Draft Huron National Wildlife Refuge Lighthouse (West Huron) Island Cultural Resources Management Plan

April 2020 Huron National Wildlife Refuge 1674 Refuge Entrance Road Seney, MI 49883

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Regional Historic Preservation Officer

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Refuge Supervisor Signature

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Approved:

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Table of Contents Signature Page ...... 2 Table of Contents ...... 3 Executive Summary ...... 5 Chapter 1. Introduction ...... 6 1.1 Huron National Wildlife Refuge Purposes, Mission and Goals ...... 6 1.2 Relationship to other plans and compliance documents ...... 8 1.3 Plan Purpose and Vision ...... 11 Chapter 2. Huron’s History: A Context for Cultural Resources ...... 13 2.1 Environmental Setting ...... 13 2.2 Summary of Lighthouse Island’s History ...... 14 Chapter 3. Identification and Evaluation of Cultural Resources on Lighthouse Island ...... 15 3.1 Previous Cultural Resources Investigations ...... 15 3.2 Inventory of Known Cultural Resources ...... 16 3.3 National Historic Register Listed and Eligible Properties ...... 16 Chapter 4. Management Considerations ...... 16 4.1 Location ...... 16 4.2 Wilderness Designation ...... 16 4.3 Hazardous Materials ...... 18 4.4 Conditions Affecting Cultural Resources (Natural) ...... 19 4.5 Conditions Affecting Cultural Resources (Human) ...... 20 Chapter 5. Public Involvement ...... 21 5.1 Refuge Visitor Use ...... 22 5.2 Partnerships ...... 22 5.3 Opportunity for Participation by Partners and Stakeholders ...... 24 5.4 Interpretation Projects ...... 25 5.5 Scoping Efforts ...... 26 Chapter 6. Intended Disposition of Cultural Resources ...... 27 6.1 Intended Disposition and its Relationship to the Huron Islands Light Station, Refuge Mission and Wilderness Character ...... 27 6.2 Cultural Resources to be Preserved in Place ...... 28 6.3 Cultural Resources to be Demolished and Removed ...... 29 Chapter 7. Treatment of Cultural Resources Preserved in Place ...... 31

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7.1 Condition Assessments ...... 31 7.2 Preservation Treatment for Historic Properties ...... 31 7.3 Preservation Treatment for Cultural Resources not Historic Properties ...... 32 Chapter 8. Treatment of Cultural Resources Demolished and Removed ...... 32 8.1 Demolition and Removal of Historic Properties ...... 33 8.2 Demolition and Removal of Cultural Resources not Historic Properties ...... 33 Chapter 9. Envisioning Implementing the Plan ...... 33 9.1 Plan Review and Revision Schedule ...... 33 9.2 Staff Requirements ...... 33 9.3 Preservation Project Goals ...... 35 9.4 Summary ...... 35 9.5 Five year rolling maintenance plan ...... 37 References Cited ...... 38 Appendix A ...... 39 Minimum Requirements Analysis - 2019 ...... 39 Appendix B ...... 40 Maps and Photos of the Cultural Resources of Lighthouse Island in 2016 ...... 40 Appendix C ...... 41 Additional Photos of the Cultural Resources of Lighthouse Island ...... 41

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Executive Summary The U.S. Fish and Wildlife Service is issuing a Cultural Resources Management Plan to cover the cultural resources on Lighthouse (West Huron) Island within the Huron National Wildlife Refuge and Huron Islands Wilderness. This draft Cultural Resources Plan further outlines historical context and description of the preferred alternative evaluated in the Draft Environmental Assessment. The Service's preferred alternative preserves and protects the Lighthouse, Assistant Keepers Quarters, Privy, Oil House, Dock, and Pathway as part of the Huron Islands Light Station and associated infrastructure, while demolishing and removing the Boathouse, Fog Signal Building, Barracks, and other site features as outlined. The Draft Environmental Assessment proposes that the preferred alternative best meets the purpose and need as it would provide the most positive permanent benefits to Wilderness character from benchmark conditions while still allowing compatibility with the refuge’s purposes and compliance with the National Historic Preservation Act. In addition, the Draft Environmental Assessment evaluates the effects on the human environment associated with the actions outlined in this plan.

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Chapter 1. Introduction This Cultural Resources Management Plan (plan) covers Lighthouse (West Huron) Island within the Huron National Wildlife Refuge (refuge) and Huron Islands Wilderness (Wilderness) in Lake Superior, Marquette County, Michigan. This plan will layout a long-term program for administering important cultural resources on the island that are in need of major protection and maintenance. This plan presents a general introduction to the mission and goals of the agency, background historical information as a context for examining the various resources, suggests standard treatment strategies and nonstandard exceptions, provides for consultation opportunities, and encourages public involvement. 1.1 Huron National Wildlife Refuge Purposes, Mission and Goals Theodore Roosevelt designated four small unnamed rocky islands the Huron Islands Reservation on October 10, 1905 by Executive Order 357-D, making it the first National Wildlife Refuge in the U.S. Fish and Wildlife Service’s Great Lakes Region (Interior Region 3). In 1938, Franklin Roosevelt signed Executive Order 7795 to enlarge the refuge to include all of the islands in the Huron island group and reestablish the refuge as Huron Migratory Bird Refuge. President Roosevelt reserved uses to the War Department and the Commerce Department (superseded and modified Executive Order 4430 (23 April 1926) as it applies to these island, and revoked Executive Order 357-D). It was renamed Huron National Wildlife Refuge by Presidential Proclamation 2416 (25 Jul 1940). The Huron Islands were then designated as a Wilderness Area on October 23, 1970 under Public Law 91-504. In 1978, all but eleven acres of Lighthouse Island was transferred to the U.S. Fish and Wildlife Service (Service, FWS). In 1991, the United States Coast Guard desired to transfer the remaining eleven acres to the Service and therefore entered into a lease with the Service. Finally, the remaining eleven acres and the lighthouse structures were transferred to the Service in 1998.

The U.S. Fish and Wildlife Service Huron National Wildlife Refuge is administered by the Service. The Service is the primary federal agency responsible for conserving, protecting, and enhancing the nation's fish and wildlife populations and their habitats. It oversees the enforcement of federal wildlife laws, management and protection of migratory bird populations, restoration of nationally significant fisheries, administration of the Endangered Species Act, and the restoration of wildlife habitat such as wetlands. The Service also manages the National Wildlife Refuge System (Refuge System).

The National Wildlife Refuge System The Refuge System protects some of the country’s most iconic ecosystems and the fish and wildlife that rely on them. The Refuge System also conserves waterways that give life to all of them — critical ecosystems along rivers, streams, wetlands, coasts, and marine areas. Refuge System lands and waters serve a purpose distinct from that of other U.S. public lands: Wildlife

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conservation drives everything on national wildlife refuges, from the purposes for which each refuge was established, to the recreational activities offered, to the resource management tools used. Each refuge is established to serve a statutory purpose that targets the conservation of native species dependent on its lands and waters. All activities on those acres are reviewed for compatibility with this statutory purpose. The National Wildlife Refuge System Improvement Act of 1997 established several important mandates aimed at making the management of national wildlife refuges more cohesive. The preparation of Comprehensive Conservation Plans is one of those mandates. The legislation directs the Secretary of the Interior to ensure that the mission of the Refuge System and purposes of the individual refuges are carried out. It also requires the Secretary to maintain the biological integrity, diversity, and environmental health of the Refuge System. The goals of the National Wildlife Refuge System are to: • Conserve a diversity of fish, wildlife, and plants and their habitats, including species that are endangered or threatened with becoming endangered. • Develop and maintain a network of habitats for migratory birds, anadromous and interjurisdictional fish, and marine mammal populations that is strategically distributed and carefully managed to meet important life history needs of these species across their ranges. • Conserve those ecosystems, plant communities, wetlands of national or international significance, and landscapes and seascapes that are unique, rare, declining, or underrepresented in existing protection efforts. • Provide and enhance opportunities to participate in compatible wildlife-dependent recreation (hunting, fishing, wildlife observation, wildlife photography, environmental education, and interpretation). • Foster understanding and instill appreciation of the diversity and interconnectedness of fish, wildlife, plants, and their habitats.

Mission The mission of the Service is: “Working with others to conserve, protect, and enhance fish, wildlife, plants, and their habitats for the continuing benefits of the American people.” The mission of the Refuge System is: “To administer a national network of lands and waters for the conservation, management, and where appropriate, restoration of fish, wildlife, and plant resources and their habitats within the United States for the benefit of present and future generations of Americans.”

Legal Mandates Huron National Wildlife Refuge was established for the following: • "… as a refuge and breeding ground for migratory birds and other wildlife …" Executive Order 7795 dated January 21, 1938, President Franklin D. Roosevelt.

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• “…for use as an inviolate sanctuary, or for any other management purpose, for migratory birds.” 16 U.S.C. 715d (Migratory Bird Conservation Act). • “…so as to provide protection of these areas…and to ensure…the preservation of their wilderness character….” (Wilderness Act of 1964, Public Law 88-577).

Presidential Executive Order 7795, January 21, 1938 re-established the refuge as Huron Migratory Bird Refuge subject to existing valid rights and uses reserved to the War Department and the Department of Commerce. “Certain of the above-described islands are primarily under the jurisdiction of the War Department and the Department of Commerce, and the reservation thereof made by this order is subject to the respective uses thereof by the said Departments in connection with the quarrying of stone to construct breakwaters and the maintenance of the Huron Island Light Station; and the use thereof by the Department of Agriculture shall not interfere with any existing or future uses or regulations of the War Department or the Department of Commerce”.

General Services Administration Transfer Letter, October 30, 1997. A letter signed by the Service Regional Director on December 7, 1998 acknowledged receipt of the transfer of the Huron Islands Light Station from the General Services Administration to the Service. The transfer was subject to reservations including (but not limited to) “the unrestricted right of the U.S. Coast Guard or its successor, to service, maintain, operate, repair and replace the aids to navigation and associated equipment” and “unrestricted right of ingress and egress for Coast Guard personnel, or its successors, to service, maintain, operate, repair and replace the aids to navigation and associated equipment”. Additionally, the General Services Administration also states, “it is the responsibility of the S to preserve the historic structures and consult with the State Historic Preservation Office on preservation and maintenance activities”.

