The Ocmulgee Flats?

A Newly Coined Term
For the Politically Incorrect

RE: Proposed Eisenhower Parkway Extension

Rebuttal of Mr. William P. Horn's opinions of the Ocmulgee 'Flats'

Mr. Larry R. Dreihaup, P.E.
Division Administrator
Federal Highway Administration
1720 Peachtree Road, N.W.
Atlanta, GA 30367

RE:Letter dated 4/18/97 from William P. Horn, Attorney for Bibb County, GA, Birch, Horton, Bittner and Cherot, Washington, DC, to Mark Edwards, State Historic Preservation Officer, Atlanta, GA, Opposing the Georgia Department of Transportation's Determination of Eligibility for the Old Ocmulgee Fields Traditional Cultural Property.

This letter begs for rebuttal. Please a consider the following points that should be corrected or explained and add them to your file containing the above-referenced correspondence.

P1, pr1: Mr. Horn begins his commentary by coining a new name, "Ocmulgee Flats," for a place known continuously since the 1700's as the "Old Ocmulgee Fields" (or the "Ocmulgee Old Fields"). He uses this unflattering new term at least 15 times throughout the document, while referring to the historic designation only once.

P1,pr2: In footnote #1, Mr. Horn states that on November 29, 1995, the Federal Highway Administration, United States Fish and Wildlife Service, Georgia Department of Transportation (Ga DOT), Historic Preservation Division of the Georgia Department of Natural Resources, National Park Service, and the Muscogee (Creek) Nation "signed a letter of cooperation as further evidence of their desire for continued cooperation in reaching a solution" He is incorrect. The signature page shows that the GaDOT's representative, though present at the meeting and listed on the document, DID NOT sign the agreement.

During the years of arguments surrounding a Middle Georgia route for the Fall Line Freeway, Macon/Bibb County political leaders insisted it must come through Macon. Many state legislators thought it should be routed "around Macon" to serve its stated purpose as a developmental road. A Macon Telegraph article dated 9/17/85 stated: "(Mayor Israel) wants to lobby for the highway to come through Macon and be linked with the proposed extension of Eisenhower Parkway." On 1/31/85, a Macon Telegraph article noted that this idea is "a revival of a 16-year road plan that would replace a shorter, half-mile-long Eisenhower extension in the MATS construction program." According to the same article, a longer extension across the river could not be justified because GaDOT traffic count studies showed that "only 2,000 vehicles a day would use the road."

There were other arguments against the Eisenhower Parkway Extension route. In a Macon Telegraph article dated 1/17/86, Rep. Sonny Watson of Warner Robins stated: "They call it a developmental highway, then run it up I-75." A Macon Telegraph article dated 1/19/86 reports: "Volleys in the great legislative road war already are flying fast and furious. And Macon is again caught in between Transportation Commissioner Tom Moreland and House Speaker Tom Murphy. He (Moreland) wants to extend the Eisenhower Parkway, with us (General Assembly) paying for it,' said Murphy after taking a look at the route and stating his opposition. How the DOT came up with a route different from the two that had been under consideration last month was a puzzle to many." After winning this fight, Commissioner Moreland resigned his position with the State of Georgia. His firm, Moreland-Altobelli Associates, planned and now manages Bibb County's $305,000,000 road improvement program, which includes the Eisenhower Parkway Extension.

P2,pr1:Where are the studies showing that 12 separate routes for the Macon portion of the Fall Line Freeway were thoroughly, carefully and exhaustively analyzed by the Georgia Department of Transportation (GaDOT), and proving that Alternative A1/Preferred Alternative (Eisenhower Parkway Extension) has the least impact on potential existing archaeological sites, wetlands, and wildlife habitat? And why have there been no hearings to allow public input regarding these routes or the Preferred Alternative?

