2015 Preface
After presenting this paper in Beijing in 2011, and seeing it handsomely published in 2013, I posted it on Academia.edu, where it's had a remarkably broad readership -- accessed by unsuspecting potential readers in countries ranging from Azerbaijan to Zimbabwe. I'm gratified by such widespread interest, but see no evidence that the paper's had any impact on practice or policy. Hope springing eternal, I thought I'd share it with readers of this blog as well.
Presented
September, 2011
(Published
in Cultural Heritage Research Volume
2 by the Chinese Academy of Social Sciences [CASS] (Proceedings of the World
Archaeological Congress 2011 Beijing
Intercongress
on Heritage Management in Asia), Science Press Beijing 2013.
Introduction: Environmental Impact Assessment (EIA)
It
is no secret that development projects of all kinds – housing and agricultural
schemes, dams, highways, rail lines – do injury to the environment. This has nothing to do with whether these
projects are justified on economic, social, and even environmental grounds;
they often if not always are. One has to
destroy in order to build; it is in the nature of the enterprise. As long as we want economic growth,
industrialization, the ability to defend our nations and provide sustenance and
comfort to our people, we must do things that injure the environment.
To
control such injury, since the early 1970s virtually every national government,
and such nongovernmental organizations (NGOs) as the World Bank, have put in
place procedures for “environmental impact assessment” (EIA) (c.f. Eccleston
2011).
The
reason for EIA procedures is summed up in the Confucian maxim roughly
translated as: “If you do not consider the future, you will be in trouble when
it comes near.” If we do not consider
what harm our proposed projects may do – however beneficial they may be – we
will be in trouble in the future, when that harm materializes. Or perhaps we will not be in trouble,
but others will be – those directly affected, and perhaps our children and
grandchildren. Accordingly, governments and funding bodies have
realized that they should consider what damage a project is likely to do before
they decide whether and how to go forward with it.
This
is not to say that damaging projects should not be undertaken; often they must
be. It is only to say that if we know
what damage is likely to occur, perhaps we can do things to keep it from
happening, to reduce its severity, or make up for the damage somehow. And
sometimes, yes, we will realize that the impacts are so severe that the project
is not worth pursuing.
EIA and Cultural Heritage
Of
course, among the aspects of the environment that can be damaged by modern
activities is what we call “cultural heritage.”
Readers of this book will probably agree readily that potential impacts
on cultural heritage should be closely examined in the course of EIA, that
alternatives to damaging activities should be considered, that steps should be
taken to avoid or reduce the damage. In
general terms, the world’s people seem to agree; most communities react badly
to actions they perceive as damaging their cultural heritage, and most
governmental guidelines for EIA indicate that impacts on cultural heritage
(defined in various ways) should be considered in planning.
Often,
however, when EIA is performed on proposed projects, not much attention is paid
to cultural heritage, or at least not to anything but the most obvious,
well-documented, officially –recognized, physical aspects of such
heritage. EIA analysts merely list historic
monuments officially designated by government, or places inscribed in the World
Heritage List. They often assume, and assert,
that these will be taken care of by following whatever standard procedures
government has put in place. Often the
people and communities whose heritage is most at risk are poorly engaged in the
process of EIA, their heritage values are poorly considered in planning, and
the steps taken to mitigate impacts – decided on by project proponents and
governments, if indeed any such steps are taken – are inadequate or even
irrelevant to the people whose heritage is affected.
In
my experience there are several common, interrelated reasons that cultural
heritage is not addressed well in EIA.
In this paper I want to outline some of these problems, discuss a case
study from my own country that exemplifies some of them, and suggest steps that
we might take to solve them.
Case Study: The Luiseño Ancestral Origin
Landscape and Liberty Quarry
The
American Indian tribe long known by their Spanish colonial name, Luiseño,
have
occupied a modest-sized territory in coastal southern California, U.S.A., since
time immemorial. Many Luiseño people now
live on a reservation adjacent to the city of Temecula in Riverside County. The city’s name is derived from ‘éxva Teméeku, an important place in a larger (about 4450 hectares)
landscape in which many of the origin traditions of the Luiseño played out –
the creation of the first people (Káamalam),
the death (the first ever) and cremation of the hero Wuyóot, and the transformation of the Káamalam into the rock outcrops that even today dot the hills. To the Luiseño, this landscape is of supreme
historical, cultural, and spiritual significance.
