Underwater Cultural Heritage: Challenges to the Office of Coast Survey

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1 Underwater Cultural Heritage: Challenges to the Office of Coast Survey John Brent Macek, B.A. National Ocean and Atmospheric Administration, Marine Chart Division, Quality Assurance, Plans and Standards Branch, Silver Spring, MD The topic of this paper is challenges. Specifically, this paper is about the challenges the cartographers and hydrographers at NOAA's Office of Coast Survey (OCS) must confront when tasked with surveying and charting the collection of objects known in the parlance of today s archaeologists as underwater cultural heritage (UCH). These challenges are fairly new to personnel at OCS. In the past, wrecks and other features where charted (or not charted) on NOAA nautical charts based solely on the principles of the impact that the feature had on navigation, with little to no thought given to the historical or cultural significance of that feature. This thought process has evolved, as an awareness of the critical importance of UCH and OCS responsibilities to protect it, is changing that point of view. New policies are being implemented at OCS, policies designed to aid those who are tasked with cultural heritage management. To appreciate the scope of this task, one must understand the relationship between UCH and the historical attitudes toward it. But to fully understand these historical attitudes, we first must define what constitutes cultural heritage. Just what is cultural heritage? Cultural heritage is defined as the legacy of physical artifacts and intangible attributes of a group or society that are inherited from past generations, maintained in the present and bestowed for the benefit of future generations. 1 This broad collection can be broken down into categories, ranging from the world heritage of sites important to mankind as a whole, to monumental heritage of architecture, from movable heritage found in traveling museum exhibits, to intangible heritage of endangered languages, and, of course, underwater heritage. And what is underwater cultural heritage? Given the definition of cultural heritage above, underwater cultural heritage is logically the extension of cultural heritage, the physical artifacts of human activity, into the marine environment. Or, underwater cultural heritage encompasses all traces of human existence that lie or were lying under water and have a cultural or historical character. 2 Thus, underwater cultural heritage encompasses such obvious things as shipwrecks, but it also encompasses much less obvious things, such as submerged shell middens, and other evidence of human occupation along paleo-shorelines For the UNESCO Convention on Underwater Cultural Heritage definition, see Appendix A. 1

2 Why do we want to protect it? UCH is a non-renewable resource that contains vast amounts of information about mankind s history. This information has shaped how we view our ancestors and continued study of UCH will provide us with invaluable context for who we are. UCH belongs to humanity as a whole and should not be exploited for private gain. The efforts of organized treasure salvors or more casual looting by individuals destroys the information resident within UCH, robbing the public of opportunities to learn about past peoples and events. Archaeological study of UCH relies upon examining the material in situ, 4 and using scientific principles to answer specific research questions with UCH. Also, protection of cultural heritage is the law. While the U.S. has not signed the United Nations Educational, Scientific and Cultural Organization (UNESCO) Convention for the Protection of Underwater Cultural Heritage, there are multiple Federal laws currently in place which protect cultural heritage whether it is on land or underwater 5 : Antiquities Act of 1906 National Parks Service Organic, Section 1, NPS Mission National Park Service Organic Act, Section 8, Reports on Threatened Landmarks and New Area Studies Historic Sites Act of 1935 Federal Property and Administrative Services Act of 1949 National Trust for Historic Preservation, Creation and Purpose Archaeological and Historic Preservation Act National Historic Preservation Act of 1966 Department of Transportation Act, Declaration of Purpose and Section 4(f) Mining in the National Parks Act of 1976 American Indian Religious Freedom Act Archaeological Resources Protection Act of 1979 Internal Revenue Code of 1986, Section 170(h), Qualified Conservation Contributions. Abandoned Shipwreck Act of 1987 Internal Revenue Code, Section 47, Rehabilitation Credit Native American Graves Protection and Repatriation Act Intermodal Surface Transportation Efficiency Act of 1991 (ISTEA) American Battlefield Protection Act of 1996 In addition, the following laws also pertain to U.S. Navy submerged shipwrecks and downed aircraft 6 : Antiquities Act National Historic Preservation Act of A Latin phrase meaning in the place. In archaeology, items in situ have value from being studied in their original context

