December 01, 2016
The Honorable Caroline Bouvier Kennedy
Ambassador, Embassy of the United States of America
Tokyo, Japan
Lt. Gen. Jerry P. Martinez
Commander, United State Forces Japan
Yokota Air Base, Japan
Lt. Gen. Lawrence D. Nicholson
Commander, United State Marines Japan
Camp Foster, Okinawa, Japan
Mr. Joel Ehrendreich
Consul General, Consulate General of the United States of America in Naha
Okinawa, Japan
Letter of Concern and Request
Inscription of Yanbaru Forest as a World Natural Heritage Site
Dear Ambassador Kennedy, Lt. Gen. Martinez, Lt. Gen. Nicholson, and Consul
General Ehrendreich:
We write to express our concern and to make requests to you regarding theconstruction of six “landing zones” for U.S. military aircraft in the U.S. military’s
Northern Training Area (NTA) in the Yanbaru forest in northern Okinawa Island,
especially in light of the fact that the Yanbaru forest is now on the Tentative List
submitted by the Japanese government for UNESCO World Natural Heritage Sites.
As the U.S. Forces in Japan is well aware, the Okinawa Defense Bureau is now
rushing to construct all the proposed landing zones by the end of the year 2016
amidst strong opposition from local communities and global environmental andpeace organizations. To do so, the Bureau adheres to its 10-year-old Environmental
Impact Assessment (EIA) (2007) for the construction, despite the fact that that EIA
has been widely criticized for its scientific and procedural flaws. The Bureau is also
making drastic changes in construction procedures while failing to implement
mitigation measures set forth in the EIA. This was most apparent in the revelation inOctober 2016 that the Bureau plans to clear-cut over 24,000 trees for construction oflanding zones and entrance roads. Not only is the Bureau destroying the environment,
but also it is subverting the integrity of EIA.
Intense and violent confrontation between protesters against the construction oflanding zones and the riot police force dispatched by the Japanese government takes
place daily at the construction sites. It often leads to various human rights violations,
including unwarranted arrest and detention of protesters, in some cases causing
injuries, and the use by police of derogatory terms such as “Dojin” (a discriminatory
term referring to indigenous people). The situation is chaotic and dangerous,escalating further the already antagonistic relationship between Okinawa and theJapanese government.
The opposition to the construction comes from various quarters. The residents ofTakae in Higashi village have been opposing it since late 1990s because theselanding zones are built extremely close to their community. The aircraft training,
using the two completed landing zones, is already causing intolerable levels of noise,
disrupting and threatening their daily life.
Others oppose it because they see the new landing zones as another form of militaryburden imposed upon Okinawa by the Japanese government. Okinawa, only 0.6% of
the landmass of Japan, already bears the “hosting” of 74% of the U.S. military bases
and facilities in Japan.
Still others (including the authors of this letter) oppose it because the landing zones
are being constructed within a sensitive area of the Yanbaru forest, which is one of
the most important ecological areas in Japan as discussed below.
We are concerned that, despite all of this, the U.S. military and the U.S. government
have remained silent, allowing construction, destruction, and confrontation to takeplace as if you had nothing to do with these matters.
Construction of Landing Zones: SACO, SOFA and Jurisdiction
We understand that the construction of the landing zones is one of the conditions
agreed between the U.S. and Japanese governments for the return of a half of theNTA to Okinawa in the Special Action Committee on Okinawa (SACO) agreementin 1996. We also understand that, under the Japanese and U.S. Mutual Security
Treaty and the U.S. and Japan Status of Forces Agreement (SOFA), the Japanese
government is responsible for providing facilities and areas to the U.S. military, andthus the Japanese government is accountable for the construction of those landingzones.
We know, however, that it was the U.S. military that demanded construction of those
new landing zones since it stood to lose seven landing zones in the land return deal.
In our opinion, the U.S. military should have returned the land without any
conditions rather than demanding additional landing zones. We also know that under
SOFA, the U.S. government (and the U.S. Forces in Japan) are given the power totake “all the measures necessary for their (U.S. bases and facilities’) establishment,operation, safeguarding, and control.”In other words, the U.S. government and the U.S. military have the power to makedecisions over whether or not to allow the construction of landing zones in the NTA.
The Yanbaru Forest on the Tentative List for UNESCO World Heritage Sites
We now direct your attention to the fact that the Yanbaru forest is on the Tentative
List submitted by the Japanese government for UNESCO World Natural Heritage

Sites.