P2,pr2:There is little opposition to the Fall Line Freeway as a whole, only to the cross-Macon (Eisenhower Parkway Extension) connector. No studies have been done to prove that this route would be "enormously beneficial to the citizens of Bibb County and surrounding areas," that safety would be dramatically improved, or that it would be the most practical and cost-effective way to relieve congestion at Macon's four Ocmulgee River bridges. Many comparable-sized or larger cities have no more bridges across their rivers (Chattanooga-4, Montgomery-2, Savannah-2, Columbus-4, for example). The perceived congestion occurs only during weekday early morning/late evening rush-hours.

Local citizens recently learned that a massive highway project is already planned to improve the I-75/I-16 interchange/river-crossing, widen I-16 to Coliseum Drive, upgrade the I-16 ramp systems, widen the Coliseum Drive (Otis Redding) bridge and make traffic light changes at the I-16, Spring Street, Second Street, and Coliseum Drive bridges. This project could easily accommodate the cross-Macon connector, since the Fall Line Freeway enters Macon from the South on I-75 and most east-west, cross-state traffic already travels I-75/I-16. This route, which is barely 1-1/2 miles further to Highway 57 (Fall Line Freeway North) than the proposed Eisenhower Parkway extension, utilizes existing roads - one of the objectives of the Governor's Road Improvement Plan. Therefore, many groups and individuals believe it is logical, cost-effective, and cultural/natural resource conservative to designate this route "Fall Line Freeway" and get on with it.

Last week, Bibb County condemned the old, waterfront Washburn Building to make way for new I-16 ramps crossing the river into downtown Macon at Coliseum Drive. Connecting Seventh Street to this system and to the present end of the Eisenhower Parkway Extension as an attractive and convenient downtown business route, instead of an eyesore, might be a truly beneficial use of taxpayer's money.

P2,pr3: Yes, the people of Macon are beginning to understand the importance of their Ocmulgee Heritage Greenway. Down-river from Macon, most of this greenway coincides exactly with the Muscogee (Creek) Old Ocmulgee Fields Traditional Cultural Property (TCP). A look at GaDOT maps of the Eisenhower Parkway Extension show that the proposed highway and its I-16 interchange would gut both the TCP and the greenway corridor between Ocmulgee National Monument and Bond Swamp National Wildlife Refuge which brings a rich variety of wildlife almost to downtown Macon. Additionally, these maps show that the Eisenhower Parkway Extension would NOT "significantly enhance access to these public lands." In fact, it would sever one of the existing access points to lands adjacent to the boundary of Ocmulgee National Monument, including the Scott- McCall Archaeological Reserve. This 300-acre tract was donated to the National Monument in 1992, and is presently held in trust by the Archaeological Conservancy pending legislation to incorporate it into the park.

The original purpose of the Eisenhower Parkway Extension was to provide convenient interstate access for the blighted Seventh Street industrial district. Completion of the Extension from Broadway to Seventh Street now allows quick access to I-75 from this area. Meanwhile, a newer industrial complex near I-16 sits half-vacant and plans for an another industrial complex have recently been announced.

Later, supporters proposed that extending Eisenhower across the river would raise property values and encourage industrial development of the still-vacant lands behind the Macon Levee. The latter goal was tied to a plan to raise the height of the Levee. After Macon's Great Flood of 1994, plans to raise the Levee were set aside, at least temporarily, due to public outcry when it was learned that constriction of the floodway between the Levee and the raised berm roadbed of I-16 immediately across the river caused much of the upstream devastation of residential areas and the Macon Waterworks. When the Levee breached in the area of the proposed new highway corridor, upstream flooding quickly subsided.

Recent studies also indicate that I-16 and the Levee cause the equivalent of 100-year floods to occur every five years at the Lamar Mounds and Village Unit, the Ocmulgee Bottoms section of the Ocmulgee National Monument, the Scott-McCall Archaeological Reserve, and over much of the Ocmulgee Heritage Greenway. Using precious public funds to raise the Levee and construct the Eisenhower Parkway Extension to encourage industrial development in the floodplain would further increase the flooding of public and private properties located upstream and across the river. With 30 year's hindsight, many local leaders today admit that constructing I-16 through the floodplain was a mistake. Should this mistake be compounded by building the Eisenhower Parkway Extension through the same area?

