity.

Cavates: Architectural recesses behind cliff dwelling which have been manipulated into the bedrock by 

humans. These features are usually the back walls of the cliff dwellings and do not constitute actual caves 

but are cave-like. 

Condition: Establishing condition of a site or structure is for the primary purpose of coordinating the evaluation with FMSS documentation, ASMIS reporting and PMIS submittals. It is recognized that a condition 

of good may need to be re-evaluated to poor due to impending threats; it may also be possible for a “poor 

condition” to result in no treatment due to other factors such as management considerations. An additional 

complexity to be recognized is that within any site or structure many different conditions may be present 

and more detailed description will be required for site documentation than for planning purposes. 

Good Condition: The site shows no clear evidence of major negative disturbance and deterioration 

by natural and/or human forces. The site’s archeological values remain well preserved, and no site 

treatment actions are required in the near future to maintain its condition.

Fair Condition: The site shows clear evidence of minor disturbance and deterioration by natural and/

or human forces and some degree of corrective action should be carried out fairly soon to protect the 

site. 

Poor Condition: The site shows clear evidence of minor disturbance and rapid deterioration by natural and/or human forces and stable immediate corrective action is required to protect and preserve 

the site.

Cultural Landscape: a geographic area, including both cultural and natural resources and the wildlife or 

domestic animals therein, associated with a historic event, activity or person(s) or exhibiting other cultural 

or aesthetic values. 

Earthen Architecture: Architecture built of earthen materials including adobe bricks, puddled earth 

(cob), rammed earth (pise) , wattle and daube (jacal), sod (terron) and /or any combination of these together. 

Intensity of On-Site Erosion: As above, this definition may require nuance in the documentation as special cases likely will result in more complex analysis.

Severe Erosion: The site will be significantly damaged or lost if action is not taken immediately.

Moderate Erosion: For an impact to be considered moderate, it must meet at least one of the fol-
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50 Terminology

lowing criteria: The site will be significantly damaged or lost if action is not taken in the immediate 

future. The site has been damaged and some integrity has been lost.

Low Erosion: The continuing effort of the impact is known but will not result in significant or irreparable damage to the site.

None: The site has not been obviously impacted.

Integrity: The authenticity of a property’s historic identity, evidenced by the survival of physical characteristics that existed during its historic and/or prehistoric period; the extent to which a property retains its 

historic appearance and its ability to convey its historic significance. In the larger sense of site, integrity refers to how much of the structure remains standing and intact. For example, a structure that only has one 

complete wall standing where four and a roof once were would be given a value of 20%. A structure with 

all four walls standing and intact, plus an intact roof and floor, would be given a value of 100%.

Ruins: Above-ground architecture which is no longer in use but still represents or depicts by its simple 

presence its original purpose. The structural remains may or may not be roofed or may only be partially 

roofed and the elemental parts of the structure exhibit the aging and effects of exposure which they have 

experienced over time. Ruins are the tangible memory of a formerly alive place which contain within the 

remains the particular cultural history of that place. 

Site: A site in the largest sense incorporates the cultural landscape which is the geographic area including both the cultural and natural resources and the wildlife or domestic animals therein. Also included 

are trails, signage, rest stops, drainage, etc. which have been added to the landscape. Within the site, the 

cultural resources defining the site within the context of Vanishing Treasures are the archeological /architectural structural remains which are associated with historical events, people, activities or other cultural 

significant history or aesthetic value. 

Site context: The cultural landscape of which the site is a part .

Stability: Stability refers to a wall or structure’s state of equilibrium. 

Stable: A structure that maintains consistency of composition and components with little or no sign of erosion that would lead to any form of structural degradation. The term stable can also be applied to structures that have essentially deteriorated to grade and thus have little or no standing structural remains above 

the ground surface that would be subject to further deterioration.

Partially Stable: A structure that exhibits signs of whole or partial degradation of the existing composition 

and components such that structural stability is threatened.

Unstable: A structure that has suffered damage from erosive forces such that structural collapse or complete degradation is imminent. Environmental changes or impacts pending which will lead to instability 

can be cause for an unstable designation. 
Preservation and Management Guidelines

Management And Monitoring: Structural Evaluation Guideline 51

APPENDIX F

Management And Monitoring : Structural Evaluation Guideline

Prepared by Preston Fisher, P.E. - April, 2005

Revised July, 2008

The purpose of these guidelines for field data collection of structural properties is to standardize nomenclature, coding values and procedures for describing, recording, monitoring and evaluating the structural 

properties and stability of archeological sites and the structures within them. The data collected will be 

used to determine the stability of structures by comparing the data with data previously collected, or by 

establishing baseline data that can be compared with data collected at a later date. The initial need for 

field data collection of structural properties is usually first identified by park staff. This is then reviewed in 

consultation with the VT Program Structural Engineer, who confirms the location of areas of concern and 

assists Park Staff with establishing specific monitoring point locations and data collection frequencies. A 

determination of the need for a site visit will be made at this point in the process. Park staff, in conjunction 

with the Structural Engineer, develops a systematic approach to analyze and evaluate structural properties 

of sites and establish monitoring frequencies. Initial monitoring points are established by the park staff 

and/or the Structural Engineer and subsequent readings are usually taken by park staff, with copies provided to the Structural Engineer for evaluation. Comparisons are generally more frequent initially to establish 

baseline conditions and may be made at more frequent intervals, such as after significant rainfall or after 

heavy snowfall or extended period of freezing weather. Generally this process involves recording findings 

on a form which includes tabular data, photographs and/or drawings as appropriate. Forms will be created 

in response to the specific site and complexity of issues. Ultimately, the form will be used to look for patterns or clues indicating the mechanism of deterioration. Examples of forms are to found on the Intranet 

site. 

These guidelines are adapted from guidelines originally developed for standing prehistoric archeological 

sites consisting mostly of stone and mud mortar or adobe. Portions of these guidelines have been amended 

to include procedures for evaluating other VT resources that include log, timber and wood frame structures. These guidelines are intended to guide park staff in evaluating areas of structural concern establishing monitoring points and frequencies.

G.1 Structural Evaluation

A structural evaluation examines and considers the condition of a structure to determine if there is any 

movement of walls or footings/foundations, or portions of them that may lead to eventual structural failure. The focus for this work is primarily on evaluating potential major wall failure. During structural evaluation work, each wall is inspected for cracking, leaning and bulging sections and deterioration of members 

within the wall. The footings/foundations are inspected to determine if there are any voids or any settlement of the wall foundation. Roofs, if present, are inspected for settlement and distortion. In alcove sites, 

the alcove ceiling and walls are inspected for past or potential rock fall and alcove scaling hazards. In timber and frame structures, connections are examined to ensure continuity. Materials of the structure such as 

stone, mortar or wood are evaluated for soundness.

The Structural Evaluation focuses on six basic conditions. In terms of definitions, most of these are selfexplanatory. These conditions can be listed as:

• cracked walls

• leaning or out-of-plumb walls

• bulging walls 

• composite conditions (a blend of the other three conditions)

• deteriorated and non-functional connections

• deteriorated structural materials

• site-specific physical abnormalities (unstable soil/bedrock, alcove conditions, erosion that threatens 

architecture, etc.)

Whichever of these conditions pertains, the objective is always to determine whether the condition is ac-
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52 Management And Monitoring: Structural Evaluation Guideline

tive or inactive. Active conditions are those that appear to be changing during the present and recent past, 

generally for the worse. Inactive conditions are those where movement occurred long ago, but the wall 

or other construct has not undergone much if any change in the modern or historic era. In some cases, 

seasonal environmental changes reflect benign movement such as expansion and contraction which can 

be misleading. Unless you have some way of knowing what has happened recently, it is generally difficult 

to know whether the structure moved long ago and is in relative stasis. This is the reason historic photographs or past documentation photos may be important. 

Another way of addressing this issue is to have some degree of knowledge about stabilization work that 

has been done. For example, if a repair to a wall was done in 1970, and there is separation of several mm or 

cm along the mortar used in that repair, it is likely that movement is active. Since this situation often does 

not pertain and many times there are no historic photos of a given wall, you can determine if a condition is 

active or not by taking measurements over a period of time and comparing them. For this reason, precise 

measuring is often necessary to determine what is occurring.

Threats such as differential fill levels, poor drainage, water infiltration, seepage, basal moisture/deterioration, settlement, erosion, insect damage and rodent burrowing are recorded. The impact of these factors 

to overall structural stability is the focus of the structural analysis. As a general rule, walls that are leaning, 

bulging or cracking should have structural evaluation data and record forms completed for them. This 

evaluation documentation should be maintained at the park with a copy sent to the structural engineer. 

Complex cases will require a structural engineer to further evaluate the wall. Deterioration of load bearing 

elements in wood structures will require engineering review. Any recommended mitigation activity should 

consider potential impact to the structural stability and should be documented and kept in a monitoring 

site file at the park with a copy to the structural engineer. This record will be used to qualitatively and quantitatively observe changes over measured time in relation to environmental influences. 

The steps in the Structural Evaluation process are:

(1) Archival research 

(2) Fieldwork

(3) Reporting 

(4) Monitoring 

The product of the structural evaluation process ranges from data in the site files to formal reports, but 

the objective is to complete an analysis recorded as a baseline structural evaluation which standardizes 

and makes available the required information. (An example of a baseline structural evaluation form can 

be found on the Intranet site) These data ultimately are used to assess periodic change during a structural 

monitoring program that can be done either independently of the overall site condition monitoring program or in concert with it.

G.1.1. Archival Research

Before visiting and inspecting any site, evaluators should locate any existing photos, reports, stabilization 

records or other documents available. These records consist of two general kinds: 

• First, in many cases, site files, local museums, libraries or archive centers are an important source 

of information. Many structural changes in these buildings took place over long periods of time, 

making historical photographs or occasional comments important. If possible, making copies of any 

old photos for comparison with current conditions will be beneficial during the evaluation phase. 

Especially useful are images showing wall elevations or evidence of structural movement such as 

cracking, leaning or bulging in the past. 

• Secondly, if you are working at a National Park, Monument or Historical Site, you should check any 

database to see if the site has been previously visited and documented. This is described in more 

detail below.

Making a working copy of the latest available site map is critical because it supplies important provenience 

information to link with other site data fields, and you will need the map to add notations in the field. This 

map will then become part of the record of your inspection. If you prepare a report, you will need to know 

the room number, which wall (north, east, south, west, etc.), and whether a condition is noted on the exterior or interior of a wall. Noting these on the plan and/or elevations in relation to photography and data 

forms will be very useful in the assessment.
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Management And Monitoring: Structural Evaluation Guideline 53

If any of the conditions above are noted, the resource person or project lead should refer to the site narrative and photos for that site to help quantify the type and severity of threats to the structural integrity of the 

site and try to ascertain if there has been any movement since the last or original observations. Recording 

that in a manner for others to see and understand will provide the basis for any actions recommended.

G.1.2. Fieldwork

In addition to maps, photos and literature collected and copied for use in the field, additional tools to help 

evaluate the structural integrity of the site are suggested. Digital and/or 35mm cameras should be taken 

along to document areas of concern within the site. Calipers graduated in 1/20 mm and a tape measure 

graduated in mm should also be utilized to take accurate measurements. A plumb bob should be taken to 

determine vertical profiles of walls. An ice pick or scratch awl can be used to probe into deteriorated wood 

to evaluate the extent of deterioration. A thermometer is also recommended to document ambient air 

temperatures as well as surface temperatures of the architecture. Access equipment such as ladders and 

ropes should be taken along if needed. Any forms necessary for recording the data and paper for sketches 

should also be taken. 

In approaching the site, the surveyor should observe and note any potential exterior threats to the site 

such as water and erosion paths leading into, through or undermining the site. Note any leaning or bulging 

walls, walls that have already fallen, rock fall above, in, or around the site, or any other threats to the site. 

The type of architecture should be characterized and identified and the construction method and materials 

used should be noted in a wall data section of the form being used, unless this data has been recorded during previous documentation efforts.

Upon arrival at a masonry site, the surveyor should systematically evaluate the site beginning at one end 

and working toward the opposite end, inspecting each wall for cracking, leaning, separating and bulging 

sections. The foundations/footers are inspected to determine if there are any voids or any settlement of 

the wall foundation or footing elements. In alcove sites, the alcove ceiling and walls are inspected for past 

or potential rock fall, and alcove scaling hazards. During a structural evaluation, threats such as differential 

fill levels, poor drainage, water infiltration, seepage, basal moisture/deterioration, settlement, erosion and 

rodent burrowing are also noted, with special attention given to how they impact or might impact cracked 

or leaning/out-of-plumb walls. 

Arriving at a timber, log or wood structure site, the surveyor should completely circulate around the structure, inspecting for telltale signs of deterioration such as leaning, settlement, roof failure, water damage or 

out of plane sections. The foundation and ground condition must be checked, working up the building to 

the roof, if there is one. Areas where wood is in direct contact with ground should be inspected carefully. 

Wood is particularly susceptible to insect attack so this inspection must always be carried out. A sharp 

object such as an ice pick can be a useful tool for probing into wood to see if the inner portion of wooden 

members is solid. In the case of roofless wooden structures, the wood elements exposed to rain and snow 

will have to be checked for rot. The wood elements and their connecting points need to be checked for deterioration and/or failure. In designing forms for wooden structures, conditions such as severe cracking, rot 

and insect damage should be noted, especially at any connections and joints. Annotation on photographs 

documents and locates specific areas of deterioration.

G.1.2.1. Cracked Walls

The life span of the prehistoric masonry structures we are observing has been much longer than the expected life span of structures built today. For example, cracks which have developed since historic stabilization materials were added are more likely related to active movement than cracks in original fabric, which 

may indicate movement several hundred years in age. Due to the long life span of the structures we are 

evaluating, we need to look for recent movement and try to determine if movement is active over a number 

of years. A crack or wall that shows little or no movement over a one- or two-year time span may show 

appreciable movement over 10, 20 or 50 years. It is common for walls and cracks to fluctuate with daily and 

seasonal temperature changes; however, structural engineers look for cracks that get progressively wider 

over longer periods of time. Changes in the rate of movement may also indicate instability in a structure. 

Most often, as an object such as a wall nears the point of failure, the rate of movement will accelerate; thus, 

if we can identify rate of movement through repeated site visits, we can sometimes predict how near a 
Vanishing Treasures Resources

54 Management And Monitoring: Structural Evaluation Guideline

structure or wall may be to imminent collapse. (See Intranet site for examples of a crack monitoring program.)

Cracking can indicate movement in the structure, which can indicate a potential for the eventual collapse 

of the structure. When cracks are evident, a determination must be made as to whether the cracks are just 

on the surface or are more significant structural cracks. 

Additional questions that you should have in mind as you are evaluating whether a crack is active or not 

would include: What is the direction of movement? What is the cause of the movement? 

The two primary causes of cracking are differential settlement, and thermal expansion and contraction. 

• Vertical cracks that run generally parallel to the end of a wall (at, or near, an abutment) often are a 

result of thermal expansion and contraction. Typical cracks to be concerned with could be at wall 

intersections/abutments or cracks that run most of the height of the wall. 

• Small hairline cracks usually indicate shrinkage in the mortar and pose no serious threat to the structure.

• Cracks that are wider at the top than at the bottom, or wider at the bottom than the top, often indicate structural problems, and the foundation of the structure may be settling unevenly (differential 

foundation settlement). 

• Diagonal cracking often indicates differential settlement as well. A line drawn perpendicular from 

the midpoint of a diagonal crack toward the ground usually points to the source of the problem, 

namely, differential settlement at that point. 

• Horizontal cracks can indicate foundation settlement or deterioration of stones and mortar along the 

base of the wall.

Inactive cracks simply need to be documented. Active cracks need to be monitored to determine the rate 

of movement. 

G.1.2.1.1. Measuring Cracks

When cracks are encountered, some initial measurements noting the configuration of the cracks and/or 

walls should be noted on the Structural Engineering Evaluation and Monitoring Form. The guideline for 

encoding the crack severity value is tied to the relationship between crack size and wall height, and determining whether the cracks is active or not is tied to a baseline evaluation of width as well as length. Measurements should be taken at locations that can be referenced in the future, keeping in mind that walls may 

settle slowly such that the movement may not be noticeable for years, decades or centuries. 

Measuring and characterizing cracks can be done in the following ways: (1) utilizing calipers and/or tape 

(2) installing commercial crack monitors and (3) photographing cracks and walls from datum points. Photography is also an important part of the first two strategies.

G.1.2.1.1.1. Calipers/Tape Measurers

The first step is to find and establish measuring locations along the crack. These locations will be used to 

take a baseline measurement of the crack that can be measured again in the future to determine if the crack 

is active. At each location, the measurement will be taken as distance between three points on stones with 

two marks on one side and one on the other side of the crack, rather than of the crack itself. Select measuring locations by scanning the crack and taking preliminary measurements to find the widest point of the 

crack. Most vertical cracks will show movement more readily toward the top, making it easier to determine 

if they are active there. It is best to establish the measuring location at, or near, the point where the crack is 

widest, and to try to measure as perpendicular to the crack as possible.

Once measuring locations are selected, it is imperative to mark the locations and take a photograph so that 

they can be located in the future, and compared to baseline measurements. Locate the horizontal and vertical distance to the measuring location from the edge of the wall, and the bottom or top of the wall. After 

selecting locations, each should be given a measuring location designator (e.g. Cr01Rm3WIntML1) for 

reference. Cr01Rm3WIntML1 stands for Crack number 1, Room 3, West Interior, Measuring Location 1. 

This measuring location designator should be noted on the plan map, a sketch elevation map and/or a copy 

of the elevation map. You can also label the location on the wall itself with a Sharpie or pencil, if appropriate. Attention must be paid to the wall material and the marker type to ensure reversibility.
Preservation and Management Guidelines

Management And Monitoring: Structural Evaluation Guideline 55

Each location is then given three measuring points. Most of the measuring locations will be geared toward 

measurement with a caliper, although for longer distances, a tape measure can be used. In any case, the 

distance between the three points is recorded to the nearest mm. Points on two stones, or opposite sides of 

the crack, should be marked by scratching fine lines and using fine pencil marks shaped like this ├ , and this 

┤ (Figure 1). If possible the two points on one side should be on the stable surface.

Figure 1. Caliper measuring points etched on Building Stones. 

Calipers are tools that can take refined measurements of small spaces, so they are especially useful in measuring cracks. Calipers can be used to take both interior and exterior measurements. Once the points are 

aligned, the space between them is then recorded to the nearest mm, even though calipers can take more 

precise measurements than that.

Tape measures can also be used to measure between points, but since they are less precise than calipers, it 

is recommended that they be used only for measurements too long to measure with calipers. Points similar 

to the caliper measuring points are etched into the wall with a knife blade and/or marked with a pencil on 

rocks at a convenient distance, and the measurements are taken with a tape measure to the nearest mm. 

One example of a situation in which a tape measure might be needed is to measure between marks on a 

sagging roof, and a marked point on the floor beneath it.

For future location purposes, it is important to supply photos with a scale showing the measuring 

location(s) enough of the crack to be able to identify the location(s). Photo reference information is 

included on the Structural Engineering Evaluation and Monitoring Form. Both close-up and overall shots 

are recommended. If measuring locations are established, the measurement and relocation information 

should be included on the Structural Engineering Evaluation and Monitoring Form. The form has a space 

for describing or supplying basic measurements for relocating measuring locations.

G.1.2.1.1.2. Commercial Crack Monitors

Commercial crack monitors consist of two overlapping acrylic plates (Figure 2). One plate is white with a 

black millimeter grid, while the other is transparent with red cross hairs centered over the grid. Once the 

Measure between marked points

in two locations with calipers.

Deviation from original position is indicated here.

Figure 2. Commercial Crack Monitor. 
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56 Management And Monitoring: Structural Evaluation Guideline

crack monitor is in position across a crack, the crosshairs shift vertically or horizontally on the grid if 

movement occurs. The movement is then recorded on monitoring sheets in the image of the crack monitor 

ruler with a red pencil.

Commercial crack monitors are more intrusive than measuring marks but are an inexpensive way to measure movement. They should be installed at locations where one part of a wall is believed to be stable, and 

the other wall moves independently of the first part. Crack monitors should be installed where minimal 

impact to original plaster or other material occurs and definitely not on unstable surfaces. Placement of a 

crack monitor may require consultation with a conservator. The usual method of attachment is to use epoxy cement, following the instructions supplied with the gauge. It takes from several hours up to a couple 

of days for the epoxy to cure so that the grids can be separated and the gauge is operational.

After the monitor becomes operational, you will need to take a baseline reading. During monitoring revisits, periodic readings are recorded on crack monitor progress sheets that are included with each Avongard 

TM (1-800-244-7241) crack monitor (Figure 2). Under no circumstances are crack monitors to be installed 

without a program in place which includes routine review and consultation with the VT Engineer. 

Figure 3. Crack Monitor Baseline Record and Progress Sheet
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Management And Monitoring: Structural Evaluation Guideline 57

G.1.2.1.1.3. Photographing Cracks and Walls from Datum Points

Photography is useful for identifying the crack monitor locations so that monitoring revisits are less complicated. Photographs are taken of areas of generalized cracking to establish baseline criteria for future 

evaluation. The location and height of the photographs from a datum is noted, so photos can be taken 

from the exact location again over years of monitoring. Documentary photographs of each monitoring 

location are also taken to help relocate the measurement locations.

G.1.2.2. Leaning/Out-Of Plumb Walls

Walls may begin to lean, twist or bulge as gravity takes its toll, sometimes 

without cracking. Factors include differential fill, rodent burrowing, 

top-heaviness and many others. Evidence that a wall is leaning, or has the 

potential for leaning, in alcove sites may be fresh ghost lines on the alcove 

ceiling or roof beam displacement.

When a leaning wall is encountered, it is possible to evaluate how likely it 

is to collapse using the Rule of Thirds. This concept is incorporated into 

the severity coding values for use on the Structural Engineering Evaluation 

and Monitoring Form. Determine the deflection value (DV) by dropping a plumb bob to the current grade on the side toward which the wall 

leans, as shown in Figure 4. Compare the greatest distance of deflection 

(Deflection Value or DV) against the wall thickness (WT) near the base of 

the wall. If the deflection value is less than one-third of the wall thickness, 

the wall is probably still stable. If the deflection value is greater than twothirds the wall thickness, the wall is probably unstable or nearing collapse.

As with crack monitoring, you need to inspect the wall enough to be able to find a point where the wall lean 

is greatest. This can be done by suspending a plumb bob from the top of the wall, or a reference point on 

the alcove ceiling, and taking a few preliminary measurements. After selecting a point along the leaning wall 

top where the wall lean is greatest, it should be marked. Marks can be made with a pencil or Sharpie, and a 

notch can be etched into the top stone where the plumb bob string is placed. Suspending a plumb bob to 

a point on the ground, that is also then marked, will permit the distance between to be measured, probably 

near the ground. In cases where the wall lean is not uniform, a vertical profile of the wall at this point should 

be recorded.

As with crack measuring points, relocation of these points is important for monitoring changes in the 

amount that the wall leans in the future. Therefore, they must be described on the form, and photographed 

to show where they are located.

G.1.2.3. Bulging Walls

Bulging walls can be the result of many different factors such as rodent burrowing, moisture infiltration, 

mortar erosion, differential settlement and top-heaviness. Bulging walls may or may not show evidence of 

cracking, and may also be associated with leaning walls.

When a bulging wall is encountered, you need to inspect the wall enough to be able to find a point where 

the bulge is greatest. This can be done by suspending a plumb bob from the top of the wall or a reference 

point on the alcove ceiling, and taking a few preliminary measurements. After selecting a point along the 

wall top where the bulge is greatest, both points should be marked. Suspending a plumb bob to a point on 

the ground that is also then marked will permit the distance to be measured between the plumb line and 

the wall, thus creating a vertical profile of the wall at the bulge. This should also be done on a horizontal 

portion of the wall. At the point where the bulge is greatest, you should set a level line along the portion 

of the wall where the bulge is greatest, and measure from the line to the wall to create a horizontal profile 

of the wall at this portion of the wall. If possible, a vertical and horizontal grid should be established by 

creating several horizontal and vertical profiles at points across the wall face. A sketch should be included 

outlining the extent of the bulge, if possible, and identifying any other concerns such as cracks, missing 

mortar or missing stones. 

Figure 4. Rule of Thirds
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58 Management And Monitoring: Structural Evaluation Guideline

G.1.2.4. Composite Conditions

This term applies to those walls that have a combination of any of the above conditions such as leaning or 

bulging walls with cracking and/or severe threats. In this case, fill out any or all sections of the form that are 

appropriate.

G.1.2.5. Connections

This term applies mostly to timber and frame structures. The integrity of timber and frame structures 

depends largely on the connections between units and members. When connecting points deteriorate 

either due to the material loss or connector deterioration, the structural stability can be compromised. It is 

necessary to characterize the connection and its deterioration so the structural engineer can evaluate the 

situation.

G.1.2.6. Materials

Material deterioration (such as stone disaggregation, spalling, flaking and delaminating), wood deterioration (such as fungal decay, insect damage, stress cracking and fire damage) and adobe erosion are fundamental causes of structural deterioration and failure. These materials make up the fundamental parts of a 

structure. Their condition and the condition of the system which connects the parts ultimately determines 

the capacity of a structure to support load, resist overturning or up-lift, respond to stress, and perform as 

intended. In ruins, often major parts of the system are gone; therefore the system becomes more complex 

and challenging, often relying on original redundancy to stay viable. Material condition must be recorded 

and changes noted in order to analyze fundamental capacity.

G.1.3. Reporting

A copy of the forms generated by the processes described above should be kept in the site file for each 

specific site. A written report should be generated if there are several monitoring points established at a 

site, and/or if it is determined that there may be active movement at a site or there is a need for additional 

monitoring at the site. This report will generally be produced by the Structural Engineer, but can also be 

produced by anyone else who has inspected the site in consultation with the Engineer. The report should 

detail the site(s) visited, a general summary of the site conditions, detailed summaries of the areas of concern, monitoring methods initiated and recommended actions, including monitoring frequencies, stabilization measures and treatments and an updated site map, with monitoring points depicted on the map. The 

format of such reporting must be easily retrievable and not in any kind of proprietary program. 

Figure 5. Measuring bulging walls

Measure from plumbline back 

to the face of the wall.

Measure at several points to 

form a grid.
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Management And Monitoring: Structural Evaluation Guideline 59

G.1.4. Monitoring

Once current or baseline conditions have been identified, areas of concern identified (if any) and monitoring points established, a monitoring schedule is required. The monitoring frequency will depend on the 

ease of accessibility to the site, the severity of threats to features within the site and availability of personnel 

to conduct the monitoring. If threats have been identified as severe, monthly monitoring should be conducted for at least one year until it can be determined if there is any movement of the walls, cracks, etc. and 

to establish a rate of movement. Monitoring data should include the current condition of the feature, any 

measurements, the person conducting the monitoring, time of reading(s), weather conditions such as temperature and sunny/cloudy/etc. and any unusual weather conditions or events prior to the time of monitoring such as recent storms and precipitation events or animal activity. This will also help to identify any rate 

of change and may help to identify causes of any movement noted. If aggravated conditions occur, comparisons should occur in more frequent intervals, such as after significant rainfall or after heavy snowfall 

or extended period of freezing weather. Photography should be used to aid in locating monitoring points. 

In large complex sites, GPS may be used. If no movement or change is noted after one year of monitoring 

for severe threats or if the initial threats are classified as moderate, monitoring should be conducted on a 

quarterly basis. If the initial threats are low or two years of monitoring severe threats shows no movement, 

or one year of monitoring moderate threats shows no movement, the monitoring should be conducted 

annually. If the data collected indicates a sudden change or increase in movement, the Structural Engineer 

or other qualified professional should be notified immediately and an on site inspection may be necessary 

and/or emergency stabilization measures may be necessary.

Monitoring data and information can be recorded in a tabular format which is typically kept in site files, 

or the information can be recorded in a field notebook kept at the site, in the site file or in an appropriate 

location. It is important to note that the monitoring data should be kept in a location that it can be easily retrieved and the site and location of monitoring points can be reestablished as needed. Copies of the 

monitoring data should be provided to the VT Structural Engineer quarterly or annually and a copy should 

be kept in the site file at the park. The monitoring forms, locations and schedule are often designed with the 

assistance of the structural engineer or architectural conservator. They should be designed with the user in 

mind, who is most likely to be unskilled in structural evaluations. Therefore the form and process should 

be user-friendly and accomplished in a brief site visit.

In many cases, this information is recorded for a few years and set aside for many years. This information 

is important when new site mangers observe conditions at sites as many as 50 years after the monitoring 

points were first established. Duplication of data which is stored at multiple locations aids in long-term 

retrieval.

G.2 Sample Inspection Forms 

Examples of structural evaluations and monitoring programs are available on the VT Intranet site. The 

Structural Engineering Evaluation and Monitoring forms and instructions adapted from Mesa Verde National Park’s Archeological Site Conservation Program are one set of examples available. These forms were 

developed for use in prehistoric archeological stone structures typically found at Mesa Verde National 

Park. They are included as examples of forms that can be modified as needed for use at other Archeological and Historic Sites.

This summary history briefly describes a few of the major trends which have occurred in the field of ruins 

preservation over the course of more than 100 years of activity. Many individuals launched programs, 

adapted to the times and accomplished research and preservation projects. Methods and materials came 

into common use, were modified and adapted or were in some cases abandoned. What knowledge can be 

gained from examining the history of preservation? Can some threads of continuity be realized which can 

inform the present? Since no comprehensive history has been written, this work serves as an introduction 

to the subject with an emphasis on treatment perspective. Hopefully some readers will find comfort in the 

realization that other preservationists have been there before and experienced much the same anguish, 

frustration and challenges that we are facing today. Roads that lead nowhere need not be taken again.

A Brief History of the National Park Service 

Management of Archeological Sites in the Southwest

by Jake Barrow 

with contributions from Jim Trott

June 2008

APPENDIX G
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62 A Brief History of NPS Management of Archeological Sites in the Southwest

Some Beginnings

For more than a hundred years, the United States Federal Government (and, after 1916, the National Park 

Service) has managed and preserved archeological sites in the arid southwest. Historically this preservation has been referred to as “ruins stabilization.” The National Park Service, signed into being by President 

Woodrow Wilson in 1916, inherited the origins and energy which began being devoted to ruins preservation beginning in the nineteenth century. That legacy has continued unbroken since the beginning and 

in 2008 is managed, in part, by the Vanishing Treasures Program within the Intermountain Region of the 

National Park Service. 

Throughout the historical process of ruins preservation, the central mission, whether local or regional, 

have not changed since 1916. The establishing principles of the National Park Service as legislated by Congress provide the organization with a mandate. As written in the 1916 Organic Act establishing the National 

Park Service, it states: “...conserve the scenery and the natural and historic objects and the wild life therein 

and to provide for the enjoyment of the same in such manner and by such means as will leave them unimpaired for the enjoyment of future generations.”

The history of ruins treatment is not recorded in one document nor is there an administrative history of 

the NPS management of archeological sites. The history of this process represents an organic and developing response that has been institutionally dependent on individuals both inside and outside the Service, 

and whose interest and enthusiasm for the subject matter moved the agency through advocacy to action. 

Public advocacy has had a role to play in pushing the agency toward some actions. The National Park Service depends on interrelationships of personnel who often change jobs and move from site to site and often 

move up in the chain of command. Others stay in one place for their entire careers. The organization itself 

grew, changed and sometimes contracted over time in a seemingly cyclical manner in which activities are 

engaged, then abandoned and seemingly forgotten for a time; and then the same energy re-emerges with 

new motivation and new knowledge. Reviewing selected parts of the history informs the present, hopefully 

avoiding reinvention.

There are opportunities for cross-fertilization when personnel move from site to site, while also resulting 

in resistance on the part of old-timers to change to new ideas and new energy. Bottom-up solutions often 

collide with top-down policy and direction and, as is typical in construction practice, the ideas and methods of craftsmen and craftswomen often are at odds with those of the architects or more highly educated 

archeologists and managers. Site-specific solutions emerge in which continuity begins to unfold over time. 

Due to the nature of this give-and-take process, the continuity appears to break when a new direction 

or approach is taken. But the overall continuity continues so long as the agency stays alive and its mission 

remains valid. Ultimately the fervor for this mission by the individuals making up the organization will 

determine the viability of the agency to meet its goals. 

It can be said that archeological activity started in the Southwest when the United States Army of conquest 

began exploring in earnest during the middle of the 19th century. Sites such as Chaco, Montezuma Castle 

and Hovenweep were put on the map and interest in those places took hold. Concurrent with the early 

interest and archeological activity during the later half of the century, there existed a trend of interest in 

antiquities throughout the western world. Pot hunting and relic collecting was a major part of the activity. 

The interest also encompassed an academic aspect in which deeper understanding of history was sought 

through direct contact with archeological and architectural remains of the past. Sometimes this included 

a romantic view toward ruins in which the remains were to be regarded as almost mythical or magical 

elements of former and sometimes lost times. This interest is clearly evident in the late renaissance recognition shown toward the Greco-Roman antiquities which first came to light in the seventeenth and eighteenth centuries in Europe, but gained in renown with the Napoleanic conquest of Egypt in 1798 and the 

resultant discovery and romanticism of ruins. 

In addition to the romantic aspect, there was a significant educational aspect to the interest in antiquities. 

Authenticity of a ruin’s site played a significant role as educated scholars visited them to better understand 
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A Brief History of NPS Management of Archeological Sites in the Southwest 63

the values, messages and information inherent in ancient fabric in order to better understand the past. The 

fundamental drive in this interest is for the individual to directly experience aspects of the past without the 

lenses of manipulated history provided by others. Deeper and deeper understanding of the behavior of the 

inhabitants of these places becomes possible and the anthropological record is informed. Following this 

objective is the desire to preserve such sites unimpaired for the future. 

As the nineteenth century closed and twentieth century unfolded, archaeological activity in the United 

States had become popular. Eastern institutions of higher learning and museums sent archaeologists into 

the Southwest to expand their knowledge of its history. The Bureau of American Ethnology in the Smithsonian Institution and the Archeological Institute of America (AIA) sponsored many of the activities. The 

National Geographic Society participated. Cultures were identified, time periods delineated, ethnography 

introduced, professional meetings convened and development of archaeological sites for research and public use were generally established. All these activities influenced the National Park Service. 

In 1880, Adolf Bandelier made his first trip representing the AIA to Pecos, New Mexico. Over the next few 

years, he visited and wrote about many sites in the Southwest which popularized the potential for exploitation. Charles Lummis was not far behind, photographing many sites for the first time. Edgar Lee Hewett, 

gifted and armed with unlimited energy and enthusiasm for the subject matter, left a huge legacy. Jesse Walter Fewkes played an important role which became somewhat controversial at the end of his career. Later, 

noted archaeologists such as Neil Judd, Earl Morris and Alfred Kidder, among others, engaged in excavations at select sites at Chaco, Aztec and Pecos. Generally Federal and State employees such as Fewkes applied some stabilization to ruins, whereas those from academia and other institutions did no stabilization. 

Morris was an exception. They all accomplished varying levels of recording and documentation.

Eventually the early National Park Service archeologists and those following them became intimately 

involved in stabilization as the founding mandate served to remind those in the field of their preservation 

agenda. These activities constitute the origins of the preservation and presentation of archeological sites 

in the Southwest. Archeology as a discipline emerged and grew right along with the growth of the new 

National Park Service Agency. In addition to the archeologists, the early managers and ethnologists were 

involved as well, thus creating the multi-layered and diverse approach to archeological site management. 

S.J. Holsinger, his protégé Frank Pinkley and Jesse Nusbaum imparted much influence. From this point, 

there evolved repetition, new directions, refinements and technological advancements over the new century. Pinkley began his career in 1900 at Casa Grande and would manage NPS efforts for the next 40 years, 

while Nusbaum began in 1909 with the Museum of New Mexico and its preservation of the Palace of the 

Governors (Santa Fe) and ended as the Superintendent of Mesa Verde in the 1940s. They would greatly 

impact early preservation in the Southwest. 

