Okinawa Governor's Visit to Washington DC: Our Analysis

From January 30 to February 5, Okinawa Governor Takeshi Onaga, accompanied by a delegation of “All-Okinawa Kaigi (conference),” visited Washington D.C. It was his third visit to the center of U.S. power since he took over the office of Governor in November 2014.  

Just like in his previous visits, the purpose of his visit this time was to ask those on Capitol Hill to cancel the plan to relocate the U.S. Futenma Air Station in Ginowan City to Henoko and Oura Bay in Nago City. Throughout his visit, he emphasized that the people of Okinawa continue to oppose the construction a new base there (the Henoko plan) and that he would use all his administrative power and means to stop the construction. 

Governor Onaga at George Washington University (Kyodo)

How did Governor Onaga’s visit go? What would Governor Onaga and the people of Okinawa do next? Here are our reviews and analysis. 

Court Decision in Japan and Trump Chaos in the U.S. 
Unfortunately for Governor Onaga and Okinawa, his trip took place against the backdrop of two unfavorable circumstances. 

First of all, on December 20, 2016, the Japanese supreme court ruled against Governor Onaga, deciding that Onaga’s revocation of the land reclamation permit granted by former Okinawa governor Hirokazu Nakaima was illegal (see The Japan Times). 

Four days later on December 26, Governor Onaga withdrew his revocation, claiming that he had to follow the rule of law and insisting that he has other "administrative means" to continue his fight. His withdrawal cleared up the legal hurdle for the Japanese government, enabling the Okinawa Defense Bureau to resume its drilling surveys and construction activities, which had been halted since March 2016. 

Secondly, as the world has already known by then, with Mr. Trump in the White House, chaos was the name of the game in Washington D.C. Congress men and women as well as federal agencies were very much occupied with their own issues, and apparently they did not have time for Onaga and Okinawa.

Despite Governor Onaga’s gleam of hope that the un-orthodox President Trump and his administration still in process of being formed could provide political space for change on the Henoko plan in U.S. policy (see The Mainichi Shimbun), his team faced difficulty even scheduling meetings with Congress members and federal officials.

In short, Governor Onaga arrived in a chaotic D.C. without much to show to back up his claims. 

Media Evaluations of Governor Onaga’s Visit
Governor Onaga was able to meet twelve House representatives but no senators. He also met with Joe Young, Director for Japanese affairs at the State Department and Paul Vosti, the acting director for Japan in the Pentagon. He also participated in a symposium at George Washington University (see The Asahi Shimbun).

At a press conference at the National Press Club in D.C., Governor Onaga summarized his visit as a success and better than the previous visits. He emphasized that “We were able to gain understanding on the Okinawa base issues, including the construction of the new base, from members of the Senate and House” (The Ryukyu Shimpo).

However, the media covered and evaluated his trip differently. The Okinawan media, which reported Governor Onaga’s previous trips to D.C. in very favorable terms for him, was very critical this time. While regarding the Henoko plan as undemocratic and unjust, they casted doubt on the timing of his visit as well as what his visit had actually accomplished (see for example The Okinawa Times (in Japanese only)).

The Okinawa Times  (Feb.5, 2017)
Headlines read "Governor's enthusiasm fails to bring results" "U.S.-Japan reaffirm Henoko plan as Okinawa delegation visits U.S." "Concerns raised over "Crushing Okinawa"" 

Meanwhile, the Japanese mainland media paid little attention to Governor Onaga’s visit. Instead, they focused on the larger political shows in Tokyo of newly appointed Defense Secretary James Mattis’ meetings with Prime Minister Shinzo Abe and Defense Minister Tomomi Inada (see their joint briefing), which were taking place as Onaga was finishing up his trip. 

In fact, in most of the Japanese media coverage, Onaga’s visit and his determination to fight the Henoko plan was pitted against and was undermined by the governments’ affirmation that the Henoko plan is “the only resolution” (see The Asahi Shimbun).

The U.S. media’ coverage was minimal, to say the least. As Tim Shorrcok tweeted, he was the only U.S. reporter at Governor Onaga's press conference at the National Press Club in D.C. 

