CR-04 INVENTORY OF HISTORIC PROPERTIES WITH
`TRADITIONAL CULTURAL SIGNIFICANCE STUDY
`SUMMARY REPORT
`
`SKAGIT RIVER HYDROELECTRIC PROJECT
`FERC NO. 553
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`Seattle City Light
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`Prepared by:
`Algonquin Consultants, Inc.
`Camassia Resource Stewardship
`HDR Engineering, Inc.
`
`With contributions from:
`Confederated Tribes of the Colville Reservation,
`Nlaka’pamux Nation Bands Coalition, Nlaka’pamux Nation Tribal Council,
`Nooksack Indian Tribe, Sauk-Suiattle Indian Tribe,
`S'ólh Téméxw Stewardship Alliance, Stillaguamish Tribe of Indians,
`Swinomish Indian Tribal Community, and Upper Skagit Indian Tribe
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`January 2025
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`Section No.
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`1.0
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`2.0
`3.0
`4.0
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`5.0
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`6.0
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`TABLE OF CONTENTS
`Description
`
`Page No.
`
`Introduction .................................................................................................................... 1-1
`1.1
`Project Background .............................................................................................. 1-2
`1.2
`CR-04 Study Plan ................................................................................................ 1-3
`1.2.1 Study Plan Determination ........................................................................ 1-4
`1.2.2 Prior Reporting......................................................................................... 1-4
`Section 106 Consultation ..................................................................................... 1-5
`1.3
`Study Goals and Objectives .......................................................................................... 2-1
`Study Area ...................................................................................................................... 3-1
`Study Methods and Theory ........................................................................................... 4-1
`4.1
`General Approach and Protocols ......................................................................... 4-1
`4.2
`Landscape and Collaborative Research Theory and Applied Practice ................ 4-2
`4.2.1 Traditional Places..................................................................................... 4-3
`4.2.2 Traditional Cultural and Ethnographic Landscapes ................................. 4-3
`4.2.3 The TCP Identification and Documentation Process ............................... 4-5
`Key Terms and Concepts within the CR-04 Study
`4.2.3.1
`Process ................................................................................... 4-5
`Four-Step Process of National Register Bulletin 38 .............. 4-7
`4.2.3.2
`CR-04 Study Implementation Process ................................... 4-9
`4.2.3.3
`4.2.4 Case Studies in TCP Documentation ..................................................... 4-10
`4.2.4.1
`First Salmon: Klamath Riverscape ...................................... 4-10
`4.2.4.2
`Lochsa River Corridor: TCP Study and Nomination ........... 4-11
`4.2.4.3
`Badger-Two Medicine Traditional Cultural District:
`National Register Nominations ............................................ 4-12
`Study Implementation ................................................................................................... 5-1
`5.1
`Study Implementation Activities ......................................................................... 5-1
`5.2
`The Lead Ethnographer Team’s Role in Study Implementation ......................... 5-4
`Study Results .................................................................................................................. 6-1
`6.1
`Overview .............................................................................................................. 6-1
`6.2
`Integrity of the Identified Properties with Traditional Cultural Significance ...... 6-7
`6.3
`Indian Tribe and Canadian First Nation Public-facing CR-04 Study Reports ..... 6-8
`6.3.1 Confederated Tribes of the Colville Reservation ..................................... 6-8
`6.3.2 Nlaka'pamux Nation Bands Coalition ...................................................... 6-8
`6.3.3 Nlaka'pamux Nation Tribal Council ...................................................... 6-11
`6.3.4 Nooksack Indian Tribe ........................................................................... 6-13
`6.3.5 Sauk-Suiattle Indian Tribe ..................................................................... 6-15
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`7.0
`
`7.2
`7.3
`
`6.3.6 S’ólh Téméxw Stewardship Alliance..................................................... 6-17
`6.3.7 Stillaguamish Tribe of Indians ............................................................... 6-20
`6.3.8 Swinomish Indian Tribal Community ................................................... 6-23
`6.3.9 Upper Skagit Indian Tribe ..................................................................... 6-25
`Resource Documentation Submitted to DAHP and City Light ......................... 6-28
`6.4
`Potential Project-related Adverse Effects and Management Recommendations .... 7-1
`Potential Project-Related Adverse Effects Identified by Indian Tribes and
`7.1
`Canadian First Nations ......................................................................................... 7-1
`Recommendations of Indian Tribes and Canadian First Nations ........................ 7-3
`Summary of Potential Project-related Adverse Effects and Co-Lead
`Ethnographers’ Management Recommendations ................................................ 7-7
`Summary and Next Steps .............................................................................................. 8-1
`8.0
`Variances from FERC-Approved Study Plan and Proposed Modifications ............ 9-1
`9.0
`10.0 References ..................................................................................................................... 10-1
`
`
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`List of Figures
`Page No.
