Attach Q - Mitigation Plan.pdf

Mitigation Plan for the (BPA) Glass Butte Radio Station Project

Bureau of Land Management Prineville District

Prepared By:

Bureau of Land Management (BLM) Prineville District

July to September 2018

BLM Prineville District Office

3050 NE Third Street

Prineville OR, 97754

Exhibit Q

Table of Contents Section Pages

I. Introduction……………………………………………………………………………………………………….…………………..…….1‐2

II. BPA Mitigation Responsibilities………………………………………………………………………………………….…………..2

Cultural Resource Personnel/Known and Current Responsibilities…………………………….…………….2‐3

Training, Coordination, and Project Area Access…………………………………………………….…………………..4

Miscellaneous Notes…………………………………………………………………………………………………..….…………..4

Cultural Resource Mitigation Table……………………………………………………………………..……….………….5‐6

Avoidance Signage and Fencing Mitigation Notes……………………………………………………….………………6

Road Improvement Mitigation……………………………………………………………………………………………………6

Surface or Subsurface Cultural Resource Mitigation……………………………………………...………..………7‐8

Staging Area Mitigation……………………………………………………………………………………………………….…..8‐9

III. Future BPA Decommissioning Responsibilities……………………………………………………………………….………9

IV. Collective BPA and BLM Mitigation Responsibilities……………………………………………………….………….…10

V. BLM Mitigation Responsibilities………………………………………………………………………………………….……10‐11

I. Introduction

The Bureau of Land Management (BLM) is the sole, lead agency and is ultimately responsible for all

Section 106 review regarding the Bonneville Power Administration (BPA) Glass Butte Radio Station

Project undertaking. For this undertaking, BPA is defined as an applicant per 36 CFR 800. The BLM is issuing a federal right‐of‐way (ROW) grant, as applied for by the BPA, for the Glass Butte Radio Station

Project undertaking pursuant to Section 106 of the National Historic Preservation Act (NHPA) and its implementing regulations (36 CFR 800). In addition, the BLM determined that the proposed issuance of the ROW grant triggered the requirements of Section 106 of the NHPA for the undertaking as defined at

36 CFR 800.16(y). The undertaking consists of the construction, operation, and maintenance of a communication facility, use of staging areas for construction equipment during construction, and use and improvements to an existing access road (road) linking U.S. Route 20 to the undertaking’s proposed communication facility near the peak of Glass Butte. More specifically, the proposed communication facility would include a 100 foot tall self‐supporting steel lattice tower with a 35 foot by 35 foot concrete foundation, a one‐story communication building that would be an approximately 20 feet wide, 52 feet long, and 15 feet high concrete masonry unit block veneer building, and one 2000 gallon propane tank installed on a concrete pad all within a graded and rocked 2.3 acre communication site area amongst and in between several existing communication facilities and approximately 120 feet southeast of Glass

Butte’s peak. Furthermore, the undertaking would provide BPA the ability to assure the secure and reliable operation of its power transmission network in Oregon and adjoining states and allow enhanced real time monitoring and management of the power grid ensuring against the possibility of significant power transmission failures.

The BLM has applied the criteria of adverse effect to historic properties effected by the Glass Butte

Radio Station Project undertaking pursuant to 36 CFR 800.5(a)(2) and completed this in consultation with the Oregon State Historic Preservation Office (SHPO), the Burns Paiute Tribe, the Confederated

Tribes of the Warm Springs Reservation of Oregon, and the Klamath Tribes. Similarly, the BLM has determined mitigation measures to resolve adverse effects in consultation with the SHPO and the Burns

Paiute Tribe, the Confederated Tribes of the Warm Springs Reservation of Oregon, and the Klamath

Tribes. In addition, views regarding adverse effects and resolution were gathered from the public and considered by the BLM agency official prior to the finalization of this mitigation plan. Lastly, the Section

106 review process associated with this undertaking was carried out according to 36 CFR 800 and the

Project Programmatic Agreement between the Bureau of Land Management, the Bonneville Power

Administration, the Advisory Council on Historic Preservation, and the Oregon State Historic Preservation

Office Regarding the Glass Butte Radio Station Project. This project Programmatic Agreement is hereafter referred to as the PA.

