August 2020 Update

The Chaco Alliance has been working to protect Chaco Culture National Historical Park and its surrounding landscape from the dangers of fracking since 2009. We are currently a consulting party under the National Historic Preservation Act (NHPA) on a multi-year joint BLM/BIA project that has produced a draft environmental impact statement (EIS) and associated Regional Management Plan Amendment (RMPA). The draft EIS addresses impacts from additional oil and gas development to the park and its landscape as well as to native communities. Comments from the public are due by September 25, 2020. Please click here to visit our Facebook page for instructions on where to submit comments and how to view the document.

We believe the draft EIS is deeply flawed both in terms of its timing and in terms of its scope and adequacy. Meaningful consultation is simply not possible during a pandemic when movement is curtailed and internet and other services are unavailable to so many. Rushing this process forward is an insult to the very intent of the National Environmental Policy Act (NEPA) and the notion of adequate consultation. In addition to the document's numerous deficiencies in terms of addressing issues of climate change, public health, environmental justice, and economic outlook, it also fails to adequately protect the cultural resources in the park as well as in the landscape in the Greater Chaco area, an area that is held sacred by both Navajo and Pueblo peoples. Additionally, it fails to analyze the numerous harmful effects to the health and traditions of the primarily Navajo communities in the planning area. The Chaco Alliance supports the All Pueblo Council of Governors call for a suspension of both the RMPA process and the NHPA Section 106 process until affected pueblos and tribes can meaningfully and safely participate, and we oppose any action intended to advance new lease sales in the planning area. We support the addition and adoption of a "no new leasing" alternative in the draft EIS. We do not support the BLM's preferred alternative C which would permit 3,101 new wells. Please make your voices heard by submitting comments.

The Chaco Alliance continues to monitor the NPS management of the park itself. We remain convinced that the NPS staff that oversees the park cannot fully appreciate the issues that confront Chaco unless they reside in the park as the staff in fact did for most of the years it has functioned. Managing the park from afar at Aztec Ruins National Monument has led to increased communication problems and to many unaddressed issues. One example is the early closing of the loop without locking the gates at both ends. Notifying visitors with a note on their cars that they should "false lock" the gate when leaving in the late afternoon is not acceptable. Both visitor safety and sacred sites are put at risk because of the lack of proper procedure for securing the ruins overnight. In addition, we are convinced that much needed maintenance on the last 4.4 miles of the road into the canyon could be achieved if focus and energy were put into working with local Navajo chapters and the BIA. Our efforts to get NPS management to address this issue began with an in-person meeting with new park management in August of 2018, but we are not aware of any progress at getting even minimal road maintenance. We are also unaware of any progress towards getting the humidifier working properly in the visitor center so that artifacts can be returned to the museum. While it is true that the pandemic has slowed down recent activity and made everything more difficult, we are convinced the NPS can and must do better as stewards of this invaluable resource. The planned replacement of the observatory dome is a first step in the right direction.

December 2017 Update

The Chaco Alliance, along with the San Juan Citizens Alliance, Wild Earth Guardians, Western Environmental Law and others, has submitted over sixty pages of comments to the BLM opposing the March 2018 lease sale of over 4500 acres near Chaco. This is the BLM's third major attempt to lease near Chaco since 2009 when they first proposed leasing 9000 acres near the park. This initial effort was defeated primarily thanks to the Hopi and with the assistance of the Chaco Alliance, San Juan Citizens Alliance, and the National Trust for Historic Preservation. BLM's attempt to lease 18,500 acres in 2012, many within a half mile of the park, was again met with opposition, and BLM deferred almost all the parcels. Although some of the parcels within ten miles of Chaco in this new offering have already been deferred, there are many more parcels offered close to that artificial boundary, and, not only will the park be impacted, but the Chacoan landscape and many Navajo communities and lives will again be made into a sacrifice zone. Please make your voices heard. Write to Victoria Barr (vbarr@blm.gov) asking that all the parcels be withdrawn, and that a complete moratorium on new drilling be put in place.