Places Become Parks, People and Projects:

Casa Grande and the Rise of Frank ‘Boss’ Pinkley

Archeological site management in the United States began at the Casa Grande Ruins National Monument 

located in south-central Arizona in 1889.* In that year, Senator George F. Hoar of Massachusetts succeeded in getting an appropriation and a declaration of a reservation for Casa Grande attached to the US 

Geological Survey budget which stated:

Repair of the ruin of Casa Grande, Arizona: to enable the Secretary of Interior to repair and protect the 

ruin of Casa Grande, situated in Pinal County near Florence, Arizona, two thousand dollars; and the Presi-

*Although a year before, in 1888, Richard Wetherill’s sighting of Cliff Palace from the mesa top served as a starting 

point for the most major pre-Columbian program of archeological site management in North America at Mesa Verde, 

it would be years before stabilization work actually occurred there. Likewise, in 1896, Edgar Lee Hewett was conducting field research on the Pajarito Plateau following in the footsteps of Bandelier. No stabilization was done. In any 

case, Mesa Verde does have the distinction of being the first National Park designated for its archeological values. Mesa 

Verde remains the only archeological area with that designation. 
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64 A Brief History of NPS Management of Archeological Sites in the Southwest

dent is authorized to reserve from settlement and sale the land on which said ruin is situated and so much 

of the public land adjacent thereto as in his judgment may be necessary for the protection of said ruin and 

of the ancient city of which it is a part. 

Casa Grande is a three-story elevated puddled earth structure (sometimes the filled base level is referred to 

as a floor level, thus a reference to a four-story structure) constructed by the Hohokam culture who thrived 

in the area from around 550 AD to 1450 AD. Casa Grande was built circa A. D. 1200s and abandoned in 

circa A.D. 1400s. 

Jesuit Priest Eusabio Kino was leading a missionary movement in the Sonoran desert when he saw the 

Casa Grande in 1694, placing it on the map as a destination. In 1879, Professor George Cook, a geologist, 

initiated what were the first scientific examinations of the remarkable structure. While his reports were not 

accessed for this history, the fact that a geologist was sent indicates the recognition that something about 

the soils of the architecture were remarkable and needed evaluation. An earthen building standing without 

a roof or maintenance for hundreds of years was remarkable by any standards. Recognition of the unique 

qualities of the structure as well as its important history resulted in the 1889 authorization to have it saved 

as a Federal Reservation. This act put it under the jurisdiction of the General Land Office (GLO) in the 

Department of the Interior. (The GLO was a precursor of the Bureau of Land Management.) Casa Grande 

later was legislatively proclaimed in 1892, and re-designated in 1918 as a National Monument when it came 

into the managerial jurisdiction of the newly-created NPS. 

This ruins treatment program at Casa Grande began in earnest in 1891 when federal funds launched a stabilization project to correct basal erosion, install bracing (probably seismic restraint) and plan for a protective shelter which eventually was constructed in 1903. A major earthquake occurred in Northern Sonora, 

Mexico in 1887 which heavily affected southern Arizona. While it is not precisely documented, damage is 

likely to have occurred to sections of the free-standing walls. Pre-1887 photos showing sections of walls 

that do not appear in photos taken post earthquake lend credence to this supposition. 

Florence, Arizona resident Rev. Isaac T. Whittemore advocated for site preservation in 1889 which resulted 

in a site visit by the Santa Fe General Land Office Representative Alexander Morrison. They met on-site 

and Whittemore, who had some construction experience, convinced Morrison to address suggested preservation issues including discussion of roofing, underpinning and vandalism. These two men developed an 

agenda for preservation that initially was rejected as too expensive by authorities. Very soon, though, Anthropologist Victor Mindeleff of the Smithsonian Institution’s Bureau of American Ethnology was engaged 

to travel out to Casa Grande to survey the ruins and recommend repairs in response to the earlier request. 

The Smithsonian, through this Bureau, played a continuing role in the management of archeological sites 

well into the twentieth century. 

With the earlier input of Morrison and Whittemore in hand, Mindeleff prepared what is considered the 

first ruins stabilization scope of work to be applied in the US. He specified six objectives: 

1. protective fencing 

2. a site management custodian 

2. site cleaning, underpinning basal erosion 

4. capping

5. reinforcing walls 

6. a sheltering roof plan 

It is interesting to note that archeological evaluation or research was not a part of the program at this point. 

Nor does documentation figure into the picture. Over the next few years as funds became available the

scope was largely achieved. It took a little longer to realize the shelter. This scope embodies fundamental 

preservation concepts for the preservation of earthen structures: the need to protect sites from vandals, a 

system to manage the site and thus provide monitoring, addressing basal erosion which is always present 

in earthen ruins which are normally set close to the ground, capping fragile wall tops which is a requirement in all exposed ruins masonry whether earthen or stone, reinforcing un-reinforced masonry walls 

that have been compromised by the loss of lateral restraints provided by roofing structures and, finally, the 
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A Brief History of NPS Management of Archeological Sites in the Southwest 65

more controversial but also the most effective preservation measure, sheltering. Sheltering the Casa Grande 

has come with a price, as it has caused a major impact on the site; still, it can not be denied that the shelter 

provides a significant amount of benign protection. 

In 1889, Whittemore, although unpaid, was named the first custodian, . This fact demonstrated his personal enthusiasm behind the initial effort. The idea of a site custodian eventually morphed into that of park 

Superintendent. As sole site employee, the early custodians had a job description which encompassed 

everything. In 1892, under Presidential proclamation, the site was made a reservation and therefore Whittemore was empowered by the Secretary of Interior to use the authority of the United States Government 

to protect the Casa Grande site. So it was under his jurisdiction that the first preservation work was accomplished. In the execution of the scope, some 

of the work was invasive. The treatment for basal 

erosion amounted to clearing debris from the 

base of walls, preparing the puddled earth surface and installing a brick veneer set in Portland 

cement mortar. Later this unsightly intervention was stuccoed over to achieve some visual 

compatibility. Portland cement, a product of the 

industrialization of building materials, had only 

been available for little more than a decade at this 

time. Strong, quick-setting, fairly easy to work 

with, Portland cement must have seemed like a 

cure-all and wonder product to stabilize the base 

of the Casa Grande. 

H. B. Mayo succeeded Whittemore in 1899 and continued to advocate for the ruin, specifically for a shelter. His tenure was very brief, for in 1901 Frank Pinkley took over as custodian. Pinkley had no training, 

background or experience in this work. He was twenty-years-old had graduated from high school and had 

worked in a jewelry store. He was sent to Arizona for his tuberculosis. Coincidentally, his uncle was the 

GLO commissioner for Arizona and he offered his nephew a job to watch over the site. Pinkley wasted no 

time in assuming a measure of control and asserting himself. By 1902, he was disputing earlier recommendations to the central office regarding the need for fencing and the idea of a shelter. Under the jurisdiction 

of the GLO, Special Agent S.J. Holsinger made visits to Casa Grande. Holsinger had significant influence 

over Pinkley and shifted stabilization work to a more materially compatible approach in contrast to the initial work (basal repair of brick laid in cement mortar) which was visually and materially incompatible with 

the character of the ruin. Rather than using brick and cement stuccos as were used in the first stabilization 

effort, he required that original materials be sought and applied for stabilization. He tested materials made 

from debris piles for crack filling. He also discovered the strata of soil from which the original caliche-rich 

soils used by the natives in construction originated, several feet below the surface. Holsinger designed 

the first shelter. He succeeded in convincing 

Pinkley of the value of a shelter, and then went 

on to have considerable influence over the development of archeological sites and resources 

around the Southwest. 

Thus, in this early management sequence, 

actions taken resulted in later reevaluation of 

treatments seeking more compatibility and 

integrity of material use, as well as the benign 

influence of the shelter. At this early date, the 

dialogue about treatment methodology had 

emerged with the emphasis on maintaining the 

character of the resource. Pinkley had been opposed to the shelter, in part due to the considerCasa Grande after initial basal stabilization

First shelter over Casa Grande 
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66 A Brief History of NPS Management of Archeological Sites in the Southwest

ation of the landscape. Quite simply, fabric erosion as a result of some heavy rains he witnessed convinced 

him of the long-term viability of sheltering. Considering that the Casa Grande had stood for hundreds of 

years unprotected, the argument for sheltering needed strong justification. While the exact record of argument is unavailable, the proponents prevailed and it was erected in 1903. In 1932, the original barn-like 

structure which had greatly deteriorated after 30 years was replaced by the current shelter. The new shelter, 

highly engineered and built of large steel posts to lift the roof high over the ruin, has always been somewhat 

controversial. Regardless, a significant amount of the structural and material conservation over the longterm has been realized.

Meanwhile, preservation techniques continued to evolve. Jesse Walter Fewkes, ethnographer/archeologist of the Smithsonian’s Bureau of American Ethnology, arrived at Casa Grande in 1907 to lead efforts to 

conduct excavations and make repairs and recommendations. Once the shelter had been constructed, the 

focus at Casa Grande went to archeology and sites surrounding the “Big House.” Reports indicate that 

Fewkes was sent to Casa Grande in response to Pinkley’s approach at managing the site, which reflected a 

somewhat unscientific attitude of engaging in overzealous excavations. Pinkley did something we would 

now call pot hunting in order to get the artifacts out on display for visitors. This sort of activity continued 

well into the twentieth century. It seems that by this time, the GLO felt the need to seek professional expertise rather than to rely solely on the uneducated but enthusiastic Pinkley. Fewkes embodied the recognition of the need to apply professionalism in archeological site management on the heels of the passage of 

the 1906 Antiquities Act. At the time Fewkes arrived on-site, he may have had little experience with ruins 

preservation but perhaps more an educated inclination from his time documenting the living Hopi and 

Zuni tribes a few years before. Quite simply, at that time, there weren’t many opportunities to gain experience in archeological research or ruins preservation work in the United States. In the course of his work, 

Fewkes made the decision to expose more ruins and make them available for interpretation, ironically, 

since Pinkley’s zeal went in the same direction. Quickly Fewkes pushed for an expanding archaeological 

knowledge base by re-examining old excavations and conducting new ones. He stipulated that the sites 

should be prepared for public visitation “...by applying simple stabilization procedures.”

Unfortunately, not much can be said to shed light on what he meant by this statement. Records indicate 

that Fewkes was using cement to stabilize low walls. Perhaps the authority on-site became confusing since 

Fewkes worked for the Smithsonian and Pinkley for the General Land Office. Fewkes’ tenure at Casa 

Grande marks the separation of duties based on discipline since he was interacting with the resources 

while Pinkley began to take on more of an administrative role.

Fewkes’ treatments were seen as somewhat temporal by Pinkley, who in his annual report to the GLO of 

1910, wrote of his concern about the exposed ruins “...from which there seems no practical method to 

protect the greater part of them”.

Pinkley became less than enthusiastic about the excavation activities which left ruins exposed and the lack 

of any funding to do anything to protect them. Records of the time indicate an emerging focus on park 

infrastructure such as visitor services and less about the resource preservation of the earlier period. Clearly 

Pinkley had changed his opinions during and following the Fewkes period and came to realize some of the 

gravity of the preservation problems he faced. Being the site steward rather than the visiting archeologist 

contributed to his growth toward a deeper appreciation for the complexity of his responsibility. Pinkley 

came of age during this experience at Casa Grande. He was learning on the job how to manage a site, including visitor services’ aspects such as interpretation, museum management, advocacy, funding requests, 

planning and preservation. Much of the early work remains visible at Casa Grande as sheltering has afforded the structure a slower rate of change and thus a less invasive preservation approach over time. 

Antiquities Act and Expansion- Pinkley Goes to Tumacacori

The passage of the Antiquities Act in 1906 had an enormous impact on the management of archeological sites. Fundamentally an act to protect sites from looting, it also gave the power to the President of the 

United States to proclaim National Monuments. This resulted in many sites of compelling importance to 

be proclaimed and thus fall under the protection of the federal government. Edgar Lee Hewett had been 

an instrumental force in propelling the Act forward. Concurrently, funding from private institutions such 
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A Brief History of NPS Management of Archeological Sites in the Southwest 67

as the Carnegie Institute, the Peabody Foundation and the American Museum of Natural History for major 

archeological excavations of sites within park areas or areas which later became national monuments or 

parks was increasing. The Antiquities Act marked a fundamental benchmark in the way cultural resources 

were to be valued and managed in America. Within a decade, sixteen major Southwest areas were declared 

National Monuments.

In 1916, the National Park Service was established and sites previously under the GLO began to be transferred over to the new agency. Soon Pinkley picked up new responsibilities as manager of the new Southwestern National Monuments. Even though his job slowly developed to encompass many parks in a multistate region, he never moved his headquarters away from Coolidge and the Casa Grande.

The Tumacacori Mission is located 113 miles south of Casa Grande and was proclaimed a National Monument in 1908 under the Antiquities Act authority. In 1918, it was added to the young National Park System. 

The first mission at what is now Tumacacori NHP was part of the Kino Mission system of the Sonoran 

desert which was first established at the Pima village of the same name in 1691. ‘Boss’ Pinkley was put in 

charge of the new park site and he wasted no time in planning preservation activities to reverse long standing deterioration. By 1921, he began the reconstruction of the Mission Church roof which had collapsed 

some years before. Open to the elements, much of the decorated interior 

was compromised by the lack of a 

roof. The walls of the Mission were 

built of adobe block and the interior 

walls were plastered and decorated, 

typical of Spanish mission construction throughout the New World. This 

project was not a shelter as in the Casa 

Grande case but a reconstruction of the 

collapsed original roof. The philosophical discussion is not available but the 

project stands as a testament to partial 

reconstruction in order to preserve 

architectural fabric which otherwise 

would surely have been compromised 

and most likely lost should the roof not 

have been constructed. Having the 

roof to protect the interior surfaces set 

the stage for the many years of conservation-focused treatments which have occurred on the site. While the 

roof protected the interior, many exterior elements on the Mission and nearby structures remained at risk. 

In 1922, Pinkley is credited with acquiring the first ever grant of monies secured from the State when he 

received $1,000 from Arizona for repairs there.

A clue to Pinkley’s evolving philosophy may be seen in his reconstruction of the bell tower stairway at Tumacacori. He is reported to have made the new work look old with a somewhat ruined appearance. Philosophical arguments about distinguishing new work from the original had not yet evolved and made their 

way into Pinkley’s thinking. Also this work and the reconstruction of the roof may have been somehow a 

result of his feelings about the solution at Casa Grande, which he initially opposed. 

The Park Service may have gotten off to a slow start but by 1923, developments were moving much faster. 

Pinkley was appointed first Superintendent of the Southwestern National Monuments which was established to include twelve monuments: Casa Grande, Tumacacori, El Morro, Montezuma Castle, Petrified 

Forest, Chaco, Navajo, Grand Quivira, Hovenweep, Pipe Springs, Wupatki and Aztec. It grew quickly. In 

support of the idea of creating Southwestern National Monuments, NPS Director Mather wrote in favor of

“...[the] idea of unifying the monuments work and passing the problems from the various monuments up 

to a local man who would be in touch with local conditions, thus relieving the already overcrowded Washington office of some of the work which could be better understood and more economically handled from 

a field headquarters....”

Tumacacori Mission Church before stabilization
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68 A Brief History of NPS Management of Archeological Sites in the Southwest

This amounts to a very nice way of saying that the Washington Office really didn’t want to be saddled with 

these resources and all their difficult problems. Funding was very meager, if at all, as systems for project 

identification and financial requests were primitive and simplistic. Washington had a focus toward the big 

natural parks and only when Depression-era programs got underway did some major funding become 

available for the ruins. Some of these Monuments were pretty hard to get to, as roads were not paved and 

the sites were located at remote locations.

In any case, 1924 marks the year that archeological site management including ruins preservation became 

a recognized activity in the NPS, even if it only meant that a small group who were on salary attended to 

it. Pinkley can be credited with establishing this concept administratively and with professionalizing the 

site custodians, who came to revere the “Boss,” as Pinkley became known. His monthly reports provide a 

direct view into these times and the focus on visitor services and the growing tourism interest was clearly 

an effort to attract attention in Washington. The reports reflect Pinkley’s realization that if he were to get 

attention from Washington, it would be because visitors were coming to these parks. He focused heavily on 

reporting about visitors. At this point, archeological research was still being conducted by outside institutions who did not engage in stabilization activities. 

A Ruins Triangle- Mesa Verde, Aztec and Chaco

The stabilization efforts at these three parks characterize some preservation trends and developments from 

the early part of the century through WWII. Resources at these three sites were constructed of stone and 

the earth and this required some different approaches than those applied to strictly earthen sites such as 

Tumacacori and Casa Grande.

Since the Wetherill family “discovered” Mesa Verde, made collections from the ruins and provided tours 

to visit the cliff dwellings, it has only grown in popularity. In 1891, Gustaf Nordenskiold, a Swede who 

was assisted by Wetherill in getting access to the site, was one of the first archeologists to excavate at Mesa 

Verde. Before the time of autos and roads, these visits and activities were done on horseback, living in very 

primitive camps in Wild West-style. Having excavated at Cliff Palace, Nordenskiold packed his collections 

out of the site and took them to Helsinki, Finland. It was not easily accomplished logistically or politically, 

as many protested. They are held there today in a very modest and hard-to-find State Museum with a small 

selected collection of the artifacts on display. Some 

burial remains and funerary objects are a part of this 

collection but they are not displayed. This removal led 

to a public outcry against allowing collections to be 

taken outside of the United States. Ultimately public 

sentiment over this issue and similar cases elsewhere 

led to the passage of the Antiquities Act in 1906. It also 

led to the 1906 creation of Mesa Verde National Park. 

On a positive note, Nordenskiold is credited with accomplishing a very scientific excavation which established methods of analysis which had heretofore not 

been practiced. 

Recognition of the effects of the various excavations at 

Mesa Verde led Jesse Fewkes to depart Case Grande 

in 1908 for Mesa Verde to excavate and stabilize ruins 

there. This represented a return trip for him since he 

had conducted surveys there a few years earlier. Hewett 

advocated for Fewkes to come to Mesa Verde based on 

his reputation and accomplishments at Casa Grande. 

Under his direction, the Smithsonian Institution’s Bureau of American Ethnology initiated a comprehensive excavation program for the major sites in the park. So long as the ruins had been left in a natural, 

Nordenskiold relaxing at Mesa Verde
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though slowly-collapsing state, they were in apparent stable condition but the uncontrolled excavations of 

previous years seriously undermined the stability of many walls. Fewke’s task was to reverse this trend of 

digging up sites without considering the preservation and presentation . He first focused on Spruce Tree 

House. His primary motivation was his view that sites held interpretive potential. He wanted to educate 

the public. Pinkley’s realization that public access and tourism were key to gaining attention and resources, 

was also influencing Fewkes.

More or less simultaneously, Dr. Edgar Lee Hewett was beginning to engage university students through 

the Archeological Institute of America to “...pursue studies among the ruins of Mesa Verde...”

This is likely the first field school activity to take place in an archeological site in America. The partnership 

with academic institutions and the value of that partnership had beginnings here and, even with interruptions, this important activity has been sustained from that moment to the present.

Fewkes was the first to systematize any kind of repairs. Repair work, according to him, was a delicate task 

seeking to preserve the original character of the ruin as far as possible, using earthen or soil cement (possibly the first use). Repair, not restoration, was the goal and prevention of further disintegration guided the 

work rather than reconstruction. Stated goals of authenticity of the resource were seen as more valid than 

reconstructing lost wall sections for interpretation. Even so, while pursuing 

his repair agenda, he was equally well-known for advocating for the visitor 

experience. At times, sections of ruins had to be reconstructed to preserve 

the remainder and clarify the context. Fewkes had noble intentions but history has not judged all of his activities positively as it appears that his stated 

objectives were not always realized in the physical manifestations of the 

treatment. When he arrived to work on Cliff Palace, the same philosophical approach applied at Spruce Tree House and Casa Grande was taken, just 

up-scaled to respond to the large size of the site. The terraced face presented 

some problems which in some cases required the rebuilding of those walls. It 

doesn’t seem that Fewkes had any reservations about using Portland cement: 

“To permanently protect these sections of the ruin, the top of walls and 

plazas were liberally covered with Portland cement, and runaways were constructed to carry off the surface water into gutters by which it was diverted 

over the retaining walls...” he wrote.

On exposed mesa-top sites, Fewkes introduced Portland cement into capping to stabilize wall tops and get the water to run off. While this may have 

helped the wall tops, it didn’t help with the depressions of the kivas and drainage. Recognition of the problem of differential levels such as kiva floors which 

could catch and contain water could only be theoretically resolved with shelter construction. It would be 

many years before shelters appeared on the mesa top sites. Backfilling would not have been considered 

since opening sites to visitors was paramount in the minds of archeologists. In characterizing the problems 

and as justification, Fewkes recorded some notes which also indicate some specific and troubling aspects of 

his work related to the complexity of the wall caps:

Water from the melting snow was particularly damaging, since it percolated between the 

facings and the core of the wall, and subsequently froze, forcing the facing of the wall away 

from the central core until it fell. In order to prevent the water from melting snow from penetrating the walls, or the rain from percolating between the core of the wall and its facing, 

I placed a cap of cement on the top of all the walls. The inner facing of the outer walls, as a 

rule, stood a few courses of stone higher than the outer, and it was necessary to add masonry 

to bring the outer wall to the level of the core and inner facing. Having leveled the top of the 

wall, I covered it with small, angular fragments of stone, placing these fragments highest in 

the middle or over the core. Over this roof-like covering was spread a thick layer of adobe. 

The top of the wall was thus made in a way to shed water. Over this roof of adobe was spread 

Fewkes’ wall capping
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70 A Brief History of NPS Management of Archeological Sites in the Southwest

a layer of Portland cement, 2 inches thick, mixed in proportion of 1 to 5, care being taken to 

use this cement freely in pointing the joints in the facing of the wall in order to prevent the 

entrance of water in the cracks. The roof shape of this covering or the fact that it is highest in 

the middle will shed the water and throw it away from the wall without harm.

This crown-shaped gutter capping of soil cement which he had applied to tops of walls must have had a 

striking appearance. Most of this – probably all – has been removed at Mesa Verde, replaced over the years 

with more compatibly visual masonry which is achieved by setting stones close together, unevenly, so that 

water flows off in various ways. Some of the setting mortars he used beneath the cap to stabilize the top 

section of wall are likely still in place. This reference may entitle Fewkes to be the father of soil cement 

which has seen continued and widespread use at many sites. The strong and visually incompatible capping 

treatment likely contributed to some peer criticism of Fewkes.

By 1910, Fewkes had moved onto sites in recently established Navajo National Monument. It seems as if 

Fewkes was the first traveling itinerant ruins treatment expert. Meanwhile funds were available to work at 

Balcony House in Mesa Verde. Fewkes, busy elsewhere, was unavailable. Edgar Hewett and Jesse Nusbaum 

made a preliminary study of the conditions of Balcony House. 

Fewkes was not far away and not gone long. Over the following years, he reappeared at Mesa Verde many 

times. He is credited with starting the fireside chats, the interpretive story-telling to visitors to the parks sitting around an open fire. It’s apparent he had much to say and his various activities and attitudes eventually 

collided with management. In 1923, Acting NPS Director Cammerer wrote, “We’ve got to keep the doctor 

out of the Mesa Verde because he is impossible. He is approaching senility, and his petty meanness and 

professional jealousy creates an intolerable situation. I think we should speak to Dr. Walcott and ask him to 

forbid Dr. Fewkes going into the Mesa.”

In order to ensure that Fewkes would be precluded from work, Cammerer allotted funds to be managed by 

Jessie Nusbaum for stabilization work. Fewkes was finished by 1923. Mesa Verde’s popularity as a tourist 

attraction had increased rapidly. Cliff Palace, Balcony House and Square Tower were to some extent stabilized and open to the public. A new era was marshaled in under the direction of Nusbaum, an archeologist 

by training, who was appointed Superintendent in 1921.

Hewett, who had first advocated for Fewkes, seems to have developed a disdain for the somewhat heavyhanded restorations he was doing over the years. He, along with Judd, were two archeologists who influenced the development of Mesa Verde and Chaco respectively, realizing properly preserved ruins are of 

interest to the public. Hewett is quoted as saying 

that ruins should be preserved as ruins, “...not as 

ghastly restoration...”

One can’t help but wonder if Hewett was reacting 

belatedly to some of Fewkes’ work. Hewett taught 

students in his field schools that demolition for archeological purposes should be avoided, minimal 

intervention should be used to stabilize them and 

to do only what is absolutely necessary for preservation. He focused on masonry details to preserve 

character and suggested models instead of reconstructions. In his 1921 article in Art and Archeology, he photographically compared Chacoan 

masonry to that of Peruvian sites and many in the 

Mediterranean basin. The issues of the Southwest 

have similarity to other sites internationally. These 

discussions suggest that treatments thought by one professional to be compatible and interpretable were 

seen by another to be completely wrong. The strong language used criticizing Fewkes and the Director’s 

Fewkes with an artifact collection
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admonition indicates the seriousness which the issue of ruins stabilization began to be taken.

One important aspect of stabilization at Mesa Verde is the fact that cliff sites are inherently protected to 

some degree and this has provided for a level of benign protection that open sites such as those on the 

mesa tops or on open terrain such as at Chaco and Aztec don’t have. Often the slopes at the front of cliff 

sites present the most serious problems. 

Also during this time period, an important discovery was made and activity initiated which has had extensive implications for Southwest archeology and indirectly, stabilization. Dr. A. E. Douglas, leader of the National Geographic tree-ring expeditions of the 1920s, established an unbroken tree-ring chronology dating 

before the year 700 A. D. to modern times in Mesa Verde. That work has continued at other southwest 

parks including Gila, Wupatki, Walnut Canyon, Tonto, Chaco, Natural Bridges, Aztec, Pecos and Salinas.

This work has provided research archeologists and preservationists with scientific evidence to date wood 

in structures and thereby date the structures 

Through the influence of Edgar Hewett, Earl Morris, a New Mexico boy who had pot hunted with his 

father as a child, received an education, and entered onto the archeology scene at Aztec in 1916. During 

1916-1922, while employed by the Museum of Natural History (Smithsonian), he was in charge of excavations and stewardship at the site. Over the course of these years and succeeding ones, he recognized the 

huge burden caused by excavations without consideration of stabilization. Eventually he was forced to 

divert manpower and funds to repair, rather than to excavate. His tenure and influence characterize more 

than two decades of developments. His initial feelings from early experiences on site were somewhat naïve 

and optimistic as he wrote in 1917, “The portions excavated show less deterioration than was to be anticipated, and it seems that a capping of cement will make the walls relatively permanent...”

Applying a cement cap and relying on that to preserve a wall would prove insufficient. His early optimism 

was replaced by a stunning realization of the fragility of the exposed ruins. Very soon, Morris’s workers 

were dismantling and re-laying portions of the sandstone block veneer of many of the less stable walls 

at Aztec using Portland cement for mortar. He was certainly not adverse to the use of modern materials. 

In 1918, he purchased an entire boxcar of cement, attesting to his understanding of the severe need to 

stabilize the ruin as well as his reliance on cement. The early use of cement and concrete was widespread at 

Aztec, which also included the construction of concrete slabs over pre-historic roofs. It would continue for 

many years here as well as other sites throughout the region. Interestingly, several caps which resemble the 

descriptions of Fewkes-style caps still exist on several walls at Aztec.

The use of cement seemed to fit a philosophy of allowing for the application of new materials so repairs 

would be recognizable. At this time many felt that a distinction between old and new work was desirable 

for the sake of authenticity. In a dialogue between himself and Boss Pinkley, Morris is reported to have 

stated, “If the coloring is made too close to the original earth mortar, many will not be able to distinguish 

between the work of the aboriginal and that of the modern masons. On the contrary the use of natural 

colored cement would create a condition that could not fail to be understood by anyone with sufficient 

intelligence to wonder about it.”

Morris’s report in 1918 to the American Museum recounted some details of the repair activity:

For the most part, the walls were in bad condition, hence a considerable proportion of the 

season’s activities consisted of patching those that threatened to collapse, and of rebuilding those that had fallen. As a final protection against the elements, the tops of the walls of 

the east wing, and those of north wing as far as they have been exposed, were capped with 

from one to three courses of stone laid in cement, the total area of wall surface so treated 

amounting approximately to 7500 square feet. By way of summary of the three years’ work 

[1916-1918], the walls of the east wing and one half of the north wing have undergone the 

ultimate stages of repair.”
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72 A Brief History of NPS Management of Archeological Sites in the Southwest

A significant change occurred administratively in 1923 when Morris was hired by the NPS to serve as first 

custodian of the newly-created Aztec National Monument. He served in this capacity until 1927. In an elite 

club with Nusbaum, he became the second professional archeologist to be hired into the Service to both 

manage and undertake stewardship of ruins. Instead of a reliance only on external institutions to conduct 

archeological excavations, the NPS was beginning to internalize the functions by hiring these experts into 

the NPS. Site preservation was expected and thus coupled with the archeological excavations. Could Boss 

Pinkley have had something to do with this development? 

Southwest archeologists, whether in the NPS or outside, had their own agenda. In 1927, led by Alfred Kidder, many of these archeologists got together for a conference at Pecos to discuss, compare and sort their 

discoveries. From these annual meetings, archeologists have been able to clarify and classify the many 

architectural, masonry, pottery and artifact findings into an evolving historically-relevant record. These 

conferences have continued uninterrupted ever since and continually enliven the never-ending debates 

focusing on anthropological research realized through the painstaking analysis of the contemporary archeologist. While these meetings have been invaluable to anthropologists, ruins stabilization has never had a 

place at this table for the seven decades they have been held. 

In 1933, an advanced program of repair and protection was prepared for Aztec Ruins; Morris, who had left 

his custodian post at Aztec in 1927 for a position with the Carnegie Institute serving as field archeologist, 

was asked to return to supervise the work. 

Morris led a move to make excavation and repair more formalized. Since so much early work had been 

done in prior years that was not well documented, a change was in order. It was agreed by those connected 

with the 1934 project that in excavation and repairs, there should be a satisfactory record to establish the 

identity of every ancient detail before any work could proceed. Photography was to be integral part of this 

documentation goal. Distinguishing between ancient original work and some repairs was impossible while 

in other cases repairs were too easily distinguishable and incompatible with the surrounding historic material. Apparently a considerable amount of time was spent in Cliff Palace distinguishing between ancient and 

rebuilt walls and this would be unnecessary in future unexplored sites if this policy were rigidly adhered to. 

The realization of the value of documentation may have been born at this time and over the ensuing years 

documentation approaches have only grown in complexity and variety. While few agree as to the type and 

method of documentation, no one disputes its ultimate value. 

Morris’s work during this period served as something of a model for future excavating, repairing and 

rebuilding. The philosophy applied could best be described as the belief that while the repair work should 

be as nearly like the original as possible, it would be the practice to distinguish the ancient from the rebuilt 

in some manner, perhaps no more evident than a slight discoloration of the mortar joints. The 1931 Athens 

Charter (an International Charter defining guidelines for the treatment of cultural patrimony) takes up this 

point: “In the case of ruins, scrupulous conservation is necessary, and steps should be taken to reinstate 

any original fragments that may be recovered (anastylosis), whenever this is possible; the new materials 

used for this purpose should in all cases be recognizable.”

Morris and associates probably knew of the Athens Charter. (See Appendix M: The Athens Charter for the 

Restoration of Historic Monuments, Adopted at the First International Congress of Architects and Technicians of Historic Monuments, Athens 1931 as an outgrowth of the International Museums Office of the 

League of Nations.)

Meanwhile, back in the administrative offices of SW Monuments, Pinkley was increasingly aware of the 

mounting difficulties in maintaining the many prehistoric sites in the Southwest. Beyond the daily management needs, he also sought the first of what was to become a succession of engineering studies for means of 

preserving fragile walls. As he explained in 1933 to the director of the National Park Service, “This whole 

situation of the repairs to ruins has been almost unbearable. We have been in a situation of a half dozen 

men trying to put out a forest fire...wherever we were and however hard we worked with what we had, we 

knew Nature was getting ahead of us someplace else.”
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In 1933, James B. Hamilton, assistant engineer from the National Park Service’s field headquarters in San 

Francisco, was sent to Aztec to evaluate the precise condition of the ruins from a professional point of view 

and to work out methods that could be taken to keep them from reverting into rubble heaps. He wrote, 

“At Aztec Ruins National Monument, much work should be done soon to prevent deterioration which is 

progressing rapidly there.”

Hamilton recognized quickly the major forces at work, including standing water in some rooms and the 

effect it had on the relatively soft sandstone. He recognized rising damp as well as wall top vulnerabilities 

and also the effects of freeze/thaw cycling. By this time, the early cement caps installed by Morris were 

deteriorating and allowing water to infiltrate walls through cracking of the interface between the rock and 

the cement mortar. Some of the concrete-slab, secondary roofs placed over rooms with intact ceilings had 

cracked open, letting water reach the perishable ceilings below. Hamilton offered many recommendations, 

accompanied by engineering drawings, for further monitoring of destructive forces and upgrading means 

for dealing with them.

He recognized the impact of the irrigation system nearby and potentially negative effects of the ground 

water which moved beneath the surface creating a saturated subsurface. He recommended test pits; if 

they proved conclusive, diversion methods should be undertaken. He went further to recommend a new 

wall cap design using stone on the top provided with expansion joints to replace the solid cement-based 

mortars. He recommended the use of tar paper in conjunction with masonry to prevent water entry; the 

use of dry barrels to collect water in low areas was included in his recommendations as well as some paving 

options for addressing the issue of concrete roofs. 

Following Hamilton’s ground water recommendations, in 1933 borings and test wells were installed. Wet 

sand was discovered at twelve feet below the surface. The National Bureau of Standards was engaged to 

evaluate samples. Early testing defined both the characteristics of the subsurface soil as well as the existence of alkali salts. Then again in 1944, several studies were done by the Park Service and drainage and soil 

experts from the Soil Conservation Service in Albuquerque to determine the exact nature and scope of the 

environmental problems afflicting Aztec Ruins and how best to resolve them. The volumes of data produced merely confirmed earlier beliefs: the source of the distressing subsurface water was from the north 

and northeast of the ruin, where a major unlined canal and irrigated fields existed. Topography and soil 

conditions contributed to the difficulties. 

Over the years, many diversion channels and buried water systems have been installed, all yielding varying degrees of mitigation, and in 2004 further hydrological studies were initiated. But by far Hamilton’s 

most profound recommendation was for the reconstruction of the Great Kiva, which had nothing to do 

with preservation of existing resources. In his report, he stated, “...following Morris’s excavation report in 

1921, it should commence as soon as possible.”

It was the impression of Hamilton that the Great Kiva had lost its form and outline by 1933 and must be 

rebuilt to be understandable. In this case, we see the engineer weighing in on interpretive agendas. It is 

apparent that Hamilton’s recommendations carried weight in Washington as NPS director Cammerer then 

requested the services of Earl Morris from the Carnegie Institute (where he was employed at the time) 

for the Kiva reconstruction. Since leaving Aztec in 1928, Morris had been engaged in Central America on 

Mayan sites working with Carnegie. This experience likely broadened his horizons. In 1933, he agreed to 

take up the Aztec work and was appointed as “Collaborator at Large” to the National Park Service. His 

salary was paid by Carnegie while per diem was paid by NPS. The major part of the Great Kiva reconstruction project took approximately five months from the spring into fall of 1934 under Morris’s supervision 

with a large WPA crew. While the actual ruminations concerning the philosophy and administrative decision process are not recorded, Robert Lister, archeologist and Chief of the Southwest Cultural Resources 

Center in 1977-78 and a protégé of Earl Morris remarked in 1988, “I think Earl felt, in order to preserve 

the Great Kiva that it was a good idea to restore[sic] it...[He] felt that one of these (Great Kivas) should 

be restored[sic] so that the public would realize the magnitude...[You] don’t get this feeling from going 
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74 A Brief History of NPS Management of Archeological Sites in the Southwest

to Pueblo Bonito or Chetro Ketl or Casa Rinconada. Such unreconstructed sites look like holes in the 

ground.”

The Great Kiva, finally completed in 1935, represents the only large-scale reconstruction undertaken 

within the Southwest’s archeological sites under the jurisdiction of the 

National Park Service. As a result of 

this particular status, it is not considered a Vanishing Treasures resource as 

reconstructions are precluded due to 

integrity and authenticity values. 

By 1990, after 100 years of trying to 

preserve and manage ruins, Dr. Robert 

Lister wrote these illuminating and 

reflective comments in relation to the 

Aztec experience: “In the case of the 

Aztec Ruins, the demands of archeology and the commitment to place the results on permanent exhibition were paramount. While concomitant preservation needs were recognized from the outset, their enormity, their perpetual recurrence, their 

possible distortion of the prehistoric record, and their huge expense were not then appreciated. It was only 

in later years that the National Park Service came to a full understanding and acceptance of the ramifications of the responsibility it had almost unknowingly acquired.”

