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3.11 CULTURAL AND HISTORIC RESOURCES

This section discusses cultural and historic resources associated with the underwater marine and 

freshwater areas and coastal areas included in the action area for the Proposed Action. The Advisory 

Council on Historic Preservation regulations at 36 CFR 800.16(l)(1) define the term ‘historic property’ (or 

historic resource) as any prehistoric or historic district, site, building, structure, or object included in, or 

eligible for inclusion in, the National Register of Historic Places (NRHP) maintained by the Secretary of the 

Interior. This term includes artifacts, records, and remains that are related to and located within such 

properties and also includes properties of traditional religious and cultural importance to an Indian tribe

or Alaska Native or Native Hawaiian Organization and that meet the National Register criteria. As 

described in Section 3.3, Regulatory Background, federal agencies are directed by the NHPA and NMSA to 

manage and maintain historic properties in ways that consider the preservation of their historic, 

archeological, architectural, and cultural values before undertaking a project. National marine sanctuaries 

were established, among other conservation purposes, to protect shipwrecks, downed aircraft, and other 

cultural and historic resources such as lighthouses, archaeological sites, and the cultural history of native 

communities. National marine sanctuaries are designated under the NMSA, as discussed in Section 3.3. 

Through site-specific legislation and regulations, national marine sanctuaries are afforded varying levels 

of protection from activities that would be potentially harmful to the natural and cultural resources they 

contain. 

Section 3.3 also discusses the role of SHPOs and THPOs in the Section 106 process. SHPOs are responsible 

for reviewing undertakings for their impact on historic properties and evaluating and nominating historic 

buildings, sites, structures, and objects to the National Register. In accordance with the NHPA, a THPO is 

the designated tribal preservation official of a federally-recognized Indian tribe. A THPO is responsible for 

the administration of any or all of the functions of a SHPO with respect to tribal land, which refers to all 

lands within the exterior boundaries of any Indian reservation and all dependent Indian communities.

3.11.1 Affected Environment

The types of cultural and historic resources that could be present in locations where NOS’s Proposed 

Action is conducted include:

1) Submerged cultural and historic resources (such as shipwrecks); 

2) Areas where traditional or tribal fishing rights are held and subsistence fishing and hunting are 

practiced, including Traditional Cultural Places (TCPs); 

3) Historic coastal infrastructure such as piers; and 

4) Viewsheds of nearshore historic properties. 

These resources are discussed below.

3.11.1.1 Submerged Cultural and Historic Resources

Submerged cultural and historic resources are objects found on the sea floor, lake beds, or river beds with 

historic, pre-historic, or culturally significant values (NPS, 2000). Archaeological sites present within the 

action area may include submerged isolated artifacts (e.g., fragments of tools, arrow points, stone bowls) 

from prehistoric or historic voyages, resources submerged as a result of sea level rise, downed aircraft, 

and historic shipwrecks. Based on research of federal and state agency sites, historical databases, and 

other informational sources, there are myriad inundated cultural and historic resources present 

throughout the extensive action area. Although these resources would be too numerous to list in this Final 
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PEIS, this subsection provides an overview of the types of submerged archaeological resources present 

throughout the action area. 

The Office of Coast Survey’s Public Wrecks and Obstructions database (also known as the Automated 

Wreck and Obstruction Information System, or AWOIS) contains information on identified submerged 

wrecks within the maritime boundaries of the U.S. Information within the database includes the position 

of each feature (latitude and longitude) along with a brief description. However, AWOIS records have not 

been updated since 2014 and are not comprehensive. A United Nations Educational, Scientific, and 

Cultural Organization (UNESCO) webpage includes information on numerous databases and maps of 

underwater cultural heritage sites maintained by external institutions worldwide (UNESCO, 2017). 

Although these and many other such databases, including the NRHP, provide valuable information on the 

nature and location of submerged historic and cultural resources, there is no one clearinghouse for the 

coordinates of the locations of all known wrecks. 

3.11.1.1.1 Greater Atlantic Region

In the Greater Atlantic Region, prehistoric archaeological sites may be present in or on the continental 

shelf. At the beginning of the Early Archaic period 10,000 years ago, the relative sea level was 

approximately 25-26 m (81-85 ft) lower than at present. Prehistoric archaeological deposits could 

potentially exist if landforms beneath the sea floor are well preserved. There is also the potential for 

historic archaeological resources to be present. For example, data sources maintained by the recreational 

SCUBA diving community in the New Jersey area estimate between 4,000 and 7,000 shipwreck sites off 

the coast of New Jersey. The majority of these wrecks are located along the coastline (NSF and USGS, 

2011). Between Truro and Wellfleet, Massachusetts, for example, more than 1,000 wrecks have occurred 

(NPS, 2020b). 

Stellwagen Bank National Marine Sanctuary, established in 1992, encompasses the historic shipping 

routes and fishing grounds for numerous ports around Massachusetts. These ports have been centers of 

maritime activity in New England for hundreds of years. Historic use of the national marine sanctuary is 

evidenced by the remains of several historic shipwrecks on the sea floor (ONMS, No Date-a). 

There are 7,290 km (4,530 mi) of coastline along the five Great Lakes. The Great Lakes region contains one 

national marine sanctuary (Thunder Bay in Lake Huron in northeastern Michigan) and two proposed 

national marine sanctuaries (Wisconsin-Lake Michigan and Lake Ontario). To date, nearly 100 shipwrecks 

have been discovered within the 11,137-km2 (4,300-mi2) Thunder Bay National Marine Sanctuary. The 

waters of Thunder Bay contain evidence of human use dating back thousands of years. Geological and 

archaeological evidence suggests a high probability of prehistoric archaeological sites that have yet to be 

discovered (ONMS, 2017). Northeastern Michigan’s maritime landscape includes hundreds of shipwrecks 

located on the bottomlands of Lake Huron. It also encompasses all of the cultural and natural features 

related to maritime heritage, such as lighthouses, commercial fishing camps, and working ports.

The proposed 2,784-km2 (1,075-mi2) Wisconsin–Lake Michigan National Marine Sanctuary would protect 

37 shipwrecks and related underwater cultural resources with historic, archaeological, and recreational 

value (ONMS, No Date-b). The area in eastern Lake Ontario being considered for designation as a national 

marine sanctuary includes approximately 4,403 km2 (1,700 mi2) of lake waters and bottomlands in the 

state of New York. These waters and bottomlands contain 21 known shipwrecks and one military aircraft. 

Based on historical records, an additional 47 shipwrecks and two aircraft are also likely located there. The 

area being considered for designation also includes a separate area surrounding the HMS Ontario, which 
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is both the oldest confirmed shipwreck (1780) and the only fully intact British warship discovered in the 

Great Lakes (ONMS, 2020).