3 Archaeological and Historic Preservation Act of 1974 Archaeological Resources Protection Act of 1979 Theft of Government Property Abandoned Shipwreck Act of 1987 Documents, Historical Artifacts, and Condemned or Obsolete Combat Material: Loan, Gift, or Exchange Archaeological Resources Protection Act Final Uniform Regulations Protection of Historic Properties Secretary of the Interior's Standards for Historic Preservation Projects Abandoned Shipwreck Act Guidelines National Register of Historic Places Determinations of Eligibility for Inclusion in the National Register of Historic Places Recovery of Scientific, Prehistoric, Historic, and Archaeological Data Curation of Federally-Owned and Administered Archaeological Collections Sunken Military Craft Act Given the amount of legislation passed on the subject, it is obvious that the Federal government takes an interest in protecting our heritage. And as an arm of the Federal government, OCS is responsible for upholding those laws as long as they do not interfere with its mission 7. What exactly are the challenges to OCS? The seemingly easy task of surveying an area and transferring the data to the chart becomes more complex when adding UCH into the equation. Challenges are faced by OCS staff in both the Hydrographic Surveys Division (HSD) and the Marine Chart Division (MCD). Each of these divisions has unique requirements that they must fulfill in order to accomplish their mission, and thus they have equally unique challenges that they must face when surveying and charting cultural heritage. For HSD, tasked with collecting data and providing it to the public as well as to MCD, they must address such issues as identifying authorities in the field of underwater archaeology, communicating with those authorities during the survey process, relaying recommendations on objects that constitute UCH through a Descriptive Report, and flagging any surveys with UCH to ensure that the data is handled in a secure manner by both MCD and the National Geographic Data Center (NGDC). In MCD the challenges are not as multi-layered. Being charged with providing the public with accurate nautical charts, MCD has a degree of leeway in presenting their information to the public. Thus, MCD s challenge is one of interpreting the data supplied by HSD and making the correct chart application based on that data. The amount of leeway, in the case of cultural heritage, is somewhat nebulous, and therefore one of the challenges MCD faces is in defining that amount. The cartographers in MCD are also tasked with handling the data, when it has been flagged as secure due to cultural heritage items by HSD, in a secure manner. 7 OCS has a responsibility to chart those features it deems dangerous, regardless or historical or cultural significance. 3