`Description
`Figure No.
`Figure 3.0-1. Location map of the Skagit River Hydroelectric Project Boundary and APE. .... 3-2
`Figure 3.0-2. Skagit River Hydroelectric Project Boundary and APE/CR-04 study area
`depicted on aerial imagery (page 1 of 3). ............................................................ 3-3
`Figure 3.0-2. Skagit River Hydroelectric Project Boundary and APE/CR-04 study area
`depicted on aerial imagery (page 2 of 3). ............................................................ 3-4
`Figure 3.0-2. Skagit River Hydroelectric Project Boundary and APE/CR-04 study area
`depicted on aerial imagery (page 3 of 3). ............................................................ 3-5
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`
`
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`List of Tables
`Page No.
`Description
`Table No.
`Table 6.1-1. Summary of Properties with Traditional Cultural Significance identified in
`the APE by study participants1 ............................................................................ 6-5
`Table 6.4-1. Summary of Districts with Traditional Cultural Significance for which TCP
`Forms have been Submitted to DAHP for the CR-04 Study1. ........................... 6-30
`Table 6.4-2. Summary of Sites with Traditional Cultural Significance for which TCP
`Forms have been Submitted to DAHP for the CR-04 Study1. ........................... 6-30
`Table 7.3-1. Summary of Project effects assessments and management recommendations
`for districts that have been documented with DAHP for the CR-04 Study. ........ 7-8
`Table 7.3-2. Summary of Project effects assessments and management recommendations
`for sites that have been documented with DAHP for the CR-04 Study............... 7-8
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`Table of Contents
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`List of Attachments
`PUBLIC: Swinomish Indian Tribal Community CR-04 Inventory of Historic
`Properties with Traditional Cultural Significance Study Report Abstract
`PRIVILEGED: Confederated Tribes of the Colville Reservation CR-04
`Inventory of Historic Properties with Traditional Cultural Significance Study
`Report
`PRIVILEGED: Nlaka’pamux Nation Tribal Council CR-04 Inventory of
`Historic Properties with Traditional Cultural Significance Study Report
`PRIVILEGED: Nooksack Indian Tribe CR-04 Inventory of Historic Properties
`with Traditional Cultural Significance Study Report
`PRIVILEGED: Sauk-Suiattle Indian Tribe CR-04 Inventory of Historic
`Properties with Traditional Cultural Significance Study Report
`PRIVILEGED: S’ólh Téméxw Stewardship Alliance CR-04 Inventory of
`Historic Properties with Traditional Cultural Significance Study Report
`PRIVILEGED: Stillaguamish Tribe of Indians CR-04 Inventory of Historic
`Properties with Traditional Cultural Significance Study Report
`PRIVILEGED: Upper Skagit Indian Tribe CR-04 Inventory of Historic
`Properties with Traditional Cultural Significance Study Report
`PUBLIC: Section 106 Consulation Record for CR-04 Inventory of Historic
`Properties with Traditional Cultural Significance Study Report
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`Attachment A
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`Attachment B
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`Attachment C
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`Attachment D
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`Attachment E
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`Attachment F
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`Attachment G
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`Attachment H
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`Attachment I
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`List of Acronyms and Abbreviations
`
`
`AAA ...........................American Anthropological Association
`ACHP .........................Advisory Council on Historic Preservation
`APE ............................Area of Potential Effects
`B2M ...........................Badger-Two Medicine
`CFR ............................Code of Federal Regulations
`City Light ...................Seattle City Light
`CRD ...........................Cultural Resources Department
`CRWG........................Cultural Resources Work Group
`DAHP .........................Department of Archaeology and Historic Preservation
`Ecology ......................Washington State Department of Ecology
`FERC..........................Federal Energy Regulatory Commission
`FLA ............................Final License Application
`H/A .............................History/Archaeology
`HDR ...........................HDR Engineering, Inc.