The complexity of these ramifications continues to confound but perhaps are more clearly recognized 

today.

Morris’s influence went beyond Aztec as he was also involved at Mesa Verde. In 1934, he hired Al Lancaster to supervise repair and reconstruction there. Lancaster became something of a legend in the ruins 

preservation and Southwest archeology world. He represented a special breed of person to be brought into 

resource preservation work during the ‘30s. Morris depended heavily on him, believing that repair and stabilization work called for professional qualifications that were not easy to find. Some of the qualifications 

he identified were: “...practical common sense, intimate familiarity with and understanding of the materials used by the ancient builders, wide and penetrating observation of original methods of construction, 

a working knowledge of masonry technique, an eye to aesthetic effect, and intense interest in the work at 

hand. Obviously such a man, if found, could not be picked up at a moment’s notice.”

This could well be the first job description for a ruins stabilization worker. He did not include a description 

for his own job which likely would have included an academic aspect. The first person to fully meet the 

qualifications set out by Morris was Al Lancaster. This job description was written after he met Lancaster. 

Morris was very conscious of how badly damaged sites such as Cliff Palace were due to the excavations and 

early repairs. It appears that he was recognizing the need to include some construction skills into the mix, 

as past work accomplished by the archeologist left something to be desired.

Lancaster, a bean farmer who had homesteaded in Southwest Colorado, had good basic construction skills 

learned, in part, from building a home from the earthen materials on his land. In 1925, he first tried out 

government service working at Mesa Verde on the road improvement project started up that year. Getting the mesa-top opened for automobile traffic and visitors was a National Park Service priority and road 

development was always on the front burner during the early years. Lancaster was a person of natural 

skills with a good eye who was willing to try about anything. After his initial federal service, he went on to 

participate on non-NPS projects at Lowry Ruin and at Awatovi into the early 1930s where he picked up 

valuable “hands on” experience with excavations and wall repair. During that work, he was discovered by 

Morris, who hired him back into the Service for archeological site duties in 1934. Morris needed someone 

he could trust to leave in charge of the Mesa Verde work while he was busy at Aztec.

Great Kiva under construction
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Lancaster’s job title was Temporary Supervisor of Repair and Reconstruction. An example of his early 

work is the stabilization of Speaker Chiefs Tower in Cliff Palace where he placed iron screw jacks beneath 

supporting stone for the tower which had listed. He constructed a stone veneer to conceal the jacks in a 

style so similar to the original it was virtually unrecognizable as a repair. It remains in place today. He found 

himself redoing much of Fewkes’ work which by this time was seen as too invasive and heavy-handed. It’s 

worth noting, however, that some twenty to twenty-five years of service life realized from Fewkes’ work 

could be considered rather effective, considering these are ruins.

Lancaster had the skill to match prehistoric work and that was apparently appreciated. His depth of 

understanding of site dynamics can be illustrated by the diversion channels on the mesa tops to protect 

ruins below which he is credited with 

constructing. In 1940, he constructed 

the first of these over Square Tower. 

Off-site, non-invasive treatments to 

protect a site demonstrate an early 

indirect conservation approach. Better 

to treat the disease, it was thought, 

than to focus on the symptom. Lancaster was too old to serve in WWII so 

he continued on during the war and 

was reassigned in 1945 to Aztec where 

he is listed as being a Park Ranger. The 

Park Service has always managed to 

use flexibility in job descriptions and 

assignments when it comes to actually 

getting work done. 

The lack of maintenance during the war created some situations around Southwestern Monuments needing attention from someone like Lancaster. By 1946, he was working at Chaco and, in 1947, he was back 

at Mesa Verde completing the triangle. His services were needed at Hovenweep during the 1947 season 

and Lancaster continued to travel for work. In 1951, he is credited with constructing shelters over the pit 

houses along the ruins road at Mesa Verde using leftover and reused CCC lumber from the camps. The 

completion of the ruins road was a long-held goal of Mesa Verde to fully interpret the 600-year architectural history of the Puebloan peoples who occupied the Mesa. Lancaster clearly understood the fragile nature 

of pit houses which lacked the protection of protective cliff overhangs. During this time period of the early 

1950s, he also provided assistance at Atsinna at El Morro where excavations had begun. His logistical expertise with dealing with the hard-to-get-to site was invaluable in this case.

In 1953, Dr. Robert Lister from the University of Colorado was reintroducing University field schools at 

Mesa Verde as well as other sites, so he got Lancaster involved with that effort, training graduate students 

about excavation and stabilization. This had to be a rewarding experience for Lancaster since he only had 

an eighth-grade education. The Mesa Verde Archeological Research Center was started up and Lancaster 

played a major role in guiding the students, being a field leader and getting project work done. 

He had a large influence over the field as he had trained so many who went on themselves to become icons 

in Southwest archeology. In 1958, George Cattanach and four others joined Lancaster in the excavation 

and stabilization of Long House. Work proceeded very quickly and Lancaster is credited with stabilizing 

features as the excavation progressed, accomplishing work that was virtually indistinguishable from the 

original. 

Lancaster may not have been conversant in the various philosophies being argued over concerning authenticity in academic circles, but he clearly had a deep understanding of the construction methods used by the 

Puebloan builders. Lancaster succeeded in accomplishing repair work that not only worked structurally 

but also aesthetically. One might ponder the question of Lancaster’s legacy of work that remains visible 

Lancaster and stabilization crew in 1935
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76 A Brief History of NPS Management of Archeological Sites in the Southwest

today and whether or not it can be distinguished from the original. 

 After a full thirty year NPS career, he retired in 1964. He had received the National Park Service’s Distinguished Service Award in 1962 for his achievements. Even after retirement, he continued to participate in 

many related activities, offering his knowledge and experience answering many calls for help from the likes 

of Lister and others. Al Lancaster’s method, which he forged together with his experience of working with 

Morris, has been well-stated by J. Adams: 

Every attempt was made to remain loyal to the aboriginal construction. Walls were rebuilt 

only when needed for retaining loose fill or for supporting other structures. Original building stone was reused until the supply was exhausted and then fresh stone was shaped to 

look aboriginal. Red adobe was packed into the joints and a thin coating was painted over 

the walls. As this aged, the new construction was nearly indistinguishable from the ruined 

walls.

While Lancaster managed the trees, Morris was looking to the forest. Because of his experiences during 

the Public Works Administration programs at Mesa Verde and Aztec Ruins, Morris favored a permanent 

plan for ruin survey within the National Park Service synchronized with an annual schedule of repairs. 

Morris’s systematic approach accomplished one benchmark in 1937 when the National Park Service 

initiated the mobile unit or team specially hired and directed to care for the ruins. The rational plan of 

procedure, he said, was to develop a stabilization crew in the park to continue repair and restoration on a 

permanent basis, the individuals to be given full-time jobs.

In addition to Lancaster, the hiring of R. Gordon Vivian about the same time represents another significant 

internalization of professionalism in the NPS. Vivian was one of Hewett’s students who went on to formalize many of the concepts put forth by Hewett. In 1933, Vivian initiated 

a major stabilization project on Chetro Ketl and Pueblo Bonito at Chaco 

under the administrative umbrella of the Civil Works Project program. 

The National Park Service took advantage of the federal jobs programs to 

get field work activities up and running in parks. Vivian’s work continued 

into 1934. Many indirect measures were taken, including constructing 

water diversion dams and drainage work around sites. Between 1933 and 

1937, he began major site preservation work at Pueblo Bonito, Chetro 

Ketl and Casa Rinconada. By 1939, it is recorded that Vivian had written 

what may have been the first ruins stabilization manual. (This manual was 

not available for reference for this history.)

Vivian and Lancaster’s career started during the last ten years of Boss 

Pinkley’s. The work of these three was closely intertwined. Pinkley died 

on the job as Director of the Southwestern Monuments in 1940. He had a 

distinguishing career of nearly forty years devoted to preserving, protecting and interpreting archeological sites in the Southwest (that is, after his 

initial foray into pot hunting). At the time of his death, twenty-one Monuments were under his capable direction. He surely gave meaning to the 

administrative concept of “command and control”.

The 1930s and growth of the federal government provided the NPS with internal capabilities that had not 

been seen before. The Depression had brought a significant change to archaeology in the Southwest. Relief 

work spilled into archaeology and stabilization, emphasizing the employment of both unskilled workers 

and skilled workers — the latter including engineers, artists and anthropologists. More archaeological sites 

were excavated, studied and stabilized. This decade was critical to the development of modern archaeology. The Bureau of American Ethnography, the School of American Research and educational institutions 

would take a back seat to this new and impressive cadre of workers at some NPS sites.

Vivian at Chaco in 1930
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In 1937, a Civilian Conservation Corps (CCC) camp first involving some 200 enrollees was set up at 

Chaco which coincided with the establishment of the Mobile Unit there. The Mobile Unit was conceived 

as a branch of the Ruins Stabilization Unit (RSU) based out of Globe that was supervised by Vivian. The 

management of the Mobile Unit was set up to be led by an archeologist with building experience to ensure 

maintenance of inherent values in sites. He was to be aided by an architect to record and develop plans. 

An agreement between the Bureau of Indian Affairs (BIA) 

and the NPS allowed for cooperative work programs. By 

joining forces with the CCC and BIA, The National Park 

Service engaged in some early capacity building. The NPS 

provided materials, equipment and supervision. The Navajo Agency supplied a crew of Native American enrollees to 

work out of a base camp in Chaco Canyon. For the following five years, the unit moved between many Southwestern 

monuments accomplishing both emergency and routine 

maintenance stabilization work as required. The number 

of Navajo participants decreased from 200 to twenty in 1938, then to ten in 1940. Between 1942 and 1946, 

the Civilian Conservation Corps Mobile Unit was disbanded because of World War II.

After the conclusion of the War, the Mobile Unit was back in action again by 1947, repairing flood damage 

and stabilizing walls at Chetro Ketl. The Mobile Unit also worked extensively at Aztec National Monument, 

since it was so close to Chaco. Although for many years their methods of work necessarily remained on a 

trial-and-error basis, the first Navajos enrolled in the program soon jelled into an efficient group of stone 

masons. Their early work at these two sites focused on walls and features which were falling into disrepair 

because of the environmental exposure they suffer. Untreated but still a major factor was damage from 

underground water which Hamilton had recognized ten years earlier as an impact at the Aztec Ruins.

The compromise between sound building methods and authenticity in appearance was a constant challenge. The RSU policy probably spelled out by Vivian in his first guidelines became one of retaining the 

look of the Puebloan architecture as it was found upon excavation, while calling for reinforcement using 

modern products and methods which would not alter that appearance. A systematic inspection of ruins 

and a standardized style of documentation of remedial treatment were instigated so that future technicians 

would be enabled to distinguish original from treated constructions and know how to proceed. Stabilization advanced from repairs done after the fact to setting up long-range plans to deal routinely with unstable 

ruins walls and to observe them over time to prevent, rather than fix, damage. No matter what the program, 

inevitably when one wall was fixed, another was falling down. 

Pinkley had accomplished a great deal but the reality of ruins preservations was still a headache. In 1941, 

an AZRU ranger was quoted: “...ruins may be seen falling before one’s 

eyes...hardly a foot of uncapped wall which has not suffered serious damage. In the southwest wing of the pueblo, a huge section of wall and door 

have collapsed.” Later the same ranger begged: “Stabilization is urgently 

required.”

The Search for Solutions (Miracles), Materials and Methods 

A change in the approach to ruins stabilization was being sought between 1930 and 1935, probably due to recognition that the authenticity of 

original architecture was being compromised. On March 31, 1931, The 

National Park Service in Washington, D. C., issued the following notice:

National Park Service is seeking means of protecting Pueblo ruins 

from weathering. The ideal solution would be a transparent, waterproof coating which could be sprayed on the walls, but no suitable 

product has been found, and the Service announced today it would 

CCC Camp, Christmas 1938

Frank “Boss” Pinkley
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78 A Brief History of NPS Management of Archeological Sites in the Southwest

welcome suggestions for a substitute.

In 1932, Standard Oil presented their suggestion, naturally a product off the oil industry shelf in the asphalt 

family. They titled the product Soil-Bitumen 1, which was an emulsified asphalt that could be added into 

the earthen mix to render a more weather-resistant material. The use of bitumens as amendments in mortars saw some extensive use during the1937-1940 period and it had intermittent use for some years following. One recognized weakness was attributed to its incompatibility with the high salt contents in the soils 

and waters which occurs in many Southwest areas. Also the admixture tended to discolor the earthen mortar. The discoloration is reduced over time through the effects of ultraviolet light. Bitumen mortars can still 

be found present in some ruin walls today, indicating at least partial success. Asphalt mixtures continued to 

be used by preservationists in different forms up into the late 1950s. It is relevant to note that contemporary 

stabilized and semi-stabilized adobe are manufactured with an aqueous-based asphalt emulsion. Asphaltstabilized adobe bricks have become a commercial industry standard and have modern widespread use in 

new construction in New Mexico and other parts of the Southwest.

Looking beyond industry to academia, the National Park Service began a collaboration with Stanford 

University seeking to make its own preservative. An experimental vinyl resin, labeled NPSX, was the result. 

In early 1935, it was applied to the exterior façade and interior of the nave of the Tumacacori Mission. The 

results of these treatments remain unqualified and for whatever reason, the use of this material was not 

continued. Any reticence at applying experimental chemicals to historic walls is not in the record. Little 

documentation exists and if some scientific advances were made, they were lost. It is a recurring problem 

throughout the early history that many field trials were done but the lack of documentation as well as the 

lack of scientific methods being applied handicapped the process. 

It seems that little progress in the research was recognized when in 1940 a meeting took place in Santa Fe 

resulting in The Report of Director’s Committee on Ruins Stabilization. Members of the committee included Erik Reed, Dale King, Lyle Bennett, A.R. Kelley, Edmund Preece and Jesse Nusbaum. The work of 

Gordon Vivian and Al Lancaster and the others must have informed these discussions. Nusbaum provided 

the history of the topic. The final product resulted in policies and recommendations informing the field. 

Among the points made was a comment regarding the 1908-1923 Fewkes period of influence. The general 

feeling of the group as noted in the Report was that Dr.Fewkes had “...deviated too far from aboriginal 

methods, exceeded justifiable limitation in matters of rebuilding, construction, and type restoration.”

Fewkes presented his conjectural reconstructions as authentic and thus had stepped out-of-bounds. It 

is ironic that a person who argued so strongly for the preservation of ruins was ultimately viewed as one 

who exceeded the limits of acceptable standards of the time. This comment mirrors many over the years 

in which whatever philosophy is current casts a shadow over its predecessors. In reality, almost all treatments are a product of their respective times. They will nearly always be criticized from the vantage point 

of future knowledge and the experts of the times. 

Cement capping installed at Aztec and Chaco was very unfavorably reviewed by this committee. The 

Committee declared in the Report that bitumen-stabilized soil demonstrated a positive value, stating, “It 

is highly probable that they will continue to occupy an important position in the family of techniques that 

may eventually be developed.”

The 1940 Committee Report previously states, “The basic deficiency is material. It is highly probable that 

superior methods of application will quickly follow the development of suitable materials. Existing stabilization measures are founded almost entirely upon the use of native soils, cement mortar as capping, 

cement mortar and soil mortar masonry and, particularly at Chaco Canyon, native soil stabilized with bitumen. A single attempt to apply modern plastics was made between 1933 and 1935, which consisted largely 

of experimental work and which, failing to recognize the physics and mechanics inherent in the problem, 

resulted in little, if any, positive value.”
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In concluding this section of the Report, the Committee remarks, “[Existing Stabilization measures] must 

be supplemented by materials of different characteristics which probably will be found only in the developments of industrial chemistry. The resins, and silicon ester in particular, appear to offer hope of eventual 

solution.”

The silicon ester (ethyl silicate) has in contemporary times become very useful in consolidating earthen 

resources, particularly surfaces.

Among the recommended policies in this document are the following:

8. Limited stabilization measures should be conspicuously distinct, particularly integral 

structural members or other devices that may be introduced under Limited Special. Subordination of appearance in Comprehensive Stabilization by means of concealment, coloration, and structural inconspicuousness is highly desirable. In general Related Stabilization 

measures should not attempt to simulate original construction but they should be harmonious and subordinated. While conforming to the requirements of obviousness, aboriginal 

materials and techniques shall be rigidly adhered to in Comprehensive Repair where the 

needs of preservation can be adequately satisfied. 

9. Prehistoric and historic structures constitute scientific data. Scientists and the public must 

be able to discriminate aboriginal from altered conditions now and for all time. Although 

stabilization procedures are required to be distinguished clearly upon close examination, 

the permanency of these measures can not be assured. Therefore, they must be supported 

by complete recordation. 

The Committee had the vision to realize that techniques and materials were deficient, and in the 1940s, the 

value of resins, plastics and silicon esters was recognized, but they were not researched until after World 

War II. One major recommendation was to equip and fund a mobile technical unit under the direction 

of an archeologist with assistance from an architect, to be manned primarily by Native Americans skilled 

in masonry work. This serves as a stamp of approval for the RSU which had already been functioning for 

a few years. Definitions were provided in the document in recognition of the fact that this area of work 

involved terminology outside normal construction lexicon. The committee also recognized the need to 

continually meet to revisit issues. It is unlikely that they met again due to the onset of WWII. During the 

waning years of the war, government officials looked ahead to what would be needed for the preservation 

of aboriginal ruins within the National Park Service system once the war was over. A call went out for statements showing comprehensive stabilization necessary under a Major Repair and Rehabilitation Program 

(also called Comprehensive Post-War Stabilization Program). As a part of this planning, portions of the 

Aztec ruin were designated for backfilling. The early recognition of this treatment option presages the 

emphasis placed on backfilling some fifty years later. In 1943, looking down on all these activities from his 

vantage point at the School of American Research, Edgar Lee Hewett wrote:

In short, the preservation of these monuments means the establishment of sanctuaries where 

a spirit of reverence may abide. We will not put back a single block of stone more than is 

necessary to arrest destruction, I will let no work or hands deface the work of their builders 

nor belie the spirit that brought them; for that spirit lives in every chapel in our southwestern 

land and blesses simple native homes with the peace more precious than worldly wealth. 

When it is important for the information of the public, make a model of the building or a 

restoration on paper, clearly indicating where it is conjectural and let it go at that. Such is the 

spirit in which we regard our obligation to preserve and protect ancient monuments. In this 

spirit we have laid the foundation of a policy in Chaco Canyon, Pecos, Jemez, Abo, Quarai, 

and Grand Quivira.

Don Morris, NPS archeologist, reflected in 1977 on Hewett’s comments that he was having a reaction 

against the reconstructions at Aztec, Wupatki and Kinishba. Hewett’s strong comments also reflect a 
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80 A Brief History of NPS Management of Archeological Sites in the Southwest

similar philosophy corresponding to that of the nineteenth-century English conservationist and critic John 

Ruskin who advocated for restraint and respect for the remains of the past precluding all but the most 

modest intervention. 

Hewett’s statements seem to have had limited impact within the ranks of the NPS as major work continued. 

At Tumacacori in 1946, Charlie Steen surveyed and identified adobe and plaster deterioration at the Mission and, in 1947, he returned with Al Lancaster to accomplish basal repair and crack filling which addressed the basic adobe problems. Basal repair and crack filling can be considered the “endless summer” 

of preservation treatments of earthen ruins, as these and capping deterioration are chronic conditions. 

Recognition of the values associated with the decorated surfaces on lime plasters and washes inside the 

mission led to R. J. Gittens of Harvard’s Fogg Museum coming to the site in 1949. He surveyed the painted 

surfaces, making recommendations for treatment, some of which later were accomplished by Steen. The 

chemical polyvinyl acetate, a common consolident in art conservation at the time, was used in the process 

which also included edging and cleaning of surfaces. This project represents a first in the Southwest for approaching decorated surfaces from the point of view of an art conservator.

The use of modern chemicals was not limited to this intervention, as Vivian is reported to have used a 

silicone “Daracone” (a silicone-based water-proofing product manufactured by Dewey and Almey Chemical Co.) during the 1950s. In 1951, a new member of the Mobile Unit, archeologist Roland Richert, was at 

work for Gordon Vivian. Together, these two forged ahead with many treatment programs. The Daracone 

applications were water-repellent surface treatments verses the acetate used at Tumacacori, which has 

consolidating properties. In 1955, Vivian wrote to Richert requesting that he purchase Daracone for use at 

Casa Grande and at Tumacacori. Experimental test walls he had constructed by the Mobile Unit at Chaco 

in 1954 convinced him that improvements were achieved in comparison to un-amended adobe. He was hosing down the walls with water 

to evaluate the treatment. History would show that Vivian and Richert 

were not treatment-averse or reticent to try things out. Time has shown 

that surface coatings such as Daracone typically resist direct water flow 

but perform less well under the influence of capillary water which is 

moving beneath the surface.

Richert is recorded as using soils strengthened with the bitumens, particularly where it was necessary to correct basal erosion. Later Richert 

began using Daraweld C (a polyvinyl acetate copolymer dispersion in 

water) in 1960 as a substitute for the Daracone and bitumens. Bitumens 

darken the soil mix and are recognizable. Throughout the history of 

treatments, amendments having no optical effects were continually 

sought. Daraweld C offered that characteristic, at least in its initial application, and it has continued to be used today as an earthen amendment at many sites. Its deterioration pattern is quite different from 

un-amended earth, but this fact did not become evident for many years. The rationale for the shift away 

from Daracone to the Daraweld C is not recorded or currently available in the record. Possibly the inherent differences between these products (Daraweld C may be both intermixed as well as applied to a surface 

while Daracone was a surface coating only) may explain part of the justification. 

Daraweld C has continued in widespread use. It is manufactured as a concrete bonding agent that has been 

adapted for use in the preservation of earthen materials. NPS preservationists during this period were 

actively experimenting and achieving some success using it as an amendment as measured simply by field 

results. These products offered a level of weather resistance and the user therefore had some new products 

in his tool kit which he could use to prolong the inevitable.

Richert and Vivian in the field
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A Brief History of NPS Management of Archeological Sites in the Southwest 81

Throughout the entire history of treatments, the use of soil cement (combinations of soil and Portland 

cement) appears over and over again. Its use may be traced back to the Fewkes work at Mesa Verde and it 

appears to be the one treatment type that surfaces and resurfaces in some cases and also has been continually used at some locations. As with other materials, it had not benefitted from thorough scientific scrutiny. 

The 1940 Committee comments reflect a general feeling that cement is not an adequate solution. From 

1941 to 1946, A. E. Buchenburg is recorded as conducting controlled testing of soil cement at Wupatki 

National Monument. Between these dates, soil cements were being experimented with in various ways, 

in particular with mortars, and the results were deemed satisfactory. His tests were simply outdoor exposure tests of 6x10x3/4” brickettes of various formulations which were observed over time. As a result, soil 

cement attained a new level of legitimacy. It continues to be used today in various mixtures, as some parks 

have realized what they consider a satisfactory level of success. 

In anticipation of the fiftieth anniversary of the founding of the NPS, in 1956 the National Park Service 

launched the Mission 66 Initiative to address long-standing deficiencies in the 179 units of the system. 

While this initiative was primarily focused on new construction enhancements such as visitor centers, 

roadways and the like, it did represent a large influx of resources to revive, repair and construct in parks 

throughout the system. New personnel were hired. Seventy new units were authorized. The expansion into 

Weatherhill Mesa at Mesa Verde became a major objective.

In 1960, Gordon Vivian decided that the bitumens and soil cements were unsatisfactory. In his opinion, it 

would be better to use unadulterated cement mortars tinted for compatibility. 

Unfortunately the background considerations for this decision are not available. At this point, Vivian had nearly thirty years’ experience and his opinion 

must have carried some weight. Records show that the Ruins Stabilization 

Unit crew (ten Navajo men) led by Charlie Voll and Martin Mayer in 1965 

were recorded as replacing bitumen mortars with tinted cement mortars. The 

distinction between soil cement mortar and cement mortar is simply that cement mortar meets an industrial standard and contains only clean washed sand 

free of soil. Vivian and Richert were practitioners who learned on the job. They 

took their cues from empirical field experience. Vivian’s legacy and that of the 

RSU continued. 

The Ruins Stabilization Unit was located out of Tucson and it became a part 

of the Western Region in the 1971 reorganization of the NPS. Arizona, except 

for a few parks in the northeast corner, went to the Western region, while New 

Mexico stayed in the Southwest Region. The Unit worked primarily in Arizona 

parks but also continued to assist at Aztec to some extent. It functioned in a 

slowly declining manner until George Chambers and his assistant, the last operatives of the Unit, retired in 

the late 1980s. The shops at Casa Grande which Boss Pinkley had established served as their field staging 

and operations center.

During the next decades, illustrative examples offer a view of the times illustrating many fits and starts as 

well as measurable progress.

Even though it might be delayed, deterioration inevitably occurs and frustration emerges. Practitioners go 

after other answers. In 1971, University of Arizona soils scientist Daniel Evans was tasked with researching 

the moisture problems in the walls at Tumacacori. This endeavor marks a realization that underlying hydrologic processes are often at work at sites which likely affect masonry materials as moisture moves through 

capillary action. Rather than always treating the symptom, an effort to understand the depth of the problem emerged which led to treating the cause. Where is the source of the moisture? What is the quantity of 

the moisture? How does it move in the materials? What can be done to address the problem? A new era of 

the scientific process was emerging.

Following this line of thinking, a new comprehensive preservation approach was launched at Tumacacori 

Vivian in 1953
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82 A Brief History of NPS Management of Archeological Sites in the Southwest

in 1975. The fundamentals of this approach included laboratory material analysis, recognition of the 

processes of deterioration, monitoring for rate of change, increased levels of documentation, a multi-disciplinary team approach and critical review. Treatments included the judicious application of conservation 

materials such as consolidents to conserve painted surfaces which could be scientifically evaluated following the program. A maintenance program was laid out and implemented at various levels. The consolident 

Acryloid B-72 (an acrylic resin used extensively in the art conservation world) was used in the project. 

Training programs and international partnerships occurred. Aspects of the project were published and 

many contributions toward a better understanding of earthen architecture preservation were made. Historical Architect Anthony Crosby of the Denver Service Center led the project.

In 1976, the Navajo Lands Group (NALA) was formed, working out of Farmington to provide preservation services to sites in the Southwest Region. Steve Adams, archeologist, served as Ruins Preservation 

Specialist for NALA which, at the time, consisted of a small crew of Navajo men from Chaco Canyon. 

Meanwhile, Archeologist Larry Nordby was hired at Pecos and he and Adams conducted “hands on” ruins 

preservation training workshops, primarily at Aztec. NALA is recorded as working at rehabilitation tasks 

at Aztec from May to November 1977 of what comprised the fifth season of a major stabilization program. 

They were providing a service the RSU (now being managed out of the Western Region) could no longer 

do. They undertook the usual relaying, recapping and repointing repairs to 34 rooms, five clan kivas and 

two rooms of the Great Kiva. Wherever possible, they knocked out loose tinted cement mortar that had 

discolored and replaced it with an amended soil mortar using “Wilhold” (a latex-based concrete adhesive which probably performed in a way similar to the Daraweld C.) Workers also took down the wooden 

roof and sides of a late nineteenth-century root cellar at Mound F. NALA operated much as the RSU had 

with specialists trained in historic preservation working with Navajo craftsmen traveling the Region to 

accomplish day labor preservation on sites. During these years, experiments with methyl methacrylate 

were undertaken at Glen Canyon and Navajo NM. NALA was disbanded not long after it was founded as 

the Southwest Cultural Resources Center (Division of Conservation under the direction of Dave Battle, 

Historical Architect) absorbed some of those responsibilities save what remnants still existed in the Tucson 

Office under the direction of Chambers. The use of traveling day labor crews which started out in Chaco 

during the Depression continued into the present through these various administrative changes because 

they provided a viable means to address preservation needs in the Southwest.

Preserving Earthen Western Forts and Missions

Earthen ruins exposed to the forces of nature present the most challenging of preservation problems and 

looking into some of the activities at several earthen sites can illustrate some of the most compelling issues 

including, to a lesser extent, stone sites. The history of preservation activity at Fort Union National Monument is very illustrative of the bold attempts to control natural forces, the fits and starts of preservation 

activity, and the cycles of treatment approaches. On April 4, 1956, Fort Union was designated a National 

Monument. A quote taken from the historical record of the nineteenth century stated: “Indeed, from the 

moment they were completed until their abandonment in 1891, the fort’s adobe structures were in an 

almost constant state of unremitting deterioration.”

A brief summary of preservation activity since the establishment of the Monument :

1956-1958: excavation and structural stabilization

1959-1962: capping with soil-cement adobes and spraying with silicone water repellent

1963-1980: applying soil-cement shelter coats and spraying with silicone water repellent

1981-present: application of unamended soil shelter coats

1996-2003: implementation of Preservation Action Plan, major recapping 100 percent of ruins

1999-2000: initial and limited application of Rhoplex-amended soil shelter coats

In the first season of Fort Union’s becoming a National Monument, the NPS was ready to set work in motion, likely due to the effect of the Mission 66 Program. Under the supervision of archaeologist George Cattanach, a park-based preservation crew cleared rubble and debris from the base of the walls to return the 

grade to its historic level, regraded and installed drainpipes to direct water away from the walls, stabilized 
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A Brief History of NPS Management of Archeological Sites in the Southwest 83

chimneys by reinforcing them with angle iron and concrete, rebuilt corners 

and built buttresses where necessary to stabilize existing walls. The crew also 

spent time setting in motion experimentation with capping walls with various mixes and material combinations. But as it inevitably works in the NPS 

with personnel moving around the system, in August 1958, Cattanach left for 

work at Mesa Verde National Park. Archeologist Rex L. Wilson took over the 

supervision of the work at Fort Union. Excavation and structural stabilization continued with a focus of capping walls with soil-cement adobes and 

spraying adobe walls with the silicone water repellent (a five-percent solution of Dow Corning Silaneal 772 in water). Wilson also experimented with 

other proprietary silicone products and created two test walls he referred to 

as “Experimental Walls” to compare various water repellents. Remnants of 

these test walls could still be seen in the early 1990s. The exact formulation 

of the soil-cement bricks used for capping is not recorded by Wilson, but the 

1988 draft “Preservation Plan” states: “Soil-cement adobes were made from 

a mixture of one-part cement, three-parts screened red sand and three-parts 

native adobe soil. In order to compensate for the light color [caused] by the addition of cement to the mixture, raw umber and burnt sienna pigment were added.”

After the departure of Rex Wilson in August of 1961, the records indicate:

The maintenance crew applied silicone coating to the walls that needed it twice a year, but 

the silicone created a thin, whitish film which was easily damaged by hail, and was regarded 

as unsatisfactory. In 1963...the collapse of several walls due to high winds renewed the search 

for more reliable methods of stabilization and preservation.

Resurfacing of adobe walls with a soil-cement shelter coat is noted about 1963 which is after Wilson had 

departed the site and maintenance/preservation fell to Superintendent Homer Hastings. Discontinuity of 

personnel and the continual frustrated search for a cure for adobe weathering is again illustrated by this 

switch to soil cement.

On June 22, 1972 the Southwest Regional Office produced its report, Operations Evaluation of Fort Union 

National Monument in the section entitled “Historic Resources Management” it stated:

The present method of stabilization consists of capping wall tops with soil cement mortar 

colored to match the adobe and filling eroded places in adobe bricks with soil cement. The 

adobe walls are then sprayed with a water-soluble silicone solution called Silaneal 772 manufactured by Dow Corning Corporation to waterproof them. Following hail storms and strong 

rainstorms, the walls affected are re-sprayed to reseal cracks and fractures in the silicone seal. 

Each wall at the fort is treated this way on a five-year cycle. Original wood beams are treated 

with wood preservative every five years. Metal is painted with rust-resistant paint on in an 

“as-needed” basis.

The report also recommended that the maintenance staff: “...experiment with a capping and patching 

material of mud mixed with silicone instead of soil cement. This material will bind better to the old adobe 

and crack less.”

Even though this statement indicates silicone as the additive, old timers on the staff at the park insisted that 

soil cement shelter coats continued to be used, as recorded by the Oliver Report of 1996.

In 1975, a new 100-gallon tank sprayer was purchased; its use is unspecified in the report, but it likely was 

destined for the application of silicone to the adobe walls.

Beginning in 1981, the maintenance staff at Fort Union created preservation plans for each year; the plans 

Spraying adobe walls
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84 A Brief History of NPS Management of Archeological Sites in the Southwest

were developed by inspecting the ruins and prioritizing the necessary work. A major change in preservation philosophy and practice also occurred. The maintenance staff abandoned the soil-cement and silicone 

regimen in favor of a return to “traditional” materials, namely the use of unamended soils for adobe blocks 

and shelter coats. This change came about due to regional influence from the Southwest Cultural Resources Center with A Comprehensive Preservation Plan that was developed prior to the start of the 1981 season 

with the assistance of Dave Battle, Regional Architect. The objectives of this plan were to:

1) return to the use of original materials in adobe and foundation work, rather than the cement and chemically stabilized material used in past years, 

2) concentrate on repair of ruins whose condition constituted major safety hazards to employees and/or visitors, and 

3) repair foundations where identity of entire buildings or of remaining adobe walls was 

about to be lost.

In 1987, Historical Architect Tony Crosby, working out of the Southwest Cultural Resources Center, and 

P. G. “Buzz” McHenry, a well-known adobe preservation architect, presented training in adobe preservation techniques at the fort, including the selection of proper soil, the manufacturing of adobe bricks, crack 

repairs and the mud plastering of walls.

A Work Procedures Manual and video resulted from the workshop and it served to direct park personnel in 

modified procedures for treating walls for several years. The Manual itemized the different work activities 

routinely undertaken by the maintenance staff, defined each activity and listed the recommended procedures to complete that activity. These activities included the repair of coving, holes and cracks, the removal 

of debris and weeds, the manufacture of adobe bricks, the reattachment of loose plaster, etc. It did not 

involve the use of chemicals or any type of stabilizers as it focused on technique and a heightened understanding of the capacity of earthen materials properly understood and used. Included were field methods 

for evaluating adobe materials.

In 1996, a new Preservation Action Plan was prepared and finalized as then-Superintendent Harry Myers 

refused to accept any loss of adobe; rather, he energized the staff and partners to develop a new preservation strategy. Since 1991, park and regional staff had been working in close collaboration with the Graduate Program in Historic Preservation at the University of Pennsylvania in which students, their professor, 

Frank Matero, and NPS personnel collaborated in a multi-year research, training and pilot treatment 

program focused on preserving detached lime plasters. This work evolved into the new agenda which set 

out to establish some baseline information:

1. chemical characterization of the historic materials

2. review deterioration history and past conservation treatment

3. conduct a structural survey and analysis of the walls

4. the establishment of a monitoring program for present and future assessment of conditions and

5. the design of a testing program of current and proposed treatments

The Action Plan represented a holistic approach for the preservation problems at the Fort. Ultimately, the 

value of this work was to redirect resources toward prioritized preservation needs that were established 

based on scientific findings. This focusing of resources provided the park with a rational method of approaching annual work and established priorities for that work. Primary was the realization of the value of 

the historic capping and how this had so significantly saved fabric. Certain walls, lintels and corners also 

played into the formula, as did weathering patterns and environmental influences. A realization emerged 

that magic formulas or new chemical products were unlikely to solve the age-old quandary of adobe deterioration; rather, focused routine maintenance would be required. 

Located not far southwest of Fort Union, Pecos National Historical Park is a similar resource consisting of 

extensive exposed earthen ruins of the Spanish Colonial Mission and Convento which is located adjoining and on top of a major Puebloan earth and stone village site. Pecos has undergone a somewhat different 
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A Brief History of NPS Management of Archeological Sites in the Southwest 85

treatment history from Fort Union with no less energy and interventions attempted. The “Stabilization 

History of Pecos National Monument 1974 and Before” notes: “Since Bandelier’s initial visit in 1880, 

hardly a decade has passed without someone excavating or stabilizing at Pecos.”

