CT Expansion: Ceremonial Stone Landscapes

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There are deep concerns over Kinder Morgan / Tennessee Gas’s (TGP”) plans for dealing with ceremonial stone landscape (“CSL”) features sacred to native peoples with cultural, religious and historical connections to land in Sandisfield, Massachusetts along the proposed route of the TGP Connecticut Expansion Project.

Photo by Heather Bellow, published in the Berkshire Edge

73 CSLs were identified in an on-the-ground survey conducted by  several Tribes in the second half of 2016.  According to Deputy Tribal Historical Preservation Officer Doug Harris of the Narragansett Indian Tribe, a full one-third of these CSLs will be destroyed during the construction of this pipeline.

On December 29, 2016, FERC sent a “Notification of Adverse Effect” to the Advisory Council on Historic Preservation’s Office of Federal Agency Programs. Deputy THPO Doug Harris registered his concerns in this letter, the Nolumbeka Project, and others are now chiming in on the FERC Docket for the CT Expansion project (FERC Docket #CP14-529).

So far, our people in Congress have not commented on this issue. Please contact them and tell them comment on FERC Docket #CP14-529 for the Connecticut Expansion project:
No tree cutting, no construction permission for the Connecticut Expansion without hearing Native voices, and no disturbance of ceremonial stone landscapes.

Contact info:
Senator Elizabeth Warren – DC 202-224-4543, Springfield 413-788-2690
Senator Ed Markey – DC 202-224-2742, Springfield 413-785-4610
Congressman Richie Neal – DC 202-225-5601, Springfield 413-785-0325
Congressman Jim McGovern – DC 202-225-6101, Northampton 413-341-8700
Out of the Berkshires / Pioneer Valley?
Find your Congressperson’s contact info here.

Key points of concern to bring up, as noted in the Nolumbeka Project’s letter:

  • FERC’s EA was issued before the NHPA surveys were taken:
    FERC’s Environmental Assessment (“EA”), issued in 2015, included alternative routes that may have avoided many of the CSLs, but FERC approved the primary route before the CSL survey was undertaken.  Thus, the FERC certificate was issued in violation of the implementing regulations of the National Historic Preservation Act (the “NHPA Regulations”), which require that the agency “complete the section 106 process ‘prior to the issuance of any license.’” 36 CFR 800.1(c). This regulation also makes clear that the purpose of initiating the section 106 process early in project planning is to ensure “that a broad range of alternatives may be considered during the planning process”. 36 CFR 800.1(c).
  • Proceeding without full Tribal participation “in the resolution of adverse effects” is an unconscionable act that also violates the NHPA Regulations, specifically 36 CFR 800.2(c)(2)(ii)(A).
  • Although some have suggested that it would be acceptable to disassemble the CSLs and reassemble them when construction of the Project is completed, Mr. Harris explains that their disassembly would be seen as an interruption of the prayers placed there. According to Mr. Harris, “Then what you have is an artistic replica of something that was spiritual. Once you remove the stones, the spiritual content is broken.”
  • Disturbance or destruction of these sites would further erase traces of a part of our history, and a still living segment of our culture that is already too often ignored – that of this region’s first peoples. To disturb these ceremonial features is damaging to the religious sensibilities of our Native citizens who still embrace the beliefs of their forebearers.
  • Regardless of our heritage, all citizens of our region would be poorer for the loss of these original historic sites, and their destruction should not be allowed.
  • FERC must not allow the these native artifacts to be destroyed.
  • Sandisfield Taxpayers Opposing the Pipeline (STOP) filed a request for a rehearing of FERC’s order issuing the Certificate of Public Convenience and Necessity in April of 2016 that has yet to be acted upon. FERC should grant the rehearing request without further delay, taking into consideration issues raised by the Narragansett, STOP, and others over the course of the FERC proceeding.

» Instructions on how to comment on the FERC  docket
(CT Expansion Docket #CP14-529)
*Be sure to cc: the ACHP rnelson@achp.gov and the Army Corps cori.m.rose@usace.army.mil when commenting to FERC

For those who prefer snail-mail over FERC’s online system, you can mail your comments in (though online submission is much more reliable and recommended).
Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First Street, NE, Room 1A
Washington, DC 20426
*remember to include the Docket number on your correspondence

» Notification of Adverse Effect
» Narragansett Deputy THPO statement
» Nolumbeka Project’s statement
» See more comments about CSLs posted on the FERC Docket

» Read more about the issue

»» Issue info sheet and comment instructions in a hand-out flyer

( Tiny URL for this page: http://tinyurl.com/SaveNativeSites )

» Learn more about preserving Native sites in MA
from Lisa McLoughlin of Nolumbeka Project

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