1

Kelly, Shaheerah

From: Dwight Mallory <Dmallory@resoluteenergy.com>

Sent: Wednesday, February 04, 2015 9:55 AM

To: Kelly, Shaheerah

Subject: RE: McElmo Creek Unit PSD Permit 

Attachments: removed.txt; Aneth Draft Final mjp2.doc

I guess it would help if I attached the report. The linked image cannot be displayed. The file may have been moved, renamed, or deleted. Verify that the link points to the correct file and location.

Dwight E. Mallory

Environmental/Regulatory Manager

Resolute Energy Corporation

1700 Lincoln Street, Suite 2800

Denver, CO 80203

Direct: 303-573-4886 X 1165

From: Dwight Mallory  

Sent: Tuesday, February 03, 2015 5:19 PM

To: 'Kelly, Shaheerah'

Subject: RE: McElmo Creek Unit PSD Permit  

Shaheerah,

That sounds good.  

In the meantime, I received the attached draft report from Dinétahdóó Cultural Resources Management, LLC on Friday.

The attached draft includes my redline comments, which were limited to address additions and correction to the

owner/operator name. These changes will be incorporated by Dinétahdóó before the final report is submitted to the

Navajo Nation Historic Preservation Dept.  

I haven’t had a chance to review it completely, but thought I’d give you an advance look at it. I will follow up after I have

reviewed the report more thoroughly.  

Dwight E. Mallory

Environmental/Regulatory Manager

Resolute Energy Corporation

1700 Lincoln Street, Suite 2800

Denver, CO 80203

Direct: 303-573-4886 X 1165

From: Kelly, Shaheerah [mailto:Kelly.Shaheerah@epa.gov]  

Sent: Tuesday, February 03, 2015 4:54 PM

To: Dwight Mallory

Cc: Patrick Flynn

Subject: RE: McElmo Creek Unit PSD Permit  

Dwight,

Thanks for getting back to me. That time works for me. I will send you an invitation.

I may touch base with you before the call.

************************************

Shaheerah Kelly

Permits Office, Air Division (AIR‐3)

U.S. Environmental Protection Agency, Region 9

San Francisco, CA 94105

Phone: 415‐947‐4156

Fax: 415‐947‐3579

Email: kelly.shaheerah@epa.gov
2

From: Dwight Mallory [mailto:Dmallory@resoluteenergy.com]  

Sent: Tuesday, February 03, 2015 2:41 PM

To: Kelly, Shaheerah

Cc: Patrick Flynn

Subject: McElmo Creek Unit PSD Permit  

Shaheerah,

Since we’ve been playing phone tag, I wanted to follow up with an email and suggest that we schedule the call to discuss

the appendices to the draft PSD permit amendment Friday, February 13th at 9:00 am Pacific Time. Pat and I are both

available. We would also be able to do a call early afternoon.  

Let me know if 9:00 am your time works. Also, please feel free to include any specific questions you need answers to in

your response.  

Dwight E. Mallory

Environmental/Regulatory Manager

Resolute Energy Corporation

1700 Lincoln Street, Suite 2800

Denver, CO 80203

Direct: 303-573-4886 X 1165

This e‐mail message and any attachments are for the sole use of the intended recipient(s) and may contain confidential,

privileged, and proprietary information of Resolute Energy Corporation. Any unauthorized review, use, disclosure or

distribution may be prohibited under law. If you are not the intended recipient, please contact the sender by reply E‐

mail of any erroneous transmission, and destroy the original E‐mail, any attachments, and all copies of the original

message. Thank you.
Confidential Report DCRM 2014-38:

An Ethnographic Survey in Eight Navajo Chapters

Regarding Air Quality and Traditional Practices for Resolute Natural Resources Company, LLC.

in Utah, Arizona, and New Mexico

Prepared by

Rena Martin, Clarina Clark, June-el Piper

and Shane Wero

Navajo Nation Historic Preservation Department Permit Number

C14021

January 29, 2015

Submitted to

Navajo Nation Historic Preservation Department

Window Rock, Arizona

Submitted by 

Rena Martin

Dinétahdóó Cultural Resources Management, LLC

P.O. Box 2012

Farmington, New Mexico 87499

Prepared for

Resolute Natural Resources Company, LLC.

Dwight E. Mallory, Environmental/Regulatory Manager

1700 Lincoln Street, Suite 2800

Denver, CO 80203
i

[When the Aneth Chapter met with Resolute and US EPA], “All they talked about was the air, 

and not about water, or about plants, even though they are all interrelated. How can you separate 

them? In order for anything to live, it has to have air, water, and land, and all of these elements 

are interconnected and give life.” C. Thomas
ii

Abstract

Dinétahdóó Cultural Resources (DCRM) is submitting this report to the Navajo Nation Historic 

Preservation Department (NNHPD) for compliance review. The undertaking is the U.S. Environmental 

Protection Agency (EPA) Region 9’s proposed action relating to amendments to the Prevention of 

Significant Deterioration (PSD) permit for the McElmo Creek Unit Oil Production Facility (MCU 

Facility), an existing oil and gas production operation.

The project center is the McElmo Creek Production Facility’s main flare just north of Aneth, Utah, in 

Section 31, Township 40 South, Range 25 East (SL Meridian). The area of concern is encompassed by a 

circle with a 50 km radius from the project center. The project area for this report is the large portion of 

that circle in Utah, Arizona, and New Mexico on Navajo Nation tribal trust lands. Colorado is mentioned 

only in passing. The following Navajo chapters are wholly or in part within the project area: Aneth, Red 

Mesa, Mexican Water, Dennehotso, Sweetwater, Teec Nos Pos, Beclahbito and Cudei (Gadii’ahi). The 

project is located on the Bluff Utah-Colorado 1983; Rock Point Arizona, New Mexico, Utah & Colorado 

1986; Farmington New Mexico, Colorado 1980, 1:100,000 USGS quadrangle maps.

Rena Martin is the Project Director/Navajo Ethnographer for DCRM. Fieldwork took place between 

October 27 and December 4, 2014. A total of 37 individuals were contacted and/or interviewed in 

conjunction with the project, including chapter officials and residents of all eight chapters.

This ethnographic report details the results of ethnographic interviews and a literature search, including 

review of the Sacred Sites files at NNHPD’s Traditional Culture Program. It also makes 

recommendations for mitigation of the effects of operation of the flare on Navajo traditional cultural 

practices.
iii

Contents

Introduction...................................................................................................................................................1

Description of the Undertaking.....................................................................................................................1

Location ........................................................................................................................................................1

Environment..................................................................................................................................................4

Cultural Overview.........................................................................................................................................4

Chapter Profiles ............................................................................................................................................6

Literature Review..........................................................................................................................................7

Ethnography and Traditional Cultural Properties.........................................................................................8

Field Methods.............................................................................................................................................10

Findings ......................................................................................................................................................12

Recommendations.......................................................................................................................................18

References Cited .........................................................................................................................................20

Confidential Appendix

(Not for public distribution) Results of Ethnographic Interviews

Figure 1. Regional map of the project area

Figure 2. Map showing the Navajo Chapters.

Table 1. Interviewees (identified by number) and Summary of the Findings and Concerns Regarding 

Traditional Practices and Lifeways
1

Introduction

As part of the U.S. Environmental Protection Agency (EPA) Region 9’s permitting process, which 

requires compliance with Section 106 of the National Historic Preservation Act, Resolute Natural 

Resources Company, LLC. contracted with Dinétahdóó Cultural Resources Management to complete an 

ethnographic inquiry with chapter officials, residents, and traditional practitioners in eight Navajo 

chapters to determine if the 20-year-old “flare” at the center of the area of concern has impacted or is 

currently impacting local traditional cultural properties and traditional lifeways. The undertaking is the 

proposed action relating to amendments to the Prevention of Significant Deterioration (PSD) permit for 

the McElmo Creek Unit Oil Production Facility (MCU Facility), an existing oil and gas production 

operation.

Between October 27 and December 4, 2014, Rena Martin, Clarina Clark, Clifford Werito, and Natasha 

Ignacio contacted chapters and concerned parties in the project area. Their fluency in the Navajo language 

encouraged greater participation by local residents in this research on their traditional lifeways and 

traditional places. DCRM staff members Mary June-el Piper and Shane Wero also worked on this project. 

