Here at the State Historic Preservation Office (SHPO) one of our main duties is to identify and nominate properties to the National Register of Historic Places (NRHP) program. We take this seriously. Utah has over 100,000 known archaeological sites that encompass at least 12,000 years of human history, and the NRHP is one of the most powerful tools we have to recognize these sites and grapple with their historic context.
Recently, one compendium of sites on Bureau of Land Management (BLM) public lands was nominated to the NRHP. The BLM turned in “The Rock Art and Archaeology of Moab’s Colorado River System Multiple Property Submission (MPS)” along with approximately 200 accompanying nominations for individual rock art sites. The National Park Service (NPS), which manages the NRHP program, returned this submission for revision. The Keeper of the National Register did not accept this nomination based on technical issues, not on substantive issues, regarding the value of this rock art to local, regional, and national communities. All parties, including the Keeper, agree that the rock art is important to understanding prehistoric peoples and support its preservation. Here are some quick facts about the nomination and an update on the process:
The National Register did not reject the nominated resources.
The NPS returned the nomination based on the need to use a different form.The NPS’ letter to the BLM and Utah SHPO did not deny that the properties were of sufficient value for inclusion on the National Register. The Utah SHPO and BLM stand behind the assessment that these sites should be included on the Register. Return of the nomination was based purely on the need for proper documentation on NPS-approved forms.
The process followed by the BLM and Utah SHPO to nominate the sites was informal and ultimately not approved.
A decade ago, the Utah SHPO had established an informal protocol with the National Register that allowed abbreviated versions of official site records to be used for formal nomination, instead of the normally required format. With both time and NPS staff turnover, the current National Register staff does not recognize the earlier informal protocol and is now requiring the BLM to record each site on its standard form – a procedure consistent with all other historic property nominations across the entire country.
The archaeological sites were not recorded in vain.
Although the documentation supplied was not considered adequate for the National Register Office, these sites have been documented up to the standards set forth by the Utah SHPO and BLM. These sites will receive the same consideration and treatment by the BLM as though they were listed on the National Register of Historic Places. Listing these sites on the National Register will not ultimately confer additional protections or considerations above and beyond what the BLM has already committed to.
The Utah SHPO stands ready to review any new documentation for these sites and to pass a revised nomination onto the Keeper of the National Register. We fully support the BLM and the dedicated volunteers who committed their time and energy to this project. Although having a nomination passed back for editing can sting, it is not an uncommon occurrence. The Utah SHPO and BLM have already started plans on how to find the money and time to get this nomination into the shape needed for eventual listing at the NRHP.
If you’d like to learn more about the Utah SHPO and the National Register of Historic Places, please visit history.utah.gov/preservation/national-register. And if you’d like to learn more about Utah archaeology and get involved with archaeological events and activities in your area, check out history.utah.gov/antiquities/upan and sign up for our newsletter.