J_A_SAM_Posting_1.pdf

United States Department of the Interior

BUREAU OF LAND MANAGEMENT

https://www.blm.gov

JUSTIFICATION AND APPROVAL

FOR ACQUISITIONS UNDER THE SIMPLIFIED ACQUISITION PROCEDURES

This document sets forth the justification and approval as required by 13.106-1(b)(1) & (2).

1. Contracting agency and activity.

The Department of the Interior, Bureau of Land Management (BLM), requests the Utah State

Office to contract on a sole source basis.

2. Nature and/or description of action being approved.

The Vegetation Management Ethnographic project is a new contract which requires a sole source justification due to the sensitive nature of ethnographic research. The purpose of this project is to identify traditional vegetation management techniques within the Color Country District

(CCDO), specifically traditional vegetation management techniques employed by the Paiute

Tribe of Utah (PITU). The PITU have requested to work with specific ethnographers (see

Attachment 1) to appropriately convey important traditional ecological knowledge.

3. Description of supplies or services.

Traditional Ecological Knowledge (TEK) informs land managers as to how landscapes have been traditionally managed prior to contact. Extensive urban growth and construction within densely vegetated areas have led to increased risk of destruction within the Wildfire Urban

Interface (WUI). The systematic suppression of fire throughout the western United States has led to significant overgrowth, unresistant species, and poor ecological health due to extensive resource competition and climate change. The completion of a detailed ethnographic study focusing on traditional vegetation management techniques will assist land managers in developing habitat restoration projects and initiatives utilizing TEK.

4. Estimated dollar value.

The proposed project is estimated to cost $90,000.00 based upon the Government Services

Administration (GSA) Pricing for Labor Category Ceiling Rates and the GSA Independent

Government Cost Estimate. This labor estimate is based upon the maximum hourly rate for a

Senior Anthropologist an Archaeological Technician 1, and a Tribal Coordinator including travel expenses (see the Independent Government Cost Estimate attached).

https://www.blm.gov/

5. Statutory authority.

__X_ 41 U.S.C. 1901 – Simplified acquisition procedures (use when the simplified procedures for purchases of property and services for amounts (1) not greater than the simplified acquisition threshold

_43 U.S.C. 869 Recreation and Public Purposes Act of 1926

_54 U.S.C. 100101 National Historic Preservation Act of 1966

_42 U.S.C. 4321 National Environmental Policy Act of 1970

_43 U.S.C. 1701 Federal Land Policy and Management Act of 1976

_42 U.S.C. 1996 American Indian Religious Freedom Act of 1978

_16 U.S.C. 470 Archaeological Resources Protection Act of 1979

Guidance for Federal Departments and Agencies on Indigenous Knowledge (Traditional

Ecological Knowledge) 2022

Advisory Council on Historic Preservation (ACHP) Policy Statement on Indigenous Knowledge and Historic Preservation 2024

ACHP Traditional Knowledge and the Section 106 Process 2021

ACHP Policy Statement on the Confidentiality of Information about Indian Sacred Sites 2021

Indian Sacred Sites Executive Order 13007 of 1996

6. Rationale supporting use of the authority stated in paragraph 5.

The PITU have requested to work with Diane E. Austin of the Bureau of Applied Research in

Anthropology, a subsidiary of the University of Arizona, as Dr. Austin has demonstrated unique qualifications and has extensive and recent experience working with the PITU community.

Ethnographic research requires extensive experience working with Tribal communities and will provide a unique product identifying traditional vegetation management practices which are vital for understanding how to better manage the landscape. Dr. Austin has completed several research projects with Federal Agencies such as the Bureau of Reclamation, National Park

Service, and the Bureau of Land Management.

Notable projects and publications include but are not limited to:

Austin, Diane and Brenda Drye. 2011. The Water that Can’t Be Stopped: Southern Paiute

Perspectives on the Colorado River and the Operations of Glen Canyon Dam. Policy and

Society 30(4):285-300.

https://www.whitehouse.gov/wp-content/uploads/2022/12/OSTP-CEQ-IK-Guidance.pdf https://www.achp.gov/sites/default/files/2024-03/SummaryofComments25March2024_0.pdf https://www.achp.gov/sites/default/files/2024-03/SummaryofComments25March2024_0.pdf https://www.achp.gov/sites/default/files/2021-05/TraditionalKnowledgePaper5-3-21.pdf#:~:text=The%20Advisory%20Council%20on%20Historic%20Preservation%20%28ACHP%29%20applies,properties%20of%20religious%20and%20cultural%20significance%20to%20them.

Austin, Diane E., Dean, Erin, and Justin Gaines (2005). “Yanawant: Paiute Places and

Landscapes in the Arizona Strip.” Volume 2, Arizona Strip Landscapes and Place Name

Study.

Austin, Diane E. 2004. Partnerships, Not Projects! Improving the Environment Through

Collaborative Research and Action. Human Organization 63(4):419-430.

Austin, Diane E. 2003. Community-Based Collaborative Team Ethnography: A

Community-University-Agency Partnership. Human Organization. 62(2):143-152.

Additionally, Dr. Austin is currently working on Ethnographic studies with the PITU regarding the compilation of traditional plant species and uses throughout Bryce Canyon National Park and has been instrumental in working with PITU to record important information in and around Glen

Canyon Dam. Dr. Austin has worked with Southern Paiute Tribes since 1991 focusing on TEK, traditional and sacred landscapes, and ecological use.

Due to significant issues and concerning ethical behavior with other ethnographic and anthropologic researchers in the past, the PITU will only work with specific anthropologists and ethnographers. Many previous ethnographic studies misrepresent Tribal knowledge and convey inaccurate information which impacts the land managers ability to utilize TEK in the decision-making process. The PITU have a long standing and good working relationship with Dr. Austin, who has consistently worked with the Tribe regarding TEK over the past 25 years.

7. Other information.

The PITU have requested to work with specific ethnographers and are not willing to work with other sources. The misrepresentation and inaccurate display of information utilized in previous ethnographic research projects conducted in Utah not only impacts the land managers ability to utilize TEK but impacts the Tribe’s ability to convey important traditional vegetation management practices.

8. The efforts to identify additional sources including the market research conducted.

No market research was completed for this project as the PITU have identified specific ethnographers who they are willing to work with for this project. The Tribe is not willing to work with other ethnographer sources.

9. Future plans to permit competition.

The proposed action is a one-time requirement, therefore, an increase for future competition is not required as there are no planned acquisitions for or related to this requirement and it is unlikely any will develop.

10. The ordering activity Contracting Officer’s certification that the justification is accurate and complete to the best of the Contracting Officer’s knowledge and belief and evidence that the supporting data that form a basis for the justification have been certified as complete and accurate by technical/program personnel.

I certify that the facts and representations under my cognizance, which are included in this justification, and which form a basis for this justification, are complete and accurate.

//Signature on File//

Name Emily Swett Date

District Fuels Archaeologist

Contracting Officer’s Representative

I certify that the justification is accurate and complete to the best of my knowledge and belief:

Byron Anderson, Contract Specialist Date

Utah State Office

Temujene H. Makua, Contracting Officer Date

Utah State Office