`HPMP .........................Historic Properties Management Plan
`ISR .............................Initial Study Report
`NDA ...........................non-disclosure agreement
`NHPA .........................National Historic Preservation Act
`NIT .............................Nooksack Indian Tribe
`NNTC .........................Nlaka'pamux Nation Tribal Council
`NPS ............................National Park Service
`NRB ...........................National Register Bulletin
`NRHP .........................National Register of Historic Places
`PA ..............................Programmatic Agreement
`PRM ...........................Project River Miles
`Project ........................Skagit River Hydroelectric Project
`PTRCI ........................Property of Traditional and Religious Cultural Importance
`RISC ...........................Resource Inventory Standards Committee
`RLNRA ......................Ross Lake National Recreation Area
`RSP ............................Revised Study Plan
`SHPO .........................State Historic Preservation Officer
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`List of Acronyms and Abbreviations
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`SITC ...........................Swinomish Indian Tribal Community
`SSIT ...........................Sauk-Suiattle Indian Tribe
`STSA ..........................S'ólh Téméxw Stewardship Alliance
`TCD............................Traditional Cultural District
`TCL ............................Traditional Cultural Landscape
`TCP ............................Traditional Cultural Property
`THPO .........................Tribal Historic Preservation Officer
`U.S.C. .........................United States Code
`USFS ..........................U.S. Forest Service
`USGS .........................U.S. Geological Survey
`USIT ...........................Upper Skagit Indian Tribe
`USR ............................Updated Study Report
`WDFW .......................Washington Department of Fish and Wildlife
`WISAARD .................Washington Information System for Architectural and Archaeological
`Records Data
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`INTRODUCTION
`
`1.0
`This is a public-facing summary of the results of a cultural resources study entitled CR-04
`Inventory of Historic Properties with Traditional Cultural Significance Study (CR-04 Study),
`which was implemented for the Skagit River Hydroelectric Project (Skagit Project, or Project)
`relicensing. This study focuses on the types of potential historic properties that may possess
`traditional cultural or religious significance as described in National Register Bulletin 38:
`Guidelines for Evaluating and Documenting Traditional Cultural Properties (National Register
`Bulletin [NRB] 38). As described in this bulletin, significance of a historic property can be derived
`from the role the property plays “in a community's historically rooted beliefs, customs, and
`practices.” Therefore, Seattle City Light (City Light) and its consultant team have collaborated
`with and provided support to the Indian Tribes and Canadian First Nations who identify the
`geography of the Project as an area of historical and cultural importance. The Indian Tribes and
`Canadian First Nations who have elected to participate in this study have authored individual
`studies that identify places of cultural importance and articulate their significance, while remaining
`consistent with documentation outlined in the study plan for the CR-04 Study submitted by City
`Light to the Federal Energy Regulatory Commission (FERC) and approved by FERC in its
`decision document dated July 16, 2021 (Accession No. 20210716-3034). The CR-04 Study is also
`consistent with the CR-04 Research Design Summary Report submitted by City Light to FERC
`and accepted for filing on September 12, 2023 (Accession Nos. 20230912-5169, 20230912-5170).