The 1960s were a transition time for work at Pecos because for so many years so much had happened with 

a mixed record of documentation. It might be described as a huge problem in that momentum for construction of a visitor center and interpretation of resources was in place while the history and archeological 

research wasn’t adequately available to provide the basis for interpretation. The transfer of Pecos from the 

State to the National Park Service in 1965 didn’t help since record-keeping held by State and other repositories were not immediately accessed by the new NPS staff. Some natural confusion occurred. 

Archeologist Jean Pinkley arrived on site in 1966 with extensive experience from working at Mesa Verde 

and also working with Al Lancaster. Jean was the daughter-in-law of the “Boss.” She was tasked with the 

goal of excavating and stabilizing the ruins in a three-year plan. This dream eroded very soon and, by 1968, 

there was a Pecos Problem. 

A level of frustration with developments there was emerging in management. Deputy Regional Director 

George Miller is quoted as saying, “Once you let those archeologists in, you can never get rid of them.”

The project just got more complex and bigger and bigger by the day, although progress was being made. 

During these years, the Lancaster method of combining excavation with stabilization was followed. This 

method offers the positive value of assuring maximum reliability regarding fine details of reconstruction which could 

easily be neglected in delayed stabilization. This method was 

personnel-dependent, relying on the skills of Lancaster. By 

mid-fall, Ruins Stabilization Foreman Al Decker and his fourman Navajo crew had completed the excavated portion of Site 

620. By mid-summer 1969, the final excavation and stabilization 

had been completed, making the site ready for interpretation 

and public visitation. Jean Pinkley died of a heart attack in 1969 

and it became evident that she had left the same problem she 

had inherited: little available documentation and limited available records. That same year, Richert capped Convento walls 

with soil cement adobes and later, in 1970, Soil Seal bricks are 

recorded being applied to the West Convento wall by park Historian Frank Wilson. Soil Seal (methyl acrylic polymer) is first recorded being tried by Charlie Steen. Steen 

is recorded as having built test walls using Soil Seal amended bricks in 1970 and 1971. The test walls were 

constructed after field trials, which seems backwards, but was par for the course during these times. The 

use of the colorless additives versus cement offered a way to treat the ruins so that the repairs were less apparent and jarring to the viewer. Lancaster’s approach was to make the repairs disappear and this method 

influenced the others. 

The Pecos experience until 1974 demonstrates a transition away from soil cement and toward chemical stabilization. It also incorporated all the frustrations inherent in the use of these materials. After initial failures 

using Pencapsula (polyurethane emulsion) as a spray applied to walls, in 1969 Pinkley and Richert began 

applying a veneer and cap which essentially encapsulated the walls with adobe, typically modified in some 

way. This solution has been retained until today.

After Pinkley and during the period of 1971 to 1974, archeologist Gary Matlock was in charge at Pecos. In 

1974 Matlock wrote, “But I think that the basic problem then and even now, remains the same. We do not 

yet know how to stabilize and preserve exposed adobe or earth walls. A lot of people in and out of the Park 

Service have and are working on the problem and progress is being made, but we have a long way to go.”

In Matlock’s statement, the sense of hope for clear coatings and chemicals is sustained. The use of soil 

Lancaster and Navajo crew
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86 A Brief History of NPS Management of Archeological Sites in the Southwest

cement had been discontinued in favor of colorless amendments. Thus the desire for a permanent maintenance-free hard mortar, capping and surface treatment was replaced by a goal to develop an earthen 

mortar, brick and plaster which would be more compatible both visually and materially than cement and 

soil cements modified materials did. 

The confidence gained by the field performance of the Soil Seal test walls led to a campaign to replace the 

earlier soil cement bricks. The effect of these new veneer bricks was more in keeping with the historic materials in color and texture. The color, texture and general incompatible appearance of Pinkley’s earlier soil 

cement bricks caused the response. In 1972, Matlock records using Acryl 60 (an acrylic emulsion) in bricks 

and the use of better quality soil. The philosophy behind using these colorless amendments was stated 

by Matlock: “And while it is desirable to have stabilized material clearly different from the original, if the 

distinction is too great, stabilized material becomes an ugly intrusion.”

In addition, recognition of moisture being trapped under soil cement caps and changing color under wet 

conditions led to moving away from cement use. During Matlock’s tenure, he summarized the guiding 

precepts for the work:“...to preserve the original, find new material solutions, maintain character using 

authentic materials, not cement, stabilize with interpretation in mind and recognize the need for constant 

maintenance.”

One missing concept in Matlock’s statement is how to deal effectively with identifying the authentic from 

the repair.

Science Applied in Seeking Chemical Solutions

Scientific validation of colorless amendments took one step forward when, in 1971, Dr. Darrel Butterbaugh, a retired chemist from Rohm and Haas Corporation (the producer of Rhoplex), volunteered as 

a Research Associate for the Museum of Applied Science Center for Archeology, University Museum, 

University of Pennsylvania, Philadelphia. After visiting Casa Grande, he initiated a program of research and 

testing seeking a chemical solution for exposed earthen architecture. He initiated this program in 1973 at 

Pecos and Chaco. Butterbaugh initiated consideration of numerous new chemicals including the acrylic 

emulsion Rhoplex, a cement amendment developed for the construction industry. It’s not very surprising 

that Rhoplex was his preferred ingredient, considering his background. At Chaco, Butterbaugh tested materials on pithouse sites, Lizard House and Pueblo del Arroyo. In 1975, Butterbaugh placed two Rhoplex 

E-330 amended adobe bricks on the roof of the University Museum at UPenn. They were reported as being 

still there and in good condition during the mid 1990’s in the course of a round of research into Rhoplex 

use being conducted at that time.

A benchmark for treatments was the Handbook Ruins Stabilization in the Southwestern United States compiled by Roland Von S. Richert and R. Gordon Vivian and published in 1974. This 168-page soft-cover 

book thoroughly discussed precise stabilization measures, materials and techniques of the times. It is an 

update of Vivian’s 1968 publication which followed the 1949 version. Oddly, in 1962 the NPS put out the 

Handbook for Ruins Stabilization, Part 2 – Field Methods with the proviso that Part 1 would come later. 

They wanted to get the materials and methods part out as soon as possible. The 1974 publication was more 

formalized and also served to commemorate the distinguished career of Gordon Vivian, who died before 

it was published. Not only does this book lay out prescriptive solutions but it serves today to illustrate the 

many treatments used during the fifties, sixties and into the seventies. Reinforced cast-in-place concrete 

used to stabilize historic earth and stone masonry units is amply represented.

The search for solutions in the university setting continued. In 1974, James Kriegh and Hassan Sultan, two 

civil engineering professors at the University of Arizona, entered into a research agreement with the NPS 

to study problems of earthen architecture and to recommend solutions. Fort Bowie and Casa Grande were 

selected as focus sites for their work. They published results of lab work testing chemical treatments of 

adobe. They tested twenty combinations of chemicals including the Rhoplex E-330 that Butterbaugh had 

launched. Sultan was instrumental in developing F325–Adobeseal (an ionized extended water miscible 
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A Brief History of NPS Management of Archeological Sites in the Southwest 87

polysiloxane). A field test was applied at Fort Bowie in February of 1974 which was followed by wholesale 

treatment in May during which time 20,000 sq. ft. were surface-treated by spraying as many as three coats 

of this material all over exposed adobe walls. The enthusiasm for this and other chemicals was not shared 

by all. Their plans for Casa Grande which amounted to honeycomb drilling and installations of epoxyembedded rods was fortunately rejected. Using engineers to seek solutions for conservation problems in 

these cases was something of a mismatch. The relationship with Sultan and Kreigh wasn’t sustained for the 

long-term.

In late 1974 and early 1975, a series of memoranda circulated between the Washington Office, the Southwest Regional Office, the Western Regional Office, the Navajo Lands Groups and others concerning the 

use of modern materials eventually leading to a moratorium as well as a testing program. On Oct. 18, 1974, 

WASO Assistant Director, Park Historic Preservation, Bob Utley wrote, “We have observed the use of many 

modern materials in the restoration and maintenance of our historic structures which have questionable 

value and which in many cases do permanent damage.”

He announced a program of research with the National Bureau of Standards in which testing of materials 

would be accomplished and reported on using WASO as a clearing house for information. James Clifton’s 

work including publications in 1977 and 1978 on adobe were two such studies accomplished that have 

contributed substantially to the field. 

In 1975, Dr. Dennis Fenn, soils scientist at the University of Arizona, was engaged by the NPS through a 

cooperative agreement to initiate a testing program to seek scientific solutions for the problem of preserving earthen materials in ruins (the by-now familiar refrain since the ‘30s once again is used to launch a 

program). Applying soils science to a soils problem gets a lot closer to the issue than using engineers to 

come up with solutions. This reflects some critical thinking on the part of management. Fenn’s approach 

was to build test walls on-site to which would be applied various chemicals. He began at Chaco in 1976 

constructing a group of test walls in which he tried seventeen various chemicals including Rhoplex as 

mortar amendments (picking up where Butterbaugh left off). The site is commonly known as “Kin Fenn” 

(Navajo for Fenn’s house). This materials test incorporated a variety of promising mortar amendments including those that had been used in the past. Each material tested was exposed to all directions and interior 

and exterior of rooms, all of which received accelerated weathering in the form of applied moisture. He 

expanded his testing program in Chaco and to other sites as well. Test walls were put up at Casa Grande, 

Tumacacori, Fort Bowie and Bents Old Fort. He reported in 1978 making recommendations including for 

the use of Rhoplex as an amendment. In 1979, he revisited the 

Chaco test walls and reaffirmed his findings. A team, including 

the author, revisited those walls with Dr. Fenn in 2004 and he 

proclaimed that all the results remained essentially the same 

after more than twenty years of exposure. The walls remain as 

a testament to the validity of his findings. Amended mortars in 

wall surfaces that do not receive direct rainfall appear clearly 

to perform better than un-amended mortars. This same statement can not be applied to capping because the direct damage caused by rain and snow on caps has proven to negatively 

affect the emulsion-modified soils much more than in the more 

protected joints below. 

Based on these studies, the acrylic emulsion Rhoplex E-330, along with Daraweld C, were verified through 

these field tests to be useful as amendments for earthen mortars as proven by the Chaco test walls. These 

water-based emulsions were able to strengthen mortar and still allow a degree of transmission of water 

vapor through of the mortar. Rhoplex E-330 was initially used in the stabilization of Wijiji Ruin at Chaco. 

Once the National Park Service gave its tacit approval for the use of Rhoplex at Wijiji, the application of 

this chemical in ruins stabilization spread rapidly. The undercurrent here is that among practitioners and 

managers there continued to be a desire to find a product which when added to earthen materials would 

provide an increased level of sustainability. Fenn’s unofficial stamp of approval provided a kind of green 

Casa Grande test walls
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88 A Brief History of NPS Management of Archeological Sites in the Southwest

light even though in his reports he is very guarded about his recommendations and states the findings are 

for internal use only. From then into the 1980s, Rhoplex was widely used. With this expanded use came 

some problems since all of the behavioral characteristics of this product were not well understood. Problems due to inappropriate use occurred in performance, sometimes with very quick failures. In the late 

1980s, a representative from Rohm and Haas, the company that manufactures Rhoplex, was invited to a 

National Park Service ruins preservation training course which served to provide some parameters for the 

correct use of Rhoplex. Later in the 1990s, lab research was conducted which provided parks with hard 

scientific data and improved guidelines for using this material.

The history that unfolded at Fort Bowie illustrates the application of knowledge gained elsewhere that may 

not have been informed by the site characteristics at the Fort. In 1977, as a result of limited field evaluations 

at the Fort, a new direction was taken which further indicates practitioners trying to eradicate cement use. 

The historic structures preservation guide stated: “The preservation of above grade adobe ruins will comprise complete removal of soil cement caps, veneer, basal erosion fill, and reconstruction.”

In 1978, work to remove the caps was undertaken in earnest. Measurement of damage and scientific evaluation of deterioration caused by the cement was not undertaken. An account of the decision to take this 

action is not clear beyond the decision to use only compatible materials and allow the site to better conform with the intended “abandoned” description that is in the founding legislation. The growing dislike for 

Portland cement generally is likely the motivation for all this work. This action is in sharp contrast to the 

developments at Fort Union where not only were the soil cement caps shown to have performed admirably 

for nearly forty years but, in the 1990s, the decision was made to replace these caps in a similar manner. 

Fort Bowie has suffered serious losses since the caps were removed and ultimately lime plaster shelter coats 

(starting in 1988) have been applied to forestall deterioration of historic fabric which continued to erode 

unprotected.

Philosophical discussion about what to do with ruins surely permeated these times. There are not many 

written expressions available but one helps to shed light on prevailing thought. In 1977, Don Morris, archeologist at WACC, wrote in his draft “Pre-Stabilization Standards,”

...[in] United States National Park Service policy developed in 1940 and current today, 

obligations to science as well as the public necessitate a firm policy of no modifications to 

unexcavated sites. Maintenance of those sites unmodified may involve, however limited 

stabilization [and] stabilization work should be held to a minimum necessary for adequate 

preservation with a minimum impairment of the site. Stabilization inevitably involves some 

alteration of the fabric of the original prehistoric material. These alterations are often subtle 

and very likely more significant than anticipated.

In 1979, A Study of Historic Preservation in the National Park System prepared by the Management Consulting Division and Cultural Resources Management Division, WASO came out and, among its recommendations was the establishment of cultural resource centers in the regions where personnel resources could be 

centered to better assist parks. The Southwest Cultural Resources Center had already been formed and one 

of the many recommendations for activities was to provide guidelines to the field. Archeologist Larry Nordby, working out of the SWCRC anthropology program, was guiding field ruins treatments while archeologist Steve Adams was doing the same thing for the Navajo Lands group (NALA). NALA was a kind of an 

offshoot of the RSU, working within the confines of the Southwest Region. Together these two, with other 

assistance, conducted ruins training workshops. When NALA disbanded, the only day labor group left was 

operating out of the Center. The concept of a mobile unit to serve small isolated parks was the same as that 

which had started in 1936. The very simple justification for this activity was the special nature of the work 

coupled with the high cost of bringing contractors to remote locations.

Central office command and control mechanisms were in place and operative. On Dec. 13, 1984, a moratorium went out from the Acting Regional Director of the Western Region to only allow Portland cement to 

be used for emergency structural purposes. He wrote, “In short, cement will be used only where the struc-
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A Brief History of NPS Management of Archeological Sites in the Southwest 89

tural integrity of the architectural features is so impaired that collapse of the historic material is eminent.”

The vilification of Portland cement was proclaimed. It is certain that not everyone heard and obeyed the 

command.

Partnerships, NAGPRA, and the VT Program

In 1965, the University of Colorado Archeological Research Center was set up at Mesa Verde using a fifteen-year cooperative agreement. Robert Lister was named Director. With his extensive NPS experience, 

using Al Lancaster to work alongside students and Dave Breternitz to run the field programs, the Center 

launched a partnering program affecting and educating many of the SW archeologists working today in 

and outside the Service. This agreement formalized a process which had been underway at Mesa Verde for 

some years already.

In the late 1980s, Chaco embarked on an ambitious program of site reburial (backfilling). Not long afterward, Aztec began a process of reducing the exposure of major portions of their resources by partial backfilling selected areas of West Ruin. In the early 1990s, at about the same time as the Native American Graves 

Protection and Repatriation Act (NAGPRA) was being enacted, plans were underway to rebury Rainbow 

House at Bandelier National Monument. This project may be the first in the NPS during which the backfill 

program designed within methods for the repatriation of human remains and funerary objects incorporated which complied with NAGPRA.

The NAGPRA law of 1990 and the effect this has had on the treatment and interpretation of Native American Ancestral Sites can not be overstated. The effect of this law has been that Native American stakeholders 

have been involved in direct consultation on many issues concerning site treatments at sites to which they 

have heritage relationships. A century of work had gone on at sites with direct relationships to various existing tribes, yet seldom if ever did consultation take place. In most cases, a complete about-face occurred 

with regard to consultation processes and the relationship between tribes and the NPS. 

In 1988, a joint NPS and State of New Mexico architectural conservation laboratory heavily focused on 

earthen materials was started in the Santa Fe NPS office using collaboration and partnership between the 

State of New Mexico and the Southwest Cultural Resources Center. The lab provided practitioners with an 

additional tool to analyze materials, deterioration mechanisms and potential treatments at a deeper level 

beyond the simple field observation. 

In 1990, the International Conference on the Preservation of Earthen Architecture co-sponsored by the 

NPS, State of New Mexico, US/ICOMOS and the Getty Conservation Institute was held in Las Cruces, 

New Mexico. One major focus of this meeting was the presentation of extensive test walls constructed at 

Fort Seldon State Monument by the Getty Conservation Institute in which many of the same chemicals that 

the Park Service had been experimenting with were again subjected to yet another battery of field trials. 

The results of this program mirrored the earlier NPS conclusion in that a magic bullet to preserve earthen 

architecture had yet to be discovered. The Getty Conservation Institute has continued to be a partner to 

the NPS with many ventures including resource studies at Chaco and partnering for three seminal conferences on Sheltering Archeological Sites (2001), Reburying Archeological Sites (2004) and Treatments for 

Decorated Surfaces of Earthen Sites (2006). 

Out of the meetings in Las Cruces, a partnership between the NPS and the Architectural Conservation 

Laboratory (ACL) in the School of Design (Director: Frank G. Matero) at the University of Pennsylvania 

was conceived in late 1990 and launched in 1991 with the fundamental idea to revive the 1930s’ concept 

of “parks as classrooms.” With the beginning of a trend to shrink the size of government and the following 

reduction of in-house capability, the NPS was looking at partnerships as a way of accomplishing work. This 

trend has expanded into the new century with vigor as an extensive network of nationwide Cooperative 

Extension Studies Units has been set up at key universities which provides access to university assistance 

with research, treatment development, training and project work for students. 
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90 A Brief History of NPS Management of Archeological Sites in the Southwest

The first of the ACL field schools got under way during the summer of 1992 at Fort Union and Fort Davis, 

focusing on the problem of detached lime plasters on earthen substrates. These represented a large resource typology which was not being addressed largely due to a lack of research, skill, methods and material knowledge. Conserving these authentic fragments of decorated and undecorated lime plaster on adobe 

walls was one of the first challenges undertaken by the university. Three consecutive five-year agreements 

were signed and executed during which research, training and pilot work was undertaken first at these 

two parks and then at others. Through a process of research and laboratory testing, building slowly on a 

knowledge base year by year, these and other difficult treatment problems began to be addressed. As the 

process advanced, graduates went to work in parks on other issues and challenges they addressed in the 

university lab. Those research agendas continue today using the CESU process. 

From the early work on lime plasters, the university began to look at even more difficult problems of 

earthen surfaces, decorated and not, at Bandelier, Casa Grande and, ultimately, at Mesa Verde. Mesa Verde 

work continues through today, advancing research and pilot treatments. Year after year, graduate students 

participated by engaging in the nuances of these challenging research questions through the masters thesis 

process, each building on the advances made by their predecessors. A considerable body of work has 

emerged which at this point is internationally recognized. Three examples of this kind of research effort 

resulting in a direct resource effect were Anne Oliver’s work on the San Antonio Mission San Jose Convento stone column, Bob Hartzler’s work on Rhoplex, and Elisa Del Bono and Kecia Fong’s work on the 

material analyses of Casa Grande. 

Oliver’s research and follow-up treatment of the column at Mission San Jose (1993) established a protocol of treating sandstone with consolidents and water-repellents separately which provided the basis for a 

process to save the extremely deteriorated column through limited reintegration, consolidation and, finally, 

repellent application. In 1996, Bob Hartzler published his thesis research on Rhoplex which established 

and clarified the behavior of this material so that users could finally clearly understand field attributes. This 

study showed that if properly used under controlled conditions and with the correctly balanced soil materials, benefits can be achieved. As stated elsewhere, Rhoplex continues to be the amendment of choice in 

many Southwest sites. Elisa Del Bono in 1999 completed her “Characterization and Analysis of the Caliche 

Walls of the Great House, Casa Grande Ruins National Monument, Coolidge, Arizona.” In her work, Del 

Bono showed through lab analysis that carbonate-rich substrates have been enriching the surface layer 

of the Great House thereby creating a kind of case-hardening of that surface. In essence, her lab work 

demonstrated that capillary moisture migrating to the surface of the walls in the evaporative process was 

depositing a residue of carbonates at the molecular level to enrich this surface. This remarkable conclusion 

demonstrated that when building materials inherently provide the level of protection needed, a hands-off 

approach may be advised. 

In 1993, two facility managers and an archeologist from their respective parks (Salinas, Aztec and Chaco) 

began discussing maintenance backlogs as well as problems in ruins preservation due to the decade or so 

of adverse changes that had been taking place, including the disbanding of the Mobile Unit, retirements 

of skilled personnel working on ruins, misperceptions about archeological site resources and where ruins 

preservation fit into the overall Cultural Resource Management (CRM) process, among other problems 

creating a crisis for these resources. These NPS staff got Vanishing Treasures (VT) started. It was envisioned as a corrective program to improve CRM in this area of work. The focus would be documentation of rate of change to demonstrate the seriousness of the problem, to foster an atmosphere for training 

within the ranks so that those retiring could impart their knowledge to new and younger hires, and to seek 

funding for personnel and projects. This initiative took off and by 1998, VT realized its first full year of 

funding. After ten years of existence, the initiative has become a full Program established in the Intermountain Region which continues to operate largely for its original purposes. 

The creation of the Vanishing Treasures Initiative coincided with the reorganization of the Regional Offices 

and the ultimate dissolution of the Southwest Cultural Resources Center and many of the various divisions 

within. Ultimately the Southwest Region was joined with the Rocky Mountain Region and parts of the 
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A Brief History of NPS Management of Archeological Sites in the Southwest 91

Western Region with the establishment of the Intermountain Region in a nationwide reorganization of the 

NPS. Day labor crews and project work being conducted out of the regional office were ultimately reduced 

with the emergence of a new agenda that was park-based. Central office command and control was over. 

The Ruins Stabilization Unit that started in the 30’s and morphed from being park-based to regional officebased ultimately found itself back in a park being assigned to Bandelier in 2007. 

In 1997, the VT Initiative drafted Guidelines for Ruins Stabilization. This document was never finalized 

and approved. The 1997 document drew heavily upon an earlier text, The 1988 Ruins Stabilization Report 

Technical Series No. 51 - Ruins Stabilization: A Handbook , by Todd R. Metzger. Prior to these works, the 

volume Ruins Stabilization in the Southwestern United States compiled by Roland Von S. Richert and R. 

Gordon Vivian in 1974 (based upon a 1962 revision of Vivian’s 1949 ruins stabilization manual) served to 

provide the field with working guidelines. The Vanishing Treasures Program has evolved and, due to vigilance in publishing an annual report each year in which funding allocations are scrupulously documented, 

the program continues to thrive. Some highlights of the emerging program are: documentation of projects 

and outcomes, sharing resources internally and externally, involving the larger scientific and preservation 

community to address needs and developing and applying new methods of documentation.

In sum, attempting to slow down the effects of nature and physics on ruins deterioration provides a challenge requiring knowledge of the past and the utilization of diverse methods and materials. There can be 

no single solution to all of our preservation problems. In the visionary words of the 1940s Director’s Committee on Ruins Preservation:

Stabilization may be said to be standing, gaunt and lean, among a multiplicity of unapplied 

techniques. The urgent need is exploratory study to determine applicable materials and their 

use in the light of modern conceptions of material physics and mechanics. Only in this way 

can progress be carried forward to that goal of preservation required by the organic legislation establishing the Service.”

Comments on Major Historical Trends and Developments 

Likely the most profound and beneficial shift in emphasis over the more than a century of archeological 

site management has been the shift from recovery archeology to archeology and preservation and, ultimately, the shift to applied conservation and non-destructive archeology. In current times, archeological 

excavations are virtually limited to mitigation only. The early days of plundering sites was immensely destructive to resources. Even though these activities continue illegally, many safeguards are now in place to 

protect sites. Ultimately the value of preserved sites is the information inherent in the sites which benefits 

the visitor and scholar. The thread of history and knowledge inherent in the archeology grows with time as 

new techniques and knowledge emerge to better document, sort and evaluate the information. The Pecos 

conference started a process which continues to enrich the record year by year.

The development of site and fabric preservation treatment programs has evolved from the fundamentals as 

they were first simply and eloquently established at Casa Grande in 1891. A list includes: 

• sheltering resources such as first accomplished at Casa Grande

• reconstruction of the roof at Tumacacori and subsequent reconstruction of roofs at Fort Davis 

forty years later

• the stone and earth wall stabilization at ancestral Puebloan sites which has evolved in very complex 

ways and more often than not is appropriately unique to each site 

• the many uses of modern and modified building materials for stabilization purposes including the 

early use of Portland cement and the introduction of soil cement; other modifiers such as bitumens, later synthetic emulsion modifiers, the use of un-amended earthen materials, cycles of material use 

• the slow steady move toward the application of scientific methods to best define behavior

• the Fort Union Preservation Action Plan and subsequent treatment program including the re-cap-
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92 A Brief History of NPS Management of Archeological Sites in the Southwest

ping of walls

• the re-burial (backfilling) programs throughout the Region as typified by the leadership of those at 

Aztec and Chaco

• realization of the growing awareness on the part of the visiting public who respect authenticity 

which has helped to focus practitioners on preservation rather than restoration

A seminal part of this history are the legislative actions which have originated in Congress to provide the 

legal basis for the work. These include the Antiquities Act of 1906, The Historic Sites Acts of 1935, the 

National Historic Preservation Acts 1966, as amended, and The Native American Graves Repatriation Act 

in 1990. In addition, many other international charters and acts have added to understanding the many 

and varied aspects of preserving archeological sites. One result of the legislation has been increased and 

improved consultation which has improved site interpretation and expanded the influence of stakeholders. 

Partnering between agencies and use of field schools which have evolved from the early activities of Edgar 

Lee Hewett through to Lister and then Matero has had a major impact on preservation development. Beyond the direct benefits of accomplishing research and training coupled with solving field problems, there 

now exists a by-product: expanding the constituent base by involving the public sector in the preservation 

agenda for sites. Often the students from these field schools have found work in the NPS. Gordon Vivian’s 

thirty-year career is a good first example.

Professionalism in the National Park Service got off to a good start in the hiring of staff during the 1930 

Depression-era programs. The Mobile Unit out of Chaco which later moved to Globe, AZ and ultimately 

split off to Farmington, NM, is a good example. Two very different but important individuals were Gordon 

Vivian and Al Lancaster who hired into the Service during the ‘30s and devoted their entire careers to this 

work. In the 1950s, the Mission 66 program resulted in the further internal enlargement of professional 

staff to accomplish preservation work. It continues today as historic preservation has advanced in the academic sphere as a legitimate profession. Many Universities offer MS and MA programs in historic preservation. Graduate certificates in Archeological Site Management are now available at several institutions. The 

University of Delaware offers a Doctorate in Historic Preservation. More and more highly educated and 

trained individuals are finding work in the field and some in the ranks of the National Park Service. These 

professionals advance the capability of staff to deal with increasingly complex, technical, legal and philosophical issues. The advance of these educational influences has not diminished the influence of traditional 

practices in preserving architecture.

Technology has also influenced the work in many ways. Photography became a part of early documentation and the advent of computers along with digitalization has provided many new venues for managing an 

ever-increasing amount of complex data. Internet resources and more sophisticated software continue to 

increase our capabilities, and thus transform the work of resource management. One downside to this new 

development is the potential loss of data due to digitalization. The shift in the mid-1990s to digital media 

from the formal written correspondence left open the possibility of losing large amounts of important 

information since record keeping is no longer controlled by or located in central office files; it’s entirely 

individual driven. So while capability has advanced, the insurance of finding information has declined. 

Since the early days of the first handful of National Monuments, now forty-five parks now participate in 

the VT program, almost double the number Boss Pinkley was responsible for at the end of his career. The 

entire National Park system has also continued to enlarge, increasing the responsibilities of resource personnel year by year. Growth of the National Park System can be directly related to increasing visitation and 

population growth. A by-product of the increase in visitation to parks is the crisis of carrying capacity for 

ruins. Nowhere can this be highlighted better than in the Superintendent’s report in 1965 on Mesa Verde: 

“...facilities are showing the effects of the strain...the ruins most of all...Limit the trips to Balcony House as 

this prehistoric gem has more than reached the breaking point....At Cliff Palace...with hundreds of people 

per hour and rangers being forced to yell above the racket, interpretation...is rapidly becoming a farce.”

Ultimately in 1967 a limitation on tour size was instituted which empowered management to control this 
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A Brief History of NPS Management of Archeological Sites in the Southwest 93

very negative impact.

Many changes occurred over the years and changes continue but the fundamentals remain much the same 

and the issues which surfaced in 1892 are very similar to the ones we face today. Research potential continues to grow exponentially. Treatment programs reflect the times, skills, knowledge and abilities of those 

applying them. Usually they are correct for their times and in retrospect can be easily criticized from the 

viewpoint of new knowledge and findings. There are no magic bullets and there are not likely to be any in 

the future. There is no substitute for good maintenance, dedication, hard work and integrity of approach. 

The following, from an unknown source, sums up the prevailing VT philosophy: 

“Do as little as possible, as much as is necessary.”

Fort Union National Monument capping in 2000
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94 A Brief History of NPS Management of Archeological Sites in the Southwest

Key Events and Founding Dates of Monuments and Parks

Currently forty-five parks in the arid West are within the jurisdiction of the Vanishing Treasures Program. 

Following are dates for the establishment of these parks and some other dates significant to resource preservation and management: 

1879 Founding of Archeological Institute of America

1880 Adolf Bandelier began visiting sites in the Southwest

1888 Richard Wetherhill and Charlie Mason first set eyes on Cliff Palace

1892 Casa Grande Ruin Reservation

1893 Grand Canyon Forest Reserve 

1902 Edgar Hewett mapped sites at Chaco

1904 Hewett’s Memorandum to Congress concerning the historic and pre-historic ruins of Arizona, 

New Mexico, Colorado, Utah and their Preservation. He wrote, “It will be a lasting reproach to 

our government if it does not use its power to restrain the destruction of ruins.”

1906 Antiquities Act 

1906 Montezuma Castle National Monument 

Petrified Forest National Monument 

El Morro National Monument 

Mesa Verde National Park (now listed as a World Heritage Site)

1907 Tonto National Monument

Chaco Canyon National Monument (later to become Chaco Culture National Historical Park, 

now listed as a World Heritage Site) 

Gila Cliff Dwelling National Monument 

The School of American Research (SAR) founded by Hewett

Jesse Walker Fewkes starts to work at Casa Grande

1908 Natural Bridges National Monument

Tumacacori National Monument

Grand Canyon National Monument 

1909 Navajo National Monument

Gran Quivira National Monument established (now Salinas Pueblo Missions)

Zion National Park (proclaimed as Mukuntuweap, NM and later incorporated as Zion, NM in 

1918; established as a National Park in 1919)

1910 Richard Wetherill shot dead at Chaco

Jesse Nusbaum rebuilt the roof on the Kiva in Ceremonial Cave at Bandelier 

1911 Colorado National Monument 

1915 Walnut Canyon National Monument 

Dinosaur National Monument 

1916 Bandelier National Monument

 Organic Act passed by Congress establishing the National Park Service 

1918 Grand Canyon National Park (now listed as a World Heritage Site)

1920 Ken Chapman rebuilt a cliff dwelling “Talus House” at Bandelier.

1923 Hovenweep National Monument

Frank Pinkley chosen as Superintendent of Southwestern National Monuments

1924 Wupatki National Monument 

Aztec Ruins National Monument

1925 At Chaco, Boss Pinkley, who by this time was well in charge of the Southwest Monuments, saw 

to the stabilization of Pueblo Bonito with field assistance from Martin Jackson, who continued in 

1928 with the work 

1927 First Pecos Conference 

1929 Arches National Park

1930 Jesse Walter Fewkes died at the age of 80

1931 Canyon De Chelly National Monument

1933 Saguaro National Park 
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A Brief History of NPS Management of Archeological Sites in the Southwest 95

Death Valley National Monument 

Region 3 (later to become the Southwest Region) established in Santa Fe, NM 

The Historic American Building Survey (HABS) program started

1934 A section of pictograph was glassed in to preserve it at Bandelier’s Long House 

1934 J.F. Motz is recorded as using soil cement mortar at WUPA and soil cement can also be traced to 

TUZI in 1935 in a project supervised by Spicer and Caywood

1935 Big Bend National Park 

The Historic Sites Act 

Ruins Stabilization Unit started at Chaco

Earl Morris completes the Great Kiva reconstruction at Aztec

1936 Joshua Tree National Monument 

1937 Organ Pipe Cactus National Monument 

Capitol Reef National Park

A routine ruins stabilization program initiated at Bandelier by J.W. Hendron; Robert Lister participated

1938 Fort Laramie National Monument 

1939 Tuzigoot National Monument

1939-1940 William Witkind excavated, stabilized, reconstructed ruins at Pecos using CCC who manufactured adobes from historic remains sometimes modified with asphalt emulsion 

1940 Frank “Boss” Pinkley had a heart attack and died on the job

1942 Southwestern National Monuments moves to Santa Fe from Casa Grande

1946 Edgar Lee Hewett died

Charlie Steen tested Ethyl Silicate at Casa Grande

1952 Coronado National Monument

Southwestern National Monuments moved from Santa Fe to Globe, AZ

1954 Fort Union National Monument

1954 Ray Rigenback photographed at Tumacacori spraying ethyl silicate on the school house walls

1956 The Mobile Unit was renamed the Ruins Stabilization Unit and was moved to Globe, AZ with 

Gordon Vivian was still directing it

 Mission 66 Program launched 

 Archeologist George Cattanach began clearing the site and applying preservation treatments at 

Fort Union

1957 Roland Richert, Field Director for the RSU installed sheltering roofs over eleven prehistoric ones 

at AZRU.

 - Southwestern National Monuments ceased operation with some functions and personnel relocated to the Southwestern Archeological Center

 - Cattanach began experimenting with water repellents on adobe walls at Fort Union

1958-60 Rex Wilson took over from Cattanach and continued spray on treatments; installed soil cement 

caps on walls (FOUN)

1958-66 Gordon Vivian served as Chief, Southwest Archeological Center in Globe, AZ

1961 Fort Davis National Historical Site

1962 Prehistoric Ruins Stabilization Handbook- Part 2, Field Methods published

1963 Fort Davis began reroofing ruins utilizing concrete bond beams to stabilize wall tops and support 

rafters thereby protecting ruins

1964 Canyonlands National Park

Fort Bowie National Historic Site

1965 Pecos National Monument 

Lake Meredith National Recreation Area 

Golden Spike National Historic Site

 - The Archeological Research Center was established at Mesa Verde National Park by Dr. Robert 

Lister

1966 Guadalupe Mountains National Park 

 - The National Historic Preservation Act (NHPA)
Vanishing Treasures Resources

96 A Brief History of NPS Management of Archeological Sites in the Southwest

1967 Archeologist Don Morris and RSU Chief Roland Richert visited Fort Bowie and made major stabilization recommendations including the addition of soil cement caps. Chaco crews were used to 

accomplish the work.

1968 Don Morris revisited Fort Bowie and determined that Pencapsula (polyurethane resin) applications were a failure as the polymer-saturated layer was sloughing off

1971 The Establishment of the Chaco Center (NPS & UNM) under the direction of Dr. Robert Lister 

and Dr. James Judge

1971 Perry Borchers began to record sites using photogrammetry followed by laboratory-created drawings based on photo work

1972 Glen Canyon National Recreation Area

1974 Ruins Stabilization in the Southwestern United States, by Richert & Vivian published

1977 The Southwest Cultural Resources Center, Santa Fe was founded

Wilcox and Shenk published The Architecture of The Casa Grande and Its Interpretation, including 

detailed drawings and photography of the walls of the ruin (a benchmark for documentation) 

James Clifton published Preservation of Historic Adobe Structures: A Status Report, (National Bureau of Standards), in which he stated, “Existence of a universal preservation material or process 

is doubtful....”

1978 San Antonio Missions National Historical Park

 - Clifton and Robbins published a second volume for the National Bureau of Standards entitled, 

Methods for Characterizing Adobe Materials

 - Lab Assessment of Soil Cement Mortars, by Fenn et. al. published

1981 Todd E. Rutenbeck, structural engineer with the Division of Adobe/Stone Conservation at the 

Western Archeological and Conservation Center, Tucson, Arizona published an article on Monitoring Structural Movements in the National Park Service CRM BULLETIN Vol.4, No.1; (Ruteneck is noted for installing the first crack monitors.)