4 Simply stated, this myriad of challenges can be distilled down to one single question: how, on one hand, does OCS fulfill its mission of providing detailed data to the taxpayer, while on the other hand, adhering to legislation such as the National Historic Preservation Act, which addresses the need for Federal agencies to protect our nation s heritage? How is the challenge being met by OCS? The answer to this question may best be illustrated with a real-world example. The following case study is of a historic wreck, the wooden-hulled, side paddle-wheel steamship Portland, a wreck so famous in her time that the gale in which she sank was thereafter known as the Portland Gale. Located within the waters of the Gerry E. Studds Stellwagen Bank National Marine Sanctuary, the wreck came to OCS attention prior to any UCH handling instructions in either the HSD Field Procedures Manual (the basic instructions on how to conduct surveys) or the MCD Nautical Chart Manual (the instructions on how to make nautical charts). Case Study Steamship Portland The steamship Portland was lost at sea sometime on November 27, She took with her the entire compliment of passengers and crew, nearly 200 people. In the days that followed, significant quantities of the vessel s superstructure and 51 bodies washed ashore along the beaches of Cape Cod. Due to her famed luxurious accommodations, and the circumstances surrounding her disappearance, she later earned the reputation of the "Titanic of New England", and secured her position in the annals of maritime New England. Last seen passing Cape Ann in waves driven by winds gusting to 90 miles per hour, she comes to our attention once again not quite one hundred years later, in It is in that year that an underwater surveying firm reports locating her. Lacking conclusive evidence, however, the wreck goes undocumented. With no documentation provided to MCD, the wreck was not published on any NOAA nautical charts. She remains an enigma. But this is about to change. Primarily because of its importance as a habitat for marine wildlife, Congress created the Gerry E. Studds Stellwagen Bank National Marine Sanctuary (NMS) in At the mouth of Massachusetts Bay, Stellwagen Bank NMS (see figure 1) contains 638 square nautical miles of open ocean and seafloor. NOAA research expeditions confirmed the Portland s location within the sanctuary in Sanctuary regulations prohibit the disturbance or destruction of historical resources within its boundaries. The story continues to unfold in the late summer of It is in that year that the NOAA ship Thomas Jefferson ran surveys of the area as part of a project to verify a large quantity of data that had been collected in 1995 and 1996 by the U.S. Geological Survey (USGS) and the Canadian Hydrographic Survey (CHS). Upon completion of its mission, the USGS/CHS data was declared usable, and the project was sent to HSD for review. During the HSD review, a hydrographer identified a multibeam sonar anomaly as the Portland and recommended that it be charted. The Portland, valuable cultural resource that she is, unwittingly became just another non-dangerous wreck. 8 See Appendix B for a timeline of events associated with the Portland. 4

5 (Figure 1. Stellwagen Bank.) 5

6 From the project, two separate hydrographic surveys emerged which overlap in the vicinity of the Portland. For the purpose of this case study they shall be referred to as Survey 1 and Survey 2. Survey 1 arrived at MCD and on November 16, 2007 it was applied to the largest scale chart of the area. The application was then reviewed, and the data was then applied through the scales, going through six other, progressively smaller, scale charts. All applications were compiled by a single cartographer, and reviewed by a senior cartographer. The descriptive report for Survey 1 mentions, by name, the wreck of the Portland. The hydrographer's recommendations were to "chart a non-dangerous to surface navigation wreck at feature position." The cartographer followed these recommendations. Survey 2 arrived at MCD and on January 25, 2008 it was applied to the largest scale chart, by a different cartographer, and was reviewed by a different reviewer. The data was applied through the scales. All the applications were reviewed. Three wrecks were applied from this survey. None of these wrecks were the Portland. While her wreckage was located within the limits of Survey 2, the Portland was not included in the survey. What Happened? The application of Survey 1 occurred prior to the development of procedures to handle cultural heritage by OCS. In MCD's source Digital Source Registry (DREG) there is a notation under Survey 1 that states, "11/5/ WAS ON HOLD PENDING RESOLUTION OF A DISCUSSION WITH SANCTUARIES ABOUT FEATURES FOUND DURING THE SURVEY." With no procedures directing relating to UCH in place, the cartographers who applied and reviewed the Survey 1 did what they were trained to do, they followed the hydrographer's recommendations and the standard MCD policy. They charted the wreck. However, during this time there was an ongoing dialogue between MCD management, HSD management, OCS management and ONMS. The result was that the wreck would eventually be deleted from all charts. A new entry in DREG from April 11, 2008 states, "PORTLAND WRECK TO BE UNCHARTED DUE TO HISTORIC PRESERVATION. SEE ASSOCIATED SUPPORT FILE FOR DESCRIPTIVE REPORT." One further release of the data was to occur with Survey 1. It was posted to NGDC's public access site. Fortunately, between the time it was downloaded to the public access site, and the time NOAA GCOS recommended the data be relocated to the limited access site, only 300 or so downloads had occurred, and they were all within the noaa.gov domain. What lessons has OCS learned? OCS has learned much for the Portland case study. It has developed a network of contacts within NOAA's archaeological community, who have worked closely with them to help develop standard operating procedures that will help protect UCH. In addition, the NOAA archaeologists have introduced OCS staff to the various State Historic Preservation Officers (SHPO), who are responsible for UCH within state waters. 6