3.11.1.1.2 Southeast Region

Florida has one of the longest continuous coastlines in the country and, as a result, the range of 

underwater archaeological sites is broad and covers thousands of years. Florida's Bureau of

Archaeological Research within the Department of State 

examines and interprets underwater sites. They have 

conducted surveys and excavations on both prehistoric and 

historic sites located offshore and in rivers and sinkholes - from 

submerged Native American middens and habitation sites to 

the remains of sunken steamboats and schooners. In 1987, 

Florida began to develop a statewide system of underwater 

parks featuring shipwrecks and other historic sites. Currently, 

there are 12 shipwrecks designated as underwater reserves 

(Florida DOS, No Date). Thousands more shipwrecks and 

offshore cultural and historic resources are likely to be present 

off of the Florida coast; there are over 1,000 shipwrecks along 

the Florida Keys National Marine Sanctuary alone (Figure 3.11-

1) (NOAA, No Date-d). 

Off the coast of North Carolina, Monitor National Marine 

Sanctuary protects the wreck of the Civil War ironclad USS 

Monitor. 

Though rare, prehistoric human remains have been discovered 

offshore in the Southeast Region. In 2016, a 0.3-ha (0.75-acre) prehistoric Native American ancestral burial 

site was discovered off the shore of Manasota Key in Florida (NatGeo, 2018). Other prehistoric and historic 

remains have been discovered within shipwrecks and underwater cave systems. 

Puerto Rico has a maritime heritage reaching back over at least 500 years. Based on archival research 

conducted by the National Park Service (NPS) and other agencies and groups, there are more than 200 

shipwrecks in Puerto Rico waters. One of the oldest of these shipwrecks is a 17th century merchantman 

off the coast of Rincon, a small municipality on Puerto Rico’s western coast. Artifacts recovered from the 

find include pins, scissors, ordnance, pewter ware, woodworking tools, myriad concretions, and a nautical 

astrolabe (NPS, 2022).

The U.S. Virgin Islands include the three main islands of St. Croix, St. Thomas, and St. John, plus Water 

Island off of St. Thomas, and about 50 islets and cays. St. Thomas was a maritime trading and mercantile 

exchange and along with St. Croix, the Danish center for the slave trade beginning in 1685. The 

importation of slaves was abolished in the early 1800s and St. Thomas became one of the first “free ports”. 

In the early 1700s, St. Thomas was a well-known haven for pirates. It later became a coaling station for 

international steamships moving between Europe and South and North America until 1935, when the U.S. 

Navy and U.S. Marine Corps began administering the islands. Based on archival research conducted by 

NPS, several hundred shipwrecks are thought to be in the waters surrounding the U.S. Virgin Islands (NPS, 

2022b).

Figure 3.11-1. City of 

Washington Shipwreck, Florida 

Keys National Marine Sanctuary
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3.11.1.1.3 West Coast Region

In 2011, BOEM conducted a study to identify the locations of known and reported submerged cultural 

resources, potential inundated prehistoric sites, coastal properties that are listed or eligible for listing on 

the NRHP, and TCPs on the west coast of the U.S., including California, Oregon, and Washington. The study 

area for this effort stretched from the U.S./Canadian border to the U.S./Mexican border and extended 

322 km (200 mi) west of the U.S. EEZ. The study discovered archaeological resources such as shell middens 

(an archaeological feature consisting mainly of mollusk shells that contain debris associated with human 

activity), lithic sites, rock art, burial grounds, and caves/rock shelters, and located records on hundreds of 

shipwrecks in the Pacific OCS area (BOEM, 2013). 

The remains of prehistoric seafaring trading expeditions along the Pacific Coast (including travel to the 

Channel Islands) has resulted in artifacts such as soapstone bowls recovered and preserved from the 

offshore areas; at least 25 individual sites have been reported between Ventura Beach and Point 

Conception in California alone (Foster, No Date). Known historic archaeological resources in the southern 

California area consist of submerged shipwrecks and submerged aircraft. The most common causes of the 

wrecks were burning, collision, or stranding (NSF and USGS, 2011). Approximately 100 shipwrecks have 

been documented in the Channel Islands National Park in California (NPS, 2016). 

3.11.1.1.4 Alaska Region

According to Geographic Information System (GIS) data, Alaska has 71,000 km (44,117 mi) of coastline 

and comprises almost half the total U.S. coastline. The numbers of both identified and potential 

submerged cultural resources in this area is vast. The U.S. Department of the Interior Minerals 

Management Service (MMS, now BOEM) estimated the presence of more than 4,000 shipwrecks off the 

coast of Alaska. In addition to marine vessels, Alaska waters contain numerous historic aircraft, many of 

which were associated with World War II military activities, battles, and campaigns (McMahan, 2007). 

MMS maps indicate that known shipwrecks are scattered throughout the Western Gulf of Alaska, with 

the heaviest concentration in Chignik Bay (NSF and USGS, 2011). At Point Belcher near Wainwright, Alaska, 

30 ships were frozen in the ice in September 1871; 13 others were lost in other incidents off Icy Cape and 

Point Franklin. Another seven wrecks are known to have occurred off Cape Lisburne and Point Hope. From 

1865 to 1876, 76 whaling vessels were lost due to ice and battleship raids, which also caused the loss of 

21 whaling ships near the Bering Strait during the Civil War (OCM, 2021). 

3.11.1.1.5 Pacific Islands Region

NOAA’s Pacific Islands Region includes Hawai’i, Guam, Northern Mariana Islands, and American Samoa. 

The high-energy marine surf environment of Hawai’i is capable of breaking apart wooden vessels and 

eventually destroying even iron and steel-constructed boats and ships. The volcanic shorelines and 

exposed coasts of the islands do not feature many naturally protected bays or harbors. These conditions, 

combined with the fringing or barrier reefs and sharp submerged lava rocks in nearshore waters, have led 

to a great number of shipwrecks in Hawai’i. An initial examination by BOEM of the reported positions of 

shipwrecks reveals clusters around the locations of historic landings (BOEM, 2017a). In the Hawaiian 

Archipelago alone, there are over 80 submerged U.S. Navy ships and submarines, and over 1,500 Navy 

aircraft. Many of these sites are war graves associated with major historic events that shaped the region 

(ONMS, 2017). 

Several maritime archaeology projects have been conducted on coastal fishing and aquaculture sites in 

the Hawaiian Islands, as part of a course offered by the University of Hawai’i. One resulted in the mapping 
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of an accumulation of hundreds of fishing lures (artificial fishing bait designed to attract a fish's attention) 

surrounding specific topographical reef features offshore from Waikiki beach on Oahu. The distribution 

of lost lures suggests hundreds of years of fishing activity at this specific location and submerged reef 

feature (BOEM, 2017a).

In June 2007, NOAA’s ONMS completed an initial maritime heritage resource document inventory for 

American Samoa. Known maritime heritage resources in American Samoa include historic shipwrecks, 

World War II naval aircraft and fortifications, gun emplacements, and coastal pillboxes; archaeological 

sites associated with the ancient past; and marine/coastal natural resources associated with the legends 

and folklore of American Samoa. Ten historic shipwrecks are known to exist in American Samoan waters, 

the earliest dating to 1828; 43 naval aircraft are known to have been ditched or crashed into American 

Samoan waters between 1942 and 1944; and countless marine archaeological resources such as whet 

stones (used to sharpen the edge of steel tools), petroglyphs (prehistoric rock carvings), and grinding 

holes/bait cups (small depressions ground into bedrock) are known to exist in American Samoan waters 

(ONMS, 2007).