As the U.S. Forces in Japan is well aware, the 27,800 ha (68,695 acres) Yanbaru
forest is the oldest subtropical rain forest on Okinawa Island and it is one of therichest biodiversity areas in Japan. It is home to some 5,400 species of fauna andover 1,000 species of vascular plants. They include over 170 endangered species
listed on the Red List of the Japanese Ministry of the Environment. Endemic andendangered species such as the Okinawa woodpecker (Sapheopipo Noguchii) and theOkinawa rail (Rallus okinawae) are the best known of the well-known habitants ofthe Yanbaru forest. They are also Japan’s “Natural Monuments.” It is mostappropriate that the Yanbaru forest, along with Iriomote Island also in Okinawa
prefecture, and Amami-Oshima and Tokunoshima Islands of Kagoshima prefecture
will be officially considered for inscription on the UNESCO World Heritage List.
The Japanese Ministry of the Environment, the Okinawa prefectural government,
other governmental agencies, and local communities worked hard to get the precious
environment of the Yanbaru forest on the Tentative List in February 2016. The
Environment Ministry also designated in September 2016 a central part of theYanbaru forest as Japan’s 33rd National Park as part of the World Natural Heritage
inscription process. It is expected that precise boundaries including “buffer zones”
for the Yanbaru forest for World Natural Heritage will be established soon and that
the International Union for Conservation of Nature (IUCN), the expert advisory bodyfor UNESCO, will visit Okinawa to evaluate these sites sometime during 2017.
Meanwhile, since 1957, when 7,800 ha (19,274 acres) of the Yanbaru forest wastaken over by the U.S. military and converted into the U.S. military’s NorthernTraining Area, the U.S. military has been conducting jungle warfare training and low
flying training of aircraft there. There are 22 (plus 2 newly constructed) landingzones for military aircraft and other training facilities in the NTA. Loud noise
emitted from aircraft, land contamination from disposed materials and crashedaircraft, combined with logging and construction of logging roads by local forest
industry, have presented and continue to present significant environmental
challenges to the Yanbaru forest. The current construction of landing zones now adds
to those challenges.
We are concerned that those challenges present a significant obstacle for the World
Natural Heritage inscription process as World Heritage requires “integrity” which isdefined by the UNESCO as “a measure of the wholeness and intactness of the natural
and/or cultural heritage and its attributes.“
Regrettably, there is no evidence that the U.S. military has given properconsideration to this World Natural Heritage inscription process of the Yanbaru
forest. None of the U.S. military’s documents available to the Okinawa publicacknowledges the inscription process. One example is the U.S. military’s “Final
Environmental Review for Basing MV-22 at MCAS Futenma and Operating in Japan”(the so-called “Environmental Review”) prepared by the U.S. Navy for thedeployment and training of MV-22 Osprey to Okinawa. The Environmental Review
discussed the natural and cultural resources of the Yanbaru forest and laws andregulations to protect them. However, it completely failed to address the fact that theJapanese Ministry of the Environment and the Okinawa prefectural government wereengaging in preparation for the inscription process despite the fact that theirpreparation was in 2012 (when the Environmental Review was published) alreadywell underway.
Given that the U.S. military closely follows developments in Okinawa in general,
especially ones associated with the U.S. bases, facilities and areas, we have difficulty
understanding why this is so. We do not know whether the U.S. military ignoresinformation on the inscription process or the Japanese government has not properly
informed the U.S. military of it.
We are concerned that, the U.S. military and the U.S. government’s failure toacknowledge the World Natural Heritage inscription process, along with theconstruction of the landing zones, the violent confrontation and human rights
violations and the training of U.S. military aircraft, all hinder the inscription process.
U.S. National Historical Preservation Act, World Heritage Convention, and OurRequests
We understand that, under the current U.S. National Historical Preservation Act(NHPA)(Section 402), the law that addresses matters related to the World Heritage
Convention, while the U.S. military is required to take into account the effects of its
undertakings, whether training or construction of facilities, on World Heritage sites
and properties in foreign countries, it is not required to do so in relation to Word
Heritage inscription processes including one for the Yanbaru forest. We believe,
however, that the spirit and intention of the NHPA is for the U.S. military to take
into account the effects of allowing construction of landing zones and training on theYanbaru forest, given that the Yanbaru forest is a World Natural Heritage candidate
site and is now undergoing inscription process
In fact, Section 135 of the Operational Guideline for the World Heritage Convention,
to which the U.S. is a signatory state, stipulates:
Wherever possible, transboundary nominations should be preparedand submitted by States Parties jointly in conformity with Article 11.3of the Convention. It is highly recommended that the States Partiesconcerned establish a joint management committee or similar body tooversee the management of the whole of a transboundary property.
