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Secretary Of The Interior's Report To The Advisory Council on Historic Preservation In Accordance With Section 213 of the National Historic Preservation Act: Evaluation of the Impact of the Proposed Highwood Generating Station on the

Great Falls Portage National Historic Landmark

By Staff, Lewis and Clark National Historic Trail

Staff, Midwest Regional Office Staff, Intermountain Regional Office

United States Department of the Interior National Park Service

Midwest Regional Office Omaha, Nebraska 2007

Executive Summary

The Advisory Council on Historic Preservation (ACHP) requested that the National Park Service (NPS) provide a report evaluating the impacts of the proposed Highwood Generating Station (HGS) on the Portage Route of the Lewis and Clark Expedition near Great Falls, Montana. This report addresses (1) the national significance of the route, (2) how the project might affect the integrity of the route, (3) recommendations to avoid, minimize, or mitigate adverse effects to the route, and (4) whether the project would threaten the current designation of the route as a National Historic Landmark (NHL) or require adjustments to its boundary.

The Portage Route's national significance was initially described and documented in its NHL nomination approved in 1966. The boundaries were approved as Great Falls Portage National Historic Landmark in 1985. To be eligible for designation as an NHL, a property must "possess exceptional value or quality in illustrating and interpreting the heritage of the United States." The Portage Route is directly associated with the Lewis and Clark Expedition, a seminal event that had a defining role in establishing the United States as a transcontinental nation. The route itself illustrates the hardships of the undertaking and the dedication and determination of its participants.

As approved by the Department of Agriculture Rural Utilities Service's (RUS) environmental Record of Decision, the preferred alternative site for the HGS is within and adjacent to the NHL. The generating station would introduce major physical, visual, and auditory elements into a landscape that has very few modern intrusions and appears and sounds much as it did when the Expedition traversed the route in 1805 and 1806.

The integrity of the NHL is based mainly on its current condition of large, open, historic and natural landscapes relatively free of intrusions. The proposed HGS and its ancillary features would constitute a broad and wide-scale impact on the surrounding landscape. In such an open landscape, the HGS cannot avoid, minimize, or mitigate adverse impacts sufficiently to maintain the integrity of the NHL.

In order to be designated an NHL, a property must have integrity. Integrity is the ability of the physical features of a property to convey its historical associations or attributes. In order to retain NHL status, a property must retain those essential physical features. The features must define both why a property is significant and when it was significant. Prior to the HGS proposal, the NPS rated the status of the NHL as "Satisfactory." When the HGS project was introduced, the NPS determined the NHL status should be elevated to "Threatened."

The HGS would have wide-spread, profound, and adverse impacts on the NHL and would require a critical review of its integrity; a process which would likely lead to the loss of NHL status for most, if not all, of the route. Since the Portage Route is also part of the Lewis and Clark National Historic Trail (LECL), the HGS would have significant and adverse impacts to LECL, a unit of the National Trails System, administered under the authority of the National Trails System Act and the NPS Organic Act.



National Historic Landmarks are afforded special protection and consideration by the National Historic Preservation Act (NHPA; 16 U.S.C. ?470u). In Section 110 of the NHPA, Federal agencies are directed to "undertake such planning and actions as may be necessary to minimize harm..." to NHLs. In addition, the regulations implementing Section 106 of the NHPA (36 CFR, Part 800) set forth special requirements for protecting NHLs and for conducting consultation with the Advisory Council on Historic Preservation (ACHP) and the Secretary of the Interior on projects involving an NHL. These regulations also provide for the ACHP to request a report from the Secretary of the Interior, under Section 213 of the NHPA, to assist in consultations involving NHLs. Section 213 of the NHPA specifically directs the Secretary of the Interior to prepare a report "detailing the significance of [the] historic property, describing the effects of [the] proposed undertaking on the affected property, and recommending measures to avoid, minimize, or mitigate adverse effects" (if requested by the ACHP). Under existing delegations of authority, the NPS acts on behalf of the Secretary of the Interior for these regulatory purposes.

The Lewis and Clark Portage Route around the Great Falls of the Missouri River, located in Cascade County, Montana, was officially designated as the Great Falls Portage National Historic Landmark (NHL) on May 13, 1966. Legal boundaries were established in a revision to the NHL dated June 18, 1985.

