Action Alert: Bears Ears Proposed Management Plan Comment/Protest

Bears Ears Proposed Management Plan & Final EIS & U.S. Forest Service Proposed Rule Revising NEPA Regulations

Bureau of Land Management (BLM), in coordination with the United States Forest Service (USFS), has prepared the Proposed Monument Management Plans (MMPs) and Final Environmental Impact Statement (EIS) for the Bears Ears National Monument (BENM) Indian Creek and Shash Jáa Units. Until August 26, 2019, there is an open protest period concerning the Proposed MMPs. Any person who previously participated in the planning process and has an interest that is (or may be) adversely affected by the proposed plan may file a protest. BLM outlines the criteria and elements.

Also open is a 60-day public comment period regarding the proposed closure of recreational target shooting (referred to as “target shooting” in the MMPs) at campgrounds, developed recreation sites, petroglyph sites, and structural cultural sites within the Bears Ears National Monument. Anyone may submit comments on this, with instructions available in the same Federal Register notice. The closing date is September 24, 2019.

Additional instructions are available here. NATHPO does not have template letters for these, but we concur with the position of the National Parks Conservation Association (NPCA), Trump Administration Issues Flawed Plan for Bears Ears National Monument Lands Despite Active Litigation and Overwhelming Opposition, and the other conservation/heritage groups quoted in NPCA’s press release on this.

U.S. Forest Service Proposed Rule Revising NEPA Regulations:

The USDA Forest Service (USFS) is extending the public comment period on a Proposed Rule revising its National Environmental Policy Act (NEPA) regulations. Public comment is being accepted through August 26, 2019. Information on the proposed rule and instructions on how to comment is available in the Federal Register.

USFS states that the proposed rule will help the agency make timelier decisions based on high quality, science-based analysis, which will improve the Forest Service’s ability to get work done on the ground while meeting its environmental stewardship responsibilities. In the current Administration, we are understandably skeptical of these sweeping and benign claims. Any gains in efficiency should not come at a cost to public involvement or conservation of natural resources, including tribal involvement and cultural resources.

Two informational webinars were conducted for tribes and may be accessed on the US Forest Service’s Tribal Relations website.

The proposed changes may indeed have implications for tribes, which often have substantial traditional cultural and ancestral connections to federal lands. These proposed changes could adversely affect tribes’ ability to protect sacred and significant cultural sites. Agencies are already challenged by the identification of properties of religious and cultural significance to tribes. Efforts to streamline review processes can impact tribes’ ability to participate in consultations, especially off tribal land, where many culturally important sites are located.

Please review NATHPO’s comment letter for additional information. Feel free to use any or all of the text in your own comments through the Federal Register and any letters you may send to USFS leadership. We suggest sending to the following leaders:

Vicki Christiansen, Chief, U.S. Forest Service
Lenise Lago, Associate Chief, U.S. Forest Service
Doug Stephens, National Heritage Program Manager, U.S. Forest Service
Fred Clark, Director, Office of Tribal Relations, U.S. Forest Service

National Association of Tribal Historic Preservation Officers (NATHPO)
For more information contact NATHPO:
202-628-8476 | info@nathpo.org | www.nathpo.org