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Historic preservation in the United States Air Force: exploring new frontiers

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Historic preservation in the United States Air Force: exploring new frontiers

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Content HISTORIC PRESERVATION IN THE UNITED STATES AIR FORCE:
EXPLORING NEW FRONTIERS
by
Osmar Humberto Alaniz
A Thesis Presented to the
FACULTY OF THE SCHOOL OF ARCHITECTURE
UNIVERSITY OF SOUTHERN CALIFORNIA
In Partial Fulfillment of the
Requirement for the Degree
MASTER OF HERITAGE CONSERVATION
August 2016
Copyright 2016 Osmar Humberto Alaniz
ii
!
Acknowledgements

Thanks Mom and Dad! My journey does not begin if not for my parents.

Thanks to the staff at USC School of Architecture, Heritage Conservation for seeing my
potential and understanding the benefit of giving a military veteran a chance at scholarship,
literally and figuratively.

Thanks to my extended family throughout southern California who made my transition to the
area much, much easier. Special thanks to my Tio Jack and Tia Mercedes for understanding the
importance of education and translating that to a welcoming home away from home.

Thanks to the members of my committee: Trudi Sandmeier, Director of the Heritage
Conservation Program, University of Southern California; Mary Ringhoff, Professor of Heritage
Conservation, University of Southern California; Stephanie Smith, Ph.D., 412Th TW Base
Historian, Edwards AFB, California; and a very special reader Vanessa Martinez. Without you
all my words would not have found the form they did.

Lastly, thanks to all those who helped create a unique academic environment in and outside of
the classroom – the Historic Preservation Office at Fort Sam Houston, Texas, and the students of
the Heritage Conservation program at USC. Finally, I would like to thank Tony Chapa and Chris
Wilson, at the Edwards AFB Base Historic Preservation Office, without them I would have not
been introduced to military preservation during the developmental stages of my thesis.

iii
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Table of Contents
Acknowledgement .................................................................................................................... ii
List of Figures ............................................................................................................................. iv
Abstract .......................................................................................................................................v
Introduction ............................................................................................................................... 1
Chapter 1: Federal Mandates ................................................................................................... 3
1.1 Federal Mandates .............................................................................................................. 3
1.2 Department of Defense Mandate: DoD Directive 4710.1 ......................................................... 9
1.3 Army Mandate: Army Regulation 220-4 ............................................................................ 12
1.4 Navy Mandate: SECNAVINST 4000.35A ............................................................................ 16
1.5 Air Force Mandate: Air Force Instruction 32-7065 ......................................................... 19
1.6 Anatomy of Military Cultural Resources Mandates ......................................................... 22
1.7 The Military’s Current Preservation System ...................................................................... 25
1.8 Numbers ........................................................................................................................... 35
1.9 Conclusion ........................................................................................................................ 38
Chapter 2: The Air Force’s Role in the DoD and Preservation .............................................. 39
2.1 Brief US Air Force History .................................................................................................. 39
2.2 Military Traditions ...........................................................................................................44
2.3 Military Cultural Resources Management Culture ...........................................................47
2.4 Historic Preservation Designations in the Air Force .......................................................... 50
2.5 Conclusion .......................................................................................................................58
Chapter 3: Edwards AFB: A Case Study .................................................................................. 59
3.1 Background of Edwards AFB ................................................................................................. 59
3.2 Areas of opportunity when establishing a preservation program ....................................... 67
3.3 Conclusion ............................................................................................................................ 73
Chapter 4: Recommendations ................................................................................................... 75
4.1 Administrative Change .......................................................................................................... 75
4.2 Conscious Multi-Skilled Military Preservation Units/Sections ........................................... 76
4.3 Foster a Heritage Conservation Culture ............................................................................ 77
4.4 Community Advocacy Projects and Programs ................................................................... 77
4.5 Air Force Wide Preservation Assessment Projects ............................................................. 78
5.6 Annual Military CRM Conferences ............................................................................... 78
5.7 Additional Recommendations ............. ........................................................................... 79
5.8 Recommendation Conclusion ............................................................................................. 79
Conclusion ................. ......................................................................................................... 80
Bibliography .............................................................................................................................. 83
Appendix A: Department of Defense Directive 4710.1 ......................................................... 91
Appendix B: Army Regulation 200-4 ................................................................................... 100
Appendix C: Secretary of Navy Instruction 4000.35A ........................................................ 121
Appendix D: Air Force Instruction 32-7065 ........................................................................ 139
iv
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List of Figures

Figure 1.1: Federal Outlays for FY 2014 5
Figure 1.2: General Sections, Cultural Resource Military Regulations 24
Figure 1.3: Actual Document Sections, Cultural Resources Military Regulations 25
Figure 1.4: Six Elements. Data from DoDI 4715.16 29
Figure 1.5: Six Elements. Data from DoDI 4715.16 31
Figure 1.6: The Specific Content of ICRMP as Directed by DoDI 4715.16 33
Figure 1.7: ICRMP Completion Status 36
Figure 1.8: DoD Distribution of 21,334 Historical Structures 36
Figure 1.9: Historical Structures “Not Yet Evaluated” 37
Figure 2.1: The Administration Building at Randolph AFB, Tx 52
Figure 2.2: Notre Dame in Chartres and Sainte-Chapelle in Paris 54
Figure 2.3: United States Air Force Academy Cadet Chapel 56
Figure 2.4: Roger’s Dry Lake 57
Figure 3.1: Captain Glen W. Edwards, the Namesake of Edwards AFB 61
Figure 3.2: Fence and Property Line at Edwards AFB 62
Figure 3.3: The Statue of Charles E. “Chuck” Yeager 66

v
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Abstract

The United States Air Force (USAF) is now at a mature age (sixty-eight at the time of this
writing)--a time when organizations commonly reflect on their heritage. This thesis explores the
practice of heritage conservation in the USAF through its federal mandates, history, and cultural
resources. Specifically, it contemplates how the USAF, with its federal preservation mandates,
supports a historic preservation program despite its culture of “newness.” Chapter One analyzes
the origin of preservation in the US military by examining military directives and probes the
viability of preservation in the US military through official reports and data. Chapter Two
examines the overarching history of the USAF as a member of the Department of Defense and
the context for which military traditions shape the overall cultural of the military. Chapter Three
of this thesis probes the historic preservation program at Edwards Air Force Base (AFB) and
details the local pitfalls in the cultural resource management program. Finally, Chapter Four
scrutinizes the thesis’ research and produces a series of recommendations for historic
preservation programs in the USAF and at Edwards AFB. Through critical analysis of military
historic preservation, we develop a context to evaluate how the USAF, with its federal
preservation mandates, can become a historic preservation conscious organization.

1
!!
Introduction

There is a new frontier for the United States Air Force (USAF) and it has little to do with new
aeronautics or space exploration; cultural heritage conservation is the new challenge for the
USAF. This thesis will guide you through the history and policy that supports a preservation-
conscious USAF.

Established in 1947, the USAF is the youngest service branch of the Department of Defense
(DoD). While the US Army, US Navy and US Marines have accumulated years of history and
acquired prestige, the USAF has championed its “newness” through the technology of flight.
This creates a unique dynamic when the USAF addresses preservation issues, as all service
branches of the DoD are required to do. Consequently, this thesis explores preservation issues
with the USAF because of it culture of newness.

The USAF is virtually an unexplored realm from a historic preservation perspective. Most
experienced preservationists have little experience in DoD historic preservation. This thesis
explores military historic preservation programs to provide a deeper understanding of where
further preservation principles can be applied and to highlight and educate the non-military
preservation community about the preservation opportunities in the DoD.

To date, most scholarly research about military preservation involves preserving cultural
resources of deactivated military sites or architects commissioned by the military to build
military structures (that later were deemed historically significant architecturally). However,
little, if any, actually is focused on active preservation programs.
1

This thesis will explore whether the USAF, with its federal preservation mandates, become an
exemplary historic preservation-conscious organization despite its forward-looking culture?
Analysis of the DoD, USAF, and Edwards AFB preservation programs painted a picture of the
current state of historic preservation in the USAF.
!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
1
NOTE: The following are three examples of theses in military preservation and the subject matter cited above:
Hartness, Gina. Re-Engaging Historic Military Sites. Master of Landscape Architecture, Clemson University, May
2
!!

Chapter One outlines the federal and DoD historic preservation mandates, and then details the
ramifications of the directives and all subsequent orders. This chapter establishes the apparent
viability of military preservation in all service branches of the DoD with supporting reports and
data.

Chapter Two introduces the USAF by examining its history, cultural uniqueness, and traditions.
The chapter goes on to demonstrate where historic preservation has already been practiced by
introducing some of the existing nationally registered USAF landmarks.

Chapter Three introduces the various cultural and historic resources found and associated with
Edwards AFB, and in doing so, shows how Edwards AFB is subject to some of the pitfalls
traditionally associated with USAF historic preservation. Edwards AFB played the role of a
preservation ready case study location. Further, the chapter provides evidence of the tremendous
heritage resources the base possesses, making it a fertile breeding ground for preservation.

Chapter Four concludes by providing a series of recommendations to be applied in the
application of historic preservation in the US military, USAF, and specifically at Edwards AFB.
This chapter contemplates the major findings of research and constructs a sequence of
recommendations for the USAF and Edwards AFB in its endeavor to manage its historic
resources. The result and underlying implication of this thesis is that federal mandates and
military traditions can co-exist to result in a cultural historic preservation conscious USAF.

3
!!
Chapter 1: Federal Mandates

1.1 Federal Mandates
The DoD oversees our nation’s military service branches. The US Constitution is the
fundamental source of the military service branches. For example, Congress created the US
Army when it deemed, “The Congress shall have Power To...To raise and support Armies, but no
Appropriation of Money to that Use shall be for a longer Term than two Years...”
2

Correspondingly, Congress created the US Navy in the same Constitutional Article, “To provide
and maintain a Navy...”
3
Just as these constitutional articles established two of our nation’s
military service branches, such service branches are subject to laws and regulations. Thus, the
evolution of our nation’s military service branches is a result of federal mandates.

The Cultural Resources program within the US military is no exception. When Congress passed
the National Historic Preservation Act (NHPA) in 1966, the US Armed Forces were ordered into
action.
4

NHPA
The federal government has been involved in conservation since the early twentieth century. The
federal government’s first significant action in conservation occurred with the passage of the
Antiquities Act of 1906.
5
Other preservation legislation followed, culminating with the NHPA of
1966. The NHPA was not merely the result of previous preservation actions - it was the United
States’ codification of historic preservation and, ultimately, the creation of the nation’s primary
heritage preservation law.
6

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2
U.S. Constitution, art. 1, sec. 8, cl. 12.
3
U.S. Constitution, art. 1, sec. 8, cl. 13.
4
NOTE: There are five service branches of service in the US military. Theses five service branches are the US
Army, US Navy, US Marines, US Coast Guard, and US Air Force. They all have individual perseveration
approaches, however for the purpose of this thesis only the three largest service branches (US Army, US Navy, and
US Air Force) will be examined.
5
Charlotte R. Bell, Federal Historic Preservation Case Law: A Special Report, Advisory Council on Historic
Preservation, Washington D.C., (1985), 6.
6
Ibid.
4
!!
The NHPA originated as Senate Bill 3035 and President Lyndon B. Johnson subsequently signed
it into law on October 15, 1966. The Act was an answer to the concerns underlying rampant
national construction and development.
7
This law established the federal government as a leader
in preservation and more importantly, confirmed the role of federal agencies and governments in
necessitating evaluation of the impact of all federally funded or sanctioned projects on historic
properties. The Bill’s introduction of the concept of an undertaking is what ties federal agencies
to this law. A federal undertaking is a “project, activity, or program 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...”
8
Therefore, this concept subjects any organization to the
requirements of this law when it requires federal financial assistance, permit, license, and or
approval.

The Bill also authorized the creation of the Advisory Council on Historic Preservation (ACHP),
now a cabinet level body. Further, the legislation also created the governor appointed State
Historic Preservation Office (SHPO), which establishes a preservation authority in every state.
The law also paved the way for the creation of the National Register of Historic Places and
National Historic Landmarks Program, administered by the National Parks Service (NPS).
Consequently, this structure established an answering authority for the DoD outside the US
military establishment.

Significance of NHPA Section 106
Section 106 process is administered by the Advisory Council on Historic Preservation. Section
106 was included in the NHPA to incorporate historic preservation values into project planning
through consultation among federal agencies. Most importantly, Section 106 provided
preservation a legal basis by mandating that federal agencies “take into account the effect of the
undertaking” and how it relates to historic properties.
9
Section 106 also recognizes the
importance of participation by various entities in the consultation process.

!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
7
Preservation50, The National Historic Preservation Act, http://preservation50.org/about/nhpa-history/, accessed on
July 24, 2014, 1.
8
National Historic Preservation Act of 1966, as amended, Public Law 89-665; U.S.C. § 470 et seq., Title II, Sec.
301, (7), (1966).
9
NHPA, sec. 106.
5
!!
The Section 106 process is summarized through four basic steps. First, federal agencies must
consult with other appropriate agencies when planning an undertaking. Second, federal agencies
must identify properties that maybe affected by undertakings. Third, federal agencies must assess
the effects of an undertaking, if any. Finally, federal agencies must resolve adverse effects of an
undertaking, if any, through alternatives or mitigation.
10
36 CFR Part 800 explains and defines
the Section 106 process in detail.

The requirements of Section 106 on federal agencies, and their subsequent undertakings, are of
particular significance because the federal government funds the US military in its entirety. In
2014, the US Government earmarked an estimated twenty-two percent ($830 Billion) of the
federal budget to the DoD, third only to Health Care and Pensions at twenty-six percent and
twenty-three percent, respectively (See Figure 1.1).
11
This is significant because it directly
connects all military building activities to the definition of a “federal undertaking.” The US
military system of building construction, by its very nature, is a “federal undertaking.”

Figure 1.1: Federal Outlays for FY 2014. The appropriations for Defense totaled $830 Billion. Source: Data and
figure courtesy of www.usgovernmentspending.com, FY14 Federal Government Spending Estimates.
!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
10
Advisory Council on Historic Preservation, A Citizen’s Guide to Section 10 Review, Washington DC,
http://www.achp.gov/docs/CitizenGuide.pdf, accessed on May 5, 2014, 5.
11
Federal Budget, FY14 Federal Government Spending Estimates, www.usgovernmentspending.com, accessed on
August 15, 2014, 1.
6
!!
Each US service branch (Army, Navy, and Air Force) has defined its view of a “federal
undertaking.” Each of these interpretations is fundamental to how the entire DoD views the
NHPA. The DoD defines an “undertaking” as:
…any Federal, federally assisted, or federally licensed action, activity, or
program, or support of any non-Federal action, activity, or program, including
both new and continuing projects and activities.
12

While, the Department of the Army defines an “undertaking” as:

…any project, activity, or program that can result in changes in the character
or use of historic properties as defined by the NHPA. The project, activity or
program must be under the direct or indirect jurisdiction of the installation
commander. Undertakings include new and continuing projects, activities, or
programs and any of their elements not previously considered under Section
106 of the NHPA.
13

Moreover, the Department of the Navy defines an “undertaking” as:

…any project, activity, or program 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 under a delegation or approval
by a federal agency.
14

Finally, the Department of the Air Force defines an “undertaking” as:

…any project, activity, action, or program wholly or partly funded under the
direct or indirect jurisdiction of a Federal agency. Includes projects and
activities that are executed by or on behalf of a Federal agency; Federally
funded; require a Federal permit, license or approval; or are subject to State or
!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
12
US Department of Defense, DoD Directive 4710.1: Archeological and Historic Resources Management,
(Washington, DC: Department of Defense, 1984), 3.
13
US Department of the Army, Army Regulation 200-4: Cultural Resources Management, (Washington, DC:
Department of the Army, 1998), 11.
14
US Department of the Navy, Secretary of the Navy Instruction 4000.35A: Department of the Navy Cultural
Resources Program, (Washington, DC: Department of the Navy, 2001), 4.
7
!!
local regulation administered through delegation or approval authority by a
Federal agency.
15

Each military branch’s definitions set forth the conditions and requirements related to
preservation within the DoD establishment. The DoD interpretation of an “undertaking” is the
broadest of all interpretations. This top-down method is how regulations in the US military are
constructed. The lower levels of the military can make the regulations more restrictive but not
less. The Army definition imposes more restriction or limitation by introducing the authority of
an army installation commander. The Navy introduces emphasis on legal status of permit and
license for proceeding with work when defining and undertaking. Lastly, the Air Force
introduces the role of state and local bodies involved in undertakings. These varied
interpretations of the concept of a federal “undertaking” illustrate the dynamics of the military
preservation program across all the service branches. The idea of undertaking actually is two
pronged. On the front end the federal money to build ties the service branch to the
responsibilities of NHPA and the Section 106 process. Then later in life cycle when another
undertaking naturally occurs to a building the Section 106 process is a required activity in the
long process of committing funds to a building action (renovation or demolition). Without, the
Section 106 process occurring the activity cannot be cleared for action and thus delay results
increasing the possibility of the branch service losing the obligation of funds.

Executive Order 11593
The requirements imposed by the NHPA made it difficult for most federal agencies to comply
because the scope of the Act was so broad. In response to this expansive scope, modifications
provided clarification in the form of executive orders and or amendments. Executive Order (EO)
11593 of 1971 was the first supplement to clarify the role of the federal government with respect
to preservation.
16
Specifically, EO 11593 placed federal organizations on notice of their
responsibilities with in connection cultural resources under their charge. This meant federal
entities had to now account for all historic properties in their inventory.
!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
15
US Department of the Air Force, Air Force Instruction 32-7065: Cultural Resources Management Program,
Washington, DC, 2004, 35.
16
Executive Order 11593 of May 13, 1971, Protection and Enhancement of the Cultural Environment, Code of
Federal Regulations, title 3 (1971), http://www.archives.gov/federal-register/codification/executive-
order/11593.html, accessed on July 20, 2014, 559.
8
!!

Section 110
In 1980, the depth of enforcement under NHPA grew. In an effort to further codify the
responsibility of federal agencies, Section 110 imposed additional requirements on cultural
resources programs. For example, Section 110 requires federal agencies to create historic
preservation programs, designate a historic preservation officer, create an award program, and
provide a process for nominating properties to the National Register.
17
As a section in the
NHPA, these provisions are a legal mandate for the DoD.

NHPA Amendments confirm EO 11593
Section 110 retroactively modified the NHPA through EO 11593’s inclusion of language
allowing subsequent amendments to the NHPA. As a result, the federal government established a
firm baseline for the execution of historic preservation programs by federal agencies. The
question that remained, however, was how the individual federal agencies would apply these
laws and mandates to their respective organizations.

These progressive series of legislative events are important when understanding the gradual
strengthening of preservation law in our country and thus federal and military historic
preservation programs. Preservation evolved from a statute that allowed for the federal
government (federal agencies) to serve as leaders of preserving our nation’s historic resources.
Subsequent federal mandates helped clarify the military's responsibility for historic preservation.
It is no surprise these responsibilities now play a significant role in the day-to-day activities of
federal agencies such as the DoD. Of the numerous federal agencies, this is an opportune time
for the DoD and its three primary sub-departments (Army, Navy, and Air Force) to actively
pursue and attain the historic preservation goals set forth by the NHPA. To this end, the DoD
established DoD Directive 4710.1, Archeological and Historical Resource Management, in June
1984.

!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
17
Advisory Council on Historic Preservation, Federal Historic Preservation Case Law: 1966-1996,
http://www.achp.gov/book/sectionII.html, accessed on July 10, 2014, 1.
9
!!
1.2 Department of Defense Mandate: DoD Directive 4710.1
All discussion of the DoD Directive 4710.1, Archeological and Historical Resource
Management, is derived directly from the language of the directive issued on 21 June 1984 and
found in Appendix A.
18

Introduction
DoD Directive 4710.1 was a result of the passing of the NHPA of 1966 and all subsequent
legislation. This directive gives clear direction on the military’s Cultural Resource Management
(CRM) program.

It took the US military establishment a considerable amount of time before taking preservation
action, almost eighteen years from the initial passing of the NHPA. The 1970s saw affirmation
with: EO 11593, Protection and Enhancement of the Cultural Environment (1971); Amendment
to the NHPA (1972); the Archeological and Historic Preservation Act (1974); the American
Indian Religious Freedom Act (1978); and the Archaeological Resources Protection Act (1979).
The wave of preservation legislation resulted in not only a DoD response in 1984, but resulted in
the US Army producing its first preservation regulation (US Army Regulation 420-40, Historic
Preservation) in that same year.
19

Before the 1960s and 1970s, preservation in the military was almost nonexistent. Preservation in
the military equated to a National Parks Service (NPS) nomination of a historic site once used by
the military. An example of this type of preservation can be seen in the establishment of Fort
Davis as a national historic site. Fort Davis is a closed Army post in west Texas. In this instance,
the designation came as a result of an act authorizing a national historic site at Fort Davis.
20
In
the act, it directed the Secretary of the Interior to acquire Fort Davis, for an allocated nominal
!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
18
US Department of Defense, DoD Directive 4710.1: Archeological and Historic Resources Management,
Washington, DC, 1984.
19
Note: Army Regulation 200-4, Cultural Resource Management, advanced the awareness of Army Regulation 420-
40, Historic Preservation, by developing a cultural resources management program in 1998 to fall in line with DoD
Directive 4710, similar to the Air Force and Navy cultural resource program. However, Army Regulation 420-40
established preservation awareness for the Army in 1984.
20
!Jerome A. Greene, Historic Resource Study Fort Davis National Historic Site, Folio F 394.F63G74, U.S.
Department of the Interior, National Park Service, November 1986, p. 381. APPENDIX J (excerpt from): Hillary A.
Tolson, Authorization Act Establishing Fort Davis National Historic Site, September 8, 1961, Laws Relating to the
National Park Service. Supplement II. Washington: Government Printing Office, (1963), 346.!
10
!
amount, and an admonition to deem it as a national historic site.
21
However, the actions taken
here were more in line with the goals of the NPS and not for preservation as we currently view it.
DoD Directive 4710 changed the way military historic sites were viewed by the military
establishment in that they began seeking historic resources at each military site.

Responsibilities
DoD Directive 4710 outlined preservation responsibilities throughout the military hierarchy.
Preservation responsibility begins at the Pentagon with the Assistant Secretary of Defense
(Manpower, Installations, and Logistics). As the primary preservation officer, the Assistant
Secretary develops policy for the DoD cultural resource program. Further, the Secretary
coordinates programs throughout the US military establishment. Lastly, the Secretary is to assign
responsibility in the case where two or more DoD Components are involved in an undertaking.
The phrase DoD Components used by this directive is another term for service branches.

After assigning primary responsibility to the Assistant Secretary, the directive charges the
leadership of the “Heads of DoD Components” with responsibility for preservation within their
respective organizations. This group includes the “Secretary of Defense, the Military
Departments (including their National Guard Reserve components), the Organization of the Joint
Chiefs of Staff, and the Defense Agencies.” These military leaders are to comply with directives,
communicate and cooperate with official preservation entities (such as the Advisory Council on
Historic Preservation, SHPO, and the public), designate an official Cultural Resource Manager
(CRM) for their component, integrate preservation into land use and planning activities, and
develop programs and manage budgets for preservation programs.

Lastly, the directive addresses the secretaries of Military departments (civilians appointed by the
President of the United States) who direct the main military service branches of the US Army,
US Navy and Marines, and USAF.
22
It directs the implementation of preservation programs by
providing appropriate resources, technical assistance, and qualified staff. With those in place, it
!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
21
!Ibid.!
22
Note: The Coast Guard was acknowledged in this Directive, however in the interest of time and brevity, the scope
of this paper was limited to the preservation programs of the Air Force, Army and Navy. The Marines are officially
under the Navy and thus receive their direction from the Navy leadership and procedures.
11
!
establishes a preservation award program, directs communication with the Department of Interior
concerning site nominations and listing on the National Register, and fulfills the permit process
regarding archeological endeavors resulting in the excavation and or removal of resources.

Requirements/Procedures
The directive requires each installation (individual military bases) to identify historically
significant properties and to inventory and evaluate when appropriate. The directive describes
the strategy for complying with preservation laws by working with local, state, and federal
preservation representatives. As a general rule all DoD representatives are required to work with
SHPO and the Advisory Council when dealing with undertakings involving a resource not yet
evaluated or eligible for inclusion to the National Register. Moreover, DoD installations are to
locate, inventory and nominate cultural resource properties found in their area of responsibility
as well as protect these resources whenever possible.
23
A Memorandum of Agreement (MOA) is
encouraged whenever resources or installations are involved in the Section 106 Process. An
MOA is a document between various groups or parties to cooperatively work together on a
project or objective.
24
In this instance the agreement would be between the Department of
Defense (or its service branches) and the State Historic Preservation Office or Department of
Secretary of the Interior. Lastly, when taking action on a historic resource, DoD installations
should provide plans to the SHPO as well as provide the ACHP in advance to allow for review of
project plans.

Resultant action from DoD Directive 4710.1
DoD Directive 4710 directed the military services to create a regulation or instruction to address
their new responsibility for cultural resources. DoD Directive 4710.1 orders each military
service, such as the Department of the Army, the Department of the Navy, and a Department of
the Air Force to designate and officially to nominate resources to the National Register of
Historic Places. The DoD provides for annual and fiscal requirements for identification and
evaluation of historic resources when such resources require an undertaking. As per policy, the
!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
23
Note: Military cultural resources are well represented on the National Register. The Department of Defense
Directive does not give mandates on the number of historic properties to be identified. Thus, the identification of
one historic property to the National Register per installation fulfills the nation register mandate of the directive.
24
Bryan A. Garner, A Dictionary of Modern Legal Usage, (New York: Oxford University Press, 2001), 726. !
12
!
DoD developed Department of Defense Instruction 4715.16 to supplement this directive
(DoDDir 4710.1) with detailed instructions. The latest version of this cultural resource
instruction is dated September 18, 2008.

It is the statutory obligation of the federal agency to fulfill the requirements of Section 106 and
to ensure that an agency official with jurisdiction over an undertaking takes legal and financial
responsibility for Section 106 compliance in accordance with subpart B of this part. The agency
official has approval authority for the undertaking and can commit the federal agency to take
appropriate action related to the specific undertaking as a result of Section 106 compliance. The
agency official may be a State, local, or tribal government official who has been delegated legal
responsibility for compliance with section 106 in accordance with Federal law.
25

1.3 Army Mandate: Army Regulation 200-4
All discussion of the Army Regulation (AR) 200-4, Environmental Quality—Cultural Resources
Management, is derived directly from the language of the regulation issued on 1 October 1998
and found in Appendix B.
26
This is the latest edition of this regulation; the AR 420-40 (issued on
April 15, 1984), could not be sourced.

Introduction
The U.S. Army initiated its CRM program through the creation of AR 420-40 in 1984. Normally
a DoD Directive would come first. However, this did not occur in this instance. Fourteen years
later, in 1998, the Army had to replace its initial regulation with one that more closely followed
the DoD Directive and advances in preservation.

AR 200-4 begins by showing its legal precedents with the NHPA. Then under Applicability it
gives numerous definitions indicative of cultural resources. The Army goes on to define the
military leader with overall responsibility of this regulation and program. The regulation then
provides guidance, through purpose and method, to how it was to meet compliances and
!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
25
36 C.F.R. S 800.2(a).
26
US Department of the Army, Army Regulation 200-4: Cultural Resources Management, Washington, DC, 1998.!
13
!
requirements.

Responsibilities
In traditional military fashion, designated authority is delegated to subordinates in the leadership
command structure. In the Army, the Secretary of the Army is the officially designated Federal
Preservation Officer (FPO).The Secretary of the Army delegates that authority to the Assistant
Secretary of the Army (Installation, Logistics, and Environment). The Assistant Secretary then
designates the Deputy Assistant Secretary of the Army with oversight of Environment, Safety,
and Occupational Health as the FPO, responsible for preservation within the Army.

The next level of command management within the Army is the Assistant Chief of Staff for
installation management. This position is the proponent of CRM programs, and oversees two
main positions. The two positions under this position’s command are: the Director of
Environmental Programs and the Commander U.S. Army Environmental Center. The Director of
Environmental Programs promulgates preservation by policy and guidance. The Commander of
U.S. Army Environmental Center provides more technical support and preservation activities.
The subsequent level of responsibilities falls upon the major Army Command Commanders.
These are a series of twenty-four organizations within the Army structure that range in
responsibility in general location (such as US Army Europe or Pacific) to responsibility in
specific disciplines (such as US Army Medical Command). The commanders in turn are the
officers commanding these various major Army Commands.
27

Within the major Army Commands are the individual Army installations. Positions called
installation commander’s lead these Army installations. The installation commander is the
highest-ranking military member at each military location and is charged with fulfilling the
mission. Each military installation is charged with a specific and unique mission.
28
It is the
installation commander that designates the installation’s CRM manager.

!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
27
“Organization: US Army Command Structure,” http://www.army.mil/info/organization/unitsandcommands/
commandstructure, accessed on May 5, 2014.
28
Note: The term installation can take many forms. The Army calls their installations Posts. The Air Force and
Navy calls their installations Bases. The Marines generally calls their installations Camps.
14
!
Functional preservation activities take place at the installation level. The position that performs
the functional preservation activities at each installation is the CRM manager. The CRM
manager establishes relationships with appropriate preservation groups, prepares and implements
Programmatic Agreements (PAs), establishes funding priorities, acts as government agency
official when needed, and various other command level preservation responsibilities. A PA is a
legal document that spells out the specific terms of formal and legally binding agreement.
29

Similar to the MOA, a PA in this instance would be between the Department of Defense (or its
service branches) and the State Historic Preservation Office or Department of Secretary of the
Interior.

Requirements
The Army regulation (AR 200-4) outlines the complete spectrum of cultural resources
compliance requirements by providing, as a reference, all of the applicable acts, laws, and
executive orders relating to preservation. This is done to give clear guidelines for effectuating a
healthy CRM program. The regulation first lists the National Environmental Policy Act (NEPA)
of 1969, as amended, to ensure environmental considerations are recognized when performing
preservation activities. Next the regulation describes the NHPA, the federal government's most
fundamental regulation on archaeology and historic preservation.

The Army regulation’s discussion of NHPA Section 106 explains the overarching process for
which the federal agency takes into account the effects of all undertakings on historic properties.
The Army emphasizes the importance of establishing a relationship with the Advisory Council
on Historic preservation and the SHPO to achieve the goals outlined in Army regulation, AR
200-4. Further, in the Army regulation denotes the proper use of the Secretary of Interior
Standards and Guidelines for archaeology and historic preservation and the use of MOA and PA
as tools when planning the method for achieving historic preservation goals.

The Army regulation’s discussion related to Section 110 requires the installation commander to
establish preservation programs that identify, evaluate, and nominate historic properties. It goes
on to further standardize requirements for construction and acquiring or leasing buildings in line
!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
29
Bryan A. Garner, A Dictionary of Modern Legal Usage, (New York: Oxford University Press, 2001), 802.
15
!
with the requirements of the Secretary of Interior. This instruction mandates specific
documentation of historic properties that will be altered or destroyed.

Section 111 mandates the installation commander to establish and develop or install alternatives
for historic properties such as adaptive reuse. Section 112 requires that the installation
commander oversee activities of third parties such as outside employees or contractors that
undertake actions that involve historic properties.

The Army regulation next turns its focus on actions involving Native Americans. The regulation
cites The Native American Graves Protection and Repatriation Act (NAGPRA) of 1990. This
legislation requires the installation commander to summarize and document the assets of cultural
significance under his/her charge. This includes repatriation of cultural items found significant to
establish original owners. After the NAGPRA, the regulation introduces the Antiquities Act of
1906, Archaeological Resources Protection Act (ARPA) of 1979, and Archaeological and
Historical Preservation Act of 1974. Collectedly, these three Acts were established in an effort to
establish the predecessors and original owners of cultural resources.

Tools
In the Section 106 process, PAs and MOAs are most readily uses to fulfill preservation goals.
The use of these tools (PAs and MOAs) requires a distinct set of principles and procedures for
which to be followed to achieve success with Section 106 goals. Next, the Army regulation
describes the procedure for signing ratified PAs or MOAs. Another procedure covers when the
commander wishes to terminate Section 106 consultation. This is where there is no PA or MOA
in place and the commander still wishes to proceed with an undertaking that adversely affects a
historic property. Finally, the section in the Army regulation covering tools outlines the
procedures for when an installation is designated for closure under the Base Realignment and
Closure (BRAC) program. Finally, when preservation assets are under consideration for transfer
to public entities, BRAC procedures will take precedence.

Next the Army regulation discusses the process for listing on the National Register of Historic
Places and how determinations and eligibility nominations are completed. The first requirement
16
!
under this section is for major Army Command commanders to establish a process for reviewing
the determination of eligibility. Next it explains the details for when leadership disagrees with
the National Register eligibility. This is followed by the procedures for formal listing on the
National Register of Historic Places. Last are the procedures for removing historic properties
from the National Register, if the need should arise.

Plans
The final part of Army regulation 200–4, outlines the use (to include the scope purpose and
content) of and Integrated Cultural Resources Management Plan (ICRMP). ICRMPs are five-
year plans that outline methods for complying with the requirements. An ICRMP is normally
produced for a single installation. In turn, the ICRMP functions as a vital entity in the
installation’s overall master plan. In all, Army regulation 200–4 sets the stage by establishing
requirements and responsibilities that commanders must meet.

1.4 Navy Mandate: SECNAVINST 4000.35A
All discussion of the Secretary of the Navy Instruction (SECNAVINST) 4000.35A, Department
of the Navy Cultural Resources Program, derives from the language of the latest regulation
issued on 1 October 1998 and can be found in Appendix C.
30
The SECNAVINST 4000.35,
published in 1992, is the Navy’s original instruction on cultural resources, and could not be
sourced.

Introduction
The Department of the Navy’s (DON) preservation instruction takes a different path to fulfill the
requirements of preservation. The Secretary of the Navy Instruction 4000.35, abbreviated as
SECNAVINST 4000.35A, is the Department of the Navy’s Cultural Resources Program. This
instruction also applies to the United States Marine Corps as the US Marines fall under the DON
!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
30
US Department of the Navy, Secretary of the Navy Instruction 4000.35A: Department of the Navy Cultural
Resources Program, Washington, DC, 2001.
17
!
and is subject to the DON’s directive.
31
The instruction assigns responsibility and develops a
policy for fulfilling preservation requirements. Next the instruction identifies the scope of
compliance. It directs preservation responsibility to the components of the DON. The Navy
instruction then provides definitions so as to aid in the different language vernacular of the
NHPA and the US military.

SECNAVINST 4000.35A’s discussion entitled Policy recognizes the control of buildings and
structures, districts, archaeological sites, artifacts ships, and other resources. Further, it directs
consultation with the appropriate groups and offices when taking action on preservation assets.
In an effort to develop a fully accountable program, the DON is responsible for developing and
inventories of all historic resources. Qualified archaeological personnel must utilize proper
techniques when accomplishing undertakings within the Navy.

Responsibilities, Requirements, Plans, and Tools
The Assistant Secretary of the Navy (Installations and Environment) provides overall policy
directives and serves as the main proponent of CRM for the Navy and Marine Corps. This
position is also called Navy Federal Preservation Officer (FPO). The Navy FPO is the central
figure in Navy preservation and to ensure the Navy remains compliant in its proper training and
procedures related to preservation of cultural resources. Thus, the position is required to liaise
with all proper authorities, organizations, groups and federal agencies. The Navy FPO possesses
final signature authority for items to be placed on the National Register and for approval of the
various ICRMPs. Lastly, the Navy FPO serves as the federal land manager of Navy assets and
can designate the historic value of all assets or resources belonging to the Navy.

The Chief of Naval Operations (CNO) and Commandant of the Marine Corps (CMC) hold the
responsibility for compliance and policy requirements of cultural resource preservation in their
respective area of responsibility. These two positions are charged with providing the proper
personnel, funding, and training to enhance preservation resources. Their purpose is also to
ensure that installation plans comply with regulations on historic resources. Lastly, they have the
!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
31
William S. Dudley, Dr., “Statement of Dr. William S. Dudley Director of Naval History Before the House Armed
Services Committee on the Secretary of the Navy and Marine Corps 18 March 2004,”
http://www.navy.mil/navydata/testimony/history/dudley040318.txt, accessed on July 20, 2014.
18
!
authority to enter into cooperative agreements with groups such as the SHPO to properly
administer archaeological assets.

The specific Commanders of Navy and Marine major units are the primary technical advisors for
the DON and are responsible for it cultural resource program compliance. They provide technical
advice to installation commanders in data management and reporting as well as sit on the Navy’s
historic preservation board. The general counsel and Judge Advocate General provide legal
advice on historic preservation issues when needed.

Commanders and commanding officers responsible for cultural resources are charged with cost-
effective stewardship of cultural resources in their area of responsibility. The commanders and
commanding officers are responsible to meet compliance requirements by preparing,
maintaining, and executing preservation plans with budgetary allowances. Lastly, they are able
to issue archaeological permits for resources they command.

Navy CRMs should be proper stewards of all cultural resources in accordance with Section 110
of the NHPA and Navy policies. They prepare installation specific plans consistent with
professional standards when undertaking a federal action. They should also provide timely inter-
agency consultation and technical guidance while maintaining cultural resource records of
historic resources that are on the National Register or are eligible for the National Register.

Delegation of Authority and Action
The Chief of Naval operations and Commandant of the Marine Corps have authority over
preservation activities, however they have the authority to delegate this responsibility to any
qualified personnel. The Navy has a robust cultural resource program in line with the direction
set by the Department of Defense. The DON is the second oldest branch of service and has
accumulated many historic resources over time.
32
Instructions such as the aforementioned can
prove to be beneficial to preserve its historic resources.

!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
32
Naval History and Heritage Command, “Establishment of the Navy: 13 October 1775,”
http://www.history.navy.mil/research/library/online-reading-room/title-list-alphabetically/e/establishment-of-the-
navy.html, accessed on February 5, 2015.
19
!
1.5 Air Force Mandate: Air Force Instruction 32-7065
All discussion of Air Force Instruction (AFI) 32-7065, Civil Engineering--Cultural Resources
Management Program, is derived directly from the language of the regulation issued on 1 June
2004 and found in Appendix D.
33

Introduction
The purpose of this instruction is to meet the legal requirements of the NHPA and subsequent
legislation. The goal of the instruction is to identify, manage and maintain historic resources so
as to “cultivate a culture of proper stewardship of cultural resources.” Historic preservation
within the USAF results from a number of preservation laws, legislation, and regulations.

Responsibilities
In the USAF, the responsibility for preservation ultimately lies with the Secretary of the Air
Force. The Secretary has overall responsibility of proper stewardship of the Air Force’s historic
resources. The Secretary delegates these preservation responsibilities to the Deputy Assistant
Secretary of the Air Force for Environment, Safety and Occupational Health (SAF/IEE). This
position is the Air Force’s FPO. The FPO’s responsibilities include compliance with policy and
nomination of sites to the National Register.