 Documentation as treatment represented in Larry Nordby’s Sliding Rock Report

 1987 El Malpais National Monument

1990 Native American Graves Repatriation Act

1990 The International Earthen Architecture Preservation Conference, Adobe 90, was held in Las 

Cruces, New Mexico

1991 The Southwest Region of the NPS and the Graduate Program in Historic Preservation at the University of Pennsylvania launched a Cooperative Agreement to participate in research, training, and 

pilot treatment development at multiple parks

1992 Manzanar National Historical Site

1994 Mojave National Preserve

1994 The NPS as part of the government reinvention act entered into the paperless age in which 

records are no longer consistently maintained in hard copy

1995 The NPS reorganized its regional divisions, and parts of the former Southwest, Western and the 

Rocky Mountain Regions were reconfigured into the Intermountain Region

1998 The VT Initiative began receiving funding for projects and park-based staff increased by sixty over 

the following ten years

2000 “Standards for Field Data Collection and Documentation,” by Nordby, Metzger, Williams and 

Mayberry published at Mesa Verde

2001 Protective Shelters colloquium and publication

2004 Site Reburial colloquium and publication

2006 The Conservation of Decorated Surfaces on Earthen Architecture colloquium and publication 

2008 Vanishing Treasures completed the transition from an Initiative to a Program
Preservation and Management Guidelines

Selected Readings 97

APPENDIX H 

Selected Readings

For a more complete listing of sources and other bibliographic references, see the Intranet site

Adams, Jenny L., Pinto Beans and Prehistoric Pots: The Legacy of Al and Alice Lancaster, Arizona State Museum, Univeristy of Arizona, Arizona State Museum Archeological Series 183, 1994.

Adobe Conservation: A Preservation Handbook, Cornerstones Community Partnerships, Santa Fe, N.M., 

Sunstone Press, 2006.

Clemenson, A. Berle, Casa Grande Ruins National Monument, Arizona: A Centennial History of the First 

Prehistoric Preserve 1892-1992, Administrative History, United States Department of the Interior, National 

Park Service, 1992.

Clifton, James R. “Preservation of Historic Adobe Structures: A Status Report,” U.S. Department of Commerce, February 1977.

Del Bono, Elisa Maria, “Characterization and Analysis of the Caliche Walls of the Great House, Casa 

Grande Ruins National Monument, Coolidge, Arizona,” unpublished manuscript, University of Pennsylvania, 1999.

Dowdy, K. and Taylor, M.R.., “Investigations into the Benefits of Site Burial in the Preservation of Prehistoric Plasters in Archaeological Ruins,” presented at the 7th International Conference on the Study and 

Conservation of Earthen Architecture, Direccao Geral dos Edificios e Monumentos Nacionais, Lisbon, 

1993.

Elliott, Melinda, Great Excavations, School of American Research Press, Santa Fe, New Mexico, 1995.

Fewkes, J. Walter, “A Report on the Present Condition of a Ruin in Arizona Called Casa Grande,” Vol. 2, A 

Journal of American Ethnology and Archaeology (Boston: Houghton Mifflin and Co., 1892), 1979.

Firor, James., Ruins Stabilization: A Handbook, technical supplement No. 2, Agents of Deterioration, National Park Service, 1988.

Hartzler, Robert, Acrylic Modified Earthen Mortar A Program of Investigation and Laboratory Research into 

Acrylic-Modified Earthen Mortar Used at Three Prehistoric Pueblo Sites, Intermountain Cultural Resources 

Center, technical paper No.61, National Park Service, Santa Fe, New Mexico, 1996.

Lister, Florence C., Trowelling Through Time, University of New Mexico Press, 2004.

Matero, F and Cancino, C., “The Conservation of Earthen Archaeological Heritage: An Assessment of 

Recent Trends,” presented at Terra 2000: 8th International Conference on the Study and Conservation of 

Earthen Architecture, Torquay, Devon, UK, English Heritage, London, May 2000.

Metzger, Todd R., Ruins Stabilization Report Technical Series No. 53, Ruins Stabilization: A Handbook, 

National Park Service, Rocky Mountain Region, Denver, Colorado, 1988.

Mindeleff, Cosmos, The Repair of Casa Grande Ruin, Arizona, Fifteenth Annual Report of the Bureau of 

Ethnology to the Secretary of the Smithsonian Institution, Government Printing Office, Washington, D.C., 

1897.

Moss, Jeremy, “Of Adobe, Lime, and Cement: A History of Archeology, Preservation and Stabilization at 
Vanishing Treasures Resources

98 Selected Readings

San Jose de Tumacacori, 1919-2005,” unpublished draft provided by the author, Tumacacori, Arizona.

National Park Service, “Handbook for Ruins Stabilization, Part 2: Field Methods,” Release 1, Department 

of the Interior, Washington D.C., 1962.

Nordby, Larry; Matlock, Gary; Creutz, A. William; “A Stabilization History of Pecos 1974 and Before,” 

unpublished manuscript, Intermountain Region, 1975. 

Nordby, Larry V., “Non-Destructive Archeology at Sliding Rock Ruin: An Experiment in the Methodology 

of the Conservation Ethic,” Southwest Cultural Resources Center, 1981.

Oliver, Anne and Hartzler, Robert, “Working Preservation Action Plan For the Adobe Ruins at Fort Union 

National Monument, New Mexico:” Implementation Project Final Report, June, 1996.

Silver, Constance; and Snodgrass, J. and Wolbers, R., “A Program for the Conservation of Prehistoric Mural 

Paintings on Mud Renderings in the American Southwest,” presented at the 7th International Conference 

on the Study and Conservation of Earthen Architecture, Direccao Geral dos Edificios e Monumentos Nacionais, Lisbon, 1993.

Torres-Reyes, Ricardo, “Mesa Verde National Park, An Administrative History 1960 -1970,” Office of History and Historic Architecture, Eastern Service Center, United States Department of the Interior, National 

Park Service, Washington, D.C., 1970.

Trott, Jim, “Ruins Preservation: Pre-Columbian and Historic Ruins Preservation in the Arid Southwest,” 

CRM, Vol.20, No.10, 1997, U.S. Dept. of the Interior, National Park Service, Cultural Resources, Washington, D.C., 1997.

Welsh, Michael, “A Special Place, A Sacred Trust: Preserving The Fort Davis Story,” Administrative History, 

Fort Davis National Historic Site, National Park Service, Intermountain Cultural Resource Center, Professional Paper No. 58, Santa Fe, New Mexico, 1996.

Wilcox, David R. and Sternberg, Lynette O., “The Architecture of the Casa Grande and Its Interpretation,” 

Arizona State Museum, University of Arizona, 1977.

Wilson, Rex L., “Fort Union National Monument, New Mexico, Rehabilitation of Historic Structures 

1956-1960,” Final Report Vol. I., 1960. 

Zhu, Liping, “Fort Union National Monument: An Administrative History,” Southwest Regional Office, Division of History, Southwest Cultural Resources Center, Professional Paper No.42, Santa Fe, New Mexico, 

1992.
Preservation and Management Guidelines

Summary of Museum Responsibilities 99

APPENDIX I

Summary Of Museum Responsibilities

The projects conducted under the Vanishing Treasures Program are designed and implemented to 

promote ruins preservation. Information about the project and any resulting archeological objects 

and architectural samples are preserved by adding them to the park’s museum collection. Ensure 

that each project includes funding to accession and catalog the collection, and properly store it in 

the designated repository per Directors Order 24.

The designated project coordinator is responsible for ensuring that all documentation, objects and 

samples are assembled for the museum collection and deposited with the curator as a complete accession. The collection should be housed in acid-free materials and be labeled properly and packaged for long-term storage. Consult with the repository in which the collections will be curated 

for their standard boxing, foldering and labeling instructions and recommended materials. Each 

repository uses different materials and box sizes to facilitate storage and for optimal preservation of 

the collections.

Projects produce field documentation in a variety of formats, including electronic and paper records. Use the list from Directors Order 28 (reproduced in the Processing and Cataloging Handbook) to ensure that all relevant documentation has been assembled. Print electronic files and a 

sample of digital photographs for each project to ensure that the information is available if future 

migration efforts with the electronic media are unsuccessful. Include appropriate metadata for all 

electronic files. Catalog this field documentation as archives following the step-by-step procedures 

in the Processing and Cataloging Handbook developed by the Intermountain Region Museum Services Program (we will provide a copy so you can scan and post).

Cataloging archeological collections and architectural samples should follow the guidelines in the 

Museum Handbook, Part II. Contact the park curator and the designated repository before initiating 

cataloging, as object name lists or other specific conventions may be used in cataloging to facilitate 

database searches. Project managers are encouraged to include the results of analyses in the catalog 

records to maximize the information available for future research. Consult with your park curator about the most appropriate method for incorporating this information. Remember to separate 

items physically so they can be retrieved by future users. For example, if ten different types of paint 

chips have been identified from a single provenience, make certain that each type is bagged and 

labeled separately so there will be no question about which chips are which type. Consult with the 

designated repository for instructions on labeling and organizing the collection for permanent storage, as some facilities store by material type and others by provenience.
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100 Consultation Guidelines: Section 106 and Tribal Consultation

APPENDIX J

Consultation Guidelines: Section 106 and Tribal Consultation

Section 106 Regulations 

Initiate the Section 106 process (800.3)

Federal agencies are encouraged to integrate the Section 106 process into agency planning at its earliest 

stages. 

Establish undertaking (800.3(a))

The determination of whether or not an undertaking exists is the Agency Official’s decision. However, the Council may render advice on the existence of an undertaking. If there is an undertaking, but 

it does not present a type of activity that has the potential to have an effect on an historic property, 

then the agency is finished with its Section 106 obligations. If the action is subject to a program alternative, such as Programmatic Agreement or an alternate agency procedure, then the agency should 

follow that process.

800.3(b) This section emphasizes the benefit to an agency of coordinating compliance with related 

statutes to increase efficiency and avoid duplication of efforts. However, this coordination is not 

mandatory and is up to the Agency Official. Although agencies are encouraged to use the information 

gathered for these other processes to meet Section 106 needs, the information must meet the standards in these regulations. 

Identify appropriate SHPO/THPO (800.3 (c)-(d) )

The Federal agency has the responsibility to properly identify the appropriate SHPO and/or THPO 

that must be consulted. If the undertaking is on or affects historic properties on tribal lands, then the 

agency must determine what tribe is involved. If the relevant tribe has assumed the SHPO’s responsibilities for Section 106 under Section 101(d)(2) of the Act, thereby having a THPO, the agency must 

consult with such THPO in lieu of the SHPO. A list of THPOs is available from the National Park 

Service. Certain owners of property on tribal lands can request SHPO involvement in addition to the 

THPO in a Section 106 case in accordance with the Act. If the relevant tribe has not assumed SHPO 

responsibilities for Section 106 under Section 101(d)(2) of the Act, the agency consults with such 

tribe and the SHPO. 

Other related points include: 

A group of SHPOs may agree to designate a lead SHPO to act on their behalf for a specific undertaking. 

The manner of consultation may vary depending on the agency’s planning process, the nature of 

the undertaking, and the nature of its effects. 

Failure of a SHPO/THPO to respond within the time frames set by the regulation permit the 

agency to assume concurrence with the finding or to consult about the finding or determination 

with the Council in the SHPO/THPO’s absence. Subsequent involvement by the SHPO/THPO 

is not precluded, but the SHPO/THPO cannot reopen a finding or determination that it failed to 

respond to earlier.

For undertakings occurring, or affecting historic properties, on tribal lands, the Section 106 

process may be completed even when the SHPO has decided not to participate in the process. 

A SHPO and a tribal representative may develop tailored agreements for SHPO participation in 

reviewing undertakings on the tribe’s lands. 

* The regulations define the term “THPO” as those tribes that have assumed SHPO responsibilities 

on their tribal lands and have been certified pursuant to Section 101(d)(2) of the NHPA. Nevertheless, remember that tribes that have not been so certified have the same consultation and concurrence rights as THPOs when the undertaking takes place, or affects historic properties, on their 

tribal lands. The practical difference is that during such undertakings, THPOs would be consulted 

in lieu of the SHPO, while non-certified tribes would be consulted in addition to the SHPO.

•

•

•

•
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Consultation Guidelines: Section 106 and Tribal Consultation 101

Plan to involve the public (800.3(e))

The Agency Official must decide early how and when to involve the public in the Section 106 process. 

A formal “plan” is not required, although that might be appropriate depending upon the scale of the 

undertaking and the magnitude of its effects on historic properties.

Identify other consulting parties (800.3(f))

The Agency Official, at an early stage of the Section 106 process, is required to consult with the 

SHPO/THPO* to identify those organizations and individuals that will have the right to be consulting 

parties under the terms of the regulations. These may include local governments, Indian tribes, and 

Native Hawaiian organizations, and applicants for Federal assistance or permits. Others may request 

to be consulting parties, but that decision is ultimately up to the Agency Official. 

No undertaking/no potential to cause effects (800.3(a)(1)) 

If the Agency Official determines that there is no undertaking as defined in Section 800.16(y), or 

there is an undertaking but it is not a type of activity that has the potential to cause effects on historic 

properties, there are no further obligations under Section 106 or the Council’s regulations. 

Agencies are strongly advised to keep appropriate records of such findings in case questions are 

raised by members of the public or other parties at a later date. 

Undertaking might affect historic properties

Assuming that the Agency Official has determined that the undertaking is a type of activity that has 

the potential to cause effects on historic properties, the agency proceeds to identify properties that 

might be affected.

Identify historic properties (800.4) 

• Determine scope of efforts (800.4(a)) 

At the beginning stages of the identification process, the Agency Official must consult with the 

SHPO/THPO* on the scope of its identification efforts and in fulfilling the steps in subsections 1 

through 4. These steps include: 

determining and documenting the area of potential effects; 

reviewing existing information about historic properties; 

seeking information from parties likely to have knowledge of or concerns about the area; and 

gathering information from Indian tribes and Native Hawaiian organizations about properties to 

which they attach religious and cultural significance, while remaining sensitive to any concerns 

they may have about the confidentiality of this information.

The SHPO/THPO should be consulted at all steps in the scoping process. The determination of the 

area of potential effects is made unilaterally by the Agency Official, after such consultation. Where 

Federal agencies are engaged in an action that is on or may affect ancestral, aboriginal or ceded lands, 

Federal agencies must gather information from Indian tribes and Native Hawaiian organizations regarding properties that may be of traditional religious and cultural significance to them, and that may 

be eligible for the National Register, on such lands. 

• Identify historic properties (800.4(b))

This section sets out the steps an Agency Official must follow to identify historic properties. Reminders scattered throughout the section emphasize the need for consultation with various parties. 

800.4(b)(1) The standard for identification is a “reasonable and good faith effort” to identify historic 

properties, depending on a variety of factors (including, but not limited to, previous identification 

work). Appropriate identification may include background research, consultation, oral history interviews, sample field investigation, and field survey. 

800.4(b)(2) Phased identification may be done when alternatives under consideration consist of corridors or large land areas, or where access to properties is restricted, and the nature of the undertaking 

and its potential scope and effect has therefore not yet been completely defined. Final identification 

•

•

•

•
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102 Consultation Guidelines: Section 106 and Tribal Consultation

and evaluation may also be deferred if provided for in an agreement with the SHPO/THPO* or other 

circumstances. Under this approach, Agency Officials are required to follow up with full identification and evaluation once project alternatives have been refined or access has been gained to previously restricted areas. Any further deferral of final identification would complicate the process and 

jeopardize an adequate assessment of effects and resolution of adverse effects.

• Evaluate historic significance (800.4(c)) 

This section sets out the process for determining the National Register eligibility of properties not 

previously evaluated for historic significance. 

800.4(c)(1) Federal agencies are required to apply the National Register Criteria to properties identified in the area of potential effects, and to acknowledge the special expertise of Indian tribes and Native Hawaiian organizations when assessing the eligibility of a property to which they attach religious 

and cultural significance. Old determinations of eligibility may need to be re-evaluated due to the 

passage of time or other factors. 

800.4(c)(2) The Agency Official makes determinations of eligibility in consultation with the SHPO/

THPO*. If there is disagreement or the Council or Secretary of Interior so requests, the Agency Official must refer the matter to the Keeper of the National Register. If an Indian tribe or Native Hawaiian organization disagrees with a determination of eligibility involving a property to which it attaches 

religious and cultural significance, then the tribe can ask the Council to request that the Agency 

Official obtain a determination of eligibility. The intention is to provide a way to ensure appropriate determinations regarding properties located off tribal lands to which tribes attach religious and 

cultural significance. 

No historic properties affected (800.4(d)(1)) 

Assuming that the Agency Official has determined that the undertaking is a type of activity that has 

the potential to cause effects on historic properties, the agency proceeds to identify properties that 

might be affected.

Historic properties are affected (800.4(d)(2))

The Federal agency must proceed to the assessment of adverse effects where it finds that historic 

properties may be affected or the SHPO/THPO* or Council objects to a no historic properties affected finding. The agency must notify all consulting parties and invite their views. Certified tribes 

would be consulted in addition to the SHPO.

Assess adverse effects (800.5) 

800.5(a) The SHPO/THPO*, and Indian tribes and Native Hawaiian organizations attaching religious 

and cultural significance to identified properties, must be consulted when agencies apply the criteria 

of adverse effect. The Agency Official also needs to consider the views of consulting parties and the 

public.

• Apply criteria of adverse effect (800.5(a)) 

800.5(a)(1) Adverse effects occur when an undertaking may directly or indirectly alter characteristics of a historic property that qualify it for inclusion in the Register. Reasonably foreseeable 

effects caused by the undertaking that may occur later in time, be farther removed in distance, or be 

cumulative also need to be considered. 

800.5(a)(2) Examples of adverse effects include physical destruction or damage; alteration not 

consistent with the Secretary of the Interior’s Standards; relocation of a property; change of use or 

physical features of a property’s setting; visual, atmospheric, or audible intrusions; neglect resulting 

in deterioration; or transfer, lease, or sale of a property out of Federal ownership or control without 

adequate protections. 

If a property is restored, rehabilitated, repaired, maintained, stabilized, remediated or otherwise 
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Consultation Guidelines: Section 106 and Tribal Consultation 103

changed in accordance with the Secretary’s Standards, then it will not be considered an adverse 

effect (assuming that the SHPO/THPO* agrees). Where properties of religious and cultural significance to Indian tribes or Native Hawaiian organizations are involved, neglect and deterioration may be recognized as qualities of those properties and thus may not necessarily constitute an 

adverse effect. 

If a property is transferred leased or sold out of Federal ownership with proper preservation 

restrictions, then it will not be considered an adverse effect as in the past regulations. Transfer between Federal agencies is not an adverse effect per se; the purpose of the transfer should be evaluated for potential adverse effects, so that they can be considered before the transfer takes place. 

Alteration or destruction of an archaeological site is an adverse effect, whether or not recovery of 

archaeological data from the site is proposed. The Council has issued guidance to help agencies 

and others reach agreement on the treatment of such properties. 

800.5(a)(3) This section is intended to allow flexibility in Federal agency decision making processes 

and to recognize that phasing of adverse effect determinations, like identification and evaluation, 

is appropriate in certain planning and approval circumstances, such as the development of linear 

projects where major corridors are first assessed and then specific route alignment decisions are 

made. 

800.5(b) The SHPO/THPO* may suggest changes in a project or impose conditions so that adverse 

effects can be avoided and thus result in a no adverse effect determination. This subsection emphasizes that a finding of no adverse effect is only a proposal when the Agency Official submits it to the 

SHPO/THPO* for review. This subsection also acknowledges that the practice of “conditional No 

Adverse Effect determinations” is acceptable. 

800.5(c) The Council will not review no adverse effect determinations on a routine basis. The 

Council will intervene and review no adverse effect determinations if it deems it appropriate based 

on the criteria listed in Appendix A (circumstances warranting Council involvement), or if the 

SHPO/THPO* or another consulting party and the Federal agency disagree on the finding and the 

agency cannot resolve the disagreement. If Indian tribes or Native Hawaiian organizations disagree 

with the finding, they can request the Council’s review directly, but this must be done within the 30 

day review period. 

If a SHPO/THPO* fails to respond to an Agency Official finding within the 30 day review period, 

then the Agency Official can consider that to be SHPO/THPO* agreement with the finding. When 

the finding is submitted to the Council, it will have 15 days for review; if it fails to respond within 

the 15 days, then the Agency Official may assume Council concurrence with the finding. When it 

reviews no adverse effect determinations, the Council will limit its review to whether or not the 

criteria have been correctly applied. The Council’s determination is binding. 

No historic properties are adversely affected (800.5(d)(1))

If no historic properties are found or no effects on historic properties are found, the Agency Official 

provides appropriate documentation to the SHPO/THPO* and notifies consulting parties. Members 

of the public need not receive direct notification, but the Federal agency must place its documentation in a public file prior to approving the undertaking, and provide access to the information when 

requested by the public. 

Once adequate documentation is received, the SHPO/THPO has 30 days to object to the determination. The Council may also object on its own initiative within the time period. Lack of such objection 

within the 30 day period means that the agency has completed its Section 106 responsibilities. 

Historic properties are adversely affected (800.5(d)(2))

A finding of adverse effect requires further consultation on ways to resolve it.
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104 Consultation Guidelines: Section 106 and Tribal Consultation

Resolve adverse effects (800.6)

The process for resolving adverse effects has been changed to reflect the altered role of the Council 

and the consulting parties.

• Continue consultation

800.6(a)(1) When adverse effects are found, the consultation must continue among the Federal 

agency, SHPO/THPO* and consulting parties to attempt to resolve them. The Agency Official 

must always notify the Council when adverse effects are found and must also invite the Council 

to participate in the consultation when any of the circumstances in 800.6(a)(1)(i)(A)-(C) exist. A 

consulting party may also request the Council to join the consultation. The Council will decide on 

its participation within 15 days of receipt of a request, basing its decision on the criteria set forth 

in Appendix A. Whenever the Council decides to join the consultation, it must notify the Agency 

Official and the consulting parties. It must also advise the head of the relevant Federal agency of 

its decision to participate. This is intended to keep the policy level of the Federal agency apprized 

of those cases that the Council has determined present issues significant enough to warrant its 

involvement. 

800.6(a)(2) New consulting parties may enter the consultation if the agency and the SHPO/THPO* 

(and the Council, if participating) agree. If they do not agree, it is desirable for them to seek the 

Council’s opinion on the involvement of the consulting party. Any party, including applicants, 

licensees or permittees, that may have responsibilities under a Memorandum of Agreement must 

be invited to participate as a consulting party. 

800.6(a)(3) The Agency Official is obligated to provide project documentation to all consulting parties at the beginning of the consultation to resolve adverse effects. Particular note should be made 

of the reference to the confidentiality provisions. 

800.6(a)(4) The Federal agency must provide an opportunity for members of the public to express 

their views on an undertaking. The provision embodies the principles of flexibility, relating the 

agency effort to various aspects of the undertaking and its effects upon historic properties. The 

Federal agency must provide them with notice such that the public has enough time and information to meaningfully comment. 

If all relevant information was provided at earlier stages in the process in such a way that a wide 

audience was reached, and no new information is available at this stage in the process that would 

assist in the resolution of adverse effects, then a new public notice may not be warranted. However, this presumes that the public had the opportunity to make its views known on ways to resolve 

the adverse effects. 

800.6(a)(5) Although it is in the interest of the public to have as much information as possible in order to provide meaningful comments, this section acknowledges that information may be withheld 

in accordance with Section 304 of the NHPA. 

Memorandum of Agreement (800.6(b)

If the Council is not a part of the consultation, then a copy of the Memorandum of Agreement must 

be sent to the Council so that the Council can include it in its files to have an understanding of a 

Federal agency’s implementation of Section 106. This does not provide the Council an opportunity 

to reopen the specific case, but may form the basis for other actions or advice related to an agency’s 

overall performance in the Section 106 process. 

800.6(b)(1) When resolving adverse effects without the Council, the Agency Official consults with 

the SHPO/THPO and other consulting parties to develop a Memorandum of Agreement. If this is 

achieved, the agreement is executed between the Agency Official and the SHPO/THPO and filed 

with required documentation with the Council. This filing is the formal conclusion of the Section 

106 process and must occur before the undertaking is approved. Standard treatments adopted by the 

Council may set expedited ways for competing memoranda of agreement in certain circumstances. 
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Consultation Guidelines: Section 106 and Tribal Consultation 105

800.6(b)(2) When the Council is involved, the consultation proceeds in the same manner, but the 

agreement of the Agency Official, the SHPO/THPO and the Council is required for a Memorandum 

of Agreement. 

800.6(c) A Memorandum of Agreement evidences an agency’s compliance with Section 106 and the 

agency is obligated to follow its terms. Failure to do so requires the Agency Official to reopen the 

Section 106 process and bring it to suitable closure as prescribed in the regulations. The reference to 

Section 110(l) of the Act is intended to conform the streamlining provisions of these regulations with 

current statutory requirements, pending amendment of that section. 

800.6(c)(1) The rights of signatories to an agreement are spelled out, along with who is required to 

sign the agreement under specific circumstances. The term “signatory” has a special meaning as 

described in this section, which is the ability to terminate or agree to amend the Memorandum of 

Agreement. The term does not include others who sign the agreement as concurring parties. 

800.6(c)(2) Certain parties may be invited to be signatories in addition to those specified in Section 800.6(c)(1). They include individuals and organizations that should, but do not have to, sign 

agreements. It is particularly desirable to have parties who assume obligations under the agreement 

become formal signatories. However, once invited signatories sign MOAs, they have the same rights 

to terminate or amend the MOA as the other signatories. 

800.6(c)(3) Other parties may be invited to concur in agreements. They do not have the rights to 

amend or terminate an MOA. Their signature simply shows that they are familiar with the terms of 

the agreement and do not object to it. 

800.6(c)(4)-(9) These sections set forth specific features of a Memorandum of Agreement and the 

way it can be terminated or amended. 

Failure to resolve adverse effects (800.7) 

What happens when the consulting parties cannot reach agreement? Usually when consultation 

is terminated, the Council renders advisory comments to the head of the agency, which must be 

considered when the final agency decision on the undertaking is made. There may be circumstances 

where the Council will recommend further discussion to try to resolve the matter.

ACHP comment and agency response 

800.7(a)(1) The head of the agency or an Assistant Secretary or officer with major department-wide 

or agency-wide responsibilities must request Council comments when the Agency Official terminates 

consultation. Section 110(l) of the NHPA requires heads of agencies to document their decision 

when an agreement has not been reached under Section 106. 

800.7(a)(2) The Council and the Agency Official may conclude the Section 106 process with a Memorandum of Agreement between them if the SHPO terminates consultation. 

800.7(a)(3) If a THPO* terminates consultation, there can be no agreement with regard to undertakings that are on or affect properties on tribal lands. In such cases, the Council will issue formal comments. This provision respects the tribe’s unique sovereign status with regard to its lands. 

800.7(a)(4) In cases where the Council terminates consultation, the Council has the duty to notify all 

consulting parties prior to commenting. The role given to the Federal Preservation Officer is intended to fulfill the NHPA’s goal of having a central official in each agency to coordinate and facilitate the 

agency’s involvement in the national historic preservation program. 

800.7(b) The Council may provide advisory comments even though it has signed a Memorandum of 

Agreement. This provision is intended to give the Council the flexibility to provide comments even 
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106 Consultation Guidelines: Section 106 and Tribal Consultation

where it has agreed to sign an MOA. Such comments might elaborate upon particular matters or 

provide suggestions to Federal agencies for future undertakings. 

800.7(c) The Council has 45 days to provide its comments to the head of the agency for a response by 

the agency head. When submitting its comments, the Council will also provide the comments to the 

Federal Preservation Officer, among others, for information purposes. 

800.7(c)(4) This section specifies what it means to “document the agency head’s decision” as required by Section 110(l) when the Council issues its comment to the agency head. 

Updated February 12, 2001 
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Consultation Guidelines: Section 106 and Tribal Consultation 107

 TRIBAL CONSULTATION FAQs

What is Consultation?

Consultation is the basic means by which American Indian tribes and federal agencies approach and 

resolve differences in the application of policies and regulations. Government-to-Government consultation is recognition of tribal sovereignty and the unique legal and historic relationship between the 

U.S. Government and Indian tribes shaped by treaties, congressional acts, court decisions, Executive 

Orders and other actions of the Executive Branch.

Why is consultation necessary?

Numerous laws require agencies to consult with American Indian tribes on federal actions. Federal 

actions are defined as projects, activities or programs funded in whole or in part under the direct or 

indirect jurisdiction of a federal agency, including those carried out by or on behalf of a federal agency; 

those carried out with federal financial assistance; those requiring a federal permit, license or approval; 

and those subject to state or local regulation administered pursuant to a delegation or approval by a 

federal agency. The decision for an agency to enter into consultation depends upon adherence to federal law, regulation, and agency policy as well as on the nature and scale of the project. Tribal governments may also request formal consultation on issues of interest at their discretion. 

What Laws, Regulations, Director’s Orders, Policies and Guidelines require federal agencies to consult?

National Historic Preservation Act (NHPA) of 1966, as amended (P.L. 89-665; 16 U.S.C. 470 et.seq.): 

Section (§) 106 of the act requires federal agencies to review federally funded projects for their affect on cultural properties. The statute and implementing regulations (36 CFR 800) require American Indian tribes to participate when an undertaking or project affects Indian lands or properties of 

historic value to an Indian tribe on non-Indian lands. When it is determined by the federal agency that 

an action or undertaking may have an effect on these properties, representatives of appropriate Indian 

tribes are to be invited to consult. § 110(d) of the act also calls for consultation with American Indian 

tribes when preservation activities are planned. At a minimum, preliminary ethnographic or ethno historic research is required to make any determination of effect resulting from federally funded projects. 

The need for consultation should arise from this preliminary work and initial contacts related to the 

proposed undertaking. § 304(a) of the act makes it possible for agencies to maintain confidentiality of 

information obtained during consultation regarding the location of sensitive resources.

National Environmental Policy Act (NEPA) of 1969 (P.L. 91-190; 42 U.S.C.4371 et. seq.): Directs 

federal agencies to consult early with American Indian tribes concerning planned actions by private 

applicants or other non-federal agencies [see 40 CFR 1501.2(d) (2)]. Regulations also require agencies to invite tribes to participate in the project scoping process and those possible conflicts between 

the proposed project and tribal land use plans, policies or controls for use of a concerned area are 

discussed as Environmental Consequences [see 40 CFR 1501.7(a)(1) and 1502.16(c), respectively]. 

NEPA requires agencies to request tribal comments on draft Environmental Impact Statements and 

agencies to notify tribes of proposed projects of local concern. The law also authorizes Indian tribes 

to be cooperating agencies in NEPA compliance. 

American Indian Religious Freedom Act (AIRFA) of 1978 (P.L. 95-431): Recognizes that the constitutional right of all U.S. citizens to practice their respective religions also includes American Indians. The 

law states that it is the “policy of the United States to protect and preserve for American Indians their 

inherent right of freedom to believe, express, and exercise [their] traditional religions...including but 

not limited to access to sites, use and possession of sacred objects...”

Archeological Resource Protection Act (ARPA) of 1979 (P.L. 96-95): § 7 of the act requires consultation with American Indian tribes if issuance of a permit will result in harm or destruction of a site that 

has importance to that community. 

Native American Graves Protection and Repatriation Act (NAGPRA) of 1990 (P.L. 101-601): Requires 
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108 Consultation Guidelines: Section 106 and Tribal Consultation

federal agencies and museums receiving federal funds to conduct summaries and inventories of their 

collections or holdings, identify potential lineal descendant(s) or cultural affiliated tribes and consult 

with tribes regarding the repatriation of human remains, funerary objects, sacred objects and objects 

of cultural patrimony as defined by NAGPRA. The statute also outlines requirements for inadvertent 

discoveries of American Indian grave sites including a ceasing of all activity at that site for thirty days 

following an inadvertent discovery to allow consultation with affiliated tribes to take place regarding 

the protection or re-internment of the remains.

National Register Bulletin 38 – Traditional Cultural Properties n.d.: Defines a new category of properties for consideration to the National Register of Historic Places (NRHP) based on the authority of 

NHPA. Bulletin 38 defines eligibility criteria for placing a Traditional Cultural Property on the National Register and outlines the need for field research and culturally sensitive consultation with groups 

having an affiliation with the property under consideration.

Executive Order 13175, “Consultation and Coordination with Indian Tribal Governments” 1993 (DOI 

only): Reinforces the responsibility of all Interior agencies toward the protection of trust resources of 

all federally recognized tribes and directs Interior agencies to operate within a government-to-government relationship with Indian tribes on all matters dealing with trust resources.

Executive Order 12898, “Environmental Justice” 1994 (All federal agencies): Requires all federal agencies to “make achieving environmental justice part of its mission by identifying and addressing, as appropriate, disproportionately high and adverse human health or environmental effects of its programs, 

policies, and activities on minority populations and low-income populations in the United States...” 

The order specifically addresses the need for agencies to collect, maintain and analyze information 

on the consumptive patterns of populations relying principally on fish and/or wildlife for subsistence. 

Details of tribal involvement in the execution of this order will be determined after consultation with 

federally recognized tribes.

Executive Order 13007, “Sacred Sites” 1996 (All federal agencies): Requires each agency to “(1) accommodate access to and ceremonial use of Indian sacred sites by Indian religious practitioners and (2) 

avoid adversely affecting the physical integrity of such sacred sites.” 

Other laws, regulations, policies and guidelines that have secondary relevance to the need to consult with 

American Indian tribes: 

• Antiquities Act of 1906 (P.L. 209), as amended: Provides for the protection of historic or prehistoric 

remains and sites of scientific value on federal lands, establishes criminal sanctions for unauthorized 

destruction or removal of antiquities, authorizes the president to establish national monuments by 

proclamation, and authorizes the scientific investigation of antiquities on federal lands, subject to 

permit and regulations. 

• Historic Sites Act of 1935 (P.L. 74-292): Directs the secretary of Interior to carry out wide-ranging 

programs in the field of history and places with the secretary the responsibility for national leadership in the field of historic preservation. Authorizes the Historic American Buildings Survey, Historic 

American Engineering Record and National Survey of Historic Sites and Buildings. The regulations 

accompanying this act require notification of the chief executive officer of an Indian tribe if a property selected for study to determine its potential for designation as a National Historic Landmark is 

located on an Indian reservation [36 CFR 65.5 (c)(1)]. 

• Endangered Species Act of 1973 (P.L. 93-205) and Secretarial Order # 3206, “American Indian 

Tribal Rights, Federal-Tribal Trust Responsibilities, and the Endangered Species Act” 1997 (DOI and 

Commerce only): Clarifies the responsibilities of the component agencies, bureaus and offices of the 

Department of the Interior and the Department of Commerce (Departments), when actions taken 

under authority of the Act and associated implementing regulations affect, or may affect, Indian 

lands, tribal trust resources or the exercise of American Indian tribal rights, as defined in the Order. 

The Order further acknowledges the trust responsibility and treaty obligations of the U.S. toward 

Indian tribes and tribal members and its government-to-government relationship in dealing with 
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Consultation Guidelines: Section 106 and Tribal Consultation 109

tribes. Accordingly, the Departments will carry out their responsibilities under the Act in a manner 

that harmonizes the Federal trust responsibility to tribes, tribal sovereignty and statutory missions of 

the Departments, and that strives to ensure that Indian tribes do not bear a disproportionate burden 

for the conservation of listed species, so as to avoid or minimize the potential for conflict and confrontation.

• Museum Properties Management Act of 1955 (P.L. 84-127): Authorizes the National Park Service to 

accept donations or bequests of museum properties, purchase them from donated funds, exchange, 

transfer, convey or destroy them, and receive and grant museum loans.

• Executive Order 11593, “Protection and Enhancement of the Cultural Environment” 1971: Directs 

Federal agencies to locate, inventory and nominate all potentially eligible sites, buildings, structures, 

districts and objects under their control to the Secretary of the Interior for listing on the NRHP. 

Agencies must also take precautions to prevent the sale, transfer or demolition of historic properties. 

Any property that will be damaged as a result of a Federal undertaking must be fully assessed and 

documented before it is impacted. 

• See also agency specific management policies. 