The National Historic Preservation Act of 1966 (amended 2004) requires that historic values must be considered in weighing the benefits and costs of federal undertakings to determine what is in the public interest. Section 106 of the National Historic Preservation Act requires Federal agencies to take into account the effect of their undertakings on historic properties. Action is necessary to insure the refuge remains in compliance with the National Historic Preservation Act. Any action or benign neglect of the historic properties could lead to an Adverse Effect determination that would need to be resolved. 1.2 Relationship to other plans and compliance documents This plan will further efforts to meet goals identified in several key refuge planning and compliance documents. The following are summaries of plans and their relationship to the cultural resources on Lighthouse Island. These provide direction and guidance that help to shape the foundation for this plan. Comprehensive Conservation Plan As mandated by the National Wildlife Refuge System Improvement Act of 1997, the 2012 Great Lakes Islands Comprehensive Conservation Plan (conservation plan) for Huron National Wildlife

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Refuge articulates the management direction for the island refuge. The goals, objectives, and strategies within the conservation plan contribute to the overall mission of the Refuge System and establishes long-term continuity in refuge management. The vision as stated in the conservation plan is, “Management of Great Lakes islands refuges will reflect the mission of the Refuge System by conserving in perpetuity a rich mosaic of island habitats and enabling nesting and migrating birds and other wildlife of conservation concern in the Great Lakes to thrive here. The refuge islands will serve as a resilient source of evolving habitats and ecosystem processes even as structure and composition are altered due to climate change. With the help of our conservation partners, we will apply sound, scientific principles based on research, studies, and adaptive management strategies to: sustain the long-term health and integrity of Great Lakes habitats; expand community outreach and environmental education and interpretation programs; and motivate visitors to embrace stewardship of natural resources.” 2012 Great Lakes Islands Comprehensive Conservation Plan overall goals are identified as:

• Ecosystem Goal: Protect and maintain natural ecological communities to promote a healthy functioning ecosystem and identify future scenarios for Great Lakes islands ecosystems. • Wildlife Goal: Protect, restore and maintain a natural diversity of fish and wildlife native to the Great Lakes, with an emphasis on Service Resource Conservation Priority Species. • Habitat Goal: Perpetuate the biological diversity and integrity of native plant communities to sustain high quality habitat for migratory birds, fish, and endangered species. • People Goal: Communicate and work in partnership with communities, governments, and appropriate organizations throughout the Great Lakes and further the mission of the Refuge System. Protect the cultural resources and cultural history of the refuges to assure historical preservation and connect refuge staff, visitors, and the community to the area’s past. The conservation plan further identifies the following objectives and strategies to protect specific, known cultural and historic sites on the island refuge. Objective: Within the life of this plan, Island cultural heritage holdings will be assessed and then maintained as determined necessary. Specific strategies under this objective include: 1. Ensure archaeological and cultural resources are identified, described, and taken into consideration prior to implementing undertakings. 2. Determine need and ultimate disposition of refuge buildings – there are eight buildings/structures on Huron Island associated with the old U.S. Coast Guard station. The exterior of the lighthouse, a National Historic Landmark, has been rehabbed and

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maintained through the efforts of the Huron Island Lighthouse Preservation Association (HILPA). The remaining buildings are in various stages of decay. 3. Coordinate with HILPA to preserve and maintain structure and historical integrity of the lighthouse and associated structures selected for preservation. 4. Ensure all doors and windows on the lighthouse building, fog horn building, and barracks are either locked or covered with plywood to protect the interior of the buildings from weather damage, to prevent vandalism, for safety concerns, and to keep the general public from entering. 5. Cover all openings in the lighthouse keeper’s quarters by the end of fall 2013. 6. Within one year of completion of this plan, cut down and remove all trees and shrubs growing against or over any of the buildings and structures to maintain the exterior condition of the buildings. 7. Establish efforts with HILPA and others to develop an oral cultural history to preserve the “community memories” and maritime history of the Huron Islands.

Wilderness Stewardship Planning The conservation plan supersedes the 1978 Wilderness Stewardship Plan. Guidance for the preservation, stewardship and use of the Wilderness can be drawn from the conservation plan, 2013 Huron Wilderness Report on Wilderness Character Monitoring, Draft 2020 Wilderness Character Monitoring Summary, 2015 Habitat Management Plan, and the recently completed 2019 Minimum Requirements Analysis for considering management of the historic Huron Islands Light Station. Once approved, this plan will also provide further guidance for future wilderness stewardship with regards to the historic structures.

2013 Report on Wilderness Character Monitoring (revised in 2020) The Huron Islands Light Station has been identified as an “Other Feature of Value” of wilderness character in the 2013 Huron Wilderness Report on Wilderness Character Monitoring and draft 2020 Wilderness Character Monitoring Summary Report. The 2020 Wilderness Report states, “It is considered a crucial and prominent part of the Huron Wilderness history. The lighthouse is constructed of locally mined granite rock, while the other buildings (Assistant Keepers Quarters, Privy, Oil House, Fog Signal Building, and Barracks) are less architecturally unique and made of concrete, wood or brick materials. The locations and functions of the other buildings represent the components of the light station and the unique challenges of operating and living on a remote and isolated island. Having a sense of the fully operational light station and what life was like at the time is of historical value and a component of this wilderness’ value.” The 2020 Wilderness Report goes on to identify a measure for monitoring the condition status (Good, Fair, Poor, No Longer Eligible) of the cultural resources or more specifically the Huron Islands Light Station. Any change would be considered significant for this measure. This plan will help to ensure protection and appropriate mitigation for this wilderness feature of value.

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In addition, development and implementation of this plan will take into consideration other important wilderness characteristics. Further elaboration on these can be found in Section 4.2. Wilderness Designation.

2019 Huron Islands Light Station Minimum Requirements Analysis To further clarify what can be done to the buildings in a designated Wilderness Area, a minimum requirements analysis was completed by the Service on April 29, 2019 to comply with the Wilderness Act of 1964. Under the wilderness policy non-degradation principle, the conditions prevailing in an area at the time of wilderness designation establish a benchmark for assessing the significance of a proposed action’s beneficial and adverse impacts on wilderness character (Service Policy, 610 FW 1.18C). In the minimum requirements analysis, the Service determined action was necessary in the Wilderness and identified four possible alternatives for the future management of the Huron Islands Light Station. 1. Preserve all structures in place using only traditional (non-motorized) tools for maintenance; 2. Preserve all structures in place with the option of using motorized tools for maintenance; 3. Preserve the lighthouse, document and preserve/demolish other structures as determined using only traditional (non-motorized) tools for demolition and maintenance; and 4. Preserve the lighthouse, document and preserve/demolish other structures as determined with the option of using motorized tools for demolition and maintenance. After consideration, the Service chose Alternative Four as the preferred management strategy. The Service determined that this alternative would provide the most positive permanent benefits to Wilderness character from benchmark conditions while still allowing compatibility with the refuge’s purposes and compliance with the National Historic Preservation Act. 1.3 Plan Purpose and Vision The Cultural Resources Management Plan is a step-down management-planning tool to the 2012 Great Lakes Islands Comprehensive Conservation Plan for Huron National Wildlife Refuge. As much as possible, this plan takes information directly from the conservation plan as mentioned above and provides more specific information regarding cultural resources management on Lighthouse Island. Also, the plan works in concert with Service Cultural Resources Management Policy 614 FW 1-6 and Wilderness law and policies. The plan will serve as a component to wilderness stewardship planning and benefit wilderness character by laying out protective measures for the Huron Islands Light Station, a value to wilderness character. Implementation work for carrying out the plan must comply with the minimum requirements analysis. Any additional prohibited uses or work not covered by 2019 analysis must be analyzed

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with a new minimum requirements analysis. See Appendix A for the 2019 Huron Islands Light Station Minimum Requirements Analysis.

The Plan Vision and Intent The vision for this plan is to capture the significance and story of the cultural resources for visitors to experience while on and off Lighthouse Island. Visitors, the community and key stakeholders through collaborative work accomplished between the Service and its partners will value the island. The refuge will be a place that offers beautiful and rugged island habitats, wildlife and historic structures. It will be secure from human health and safety hazards that are remnants of the historic light station. Visitors will have opportunities to ensure they are prepared for what to expect prior to visiting the island. If not all extant structures of the historic light station remain on Lighthouse Island, for those that are removed, visitors will virtually experience those absent building(s) through accessing photos, records and other information using internet technology. While on the island, visitors seeking information about the lighthouse will be able to experience the landscape, see key pieces of the light station and on- the-ground interpretation to get a sense of what life was like for the island dwellers. It will be clear to visitors that the structures preserved in place are a valued piece of history and although rustic, they are maintained appropriately. For those who are pursuing a more primitive wilderness experience, they will be able to access parts of the island that no longer have buildings that reflect the former light station complex. The rustic buildings that do remain will remind visitors of a former time while not detracting from opportunities for self-reliant recreation, discovery and solitude. The island habitats and natural communities will be free from invasive species and continue to thrive. There will be minimal evidence of human over-use such as vandalism, accumulation of trash and human waste, and off-pathway vegetation trampling. Visitors will be inspired to protect the historic structures and practice a “leave no trace” ethos. The island’s cultural resources and natural wilderness will be a source of pride in the community. The goal for the management of historic properties is to be compatible with Wilderness and refuge management; in compliance with cultural resources laws and Service policies; and the integration of preservation work into routine refuge project planning. Management objectives and strategies identified for each component of the light station should contribute to the understanding of the significant values of the light station. In other words, management should aim to preserve the story that the lighthouse station structures help to tell. This can be broken into a few components.

