Please Write Your Legislators

From Christopher Judge:

"I urge everyone to write to your legislators now and ask them to see that the Office of Coastal Resource Management within DHEC reverse their recent policy change whereby they no longer require that cultural resources surveys be conducted along our SC coast. More details are attached in a letter from Sean Norris Presdient of the Council of SC Professional Archaeologists:"

Carolyn Boltin-Kelly, Deputy Commissioner
Rheta Dinovo, Director of Regulatory Programs
DHEC-OCRM
1362 McMillan Avenue
Suite 400
Charleston, SC 29405

Dear Deputy Commissioner Boltin-Kelly and Director Dinovo:

In 2011, the Department of Health and Environmental Control-Ocean and Coastal Resource Management Division (OCRM) revised its policy so that archeological surveys will no longer be required for land disturbance permits. The Council of South Carolina Professional Archaeologists believes that this policy change should be reexamined. With the 1977 Coastal Zone Management Act OCRM has been mandated to consider, "the extent to which the development could affect irreplaceable historic and archeological sites of South Carolina's coastal zone" (Section 48-39-150(A)(6)).

Since the OCRM has no archaeologist or historian on staff, it consults with the South Carolina State Historic Preservation Officer (SHPO) in order to identify irreplaceable historic and archaeological sites. The SHPO maintains a list of all the archaeological sites that have been submitted to the state for review. The SHPO makes a determination of whether a site submitted for review is important enough to be on the National Register of Historic Places. OCRM has interpreted its mandate to consider irreplaceable sites as simply using SHPO’s inventory of sites on the National Register as the final list of sites that will be protected. As new sites are added to the SHPO’s list OCRM can add them to their list.

This is where the process falls apart. SHPO is a review agency; they do not actively undertake archaeological surveys. OCRM tasks agencies such as the South Carolina Department of Natural Resources and Fish and Wildlife to provide information on important natural and biological resources. These agencies physically go out in the field and identify those resources. SHPO, on the other hand, only reviews archaeological site surveys that have been requested by Federal or State agencies. If the State agency (OCRM) does not request an archaeological survey no new sites can be added to SHPO’s list and therefore fewer sites will be added to OCRM’s list.

OCRM has recognized this gap in the past and has appropriately consulted with SHPO on permit applications. SHPO would review their records and if no archaeological survey had been done in a permit area and if there were Native American shell mounds, plantation sites, cemeteries or other sites in the vicinity or on similar landform settings they would recommend that OCRM require the permit applicant to conduct an archaeological survey. The reason was similar to OCRM requiring a Wetlands Master Plan, or a map showing where the wetlands were on a property and how they will be affected. To generate a Wetlands Master Plan someone has to survey a property to find where the wetlands are. Similarly, someone would have to survey a property to find the archaeological sites.

The as-yet unidentified, unknown sites are of great concern. According to records on file at the SHPO, in the last ten years alone Cultural Resource Surveys initiated by OCRM permits have identified numerous previously unknown significant archaeological sites such as Palmetto Bluff in Beaufort County and the Dean Hall Plantation slave settlement in Berkeley County. These sites provide invaluable information concerning the history and prehistory of South Carolina. They would have been lost without OCRM recommending archaeological surveys.

The professional archaeological community understands the need for development on the coast. For decades we have worked with developers in order to minimize the cost of our services while still being responsible stewards of the archaeological resources. The cost of an archaeological survey is marginal compared to other costs a developer will encounter. The destruction or loss of a significant archaeological site can only hurt one of the things that makes the coast of South Carolina so special. The amount of money generated by heritage tourism on the coast is significant. According to South Carolina Parks Recreation and Tourism, in 2003 there were 1.6 million visitors to historic attractions in South Carolina spending an average of $62 a day. The Advisory Council on Historic Preservation cites a 2002 Department of Commerce statement that for every 1000 heritage tourists 10 jobs are created. Additionally the jobs of the professional archaeological community are affected by the policy change.

The archaeological community encourages OCRM to review and revise its policy in order to protect, sustain and promote the unique character of life on the coast that is reflected in its archaeological and historical resources.

Sincerely,

Sean Norris
President-Council of South Carolina Professional Archaeologists