Memorandum in support of motion to vacate second administrative action

TABLE OF ABBREVIATIONS FOR CITED REFERENCES

APA Administrative Procedure Act, 5 U.S.C. 551 et seq.

ARPA Archaeological Resources Protection Act, 16 U.S.C. 470aa et seq.

BIA Bureau of Indian Affairs

BLM Bureau of Land Management

COE Record of Army Corps of Engineers

COE-F Supplemental Record of Army Corps of Engineers (on FOIA)

COE-S Supplemental Record of Army Corps of Engineers (on site burial)

DKT Court docket number assigned to case filings

DOI Record of Department of Interior

ER Excerpt of Record filed with this brief

FOIA Freedom of Information Act, 5 U.S.C. 552 et seq.

NAGPRA Native American Graves Protection and Repatriation Act, 25 U.S.C. 3001 et seq.

NHPA National Historic Preservation Act, 16 U.S.C. 470 et seq.