Below the Air Force FPO, responsibility for historic preservation falls upon the Civil Engineer
(CE). This position is the steward of the USAF cultural resource program and is responsible for,
ensuring compliance with programs and budget. The CE of the Air Force responds to
congressional inquiries and comments on proposed legislation. Lastly, the CE assesses the
effects of Air Force actions outside the US, particularly, so that the USAF does not adversely
affect them.

In the USAF there are generally three levels of authority (leadership). First, there is the Air Force
headquarters, which is based at the Pentagon in Virginia just across the Potomac from
Washington DC. Second, there are the major commands, which have their individual
!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
33
US Department of the Air Force, Air Force Instruction 32-7065: Cultural Resources Management Program,
Washington, DC, 2004.
20
!
headquarters throughout the United States. Third, there is the base level--found all across United
States and the world. Each base is directed by a major command and each major command
answers to their corresponding function at headquarters. The major commands are the next
position holding responsibility for cultural resources within the Air Force.

The USAF headquarters designates command CRMs with the qualifications required for such a
program. In turn, the command CRMs guides the installation CRMs in a method consistent to
achieving resource management goals. Consequently, the command CRM responsibilities
include providing technical support to ensure programs are executed properly. Specifically, the
major commands file the CRM plans for each individual base. In addition, the major commands
are to review the installation ICRMP, installation compliance agreement, National Register
nominations, and cultural resources funding requirements.

CRM plans are produced by each CRM program. These plans detail activities and roles for CRM
programs. Specifically, they cover: responsibility; inventory evaluation; individual installation
strategies for maintaining cultural resources; procedures for budgeting; staffing; scheduling of
activities for cultural resources activities; assessment of cultural resource activities (with
impact); and guidelines to meet with preservation laws and regulations at all levels.

The next level of responsibility falls on the base level Installation Commanders. The Installation
Commander approves and implements the installation CRM plan by consulting with federally
recognized groups and tribes under the regulations described in Section 106 of the NHPA.
Installation commanders have the responsibility to review their CRM programs by utilizing the
installation’s environmental protection committee. The environmental protection committee is a
professional committee charged with implementing and maintaining the requirements of NEPA.

The next level of responsibility falls upon the base CE or Environmental Directors at each
installation. The local level (installation) CE advises the Installation Commander on issues
regarding historic properties. The CE also serves as the federal agency official in activities
regarding historic properties. Lastly, the CE designates a qualified CRM manager for the
installation.
21
!

The last level of responsibility falls upon the installation’s CRM manager. The CRM manager
develops and implements the installation’s ICRMP. They are charged to locate, inventory and
evaluate, and recommend any historic properties to the National Register. They ensure all
proposed actions take place as planned in accordance with the regulations by monitoring the
work of contractors on the installation. The CRM coordinates with SHPOs and other
preservation officers, including tribal historic preservation officers, when appropriate. Lastly,
they maintain a cultural resource database for the installation in order to adequately account for
all cultural resources in the area.

Requirements
The installation CRM manager is charged with the protection of historic properties as outlined by
the Secretary of Interior standards and guidelines. When evaluating any cultural resources, the
CRM should work hand-in-hand with the SHPO to determine specific eligibility. All installations
should follow state and local guidelines for researching and reporting cultural resources.

The CRM evaluates all resources on an installation and determines eligibility for inclusion in the
National Register of Historic Places. Disagreements between the installation’s CRM office and
the SHPO on the eligibility of resources will be evaluated and determined by the National Park
Service (NPS). Where a resource is eligible for the National Register, the USAF is to give
priority to nominating the property to the NPS national listing. The major commands and SHPO
must coordinate nominations for proper review and documentation of the eligible natural and
cultural resources to the National Register.

Procedures
When actions by the USAF can have an effect on historic properties, the installation must follow
the Section 106 process of the NHPA. In this instance, the installation commander will evaluate
all cultural resources possibly affected by the undertaking. The installation commander must
follow procedures for compliance. Failure to do so will result in the historic properties held by
the USAF and Secretary of the Air Force falling under formal notification for foreclosure by the
Secretary of the Interior or other non-military federal body.
22
!
Communication is vital for success. To this point, consultation with State Historic Preservation
Office (SHPO), Tribal Historic Preservation Office (THPO), and the public provides an
opportunity for accomplishment of preservation goals. The evaluation should result in the
development of alternatives if results or actions are adverse effects. Most mitigation procedures
equate to a MOA or PA between the government entity and all involved parties. When
consultation does not lead to an adequate resolution, the installation commander may request the
Air Force FPO to terminate consultation and apply for final comment by the Advisory Council
on Historic Preservation. If the Air Force FPO approves this action, additional information may
be required to move forward.

Planning and design for military construction should take into account and give preference to
considering adaptive reuse of historic structures. The Air Force is to document the historic
buildings if the structures will be altered or destroyed. The installation commanders are also to
ensure historic properties are preserved when transferred to private parties.

Tools and Plans
The Air Force places importance on historic resource information. The Air Force requires that
cultural resource activities and the data produced from these activities be entered into the
installation’s cultural resources electronic files. These electronic files serve as a general tool for
tracking and maintaining information on cultural resources. Further, the USAF recommends
using the planning module (workforce information management system) for maintaining the
database of cultural resources.

Each Air Force installation must prepare an ICRMP in accordance with DoD Instruction 4715.3,
which should be ratified and or updated every five years. The CRM manager on the installation
is responsible to ensure the ICRMP guidelines are applied in a fashion accentuating the specific
needs and resources of the particular installation. The Air Force places high priority on qualified
personnel within CRM. Therefore, the CRM manager’s qualifications, training, certification, and
professional development are to be tailored to the individual installation by hiring and training
qualified individuals for the needs of the installation.

23
!
1.6 Anatomy of Military Cultural Resource Mandates
The DoD, Army, Navy, and Air Force branches all aspire to be responsible stewards of their
respective cultural resources. Each organization has published varying tools and processes for
which to conduct and achieve such goals.

Function Similarity
Each instruction, or regulation, differs in format and language. Sections differ in order yet all
covered three important aspects of maintaining an effective preservation program. The three legs
of CRM are: responsibility, requirements, and tools. All four documents contain three common
aspects, as Figure 1.2 demonstrates. Moreover, section concerning responsibility highlights the
importance of knowing who is charged with overall responsibility.

The term Requirements and Procedures are interchangeable in meaning when comparing the
service branches’ documents. The words requirements and procedures are used in the same
context despite the difference in terms. These functions (requirements and procedures) are
mainstays of the military culture. A Commander, at all levels, is primarily concerned with the
installation’s military mission and compliance with applicable requirements. While CRM may
not always be directly related to an installation’s military mission, it is always related to the
installation’s adherence to federal requirements and resulting compliance. Lastly, the tools
utilized in these documents are effectively best practices, or the recommended approach to
achieve the goals set forth in the requirements.

24
!

Figure 1.2: General Sections, Cultural Resource Military Regulations. Source: Made by Author.

Structure Difference
The structural differences of each instruction or regulation are the result of the cultural and
mission differences of each distinctive organization. The length of each document exemplifies
the culture and mission differences between these organizations. For example, the length of the
DoD directive is short, relative to the others. This is a result of the DoD being an organization
primarily concerned with policy. This results in the DoD’s directive being centered on primarily
laying out requirements, and not overly concerned with laying out how to comply with such
requirements.

Cultural Resource Military
Regulations
(General Sections)
Depart. of Defense
DoDD 4710.1
• Introduc)on*
• Responsibili)es*
• Requirements/
Procedures*
Depart. of Navy
SECNA VINST 4000.35A
• Introduc)on*
• Responsibili)es/
Requirements/*
*****Plans/*
*****Tools*
• Delega)on/Ac)on*
Depart. of Army
AR 200-4
• Introduc)on*
• Responsibili)es*
• Requirements*
• Tools*
• Plans*
Depart. of Air Force
AFI 32-7065
• Introduc)on*
• Responsibili)es*
• Requirements*
• Procedures*
• Tools/Plans*
• Quality*
25
!
Figure 1.3 outlines the particular sections of each individual document. This listing illustrates the
particular methods (by sections) used to reach the same goals in each document. When compared
to Figure 1.2, one can appreciate the differences and similarities within the dynamic US military
establishment.

Figure 1.3: Actual Document Sections, Cultural Resources Military Regulations. Source: Made by Author.

1.7 The Military’s Current Preservation System
The most vital component of the military’s CRM program is the CRM manager at each military
installation. These positions, and ultimate responsibilities, are the front line of preservation
within the military. All activities implemented to reduce adverse effects in preservation begin
Cultural Resource Military
Regulations
(Actual Document Sections)
Depart. of Defense
DoDD 4710.1
• Purpose(
• Applicability(and(
Scope(
• Defini6ons(
• Policy(
• Responsibili6es(
• Procedures(
• Effec6ve(Date(and(
Implementa6on(
Depart. of Navy
SECNA VINST 4000.35A
• Purpose(
• Cancella6on(
• Scope(
• Defini6ons(
• Policy(
• Responsibili6es(
• Delega6on(of(Authority(
• Ac6on(
(
Depart. of Army
AR 200-4
• Introduc6on(
• Cultural(Resources(
Compliance(
Requirements(
• NHPA(Sec6on(106(
PAs,(and(MOAs,(
Na6onal(Register(of(
Historic(Places,(
NAGPRA(CAs(and(
Plans(of(Ac6on,(
Coopera6ve(
Agreements(and(
Funding(
• Integrated(Cultural(
Resources(
Management(Plans(
(ICRMPs)(
(
Depart. of Air Force
AFI 32-7065
• How(To(Use(This(
Instruc6on(
• Inventory(
• Project(Review(
• General(
Management(
• DOD(Measures(of(
Merit(
26
!
here. This position ultimately ensures the well management of historic and cultural
archeological and architectural resources.

Cultural Resource Managers
Cultural resource managers are charged with implementing an installation’s CRM program.
Their responsibilities lay within the disciplines of archeology and historic preservation. The
military mandates illustrated above describe the overarching structure for which archeology and
historic preservation is to be conducted. Both systems of resource management are important to
the overall health of a CRM program.

The importance of archaeology is it connects us with our previous cultures. Archeology is a
branch of Anthropology. Anthropology is the study of humankind, including physical evolution,
social systems and material cultural.
34
In terms of definition, archaeology is the “scientific study
of the human past, of ancient human behavior, from the earliest times right up to the present.”
35

David Thomas, in his book, Archeology: An Introduction, describes archeology as “the study of
the human past.”
36
Continuing in his description of archeology he explains:

Archeology’s initial objective is the construction of cultural chronology; its
intermediate objective is the reconstruction of past lifeways; and its ultimate
objective is the discovery of the processes, which underlie and condition human
behavior.
37

Historic preservation, on the other hand, holds importance in preservation in that it recognizes
our current, or most historically recent, cultural aptitude. The United Kingdom’s English
Heritage defines historic preservation as “the process of managing change to a significant place
in its setting in ways that will sustain its heritage values, while recognizing opportunities to
reveal or reinforce those values for present and future generations.”
38
In the United States
historic preservation is defined, as “a commitment to conservation and celebration of the tangible
!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
34
Kevin Greene and Tom Moore, Archaeology: An Introduction, 5th Edition, (New York: Routledge, 2010), 313.
35
Brian M. Fagan, Archaeology: A Brief Introduction, 11ed, (Boston: Pearson, 2012), 4.
36
David Thomas. Archaeology, (New York: Holt, Rinehart and Winston, 1979), 456.
37
Ibid.
38
Paul Drury and Anna McPherson, English Heritage, Conservation Principles, Policies and Guidance: For the
Sustainable Management of the Historic Environment, (London: Vitesse, 2008), 71.
27
!
evidence of our past – is a major contributor to these intangible yet invaluable qualities.”
39

Further, it “is about nurturing the grass roots and assisting communities with the preservation of
physical structures, objective, and settings that tell the story of our collective experience.”
40

The importance of both archeology and historic preservation also can be seen at the State
Historic Preservation Office (SHPO) found in every state. The SHPO officer is the governor
appointed position in every state charged with the responsibility of the governance of all historic
resources within a state. This position and office is the center point in the overall federal historic
preservation program created by the National Historic Preservation Act of 1966.

In reviewing, three SHPOs from the state of California, New York, and Texas, it can be noted
that while all three are unique, all three maintain two specific functions: Archeology and
Architecture (built environment review). California has the function of Archeology and
Environmental Compliance, and the function of Architectural Review and Environmental
Compliance.
41
New York has the Archeology Unit and the Survey (architectural survey) &
Certified Local Government Program (CLG) Unit.
42
Texas has the Archeology division and the
Architecture division.
43
Although the terms vary, the function is still the same: archeological and
architectural review. In many respects this organizational structure provides a subtle hint to how
CRM programs should be structured at some level.

In the end, both archeology and historic preservation are connected to cultural resources
programs because they are both important in the sustainment of our nation’s (or our national
military’s) heritage. Both are the study of our past culture. As Orbasli explains, ““heritage”
encompasses ruins, archaeological sites, monuments, palaces, castles, vernacular buildings,
groups of buildings or ensembles, settlements and urban areas. It also includes the natural
!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
39
Sally G. Oldham, Historic Preservation in American Communities, National Trust for Historic Preservation,
Washington DC, 1987, p 2.
40
Robert E. Stipe, A Richer Heritage: Historic Preservation In The Twenty-First Century, (Chapel Hill, NC.: The
University of North Carolina Press, 2003), 1.
41
California SHOP website: http://ohp.parks.ca.gov/pages/1066/files/orgChrt.pdf, accessed June 15, 2014.
42
Parks, Recreation and Historic Preservation – New York State, Division of Historic Preservation,
http://parks.ny.gov/shpo/contact, accessed on February 10, 2015.
43
Texas Historical Commission, Our Divisions, http://www.thc.state.tx.us/about/our-divisions, accessed on Dec 15,
2014.!
28
!
heritage, areas of landscape significance and the cultural value of meaning and association.”
44

All this highlights the two stalwarts of preservation: Archeology and Architecture.
45

DoDI 4715.16: Cultural Resource Management
In 2008, DoD Instruction 4715.16, published in 2008, requested metrics and performance data
related to the DoD CRM program. The following discussion outlines 4715.16 and assesses the
effects on the practice of historic preservation in the military. The instruction details three
sections of concern. The three sections are then further broken down into six areas of metrics for
evaluation in an effort to outline tangible goals of the nation’s military CRM program.

The three major sections of 4715.16 are: 1) health of the inventory of cultural resources, 2)
health of the Cultural Resources Program, and 3) additional Information or areas. In terms of
deliverables the six areas of metrics are comprised of 1) Historic Preservation, 2) Curation, 3)
Archeological Survey, 4) Geographic Information System (GIS) mapping, 5) Integrated Cultural
Resources Management Plans (ICRMPs), and 6) Public Outreach.

The Health of the Inventory of Cultural Resources is a major section focusing on the
categorization of historic structures and buildings and the curation of archeological items. The
data collected from historic structures and buildings provides a unique insight on the health of
the CRM program. One of the most important categorization requirements is the second level
classification of historic properties into six elements. The six elements, as illustrated in Figure
1.9, categorize historic properties to groupings similar to civilian historic preservation
classification when distinguishing between elements of historic districts and individual historic
properties.

!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
44
Aylin Orbasli, Architectural Conservation: Principles and Practices. (Oxford, UK: Blackwell Science, 2008), 5.
45
Note: the types of cultural heritage vary. They include tangible resources, and non-archaeological/non-
architectural cultural resources like Traditional Cultural Properties.
29
!

Figure 1.4: Six Elements. Data from Department of Defense Instruction 4715.16, Cultural Resources Management.
Source: Figure made by Author.

The Health of the Cultural Resources Program is another major section concerning the reporting
of inventory and evaluation of historic properties and archeological sites. The inventory and
evaluation of historic properties targets the distinguishing of evaluated properties and those “not
yet evaluated.”
46
All properties have the potential to be historic properties. The best way of
determining if a property is a historic property is to evaluate the properties for determination of
eligibility to the National Register. The evaluation (with subsequent review and concurrence)
determines if a property is historic. A historic preservation evaluation takes into account the
architectural significance, historic connection, and integrity (to name a few) of a structure to then
determine it qualification as a historic property. If a property is not eligible, it does not fall under
the requirements of the NHPA.

The area of metrics governing the inventory of historic archeological properties attempts to attain
an overall picture of DoD lands surveyed for archeological artifacts. This section specifically
focuses its interest to metrics of survey of lands available for survey. Some lands owned by the
DoD are not available for survey. Examples of these include bombing and firing ranges.
!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
46
US Department of Defense, Department of Defense Instruction 4715.16, Cultural Resource Management.
(Washington DC: Department of Defense, 2004), 18.
30
!

The third and final major section of 4715.16 is Additional Information or Areas. This section
effectively serves as a catchall of ancillary areas for cultural resource managers. The specific
three areas in which this section is measured include are Geographic Information Systems (GIS),
Integrated Cultural Resources Management Plans (ICRMPs), and public access to cultural
resources information. By applying the results of previous research into a computerized
geographic platform, historic property management moves into the geospatial realm. An ICRMP
is the installation or region level policy document, which describes the method by which the
CRM will co-exist with the multiple operations of the base or region. The public access to
cultural resources information is a series of metrics illustrating methods for which the public can
gain knowledge of the historic resources on military installations. The metrics specifically
tracked are the amount of web pages, tours, and pamphlets in welcome packages containing
cultural resource information.

All the above metrics were described to illustrate the prolific data required to report to Congress.
The significance of this is the importance placed on accountability to our military’s preservation
program. While Section 106 and 110 of the NHPA lay out the legal process for maintaining
cultural resources, DoD Instruction 4715.16, Cultural Resources Management, provides us with
specific metrics necessary for management and lays out requirements for a CRM program.

31
!

Figure 1.5: Six Elements. Data from Department of Defense Instruction 4715.16, Cultural Resources Management.
Source: Figure made by Author.
32
!

Integrated Cultural Resources Management Plan (ICRMP)
As with all good programs, it is essential to have a plan for achieving success. The Integrated
Cultural Resources Management Plan (ICRMP) is such a plan when dealing with cultural
resources. Although other USAF instructions have provided direction on the standards of the
ICRMP, the DoDI 4715.16 has become the primary source for developing an ICRMP.

The ICRMP is a mandatory five-year plan of activities involving cultural resources. DoDI 4715,
through the responsibilities of the Deputy Under Secretary of Defense for Installations and
Environment, mandates ICRMPs are used as an instrument “for compliance with the statutory
management requirements” of the CRM program.
47
The definition provided by the Air Force in
AFI 32-7065 published on June 1, 2004 is as follows:

Integrated Cultural Resources Management Plan (ICRMP)—A document that
defines the procedures and outlines plans for managing cultural resources on
DoD installations. ICRMPs are required for all DoD installations under DoD
Instruction 4715.3, Environmental Conservation Program. The ICRMP differs
from previous CRMPs in that it is more comprehensive, and integrates, and is
integrated into, other land management and development plans at installations.
Air Force installations must update their plan every 5 years.

The DoD Instruction 4715.16, the fundamental document directing ICRMPs, recommends two
levels of content in an ICRMP, general content and specific content. The items designated as
general content refer to items that give a primer, or orientation, to the installation. To this end,
the general content includes a beginning summary of the plan. This includes pertinent context
information of the installations jurisdiction. Next it recommends including procedures and
priorities for the specific content section. Lastly, it emphasizes the importance of appropriate
stewardship of cultural resources within the context of a mission priority. The items designated
as specific content have been consolidated and placed in Figure 2.3.

!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
47
US Department of Defense. Department of Defense Instruction 4715.16, Cultural Resource Management,
(Washington DC: Department of Defense, 2004), 21.
33
!

Figure 1.6: The specific content of ICRMP as directed by DoD Instruction 4715.16. Data courtesy of DoD
Instruction 4715.16. Source: Figure made by Author.

The interpretation of the Air Force ICRMP follows the DoD instruction to a required extent. AFI
32-7065 also provides guidelines on how to prepare an ICRMP. First, an ICRMP should begin
with an executive summary and followed by general information that includes the mission
statement of the installation. The third major section is the cultural resources inventory which
includes prehistoric at historic resources. Next the guidelines require the Air Force to give
34
!
compliance procedures for all historic resources found on the installation. These compliance
procedures are to take into account the issues discovered and thus specific to the installation. The
fifth area identified is the provision for giving Standard Operating Procedures (SOP). SOPs are
“specifically defined steps necessary to implement required actions during most routine or
reasonably expected situations.” These five areas make up the components of an ICRMP and
reflect the USAF’s interpretation.

The result of DoDI 4715.16, Cultural Resource Management, was the codification of the
activities of CRM and the development of the ICRMP and its implementation. Once the
requirement to develop an ICRMP was established for all installations, the next step was to track
the ICRMPs progress to completion.
48
The figure below illustrates how the DoD components
fared as of fiscal year 2010. (Figure 2.4)

!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
48
US Department of the Air Force, Air Force Instruction 32-7065: Cultural Resources Management Program,
(Washington, DC: Department of Air Force, 2004), 26.
35
!

Figure 1.7: ICRMP Completion Status. Data courtesy of Fiscal Year 2010 – Defense Environmental Programs
Annual Report to Congress. Source: Figure made by Author.

1.8 Numbers
Overall DoD Numbers
The DoD manages more than 20,000 listed or eligible National Register properties. The DoD is
also responsible for over 100,000 archeological sites.
49
As of fiscal year 2010, the DoD’s Real
Property Asset Database--a computer program used to track all DoD Real Property--identified
21,334 buildings and structures with historic classifications in the database.
50
The below is the
distribution of all 21,334 resources by ownership within their respective DoD components.
(Figure 2.5)

!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
49
Defense Environmental Programs Annual Report to Congress Fiscal Year 2010, Chapter 3 Cultural Resources,
Washington DC., (2010), 19.
50
Ibid., 22.
113!
2!
133!
11!
37!
296!
3!
7!
34!
44!
Air!Force!
DLA!
Army!
Marine!Corps!
Navy!
DoD!Total!
ICRMP&Completion&Status&
Completed! Not!Completed!
36
!

Figure 1.8: DoD Distribution of 21,334 Historical Structures found in DoD responsibility. Data courtesy of Fiscal
Year 2010 - Defense Environmental Programs Annual Report to Congress. The figure does not include
archeological sites. Source: Figure made by Author.

Individual Numbers: Army, Air Force, Navy and Marines
The Army is undoubtedly the largest DOD component maintaining historic properties in the
military. The Army’s 13,634 historic properties illustrate the priority placed on holding large
areas of land as a primary function for waging war. The Air Force illustrates its unique role in
the future of military preservation by being the steward of 4,249 historical structures, the second
most of the DoD components. The Navy and Marines combine for a total of 3,450 preservation
unique structures. The natural tendency of the Navy and Marine’s aquatic mission lends itself to
the limited amount of historical land (real estate) assets. What these numbers help to illustrate is
large number of cultural resources for which the military is responsible.

Army!!
(13,634)!
Air!Force!
(4,249)!
Navy!
(2,733)!
Marine!Corps!
(717)!
Washington!DC!!!!!!!!
!(1)!
DoD&Distribution&of&NRHP9Eligible&or&Listed&
Properties&
37
!
If there is a data point illustrating promise to the necessity of architectural preservation within
the military, there is no better example than the one offered by the Defense Environmental
Programs Annual Report, defined as “Number of buildings, structures, and linear structures 50
years or older with the historical status data element code Not Yet Evaluated (NEV).” The data
indicates there are 66,593 such resources within the DoD inventory still requiring evaluation
(See below, Figure 2.6).
51
This number will continue to grow as the rest of the building and
structures in the US military inventory continue to age.

Figure 1.9: Historical Structures “Not Yet Evaluated.” Data courtesy of Fiscal Year 2010 – Defense Environmental
Programs Annual Report to Congress. Source: Figure made by Author.

!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
51
!Defense Environmental Programs Annual Report to Congress Fiscal Year 2010, Chapter 3 Cultural Resources,
Washington, DC., (2010), D-40.
Army!!
(33,219)!
Air!Force!
(9,479)!
Navy!
(20,178)!
Marine!Corps!
(3,707)!
Washington!DC!!!!!!!!
!(10)!
Historical&Structures&&
"Not&Yet&Evaluated"&
38
!
1.9 Conclusion
This chapter has outlined the national laws and military regulations applicable to preservation to
establish the context in which military CRM programs are based. This forms the foundational
framework for historic preservation. A constant goal of the DoD is to align actions of the US
Army, US Navy (to include the US Marines), and US Air Force in a direction that maximizes the
efforts of the entire US military establishment. The goals and requirements set forth by the laws
resulting from the NHPA are used to create and develop a military historic preservation program.
Consequently, US military establishment provides an optimistic outlook that historic
preservation has a strong opportunity to succeed.

39
!
Chapter 2: Military Traditions of the US Military

2.1 Brief USAF History
The purpose of this chapter is to introduce the Air Force through its history, traditions, and
cultural uniqueness. The intention is to establish a general understanding of the Air Force so as
to then present the nature of which architectural preservation is prioritized in the Air Force. As
when describing most organizations, we begin with the inception when conducting a historical
review.

The Air Force and Resultant Culture
US Air Force Doctrine defines ‘Airpower’ as “the ability to project military power or influence
through the control and exploitation of air, space, and cyberspace to achieve strategic,
operational, or tactical objectives.”
52
While this is the latest version of the definition of Airpower
the concept of a technological air focused force is still fundamentally the same as when the air
force was conceived.

World War I (WWI) was the first time aerial technology was used as it was effectively the first
mechanized war.
53
However, the powers in place did not really know what type of capability
aerial technology gave them. “Conquering the air was not undertaken for military purposes and,
when it had been done, there was not a clear idea about how it was to be used other as an
airborne cavalry.”
54
In this case airborne cavalry was meant to be the strategic delivery of items
(supplies and troops) to the battlefield. WWI provided the military community with a lot of
lessons. One lesson, albeit seemingly an obvious one, was the identification of the locations
where war was going to be waged.

!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
52
Air Force Doctrine, Airpower, Vol. 1 Basic Doctrine, Chapter Two, Curtis E. LeMay Center for Doctrine
Development and Education, last updated on 27 Feb 2015.
53
Maryam Philpott, Air and Sea Power in World War I: Combat and Experience in the Royal Flying Corps and the
Royal Navy, (London: I.B. Tauris, 2013), 96.
54
Robert F. Grattan, The Origins of Air War: The Development of Military Air Strategy in World War I, (New York:
I.B. Tauris, 2009), 169.
40
!
With air forces now in the fold, “there was an air war, in the same way as there is [was] land war
and a war at sea, and the air war needs [ed] to have its own aims.”
55
Although it was a new area
of war it was not unlike the war at sea, “where opposing forces manoeuvred [sic] in, but did not
‘hold,’ areas of the ocean.”
56
The reality was air forces could transcend the areas they did battle
in. While they had their battle in the air, they also could support and affect the balance of land or
sea war.
57

During World War II (WWII), as various flying technologies developed the war making
capabilities of a flying force, the US Army Air Corps used flying for bombing, close air support
and airlift (airborne). It became evident that the US Army Air Corps “had become the most
powerful air force in the history of the world in the forty-four months after Pearl Harbor.”
58
This
proved to be an amazing feat in such a short period of time.

By the war’s end, it was evident that military aviation had grown in relevance and value when it
came to the ability to make war. In an effort to develop a concept as to how the US nation’s
post-war military would look, President Truman’s Air Policy Commission (July 18, 1947)
overwhelmingly recommended a “sharp increase in Air Force and Navy combat planes,” putting
into motion the need for an independent air force.
59
This and a wave of other changes in
philosophy proved to be vital in the government’s overall acceptance, and later implementation,
of a military unification plan. This unification idea was essentially a call for restructuring the US
military establishment.

Up to this time, the national defense establishment was the responsibility of two independent and
separate, government departments. The two departments were: The Department of the Navy (the
nation’s sea force) and The Department of War (the nation’s land force, or army). The Army Air
Corp fell under the Department of War. This “antiquated defense setup,” as President Truman
!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
55
Robert F. Grattan, The Origins of Air War: The Development of Military Air Strategy in World War I, (New York:
I.B. Tauris, 2009), 170.
56
Grattan, 171.
57
Ibid., 172.
58
Walter J. Boyne, The Influence of Air Power upon History, (Gretna, AL: Pelican Publishing Co., Inc. 2003), 290.
59
William D. Hartung, Prophets of War: Lockheed Martin and the Making of the Military-Industrial complex, (New
York: Nation Books, 2012), 56.
41
!
construed, required updating.
60
The unification of the national defense establishment came to
fruition with the passing of the National Security Act of 1947.
61

The Act of Creation
The most important aspect of this Act, relative to our subject, was the creation of the US Air
Force as a third independent branch of the National Military Establishment (later renamed the
Department of Defense) headed by the Secretary of Defense. Below the Sectrary of Defense was
each independent secretary of the Army, Navy and Air Force.
62
The first Secretary of the Air
Force was W. Stuart Symington and the first Chief of Staff of the Air Force (the highest military
member) was General Carl A. Spaatz.
63
While the Air Force was “created out of the existing
Army Air Forces” the official birthday of the Air Force--as a result of the Executive Order 9877
and National Security Act—is September 18, 1947.”
64

Throughout all of this prodigious change, the Navy, with its own flying corps, fought the Air
Force’s mission from the beginning. The Navy knew the capabilities of the Air Force could
threaten their desire of controlling the nation’s “strategic and tactical nuclear capability.”
65
Thus,
from the onset, the Air Force was given almost instant vital responsibility while the history’s
most traditional and already existing military forces (armies and navies) were losing a next
generation role (nuclear capability) to a neophyte arm of the military.

The Air Force’s First Action: Berlin Airlift
On June 22, 1948, the Soviet Union commenced a blockage of all supplies into West Germany in
an effort to move Western Allies from their zones in West Berlin.
66
The Western Allies did not
know how to respond. In general, the responses centered on either a fight or flight counter.
However, another type of recommendation was proffered, which gave the Western Allies time to
!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
60
Warren A. Trest, Air Force Roles and Missions: A History, U.S. Government Printing Office, (Washington, D.C.:
Air Force History and Museums Program, 1998), 111.
61
Walter J. Boyne, Beyond the Wild Blue: A History of the United States Air Force 1947-2007, 2
nd
Ed., (New York:
Thomas Dunne Books, St. Martin’s Press, 2010), 31.
62
Ibid., 31.
63
Boyne, 463.
64
Boyne, 32; Warren A. Trest, Air Force Roles and Missions: A History, U.S. Government Printing Office,
(Washington, D.C.: Air Force History and Museums Program, 1998).
65
Walter J. Boyne, The Influence of Air Power upon History, (Gretna, AL: Pelican Publishing Co., Inc., 2003), 290.
66
Walter J. Boyne, The Influence of Air Power upon History, (Gretna, AL: Pelican Publishing Co., Inc., 2003), 290.
42
!
resolve the matter “diplomatically.”
67
This passive method of flying in support of the war effort
was aggressively seized by the Air Force General LeMay when he said the Air Force “could do
anything,” and they did.
68
On June 26, 1948 the Berlin Airlift supplied 80 tons of supplies to
Berlin.
69
At the height of the airlift, West Berlin received more supplies then they ever could
have been transported by normal rail, road, and canal. By the airlift’s end on September 30,
1949, the airlift had brought in an astonishing “2,325,000 tons of supplies” over 275,000
flights.
70

The importance of the Berlin Airlift is it gave the Air Force its first opportunity to showcase its
capabilities since becoming its own independent branch of the military. More important to
history, it introduced to the world the “technological triumph” that was the US Air Force and to a
further extent the United States. After this the “Kremlin lifted the blockade, but drew the Iron
Curtain tighter as the Marshall Plan took root.”
71

Revolt of the Admirals
By April 23, 1949, the biggest fear of the US Navy had come to fruition: the US Air Force had
effectively been given the role of delivering nuclear assets. This occurred when the newly
installed Louis A. Johnson, just one month into his regime as Secretary of Defense, canceled the
“Navy’s $188 million supercarrier” as it was deemed to be obsolete in the wake of new Air
Force strategic bombers.
72
Needless to say, Navy leaders did not take to this well. Navy
Admirals denounced the decision culminating with the Secretary of the Navy, John L. Sullivan,
resigning in protest in what was called the “Revolt of the Admirals.”
73
This also resulted in
severing and settling the relationship between the new US Air Force and the US Navy.

!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
67
Ibid., p. 291.
68
Ibid.
69
Walter J. Boyne, Beyond the Wild Blue: A History of the United States Air Force 1947-2007, 2nd Ed., (New York:
Thomas Dunne Books, St. Martin’s Press, 2010), 464.
70
Boyne, Influence, 291.
71
Warren A. Trest, Air Force Roles and Missions: A History, U.S. Government Printing Office, (Washington, D.C.:
Air Force History and Museums Program, 1998), 125.
72
Boyne, Influence, 295.
73
Warren A. Trest, Air Force Roles and Missions: A History, U.S. Government Printing Office, (Washington, D.C.:
Air Force History and Museums Program, 1998), 127.
43
!
The Air Force: The Next Generation of the Military
The early Air Force events above positioned the United States as a, “nation which [that]
understood new weapons.”
74
This new-found perception highlighted that the, “Air Force’s
leadership emphasized technological innovation,” resulting in much-improved war making
capabilities. The biggest gain however was the overall culture and identification as a
technological force.
75
This forward-thinking new service showed its leadership in other fronts as
well. On April 26, 1948 the Air Force became the first US military branch to implement a policy
of racial integration. Later the other service branches followed suit, but only after the executive
order (EO 9981) by President Truman in the same year.
76
This illustrates why the Air Force held
such an important role in the next American conflicts in North Korea as well as in the Cold
War.
77

This capsule of US Air Force history has been given to illustrate the newness of the Air Force
which impacts historic preservation since it has only been until relatively recently, 1997, the Air
Force surpassed fifty years of existence. The historic preservation community traditionally
deems fifty years as the age for which a structure is suitable for historic evaluation; the same
community, however, now has factions arguing there should be no age threshold. This could play
a significant role because a portion of the Air Force bases were converted Army installations,
however the buildings were built new for the new branch of service, they did not simply use old
Army buildings.
78
What this means is many of the Air Force’s architectural resources have
turned, or are about to turn, fifty years of age. This could trigger a requirement for a historic
preservation evaluation, depending upon the nature of a future undertaking. The bottom line is
that, even though the Air Force is on the cutting edge of technology and may one day be called
!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
74
Burke Davis, The Billy Mitchell Affair, (New York: Random House Book, 1967), 210.
75
Major John R. Carter, USAF, Airpower and The Cult of the Offensive, (Maxwell Air Force Base, AL: Air
University Press, 1998), 83.; Mike Worden, Colonel USAF, Rise of the Fighter Generals: The Problem of Air Force
Leadership 1945-1982, (Maxwell Air Force Base, AL: Air University Press, 1998), 14.
76
Walter J. Boyne, Beyond the Wild Blue: A History of the United States Air Force 1947-2007, 2nd Ed., (New York:
Thomas Dunne Books; St. Martin’s Press, 2010), 464.
77
Frederick J. Shaw, ed., Locating Air Force Base Sites: History’s Legacy, (Washington D.C.: Air Force History
and Museums Program, United States Air Force, 2004), 53.; Mike Worden, Colonel USAF, Rise of the Fighter
Generals: The Problem of Air Force Leadership 1945-1982, (Maxwell Air Force Base, AL: Air University Press,
1998), 55.
78
Frederick J. Shaw, ed., Locating Air Force Base Sites: History’s Legacy, (Washington D.C.: Air Force History
and Museums Program, United States Air Force, 2004), 70.!
44
!
the “United States Aerospace Force,” this does not absolve the Air Force of its cultural resources
responsibility.
79

2.2 Military Traditions
Despite the newness of the Air Force it is still a military service. More so, the Air Force is a
military service born of the Army, as the Army Air Corps. This means the Air Force is a service
with a full complement of military traditions, either newly made or carried on from US Army
practice. The nature of war, with its associated ultimate cost, creates an environment with a high
propensity for developing traditions. Military traditions are primarily a practice of time-tested
and handed-down customs that aid in either survival of war or the ability to move on from loss.
The following are examples of military traditions that give context to the type and meaning of
US military traditions.

Uniform
A uniform is a perfect example of a military tradition. The tradition of a uniform can be broken
down into two purposes. The first and most crucial is to “distinguish between friend and foe.”
The second arose from economic concerns as “in foreign countries the colonel was responsible
for clothing his regiment and it was cheaper to buy the material in bulk lots.”
80
The aspect of this
tradition that is most interesting is that while it is a tradition set to stand the test of time, it is also
a tradition of continual change. This is to say, while the uniformity is constant the uniform it self
is ever changing. The constant change is a result of the ever-changing mission that usually results
from a change in environment, or in terms of war, a different global location of the preceding
war.

For example, during the British occupation of India, it was the confluence of necessity to blend
into the environment and the availability of curry powder that resulted in the process of dying
!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
79
Boyne, Beyond, 277.
80
Boatner, Mark M., Major, USAF, Military Customs and Traditions, (New York: David McKay Company, Inc.,
Van Rees Press, 1956), 23.
45
!
uniforms to a brown hue, or “dust-colored,” what we now call khaki.
81
This evolution of
uniforms has occurred time and time again throughout the history of warfare. US military
uniform history is no exception the jungle green in Vietnam and desert beige in Desert Storm are
just two examples of evolution within US military uniform tradition.

Change of Command
The change of command is a ceremony marking the start of a new Commander’s regime and
consequently, the end of the former commander’s tenure. As will become evident with
subsequent examples of tradition, the change of command tradition is one that marks the end of
the old and the beginning of the new. One aspect of this tradition is that after the end of the
ceremony members of the military unit should no longer see the old Commander. The outgoing
commander must remove his or herself from public view so as not to cause confusion of current
authority. In short, the ceremony is a public showing of who is in command.
82
An important
side-note about unit commanders is their first impression of historic preservation. When taking
command, a commander takes full command; that is the commander is fully responsible for all
that occurs at the installation. Historic preservation, however, is an entity that effectively reminds
a Commander that he or she does not quite have full jurisdiction over the installation’s buildings,
or resources.

Hail and Farewell
The “hail and farewell” is a traditional event marking the departure and arrival of individuals
into a military unit. This event comes in the form of a social unit meeting where leadership can
publicly introduce newcomers and properly say farewell to departing members. The “hailed”
members are introduced by a short synopsis
of their prior experience and base (military installation) for which they are arriving from. The
departing members receive accolades for work during their respective assignments and are
presented a parting gift commemorating their time served. Once again this is a military “good-
bye” to the old and “hello” to the new.
!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
81
Boatner, Mark M., Major, USAF, Military Customs and Traditions, (New York: David McKay Company, Inc.,
Van Rees Press, 1956), 28.
82
US Department of the Air Force, Air Force Pamphlet 34-1202: Guide to Protocol, (Washington, DC: Department
of Air Force, 2013), 64.
46
!
Calling a Room to Attention
This tradition is the formal acknowledgement of the highest-ranking officer into a room. In this
tradition, “the first person to see an officer entering the room calls the room to attention. If an
officer of equal or higher rank is already in the room, the room is not called to attention. When
the officer departs, the room is called to attention again.”
83
This tradition crosses a few
significant lines in terms of the focus of this thesis. For one, it presents a valued military resource
in an everyday event as a form of tradition and ceremony. This falls in line with the values of
historic preservation; displaying important resources. Second, it is another example where the
military opens and closes events in a compartmental fashion, marking the beginning and end of a
professional association.

