NATHPO Advocacy
COMMENT LETTERS & PRESENTATIONS
Upcoming comment letters NATHPO is drafting:
- Comment Letter on Development of a Program Alternative for Section 106 for Land and Water Conservation Fund State and Local Assistance Programs. Due: June 28, 2024.
2024:
- 07-31-24 NATHPO Amicus Brief in support of the Tohono O’odham Nation and the San Carlos Apache Tribe in their lawsuit against the U.S. Department of the Interior (DOI) for failing to properly consult with the Tribes under Section 106 of the National Historic Preservation Act (NHPA).
- 06-28-24 NATHPO comment letter on the the National Park Service’s (NPS) proposal to develop a Section 106 Program Alternative (PA) for the Land and Water Conservation Fund (LWCF) state and local assistance programs.
- 06-22-24 NATHPO comment letter regarding how the Department of Homeland Security’s (DHS) Environmental Justice Strategic Plan may impact Tribal Nations in accordance with Executive Order 13175, Consultation and Coordination with Indian Tribal Governments, and President Biden’s “Memorandum on Tribal Consultation and Strengthening Nation-to-Nation Relationships.”
- 06-10-24 NATHPO comment letter to the Bureau of Land Management and U.S. Department of Agriculture’s Forest Service’s Bear Ears National Monument Draft Resource Management Plan (RMP) and Draft Environmental Impact Statement (EIS).
- 04-30-23 NATHPO comment letter to NPS on the 2022 Draft Revisions to National Register Bulletin 38: Guidelines for Evaluating and Documenting Traditional Cultural Properties
- 04-12-24 NATHPO comment letter regarding the U.S. Department of the Interior’s Federal Indian Boarding School Initiative.
- 04-09-24 NARF & NATHPO Joint Memorandum on The U.S. Army Corps of Engineers’ Unlawful Adoption and Use of 33 C.F.R. Part 325, Appendix C, to Fulfill Section 106 of the National Historic Preservation Act.
- 04-09-24 NATHPO comment letter in Support of U.S. Army Corps of Engineers’ Notice of Proposed Rulemaking to Rescind 33 C.F.R. Part 325, Appendix C.
- 04-08-24 NATHPO comment letter to the Federal Permitting Improvement Steering Council’s implementation of Executive Order (E.O.) 13175, “Consultation and Coordination with Indian Tribal Governments.”
- 03-25-24 NATHPO comment letter to NPS on the November 6, 2023, Draft Revisions of National Register Bulletin 38, Identifying, Evaluating, and Documenting Traditional Cultural Places.
- 02-16-24 NATHPO comment letter to the National Park Service (NPS) on their proposed National Programmatic Agreement (NPA) for Section 106 reviews.
- 02-09-24 NATHPO comment letter to Sen. Sheldon Whitehouse (D-RI) on his draft Create Offshore Leadership and Livelihood Alignment by Operating Responsibly and Together for the Environment (COLLABORATE) Act, offshore wind bill.
- 02-06-24 NATHPO Presentation on new Native American Graves Protection and Repatriation Regulations: Immediate Concerns for Indian Tribes
2023:
- 10-30-23 NATHPO comment letter to the Department of Homeland Security on the proposed NPA program alternative to Section 106.
- 10-17-23 NATHPO support letter to the Southeastern Archaeological Conference (SEAC) on their image policy that requires authors to consult with descendant communities if they want to include images of burial items in articles in SEAC’s journal.
- 09-29-23 NATHPO comment letter to U.S. Department of Energy on the Coordinate Interagency Transmission Authorization and Permits (CITAP) Program to accelerate Federal environmental review and permitting processes for qualifying onshore electric transmission facilities.
- 09-29-23 NATHPO comment letter to the White House Council on Native American Affairs on the National Plan on Native Language Revitalization (Dear Tribal Leaders Letter).
- 09-27-23 NATHPO comment letter to the Council on Environmental Quality on the new National Environmental Protection Act revisions.
- 09-27-23 NATHPO comment letter to the White House Council on Native American Affairs on the proposed Sacred Sites best practices guide.
- 09-15-23 NATHPO comment letter to the Bureau of Land Management on the revision to the National Programmatic Agreement (NPA) for the National Historic Preservation Act (NHPA).
- 04-17-23 NATHPO comment letter to National Park Service on NPS’ intent to create a Nationwide Programmatic Agreement (NPA) to provide consistency in the application of Section 106 compliance procedures for federal cultural resources financial assistance activities.
FEDERAL APPROPRIATIONS
Per the 1992 amendments to the National Historic Preservation Act of 1966, federally recognized Tribal governments were able to create and operate Tribal Historic Preservation Officer (THPO) programs by officially entering into agreements with the National Park Service on behalf of the Secretary of the Interior. Among other tasks, THPOs may assume the State Historic Preservation Officer (SHPO) responsibilities on Tribal lands and also receive funds for this purpose from the Historic Preservation Fund (HPF), also administered by the National Park Service. The HPF is supported by annual revenues from Outer Continental Shelf oil leases and assists states, local governments, and Indian Tribes with their historic preservation activities nationwide.