Final Environmental Assessment Merit Reach-3Mc Ii

FINAL ENVIRONMENTAL ASSESSMENT

MERIT REACH-3MC II - (Rural, Education, Anchor, Community & Healthcare – Michigan Middle

Mile Collaborative)

PROJECT

Prepared for: Prepared by: National Telecommunications and Information Administration (NTIA)

On behalf of: Environmental Consulting & Technology, Inc. 2200 Commonwealth Blvd., Ste. 300 Merit Network, Inc. Ann Arbor, MI 48105 1000 Oakbrook Drive Ph: (734) 769-3004 Ann Arbor, Michigan 48104-6794 Fax: (734) 769-3164

July 15, 2011 TABLE OF CONTENTS

Section Pag e EXECUTIVE SUMMARY ...... 1

1.0 CHAPTER 1 - PURPOSE AND NEED ...... 5 1.1 PROJECT INTRODUCTION ...... 5 1.2 PROJECT PURPOSE ...... 7 1.3 PROJECT NEED ...... 7

2.0 CHAPTER 2 - DESCRIPTION OF PROPOSED ACTION AND ALTERNATIVES ...... 11 2.1 PROJECT DESCRIPTION ...... 11 2.1.1 Project Construction ...... 16 2.1.2 Alternatives Included in Proposed Project Description ...... 19 2.2 GEOGRAPHIC SETTING ...... 24 2.2.1 Middle Corridor (Figure 2.2.1) ...... 24 2.2.2 Northeastern Corridor (Figure 2.2.2) ...... 26 2.2.3 Northern Corridor (Figures 2.2.3a and b) ...... 26 2.2.4 Green Bay Spur (Figure 2.2.3b) ...... 26 2.2.5 Duluth Spur (Figure 2.2.4) ...... 26 2.3 ALTERNATIVES ...... 31 2.3.1 No Action Alternative ...... 31 2.3.2 Preferred Alternative (Proposed Action) ...... 32 2.3.3 Alternatives Considered but Eliminated from Further Discussion ...... 32

3.0 CHAPTER 3 - DESCRIPTION OF THE AFFECTED ENVIRONMENT ...... 34 3.1 NOISE ...... 34 3.2 AIR QUALITY ...... 34 3.2.1 Climate, Greenhouse Gases and Global Warming ...... 34 3.3 GEOLOGY AND SOILS ...... 38 3.4 WATER RESOURCES ...... 39 3.4.1 Surface Water ...... 39 3.4.2 Groundwater ...... 40 3.4.3 Wetlands ...... 44 3.4.4 Coastal Zones ...... 45 3.4.5 Environmental Areas ...... 48

Merit REACH-3MC II Final Environmental Assessment (7/15/2011) i 3.4.6 Critical Dune Areas ...... 48 3.4.7 Floodplains ...... 48 3.4.8 Designated Wild and Scenic Rivers ...... 50 3.4.9 State-Designated Rivers ...... 50 3.5 BIOLOGICAL RESOURCES ...... 57 3.5.1 Ecoregions ...... 57 3.5.2 Wildlife ...... 57 3.5.3 Vegetation ...... 58 3.5.4 Threatened and Endangered Species and Critical Habitats ...... 58 3.5.4.1 Federal Threatened and Endangered Species ...... 59 3.5.4.2 Michigan Threatened and Endangered Species ...... 59 3.5.4.3 Wisconsin Threatened and Endangered Species ...... 61 3.5.4.4 Minnesota Threatened and Endangered Species ...... 65 3.5.5 Wetland Habitat ...... 65 3.6 HISTORIC AND CULTURAL RESOURCES ...... 66 3.6.1 Archaeological Resources ...... 66 3.6.2 Architectural Resources ...... 66 3.6.3 Native Resources ...... 67 3.7 AESTHETIC AND VISUAL RESOURCES ...... 69 3.8 LAND USE ...... 69 3.9 INFRASTRUCTURE ...... 75 3.10 SOCIOECONOMIC RESOURCES...... 75 3.11 HUMAN HEALTH AND SAFETY ...... 77 3.11.1 Public and Worker Safety ...... 77 3.11.2 Brownfields ...... 77

4.0 CHAPTER 4 - ANALYSIS OF ENVIRONMENTAL IMPACTS ...... 79 4.1 NOISE ...... 79 4.2 AIR QUALITY ...... 79 4.3 GEOLOGY AND SOILS ...... 79 4.4 WATER RESOURCES ...... 80 4.4.1 Surface Water ...... 80 4.4.2 Groundwater ...... 80 4.4.3 Wetlands ...... 81 4.4.4 Coastal Zones ...... 82 4.4.5 Environmental Areas ...... 82

Merit REACH-3MC II Final Environmental Assessment (7/15/2011) ii 4.4.6 Critical Dune Areas ...... 83 4.4.7 Floodplains ...... 83 4.4.8 Designated Wild and Scenic Rivers ...... 83 4.4.9 State-Designated Rivers ...... 84 4.5 BIOLOGICAL RESOURCES ...... 84 4.5.1 Ecoregions ...... 84 4.5.2 Wildlife ...... 84 4.5.3 Vegetation ...... 84 4.5.4 Threatened and Endangered Species and Critical Habitats ...... 85 4.5.4.1 Federal Threatened and Endangered Species ...... 85 4.5.4.2 Michigan Threatened and Endangered Species ...... 85 4.5.4.3 Wisconsin Threatened and Endangered Species ...... 98 4.5.4.4 Minnesota Threatened and Endangered Species ...... 121 4.5.5 Wetland Habitat ...... 121 4.6 HISTORIC AND CULTURAL RESOURCES ...... 122 4.6.1 Archaeological Resources ...... 122 4.6.2 Architectural Resources ...... 123 4.6.3 Native Resources ...... 123 4.7 AESTHETIC AND VISUAL RESOURCES ...... 125 4.8 LAND USE ...... 126 4.9 INFRASTRUCTURE ...... 126 4.10 SOCIOECONOMIC RESOURCES...... 127 4.11 HUMAN HEALTH AND SAFETY ...... 128 4.11.1 Public and Worker Safety ...... 128 4.11.2 Brownfields ...... 128 4.12 CUMULATIVE IMPACTS ...... 128 4.13 SUMMARY OF IMPACTS TO RESOURCE AREAS ...... 129

5.0 CHAPTER 5 - APPLICABLE ENVIRONMENTAL PERMITS & REGULATORY REQUIREMENTS ...... 131

6.0 CHAPTER 6 - LIST OF AGENCIES AND PERSONS CONSULTED ...... 136

7.0 CHAPTER 7 - REFERENCES ...... 142

Merit REACH-3MC II Final Environmental Assessment (7/15/2011) iii List of Figures Page Figure 1.1.1 REACH-3MC II Project Location Map ...... 6 Figure 2.1.1 Proposed Project Corridor and Spurs ...... 14 Figure 2.1.2 Proposed Hut Locations ...... 15 Figure 2.2.1 Middle Corridor and Spurs...... 25 Figure 2.2.2 Northeastern Corridor ...... 27 Figure 2.2.3a Northern Corridor and Spurs ...... 28 Figure 2.2.3b Northern Corridor and Spurs, Green Bay Spur ...... 29 Figure 2.2.4 Duluth Spur ...... 30 Figure 3.3.1a Regional Landscape Ecosystems of the Project Area – Michigan ...... 36 Figure 3.3.1b Regional Landscape Ecosystems of the Project Area – Wisconsin and Minnesota ...... 37 Figure 3.4.8.1 Wild and Scenic River Crossing Map ...... 55 Figure 3.4.9.1 Overall Designated River Crossing Map ...... 56 Figure 3.6.3.1 Proposed Route Across Bad River Indian Reservation ...... 68

List of Tables Page Table 2.1.1 Statewide Summary of the REACH-3MC II Project ...... 12 Table 2.1.2 Summary of Hut Locations ...... 13 Table 2.1.3 Summary of Dual Option Areas ...... 21 Table 2.1.4 Summary of CAI Services Areas Update ...... 23 Table 3.2.1 Class I Areas Within 100 Miles of Proposed Project ...... 34 Table 3.4.1.1 Summary of Surface Water Crossings ...... 41 Table 3.4.4.1 Summary of Michigan Coastal Zone Crossings ...... 46 Table 3.4.4.2 Summary of Wisconsin Coastal Zone Crossings ...... 47 Table 3.4.5.1 Summary of Environmental Areas ...... 49 Table 3.4.8.1 Summary of Designated River Crossings ...... 51 Table 3.5.4.1 Summary of Known Element Occurences for Michigan ...... 60 Table 3.5.4.2 Summary of Known Element Occurences for Wisconsin ...... 62 Table 3.5.4.3 Summary of Known Element Occurences for Minnesota ...... 65 Table 3.8.1 Summary of Public Land Crossings ...... 71 Table 3.8.2 Summary of Existing Land Uses at Hut Locations ...... 73 Table 3.8.3 Summary of National Forest Crossing ...... 74 Table 3.10.1 Summary of Vulnerable Population Data per 2000 Census ...... 76 Table 4.5.4.1 Summary of MiDNRE Review for Known Element Occurrences ...... 87 Table 4.5.4.2 Summary of WiDNRE Review for Known Element Occurrences ...... 99 Table 4.13.1 Summary of Impacts to Resource Areas ...... 130

Merit REACH-3MC II Final Environmental Assessment (7/15/2011) iv APPENDICES Appendix A - Project Route Photographs Appendix B - Hut Location Photographs Appendix C - Photographs of a Typical Hut Appendix D - Dual Option Area Location Maps Appendix E - CAI Service Area Location Maps Appendix F - Agency Correspondence F-1 - Michigan Department of Natural Resources and Environment F-2 - Wisconsin Department of Natural Resources F-3 - Minnesota Department of Natural Resources F-4 - U.S. Army Corps of Engineers F-5 - U.S. Fish and Wildlife Service F-6 - U.S. Forest Service F-7 - State Historic Preservation Offices F-8 - Tribal Historic Preservation Offices F-9 - Michigan Department of Transportation Appendix G- Surface Water Crossing Maps Appendix H - Wetland Crossing Maps and Tables Appendix I - Coastal Zone Crossing Maps Appendix J - Environmental Area Maps Appendix K - Existing Land Use Maps Appendix L - Public Land Crossing Maps

Merit REACH-3MC II Final Environmental Assessment (7/15/2011) v EXECUTIVE SUMMARY

In August 2010, the National Telecommunications and Information Administration (NTIA) awarded a $69.6 million federal grant through its American Recovery and Reinvestment Act (ARRA, aka the federal stimulus package) funded Broadband Technology Opportunities Program (BTOP) to Merit Network, Inc. (Merit). As a recipient of this federal grant, Merit is submitting the following Environmental Assessment (EA) to NTIA in compliance with the National Environmental Policy Act (NEPA).

Merit is proposing to build the Rural, Education, Anchor, Community and Healthcare – Michigan Middle Mile Collaborative Project (REACH-3MC II) (the Project), a 1,263 mile long advanced fiber-optic network through underserved counties in Michigan’s Upper and Lower Peninsulas with diverse paths to Wisconsin and Minnesota. In addition, Merit will purchase approximately 60 miles of existing fiber infrastructure and one telecommunication hut. The Project is a unique relationship between Merit, one public and seven private sector entities that provide high- performance broadband middle and last mile services, namely, the Michigan 911 Administrator’s Office, ACD.Net, Boardman River Communications, CCI Systems, Great Lakes Comnet, Lynx Network Group, and Peninsula Fiber Network. The Project will engage citizens in Michigan, Wisconsin and Minnesota in the digital economy by providing affordable, high-performance broadband Internet, voice, and video services to homes, businesses, and statewide community anchor institution (CAIs) in 29 Michigan counties in both the Upper and Lower Peninsulas, eight in Wisconsin and one in Minnesota. Of these 38 counties, 29 are underserved and eight have underserved areas. Additionally, the Project creates opportunities to provide high-speed capabilities to four Native American tribes in the region: Sault Ste. Marie Tribe of Chippewa Indians, Little Traverse Bay Band of Odawa Indians, Hannahville Indian Community, and the Bad River Band of the Lake Superior Chippewa.

Merit Network, Inc., a not-for-profit broadband service provider, has built and run networks for anchor institutions throughout the State of Michigan for 44 years, supporting the education and not-for-profit community. Michigan State University uses Merit’s network and high definition video to teach remote medical school classes around the state. Merit currently operates over 1,600 fiber miles, including the Michigan Lambda Rail and Blue Line fiber projects in its network. Merit is owned and governed by the following Michigan universities: Grand Valley State, Ferris State, Michigan State, Central Michigan, Western Michigan, The University of Michigan, Northern Michigan, Lake Superior State, Michigan Technological, Wayne State, Eastern Michigan, and Oakland. Merit provides high-performance networking and services to the research and education communities in Michigan. Specific Project objectives include the following:

• Foster economic development and growth in underserved areas of Michigan, Wisconsin and Minnesota that lack widely available and affordable broadband services. • Offer fiber services and speeds from 1.5 Mbps to 10 Gbps to a service area with more than 781,700 CAIs, households, and businesses. • Collaborate with sub-recipients to offer broadband Internet, voice, and video services to households and businesses. • Compliment Merit’s $33M BTOP Round One infrastructure award for west, south, east and central Michigan by leveraging its platform, billing, and operations.

The Project proposes to immediately connect 61 CAIs including libraries, universities, community colleges, and community healthcare centers, and pass 759 CAIs in the service area. The fiber network will pass approximately 731,237 households and 49,661 businesses. The fiber infrastructure project will use existing road and utility rights- of-way (ROW’s) for the entire 1,263 miles of the route. The proposed fiber optic cable will be installed using a combination of aerial and underground construction methods. Aerial construction involves hanging fiber on existing utility poles with some poles being replaced as needed. Underground construction will consist of vibratory plowing, directional drilling, and utilization of existing underground conduit where available. Directional boring will be used,

Merit REACH-3MC II Final Environmental Assessment (7/15/2011) 1 where feasible, in environmentally sensitive areas such are stream and river crossings, sensitive wetland crossings and rare species habitats. Plowing will be used for the remaining underground construction, especially where the lines parallel roadways and in disturbed urban areas lacking significant natural and cultural resources. No new utility corridors will be created. Environmental impacts will be minimized through the utilization of existing, disturbed road and utility ROW’s for the entire length of the project.

The proposed construction methods identified in the Environmental Assessment are based on preliminary engineering studies; however, it may be necessary to substitute underground construction for aerial construction in certain locations for a variety of reasons including, but not limited to the following:

• Merit’s ability to enter into pole attachment agreements with existing pole owners; • the condition of existing poles and the ability of pole owners to complete “make ready” activities in a manner that maintains the project schedule; • negotiations with municipalities and land management agencies that may require underground construction; and, • local ordinances that may require underground construction.

Based on preliminary engineering studies, approximately 43% of the construction will be aerial fiber hung on existing utility poles, with some poles being replaced as needed. No new pole runs are proposed for the Project. Approximately 41% of the construction will involve underground installation of fiber. The remaining 16% of the project corridor is defined as “Urban” where the fiber optic cable may be located within 2,500 feet of the proposed location shown in the Environmental Assessment pending negotiations with municipalities and right-of-way managers. The Project will use existing, previously disturbed ROW’s for the entire 1,263 miles of the route.

During the agency consultation process, Merit has identified the wider urban corridors and the potential for alternative construction methods to be used and has requested that agencies review the Project in light of the potential for either aerial or underground construction within the proposed project corridor.

The Project includes 63 Dual Option Areas (DOAs) defined as segments where utility ROW’s are not located within or adjacent to road ROW’s. The final location and choice of construction methods in these areas will be determined based on land use constraints or the accessibility of existing poles and/or conduit. Thirteen CAI Service Areas, defined as route locations which may be employed to facilitate future connections to CAIs, are proposed for the Project. Construction methods are the same as for the rest of the Project and environmental impacts will be minimized through the utilization of existing, disturbed road and utility ROW’s for the entire length of the project. Eleven telecommunication huts will be installed on existing developed sites in close proximity to the proposed fiber optic line; one existing telecommunication hut will be purchased.

Broadband access is a critical component for economic development. As Michigan and northern Wisconsin and Minnesota seek to recover from their significant economic challenges, broadband becomes an even more important foundation for the future. Alternative energy, next generation manufacturing, and other initiatives depend not only on access to information, but on an educated populace well-versed in new technology. In many rural areas, the high cost and lack of competition for backhaul service has limited last mile service performance, availability, and affordability for homes, businesses, schools, libraries, public safety, and other anchor institutions. Last mile providers in parts of Michigan have reported that up to 80% of their costs go to backhaul.

The Project directly addresses this problem by building 1,263 miles of 12-168 strand fiber infrastructures into selected rural and underserved areas in Michigan, Wisconsin, and Minnesota. Merit Network, Inc., an established non-profit provider to anchor institutions, together with four commercial service providers, will use the new infrastructure to serve all sectors of the economy. Merit’s mission of serving anchor institutions, combined with the sub-recipients' business plans, ensures that households, businesses, and CAIs will all see major benefits from, and that citizens in Michigan, Wisconsin and Minnesota are engaged in, the digital economy.

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The alternatives considered for the Project are all based upon Merit’s existing core or backbone fiber network in Michigan’s Upper and Lower Peninsulas, since all proposed fiber routes had to expand from this backbone network. Determining the routes of the proposed fiber paths first involved locating connection points in unserved and underserved areas in 29 Michigan counties in both the Upper and Lower Peninsulas, eight in Wisconsin and one in Minnesota. Once connection points were identified, baseline routes were established to the existing backbone network. Route analyses followed, with fiber paths being finalized in a manner that minimized the temporary environmental impacts associated with the Project, while maximizing connectivity between served and unserved areas. Route finalization included the consideration of the following:

• Presence of utility poles. • Location and condition of existing utility poles. • Presence of existing conduits. • Distance between backbone network access points, major telecommunications points of presence, and CAIs. • Building infrastructure and network hookup locations at community anchor institutions. • Existing natural features (such as rivers and wetlands) and known cultural resource sites.

Several alternatives were considered for the Project: No Action, Preferred, and Alternatives Considered but Eliminated from Further Discussion. The No Action Alternative involves not constructing the Project. The Preferred Alternative is comprised of a combination of aerial and underground installation techniques. Alternatives Considered but Eliminated from Further Discussion included: 1) routing the proposed fiber paths via underground installation only, 2) running the proposed fiber paths via aerial installation only, and 3) the use of wireless technology. Without access to high-quality middle mile fiber infrastructure, learning, productivity, and economic development in Michigan, Wisconsin and Minnesota would suffer. Therefore, a combination of aerial and underground installation was ultimately selected as the Preferred Alternative, because it allows for the selection of the most appropriate fiber installation methodology for the various sites along the Project’s three corridors and associated spurs. This alternative allows the Project to leverage the time, cost, and environmental benefits of utilizing existing utility poles and underground utility conduits, while saving the more expensive and time-consuming underground installation techniques for areas with no available poles and/or restrictive utility ordinances. Overall, the Preferred Alternative allows implementation of the Project to proceed with the least amount of adverse environmental impacts, while still meeting the Project’s purpose and need—to provide affordable, high-performance broadband to homes, businesses, CAIs, and critical community facilities in unserved and underserved areas in Michigan, Wisconsin, and Minnesota.

The proposed Project crosses the Bad River Indian Reservation and four National Forests. The Project Team has been consulting with representatives of the Bad River Band, the U.S. Forest Service and other state and federal natural resource agencies to identify the necessary clearances and permits needed to construct the Project. Agency correspondence is provided in Appendix F.

The existing road ROW’s that will be used by the Project are managed by State Highway Departments and local road departments/commissions; existing utility ROW’s are typically owned by electric distribution companies. On-going engineering studies have identified no private land crossings to-date.

Adverse environmental impacts resulting from the Project will be minimized through the utilization of existing, previously disturbed utility and road ROW”s for the entire length of the Project. The environmental impacts associated with the Project are typically a result of soil disturbance associated with construction. Areas that are disturbed during construction will be restored to their pre-construction condition and stabilized with seed and mulch. Therefore environmental impacts are anticipated to be relatively minor and temporary. The proposed Project was found to have no impacts to noise, air quality, surface water, groundwater, designated Critical Dune, historic architectural, aesthetic/visual, and land use resources. The proposed Project was found to have potential minor, temporary adverse impacts to geology/soils, wetlands, designated Coastal Zones, floodplains, designated federal

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Wild and Scenic Rivers, State-designated rivers and waterways, designated Environmental Areas, vegetation, wildlife, threatened and endangered species, wetland habitats, archeological/native, public land, and human health and safety resources. The proposed Project was found to have significant positive impacts on infrastructure, socioeconomic resources, and environmental justice populations.

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1.0 CHAPTER 1 - PURPOSE AND NEED

1.1 PROJECT INTRODUCTION

In August 2010, the National Telecommunications and Information Administration (NTIA) awarded a $69.6 million federal Round Two grant through its American Recovery and Reinvestment Act (ARRA, aka the federal stimulus package) funded Broadband Technology Opportunities Program (BTOP) to Merit Network, Inc. (Merit). As a recipient of this federal grant, Merit is submitting the following Environmental Assessment (EA) to NTIA in compliance with the National Environmental Policy Act (NEPA).

Merit is proposing to build the Rural, Education, Anchor, Community and Healthcare – Michigan Middle Mile Collaborative Project (REACH-3MC II) (the Project), a 1,263 mile long advanced fiber-optic network through underserved counties in Michigan’s Upper and Lower Peninsulas with diverse paths to Wisconsin and Minnesota. In addition, Merit will purchase approximately 60 miles of existing fiber infrastructure and one telecommunication hut. The Project is a unique relationship between Merit, one public and seven private sector entities that provide high- performance broadband middle and last mile services, namely, the Michigan 911 Administrator’s Office, ACD.Net, Boardman River Communications, CCI Systems, Great Lakes Comnet, Lynx Network Group, and Peninsula Fiber Network. The Project will engage more citizens in the digital economy by providing affordable, high-performance broadband Internet, voice, and video services to homes, businesses, and statewide community anchor institution (CAIs) in 29 Michigan counties in both the Upper and Lower Peninsulas, eight in Wisconsin and one in Minnesota. Of these 38 counties, 29 are underserved and eight have underserved areas.

REACH-3MC II is a standalone project that will bring great benefit to the region and is the foundation of a coordinated plan to serve the region. The eight diverse Project partners designed the network to meet their combined needs. The Project will extend Merit’s existing 1,600+ mile fiber network and complement Merit's REACH-3MC Round One 1,015-mile advanced fiber optic project. The future 3,800+ mile network will provide advanced services previously unavailable to many parts of rural Michigan, Wisconsin and Minnesota and will help bring the State of Michigan’s “Michigan’s Push for Broadband” to fruition. Refer to Figure 1.1.1 for a map of the Project and complementary project locations.

Merit Network, Inc., a not-for-profit broadband service provider, has built and run networks for anchor institutions throughout the state of Michigan for 44 years, supporting the education and not-for-profit community. Merit currently operates over 1,600 fiber miles, including the Michigan Lambda Rail and Blue Line fiber projects in its network. Merit is a nonprofit, owned and governed by the following Michigan universities: Grand Valley State, Ferris State, Michigan State, Central Michigan, Western Michigan, The University of Michigan, Northern Michigan, Lake Superior State, Michigan Technological, Wayne State, Eastern Michigan, and Oakland. Merit provides high-performance networking and services to the research and education communities in Michigan.

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Figure 1.1.1 REACH-3MC II Project Location

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1.2 PROJECT PURPOSE

The purpose of the Project is to provide affordable, high-performance broadband to homes, businesses, and CAIs in underserved areas in 29 counties in Michigan (MI), eight counties in Wisconsin (WI) and the southern portion of one county in Minnesota (MN) via three proposed fiber corridor backbones and ten spurs. Specific Project objectives include the following:

The proposed Project network will bring high-performance, low-cost middle mile service closer to: 1) unserved areas; 2) 29 completely underserved counties; and, 3) eight counties with significantly underserved areas (Figure 1.1.1). This middle mile service will provide the vital connection between Merit’s existing backbone (core) network and small edge sub- networks on the fringe of Michigan’s hierarchical fiber network. The spurs to Duluth and Green Bay provide diverse paths to complementary CAI networks: WiscNet, Boreas-Net and the Northern Tier Network. Merit and Northern Tier Network will directly interconnect, providing higher speed between colleges and universities in the region for research. The network will immediately connect 61 anchor institutions and will pass 759 CAIs in the service area. The Project is the foundation on which Michigan’s Next Generation (NG) 911 project will be built, providing affordable infrastructure to connect all Public Safety Answering Points.

The Project will offer Dark Fiber, Wavelength, TDM, SONET, Ethernet, p2p, and IP service, and speeds will be up to 10 Gbps with standard lower speeds available. The Project proposes to immediately connect 61 CAIs including libraries, universities, community colleges, and community healthcare centers, and will pass 759 CAIs in the service area. The open design of the proposed fiber-optic network expansion enables all service providers to directly connect to the network to make broadband more easily available to an estimated 731,237 households, 49,661 businesses, and 820 anchor institutions. The proposed service area also includes four government organizations, 19 K-12 institutions, 22 public library systems, one major healthcare facility, and 10 higher education locations.

1.3 PROJECT NEED

The level of need for the Project is defined by several indicators including economic hardship, last mile underserved, the availability of backhaul and cost, CAIs, and the Statewide CAI Network. The vast majority of the service area faces extreme economic hardship and is underserved according to last mile BTOP standards. There is a lack of both technology and affordable high-speed backhaul service within the service area and diverse paths out of the service area. CAI’s in the service area have submitted 187 letters of support expressing that their needs are not currently being met. The urgency of a statewide CAI network is substantiated in additional letters of support from CAI leadership organizations.

Economic Hardship Michigan has had extremely high unemployment rates and has lost hundreds of thousands of jobs since 2000 including 350,000 manufacturing jobs (American Trade Manufacturing Coalition). As the state transitions to an information-based economy, its entire citizenry needs access to affordable, high-speed broadband at home, in the workplace and especially at CAIs. As Michigan and the rest of the region seeks to recover from its significant economic challenges, broadband becomes an even more important foundation for the future.

The Project is focused on the needs of Michigan, Wisconsin, and Minnesota’s efforts to fix their faltering economy. Ninety-three percent of the 29 counties in the Michigan service area are economically distressed, as are seven

Merit REACH-3MC II Final Environmental Assessment (7/15/2011) 7 counties in Wisconsin. Extending broadband to these financially troubled areas will create jobs and bolster economic growth. Alternative energy, next generation manufacturing, and other initiatives depend not only on access to information, but on an educated populace well-versed in new technology.

Last Mile Underserved The Project serves 29 Michigan counties of which 24 are underserved according to BTOP standards. There are underserved census tracts in the five remaining counties. According to the Upper Peninsula (UP) Association of County Commissioners, all 15 counties in the UP are underserved; 10 are in the service area. In addition, there are five underserved counties in the Wisconsin service area, as well as St. Louis County, Minnesota.

Backhaul Availability, Technology, and Cost In many rural areas of the tri-State region, the high cost and lack of competition for backhaul service has limited last mile service performance, availability, and affordability for homes, businesses, schools, libraries, public safety and other anchor institutions. Last mile providers in parts of Michigan have reported that up to 80% of their costs go to backhaul. The Project’s service area has few viable options for backhaul. Available backhaul service that is too expensive due to tariff rates poses the same problem as non-existent backhaul. The primary problem in the service area is the high cost of backhaul and the unavailability of the right technology (Dark Fiber, Waves, Gig Ethernet, and SONET). Dark Fiber is the most viable technology for CAI networks and once the capital investment is made to own Dark Fiber it is cheaper and significantly more sustainable compared to long-term Circuit leases. Standard technology enables a single pair of fiber to support 40 10G Waves. For a one-time upgrade in optronics, capacity can be increased 10 times. Dark Fiber is the most viable technology for CAI networks and regional, commercial- provider backbones (like those of the Project sub-recipients).

Dark Fiber is currently not available in the Project service area. ATT, Verizon, Comcast and Charter may have fiber in some areas, but do not sell Dark Fiber. Smaller competitive local exchange companies (CLECs) and incumbent local exchange companies (ILECs) in the service area have fiber, but most will not sell. Even so, existing CLEC and ILEC fiber in the service area is only local and is not connected to infrastructure needed to form the regional network created by the Project or provide the backhaul the Project will provide.

Gig Ethernet, TDM and/or Waves are key to fast, economical backhaul in the absence of Dark Fiber. Waves are presently available only in the North and Northeast Corridor at tariff rates and 10 Gbps Ethernet is not available. Gig Ethernet is available however in parts of the North and Middle Corridors, and high speed TDM is available in the North and Northeast Corridor, but only at tariff rates. Local loops in the region are limited to 155 Mbps TDM. According to letters of support and the FCC National Broadband Plan, the available technology will not meet the needs of CAIs, nor will available technology provide a foundation for last mile providers to expand or upgrade their service.

Community Anchor Institutions Community anchor institutions provide communities with vital services and resources such as regional hospitals, public health departments, or a regional association of community health centers, the importance of which increases dramatically during times of economic hardship. In the recession, CAIs have been forced to provide more with smaller budgets. By extending access to affordable high-speed broadband into underserved areas of the tri-state region, the Project will enable CAIs to consolidate and share resources. Merit’s backbone is currently 10 Gbps where Merit has Dark Fiber. Some Anchors are connected with multiple 10 Gbps connections, while many others have multiple 1 Gbps connections. CAI’s in the service area that use circuits for local loop, or are connected at the end of a circuit-based backbone, do so because it is their only option. Current ILEC networks do not necessarily have infrastructure where it is needed to serve these CAIs. The result is CAIs cannot obtain the speed they require at a cost they can afford. Every year Merit upgrades its infrastructure to meet growing demand.

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Statewide CAI Network The nature of networks is changing. During the early phase of the Internet, regional networks served as conduits to Tier 1 Internet Providers (AT&T, Verizon, etc.). Tier 1’s gave the Internet its value by serving as a central trunk so that any user could get to any site on the Internet. They still serve this same purpose, but it is less important in the complete picture. For example, 10 years ago over 95% of the traffic that left a campus on the Merit Network went to the Tier 1’s. Last year less than 15% did. The tri-State region needs not only better service to remote areas; it also needs statewide networks for their CAIs. The Project will integrate the Statewide Network with those of neighboring states to enhance the benefit.