Honor Guard (Funeral)
This tradition encompasses the presentation of the US flag by a ceremonial group of military
members during a funeral of a military member or military veteran. During the ceremony, “the
American Flag that covers the casket symbolizes the decedent’s service in the armed forces of
the United States of America.”
84
Later, the same flag that had draped the casket is folded in a
triangular fashion within a concise package. The folded flag is then presented to the family of the
fallen member. The tradition of the presentation of the US flag represents a remembrance of
service as well as a reminder of the required resolve to continue on after a loss. Loss represented
in cherished objects and as a remembrance of persons is the innate nature of the military service.
However, moving on is also an attached necessity with this tradition. Once again this military
tradition is an example where military members say good-bye and close a chapter in events.

Concluding Traditions
The military traditions discussed above exhibit instances where the military gives illustration of
an inclination to abdicate the old. In contrast, historic preservation fosters a culture of retaining
mature resources. It would seem the military, with its traditions, would find historic preservation
counterintuitive to its established culture. Quite frankly, the traditions of the military are more
!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
83
US Department of the Air Force, Air Force Pamphlet 34-1202: Guide to Protocol, (Washington, DC: Department
of Air Force, 2013).
84
US Department of the Air Force, Air Force Manual 32-2203: Drill and Ceremonies, (Washington, DC:
Department of Air Force, 2013), 143.
47
!
concerned with the standardizations of activities (to achieve its mission) than on the preservation
of resources.

In researching military tradition it was apparent that, while historically connected, traditions
could be created at any time. The main reason this thesis challenges the establishment of
traditions with the ‘new’ obligation of preservation is because traditions are historic
preservation's biggest obstacle. However, military traditions can be viewed as an ally to
preservation in that military traditions are continually developing and evolving. Just like this
thesis is the introduction to the possibility of a new culture of Air Force historic preservation, it
can also spark the onset of new traditions in maintaining heritage resources.

2.3 Military Cultural Resource Management Culture
The culture of military cultural resource management was established in a way that resulted in an
overwhelmingly focus on archeology. The traditions presented above do not necessarily foster
the preservation of resources and related heritage. This is an obstacle for all of cultural resources,
archeology and historic preservation alike. The next section will attempt to illustrate how even if
the traditions of the military were welcoming to historic preservation, the intra-cultural resource
management discipline of archeology is one that currently commands and dominates the culture
of military cultural resource management.

Governmental Archeology
Up until 1966, cultural resources management was primarily associated with archeology
throughout the nation, including in the military. The first law enacted by the US Congress related
to Archeology was The Antiquities Act of 1906. This Act specifically protected archeological
artifacts found on government-owned property. The next Act governing archeological activities
was the Historic Sites Act of 1935. The Historic Sites Act was the first to include historic sites
and buildings, effectively laying groundwork for the National Historic Preservation Act (NHPA).
In 1966, the NHPA officially merged archeology and architectural preservation. More
specifically this Act expanded the scope of entry into the National Register of Historic Places.

48
!
The next decade saw Congress pass the Archeological and Historic Preservation Act to ensure all
government entities were responsible (through mitigation) of undertakings of a destructive
nature. Such mitigation requirements were also addressed in amendments to the NHPA.
Congress than passed the next archeological law by affirming the Archeological Resources
Protection Act of 1979. Among other things, the act imposed standards on post-discovery
repository locations when cultural artifacts become a part of the inventory. Next, in an effort to
standardize underwater archeology, Congress passed the Abandoned Shipwreck Act of 1987.
The last proper “Act” issued by Congress was the Native Americans Protection Graves
Repatriation Act of 1990 which established procedures and consequence for returning and
keeping Native American articles found and kept in the field.
85

The Unique Connection between Archeology and the Military
The Depression of 1929 was an ominous event in American history, pushing over ten million
people into unemployment.
86
President Roosevelt, as a part of his New Deal effort to get the
nation back to work, created various relief agencies with this goal in mind. With respect to
archeology, the Federal Emergency Relief Administration (FERA) was the relief effort
specifically offering funds to large archeological government projects.
87
The intrinsic nature of
archeology lends itself easily to the “major requirement of work relief programs” with
archeology being a “shovel ready” activity.
88

In the end, these relief programs resulted in two archeological predicaments. First, it resulted in
the largest archeological work recorded to date. Much of the work done has not, to date, been
properly processed. Essentially, a great deal of raw inventory and or documentation remains to
be processed. The second issue is it resulted in a large population of archeologically trained, or
experienced, personnel.
89
On the surface this may not seem like a predicament, but what results
is a management pool filled with predominately archeologists. A better scenario would be to
!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
85
National Park Service. Archeology Program. http://www.nps.gov/archeology/public/publicLaw.htm., accessed on
Feb 2, 2015.
86
Lyon, Edwin A., New Deal for Southeastern Archaeology. (Tuscaloosa, AL: Univ. of Alabama Press, 1996), 27.
87
Ibid., p. 28.
88
Means, Bernard K., ed. Shovel Ready: Archaeology and Roosevelt's New Deal for America. (Tuscaloosa, AL:
University Alabama Press, 2013), 8.
89
Bernard K. Means, ed. Shovel Ready: Archaeology and Roosevelt's New Deal for America. (Tuscaloosa, AL:
University Alabama Press, 2013), 11.
49
!
have a management pool composed of both archeologists and historic preservationists. The
overwhelming number of archeologists in this trade can be attributed to the large numbers of
members which entered into the military with the onset of WWII. This population, in turn, when
done with military service, utilized veteran educational services to return into the archeological
community and later practice the profession. This shows the intricate relationship between
archeology and the military.

Land Mass
In a basic introduction to the relationship between the military forces and land, a study in Sun
Tzu’s The Art of War helps to illustrate the importance of “terrain” and “ground” when with war.
The first (Chapter 10, Terrain) is dealt with in terms of traversing it. The second (Chapter 11,
The Nine Situations; or varieties of ground) is discussed to educate on the types of ground to be
attained and battled upon.
90
The point here being, the entities of war have always been interested
in the attainment and possession of land as a means to attain victory in war.

Today, US military land possession in the continental United States is more a function of staging
for war than an actual battle to attain it. Nonetheless, the amount of land in possession by the
Department of Defense is a staggering nineteen million acres in the form of military bases and
training ranges.
91
In terms of architecture, the Department of Defense is in custody of “500,000
buildings and structures spread throughout the United States and more than 30 other countries.”
92

Assets Causing Change
As described above, the main reason for archeology as a primary discipline in the military and
Air Force is due to the large amounts of land acquired by the U.S. Military. The Air Force
accumulated large amounts of land and now the assets on these lands are in need of evaluation.
After WWII, with the United States moving on to other military conflicts, President Truman
“directed that the Air Force build new domestic bases only if no exiting base could be
!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
90
Sun Tzu, Art of War. Chapter 10, 11.
91
Ross W. Gorte, Carol H. Vincent, et al, Federal Land Ownership: Overview and Data, (Congressional Research
Service, 2012), 1.
92
Office of the Deputy Under Secretary of Defense Installations and Environment, Real Property Accountability.
http://www.acq.osd.mil/ie/bei/accountability.shtml, accessed on January 5, 2015.
50
!
modernized.
93
Even though existing military bases were used, the Air Force still built new
facilities on these bases. In fact, during the early 1950’s the Air Force actually built entirely new
bases, further compounding the issue.
94
Later on, the Air Force grew:

“The total number of active Air Force wings in the CONUS grew from 67 (55
combat) in 1947 to 183 (143 combat) in 1956. The number of major USAF
installations in the same year increased from 115 to 162. Almost 100 USAF
bases remained active throughout the period 1947-1960, but during those years
the service developed sixty-eight bases to accommodate its expansion. The great
majority (forty-seven) were reactivated World War II airfields. Eleven of the
additional bases came from the Army or Navy; eight were built from scratch.
Two were reactivated in 1951 after having been inactivated in 1949.”
95

This resulted in a huge number of architectural assets built during the Cold War era. The age of
the installation is a solid indicator of the age of the buildings and the period for which significant
historic involvement can occur. These buildings are now coming into an age where they can be
evaluated for their historical significance. This fact creates an opportunity for preservation
advancement within the Air Force because like its partner service branches, the Army and Navy,
the Air Force has now reached a true period ripe for preservation.

2.4 Historic Preservation Designations in the Air Force
Despite the heavy archeological precedence in USAF cultural resource management, the
following are three excellent examples of architectural and landscape designation found within
the USAF. The very nature of the air service, and its military affiliation, implies its connection to
federal funds and resources. These financial resources are the basis for commissioned
architecture resulting, at times, in quality architecture. The following are three perfect examples
of the Air Force’s quality architectural inventory: Randolph Field Historic District, The US Air
Force Academy--Cadet Campus, and Moroc Dry Lake.
96
These buildings and landscapes are
!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
93
Frederick J. Shaw, ed., Locating Air Force Base Sites: History’s Legacy, (Washington D.C.: Air Force History
and Museums Program, 2004), 55.
94
Shaw, 56.
95
Shaw, p. 89.
96
Frederick J. Shaw, ed., Locating Air Force Base Sites: History’s Legacy, (Washington D.C., Air Force History
and Museums Program, 2004).
51
!
many years apart in age and even further apart in architectural style; however, they are gems in
the USAF’s architectural inventory.

Randolph Field Historic District
In April of 1927, the Army Air Corps created a site location board in search for a new flying
school. They found a location of particular interest near San Antonio, Texas. This location
possessed great annual weather and close proximity to the advanced flying training location of
Kelly Field.
97
The entire Randolph field was designed with the flying culture in mind. The base,
in its entirety, was built in circular forms with two separate circles forming an overall rectangular
area. The centerpiece of the campus, the Administration Building, was designed by San Antonio
architect Atlee B. Ayres. The Administration building, later dubbed the “The Taj Mahal,”
referred to its pronounced position in the center of the base.
98
Ayres’ building was both aesthetic
and functional, upon completion in 1931, its 170 foot tower could not only be seen for up to fifty
miles away, but the tower itself also contained a 500,000 gallon water tank.
99
The Spanish
Colonial Revival Style building (Figure 3.1), accentuated with stucco exterior and tile roofing
topped by open bays resulted in the tower becoming an iconic figure in military aviation. The
tower was so connected to aviation it was featured in the Hollywood film West Point of the Air,
and movies depicting the rigors of military pilot training.
100

Randolph Field was added as a Historic District to the National Register of Historic Places
because of its cultural values of architecture, landscape architecture, and urban design. In
addition, it helped shape the political landscape through its Military Institutions and Activities.
101

In total, the Historic District contains 342 buildings, seven structures, and one site contributing to
the Randolph Field Historic District.
102

!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
97
Ibid.
98
Robert James Coote, The eclectic odyssey of Atlee B. Ayres, Architect, (College Station, TX: Texas A&M
University Press, 2001), 101.
99
Randolph Field: A History and Guide; compiled by workers of the writers’ program of the Work Projects
Administration in the State of Texas, Sponsored by the Commanding Officer, Randolph Field, The Devin-Adair
Company, (New York: Bureau of Research in the Social Sciences of the University of Texas, 1942), 123.
100
Title: “West Point of the Air,” Dir: Richard Rosson, Prod: Monta Bell, Metro-Goldwyn-Mayer, Released: 23
March 1935.
101
Jody Cook, National Historic Landmark Nomination: Randolph Field Historic District, Atlanta, GA, Designated:
August 7, 2001, 35.
102
Ibid., 1.
52
!

Figure 2.1: The Administration Building, or Building 100, also called “The Taj Mahal” at Randolph AFB, Tx.
Source: Author.

The Taj Mahal at Randolph AFB symbolized the moniker given to Randolph AFB as “The West
Point of the Air.”
103
That is until the Air Force finally built itself its own proper academy in
Colorado Springs, Colorado. True to form, the Air Force once again built itself another Taj
Mahal, this time in the form of a cadet campus centerpiece: the Cadet Chapel.
104

!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
103
Thomas Manning, History of Air Education and Training Command, 1942-2002, Office of History and Research
at Headquarters, (Randolph AFB, TX: Air Education and Training Command publishing, 2005), 3.
104
Note: The term Taj Mahal has also taken on the a more colloquial role in the Air Force, where the inception of
any new headquarters building is at first termed the Taj Mahal until changed as locally determined.
53
!
United States Air Force Academy, Cadet Area
The Air Force wanted an academy to rival the Army’s West Point and the Navy’s Annapolis.”
105

President Eisenhower officially made this come true with the Air Force Academy Act in April
1954.
106
A perfect example of the "newness" of the Air Force can be found in its Cadet Area
focal point, Cadet Chapel. Walter A. Netsch was the architect of the Cadet Chapel from the firm
of Skidmore, Owings, and Merrill.
107
Netsch visited Europe and found inspiration there,
specifically using the Cathedral of Notre Dame in Chartres, and the Sainte-Chapelle in Paris as
inspiration.
108
He particularly liked the stained glass windows that separated the flying
buttresses.”
109
This patterned feature later showed itself in the chapel.

!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
105
Frederick J. Shaw, ed., Locating Air Force Base Sites: History’s Legacy, (Washington D.C.: Air Force History
and Museums Program, 2004), 83.
106
George V. Fagan, The Air Force Academy: An Illustrated History, (Boulder, CO: Johnson Books, 1988), 81.
107
Ibid.
108
Ibid.
109
Ibid.
54
!

Figure 2.2: Notre Dame in Chartres (top) and Sainte-Chapelle in Paris (bottom), Source: Getty Pictures.

55
!
Once the campus was complete, the centerpiece was what most commented on. The criticisms
varied, one Senator from Virginia, Willis Robertson, said “You don’t seem to hear the rustling
sound of angels’ wings when you look at that chapel.”
110
Of course the architectural firm of
Skidmore, Owings, and Merrill debunked criticisms, believing “the architectural style of the
Academy would be timeless.”
111
Most architects defended the notion believing “the Air Force
should be permitted to express the spirit of the air age in its new institution and at the same time
accentuate the natural beauty of its Rocky Mountain setting.”
112

The US Air Force Cadet Campus was selected for nomination to the National Register of
Historic Places under criterion one and four: one, “Significance as a US Military Academy,”
113

and four, “Significance as Federally Commissioned Modern Architecture.”
114
The national
historic landmark themes of the Cadet Campus included expressing cultural values with
“Educational and Intellectual Currents” and “Architecture, Landscape Architecture, and Urban
Design.” In addition, a theme of Shaping the Political Landscape with “Military Institutions and
Activities.”
115
The campus district contains ten buildings, one structure, and one site.
116

!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
110
George V. Fagan, The Air Force Academy, An Illustrated History, (Boulder, CO: Johnson Books, 1988), 81.
111
Ibid.
112
Ibid.
113
Daniel J. Hosington, National Historic Landmark Nomination: United States Air Force Academy: Cadet Area,
Roseville, MN, Designated: April 1, 2001, 22.
114
Ibid., p. 32.
115
Ibid., p. 20.
116
Ibid., p. 1.
56
!

Figure 2.3: United States Air Force Academy Cadet Chapel. Source: Author.

Muroc Dry Lake
Muroc Dry Lake is in the Antelope Valley and serves as the center of Edwards AFB. It is a
pluvial lake created roughly two and half million years ago during the late Pleistocene Era.
117

The dry lakebed is roughly twelve miles long and five miles wide. The nature of the landscape
makes the dry lakebed ideal for aeronautical testing operations because of its large and continual
flat surface.
118
Because of the flat nature of the lakebed it was perfect for speed tests. Effectively,
because of its extremely extensive and flat surface, ground speed experiments could be
conducted due to ample room for error. Muroc Dry Lake was eventually selected for nomination
!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
117
Robert Johnstone, National Historic Landmark Nomination: Muroc Dry Lake, Edwards AFB, Prepared: January
16, 1986, 2.
118
Ibid., 3.
57
!
to the National Register because of its unique landscape qualities and significance with
“Aeronautical Research and Space Exploration.”
119

Figure 2.4: Roger’s Dry Lake, formerly Muroc Dry Lake. Source: Goggle Maps edited by Author

Preservation Air Force
These three historic preservation designations show the approximate temporal and geographic
range of the Air Force domestic facilities. From a larger perspective it provides a context to a
distinct framework for preservation.

!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
119
Ibid.
58
!
2.5 Conclusion
A Framework for Preservation
In essence, DoD Directive 4710.1 laid out the preservation responsibilities for each individual
military branch essentially illustrating the expansive size of the entire program. US departments
such as the Department of Transportation often are more readily associated with environmental
and preservation issues because they serve the public. The DoD, however, is a federal
organization that conducts its mission and reaches its goals behind protective gates. The lack of
transparency is one of the major factors why the military have always been put into question, in
terms of historic preservation. The federal undertakings conducted within the military are no
different than those undergone on Main Street.

In the military, preservation programs provide context of what can potentially be lost if cultural
resources are not properly accounted. The military’s main focus is usually centered on the ability
to conduct war, or more specifically the achievement of the mission that is geared to winning
war. With the onset of preservation programs the evaluation and consultation process creates a
vetting system to account for historic properties before demolition. This fundamental
understanding of preservation programs falls perfectly in line with military accountability values.

This chapter presented an overarching context that breaks through the general belief of non-
transparency within the military. The USAF history, culture of “newness,” and military/USAF
traditions found within its context establish a culture that questions whether or not historic
preservation can exist and thrive in the military and USAF. However, despite these questions
three strong examples of extant historic preservation were presented that illustrate precedent.

59
!
Chapter 3: Edwards AFB: A Case Study

Introduction
This chapter will introduce Edwards AFB, and in doing so, show how the base has fallen prey to
the haphazard approach of preservation on Air Force bases. Edwards AFB is an excellent
example of a preservation ready military location with its rich history and tremendous heritage
resources.

3.1 Background of Edwards AFB
Dry Lake and Muroc
The formation of the area and dry lakebed now encompassing Edwards AFB began more than
one million years ago in the Pleistocene Epoch. The last climate and geological inflexion
resulted in the extant prehistoric pluvial lake to dehydrate. What remained was a massive
geological feature unlike anything else in the world. Rogers Dry Lake, formerly Rodriquez Dry
Lake, is in the Mojave Desert and more specifically the Antelope Valley. The Antelope Valley is
situated at an elevation of “about 2300 feet and has a typical sunny desert climate with moderate
temperature, low humidity, and an average rainfall of about 7 inches.”
120
The General Mining
Law of 1872 began the influx of population to the area establishing settlements specifically
interested in mining.
121

This influx also included families, particularly the Corum family. The Corum family established
a settlement alongside the dry lakebed as a train station and water stop in the early 1900’s. The
Santa Fe railroad owned the railway until 1953 during which Muroc Station was establishment as
the right of way bisected the dry lake.
122
The family was denied the name Corum because there
already was a town called Coram, California for which the California registration authority felt
!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
120
Mike Gruntman, Blazing the Trail: The Early History of Spacecraft and Rocketry. (Reston, VA: American
Institute of Aeronautics and Astronautics, Inc., 2004), 14.
121
National Park Service, History and Culture, http://www.nps.gov/moja/learn/historyculture/index.htm, accessed
on June, 20 2014.
122
Ibid.
60
!
was too similar. Consequently, the family reversed their name christening the town of Muroc.
123

They instituted a general store and post office to service the local area. In 1912, the store of the
town was converted into the first schoolhouse. The town of Muroc was the civil and cultural
center of the dry lake area until the military broadened its operational base and removed the area
from public use.

Military at Rogers Dry Lake
Lieutenant Colonel H. H. “Hap” Arnold, while stationed at March Field near Riverside
California, discovered the Muroc Dry Lake and established it as the new bombing and gunnery
range for his squadron.
124
The bombing and gunnery range established in 1933 were humble
campsites on the east shore of the dry lake.
125
The location became known as the “Muroc
Bombing and Gunnery Range” and the 1
st
Wing from March Field began active flight activities
there in 1936.
126
The use of the range continued during WWII. After WWII, the mission for
Rogers Dry Lake expanded to testing the new age fighter jets, so “Muroc Bombing and Gunnery
Range became Muroc Air Base and chief contestant for the title of airspeed center of the
nation.”
127
As outlined above the dry lakebed has been associated with various names, the titles
of Rodriquez, Rogers, and Muroc have all been used interchangeably or wrongly applied to what
we now know as Rogers Dry Lakebed.

In keeping with the US Air Force’s tradition of naming air force bases after military members
with local connection, Edwards AFB was named after Captain Glen W. Edwards (Figure 4.1).
Captain Edwards died in a training mission over Murdoc Air Force Base. On June 5, 1948,
Captain Edwards departed on a mission in a “Northrop YB-49 flying wing bomber.”
128
What
happened in the air is unknown, but the YB-49 plummeted to the ground resulting in a fatal
crash. The Air Force crash investigation resulted with the explanation that Edwards “ran into
!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
123
David L. Durham, California's Geographic Names: A Gazetteer of Historic and Modern Names of the State,
(Clovis, CA: Word Dancer Press, 1998), 1079.
124
Edwards Air Force Base, Edwards’ History, http://www.edwards.af.mil/library/factsheets/factsheet.asp?id=10346,
accessed on May 15, 2014.
125
Storrs W. Lee, The Great California Deserts. (New York: Putnam Publishing, 1963), 267.
126
Peebles, 8.
127
Lee, 267.
128
George J. Marrett, Contrails Over the Mojave: The Golden Age of Jet Flight Testing at Edwards Air Force Base.
(Annapolis, MD: Naval Institute Press, 2014), 7.
61
!
difficulties in the air.” With this tragedy, the Air Force renamed Muroc Air Force Base to
Edwards Air Force Base.
129

Figure 3.1: Captain Glen W. Edwards, the namesake of Edwards AFB, Source: Photograph of painting by Author.
!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
129
Lee, 268.
62
!

Highway 58 borders Edwards AFB from the north and the city of Lancaster borders the base
from the south. The western and eastern borders of Edwards AFB are the towns of Rosamond
and the town of Boron, respectively (Figure 3.2). The large landmass of Edwards AFB allows for
various unique types of test and evaluation. In total, the base encompasses 301,209 acres making
it the second largest base within the Air Force.
130
The two lakebeds, Rogers and Rosemond,
provide a unique environment for air operations. The lakebeds are dry ten months out of the year,
however when it does rain and the lakebeds are covered with a few inches of water the
combination of the wind and the water smoothens the surface of the lakebed.
131
This results in a
hard crust that can withstand 250 pounds of pressure per square inch.
132
This ultimately allowed
for the “world’s longest runway—a paved strip stretching out for 15,000 feet and continuing on
across hard-packed Rogers Dry Lake for 15 miles or more.”
133

Figure 3.2: Fence and property line at Edwards AFB. Source: Google Earth, Edited by Author.

!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
130
Storrs W. Lee, The Great California Deserts. (New York: Putnam Publishing, 1963), 265.
131
Ibid.
132
Ibid.
133
Ibid.
63
!
Because of these special attributes of the dry lakebeds, our special military missions soon came
to this location. The Power Plant Laboratory had already been established in Wright Field, Ohio
in 1939.
134
At this laboratory new technology was tested and evaluated for full military use.
However, by 1947 a new site was selected at the Luehman Ridge near Rogers Dry Lake as its
new Experimental Rocket Engine Test Station.
135
The contract to begin building at the ridge site
began in April of that same year.
136
The “granite ridge” at the edge of the dry lake became
known as “the team on the ridge.”
137

Aircraft activities also found an interest in the Mojave high desert as the Army Air Corps test
came to Muroc. Later, the Experimental Test Pilot School developed. The school’s mission was
to train pilots to test “the planes and spaceships of the future. Every eight months a new class of
16 hand-picked pilots graduated from the Experimental Test Pilot School operated by the
base.”
138
The test pilot school is significant because it helped create an environment where
advances in avionics were being made on a daily basis. This is just one of the numerous “firsts”
that occurred in avionic history at Edwards AFB.

There have been hundreds of significant aviation "firsts" accomplished at Edwards AFB.
Although only a few have been highlighted, to name them all would be an exhaustive task.
Notably, however, this is where Capt. Chuck Yeager and the Bell X-1 first broke the sound
barrier on Oct. 14, 1947, and where other X-planes pushed that record to two, three, four, five
and six times the speed of sound and beyond. It is also here that the X-15 probed the threshold of
space and where the space shuttle first landed on its initial return from an orbital mission.

The following are the highlights of avionic “firsts” as detailed in Walter Boyne’s book, Beyond
the Wild Blue: A History of the U.S. Air Force 1947-1997 and Storrs Lee’s book, The Great
California Deserts.

!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
134
Air Force Rocket Propulsion Laboratory (U.S.) Edwards Air Force Base, Calif., U.S. Air Force Systems
Command, (The United States Air Force Rocket Propulsion Laboratory: National Government Publication, 1986), 2.
135
Ibid.
136
Ibid.
137
Rocket Propulsion, 3.
138
Storrs W. Lee, The Great California Deserts. (New York: Putnam Publishing, 1963), 271.
64
!
• October 1, 1942: Bob Stanley; XP-59A, First turbojet airplane when wheels lift off ground
• January 8, 1944: Lockheed XP-80, First American aircraft exceeding 500 mph
• February 28, 1946: Major William Lien; Republic XP-84, First postwar fighter
• October 1, 1947: George S. “Wheaties” Welch, XP-86 Sabre, First swept-wing fighter
• October 14, 1947: Captain Charles E. Yeager, Bell XS-1, First supersonic flight
• August 16, 1948: Fred C. Brethcher, XF-89 Scorpion, All-weather interceptor
• December 16, 1948: Charles Tucker, X-4 Bantam, First flight swept-wing aircraft
• September 15, 1948: Major Richard L. Johnson, F-86, Recaptures speed record (670 mph)
• May 9, 1949: Carl Bellinger, XF-91 Thundercepter, First flight jet/rocket hybrid
• June 20, 1951: Jean Skip Ziegler, Bell X-5, First flight of variable-sweep wings aircraft
• August 18, 1951: Colonel Keith Compton, F-86A Sabre, Wins first USAF jets-only race

While these advancements in avionics and jet propulsion were technically flying, based they also
provided a transition to the frontier of space. The jet propulsion age at Edwards AFB came about
because of a shift in our national goals. When the Rocket Propulsion Laboratory first came to
Edwards AFB, its role was to test the BOMARC engine from Aerojet Engineering Corporation,
which would eventually “booster Atlas missiles and Thor missiles.”
139
As testing advanced more
facilities were built, and "captive testing" of Atlas, Thor, and other missile propulsion systems,
continued through the 1950s.
140
It is said that, “every Air Force rocket-propelled missile, booster,
and spacecraft contains technology developed at the Lab.”
141
This was rightly so, as the solitude
of the base allowed for extensive facilities and thus capabilities. The fabrication facilities also
were so extensive they were “able to meet a wide variety of needs.”
142

The extensive capability of the base was in large part due to international competition with the
Soviet Union. The advances in avionics culminated in jets, and jets resulted in larger propulsion,
and propulsion, in turn, brought the United States into space and missiles. The “shock of
Sputnik’s launch” brought new focus to the tests already being conducted at Edwards AFB. The
new focus provided a new vision and priority, and new requirements for success. After Sputnik,
it just became “easier to get funding to do what people already knew needed to be done.”
143

!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
139
Mike Gruntman, Blazing the Trail: The Early History of Spacecraft and Rocketry. (Reston, VA: American
Institute of Aeronautics and Astronautics, Inc., 2004), 3.!
140
Ibid.
141
Ibid.
142
Ibid, 13.
143
Macinnis, 209.
65
!
Notable Persons
In addition to projects at Edwards AFB, as one might imagine there were also notable personnel
at the base. The following are two strategically chosen individuals that illustrate this point.
Charles E. “Chuck” Yeager and Dr. John Paul Stapp. The former is the most illustrious test pilot
in USAF history, and the latter is the most underappreciated medical doctor who revolutionized
automotive safety. Both these individuals accomplished feats that continue to impact society to
this day.

Chuck Yeager began his military flying career in WWII flying missions over Germany. After
being shot down, getting captured, escaping and aiding others to escape, he was awarded a
Bronze Star. Later in the war after shooting down the requisite five enemy aircraft, he became a
military “Ace” by war’s end.
144
After WWII he was assigned to the Aeronautical Systems Flight
Test Division and was eventually transferred to the Muroc Army Air Field. His flying talent was
obviously noticed as he was chosen to be the first to fly the Bell X-1 at supersonic speeds. On
October 14, 1947 Yeager became the first man to break the sound barrier by flying at a speed of
Mach 1.07.
145
History was in the cards for Yeager, as even broken ribs and resulting pain could
not deter him from this day in the record books. The pain was said to be so excruciating he could
not even close the hatch to the cockpit himself, yet despite this, he goes down in history as the
first man to break the sound barrier.
146

!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
144
Edwards Air Force Base, Edwards’ History, http://www.edwards.af.mil/library/factsheets/factsheet.asp?id=10346,
accessed on May 15, 2014.
145
Manfred Von Ehrenfried, Stratonauts: Pioneers Venturing into the Stratosphere, (Chichester, UK: Springer
Praxis Publishing, 2014), 167.
146
Edwards Air Force Base Home Page, Fact Sheet: 412
th
Test Wing, http://www.edwards.af.mil/library/factsheet,
accessed on May, 15 2014.
66
!

Figure 3.3: The statue of Charles E. “Chuck” Yeager at the corner of N. Rosamond Blvd. and Yeager Blvd. on
Edwards AFB. Source: Photograph taken by Author.

John Paul Stapp was a medical doctor who was intrigued with the physiological effects of
velocity. Dr. Stapp’s connection to Edwards AFB is that his first sled track test took place, in
what was then Muroc AFB. The 2,000-foot long track at first tested with dummies; however,
after increased trials and velocities, with the addition of rockets, Dr. Stapp placed himself in the
sled seat. The tests were extreme, as “Stapp could accelerate down the length of the track to near
crash speeds. A series of 45 clasping pairs of brake surfaces would stop the sled at the end of the
track, mimicking what a pilot would experience when crashing at high speeds.”
147
The results of
!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
147
Amy S. Teitel, “John Paul Stapp: A Real Life Rocket (Sled) Man,” posted September 26, 2014,
http://www.popsci.com/blog-network/vintage-space/john-paul-stapp-real-life-rocket-sled-man, accessed on
December 12, 2014.
67
!
Dr. Stapp’s research concluded in the creation of airplane seats orientated in the “backwards”
position as he found it to be much safer in aircraft crashes. Also, resulting from his research is
the sidesaddle, or triangular, seat belts found in most all modern cars. Dr. Stapp is credited with
the inventor of Murphy’s Law: If anything can go wrong, it will.
148
In all, Dr. Stapp can be
credited in revolutionizing aviation and automotive safety restraints.

Edwards AFB History
This brief overview of the history of Edwards AFB was provided to demonstrate the existing
historic preservation potential the base holds. Yet, history alone is not the only qualification in
historic preservation. The connection to buildings and landscapes must be established in a
manner sufficient to the directions of the Secretary of the Interior. The built environment
connected to this history still exists in adequate proportions. What arises next are the cultural and
organizational norms existing from an organization new to the concept of historic preservation.
The next section discusses the areas where such norms exist.

3.2 Areas of opportunity when establishing a preservation program
In terms of preservation, Edwards AFB has many areas of opportunity to establish a robust
program. The mission of Edwards Air Force Base is unique in that it is a testing and evaluation
Air Force base. Most Air Force bases do not have such a mission. What this translates to in terms
of historic preservation is that most bases do not have to deal with the continual change of its
mission. Most Air Force bases have a singular and significant combat mission that establishes
the definition of the base’s activities. For example, if a base has F-16 aircrafts, it will have only
that aircraft for a significant period of time (thirty to sixty years). This results in little to no
change in support functions for the aircrafts. These support functions are the organizations within
the base aiding the flying of the aircraft, in this case F-16s. These organizations require the use
of facilities and buildings, such as in administration, support, and operations. Edwards AFB, on
the other hand, tests weapons systems new to the Air Force. While a weapon system can stay at
Edwards AFB for twenty years it can routinely be moved to make room for the Air Force’s
!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
148
Douglas Martin, “John Paul Stapp, 89, Is Dead; ‘The Fastest Man on Earth.’” The New York Times, New York,
November 16, 1999.
68
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newest weapon system, uniquely falling inline with the obligation of a federal undertaking as
defined by the NHPA. Such a move to make way for a new weapons system creates a domino
effect of undertakings along the flight. Each organizational move (the weapon system moving in
and the weapon system moving out) will require a NHPA section 106 review.

With the above understanding of Edwards AFB, the research of this case study has identified six
areas of opportunity specific to historic preservation. While taking into account the base’s
mission, the following are areas that provide fortuity in historic preservation at Edwards AFB.

The History of Flux in Base Historic Preservation Officer
When discussing the most pressing issues with the then Base Historic Preservation Officer
(BHPO), Tony Chapa, he felt the largest challenge with respect to preservation was found simply
in consistency of the BHPO position. Within a span of seven years the position had turned over
four times.
149
The reasons for the turnover all were all specific to the situation--some moved on
due to professional opportunities while others moved on for personal reasons. The consequence
of this high turnover resulted in a lack of institutional knowledge and an outward appearance of a
lack of responsibility.

At the time of with writing, the USAF would be hard pressed to hire a Historic Preservationist,
Architectural Historian, due to a simple lack of understanding of requirements. The Secretary of
Interior’s Historic Preservation Professional Qualification Standards, found in 36 CFR Part 61
Appendix A, specifically states requirements for History, Archeology, Architectural History,
Architecture, and Historic Architecture.
150
The Architectural Historian portion specifically
allows a degree in “historic preservation or closely related field...” This loose requirement is
more than likely the reason why organizations in the USAF focus on hiring archeologist and
fulfill historic preservation requirement through subcontractors. The loose wording of “closely
related field” as resulted in a lessened priority. With stronger wording specifically asking for
historic preservation graduates could result in the USAF actively recruiting historic
!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
149
Chapa, Tony. Interview with Tony Chapa, Edwards AFB Base Historic Preservation Officer, interview conducted
on October 8, 2013.
150
National Parks Service, Archeology and Historic Preservation: Secretary of the Interior’s Standards and
Guidelines, https://www.nps.gov/history/local-law/arch_stnds, accessed on May 16, 2014.
69
!
preservationist similar to the way they actively recruit archeologist. As in any job in the military,
the more institutional knowledge through consistent staffing (and less turnover), the more the
program has the opportunity to thrive and succeed.

The Air Force’s Archeological / Single Skilled Preservation Section
The cultural resource offices on military bases have long been focused from the perspective of
archeology. This single skilled preservation focus section or office limits the knowledge of
historic preservation and the responsibilities associated with the discipline as outlined by the
Secretary of the Interior.

The two best examples of Edwards AFB’s archeological inclination can be found in the base’s
environmental management documents: Programmatic Agreement between the United States Air
Force and the California State Historic Preservation Officer Regarding Implementation of the
Air Force Flight Test Center Mission and the Integrated Cultural Resources Management Plan
at Edwards Air Force Base, California and the Integrated Cultural Resources Management Plan
for Edwards Air Force Base, California. These two documents, while both charged with the
responsibility of both archeology and historic preservation, are structured in a manner organized
that lends itself to an emphasis on archeology.

These documents intrinsically are riddled with limitations as both documents fall under (or very
close to) the military For Official Use Only (FOUO) protocol. This limits the nature of
specificity within the documents. However, this thesis only requires ordinary knowledge of the
structure of the two documents to demonstrate the archeological inclination. The Programmatic
Agreement (PA) is a legal document containing stipulations for which the State Historic
Preservation Office (SHPO) and Edward AFB are to adhere to throughout the duration of the
agreement. The PA contains ninety-seven stipulations and sub-stipulations. The breakdown of
the stipulation subject matter illustrates how the PA is inclined to archeology. Of the ninety-
seven stipulations and sub-stipulations fifty-four are administrative in nature and can be applied
neutrally to both archeology and historic preservation. The remaining forty-three stipulations
have a predisposition in favor of archeology resulting in a total of thirty-eight stipulations related
to archeology and five stipulations specific to historic preservation. This is a percentage
70
!
difference of thirty-nine percent archeology to five percent historic preservation.
151
Percentage
differential may not seem to outright exclaim the bias being explained, however, in most areas
where archeological stipulation was directly addressed one could argue both archeological and
historic preservation issues could have been covered. Case in point, when discussing procedures
for “National Register of Historic Placed Eligibility Evaluation” the direction was for
specifically nominating archeological sites; even though the same process could apply to historic
preservation properties as well.
152

The Integrated Cultural Resource Management Plan (ICRMP) is similar in its propensity towards
archeology. The ICRMP is not a legal document like the PA. Thus, an alternative method of
showing the tendency toward archeology is through subject matter volume. The breakdown of
the pages devoted to particular subject matter illustrates how the ICRMP is also skewed toward
archeology. Of the one hundred and sixty-one pages in the ICRMP, eighty-eight are
administrative in nature or they provide natural and historical context for Edwards AFB. The
remaining seventy-three pages of the ICRMP are archeology-skewed for a total of seventy
archeology content filled pages to three historic preservation content filled pages. This is a
percentage difference of forty-three percent archeology to two percent historic preservation.
153

The difference in pages committed to archeology in the Edwards AFB’s ICRMP is so
overwhelmingly unbalanced it gives a good indication of its disposition toward archeology.

Another reason why a more balanced approach is needed is a result of the DoD over-arching
change to local military command structure: Joint Base re-organizations. This re-organization to
a Joint Base, is occurring in locations in the continental United States where multiple military
installations are in a working vicinity to have operational commands join resources and be
unified under one overall commander. This joint mentality can be easily applied to archeology
and historic preservation. In most Joint Base locations the decisions on the structure of the
preservation office has not yet been decided. However, it is logical to infer the preference the
!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
151
Programmatic Agreement between the United States Air Force and the California State Historic Preservation
Officer Regarding Implementation of the Air Force Flight Test Center Mission and the Integrated Cultural
Resources Management Plan at Edwards Air Force Base, California. Dated and signed 2009.
152
Ibid.!
153
Integrated Cultural Resources Management Plan for Edwards Air Force Base, California, 95
th
Air Base Wing,
Civil Engineer Directorate, Environmental Management Division, Edwards Air Force Base, California. Dated
January 2012.
71
!
military community takes with preservation will mimic that of the overall operation of the Joint
Base. With preservation the idea seems straightforward to have one office governing all heritage
resources managed under one roof. Yet, the number of cultural resource personnel is the key.
The consolidation of resources will require more personnel and yet still present an opportunity
for reducing redundancy and maximizing efficiencies in the new “super” preservation offices’
operations. This paper puts forward that anything less than a two-person cultural resource
preservation staff is false economy and will cost the military more in the long run due to time
lost and possibly monetary fines.