According to the PA, the BLM would not issue a Notice to Proceed permitting any ground disturbing or construction activities authorized by the ROW prior to completing a Mitigation Plan in accordance with the stipulations in the PA. Furthermore, the BLM determined that it would not issue the ROW until this

Mitigation Plan was appended to the ROW stipulations prior to ROW issuance. BPA, the potential grantee of the ROW, signed the PA as an invited signatory and agreed to carry out a portion of the mitigation necessary to resolve adverse effects to historic properties as they are indicated to be specifically responsible for as documented in this Mitigation Plan under the oversight of the BLM. In addition, the BLM agreed to carry out and be responsible for the remaining mitigation necessary to resolve adverse effects to historic properties as documented in this Mitigation Plan. Lastly and per the

PA, BPA shall ensure that the Glass Buttes BPA Communication Site Inadvertent Discovery Plan shall be followed by their contractors during construction or construction related activities immediately after the inadvertent discovery of human remains, funerary objects, sacred objects, or objects of cultural patrimony as specifically defined in the Code of Federal Regulations for the Native American Graves

Protection and Repatriation Act (43 CFR 10) or after any new or unanticipated discovery of a historic property as defined and directed by Section 106 of the National Historic Preservation Act (36 CFR 800).

Please note Historic Properties and other cultural resources in need of mitigation per adverse effect consultation with the BPA, the tribes, and the Oregon SHPO will hereafter be referred to as “cultural resources”.

II. BPA Mitigation Responsibilities

BPA, the ROW grantee as an invited signatory to the PA, has agreed to carry out the following mitigations and be responsible for funding all contracted archaeologists, tribal cultural resource monitors, BPA cultural staff, and any other non‐BLM cultural staff for the duration of all project ground disturbing activities including construction and preparation of the BPA communication site to be built on

Glass Butte, road improvements, and the use of any staging areas. Furthermore, BPA will also eventually decommission their Glass Butte communication site and has agreed to decommission the site, in part with respect to cultural resources, according to the direction provided in this mitigation plan. Failure by BPA to implement the mitigations in this mitigation plan will result in the undertaking being subject to additional Section 106 review potentially including dispute resolution, delays, PA termination, or additional consultation with the Burns Paiute Tribe, the Confederated Tribes of the

Warm Springs Reservation of Oregon, the Klamath Tribes, the BLM, the Oregon SHPO, and the ACHP per the PA.

Cultural Resource Personnel/Known and Current Responsibilities

A BPA archaeologist will be working full‐time on‐site during the first week of project/construction/road improvement activities. They will work longer than that amount of time if necessary. The BPA archaeologist will also be working on‐site after that for 1‐2 days every month for the life of the project and will participate in the contract selection process for the project and be at the pre‐bid and preconstruction tours, as well as, preconstruction meetings. The BPA archaeologist will provide on‐site training to all project employees or ensure all employees receive training relating to ARPA violations, as well as, a general introduction to the cultural significance of the area. Furthermore, they will communicate the need to respect all mitigation measures as well as the consequences to the individual and project as a whole should any of the mitigation measures be ignored or impacted. The BPA archaeologist will also supervise or directly provide environmental training regarding the need for all project personnel to stay within the project ROW at all times while working or driving and for all project personnel to work only where directed. This training will also communicate the need for all project personnel including all cultural staff to work together as a team.

BPA will contract with each of the consulting tribes who will be responsible for the provision of a tribal cultural monitor to be present during ground disturbing construction activities. In addition and more specifically, the contracted archaeologist (On‐Site Archaeologist) shall supervise and coordinate work with a total of three tribal cultural resource monitors, one selected from each of the consulting tribes unless a tribe declines or fails to select a monitor to work during BPA scheduled, ground disturbing construction activities. Furthermore, the On‐Site Archaeologist shall be on‐site during all non‐ground disturbing construction activities within the communication site such as communication tower construction, building construction, etc. If the contracted On‐Site Archaeologist is absent or otherwise unable to work, a backup and contracted On‐Site Archaeologist will work in their place so that an On‐

Site Archaeologist is always available, present, and able to work on‐site during the life of the construction project. In addition, at least one cultural staff member will be present during all ground disturbing construction activities in the event of additional cultural staff absences. BPA may choose to contract with additional monitors as necessary beyond the four‐person cultural staff described here for monitoring purposes in order to avoid any project delays due to cultural staff absences or unforeseen needs.