CAI networks need to be focused on their members, but interconnected so that better consolidation and economies of scale can be achieved. Michigan, Wisconsin, and Minnesota CAIs need the benefits of statewide networks to help lower costs and improve service. The majority of Michigan CAIs already are Merit members, but for most of those that are not it is the cost of backhaul that precludes them from connecting to the Merit statewide CAI network. Access to a robust statewide CAI network is an important goal for Michigan's CAI leadership organizations. This need is substantiated by letters from the State, the Intermediate School District Association, the State Superintendent, the Public University President’s Council, the State Librarian, the Michigan Community College Association and the State 911 Administrator. Due to this Project, Michigan is on the verge of being able to provide a practical networking solution with diverse paths to neighboring counterpart networks for all CAIs, regardless of their location.

Public universities currently have a network—although the universities in the UP only achieve this through their Merit Membership, as Merit shoulders the majority of the high cost of connecting them to public universities elsewhere in the state. The Project will lower this cost and provide universities in the UP much-needed high-speed, diverse paths. Community Colleges in Gogebic, Bay de Noc and Alpena, as well as Bay Mills Tribal College, are not able to connect to other Michigan community colleges by Dark Fiber. All want to be able to share in the benefits of a CAI network as advocated by the Michigan Community College Association. The Michigan Department of Education has long identified the need for a statewide K12 network. School districts in the service area are among the smallest and therefore will benefit the most from the sharing of resources a K12 network enables.

Due to the need to update first-response public safety, the State of Michigan commissioned a study on transitioning to Next Generation (NG) 911 service. The resulting plan has a dedicated high-availability network as its foundation. The cost of such a network places the implementation of this plan in doubt. With Merit’s existing network and the addition of REACH-3MC and the Project, a statewide backbone will be in place which will make an incremental move to the NG 911 system not only possible but likely in the future.

Summary Merit has operated a statewide CAI network for over 40 years. The service Merit can provide to CAIs in remote areas has been limited by high backhaul costs or limited technology options. Only CAIs in served areas of Michigan, Wisconsin, and Minnesota have been able to take advantage of a CAI network by collaborating and sharing resources. Currently, CAIs in the proposed the Project service area have either elected not to join or to take service levels below their need, because there is no state subsidy for Michigan's CAIs and the cost of backhaul in remote areas is so high.

The Project directly addresses this problem by building 1,263 miles of multiple-strand count (12-168 strands) fiber infrastructure into rural and underserved areas. An additional purchase of 54 miles of existing aerial fiber from St. Ignace to Sault Ste. Marie, Michigan and 5.5 miles of existing conduit on the Mackinac Bridge will bring the total Project network to 1,322 miles. Merit Network, Inc. is an established non-profit provider to CAIs and, together with seven commercial service providers, will use the new infrastructure to serve all sectors of the economy. Merit’s mission of serving anchor institutions, combined with the sub-recipients' business plans, ensures that households, businesses, and critical community facilities will all see major benefits from the Project and that citizens in Michigan, Wisconsin and Minnesota are engaged in the digital economy.

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The Project leverages the current networks operated by Merit and the sub-recipients to deliver maximum benefit for the cost. Merit’s current anchor members enjoy tremendous benefits by collaborating over its existing infrastructure. Specifically, the benefits of an open, collaborative network include increased competition and choices between commercial Internet service providers (ISPs), resulting in lower costs, increased service options, increased availability of unique services, and the availability of various levels of service for a range of prices. These benefits have been denied to CAIs in the underserved areas of the region because of the high backhaul costs, i.e. the costs associated with connecting the core network with small edge sub-networks. Not only will newly connected institutions benefit from the Project, but also current Merit members will benefit from the synergistic effect of the new anchor institutions on the extended network.

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2.0 CHAPTER 2 – DESCRIPTION OF PROPOSED ACTION AND ALTERNATIVES

2.1 PROJECT DESCRIPTION

The Project consists of approximately 1,263 miles of new multi-strand fiber plus 60 miles of purchased existing fiber infrastructure for a total of 1,322 miles of fiber network in Michigan’s Upper and Lower Northern Peninsulas, with diverse paths to Wisconsin and Minnesota (Table 2.1.1). In addition, the Project includes placement of 11 telecommunication huts (Table 2.1.2) and purchase of one existing telecommunication hut. Merit Network is an established non-profit provider to community anchor institutions (CAIs) and will use the new infrastructure to serve all sectors of society. The Project leverages sub-recipients’ current networks and REACH-3MC, the Broadband Training Opportunities Project (BTOP) Round One-funded network in West, South, East and Central Michigan, to deliver maximum benefit for cost. Merit’s mission of serving CAIs, combined with the partners' business plans, ensures that households, businesses, and CAIs will all see major benefits from the Project.

The Project’s service area includes 29 counties in Michigan, eight in Wisconsin and the southern portion of one county in Minnesota. The Project proposes to immediately connect 61 CAIs including libraries, universities, community colleges, and community healthcare centers, and will pass 759 CAIs in the service area. The Project service area contains the most underserved areas in the region and will dramatically improve access to consumers in these areas. Of the 38 counties in the service area, 29 are underserved by BTOP standards and eight more have underserved areas. The Project will provide access to broadband service to these unserved and underserved areas, including numerous communities with minority and low-income populations per the 2000 Census. The open design of the Project’s fiber-optic network enables all service providers to directly connect to the network to make broadband more easily available to an estimated 731,237 households, 49,661 businesses, and 820 anchor institutions. Additionally, the proposed service area includes four government organizations, service areas for four Tribes, 19 K- 12 institutions, 22 public library systems, one major healthcare facility, and 10 higher education locations.

Of the 38 counties in the Project service area, 27 are economically distressed. The Project will not only bring high- performance, low-cost broadband service to these underserved areas but much needed jobs as well. Michigan has been in a recession since the early part of the century and has had some of the highest unemployment rates in the nation. Merit Network estimates 946 jobs will be created as a result of the Project and will further help Michigan cope with the staggering loss of manufacturing jobs by supporting the transition to an information-based economy though providing its entire citizenry much needed access to affordable, high-speed broadband at home, in the workplace and especially at its community anchor institutions (CAIs).

The Project consists of three Corridors; the Middle, Northeastern, and Northern. Ten spurs extend from these backbones; the Leroy to Luther, Rose City to Kalkaska, Grayling to Lovells, Grayling to Higgins Lake, Indian River to Gaylord, St. Ignace to Sault Ste. Marie, Watersmeet to Houghton, Rockland to Ontonagon, Green Bay, and Duluth Spurs. The Project will use existing road and utility rights-of-way (ROW’s) that have been previously disturbed for the entire 1,263 miles of the route. Figures 2.1.1 and 2.1.2 illustrate the proposed fiber corridors and hut locations respectively.

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Table 2.1.1 Statewide Summary of the REACH-3MC II Project

Aerial Underground Existing Urban Subtotal Total Length Corridor/Spur Start/End Counties Crossed Portion Portion Conduit (miles) (miles) (miles) (miles) (miles) (miles) MIDDLE CORRIDOR Grand Rapids to Kent, Montcalm, Mecosta, Osceola, Wexford, Backbone 99.8 86.9 28.4 33.1 248.2 248.3 Oscoda Missaukee, Roscommon, Ogemaw, Iosco LeRoy to Luther Spur LeRoy to Luther Lake, Osceola 12.9 0.3 0.0 0.2 13.4 13.4 Rose City to Rose City to Kalkaska Spur Ogemaw, Oscoda, Crawford, Kalkaska 43.4 25.0 0.0 9.3 77.7 77.7 Kalkaska Grayling to Lovells Spur Grayling to Lovells Crawford 11.6 7.9 0.0 0.5 20.0 20.0 Grayling to Higgins Lake Grayling to Higgins Crawford 8.8 0 0.0 1.3 10.1 10.1 Spur Lake NORTHEASTERN CORRIDOR Oscoda to Iosco, Alcona, Alpena, Montmorency, Presque Isle, Backbone 146.0 21.3 0.0 34.2 201.5 201.5 Mackinaw City Cheboygan, Emmet Indian River to Gaylord Indian River to Otsego, Cheboygan 22.6 1.9 0.0 5.7 30.2 30.2 Spur Gaylord NORTHERN CORRIDOR Mackinac, Schoolcraft, Delta, Menominee, St. Ignace to Backbone Dickenson, Iron (MI), Florence (WI), Iron (WI), 117.8 177.3 0.0 47.9 343.0 343.0 Ironwood Gogebic 5.5 Mackinaw City to Mackinaw Bridge Emmet, Mackinac 0.0 0.0 0.0 0.0 0.0 (existing line to St. Ignace be purchased) 54.0 St. Ignace to Sault Ste. St. Ignace to Sault Mackinac, Chippewa 0.0 0.0 0.0 0.0 0.0 (existing line to Marie Spur Ste. Marie be purchased) Watersmeet to Houghton Watersmeet to Gogebic, Ontonagon, Houghton 10.9 59.2 0.0 18.0 88.1 88.1 Spur Houghton Rockland to Ontonagon Rockland to Houghton, Ontonagon 3.7 6.6 0.0 3.7 14.0 14.0 Spur Ontonagon WISCONSIN/MINNESOTA SPURS Powers to Green Menominee, Marinette (WI), Oconto (WI), Brown Green Bay Spur 36.6 58.5 0.0 7.9 103.0 103.0 Bay (WI) (WI) Ironwood to Duluth Iron (WI), Ashland (WI), B ayfield (WI), Douglas (WI), Duluth Spur 32.5 45.4 0.0 36.0 113.9 113.9 (MN) St. Louis (MN) 546.6 28.4 197.8 1,26 3.1 TOTAL 490.3 (38.8%) 1,322.6 (43.3%) (2.2%) (15.7%) (100%)

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Table 2.1.2 Summary of Hut Locations

Hut Name/ Corridor County State Township Range Section General Location Description Community

Hiawatha Trail/Melville St. (between Melville St. Engadine Northern - Backbone Mackinac MI T43N R10W S16 and Park St.), just east of M-117 US -2, just east of Co. Hwy. 442 (southwest of Manistique Northern – Backbone Schoolcraft MI T41N R17W S31 Cooks) Northeast corner of Danforth Rd. and N. 30th Escanaba Northern – Backbone Delta MI T39N R23W S13 St. (west of US-2/N. Lincoln Rd.) Northern – Green Gro ve St. just east of Maple St., south of US -2 Powers Menominee MI T38N R26W S16 Bay Spur (just east of Powers) W. Cleveland Ave., west of Roosevelt Rd.(north Northern – Green Marinette Marinette WI T30N R23E S11 of US-41/Marinette Ave) [southwest of Bay Spur Marinette] E. Frank Pipp Dr., just east of US -2 (north of Iron Mountain Northern – Backbone Dickinson MI T40N R30W S20 Iron Mountain) US -2 between Tobin -Alpha Rd. and Zavada Dr. Crystal Falls Northern – Backbone Iron MI T43N R32W S30 (west of Crystal Falls) Northern – East of US-45, between 1st St. and 2nd St. Watersmeet Watersmeet to Gogebic MI T45N R39W S27 (north of US-2, Watersmeet) Houghton Spur Northeast corner of US -2 and Blackjack Rd. Wakefield Northern – Backbone Gogebic MI T47N R45W S7 (between Wakefield and Bessemer) Nor thern – Duluth Southwest corner of US -2 and State Farm Rd. Ashland Ashland WI T47N R5W S10 Spur (west of Ashland) Northern – Duluth North of US -2, between S. Maple Rd. and S. Poplar Douglas WI T47N R11W S4 Spur Wiehe Rd. (between Poplar and Maple)

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Figure 2.1.1 Proposed Project Corridor and Spurs

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Figure 2.1.2 Proposed Hut Locations

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The proposed system is a fiber network that uses advanced technologies to bring high-performance, low-cost and easily scalable backhaul services to underserved areas. Merit Network is proposing the deployment of an advanced networking state-of-the-art fiber optic network. Merit will deploy a multiple strand count (12 to 168 strands) fiber optic backbone throughout the project area that will increase broadband availability to unserved and underserved areas. Merit has engineered a hybrid CWDM (Course Wave Division Multiplexing) / DWDM (Dense Wave Division Multiplexing) fiber optic network that will deliver a host of broadband connectivity options in a very cost effective manner. CWDM is a technology in which fewer signals are multiplexed onto a single fiber for short haul transport. The wide availability and low cost of CWDM components make it ideal for middle mile aggregation to core sites and will allow for extensive network propagation to communities throughout the state. DWDM is a technology which multiplexes many optical signals on a single optical fiber by using different wavelengths, or colors, of light to carry different signals. This allows for a multiplication in circuit capacity and facilitates high bandwidth capacity over long distances. The network design is flexible enough to allow Merit to offer broadband Ethernet, leased fiber, and wave services to anyone where capacity is available. Additionally, Merit will be able to offer last mile and other middle mile providers the ability to connect OC-48/OC-192, DS-1, DS-3 to the Merit DWDM optical network. This will allow other networks the ability to leverage the high speed, high capacity DWDM long haul network.

The basic access rates will be 10 Gbps and 2.5 Gbps between add/drop sites at strategic locations on the network. These rates can be either Ethernet or SONET standards. Secondary regional access loop fibers will deliver 100 Mbps to 1 Gbps to the add/drop points for aggregation into the backbone network. Routers and switches on the regional access loops will operate with standard TCP/IP protocols and services.

The proposed fiber plan provides between 12 and 168 strands to be deployed throughout the state. Strand counts on the routes vary based on need and sub-recipient’s requirements. A minimum of twelve of those strands will be dedicated for Merit’s use. Two of the twelve strands will be used to provide long haul optical transport for a 40 wave DWDM system with nodes located at strategic core sites across the state of Michigan. An additional two stands will be utilized to provide optical transport and connectivity for regional CWDM systems that will deliver access to the long haul core sites. The remaining two Merit strands are for future expansion, lease fiber offering, testing and emergency recovery. The balance of the strands will be utilized by sub-recipients to this application as well as allow for significant growth and expansion.

Merit’s Ethernet service offering will cost-effectively extend the reach of the DWDM core network to vast unserved and underserved communities to gain access to broadband Ethernet connectivity. Merit will use 2 strands of fiber to interconnect various communities throughout the state to the DWDM core sites. This interconnectivity will provide up to one gigabit Ethernet connectivity to multiple community members throughout the Merit fiber network. Project Construction Methods

2.1.1 Project Construction The proposed fiber optic cable will be located in existing disturbed ROW’s for its entire length. The existing road ROW’s that will be used by the Project are managed by State Highway Departments and local road departments/commissions; existing utility ROW’s are typically owned by electric distribution companies. On-going engineering studies have identified no private land crossings to-date.

The fiber optic cable will be installed using a combination of aerial and underground construction methods as described in more detail below. Aerial construction is more prevalent in Michigan’s Lower Peninsula which is more developed and existing utility poles are more readily available than in the UP and northern Wisconsin and Minnesota. Appendix A provides typical photographs of the ROW conditions where the fiber optic cable will be built.

When developing the engineering plans for the Project, Merit will identify opportunities to support the goals outlined in Executive Order 13514: Federal Leadership in Environmental, Energy, and Economic Performance. Opportunities may include, but not be limited to, recycling poles that require replacement, use of wood from certified sustainable

Merit REACH-3MC II Final Environmental Assessment (7/15/2011) 16 forests for new poles, and use of alternative fuels for construction equipment to increase energy efficiency and reduce air emissions.

Worker and road safety will be an important component of the Project. All construction crew members will be trained and familiar with local, state, and federal traffic control and safety regulations and specifications and will comply with applicable Occupational Health and Safety Administration (OSHA) and State Highway Department (SHD) regulations. It is anticipated that along the majority of the Project route, road shoulders will be large enough to accommodate construction workers and equipment, such that vehicles and other equipment will be located completely off of the road. Therefore, road shoulder closures are anticipated for most of the route, but frequent lane closures or complete road closures are not anticipated. In the event that traffic needs to be routed around a vehicle for aerial construction, a flagman will be posted to safely direct traffic per SHD procedures. To mitigate the potential for automobile accidents, signs will be posted in both directions to denote construction work along road shoulders and in road rights-of-way, per SHD guidelines. Underground installation crews will be located completely off of the road and will be relatively stationary each day, so underground work areas will be demarked with regulation-sized road cones. As most of the Project route is rural in nature, traffic control will be most important near anchor institutions in urban areas with higher traffic volumes. All required permits for roadside work will be obtained and complied with throughout Project construction.

Aerial Construction Approximately 43% of the total route construction will be aerial fiber hung on existing utility poles, with some poles being replaced as needed. The existing utility poles may be located within road or utility ROW’s. Construction crews will access the pole sites from existing public roads and the existing utility ROW’s. Timber mats will be used to support construction equipment in wetland areas where saturated conditions create the potential for rutting. Aerial installation of fiber infrastructure will not involve stream or river crossings by construction equipment. Waterway spans will be accessed via road and utility ROW’s on both sides of the water feature, and fiber will be strung across from bank to bank by hand or by boat and pulled into place. Aerial crews will likely install aboveground fiber infrastructure at an approximate rate of 5,000 feet per day. Equipment typically used for aerial construction includes bucket trucks, all-terrain vehicles (ATV’s), cable trolleys, and ladders.

Pole replacement and acquisition of applicable permits will be performed by the utility companies that own the poles. Pole replacement will involve mounting new poles on a concrete footing or directly burying them into the ground next to the existing poles to be replaced. The installation process will be as follows: 1) a hole approximately 4-8 feet in diameter will be augured approximately 15-35 feet deep; 2) a concrete footing will be poured and the pole mounted on the footing, or the proposed pole will be directly buried into the ground and backfilled with crushed rock; 3) the area around the pole will be restored to preconstruction grades and stabilized; and, 4) the existing aerial utilities and proposed fiber will be strung on the new poles and activated. Any excess material will be placed in upland areas and stabilized. For locations where existing poles will be replaced, the new replacement pole will be installed approximately 15-30 feet from the existing pole. The existing pole will be pulled from the ground or cut off near the surface once aerial utilities are installed on the new pole, removed from the utility or road ROW, and properly disposed of offsite. All construction-related disturbances associated with pole replacement will be temporary.

Underground Fiber Construction Approximately 39% of the total route construction will involve installation of fiber infrastructure underground using plowing or directional boring or installation within existing conduit. Underground construction will occur exclusively within existing road ROW’s. Plowing will be used for the majority of underground construction, especially in disturbed developed areas lacking natural and cultural resources. Plowing is a trenchless installation method that involves a tractor-crawler and friction-type plow blade capable of minimal ground disturbance (approximately six inches wide and 48 inches deep). Fiber encased in flexible conduit less than two inches in diameter is plowed into the ground at least four feet deep. Restoration in plowed areas will involve compaction of the original soils in the cable plow slot. Plowing, unlike trenching, does not involve the discharge of fill material.

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Directional boring will be used in the following locations: 1) environmentally sensitive areas, such as rivers and streams, sensitive wetlands, and rare species habitats; 2) areas specifically required by regulatory agencies; and, 3) developed sites where extensive paved areas make plowing unfeasible. Directional boring involves excavating a 10 x 10 foot area for equipment and drill bit access. Directional boring pits will occur in upland areas set back a minimum of 25 feet from existing wetlands or stream banks. The staging of any required equipment will be in upland areas. Bore pits will be restored to their original grade using the original soil materials and seeded.

Existing conduits will be used where available. Conduits are typically accessed via manholes or access portals located at each end. Approximately 28.4 miles of cable, or 2.2% of the total project length, will be installed in existing conduits.

Hand holes are dug and hard plastic bottomless casings are installed every 1,800-2,500 feet, depending on the environment, to provide storage space for fiber slack and maintenance access. Hand holes will be located in upland areas, and excavation involves a 3x3 foot area and extends to the depth of the buried fiber conduit, usually four feet deep. All construction-related disturbances associated with underground installation of fiber will be temporary and will return soil grades to their original elevations.

Underground crews will likely install underground fiber infrastructure at an approximate rate of 550 feet per day for directional boring and 2,500 feet per day for plowing. Equipment typically used for underground installation includes small track-mounted or rubber-tired backhoes, vibratory plows mounted on small bulldozers, directional drills and pipe strings, and hand tools such as shovels and rakes.

Telecommunication Huts In addition to fiber optic lines, the Project will involve the placement of 11 – 10 foot x 20 foot telecommunication huts; eight in Michigan’s Upper Peninsula and three in Wisconsin (Table 2.1.2). One existing hut will be purchased in St. Ignace. The huts will be used for telecommunication and network equipment. Each hut will include external access to connect to a power generator, 200A AC power service, 48VDC 50A rectifiers and 48V batteries. Each new hut will be installed on previously-disturbed developed land along the fiber route.

The telecommunication huts will be located within existing developed areas and set approximately 50 feet from the edge of the road. Clearing and excavation will be limited to that needed allow a concrete building pad for hut installation and 20-foot wide access drive. While the amount of disturbance will be limited to the minimum needed to place the hut and driveway, an area as large as 80’ x 80’ may be cleared and graded to accommodate each hut. Typically the lot will already be cleared, however brush and small trees may need to be removed. The access drive will be gravel, generally 50 feet long, and built to local standards and requirements. A utility pole will be installed to provide power to each hut. Appendices B and C contain aerial photographs of each hut site and typical telecommunication huts respectively.

Incidental Fiber Infrastructure The Project also involves building incidental fiber infrastructure to connect the network to the 61 CAIs. Building access will occur in utility corridors within the building footprint and associated infrastructure footprint in existing, disturbed urban areas. Building connections will generally be no more than 250-500 feet in length but may be as long as 2,500 feet. Therefore, these incidental runs have not been counted toward the total mileage of the Project route. Connections to CAIs will typically be made through existing utility conduits. If no existing conduits exist, Merit will coordinate with the building owner to identify the preferred location and method of connection. New fiber infrastructure proposed within CAIs will be located within existing buildings; no new buildings or structures are proposed to house new infrastructure within CAIs.

Merit REACH-3MC II Final Environmental Assessment (7/15/2011) 18 project corridor is defined as “Urban” where the fiber optic cable may be located within 2,500 feet of the proposed location shown in the EA pending negotiations with municipalities and right-of-way managers. The Project will use existing, previously disturbed ROW’s for the entire 1,263 miles of the route.

Engineering of the proposed fiber optic system is proceeding in tandem with preparation of the Environmental Assessment (EA). The proposed construction methods identified in the EA are based on preliminary engineering studies; however, it may be necessary to substitute underground construction for aerial construction, or in some cases, aerial for underground in certain locations for a variety of reasons including, but not limited to the following:

During the agency consultation process, Merit identified the wider urban corridors and the potential for alternative construction methods to be used and requested that agencies review the Project in light of the potential for either aerial or underground construction within the proposed project corridor as shown in the EA and the alternatives discussed in the next section.

2.1.2 Alternatives Included in Proposed Project Description The Project Team identified three types of alternatives that will be analyzed in the EA and provided to regulatory agencies during project consultation to provide flexibility as the engineering is being finalized. The purpose of these alternatives is to obtain the clearances necessary for construction should it be necessary to deviate from the proposed route identified in the Environmental Assessment. The three types of alternatives include: 1) Urban Areas; 2) Dual Option Areas; and 3) CAI Service Areas. Each of these areas is described in more detail below.

For all of these alternatives, the fiber optic cable will be installed in existing disturbed road and utility ROW’s using the same construction methods described for the rest of the Project. The environmental impacts of these alternatives are similar to those described for the proposed route.

Urban Areas While the preferred fiber optic route through urban areas is shown on the maps within this EA, the final locations and construction methods are subject to municipal review and approval. For example, local officials may prefer that the cable be located on a street where road construction is planned in the same season as the cable installation, or that the cable be installed underground despite the presence of existing utility poles, or may know of existing conduit that could be used for the Project. Regardless, the fiber optic cable will be installed within existing disturbed road or utility ROW’s. Fifty four locations totaling approximately 197.8 miles, or 15.7% of the proposed fiber optic route fall within this category.

Dual Option Areas The Project includes fiber optic segments called Dual Option Areas (DOAs) where either aerial installation in utility ROW’s or underground installation in road ROW’s will occur. In general, aerial construction is the preferred method for installing the proposed fiber optic cable due to cost and minimal potential for environmental impacts. Utility poles are typically located within existing road ROW’s or in utility ROW’s adjacent or in close proximity to, existing road ROW’s. In some locations however, the utility ROW may be 200 feet or more from the road. In these areas, the final location and method of fiber installation will be based on site conditions, land use constraints, the accessibility of existing poles, and local ordinances.

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The Project is seeking clearance for both alternatives to allow flexibility during construction. There are 63 Dual Option Areas. The distance between the road ROW and utility ROW is typically less than 500 feet but may be as much as a quarter- to half-mile in a few locations. Dual Option Area segment lengths range from .05 to 6.90 miles with most less than two miles long (Table 2.1.3). Refer to Appendix D for detailed location maps.

CAI Service Areas Thirteen CAI Service Areas, defined as route locations which may be employed in order to facilitate future connections to CAIs, are proposed for the Project (Table 2.1.4). Refer to Appendix E for detailed location maps. Construction methods are the same as for the remainder of the Project and environmental impacts will be minimized through the utilization of existing, disturbed road and utility ROWs for the entire length of the Project.

Summary of Proposed Route and Agency Consultation The Project Team provided the following information to federal and state agencies for their review and comment:

• the proposed fiber optic route as shown on the maps in the EA with the understanding that aerial or underground construction may be used pending completion of final engineering studies and consultation with existing utility pole owners; • Urban Areas where the location of the fiber optic route may shift by as much as 2500 feet and aerial or underground construction may be used pending final negotiations with ROW managers; • Dual Option Areas where Merit is investigating the feasibility of locating the fiber optic cable in utility ROW’s that are located more than 200 feet from the road ROW but reserves the option of locating the fiber optic cable in the road ROW if aerial construction in the utility ROW proves to be unfeasible; and, • CAI Service Areas where Merit reserves the option of locating fiber optic cable to serve CAI’s that may enter into service agreements in the future.

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Table 2.1.3 Summary of Dual Option Areas

Maximum Distance between Aerial and Corridor Community County Length (miles) Underground (miles) Aetna Twp Missaukee 3.37 0.07 Cadillac Wexford 0.65 0.03 Green Twp Mecosta 0.05 0.07 Richmond Twp Osceola 0.36 0.02 Goodar Twp Ogemaw 0.47 0.1 Rose Twp Ogemaw 0.25 0.03 Big Rapids Twp Mecosta 0.77 0.02 Green Twp Mecosta 1.88 0.12 Green Twp Mecosta 0.85 0.06 Middle Corridor Backbone Sherman Twp Osceola 2.72 0.11 Clam Lake Twp Wexford 2.41 0.42 Cumming Twp Ogemaw 0.99 0.04 West Branch Twp Ogemaw 0.51 0.04 Richfield Twp Roscommon 2.01 0.08 Backus Twp Roscommon 2.59 0.06 Reeder Twp Missaukee 1.03 0.03 Reeder Twp Missaukee 3.55 0.02 Enterprise Twp Missaukee 0.96 0.02 Ellsworth Twp Lake 1.02 0.28 Leroy to Luther Spur Leroy Twp Osceola 1.39 0.05 Grayling Twp Crawford 1.35 0.09 Bear Lake Twp Kalkaska 0.58 0.07 Kalkaska Twp Kalkaska 0.71 0.04 Big Creek Twp Oscoda 0.83 0.13 Big Creek Twp Oscoda 1.98 0.04 Big Creek Twp Oscoda 0.65 0.03 Rose City to Kalkaska Spur Rose Twp Ogemaw 5.1 0.14 Rose Twp Ogemaw 0.31 0.05 Grayling Twp Crawford 0.38 0.06 Grayling Twp Crawford 4.93 0.07 Big Creek Twp Oscoda 1.13 0.23 Big Creek Twp Oscoda 1.29 0.03

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Table 2.1.3 Summary of Dual Option Areas (Cont’d)

Maximum Distance between Aerial and Corridor Community County Length (miles) Underground (miles) Grayling Twp Crawford 6.87 0.14 Beaver Creek Twp Crawford 6.83 0.14 Grayling to Higgins Lake Spur Maple Forest Twp Crawford 1.27 0.06 Lovells Twp Crawford 0.92 0.11 Hillman Twp Montmorency 5.09 0.06 Harrisville Twp Alcona 1.08 0.12 Mackinaw Twp Cheboygan 3.68 0.06 Beaugrand Twp Cheboygan 6.89 0.05 Beaugrand Twp Cheboygan 6.24 0.06 Oscoda Twp Iosco 1.26 0.03 Mikado Twp Alcona 0.52 0.07 Alcona Twp Alcona 1.4 0.06 NE Corridor Backbone Sanborn Twp Alpena 2.56 0.09 Allis Twp Presque Isle 0.64 0.14 Rogers Twp Presque Isle 0.23 0.05 Forest Twp Cheboygan 0.55 0.46 Forest Twp Cheboygan 0.9 0.06 Walker Twp Cheboygan 0.37 0.02 Inverness Twp Cheboygan 0.8 0.06 Wilson Twp Alpena 1.36 0.02 Green Twp Alpena 2.9 0.13 Tuscarora Twp Cheboygan 0.28 0.05 Mentor Twp Cheboygan 0.67 0.08 Nunda Twp Cheboygan 0.29 0.05 Indian River to Gaylord Spur Wilmot Twp Cheboygan 0.89 0.04 Corwith Twp Otsego 0.44 0.03 Mentor Twp Cheboygan 0.19 0.05 Manistique Twp Schoolcraft 1.27 0.06 Nahma Twp Delta 0.62 0.15 Northern Corridor Backbone Garden Twp Delta 0.53 0.08 Spalding Twp Menominee 2.32 0.5

TOTAL 106.93

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Table 2.1.4 Summary of CAI Service Areas

Crossing Type Total Existing Corridor Service Area Counties Crossed Underground Length Aerial (miles) Conduit Urban (miles) (miles) (miles) (miles) MIDDLE CORRIDOR Backbone Houghton Lake Roscommon (MI) 7.3 0.9 -- -- 8.2 Backbone Rose City Long Lake Iosco, Ogemaw (MI) 2.0 9.1 -- -- 11.1 LeRoy to Luther Spur Luther Leroy Osceola (MI) -- 6.8 -- -- 6.8 Rose City to Kalkaska Spur Kalkaska Loop Kalkaska (MI) -- 0.1 -- 3.1 3.2 NORTHEASTERN CORRIDOR Backbone Alpena Loop Alpena (MI) 1.7 0.7 -- -- 2.4 Backbone Harrisville Loop Alcona (MI) 0.4 ------0.4 Backbone Indian River Loop Cheboygan (MI) -- 0.6 -- -- 0.6 Backbone Millersburg Presque Isle (MI) -- 2.5 -- -- 2.5 Backbone Tower Cheboygan (MI) -- 0.5 -- -- 0.5 NORTHERN CORRIDOR Backbone Worth Road Mackinac (MI) 2.4 20.4 -- -- 22.8 Backbone Watersmeet Hut Loop Gogebic (MI) ------0.6 0.6 Watersmeet to Houghton Spur Houghton Hancock Houghton (MI) ------7.9 7.9 WISCONSIN/MINNESOTA SPURS Duluth Spur Ashland Bayfield (WI) -- 1.9 -- -- 1.9

TOTAL 13.8 (20.0%) 43.5 (63.1%) 0.0 (0.0%) 11.6 (16.8%) 68.9 (100%)

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2.2 GEOGRAPHIC SETTING

The Project runs from Grand Rapids, Michigan to Duluth, Minnesota and consists of three proposed fiber corridors and ten spurs in 29 counties in Michigan, eight in Wisconsin, and one in Minnesota. The Project also includes the placement of 11 telecommunication huts required to support equipment in these remote areas; eight in Michigan’s Upper Peninsula and three in Wisconsin. Each will be installed on previously-disturbed developed land along the fiber route. All locations noted below may be assumed be in Michigan unless otherwise indicated.

