A cultural resources survey was conducted within the project area to evaluate potential impacts to cultural and historic resources. The Natural Resources Conservation Service (NRCS) is anticipated to award funding to this project under Public Law 83-566 regulations, which requires the development and approval of a Watershed Protection Plan-Environmental Assessment (Plan-EA) to identify and address potential environmental impacts resulting from the proposed Project in accordance with environmental law. The National Environmental Policy Act (NEPA) of 1969 requires Federal agencies to consider the environmental consequences of their proposed actions before a decision is made. A Plan-EA has been prepared to comply with the requirements of NEPA and the National Watershed Program Manual. The Plan-EA presents the proposed Project and associated alternatives, and discusses potential environmental impacts that may result from the implementation of the proposed Project. The NRCS will then issue a Finding of No Significant Impact (FONSI) or request additional information as necessary to approve the Proposed Action. 

Since federal money through the Natural Resources Conservation Service (NRCS) is anticipated to fund a portion of this project, the project is deemed a federal undertaking and is therefore also subject to the requirements of Section 106 of the National Historic Preservation Act (NHPA) of 1966 as amended. As part of the Section 106 process, the City and GRWW have been in consultation with the Natural Resources Conservation Service (NRCS) and other agency partners to evaluate potential impacts to archaeological, historic, and architectural resources. NRCS provided an initial request for Section 106 consultation to the MI State Historic Preservation Office (SHPO) in 2018. 

In March of 2021 it was determined that the four low-head dams were eligible for listing on the National Register of Historic Places. Because the project requires removal of all four low-head dams, the project does not allow for avoidance or minimization of adverse impacts to these structures and the impacts to the dams must be mitigated. 

NRCS, The City of Grand Rapids, and GRWW worked together to develop an appropriate mitigation plan to document the historic role of these structures in the city’s history. The proposed mitigation measures were presented during a NRCS Public Comment period in November of 2021 and a Memorandum of Agreement between the City, GVMC, GRWW, NRCS, and MI-SHPO, is currently being reviewed by the agencies as a formal mechanism to ensure that the mitigation measures are followed during construction of the project and removal of the low-head dams.