The 1978 amendment to the National Trail System Act established the Lewis and Clark National Historic Trail (LECL) along both the outbound and return routes of the Lewis and Clark Expedition of 1804-1806. Under this law, the NPS administers the LECL and has as its purpose the identification and protection of the historic route and its historic remnants and artifacts for the public enjoyment. The LECL is an administrative unit of the NPS, which extends the protection of the Organic Act (1916, as amended) to the Trail, specifically honoring the charge to "conserve the scenery and the natural and historic objects and the wildlife therein and to provide for the enjoyment of the same in such manner and by such means as will leave them unimpaired for the enjoyment of future generations." The Great Falls Portage Route is situated on and is a significant component of the LECL.

In 2004, the Southern Montana Electric Generation and Transmission Cooperative (SME) applied to the USDA Rural Utilities Service (RUS) for a loan guarantee for construction of a coal-fired electric generating plant and pilot wind turbine farm, to be called the "Highwood Generating Station" (HGS). The preferred location was an area called the Salem Site, within and adjacent to the NHL. In addition to undertaking the 1969 National Environmental Policy Act (NEPA) process, RUS initiated the required Section 106 consultation, to take into account the effects of this project on historic properties.

In this report, both the "Expedition" and the "Corps of Discovery" refer to the historic Lewis and Clark Expedition of 1804-1806; the "Portage Route" refers to the actual historic path of the Expedition around and near the Great Falls of the Missouri River in Montana. "NHL" refers to the land of the Portage Route and the adjoining land that comprises the Great Falls Portage National Historic Landmark.


Project Review

On June 29, 2006, the NPS Intermountain Region (IMR) was invited by the RUS to participate in the Section 106 consultation process. The HGS Proposed Action at the Salem Site (identified in the Draft Environmental Impact Statement June 26, 2006) would have an adverse impact on the NHL. The IMR expressed their willingness to participate in the 106 consultation process in a letter dated July 21, 2006. At the request of IMR, the LECL was invited to be a consulting party on September 12, 2006. LECL participated in two face-to-face consultations with the RUS, other Federal, State, and local government officials, national and state preservation groups, and individual citizens.

In a teleconference on March 15, 2007, the ACHP indicated it would ask for a report under Section 213 of the NHPA. The NPS agreed that it would complete the report, upon request. The RUS restated its commitment to issuing the Record of Decision (ROD) "by the end of March or the first week in April, 2007."

In a letter to the NPS Director, dated March 22, 2007, the ACHP requested the views of the Secretary of the Interior on the potential adverse effects of the proposed HGS, within and adjacent to the NHL, pursuant to Section 213 of the NHPA:

Specifically, we request your views and comments on: ? What makes this site unique and important on a national level? ? How the proposed project may affect the integrity of the NHL; ? Recommended measures to avoid, minimize, or mitigate adverse effects to the NHL; ? Whether the adverse effects from the proposed HGS would threaten the continued designation of this property as a National Historic Landmark or require adjustments to the current boundary.

On May 11, 2007, the RUS issued the ROD approving the HGS, and the Montana Department of Environmental Quality issued the air quality permit for the project.

National Significance of the Great Falls Portage NHL

The Great Falls Portage NHL is among the few sections of the historic route of the LECL that can be identified and mapped using William Clark's original survey notes. The hardships faced during this 31-day portage were among the toughest ordeals encountered by the explorers and threatened the success of the Expedition. The delay occasioned by this portage was critical because the Corps of Discovery needed to traverse the "unknown" Rocky Mountains before the onset of winter. The property's designation as an NHL was based upon the national significance of the event and the high integrity of the resource ? the largely unimpaired landscape within which the event took place.

The significance of this landscape was recognized on May 23, 1966, with the authorization of the Great Falls Portage National Historic Landmark Review Project. The NHL nomination was revised and updated in 1976 and in 1984. It was formally approved with legal boundaries in 1985. The entire Portage Route was not included in the NHL because Malmstrom Air Force


Base and several residential subdivisions of the City of Great Falls existed on the Portage Route by the time the boundaries were approved by the Secretary of the Interior. The current NHL encompasses 7,700 acres.

The 1976 review report states: "Since no permanent man-made evidence remains of the Lewis and Clark expedition's campsites and exploration of the Great Falls area, the integrity of the historic sites is dependent on the preservation of the natural scene as it was when the explorers camped there and described it. Therefore, the sections of the National Historic Landmark with the most integrity are those which retain the area's natural character and have the fewest manmade intrusions."

