Please be advised that the HPTP filed with the Commission per CEC Condition 12 on December 5 stands premature and inconsistent with the terms of the PA and NHPA. The ACHP has similarly advised BLM of serious flaws in the HPTP and NHPA compliance process. BLM has acknowledged its duty to consult with the disputing parties and ACHP to resolve the dispute but has yet to do so.
The Tohono O’odham Nation and the San Carlos Apache Tribe notified the Arizona Corporation Commission (ACC) that the BLM’s Historic Properties Treatment Plan (HPTP) filed with the ACC to fulfill Condition 12 of the Certificate of Environmental Compatibility (CEC) is “illegitimate and incomplete.”
The Nation and Tribe also state that Pattern Energy violated Condition 27 of the CEC by starting construction before a cultural landscape study was conducted. They further state that the BLM refused to do this study. The Nation and Tribe ask the ACC to halt construction on SunZia until the CEC is complied with.