• Understanding the period of time when the Lighthouse was built and the light station was in operation prior to becoming automated (1868-1972). • Getting a sense of what life was like for the keepers and their families during that time. • Appreciating that the unique function and placement of the different buildings indicate the duties and challenges the keepers experienced.

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In addition, what happened before the lighthouse construction and led up to its development is an important component of the cultural history of the island. The history before and during the lighthouse operation presents an opportunity to capture Native American and Maritime history as it relates to the island.

Chapter 2. Huron’s History: A Context for Cultural Resources 2.1 Environmental Setting For many, the thought of islands can evoke a sense of mystery, isolation, history, and wildness, or they can provide dreams of an exotic, private hideaway from a fast-paced world. Islands are a place of sanctuary and protection from the harsh elements of the open water. Islands also serve as a refuge for rare plants and animals, protected by miles of water from predators, diseases, and urban development. That is why both people and wildlife are attracted to these island havens. Great Lakes islands have unique landforms, plant and animal assemblages, and cultural history. They are living laboratories of natural selection. Great Lakes islands contain globally-rare conservation targets, such as alvar plant communities—found only in Scandinavia and the Great Lakes ecosystem—and they provide breeding habitat for wildlife species of conservation priority. Many Great Lakes islands offer important breeding and stopover sites for migratory birds, and they provide climatic buffers and other special protection for fish nurseries.

Huron National Wildlife Refuge consists of pink and gray granite outcroppings of Precambrian age. These islands are upthrusts left after the last Wisconsin Ice Age. Physiographically the islands are similar, varying chiefly in size and elevation. They portray an ecological sequence from the small, bare rock islands (on one end of the continuum) to the mostly forested McIntyre Island (on the other end), covering 77 acres and rising to about 160 feet. Lighthouse Island is 40 acres with a mix of forest and open rock areas.

Flora: Four islands the refuge are vegetated; the remaining islands are barren outcrops of granite. Vegetation surveys have documented 157 species of flora. The vegetated islands are generally characterized by shallowly rooted trees and exposed granite. Vegetation is a boreal transition type made up of balsam fir, white pine, red pine, white spruce, red maple, bigtooth aspen, and paper birch. Much of the balsam fir is decadent and contributes to a significant fuel loading on Huron Island. The understory contains cherry species, balsam fir regeneration, Canada yew, various woody shrubs, grasses, and forbs. There are a few areas on McIntyre that contain small sphagnum bogs with an occasional black spruce. Only Lighthouse Island, McIntyre, Cattle and Gull Rock Islands have substantial vegetation.

Fauna: According to evidence, with the exception of the birds on the island, the species on the island represent less than 20 percent of the species found on the adjacent mainland. Most mammals found on the islands probably arrived by crossing the ice during winter and the majority of amphibians and reptiles probably reached the islands by swimming. Amphibians are scare due to a lack of suitable breeding areas on even the larger islands. Some common species

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found in the Huron Wilderness include: Eastern Red Bat (Lasiurus borealis), Snowshoe Hares (Lepus americanus), and Herring Gulls (Larus argentatus).

2.2 Summary of Lighthouse Island’s History Much of the summary of the history of Lighthouse Island is taken mainly from three documents, The 2003 “Historic Structures Report: Huron Island Lighthouse” written by Hitch, Inc.; the 2000 manuscript “Living with the Lights” by Christine Collins; and a 2003 Northern Michigan University Masters of Arts thesis “Teaching History with the Huron Island Lighthouse” by Christine Collins. Additional information came from the Marquette Underwater Preserve’s Huron Islands Unit website and information provided by the Keweenaw Bay Indian Community.

Tribal Use Since Lighthouse Island became habitable after the end of the ice age some 8,000 to 10,000 years ago, it seems reasonable to assume that Native American groups seasonally visited the island through the millennia. The refuge is located within the historic homelands of the Keweenaw Bay Indian Community. The fish, plant and wildlife communities associated with the Islands are part of their history and identity. Like their ancestors before them, the Keweenaw Bay Indian Community is a fishing community and tribal members continue commercial and subsistence harvest in Lake Superior waters. In a recent letter to the Service the tribe states, “The Huron National Wildlife Refuge is one of the three main spawning reefs for lake trout in the mid-Lake Superior area. This reef contributes to the fishery (tribal, subsistence, recreational) in terms of population, harvest, and genetic resiliency making it a critical component of Lake Superior’s fish habitat”. In addition, their historic records refer to use of the islands for subsistence gathering of gull eggs by the Ojibwa. Tribal members continue to use the islands for resource procurement, recreation and spiritual purposes. For the tribe, the islands’ natural resources remain an essential component of their cultural resources.

Shipwrecks Boats have been traversing Lake Superior for many millennia, but it was not until the Soo Locks were opened in 1855 which enabled large commercial vessels to become more commonplace. During the 1860s, the Huron Islands were well known to those sailing the coastal waters, because they mark the turning point between Marquette and Keweenaw Bay. With increased ship traffic came shipwrecks. On May 28, 1860, the 237 foot long Steamer Arctic wrecked on the south side of Lighthouse Island. Its remains are still present today on a steep incline in 5 to 105 feet of water. On September 18, 1898, in heavy fog, the 137 foot long sailing vessel Southwest ran aground just off McIntyre Island (East Huron) Island. It is currently sitting in about 100 feet of water and is a popular location for sport divers. On April 30, 1909, in a fierce storm, the 207 foot long schooner-barge George Nestor, violently crashed into the north side of Lighthouse Island, suffering the death of seven of its crew members. Its remains are still found in 20 to 100 feet of water today.

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Government Ownership and Lighthouse Station Construction on Lighthouse Island After the Arctic shipwreck in 1860, it became clear to the U.S. Lighthouse Board that a few lighthouses were needed in this area of Lake Superior to help stabilize the growing copper and iron ore industry on the Keweenaw Peninsula. In 1866, the island was placed in federal public domain and the construction of the lighthouse began in 1868. Constructed from Lake Superior Granite mined from the south shore of Lighthouse Island itself, the lighthouse, and her nearby identical twin Granite Island Lighthouse near Marquette, Michigan, both were fully ready for the shipping season in the spring of 1869. Over the years, other buildings/structures were constructed to aid in the operation of the Huron Islands Light Station. Current extant buildings/structures include: the wooden Assistant Keepers Quarters (1934), the ferro-cement Boathouse (1913), the brick Oil House (1896), the brick Privy (1898), the concrete Dock (2008) and, on the other side of the island, the brick Fog Signal Building (1891), and the concrete block Barracks (1962). All of these structures make up the Light Station, which is referred to as such in this plan.

Lighthouse Service/Coast Guard Operation of the Light Station From 1869-1951, the light station was operated on a seasonal basis by the Lighthouse Service with the lighthouse keeper and assistant keeper and their families arriving on the island in the early Spring and leaving as the shipping season closed in the late Fall. After 1951, the station was seasonally manned by five unrelated crew members from the U.S. Coast Guard. In 1972, the light was automated, eliminating the need for a seasonal occupation of the island. The Coast Guard still periodically visits the island to check on the light and its infrastructure. The light is currently powered by a photovoltaic electrical array constructed next to the Lighthouse.

Final transfer of land to the Service The Huron National Wildlife Refuge (under its various names) was initially established around the light station in 1905 with the Wilderness designation following in 1970. In 1978, all but 11 acres of Lighthouse Island was transferred to the control of the Service. In 1991, the Coast Guard desired to transfer the remaining 11 acres to the Service and therefore entered into a lease with the Service. Finally, the remaining 11 acres and the lighthouse structures were transferred to the Service in 1998 through the Government Services Administration.

Chapter 3. Identification and Evaluation of Cultural Resources on Lighthouse Island 3.1 Previous Cultural Resources Investigations No systematic cultural resources surveys have been conducted on the island and no archaeological sites from the Precontact Period have been identified to date. Although human visitations before Lighthouse construction can be assumed, perhaps because of its rocky landscape and harsh weather conditions for much of the year, especially in the winter, it may be that no Native American or Euro-American habitation sites (beyond the light station

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complex) exist on the island. It is possible, however, that evidence of small natural resource procurement sites is present. 3.2 Inventory of Known Cultural Resources A map of the island and photographs from 2016 of the known cultural resources on Lighthouse Island are found in Appendix B. As stated above, the recorded extant cultural resources located on Lighthouse Island include: the Lighthouse (1868), the wooden Assistant Keepers Quarters (1934), the ferro-cement Boathouse (1913), the brick Oil House (1896), the brick Privy (1898), the concrete Dock (2008) and, on the other side of the island, the brick Fog Signal Building (1891), and the concrete block Barracks (1962). There are several other remnant site features associated with the light station including a small tramway, fuel storage tanks, components of infrastructure from island utilities (phone, sewer and electric), and a Pathway with concrete walkways, footbridges and steps. 3.3 National Historic Register Listed and Eligible Properties The 1868 Lighthouse was listed on the National Register of Historic Places (NRHP) on September 2, 1975 (NRHP # 75000955). The rest of the buildings/structures (except for the Dock, the Pathway and other site features) were declared eligible for listing on the National Register of Historic Places by the Service on December 7, 2004.