More specifically, three tribal cultural resource monitors shall be individually selected by the Burns

Paiute Tribe, the Confederated Tribes of the Warm Springs Reservation of Oregon, and the Klamath

Tribes. In addition, these three tribal cultural resource monitors shall be BPA funded to monitor all ground‐disturbing construction activities, which include all road improvement activities, fencing, and staging area fencing within the finalized ROW. The Inadvertent Discovery Plan shall be followed when inadvertent discoveries occur, new historic properties are discovered, or when unanticipated effects occur to known historic properties.

A member of the cultural staff will always be present during construction and road improvement activities for monitoring purposes.

The On‐Site Archaeologist will be responsible for the installation of temporary protective fencing in advance of the commencement of any construction activities. The On‐Site Archaeologist will coordinate the timing of this work with each of the tribes to allow them the opportunity to be present while the work is done. Together, the cultural staff will determine where fencing should occur based on cultural resource boundaries, as well as, by the direction within the Road Improvement Mitigations, Staging Area

Mitigations, and Surface or Subsurface Cultural Resource Mitigation subsections listed below. If a surface cultural resource boundary is determined to be larger or different than the previously recorded cultural resource boundary, then the area for avoidance will be modified to accurately reflect conditions on the ground, with the changes noted, recorded via GPS by the On‐Site Archaeologist, and shared with the BPA and BLM to ensure continuity throughout the life of the project. The On‐Site Archaeologist in consultation with the tribal cultural resource monitors may determine where fencing is not needed in areas with steep slopes or large boulders that would naturally prevent construction and other work vehicles from driving off roads and affecting cultural resources. Any such areas will be noted and shared with the BPA and the BLM.

All cultural resource books or documents including the mitigation plan itself provided to cultural staff for the purposes of carrying out this mitigation plan shall be turned over to Brian O’Donnchadha at the completion of the project and destroyed by him when no longer needed. If any of these books or documents as well as the mitigation plan are provided temporarily to any other staff, they too will be destroyed by Brian at the end of the project. Brian will keep a tally of what books or documents were provided to whom and he will make sure that they return these books and documents back to him for destruction purposes.

Training, Coordination, and Project Area Access

All construction employees, contractors, subcontractors, new employees, or project‐associated visitors including BPA employees will go through environmental training provided at the beginning of the project by a BPA Archaeologist and then provided as needed by the On‐Site Archaeologist. At the completion of this training, a sticker (to be worn on hard‐hats) will be provided to establish an easy system to track who has received the training. All on‐site staff, with no exceptions, must complete this training. One‐time visitors to the project (BPA, BLM, Tribal, or private contractors) who have not, or for some reason cannot complete the training, must be accompanied at all times by someone who has been received the training. A BPA archaeologist will also participate in construction meetings. In addition, training will ensure that all of the parties listed above stay where they are supposed to be while on the job site. This will prevent the destruction of cultural resources that are archaeological or traditional in nature. Anyone who violates the job site rules will be held accountable for their actions and if warranted, may be removed from the project team. Any outside project‐associated personnel not directly associated with day‐to‐day construction activities will need to sign in and out of the job site and be chaperoned including any senior BPA executives, etc. All equipment and vehicle drivers will be trained to stay on ROW roads and to use only identified passing, staging, and parking areas. Access to the radio site work area will be limited to required work vehicles, with all private vehicles and non‐ essential work vehicles to be left at the staging area of Hwy 20, and project personnel commuting to the peak of Glass Butte in as few vehicles as possible.

Tailgate meetings will occur each day to determine what work will happen for the day, all cultural staff will attend, and the archaeologist will determine where cultural staff need to complete work for the day.

A three weeks look‐ahead work schedule will be provided to all consulting parties each week to help determine cultural staffing needs into the future.