A total of 37 Navajo individuals were contacted and/or interviewed.

Prior to the fieldwork, the Sacred Sites data base at the Navajo Nation Historic Preservation Department 

(NNHPD) was reviewed, and Mr. Timothy Begay of NNHPD’s Traditional Cultural Program was 

consulted. It was determined that the size of the project area precluded a full inventory of cultural 

resources, both archaeological and traditional. It was also determined that the impact of air quality on 

traditional practices and lifeways was the best focus for this research.

This report identifies the areas of concern and provides management recommendations for the protection 

of traditional cultural resources and lifeways, including natural resources. This ethnographic project was 

completed under Navajo Nation Cultural Resources Inventory Permit Number C14021.

Description of the Undertaking

The U.S. EPA is proposing to amend the Prevention of Significant Deterioration (PSD) permit for the 

McElmo Creek Unit Oil Production Facility (MCU Facility), an existing oil and gas production operation. 

The facility is owned and operated by Resolute Natural Resources Company, LLC.. Air pollution 

emissions for this permit action would not cause or contribute to violations of any National Ambient Air 

Quality Standards (NAAQS) or any applicable PSD increments. Other than the replacement of a fixed 

speed fan with a variable speed fan, this permit action does not authorize any new construction or 

modification of existing equipment at the MCU facility. Therefore, there will be no ground disturbance as 

a result of this undertaking.

Location

The project center is the McElmo Creek Production Facility’s main flare just north of Aneth, Utah, in 

Section 31, Township 40 South, Range 25 East (SL Meridian). The area of concern is encompassed by a 

circle with a 50 km radius from the project center. The project area for this report is the large portion of 

that circle in Utah, Arizona, and New Mexico on Navajo Nation tribal trust lands.

The following Navajo chapters are wholly or in part within the project area: Aneth, Red Mesa, Mexican 

Water, Dennehotso, Sweetwater, Teec Nos Pos, Beclahbito and Cudei (Gadii’ahi). The project is located 

on the Bluff Utah-Colorado 1983, Rock Point Arizona, New Mexico, Utah and Colorado 1986 and 

Farmington New Mexico-Colorado 1980 1:100,000 USGS quadrangle maps.
2

Figure 1. Showing the 50 km area with the Navajo Nation boundaries.
3

. 
4

The areas visited are partly developed, with a moderate amount of traffic on the paved roads, and 

numerous dirt roads that serve residences, community services (schools, government offices), commercial 

activities, and facilities and operations related to oil and gas production. The community of Aneth is 

located in the northern portion of the project area, Cudei is located on the southeastern edge, the Carrizo 

Mountains border the southern edge, and Mexican Water is located on the southwestern edge of the 

project area.

Environment

The project area is part of the Four Corners Region, renowned for its rugged canyons and steep 

escarpments (Bernard et al. 2006). Part of the Blanding Basin geologic domain (Stokes 1986:235-236),

this is a region of rock-strewn mesas and rocky buttes that drain into the San Juan River. The importance 

of the San Juan River to the Navajo is found in its many names: as “Old Ages River (Sá Bitooh), Male 

Water (Tooh Biką’i), One with a Long Body (Bits’íísnineezí), and One with a Wide Body (Bits’íínteelí)” 

(McPherson 1992:49). The hardrock that bounds the project area is primarily rainbow-colored Morrison 

Formation Sandstone and yellow-hued Navajo Sandstone (Chronic 1990:70). Because of the sandstone, 

the local soils are poor in quality, lack consistency, mix easily with the windblown loess, and contain 

considerable gravel that erodes from the nearby cliffs (Hintze 1988:200).

Native vegetation of the project area includes various grasses, globemallow, beeplant, yucca, greasewood, 

cliffrose, Indian tea, purple aster, sacred datura, evening primrose, cacti, prickly pear, snakeweed, 

rabbitbrush, cholla, Mormon tea, and sagebrush. Higher elevations support mixed conifer (pinyonjuniper) woodlands. Non-native species such as Russian olive, tamarisk, and cheat grass have invaded the 

narrow strip of riparian vegetation that occurs in the northern portion of the project area, along the San 

Juan. Within this zone, residents have constructed water diversion channels and dams to water farm fields 

where various domestic plants are grown. Corn (naadáá), one of the plants harvested in the project area, 

is a sacred plant among the Navajo used in a number of traditional ceremonies (Dinétahdóó CRM 2003).

In the project area, one plant is listed as a species of concern by the Navajo Nation’s Department of Fish 

and Wildlife. It is known as Navajo sedge, or Carex specuicola

(http://www.nndfw.org/nnhp/docs_reps/casp_rpt.pdf). In the project area it can be found in hanging 

gardens on Chinle Creek cliffs of Navajo Sandstone: for example, near Comb Wash. Its traditional use is 

for grazing.

Most Navajos observe a balance among the water, plants, and animals of the region, ascribing individual 

and tribal health and well-being to this balance. They worry about the effects that resource extraction has 

had on the air, land, and water.

Cultural Overview

Navajos recognize a deep cultural connection to the San Juan region that is passed on through traditional 

stories. Specific references are made to various places in the region, including Montezuma Creek (Brugge

1983:490). Traditional Navajo beliefs recount that upon their emergence into this world they were preyed 

upon by monsters until twin boys, Monster Slayer and Born for Water, came to fight the monster beings. 

Physical reminders of their battles occur throughout this locality, such as Shiprock pinnacle (Tsé bit’a’í), 

Red Mesa (Tsé Łichii Dah’Azhkání), and the Bears Ears (Shash bijaa?), which are evidence of the war 

between the twins and the monsters (Van Valkenburgh 1999:97; McPherson 1995:21). To the Navajo, the 

oil extracted from the Aneth Oil Field is actually the black “blood” of the monsters spilled in battle and 

trapped beneath the surface (McPherson 1997:1).

Archaeologically, Navajo occupation of the study area is documented in countless sites. The earliest 

historical records date to the Spanish colonial, Mexican, and American eras. The Navajo population in the 

project area remained fluid through the eighteenth and nineteenth centuries because of conflicts with 

native and non-native groups. Skirmishes with Utes, Spaniards/Mexicans, and Euroamericans were 

relatively common. Many Navajos practiced transhumance, moving seasonally between the arid high 
5

ground and the drainages. Raiders took more than livestock; they also preyed upon Navajo girls, who 

were taken as weavers and domestics for Spanish and Mexican households. The insecurity of the situation 

forced Navajos deeper into the remote canyons of Arizona and Utah.

By 1846, the newly established U.S. government control of the Four Corners compelled Navajos to sign

the Treaty of Ojo de Oso (Bailey and Bailey 1986:18). Little changed for the Navajo, however; in 1865, 

when black slavery officially ended in the U.S., more than 3,000 Navajo women and children were still 

being kept in captivity in New Mexico (McPherson 1999:13). During the this same period, as Navajos 

were being rounded up for confinement on a reservation at Fort Sumner (on the eastern plains of New 

Mexico), a great many Navajos sought refuge in the rough country of the project area. The drylands of the 

project area became an isolated haven for tribal members until the U.S. government released the confined 

Navajos to their trust lands in 1868.

The portion of the project area in Utah was not included in the Treaty Reservation of 1868, although 

Navajos had long occupied the area. The southeastern portion of Utah south of the San Juan River was 

added to the Navajo Nation on May 17, 1884. On March 10, 1905, the area north of the San Juan was 

added. Additional areas known as the “Aneth Extensions” were added as a result of a land exchange 

involving the construction of Glen Canyon Dam and the town of Page, Arizona (Rogers 2004:311).

Navajos in the project area had developed a dryland livestock system that ranged unfettered until 1879,

when LDS Church pioneers brought their own herds into the Montezuma Creek and Aneth area 

(McPherson 1995:101). Almost immediately, livestock operators from Fort Montezuma and Fort Bluff 

came into conflict with native ranchers in competition for available range. In order to mitigate rangeland 

conflict, federal officials looked to establish farms on the floodplain south of the San Juan River and 

recommended that 260 acres near Bluff be turned into Navajo farmlands (McPherson 1999:46). Local 

Navajos received farm tools and wagons and were instructed to dig irrigation ditches, build dams, 

construct riprap around headgates, and plant farm fields (McPherson 1999:54). Farmers from the region 

established the first Shiprock Fair on October 20, 1909, in evidence of their agricultural skill, an event 

that continues today. However, flooding in the 1920s and 1930s destroyed headgates and devastated 

fields, forcing Navajos to focus once again on a stockraising economy. At the same time, concerns over 

erosion led to the infamous stock reduction era, when the project area residents’ herds were decimated by 

order of the federal government (Bailey and Bailey 1986). Nevertheless, most residents of the project area

were livestock producers when oil field exploration began in the early 1950s, and many still try to make 

or supplement their living this way.

