Appendix E-1

11/17/2010 Letter from NTIA to SHPO/DAHP

introducing Round II project

Appendix E-2

11/22/2010 Letter from SHPO/DAHP to NTIA

concurring with the APE

STATE OF WASHINGTON

DEPARTMENT OF ARCHAEOLOGY & HISTORIC PRESERVATION 1063 S. Capitol Way, Suite 106 � Olympia, Washington 98501

Mailing address: PO Box 48343 � Olympia, Washington 98504-8343 (360) 586-3065 � Fax Number (360) 586-3067 � Website: www.dahp.wa.gov

November 22, 2010

Ms. Jill Dowling

Department of Commerce

NTIA

Washington, D. C. 20230

Re: Grantee # 5376 NoaNet Broadband Initiatives Project

Log No.: 112210-37-DOC

Dear Ms. Dowling:

Thank you for contacting our department. We have reviewed the materials you provided for the proposed

NoaNET Broadband Initiatives Project for approximate 511 miles of fiber optic facilities in 25 of 39

Counties in Washington.

We concur with the proposed Area of Potential Effect (APE). We look forward to further consultation

regarding the proposed project and your approach for addressing the cultural resources identification,

evaluations and treatment plans for the Broadband facilities.

We would also appreciate receiving any correspondence or comments from concerned tribes or other

parties that you receive as you consult under the requirements of 36CFR800.4(a)(4).

These comments are based on the information available at the time of this review and on behalf of the

State Historic Preservation Officer in compliance with the Section 106 of the National Historic

Preservation Act, as amended, and its implementing regulations 36CFR800.4. Should additional

information become available, our assessment may be revised, including information regarding historic

properties that have not yet been identified. Thank you for the opportunity to comment and we look

forward to further information.

Sincerely,

Robert G. Whitlam, Ph.D.

State Archaeologist

(360)586-3080

email: rob.whitlam@dahp.wa.gov

 

Appendix E-3

11/26/2010 Letter from NTIA to NoaNet

Regarding TCNS

Date: 11/26/2010Reference Number:

UNITED STATES DEPARTMENT OF COMMERCENational Telecommunications and Information Administration

Washington, DC 20230

Dear Sir or Madam:

The National Telecommunications and Information Administration (NTIA) is using a modified version of the Federal Communications Commission�s (FCC) Tower Construction Notification System (TCNS) as a means of expediting its Broadband Technology Opportunities Program (BTOP), part of President Obama�s American Recovery and Reinvestment Act of 2009 (ARRA). This notice is to inform you that the following authorized parties were sent information about the application that you submitted to BTOP.

Those authorized parties who have received the information about your BTOP application include leaders of federally-recognized American Indian Tribes, including Alaska Native villages (collectively �Tribes�), or their designees, Native Hawaiian Organizations (NHOs), and State Historic Preservation Officers (SHPOs). For your convenience in identifying the referenced Tribes and in making further contacts, the City and State of the Seat of Government for each Tribe and NHO, as well as the designated contact person is included in the list below. NTIA notes that Tribes might attach religious and cultural significance to historic properties located in their ancestral homelands or other areas far removed from their current Seat of Government.

The information you provided was forwarded to the following Tribes and NHOs who have set their geographic preferences on TCNS.

NORTHWEST OPEN ACCESS NETWORKDAVE SPENCER H.C. HOOVER BUILDING, ROOM 10361401 CONSTITUTION AVENUE, NWWASHINGTON, DC 20230

NOTICE OF ORGANIZATION(S) WHICH WERE SENT PROPOSED BROADBAND PROJECT NOTIFICATION INFORMATION

1. Tribal Archaeologist - Laura Murphy - Muckleshoot Indian Tribe - Auburn, WA - electronic mailDetails: The Muckleshoot Tribe requests that a street map be provided with each TCNS notification. The Muckleshoot Tribe is only interested in reviewing proposed sites in King, Pierce and Snohomish Counties in the State of Washington.

2. Deputy THPO - Kelly Easter - Lummi Nation - Bellingham, WA - electronic mail

3. Planning Director - Jeff Hertz - Nooksack Indian Tribal Council - Deming, WA - electronic mail

4. Cultural Resources Director - Marie Hebert - Port Gamble S'Klallam Tribe - Kingston, WA - electronic mail

Page 1 of 5

5. Cultural Resources Program Manager - Jacquelyn C Ferry - Samish Indian Nation - Anacortes, WA - electronic mailDetails: The Samish Indian Nation is not interested in participating on projects in areas that are previously disturbed to the depth of proposed disturbance.

To complete consultation, the Samish Indian Tribe requests a copy of the archaeological survey report. If not supplied within the report, the Tribe also requests a topographic map of the project area, location information (e.g., UTMs, latitude/longitude), details of the proposed tower (e.g., height, type), and photographs of the project area. Emailed documents are welcome (jferry@samishtribe.nsn.us).

The Samish Indian Nation does not subscribe to the thirty-day comment period policy. Consistent with Section IX of the Nationwide Programmatic Agreement and applicable law, the Tribe requires notification in the event archaeological properties or human remains are discovered during construction.

Thank you.

6. Chairwoman - Gloria Green - Sauk Suiattle Indian Tribe - Darrington, WA - electronic mailDetails: If the Applicant/tower builder receives no response from the Sauk-Suiattle Indian Tribe within 30 days after notification through TCNS, the Sauk-Suiattle Indian Tribe has no interest in participating in pre-construction review for the proposed site. TheApplicant/tower builder, however, must notify the Sauk-Suiattle Indian Tribe in the event archaeological properties or human remains are discovered during construction, consistent with Section IX of the Nationwide Programmatic Agreement and applicable law.

7. Chairman - Shawn E Yanity - Stillaguamish Tribe - Arlington, WA - electronic mail

8. Archaeologist - Dennis E Lewarch - Suquamish Tribe - Suquamish, WA - electronic mail

9. THPO - Larry W Campbell Sr - Swinomish Indian Tribal Community - La Conner, WA - electronic mail

10. Data Services Assistant Director - Greg Keith - Tulalip Tribes of the Tulalip Reservation - Tulalip, WA - electronic mailDetails: If the Applicant receives no response from the Tulalip Tribe within 30 days after notification through TCNS, the Tulalip Tribe has no interest in participating in pre-construction review for the site. The Applicant, however, must notify the Tulalip Tribe in the event archeological properties or human remains are discovered during construction, consistent with Section IX of the Nationwide Programmatic Agreement and applicable law.

11. Cultural Policy Representative - Scott Schuyler - Upper Skagit Indian Tribe - Sedro Woolley, WA - electronic mail

12. Director of Planning and Development - Wallis D Hubbard - Kalispel Tribe of Indians - Usk, WA - electronic mail

13. Cultural Resources Director - Johnson Meninick - Yakama Nation - Toppenish, WA - electronic mailDetails: If the Applicant/tower builder receives no response from the Yakama Nation within 30 days after notification through TCNS, the Yakama Nation has no interest in participating in pre-construction review for the proposed site. The Applicant/tower builder, however, must IMMEDIATELY notify the Yakama Nation in the event archaeological properties or human remains are discovered during construction, consistent with Section IX of the Nationwide Programmatic Agreement and applicable law.

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14. THPO/ Archaeologist - Patrick Baird - Nez Perce Tribe - Lapwai, ID - electronic mail

If the applicant/tower builder receives no response from the Nez Perce Tribe within 30 days after notification through TCNS, the Nez Perce Tribe has no interest in participating in pre-construction review for the proposed site. The Applicant/tower builder, however, must immediately notify the Nez Perce Tribe in the event archaeological properties or human remains are discovered during construction, consistent with Section IX of the Nationwide Programmatic Agreement and applicable law.

15. THPO - Jill M Wagner PhD - Coeur d'Alene Tribal Council - Plummer, ID - electronic mail

16. Executive Director - Alexis Berry - Hoh Tribe - Forks, WA - electronic mail

17. Cultural Resources Officer - Kathy Duncan - Jamestown S'Klallam Tribe - Sequim, WA - electronic mail

18. IT Manager - Gene Terry - Quinault Indian Nation - Taholah, WA - electronic mail

19. Environmental Planning Manager - Karen Suyama - Snoqualmie Tribal Organization - Snoqualmie, WA - electronic mail

If the applicant/tower builder receives no response from the Snoqualmie Tribal Organization within 30 days after notification through TCNS, the Snoqualmie Tribal Organization has no interest in participating in pre-construction review for the proposed site. The Applicant/tower builder, however, must immediately notify the Snoqualmie Tribal Organization in the event archaeological properties or human remains are discovered during construction, consistent with Section IX of the Nationwide Programmatic Agreement and applicable law.

20. Assistant Director - Cultural Resources - Edwin Arthur - Cowlitz Indian Tribe - Longview, WA - electronic mailDetails: If the Applicant receives no response from the Cowlitz Indian Tribe within 30 days after notification through TCNS, the Cowlitz Indian Tribe has no interest in participating in pre-construction review for the site. The Applicant, however, must notify the Cowlitz Indian Tribe in the event archaeological properties or human remains are discovered during construction.

21. Tribal Historic Preservation Officer - Camille Pleasants - Confederated Tribes of the Colville Reservation - Nespelem, WA - electronic mail

22. THPO and Director - Janine Bowechop - Makah Tribe - Neah Bay, WA - electronic mail

23. Tribal Compliance Manager - Clarinda Burke - Confederated Salish and Kootenai Tribes of the Flathead Nation - Pablo, MT - electronic mailDetails: If the Applicant/tower constructor receives no response from the Confederated Salish and Kootenai Tribes of the Flathead Nation within 30 days after notification through TCNS, the Confederated Salish and Kootenai Tribes of the Flathead Nation has no interest in participating in pre-construction review for the site. The applicant/tower builder, however, must IMMEDIATELY notify the Confederated Salish and Kootenai Tribes of the Flathead Nation in the event archaeological properties or human remains are discovered during construction, consistent with Section IX of the Nationwide Programmatic Agreement and applicable law.

24. THPO - Kris Miller - Skokomish Indian Tribe - Skokomish Nation, WA - electronic mail

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25. THPO - Randy Abrahamson - Spokane Tribe of Indians - Wellpinit, WA - electronic mailDetails: The Spokane Tribe of Indians REQUIRES the township range and section for each proposed project. We are unable to make a determination until we have received this information. Please provide the township range and section for the proposed project in an attachment when you first submit your tower notification to TCNS, or e-mail this information to me separately. If e-mailed separately, please provide the TCNS number in the subject line of your e-mail. Thank you.Randy Abrahamson, THPOSpokane Tribeof Indiansrandya@spokanetribe.com

26. Cultural Resources Manager - Teara Farrow Ferman - Confederated Tribes of the Umatilla Indian Reservation - Pendleton, OR - electronic mail

The information you provided was also forwarded to the additional Tribes and NHOs listed below. These Tribes and NHOs have NOT set their geographic preferences on TCNS Broadband, and therefore they are currently receiving tower notifications for the entire United States.

The information you provided was also forwarded to the following SHPOs in the state in which you propose to construct and neighboring states. The information was provided to these SHPOs as a courtesy for their information and planning.

27. SHPO - Allyson Brooks - Office of Archeology & Historic Preservation - Olympia, WA - electronic mail

28. Deputy SHPO - Greg Griffith - Office of Archeology & Historic Preservation - Olympia, WA - electronic mail

Please be advised that the NTIA cannot guarantee that the contact(s) listed above opened and reviewed an electronic or regular mail notification. NTIA will contact you shortly to identify the next steps required for completing review under Section 106 of the National Historic Preservation Act, 16 U.S.C. § 470f and its implementing regulations (36 CFR Part 800).

The following information relating to the proposed project was forwarded to the person(s) listed above:

Notification Received: 11/18/2010

Notification ID: 70922Project Number: 5376Applicant: Northwest Open Access NetworkApplicant Contact: Dave Spencer

Project Type(s): Multiple Project Components

Region(s) affected (State, County): WASHINGTON, ADAMS WASHINGTON, BENTON WASHINGTON, CLARK WASHINGTON, FERRY WASHINGTON, FRANKLIN WASHINGTON, JEFFERSON WASHINGTON, KITSAP WASHINGTON, KITTITAS WASHINGTON, LINCOLN WASHINGTON, OKANOGAN WASHINGTON, PEND OREILLE WASHINGTON, SKAGIT WASHINGTON, SKAMANIA WASHINGTON, SNOHOMISH WASHINGTON, SPOKANE WASHINGTON, STEVENS WASHINGTON, WALLA WALLA WASHINGTON, WHATCOM

Page 4 of 5

WASHINGTON, YAKIMA

Address or Geographical Location Description: Project takes place in Washington State; please see attached map for more information.

If you have any questions or comments regarding the content of this notice, please contact NTIA at btoptcns@ntia.doc.gov or the following:

Frank Monteferrante, Ph.D.Environmental Compliance SpecialistBroadband Technology Opportunities ProgramH.C. Hoover Building, Room 422814th St. and Constitution Avenue, NWWashington, D.C. 20230Telephone: (202) 482-1303Fax: (202) 501-8009Electronic Mail: btoptcns@ntia.doc.gov

Page 5 of 5

 

Appendix E-4

2/14/11 Letter from Tierra to NTIA summarizing

Round 2 with Treatment Plan Template

Ran dye K . Fe r r i ck , Pr e s i den t & B r oke r 1575 E as t R iver Roa d , Su i te 201 ● Tucson , Ar izona 85718 ● 520 .319 .2106 ● Fax : 520 .323 .3326

R i g h t o f W a y ● C u l t u r a l R e s o u r c e s ● E n v i r o n m e n t a l P l a n n i n g

F e d e r a l , S t a t e , a n d L o c a l P e r m i t t i n g ● G I S / C A D M a p p i n g

w w w . t i e r r a - r o w . c o m

February 14, 2011 Frank J. Monteferrante, Ph.D. NEPA Environmental Specialist Broadband Technology Grant Program 1401 Constitution Avenue, N.W., Suite 4228 Washington, D.C. 20230 RE: Cultural Resources Recommendations for NoaNet’s Washington Rural Access Project (WRAP) (Round II) Dear Frank, Tierra Right of Way Services (Tierra) has recently completed the cultural resources reports for the WRAP II and submitted them to your office for review and transmittal to the Washington State Historic Preservation Office (SHPO). The routes for this project are NC-1, 2, and 3; NE-1, 2, and 3; NW-1A, 2, and 3; and SC-2A, 5, and 6. These have been grouped into 4 reports: NC, NE, NW, and SC. This letter summarizes the findings of the reports and discusses Tierra’s recommendations regarding effects on cultural resources and historic properties for each route. Each route is discussed individually below, and the number of potentially impacted archaeological sites, historic properties, and cemeteries within the area of potential effect (APE) are listed for each route. Table 1 lists the routes for which we recommend no further work. However, if cultural resources are encountered during construction within any of these routes, we recommend that the communication, consultation, and discovery plan outlined in the approved Treatment Plan template be strictly adhered to. Table 2 lists the routes which contain areas of cultural significance or sensitivity, or where sites are known to exist in the vicinity of buried portions of the route. Maps detailing these areas are available in the full Tierra reports. With very few exceptions, this project is to take place within previously disturbed, existing road rights-of-way. Although the overall project goal is to avoid all sites of cultural and historic significance, for routes where underground construction is planned and significant sites are believed to be in proximity of the planned route (Table 2), we recommend the following:

a Historic Properties Treatment Plan be developed in consultation with the National Telecommunications and Information Administration (NTIA), SHPO, and any concerned tribes (a template for this plan has already been developed and approved by the NTIA and Washington SHPO);

monitoring or other treatment prior to, or during, ground disturbance in these areas; and

a subsequent monitoring/archaeological report be written and submitted to the NTIA and SHPO. If these recommendations are carried out, our recommendation for this project is one of No Adverse Effect to Cultural Resources.