Miscellaneous Notes

BPA plans to have a lead vehicle to determine when the road is clear for the movement of large equipment and machinery up and down the ROW road as well as a flag vehicle to escort the movement of large equipment and machinery for the purposes of public, tribal, and project employee safety.

Additional safety protocols and mechanisms may be introduced in consultation with the BLM and/or according to law.

BPA plans for the ROW road to be minimally and lawfully improved in such a way that it allows for safety and project construction access, while not indirectly providing for a major influx of additional road users to gain access to the peak of Glass Butte.

This document does not change or alter any of BPA’s and the BLM’s other lawful and safety responsibilities. And this document carries no responsibility for any unsafe or unlawful practices carried out in association with this mitigation plan and this mitigation plan does not direct any unsafe or unlawful practices to occur per its direction. All mitigation plan work shall be conducted in a safe, responsible, and lawful manner.

Clarifications regarding this mitigation plan can be provided by BLM cultural resource staff under the leadership of the Central Oregon Field Office Manager or by BPA Archaeologist Brian O’Donnchadha in consultation with the BLM cultural resource staff.

Cultural Resource Mitigation Table

Cultural resources listed in the table below are in need of specific mitigation types given their specific locations and likely (undertaking) project effects to those resources. The table below shall be used to identify which mitigation measures will be selected and completed by BPA employed cultural staff prior to or during project implementation to avoid adverse effects or otherwise mitigate those effects to cultural resources.

Cultural Resource Number

Apply Road Mitigation

Apply Staging Area Mitigation

Apply Surface or Subsurface Cultural Resource Mitigation

Responsible Agency

15/2349‐101 Yes Yes BPA

35LK4333 Yes BPA

15/2349‐119 Yes BPA

35LK2639 Yes BPA

35LK381 Yes BPA

15/2349‐222 Yes BPA

15/2349‐221 Yes BPA

15/2349‐118 Yes BPA

15/2349‐220 Yes BPA

15/2349‐114 Yes BPA

15/2349‐218 Yes Yes BPA

15/2349‐217 Yes BPA

15/2349‐216 Yes BPA

15/2349‐117 Yes BPA

15/2349‐214 Yes BPA

15/2349‐113 Yes BPA

15/2349‐212 Yes BPA

15/2349‐211 Yes BPA

15/2349‐110 Yes BPA

15/2349‐210 Yes BPA

15/2349‐116 Yes BPA

15/2349‐115 Yes BPA

15/2349‐109 Yes Yes BPA

15/2349‐105 Yes Yes BPA

15/2349‐204 Yes BPA

15/2349‐106 Yes Yes BPA

Glass Buttes TCP Yes Yes BPA

Avoidance Signage and Fencing Mitigation Notes

Signs reading, “No Project Access” shall be used along all fencing to indicate to workers that they may not go beyond fencing for any personal or work related reason. Any changes to “No Project Access” language on these signs shall be considered and subject to the approval of the BLM Prineville District

Central Oregon Field Office Manager or their acting in consultation with their cultural resource staff.

Road Improvement Mitigation

Signs will be placed at half mile or quarter miles increments to remind all project and construction drivers to stay on the roads unless deemed unnecessary by the archaeologist in those areas with steep drop‐offs adjacent to roads. In advance of the commencement of construction, multiple approved passing areas will be identified by the On‐Site Archaeologist and tribal cultural resource monitors. The number of passing areas will depend on need as expressed by the construction contractor and availability of suitable areas as determined by the cultural staff. All passing areas will not affect or overlap previously mapped cultural resources. Once identified, these passing areas will be signed and appropriately with no exceptions. Equipment and vehicle drivers will communicate via CB’s or other effective means for all passing and travel purposes so that they stay within the ROW roads and the areas identified for passing only. All ROW road users will carpool in work vehicles to job sites within the ROW.