7 Through queries with NOAA GCOS, OCS has confirmed its mission. Dangerous wrecks and obstructions shall be charted. Protecting UCH is important, but the primary goal of OCS is to inform the mariner of dangers to navigation. In addition, OCS has confirmation that Section 304, National Historic Preservation Act of 1966 does give it the freedom to withhold site locations from the public. OCS has also learned, in regards to the unintentional release of data through the NGDC site, that an erroneous release of data does not equate to an intentional release of data into the public domain, and that data released to the public can be withdrawn. What process improvements have been made? In May 2008, HSD updated the Field Procedures Manual to include specific steps aimed at identifying UCH and handling it in a timely fashion. 9 These include consultations with SHPOs or Federal archaeologists and methods to secure surveys containing UCH from public view. Likewise, MCD has updated the Nautical Chart Manual. 10 To ensure the data is secure at MCD, each survey with UCH will carry the following disclaimer (in this instance, from our case study Survey 2): Conclusion 7/31/08--THIS DOCUMENT CONTAINS POTENTIALLY SENSITIVE HISTORIC DATA. IDENTIFICATION OF SPECIFIC FEATURES MEETING THIS CRITERIA SHOULD BE DETERMINED USING THE ASSOCIATED SUPPORT FILE (DESCRIPTIVE REPORT) AND NOTED IN THE CHARTS' HISTORIES DURING APPLICATION. PRODUCTS BRANCH CHIEFS SHOULD BE NOTIFIED AND CONSULTED PRIOR TO PUBLIC RELEASE OF ANY CHART CONTAINING SUCH DATA. DATA DETERMINED TO CONTAIN ITEMS OF HISTORIC SIGNIFICANCE MAY BE EXEMPT FROM FOIA REQUESTS; CONSULT CHIEF, NDB. This paper is about challenges. It is about how OCS, when faced with a choice, embraced its historic preservation mandates. This paper is about the challenges we, as inhabitants of this Earth, have in accepting our stewardship of our common past, our history, and the record of our predecessors, as seen through the lens provided by the protection of ages past, during which few if any human eyes were able to penetrate the deep waters of the Earth, and where, until the invention of the aqualung, they rested, for the most part unseen and undisturbed. APPENDIX A - UNESCO Convention on UCH (Note, as stated above, the US has not ratified the UNESCO Convention on UCH. The author of this paper believes, however, that the UN definitions have merit and are worthy of inclusion in this report. Also note, in section 1. (a) below, where the UN considers 100 years as the cutoff, the US is in favor of 50 years.) 9 See Appendix C for excerpts from the Field Procedures Manual. 10 See Appendix D for the text of the proposed addition to the Nautical Chart Manual. 7

8 Article 1 Definitions For the purposes of this Convention: 1. (a) Underwater cultural heritage means all traces of human existence having a cultural, historical or archaeological character which have been partially or totally under water, periodically or continuously, for at least 100 years such as: (i) sites, structures, buildings, artefacts and human remains, together with their archaeological and natural context; (ii) vessels, aircraft, other vehicles or any part thereof, their cargo or other contents, together with their archaeological and natural context; and (iii) objects of prehistoric character. (b) Pipelines and cables placed on the seabed shall not be considered as underwater cultural heritage. (c) Installations other than pipelines and cables, placed on the seabed and still in use, shall not be considered as underwater cultural heritage. APPENDIX B Portland Timeline SS Portland constructed in Maine by the New England Shipbuilding Company. The Portland was 291 feet in length, with a breadth of 68 feet. Capable of handling close to 800 passengers, she was one of New England's largest steamships, with a reputation for luxury. 26 November SS Portland leaves Boston for Portland, Maine. A gale moving up the East coast catches her at sea, sinking her with a loss of 192 souls, a loss so tragic, the gale was named "The Portland Gale" and the wreck known as the "Titanic of New England." National Marine Sanctuary Program was established by Title III of the Marine Protection, Research and Sanctuaries Act Wreck reported discovered by American Underwater Search and Survey. 4 November President Bush signs law which authorizes Gerry E. Studds Stellwagen Bank National Marine Sanctuary. 29 March 1995 to 4 December U.S. Geological Survey (USGS) and Canadian Hydrographic Survey conduct surveys in the vicinity of the wreck site. 8

