Cultural Resource Management: Protecting Heritage

Picture a construction crew clearing land for a new highway in Virginia, and a bulldozer blade scraping against something that is definitely not rock — curved, dark, unmistakably human. The crew foreman picks up a phone, and within hours archaeologists arrive to document what turns out to be a seventeenth-century colonial burial ground. This scene plays out thousands of times every year across the United States and around the world, and it represents cultural resource management in action — the often-unseen profession that balances the relentless momentum of development with the fragile, irreplaceable evidence of the human past. Without cultural resource management, most of the archaeological sites we know today would have been destroyed before anyone could study them.

What Is Cultural Resource Management?

Cultural resource management, commonly called CRM, is the professional practice of identifying, evaluating, and preserving cultural resources — archaeological sites, historic buildings, cultural landscapes, and traditional cultural properties — in the context of land-use planning and development. In the United States, CRM archaeology employs more archaeologists than any other sector — roughly 70 percent of all professional archaeologists work in CRM, not in academia or museums.

The Birth of a Profession

CRM emerged from the environmental movement of the 1960s and 1970s. The National Historic Preservation Act of 1966, the National Environmental Policy Act of 1969, and the Archaeological and Historic Preservation Act of 1974 created a legal framework requiring federal agencies to consider the effects of their projects on cultural resources. Section 106 of the National Historic Preservation Act is the most frequently invoked of these provisions — it requires federal agencies to identify historic properties, assess the effects of their projects on those properties, and consult with state historic preservation offices and other stakeholders to avoid, minimize, or mitigate adverse effects.

Who Does CRM?

CRM archaeologists work for private consulting firms, tribal governments, state and federal agencies, and nonprofits. A typical CRM project might involve a private energy company hiring an archaeological consulting firm to survey a proposed pipeline route, identify any archaeological sites along the route, test those sites to determine their significance, and either redesign the route to avoid them or excavate them before construction begins. The archaeologist who makes that site evaluation is a CRM professional, and their work has legal and financial consequences that can run into millions of dollars.

The CRM Process

CRM follows a well-established sequence of steps designed to build information incrementally and allow decisions to be made at each stage.

Phase I: Identification Survey

Phase I is the initial survey designed to identify cultural resources within a project area. Archaeologists walk the land, examine exposed surfaces for artifacts, dig shovel test pits at regular intervals, and use geophysical survey techniques where appropriate. Every find is recorded with its GPS coordinates, photographed, and collected for analysis. The Phase I report describes the survey methods, presents the findings, and makes recommendations about which sites warrant further investigation.

On a large project — a highway corridor or a pipeline spanning multiple states — Phase I survey can involve dozens of archaeologists walking hundreds of linear miles. The Dakota Access Pipeline survey, before it became nationally controversial, involved thousands of shovel tests across four states and identified hundreds of archaeological sites along the proposed route.

Phase II: Evaluation

If Phase I identifies archaeological sites, Phase II determines whether they are significant enough to warrant preservation. “Significance” in CRM terminology means eligibility for listing on the National Register of Historic Places. A site is eligible if it meets at least one of four criteria: association with important events, association with important persons, distinctive design or construction, or potential to yield important information about the past.

Phase II evaluation typically involves limited excavation — enough to determine the site’s age, integrity, research potential, and horizontal and vertical extent. The excavators dig test units, screen all soil through quarter-inch mesh, collect artifacts for analysis, and record stratigraphy. The Phase II report evaluates each site against the National Register criteria and recommends whether the site is eligible or not.

Phase III: Data Recovery

If a site is eligible for the National Register and the project cannot avoid it, Phase III data recovery — essentially full-scale excavation — is required. The goal is to recover all significant information from the site before it is destroyed by construction. Data recovery excavations are governed by a detailed research design approved by the state historic preservation office. They follow the same professional standards as academic excavations but operate under tighter deadlines and more constrained budgets.

Mitigation Beyond Excavation

Excavation is not the only form of mitigation. Project redesign to avoid sites entirely is the preferred option under Section 106 and is far more common than most people realize. Pipeline routes shift by a few meters, construction boundaries contract, bridge foundations are relocated — all to avoid archaeological sites. When avoidance is impossible, other mitigation measures may include site capping (covering the site with clean fill to protect it), site monitoring during construction, or public interpretation through signage, brochures, or museum exhibits.

The Legal Framework

CRM archaeology is fundamentally a legal profession, and practitioners must understand the statutes and regulations that govern heritage protection.

Section 106 of the National Historic Preservation Act

Section 106 is the workhorse of American cultural resource management. It establishes a four-step process: (1) initiate the Section 106 review, (2) identify historic properties, (3) assess adverse effects, and (4) resolve adverse effects through consultation. The process is triggered whenever a federal agency funds, permits, licenses, or carries out a project. Because so many projects involve federal funding or permits — highway construction, pipeline crossing of waterways, telecommunications towers on federal land — Section 106 review touches an enormous number of development projects every year.