The Chaco Alliance has also written to the BIA Regional archaeologist who oversees the Navajo lands surrounding Chaco. We are seeking clarification and help in making sure the BLM adheres to proper procedure when improving roads in order to protect sacred sites. A copy of that letter will be added to our documents

We continue to wait for the BLM's Victoria Barr to respond to our letters regarding the lack of consultation and the lack of protection of six sites in and along the Chaco Road in the 2014 road improvement. The BLM has stonewalled us for many months. A copy of those letters will be added to our documents.

March 2016 Update

2016 marks the ten year anniversary of the Chaco Alliance. Many thanks to everyone who has helped along the way. Working in concert with our friends at San Juan Citizens Alliance, Wild Earth Guardians, and the Western Environmental Law Center, we continue to call for a moratorium on all new oil and gas drilling and a retirement of existing wells. We remain active as a consulting party in the on-going Mancos Shale Regional Management Plan Amendment and its associated EIS. Scoping comments have been submitted as well as recent supplemental comments from us and other groups on the RMP process that call for the BLM to move toward an ecological and community resiliency model, and that further explain serious concerns about the MLP submitted by other environmental groups. We do not accept the assumption that continued oil and gas development in the San Juan Basin is a fait accompli, nor do we believe that local Navajo communities and land should be made into sacrifice zones for energy development.

In addition, we are investigating the BLM Farmington Field Office's abdication of their responsibilities under the National Historic Protection Act, and the resulting damage to archeological sites in and along the Chaco Road. We cannot accept that San Juan County has a network of roads that cross public land (and numerous sacred sites) that lies beyond the reach of federal protection. It is the duty of the BLM to assume their role as stewards of our public lands and any sites on them. Proper procedure must be followed, not just in terms of the work done on the Chaco Road (CR7950), but in the work done on the many miles of roads that cross this treasured landscape.

January 2015 Update

Due to pressure from the Western Environmental Law Center, Chaco Alliance, San Juan Citizens Alliance, and Wild Earth Guardians, the BLM has deferred more than 2,800 acres scheduled for leasing in January 2015. The is good news, at least for now. But the Saddle Butte Pinion pipeline project continues to move forward. The comment period has been extended to January 30th, and additional public meetings have been scheduled. Please make your voices heard in opposition to this 130 mile long pipeline which will open even more of NW New Mexico to fracking from oil and gas development, and put at risk the extensive Chacoan landscape, including great houses, ancient roads, and sacred sites.

Farmington, January 13, 5-7 pm at Farmington Civic Center
Lybrook, January 14, 5-7 pm at Lybrook Elementary School
Santa Fe, January 15, 5-7 pm at BLM State Office - 301 Dinosaur Trail

Send comments by January 30th to:
Email: BLM_NM_Comments@blm.gov
Mail: Scott Hall, BLM
6251 College Blvd., Suite A
Farmington, NM 87402

December 2014 Update

The Chaco Alliance, along with the Western Environmental Law Center, San Juan Citizens Alliance, and others has formally protested the proposed BLM January 2015 Lease Sale of parcels totaling more than 2,800 acres. We have also been granted consulting party status on a proposed oil pipeline and gathering pipeline system of approximately 130 miles that would run within two miles of seven Chacoan great houses and cross ancient roads. Public comments are being received until December 31st. Contact BLM Assistant Field Manager Maureen Joe at mjoe@blm.gov.

January 2013 Update

San Juan County has officially abandoned all efforts to improve the road into the park. The NEPA process has ended. While this is a victory for all of us who have devoted time and effort protecting Chaco, the action came in spite of the fact that the County had already agreed to a compromise. Their consultants (URS) had begun work on an Environmental Assessment that would have improved the road with gravel, but not chip seal. Surprisingly, San Juan County walked away from any improvements although they have long held they were concerned about the local Navajo and road safety. As the history below makes clear, the Chaco Alliance has never opposed improvements to the road as long as there was no paving. We continue to research why the County commissioners made the decision to give up. The Updates and links below document the long battle to stop the paving of the Chaco road. In particular, we thank the Hopi and the San Juan Citizens Alliance for their efforts in this regard, and we continue to work closely with both in the on-going effort to protect the park from encroaching oil and gas leasing.

