7-PEPC_56527-_Categorical_Exclusion_signed_12.28.2017.pdf

U.S. Department of the Interior

National Park Service

Categorical Exclusion Form

Jewel Cave National Monument Date: 12/27/2017

Project: Replace cave tour structures to provide for increased safety PEPC Project Number: 56527 Project Locations: Jewel Cave

Location

County: Custer State: SD

DESCRIPTION OF ACTION: The National Park Service (NPS) at Jewel Cave National Monument (JECA) proposes to upgrade the cave tour structures that allow visitor access to the Scenic Tour route. T he project's pu rpose is to increase visitor and employee safety. Two serious injuries in 2013 and 2014 made it apparent that the protection afforded by the existing structures was inadequate. Installation of chaj n-link fen ce aroun d the platfo rms and bridges has served as an interim mitigation, but further review has established the need to make permanent changes to guardrails, hand rails and stair runs. As much as possible, this project will also meet current construction codes.

The Scenic Tour route is approximately one-half mile long. The route consists of alumimun stairs, bridges, and platforms, and concrete trails, which were constructed in 1967-1969, before th e existence of modern building and safety codes. T he scope of this project consists of replacing handrails, stair treads, and bridge/platfo rm floo r grating with stainless steel components. Stainless steel guard rail s will be added. Structural suppo rt members and concrete footings will be eval uated and replaced as needed. Concrete paths will be widened in key areas, and trail lightjng will be added in a few dark areas. Curbing along th e concrete trrul and lint collection pans beneath the metal structures will help the park staff to clean the tour route more efficiently and safe ly. When completed, the trail will retain the same configuration, with only minor changes to trail width and grade.

Because the proposed work would require closure to many cave areas, the work will be do ne during the off season when fewer impacts to the visitor experience are expected.

PURPOSE: The project's purpose is to increase visitor and employee safety.

CE Citation: C.19 Construction o r rehabilitation in previously disturbed or developed areas, required to meet htalth or safety regulations, or to meet requirements for making facilit ies accessible to the handicapped.

CE Justification: This analysis was to determine whether certain activities associated with replacement of the cave tour structure would have either individual or cumulative adverse impacts on either th e physical or human environment as determined through NEPA. Issues and environmental effects are discussed below:

Historic and Cultural Resources - JECA consulted with several federal and state agencies regarding the proposed action and associated infrastructure. The SHPO indicated for the overall project that the p roject w ill not have an adverse effect on historic properties. In their letter dated November 17, 2017 the South Dakota SHPO concurred with the NPS determination of No Adverse Effect to H istoric Resources.

Categorical Exclusion Form - Replace cave tour structures to provide for increased safety - PEPC ID: 56527

Natural Resources - The action is not expected to have a direct effect on federally-listed bats. No federally listed or candidate species were found directly within the project area.

Three federally protected species Red Knot (Calidris canufus ru/a), Whooping Crane (Grus americana), and Northern Long-eared bat (Myotis septentrionalis) may occur in the vicinity of the project area (FWS IPaC 2017).

There is no critical habitat for the Red Knot or Whooping Crane within the action area; therefore there would be "no effect" on these species.

The Northern Long Eared Bat (NLEB) is listed as Threatened, and its habitat includes the historic cave entrance and surrounding area. The NLEB would be most vulnerable to disturbance in the winter and early spring.

However, this action will occur nearly a mile from the historic cave entrance and will not impact the environment of that part of the cave, or the trees used for roosting.

The National Park Service (~PS) has completed informal consultation with the U.S. Fish and Wildlife Service (FWS) regarding the Threatened NLEB. The NPS determined that project will have No Effect on the threatened Northern Long-eared bat. In their e-mail communication dated August 10, 2017 the FWS determined that no formal documentation would be needed under ESA with the NPS determination of "no effect".

MITIGATION MEASURES: To ensure the preservation of cave resources and that any potential impacts are minimal, the following measures will be followed:

• The NPS will provide training for in-cave behavior to all contractor employees

• A full-time NPS employee will be present during all in-cave activity, to monitor activities and potential risks to cave resources.

• The NPS will identify sensitive areas, and provide methodologies for avoiding impact as follows:

Confine all operations to the work limits of the project. All work near cave features will be carefully supervised to prevent damage. The contractor's employees will only be permitted to be off the cave trails where it is necessary to carry out the work of this project.

Work in any areas designated as sensitive will require additional coordination with the contracting officer and CMR. The contractor shall notify the contracting officer and CMR 14 days in advance of

·~ anticipated work in such areas.