Edwards AFB is an excellent example of historic preservation opportunities found with joint
base. Edwards AFB is a large base, roughly the size of Joint Base San Antonio, including the city
of San Antonio, TX.
154
If a project requires the on-site visit of a building or archeological site on
the far side of Edwards AFB base, the travel to the location can take the better part of three
hours. In many cases when reviewing resources on the eastern edge of Edwards AFB the travel
to the location would require leaving the base getting on highway 58 then re-entering the base
closer to the eastern edge of the base. This is similar to the preservation personnel at Joint Base
San Antonio, with offices currently at Fort Sam Houston, having to cross the city of San Antonio
and travel sixteen miles to Lackland AFB to review a cultural resource. This access to cultural
resources is simply an occupational requirement. A one-person staff responsible for all aspects of
cultural resources management (historic preservation and archeology) would be highly tasked
when considering travel, number of resources, and administrative requirements.

If the Cultural Resources office could command a structure that allows the office to posses
various skills this multi-skilled office could satisfy the needs of preservation (a more balanced
approach) and distribution of workload. The quicker the Air Force, and DoD for that matter,
understands the need for multi-skilled cultural resource management staff, the quicker the
military community will have a handle on historic preservation concerns.

!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
154
Note: Joint Base San Antonio consists of four installations: Randolph AFB, on the northeast side; Fort Sam
Houston, in the central eastern side; Lackland AFB, on the southwest side; and Camp Bullis, on the far northwest
side.!!!
72
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Foster a Historic Preservation Conscious Culture
As detailed throughout the text above, the Air Force is not very conscious of historic
preservation outside of the federal compliance requirements.
155
What this means is that the
environmental management section at every base, to include Edwards AFB, is the primary and
usually only section concerned with historic preservation. As the Edwards AFB BHPO stated,
“the Air Force’s main mission is flying and if it ever thinks of preservation, it first thinks
archeology. As it stands now historic preservation is not a conscious thought in the minds of
today’s USAF Airmen.”

Community Advocacy Projects and Programs
The cultural resource management program at Edwards AFB does not currently have
programmatic community advocacy projects or programs to endorse historic preservation on a
consistent basis. The current extent of advocacy is the production of “pamphlets as a result of
SHPO consultation.”
156
Consequently, rather than constituting organic programmatic projects for
holistic reasons, advocacy efforts are the result of consultation with the State Historic
Preservation Office (SHPO) to gain favor and appease the SHPO. Despite the status quo, “there
are numerous groups such as the local Air Force Association that would champion historic
preservation causes.”
157

The bottom line is that historic preservation within the military is no different than historic
preservation on Main Street, and just like Main Street, advocacy is the responsibility of
preservationists everywhere, even those working on military bases.

Air Force Wide Preservation Assessment Project
Many of the issues concerning historic preservation within the Air Force are universal across the
entire military and not just isolated to a single base. In an effort to bridge gaps, the Advisory
Council on Historic Preservation (ACHP) routinely provides Program Comments based on its
evaluation of general building types and consequently established eligibility, to certain building
!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
155
Chapa, Tony. Interview with Tony Chapa, Edwards AFB Base Historic Preservation Officer, interview conducted
on October 8, 2013.
156
Ibid.
157
Ibid.
73
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types, across the board.
158
The ACHP’s work, while worthwhile, does not reach many of the
USAF’s most pressing issues such as flight-line areas. Consequently, the Air Force should take
on this void itself.

Annual CRM Conference
Before 2010 the Air Force had annual Air Force wide cultural resource management conferences
to discuss the state of the USAF’s cultural resource management program. For some reason, the
conferences ceased, leaving a void in communication concerning archeology and historic
preservation. When the conferences were conducted, the entire USAF’s data concerning cultural
resource management was presented.
159
This provided each base with helpful insight of the entire
cultural resource management program to compare. It also fostered the communication of best
practices for those individual programs needing support. Based on the benefits of knowledge
sharing and the current void, the USAF needs to reinstate CRM conferences to advance the entire
cultural resource management program at a steady pace.

3.3 Conclusion
This glance at Edwards AFB’s military history throughout the span of its existence was provided
to demonstrate the base’s importance to the nation. The dry lakebed and the expansive acreage
made it an aviation-friendly environment. The environment along with a desire to achieve goals
literally out of this world is what makes Edwards AFB so unique. When the Space Shuttle
Columbia landed on Rogers Dry Lake, it was the first “orbiting space vehicle ever to leave the
Earth under rocket power and return on the wings of an aircraft.”
160
There is no doubt that the
fact it occurred at Edwards AFB was symbolic of the significance and advances made at the
base.

!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
158
Advisory Council on Historic Preservation, Program Comment for World War II and Cold War (1939 – 1974)
Army Ammunition Production Facilities and Plants, (Washington DC: ACHP, 2006).
159
Lt. Col. Douglas Burkett, USAF, Headquarter Air Force Conservation, AF/A7CVQ, (Washington DC,
Pentagon, 2007).
160
Edwards Air Force Base, Edwards’ History, http://www.edwards.af.mil/library/factsheets/factsheet.asp?id=10346,
accessed on May 15, 2014.
74
!
Edwards AFB has been the center of the aeronautical testing universe before the inception of the
US Air Force. History has highlighted Edwards AFB’s uniqueness given that it was the location
where the sound barrier was broken and where the fastest manned aircraft reached the speed of
Mach 6.72. These records definitely solidify Edward AFB’s historical prowess and possibly
historic preservation significance. However, the point must be emphasized in this chapter that the
current mission at Edwards AFB is also driven by traditions. These are traditions that, at first
glance, may not seem to support initiatives such as historic preservation.

Edwards AFB continues to lay the groundwork for additional “historical-first” by being the test
center of tomorrow’s weapon systems. As of the time of this writing, Edwards AFB is testing the
F-35 Joint Strike Fighter, which is pushing the envelope on air-to-ground attack technology.
Edwards AFB is also the home of the F-22 “Raptor” testing. The F-22 is utilizing the avant-
garde of “stealth, super-cruise, maneuverability and integrated avionics…”
161
This technology
will take the Air Force into the next century.

Outside conventional avionics, Edwards also test and evaluates various versions of un-manned
aircraft. One such weapon system is the RQ-4A Global Hawk Unmanned Combat Aerial System.
This system is revolutionizing battlefield status information provided to frontline commanders
by furnishing “near real-time, high-resolution intelligence, surveillance and reconnaissance
imagery.”
162
In short, tomorrow’s technology and capabilities are being tested at Edwards AFB,
a base rich with history and tradition. The hope is that all of these mission and characteristics of
the base can all to co-exist.

!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
161
Edwards Air Force Base Home Page, Fact Sheet: 412
th
Test Wing, http://www.edwards.af.mil/library/factsheet,
accessed on May, 15 2014.
162
Ibid.
75
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Chapter 4: Recommendations

Introduction
The following chapter provides recommendations based on the Edwards AFB case study and
other prominent areas ripe for consideration within the military preservation community. These
recommendations range from ready-to-implement actions to long-term future goals related to
military preservation. The recommendations are the areas where federal mandates and traditions
can better consolidate their efforts to produce a preservation conscious Air Force. The
recommendations goals below are the result of the research and case study found in this thesis.

4.1 Administrative Change
Hire Historic Preservationist
The USAF should create a position, which requires a degree in historic preservation and or
heritage conservation. A first step in addressing the issues with the preservation of Air Force is
to hire historic preservationists. This call does not imply a hold in hiring archaeological
personnel for the needed installations. This call would more specifically ask for an addition to
the skill set found in preservation offices in Air Force. The office would be a multidisciplinary
structured unit, to allow all aspects of CRM to be properly addressed. Thus, this recommendation
is to make the necessary administrative changes for enhancing and adding historic preservation
to the CRM office so as to fully realize the requirements of the Secretary of the Interior.

Consistency in Base Historic Preservation Officer
The solution to curing the inconsistency within the Edwards AFB BHPO is to develop a multi-
faceted team of preservationists. Specifically having two BHPOs with one concentrating on
Architecture and the other on Archeology would create consistency within the CRM program
and office of the BHPO. First it creates team concepts which helps solidify and reach program
goals. Second it will afford some coverage if positions, for whatever particular reason, are
vacated. This second reason also aids the program's consistency.

76
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4.2 Conscious Multi-Skilled Military Preservation Units/Section.
As discussed earlier, the SHPOs are generally structured in a way that allows them to review
Archeology and Architectural preservation issues. This recommendation strives to develop an
“office” that is reflective or corresponds to respective state SHPOs. Edwards AFB’s Cultural
Resources section is striving for this tactic. Cultural Resources section employs both an
archeologist and an architectural historian; both positions are identified as a Base Historic
Preservation Officer (BHPO), however one is responsible for archeology and the other
architecture (or buildings).

Joint Bases: Its impact
Another reason why a change is needed is a result of the DoD change to local military command
structure: Joint Base re-organizations. These re-organizations are locations in the continental
United States where multiple military installations in working vicinity are combined to have
operational commands and be unified under one overall commander. This joint mentality can be
easily applied to historic preservation and archeology. In most joint base locations the decisions
on the structure of the preservation office has not been decided. However, it is logical to infer
military leadership will simply relegate the all responsibilities to a single condensed cultural
resource office. The idea seems straightforward: one office governing all heritage resources
managed under one roof. This is where this paper believes there is opportunity. If requirements
are voiced in this period of decision-making, the cultural resource office could result in having
the qualifications required by the Secretary of the Interior. The consolidation of resources will
require more personnel and yet still present an opportunity for reducing redundancy and
maximizing efficiencies in the new “super” preservation offices’ operations. As discussed in the
previous chapter, the number of resources a singular joint base preservation office will have to
govern will instantly increase with joint base. This recommendation does not have an issue with
a singular preservation office within the joint base structure. It simply recommends the singular
office possess all the qualifications to properly fulfill its preservation responsibilities.

Further, this recommendation argues against the trappings of false economy by believing one
person (the possible result from the fiscal goals of joint base concept) can successfully maintain
the workload of what was previously the responsibility of multiple cultural resource offices. The
77
!
false economy comes in time and funds lost due to ties to civil engineering fund commitment
dates. If funds are not committed by a certain date project funds could be lost. This relates to the
cultural resource office because if NHPA section 106 process cannot be conducted in a timely
manner, the project cannot proceed.

4.3 Foster a Heritage Conservation Culture
This recommendation recognizes that the BHPO is usually the only individual holding a Historic
Preservation or Heritage Conservation degree and thus is rightfully charged with cultivating a
heritage conservation “culture” throughout the base. This, while seemingly obvious, is a point to
be made in that many times the day-to-day requirement of such a position takes focus away from
such fundamental duties for actively developing a heritage culture. By stating this as a
recommendation, and possible future requirement, it puts forward the obligations all
preservations take on and thus introduces the idea of a military requirement to actively be
stewards of our nation’s military heritage by aggressively fostering a heritage conservation
culture.

Both the USAF and the community of historic preservation place high value on traditions. In the
USAF traditions are what keep the warrior spirit alive for the airmen. Be it traditions passed
down from the army or ones created after their independence from older military service. In the
civilian world historic preservationist are the grass-root voice for remembering tradition, culture
and heritage. This recommendation is a reminder that both institutions have the same goal they
have just simply have different organizational origins. The opportunity here can be found in the
role of traditions fostering a historic preservation ethic.

4.4 Community Advocacy Projects and Programs
This recommendation is a tactical application of the development of a preservation culture. As
the community preservation community strongly advocates, repeated annual projects and
programs that promote local preservation missions are an excellent vehicle to fostering a
preservation rich culture. One, intra-base example may be a periodic architectural educational
78
!
session with the on-base school students, teaching them about architecture and possibly the types
of architecture found on base. Another, inter-base/community example may be periodic tours on
base facilities (possibly in conjunction with the base museum, where available) to allow local
residents the opportunity to view the structures and hear the history of the base in their respective
communities. Military bases are inherently a part of the community and the BHPO is in a
position to reinforce the importance of the heritage and historical significance within each base.

4.5 Air Force Wide Preservation Assessment Project
This recommendation is focused on clarifying the USAF’s assessment issue in large continental-
United States projects. Many of the Air Force’s installation issues with regard to preservation
deal with simply trying to catch up to the requirements set upon them by the National Historic
Preservation Act, and its section 106 processe. Since the USAF is obviously behind on assessing
assets, it is recommended to contract civilian architectural preservationists to assess all structural
assets over fifty years of age on designated installations. The goal would be to designate eligible
structures by creating a definite illustration (for installation leaders and organizations) of where
historic properties reside on base. This recommendation, while large and costly, will place USAF
preservation on the right track for reaching compliance. This recommendation would require a
tangible goal such as one hundred percent evaluation by 2025.

4.6 Annual Military CRM Conferences
This specific recommendation is presented to develop and foster knowledge sharing within the
entire DoD’s preservation community. This recommendation seeks the implementation of both
an intra-service convention and an inter-service convention so that communication lines are
instituted for the health of the entire DoD Cultural Resources program. One proposal would be to
alternate from DoD gatherings once a year and a service branch convention (for example, Air
Force only) the other year. However, in each year these intra- or inter-service branch conventions
would occur six months prior to the National Preservation Conference so that any potentially
notable ideas can be presented at the national conference.

79
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4.7 Additional Recommendations
A Standardized PA Utilizing Qualified BHPOs as Local Military Advocates
This recommendation, as a result of the previous two, proposes the idea that qualified
preservationists are given the authority of full concurrence at the base (installation) level. Thus,
this recommendation solicits the creation of a Programmatic Agreement that allows a federally
employed individual holding a historic preservation degree in the post of BHPO the same
authority given to SHPO reviewers and alike. The position would be considered a military
extension of the SHPOs. This recommendation will help to streamline workload while ensuring
the health of the military’s heritage.

Future of Military Preservation Obligation
This recommendation recognizes that military preservation is such a unique community that it
should be obligated to continually present new methods for which to conduct preservation on
military installations. This can be done through papers and other professional platforms. The
point being, just as preservation is unique within different regions and programs, the military
environment can present some excellent lessons for the entire preservation community.
Therefore, when quality military programs are recognized, there is pathway or procedure for
communicating the significant programs to the civilian preservation community. The tactical
application of this recommendation would be to present such ideas at National Preservation
Conferences held each year.

4.8 Recommendation Conclusion
This assemblage of recommendations is not only the result of this thesis but also the indirect
result of the totality of requirements this thesis believes should be placed on military
preservationists and the subsequent cultural resources management programs. These
recommendations range from immediate implementation type programs to long-term activities
and philosophies. All in all, the intent was to highlight all that can be done in military
preservation, with a specific emphasis on what should be done as a preliminary baseline.

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Conclusion

This thesis provided a guide of the US military and USAF’s history and traditions with an
emphasis on applicability to historic preservation. The combination of federal mandates and
military traditions placed the USAF’s historic preservation program and cultural consciousness
into question. Specifically, the question was: Can the USAF, with its federal preservation
mandates, be a historic preservation conscious organization despite its military traditions?

What The Thesis Provided
This thesis provided a focused study into the question of whether federal mandates and military
traditions could co-exist to result in a historic preservation focused USAF. The USAF is an
organization conceived by the national military goal of air superiority. Now the USAF is
challenged with the goal of becoming a historic preservation focused organization. In short, this
thesis explored the Air Force’s aptitude for success in this endeavor.

This thesis provides an inside look at historic preservation on military installations by outlining
the federal mandates, extensive history, and distinguishing tradition of the military. The
numerous mandates and the historic events and people associated with the military establishment
provide the requisite support for preservation on military bases. This thesis provided an extensive
introduction and review to the mandates of the federal government. Further, this thesis illustrated
how the federal mandates manifested throughout the individual service branches. The
implication of this thesis is that the military is conducive to the objectives of the NHPA of 1966,
as amended.
163
The USAF, like all other service branches, possesses history that provides a
baseline for organizational significance and thus historic preservation. Lastly, the thesis exposes
the traditions that sustain the cultural in all services branches. Further, the thesis specifies the
traditions of USAF and those found supplementing the culture at Edwards AFB. The research
and evidence resulting from this thesis found the military as an organization with the propensity
for conducting a professional preservation program.

!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
163
Public Law 89-665; 16 U.S.C. 470 et. seq.
81
!
The bottom line is the military should no longer be thought of as a mystery organization, but
more of one with federal requirements to comply and abide by sound preservation values. The
military has long possessed strong values and that idiosyncrasy favors the survival and
flourishing of preservation. The case in point for the US Air Force is its Core Values.

A Perfect Preservation Organization
The United States Air Force grounds all it does on the basis of three core values: Integrity First,
Service Before Self, and Excellence in All We Do. Integrity First core value is directed to the
personal core value each individual Airman must maintain. It is the most important character
trait. Further it is described as a combination of several other moral traits, two of which are
Responsibility and Accountability. Having these two qualities make it difficult for the Air Force
and the Airman executing its values not to be inclined to historic preservation. Historic
preservation is the profession of taking responsibility for the heritage of our culture. Historic
preservation takes responsibility by holding its own grass roots organizations and charging others
with accountability of historic assets under their charge.

The second core value of the Air Force is Service Before Self. This core value is guided under
the principle that “An Airman’s professional duties always take precedence over personal
desires.”
164
Once again the similarities between the Air Force and historic preservation is
displayed. Historic preservation also is a profession where obligation and service takes priority
over individual interest.

The third and final core value of the Air Force is Excellence in All We Do. This is a call for
excellence in all endeavors undertaken. The depth and breath of this final core values covers
many facets. Two vital features of this core value are Community Excellence and Resource
Excellence. The Community Excellence sub-value is one that emphasizes maximizing
achievement through a synergy of effort by all constituents involved. In parallel, historic
preservation perpetually looks to achieve transparence through community involvement and
public buy-in on issues dealing with historic resources. The second sub-value, Resource
!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
164
United States Air Force, United States Air Force Core Values Pamphlet, Air Education and Training Command,
1997, http://www.e-publishing.af.mil/shared/media/document/AFD-070906-003.pdf., accessed on May 12, 2014.
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Excellence, mirrors historic preservation most directly. The value of Resource Excellence
stresses the implementation of policies to ensure the best possible “management of resources.”
165

In all the goals and mission statements local and state conservation organizations may have, they
all come down to the advocacy of resource management. These three examples of the coherence
between the values of historic preservation and that of the Air Force’s Core Values leaves little
doubt of the predisposition for preservation in the Air Force organization.

In conclusion, if the federal mandates and DoD programs do not establish the foundation for a
viable historic preservation force, the fundamental composition of the Air Force (outlined in its
core values) does possess the foundation to ensure a historic preservation rich culture. The
world’s greatest air force, in the same manner it possesses aeronautical excellence, can also
transform its values and culture to be the world’s greatest historic preservation force.

!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
165
United States Air Force, United States Air Force Core Values Pamphlet, Air Education and Training Command,
1997, http://www.e-publishing.af.mil/shared/media/document/AFD-070906-003.pdf., accessed on May 12, 2014.
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36 CFR, PART 800. Protection of Historic Properties. As amended effective August 5, 2004.

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APPENDIX A

Department of Defense Directive 4710.1
Archeological and Historic Resources Management

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Department of Defense
DIRECTIVE

NUMBER 4710.1
June 21, 1984

SUBJECT: Archeological and Historic Resources Management
ASD(MI&L)

References: (a) Section 470 et seq. of title 16, United States Code (Public Law
89-665, "National Historic Preservation Act," as amended)
(b) Section 469 et seq. of title 16, United States Code (Public Law
93-291, "Archeological and Historic Data Preservation Act," as
amended)
(c) Section 470 aa-ll of title 16, United States Code (Public Law 96-95,
"Archaeological Resources Protection Act of 1979")
(d) Executive Order 11593, "Protection and Enhancement of the Cultural
Environment," May 13, 1971
(e) DoD Directive 6050.1, "Environmental Effects in the United States of
DoD Actions," July 30, 1979
(f) through (h), see enclosure 1

1. PURPOSE

This Directive, under references (a) through (e), provides policy, prescribes procedures,
and assigns responsibilities for the management of archeological and historic resources
located in and on waters and lands under DoD control.

2. APPLICABILITY AND SCOPE

2.1. This Directive applies to the Office of the Secretary of Defense, the Military
Departments (including their National Guard and Reserve components), the Organization
of the Joint Chiefs of Staff, and the Defense Agencies (hereafter referred to
collectively as the "DoD Components").
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2.2. Its provisions apply only within the United States, the District of Columbia,
Puerto Rico, Guam, the Virgin Islands, American Samoa, the Commonwealth of the
Northern Mariana Islands, and the Trust Territory of the Pacific Islands.

2.3. Nothing contained herein or in implementing documents shall modify any
rights granted by treaty or otherwise to any Indian tribe or its members. At locations
other than those in paragraph 2.2., above, the DoD Components shall comply with
historic preservation requirements of the host country, international agreements, and
status-of-forces agreements as well as applicable portions of Federal law that govern
preservation management outside of the United States (reference (a)).

2.4. This Directive does not apply to the civil programs of the U.S. Army Corps of
Engineers.

3. DEFINITIONS

3.1. Advisory Council on Historic Preservation. The independent agency mandated
to advise the President and Federal Agencies regarding undertakings that may affect
properties listed or eligible for listing in the National Register of Historic Places.

3.2. National Register of Historic Places. The listing of districts, sites, buildings,
structures, and objects of national, State, or local significance in American history,
architecture, archeology, and culture that is maintained by the Secretary of the Interior.

3.3. Rehabilitation. Efforts and resources expended to maintain, repair, reproduce,
revitalize, or protect the significant characteristics that qualify a property for listing in
the National Register of Historic Places.

3.4. Significance or Significant. Those attributes or characteristics of a property
that qualify it as eligible for the National Register of Historic Places, as determined by
criteria in 36 CFR Parts 60 and 65 (references (f) and (g)). This term includes records
and remains related to such property.

3.5. State Historic Preservation Officer. The official, appointed pursuant to 16
U.S.C. 470a(b)(1) (reference (a)), who is responsible for administering the National
Historic Preservation Act within a State or jurisdiction.

3.6. Treatment. The way a historic property is maintained, repaired, used,
protected, excavated, documented, or altered.
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3.7. Undertaking. Any Federal, federally assisted, or federally licensed action,
activity, or program, or support of any non-Federal action, activity, or program,
including both new and continuing projects and activities.

4. POLICY

It is DoD policy to integrate the archeologic and historic preservation requirements of
applicable laws with the planning and management of activities under DoD control; to
minimize expenditures through judicious application of options available in complying
with applicable laws; and to encourage practical, economically feasible rehabilitation and
adaptive use of significant historical resources.

5. RESPONSIBILITIES

5.1. The Assistant Secretary of Defense (Manpower, Installations, and Logistics)
(ASD(MI&L)) shall:

5.1.1. Issue and monitor policy related to management of archeological and
historic resources on DoD properties.

5.1.2. Coordinate policies and programs among the DoD Components and
other Federal Agencies concerning archeological and historic resources on DoD
properties.

5.1.3. Assign responsibility to the appropriate DoD Component when more
than one DoD Component is involved in an archeological or historic resource
management issue.

5.1.4. Apply for exemption under 16 U.S.C. 470v (reference (a)) when
necessary.

5.2. The Heads of DoD Components shall:

5.2.1. Comply with the provisions of this Directive.

5.2.2. When required, communicate directly with and cooperate with the
Advisory Council on Historic Preservation, State historic preservation officers, and the
public regarding the effects of an undertaking on significant archeological and historic
properties.
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5.2.3. Designate an official who shall be responsible for matters pertaining to
this Directive.

5.2.4. Integrate historic preservation programs into land use plans and other
planning activities to reduce adverse effects on significant historic properties.

5.2.5. Program and budget for development and implementation of historic
preservation programs as necessary to comply with Pub. Ls. 89-665, 93-291, and 96-95;
E.O. 11593; and DoD Directive 6050.1 (references (a) through (e)).

5.3. The Secretaries of the Military Departments:

5.3.1. Shall implement an archeological and historic preservation program that
provides the resources, technical assistance, and qualified staff necessary to manage the
program effectively.

5.3.2. May establish an archeologic and historic preservation award program to
recognize outstanding historic properties management at installations under their
control.

5.3.3. Shall communicate directly with organizational elements of the
Department of the Interior on matters concerning nominations to and listings in the
National Register of Historic Places and rehabilitation or other treatment of listed
properties.

5.3.4. Shall maintain a list of significant archeological and historic properties
under their control and a record of the cost of rehabilitation or other treatment of those
properties.

5.3.5. Shall process applications for permits to excavate and remove
archeological resources from lands under their jurisdiction. Permits may be issued
with appropriate conditions in accordance with 43 CFR Part 7 (reference (h)).

6. PROCEDURES

6.1. Each DoD installation shall maintain a historic preservation plan (which may be
part of a more comprehensive planning document) that:

6.1.1. Identifies the likelihood, based on scientific studies, of the presence of
significant archeological and historic properties.
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6.1.2. Contains an inventory and evaluation of all known archeological and
historic properties.

6.1.3. Describes the strategies for complying with requirements of Pub. Ls.
89-665, 93-291, and 96-95 and E.O. 11593 (references (a) through (d)) and this
Directive.

6.1.4. Is developed in consonance with local, State, and other appropriate
Federal historic preservation programs.

6.2. In accordance with reference (a), the DoD Components shall consult with the
State historic preservation officer concerning effects of DoD undertakings on National
Register or eligible properties. If the State historic preservation officer or the DoD
Component determines that the undertaking may have an effect on such property, DoD
Components shall give the Advisory Council on Historic Preservation a reasonable
opportunity to comment in accordance with appropriate regulations. Specific program
decision points for such undertakings shall be provided to the Advisory Council and the
State historic preservation officer.

6.3. Moreover, the DoD Components shall:

6.3.1. Whenever economical, use historic properties available to them before
acquiring, constructing, or leasing buildings.

6.3.2. Locate, inventory, and nominate properties under their control that
appear to qualify for inclusion in the National Register of Historic Places, and ensure
that any such property that may qualify for inclusion is not inadvertently transferred,
sold, demolished, substantially altered, or allowed to deteriorate significantly.

6.3.3. Ensure that inadvertently discovered archeological and historic
resources are protected at the site of discovery whenever possible until cognizant
authorities have evaluated their significance.

6.3.4. Provide for the protection and storage of archeological and historic
properties and records that accrue as a result of a DoD Component's or installation's
historic preservation program.

6.3.5. Identify undertakings for which application for exemption from the
requirements of reference (a) may be made by the ASD(MI&L).
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6.4. The DoD Components are encouraged to enter into memoranda of agreement
with licensing agencies to assist in meeting the requirements of Section 106 of
reference (a).

6.5. Before disposing of significant historic properties that exceed DoD needs, the
DoD Component with responsibility for the property involved shall:

review.
6.5.1. Provide the disposal plans to the State historic preservation officer for

6.5.2. In accordance with appropriate regulations, give the Advisory Council
on Historic Preservation a reasonable opportunity to comment before proceeding with
the disposal action.

6.5.3. Execute a Memorandum of Agreement with the General Services
Administration (GSA), the State historic preservation officer, and the Advisory Council
on Historic Preservation if the disposal action will affect adversely the property. The
GSA is responsible for the conditions of property transfer.

6.6. Each Military Department shall designate an official who may sign and
transmit nominations to the National Register of Historic Places for that Military
Department.

6.7. The DoD Components shall ensure that monies requested for historic
rehabilitation or restoration of National Register or eligible properties are spent on the
historically significant characteristics of the structures. Rehabilitation for modern
amenities is not historic restoration.
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7. EFFECTIVE DATE AND IMPLEMENTATION

This Directive is effective immediately. Forward two copies of implementing
documents to the Assistant Secretary of Defense (Manpower, Installations, and
Logistics) within 150 days.

Enclosures - 1
E1. References, continued
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E1. ENCLOSURE
1
REFERENCES,
continued

(f) Department of the Interior Regulation, "National Register of Historic
Places" (36 CFR Part 60)
(g) Department of the Interior Regulation, "National Historic Landmarks
Program" (36 CFR Part 65)
(h) Department of the Interior Regulation, "Archaeological Resources
Protection Act of 1979; Uniform Regulations" (43 CFR Part 7)

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APPENDIX B

Army Regulation 200-4
Environmental Quality, Cultural Resource Management

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Army%Regulation%200–4!

Environmental Quality

Cultural
Resources
Management

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Headquarters Department of
the Army Washington, DC
1 October 1998
UNCLASSIFIED
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SUMMARY of CHANGE
AR 200–4
Cultural Resources Management
This new Army regulation--
(g) Reflects the transfer of responsibilities previously assigned to the
Assistant Chief of Engineers to the Assistant Chief of Staff for Installation
Management (para 1-5).

(h) Provides installation commanders greater authority for compliance with
cultural resources legal requirements (para 1-9).
(i) Reflects new emphasis on Native American affairs (paras 2-4, 2-5, and 2-8).
o Establishes new policy for preparation of and staffing procedures for
cultural resources compliance agreements (paras 3-1 and 3-3).

(j) Establishes new policy for Integrated Cultural Resources Management Plans
(para 4-1).
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Headquarters
Department of the Army
Washington, DC
1 October 1998
*Army Regulation 200–4

Effective 1 November 1998

Environmental Quality
Cultural Resources Management

History. This new regulation replaces AR
420-40, printed 15 April 1984.
Summary. This regulation updates the Ar-
my’s policy for managing cultural resources
to meet legal compliance requirements and to
support the military mission. Cultural re-
sources are: historic properties as defined in
the National Historic Preservation Act, cul-
tural items as defined in the Native American
Graves Protection and Repatriation Act, ar-
cheological resources as defined in the Ar-
cheological Resources Protection Act, sacred
sites as defined in Executive Order 13007 to
which access is provided under the American
Indian Religious Freedom Act, and collec-
tions as defined in 36 CFR 79, Curation of
Federally-Owned and -Administered Collec-
tions. Requirements set forth in the National
Environmental Policy Act of 1969 as
amended, National Historic Preservation Act,
Archeological Resources Protection Act, Na-
tive American Graves Protection and Repatri-
ation, American Indian Religious Freedom
Act, 36 CFR 79, Executive Order 13007, Ex-
ecutive Order 11593, and Presidential Memo-
randum on Government-to-Government
Relations with Native American Tribal Gov-
ernments, define the basis of the Army’s
compliance responsibilities for management
of cultural resources. Regulations applicable
to the Army’s management of cultural re-
sources include those promulgated by the
Advisory Council on Historic Preservation
and the National Park Service.
Applicability.
a. This regulation applies to the Active
Army, the Army National Guard of the
United States, the U.S. Army Reserve and to
all installations and activities under control of
the Department of the Army by ownership,
lease, license, public land withdrawal, or any
similar instrument. Specifically it applies
to—
8. Army installations and activities.
9. Army National Guard Federal installa-
tions, activities, and sites supported with
Federally appropriated funds or subject to
Federal approval.
10. Installations and activities, or
portions thereof, that are in full-time or
intermittent use by the U.S. Army Reserve or
Reserve Officer Training Corps.
11. Real property of other Federal,
State, and local agencies and private parties
used by the U.S. Army, U.S. Army Reserve,
or Re- serve Officers’ Training Corps under
license, permit, lease, or other land and or
facility use agreement.
12. Military functions of the U.S. Army
Corps of Engineers.
13. Tenants, such as other Federal agen-
cies, contractor activities, lessees, and all
others performing activities in direct support
of the Army located on real property under
Department of the Army jurisdiction.
14. Contracts at Government-owned,
con- tractor-operated facilities which will
refer- ence this regulation and or will
designate by specific citation applicable
provisions of this regulation.
b. All of the above will be referred to in
this regulation as the Army, unless otherwise
noted.
c. This regulation does not apply to the
Civil Works functions of the U.S. Army
Corps of Engineers, except when the U.S.
Army Corps of Engineers is operating on or
using funds of military installations and ac-
tivities.
d. Nothing in this regulation changes any
rights granted by treaty or otherwise to any
Indian tribe, Native Hawaiian organization,
or to its members.
e. This regulation applies to installations
and activities within any state of the United
States, the District of Columbia, and territo-
ries of the United States (United States).
f. Commanders outside of the United
States will comply with—
7 Substantive cultural resources require-
ments of general applicability included in
host nation law and regulation to the extent
practicable or, when adopted, those require-
ments identified in Final Governing Stand-
ards adopted by the DoD Executive Agent.
8 International Treaties and Status of
Forces Agreements.
9 National Historic Preservation Act
Amendments of 1980, Section 402 (16 USC
470a-2).

Proponent and exception authority.
The proponent of this regulation is the As-
sistant Chief of Staff for Installation Manage-
ment. The proponent has the authority to
approve exceptions to this regulation that are
consistent with controlling Federal law and
regulation. Proponents may delegate the ap-
proval authority, in writing, to a division
chief within the proponent agency in the
grade of colonel or the civilian equivalent.

Army management control process.
This regulation is subject to the requirements
of AR 11-2. It contains management control
provisions but does not contain checklists for
conducting environmental management re-
views.

Supplementation. Supplementation to this
regulation and establishment of command
and local forms is prohibited without the
prior approval of the Director of Environ-
mental Programs, DAIM-ED, 600 ARMY
PENTAGON, WASH, DC 20310-0600. The
requirements of such supplements must be
consistent with and no less stringent than the
requirements of this regulation.

Suggested Improvements. Users are in-
vited to send comments and suggested im-
p r o v e m e n t s o n D A F o r m 2 0 2 8
(Recommended Changes to Publications and
Blank Forms) directly to HQDA, DAIM-ED-
N, 600 ARMY PENTAGON, WASH, DC
20310-0600.

Distribution. Distribution of this publica-
tion is made in accordance with the initial
distribution number (IDN) 095561, intended
for command levels C, D, and E for Active
Army, Army National Guard of the United
States, and U.S. Army Reserve.

*This regulation supersedes AR 420-40, 15 April 1984.

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Contents (Listed by paragraph and page number)

Chapter 1
Introduction, page 1

Section I
General, page 1
Purpose • 1–1, page 1
References • 1–2, page 1
Explanation of abbreviations and terms • 1–3, page 1

Section II
Responsibilities, page 1
Deputy Assistant Secretary of the Army (Environment, Safety and
Occupational Health) (DASA(ESOH)) • 1–4, page 1
The Assistant Chief of Staff for Installation Management (ACSIM)
• 1–5, page 1
The Judge Advocate General (TJAG) • 1–6, page 1
Director, Army National Guard Bureau (ARNGB) • 1–7, page 1
MACOM Commanders; Commander, U.S. Army Reserve
Command; and Director of Environmental Programs, National
Guard Bureau (MACOM commanders) • 1–8, page 1
Installation Commanders; Commanders, of US Army Reserve
Regional Support Commands; and the Adjutants General
(Installation commanders) • 1–9, page 1

Chapter 2
Cultural Resources Compliance Requirements, page 2 Cultural
Resources Management Program • 2–1, page 2 National
Environmental Policy Act of 1969 as amended (NEPA)
• 2–2, page 2
National Historic Preservation Act of 1966 as amended (NHPA)
• 2–3, page 2
American Indian Religious Freedom Act of 1978 (AIRFA) and EO
13007, Indian Sacred Sites • 2–4, page 3
Native American Graves Protection and Repatriation Act of 1990
(NAGPRA) • 2–5, page 4
Antiquities Act of 1906 and Archeological Resources Protection
Act of 1979 (ARPA) and Archeological and Historic
Preservation Act of 1974 (AHPA) • 2–6, page 4
36 CFR 79, Curation of Federally-Owned and -Administered
Archeological Collections • 2–7, page 5
Presidential Memorandum for Heads of Executive Departments and
Agencies dated April 29, 1994: Government-to-Government
Relations with Native American Tribal Governments. • 2–8,
page 5

Chapter 3
NHPA Section 106 PAs,and MOAs, National Register of Historic
Places, NAGPRA CAs and Plans of Action, Cooperative
Agreements and Funding, page 6
NHPA Section 106 PAs and MOAs • 3–1, page 6
National Register of Historic Places Determinations of Eligibility,
Nominations, and Delisting • 3–2, page 7
NAGPRA CAs and Plans of Action • 3–3, page 7
Cooperative Agreements and Interagency Agreements • 3–4,
page 8
Funding Cultural Resources Activities • 3–5, page 8

Chapter 4
Integrated Cultural Resources Management Plans (ICRMPs)
, page 9
Scope and Purpose of ICRMPs • 4–1, page 9
Content of ICRMPs • 4–2, page 9

Appendixes
7 References, page 10
8 Federal Statutes, Regulations, Executive Orders and
Presidential Memorandum, page 10

Glossary Index
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Chapter 1 Introduction
Section I General
1–1. Purpose
This regulation prescribes Army policies, procedures, and responsi-
bilities for meeting cultural resources compliance and management
requirements. The scope of this regulation includes the National
Historic Preservation Act (NHPA); American Indian Religious Free-
dom Act (AIRFA) and Executive Order (EO) 13007; Native Ameri-
can Graves Protection and Repatriation Act (NAGPRA);
Archeological Resources Protection Act (ARPA), 36 CFR 79; and
other requirements and policies affecting cultural resources manage-
ment. These policies are designed to ensure that Army installations
make informed decisions regarding the cultural resources under their
control in compliance with public laws, in support of the military
mission, and consistent with sound principles of cultural resource
management.
1–2. References
Required and related publications and prescribed and referenced
forms are listed in appendix A.
1–3. Explanation of abbreviations and terms
Abbreviations and special terms used in this regulation are ex-
plained in the glossary.

Section II Responsibilities

1–4. Deputy Assistant Secretary of the Army (Environment,
Safety and Occupational Health) (DASA(ESOH))
The DASA(ESOH) is the Army’s Federal Preservation Officer
(FPO) pursuant to designation by the Assistant Secretary of the
Army (Installations, Logistics, and Environment) on behalf of the
Secretary of the Army. As the FPO, the DASA(ESOH) is responsi-
ble for oversight and coordination of the Army’s activities under the
NHPA, including approval and signature on Army National Register
of Historic Places nominations for Federally-owned and -controlled
historic properties. DASA(ESOH) FPO signature authority for Na-
tional Register nominations may be delegated to the ACSIM.