Chapter 4. Management Considerations 4.1 Location One of the primary challenges for managing cultural resources on Lighthouse Island is the location of the site. Getting to the island requires significant logistical planning. The refuge is unstaffed. The staff at Seney National Wildlife Refuge administer the Huron National Wildlife Refuge and typically only get to the island 1-4 times a year. Seney is a three hour vehicle drive east of Big Bay, Michigan, the nearest suitable boat launch for refuge staff. Once on the water, the boat launch in Big Bay is approximately 17 miles from the refuge. Lake Superior marine conditions can be challenging to predict and change significantly over the course of a few hours. Southwest wind directions and wave action are not suitable forecasts for docking boats in the rocky and small harbor area. Drastic temperature changes in late summer and fall can leave fog lingering on the lake causing hazardous low visibility. Once docked, the historical concrete foot Pathway is the only route for transporting materials, tools and people. The Pathway to the lighthouse complex is narrow and rocky and climbs 160 feet above the water. There are two concrete bridges and tall steep stairways. The concrete Pathway to the northwest end of the island containing the Fog Signal Building and Barracks is also narrow and rocky with those buildings being almost one mile from the Dock. 4.2 Wilderness Designation Planning and management of the cultural resources must take into consideration potential implications that project outcomes may have on wilderness character. Visitors to the Huron

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Wilderness can expect opportunities to be self-reliant. Only management that is necessary to protect wilderness character can occur on the island and must comply with the Wilderness Act and Service wilderness policies. A minimum requirements analysis may be needed to determine whether action is necessary and evaluate alternative methods to accomplish the action. The following should continue to be given consideration and are important aspects of wilderness character monitoring (see 2013 and 2020 Wilderness Character Monitoring Report documents).

• Lack of public awareness of wilderness designation - Being unprepared or uninformed about interfacing with wilderness can lead visitors to having a poor experience on the island and possibly cause degradation of wilderness values. It was once said that if something is not understood, it is not valued; if it is not valued, it is not loved; if it is not loved, it is not protected; and if it is not protected, it is lost. Public surveys have found that people who know about wilderness value it tremendously, yet almost half of Americans simply do not understand what wilderness is, how it shaped our nation, and how they benefit from it. Furthermore, Leave No Trace practices are not well known or promoted in the area. • Number of person-hours spent maintaining the Pathway - The maintenance of the Pathway is done in order to provide access to the lighthouse station facilities. The untrammeled quality is degraded if person-hours spent maintaining the pathway increases. • Introduction of invasive species - increases in non-native plants possess the ability to shift native flora composition if not carefully monitored and managed. This can often results in a loss of biodiversity, which can be detrimental to the entire wilderness ecosystem. If the percentage of wilderness containing non-native plant species increases, the natural quality will be degraded. • Presence of non-recreational structures, installations, and developments - Few developments exist in the Huron Islands Wilderness, aside from on Lighthouse Island. This wilderness measure currently accounts for Lighthouse Island developments such as the Dock, Lighthouse, and other historic buildings. Any additions to the current number of non-recreational structures will degrade the undeveloped quality of the wilderness. • Use of motor vehicles, motorized equipment, or mechanical transport - The Wilderness Act discusses three forms of mechanization that degrades wilderness character: motor vehicles (aircraft and motorboats are included here), motorized equipment, and mechanical transport. Agency policies restrict the use of motorized equipment and mechanical transport, requiring authorization for such uses when deemed necessary. Motorized boats are used to access Huron Islands Wilderness, and with the exception of Lighthouse Island, they do not technically enter the wilderness, which starts at the mean high water mark. Mechanical transport or motorized equipment have rarely been used in the Huron Islands Wilderness except when such equipment was deemed the minimal tool necessary to accomplish refuge goals and to protect the wilderness resource. Any

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change in use is a significant change since the Wilderness Act prohibits the use of motorized equipment and mechanical transport. • Changes in visitation – Crowding and loss of solitude are important impacts to the social aspects of wilderness that can occur from recreation. Although visitor experiences are complex, encountering few or no other people can greatly add to the sense of solitude and wilderness experience. Alternatively, when faced with crowding, users desiring high levels of solitude are often displaced from high-use locations and will not return for that reason. • Degree of accumulated trash and debris on Lighthouse Island - Trash and debris in a wilderness impacts a visitor’s experience because it is an obvious sign of human presence. This trash may wash up on shore or be left behind by visitors to the wilderness. An increase in the degree of accumulated trash and debris over time would represent a downward trend to the quality of solitude. • Number of agency-provided recreation facilities – Recreational facilities can decrease opportunities for self-reliant recreation in wilderness. The Huron Islands Wilderness currently has few recreational facilities within it, and therefore makes an ideal contribution to the quality of solitude or primitive and unconfined recreation. The only island that contains recreational facilities is Lighthouse Island. Any change in the number of recreational facilities will be considered a significant change to the opportunities for solitude, primitive and unconfined type of recreation. • Status of Cultural Resources - While cultural resources are human made structures, they are irreplaceable relics of a time when human history was more intertwined with nature. They reflect the primeval character of wilderness and have often been in place for hundreds of years. They are a crucial part of human history and the wilderness’ history as well. It is therefore important to monitor the degradation or disturbance to the value of these resources, which may be caused by authorized, unauthorized, or natural means. 4.3 Hazardous Materials Exposure to uncontained hazardous materials on Lighthouse Island present a risk to workers, visitors, subsistence users and the natural environment. Lead and asbestos containing materials were used in the construction of the historic facilities. Peeling, chipping and dislodged materials containing lead and asbestos are routinely found scattered on the ground. Broken glass also continues to be unearthed. Most of these materials are concentrated within the vicinity of the buildings. However, the full extent of hazardous materials is currently unknown. In 2019, Service funding was awarded to a contractor for a feasibility study for hazardous material cleanup on Lighthouse Island. The study is to be completed by fall of 2020. The purpose of the study is to identify necessary cleanup activities (and cost estimates) for known and unknown hazardous materials and possible environmental contamination. The final study

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report will serve as an informative tool for shaping project scopes of work and acquiring funding to complete said work. More specifically, an environmental assessment of buildings (internally & externally) and oil handling system on Lighthouse Island will determine the presence of lead (in paint and ground soil around building), asbestos, and possible soil contamination due to the handling of oil on the island. The assessment shall also determine if elemental liquid mercury contamination is present within the Lighthouse and other possible storage areas: the original lens in the Lighthouse was a Fresnel, which would float in liquid mercury to reduce friction in rotation. In addition, the study will confirm if residual oil is present in the 5,000 gallon storage tank on the northwest side of the island. Sampling of soil will be done around and near the Oil House and large oil tank. 4.4 Conditions Affecting Cultural Resources (Natural) There are several natural factors that can affect the condition of the Huron Islands Light Station buildings. Although efforts have been made to ensure the buildings are properly sealed and protected from these natural conditions, it requires annual upkeep. An island trip report form is used for each site visit to document any disturbances or degradation to the cultural resources. Plywood is used to cover the opening to doors and windows of the buildings as well as a hole in the roof of the barracks building. Plexiglas gives the windows of the Lighthouse tower additional protection while allowing natural light to come in. The natural lighting provides safer conditions for Service and Coast Guard personnel utilizing the circular stairway to reach the navigational light at the top of the tower.

Weathering Weathering is one of the primary natural factors that affect the condition of the structures. Weathering can cause the materials to break down over time causing the structure to be even further exposed to environmental conditions and weaken the structural integrity of the building. Weathering may/can be caused from chemical processes from acid rain, oxidation or lichens growing on stone features that can potentially weaken building materials. Weathering can also be caused by living organisms. For example, the roots of vegetation growing too close to building foundations and concrete walkways can create cracks or exacerbate existing cracks and weaken the structure. Small rodents may also burrow into cracks or woodpeckers may drill into wood features creating excavations. Furthermore, the island climate is relatively severe considering the northern latitude and relatively high elevation. The growing season ranges from 70-130 days with spring freezes common. Extreme temperatures recorded range from -50 degrees Fahrenheit to over 105 degrees Fahrenheit. Snowfall is heavy, with over 140 inches recorded annually in the region. The temperature variation can cause materials to expand and contract with the temperature, freezing and thawing cycles and result in cracks and other damage.

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Severe weather The extreme conditions that occur during storms, wind events and drought can pose higher risks to cultural resources damages on the island. Climate change models project the frequency of severe weather will increase and pose higher risk for storm damage to the cultural resources. These type of events can cause materials to become dislodged, cause wildfires from lightning strikes, and/or possibly knock features over (weak walls, trees, etc.). Commonly, roof shingles blow off the buildings on the island. These extreme events compound the effects of weathering on a structure and may go unnoticed for long periods between island inspections.

Lake Levels Although impacts may be minimal, fluctuating lake levels may reduce access to the historical dock locations and use of dock areas. Current climate change models predict lake levels to decrease. High water levels favor better island access at the current Dock while low levels cause submerged boulders to pose more of a hazard to boaters using this location. When waters are low, a shorter amount of dock space is available for boaters and only suitable for smaller watercrafts (less than 25 feet). Shoreline erosion is not considered a threat to cultural resources -- the islands are primarily composed of granite stone. 4.5 Conditions Affecting Cultural Resources (Human) Several disturbances affecting the condition of these cultural resources can be caused by humans. As previously mentioned, in recent years an island trip report form has been developed by the Service and is used for each site visit to document any disturbances or degradation to the cultural resources. The form is uploaded into ServCat (the Service database). (https://ecos.fws.gov/ADSTS/WSFederation/Issue?wa=wsignin1.0&wtrealm=https%3a%2f%2fe cos.fws.gov%2fServCat%2f&wctx=rm%3d0%26id%3dpassive%26ru%3d%252fServCat%252f&wc t=2020-02-20T13%3a04%3a34Z). The form also captures the number of campfires, trash and unsanitary practices observed on the island. For added building security, refuge management has switched to using thicker plywood (3/4 inch) and a more unique screw head on the windows and doors of the buildings that is harder to remove or destruct.

Alterations From 1983 through approximately 1992 the Coast Guard issued a lease to a private individual for the purpose of restoration and preservation of the Lighthouse, Assistant Keepers Quarters, and Boathouse. According to correspondence and photos in refuge files, this individual completed renovations without consultation with the Michigan State Historic Preservation Office. The extent and appropriateness of the renovations are not entirely clear. He provided some photographs showing repairs the to the lighthouse roof in 1990, which afterwards remained in poor condition until being replaced in 2006. The individual also had crews replace a portion of the lighthouse fascia, perhaps eliminating an original boxed-in roof gutter. The crews painted the exterior of the Assistant Keepers Quarters and perhaps replaced or repaired doors and windows. It was also noted they stripped the inside of the Assistant Keepers Quarters

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leaving it a “wreck” according to internal agency notes. Additional information on proposed projects from the individual are stored in the refuge’s historical files.