Unfortunately, the General Management Plan Amendment EA referenced in the March 2012 Update has been approved despite lengthly written objections submitted by the Chaco Alliance and the San Juan Citizens Alliance. As is now clear, we correctly challenged the validity of the Purpose and Need for any amendment because the road was not going to be paved. In addition, we are not aware of any effort the park has made to deal with the eyesore created by the new water tank. We continue to work toward a resolution of this issue.

March 2012 Update

The Chaco General Management Plan Amendment Environmental Assessment (EA) has been published. April 9, 2012 is the last day for receiving comments. As indicated in the August 2011 Update, the plan relies on David Evans and Associates visitation projections which are incorrect. These projections must be corrected before the EA has any validity. The park was made aware of the blatant factual errors in the document over two years ago, but has chosen to use it without correction (see Chaco Alliance Response to 2009 NPS Visitation Study below). The Evans document vastly underestimates the effects of any additional paving (chip-sealing) on visitation, thereby encouraging future attempts to pave the road and undercutting many years of citizen/visitor input against paving. In addition, the new management plan would require mandatory visitor education and includes an automatic gate at the loop entrance; all put in place without regard for actual visitation increases. Group visitations per day would be limited, and future plans would place all visitors to the canyon on a reservation only basis. This last eventuality is downplayed in the EA using the incorrect visitation projections from Evans and Associates.

The park claims that the threat of increased visitation from the prospect of paving CR7950 is the main fact that has brought about the proposed changes in the quality of the visitor experience as well as access. The purpose and need for this Environmental Assessment must be challenged. The NEPA process for the improvements for CR7950, the main access road to Chaco, has been on hold for years, and it appears that paving will not be the preferred alternative if and when the process begins again (Note that San Juan County might well use the incorrect, low visitation projections from the Evans document as underpinning for a new paving attempt). The EA uses the fact that Chaco is a World Heritage Site as a second reason for probable increases in visitation. Visitation has already been effected by this fact since Chaco has been a World Heritage Site since 1987. The EA asserts that a third reason visitation will increase will come from the commemorative quarter due to be released in April. There is no reason to believe that this action will substantially increase visitation.

Please demand that the Evans and Associates projections be corrected, and that a complete Environmental Impact Statement (EIS) be undertaken because of the significant impact on visitor experience and access, and the arbitrary and capricious nature of the EA. Submit comments by clicking on open for comment, the plan name, then comment on document at: http://parkplanning.nps.gov/projectHome.cfm?projectID=21575

August 2011 Update

There are encouraging developments in the attempt to preserve and protect Chaco Culture National Historical Park; unfortunately, there are also many negative and perplexing questions about the park's management and its overall vision. On the positive side, the National Trust for Historic Preservation has declared the Greater Chaco Landscape as one of America's 11 Most Endangered Places in 2011 because of energy development. This listing will continue to focus attention on the fragile nature of the Chacoan landscape (and its viewshed), and hopefully will encourage more interaction and cooperation by the BLM with the Hopi Tribe and with preservation groups like the Chaco Alliance, the National Trust for Historic Preservation, and the San Juan Citizens Alliance (see August 2011 letter to BLM below). Also positive is the news that it appears that San Juan County will compromise and accept gravel, not chip-seal, on CR 7950, the main entry road to the park. The Federal Highway Administration has recommended this choice. We have as yet seen no written documentation for this, but our contacts tell us that the Environmental Assessment now underway for CR 7950 will choose gravel as the preferred alternative. We have always supported gravel as a way of improving the road, and we continue to believe it will not have a significant impact on visitation.

One would expect the political climate at the park to reflect in part these good omens. Instead, the park continues to work on a General Management Plan Amendment Environmental Assessment (EA) that we are told calls for radical changes in the managing of visitors to Chaco (mandatory visitor education, gated car-wash like entry to the loop, and severe group visit limits, to name a few). The proposed changes are predicated on a potential increase in visitation that does not appear to in any way to be probable. In fact, the park is already shutting down access to many sites by roping off areas in the campground and on the trails that have previously been accessible. The nature of the visitor experience is being impacted although there is significant disagreement within the staff about whether the changes are in fact necessary. In addition, a shiny new water tank sits on top of the mesa above the new Visitor Center construction. It can be seen from as far away as Pueblo Alto and from many other areas of the canyon. The oddly painted eyesore is just hundreds of feet above the administration offices of the park. How is it possible that the Hopi Tribe, Chaco Alliance, San Juan Citizens Alliance, and the National Trust for Historic Preservation continue to work to stop the ruining of the viewshed around the park, but the management of the park cannot protect the cultural resource in its own backyard? And the costly paperwork of the revised management plan undertaken by the park, and its regional office in Denver, is fixing a problem that doesn't exist. Perhaps it is time for all work to stop on the General Management Plan Amendment Environmental Assessment, and on the on-going changes within the park, until an outside (non-NPS) entity can access what is truly necessary if Chaco is to be properly protected.