2.2.1 Middle Corridor (Figure 2.2.1) The Middle Corridor Backbone connects to Merit’s core network in Grand Rapids and extends north and east to Oscoda, passing through the cities of Big Rapids, Leroy, Cadillac, Lake City, Houghton Lake, and Rose City. The Backbone connects to existing fiber at Grand Rapids and Big Rapids, and Round One network in Houghton Lake and Oscoda. This segment of the Project crosses lands within the Huron National Forest. The entire 248.3 miles of the corridor occur within existing disturbed ROW’s, with 40% of the route consisting of aerial fiber, 35% consisting of underground fiber, 11% existing conduit and 13% is classified as urban.

The Leroy to Luther Spur connects to Round One fiber at Luther. The entire 13.4 miles of the corridor occur within existing disturbed ROW’s, with 96% of the route consisting of aerial fiber, 2% consisting of underground fiber and 2% is classified as urban.

The Rose City to Kalkaska Spur connects to Round One network in Kalkaska extending west from Rose City, passing through the cities of Mio and Grayling. This segment of the Project crosses lands within the Huron National Forest. The entire 77.7 miles of the corridor occur within existing disturbed ROW’s, with 56% of the route consisting of aerial fiber, 32% consisting of underground fiber and 12% is classified as urban.

The Grayling to Lovells Spur connects to Round One network in Grayling and extends north and east to Lovells. This segment of the Project crosses lands within the Huron National Forest. The entire 20 miles of the corridor occur within existing disturbed ROW’s, with 58% of the route consisting of aerial fiber, 40% consisting of underground fiber and 2% is classified as urban.

The Grayling to Higgins Lake Spur connects to Round One network in Grayling and extends south to just north of Higgins Lake, connecting to Round One fiber there. The entire 10.1 miles of the corridor occur within existing disturbed ROW’s, with 87% of the route consisting of aerial fiber and 13% is classified as urban.

Merit REACH-3MC II Final Environmental Assessment (7/15/2011) 24

Figure 2.2.1 Middle Corridor and Spurs

Merit REACH-3MC II Final Environmental Assessment (7/15/2011) 25

2.2.2 Northeastern Corridor (Figure 2.2.2) The Northeastern Corridor Backbone connects to Round One network in Oscoda and extends north and west to Mackinaw City, connecting to Round One network in Hillman and Mackinaw City. The Corridor passes through the cities of Alpena, Hillman, Posen, Rogers City, Onaway, Indian River, and Cheboygan. This segment of the Project crosses lands within the Huron National Forest. The entire 201.5 miles of the corridor occur within existing disturbed ROW’s, with 73% of the route consisting of aerial fiber, 11% consisting of underground fiber and 17% is classified as urban.

The Indian River to Gaylord Spur connects to Round One network in Gaylord. The entire 30.2 miles of the corridor occur within existing disturbed ROW’s, with 75% of the route consisting of aerial fiber, 6% consisting of underground fiber and 19% is classified as urban.

2.2.3 Northern Corridor (Figures 2.2.3 a and b) The Northern Corridor Backbone connects to Merit’s Round One network in Mackinaw City and extends north to St. Ignace and west to Ironwood, connecting to Merit’s core network in Iron Mountain and Crystal Falls (Figure 2.2.3). The Corridor passes through the cities of Manistique, Escanaba, Powers, Iron Mountain, Crystal Falls, Watersmeet, and Wakefield. The Northern Corridor Backbone connects Round One network in Mackinac City to existing network in Iron Mountain and Chrystal Falls. This segment of the Project crosses lands within the Hiawatha and Ottawa National Forests. The entire 343.0 miles of the corridor occur within existing disturbed ROW’s, with 34% of the route consisting of aerial fiber, 52% of the route consisting of underground fiber and 14% is classified as urban. Approximately 9% of the Backbone will be in urban areas. Seven telecommunications huts are proposed along the Northern Corridor: Engadine, Manistique, Escanaba, Iron Mountain, Chrystal Falls, Watersmeet, and Wakefield.

Merit will purchase existing fiber optic cable to cross the five mile Mackinac Bridge between Mackinaw City and St. Ignace.

The St. Ignace to Sault Ste. Marie Spur is 54.0 miles of existing fiber infrastructure and one existing telecommunication hut that will be purchased by the Project. It connects to the Merit’s Round One network in St. Ignace and terminates in the city of Sault Ste. Marie.

The Watersmeet to Houghton Spur connects Watersmeet to Merit’s core network in Houghton and passes through the city of Rockland. This segment of the Project crosses lands within the Ottawa National Forest. The entire 88.1 miles of the corridor occur within existing disturbed ROW’s, with 12% of the route consisting of aerial fiber, 67% consisting of underground fiber, and 21% of the route in urban areas.

The Rockland to Ontonagon Spur connects to Merit’s core network in Houghton. The entire 14.0 miles of the corridor occur within existing disturbed ROW’s, with 26% of the route consisting of aerial fiber, 47% consisting of underground fiber, and 27% of the route in urban areas.

2.2.4 Green Bay Spur (Figure 2.2.3 b) The Green Bay Spur connects Powers (MI) to the existing University of Wisconsin (Green Bay) network and passes through the cities of Menominee and Marinette (WI). The entire 103.0 miles of the corridor occur within existing disturbed ROW’s, with 35% of the route consisting of aerial fiber, 57% consisting of underground fiber, and 8% of the route in urban areas. One telecommunications hut is proposed in Marinette (WI).

2.2.5 Duluth Spur (Figure 2.2.4) The Duluth Spur connects Ironwood (MI) to the existing University of Minnesota’s network in Duluth (MN), passing through the Bad River Band of Lake Superior Chippewa Reservation and the city of Ashland (WI). This segment of the Project crosses lands within the Chequamegon National Forest. The entire 113.9 miles of the corridor occur within existing disturbed ROW’s, with 28% of the route consisting of aerial fiber, 40% consisting of underground fiber, and 32% of the route in urban areas. Two telecommunications huts are proposed: Ashland (WI) and Poplar (WI).

Merit REACH-3MC II Final Environmental Assessment (7/15/2011) 26 Figure 2.2.2 Northeastern Corridor

Merit REACH-3MC II Final Environmental Assessment (7/15/2011) 27 Figure 2.2.3a Northern Corridor and Spurs

Merit REACH-3MC II Final Environmental Assessment (7/15/2011) 28 Figure 2.2.3b Northern Corridor and Spurs, Green Bay Spur

Merit REACH-3MC II Final Environmental Assessment (7/15/2011) 29 Figure 2.2.4 Duluth Spur

Merit REACH-3MC II Final Environmental Assessment (7/15/2011) 30 2.3 ALTERNATIVES

The alternatives considered for the Project are all based upon Merit’s existing core or backbone fiber network and REACH-3MC Round One infrastructure (Figure 1.1.1). Since the other networks depicted are not owned by Merit and have limited capacity, all proposed fiber routes had to expand from Merit’s backbone network. Determining the routes of the proposed fiber paths first involved locating connection points in unserved and underserved areas, especially those with schools, libraries, medical and healthcare providers, community colleges and other institutions of higher education, public safety agencies, organizations that support vulnerable populations, job-creating facilities, and other community support organizations. Once connection points were identified, baseline routes were established to the existing backbone network. Route analyses followed, with fiber paths being finalized in a manner that addressed cost constraints and minimized the temporary environmental impacts associated with the Project, while maximizing connectivity between served and unserved areas. Route finalization included the consideration of the following:

2.3.1 No Action Alternative The “No Action Alternative” involves not constructing the Project, and, thus, avoids the minor and temporary construction impacts associated with all of the other Project alternatives. The proposed 1,263 miles of advanced fiber-optic expansion of Merit's existing 1,600+ mile backbone fiber network would not occur. Without the additional multiple strand middle mile fiber infrastructure, Merit and its sub-recipients would be unable to provide affordable, high-performance broadband Internet, voice, and video services to homes, businesses, and community anchor institutions in rural and underserved areas in 29 counties in Michigan, eight counties in Wisconsin and the southern portion of one county in Minnesota. Many rural areas in the region would continue to suffer from no or poor broadband service, limiting residents’ ability to participate in the digital economy.

The high cost and lack of competition for backhaul service would continue to limit last mile service performance, availability, and affordability for homes, businesses, schools, libraries, public safety and other anchor institutions in Michigan, Wisconsin, and Minnesota. Approximately 731,237 households, 49,661 businesses, and 820 anchor institutions, four government organizations, 19 K-12 institutions, 22 public library systems, one major healthcare facility, and 10 higher education locations would be denied convenient, affordable access to broadband technology supported by high-capacity fiber-optic infrastructure. As a specific example, Merit’s plan to extend the Northern Michigan's Emergency Services Internet program to provide e911 services throughout rural northern Michigan would not be realized.

Broadband access is a critical component for economic development. Alternative energy, next generation manufacturing, and other initiatives depend not only on access to information, but on an educated populace well- versed in new technology. Without access to high-quality middle mile fiber infrastructure, learning, productivity, and

Merit REACH-3MC II Final Environmental Assessment (7/15/2011) 31 economic development in the region would suffer. Specifically, failure to implement the Project means that the associated jobs and new businesses would not be realized, including the addition of the anticipated 946 Project- related jobs per year.

2.3.2 Preferred Alternative (Proposed Action) The Preferred Alternative consists of building 1,263 miles of fiber optic cable, purchasing 60 miles of existing fiber optic infrastructure, and placing 11 telecommunication huts. The fiber optic cable will be constructed in existing previously-disturbed road and utility ROW’s using a combination of the aerial and underground installation techniques. This alternative allows the Project to leverage the time, cost, and environmental benefits of utilizing existing utility poles and underground utility conduits, while saving the more expensive and time-consuming underground installation techniques of directional boring and plowing for areas with no available poles and/or restrictive utility ordinances. The Preferred Alternative allows for the selection of the most appropriate fiber installation methodology for the various sites along the Project’s three backbone corridors and 10 spurs. Being able to choose from a variety of aerial and underground installation techniques allows the Project to be responsive to existing site conditions and local, state, and federal regulations that apply to each mile of the extensive 1,263 mile fiber route.

Merit’s network engineering and operations team will install and manage the optical transport equipment and the network equipment including routers and switches. Merit will work with fiber installation contractors to install the fiber along the proposed routes. Turn-Key Network Solutions, Western Tel-Com, Inc. CCI Systems, and Fiber Link Inc. have a signed Memorandum of Understanding in place with Merit Network to provide construction services, including engineering, for the Project upon funding. Merit has worked with each of these organizations on fiber installations throughout Michigan, with the exception of CCI Systems—a Project sub-recipient. Merit has a Memorandum of Understanding with Sky Telecom, LLC to provide project management and inside plant installation within community anchor institution locations. Sky Telecom has vast experience with inside plant requirements for schools, libraries, and governmental agencies.

Table 2.1.1 provides a statewide summary of the Project by corridor and proposed construction methodology. Appendix A provides photographs of the proposed fiber route, organized by corridor. Appendix B provides aerial views of hut locations. Photographs of a typical hut are presented in Appendix C. No new utility corridors will be created; no new access roads will be constructed. Environmental impacts will be minimized through the utilization of existing, previously disturbed utility and road ROW’s for the entire length of the project. Aerial construction will involve the use of existing utility poles. Minor disturbances associated with underground construction and pole replacement will result in the ground surface being returned to its original grade. Therefore, the environmental impacts associated with the Project are anticipated to be relatively minor and temporary.

2.3.3 Alternatives Considered but Eliminated from Further Discussion The first alternative eliminated from further discussion involved constructing the proposed fiber optic cable using underground installation methods only. The costs associated with burying 1,263 miles of fiber were such that meeting the Project’s purpose—to provide affordable, high-performance broadband to homes, businesses, community anchor institutions, and critical community facilities in unserved and underserved areas in Michigan, Wisconsin, and Minnesota—would no longer be feasible. The length of time it would take to install the fiber via this method would also jeopardize the Project’s deadline. Underground installation includes the benefit of using existing conduit to run fiber parallel with existing utilities, minimizing environmental disturbance. However, it also involves increased ground disturbance and potential for environmental impacts associated with plowing that accumulate over the long distance of the Project. Directional boring may be used to reduce environmental impacts to sensitive areas, such as rivers, streams, wetlands, and rare species habitat, and may be specifically required in some areas by regulatory agencies. However, the implementation of the directional boring technique over long distances can be cost-prohibitive. This alternative was ultimately rejected due to high anticipated costs of construction, the amount of time, and large amount of ground disturbance compared to other methods.

Merit REACH-3MC II Final Environmental Assessment (7/15/2011) 32 The second alternative considered but rejected proposed constructing the fiber optic cable using aerial installation methods only. This construction method is most preferred for large-scale fiber projects, as it is very cost-effective and minimizes ground disturbance. Usually, the only time this method is not utilized is when 1) utility poles are not available or are not in good enough condition to support additional utility attachment; 2) municipalities or land management agencies with restrictive local ordinances prohibit the aerial installation of new utilities; and, 3) accessible existing conduit is available for underground installation. Therefore, implementation of aerial-only construction would prevent the Project from providing high-performance broadband to underserved homes, businesses, and institutions located in municipalities with the above-mentioned ordinances and in areas where utility poles are in poor condition or not available. Only considering aerial installation would limit the areas served and increase route distance and Project construction time and cost. For example, larger amounts of underground fiber placement proposed in the Northern Corridor and associated Spurs are indicative of the remote nature of the areas being served and the lack of existing utility poles. The Project’s purpose—to provide affordable, high-performance broadband to homes, businesses, community anchor institutions, and critical community facilities in unserved and underserved areas in 29 Michigan, eight Wisconsin, and one Minnesota counties—would no longer be feasible. For these reasons, this alternative was also ultimately rejected.

The final alternative considered the installation of wireless infrastructure in lieu of aerial or underground installation of fiber optic cable. Wireless infrastructure would require construction of approximately 55 radio towers with 100 microwave dishes and microwave radios throughout the project area. At the base of each tower, huts with radio gear and diesel generators would also need to be installed. The costs associated with constructing and operating approximately 55 radio towers and associated infrastructure were such that meeting the Project’s purpose—to provide affordable, high-performance broadband to homes, businesses, community anchor institutions, and critical community facilities in unserved and underserved areas in the target counties—would no longer be feasible. The length of time it would take to install the wireless infrastructure would also jeopardize the Project’s deadline. Microwave radio technology is not as reliable as fiber optic technology and does not currently support the capacity proposed. Also, many anchor institutions would likely be reticent to connecting to an unreliable network. Therefore, additional redundant wired projects involving fiber optic installation on existing utility poles would likely follow a wireless project. Construction of towers and associated infrastructure would involve significant ground disturbance, visual and aesthetic impacts, and greater potential for significant adverse impacts to natural, cultural, and historical resources compared to a wired project restricted to disturbed and regularly maintained road and utility ROW’s. For these reasons, this alternative was ultimately rejected, and wireless technology was also not incorporated into the Preferred Alternative.

3.0 CHAPTER 3 –EXISTING ENVIRONMENT AND ENVIRONMENTAL

Merit REACH-3MC II Final Environmental Assessment (7/15/2011) 33 3.0 CHAPTER 3 –DESCRIPTION OF THE AFFECTED ENVIRONMENT

3.1 NOISE

The most common source of noise in the ROW’s where the proposed fiber optic cable is to be located is vehicular traffic and the sounds associated with road and utility maintenance. This noise is loudest and most continuous in larger urban areas such as Grand Rapids, Superior, Green Bay and Duluth and in smaller urban areas along interstates and major highways such as I-75, US-2, US-131 U.S. 23, and US-41. The areas with the lowest levels of traffic-related noise are located between these urban areas and are generally located in Michigan’s Upper Peninsula and northern Wisconsin. Sensitive noise receptors such as churches, hospitals, libraries, and schools tend to be more densely clustered in urban and developed areas, but are found throughout the project route. Other sensitive receptors include local parks, state parks and National Forests which are typically located in rural areas. No designated wilderness areas are located within 10 miles of the ROW’s where the proposed fiber optic cable is to be located.

3.2 AIR QUALITY

None of the counties in which the proposed fiber optic cable is proposed have been designated by the U.S. Environmental Protection Agency as Nonattainment Areas for Criteria Air Pollutants (USEPA, 2011). Several Class I Areas, defined in the Clean Air Act as the following areas that were in existence as of August 7, 1977: National Parks over 6,000 acres; National Wilderness Areas and National Memorial Parks over 5,000 acres; and, International Parks, are located within 100 miles of the proposed Project; (USFS et al. 2010) these areas are listed in Table 3.2.1.

Table 3.2.1 Class I Areas within 100 Mile of Proposed Project

CLASS I AREA PROJECT SEGMENT WITHIN 100 MILES Seney Wilderness (USFWS) Northern Corridor Backbone, Green Bay Spur Northern Corridor Backbone, Duluth Spur, Watersmeet-Houghton Isle Royal National Park (NPS) Spur, Rockland-Ontonagon Spur Rainbow Lake (USFS) Northern Corridor Backbone, Duluth Spur Boundary Waters Canoe Area (USFS) Northern Corridor Backbone, Duluth Spur, Voyageurs National Park (NPS) Duluth Spur

3.2.1 Climate, Greenhouse Gases and Global Warming

Climate The proposed Project is located in both the Upper and Lower Peninsulas of Michigan, northern Wisconsin, and the Duluth, Minnesota area and includes five landscape ecosystem regions (Figures 3.3.1a and 3.3.1b). Section VI Southern Lower Michigan’s climate is strongly influenced by the warm humid air masses from the Gulf of Mexico rather than cold dry air masses of continental origin (Albert 1995). Winter precipitation is higher and growing season longer and warmer than that of Section VII to the north. Section VII’s climate is influenced by air masses that usually cross the Great Lakes before entering the Section, resulting in warmer winters, cooler summers, and more lake effect snow within 20-30 miles of the Great Lakes shorelines than in Section VI to the south. The portions of Section VII farthest from the Great Lakes are also at the highest elevation above the lakes and experience more summer precipitation, greater summer and winter temperature extremes, and a shorter growing season (Albert 1995).

Merit REACH-3MC II Final Environmental Assessment (7/15/2011) 34

The climate of Section VIII Northern Lacustrine-Influenced Upper Michigan and Wisconsin is also influenced by air masses crossing the Great Lakes (Albert 1995). Northeastern Wisconsin experiences more continental climate in areas where prevailing winds less often originate over the Great Lakes. Compared to Section IX of Wisconsin and Michigan, Section VIII is warmer in winter months and cooler during the summer. The Great Lakes shorelines (especially Lake Superior) experience lake-effect snow, and rainfall that is evenly distributed throughout the year. Section IX is strongly continental with moderate influence from Lake Superior. Winter temperatures are extremely cold. In areas adjacent to Lake Superior, snowfall and rainfall are heavy as a result of moisture-laden air rising rapidly over bedrock uplands in the northern edge of the section (Eichenlaub et al. 1990, Eichenlaub 1979, Wisconsin Statistical Reporting Service 1967, and Albert et al. 1986 as cited in Albert 1995).

Section X Northern Minnesota experiences slightly higher precipitation than in Sections I, II, and XI to the west, and lower than Section IX to the southeast (Albert 1995). There are low amounts of winter precipitation which subsequently increases the potential for spring fires. Winter temperatures are lower than in Section IX but similar to those in the northern part of Section I and in Section XI.

Greenhouse Gases and Global Warming Greenhouse gases (GHGs) are components of the atmosphere that trap heat relatively near the surface of the earth, and therefore, contribute to the greenhouse effect and global warming. Most GHGs occur naturally in the atmosphere, but increases in their concentration result from human activities such as the burning of fossil fuels. Global temperatures are expected to continue to rise as human activities continue to add carbon dioxide, methane, nitrous oxide, and other greenhouse (or heat trapping) gases to the atmosphere. Since 1900, the Earth's average surface air temperature has increased by about 1.2 to 1.4ºF. The warmest global average temperatures on record have all occurred within the past 10 years, with the warmest year being 2005 (USEPA, 2007b). Most of the U.S. is expected to experience an increase in average temperature. Precipitation changes, which are also very important to consider when assessing climate change effects, are more difficult to predict. Whether or not rainfall will increase or decrease remains difficult to project for specific regions (USEPA, 2010a; IPCC, 2007). The extent of climate change effects, and whether these effects prove harmful or beneficial, will vary by region, over time, and with the ability of different societal and environmental systems to adapt to or cope with the change. Human health, agriculture, natural ecosystems, coastal areas and heating and cooling requirements are examples of climate-sensitive systems. Rising average temperatures are already affecting the environment. Some observed changes include shrinking of glaciers, thawing of permafrost, later freezing and earlier break-up of ice on rivers and lakes, lengthening of growing seasons, shifts in plant and animal ranges and earlier flowering of trees (USEPA, 2010a; IPCC, 2007).

Merit REACH-3MC II Final Environmental Assessment (7/15/2011) 35

Figure 3.3.1a: Regional Landscape Ecosystems of the Project Area - Michigan

Merit REACH-3MC II Final Environmental Assessment (7/15/2011) 36

Figure 3.3.1b: Regional Landscape Ecosystems of the Project Area – Wisconsin and Minnesota

Merit REACH-3MC II Final Environmental Assessment (7/15/2011) 37

3.3 GEOLOGY AND SOILS

The Project is proposed within two United States Physiographic Regions; Region 1: The Superior Upland, Laurentian Upland Division and 12a: Interior Plains Division, Central Lowland Province, and Eastern Lake Section (USGS 2003). The Superior Upland of Wisconsin and Minnesota is the southern extension of the Laurentian Upland Province and is also known as the Canadian Shield. It is the largest U.S. surface exposure of the ancient core (2.6 to 1.6 billion years old) of the North American continent. A thin veneer of glacial deposits left behind when glaciers melted at the end of the Pleistocene Ice Age cover the Precambrian metamorphic and overlying Paleozoic rocks (Cambrian). The metamorphic rock found in the area once formed mountains but now exhibit low topographic relief. Some of these highly altered rocks have been important sources of iron, copper, and other industrial minerals. The Eastern Lake Section is characterized by the Michigan Basin, a bowl-shaped landscape feature of uncertain origin that contains over 2.5 miles of inward-dipping Paleozoic strata with a veneer of Jurassic sedimentary rocks. This region is part of the tectonically less active interior of the continent, located between the Appalachians and the Rocky Mountains. The Michigan Basin subsided rapidly from the Cambrian to Silurian Periods, filling with shallow-water marine sediments (USGS 2003). During the Wisconsinan Glaciation of the Pleistocene Epoch, Michigan was completely covered by ice. Glacial retreat occurred from 10,000 to 16,000 years ago.

The Project area’s current physiography and soils are the result of glacial deposits, post-glacial erosion, and soil formation processes acting on the glacial parent material (Albert et al. 1986). Per the USGS classification of regional landscape ecosystems in Michigan, Minnesota, and Wisconsin, the Project involves five landscape ecosystem regions (Figure 3.3.1.1 and Figure 3.3.1.2) (Albert et al. 1986, Albert 1995):

• Section VI Southern Lower Michigan • Section VII Northern Lacustrine-Influenced Lower Michigan • Section VIII Northern Lacustrine-Influenced Upper Michigan and Wisconsin • Section IX Northern Continental Michigan, Wisconsin, and Minnesota • Section X Northern Minnesota

Section VI Southern Lower Michigan Section VI Southern Lower Michigan is covered by Wisconsinan-age glacial and postglacial landforms including lake plain, outwash, ground moraine, and end moraine (Albert 1995). The bedrock geology is underlain by Paleozoic bedrock deposited in marine and near-shore environments and includes sandstone, shale, limestone and dolomite (Dorr and Eschman 1984 and Milstein 1987 as cited in Albert 1995). The Section is characterized by rolling hills and flat lake plains that have been modified by urban development and agriculture. The soils are derived from underlying limestone, shale, and sandstone, and are generally loamy and calcareous. Most of the soils are Alfisols (USDA Soil Conservation Service 1967 as cited in Albert 1995). Section VI contains six Subsections: Washtenaw, Kalamazoo Interlobate, Allegan, Ionia, Huron, and the Saginaw Lake Plain.

Section VII Northern Lacustrine-Influenced Lower Michigan Section VII Northern Lacustrine-Influenced Lower Michigan was covered during the Wisconsinan Glaciation with common landforms such as lake plain, outwash plain, end moraine, and ground moraine occurring across the landscape (Albert 1995). The Section is underlain by Paleozoic bedrock deposited in marine and near-shore environments and includes sandstone, shale, limestone and dolomite (Dorr and Eschman 1984 and Milstein 1987 as cited in Albert 1995). Soils in the section range from clay to sands, and almost all the soils are forest types classified primarily as Spodosols (USDA Soil Conservation Service 1967 as cited in Albert 1995). Section VII contains six Subsections: Arenac, Highplains, Newaygo Outwash Plain, Manistee, Leelanau and Grand Traverse Peninsula, and Presque Isle.

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Section VIII Northern Lacustrine-Influenced Upper Michigan and Wisconsin Section VIII Lacustrine-Influenced Upper Michigan and Wisconsin is underlain by Cambrian-age sandstone and Paleozoic limestone, shale and dolomite (Dorr and Eschman 1984 as cited in Albert 1995) and the flat topography contains large expanses of swamp forest and peatland. Soils of the extensive sand and clay lake plain are largely poorly drained or very poorly drained and support extensive peatlands and swamp forests. Excessively drained soils are found in the outwash plains, with the remaining soils sandy and loamy tills. The most common soils orders are Alfisols, Histosols, and Entisols, with some Orthods and Aquods (USDA Soils Conservation Service 1967 as cited in Albert 1995). Section VIII contains three Subsections: Niagaran Escarpment and Lake Plain, Luce, and Dickinson.

Section IX Northern Continental Michigan, Wisconsin, and Minnesota Section IX Northern Continental Michigan, Wisconsin, and Minnesota is characterized by large exposures of; 1) Precambrian bedrock in the north, 2) exposed middle Precambrian volcanics, conglomerates, sandstones, and shales on the Keweenaw Peninsula, and 3) Cambrian sandstone, with some dolomite and shale often within a few feet of the surface underlying the glacial drift (Doonan and Hendrickson 1968, Dorr and Eschman 1984, Ostrom 1981, Reed and Daniels 1987, and Thwaites 1929 as cited in Albert 1995). The red soils of the area result from the abrasion of bedrock by continental glaciation and subsequent incorporation into the glacial drift. The most common landform features are ground- and end-moraine ridges, which occur throughout the Section. Clayey glacial lake plains occur near Lake Superior. Section IX also contains several extensive outwash plains. Stony, red, sandy loams are found on the moraines, and one to two feet of wind-blown silt blanket large areas, creating a silt-loam surface soil which becomes discontinuous in northern Wisconsin and Michigan (Albert 1990, Hole and Germain 1994, and Hole 1976 as cited in Albert 1995). The major soils are classified as Spodosols (Orthods), with some Boralfs, Ochrepts, Aquepts, and Psamments (USDA Soil Conservation Service 1967 and Anderson and Grigal 1984 as cited in Albert 1995). Section IX contains eight Subsections: Spread Eagle-Dunbar Barrens, Michigamme Highland, Upper Wisconsin/Michigan Moraines, Lincoln Formation Till Plain, Lac Vieux Desert Outwash Plain, Bergland, Keweenaw, and Lake Superior Lake Plain.

Section X Northern Minnesota Section X Northern Minnesota is characterized by Wisconsinan-age glacial drift and landforms, with the largest glacial feature a significant part of Glacial Lake Agassiz. Ground- and end-moraine ridges cover large areas in Section X, with the till of these moraines quite variable depending on the source material (Albert 1995). There are vast peatlands on the glacial lake plains. Precambrian igneous and metamorphic bedrock underlies all of the Section, with thick glacial drift up to 600 feet deep blanketing much of the area (Morey 1976, Olsen and Mossler 1982, and Ostrom 1981 as cited in Albert 1995). From Duluth to the Canadian border, Section X is underlain by Keweenawan basalt and diabase (Hargrave 1992 as cited in Albert 1995). There are also Cambrian shale, sandstone, and dolomite at the extreme southeastern edge, and Cretaceous shale, sandstone, and clay near the southwestern edge (Morey 1976 as cited by Albert 1995). Section X contains twelve Subsections: Bayfield Barrens, Mille Lacs Uplands, Laurentian Highlands, Tamarack Lowlands, Pine Moraines and Outwash Plains, Chippewa Plains, St. Louis Moraines, Nashwauk Uplands, North Shore (Lake Superior) Highlands, Border Lakes, Littlefork- Vermilion Uplands, and Agassiz Lowlands.

