2.0 Methods of Investigation, part II.

2.2 Historic Architectural Inventory

As discussed above, MCD facilities that are of historic age, were previously reviewed by Foss (2001) and determined to be ineligible for the NRHP. However, the architectural survey was conducted for the purpose of determining if any undocumented aboveground historic architectural resources would be impacted by the proposed undertaking. The APE as defined in 36 CFR 800.16(d), is the geographic area or areas within which an undertaking may directly or indirectly cause changes in the character or use of historic properties if any such properties exist. Typically, the architectural APE includes both the project tract for the proposed undertaking, as well as its viewshed.

Background investigations consisted of a review of current and historic maps and aerial photographs, county tax records, and an examination of all previously recorded architectural resources and surveys located within, or immediately adjacent to, the architectural APE. Recorded real estate deeds and plat maps were examined to determine the patterns of development within the APE. Background research included analysis of historic resource forms for previously recorded historic architectural buildings and structures located within the architectural APE. In addition, files were reviewed to determine whether NRHP listed architectural resources were located within the architectural APE.

Because of the nature and scope of the undertaking, there is limited potential for direct or indirect effects to historic resources anticipated to be created by the decommissioning of the MCD industrial park development. Despite its remoteness, the surrounding township beyond MCD was assessed. However, although the potential viewshed across remote desert flats can be several miles, visual analysis was also impractical for a variety of reasons:

1. Generally speaking the MCD perimeter fence dominates the landscape in most directions.  As described above, the perimeter fence is generally 20-ft. tall sections of corrugated metal. Thus, MCD has already impacted the viewshed, and its removal, would arguably restore the historic landscape of Loteria Township.
2. Conversely, the MCD fence, per Foss (2001)[1], primarily built in 1947 has already been determined to be a historic resource on its own, albeit one that is ineligible for the NRHP.
3. The immediacy of the international border on the eastern and southern MCD perimeter fences adds practical, jurisdictional issues for any historic structures in these areas.

Regardless, within and around such a vast tract as MCD the potential for previously unrecorded historic-age buildings and structures not associated with the federal facility was great. Therefore the project historian undertook both a windshield reconnaissance and an intensive survey of the project APE. The survey included a pedestrian inspection of individual properties that fell within the APE and high-resolution photographs were taken of each resource. Notes were taken as to construction method, design and alterations. Most work took place from public rights-of-way, although closer inspection was made of some properties if staff was granted permission by MCD security. Construction dates and the age of resources were based on information from the, field observations, historic maps, tax assessor data, and occasionally local informants. In addition to the coarse windshield survey, finer survey was assisted by the archaeological survey crew, who, of course, traversed the approximately 30, 000 acre property on foot at 30-m intervals, and had the opportunity to initially record numerous structural anomalies away from surface roads for the historian.

2.3 Traditional Cultural Properties and Sacred Sites

Legal mandates pertaining to American Indian cultural resources and religious freedom include the NHPA, Native American Graves Protection and Repatriation Act (NAGPRA), NEPA, Archaeological Resources Protection Act (ARPA), American Indian Religious Freedom Act (AIRFA), and EO 13007. Consultation with the appropriate American Indian groups is necessary to identify Traditional Cultural Properties (TCPs) as well as sacred or ceremonial sites. The NHPA requires protection of TCPs, and access to sacred and ceremonial sites is guaranteed by AIRFA and EO 13007.

The current SOW (USACE-EP 2012) also recommends that, in accordance with Section 110 of the NHPA, consultation with American Indian tribes and other parties should be initiated in an effort to identify TCPs at the facility.

The current CRMP (Foss 2001) previously recommended tribal consultation efforts be considered complete based on personal communications with the local Spanktomie Tribe, whom had been relocated from the Sierra Rica area to southeastern Loteria Township (Section SE ¼, 49) circa 1947.

In early 2012, USACE-EP attempted Tribal consultation for all of MCD property by requesting the Spanktomie provide comment on the 2001 CRMP and the current SOW.  Chief Brown Chicken Brown Cow of the Spanktomie Reservation responded to the request to consult.

In February 2012, TCCRC facilitated a forum was held between representatives of the tribe, GloboMax, Inc. and USACE-EP. Negotiations attempted to draft Memorandum of Understanding (MOU) that outlined potential levels of consultation with consideration to factors such as the cultural significance of a facility to tribe, activity impacts of a proposed project, and consultation options. However, Spanktomie representatives were largely concerned with the disposition of the land following the closure of MCD, and insisted it fall to their ancestral claims, rather than the transferal to the U.S. Bureau of Land Management, National Park Service or U.S. Department of Housing and Urban Development, all of which had been internally discussed with the General Services Administration, which intended to assume interim management of the property from the Department of Defense. 

A dialog was maintained by TCCRC following the breakdown of negotiations throughout the period of investigations. However, the Tribe has not been forthcoming with information on their current or historic cultural practices and to date, the TCCRC has received no information from the Tribe regarding the potential for properties of traditional, religious, or cultural importance at this facility.