Vandalism Today, vandalism is a one of the primary human disturbances affecting the light station and remains a challenge. There is evidence of rocks having been thrown at and on top of the buildings. At one time or another, windows, doors and plywood coverings have been damaged in efforts to gain access to the interior of most of the buildings. The openings caused by damaging the plywood, windows and doors leaves the buildings exposed to variable weather conditions and access for animals and people to enter into the buildings. This results in accelerated damage to the historic fabric of the buildings, is a risk to human safety and encourages additional vandalism. Graffiti is another common form of vandalism on the island. The Boathouse is the most popular structure where graffiti covers the interior walls, but the Oil House also has graffiti damage. Lastly, just north of the Fog Signal Building someone has spray painted “Huron Island” onto the rock face overlooking Lake Superior. Theft has also been documented on the island. Theft cannot only result in the loss of historical information, but also severe damage to the structures. In one incident a large segment of the copper grounding wire for the Lighthouse was stolen, leaving the building unprotected from the risk of a lightning strike and fire. It was unclear how long this had gone unnoticed during island inspections, but seasonal weather conditions prevented staff from replacing the wire for over 6 months once detected. Illegal use of fireworks, campfires or arson also pose a serious risk for fires damaging the structures. Heavy natural fuel loadings of the boreal forest would intensify this issue.

Trash As a wilderness area, visitors can and are expected to be self-reliant. No restroom facilities or trash bins are available. Rather, Leave No Trace wilderness practices are expected. Unfortunately, a small number of visitors can leave quite the mark on even a lightly-visited area. Left behind sometimes are trash, toilet paper and human feces. These can be found on or around the historic structures and pose a safety hazard and biohazard as well as negatively impacting others experience of the cultural and natural resources. Although it is a generally accepted practice to bury human waste in catholes, Leave No Trace practices at the Huron Wilderness encourages the use of portable personal waste disposal systems, such as Wag Bags. Either way, there is little excuse for leaving trash on the island for what is packed in can easily be packed out.

Chapter 5. Public Involvement The following sections describe the current program and potential for expanding the historic preservation program by embracing additional partners. Additionally, opportunities for outside funding are explored.

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5.1 Refuge Visitor Use The island is a little well-known local popular destination spot for sightseeing, picnics, fishing, and diving around the shoreline. Public Use on the refuge is guided by the conservation plan and the overarching goal related to people is mentioned in Section 1.2. The approved compatible daytime uses on Lighthouse Island include wildlife observation, photography, environmental education and interpretation. A refuge welcome sign and regulation sign orient visitors to the island. There is no overnight camping, campfires or motorized vehicles allowed. All other refuge islands are closed to the public. Visitors can access Lighthouse Island using their own water transportation to the concrete Dock and wooden walkway on the southwest side of the island adjacent to the Boathouse. There are no existing trails other than the historical concrete Pathway that leads to the lighthouse buildings and Fog Signal Building and Barracks. There are currently no restroom facilities, drinking water or trash disposal receptacles available for visitors. Visitation at the time of wilderness designation in 1970 was estimated to be 100 visits/year. In 2018, a trail counter was installed on the island just past the Boathouse. Current annual visitation is estimated at 1,100 visits/year, an eleven fold increase. Visitation is recorded on trip reports and annually reported in the Wilderness Character Monitoring Reports. Visitors to the island most often arrive by motor powered boat. Development of this plan is in alignment with the refuge’s comprehensive conservation plan strategy that calls for management to assess and maintain as determined necessary the island cultural heritage holdings in coordination with partners. Additional specific conservation plan goals related to public use call for the refuge to monitor visitation, develop a Visitor Use Plan, and develop interpretive materials to educate the public about the islands. 5.2 Partnerships Current Partnerships Huron Island Lighthouse Preservation Association (HILPA) In the late 1990’s, several local residents from the L’Anse and Baraga area came together and formed HILPA. HILPA is a non-profit association formed to preserve the historical and architectural features of the lighthouse for future generations. In 1999, the newly formed HILPA signed a 20-year Memorandum of Understanding (memorandum) with the Service to “seek and acquire funds to restore, preserve and maintain the historic character of the Huron Islands Lighthouse”. During this time, HILPA completed a Historic Structures Report (2003) and replaced the roof on the Lighthouse (2006). Over the last decade of the memorandum, the organization suffered from refuge staff turnover and lack of volunteer engagement. However, in the last year, HILPA has reengaged with some new members and elected a new board. A new memorandum between the Service and HILPA was recently signed in 2020 for a period of five years. Routine extensions to the memorandum are anticipated after the initial five years. The Service will engage with HILPA for plans related to the Lighthouse preservation within the Cultural Resources Management Plan.

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Keweenaw Bay Indian Community In 2018, Keweenaw Bay Indian Community requested a government-to-government consultation with the Service regarding the condition of Lighthouse Island and the buildings. Since 2018, the tribe has provided transportation assistance, historical background information, management recommendations, advocacy, as well as natural resource expertise to the Service. The exciting newly established partnership expands capabilities and opportunities for achieving the goals of the refuge. The Service anticipates actively engaging with the tribe for implementing the plan and additional natural resource management activities.

HistoriCorps HistoriCorps is a national, non-profit organization dedicated to saving our nation’s most vulnerable historic places. The Service is currently finalizing a national Cooperative Agreement with them to work on Service historic properties. They are uniquely qualified to spearhead preservation efforts and can supply the qualified and energetic people to do the work on Lighthouse Island. Their work is designed to be a unique educational experience in historic preservation. The training arm of HistoriCorps, the HistoriCorps Institute, teams volunteer/ students from all walks of life with instructors to do the preservation work needed. HistoriCorps is responsible for organizing and selecting the students/instructors, setting up the logistics of getting the crew to/from the island, and feeding/housing them during the time of the project. Not a small endeavor for potential immersion field projects on a rocky, remote island in Lake Superior.

Michigan State Historic Preservation Office Michigan State Historic Preservation Office is a state governmental agency authorized by the United States federal government in 1966 under Section 101 of the National Historic Preservation Act for the purposes of surveying and recognizing historic properties, reviewing nominations for properties to be included in the National Register of Historic Places, reviewing federal undertakings for the effects on historic properties as well as generally supporting the historic preservation efforts of federal agencies, state and local governments, and the private sector. The Michigan State Historic Preservation Office has been consulted over the years on Service undertakings taking place on Lighthouse Island. In 2018, their architect, Bryan Lijewski, met with the Refuge Manager, Assistant Manager, and Service Regional Historic Preservation Officer, about the Huron Islands Light Station. He indicated that the State Historic Preservation Office stands ready to advise and assist the Service in the management of the cultural resources on Lighthouse Island.

Potential New Partnership Opportunities The following entities are identified as stakeholders, although no current formal partnership exists. This is not an exhaustive or complete list. Rather, the following present opportunities for the Service to consider pursuing. The Service would welcome additional stakeholders/partners not identified in this plan.

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U.S. Coast Guard The Coast Guard currently maintains the navigational light at the top of the Lighthouse and the padlock to the Lighthouse entrance. In recent years, official communication contacts and pathways have not been clearly established or maintained and so there has been minimal but positive communication between Service and Coast Guard staff. This is primarily due in part from staff turnover as well as lack of a pre-identified need or opportunity. The Service should further explore opportunities for collaboration efforts.

Marquette Maritime Museum The Marquette Maritime Museum’s mission is to preserve, protect and promote the maritime history of Marquette, Lake Superior and the Great Lakes and to remember the sacrifices of our submarine veterans. The museum is said to house the original Fresnel lens from the Huron Island Lighthouse. Opportunities should be explored for how the museum and Service could collaborate together on future projects.

Huron Mountain Club The Huron Mountain Club is the closest land owner to the refuge and possible source of many visitors to Lighthouse Island. A private club, they own a large tract of forested land within the Huron Mountains region. Their land contains old-growth forests, and because of the large size and pristine nature of the property, scientists sponsored by the independently-operated Huron Mountain Wildlife Foundation live and do research on the club’s land. Refuge staff have frequently encountered refuge visitors who identify as family and friends of club members. The Service should make efforts to engage the club’s General Manager and explore if collaboration opportunities exist. 5.3 Opportunity for Participation by Partners and Stakeholders Opportunities for individuals to participate in the historic preservation program or become a partner engaged in this program can take many forms. This section outlines only a few.

Technical Expertise in Planning Documents Environmental, architectural, engineering and historical structure reports and condition assessments need to be completed to ensure preservation, maintenance and demolition/ removal requirements are met. This work requires trained professionals with this expertise. Assistance in developing interpretive projects listed in Section 5.4. Interpretation Projects is also needed.

Financial Assistance It is expected that the level and availability of funding needed to complete priority projects will vary from year to year. The Service will establish the priority list and plans for historic preservation projects. All projects will require Service approval before implementation. Direct funding for projects from the Service will be managed by the Service. Partners may be interested in pursuing grants and would manage any funding awarded to them. This plan and

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comprehensive condition assessments will provide the baseline information for planning projects and calculating costs. Partners may seek funding from many types of groups, such as private individuals, corporations and foundations interested in community development, wilderness enhancement, historic preservation and lighthouse history.

In-Kind Contributions Contributions of restoration materials and supplies is another avenue for expanding the network of partners. Paint, lumber, masonry supplies, scaffolding, generators, and tools are a few items needed for preservation and maintenance. Transportation of people and items to the island is another source of an in-kind contribution.