And the UNESCO World Heritage Convention Article 11-3 stipulates:
The inclusion of a property in the World Heritage List requires theconsent of the state concerned. The inclusion of a property situated ina territory, sovereignty or jurisdiction over which is claimed by morethan one State, shall in no way prejudice the rights of the parties to thedispute.

Please be reminded that the U.S. military’s NTA, over which the U.S. hasjurisdiction, is located in a sensitive part of the Yanbaru forest and that thecoordinates of the “northern part of Okinawa Island” or the Yanbaru forest for World
Natural Heritage inscription provided on the Tentative List is just 1 km (0.6 miles)
away from the NTA.
We do not believe that the U.S. military and the U.S. government would like to be
seen as an obstacle in the way of the World Heritage inscription process in an allycountry.
Therefore, we request the following:
In accordance with Article 11-3 of the UNESCO World Heritage Convention,
Section 135 of the Operational Guideline for the World Heritage Convention, and thespirit and intent of 402 of the National Historical Preservation Act,
That the U.S. military, in consultation with local communities, prefectural andnational (Japanese) government, and relevant NGOs, conduct an assessment
regarding the impact of allowing the construction of landing zones and the conductof aircraft and other types of training in the Yanbaru forest on the inscription processof the Yanbaru forest for World Natural Heritage;
That the U.S. military, while conducting this assessment, cease the issue of entrance
permits to the Okinawa Defense Bureau for purposes of landing zone construction
and suspend its aircraft and other types of training;That relevant U.S. government agencies, including the Advisory Council onHistorical Preservation and the Office of the Assistant Secretary of Fish and Wildlifeand Parks, should be involved in the assessment process.
Sincerely,
Okinawa Environmental Justice Project
Association to Promote Ryukyu Islands as World Natural Heritage
Okumagawa Basin Protection Fund
Yanbaru DONguries
Naha Broccoli
Okinawa Environmental Network
Japan Environmental Lawyers’ Federation (JELF)

The Conservation Network for Forest Ecosystem in JapanThe Nature Conservation Society of Japan
Greenpeace Japan
Friends of the Earth JapanThe Japan-U.S. Citizens for Okinawa Network
No Helipad Resident Society
Association for On-Site-Action Against Helipad Construction in Takae
Association for Protection of Marine Communities (AMCo)
Okinawa Reefcheck and Research Group
Association to Protect the Northernmost Dugong
Save the Dugong Campaign CenterDugong Protection FundThe Save-Awase-Higata Association
Iruka & Kujira ( Dolphin & Whale ) Action Network
Biodiversity Information Box
Diving Team Rainbow-The Conference Opposing Heliport Construction
Project Disagree
All Okinawa Council for Human Rights
International Movement Against All Forms of Discrimination and Racism
Alternative People's Linkage in Asia
“No Heliport Base” Association of 10 Districts North of Futamai
The Conference Opposing Heliport Construction
Minshuku Yaponesia
Dugong no sato

“No Heliport Base” Association of 10 Districts North of Futamai
Committee on Okinawa, Northern Branch, Tokyo District, The United Church ofChrist in Japan
Committee on International Mission・Northern Branch, Tokyo District, The United
Church of Christ in Japan
Shinshu Otaniha・Kyugjonokai Ogaki
The Voice of Gifu Citizens for saving Peace, Human rights and Environment
Kyujonokai Ogaki
Zainichi chosenjin sakkao yomukai
The following organizations support this letter.
Dugong Network Okinawa
Team Zan
Contact:
Hideki Yoshikawa
DirectorOkinawa Environmental Justice Project
Email: yhidekiy@gmail.com
Enclosure: YANBARU, OKINAWA: Future World Natural Heritage and U.S.
Military’s Northern Training Area (map)
CC: Advisory Council on Historical Preservation
CC: The Office of the Assistant Secretary of Fish and Wildlife and Parks