CT Exp: Ceremonial Stone Landscapes




Click to enlarge. Contact Lisa McLoughlin for more info.

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


Ceremonial Stone Turtle Effigy. Photo is representative, but not of site present in Sandisfield.  © Used with permission.

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 have now been  desecrated 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, have chimed in on the FERC Docket for the CT Expansion project (FERC Docket #CP14-529).

FERC approved the pipeline route and awarded a Certificate of Public Convenience and Necessity before the tribes were brought in for a survey of the route.  By National Historic Preservation Act Rules, and laws governing pipeline approval, these consultations and surveys are supposed to happen early in the process and BEFORE approval. Deputy THPO for the Narragansetts, Doug Harris is now suing FERC over this violation of the NHPA.

Key points of concern :

  • 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).
    » See NITHPO’s attorney’s citations on violations of the NHPA
  • 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.

» 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


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

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