Cave walls will be protected during the movement of materials through the passageways (use padded material as necessary to protect the cave walls).

Temporary barriers will be provided to protect existing cave features and to prevent unauthorized personnel from accessing the construction area.

The contractor's employees will not drill into or set bolts or other anchoring devices in cave walls, or fasten ropes, cables, or guys to existing cave walls or features.

Protect surrounding cave features and adjacent passageways from dust created during construction (such as rock excavation; drilling dowels and rock anchors; and concrete sawing). Dust control methods used shall be at the discretion of the contractor and may include collection and filtration, vacuuming, and misting.

Capture any slurry created from concrete wet sawing operations and properly dispose of outside of the cave.

Capture all concrete, metal, and plastic/nylon shavings created from drilling new anchor bolts and new connections in structural members, and properly dispose outside of the cave.

Manganese is present in several locations off trail where work will be required and any contractor employee working in the manganese areas shall remove their footwear prior to walking back onto the existing pathway (this can be accomplished with either a change of footwear or temporary boot coverings).

Deliveries will be scheduled to minimize use of driveways and entrances and to minimize space and time requirements for storage of materials and equipment on-site.

Categorical Exclusion Form - Replace cave tour structures to provide for increased safety - PEPC ID: 56527

No federally listed or candidate species were fo und directly within the project area. If a listed species is encountered, construction activities will be stopped and immediate consultation with the USFWS will be reinitiated.

Maintain a 2-door airlock system at th e Portal entrance, ensuring that at least one door remains closed at all times.

Decision: I find that the action fits within the categorical exclusion above. Therefore, I am categorically excluding the described project from further NEPA analysis. No extraordinary circumstances apply.

Signature

Superintendent: & 5~ AP.

Bonnie Schwartz

Date: (d -c:) g'-/ }-

Categorical Exclusion Form - Replace cave tour structures to provide for increased safety - PEPC ID: 56527

Extraordinary Circumstances:

'If implemented, would the proposal... /Yes/No jNotes

!A. Have significant impacts on public health or safety?

B. Have significant impacts on such natural resources and unique geographic characteristics as :historic or cultural resources; park, recreation, or refuge lands; wilderness areas; wild or scenic rivers; national natural landmarks; sole or principal drinking water aquifers; prime farmlands;

!wetlands (Executive Order 11990); floodplains (Executive Order 11988); national monuments;

\migratory birds; and other ecologically significant or critical areas?

/c. Have highly controversial environmental effects or involve unresolved conflicts concerning !alternative uses of available resources (NEPA section 102(2)(E))?

;o. Have highly uncertain and potentially significant environmental effects or involve unique or unknown environmental risks?

!No I No r1 r1 !E. Establish a precedent for fu_tu_r_e_a_c-ti_o_n_o_r_r_e_p-re-s-en_t_a_d_e_c-is_i_o_n-in-p-ri_n_ci_p_le_a_b_o_u_t_fu_tu_r_e_a_ct_i_on-s-~I with potentially significant environmental effects? I I --------------------------! F. Have a direct relationship to other actions with individually insignificant, but cumulatively ~I

'significant, environmental effects? I I G. -H~~~ ~ig~ifi~-~~-t-i~p-a-c--t~s_o_n_p_r_o_p_e_rt-ie_s_l_is-te_d_o_r_e_l_ig-ib_l_e_t_or-1-is-t-in_g_o_n_t_h_e_N-at-io_n_al_R_e_g-is-te_r_o_f_~ I

Historic Places, as determined by either the bureau or office? I I H. Have significant impacts on species listed or proposed to be listed on the List of Endangered or ~I :Threatened Species, or have significant impacts on designated Critical Habitat for these species? I I f1. Violate a federal, state, local or tribal law or requirement imposed for the protection of the ; environment?

~. Have a disproportionately high and adverse effect on low income or minority populations (EO i12898)?

r1-r1

~,K-.-L-im-it-a·-c-ce_s_s-to-an_d_ce_r_e_m--o-n-ia_l_u_s_e_o_f_In_d_i_an_s_a_cr_e_d_s-it_e_s_o_n_fi_e_d_er_a_l_la_n_d_s_b_y_I_n_d_ian--re-1-ig-io_u_s __ ~ I

;practitioners or adversely affect the physical integrity of such sacred sites (EO 130007)? I I :.:·L. Contribute to the introduction, continued existence, or spread of noxious weeds or non-native ro , '.invasive species known to occur in the area or actions that may promote the introduction, growth, :or expansion of the range of such species (Federal Noxious Weed Control Act and Executive Order 13112)?