It
is, however, at this writing not listed on any official roster of cultural
heritage – not on the World Heritage List, not on the U.S. National Register of
Historic Places, not on California’s own register of historic places. Only
within the last year did the Tribe place it on the list of “sacred sites”
maintained by the state’s Native American Heritage Commission.
There
are excellent reasons for all this – besides the fact that getting a place
listed is costly and time consuming. For
the last 500 years the federal and state governments (and their colonial
predecessors) have carried out military actions against North America’s tribes,
taken their land, placed them on reservations and until quite recently insisted
that they give up their traditional religions and lifeways. The Luiseños’ non-indigenous neighbors have
at best regarded their traditions as quaint.
People have dug up their ancestors, defaced their rock art, and desecrated
their sacred places. Under such
circumstances, why would any sensible indigenous group volunteer to register
its traditional places on a government list?
Tribes simply have no reason to trust the government, and every reason
not to share sensitive information with its representatives. But absence from lists says nothing about the
significance of a place to the Luiseño; they know what it is, and why it
is important.
California-based
Granite Construction has proposed to build a large aggregate quarry within the
Luiseños’ valued landscape. The story of
the Luiseño effort to get government to respect their cultural heritage
concerns about this proposal illustrates the problems I want to explore with
cultural heritage in EIA. I stress,
however, that – sadly – this story is not unique or even unusual; similar
conflicts play out the world over, and are poorly addressed in EIA and
government planning.
Problem One: What is Cultural Heritage?
Different
people conceptualize cultural heritage in different ways, and this complicates
its consideration in EIA. In my own
experience in the United States and the Pacific islands, and in reading the
international literature, I find that ccultural heritage is variously defined to include – or
exclude (among other things)
- Monuments,
archaeological sites, and cultural landmarks;
- Traditional
ways of using the land and its resources;
- Culturally
important plants and animals, water sources, and landscapes;
- Culturally
valued soundscapes and viewsheds;
- Stories,
songs, philosophy and language;
- Traditional
forms of subsistence;
- Traditional
ways of life;
- Religious,
spiritual and other cultural practices;
- Objects
of material culture (artifacts, antiquities);
- Art
forms, and
- Books,
manuscripts, and other literary products.
Each
of us academic and professional practitioners specializes in one or more of the
above types of heritage. Most of us at
the Intercongress that produced this volume, in fact, specialize in a
subdivision of the first type shown on my list: archaeological sites, which may also be thought of as historic places and/or landmarks. We understandably do not take responsibility
for other kinds of cultural expression, other parts of the cultural
environment. But here is the problem: we
also often fail to inform those who plan and carry out EIA that we are not
authorities on all aspects of cultural heritage. And we fail to recommend that they consult
those who are authorities on cultural things other than archaeology,
notably including the local people themselves.
We call ourselves things – like “cultural heritage specialist” and
“cultural resource manager” – that obfuscate what we actually know and can
advise about. This results in
assessments in which “cultural heritage” is equated entirely with monuments or
archaeology, while the other elements of culture are given little consideration
or even ignored entirely. These aspects
of the cultural environment may be just as worthy of protection as – even more
worthy than – archaeological sites, and they may be much more the concern of
local people, but if they are considered in EIA at all, it is often in spite of
us rather than with our support.
Consider,
for example, animals or plants that figure in a community’s self-identity. I have been involved with the Okinawa dugong,
significant in the beliefs of traditional Okinawans; the dugongs’ habitat is
threatened by the proposed construction of a U.S. military base. To those performing EIA on the project, the
dugongs were animals of professional concern to biologists and natural resource
managers. To the local people, however,
the dugong is literally a sacred animal.
Had it not been for litigation by Okinawan, Japanese, and U.S.
environmental groups, and near-violent demonstrations on the project site by
Okinawans, the cultural value of dugongs and their habitat to the people of
Okinawa would have been ignored in the military’s EIA and its decision making
about the project (c.f. King 2006).
In
the case of the Luiseño Ancestral Origin Landscape, the Riverside County Planning
Department performed EIA on the proposed Liberty Quarry, under the authority of
the California Environmental Quality Act (CEQA). The County Planning staff examined the Native
American Heritage Commission’s list of “sacred sites” and found that none were
listed within the project boundaries.
They also had an archaeological survey done that revealed no
archaeological sites. When challenged by
the Pechanga Band of Luiseño Indians for failing to consider the Origin
Landscape, they said that CEQA did not permit them to consider any place that
archaeologists did not regard as significant.