By 1956, Aneth Oil Field tribal leases with Humble and Shell Oil Companies produced nearly 35 million 

dollars in royalties for the tribe (McPherson 1995:209). The Utah Navajo share of these royalties was 

considerably less than this amount, although Aneth’s long-term leases permitted oil companies to 

establish one well per forty acres in this remote portion of the reservation (McPherson 1997:5). Social 

reactions to increased well-sites in Aneth in the 1960s were mixed; some feared damage to their culinary 

wells and springs and others believed the wells contributed to the poor health of residents while still 

others regarded the boom as economically advantageous regardless of the presence of the pumps. By the 

1970s, local residents expressed strong dissatisfaction erupting in near violence as tensions among 

residents, tribal officials, and oil workers grew. Aneth residents demanded to renegotiate royalties with 

greater consideration for the community at large. Although tensions have eased, community support for 

oil exploration remains uneven (McPherson 1997:11).

Subsequent to the modern period of unrest was the out-migration of many residents as people looked for 

work and educational opportunities beyond the chapter boundaries. Concerns about pollution as well as

danger from the oil development facilities led some to move to Albuquerque, Cortez, Durango, and Salt 

Lake City. While some continue to express these concerns, there has been an influx of populous in recent 

years, a return of sorts of a younger generation that had not previously lived full-time on the reservation, 
6

perhaps only visiting in the summers. Now some families are permanently relocating to tribal lands, 

seeing in them a similar refuge as the canyons had been for their elders more than a century ago.

Chapter Profiles

Aneth Chapter. The Aneth community is known as Táá bíích’iídii, often interpreted as “Just like the 

devil,” in reference to unscrupulous practices of the first trader in the area (Rodgers 2004:310; see also 

Wilson 1995:2). Linford (2000:285–286) provides a brief summary of the Navajo name, trading post 

operations in the area, Navajo resistance to schooling, and oil development (see Baars 1995 for a 

discussion on the Aneth oil fields). Younger tribal people use the term táá bíích’iídii to refer to the dry, 

isolated, and rough country of the area (Bernard et al. 2006). 

The chapter is located in the Northern (Shiprock) Agency of the Navajo Nation. Agencies are 

administrative units of the Navajo Nation and the Bureau of Indian Affairs. The day-to-day operations are 

handled by a Community Services Coordinator (“Chapter Coordinator”). The chapter membership 

decides on chapter policies and decisions affecting the community at monthly chapter meetings. The 

central Navajo Nation government in Window Rock provides oversight of the chapter’s operations.

The Aneth Chapter has pursued housing, utilities, and economic development projects. The chapter 

comprises nearly 184,000 acres (Rodgers 2004:310). The community boasts a senior citizens center; a 

HeadStart program; schools that serve all grades; several churches of various dominations; several 

convenience stores providing groceries, fuel, and laundry services; a health clinic; and several housing 

developments. Many of the Navajo Nation offices provide services within the community. The 

community is served by two paved roads: State Route 262 and Navajo Route 35. Many community 

members obtain primary care medical services at the clinics located in Aneth Chapter; Teec Nos Pos, 

Arizona; Cortez, Colorado; and Blanding, Utah. Major medical services requiring hospital care are 

located at Monticello, Utah; Northern Navajo Medical Center, Shiprock, New Mexico; and the Southwest 

Memorial Hospital, in Cortez.

Many of the community members still raise livestock. In the Northern Agency, the Navajo Nation has 

more than 4,169 livestock permittees (to own and graze livestock on the Navajo Nation, a person must 

have a permit issued by the Bureau of Indian Affairs). In 2003 sheep, goats, cattle, horses, llamas, and 

alpacas numbered about 108,639 across the reservation. The predominant species is sheep, followed by 

cattle and goats (information compiled from the Navajo Nation Department of Agriculture’s 2003 

Livestock and Permittee Report). Livestock still play an important role in the lives of Navajo people. 

Beclabito Chapter. The Navajo name Bit’cłáá bitó means “Beneath Its Water.” The chapter encompasses 

approximately 87,000 acres. It is south of the San Juan River, primarily in New Mexico (with a small 

portion in Arizona). The chapter house was built in 1968 and has since been renovated. There is also a 

preschool, a senior citizen’s center, and a former BIA Day School that was built in 1934. The trading post 

was established in 1911 (Linford 2000:175).

Gadii’ahi Chapter. The Navajo name means (One) Juniper Standing. Formerly known as Cudei, the 

chapter is north of the San Juan River in northwestern New Mexico. Its 44,000 acres were part of the 

Beclabito chapter until 1978. Residents along the San Juan River practice irrigation farming. Many of the 

residents in the Rattlesnake area, primarily elders, raise stock. Rattlesnake or Toh koh eh (Gas Lanterns) 

is one of the oldest oil and gas producing fields on the Navajo Nation (1922).

The road to the Gadii’ahi community was paved in 1997; water and powerlines were extended to 

Gadii’ahi in the mid-1980s. As in all Navajo chapters, however, many outlying residences still do not 

have water or electricity.
7

The chapter has two paved roads, U.S. Route 64 and Navajo Route 57A. In addition to the chapter house 

(built in 1982) there are several churches and a preschool but no commercial establishments (Rogers 

2004:324). Students from this chapter attend classes in Beclabito or Shiprock.

Mexican Water Chapter. Naakaii tó was named after three Mexicans (Spaniards?) who were passing 

through the area and dug shallow wells here. The community was certified as a chapter in 1956; it 

contains 160,000 acres. The first chapter house was built near the trading post and school; a brand new 

chapter house has been built along U.S. Route 191. The Navajo Baptist Church still operates near the old 

trading post area. Elementary through high school students are bussed to Red Mesa. The first bridge over 

Chinle Wash in this area was built in 1939; it has since been replaced. The trading post was built in 1907 

(Linford 2000:111).

Red Mesa Chapter. The Navajo name for Red Mesa is Łichii’ da’azkání. The chapter encompasses 

approximately 268,000 acres extending south of the San Juan River, primarily in Utah but with a small 

section in Arizona. Prior to 1967, the chapter was part of the Mexican Water chapter. The Red Mesa 

Trading Post was established in the 1930s. There are public schools (preschool and high school), in 

addition to the chapter house (built in 1992) and a senior citizen center. Commercial establishments 

include gas stations, convenience stores, the trading post, and oil company offices. In Navajo oral history, 

Monster Slayer killed Déégééd here, staining the sand red with the monster’s blood (Linford 2000:123; 

McPherson 1992:33)

Sweetwater Chapter. The Navajo name for Sweetwater is Tó łikon. The chapter encompasses just over 

152,000 acres. There is a single gas station/convenience store in the chapter. Students are bussed to Red 

Mesa. 

Teec Nos Pos Chapter. The Navajo spelling of this chapter is T’iis Násbas, or Cottonwoods in a Circle. 

Most of the chapter is in Arizona, but the northeast corner of the chapter is the famous Four Corners, so 

parts of the chapter are also in Utah and New Mexico. The chapter contains just under 234,000 acres. The 

community was named after a cottonwood tree and dates at least to the 1880s. The trading post was built 

in 1905. There is a chapter house, a senior center, an elementary school, several churches, and a clinic.

The northern boundary of the chapter is the San Juan River, and the southern boundary is Carrizo 

Mountain.

Dennehotso Chapter. The eighth chapter in the project area, Dennahootsoh (Green Meadow Converging 

at Upper End), is the only chapter in this project in the Western Navajo Agency. Comprising nearly 

292,000 acres, it extends into Utah (the only portion of the chapter that is within the project area). Most of 

the people in the chapter live in or near the community of Dennehotso, long U.S. Route 160 in Arizona.

