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May 16, 2019

Dear Dr. Travnicek,

The Jewish Coalition for Religious Liberty (JCRL) is a non-denominational organization
of Jewish communal and lay leaders who seek to protect the ability of all Americans to practice
their faith. We write in support of the petition.
JCRL supports expanding the right to posess religiously significant eagle feathers—
currently limited to members of federally recognized tribes—to include any interested religious
adherent. The protections will immediately benefit Native Americans who hold sincere religious
convictions despite not belonging to federally recognized tribes. Adopting the proposal will
additionally benefit all Americans by advancing a policy of government impartiality between
groups of religious adherents.
Native American tribes such as the Lipan Apache Tribe of Texas will directly benefit
from the proposed rule. Currently, the government distinguishes between believers by granting
increased religious liberty protection to federally recognized tribes at the expense of all other
tribes. The government does not question the sincerity of other Native American adherents. Nor
does it doubt their claims that eagle feathers are religiously significant to them. It simply chooses
to privilege some believers’ religious practices over others. Adopting this petition will eliminate
that injustice. Recognizing all Native Americans’ freedom to exercise their faith is necessary to
avoid inflicting further injustice on believers who do not belong to federally recognized tribes.
JCRL also supports the proposed policy because of its broader implications for religious
liberty. By extending protection to all sincere believers, the Department will demonstrate its
commitment to religious liberty for all Americans. This is a matter of particular importance to
the Jewish community. Judaism encompasses a wide variety of opinions on every religious issue.
Jewish groups disagree with one another and even have internal disagreements over some of the
most important theological question—including which individuals count as Jews. Some of these
arguments date back to antiquity, and some are of recent vintage. Some opinions are held by
large groups of people, and some are held by tiny minorities. But, none of that should impact
every adherent’s right to exercise his faith. The government must grant protection to every
sincerely held position under the big fractious tent of Judaism regardless of what type of Jewish
group or individual requests protection. Jews may famously disagree with one-another, but the
government must nonetheless respect all of our sincere theological positions.
JCRL believes the proposed policy is best both for the Native American tribes who will
benefit directly, and for any American who supports the fundamental human right of religious
liberty. We urge you to grant the petitioners request.

Howard Slugh
General Counsel Jewish Coalition for Religious Liberty