Categorical Exclusion Form - Replace cave tour structures to provide for increased safety - PEPC ID: 56527

National Park Service

ENVIRONMENTAL SCREENING FORM (ESF)

Updated Sept 2015 per NPS NEPA Handbook

A. PROJECT INFORMATION

Jewel Cave National Monument Date: 12/27/2017

P1oject Title: Replace cave tour structures to provide for increased safety PEPC Project Number: 56527 PMIS Number: 219033 Project Type:

Project Locatio n :

County, State:

Project Leader:

Reconstruction (REC)

Custer , South Dakota John Black

B. PROJECT DESCRIPTION

The National Park Service (NPS) at Jewel Cave Natio nal Monument QECA) proposes to upgrade the cave to ur structures that allow visitor access to the Scenic T our route. T he project's pu rpose is to inc rease visitor and employee safety. Two serious injuries in 2013 and 2014 made it apparent that the p rotection affo rded by the existing structures was inadequate. Installation of chain -lin k fence aroun d the platfo rms and b ridges has se rved as ari interim mitigation , but further review has established the need to make permanent changes to guardrails, handrails and stair runs. As much as possib le, this project will also meet current construction codes.

The Scenic Tour route is approximately one-half mile long. The route consists of aluminum stairs, bridges, and platforms, and concrete trails, which were constructed in 1967-1969, before the existence of modern building and safety codes. The scope of this project consists of replacing handrails, stair treads, and b ridge/ platfo rm floo r grating with stainless steel components. Stainless steel guard rails will be added. Structural support members and co ncrete footings will be evaluated and replaced as needed. Concrete paths wi ll be w idened in key a reas, and trail lighting will be added in a few dark areas. Curbing alo ng the concrete trail and lin t collection pans beneath the metal structures will help the park staff to clean the tour route mo re efficiently and safely. W he n co mpl eted, the trail will retain the same configuration, with only mino r changes to trail width and grade.

Because the proposed work would require closure to many cave areas, the work will be do ne d uring the off season when fewer impacts to the visitor experience are expected.

The National Park Service has determined that project will have N o Effect on the threatened N orth ern Long eared bat, which uses the historic cave entrance, about o ne mile from the construction site. See uploaded file in File List.

Environmental Screening Form (ESF) - Replace cave to ur structures to provide for increased safety - PEPC ID:

56527

To ensure the preservation of cave resources and that any potential impacts are minimal, the following measures will be followed:

• The NPS will provide training for in-cave behavior to all contractor employees

• A full-time NPS employee will be present during all in-cave activity, to monitor activities and potential risks to cave resources.

• The NPS will identify sensitive areas, and provide methodologies for avoiding impact

C. RESOURCE IMPACTS TO CONSIDER:

Resource Potential Potential Issues & Impacts for Impact

Air Potential Issue: Dust from construction activities contaminating the cave air.

Air Quality Cave air Impact: Moderate impact. Dust will be minimized with methods such as collection, filtration, vacuuming and misting.

Biological Potential Issue: Introduction of nonnative or exotic species with new materials Nonnative or Exotic brought into the cave during construction.

Species Mold, Fungus, Algae Impact: Minor impact. Introduction of non-native species will be mitigated by maintaining a 2-door airlock entry, with at least one door closed at all times. Supplies, equipment, and footwear will be cleaned before entering the cave.

Biological Potential Issue: The NLEB uses Jewel Cave and surrounding roost trees for Species of Special habitat.

Concern or Their Habitat Impact: Negligible impact. The work will take place in a part of the Threatened Northern cave that is nearly a mile from the hibernaculum found inside the Long-eared bat historic entrance. It will not impact any trees.

(NLEB)

Biological None Vegetation

Biological None Wildlife and/or Wildlife Habitat including terrestrial and aquatic species

Cultural None Archeological Resources

Cultural None Cultural Landscapes

Cultural None Ethnographic Resources

Environmental Screening Form (ESF) - Replace cave tour structures to provide for increased safety- PEPC ID:

Cultural None Museum Collections

Cultural Potential Issue: Replacement of portions of the cave tour structures.

Prehistoric/historic structures Impact: Minor impact. The upgrades will be in keeping with the nature

c. 1966 tour structures of existing structures. The tour path will not be altered.

within the cave

Geological Potential Issue: Feature damage due to construction activities.

