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How to Write Off Traditional Cultural Properties: the Gladesmen Report

by Tom King

Note: This article was first posted as an entry on the weblog Tom King’s CRM Plus on July 8, 2014.

Credit: National Park Service
Historic image of Gladesmen using Dune Buggies in the Everglades. Credit: NPS

I recently reviewed a report prepared for the U.S. Army Corps of Engineers by New South Associates, entitled You Just Can’t Live Without it: Ethnographic Study and Evaluation of Traditional Cultural Properties of the Modern Gladesmen Culture. I hoped that the report would describe a good traditional cultural properties (TCP) study that focused on places of concern to groups of people other than Native Americans or Native Hawai’ians.  Such studies are rare; although National Register Bulletin 38 on the identification and documentation of TCPs makes it clear that diverse groups of people can value such places, there is a tendency to limit the context in which the TCP concept is applied.

I was deeply disappointed by the Gladesmen report, and feel obligated to say why.

Who Are the Gladesmen?

The Gladesmen are mostly Euro-american (especially Scots-Irish) rural residents of Florida’s Everglades. They’re broadly characterized as a subdivision of the American South’s “Cracker” culture of self-sufficient rural subsistence farming, fishing, hunting, gathering and very small-scale industry. Gladesmen comprise the families that have for generations lived in and around the Everglades, more or less making their livings by hunting alligators and other game, fishing, plume gathering, moonshining, and small-scale agriculture (See Simmons & Ogden 2010, Ogden 2011).

The Study

The ethnographic study of Gladesmen TCPs was commissioned by the Corps of Engineers in connection with a Master Recreation Plan being developed as part of the Comprehensive Everglades Restoration Plan (CERP). Apparently the possibility of National Register eligible TCPs was raised during public meetings on the CERP, and the Corps contracted with New South to determine whether any existed. New South undertook a program of background research and ethnographic interviews to reach conclusions about whether any Gladesmen TCPs were present. Having identified thirteen candidate sites, they went through them and concluded that only two were in fact TCPs eligible for the Register – though they hedge their bets by calling for some to be analyzed further if some future action threatens them.


So why did I find the Gladesmen study so disappointing? Let me try to explain:

What Was Evaluated?

It is not clear to me how the thirteen sites studied were selected, or indeed why specific sites were selected at all. Comments on the draft report by Palm Beach County Archaeologist Christian Davenport identified a number of other seemingly relevant locations that should have been considered, as well as additional informants. New South breezily dismisses Davenport’s comments as “outside the scope of this preliminary study.” Exactly what the study is “preliminary” to is unclear. What particularly puzzles me is why the authors felt compelled to focus on specific locations. One clear feature of Gladesmen culture is the mobility of its participants; they traveled and still travel all over the Glades. Why wasn’t the overall landscape evaluated? By focusing on specific locations (albeit including some linear properties like roads and streams), it seems to me that the study atomizes the environment that Gladesmen value, making it easy to devalue its specific parts.

Which is what the report proceeds to do.

(Mis)understanding TCPs

Although the authors of the report have apparently at least looked at National Register Bulletin 38, there is little evidence that they’ve tried very hard to understand it. Instead, it appears that they have cherry-picked concepts, and in some cases made them up, to support their conclusions.

In Chapter II, for example, on page 10, we are told that:

“(a)n identified historic property usually must be 50 years old to be considered a TCP.”

This implies that a place must first be “identified” as an historic property and then considered for TCP status if it is 50 years old. This of course stands the evaluation process on its head. A place is a TCP if it is regarded by people as important in sustaining their traditional cultural values; having recognized that it has this value, then one applies the National Register criteria and criteria considerations to see if it is Register-eligible. And of course, “50 years old” is a deeply simplistic gloss on the actual “Fifty-year rule” laid out in the Register’s criteria considerations.

The same paragraph characterizes the “integrity” of a TCP as referring to “a sustained, integral relationship to traditional cultural or beliefs” and a condition that is “sufficient to convey significance.” This may be a clumsy gloss on the Bulletin’s discussion of a TCP’s two kinds of integrity – integrity of association and integrity of condition – but if so it is a clumsy one indeed. The reference to a “sustained…relationship,” for example, is made up out of whole cloth, but neatly sets the authors up for their subsequent dismissal of eleven of the sites. The allusion to “convey(ing) significance” – another notion not derived from Bulletin 38 – helps the authors dismiss the significance of the sites based on their own perceptions (i.e. the perceptions of those to whom the sites do or do not convey things) – never mind those of the Gladesmen.