Oddly, at the same time they contracted with an ethnographer to study
the ethnohistorical record of the area; he advised that it probably represented
a cultural landscape important to the Luiseño, and recommended more study.
Rather
than undertaking such study – which would inevitably have involved face-to-face
consultation with the Luiseño – the County staff and the project proponent
interpreted the ethnographer’s report to mean that no culturally significant
places were present. Their rationale for
this interpretation, insofar as it can be found in their documentation, seems
to have been that the ethnographer had not identified specific archaeologically
observable cultural places within the proposed quarry site. The notion that the landscape containing
the quarry site could be culturally important, regardless of its archaeological
visibility, seems to have escaped them.
Problem Two: The Limitations of Traditional Thinking About
Cultural Heritage
As
in many other cases, part of the conflict over the Luiseño Ancestral Origin
Landscape reflects deliberate twisting of expert opinion by the employees of project
proponents and regulatory bodies who see advancing development as keys to their
job security. Much of what has happened,
however, is less iniquitous; it is simply inherent in the ways people think
when they work in cultural heritage management and EIA, and in the ways that
cultural heritage and EIA systems interact.
EIA
has developed as a part of governmental and non-governmental planning only in
the last half-century. The management of
historic landmarks, monuments, and archaeological resources, of course, has a
more venerable history, by some reckonings going back to the 10th
century ACE and perhaps farther. Organized
government systems for heritage management were being put in place in Europe by
the early 19th century, and spread across the world with colonialism. So the ways archaeologists, architectural historians,
and our colleagues think about our aspects of cultural heritage were
well set in place before EIA ever came on the scene. These ways of thinking feature the following
more or less standard elements:
- A narrow focus on specific, carefully
defined places – usually buildings, other structures, monuments,
and archaeological sites, and on portable antiquities;
- Difficulties in conceptualizing broad
landscapes and natural places as having cultural significance;
- Compilation of official lists of
heritage places, variously called registers, inventories, and schedules,
among other things;
- An expectation that listed heritage
places should be preserved unchanged in perpetuity;
- Little or no consideration given to
places not on official lists, or not at least regarded as eligible
for them;
- Official governmental bodies that
compile and maintain lists, and promote preservation;
- Laws and regulations aimed at protecting
listed places to varying degrees, or at least at reserving to government
the right to destroy them.
- More or less rigorous constraints on the
private appropriation of heritage places, or of antiquities.
These
standard elements are embedded not only in the legal systems of most nations,
but in such international instruments as the World Heritage List. Even when we try to bend our minds around
cultural things that are not archaeological sites and historic
landmarks, we automatically apply our traditional ways of thinking. The UNESCO Convention for the Safeguarding of
the Intangible Cultural Heritage, for example, directs that signatory nations
compile lists of intangible cultural heritage, despite the inherent fluidity and
evanescence of intangible culture.
When
this list-based, hierarchical, bureaucratic and rather rigid system of thought
intersects with EIA, it further narrows the scope of impact analysis. Not only does EIA come to represent
archaeological sites and landmarks as the only culturally significant aspects
of an affected environment, it tends to recognize as significant only those
sites and landmarks that government has officially declared and listed as
such. In the United States, for instance
– to hold up only my own country as a sad example – if a local community fears
that a place it holds dear may be destroyed by government action and wants it
considered in EIA, it must show that the place is eligible for the National
Register of Historic Places. This
requires the community to explain the place’s significance to government
archaeologists, architectural historians, and others following technical
regulations issued by the National Park Service and readily understood only by
specialists. In most EIA documents in
the United States, if a place has not been found eligible for the National
Register, it is assumed to be of no significance, and can be destroyed with
impunity. And cultural heritage that is not
embodied in places – for example animals, plants, belief systems, traditional
food – has almost no chance of being considered in EIA. This strikes me, at least, as a strange way
for a grandly self-proclaimed democracy to respect the cultural values of its
people.
In
the Luiseño case, much of the argument about the Tribe’s cultural landscape has
centered on its eligibility for the California Register of Historic Resources,
which derives its criteria for inclusion from the U.S. National Register of
Historic Places. After the Tribe
forcefully rebutted the County staff’s assertion that only archaeological sites
could be considered in the course of EIA, Granite Construction hired its own
historic preservation expert to argue its case.
Her approach eschewed all contact with the Tribe and was based solely on
the ethnographic literature and government regulations. She began with a careful explanation of what
she said were the U.S. government’s rules governing National Register
eligibility. These, she said, permitted
recognizing a place as eligible only if it related to a well-articulated
historical “theme.” She generously
allowed that Luiseño Origin traditions might constitute such themes, but then
deconstructed them into multiple examples, each giving significance only to a
limited part of the overall cultural landscape.