Supporters of the Eisenhower Parkway Extension route are unwilling to consider alternatives. The TCP nomination has become a major threat, because they know the required studies, if honestly undertaken, will prove that feasible alternatives have existed since the Fall Line Freeway was first conceived.

Those who oppose this route are convinced that protecting Macon's unique cultural and natural legacy from further degradation would be far more beneficial to the city's economic future than constructing the Eisenhower Parkway Extension (which has been called: "The Longest Bridge in Georgia;" another bypass of downtown Macon; and a shortcut to the Macon Mall for a few people in Twiggs County). A 1988 study commissioned by the Greater Macon Chamber of Commerce entitled "Point of Destination Tourism Attraction for Macon: A Feasibility Assessment," prepared by Davidson-Peterson Associates, York, ME, validates the economic importance of Macon's cultural and natural resources. Heritage tourism is one of the world's largest, cleanest, and fastest growing industries.

A newly developing vision for Macon includes utilizing the lands behind the Levee for expansion of the Central City Park recreational complex. This use of the west-side river bottomlands is compatible with current floodplain regulations and the TCP nomination. It also respects a 1825 law in which Macon's founders set aside the area below Seventh Street for the "health and recreation" of the city's citizens. Across the river, a "backcountry" greenway would extend from the Ocmulgee National Monument to Browns Mount/Bond Swamp National Wildlife Refuge and beyond. The Old Ocmulgee Fields TCP designation would help to preserve and enhance the cultural, historical and natural value of this priceless legacy.

The city of Macon's political leaders have, wisely, remained neutral during the recent Eisenhower Parkway Extension controversies. They want the Fall Line Freeway to come through Bibb County, but have not endorsed a specific route. They have not participated in Bibb County's expensive, coercive attempts to convince the Muscogee (Creek) people to forego their efforts to preserve the remainder of the Old Ocmulgee Fields, the intimidation of members of the opposition, or unsavory references to the Muscogee (Creek) Nation - "its a radical, dissident bunch out there" (quote from Macon Telegraph article); "if they don't give in, we'll just knock 'em down" (said on National Public Radio); "Bibb County Commissioners hope to reach a compromise that could mean casinos in Georgia. We have to be careful it could smack of you are bribing them.'" (WMAZ TV interview transcript).

Macon's leaders understand that this short, extremely expensive, highly destructive new road will not solve the county's social and economic problems. Perhaps they realize the $84,000 in Bibb County taxes used to hire a Washington lobbyist (Mr. Horn) to push the Eisenhower Parkway Extension through, might be better spent on air-conditioners for the public schools, additional law enforcement personnel and facilities, or other dire local needs. They know that the cost of this highway skyrocketed from $22,218,000 in 1985 to $106,413,000 in 1993 (last available estimate), a huge amount that would pay for completion of well over one-third of the Fall Line Freeway's leg from Macon to Augusta. Knowing this - and despite unprecedented concern for the national budget deficit - Bibb County's U.S. Representative has asked the federal government to pay 80% of the estimated $283,000,000 cost of this construction.

P2,pr4: Extending the Eisenhower Parkway has been "delayed" over 20-years for a wide variety of legitimate reasons. This time lapse and the huge cost increases suggest that this highway was an idea whose time should never come. Meanwhile, the cultural identity of the Old Ocmulgee Fields has never been questioned. This area has been recognized as Muscogee (Creek) since long before the shameful period, known as "The Trail of Tears," when these indigenous people were forcefully removed from Southeast. The Muscogee (Creek) ancient tradition that this is the birthplace of their nation, and their historical attachment to the Ocmulgee Old Fields, are well- documented. Mr. Horn's statement that "the cultural identity of the property has long been destroyed" is simply untrue.

