The Pacuache Clan of Texas
Missions Indians San Juan Baustista-San Bernardo-San Francisco De Solano Missions our Ancestral
Sacred Lands Anacacho Dacate Sacatsol Mountains, Chotilapacquen, Ona River Elm Creek, PilapaxamPulapacxam River, Nueces River and Rio Grande River, San Antonio Missions Yanaguana Land Indigenous
Missions Lineal Descendants to Texas and North Eastern Mexico. Tribal Nation Sovereign, Inherent and
Self Government. 1675 Foundation
February 28, 2015
To the Texas Parks and Wildlife Commissioners Board:
The following is a Formal Complaint to the Texas Parks and Wildlife Commissioners Board, as well as our
Tribe request that Texas Parks and Wildlife conduct an intensive investigation regarding a repeating
pattern of criminal violations and gross negligence by the City of San Antonio (COSA) and the Local
Government Corporation (LGC) called HemisFair Park Area Redevelopment Corporation (HPARC), of
Chapter 26, the Protection of Public Parks and Recreational Lands, Title 3. Parks and Wildlife Code
Section 26.001 (1) (2) (a) (b) (c).
This repeating pattern of violations by COSA and HPARC date back to 1994 when over three acres of
HemisFair 14.97 Acre Dedicated Park were consumed by the Henry B. Gonzalez Convention Center
Expansion. No ordinance or replacement of this cannibalized Dedicated Park acreage, in another part of
HemisFair Park’s nearly 50 acre contiguous tract occurred even though San Antonio City Council was
repeatedly and formally requested to correct this plundering with an ordinance.
In July 2013, this pattern repeated itself again, when nearly two more acres of the same 14.97 acre
Dedicated Park tract, that is National Historic Register District Eligible, were excavated and converted
into a parking lot principally for benefit of a Restaurant in the Tower of the Americas. Again, this was
done without the prerequisite public review, public vote or City Ordinance. This National Historic
Eligible Dedicated Park Land, adjacent to Federal Property, was replaced by close to 200 paved parking
spaces. COSA, as well as HPARC in this case, were catering to the very influential owner of the
restaurant located in the Tower of The Americas who complained about losing valuable parking spaces
due to the latest Henry B. Gonzalez Convention Center expansion.
A third violation occurred during November 2013, when additional Dedicated Park Land in HemisFair
Park’s 4.081 Yanaguana Garden Children’s Tract was converted into an Emergency Road, as well as
below surface “infrastructure” to support an adjacent for profit retail/residential/commercial project
within our historic park (Yanaguana) Coaguiteca Park footprint and where our Tribe Religious Practices
were violated by COSA trademarking and patent our Religious Sacred Yanaguana and named “New Park”
without our permission. And a fourth time, on February 2015, Dedicated Park Land of this same
Children’s Play Ground area was replaced with a Paved Parking lot for exclusive use of private
construction company workers and subcontractors.
Perhaps most damaging, a Fifth violation occurred as an outgrowth of the final Civic Park Design by the
firms Gustafson Guthrie Nichol (GGN) and Alamo Architects. According to Lead Designer Ms. Kathryn
Gustafson, the nearly 8 acre park was reduced to only two acres in order to maximize commercial
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seating and a buffer for the bars and restaurants HPARC demanded and which are envisioned to circle
this area. This leaves a little Commercial Commons (A style Roman Bacchanal), which will be used, “247” according to Downtown Operations, for music and entertainment to benefit, principally, Convention
Center and out of town visitors staying in the nearby, as well as future hotels planned for the park.
(REFER TO IMAGE NEXT PAGE)
FINAL CIVIC PARK DESIGN OF GGN, December 2014, One Year after Ordinance establishing 18+ acres of
Park Land, COSA and HPARC’s failure to satisfy the requirements of 2014 State Legislation in a fact that
need reviewed by both TPWD and the Federal Government and failing to meet requirements of 2014
State Legislation. (Photo courtesy of HPARC)
To The Honorable Commissioners Dan Allen Hughes Jr., Chairman, Ralph H. Duggins Vice-Chairman, T.
