SHA Government Affairs Newsletter – February 2020

SHA Government Affairs Newsletter – February 2020

CEQ Issues Proposed Changes to the National Environmental Policy Act (NEPA)

The Council on Environmental Quality (CEQ) released its proposed changes to the regulations implementing NEPA and opened a 60-day comment period, which ended on March 10th. Upon reading the proposed changes to NEPA, the SHA and the Coalition for American Heritage grew very concerned that, if these changes are made, they would dramatically reduce consideration of cultural resources on infrastructure projects.

Given that these changes are the first major revision of NEPA regulations in 40 years, we had a very short window of opportunity to make our case for protecting cultural resources in this process. Only two public hearings were scheduled across the nation. Belatedly, CEQ invited tribes to a hearing, but provided only two weeks-notice prior to the event. With so few opportunities for the public to weigh in on these major changes, comment letters were vital to ensuring due consideration of historic resources.

By law, CEQ is required to consider all the comment letters that it receives on the proposed changes. Furthermore, the agency is required to respond to all comments in the final regulation, whether or not they accept the suggestion. The agency must explain its rationale for incorporating a comment or not. If the agency ignores evidence presented during the comment period, it can be challenged in court.

The Coalition for American Heritage Rallies Responses to NEPA Changes

The Coalition for American Heritage prepared a detailed letter to CEQ outlining our concerns. We also provided training and sample comment letters to advocates across the nation who used our materials to send their own, individual letters to CEQ. The Coalition’s no-cost webinar explained the specific effects that the changes to NEPA would have on cultural resources. Along with the sample letters on the Coalition site, the webinar empowered our members, who are subject-matter experts with important knowledge to share.

The agency comment period is not the only opportunity to speak out on this important topic. Please, see the Coalition web site for tips on how to send a letter to your Congressional delegation. Ask your Representative to cosponsor H Con Res 89, a bill urging the Trump Administration not to proceed with the proposed changes to NEPA. Through your letters and outreach to Congress, you can demonstrate that the public supports the important protections that NEPA provides.

Potential Damage to Underwater Military Heritage Sites

SHA and the Coalition for American Heritage are concerned about the implications of reviving the Navy Trade and Exchange Program. We wrote to the Director of Naval History and Heritage Command about the current plan of action and how it could adversely impact the nation’s historic resources and military heritage sites.

We asked that that the Trade and Exchange policy, if implemented, be revised to limit and further define important terms in the policy, and to create clear steps to preserve archaeological information and follow common professional ethics in the archaeological community. Click here for a full copy of our letter.

Coalition Decries Damage to Cultural Resources Caused By Border Wall Construction

As news stories revealed the federal government’s use of explosive materials for rock removal, harm to burial grounds, and failure to consult the local tribe on border wall construction at Organ Pipe Cactus National Monument, the Coalition released a statement on the destruction of cultural resources along the U.S.-Mexico border. We urged the federal government to abide by existing processes to ensure that federal agencies weigh the effects their actions will have on cultural resources, including: tribal lands, burial grounds, artifacts, and other cultural treasures.

We commended Rep. Raul Grijalva, Chairman of the House Natural Resources Committee, for his decision to hold a public hearing on this issue, giving the Tohono O’odham Nation, and other key stakeholders, an opportunity to air their concerns. It is our hope that incidents like this one will serve as powerful testimony about the need for laws that give all stakeholders a voice in development decisions.

How You Can Get Involved

For additional information on our advocacy efforts, please sign up for email alerts from the Coalition for American Heritage at https://heritagecoalition.org/for-individuals/ and follow the Coalition on Facebook at @heritagecoalition. You’ll get Calls to Action with sample scripts for emailing/calling your Member of Congress. You will also receive information on how to send a comment letter to federal agencies and examples of what you may choose to say.

Also, please consider joining SHA’s Government Affairs Committee! Given increasing threats (to both terrestrial and underwater sites) from the current Administration, your involvement is critical. If interested, please contact Terry Klein at tklein@srifoundation.org or Marion Werkheiser (marion@culturalheritagepartners.com). We look forward to working alongside you to advance the protection of our historical archaeological heritage!