The fiber for this project will be installed aerially in some areas and buried in others. Aerial portions of the fiber will be installed on existing poles, and are therefore exempt from the 106 process, per the established Programmatic Agreement between the NTIA, Rural Utilities Service (RUS), and others. General Avoidance and Mitigation Measures The general approach for this project will be to avoid archaeological sites, when possible, by locating underground cable to avoid potential sites of significance. An alternative is to install aerial cable in the vicinity of sites rather than burying the cable, while ensuring that the installation vehicles remain on the shoulder of the road while installing aerial cable in the vicinity of sites that extend into the right-of-way. If avoidance of an archaeological or historic site by route adjustments or aerial installation is not possible, we recommend site reconnaissance (to include site relocation, site form and map updates, and National Register of Historic Places [NRHP] eligibility status) and/or monitoring in culturally sensitive areas. As discussed above, monitoring plans for the recommended routes will be developed in consultation with SHPO and any concerned tribes prior to construction. All fieldwork will be conducted by a State of Washington–permitted archaeologist. For cemeteries, we recommend site flagging and/or monitoring for those with boundaries near the APE. Some of these cemeteries date prior to the 20th century, and their original boundaries may not be in line with those delineated today. During site reconnaissance, the archaeologist will evaluate the proximity of the cemetery and determine if monitoring during construction is necessary. Records of flagging and/or results of monitoring will be included in the final monitoring report. For historic properties and districts, there will be no visual impacts whether the line is to be buried or placed aerially, as the aerial placement will use existing poles with existing lines, and buried cable will not be visible. The buildings and contributing properties to historic districts are outside of the road right-of-way (where the majority of placement is taking place), and so will not be directly impacted. Our recommendation for these properties would be to discontinue use of high-vibration construction equipment while in the vicinity of historic properties whose structural integrity is questionable.

If you have any questions or need anything further, please do not hesitate to contact me at (520) 319-2106 or bmontgomery@tierra-row.com. Sincerely,

Barbara K. Montgomery, Ph.D. Principal Investigator, Cultural Resources Division

Recommendations Table 1. Routes of Minimal Concern (full details of each route are discussed in the Tierra reports dated 2011)

Route Buried/

Aerial/Wireless Sites

Historic Properties

Register District

Register Properties

Cemeteries Recommendation

NC-1 Buried and Aerial 0 0 0 0 1 No Effect—The cemetery is within an aerial

portion of the route and will not be impacted.

NW-3 Aerial 0 7 0 0 4 No Effect—The historic properties and cemeteries

are within aerial portions of the route and are therefore exempt.

Table 2. Routes for Which We Recommend Further Treatment (full details of each route are discussed in the Tierra reports dated 2011)

Route Buried or

Aerial Sites

Historic Properties

Register District

Register Properties

Cemeteries Recommendation

NC-2 Buried and

Aerial 0 6 0 1 1

No Adverse Effect—The cemetery is within an aerial portion and will therefore not be impacted. In our opinion, historic structures and register property will not be impacted by adjacent plow insertion of fiber cable, and we recommend only discontinued use of high-vibration construction equipment when working in the vicinity of structures whose integrity is in question.

NC-3 Buried and

Aerial 1 14 1 1 1

No Adverse Effect—The register district is within an aerial portion of the route and is therefore exempt. The archaeological site and cemetery are also within aerial portions and will therefore not be impacted. In our opinion, historic structures and register property will not be impacted by adjacent plow insertion of fiber cable, and we recommend only discontinued use of high-vibration construction equipment when working in the vicinity of structures whose integrity is in question.

Route Buried or

Aerial Sites

Historic Properties

Register District

Register Properties

Cemeteries Recommendation

NE-1 Buried and

Aerial 28 28 0 9 9

No Adverse Effect—We recommend development of a treatment plan to include reconnaissance of the archaeological sites, monitoring specifications (if warranted), and procedures for avoidance of cemeteries during construction. In our opinion, historic structures will not be impacted by adjacent plow insertion of fiber cable, and we recommend only discontinued use of high-vibration construction equipment when working in the vicinity of structures whose integrity is in question.

NE-2 Buried and

Aerial 27 3 0 0 2

No Adverse Effect—The archaeological sites and historic properties are within aerial portions of the route and are therefore exempt. We recommend development of a treatment plan to include procedures for avoidance of the cemeteries during construction. In our opinion, historic structures will not be impacted by adjacent plow insertion of fiber cable, and we recommend only discontinued use of high-vibration construction equipment when working in the vicinity of the four structures whose integrity is in question.

NE-3 Wireless to be

determined to be

determined to be

determined to be

determined to be

determined

No Adverse Effect—This route is comprised of 13 microwave towers. Any potential effects to cultural properties will be mitigated following the requirements of the Federal Communications Commission Nationwide Programmatic Agreement.

NW-1A Wireless to be

determined to be

determined to be

determined to be

determined to be

determined

No Adverse Effect—This route is comprised of 44 collocations on existing cell towers with no new construction. Any potential effects of construction will be mitigated by following the requirements outlined in the Federal Communications Commission Nationwide Programmatic Agreement.

Route Buried or

Aerial Sites

Historic Properties

Register District

Register Properties

Cemeteries Recommendation

NW-2 Buried/ Aerial/ Wireless

5 10 2 9 4

No Adverse Effect—We recommend development of a treatment plan to include reconnaissance of the archaeological sites, monitoring specifications (if warranted), and procedures for avoidance of cemeteries during construction. In our opinion, historic structures will not be impacted by adjacent plow insertion of fiber cable, and we recommend only discontinued use of high-vibration construction equipment when working in the vicinity of structures whose integrity is in question. Also, planned collocations on 44 existing cell towers, and the construction of one new cell tower and three maintenance structures, will be mitigated by following the requirements outlined in the Federal Communications Commission Nationwide Programmatic Agreement.

SC-2A Buried and

Aerial 10 9 0 1 1

No Adverse Effect—We recommend development of a treatment plan to include reconnaissance of the archaeological site within a buried portion of the line and monitoring specifications, if warranted. The historic properties and cemeteries are within aerial portions of the route and are therefore exempt

SC-5 Buried and

Aerial 10 32 0 5 2

No Adverse Effect—The register properties and cemeteries are in aerial portions of the route and are therefore exempt. We recommend development of a treatment plan to include reconnaissance of the archaeological sites and monitoring specifications, if warranted. In our opinion, historic structures will not be impacted by adjacent plow insertion of fiber cable, and we recommend only discontinued use of high-vibration construction equipment when working in the vicinity of structures whose integrity is in question.

Route Buried or

Aerial Sites

Historic Properties

Register District

Register Properties

Cemeteries Recommendation

SC-6 Buried and

Aerial 24 3 0 0 1

No Adverse Effect— We recommend development of a treatment plan to include reconnaissance of the archaeological sites, monitoring specifications if warranted, and procedures for avoidance of cemeteries during construction. The historic properties are within aerial portions of the route and are therefore exempt.

Draft Historic Properties Treatment Plan for Round II of the Washington Rural Access Project Prepared by: Jennifer Hushour, MSc., RPA Barbara Montgomery, PhD. Tierra Right of Way Services, Ltd. Prepared for: Frank J. Monteferrante, Ph.D. NEPA Environmental Specialist Broadband Technology Grant Program 1401 Constitution Avenue, N.W., Suite 4228 Washington, D.C. 20230 February 14, 2011

ii

TABLE OF CONTENTS Introduction ........................................................................................................................................................ 1 Communication Plan ......................................................................................................................................... 2 Construction Methods ...................................................................................................................................... 4 Procedures for the Inadvertent Discovery of Cultural Resources .............................................................. 5 Special Procedures for the Discovery of Human Skeletal Material ............................................................ 6 Proceeding with Construction ......................................................................................................................... 6 Cultural Resources Monitoring and Discovery Plan .................................................................................... 7 Documentation and Reporting ........................................................................................................................ 8 

LIST OF FIGURES Figure 1. Washington Rural Access Project Area ......................................................................................... 9 

APPENDICES Appendix A. Cultural Resources Summary Letter .................................................................................... A.1

1

INTRODUCTION This draft historic properties treatment plan discusses the measures that will be undertaken to identify further cultural resources prior to construction and to address any cultural resources encountered during construction of the Washington Rural Access Project (WRAP) Round II. The WRAP Round II is a project for installation of 490 miles of fiber optic cable and electronics to provide high capacity broadband access to rural areas throughout Washington. The overall project area is depicted in Figure 1. This document is meant to be a template with which to develop individual plans specific to different portions of the project (see discussion below). Pursuant to a federal stimulus grant received as part of the Broadband Technology Opportunities Program (BTOP) by the National Telecommunications and Information Administration (NTIA), Northwest Open Access Network (NoaNet) will coordinate the construction of fiber optic infrastructure in rural areas Washington State. As this is a federally funded project, it is considered an undertaking under Section 106 of the National Historic Preservation Act (NHPA) as defined in 36 CFR part 800. The purpose of this document is to comply with Section 106 process, ensure that no cultural resources are adversely impacted during the course of this project, and outline general procedures to follow during this project from pre- to post-construction. As the lead federal agency, the NTIA instructed NoaNet to conduct a records check of known archaeological and historic cultural properties within the project area for inclusion in the Environmental Assessment (EA). This research (conducted by Tierra Right of Way Services, Ltd. [Tierra]) resulted in 4 regional route reports representing the 12 individual WRAP Round II routes (Tierra Archaeological Report Nos. 2011-15, 17, 18 by Barbara K. Montgomery and Chance Copperstone and 2011-16 by Barbara K. Montgomery and April Whitaker). Subsequent to the records check, a summary of recommendations regarding the potential effects of the current undertaking on cultural resources was provided to NTIA and the Washington SHPO (Appendix A). This communication included a discussion of which routes had sensitive cultural areas which would require further consideration and which did not. It was Tierra’s recommendation that through a combination of avoidance and monitoring, this project will have No Adverse Effect on cultural resources within the Area of Potential Effect (APE). Once final staking is completed, NoaNet’s archaeological consultant(s) will determine further necessary steps to identify cultural resources in the APE; visit the sensitive cultural areas, sites, and properties that were identified within the APE during the records review (see attached summary letter) to perform site reconnaissance and further determine which sites/properties will and will not be impacted, which of the impacted sites can be avoided (through boring, re-staking, or use of aerial cable) and which areas will require additional monitoring. NoaNet will retain additional archaeological subconsultants, permitted in the state of Washington, to conduct fieldwork and author reports. Tierra will still be the lead archaeological consultant for continuity and consistency of communication and project information. This document is to be used as a template with which to craft each individual monitoring plan, specific to each route that requires further cultural resources work and/or monitoring. These individual route monitoring plans will be developed in consultation with NTIA, the Washington Department of Archaeology and Historic Preservation (DAHP), and any other consulting parties or

2

tribes for the route in question. Each individual plan will discuss the identified resources specific to each route, identify the necessary consulting parties and tribes, contain communication protocol for each party, and will follow the general guidelines outlined below. Copies of the individual monitoring plans for each route will be provided to all consulting parties and tribes prior to the start of construction. In cases of further Tribal Consultation, NTIA will be responsible for transmitting these documents to the concerned tribes. Tribes may request that their own monitors be present during construction, and this will be coordinated with NoaNet’s archaeological project manager. Once fieldwork is completed, results of all avoidance and monitoring activities will be documented (as outlined below) and report(s) will be provided to the NTIA, Washington SHPO, NoaNet, and other Tribes and consulting parties. All archaeological supervisory staff during the fieldwork and report writing processes will be permitted by DAHP to conduct work within the State of Washington.