NAGPRA and Tribal Consultation

The Native American Graves Protection and Repatriation Act of 1990 (NAGPRA) established the rights of Native American tribes over human remains, funerary objects, sacred objects, and objects of cultural patrimony found on federal or tribal lands. NAGPRA requires consultation with tribes when archaeological excavations encounter Native American remains and establishes processes for repatriation. CRM archaeologists must be trained in NAGPRA compliance and tribal consultation, and relationships between CRM firms and tribal historic preservation offices are often among the most complex and sensitive aspects of CRM practice.

International Frameworks

The UNESCO World Heritage Convention (1972) provides an international framework for cultural resource management, though its enforcement mechanisms are limited. The convention establishes the World Heritage List, identifies sites of outstanding universal value, and requires signatory nations to protect their World Heritage properties. In practice, national and state-level legislation — such as the United Kingdom’s Ancient Monuments and Archaeological Areas Act of 1979 or Australia’s Aboriginal and Torres Strait Islander Heritage Protection Act of 1984 — provides the actual regulatory teeth for heritage protection.

Ethics and Tensions in CRM

CRM archaeology operates at the intersection of science, business, and policy, creating tensions that practitioners must navigate daily.

Development vs. Preservation

The fundamental tension in CRM is between development and preservation. CRM archaeologists work within a system that assumes development will proceed — the goal is not to stop projects but to ensure that cultural resources are considered and, where possible, protected. Critics argue that the system amounts to a license to destroy, allowing developers to pay for excavation as a cost of doing business while the archaeological record is steadily depleted. Supporters counter that CRM has preserved more archaeological information than any other approach in human history, and that without the legal framework, development would destroy sites without any documentation at all.

Professional Standards and Commercial Pressures

CRM firms operate as businesses. They compete for contracts on price and schedule as well as quality. This creates pressure to cut corners — to survey less intensively, to test fewer shovel tests per acre, to write reports more quickly. Professional organizations such as the Register of Professional Archaeologists and the Chartered Institute for Archaeologists maintain standards and ethics codes that require CRM archaeologists to resist these pressures, but the tension between commercial realities and professional ethics is a constant feature of CRM practice.

Public Engagement

CRM archaeology produces an enormous amount of data — excavation reports, artifact collections, technical studies — that rarely reaches the public. Gray literature, the technical reports produced for CRM projects, is notoriously difficult to access, though digital repositories like the Digital Archaeological Record (tDAR) and the Archaeology Data Service are improving the situation. Public outreach requirements attached to some projects — signage, public lectures, school programs — are often the only way that local communities learn about the archaeology in their own backyards.

CRM Around the World

While the United States has one of the most developed CRM systems, heritage protection takes different forms globally. In the United Kingdom, the planning system requires archaeological evaluation before development consent is granted, and the “polluter pays” principle ensures that developers fund mitigation. In China, rapid economic growth has created a construction boom that makes CRM a constant challenge — the Three Gorges Dam project submerged thousands of archaeological sites despite a massive salvage excavation program. For more on how field methods underpin CRM practice, see Field Archaeology.

The Future of CRM

CRM faces several significant challenges. Climate change is threatening coastal archaeological sites at an accelerating rate, creating an urgent need for rapid survey and documentation before sites are lost to sea-level rise. The COVID-19 pandemic disrupted fieldwork schedules and created backlogs of unprocessed collections and unwritten reports. The profession is also grappling with equity issues — CRM has historically been predominantly white and male, and efforts to diversify the workforce are ongoing. Despite these challenges, CRM remains the primary mechanism for heritage protection in most of the world, and the demand for CRM professionals continues to grow as development expands. For more on ethical issues in archaeology, see Archaeological Theory.

FAQ

What is the difference between CRM and academic archaeology?

CRM archaeology is conducted within the framework of development and land-use management, under legal requirements and tight schedules. Academic archaeology is driven by research questions chosen by the investigator, with more flexible timelines. CRM employs far more archaeologists than academia.

Who pays for CRM archaeology?

The developer or project proponent pays for CRM work under what is called the “polluter pays” principle. In the United States, federal agencies fund Section 106 compliance as part of their project budgets. The cost is ultimately borne by taxpayers or consumers.

Can CRM halt a development project?

CRM can require project redesign to avoid sites, and it can add time and cost to a project, but it rarely stops a project entirely. The Section 106 process is designed to balance preservation with development, not to prevent development.

What happens to artifacts found during CRM excavations?

Artifacts and records are curated in a repository — typically a museum, university, or tribal facility — where they are available for future research. Curation costs are a significant and often underfunded component of CRM.

How do I become a CRM archaeologist?

A bachelor’s degree in archaeology or anthropology is the minimum requirement. Most CRM positions require a master’s degree for career advancement. Field school training and demonstrated knowledge of Section 106 and NAGPRA compliance are essential.

What is the biggest challenge facing CRM today?

Climate change threatens more archaeological sites than all development projects combined, and CRM lacks the funding and regulatory framework to address the scale of the threat. Coastal erosion is destroying sites faster than they can be documented.