This area was a summer residential location for Navajos families who moved elsewhere in the winter; it is 

now inhabited year-round. In addition to farming along the creek in the main community, there are also 

extensive uranium operations (now closed) dating from the 1950s and 1960s. The main community has a 

chapter house, several churches, an elementary school, and a post office. The trading post (now closed) 

was built near Baby Rocks, an earlier farming community whose fields were devasted by flooding in the 

early 1900s.

Literature Review

This section of the report summarizes previously documented sacred places or other places of traditional, 

cultural, or ceremonial concern. 

Local places of traditional and historical importance to Navajos include Hovenweep National Monument, 

the San Juan River, White Mesa, Ute Mountain, Mancos Canyon, Navajo Wash, and McElmo Canyon. 

These places figure prominently in the migrations of certain Navajo progenitors, ceremonial history and 

traditions, and Navajo people’s use of and relation to plants and wildlife (Bernard et al. 2006).
8

The Aneth area is important in Navajo ceremony and culture. According to NNHPD’s database, certain 

ceremonies have established history and offering locales in the area, including Hózhóójí (Blessingway), 

Tł’éejí (Nightway), Dził k’íjí (Mountaintopway), and Íínaají (Lifeway). Undoubtedly, the area figures in 

many more, unrecorded ceremonial traditions.

Plants, minerals, and other resources in the Aneth area are collected for ceremonial and daily use. Many 

of the important places mentioned in the Sacred Places Database and referred to in ceremonial repertoires 

are natural features (hills, springs, mesas, mountains, flora and fauna) and, in many instances, prehistoric 

sites. Many archaeological sites are important in Navajo history, traditions, clan origins, and the 

development and practice of ceremony and rituals.

A general literature search revealed the following information. According to Linford (2000:287), 

nonlinear prehistoric roads have been identified in the vicinity of Bluff (see Gabriel 1991:276).

Lime Ridge is a steep north-south incline crossing the east end of the Valley of the Gods (north of the San 

Juan River) a mile or so east of Lime Creek (Linford 2000:294). Navajos say that children disobedient to 

Johonaa’ei (Sun Bearer) are trapped in a large trapezoidal boulder along this ridge. A pair of two-horned 

snakes live here, guarding the eastern boundary of Navajoland (McPherson 1992:25).

Poncho House, Tséyaakin, “House Under the Rocks,” is a large, late Mesa Verde-type Anasazi cliff ruin 

located in a large shallow cave on the west bank of Chinle Wash, some 10 miles south of that stream’s 

juncture with the San Juan River (Linford 2000:302). Like all Anasazi sites, it is a sacred place.

Ute Mountain, also called Sleeping Ute Mountain is known in Navajo as Dziłnaa jini, Black Mountain 

Sloping Down. It is one of the sacred mountains of the Navajos. From the south it appears like a sleeping 

giant with the head to the north. Navajo medicine men tell that the mountain is fastened to the sky by a cord 

of rain and is decorated with corn pollen, dark mist, and female or gentle rain. The Holy Boy and Girl who 

make rough jewels are said to dwell on the mountain (Van Valkenburgh 1991).

Ethnography and Traditional Cultural Properties

Collecting information about traditional cultural properties protects resources for the living cultures that 

maintain a connection to cultural landscapes. These resources include gathering area and places 

associated with oral traditions and ceremonies. Any of these places could be called sacred, depending on 

their significance to traditional lifeways. According to Vannette (1988:32),

they are places mentioned in legend; places where something supernatural has happened; and at 

all of these sites, either plants and herbs or minerals and water possessing healthy powers may be 

taken. Prayers and offerings are made at nearly all sacred locations.

Navajo beliefs and lifeways are grounded in a tremendous amount of esoteric knowledge that only certain 

medicine people possess, including information that is organized into ceremonial procedures, 

paraphernalia, prayers, songs, and stories (Kelley and Francis 1994). Traditional places connected to this 

cultural knowledge are increasingly threatened by alterations to the physical landscape through modern 

development, construction projects, loss of land jurisdiction, and other means. The push to modernize 

tribal lands often occurs without consideration for native traditionalists whose lifeway is dependent on 

resources and places within their cultural landscape. Many traditional people place religious significance 

on places in elevated areas (mountains/mesas), canyons, streams and springs, and places associated with 

certain animals and birds. Cultural properties are further threatened by the overall decline of native 

languages and traditional lifeways along with the failure of younger generations to become acquainted 

with their cultural heritage. For those who retain a traditional life, the jurisdictional context of a sacred 

place—whether it falls within or outside reservation boundaries—has little value, as the Diné connect the 

cultural and physical landscape seamlessly, making no distinction between the sacred and the secular. No 
9

passage of time affects the religious nature of these places; a property that might appear to outsiders to be 

long abandoned retains traditional significance as a sacred place (hodiyin).

The following places are included in the Sacred Sites files curated at the NNHPD Traditional Culture 

Program in Window Rock.

Tooh (River; Colorado and San Juan Rivers)

Vannette 1988:36; Vannette and Feary 1981:18; Luckert 1977. Source of waters collected for ceremonies. 

Initiates of several ceremonial repertoires float down the river. Navajos offer tadidiin (corn pollen) to the

river for rain. 

Places in New Mexico

Bitł’ah Bito (Spring at the Bottom; Beclabito) T30N R21W

Area is also called Tse Nashchii’. Point on Nighway ceremonial route of travel of the Visionary and the 

Holy People.

Tse Nachii’, Tse Nashchii’ (Red Rock Circle, Beclabito Dome) T30N R21W

Also includes Beclabito Springs and is considered a sacred place (Downer et al. 1988:27); Initiates in two 

different ceremonies (Nightway and Beautyway) learned about ceremonial use of mineral and animal 

resources here.

Places in Colorado

Tó Nts’ósikooh (Slim Water Canyon, lower Mancos Creek) T32N R17W and long zone to southwest

Initiates in Female Mountaintopway and Beautyway pass downstream along the San Juan to Mancos 

Canyon, go back and forth around Carrizo Mountains and Bear Ear (Tse Ii’ahi?), and then go their

separate ways. The Nighway initiate, traveling to learn about plants, goes from Dibe Ntsaa and Dził Łigai 

(San Juan Mountains or Aztec Ruins and Mesa Verde) across the Mancos near the Mancos River Trading 

Post (K’ii Łitsoi) and then down to the mouth of Mancos Creek, then crossing the San Juan and up T’iis 

Nasbas Canyon or southward through Bitł’ah Bito. 

The upper or lower Mancos may be where the sexes separated before the Emergence (Kelley and 

Francis 2001).

Tse Łigai Ii’ahi (Rock Spire, Chimney Rock) T31N R16W

Van Valkenburgh (1974:128) located this place 22 miles southeast of Towaoc, the home of Two-Faced 

Monster, who may have been a being with a mask, possibly associated with hunting. Assumed to be one 

of the places called Bear’s Ear (Shash Bijaa’) in a version of Mountaintopway stories; possible marker for 

ceremonial route from the Hogback into upper Mancos Canyon. At Tse łigai Ii’ahi (White Standing 

Rock), the family of the Male Mountaintopway initiate camps.

After leaving Hajiinai [the Emergence], people moved to the upper Mancos Canyon and then to 

Tse łigai Ii’ahi, where they stayed for 13 years before moving to Tse Baah Halgai (mouth of Sanostee 

Canyon); four people who survived the monsters moved to Tse łigai Ii’ahi and found a small turquoise 

image of a woman, which one of the Holy Beings told them to bring to Gobernador Peak to put down 

with a white shell image to create Holy People. These references could be either to this place or to the 

place of the same name in Red Valley (NM). Either way, a precolumbian ruin is indicated.

K’ii’ łitsoi (Rabbitbrush, Navajo Spring Canyon)

Ceremonial route of travel into upper Mancos Canyon and Mesa Verde precolumbian ruins for initiates in 

Tł’eeji (Nightway) and Iinaji (Beeshee Flintway) stories.

Places in Arizona

Naakaii To (Mexican Water) T41N R25E

Name could reflect Armijo horse trail of 1830s through here to Los Angeles (Hafen and Hafen 1954). 

