Archaeology Southwest issues statement on recent Notice of Dispute
sent to BLM Director Stone-Manning
John R. Welch, Bill Doelle, Skylar Begay, and Ashleigh Thompson
Tucson, Ariz. (August 15, 2023)—On August 4, 2023, Archaeology Southwest, the Tohono O’odham Nation, and the San Carlos Apache Tribe advised the US Bureau of Land Management (BLM), via a jointly submitted Notice of Dispute, of its failures to complete the historic property identification and Tribal Consultation processes required to move forward with the SunZia Southwest Transmission Project.
Read the Notice of Dispute (opens as a PDF)
The Pattern Energy website states, “SunZia Transmission is a 550-mile ±525 kV high-voltage direct current (HVDC) transmission line between central New Mexico and south-central Arizona, with the capacity to transport 3,000 MW of clean, renewable energy.” Further, “SunZia Transmission is setting a precedent with a gold standard in environmental mitigation.”
What neither the BLM nor the Pattern Energy sponsor will say is that the power line should have never been routed through the San Pedro valley in the first place. We think the “gold standard” in environmental stewardship must be reserved for projects that avoid unnecessary impacts, not those that excel in mitigating unnecessary impacts when at least one good alternative is available.
For more than a decade, we have worked hard to show the BLM and the SunZia sponsor exactly how to avoid damage to lands and communities. The jointly submitted Notice of Dispute follows 14 long years of substantive meetings and detailed letters. The August 27, 2009, letter signed by Bill Doelle and representatives of the National Trust for Historic Preservation makes clear the organizations’ support for “generation and transmission of renewable energy.” The 2009 letter also urges the BLM to initiate consultations to address SunZia’s likely impacts to “Native American traditional cultural properties and sacred places… and unparalleled landscapes of human history located within the proposed project area.” The letter includes an urgent call for a “comprehensive renewable energy development plan [for the Southwest to identify] opportunities to co-locate transmission facilities and, thus, eliminate the need for new rights-of-way.”
Instead of dodging most impacts by co-locating the transmission line within an existing corridor (along I-10 and/or US Highway 70), BLM and the SunZia sponsor committed to plans for a new industrial corridor through the sensitive natural and cultural landscapes of the San Pedro River valley north of Benson. The San Carlos Apache Tribe’s August 22, 2012, letter objects to “the discontinuation of meaningful consultation with the Tribe’s representatives and department managers” and to the San Pedro valley as the route for SunZia. The letter clearly requests that BLM and SunZia respect the sensitivity of “Apache cultural sites, sacred areas, and plant-gathering areas.”
Inadequate consultation, disregard for the Tribes’ and Nations’ repeated objections, and failures to investigate the presence of Holy Places and other highly sensitive areas compromised by the new right-of-way led to formal protests. The Tohono O’odham Nation’s March 16, 2023, letter states, “All of the evidence for the significance of the San Pedro Valley Traditional Cultural Landscape to the Tohono O’odham Nation and other Tribes has been largely ignored by the Bureau of Land Management.”
San Carlos Apache Tribe Chairman Terry Rambler’s March 9, 2023, letter states: “The Tribe is especially concerned about the highly intrusive, all-new transmission corridor through the San Pedro Valley from Benson to San Manuel. This Valley…one of the ‘Last Great Places’ in America, is the fragile core for the largest expanse of unfragmented land in the Southwest, an area that includes the southern half of the San Carlos Apache Reservation. At least as importantly, the Valley is the home to more than 60 landforms named and remembered in our Apache language. The Valley also hosts thousands of localities having religious, cultural, historical, and archaeological importance to Apache, O’odham, Hopi, and Zuni peoples.”
The BLM’s reply to these heartfelt and thoughtful objections was terse: “the BLM New Mexico State Director followed the applicable laws, regulations, and policies and considered all relevant resource information and public input. …[Y]our protest is denied.”
We can agree with the Wall Street Journal that the 17 years the BLM took to approve the SunZia project “shows why the permitting process should be overhauled,” but only because the BLM failed to listen to Tribes and to confirm that public benefits outweigh the massive and irrevocable costs. We cannot, as some nonprofit organizations have, celebrate “good impact mitigation” when avoidance remains the responsible alternative. We cannot condone the desecration of Tribal cultural resources and the repeated decimation of public land values. We cannot support a project that delivers energy to metropolitan areas and corporate profits by degrading rural landscapes and trampling on Indigenous territories.
Unless and until the BLM and the SunZia sponsor decide to follow the National Historic Preservation Act and other rules requiring meaningful consultations with Native American Tribes and Nations, we are obliged by our consciences and by Archaeology Southwest’s mission and Model for Tribal Collaboration to use all lawful means to defend the San Pedro valley and its unique, diverse, and extraordinary values.
Read the Notice of Dispute (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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