Volunteer Labor-force Keeping up with historic building preservation and island maintenance is labor-intensive work and refuge staffing is at a minimum. Volunteers could assist with island monitoring for vandalism, annual Pathway clearing, trash removal and minor building maintenance and repair. Major projects on the buildings would be done with Service paid staff, HistoriCorps or by a contractor. Limited opportunities exist for volunteering under a Service volunteer agreement. The Service highly recommends volunteer labor is done under the umbrella of an organized group, such as a partner. 5.4 Interpretation Projects Proposed Projects Currently, there are two signs that welcome and orient visitors to the island – a refuge entrance sign and a directional sign regarding use of the refuge. There are no interpretive panels or kiosks on the island. The current refuge website offers minimal information for visitors. The website contains little information on the island’s history and cultural resources. Interpretive Information about the cultural resources on Lighthouse Island can be presented in a variety of formats. At a minimum, a webpage can be developed on the refuge website dedicated to cultural resources and interpretation of the light station. The page can contain a summary of the rich history, photos and GPS coordinates of the buildings, site and building plans, and videos. Links to reports, studies, and theses can serve as resources for people wanting to dive deeper into the island history and protection of cultural resources. The website can be a platform to share personal stories from family members of former lighthouse keepers who experienced life on the island prior to automation of the navigational light. Lastly, the page will include information aimed to properly prepare people for what to expect when visiting the island and how they can help protect the light station buildings and wilderness. In addition to providing information online, simple signs on the island can identify the buildings’ name, age, and function as it related to the light station. Providing information on the internet and simple signs is a proposed minimum for the program. All additional future interpretive projects are subject to further consultation with partners and wilderness review. For any proposed future recreational or interpretive developments, only those that are necessary to

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protect wilderness character can occur on the island and must comply with Wilderness Act and the Service wilderness policies. A minimum requirements analysis may be needed to determine whether action is necessary and evaluate alternative methods to accomplish the action.

Future Projects to Explore It is recommend that the Service should work with partners and stakeholders to explore offsite interpretive opportunities. These can range from signs, kiosks, exhibits and/or brochures available at strategic locations (boat launches, cultural centers, museums, visitor centers, etc.) around the Upper Peninsula of Michigan to target audiences potentially open to learn about or even visit the Huron Islands Light Station. Additionally, Service and partners may want to consider utilizing a computer application to offer an enhanced experience for visitors wanting a guided audio tour or virtual simulation of seeing the removed buildings onsite using a cellular smartphone. This type of technology is currently offered at the Seney National Wildlife Refuge. 5.5 Scoping Efforts Informal information gathering began in 2015 with new Service personnel and later in 2016 with HILPA board members meeting to review the status and interest in pursuing future collaboration efforts on Lighthouse Island. Since that time, Service staff have traveled to the L’Anse/Baraga/Big Bay region on numerous occasions and engaged a variety of people about their perspective on the refuge. Additional insights about the local perception on the condition of the island structures came from tribal consultation initiated by Keweenaw Bay Indian Community in April of 2018. Since that time, refuge management has routinely communicated with the tribe about the island conditions and future planning. To help shape planning, and provide opportunities for everyone to comment, an initial public scoping effort began on December 2, 2019 for a 30 day comment period. A press release and information document was developed for the public and provided on the refuge website, local media outlets and to interested parties. The local newspaper, The Mining Journal, published a story on Monday December 16th, 2019 regarding the effort. Local TV 3 WJMN covered the story on December 18th, 2019. Information was also posted on the Seney National Wildlife Refuge Facebook page twice where it had 83 likes and 12 shares on December 4, 2019 and 82 likes and 8 shares on December 18, 2019. Upon their request, Keweenaw Bay Indian Community was granted an additional 30 days to comment. Eight entities provided comments to Refuge Manager, Sara Siekierski. As would be expected, there were a variety of recommendations for how to best manage Lighthouse Island generally and the Huron Island Light Station in particular. They ranged from suggestions to preserve all buildings, to only keeping a select few. Overall, there was a slight favor to preserve only a select few.

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Chapter 6. Intended Disposition of Cultural Resources 6.1 Intended Disposition and its Relationship to the Huron Islands Light Station, Refuge Mission and Wilderness Character In line with the refuge’s goals and objectives laid out in the conservation plan and Alternative Four within the 2019 wilderness analysis, a combination of disposition strategies for preservation of the historical significance of the Huron Islands Light Station is the recommended best approach. The historical significance of the station is multifaceted and includes understanding the period of time from when the Lighthouse was constructed and the light station was in operation prior to becoming automated (1868-1972) and getting a sense of what life was like for the keepers and their families during that time. The function of the different buildings and placement of the buildings indicate the duties and challenges they experienced as they operated a strategically important facility on an isolated island in Lake Superior. The opportunity to appreciate those duties and challenges in a wilderness setting is a unique educational experience for any modern visitor to the island. Following the 2019 wilderness analysis, it is the decision by the Service that the Lighthouse will be preserved in perpetuity. It is the oldest and most substantial building on the island, listed on the National Register of Historic Places and the Coast Guard needs access to its interior for navigational purposes. Internal deliberations to preserve or demolish some of the island’s other buildings/features were guided by three factors: the significance and proximity of the building/feature relative to the Lighthouse, the historic function and current condition of the building/feature, and the Service’s desire to maintain or further enhance wilderness character, especially on the northwest side of the island. As such, the Service has decided that all the historic properties clustered around the Lighthouse (Assistant Keepers Quarters, Privy and Oil House) will be preserved. They provide a strong “interpretational affinity” to each other and allow the public to truly understand the feeling of the operation of a light station on Lake Superior from 1868-1972. The interplay of the buildings in close proximity can transport the visitor back to the time when the light station was in operation and staffed. The Dock and Pathway, while not historic properties, allow the visitor access to the cluster of lighthouse buildings and to the other side of the island. They will also be preserved. The three other historic properties (Boathouse, Barracks and Fog Signal Building) and the various other site features (a small tramway, fuel storage tanks, and components of infrastructure from island utilities), will be demolished and removed from the island but for different reasons. The Boathouse is in poor shape, one wall is cracked and leaning to the point of possibly nearing collapse across the walkway, and is constantly subjected to severe vandalism. It is becoming a growing danger to the public. It is not savable in its current form. Appendix C has photographs of the Boathouse since 2016.

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The Barracks, the Fog Signal Building, and some other prominent site features, like the tramway and fuel tanks, are all clustered together across the island, over a half a mile from the lighthouse complex. While technically part of the light station, these buildings and features have a weak interpretational affinity with and cannot be seen from the Lighthouse, even from the lantern room. Additionally, completely removing these buildings and features will greatly enhance the undeveloped, naturalness and solitude wilderness characters of that side of the island and allow those visitors who do not want to interact with cultural resources a chance to clearly imagine the island as it was for the many millennia before construction of the Lighthouse in 1868. 6.2 Cultural Resources to be Preserved in Place Lighthouse (1868) The Lighthouse is a two story rectangular building with a four story square light tower. It is built from pinkish-grey Lake Superior Granite with sandstone corners, window trim and lintels. The second story is not present over the south portion of the building. Four dormers were added on in the 1940s. All its windows and doors are currently boarded up. The Lighthouse will be preserved to the 2017 Secretary of the Interior’s Standards for the Treatment of Historic Properties (SOI Standards) as outlined in Section 7.2: Preservation Treatment for Historic Properties to protect this national treasure, wilderness feature, and to ensure compliance with the 1997 General Service Administration land transfer letter that describes the rights granted to Coast Guard. The Lighthouse is an indispensable component of the light station for which several of the other buildings were constructed around. In addition, the Lighthouse is in good condition, made from locally mined granite rock, and considered aesthetically pleasing as it appears to rise up from the rocky outcrops much like a geological feature. When one sees the date on the building and detailed stone work, it is truly impressive to think of the labor techniques used to construct the tower. Standing next to the Lighthouse high above the water overlooking the island it is easy to imagine the difficulty of hauling everyday supplies from the Dock to the Lighthouse as the lighthouse keepers once did, let alone constructing buildings and pathways throughout the island.

Assistant Keepers Quarters (1934) The Assistant Keepers Quarters is a one story rectangular wooden building. The southern portion was added in 1949. All its windows and doors are currently boarded up. The Assistant Keepers Quarters is in close proximity to the Lighthouse and by housing the Assistant Light Keeper and his family it functioned as a significant part of operating the light station. The building is in good condition and will be preserved to SOI Standards. It does not significantly add or reduce the footprint of existing human developments within the Wilderness. Preserving this building not only helps tell the story of Huron Islands Light Station,

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but may also be beneficial to use as a storage building for project materials, supplies, scaffolding, and tools.

Privy (1898) The Privy is made of red brick and has room for one individual at a time. While its original wooden door is currently missing, the privy doorway, window and back access panel is currently boarded up with plywood to prevent further damage to this cultural resource. The outdoor Privy is in close proximity to the Lighthouse and Assistant Keepers Quarters and gives a sense to visitors the difficulty of life on the island without running water and indoor plumbing. This building is in fair condition, posing little hazard to visitors and will be preserved to SOI Standards. It does not significantly add or reduce the footprint of existing human developments within wilderness.

Oil House (1896) The single story Oil House is made of red brick and has a functional metal door and a metal vent on the roof. The Oil House is within close proximity to the Lighthouse and gives a sense to visitors the technology needed to light the lantern at a time without electricity. This building is in good condition, posing little hazard to visitors and will be preserved to SOI Standards. It does not significantly add or reduce the footprint of existing human developments within wilderness.

Dock (2008) and Pathway The Dock and Pathway are both made of concrete. The Pathway includes walkways, stairs and two concrete bridges. The Dock is a modern, stable structure in good condition that allows visitors the only safe access to Lighthouse Island. It will be preserved to Service facilities maintenance standards. The Pathway, including the stairs, bridges and walkways provide access to the lighthouse structures and the other side of the island. It is in good condition. This feature is critical for both workers and visitors alike. Funneling traffic along a single, well-marked pathway also helps focus trash and vandalism issues and to protect the island’s fragile vegetative communities from trampling as well as focuses the introduction of invasive plants to a defined area for staff and volunteer monitoring. It will be preserved to Service facilities maintenance standards. 6.3 Cultural Resources to be Demolished and Removed Boathouse (1913) The rectangular Boathouse is made of ferro-cement and was enlarged in 1951. It is completely open to the elements. The Boathouse is in poor condition showing extensive cracking in the walls, roof and foundation. The overhang is starting to separate from the rest of the building. Unfortunately, people have to walk by it to access the island. The building has deteriorated to the point where major repairs are needed and it poses a safety hazard to visitors. This building will be

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demolished and removed. The Boathouse and Dock symbolize one of the two locations where supplies and material had to be transported to the light station and where boats were stored on the island. Therefore, the significance of the boathouse will be preserved in an alternative format within a future Memorandum of Agreement (formal agreement) with consulting parties as outlined in Section 8.1: Demolition and Removal of Historic Properties below.