Possible reference to precolumbian ruins in the area: Western Water Clan people stopped here.
10

Hooghan Si’ani (Dwelling In Place; Hogan Saani Spring) T40N R26E

Spring at confluence of Walker Creek and To Ch’inilini In the Iinaji story, Hooghan Si’ani is mentioned 

in sequence between Carrizo Mountains and Aghaa’ ła as the family flees the wrath of Ii’ni’ łigai and 

goes to Dook’o’oosliid. May be the same as Tsin Tł’oo’di Hooghan, a place on the route of Western 

Water Clan people. Possible reference to a precolumbian ruin.

Dził Náhoziłii (Groping Mountain; Carrizo Mountain) T39N R30E

One of the first mountains that the Holy People put down after the Emergence. Various stories about 

Western Water Clan people stopping here may refer to precolumbian ruins in the area. On various 

ceremonial routes of travel. Source of blackening pigment for Nightway (see T’eeshchiih Al’ini). Place 

on route of Jadi Naakits’aadah (Twelve Antelope) to Sunset Pass (Jadi Hi’ibikaa’) (Van Valkenburgh 

1974:97).

On the east side of Dził Náhoziłii, at the entrance to a canyon, is a water pocket, a hole about the 

size of a human. Tobacco grows all around it. The place is called Tó Ásaa’ (Water Pot) (Kelley and 

Francis 2000:201).

T’eeshchiih Al’ini (Blackening “Ochre” Is Made; Carrizo Mountain summit) T34N R23E

Pigment mine visited by the Nightway initiate and Holy People.

T’iis Nasbas (Ring of Cottonwoods; Teec Nos Pos Canyon) T40N R30E

Place on ceremonial route of travel of the Nightway initiate. Perennial spring left by Tse Naaghai (Rolling 

Rock) pursued by Naayee’ Neizghani.

Field Methods

Pursuant to consultations between the US EPA and NNHPD, the Navajo Nation’s Traditional Cultural 

Program decided to concentrate on the potential effects of this undertaking on traditional lifeways and 

traditional cultural places within a 50 km radius of the main flare, and to require consultation with 

traditional practitioners who perform cultural activities within this area. NNHPD also required interviews 

with chapter representatives and with residents who live within one-half mile of the main flare.

NNHPD decided not to require consideration of archaeological resources within this 50 km radius area 

except for any that are also considered traditional cultural places in the literature or the interviews. This is 

because there are probably tens of thousands of cultural resources (archaeological sites, burials, and 

isolated occurrences, either recorded or not yet recorded; this estimate does not include in-use sites) 

within the project area, and a full consideration would be impossible within the time frame of this project.

(For example, in 2006 DCRM surveyed a tiny fraction of the current project area for a different 

undertaking and found 124 TCPs and burial locations, not including the archaeological and in-use sites: 

Bernard et al. 2006.) Also, the impact of operation of the main flare on surface or buried archaeological 

sites is beyond the scope of this project. Instead, NNHPD’s Traditional Cultural Program decided for the 

purposes of this project to focus on lifeways, traditional practices, and plant and animal resources used in 

traditional activities.

Immediately after a permit was obtained from NNHPD, the department’s confidential TCP files and maps 

were checked for any previously recorded TCPs by June-el Piper and Clifford Werito (see above).

Before the interviews were initiated Rena Martin, Clarina Clark, and June-el Piper took a tour of the 

central project area and visited the McElmo Creek Unit Oil Production Facility and saw the main flare. 

The ethnographers saw several Navajo homes within 400 ft of the flare. The tour enabled the 

ethnographers to estimate the number of homes located within one-half mile of the flare.
11

Next, opening visits were made to the various chapter houses and offices to describe the nature of the 

proposed federal undertaking to the chapter coordinator (see Appendix A for contacts and dates). Since 

each chapter is governed somewhat differently, the level of contact varies. Some chapters, such as Red 

Mesa, required a presentation at a monthly chapter meeting that is open to all chapter members (all 

registered voters who are official residents); others such as Dinnehotso required a presentation at a 

planning meeting typically attended by officials and the planning board; still others such as Aneth only 

required a meeting with chapter official(s) and staff.

After completing these initial steps, Rena Martin, Clarina Clark, Clifford Werito, and Natasha Ignacio 

began conducting interviews with the traditionalists recommended by the chapter officials and other 

community members. These individuals provided additional names of people, including knowledgeable 

elders who were known to gather plants or to participate in ceremonies.

Fieldwork took place between October 27 and December 4, 2014. Fieldwork consisted of arranging 

contacts with the eight Chapters and presenting the project. The chapter officials either agreed to a 

chapter presentation or a meeting the officials. Once the meetings with the chapters were initiated a 

decision was made on whether a formal meeting presentation would be required. The chapter officials or 

staff members including senior center staff provided names of traditional community members DCRM 

interviewers should contact. Interviews and field visits, broadening contacts with additional people who

they thought should be contacted. Participants were told of the project and purpose of the ethnographic 

inventory, and all contributors agreed to have their names be used in a confidential appendix the 

questioning began (see Appendix A). Contributors who offered relevant cultural information were 

compensated.

The protocol for interviews adhered to the procedures outlined in the Navajo Nation guidelines for 

ethnographic study. Precise questions were asked of each interviewee, although it was common for 

speakers to offer suggestions beyond the scope of the protocol. 

The interviewees were asked open ended questions related to air-quality as from the flare and traditional 

lifeways,

a. Are you aware if the air quality is affecting any traditional ceremonies or practices?

b. Are you aware of changes in any traditional practices because of the air quality?

c. If you aware of any effects of air quality on traditional lifeways or practices, please provide 

us with recommendations.

All interviews were conducted in person by Martin, Clark, Werito, and Ignacio. A good faith effort was 

made to contact all residents and land users within one-half mile of the flare as well as all individuals

recommended by chapter officials and other interviewees. Given the busy schedule of traditional 

practitioners in early winter, the process required repeated efforts to contact individuals. Two 

recommended individuals could not be reached, as well as two additional prominent practitioners and one 

botanist.

Interviews were conducted in Navajo, although notes were taken in both English and Navajo. All field 

notes were transcribed into English, except for the plant names whose common/scientific names are not 

known. Ethnographic inquiry continued until project participants began suggesting the same names for 

additional interviewees. When this occurs (renaming of individuals) it generally means the list of 

potential interviewees is exhaustive and fieldwork is complete. Lastly, Dinétahdóó compensated all 

consultants at the time of the interview. 
12

Findings

Table 1 presents a summary of the information provided during interviews and consultations.

Table 1. Interviewees (identified by number) and Summary of the Findings and Concerns Regarding 

Traditional Practices and Lifeways. More specific information is provided in the Appendix.

Interviewee 

Number

General Interview Summaries

3 

(Sweetwater)

Stated her concerns are related to the heavy smog that hits their community in the evenings and 

stays until early morning. She said the haze is more noticeable in the fall and winter. She stated 

that the smog from the Four Corners power plants and possibly the gas from the Aneth area get 

caught at the foothills of Carrizo Mountain. She also talked of air [quality] being worse in the 

winter because of the locals burning coal and firewood. She notices that more children are 

getting asthma whereas in the past even if the families burned coal and wood children did not 

have respiratory issues.

Stated that when she visits her family in Aneth, she cannot stand the smell of the air and asks her 

family how they can put up with the smell of gas on a daily basis. She stated that something 

needs to be done, including testing for any health-related issues. She has heard people state that 

the air quality in the Aneth area is causing major headaches, sinus issues, and eye irritation.

5 (Aneth) Stated they had a trailer in [the chapter’s] front yard and that NNEPA had not informed them 

about what the trailer was outfitted with and what it was doing. He said, “We don’t know if the 

instruments are collecting any data on the air,” and he did not know what the study was going to 

be used for. He stated, “nobody keeps us informed on what the studies show and whether the air 

from here or in other areas is harming us.” He further stated, “All the money made from our 

community is going into Window Rock and none of it is returned to us.” He stated that the 

information that DCRM is collecting is just going to be taken to Window Rock and stay there, 

with no results sent back to the community. He further stated that the NN Historic Preservation 

Department does not help them and just seems to store information gathered from work done 

here.