Dan Friedkin, Roberto De Hoyos, Bill Jones, James H. Lee, Margaret Martin, S. Reed Morian, Dick Scott,
Lee Marshall Bass, greetings. The Pacuache Clan of Texas herein submits our Formal Complaint /
Request for Investigation to you. We request that a serious investigation be conducted and those
responsible be held accountable to the fullest extent of the law. We request that a Forensic Accounting
of Park Acreage, by a mutually acceptable licensed Texas Surveyor, take place in order to calculate The
HemisFair Historical Dedicated Park Lands that have been taken without due process. These acres are
integral, as well as sacred part of our Mission San Antonio De Valero / The Alamo Mission site founded
in 1718. Historians, such a Richard Santos, confirmed that what is now called the HemisFair Yanaguana
Garden Tract possesses the oldest exposed archaeological features of our Mission Site in Bexar County.
A grave SOCIAL INJUSTICE has occurred. We requested many City, State and Federal agencies to
include the Mission San Antonio de Valero/ALAMO archaeological heritage in HemisFair Park that was
negligently place in harm’s way as World Heritage Property and a major contributing Historic Resource
of our state and nation’s prestigious World Heritage Site Inscription. This would have helped prevent
the adverse impacts which are taking place at the hands of COSA, HPARC and many special interest
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groups behind this project at this very moment. With arrogance, our multiple requests were rebuffed
and with taxpayer dollars, our Religious Rights, Civil Rights violated.
The HemisFair Historical Dedicated Park Lands were composed of 14.97 acres of Dedicated Park Land,
with the archaeological record of important parts of HemisFair Park a Religious Indian Burial Sacred Site
remaining both undisturbed, as well as open for enjoyment of current and future generations. These
historic resources, dating back to as early as 1719, identify the spot where Mission San Antonio de
Valero was relocated and its religious facility constructed on the east side of the San Antonio River. The
Boundary and gateway into this area are delineated by the Acequia Madre de Valero, 95 feet of which
were restored in 1968, however, an even larger area has been neglected by UTSA, the City Management
and City Council of San Antonio, the Texas Historical Commission and other special interest groups who
view Historic HemisFair Park as a mixed-use, multi-family residential play for the long-term benefit of a
greedy few special interest groups.
Another key feature of our Sacred Mission San Antonio de Valero Religious Site is The Camino Real De La
Bahia Del Espirtu Santo, also known as Old Goliad Road. Several of our Sacred Religious Indian Burial
Sites front both the Acequia Madre de Valero, as well as this Historic Camino Real Trails that traverse
HemisFair Park and whose terminus is Mission San Antonio de Valero/Alamo Plaza, a.k.a. The Alamo.
HemisFair Historical Dedicated Park Land is being manipulated and desecrated. Historic Resources are
being irreversibly destroyed and forever lost to all future generations – without public review or
comment. The most important Historic Park and Spanish and Mission Indian resources of our state are
being parceled out by developers (who are being handsomely compensated by both salary and quid-proquo housing incentive monies), to their developer friends. Natural and Historic Resources vital to our
people and our future generations are being systemically replaced with parking lots, parking garages, as
well as inappropriate for profit projects atop at our Religious Indian Sacred Burial Sites.

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Exhibit “A” shows several hundred parking spaces illegally created on parkland in July 2013.
Exhibit “B” shows dedicated park acreage illegally taken and replaced with an Emergency Road
and commercial project infrastructure during the month of November 2013.
Exhibit ”C” shows Dedicated Park Land of the historic HemisFair “Park” Yanaguana Garden
Children’s Play Ground area with a Parking lot exclusively for construction workers/special
interest groups on February 2015.