In Guam, due to the region’s substantial number of historic military activities, there are various 

underwater sites associated with World War II occupation and combat. From historical records and 

discovery, there are many known aircraft, ships, construction equipment, cargo, and supplies submerged 

throughout Micronesia. World War II-affiliated sites within and south of Guam’s Apra Harbor include areas 

where the U.S. military dumped equipment or supplies; Japanese boats sank; or remnants of Japanese 

aircraft exist. One of Guam’s most popular fishing sites, Ritidian, includes the remains of an ancient fish 

camp, where indigenous people gathered to process and cook fish (Auyong, 2016).

More than four dozen documented shipwrecks have occurred in the waters of the Northern Mariana 

Islands. Two of the earliest known losses are the Santa Margarita in 1601 and the Nuestra Senora de la 

Concepción in 1635. Six other ships are reported to have been lost during the Spanish colonial period. The 

majority of shipwrecks are from World War II. Due to their location between Hawai’i and the Philippines, 

the Northern Mariana Islands played an important role in several World War II battles. As a result, the 

waters of the Northern Mariana Islands contain sunken warships, auxiliaries, airplanes, tanks, and other 

military related debris (NPS, 2022c). 

3.11.1.2 Subsistence Hunting and Fishing Areas, Including Traditional Cultural Places

State and federal laws define subsistence as the customary and traditional uses of wild resources for food, 

clothing, fuel, transportation, construction, art, crafts, sharing, and customary trade. Subsistence fishing, 

hunting, trapping, and gathering are important sources of employment and nutrition in many rural coastal 

communities and have cultural importance. In general, these rights are based on the legal foundations of 

tribal sovereignty, treaty provisions, and the "reserved rights" doctrine, which holds that Native 

Americans retain all rights not explicitly revoked in treaties or other legislation (NCAI, No Date).

From 1778 to 1871, the federal government’s relations with Indian tribes were conducted largely through 

the treaty-making process. These treaties recognized the sovereignty of Indian tribes and established 

rights, benefits, and conditions for the treaty-making tribes that agreed to cede millions of acres of their 

land to the U.S. in return for recognition of property rights and federal protections. These rights are also 

known as “reserved rights.” Treaties with Indian tribes cover reserved rights such as the right to hunt, fish, 

and gather both on land ceded by tribes and on land retained by tribes. Although treaty-making ended in 

1871, federal treaties with Indian tribes ratified by Congress remain the law, though treaties have been 
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supplemented by federal legislation such as land claims settlement acts and EOs (ACHP, 2018). Under the 

U.S. Constitution, treaties carry the same legal weight as federal statutes and bind both the federal 

government and the signing Indian tribe or tribes. This means that federal agencies must ensure that their 

actions do not conflict with tribal treaty rights (ACHP, 2018). Though not all federally-recognized tribes 

are located along the coastline, unless specifically revoked by the U.S., tribes have rights to fish at all 

“usual and accustomed places”, which are not typically specifically defined regions (JRank, No Date).

Subsistence harvest practices have been documented in many studies over the last several decades. A 

wide array of natural resources is harvested throughout the year in a regular cycle of seasonal efforts 

timed for availability, access, and condition of the resources. The composition of subsistence harvests 

includes many species of fish, land mammals, marine mammals, and invertebrates, terrestrial 

invertebrates, waterfowl, berries, roots, and fuel gathering. Communities express and reproduce their 

unique identities based on the enduring connections between current residents, those who used harvest 

areas in the past, and the wild resources of the land (MMS, 2010). The role of subsistence hunting and 

fishing and traditional fishing rights in each region are described below. Relevant laws, treaties, and 

organizations are noted throughout the next sections.

3.11.1.2.1 Greater Atlantic Region

The Greater Atlantic Region includes the east coast states of Maine, New Hampshire, Massachusetts, 

Rhode Island, Connecticut, New York, New Jersey, Delaware, and Maryland, and the states surrounding 

the Great Lakes (Indiana, Michigan, Minnesota, and Wisconsin). There are 17 federally-recognized tribes

within the east coast states (four in Maine, two in Massachusetts, one in Rhode Island, two in Connecticut, 

and eight in New York) and 31 federally-recognized tribes in the states surrounding the Great Lakes (one 

in Indiana/Michigan, 11 in Michigan, eight in Minnesota, and 11 in Wisconsin). 

The Maine Department for Inland Fisheries and Wildlife recognizes Maine Native American traditional 

fishing rights and issues a set number of trapping and fishing licenses for individuals belonging to the four 

federally-recognized tribes in Maine: the Passamaquoddy Tribe, Penobscot Nation, Houlton Band of 

Maliseet Indians, and Aroostook Band of Micmacs or Aroostook Micmac Council. Two tribal organizations, 

the Great Lakes Indian Fish and Wildlife Commission and the Chippewa Ottawa Resources Authority, 

manage traditional fishing rights and resources in the Great Lakes. The Great Lakes Indian and Wildlife 

Commission is an agency of 11 Ojibwe nations in Minnesota, Wisconsin, and Michigan that manages 

traditional fishing rights in Lake Superior for individuals belonging to these nations (GLIFWC, No Date). 

The Chippewa Ottawa Resource Authority manages fishing rights for five different tribal organizations 

under 1836 Treaties (CORA, No Date). 

3.11.1.2.2 Southeast Region

The Southeast Region includes the states of Virginia, North Carolina, South Carolina, Georgia, Florida, 

Alabama, Mississippi, Louisiana, and Texas. It also includes Puerto Rico and the U.S. Virgin Islands. There 

are 23 federally-recognized tribes across all of these states (seven in Virginia, four in North Carolina, one 

in South Carolina, zero in Georgia, two in Florida, one in Alabama, one in Mississippi, four in Louisiana, 

and three in Texas); tribes in Puerto Rico and the U.S. Virgin Islands are not federally-recognized. 

Fishing is an important component of the culture and livelihood of many individuals on the U.S. Caribbean 

islands, whether commercial, recreational, or subsistence, and is tied directly and indirectly to many of 

the island’s residents and businesses. Fisheries are woven into the cultural fabric of local communities 

and make an important contribution to attainment of food and nutrition security. A significant portion of 
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fishermen in these areas retain a portion of their landings for their own or their family’s consumption, 

and, as such, engage in subsistence fishing. In the U.S. Virgin Islands, for example, approximately 11 

percent of fishermen reported that they did not sell any of their catch in 2011. (NOAA, 2014a).

