Section 106 and Cemeteries

By: Olivia Kendrick, Environmental Review Historian

If I were to ask you to name a cemetery in Georgia, you could probably name a few. From Oakland in Atlanta to Rose Hill in Macon, to Bonaventure in Savannah, it is no secret that Georgia has numerous noteworthy cemeteries that feature many incredible architectural structures and landscapes. What if I were to ask you to name the type and style of a cemetery? Could you, do it?  Or would you need to flip through National Register Bulletin No. 41, Guidelines for Evaluating and Registering Cemeteries and Burial Places to jog your memory on terminology?  If you answered, “I might need a refresher on describing a cemetery,” there is a new and notable Georgia-specific cemetery resource you can check out! Through the work of New South Associates in collaboration with the Georgia Department of Transportation and the guidance of Historic Preservation Division staff, the new cemetery context allows historians and archaeologists to effectively evaluate these cultural resources. Since its publication in October 2023, the Georgia Statewide Cemetery Context entitled, Identification and Evaluation of Georgia’s Historical Burial Grounds has been aiding historians and archaeologists alike in evaluating these resources for the purpose of Section 106 reviews under the National Historic Preservation Act (NHPA). The document serves as a guide for determining if a cemetery carries enough significance to be considered eligible for listing in the National Register of Historic Places (NRHP).

Cemeteries present unique challenges when evaluating NRHP-eligibility for Section 106 purposes because of the dual nature of the above- and below-ground resource. The age of some cemeteries means that they have been utilized across multiple generations, resulting in an eclectic collection of different styles and time periods of architecture. The same cemetery may have been used by different cultural and religious groups, each with their own beliefs and funerary traditions. The Georgia Statewide Cemetery Context details burial traditions, beliefs, cultural influences, and the funerary industry in Georgia, while providing an approach for evaluating cemeteries’ NHRP-eligibility and guidance on identifying the types and styles that these cemeteries conform to. The context asks the evaluator to consider topics such as the socioeconomic status of those buried, artistic expressions in the markers, and associations with institutions or organizations. If a cemetery contains enough historical significance and adequate integrity to convey its significance, it can be considered eligible for listing in the NRHP. The new cemetery context provides both Section 106 practitioners and those interested in the history of Georgia a useful and insightful tool!