In the 1700's, James Adair referred to the area as "belonging to the Muskohge," William Bartram noted: "If we are to give credit to the account the Creeks give of themselves, this place is remarkable for being the first town or settlement, when they sat down (as they term it) or established themselves." He further stated that "Their old fields and planting lands extend up and down the river, fifteen or twenty miles from this site." Creek refusal to give up the area is recorded in treaties extending in time from 1805 until the 1826 Treaty of Washington which forced them out of Georgia. The 3x5-mile strip known in these treaties as the Old Ocmulgee Fields Reserve was an artificial boundary which served the interests of the State of Georgia. Though removed from their homeland, the Muscogee (Creek) Nation's continued connection to the area lives on in the name of their present-day capital - Okmulgee, OK. It is documented in the historical research and interpretive plans for the Ocmulgee National Monument, by pilgrimages to the area by the last four Principal Chiefs and uncounted members of the Muscogee (Creek) Nation, by the interactions of Macon and Bibb County with the Muscogee (Creek) Nation, and by 1992, 1995, and 1997 Muscogee (Creek) Nation and independent tribal town resolutions. Even Mr. Horn admits the possibility that the Old Ocmulgee Fields might at least be "minimally eligible" for TCP status under the requirements of National Register Bulletin 38.

P3,pr2:Mr. Horn continues to misinform by stating that Ocmulgee National Monument is "located approximately 2.5miles north of the proposed Fall Line Freeway." This is impossible. The National Monument's Macon Plateau Unit is located only 1.2 miles from the Lamar Mounds and Village Unit. The proposed highway corridor splits this strip. Measurements taken from one of the latest GaDOT Eisenhower Parkway Extension project maps indicates that the highway's I-16 interchange ramps will be located only .3 miles from the Lamar Unit and the interchange itself will be partially constructed on the Scott-McCall Archaeological Reserve. Mr. Horn references a statement in Ocmulgee National Monument's 1976 National Register nomination made by archaeologist Ritchie and park ranger Berg saying, "It is felt that the present Monument boundary does not contain necessarily the entire site of the pre-historic Master Farmer Village, but development outside the Monument area has obliterated other possible recognizable features." This, he says, "confirms that the primary examples of Muscogee (Creek) heritage in the area are already preserved." He fails to understand that the "Master Farmer Village" refers to the Early Mississippian Macon Plateau culture town that existed at the site a thousand years before the historic Muscogee (Creek) town of Ocmulgee and its associated Old Ocmulgee Fields.
Even so, he omits the sentence following his quote which says: "The ecumene of the village itself was directly associated with an area twenty miles above and below the site."

Mr. Horn also ignores other documents indicating concern for the lands laying between Ocmulgee National Monument's Main Unit and the Lamar Unit. Ocmulgee National Monument's enabling legislation refers to 2,000 acres of lands "commonly known as the Old Ocmulgee Fields." The Monument's boundaries presently encompass only 702 acres of the designated area. The park's Statements for Management have repeatedly expressed concern for the lands between the Macon Plateau and Lamar Units. Questions about this area are complicated by the donation of the 300 acre Scott-McCall Archaeological Reserve which would be directly impacted by the proposed highway. In 1995, the GaDOT attempted to answer the questions by commissioning a study entitled "Archaeological and Historical Delineation of Ocmulgee/Macon Plateau." This report states:

In addition to the differing boundaries (for the National Register listing) noted above, an additional map of the NRHP district was found attached to the nomination form (See Appendix B). This map shows a boundary area around an area encompassing approximately 2,190 acres, including the Macon Plateau sites, the Lamar sites, and the floodplain area between these two main loci. Personal communications between GDOT archaeologists and the Keeper of the NRHP indicated that this map was a management document."

"Defining the boundaries for Ocmulgee/Macon Plateau is problematic, in part because of differences in the definition of a site' as used by archaeologists and historians. Historic accounts delineating the Creek town of Ocmulgee tend to incorporate the old fields' as factors. In contrast, archaeological procedures tend to use feature and artifact distribution to define site boundaries. Thus, the Ocmulgee National Monument boundary appears to define an area larger than that defined by archaeologists for the archaeological site. Identification of the source and location of a map of the proposed 2,000 area park has proven elusive. Unfortunately, information (about the originally proposed boundary) appears to be unavailable in public records."