“Continuity” Claptrap

On the same page, we are told that:

“the most critical element in whether or not a property represents a TCP is its role in long term and continuous maintenance of a given culture” (emphasis added).

“Continuity” is a notion that has no basis whatever in Bulletin 38. The Bulletin succinctly says, on page 18, that “(t)he fact that a property may have gone unused for a lengthy period of time … does not make the property ineligible for the (National) Register.” Let alone ineligible to be a TCP. Continuity as a “critical element” – or indeed any kind of element – is something that has been made up to justify dismissing the significance of places from whose use people have been lately excluded. As many Indian tribes can testify, the fact that one has been made unable to maintain the traditional use of a place – through relocation, forcible exclusion, genocide, or other historical circumstance – by no means renders the place insignificant. Yet the authors of the Gladesmen study elevate their whole-cloth invention to the status of “most critical element” in determining whether a place is a TCP. They go on to explain:

“Because continuity in use plays such an important role in defining TCPs, changes in a property’s use or association through time can change the eligibility status of that property. If extensive changes or discontinuity in use occur through time, a site that has integrity may still be eligible for recording as a historic property…. But it would not maintain the necessary level of significance for recording as a TCP.”

This “important role” that the authors assign to “continuity in use” forms the basis for the rest of the study’s dismissive “analysis.” But it is a status assigned by the authors based on no stated authority, and it is directly inconsistent with the plain language of Bulletin 38.

Inflating Misstatements

Perhaps following the maxim that if you tell a big enough lie often enough it becomes the truth, the authors repeatedly reframe and elaborate on their misstatements. On page 103, Chapter VII, for instance, as they set about “identifying Gladesmen TCPs,” they say that:

“(i)t is important to restate here that many properties associated with Gladesmen Culture may warrant recording as ‘historic properties’… but not all of these will meet the criteria for recording them (sic) as TCPs. The NRHP guidelines distinguish a TCP as a property that not only meets existing criteria as a historic property … but is also one that represents a continuing association with the (Gladesmen) culture whose primary importance is its role in maintaining cultural identity and practice.”

So now a Gladesmen TCP must not only be eligible for the Register and “represent a continuing association” (whatever that means), but must have “maintaining cultural identity and practice” as its “primary importance.” How in the world is anyone supposed to ascertain whether a place meets all these new and inventive standards? Who, for instance, is supposed to decide whether a place’s role in “maintaining cultural identify and practice” is “primary?” As opposed to secondary, tertiary, or quaternary?

Note, too, the reference to “NRHP guidelines.” What guidelines are these? Certainly not Bulletin 38. The bibliography also refers to National Register Bulletin 15; if that bulletin provides advice upon which the authors base their assumptions, it would have been helpful for them to have provided a specific citation. But no, we are simply assured that New South’s case is grounded on “NRHP guidelines.”

The mysterious “guidelines” are referred to again on page 124, where we are told that:

“NRHP guidelines distinguish a TCP as a property that not only meets existing (as opposed, one imagines, to nonexistent) criteria as a historic property … but is also one that represents a continuing association whose primary importance is its role in maintaining cultural identity and practice.”

The authors go on to warn us that:

“(p)roperties will not meet TCP criteria if the continuity of their use has significantly changed over time, if they do not retain sufficient integrity, and, most importantly, if they do not contribute to maintaining Gladesmen Culture as a whole.”

Again, as far as I can tell, New South has made up these standards on the spot, out of thin air.

Who Sez?

But let’s assume just for a moment that there really is some National Register guideline that makes all those preposterous statements. How would one operationalize it? Notably, who is to determine whether the use of a place has “significantly changed?” Or whether it retains “sufficient” integrity? “Sufficient” relative to what? And who decides whether a place contributes to maintaining Gladesmen Culture, particularly “as a whole?”

New South never tells us, but it becomes abundantly clear that the invariable answer to the question of “who says” is: you guessed it, New South. Despite Bulletin 38’s repeated calls for evaluating the significance and integrity of places with reference to the views and beliefs of those who value them, the Gladesmen report authors never miss a beat in skipping from describing properties to evaluating them, with never a reference that I could find to the views of Gladesmen themselves. Chapter IX presents the study’s “results,” which the authors unblushingly identify on page 131 as “New South Associates’ findings.”