T‐posts with rope fencing will be used along road prism edges to prevent off‐road driving into cultural resource areas by all project‐related vehicles and employees. And “No Project Access” signage will be placed along this fencing. Furthermore, the fencing will be placed along the road edge at a minimum of

10 meters beyond cultural resource boundaries where those cultural resource boundaries intersect the road. Fencing will always be placed on both edges of the road prism even when a cultural resource is only located on one side of the road. Fencing will never block any road intersections including road entryways into unmarked and public user‐created camping or parking areas. Signage (with an arrow, “No Project Access, but still open to the public” language) will be placed at all road intersections to direct all project‐related traffic to stay within the road ROW and off all other public roads. BPA

Archaeologist Brian O’Donnchadha will provide all of the cultural resource boundary data to the archaeologists and to monitors as appropriate and as necessary for mitigation purposes.

Surface or Subsurface Cultural Resource Mitigation

No surface or subsurface grading will occur upon native road surfaces within cultural resource boundaries. When road improvements other than water bars are needed within cultural resource boundaries, gravel will be used to fill in and cap those locations. Grading may only occur on top of gravel placed on top of cultural resources within road prisms so that cultural resources are not affected.

Water Bar(s) within Cultural Resource 15/2349‐218:

Water Bar locations within Cultural Resource 15/2349‐218 that require grading, earth moving, or subsurface construction digging shall have their adverse effects mitigated as discussed below.

Surficial artifacts upon water bar locations shall be classified; temporally or functionally diagnostic tool artifacts will be photographed, described, and measured; the general locations of artifacts shall be noted; and if water bars locations contain artifacts these locations will be GPS’ed via the collection of

NAD 83 UTM Zone 10 coordinates with up to 5 meters of error. Artifacts that migrate to the surface or into view during water bar construction activities will also documented as described immediately above.

All documented artifacts will be moved away from water bar locations upon the road to a natural surface location within the cultural resource boundary and this location will also be documented and

GPS’ed as described above. Digital documentation for each instance of water bar Surface or Subsurface

Cultural Resource Mitigation in a digital Microsoft Word document will include at a minimum a description and tally of all the classified artifacts observed, pictures with a description for those diagnostic artifacts photographed, measurements for all diagnostic artifacts, the general locations of where artifacts were found, the water bar’s NAD 83 UTM center point coordinates, and UTM coordinates for the location in which artifacts were moved to within the cultural resource 15/2349‐218 boundary. If multiple water bars occur within the cultural resource boundary, then the documentation described above for each water bar will be provided within a single document. The Microsoft Word document will be in a finalized state ready for the BLM to append to their existing cultural resource site records. And these documents and all associated GIS data will be delivered to the BLM Prineville District cultural resource staff within 30 days of the completion of all project construction activities. Cultural staff will monitor all water bar construction within and adjacent to cultural resource 15/2349‐218 and will direct construction employees to stop intermittently when necessary or for longer periods in the event of an inadvertent discovery or after any new or unanticipated discovery of a historic property according to the Inadvertent Discovery Plan.

Additional Water Bars:

Any additional additional water bars proposed to be constructed by BPA shall be GPS’ed via the collection of NAD 83 UTM Zone 10 coordinates with up to 5 meters of error and constructed within the roadway surface material (gravel, etc.) and not upon native road surfaces. In addition, no additional grading or earth movement will occur as a result of their construction within cultural resource boundaries. Furthermore, cultural staff shall also monitor any additional water bar construction within cultural resource boundaries as necessary. Each water bar location shall be independently and digitally documented within a single, digital Word Document and these digital documents and all associated GIS data will be delivered to the BLM Prineville District cultural resource staff within 30 days of completion of all project construction activities.

When any additional water bars are constructed within or adjacent to cultural resource boundaries, those water bars will direct water in the least impactful and least energetic way possible within cultural resource boundaries. No water bars will direct water towards previously recorded rock feature cultural resources adjacent to roads, and no water bar construction will directly affect previously recorded rock feature cultural resources.

Communication Site Footprint and Utility Trench:

The new BPA communication site footprint will be no larger than the communication site ROW and this communication site ROW will be enclosed where possible with temporary fencing during the entire life of construction activities and signed by cultural staff in the same manner as roads and staging areas.

Other than trenching and constructing underground utilities, all direct communication site construction activities will occur within the communication site ROW. Cultural staff will monitor all trenching, earth removal, and soil or sediment displacement as necessary.