P3,pr5:The GaDOT has NOT "conducted additional extensive archaeological surveys of the entire area in question." Most of the proposed TCP has never been archaeologically surveyed. The 1995 GaDOT report cited above states:

"Field investigations conducted in recent decades have been mainly restricted to opportunistic surveys conducted by amateurs and NPS personnel (Georgia Archaeological Site Files), and cultural resource management projects [several listed]. Although limited in a real scope, these investigations have resulted in the recording of numerous archaeological sites in the Macon area."

Within the proposed highway corridor, GaDOT's archaeological survey contract required shovel tests at 30 meter intervals - except on slopes of greater than 20 degrees or in areas of standing water. This eliminated much of the floodplain and adjacent terrace slopes. Work in the eastern floodplain section of the proposed Eisenhower Parkway Extension corridor consisted of ONE deep test and a few shovel tests in an area known to be covered by historic silt deposits up to 12' deep and to encompass one of the deepest (19') peat deposits in Georgia. This sensitive area lays below the Ocmulgee National Monument and Gledhill terraces where two rare Ice Age Clovis spearpoints and numerous later archaeological sites have been found. A GaDOT (1992 Brockington and Associates) survey of the Gledhill Terrace located still-another site (9Bi52) deemed eligible for the National Register of Historic Places.

P4,pr4:Mr. Horn fails to mention that much of the corridor on the west side of the river was not surveyed. In the long segment between the Seaboard Railroad crossing and Walker Swamp Road, hazardous wastes (including PCP's) were encountered which "prompted the GDOT to recommend termination of further archaeological investigations in this area" (see referenced 1995 Brockington and Associates report). Nevertheless, despite Mr. Horn's statement that the survey confirms "any remaining historic or cultural features have been lost via decades of prior activity," several prehistoric sites were discovered in the proposed highway corridor behind the Macon Levee. One of these newly recorded sites (9Bi73) spread across the entire 200' wide corridor and an equal distance to the South. Represented were "relatively undisturbed, stratigraphically defined" Woodland (Napier), Mississippian (Lamar) and Historic Creek (Ocmulgee Fields) occupations. An important Late Archaic Period site (9Bi74) was also discovered in the corridor. Both sites were recommended eligible for the National Register.

P5,pr2:Mr. Horn again uses remarks out of context and fails to quote additional pertinent documents. A letter dated 5/30/90 from Ocmulgee National Monument's Superintendent Mark Corey to Ralph Locurcio, Corps of Engineers states: "As indicated on the enclosed map this proposed highway will be near Ocmulgee National Monument, which is listed in it's entirety on the National Register of Historic Places. I request that your office inform me of all plans, proposals, negotiations, meetings, and actions that you are aware of, or become aware of, that relate to the issuance of permits concerning this proposed project as required by the following laws (listing of laws)." A 4/28/92 letter from Acting Superintendent Guy LaChine notes: "In past discussions with Georgia Department of Transportation representatives, we indicated our concern for visual and noise impacts to the park, changes in water levels which could impact the park, adjacent urban development as a direct result of the road, loss of significant archaeological sites outside the park, and loss of access to the Lamar Mounds unit of the park.
Because of these impacts we feel that this project will require an Individual Permit in the Section 404 permitting process."

In a letter dated 3/30/94 to GaDOT contractor Maguire Baker Associates, Phil Laumeyer, U.S. Fish and Wildlife Service, stresses that "because of the Federal trust resources potentially at risk [from construction of the Eisenhower Parkway Extension], the environmental review needs to consider the impacts of the project on all uplands and wetlands in the construction corridor." He states that on 2/15/94, his agency requested a complete and thorough analysis for each alternative. He lists the information that should be included and says, "We are concerned that the preferred alternatives would be contrary to Executive Order 11988." He expresses concern about habitat segmentation and notes that both the Manager of Bond Swamp National Wildlife Refuge and the Superintendent of the Ocmulgee National Monument have requested an analysis of the effects of this project on their respective properties. To date, no analyses of alternative routes and impacts to Federal properties have been received by the requesting agencies.