`
`The CR-04 Study is one of four cultural resources studies designed for City Light’s relicensing
`process, to identify, document, and evaluate cultural resources in the Project’s Area of Potential
`Effects (APE) that may (1) be eligible for inclusion in the National Register of Historic Places
`(NRHP) as historic properties, defined in the National Historic Preservation Act (NHPA) and
`implementing Code of Federal Regulations (CFR) 36 CFR Part 800, and (2) may incur adverse
`effects due to activities of the Project in a new license term. The results of these studies will provide
`a basis for FERC and designee (City Light) to consult with NHPA Section 106 parties, and propose
`management strategies to avoid, minimize, or mitigate effects to historic properties caused by
`operating the Project through a new license term. Below is a list of the four Project relicensing
`cultural resources studies:
`
` CR-01 Cultural Resources Data Synthesis;
` CR-02 Cultural Resources Survey;
` CR-03 Gorge Bypass Reach Cultural Resources Survey; and
` CR-04 Inventory of Historic Properties with Traditional Cultural Significance Study (this
`study)
`
`Nine Indian Tribes and Canadian First Nations participated in the CR-04 Study, including (listed
`alphabetically):
`
` Confederated Tribes of the Colville Reservation
` Nlaka’pamux Nation Bands Coalition
` Nlaka’pamux Nation Tribal Council
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` Nooksack Indian Tribe
` Sauk-Suiattle Indian Tribe
` S’ólh Téméxw Stewardship Alliance representing 17 First Nations1
` Stillaguamish Tribe of Indians
` Swinomish Indian Tribal Community
` Upper Skagit Indian Tribe
`
`These participating Indian Tribes and Canadian First Nations have either worked directly with
`ethnographers of their choice or have implemented their studies in-house. These studies document
`and evaluate properties of traditional cultural significance that may be eligible as historic
`properties under the NRHP Criteria for Evaluation and have potential to be affected by activities
`and/or operations associated with the Project. Additionally, City Light engaged a lead
`ethnographer team to provide guidance to the study participants on study implementation and
`reporting, ensuring consistency with the study plan approved by FERC. The lead ethnographers
`and/or City Light coordinated with the various Indian Tribes and Canadian First Nations to prepare
`this CR-04 Summary Report that documents the public-facing results of the study. This report
`document reflects all information received from participating Indian Tribes and Canadian First
`Nations as of August 16, 20242. City Light has invited participating Indian Tribes and Canadian
`First Nations to provide final reports and findings from their studies upon completion. Not all
`participating parties have completed or shared work products with City Light. City Light does not
`make assumptions regarding potential historic properties with traditional cultural significance and
`related Project effects in the absence of information from the participating Indian Tribes and
`Canadian First Nations.
`
`Project Background
`1.1
`The Project, licensed to the City of Seattle, Washington, and operated through its publicly-owned
`electric power utility City Light, is located in northwest Washington State and consists of three
`power-generating developments on the Skagit River—Ross, Diablo, and Gorge—and associated
`lands and facilities. The Project generating facilities are in the Cascade Mountains of the upper
`Skagit River watershed, between Project River Miles (PRM) 94.7 and 127.9 (U.S. Geological
`Survey [USGS] River Miles 94.2 and 127). Power from the Project is transmitted via two 230-
`kilovolt powerlines that span over 100 miles and end just north of Seattle at the Bothell Substation.
`
`1
`
`
`The S'ólh Téméxw Stewardship Alliance member First Nations are: Aitchelitz First Nation, Chawathil First
`Nation, Seabird Island First Nation, Shxwhà:y Village, Skowkale First Nation, Soowahlie First Nation, Sq’éwlets,
`Squiala First Nation, Tzeachten First Nation, Yakweakwioose First Nation, Kwaw’Kwaw’Apilt First Nation,
`Scowlitz First Nation, Skawahlook (Sq’ewá:lxw) First Nation, Skwah First Nation, Sumas First Nation, and Yale
`First Nation. The Stó:lō Research and Resource Management Centre and People of the River Referrals Office,
`have been the points of contact for S'ólh Téméxw Stewardship Alliance for this study.
`2 Nlaka'pamux Nation Tribal Council and S'ólh Téméxw Stewardship Alliance subsequently provided the updated
`privileged study reports included in Attachments C and F, respectively, to City Light to match the TCP forms
`those study participants had provided to DAHP.