COMMUNICATION PLAN The following are general guidelines for communication regarding cultural resources for this project identified in August of 2010: NTIA is the lead agency. All official communication between NoaNet (the BTOP grantee); CHR, PACE Engineers, Tierra, or other subconsultants retained by NoaNet with the Washington SHPO, Tribes, or other consulting parties will be coordinated through the NTIA. The main point of contact for cultural resources matters associated with this project is Jennifer Hushour, MSc., RPA (Archaeological Project Manager) or Barbara K. Montgomery, Ph.D. (Archaeological Principal Investigator). During the fieldwork phases of the project, it may be necessary for the archaeological consultant to contact the SHPO, tribes, the coroner’s office regarding unanticipated discovery situations. All such occurrences will also be communicated to NoaNet and the NTIA within 24 hours. If a secondary archaeological contractor is on site during a discovery situation, they will contact the construction manager and the Archaeological Project Manager (Jennifer Hushour or her designee), who will then make the necessary communications outlined above. Project contact information (additional contact information for additional consulting parties will be added to the individual monitoring plans as needed): Jill Dowling (Reviewer for NTIA) Federal Preservation Officer U.S. Department of Commerce H.C. Hoover Bldg. Room 1036 1401 Constitution Avenue, NW Washington DC 20230 Email: jdowling@doc.gov Tel: 202.482.4456 Fax: 202.501.8009

3

Frank J. Monteferrante, Ph.D. (NTIA reviewer) Environmental Compliance Specialist U.S. Department of Commerce H.C. Hoover Bldg. Room 1036 1401 Constitution Avenue, NW Washington, DC 20230 Email: FMonteferrante@ntia.doc.gov Tel: 202.482.4208 Fax: 202.501.8009 Rob Whitlam, Ph.D. (DAHP) State Archaeologist Washington Department of Archaeology and Historic Preservation 1063 South Capitol Way, Suite 106 Olympia WA 98501 Email: Rob.Whitlam@DAHP.WA.GOV Tel: 360.586.3065 Fax: 360.586.3067 Rob Kopp (NoaNet) Chief Technology Officer (Grantee representative) 10205 Gabica St Middleton, ID 83644 Email: rkopp@noanet.net Tel: 208.863.5346 (cell) Fax: 509.352.9231 Susan E. Boyd (Environmental Assessment Lead) Vice President PACE Engineers, Inc. 1601 Second Avenue, Suite 1000 Seattle, WA 98101 Email: sboyd@paceengrs.com Tel: 206.441.1855 Fax: 206.448.7167 Jennifer Hushour, MSc., RPA (Archaeological Project Manager) Tierra Right of Way Services, Ltd. 1575 E. River Road, Suite 201 Tucson, AZ 85718 Email: jhushour@tierra-row.com Tel: 520.305.1264 Fax: 520.323.3326

4

Barbara K. Montgomery, Ph.D. (Archaeological Principal Investigator) Tierra Right of Way Services, Ltd. 1575 E. River Road, Suite 201 Tucson, AZ 85718 Email: bmontgomery@tierra-row.com Tel: 520.319.2106 Fax: 520.323.3326 Peter Rasmusson (Project Manager - Engineering and Construction) CHR Solutions SVP, Engineering Field Services 1515 N. Sanborn Blvd. Mitchell, SD 57301 Email: peter.rasmusson@chrsolutions.com Tel: 605.995.6831 Cell: 605.999.6278 Fax: 605.995.2577

CONSTRUCTION METHODS The fiber optic line will be installed either aerially on existing poles or buried within predisturbed rights-of-way. The details regarding which type of installation to be used for each route are discussed in the Environmental Assessment and individual Tierra reports; and will be reiterated in the pre-construction monitoring addenda to this report. The method of ground disturbance which will be used is known as plow insertion, a minimally invasive technique employed to install cable quickly, efficiently and with limited disturbance of the environment. A typical plowing blade, which is not more than 2-3” in width, acts like a knife during plowing and cable installation and disturbs very little soil. The depth of cable will be similar to other telecommunication lines in place, at a minimum of 36 inches below the ground surface and a maximum of 42 inches. In limited instances, boring will be required for avoidance of environmental impact or to install cable in the vicinity of other infrastructure. In general terms, the range of impact of a typical underground plow construction site would be 20’ to 40’ wide. The plow equipment used range from 8’-12’ wide. The plow slot is created in the center of these machines by the mechanical arms. When the plowing is performed, the ground is disturbed to place the conduit to the proper depth, and then the plow slot is backfilled and compacted as close as possible to its original condition. When the boring method is used, the impact is minimal along the route due to the “drilling” under the surface of the ground. Where the bore machine is placed to drill, the impact is about 15’ wide. During the underground construction process all equipment is parked in areas that have little or no impact, such as the shoulder of the roadway. Where aerial placement on existing poles happens the impact would be very minimal. The boom trucks are 10’ wide and are driven down the shoulder of the road during cable placement. Sometimes if the pole is out of reach and the terrain is such that it allows the truck to be driven to it,

5

this will happen assuming no known resources have been identified in the area (all of which will have been previously marked). The procedures put forth herein are typical and provide a baseline for areas of the WRAP Round II that have been identified as requiring additional monitoring during construction. It is important to note that areas of historic and cultural significance will be considered in project staking and final project layout, with the goal of avoidance and therefore, no effects. However, it is anticipated that in certain areas, on-site monitoring will be required in accordance with the requirements of the SHPO and local tribal archaeologists. In these cases, the Grantee will retain the services of an archaeological contractor, licensed in the State of Washington, who will provide staff to monitor ground disturbance in sensitive areas and educate the General Contractor and Construction Manager on the precautions and procedures to be employed and monitor onsite activities in accordance with all established requirements.

PROCEDURES FOR THE INADVERTENT DISCOVERY OF CULTURAL RESOURCES This section identifies the key responsibilities in the event of a discovery of an item of potential cultural significance during the WRAP Round II. In the event of a discovery, the archaeological monitor shall make its best efforts, in accordance with state and federal law, to ensure that its employees and contractors keep the discovery of any found or suspected human remains, other cultural items, or potential historic properties confidential. To the extent permitted by law, prior to any release of information, DAHP, Tierra, other archaeological contractors or subcontractors, and the other consulting parties shall concur on the amount of information, if any, to be released to the public, any third party, and the media and the procedures for such a release. In the unanticipated event of a discovery, the following steps shall be taken: Step 1: Stop Work. If any agency employee, contractor, or subcontractor believes that he or she has uncovered any cultural resource at any point in the project, all work adjacent to the discovery will be stopped. The discovery location will not be left unsecured at any time. The individual making the discovery will immediately contact the Construction Manager and notify him or her of the situation. Step 2: Notify Monitor. Immediately following the work stoppage and notification of construction management and/or site safety personnel, the archeological monitor for the project shall be contacted (if not already present). Step 3: Notify Project Management and Consulting Parties. The archaeological monitor will first ensure appropriate treatment and protection of the discovery. Following these actions, the DAHP and the other consulting parties for the specific route will be notified immediately. The Archaeological Monitor’s responsibilities include: • Protect Find: The Archaeological Monitor, in coordination with the Construction Manager, is responsible for taking appropriate steps to protect the discovery site. All work will stop in an area adequate to provide for the total security, protection, and integrity of the resource. Vehicles, equipment, and unauthorized personnel will not be permitted to traverse the discovery site. Work in the immediate area will not resume until treatment of the discovery has been completed following provisions for treating archaeological/cultural material as set forth in this document.

6

• Direct Construction Elsewhere On Site: The Archaeological Monitor, in coordination with the Construction Manager, may direct construction away from cultural resources to work in other areas prior to contacting the concerned parties. • Identify Find: The archaeological monitor will ensure that a qualified individual examines the find to determine if it is archaeological. If it is determined not to be archaeological, work may proceed with no further delay. If it is determined to be archaeological, the archeologist will continue with notification. If the find may be human remains or funerary objects, the archaeologist will examine the find. • Notify DAHP: The Archaeologist will contact the involved federal agency(s), the DAHP, and any concerned Tribes or other parties specific to the route.

SPECIAL PROCEDURES FOR THE DISCOVERY OF HUMAN SKELETAL MATERIAL If human remains are encountered, they will be treated with dignity and respect at all times. Remains will be covered immediately with a tarp or other materials (not soil or rocks) for temporary protection in place and to shield them from being photographed. Confidentiality will be a priority and responses to and discoveries of human remains and associated materials will comply with provisions of the Native American Graves Protection and Repatriation Act and its implementing regulations, as well as existing protocols of the involved tribes. Native peoples in the study area consider the graves of their ancestors to be important in both their cultural identity and in defining their relationship with the land. These graves are therefore considered sacred and should be left undisturbed. Should inadvertent disturbance occur, the remains and associated materials (“funerary objects”) must be treated with respect and honor. All appropriate federal, state, and Tribal laws, regulations, and procedures regarding burials will be rigorously enforced. In the event that likely or confirmed human remains are encountered, all further sampling or other ground-disturbing activity will cease immediately. In the event of the discovery of human skeletal remains, the archaeological monitor will make the notifications identified below. • Notify Law Enforcement Agency or Coroner’s Office: The archaeological monitor will immediately notify the local law enforcement agency or coroner’s office. The coroner (with assistance of law enforcement personnel) will determine if the remains are human, whether the discovery site constitutes a crime scene, and will notify DAHP. • Participate in Consultation: Per RCW 27.53.030, 68.50, and 68.60, DAHP will have jurisdiction over non-forensic human remains. The archaeological monitor and any other consulting parties or Tribes will participate in consultation.

PROCEEDING WITH CONSTRUCTION Project construction outside the discovery location may continue while documentation and assessment of the cultural resources proceed. The archaeologist on-site must determine the boundaries of the discovery location. In consultation with DAHP, Tierra, and affected Tribe(s), the

7

qualified archeologist will determine the appropriate level of documentation and treatment of the resource. Construction may continue at the discovery location only after the process outlined in this plan is followed and the on-site archaeologist (in consultation with DAHP and other agencies, as appropriate) determines that compliance with state and federal laws is complete.

CULTURAL RESOURCES MONITORING AND DISCOVERY PLAN Prior to construction the archaeological monitor will brief construction crews on the role of the monitor, the duties of the crew in the event of a discovery situation, and applicable laws and regulations. Contact information for all necessary parties will be distributed to the relevant personnel at the pre-construction meeting. A qualified professional archeologist and/or Tribal representatives will be present to observe all ground disturbance during construction activities at each of the required locations. The archaeological monitor and/or tribal representative following Washington State DAHP procedures will record all prehistoric and historic cultural material discovered during project construction. The significance of all sites encountered during monitoring will be addressed using established criteria (36 CFR60.4). The criteria for NRHP eligibility are listed in 36 CFR 60 as follows:

The quality of significance in American history, architecture, archaeology, engineering, and culture is present in districts, sites, buildings, structures, and objects that possess integrity of location, design, setting, materials, workmanship, feeling, and association and

(a) That are associated with events that have made a significant contribution to the broad patterns of our history; or (b) That are associated with the lives or persons significant in our past; or (c) That embody the distinctive characteristics of a type, period, or method of construction, or that represent the work of a master, or that possess high artistic values, or that represent a significant and distinguishable entity whose components may lack individual distinction; or (d) That have yielded, or may be likely to yield, information important in prehistory and history.

Site features and artifacts will be photographed and stratigraphic profiles and soil descriptions will be prepared for subsurface exposures. Discovery locations will be documented on scaled site plans and site location maps. Cultural features, horizons, and artifacts detected in buried soils may require further evaluation using hand-excavated test units. Units may be dug in controlled fashion to expose features, collect samples from undisturbed contexts, or interpret complex stratigraphy. A test excavation unit or small trench might be used to determine whether an intact occupation surface is present. Test units will be used only when necessary to gather information on the nature, extent, and integrity of subsurface cultural deposits to evaluate the site’s significance. Field staff will record spatial information, depth of excavation levels, natural and cultural stratigraphy, presence or absence of cultural material, and depth to sterile soil, regolith, or bedrock

8

for each probe on a standard form. Test excavation units will be recorded on unit-level forms, which include plan maps for each excavated level; as well as material type, number, and vertical provenience (depth below surface and stratum association where applicable) for all artifacts recovered from the level. A stratigraphic profile will be drawn for at least one wall of each test excavation unit. Soils excavated for purposes of cultural resources investigation will be screened through 1/8-inch mesh, unless soil conditions warrant 1/4-inch mesh. If excavation activities expose human remains (burials, isolated teeth, or bones), the procedures for the discovery of human skeletal materials outlined above will be followed. All prehistoric and historic artifacts collected from the surface and from probes and excavation units will be analyzed, catalogued, and temporarily curated. Ultimate disposition of cultural materials will be determined in consultation with the NTIA, DAHP, and the affected Tribes.

DOCUMENTATION AND REPORTING The archaeological monitor will ensure proper documentation and assessment of any discovered cultural resources in cooperation with the NTIA, DAHP, affected Tribes, and a contracted consultant (if any). In the event that cultural resources are discovered during the construction work, the appropriate DAHP form will be completed by a professional archaeologist and submitted to DAHP. Significance evaluations and need for additional archaeologist work will be decided in consultation with DAHP, project archaeologist, and Tribal Historical Preservation Officers. All prehistoric and historic cultural material discovered during the project construction will be treated in the same manner as described above. A professional archaeologist will record identified archaeological materials following standard Washington DAHP procedures. Site features and artifacts will be photographed and stratigraphic profiles and soil descriptions will be prepared for subsurface exposures. Discovery locations will be documented on scaled site plans and site location maps. Within 90 days of concluding fieldwork, a technical report documenting the results of the study will be provided to the NTIA, who will forward the report to DAHP and the affected Tribe(s) for review and concurrence. If the presence of archaeological materials is suspected or demonstrated, recommendations for additional evaluation or mitigation will be provided. All site maps, photographs, field forms, and other documentation will be included in the submitted report, which will meet the State of Washington reporting standards and include a discussion of the NRHP eligibility of discovered resources.

9

Figure 1. Washington Rural Access Project Area

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A.1

APPENDIX A. CULTURAL RESOURCES SUMMARY LETTER

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Rand ye K . F e r r i c k , P r e s i d en t & B r oke r

1 5 7 5 Eas t R i v er R o a d , Su i t e 2 0 1 ● T uc s o n , A r i zo n a 8 5 7 1 8 ● 5 2 0 . 3 1 9 . 2 1 0 6 ● Fa x : 5 2 0 . 3 2 3 . 3 3 2 6 R i g h t o f W a y ● C u l t u r a l R e s o u r c e s ● E n v i r o n m e n t a l P l a n n i n g

F e d e r a l , S t a t e , a n d L o c a l P e r m i t t i n g ● G I S / C A D M a p p i n g w w w . t i e r r a - r o w . c o m

February 14, 2011 Frank J. Monteferrante, Ph.D. NEPA Environmental Specialist Broadband Technology Grant Program 1401 Constitution Avenue, N.W., Suite 4228 Washington, D.C. 20230 RE: Cultural Resources Recommendations for NoaNet’s Washington Rural Access Project (WRAP) (Round II) Dear Frank, Tierra Right of Way Services (Tierra) has recently completed the cultural resources reports for the WRAP II and submitted them to your office for review and transmittal to the Washington State Historic Preservation Office (SHPO). The routes for this project are NC-1, 2, and 3; NE-1, 2, and 3; NW-1A, 2, and 3; and SC-2A, 5, and 6. These have been grouped into 4 reports: NC, NE, NW, and SC. This letter summarizes the findings of the reports and discusses Tierra’s recommendations regarding effects on cultural resources and historic properties for each route. Each route is discussed individually below, and the number of potentially impacted archaeological sites, historic properties, and cemeteries within the area of potential effect (APE) are listed for each route. Table 1 lists the routes for which we recommend no further work. However, if cultural resources are encountered during construction within any of these routes, we recommend that the communication, consultation, and discovery plan outlined in the approved Treatment Plan template be strictly adhered to. Table 2 lists the routes which contain areas of cultural significance or sensitivity, or where sites are known to exist in the vicinity of buried portions of the route. Maps detailing these areas are available in the full Tierra reports. With very few exceptions, this project is to take place within previously disturbed, existing road rights-of-way. Although the overall project goal is to avoid all sites of cultural and historic significance, for routes where underground construction is planned and significant sites are believed to be in proximity of the planned route (Table 2), we recommend the following:

a Historic Properties Treatment Plan be developed in consultation with the National Telecommunications and Information Administration (NTIA), SHPO, and any concerned tribes (a template for this plan has already been developed and approved by the NTIA and Washington SHPO);

monitoring or other treatment prior to, or during, ground disturbance in these areas; and a subsequent monitoring/archaeological report be written and submitted to the NTIA and SHPO.

