Cultural Resources

BPA Cultural Resource Program

Cultural resources are considered whenever project activities include:

Ground disturbance (e.g., planting, infrastructure or new construction that involves digging)
Historic (over 50 years old) buildings or structures (e.g., barns, houses, dams)
Ongoing impacts to cultural resources like frequent exposure or effects from erosion

BPA manages cultural resource compliance activities in collaboration with affected Tribes, State Historical Preservation Offices (SHPOs), Tribal Historical Preservation Offices (THPOs), other federal and state land management agencies, the federal Advisory Council on Historic Preservation and interested members of the public.

BPA's activities focus on the Federal Columbia River Power System, Transmission and Fish & Wildlife.

In order to effectively manage historic properties within 14 of the dams and reservoirs, the FCRPS Cultural Resource Program was created in 1997 as a jointly-administered effort overseen by the U.S. Army Corps of Engineers, the Bureau of Reclamation, and BPA to address NHPA section 106 compliance. Work is guided by a programmatic agreement for management of historic properties effected by the operation and maintenance of the FCRPS. Effects can be caused by water rising and falling due to dam operations which can erode burial sites and other cultural resources, or expose them so that they are susceptible to recreational impacts. Mitigation of these effects protect valuable resources and help ensure compliance with Section 106 of the NHPA. Each agency has a comprehensive cultural resource program specific to its mission and must comply with its own regulations and policies. The FCRPS Cultural Resource Program is only one part of the larger FCRPS program.

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BPA Cultural Resource Compliance for transmission system projects covers both new construction projects and operations and maintenance projects. Some examples include construction of new transmission lines and substations, rebuilding and/or re-conductoring existing transmission lines, and replacing transmission line structures, access road construction or improvement, and other activities.

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BPA Cultural Resource Compliance for fish and wildlife projects help ensure cultural resources are considered during the planning and implementation of the BPA-funded Columbia Basin Fish and Wildlife Program. Through its partners, including Tribes, state agencies, conservation organizations, and watershed groups, BPA funds projects that help improve conditions for fish and wildlife species in the Columbia River basin and stretching across five states. Projects range from laboratory research, hatchery programs, acquiring land for conservation easements, or habitat improvement actions such as stream channel reconstruction, large woody debris placement, or upgrades to existing irrigation systems.

Learn more.

National Historic Preservation Act

Cultural resource compliance is guided primarily by National Historic Preservation Act (NHPA) regulations and guidelines under Section 106.

This act supports historic preservation activities and programs, and encourages protection of “historic properties” in the United States. It created the National Register of Historic Places, the list of National Historic Landmarks, and SHPOs and THPO. Historic properties are prehistoric or historic districts, sites, buildings, structures, or objects that are eligible for listing in the National Register of Historic Places. They can include traditional cultural properties and landscapes. NHPA was signed into law October 15, 1966, and is the most far-reaching historic preservation legislation ever enacted in the United States.

Section 106 Process

Formal consultation begins with providing the proposed project details to all consulting parties, which include SHPOs, THPOs, effected tribal governments, local governments, state and vederal agencies, interested parties and the public. Questions asked during this step are:

Who is the landowner?
Do they require a permit?
Are other agencies involved in the proposed project and if so, which agency will be the lead agency for Section 106 compliance?

All consulting parties are provided a 30-day review and comment period.

Background research is conducted prior to an intensive cultural resources survey of the proposed project area using relevant literature, previous cultural surveys, recorded site data, historic maps, other environmental data, and data recommended by the consulting parties.

Field Investigations of the project area include intensive pedestrian survey, subsurface testing, followed by a professional report following SHPO standards.

If cultural resources are identified within the proposed project area, they are systematically recorded to determine their location and extent, the type of cultural resource, age, and last but not least, its eligibility to the National Register of Historic Places.

A cultural resource can be a historic property if it’s determined to be significant and retains its integrity by one or all of these characteristics: location, design, setting, materials, workmanship, feeling and association.

There are 4 criteria used to make that designation:

Criterion A - Associates the property with significant events
Criterion B - Associates the property with significant persons or beings
Criterion C - Associates significant architecture, which represent specific type or period, or method of construction
Criterion D - Provides data important to our understanding of prehistory or history

Determine if the historic resource would be impacted by the proposed project and resolve those potential impact. If impacts to historic properties are possible, BPA Cultural staff work with the BPA project team to avoid impacts to these resources by enlisting the project team to find design alternatives (for example, moving a proposed transmission line structure to be constructed outside of archaeological site boundaries to avoid impacts to the archaeological site).

BPA also works with the project team to manage historic properties during the construction phase of a project. This may include marking and flagging cultural resources to avoid impacts and having cultural monitor’s onsite during construction activities.

All consulting parties are provided a 30-day review and comment period.

BPA works hard to avoid impacts to historic properties. If impacts to historic properties are unavoidable, then adverse effects to the resource needs to be resolved prior to the completion of the Section 106 process. Resolution, in the form of mitigation, is determined in consultation with the consulting parties for the proposed project.

Mitigation is negotiated between the consulting parties. The agreed upon mitigation is documented in a Memorandum of Agreement (MOA) which is a legal document signed by the consulting parties which formalizes the specific actions the federal agency will take to minimize, avoid, or mitigate the adverse effect.

The Advisory Council on Historic Preservation is notified and a 15-day review and comment period is provided.

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