Violations under Chapter 26 Sec. 26.001 (1)(2)(a)(b)(c) are so well documented, we would like to know
why the Texas Parks and Wildlife Agency, and specifically those that represent San Antonio on your
board, have done nothing!
Additionally, state law required the City’s authority (under code 379C.014), to adopt a Urban Land Bank
Demonstration Program and approval of the HemisFiar Park Public Facilities Corporation as the City’s
Land Bank, as well as the dedication of at least 18 acres of public squares or parks in HemisFair Park, all
to take place before January 1, 2014 in order to develop portions of HemisFair without a Public Election.
We request the TPWA to conduct a Forensic Accounting / Survey, as the City of San Antonio has simply
failed, with gross negligence, to provide the prerequisite 18 acres. Even worse, at the onset of the
HemisFair Project, San Antonians’ were promised that a minimum of 24 acres of park land would be set
aside. That was reduced to 20, then to 18 by Leticia Van De Putte her signed Legislature House Bill 930
and by Representative Mike Villarreal his signed Legislature House Bill 2018, and now we calculate it has
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been reduced more to a meager 15 acres … close to half what was both promised and set forth within
the HemisFair Park Area Redevelopment Master Plan!
Our Clan, herein, also brings to the attention of the Texas Parks and Wildlife Commissioners that the City
of San Antonio ingeniously utilized FRAUDULENT CREATIVE ACCOUNTING. The City of San Antonio
ingeniously substituted undisturbed Natural/Archaeological resources for previously developed during
HemisFair ’68 concrete, “SeaWorld” like, for profit, river barge entertainment infrastructure and the
Patio for elite Ruth Chris Steak House clientele. We believe this represents a sixth violation. This is no
joke!
Our Clan under our Religious Practices cites the Executive Order 13007 in the Protection of Religious
Sacred Sites, The Native American Religious Act 1996, NAGPRA The Native American Protection
Repatriation Act 1990 that applies to The HemisFair Historical Dedicated Park Lands as well as those of
la Villita a Religious Indian Burial Site and an original Indian Village founded by our Ancestors on 1720.
Commissioners our Clan Requests TPWD conduct from you a complete investigation of this criminal
manipulation and desecration / destruction being fast-tracked without public and Native American
input, over HemisFair Dedicated Public Park Land that is our Native American Archaeological Religious
Sacred Ground Site whose historic resources are vital to our nation’s future World Heritage Site.
Our Clan appreciates your urgent intervention and requests an exhaustive investigation of an ongoing
pattern of criminal violations of Chapter 26 of the Texas Parks and Wildlife Code.
Respectfully,
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The Pacuache Clan of Texas
The Coaguilteca Indian Tribe First Nation
Mary Torres
Tribal Chairwoman
P.O. Box 790434
San Antonio, Texas 78278
(210) 341-9275
Enclosures
Cc,
Texas Parks and Wildlife Commissioners,
Dan Allen Hughes Jr., Chairman, P.O. Box 14 Beeville, Texas 78104
Fax. (361) 881-1686
Ralph H. Duggins Vice-Chairman, 600 W. Sixth, Suite 300 Forth Worth, Texas 76102
Fax. (817) 877-2807
T. Dan Friedkin 1375 Enclave Parkway Houston, Texas 77077
Fax. (713) 580-5220
Roberto De Hoyos 2200 West Loop South, Suite 800 Houston, Texas 77027
Bill Jones 100 Congress Avenue Suite 2000 Austin, Texas 78701
Fax. (512) 469-6306