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`The Project also includes two City Light owned towns, an Environmental Learning Center, several
`recreation facilities, and several fish and wildlife mitigation lands.3
`
`Project generating facilities are all located in Whatcom County, although Ross Lake (the most
`upstream reservoir) crosses the U.S.-Canada border and extends for about one mile into British
`Columbia at normal maximum water surface elevation. Gorge Powerhouse (the most downstream
`facility) is approximately 120 miles northeast of Seattle and 60 miles east of Sedro-Woolley, the
`nearest large town. The closest town is Newhalem, which is part of the Project and just downstream
`of Gorge Powerhouse. The primary transmission lines cross Whatcom, Skagit, and Snohomish
`counties; the fish and wildlife mitigation lands are in the same counties.
`
`The Project Boundary spans over 133 miles from the Canadian border to the Bothell Substation
`just north of Seattle, Washington. In addition, there are “islands” of fish and wildlife mitigation
`lands and recreation facilities within the Skagit, Sauk, and South Fork Nooksack watersheds that
`are also within the Project Boundary. Project generating facilities are entirely within the Ross Lake
`National Recreation Area (RLNRA), which is administered by the National Park Service (NPS) as
`part of the North Cascades National Park Complex. The RLNRA was established in 1968 in the
`enabling legislation for North Cascades National Park to provide for the “public outdoor recreation
`use and enjoyment of portions of the Skagit River and Ross, Diablo, and Gorge lakes.” The
`legislation maintains the FERC jurisdiction “in the lands and waters within the Skagit River
`Hydroelectric Project,” as well as hydrologic monitoring stations necessary for the proper
`operation of the Project (16 United States Code [U.S.C.] § 90d-4; Public Law 90-544. Sec. 505
`dated October 2, 1968, as amended by Public Law 100-668. Sec. 202 dated November 16, 1988).
`
`Relicensing of the Project by FERC is considered a federal undertaking under Section 106 of the
`NHPA, as amended, and its implementing regulations (36 CFR Part 800). Section 106 establishes
`a process for federal agencies to identify and take into account the effects of their undertakings on
`historic properties, as defined further in the paragraphs below.
`
`Historic property means any prehistoric or historic district, site, building, structure, or object
`included in, or eligible for inclusion in, the NRHP maintained by the Secretary of the Interior. This
`term includes artifacts, records, and remains that are related to and located within such properties.
`The term includes properties of traditional religious and cultural importance to an Indian Tribe or
`Native Hawaiian organization and that meet the National Register criteria (36 CFR §
`800.16[1][1]).
`
`CR-04 Study Plan
`1.2
`The CR-04 Study was conducted in support of the relicensing of the Project, FERC No. 553, as
`identified in the Revised Study Plan (RSP) submitted by City Light on April 7, 2021 (City Light
`2021). On June 9, 2021, City Light filed a “Notice of Certain Agreements on Study Plans for the
`Skagit Relicensing” (June 9, 2021 Notice).4 The June 9, 2021 Notice proposed no changes to the
`
`3
`
`
`In 2020, City Light amended the Project Boundary to include additional fish and wildlife mitigation lands that
`were recently acquired under ongoing implementation of the current FERC Project license (April 1, 2020, request
`to amend Exhibit K, as modified in its August 19, 2020 Response to FERC’s July 21, 2020 Additional Information
`Request).
`4 Referred to by FERC in its July 16, 2021 Study Plan Determination as the “updated RSP.”
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`CR-04 Study as described in the RSP but did detail additional modifications to the RSP agreed to
`between City Light and supporting licensing participants (which include the Swinomish Indian
`Tribal Community, Upper Skagit Indian Tribe, National Marine Fisheries Service, NPS, U.S. Fish
`and Wildlife Service, Washington State Department of Ecology [Ecology], and Washington
`Department of Fish and Wildlife [WDFW]).