If these recommendations are carried out, our recommendation for this project is one of No Adverse Effect to Cultural Resources.

The fiber for this project will be installed aerially in some areas and buried in others. Aerial portions of the fiber will be installed on existing poles, and are therefore exempt from the 106 process, per the established Programmatic Agreement between the NTIA, Rural Utilities Service (RUS), and others. General Avoidance and Mitigation Measures The general approach for this project will be to avoid archaeological sites, when possible, by locating underground cable to avoid potential sites of significance. An alternative is to install aerial cable in the vicinity of sites rather than burying the cable, while ensuring that the installation vehicles remain on the shoulder of the road while installing aerial cable in the vicinity of sites that extend into the right-of-way. If avoidance of an archaeological or historic site by route adjustments or aerial installation is not possible, we recommend site reconnaissance (to include site relocation, site form and map updates, and National Register of Historic Places [NRHP] eligibility status) and/or monitoring in culturally sensitive areas. As discussed above, monitoring plans for the recommended routes will be developed in consultation with SHPO and any concerned tribes prior to construction. All fieldwork will be conducted by a State of Washington–permitted archaeologist. For cemeteries, we recommend site flagging and/or monitoring for those with boundaries near the APE. Some of these cemeteries date prior to the 20th century, and their original boundaries may not be in line with those delineated today. During site reconnaissance, the archaeologist will evaluate the proximity of the cemetery and determine if monitoring during construction is necessary. Records of flagging and/or results of monitoring will be included in the final monitoring report. For historic properties and districts, there will be no visual impacts whether the line is to be buried or placed aerially, as the aerial placement will use existing poles with existing lines, and buried cable will not be visible. The buildings and contributing properties to historic districts are outside of the road right-of-way (where the majority of placement is taking place), and so will not be directly impacted. Our recommendation for these properties would be to discontinue use of high-vibration construction equipment while in the vicinity of historic properties whose structural integrity is questionable. If you have any questions or need anything further, please do not hesitate to contact me at (520) 319-2106 or bmontgomery@tierra-row.com. Sincerely,

Barbara K. Montgomery, Ph.D. Principal Investigator, Cultural Resources Division

Recommendations Table 1. Routes of Minimal Concern (full details of each route are discussed in the Tierra reports dated 2011)

Route Buried/

Aerial/Wireless Sites

Historic Properties

Register District

Register Properties

Cemeteries Recommendation

NC-1 Buried and Aerial 0 0 0 0 1 No Effect—The cemetery is within an aerial

portion of the route and will not be impacted.

NW-3 Aerial 0 7 0 0 4 No Effect—The historic properties and cemeteries

are within aerial portions of the route and are therefore exempt.

Table 2. Routes for Which We Recommend Further Treatment (full details of each route are discussed in the Tierra reports dated 2011)

Route Buried or

Aerial Sites

Historic Properties

Register District

Register Properties

Cemeteries Recommendation

NC-2 Buried and

Aerial 0 6 0 1 1

No Adverse Effect—The cemetery is within an aerial portion and will therefore not be impacted. In our opinion, historic structures and register property will not be impacted by adjacent plow insertion of fiber cable, and we recommend only discontinued use of high-vibration construction equipment when working in the vicinity of structures whose integrity is in question.

NC-3 Buried and

Aerial 1 14 1 1 1

No Adverse Effect—The register district is within an aerial portion of the route and is therefore exempt. The archaeological site and cemetery are also within aerial portions and will therefore not be impacted. In our opinion, historic structures and register property will not be impacted by adjacent plow insertion of fiber cable, and we recommend only discontinued use of high-vibration construction equipment when working in the vicinity of structures whose integrity is in question.

Route Buried or

Aerial Sites

Historic Properties

Register District

Register Properties

Cemeteries Recommendation

NE-1 Buried and

Aerial 28 28 0 9 9

No Adverse Effect—We recommend development of a treatment plan to include reconnaissance of the archaeological sites, monitoring specifications (if warranted), and procedures for avoidance of cemeteries during construction. In our opinion, historic structures will not be impacted by adjacent plow insertion of fiber cable, and we recommend only discontinued use of high-vibration construction equipment when working in the vicinity of structures whose integrity is in question.

NE-2 Buried and

Aerial 27 3 0 0 2

No Adverse Effect—The archaeological sites and historic properties are within aerial portions of the route and are therefore exempt. We recommend development of a treatment plan to include procedures for avoidance of the cemeteries during construction. In our opinion, historic structures will not be impacted by adjacent plow insertion of fiber cable, and we recommend only discontinued use of high-vibration construction equipment when working in the vicinity of the four structures whose integrity is in question.

NE-3 Wireless to be

determined to be

determinedto be

determined to be

determined to be

determined

No Adverse Effect—This route is comprised of 13 microwave towers. Any potential effects to cultural properties will be mitigated following the requirements of the Federal Communications Commission Nationwide Programmatic Agreement.

NW-1A Wireless to be

determined to be

determinedto be

determined to be

determined to be

determined

No Adverse Effect—This route is comprised of 44 collocations on existing cell towers with no new construction. Any potential effects of construction will be mitigated by following the requirements outlined in the Federal Communications Commission Nationwide Programmatic Agreement.

Route Buried or

Aerial Sites

Historic Properties

Register District

Register Properties

Cemeteries Recommendation

NW-2 Buried/ Aerial/ Wireless

5 10 2 9 4

No Adverse Effect—We recommend development of a treatment plan to include reconnaissance of the archaeological sites, monitoring specifications (if warranted), and procedures for avoidance of cemeteries during construction. In our opinion, historic structures will not be impacted by adjacent plow insertion of fiber cable, and we recommend only discontinued use of high-vibration construction equipment when working in the vicinity of structures whose integrity is in question. Also, planned collocations on 44 existing cell towers, and the construction of one new cell tower and three maintenance structures, will be mitigated by following the requirements outlined in the Federal Communications Commission Nationwide Programmatic Agreement.

SC-2A Buried and

Aerial 10 9 0 1 1

No Adverse Effect—We recommend development of a treatment plan to include reconnaissance of the archaeological site within a buried portion of the line and monitoring specifications, if warranted. The historic properties and cemeteries are within aerial portions of the route and are therefore exempt

SC-5 Buried and

Aerial 10 32 0 5 2

No Adverse Effect—The register properties and cemeteries are in aerial portions of the route and are therefore exempt. We recommend development of a treatment plan to include reconnaissance of the archaeological sites and monitoring specifications, if warranted. In our opinion, historic structures will not be impacted by adjacent plow insertion of fiber cable, and we recommend only discontinued use of high-vibration construction equipment when working in the vicinity of structures whose integrity is in question.

Route Buried or

Aerial Sites

Historic Properties

Register District

Register Properties

Cemeteries Recommendation

SC-6 Buried and

Aerial 24 3 0 0 1

No Adverse Effect— We recommend development of a treatment plan to include reconnaissance of the archaeological sites, monitoring specifications if warranted, and procedures for avoidance of cemeteries during construction. The historic properties are within aerial portions of the route and are therefore exempt.

Appendix E-5

2/24/11 Letters from NTIA requesting concurrence

on a finding of No Adverse Effect

 

Appendix E-6

3/2/2011 Letter SHPO/DAHP concurring with

finding of No Adverse Effect

STATE OF WASHINGTON

DEPARTMENT OF ARCHAEOLOGY & HISTORIC PRESERVATION 1063 S. Capitol Way, Suite 106 � Olympia, Washington 98501

Mailing address: PO Box 48343 � Olympia, Washington 98504-8343 (360) 586-3065 � Fax Number (360) 586-3067 � Website: www.dahp.wa.gov

March 2, 2011

Ms. Jill A. Dowling

Federal Preservation Officer

Department of Commerce

Washington, D.C. 20230

Re: NoaNet Grant #5376 Project

Log No: 112210-37-DOC

Dear Ms. Dowling:

Thank you for contacting our department. We have reviewed the revised professional archaeological

assessment report and associated materials you provided for the proposed NoaNet Grant #5376 Project in

multiple counties across Washington.

We concur with your Determination of No Adverse Effect exclusive of those elements of the Project

under the jurisdiction of the THPOs. We look forward to further consultation as the results of the on the

ground verification are obtained and as the treatment stipulations are implemented.

We would appreciate receiving any correspondence or comments from concerned tribes or other parties

that you receive as you consult under the requirements of 36CFR800.4(a)(4).

These comments are based on the information available at the time of this review and on the behalf of the

State Historic Preservation Officer in conformance with Section 106 of the National Historic Preservation

Act and its implementing regulations 36CFR800. Should additional information become available, our

assessment may be revised. Thank you for the opportunity to comment and a copy of these comments

should be included in subsequent environmental documents. We look forward to further consultation.

Sincerely,

Robert G. Whitlam, Ph.D.

State Archaeologist

(360) 586-3080

email: rob.whitlam@dahp.wa.gov

 

Appendix E-7

1/6/2011 Letter from NTIA to Tribes introducing

project, ongoing efforts, and requesting input

beaus

Text Box

NOTE: This is an example of the letter that was sent to the Nooksack, Suquamish, Tulalip, Kalispell, Upper Skagit, Yakama tribes to introduce the project, discuss ongoing efforts, and request input.

Appendix E-8

TCNS RESPONSES: Fiber

 

Laura Murphy Muckleshoot Indian Tribe 39015 172nd Ave SE Auburn, WA 98092 May 13, 2011 Re: Northwest Open Access Network (NoaNet) Washington Rural Access Project II Dear Ms. Murphy, The National Telecommunications and Information Administration notified your office of the above-referenced fiber-optic project via the TCNS system. You responded with the following: “The Muckleshoot Tribe requests that a street map be provided with each TCNS notification. The Muckleshoot Tribe is only interested in reviewing proposed sites in King, Pierce and Snohomish Counties in the State of Washington”. Per your request, attached is a map of Route NC-2 of this project, the only route which crosses any of the three counties you listed (Snohomish). As you can see, Muckleshoot Reservation lands are not crossed by this project.

Appendix E-8.1

TCNS RESPONSES: Wireless

From: towernotifyinfo@fcc.govTo: Rob KoppSubject: Proposed Tower Structure Info - Email ID #2866137Date: Friday, August 19, 2011 1:28:40 PM

Dear William Kopp,

Thank you for submitting a notification regarding your proposed construction via the Tower ConstructionNotification System. Note that the system has assigned a unique Notification ID number for thisproposed construction. You will need to reference this Notification ID number when you update yourproject's Status with us.

Below are the details you provided for the construction you have proposed:

Notification Received: 08/19/2011

Notification ID: 79107 Tower Owner Individual or Entity Name: Northwest Open Access Network Consultant Name: William Kopp Street Address: 5802 Overlook Avenue, NE City: Tacoma State: WASHINGTON Zip Code: 98422 Phone: 208-863-5346 Email: rkopp@noanet.net

Structure Type: BPOLE - Building with Pole Latitude: 47 deg 38 min 59 sec N Longitude: 117 deg 17 min 13 sec W Location Description: 305 E. Main Street City: Fairfield State: WASHINGTON County: SPOKANE Ground Elevation: 741.6 meters Support Structure: 6.1 meters above ground level Overall Structure: 9.1 meters above ground level Overall Height AMSL: 750.7 meters above mean sea level

Appendix E-8.1

TCNS ID No: 79108

Appendix E-8.1

TCNS ID No: 79108

From: towernotifyinfo@fcc.govTo: Rob KoppCc: kim.pristello@fcc.gov; diane.dupert@fcc.govSubject: NOTICE OF ORGANIZATION(S) WHICH WERE SENT PROPOSED TOWER CONSTRUCTION NOTIFICATION

INFORMATION - Email ID #2867068Date: Friday, August 26, 2011 12:01:13 AM

Dear Sir or Madam:

Thank you for using the Federal Communications Commission's (FCC) Tower Construction NotificationSystem (TCNS). The purpose of this electronic mail message is to inform you that the followingauthorized persons were sent the information you provided through TCNS, which relates to yourproposed antenna structure. The information was forwarded by the FCC to authorized TCNS users byelectronic mail and/or regular mail (letter).

Persons who have received the information that you provided include leaders or their designees offederally-recognized American Indian Tribes, including Alaska Native Villages (collectively "Tribes"),Native Hawaiian Organizations (NHOs), and State Historic Preservation Officers (SHPOs). For yourconvenience in identifying the referenced Tribes and in making further contacts, the City and State ofthe Seat of Government for each Tribe and NHO, as well as the designated contact person, is includedin the listing below. We note that Tribes may have Section 106 cultural interests in ancestral homelandsor other locations that are far removed from their current Seat of Government. Pursuant to theCommission's rules as set forth in the Nationwide Programmatic Agreement for Review of Effects onHistoric Properties for Certain Undertakings Approved by the Federal Communications Commission(NPA), all Tribes and NHOs listed below must be afforded a reasonable opportunity to respond to thisnotification, consistent with the procedures set forth below, unless the proposed construction falls withinan exclusion designated by the Tribe or NHO. (NPA, Section IV.F.4).

The information you provided was forwarded to the following Tribes and NHOs who have set theirgeographic preferences on TCNS. If the information you provided relates to a proposed antennastructure in the State of Alaska, the following list also includes Tribes located in the State of Alaska thathave not specified their geographic preferences. For these Tribes and NHOs, if the Tribe or NHO doesnot respond within a reasonable time, you should make a reasonable effort at follow-up contact, unlessthe Tribe or NHO has agreed to different procedures (NPA, Section IV.F.5). In the event such a Tribe orNHO does not respond to a follow-up inquiry, or if a substantive or procedural disagreement arisesbetween you and a Tribe or NHO, you must seek guidance from the Commission (NPA, Section IV.G). These procedures are further set forth in the FCC's Declaratory Ruling released on October 6, 2005 (FCC05-176).

