Thursday, September 24, 2015

Havasupai Environmental and other Studies 1974-9

This round-up of Havasupai-related documents brings to a close my recounting of the studies ordered by the 1975 Enlargement Act.
 In review: The Suitability Study saved some of the old Monument lands for the Park. The Wilderness Study produced an excellent recommendation that was suppressed due to lobbying by motorized commercial river companies. The Adjacent Lands Study produced a deftly emasculated bureaucratic report that, completed in the early Reagan-Watt years, was disappeared. The Secretarial Land Use Plan for the Havasupai was approved, but no sign of monitoring or evaluation has appeared to indicate its success or relevance for the Havasupai today and in the future.
   As to whether the Act itself successfully altered the course of NPS administration of the Park, I have my doubts, and it would be a subject worth, as with the Havasupai Reservation enlargement, a full-fledged evaluation with public discussion. Breaths should not be held, but the agenda for future action is a full one.

As the period of congressional decision-making on repatriating land to the Havasupai was reaching its climax, in the summer of 1974, a document appeared that delighted opponents. 

The Arizona Governor's office of Economic Planning & Development had prepared a draft for a Havasupai Comprehensive Plan that summer. Never finalized or approved by the Havasupai, it was another in a long line of "outside" efforts; as its introduction said, the last decade had seen six studies on various aspects of Havasupai life. It was an earnest and often detailed effort. Most relevantly for repatriation's enemies, it included a common-sense BIA evaluation for bringing to the existing reservation a power line, an aerial freight/passenger tramway, and a jeep-truck trail into the canyon. Deemed feasible, these projects together provided ammunition to Havasupai opponents arguing that this precious part of the Grand Canyon would be industrialized and desecrated should the Havasupai get hold of more of it. 

Repudiated, the study apparently never reached any final form. In any case, these "outsiders" concentrated on the existing reservation and grazing allotments. Probably it served to shape more what the Secretarial Land Use Plan would not look like and include than it helped the Havasupai-BIA team in its plan preparation of early 1975. It does, however, provide some  baseline documentation that could supplement the Secretarial Plan Environmental Impact Statement. 

There were population and employment statistics and descriptive details, including two pages on packing. It carried forward recommendations  of a 1963 tourism study, including a new lodge, Hilltop improvements, and that tramway for residents and visitors. Typically, there was a "survey" to "ascertain intimately" Havasupai attitudes toward socio-economic improvements. (The contrast is striking between the rhetoric of this survey by an outside agency and that of the Secretarial, Havasupai-driven, Land Use Plan.) The idea of a road &/or tramway was highlighted as "MOST RESENTED" by Havasupai surveyed. 

Three reports by Martin Goodfriend --1967, 1969, 1972-- were summarized for problems and solutions, and provide more baseline information. The state report, based on their "numerous visits…lasting for a number of days", derived "the goals of the people". (No surprise, the most important was repatriating their land.)

The General Plan section covered transportation (access from I-40 & the Willaha road), electric power, education, and a tramway (to be determined by the Havasupai). A long section had much detailed analysis and then recommendations on various aspects of tourism, including discussion of Hilltop, Long Mesa, & Topacoba. (Their analysis, however, was based on the pre-1975 reservation.) Housing in Supai was discussed in detail, as was sewerage and solid waste disposal. 

This draft report, as presented to the Havasupai on 30 Aug 1974, concluded with recommendations for implementation by themselves with the aid of several agencies. What is most strikingly different from the Secretarial Land Use Plan is not the various ideas and projects, but the language, the stance & attitude, of the authors. The outsiders, earnest and outwardly deferential, present problems and solutions. The Havasupai, in the Secretarial Plan, skip the deference and proclaim their values and "intention of being guided by their traditional concepts of harmony with all life." 

Doing It Themselves

As stated by Hirst some years later (see below), the first written Land Use Plan by the Havasupai was drawn up (perhaps by what was called the Working Group, or maybe even fewer participants) in the first three months of 1975, and not changed substantially during the EIS preparation and public consideration over the next six years. [Though I have argued that this makes it even more a product of a time of battle & triumph, and the arguments used therein. So now might be a good time to review, consider fully, and evaluate this 40-year-old work?)