1–5. The Assistant Chief of Staff for Installation
Management (ACSIM)
ACSIM is the Army Staff proponent for the military Cultural Re-
sources Management Program. ACSIM functional responsibilities in
this program area are implemented as follows:
8.6. The Director of Environmental Programs (DEP) carries out
the ACSIM Army Staff function for the military Cultural Resources
Management Program through the following responsibilities:
(i) Promulgates cultural resources policy and guidance.
(j) Identifies, supports, and defends cultural resources
requirements.
(k) Directs and coordinates Army Staff cultural resources
man- agement program requirements.
8.7. The Commander, U.S. Army Environmental Center (AEC),
under the direction of the DEP, is responsible for a broad range of
technical support and oversight services for execution of the military
cultural resources management program worldwide including:
(1) Support for HQDA, MACOM, and installation cultural re-
sources compliance activities and programs.
(2) HQDA technical oversight and review of the Army Cultural
Resources Management Program including NHPA Section 106 Pro-
grammatic Agreements (PAs) and Memoranda of Agreement
(MOA), NAGPRA Comprehensive Agreements (CAs) and Plans of
Action, other cultural resources agreements and actions, and Na-
tional Register of Historic Places nominations .
(3) Identification of Army-wide cultural resources requirements
and shortfalls through analysis of Army programming data, emerg-
ing statutory and regulatory requirements, and the Army Environ-
mental Strategic Action Plan (AESAP). Development, execution and
management of programs and initiatives to address shortfalls and
requirements.
1–6. The Judge Advocate General (TJAG)
TJAG provides legal advice to the Army on military cultural re-
sources legal matters. The Chief, Environmental Law Division
(ELD), will exercise those authorities on behalf of TJAG and will—
a. Serve as legal advisor to the ACSIM and DEP with regard to
the Army Cultural Resources Management Program.
b. Review draft cultural resources compliance agreements IAW
the procedures and time frames of this regulation.
c. Serve as agency counsel for the Army in appropriate adminis-
trative cases, hearings, and enforcement actions.
1–7. Director, Army National Guard Bureau (ARNGB)
The Director, Army National Guard Bureau will—
a. Approve, oversee, and coordinate all cultural resources com-
pliance activities on ARNG Federally-owned or controlled installa-
tions and sites, or for actions that are supported with Federal funds
or subject to Federal approval.
b. Provide directions to the Assistant Deputy Director, Army
National Guard Bureau (NGB-ILE) in all matters relating to cultural
resources management.
c. Act as the official channel of communication between the
State and Territory Adjutants General and HQDA.

1–8. MACOM Commanders; Commander, U.S. Army Reserve
Command; and Director of Environmental Programs, National
Guard Bureau (MACOM commanders) MACOM commanders
will direct and assist their installations in the conduct of installation
cultural resources programs consistent with this regulation. Each
MACOM commander and the Director of En- vironmental
Programs, National Guard Bureau will—
a. Ensure that cultural resources responsibilities are implemented
across all installations.
b. Monitor installation cultural resources management programs.
c. Review ICRMPs, NHPA MOAs and PAs, National Register
determinations of eligibility and nominations, NAGPRA CAs and
Plans of Action. Forward NHPA PAs and MOAs, NAGPRA CAs
and Plans of Action, and National Register nominations to HQDA
(AEC) for HQDA review. MACOM commanders may also elect to
sign NHPA PAs and MOAs, and NAGPRA CAs and Plans of
Action.
d. Implement HQDA cultural resources management policy and
guidelines in this regulation and in DA Pamphlet 200-4 at their
respective installations.
e. Provide MACOM cultural resources reporting information to
HQDA to include, the Installation Status Report (ISR), the Environ-
mental Quality Report (EQR), and the Environmental Program Re-
quirements (EPR).
f. Assist installation commanders in establishing reasonable fund-
ing priorities and meeting appropriate milestones in program devel-
opment and implementation IAW this regulation.
g. Ensure that installation cultural resources programs are accu-
rately evaluated when conducting environmental compliance assess-
ments pursuant to AR 200-1.
h. MACOM commanders may delegate any of these responsibili-
ties to commanders of their major subordinate commands.

1–9. Installation Commanders; Commanders, of US Army
Reserve Regional Support Commands; and the Adjutants
General (Installation commanders)
Installation commanders will—
a. Establish an Installation Cultural Resources Management Pro-
gram by implementation of this regulation and DA Pamphlet 200-4.
b. Designate NLT 1 June 1999, an installation Cultural Resource
Manager (CRM) to coordinate the installation’s cultural resources
management program. The installation commander will ensure that
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the CRM has appropriate knowledge, skills, and professional train-
ing and education to carry out installation cultural resources man-
agement responsibilities. The installation commander will also
ensure that all cultural resources technical work (including but not
limited to identification, evaluation, and treatment of historic prop-
erties, and preparation and implementation of an ICRMP), is con-
ducted by individuals who meet the applicable professional
qualifications standards established by the National Park Service in
36 CFR 61, Appendix A.
c. The installation commander will establish a government-to-
government relationship with Federally-recognized Indian tribes, as
needed. If there are significant Native American issues, the installa-
tion commander will also designate an installation “Coordinator for
Native American Affairs” to facilitate the government-to-govern-
ment relationship. The installation commander will ensure that the
Coordinator for Native American Affairs has appropriate knowl-
edge, skills, and professional training and education to conduct
installation consultation responsibilities with Indian tribes.
d. Establish a process that requires early coordination between
the CRM and other installation staff elements, tenants, and others
early in the planning of projects and activities that may affect
cultural resources.
e. Prepare and implement, if appropriate, an installation wide
NHPA Section 106 PA, and a NAGPRA CA where required to
address and streamline NHPA and NAGPRA compliance procedures
for ongoing mission and operations. If an installation-wide NHPA
Section 106 PA and NAGPRA CA is not prepared, the commander
must ensure that individual undertakings and activities follow
NHPA Section 106 (36 CFR 800) and NAGPRA (43 CFR 10)
compliance procedures.
f. Ensure that cultural resources management is integrated with
installation training and testing activities, master planning (AR 210-
20), environmental impact analysis (AR 200-2), natural resources
and endangered species management planning and programming to
include Integrated Natural Resources Management Plans (AR 200-
3), and the Integrated Training Area Management (ITAM) program.
Ensure that the installation cultural resources management program
is developed and implemented IAW the policies and guidelines set
forth in this regulation and in DA Pam 200-4.
g. Establish funding priorities and program funds for cultural
resources compliance and management activities into the Environ-
mental Program Requirements report.
h. Conduct a comprehensive evaluation of the installation’s cul-
tural resources management program as part of the environmental
compliance assessment required by AR 200-1.
i. Develop ICRMPs, cultural resources inventory plans and
schedules, NHPA PAs and MOAs, NAGPRA CAs and Plans of
Action, and other documents as appropriate, and coordinate such
documents with the MACOM and HQDA IAW this regulation.
j. Serve as the Agency Official as defined in 36 CFR 800 with
responsibility for installation compliance with the NHPA.
k. Serve as the Federal Agency Official as defined in 43 CFR 10
with responsibility for installation compliance with NAGPRA.
l. Serve as the Federal land manager as defined in 32 CFR 229
with responsibility for installation compliance with ARPA. ARPA
permits are issued by the supporting USACE District Real Estate
office upon approval of the installation commander IAW ER 405-1-
12 and AR 405-80. Installation commander approval is provided
through the issuance of the Report of Availability to the supporting
USACE District Real Estate office.
m. Serve as the Federal Agency Official as defined in 36 CFR 79
with management authority over archeological collections and asso-
ciated records.
n. Sign NHPA PAs and MOAs, and NAGPRA CAs and Plans of
Action and other installation cultural resources agreements after
MACOM and HQDA comments have been addressed.
Chapter 2
Cultural Resources Compliance Requirements
2–1. Cultural Resources Management Program
a. This chapter identifies the basic compliance requirements asso-
ciated with the major Federal cultural resources laws and regulations
applicable to Army activities. Installation commanders must comply
with applicable cultural resources statutes, regulations, Executive
Orders, and Presidential Memoranda listed in appendix B.
b. DA personnel, at all levels, must ensure that mission require-
ments are carried out in harmony with such statutory and regulatory
requirements. Failure to fulfill these requirements could result in
halting or delaying ongoing or proposed mission essential projects,
training and testing actions, and could deplete limited financial and
staff resources. Proponents of Army actions should coordinate with
the CRM early in the planning stage of projects and activities to
identify potential cultural resources compliance requirements.
c. The key to the successful balance of mission requirements and
cultural resources compliance and management responsibilities is
early planning, and coordination to prevent conflicts between the
mission and the resources. Integrated Cultural Resources Manage-
ment Plans, as identified in chapter 4, are the installation command-
er’s primary tool for planning and integration of cultural resources
compliance and management activities into the military mission.
d. In fulfilling its cultural resources responsibilities, the installa-
tion will work closely with the appropriate authorities designated in
applicable Federal statute and regulation.

2–2. National Environmental Policy Act of 1969 as amended
(NEPA)
a. NEPA requires installation commanders and other Army deci-
sion makers to consider the environmental effects of their proposed
programs, projects, and actions prior to initiation. Pursuant to the
National Environmental Policy Act of 1969 (NEPA) and the Coun-
cil on Environmental Quality regulations 40 CFR 1500-1508, the
proponents of Army actions will ensure that cultural resources are
fully considered when preparing NEPA documents. Army policy for
compliance with NEPA is found in AR 200-2.
b. NEPA documents will include a comprehensive assessment of
the impacts of proposed Army actions or activities on cultural re-
sources. However, compliance with NEPA for a specific action does
not relieve the Army of the independent compliance procedures
associated with applicable cultural resources requirements in appen-
dix A. Information and findings obtained through compliance with
cultural resources statutes, regulations, Executive Orders, and Presi-
dential Memoranda should be integrated into the concurrent NEPA
compliance process and documents.
c. Impact assessments under NEPA must consider the effects of
proposed Federal actions on cultural resources and the effects on
Indian tribes, Native Hawaiian Organizations, Native Alaskans, and
other ethnic and social communities to whom the cultural resources
may have importance. The information needed to make such impact
assessments may be acquired from information developed as a result
of compliance with cultural resources statutes, regulations and Exec-
utive Orders.

2–3. National Historic Preservation Act of 1966 as amended
(NHPA)
a. The National Historic Preservation Act (NHPA) establishes the
Federal government’s policy to provide leadership in the preserva-
tion of historic properties and to administer Federally-owned or -
controlled historic properties in a spirit of stewardship. The installa-
tion commander shall administer, manage and treat historic proper-
ties in accordance with the NHPA. The installation commander shall
also identify, evaluate, and nominate historic properties for listing in
the National Register of Historic Places consistent with the policies
and guidelines in this regulation and DA Pam 200-4.
b. Section 106 of the NHPA:
(1) The installation commander shall identify, evaluate and take
into account the effects of all undertakings on historic properties
IAW the procedures set forth in 36 CFR 800 and this regulation.
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The ACHP is responsible for providing comments on undertakings
that affect historic properties. The State Historic Preservation Offi-
cer (SHPO) is a significant participant in the Section 106 compli-
ance process by providing comments on efforts to identify, evaluate
and treat any effects on historic properties. If an undertaking on
Army lands may affect properties having historic value to a Federal-
ly-recognized Indian tribe, such tribe shall be afforded the opportu-
nity to participate as interested persons during the consultation
process defined at 36 CFR 800. Traditional cultural leaders and
other Native Americans and Native Hawaiians are considered to be
interested persons with respect to undertakings that may affect his-
toric properties of significance to such persons. If an undertaking
may involve excavation of NAGPRA cultural items, the require-
ments of NAGPRA and 43 CFR 10 must also be met prior to
implementation of the undertaking.
(2) Failure to take the effects of an undertaking on historic prop-
erties into account IAW NHPA Section 106 and 36 CFR 800 can
result in formal notification from the ACHP to the Secretary of the
Army of foreclosure of the ACHP’s opportunity to comment on the
undertaking pursuant to the NHPA. A notice of foreclosure can be
used by litigants against the Army in a manner that can halt or delay
critical mission activities.
(3) The installation commander will ensure that the efforts to
identify, evaluate, and treat historic properties follow the Secretary
of the Interior’s Standards and Guidelines For Archeology And
Historic Preservation and are conducted under the supervision of
personnel who meet the applicable professional qualifications stand-
ards set forth in 36 CFR 61 appendix A. Disagreements between the
installation commander and the SHPO regarding the eligibility of a
property for listing in the National Register shall be resolved
through the procedures at 36 CFR 63.2(d).
(4) PAs and MOAs executed pursuant to NHPA Section 106 and
36 CFR 800 are compliance agreements that set forth how the Army
will satisfy the responsibilities of Section 106 of the NHPA in the
context of an Army undertaking that will affect an historic property.
Section 106 PAs that address and define ongoing installation-wide
undertakings associated with mission activities and their effects on
historic properties over a 5-year programming and budgeting cycle
are encouraged because they can streamline the NHPA compliance
process and serve as a program management tool. Any management
procedures and determinations provided in PAs and MOAs should
be integrated into the installation’s ICRMP. However, NHPA PAs
and MOAs shall not refer to or implement an ICRMP. An ICRMP
is intended to integrate all of the installation’s responsibilities for
managing all cultural resources as defined by this regulation. Im-
plementing such a document with an NHPA PA or MOA would
vest review authority in the ACHP and SHPO over the installation’s
compliance with statutes and regulations that are clearly outside the
statutory authority of the ACHP and SHPO. ACHP and SHPO
statutory authority is limited to consultation with Federal agencies
under the NHPA and 36 CFR 800.
c. Section 110 of the NHPA imposes specific responsibilities
upon the installation commander regarding historic preservation. In
accordance with Section 110(a)(1), the affirmative preservation re-
sponsibilities in Section 110 must be undertaken in a manner consis-
tent with the installation’s mission. Such responsibilities include but
are not limited to the following:
(1) Establishing a historic preservation program to include the
identification, evaluation and nomination of historic properties to the
National Register of Historic Places in consultation with the ACHP,
SHPO, local governments, Indian tribes, Native Hawaiian organiza-
tions, and the interested public as appropriate. This responsibility is
fulfilled by implementation of this regulation at all levels within the
Army.
(2) Prior to acquiring, constructing, or leasing buildings, installa-
tion commanders must use available historic properties to the maxi-
mum extent feasible.
(3) The installation commander must document historic proper-
ties that will be altered or destroyed as a result of Army action.
Such actions must be reviewed in accordance with NHPA Section
106.
(4) In transferring Army historic properties, the installation com-
mander must ensure that the significant historic values of the prop-
erty are appropriately preserved.
(5) The Secretary of the Army must document decisions to pro-
ceed with Army undertakings that adversely affect historic proper-
ties when the installation commander has been unable to reach
agreement through execution of a MOA or PA with the ACHP and
SHPO. Procedures for installation commanders to follow when such
a situation arises in the context of an NHPA undertaking are at
section 3-1d of this regulation.
d. Section 304 of the NHPA requires that information about the
location, character, or ownership of a historic property be withheld
from public disclosure when the installation commander determines
that disclosure may cause a significant invasion of privacy, risk
harm to the historic property, or impede the use of a traditional
religious site by practitioners. After determining that information
should be withheld, the installation commander will provide such a
determination through command channels to HQDA (DEP).
e. Section 101(d)(2) of the NHPA provides for the assumption by
Federally-recognized Indian tribes of all or any part of the functions
of a SHPO with respect to tribal lands (for example, all lands within
the exterior boundaries of any Indian reservation and all dependent
Indian communities). Section 101(d)(6) requires installations, in car-
rying out their Section 106 responsibilities, to consult with Federally
recognized Indian tribes and Native Hawaiian Organizations that
attach religious or cultural significance to an historic property. In-
stallation commanders will consult with Federally-recognized Indian
tribes and Native Hawaiian Organizations in the Section 106 process
to identify, evaluate, and treat historic properties that have religious
or cultural importance to those groups.
f. Section 111 of the NHPA requires installation commanders, to
the extent practicable, to establish and implement alternatives for
historic properties, including adaptive use, that are not needed for
current or projected installation mission requirements.
g. Section 112 of the NHPA requires that installation command-
ers who are responsible for protection of historic properties pursuant
to NHPA ensure that all actions taken by employees or contractor
meet professional historic preservation standards established by the
Secretary of the Interior.
2–4. American Indian Religious Freedom Act of 1978 (AIRFA)
and EO 13007, Indian Sacred Sites
a. Installation commanders will develop and implement proce-
dures to protect and preserve the American Indian, Eskimo, Aleut,
and Native Hawaiians’ right of freedom to believe, express, and
exercise their traditional religions, including but not limited to ac-
cess to sacred sites, use and possession of sacred objects, and free-
dom to worship through ceremonies and traditional rites. Installation
commanders shall also establish procedures to facilitate consultation
with Federally-recognized Indian tribes and Native Hawaiian organi-
zations, as appropriate.
b. Installation commanders shall consult with Indian tribes and
Native Hawaiians to identify sacred sites that are necessary to the
exercise of traditional religions and shall provide access to Army
installations for Indian tribes and Native Hawaiian practice of tradi-
tional religions, rights and ceremonies. The installation commander
shall maintain the confidentiality of sacred site locations. Installation
commanders may impose reasonable terms, conditions and restric-
tions upon access to such sites when the commander deems it
necessary for the protection of personal health and safety, or to
avoid interference with the military mission, or for other reasons of
national security. The installation commander shall maintain the
confidentiality of sacred site locations.
c. Installation commanders will avoid adversely affecting the
physical integrity of sacred sites and shall establish procedures to
ensure reasonable notice is provided to Federally-recognized Indian
tribes and Native Hawaiian organizations when proposed actions or
land management policies and practices may restrict future access
to, ceremonial use of, or adversely affect the physical integrity of
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sacred sites. Such procedures should be set forth in an installation
ICRMP. If a sacred site may be affected by installation land man-
agement policies or practices, the installation commander shall also
ensure that the compliance requirements of the NHPA are met if the
sacred site meets the NHPA definition of an historic property.

2–5. Native American Graves Protection and Repatriation Act
of 1990 (NAGPRA)
a. The intent of NAGPRA is to identify proper ownership and to
ensure the rightful disposition of cultural items (defined in Section 2
of NAGPRA) that are currently in Federal possession or control.
NAGPRA mandates that installation commanders summarize, inven-
tory, and repatriate cultural items in the possession or control of the
installation to lineal descendants or to culturally affiliated Federally-
recognized Indian tribes or Native Hawaiian organizations.
NAGPRA also requires that certain procedures be followed when
there is an intentional excavation of or an inadvertent discovery of
cultural items. The installation commander will ensure compliance
with NAGPRA (23 USC 3002) and its implementing regulation (43
CFR 10).
b. The installation commander may enter into CAs with Federal-
ly-recognized Indian tribes and Native Hawaiian organizations for
the purposes of compliance with NAGPRA and 43 CFR 10. CAs
should establish responsibilities and address all installation land
management activities that could result in the intentional excavation
or inadvertent discovery of cultural items, establish standard consul-
tation procedures, and provide for the determination of custody,
treatment, and disposition of cultural items. Such CA procedures
and determinations should be incorporated by reference into any
ICRMP prepared by the installation. However, CAs must be pre-
pared independent of ICRMPs and such CAs shall not refer to or
implement an ICRMP.
c. Absent a CA, the installation commander shall take reasonable
steps to determine whether a planned activity may result in the
intentional excavation or inadvertent discovery of cultural items
from Federally-owned or -controlled Army lands. When it is deter-
mined that cultural items may be encountered and, prior to issuing
approval to proceed with the activity, the commander shall carry out
the consultation procedures and planning requirements of 43 CFR
10.3 and 10.5. Following consultation per 43 CFR 10.5 as part of
the intentional excavation or inadvertent discovery of cultural items,
a written Plan of Action must be prepared IAW the 43 CFR 10.5(e).
Such procedures and actions should be coordinated with the require-
ments of the NHPA and ARPA when such excavations or discover-
ies may involve historic properties and or archeological resources.
d. If an inadvertent discovery of cultural items occurs in connec-
tion with an ongoing activity on the installation and there is no CA
in effect that sets forth agreed upon procedures for such instances,
then the installation commander must comply with 43 CFR 10.4 (a-
d). Such compliance measures include but are not limited to notifi-
cations, cessation of the activity for 30 days in the area of the
discovery, protection of the discovery, consultation with Indian
tribes or Native Hawaiian organizations affiliated with the discovery
IAW 43 CFR 10.5 and preparation of a written Plan of Action. The
installation commander must ensure that all authorizations to carry
out activities on Federally-owned or-controlled installation lands,
including leases and permits, include a requirement for the holder of
the authorization to notify the commander immediately upon the
inadvertent discovery of cultural items and to protect such discover-
ies until applicable compliance procedures are satisfied.
e. Installation commanders must ensure that intentional excava-
tion and response to any inadvertent discovery of NAGPRA cultural
items are carried out in compliance with all applicable statutory and
regulatory requirements of NAGPRA, ARPA and NHPA. Each stat-
ute mandates compliance with independent requirements. Compli-
ance with one statutory requirement therefore, may not satisfy other
applicable requirements.
f. Summary, inventory and repatriation of cultural items that are
in existing collections under Army possession or control shall occur
IAW NAGPRA Sections 5, 6, and 7 and 43 CFR 10. In instances
where there is a dispute as to the ownership of cultural items, the
installation shall safeguard the cultural items until the dispute is
resolved IAW NAGPRA Section 7(e). The installation commander
shall notify the MACOM and HQDA (AEC) in the event of a
dispute as to ownership of cultural items.
g. All activities carried out to comply with NAGPRA and 43
CFR 10 shall only occur with Federally-recognized Indian tribes,
Native Hawaiian organizations, and lineal descendants as defined
and provided for by NAGPRA.

2–6. Antiquities Act of 1906 and Archeological Resources
Protection Act of 1979 (ARPA) and Archeological and
Historic Preservation Act of 1974 (AHPA)
a. The Antiquities Act of 1906 and ARPA prohibit the excava-
tion, collection, removal, and disturbance of archeological resources
(as defined by ARPA) and objects of antiquity (as referenced in the
Antiquities Act) on Federally-owned Army property without a per-
mit issued by the USACE District Real Estate Office on the ap-
proval of the installation commander. Violation of either statute may
result in the assessment of civil or criminal penalties, and forfeiture
of vehicles and equipment that were used in connection with the
violation.
b. Paleontological Resources. Paleontological remains and depos-
its are considered to be objects of antiquity pursuant to the Antiqui-
ties Act. Management of important paleontological remains or
deposits should be integrated into ICRMPs prepared pursuant to this
regulation. Paleontological resources are scientifically significant
fossilized remains, specimens, deposits and other such data from
prehistoric, non-human life. The AHPA specifically provides for the
survey and recovery of scientifically significant data which may be
irreparably lost as a result of any alteration of the terrain from any
federal construction projects, or Federally licensed project, activity,
or program. Any installation paleontological resource management
requirements will be integrated in ICRMPs and will establish and
include installation policy for limitation of collection and removal of
paleontological resources. Known paleontological resources will
also be addressed in any NEPA documentation prepared for actions
that may impact or cause irreparable loss or destruction of such
resources.
(1) When an installation finds, or is notified in writing by an
appropriate authority that its activities may cause irreparable loss or
destruction of scientifically significant paleontological resources, the
installation commander will notify the Secretary of the Interior in
writing and will provide information concerning the activity IAW
AHPA. Such notification may be incorporated as part of the NEPA
public review and comment process for the subject activity.
(2) Upon notification by the installation that scientific data may
be irrevocably lost or destroyed by a proposed activity, the Secre-
tary of the Interior shall, if he or she determines that such data are
significant and after reasonable notice to the installation responsible
for the activity, conduct or cause to be conducted a survey and other
investigation of the affected area and recover and preserve such
data. APHA provides installation commanders the authority to assist
the Secretary of the Interior with funds for surveys or other activi-
ties to recover significant scientific data, but such financial assist-
ance is not required. Likewise, installation commanders may choose
to undertake such professional survey and recovery activities them-
selves with funds appropriated for the project, program, or activity.
Such project requirements shall be programmed in the Environmen-
tal Program Requirements Report.
c. The use of metal detectors to locate archeological resources is
prohibited on Army installations except when used by Army person-
nel, contractors, or permittees in association with official cultural
resource management activities or pursuant to a permit issued under
ARPA.
d. ARPA permits for archeological investigations that may result
in the excavation or removal of Native American human remains
and other cultural items, as defined in NAGPRA, or in the excava-
tion of archeological resources that are of religious or cultural im-
portance to Federally-recognized Indian tribes, will be issued IAW
AR 405-80 and this regulation. An installation’s supporting USACE
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District Real Estate Office will issue the permit after the installation
commander conducts consultation IAW 43 CFR 10.5 and 32 CFR
229.7 with the culturally affiliated Indian tribes or Native Hawaiian
organizations. The installation commander provides the USACE
District with approval to issue the permit by means of a Report of
Availability prepared after necessary consultation and compliance
actions have been met. ARPA permits shall provide for the disposi-
tion of NAGPRA cultural items in accordance with NAGPRA sub-
sections 3(a) and (b) and 43 CFR 10. The installation commander
will ensure that documentation of consultation with culturally affili-
ated Indian tribes or Native Hawaiian organizations is prepared and
maintained as part of the record of each such permit.
e. The installation will ensure that ARPA permits—
(1) Comply with the requirements of 32 CFR 229, 43 CFR 10,
(2) Require that any interests which Federally-recognized Indian
tribes or Native Hawaiian organizations may have in the permitted
activity are addressed in a manner consistent with the requirements
of NHPA and NAGPRA, prior to issuance of the permit,
(3) Require permitted activities be performed according to appli-
cable professional standards of the Secretary of Interior, and
(4) Require that the excavated archeological artifact collection
and associated records are permanently curated in a curation facility
which meets the requirements of 36 CFR 79.
f. Archeological resources, objects of antiquity, and scientific
data from Federal installations belong to the installation, except
where NAGPRA requires repatriation to a lineal descendant, Indian
tribe or Native Hawaiian organization. Archeological resources and
objects of antiquity from non-Federal land belong to the State,
Territory, or land owner. Such resources from lands used by the
Army but for which fee title is held by another agency are the
property of the agency designated as the land manager in the land
use instrument (for example, Public Land Order, Special Use Per-
mit, etc.). Installation commanders should ensure that land use in-
struments allowing for military use are reviewed to determine
proper roles and responsibilities.
g. Army staff or contractors carrying out official duties associ-
ated with the management of archeological resources who meet the
professional qualifications and whose investigations meet the re-
quirements of 32 CFR 229.8 are not required to obtain a permit
under ARPA or the Antiquities Act for the investigation of archeo-
logical resources on a Federally-owned or-controlled installation,
including situations where cultural items as defined by NAGPRA
may be excavated. However, in situations where NAGPRA cultural
items or NHPA historic properties may be encountered during inten-
tional excavation of archeological resources, the requirements of
NAGPRA and 43 CFR 10, and NHPA and 36 CFR 800 must be met
prior to such archeological excavations.
h. For the purposes of Army compliance with ARPA, the instal-
lation commander is considered the Federal land manager as defined
in 32 CFR 229.3(c). As the Federal land manager, the installation
commander may determine that certain archeological resources in
specified areas under his or her jurisdiction, and under specific
circumstances, are not or are no longer of archeological interest and
are not considered archeological resources for the purposes of
ARPA (IAW 32 CFR 229.3(a)(5)). All such determinations shall be
justified and documented by memorandum and shall be formally
staffed for review through the MACOM to HQDA (AEC) prior to
final determination.
i. The installation commander will ensure that military police,
installation legal staff, the installation Public Affairs Office (PAO),
and the fish, game, and recreation management staff are familiar
with the requirements and applicable civil and criminal penalties
under ARPA. Also, IAW ARPA Section 9, the installation com-
mander may withhold information concerning the nature and loca-
tion of archeological resources from the public under subchapter II
of chapter 5 of title 5 of the United States Code or under any other
provision of law.
2–7. 36 CFR 79, Curation of Federally-Owned and -
Administered Archeological Collections
a. The installation commander will ensure that all “collections,”
as defined in 36 CFR 79.4(a) are processed, maintained and curated
in accordance with the requirements of 36 CFR 79. However,
NAGPRA cultural items in the installation’s possession and control
shall be disposed of in a manner consistent with the requirements of
NAGPRA and 43 CFR 10.
b. Installation archeological collections may be processed, main-
tained, and curated on and by the installation, by another Federal
agency, State agency, or other outside institution or non-Govern-
mental organization, in cooperative repositories maintained by or on
behalf of multiple agencies, or in other facilities, under contract,
cooperative agreement or other formal funding and administrative
arrangement provided the standards of 36 CFR 79 are met. General-
ly, installations should not establish archeological curation facilities
on the installation due to the permanent recurring costs and person-
nel requirements to maintain such repositories to the minimum
standards in 36 CFR 79 in perpetuity. Prior to the installation com-
mander’s approval of the establishment of an on-post archeological
curation facility, a cost analysis shall be conducted and included as
a primary factor in the decision. The cost analysis will include
factors such as professional curatorial personnel costs for the instal-
lation; initial installation infrastructure start-up costs to establish the
facility; and installation costs for annual operation, materials, main-
tenance, and repair. These installation cost factors should be com-
pared with similar costs associated with curating the materials in a
outside facility such as at a State museum, other federal or state
agency, or with a non-Governmental organization. If a certified
Army museum exists on the installation (pursuant to AR 870-20),
use of that facility for archeological curation should be investigated
prior to any other action to establish or contract out for curation
services.
c. Installation commanders shall establish procedures in the in-
stallation ICMRP to minimize the amount of archeological “material
remains” (as defined in 36 CFR 79.4(a)(1), that are collected during
archeological inventory and site excavation and permanently cu-
rated. Such procedures will be integrated into any SOPs and con-
tracts or cooperative agreements for such activities and will serve to
reduce the long term costs associated with archeological materials
curation requirements. Such procedures shall recognize that not all
archeological material remains recovered from field work need be
accessioned into the installation collection and permanently curated.
Archeological material remains recovered during field inventory and
site identification efforts should be analyzed and recorded, but gen-
erally should not be accessioned into the permanent installation
archeological collection. For artifacts recovered from more exten-
sive excavations (mitigation), some classes of material remains may
be analyzed and recorded but not permanently accessioned into the
installation collection. Permanent curation should be reserved for
diagnostic artifacts and other significant and environmentally sensi-
tive material that will add important information to site
interpretation.

2–8. Presidential Memorandum for Heads of Executive
Departments and Agencies dated April 29, 1994:
Government-to-Government Relations with Native American
Tribal Governments.
This memorandum requires that—
a. Consultation between the Army and Federally-recognized In-
dian tribes occur on a government-to-government basis, and in an
open and candid manner.
b. Consultation with Federally-recognized Indian tribes on a gov-
ernment-to-government basis occurs formally and directly between
installation commanders and heads of Federally-recognized tribal
governments. Installation commanders establish government-to-gov-
ernment relations with Federally recognized Indian tribes by means
of formal, written letters to the heads of tribal governments. Such
letters should designate an installation Coordinator for Native Amer-
ican Affairs who is authorized to conduct follow-on consultations
with designated representatives of the tribal government. Any final
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decisions on installation plans, projects, programs or activities that
have been subject of government-to-government consultation will be
formally transmitted from the installation commander to the head of
the tribal government.
c. Installations assess the impact of their plans, projects, pro-
grams, and activities on tribal trust resources and assure that tribal
government rights and concerns are considered during the develop-
ment of such plans, projects, programs, and activities.

Chapter 3
NHPA Section 106 PAs,and MOAs, National Register of
Historic Places, NAGPRA CAs and Plans of Action,
Cooperative Agreements and Funding
3–1. NHPA Section 106 PAs and MOAs
a. When an installation commander requires a NHPA Section
106 PA or MOA, the following principles and procedures shall be
followed:
(1) PAs and MOAs should contain a compliance schedule with
deadlines set to meet the needs of particular undertakings, and
procedures for schedule and task modification, dispute resolution,
and amendment and termination of the agreement. All agreements
will clearly identify the Army undertakings, the affected historic
properties, and will address only NHPA compliance responsibilities.
PAs shall identify specific installation undertakings over a 5-year
planning cycle to the greatest extent possible. Installation undertak-
ings shall be identified through an analysis of such documents
including but not limited to the Master Plan, military construction
plans, troop training and range operation plans, Integrated Natural
Resources Management Plans, and historic property rehabilitation or
demolition plans.
(2) PAs and MOAs shall not provide the SHPO, ACHP or other
consulting party with authority to review, consult, or comment on
activities associated with the management of cultural resources other
than historic properties. Such comments may be obtained as non-
binding technical review comments outside of the Section 106
regulatory process.
(3) PAs and MOAs shall not provide the SHPO, ACHP or other
consulting party with any approval authorities over any Army un-
dertakings or work products associated with execution of an NHPA
undertaking. Such authorities are beyond those provided to the
SHPO, ACHP or consulting parties under NHPA, and rest with the
installation commander. This provision equally applies to any and
all conditions associated with no adverse effect determinations made
IAW 36 CFR 800. It is recognized however, that the National Park
Service has approval authority regarding: acceptance of HABS/
HAER documentation into the Library of Congress, acceptance of
nominations for formal listing of historic properties in the National
Register of Historic Places, and has the final decision in determina-
tions of National Register eligibility.
(4) All actions requiring expenditure of funds in future fiscal
years shall be identified in PAs or MOAs as being subject to
availability of funds for purposes of compliance with the Anti-
Deficiency Act. PAs and MOAs shall stipulate that if sufficient
funds are not made available to fully execute the agreement, the
installation commander shall consult with the other signatories to
either terminate or amend the PA or MOA IAW the termination and
amendment procedures set forth in the agreement.
(5) The initial Draft PAs or MOAs prepared by the installation
shall be staffed for review through the MACOM to HQDA (AEC).
If the SHPO or another consulting party prepares the PA or MOA,
the initial draft shall be likewise forwarded from the installation
commander for MACOM and HQDA review. The MACOM will
provide a technical and legal review as appropriate. HQDA (AEC)
will provide HQDA technical review and will coordinate with TJAG
(ELD) to obtain HQDA legal review. HQDA (AEC) will provide
the MACOM and installation commander with the HQDA technical
and legal reviews. When forwarded for MACOM and HQDA re-
views, draft PAs and MOAs shall be accompanied by a “For Offi-
cial Use Only” (FOUO) document prepared by the installation that
contains—
(a) Cost estimates by fiscal year and a funding plan ensuring that
the compliance schedule set in the PA or MOA can be met and that
costs for out year actions will be programmed into the Environmen-
tal Program Requirements Report and the installation Command
Budget Estimate, and
(b) Confirmation that relevant installation level activities and of-
fices, including but not limited to the installation Office of the Staff
Judge Advocate have reviewed and concur with the draft agreement.
b. Within 15 days from HQDA (AEC) receipt of the draft agree-
ment and supporting documentation, HQDA (AEC) will notify the
MACOM and installation commander that—
(1) The agreement is IAW HQDA policy, and follows appropri-
ate technical and legal practices and procedures. In such instances,
the installation shall proceed with execution of the agreement, or
(2) The agreement requires revision and that HQDA review com-
ments will be forwarded within the following 15 days, or
(3) The draft PA or MOA addresses an issue or property type
with Army-wide applicability, or that it is a precedent setting action,
or that it has major financial implications. In such instances, AEC
will advise the DEP and TJAG (ELD). The DEP may elect to be a
participant in and an Army signatory to such agreement.
c. Signature authority and procedures for finalizing NHPA PAs
and MOAs is as follows:
(1) The installation commander has signature authority for NHPA
PAs, MOAs, pertaining to Army owned and controlled Federal
properties, or actions subject to Army Federal approval, that fall
within the installation commanders area of responsibility. The DEP
has signature authority for PAs and MOAs having Army-wide
implications.
(2) In preparing final PAs and MOAs, the installation com-
mander will work cooperatively to address all MACOM and HQDA
comments on the draft agreements. Following integration of
MACOM and HQDA comments, the installation commander will
sign the agreement, obtain SHPO, MACOM (as appropriate), and
any consulting party signature, and forward the document to the
ACHP for signature. The ACHP will return the signed agreement to
the installation commander.
(3) In instances where the DEP elects to be a signatory to an
agreement, HQDA (AEC) shall act on behalf of the DEP and, as
needed, in coordination with MACOMs, installations, SHPO and
ACHP in development of the compliance agreement. The DEP shall
sign the final agreement. HQDA(AEC) will then staff the agreement
to the SHPO, any consulting parties, and the ACH for their
signature.
(4) A copy of the fully executed PA or MOA will be provided to
the MACOM and HQDA (AEC) by the installation.
d. The following procedures shall be complied with when Section
106 consultation is terminated IAW 36 CFR 800.5(e)(6), and the
installation intends to proceed with an undertaking that will have an
adverse effect on an historic property absent a PA or MOA.
(1) In such instances, the installation commander shall request
ACHP comments IAW the procedures in 36 CFR 800.6(b), and this
regulation. The ACHP provides their comments in this circumstance
directly to the Secretary of the Army. The Secretary of the Army,
IAW NHPA Section 110(1), must document all decisions to proceed
with an undertaking that will have an adverse effect on an historic
property absent an agreement, and may not delegate this documenta-
tion responsibility. Such documentation is provided through a re-
sponse directly for the Secretariat to the ACHP. Once the Secretary
of the Army has provided such documentation in response to the
ACHP’s comments, the installation commander may proceed with
the undertaking IAW the Secretary of the Army’s documentation.
(2) To provide advance notice of termination actions to the Sec-
retariat, the installation commander shall provide notification
through the MACOM to HQDA (AEC) will provide the DEP and
TJAG (ELD) with an analysis of the termination action. The DEP
will advise the Army FPO of such actions in preparation for the
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required Secretariat response to ACHP comments. Installation com-
manders should be prepared to provide HQDA any and all other
requested information regarding the termination of consultation.
e. Installation commanders may seek a 1-year variance from
HQDA review of all NHPA MOAs and PAs. To justify a 1-year
variance from HQDA MOA review, the installation commander
must have available both technical and legal personnel who have
prior experience in developing and implementing NHPA Section
106 compliance agreements. Requests for variance shall be made as
follows:
(1) Installation requests for the 1-year variance from HQDA
MOA and PA review requirements are made by memorandum
through the MACOM to HQDA (AEC). The request for variance
shall include information on the installation staff personnel meeting
the above requirement and any anticipated MOAs and PAs that may
be developed. The request must include the installation command-
er’s guarantee that HQDA policies and principles established by
chapter 3-1.a (1-4) of this regulation shall be followed in prepara-
tion and execution of MOAs and PAs that when said policies and
procedures cannot be met, the standard staffing procedures at chap-
ter 3-1.a (5) of this regulation will be followed.
(2) HQDA (AEC) will review and will forward the request for
variance with an analysis and recommendation to the DEP and
TJAG (ELD). Variance from HQDA review of MOAs and PAs are
provided by the DEP for the specified one-year period. Installation
commanders may request an annual renewal of the 1-year variance
through the procedures in section 3-1e(1).
f. In instances where an installation is identified and included in
the Base Realignment and Closure (BRAC) program, MACOM
commanders will function as the installation commander for the
purposes of NHPA compliance and PA and MOA staffing. Staffing
procedures established by the Army Base Closure Office (DAIM-
BO) for BRAC NHPA PAs and MOAs shall be followed for BRAC
agreements.