Where can I find more information?

http://inside.nps.gov/regions/custommenu.cfm?lv=1&rgn=&id=5682

Who can I call for more information? See:

http://inside.nps.gov/waso/contacts.cfm?lv=2&prg=20

National Park Service 

Intermountain Region 

Office of Indian Affairs and American Culture 
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110 Consultation Guidelines: Section 106 and Tribal Consultation

DRAFT TRIBAL CONSULTATION GUIDELINES 

July 12, 2006 

BACKGROUND 

Many laws, regulations and executive orders require federal agencies to consult with American Indian 

tribes. It is the policy of the NPS Intermountain Region to pay for costs of tribal participation in official 

government-to-government consultation initiated by the NPS. These guidelines will facilitate consistency 

within the region. 

1. ESTIMATING CONSULTATION MEETING COSTS 

Parks should estimate the cost of the planned consultation meeting before sending out invitation letters. The number of tribal representatives supported by the NPS to attend a consultation meeting depends upon the number of affiliated tribes, the topics for discussion, and the budget available. The NPS 

may cover the costs for one or two participants from each tribe but can state that other representatives 

are welcome to attend at the tribe’s expense. Parks should prepare a DI-1(s) or Purchase Request(s) 

for the professional services to be provided during the consultation meeting by the designated representatives following preparation of the budget estimate. In IMR parks, the Superintendent has the line 

authority to sign consultation related correspondence and authorize expenses. In the IMR office, the 

Director for Indian Affairs and American Culture (IAAC) has the line authority to sign consultation 

related correspondence and authorize expenses; at WACC, the Center Manager has the authority. An 

example budget estimating spreadsheet and letter of invitation to consult are attached. 

2. FACILITATING TRIBAL PARTICIPATION 

Tribal participation may be facilitated by including the following expenses in the “Fee for Professional 

Services” (note that this is not an explicit endorsement to pay travel expenses for tribal attendees but 

rather that accumulated travel expenses may be considered as part of the total fee paid to attendees for 

professional services rendered): 

• AIRFARE 

Tribal representatives may travel by air as needed and can be reimbursed via the Fee paid for Professional Services. 

• VEHICLE 

Tribal representatives may travel in personal vehicles, tribal vehicles, or rental cars. Participants 

traveling in their personal or tribal vehicle should be reimbursed at the prevailing standard government mileage rate unless their mileage is being paid for by the tribe. Tribal representatives may be 

reimbursed for a rental car at the prevailing government rate and fuel costs.

• LODGING 

Parks should arrange for a block of rooms at the prevailing government rate and are encouraged to 

work with the hotel to arrange for an RSVP date, after which rooms will be released. NPS employees 

may not reserve or pay for rooms for anyone other than themselves. Tribal members may call the hotel directly to reserve their room with their own credit card; they must pay for telephone calls, room 

service and incidentals on their own. 

• PER DIEM 

Tribal participants not being paid by the tribe may be provided per diem at the prevailing government rate for travel and meeting days as part of the total “Fee for Professional Services.” 

• FEE FOR PROFESSIONAL SERVICES 

If the tribal participant is NOT being paid by the tribe as an official representative, the NPS may provide a “Fee for Professional Services” for their subject matter expertise not to exceed $150 (this is in 

addition to any other considerations regarding the ‘cost to participate’ as detailed above). 

• REIMBURSEMENT 

At the meeting, tribal participants submit an invoice for the Fee for Professional Services with their 

individual information including their Social Security number or tax identification number, mailing 
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Consultation Guidelines: Section 106 and Tribal Consultation 111

address, telephone number, and description of services provided. It may be helpful to provide a draft 

invoice form son-site (example attached). During the meeting, an authorized NPS staff member will 

compile the information and prepare payment of Professional Services Fees to be dispersed at the 

close of the meeting referencing the DI-1(s) or Purchase Request(s). Tribal representatives should 

sign the invoice acknowledging submission of the invoice and receipt of payment. Tribal representatives should receive a copy of the signed invoice and the park or office should retain all original 

forms as part of the administrative record. 

3. MEETING DOCUMENTATION, ACCOUNTABILITY, AND REPORTING

The park should maintain a detailed administrative record of consultation meetings, attendees and 

process. IAAC will maintain consultation records in regional program files if the parks provide copies to IAAC. In response to OMB Circular A-123 (draft), parks and offices should submit an annual 

overview of consultation activities. A simple template is attached. 

CONTACTS 

Cyd Martin, Director,, Dave Ruppert, Assistant Director 

Intermountain Region, National Park Service 

Office of Indian Affairs and 

American Culture Office of Indian Affairs and American Culture 

12795 West Alameda Parkway 12795 West Alameda Parkway 

Denver, CO 80225 Denver, CO 80225 

PHONE: (303) 969-2868, PHONE: (303) 969-2879 

FAX: (303) 969-2063 FAX, (303) 969-2063 

E-Mail: cyd_martin@nps.gov, E-Mail: dave_ruppert@nps.gov

Initiate Section 106 Process

Establish undertaking

Identify appropriate SHPO/THPO

Plan to involve the public

Identify other consulting parties

Identify Historic Properties

Determine scope of efforts

Identify historic properties

Evaluate historic significance

Assess Adverse Effects

Apply criteria of adverse effect

Resolve Adverse Effects

Continue consultation

Undertaking is type that might 

affect historic properties

Historic properties are affected

Historic properties are adversely affected

FAILURE TO AGREE

No Undertaking - No potential to 

cause effects

No historic properties 

affected

No historic properties 

adversely affected

Memorandum of 

Agreement

COUNCIL COMMENT
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112 Policy, Standards and Guidelines For Historic Preservation In The NPS

APPENDIX K

Policy, Standards and Guidelines 

For Historic Preservation In The National Park Service

Historic preservation actions within the National Park system are directed by existing policies, standards 

and guidelines. While these provide over arching instruction, they often do not specifically or directly 

address the resources and challenges involved in ruins preservation. By definition, Vanishing Treasures 

resources have been un-maintained over some part of their life, have experienced some level of 

deterioration and are to be maintained in their current, deteriorated state. As such, these resources are 

covered under a combination of archeological, historic structure, preservation and cultural landscape 

policy statements, standards and guidelines. While these existing policies, standards and guidelines 

include conceptual guidance that is appropriate for managing these resources, they do not provide specific 

procedures that are required to develop and implement a Vanishing Treasures project. That is the purpose 

of these Ruins Preservation Guidelines.

Following is a synopsis of the various policies, standards and guidelines that provide the legal and 

conceptual underpinnings of the Vanishing Treasures Ruins Preservation Guidelines.

1. Policy

As stated in the National Park Service Management Policies 2006, “Policy sets the framework and provides 

direction for all management decisions. This direction may be general or specific; it may prescribe the 

process through which decisions are made, how an action is to be accomplished, or the results to be 

achieved.” The Management Policies is “the basic Service-wide policy document of the National Park 

Service, superseding the 2001 edition. It is the highest of three levels of guidance documents in the NPS 

Directives System.”

Chapter 5 of the Management Policies includes a general discussion of the treatment of archeological 

fabric, historic and prehistoric structures, and ruins. It focuses on the policy that these resources are to be 

preserved in a stable condition. Some of the discussion for these resources includes:

5.3.5 Treatment of Cultural Resources

The Park Service will provide for the long-term preservation of, public access to, and 

appreciation of the features, materials, and qualities contributing to the significance of 

cultural resources. With some differences by type, cultural resources are subject to several 

basic treatments, including (1) preservation in their existing states; (2) rehabilitation to 

serve contemporary uses, consistent with their integrity and character; and (3) restoration to 

earlier appearances by the removal of later additions and replacement of missing elements. 

Decisions regarding which treatments will best ensure the preservation and public enjoyment 

of particular cultural resources will be reached through the planning and compliance process, 

taking into account

•	 the nature and significance of a resource and its condition and interpretive value

•	 the research potential of the resource

•	 the level of intervention required by treatment alternatives

•	 the availability of data and the terms of any binding restrictions

•	 the concerns of traditionally associated peoples and other groups and individuals

Except for emergencies that threaten irreparable loss without immediate action, no treatment 

project will be undertaken unless supported by an approved planning document appropriate 

to the proposed action.

5.3.5.1 Archeological Resources

Archeological resources will be managed in situ, unless the removal of artifacts or physical 

disturbance is justified by research, consultation, preservation, protection, or interpretive 
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Policy, Standards and Guidelines For Historic Preservation In The NPS 113

requirements. Preservation treatments will include proactive measures that protect resources 

from vandalism and looting, and will maintain or improve their condition by limiting damage 

due to natural and human agents. Data recovery actions will be taken only in the context 

of planning, consultation, and appropriate decision-making. Preservation treatments and 

data recovery activities will be conducted within the scope of an approved research design. 

Archeological research will use nondestructive methods of testing and analysis wherever 

possible. The Park Service will incorporate information about archeological resources into 

interpretive, educational, and preservation programs. Artifacts and specimens recovered 

from archeological resources, along with associated records and reports, will be maintained 

together in the park museum collection.

(Also see Director’s Order #28A: Archeology; 36 CFR Part 79; Secretary of the Interior’s 

Standards and Guidelines for Archeological Documentation [48 FR 44734-737]; Museum 

Handbook.)

5.3.5.2 Cultural Landscapes

The treatment of a cultural landscape will preserve significant physical attributes, biotic 

systems, and uses when those uses contribute to historical significance. Treatment decisions 

will be based on a cultural landscape’s historical significance over time, existing conditions, 

and use. Treatment decisions will consider both the natural and built characteristics and 

features of a landscape, the dynamics inherent in natural processes and continued use, and 

the concerns of traditionally associated peoples. The treatment implemented will be based on 

sound preservation practices to enable long-term preservation of a resource’s historic features, 

qualities, and materials. There are three types of treatment for extant cultural landscapes: 

preservation, rehabilitation, and restoration.

(See Decision-making Requirements to Identify and Avoid Impairments 1.4.7. Also see Secretary 

of the Interior’s Standards for the Treatment of Historic Properties with Guidelines for the 

Treatment of Cultural Landscapes.)

5.3.5.4 Historic and Prehistoric Structures

The treatment of historic and prehistoric structures will be based on sound preservation 

practice to enable the long-term preservation of a structure’s historic features, materials, and 

qualities. There are three types of treatment for extant structures: preservation, rehabilitation, 

and restoration.

(Also see Secretary of the Interior’s Standards for the Treatment of Historic Properties.)

5.3.5.4.10 Historic and Prehistoric Ruins

The stabilization of historic and prehistoric ruins will be preceded by studies leading to the 

recovery of any data that would be affected by stabilization work. Ruins and related features 

on un-excavated archeological sites will be stabilized only to the extent necessary to preserve 

research values or to arrest structural deterioration, recognizing that it is preferable to preserve 

archeological sites in situ than to excavate them. Archeological ruins to be exhibited will not be 

excavated until consultation has occurred with traditionally associated peoples and adequate 

provisions are made for data recovery and stabilization. Structures will not be deliberately 

reduced to ruins, and missing structures will not be reconstructed to appear damaged or 

ruined.

2. Director’s Orders

With the Management Policies establishing a broad conceptual framework for ruins preservation, the 

second tier in the NPS Directives System creates operational policies and procedures to supplement 

the Management Policies. In the form of Director’s Orders, this tier provides standards that define the 

quality expected to be achieved and maintained in implementing management policies. In the realm of 

cultural resource activities, Director’s Order 28, Cultural Resources Management and Director’s Order 28A, 

Archeology provide measures of satisfactory accomplishment and guiding principles for archeological and 

historic preservation methods and activities.
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114 Policy, Standards and Guidelines For Historic Preservation In The NPS

Director’s Orders are typically developed by the WASO program office that has functional responsibility or 

subject matter expertise relevant to the subject of the Order. As of January 2009, Director’s Orders 28 and 

28A were being updated. Release 5 remains in effect until the update is finalized.

3. Handbooks and Reference Manuals

The third tier in the system provides further detail and guidance beyond the Service-wide policies and 

procedures that are laid out in the Director’s Orders. This information is usually provided in the form of 

handbooks and reference manuals.

At this level, the Secretary of the Interior’s Standards for the Treatment of Historic Properties (36 CFR Part 

68) is integral to Director’s Order 28. Likewise, the Secretary of the Interior’s Standards and Guidelines 

for Archeological Documentation is integral to Director’s Order 28a. These two sets of Standards are broad 

conceptual principles that are designed to provide philosophical consistency in the treatment of cultural 

resources.

While the Standards for the Treatment of Historic Properties stand on their own, the Standards and 

Guidelines for Archeological Documentation is part of the larger ARCHEOLOGY AND HISTORIC 

PRESERVATION: Secretary of the Interior’s Standards and Guidelines [As Amended and Annotated]. These 

Standards and Guidelines are not regulatory and they do not set or interpret agency policy. They are 

intended to provide technical advice about archeological and historic preservation activities and methods. 

While these Standards and Guidelines are not always directly applicable to ruins and structure preservation, 

they all support background resource identification, evaluation, and registration as activities that are 

necessary before the implementation of historic preservation treatment actions.

In addition to the Standards and Guidelines for Archeological Documentation, ARCHEOLOGY AND 

HISTORIC PRESERVATION: Secretary of the Interior’s Standards and Guidelines includes 7 other sections. 

These are: Preservation Planning, Identification, Evaluation, Registration, Note on Documentation 

and Treatment of Historic Properties, Historical Documentation, and Architectural and Engineering 

Documentation, each of which is accompanied by relevant Guidelines and Technical Information. Each of 

these Standards, along with its applicability to Vanishing Treasures resources, is discussed below.

1. Standards for Preservation Planning: Preservation Planning is a process that organizes preservation 

activities (see Identification, Evaluation, Registration, and Treatment below) in a logical sequence. The 

Standards for Planning discuss the relationship among these activities, while the remaining activity 

standards consider how each activity should be carried out. They outline a process that determines 

when an area should be examined for historic properties, whether an identified property is significant, 

and how a significant property should be treated.

Applicability to Vanishing Treasures resources: Preservation Planning Standard II, “Preservation 

Planning Uses Historic Contexts to Develop Goals and Priorities for the Identification, Evaluation, 

Registration and Treatment of Historic Properties” specifies that preservation planners use historic 

contexts to develop goals and priorities for resource treatment actions. This becomes even more 

important as Vanishing Treasures sites are increasingly viewed within the context of the larger cultural 

landscape, and planning efforts expand beyond the preservation of the just the structures themselves.

2. Standards for Identification: Identification activities are undertaken to gather information about 

historic properties in an area. The scope of these activities will depend on existing knowledge, goals 

developed through the planning process, and current management needs.

Applicability to Vanishing Treasures resources: The three standards; “Identification of Historic 

Properties Is Undertaken to the Degree Required To Make Decisions,” “Results of Identification 

Activities Are Integrated Into the Preservation Planning Process,” and “Identification Activities 

Include Explicit Procedures for Record-Keeping and Information Distribution” lay the foundation for 

documentation of Vanishing Treasure resources. 

3. Standards for Evaluation: Evaluation is the process of determining whether identified properties 
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Policy, Standards and Guidelines For Historic Preservation In The NPS 115

meet defined criteria of significance and therefore should be included in an inventory of historic 

properties determined to meet the criteria. The criteria employed vary depending on the inventory’s 

use in resource management. The Vanishing Treasures program has defined a specific set of criteria that 

determine eligibility for inclusion in the Program.

Applicability to Vanishing Treasures resources: Evaluation Standard III “Evaluation Results in a 

List or Inventory of Significant Properties that is Consulted in Assigning Registration and Treatment 

Priorities” echoes the process that is used to determine the eligibility of, and treatment priorities for 

Vanishing Treasures resources.

4. Standards for Registration: Registration is the formal recognition of properties evaluated as 

significant.

Applicability to Vanishing Treasures resources: Registration Standard II “Registration Information 

Locates, Describes and Justifies the Significance and Physical Integrity of a Historic Property” states that 

registers are used for planning, research and treatment. They must contain adequate information for 

users to locate a property and understand its significance. Additional information may be appropriate 

depending on the intended use of the register.

Initially, a module was created within The Archeological Sites Management Information System 

(ASMIS), which is the National Park Service’s database for the basic registration and management of 

park prehistoric and historic archeological resources that was intended to inventory VT resources. 

However, this module was never adequately populated and the Program is now actively working to 

create a comprehensive inventory of VT resources.

5. Note on the Standards for Historical Documentation: Documentation and treatment of historic 

properties include a variety of techniques to preserve or protect properties, or to document their 

historic values and information. While documentation activities may be applied to any potentially 

historic property, generally only those properties that first have been evaluated as significant against 

specified criteria (such as those of the National Register or the Vanishing Treasures Program) are 

treated. Some commonly applied treatments are preservation in place, rehabilitation, restoration and 

stabilization; there are other types of treatments also. Documentation and treatment may be applied 

to the same property; for example, archeological, historical, and architectural documentation may be 

prepared before a structure is stabilized or before foundations or chimneys or other lost features are 

reconstructed. 

Applicability to Vanishing Treasures resources: Of the possible treatments listed above, only 

stabilization and preservation in place are applicable to VT resources. Rehabilitation and restoration 

are not appropriate treatments for VT sites. Additionally, within the Vanishing Treasures Program, 

documentation alone is also considered to be an appropriate “treatment.”

6. Standards for Historical Documentation: Research of historic information can provide important 

information related to the significance of a property for use by historians, researchers, preservationists, 

architects, and historical archeologists. Research is used early in planning to gather information needed 

to identify and evaluate properties. Historical documentation is also a treatment that can be applied in 

several ways to properties previously evaluated as significant; it may be used in conjunction with other 

treatment activities (as the basis for rehabilitation plans or interpretive programs, for example) or as a 

final treatment to preserve information in cases of threatened property destruction.

Applicability to Vanishing Treasures resources: Historical documentation is a data gathering 

technique to provide information, in a structured format, about Vanishing Treasures resources. This 

documentation can serve as the foundation for the development of treatment plan or it may serve as a 

final treatment to preserve information of sites that will not receive further preservation treatments.

7. Standards for Architectural and Engineering Documentation: These standards concern the 

development of documentation for historic buildings, sites, structures and objects, which usually 

consists of measured drawings, photographs and written data. They provide information on a property’s 

significance for use in preserving that property. Documentation enables accurate repair or preservation 

of a resource or preserves information as a final treatment. These Standards are intended for use in 

developing documentation to be included in the Historic American Buildings Survey (HABS), the 

Historic American Engineering Record (HAER), and the Historic American Landscapes Survey (HALS) 

programs.
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116 Policy, Standards and Guidelines For Historic Preservation In The NPS

Applicability to Vanishing Treasures resources: These standards are directly applicable to preservation 

of Vanishing Treasures resources and should be applied to Vanishing Treasures projects whenever 

written or graphic documentation is prepared.

8. Standards for Archeological Documentation: Archeological documentation may occur at any or all 

levels of planning, identification, evaluation or treatment with the nature and extent of documentation 

being determined by each specific set of circumstances. Archeological documentation consists of such 

activities as archival research, observation and recording of above-ground remains, and observation 

(directly, through excavation, or indirectly, through remote sensing) of below-ground remains. 

Archeological documentation is employed for the purpose of gathering information on individual 

historic properties or groups of properties and may be undertaken as an aid to preservation treatments 

including research, interpretation, and data recovery.

Applicability to Vanishing Treasures resources: These standards are directly applicable to the 

preservation of Vanishing Treasures resources. The Ruins Preservation Guidelines have been developed 

as part of a strategy to expand upon the Cultural Resource Management Guidelines (NPS-28), and 

to define fundamental standards for ruins preservation documentation and treatment. Because the 

majority of VT resources are archeological sites, this form of documentation must occur at all levels of 

the planning, evaluation and treatment of many Vanishing Treasures resources. 

As it was originally conceived, ARCHEOLOGY AND HISTORIC PRESERVATION: Secretary of the Interior’s 

Standards and Guidelines had one addition category, the Standards for Historic Preservation Projects. 

These standards have since been superseded by the Secretary of the Interior’s Standards for the Treatment 

of Historic Properties (36 CFR Part 68), which is specifically referenced in Director’s Order 28. Unlike the 

earlier standards which were not regulatory and did not set or interpret agency policy, the Secretary of 

the Interior’s Standards for the Treatment of Historic Properties are part of the Code of Federal Regulations 

(CFR), which codifies the general and permanent rules created by the executive departments and agencies 

of the Federal Government. As such, the Secretary’s Standards have the force of law under certain 

circumstances, and may be used by anyone planning and undertaking work on historic properties.

The Standards are a series of concepts about maintaining, repairing and replacing historic materials, as 

well as designing new additions or making alterations. They cannot, in and of themselves, be used to make 

decisions about which features of a historic property should be preserved and which might be changed. 

But once an appropriate treatment is selected, the Standards provide philosophical consistency to the 

work.

There are Standards for four distinct, but interrelated, approaches to the treatment of historic properties--

preservation, rehabilitation, restoration, and reconstruction. Of these, only the Standards for Preservation, 

which focus on the maintenance and repair of existing historic materials and retention of a property’s form 

as it has evolved over time, provide guidance that is applicable to Vanishing Treasures resources.

Preservation is defined as the act or process of applying measures necessary to sustain the existing form, 

integrity, and materials of an historic property. Work, including preliminary measures to protect and 

stabilize the property, generally focuses upon the ongoing maintenance and repair of historic materials and 

features rather than extensive replacement and new construction. New exterior additions are not within 

the scope of this treatment. The Standards for Preservation are:

1. A property will be used as it was historically, or be given a new use that maximizes the 

retention of distinctive materials, features, spaces, and spatial relationships. Where a 

treatment and use have not been identified, a property will be protected and, if necessary, 

stabilized until additional work may be undertaken. 

2. The historic character of a property will be retained and preserved. The replacement of intact 

or repairable historic materials or alteration of features, spaces, and spatial relationships 

that characterize a property will be avoided. 

3. Each property will be recognized as a physical record of its time, place, and use. Work 

needed to stabilize, consolidate, and conserve existing historic materials and features will 

be physically and visually compatible, identifiable upon close inspection, and properly 
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Policy, Standards and Guidelines For Historic Preservation In The NPS 117

documented for future research. 

4. Changes to a property that have acquired historic significance in their own right will be 

retained and preserved. 

5. Distinctive materials, features, finishes, and construction techniques or examples of 

craftsmanship that characterize a property will be preserved. 

6. The existing condition of historic features will be evaluated to determine the appropriate 

level of intervention needed. Where the severity of deterioration requires repair or limited 

replacement of a distinctive feature, the new material will match the old in composition, 

design, color, and texture. 

7. Chemical or physical treatments, if appropriate, will be undertaken using the gentlest means 

possible. Treatments that cause damage to historic materials will not be used. 

8. Archeological resources will be protected and preserved in place. If such resources must be 

disturbed, mitigation measures will be undertaken.

Guidelines, which are instructions for determining procedures for the implementation of policy and/or 

assuring that policy requirements and standards are met, accompany all of the standards included in the 

ARCHEOLOGY AND HISTORIC PRESERVATION: Secretary of the Interior’s Standards and Guidelines. 

Illustrated guidelines have been prepared for the Standards for the Treatment of Historic Properties. 

Additionally, direction for the implementation of service wide cultural resource management policy is 

provided in NPS-28: Cultural Resource Management Guideline.

NPS-28 elaborates on the National Park Service Management Policies 2006 and offers guidance in applying 

them to park cultural resources. These guidelines, although more specific, are in conformance with 

the guidelines that are offered with ARCHEOLOGY AND HISTORIC PRESERVATION: Secretary of the 

Interior’s Standards and Guidelines, and the Secretary’s Standards for the Treatment of Historic Properties. 

Of particular relevance to Vanishing Treasures resources are Chapter 6, Management of Archeological 

Resources and Chapter 8, Management of Historic and Prehistoric Structures.

Chapter 6 includes sections on the types of archeological resources, NPS objectives, applicable standards, 

archeological research, resource management planning, and stewardship of archeological resources. 

Likewise, Chapter 8 has sections dealing with the types of historic and prehistoric structures, NPS 

objectives, research, including identification, evaluation, and registration, resource management planning 

and stewardship of historic and prehistoric resources.

Even though the guidance becomes more specific as it moves from general policy to handbooks and 

reference manuals, the existing literature generally lacks the specialized knowledge required by the unique 

challenges of maintaining sites and structures that are in various states of deterioration. It is that gap that 

the Ruins Preservation Guidelines is meant to fill.

REFERENCES

National Park Service Management Policies 2006

URL: http://www.nps.gov/policy/MP2006.pdf

Director’s Order 28, Cultural Resources Management

URL: http://www.nps.gov/policy/DOrders/DOrder28.html

Director’s Order 28A, Archeology

URL: http://www.nps.gov/policy/DOrders/DOrder28A.html

Secretary of the Interior’s Standards for the Treatment of Historic Properties

URL: http://www.nps.gov/history/hps/tps/standards_guidelines.htm
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118 Policy, Standards and Guidelines For Historic Preservation In The NPS

ARCHEOLOGY AND HISTORIC PRESERVATION: Secretary of the Interior’s Standards and Guidelines 

[As Amended and Annotated]

URL: http://www.nps.gov/history/local-law/arch_stnds_0.htm

Illustrated guidelines for the Treatment of Historic Properties

URL: http://www.cr.nps.gov/hps/tps/standguide/index.htm

NPS-28: Cultural Resource Management Guideline

URL: http://www.nps.gov/history/history/online_books/nps28/28contents.htm

Laws and Executive Orders that Affect Historic Preservation-The guidelines for cultural resource 

management in the national park system are derived from a hierarchy of laws, proclamations, orders, 

regulations, and policies. Primary among these are the acts and proclamations establishing individual 

parks which state the congressional or presidential intent for including them in the system. Other laws 

and executive orders have general application to cultural resource management throughout the park 

system.

• Antiquities Act of 1906 (P.L. 59-209, 34 Stat. 225)

• National Park Service Act of August 25, 1916 (P.L. 64-235, 39 Stat. 535)

• Historic Sites Act of 1935 (P.L. 74-292, 49 Stat. 666)

• Management of Museum Properties Act of 1955 (P.L. 84-127, 69 Stat. 242)

• Reservoir Salvage Act of 1960 (P.L. 86-523, 74 Stat. 220)

• Department of Transportation Act of 1966 (P.L. 89-670, 80 Stat. 931)

• National Historic Preservation Act of 1966 (P.L. 89-665, 80 Stat. 915; as amended by P.L. 91-243, P.L. 

93-54, P.L. 94-422, P.L. 94-458, P.L. 96-199, P.L. 96-244, P.L. 96-515, P.L 98-483, P.L. 99-514, P.L. 100-

127, and P.L. 102-575)

• National Environmental Policy Act of 1969 (P.L. 91-190; 31 Stat. 852)

• Executive Order 11593, Protection and Enhancement of the Cultural Environment, May 13, 1971

(36 FR 8921)

• Archeological and Historic Preservation Act of 1974 (P.L. 93-291; 88 Stat. 174)

• Mining in the Parks Act of 1976 (P.L. 94-429; 90 Stat. 1342)

• Tax Reform Act of 1976 (P.L. 94-455; 90 Stat. 1916)

• General Authorities Act of 1976 (P.L. 94-458; 90 Stat. 1939)

• Public Buildings Cooperative Use Act of 1976 (P.L. 94-541; 90 Stat. 2505)

• American Indian Religious Freedom Act of 1978 (P.L. 95-341; 92 Stat. 469)

• Archaeological Resources Protection Act of 1979 (P.L. 96-95; 93 Stat. 712)

• Alaska National Interest Lands Conservation Act of 1980 (P.L. 96-487)

• World Heritage Convention, 1980 (P.L. 96-515, 94 Stat. 3000)

• Abandoned Shipwreck Act of 1987 (P.L. 100-298; 102 Stat. 432)

• Native American Graves Protection and Repatriation Act of 1990 (P.L. 101-601; 104 Stat. 3049)

• Executive Order 13007, Indian Sacred Sites, May 24, 1996 (61 FR 26771)

Regulations-Regulations are promulgated and published in the Code of Federal Regulations (CFR) to 

direct the implementation of laws. The following CFR citations are most pertinent to cultural resource 

management.

• 36 CFR 2.5 (NPS Act of 1916)

• 36 CFR 18 (National Historic Preservation Act of 1966)

• 36 CFR 60 (NHPA and EO 11593)

• 36 CFR 61 (NHPA and EO 11593)

• 36 CFR 63 (NHPA and EO 11593)

• 36 CFR 65 (Historic Sites Act of 1935)

• 36 CFR 67, “Historic Preservation Certifications Pursuant to the Tax Reform Act of 1976, the Revenue 

Act of 1978, the Tax Treatment Extension Act of 1980, and the Economic Recovery Tax Act of 1981

• 36 CFR 68 (NHPA)

• 36 CFR 79 (NHPA and ARPA)
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Policy, Standards and Guidelines For Historic Preservation In The NPS 119

• 36 CFR 800 (NHPA and EO 11593)

• 43 CFR 3 (Antiquities Act)

• 43 CFR 7, Subparts A and B (Archaeological Resources Protection Act, as amended)

• 43 CFR 10 (NAGPRA)

NPS Orders and Guidance-The following NPS orders and guidance pertain to cultural resource 

management.

• Director's Order 24, “Standards for NPS Museum Collections Management” 

• Director's Order 26, “Projects Must Fund Basic Preservation of Museum Collections They 

Generate”

• Director's Order 27, “Historic Property Leases and Exchanges”

• Staff Directive 96-1, “Linking Cultural and Natural Resource and Socio-economic Data to Park 

Planning and Management”

• Department of the Interior Interim Standards for Documentation, Preservation and 

Protection of Museum Property (September 1990)

• National Park Service Abandoned Shipwreck Act Guidelines (55 FR 50116, Dec. 4, 1990; 55 FR 

51528, Dec. 14, 1990; 56 FR 7875, Feb. 26, 1991)
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120 Policy, Standards and Guidelines For Historic Preservation In The NPS

NPS-DO-28 and 28A: Cultural Resource Management Guidelines, Release #5

Relevant sections of Chapter 6 and Chapter 8 of DO 28 are excerpted below:

CHAPTER 6: MANAGEMENT OF ARCHEOLOGICAL RESOURCES

D. Stewardship

Stewardship of archeological resources is wide-ranging. It includes their treatment, preservation, and 

protection. It includes monitoring resource condition and assessing threats and disturbances. It also 

includes staff involvement and training in protection concerns and methods, preservation of significant 

features, sites, and recovered materials, and interpretation of archeological resources for public benefit.

1. Treatment

Archeological resources will be left undisturbed unless intervention can be justified based on compelling research, interpretation, site protection, or park development needs. Recovered archeological 

materials and associated records will be treated in accordance with the NPS Management Policies, 

NPS Museum Handbook, and 36 CFR Part 79. Archeological collections will be cataloged, stabilized, 

and prepared for storage as part of the study or project that generated the material.

a. Preservation

Guidance for preserving historic and prehistoric structures is presented in Chapter 8 of this 

guideline, and that for museum objects is found in Chapter 9. More specific guidance for preserving archeological resources, including prehistoric structures, can be found in sources listed in 

Appendix J, the selected archeology bibliography. Guidance applicable to all types of archeological resources is summarized here:

(1) All resources will be protected against natural and human agents of destruction and deterioration whenever practicable.

(2) Preservation will maintain the existing form, integrity, and materials of the resource.

(3) Preservation will include techniques of arresting or retarding deterioration through a program of ongoing maintenance. Deteriorated areas (e.g., depressions created through erosion, 

slumping, subsidence, and other natural causes) will be backfilled or otherwise stabilized.

(4) Excavation and other destructive techniques will be employed only when necessary to provide sufficient information for research, interpretation, and management needs. Excavated 

areas (including potholes excavated by looters) will be backfilled or otherwise stabilized.

(5) Stabilization of a resource to arrest and inhibit deterioration will be done in such a way as to 

detract as little as possible from its appearance and significance and not adversely affect its 

research potential unless adequate data recovery has occurred. Stabilization by vegetation, 

installation of rip rap or landscape netting, burial, or other alteration will be undertaken only 

after sufficient research or experimentation to determine the probable efficacy of the action 

and only after existing conditions are fully documented. A complete record of stabilization 

work will be kept.

(6) Data recovery will precede and be completed before physical intervention into any archeological resource, including sites associated with historic structures.

b. Rehabilitation, Restoration, and Reconstruction

Archeological sites and structures will not be rehabilitated, restored, or reconstructed. 

2. Protection

Archeological resources will be protected from vandalism and looting. Patrols, fencing, warning 

signs, and remote-sensing alarms will be used as appropriate. Stewardship programs wherein concerned local people are enlisted to monitor conditions of archeological resources are encouraged.

Interpretive and public educational programs to promote site protection are encouraged. The public 

should be made aware of the value of archeological resources and the penalties for destroying them 

through posters, films, and other media. Park staff should be made aware of protection concerns and 

methods through training sessions.
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Policy, Standards and Guidelines For Historic Preservation In The NPS 121

CHAPTER 8: MANAGEMENT OF HISTORIC AND PREHISTORIC STRUCTURES

A. Introduction

1. Resource Definition

A historic structure is “a constructed work . . . consciously created to serve some human activity.” Historic structures are usually immovable, although some have been relocated and others are mobile by 

design. They include buildings and monuments, dams, millraces and canals, nautical vessels, bridges, 

tunnels and roads, railroad locomotives, rolling stock and track, stockades and fences, defensive 

works, temple mounds and kivas, ruins of all structural types, and outdoor sculpture. 

Prehistoric structures are included in this chapter because the technical aspects of their preservation are similar to those of many historic structures. All prehistoric structures are also archeological 

resources, and some are ethnographic resources. They should therefore be managed within the general provisions of Chapters 6 and 10, particularly with respect to research and planning. Prehistoric 

structures are further distinguished by National Park Service policy limitations on their use and treatment. Given these qualifications, the term “historic structure” in this guideline is meant to encompass 

prehistoric structures unless otherwise stated.

2 Program Objectives

The preservation of historic structures involves two basic concerns: slowing the rate at which historic 

material is lost, and maintaining historic character. Research on, planning for, and stewardship of 

historic structures focus on these concerns. Research defines historical associations, integrity, character, and the causes of material deterioration; planning develops and evaluates proposals for use and 

treatment in terms of their likely effects; and stewardship entails activities ranging from craft training 

to the identification and mitigation of threats.

Preservation of historic structures is an interdisciplinary effort requiring cooperation and communication among historical architects, architectural conservators, preservation specialists, archeologists, 

landscape architects, historians, ethnographers, and curators. 

B. Research

Research about historic structures is a prerequisite for treatment and provides a basis for decisionmaking by managers. Situations benefiting from research-generated information range from review of 

weekly maintenance projects to long-term planning projects. Research also contributes to interpretation, compliance, and facility design.

To accomplish these purposes, research typically concentrates on three broad aspects of a historic structure: its historical, technical, aesthetic, or scientific associations; its developmental history or evolution; 

and the nature, performance, and capability of its materials and systems. This information is collected, 

analyzed, and organized through a variety of means, discussed below.

1. Identification, Evaluation, and Registration

Section 110 of the National Historic Preservation Act requires the NPS to identify and nominate to 

the National Register of Historic Places all structures and other properties under its jurisdiction that 

appear eligible. Historical areas of the national park system are automatically listed in the National 

Register in toto upon their establishment by law or executive order, but those structures and other 

features within them that contribute to their historical significance must still be documented for Register purposes.

a. Historic Resource Study

The historic resource study (HRS) is the primary document used to identify and manage the historic resources in a park. It is the basis for understanding their significance and interrelationships, a 

point of departure for development of interpretive plans, and the framework within which additional research should be initiated.

Although structures may be nominated to the National Register on an individual basis, they are 

most efficiently processed as part of an HRS. (For more guidance see “Baseline Research Reports” 

in Chapter 2.) With respect to historic structures, an HRS is adequate when three conditions–re-
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122 Policy, Standards and Guidelines For Historic Preservation In The NPS

quired for National Register nomination–are met. First, the thematic context must be sufficient to 

evaluate historical, aesthetic, technical, or scientific associations of structures within the study area. 

Second, the HRS must contain enough information about the developmental history or evolution 

of each structure to evaluate its integrity. Third, the study must contain enough information about 

the contributing environment of each structure to enable National Register boundaries to be defined and possible overlaps with cultural landscapes and archeological or ethnographic resources 

to be identified.

