Oil-and-Gas Development in BLM’s Farmington Field Office

In response to increased oil-gas development, and in conjunction with the Navajo Area Office of the Bureau of Indian Affairs (BIA), the Farmington Field Office of the Bureau of Land Management (BLM) is in the process of amending the 2003 Resource Management Plan (RMP) and draft Environmental Impact Statement (EIS). As part of this process, a variety of Tribal, environmental, preservation, and advocacy groups have offered input and formal comments at various points. This process is projected to be completed by mid-to-late 2021.

Archaeology Southwest’s involvement in protecting the Greater Chaco Landscape dates to early 2014. At that time we were putting together the details necessary to hold a priority planning meeting for the Chaco and Middle San Juan region in Farmington, New Mexico. Our organization has completed these exercises in a number of BLM districts and other geographic locales around the American Southwest. In brief, the planning meetings gather local archaeologists, Tribal representatives, federal archaeologists, and other experts to identify those areas in a district or other locale that are of most concern for preservation. The meeting held in Farmington in May 2014 resulted in the identification of a number of areas that were of great concern to the people gathered. These areas were mapped and converted to GIS shape files and shared with Farmington BLM and other managing agencies in the hope that future development projects, particularly oil-gas related activities, could be managed to avoid impacts to these areas (see figure 16.2).

As we at Archaeology Southwest completed the priority planning exercise in mid-2014, we also made the decision to become involved in the RMP amendment process as an interested party. What followed over the next six years were numerous meetings with BLM, BIA, Tribal officials, state officials, and members of the public.

In 2015, Archaeology Southwest convened a series of public forums to discuss impacts to the Greater Chaco Landscape and get public input on the best approach to preservation and protection. I organized and chaired the events held at Crow Canyon Archaeological Center, Cortez, Colorado; at the University of New Mexico–Hibben Center; and at the main office of the National Congress of American Indians in Washington, DC. Panel members included then-governor Fred Vallo of Acoma Pueblo, Ora Marek-Martinez (Navajo Nation tribal historic preservation officer at the time), Tim Menchengo (of the Pueblo of Santa Ana), Dale Davidson (former BLM archaeologist in Utah), and David Fraley (private citizen in Cortez, Colorado). All of these events were well attended, and we gathered useful public input.

In 2016 Archaeology Southwest, with support from several partners, produced a handout brochure on the Greater Chaco Landscape (Archaeology Southwest 2016). The goal was to summarize the key issues for the general public and interested parties and make more information readily available. We distributed thousands of brochures between 2016 and 2018 and have increased awareness of the issue and the choices before the American public as oil-gas development continues to threaten Greater Chaco and other fragile ancient landscapes.

Following on the heels of the NPS-sponsored conference at Crow Canyon, of which this volume is one product, Archaeology Southwest organized a telephone press conference with media to discuss concerns about protecting the Greater Chaco Landscape (Reed et al. 2017). This event generated nationwide interest and resulted in articles in major newspapers (e.g., the Washington Post). A group of scholars and advocates wrote short essays highlighting their research and concerns about oil-gas development across the Greater Chaco Landscape.

Detailed Feedback to the Agencies on Protecting the Greater Chaco Landscape

Archaeology Southwest and our partners—Audubon New Mexico, Coalition to Protect America’s Parks, Izaak Walton League, National Audubon Society, National Parks Conservation Association, National Trust for Historic Preservation, National Wildlife Federation, New Mexico Wilderness Alliance, New Mexico Wildlife Federation, the United States Committee for the International Council on Monuments and Sites, and the Wilderness Society—have provided detailed comments to BLM and BIA at various points over the last several years. Most recently, in September 2020, we prepared comprehensive comments during the final period of public review as the agencies finish the draft RMP amendment and EIS documents (Archaeology Southwest et al. 2020). Because of the importance of those planning documents for the protection of Chaco’s resources, below I reiterate, in some detail, the most relevant comments provided to the agencies in September 2020.