The 1984 review states: "The boundaries... include the terrain necessary to convey the historical feeling and association of the portage route and the intrusions at such a scale are minor. The nomination includes the most important points of the portage route, and while not contiguous for the entire eighteen-mile length, presents a near-complete picture of the portage route." The boundary is roughly 2000-4000 feet wide by 8 miles long on the eastern side (lower portage route) and 2000-3000 feet by 4 miles on the western (upper portage route). A 4.8 mile section of the route is excluded from the boundaries "due to its loss of historic integrity." The western portion as established was significantly smaller "due to intrusions and altered landforms." In contrast the eastern portion of the NHL retains a high degree of integrity with little to no intrusions on the historic and natural scene. The landmark boundaries, drawn in consultation with a historian of the Portage Route, reflect the high degree of confidence in the location of the route.

Impacts to the NHL have been relatively minor since 1984. As mandated by program regulations (36 CFR, part 65.10), the NPS monitors the condition of NHLs through the biennial "National Historic Landmarks Update" report and makes recommendations to owners and policy makers regarding preservation and protection.

As recently as 2004, the NPS recognized the efforts of Montana Fish, Wildlife and Parks, the U. S. Forest Service, the Bureau of Land Management, The Conservation Fund, Pennsylvania Light and Power (Montana), and the R.K. Mellon Foundation to further protect the relatively unaltered character of this landscape through conservation easements on the eastern portion of the NHL. This was profoundly significant because the NHL had been reduced from its original 1966 acreage due to man-made intrusions and subsequent losses of integrity in its western portion.

Prior to the proposed action by RUS, the "National Historic Landmarks Update" determined the Great Falls Portage Route NHL to be in "satisfactory" condition. However, in the most recent report (2006) that status was changed to "threatened," indicating that the NHL had suffered, or is in imminent danger of suffering, a severe loss of integrity. Specifically, the status was described with the comment that the proposed development of the Highwood Generating Station would negatively impact this significant historic scene.

(For an abbreviated Expedition history of the Portage Route, please see Appendix)


How the Proposed Project Could Impact the Integrity of the NHL


The physical properties of any NHL must convey its historical associations and attributes; evaluating integrity must be grounded in an understanding of a property's physical features and how they relate to those associations or attributes.

A great number of NHL nominations are documents that are products of their time, in that they were prepared according to the professional requirements and expertise of their era. The requirements for preparation of NHL nominations have evolved over time. Today a more rigorous set of criteria and guidelines must be met. The content of NHL nominations has evolved considerably since 1966 when the NHL was designated.

Today any property proposed for NHL designation must define the significance of the property and its ability to convey that significance through its integrity. The seven aspects of historic integrity, as defined in the National Register Bulletin "How to Prepare National Historic Landmark Nominations," are: location, design, setting, materials, workmanship, feeling, and association. The NHL boundary justification provided in the 1984 revision does identify intrusive elements to the portage, but does not directly address integrity as would be required by current standards.

The 1966, 1976 and 1985 NHL documentation predates our current understand of "historic/cultural landscape." The National Register Bulletin "Guidelines for Evaluating and Documenting Rural Historic Landscapes," and subsequent report entitled "The Secretary of the Interior's Standards for the Treatment of Historic Properties with Guidelines for the Treatment of Cultural Landscapes (1996), defines a historic/cultural landscape as:

a geographical area (including both cultural and natural resources and the wildlife or domestic animals within), associated with a historic event, activity, or person, or exhibiting other cultural or aesthetic values.

There are eleven characteristics of an historic landscape: land uses and activities; patterns of spatial organization; response to the natural environment; cultural traditions; circulation networks; boundary demarcations; vegetation related to land use; buildings, structures, and objects; clusters; archeological sites; and small-scale elements. The NHL documentation contains very little information related to these characteristics. For example, any discussion of the historic landscape of the NHL should consider the human response to the natural environment: the basic fact that the Portage Route exists due to the presence of the Great Falls of the Missouri.

The historic landscape of the NHL has not been formally documented following the contemporary guidelines and criteria specified by the NPS. It is entirely possible that there is physical evidence remaining on the route, regardless of what the NHL documentation states. While there have been investigations at the NHL, it is not known if they were complete, adequate, or what results the investigations actually produced.


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