Archaeology Southwest Submits Formal Comments on USBLM’s Proposed Rule

Tucson, Ariz. (June 29, 2023)—Yesterday, Archaeology Southwest submitted formal comments on the Bureau of Land Management’s (BLM) Proposed Federal Land Policy and Management Act of 1976 Regulations on Conservation and Landscape Health (“Proposed Rule,” from 88 Fed. Reg. 19583-19604, April 3. 2023).

Read our formal comments (opens as a PDF)

Specifically, Archaeology Southwest endorses all elements of the Proposed Rule that advance the following five essential principles for BLM decisions:

(a) Place conservation on par with other land and resource uses in BLM decision-making;

(b) Enable conservation leases and otherwise recognize the market values of high-integrity cultural and natural resources;

(c) Clarify and elevate the roles of areas of critical environmental concern (“ACECs”) by guiding BLM to conserve intact landscapes and manage ACECs for ecosystem resilience;

(d) Clarify and elevate the concept of “land health” in planning and analyses of land use and resource management actions and alternatives (not just grazing lease assessments);

(e) Empower Tribes to lead, inform, and participate directly in the conservation and stewardship of ACECs and other culturally important lands and waters.

“Indigenous Peoples’ values, interests, preferences, and knowledge—which have all been systematically excluded from most previous consideration in the management of public lands—are now required and desired complements to non-Indigenous ways of learning and managing,” noted John R. Welch, Director of Archaeology Southwest’s Landscape and Site Preservation Program. “In our view, the Final Rule should carefully and consistently optimize opportunities for Tribes’ duly designated officials to play roles in BLM operations and decisions that are commensurate with the Tribes’ values, interests, preferences, and knowledge.”

Other signatories on the letter to BLM Director Tracey Stone-Manning include Bill Doelle (President & CEO), Ashleigh Thompson (Director, Tribal Collaboration in Research & Education), Skylar Begay (Director, Tribal Collaboration in Outreach & Advocacy), Aaron M. Wright (Preservation Anthropologist), and Paul F. Reed (Preservation Archaeologist).

Archaeology Southwest supports and will continue to contribute directly to BLM and other efforts—Tribal, Federal, state, and community-based—to prioritize the health and resilience of ecosystems through the protection, rehabilitation, and restoration of public lands, most especially in and through alignment with the cultural resources, sacred sites, treaty rights, and other reserved rights of Indian Tribes.

Learn more about the proposed rule from the Conservation Lands Foundation here.

The comment period ends on July 5, 2023. Submit comments here (via Act Now for Public Lands) or here (BLM’s information and submission portal).

Read our formal comments (opens as a PDF)

About Archaeology Southwest

Founded in 1989, Archaeology Southwest is a private 501(c)(3) nonprofit organization based in Tucson, Arizona, on the homelands of the Tohono O’odham Nation and the Pascua Yaqui Tribe. We are privileged to work across the US Southwest and into northwestern Mexico on the Lands and Territories of many Indigenous Tribes and descendant communities. 

We practice Preservation Archaeology, a holistic and conservation-based approach to exploring and protecting heritage places while also honoring the diverse values these places hold for people. We gather information, help make it accessible and understandable, share it with the public and decision-makers, advocate for landscape-scale protection, and co-steward heritage preserves with people who share interests in their conservation. We are committed to real and ongoing collaboration with Tribes in all areas of our work. 

Learn more at archaeologysouthwest.org.

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