In any case, toward the end of 1975, and perhaps with the hope of avoiding the work of a full EIS, the BIA's Truxton Cañon Agency prepared an Environmental Assessment. It is a confounding document, and may well have encouraged BIA superiors to do an EIS. 

The EA starts off with the statement that Havasupai concepts will be their guide and that the Tribe is the authority. That settled, there follows a pleasantly even-handed organization chart:

Fourteen actions are contemplated as follows:
Revegetation, Roads & Trails, Telephone, Waste Management, Energy, Support Facilities, Water, Agriculture, Grazing, Visitation, Wildlife Management, Residence, Culture, Law Enforcement. 

Here is a sample of the EA's to-and-fro style: Revegetation would improve the range so the economy could produce more. But it is limited by soil and moisture. Further, no date was set to start; there are no funds; study is needed. Still, the law intended there be increased Havasupai well-being from grazing. 

The Topacoba road will be paved; it is not included on any BIA plans. Neither funding nor timetable for roads & trails is scheduled. There is no timetable for communication improvements.
Need for support facilities is over 20 years away as there is no schedule for residences and the total using the upper reservation will be minimal because of the population base, dependent on water being available.  
Pooled underground water will be tapped judiciously by deep wells. Existing springs and water flow will not be significantly interfered with. 
The first family will commence living and gardening (on the upper reservation?) upon plan approval. 
Grazing is a continuing use, to be expanded by management and revegetation programs to improve Havasupai well-being. However, development will be gradual due to its "enormity", lack of feasibility, and "the unstructured management of this economy".
Public access to the Use Area (in the Park) will be on routes mutually agreed upon by Havasupai and Interior; but Great Thumb Deer Trail will be the only upper reservation access to lands below the rim. 
Tourist expansion is for Havasupai well-being; extensive facilities development depends on water, roads, funds, and will be gradual. 
The 1975 Act allowed use of the upper reservation for Havasupai economic & social betterment. There is no timetable for the needed water, roads, energy, and public facilities. "But it is certain the first familiies will occupy the upper reservation soon after the (plan's) approval."

Reading it now, on the one hand, the authors rushed into putting out their plan; on the other, it is hand-waving and avoiding commitment and requests for others' commitment. One might think, perhaps uncharitably, that after all those centuries and decades of experience with this country, the Havasupai could have taken the time to consult among themselves and come up with ways they found suitable to improve "economic and social well-being".

The assessment then described the current environment, using the language of the past years of deprivation and confinement, winding up with the describing the probable future without the plan as: 1)having no range improvement; 2) no improved trails and roads meaning a limited tourism industry, unsatisfied residential needs, and continuing problems from dust. 3) Without being able to use the upper reservation, the Havasupai would continue to be confined to Supai with all its problems or will have to move.

Assessment of the Plan's future environmental impact starts out noting there is no provision for monetary implementation. Within the plan, there is no "apparent change of economic conditions or major change in economic life style". NPS and the Forest Service had more funds to carry the burdens of the area than the Havasupai will. 
Consequently, there is no support for revegetation. When future road work or electricity installation is decided upon, there can be an assessment. Only if there is an expansion of air traffic will an assessment be needed. Since the Havasupai love the land and its beauty, there will be no need to consult with the Secretary about landfill sites. Support facilities can be assessed if they are ever specified. The Plan does not change the Act's intent on any of these possibilities. Placing a maximum of 60 homes, if scattered, on the plateau will not have a significant environmental impact. If clusters develop, their impact can be assessed. 

There is limited economic feasibility and fund availability for water developments, so assessment can be done later. Gardening is a continuing use, although "partially interrupted by decades of interference." Grazing is already governed by the Havasupai Charter, and anyway the plan does not detail reseeding, tillage or corral construction. 

In short, the assessment was that there was nothing to assess.

By control over numbers and access, the Plan should heighten visitor enjoyment, preserve the environment. and better control Havasupai economics.

The current controls on the plan preclude the need for other mitigating measures, and public meetings have not indicated a need for a full EIS. 

Havasupai short-term uses are designed to protect long-term values.

Legislation could change some of the controls & prohibitions in the 1975 Act. Mining water could be an irreversible commitment. 

