29 July 26
Chaco Canyon Public Comment
I have started the practice of submitting public comments on contentious agency proposals, as I shared earlier with my comment on proposed changes by the Office of Management and Budget to the federal funding process . Yesterday I submitted another comment, this time on a plan by the Bureau of Land Management to revoke protections adopted during the Biden administration for a 10-mile buffer surrounding Chaco Culture National Historical Park in New Mexico. This plan would open this area to oil, gas, and mineral extraction. Here is a good overview of the controversy.
As I did with the OMB proposal, I am sharing the text of my comment below.
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I strongly oppose the proposed revocation of Public Land Order 7923, the public lands withdrawal surrounding Chaco Culture National Historical Park. This proposed revocation is described in the July 2026 BLM environmental assessment document DOI-BLM-NM-F010-2026-0002-EA, hereafter referred to as the BLM document.
The Chaco Canyon landscape is a UNESCO World Heritage Site. It has outstanding cultural and natural value to humanity as a whole. It is one of only 23 such sites in the United States. In 1972 the United States was the first to ratify the international treaty to preserve such sites for humanity. The Chaco Canyon cultural landscape extends well beyond the boundaries of the National Historical Park (NHP). It is a landscape sacred to the Pueblo peoples who live in the area. According to the BLM document, there are at least 145 traditional cultural properties including 9 great houses within the 10 mile buffer surrounding the NHP.
The BLM document itself states that “the Pueblo tribes view the Chacoan landscape as an integrated cultural system spanning northwest New Mexico and beyond, not a collection of isolated sites. They see its network of roads and interconnected communities as reflective of a society that thrived through regional connections rather than isolation…Maintaining this landscape is considered important by the Pueblo tribes for its cultural and historical integrity.” (Page 28).
The proposed revocation has been a travesty of public process. In April 2026 BLM opened a public scoping period for only seven days. This was entirely online with no in-person meetings. Despite the short window, BLM received over 100,000 comments, but Appendix E of the BLM document intentionally omits any summary of the content of these comments. The window to comment on the present BLM document is almost as short, only 14 days.
This dismissal of public input contrasts strikingly with the process that led to the issuance of PLO 7923 in 2023, which took a year-and-a-half with eight public meetings and a 120-day public comment period which elicited over 110,000 comments, all of which followed a decade of public engagement by Tribal groups such as the All Pueblo Council of Governors.
There is no justification in the BLM document for overturning this extended public process that led to the creation of PLO 7923, other than referring vaguely to the executive orders EO 14241 and SO 3418. By the analysis presented in the BLM document, the economic benefits of oil, gas, and mineral development within the NHP 10-mile buffer would be extremely modest. The analysis estimates that only 14 jobs would be created across the four county region over a twenty-year period.
But the BLM document fails to analyze possible economic losses to the region that might result from reduced visitation to Chaco Culture NHP as a result of destruction of the buffer lands. As an example, Chaco Culture NHP is renowned as a dark sky site for public astronomy. (See the Chaco Culture NHP webpage at https://www.nps.gov/chcu/planyourvisit/nightsky.htm.) The BLM document acknowledges (Appendix C, AIB-11) the potential for increased sky glow as a result of development of the buffer zone. Brighter skies means less reason for amateur astronomers to visit the NHP. More generally, the failure to study impacts to the recreational economy of the region as a result of buffer zone development is a substantial weakness of the BLM economic analysis.
The cultural landscape surrounding Chaco Canyon dating back at least 1200 years is a treasure for all Americans. Any development in the vicinity would irrevocably disrupt the integrity of the landscape, all for a few dollars worth of energy resources seized in an unethical affront to the public engagement process. I urge BLM to keep Public Land Order 7923 as it stands.
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