3–2. National Register of Historic Places Determinations of
Eligibility, Nominations, and Delisting
a. Determinations of Eligibility. MACOM commanders shall es-
tablish a process for review of the installation determinations of
National Register eligibility of properties that are made IAW 36
CFR 800.4(c). The MACOM process will provide for review of
such determinations prior to their transmittal to the SHPO, and shall
be integrated with installation undertakings in a manner that does
not impact project schedules or costs.
b. Disagreement regarding National Register Eligibility. When a
disagreement regarding an historic property’s eligibility for the Na-
tional Register occurs between the installation and the SHPO in the
context of a NHPA Section 106 undertaking and compliance with
36 CFR 800.4(c), the installation shall request a determination of
eligibility from the Keeper of the National Register IAW 36 CFR 63
and provide a description of the property, statement of significance
or lack thereof, photographs, and the written opinion of the SHPO
regarding the eligibility of the property. A draft copy of such re-
quests may be provided through the MACOM to HQDA (AEC) for
technical review and comment prior to the installation’s submittal to
the Keeper of the National Register.
c. Nominations for formal listing of historic properties in the
National Register of Historic Places. In such instances, following
information and staffing procedures shall be followed:
(1) Financial and personnel resources shall be primarily devoted
to the operation of the internal cultural resources program for identi-
fication, evaluation to determine National Register eligibility, and
management of historic properties. Formal nomination of historic
properties to the Keeper of the National Register of Historic Places
in not a high program priority. Formal nomination for listing in the
National Register makes no difference in the way historic properties
are managed, and diverts scarce resources away from other cultural
resources management activities. The Army will formally nominate
only those properties that it intends to interpret, commemorate, or
otherwise actively manage as sites of popular interest that are nor-
mally open to the general public.
(2) Installations will coordinate their intention to formally nomi-
nate a property for listing on the National Register through the
MACOM to HQDA (AEC) for review and comment prior to the
commitment of funds or personnel resources for preparation of Na-
tional Register nomination packages. When the above policy thresh-
old for formal nomination of a historic property to the National
Register is met, all materials required to nominate historic properties
for listing in the National Register prepared by the installation are
forwarded to the SHPO for review and for SHPO signature. The
SHPO shall be requested to return the signed nomination to the
installation commander.
(3) The installation commander will forward the nomination with
the SHPO’s signature through the MACOM to HQDA(AEC).
HQDA (AEC) will review the nomination and MACOM comments
and will provide a recommendation to the DEP. Upon DEP concur-
rence, he or she will provide the DASA (ESOH) with the nomina-
tion and a request for signature. The DASA (ESOH), as the Army
FPO, has the Army signature authority for all nominations and
forwards nominations to the Keeper of the National Register for
formal listing in the National Register of Historic Places.
d. Removal of Historic Properties from the National Register.
Installation commanders may request that historic properties be re-
moved from the National Register IAW 36 CFR 60.15. In such
instances, following information and staffing procedures shall be
followed:
(1) The installation commander will prepare documentation
detailing the grounds for removal of the historic property from the
National Register as specified in 36 CFR 60.15.
(2) The installation commander will notify and obtain the com-
ments of the SHPO and forward those comments with the documen-
tation detailing the grounds for removal through the MACOM to
HQDA (AEC). HQDA (AEC) will review the documentation and
provide a recommendation to the DEP. Upon DEP concurrence, he
or she will provide the DASA (ESOH) with the documentation and
a request that a petition for removal of the historic property from the
National Register be made to the Keeper of the National Register.
The DASA (ESOH) will forward such petitions to the Keeper of the
National Register.

3–3. NAGPRA CAs and Plans of Action
a. When the installation commander requires a CA or Plan of
Action, the following principles and procedures shall be followed:
(1) NAGPRA CAs and Plans of Action should contain a compli-
ance schedule with deadlines, procedures for schedule and task
modification, dispute resolution and termination, standard consulta-
tion procedures for land management activities that could result in
intentional or inadvertent discovery of cultural items, and determina-
tion of custody for cultural items. Pursuant to NAGPRA and 43
CFR 10, the consulting parties are to be provided review and con-
sultation regarding the land management activities that are the sub-
ject of the agreement. CAs and Plans of Action will not provide the
consulting parties with any approval authorities over any Army land
management activities or work products associated with execution
of the land management activities. Such approval authority is be-
yond the authority provided to consulting parties under NAGPRA
and rests with the installation commander. Plans of Action shall
contain all documentation requirements specified in 43 CFR
10.5e.(1-9).
(2) All actions requiring expenditure of funds in future fiscal
years will be identified in the agreement as being “subject to availa-
bility of funds” (SAF) for purposes of compliance with the Anti-
Deficiency Act.
(3) Initial draft CAs and Plans of Action will be staffed through
the MACOM to HQDA (AEC) for review. The installation shall
ensure that the initial draft CA or Plan of Action that is coordinated
with the MACOM and HQDA (AEC) embodies and reflects the
prior NAGPRA consultations between the installation commander
and the head of the Federally-recognized Indian tribal government
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or Native Hawaiian organization. AEC will provide HQDA techni-
cal review and will coordinate with TJAG (ELD) for HQDA legal
review. HQDA (AEC) will provide the HQDA technical and legal
review comments to the MACOM and installation commander.
When forwarded for MACOM and HQDA (AEC) review, such draft
agreements shall be accompanied by a “For Official Use Only”
(FOUO) document prepared by the installation that contains—
(a) Cost estimates by fiscal year and a funding plan ensuring that
the compliance schedule set in the CA or Plan of Action can be met
and that costs for out year actions will be programmed into the
Environmental Program Requirements Report (formerly the RCS
1383 report) and the installation Command Budget Estimate.
(b) Confirmation that relevant installation level activities and of-
fices, including but not limited to the installation Office of the Staff
Judge Advocate have reviewed and concur with the agreement.
b. Within 15 days from HQDA (AEC) receipt of the draft agree-
ment and supporting memorandum, HQDA (AEC) will notify the
MACOM and installation that—
(1) The agreement is IAW HQDA policy, and follows appropri-
ate technical and legal practices and procedures. In such instances,
the installation should proceed with execution of the agreement, or
(2) The agreement requires revision and that HQDA review com-
ments will be forwarded within the following 15 days, or
(3) The draft CA or Plan of Action addresses an issue with
Army-wide applicability, or that it is a precedent setting action, or
that it has major financial implications. In such instances, AEC will
advise the DEP and TJAG (ELD), and the DEP may elect to be a
participant in and an Army signatory to the agreement.
c. Signature authority and procedures for finalizing CAs and
Plans of Action are as follows:
(1) The installation commander has signature authority for CAs
and Plans of Action pertaining to Army owned and controlled Fed-
eral properties, or actions subject to Army Federal approval that fall
within the installation commanders area of responsibility. The DEP
has signature authority for CAs and Plans of Action having Army-
wide implications.
(2) In preparing final CAs and Plans of Action the installation
commander will address all MACOM and HQDA comments on the
draft agreements. Following integration of MACOM and HQDA
comments, the installation commander will sign the agreement and
forward the document to the MACOM (as appropriate), and Federal-
ly-recognized Indian tribe or Native Hawaiian organization for their
signature. A signed copy will be requested and returned to the
installation commander.
(3) In instances where the DEP elects to be a signatory to an
agreement, HQDA (AEC) shall act on behalf of the DEP and in
coordination with the installations, MACOMs, and Indian Tribe or
Native Hawaiian organization in development of the agreement.
HQDA (AEC) will staff such agreements to the Federally-recog-
nized Indian tribes or Native Hawaiian organizations for signature.
d. Installation commanders may seek a 1-year variance from
HQDA review of all NAGPRA Plans of Action and CAs. To justify
a 1-year variance from HQDA review, the installation commander
must have technical and legal personnel on staff who have signifi-
cant experience in NAGPRA compliance activities or in consulta-
tion with Indian tribes or Native Hawaiian organizations.
(1) Requests for variance from HQDA Plan of Action review
requirements are made by memorandum through the MACOM to
HQDA (AEC). The request for variance shall include information
on the staff personnel meeting the above requirement and any antici-
pated Plans of Action that may be developed. The request must
include the installation commander’s guarantee that HQDA policies
and principles established by paragraph 3-3a(1-2) of this regulation
shall be followed in preparation and execution of Plans of Action
and CAs and that when said policies and procedures cannot be met,
the standard staffing procedures at paragraph 3-1a(3) of this regula-
tion will be followed.
(2) HQDA (AEC) will forward the request for 1-year variance
with an analysis and recommendation to the DEP and TJAG (ELD).
Variance from HQDA review of Plans of Action and CA’s are
provided by the DEP for the specified 1-year period only. Installa-
tion commanders may request an annual renewal of the 1-year
variance through the procedures at section 3-3d(1).
e. In instances where an installation is identified and included in
the Base Realignment and Closure (BRAC) program, MACOM
commanders will function as the installation commander for the
purposes of NAGPRA compliance and CA and Plan of Action
staffing. Additional HQDA staff review of BRAC NAGPRA CAs
and Plans of Action may be required beyond those identified in this
regulation.

3–4. Cooperative Agreements and Interagency Agreements
a. As a general rule, Federal agencies, including the Army, must
engage in full and open competition IAW the Federal Acquisition
Regulation (FAR) to obtain goods and services. Congress, however,
has created exceptions to that rule through enactment of independent
statutory authority, empowering Federal agencies to procure goods
and services from other Federal agencies, states, local governments
and private nonprofit organizations through interagency or coopera-
tive agreements. Installations are hereby authorized to develop and
implement interagency agreements and or cooperative agreements,
relevant to cultural resources management, with said entities on the
basis of the following statutory authorities:
(1) Economy Act, 3l USC 1535, authorizes the Army to issue
orders to other Federal agencies to provide goods or services, so
long as the order is in the best interests of the Government, is
cheaper or more convenient than procurement under contract, and
does not conflict with another agency’s authority.
(2) Title 10 USC 2684 authorizes the Army to enter cooperative
agreement with States, local governments, or other entities for the
preservation, maintenance, and improvement of cultural resources
on military installations and for the conduct of research regarding
cultural resources on installations. (National Defense Authorization
Act for Fiscal Year 1997, Public Law No 104-210, 110 Stat. 2422,
Section 2862 (1996), adding section 2684 to Chapter 159 of title 10
of the United States Code.)
b. Agreements (for example, Interagency Agreements, Memo-
randa of Understanding, and Cooperative Agreements) have been
established between the DOD, other Federal agencies and nonprofit
organizations which provide arrangements for DOD components to
enter into implementing agreements with such agencies and organi-
zations for the attainment of mutual conservation objectives. Instal-
lation commanders and commanders of other Army activities,
utilizing relevant and appropriate statutory authority, as set forth
above, may develop and sign implementing Interagency Agreements
(IAG), Memoranda of Understanding, or Cooperative Agreements
with said entities. All IAGs and Cooperative Agreements entered
into IAW the provisions of this section must receive technical and
legal review prior to the installation commander’s signature.

3–5. Funding Cultural Resources Activities
a. HQDA policy for use of environmental funds for cultural re-
sources activities is established in “Policy and Guidelines for identi-
fying U.S. Army Environmental Program Requirements(EPR
Report)”. Part 1, item l of the EPR policy specifies projects and
activities that are not eligible for environmental funding.
(1) Projects and activities that are not eligible for environmental
funding include routine grounds maintenance such as grass mowing,
tree pruning, and landscaping, and includes those activities when
they occur in historic cemeteries.
(2) Repair, maintenance, and rehabilitation of historic properties
(including National Register eligible and listed buildings, structures,
sites, objects, landscapes, districts, and cemeteries) are not eligible
for environmental funding. In cases where repair, maintenance, and
rehabilitation activities are stipulated and required in NHPA Section
106 PAs or ICRMPs, such activities remain ineligible for environ-
mental funds. Appropriate funding sources for these activities in-
clude the Real Property Maintenance Account (RPMA).
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b. Plans and studies for historic property identification; evalua-
tion; maintenance; stabilization; repair; rehabilitation; conditions as-
sessments; and reports, are eligible for environmental funds when
such documents are developed IAW professional historic preserva-
tion standards and guidelines established by the Secretary of the
Interior.

Chapter 4
Integrated Cultural Resources Management Plans (ICRMPs)
4–1. Scope and Purpose of ICRMPs
a. An ICRMP is a 5-year plan for compliance with the require-
ments outlined in chapter 3 of this regulation. As a component of
the installation master plan, the ICRMP is the installation command-
er’s decision document for cultural resources management actions
and specific compliance procedures. ICRMPs are internal Army
compliance and management plans that integrate the entirety of the
installation cultural resources program with ongoing mission activi-
ties, allow for ready identification of potential conflicts between the
installation’s mission and cultural resources, and identify compli-
ance actions necessary to maintain the availability of mission essen-
tial properties and acreage. While ICRMPs are not required by any
statute or regulation other than this regulation, ICRMPs should ad-
dress the applicable cultural resources legal requirements as defined
by this regulation. ICRMPs are subject to NEPA analysis and docu-
mentation requirements. It is recommended that an Environmental
Assessment be prepared to implement ICRMPs. ICRMPs shall su-
persede and replace Historic Preservation Plans (HPP) prepared
under AR 420-40. ICRMPs shall be prepared IAW the guidelines in
DA Pam 200-4.
b. ICRMPs shall not be the subject of, implemented by reference
to, or included in NHPA PAs or MOAs, or NAGPRA CAs or Plans
of Action. The scope of an ICRMP includes statutes and regulations
that are beyond the statutory authority of the ACHP and SHPO, or
Indian tribes and Native Hawaiian organizations. The section of the
ICRMP that pertains to NHPA compliance may be extracted from
the ICRMP and those actions may be integrated by reference into a
NHPA PA or MOA. Similarly, the section of the ICRMP that
pertains to NAGPRA compliance may be extracted from the
ICRMP, modified, and may be integrated by reference into a
NAGPRA CA or Plan of Action. The installation’s internal operat-
ing procedures required to implement such agreements should be
found in the ICRMP. Installations my request the SHPO, Indian
tribe, or any other interested party for a nonbinding technical review
of ICRMPs outside of any statutory or regulatory requirement to
take advantage of outside expertise. Such comments should also be
obtained throughout the ICRMP NEPA review process.
c. ICRMPs shall be prepared and implemented by all Federally-
owned or -controlled Army installations having statutory and
regulatory cultural resource management responsibilities. Installa-
tions with an existing plan (Cultural Resources Management Plan
and or a Historic Preservation Plan developed IAW AR 420-40) that
was prepared less than 3 years prior to the effective date of this
regulation need not prepare an ICRMP IAW this regulation until the
3-year point is reached.
d. Installation commanders may seek a HQDA variance from
ICRMP preparation requirements. The conditions for a variance
include situations such as where the installation has conducted com-
prehensive efforts to locate and identify cultural resources following
the appropriate statutory and regulatory procedures, and the installa-
tion commander has determined that there is minimal added value
that would result from preparation of an ICRMP because there are
very limited or no cultural resources within the area of the installa-
tion commander’s responsibility. Such situations are expected to be
rare. Requests for variance with a justification statement shall be
staffed from the installation commander through the MACOM to
HQDA (AEC) for review. HQDA (AEC) will forward the request
for variance with an analysis and recommendation to the DEP and
TJAG (ELD). Variance from ICRMP requirements are provided by
the DEP.
e. Installations that have received a HQDA variance from
ICRMP preparation requirements IAW this regulation shall reevalu-
ate the need to prepare a ICRMP in conjunction with each environ-
mental audit conducted in accordance with AR 200-1.
f. Draft ICRMPs prepared by the installation commander will be
formally staffed to the MACOM for review. The installation com-
mander will consider MACOM and other comments and finalize the
ICRMP.
g. Installations scheduled for closure within 5 years pursuant to
base realignment and closure law are exempt form the ICRMP
preparation requirements of this regulation.

4–2. Content of ICRMPs
a. ICRMPs will be prepared IAW DA Pam 200-4
and will in- clude but not be limited to—
(1) Identification of all applicable legal requirements and proce-
dures for integrating compliance between the various independent
cultural resources legal requirements.
(2) Identification to the extent possible, of specific actions, proj-
ects and undertakings projected over a 5-year period that may re-
quire cultural resources legal compliance actions.
(3) Development and implementation, as appropriate, of a cul-
tural landscape approach to installation cultural resources manage-
ment and planning as described in DA Pam 200-4.
(4) A planning level survey that includes existing information on
cultural resources, development of or reference to existing historic
contexts, an archeological sensitivity assessment or archeological
predictive model, and a listing of any Federally-recognized Indian
tribes or Native Hawaiian organizations associated with the
installation.
(5) A plan for the actual field inventory and evaluation of cul-
tural resources that is prioritized according to the inventory and
evaluation requirements associated with specific installation compli-
ance requirements, such as NHPA Section 106 undertakings, that
could affect cultural resources. Any electronic spatial data produced
by inventories shall conform with the Federal Information Process-
ing Standards and spatial data standards for DOD to ensure that the
spatial data is useable in various spatial data systems.
(6) Internal procedures for consultation, survey, inventory, evalu-
ation, treatment, recordation, monitoring, emergency or inadvertent
discovery, reporting, etc., tailored for the particular conditions and
specific requirements at the installation. Interface requirements be-
tween the cultural resources management program and other pro-
gram areas (including but not limited to natural resources
management, ITAM, master planning, facilities and housing and
mission related training and testing activities) should be identified.
The coordination processes within the installation and between the
installation, MACOM, HQDA, regulatory agencies, and the inter-
ested public should also be defined.
(7) Provisions for curation of collections and records (IAW 36
CFR 79) that are, associated with NHPA undertakings, and proce-
dures to reduce the amount of materials that are accessioned and
permanently curated by the installation.
(8) Provisions for limiting the availability of cultural resource
locational information for the purposes of protecting resources from
damage.
(9) Provisions and procedures for the conduct of an economic
analysis and alternative use analysis on historic properties that are
being considered for demolition and replacement.
(10) Procedures to ensure Indian tribes and Native Hawaiian or-
ganizations are provided access to sacred sites and are consulted
when future access may be restricted or when adverse effects to the
physical integrity of the sacred site may occur.
(11) Development of standard treatment measures for cultural
resources.
(12) An estimate of resources required to execute the plan. Such
estimates must have restricted access and be “For Official Use
Only” due to protection of Government cost
estimates.
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Appendix A
References

Section I
Required Publications

AR 200–1
Environmental Protection and Enhancement. (Cited in paras 1-1-8g,
1-9h, and 4-1e.)

AR 200–2
Environmental Effects of Army Actions. (Cited in paras 1-9f, and 2-
2a.)

AR 200–3
Natural Resources, Land, Forest, and Wildlife Management. (Cited
in para 1-9f.)

DA Pamphlet 200–4
Cultral Resources Management. (Cited in para 1-9f.)

AR 405–80
Granting Use of Real Estate (Cited in para 1-9l and 2-6d.)

Section II
Related Publications
A related publication is merely a source of additional information.
The user does not have to read it to understand this regulation.

AR 15–13
Military Construction Army (MCA) Disposal of Structures.

AR 190–31
Crime Prevention Program, Department of the Army.

AR 210–20
Master Planning for Army Installations.

AR 405–10
Acquisition of Real Property and Interests Therein.

AR 405–90
Disposal of Real Estate.

AR 415–15
Military Construction, Army (MCA) Program Development).

AR 415–35
Minor Construction.

AR 420–10
Facilities Engineering: General Provisions, Organizations,Functions,
and Personnel.

AR 420–17
Real Property and Resource Management.

AR 420–22
Preventative Maintenance and Self-Help.

AR 870–20
Historical Properties and Museums.

DODI 4715.3
Environmental Conservation Program.
EPR Report
Policy and Guidance for Identifying U.S. Army Environmental
Program Requirements, ODEP

Section III Prescribed
Forms
This section contains no entries.

Section IV Referenced
Forms
This section contains no entries.

Appendix B
Federal Statutes, Regulations, Executive Orders and Presidential
Memorandum
Statutes
Abandoned Shipwreck Act of 1987 43 USC 2101-2106.
American Indian Religious Freedom Act of 1978, as amended 42
USC 1996-1996a.
Antiquities Act of 1906 16 USC 431-433; 34 Stat. 225.
Archeological and Historic Data Preservation Act of 1974 16 USC
469-469c.
Archeological Resources Protection Act of 1979 16 USC 470aa-
470ll.
Historic Sites Act of 1935 16 USC 461-467.
National Environmental Policy Act 42 USC 4321-4370c.
National Historic Preservation Act of 1966, as amended 16 USC
470-470w.
Native American Graves Protection and Repatriation Act of 1990 25
USC 3001-3013.
Federal Regulations
Advisory Council on Historic Preservation, Protection of Historic
and Cultural Properties, 36 CFR 800.
Council on Environmental Quality, Regulations Implementing the
National Environmental Policy Act, 40 CFR 1500-1508.
Department of Defense, Protection of Archeological Resources, 32
CFR 229.
Department of the Interior, Native American Graves Protection and
Repatriation Act, 43 CFR 10.
Department of the Interior, Curation of Federally-owned and Ad-
ministered Archeological Collections, 36 CFR 79.
Department of the Interior, Determinations of Eligibility for Inclu-
sion in the National Register of Historic Places, 36 CFR 63.
Department of the Interior, National Historic Landmark Program, 36
CFR 65.
Department of the Interior, National Register of Historic Places, 36
CFR 60.
Department of the Interior, Preservation of American Antiquities, 43
CFR 3.
Department of the Interior, Supplemental Regulations (per ARPA),
43 CFR 7.2.
Department of the Interior, Waiver of Federal Agency Responsibil-
ity under Section 110 of the National Historic Preservation Act, 36
CFR 78.
Executive Orders
EO 11593—Protection and Enhancement of the Cultural
Environment.
EO 13007—Indian Sacred Sites
Presidential Memoranda
Memorandum for the Heads of Executive Departments and Agen-
cies, dated April 29,1994: Government-to-Government Relations
with Native American Tribal Governments.
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Glossary

Section I Abbreviations

ACHP
Advisory Council on Historic Preservation

ACSIM
Assistant Chief of Staff for Installation
Management

AEC
Army Environmental Center

AHPA
Archeological and Historical Preservation
Act

AIRFA
American Indian Religious Freedom Act

ARNG
Army National Guard

ARPA
Archeological Resources Protection Act

CA
Comprehensive Agreement (per 43 CFR 10)

CFR
Code of Federal Regulations

CRM
Cultural Resources Manager

DASA(ESOH)
Deputy Assistant Secretary of the Army (En-
vironment, Safetyand Occupational Health)

DEP
Director of Environmental Programs

FOUO
For Official Use Only

FPO
Federal Preservation Officer

HPP
Historic Preservation Plan

HQDA
Headquarters, Department of the Army

IAW
In accordance with

ICRMP
Integrated Cultural Resources Management
Plan

ITAM
Integrated Training Area Management
(program)

MACOM
major Army command
MCA
Military Construction Army

MOA
Memorandum of Agreement (per 36 CFR
800)

NAGPRA
Native American Graves Protection and Re-
patriation Act

NEPA
National Environmental Policy Act of 1969,
as amended

NGB-ARE
National Guard Bureau, Environmental
Programs

NHPA
National Historic Preservation Act of 1966,
as amended

NPS
National Park Service

PA
Programmatic Agreement (per 36 CFR 800)

SHPO
State Historic Preservation Officer

TJAG (ELD)
The Judge Advocate General (Environmental
Law Division)

USACE
U.S. Army Corps of Engineers

Section II Terms

Cultural Resources
Historic properties as defined by the NHPA,
cultural items as defined by NAGPRA, ar-
cheological resources as defined by ARPA,
sacred sites as defined in EO 13007 to which
access is afforded under AIRFA, and collec-
tions and associated records as defined in 36
CFR 79.

Integrated Cultural Resources
Management Plan (ICRMP)
A 5-year plan developed and implemented by
an installation commander to provide for the
management of cultural resources in a way
that maximizes beneficial effects on such re-
sources and minimizes adverse effects and
impacts without impeding the mission.

Cultural Resources Management Program
Activities carried out under the authority of
this regulation to comply with Federal stat-
utes and regulations pertaining to cultural
resources.

Indian Tribe
Any tribe, band, nation, or other organized
Indian group or community of Indians, in-
cluding any Alaska Native village or corpora-
tion as defined in or established by the
Alaska Native Claims Settlement Act (43
USC 1601 et seq.) which is recognized as
eligible for special programs and services
provided by the United States to Indians be-
cause of their status as Indians. Such ac-
knowledged or “Federally-recognized” Indian
tribes exist as unique political entities in a
government-to-government relationship with
the United States.

National Register of Historic Places
(National Register)
The nation’s inventory of known historic
properties that have been formally listed by
the NPS. The National Register of Historic
Places is administered by the NPS on the
behalf of the Secretary of the Interior. Na-
tional Register listings include districts, land-
scapes, sites, buildings, structures, and
objects that meet the set of criteria found in
36 CFR 60.4.

Native Hawaiian Organization
Any organization that serves and represents
the interests of, has a primary stated purpose
to provide services to, and has expertise in
Native Hawaiians and Native Hawaiian af-
fairs. Such organizations must include the
Office of Hawaiian Affairs and Hui Malama
I Na Kupuna ’O Hawai’i Nei.

Undertaking
Any project, activity, or program that can
result in changes in the character or use of
historic properties as defined by the NHPA.
The project, activity or program must be
under the direct or indirect jurisdiction of the
installation commander. Undertakings include
new and continuing projects, activities, or
programs and any of their elements not
previously considered under Section 106 of
the NHPA.

Section III
Special Abbreviations and Terms
This section contains no entries.
1
2
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118!
Index
This index is organized alphabetically by
topic and subtopic. Topics and subtopics
are identified by paragraph number.
American Indian Religious Freedom Act,
2-4
Antiquities Act, 2-6
Archeological investigation permits, 2-6
Archeological collection curation, 2-7
Archeological Resources Protection Act
Applicability of NAGPRA procedures, 2-6
Definition of federal land manager, 2-6
Permit procedures, 2-6
Consultation
American Indian Religious Freedom Act,
2-4
National Historic Preservation Act, 2-3
Native American Graves Protection and
Repatriation Act, 2-5
Cultural Resources Management Program,
2-1
Executive Order 13007, 2-4
Inadvertent discovery of human remains,
2-5
Indian sacred sites
Access to, 2-4
Avoidance of damage to, 2-4
Protection measures, 2-4
Integrated Cultural Resources
Management Plan
Description of, 4-1
Required contents, 4-2
Staffing procedures, 4-1
Intentional excavations, 2-5, 2-6
National Environmental Policy Act, 2-2
National Historic Preservation Act
Applicability of NAGPRA procedures, 2-3
Notice of foreclosure, 2-3
Procedures for eligibility determinations,
nominations, and delisting, 3-2
Section 106 Programmatic Agreements/
Memoranda of Agreement, 3-1
Section 110 requirements, 2-3
Native American Graves Protection and
Repatriation Act
Disputed ownership, 2-5
Federally-recognized tribes, 2-5
Inadvertent discovery of cultural items/
human remains, 2-5
Intentional excavation of cultural items/
human remains, 2-5
Summary, inventory and repatriation of
collections, 2-5
Metal detectors, use of, 2-6
Presidential Memorandum on Native
American Relations, 2-8
Responsibilities
Assistant Chief of Staff for Installation
Management, 1-5
Chief, National Guard Bureau, 1-7
Director, Army National Guard, 1-7
Deputy Assistant Secretary of the Army
(Environment, Safety and Occupational
Health), 1-4
Installation Commanders, 1-9
Judge Advocate General, 1-6
MACOM Commanders, 1-8

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APPENDIX C

Secretary of Navy Instruction (SECNAVINST) 4000.35A
Department of the Navy Cultural Resources Program

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APPENDIX D

Air Force Instruction 32-7065
Civil Engineering, Cultural Resources Management Program