So far, we at OEJP have found only two articles on Governor's visit by non-Japanese media on the internet. One is by Tim Shorrock on the LobeLog Foreign Policy (read the article) and the other is by the Russia Today (read the article).

Our Analysis
It is probably too early to tell what Governor Onaga’s third visit to Washington D.C. has accomplished and what effects it will have in the future. 

However, reviewing our discussion with prefectural government officials and others as well as documents and media reports, we can argue that there was lack of strategic preparation and engagement on the part of Governor Onaga and the prefectural government. 

As Governor Onaga was preparing for his trip, the Okinawa prefectural government’s inquiries with the Okinawa Defense Bureau on the details of drilling surveys and land reclamation plans were still in process. Without sufficient information, it appears, Governor Onaga could not move on to use his next “administrative means” to stop the construction before his departure for Washington D.C. 
Meanwhile, as evident by the fact that there was only one U.S. reporter present at his press conference in D.C., the prefectural government failed big in terms of public relations. Dishearteningly and disturbingly, there were no releasing of statements or documents explaining Governor Onaga’s position and Okinawa’s situation from the Okinawa prefectural government before, during and after his visit.  

Moreover, the home page of the Washington D.C. Office of the Okinawa Prefectural Government, which was set up to “play a key role in the Governor’s visits to the U.S. and disseminating information on Okinawa’s situations and other matters” (see the site
), DID NOT cover its Governor's visit to D.C. (We do not know why but let you know when we find out why). 

Okinawa’s Fight Continues

It is no doubt that Governor Onaga and the Okinawa prefectural government have been overwhelmed by the Henoko issue (and other U.S. military related issues). It is also apparent that Governor Onaga and his prefectural government's capacity to challenge the Henoko plan has been undermined by both external and internal factors.

However, Okinawa's fight against the Henoko plan continues. 

As soon as the Okinawa Defense Bureau resumed drilling surveys, protesters were out in kayaks and boats in Oura Bay as well as were at the front gate of Camp Schwab in Henoko (The Asahi Shimbun).  Back in his office in Okinawa, Governor Onaga and his team are now examining his "administrative means" and assessing when to take the next step to halt the construction. 

Protesters on kayaks and Japan Coast Guard
photo by T. Kitaueda
In our view, there are two important elements that have kept and will keep Okinawa’s fight going.

One is the determination of the people of Okinawa and their supporters to fight. Their determination comes from their experience of suffering from living with so man military bases on their small islands for 70 years (see for example The Mainichi Shimbun and The Japan Times). Enough is enough.

The other element is the invaluable natural environment of Henoko and Oura Bay. As an integral part of northern Okinawa Island (a part of this area has been officially nominated for World Natural Heritage Status), the natural environment of Henoko and Oura Bay provides the people of Okinawa with both a reason and a tool to continue their fight (see IUCN Recommendationthe joint statement by 19 academic and scientific societies, and this joint statement by NGOs).   

Blue Coral in Oura Bay
photo by Osamu Makishi

OEJP joins Okinawa's fight against the construction of a new U.S. military base in Henoko and Oura Bay on the environmental front. 


A Ceremony Nobody Celebrated: Return of Land

On December 22, 2016, the U.S. and Japanese governments jointly held a ceremony in Nago City, Okinawa to mark the return of 4.000 hectares of the U.S. military’s Northern Training Area in northern Okinawa Island to Japan. Both governments tried to promote the event as celebratory as possible (see the U.S. Embassy website). 

Photo by Lance Cpl. C. Robertson

However, the ceremony was an awkward and blundering event in the sense that no one seemed to be in mood for real celebration (see The New York Times and Truthout)

The return of land is certainly a positive development for Okinawa. Many in Okinawa were however not celebrating because the land return deal was contingent upon the construction of six new helipads next to the community of Takae in Hagashi village. They were angry that the Japanese government took an iron hand approach to finish the construction in time for the ceremony by oppressing and arresting protesters (see The Japan Times). 

Okinawa Governor Takeshi Onaga, along with many prefectural assembly members and national diet members from Okinawa, did not attend the ceremony, declining the Japanese government’s invitation (see Governor Onaga's letter declining the government's invitation).