9 Late July and early August Stellwagen Bank National Marine Sanctuary and the National Undersea Research Center at the University of Connecticut image the wreck with side scan sonar and document the wreck with a remotely operated vehicle. 29 August NOAA officially confirms that the Portland lies within the Stellwagen Bank NMS. September In an effort to confirm outside source data from USGS and CHS, and to thereby allow that data to be used by the Marine Chart Division for charts updates, NOAA Ship Thomas Jefferson collects data in the area. 17 February Steamship Portland listed on the National Register of Historic Places. March Two survey descriptive reports, each containing data on the Portland, are approved for use by MCD. 16 November 2007 First survey applied to largest scale chart by MCD cartographer. The wreck of the Portland was added to the chart. 25 January 2008 Second survey applied to largest scale chart by different MCD cartographer. Portland was removed from the chart. May 2008 HSD incorporates UCH protocols into their Field Procedures Manual MCD drafts non-dangerous wreck policy for inclusion in the Nautical Chart Manual. APPENDIX C Pertinent Selections from the April 2009 HSD Field Procedures Manual Cultural or Historic Submerged Features HSD Operations Branch will contact the State Historic Preservation Officer (SHPO) and Historical/Archaeological contact at the NOAA National Marine Sanctuaries Program (NMSP) office during preparation of Project Instructions to request information on any historically significant man-made features on the seabed within the survey area. Any information provided by these groups will be included in the Project Instructions. The Project Instructions will also include the contact information of the SHPO and NMSP for use in the event of discovery of a potentially historically significant man-made feature, in accordance with Special Wreck Investigations If a hydrographic field unit discovers a potentially significant historic wreck site, or conducts a special wreck investigation through a contract from another NOAA program or a request from a NOAA Navigation Manager, the field unit should make an effort to ensonify the wreck site and associated debris field with each type of sonar system that is readily available. When conducting side scan sonar operations, run parallel tracks on either side of the wreck, so that both sides are 9

10 imaged, as well as two additional tracks orthogonal to the site. The imagery and bathymetry data will provide clues to the wreck s status and identity, identify any obstructions, and provide researchers with an adequate baseline assessment with which to compare future surveys DToN Submission (see section of HSSD) 2. If a DTON report includes a potentially historically-significant wreck, the field unit shall provide a courtesy copy of the report sections pertaining to that specific feature to the corresponding NOAA Navigation Manager and State Historic Preservation Officer. If a potentially historically-significant wreck is identified outside of state waters, notify the current Sanctuaries Historical/Archaeological contact Cultural or Historical Submerged Features In the course of acquiring or processing hydrographic data, features on the seafloor may be discovered which are of potential cultural or historical significance. These include wrecks of ships or aircraft, the recognizable debris from wrecks, or other items which may appear anthropogenic in origin and have some associated cultural or historical significance. Chiefs-of-Party must always promptly assess the discovery of any features for significance to local surface navigation and report these accordingly. Any feature determined to be a Danger to Navigation shall be immediately reported through the standard DTON reporting process (see Section 4.4.4). It is Marine Chart Division (MCD) policy that all features recommended for charting by the Chief-of-Party be applied to the appropriate nautical charts. Chiefs-of-Party must continue to recommend for charting all features determined to be significant to surface navigation, as well as features determined to be significant or hazardous to other marine chart users engaged in activities such as fishing or trawling. This includes features which may have potential cultural or historical significance. This policy is unchanged and in accordance with the MCD Nautical Charting Manual. All features which appear to be of cultural or historical significance, and appear anthropogenic in origin, do require special consideration during the hydrographic surveying process. Data and information from these features must always be protected and may only be released in accordance with OCS policies and procedures. Unless specified by the Project Instructions (or other written instructions from OCS): 1. Do not attempt to determine the cultural or historic significance of any features. And, do not expend any operational effort toward identification beyond what is necessary for assessment as a Danger to Navigation. 2. Do not speculate about a known or newly discovered feature s potential cultural or historical significance, either publicly or in writing. 10