Coast Guard Barracks (1962) The rectangular Barracks is made from concrete block. The roof has a large hole, which has been mostly patched with plywood, but is failing. The shingles are badly deteriorated. The Barracks on the northwest end of the island is the youngest of all the buildings. It was abandoned in 1970 after less than 10 years of occupation. It is over a half mile away and cannot be seen from the lighthouse complex. This building is in poor condition and considered an eye- sore to most all who have commented to the staff. Demolishing and removing this building will reduce the building footprint on the island and, along with the removal of the Fog Signal Building and other site features, will enhance the naturalness and solitude wilderness characters of Lighthouse Island. The significance of the Barracks will be preserved in an alternative format within a future agreemnt with consulting parties.

Fog Signal Building (1891) The rectangular Fog Signal Building is made of red brick. It was expanded in 1931. All its doors and windows are currently boarded up. The Fog Signal Building is located on the northwest end of the island over a half mile away and cannot be seen from the lighthouse complex. The building is in good condition. However, demolishing and removing this building will reduce the building footprint on the island and, along with the removal of the Barracks and other site features, will enhance the naturalness and solitude wilderness characters of Lighthouse Island. The significance of the Fog Signal Building will be preserved in an alternative format within a future formal agreement with consulting parties.

Other Site Features The other installations that are included on Lighthouse Island are a portion of a tram railway, fuel storage tanks, septic pump system, flagpole, radio tower, in-ground concrete vaults, and utility poles and other electrical infrastructure. They are currently not being maintained. These site features are scattered around the island. They are in fair to poor condition, a safety hazard, and not compatible with wilderness character. They have limited ability to convey significant knowledge about the operation of the light station. Removing these features will reduce their footprint on the island and, along with the removal of the Barracks and Fog Signal Building, will enhance the naturalness and solitude wilderness characters of Lighthouse Island. Any significance of the site features will be preserved in an alternative format defined by the Service and the Partners.

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Chapter 7. Treatment of Cultural Resources Preserved in Place For those historic properties (Lighthouse, Assistant Keepers Quarters, Privy and Oil House) and non-historic properties (Dock and Pathway) being preserved in place, the Service will conduct condition assessments on each one and follow the appropriate treatment standards for pertinent historic property status.

7.1 Condition Assessments In cooperation with the Services’ Regional Facilities Management Coordinator, a detailed condition assessment will be made for every cultural resource to be preserved in place. Any vegetation or debris would be removed from in and around the cultural resources. A condition assessment will consist of an analysis of the current state of the cultural resources through descriptions and photographs with an emphasis on any character-defining features, an itemized listing of projects to be done to keep/return the cultural resources up to the appropriate treatment standards depending upon their historic property status, and the estimated costs of these projects both individually and cumulatively. The listing of these projects and estimated costs will feed directly into the Service 5 year rolling maintenance plan for Lighthouse Island outlined in Section 9.5: Five Year Rolling Maintenance Plan. 7.2 Preservation Treatment for Historic Properties The Lighthouse, Assistant Keepers Quarters, Privy and Oil House are all historic properties. As such, they require treatment standards as outlined in 2017 by the Secretary of the Interior. For all three historic properties the Service has selected the “Preservation” treatment standards. This is stated as such: “Preservation is defined as the act or process of applying measures necessary to sustain the existing form, integrity, and materials of an historic property. Work, including preliminary measures to protect and stabilize the property, generally focuses upon the ongoing maintenance and repair of historic materials and features rather than extensive replacement and new construction. New exterior additions are not within the scope of this treatment; however, the limited and sensitive upgrading of mechanical, electrical, and plumbing systems and other code-required work to make properties functional is appropriate within a preservation project.” The Preservation Standards further states: “The Standards will be applied taking into consideration the economic and technical feasibility of each project. 1. A property will be used as it was historically, or be given a new use that maximizes the retention of distinctive materials, features, spaces and spatial relationships.

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Where a treatment and use have not been identified, a property will be protected and, if necessary, stabilized until additional work may be undertaken. 2. The historic character of a property will be retained and preserved. The replacement of intact or repairable historic materials or alteration of features, spaces and spatial relationships that characterize a property will be avoided. 3. Each property will be recognized as a physical record of its time, place and use. Work needed to stabilize, consolidate and conserve existing historic materials and features will be physically and visually compatible, identifiable upon close inspection and properly documented for future research. 4. Changes to a property that have acquired historic significance in their own right will be retained and preserved. 5. Distinctive materials, features, finishes and construction techniques or examples of craftsmanship that characterize a property will be preserved. 6. The existing condition of historic features will be evaluated to determine the appropriate level of intervention needed. Where the severity of deterioration requires repair or limited replacement of a distinctive feature, the new material will match the old in composition, design, color and texture. 7. Chemical or physical treatments, if appropriate, will be undertaken using the gentlest means possible. Treatments that cause damage to historic materials will not be used. 8. Archeological resources will be protected and preserved in place. If such resources must be disturbed, mitigation measures will be undertaken.“ 7.3 Preservation Treatment for Cultural Resources not Historic Properties The Dock and Pathway are not historic properties but they are cultural resources to be preserved by the Service. Preservation of these cultural resources will follow regular Service facilities maintenance protocols, procedures and treatments.

Chapter 8. Treatment of Cultural Resources Demolished and Removed For those historic properties (Boathouse, Fog Signal Building and Barracks) and the non-historic properties (Other Site Features) to be demolished and removed from Lighthouse Island, the Service will mitigate for loss of the cultural resources in such a way that visitors can still know their location and function and get a fuller sense of what life was like on the island from 1868- 1972. Although the cultural resources will be physically gone, the significance and value of that cultural resource will be preserved in an alternative format. This action will improve the undeveloped, naturalness, and solitude character of the wilderness, while maintaining the remaining buildings/structures of the Huron Islands Light Station as a wilderness feature of value.

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8.1 Demolition and Removal of Historic Properties The Boathouse, Fog Signal Building and Barracks are all historic properties. As such, their demolition and removal is considered an Adverse Effect under Section 106 of the National Historic Preservation Act. An Adverse Effect to an historic property is resolved through a formal agreement between the federal agency and any consulting parties including, possibly, the Advisory Council on Historic Preservation (Advisory Council). In this instance, a formal agreement would likely be negotiated and signed between the Service, State Historic Preservation Office, HILPA, Keweenaw Bay Indian Community, and, again, possibly the Advisory Council. Other signatories or interested parties may be identified during the formal agreement consultation process. The resolution of an Adverse Effect on a historic property to be demolished often includes recordation to standards agreed to by the consulting parties (e.g. the Historic American Buildings Survey (HABS)/Historic American Engineering Record (HAER) standards) and possibly other measures. The Service is solely responsible to see that the stipulations in the formal agreement are fully carried out and that Section 106 compliance is completed.

8.2 Demolition and Removal of Cultural Resources not Historic Properties The other site features (tram railway, fuel storage tanks, septic pump system, flagpole, radio tower, in-ground concrete vaults, and utility poles and other electrical infrastructure) on Lighthouse Island are not historic properties but they are cultural resources. As such, before demolition and removal they will be recorded through photographs, maps, measurements and descriptions. Demolition and removal of these cultural resources will follow regular Service facilities demolition and removal policies, protocols and procedures.

Chapter 9. Envisioning Implementing the Plan The following sections discuss the Cultural Resources Management Plan review schedule, staffing requirements, and preservation project goals. Staffing requirements and preservation goals will be discussed. Actual project work will be contingent on availability of resources and changing site conditions. 9.1 Plan Review and Revision Schedule This plan will be in effect for a period of 15-20 years, or in the event it no longer reflects the site conditions or management goals of the conservation plan. 9.2 Staff Requirements Huron National Wildilfe Refuge is an unstaffed refuge. Staff at Seney National Wildlife Refuge administer this refuge. All refuge staff are responsible for completing one island trip report for each trip made to the islands. The number of visits made in a year ranges from one to four trips, with two trips being the average in the last five years. Trip reports are uploaded and saved on the Service’s ServCat database. These reports are used to assist with monitoring and reporting requirements for the wilderness character monitoring, Habitat Management Plan and Refuge

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Annual Performance Plan. In addition, typically two or more refuge staff positions are certified Service boat operators and are able to provide Service boat transportation to the island. The following permanent positions are identified for the Seney refuge organizational workforce chart. Contributions and efforts targeted for Huron National Wildlife Refuge vary annually and are dependent on other refuge annual priorities.

• Refuge Manager. This position serves as the point of contact for all activities on the refuge, including those of partners and contractors and is the responsible party for adherence to the National Historic Preservation Act and promulgating this plan. Ultimately, the Refuge Manager is responsible for keeping track of the condition of the historic properties and ensuring completion of appropriate compliance documents. • Assistant Refuge Manager. This position provides management support and expertise on formal agreements, contracts and oversight for maintenance projects. • Visitor Services Manager. This position provides expertise and support related to visitor use and planning. This includes managing content for the refuge website, signage and press releases. This position serves as lead for monitoring and reporting visitation (coordinates placement of people counters) for RAPP and development of visitor use plans. • Refuge Biologist. This position provides expertise and support related to wildlife and wildland habitats. This includes conducting island inspections, wildlife and habitat surveys, and providing recommendations and analysis of projects that have potential to impact wildlife and wilderness values. • Fire Management Specialist. This position provides expertise and supported related to wildlife habitat, planning for and administrating any potential prescribed burns, and coordination for wildfire response. Lead effort to maintain “fire wise” habitat around buildings, especially wooden Assistant Keepers Quarters. • Refuge Maintenance Worker. The refuge typically has two people serving in this position. These individuals assist in minor maintenance and repair of refuge facilities and replacement of regulatory signs. • Administrative Technician. This position provides support and expertise related to budgeting, contracting and purchases. • Seasonal Park Ranger. This seasonal position provides expertise and support related to the volunteer program operations at Seney National Wildlife Refuge, Leave no Trace Wilderness practices and signage needs for orienting visitors to the Huron National Wildlife Refuge. In addition, the following regional staff have a key role for implementing this plan.

