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Rebuttal Response: “Disturbance to Surface Lithic Components of Archaeological Sites by Drill Seeding.” Rangeland Ecology & Management 64:171–177

We welcome the dialogue initiated by the rebuttal of Rust and Earl as an opportunity to discuss the concerns of both archaeologists and ecologists regarding the disturbances associated with rangeland management practices. We hope that in the process, unconfirmed opinions can be distinguished from empirical evidence, and therefore allow policy and its implementation to be aligned with sound, research-based principles. We stated in our article that cultural resources need to be considered and protected. Rust and Earl confirm that statement but misrepresent other aspects of our work. Rust and Earl begin by stating that National Register Criteria typically would not call for avoidance of surface lithic scatters but later take us to task for ‘‘misunderstanding’’ the significance of lithic scatters. We intentionally designed our study to quantify effects of rangeland drill-seeding on surface lithic scatters precisely because they a) are a common feature, b) can remain undetected in a pedestrian survey, and c) are potentially subject to the direct effect of drill-seeding equipment. For the reasons that Rust and Earl ably explain, a preponderance of recorded sites are characterized—upon initial examination, at least—only by surface lithic scatters, whether they later are found to contain subsurface features or not. We infer from Rust and Earl’s objections that surface lithic scatters are not intrinsically valuable, but that they serve as a marker of more important cultural sites. In contrast, our study considered surface lithic scatters as cultural sites in their own right but distinct from sites with additional archaeological features. At no point did we intend to imply that the direct effects we measured on surface lithics could be translated to other archaeological features. The ‘‘risk to cultural sites’’ to which we refer in the Management Implications section is indirect damage to sites, including potential for soil erosion and looting of artifacts following avoidance mitigation. The National Register Criteria are implemented by agencies and interpreted by individuals. According to the BLM Handbook, 10 surface lithics within a 10-m diameter would qualify as an archaeological site; not unlike our study design. However, ‘‘Archaeological discoveries which are less substantial … may be recorded as sites if a professional archaeologist believes they are important enough …’’ (BLM Handbook H-8110 2002). Even in this first step in the process of adding a site to the National Register, great latitude is given to an individual interpretation of the importance of cultural resources relative to other valuable resources.