3.11.1.2.3 West Coast Region

There are more than 40 federally-recognized tribes with treaties and tribal fishing rights in place in NOAA’s 

Northwest Region, which includes Washington, Oregon, California, and Idaho (NMFS, No Date-e). The 

Northwest Indian Fisheries Commission helps support natural resources management for 20 treaty Indian 

tribes in coastal Washington (NWIFC, No Date). The Olympic Coast National Marine Sanctuary on the coast 

of Washington is entirely encompassed by the traditional harvest areas of the Hoh, Makah, and Quileute 

tribes, and the Quinault Indian Nation. Along with the state of Washington and the Olympic Coast National 

Marine Sanctuary, these tribes created the Olympic Coast Intergovernmental Policy Council in January 

2007, which provides a regional forum for the collective management of resources within the Olympic 

Coast National Marine Sanctuary (NOAA, No Date-e). 

3.11.1.2.4 Alaska Region

The MMPA and the ESA acknowledge, and have exemptions for, pre-existing rights for Alaska Native 

groups to hunt and fish specific protected species. Under the MMPA (16 U.S.C. § 1371(b)) and the ESA (16 

U.S.C. § 1539(e)), for example, Alaska Natives are allowed to harvest marine mammals as subsistence

resources (OCM, 2021). Subsistence hunting of marine mammals, including seals, sea lions, walruses, and 

whales, occurs throughout Alaska all year long and is critical to the nutrition, food security, and economic 

stability of Alaska Natives. The Alaska Region includes subsistence use areas of traditional cultural 

significance to Alaska Peninsula Native people, who are ancestors of the maritime hunting cultures of 

Pacific and Yupi‘k Eskimos and Aleuts. Their primary subsistence activity is fishing all five species of Pacific 

salmon, halibut, cod, and other fish species. (NSF and USGS, 2011). Section 3.13, Environmental Justice 

includes a description of Alaska Native populations that hunt marine mammals and fish for subsistence

use, including the cultural, nutritional, and spiritual importance of each marine animal as well as where, 

when, and how it is hunted or fished for subsistence use. 

The subsistence heritage of rural Alaskans is the basis for Title VIII of the Alaska National Interest Lands 

Conservation Act (ANILCA), which states that continuation of the subsistence way of life by rural Alaskans 

is essential to their physical, economic, traditional, cultural, and social existence. This applies not only to 

Indians, Eskimos, and Aleuts, but to non-Native rural residents as well (USFS, 2010). The federal 

subsistence priority means that subsistence uses by rural residents of Alaska are given priority over nonsubsistence uses (commercial or sport). On October 1, 1999, the Secretaries of the Interior and Agriculture 

published regulations (36 CFR 242 and 50 CFR 100) to provide for federal management of subsistence

fisheries on Alaska rivers and lakes and limited marine waters within and adjacent to federal public lands.

The USFWS is the lead agency for federal subsistence management. The ADF&G regulations continue to 

apply statewide to all commercial, sport, personal use, and subsistence fisheries, unless otherwise 

superseded by federal regulations. Federal subsistence fisheries often occur in the same area as state of 

Alaska fisheries. Federal regulations apply only on federal public lands and waters (USFWS, No Date-d). 

The Federal Subsistence Board oversees the Federal Subsistence Management Program. The Board 

members include the agency heads for Alaska of the USFWS, NPS, Bureau of Land Management, Bureau 

of Indian Affairs, and U.S. Forest Service. There are also three public members appointed by the 

Secretaries of the Interior and Agriculture: the Chair of the Federal Subsistence Board and two public 

members who possess personal knowledge of and direct experience with subsistence uses in rural Alaska 

(USFWS, No Date-d).
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3.11.1.2.5 Pacific Islands Region

Fishing continues to contribute to the cultural integrity and social cohesion of Pacific island communities 

and support island economies (WPRFMC, 2016). In Hawai’i, a substantial portion of the local population 

participates in recreational and subsistence fishing. Fishing in Guam and the Mariana Islands is important 

not only in terms of contributing to the subsistence needs of the Chamorro people but also in preserving 

their history and identity. Fishing perpetuates traditional knowledge of marine resources and maritime 

heritage of the ancient Chamorro culture (Ka’ai’ai, 2016). In American Samoa, fish brought to shore 

continue to be distributed within Samoan villages according to age-old ceremonial traditions. Similar 

traditions are still practiced in Hawai’i, the Northern Mariana Islands, and Guam. These sociocultural 

attributes of fishing are at least as important as the contributions made to the nutritional or economic 

wellbeing of island residents (WPRFMC, 2016). 

3.11.1.2.6 Traditional Cultural Places

The NHPA defines the word ‘culture’ as the traditions, beliefs, practices, lifeways, arts, crafts, and social 

institutions of any community, be it an Indian tribe, a local ethnic group, or the people of the nation as a 

whole. One kind of cultural significance a property or place may possess, and that may make it eligible for 

inclusion in the Register, is traditional cultural significance. "Traditional" in this context refers to beliefs, 

customs, and practices that have been passed down through generations of people, usually orally or 

through practice. Thus, TCPs, also referred to as “Traditional Cultural Properties,” are historic properties 

that derive their cultural significance from the role the property plays in a community's historically rooted 

beliefs, customs, and practices (NPS, No Date-a). 

TCPs may include locations of historic events, locations where sacred or ceremonial rituals, practices, or 

activities are or were performed, locations associated with the traditional beliefs or history of a cultural 

group, traditional hunting or gathering areas of economic and cultural importance, and sources of raw 

materials used to produce tools or sacred objects. The community may consider these properties 

significant to the cultural values, identity, and persistence of their traditional culture (NPS, 2012a). 

Cultural resources usually consist of tangible man-made properties, such as buildings, archeological sites, 

structures, objects, or historic districts. Although these same types of cultural resources may also be TCPs 

when cultural groups identify them as an important part of their community's history or as important to 

maintaining the cultural identity of their community, generally, the major differences in property types 

between cultural resources and TCPs are that the latter may be natural areas with no evidence of human 

activity or intervention.

Offshore TCPs may include subsistence hunting and fishing areas of cultural groups, and locations where 

American Indians or Alaska Natives performed ceremonial activities. For example, Chelhtenem (also 

known as Lily Point), located in Puget Sound, Washington (Figure 3.11-2), was added to the NRHP in 1994 

for its cultural importance as a fishing site. Lily Point was the most important Native reef net fishery and 

one of the most significant salmon fisheries of the Central Coast Salish Tribe. Chelhtenem was a center of 

traditional salmon culture for hundreds of years and a place of spiritual importance for native peoples. 

The First Salmon Ceremony honored the returning salmon and directed them into the reef nets. The bones 

of the first fish "were carefully returned to the sea where the fish regained its form and told other salmon 
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how well it had been treated, thus 

allowing the capture of other fish and 

insuring a return the following year." 

(Whatcom Land Trust, No Date). In the 

late 19th century, non-Indian fish traps 

replaced traditional reef nets. Alaska 

Packers purchased a cannery at Lily 

Point in 1884. The cannery was closed 

in 1917, leaving pilings and debris still 

visible today. 