Geologic Features Cave surf aces, Impact: Minor impact: The NPS will provide training for in-cave sediments, speleogens, behavior to all contractor employees. A full-time NPS employee will be speleothems present during all in-cave activity, to monitor activities and potential risks to cave resources. The NPS will identify sensitive areas, and provide methodologies for avoiding impact.

Geological None Geologic Processes

Lightscapes Potential Issue: Additional lighting to be installed with this project will change Lightscapes the lightscape in the cave.

Cave lighting

Impact: Negligible impact. Low intensity lighting will be installed in a few dark areas, to illuminate only the foot trail.

Other Potential Issue: Safety concerns for workers within an unfamiliar (cave) Human Health and environment.

Safety Contractor employees Impact: Moderate impact. Contractors will be trained and monitored to ensure safe practices within the cave environment.

Soundscapes Potential Issue: Additional noise from construction activities affecting the Soundscapes soundscape of the cave.

Vibrational sounds from people walking on Impact: Negligible impact. This will be a short-term effect. In the long metal tour structures term, stainless steel treads and rails will result in less vibrational noise.

Visitor Use and Potential Issue: Full or partial closure of the tour route during construction.

Experience Recreation Resources Impact: Minor impact. Closures will occur in the off-season, which Accomodation of tour accounts for only a small percentage of the annual visitation. Notice of groups closures will be widely distributed to the public.

Visitor Use and Potential Issue: Higher guardrails and additional handrails may detract from Experience aesthetics.

Visitor Use and Experience Impact: Minor impact. Guard rails will use a cable system, instead of Aesthetic values additional rails, to mitigate visibility. Additional handrails will be installed only where necessary. Stainless steel will not have a highly reflective finish.

Environmental Screening Form (ESF) - Replace cave tour structures to provide for increased safety - PEPC ID:

Water Potential Issue: Co ntamination of water due to construction activities.

Water Qual ity o r Quantity Impact: Moderate impact. The NPS will provide training for in-cave Pools and drip sites behavio r to all contractor employees. A fu ll-time N PS employee will be present during a ll in-cave activity, to monitor activities and p otential risks to cave resources. T he N PS will identify sensitive areas, and provide methodologies fo r avoiding impact.

Wilderness one Wilderness

D. ESF ADDENDUM QUESTIONS:

I Question

Reviewers:

Mike Wil es, Dan Austin

Compliance Specialist:

NEPA

Mike Wiles

NHPA

Mike W iles

Approved:

Superintendent:

I Answer I Notes

Date: 12/27)17

Date:

Date:

Environmental Scree ning Fo rm (ESF) - Replace cave tour structures to provide for increased safety - PEPC ID:

Page 4 o f 4

National Park Service Jewel Cave National Monument Date: 09/29/2017

ASSESSMENT OF ACTIONS HAVING AN EFFECT ON

HISTORIC PROPERTIES

A. DESCRIPTION OF UNDERTAKING

1. Park: Jewel Cave National Monument

2. Project Description:

Project Name: Replace cave tour structures to provide for increased safety Prepared by: Mike Wiles Date Prepared: Telephone: 605-673-8308 PEPC Project Number: 56527 Locations:

County, State: Custer, SD Describe project:

The National Park Service (NPS) at Jewel Cave National Monument OECA) proposes to upgrade the cave tour structures that allow visitor access to the Scenic Tour route. The project's purpose is to increase visitor and employee safety. Two serious injuries in 2013 and 2014 made it apparent that the protection afforded by the existing structures was inadequate. Installation of chain-link fence around the platforms and bridges has served as an interim mitigation, but further review has established the need to make permanent changes to guardrails, handrails and stair runs. As much as possible, this project will also meet current construction codes.

The Scenic Tour route is approximately one-half mile long. The route consists of aluminum stairs, bridges, and platforms, and concrete trails, which were constructed in 1967-1969, before the existence of modern building and safety codes. The scope of this project consists of replacing handrails, stair treads, and bridge/platform floor grating with stainless steel components. Stainless steel guard rails will be added. Structural support members and concrete footings will be evaluated and replaced as needed. Concrete paths will be widened in key areas, and trail lighting will be added in a few dark areas. Curbing along the concrete trail and lint collection pans beneath the metal structures will help the park staff to clean the tour route more efficiently and safely. When completed, the trail will retain the same configuration, with only minor changes to trail width and grade.

Because the proposed work would require closure to many cave areas, the work will be done during the off season when fewer impacts to the visitor experience are expected.