11 3. Do not identify by name or otherwise associate with a name, any cultural or historical feature in the Descriptive Report (DR) or any part of the survey s data. 4. DO include an image, SSS or bathymetry, of the feature in the Pydro feature report for recognition by a historian or preservation official. OCS, as a unit of a federal agency, has responsibilities under Section 106 of the National Historic Preservation Act (NHPA, 16 U.S.C. 470 et seq.) to take into account the effects of its undertakings on historic properties. The process for federal agencies in complying with the NHPA is laid out in 36 C.F.R. Part 800, which prescribes consultation with the State Historic Preservation Officer (SHPO). 1. OCS will consult with the NOAA National Marine Sanctuaries Program (NMSP) Marine Historian where hydrographic projects are located within Federal waters, including National Marine Sanctuary boundaries. 2. OCS will also consult with the appropriate SHPO where hydrographic projects are located in state waters. OCS consultations for hydrographic projects provide information about planned survey activities, and about survey outcomes. A pre- or post-survey consult will allow NMSP or a SHPO at least 30 days to respond. In general, NOAA field units are not required to submit any data to NMSP or a SHPO. All consultations will be conducted by OCS Pre-survey Consult A pre-survey consult will be initiated during the project planning process by OCS HSD Operations Branch (or NSD Navigation Response Branch). Any responses or special handling that may be required of a NOAA field unit will be provided in the Project Instructions. A pre-survey consult with NMSP or a SHPO may be anticipated to result in one of three general outcomes: 1. No Response HSD Operations branch will note this and the project instructions will not require any special data handling. 2. Informational response Information about known or reported features of cultural or historical significance may be received by OCS following the pre-survey consult period. An informational response means information from NMSP or a SHPO received by OCS is provided without any restriction for public release. This information will be included with the Project Instructions. The project instructions will not require any special data handling. 11

12 3. Actionable response Specific information received following the NMSP or SHPO presurvey consult period may prevent the public release of all or part of the survey data or products. The specific information received following a pre-survey consult period will be evaluated by OCS HSD Operations Branch, and clear instructions for data handling will be provided Post-survey Consult A post-survey consult will be initiated by HSD s Atlantic Hydrographic Branch (AHB) or Pacific Hydrographic Branch (PHB). Immediately upon receiving a data submission, AHB or PHB will provide a copy of survey s composite Descriptive Report (DR) that includes the written DR, the feature report, and the Danger to Navigation report to the NMSP and/or SHPO specified in the Project Instructions, and request a direct response within 30 days.ahb or PHB will provide courtesy copies of the DR Transmittal Letter to: 1. Chief, HSD or NSD 2. Chief, HSD Operations Branch or NSD Navigation Response Branch 3. Regional Navigation Manager (as assigned in the Project Instructions) The composite DR may be transmitted by or on letterhead, with a message in the following form: The National Oceanic and Atmospheric Administration s Office of Coast Survey (OCS) previously contacted you regarding hydrographic surveys in [location] on or about [dates]. A Descriptive Report for one of those surveys is attached for your information. Please provide any comments regarding this survey within 30 days with reference to survey [insert registry number] to [insert name] Chief, [Atlantic or Pacific] Hydrographic Branch [insert telephone, , and mailing address]. If we have not received a response in 30 days, we will assume that the survey data may be made publicly available. A post-survey consult with NMSP or a SHPO may be anticipated to result in one of three general outcomes: 1. No Response All survey data and products will be made publically available through NGDC following an affirmative Survey Acceptance and Review (SAR) by the either the Atlantic or Pacific Hydrographic Branch. 2. Informational response An informational response means information from NMSP or a SHPO received by OCS is provided without any restriction for public release. If received following a post-survey consult, this information will be inserted into the survey s DR as supplemental correspondence. All survey data and products will be made publically available through NGDC following an affirmative SAR by the assigned OCS HSD Hydrographic Branch. 12