As for alternatives, "the proposed plan contemplates a transition, unencumbered by preciseness, timetables, and economic goals; it allows for the community's culture to determine whether the traditional uses will be totally re-employed or whether the best of both historical cultures will be employed to create a living, growing culture (that will give the Havasupai) the social, economic, and cultural improvements contemplated by the Act."

One alternative would be to plan precisely, survey in depth present uses, and totally inventory existant (sic) resources, followed by economic evaluations, management plans, and funding determination.  "We cannot justify an in-depth inventory of an OBVIOUSLY HARSH, BARREN, UNPRODUCTIVE LAND BASE just to utilize the malleable, semi-productive, usable portion." (my bold)
Or there could be precise plans for each area in the plan to be supported by federal agencies' funding. This would be more responsible, but we think Congress wanted a general plan first, with normal review of future development when the need arises. 

So neither an "as is" choice nor a finely detailed course fulfills the Act's mandate as appropriately as does our proposal. And once the Secretarial plan is approved, we can proceed with establishing priorities.

In considering comments on the plan, the NPS call for more coordination was rejected. NPS was told Havasupai respect for bighorn was greater than NPS'. I was told I was more concerned about the Park Service than the Havasupai, which wasnt what I said, but the misinterpretation was a good indication of the mind-set of the Assessment's "Working Group".
In another reply, it stated that mechanical lifts had been ignored "for reasons expedient to the community", although a potential airstrip in Pasture Wash was allowed.
The statement was reaffirmed that a timetable and priorities would be established after plan approval. 

The local BIA official on 23 Feb 1976 signed a declaration that this Assessment was enough, since the Plan was not a major federal action affecting the environment.
Fortunately that opinion was countermanded, and the BIA moved into the EIS process.

Finally, some tidbits from the EIS

The EIS was researched and written by Arid Lands staff at the University of Arizona, providing what might be called the "standard" evaluation of the Reservation and its population as of the mid-1970's. It does mix in analysis and evaluation of the old Reservation with the added lands with respect to farming and tourism, for instance on II 38-42 (the notation means pages 38-42 in section II).

The EIS provides a better area map:

I 20f: Strongly stresses that the Plan is proposed, a statement of intent, not of operations. The Plan avoids specific locations and time guidelines. It is flexible. 

II 4: Most of the addition, up on the plateau is quiet; in Havasu, near the falls, there is noise from aircraft and visitors. 

It describes the environment (under "cultural resources" II 46) as consisting "of ridges (house location), washes and flats (agricultural locations), sporadic water sources (springs, checkdams, and winter snow), plant associations in both washes and flats containing edible species, and numerous small and large game animals which were undoubtedly more abundant in aboriginal times. The area was well-sited to a hunting and gathering economy".

The history of surveys of the archeological resources is summarized (II 51): 30 years of study show the Cohonina Branch 700-1100's A.D. occupied the area ranged over later by the Havasupai.
The report stresses how much basic information is lacking (II 58-9).

Bighorn sheep seem not to use the Added Lands, though they are well-established in that part of the Park marked out as the Havasupai Use Area, from the rim area down to the river. Feral burro appear not to have settled on the Added Lands (II 79).

The impacts (III 29ff) of the proposed grazing plan and possible ("marginal") farming  would, because they were to be restricted to the area's "carrying capacity", be without "measurable average deleterious effects". Damage to vegetation would be kept to a "negligible minimum". Throughout, the evaluations of impacts are based on the stated ideals of the Havasupai that underlie the plan, since no detailed actions were set forth. These ideals stand in contrast to the description of the existing plateau that depicts a harsh environment resulting from both long-term aridity and the past century's difficult conditions. The unknowable contrast would be with an environment existing had the original Reservation been established to include these plateau lands -- still arid, but a place where the Havasupai could have continued living as they had for the centuries before 1880 (or better, 1800 -- no ranchers, no cattle or sheep).