Governor Onaga was outraged because not only a U.S. military MV-22 Osprey crashed in the coastal area of Abu, Nago city on December 13 (see BBC News). But also because the U.S. military resumed the operations of MV-22 Osprey on December 19, ignoring Onaga’s plea to halt their  operations until the U.S. military's investigation over the crash is complete (see Governor Onaga's statement).

Photo Sankei Shimbun

Instead of attending the governments' land return ceremony, Governor Onaga joined a protest rally held in Nago city, condemning the crash and demanding the removal of the MV-22 Osprey from Okinawa.

Of course, the U.S. and Japanese governments were irritated about many people in Okinawa not appreciating the return of land and Governor Onaga not showing up for the ceremony. Chief Cabinet Secretary Yoshihide Suga said "it was extremely deplorable that the governor who has called for reduction of the military presence did not attend the ceremony" (see Stars and Stripes). 

At the same time, it is easily assumed that both governments were vexed. The crash of a MV-22 ruined this important opportunity for the governments to legitimize their 1996 SACO agreement, which stipulates the construction of helipads in the Yanbaru forest and of a new U.S. air base in Henoko and Oura Bay, Nago city. Many in Okinawa have come to see the SACO agreement as oppressive.

The U.S. military itself was probably frustrated as well. Not only that it has lost 4, 000 hectares of its training area. But also some of the helipads, declared “complete” by the Japanese government in time for the ceremony, appeared not to be so (see Choi san no okinawa nikki and Tokyo Shimbun/TOKYO web). In fact, there has been no official word from the U.S. military regarding the readiness and safety of the helipads for use. The use of the incomplete helipads by MV-22 could lead to another disastrous accident. 

Photo taken by a citizen on December 16 (Choi san's blog)
U.S. military personnel conduct inspection on the H-Area landing zone (helipad)

Photo taken by a citizen at H-Area on December 16 (Choi san's blog)
Despite the Japanese government's declaration that the construction of all the helipads was now complete, construction work was still in process.  

All the anger, outrage, irritation and frustration surrounding the ceremony can be explained by this simple fact: too many U.S. military bases and facilities are still in Okinawa. With the return of land to Japan and Okinawa, now 70 percent (down from 74%) of the U.S. military bases and facilities are still concentrated in Okinawa, which accounts for only 0.6% of Japan’s land mass.

Following the Rand Corporation’s report, Overseas Basing of U.S. Military Forces: An Assessment of Relative Costs and Strategic Benefits (2013), it can be argued that the concentration of U.S. military bases in Okinawa has caused strong anti-U.S. military sentiment among the people of Okinawa; it has constrained the U.S. military’s capacities to train, and it has made the U.S. military bases vulnerable to "threat from long-range precision-guided weapons of adversaries.”

President-elect Donald Trump during his presidential election campaign insisted that Japan should shoulder its share of defense costs. 

It is time for the U.S. government and military to tell the Japanese government that "burden sharing" should be sought for not only in financial and strategic terms between countries, but also on the principles of democracy, equality, and justice between countries, regions and people within the countries.

Okinawa Environmental Justice Project

P.S. The U.S. military in Okinawa will face a difficult situation as the inscription process of the Yanbaru forest for World Natural Heritage moves on to the next stage in early next year (see NGOs' Letter of Concern and Request). The presence of the U.S. military Northern Training Area in the forest should be a hot topic among the UNESCO's World Heritage committee as the construction of helipads and the conduct of U.S. military training in the forest could hinder the chances of success for the forest in its bid for recognition as a World Natural Heritage site. 


Launched in November 2016, the Okinawa Environmental Justice Project strives to protect the environment and the lives of people in Okinawa, Japan through the means of "connecting the green dots." That is, we reach out to, connect, and make best use of available resources in local communities, environment NGOs, domestic institutions and laws, and international institutions and conventions in bringing environmental justice to Okinawa. We believe that, by protecting the environment, we can also improve the quality of life and promote peace/genuine security in Okinawa and beyond.

map enclosed with the letter
 As our first action, we, along with 38 other Okinawan and Japanese organizations, are sending a letter of concern and request to the U.S. government and the U.S. military regarding the future of the Yanbaru forest in northern Okinawa Island.  