Another example of a TCP is Nantucket 

Sound, Massachusetts, which was 

determined eligible for the NRHP in 

2010 (Figure 3.11-3). Nantucket Sound 

is a culturally significant landscape 

associated with the history and 

traditional cultural practices of two Wampanoag tribes. It has yielded and has the potential to yield 

important information about the Native American exploration and settlement of Cape Cod and the 

Islands. Although the exact boundary is not precisely defined, the Sound is eligible as an integral, 

contributing feature of a larger historic district (BOEM, 2019a). 

Figure 3.11-3. Nantucket Sound Traditional Cultural Place Boundary

Figure 3.11-2. Lily Point TCP, Washington
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3.11.1.3 Coastal Infrastructure and Communities and Nearshore Historic Properties

Coastal infrastructure refers to structures, 

systems, and facilities built along the coastline. 

This includes harbors, marinas, piers, and other 

types of development. 

A pier (Figure 3.11-4) is a raised structure in a 

body of water, typically supported by piles or 

pillars. Piers may support bridges, buildings, and 

walkways. Their open structure allows waves, 

tides, and currents to flow relatively 

unhindered. Piers can be categorized according 

to their principal purpose and include working 

piers, pleasure piers, and fishing piers. 

There are many piers listed or eligible for listing 

on the NRHP throughout the U.S. as either 

individual resources or as contributing elements 

of an historic district. Hanalei Pier in Hawai’i, for 

example, is a typical finger pier constructed in 

the 1920s. The structure was used seasonally, 

primarily to transport rice from Hanalei to 

Honolulu. It is one of approximately a dozen remaining structures of this type in the state and is listed on 

the NRHP for its historical significance as one of the last remaining vestiges of the rice industry in Hanalei 

(NPS, 1979).

Other cultural and historic resources located along the coastline include fishing communities, whaling

villages, and Native American settlements. A fishing community is a social or economic group whose 

members reside in a specific location and share a common dependence on commercial, recreational, or 

subsistence fishing or on directly related fisheries dependent services and industries (for example, 

boatyards, ice suppliers, tackle shops) (50 CFR 600.345).

Point Hope, Alaska, is one of the oldest continuously inhabited settlements in North America. Its whaling

traditions extend back thousands of years, and Tikigaq – its Inupiaq name – is considered to be one of the 

most traditional villages in Alaska. The people hunt caribou, moose, seals, walrus, birds, fish, beluga 

whales, and polar bear, but the bowhead whale remains the focus of the annual subsistence cycle (AEWC, 

No Date). 

In addition to the cultural and historic resources described above, there are many historic properties 

located near the shoreline that are listed or eligible for listing on the NRHP. Countless archaeological sites 

and cultural remains are also present along the coastline that provide evidence of the prehistory and 

history of coastal communities. These sites often contain lithic assemblages comprised of materials such 

as shell and midden refuse, fire cracked rock, quartz and basalt flakes, and chert points. 

3.11.1.4 Visual Resources Associated with Historic Properties

Under Section 106 of the NHPA, the potential visual impacts from a proposed project or activity are 

considered with respect to the integrity of setting, feeling, and/or association of historic properties. 

Figure 3.11-4. Tide Gauge on a Pier
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Setting is the physical environment of a historic property and can include natural or human-made 

elements, such as topographic features, vegetation, paths, or fences, and, importantly, the relationships 

between buildings and other features or open space. Feeling is a property’s expression of the aesthetic or 

historic sense of a particular period of time. It results from the presence of physical features that convey 

the property’s historic character. Association is the direct link between an important historic event or 

person and a historic property. A property retains association if it is the place where the event or activity 

occurred and is sufficiently intact to convey that relationship to an observer (Sullivan et. al, 2018). 

Some historic properties are or include “designed cultural landscapes” that may include purposefully 

designed views or vistas. In a designed cultural landscape, the view itself is a significant characteristic of 

the historic property. Therefore, changes to these designed views, vistas, or view corridors may adversely 

affect the integrity of the property’s design, not simply causing visual effects on integrity of setting, 

feeling, or association (NPS, No Date-b). 

Many coastal resources listed on the NRHP derive all or part of their significance from their historic 

maritime setting. These resources include TCPs, coastal fortifications, parks and seashores, residential 

estates, lighthouses, life-saving stations, breakwaters, marinas, fishing and resort communities, and shore 

lodgings of all kinds, including hotels, motels, inns, seasonal cottages, and permanent residences. Some 

TCPs, for example, derive their importance from unobstructed views toward the rising sun (Klein et al., 

2012). 

In 2012, BOEM directed the preparation of a GIS database of known cultural resources and historic 

properties that could be impacted by the introduction of off-shore energy facilities along the entire east 

coast of the U.S. Based on existing data, each resource was assessed with respect to its maritime setting 

and view to the sea. In total, 9,175 resources were considered to have a historically significant maritime 

setting and 1,108 were considered to have a historically significant view toward the open sea (Klein et al., 

2012).

3.11.2 Environmental Consequences for Cultural and Historic Resources

This discussion includes analysis of potential impacts to submerged cultural and historic resources; areas 

where traditional or tribal fishing rights are held and subsistence fishing and hunting are practiced, 

including TCPs; and coastal infrastructure listed or eligible for listing on the NRHP. Activities described in 

Sections 2.3.1 through 2.3.13 that occur on NOS projects and that could be expected to impact cultural 

and historic resources include: (1) anchoring; (2) bottom sampling; (3) installation, maintenance, and 

removal of tide gauges and buoys; and (4) installation of GPS reference stations. 

NOS has prepared this Final PEIS to inform the NHPA Section 106 consultation when implementing the 

Proposed Action. NOS will initiate project-specific consultations under Section 106 of the NHPA before 

commencing any activity with the potential to affect cultural or historic resources. Also, NOS intends to 

notify individual federally recognized tribes and Alaska Native corporations consistent with EO 13175 

(Consultation and Coordination with Indian Tribal Governments) before conducting any project that may 

have tribal implications. Federally recognized tribes and Alaska Native corporations may request formal 

government-to-government consultation pursuant to EO 13175 at any time. 

Note that this Final PEIS considers the impacts to historic and cultural resources from NOS data collection.

NOS acknowledges the potential for adverse effects resulting from the release of collected data. NOAA, 

like other federal agencies, is required to comply with Section 304 of the NHPA, which protects certain 
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sensitive information about historic properties from disclosure to the public when such disclosure could 

result in a significant invasion of privacy, damage to the historic property, or impede the use of a 

traditional religious site by practitioners. NOS would comply with Section 304 of the NHPA in the course 

of creating public data products. Effects from the release of collected data are not assessed further in the 

PEIS.

3.11.2.1 Methodology

The factors from NOS activities that could impact the cultural and historic environment include: (1) 

placement or dragging of equipment directly on or along the sea floor; (2) the presence of vessels 

operated by NOS within areas with activity restrictions, such as subsistence hunting and fishing areas, 

TCPs, and national marine sanctuaries; (3) placement of equipment on historic nearshore properties; (4) 

the discovery of archaeological resources during the installation of tide gauges, buoys, and GPS reference 

stations. These potential impact causing factors and their associated impacts on cultural resources are 

discussed below. 