At a subsequent meeting, with other chapter officials present, he opened up the discussion with a 

comment: “I thought for two days about the question you were posing to us, and I am still not 

sure if you will really get an answer. Your research is hard to explain because it relates to air 

quality. [You say that] your study is not really about health, but in a sense it is really is related to 

health.” He and I explained to the group that the primary question being as was how has/is the 

quality of air affecting traditions including those related to ceremonies, traditional plant use and 

gathering, mineral gathering, traditional lifeways, and related issues.

The group all agreed that the air in their community has a bad smell all of time. They said the 

summers are the worst, when the heat bears down and the fumes from various gas facilities get 

worse; the smell gives everyone headaches. They agreed that they get stuffy noses, blurry vision, 

cough, and catch colds easily. They also stated that there were two additional flares in the 

immediate area and asked why they were not included the study. . . . They discussed how 

pockets of bad air form in the low areas, and that evenings were usually the worst, especially 

when there is no breeze and the air seems heavier. They also all agreed that there need to be 

more studies, including those related to health, animals, and plants so there can be comparative 

data for the future.

6 and 7 

(Aneth)

(6) works with the US Department of Agriculture and has an office in the chapter facilities. (7) 

is a local medicine man.

Both men stated that air quality in their community is bad. (6) stated that more people are 

requesting Níłchi’ji and Chishí’ nahaga’. He believes the air is getting worse, which makes the 

people request more breathing-related ceremonies. Both men stated that health issues related to 

the air are bad. They agreed that when there is no breeze, driving up out of the valley helps them 

to get fresher air, without the smell that continually lingers. They both agreed the air smells like 

gas/oil and the smell is worse in some areas and at different seasons.
13

Interviewee 

Number

General Interview Summaries

(7) agreed to visit with DCRM staff members when our crews get up this way for interviews. 

The pair also recommended that we consult with another local hataałii.

At a subsequent interview, he mentioned the medicine iilnajii’ in the Mule Ear area (Tsenaza) 

[between Mexican Water and Dinnehotso]. He stated, “One has to go down into the bikoh

(canyon) to get good plants over in the Mule Ear area; it takes a young person to go down into 

the canyon. I can no longer do it because I am getting old. The plants for all ceremonies were 

available near our homes, but now we have to travel to get it.”

He said, “When you look for plants now around Aneth, the plants do not always look healthy; 

their leaves have brown edges or sometimes they have unhealthy looking roots. I have noticed 

that the leaves are brownish and there are scars and growths that are not normal. So I am sure 

that the air affects the plants like it does us, and the roots do not look well too because the water 

that wets them is contaminated as well. Like us, they [plants] are affected by the local 

environment. When you find the plant that you need, you talk to them when you are gathering it 

and provide them an offering and explain how it will help a person. You do this by talking to the 

plant that will be used for medicine.”

He said he now travels to other areas to locate healthy plants, including the Wheatfield Lake area 

[between Navajo, NM, and Tsaile, AZ, well outside the project area]. He collects a particular 

plant from the south face of one of the formations, way up high on the mountain. He also 

explained how some plants are being misused; he said this could cause harm to the gatherer too. 

He said, one should always bring what was not used back to the place of origin, but because of 

the distance herbalists how have to travel this was not always possible. But his main concern was 

for the plants in the Aneth and surrounding area. The people he helps are from that area, and the 

plants that live and/or used to live there were placed there for them. These plants are now gone, 

and herbalists and hataałii have to travel for them. He also said, “These plant gathering areas 

have been used for generations by one family, like fathers and grandfathers.”

“There’s lot of oil and gas development activities; I think that is why there are no more plants. 

The smells and waste left on the ground affects our breathing, and I am sure it harms the plants 

and animals too. Research is needed to see how all of these unseen fumes and smells are 

affecting our health. There are still ceremonies, but the plants that go with the ceremonies are 

getting harder to get near here.” He continued, “Even though it rains, sometimes it is still too hot; 

most of the plants are gone because of the heat. Maybe they [the plants] just migrate to better 

areas. Chishi ceremonies help with health issues from lightning/twisters. I was able to gather 

ilkoh and atsaa bi... [full name not recorded] from near the rocks but often cannot find them 

anymore. When it’s windy, it blows all sort of bad things that harm the plants. When it’s calm, it 

seems alright, but the smell and other things in the air that we cannot smell affect our lungs, the 

lining of our nose, and gives us headaches.”

“The water is all not good either. For years the oil and gas leaks have been seeping into the 

washes and natural springs, and I am sure it has ruined our local water. Someone needs to test 

our water in this area. Our old natural springs are gone, and what is left tastes awful or barely 

exists. Over where I live they tested our old spring and it turned out bad. They retested at a 

different location and found that at 160 feet the water was good, so something has seeped into 

the upper groundwater.”

“Otherwise, since we are talking about sacred areas and such, let me tell you of a place we use to 

place nitliz [offerings], but, the location got bladed for road improvement. Then there was also a 

place where we gathered plants for the Wolachiiji around my home area, but during a seismic 

project the plants got bladed. The good thing is, when I checked they had grown back a distance 

from their old home.” 

He then spoke at length about living downwind from a uranium mining area. He talked of how 

the both the oil/gas industry and old uranium mines are affecting people’s lives and causing 
14

Interviewee 

Number

General Interview Summaries

health problems. He was concerned that the oil/gas-related health issues may turn out to be as 

detrimental as uranium. He has had patients who complain about itchy skin, rashes, sores in the 

nose, and does not know if this is related to the dry air or a combination of blowing uranium dust 

and the burning of gas.

9 (Aneth) At a meeting at the Aneth chapter house, (9) stated, “All living things live on air and water. The 

plants need air just like us, and our air is hot. We hardly get any more rain; our community 

[Aneth] is like a furnace. Our air is polluted by the heat. We let off so much heat and gas that it 

is affecting us and all living plants and animals. The animals seek plants that are their medicine 

and food, but around here there are fewer plants for them to eat. The goats are real smart; they 

seek out good plants. The cottonwoods that used to grow along the river seem to be dying out,

along with other, smaller shrubs and plants. We are missing some birds—birds that assisted us 

with prayers. There are even fewer prairie dogs. There used to be eagles’ nests in the trees along 

the river too. I see this area as being a hogan stove pipe that lets off heat into the atmosphere. 

When we were little, we were trained to collect plants, and I would be asked to go over to certain 

areas to collect plants for family members. Those plants have all moved. I remember one for an 

upset stomach; that plant is not growing where it grew for years. My mom would say, “Go get 

me some berries and wah’.” I cannot do that anymore. I don’t know if the heat from the burning 

of excess gas will ever stop, and as long as they do it we will be living like this and it will get 

worse. We hardly get any rain, and we have not had a good snow in a very long time. We cannot 

seem to get our concerns about being overrun by gas/oil companies to the right people.”

At a subsequent interview, he stated, “I notice patients with allergy-like symptoms when they 

come to see me. I hear that sometimes within 2 to 5 hours after taking the natural medicine that 

was made for them, they start rubbing their noses or eyes again. This may be because the plants 

are not from here or are not healthy.”

He said, “During the summer, you can really smell the gas/oil residue left from the companies 

around here. The ground smells of spilled gas/oil that has been covered with dirt. I think you can 

tell how bad some of our ground and water sources are by looking at and using our local 

plants—they are no longer healthy. When the plants become dry, the edge of the leaves become 

dry. [Once] There were a lot of plants, but there is much less today; what is left is not healthy. 

When I gather plants I notice that the edges of the plant leaves are brown—a sign that something 

is bothering them. The air affects the plants we use for traditional medicine—I know this is a 

fact. The plants need air and water just like us, and those two elements are bad around here.

Around 1980, his father gathered plants. He named a few of the plants he gathers locally,

including those for infections called nii’iinił, na’ashjéiidaa’, azee has’jinii’, ya ii ya, na’is kaji, 

iicha’ji azee. “There used to be more birds too. I do not see any more eagles and ducks. I bet 

even the fish count is low. The plants with long deep roots may survive better, but for sure, the 

short-rooted plants are having a hard time. or most no longer exist. I know I have not seen any 

awee’a’tsal, tsinitłiz, or nidiyilitsoh where I used to gather them. Also, niłchił bichił is no longer 

available nearby.”

