September 30, 2021

Ms. Shannon Estenoz
Assistant Secretary for Fish and Wildlife and Parks
U.S. Department of the Interior
1849 C Street, N.W.
Washington DC 20240

Dear Ms. Estenoz:

Thank you again for meeting with us on Tuesday, September 28. We greatly appreciated the opportunity to discuss several important issues and concerns with you. It was such a good conservation that we were unable to mention several of the topics we had hoped to discuss with you! We would like to bring one of them to your attention now.

As context, we had wanted to express our support during the call for the 30×30 Initiative as described in the preliminary report. We agree with the report’s focus on supporting local conservation efforts as offering the best opportunities for net gains in “conservation value” of relatively undeveloped landscapes across the Nation. Given that focus, we recommend the National Park Service (NPS) National Heritage Area (NHA) Program as an excellent model to consider that would “support locally led and locally designed conservation efforts” as described in 30×30 Core Principle #3. There are several NHA proposals currently under consideration in Congress that merit Interior Department and NPS support.

Once such proposal involves the Alabama Black Belt National Heritage Area (NHA) and related legislation H.R. 3222 and S. 1643. The proposed NHA enjoys broad bipartisan support in Alabama, including that of the Honorable Kay Ivey, Governor of the State of Alabama; famed biologist, naturalist and writer E.O Wilson, who grew up in the Black Belt area; both Alabama U.S Senators, including S. 1643 sponsor Richard Shelby; and six of Alabama’s seven members of Congress, including H.R. 3222 sponsor Terri Sewell.

The national significance of the Black Belt region of Alabama is best summarized in an excerpt from the local proponents’ most recent submission to the NPS National Heritage Program staff, which states, in part:

The Black Belt region of Alabama and the rivers that flow through it represent one of North America’s great centers of biological and cultural diversity. “Black Belt” is a colloquial term referencing both the slash of dark fertile soil across Alabama’s midsection and the high numbers of historically enslaved Africans and African Americans living in the area.

The region, covering almost a third of the state, embraces the centers of forest and aquatic biodiversity in the United States, and its famously rich soils and landscapes had a profound impact on the culture, history and politics of not only this region, but of this country. It supported grand cities built by Native Americans long before Europeans discovered these shores and served as the site of one of the largest battles between Europeans and Natives fought east of the Mississippi River when DeSoto encountered the powerful Mabila people. The enslavement and expulsion of Native Americans from Eastern North America was sealed in this basin, as Andrew Jackson led the effort to open up these famously rich lands for modern agriculture.

It is no coincidence, therefore, that: 1) Martin Luther King marched from Selma to Montgomery on the same paths of the last great struggles for Native American independence in the Eastern United States; 2) The first great explosion of modern agriculture here fed the industrial expansion of Europe and New England; 3) The wealth of the 19th Century Cotton Kingdom here created the political center of the southern Confederacy; 4) Throngs of enslaved people marched these roads from Selma a century before King did so, following Union troops as they took Montgomery back from the Confederacy; 5) Emancipation brought new opportunities and struggles as farming patterns changed, educational opportunities were pursued, and social structures shifted and became rooted in the search for equality; and 6) Stokely Carmichael and the Student Non-Violent Coordinating Committee tested black power and voting rights here alongside thousands of unsung heroes of the Civil Rights movement.

Understanding the Alabama Black Belt, and recognizing how the footsteps of diverse human experience have tracked the natural diversity of this basin for millennia, is essential to understanding the American experience. Hundreds of little-known, but important cultural, heritage and natural sites will receive due attention, recognition, and preservation, through the establishment of an Alabama Black Belt NHA Area and complement the recent establishment of civil rights sites in the state and the Selma to Montgomery National Historic Trail.

While the landmark events of the American Civil Rights Movement—Rosa Parks’ refusal to give up her bus seat to a white passenger, the Montgomery bus boycott, the Selma-to-Montgomery marches—are remarkable and nationally significant in and of themselves, they are more richly textured and nuanced when explored in the context of the place, people, and cultural traditions from which they arose. Understanding the origins, process, and outcome of this struggle for equality is central to our national identity and to the ongoing effort in our nation to secure freedom from oppression for all citizens.

In our view, the proponents’ description eloquently captures the breadth and depth of the Alabama Black Belt’s historical context, a place where the convergence of environmental, cultural, racial, and social factors played an important role in a number of significant but not necessarily nationally known historical events and conflicts that occurred over multiple centuries. In turn, those events set the stage for the much more well-known Civil Rights events of the 1960’s.

We understand that NPS National Heritage Area Program staff has provided feedback to the local proponents on several occasions that their NHA proposal should focus primarily on the Civil Rights movement. Reflecting this narrower focus, the Department’s testimony on H.R. 3222 at the House subcommittee legislative hearing on June 15, 2021 described the purpose the Alabama Black Belt NHA as “conserving and interpreting sites and stories central to the American Civil Rights movementwithin 19 counties in the State of Alabama.” (See With all due respect, the Department’s description above is inconsistent with the local proponents’ broader vision and only tells a limited part of the rich, diverse history of the Alabama Black Belt.

In brief, we believe the proposed Alabama Black Belt NHA epitomizes this Administration’s and the Department’s vision of appropriate action related to the 30×30 Initiative. The local vision for this NHA represents the convergence of protection, conservation, and education of both natural and cultural resources in one of our nation’s most biodiverse and culturally significant regions. We urge the Department and the NPS to support the local proponents’ vision for the Alabama Black Belt. Please consider encouraging the NPS to not limit that vision to only one, albeit important, aspect of the Black Belt’s history; and help the local proponents become successful in completing the paperwork necessary to support their goal of establishing the Alabama Black Belt National Heritage Area. This approach can truly be a model for telling our American story from many perspectives!

In closing, we greatly appreciate your willingness to maintain an open channel of communication with our organization and thank you for your consideration of this particular concern.


Phil Francis Signature




Philip A. Francis, Jr., Chair
Coalition to Protect America’s National Parks
2 Massachusetts Ave NE, Unit 77436
Washington, DC 20013

Shawn Benge, Acting Director, National Park Service
Joy Beasley, Associate Director of Cultural Resources, Partnerships, and Science, NPS
Ray Sauvajot, Associate Director of Natural Resource, Stewardship and Science, NPS
Chuck Hunt, Acting Assistant Director for Legislative and Congressional Affairs, NPS