Each of these, strangely enough, happened not to include the quarry
site. She acknowledged that one could
map much larger landscapes based on the traditions, and that some of these would
include the quarry site, but she implied that these would be so big that the
quarry’s effects on them would be miniscule.
She then prudently left town before the decision makers or the public could
question her.
The consultant’s
willingness to interpret government procedures in ways that undercut the
interests of the Tribe strikes me as professionally reprehensible, but such
things are probably inevitable in an EIA system like that in the U.S., where project proponents either hire (and fire)
those who analyze potential project impacts or strongly influence the
regulatory agencies that engage such analysts.
But the Luiseño case also
illustrates a more institutional problem with the interactions between EIA and
cultural heritage.
Problem Three: Attitudes and Assumptions
When
people conducting EIA seek to consider the cultural aspects of the environment,
they understandably turn for advice to the government’s cultural heritage
authorities – ministries of culture, official archaeological surveys, agencies
that maintain schedules or registers of cultural places and things. In the Luiseño case, the State Historic
Preservation Officer and Native American Heritage Commission were the
government experts contacted. EIA
analysts reasonably assume that such authorities can advise them about – perhaps
even provide them with lists of – significant cultural heritage that may be
affected.
The cultural
heritage authorities often have little understanding of EIA, but they do know
their own programs, regulations, policies, and specialties. As far as they know, when they are asked to
advise about cultural heritage, they are being asked to advise about what is on
their lists, what they are officially responsible for, or what falls within the
ambit of their professional expertise.
They advise about archaeological sites, scheduled monuments, registered
buildings, listed sacred sites. What
they almost certainly do not advise about is how to interact with local
people and, communities, to find out
what they think is important and what they think ought to be done
about it. That sort of engagement has
never been part of the portfolio of most government heritage offices, and few
of them are staffed, funded, trained or encouraged to promote such engagement. In these days of fiscal belt-tightening and
regulatory “streamlining” among government agencies everywhere, cultural
heritage authorities are often barely able to process paperwork crossing their
desks, and are most unlikely to assert themselves on behalf of people and
communities they may not even know exist.
So they tell the EIA specialists what is on their lists, in their files,
and little if anything more. Or they ask
that an archaeological or architectural survey be done, and its results
subjected to professional review.
Having
received the advice of the government experts, perhaps doing the requested
professional studies, and believing that they now know what cultural heritage
may be affected, the people conducting EIA duly report what they have learned
and proceed to analyze environmental impacts without further consideration of
culture. If local people and other
interest groups then object – perhaps violently – to what they think the
project will do to their heritage, it often comes as a surprise to the
project’s proponents and their EIA specialists (and sometimes to the cultural
heritage authorities as well).
In
the Luiseño case, the County staff checked a records center maintained by the
State Historic Preservation Officer, where they found that only one cluster of
archaeological sites had been nominated to the National Register of Historic
Places. This cluster, though part of the
Ancestral Origin Landscape, had been nominated by an archaeologist – this
author, as a much younger man – who had failed to consult the Luiseño. Its rather arbitrarily-drawn boundaries were some
distance away from the Liberty Quarry project site. They also contacted the State Native American
Heritage Commission and checked its “sacred sites files,” but as noted above,
the Pechanga Band had not at that time had occasion to list its landscape
there. To its credit, the Commission did
suggest that the County consult the Band, but provided no detailed guidance,
and the County’s consultative efforts were limited at best. Following standard California state practice,
the County also had an archaeological survey conducted of the project site,
which produced no significant results.
The EIA report, when published, suggested that the project would have a
less than significant effect on “cultural resources,” despite the Band’s by-now
vociferous objections to the potential desecration of its cultural
landscape.
Government, Culture, and People
The Luiseño case is by no
means unusual; comparable examples can be found in virtually every part of the
United States and in every country world-wide.
