Less than a year ago (but 3,168 covid years), the City of Savannah passed an archaeological ordinance. The ordinance has many shortcomings, but the idea behind it is to ease into archaeology, starting with a few public property projects as a pilot program. To assess the pilot program, an archaeology committee was formed consisting of representatives from the city, development community members, hobbyists, historic preservationists, and archaeologists. This committee has met twice to give the city feedback on requests for proposals (RFPs) to hire an archaeological firm to carry out the new ordinance. Several individuals (myself included) with experience in cultural resources management (CRM), the broad industry under which archaeology falls, discussed the importance of having two requests for proposals (RFPs). One RFP would be for a company to conduct the actual archaeology and a second RFP would be for an individual archaeologist or firm to act as a city archaeologist. The “city archaeologist” would be the city’s representative to protect the city’s interests. This is how virtually all CRM legislation works- you have a balance of power between the city/employer and company/employed. We were told this was too expensive. Two RFPs were not going to happen.
Here is a theoretical, while unlikely, example of why we need checks and balances. Let’s say the city accepts Company X’s bid, and Company X now holds the archaeological services contract. Their first project is to assess a piece of surplus property assigned for resale. How would the city know what is an appropriate amount of research and fieldwork? How and who is assessing that Company X is following best practices and not just digging everything in sight while causing the citizens an enormous bill?
The next phase in this pilot program was launched yesterday when the city released an RFP for “Annual Contract for Archaelogical Services” [sic]. Yes, “Archaeological” was spelled wrong.
Once CRM firm(s) are hired, I look forward to seeing how the process works and using these experiences to work out the kinks. Eventually, we need to expand the program to private property and hire a city archaeologist. Without both of these elements, the ordinance is mostly worthless. Despite this slow process (partly due to covid) and the caveats I’ve listed, I am hopeful because we are continuing the process of implementing the Archaeology Resource Protection Ordinance (its official title).
Archaeology sites, once destroyed, are gone forever and so is the history they hold.
The draft archaeological ordinance was released at close of business Friday, November 8. You can read the four-page document as well as view the powerpoints from the public meetings on Speak Up Savannah, the city’s “new social media space” for feedback and discussion. From this site, you can ask questions and get news updates on the ordinance.
Actual feedback on the draft ordinance should be sent to planning@savannahga.gov. From Bridget Lidy’s notification email: “Comments will be accepted through November 20. Prior to posting the final version of the ordinance, we will review and evaluate all comments received. A final version of the ordinance will be posted by November 25 in preparation for City Council consideration in December.”
The draft ordinance is exactly as advertised. Archaeology will be required on city construction projects over 1,500 sq. ft. only, using the “traditional” three-staged process of survey, evaluation, and mitigation. The ordinance can be interpreted as only applying to buildings, but not infrastructure such as utilities, which also disturb the ground. It will be illegal to dig or remove artifacts on city property (it already is illegal to dig on city property, but not for archaeological reasons). Also no metal detector use on city property.
Other than the obvious problem that this ordinance will not cover 95% of the development in the city, I will be submitting a few other comments. First, the ordinance defines an archaeological site as artifacts and remains in a location that are at least 75 years old. Fifty years is the federal guideline, and 75 is too long. Once an archaeology site is gone, it’s gone forever. You don’t get the chance to get back a 1950s civil rights site that’s “not old enough”.
Another big problem: there is no mention of public outreach and education. One of the biggest benefits of requiring archaeology is sharing the findings with the public. It’s also one of the concerns voiced at the second public meeting. I won’t go deeply into all of the public benefits of archaeology (cultural, economic, educational), as there have been entire books written on the subject. But to not require public outreach is a huge “missed opportunity“.
Savannah Under Fire Project in Madison Square, Savannah
The city is putting forth a very weak archaeology ordinance. City Council will vote on it in late December. Then a committee will be formed to explore an ordinance that might actually be useful and lots of different groups will have input.
The Details
At the October 24 meeting, city officials presented the feedback received about the possible archaeology ordinance. I was hoping to have a copy of the presentation to share, but I’m afraid you’ll have to do with my notes and crappy pictures taken during the meeting.
Quick summary of survey findings:
567 people took the survey
85% believe we need an archaeology ordinance
70.5% believe it should apply to the whole city (as opposed to just the downtown historic district or just historic districts)
84% believe the ordinance should apply to both public (city) and private projects
Acting Zoning Administrator Bridget Lidy, who led the meeting, also stated there was a very vocal minority who were strongly against the ordinance.
The bottom line– Lidy is writing an ordinance that will only apply to city projects, meaning the city will have to do archaeology in some form before doing development projects. Artifacts found during this process will be placed in an archaeological repository. The ordinance will require any city property sold to have an archaeological survey. It will prohibit metal detecting and other archaeological-type activities on city property. Note digging on city property without a permit is already illegal in general (not for archaeological reasons). Here is the timeline.