1. Cultural Resources Director Johnson Meninick - Yakama Nation - Toppenish, WA - electronic mail andregular mailDetails: If the Applicant/tower builder receives no response from the Yakama Nation within 30 daysafter notification through TCNS, the Yakama Nation has no interest in participating in pre-constructionreview for the proposed site. The Applicant/tower builder, however, must IMMEDIATELY notify theYakama Nation in the event archaeological properties or human remains are discovered duringconstruction, consistent with Section IX of the Nationwide Programmatic Agreement and applicable law.

2. THPO Jill M Wagner PhD - Coeur d'Alene Tribal Council - Plummer, ID - electronic mail and regularmail

3. Tribal Historic Preservation Officer Camille Pleasants - Confederated Tribes of the Colville Reservation- Nespelem, WA - regular mail

Appendix E-8.1

TCNS ID No: 79108

4. Tribal Compliance Manager Clarinda Burke - Confederated Salish and Kootenai Tribes of the FlatheadNation - Pablo, MT - electronic mailDetails: If the Applicant/tower constructor receives no response from the Confederated Salish andKootenai Tribes of the Flathead Nation within 30 days after notification through TCNS, the ConfederatedSalish and Kootenai Tribes of the Flathead Nation has no interest in participating in pre-constructionreview for the site. The applicant/tower builder, however, must IMMEDIATELY notify the ConfederatedSalish and Kootenai Tribes of the Flathead Nation in the event archaeological properties or humanremains are discovered during construction, consistent with Section IX of the Nationwide ProgrammaticAgreement and applicable law.

5. THPO Randy Abrahamson - Spokane Tribe of Indians - Wellpinit, WA - electronic mail and regularmailDetails: The Spokane Tribe of Indians REQUIRES the township range and section for each proposedproject. We are unable to make a determination until we have received this information. Pleaseprovide the township range and section for the proposed project in an attachment when you first submityour tower notification to TCNS, or e-mail this information to me separately. If e-mailed separately,please provide the TCNS number in the subject line of your e-mail. Thank you.Randy Abrahamson, THPOSpokane Tribeof Indiansrandya@spokanetribe.com

The information you provided was also forwarded to the additional Tribes and NHOs listed below. TheseTribes and NHOs have NOT set their geographic preferences on TCNS, and therefore they are currentlyreceiving tower notifications for the entire United States. For these Tribes and NHOs, you are requiredto use reasonable and good faith efforts to determine if the Tribe or NHO may attach religious andcultural significance to historic properties that may be affected by its proposed undertaking. Suchefforts may include, but are not limited to, seeking information from the relevant SHPO or THPO, IndianTribes, state agencies, the U.S. Bureau of Indian Affairs, or, where applicable, any federal agency withland holdings within the state (NPA, Section IV.B). If after such reasonable and good faith efforts, youdetermine that a Tribe or NHO may attach religious and cultural significance to historic properties in thearea and the Tribe or NHO does not respond to TCNS notification within a reasonable time, you shouldmake a reasonable effort to follow up, and must seek guidance from the Commission in the event ofcontinued non-response or in the event of a procedural or substantive disagreement. If you determinethat the Tribe or NHO is unlikely to attach religious and cultural significance to historic properties withinthe area, you do not need to take further action unless the Tribe or NHO indicates an interest in theproposed construction or other evidence of potential interest comes to your attention.

None

The information you provided was also forwarded to the following SHPOs in the State in which youpropose to construct and neighboring States. The information was provided to these SHPOs as acourtesy for their information and planning. You need make no effort at this time to follow up with anySHPO that does not respond to this notification. Prior to construction, you must provide the SHPO ofthe State in which you propose to construct (or the Tribal Historic Preservation Officer, if the project willbe located on certain Tribal lands), with a Submission Packet pursuant to Section VII.A of the NPA.

6. SHPO Allyson Brooks - Office of Archeology & Historic Preservation - Olympia, WA - electronic mail

7. Deputy SHPO Greg Griffith - Office of Archeology & Historic Preservation - Olympia, WA - electronic

Appendix E-8.1

TCNS ID No: 79108

mail

If you are proposing to construct a facility in the State of Alaska, you should contact Commission stafffor guidance regarding your obligations in the event that Tribes do not respond to this notificationwithin a reasonable time.

Please be advised that the FCC cannot guarantee that the contact(s) listed above opened and reviewedan electronic or regular mail notification. The following information relating to the proposed tower wasforwarded to the person(s) listed above:

Notification Received: 08/19/2011 Notification ID: 79107 Tower Owner Individual or Entity Name: Northwest Open Access Network Consultant Name: William Kopp Street Address: 5802 Overlook Avenue, NE City: Tacoma State: WASHINGTON Zip Code: 98422 Phone: 208-863-5346 Email: rkopp@noanet.net

Structure Type: BPOLE - Building with Pole Latitude: 47 deg 38 min 59.0 sec N Longitude: 117 deg 17 min 13.0 sec W Location Description: 305 E. Main Street City: Fairfield State: WASHINGTON County: SPOKANE Ground Elevation: 741.6 meters Support Structure: 6.1 meters above ground level Overall Structure: 9.1 meters above ground level Overall Height AMSL: 750.7 meters above mean sea level

If you have any questions or comments regarding this notice, please contact the FCC using theelectronic mail form located on the FCC's website at:

http://wireless.fcc.gov/outreach/notification/contact-fcc.html.

You may also call the FCC Support Center at (877) 480-3201 (TTY 717-338-2824). Hours are from 8a.m. to 7:00 p.m. Eastern Time, Monday through Friday (except Federal holidays). To provide qualityservice and ensure security, all telephone calls are recorded.

Thank you,Federal Communications Commission

Appendix E-8.1

TCNS ID No: 79108

Appendix E-8.1

TCNS ID No: 79108

From: towernotifyinfo@fcc.govTo: Rob KoppCc: tcns.fccarchive@fcc.gov; randya@spokanetribe.comSubject: Reply to Proposed Tower Structure (Notification ID: 79107) - Email ID #2872626Date: Monday, August 29, 2011 10:38:22 AM

Dear William Kopp,

Thank you for using the Federal Communications Commission's (FCC) Tower Construction NotificationSystem (TCNS). The purpose of this email is to inform you that an authorized user of the TCNS hasreplied to a proposed tower construction notification that you had submitted through the TCNS.

The following message has been sent to you from THPO Randy Abrahamson of the Spokane Tribe ofIndians in reference to Notification ID #79107:

We have an interest in this site and would like the applicant to contact us. randy abrahamson 509-258-4315

For your convenience, the information you submitted for this notification is detailed below.

Notification Received: 08/19/2011 Notification ID: 79107 Tower Owner Individual or Entity Name: Northwest Open Access Network Consultant Name: William Kopp Street Address: 5802 Overlook Avenue, NE City: Tacoma State: WASHINGTON Zip Code: 98422 Phone: 208-863-5346 Email: rkopp@noanet.net

Structure Type: BPOLE - Building with Pole Latitude: 47 deg 38 min 59.0 sec N Longitude: 117 deg 17 min 13.0 sec W Location Description: 305 E. Main Street City: Fairfield State: WASHINGTON County: SPOKANE Ground Elevation: 741.6 meters Support Structure: 6.1 meters above ground level Overall Structure: 9.1 meters above ground level Overall Height AMSL: 750.7 meters above mean sea level

Appendix E-8.1

TCNS ID No: 79108

Appendix E-8.1

TCNS ID No: 79108

From: towernotifyinfo@fcc.govTo: Rob KoppSubject: Proposed Tower Structure Info - Email ID #2866139Date: Friday, August 19, 2011 1:33:15 PM

Dear William Kopp,

Thank you for submitting a notification regarding your proposed construction via the Tower ConstructionNotification System. Note that the system has assigned a unique Notification ID number for thisproposed construction. You will need to reference this Notification ID number when you update yourproject's Status with us.

Below are the details you provided for the construction you have proposed:

Notification Received: 08/19/2011

Notification ID: 79108 Tower Owner Individual or Entity Name: Northwest Open Access Network Consultant Name: William Kopp Street Address: 5802 Overlook Avenue, NE City: Tacoma State: WASHINGTON Zip Code: 98422 Phone: 208-863-5346 Email: rkopp@noanet.net

Structure Type: B - Building Latitude: 48 deg 8 min 11 sec N Longitude: 122 deg 46 min 10 sec W Location Description: 200 Battery Way City: Port Townsend State: WASHINGTON County: JEFFERSON Ground Elevation: 8.8 meters Support Structure: 6.1 meters above ground level Overall Structure: 12.2 meters above ground level Overall Height AMSL: 21 meters above mean sea level

Appendix E-8.1

TCNS ID No: 79108

Appendix E-8.1

TCNS ID No: 79108

From: towernotifyinfo@fcc.govTo: Rob KoppCc: kim.pristello@fcc.gov; diane.dupert@fcc.govSubject: NOTICE OF ORGANIZATION(S) WHICH WERE SENT PROPOSED TOWER CONSTRUCTION NOTIFICATION

INFORMATION - Email ID #2867074Date: Friday, August 26, 2011 12:01:13 AM

Dear Sir or Madam:

Thank you for using the Federal Communications Commission's (FCC) Tower Construction NotificationSystem (TCNS). The purpose of this electronic mail message is to inform you that the followingauthorized persons were sent the information you provided through TCNS, which relates to yourproposed antenna structure. The information was forwarded by the FCC to authorized TCNS users byelectronic mail and/or regular mail (letter).

Persons who have received the information that you provided include leaders or their designees offederally-recognized American Indian Tribes, including Alaska Native Villages (collectively "Tribes"),Native Hawaiian Organizations (NHOs), and State Historic Preservation Officers (SHPOs). For yourconvenience in identifying the referenced Tribes and in making further contacts, the City and State ofthe Seat of Government for each Tribe and NHO, as well as the designated contact person, is includedin the listing below. We note that Tribes may have Section 106 cultural interests in ancestral homelandsor other locations that are far removed from their current Seat of Government. Pursuant to theCommission's rules as set forth in the Nationwide Programmatic Agreement for Review of Effects onHistoric Properties for Certain Undertakings Approved by the Federal Communications Commission(NPA), all Tribes and NHOs listed below must be afforded a reasonable opportunity to respond to thisnotification, consistent with the procedures set forth below, unless the proposed construction falls withinan exclusion designated by the Tribe or NHO. (NPA, Section IV.F.4).

The information you provided was forwarded to the following Tribes and NHOs who have set theirgeographic preferences on TCNS. If the information you provided relates to a proposed antennastructure in the State of Alaska, the following list also includes Tribes located in the State of Alaska thathave not specified their geographic preferences. For these Tribes and NHOs, if the Tribe or NHO doesnot respond within a reasonable time, you should make a reasonable effort at follow-up contact, unlessthe Tribe or NHO has agreed to different procedures (NPA, Section IV.F.5). In the event such a Tribe orNHO does not respond to a follow-up inquiry, or if a substantive or procedural disagreement arisesbetween you and a Tribe or NHO, you must seek guidance from the Commission (NPA, Section IV.G). These procedures are further set forth in the FCC's Declaratory Ruling released on October 6, 2005 (FCC05-176).

1. Cultural Resources Director Marie Hebert - Port Gamble S'Klallam Tribe - Kingston, WA - electronicmail and regular mail

2. Archaeologist Dennis E Lewarch - Suquamish Tribe - Suquamish, WA - electronic mail and regularmail

3. THPO Richard Young - Tulalip Tribes of the Tulalip Reservation - Tulalip, WA - electronic mail andregular mail

4. Cultural Resources Director Johnson Meninick - Yakama Nation - Toppenish, WA - electronic mail andregular mail

Appendix E-8.1

TCNS ID No: 79108

Details: If the Applicant/tower builder receives no response from the Yakama Nation within 30 daysafter notification through TCNS, the Yakama Nation has no interest in participating in pre-constructionreview for the proposed site. The Applicant/tower builder, however, must IMMEDIATELY notify theYakama Nation in the event archaeological properties or human remains are discovered duringconstruction, consistent with Section IX of the Nationwide Programmatic Agreement and applicable law.

5. Acting Executive Director Robert Smith - Hoh Tribe - Forks, WA - electronic mail and regular mail

6. Cultural Resources Officer Kathy Duncan - Jamestown S'Klallam Tribe - Sequim, WA - electronic mailand regular mail

7. IT Manager Gene Terry - Quinault Indian Nation - Taholah, WA - electronic mail

8. THPO and Director Janine Bowechop - Makah Tribe - Neah Bay, WA - electronic mail and regular mail

9. THPO Kris Miller - Skokomish Indian Tribe - Skokomish Nation, WA - electronic mail and regular mail

The information you provided was also forwarded to the additional Tribes and NHOs listed below. TheseTribes and NHOs have NOT set their geographic preferences on TCNS, and therefore they are currentlyreceiving tower notifications for the entire United States. For these Tribes and NHOs, you are requiredto use reasonable and good faith efforts to determine if the Tribe or NHO may attach religious andcultural significance to historic properties that may be affected by its proposed undertaking. Suchefforts may include, but are not limited to, seeking information from the relevant SHPO or THPO, IndianTribes, state agencies, the U.S. Bureau of Indian Affairs, or, where applicable, any federal agency withland holdings within the state (NPA, Section IV.B). If after such reasonable and good faith efforts, youdetermine that a Tribe or NHO may attach religious and cultural significance to historic properties in thearea and the Tribe or NHO does not respond to TCNS notification within a reasonable time, you shouldmake a reasonable effort to follow up, and must seek guidance from the Commission in the event ofcontinued non-response or in the event of a procedural or substantive disagreement. If you determinethat the Tribe or NHO is unlikely to attach religious and cultural significance to historic properties withinthe area, you do not need to take further action unless the Tribe or NHO indicates an interest in theproposed construction or other evidence of potential interest comes to your attention.

None

The information you provided was also forwarded to the following SHPOs in the State in which youpropose to construct and neighboring States. The information was provided to these SHPOs as acourtesy for their information and planning. You need make no effort at this time to follow up with anySHPO that does not respond to this notification. Prior to construction, you must provide the SHPO ofthe State in which you propose to construct (or the Tribal Historic Preservation Officer, if the project willbe located on certain Tribal lands), with a Submission Packet pursuant to Section VII.A of the NPA.