• Regional Historic Preservation Officer. This position serves the Interior Region 3, Great Lakes Region for the Service. The role of the Historic Preservation Officer is to help the refuge develop historic preservation plans, monitor work, coordinate with volunteer or

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contractor groups, plan training sessions for the refuge staff, determine if proposed projects will affect historic properties, and coordinates with State Historic Preservation Office. • Historic Architect/Engineer. This position will be necessary on a case-by-case basis as historic preservation/restoration projects are accomplished. The expertise of a historic structural engineer or architect may be filled under contract. • Regional Facilities Management Coordinator. This position conducts Comprehensive Condition Assessments of facilities throughout the region. In addition, they may help to coordinate regional maintenance action teams to address maintenance and preservation projects. • Zone Refuge Officer. This position is currently based at Detroit International Wildlife Refuge. As feasible, this position will provide annual occasional law enforcement presence at the refuge to help control vandalism/litter issues or other more serious issues and provide a public safety presence. • Regional Wilderness Coordinator. This position provides support and guidance regarding wilderness policies, reporting and assistance with minimum requirements analysis. Additional minimum requirements analyses will be needed to implement components of this plan (i.e. removal of buildings or interpretive signage considerations). 9.3 Preservation Project Goals The goal for the management of historic properties is to be compatible with Wilderness and refuge management; in compliance with cultural resources laws and Service policies; and integration of work into routine refuge project planning. This goal will help further efforts to realize the overall plan vision. Preservation projects will be completed through collaboration with key partners and consultation with the Michigan State Historic Preservation Office. Formal agreements will be developed to lay out roles and responsibilities for each entity. Management objectives and strategies identified for each component of the light station will contribute to the understanding of the significant values of the station. Management objectives and strategies also address pre-lighthouse construction and tribal history on the island. Preservation projects are contingent on many issues, including the cost of working in a remote setting, transportation of construction materials, limited available labor source, and lack of persons trained in the conservation of historic structures on islands. Costs could be ameliorated by partner financial support, donated supplies, and grant opportunities. 9.4 Summary Within 5-10 Years All work proposed is contingent on availability of resources (staff, funding, partners, etc.) and other work priorities within the Seney National Wildlife Refuge Complex.

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• Complete the feasibility study for cleanup of hazardous materials on the island. • Abate any immediate threat from the hazardous materials identified in the feasibility study. • Continue to clear woody vegetation and debris from in and around building foundations, other site features, the Pathway, and the Dock as needed. • Enter into formal agreements with the Partners and Stakeholders, as needed, to implement the Cultural Resources Management Plan. • Continue to stabilize, mothball, and protect all cultural resources as the plan is being implemented. • Complete wilderness minimum requirements analysis and demolish and remove the Boathouse as a stand-alone, urgent undertaking with the resolution of the adverse effect through a formal agreement and protect access onto the island. • Complete condition assessments of all the buildings/structures to be preserved in place. • Coordinate with Partners and Stakeholders to complete small, urgent preservation projects identified in the condition assessments. • Service will seek agency funding and the Partners will seek outside funding for large, long-term preservation and hazardous materials abatement projects. • Complete wilderness minimum requirements analysis and sign/begin the implementation of an agreement to resolve the adverse effects to the Barracks and Fog Signal Building historic properties slated for demolition and removal. • Compile documentation (photos, drawings, audio description/narrative tour, etc.) of the historic properties and non-historic properties slated for demolition and removal for inclusion of “virtual” tour for visitors. • Develop a visitor use or interpretive plan.

Within 10-15 Years All work proposed is contingent on availability of resources (staff, funding, partners, etc.) and other work priorities within the Seney National Wildlife Refuge Complex.

• Continue coordination with Partners and Stakeholders for completing work on additional preservation projects identified in the condition assessments based upon a five year rolling maintenance plan. • Complete minimum requirements analysis for demolition and removal of the other site features. • Demolish and remove Barracks, Fog Signal Building and other site features dependent on formal agreement stipulations, funding and weather/logistics limitations. • Complete any remaining hazardous materials abatement projects. • Develop and implement a “virtual” tour for visitors which would include those historic properties and non-historic properties slated for demolition and removal. • Begin to implement signage or other interpretive recommendations from visitor use or interpretive plan.

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9.5 Five year rolling maintenance plan Comprehensive Condition Assessment Service Regional Facilities Management Coordinator will conduct a Comprehensive Condition Assessment of the cultural resources on Lighthouse Island every 5 years to evaluate the extant buildings/structures. This information will supplement the historic preservation condition assessments outlined in the Cultural Resources Management Plan and will form the basis for developing a 5 year rolling maintenance plan.

Deferred Maintenance Work Orders Annually, refuge management will review the refuge’s deferred maintenance work orders and coordinate with Regional Facilities Manager and Regional Historic Preservation Officer (RHPO) to update the 5 year rolling maintenance plan as needed.

Annual Maintenance and Repair of Architectural Historic Properties The site should be inspected at a minimum annually to ensure conditions are safe and buildings are secure. The Pathway railings, bridges, stairs and Dock should appear functional for use. The buildings should have no opening for animals, humans, or water/wind to enter the inside. Coverings should remain in place over all entryways. Lightning protection should be in place and properly grounded. The building foundations and roofs should remain clear of trees and other vegetation. Vandalism and trash should be cleaned up as much as possible. Maintenance and repair may damage the character and integrity of architectural historic properties if proper procedures are not followed. Therefore, in order not to alter the character or integrity of the historic property, the SOI Preservation Standards should be followed. In addition, Service Section 106 review procedures should also be followed: 1. Service Project Manager will submit proposed project plan to RHPO for review. 2. RHPO will determine if project can be accomplished in accordance withplan or any signed MOA. a. If NO, follow additional Section 106 compliance procedures. b. If YES, the project may proceed. 3. RHPO and Service Project Manager will ensure that Service maintenance personnel are familiar with proper maintenance and repair procedures or will inform Service Contracting Officer or Partner of special requirements for contracts related to maintenance and repair of historic properties. 4. Service Project Manager will familiarize any outside subcontractor with proper maintenance and repair procedures. 5. RHPO and/or the Service Project Manager will monitor maintenance or repair activities to ensure the protection of the historic properties.

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References Cited Presidential Executive Order 357-D, October 10, 1905 Presidential Executive Order 7795, January 21, 1938 Presidential Proclamation 2416, July 25, 1940 The Wilderness Act of 1964 The National Historic National Historic Preservation Act of 1966 (amended 2004) Huron Islands Wilderness Area, October 23, 1970 (Public Law 91-504) National Wildlife Refuge System Improvement Act of 1997 General Services Administration Transfer Letter, October 30, 1997 2000 Manuscript “Living with the Lights” by Christine Collins 2003 Northern Michigan University Masters of Arts thesis “Teaching History with the Huron Island Lighthouse” by Christine Collins 2003 Historic Structures Report, Huron Island Lighthouse 2012 Great Lakes Islands Comprehensive Conservation Plan 2013 Huron Wilderness Report on Wilderness Character Monitoring 2015 Island Habitat Management Plan, Seney National Wildlife Refuge 2017 Secretary of the Interior’s Standards for the Treatment of Historic Properties 2019 Huron Island Light Station Minimum Requirements Analysis Decision Guide Workbook 2020 Draft Huron Wilderness Character Monitoring Summary FWS Policy 610 FW 1.18C (Wilderness non-degradation principal) FWS Policy 614 FW 1-6 (Cultural Resources Management)

ServCat https://ecos.fws.gov/

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Appendix A Minimum Requirements Analysis - 2019 The Minimum Requirements Analysis is completed by filling out a Minimum Requirements Decision Guide workbook to determine if administrative action is necessary in wilderness and what the minimum activity that should occur to address the need for necessary action. A Minimum Requirements Analysis was completed in 2019 to evaluate if management of historic structures was required in Huron Wilderness at Lighthouse Island and what the minimum tool necessary to achieve management concerns. See the full analysis at https://ecos.fws.gov/ServCat/DownloadFile/164016.

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Appendix B Maps and Photos of the Cultural Resources of Lighthouse Island in 2016 Photos of known cultural resources taken in 2016. Images include: • Location map of Huron National Wildlife Refuge • Site map showing locations of buildings at Lighthouse Island. • Photos of exterior and interior of the Boathouse. • Aerial Photo and exterior photos of the Oil house building. • Aerial Photo and interior and exterior photos of the Lighthouse. • Aerial Photo and interior and exterior photos of the Privy. • Aerial Photo and interior and exterior photos of the Assistant Keepers Quarters. • Aerial Photo and exterior photos of the fog signal building. • Aerial Photo and exterior photos of other site features. • Aerial Photo and interior and exterior photos of the barracks.

See separate attached document.

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Appendix C Additional Photos of the Cultural Resources of Lighthouse Island Photos of known cultural resources taken from 2012 through 2019. Images include: • Exterior photos of the Lighthouse. • Exterior photos of the Oil house. • Exterior photos of the Privy. • Exterior photos of the Assistant Keepers Quarters. • Exterior photos of the Fog Signal building. • Exterior photos of Other Site Features. • Exterior photos of the Boathouse.

See separate attached document.

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