New Acronyms

As the inventor of such widely used cultural resource management (CRM) acronyms as "TCP" (traditional cultural property or place) and "APE" (area of potential effects), I'm pleased to announce promulgation of two more.

1. "MMD" stands for "mealy-mouthed drivel," that is, high-falutin language that means nothing (especially if not followed up in, or if contradicted by, a document's substantive provisions). Example (real language, with agency identity protected):

The Tribes and the agency shall, in a spirit of positive collaboration, effect goals in regards to the project, protection and preservation of natural and cultural resources, under the agency?s jurisdiction or control and for mutually creating a positive management strategy for maintaining properties that considers the preservation of their archaeological, historical, and cultural values and the avoidance of adverse effects in the light of the views of the Tribes.

2. "GSF" stands for "gratuitous statement of fact," wherein an agency clutters up a document by stating facts having nothing directly (or often even indirectly) to do with the subject of the document. These may note that the agency will obey a law or regulation (awfully good of them, yes?), or simply provide an extraneous bit of filler material. Example (again, real language, agency ID disguised):

The agency, in carrying out its responsibilities as the lead Federal agency for NHPA Section 106 compliance, has developed policies and procedures to help guide its planning and decision making as it affects historic and cultural properties.

I've recently reviewed two draft-final programmatic agreements (PAs) under Section 106 of the National Historic Preservation Act, almost every clause of which is made up of MMD and GSF. This creates a dense thicket of prose in which the substantive provisions, such as they are, get lost, and it's hard for even an experienced reader to pick out their strengths and weaknesses.

Please welcome MMD and GSF to the lexicon of CRM acronymology.

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