3.4 WATER RESOURCES

3.4.1 Surface Water All of the rivers, streams, lakes, and ponds encountered along the Project route have experienced some type of past disturbance, as they are all located within existing road and/or utility ROW’s. Based on geographic information systems (GIS) analyses of watercourse (river and stream) and waterbody (lake and pond) shapefiles (MiGDL 2002b, 2002c, WiDNR, 2010, MnDNR, 2010, WiDNR 2010a and b, MiDNRE 2010a and b), the Project involves 189 watercourse crossings and 4 waterbody crossings for the entire route. For the 189 watercourse crossings, 96 involve aerial installation, 73 involve underground installation, 4 utilize existing conduit, and 16 are in an Urban Areas. Waterbody crossings include one aerial installation, one existing conduit, and two Urban Areas. Table 3.4.1.1

Merit REACH-3MC II Final Environmental Assessment (7/15/2011) 39 summarizes route crossings of surface water features by corridor, county, and crossing type. Appendix G depicts the locations of surface water crossings for the entire Project route by Corridor. The Middle Corridor (backbone and associated spurs) involves 53 watercourse crossings and one waterbody crossing in 13 counties. The Northeastern Corridor (backbone and associate spurs) involves 34 watercourse crossings and one waterbody crossings in eight counties. The Northern Corridor (backbone and associated spurs) involves 57 watercourse crossings and one waterbody crossing in 11 counties. The Green Bay Spur involves 9 watercourse crossings in four counties. The Duluth Spur involves 36 watercourse crossings and 1 waterbody crossings in nine counties.

Surface water crossings are regulated by the U.S. Army Corps of Engineers (ACOE), MiDNRE, WiDNR, and MnDNR. Refer to Chapter 5 for a summary of permitting requirements and Appendix F for agency correspondence.

3.4.2 Groundwater Drinking water aquifers in the area that will be affected by the proposed Project area are significantly deeper than the maximum depth at which the proposed fiber optic cable will be installed. However, high groundwater tables are likely to occur in wetlands and near watercourse crossings and may be encountered during short-term excavation associated with placement of new replacement poles and/or directional bore pits.

Merit REACH-3MC II Final Environmental Assessment (7/15/2011) 40

Table 3.4.1.1 Summary of Surface Water Crossings

# of Watercourse Crossings # Waterbody Crossings Total Corridor County State Crossings Aerial Conduit Underground Urban Aerial Conduit Underground Urban

Middle Corridor Kent MI 0 1 5 0 0 0 0 0 6 Montcalm MI 0 0 2 0 0 0 0 0 2 Mecosta MI 4 1 2 0 0 0 0 0 7 Osceola MI 2 1 0 0 0 0 0 0 3 Backbone Wexford MI 2 0 0 0 0 1 0 0 3 Missaukee MI 2 0 1 0 0 0 0 0 3 Roscommon MI 0 0 2 0 0 0 0 0 2 Ogemaw MI 14 0 1 0 0 0 0 0 15 Iosco MI 2 0 0 0 0 0 0 0 2 Osceola MI 0 0 0 0 0 0 0 0 0 LeRoy to Luther Spur Lake MI 0 0 0 0 0 0 0 0 0 Ogemaw MI 0 0 0 0 0 0 0 0 0 Oscoda MI 3 0 0 0 0 0 0 0 3 Rose City to Kalkaska Spur Crawford MI 4 0 1 0 0 0 0 0 5 Kalkaska MI 2 0 0 0 0 0 0 0 2 Grayling to Lovells Spur Crawford MI 1 0 0 0 0 0 0 0 1 Grayling to Higgins Lake Crawford MI 0 0 0 0 0 0 0 0 0 Spur

Northeastern Corridor Iosco MI 1 0 0 0 0 0 0 0 1 Backbone Alcona MI 5 0 0 0 0 0 0 0 5 Alpena MI 6 0 0 2 0 0 0 0 8

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# of Watercourse Crossings # Waterbody Crossings Total Corridor County State Crossings Aerial Conduit Underground Urban Aerial Conduit Underground Urban

Montmorency MI 1 1 1 0 0 0 0 0 3 Presque Isle MI 3 0 2 0 0 0 0 0 5

Cheboygan MI 6 0 1 1 1 0 0 0 9 Emmet MI 0 0 0 0 0 0 0 0 0

Indian River to Gaylord Cheboygan MI 3 0 0 1 0 0 0 0 4 Spur Otsego MI 0 0 0 0 0 0 0 0 0 Northern Corridor Mackinac MI 3 0 2 0 0 0 0 0 5 Chippewa MI 0 0 0 0 0 0 0 0 0 Schoolcraft MI 1 0 1 0 0 0 0 0 2 Delta MI 6 0 3 1 0 0 0 0 10 Backbone Menominee MI 1 0 2 0 0 0 0 0 3 Dickinson MI 0 0 2 0 0 0 0 0 2 Florence WI 1 0 0 0 0 0 0 0 1 Iron MI 0 0 3 1 0 0 0 0 4 Gogebic MI 4 0 14 0 0 0 0 0 18 Gogebic MI 1 0 0 0 0 0 0 0 1 Watersmeet to Houghton Ontonagon MI 1 0 9 1 0 0 0 0 11 Spur Houghton MI 0 0 0 0 0 0 0 1 1 Rockland to Ontonagon Ontonagon MI 0 0 0 0 0 0 0 0 0 Spur

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# of Watercourse Crossings # Waterbody Crossings Total Corridor County State Crossings Aerial Conduit Underground Urban Aerial Conduit Underground Urban

Wisconsin/Minnesota Spurs Menominee MI 1 0 2 1 0 0 0 0 4 Marinette WI 0 0 1 0 0 0 0 0 1 Green Bay Spur Oconto WI 0 0 1 0 0 0 0 0 1 Brown WI 1 0 2 0 0 0 0 0 3 Iron WI 6 0 2 0 0 0 0 0 8 Ashland WI 1 0 3 2 0 0 0 0 6 Duluth Spur Bayfield WI 3 0 4 0 0 0 0 0 7 Douglas WI 5 0 4 6 0 0 0 1 16 St. Louis MN 0 0 0 0 0 0 0 0 0 Total -- -- 96 4 73 16 1 1 0 2 193

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3.4.3 Wetlands Data from the National Wetland Inventory (NWI) and Wisconsin Wetland Inventory (WWI) were used to assess the number and extent of wetland crossings that are proposed. National Wetland Inventory data were not available for Florence County, Wisconsin, therefore hydric soils maps were used to determine wetland areas (WiDNR 2010a). The number of wetland crossings is based on the number of NWI and WWI mapped wetlands that intersected the Project route. This is a conservative estimate of wetland crossings, based on the level of accuracy in mapping and the width of the corridor that will be disturbed by construction. For example, areas within road ROW’s may be shown as wetland on an NWI map, when, in reality, these areas may consist of both uplands created by road construction and grading (embankments) and wetlands.

All of the wetlands encountered along the Project route have experienced some type of past disturbance, as they are located within existing road and/or utility ROW’s. Many of these wetlands may not occur directly within the proposed area of temporary disturbance, since much of the road ROW along the Project route was graded above the natural maximum water elevation of the wetlands. These ROW’s are regularly maintained, and wetland vegetation that does occur within the ROW tends to be herbaceous due to frequent maintenance activities such as mowing and clearing. Based on GIS analyses of NWI and WWI data for the state (MiGDL 2002d, WiDNR 2010g, MnDNR 2010b), the Project involves 971 wetland crossings totaling 99 miles, e.g. 7.8% of the entire Project route.

As stated above, it is very unlikely that all of the wetlands identified through this analysis truly extend into the ROWs where Project activities are proposed, especially for the majority of the Project route within existing road ROW’s where significant grade changes and vegetation management have occurred. Table 3.4.3.1 summarizes the proposed wetland crossings by corridor, county, and crossing type. Tables providing the details of each wetland crossing for each corridor, including county, local municipality, wetland type, wetland coordinates, and crossing length, and method of installation can be found in Appendix H. Wetland vegetation within these ROW’s tends to be predominately emergent wetland vegetation since the Project will be restricted to regularly-maintained road and utility ROW’s where mowing and clearing activities favor herbaceous plant communities. Appendix H contains maps of the locations of NWI wetland crossings for the entire Project route by corridor.

The Middle Corridor Backbone involves 121 aerial, 48 underground, 32 conduit and 5 wetland crossings in urban areas within nine counties for a total wetland crossing distance of 14.24 miles. The Northeastern Corridor involves 105 aerial, 15 underground and 3 urban wetland crossings in seven counties for a total wetland crossing distance of 12.09 miles. The Northern Corridor involves 135 aerial, 226 underground, and 10 urban wetland crossings in nine counties for a total wetland crossing distance of 50.74 miles. The Leroy to Luther Spur involves 12 aerial and 1 underground wetland crossings in two counties for a total wetland crossing distance of 0.92 miles. The Rose City to Kalkaska Spur involves 25 aerial, 2 underground and 1 urban wetland crossings in four counties for a total wetland crossing distance of 2.00 miles. The Grayling to Higgins Lake has no wetland crossings. The Grayling to Lovells Spur involves two aerial wetland crossings in one county for a total wetland crossing distance of 0.37 miles. The Indian River to Gaylord Spur involves three aerial and two underground wetland crossings in two counties for a total wetland crossing distance of 0.21 miles. The Watersmeet to Houghton Spur involves 2 aerial, 30 underground, and 8 urban wetland crossings in three counties for a total wetland crossing distance of 3.11 miles. The Rockland to Ontonagon spur involves two aerial and two underground wetland crossings in one county for a total wetland crossing distance of 0.35 miles. The Green Bay Spur involves 33 aerial, 84 underground, and 3 urban wetland crossings in four counties for a total wetland crossing distance of 10.44 miles. The Duluth Spur involves 25 aerial wetland, 24 underground and 9 urban wetland crossings in six counties for 4.61 miles.

The telecommunication huts will be installed on previously disturbed lands in developed upland areas and therefore no impacts to wetlands would occur.

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3.4.4 Coastal Zones The Coastal Zone Management Act establishes a national policy for the wise use of the Nation’s coastal resources, including the Great Lakes, and balances economic development with environmental conservation. The Act established a voluntary program to encourage coastal states to develop and implement Coastal Management Plans to assist in meeting this goal. Each state's plan is required to define boundaries of the Coastal Zone, to identify uses of the area to be regulated by the state, the mechanism (criteria, standards or regulations) for controlling such uses, and broad guidelines for priorities of uses within the designated Coastal Zone.

Michigan's Coastal Zone boundary generally extends a minimum of 1,000 feet inland from the Ordinary High Water Mark of the Great Lakes and connecting channels, or further to include coastal lakes, river mouths and bays, floodplains, coastal wetlands, designated sand dune areas, public parks, recreation and natural areas and urban areas. The Wisconsin Coastal Management Program was established in 1978 under the Federal Coastal Zone Management Act to protect and promote the wise use the natural resource for present and future generations. The boundaries of the Coastal Zone subject to the Wisconsin Coastal Management Program extend to the state boundary on the waterward side and, on the inland side, include the entirety of 15 counties with frontage on Lake Superior, Lake Michigan, or Green Bay. Minnesota’s Lake Superior Coastal Program, which was approved in 1999 to protect the State’s 189 miles of coastline, is led by the Minnesota Department of Natural Resources. Minnesota's Coastal Zone includes the area approximately six miles inland from Lake Superior following the nearest township boundaries along the shore.

Per the MiDNRE’s Coastal Zone Boundary Maps (MiDNRE 2010a), the Project crosses approximately 43.96 miles of Coastal Zone identified in Michigan’s Coastal Management Plan along the Middle, Northeastern and Northern Corridors, including the Rockland to Ontonagon, Watersmeet to Houghton, and Green Bay Spurs representing 4% of the total Project route (Table 3.4.4.1). No telecommunication huts are proposed in Coastal Zones in Michigan. According to the Wisconsin Coastal Zone Program Maps (WiDNR 2010), the Project crosses approximately 164.51 miles of coastal zone along the Northern Corridor’s Green Bay and Duluth Spurs representing 13% of the total Project route (Table 3.4.4.2). Three telecommunications huts are proposed in counties within Wisconsin’s Coastal Zone. These include the Marinette Hut on the Green Bay Spur in Marinette County, and the Ashland and Poplar huts located on the Duluth Spur in Ashland and Bayfield Counties respectively. The entire 6.8 mile long fiber optic route in Minnesota lies within lies within that state’s designated Coastal Zone. Refer to Appendix I for maps showing Project route locations within designated Coastal Zones.

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Table 3.4.4.1 Summary of Michigan Coastal Zone Crossings

CORRIDOR NAME CORRIDOR TYPE DISTANCE IN MILES MIDDLE CORRIDOR Iosco County Urban (Utility and Road ROWs) 0.05 TOTAL MIDDLE CORRIDOR 0.05 NORTHEASTERN CORRIDOR Aerial (Utility and Road ROW s) 0.11 Alcona Subtotal 0.11

Aerial (Utility and Road ROWs) 4.05 Alpena Urban (Utility and Road ROWs) 3.90 Subtotal 7.95

Underground (Road ROW) 1.92 Aerial (Utility and Road ROWs) 9.91 Cheboygan Urban (Utility and Road ROWs) 2.80 Subtotal 14.63

Urb an (Utility and Road ROWs) 0.46 Presque Isle Subtotal 0.46 TOTAL NORTHEASTERN CORRIDOR 23.15 NORTHERN CORRIDOR BACKBONE Underground (Road ROW) 4.35 Aerial (Utility and Road ROWs) 3.63 Delta Urban (Utility and Road ROWs) 1.09 Subtotal 9.07

Aeri al (Utility and Road ROWs) 6.34 Schoolcraft Urban (Utility and Road ROWs) 1.70 Subtotal 8.04 TOTAL NORTHERN CORRIDOR BACKBONE 17.11 NORTHERN CORRIDOR, WATERSMEET TO HOUGHTON SPUR Houghton Urban (Utility and Road ROWs) 1.55 TOTAL WATERSMEET TO HOUGHTON SPUR 1.5 5 NORTHERN CORRIDOR, ROCKLAND TO ONTONAGON SPUR Ontonagon Urban (Utility and Road ROWs) 0.30 TOTAL ROCKLAND TO ONTONAGON SPUR 0.30 NORTHERN CORRIDOR, GREEN BAY SPUR Urban (Utility and Road ROWs) 1.12 Menominee Aerial (Utility and Road ROWs) 0.68 Subtotal 1.80 TOTAL GREEN BAY SPUR 1.80 GRAND TOTAL 43.96 Michigan Coastal Zones

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Table 3.4.4.2 Summary of Wisconsin Coastal Zone Crossings

CORRIDOR NAME CORRIDOR TYPE DISTANCE IN MILES NORTHERN CORRIDOR, GREEN BAY SPUR Underground (Road ROW) 11 .54 Aerial (Utility and Road ROWs) 3.79 Brown Urban (Utility and Road ROWs) 1.51 Subtotal 16.84

Underground (Road ROW) 10.99 Aerial (Utility and Road ROWs) 3.59 Marinette Urban (Utility and Road ROWs) 0.50 Marinette Hut (T30N, R23E, S 14) --- Su btotal 15.08

Underground (Road ROW) 10.39 Oconto Aerial (Utility and Road ROWs) 17.58 Subtotal 27.97 TOTAL NORTHERN CORRIDOR, GREEN BAY SPUR 59.89 NORTHERN CORRIDOR, DULUTH SPUR Underground (Road ROW) 11.67 Aerial (Utility and Road ROWs ) 3.67 Ashland Urban(Utility and Road ROWs) 6.10 Ashland Hut (T47N, R4W, S6) --- Subtotal 21.44

Underground (Road ROW) 22.01 Aerial (Utility and Road ROWs) 7.18 Bayfield Urban(Utility and Road ROWs) 2.48 Subtotal 31.67

Underground (Road R OW) 8.03 Aerial (Utility and Road ROWs) 10.71 Douglas Urban(Utility and Road ROWs) 14.08 Poplar Hut (T47N, R11W, S6) --- Subtotal 33.22

Underground (Road ROW) 6.54 Aerial (Utility and Road ROWs) 11.75 Iron Urban (Utility and Road ROWs) Subtotal 18.29 TOTAL NORTHERN CORRIDOR, DULUTH SPUR 104.62 GRAND TOTAL 164.51 Wisconsin Coastal Zones

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3.4.5 Environmental Areas Part 323 of the Michigan Natural Resources and Environmental Protection Act, 1994 PA 451, as amended, provides for the designation of Environmental Areas (EAs) up to 1,000 feet landward of the Ordinary High Water Mark of the Great Lakes or 1,000 feet landward of the Ordinary High Water Mark of lands adjacent to waters affected by levels of the Great Lakes. Per the MiDNRE’s Environmental Areas County Table (MiDNRE 2010), the Northeastern and Northern Corridors cross EAs in four counties (Table 3.4.5.1, Maps - Appendix J). The Northeast Corridor crosses approximately 3.3 miles of EA on US-23 south of Alpena along Squaw Bay and approximately 0.7 miles of EA on US- 23 in Cheboygan. The Northern Corridor crosses four EAs in Delta County; 1) 2.70 miles on US-2 between M-183 and Main St. in Garden Township, 2) 2.60 miles on US-2 southwest of Rapid River in Masonville Township, 3) 0.3 miles at the Escanaba River on US-2 just north of Escanaba, and 4) 0.05 miles on US-2 north of Gladstone in Brampton Township.

None of the proposed telecommunication huts are located in designated Environmental Areas.

3.4.6 Critical Dune Areas Part 353 of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended, provides for the designation of Critical Dune Areas. The Project route, including proposed locations for telecommunications huts, does not traverse any designated Critical Dune Areas (MiDNRE 1989, MiGDL 2002a). Therefore, this resource area will not be analyzed further in this document.

3.4.7 Floodplains Floodplains would likely be encountered along many of the watercourse crossings proposed by the Project and where the route parallels the Great Lakes shoreline. No permanent filling or excavation is proposed in floodplains. In Michigan, a permit is required from the MiDNRE to cross floodplains; floodplain permits are not required in Wisconsin or Minnesota but these crossings are typically reviewed as part of applications for stream and river crossings.

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Table 3.4.5.1 Summary of Environmental Areas

Aerial Underground Area Location Corridor Counties General Location Crossing Crossing Urban Total Mileage Number (Township/Range/Section (miles) (miles)

Alpena Twp US-23 just south of Alpena (MI) 05-12 2.2 0.0 1.1 3.3 T30N R8E S 9,10,11,15,16,22 Alpena (Squaw Bay)

City of Cheboygan Cheboygan (MI) 05-09 US-23/M-27 Cheboygan 0.0 0.0 0.7 0.7 T38N R1W S30

Little Fish Dam River Garden Twp. 03-17 US-2 between M-183 and 2.7 0.0 0.0 2.7 T41N R18W S 32, 33 Main St. Northeastern Corridor Masonville Twp. Rapid/Tacoosh River 03-08 0.5 2.0 0.0 2.5 T41N R21W S 29,30, 31, 32 US-2 at Rapid River

Delta (MI) Wells Twp. Escanaba River 03-06 0.0 <0.1 0.3 0.3 T39N R22W S 7, 18 US-2 south of Gladstone Days River US-2 just north of Brampton Twp. 03-07 Gladstone between 225 0.0 <0.1 0.0 <0.1 T40N R22W S2 Ln and Days River 245 Rd.

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3.4.8 Designated Wild and Scenic Rivers Congress passed the National Wild and Scenic Rivers Act in 1968 (Public Law 90-542; 16 U.S.C. 1271 et seq.) to preserve certain rivers with outstanding natural, cultural, and recreational values. A “Section 7 Analysis” is required for any project that may impact 1) a designated Wild or Scenic River; 2) a river that has been authorized for study as potential components of the Wild and Scenic River System; and, 3) tributaries to designated Wild and Scenic Rivers. This analysis will be conducted by the U.S. Forest Service since all of these crossings occur on Forest Service land. Over the entire 1,263 mile Project route, proposed fiber infrastructure crosses seven federally-designated Wild and Scenic Rivers; all of which are located in Michigan on the Northern Corridor (Table 3.4.8.1) (USDA Forest Service et al. 2007). Figure 3.4.8.1 shows these crossings.

Aerial Crossings : The proposed crossings of Middle Branch of the Ontonagon (Gogebic County, MI), Sturgeon (Delta County, MI), and Whitefish (Delta County, MI) Rivers would occur via aerial installation on existing utility poles within an existing, regularly-maintained, utility ROW; tributary crossings via aerial installations would occur on existing utility poles within an existing, regularly-maintained road ROW.

Underground Installation : The proposed crossings of Carp Creek (Mackinac County, MI), the South Branch of the Paint River (Gogebic County, MI), the Middle Branch of the Ontonagon River (Gogebic County, MI), Tenderfoot Creek (tributary of the Ontonagon River) (Gogebic County, MI), and the Presque Isle River (Gogebic County, MI) would occur via directional drilling to place underground conduit within existing road ROW’s.

3.4.9 State-Designated Rivers Michigan's Natural River Act, Part 305, Natural Rivers, of Public Act 451 of 1994, was passed to preserve and enhance Michigan’s rivers with unique aesthetic, free-flowing condition, recreation, boating, historic, water conservation, floodplain, and fisheries and wildlife habitat values. A Natural River Zoning Permit from the MiDNRE Fisheries Division is required for crossings of designated Natural Rivers including a 400-foot wide buffer on either side of the river.

Wisconsin’s highest quality waters are designated as Outstanding Resource Waters (ORWs) or Exceptional Resource Waters (ERWs) (WiDNR 2010b). These surface waters have been determined by the State of Wisconsin to warrant additional protection from the effects of pollution due to their valuable fisheries and wildlife habitat, good water quality, recreational opportunities, and are the lack of significant impact by human activities. These designations are intended to meet federal Clean Water Act obligations but are not regulatory in nature. The waterways permit issued by WiDNR for stream and river crossings includes crossings of ORW’s and ERW’s.

The Project does not cross any State-designated rivers in Minnesota. Refer to Chapter 5 for a summary of waterway crossing permit requirements, including those required for state-designated rivers, and Appendix F for agency correspondence.

Table 3.4.8.1 summarizes Michigan Natural Rivers, Outstanding Resource Waters, Exceptional Resource Waters, and the Federal Wild and Scenic River crossings by corridor, location, and crossing type. Figure 3.4.9.1 shows a Project-wide overview of designated river crossings. Refer to Appendix G for detailed maps of designated river crossings. The proposed crossings of 21 Natural Rivers, one ORW river, and two ERW rivers would occur via aerial installation on existing utility poles within an existing, regularly-maintained, road and utility ROW’s. The proposed crossings of four Natural Rivers and four ORW rivers would occur via boring to place underground conduit within existing ROW’s.

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Table 3.4.8.1 Summary of Designated River Crossings

CROSSING CORRIDOR COUNTY STATE COMMUNITY RIVER STATUS TYPE

MIDDLE CORRIDOR MI Algoma Twp. Underground Rouge River MI Natural River Kent MI Algoma Twp. Underground Little Cedar Creek (tributary to Rogue River) MI Natural River MI Solon Twp. Underground Cedar Creek (tributary to Rogue River) MI Natural River Montcalm MI ------Mecosta MI ------Osceola MI Burdell/Sherman Twp. Aerial E. Branch Pine River MI Natural River Wexford MI ------Missaukee MI ------Roscommon MI ------West Branch Twp./Churchill MI Aerial Klacking Creek (tributary to Rifle River) MI Natural River Twp. MI Cumming Twp. Aerial Bailer Creek (tributary to Rifle River) MI Natural River Backbone MI Cumming Twp. Aerial Prior Creek (tributary to Rifle River) MI Natural River MI Cumming Twp. Aerial Wilkins Creek (tributary to Rifle River) MI Natural River MI Rose City Aerial Houghton Creek (Tributary to Rifle River) MI Natural River

Ogemaw MI Rose Twp. Aerial Andrews Creek (Tributary to Rifle River) MI Natural River MI Rose Twp. Aerial Mayhue Creek (Tributary to Rifle River) MI Natural River

MI Rose Twp. Aerial Oyster Creek (Tributary to Rifle River) MI Natural River

MI Rose Twp. Aerial Vaughn Creek (Tributary to Rifle River) MI Natural River MI Goodar Twp. Aerial Harper Creek (tributary to Rifle River) MI Natural River MI Goodar Twp. Aerial South Branch River (tributary to Rifle River) MI Natural River MI ------

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CROSSING CORRIDOR COUNTY STATE COMMUNITY RIVER STATUS TYPE

MIDDLE CORRIDOR Osceola MI ------LeRoy to Luther Spur Lake MI ------Ogemaw MI ------MI Big Creek Twp. Aerial Lost Creek (tributary to Au Sable River) MI Natural River Oscoda MI Big Creek Twp. Aerial East Branch Big Creek (tributary to Au Sable River) MI Natural River MI Big Creek Twp. Aerial West Branch Big Creek (tributary to Au Sable River) MI Natural River MI South Branch Twp. Underground South Branch Au Sable River MI Natural River Rose City to Kalkaska MI Grayling Aerial Au Sable River MI Natural River Spur Crawford MI Grayling Aerial Au Sable River MI Natural River MI Grayling Twp. Aerial Au Sable River MI Natural River MI Frederic Twp. Aerial Manistee River MI Natural River MI Excelsior Twp. Aerial North Branch Manistee River MI Natural River Kalkaska MI Kalkaska Aerial North Branch Boardman River MI Natural River Grayling to Lovells Spur Crawford MI Lovells Twp. Aerial East Branch Au Sable River MI Natural River Grayling to Higgins Lake Crawford MI ------Spur NORTHEASTERN CORRIDOR Iosco MI ------Alcona MI ------Alpena MI ------Backbone Montmorency MI ------Presque Isle MI ------Cheboygan MI Ellis Twp./Koehler Twp. Aerial Pigeon River MI Natural River Emmet MI ------Indian River to Gaylord Cheboygan MI Spur Otsego MI

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CROSSING CORRIDOR COUNTY STATE COMMUNITY RIVER STATUS TYPE

NORTHERN CORRIDOR Federal Wild and Scenic Mackinac MI Brevort Twp. Underground Carp Creek (Hiawatha NF) Chippewa MI ------Schoolcraft MI ------Federal Wild and Scenic MI Nahma Twp. Aerial Sturgeon River (Hiawatha NF) Delta Federal Wild and Scenic MI Masonville Twp. Aerial Whitefish River (Hiawatha NF) Menominee MI ------Dickinson MI ------Backbone Exceptional Resource Florence WI Commonwealth Aerial Fisher Creek Water Iron MI ------Fe deral Wild and Scenic MI Watersmeet Twp. Underground South Branch Paint River (Ottawa NF) Federal Wild and Scenic MI Watersmeet Twp. Underground Middle Branch Ontonagon River (Ottawa NF) Gogebic Federal Wild and Scenic MI Marenisco Twp. Underground Tenderfoot Creek (tributary to Ontonagon River) (Ottawa NF) Federal Wild and Scenic MI Marenisco Twp. Underground Presque Isle River (Ottawa NF) Federal Wild and Scenic Gogebic MI Watersmeet Twp. Aerial Middle Branch Ontonagon River (Ottawa NF) Watersmeet to Houghton Federal Wild and Scenic Spur Ontonagon MI Rockland Twp. Underground Middle Branch Ontonagon River (Ottawa NF) Houghton MI ------Rockland to Ontonagon Ontonagon MI ------Spur

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CORRIDOR COUNTY STATE COMMUNITY CROSSING TYPE RIVER STATUS

WISCONSIN/MINNESOTA SPURS Menominee MI ------Marinette WI ------Green Bay Spur Oconto WI ------Brown WI ------Iron WI ------Ashland WI ------Unnamed tributary to South Fish WI Eileen Twp. Aerial Exceptional Resource Water Creek Bayfield WI Keystone Twp. Underground North Fish Creek Outstanding Resource Water Duluth Spur WI Keystone Twp. Underground North Fish Creek Outstanding Resource Water WI Brule Twp. Underground Tributary to Brois Brule River Outstanding Resource Water Douglas WI Brule Twp. Underground Tributary to Brois Brule River Outstanding Resource Water WI Amnicon Twp. Aerial Amnicon River Outstanding Resource Water St. Louis MN ------14 Underground TOTAL ------Crossings; 29 Aerial -- Crossings

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Figure 3.4.8.1 Wild and Scenic River Crossing Map

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Figure 3.4.9.1 Overall Designated River Crossing Map

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3.5 BIOLOGICAL RESOURCES

The Project Team began corresponding with state and federal agencies in September 2010 to discuss potential impacts to biological resources. Agencies consulted to date include the U.S. Fish and Wildlife Service (USFWS), Michigan Department of Natural Resources & Environment (MiDNRE) Wildlife Division, Michigan Department of Transportation (MDOT) Environmental Section, Wisconsin Department of Natural Resources (WiDNR) Office of Energy, and Minnesota Department of Natural Resources (MnDNR) Ecological and Water Resources Division. Biological resource protection regulations being considered include the following:

• Section 7 of the Endangered Species Act, • Michigan: Natural Resources and Environmental Protection Act, 1994 PA 451, as amended, Part 365 Endangered Species Protection • Wisconsin: State Statute 29.604 Endangered and Threatened Species Protected and Administrative Rule NR 27 Endangered and Threatened Species, and • Minnesota: State Statute 84.0895 Protection of Threatened and Endangered Species and Administrative Rules Chapter 6134 Endangered, Threatened, Special Concern Species and Chapter 6212 Parts 6212.1800 to 6212.2300 Threatened and Endangered Species.

Refer to Appendix F for agency correspondence.

3.5.1 Ecoregions The Project crosses two Level I, two Level II, and two Level III North American Ecoregions mapped by the Commission for Environmental Cooperation (CEC 1997, CEC 2009, USEPA 2010).