This is a very tight timeline. Early next year, the city will form a committee charged with:
studying the impacts of the initial ordinance and
determining the components of a (potential) more robust ordinance
The committee members will include archaeologists, developers, hobbyists, historic preservationists, the Metropolitan Planning Commission employees, and representatives from the Gullah Geechee and Native American communities.
At the meeting, community members expressed two general concerns. One is that residents will have to do archaeology every time they plant an azalea or do other minor changes to their homes. This is not how archaeology ordinances work. Most archaeology ordinances do not even apply to individual homes, and if they do, it’s only for new construction or major renovations that would significantly destroy an archaeology site in the process. Whether residences should be included or not would be up for discussion during Round 2.
The second concern was that the ordinance would prohibit hobbyists and metal detectorists. This concern was couched in terms of private property rights. The hobbyists criticized archaeologists for not finding anything, never sharing their finds, never publishing, and generally being stingy. The hobbyists did not seem to be able to distinguish between the process of professional archaeology and what hobbyists do. It is true, archaeologists do not always find sites. But sometimes we do. When we do, we share those reports whenever possible. See my technical reports here and here, and LAMAR Institute’s 200+ reports here for example. Sometimes CRM (cultural resource management) companies cannot share their archaeology reports because of contractual obligations, or the reports are shared on a very limited basis because they don’t have the budgets for large scale publications.
More importantly, everyone needs to understand the difference between hobbyists and professional archaeology. Both hobbyists and professional archaeologists destroy archaeology sites. Much as the Mythbusters always said, “the difference between screwing around and science is writing it down.” Professional archaeologists record archaeology sites through maps, photographs, and (yes) paperwork. They also take soil samples to extract tiny artifacts, pollen, and phytoliths, which can tell us about people’s diet, climate, and environment. Soil samples taken from privies (outdoor toilets) can contain parasites that let us know whether people are healthy (or not!). This recording process is critical because each archaeological site is unique and irreplaceable. Once excavated, it is gone forever, along with all of the (pre)history contained in it. Archaeologists use these records and paperwork along with their lab analyses of artifacts, soil samples, and soil stratigraphy (layers) to understand the history contained in the site. This is a relatively slow process. It’s not just about fieldwork. The real understanding comes in the lab using the scientific research process.
After analysis, artifacts go to an archaeological repository so they are accessible for other researchers. They write technical reports that go the State Historic Preservation Office (SHPO) and usually local libraries or archives. Since the 1990s, public outreach and education has been an increasingly important (and often unpaid) part of the job too– including social media, lectures, visiting classrooms, site tours, kids books, popular publications, and the ArchaeoBus, just to name a few.
Hobbyists pull artifacts from the ground. They may even research those artifacts. But their understanding of those artifacts and the larger history of the site are minuscule compared to professional archaeologists because they don’t have the context, or all of the information surrounding an artifact (remember that annoying paperwork?). Hobbyists also often rely on metal detectors, so they only look at metal artifacts. Imagine someone trying to understand your life by only looking a very small portion of the evidence. Their conclusions would be seriously skewed.
I look forward to the continuing dialogue about how Savannah should treat its archaeology sites. I’m happy to answer questions about how archaeology really works. (The guy in the fedora isn’t really an archaeologist).
Quick edit- there are many, many excellent programs that include volunteers working with professional archaeologists. These types of partnerships are incredibly valuable, and I would love to see more of them everywhere, especially Savannah. The hobbyists I refer to above are folks working independently.
Local and state archaeological ordinances often mirror the federal preservation legislation, primarily the National Historic Act of 1966, but there are differences in the level of detail. How do they work? What are these Phases? What does mitigation mean? In order to have an informed opinion when you take the Savannah Archaeological Ordinance Survey, read on.
In general, when a new development (hotel, arena, etc…) is proposed it goes through a permitting process. One of those permits can be for archaeology. An initial check is done to learn the property’s history including known archaeology sites, what has been built, and how previous development may have affected archaeology sites. If there is potential for archaeology sites, then a Phase 1 survey is done. Typically, in the Southeast, this means hiring an archaeologist to do shovel test pits (roughly one-foot diameter holes dug in a grid pattern).
Digging shovel test pits in Emmet Park during the Savannah Under Fire project.
If artifacts are found indicating a site(s) is present, then it’s on to Phase II. Phase II involves more extensive excavations to see if the site(s) is intact and is likely to yield good data. For projects under the federal legislation, the main question asked is, “Is this site eligible for the National Register of Historic Places?”. There are four National Register criteria under which properties can be nominated:
Criterion A: “associated with events that have made a significant contribution to the broad patterns of our history.”
