The Chaco Alliance formed in 2006 in opposition to an attempt to chip seal the main road into Chaco (CR 7950) without any impact studies that would protect Chaco Culture National Historical Park (CCNHP), or the archeological sites in and along the road. The Chaco Alliance organized the initial meeting with the Federal Highway Administration (FHWA) in late August of 2006, and we were the sole citizens' group personally represented at that meeting. Although the FHWA initially planned to grant a Categorical Exclusion to the project, preventing all analysis of impacts, the FHWA agreed to place the road improvement project under National Environmental Policy Act (NEPA) and National Historic Preservation Act (NHPA) law.
It was the Chaco Alliance's position from the start that the improvements to the road were primarily driven by an attempt to open up better and easier access for economic development. Within a few years, the BLM would offer thousands of acres near the park for lease to the oil and gas industry. Also from the start, we supported improvements to the road short of chip sealing and under the protections of NHPA. Studies showed that chip sealing could dramatically increase visitation to the park, overwhelming the fragile ecosystem as well as putting infrastructure and archeological sites at risk. We demanded proper procedure and proper consultation, especially with the tribes. San Juan County had letters from both the Hopi Tribe and the Pueblo of Zuni asking for consultation before the initial work on the first three miles of road began in 2006. To our knowledge, they were not consulted.
In 2007 the Chaco Alliance was part of a coalition of groups that stopped Cimerax from putting wells on state land just below the border of the park, south of Fajada Butte. In 2009 the Chaco Alliance alerted the Hopi Preservation Department that the BLM intended to offer for lease almost 10,000 acres of land just outside the park. In October 2009, the BLM withdrew its lease proposal thanks primarily to the efforts of the Hopi, working in concert with the Chaco Alliance, San Juan Citizens Alliance, and the National Trust for Historic Preservation. The Director of the Hopi Cultural Preservation Office wrote to the BLM: "Because the Hopi Tribe and other Pueblo tribes have not been consulted, appropriate consultations have not been concluded…Therefore we protest this lease sale and request that it be canceled or postponed until appropriate consultations have been concluded." In early 2010 the Chaco Alliance and San Juan Citizens Alliance were granted consulting party status under Section 106 of NHPA for all oil and gas leasing within ten miles of Chaco. The Hopi, Navajo Nation, and the New Mexico State Historic Preservation division unanimously agreed to offer consulting party status to both groups.
In October of 2010 the Chaco Alliance, San Juan Citizens Alliance, and National Trust submitted a Master Leasing Plan designed to protect both the park and nearby landscape. It was summarily rejected, as was another 2013 Administrative Petition submitted by the Chaco Alliance, Wild Earth Guardians, San Juan Citizens Alliance, Society for American Archeology, and the New Mexico Archeological Council to declare an Area Of Critical Environmental Concern (ACEC) around the park. The petition to declare the park and the Greater Chaco Landscape an ACEC was supported by both the Hopi and the Navajo Nation. These two early efforts, although denied, and years of meetings and discussion with the BLM, informed and foreshadowed the current effort to restrict fracking on federal land within ten miles of the park. The Hopi Tribe wrote to the BLM in 2013: "We have repeatedly stated that oil and gas leasing and development on FDO lands surrounding Chaco threaten the Park and the Greater Chaco Landscape. We have reiterated that the co-mingling of energy development and resource protection around Chaco will inevitably lead to adverse effects to cultural resources significant to the Hopi Tribe. We have consulted with the FDO and parties including the National Trust, Chaco Alliance, and the San Juan Citizens Alliance regarding the development and implementation of a permanent plan for preserving the landscape surrounding Chaco."