Level I The lower half of Michigan’s Lower Peninsula and the Green Bay, Wisconsin area occur within Level I Ecoregion 8.0 Eastern Temperate Forest which is described as having relatively dense and diverse forest cover and high density of human occupancy. The northern Lower and entire Upper Peninsula of Michigan, northern Wisconsin, and Minnesota occur in Level I 5.0 Northern Forests and is characterized by extensive boreal forests and a high density of lakes (CEC 1997).

Level II The lower half of Michigan’s Lower Peninsula and the Green Bay, Wisconsin area occur within Level II 8.1 Mixed Wood Plains which is characterized by oak (Quercus spp.), hickory (Carya spp.), maple (Acer spp.), beech (Fagus grandifolia), and some pine (Pinus spp.), and basswood (Tilia Americana) (CEC 2009). The northern Lower and entire Upper Peninsulas of Michigan, northern Wisconsin, and Minnesota occur in Level II 5.2 Mixed Wood Shield contains mixed conifers (white (Picea glauca) and black spruce (P. mariana), balsam fir (Albes balsamae), jack pine (Pinus banksiana), balsam poplar (Populus balsamifer), oak (Quercus spp.), sugar maple (Acer saccharum), and beech (F. grandifolia) (CEC 2009).

Level III The lower half of Michigan’s Lower Peninsula and the Green Bay, Wisconsin area occur within Level III 8.1.6 Southern Michigan/Northern Indiana Drift Plains Oak and contain hickory forests, northern swamp forests, and beech forests with many lakes and marshes (Griffith et al. 2008). The northern Lower and entire Upper Peninsulas of Michigan, northern Wisconsin, and Minnesota occur in Level III 5.2.1 Northern Lakes and Forests, which is characterized by coniferous and northern hardwood forests with numerous lakes (Griffith et al. 2008).

3.5.2 Wildlife The environmental conditions within the existing, disturbed road and utility ROW’s associated with the Project are not conducive to providing high quality wildlife habitat. As noted above, these ROW’s are regularly-maintained, and corridor vegetation tends to be herbaceous and composed of relatively low-quality ruderal species, due to frequent

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maintenance activities such as mowing and clearing. Road ROW vegetation tends to provide wildlife habitat of only marginal quality, due to limited vegetation diversity and vehicular traffic. Wildlife species that typically utilize roadside and utility ROW’s are adapted to edge conditions and relatively frequent human disturbance, or can be species adapted to other habitat types that utilize fence rows, forest or field edges, and watercourses as travel corridors. Common wildlife species in the Upper Great Lakes include the northern raccoon (Procyon lotor), eastern cottontail (Sylvilagus floridanus), porcupine (Erithizon dorsatum), woodchuck (Marmota monax), white-tailed deer (Odocoileus virginianus), eastern fox squirrel (Sciurus niger), and striped skunk (Mephitis mephitis). As with plant species, wildlife species associated with landscape ecosystems adapted to fire may take refuge within utility corridors. Refer to Section 3.5.4 Threatened and Endangered Species and Critical Habitats for detailed information about rare wildlife species that may occur along the Project route.

3.5.3 Vegetation All of the vegetation encountered along the Project route has experienced some type of past disturbance, being located within existing road and utility ROW’s. These ROW’s are regularly-maintained, and vegetation occurring within the ROW’s tends to be herbaceous and composed of relatively low quality ruderal species, due to frequent maintenance activities such as mowing and clearing. In many cases, frequent disturbance associated with maintenance activities provides environmental conditions conducive to the establishment and spread of non-native, invasive plant species, such as common reed (Phragmites australis), reed canarygrass (Phalaris arundinacea), garlic mustard (Alliaria petiolata), smooth brome (Bromus inermis), Canada thistle (Cirsium arvense), and spotted knapweed (Centaurea maculosa). Road ROW vegetation tends to lack diversity, due to road maintenance activities, such as mowing and deicing. In urban areas where Project anchor institutions are located, corridor vegetation tends to be composed of non-native turfgrass and ornamental plant species. Utility ROW vegetation tends to be of somewhat higher quality but is still disturbed by regular utility maintenance activities. In many areas along the Project route, road and utility ROW’s traverse agricultural fields, and corridor vegetation is composed of crop plants like corn (Zea mays) and soybean (Glycine max) and old-field, agricultural weed species. Within landscape ecosystems adapted to fire as a natural disturbance, utility ROW maintenance may actually provide artificial disturbance that mimics fire, e.g. baring the soil surface for seed establishment and increasing light availability for shade intolerant plants via woody plant removal and mowing. In these areas, more conservative prairie, savanna, and oak-pine barren plant species may take refuge within utility corridors, as fire suppression and woody plant encroachment degrade their habitat in the surrounding landscape. Refer to Section 3.5.4 Threatened and Endangered Species and Critical Habitats for detailed information about rare plant species that may occur along the Project route.

3.5.4 Threatened and Endangered Species and Critical Habitat The NTIA sent coordination letters to the U.S. Fish and Wildlife Service (USFWS) Field Offices in East Lansing, Michigan, Green Bay, Wisconsin, and Bloomington (aka Twin Cities), Minnesota. Per USFWS guidance regarding Section 7 Consultation (USFWS 2009), the Project Team reviewed the federal lists of Threatened and Endangered (T&E) species and designated critical habitats for all 38 counties crossed by the Project (USFWS 2010). The Project route does not traverse any federally designated critical habitats for federally listed species in Wisconsin or Minnesota. However, one crossing of a federally designated critical habitat area is proposed in Michigan. The Northern Corridor of the Project route traverses Michigan Unit 1 for the federally endangered Hine’s emerald dragonfly ( Somatochlora hineana ) in Michigan’s Upper Peninsula north of the Mackinac Bridge and St. Ignace.

Preliminary shapefiles of the Project route through Michigan and Wisconsin were submitted to the Michigan Natural Features Inventory (MNFI) and WiDNR in September 2010 to provide the Project Team with preliminary data regarding the potential for threatened and endangered (T&E) species and critical habitats to occur within the area crossed by the proposed Project. These agencies provided information regarding known locations of T&E species and important natural communities that are mapped within 150 feet in Michigan and one mile in Wisconsin of the preliminary fiber optic cable route. No preliminary shapefiles were created for Minnesota due to the urban nature of the Project route in this location. This information was used to conduct windshield surveys of the proposed route to verify habitat conditions, refine the Project route, and initiate efforts to develop mitigation strategies where necessary.

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The Project Team provided the Michigan, Wisconsin, and Minnesota Departments of Natural Resources with finalized GIS shapefiles of the Project route through each state to initiate formal consultation on December 8, November 8, and November 8, 2010, respectively. Additional minor route changes were addressed via subsequent correspondence. Refer to Appendix F for agency correspondence.

3.5.4.1 Federal Threatened and Endangered Species Correspondence with each state natural resource agency, the Project Team’s review of federal species lists by county, and informal consultation with the East Lansing USFWS Field Office identified the following federally listed or otherwise federally protected or monitored species and one designated critical habitat area that may be affected by the proposed Project:

• Michigan (10 species and one designated critical habitat area): Snuffbox mussel ( Epioblasma triquetra ), Karner blue butterfly ( Lycaedes melissa samuelis ), Eastern massasauga rattlesnake ( Sistrurus catenatus catenatus ), Kirtland’s warbler ( Dendroica kirtandii ), Houghton’s goldenrod ( Solidago houghtenii ), Dwarf lake iris ( Iris lacustris ), Gray wolf (Canus lupis ), Hine’s emerald dragonfly ( Somatochlora hineana ), Hine’s emerald dragonfly critical habitat (Michigan Unit 1), Canada lynx ( Lynx canadensis ), and Bald eagle (Haliaeetus leucocephalus ).

• Wisconsin (nine species): Gray wolf, Canada lynx, Piping plover ( Charadrius melodus), Fassett’s locoweed (Oxytropis campestris var. chartacea ), Dwarf lake iris, Kirtland’s warbler, Whooping crane (Grus americanus ), Karner blue butterfly, and Bald eagle.

• Minnesota (three species): Gray wolf, Canada lynx, and Piping plover.

Summaries of each state natural resource agency's review for potential impacts to state listed T&E species are presented below.

3.5.4.2 Michigan Threatened and Endangered Species The Michigan Department of Natural Resources & Environment (MiDNRE) Wildlife Division checked the proposed Project route against known localities for federal and state listed rare species and unique natural features (aka element occurrences) which are recorded in a statewide database. This continuously updated database is a comprehensive source of information on Michigan's endangered, threatened, and special concern species, exemplary natural communities, and other unique natural features. Per the MiDNRE review letter and subsequent correspondence dated January 7 and January 31, 2011 and per informal consultation with the USFWS, the agencies identified six state-listed endangered species, 16 state-listed threatened species, 24 state-listed special concern species, six state natural communities, and one federally designated critical habitat for evaluation. Special concern species and exemplary natural communities are tracked in the MNFI database but are not legally protected by Michigan’s endangered species legislation. None of the proposed MI hut sites were associated with known element occurrences in the state database. In addition, MiDNRE and the Project Team identified 22 Protected Areas administered by the Michigan Department of Transportation (MDOT) where road ROWs may contain rare species and associated habitat. For a specific list of element occurrences in Michigan that have the potential to be impacted along the Project Route, please refer to Table 3.5.4.1 below. Refer to Appendix F for MiDNRE and MDOT correspondence.

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Table 3.5.4.1 Summary of Known Element Occurrences for Michigan

Federal State Species/Natural Community Project Corridor Status* Status** Snuffbox mussel ( Epioblasma triquetra ) C E Middle Kirtland’s Warbler ( Dendroica kirtlandii ) E E Middle Pugnose shiner ( Notropis anogenus ) N/A E Northeastern Hine's emerald dragonfly ( Somatochlora hineana ) E E Northern Canada lynx ( Lynx canadensis ) T E Northern Deep-throat vertigo snail ( Vertigo nylanderi ) N/A E Northern Wooded Dune & Swale Complex N/A N/A Northeastern, Northern Great Lakes Marsh N/A N/A Northeastern Critical Habitat for Hine's emerald dragonfly N/A N/A Northern Alvar/alkaline scrub-grassland N/A N/A Northern Muskeg/scrub bog N/A N/A Northern Bog N/A N/A Northern Mesic Northern Forest N/A N/A Northern Bald eagle ( Haliaeetus leucocephalus) N/A SC Middle, Northeastern, Northern Eastern massasauga rattlesnake ( Sistrurus catenatus C SC Middle, Northeastern catenatus ) Wood turtle ( Clemmys insculpta ) N/A SC Middle, Northeastern Blanding’s turtle ( Emydoidea blandingii ) N/A SC Middle, Northeastern Alleghany plum ( Prunus alleghaniensis var. davisii ) N/A SC Middle Hill’s thistle ( Cirsium hillii ) N/A SC Middle Dusted skipper ( Atrytonopsis hianna ) N/A SC Middle Red-legged spittlebug ( Prosapia ignipectus ) N/A SC Middle Grizzled skipper ( Pyrgus centaureae wyandot ) N/A SC Middle Boreal fen moth ( Brachionycha borealis ) N/A SC Middle Butterwort ( Pinguicula vulgaris ) N/A SC Northern Incurvate emerald dragonfly ( Somatochlora incurvata ) N/A SC Northern Sharp-tailed grouse ( Tympanuchus phasianellus ) N/A SC Northern Eastern flat-whorl snail ( Planogyra asteriscus ) N/A SC Northern Prairie dropseed ( Sporobolus heterolepis ) N/A SC Northern Mystery vertigo snail ( Vertigo paradoxa ) N/A SC Northern Tapered vertigo snail ( Vertigo elatior ) N/A SC Northern Rapids clubtail ( Gomphus quadricolor ) N/A SC Northern Riverine snaketail ( Stylurus amnicola ) N/A SC Northern Furrowed flax ( Linum sulcatum ) N/A SC Northern Frigga fritillary ( Boloria frigga ) N/A SC Northern Satiny willow ( Salix pellita ) N/A SC Northern Purple clematis N/A SC Northern Douglas’ hawthorn ( Crataegus douglasii ) N/A SC Northern Karner blue butterfly ( Lycaeides melissa samuelis ) E T Middle Persius dusky wing ( Erynnis persius persius ) N/A T Middle

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Federal State Species/Natural Community Project Corridor Status* Status** Rough fescue ( Festuca scabrella ) N/A T Middle Houghton's goldenrod ( Solidago houghtonii ) T T Middle, Northern Common tern ( Sterna hirundo ) N/A T Northeastern Dwarf lake iris ( Iris lacustris ) T T Northeastern Lake cress ( Armoracia lacustris ) N/A T Northeastern Gray wolf ( Canis lupus ) E T Northeastern, Northern Calypso ( Calypso bulbosa ) N/A T Northern Black crowberry ( Empetrum nigrum ) N/A T Northern Mat muhly ( Muhlenbergia richardsonis ) N/A T Northern Land snail ( Euconulus alderi ) N/A T Northern Sweet coltsfoot ( Petasites sagittatus ) N/A T Northern Smooth beardtongue ( Penstemon calycosus ) N/A T Northern Compass plant ( Silphium laciniatum ) N/A T Northern Pine-drops ( Pterospora andromedea ) N/A T Northern *C = federal candidate species, E = federally endangered species, T = federally threatened species **E = state endangered species, SC = state special concern species, T = state threatened species

3.5.4.3 Wisconsin Threatened and Endangered Species The Wisconsin Department of Natural Resources (WiDNR) Office of Energy checked a two-mile wide corridor on either side of the proposed Project route against known localities for federal and state listed rare species and unique natural features (aka element occurrences), which are recorded in a statewide database. This continuously updated database is a comprehensive source of information on Wisconsin's endangered, threatened, and special concern species, exemplary natural communities, and other unique natural features. Per the WiDNR review letter dated December 15, 2010 and informal consultation with USFWS, the agencies identified 14 state-listed endangered, 17 state-listed threatened, 67 state-listed special concern species and miscellaneous natural elements, and 13 natural communities for evaluation. Special concern species and exemplary natural communities are tracked in the Wisconsin Natural Heritage Inventory Database and are generally not legally protected by Wisconsin’s endangered species legislation. Notable exceptions include special concern species protected by federal designation, the Bald and Golden Eagle Act, and the Migratory Bird Act. None of the proposed hut sites were associated with known element occurrences in the state database, and WiDNR had no rare species concerns related to the hut locations. For a specific list of element occurrences in Wisconsin that have the potential to be impacted along the Project Route, please refer to Table 3.5.4.2 below. Refer to Appendix F for WiDNR correspondence.

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Table 3.5.4.2 Summary of Known Element Occurrences for Wisconsin

Federal State Species/Natural Community ¥ Project Corridor Status* Status** Lake-cress ( Armoracia lacustris ) N/A E Green Bay Spur Piping plover ( Charadrius melodus ) E E Green Bay Spur, Duluth Spur Red-necked grebe ( Podiceps grisegena ) N/A E Green Bay Spur Caspian tern ( Sterna caspia ) N/A E Green Bay Spur Common tern ( Sterna hirundo ) N/A E Green Bay Spur, Duluth Spur Swamp metalmark ( Calephelis muticum ) N/A E Green Bay Spur Forster's tern ( Sterna forsteri ) N/A E Green Bay Spur Peregrine falcon ( Falco peregrinus ) N/A E Green Bay Spur, Duluth Spur American marten ( Martes americana ) N/A E Northern Little goblin moonwort ( Botrychium mormo ) N/A E Duluth Spur Large-leaved sandwort ( Moehringia macrophylla ) N/A E Duluth Spur Small yellow water crowfoot ( Ranunculus gmelinii ) N/A E Duluth Spur Fassett’s locoweed (Oxytropis campestris var. chartacea ) T E Duluth Spur Slender spike-rush ( Eleocharis nitida ) N/A E Duluth Spur Alder Thicket N/A N/A Green Bay Spur Northern Wet-Mesic Forest N/A N/A Green Bay Spur Northern Dry Forest N/A N/A Green Bay Spur Great Lakes Beach N/A N/A Green Bay Spur Emergent Marsh N/A N/A Green Bay Spur, Duluth Spur Shrub-Carr N/A N/A Green Bay Spur Lake—deep, soft seepage N/A N/A Northern Bracken Grassland N/A N/A Northern Open Bog N/A N/A Duluth Spur Emergent Marsh-Wild Rice N/A N/A Duluth Spur Northern Wet Forest N/A N/A Duluth Spur Lake—Soft Bog N/A N/A Duluth Spur Hardwood Swamp N/A N/A Duluth Spur Indian cucumber root ( Medeola virginiana ) N/A SC Green Bay Spur Northern wild raisin ( Viburnum nudum var. cassinoides ) N/A SC Green Bay Spur Yellow screwstem ( Bartonia virginica ) N/A SC Green Bay Spur Crinkled hairgrass ( Deschampsia flexuosa ) N/A SC Green Bay Spur Weed shiner ( Notropis texanus ) N/A SC Green Bay Spur Four-toed salamander ( Hemidactylium scutatum ) N/A SC Green Bay Spur Pygmy shrew ( Sorex hoyi ) N/A SC Green Bay Spur American bullfrog ( Lithobates catesbeianus ) N/A SC Green Bay Spur Northern bog sedge ( Carex gynocrates ) N/A SC Green Bay Spur Blunt-lobe grape-fern (Botrychium oneidense ) N/A SC Green Bay Spur Male fern ( Dryopteris filix-mas ) N/A SC Green Bay Spur Mulberry wing ( Poanes massasoit ) N/A SC Green Bay Spur

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Federal State Species/Natural Community ¥ Project Corridor Status* Status** Broad-winged skipper ( Poanes viator ) N/A SC Green Bay Spur Elktoe ( Alasmidonta marginata ) N/A SC Northern Leonard's skipper ( Hesperia leonardus ) N/A SC Northern White adder's -mouth ( Malaxis monophyllos var. N/A SC Duluth Spur brachypoda ) Oregon woodsia (tetraploid; Woodsia oregana ssp. N/A SC Duluth Spur cathcartiana ) Pale sedge ( Carex pallescens ) N/A SC Duluth Spur Lepidostomatid caddisfly ( Lepidostoma libum ) N/A SC Duluth Spur Large roundleaf orchid ( Platanthera ororbiculata ) N/A SC Duluth Spur Northern black currant ( Ribes hudsonianum ) N/A SC Duluth Spur Marsh willow-herb ( Epilobium palustre) N/A SC Duluth Spur Assiniboine sedge ( Carex assiniboinensis ) N/A SC Duluth Spur Predaceous diving beetle ( Hydroporus vittatus ) N/A SC Duluth Spur Wild licorice ( Glycyrrhiza lepidota ) N/A SC Duluth Spur Large-flowered ground-cherry ( Leucophysalis grandiflora ) N/A SC Duluth Spur Northern yellow lady's -slipper ( Cypripedium parviflorum N/A SC Duluth Spur var. makasin) Aurora damselfly ( Chromagrion conditum ) N/A SC Duluth Spur Bog fritillary ( Boloria eunomia ) N/A SC Duluth Spur Tiger beetle ( Cicindela longilabris ) N/A SC Duluth Spur Tiger beetle ( Cicindela patruela patruela ) N/A SC Duluth Spur Eastern elliptio ( Elliptio complanata ) N/A SC Duluth Spur Migratory Bird Sites N/A SC Duluth Spur Wetland Bird Rookeries N/A SC Duluth Spur Purple clematis (Clematis occidentalis ) N/A SC Duluth Spur Laurentian bladder fern ( Cystopteris laurentiana ) N/A SC Duluth Spur Fragrant fern ( Dryopteris fragrans var. remotiuscula ) N/A SC Duluth Spur Marsh horsetail ( Equisetum palustre ) N/A SC Duluth Spur Alpine cotton-grass ( Eriophorum alpinum ) N/A SC Duluth Spur Large -leaved avens ( Geum macrophyllum var. N/A SC Duluth Spur macrophyllum ) Fir clubmoss ( Huperzia selago ) N/A SC Duluth Spur Vasey rush ( Juncus vaseyi ) N/A SC Duluth Spur Adder's-tongue ( Ophioglossum pusillum ) N/A SC Duluth Spur Large Roundleaf Orchid ( Platanthera orbiculata ) N/A SC Duluth Spur Brown beakrush ( Rhynchospora fusca ) N/A SC Duluth Spur Georgia bulrush ( Scirpus georgianus ) N/A SC Duluth Spur Marsh ragwort ( Senecio congestus ) N/A SC Duluth Spur Veined meadowrue ( Thalictrum venulosum ) N/A SC Duluth Spur Common bog arrow-grass ( Triglochin maritime ) N/A SC Duluth Spur American eel ( Anguilla rostrata ) N/A SC Duluth Spur Gray wolf ( Canis lupus ) E SC/FL Green Bay Spur, Northern, Duluth Spur

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Federal State Species/Natural Community ¥ Project Corridor Status* Status** Kirtland’s Warbler ( Dendroica kirtlandii ) E SC/FL Green Bay Spur, Duluth Spur Whooping crane ( Grus americana ) NEP SC/FL Green Bay Spur Karner blue butterfly ( Lycaeides melissa samuelis ) E SC/FL Green Bay Spur Osprey ( Pandion haliaetus ) N/A SC/M Green Bay Spur Black-crowned night-heron ( Nycticorax nycticorax ) N/A SC/M Green Bay Spur Common moorhen ( Gallinula chloropus ) N/A SC/M Green Bay Spur Upland sandpiper ( Bartramia longicauda ) N/A SC/M Northern, Duluth Spur Cape may warbler ( Dendroica tigrina ) N/A SC/M Duluth Spur American bittern ( Botaurus lentiginosus ) N/A SC/M Duluth Spur Black tern ( Chlidonias niger ) N/A SC/M Duluth Spur Western meadowlark ( Sturnella neglecta ) N/A SC/M Duluth Spur Dickcissel ( Spiza americana ) N/A SC/M Duluth Spur Northern goshawk ( Accipiter gentilis ) N/A SC/M Duluth Spur Canada warbler ( Wilsonia canadensis ) N/A SC/M Duluth Spur Bald eagle ( Haliaeetus leucocephalus ) N/A SC/P Green Bay Spur, Northern, Duluth Spur Canada lynx ( Lynx canadensis ) T SC/P Green Bay Spur, Northern, Duluth Spur Blanding's turtle ( Emydoidea blandingii ) N/A T Green Bay Spur Pygmy snaketail ( Ophiogomphus howei ) SOC T Green Bay Spur Greater redhorse ( Moxostoma valenciennesi ) N/A T Green Bay Spur Redfin shiner ( Lythrurus umbratilis ) N/A T Green Bay Spur Wood turtle ( Glyptemys insculpta ) N/A T Green Bay Spur, Northern, Duluth Spur Slippershell mussel ( Alasmidonta viridis ) N/A T Green Bay Spur Seaside crowfoot ( Ranunculus cymbalaria ) N/A T Green Bay Spur, Duluth Spur Pale green orchid ( Platanthera flava var. herbiola ) N/A T Green Bay Spur Longear sunfish ( Lepomis megalotis ) N/A T Green Bay Spur Dwarf lake iris ( Iris lacustris ) T T Green Bay Spur Braun's holly-fern ( Polystichum braunii ) N/A T Duluth Spur Black-throated blue warbler ( Dendroica caerulescens ) N/A T Duluth Spur Round-leaved orchis ( Amerorchis rotundifolia ) N/A T Duluth Spur Arrow-leaved sweet-coltsfoot ( Petasites sagittatus ) N/A T Duluth Spur Canada gooseberry ( Ribes oxyacanthoides ) N/A T Duluth Spur Northern bur-reed ( Sparganium glomeratum ) N/A T Duluth Spur Spruce grouse ( Falcipennis canadensis ) N/A T Duluth Spur ¥ Important Note: The specific locations and identities of endangered resources included in the Wisconsin Endangered Resources Review are 1) sensitive, 2) not subject to Wisconsin’s Open Records Law, and 3) may not be released or reproduced in any publicly disseminated document. Therefore, if NTIA deems that this document must become public, any reference to a specific species, natural community, or other natural featured derived from the Wisconsin Natural Heritage Inventory Database within the document’s text and agency correspondence must be redacted. *C = federal candidate species, E = federally endangered species, SOC = federal species of concern, T = federally threatened species, NEP = Non-essential Experimental Population **E = state endangered species, SC = state special concern species, SC/FL = federally protected as endangered or threatened, but state special concern, SC/M = fully protected by federal & state laws under the Migratory Bird Act, SC/P = fully protected state special concern, T = state threatened species

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3.5.4.4 Minnesota Threatened and Endangered Species The Minnesota Department of Natural Resources (MnDNR) checked the proposed Project route against known localities for federal and state listed rare species and unique natural features (aka element occurrences), which are recorded in a statewide database. This continuously updated database is a comprehensive source of information on Minnesota's endangered, threatened, and special concern species, exemplary natural communities, and other unique natural features. Per the MnDNR review letter dated January 12, 2011, 24 element occurrences, including several species of fish, shore birds, and vascular plants, are known to occur within one mile of the Project route in Minnesota. Initially, based on the description of the Project and its location within the highly disturbed area within the City of Duluth, the MnDNR concluded that none of these element occurrences would be negatively affected by the proposed Project and that further analysis of impacts was not necessary. In a letter dated February 28, 2011, following additional correspondence relating to route location and construction methods associated with crossing St. Louis Bay, MnDNR ultimately requested analysis of potential impacts to two state-threatened bird species, Peregrine falcon (Falco peregrinus ) and Common tern ( Sterna hirundo ), known to nest on the Blatnik Bridge or on Interstate Island west of the Bridge, respectively. For a specific list of element occurrences in Minnesota that have the potential to be impacted along the Project Route, please refer to Table 3.5.4.3 below. Refer to Appendix F for MnDNR correspondence and a complete list of element occurrences within one mile of the Project route, including federally and state listed species and unique natural features. Important Note : The information provided in the correspondence from the MnDNR may include specific location information that is considered non-public data under Minnesota Statutes Section 84.0872 subd. 2. Written permission is required to reprint or publish the data.

Table 3.5.4.3 Summary of Known Element Occurrences for Minnesota

Federa l State Species/Natural Community Project Corridor Status* Status** Peregrine falcon ( Falco peregrinus ) N/A T Duluth Spur Common tern ( Sterna hirundo ) N/A T Duluth Spur Piping plover ( Charadrius melodus ) E E Duluth Spur Not noted in Gray wolf ( Canis lupus ) T Duluth Spur MnDNR review Not noted in Canada lynx ( Lynx canadensis ) T Duluth Spur MnDNR review *E = federally endangered species, T = federally threatened species **E = state endangered species, T = state threatened species

3.5.5 Wetland Habitat All of the wetland habitats encountered along the Project route have experienced some type of past disturbance, as they are all located within existing road and/or utility ROW’s. Many of these wetlands likely extend beyond the proposed area of temporary disturbance. These ROW’s are regularly maintained. Although wetland maps indicate aquatic, emergent, scrub-shrub, and forested wetland types occurring along the Project route, wetland vegetation that does occur within the ROWs tends to be herbaceous due to frequent maintenance activities such as mowing and clearing. Road ROW wetlands tend to provide wildlife habitat of only marginal quality, due to limited vegetation diversity and vehicular traffic. Utility ROW wetland habitats tend to be of higher quality but are still disturbed by regular utility maintenance activities. No new disturbance to wetlands beyond the current ROW maintenance activities will occur due to this Project. For a detailed description of wetlands encountered along the Project route, refer to the above Section 3.4.3 Wetlands. No telecommunication huts are proposed wetlands.

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3.6 HISTORIC AND CULTURAL RESOURCES

Per Section 106 of National Historic Preservation Act, NTIA initiated consultation with the State Historic Preservation Offices (SHPO) in Michigan, Wisconsin and Minnesota via mail and with the Tribal Historic Preservation Officers (THPO) via posting the Project on the nationwide Indian Tribal Tower Construction Notification System (TCNS). The following subsections summarize the Project Team's follow-up correspondence with SHPO and THPO.

3.6.1 Archaeological Resources The Project Team conducted a pre-application meeting with Michigan SHPO (MiSHPO) on April 23, 2010 to discuss Round One of the REACH 3 MC Project. At that meeting, SHPO representatives indicated that use of existing road ROW’s would likely limit impacts to cultural resource sites due to extensive grading to construct the road and installation of other utilities within the ROW. When contacted to initiate consultation on Round Two of the Project, MiSHPO staff indicated that a second pre-application would not be necessary since the projects are so similar.

The Project Team submitted an application package for Section 106 review of the Round 2 project to the Michigan SHPO on December 22, 2010. The package included the Project superimposed on topographic maps showing the locations of known archaeological sites. Subsequent correspondence on February 12, March 29, and June 30, 2011 provided further clarification on Project alternatives and construction methods. Refer to Appendix F for agency correspondence.

A report documenting the results of a Phase I literature search was submitted to the Wisconsin SHPO on November 10, 2010. The Area of Potential Effects (APE) for direct effects included the existing roadways within which the proposed fiber optic line will be installed and a 500 foot buffer on either side of the roadway centerline. In areas designated as Urban, the APE for archaeological resources is 2,500 feet on either side of the proposed route to allow for greater flexibility in the location of the final alignment. The APE for the three proposed telecommunications hut sites is 500 feet. One site listed in the National Register of Historic Places was identified in the literature search; the Oconto site (47OC0045 / BOC0046) occurs within the APE of the Green Bay Spur. In addition, 4 catalogued burial sites and 19 uncatalogued burial sites were identified within the APE for the Project. No archaeological resources were identified within the APE of the telecommunications huts.

The Project Team submitted detailed information regarding the proposed Project location and construction methods in Minnesota to the Minnesota SHPO on December 7, 2010. The entire Project in Minnesota is located within existing road and utility ROW’s in the industrial and urban area of Duluth. Adverse impacts to archaeological resources are highly unlikely due to the extensive amount of disturbance associated with this development.

3.6.2 Architectural Resources The Project Team reviewed the Michigan Sites Online website (Michigan SHDA, 2009) to identify any sites that are listed in the National Register of Historic Places or the State Register of Historic Sites that may be affected by the proposed Project. Approximately 135 sites are located within one mile of the proposed Project in Michigan.