In compliance with Sections 106 and 110 of the NHPA, the federal government should continue consultation with American Indian tribes and other parties to identify concerning TCPs, sacred or ceremonial sites, and other items of potential concern for the tribes. Following DoDI 4715.16, TCP consultation should be conducted as part of the Tribal review of this current technical report.

2.4 Evaluation of NRHP Eligibility

Cultural resources are evaluated based on the criteria for eligibility to the NRHP as specified in Department of Interior Regulations (36 CFR Part 60: National Register of Historic Places). According to 36 CFR Part 60.4 (Criteria for evaluation), sites can be defined as significant (i.e., eligible for the NRHP) if they “possess integrity of location, design, setting, materials, workmanship, feeling, and association,” and if they:

A. Are associated with events that have made a significant contribution to the broad pattern of history; or
B. Are associated with the lives of persons significant in the past; or
C. Embody distinctive characteristics of a type, period, or method of construction, or represent the work of a master, possess high artistic values, or represent a significant and distinguishable entity whose components may lack individual distinction; or
D. Have yielded, or may be likely to yield, information important in prehistory or history.

Archaeological properties are usually evaluated relative to Criterion D. As locations of human activities that include physical remains of those activities, archaeological sites are potential sources of important information. As indicated in 36 CFR Part 60.4(d), archaeological sites “that have yielded, or are likely to yield, information important in prehistory or history” can be eligible for the NRHP. The National Park Service defines two requirements for archaeological sites to be eligible under NRHP Criterion D (Savage and Pope 1998:21)[2]:

1. The site must have, or have had, information to contribute to our understanding of human history or prehistory, and
2. The information must be considered important.

The National Park Service provides clarification for the first requirement by stating that an archaeological site is eligible for the NRHP if that site “has been used as a source of data and contains more, as yet unretrieved data” (Savage and Pope 1998:21).

Regarding the second requirement, Glassow (1977)[3] recommends careful consideration of specific site attributes (integrity, clarity, artifact frequency, and artifact diversity) in determining whether an archaeological site contains important information. Under Criterion D, importance or significance can be defined as research potential. The research potential of an archaeological site lacking architectural remains can be determined by demonstrating that the site retains relatively intact archaeological contexts, such as culturally or temporally diagnostic artifacts, intact features, discrete artifact clusters denoting activity areas, or preserved organic material capable of providing data to assist addressing important research questions.

Architectural resources within the architectural APE were typically evaluated under the first three broad evaluative criteria for determining the significance.

• Under Criterion A, the building or structure must be documented to have existed and to have been importantly associated with significant historic events. Historic structures in and around MCD have the potential to represent significant historic periods from the earliest Mogollon pueblos in the third century to the Spanish haciendas of the 16^th century to the craftwork of the  good people of GloboMax and its subcontractors in the 20^th century.
• Under Criterion B, a building or structure must be associated with a person’s productive life, reflecting the time when he or she achieved significance. Properties that pre- or post-date the individual’s significant accomplishments are usually not eligible unless there are no other properties that might qualify. Historic structures in and around MCD have the potential to be associated with important historic figures from prominent conquistadors on entrada to American Indians and American Indian fighters to the ribbon-cutting dignitaries and emigrant German scientists from the heyday of the MCD production lines.
• Under Criterion C, properties are eligible for the NRHP if they are significant for their physical design or construction, including such elements as architecture, landscape architecture, engineering, and artwork. To qualify under this Criterion, a property must embody the distinctive characteristics of a type, period, or method of construction. The built environment at MCD may have the masterwork from the roughhewn Tudor arches of the extant historic uranium mine shafts to the to the Rustic Adobe walls of the local pastoral communities to the Desert Werkbund style of the explosives storage magazines.

Additionally, under Criterion C, properties are eligible for the NRHP as a distinguishable entity with individual component that may or may not be individually distinct. Thus a “district” may be composed of a variety of resources that derive meaning from constituting a unified entity. Its varied resources are consequently interrelated, conveying a visual sense of the overall historic environment or arrangement of historically or functionally related properties. At MCD, arguments can be made, and have, that the 65-year old facility, itself—with its significant contribution to winning the Cold War (A), through the efforts of an endless parade of the most-important scientists, engineers, and politicians of their day (B) within a facility that was and is, the pique of Bauhaus severity and efficiency (C) — meets the requirements of an eligible NRHP district.

It has been determined not to (cf. Foss 2001).

[1] Foss, Gene 2001. Mountweazel Chemical Depot Cultural Resources Management Plan. Prepared for the GloboMax, Inc., Richmond, Virginia, under contract with US Army Corps of Engineers, El Paso District. Third Square Consulting, LLC., Philadelphia.

[2] Savage, Beth L., and Sarah Dillard Pope. 1998. National Register Bulletin: How to Apply the National Register Criteria for Evaluation. United States Department of the Interior, National Park Service, Washington, DC.

[3] Glassow, Michael. 1977. Issues in Evaluating the Significance of Archaeological Resources. American Antiquity 42:413-420.

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