As discussed in Section 3.2.2, significance criteria were developed for each resource to provide a 

structured framework for assessing impacts from the Proposed Action and the significance of the impacts. 

The significance criteria for cultural resources are shown in Table 3.11-1.

Table 3.11-1. Significance Criteria for the Analysis of Impacts to Cultural Resources

Impact 

Descriptor Context, Intensity, and Likelihood

Significance 

Conclusion

Negligible

The action would disturb a submerged archaeological 

resource or the sediment surrounding a submerged 

cultural or historic resource but would not have a 

measurable or perceptible impact. The action may occur 

in traditional subsistence hunting or fishing areas but 

would not disturb these practices.

Insignificant

Minor

The action would have a measurable or perceptible 

impact on a submerged cultural resource or historic 

resource’s location, design, setting, materials, feeling, or 

association, but would not cause the loss of diagnostic 

features or research potential. The action would cause a 

temporary (lasting a few days) interference with 

traditional subsistence hunting and fishing practices.

Moderate

The action would diminish the integrity of a submerged 

cultural or historic resource or a historic property's 

location, design, setting, materials, workmanship, 

feeling, or association, resulting in the loss of diagnostic 

features or research potential. The action would 

temporarily interfere with traditional subsistence

hunting and fishing practices during peak seasons or 

times.

Major

The action would permanently damage or destroy a 

submerged cultural or historic resource or historic 

property, resulting in the unrecoverable loss of the 

Significant
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Impact 

Descriptor Context, Intensity, and Likelihood

Significance 

Conclusion

resource or property’s historic value, diagnostic features, 

research potential, or integrity. The action would result in 

a prolonged disturbance of traditional subsistence

hunting and fishing practices during peak seasons or 

times. 

3.11.2.1.1 Projects with No Potential to Cause Effects to Historic Properties 

On December 20, 2017, following guidance from the Advisory Council on Historic Preservation (ACHP), 

NOS prepared a Statement on Surveying and Mapping Activities with No Potential to Cause Effects to 

Historic Properties (“Statement”) (NOS, 2017). This Statement identifies NOS projects that have no 

potential to cause effects to historic properties, assuming such historic properties were present, per 36 

CFR 800.3(a)(1). These projects, listed below, do not require consultation under Section 106 of the NHPA. 

The sections of this Final PEIS in which these activities are described in detail are also included below in 

parentheses. The full Statement includes justification for each NOS determination based on the potential 

for each method or technology to interact with the sea floor, where cultural and historic resources might 

be present. Actions that were determined to have no potential to cause effects to historic properties 

include: 

• Operation of manned vessels (Section 2.4.1);

• Operation of remotely operated vehicles and unmanned/autonomous systems (Section 2.4.3);

• Use of echo sounders (Section 2.4.4);

• Use of acoustic doppler current profilers (Section 2.4.5);

• Use of acoustic communication systems (Section 2.4.6);

• Use of sound speed data collection equipment (Section 2.4.7);

• Operation of drop/towed cameras and video systems (Section 2.4.8); and

• Use of passive listening systems (Section 2.4.10).

However, other activities performed under the Proposed Action (such as anchoring and bottom sampling) 

are not included in the Statement and could potentially damage cultural resources. These substratedisturbing activities and their potential impacts are discussed in the following sections. 

3.11.2.2 Alternative A: No Action - Conduct Surveys and Mapping for Coastal and 

Marine Data Collection with Current Technology and Methods, at Current 

Funding Levels

Although the survey effort under Alternative A would vary by year (see Table 3.4-4), the greatest number 

of nautical miles surveyed over the five-year period would be in the Southeast Region (over 50 percent). 

The survey effort in each of the other four regions would be of a similar order of magnitude, approximately 

10 percent in each region over five years, although slightly greater in the Alaska Region, where the survey 

effort would be approximately 16 percent over five years. Survey effort in the Great Lakes would be less 

than one percent of the total survey effort. In general, it is expected that level of effort and overall impacts 

trend together (i.e., greater impacts where the survey effort is higher), but there are other factors, such 

as location and depth of surveys, that add nuance to this trend. Overall, NOS projects would comprise a 

very small part of all ocean activities as vessels used by NOS would represent a very small proportion of 

all vessel traffic in the action area (as discussed in Section 2.4.1). Additionally, whenever possible, the 

location and timing of a given project would be purposefully coordinated to ensure that areas are not 
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repeatedly surveyed. This ensures that the potential environmental impacts directly resulting from 

proposed NOS activities would not be exacerbated by repeated surveys within a given area. 

3.11.2.2.1 Anchoring

Approximately 20 percent of NOS crewed vessel projects involve anchoring, so under Alternative A, NOS 

would undertake or fund approximately 55 projects with a planned anchoring component annually. 

Anchoring is described in Section 2.4.2. 

When a vessel is not collecting data, it may anchor either within the project area or nearby. While smaller 

boats used by NOS would not typically anchor except in an emergency, larger vessels conducting multiday efforts may anchor within or near the project area to reduce the transit time to the project area and 

to save fuel. 

Although anchoring has the potential to impact submerged isolated artifacts (e.g., fragments of tools, 

arrow points, stone bowls) from prehistoric or historic voyages, resources submerged as a result of sea 

level rise, or undocumented downed aircraft or shipwrecks, the likelihood of an anchor landing on a 

historic resource is low. Vessel operators would select the anchor location based on depth, protection 

from seas and wind, and bottom type. Preferred bottom types are sticky mud or sand, as those 

characteristics allow the flukes of the anchor to dig into the bottom and hold the chain in place. When 

working in an un-surveyed area or in an area that has not been surveyed in many years, the ship would

try to anchor in bays where data have already been collected, providing the ship with better information 

on where to drop the anchor. These practices would continue to minimize the potential for adverse 

impacts to submerged cultural or historic resources. Thus, adverse impacts would be unlikely, given that 

the submerged cultural or historic resources likely to be present in any one area compared to the 

enormous extent of the action area, continued adherence to NOS protocols, and the relatively small 

number of projects planned that would involve anchoring.

However, in the event anchoring results in the discovery of a cultural or historic property, the coordinates 

of the discovery would be noted and provided to the appropriate SHPO along with any information 

collected.

Impacts to cultural resources from anchoring under Alternative A would continue to be adverse and 

permanent and would range from negligible to moderate, depending upon the extent of damage the 

anchor caused to the resource and the cultural significance of the resource damaged. Anchoring could 

diminish the integrity of a submerged cultural or historic resource, resulting in the loss of diagnostic 

features or research potential. Impacts in general would be unlikely; impacts that would be moderate or 

higher would be very unlikely. It is far more likely that impacts would continue to be insignificant. 

3.11.2.2.2 Bottom Sampling

Under Alternative A, NOS would undertake or fund approximately 54 projects that require collection of 

bottom samples, annually. Bottom sampling is described in detail in Section 2.4.9. 