13 3. Actionable response Specific information received following a post-survey consult will be evaluated by the assigned OCS HSD Hydrographic Branch. This evaluation may result in all or some of the survey data and products to be not made publically available through NGDC following an affirmative Survey Acceptance and Review (SAR) by the assigned OCS HSD Hydrographic Branch. The policies and procedures described in this section should never cause a delay in the completion of a hydrographic survey and the immediate notification of potential Dangers to Navigation. Any questions regarding cultural or historical submerged features should be promptly directed to the Chief, HSD Operations Branch. APPENDIX D UCH Addition to the MCD Nautical Chart Manual (DRAFT) Nondangerous Wrecks of Cultural or Historical Value Previously uncharted nondangerous sunken wrecks which have been identified by authoritative sources as having historical value or containing cultural resources present a unique situation to NOAA cartographers. Due to the archaeologically sensitive conditions of these wrecks, or the vulnerability of artifacts contained therein, they may be protected under provisions found in section 106 of the National Historic Preservation Act (NHPA, 16 U.S.C. 470 et seq.) and 33 CFR Part 800. NOAA hydrographic surveys are the most usual source document to contain wreck data of this nature. HSD has implemented review procedures for wrecks. For a detailed explanation of the procedures, please consult their Field Procedures Manual, Section 4.4.5, Cultural or Historical Submerged Features. NDB, upon receipt of a survey flagged as containing restricted data, shall add an explanatory statement to that survey s entry in DREG. This statement informs those who are querying the system that the survey in question requires special handling due to the potentially sensitive historic data contained therein. If by chance a source document detailing a wreck of historic or cultural value arrives in NDB from other a source supplier other than HSD, NDB will seek instructions from QAPSB. Production branch cartographers, upon receipt of a survey containing historic or culturally significant wrecks, shall review the recommendations stated in the Descriptive Report. Generally, MCD cartographers shall follow these recommendations -- the wreck may be charted as a sounding without the usual label, or if the wreck is sufficiently deep, and the least depth of the wreck not significantly shoaler than its surroundings, it may remain uncharted. The following shall be taken into account when applying these wrecks. When the wreck in question has been previously charted or has been published in some way, the wreck shall remain charted regardless of its historic or cultural status. Also, considerations for choosing which of the above actions to use may include data quality, the availability of least depth data, surrounding 13

14 depths and charted features, size of the wreck and likely vessel traffic, or recommendations from the acquisition platform, HSD offices, or NHPA authorities. Charted nondangerous sunken wrecks identified as having historical value or containing significant cultural resources shall remain charted, except in instances where the wreck was labeled with a qualifier such as Position Approximate, Position Doubtful or Existence Doubtful. When a cartographer is directed to move such a wreck through a hydrographic survey Descriptive Report, it may be deleted instead. The recommended charting action shall be presented to QAPSB for approval. Upon QA approval, the Office of General Counsel for Oceanic Services (GCOS) is notified, and final charting disposition of the wreck is forwarded to ONMS archaeologists. AKNOWLEDGEMENTS The author would like to thank the following for their insight and contributions: Mike Brown (Deputy Chief, HSD), Bruce Terrell (Archaeologist, NMS), Frank Cantelas (Archaeologist, Office of Ocean Exploration and Research), and Matthew Lawrence (Archaeologist, Stellwagen Bank NMS). 14