Consultation with the Division of Historic Preservation, Wisconsin Historical Society confirmed that since the fiber optic line will be constructed underground or attached to existing utility poles, there will be no affect to above-ground historic properties located within the visual APE of the project. Therefore, potential architectural resources eligible for the National Register of Historic Places were not identified in Wisconsin as part of the Literature Review for the Project.

No architectural resources listed in or eligible for listing in the national Register of Historic Places that would potentially be affected by the proposed Project were identified in Minnesota.

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3.6.3 Native Resources The NTIA initiated contact with Tribal Nations with a potential interest in the proposed Project through its Tower Construction Notification System (TCNS). Three Tribes, the Shawnee Tribe, Miami Tribe of Oklahoma, and Wyandotte Nation requested additional information about the Project after being notified through the TCNS. Merit also reviewed the list of Tribes that automatically request additional project information through their participation in TCNS. Twelve additional tribes were provided project descriptions and maps of the proposed Project. In addition, Merit contacted the Lac Vieux Desert Band (LVD Band) of Lake Superior Chippewa Indians (Ketegitigaaning) to discuss the Project. The Project Team had consulted with the LVD Band during Round One of the REACH 3MC project and initiated consultation for Round Two. The submittals that were provided to the Michigan and Wisconsin SHPOs and a map of the Project route within Duluth, Minnesota were provided to the LVD Band on January 10, 2011.

Refer to Appendix F for details regarding correspondence with Tribal Nations.

Approximately 16.5 miles of the Project route traverses the Bad River Band of Lake Superior Tribe of Chippewa Indian (Bad River Band) Reservation in Ashland County, Wisconsin. The Project Team met with representatives of the Bad River Band on January 5 and March 22 to discuss the proposed Project and identify a project route that minimizes potential impacts to cultural and natural resources within the Reservation.. Discussion focused on the Project route along U.S. 2, which bisects a significant burial site on the west side of the Bad River. Merit agreed to revise the Project route in this area to avoid the burial site; the revised route is shown on all maps within this document. Figure 3.6.3.1 shows the proposed fiber optic route through the Reservation in detail. A permit from the Bad River Band is needed to cross wetlands and watercourses within the Reservation.

Refer to Appendix F for meeting minutes and correspondence

No telecommunication huts are proposed on tribal land.

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Figure 3.6.3.1 Proposed Route Across Bad River Indian Reservation

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3.7 AESTHETIC AND VISUAL RESOURCES

The aesthetic and visual resources that occur where the Project is proposed can be divided into two areas; the agriculture-dominated landscape of southern Lower Michigan and eastern Wisconsin; and, the forest-dominated landscape of northern Lower Michigan, Michigan’s Upper Peninsula, and northern Wisconsin. These are described in more detail below.

The Middle Corridor in Kent, Montcalm, Mecosta Counties, and the Green Bay Spur in Marinette, Oconto and Brown Counties in Wisconsin cross landscapes that are generally characterized by a predominance of active crop land interspersed with natural areas such as deciduous woodlands, wetlands and riparian corridors. Development tends to be concentrated in the larger cities of Grand Rapids and Green Bay and smaller cities and towns. The landscape crossed by the remainder of the Project is much more rural and forested in character. Forests transition from predominantly deciduous woodlands in northern Michigan to coniferous forests in the Upper Peninsula and northern Wisconsin. Agricultural areas are more limited in extent and include more active pasture than is found in the southern parts of the Project area. Large cities include Superior, Wisconsin and Duluth, Minnesota. The visual character of this part of the Project is enhanced by views to Lake Huron and Lake Michigan, most notably along US- 23 and US-2 respectively. Long-distance views of Lake Superior are available from US-2 in Wisconsin with close views of the lake available in Ashland, Superior and Duluth.

The Project route crosses lands within the Huron, Hiawatha, Ottawa and Chequamegon National Forests. The Forest Plans for each of these National Forests establish Scenic Integrity Objectives (Chequamegon and Huron National Forests) or Visual Quality Objectives (Ottawa and Hiawatha National Forests) to guide visual resource management. In general, the road corridors where the Project is proposed in National Forests are considered to be important considerations in the Forest Plans due to the fact that the majority of Forest users travel these roads and their recreational experiences are strongly influenced by their view from these roads. Aerial installation is proposed in locations where existing utility poles are suitable for attaching the fiber optic cable and underground installation is proposed in road ROW’s where suitable utility poles do not exist.

In Huron National Forest, the Middle Corridor follows the Natural Scenic Byway River Road from Long Lake Rd. to Oscoda in Iosco County (MDOT 2010 State Map) and consists of 4.3 miles of aerial fiber and 22.3 miles of underground installation.

Refer to Section 3.8 for additional discussion of National Forest lands.

3.8 LAND USE

Existing land uses within the 1,263 mile Project corridor are relatively uniform, as ROW’s serve as areas for regular road and utility maintenance. Land cover within the Project corridor ranges from disturbed and highly-maintained vegetation and hard surface infrastructure in road ROW’s in highly urbanized areas to agricultural land, abandoned pasture, and disturbed wetland, and upland grassland with unpaved vehicle access in utility ROW’s. Beyond the Project corridor, adjacent land uses include commercial, industrial, institutional, high to low density single residential and multifamily residential, agricultural, forest land and orchard/vineyard/nursery (MiGDL 2001, WiDNR 2010d, MiDNRE 2010c). Appendix K illustrates existing land use and cover along the Project route.

The eleven proposed telecommunication huts are located on disturbed land within developed areas. Five huts will be located on properties associated with schools or colleges, three are located on municipal sites, one is co-located with an existing telecommunications hut, one is on a storage facility lot, and one is located on vacant commercial land.

Public Lands : The Project route crosses ROW’s on public lands along all three Corridors and five Spurs. In Michigan, the Project crosses three National Forests, seven State parks, one State Game Area, one Research Area, seven State Forests, and one State Fish Hatchery. In Wisconsin, the Project crosses one National Forest, one State

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Natural Area, one State Wildlife Area, one State Forest, and three County Forests. (MiGDL 2002e, WiDNR 2010d, MiDNRE 2010c). No public land crossings were identified in Minnesota. Table 3.8.1 summarizes public land crossings by corridor, location, and crossing type. Table 3.8.2 summarizes the existing land uses at each of the proposed hut locations. Appendix L shows the locations of public land crossings along the Project route.

The Huron, Hiawatha, Ottawa, and Chequamegon National Forests are administered by the U.S. Forest Service. The Project Team has been coordinating with staff from the National Forests on Special Use Permits (SUP) which will be needed to cross lands within the National Forests. Each Forest will issue individual SUP’s instead of developing a Regional SUP to include all four National Forests.

Specific areas that will be addressed during the SUP application review process include measures to limit the spread of invasive plant species, alternatives to aerial construction where proposed, BMP’s for wetland and waterway crossings, and protective measures for cultural resource sites and rare plant and animal species. Forest Service staff has informally indicated that they do not foresee any potential issues that cannot be addressed during the SUP application review process, since the Project will be located within existing road and utility ROW’s for its entire length across National Forest lands. Refer to Table 3.8.3 for a summary of National Forest crossings and Appendix F for agency correspondence.

No telecommunication huts are proposed on public land, including National Forest land (not including the school and municipal sites noted above).

Tribal Lands : The Project crosses the Bad River Band of Lake Superior Tribe of Chippewa Indians Reservation, which is located on a 125,000+ acres in Northern Wisconsin on the south shore of Lake Superior in Ashland and Iron Counties. The Project Team and NTIA have been coordinating with the Band River Band regarding the Project and cultural and natural resources along the proposed fiber optic route. Refer to 3.6.3 for further discussion. No telecommunication huts are proposed on tribal land.

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Table 3.8.1 Summary of Public Land Crossings

CORRIDOR COUNTIES LAND NAME LAND TYPE CROSSING TYPES MICHIGAN Iosco, Ogemaw, Huron National Forest National Forest Underground Kent Rouge River State Game Area State Game Area Underground Underground, Aerial, Mecosta, Osceola, Wexford, White Pine Trail State Park State Park Middle Corridor Backbone Conduit Missaukee, Roscommon Houghton Lake Research Area State Wildlife Research Area Aerial Ogemaw, Osceola Unnamed State of Michigan Aerial, Conduit Roscommon Au Sable State Forest State Forest Aerial Crawford, Ogemaw, Oscoda Huron National Forest National Forest Aerial Crawford, Ogemaw Au Sable State Forest State Forest Aerial Rose City to Kalkaska Spur Kalkaska Pere Marquette State Forest State Forest Underground Alcona Huron National Forest National Forest Aerial Grayling Higgins Lake Spur Crawford Au Sable State Forest State Forest Aerial Grayling Lovells Spur Crawford Hartwick Pines State Park State Park Underground, Aerial Alcona, Alpena, Cheboygan, Iosco, Presque Isle Unnamed State of Michigan Underground, Aerial Alcona Harrisville State Park State Park Aerial Northeastern Corridor Backbone Alpena, Cheboygan, Presque Isle Mackinaw State Forest State Forest Underground, Aerial Cheboygan Old Mill Historic Park State Park Aerial Iosco Au Sable State Forest State Forest Aerial Chippewa, Delta, Mackinac, Schoolcraft Hiawatha National Forest National Forest Underground, Aerial Chippewa, Delta, Mackinac, Schoolcraft Lake Superior State Forest State Forest Underground, Aerial Chippewa, Delta, Mackinac, Schoolcraft Lake Superior State Forest State Forest Underground, Aerial Chippewa, Delta, Dickinson, Gogebic, Iron, Unnamed State of Michigan Underground, Aerial Mackinac, Schoolcraft Northern Corridor Backbone Gogeb ic, Iron Ottawa National Forest National Forest Underground Iron Copper Country State Forest State Forest Underground Iron Bewabic State Park State Park Aerial Mackinac Straits State Park State Park Aerial Schoolcraft Thompson State Fish Hatchery State Fish Hatchery Aerial Schoolcraft Indian Lake State Park - W. Unit State Park Aerial

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CORRIDOR COUNTIES LAND NAME LAND TYPE CROSSING TYPES MICHIGAN Gogebic, Ontonagon Ottawa National Forest National Forest Underground Watersmeet to Houghton Spur Gogebic, Houghton, Ontonagon Unnamed State of Michigan Aerial, Urban Houghton, Ontonagon Copper Country State Forest State Forest Underground Rockland to Ontonagon Spur Ontonagon Unnamed State of Michigan Unknown WISCONSIN Northern Corridor Backbone Florence Spread Eagle Barren Natural Area Wisconsin DNR Underground Green Bay West Shores Wildlife Brown Wisconsin DNR Underground Green Bay Spur Area Oconto County Forest Oconto County Aerial Bayfield County Forest Bayfield County Underground Bayfield, Douglas Brule River State Forest Wisconsin DNR Underground, Aerial Duluth Spur Bayfield, Ashland, Iron County Forest Bayfield County Aerial Bayfield Chequamegon National Forest USDA Forest Service Underground

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Table 3.8.2 Summary of Existing Land Uses at Hut Locations

HUT NAME CORRIDOR STATE COUNTY TOWNSHIP RANGE SECTION EXISTING LAND USE MICHIGAN Engadine Northern – Backbone MI Mackinac T43N R10W S16 School Manistique Northern – Backbone MI Schoolcraft T41N R17W S31 Commercial Storage Facility Escanaba Northern – Backbone MI Delta T39N R23W S13 Bay College Powers Northern – Green Bay Spur MI Menominee T38N R26W S16 School Iron Mountain Northern – Backbone MI Dickinson T40N R30W S20 Bay College Crystal Falls Northern – Backbone MI Iron T43N R32W S30 Existing Telecommunications Hut Northern – Watersmeet to Watersmeet MI Gogebic T45N R39W S27 Township Hall Houghton Spur Wakefield Northern – Backbone MI Gogebic T47N R45W S7 Vacant Commercial WISCONSIN Marinette Northern – Green Bay Spur WI Marinette T30N R23E S11 City Water Tower Ashland Northern – Duluth Spur WI Ashland T47N R5W S10 Bayfield County Agricultural Center Poplar Northern – Duluth Spur WI Douglas T47N R11W S4 School

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Table 3.8.3 Summary of National Forest Crossings

AERI AL UNDERGROUND CONSTRUCTION CONSTRUCTION TOTAL (MILES) (MILES) CHEQUAMEGON NF Duluth Spur 0 4.25 4.25 OTTAWA NF Northern Corridor Backbone 0.40 34.74 35.14 Watersmeet-Houghton Spur 0 10.14 10.14 HIAWATHA NF Northern Corridor Backbone 5.65 18.09 23.74 HURON NF Middle Corridor Backbone 1.19 18.06 19.25 Rose City-Kalkaska Spur 3.88 14.50 18.38 Northeast Corridor Backbone 1.53 0.10 1.63 12.65 99.88 112.53 GRAND TOTAL (11.2%) (88.8%) (100%)

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3.9 INFRASTRUCTURE

The existing road and utility ROW’s where the Project is proposed supports a variety of infrastructure including paved limited access highways, state trunklines and local roads, railroads, and utilities such as electric transmission and distribution lines, oil and natural gas transmission and distribution lines, water, sanitary sewer, storm sewer, and telecommunications lines. Installation of the proposed fiber optic system will require coordination with State Highway Departments, local road departments and commissions, and local and regional utility companies.

3.10 SOCIOECONOMIC RESOURCES

The multi-sector partnerships that are part of the Project includes entities that provide last mile service, as well as entities that provide middle mile service. That means the Project would bring competition to the proposed service area, where affordable, high-performance broadband has been lacking for so long. The Project would keep the cost of service low, while significantly improving the quality of service available. Every sector of society stands to benefit from lower prices and better service.

The proposed route would follow existing utility lines regardless of minority status, demographics, and income status of the populations the broadband service is intended to serve. The route would serve some of the lowest per capita counties in Michigan, as well as some of the more prosperous areas. Table 3.10.1 summarizes vulnerable population data per the 2000 Census by county.

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Table 3.10.1 Summary of Vulnerable Population Data per 2000 Census (USDA Economic Research Service Database)

Individuals African American Hispanic or Asian Below the Americans Indians Latino Total Poverty Level Geography population Number % Number % Number % Number % Number %

Michigan 9,938,444.00 1,412,742.00 14% 58,479 1% 176,510 2% 323,877 3% 1,453 13% Alcona 11,719 19 <1% 73 1% 21 <1% 81 1% 3,278 11% Alpena 31,314 77 <1% 123 <1% 103 <1% 181 1% 3,187 12% Cheboygan 26,448 65 <1% 674 3% 52 <1% 202 1% 4,167 13% Chippewa 38,543 2,127 1% 5,131 13% 177 <1% 599 2% 1,756 13% Crawford 14,273 214 1% 85 1% 36 <1% 142 1% 3,594 9% Delta 38,520 36 <1% 850 2% 121 <1% 187 <1% 2,452 9% Dickinson 27,472 32 <1% 142 1% 109 <1% 187 1% 2,266 7% Gogebic 17,370 305 2% 382 2% 40 <1% 153 1% 5,563 17% Houghton 36,016 339 1% 194 1% 646 2% 251 1% 3,398 13% Iosco 27,339 111 <1% 181 1% 126 <1% 269 1% 1,419 11% Iron 13,138 144 1% 134 1% 26 <1% 84 1% 1,708 10% Kalkaska 16,571 35 <1% 129 1% 37 <1% 142 1% 49,832 9% Kent 574,335 51,287 9% 2,999 1% 10,667 2% 40,183 7% 2,072 19% Lake 11,333 1,266 11% 114 1% 17 <1% 191 2% 1,235 10% Mackinac 11,943 24 <1% 1,697 14% 37 <1% 107 1% 5,960 16% Mecosta 40,553 1,460 4% 261 1% 354 1% 520 1% 2,855 11% Menominee 25,326 25 <1% 576 2% 54 <1% 190 1% 1,021,605 11% Missaukee 14,478 29 <1% 72 <1% 35 <1% 169 1% 1,529 11% Montcalm 61,266 1,330 2% 366 1% 159 <1% 1,394 2% 6,394 11% Montmorency 10,315 25 <1% 37 <1% 10 <1% 67 1% 1,307 13% Ogemaw 21,645 29 <1% 129 1% 82 <1% 252 1% 2,983 14% Ontonagon 7,818 2 <1% 75 1% 14 <1% 58 1% 796 10% Osceola 23,197 81 <1% 116 1% 50 <1% 230 1% 2,908 13% Oscoda 9,418 8 <1% 67 1% 7 <1% 89 1% 1,365 15% Otsego 23,301 42 <1% 145 1% 79 <1% 175 1% 1,563 7% Presque Isle 14,411 38 <1% 85 1% 23 <1% 79 1% 1,469 10% Roscommon 25,469 82 <1% 162 1% 49 <1% 204 1% 3,107 12% Schoolcraft 8,903 145 2% 545 6% 37 <1% 83 1% 1,036 12% Wexford 30,484 57 <1% 225 <1% 127 <1% 307 1% 3,096 10% Environmental Justice Population, e.g. County % > Total % in the State

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Table 3.10.1 Summary of Vulnerable Population Data per 2000 Census (USDA Economic Research Service Database) continued… Individuals African American Hispanic or Asian Below the Americans Indians Latino Total Poverty Level Geography population Number % Number % Number % Number % Number %

Minnesota 4,919,479 171,731 3% 54,967 1% 141,968 3% 143,382 3% 380,476 8% St. Louis 200,528 1,704 1% 4,074 2% 1,333 1% 1,597 1% 23,211 12%

Wisconsin 5,363,675 304,460 6% 47,228 1% 88,763 2% 192,921 4% 451,538 9% Ashland 16,866 36 <1% 1,745 10% 53 <1% 188 1% 1,920 12% Bayfield 15,013 20 <1% 1,409 9% 41 <1% 91 1% 1,861 13% Brown 226,778 2,641 1% 5,191 2% 4,935 2% 8,698 4% 15,123 7% Douglas 43,287 246 1% 786 2% 273 1% 315 1% 4,605 11% Florence 5,088 8 <1% 22 <1% 14 <1% 23 <1% 457 9% Iron 6,861 6 <1% 41 1% 9 <1% 45 1% 749 11% Marinette 43,384 100 <1% 215 <1% 119 <1% 325 1% 3,503 8% Oconto 35,634 48 <1% 277 1% 72 <1% 240 1% 2,497 7% Environmental Justice Population, e.g. County % > Total % in the State

3.11 HUMAN HEALTH AND SAFETY

3.11.1 Public and Worker Safety

Public and worker safety along road and utility ROW’s will be an important component of the Project. The Project will comply with local, state, and federal traffic control and safety regulations including applicable occupational Health and Safety Administration (OSHA) and State Highway Department regulations. Furthermore, the Project will adhere to the safety requirements and Standard Operating Procedures of the utility companies that own the poles where the fiber optic cable will be attached.

3.11.2 Brownfields In an effort to identify the need to research potential brownfield sites and sites of known contamination, the Project Team first considered the method of underground utility installation and, therefore, the relative risk to workers, the environment, and public health and safety. The risk associated with the installation method would involve the potential to exacerbate existing contamination or exposure to contaminants during installation.

Aerial installation would typically not result in soil disturbance thereby minimizing the potential to exacerbate existing contamination or exposure to contaminants during installation. There are three installation methods for the underground portion of the new utility that will be employed as part of this process:

• Placement of the utility in existing underground conduit. Apart from a small ingress and egress excavation at each end of the conduit, no other impact can be expected from this method of installation. Additionally, the ingress and egress locations have already been excavated during the original installation of the conduit and are therefore considered to be located either in clean native material or excavation at each end of the installation in order to join the utility segments. Therefore, the risk associated with this method is not

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considered to be significant. • Installation of the utility by directional boring. Typically this method employs a small excavation that is used to access the appropriate installation depth and to allow for joining of two sections of the utility. This method does not significantly disturb the subsurface soil and any soil removed at the excavation point is returned to its original location upon completion of the boring. Therefore, the risk associated with this method is not considered to be significant. • Installation of the utility by plowing. Plowing is a common method for the installation of small utilities and involves a blade that extends into the ground approximately four feet to which the conduit is attached. This assembly is then dragged behind a tractor and cuts its way through the soil. This method does not generate any soil and does not create a lasting disturbance in the surface soil once the blade has passed. This method also employs a small excavation at each end of the installation in order to join the utility segments. Therefore, the risk associated with this method is not considered to be significant.

In addition to fiber optic lines, the Project will involve the placement of 11 - 10’ x 20’ telecommunication huts; eight in Michigan’s Upper Peninsula and three in Wisconsin. The 10’ x 20’ pre-fabricated huts will be placed on concrete slabs. Other site improvements include a 20-foot wide access driveway to service each hut and one utility pole for electrical power. While the amount of disturbance will be limited to the minimum needed to place the hut and driveway, an area as large as 80’ x 80’ may be cleared and graded to accommodate each hut. A Phase I Environmental Site Assessment will be conducted on each hut site prior to purchasing rights to construct the huts. Given that the huts are pre-fabricated and that the foundation is slab-on-grade, the likelihood that contaminated soil will be encountered is minimal due to the shallow intrusion of the subsurface. In the event that contaminated soil is encountered, the soil will either be returned to its original location or located under the slab foundation. If soil cannot be handled in this manner and must be removed from the site, the soil will be characterized for appropriate disposal in a licensed landfill.

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4.0 CHAPTER 4 – ANALYSIS OF ENVIRONMENTAL IMPACTS

4.1 NOISE

Neither the hanging of new fiber-optic cable from existing utility poles, underground installation of new fiber-optic cable, the operation of that cable to provide data transmission within existing road and utility rights-of-way (ROW’s), nor the placement of huts would create any new long-term sources of noise. Noise associated with the construction phase of the Project would be temporary and comparable to that associated with regular maintenance activities along the existing ROWs. Therefore, this Project would not have any adverse impact on ambient noise levels.

The No Action Alternative would have no adverse impact on ambient noise levels.

4.2 AIR QUALITY

The Preferred Alternative would result in the release of approximately 36 metric tons of equivalent of CO2 emissions. There would be 0 emissions for the No Action alternative. The Council on Environmental Quality (CEQ) has issued draft guidance on when and how federal agencies should consider GHG emissions and climate change in NEPA. The draft guidance includes a presumptive effects threshold of 25,000 metric tons of CO2 equivalent emissions from an action (CEQ, 2010). The GHG emissions associated with the Preferred Alternative are well below the CEQ threshold. Therefore, GHG emissions from the Preferred Alternative would not contribute appreciably to climate change or global warming.

The No Action Alternative would have no adverse impact on air quality.

4.3 GEOLOGY AND SOILS

Glacial deposits and subsequently formed soils are sufficiently deep over the entire Project route to make blasting of bedrock unnecessary. Underground installation of fiber infrastructure via plowing and directional boring and pole replacement will involve only temporary disturbance of soil in a relatively limited area during the construction phase of the Project. All areas with disturbed soil will be returned to their pre-construction grades and stabilized. The Project does not involve the conversion of farmland to other uses, as the entire proposed fiber infrastructure route is contained within existing road and utility ROW’s with connection points located in disturbed areas already in urban development. Therefore, this Project would not have any adverse impact on prime or unique farmlands, and this resource area will not be analyzed further in this document.

Areas of ground disturbance associated with the placement of huts, pole replacement, plowing, and directional boring during the construction phase of the Project would be limited in size and returned to their pre-construction grades and stabilized following construction completion. The need for local and/or state soil erosion and sedimentation control (SESC) permits will be investigated. SESC permits will be acquired from the applicable local and/or state agencies, and SESC permit requirements will be adhered to throughout the construction of the Project. Therefore, potential adverse impacts resulting from the proposed Project, if any, would be limited to the construction phase, and be short- term and minor.

The telecommunication huts will be installed on previously disturbed lands in developed areas and therefore no impacts to prime or unique farmlands would occur.

The No Action Alternative would have no adverse impact on prime or unique farmlands or soil resources.

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4.4 WATER RESOURCES

4.4.1 Surface Water The majority (53%) of surface water features along the Project route would be crossed via aerial installation or use of existing underground conduit. Seventy-three (38%) watercourse crossings would be crossed via directional boring. Eighteen crossings are in Urban Areas (9%).

Aerial installation of fiber infrastructure would not involve stream or river crossings by construction equipment. Waterway spans would be accessed via road and utility ROW’s on both sides of the water feature, and fiber would be strung across from bank to bank by hand or by boat and pulled into place. Underground installation of fiber infrastructure beneath watercourses would involve directional boring at a depth of at least 4 feet below the bottom of the channel; no trenching within the channel or banks is proposed. Directional boring pits and the staging of any required equipment or materials would occur in upland areas set back a minimum of 25 feet from existing stream banks and associated wetlands. Bore pits and staging areas would be restored to their original grade using the original soil materials and seeded.

Eleven pre-fabricated telecommunication huts will be installed as part of the Project. The huts will be placed on a 10’ x 20’ concrete pad and a 20-foot wide gravel driveway constructed to provide vehicular access; the typical driveway length would be 50 feet. The amount of impervious surface associated with each hut is minor and will not appreciably increase stormwater runoff.

Permits from the U.S. Army Corps of Engineers (ACOE), the Michigan Department of Natural Resources and Environment (MiDNRE), Wisconsin Department of Natural Resources (WiDNR) and Minnesota Department of Natural Resources (MnDNR) may be required to construct the Project across watercourses and waterbodies. The need for local and/or state soil erosion and sedimentation control (SESC) permits will be investigated. All applicable permits will be acquired permit requirements will be adhered to throughout the construction of the Project. Refer to Chapter 5 for a summary of permitting requirements.

Given that surface water crossings would be aerially installed without crossing by construction equipment, directionally bored at least four feet below the bottom of the channel, or crossed using existing underground conduit, the proposed Project, including the placement of huts, would have no adverse impact on surface water resources.

The No Action Alternative would have no adverse impact on surface water resources.

4.4.2 Groundwater If the water table is encountered when excavating bore pits for directional drilling, the excess water would be pumped out of the pit into a filter bag with silt fence barrier as necessary and discharged to a well-vegetated upland area, per typical SESC procedures. The Project would not involve contamination of drinking water sources or permanent drawdown of the groundwater table. Therefore, the proposed Project would have no impact on groundwater resources.

The extent of impervious surface associated with each telecommunication hut will be minimal and the huts will be installed on previously disturbed lands in upland areas at least three feet above the water table. Therefore no impacts to groundwater resources would occur as a result of hut installation.

The No Action Alternative would have no adverse impact on groundwater resources.

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4.4.3 Wetlands Aerial installation of fiber infrastructure involves hanging fiber on existing poles in existing, disturbed road and utility ROW’s. Construction equipment, including rubber tire and/or tracked vehicles, would traverse the Project route within disturbed ROW’s along road shoulders and within disturbed areas in existing utility corridors. No new access roads would be required for the Project. Timber mats would be used to support construction equipment in wetland areas where saturated conditions create the potential for rutting. If expansive wetland areas are encountered, then installation of aerial fiber may be scheduled during the winter when the ground is frozen and can better support construction equipment in sensitive areas with unstable soils. Incidental ground disturbance from equipment and/or pole replacement would be mitigated by returning soil grades to their pre-construction elevations and stabilizing the soil using typical SESC best management practices (BMP’s). Any excess material associated with pole replacement would be placed in upland areas only and stabilized via typical SESC BMP’s. Since existing pole corridors would be utilized, there is no need to create new utility corridors or access roads for the Project. Thus, no new wetlands would be impacted by the Project for new pole runs or access roads. All construction-related disturbances associated with aerial installation of fiber would be short-term, temporary, and comparable to current ROW maintenance activities.

Underground construction methods include use of existing underground conduit, directional drilling, and vibratory plowing. All underground crossings will occur within existing road ROW’s. Utilization of existing underground conduit and directional boring in select locations will minimize adverse impacts to wetlands. Plowing will result in temporary soil disturbance associated with equipment tracks and the narrow slot created to install the fiber optic cable and conduit. Areas of ground disturbance created by plowing will be restored to their pre-construction grades and stabilized. Bore pits excavated for directional drilling will be located a minimum of 25 feet from wetland boundaries. No trenching or wetland fill is proposed. All construction-related disturbances associated with underground installation of fiber infrastructure would be temporary and short-term and would return soil grades to their original elevations.

Wetland permits will be acquired from the applicable federal, state, and local agencies; refer to Chapter 5 for a list of wetland permits that may be needed for construction and Appendix F for agency correspondence. All wetland permit requirements will be adhered to throughout the construction of the Project. Since Project impacts to wetlands are anticipated to be minor, short-term, and temporary, no wetland mitigation is proposed for the Project. The approved wetland permits, when received, will be included in the construction documents for the Project. In addition, the following Standard Operating Procedures will be incorporated into the construction documents to ensure that the contractor is aware of the construction methods to be used to minimize potential wetland impacts and comply with permit conditions:

• Access existing poles from the road shoulder and avoid crossing wet unstable ground with trucks and heavy equipment where possible. • Utilize prefabricated timber mats to provide a stable surface. Remove the mats when the crossing is completed. • If crossing wetlands with equipment is necessary, find a higher, drier part of the ROW to cross. • Do not enter wetlands during wet conditions if possible. Cross wetlands during the drier summer months or in the winter under frozen conditions. Note that there are some wetlands that never dry out enough to support vehicles or heavy equipment. • Cross the wetland at its narrowest width. If multiple vehicles or pieces of equipment are involved, consolidate crossings at the same point rather than each crossing at a different location in the wetland. • Minimize the number of times the wetland is crossed. Soil conditions often become wetter and more unstable as the number of crossings increases. • If ruts are accidentally formed, smooth them out with the bucket of a backhoe or using hand tools such as shovels and rakes.

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• Store hazardous materials in appropriate containment areas so any spillage will not flow into the wetland. Use any of these materials at least 100 feet from the edge of a wetland. Maintain a supply of materials to absorb and contain spills should they occur.

The proposed fiber optic route is located entirely within existing disturbed road and utility ROW’s. The proposed construction methods are designed to minimize ground disturbance and restore disturbed grades to pre-construction conditions. No new utility corridors or access roads are proposed. No wetland fill is proposed. Therefore, the potential adverse impacts to wetlands associated with the Project would be limited to the construction phase, short- term, and temporary.