The systems – if such they can be called – that permit and facilitate
such abuses are fundamentally unfair and counter-democratic, and their
operation undercuts our efforts to preserve cultural heritage. Surely it is true that only the citizens of
our countries, only the people, have the power to redirect and control destructive
development, but our traditional ways of managing heritage disconnects us
from the people. By focusing attention
only on the kinds of heritage that we archaeologists, architectural
historians, and other “experts” understand and appreciate, we fail to engage
the people. By failing to respect them and the things they
think are significant, by insisting instead that they respect our
evaluations of heritage, our terminology and ways of viewing the
universe, our ways of describing and discussing heritage, and our
plans for its management, we cause ourselves to be seen as elitist and
irrelevant to the people’s interests. Not
only does this break faith with the people in whose interests we presumably
seek to manage heritage; it also leaves us in a relatively powerless position
when contending with developments that destroy it. We become, in essence, junior partners in
such developments, and we are easily ignored by our senior partners in
government and industry when conflicts arise.
Ironically,
failing to engage the people and address the heritage they value can also impede
development projects. I have personally
seen important, highly justified projects held up for years, at very high cost,
and sometimes abandoned altogether, because of last-minute controversies over
locally valued cultural heritage. In the
Luiseño case, at this writing, the County Planning Commission has denied a
permit for the Liberty Quarry, in part because of its impacts on the Luiseño
ancestral origin landscape. Appeals will
doubtless be lodged, the final outcome remains in doubt, and the Commission’s
action came only after an extraordinary effort by the Pechanga Band and its
allies, who had to engage their own expensive “expert” consultants (like the
author) to help rebut the conclusions of the project proponent’s consultants
and the County staff. Both sides spent a
great deal of time and money that could have been saved, had a more thoughtful
process of EIA been carried out.
Controversies
like the one surrounding the proposed Liberty Quarry can often be avoided or efficiently resolved if affected
people and communities are respectfully
consulted, early in project planning.
Unfortunately, and quite inadvertently, our systems for considering
cultural heritage in EIA do not routinely or even often provide for such
consultation. I suggest that it would be
in everyone’s interests – the interests of governments, of archaeologists and
other heritage professionals, of our institutions and agencies, of communities
world-wide, and of the development community – to make EIA more sensitive to
cultural heritage, broadly defined, and notably to the cultural values of local
communities. Interestingly, a way to do
this has been offered – not by us cultural heritage experts, but by biologists.
The Akwé:
Kon Guidelines
The
Secretariat of the Convention on Biological Diversity – a convention to which
China and other Asian countries are signatories, but my country, I am sorry to
say, is not – has produced a sophisticated set of guidelines for considering
cultural heritage in EIA (Secretariat of the Convention on Biological Diversity
2004). These guidelines are called “Akwé: Kon”(“Ahgwégoh”) a term in the
language of the North American Mohawk tribe meaning “everything in creation.” They outline how to conduct social, cultural,
and environmental impact assessments in concert with affected communities. The guidelines are voluntary; the Secretariat
has no regulatory authority. Their
lengthy subtitle indicates that their application is recommended only where
“sacred sites” or “lands and waters traditionally occupied or used by
indigenous and local communities” are involved.
Their unenforceable character does not detract from their quality as
good advice, however, and it is hard to imagine a place on earth, other than
the deep oceans and Antarctica, that has not been “traditionally occupied or
used” by communities.
A
government or NGO planning some
form of land-use – a dam, a highway, an agricultural or urban revitalization
scheme, or a power plant – that conscientiously followed Akwé: Kon would actively and creatively engage local communities
in every aspect of planning. It would
work with such communities to identify who speaks for different cultural
interests. It would learn how to
communicate with these groups, find out and record their concerns and negotiate
ways to address them. In doing so, it
would make sure that affected groups have the financial and other resources
necessary to participate fully in impact assessment and decision making. It would negotiate and put in place
agreements with the communities about how the impacts of the project would be
identified and considered. Following
such agreements, it would conduct cultural impact studies addressing the
project’s possible impacts on, for example:
…cultural heritage, religions, beliefs and
sacred teachings, customary practices, forms of social organization, systems of
natural resource use, including patterns of land use, places of cultural
significance, economic valuation of cultural resources, sacred sites, ceremonies,
languages, customary law systems, and political structures, roles
and customs.
(Secretariat of the CBD 2004:13)
The scope
of such studies would take into account:
(a) Possible
impacts on continued customary use of biological resources;
(b) Possible
impacts on the respect, preservation, protection and maintenance
of traditional knowledge, innovations and practices;
(c) Protocols
(negotiated with communities);
(d) Possible
impacts on sacred sites and associated ritual or ceremonial activities;
(e) Respect
for the need for cultural privacy; and
(f) Possible
impacts on the exercise of customary laws.