Criterion B: “associated with the lives of persons significant in our past.”
Criterion C: “embody the distinctive characteristics of a type, period, or method of construction, or that represent the work of a master, or that possess high artistic values, or that represent a significant and distinguishable entity whose components may lack individual distinction.” (aka important architecture)
Criterion D: “have yielded, or may be likely to yield, information important in prehistory or history.” (aka archaeological sites)
Students and volunteers excavating at the Kiah House, 2018. These are test pits, typical of Phase II excavations.
If the site is eligible for the National Register, then you go to Phase III, or mitigation. For archaeology sites, mitigation usually means large scale excavation to get the data from the site before it is destroyed. On extraordinarily rare occasions, mitigation involves preserving in place (or in situ).
At each stage in the process, there should be consultation with any interested groups. For example, if you are excavating a Benedictine monastery and Freedmen school, you would consult with the current Benedictine community at Benedictine Military School and the Savannah diocese. Also, the archaeologists would try to find the students’ direct descendants, as well as reaching out to the larger African American community.
Ordinances have the three phase structure to avoid wasting lots of time and money on unnecessary excavation. The process only proceeds to the next phase if it is warranted. By integrating the archaeology into the permitting process, you get everything done before the construction. It is also important to note, a small percentage of proposed development projects ever get to a Phase I, and very few ever get to Phase III.
Who manages this process? The optimal answer is a city or county archaeologist. They review permit applications and guide the process. The developer (or other permit applicant) hires archaeologists on a project-by-project basis to research, excavate, analyze, and write technical reports for each phase.
Who does the ordinance apply to? This varies widely. Some ordinances only apply to public (governmental) projects. Others legislate public and private developments. Private development usually applies to businesses, not private homes. I’m not aware of any archaeological ordinances that apply to homeowners.
How much development is enough for the ordinance to apply? In other words, we don’t want the ordinance to apply every time someone replaces a fence post. But how much is enough trigger the ordinance? This is another decision to be made as the ordinance is written.
Where does the ordinance apply? Ideally, the ordinance would cover the entire county, but since this is a city initiative, that’s all we have to work with. I cannot stress this enough- there are archaeology sites everywhere, not just in the downtown historic district, or just in the historic districts.
Frequently, incentives are offered to offset the “inconvenience” of doing archaeology. Incentives can include an expedited permit review process and/or reduced development or permit fees. Often, these incentives are used as a carrot to encourage archaeology, rather than requiring archaeology and giving incentives as a benefit. Making archaeology optional and only offering incentives will make a very weak ordinance and will result in very little archaeology completed.
How much is this going to cost me? As a resident, a properly written ordinance should not cost you. For federal legislation, the cost of archaeology is typically 1% or less of the total project cost. The city’s cost could be covered by an archaeological fee assessed on development or as a percentage of the development’s total cost. My opinion is that whoever is destroying the site, needs to pay for its mitigation.
I urge you to look over the gold-standard, Alexandria Archaeology. From their downtown museum, they run student programs, walking tours, kid and adult hands-on programs, field schools, lectures, site tours, summer camps, and many volunteer opportunities.
I wanted to share a few take-aways from last night’s public meeting about our potential archaeology ordinance. First, most importantly, if you want to comment on this subject, please take their survey and/or send general comments to planning@savannahga.gov. The survey will close on October 15, so that’s not a lot of time to get feedback. I’d be happy to answer any technical questions, such as what is this Phase 1, 2, 3, thing? Post them to the Facebook page and I’ll answer them so everyone can learn. It is also important to make your support known directly to your alderman and the mayor. Click here for their contact information. Except, use chbell210@aol.com for Carol Bell, because she admitted to us at a neighborhood association meeting that she rarely checks her city email address. Any one in opposition to the ordinance will absolutely be contacting their city officials and likely meeting behind the scenes, rather than attending these public meetings. I suggest anyone that can, do the same.
The meeting had a good turnout, around 55 people. Acting Zoning Administrator Bridget Lidy and Municipal Archives Director Luciana Spracher spent most of the discussing the city’s history with doing archaeology and were very honest about the many missed opportunities. It seemed like most (all?) present were in favor of an archaeology ordinance, and several people spoke out with excellent ideas. For example, someone commented that in St. Augustine, every development project has an associated fee that go towards funding their archaeology program.
The crowd last night.
The next public meeting will be October 24, 6pm, again at the Coastal Georgia Center. The city staff will report what they have learned from our feedback, but probably not have a draft ordinance yet. Their goal is to have an archaeology ordinance to present to City Council for a vote by January 1, 2020.