James H. Lee 1330 Post Oak Blvd, Suite 1550 Houston, Texas 77056
Fax. (713) 552-1441
Margaret Martin 215 West Bandera Road Suite 114-619 Boerne, Texas 78006
S.Reed Morian 300 Jackson Hill Houston, Texas 77007
Fax. (713) 863-8202
Dick Scott P.O. Box 2489 Winberley Texas 78676
Fax. (713) 453-2756
Lee Marshall Blass 201 Main Street Forth Worth, Texas 76102
Fax. (817) 390-8408
Texas Parks and Wildlife Department
Carter Smith Executive Director
Texas General Land Office
Commissioner George P. Bush
Texas Historical Commission
Mark Wolfe Executive Director
Mark Denton Project Review State and Federal Preservation Programs
Greg Smith National Register Keeper
Pat Mercado Allinger Head Archeologist
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Unites Nations Cultural Fund for
Indigenous Human Rights
World Heritage Nominations Committee Paris France
Secretariat ICOMOS
World Heritage Experts
Dr. Gustavo Aroez
Dr. Ruben Mendoza
Dr. Jaime Font Fransi
Dr. Francisco J. Lopez-Morales, Director Del Patrimonio Nacional Del Instituto Nacional Arquelogico y de
Historia de Mexico
Dr. Gordon Fulton
Dr. Emilio Jose Luque-Ascona
Independent Expert Acequias
Dr. C.R. Porter
Ivan Myjer, Principal Building and Monument Preservation
Dr. William E. Doolittle
Professor of Geography
Dr. Maria Carolina Flores
Professor of History
Dr. Felix Almaraz
Peter T. Flawn Distinguished University Professor of Borderlands History
Dr. Andres Tijerina
Professor of History
Dr. Juan De La Teja
Estate of Texas Historian
Dr. Paul T. Ringenbach
Professor of History
The National Registar Hisorical Preservation
Ms. Carol Shull National Registar Keeper
Washigton, D.C.
The National Historical Preservation Council
John Fowler Executive Director
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Valerie Hauser Office of the Native American Affairs Director
W. Dancing Feather
John Wilson Project Anaylist
Indian Tribes First Nations
San Antonio Missions Coahuiltecas Indians Lineal Descendants
Terry Bustillos Pampopa-Piquhuique Clan, Olivia Valero Malaquia-Pauguaxcan Clan, Diana Flores Lipan
Apache- Chayopin Clan ,Mary Jane Martinez Borrado Clan, Cynthia Rodriguez Pampopa Clan, Vicente
Huizar Pampopa Clan, Rudy Perez Manos de Perro Clan-Lipan Apache, Antonio Diaz Pamaque Clan, Ron
Rocha Garza Clan,
Lance Aaron Historical Preservationist Cherokee Lineal Descendant
Shawnee Tribe of Oklahoma Edwina Butler-Wolfe, Governador, Karen Kaniatobe, Tribal Historic
Preservation Officer, Alabama-Coushatta Tribe of Texas Ronnie Thomas, Chairman, Alabama-Quassarte
Tribal Town Tarpie Yargee, Chief, Apache Tribe of Oklahoma Donnie Donald Cabaniss, Jr Chairman,
Caddo Nation Brenda Edwards, Chairwoman Robert Cast, Tribal Historic Preservation Officer, Cherokee
Nation of Oklahoma Bill John Baker, Principal Chief, Choctaw Nation of Oklahoma Gregory E. Pyle, Chief,
Dr. Ian Thompson, Tribal Historic Preservation Officer, Comanche Nation of Oklahoma Wallace Coffey,
Chairman, Coushatta Tribe of Louisiana Lovelin Poncho, Chairman, Linda Langley, Tribal Historic
Preservation Officer, The Delaware Nation C.J. Watkins, Acting President, Jicarilla Apache Nation Ty
Vicenti, President, Jeffrey Blythe, Tribal Historic Preservation Officer, Mescalero Apache Tribe Sandra
Platero, President, Holly Houghten, Tribal Historic Preservation Officer, Muscogee Creek Nation George
Tiger, Principal Chief, Emman Spain , Tribal Historic Preservation Officer, Poarch Band of Creek Indian
Buford L. Rolin, Chairman, Robert Thrower, tribal Historic Preservation Officer, Quapaw Tribe of