Discussion

The Greater Chaco Landscape includes Chaco Culture NHP and many cultural resources in the surrounding landscape that are affiliated with ancient Chaco, such as the Great North Road and Pierre’s Site. Over the years, the BLM has leased more than 91 percent of its managed landscape for oil and gas development (see figure 16.2). Together with our partners, and until we have legislation in place, we have asked the BLM and BIA to put in place a moratorium on future oil-gas leasing in a 10 mi. protection zone around Chaco Culture National Historical Park and to also ensure the protection of significant sites in the broader landscape, including the Pierre’s Community and other significant areas identified in Archaeology Southwest’s 2020 study (Reed 2020).

The All Pueblo Council of Governors (APCG) has spoken out on several occasions, issuing several resolutions calling on the BLM and BIA to work closely with Pueblo people while preparing this new plan (APCG 2014, 2015, 2016, 2017, 2018). The Pueblo governors also endorsed a series of measures that would go a long way toward protecting the magnificent cultural resources and modern-day residents of the Chaco area from oil and gas development, including supporting the 10 mi. protection zone around the park that would be off-limits to oil and gas development. Most recently, the APCG has partnered with the Navajo Nation in 2017 and 2019 to press the agencies for additional protections across the Greater Chaco Landscape (APCG 2017, 2018).

The National Congress of American Indians (NCAI 2017) passed a resolution in October 2017 calling on the Department of the Interior to issue a moratorium on all oil and gas permitting and leasing in the Greater Chaco Canyon Region to protect traditional cultural properties and sacred sites in the region until the BLM and BIA initiate and complete an ethnographic study of cultural landscapes across the Greater Chaco region and finish the management plan and Environmental Impact Statement (EIS). I support the NCAI’s resolution and amplify their call for a moratorium on new oil-gas development across Greater Chaco.

Many groups and individuals in New Mexico have worked tirelessly to support this process. US senators Udall and Heinrich and Congressman Ben Ray Lujan have played an instrumental role in working to find a solution to protect the Chaco Canyon area—recognizing that they must balance all of their constituents’ diverse interests. Moving forward, we will continue to need strong leadership from our elected representatives to see this process through.

Archaeology Southwest has continued intensive dialogue with BLM and BIA as they finalize the draft RMP amendment and EIS for the Greater Chaco Landscape. I feel strongly that the standard approach to cultural resource protection, as prescribed by Section 106 of the National Historic Preservation Act (NHPA) and other laws, is not working in this highly sensitive area. The Section 106 approach calls for cultural resources (historic and archaeological sites, traditional cultural places, and sacred sites) to be identified and then either avoided by construction activities or to have adverse impacts on resources mitigated through various measures. This approach has resulted in a highly dissected landscape that is crisscrossed by oil-gas roads and pipelines and various wells pads and other facilities (figure 16.6). These activities have severely impacted the ancient Chacoan landscape.

In 2018, Archaeology Southwest engaged researchers Richard Friedman and Sean Field to conduct analysis of the BLM-procured LiDAR data (and other remote sensing data) from 2016 (Reed, Friedman, and Field 2019). This project was supported by the Conservation Lands Foundation and focused primarily on oil-gas lease parcels from the BLM’s March 2018 sale, as well as the Bis sa’ani Chacoan Community located roughly 5 mi. northeast of Chaco. A variety of landscape features were identified by the analysts across the lease areas and in the Bis sa’ani Community area. Most were determined to be of modern or recent historic origin. Nonetheless, several features of possibly ancient, Chacoan origin were found (figure 16.7). Several landscape features were identified within the Bis sa’ani Community that line up with a road-related feature recorded during the late 1970s work (Breternitz et al. 1982). These features show evidence of relatively recent vehicular activity (used as a two-track road). However, given the match to the previously identified road segment, it seems likely they are part of a Chacoan road through the Bis sa’ani area. In several of the lease parcels, anomalous linear features were detected that do not appear to represent modern or historic phenomena. Additional fieldwork is necessary to confirm or refute the ancient origin of these features. Nevertheless, this limited LiDAR project makes clear the value of using these data to assess lease parcels across Greater Chaco (Reed, Friedman, and Field 2019).