As the BLM continued to propose leasing more parcels and was met with opposition, San Juan County continued to pursue its desire to chip seal the road. Surprisingly, in 2012 San Juan County agreed to a stabilized aggregate alternative as a compromise in the Chaco Road improvement NEPA/NHPA process. But in late 2012 they reversed course and decided to abandon the project altogether. SJ County renewed its focus in 2014 and chose to improve the road using the stabilized aggregate alternative they had agreed to in their 2012 compromise, but without doing consultation or mitigation for the six sites in and along the roadway. In August 2014, the Hopi Tribe wrote that they "share the Chaco Alliance's concerns that improvements have been or are about to be made to CR7950 without consultation or compliance." The Chaco Alliance was in frequent communication with the Hopi, the New Mexico State Historic Preservation Office, BLM, and the Advisory Council on Historic Preservation about proper permitting procedure, questionable Right of Way claims, and lacking tribal consultation. The source of the funding for the 2014 8.21 mile road improvement is not clear, but it does not appear to be federal.
In 2013 the BLM attempted a larger offering of almost 19,000 acres for oil and gas leasing in the greater Chaco landscape.This massive lease sale was prevented by the on-going opposition of the Hopi, in concert with the Chaco Alliance and the groups mentioned above as well as others. Although many of the parcels were deferred, we continued to call for permanent protection. Our 2013 ACEC petition referenced above would have done just that. It was rejected in 2014. In 2014 the BLM moved ahead with an attempt to open over four million acres of land for full field development of gas and oil by preparing a Resource Management Plan Amendment and Environmental Impact Statement to address issues relating to oil and gas development which were unplanned for in the 2003 management plan. We have been a consulting party to the Mancos Shale RMPA and related EIS since 2014. We were also a consulting party to the now defunct 2014 Saddle Butte Pinon Pipeline Project. Since 2015 numerous attempts have been made to offer more acreage near CCNHP and in the greater Chaco landscape for lease to the oil and gas industry. Many of these leasing attempts have been deferred or withdrawn because of growing demands for meaningful consultation and expanding, organized indigenous opposition.
We continue to believe that energy development is incompatible with cultural resource protection. We have called for many years for a moratorium on all new drilling in the greater Chaco landscape until a new Regional Management Plan has been adopted. The Chaco Alliance has been a member of the Greater Chaco Coalition since 2015. In 2018, the Chaco Alliance along with the San Juan Citizens Alliance, Wild Earth Guardians, Western Environmental Law Center, and others submitted scoping comments opposing the BLM's scheduled December 2018 lease sale of thousands of acres near Chaco, some within ten miles of the park. In September of 2020, the Chaco Alliance along with the San Juan Citizens Alliance, Wild Earth Guardians, Western Environmental Law Center, Pueblo Action Alliance, Diné Citizens Against Ruining Our Environment, and others submitted over 150 pages of comments on the Draft RMPA/ EIS. In 2022, along with Western Environmental Law Center, San Juan Citizens Alliance, Wild Earth Guardians and others, we submitted extensive comments on the Chaco Withdrawal Environment Assessment proposed by Secretary Haaland and the Department of the Interior. We have long supported a ten mile buffer zone around the park as well as any federal legislation that would permanently protect the park, the impacted local communities, and the greater Chaco landscape. We have long demanded environmental justice, an end to the sacrifice zone mentality that has created an industrialized landscape that threatens communities and sacred sites.
Chaco Culture NHP in North-Central New Mexico is a very special place. It was inhabited for many hundreds of years and its culture peaked a millennium ago — before that of the more widely known Mesa Verde site.
Chaco at sunset from NPS housing.
Rock art on the Peñasco Blanco trail. Peñasco Blanco is an unexcavated great house.
Fajada Butte, home of the Sun Dagger site.
Navajo for "clay in place", Bis sa'ani is a 35-room ancestral Puebloan great house and archeological site located 8 miles from Pueblo Bonito.
All the road needs is routine maintenance.
We don't need more fossil fuels
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.
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 (email@example.com) 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.
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.
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
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:
Mail: Scott Hall, BLM
6251 College Blvd., Suite A
Farmington, NM 87402
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 firstname.lastname@example.org.
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.
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
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.
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: (email@example.com), or at a newly added address: (firstname.lastname@example.org). 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.
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: