Issue 1: The Future of the Light Stations

It is often noted that the prominent authority on lighthouse history, Francis Ross Holland, Jr. remarked,  "Within the boundaries of the Apostle Islands National Lakeshore is the largest and finest single collection of lighthouses in the country."

The National Park Service, meanwhile, is proud to claim the  mantle of "the nation's premier federal historic preservation agency.”

With that in mind, it would be reasonable to expect that the Apostle Islands National Lakeshore would be found at the forefront of lighthouse preservation in the U.S. Unfortunately, the options presented here would fall far short of that standard. Moreover, the commitment expressed to preservation of the historic lights is disconcertingly tepid. The “given”  statement is  peppered with qualifiers: "The National Park Service would not purposely let the light towers significantly deteriorate or fall down."

Additionally, this document attempts to draw a spurious distinction between the light towers and the historic light stations of which they are one element. To apply one standard of preservation to the highly visible towers and another to the less prominent, but equally significant, elements of a National Register-listed property flies in the face not only of sound historic preservation practice, but also of the National Historic Preservation Act of 1966. Allowing all but the most noticeable features of the light stations to “slowly deteriorate” would adversely impact the entire property’s integrity of material, workmanship, setting, feeling, and association, and would not be permissible without consultation with the State Historic Preservation Officer and implementation of mutually agreed-upon mitigation measures.

Nineteenth-century lighthouse keepers' dwellings at
Devils Island: to "slowly deteriorate?"

Moreover, NPS 28, the agency’s Cultural Resource Management Guideline, directs that:

“…all historic structures in which the Service has a legal interest are to be managed as cultural resources. Regardless of type, level of significance, or current function, every structure is to receive full consideration for its historical values whenever a decision is made that might affect its integrity. (Chapter 8, A-2; emphasis added)

Additional refutation of this false dichotomy can be found through examination of Public Law 106-355, the National Historic Lighthouse Preservation Act of 2000. (NHLP)This act, while not specifically binding on the managers of Apostle Islands National Lakeshore, provides the most recent guidance as to the wishes of Congress concerning the nation's historic lighthouses.

The NHLP established a “national historic light station program,” to be administered, it should be noted,  by the National Park Service itself. The Act  provides a system for entrusting historic lighthouses to agencies and organizations willing to maintain and preserve them, requiring that:

• The eligible entity to which the historic light station is conveyed under this section shall, at its own cost and expense, use and maintain the historic light station in accordance with this Act, the Secretary of the Interior's Standards for the Treatment of Historic Properties, ( SEC. 308. D)

• The eligible entity to which the historic light station is conveyed under this section shall make the historic light station available for education, park, recreation, cultural or historic preservation purposes for the general public at reasonable times and under reasonable conditions; (SEC. 308. E)

The NHLP makes absolutely no distinction in the treatment required between the light tower and the other components of the light station:

Definitions. For purposes of this section… (2) Historic light station.--The term `historic light station' includes the light tower, lighthouse, keepers dwelling, garages, storage sheds, oil house, fog signal building, boat house, barn, pumphouse, tramhouse, support structures, piers,  walkways, underlying and appurtenant land and related real property and improvements associated therewith; provided that the `historic light station' shall be included in or eligible for inclusion in the National Register of Historic Places.

It is both patently clear, and sadly ironic, that if the Options For Future Management were presented by a local government agency or private non-profit, the National Park Service would rule the Lakeshore unsuitable to manage a historic light station under the terms of the National Historic Lighthouse Preservation Act.

Interior of the 1856 lighthouse on Michigan Island:
to "deteriorate slowly" from here?

In specific, Option 1 admits that : "There would be no major improvements in the facilities or their uses, and there could be some slow deterioration of the facilities” (emphasis added).

To appreciate the import of that admission, it is only necessary to refer back a few paragraphs to the document’s assessment of current conditions:

Natural weathering and erosional processes have resulted in deterioration of the light stations and associated resources, threatening the long-term integrity of these properties…. Vegetation is encroaching into formerly cleared areas around many of the light stations, contributing to the loss of some of the cultural landscape as well as the buildup of fire fuels. As a result, wildland fire poses an increased risk to the light stations...

Any option which posits further deterioration from this baseline is unacceptable.

Similarly, Option 2 states that,

Only the most important elements of the other stations [beside Raspberry Island] would be stabilized. There could be some deterioration of some facilities in the five other light stations (emphasis added).

In the harsh environment of the Lake Superior shoreline, catastrophic deterioration of an unstabilized structure is not a matter of could, but will.

Option 3 seems somewhat less Draconian on first glimpse, but it, too, contains worrisome concepts, especially those expressed in the passage explaining that priorities for preservation would be established, “Based on historic significance, cost-efficiency, and other criteria.” Absent a more specific explanation of those “other criteria,” it is impossible to assess the full implications of this option; moreover, there is nothing in any of the guiding statutes cited above that that offer the NPS an option of preserving only that which is “cost efficient.”

It is difficult to view this option in any way that does not predict the sacrifice of substantial portions of the park’s historic patrimony.

Finally, it is not possible to comment on the very sparsely-presented Option 4 in a meaningful way.

Continue to Issue 2: The Future of the Life Estates and the Expired Use and Occupancy Properties

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The Document Under Review

Options For Future Management
(PDF format; 2.8 Mb)