The optimism of the planners and EIS writers appears (IV 2) under mitigating measures: "The plan has been carefully thought through and the specific proposals (are) designed to improve, rather than harm, the environment and its native flora and fauna." And (V 1), "if the plan is followed, and minimal precautions taken, there should be no unavoidable adverse effects". However, it is also possible to read this report as depicting an environment with so little friendliness for Havasupai economic planning that it itself tightly circumscribes their activities. 
Additionally (VI 2), most development will have modest, or even beneficial, effects, with the plan designed to increase long-term productivity. 

The only alternative considered, and that briefly, was a course of "no plan, no action". However, there could then be political, social, and psychological damage (VIII 2). A possible paved road and/or "chairlift" into the Canyon were "strongly opposed" by the Havasupai, and not politically feasible in the immediate future. Delay in wildlife management, farming, and the grazing plan would be adverse to any Havasupai benefit. However, more consideration of camping sites might lead to less harmful alternatives. Of course, prudent delay in some parts of the plan need not affect implementation of other parts.

That the Land Use Plan's EIS is overall a supportive, even cheery, document, is not surprising, given the difficulties of the 1975 environment and the Plan's basic assumption of being able to improve the environment, or at least not degrade it significantly. However, since no monitoring or continuing evaluation or revising of the Plan was considered or has been carried out, there is no easy way for the Havasupai or anyone else to know whether it has been a successful guide for the past 40 years of Havasupai sovereignty of the added lands. 

A second volume of the EIS reported comments by agencies and the public gathered during the period of 25 Jul to 21 Sep 1979. At the three hearings in September (Supai, Kingman, Flagstaff), a total of 12 persons spoke. The only private individuals were S.Hirst, C&J Huline, and me. Nine federal agencies responded, as did a dozen from the State. A couple of green NGOs and one for Indian interests, the Hopi, and the Havasupai Tribal Chair and Attorney, all supplied statements. 

Some comments caught my eye:
Hirst, as an assistant to the Havasupai's Land Use Planning Committee, suggests Pasture Wash activities would be only those being pursued at the time of the Act's passage. Dry gardens produced some crops into the 1950's; potentially, that might be started up again.
Havasupai tradition & respect is sufficient to protect cultural resources. 
Cattle-raising being marginal, how about harvesting deer? Venison & hides could free some Havasupai from the cash economy. 
Hirst notes that the original plan was developed by the Havasupai in Jan-Mar 1975; the final 1979  differs only in detail; all the rest has been spent bureaucratically. 

The Havasupai accepted that the eastern boundary was along section lines. 

My statement was appreciative and laudatory of this "modest plan largely conceived in accordance with the letter & spirit" of the 1975 Act. My comment emphasizing that future changes would also be subject to public review brought BIA agreement to seek "a broad spectrum of public involvement whenever … changes may occur." (X 30)

To a desire for year-round camping on the Great Thumb, the Havasupai decided it should be seasonal.

From a Sierra Club member came the experience of finding 99% of the lands remote and "nearly uninhabited".

In the comments from the National Park were sniffs about "subjective" wording about past actions and other NPS prerogatives. 
NPS strongly disagreed about the Cohonina connection.
NPS & BIA disagreed about whether bighorn were observed near Supai. When NPS questioned the grazing section, the BIA replied that it was BIA business. 
The ambiguity of the Use Area figured in several comments and BIA replies. 
Overall, this was a somewhat stiff-necked exchange.

Likewise, state Game & Fish concern for the "loss" of hunting lands was, in effect, rejected as "insignificant" in the BIA reply. 

The Hopi were fully supportive of the Havasupai effort. 

Tribal Attorney Sparks gloried in the "virtually unanimous" pubic approval of the Plan.
Havasupai Chair Wayne Sinyella opened and closed by emphasizing that preservation of their land was of the utmost importance, and was glad to see their goals supported. 

Governor's Office of Economic Planning and Development, "Havasupai Comprehensive Plan", Draft 30 Aug 1974

Truxton Cañon Agency, BIA, "Environmental Assessment, Havasupai Plan to Utilize Lands Added to the Reservation, December 1975

Phoenix Area Office, Bureau of Indian Affairs, "Draft (then Final) Environmental Statement, The Secretarial Land Use Plan for the Addition to the Havasupai Indian Reservation", Vol. I (INT DES 79-42), 26 Jul 1979, and Vol. II (FES 81 - 47) 15 Oct 1981

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