`
`Study Plan Determination
`1.2.1
`In its July 16, 2021 Study Plan Determination, FERC approved the CR-04 Study with
`modifications. Specifically, FERC recommended that City Light include the Nlaka’pamux Nation
`Bands Coalition as a Canadian First Nation that should be consulted during the study. Accordingly,
`City Light consulted with the Nlaka’pamux Nation Bands Coalition for the study.
`
`Prior Reporting
`1.2.2
`On March 8, 2022, City Light filed its Initial Study Report (ISR). At that time, the Upper Skagit
`Indian Tribe requested to modify the CR-04 Study by including them as a participating Indian
`Tribe who would independently provide their research results in a privileged study report. FERC’s
`August 8, 2022 Determination on Requests for Study Modifications found that City Light is
`conducting the study in accordance with the approved study plan and Section 106 criterion and
`required no modifications to the study.
`
`A progress report on the CR-04 Study was filed with FERC as part of City Light’s Updated Study
`Report (USR) on March 8, 2023. As reported in the USR, City Light extended the schedule for
`completion of this study. A key factor in City Light’s decision to provide more time for study
`participants to complete this study was due to the schedule. The CR-04 Study was designed to be
`a two-year study, but because of several delays for a variety of reasons,5 significantly less than
`two years would have been available for study implementation. Allowing more time for the CR-
`04 Study has provided study participants an additional field season to gather data in 2023.
`
`The study plan required development of a research design for the study, which was developed and
`finalized in 2023. The CR-04 Study Research Design outlined the individual processes and
`methodologies that each study participant identified for implementing the study, while remaining
`consistent with the study plan. The Department of Archaeology and Historic Preservation (DAHP)
`affirmed the adequacy of the CR-04 Study Research Design in a letter dated September 6, 2023,
`and the final research design was filed with FERC on September 12, 2023.
`
`Implementation and reporting of the CR-04 Study continued into 2023 and 2024. The study efforts
`and results are summarized in this public-facing report, which City Light submitted to the FERC
`docket for the Skagit Project (P-553) on January 10, 2025. Privileged study reports from each
`study participant, documenting individual study efforts and results, are included as privileged
`attachments (Attachments B-D and F-H) to this report or have been filed separately with FERC by
`
`5
`
`
`Some of the reasons for these delays include impacts from COVID-19; catastrophic wildfires and flooding that
`impacted study participants’ ability to implement the study; unique decision-making processes of the study
`participants that required additional time to complete; the need for complex contracting mechanisms necessary to
`support study participants and/or their chosen ethnographers; and an extensive outreach process required to
`identify qualified and available ethnographers to assist with study implementation.
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`1.0 Introduction
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`individual study participants (Attachment E, filed March 7, 2024 by Sauk-Suiattle Indian Tribe;
`FERC Accession Number 20240307-5137).
`
`The remainder of this document is organized as follows:
`
` Section 2.0 includes the goals and objectives of the CR-04 Study.
` Section 3.0 describes the Project study area or APE.
` Section 4.0 provides an overview of methods including a description of key terms and
`concepts, a review of the four-step process outlined in NRB 38, and an overview of the
`protocols and processes involved in study implementation.
` Section 5.0 discusses the study implementation including a description of study activities and
`key deliverables.
` Section 6.0 presents the study results and summarizes the findings of each of the Indian Tribes
`and Canadian First Nations CR-04 study reports that identified historic properties with
`traditional cultural significance and assessed NRHP eligibility.
` Section 7.0 presents the potential Project-related adverse effects and management
`recommendations.
` Section 8.0 provides a summary of the study and next steps vis-à-vis the Historic Properties
`Management Plan (HPMP).
` Section 9.0 identifies any variances to the FERC-approved study plan.
` Section 10.0 lists the references used in this CR-04 Summary Report.
