The Bureau of Land Management (BLM), the Bureau of Indian Affairs (BIA), and the Department of the Interior have produced a draft Resource Management Plan amendment (RMPA) and Environmental Impact Statement (EIS) that proposes to open more land in the Greater Chaco Landscape Region to oil and gas drilling. Essentially, the agencies' preferred option is to allow drilling and related infrastructure development right up to the current boundaries of the Chaco Culture National Historic Park. For many Native tribes and pueblos, as well as environmentalists and avocational archaeologists, this is suboptimal.
On September 4, 2020, the GCAS Board of Trustees submitted a detailed comment to the draft RMP/EIS on behalf of our group as a whole. Meanwhile, you can help protect the Park as well as the Greater Chaco Landscape Region by spending as little as five minutes of your time to submit a comment as an individual, via email. Here's how:
Archaeology Southwest provides a quick summary of the three main issues involved in this RMPA/DEIS, here.
The Chaco Coalition has set up an easy-to-use comment portal, here. You must give your name and city/state/zip code to submit a comment. They have provided a sample comment that you can add to or change; or you are welcome to use any or all of the sample five-paragraph comment below, which includes the main points to make but also is more specific to the GCAS mission of protecting the numerous archaeological and cultural sites located throughout the region that will be destroyed if it is opened to oil-gas drilling:
NEPA Number: DOI-BLM-NM-F010-2017-0128-RMP-EIS
Project Name: Farmington RMP: Mancos-Gallup Amendment
Number LLNM004000 (1610)
The Greater Chaco Region is one of the richest cultural areas in the United States. Chaco Canyon and the Greater Chaco Landscape are part of the ancestral homelands of many tribes including the Pueblos, Hopi, the Navajo Nation and other tribes throughout the Southwest. These tribes consider the entire area a sacred and critical part of their ongoing identity and cultural practices. This living cultural landscape holds thousands of ancient structures, archaeological sites and other cultural resources. More significantly, a vast number of these sites are known to contain or are likely to contain ancestral human remains. All these sites reflect many and varied precursor cultures to the pueblos and tribes affected by this proposed project. Some sites have yet to be documented, so funds should be made available and prioritized for archaeological and cultural research surveys within the proposed Greater Chaco Landscape project area, and for any excavations or mitigation such surveys deem necessary, before any other decision or action be taken under any of the draft RMP/EIS’s proposed alternatives.
In contrast, if activities were to be taken under the development project as proposed they would cause large, irreversible gaps in the affected pueblos’ and tribes’ cultural knowledge of their own ancestral homeland. All of the scientific and cultural information, and the ancestral human remains that these sites contain, would be irretrievably lost. These sites and the information they contain comprise the continuum of each tribe’s and pueblo’s particular history, culture, and ancestral lineage. Therefore if this draft RMP/EIS is allowed to continue, its Alternative B-1 is the only option yet made available to the public that provides any realistic protection of these valuable and culturally sensitive sites.
In order to safeguard the irreplaceable cultural, historic, and natural resources located in the proposed project area from future development, and because these critical resources extend beyond the boundaries of the Chaco Culture National Historic Park, the final RMPA/EIS must include a 10-mile protective withdrawal area around the Park and around contiguous lands (500-acre addition to Bisti Wilderness, LWC2, and Split Lip Flats) in which future oil and gas development on federal land is prohibited. For years, the Department of the Interior has designated federal land in this 10-mile area unavailable or otherwise removed parcels from oil and gas lease sales; thus this request to prohibit oil and gas development in this 10-mile protective area essentially continues existing federal policy at no significant additional expense or effort in implementation. The draft RMPA’s preferred alternative would be a significant step backwards.
More than 90 percent of the land affected by this draft RMP/EIS is already leased for oil and gas development, but the draft RMP/EIS omits any analysis of the fact that the worldwide economic circumstances of oil and gas extraction have changed dramatically. This altered economic situation greatly diminishes the justification for the proposed development project at issue here. Therefore it is imperative that an accurate and complete analysis be performed that substantiates what a reasonable amount of oil and gas development would be, that falls in line with today’s circumstances. The absence of any such analysis in the RMP/EIS can only be cured by a Supplemental EIS that addresses this issue thoroughly.
I urge you to prepare a supplement to the draft RMPA and EIS in order to consider both the changed economic circumstances surrounding oil and gas extraction and to examine additional alternatives that emphasize conservation—including protection of lands with wilderness characteristics and protection of the sacred landscape, archaeological sites, and cultural resources integral to the well-being of Native communities. If the Department of the Interior does not undergo this additional analysis, it should, at the very least, support EIS Alternative B-1 as its preferred alternative because it better enhances protections for the Greater Chaco Region than the current EIS preferred alternative, while allowing a more reasonable amount of oil and gas development in line with today’s circumstances.
The deadline for individuals or groups to submit comments is September 25, 2020, but please do not delay.
Questions? Contact your GCAS webmaster for help!