(Secretariat
of the CBD 2004:14)
The
government or NGO would carry out environmental assessments coordinated with
the cultural assessments. These would “respect existing inherent land and
treaty rights as well as
legally established rights of indigenous and local communities” and “contribute to the protection of the rights of indigenous
and local communities by
recognizing (their) distinct activities, customs and beliefs…” Such assessments would consider, among other
more strictly eco-biological factors:
·
areas
of particular economic significance (as hunting areas and trapping sites, fishing grounds,
gathering areas, grazing lands, timber harvesting sites and other harvesting
areas);
·
particularly significant physical features and
other natural factors which provide for biodiversity and
ecosystems (e.g. watercourses, springs, lakes, mines/quarries
that supply local needs); and
·
sites of religious, spiritual, ceremonial
and sacred significance (such as sacred groves and
totemic sites).
(Secretariat of the CBD 2004:16-17)
Coordinated social impact assessments would:
…. take
into account gender and demographic factors, housing and
accommodation, employment, infrastructure and services, income and
asset distribution, traditional systems and means of production, as well as
educational needs, technical skills and financial implications… and evaluate …. tangible benefits to such
communities, such as non-hazardous job creation, viable revenue from the
levying of appropriate fees from beneficiaries of such developments, access
to markets and diversification of income opportunities.
(Secretariat of the CBD 2004: 18)
Economic
assessments would recognize that:
…changes to traditional practices for food production, or (that) involve the introduction of
commercial cultivation and harvesting
of a particular wild species (e.g. to supply market demands for particular herbs, spices, medicinal
plants, fish, fur or leather) may lead to pressures to restructure traditional systems of land
tenure or expropriate land,
and to pressures on the sustainable use of biological diversity, in order to
accommodate new scales of production. The ramifications of these kinds of changes can be far-reaching and
need to be properly assessed, taking into account the value systems of indigenous and local
communities. Likely impacts
associated with the cultivation and/or commercial harvesting of wild species should also be assessed
and addressed.
(Secretariat of the CBD 2004: 19-20)
The results of all these assessments would be
brought back to the community and coordinated with its own planning, in a
transparent, consultative manner, with provision made for the resolution of
disputes (Secretariat of the CBD 2004:22-25).
Opting
for Akwé: Kon
An
EIA system based on Akwé: Kon would
not discourage consideration of things like World Heritage sites and places or
things listed in a national schedule or register, but it would recognize that
those who are fixated on such places – that is, let us admit it, many of us
– constitute only one set of cultural stakeholders, whose values are not
privileged over those of others, notably including local people. It would be significantly more democratic,
more transparent, more inclusive than most existing systems. It would also, I think, produce a higher
degree of predictability for development project proponents than they currently
enjoy.
Adopting
an Akwé: Kon based system would
require administrative, legislative, and policy actions of different kinds,
depending on the nation or NGO involved.
In the U.S., unfortunately, it would require action by our legislative
bodies, which is very unlikely to happen given their current composition. In nations with less fossilized EIA and
cultural heritage systems than ours, among NGOs and even perhaps among private-sector
developers, there may be more hope.
I
have no magic formula for replacing the world’s ineffective cultural heritage
systems with something like Akwé: Kon. My purpose in this paper has simply been to suggest
that many of our existing systems for relating cultural heritage to EIA are
self-defeating, and to suggest that we consider such creative alternatives as Akwé: Kon – alternatives that stress
finding out what concerns living people and communities – not just governments
and specialists – about impacts on cultural heritage as they define it,
and addressing such concerns creatively and with responsibility. I hope that the world’s environmental and cultural
heritage organizations, and the smart young people who are rising to leadership
in them, will undertake this consideration.
Bibliography
Convention
on Biological Diversity: Secretariat of, 2004
Akwé: Kon – Voluntary
Guidelines for the Conduct of Cultural, Environmental, and Social Impact
Assessments Regarding Developments Proposed to Take Place On, or Which Are
Likely to Impact On, Sacred Sites and on Lands and Waters Traditionally
Occupied or Used by Indigenous and Local Communities. Secretariat of the Convention on Biological
Diversity, Montreal, available from http://www.cbd.int/doc/publications/akwe-brochure-en.pdf,
[23 September 2011].
Eccleston,
Charles H., 2011 Environmental Impact Assessment: A Guide to Best Professional
Practices. CRC Press, New York.
King,
Thomas F., 2006 Creatures and Culture:
Some Implications of Dugong v. Rumsfeld.
International Journal of Cultural
Property 13, 235-40
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