“My father used to say after plants go missing for a season or two, they will come back, and the 

plants did grow back, but now, the plants do not come back for several reasons. It does not rain, 

and the area is so hot, and the air smells now. It was not like this when I was a child helping to 

take care of sheep along the river and camping along the river. Also, when the wind blows, I am 

sure it blows in contaminated dust from all of the buried waste.”

During the interview, he mentioned that at the recent meeting with the Aneth Chapter, Resolute 

and the US EPA, the visitors kept saying “We are only talking about ‘the air quality.’” “All they 

talked about was the air, and not about water, or about plants, even though they are all 

interrelated. How can you separate them? In order for anything to live, it has to have air, water, 

and land, and all of these elements are interconnected and give life.”

11 (Aneth) Lives within one mile north of the flare. She was asked if she had any issues related to air 

quality. She stated that it does impact her life, and that she moved to the top of the mesa from 
15

Interviewee 

Number

General Interview Summaries

down below. near her extended family, to get the breeze, but she still has issues. She said she 

formerly lived below the “barrels” [tanks]. 

She said she relocated to get away from the all dust, noise, and residue from the gas facility. She 

said the flare that was rather scary because of the residue it leaves after they ignite the flare to 

burn the gas. She thought the move would help, but they still get the residue on their vehicles 

because their current place is at the same elevation as the main flare.

13 (Aneth) The Aneth Chapter president asked if arrangements could be made to scheduled site visits to tour 

the Resolute facility. He also asked if any surveys had been conducted regarding, plants, 

livestock, etc., which would tell them how far the effects of the gas industry may be impacting 

their community since 1987. They would like to see the bigger picture on how the industry may 

be affecting them.

22 

(Sweetwater)

She stated they gather plants from the area to the east (possibly the mountains) and do not gather 

near the Aneth area. She stated that she has concerns for plants because they are medicine and 

wonders if the pollutants in the air may travel down to the ground when it rains. She said. 

“Certain iłkóh is used for stomachs, including stomach cancer. We mainly use it for that ailment. 

People come to us for different medicines, and we gather and mix remedies for them. We [also] 

make medicine for asthma and breathing problems.”

“Some nights we go to sings [ceremonies] in Aneth, and I help sing. It really smells awful there. 

You can smell the residue of the gas and oil production in the air, and when the air is thick, it 

makes it hard to breathe and sing.” We go to sings in Dził nahozili, Lukachukai, Narbona Pass, 

and Ganado. I really do not know how those people and relatives can live that way—all the smell 

and such. The air feels thick and congested. Once I had to drive up to the hill to get some better 

air.”

30 

(Sweetwater)

Said [at one time] many people had sheep, and now there are a few who still have sheep. He 

continued, “There were numerous sheep, and there were no problems with the sheep eating the 

vegetation. Now there’s nothing but Russian thistles.” He is not sure if the air quality had any 

effects on the vegetation. “But something killed off the brushes,” he says.

He also said medicine such as iłk’óh was mixed with other medicines. But that cannot be found 

either; around the area, there’s none. He would drive around the area and couldn’t find any of 

that type of plants (medicine). There used to be some, such as keya hani (?), but now there are 

none. His wife’s father used to use that type of medicine plants with his patients. Such medicine 

plants (herbs) were used, such as for problems with awee’. Toward the highway there used to be 

yadihachini, used for Hozho’ji (Beauty Way). Now, you don’t find that anymore. Now one has 

to go to the mountains to find the numerous medicine plants used for nahagha. He said, “Yes, 

the air, the smells from Red Mesa when you go out there for meetings. When you go through 

Aneth, in about 2 days it’ll start to bother the nose and eyes, with burning sensations.

He also said, “At home, when you open the door, you can smell the fumes. The fumes stay with 

you and can smell them from inside your body.” He thinks that it affects all ages, that when you 

go out to other communities, people have certain attitudes. He said, “I think these environmental 

issues affect them, in a psychological way. For example, angry, negative attitudes, and people 

speaking negatively about each other.”

He asked, “when aká [oil] is inhaled or eaten over the years, how would it affect you? Is that 

how it affects people?” He thinks it works against people. He called it aka bisííl. “For example, 

dibé [sheep], they normally go in groups.” He’s noticed that it’s different now. He says they are 

crazy. “Before, they worked together. You could hear them when one gets lost or so. Now the 

sheep don’t do that anymore.”

32 

(Sweetwater)

Is sixty-six years old and has lived in Sweetwater all his life. He performs Navajo ceremonies 

such as the Big Star and Lightning, for different reasons, such as for body ailments or keeping 

evil spirits away. He has offering sites in the local area. He described how the bad air causes 

sickness, such as headaches and body ailments, and breathing becomes difficult. The air smells

like oil residue from the oil wells. He also explained that in his surrounding area the vegetation 
16

Interviewee 

Number

General Interview Summaries

has become scarce. He described the Navajo traditional medicine known as azee’, and there is 

still some left in the area. The local grasses and brushes that sheep graze on are really scarce. He 

is not sure of the local water supply because he has no water service to his home. He feels his 

Navajo ceremonial practices are not affected by Resolute’s operation. Mr. Hut currently does not 

object to the permit renewal but he did say he may change his mind.

33 

(Sweetwater)

Is a hataałi. He is 55 years old and has lived in Sweetwater all of his life. He did not disclose the 

types of ceremonies he performs.

He expressed concern about the traditional medicine azee’; he said that plants [locations for 

gathering] are not stable like they used to be. He does not know why they now tend to be 

growing in different surroundings. He did say that he did not think the plants he gathers are 

affected. However, he expressed great concerns about water. He said, “I think the water is 

contaminated and it has been affecting the local area.” 

He ended by saying he had no objection to the Resolute Natural Resources oil/gas refining 

projects because they employ Navajos. 

34 and 35 

(Aneth)

This couple was interviewed at their residence, located within 600 feet of the flare. MrsShe and 

one of her cousins have the grazing permit for this area. The Oldman family was not informed 

about the meeting on November 20, 2014. They would like to meet with an EPA representative 

to discuss their concerns. She also asked what was being done about the other flares in the Aneth 

area. 

She stated, “The gas from flare really smells in the mornings; our area smells all the time, but it 

is worse at different times. Living this close to the flare is hard. We get oil on our houses and 

cars. You can see spots of oily drops that come from the flare after it has burned. The sprinkle of 

oil on our property was confirmed by Resolute. 

We still use hataałi for our cures. We have had Naa'a’toi, Hochoxi ji , and Chishi ceremonies 

pertaining to respiratory issues.

When it blows around here the dust gets everywhere; our trees are almost all dead and we cannot 

plant anything. The hills we used for placing nitliz have been torn down. Now there’s no more of 

those, no more prayers done where the hills were.”

He remembers, “over near the flare under the sandstone ledge was an underground spring that 

was used for drinking, and for livestock. Now the spring has become only a saltwater seep which 

leaves white salty soil. The spring is ruined. All of the springs near here seem to be saltwater 

seeps, and they do not flow like they used to. The plants are affected because the springs that 

watered them are gone. Not only are our plants disappearing, our sheep numbers have been 

reduced because there is no more natural springs and hardly any plants for them to eat. The 

sheep get sick easily and die. We cannot make a living like the old ones did.”

He continued, “sometimes Resolute releases the gas through the flare tower and it really stinks, 

and I know they release CO2 into the air too. I don’t think the NNEPA know about the bleeding 

of the gases. I have reported this to Resolute and they denied releasing it. We tell Robert Billie, 

liaison with Resolute and the Aneth Chapter, but nothing was done about it. No reports are 

provided to the NNEPA. Most of the people here do not know of the bleeding/releasing of the 

bad gas. The air smells worse during the summers. We have constant headaches from the smell 

in the air. I am on oxygen now, and I blame it on living here near the flare and in the middle of 

all of this oil/gas development for over 30 years. I married into this area and we have no place to 

go. Both of my wife’s parents lived here for a long time and both died of heart problems. Now, 

we both have heart problems. My wife had a bypass done on her heart.”

He continued, “about 20 years ago, I walked into onto a site with an opened tank with H2S. I 

have had heart problems since that time. I think I am the only one in the community area who 

complains and argues with Resolute over the dangerous gas they are working with near our 
17

Interviewee 

Number

General Interview Summaries

homes.”