10. SHPO Allyson Brooks - Office of Archeology & Historic Preservation - Olympia, WA - electronic mail

11. Deputy SHPO Greg Griffith - Office of Archeology & Historic Preservation - Olympia, WA - electronic

Appendix E-8.1

TCNS ID No: 79108

mail

If you are proposing to construct a facility in the State of Alaska, you should contact Commission stafffor guidance regarding your obligations in the event that Tribes do not respond to this notificationwithin a reasonable time.

Please be advised that the FCC cannot guarantee that the contact(s) listed above opened and reviewedan electronic or regular mail notification. The following information relating to the proposed tower wasforwarded to the person(s) listed above:

Notification Received: 08/19/2011 Notification ID: 79108 Tower Owner Individual or Entity Name: Northwest Open Access Network Consultant Name: William Kopp Street Address: 5802 Overlook Avenue, NE City: Tacoma State: WASHINGTON Zip Code: 98422 Phone: 208-863-5346 Email: rkopp@noanet.net

Structure Type: B - Building Latitude: 48 deg 8 min 11.0 sec N Longitude: 122 deg 46 min 10.0 sec W Location Description: 200 Battery Way City: Port Townsend State: WASHINGTON County: JEFFERSON Ground Elevation: 8.8 meters Support Structure: 6.1 meters above ground level Overall Structure: 12.2 meters above ground level Overall Height AMSL: 21.0 meters above mean sea level

If you have any questions or comments regarding this notice, please contact the FCC using theelectronic mail form located on the FCC's website at:

http://wireless.fcc.gov/outreach/notification/contact-fcc.html.

You may also call the FCC Support Center at (877) 480-3201 (TTY 717-338-2824). Hours are from 8a.m. to 7:00 p.m. Eastern Time, Monday through Friday (except Federal holidays). To provide qualityservice and ensure security, all telephone calls are recorded.

Thank you,Federal Communications Commission

Appendix E-8.1

TCNS ID No: 79108

Appendix E-8.1

TCNS ID No: 79108

From: towernotifyinfo@fcc.govTo: Rob KoppSubject: Proposed Tower Structure Info - Email ID #2866141Date: Friday, August 19, 2011 1:35:09 PM

Dear William Kopp,

Thank you for submitting a notification regarding your proposed construction via the Tower ConstructionNotification System. Note that the system has assigned a unique Notification ID number for thisproposed construction. You will need to reference this Notification ID number when you update yourproject's Status with us.

Below are the details you provided for the construction you have proposed:

Notification Received: 08/19/2011

Notification ID: 79109 Tower Owner Individual or Entity Name: Northwest Open Access Network Consultant Name: William Kopp Street Address: 5802 Overlook Avenue, NE City: Tacoma State: WASHINGTON Zip Code: 98422 Phone: 208-863-5346 Email: rkopp@noanet.net

Structure Type: B - Building Latitude: 48 deg 6 min 42.6 sec N Longitude: 122 deg 46 min 16 sec W Location Description: 1820 Jefferson Street City: Port Townsend State: WASHINGTON County: JEFFERSON Ground Elevation: 29 meters Support Structure: 6.1 meters above ground level Overall Structure: 18.3 meters above ground level Overall Height AMSL: 47.3 meters above mean sea level

Appendix E-8.1

TCNS ID No: 79109

Appendix E-8.1

TCNS ID No: 79109

From: towernotifyinfo@fcc.govTo: Rob KoppCc: kim.pristello@fcc.gov; diane.dupert@fcc.govSubject: NOTICE OF ORGANIZATION(S) WHICH WERE SENT PROPOSED TOWER CONSTRUCTION NOTIFICATION

INFORMATION - Email ID #2867085Date: Friday, August 26, 2011 12:01:13 AM

Dear Sir or Madam:

Thank you for using the Federal Communications Commission's (FCC) Tower Construction NotificationSystem (TCNS). The purpose of this electronic mail message is to inform you that the followingauthorized persons were sent the information you provided through TCNS, which relates to yourproposed antenna structure. The information was forwarded by the FCC to authorized TCNS users byelectronic mail and/or regular mail (letter).

Persons who have received the information that you provided include leaders or their designees offederally-recognized American Indian Tribes, including Alaska Native Villages (collectively "Tribes"),Native Hawaiian Organizations (NHOs), and State Historic Preservation Officers (SHPOs). For yourconvenience in identifying the referenced Tribes and in making further contacts, the City and State ofthe Seat of Government for each Tribe and NHO, as well as the designated contact person, is includedin the listing below. We note that Tribes may have Section 106 cultural interests in ancestral homelandsor other locations that are far removed from their current Seat of Government. Pursuant to theCommission's rules as set forth in the Nationwide Programmatic Agreement for Review of Effects onHistoric Properties for Certain Undertakings Approved by the Federal Communications Commission(NPA), all Tribes and NHOs listed below must be afforded a reasonable opportunity to respond to thisnotification, consistent with the procedures set forth below, unless the proposed construction falls withinan exclusion designated by the Tribe or NHO. (NPA, Section IV.F.4).

The information you provided was forwarded to the following Tribes and NHOs who have set theirgeographic preferences on TCNS. If the information you provided relates to a proposed antennastructure in the State of Alaska, the following list also includes Tribes located in the State of Alaska thathave not specified their geographic preferences. For these Tribes and NHOs, if the Tribe or NHO doesnot respond within a reasonable time, you should make a reasonable effort at follow-up contact, unlessthe Tribe or NHO has agreed to different procedures (NPA, Section IV.F.5). In the event such a Tribe orNHO does not respond to a follow-up inquiry, or if a substantive or procedural disagreement arisesbetween you and a Tribe or NHO, you must seek guidance from the Commission (NPA, Section IV.G). These procedures are further set forth in the FCC's Declaratory Ruling released on October 6, 2005 (FCC05-176).

1. Cultural Resources Director Marie Hebert - Port Gamble S'Klallam Tribe - Kingston, WA - electronicmail and regular mail

2. Archaeologist Dennis E Lewarch - Suquamish Tribe - Suquamish, WA - electronic mail and regularmail

3. THPO Richard Young - Tulalip Tribes of the Tulalip Reservation - Tulalip, WA - electronic mail andregular mail

4. Cultural Resources Director Johnson Meninick - Yakama Nation - Toppenish, WA - electronic mail andregular mail

Appendix E-8.1

TCNS ID No: 79109

Details: If the Applicant/tower builder receives no response from the Yakama Nation within 30 daysafter notification through TCNS, the Yakama Nation has no interest in participating in pre-constructionreview for the proposed site. The Applicant/tower builder, however, must IMMEDIATELY notify theYakama Nation in the event archaeological properties or human remains are discovered duringconstruction, consistent with Section IX of the Nationwide Programmatic Agreement and applicable law.

5. Acting Executive Director Robert Smith - Hoh Tribe - Forks, WA - electronic mail and regular mail

6. Cultural Resources Officer Kathy Duncan - Jamestown S'Klallam Tribe - Sequim, WA - electronic mailand regular mail

7. IT Manager Gene Terry - Quinault Indian Nation - Taholah, WA - electronic mail

8. THPO and Director Janine Bowechop - Makah Tribe - Neah Bay, WA - electronic mail and regular mail

9. THPO Kris Miller - Skokomish Indian Tribe - Skokomish Nation, WA - electronic mail and regular mail

The information you provided was also forwarded to the additional Tribes and NHOs listed below. TheseTribes and NHOs have NOT set their geographic preferences on TCNS, and therefore they are currentlyreceiving tower notifications for the entire United States. For these Tribes and NHOs, you are requiredto use reasonable and good faith efforts to determine if the Tribe or NHO may attach religious andcultural significance to historic properties that may be affected by its proposed undertaking. Suchefforts may include, but are not limited to, seeking information from the relevant SHPO or THPO, IndianTribes, state agencies, the U.S. Bureau of Indian Affairs, or, where applicable, any federal agency withland holdings within the state (NPA, Section IV.B). If after such reasonable and good faith efforts, youdetermine that a Tribe or NHO may attach religious and cultural significance to historic properties in thearea and the Tribe or NHO does not respond to TCNS notification within a reasonable time, you shouldmake a reasonable effort to follow up, and must seek guidance from the Commission in the event ofcontinued non-response or in the event of a procedural or substantive disagreement. If you determinethat the Tribe or NHO is unlikely to attach religious and cultural significance to historic properties withinthe area, you do not need to take further action unless the Tribe or NHO indicates an interest in theproposed construction or other evidence of potential interest comes to your attention.

None

The information you provided was also forwarded to the following SHPOs in the State in which youpropose to construct and neighboring States. The information was provided to these SHPOs as acourtesy for their information and planning. You need make no effort at this time to follow up with anySHPO that does not respond to this notification. Prior to construction, you must provide the SHPO ofthe State in which you propose to construct (or the Tribal Historic Preservation Officer, if the project willbe located on certain Tribal lands), with a Submission Packet pursuant to Section VII.A of the NPA.

10. SHPO Allyson Brooks - Office of Archeology & Historic Preservation - Olympia, WA - electronic mail

11. Deputy SHPO Greg Griffith - Office of Archeology & Historic Preservation - Olympia, WA - electronic

Appendix E-8.1

TCNS ID No: 79109

mail

If you are proposing to construct a facility in the State of Alaska, you should contact Commission stafffor guidance regarding your obligations in the event that Tribes do not respond to this notificationwithin a reasonable time.

Please be advised that the FCC cannot guarantee that the contact(s) listed above opened and reviewedan electronic or regular mail notification. The following information relating to the proposed tower wasforwarded to the person(s) listed above:

Notification Received: 08/19/2011 Notification ID: 79109 Tower Owner Individual or Entity Name: Northwest Open Access Network Consultant Name: William Kopp Street Address: 5802 Overlook Avenue, NE City: Tacoma State: WASHINGTON Zip Code: 98422 Phone: 208-863-5346 Email: rkopp@noanet.net

Structure Type: B - Building Latitude: 48 deg 6 min 42.6 sec N Longitude: 122 deg 46 min 16.0 sec W Location Description: 1820 Jefferson Street City: Port Townsend State: WASHINGTON County: JEFFERSON Ground Elevation: 29.0 meters Support Structure: 6.1 meters above ground level Overall Structure: 18.3 meters above ground level Overall Height AMSL: 47.3 meters above mean sea level

If you have any questions or comments regarding this notice, please contact the FCC using theelectronic mail form located on the FCC's website at:

http://wireless.fcc.gov/outreach/notification/contact-fcc.html.

You may also call the FCC Support Center at (877) 480-3201 (TTY 717-338-2824). Hours are from 8a.m. to 7:00 p.m. Eastern Time, Monday through Friday (except Federal holidays). To provide qualityservice and ensure security, all telephone calls are recorded.

Thank you,Federal Communications Commission

Appendix E-8.1

TCNS ID No: 79109

Appendix E-8.1

TCNS ID No: 79109

From: towernotifyinfo@fcc.govTo: Rob KoppSubject: Proposed Tower Structure Info - Email ID #2866143Date: Friday, August 19, 2011 1:37:29 PM

Dear William Kopp,

Thank you for submitting a notification regarding your proposed construction via the Tower ConstructionNotification System. Note that the system has assigned a unique Notification ID number for thisproposed construction. You will need to reference this Notification ID number when you update yourproject's Status with us.

Below are the details you provided for the construction you have proposed:

Notification Received: 08/19/2011

Notification ID: 79110 Tower Owner Individual or Entity Name: Northwest Open Access Network Consultant Name: William Kopp Street Address: 5802 Overlook Avenue, NE City: Tacoma State: WASHINGTON Zip Code: 98422 Phone: 208-863-5346 Email: rkopp@noanet.net

Structure Type: POLE - Any type of Pole Latitude: 48 deg 1 min 59 sec N Longitude: 122 deg 45 min 7 sec W Location Description: 42 N Water Street City: Port Hadlock State: WASHINGTON County: JEFFERSON Ground Elevation: 2.7 meters Support Structure: 6.1 meters above ground level Overall Structure: 9.1 meters above ground level Overall Height AMSL: 11.8 meters above mean sea level

Appendix E-8.1

TCNS ID No: 79110

Appendix E-8.1

TCNS ID No: 79110

From: towernotifyinfo@fcc.govTo: Rob KoppCc: kim.pristello@fcc.gov; diane.dupert@fcc.govSubject: NOTICE OF ORGANIZATION(S) WHICH WERE SENT PROPOSED TOWER CONSTRUCTION NOTIFICATION

INFORMATION - Email ID #2867096Date: Friday, August 26, 2011 12:01:13 AM

Dear Sir or Madam:

Thank you for using the Federal Communications Commission's (FCC) Tower Construction NotificationSystem (TCNS). The purpose of this electronic mail message is to inform you that the followingauthorized persons were sent the information you provided through TCNS, which relates to yourproposed antenna structure. The information was forwarded by the FCC to authorized TCNS users byelectronic mail and/or regular mail (letter).

Persons who have received the information that you provided include leaders or their designees offederally-recognized American Indian Tribes, including Alaska Native Villages (collectively "Tribes"),Native Hawaiian Organizations (NHOs), and State Historic Preservation Officers (SHPOs). For yourconvenience in identifying the referenced Tribes and in making further contacts, the City and State ofthe Seat of Government for each Tribe and NHO, as well as the designated contact person, is includedin the listing below. We note that Tribes may have Section 106 cultural interests in ancestral homelandsor other locations that are far removed from their current Seat of Government. Pursuant to theCommission's rules as set forth in the Nationwide Programmatic Agreement for Review of Effects onHistoric Properties for Certain Undertakings Approved by the Federal Communications Commission(NPA), all Tribes and NHOs listed below must be afforded a reasonable opportunity to respond to thisnotification, consistent with the procedures set forth below, unless the proposed construction falls withinan exclusion designated by the Tribe or NHO. (NPA, Section IV.F.4).

The information you provided was forwarded to the following Tribes and NHOs who have set theirgeographic preferences on TCNS. If the information you provided relates to a proposed antennastructure in the State of Alaska, the following list also includes Tribes located in the State of Alaska thathave not specified their geographic preferences. For these Tribes and NHOs, if the Tribe or NHO doesnot respond within a reasonable time, you should make a reasonable effort at follow-up contact, unlessthe Tribe or NHO has agreed to different procedures (NPA, Section IV.F.5). In the event such a Tribe orNHO does not respond to a follow-up inquiry, or if a substantive or procedural disagreement arisesbetween you and a Tribe or NHO, you must seek guidance from the Commission (NPA, Section IV.G). These procedures are further set forth in the FCC's Declaratory Ruling released on October 6, 2005 (FCC05-176).