NOTICE: This publication is available digitally on the AFDPO WWW site at:
http://www.e-publishing.af.mil.
COMPLIANCE WITH THIS PUBLICATION IS MANDATORY
BY ORDER OF THE SECRETARY
OF THE AIR FORCE
AIR FORCE INSTRUCTION 32-7065
1 JUNE 2004
Civil Engineering
CULTURAL RESOURCES MANAGEMENT
PROGRAM
OPR: HQ AFCEE/TDI (Dr. James D. Wilde) Certified by: HQ USAF/ILEV (Col Daly)
Supersedes AFI 32-7065, 13 June 1994 Pages: 39
Distribution: F
This Instruction supplements U.S. Air Force policy for managing cultural resources to support the mili-
tary mission and to meet legal compliance requirements (see Attachment 1). It implements AFPD 32-70,
Environmental Quality and DoD Instruction 4715.3, Environmental Conservation Program, May 3, 1996.
It establishes guidelines for managing and protecting cultural resources on property affected by Air Force
operations in the United States and US territories and possessions. Use AFI 32-7006, Environmental Pro-
grams in Foreign Countries, and the relevant Final Governing Standards (FGS) for managing cultural
resources on overseas installations. For locations without a FGS, refer to the DoD Instruction 4715.5-G,
DoD Overseas Environmental Baseline Guidance Document. For deployment situations, refer to AFH
10-222, Volume 4: Environmental Guide for Contingency Operations. See Attachment 1 for acronyms
and abbreviations and definitions of terms used in this instruction. Users should send comments and sug-
gested improvements on AF Forms 847, Recommendations for Change of Publications, through channels
to HQ USAF/ILEV, 1260 Air Force Pentagon, Washington DC 20330-1206. Ensure that all records cre-
ated as a result of processes prescribed in this publication are maintained in accordance with AFPD 37-1,
Information Management, and AFMAN 37-123, Management of Records, and are disposed of in accor-
dance with the Air Force Records Disposition Schedule (RDS) located at https://webrims.amc.af.mil
SUMMARY OF REVISIONS
This document is substantially revised and must be completely reviewed.
This is a revised publication of AFI 32-7065, dated 13 June 1994. Major revisions include a complete
reorganization, expanded descriptions of Air Force organizational responsibilities, updated and expanded
sections on compliance requirements, and more complete information and guidance on managing Air
Force cultural resources. Much of the 1994 Instruction is incorporated and updated in five chapters, rather
than the eight chapters of the 1994 Instruction. The five chapters in this document are organized around
three principal actions associated with cultural resources compliance: Inventory, Project Review, and
General Management. In addition, this revision contains only two attachments, instead of the five attach-
ments to the 1994 Instruction. The first attachment is titled Glossary of References and Supporting Infor-
2 AFI32-7065 1 JUNE 2004
mation, which includes a comprehensive set of references, terms, acronyms, and authorizing legislation,
regulations, and orders. The second attachment, titled Guidelines for Preparing Integrated Cultural
Resources Management Plans is a greatly expanded and updated version of guidelines in the 1994 Instruc-
tion.
Chapter 1— HOW TO USE THIS INSTRUCTION 4
1.1. Background: ............................................................................................................... 4
1.2. Goals: ......................................................................................................................... 4
1.3. Policies: ...................................................................................................................... 5
1.4. Responsibilities: ......................................................................................................... 5
Chapter 2— INVENTORY 9
2.1. Identification: .............................................................................................................9
2.2. Evaluation: .................................................................................................................9
2.3. Completion of NHPA Section 110 Inventory: ........................................................... 10
2.4. Unevaluated Resources: ............................................................................................. 10
2.5. National Register of Historic Places .......................................................................... 11
2.6. Removal of Listed Historic Places from the National Register: ................................ 11
Chapter 3— PROJECT REVIEW 13
3.1. The NHPA Section 106 Process: ............................................................................... 13
3.2. Consultation with Native Americans: ........................................................................ 15
3.3. Environmental Impact Analysis Process (EIAP): ...................................................... 15
3.4. NEPA Categorical Exclusions (CATEXes): .............................................................. 16
3.5. Engineering Work Order Review: ............................................................................. 16
3.6. Military Construction Planning and Design: ............................................................. 16
3.7. Repair and Maintenance Activities: ........................................................................... 16
3.8. Real Property Actions: ............................................................................................... 17
3.9. Inadvertent Discoveries of Archaeological Objects or Native American
Human Remains and Cultural Items: ........................................................................ 17
3.10. NAGPRA Plans of Action: ........................................................................................ 18
Chapter 4— GENERAL MANAGEMENT 20
4.1. Aircraft Wreck Sites: ................................................................................................. 20
4.2. Archaeological Resources Protection: ....................................................................... 20
4.3. Base Comprehensive Planning Process: .................................................................... 20
AFI32-7065 1 JUNE 2004 3
4.4. Confidentiality Requirements: ................................................................................... 21
4.5. Cooperative Agreements: .......................................................................................... 21
4.6. Care of Archaeological and Historic Property Collections and Records: ................. 21
4.7. Environmental Compliance Assessment and Management Program (ECAMP): ..... 22
4.8. Funding Requirements: .............................................................................................. 22
4.9. Information Management: ......................................................................................... 23
4.10. Integrated Cultural Resource Management Plans (ICRMPs): ................................... 23
4.11. Integrated Natural Resource Management Plan (INRMP): ....................................... 24
4.12. Metal Detecting: ........................................................................................................ 24
4.13. Public Awareness: ...................................................................................................... 24
4.14. Reports: ...................................................................................................................... 24
4.15. Sacred Sites Access and Protection: .......................................................................... 24
4.16. Static Displays: .......................................................................................................... 25
4.17. Personnel: Qualifications, Training, Certification, and Professional Development: . 25
4.18. Waivers and Exemptions: .......................................................................................... 26
Chapter 5— DOD MEASURES OF MERIT (MOM). 27
5.1. Assessments: .............................................................................................................. 27
5.2. Review Criteria: ......................................................................................................... 27
5.3. Forms Adopted: ......................................................................................................... 27
Attachment 1— GLOSSARY OF REFERENCES AND SUPPORTING INFORMATION 28
Attachment 2— GUIDELINES FOR PREPARING INTEGRATED CULTURAL
RESOURCES MANAGEMENT PLANS 35
4 AFI32-7065 1 JUNE 2004
Chapter 1
HOW TO USE THIS INSTRUCTION
1.1. Background:
1.1.1. Cultural Resources. Cultural resources include “historic properties” as defined in the
National Historic Preservation Act (NHPA), Title 16. United States Code, section 470, et seq., (16
U.S.C. §470, et seq.; “cultural items” as defined in the Native American Graves Protection and Repa-
triation Act (NAGPRA), 25 U.S.C. §§3001-3013; “archaeological resources” as defined in the Archae-
ological Resources Protection Act (ARP A), 16 U.S.C. §§470aa-470mm; and “sacred sites” as defined
in Executive Order (E.O.) 13007, Indian Sacred Sites, May 24, 1996. Cultural resources are often gen-
erally referred to as "heritage resources." "Historic properties" are cultural resources that are eligible
for listing to the National Register of Historic Places (National Register).
1.1.2. Cultural Resources Program. Cultural Resources program management incorporates a suite
of specific methods, techniques, policies, plans, and practices that an agency uses to meet its respon-
sibilities regarding Cultural Resources Management and historic preservation. The Air Force program
is executed at Major Commands (MAJCOMs) and installations.
1.1.3. Cultural Resources Manager. The person appointed by a commander on a primary or collat-
eral duty basis to manage the installation’s or MAJCOM’s cultural resources program.
1.1.4. Legal Requirements. Federal statutes, regulations, guidance documents and Executive Orders
cited in Attachment 1 provide the legal basis of the Air Force's compliance responsibilities for man-
aging cultural resources. Air Force installations and organizations must comply with state and local
cultural resources laws when sovereign immunity has been waived in relevant federal statutes. Even if
sovereign immunity has not been waived, Air Force installations are encouraged to comply with rele-
vant state and local cultural resources standards and requirements where they do not conflict with fed-
eral requirements and the Air Force mission, and compliance with such non-mandatory state and local
requirements does not violate fiscal law restrictions. Consult with the Staff Judge Advocate’s office to
determine whether or to what extent sovereign immunity may have been waived and to determine
whether any fiscal law principles may prevent or limit compliance with state or local requirements
when sovereign immunity has not been waived.
1.1.5. Requirements for managing cultural resources at Air Force installations are defined in this reg-
ulation. Further detailed requirements can be found in the laws or regulations cited in this Instruction
and listed in Attachment 1.
1.1.6. Environmental Management System. Consistent with Executive Order (E.O.) 13148, Green-
ing Government Through Leadership in Environmental Management, April 21, 2000, Air Force
installations will develop and implement an environmental management system to sustain, restore,
and modernize natural infrastructure to support mission capability. The system will be compatible
with and support the Air Force Environment, Safety, and Occupational Health Management System
(ESOHMS). All Air Force installations and facilities will comply with the goals of E.O. 13148 and
Air Force EMS interim guidance.
1.2. Goals:
AFI32-7065 1 JUNE 2004 5
1.2.1. The Air Force will identify, manage, and maintain its important cultural resources in a spirit of
stewardship for the benefit of this and future generations of Americans.
1.2.2. The Air Force will endeavor to integrate cultural resources stewardship with the needs of its
primary military mission.
1.3. Policies:
1.3.1. Air Force personnel must comply with the Federal statutes, regulations, Executive Orders, and
Presidential Memoranda listed in Attachment 1, and must ensure that mission requirements are car-
ried out in accordance with these requirements.
1.3.2. Air Force personnel must comply with relevant state and local cultural resources laws and reg-
ulations as set forth in ¶1.1.4., Legal Requirements.
1.3.3. The keys to the successful integration of Air Force mission requirements and cultural resources
compliance and management responsibilities are early planning and coordination.
1.3.4. The installation commander will develop and use the Integrated Cultural Resources Manage-
ment Plan (ICRMP) to comply with mandated cultural resources management requirements. (See
¶4.10. and the ICRMP definition in Attachment 1.)
1.3.5. Inventory, Project Review, and General Management are the three principal actions associated
with cultural resources compliance. Minimal compliance requirements for each action are summa-
rized in this Instruction.
1.3.6. Timeliness. The consultation process, where applicable, for all proposed projects affecting cul-
tural resources on an installation will be conducted so as not to negatively impact the military mission,
project schedule or costs. Such consultations will be initiated at the earliest practicable stage in the
Environmental Impact Analysis Process, and unless extraordinary circumstances prevent it, will be
completed prior to finalizing any NEPA documents (Categorical Exclusion (CATEX) determination,
Environmental Assessment/Finding of No Significant Impact or Environmental Impact Statement).
1.4. Responsibilities:
1.4.1. The Secretary of the Air Force (SAF)
1.4.1.1. Documents decisions to proceed with Air Force undertakings that adversely affect his-
toric properties when the installation commander has been unable to reach agreement with the
Advisory Council on Historic Preservation (hereafter referred to as Council) or with the State His-
toric Preservation Officer (SHPO).
1.4.2. The Deputy Assistant Secretary of the Air Force for Environment, Safety and Occupational
Health (SAF/IEE):
1.4.2.1. Is the Air Force Federal Preservation Officer (FPO) as designated by the Assistant Secre-
tary of the Air Force (Installations, Environment, and Logistics (SAF/IE).
1.4.2.2. Coordinates Air Force cultural resources compliance and policy with the other services to
explore common areas of interest and prevent duplication of effort.
1.4.2.3. Nominates Air Force properties to the Department of the Interior for listing on the
National Register.
6 AFI32-7065 1 JUNE 2004
1.4.2.4. Approves departmental policies for cultural resources compliance and management.
1.4.2.5. Serves as the principal Air Force representative and advocate for cultural resources com-
pliance and policy with the Office of the Secretary of Defense (OSD), Federal agencies, and the
Congress.
1.4.3. Deputy General Counsel for Installations and Environment (SAF/GCN):
1.4.3.1. Provides legal oversight, coordination, review and counsel, as appropriate, concerning
cultural resources laws, regulations, policies, and directives to the SAF and Air Staff, the Civil
Engineer (HQ USAF/ILE), the Air Force Legal Services Agency Environmental Law & Litigation
Division (AFLSA/JACE), Major Commands (MAJCOMs), and the Air Force Center for Environ-
mental Excellence (HQ AFCEE).
1.4.4. The Civil Engineer (HQ USAF/ILE):
1.4.4.1. Oversees execution of Air Force cultural resources policy and the Air Force cultural
resources program.
1.4.4.2. Responds to congressional inquiries in coordination with SAF/LL.
1.4.4.3. Reviews and comments on proposed legislation in coordination with SAF/LL and SAF/
GCN.
1.4.4.4. Ensures compliance with cultural resources program requirements.
1.4.4.5. Advocates for cultural resources program funding in the budget process.
1.4.4.6. Approves cultural resources proposals for DoD Legacy Program funding.
1.4.4.7. Approves cultural resources cooperative agreements with other agencies and branches of
government.
1.4.4.8. Assesses the effects of Air Force actions outside the U.S. on World Heritage List proper-
ties or the applicable country’s equivalent of the NHPA, for purposes of avoiding or mitigating any
adverse effects (Federal Undertakings Outside the United States; Mitigation of Adverse Effects,
16 USC 470a-2).
1.4.4.9. Reviews NHPA Section 106 (16 U.S.C. §470f) consultation actions forwarded by MAJ-
COMs for important Air Force-wide policy implications.
1.4.5. The Air Force Center for Environmental Excellence (HQ AFCEE):
1.4.5.1. Provides technical advice and support to all Air Force activities for executing cultural
resource management requirements.
1.4.5.2. Represents the Air Force on the DoD Integrated Process Team (IPT) for Curation of
Archaeological Collections.
1.4.5.3. Prepares the annual Air Force Federal Archaeological Report to Congress (RCS:
HAF-ECS(A)0309).
1.4.5.4. Develops guidelines, fact sheets, and other documents to assist execution of the Air Force
Cultural Resources Management Program.
1.4.6. The Air Force Historian (HQ USAF/HO):
AFI32-7065 1 JUNE 2004 7
1.4.6.1. Reviews installation-generated National Register nominations or eligibility determina-
tions for static displays or other properties owned and managed by the Air Force Museum System
(USAFMS).
1.4.6.2. Acquires, controls, and manages items of the Air Force’s military heritage (per AFI
84-103, Museum System). See ¶1.4.10.3. for a list of possible items.
1.4.7. MAJCOMs (includes the Air National Guard Readiness Center and other organizations HQ
USAF designates as "MAJCOM equivalent."):
1.4.7.1. Provide technical support and advice to their installation cultural resources managers.
1.4.7.2. Ensure that cultural resource management programs are implemented at their installa-
tions.
1.4.7.3. Designate a qualified command cultural resource manager (CRM) to execute program
requirements.
1.4.7.4. Review installation Integrated Cultural Resource Management Plans (ICRMPs) every
five years.
1.4.7.5. Review installation compliance agreements.
1.4.7.6. Review installation National Register nominations and forward to HQ USAF/ILE.
1.4.7.7. Review and validate, in conjunction with the command JA, each installation’s cultural
resources funding requirements; compile them in the command's Program Objective Memoran-
dum (POM) annually.
1.4.7.8. Maintain a data file for all command cultural resources.
1.4.7.9. Maintain a record of cultural resources training and certification for CRMs on their instal-
lations.
1.4.7.10. Monitor consultations under Section 106 of the NHP A for actions involving more than
one installation or MAJCOM.
1.4.8. Installation Commanders:
1.4.8.1. Approve and implement the installation's ICRMP.
1.4.8.2. Consult, as required by Federal law or regulation, Executive Order, DOD or Air Force
policy or regulation, with leaders of Federally recognized Indian Tribes, Alaska Native Villages,
and Native Hawaiian Organizations whose members are affiliated with lands controlled by the
installation (see definition of Indian Tribes, Attachment 1).
1.4.8.3. Monitor consultations under Section 106 of the NHP A for activities and property under
their control and sign ICRMPs, Programmatic Agreements (PA) or Memoranda of Agreement
(MOA). Forward draft agreements with other Federal or state agencies or Tribes through channels
to AF/ILE for review and coordination with SAF/IEE before signing. SAF/IEE may determine the
signature level for such agreements on a case-by-case basis.
1.4.8.4. Establish government-to-government relationships with Indian Tribes as necessary and in
accordance with DOD and Air Force policy and guidance.
8 AFI32-7065 1 JUNE 2004
1.4.8.5. Ensure the installation's cultural resources program is reviewed annually by the Environ-
mental Protection Committee.
1.4.9. Base Civil Engineers (BCE) or Environmental Directors (in Air Force Materiel Command
[AFMC]):
1.4.9.1. Issue ARP A Permits to qualified applicants and provide a copy of the signed permit to HQ
AFCEE (see Section 4.2).
1.4.9.2. Designate a qualified installation CRM.
1.4.9.3. Advise the installation commander of proposed actions that may result in the potential
adverse effects to historic properties.
1.4.9.4. Serve as the Federal agency official with responsibility for installation compliance with
NAGPRA.
1.4.9.5. Serve as the Federal agency official with management authority over archaeological col-
lections and associated records.
1.4.10. Installation Cultural Resource Managers (CRMs):
1.4.10.1. Develop, implement, and maintain an ICRMP for the installation.
1.4.10.2. Locate, inventory, evaluate, and recommend the nomination of eligible properties on the
installation to the National Register.
1.4.10.3. Identify items of potential importance for Air Force history to the USAFMS. Such items
may include aerospace vehicles, weapons, equipment, supplies, personal property, and other phys-
ical manifestations of the Air Force's heritage (see AFPD 84-1, Historical Information, Property,
and Art,; and AFI 84-103).
1.4.10.4. Ensure that all proposed actions that may affect cultural resources are identified early in
the planning process and coordinated with appropriate regulatory authorities. See Chapter 3 for
processes to be followed.
1.4.10.5. Monitor the work of contractors on the installation to ensure compliance with Air Force
cultural resource requirements.
1.4.10.6. Coordinate with installation personnel, the SHPO (or Tribal Historic Preservation
Officer [THPO]) the Council, Indian Tribal representatives, and others as appropriate to identify
significant cultural resources, evaluate potential impacts, and reduce, avoid or mitigate adverse
effects through memoranda of agreement (MOAs). Any prescribed action involving the SHPO
applies equally to the THPO where appropriate. See definition of Tribal Historic Preservation
Officer in Attachment 1.
1.4.10.7. Conduct public awareness and education programs.
1.4.10.8. Review all installation projects for compliance with this Instruction and with Federal
cultural resource laws.
1.4.10.9. Develop and maintain a cultural resources management database.
AFI32-7065 1 JUNE 2004 9
Chapter 2
INVENTORY
2.1. Identification:
2.1.1. Inventory [per NHP A, Section 110(a)(2)(A), 16 U.S.C. §470h-2(a)(2)(A)] cultural resources
under control of the installation through identification and evaluation methods defined in:
2.1.1.1. Title 36, Code of Federal Regulations (CFR), Part 800 (36 CFR § 800), Protection of His-
toric Properties, §800.4.
2.1.1.2. 48 Federal Register 44716-44742 (29 Sept 1983), Archeology and Historic Preservation:
Secretary of the Interior's Standards and Guidelines.
2.1.2. Archaeological Sampling.
2.1.2.1. Installations will survey their accessible land area for cultural resources. For larger instal-
lations and ranges (i.e., greater than 200,000 acres) appropriate sampling surveys will be con-
ducted to predict the numbers, types, natures, and locations of archaeological resources on lands
not surveyed.
2.1.2.2. Work with SHPO and MAJCOM to develop sampling survey methods.
2.1.2.3. Plan and program annual identification efforts on large installations and ranges to com-
plete a MAJCOM-approved level of sampling survey each year.
2.1.3. Level of Effort. Program in conjunction with installation long range plans to ensure that identi-
fication focuses first on areas where future construction and development is most imminent.
2.1.4. Identify, or predict through sampling, the location of archaeological sites, artifacts, districts,
and landscapes on Air Force controlled property.
2.1.5. Identify all historic buildings, structures, districts, and landscapes on Air Force controlled
lands.
2.1.5.1. Historic buildings and structures typically are older than 50 years of age.
2.1.5.2. Cold War resources were built or used by the Air Force between 1946 and 1989.
2.1.5.3. Historic landscapes include but are not limited to significant topography, vegetation
(plants, trees, shrubs, and lawns), water features (ponds and streams), circulation features such as
roads, paths, steps, walls, buildings and furnishings, including fences, benches, lights and sculp-
tural objects (see Preservation Brief 36, Protecting Cultural Landscapes, US Department of the
Interior, National Park Service, June 29, 2001).
2.1.6. Identify American Indian sacred sites, cultural items (per NAGPRA), and traditional resources
of appropriate affiliated cultures (per National Register Bulletin 38, Guidelines for Evaluating and
Documenting Traditional Cultural Properties, US Department of the Interior, National Park Service,
1990).
2.2. Evaluation: Evaluate and determine National Register eligibility of identified cultural resources
(see 36 CFR §60, National Register of Historic Places, §60.4, Criteria for Evaluation).
10 AFI32-7065 1 JUNE 2004
2.2.1. Evaluation can be accomplished in several ways, and installations have flexibility to determine
the methods they will use. Consult with SHPOs in selecting evaluation methods. Example methods
include:
2.2.1.1. The installation, SHPO, and other consulting parties agree to treat properties as eligible
for the National Register. The determination can be based on existing documentation or no docu-
mentation.
2.2.1.2. The installation and SHPO develop sampling programs to determine eligibility of
selected resources. Extrapolate the results to the larger population of similar resources to estimate
the approximate number of eligible sites in the entire area.
2.2.1.3. The installation follows SHPO guidelines for archaeological testing, or consults to use
alternative methods for testing on installation controlled lands.
2.2.1.4. The installation develops and consults with SHPO on installation-specific contexts for
determining eligibility.
2.2.2. The level and extent of evaluation efforts should be commensurate to the complexity and nature
of the undertaking. Evaluate only enough to reach a reasonable conclusion.
2.2.3. Follow state guidelines for research and reporting where appropriate.
2.2.4. Cold War era resources less than 50 years old must be of exceptional importance to the nation's
history to be eligible to the National Register (refer to HQ USAF/CE Memorandum, Interim Guid-
ance for Cold War Resources, 29 June 1993, and National Register Bulletin 22, Guidelines for Evalu-
ating and Nominating Properties that have Achieved Significance Within the Last Fifty Years, US
Department of Interior, National Park Service, 1996).
2.3. Completion of NHPA Section 110 Inventory: An installation's inventory of historic properties,
required under NHP A §110(a)(2)(A) [16 U.S.C. §470h-2(a)(2)(A)], and accomplished through identifica-
tion and evaluation, is complete when:
2.3.1. Qualified personnel have surveyed all undisturbed and accessible lands, or appropriately sam-
pled or researched the land or properties under the installation's control, and have provided their find-
ings and recommendations to the installation,
2.3.2. The installation has provided its inventory methods and determinations of eligibility to the
SHPO for comment and concurrence, and to other interested parties for comment,
2.3.3. In case of disagreements, the Keeper of the National Register (Keeper), located in the National
Park Service (NPS), makes final determinations of eligibility for disputed properties,
2.3.4. The installation has planned for managing and maintaining identified historic properties in their
ICRMP, and
2.3.5. The installation has appropriately curated recovered artifacts and associated records.
2.4. Unevaluated Resources: Identified, but not evaluated, archaeological sites comprise a large number
of cultural resources on installations.
2.4.1. Manage identified but unevaluated or "potentially eligible" resources as if eligible for the
National Register.
AFI32-7065 1 JUNE 2004 11
2.4.2. Program and budget annually for evaluation of a portion of unevaluated resources.
2.4.3. Require contractors (through SOW tasks and research designs) to conduct sufficient research
during inventory. This would include assessing sites and providing recommendations on National
Register eligibility.
2.5. National Register of Historic Places
2.5.1. Determinations of Eligibility.
2.5.1.1. Assess and determine the National Register eligibility of properties according to 36 CFR
§60.4, based on recommendations of professionally qualified investigators (see also National
Register Bulletin 15, How to Apply the National Register Criteria for Evaluation, US Department
of Interior, National Park Service, 1991).
2.5.1.2. MAJCOMs will review installations' determinations of eligibility prior to them being sent
to the SHPO for comment and concurrence.
2.5.2. Disagreements Regarding National Register Eligibility.
2.5.2.1. The installation may request a determination of eligibility from the Keeper in accordance
with 36 CFR §63, Determinations of Eligibility for Inclusion in the National Register of Historic
Places, §63.2, when disagreements on eligibility occur between the Air Force and the SHPO.
2.5.2.2. Requests to the Keeper will be staffed and routed from the installation to MAJCOM to
HQ USAF/ILEV .
2.5.2.3. The Keeper's determination is final.
2.5.3. Nominations for Listing of Historic Properties to the National Register.
2.5.3.1. The Air Force will give priority to nominating those properties the installation intends to
interpret, commemorate, or actively manage as sites of historic significance, and which are open
to the base community and/or the general public.
2.5.3.2. An installation's intention to nominate a property must be coordinated through the MAJ-
COM to HQ USAF/ILEV .
2.5.3.3. Once coordinated, forward all required materials to the SHPO for review and concur-
rence.
2.5.3.4. After SHPO review, HQ USAF/ILEV forwards the nomination package to the Air Force
FPO.
2.5.3.5. The Air Force FPO submits National Register nominations to the Keeper.
2.6. Removal of Listed Historic Places from the National Register:
2.6.1. Installation commanders may request that historic properties be removed from the National
Register in accordance with 36 CFR §60.15.
2.6.2. Prepare documentation detailing the grounds for removal of the historic property from the
National Register.
2.6.3. Notify and obtain the SHPO's comments and forward them, with all supporting documentation
detailing the grounds for removal, through the MAJCOM to HQ USAF/ILEV .
12 AFI32-7065 1 JUNE 2004
2.6.4. HQ USAF/ILEV will review the documentation and provide a recommendation to the Air
Force FPO regarding the request for petition to remove the historic property from the National Regis-
ter.
AFI32-7065 1 JUNE 2004 13
Chapter 3
PROJECT REVIEW
3.1. The NHPA Section 106 Process:
3.1.1. All proposed Air Force actions that might affect historic properties are subject to review under
Section 106 of the NHPA.
3.1.1.1. The installation commander (through delegation to the BHPO) will identify and evaluate
all cultural resources in the area of potential effect (APE) of an undertaking, and will take into
account the effects of all undertakings on historic properties.
3.1.1.2. Detailed review procedures for compliance are provided in the NHPA, Section 106 and 36
CFR §800.
3.1.1.3. Failure to take into account the effects of an undertaking on historic properties according
to Section 106 and 36 CFR Part 800 can result in the Council's formal notification of foreclosure
to the SAF [per 36 CFR §800.9(b)]. Foreclosure is a term that implies a Federal agency has initi-
ated an action before providing the Council an opportunity, in consultation with the SHPO and
other interested parties, to comment on the undertaking.
3.1.1.3.1. The Council publishes determinations of foreclosure and notifies interested parties
of the action undertaken on an installation's historic properties. A notice of foreclosure can be
used to support a court determination that the installation has violated Section 106, should the
issue be litigated.
3.1.1.4. Consult with the SHPO (or Tribal Historic Preservation Officer [THPO] for Indian lands),
and other consulting parties, to identify, evaluate, and mitigate any adverse effects on historic
properties.
3.1.1.5. Afford Indian Tribes the opportunity to participate as consulting parties during the con-
sultation process for undertakings on Air Force lands that might affect properties having historic
traditional value to those Tribes (per 36 CFR § 800.2).
3.1.1.6. Afford the public an opportunity to comment on actions that might affect historic proper-
ties (per 36 CFR §800.6).
3.1.1.7. Develop and evaluate alternatives or modifications to proposed undertakings that could
avoid, minimize, or mitigate adverse effects on historic properties.
3.1.1.8. Mitigation: Air Force undertakings adversely affecting historic properties require mitiga-
tion measures that are outlined in a Memorandum of Agreement (MOA) or Programmatic Agree-
ment (PA) (between the installation and SHPO and other appropriate parties) or cited in the
relevant Environmental Impact Analysis Process (EIAP) document.
3.1.1.8.1. PAs and MOAs executed pursuant to NHPA Section 106 and 36 CFR §800.11 and
§800.14 are legally binding compliance agreements.
3.1.1.8.2. Management procedures and determinations stipulated in PAs and MOAs should be
described and integrated into the installation’s ICRMP.
14 AFI32-7065 1 JUNE 2004
3.1.1.8.3. Under Section 110(b) of the NHPA, 16 U.S.C. §470h-2(b), MOAs or PAs will
require Historic American Building Survey/Historic American Engineering Records (HABS/
HAER) documentation to mitigate adverse effects when demolition of historic buildings or
structures on an installation is unavoidable, or when the Air Force intends to convey historic
buildings to a non-federal agency.
3.1.1.8.3.1. The level and kind of HABS/HAER recordation depends on the property's rel-
ative significance and the nature of the undertaking’s effects, determined in consultation
with the SHPO/THPO, Council, or the NPS.
3.1.1.8.3.2. 48 Federal Register 44731-44734 (Sept 29, 1983) contains HABS/HAER
documentation standards.
3.1.1.8.4. Archaeological data recovery: When adverse effects to archaeological historic prop-
erties cannot be avoided and data recovery is required in an MOA or PA, comply with:
3.1.1.8.4.1. Archaeological and Historic Preservation: Secretary of the Interior's Stan-
dards and Guidelines.
3.1.1.8.4.2. Advisory Council Handbook, Recommended Approach for Consultation on
Recovery of Significant Information from Archeological Sites, June 17, 1999.
3.1.1.8.4.3. DoD Legacy Management Program Office Project No. 98-1714, Guidelines
for the Field Collection of Archaeological Materials and Standard Operating Procedures
for Curating Department of Defense Archaeological Collections, 1999.
3.1.1.9. Draft PAs or MOAs, whether prepared by the installation or another party, such as a
SHPO/THPO, will be staffed and routed for legal and technical review with the installation CRM,
Judge Advocate (JA), BCE, the installation commander and the MAJCOM.
3.1.1.9.1. The MAJCOM will elevate the agreement to HQ USAF/ILEV for technical and
legal review.
3.1.1.9.2. The installation commander has signature authority for PAs or MOAs pertaining to
properties under his/her control, unless otherwise directed by SAF/IEE.
3.1.1.9.3. The Air Force FPO has signature authority for PAs and MOAs that affect the entire
Air Force or for unique actions that affect policy.
3.1.1.9.4. The installation provides a copy of the fully executed PA or MOA to the MAJCOM
and any and all signatory parties.
3.1.2. Terminating Consultation:
3.1.2.1. The installation commander may request the Air Force FPO terminate consultation and
seek final comments of the Council, when the installation, the SHPO/THPO, the Council and/or
other consulting parties are unable to agree on steps to resolve adverse effects to a historic prop-
erty [per 36 CFR §800.7(a)].
3.1.2.2. Do not terminate consultation without first acquiring approval from higher headquarters.
3.1.2.3. Send notice of termination actions to the SAF through the MAJCOM and HQ USAF/
ILEV .
AFI32-7065 1 JUNE 2004 15
3.1.2.4. HQ USAF/ILEV provides the Air Force FPO with an assessment and recommendation of
the termination action.
3.1.2.5. The Air Force FPO will prepare the SAF's response to the Council comments.
3.1.2.6. Additional information regarding the termination of consultation may be required.
3.1.3. BRAC Installations:
3.1.3.1. Site Managers or the Director of the Air Force Real Property Agency (AFRPA) function
as the installation commander for the purposes of NHP A compliance and PA and MOA staffing
when an installation is included in the Base Realignment and Closure (BRAC) program.
3.1.3.2. Comply with AFRPA staffing procedures and signatory authority for BRAC NHP A Sec-
tion 106 PAs and MOAs.
3.2. Consultation with Native Americans:
3.2.1. In accordance with DOD and Air Force policy and guidance, consult with Federally recognized
Indian Tribes (see “Indian Tribes”, Attachment 1) pursuant to NHPA Section 110(a)(2) [16 U.S.C.
§470h-2(a)(2)] and 36 CFR §800.2 to identify, evaluate, and treat historic properties that have reli-
gious or cultural importance to those groups.
3.2.2. Air Force policy requires installation commanders, or their designated 0-6 representatives, to
meet periodically with designated representatives of each Indian Tribe that is affected by the installa-
tion's plans, activities, or operations (per HQ USAF/CV A Memorandum, Consultation with American
Indian Tribal Governments and Alaska Native Organizations, 10 Nov 97).
3.2.3. Follow DoD policy for contacts and consultations with Tribes as per the Department of Defense
American Indian and Alaska Native Policy, October 20, 1998.
3.2.4. Ensure that consultations between the Air Force and Indian Tribes are conducted on a govern-
ment-to-government basis in an open and candid manner.
3.2.5. Document all consultations to demonstrate compliance.
3.3. Environmental Impact Analysis Process (EIAP): Proponents of Air Force actions will ensure that
impacts of those proposed actions on cultural resources are fully considered in documents prepared pur-
suant to the National Environmental Policy Act (NEPA), 42 U.S.C. §4321, et seq., NEPA’s implementing
regulations at 40 CFR §§1500-1508;AFI 32-7061, The Environmental Impact Analysis Process, as pro-
mulgated at 32 CFR §989; and the NHP A regulations at 36 CFR §800.8.
3.3.1. Incorporate NHPA Section 106 review into NEPA decision-making processes when purpose
and need are being defined and a wide range of alternatives is open. Coordinate Section 106 compli-
ance with the NEPA process per 36 CFR §800.8.
3.3.2. Substitute the NEP A process for separate NHP A Section 106 review of alternatives, by comply-
ing with 36 CFR §800.8(c):
3.3.2.1. Notify the SHPO/THPO and Council that the installation intends to substitute NEP A for
the NHP A Section 106 process.
3.3.2.2. Invite interested parties and appropriate Indian Tribes to participate.
16 AFI32-7065 1 JUNE 2004
3.3.2.3. Phase the scope and timing of cultural resources identification and effects assessment to
coincide with the consideration of alternatives.
3.3.2.4. Ensure that effects to cultural resources are fully assessed along with other environmental
resources.
3.3.2.5. Consult with the SHPO/THPO, Tribes, and other consulting parties about the action’s
effect during NEP A scoping, analysis, and documentation review. Involve the public in accordance
with AFI 32-7061, as promulgated at 32 CFR §989.
3.3.2.6. Develop alternatives and mitigation measures in consultation with the various parties, and
describe them in the Environmental Assessment (EA) or Environmental Impact Statement (EIS).
3.3.2.7. Specify in the Finding of No Significant Effect (FONSI) or Record of Decision (ROD)
the measures proposed to mitigate adverse effects on historic properties, and ensure that approval
of the undertaking contains the same conditions.
3.3.2.8. A FONSI requires a MOA for mitigating adverse effects; a ROD does not, per 36 CFR
§800.8(c)(4).
3.4. NEPA Categorical Exclusions (CATEXes): Installation Commanders will determine if a project,
activity, or program which is categorically excluded under Air Force NEP A procedures, qualifies as an
undertaking requiring NHPA Section 106 review [per 36 CFR §800.8(b)].
3.5. Engineering Work Order Review:
3.5.1. The installation CRM will participate in the environmental review of work requests (Air Force
Form 332, Base Civil Engineer Work Request) and requests for environmental impact analysis.
3.5.2. All Air Force Forms 813, Request for Environmental Impact Analysis Categorical Exclu-
sion, initiated at base level will be reviewed and coordinated with the installation CRM. If the work
order request indicates the need to conduct an environmental analysis, the installation CRM must
ensure that impacts to significant cultural resources are considered and avoided or mitigated (refer to
AFI 32-7061, as promulgated at 32 CFR §989) in CATEXes, EAs, and EISs.
3.6. Military Construction Planning and Design:
3.6.1. Establish and implement alternatives to demolition of historic buildings and structures by con-
sidering adaptive re-use, mothballing, transfer, sale, or lease.
3.6.2. Document historic buildings and structures that will be altered or destroyed due to Air Force
actions.
3.6.3. Air Force MILCON and Family Housing MILCON projects will include historic properties in
their background data review, historic renovation cost factors, and Military Construction Project Data
(form DD 1391, Military Construction Project Data) development (per AFMAN 32-1089, Air
Force Military Construction and Family Housing Economic Analysis Guide).
3.6.4. The installation CRM must review MILCON project plans to ensure compliance with NHPA
Section 106.
AFI32-7065 1 JUNE 2004 17
3.7. Repair and Maintenance Activities: Repair to a facility that exceeds 70 percent of its replacement
cost is classified by the Air Force as construction (per AFI 32-1032, Planning and Programming Appro-
priated Funded Maintenance, Repair, and Construction Projects). This rule does not apply to buildings or
structures listed on or eligible to the National Register of Historic Places. This permits greater leeway for
installations to design mitigation for adverse effects to historic properties. Note: Construction and mainte-
nance costs are not eligible for Conservation funding.
3.8. Real Property Actions:
3.8.1. Coordinate with the real property manager to ensure that:
3.8.1.1. Real property records accurately describe cultural resources.
3.8.1.2. Installation archaeological sites are indicated (not specifically located) on real property
records and appropriate base maps and plans.
3.8.2. The installation commander must ensure that the significant value of properties are appropri-
ately preserved when Air Force historic properties are transferred to private parties or state, tribal, or
local governments.
3.8.3. Transfer of historic properties to another Federal agency does not require such protection
because the receiving agency will assume the normal federal preservation responsibilities.
3.8.4. The base CRM ensures SHPO coordination prior to the disposal of real property outside the
federal government (e.g., Declarations of Excess and AF Form 300, Facility Disposal).
3.9. Inadvertent Discoveries of Archaeological Objects or Native American Human Remains and
Cultural Items:
3.9.1. Installations will ensure that inadvertent discoveries of Native American cultural items comply
with NAGPRA and 43 CFR §10. When potential NAGPRA cultural items are inadvertently found on
Air Force lands, follow these procedures;
3.9.1.1. Immediately cease construction activities in the vicinity of the discovery. If the remains
or artifacts are determined to be NAGPRA cultural items, the construction activities must be halted
for 30 days after notifying the commander (see 3.9.1.6.). If the remains or artifacts are not subject
to NAGPRA, the activity may resume when the items have been recorded and evaluated in accor-
dance with ARP A and the NHP A (see 3.9.6. and 3.9.7.).
3.9.1.2. Notification:
3.9.1.2.1. Finder (e.g., construction crew, utility workers) must immediately notify the CRM.
3.9.1.2.2. CRM must immediately notify the installation commander and the MAJCOM.
3.9.1.2.3. CRM takes steps to ascertain that cultural items or remains are truly Native Ameri-
can and not those of some other group. Only Native American remains and cultural items are
covered under NAGPRA.
3.9.1.2.4. Installation commander certifies in writing that he/she was notified of the discovery.
3.9.1.2.5. MAJCOM will notify HQ USAF/ILEV.
18 AFI32-7065 1 JUNE 2004
3.9.1.2.6. Within 3 working days of determining that cultural items or remains are NAGPRA
items, the installation commander or CRM must notify officials of Indian Tribes likely to be
culturally affiliated (per 43 CFR §10.4).
3.9.1.3. Protect the discovery from disturbance, erosion, or vandalism.
3.9.1.4. Consult with appropriate tribal officials on procedures for recovery or preservation of the
remains or items (per 43 CFR §10.5).
3.9.1.5. Prepare and execute a Plan of Action if the remains or cultural items must be removed
(per 43 CFR §10.3).
3.9.1.6. Resume the earth-disturbing activity near the discovery, either,
3.9.1.6.1. Thirty (30) days after the commander certifies in writing that he/she was notified,
or,
3.9.1.6.2. When the Plan of Action has been executed, if this occurs less than 30 days after
written notification of the commander, or,
3.9.1.6.3. When the installation commander and affiliated Tribal officials agree on a course of
action that does not require removing the items or remains, if this occurs less than 30 days
after notification of the commander.
3.9.2. Consider Comprehensive Agreements (NAGPRA CAs) per 43 CFR §10.5(f) with Indian Tribes
potentially affiliated with cultural items under Air Force control. Comprehensive Agreements detail
procedures to be followed in the event of inadvertent discoveries or emergencies related to all land
management activities at an installation. These are more comprehensive than contingency Plans of
Action (see 3.10.), since they address various activities as opposed to a specific activity with the
potential to affect NAGPRA cultural items. CAs require approval and signatures of consulting Tribal
officials.
3.9.3. Inadvertent discoveries of Native American human remains do not require notification to the
SHPO, unless the remains are associated with a larger archaeological site that must be identified and
evaluated. Such cases will entail concurrent NAGPRA consultations and separate NHPA Section 106
consultations.
3.9.4. Installations will ensure that NAGPRA Plans of Action and NHPA MOAs do not contradict each
other.
3.9.5. Tribal members may be involved in NHPA Section 106 reviews, but the SHPO has no role in
NAGPRA consultations and Plans of Action.
3.9.6. Inadvertent discoveries of human remains that are not those of Native Americans require NHPA
Section 106 consultation with the SHPO, and possibly notification of installation or local law-enforce-
ment authorities. Use regionally qualified archaeologists to assist in the decision by determining the
location, context, and associations (and possibly the date) of the remains.
3.9.7. Inadvertent discoveries of artifacts, archaeological features, or buried large animal skeletal
remains not subject to NAGPRA require NHPA Section 106 consultation with the SHPO or THPO.
3.9.8. Responsibilities and associated duties prescribed in archaeological monitoring plans, inadvert-
ent discovery plans, or standard operating procedures (SOPs) in the installation ICRMP should be fol-
AFI32-7065 1 JUNE 2004 19
lowed when inadvertent discoveries are made during ground disturbing activities on Air Force
controlled lands.
3.10. NAGPRA Plans of Action: 43 CFR §§10.3 and 10.5 describe two different kinds of Plans of
Action. One is for removal of inadvertently discovered NAGPRA cultural items (see ¶3.9.1.5. of this
Instruction). The other is a contingency document for a planned activity that reasonably might encounter
NAGPRA cultural items.
3.10.1. Take reasonable steps to determine whether a planned activity on the installation might result
in the intentional excavation or inadvertent discovery of NAGPRA cultural items.
3.10.2. Prepare a contingency Plan of Action when the CRM determines that NAGPRA cultural items
are likely to be encountered during a planned activity [see 43 CFR §§10.3(c)(1 and 2) and 10.5(e)].
3.10.3. Plans of Action, whether prepared for individual inadvertent discoveries or prior to planned
activities, require the signature of the installation commander. Plans of Action require consultation
with, but not the approval (or signatures) of, Indian Tribal officials [per 43 CFR §10.5(e)].
20 AFI32-7065 1 JUNE 2004
Chapter 4
GENERAL MANAGEMENT
4.1. Aircraft Wreck Sites:
4.1.1. Note the location of discovered aircraft wreck sites on the installation GIS, or appropriate
installation map. Wreck sites older than 50 years should be evaluated for significance per Section 110
of the NHP A.
4.1.2. Determine if cultural resources have been affected by a crash or by post crash activities such as
access road construction. If so, proceed with NHP A Section 106 consultations.
4.1.3. Refer to AFI 91-204, Safety Investigations and Reports, for Air Force policy on crash
responses.
4.2. Archaeological Resources Protection:
4.2.1. Protect archaeological sites on lands under Air Force control or management. Unauthorized
excavation, removal, damage, alteration, or defacement of archaeological resources on Air Force
property is prohibited, and punishable by civil and criminal penalties.
4.2.2. Determine which Federal agency has archaeological resources protection responsibilities (per
ARP A) on lands shared with the Air Force. Document the determination and responsibilities of each
party in a Memorandum of Understanding (MOU) or other agreement document between the Federal
agency and the Air Force.
4.2.3. Review deeds, leases, and use-agreements allowing for military operations on non-Air Force
lands to determine proper cultural resource protection roles and responsibilities.
4.2.4. ARP A permits are required for the actual or attempted excavation, collection, removal, and dis-
turbance of archaeological resources on Air Force property (per 32 CFR §229, Protection of Archae-
ological Resources: Uniform Regulations, §§229.5 - 229.11). However, ARPA permits are not
required for qualified archaeologists employed by, or under contract to the Air Force or its agents in
carrying out their official or contracted duties on the installation [per 32 CFR §229.5(c)]. Nonetheless,
32 CFR §229.5(c) requires permit provisions to be met by other documented means, and ensuring that
any official duties which might result in harm to or destruction of any Indian tribal religious or cul-
tural site are the subject of notification to tribes as set forth in 32 CFR §229.7.
4.2.5. The installation commander will ensure that security forces, legal staff, public affairs office,
and the fish, game, and recreation management staff are familiar with the requirements and applicable
civil and criminal penalties under ARP A Section 6(a) and 32 CFR §229.4
4.2.6. The BCE (or Environmental Manager) will issue ARPA permits to qualified individuals after
technical review of the application by HQ AFCEE.
4.2.6.1. The reviewed permit is sent by the CRM to the BCE for signature.
4.2.6.2. The CRM sends one copy of the signed permit to the proponent and another to HQ
AFCEE.
4.3. Base Comprehensive Planning Process:
AFI32-7065 1 JUNE 2004 21
4.3.1. Installations will fully integrate cultural resources into the comprehensive planning process,
per AFI 32-7062, Air Force Comprehensive Planning.
4.3.2. Ensure that general, non-point specific cultural resource locations are displayed in the Compos-
ite Constraints and Opportunities Plan as a data layer.
4.4. Confidentiality Requirements:
4.4.1. Section 9 of ARP A permits the installation to withhold information concerning the nature and
location of archaeological resources from the public.
4.4.2. Section 304 of the NHP A, 16 U.S.C. §470w-3(a), also requires withholding information about
the location, character, or ownership of an historic property when disclosure might cause a significant
invasion of privacy, risk harm to the historic property, or impede the use of a traditional religious site
by practitioners.
4.4.3. Consult with the local Staff Judge Advocate before withholding of any information pursuant to
these provisions and coordinate, through channels, with HQ USAF/ILEV .
4.5. Cooperative Agreements:
4.5.1. The Economy Act, 3, U.S.C. §1535, authorizes the Air Force to issue orders to other federal
agencies to provide goods and services, so long as the order is in the best interests of the Government,
is more economical or convenient than procurement under contract, and does not conflict with another
agency’s authority.
4.5.2. 10 U.S.C. §2684, Cooperative Agreements for Management of Cultural Resources, allows
installations to enter into cooperative agreements (CA) with States, local governments, or other enti-
ties for research on, or preservation, maintenance, and improvement of, cultural resources on installa-
tions.
4.5.3. Installations may develop and implement interagency agreements or CAs according to these
provisions, following technical and legal review at the installation and MAJCOM.
4.5.4. Ensure that principal investigators, crew leaders, and others who will oversee preparation of the
CA or interagency agreement are qualified under current standards specified in Archeology and His-
toric Preservation: Secretary of the Interior's Standards and Guidelines.
4.6. Care of Archaeological and Historic Property Collections and Records:
4.6.1. Ensure that all collections of archaeological artifacts and records are processed, maintained,
and curated in accordance with 36 CFR §79, Curation of Federally-Owned and Administered Archae-
ological Collections.
4.6.2. NAGPRA cultural items in the installation’s possession and control will be disposed of consis-
tent with the requirements of NAGPRA and 43 CFR §10.
4.6.3. Installation commanders will establish procedures in the installation ICRMP to minimize the
amount of “material remains” [as defined in 36 CFR §79.4(a)(1)], collected during archaeological
inventory and site excavation that requires permanent curation.
22 AFI32-7065 1 JUNE 2004
4.6.4. Follow the guidelines and standards outlined and discussed in the DoD Guidelines for the Field
Collection of Archaeological Materials and Standard Operating Procedures for Curating Department
of Defense Archaeological Collections.
4.6.5. Do not establish Air Force archaeological curation facilities on installations.
4.6.5.1. Exceptions to this curation policy will be reviewed by the MAJCOM and HQ AFCEE and
approved by HQ USAF/ILEV on a case-by-case basis.
4.6.5.2. Justification for a waiver to construct curation facilities will include an analysis of costs
for professional curatorial personnel, initial installation infrastructure start-up costs, and installa-
tion costs for annual operation, materials, maintenance, and repair.
4.6.6. Artifacts, records, and material remains related to a historic property are included in the defini-
tion of that property. Installations must ensure proper care and storage and consult with SHPO on
ways to mitigate adverse effects to these items. Examples include photographs, blueprints, line draw-
ings, building or construction elements, etc, associated with historic buildings and structures.
4.7. Environmental Compliance Assessment and Management Program (ECAMP):
4.7.1. Ensure that cultural resource findings from internal and external ECAMPs are addressed in the
ECAMP action plan, per AFI 32-7045, Environmental Compliance Assessment and Management Pro-
gram (ECAMP).
4.7.2. Program all Level 0 or Level 1 funding requirement driven by an ECAMP finding into the envi-
ronmental funding portion of the Automated Civil Engineering System-Project Management Module
(ACES-PM) (per HQ USAF/ILE Memorandum, Air Force Programming and Budgeting Guidance,
11 Sep 2000).
4.8. Funding Requirements:
4.8.1. Identify cultural resources funding requirements in the environmental portion of ACES-PM
(refer to AFI 32-7001, Environmental Budgeting and the detailed guidance in HQ USAF/ILE Memo-
randum, 11 Sep 2000).
4.8.1.1. Priority funding includes, but is not limited to:
4.8.1.1.1. Salaries and training in direct support of cultural resources compliance obligations.
4.8.1.1.2. Historic building inventory and evaluation.
4.8.1.1.3. Archaeological inventory and evaluation.
4.8.1.1.4. Section 106 consultation and development of MOAs and PAs.
4.8.1.1.5. Cultural resources portions of environmental impact analyses.
4.8.1.1.6. Approved curation of archaeological collections and records.
4.8.1.1.7. Government-to-government consultations with Indian Tribes.
4.8.1.1.8. Initial preparation and 5-year updates of ICRMPs.
4.8.1.2. Projects and activities typically not eligible for environmental funding include, but are
not limited to:
AFI32-7065 1 JUNE 2004 23
4.8.1.2.1. Mitigation measures for adverse effects to historic properties, including archaeolog-
ical data recovery (proponent should pay for mitigation).
4.8.1.2.2. Maintenance and/or repair of historic buildings and structures.
4.8.1.2.3. Routine grounds maintenance such as grass mowing, tree pruning, and landscaping,
including such activities occurring in historic cemeteries.
4.8.1.2.4. Restoration of historic cemeteries.
4.8.1.2.5. Weapons systems acquisition EIAP costs.
4.8.1.2.6. Projects associated with base realignment and closure EIAP costs.
4.9. Information Management:
4.9.1. Enter and maintain core data, metadata, and information regarding cultural resource activities
in the installation's cultural resources automated data files.
4.9.2. Digital geospatial data produced by cultural resource inventories will conform to military stan-
dards available through the CADD/GIS Technology Center at
http://tsc.wes.army.mil/products/TSSDS-TSFMS/tssds/html/ .
4.10. Integrated Cultural Resource Management Plans (ICRMPs):
4.10.1. DoD Instruction 4715.3, ¶4.3.3, requires ICRMPs to be prepared for all military installations
having cultural resources. See Attachment 2 for Guidelines for preparing ICRMPs. Electronic tem-
plates of ICRMPs are available on the Denix website:
https://www.denix.osd.mil/denix/Public/ES-Programs/Conservation/Legacy/ETB/EtbWel-
come.htm
4.10.1.1. Installations will update their ICRMP every five years.
4.10.1.2. The development and preparation of the ICRMP may require analysis under NEPA if the
ICRMP contains plans for new proposed actions that may impact the environment which have not
been previously analyzed under NEPA. When that is the case, the draft ICRMP must be assessed
in compliance with AFI 32-7061, The Environmental Impact Analysis Process, as promulgated at
32 CFR §989. When a NEPA analysis is required, for purposes of alternatives analysis n the NEPA
document, ICRMP proponents shall develop, to the extent practicable, a range of potential alterna-
tive means of executing the ICRMP.
4.10.1.3. Forward the draft ICRMP to the MAJCOM CRM and JA for review. After MAJCOM
review, installations may provide a copy of the draft ICRMP, or relevant parts of the plan, to the
SHPO for their information. SHPO comments may be considered, however SHPO approval is not
required to complete the ICRMP.
4.10.1.4. The installation will consider MAJCOM and other comments in preparing the final
ICRMP.
4.10.1.5. The title page of the ICRMP will include the date and signature of MAJCOM reviewers
and the approval date and signature of the installation commander.
4.10.2. Installations scheduled for closure within 5 years pursuant to BRAC laws are exempt from
preparing an ICRMP.
24 AFI32-7065 1 JUNE 2004
4.10.3. Installations that have completed their cultural resource inventories and identified no historic
properties or other cultural resources requiring management may petition the MAJCOM for a waiver
from the ICRMP requirement.
4.10.3.1. The Base CE or Environmental Director will prepare a letter of justification to MAJ-
COM/CE requesting the waiver.
4.10.3.2. The MAJCOM/CE will notify both the installation and HQ USAF/ILEV of the waiver
and reflect the "No ICRMP Required" status in all relevant program management metrics.
4.10.4. The ICRMP will be classified “For Official Use Only” and its handling will comply with
appropriate procedures for documents in that category.
4.10.5. Annual or as needed updates to the ICRMP will be completed by the installation CRM.
4.10.6. The CRM will include appropriate justification for contractor support in their program fund-
ing request for 5-year updates to the ICRMP.
4.11. Integrated Natural Resource Management Plan (INRMP):
4.11.1. The installation CRM will ensure relevant sections of the draft INRMP are consistent with the
installation's cultural resources program. Focus on those elements of the INRMP that relate to and
may potentially affect cultural resources on the installation.
4.11.2. See AFI 32-7064, Integrated Natural Resources Management, for details on natural resources
programs.
4.12. Metal Detecting: Use of metal detectors on Air Force property is generally prohibited, except
when used by Air Force personnel, contractors, or permittees in association with official cultural resource
management activities, or pursuant to an ARPA permit. Installations may develop detailed rules for metal
detector use on their lands.
4.13. Public Awareness: Establish awareness programs to educate and inform the public about the sig-
nificance of archaeological resources on installation lands [per ARPA Section 10 (c) and 32 CFR
§229.20].
4.14. Reports:
4.14.1. Installations provide information on their annual archaeological activities to the MAJCOM
CRM, who then forwards the data to HQ AFCEE. HQ AFCEE completes the annual "Federal Archae-
ological Activities Report to Congress" for the Air Force [per the Archaeological and Historic Pres-
ervation Act, 16 U.S.C., 469-469c] and sends it through HQ AF/ILEV to the NPS (RCS:
HAF-ECS(A)0309)).
4.14.2. Installations will report incidents of potential ARP A violations to their respective MAJCOMs.
4.14.3. Installations provide information on their annual NAGPRA activities to the MAJCOM CRM,
who then forwards the data to HQ AFCEE. HQ AFCEE consolidates the data, creates an Air Force
NAGPRA Activities Report, and forwards it to HQ AF/ILEV in route to NPS.
4.15. Sacred Sites Access and Protection:
AFI32-7065 1 JUNE 2004 25
4.15.1. Provide Federally recognized American Indian Tribes access to and use of sacred sites on Air
Force controlled lands. Sacred sites are specifically defined in Executive Order 13007.
4.15.2. Impose reasonable terms, conditions, and restrictions on access to such sites to protect per-
sonal health and safety, to avoid interference with the military mission, or for reasons of national secu-
rity.
4.15.3. Avoid adversely affecting the physical integrity of sacred sites.
4.15.4. Ensure reasonable notice is provided to Federally-recognized Indian Tribes when proposed
Air Force actions or land management policies and practices might restrict future access to, ceremo-
nial use of, or adversely affect the physical integrity of identified sacred sites.
4.15.5. Outline notification procedures in the installation ICRMP. Ensure that NHPA §106 compli-
ance requirements are met if the affected sacred site is a historic property.
4.15.6. Take reasonable measures to maintain the confidentiality of sacred site locations.
4.16. Static Displays:
4.16.1. Air Force aircraft, missiles, weapons, and hardware on static display belong to the USAFMS.
4.16.2. The USAFMS is responsible for determining National Register eligibility and for nominating
USAFMS-owned properties to the National Register.
4.16.3. Installations will notify and consult with the USAFMS on undertakings that might affect these
resources, whether or not they are considered eligible.
4.17. Personnel: Qualifications, Training, Certification, and Professional Development:
4.17.1. An astute awareness of cultural resources management protocols is important in achieving
program objectives and supporting the installation's military mission. As such, CRMs must be knowl-
edgeable of the installation’s cultural resources and the appropriate management protocols to effec-
tively and comprehensively execute program requirements. Given the diversity of cultural resources
in terms of categories and numbers across the Air Force, qualifications for CRM positions should be
tailored to the uniqueness of the installation, considering both the scope and complexity of existing
resources. The Secretary of the Interior's Professional Qualification Standards defines the desirable
knowledge, skills and training background for CRMs. Each installation, however, should assess its
specific cultural resource management requirements and fill the CRM position according to their need
and the sensitivity of the installation's cultural assets. It's important that CRMs obtain adequate train-
ing commensurate with the resources managed. Installations who use consultants to perform work on
behalf of the Air Force, should ensure they are highly capable and qualified to assist in the identifica-
tion, evaluation and management of cultural resources.
4.17.2. Air Force CRMs will obtain certification, education and training appropriate to their respon-
sibilities and experience. At installations with few cultural resources, most CRM responsibilities can
be assigned as collateral duties. However, in such cases, the installation should still coordinate the
responsibilities stated in 1.4.10.2. and 1.4.10.6. with a qualified cultural resource professional at
MAJCOM or AFCEE.
4.17.3. MAJCOMs will maintain databases on training and certification available and completed by
CRMs on their installations.
26 AFI32-7065 1 JUNE 2004
4.17.4. The installation CRM will:
4.17.4.1. Incorporate basic information on cultural resources into installation newcomer orienta-
tion briefings.
4.17.4.2. Conduct periodic reviews of the cultural resources program at commanders' calls and
other installation forums.
4.17.4.3. Inform personnel housed in historic quarters about the significance of these buildings
and explain any special management considerations.
4.17.4.4. Provide training for maintenance personnel to learn proper maintenance and repair pro-
cedures for historic properties.
4.18. Waivers and Exemptions:
4.18.1. SAF may waive all or part of the Air Force's Section 106 responsibility on a specific project
if the Secretary determines the existence of an imminent major natural disaster or a threat to national
security (per 36 CFR §78, Waiver of Federal Agency Responsibilities under Section 110 of the
National Historic Preservation Act).
4.18.1.1. Emergency action to preserve human life or property will override cultural resource
preservation requirements.
4.18.1.2. A waiver will not exceed the period of the emergency.
4.18.1.3. During the waiver period, implement all measures to avoid or minimize harm to historic
resources per Archeology and Historic Preservation: Secretary of the Interior's Standards and
Guidelines.
4.18.2. MAJCOMs forward waiver requests to the Air Force FPO through HQ USAF/ILEV .
4.18.3. The Air Force FPO informs the NPS, the Council, and relevant SHPOs within 12 days of
effecting a waiver per 36 CFR §78.
4.18.4. The Council may exempt Air Force activities from any NHP A statutory requirements.
4.18.5. MAJCOMs requests for exemptions to HQ USAF/ILEV must include:
4.18.5.1. A description of the activity, including its nature, scope, duration, legislative authority,
level of appropriation, and potential effects on historic properties.
4.18.5.2. The specific provisions of the NHPA that allows the exemption.
4.18.5.3. A description of the affected parties.
4.18.5.4. An evaluation of the potential effect of granting the exemption.
4.18.6. HQ USAF/ILEV forwards the request through channels to the Air Force FPO.
4.18.7. The Air Force FPO forwards requests for exemptions to the Council.
4.18.8. The Council advises the Air Force of the appropriate public notice.
4.18.9. The process allows a period for public comment of at least 30 days.
AFI32-7065 1 JUNE 2004 27
Chapter 5
DOD MEASURES OF MERIT (MOM).
5.1. Assessments: Internal conservation self-assessments will be conducted at installations at least annu-
ally, and external conservation self-assessments (ECAMPs) will be conducted at least once every 3 years
at all installations that require ICRMPs (per DoD Instruction 4715.3, and AFI 32-7045).
5.2. Review Criteria: Results of assessments will not normally be released to regulators or to the public.
At a minimum, reviews will assess:
5.2.1. Adherence to funding priorities listed in DoD Instruction 4715.3 and Air Force Conservation
Programming and Budgeting Guidance, 11 Sep 2000.
5.2.2. Information documented and maintained in relation to Measures of Merit as outlined in DoD
Instruction 4715.3.
5.3. Forms Adopted: AF Form 847, Recommendation for Change of Publication; AF Form 300,
Facility Disposal; DD Form 1391, FY__Military Construction Project Data.
DONALD J. WETEKAM, Lt General, USAF
DCS/Installations & Logistics
28 AFI32-7065 1 JUNE 2004
Attachment 1
GLOSSARY OF REFERENCES AND SUPPORTING INFORMATION
References
Advisory Council Handbook, Recommended Approach for Consultation on Recovery of Significant Infor-
mation from Archeological Sites, Advisory Council for Historic Preservation, June 17, 1999
AFI 32-1032, Planning and Programming Appropriated Funded Maintenance, Repair, and Construction
Projects
AFI 32-7001, Environmental Budgeting
AFI 32-7006, Environmental Programs in Foreign Countries
AFI 32-7061, Environmental Impact Analysis Process (EIAP), as promulgated at 32 CFR §989.
AFI 32-7045, Environmental Compliance Assessment and Management Program (ECAMP).
AFI 32-7064, Integrated Natural Resources Management
AFI 84-103, Museum System
AFI 91-204, Safety Investigations and Reports
AFMAN 32-1089, Air Force Military Construction and Family Housing Economic Analysis Guide
AFMAN 37-123, Management of Records
AFPD 32-70, Environmental Quality
AFPD 37-1, Information Management
AFPD 84-1, Historical Information, Property, and Art
Archaeological and Historic Preservation Act, 16 U.S.C. 469-469c-2
Archeology and Historic Preservation: Secretary of the Interior's Standards and Guidelines, 48 Federal
Register 44716-44742, September 29, 1983
Archaeological Resources Protection Act (ARPA), 16 U.S.C., 470aa-470mm
Cooperative Agreements for Management of Cultural Resources, 10 U.S.C. §2684
Curation of Federally-Owned and Administered Archaeological Collections, 36 CFR § 79
DoD Directive 4710.1, Archaeological and Historic Resources Management, June 21, 1994
DoD Instruction 4715.3, Environmental Conservation Program, May 3, 1996
DoD Instruction 4715.5-G, DoD Overseas Environmental Baseline Guidance Document AFH 10-222,
V olume 4: Environmental Guide for Contingency Operations
DoD Legacy Management Program Office Project No. 98-1714, Guidelines for the Field Collection of
Archaeological Materials and Standard Operating Procedures for Curating Department of Defense
Archaeological Collections, 1999 (available DENIX at https://www.denix.osd.mil and HQ AFCEE at
http://www.afcee.brooks.af.mil)
Determinations of Eligibility for Inclusion in the National Register of Historic Places, 36 CFR §63
AFI32-7065 1 JUNE 2004 29
The Economy Act, 31 U.S.C. §1535
Executive Order 13007, Indian Sacred Sites, May 24, 1996
Executive Order 13148, Greening Government Through Leadership in Environmental Management,
April 21, 2000
Executive Order 13175, Consultation and Coordination with Indian Tribal Governments, November 6,
2000
HQ USAF/CE Memorandum, Interim Guidance for Cold War Resources, 29 June 1993
HQ USAF/CV A Memorandum, Consultation with American Indian Tribal Governments and Alaska
Native Organizations, 10 Nov 97
HQ USAF/ILE Memorandum, Air Force Conservation Programming and Budgeting Guidance, 11 Sep-
tember 2000
HQ AFCEE Cultural Resources Fact Sheet: Recommended Guidelines for Standard Operating Proce-
dures in Integrated Cultural Resources Management Plans, February 2001, available at
http://www.afcee.brooks.af.mil).
Interim Guidance for Cold War Resources, HQ USAF/CE, 29 June 1993
International Federal Activities Affecting Historic Properties, 16 U.S.C., §470a-2,
National Environmental Policy Act (NEP A), 42, U.S.C. §4321, et seq.
National Historic Preservation Act (NHP A), 16 U.S.C., §470, et seq.
National Park Service Brochure, Secretary of the Interior's Standards for the Treatment of Historic Prop-
erties, US Department of Interior, National Park Service, 1992)
National Register Bulletin 15, How to Apply the National Register Criteria for Evaluation, US Depart-
ment of Interior, National Park Service, 1991
National Register Bulletin 22, Guidelines for Evaluating and Nominating Properties that have Achieved
Significance Within the Last Fifty Years, US Department of Interior, National Park Service, 1996
National Register Bulletin 38, Guidelines for Evaluating and Documenting Traditional Cultural Proper-
ties, US Department of Interior, National Park Service, 1990
Native American Graves Protection and Repatriation Act (NAGPRA), 25 U.S.C. §§3001-3013
Preservation Brief 36, Protecting Cultural Landscapes, US Department of the Interior, National Park Ser-
vice, June 29, 2001
Protection of Archaeological Resources, 32 CFR §229
Protection of the Environment, 40 CFR §1500-1508
Protection of Historic Properties, 36 CFR §800
Secretary of Defense Memorandum, American Indian and Alaska Native Policy, October 20, 1998
Wagner, Richard D, 1996, Preserving a Heritage. Standards and Illustrated Guidelines for Rehabilitating
Historic Air Force Buildings and Structures. United States Air Force: Office of the Civil Engineer.
30 AFI32-7065 1 JUNE 2004
Waiver of Federal Agency Responsibilities under Section 110 of the National Historic Preservation Act,
36 CFR §78
Abbreviations and Acronyms
AFI—Air Force Instruction
AFMAN—Air Force Manual
AFPD—Air Force Policy Directive
AIRFA—American Indian Religious Freedom Act of 1978
ARPA—Archaeological Resources Protection Act of 1979
CA—NAGPRA Comprehensive Agreement; or, Cooperative Agreement under 10 U.S.C. §2684,
Cooperative Agreements for Management of Cultural Resources
CFR—Code of Federal Regulations
Council—Advisory Council on Historic Preservation
CRM—Cultural Resources Manager
CRMP—Cultural Resource Management Plan (see also ICRMP)
EIAP—Environmental Impact Analysis Process
EO—Executive Order
FOUO—For Official Use Only
FPO—Federal Preservation Officer
FR—Federal Register
HABS—Historic American Building Survey
HAER—Historic American Engineering Record
HQ AFBDA—Headquarters, Air Force Base Development Agency
HQ AFCEE—Headquarters, Air Force Center for Environmental Excellence
HQ AFLSA/JACE—Headquarters, Air Force Legal Office, Judge Advocate for Civil Engineering
HQ USAF—Headquarters, United States Air Force
ICRMP—Integrated Cultural Resources Management Plan
MAJCOM—Major Command
MOA—Memorandum of Agreement
NAGPRA—Native American Graves Protection and Repatriation Act of 1991
NEPA—National Environmental Policy Act of 1969
NHPA—National Historic Preservation Act of 1966
NPS—National Park Service
OCR—Office of Coordinating Responsibility
AFI32-7065 1 JUNE 2004 31
OPR—Office of Primary Responsibility
PA—Programmatic Agreement, per 36 CFR §800.16
PL—Public Law
POC—Point of Contact
SAF/IE—Assistant Secretary of the Air Force for Installations, Environment, and Logistics
SAF/IEE—Deputy Assistant Secretary of the Air Force for Environment, Safety and Occupational
Health
SHPO—State Historic Preservation Officer
THPO—Tribal Historic Preservation Officer
USAFMS—United States Air Force Museum System
U.S.C.—United States Code
Terms
ACES-PM—A sub-module for reporting environmental funding requirements in the Automated Civil
Engineering System-Project Management module. Cultural resources funding requirements must be
entered into this sub-module of ACES-PM to be considered for funding.
Advisory Council on Historic Preservation (Council)—The independent Federal agency charged by
the NHPA, as amended to advise the President, Congress, and Federal agencies on matters related to
historic preservation. The Council also administers Section 106 of the NHPA through 36 CFR §800,
"Protection of Historic Properties."
Archaeological Resources—Any material remains of past human life or activities that are of capable of
providing scientific or humanistic understandings of past human behavior and cultural adaptation through
the application of scientific or scholarly techniques such as controlled observation, contextual
measurement, controlled collection, analysis, interpretation, and explanation (see ARPA and 32 CFR
§229.3).
Area of Potential Effect (APE)—The land area an undertaking has the potential to effect. The APE
includes the footprint of the proposed project, and areas around the footprint that might be affected by
visual, auditory, erosional, and other direct and indirect results of the undertaking.
Arrowheads—Used generically in ARPA and this Instruction to refer to any shaped stone projectile point
used to tip spears, darts, arrows, or other thrusting tools. Casual surface collecting (not digging)
arrowheads from archaeological sites is specifically exempted from criminal acts of vandalism as defined
by ARPA Section 6.
Comprehensive Agreement—An agreement between a Federal agency and an Indian Tribe affiliated
with NAGPRA remains or cultural objects, concerning all agency land management activities that could
result in the intentional excavation or inadvertent discovery of Native American human remains, funerary
objects, sacred objects, or objects of cultural patrimony. The CA should establish procedures for
consultation, treatment, and disposition of NAGPRA remains or cultural objects likely to be found during
any undertaking or action on agency lands [per 43 CFR §10.5(f)]. The signed agreement, or
correspondence related to efforts to reach agreement, constitute proof of consultation. A Contingency
Plan of Action is similar to a CA, but deals only with NAGPRA remains and objects likely to be
32 AFI32-7065 1 JUNE 2004
discovered during a specific undertaking or action. Tribal and agency officials (e.g., the installation
commander) must sign CAs, but only the agency official signs Plans of Action [per 43 CFR §10.5(e)].
Consultation—A reasonable and good faith effort to involve affected parties in the findings,
determinations, and decisions made during the Section 106 Process, and other processes required under
NAGPRA, AIRF A, NEP A, ARP A, and other statutes and regulations. Consultations with Indian Tribes must
be on a government-to-government level to respect tribal sovereignty and to recognize the unique legal
relationship between the Federal Government and Indian Tribes set forth in the Constitution, treaties,
statutes, and court decisions (see also Notification).
Consulting Parties—In accordance with 36 CFR §800.2(c), parties with consulting roles in the NHPA
Section 106 Process include SHPOs, and or THPOs; Indian Tribal governments; representatives of local
governments; applicants for Federal assistance, permits, licenses, and other approvals; and members of
the Public with interests in the undertaking.
Cultural Resource Professional—A person who meets professional qualifications in anthropology,
archaeology, history, historical architecture, preservation planning, or other preservation specialties set
forth in Section 112 of the NHP A and Archeology and Historic Preservation: Secretary of the Interior’ s
Standards and Guidelines.
Curation—The process of managing and preserving an archaeological collection of artifacts and records
according to professional museum and archival practices, as defined in 36 CFR §79. Refer to Legacy
Resource Management Program Office, Legacy Project No. 98-1714, Guidelines for the Field Collection
of Archaeological Materials and Standard Operating Procedures for Curating Department of Defense
Archaeological Collections," available through the DENIX and AFCEE websites.
Department of the Air Force Federal Preservation Officer (Air Force FPO)—An official appointed
by the Secretary of the Air Force in accordance with Section 110 of the NHP A to direct the AF Cultural
Resources Program. The Air Force FPO is the Deputy Assistant Secretary of the Air Force for
Installations, Environment, and Logistics (SAF/IEE).
Historic Preservation—Section 301(8) of the NHPA, 16 U.S.C. §470w(8), states that historic
preservation "includes identification, evaluation, recordation, documentation, curation, acquisition,
protection, management, rehabilitation, restoration, stabilization, maintenance, research, interpretation,
conservation, and education and training" regarding cultural resources. The Secretary of the Interior's
Standards for the Treatment of Historic Properties (NPS 1992) defines historic preservation as "the act or
process of applying measures necessary to sustain the existing form, integrity, and materials of a historic
property."
Historic Property—Any district, site, building, structure, or object included on or eligible for inclusion
on the National Register of Historic Places (National Register). 36 CFR §60.4 explains criteria for
determining eligibility for listing to the National Register.
Identification of Historic Properties—The first step in the NHPA Section 106 process includes
preliminary work, actual efforts to identify properties, and the evaluation of identified properties to
determine if they qualify as historic properties. The standard is a "reasonable and good faith effort" for
identification and evaluation.
Indian Tribe—For the purposes of this Instruction, the term Indian Tribe includes Federally recognized
American Indian Tribes, Alaska Native Villages, and Native Hawaiian Organizations. A Federally
recognized tribe is one the United States government formally recognizes as a sovereign entity that
AFI32-7065 1 JUNE 2004 33
requires government-to-government relations. The Federal government holds lands in trust for many, but
not all, Indian Tribes. Some Tribes are not Federally recognized, and are not afforded special rights under
Federal law. CRM programs on installations are required under various statutes to notify and/or consult
with Federally recognized Tribes (but not Tribes that are not Federally recognized). The number of
Federally recognized Tribes increases as the Bureau of Indian Affairs adds Tribes to the list.
Integrated Cultural Resources Management Plan (ICRMP)—A document that defines the
procedures and outlines plans for managing cultural resources on DoD installations. ICRMPs are required
for all DoD installations under DoD Instruction 4715.3, Environmental Conservation Program. The
ICRMP differs from previous CRMPs in that it is more comprehensive, and integrates, and is integrated
into, other land management and development plans at installations. Air Force installations must update
their plan every 5 years.
National Register of Historic Places (National Register)—The Federal government's official list of
buildings, structures, districts, sites, and objects that are significant in American history, architecture,
archaeology, engineering, or culture, and are thereby considered for preservation. The National Register
is administered by the Department of the Interior, National Park Service (NPS). Criteria for eligibility, and
the procedures for nomination, making changes to listed properties, and for removing properties from the
National Register are detailed in 36 CFR §60, "National Register of Historic Places."
Notification—Written notification (vs Consultation) is specifically required in various statutes. For
example, affiliated Federally recognized Indian Tribes must be notified 30 days before a Federal agency
may issue an ARP A permit if the proposed research might disturb or harm any Indian tribal or religious
site on agency land [32 CFR §229.7(a)]. Written notification also is required by NAGPRA for planned
intentional excavation or inadvertent discovery of Native American human remains, and funerary or
sacred objects, or objects of cultural patrimony. See 43 CFR §10.5(b) for the list of people who must be
notified under NAGPRA. The NHPA requires notification of the Council that an undertaking will
adversely effect a historic property [36 CFR §800.6(a)(1)].
Plan of Action—A written plan, prepared, approved, and signed by a Federal agency official (e.g., the
installation commander), in response to an inadvertent discovery or intentional excavation of Native
American human remains, funerary objects, sacred objects, or objects of cultural patrimony on agency
land. A Contingency Plan of Action is similar but is developed prior to a specific planned undertaking or
action likely to result in the discovery of NAGPRA remains or objects. Both kinds of Plans of Action are
completed after consultation between the Federal agency and a Federally recognized Indian Tribe
affiliated with the NAGPRA remains or cultural objects. The Plan of Action outlines consultation
procedures, treatment, and disposition of the NAGPRA remains and objects. Signatures of Tribal officials
are not required [43 CFR §10.5(e)].
State Historic Preservation Officer (SHPO)—The official appointed by the Governor of each State and
territory to carry out the functions defined in the NHP A, and to administer the State Historic Preservation
Program. SHPOs provide advice and assistance to Federal agencies regarding their Cultural Resources
Management programs and historic preservation responsibilities. Throughout this AFI, SHPO is
understood to mean THPO where consulting a designated THPO is appropriate.
Tribal Historic Preservation Officer (THPO) —The official appointed by an Indian Tribe in
accordance with the NHPA to administer the Tribal Historic Preservation Program and assume duties and
functions for tribal lands similar to those that the SHPO has for State lands. The Secretary of Interior
designates tribes with THPO responsibilities. Air Force installations must consult with the THPO, instead
34 AFI32-7065 1 JUNE 2004
of the SHPO, on undertakings on or over Indian tribal lands where a Tribe has been granted THPO
responsibilities by the Secretary of the Interior.
Undertaking—Any project, activity, action, or program wholly or partly funded under the direct or
indirect jurisdiction of a Federal agency. Includes projects and activities that are executed by or on behalf
of a Federal agency; Federally funded; require a Federal permit, license or approval; or are subject to State
or local regulation administered through delegation or approval authority by a Federal agency.
Undertaking proponent—The commander, commanding officer, or civilian director of a unit, activity,
or organization, who initiates a proposal for an undertaking, who has command and control authority over
the undertaking once it is authorized, or who has the legal and financial authority to commit the Air Force
to agreements undertaken in compliance with cultural resource laws and regulations.
AFI32-7065 1 JUNE 2004 35
Attachment 2