NOS would continue to use previously surveyed areas when available if anchoring were required for 

collection of the bottom sample. This would help to ensure that bottom samples are not collected near 

any documented or potential historic properties. When sampling the sea floor, crews would typically use 

a 6” by 6” clamshell bottom snapper or similar type of grab sampler or sediment corer to obtain samples. 

Samples would be obtained from only the top few inches of sediment. This is unlikely to disturb any 
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objects that may be present, as it is likely that there is a thick layer of sediment over long-buried objects. 

At most, a few cups of sediment would be collected during each bottom sampling activity. Samples would 

not be collected in waters deeper than 80 m (263 ft). In areas surveyed within the last 30 years, samples 

may not need to be collected at all. In keeping with NOS protocol, samples would not be collected on coral 

reefs, shipwrecks, obstructions, or hard bottom areas. These practices would continue to minimize the 

potential for adverse impacts to archaeological resources. 

However, if collection of a sample results in the discovery of an object that may be eligible for listing in 

the NRHP, the coordinates of the discovery would be noted and provided to the appropriate SHPO along 

with photographs of the sample and, if practicable, the recovered object itself. 

In the event of inadvertent resource discovery, effects from bottom sampling under Alternative A could 

be adverse or beneficial. Adverse impacts would occur if the resource were damaged or destroyed during 

sample collection and would range from negligible to minor (less than those that could result from 

anchoring activities due to the nature and smaller size of the grab sampler) and would be permanent. 

Beneficial impacts would occur if a resource were discovered that led to the identification of a culturallysignificant artifact, group of artifacts, or previously undocumented historic site. Impacts in general would 

be unlikely; impacts that could be moderate or higher would be very unlikely. It is far more likely that 

impacts would continue to be insignificant. 

3.11.2.2.3 Installation, Maintenance, and Removal of Tide Gauges, Buoys, and GPS Reference 

Stations

Tide gauge stations consist of a sensor, data collection platform, solar panels, and satellite transmitter. 

Tide gauge installation would continue to occur primarily out of the water at existing piers, docks, 

bulkheads, and similar locations. Images of tide gauge stations are included in Section 2.4.12. Under 

Alternative A, NOS would undertake or fund approximately 32 projects that include tide gauge 

installations and 305 projects that include tide gauge maintenance visits, annually. NOS would undertake 

or fund approximately 12 projects that include GPS reference system installation annually. 

As related to the Proposed Action, in accordance with 36 CFR 800.5, potential adverse effects from the 

installation of tide gauges on historic properties could include, but are not limited to:

i. Physical destruction of or damage to all or part of the property;

ii. Alteration of a property, including restoration, rehabilitation, repair, and maintenance...that is 

not consistent with the Secretary's standards for the treatment of historic properties (36 CFR 

part 68) and applicable guidelines;

iii. Removal of the property from its historic location;

iv. Change of the character of the property's use or of physical features within the property's 

setting that contribute to its historic significance; and 

v. Introduction of visual, atmospheric or audible elements that diminish the integrity of the 

property's significant historic features.

Impacts to coastal structures could occur if the installation of tide gauges and GPS reference stations 

affected the view of or from the coastal structure that would affect the integrity of the structure’s 

location, design, setting, materials, workmanship, feeling, or association, as described in Section 3.11.1.4. 

Installation of tide gauges and GPS reference stations also have the potential to damage the historic 

structures on which they are being placed. Pier-mounted acoustic sensors, pressure-sensor tide gauge
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stations, microwave sensors and instruments, shore-based GPS reference stations, and, to a lesser extent, 

GPS tide buoys installed within the viewshed of a nearshore historic property or designed cultural 

landscape have the potential to impact cultural and historic resources. Changes to these designed views, 

vistas, or view corridors could impact the integrity of the property’s design, not simply cause visual effects 

on the integrity of a historic property’s setting or other historic characteristics. 

If a sensor or station were proposed for installation on any coastal structure or would be anticipated to 

cause ground disturbance, NOS would continue to confer with the appropriate SHPO prior to installation. 

Adherence to this protocol would continue to minimize or avoid potential impacts to coastal structures 

listed or eligible for listing on the NRHP. 

Since NOS would continue to confer with the SHPO prior to the installation of tide gauges or GPS reference 

stations on properties listed or eligible for listing on the NRHP, adverse impacts to historic piers and 

viewsheds would be very unlikely, given the enormous extent of the action area compared to the small 

number of tide gauge and GPS reference station installations planned annually and the likely avoidance 

of historic sites during the site selection process or avoidance of impacts to historic coastal structures 

following communication with the SHPO. 

Impacts would be very unlikely; however, if a historic resource were inadvertently damaged during 

installation of tide gauges or GPS reference stations, impacts would continue to be adverse, short-term 

or long-term (depending on whether the installation is temporary or more permanent), would occur only 

to the historic resource or the viewshed of the historic resource, and would continue to range from 

negligible to minor. Impacts would therefore be insignificant. 

3.11.2.2.4 Impacts on Subsistence Hunting and Fishing Areas, Including TCPs

Where relevant, the THPO assumes oversight of the Section 106 process from the state, providing the 

tribe with review authority over federal undertakings (NPS, 2012b). E.O. 13175, Consultation and 

Coordination with Indian Tribal Governments (November 6, 2000), requires each federal agency to 

establish procedures for meaningful consultation and coordination with tribal officials in the development 

of federal policies that have tribal implications.

The procedures outlined in the NOAA Procedures for Government-to-Government Consultation with 

Federally Recognized Indian Tribes and Alaska Natives (NOAA Tribal Consultation Handbook) provide 

guidance to NOAA to support a consistent, effective, and proactive approach to communicating with 

tribes. Examples of actions with the potential to trigger communication with tribes include but are not 

limited to: 

• An action that would have effects within a reservation or Alaska Native village.

• An action that may impact tribal trust resources or the rights of a federally-recognized Tribe.

• An action affecting a facility or entity owned or operated by a tribal government. 

• An action that affects Tribes, tribal governments, or a tribe’s traditional way of life. 

• An action that affects TCPs or Traditional Use Areas.

EO 13175 and the NOAA Tribal Consultation Handbook provide required procedures for consultation in 

recognition of the sovereignty of federally-recognized tribes and the federal government’s trust 

responsibility to those tribes. NOS must invite any tribe to consult on a proposed policy, regulation, or 

action that might have tribal implications. NOS also consults with Alaska Native corporations on the same 
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basis as federally recognized tribes under EO 13175. NOAA also communicates with many non-recognized 

tribes and tribal coalition groups who have interests regarding NOAA's activities. 

In recent years in Alaska, the potential for NOS work to interfere with subsistence hunting has been the 

primary issue of concern identified by tribes during meetings. In the Pacific Northwest, the primary issues 

of concern from tribes have been the potential for NOS activities to affect ecotourism and to contribute 

to commercial vessel traffic. Concerns about the potential for NOS work to damage or alter historically or 

culturally significant sites have not been routinely identified in either location by tribal representatives. 