1. Cultural Resources Director Marie Hebert - Port Gamble S'Klallam Tribe - Kingston, WA - electronicmail and regular mail

2. Archaeologist Dennis E Lewarch - Suquamish Tribe - Suquamish, WA - electronic mail and regularmail

3. THPO Richard Young - Tulalip Tribes of the Tulalip Reservation - Tulalip, WA - electronic mail andregular mail

4. Cultural Resources Director Johnson Meninick - Yakama Nation - Toppenish, WA - electronic mail andregular mail

Appendix E-8.1

TCNS ID No: 79110

Details: If the Applicant/tower builder receives no response from the Yakama Nation within 30 daysafter notification through TCNS, the Yakama Nation has no interest in participating in pre-constructionreview for the proposed site. The Applicant/tower builder, however, must IMMEDIATELY notify theYakama Nation in the event archaeological properties or human remains are discovered duringconstruction, consistent with Section IX of the Nationwide Programmatic Agreement and applicable law.

5. Acting Executive Director Robert Smith - Hoh Tribe - Forks, WA - electronic mail and regular mail

6. Cultural Resources Officer Kathy Duncan - Jamestown S'Klallam Tribe - Sequim, WA - electronic mailand regular mail

7. IT Manager Gene Terry - Quinault Indian Nation - Taholah, WA - electronic mail

8. THPO and Director Janine Bowechop - Makah Tribe - Neah Bay, WA - electronic mail and regular mail

9. THPO Kris Miller - Skokomish Indian Tribe - Skokomish Nation, WA - electronic mail and regular mail

The information you provided was also forwarded to the additional Tribes and NHOs listed below. TheseTribes and NHOs have NOT set their geographic preferences on TCNS, and therefore they are currentlyreceiving tower notifications for the entire United States. For these Tribes and NHOs, you are requiredto use reasonable and good faith efforts to determine if the Tribe or NHO may attach religious andcultural significance to historic properties that may be affected by its proposed undertaking. Suchefforts may include, but are not limited to, seeking information from the relevant SHPO or THPO, IndianTribes, state agencies, the U.S. Bureau of Indian Affairs, or, where applicable, any federal agency withland holdings within the state (NPA, Section IV.B). If after such reasonable and good faith efforts, youdetermine that a Tribe or NHO may attach religious and cultural significance to historic properties in thearea and the Tribe or NHO does not respond to TCNS notification within a reasonable time, you shouldmake a reasonable effort to follow up, and must seek guidance from the Commission in the event ofcontinued non-response or in the event of a procedural or substantive disagreement. If you determinethat the Tribe or NHO is unlikely to attach religious and cultural significance to historic properties withinthe area, you do not need to take further action unless the Tribe or NHO indicates an interest in theproposed construction or other evidence of potential interest comes to your attention.

None

The information you provided was also forwarded to the following SHPOs in the State in which youpropose to construct and neighboring States. The information was provided to these SHPOs as acourtesy for their information and planning. You need make no effort at this time to follow up with anySHPO that does not respond to this notification. Prior to construction, you must provide the SHPO ofthe State in which you propose to construct (or the Tribal Historic Preservation Officer, if the project willbe located on certain Tribal lands), with a Submission Packet pursuant to Section VII.A of the NPA.

10. SHPO Allyson Brooks - Office of Archeology & Historic Preservation - Olympia, WA - electronic mail

11. Deputy SHPO Greg Griffith - Office of Archeology & Historic Preservation - Olympia, WA - electronic

Appendix E-8.1

TCNS ID No: 79110

mail

If you are proposing to construct a facility in the State of Alaska, you should contact Commission stafffor guidance regarding your obligations in the event that Tribes do not respond to this notificationwithin a reasonable time.

Please be advised that the FCC cannot guarantee that the contact(s) listed above opened and reviewedan electronic or regular mail notification. The following information relating to the proposed tower wasforwarded to the person(s) listed above:

Notification Received: 08/19/2011 Notification ID: 79110 Tower Owner Individual or Entity Name: Northwest Open Access Network Consultant Name: William Kopp Street Address: 5802 Overlook Avenue, NE City: Tacoma State: WASHINGTON Zip Code: 98422 Phone: 208-863-5346 Email: rkopp@noanet.net

Structure Type: POLE - Any type of Pole Latitude: 48 deg 1 min 59.0 sec N Longitude: 122 deg 45 min 7.0 sec W Location Description: 42 N Water Street City: Port Hadlock State: WASHINGTON County: JEFFERSON Ground Elevation: 2.7 meters Support Structure: 6.1 meters above ground level Overall Structure: 9.1 meters above ground level Overall Height AMSL: 11.8 meters above mean sea level

If you have any questions or comments regarding this notice, please contact the FCC using theelectronic mail form located on the FCC's website at:

http://wireless.fcc.gov/outreach/notification/contact-fcc.html.

You may also call the FCC Support Center at (877) 480-3201 (TTY 717-338-2824). Hours are from 8a.m. to 7:00 p.m. Eastern Time, Monday through Friday (except Federal holidays). To provide qualityservice and ensure security, all telephone calls are recorded.

Thank you,Federal Communications Commission

Appendix E-8.1

TCNS ID No: 79110

Appendix E-8.1

TCNS ID No: 79110

From: towernotifyinfo@fcc.govTo: Rob KoppSubject: Proposed Tower Structure Info - Email ID #2866146Date: Friday, August 19, 2011 1:39:45 PM

Dear William Kopp,

Thank you for submitting a notification regarding your proposed construction via the Tower ConstructionNotification System. Note that the system has assigned a unique Notification ID number for thisproposed construction. You will need to reference this Notification ID number when you update yourproject's Status with us.

Below are the details you provided for the construction you have proposed:

Notification Received: 08/19/2011

Notification ID: 79111 Tower Owner Individual or Entity Name: Northwest Open Access Network Consultant Name: William Kopp Street Address: 5802 Overlook Avenue, NE City: Tacoma State: WASHINGTON Zip Code: 98422 Phone: 208-863-5346 Email: rkopp@noanet.net

Structure Type: B - Building Latitude: 47 deg 49 min 24 sec N Longitude: 122 deg 52 min 30 sec W Location Description: 294715 Highway 1 City: Quilcene State: WASHINGTON County: JEFFERSON Ground Elevation: 12.2 meters Support Structure: 6.1 meters above ground level Overall Structure: 6.1 meters above ground level Overall Height AMSL: 18.3 meters above mean sea level

Appendix E-8.1

TCNS ID No: 79111

Appendix E-8.1

TCNS ID No: 79111

From: towernotifyinfo@fcc.govTo: Rob KoppCc: kim.pristello@fcc.gov; diane.dupert@fcc.govSubject: NOTICE OF ORGANIZATION(S) WHICH WERE SENT PROPOSED TOWER CONSTRUCTION NOTIFICATION

INFORMATION - Email ID #2867107Date: Friday, August 26, 2011 12:01:15 AM

Dear Sir or Madam:

Thank you for using the Federal Communications Commission's (FCC) Tower Construction NotificationSystem (TCNS). The purpose of this electronic mail message is to inform you that the followingauthorized persons were sent the information you provided through TCNS, which relates to yourproposed antenna structure. The information was forwarded by the FCC to authorized TCNS users byelectronic mail and/or regular mail (letter).

Persons who have received the information that you provided include leaders or their designees offederally-recognized American Indian Tribes, including Alaska Native Villages (collectively "Tribes"),Native Hawaiian Organizations (NHOs), and State Historic Preservation Officers (SHPOs). For yourconvenience in identifying the referenced Tribes and in making further contacts, the City and State ofthe Seat of Government for each Tribe and NHO, as well as the designated contact person, is includedin the listing below. We note that Tribes may have Section 106 cultural interests in ancestral homelandsor other locations that are far removed from their current Seat of Government. Pursuant to theCommission's rules as set forth in the Nationwide Programmatic Agreement for Review of Effects onHistoric Properties for Certain Undertakings Approved by the Federal Communications Commission(NPA), all Tribes and NHOs listed below must be afforded a reasonable opportunity to respond to thisnotification, consistent with the procedures set forth below, unless the proposed construction falls withinan exclusion designated by the Tribe or NHO. (NPA, Section IV.F.4).

The information you provided was forwarded to the following Tribes and NHOs who have set theirgeographic preferences on TCNS. If the information you provided relates to a proposed antennastructure in the State of Alaska, the following list also includes Tribes located in the State of Alaska thathave not specified their geographic preferences. For these Tribes and NHOs, if the Tribe or NHO doesnot respond within a reasonable time, you should make a reasonable effort at follow-up contact, unlessthe Tribe or NHO has agreed to different procedures (NPA, Section IV.F.5). In the event such a Tribe orNHO does not respond to a follow-up inquiry, or if a substantive or procedural disagreement arisesbetween you and a Tribe or NHO, you must seek guidance from the Commission (NPA, Section IV.G). These procedures are further set forth in the FCC's Declaratory Ruling released on October 6, 2005 (FCC05-176).

1. Cultural Resources Director Marie Hebert - Port Gamble S'Klallam Tribe - Kingston, WA - electronicmail and regular mail

2. Archaeologist Dennis E Lewarch - Suquamish Tribe - Suquamish, WA - electronic mail and regularmail

3. THPO Richard Young - Tulalip Tribes of the Tulalip Reservation - Tulalip, WA - electronic mail andregular mail

4. Cultural Resources Director Johnson Meninick - Yakama Nation - Toppenish, WA - electronic mail andregular mail

Appendix E-8.1

TCNS ID No: 79111

Details: If the Applicant/tower builder receives no response from the Yakama Nation within 30 daysafter notification through TCNS, the Yakama Nation has no interest in participating in pre-constructionreview for the proposed site. The Applicant/tower builder, however, must IMMEDIATELY notify theYakama Nation in the event archaeological properties or human remains are discovered duringconstruction, consistent with Section IX of the Nationwide Programmatic Agreement and applicable law.

5. Acting Executive Director Robert Smith - Hoh Tribe - Forks, WA - electronic mail and regular mail

6. Cultural Resources Officer Kathy Duncan - Jamestown S'Klallam Tribe - Sequim, WA - electronic mailand regular mail

7. IT Manager Gene Terry - Quinault Indian Nation - Taholah, WA - electronic mail

8. THPO and Director Janine Bowechop - Makah Tribe - Neah Bay, WA - electronic mail and regular mail

9. THPO Kris Miller - Skokomish Indian Tribe - Skokomish Nation, WA - electronic mail and regular mail

The information you provided was also forwarded to the additional Tribes and NHOs listed below. TheseTribes and NHOs have NOT set their geographic preferences on TCNS, and therefore they are currentlyreceiving tower notifications for the entire United States. For these Tribes and NHOs, you are requiredto use reasonable and good faith efforts to determine if the Tribe or NHO may attach religious andcultural significance to historic properties that may be affected by its proposed undertaking. Suchefforts may include, but are not limited to, seeking information from the relevant SHPO or THPO, IndianTribes, state agencies, the U.S. Bureau of Indian Affairs, or, where applicable, any federal agency withland holdings within the state (NPA, Section IV.B). If after such reasonable and good faith efforts, youdetermine that a Tribe or NHO may attach religious and cultural significance to historic properties in thearea and the Tribe or NHO does not respond to TCNS notification within a reasonable time, you shouldmake a reasonable effort to follow up, and must seek guidance from the Commission in the event ofcontinued non-response or in the event of a procedural or substantive disagreement. If you determinethat the Tribe or NHO is unlikely to attach religious and cultural significance to historic properties withinthe area, you do not need to take further action unless the Tribe or NHO indicates an interest in theproposed construction or other evidence of potential interest comes to your attention.

None

The information you provided was also forwarded to the following SHPOs in the State in which youpropose to construct and neighboring States. The information was provided to these SHPOs as acourtesy for their information and planning. You need make no effort at this time to follow up with anySHPO that does not respond to this notification. Prior to construction, you must provide the SHPO ofthe State in which you propose to construct (or the Tribal Historic Preservation Officer, if the project willbe located on certain Tribal lands), with a Submission Packet pursuant to Section VII.A of the NPA.

10. SHPO Allyson Brooks - Office of Archeology & Historic Preservation - Olympia, WA - electronic mail

11. Deputy SHPO Greg Griffith - Office of Archeology & Historic Preservation - Olympia, WA - electronic

Appendix E-8.1

TCNS ID No: 79111

mail

If you are proposing to construct a facility in the State of Alaska, you should contact Commission stafffor guidance regarding your obligations in the event that Tribes do not respond to this notificationwithin a reasonable time.

Please be advised that the FCC cannot guarantee that the contact(s) listed above opened and reviewedan electronic or regular mail notification. The following information relating to the proposed tower wasforwarded to the person(s) listed above:

Notification Received: 08/19/2011 Notification ID: 79111 Tower Owner Individual or Entity Name: Northwest Open Access Network Consultant Name: William Kopp Street Address: 5802 Overlook Avenue, NE City: Tacoma State: WASHINGTON Zip Code: 98422 Phone: 208-863-5346 Email: rkopp@noanet.net

Structure Type: B - Building Latitude: 47 deg 49 min 24.0 sec N Longitude: 122 deg 52 min 30.0 sec W Location Description: 294715 Highway 1 City: Quilcene State: WASHINGTON County: JEFFERSON Ground Elevation: 12.2 meters Support Structure: 6.1 meters above ground level Overall Structure: 6.1 meters above ground level Overall Height AMSL: 18.3 meters above mean sea level

If you have any questions or comments regarding this notice, please contact the FCC using theelectronic mail form located on the FCC's website at:

http://wireless.fcc.gov/outreach/notification/contact-fcc.html.

You may also call the FCC Support Center at (877) 480-3201 (TTY 717-338-2824). Hours are from 8a.m. to 7:00 p.m. Eastern Time, Monday through Friday (except Federal holidays). To provide qualityservice and ensure security, all telephone calls are recorded.

Thank you,Federal Communications Commission

Appendix E-8.1

TCNS ID No: 79111

Appendix E-8.1

TCNS ID No: 79111

From: towernotifyinfo@fcc.govTo: Rob KoppSubject: Proposed Tower Structure Info - Email ID #2866147Date: Friday, August 19, 2011 1:44:55 PM

Dear William Kopp,

Thank you for submitting a notification regarding your proposed construction via the Tower ConstructionNotification System. Note that the system has assigned a unique Notification ID number for thisproposed construction. You will need to reference this Notification ID number when you update yourproject's Status with us.