Oklahoma John L. Berrey, Chairman, Everett Bandy, Tribal Historic Preservation Officer, Thiopthlocco
Tribal Town George Scott, Town King, Charles Coleman, Tribal Historic Preservation Officer, Tunic-Bilox
Tribe of Louisiana Marshall Pierite, Chairman, Earl J. Barbry, Jr., Tribal Historic Preservation Officer,
Ysleta Del Sur Pueblo of Texas Frank k. Paiz, Governador, Kickapoo Traditional Tribe of Texas Juan Garza,
Jr., President, Kickapoo Traditional Tribe of Oklahoma, Gilbert t Salazar, Chairperson, Tonkawa Tribe of
Oklahoma Donald L. Patterson, President
Department of the Interior
Indian Affairs Southern Plains Region
Mr. Dan Deer and Water
Executive Director
The Department of the Interior
The Secretary of The Interior
Sally Jewell
The Department of the Interior
National Park Service
Jon Jervis Director
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Depatment of the Interior
Cultural Affairs
Steve Morris Director
Departament of the Interior
San Antonio Historical National Park Service
Mardi Arce Superintendant
Susan Snow World Heritage Coordinator for San Antonio Missions
U.S. General Administration Services
Ms. Denise Roth Executive Director
Mr. Steve Kline Historical Preservation Officer
U.S. Federal Transit Administration
Ms. Elizabeth Patel Historical Preservation Officer
Mr. Robert Patrick Administrator Region 6
San Antonio VIA transit
Mr. Jeffrey Arndt President and CEO
San Antonio VIA Transit Board of Trustees
Hope Andrade, Steve P. Allison, Marc Harrison,
Lester Bryant, Rebecca Q. Cedillo, Dr. Richard Gambitta,
A. David Marne, Carl Morgan, Bobby Perez,
Douglas Poneck, Katherine Thompson-Garcia
U.S. Federal Transit Administration
Region 6
Mr. Robert Patrick Regional Administrator
Comanche First Tribe Indian Nation
Jimmy Arterberry National Tribal Historical Preservation Officer
The Kumash Indian Tribe First Nation
Chief Mati Wishtoyo and Luhuiisha Wishtoyo
Caddo-Adais First Tribe Indian Nation
Chief Rufus Davis
US EPA
Mr. Randy Gee US EPA Region 6
Coordinator Indian Tribes Environmental Social Justice
U.S. Senator Floyd Doggett
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U.S. Senator Lamar Smith
U.S. House Representative Joaquin Castro
Bexar County Commissioners
Commissioner Nelson W. Wolff
Commissioner Sergio Rodriguez
Commissioner Paul Elizondo
Commissioner Kevin Wolff
Commissioner Tommy Adkisson
LULAC League United Latin American Council
George Alejos
NAACP National Association for the Advancement of Colored People
Regent Gary Bledso
President of the Texas NAACP
Esperanza Justice Center
Graciela Sanchez Director
Amy Kaisley
Susana Segura
Westside Historical Preservation Allegiance
Dr. Antonia Castaneda Director
Attorney Leslie Barras
Historical Preservation Expert
Attorney Enrique Valdivia
Environmental Social Justice Expert
Rio Grande Legal Aid
City of San Antonio Mayor and City Council Members
Gustafson Guthrie Nichol GGN
Civic Park Design
Lead Designer Kathryn Gustafson
Alamo Architects
Sierra Club
Ms. Reggie James President
Public Citizens in Austin Texas
Ms. K. White
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Austin Statement
K. Collier
Texas Tribune
Julian Aguilar
La Prensa
Tino Duran
Hello Rivard Report
Editor
Eagle Pass Business Journal
Editor
Current Media
Editor
Austin Texas Media KUT
Mose Buchele
Media News at San Antonio, Austin, Dallas, Houston:
CBS Channel 5
ABC Channel 12
NBC Channel 4
Fox Channel 29
Telemundo Media Channel 60
Univision Media Channel 41
Time Warner Channel 35
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