Finally, Archaeology Southwest worked with the Pueblo of Acoma to complete a limited ethnographic study of a portion of the Greater Chaco Landscape in 2018 (Anschuetz et al. 2019). The project involved visits to Fajada Butte in Chaco Canyon (figure 16.8), sites along the Great North Road including Twin Angel’s Pueblo, Halfway House, and the Pierre’s Community, the Bis sa’ani Community northeast of Pueblo Bonito, Pueblo Pintado, oil-gas lease areas within the 10 mi. protection zone, and additional areas. Goals of the Acoma Project included having the Acoma team visit the landscapes of Greater Chaco that are threatened by development and collecting appropriate data to help inform BLM and BIA as they continue managing oil-gas development across the GCL. Project findings indicate the presence of Acoma TCPs and cultural landscapes that have not been previously identified or discussed.

Adding to my list of recommendations above, then, I encourage BLM and BIA to require oil-gas lease holders to use LiDAR and other remote sensing data that are currently available to assess tracts of land to be developed. This approach should complement more conventional archaeological work under Section 106 of the NHPA and reduce the risk of unidentified cultural resources being damaged or destroyed during oil-gas development. In addition, the preliminary findings of the Acoma Ethnographic Project make clear that the requirements of Section 106 of the NHPA and Bulletin 38 are not being adequately met with the standard, archaeological approach to fieldwork and reporting. It is critically important to get Native American teams into the field to document cultural resources prior to clearances being issued for oil-gas and other development across the Greater Chaco Landscape.

Conclusion

In summary, it is clear that the BLM and BIA should protect larger pieces of the remaining landscape, particularly areas surrounding Chacoan great house communities and areas identified by Native American Pueblos and Tribes as TCPs or sacred sites. With the advances in various technologies, as described in this volume by Ruth Van Dyke, Anna Sofaer and her colleagues, Carrie Heitman and Sean Field, and others, it is abundantly clear that archaeologists completing survey work prior to oil-gas development are not identifying all of the archaeological and cultural resources and phenomena on the landscape and that continuing with the current approaches to resource protection will result in losses of additional, undocumented cultural resources and further impacts to the Greater Chaco Landscape. Moreover, consistent with obligations under NHPA, NEPA, and related laws, the agencies must incorporate and utilize the significant new information about the Greater Chaco Landscape that has been generated internally and provided to them by the Tribal and archaeological communities. The Acoma Ethnographic Project recently completed (Anschuetz et al. 2019) amply demonstrates the need for Native American experts to identify their own cultural resources in the field, prior to development. The use of LiDAR and other remote sensing data should be required of all oil-gas developers prior to any ground-disturbing activities. Lastly, with funding finally in place for two cultural-ethnographic studies by Tribes, we ask the agencies to delay finalization of the RMPA and EIS documents until preliminary results from this very important work can be incorporated into the planning documents.

Acknowledgments

I would like to thank Ruth Van Dyke, Carrie Heitman, and Steve Lekson for organizing and convening the 2017 Chaco Landscapes meeting at Crow Canyon Archaeological Center. Ruth and Carrie also deserve thanks for working so hard to assemble this volume. I want to thank Archaeology Southwest’s closest partners over the last six years: The Wilderness Society, the National Trust for Historic Preservation, National Parks and Conservation Association, and the New Mexico Wilderness Alliance, as well as more recent partners Conservation Lands Foundation and Pew Charitable Trusts. I want to acknowledge the expertise and efforts of the Pueblo of Acoma team and advisory board members who worked on the Acoma Ethnographic Project in 2018. The sustained efforts of the All-Pueblo Council of Governors over the last few years have helped bring national attention to the impacts faced by Greater Chaco, and I thank all the Pueblo governors and APCG staff. Last, I am gratified that the Navajo Nation has partnered with APCG to protect the Greater Chaco Landscape. The importance of Native American leadership in this process cannot be overstated.

References