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Meeting minutes of January, February, and March 2021, disclosed that opposition took KNHAP entirely by surprise, as did Governor Rickes' leer. A troubling issue of the NHA process was recorded in the February 25, 2021 minutes: "Not worth our while to have public meetings until FS [Feasibility Study] is in motion because they will have to be part of that process." Is this the prevailing aitude of NHA proponents toward residents and counties to be exploited for a feasibility study? KNHAP considered including student work hours as in-kind contributions for grant applications. Is it ethical or legal to use student work hours at UNL as in-kind contributions for a nonprofit? Public-Private NPS partnerships provide a fertile field for collusive, corrupt, illegal, and unethical activity, not to mention hidden agendas. One case out of Mississippi Gulf Coast National Heritage Area (MGCNHA) involved the purchase of real property with NHA federal funds. e Final Audit of Management of NHA Program Funds Under Cooperative Agreement No. H5041110008, found poor NPS oversight provided an opportunity for former Mississippi Department of Marine Resources and MGCNHA managers to dispense program funds to hand-picked sub-recipients. e Audit also found the NPS did not have policies and procedures in place that focused on oversight, failed to enforce single audit requirements, and failed to publicly report program awards and subawards. Canyons & Plains NHA demonstrated a lack of transparency, failure to disclose, the appearance of impropriety, failure of leadership, unprofessional behavior, misinforming the public, incompetence, potential conflicts of interest, failure to perform due diligence, failure of NPS to adhere to a feasibility study agreement, collusion between local, state, and federal entities, and gaining access to private property under false pretenses. Canyons & Plains and the NPS hid the process from the public for almost ten years under the guise of heritage tourism, representing the biggest scam the region ever witnessed. Heritage tourism is touted as a driver of economic development while representing a small niche in the industry. Colorado tourist season runs from Memorial Day to Labor Day, followed by big game and winter sports seasons. Great Falls is listed on the Lewis & Clark National Historic Trail interactive map with links to High Potential Historic Sites, and the Missouri River is already listed as wild and scenic. ese aractions can be accessed on a smartphone without NHA and NPS management and oversight. Freedom's Frontier NHA has operated under a management plan since 2009. Of the 41 counties there, 21 Kansas and eight Missouri counties lost population between 2010 and 2018, calling into question the economic benefits of heritage tourism. e pandemic all but shut down the hospitality and tourism industry, with NPS units still under strict Covid protocols. e NHA program was designed in the early 1980s when print, radio, and television advertising were paramount. Currently, any individual, business, or group can exploit social media to bring aention to aractions, businesses, and events that can be linked without the intervention of a nonprofit partnering with the NPS. Nonprofits covet large designations where board members don't live, work, maintain a business, own property, pay taxes, or represent any significant constituency. e NPS projects its conservation and preservation agenda beyond the land it occupies through the use of these nonprofits. Nonprofits seeking designation covet the use of property that doesn't belong to them, all of the lands within a federal boundary, regardless of the owner's desire to have their property excluded. Big Sky Country, Canyons & Plains, KNHAP, and the NPS aempt to exploit whole regions for their own benefit without property owners' knowledge, notification, or consent. Whether in Colorado, Kansas, Montana, or Nebraska, residents and property owners have a right to oppose an unelected nonprofit in partnership with the NPS when they perceive an NHA does not serve their region, diminishes their private property rights, and subverts local sovereignty. Despite significant to overwhelming opposition to these designations, BSCNHA and KNHAP continue to pursue them. e boom line expressed in many resolutions is: "e Board of County Commissioners does not wish to confer upon an unelected management entity, the ability to influence land-use policy and economic development in this county." Land use policy and economic development reside properly in the hands of accountable elected officials. SIGNATURE MONTANA | 93 Ross Butcher, Fergus County Commissioner, Kings Arena, MT, October 15, 2020. Norman Kincaide was raised in Pueblo County, CO. Earned degrees in history from, University of Colorado, University of Northern Colorado, and ASU, Ph.D. After 22 years in legal publishing retired to Rocky Ford, CO in 2008. S MT

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