The National Park Service has conducted and completed informal consultation with representatives for the U.S.

Fish and Wildlife Service (FWS) regarding six federally listed bat species which occupy the cave including the Townsend Big Eared Bat (Corynorhinus townsendii); however, the hibernaculm (winter roosting site) is located at least one quarter mile from the proposed worksite entrance and no adverse affects to species stemming from this proposed action are expected.

Assessment of Effect Form - Replace cave tour structures to provide for increased safety- PEPC ID: 56527

To ensure the preservation of cave resources and that any potential impacts are minimal, the following measures will be followed:

- The NPS will provide training for in-cave behavior to all contractor employees - A full-time NPS employee will be present during all in-cave activity, to monitor activities and potential risks to cave resources. - The NPS will identify sensitive areas, and provide methodologies for avoiding impact

Area of potential effects {as defined in 36 CFR 800.16[d]) Please see "Draft Design Development Drawings" PDF in Internal Documents I Comments section for layout and construction details.

3. Has the area of potential effects been surveyed to identify historic properties?

No

X Yes

Source or reference: HRS Evans-Hatch 2006

4. Potentially Affected Resource{s}:

Archeological Resources Affected: NI A

Archeological Resources Notes: Humans first entered this part of the cave in 1962.

Historical Structures/Resources Affected: NI A

Historical Structures/Resources Notes: The tour structures were completed in 1969. Most handrails and floor decking have been replaced over the years. Support structures remain intact, but some will be replaced during construction. Asphalt trail was replaced with concrete in the mid-1980s. Tour route configuration will remain the same.

Cultural Landscapes Affected: NI A

Cultural Landscapes Notes: NI A

Ethnographic Resources Affected: NI A

Ethnographic Resources Affected Notes: NIA

5. The proposed action will: {check as many as apply}

No Destroy, remove, or alter features/elements from a historic structure

No Replace historic features/elements in kind

No Add non-historic features/elements to a historic structure

No Alter or remove features/elements of a historic setting or environment {inc. terrain}'

Add non-historic features/elements (inc. visual, audible, or atmospheric) to a historic No setting or cultural landscape

No Disturb, destroy, or make archeological resources inaccessible

Assessment of Effect Form - Replace cave tour structures to provide for increased safety- PEPC ID: 56527

No Disturb, destroy, or make ethnographic resources inaccessible

No Potentially affect presently unidentified cultural resources

Begin or contribute to deterioration of historic features, terrain, setting, landscape No elements, or archeological or ethnographic resources

~ Involve a real property transaction (exchange, sale, or lease of land or structures)

Other (please specify): -------------------------

6. Supporting Study Data:

(Attach if feasible; if action is in a plan, EA or EIS, give name and project or page number.)

8. REVIEWS BY CULTURAL RESOURCE SPECIALISTS

The park 106 coordinator requested review by the park's cultural resource specialist/advisors as indicated by check-off boxes or as follows:

[ X ] Archeologist Name: Anne Vawser Date: 07/25/2017 Comments: This project has no potential to affect archeological resources.

Check if project does not involve ground disturbance [ ] Assessment of Effect: _No Potential to Cause Effect _No Historic Properties Affected _No Adverse Effect _Adverse Effect _Streamlined Review Recommendations for conditions or stipulations:

[ X ] Historian Name: Ron Cockrell Date: 07/21/2017 Comments: The cave tour infrastructure needs to be evaluated by the South Dakota SHPO as it was developed in conjunction with the overall MISSION 66 program for Jewel Cave NM. A DOE needs to be submitted and alterations reviewed by SHPO.

Check if project does not involve ground disturbance [ J Assessment of Effect: _No Potential to Cause Effect _No Historic Properties Affected _lLNo Adverse Effect _Adverse Effect _Streamlined Review Recommendations for conditions or stipulations:

Doc Method: Standard 4-Step Process

[ X] Historical Architect Name: William Harlow Date: 07/20/2017 Comments: Based on the schematic design provided, the proposed modifications while extensive appear to maintain the character and feeling of the path through the cave. I recommend that the he 1969 structure is register eligible at the entire landscape development level as a unique "one-off" custom engineering design that could not have been built much earlier before the standardization of aluminum shapes and likely would not have been allowed later. It is intimately linked to the Mission 66 visitor development on the surface above. Consider that the Assessment of Effect Form - Replace cave tour structures to provide for increased safety - PEPC ID: 56527 project will need a DOE and analysis confirming that the rehabilitation uses standard metal shapes and hardware that is compatible with the original skeleton of the elevated walk system.