The telecommunication huts will be installed on previously disturbed lands in developed upland areas and therefore no impacts to wetland resources would occur.

The No Action Alternative would have no adverse impact on wetland resources.

4.4.4 Coastal Zones The Project Team corresponded with the Coastal Management Program's Federal Consistency Coordinators for all three States and submitted coastal zone data. In Michigan and Wisconsin, the primary mechanism for ensuring that proposed projects conform to the Coastal Management Plan is the permitting process administered by the ACOE under Section 404 of the Clean Water Act and Section 10 of the Rivers and Harbors Act, and each state (i.e. MiDNRE and WiDNR). By securing and complying with the requirements of the ACOE and state wetland and water crossing permits, the Project would comply with Michigan and Wisconsin’s Coastal Management Plans and no separate coastal zone permit is required. The Federal Consistency Coordinator from Minnesota’s Lake Superior Coastal Program (MLSCP) stated that the proposed Project is consistent with the state-enforceable policies of the MLSCP. Refer to Appendix F for agency correspondence.

Fiber infrastructure installation would occur within existing, disturbed road and utility ROW’s in these coastal zones, and all construction-related disturbances associated with the Project would be short-term, minor, and comparable to current ROW maintenance activities. Hut placements will also occur within existing developed and disturbed areas and would therefore be compatible with existing land uses within designated Coastal Zones. Therefore, potential adverse impacts resulting from the Project would be limited to the construction phase, and would be short term and minor.

The No Action Alternative would have no adverse impact on coastal resources.

4.4.5 Environmental Areas The specialized construction techniques described in Section 4.4.1 and 4.4.3 will be used to minimize impacts to waterways and wetlands within designated Environmental Areas (EA’s). No vegetation clearing is proposed within EA’s because the cable installation would be done within existing, regularly maintained road and/or utility ROW’s. Construction-related disturbance would be limited to incidental soil disturbance associated with equipment traffic or equipment use for the aerial installation of fiber-optic cable. Should existing herbaceous vegetation be incidentally disturbed by construction equipment adjacent to EAs, all disturbed areas would be seeded with an appropriate seed mix and stabilized.

Potential adverse impacts resulting from the Project would be limited to the construction phase, and would be short- term and minor and comparable to current ROW maintenance activities.

There are no EA’s located at the eleven telecommunication hut sites, therefore no impacts to Environmental Areas would occur.

The No Action Alternative would have no adverse impact on designated Environmental Areas.

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4.4.6 Critical Dune Areas Part 353 of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended, provides for the designation of Critical Dune Areas. The Project route does not traverse any designated Critical Dune Areas (MiDNRE 1989, MiGDL 2002a). Therefore no adverse impacts to Critical Dune Areas would occur.

No telecommunication huts will be installed in designated Critical Dune Areas; therefore no adverse impacts to these areas would occur.

The No Action Alternative would have no adverse impact on designated Critical Dune Areas.

4.4.7 Floodplains The Project would not involve changes in floodplain elevation via cut or fill, as all construction-related disturbances associated with the Project would be short-term, temporary, and return any disturbed soils to their original grades. No new structures or telecommunication huts are proposed within floodplains. Applicable permits will be acquired as necessary and subsequent floodplain permit requirements adhered to throughout Project construction. Potential adverse impacts to floodplain resources would be limited to the construction phase and would be short-term and minor.

No telecommunication huts are proposed in floodplains; therefore, no adverse impacts to floodplains will occur.

The No Action Alternative would have no adverse impact on floodplain resources.

4.4.8 Designated Wild and Scenic Rivers Aerial installation of fiber infrastructure across designated Wild and Scenic Rivers would not involve crossing rivers with construction equipment. Waterway crossings would be accessed via existing, disturbed road and utility ROW’s on both sides, and fiber would be strung across from bank to bank by hand or by boat and pulled into place. No vegetation clearing is proposed adjacent to these natural features because the cable installation would be done within existing, regularly maintained road and/or utility ROW’s. Construction-related disturbance would be limited to incidental soil disturbance associated with equipment traffic or equipment use for the aerial installation of fiber-optic cable. Should existing herbaceous vegetation be inadvertently disturbed, all disturbed areas would be seeded with an appropriate seed mix and stabilized.

Underground installation will be done by directional boring within existing road ROW’s. Directional boring pits will occur in upland areas set back a minimum of 25 feet from existing wetlands or stream banks, and the staging of any required equipment will be in upland areas. Bore pits will be restored to their pre-construction grade using the original soil materials and seeded.

All construction-related disturbances associated with Wild and Scenic Rivers would be limited to existing road and utility ROWs and would be short-term and temporary. Therefore, the potential for adverse impacts resulting from the proposed Project would be limited to the construction phase and would be short-term and minor. The applicable permits and clearances from state and federal agencies will be acquired and adhered to throughout Project construction. Refer to Chapter 5 for permitting requirements.

The telecommunication huts will be installed on previously disturbed lands in developed areas away from Wild and Scenic Rivers and therefore no impacts to Federal Wild and Scenic Rivers would occur.

The No Action Alternative would have no adverse impact on Federal Wild and Scenic River resources.

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4.4.9 State-Designated Rivers Aerial waterway crossings would be accessed via existing, disturbed road and utility ROW’s on both sides, and fiber would be strung across from bank to bank by hand or by boat and pulled into place. No construction equipment will cross the river channel or banks. No vegetation clearing is proposed adjacent to these natural features because the cable installation would be done within existing, regularly maintained road and/or utility ROW’s. Construction-related disturbance would be limited to incidental soil disturbance associated with equipment traffic or equipment use for the aerial installation of fiber-optic cable. Should existing herbaceous vegetation be incidentally disturbed by construction equipment adjacent to these natural features, all disturbed areas would be seeded with an appropriate seed mix and stabilized.

Underground construction across waterways, including state-designated rivers, will utilize directional boring within existing road ROW’s. Directional boring pits will occur in upland areas set back a minimum of 25 feet from existing wetlands or stream banks, and the staging of any required equipment will be in upland areas. Bore pits will be restored to their pre-construction grade using the original soil materials and seeded.

All construction-related disturbances associated with designated rivers would be limited to existing road and utility ROWs and would be short-term and temporary. No vegetation clearing or placement of new permanent structures is proposed. Therefore, the potential for adverse impacts resulting from the proposed Project would be limited to the construction phase and would be short-term and minor. The applicable permits and clearances from state and federal agencies identified in Chapter 5 will be acquired and adhered to throughout Project construction. Refer to Appendix F for agency correspondence.

No telecommunication huts are proposed in Natural River Districts in Michigan or near Outstanding or Exceptional Water Resources in Wisconsin, and therefore no impacts to state designated rivers would occur.

The No Action Alternative would have no adverse impact on State-Designated River resources.

4.5 BIOLOGICAL RESOURCES

4.5.1 Ecoregions Changes to ecoregions would not occur for both the proposed Project and the No Action Alternative.

4.5.2 Wildlife No changes to wildlife habitat, including vegetation clearing, is proposed and construction-related noise and human activity will be similar to that experienced during routine maintenance of the road and utility ROW’s where the Project is to be located. Aerial construction on existing poles in existing, regularly disturbed road and utility ROWs and the use of existing underground conduit minimize the Project’s impact on corridor wildlife. Minor, temporary disturbances associated with underground construction and pole replacement would result in the ground surface being returned to its original grade and stabilized. Therefore, the potential adverse impacts to wildlife species associated with the Project would be limited to the construction phase, short-term, and minor.

The telecommunication huts will be installed on previously disturbed lands in developed areas and therefore no adverse impacts to wildlife resources will occur.

The No Action Alternative would have no adverse impact on wildlife resources.

4.5.3 Vegetation No vegetation clearing or alteration of existing vegetation communities is proposed. Aerial construction on existing poles in existing, regularly disturbed road and utility ROW’s and the use of existing underground conduit minimize the Project’s impact on corridor vegetation. Minor, temporary disturbances associated with underground construction

Merit REACH-3MC II Final Environmental Assessment (7/15/2011) 84 and pole replacement would result in the ground surface being returned to its original grade and stabilized. Therefore, the adverse impacts to vegetation associated with the Project would be limited to the construction phase, short-term, and minor.

The telecommunication huts will be installed on previously disturbed lands in developed areas and no adverse impacts to vegetation would occur.

The No Action Alternative would have no adverse impact on vegetation resources.

4.5.4 Threatened and Endangered Species and Critical Habitats The Project Team reviewed aerial and roadside photographs using Google Earth and conducted habitat evaluations in the field for all of the federal element occurrences noted by state natural resource agencies and the USFWS field offices during the months of September, October, and November 2010 and May 2011. The results of this review and coordination with state and federal agencies is discussed in more detail below.

4.5.4.1 Federal Threatened and Endangered Species For the majority of the federal element occurrences, quality habitat is not present within the immediate Project construction site, which involves disturbed and regularly maintained road and utility ROWs. Aquatic species habitat will not be adversely impacted by the proposed Project, because waterways will either be bored under, crossed using existing conduit, or aerially crossed via road shoulder access, by hand, or by boat. Terrestrial federal target species are much more likely to occur within higher quality habitats beyond the limits of the disturbed and regularly maintained road and utility ROW’s that will temporarily be impacted by the Project. However, construction crews will be made aware of federally listed species and their habitats and will implement the protective measures detailed in correspondence with the USFWS field offices and state natural resource agencies (see Appendix F).

Protective mitigation measures utilize specific construction technique selection, spatial restrictions, and seasonal restrictions to minimize adverse impacts to rare species along the Project route. As a specific example of construction technique selection, aerial installation on existing poles via road shoulder access, by hand, or by boat; directional boring; or utilization of existing conduit, when available, will be implemented to cross the Grand River and completely avoid suitable habitat for the snuffbox mussel in Kent County. As an example of both spatial and seasonal restrictions, the measures described for Karner blue butterfly and its habitat in Montcalm County restrict construction equipment spatially to the maintained portion of the highway ROW to avoid impacts to the larval host plant, wild lupine, and butterfly larvae and eggs and seasonally to when adult butterflies are not present, thus, protecting the species in all of its life stages.

In one instance, the route of the Northern Corridor was modified to avoid a designated critical habitat area for the Hine’s emerald dragonfly along Mackinac Trail north of St. Ignace. The route was shifted west to the I-75 ROW between the highway interchange at Evergreen Shores and the highway interchange at M-123. This change is shown on all of the maps in this Environmental Assessment. The Michigan SHPO was informed of this change and issued a supplemental clearance letter on July 15, 2011.

The Project Team determined the following for federal element occurrences in each state:

• Michigan: o No effect on snuffbox mussel due to habitat avoidance via construction technique selection, o No effect on Houghton's goldenrod in Schoolcraft County due to the lack of suitable habitat and individuals within the area of proposed impact, o No effect on the three Kirtland’s warbler occurrences due to seasonal restrictions that limit work to when the bird is not nesting in Michigan,

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o May affect, but not likely to adversely affect, the remaining federal species occurrences, including the Hine’s emerald dragonfly and its designated critical habitat area, due to the implementation of spatial and seasonal protection measures, and o May affect, but not likely to adversely affect, Bald eagle due to the implementation of spatial and seasonal protection measures per the USFWS Step-by-Step Guidance for Bald eagle nests.

• Wisconsin: o No effect on Piping plover due to lack of suitable habitat within the area of proposed impact and seasonal restrictions that limit work to when the bird is not nesting in Wisconsin, o No effect on Fassett’s locoweed, Dwarf lake iris, Kirtland’s warbler, Whooping crane, and Karner blue butterfly due to lack of suitable habitat within the area of proposed impact, o May affect, but not likely to adversely affect Gray wolf and Canada lynx due to the area of proposed impact being constrained to existing road and utility ROW’s in close proximity to roads, the temporary nature of the Project impacts, and the highly unlikely possibility of encountering these cryptic mammals during construction, and o May affect, but not likely to adversely affect Bald eagle due to the implementation of spatial and seasonal protection measures per the USFWS Step-by-Step Guidance for Bald eagle nests.

• Minnesota: o No effect on Piping plover due to lack of suitable habitat within the area of proposed impact and seasonal restrictions that limit work to when the bird is not nesting in Minnesota, and o No effect on Gray wolf and Canada lynx due to the lack of suitable habitat in downtown Duluth and the high unlikelihood of encountering these cryptic mammals during construction.

The Project received concurrence with these determinations for Minnesota from the USFWS Twin Cities Field Office on April 7, 2011 and for Michigan and Wisconsin from the USFWS East Lansing Field Office on June 27, 2011. Refer to Appendix F for USFWS correspondence.

Summaries of each state's review for potential impacts to federal and state listed T&E species are presented below.

4.5.4.2 Michigan Threatened and Endangered Species Table 4.5.4.1 summarizes element occurrences in Michigan that have the potential to be impacted along the Project Route, including federally and state listed species and unique natural features and protected areas administered by MDOT, by corridor and county, per the MiDNRE Wildlife Division review letter dated January 7, 2011 and subsequent correspondence on January 31, 2011. Refer to Appendix F for the MiDNRE correspondence. This table also summarizes the Project Team’s findings regarding the potential for impacts to each element occurrence in Michigan based on the potential for suitable habitat to be present in the area that would be affected by the proposed Project or proposed construction methods that would be used to minimize potential impacts to T&E species or their habitats.

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Table 4.5.4.1 Summary of MiDNRE Review for Known Element Occurrences

Corridor/ Species/Natural Federal State Proposed MiDNRE Habitat Adverse Impact? County Community Status* Status** Action Recommendation MIDDLE No Impact: crossings of Grand River to occur in Snuffbox mussel Grand River; rivers/streams w/ swift current & Kent C E Urban None existing conduit, be bored, or aerially installed by (Epioblasma triquetra ) cobble/gravel/sand substrate hand/boat/road shoulder—no equipment in river Not Significant; coordinate w/ MDOT to locate Karner blue butterfly Along US-131 near M-82 (US-131 Howard City underground cable w/in regularly mown portion of Underground (Lycaeides melissa E T MDOT Protected Area); oak & oak-pine None Road ROW lacking larval host plant & restrict Road ROW samuelis ) savanna or barrens timing to September 1-May 1 to avoid adult flight periods Montcalm Not Significant; coordinate w/ MDOT to locate Along US-131 near Cannonsville Rd.; oak-pine Persius dusky wing underground cable w/in regularly mown portion of barrens & adjacent prairies & brushy fields, Underground (Erynnis persius N/A T None Road ROW lacking larval host plant & restrict along trails & utility rights-of-way through Road ROW persius ) timing to September 1-May 1 to avoid adult flight barrens period Not Significant; per USFWS Step -by -Step West of M-20; large trees in isolated areas in Guidance, limit construction as follows: no activity Bald eagle (Haliaeetus proximity to large areas of surface water, large Underground Mecosta N/A SC None ¥ w/in 330’ of eagle nest year-round or w/in 660’ of leucocephalus ) complexes of deciduous forest, coniferous Road ROW eagle nest from January 1 st to August 1 st ; known forest, wetland, and shrub communities nest is 1,300’ from route South of County Hwy F 17; large trees in Not Significant; per USFWS Step-by-Step isolated areas in proximity to large areas of Guidance, limit construction as follows: no activity Bald eagle (Haliaeetus Underground Ogemaw N/A SC surface water, large complexes of deciduous None ¥ w/in 330’ of eagle nest year-round or w/in 660’ of leucocephalus ) Road ROW forest, coniferous forest, wetland, and shrub eagle nest from January 1 st to August 1 st ; known communities nest is 840’ from route Between Long & Loon Lakes; large trees in Not Significant; per USFWS Step -by -Step Aerial isolated areas in proximity to large areas of Guidance, limit construction as follows: no activity Bald eagle (Haliaeetus preferred but N/A SC surface water, large complexes of deciduous None ¥ w/in 330’ of eagle nest year-round or w/in 660’ of leucocephalus ) Underground forest, coniferous forest, wetland, and shrub eagle nest from January 1 st to August 1 st ; known possible communities nest is 1,500’ from route Not Significant; make field crews aware of species Eastern massasauga River Rd & Monument Rd.; variety of wetlands, If observed, leave Underground so can avoid it & operate construction equipment at rattlesnake ( Sistrurus C SC especially prairie fens, in spring & fall & alone & allow to Iosco Road ROW slow speeds during active season (April through catenatus catenatus ) adjacent uplands in summer retreat October) Not Significant; make field crews aware of species Wood turtle ( Clemmys River Rd. & Kobs Rd.; sandy-bottomed Underground so can avoid it; no river crossings proposed in this N/A SC None insculpta ) streams/rivers Road ROW area; not likely to occur in disturbed, graded Road ROW Kirtland’s Warbler Tawas Kirtland’s Warbler Management Area Urban & Not Signi ficant; coordinate w/ MDOT to locate E E None (Dendroica kirtlandii ) south of River Rd. (not currently occupied per Underground underground cable as close to road shoulder as

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Corridor/ Species/Natural Federal State Proposed MiDNRE Habitat Adverse Impact? County Community Status* Status** Action Recommendation USFWS); large homogenous stands of jack Road ROW possible & restrict timing of installation to when pine w/ scattered small openings warbler has migrated south (August 15 - May 1); no woody vegetation removal proposed Not Significant; coordinate w/ MDOT to locate Clark’s marsh along River Rd.; ponds, underground cable as close to road shoulder as Blanding’s turtle marshes, swamps, bogs, wet prairies, river Underground possible & restrict timing of installation of N/A SC None (Emydoidea blandingii ) backwaters, embayments, sloughs, slow- Road ROW underground cable in upland Road ROW August 15 moving rivers, and lake shallows and inlets - May 1, when turtle is hibernating in wetlands & not nesting in uplands Not Significant; restrict timing of aerial & Mock Lake Kirtland’s Warbler Management DOA: Aerial underground installation to when warbler has Area south of Mio along M-33 (M-33 Mio MDOT preferred, Kirtland’s Warbler migrated south (August 15 - May 1); coordinate E E Protected Area; not currently occupied per otherwise None (Dendroica kirtlandii ) w/ MDOT to locate underground cable as close USFWS); large homogenous stands of jack Underground to road shoulder as possible; no woody pine w/ scattered small openings Road ROW vegetation removal proposed Oscoda Not Significant; woody & not likely to occur in Alleghany plum South of Mio east of M-33 (M-33 Mio MDOT Underground cleared & constructed Road ROW; will coordinate (Prunus alleghaniensis N/A SC Protected Area); oak & pine barrens & dry sand None Road ROW w/ MDOT to stay as close to road shoulder as var. davisii ) prairies possible; no woody vegetation removal proposed Not Significant; not likely to occur in cleared & Hill’s thistle ( Cirsium Southeast corner of M-33 & Curtisville Rd (M- Underground N/A SC None constructed Road ROW; will coordinate w/ MDOT hillii ) 33 Mio MDOT Protected Area); pine barrens Road ROW to stay as close to road shoulder as possible Not Significant; coordinate w/ MDOT to locate underground cable installation along bare dirt Dusted skipper M-72 at Smith Bridge; oak-pine barrens, Underground N/A SC None shoulder of Old M-72 or conduct survey during (Atrytonopsis hianna ) prairies, sandy ROWs Road ROW agency’s recommended time period in 2011 prior to construction; if found, bore under occurrence(s) Not Significant; will conduct survey during agency’s Rough fescue ( Festuca East of Grayling along M-72; openings of sandy Underground N/A T None recommended time period in 2011 prior to scabrella ) jack pine woodlands Road ROW construction; if found, bore under occurrence(s) Muskrat Lake Kirtland’s Warbler Management Aerial Not Significant; coordinate w/ MDOT to locate Crawford Area along M-72 (M-72 South Down River Rd. preferred but underground cable as close to road shoulder as Kirtland’s Warbler MDOT Protect Area); stand southwest of Staley Underground possible & restrict timing of aerial & underground E E None (Dendroica kirtlandii ) Lake Rd. & M-72 currently occupied per possible & installation to when warbler has migrated south USFWS; large homogenous stands of jack pine Underground (August 15 - May 1); no woody vegetation removal w/ scattered small openings Road ROW proposed DOA: Aerial Not Significant; make field crews aware of species Eastern massasauga Northeast of M-72; variety of wetlands, preferred, If observed, leave so can avoid it & operate construction equipment at rattlesnake ( Sistrurus C SC especially prairie fens, in spring & fall & otherwise alone & allow to slow speeds during active season (April through catenatus catenatus ) adjacent uplands in summer Underground retreat October) Road ROW

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Corridor/ Species/Natural Federal State Proposed MiDNRE Habitat Adverse Impact? County Community Status* Status** Action Recommendation Along M -93 between I -75 & Hartwick Pines Not Significant; not likely to occur in cleared & Red-legged spittlebug Underground N/A SC State Park (I-75 Grayling MDOT Protected None constructed Road ROW; will coordinate w/ MDOT (Prosapia ignipectus ) Road ROW Area); moist grasses & prairie edges to stay as close to road shoulder as possible Grizzled skipper No Impact; not suitable habitat -- larval host plant Along M-93 near Hartwick Pines State Park; Underground (Pyrgus centaureae N/A SC None (wild strawberry) not observed during field survey open, disturbed areas in oak-pine barrens Road ROW wyandot ) w/in Road ROW DOA: Aerial Boreal fen moth preferred, South of Grayling near I-75 rest area; dry-mesic Not Significant; not likely to occur in cleared & (Brachionycha N/A SC otherwise None oak-pine forests constructed ROW on opposite side of I-75 borealis ) Underground Road ROW Not Significant; conduct aerial installation during DOA: Aerial winter when snow cover present to protect dormant M-72 & Arrowhead Rd (M-72 Portage Creek preferred, Houghton's goldenrod plants from just north of Arrowhead Rd. to T T MDOT Protected Area); northern wet prairie otherwise None (Solidago houghtonii ) McIntyres Landing Rd.; conduct underground w/in jack pine barrens Underground installation via boring along entire length of signed Road ROW Protected Area NORTHEASTERN DOA: Aerial Not Significant; make field crews aware of species preferred, Wood turtle (Clemmys F-41 at Pine River; sandy-bottomed so can avoid it; no equipment in river—aerial N/A SC otherwise None insculpta) streams/rivers crossing by hand/boat or underground crossing via Underground boring Alcona Road ROW West of Harrisville near M -72; ponds, marshes, Aerial Not Significant; make field crews aware of species Blanding’s turtle swamps, bogs, wet prairies, river backwaters, preferred but so can avoid it; limit aerial construction equipment N/A SC None (Emydoidea blandingii ) embayments, sloughs, slow-moving rivers, and Underground to road shoulder where feasible; limit underground lake shallows and inlets possible construction to road ROW DOA: Aerial Not Significant; make field crews aware of species Eastern massasauga Wilds Rd. near Devil’s River; variety of preferred, If observed, leave so can avoid it & operate construction equipment at rattlesnake ( Sistrurus C SC wetlands, especially prairie fens, in spring & fall otherwise alone & allow to slow speeds during active season (April through catenatus catenatus ) & adjacent uplands in summer Underground retreat October) Road ROW Aerial Not Significant; not likely to occur in cleared & South of Alpena along US-23 near Squaw Bay preferred but Take precautions to constructed ROW & residential development; cable Alpena Wooded Dune & Swale (US-23 Partridge Point MDOT Protected Area); N/A N/A Underground minimize wetland to be installed aerially on existing poles, most of Complex sand ridges & interdunal troughs along Great possible & impacts which can be accessed from road shoulder; limit Lakes shoreline Urban underground construction to road ROW South of Alpena along US -23 near Squaw Bay Aerial No construction w/in Not Significant; nesting colony not likely to occur in Common tern ( Sterna (US-23 Partridge Point MDOT Protected Area); preferred but ¼ mile of known tern cleared & constructed ROW; cable to be installed N/A T hirundo ) bare/sandy/gravelly areas of island & Underground colony during nesting aerially on existing poles or underground in the peninsulas possible season May 1- Aug 7 road ROW during non-nesting season (mid-August

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Corridor/ Species/Natural Federal State Proposed MiDNRE Habitat Adverse Impact? County Community Status* Status** Action Recommendation to late April) Not Significant; not likely to occur in cleared & constructed ROW; cable to be installed aerially on South of Alpena along US-23 near Squaw Bay Aerial Take precautions to existing poles during winter when ground is frozen (US-23 Partridge Point MDOT Protected Area); preferred but Great Lakes Marsh N/A N/A minimize wetland & vegetation dormant or climb poles on foot when wetland influenced by & connected to large Underground impacts cannot be accessed from road shoulder during freshwater lake possible growing season; limit underground construction to road ROW Not Significant; make field crews aware of species so can avoid it; cable to be installed aerially on South of Alpena along US-23 near Squaw Bay Aerial existing poles either during winter when ground is Dwarf lake iris ( Iris (US-23 Partridge Point MDOT Protected Area); preferred but frozen, snow cover for protection, & plant is T T None lacustris ) near Great Lakes shoreline on sand/thin soils Underground dormant or climb poles on foot when cannot be over calcareous gravel/bedrock possible accessed from road shoulder during growing season; conduct survey & bore under plants if underground construction is necessary Lake cress ( Armoracia In Thunder Bay River; shallow lake margins & No Impact; no boring under or construction N/A T Urban None lacustris ) backwaters of slow-moving streams equipment in river—aerial crossing by hand/boat No Impact; no construction equipment in river — Pugnose shiner Thunder Bay River & Hillman Pond; inland aerial crossing by hand/boat or bore or cable to be Montmorency N/A E Urban None (Notropis anogenus ) lakes & streams installed in existing conduit across the Thunder Bay River Not Significant; make field crews aware of species so can avoid it; no equipment in or crossing of Wood turtle ( Clemmys Underground N/A SC Ocqueoc River; sandy-bottomed streams/rivers None river—not likely to occur on south side of highway insculpta ) Road ROW opposite the river in disturbed, graded Road ROW; Presque Isle will bore under Indian Creek Not Significant; not likely to be encountered in Gray wolf ( Canis Aerial & E T Northern forested areas None ¥ disturbed ROWs, especially given how quickly work lupus ) Underground will move through any given area East of I-75 & north of M-68; large trees in Not Significant; per USFWS Step-by-Step Aerial isolated areas in proximity to large areas of Guidance, limit construction as follows: no activity Bald eagle (Haliaeetus preferred but N/A SC surface water, large complexes of deciduous None ¥ w/in 330’ of eagle nest year-round or w/in 660’ of leucocephalus ) Underground forest, coniferous forest, wetland, and shrub eagle nest from January 1 st to August 1 st ; known Cheboygan possible communities nest is 1,600’ from route Not Significant; not likely to be encountered in Gray wolf ( Canis Aerial & E T Northern forested areas None ¥ disturbed ROWs, especially given how quickly work lupus ) Underground will move through any given area NORTHERN CORRIDOR / UP SPURS Mackinac Calypso ( Calypso N/A T Near McCloud Creek at intersection of I -75 & Purchase None No Impact; existing fiber infrastructure to be

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Corridor/ Species/Natural Federal State Proposed MiDNRE Habitat Adverse Impact? County Community Status* Status** Action Recommendation bulbosa ) M-134 (I -75 St. Martin Bay Protected Area); existing fiber purchased moist coniferous forests w/ cool soils in shade Throughout Summerby Fen near Mackinac Butterwort ( Pinguicula Trail northeast of intersection w/ M-123; Purchase No Impact; existing fiber infrastructure to be N/A SC None vulgaris ) interdunal & marly flats & fens, rock outcrops existing fiber purchased inland of Great Lakes & along shoreline Both sides of Mackinac Trail north of Purchase intersection w/ M-123 (M-123 Summerby Fen No Impact; existing fiber infrastructure to be Black crowberry Existing Fiber, N/A T Protected Area); bare rock outcrops, cedar- None purchased & existing conduit utilized north of (Empetrum nigrum ) Existing spruce bogs, exposed sandy bluffs & old dune intersection w/ M-123 Conduit ridges under pines Purchase Both sides of Mackinac Trail near intersection Existing Fiber, Not Significant; existing fiber infrastructure to be Take precautions to Wooded Dune & Swale w/ M-123 (M-123 Summerby Fen Protected Existing purchased & existing conduit utilized north of N/A N/A minimize ecosystem Complex Area); sand ridges & interdunal troughs along Conduit, & intersection w/ M-123; cable to be installed in impacts Great Lakes shoreline Underground disturbed, graded Road & Utility ROW Road ROW Purchase Hine's emerald Existing Fiber, Not Significant; plow in disturbed upland road ROW West of I-75 north of southbound exit ramp at If boring, limit work to dragonfly Existing & bore beneath stream/wetland crossings; existing E E M-123 (M-123 Summerby Fen Protected Area); upland along (Somatochlora Conduit, fiber infrastructure to be purchased north of M- calcareous marshes over dolomite bedrock roadside. hineana ) Underground 123/I-75 intersection Road ROW Mat muhly North side M-123 east of Summerby Creek (M- Underground No Impact; no suitable habitat in maintained portion (Muhlenbergia N/A T None 123 Summerby Fen Protected Area); alvar Road ROW of Road ROW richardsonis ) Both sides of M -123 near Summerby Creek (M - Black crowberry 123 Summerby Fen Protected Area); bare rock Underground No Impact; no suitable habitat in maintained portion N/A T None (Empetrum nigrum ) outcrops, cedar-spruce bogs, exposed sandy Road ROW of Road ROW bluffs & old dune ridges under pines Hine's emerald North side M-123 west of Summerby Creek (M- If boring, limit work to dragonfly Underground Not Significant; plow in disturbed upland road ROW E E 123 Summerby Fen Protected Area); upland along (Somatochlora Road ROW & bore beneath stream/wetland crossings calcareous marshes over dolomite bedrock roadside. hineana ) MI Units 1 and 2 east & west of I -75 and north Critical Habitat for & south of M-123; (M-123 Summerby Fen Underground Not Significant; plow in disturbed upland road ROW Hine's emerald N/A N/A None ¥ Protected Area); calcareous marshes over Road ROW & bore beneath stream/wetland crossings dragonfly dolomite bedrock Incurvate emerald North side M -123 west of Summerby Creek (M - If boring, limit work to Underground Not Significant; plow in disturbed upland road ROW dragonfly N/A SC 123 Summerby Fen Protected Area); small upland along Road ROW & bore beneath stream/wetland crossings (Somatochlora pools of spring water in sphagnum bogs, roadside.