Below are the details you provided for the construction you have proposed:

Notification Received: 08/19/2011

Notification ID: 79112 Tower Owner Individual or Entity Name: Northwest Open Access Network Consultant Name: William Kopp Street Address: 5802 Overlook Avenue, NE City: Tacoma State: WASHINGTON Zip Code: 98422 Phone: 208-863-5346 Email: rkopp@noanet.net

Structure Type: UTOWER - Unguyed - Free Standing Tower Latitude: 47 deg 34 min 36 sec N Longitude: 117 deg 17 min 57 sec W Location Description: SE 1/4 NW 1/4 NW 1/4 T24N R44E S18 City: Spokane State: WASHINGTON County: SPOKANE Ground Elevation: 1097.3 meters Support Structure: 45.7 meters above ground level Overall Structure: 45.7 meters above ground level Overall Height AMSL: 1143 meters above mean sea level

Appendix E-8.1

TCNS ID No: 79112

Appendix E-8.1

TCNS ID No: 79112

From: towernotifyinfo@fcc.govTo: Rob KoppCc: kim.pristello@fcc.gov; diane.dupert@fcc.govSubject: NOTICE OF ORGANIZATION(S) WHICH WERE SENT PROPOSED TOWER CONSTRUCTION NOTIFICATION

INFORMATION - Email ID #2867118Date: Friday, August 26, 2011 12:01:16 AM

Dear Sir or Madam:

Thank you for using the Federal Communications Commission's (FCC) Tower Construction NotificationSystem (TCNS). The purpose of this electronic mail message is to inform you that the followingauthorized persons were sent the information you provided through TCNS, which relates to yourproposed antenna structure. The information was forwarded by the FCC to authorized TCNS users byelectronic mail and/or regular mail (letter).

Persons who have received the information that you provided include leaders or their designees offederally-recognized American Indian Tribes, including Alaska Native Villages (collectively "Tribes"),Native Hawaiian Organizations (NHOs), and State Historic Preservation Officers (SHPOs). For yourconvenience in identifying the referenced Tribes and in making further contacts, the City and State ofthe Seat of Government for each Tribe and NHO, as well as the designated contact person, is includedin the listing below. We note that Tribes may have Section 106 cultural interests in ancestral homelandsor other locations that are far removed from their current Seat of Government. Pursuant to theCommission's rules as set forth in the Nationwide Programmatic Agreement for Review of Effects onHistoric Properties for Certain Undertakings Approved by the Federal Communications Commission(NPA), all Tribes and NHOs listed below must be afforded a reasonable opportunity to respond to thisnotification, consistent with the procedures set forth below, unless the proposed construction falls withinan exclusion designated by the Tribe or NHO. (NPA, Section IV.F.4).

The information you provided was forwarded to the following Tribes and NHOs who have set theirgeographic preferences on TCNS. If the information you provided relates to a proposed antennastructure in the State of Alaska, the following list also includes Tribes located in the State of Alaska thathave not specified their geographic preferences. For these Tribes and NHOs, if the Tribe or NHO doesnot respond within a reasonable time, you should make a reasonable effort at follow-up contact, unlessthe Tribe or NHO has agreed to different procedures (NPA, Section IV.F.5). In the event such a Tribe orNHO does not respond to a follow-up inquiry, or if a substantive or procedural disagreement arisesbetween you and a Tribe or NHO, you must seek guidance from the Commission (NPA, Section IV.G). These procedures are further set forth in the FCC's Declaratory Ruling released on October 6, 2005 (FCC05-176).

1. Cultural Resources Director Johnson Meninick - Yakama Nation - Toppenish, WA - electronic mail andregular mailDetails: If the Applicant/tower builder receives no response from the Yakama Nation within 30 daysafter notification through TCNS, the Yakama Nation has no interest in participating in pre-constructionreview for the proposed site. The Applicant/tower builder, however, must IMMEDIATELY notify theYakama Nation in the event archaeological properties or human remains are discovered duringconstruction, consistent with Section IX of the Nationwide Programmatic Agreement and applicable law.

2. THPO Jill M Wagner PhD - Coeur d'Alene Tribal Council - Plummer, ID - electronic mail and regularmail

3. Tribal Historic Preservation Officer Camille Pleasants - Confederated Tribes of the Colville Reservation- Nespelem, WA - regular mail

Appendix E-8.1

TCNS ID No: 79112

4. Tribal Compliance Manager Clarinda Burke - Confederated Salish and Kootenai Tribes of the FlatheadNation - Pablo, MT - electronic mailDetails: If the Applicant/tower constructor receives no response from the Confederated Salish andKootenai Tribes of the Flathead Nation within 30 days after notification through TCNS, the ConfederatedSalish and Kootenai Tribes of the Flathead Nation has no interest in participating in pre-constructionreview for the site. The applicant/tower builder, however, must IMMEDIATELY notify the ConfederatedSalish and Kootenai Tribes of the Flathead Nation in the event archaeological properties or humanremains are discovered during construction, consistent with Section IX of the Nationwide ProgrammaticAgreement and applicable law.

5. THPO Randy Abrahamson - Spokane Tribe of Indians - Wellpinit, WA - electronic mail and regularmailDetails: The Spokane Tribe of Indians REQUIRES the township range and section for each proposedproject. We are unable to make a determination until we have received this information. Pleaseprovide the township range and section for the proposed project in an attachment when you first submityour tower notification to TCNS, or e-mail this information to me separately. If e-mailed separately,please provide the TCNS number in the subject line of your e-mail. Thank you.Randy Abrahamson, THPOSpokane Tribeof Indiansrandya@spokanetribe.com

The information you provided was also forwarded to the additional Tribes and NHOs listed below. TheseTribes and NHOs have NOT set their geographic preferences on TCNS, and therefore they are currentlyreceiving tower notifications for the entire United States. For these Tribes and NHOs, you are requiredto use reasonable and good faith efforts to determine if the Tribe or NHO may attach religious andcultural significance to historic properties that may be affected by its proposed undertaking. Suchefforts may include, but are not limited to, seeking information from the relevant SHPO or THPO, IndianTribes, state agencies, the U.S. Bureau of Indian Affairs, or, where applicable, any federal agency withland holdings within the state (NPA, Section IV.B). If after such reasonable and good faith efforts, youdetermine that a Tribe or NHO may attach religious and cultural significance to historic properties in thearea and the Tribe or NHO does not respond to TCNS notification within a reasonable time, you shouldmake a reasonable effort to follow up, and must seek guidance from the Commission in the event ofcontinued non-response or in the event of a procedural or substantive disagreement. If you determinethat the Tribe or NHO is unlikely to attach religious and cultural significance to historic properties withinthe area, you do not need to take further action unless the Tribe or NHO indicates an interest in theproposed construction or other evidence of potential interest comes to your attention.

None

The information you provided was also forwarded to the following SHPOs in the State in which youpropose to construct and neighboring States. The information was provided to these SHPOs as acourtesy for their information and planning. You need make no effort at this time to follow up with anySHPO that does not respond to this notification. Prior to construction, you must provide the SHPO ofthe State in which you propose to construct (or the Tribal Historic Preservation Officer, if the project willbe located on certain Tribal lands), with a Submission Packet pursuant to Section VII.A of the NPA.

6. SHPO Allyson Brooks - Office of Archeology & Historic Preservation - Olympia, WA - electronic mail

7. Deputy SHPO Greg Griffith - Office of Archeology & Historic Preservation - Olympia, WA - electronic

Appendix E-8.1

TCNS ID No: 79112

mail

If you are proposing to construct a facility in the State of Alaska, you should contact Commission stafffor guidance regarding your obligations in the event that Tribes do not respond to this notificationwithin a reasonable time.

Please be advised that the FCC cannot guarantee that the contact(s) listed above opened and reviewedan electronic or regular mail notification. The following information relating to the proposed tower wasforwarded to the person(s) listed above:

Notification Received: 08/19/2011 Notification ID: 79112 Tower Owner Individual or Entity Name: Northwest Open Access Network Consultant Name: William Kopp Street Address: 5802 Overlook Avenue, NE City: Tacoma State: WASHINGTON Zip Code: 98422 Phone: 208-863-5346 Email: rkopp@noanet.net

Structure Type: UTOWER - Unguyed - Free Standing Tower Latitude: 47 deg 34 min 36.0 sec N Longitude: 117 deg 17 min 57.0 sec W Location Description: SE 1/4 NW 1/4 NW 1/4 T24N R44E S18 City: Spokane State: WASHINGTON County: SPOKANE Ground Elevation: 1097.3 meters Support Structure: 45.7 meters above ground level Overall Structure: 45.7 meters above ground level Overall Height AMSL: 1143.0 meters above mean sea level

If you have any questions or comments regarding this notice, please contact the FCC using theelectronic mail form located on the FCC's website at:

http://wireless.fcc.gov/outreach/notification/contact-fcc.html.

You may also call the FCC Support Center at (877) 480-3201 (TTY 717-338-2824). Hours are from 8a.m. to 7:00 p.m. Eastern Time, Monday through Friday (except Federal holidays). To provide qualityservice and ensure security, all telephone calls are recorded.

Thank you,Federal Communications Commission

Appendix E-8.1

TCNS ID No: 79112

Appendix E-8.1

TCNS ID No: 79112

From: towernotifyinfo@fcc.govTo: Rob KoppCc: tcns.fccarchive@fcc.gov; randya@spokanetribe.comSubject: Reply to Proposed Tower Structure (Notification ID: 79112) - Email ID #2872625Date: Monday, August 29, 2011 10:38:01 AM

Dear William Kopp,

Thank you for using the Federal Communications Commission's (FCC) Tower Construction NotificationSystem (TCNS). The purpose of this email is to inform you that an authorized user of the TCNS hasreplied to a proposed tower construction notification that you had submitted through the TCNS.

The following message has been sent to you from THPO Randy Abrahamson of the Spokane Tribe ofIndians in reference to Notification ID #79112:

We have no interest in this site. However, if the Applicant discovers archaeological remains or resourcesduring construction, the Applicant should immediately stop construction and notify the appropriateFederal Agency and the Tribe.

For your convenience, the information you submitted for this notification is detailed below.

Notification Received: 08/19/2011 Notification ID: 79112 Tower Owner Individual or Entity Name: Northwest Open Access Network Consultant Name: William Kopp Street Address: 5802 Overlook Avenue, NE City: Tacoma State: WASHINGTON Zip Code: 98422 Phone: 208-863-5346 Email: rkopp@noanet.net

Structure Type: UTOWER - Unguyed - Free Standing Tower Latitude: 47 deg 34 min 36.0 sec N Longitude: 117 deg 17 min 57.0 sec W Location Description: SE 1/4 NW 1/4 NW 1/4 T24N R44E S18 City: Spokane State: WASHINGTON County: SPOKANE Ground Elevation: 1097.3 meters Support Structure: 45.7 meters above ground level Overall Structure: 45.7 meters above ground level Overall Height AMSL: 1143.0 meters above mean sea level

Appendix E-8.1

TCNS ID No: 79112

Appendix E-9

4/19/2011 Letter from Kalispell tribe concurring

with finding of No Adverse Effect

Appendix E-10

4/27/11 Email response from Nooksack tribe

 

Appendix E-11

4/26/2011 Letter from Yakama Nation to NTIA

stating that they do not concur with the finding of

No Adverse Effect

1

Susan Boyd

From: Rob Kopp [rkopp@noanet.net]Sent: Thursday, July 14, 2011 1:29 PMTo: Susan Boyd; 'Jennifer Hushour' (jhushour@tierra-row.com)Cc: Chantel DeMastersSubject: Yakima Nation

Susan,   This e‐mail serves as an update regarding the Yakima Nation consultation for NoaNet’s Round II BTOP Project.  Upon receipt of the letter dated April 26th sent by the Yakima Nation to the NTIA disagreeing with our determination of “No Impact to Cultural Resources” NoaNet’s Executive; Mike Henson contacted Yakima Nation management within the Yakima Power organization, which is tribal owned and has been collaborating with NoaNet for the project, to ask if they would communicate to the THPO for the Yakima Nation and request that a new letter is drafted concurring with our determination of “No Impact to Cultural Resources with language that NoaNet will not utilize any resource other than Yakima Nation assigned resources for all Cultural and Construction activities under the project.  Mr. Henson was told that the THPO was to draft the new letter and transmit directly to the NTIA.  To date, we have not been notified by the NTIA that a revised letter of concurrence has been received and multiple follow up calls and e‐mails into the Yakima Power contacts have not been  successful in determining current state.  As you know we are submitting an updated EA to the NTIA tomorrow.  Please insert this e‐mail into the communication plan.  My communication to NTIA is suggesting that the NTIA write the FONSI with a condition that NoaNet will not proceed with any work on projects within Yakima Nation reservation lands until concurrence is received and agreed to by NTIA and NoaNet.  Thanks rob 

 

Appendix E-12

5/2/2011 Email to Upper Skagit tribe transmitting

cultural resources report

upper_skagit From: Barbara K Montgomery [bmontgomery@tierra-row.com] Sent: Monday, May 02, 2011 5:59 PM

To: Scott Schuyler Cc: rkopp@noanet.net; Chantel DeMasters; Jen Hushour

Subject: Cultural Resources Records Review for NoaNet's BTOP Round II Project Attachments: shrunk_2.21.11_NC_draft_report.pdf

Mr. Schuyler,

It has come to my attention, through NoaNet and Chris Banchero, that you need a copy of the records review report that Tierra Right of Way Services has produced, which covers the three NoaNet routes in north-central Washington. The report is attached. It is a large file that may not go through the email so please send a quick email back to me acknowledging that you received it. I will also be sending another email with two more smaller attachments, including a transmittal letter from NTIA (US Dept of Commerce), who is the lead federal agency for this project.

This project, as you probably know, will not be producing any ground disturbance as a result of construction on reservation lands. Only about 1/10th of a mile of aerially installed fiber on existing poles will be involved. Nevertheless, NTIA is submitting the records review report which covers your region of Washington state. Please let them know if you have any concerns.

Sincerely,Barbara MontgomeryPrincipal Investigator, Cultural Resources Division

*********************************************************

Barbara K. Montgomery, Ph.D.Principal InvestigatorTierra Right of Way Services, Ltd.bmontgomery@tierra-row.com(520) 319-2106

Your Permit To ProceedThis message, including any attachments, contains confidential information intended for a specific individual and purpose, and is protected by law. Any disclosure, copying, or distribution of this message or the taking of any action based on it, without the express written consent of Tierra Right of Way Services is strictly prohibited.**********************************************************

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