NOS would continue to attempt to coordinate projects that would occur in traditional hunting and fishing 

areas in Alaska and the Pacific Northwest to avoid peak hunting and fishing seasons (e.g., whale, seal, and 

salmon seasons) or times of year to the extent possible, based on information obtained from the tribes. 

The effects of NOS’s projects on subsistence hunting and fishing practices of Alaska Natives and 

indigenous tribes are discussed in further detail in Section 3.13.2. Any impacts to subsistence hunting or 

fishing that might occur if traditional hunting and fishing areas cannot be avoided during peak seasons are 

also described in Section 3.13.2. 

Activities planned to occur in any NRHP-listed TCP would continue to comply with federal regulations 

related to the protection of these culturally significant places. The Section 106 review process is mandated 

for any federal projects that might affect a TCP; consultation with the affected traditional community may 

also be required (NPS, No Date-a). With the legal protection afforded to listed TCPs by the Section 106 

review process, the effects of NOS activities in these areas under Alternative A are expected to be adverse, 

short-term (lasting only the duration of the activity), negligible to minor, and insignificant. 

NOS would continue to facilitate tribal involvement related to planned projects throughout the action 

area. For example, regional Coast Survey representatives (“Navigation Managers”) for Alaska and the 

Pacific Northwest would continue to discuss survey plans for the upcoming year during meetings open to 

the public. It is anticipated that these meetings would continue to be attended by tribal leadership or 

members. Meetings in the Pacific Northwest (Harbor Safety Committee meetings) would continue to take 

place approximately once every two months. In Alaska, meetings would continue to occur six to eight 

times per year. Following meetings, meeting minutes would continue to be developed and posted online.

Although NOS projects under Alternative A could temporarily interfere with traditional subsistence

hunting and fishing practices during peak seasons or times, with ongoing communication between NOS 

and THPOs and attempted avoidance of these areas during peak times to the extent practicable, impacts 

under Alternative A of projects on subsistence hunting and fishing areas, including TCPs, would continue 

to be adverse, short-term (lasting only the duration of the activity), negligible to moderate, and 

insignificant. 

3.11.2.2.5 Conclusion

The effects of impact causing factors on cultural resources range from negligible to moderate; thus, the 

overall impact of Alternative A on cultural resources, including impacts to submerged cultural or historic 

resources; coastal infrastructure; viewsheds of nearshore historic properties and designed cultural 

landscapes; and subsistence hunting and fishing areas, including TCPs, would continue to be adverse and 

moderate. Therefore, impacts of Alternative A to cultural and historic resources would continue to be 

insignificant. 
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3.11.2.3 Alternative B: Conduct Surveys and Mapping for Coastal and Marine Data 

Collection with Equipment Upgrades, Improved Hydroacoustic Devices, and 

New Tide Stations

The same impact causing factors on cultural resources considered under Alternative A are considered 

under Alternative B. Under Alternative B, all of the activities and equipment operations proposed in 

Alternative A would continue but at a higher level of effort, although the percentage of nautical miles 

covered by projects in each region would be the same as under Alternative A. Total survey effort for 

Alternative B in each region for the five-year timeframe is shown in Table 3.4-5. The greatest number of 

nautical miles surveyed over the five-year period would be in the Southeast Region (over 50 percent). The 

survey effort in each of the other four regions is of a similar order of magnitude (approximately 10 percent 

in each region over the five-year period), although slightly greater in the Alaska Region (approximately 16 

percent). Survey effort in the Great Lakes over the five-year period would represent less than one percent 

of the overall survey effort. As described under Alternative A, it is generally expected that level of effort 

and overall impacts trend together (i.e., greater impacts where the survey effort is higher), but there are 

other factors, such as location and depth of surveys, that add nuance to this trend. 

Survey activities under Alternative B would take place in the same geographic areas and timeframes as 

under Alternative A; however, Alternative B would include more projects and activities and thus more 

nautical miles traveled than Alternative A. Overall, there would be an additional 264,796 nm (490,402 km) 

of survey effort under Alternative B as compared to Alternative A. The types and mechanisms of impacts 

would remain the same in Alternative B as discussed for Alternative A. Therefore, the difference between 

the two alternatives is a matter of scale with an increased activity level, although distributed unevenly 

among the different types of activities, leading to a corresponding, incremental increase in the potential 

for effects under Alternative B as compared to Alternative A. 

Impacts of Alternative B on cultural resources, including submerged cultural or historic resources; coastal 

infrastructure; viewsheds of nearshore historic properties and designed cultural landscapes; and 

subsistence hunting and fishing areas, including TCPs, would be the same or slightly, but not appreciably, 

larger than those discussed above under Alternative A for each impact causing factor. Overall, impacts on 

cultural resources under Alternative B would be adverse, moderate, and insignificant.

3.11.2.4 Alternative C: Upgrades and Improvements with Greater Funding Support

The same impact causing factors for cultural resources considered under Alternatives A and B are 

considered under Alternative C. Under Alternative C, all of the activities and equipment operation 

proposed in Alternatives A and B would continue but at an even greater level of effort than Alternative B, 

given the overall funding increase of 20 percent relative to Alternative B. However, the percentage of 

linear nautical miles of survey effort in each region would be the same as under Alternatives A and B. Total 

survey effort for Alternative C in each region for the five-year timeframe is shown in Table 3.4-6. The 

greatest number of nautical miles surveyed over the five-year period would be in the Southeast Region 

(over 50 percent). The survey effort in each of the other four regions would be of a similar order of 

magnitude (approximately 10 percent in each region over five years), although slightly greater in the 

Alaska Region (approximately 16 percent over five years). Survey effort in the Great Lakes over the fiveyear period would be less than one percent of the overall survey effort. As described under Alternatives 

A and B, it is generally expected that level of effort and overall impacts trend together (i.e., greater impacts 

where the survey effort is higher), but there are other factors, such as location and depth of surveys, that 

add nuance to this trend. 
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Survey activities under Alternative C would take place in the same geographic areas and timeframes as 

under Alternatives A and B; however, Alternative C would include more projects and activities and thus 

more nautical miles traveled than Alternatives A and B. Overall, there would be an additional 264,796 nm 

(490,402 km) of survey effort under Alternative C as compared to Alternative B, and an additional 529,592 

nm (980,803 km) as compared to Alternative A. The types and mechanisms of impacts would remain the 

same in Alternative C as discussed for Alternatives A and B. Therefore, the difference between the 

alternatives is a matter of scale with an increased activity level, although distributed unevenly among the 

different types of activities, leading to a corresponding, incremental increase in effects under Alternative 

C as compared to Alternatives A and B.

The potential for impacts to cultural resources from Alternative C, including impacts to submerged cultural 

or historic resources; coastal infrastructure; viewsheds of nearshore historic properties and designed 

cultural landscapes; and subsistence hunting and fishing areas, including TCPs, would be the same or 

somewhat, but not appreciably, greater than those discussed above under Alternative A for each impact 

causing factor. Overall, impacts on cultural resources under Alternative C would be adverse, moderate, 

and insignificant.