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To: Mike Blenden and Jay Slack (USFWS) David Neslin (COGCC), Senators Salazar and Allard, Governor Ritter, Representative Salazar, Robbie Roberts (EPA), Jim Martin ( Colorado DPHE) and Concerned Others

I write to express grave concern about the inadequacy of the Draft Environmental Assessment of Planned Gas and Oil Exploration of Baca National Wildlife Refuge (hereafter, EA). These concerns span a host of issues, including the likely deleterious environmental effects to the aquifer, wildlife habitat, air quality, and recreation. The assessment’s narrow frame fails to account for the numerous questions raised in the scoping period, and addresses a range of alternatives for more constricted than those actually open to the USFWS. Owing to my professional orientation as a cultural anthropologist, however, I will concentrate my elaboration of concerns in the areas of cultural and socioeconomic impacts.

Under my guidance, an advanced anthropology course on the topic of religion and ritual has spent the entire week of February 25-28, 2008 conducting an intensive, team-based investigation focused on place, religious practice and the potential effects of natural gas drilling. The group, comprised of 25 students, a paraprofessional and I, accomplished the following:

visited six religious communities and participated in their ceremonial observances;
convened two roundtables with environmental activists (4) and Crestone Spiritual Alliance representatives (12) respectively; and
conducted individual interviews with over forty long-term and recent-arrival residents, as well as several frequent attendees at retreats. .

This investigation yields the incontrovertible conclusion that the proposed exploratory natural gas drilling alone would have a devastating effect on the cultural and economic life of the residents in and surrounding the BNWR. The local culture is characterized by individuals who have actively sought out a remote location; many have done so for the express purpose of religious contemplation and meditation. Others who are not actively integrated into one of the over-twenty religious communities nonetheless express appreciation for the effects of their presence on the town, including the considerable business that retreat attendees and pilgrims to the area generate. Just two of our interviewees were positive about potential economic opportunities afforded by the drilling prospects, all others expected that the few jobs would not go to community members in the first place, while the effects of the drilling would devastate the retreat and tourist economies upon which most residents rely.

The key environmental supports enabling the cluster of religious communities to carry out their practices include silence, proximate wilderness and the presence of wildlife, a sizable, pristine water source in the aquifer, and stunning aesthetic views of the mountains. In our interviews we asked the following question: “Could you, or your community, realize your religious practices elsewhere – say in another pristine montaine setting in this region?” Answers here were categorically in the negative. For the area’s religious adherents, the distinctiveness of this setting goes beyond these visible characteristics, and is tied to their perceptions of physical properties resulting from the interaction between wind, subterranean water, sunlight and mountains in the area. Lakota Chief Arvol Looking Horse, for example, says that only here can wind pass unimpeded across a long, sunlit valley, over water, and then be thrust up by sharply uprising mountains, creating a field of energetic uplift not found elsewhere. The Venerable Dzigar Kongtrül Rinpoche said there is nowhere where the five elements recognized in Tibetan Buddhism combine in such rarified form in the free world (meaning, outside occupied Tibet) other than Crestone. Whether such statements are empirically verifiable in scientific terms at present is not the point. Rather, they constitute ethnographic facts, cultural charters that assert the unparalleled singularity of the locale as a sacred landscape for enabling meditation, ritual efficacy, and therapeutic work.

In my considered view as a cultural anthropologist, the BNWR crisis reveals a profound shortcoming in federal case law regarding places needful of protection against unacceptable cultural impacts. The 1978 American Indian Religious Freedom Act (AIRFA) has been widely criticized for inadequately protecting sacred sites, and the area around the BNWR is recognized not only by surrounding peoples – Ute, Apache, Navajo (Dineh), Hopi and other Pueblo peoples – as a longstanding, sacred neutral ground, but also by peoples further away, such as Cree, Lakota and Blackfoot. The fact that no native peoples historically claimed this area home territory, ironically, results from its sacred importance to multiple peoples; various sources suggested that American Indians found it too powerful a place in which to permanently reside. Beyond AIRFA, legal precedents of potential relevance include the National Historic Preservation Act of 1966, the “Sense of Place” argument that underpinned the moratorium on drilling in Montana’s Rocky Mountain Front, and the rejection of corporate constitutional rights as advanced by the Community Environmental Legal Defense Fund in Pennsylvania. No one of these measures, however, adequately accounts for the convergence of environmental and cultural characteristics found in the proximity of the BNWR, nor can adaptations or extensions of these be forwarded in time to avert the Lexum’s immanent plans.

Fortunately, the provisions of the National Environmental Policy Act (NEPA) alone support Environmental Impact Statement to be required (here I refer you to the letter written jointly by the San Luis Valley Citizens Alliance and the Citizens of the San Luis Valley that details this argument); the inadequacy of the Environmental Assessment performed by ENSR only reinforces this requirement.

In closing, I would speak as an educator and stress the importance of Colorado College’s Baca Campus in providing unmatched learning experiences for numerous programs, including place-based activities and research in cultural anthropology, archaeology, history, environmental studies, Southwest studies, and numerous others. We also use the campus as a site for faculty retreats and other events requiring distancing from campus. The disruptive effects of drilling, even if confined to the two exploratory wells in question, would irreparably compromise this valuable educational resource.