The Bottom Line

And what are these findings? That eleven of the thirteen properties described just haven’t been “demonstrated” (by whom?) to be TCPs, or lack “sufficient” information to permit evaluation. Two properties – a duck camp and the site of an airboat association (already identified by the Corps as eligible for the Register) are identified as honest-to-gosh TCPs.

Here’s one typical example of how New South writes off possible TCPs. It happens to be Duck Camp #2, but it could be any of the others.

“Oral history suggests that this campsite has been in use by modern Gladesmen since the late 1950s, as well as during earlier times. However, use of the camp by regional Gladesmen changed with its ownership by Governor Kirk, and the current camp cabin was not built until the 1970s. While the location has a known Gladesmen association that qualifies it as an historic property, New South does not recommend Duck Camp #2 to the NRHP as a TCP.”

Just like that. The site is associated through oral history with Gladesmen use since sometime before the late 1950s but New South in its Olympian wisdom “does not recommend” it as a TCP.

Why? Well, we’re not told, but maybe it has something to do with that 1970s house. But we’re talking about a site here, are we not? Which in NRHP lingo means a piece of real property regardless of any buildings or structures on it. Or maybe it’s something in the oral history – maybe people say “naah, we don’t care about that place.” If that’s what they say, it might have been nice of the authors to mention it. But New South apparently feels no need to justify its judgments with data; it is sufficient that it “does not recommend” the place.

The statement does go on:

“The camp appears to be typical of a mid-century Everglades backcountry camp that is used by an individual or a small number of people.”

Is this some sort of implicit standard? Must the camp be atypical? Used by more than a “small” (sic) number of people? We are not told. We are told, however – in another unsubstantiated statement of imperious opinion, that:

“Duck Camp #2 does not exhibit a continuing association with modern Gladesmen Culture as a whole and therefore is not recommended as a TCP.”

Excuse me? Have the authors not just asserted that Duck Camp #2 has a Gladesmen association extending back to before the 1950s? Is this somehow not “continuing?” Did Governor Kirk’s ownership sever that relationship? If so, how? Or is the failure somehow to reflect association with Gladesman culture “as a whole” what dooms the camp? The (somewhat) detailed data on Duck Camp #2 found on pages 156-60 does not clarify.

The rest of the evaluations are similar. Each briefly summarizes descriptive data on the site and then states a conclusion, substantiated by nothing other than New South’s self-assumed authority


What are we to make of this report? It’s certainly not an example I intend to cite – except perhaps as an indicator of how not to evaluate TCPs. But why in the world is it as it is? Does it give the Corps of Engineers anything it can really use in designing and carrying out the CERP? Does it give Gladesmen any help in preserving these places that, as the report’s title implies, they “just can’t live without?” Did preparing it accomplish anything other than to support some New South employees for a while and bring New South some overhead?

I don’t know, but I do know that the report butchers the very notion of traditional cultural properties, wildly misinterpreting Bulletin 38. I suspect, too, that it has given the Corps an ostensibly authoritative basis for writing off the traditional cultural significance of Gladesmen sites – and perhaps more importantly, of Gladesmen cultural landscapes – as it moves forward with implementing the CERP.


Ogden, Laura A.
2011 Swamplife: People, Gators, and Mangroves Entangled in the Everglades. Minneapolis, University of Minnesota Press

Parker, Patricia L. and Thomas F. King

1990 Guidelines for the Evaluation and Documentation of Traditional Cultural Properties. National Register Bulletin 38. Washington DC, National Register of Historic Places, National Park Service.

Simmons, Glenn, and Laura Ogden
2010 Gladesmen: Gator Hunters, Moonshiners, and Skiffers. Gainesville, University Press of Florida.

Addendum: After this review appeared on my weblog, I received a note from a source that I regard as entirely reliable, advising me that the Gladesmen report had been modified significantly after its author turned it in, without her knowledge or consent, essentially reversing her conclusions. If this is true — and I have no reason to think it is not, it absolves her of responsibility for the report, but does nothing to resolve the larger issues. Sadly, I think the kind of thing the published Gladesmen report represents is pretty typical of standard “professional” practice these days in cultural resource management and environmental impact assessment.

Thomas F. (Tom) King is the author, co-author, or editor of ten books on aspects of cultural heritage, and the co-author of National Register Bulletin 38 on the identification and documentation of traditional cultural places. He is a consultant based in Silver Spring, Maryland, and can be contacted at tomking106 at gmail.com.