At a 7/19/94 meeting, the federal agencies involved agreed that bridging the wetlands was far more acceptable than a berm roadway. However, meeting notes indicate that the Native American issues were not resolved and that it "will not be known until additional public involvement takes place, what response will be received from the Creek Nation." The Muscogee (Creek) National Council responded in 1995 by passing Resolution TR95-10 confirming their 1992 resolution.

Nine years ago, the Muscogee (Creek) Nation did not have a legal right to consideration when federal or state projects threatened places important to their heritage. Shortly after they gained such a right in the early 1990's, they initiated processes intended to protect the Old Ocmulgee Fields. These efforts culminated in the current TCP determination.

P6,pr2: There is no doubt, as some of the above references show and others will confirm, that the Old Ocmulgee Fields are associated with "cultural practices or beliefs of a living community that (a) are rooted in the community's history, and (b) are important in maintaining the continuing cultural identity of the community."

In a 12/27/95 letter to Leon Larson, Federal Highway Administration, Principal Chief Bill Fife stated: "It is both an inalienable right and a fundamental responsibility of a sovereign nation to protect and preserve the cultural and historical legacy of its people. Through forced removal, the Muscogee National has been denied the right to protect its historical sites, ceremonial and religious use areas, and other traditional cultural properties The existence of these fundamental rights is the basis for the tribal role in federal historic preservation and environmental protection statutes. I believe that the Muscogee people and the citizens of Macon have common interests in the fall-line region of the Ocmulgee river. Both peoples have enormously rich cultural and historical legacies there. We must work together to ensure that, in the effort to develop economically, we preserve for our children what is truly most valuable to us - the irreplaceable land and the story that it contains."

P7,pr2:The Muscogee (Creek) Nation has conceded that the area of the Old Ocmulgee Fields Reserve laying North of Ocmulgee National Monument has lost its "significance through alteration of its location, setting, design, or materials." However, a look at the U.S. Geological Survey quad map of the Old Ocmulgee Fields down- river from the National Monument shows that the area has suffered amazing few alterations over the last 150 years, especially since it is located so close to a major metropolitan area. It is worth noting that most of the impacts mentioned by Mr. Horn exist within the boundaries of Ocmulgee National Monument itself. Supporters of the TCP nomination believe that the few alterations which have occurred in the TCP portion of the Old Ocmulgee Fields are not sufficient to eliminate its integrity.

P7-P9: The Old Ocmulgee Fields are inextricably linked, through archaeological excavation and written records, to every prehistoric Native American cultural period in the Southeast and to the history of the Muscogee (Creek) Nation. This place is crucial to understanding the lifeways and origin of the Muscogee (Creek) people, the formation of their great Confederacy, the affects of colonial Spanish/British expansion on this native population, their interactions with other cultures, and their tragic of the Trail of Tears, with its sad aftermath and gradual recovery. The Old Ocmulgee Fields are associated with the lives of many historically significant Creek leaders.
For example, Chief William McIntosh was assassinated by his own people after he signed the 1825 Treaty of Indian Springs which would have ceded the Old Ocmulgee Fields Reserve. The U. S. Government declared the this infamous treaty illegal.

The Old Fields contain examples of the abundant natural resources of the Georgia Fall Line region that sustained the Creek people for untold generations. It is an archive in the soil of their homesteads, their places of worship, the graves of their ancestors. They come to the Old Ocmulgee Fields Heritage Greenway and know they are near the bald eagle, the wildcat, the bear, the deer and other creatures honored in traditional Muscogee (Creek) clan names. They know this special place is a symbol of hope because, like Bond Swamp National Wildlife Refuge's bald eagles, they survived to return.