Please review the letter from the Chaco Alliance, the National Trust for Historic Preservation, and the San Juan Citizens Alliance asking that the viewshed within five miles of Pueblo Pintado be protected from oil and gas development (The park signed off on this 480 acre oil and gas lease nomination without opposition. See Pueblo Pintado Leases below). Also note our response to the Evans and Associates document that continues to be used in the General Management Plan Amendment EA although it is factually incorrect (The park reviewed and accepted this $18,000 NPS study. See Chaco Alliance Response to 2009 NPS Visitation Study). Also note the denial of conflict of interest letter from the URS Corporation, the consultant on the Chaco road CR7950 project and, unbeknownst to many of the staff at Chaco, the consultant on at least part of the major Visitor Center construction (See URS Denial Of Conflict of Interest below). Please email Barbara West, Superintendent, and ask that the new water tank be reduced in height, repainted, and moved out of eyesight. It is an act of unacceptable vandalism. Ask that all work on the General Management Plan Amendment EA be halted until the staff has taken into account the very low probability that visitation will substantially increase (the purpose and need for the amendment). Also ask that all new restrictive measures within the park be revoked until a proper review of all actions that impact visitor experience is undertaken. It is our understanding that all changes that affect visitor experience, or the landscape and historic fabric of the canyon, must be reviewed by the New Mexico Historic Preservation Office for proper compliance with the National Environmental Protection Act and the National Historical Protection Act. We are in the process of determining whether this compliance has been met. Please encourage the park management to work for consensus decision-making that solicits and values the opinions from all divisions within the park as well as from concerned groups outside the park.

Thanks again for all your support.

June 2010 Update

The Chaco Alliance continues to expand its role in protecting and preserving Chaco Culture National Historical Park.

BLM OIL/ GAS LEASES: We have been accepted as a Consulting Party by the Farmington Field Office of the BLM on all oil and gas leases within ten miles of Chaco. The Hopi Tribe, Navajo Nation, and New Mexico State Preservation Office unanimously supported our acceptance. Along with the Hopi, National Trust for Historic Preservation, San Juan Citizens Alliance, and other groups, we have successfully petitioned to have eight leases close to Chaco withdrawn from sale (see link below). We are part of a working group that will determine the extent of the area to be protected and the kind of impacts that are of concern to all who cherish the park. CHACO ROAD: We remain committed to transparency and proper procedure in the on-going National Environmental Protection Act/ National Historical Protection Act (NEPA/ NHPA) process that will ultimately culminate in an Environmental Assessment (EA). Our understanding is that the EA has been put on hold while the Chaco Culture National Historical Park, San Juan County, and the Navajo Nation attempt to come to an agreement about the road. We have formally asked to be included in their discussions about the road, but that request has been denied. We continue to be concerned about a process that ignores the input of many of the concerned parties and that appears to function outside the requirements of NEPA and NHPA. We have seen no written agreement, but we remain opposed to any additional paving of the Chaco road because of adverse impacts to the park from increased visitation and from increased potential for energy development near Chaco. We re-affirm our demand for a thorough Environmental Impact Statement (EIS), not the lesser level of analysis of an EA.

CHACO GENERAL MANAGEMENT PLAN AMENDMENT and EA: Chaco Culture National Historical Park is re-doing its management plan in an attempt to respond to the possibility of increased visitation. The new plan could significantly restrict and alter visitor experience at the park. Our understanding is that the required EA is in its early scoping stages, but we responded in detail in February 2010 (see link below) to a flawed visitation study produced for the NPS by Evans and Associates that will underpin that management approach. We have yet to receive a reply to our corrections. The visitation study significantly underestimates the impact to park visitation that will result from any amount of paving of the remaining thirteen miles. Contact Chaco Culture National Historical Park directly to become involved in the management plan EA process.