Research on structures or topics that were not included in an earlier HRS should be published as 

an addendum to that document.

b. National Register Nominations

National Register nominations may be prepared either for individual structures or for groups of 

structures. Collective nominations are appropriate for structures that are physically related, as in a 

historic district, or thematically related, as in a multiple property nomination. (For additional guidance see “Resource Identification, Evaluation, and Registration” in Chapter 2.)

As noted in the introduction to this guideline, the cultural resource types in the NPS Management 

Policies and this guideline are adaptations for management purposes of the property categories 

used by the National Register. Park resources classified as structures may be listed as buildings, 

structures, or objects in the National Register. Historic and prehistoric structures also may be 

included in the Register as contributing elements of historic districts, either as components of 

developed areas or as landscape features.

c. List of Classified Structures

The List of Classified Structures (LCS) is the primary computerized database containing information about historic and prehistoric structures in which the NPS has or plans to acquire any legal 

interest. Properties included in the LCS are either in or eligible for the National Register or are to 

be treated as cultural resources by law, policy, or decision reached through the planning process 

even though they do not meet all National Register requirements. Data fields in the LCS include 

identification, category of significance, condition, use, threats, treatments, cost estimates for treatments, and physical description.

The LCS has three major applications: (a) to describe historic structures on an individual or collective basis at park, regional, or Service-wide levels, (b) as a common information source for other 

automated management systems such as the Maintenance Management (MM) program and the 

Housing Inventory, and (c) as an analytical tool in budgeting, scheduling, and program development.

(For more information see “Service-wide Inventories” in Chapter 2 and the List of Classified Structures [LCS] User’s Manual, 1993.)

d. Categories of Significance

All cultural resources are managed under a uniform standard of preservation responsibility. The 

following categories of significance are used to establish LCS management categories, determine 

appropriate levels of graphic documentation, and make other related management decisions for 

prehistoric and historic structures within the national park system. 

Category Ia: Individual structures that qualify as national historic landmarks, are listed in the National Register as nationally significant, or that possess national significance by act of Congress or 

executive order.

Category Ib: Structures that do not possess national significance on an individual basis, but contribute to the national significance of a park or historic district.

Category II: Structures that individually or collectively qualify for the National Register and possess significance at the state level.

Category III: Structures that individually or collectively qualify for the National Register and possess significance at the local level.
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Policy, Standards and Guidelines For Historic Preservation In The NPS 123

2. Documentation and Investigation

As a rule, research about a historic structure should complement existing information and strive to 

produce a comprehensive understanding of the structure in order to adequately address management 

objectives. Research effort should be proportional to the significance of the structure and the range of 

effects associated with the objectives. Although individual features, areas, or systems may be emphasized, research should approach the structure as a whole.

Research needed to supply missing information should be defined in terms of subject, scope, and level of investigation. The subject may range from one feature on a single historic structure to a complex 

of structures. Scope includes but is not limited to thematic context, physical documentation, temporal 

associations, developmental history, scientific value, and material analysis. Level of investigation describes the nature and location of sources to be consulted and the degree to which extant material will 

be disturbed or destroyed during research. These considerations are described in the task directive 

and research design for every substantial research effort. (See “Research Methodology” in Chapter 2.)

Destructive techniques, such as archeological excavation and selective demolition, should be used 

only when alternatives are inadequate to provide information essential for evaluating, planning for, 

treating, or interpreting a historic structure. Any research that would directly impact a cultural resource must be reviewed in advance through the compliance process. Research involving prehistoric 

and some historic structures may also require consultation with Native Americans or other associated 

ethnic groups.

a. Historic Structure Report

The historic structure report (HSR) is the primary guide to treatment and use of a historic structure 

and may also be used in managing a prehistoric structure. A separate HSR should be prepared for 

every major structure managed as a cultural resource. Groups of similar structures or ensembles of 

small, simple structures may be addressed in a single report. In no case should restoration, reconstruction, or extensive rehabilitation of any structure be undertaken without an approved HSR, 

Parts 1 and 2.

An HSR includes the following:

Management Summary. This is a concise account of research done to produce the HSR, major 

research findings, major issues identified in the task directive, and recommendations for treatment 

and use. Administrative data on the structure and related studies are included.

Part 1, Developmental History, is a scholarly report documenting the evolution of a historic structure, its current condition, and the causes of its deterioration. It is based on documentary research 

and physical examination. The scope of documentary research may extend beyond the physical 

development of the structure if needed to clarify the significance of the resource or to refine contextual associations; however, major historical investigation of contextual themes or background 

information should be conducted as part of a historic resource study. If the Inventory and Condition Assessment Program (FMSS) is used to describe the nature and condition of features, resultant 

reports (e.g., the historic asset assessment report) should be included in the HSR’s appendix.

Part 2, Treatment and Use, presents and evaluates alternative uses and treatments for a historic 

structure. Emphasis is on preserving extant historic material and resolving conflicts that might 

result from a structure’s “ultimate treatment.” Part 2 concludes by recommending a treatment and 

use responding to objectives identified by park management. In most cases, design work does not 

go beyond schematics. 

Part 3, Record of Treatment, is a compilation of information documenting actual treatment. It 

includes accounting data, photographs, sketches, and narratives outlining the course of work, conditions encountered, and materials used. 

All aspects of a historic structure and its immediate grounds should be addressed in an HSR. 

Potential overlaps with other cultural resource types and natural resource issues should be identified, and applicable studies and reports should be called for or referenced. An HSR and analogous 

reports (e.g. a cultural landscape report) may be combined to address multiple resource types at a 

single property or area.
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124 Policy, Standards and Guidelines For Historic Preservation In The NPS

Parts 1 and 2 of an HSR should be prepared jointly as part of a comprehensive effort soon after 

acquisition of a structure or recognition of its status as a cultural resource. Given funding and time 

constraints, however, an HSR may be prepared incrementally. Incremental research and design 

should also be considered when a complete HSR does not exist or an existing HSR does not adequately address aspects of a proposed treatment such as replication of missing features, removal of 

significant features or large amounts of historic material, or introduction of new systems or exterior 

additions. In no case should a Part 2 be prepared without a Part 1. 

The scope, level of investigation, and extent of schematic development are outlined in a task 

directive that is based on the recommendations of a historical architect in consultation with other 

cultural resource specialists and the park manager. Major factors considered in developing the task 

directive include the structure’s significance, condition, and intended use. The task directive should 

also address participation of other cultural resource specialists and publication of the document.

The following standards apply:

• A historic structure report (HSR) is prepared to minimize loss of character-defining features and 

materials whenever existing information about the developmental history and condition of the 

historic structure does not provide an adequate basis upon which to address anticipated management objectives, whenever alternative courses of action for impending treatment and use could 

have adverse effects, or to record treatment.

• Architectural, landscape, and archeological investigations supporting an HSR have the least possible impact on the property studied and employ nondestructive methods to the maximum extent possible; they are prescribed and justified in a task directive that includes a research design 

and impact analysis.

b. Graphic Documentation

Documentation of historic structures is undertaken to record preservation treatment, provide a 

baseline for monitoring, aid in interpretation, support scholarly research, and serve as an objective 

reference for repair or reconstruction in the event of damage or loss. The scope, method, and level 

of documentation of a structure should be proportional to its significance as a cultural resource, 

the character of its features, the degree to which it is endangered, and the ways in which the documentation is most likely to be used.

All documentation is done in conformance with the Secretary of the Interior’s Standards for Architectural and Engineering Documentation (see Appendix C). Where recording is done to establish a 

baseline for planning or before demolition, the following documentation levels are recommended: 

Level I for Category Ia structures, Level II for Category Ib structures, Level III for Category II 

structures, and Level IV for Category III structures.

New materials and replacement features introduced should be recorded in place with photographs 

or drawings that clearly indicate their extent. Physical evidence of the developmental history of a 

structure should be recorded before being removed or covered during treatment. Copies of task 

directives, daily reports, and change orders should also be retained in park files.

3. Ultimate Treatment

The ultimate treatment of a historic structure is a general definition of its development limits based on 

considerations of use and the historic character that should be presented to the public. It is accomplished through one or more construction projects, after which the structure is preserved by preservation maintenance. Subsequent rehabilitation or restoration may be needed to update the structure’s 

functional aspects and to repair or replace damaged or deteriorated features. Pending ultimate 

treatment, a structure is stabilized and protected in its existing condition; it may also receive interim 

treatment compatible with its planned appearance and use.

The categories of ultimate treatment are preservation, rehabilitation, restoration, and reconstruction.

Preservation as an ultimate treatment maintains the existing integrity and character of a historic 

structure. This alternative precludes uses that would require major additions or demolition. It should 

always receive first consideration.
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Policy, Standards and Guidelines For Historic Preservation In The NPS 125

Reconstruction produces a new structure identical in form, features, and details to a historic structure 

that no longer exists. Management Policies permits reconstruction only if (a) it is essential for public 

understanding of the cultural associations of a park established for that purpose, (b) the structure 

can be built at full scale on the original site with minimal conjecture, and (c) significant archeological resources will be preserved in situ or their research values will be realized through data recovery. 

Meeting the first criterion requires a demonstration that no other interpretive media or techniques 

can render the park’s primary theme comprehensible to visitors. Reconstruction will be undertaken 

only upon specific written approval of the director after policy review in the Washington office.

D. Stewardship

For historic structures, stewardship focuses on five major activities: (a) control of treatment and use, (b) 

monitoring conditions of deterioration and structural failure, (c) protecting structures from human and 

environmental threats, (d) retaining or delegating responsibility for structures, and (e) developing the 

skills, knowledge, and attitudes needed to support the program. The last of these is addressed in Chapter 4 as part of training. Guidance for the others follows.

1. Treatment and Use

Treatment and use of historic structures follows the conditions outlined in approved planning documents such as the general management plan, historic structure report, and FMSS work procedures.

Treatment of historic structures is divided into four categories: preservation, rehabilitation, restoration, and reconstruction. These categories parallel those used in planning for the ultimate treatment 

of historic structures. They are also the same as those outlined in Management Policies and the Secretary of the Interior’s Standards for the Treatment of Historic Properties, commonly referred to as the 

Secretary’s Standards.

One treatment category, preservation, encompasses four activities recognized in the 1995 Servicewide 

Programmatic Agreement (PA): stabilization, housekeeping, routine maintenance, and cyclic maintenance. Under stipulation IV of the PA these activities are referred to collectively as “preservation 

maintenance.” (See Chapter 5 for additional information.)

The following standards apply to all treatments:

Use is monitored and regulated to minimize both immediate and long-term damage.

Use of destructive techniques, such as archeological excavation, is limited to providing sufficient 

information for research, interpretation, and management needs.

All work that may affect resources is evaluated by an historical architect and other professionals, as 

appropriate.

All modification, repair, or replacement of materials and features is preceded by sufficient study and 

recording to protect research and interpretive values.

New work, materials, and replacement features are identified, documented, or permanently marked 

in an unobtrusive manner to distinguish them from original work, materials, and features. The 

manner and location of identification is recorded using the Inventory and Condition Assessment 

Program (now in FMSS).

A proposed treatment project is initiated by the appropriate programming document, including a 

scope of work and cost estimate from an HSR or FMSS. Such projects include preservation maintenance as well as major treatment. No treatment is undertaken without an approved HSR or work 

procedure documenting the work, and Section 106 compliance.

A treatment project is directed by a historical architect and performed by qualified technicians.

Representative features salvaged from a historic structure are accessioned and cataloged, provided 

that they fall within the park’s scope of collection statement.

All changes made during treatment are graphically documented with drawings and photographs. 

Records of treatment are managed as archival materials by a curator or archivist within the park’s 

museum collection.

a. Preservation

•

•

•

•

•

•

•

•

•
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126 Policy, Standards and Guidelines For Historic Preservation In The NPS

Preservation maintains the existing integrity and character of a historic structure by arresting or 

retarding deterioration caused by natural forces and normal use. It includes both maintenance and 

stabilization. Maintenance is a systematic activity mitigating wear and deterioration of a structure by 

protecting its condition. Stabilization involves reestablishing the stability of an unsafe, damaged, or 

deteriorating structure while maintaining its existing character. The following standards based on 

the Secretary of the Interior’s Standards for the Treatment of Historic Properties apply:

• A historic structure is used as it was historically, or is given a new or adaptive use that maximizes the 

retention of historic materials, features, spaces, and spatial relationships. Where a treatment and use 

have not been identified, a structure is protected and, if necessary, stabilized until additional work 

may be undertaken. Adaptive use of prehistoric structures is prohibited.

• The historic character of a historic structure is retained and preserved. The replacement or removal 

of intact or repairable historic materials or alteration of features, spaces, and spatial relationships 

that characterize a structure is avoided.

• Each historic structure is recognized as a physical record of its time, place, and use. Work needed to 

stabilize, consolidate, and conserve historic materials and features is physically and visually compatible, identifiable upon close inspection, and properly documented for future research.

• Changes to a historic structure that have acquired historical significance in their own right are retained and preserved.

• Historic materials, features, finishes, and construction techniques or examples of craftsmanship that 

characterize a historic structure are preserved.

• The existing condition of historic features is evaluated to determine the appropriate level of intervention needed. Where the severity of deterioration requires repair or limited replacement of a 

historic feature, the new work matches the old in design, color, texture, and where possible, materials. Repair or replacement of features is substantiated by archeological, documentary, or physical 

evidence.

• Chemical or physical treatments that cause damage to historic materials are not used.

• Archeological and landscape resources are protected and preserved in place. If such resources must 

be disturbed, mitigation measures are undertaken including recovery, curation, and documentation.

The following additional standards apply:

• Stabilization detracts as little as possible from a historic structure’s appearance and significance. Reinforcement is concealed wherever possible so as not to intrude upon or detract from the aesthetic, 

historical, or archeological quality of the structure, except where concealment would result in the 

alteration or destruction of historically or archeologically significant features, materials, or physical 

or visual relationships. Accurate documentation of stabilization procedures is kept and made available for future needs.

• Maintenance is executed by qualified technicians in accordance with approved work procedures. 

Where such procedures are nonexistent or incomplete, a historical architect provides technical 

guidance.

• All features of a historic structure are inspected on a scheduled basis and information about their 

condition is entered into ICAP (now FMSS).

d. Reconstruction

Reconstruction entails reproducing the form, features, and character of a non-surviving historic 

structure, or any part thereof, as it appeared at a specific time and place. Reconstruction of an entire 

structure is always a last-resort measure for addressing a management objective and will be undertaken only upon specific written approval of the director after policy review in the Washington 

office. The following standards based on the Secretary of the Interior’s Standards for the Treatment 

of Historic Properties apply:

• Archeological, documentary, or physical evidence is available to permit accurate reconstruction 

with minimal conjecture, and such reconstruction is essential to public understanding of the cul-
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Policy, Standards and Guidelines For Historic Preservation In The NPS 127

tural associations of a park established for that purpose.

• Reconstruction of a historic structure in its historic location is preceded by a thorough archeological investigation to identify and evaluate those features and artifacts which are essential to an 

accurate reconstruction. Mitigation measures are undertaken including recovery, curation, and 

documentation.

• Reconstruction includes measures to preserve any remaining historic material, features, and spatial relationships.

• Reconstruction is based on the accurate duplication of historic features substantiated by archeological, documentary, or physical evidence, rather than on conjectural designs or the availability of 

different features from other structures. A reconstructed historic structure re-creates the appearance of the non-surviving structure in design, color, texture, and, where possible, materials.

• A reconstruction is clearly identified as a contemporary re-creation.

• Designs that were never executed historically are not constructed.

The following additional standards apply:

• The reconstructed historic structure is full-scale and on the original site.

• The reconstruction does not simulate a damaged or ruined historic structure or constitute a general representation of a “typical” structure.

2. Monitoring and Inspections

Planning for maintenance of historic structures requires information about the nature and condition of their features. These data are collected on a systematic basis using the procedures outlined in 

the Inventory and Condition Assessment Program (ICAP). Major components of ICAP include the 

scheduled and major assessments modules that upload information into the Maintenance Management (MM) program to generate work requests. ICAP work procedures are contained in the Historic 

Property Preservation Database (HPPD) and are compatible with the MM program. ICAP interfaces 

electronically with the List of Classified Structures (LCS) and the Cultural Resources Management 

Bibliography (CRBIB).

As an integrated database with a growing capacity to coordinate information between maintenance 

and resource management, ICAP should be promptly implemented in all parks. All major assessments 

of historic structures should be based on ICAP, and reports of work done to historic structures should 

be recorded in ICAP.

ICAP has now been superseded by FMSS; see Appendix N.

3. Protection

Special attention must be paid to protection of historic structures from threats caused by use and 

environmental forces. Such threats include vandalism, smoking, storage of flammable materials and 

explosives, and vehicular and airplane traffic. Solutions include road patrols, restrictions on smoking 

and storage of flammables (as required in certain cases by Management Policies), proper collection 

and disposal of trash, housekeeping, routine and cyclic maintenance, installation of fire detection and 

suppression systems, limitations on or removal of traffic, and periodic inspections.
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128 Policy, Standards and Guidelines For Historic Preservation In The NPS

CHECKLIST FOR MANAGEMENT OF HISTORIC AND PREHISTORIC STRUCTURES

RESEARCH:

• All structures eligible for the National Register of Historic Places have been identified and nominated.

• All historic structures are in the List of Classified Structures and entries are complete and current.

• Documentary research and physical examination are sufficient to support treatment.

• Work procedures and major assessments are complete in an FMSS format.

• All historic structures have been recorded to levels commensurate with their significance and 

mandated purposes.

• Material samples, field notes, photographs, and construction files composing the resource information base are properly organized and placed in the park museum collection.

• All professional reports and publications are entered in the Cultural Resources Management Bibliography.

PLANNING

• All historic structures are appropriately addressed in the park’s general management plan, development concept plan(s), and interpretive prospectus with respect to their significance, purposes 

or uses, and research bases.

•Plans and specifications for all preservation, rehabilitation, restoration, and reconstruction work 

are prepared by a historical architect.

•Work assignments for preservation maintenance are assigned priority based on the relative significance of assets and the relative seriousness of their condition.

• Required consultation and legal compliance is carried out before any work is initiated, and the 

concerns of consultants are taken into account in decision-making.

STEWARDSHIP:

• All work is done by qualified people in conformance with approved plans and specifications or 

work procedures.

• All historic structures are inspected at least annually in an FMSS format.

• All maintenance personnel who work in, on, or around historic structures are given appropriate 

training.

• The entire park staff is made aware of the significance of all historic structures and the major 

threats to them.

• All ground disturbance around historic structures is cleared or monitored by an archeologist.
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Policy, Standards and Guidelines For Historic Preservation In The NPS 129

CHECKLIST FOR MANAGEMENT OF ARCHEOLOGICAL RESOURCES

RESEARCH:

Sufficient research is conducted to identify and evaluate park archeological resources and to assess their condition and threats to them.

Recovered archeological materials are cleaned, conserved, studied, cataloged, and properly 

stored. Associated records documenting resources are maintained as a part of the archeological 

collection.

Information about archeological resources is compiled and maintained in the archeological 

component of the Cultural Sites Inventory. Paper and electronic records are maintained nationally and at parks, support offices, and centers.

Eligible archeological resources are nominated for listing in the National Register of Historic 

Places.

Park base maps are prepared showing the location and distribution of archeological resources 

and the nature and extent of archeological identification activities.

Research results are disseminated to park managers, planners, interpreters, and other NPS specialists and incorporated into appropriate park planning documents.

PLANNING:

Planning for actions that might affect archeological resources is preceded by research sufficient 

to identify and evaluate such resources.

Planning decisions promote the preservation of archeological resources in place.

Planning decisions that result in adverse effects on archeological resources are made only after 

a thorough analysis of impacts, when there are no feasible alternatives, and when all reasonable 

measures to limit the adverse effects are taken.

Required consultation and legal compliance is carried out, and the concerns raised during consultations are taken into account in decision-making.

STEWARDSHIP:

Archeological resources are preserved and protected by eliminating and avoiding natural and 

human impacts, stabilizing sites and structures, monitoring conditions, and enforcing protective 

laws and regulations.

Information about archeological resources is included, as appropriate, in interpretive and educational programs designed for the public.

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130 Policy, Standards and Guidelines For Historic Preservation In The NPS

MODEL HSR CONTENTS

i. Cover Page

ii. Table of Contents

iii. Executive Summary. This introductory text provides a concise account of (a) research done to produce the HSR, (b) major research findings, (c) major issues identified in the task directive, and (d) 

recommenda-tions for treatment or use. Deviations from general planning documents should be 

identified here and discussed more fully in the body of the report.

iv. Administrative Data. This section contains (a) names, numbers, and locational data used to refer to 

the historic structure, (b) the proposed treatment of the structure including the source document, (c) 

related studies, (d) cultural resource data including date listed in the National Register, period of significance, and context of significance, and (e) recommendations for documentation, cataloging, and 

storage of materials generated by the HSR.

PART 1. DEVELOPMENTAL HISTORY

A. A. Historical Background and Context. This section briefly describes the people and events associated 

with the structure. The section should establish a recommended period or periods of significance if 

this has not been done in the National Register nomination or historic resource study (HRS).

B. B. Chronology of Development and Use. Physical construction, modification, and use of the structure is summarized in this section. The text should be based on historical documentation with corroboration from first-hand observation and materials analysis.

C. C. Physical Description. This section contains a systematic accounting of all features, materials, and 

spaces according to age, significance, and condition. Copies of computer-generated inspection reports 

should be included in the appendix but summarized in the body of the chapter. The text should also 

discuss causes of deterioration and structural adequacy.

PART 2. TREATMENT AND USE

A. A. Ultimate Treatment and Use. This narrative discusses and analyzes the ultimate treatment and use 

of the structure as defined in park planning documents. If they have not been defined, this section may 

recommend an ultimate treatment and use. If analysis of the structure suggests that a planned treatment or use would adversely affect it, the text may present an alternative approach.

B. B. Requirements for Treatment. In concise terms, this text outlines applicable laws, regula-tions, and 

functional requirements. Specific attention should be given to issues of human safety, fire protection, 

energy conservation, abatement of hazardous materials, and handicapped accessibility.

C. C. Alternatives for Treatment. This section presents and evaluates alternative approaches to realization 

of the ultimate treatment. Alternatives are presented in both text and graphic form. Analysis addresses 

the adequacy of each solution in terms of impact on historic materials, effect on historic character, 

compliance with NPS policy, and other management objectives. The section concludes with elaboration on the recommended course of action and specific recommendations for preservation treatments.

PART 3. RECORD OF TREATMENT

A. A. Completion Report. This section summarizes (a) the intent of the work, (b) the way in which the 

work was approached and accomplished, (c) the time required to do the work, and (d) the cost of the 

work. It also describes any information about the history of the structure based on physical evidence 

discovered during construction.

B. B. Technical Data. This portion of the report contains copies of field reports, material data sheets, field 

notes, correspondence, accounting spread sheets, and contract summaries.

APPENDIX

Bibliography

Drawings

Photographs

Materials Analysis
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Historic American Buildings Survey 131

APPENDIX L

Historic American Buildings Survey (HABS) 

The Historic American Buildings Survey (HABS) is the nation’s first federal preservation program, begun in 1933 to document America’s architectural heritage. Creation of the program was 

motivated primarily by the perceived need to mitigate the negative effects upon our history and 

culture of rapidly vanishing architectural resources. At the same time, important early preservation initiatives were just getting underway, such as restoration of the colonial capital at Williamsburg and the development within the National Park Service (NPS) of historical parks and National Historic Sites. Architects interested in the colonial era had previously produced drawings 

and photographs of historic architecture, but only on a limited, local, or regional basis. A source 

was needed to assist with the documentation of our architectural heritage, as well as with design 

and interpretation of historic resources, that was national in scope. As it was stated in the tripartite agreement between the American Institute of Architects, the Library of Congress, and the 

NPS that formed HABS, “A comprehensive and continuous national survey is the logical concern 

of the Federal Government.” As a national survey, the HABS collection is intended to represent 

“a complete resume of the builder’s art.” Thus, the building selection ranges in type and style 

from the monumental and architect-designed to the utilitarian and vernacular, including a sampling of our nation’s vast array of regionally and ethnically derived building traditions.

HABS recording combines drawings, history, and photography to produce a comprehensive, 

interdisciplinary record. The documentation ranges in scope depending largely upon the level 

of significance and complexity. It should first and foremost convey what is most important about 

that particular structure. The drawings component generally includes floor plans, elevations, 

architectural details, and construction elements, sometimes expanded to include sectional or 
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132 Historic American Buildings Survey

axonometric drawings to convey the interrelationship of the building parts. In the case of relatively simple vernacular structures, however, it may be enough to undertake only a first floor plan 

and significant architectural and structural details. The written history follows an outline format 

that begins with a statement of significance supported by the development of the architectural 

and historical context in which the structure was built and subsequently evolved. The report also 

includes architectural description and bibliographic information. Again, in the case of a structure of limited complexity, the HABS “short format” historical report may suffice. The large-format, black-and-white photographs record the environmental setting, elevations, and significant 

details, both inside and out. The number of photographs should be weighted against the other 

components (and vice versa); it may be more appropriate to photograph rather than draw or 

describe elements such as secondary elevations and architectural details. In any case, each component of the documentation conveys an important piece; together they create a comprehensive 

understanding of the site. 

There are four standards that describe the fundamental principles of HABS/HAER documentation:

Standard I: Content

1 Requirement: Documentation shall adequately explicate and illustrate what is significant 

or valuable about the historic building, site, structure, or object being documented.

2. Criteria: Documentation shall meet one of the following documentation levels to be considered adequate for inclusion in the HABS/HAER collections.

a. Documentation Level I;

(1) Drawings: a full set of measured drawings depicting existing or historic conditions.

(2) Photographs: photographs with large-format negatives of exterior and interior 

views; photocopies with large-format negatives of select existing drawings or historic views where available.

(3) Written data: History and description.

b. Documentation Level II;

(1) Drawings: select existing drawings, where available, should be photographed with 

large-format negatives or photographically reproduced on mylar.

(2) Photographs: photographs with large-format negatives of exterior and interior 

views, or historic views, where available.

(3) Written data: history and description.

c. Documentation Level III;

(1) Drawings: sketch plan.

(2) Photographs: photographs with large-format negatives of exterior and interior 

views.

(3) Written data: architectural data form.

d. Documentation Level IV: HABS/HAER inventory card.

3. Test: Inspection of the documentation by HABS/HAER staff.

4. Commentary: The HABS/HAER office retains the right to refuse to accept any documentation on buildings, sites, structures or objects lacking historical significance. Generally, 

buildings, sites, structures or objects must be listed in, or eligible for listing in the National 

Register of Historic Places to be considered for inclusion in the HABS/HAER collections.

The kind and amount of documentation should be appropriate to the nature and significance of the buildings, site, structure or object being documented. Generally, Level I 

documentation is required for nationally significant buildings and structures, defined as 

National Historic Landmarks and the primary historic units of the National Park Service. 

On occasion, factors other than significance will dictate the selection of another level of 
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Historic American Buildings Survey 133

documentation. For example, if a rehabilitation of a property is planned, the owner may 

wish to have a full set of as-built drawings, even though the significance may indicate Level II documentation. Level IV documentation consists of completed HABS/HAER inventory cards. This level of documentation, unlike the other three levels, is rarely considered 

adequate documentation for the HABS/HAER collections but is undertaken to identify 

historic resources in a given area prior to additional, more comprehensive documentation.

Standard II: Quality

1. Requirement: HABS and HAER documentation shall be prepared accurately from reliable 

sources with limitations clearly stated to permit independent verification of information.

2. Criteria: For all levels of documentation, the following quality standards shall be met:

a. Measured drawings: Measured drawings shall be produced from recorded, accurate 

measurements.. No part of the measured drawings shall be produced from hypothesis 

or non-measurement related activities. Documentation Level I measured drawings 

shall be accompanied by a set of field notebooks in which the measurements were first 

recorded. Other drawings prepared for Documentation Levels II and III, shall include 

a statement describing where the original drawings are located.

b. Large format photographs: Large format photographs shall clearly depict the appearance of the property and areas of significance of the recorded building, site, structure 

or object. Each view shall be perspective-corrected and fully captioned.

c. Written history: Written history and description for Documentation Levels I and II 

shall be based on primary sources to the greatest extent possible. For Levels III and 

IV, secondary sources may provide adequate information; if not, primary research will 

be necessary.

3. Test: Inspection of the documentation by HABS/HAER staff.

4. Commentary: The reliability of the HABS/HAER collections depends on documentation 

of high quality. Quality is not something that can be easily prescribed or quantified, but it 

derives from a process in which thoroughness and accuracy play a large part. The principle of independent verification of HABS/HAER documentation is critical to the HABS/

HAER collections.

Standard III: Materials

1. Requirement: HABS and HAER documentation shall be prepared on materials that are 

readily reproducible for ease of access; durable for long storage; and in standard sizes for 

ease of handling.

2. Criteria: For all levels of documentation, the following material standards shall be met:

a. Measured Drawings:

Readily Reproducible: Ink on translucent material.

Durable: Ink on archivally stable materials.

Standard Sizes: Two sizes: 19 X 24” or 24 X 36”.

b. Large Format Photographs:

Readily Reproducible: Prints shall accompany all negatives.

Durable: Photography must be archivally processed and stored. Negatives are required 

on safety film only. Resin-coated paper is not accepted. Color photography is not acceptable.

Standard Sizes: Three sizes: 4 X 5”, 5 X 7”, 8 X 10”.

c. Written History and Description:

Readily Reproducible: Clean copy for xeroxing.

Durable: Archival bond required.

Standard Sizes: 81⁄2 X 11”.

d. Field Records:
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134 Historic American Buildings Survey

Readily Reproducible: Field notebooks may be xeroxed. Photo identification sheet will 

accompany 35 mm negatives and contact sheets.

Durable: No requirement

Standard Sizes: Only requirement is that they can be made to fit into a 91⁄2 X 12” archival folding file.

3. Test: Inspection of the documentation by HABS/HAER staff.

4. Commentary: All HABS/HAER records are intended for reproduction; some 20,000 

HABS/HAER records are reproduced each year by the Library of Congress. Although 

field records are not intended for quality reproduction, it is intended that they be used 

to supplement the formal documentation. The basic durability performance standard for 

HABS/HAER records is 500 years. Ink on mylar is believed to meet this standard, while 

color photography, for example, does not. Field records do not meet this archival standard, but are maintain in the HABS/HAER collections as a courtesy to the collection user.

Standard IV: Preservation

1. Requirement: HABS and HAER documentation shall be clearly and concisely produced.

2. Criteria: For levels of documentation as indicated below, the following standards for presentation will be used:

a. Measured Drawings: Level I measured drawings will be lettered mechanically (i.e., 

Leroy or similar) or in a hand printed equivalent style. Adequate dimensions shall be 

included on all sheets. Level III sketch plans should be neat and orderly.

b. Large format photographs: Level I photographs shall include duplicate photographs 

that include a scale. Level II and III photographs shall include, at a minimum, at least 

one photograph with a scale, usually of the principal facade.

c. Written history and description: Data shall be typewritten on bond, following accepted rules of grammar.

3. Test: Inspection of the documentation by HABS/HAER staff.

In addition to the Standards, guidelines provide direction in the production of measured drawings to HABS Standards. These guidelines cover:

1.0 Project Preparation 

2.0 Field Notes 

3.0 Measuring Structures

4.0 Preliminary (Pencil) Drawings

5.0 Ink On Drafting Film Drawings 

6.0 Landscape Documentation

7.0 Documentation Of Construction Histories And Site Development

8.0 Completing The Set

HABS appendices cover the additional topics of: Graphic Constructions; Perimeters, Areas and 

Volumes; Using Trigonometric Laws and Functions to Solve Surveying Problems; Determining 

the Heights of Tall Structures with a Transit; Measuring Circular Objects and Areas; Projections 

from Plans to Elevations, and; English and Metric Systems.

More detail on the Historic American Building Survey and its Standards and Guidelines can be 

found at the NPS Heritage Documentation Programs website: http://www.nps.gov/hdp/index.

htm.
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Historic American Buildings Survey 135
Vanishing Treasures Resources

136 National and International Charters, Declarations and Codes

APPENDIX M

Commentary and Excerpts from other Relevant National and International 

Charters, Declarations, and Codes

Grand Canyon National Park, Chaco Culture National Historical Park and Mesa Verde National Park have 

the distinction of being designated as World Heritage Sites. The Convention Concerning the Protection of 

the World Cultural and Natural Heritage (the World Heritage Convention) was adopted by the UNESCO 

General Conference at its 17th session in Paris on 16 November 1972. The Convention came into force in 

1975 and as of December 2001 had 170 member countries. The list includes twenty American places. The 

Convention is considered the most successful global instrument for the protection of cultural and natural 

heritage.

The World Heritage Convention aims to promote cooperation among nations to protect heritage from 

around the world that is of such outstanding universal value that its conservation is important for current 

and future generations. It is intended that, unlike the seven wonders of the ancient world, properties on the 

World Heritage List will be conserved for all time. States Parties to the Convention commit themselves to 

ensure the identification, protection, conservation and presentation of World Heritage Properties. States 

recognize that the identification and safeguarding of heritage located in their territory is primarily their 

responsibility. They agree to do all they can, using their own resources and, at times with international assistance, to protect their World Heritage Properties. They agree, amongst other things, to as far as possible:

•adopt a general policy which aims to give the cultural and natural heritage a function in the life of the 

community and to integrate the protection of that heritage into comprehensive planning programs. 

•undertake ‘appropriate legal, scientific, technical, administrative and financial measures necessary for 

the identification, protection, conservation, presentation and rehabilitation of this heritage’ 

•refrain from ‘any deliberate measures which might damage, directly or indirectly, the cultural and 

natural heritage’ of other Parties to the Convention, and to help other Parties in the identification and 

protection of their properties 

This international recognition afforded by the Convention suggests that additional charters be referenced 

so as to provide guidance to the safeguarding of the status of the listed sites. It should be recognized that 

similar issues and problems confronting Vanishing Treasures sites exist elsewhere in the world. The United 

States has participated actively in the Convention and has had involvement in the drafting of many of the 

documents that follow. Resource protection philosophy and applied technology has been shared internationally for many years. The higher status of these sites and the heightened attention they receive which 

often results in increased funding, more projects and a higher level of applied conservation can provide, 

through demonstrable action, benchmarks for other work that occurs on other Vanishing Treasures sites.

These excerpts inform our history and process.
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National and International Charters, Declarations and Codes 137

Excerpted from: 

The Athens Charter for the Restoration of Historic Monuments

Adopted at the First International Congress of Architects and Technicians of Historic Monuments, Athens 

1931:

VI. -- THE TECHNIQUE of CONSERVATION.

The Conference is gratified to note that the principles and technical considerations set forth in the different 

detailed communications are inspired by the same idea, namely: 

In the case of ruins, scrupulous conservation is necessary and steps should be taken to reinstate any 

original fragments that may be recovered (anastylosis) whenever this is possible; the new materials used 

for this purpose should in all cases be recognizable. When the preservation of ruins brought to light in the 

course of excavations is found to be impossible, the Conference recommends that they be buried, accurate 

records being of course taken before filling-in operations are undertaken. 

It should be unnecessary to mention that the technical work undertaken in connection with the excavation 

and preservation of ancient monuments calls for close collaboration between the archaeologist and the 

architect. 

With regard to other monuments, the experts unanimously agreed that, before any consolidation or partial 

restoration is undertaken, a thorough analysis should be made of the defects and the nature of the decay of 

these monuments. They recognized that each case needed to be treated individually. 
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138 National and International Charters, Declarations and Codes

Excerpted from: 

The VENICE CHARTER - 1964

[Preamble] 

Imbued with a message from the past, the historic monuments of generations of people remain to the present day as living witnesses of their age-old traditions. People are becoming more and more conscious of the 

unity of human values and regard ancient monuments as a common heritage. The common responsibility 

to safeguard them for future generations is recognized. It is our duty to hand them on in the full richness of 

their authenticity. 

It is essential that the principles guiding the preservation and restoration of ancient buildings should be 

agreed and be laid down on an international basis, with each country being responsible for applying the 

plan within the framework of its own culture and traditions. 

By defining these basic principles for the first time, the Athens Charter of 1931 contributed towards the 

development of an extensive international movement which has assumed concrete form in national documents, in the work of ICOM and UNESCO and in the establishment by the latter of the International 

Centre for the Study of the Preservation and the Restoration of Cultural Property. Increasing awareness 

and critical study have been brought to bear on problems which have continually become more complex 

and varied; now the time has come to examine the Charter afresh in order to make a thorough study of the 

principles involved and to enlarge its scope in a new document. 