By Mr. Horn's reasoning, few archaeological sites would qualify for inclusion in the National Register of Historic Places since they are often "not distinct and cannot be considered constructions of any kind." Indeed, many are buried beneath many feet of historic alluvial soil. But It should be noted that the unique Ceremonial Earthlodge on the Macon Plateau and the country's only remaining spiral mound, located at the Lamar site, are considered by the Muscogee (Creek) Nation to be part of its heritage. They are included in the TCP.

The Ocmulgee Old Fields are as culturally important to the Muscogee (Creek) people as the sedge fields located along the Russian River in California, used as an illustration by Mr. Horn, are to the Pomo Indians. The difference is that the Pomo were not totally driven from their homeland. As Mr. Horn suggests, it might be argued that the Old Ocmulgee Fields are an irreplaceable component of a larger property (not just Macon, but much of the states of Georgia/Alabama and parts of Tennessee/Florida/South Carolina) that has great long-term significance to the Creek people.

As indicated above, the areas with a history of yielding important historical information are not all protected by the Ocmulgee National Monument. It is ludicrous to say that "through extensive archaeological studies, GaDOT has discovered and analyzed any existing historical or archaeological sites around the proposed Fall Line Freeway route." It is pertinent to remember that during construction of I-16 in the 1960's the GaDOT destroyed or heavily damaged the New Pond Site, Adkins Mound, two of the Gledhill sites, and Shell Rock Cave.
More recent lack of concern for the Old Ocmulgee Fields is evidenced by a Maquire Baker Associates, Inc. memorandum recording a meeting conducted at GaDOT's Office of Environment and Location on 10/5/1994 which reports: "the Department does not agree with FHWA's opinion of 4(f) applicability." They also rejected a decision set forth in a letter from Georgia's Historic Preservation Division to the Federal Highway Administration's Larry Dreihaup, dated 2/13/96, which said: "In our opinion, this property appears to meet the eligibility criteria for listing in the National Register. Therefore, HPD concurs with the finding, as stated in TR95-10, that 'Ocmulgee Old Fields' constitutes a Muscogee traditional cultural property."

In the 1970's, Bibb County destroyed the ancient Swift Creek Mounds and Village, type-site for a widespread Woodland Period culture, in order to build a Sheriff's Department firing range. Bibb County and GaDOT lack of concern for Southeastern Native American heritage generally, and the Old Ocmulgee Fields specifically, speaks for itself. Still, for ever loss there have been on-going discoveries and new questions to be answered about this place and its people.

Mr. Horn is willing to admit in this paragraph that "parts of this larger area may have been used by Muscogee (Creek) Nation for religious purposes," yet he would deny the Old Ocmulgee Fields National Register status because there might be "birthplaces, graves and cemeteries" located there. Using his criteria, many of the country's National Historic Sites and National Monuments would be excluded from the National Register - along with the archaeological sites.

CONCLUSION:

On 10/4/95 Principal Chief Fife wrote to Brigadier General Ralph Locurcio, U.S. Army Corps of Engineers: "The Muscogee people and the citizens of Macon, as well as those of Georgia, share in the extraordinary historical, cultural, and natural resources contained within the fall-line region of the Ocmulgee valley. As responsible stewards of this invaluable inheritance, we must proceed more reasonably than we have thus far."

The Muscogee (Creek) Nation and others who support the TCP designation for the Ocmulgee Old Fields recognize the need for economic development. At the same time, they stringently believe there are special places on this earth that must be protected for future generations. The citizens of many areas have proven that prudent progress and thoughtful preservation can become partners to the benefit of everyone involved.

Mr. Horn's motives are obvious. He did what his firm is being paid a large sum of money to do - attempt to convince as many people as possible that the Old Ocmulgee Fields have no historical, cultural or physical integrity in order to assure that a TCP designation will not impede construction of the Eisenhower Parkway Extension. His cursory research sounds impressive until it is examined closely and founded to be flawed. His conclusion that the "Ocmulgee Flats" do not qualify for listing as a Traditional Cultural Property, is simply that -his conclusion. This letter must not be allowed to bias the Old Ocmulgee Fields TCP determination.

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