Can the Yanbaru forest become a World Natural Heritage site? Or would the presence of the U.S. military's Northern Training Area in the Yanbaru forest, low altitude flight training, and the construction of new landing zones hinder the forest's chance of becoming a World Heritage Site?  Would the U.S. military and the U.S. government make sure that the Yanbaru forest become a World Heritage site? These are some of the concerns and reqeusts expressed in the letter. 

Please read our letter and help spread the word. 

*PDF versions of the letter (without photos) and the map are also available for download at the very bottom of this blog page.

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 the construction 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 and peace 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 in October 2016 that the Bureau plans to clear-cut over 24,000 trees for construction of landing 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 of landing 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 the Japanese government.

The opposition to the construction comes from various quarters. The residents of Takae in Higashi village have been opposing it since late 1990s because these landing 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 military burden 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 take place 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 the NTA to Okinawa in the Special Action Committee on Okinawa (SACO) agreement in 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, and thus the Japanese government is accountable for the construction of those landing zones. 

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 to take “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 make decisions over whether or not to allow the construction of landing zones in the NTA.

landing zones under construction Nov. 2016

           photo provided by S. Kirishima

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 the richest biodiversity areas in Japan. It is home to some 5,400 species of fauna and over 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 and endangered species such as the Okinawa woodpecker (Sapheopipo Noguchii) and the Okinawa rail (Rallus okinawae) are the best known of the well-known habitants of the Yanbaru forest. They are also Japan’s “Natural Monuments.” It is most appropriate 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 the Yanbaru 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 body for 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 was taken over by the U.S. military and converted into the U.S. military’s Northern Training 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) landing zones for military aircraft and other training facilities in the NTA. Loud noise emitted from aircraft, land contamination from disposed materials and crashed aircraft, 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 is defined 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 proper consideration to this World Natural Heritage inscription process of the Yanbaru forest. None of the U.S. military’s documents available to the Okinawa public acknowledges 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 the deployment 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 the Japanese Ministry of the Environment and the Okinawa prefectural government were engaging in preparation for the inscription process despite the fact that their preparation was in 2012 (when the Environmental Review was published) already well 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 ignores information 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 to acknowledge the World Natural Heritage inscription process, along with the construction of the landing zones, the violent confrontation and human rights violations and the training of U.S. military aircraft, all hinder the inscription process. 

MV-22 Osprey terrain flight training in the Yanbaru forest
photo provided by T. Kitaueda

U.S. National Historical Preservation Act, World Heritage Convention, and Our Requests
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 the Yanbaru 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 prepared and submitted by States Parties jointly in conformity with Article 11.3 of the Convention. It is highly recommended that the States Parties concerned establish a joint management committee or similar body to oversee 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 the consent of the state concerned. The inclusion of a property situated in a territory, sovereignty or jurisdiction over which is claimed by more than one State, shall in no way prejudice the rights of the parties to the dispute.

Please be reminded that the U.S. military’s NTA, over which the U.S. has jurisdiction, is located in a sensitive part of the Yanbaru forest and that the coordinates 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 ally country.

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 the spirit and intent of 402 of the National Historical Preservation Act,

That the U.S. military, in consultation with local communities, prefectural and national (Japanese) government, and relevant NGOs, conduct an assessment regarding the impact of allowing the construction of landing zones and the conduct of aircraft and other types of training in the Yanbaru forest on the inscription process of 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 on Historical Preservation and the Office of the Assistant Secretary of Fish and Wildlife and Parks, should be involved in the assessment process.

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 Japan

The Nature Conservation Society of Japan
Greenpeace Japan
Friends of the Earth Japan

The 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 Center

Dugong Protection Fund

The 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 of Christ in Japan

Committee on International MissionNorthern Branch, Tokyo District, The United Church of Christ in Japan

Shinshu OtanihaKyugjonokai 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

Hideki Yoshikawa
Okinawa 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