Surficial artifacts upon planned trenching, earth removal, and soil/sediment displacement areas will be classified; temporally or functionally diagnostic tool artifacts will be photographed, described, and measured; and the locations of individual artifacts will be GPS’ed via NAD 83 UTM Zone 10 coordinates with up to 5 meters of error. Artifacts that migrate to the surface or into view during any of these construction activities will also documented as described immediately above. All documented artifacts will be moved away from these construction activity areas to a natural surface location within the cultural resource 15/2349‐106 boundary and this location will also be documented and GPS’ed as described above. Digital documentation for each documented artifact shall be done within a single, digital Microsoft Word document and will include at a minimum: a description and tally of all the classified artifacts observed; pictures with a description for those diagnostic artifacts photographed;

measurements for all diagnostic artifacts; the GPS’ed locations of where artifacts where found; the construction activity area’s GPS’ed surface footprint; and UTM coordinates for the location in which artifacts were moved to within cultural resource 15/2349‐106. The digital Microsoft Word document will be in a finalized state ready for the BLM to append to their existing cultural resource site records.

And this document and all associated GIS data will be delivered to the BLM Prineville District cultural resource staff within 30 days of the completion of all project construction activities. Cultural staff will monitor all communication site construction activities and will direct construction employees to stop intermittently when necessary or for longer periods in the event of an inadvertent discovery or after any new or unanticipated discovery of a historic property according to the Inadvertent Discovery Plan.

Staging Area Mitigation

A total of four staging areas will be used during construction activities.

Staging Area 1:

This staging area will not overlap any previously mapped cultural resources and specifically cultural resource 15/2349‐101. The southwest corner of the staging area as originally designed overlaps cultural resource 15/2349‐101 and will need to be adjusted during staging area fencing layout as necessary by cultural staff to avoid affects to this cultural resource. In addition, staging area fencing will only be placed in areas at least 25 feet beyond the cultural resource boundary.

Staging Area 2:

This staging area will be moved from its original proposed location to the southwest as proposed by BPA and agreed upon by the BLM, and new staging area location will not overlap any previously mapped cultural resources and specifically cultural resource 15/2349‐109. In addition, no off‐road driving will occur off‐road across 15/2349‐109 to enter Staging Area 2 at any time. Furthermore, Stage Area 2 shall be fenced as necessary by cultural staff to avoid disturbance outside of the staging area.

Staging Area 3:

This staging area will not overlap any previously mapped cultural resources and specifically cultural resource 15/2349‐105. The southeast corner of the staging area as originally designed overlaps cultural resource 15/2349‐105 and will need to be adjusted during staging area fencing layout as necessary by cultural staff to avoid affects to this cultural resource. Staging Area 3 will be used appropriately and parking will not be allowed to overflow outside of its boundaries.

Staging Area 4:

Staging Area 4 falls upon the old ODOT communication site footprint and will only be used where it is already disturbed. There are no archaeological historic properties near or surrounding this staging area.

In addition, Staging Area 4 shall be fenced as necessary by cultural staff to avoid disturbance outside of the staging area.

III. Future BPA Decommissioning Responsibilities

The BPA intends to eventually decommission the BPA Glass Butte communication site according to the stipulations within the ROW grant. In addition, decommissioning shall include the use of three (total) tribal cultural resource monitors individually selected by the Burns Paiute Tribe, the Confederated Tribes of Warm Springs Reservation of Oregon, and the Klamath Tribes that would be funded by the BPA to monitor all ground disturbing, communication site decommissioning and reclamation activities. In addition, these cultural resource monitors would follow the Inadvertent Discovery Plan that is part of this Mitigation Plan and ROW grant. The BPA will fund and work with the BLM to provide necessary monitoring personnel in the event that any tribe decides not to participate in decommissioning through the selection of a tribal cultural resource monitor.