GUIDELINES FOR PREPARING INTEGRATED CULTURAL RESOURCES
MANAGEMENT PLANS
US Air Force Integrated Cultural Resource Management Plans (ICRMPs) must address and include the
information outlined below. The guidelines offer a suggested structure to the development of a plan.
A2.1. Executive Summary:
A2.1.1. Summarize the major components of the plan.
A2.1.2. Identify future directions for the cultural resources program.
A2.2. General Information:
A2.2.1. Mission Statement: Briefly describe the installation mission.
A2.2.2. Physical Setting: Description of the installation, location, size in acres, climate, geography,
geology, vegetation zones. Include appropriate maps.
A2.2.3. Historical Perspective: A short history of the installation, including how it manages historic
resources.
A2.2.4. Organizational Listing and Roles. List important base organizations, and discuss how their
activities might impact on the historic preservation program. For example: Base civil engineering con-
ducts or oversees most facility and infrastructure development that may potentially affect buried
archeological resources.
A2.2.5. CRM Goals and Objectives:
A2.2.5.1. Outline the goals and planning objectives that might affect cultural resources on the
installation.
A2.2.5.2. Give specific management objectives and milestones. For example: Complying with
cultural resource legislation and properly managing known cultural resources.
A2.2.5.3. Develop a 5-year plan that includes the installation's programmed projects for the
Future Year Defense Plan (FYDP).
A2.2.6. CRM Program Responsibilities:
A2.2.6.1. Describe specific responsibilities for managing the program.
A2.2.6.2. Identify who coordinates and communicates with off-base entities.
A2.2.6.3. Discuss penalties and possible complications from noncompliance.
A2.3. Cultural Resources Inventory:
A2.3.1. Prehistoric and Historic Resources:
A2.3.1.1. Prehistoric and Historic Framework:
A2.3.1.1.1. Briefly summarize the known prehistory and history of the area, citing relevant
and timely literature.
36 AFI32-7065 1 JUNE 2004
A2.3.1.1.2. Identify any relevant research questions or contexts that the SHPO or others have
developed for the area and include them here or as an attachment.
A2.3.1.1.3. Identify affiliated Indian Tribes. Highlight their concerns here and in appropriate
subsequent sections.
A2.3.1.2. Resource Inventory:
A2.3.1.2.1. Archaeological Resources: Begin this section with a statement on the importance
of protecting archaeological site locations and the penalties for disturbance.
A2.3.1.2.1.1. Summarize past archaeological surveys conducted on the installation.
Include dates, surveying agency and/or contractor, results, and references.
A2.3.1.2.1.2. Use tables and text to summarize the installation's archaeological database.
A2.3.1.2.1.3. Consult with the SHPO and other agencies to ensure all recorded archaeo-
logical resources are included in the database.
A2.3.1.2.1.4. Include determinations of eligibility and justifications for all listed sites.
Indicate the status of SHPO and other consulting party concurrence on determinations.
A2.3.1.2.1.5. Describe measures taken to mitigate adverse effects on archaeological
resources. Include dates, conducting organizations, results, references, and curation of arti-
facts and records.
A2.3.1.2.2. Historic Resources: Follow procedures outlined under A2.3.1.2.1. to describe and
summarize inventories, significance, and mitigation measures related to the installation's his-
toric buildings, structures, landscapes, and other resources.
A2.3.1.2.3. Traditional Cultural Resources and Sacred Sites:
A2.3.1.2.3.1. Begin this section with a statement about confidentiality requirements for
select sacred sites and Traditional Cultural Places (TCP).
A2.3.1.2.3.2. Follow procedures outlined under A2.3.1.2.1. to describe and summarize
inventories and the significance of the installation's TCPs and sacred sites.
A2.3.1.3. Areas of Concern:
A2.3.1.3.1. Identify areas on the installation with a high, medium, or low probability for con-
taining archaeological and historic resources.
A2.3.1.3.2. Describe any deficiencies or problems with previous inventories and identify cor-
rective actions.
A2.3.1.3.3. Include a schedule for surveying lands containing significant archeological
resources.
A2.3.2. Mapping: Tie the ICRMP to current maps or GIS files showing locations of all cultural
resource assets, with special care to only generally depict archaeological sites and sacred places. Use
restricted access files for GIS overlays that specifically locate archaeological sites and sacred places.
A2.4. Compliance Procedures:
A2.4.1. Issues:
AFI32-7065 1 JUNE 2004 37
A2.4.1.1. Identify any unique cultural resource issues confronting the installation.
A2.4.1.2. Identify affiliated American Indian tribal concerns, and those of other affiliated groups
who have identified TCPs on the installation.
A2.4.1.3. Identify potential impacts of cultural resource management on other base programs
including:
A2.4.1.3.1. The Installation Restoration Program (IRP).
A2.4.1.3.2. Threatened and endangered species.
A2.4.1.3.3. Training operations.
A2.4.1.4. Establish procedures to ensure archaeological resources are protected in compliance
with ARP A. Include procedures to respond to and document incidents of vandalism to archaeolog-
ical resources.
A2.4.1.5. Identify potential conflicts between the cultural resource management program and
mission accomplishment.
A2.4.1.6. Develop procedures to mitigate potential conflicts, comply with cultural resource legis-
lation, and avoid impairing the mission.
A2.4.2. Preservation and Mitigation Strategies:
A2.4.2.1. Archeological and Historic Resources:
A2.4.2.1.1. Review installation plans and project programming documentation, including
maintenance, upgrade, or renovation projects to identify archeological and historic resources
that may be threatened by proposed construction, acts of nature, or base operations might
threaten.
A2.4.2.1.2. Describe mitigation plans for threatened cultural resources.
A2.4.2.1.3. Include a plan for handling inadvertent discoveries of archeological resources,
including NAGPRA remains and cultural items.
A2.4.2.1.4. Discuss applying the Secretary of the Interior's Standards for Historic Preserva-
tion Projects.
A2.4.2.1.5. Describe any unique historic resource maintenance requirements and define stan-
dard maintenance procedures to satisfy those requirements.
A2.4.2.1.6. Curation of Collections and Records:
A2.4.2.1.6.1. Summarize archaeological and historic properties collections, including cur-
rent locations, size of collections in cubic feet, size of associated records (notes, photo-
graphs, maps, blueprints, etc) in linear feet, type of collections, condition, and other
relevant information.
A2.4.2.1.6.2. Identify curation facilities housing installation collections, and those that
have approved curation agreements with the installation.
A2.4.2.1.6.3. Identify procedures to comply with relevant section of DoD Legacy Man-
agement Program Office Project No. 98-1714, Guidelines for the Field Collection of
38 AFI32-7065 1 JUNE 2004
Archaeological Materials and Standard Operating Procedures for Curating Department of
Defense Archaeological Collections, 1999.
A2.4.2.1.6.4. Identify future curation needs and methods to meet those needs in relation to
the DoD Legacy Guidelines, and 36 CFR §79.
A2.4.2.2. Other Cultural Resources: Include plans that involve research and consultation with
appropriate affiliated Indian Tribes and other interested parties to identify cultural landscapes,
sacred sites, and other related cultural resources.
A2.4.3. Consultation Procedures:
A2.4.3.1. Outline procedures for consulting with SHPO (or THPO where appropriate), the Coun-
cil, and interested parties.
A2.4.3.2. Establish SHPO review protocols and ensure these are incorporated in contracting for
projects and services.
A2.4.3.3. Identify the point of contact and necessary documents for each review agency and con-
sulting party.
A2.4.3.4. Establish internal review procedures to include adequate time for SHPO coordination to
ensure project proponents have sufficient time to respond to comments without delaying the
project.
A2.5. Standard Operating Procedures (SOP). SOPs describe internal installation procedures on various
cultural resource activities and requirements. They must sufficiently define steps necessary to implement
required actions during most routine or reasonably expected situations (for helpful hints, see HQ AFCEE
Cultural Resources Fact Sheet: Recommended Guidelines for Standard Operating Procedures in Inte-
grated Cultural Resources Management Plans, February 2001, available at
http://www.afcee.brooks.af.mil).
A2.5.1. CRMs must ensure that SOPs:
A2.5.1.1. Address specific situations (e.g., training exercises, construction, maintenance, devel-
opment, demolition, cleanup, transfer of ownership, leases, etc).
A2.5.1.2. Are triggered and implemented by specific events (e.g., inadvertent finds, weather dam-
age, crashes, scheduled maintenance, roof replacement, etc).
A2.5.1.3. Identify specific individuals or organizations responsible for executing each part of the
procedure.
A2.5.1.4. Identify tasks and duties of each individual or organization involved with the procedure,
not only the CRM staff.
A2.5.1.5. Link any critical action requiring a decision to a designated office symbol or a backup.
A2.5.1.6. Identify the primary POC responsible for executing each SOP task.
A2.5.2. Cite but do not paraphrase or mirror regulatory procedures. This avoids unnecessary amend-
ments to the ICRMP if regulations change (citation generally do not change).
A2.5.3. Triggering events for SOPs include but are not limited to:
A2.5.3.1. Accidents (aircraft, vehicular, etc) affecting historic properties
AFI32-7065 1 JUNE 2004 39
A2.5.3.2. Indian Tribal access to sacred sites or traditional cultural properties
A2.5.3.3. Coordinating planned construction or maintenance activities with proponents
A2.5.3.4. Cultural resources contracting
A2.5.3.5. Hazardous spills affecting historic properties
A2.5.3.6. Historic building demolition
A2.5.3.7. Inadvertent discoveries of NAGPRA remains or cultural items. Include developing and
executing Plans of Action.
A2.5.3.8. Initiating the Environmental Impact Analysis Process (EIAP), when EIAP is required.
A2.5.3.9. Natural emergencies affecting historic properties
A2.5.3.10. Recovering jettisoned ordinance or fuel tanks affecting historic properties
A2.5.3.11. Rehabilitation of historic properties
A2.5.3.12. Suspected vandalism or looting of archaeological sites
A2.5.3.13. Unexpected discoveries of archeological materials during construction projects.
A2.5.4. Use your imagination to identify as many standard and expected activities as possible to
address in SOPs.
A2.6. Attachments:
A2.6.1. Attach any supplemental materials that provide useful references, including:
A2.6.1.1. Copies of MOAs, PAs, NAGPRA CAs, and other current signed agreements.
A2.6.1.2. Relevant legislation and regulations.
A2.6.1.3. Relevant guidance.
A2.6.1.4. Relevant and appropriate local policy and procedural documents.
A2.6.2. In a separate volume, or preferably on an electronic medium such as a CD-ROM, compile
copies of all archeological and historic site and inventory forms. Archeological site locations are sen-
sitive information. Do not release them to the general public.
A2.7. Production of ICRMPs: All Air Force ICRMPs must be produced in the appropriate version of
Microsoft Word, and developed in two formats:
A2.7.1. Hard paper copies bound or enclosed in loose leaf binders (depending on installation require-
ments).
A2.7.2. Appropriate electronic media, such as CD-ROM.

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Asset Metadata

Creator Alaniz, Osmar Humberto (author)

Core Title Historic preservation in the United States Air Force: exploring new frontiers

School School of Architecture

Degree Master of Heritage Conservation

Degree Program Heritage Conservation

Publication Date 06/28/2016

Defense Date 02/08/2016

Publisher University of Southern California (original), University of Southern California. Libraries (digital)

Tag cultural resource management,Department of Defense,Historic Preservation,Military,OAI-PMH Harvest,United States Air Force

Format application/pdf (imt)

Language English

Contributor Electronically uploaded by the author (provenance)

Advisor Sandmeier, Trudi (committee chair), Ringhoff, Mary (committee member), Smith, Stephanie (committee member)

Creator Email osmar.alaniz.3@us.af.mil,osmar5@yahoo.com

Permanent Link (DOI) https://doi.org/10.25549/usctheses-c40-257624

Unique identifier UC11280616

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Rights Alaniz, Osmar Humberto

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Access Conditions The author retains rights to his/her dissertation, thesis or other graduate work according to U.S. copyright law. Electronic access is being provided by the USC Libraries in agreement with the a...

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