Some general observations and strictly my opinion: Any ordinance that does not include a city archaeologist will not be worth much. Any ordinance that only applies to public, but not private, projects will not be worth much. There are serious considerations on how to fund an archaeology program. There are lots of models out there, Alexandria Archaeology being the gold standard. Boston has another great program. Archaeology sites are generally stable until they are disturbed by digging through them. Personally, I believe the person or company who wants to disturb the archaeology site should be the one to pay for the professional excavation.
The devil is in the details. It sounds likely that an archaeology ordinance in some form will be presented to City Council early next year. The question is what form it will take and whether it will be actually effective in preserving the data and history from archaeology sites.
Finally, as a former teacher, I feel the need to remind people about citations. Pro Tip: When you steal internet images for your powerpoints, it’s polite to acknowledge the source. Especially when your audience is full of the people whose images you stole.
Why do we need an archaeological ordinance? How would Savannah benefit? Why should you bother to attend a public meeting on the potential ordinance? I’m going to answer the last question first- The City of Savannah has previously balked at creating an archaeological ordinance, citing pressure from looters. Without a big turnout, I fear they will drop the issue, and we won’t get another chance. Join us tonight, September 26, 6pm at the Coastal Georgia Center (305 Fahm St, Savannah, GA) and speak out about the importance of archaeology.
How Savannah Benefits from Archaeology
1. Reduces expenses to city departments currently required to deal with unexpected crises such as adverse impacts to archaeological sites from hurricanes, discovery of buried explosive ordnance, and other issues.
2. An awareness of heritage decreases blight by providing a sense of place, pride, and connection for residents of all parts of the city. “Heritage anchors people to their roots, builds self-esteem, and restores dignity.” Cities such as Phoenix, AZ include archaeology in blight-reduction plans.
3. Eliminates “surprises” to developers and the city, such as the discovery of unknown graves, unexploded ordnance, and other PR issues that would slow or stop development. Who remembers the family cemetery found on White Bluff Road that delayed the auto parts store?
4. Provides developers with unique content, artifacts, and information that can be used in exhibits and marketing within their development.
5. Diversifies tourism and provides authenticity and accurate information for tourism content. This makes Savannah more than just another ghost tour town. “A city’s conserved historic core can differentiate that city from competing locations – branding it nationally and internationally…”
6. Provides outreach opportunities for disenfranchised youth, K-12 STEM educators, and all residents.
7. Documents and preserves local cultures before they are destroyed (ex. Gullah-Geechee village).
Savannah is Georgia’s oldest city and holds national and international significance. Its history drives a massive economic engine. This history, most abundant in its archaeological sites, is being destroyed daily. Savannah can stop this destruction without slowing or stopping development. Savannah lags behind more than 269 cities, including ones in Mississippi and Alabama, in protecting its priceless archaeological sites. During the past 30 years, Savannah has revisited an archaeology ordinance but taken no action. In that time, hundreds of archaeological sites have been decimated. The irreplaceable information they contain is now lost forever, but it is not too late to save what remains.
Number of people who signed the 2016 petition for an Archaeology Ordinance in Savannah: 1,245
Myth 1: Archaeology will slow or stop development. Wrong. An archaeology ordinance will enable developers to know exactly what they need to do far in advance, allowing archaeology to be completed prior to construction start dates.
Myth 2: Archaeology is cost-prohibitive. Incorrect. An archaeology ordinance will allow developers to plan accordingly and include the low cost of doing archaeology along with other routine costs of developing a property. Archaeology costs are negligible on most projects and especially on many of the current projects such as the $270 million dollar development along River Street.
Myth 3: Developers will not develop if they are required to have archaeology done on their property. Not true. Other cities with archaeological ordinances have shown no decrease in the level of development as a result of archaeology ordinances.
Myth 4: A City Archaeologist position is an unnecessary expense. False. A dedicated position will save the city money by helping insure front-end planning for developers, on-call expertise available for all city departments, lower cost and quicker “in-house” archaeological investigations, and the competent creation and execution of MOAs, PAs, Scopes of Work, RFPs, and RFQs. In 2011, San Antonio, TX saved “several hundred thousand dollars” by having a City Archaeologist.
Myth 5: Few in Savannah really care about its archaeological sites. Untrue. Residents, businessmen and women, and tourists care. The reason policy makers haven’t heard this concern is that the public thinks the city is already protecting its non-renewable archaeological sites. In fact, many city leaders incorrectly think the same thing. The public is appalled when they learn otherwise.
Heritage tourists spend more per day (27%) and stay longer (1-3 more days) than other travelers. Archaeology feeds heritage tourism.
Credits: Rita Elliott wrote most of this in a two-page brief for distribution to the public and city officials. It was written explicitly for R&D (rip-off and duplicate) and was designed to be shared. Please do!
Savannah Archaeological Alliance 