She said, “yes, we live too close to the Resolute facilities, but where are we expected to go? Our 

mothers and fathers have lived here, and now us. This is our family’s use area, and we have 

nowhere else to move. For a while the oil/gas workers were driving in our front yard to access 

their wells. It got so dusty in the summers and we complained, and finally we worked on the 

ROW issues. They can no longer drive in our front yard; they are using the road to the east. The 

air still gets real dusty from the traffic. The access roads have taken the medicinal plants around 

here and none are growing back. People have to go elsewhere to get the plants they use for 

medicine.”

They continued, “We were told that there would be monitoring of the flares, but sometimes at 

night the flare raises real high/big. I had a picture of the flare once when the flare was so huge it 

caught the surrounding dry vegetation on fire. People don’t understand; they come from 

elsewhere when we raise our issues. One has to actually live here to know all of the concerns. . . 

A relative who lives on the west side of the flare is currently having health problems, particularly 

with her muscles. We do not know what happened to her, but we blame our atmosphere around 

here. E Begay used to herd sheep around our use area all the time; now she gets numbness in 

parts of her body. We don’t know what to think; we ask, is it from the smells, the water, or what? 

One day we were asked to have a wedding lunch here and that flare went off, that flare got that 

stuff all over everything like the steaks, all the paper goods and items we could not replace 

because we have to bring in food from Cortez. We reported the incident and Resolute replaced 

our steaks!” 

“Every so often a Resolute supervisor may come around to ask questions about our homes and 

their facilities. We tell them that the smell is bad and tell them about the film of gas residue that 

covers our vehicles after a burn-off; it’s awful. Then the spring water is no good for the sheep 

anymore, and we can’t eat the sheep anymore either; we don’t know if they are eating good 

grass,” she said. 

The couple discussed their situation and wondered which EPA office has [jurisdiction] over their 

area: the Navajo Nation EPA, the San Juan County (UT), [the Utah] State EPA, or the San 

Francisco EPA. He knows about certain issues and worked in [different] places, so he knows 

about pipelines. He says that Resolute talks about safety but didn’t do anything about a broken 

CO2 pipeline when it was reported; all they were told was that a Resolute supervisor will contact 

them. 

They stated, “we were not informed whenever they expanded their facility or even asked if we 

would grant permission for this last expansion.” He and his father-in-law went to Cortez for the 

planning meeting regarding their area. At the time, his father-in-law asked about compensation 

for his use area. “An agreement was made that he would get $200 per year with a $50 increase 

each year. At the time, he was told the compensation was for him and the other families near the 

facility, but now everyone gets compensated even if we get the worst of it.”

“We cannot use our tachee [sweatlodge] either, because the springs where we got our water for 

the steam are all ruined—the springs are all saltwater seeps now. We haul some water from 

elsewhere. There are places over there that are just ugly; there are pipelines all over the place. 

When we report anything the answers are, ‘We will take care of it,’ but we never see any cleanup around here.”

She stated, “Our family moved here before the gas companies, but no one helps us to stop what 

is happening; we are being over-run. Nobody listens to us.”

36 (Aneth) A retired teacher and daughter of an herbalist was interviewed at her residence. (35) is her aunt. 

West of the residence was the former Phillips Petroleum facilities, one of the first gas companies 

who explored and developed the area, but since then the facilities have been sold to others.
18

Interviewee 

Number

General Interview Summaries

She stated, “there is a flare across the road from us on the east side of our home at about 1⁄4 of a 

mile from our home. Why is this flare not a part of the study pertaining to the other flare?”

She stated, “I just do not know where to start with all this oil/gas industry history and 

development here. All of the water in our community seems to be contaminated. We used to get 

our drinking water from the substation but were told the water was contaminated there too. So 

we are getting drinking water from Bluff and bottled store water. They were told even if the 

contaminated water is boiled, it would still be bad; it is not good water anymore.”

Her mother was an herbalist who knew of plants that grew in their yards that cured illnesses 

related to colds, spider bites, healing after injuries, and those related to changing of the moons. 

She said, “Most of those plants do not grow here anymore; I used to gather them with her right 

here in the sandy areas.”

Because of the flares there is no more vegetation in our community. The herbs use to grow there, 

but no longer. . . . The Indian paintbrush no longer exists there near the mesa. There was a dark 

plant used for wood, possibly chilizhini (dark plant), towards the east. There were deep-rooted 

plants, too. Yellow flowered plants were visible all around the area. 

She said, “Yes, it’s dangerous” to live in the area. When it’s windy the flare swipes the ground 

and the vegetation. Going to the clinic and using herbal medicine is different, she said. The 

management of our [health by] the clinics just prolongs our illnesses because we just return to 

this [the bad air]. “Using the plant medicine doesn’t take long for the cure, but we can’t find 

those plants around us anymore now. We have to [are supposed to] use local plants, but we have 

to travel for it, and the plants from other areas may not always work on our issues.” 

She continued, “It is affecting our lives. My mother-in-law comes to visit us but could not stay 

overnight; that’s how bad the smell is. She says, ‘I cannot breathe; I feel like choking from the 

smell.’ She leaves after a few hours.”

Her family can’t have sheep because of the fast cars passing by on the road. She says, for 

medicine you have to go to Tuba City or Chinle. Chiłdijeehi (sticky plant) used to grow around 

their area. There were [native] trees along the river, but now there are just Russian olive trees. 

Her family, such as her grandparents, would move down there during the summers, and now it’s 

impossible to move there. 

Recommendations

In order to mitigate the effect of the undertaking on Navajo traditional lifeways and cultural resources, we 

make the following recommendations.

1. The USEPA or their contractors should visit the homesites within one-half mile of the flare to see and 

analyze the oily residue that falls on their property as a result of the burning of excess gas. Resolute 

should be required to maintain the property around their installation to prevent the vegetation from 

catching fire and to prevent oil spills. The possibility of moving some or all of the facility to a location 

farther from current habitation should be seriously considered.

2. The USEPA and/or Resolute should make arrangements to discuss results of air quality tests and 

monitoring with the chapter officials and the nearby residents. A knowledgeable Navajo interpreter 

should be a part of these discussions. This should not be a standard public meeting where the scientists 

and policy makers simply notify the public using technical terms. The format of these meetings should 

include culturally appropriate explanations and discussion. Often in large Section 106 compliance scopes 

of work, the contractor is required to provide/disseminate a “popular summary” in language and format 
19

that is geared to the community. This same concept should be applied to the mitigation of effects of the 

current undertaking.

3. Although this document is intended for Section 106 compliance rather than NEPA review, we believe 

that the concept of environmental justice pertains. Executive Order 12898, dated February 11, 1994, 

requires agencies to identify and address disproportionately high and adverse human health or 

environmental effects of their programs and policies on minorities and low-income populations and 

communities. The positive effects of this undertaking on the local Navajo residents and community 

include access to high-paying jobs and revenues for the tribe. The negative effects include poor air quality 

and impacts on traditional lifeways and practices, health, soil, vegetation, wild and domesticated animals, 

and water.

4. As stated in the quote at the beginning of this report and also by interviewees throughout our fieldwork, 

it is impossible to separate air quality from the effects on health, vegetation, soil, and water—in fact, all 

parts of the environment. Baseline studies should be made to determine the current situation and 

continued monitoring should be required. If this work is already in place, local residents MUST be 

informed of the results. See #2 above.

5. The residents throughout the project area noted that problems increase during certain seasons and 

climate and topographic conditions. Any monitoring and testing should include these variables, and again 

the results should be reported to the public. See #2 above.

6. Several users of traditional medicines mentioned that the plants are not only no longer growing where 

they used to, the ones that remain are not as effective. Resolute could fund a project that is designed and 

implemented by both local traditional practitioners and botanists to inventory and document the types of 

plants used, their current range, and make recommendations for improvement. Because knowledge of 

traditional medicines is esoteric, dissemination of results should be restricted. During the fieldwork we 

were unable to contact Arnold Clifford, a local resident and Navajo botanist. Consideration should be 

given to working with him and other knowledgeable individuals on this type of project.

7. Although not specifically relevant to this undertaking, several of our interviewees noted that there are 

two other flares nearby. These same recommendations should be considered by USEPA in any 

undertakings related to those two flares.
20

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22

Appendix: NOT FOR PUBLIC DISTRIBUTION

Results of Ethnographic Interviews