IV. Collective BPA and BLM Mitigation Responsibilities

BPA and BLM Cooperative Off‐site Mitigation

Kiosk: A three‐paneled kiosk with an overhead shade structure or roof will have a thief in time or other relevant Archaeological Resources Protection Act (ARPA) message to educate the public about ARPA and the importance of archaeological resources. The BLM shall invite tribal representatives from the Burns

Paiute Tribe, the Confederated Tribes of the Warm Springs Reservation of Oregon, and the Klamath

Tribes to consult on any content produced regarding the precontact use of Glass Buttes obsidian if such a panel is desired by the tribes. Consultation will occur within 30 days after it is initiated via correspondence by the BLM with a single tribal representative from each tribe. Consultation will conclude even if no reply is received from a single tribe or all three tribes during that period, and the

BLM will finalize panel content after the 30‐day consultation period. Any additional space on the kiosk would be used to educate the public about other natural resources and other pertinent regulations, etc.

at the BLM’s discretion.

BPA will determine the appropriate kiosk type and vendor with the BLM, and BPA will fund and construct the kiosk in a location and at an aspect of the BLM’s choosing outside of any known archaeological cultural resource sites and within the area previously surveyed for BPA’s undertaking near the intersection of the highway (US Route 20) and the communication site access road ROW. The kiosk will be built by 9/30/2019 and the panels described above will be completed and added to the kiosk by 9/30/2020.

*Please Note: this off‐site kiosk mitigation will not involve the cultural staff and tribal cultural resource monitors in the BPA Mitigation Responsibilities section above and is not considered part of any BPA construction activities for BPA’s undertaking.

V. BLM Mitigation Responsibilities

Cultural Resources listed in the table below are in need of specific mitigation types given their specific locations and the likely (undertaking) project effects to those resources. The table below shall be used to identify the mitigation measures to be completed by BLM employed cultural staff according to the schedules provided below to avoid adverse effects or otherwise mitigate effects to those cultural resources.

Cultural Resource Number Off‐site Mitigation Responsible Agency

15/2349‐106 150 acres of survey BLM

Glass Buttes TCP Yes, 10‐900 Form and kiosk BLM

The BLM shall commence implementation and funding of the following mitigations within five years of the issuance of the ROW grant. Failure by the BLM to implement the following mitigations in this mitigation plan will result in the undertaking being subject to additional Section 106 review potentially including dispute resolution, PA termination, or additional consultation with the Burns Paiute Tribe, the

Confederated Tribes of the Warm Springs Reservation of Oregon, the Klamath Tribes, the BLM, the

Oregon SHPO, and the ACHP per the PA.

The BLM will conduct 150 acres of new survey at Glass Buttes in search of precontact cultural resources.

At a minimum survey will be accomplished in order to identify surface cultural resources and their boundaries within the 150‐acre survey area so that such resources can be avoided if necessary during any future undertakings at Glass Buttes. The 150‐acre survey area will be selected in consultation with the Burns Paiute Tribe, the Confederated Tribes of the Warm Springs Reservation of Oregon, and the

Klamath Tribes. The survey methodology will also be consulted upon with the tribes. Consultation will occur within 30 days after it is initiated via correspondence by the BLM with a single tribal representative from each tribe. Consultation will conclude even if no reply is received from a single tribe or all three tribes during that period, and the BLM will finalize the 150‐acre survey area and survey methodology after the 30‐day consultation period. After the completion of survey, a survey report and cultural resource records will be produced and finalized within the BLM OCRIS database or other applicable BLM database and sent to the Oregon SHPO.

The BLM will take the steps necessary with the Oregon SHPO, BLM, National Park Service, Department of Interior (DOI), private landowners, the public, and any other necessary entities, groups, or agencies to nominate a cultural landscape site at Glass Buttes. This will include the Glass Buttes TCP, archaeological sites, and potentially, any additional historic properties of cultural and religious significance identified by the Burns Paiute Tribe, CTWSRO, and Klamath Tribes falling within the Glass Buttes TCP boundary.

Existing information will be used to complete the nomination and additional information regarding contributing and non‐contributing resources will be gathered and presented within the

10‐900 nomination form as well. Changes to the nomination content and boundary as discussed here shall only occur as necessary per the pertinent regulations, as well as, the recommendations and direction of the National Park Service, DOI, and other necessary regulatory bodies.