`
`Attachments A through I to this CR-04 Summary Report include the Swinomish Indian Tribal
`Community’s public-facing study abstract for the CR-04 Study (Attachment A) and privileged
`CR-04 study reports that are not public-facing for the following: Confederated Tribes of the
`Colville Reservation (Attachment B), the Nlaka’pamux Nation Tribal Council (Attachment C), the
`Nooksack Indian Tribe (Attachment D), the Sauk-Suiattle Indian Tribe (Attachment E), the S’ólh
`Téméxw Stewardship representing 17 First Nations (Attachment F), the Stillaguamish Tribe of
`Indians (Attachment G), and the Upper Skagit Indian Tribe (Attachment H). The Section 106
`Consulation Record for CR-04 Inventory of Historic Properties with Traditional Cultural
`Significance Study Report (Attachment I) is public facing.
`
`Section 106 Consultation
`1.3
`City Light, as FERC’s non-federal representative6 for carrying out informal consultation under
`Section 106 of the NHPA, has consulted with Section 106 participants for the CR-04 Study. The
`Section 106 consulting parties include (in alphabetical order): Confederated Tribes of the Colville
`Reservation, DAHP, FERC, Lummi Nation, Muckleshoot Indian Tribe, Nlaka’pamux Nation
`Bands Coalition, Nlaka’pamux Nation Tribal Council, Nooksack Indian Tribe, North Cascades
`Conservation Council, North Cascades Institute, NPS, Samish Indian Nation, Sauk-Suiattle Indian
`
`
`6 On June 26, 2020, FERC issued a “Notice of Intent to File License Application for a New License and
`Commencing Pre-filing Process” in which FERC designated City Light as its non-federal representative for
`carrying out informal consultation pursuant to Section 106 (FERC Filing Accession No. 20200626-3024).
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`Tribe, Snohomish County, Skagit River System Cooperative, Snohomish County, Snohomish
`County Public Utility District No. 1, Snoqualmie Indian Tribe, Stillaguamish Tribe of Indians,
`S’ólh Téméxw Stewardship Alliance, Suquamish Tribe, Swinomish Indian Tribal Community,
`Tulalip Tribes of Washington, Upper Skagit Indian Tribe, U.S. Bureau of Indian Affairs, U.S.
`Department of the Interior, U.S. Forest Service (USFS), WDFW, Washington Department of
`Natural Resources, Washington State Parks and Recreation, and Washington Trust for Historic
`Preservation. Other entities receiving updates related to the Cultural Resources Work Group
`(CRWG) include Skagit County and Ecology. The CRWG is one of multiple working groups
`created by City Light for the purpose of organizing coordination with participants engaging in the
`Project relicensing process.
`
`As part of the iterative process of the CR-04 Study, participating Indian Tribes and Canadian First
`Nations were provided multiple opportunities to review and provide feedback on the early drafts
`of the CR-04 Summary Report. The first review began on December 22, 2023, and ended on
`January 31, 2024. City Light addressed all comments received to create a revised draft of the CR-
`04 Summary Report. The second review of the revised draft by study participants began on March
`8, 2024, and ended on March 20, 2024. City Light received no comments from participating Indian
`Tribes or Canadian First Nations on the second draft. City Light sent the CR-04 Summary Report
`to the NHPA Section 106 consulting parties on March 29, 2024, for a 30-day review period without
`the privileged attachments (Attachments B-H). City Light received no comments from the
`consulting parties. Subsequently, the CR-04 Summary Report was revised to incorporate updated
`information regarding participating Indian Tribes’ and Canadian First Nations’ submittals of TCP
`forms, privileged reports, and shapefiles to DAHP. The revised CR-04 Summary Report was then
`submitted to the Indian Tribes and Candian First Nations participating in the study for a two-week
`review period to confirm the updates. The review period began on October 10, 2024, and ended
`on October 24, 2024. City Light received no comments from participating Indian Tribes or
`Canadian First Nations on the revised CR-04 Summary Report.
`
`With the iterative review cycles with Indian Tribes and Canadian First Nations completed, City
`Light then submitted this report and its attachments7 to DAHP on December 11, 2024, for its
`review and to request concurrence on the associated NRHP eligibility determinations. In a letter
`dated December 16, 2024, DAHP concurred with the eligibility determinations that are included
`in this report.
`
`City Light updated this CR-04 report to reflect its consultation with DAHP and DAHP’s
`concurrence r