We appreciate your support in all three of these related endeavors. Our hope is that the on-going discussions can be elevated to the level of transparency, inclusion, and thorough procedure that is necessary when considering actions that can forever impact this treasured World Heritage Site. We can be reached at our old email address: (dontpavechaco@gmail.com), or at a newly added address: (chacoalliance@gmail.com). We welcome your comments. Please write to the individuals linked below requesting no more paving, strict adherence to all NEPA/ NHPA procedures, and a full EIS for the Chaco Road. Thanks again.

July 2009 Update

The Environmental Assessment (EA) is due out this summer, perhaps by the end of July. San Juan County (SJC) is still seeking to pave the road by introducing a proposed action that stops the paving 4.4 miles before the canyon. Numerous critiques and unanswered questions have been posed by the New Mexico Sate Historic Preservation Officer (NMSHPO), the Hopi, Chaco Culture National Historical Park (CCNHP), the San Juan Citizens Alliance, the New Mexico Wilderness Alliance, and the Chaco Alliance. Central to many of the objections are the following points:

1. There are simply no significant statistics to support the "hazardous" road argument presented by San Juan County, no fatalities except on roads that have already been paved, and too few local residents to justify the increased visitation threat to a World Heritage Site. A 2005 NPS study indicates negative impacts to Chaco infrastructure, sites, staffing, and the quality of the visitor's experience if the road is paved. A five-fold increase in visitation is possible. San Juan County refuses to compromise by doing regular maintenance, and adding signs, fencing, gravel, etc.


2. The Federal Highway Administration (FHWA) has allowed SJC and its consultants, URS Corporation and Parametrix, to manage and control the application of the National Environmental Protection Act (NEPA) and National Historic Preservation Act (NHPA) procedure, and the result has been the waste of over $400,000 of taxpayer money to produce two studies that have been highly challenged by the New Mexico State Preservation Officer (NMSHPO), CCNHP, the Hopi, San Juan Citizens Alliance, Chaco Alliance, and others. No adequate or un-biased EA has been produced after over two years of study and expense. The questions from the NMSHPO, Hopi, CCNHP and others remain without adequate answers.


3. Newly-elected New Mexico Senator Tom Udall has not provided the oversight and guidance that could protect a World Heritage Site. As a member of the Congress in 2005, then Representative Udall earmarked the $800,000 for improvements to the Chaco road. He was either misled or ill-informed, but the project would have been granted a Categorical Exclusion by the Federal Highway Administration and gone forward without any impact studies if our group and others had not intervened. Tom Udall was made aware of the problems and the plight of Chaco as early as August 2006, but he has done little to help. His new staff in Washington needs to become aware of the complexity of the project, and aware of the many emails and letters Tom has received about this ill-starred venture. A phone call from Tom could easily direct SJC toward improvements like fencing, gravel, and maintenance, and away from its obsession with paving. Please write to Senator Udall and urge him to commit to improvements, not paving. Tell him that no more money should be granted for this project, and that a complete audit of the money already spent is necessary.


4. Federal and state laws may have been broken in the initial and current phase of San Juan County's attempt to pave as many miles of the Chaco road (CR7950) as possible. We continue to investigate charges that the NMSHPO was not consulted as required by state law on the chip sealing of the first three miles. She may also have lacked proper consultation in the NEPA/NHPA process that covers the additional 13 miles. In addition, there are charges that the New Mexico Department of Transportation insured the Hopi and the Zuni that all applicable laws would be adhered to in the chip-sealing of the first three miles, and then failed to require San Juan County to consult with them or any of the tribes that claim cultural affiliation with Chaco as required by an Executive Order from the Governor. Lack of proper consultation continues to be a possible avenue of concern in the NHPA Cultural Resources Survey released in May 2009, as do questions pertaining to improper procedure, inaccurate documentation, conflict of interest, and segmentation. Still unanswered is the question of why this study has remained an EA instead of the more exhaustive Environmental Impact Study (EIS) since the threshold requirement of significant controversy has clearly already been met.