Check if project does not involve ground disturbance [ ] Assessment of Effect: _No Potential to Cause Effect _No Historic Properties Affected _x_No Adverse Effect _Adverse Effect _Streamlined Review Recommendations for conditions or stipulations:

Doc Method: Standard 4-Step Process

[ X ] Historical Landscape Architect Name: Marla McEnaney Date: 08/08/2017 Comments: Concur w/ requirement to complete a DOE for the cave development.

Check if project does not involve ground disturbance [ ] Assessment of Effect: _No Potential to Cause Effect _No Historic Properties Affected -1LN0 Adverse Effect _Adverse Effect _Streamlined Review Recommendations for conditions or stipulations:

Doc Method: Standard 4-Step Process

[ X] Regional Section 106 Coordinator Name: Stephen Rogers Date: 08/09/2017 Comments: This consensus determination is based upon a review of comments by all CRM Team members.

When individual CRM Team member comments differ, this shall serve as the final determination of effect and consultation method.

Check if project does not involve ground disturbance [ ] Assessment of Effect: _No Potential to Cause Effect _No Historic Properties Affected _x_No Adverse Effect _Adverse Effect _Streamlined Review Recommendations for conditions or stipulations: Ensure CRM Team is included in review of draft construction drawings.

Doc Method: Standard 4-Step Process

No Reviews From: Curator, 106 Advisor, Anthropologist

C. PARK SECTION 106 COORDINATOR'S REVIEW AND RECOMMENDATIONS

1. Assessment of Effect:

No Potential to Cause Effects ---- No Historic Properties Affected ----

X No Adverse Effect ---- Adverse Effect ----

Assessment of Effect Form - Replace cave tour structures to provide for increased safety - PEPC ID: 56527

2. Documentation Method:

[ X] A. STANDARD 36 CFR PART 800 CONSULTATION

Further consultation under 36 CFR Part 800 is needed.

[ ] B. STREAMLINED REVIEW UNDER THE 2008 SERVICEWIDE PROGRAMMATIC AGREEMENT (PA)

The above action meets all conditions for a streamlined review under section Ill of the 2008 Servicewide PA for Section 106 compliance.

APPLICABLE STREAMLINED REVIEW Criteria (Specify 1-16 of the list of streamlined review criteria.)

[] C. PLAN-RELATED UNDERTAKING

Consultation and review of the proposed undertaking were completed in the context of a plan review process, in accordance with the 2008 Servicewide PA and 36 CFR Part 800.

Specify plan/EA/EIS:

[] D. UNDERTAKING RELATED TO ANOTHER AGREEMENT

The proposed undertaking is covered for Section 106 purposes under another document such as a statewide agreement established in accord with 36 CFR 800.7 or counterpart regulations.

[ ] E. Combined NEPA/NHPA Process Documentation is required for the preparation of an EA/FONSI or an EIS/ROD has been developed and used so as also to meet the requirements of 36 CFR 800.3 through 800.6

[ ] G. Memo to SHPO/THPO

[ ] H. Memo to ACHP

SHPO/THPO Notes:

3. Additional Consulting Parties Information:

Additional Consulting Parties: No

4. Stipulations and Conditions:

Following are listed any stipulations or conditions necessary to ensure that the assessment of effect above is consistent with 36 CFR Part 800 criteria of effect or to avoid or reduce potential adverse effects.

Request that SD-SHPO conduct an informal Determination of Eligibility for the cave tour route.

5. Mitigations/Treatment Measures:

Measures to prevent or minimize loss or impairment of historic/prehistoric properties:

(Remember that setting, location, and use may be relevant.)

No Assessment of Effect mitigations identified.

Assessment of Effect Form - Replace cave tour structures to provide for increased safety- PEPC ID: 56527

D. RECOMMENDED BY PARK SECTION 106 COORDINATOR:

Compliance Specialist:

NHPA Specialist

Mike Wiles

E. SUPERINTENDENT'S APPROVAL

Date: q / "'2_ 4 { 17

The proposed work conforms to the NPS Management Policies and Cultural Resource Management Guideline, and I have reviewed and approve the recommendations, stipulations, or conditions noted in Section C of this form.

Signature

Superintendent: M )r~J/7""~ ___..............__'---'~--"""Bo~m1c......,..ie ~.=..ch"""""'--++-z---

Date: £ ~;) P -/ ~

Assessment of Effect Form - Replace cave tour structures to provide for increased safety - PEPC ID: 56527