Accordingly, the IInd International Congress of Architects and Technicians of Historic Monuments, which 

met in Venice from May 25th to 31st 1964, approved the following text: 

Excerpts from the section: 

VENICE CHARTER CONSERVATION

ARTICLE 4. It is essential to the conservation of monuments that they be maintained on a permanent 

basis. 

ARTICLE 5. The conservation of monuments is always facilitated by making use of them for some socially useful purpose. Such use is therefore desirable but it must not change the lay-out or decoration of 

the building. It is within these limits only that modifications demanded by a change of function should be 

envisaged and may be permitted. 

ARTICLE 6. The conservation of a monument implies preserving a setting which is not out of scale. Wherever the traditional setting exists, it must be kept. No new construction, demolition or modification which 

would alter the relations of mass and color must be allowed. 

ARTICLE 7. A monument is inseparable from the history to which it bears witness and from the setting in 

which it occurs. The moving of all or part of a monument cannot be allowed except where the safeguarding of that monument demands it or where it is justified by national or international interest of paramount 

importance. 

ARTICLE 8. Items of sculpture, painting or decoration which form an integral part of a monument may 

only be removed from it if this is the sole means of ensuring their preservation. 
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National and International Charters, Declarations and Codes 139

Excepted from the section:

RESTORATION

ARTICLE 9. The process of restoration is a highly specialized operation. Its aim is to preserve and reveal 

the aesthetic and historic value of the monument and is based on respect for original material and authentic 

documents. It must stop at the point where conjecture begins, and in this case moreover any extra work 

which is indispensable must be distinct from the architectural composition and must bear a contemporary 

stamp. The restoration in any case must be preceded and followed by an archaeological and historical study 

of the monument. 

ARTICLE 10. Where traditional techniques prove inadequate, the consolidation of a monument can be 

achieved by the use of any modem technique for conservation and construction, the efficacy of which has 

been shown by scientific data and proved by experience. 

ARTICLE 11. The valid contributions of all periods to the building of a monument must be respected, 

since unity of style is not the aim of a restoration. When a building includes the superimposed work of 

different periods, the revealing of the underlying state can only be justified in exceptional circumstances 

and when what is removed is of little interest and the material which is brought to light is of great historical, 

archaeological or aesthetic value, and its state of preservation good enough to justify the action. Evaluation 

of the importance of the elements involved and the decision as to what may be destroyed cannot rest solely 

on the individual in charge of the work. 

ARTICLE 12. Replacements of missing parts must integrate harmoniously with the whole, but at the same 

time must be distinguishable from the original so that restoration does not falsify the artistic or historic 

evidence. 

ARTICLE 13. Additions cannot be allowed except in so far as they do not detract from the interesting parts 

of the building, its traditional setting, the balance of its composition and its relation with its surroundings. 
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140 National and International Charters, Declarations and Codes

Excerpted from: 

THE DECLARATION OF SAN ANTONIO - 1996

We, the presidents, delegates and members of the ICOMOS National Committees of the Americas, met in 

San Antonio, Texas, United States of America, from the 27th to the 30th of March, 1996, at the Inter-American Symposium on Authenticity in the Conservation and Management of the Cultural Heritage to discuss 

the meaning of authenticity in preservation in the Americas. We did so in response to the call issued by the 

Secretary General of ICOMOS for regional participation in the international debate on the subject. 

AUTHENTICITY AND MATERIALS

The material fabric of a cultural site can be a principal component of its authenticity. As emphasized in 

Article 9 of the Venice Charter, the presence of ancient and original elements is part of the basic nature of 

a heritage site. The Charter also indicates that the material elements of our tangible cultural heritage are 

bearers of important information about our past and our identity. Those messages include information 

about a site’s original creation as well as the layered messages that resulted from the interaction between 

the resource and new and diverse cultural circumstances. For these reasons, those materials and their setting need to be identified, evaluated and protected. In the case of cultural landscapes, the importance of 

material fabric must be weighed along with the immaterial distinctive character and components of the site. 

Over time, heritage sites have come to possess a testimonial value - which may be aesthetic, historic or otherwise - that is readily evident to most of society. In addition to the testimonial value, there are less evident 

documentary values that require an understanding of the historic fabric in order to identify their meaning 

and their message. Since the documentary value responds to evolving questions posed by the community 

over time, it is important that the material evidence, defined in terms of design, materials, manufacture, 

location, and context be preserved in order to retain its ability to continue to manifest and convey those 

concealed values to present and future generations. 

The degree to which documented missing elements are replaced as part of restoration treatments varies 

within the Americas in accordance to the cultural characteristics of each country. Some national policies 

indicate that what is lost can only be part of our memory and not of our heritage. Elsewhere, policies encourage the replacement of fully documented elements in facsimile form in order to re-establish the site’s 

full significance. Nevertheless, we emphasize that only the historic fabric is authentic, and interpretations 

achieved through restoration are not; they can only authentically represent the meaning of a site as understood in a given moment. Furthermore, we universally reject the reliance on conjecture or hypotheses for 

restoration. 

That further consideration be given to the proofs of authenticity so that indicators may be identified for 

such a determination in a way that all significant values in the site may be set forth. The following are some 

examples of indicators: 

Reflection of the true value. That is, whether the resource remains in the condition of its creation and 

reflects all its significant history. 

Integrity. That is, whether the site is fragmented; how much is missing, and what are the recent additions. 

Context. That is, whether the context and/or the environment correspond to the original or other periods of significance; and whether they enhance or diminish the significance. 

Identity. That is, whether the local population identify themselves with the site, and whose identity the 

site reflects. 

Use and function. That is, the traditional patterns of use that have characterized the site.

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National and International Charters, Declarations and Codes 141

Some important and relevant language from the NAGPRA law is provided and relevant excerpts from the 

New Zealand treaty of Waitangi follow that. These relate to the important issues of contextual relationships 

with native populations and give definition to what has been termed “intangibles” in the modern lexicon of 

historic preservation. 

Excerpted from: 

NAGPRA 43 CFR 10.2 Cultural affiliation

(e) What is cultural affiliation? Cultural affiliation means that there is a relationship of shared group 

identity which can reasonably be traced historically or prehistorically between members of a presentday Indian tribe or Native Hawaiian organization and an identifiable earlier group. Cultural affiliation 

is established when the preponderance of the evidence — based on geographical, kinship, biological, 

archeological, linguistic, folklore, oral tradition, historical evidence or other information or expert 

opinion — reasonably leads to such a conclusion.

(f) What types of lands do the excavation and discovery provisions of these regulations apply to? (1) 

Federal lands means any land other than tribal lands that are controlled or owned by the United States 

Government, including lands selected by but not yet conveyed to Alaska Native Corporations and 

groups organized pursuant to the Alaska.

Native Claims Settlement Act (43 U.S.C. 1601 et seq.). United States ‘‘control,’’ as used in this definition, 

refers to those lands not owned by the United States but in which the United States has a legal interest 

sufficient to permit it to apply these regulations without abrogating the otherwise existing legal rights of a 

person.

Pursuant to NAGPRA the example in New Zealand has relevance.

Excerpted from: 

ICOMOS NEW ZEALAND- Charter for the Conservation of Places of Cultural Heritage Value

The Treaty of Waitangi is the historical basis for indigenous guardianship. It recognizes the indigenous 

people as exercising responsibility for their treasures, monuments and sacred places. This interest extends 

beyond current legal ownership wherever such heritage exists. Particular knowledge of heritage values is 

entrusted to chosen guardians. The conservation of places of indigenous cultural heritage value therefore 

is conditional on decisions made in the indigenous community, and should proceed only in this context. 

Indigenous conservation precepts are fluid and take account of the continuity of life and the needs of the 

present as well as the responsibilities of guardianship and association with those who have gone before. In 

particular, protocols of access, authority and ritual are handled at a local level. General principles of ethics 

and social respect affirm that such protocols should be observed.
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142 National and International Charters, Declarations and Codes

Excerpted from: 

CHARTER FOR THE PROTECTION AND MANAGEMENT OF THE ARCHAEOLOGICAL 

HERITAGE (1990) 

Prepared by the International Committee for the Management of Archaeological Heritage (ICAHM) an 

approved by the 9th General Assembly in Lausanne in 1990. 

MAINTENANCE AND CONSERVATION 

Article 6. 

The overall objective of archaeological heritage management should be the preservation of monuments 

and sites in situ, including proper long-term conservation and curation of all related records and collections etc. Any transfer of elements of the heritage to new locations represents a violation of the principle 

of preserving the heritage in its original context. This principle stresses the need for proper maintenance, 

conservation and management. It also asserts the principle that the archaeological heritage should not be 

exposed by excavation or left exposed after excavation if provision for its proper maintenance and management after excavation cannot be guaranteed. 

Local commitment and participation should be actively sought and encouraged as a means of promoting 

the maintenance of the archaeological heritage. This principle is especially important when dealing with 

the heritage of indigenous peoples or local cultural groups. In some cases it may be appropriate to entrust 

responsibility for the protection and management of sites and monuments to indigenous peoples. 

Owing to the inevitable limitations of available resources, active maintenance will have to be carried out on 

a selective basis. It should therefore be applied to a sample of the diversity of sites and monuments, based 

upon a scientific assessment of their significance and representative character, and not confined to the 

more notable and visually attractive monuments. 

The relevant principles of the 1956 UNESCO Recommendations should be applied in respect of the maintenance and conservation of the archaeological heritage. 

excerpted from the section : 

PRESENTATION, INFORMATION, RECONSTRUCTION 

Article 7.

The presentation of the archaeological heritage to the general public is an essential method of promoting an understanding of the origins and development of modern societies. At the same time it is the most 

important means of promoting an understanding of the need for its protection. 

Presentation and information should be conceived as a popular interpretation of the current state of 

knowledge, and it must therefore be revised frequently. It should take account of the multifaceted approaches to an understanding of the past. 

Reconstructions serve two important functions: experimental research and interpretation. They should, 

however, be carried out with great caution, so as to avoid disturbing any surviving archaeological evidence, 

and they should take account of evidence from all sources in order to achieve authenticity. Where possible and appropriate, reconstructions should not be built immediately on the archaeological remains, and 

should be identifiable as such.
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ETHICS

The American Institute for the Conservation of Historic and Artistic Works (AIC) has provided the professional field with a Code of Ethics. This has been included because the focus and quality of the Code can 

be used to provide ethical standards for those practicing conservation activities relating to treatments on 

historic monuments generally. The fundamental authenticity of sites within the VT program which can be 

considered of irreplaceable value puts them in the highest category of cultural resources; thus, approaching such sites demands that the highest level of integrity and professionalism be applied. This level is well 

defined by the AIC Code. This Code is focused on the private sector which directly relates to work which 

might be performed under contract and thus guides expectations which might be placed on contractors 

working on VT sites. Civil servants charged with resource management responsibilities can apply these 

standards through an adaptive process refocusing from a public sector point of view. 

Excerpted from: 

The CODE OF ETHICS of the American Institute for Conservation of Historic and Artistic Works

PREAMBLE

The primary goal of conservation professionals, individuals with extensive training and special expertise, 

is the preservation of cultural property. Cultural property consists of individual objects, structures, or aggregate collections. It is material which has significance that may be artistic, historical, scientific, religious, 

or social, and it is an invaluable and irreplaceable legacy that must be preserved for future generations. In 

striving to achieve this goal, conservation professionals assume certain obligations to the cultural property, 

to its owners and custodians, to the conservation profession, and to society as a whole. This document, 

the Code of Ethics and Guidelines for Practice of the American Institute for Conservation of Historic and 

Artistic Works (AIC), sets forth the principles that guide conservation professionals and others who are 

involved in the care of cultural property.

I. The conservation professional shall strive to attain the highest possible standards in all aspects of conservation, including, but not limited to, preventive conservation, examination, documentation, treatment, 

research, and education.

II. All actions of the conservation professional must be governed by an informed respect for the cultural 

property, its unique character and significance, and the people or person who created it.

III. While recognizing the right of society to make appropriate and respectful use of cultural property, the 

conservation professional shall serve as an advocate for the preservation of cultural property.

IV. The conservation professional shall practice within the limits of personal competence and education as 

well as within the limits of the available facilities.

V. While circumstances may limit the resources allocated to a particular situation, the quality of work that 

the conservation professional performs shall not be compromised.

VI. The conservation professional must strive to select methods and materials that, to the best of current 

knowledge, do not adversely affect cultural property or its future examination, scientific investigation, 

treatment, or function.

VII. The conservation professional shall document examination, scientific investigation, and treatment by 

creating permanent records and reports.

VIII. The conservation professional shall recognize a responsibility for preventive conservation by endeavoring to limit damage or deterioration to cultural property, providing guidelines for continuing use and 

care, recommending appropriate environmental conditions for storage and exhibition, and encouraging 

proper procedures for handling, packing, and transport.
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144 National and International Charters, Declarations and Codes

IX. The conservation professional shall act with honesty and respect in all professional relationships, seek 

to ensure the rights and opportunities of all individuals in the profession, and recognize the specialized 

knowledge of others.

X. The conservation professional shall contribute to the evolution and growth of the profession, a field of 

study that encompasses the liberal arts and the natural sciences. This contribution may be made by such 

means as continuing development of personal skills and knowledge, sharing of information and experience with colleagues, adding to the profession’s written body of knowledge, and providing and promoting 

educational opportunities in the field.

XI. The conservation professional shall promote an awareness and understanding of conservation through 

open communication with allied professionals and the public.

XII. The conservation professional shall practice in a manner that minimizes personal risks and hazards 

to co-workers, the public, and the environment. XIII. Each conservation professional has an obligation to 

promote understanding of and adherence to this Code of Ethics.

GUIDELINES FOR PRACTICE 

of the American Institute for Conservation of Historic and Artistic Works

The conservation professional should use the following guidelines and supplemental commentaries together with the AIC Code of Ethics in the pursuit of ethical practice. The commentaries are separate documents, created by the AIC membership, that are intended to amplify this document and to accommodate 

growth and change in the field.

PROFESSIONAL CONDUCT

1. Conduct: Adherence to the Code of Ethics and Guidelines for Practice is a matter of personal responsibility. The conservation professional should always be guided by the intent of this document, recognizing 

that specific circumstances may legitimately affect professional decisions. 

2. Disclosure: In professional relationships, the conservation professional should share complete and accurate information relating to the efficacy and value of materials and procedures. In seeking and disclosing 

such information, and that relating to analysis and research, the conservation professional should recognize the importance of published information that has undergone formal peer review.

3. Laws and Regulations: The conservation professional should be cognizant of laws and regulations that 

may have a bearing on professional activity. Among these laws and regulations are those concerning the 

rights of artists and their estates, occupational health and safety, sacred and religious material, excavated 

objects, endangered species, human remains, and stolen property.

4. Practice: Regardless of the nature of employment, the conservation professional should follow appropriate standards for safety, security, contracts, fees, and advertising.

4a. Health and Safety: The conservation professional should be aware of issues concerning the safety 

of materials and procedures and should make this information available to others, as appropriate. 

4b. Security: The conservation professional should provide working and storage conditions designed 

to protect cultural property. 

4c. Contracts: The conservation professional may enter into contractual agreements with individuals, 

institutions, businesses, or government agencies provided that such agreements do not conflict with 

principles of the Code of Ethics and Guidelines for Practice. 

4d. Fees: Fees charged by the conservation professional should be commensurate with services rendered. The division of a fee is acceptable only when based on the division of service or responsibility. 
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National and International Charters, Declarations and Codes 145

4e. Advertising: Advertising and other representations by the conservation professional should present an accurate description of credentials and services. Limitations concerning the use of the AIC 

name or membership status should be followed as stated in the AIC Bylaws, section II, 13. 

5. Communication: Communication between the conservation professional and the owner, custodian, or 

authorized agent of the cultural property is essential to ensure an agreement that reflects shared decisions 

and realistic expectations.

6. Consent: The conservation professional should act only with the consent of the owner, custodian, or 

authorized agent. The owner, custodian, or agent should be informed of any circumstances that necessitate significant deviations from the agreement. When possible, notification should be made before such 

changes are made.

 7. Confidentiality: Except as provided in the Code of Ethics and Guidelines for Practice, the conservation 

professional should consider relationships with an owner, custodian, or authorized agent as confidential. Information derived from examination, scientific investigation, or treatment of the cultural property 

should not be published or otherwise made public without written permission. 

8. Supervision: The conservation professional is responsible for work delegated to other professionals, 

students, interns, volunteers, subordinates, or agents and assignees. Work should not be delegated or 

subcontracted unless the conservation professional can supervise the work directly, can ensure proper supervision, or has sufficient knowledge of the practitioner to be confident of the quality of the work. When 

appropriate, the owner, custodian, or agent should be informed if such delegation is to occur.

9. Education: Within the limits of knowledge, ability, time, and facilities, the conservation professional is 

encouraged to become involved in the education of conservation personnel. The objectives and obligations 

of the parties shall be agreed upon mutually.

10. Consultation: Since no individual can be expert in every aspect of conservation, it may be appropriate to consult with colleagues or, in some instances, to refer the owner, custodian, or authorized agent to a 

professional who is more experienced or better equipped to accomplish the required work. If the owner 

requests a second opinion, this request must be respected.

11. Recommendations and References: The conservation professional should not provide recommendations without direct knowledge of a colleague’s competence and experience. Any reference to the work of 

others must be based on facts and personal knowledge rather than on hearsay.

12. Adverse Commentary: A conservation professional may be required to testify in legal, regulatory, or administrative proceedings concerning allegations of unethical conduct. Testimony concerning such matters 

should be given at these proceedings or in connection with paragraph 13 of these Guidelines.

13. Misconduct: Allegations of unethical conduct should be reported in writing to the AIC president as 

described in the AIC Bylaws, section II, 12. As stated in the bylaws, all correspondence regarding alleged 

unethical conduct shall be held in the strictest confidence. Violations of the Code and Guidelines that constitute unethical conduct may result in disciplinary action.

14. Conflict of Interest: The conservation professional should avoid situations in which there is a potential 

for a conflict of interest that may affect the quality of work, lead to the dissemination of false information, 

or give the appearance of impropriety.

15. Related Professional Activities: The conservation professional should be especially mindful of the considerable potential for conflict of interest in activities such as authentication, appraisal, or art dealing.
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EXAMINATION AND SCIENTIFIC INVESTIGATION

16. Justification: Careful examination of cultural property forms the basis for all future action by the 

conservation professional. Before undertaking any examination or tests that may cause change to cultural 

property, the conservation professional should establish the necessity for such procedures.

17. Sampling and Testing: Prior consent must be obtained from the owner, custodian, or agent before any 

material is removed from a cultural property. Only the minimum required should be removed, and a record 

of removal must be made. When appropriate, the material removed should be retained.

18. Interpretation: Declarations of age, origin, or authenticity should be made only when based on sound 

evidence. 

19. Scientific Investigation: The conservation professional should follow accepted scientific standards and 

research protocols.

PREVENTIVE CONSERVATION

20. Preventive Conservation: The conservation professional should recognize the critical importance of 

preventive conservation as the most effective means of promoting the long-term preservation of cultural 

property. The conservation professional should provide guidelines for continuing use and care, recommend appropriate environmental conditions for storage and exhibition, and encourage proper procedures 

for handling, packing, and transport. 

TREATMENT

21. Suitability: The conservation professional performs within a continuum of care and will rarely be the 

last entrusted with the conservation of a cultural property. The conservation professional should only 

recommend or undertake treatment that is judged suitable to the preservation of the aesthetic, conceptual, 

and physical characteristics of the cultural property. When nonintervention best serves to promote the 

preservation of the cultural property, it may be appropriate to recommend that no treatment be performed

22. Materials and Methods: The conservation professional is responsible for choosing materials and methods appropriate to the objectives of each specific treatment and consistent with currently accepted practice. The advantages of the materials and methods chosen must be balanced against their potential adverse 

effects on future examination, scientific investigation, treatment, and function. 

23. Compensation for Loss: Any intervention to compensate for loss should be documented in treatment 

records and reports and should be detectable by common examination methods. Such compensation 

should be reversible and should not falsely modify the known aesthetic, conceptual, and physical characteristics of the cultural property, especially by removing or obscuring original material.

DOCUMENTATION

24. Documentation: The conservation professional has an obligation to produce and maintain accurate, 

complete, and permanent records of examination, sampling, scientific investigation, and treatment. When 

appropriate, the records should be both written and pictorial. The kind and extent of documentation may 

vary according to the circumstances, the nature of the object, or whether an individual object or a collection is to be documented. The purposes of such documentation are: 

to establish the condition of cultural property; 

to aid in the care of cultural property by providing information helpful to future treatment and by adding to the profession’s body of knowledge; 

to aid the owner, custodian, or authorized agent and society as a whole in the appreciation and use of 

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National and International Charters, Declarations and Codes 147

cultural property by increasing understanding of an object’s aesthetic, conceptual, and physical characteristics; 

and to aid the conservation professional by providing a reference that can assist in the continued development of knowledge and by supplying records that can help avoid misunderstanding and unnecessary litigation. 

25. Documentation of Examination: Before any intervention, the conservation professional should make 

a thorough examination of the cultural property and create appropriate records. These records and the 

reports derived from them must identify the cultural property and include the date of examination and 

the name of the examiner. They also should include, as appropriate, a description of structure, materials, 

condition, and pertinent history.

EMERGENCY SITUATIONS

29. Emergency Situations: Emergency situations can pose serious risks of damage to or loss of cultural 

property that may warrant immediate intervention on the part of the conservation 26. Treatment Plan: Following examination and before treatment, the conservation professional should prepare a plan describing 

the course of treatment. This plan should also include the justification for and the objectives of treatment, 

alternative approaches, if feasible, and the potential risks. When appropriate, this plan should be submitted 

as a proposal to the owner, custodian, or authorized agent. 

27. Documentation of Treatment: During treatment, the conservation professional should maintain dated 

documentation that includes a record or description of techniques or procedures involved, materials used 

and their composition, the nature and extent of all alterations, and any additional information revealed 

or otherwise ascertained . A report prepared from these records should summarize this information and 

provide, as necessary, recommendations for subsequent care.

28. Preservation of Documentation: Documentation is an invaluable part of the history of cultural property and should be produced and maintained in as permanent a manner as practicable. Copies of reports 

of examination and treatment must be given to the owner, custodian, or authorized agent, who should be 

advised of the importance of maintaining these materials with the cultural property. Documentation is 

also an important part of the profession’s body of knowledge. The conservation professional should strive 

to preserve these records and give other professionals appropriate access to them, when access does not 

contravene agreements regarding confidentiality.

In an emergency that threatens cultural property, the conservation professional should take all reasonable 

action to preserve the cultural property, recognizing that strict adherence to the Guidelines for Practice 

may not be possible.

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148 Facility Management Software System 

APPENDIX N

A Summary of Maintained Archeological Sites in the Facility Management Software System

The National Park Service manages over 68,000 archeological sites in park units throughout the country. A 

percentage of those archeological sites receive care and intervention by cultural resource experts and facilities management staff, sometimes in tandem, to ensure they are stabilized, preserved and well-maintained. 

A group of NPS archeologists, facilities management experts, and park managers (the Maintained Archeological Sites Working Group [MASWG]) worked on integrating the operations and maintenance of specific 

archeological sites with the Facility Management Software System (FMSS) since 2006. This integration 

enables park managers, facilities management and cultural resource staffs to:

estimate and plan more efficiently the maintenance needs for specific park archeological sites 

determine and document the long-term requirements and costs to maintain these sites at the park, 

regional and national levels

apply for funding from Facility Management funding sources, such as Cyclical or Repair, Rehab, or the 

Recreation Fee Program

track staff time, costs and project funding for archeological site maintenance

The MASWG began by defining Maintained Archeological Sites (MAS) as archeological sites within the 

NPS system that are maintained actively. This involves improvements to an archeological site that extend 

its life and enhance its value through conservation or preservation activities. Such activities include preventative maintenance, in-kind replacement of parts and structural components, conservation treatments, 

recurring repairs, normal repairs, unscheduled repairs, and other actions. Active maintenance of archeological sites is part of a resource stewardship and management program. Reasons for active maintenance of 

archeological sites include: (a) to retain structural and physical integrity, (b) to correct or prevent deterioration, (c) to be kept at or brought to a state of “fair” or “good” condition under ASMIS criteria, (d) for 

public interpretation, (e) emergency situations, or (e) for other management purposes.

As of January 2009, all the protocols to enter a MAS into FMSS are in place, including the asset specification template, the equipment specification templates, and the data fields necessary to develop work orders 

on MAS. The MAS Business Practices are also finalized (see web page below), which provide guidance on: 

the general management approach to MAS

how to identify a park’s inventory of MAS and the various kinds of archeological sites that may be MAS

how to create an asset record for a MAS in FMSS

how to classify and rank MAS within the FMSS framework

how to deal with potential overlaps between MAS and other asset types

MAS and the Current Replacement Value (CRV)

MAS and the Asset Priority Index (API) 

how to inspect a MAS to determine its condition and deferred maintenance needs 

All parks have an asset portfolio and an accompanying asset management plan. The portfolio must include 

MAS, if a park has any. The plan must integrate maintenance goals and objectives for MAS, if a park has 

any. Also, specific maintenance activities for MAS need to be included in a park’s annual funding plans 

and project schedules so these assets may be preserved and used over the long term as important places for 

commemoration, historical and scientific research, and/or visitor interpretation. MAS included in a park’s 

asset portfolio, plan, and FMSS are only those expected to require ongoing maintenance activities.

The maintenance, documentation and tracking in FMSS of MAS are the responsibility of facility maintenance staff members at a park. However, facility managers and maintenance staff members must collaborate with archeologists and cultural resource managers to produce the most effective outcomes of a maintenance program designed to sustain the integrity of certain archeological sites while maintaining them in a 

condition that promotes the use and interpretation of sites to further the mission of the NPS.

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Facility Management Software System 149

Identifying MAS

To create an effective asset management program for archeological sites, park managers must first identify any MAS within their park. The service-wide Archeological Sites Management Information System 

(ASMIS) database provides the overall inventory of NPS archeological sites. However, the archeologist or 

cultural resources staff and facilities management staff at each park and region, when appropriate, must 

identify which, if any, archeological sites in ASMIS are actively maintained and require treatment. The 

park then must value what those assets are worth, assess their condition, and determine what it will take to 

sustain them over time.

The primary criteria used to identify a MAS are:

The archeological site is registered in ASMIS as a site or sub-site.

The site fabric was previously stabilized.

The site must be maintained for physical integrity.

The site must be maintained for interpretation purposes.

The site is regularly accessed by the public, presenting potential safety hazards or impacts from visitor 

use that requires treatment.

The park performs regular routine or cyclic maintenance at the site.

The park has applied for funding and/or plans to perform major site work (e.g. fabric or environmental 

stabilization along with the appropriate documentation).

The park wants to track staff time, costs, and project funding for site maintenance.

Evaluating Archeological Sites Already Registered in FMSS

MAS are asset code 7200, formerly called “Ruins,” in FMSS. Approximately 1,200 existing “Ruins” assets have been rolled into MAS as of June 2008, because the latter can be more broadly interpreted and 

include a wider variety of archeological sites.

The MASWG evaluated the list of assets once coded as “Ruins” in FMSS to determine which ones are 

definitely MAS and which ones might need to be reclassified. Approximately 900 assets were determined 

to be MAS. The MASWG intends to contact each park with the potential non-MAS assets to discuss the 

work required to determine if they are a MAS or if they need to be reclassified in another asset category. 

Steps will need to be taken to decide on the appropriate asset category for these resources, including a 

visit to the asset by an archeologist and a facility staff member to document it. If the asset is determined 

to be a MAS, a site record in the ASMIS must be created. The MAS asset record in FMSS must be updated and the MAS equipment specification templates must be entered in FMSS. If the asset is determined 

to be another asset type, the necessary steps must be taken in FMSS to reclassify it appropriately. It is also 

possible that the field visit could result in a determination by park staff to remove the asset from FMSS, 

following the established protocols on asset disposition. 

To Learn More about MAS and FMSS:

The MASWG and NPS Archeology Program have a webpage on InsideNPS for information about developments of the MAS-FMSS procedures. The MAS Business Practices are posted on the site at: 

http://inside.nps.gov/waso/custommenu.cfm?lv=3&prg=279&id=4943 

If there are questions about the MAS Business Practices or other aspects of the MAS asset type in FMSS, 

contact:

Terry Childs, in the Archeology Program, Washington Office (WASO), (202) 354-2125 or 

Gayle Burgess, in the Park Facility Management Division, WASO, (970) 641-2774 

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150 Safety Program

APPENDIX O

Safety Program

A complete Safety Program for any project is available on line at:

InsideNPS>Regions>Intermountain Region>ARD Park Operations – Facility Management, Design and Engineering> Historic Preservation

http://inside.nps.gov/regions/custommenu.cfm?lv=3&rgn=1013&id=5622

This Program originates from the Historic Preservation Training Center of the National Park 

Service in Frederick Maryland and was adapted by the Historic Preservation Projects Program 

within the Facility Management Division of the Intermountain Region.

Table of Contents for Safety Program

INTRODUCTION ......................................................................................................................................................1

HPP SAFETY POLICY ...............................................................................................................................................1

BACKGROUND...........................................................................................................................................................1

SAFETY PROGRAM...................................................................................................................................................3

PURPOSE AND AUDIENCE....................................................................................................................................3

I. CREW.....................................................................................................................................................................3

II. PROJECT LEADERS ..........................................................................................................................................4

III. PROJECT SUPERVISOR..................................................................................................................................4

IV. MANAGEMENT................................................................................................................................................5

V. SAFETY MANAGER...........................................................................................................................................5

VI. TRAINING MANAGER...................................................................................................................................5

ACCIDENT PREVENTION......................................................................................................................................6

I. DEFINITIONS......................................................................................................................................................6

II. PROJECT HAZARD ANALYSIS.......................................................................................................................7

III. PROJECT SAFETY PLANS/SAFETY MODULES.......................................................................................8

IV. LESSONS LEARNED........................................................................................................................................8

V. EMPLOYEE TRAINING AND AWARENESS................................................................................................8

VI. INSPECTION AND COMPLIANCE.............................................................................................................8

VII. ENCOUNTERS WITH HAZARDOUS SITUATIONS..............................................................................8

IX. PROVIDE EMPLOYEES WITH COMFORTABLE PPE ............................................................................9

INCIDENT RESPONSE AND ACCIDENT REPORTING..................................................................................9

I. DEFINITIONS ......................................................................................................................................................9

II. ROLES & RESPONSIBILITIES.......................................................................................................................12

III. ACCIDENT /INCIDENT ANALYSIS...........................................................................................................14

IV. MEDICAL MONITORING............................................................................................................................15

FACILITY SAFETY PLAN.......................................................................................................................................16

PROJECT SAFETY PLANS......................................................................................................................................18

I. PROJECT HAZARD ANALYSIS ......................................................................................................................18
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II. PROJECT SAFETY PLANS .............................................................................................................................18

III. LESSONS LEARNED-NEAR MISSES/ACCIDENT/INCIDENT ANALYSES.....................................19

IV. CERTIFICATION OF COMPLETION ........................................................................................................19

V. EMPLOYEE TRAINING AND AWARENESS..............................................................................................20

VI. INSPECTION AND COMPLIANCE...........................................................................................................20

VII. CERTIFICATE OF COMPLETION............................................................................................................21

VIII. COMPETENT PERSON DESIGNATION...............................................................................................21

IX. PROJECT HAZARD ANALYSIS QUESTIONNAIRE...............................................................................21

PROJECT SAFETY PLAN TEMPLATE.................................................................................................................22

SAFETY MODULES.................................................................................................................................................30

ASBESTOS EXPOSURE PLAN...............................................................................................................................31

CHAINSAW SAFETY PLAN...................................................................................................................................34

COMPRESSED GAS/WELDING AND SOLDERING SAFETY PLAN ..........................................................36

CONFINED SPACE SAFETY PLAN......................................................................................................................38

CRANE, HOIST AND AERIAL LIFT SAFETY PLAN........................................................................................40

ELECTRICAL SAFETY PLAN................................................................................................................................42

EXTREME WEATHER SAFETY PLAN ...............................................................................................................44

FALL PROTECTION PLAN....................................................................................................................................46

FIRE EXTINGUISHER PLAN................................................................................................................................48

FIRST AID AND BLOOD BORNE PATHOGEN PLAN ....................................................................................50

GENERAL JOB SITE SAFETY PLAN....................................................................................................................53

GRINDER (HAND-HELD) SAFETY PLAN........................................................................................................55

GRINDER (STATIONARY) SAFETY PLAN ........................................................................................................57

HAND AND POWER TOOL SAFETY PLAN......................................................................................................60

HARD HAT SAFETY PLAN....................................................................................................................................62

HAZARD COMMUNICATION PLAN.................................................................................................................64

HAZARDOUS MATERIALS SURVEY PLAN......................................................................................................66

HEARING CONSERVATION PLAN.....................................................................................................................68

LABORATORY CHEMICAL HYGIENE PLAN ..................................................................................................71

LEAD EXPOSURE PLAN........................................................................................................................................73

LOCKOUT-TAGOUT SAFETY PLAN..................................................................................................................76

MACHINE GUARDING PLAN .............................................................................................................................79

MATERIALS HANDLING AND STORAGE PLAN ...........................................................................................81

MEDICAL MONITORING PLAN ........................................................................................................................84

METAL BRAKE SAFETY PLAN.............................................................................................................................87

NATURAL HAZARDS SAFETY PROGRAM.......................................................................................................88

OFFICE SAFETY AND ERGONOMICS PLAN ..................................................................................................89
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152 Safety Program

PERSONAL PROTECTIVE EQUIPMENT PLAN..............................................................................................91

RESPIRATORY PROTECTION PLAN..................................................................................................................93

ROADWAY SAFETY PLAN .....................................................................................................................................98

SAWMILL SAFETY PLAN ......................................................................................................................................99

SCAFFOLD SAFETY PLAN................................................................................................................................. 101

SILICATES SAFETY PLAN .................................................................................................................................. 103

SKID STEER LOADER SAFETY PLAN............................................................................................................. 106

STATIONARY POWER EQUIPMENT .............................................................................................................. 108

TRENCHING AND EXCAVATING PLAN ....................................................................................................... 109

VACCINATION PLAN.......................................................................................................................................... 111

VEHICLES AND DRIVING SAFETY PLAN.................................................................................................... 113

VISITOR AND SIGNAGE SAFETY PLAN ........................................................................................................ 117

REFERENCE MATERIALS.................................................................................................................................. 119

ACCIDENT/INCIDENT ANALYSIS REPORT (SAMPLE)......................................................................... 120

ASBESTOS CONTAINING MATERIALS – PARTIAL LIST....................................................................... 123

ASBESTOS CONTAINING MATERIAL SURVEY....................................................................................... 125

ASBESTOS MANAGEMENT PLAN (SAMPLE) .......................................................................................... 126

ASBESTOS POLICY ........................................................................................................................................... 128

CONFINED SPACES CHECKLIST................................................................................................................. 130

CRANE HAND SIGNALS................................................................................................................................. 131

CRANE SIGNAL PERSON TIPS...................................................................................................................... 133

FALL PROTECTION PLAN (SAMPLE) ........................................................................................................ 134

FIRE EXTINGUISHERS INSPECTION PROCEDURES ........................................................................... 146

FIRE EXTINGUISHER INSPECTION FORM............................................................................................. 147

FIRST AID KITS MINIMUM STANDARDS................................................................................................. 148

FIRST AID KIT CONTENTS ........................................................................................................................... 149

FLAMMABLE AND COMBUSTIBLE LIQUIDS CLASSIFICATION ...................................................... 150

FLAMMABLE AND HAZARDOUS MATERIAL STORAGE GUIDELINES.......................................... 151

HARD HAT POLICY.......................................................................................................................................... 152

HOUSEKEEPING GUIDELINES ................................................................................................................... 154

INCLEMENT WEATHER................................................................................................................................ 156

PPE CHOICES AND REQUIREMENTS........................................................................................................ 162

SAFETY HAZARD ALERT FORM.................................................................................................................. 165

SAFETY INSPECTION CHECKLIST............................................................................................................. 166

VACCINATION PARTICIPATION FORM .................................................................................................... 168
Preservation and Management Guidelines

153