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Corridor/ Species/Natural Federal State Proposed MiDNRE Habitat Adverse Impact? County Community Status* Status** Action Recommendation incurvata ) patterned peatl ands & northern fens Aerial preferred but Sharp-tailed grouse Northeast of M-123 west of Summerby Creek Underground Not Significant; limit installation to non-nesting & (Tympanuchus N/A SC (M-123 Summerby Fen Protected Area); large None possible & brood rearing season (August 1 to April 1) phasianellus ) open areas w/ grass, brush, & few mature trees Underground Road ROW Greene Cedar Swamp near intersection w/ Not Significant; cable to be directionally bored at Eastern flat-whorl snail Worth Rd. (M-123 Greene Cedar Swamp Underground N/A SC None base of road shoulder grade a minimum of 1,000' (Planogyra asteriscus ) MDOT Protected Area); spruce-arborvitae Road ROW on either side of Worth Rd. and west of M-123 swamps adjacent to deciduous upland forest Greene Cedar Swamp near intersection w/ Not Significant; cable to be directionally bored at Land snail ( Euconulus Worth Rd. right side of M-123 (M-123 Greene Underground N/A T None base of road shoulder grade a minimum of 1,000' alderi ) Cedar Swamp MDOT Protected Area); fens, Road ROW on either side of Worth Rd. and west of M-123 tamarack-sedge & cool calcareous wetlands Take precautions to Not Significant; cable to be installed in disturbed, Alvar/alkaline scrub- Sedge & grass ecosystem on both sides of M- Underground N/A N/A minimize ecosystem graded Road ROW; will coordinate w/ MDOT to grassland 123 Road ROW impacts stay as close to road shoulder as possible or bore Prairie dropseed Not Significant; cable to be installed in disturbed, Alvar; sedge & grass ecosystem on both sides Underground (Sporobolus N/A SC None graded Road ROW; will coordinate w/ MDOT to of M-123 Road ROW heterolepis ) stay as close to road shoulder as possible or bore Take precautions to Underground Not Significant; cable to be installed in disturbed, Muskeg/scrub bog N/A N/A Wetland complex southeast of Trout Lake Rd. minimize wetland Road ROW graded Road ROW, not in wetland impacts Not Significant; not likely to be encountered in Gray wolf ( Canis Aerial & E T Northern forested areas None ¥ disturbed ROWs, especially given how quickly work lupus ) Underground will move through any given area Not Significant; not likely to be encountered in Canada lynx ( Lynx Aerial & T E Northern forested areas None ¥ disturbed ROWs, especially given how quickly work canadensis ) Underground will move through any given area Sharp -tailed g rouse Large open areas w/ grass, brush, & few Purchase No Impact; existing fiber infrastructure to be (Tympanuchus N/A SC None mature trees existing fiber purchased phasianellus ) Not Significant; not likely to be encountered in Gray wolf ( Canis Aerial & Chippewa E T Northern forested areas None ¥ disturbed ROWs, especially given how quickly work lupus ) Underground will move through any given area Not Significant; not likely to b e encountered in Canada lynx ( Lynx Aerial & T E Northern forested areas None ¥ disturbed ROWs, especially given how quickly work canadensis ) Underground will move through any given area Houghton's goldenrod Northern Lake Michigan shoreline (US -2 DOA: Aerial No Impact; existing po les in disturbed, graded Schoolcraft T T None (Solidago houghtonii ) Manistique MDOT Protected Area); Northern preferred, landscape along US-2 & near buildings--not

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Corridor/ Species/Natural Federal State Proposed MiDNRE Habitat Adverse Impact? County Community Status* Status** Action Recommendation shores of Lake s Michigan & Huron, restricted to otherwise suitable habitat; if underground installation calcareous beach sand, rocky/cobbly shores, Underground required, will be on north side (opposite of beach flats, interdunal wetland paralleling the Road ROW shoreline) of US-2--not suitable habitat; not shoreline, and seasonally wet limestone observed during field survey w/in Road ROW pavement Aerial Take precautions to Wooded Dune & Swale Along US-2; sand ridges & interdunal troughs preferred but Not Significant; cable to be installed in disturbed, N/A N/A minimize ecosystem Complex along Great Lakes shoreline Underground graded Road & Utility ROWs impacts possible Take precautions to Underground No Impact; cable to be installed on north side US-2 Bog N/A N/A Peatland south of US-2 minimize wetland Road ROW in disturbed, graded Road ROW, not in wetland impacts Not Significant; not likely to be encountered in Gray wolf ( Canis Aerial & E T Northern forested areas None ¥ disturbed ROWs, especially given how quickly work lupus ) Underground will move through any given area Not Significant; not likely to be encountered in Canada lynx ( Lynx Aerial & T E Northern forested areas None ¥ disturbed ROWs, especially given how quickly work canadensis ) Underground will move through any given area North & south sides of US -2 east of intersection DOA: Aerial Not Significant; cable to be installed aerially on w/ M-183 (US-2 Big Bay De Noc MDOT preferred, Mystery vertigo snail existing poles during winter when ground is frozen; N/A SC Protected Area); leaf litter in upland woods, otherwise None (Vertigo paradoxa ) if underground installation required, boring will carbonate outcrops, & basalt outcrops near Underground occur Lake Superior Road ROW DOA: Aerial North & south sides of US-2 east of intersection Not Significant; cable to be installed aerially on Deep-throat vertigo preferred, w/ M-183 (US-2 Big Bay De Noc MDOT existing poles during winter when ground is frozen; snail ( Vertigo N/A E otherwise None Protected Area); calcareous fens w/ open if underground installation required, boring will nylanderi ) Underground tamarack, alder, & sedge vegetation occur Road ROW North & south sides of US -2 east of intersection DOA: Aerial Not Significant; cable to be installed aerially on Delta w/ M-183 (US-2 Big Bay De Noc MDOT preferred, existing poles during winter when ground is frozen; Tapered vertigo snail N/A SC Protected Area); tamarack-sedge wetlands, otherwise None if underground installation required, boring will (Vertigo elatior ) white-cedar wetlands, northern fens, & cobble Underground occur beaches Road ROW DOA: Aerial Not Significant; cable to be installed aerially on North & south sides of US-2 east of intersection preferred, existing poles during winter when ground is frozen; Land snail ( Euconulus w/ M-183 (US-2 Big Bay De Noc MDOT N/A T otherwise None if underground installation required, boring will alderi ) Protected Area); fens, tamarack-sedge Underground occur wetlands Road ROW Along Big & Little Bay de Noc; large trees in Aerial Not Significant; per USFWS Step -by -Step Bald eagle (Haliaeetus N/A SC isolated areas in proximity to large areas of preferred but None ¥ Guidance, limit construction as follows: no activity leucocephalus ) surface water, large complexes of deciduous Underground w/in 330’ of eagle nest year-round or w/in 660’ of

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Corridor/ Species/Natural Federal State Proposed MiDNRE Habitat Adverse Impact? County Community Status* Status** Action Recommendation forest, coniferous forest, wetland, and shrub possible ; eagle nest from January 1 st to August 1 st ; known communities Underground nests are 400’ to 1,600’ from route Road ROW; Urban Aerial Ford River crossing at US-2 (US-2 Ford River No Impact; no construction equipment in river; Rapids clubtail preferred but N/A SC MDOT Protected Area); clear streams over None access will occur from road shoulder or boat or (Gomphus quadricolor ) Underground gravel, cobble, or bedrock w/ strong current crossing will be directionally bored possible Aerial Ford River crossing at US-2 (US-2 Ford River No Impact; no construction equipment in river; Riverine snaketail preferred but N/A SC MDOT Protected Area); clear streams over None access will occur from road shoulder or boat or (Stylurus amnicola ) Underground gravel or sand w/ current crossing will be directionally bored possible Not Significant; not likely to be encountered in Gray wolf ( Canis Aerial & E T Northern forested areas None ¥ disturbed ROWs, especially given how quickly work lupus ) Underground will move through any given area Not Significant; not likely to be encountered in Canada lynx ( Lynx Aerial & T E Northern forested areas None ¥ disturbed ROWs, especially given how quickly work canadensis ) Underground will move through any given area North & south of US -2 (Wilson Roadcut/Indian Sweet coltsfoot Underground Not Significant; boring will occur for whole length of N/A T Town MDOT Protected Area); sedge fen, None (Petasites sagittatus ) Road ROW signed Protected Area marsh, & wet swales Smooth beardtongue Open area along US -2 east of Powers or prairie No Impact; disturbed, graded landscape along US - Underground (Penstemon N/A T remnant along golf course; little habitat data None 2--not suitable habitat & not observed during field Road ROW calycosus ) available survey w/in Road ROW Furrowed flax ( Linum West side of US -41 east of railroad tracks; Underground No Impact; cable route shifted to opposite (east) N/A SC None sulcatum ) prairies & dry open sandy ground Road ROW side of US-41 where no suitable habitat exists Menominee West side of US -41 east of railroad tracks in Compass plant Underground No Impact; cable route shifted to opposite (east) N/A T prairie remnant (US-41 Birch Creek Prairie None*** (Silphium laciniatum ) Road ROW side of US-41 where no suitable habitat exists MDOT Protected Area); mesic prairie Not Significant; not likely to be encountered in Gray wolf ( Canis Aerial & E T Northern forested areas None ¥ disturbed ROWs, especially given how quickly work lupus ) Underground will move through any given area Not Significant; not likely to be encountered in Canada lynx ( Lynx Aerial & T E Northern forested areas None ¥ disturbed ROWs, especially given how quickly work canadensis ) Underground will move through any given area Not Significant; per USFWS Step -by -Step North of US-2; large trees in isolated areas in Guidance, limit construction as follows: no activity Bald eagle (Haliaeetus proximity to large areas of surface water, large Underground N/A SC None ¥ w/in 330’ of eagle nest year-round or w/in 660’ of Dickinson leucocephalus) complexes of deciduous forest, coniferous Road ROW eagle nest from January 1 st to August 1 st ; known forest, wetland, and shrub communities nest is 1,500’ from route Gray wolf ( Canis E T Northern forested areas Aerial & Non e¥ Not Significant; not likely to be encountered in

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Corridor/ Species/Natural Federal State Proposed MiDNRE Habitat Adverse Impact? County Community Status* Status** Action Recommendation lupus ) Underground disturbed ROWs, especially given how quickly work will move through any given area Not Significant; not likely to be encountered in Canada lynx ( Lynx Aerial & T E Northern forested areas None ¥ disturbed ROWs, especially given how quickly work canadensis ) Underground will move through any given area Not Significant; cable to be installed on opposite Frigga fritillary ( Boloria Underground N/A SC Bowers Creek Bog east of US-2; None (west) side US-2 in disturbed, graded Road ROW, frigga ) Road ROW not in wetland Both sides of US -2 (US -2 Bates Roadside Park Not Significant; cable to be installed in disturbed, MDOT Protected Area); forest north of Underground Mesic Northern Forest N/A N/A None graded Road ROW, not in forest; will coordinate w/ transition zone characterized by hardwoods & Road ROW MDOT to stay as close to road shoulder as possible hemlock Not Significant; cable to be installed in disturbed, Iron Satiny willow ( Salix Near intersection of US-2 & Federal Forest Underground graded Road ROW w/ all river & stream & N/A SC None pellita ) 3920 Rd; riverbanks & sandy shores Road ROW shrub/forested wetland crossings to be bored; removal of woody vegetation not proposed Not Significant; not likely to be encountered in Gray wolf ( Canis Aerial & E T Northern forested areas None ¥ disturbed ROWs, especially given how quickly work lupus ) Underground will move through any given area Not Significant; not likely to be encountered in Canada lynx ( Lynx Aerial & T E Northern forested areas None ¥ disturbed ROWs, especially given how quickly work canadensis ) Underground will move through any given area Roadside ditch along Old US -2; rocky openings Underground Not Significant; cable to be installed in disturbed, Purple clematis N/A SC None of dry-mesic forests Road ROW graded Road ROW along US-2 not Old US-2 Intersection of US -2 & Hwy 64 (Marenisco East No Impact; disturbed, graded landscape along US - Sweet coltsfoot Underground N/A T MDOT Protected Area); sedge fen, marsh, & None 2-- not suitable habitat & not observed during field (Petasites sagittatus ) Road ROW wet swales survey w/in Road ROW Gogebic Not Significant; not likely to be encountered in Gray wolf ( Canis Aerial & E T Northern forested areas None ¥ disturbed ROWs, especially given how quickly work lupus ) Underground will move through any given area Not Significant; not likely to be encountered in Canada lynx ( Lynx Aerial & T E Northern forested areas None ¥ disturbed ROWs, especially given how quickly work canadensis ) Underground will move through any given area No Impact; disturbed, graded land scape along US - Pine-drops ( Pterospora Woods near US-45; dry woods w/ rocky soil Underground N/A T None 45-- not suitable habitat & not observed during field andromedea ) dominated by conifers, especially pines Road ROW survey w/in Road ROW Not Significant; not likely to be encountered in Ontonagon Gray wolf ( Canis Aerial & E T Northern forested areas None ¥ disturbed ROWs, especially given how quickly work lupus ) Underground will move through any given area Canada lynx ( Lynx Aerial & Not Significant; not likely to be encountered in T E Northern forested areas None ¥ canadensis ) Underground disturbed ROWs, especially given how quickly work

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Corridor/ Species/Natural Federal State Proposed MiDNRE Habitat Adverse Impact? County Community Status* Status** Action Recommendation will move through any g iven area Not Significant; woody & not likely to occur in Douglas’ hawthorn West side of US-41 across from Quincy Mine N/A SC Urban None cleared & constructed ROW; removal of woody (Crataegus douglasii ) Hoist vegetation not proposed Not Significant; not likely to be encountered in Gray wolf ( Canis Aerial & Houghton E T Northern forested areas None ¥ disturbed ROWs, especially given how quickly work lupus ) Underground will move through any given area Not Significant; not likely to be encountered in Canada lynx ( Lynx Aerial & T E Northern forested areas None ¥ disturbed ROWs, especially given how quickly work canadensis ) Underground will move through any given area *C = federal candidate species, E = federally endangered species, T = federally threatened species **E = state endangered species, SC = state special concern species, T = state threatened species ***Listed species or suitable habitat observed by Project Team during field review of the Project route but not formally included in 1-7-11 MDNRE Wildlife Division review. Additional listed species to be addressed per 1-31-11 correspondence from MiDNRE Wildlife Division. ¥Element occurrences identified by USFWS review but not included in MiDNRE review.

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Many of T&E species listed in Table 4.5.4.1 will not be adversely affected by the proposed Project, because construction methods will be utilized to avoid impacts to suitable habitat. As specific examples, snuffbox (Epioblasma triquetra ) (mussel), pugnose shiner ( Notropis anogenus ) (fish), and riverine snaketail ( Stylurus amnicola ) (dragonfly) occupy streams, rivers, and lakes. Their aquatic habitats will not be impacted by the proposed Project, since fiber infrastructure installation in these areas is to occur via use of existing conduit, directional boring, or aerial installation on existing poles via road shoulder access, by hand, or by boat. Several other T&E species listed in Table 4.5.4.1, including the plant species calypso ( Calypso bulbosa ), butterwort ( Pinguicula vulgaris ), and black crowberry ( Empitrum niger ) would not be impacted at all, due to the proposed purchase of existing fiber infrastructure rather than new aerial or underground construction. Aerial construction on existing poles in existing, regularly disturbed ROWs and the use of existing fiber infrastructure, existing underground conduit, and directional boring minimize the Project’s impact on T&E species and their associated habitats. Minor, temporary disturbances associated with underground construction will result in the ground surface being returned to its original grade and stabilized.

Special precautions to minimize impacts to rare species that are known to occur within the road and utility ROW’s and have been identified in consultations with MiDNRE Wildlife Division and MDOT will be implemented. Timing of construction and selection of the installation method for the fiber have been adjusted as needed to limit impacts to known element occurrences. For example, adverse impacts to federally and state threatened Houghton’s goldenrod, which is known to occur within the road ROW along the Project route in Crawford County, will be minimized by timing aerial installation to occur when the plant is dormant and protected by snow cover or by boring beneath the plants if underground construction is necessary. As another example, adverse impacts to federally and state endangered Kirtland’s warbler and its habitat in jack pine stands, which are known to occur within the road ROW along the Project route, will be minimized by timing underground cable installation to occur when the warbler has migrated south out of the region, e.g. August 15 th through May 1st. Construction crews will be made aware of federally and state listed species and their habitats and will implement the protective measures detailed in correspondence with the USFWS field offices and MiDNRE Wildlife Division (see Appendix F). All agency requirements will be adhered to throughout the construction of the Project.

The Project Team received concurrence with these findings and Project clearance from the MiDNRE Wildlife Division on May 3, 2011 and MDOT on June 27, 2011. Refer to Appendix F for MiDNRE and MDOT correspondence.

The No Action Alternative would have no adverse impact on federal and state T&E species and critical habitat resources in Michigan.

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4.5.4.3 Wisconsin Threatened and Endangered Species Table 4.5.4.2 summarizes element occurrences that have the potential to be impacted along the Project Route, including federally and state listed species and unique natural features, by corridor and county, per the WiDNR Office of Energy review letter dated December 15, 2010. Refer to Appendix F for the WiDNR correspondence. This table also summarizes the Project Team’s findings regarding the potential for impacts to each element occurrence in Wisconsin. Important Note : The specific locations and identities of endangered resources included in the Wisconsin Endangered Resources Review are 1) sensitive, 2) not subject to Wisconsin’s Open Records Law, and 3) may not be released or reproduced in any publicly disseminated document. Therefore, if NTIA deems that this document must become public, any reference to a specific species, natural community, or other natural featured derived from the Wisconsin Natural Heritage Inventory Database within the document’s text and agency correspondence must be redacted.

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Table 4.5.4.2 Summary of WiDNR Review for Known Element Occurrences

Corridor / Species /Natural Federal State Proposed Habitat WiDNR Recommendation Adverse Impact? County Community ¥ Status* Status** Action GREEN BAY SPUR No Impact; d oes not occur in West of Peshtigo & southeast of US-41; Underground Road See general maintained & constructed ROW along Alder Thicket N/A N/A minerotrophic wetland community dominated ROW & Urban recommendations below US-41 or downtown Peshtigo & no by tall shrubs, especially speckled alder woody vegetation removal proposed West of Peshtigo & southeast of US -41; No Impact; does not occur in Northern Wet- forested minerotrophic wetland dominated by Underground Road See general maintained & constructed ROW along N/A N/A Mesic Forest northern white-cedar, occuring on rich, neutral ROW & Urban recommendations below US-41 or downtown Peshtigo & no to alkaline peats & mucks woody vegetation removal proposed South side of Marinette Service Alternative; No Impact; does not occur in nutrient-poor sites w/ excessively drained maintained & constructed ROW & no sandy or rocky soils; mature stands dominated See general Northern Dry Forest N/A N/A Urban woody vegetation removal proposed; by jack & red pines a/o Hill's oak; disturbed recommendations below Marinette Service Alternative no longer stands dominated by aspen, red maple, & proposed oaks South and east side of Marinette Service No Impact; not likely to occur in Alternative; interface of land & water along the Great Lakes See general maintained & constructed ROW; N/A N/A margins of Lakes Michigan & Superior, often in Aerial & Urban Beach recommendations below Marinette Service Alternative no longer association w/ sparsely vegetated, semi- proposed stabilized dune systems Marinette No Impact; very old occurrence (1930), Section data not completely available, near Underground Road no suitable habitat in urban areas or Indian cucumber root See general N/A SC Peshtigo & Marinette; rich hardwood or mixed ROW, Aerial, & maintained & constructed ROW along (Medeola virginiana ) recommendations below conifer-hardwood forests Urban US-41, & no woody vegetation removal proposed Not Significant; very old occurrence Section data not completely available, near Northern wild raisin Underground Road (1916), not likely to occur in urban Peshtigo & Marinette; open or brushy See general (Viburnum nudum N/A SC ROW, Aerial, & areas or maintained & constructed wetlands, less commonly on wet forest recommendations below var. cassinoides ) Urban ROW along US-41 & no woody margins mostly near Green Bay vegetation removal proposed Not Significant; very old occurrence Section data not completely available, near Underground Road Yellow screwstem See general (1916) & not likely to occur in urban N/A SC Peshtigo & Marinette; acid ditches & along ROW, Aerial, & (Bartonia virginica ) recommendations below areas or maintained & constructed trails, often in moss mats Urban ROW along US-41 No Impact; no construction equipment Lake-cress Peshtigo River; still waters of lakes, rivers, See general N/A E Urban in rivers/lakes—aerial crossing by (Armoracia lacustris ) estuaries recommendations below hand/boat or bore under Peshtigo River Crinkled hairgrass South side of Marinette Service Alternative; See general No Impact; not likely to occur in N/A SC Urban (Deschampsia pine forests & barrens, mostly near the Great recommendations below maintained & constructed ROW;

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Corridor / Species /Natural Federal State Proposed Habitat WiDNR Recommendation Adverse Impact? County Community ¥ Status* Status** Action flexuosa ) Lakes Marinette Service Alterna tive no longer proposed Not Significant; per USFWS Step -by - Southeast of Peshtigo & west of Marinette; Step Guidance, limit construction as Bald eagle large trees in isolated areas in proximity to Follow USFWS Bald Eagle follows: no activity w/in 330’ of eagle (Haliaeetus N/A SC/P large areas of surface water, large complexes Urban Management Guidelines nest year-round or w/in 660’ of eagle leucocephalus ) of deciduous forest, coniferous forest, wetland, nest from January 1 st to August 1st ; no and shrub communities known nests w/in 660’ of route South of Marinette; supercanopy snags and Not Significant; per USFWS Step -by - dead-topped pines located along lake and Follow USFWS Bald Eagle Step Guidance, limit construction as Osprey (Pandion N/A SC/M stream shoreline, in recent clearcut areas near Urban Management Guidelines; follows: no activity w/in 330’ of osprey haliaetus ) water, in swamp conifer stands, and on snags nest April 1 st through August nest year-round or w/in 660’ of osprey in marshes and bogs nest from April 1 st to September 1 st Trout Creek tributary to Peshtigo River; No Impact; no construction equipment sloughs, lakes, & still-sluggish sections of Bore all perennial waterways Weed shiner in river—aerial crossing by hand/boat or N/A SC medium streams to large rivers w/ sand, mud, Urban from late August to early (Notropis texanus ) bore under waterway from late August clay, silt, detritus, gravel or boulders May to early May substrates Bore all wetlands; locate Not Significant; hire monitor May–July sandy/gravelly soils/fill w/ North & southwest of Peshtigo; wide variety of to identify turtles & nesting habitat; bore soils maps, & reroute Blanding's turtle aquatic habitats--marshes, shallow bays of all wetlands April-October & all Underground Road around potential nesting (Emydoidea N/A T lakes & impoundments, sluggish streams, inundated wetlands November– March ROW & Urban areas OR place exclusion blandingii ) oxbows & other backwaters of rivers, drainage w/in given area; access poles by foot & fencing between May 6 th ditches, & sedge & wet meadows climb manually April-October if can’t and May 20 th and work may access from road shoulder proceed Not Significant; not likely to occur in Four-toed Avoidance measures similar North of Peshtigo; northern & southern downtown Peshtigo or maintained & salamander to those for rare turtles, i.e. N/A SC hardwood forests, conifer swamps, ponds, Urban constructed ROW along US-41; (Hemidactylium bore wetlands & perennial seepage pools & springs implement turtle mitigation measures scutatum ) waterways above Section data not available, southern part of Not Significant; very old occurrence Pygmy shrew county; debris & heavy vegetation in woods, Underground Road (1937), not likely to occur in urban N/A SC None (Sorex hoyi ) clearings, & meadows w/ high grass, drier ROW areas or maintained & constructed areas in cold sphagnum or tamarack bogs ROW along US-41 Bore all perennial waterways, establish bore No Impact; no construction equipment Pygmy snaketail Menominee River; small-large, clean, fast- pits 50 ft from waterway, & in streams—aerial crossing by (Ophiogomphus SOC T flowing warm streams w/ gravel-sand Urban implement proper erosion hand/boat or bore under perennial howei ) substrates control measures to prevent waterways w/ 50ft min. buffer sedimentation

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Corridor / Species /Natural Federal State Proposed Habitat WiDNR Recommendation Adverse Impact? County Community ¥ Status* Status** Action Not Significant; not likely to be Gray wolf ( Canis Aerial & encountered in disturbed ROWs, E SC/FL Northern forested areas None € lupus ) Underground especially given how quickly work will move through any given area Not Significant; not likely to be Canada lynx ( Lynx Aerial & encountered in disturbed ROWs, T SC/P Northern forested areas None € canadensis ) Underground especially given how quickly work will move through any given area Kirtland’s Warbler Large homogenous stands of jack pine w/ No Impact; suitable habitat does not E SC/FL N/A None € (Dendroica kirtlandii ) scattered small openings occur along the route Piping plover Shorelines of lakes/rivers, sandy beaches No Impact; suitable habitat does not E E N/A None € (Charadrius melodus ) where vegetation is sparse occur along the route No Impact; does not occur in East of US-41 in northern portion of county; Aerial & See general maintained & constructed ROW along Alder Thicket N/A N/A minerotrophic wetland community dominated Underground Road recommendations below US-41/141 & no woody vegetation by tall shrubs, especially speckled alder ROW removal proposed East of US -41 in northern portion of county; Aerial & No Impact; does not occur in maintained Northern Wet-Mesic forested minerotrophic wetland dominated by See general recommendations N/A N/A Underground Road & constructed ROW along US-41/141 & Forest northern white-cedar, occurring on rich, neutral below ROW no woody vegetation removal proposed to alkaline peats & mucks Not Significant; not likely to occur in Northern wild-raisin Southwest of Oconto; open or brushy Underground Road See general urban areas or cleared & constructed (Viburnum nudum N/A SC wetlands, less commonly on wet forest ROW & Aerial recommendations below ROW along US-41/141 & no woody var. cassinoides ) margins mostly near Green Bay vegetation removal proposed Crinkled hairgrass Actually in Brown County to the south; pine See general (Deschampsia N/A SC See Below See Below forests & barrens, mostly near the Great Lakes recommendations below Oconto flexuosa ) No Impact; no suitable habitat in urban Indian cucumber-root South of Pensaukee; rich hardwood or mixed Underground Road See general areas or cleared & constructed ROW N/A SC (Medeola virginiana ) conifer-hardwood forests ROW & Aerial recommendations below along US-41/141 & no woody vegetation removal proposed Uplands near Brookside Creek northeast of Not Significant; per USFWS Step-by- Abrams; supercanopy snags and dead-topped Follow USFWS Bald Eagle Step Guidance, limit construction as Osprey (Pandion pines located along lake and stream shoreline, N/A SC/M Aerial Management Guidelines; follows: no activity w/in 330’ of osprey haliaetus ) in recent clearcut areas near water, in swamp nest April 1 st through August nest year-round or w/in 660’ of osprey conifer stands, and on snags in marshes and nest from April 1 st to September 1 st bogs Section data not ava ilable, in vicinity of Where work to occur outside No Impact; no construction proposed Black-crowned night- Oconto; freshwater wetlands dominated by Underground Road of existing Road ROW, in/near suitable habitat, work to be heron (Nycticorax N/A SC/M bulrush and cattail with small groves of alder, ROW & Aerial complete cable installation & completed w/in Road ROW, & no nycticorax ) willow, or other brush vegetation clearing from vegetation clearing proposed

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Corridor / Species /Natural Federal State Proposed Habitat WiDNR Recommendation Adverse Impact? County Community ¥ Status* Status** Action September 1 st to May 15 th Northeast of Pensaukee & east of US -41 in Complete work in or No Impact; no construction proposed wetland mitigation; seasonally or permanently Red-necked grebe adjacent to wetland & open in/near suitable habitat, work to be N/A E flooded wetlands with extensive beds of Aerial (Podiceps grisegena ) water habitat from completed w/in Road ROW, & no aquatic plants & large beds of softstem September to early May vegetation clearing proposed bulrush in open country Complete work adjacent to Mouth of the Pensaukee River in Green Bay Green Bay w/in marshes, No Impact; no construction proposed Piping plover Shores Wildlife Area; shorelines of Underground Road beaches, or shorelines from near suitable habitat w/in marshes, E E (Charadrius melodus ) lakes/rivers, sandy beaches where vegetation ROW & Aerial October to early-May to beaches, or shorelines adjacent to is sparse prevent disturbance during Green Bay in Oconto Co. the breeding season Near shoreline & unnamed stream north of Not Significant; per USFWS Step -by - Oconto in Green Bay Shores Wildlife Area; Step Guidance, limit construction as Bald eagle large trees in isolated areas in proximity to Underground Road Follow USFWS Bald Eagle follows: no activity w/in 330’ of eagle (Haliaeetus N/A SC/P large areas of surface water, large complexes ROW Management Guidelines nest year-round or w/in 660’ of eagle leucocephalus ) of deciduous forest, coniferous forest, wetland, nest from January 1 st to August 1 st ; no and shrub communities known nests w/in 660’ of route Complete work adjacent to Green Bay w/in marshes, No Impact; no construction proposed South Oconto Marsh; undeveloped sand Caspian tern (Sterna Underground Road beaches, or shorelines from near suitable habitat w/in marshes, N/A E beaches & islands along the Great Lakes, caspia ) ROW & Aerial October to early-May to beaches, or shorelines adjacent to typically on sandy or gravelly coastal islands prevent disturbance during Green Bay in Oconto Co. the breeding season Complete work adjacent to Green Bay w/in marshes, No Impact; no construction proposed South Oconto Marsh; Great Lakes' shorelines, Common tern (Sterna Underground Road beaches, or shorelines from near suitable habitat w/in marshes, N/A E bays, sand bars of large lakes and rivers, hirundo ) ROW & Aerial October to early-May to beaches, or shorelines adjacent to sandy or rocky coastal islands, and marshes prevent disturbance during Green Bay in Oconto Co. the breeding season Pensaukee River & unnamed tributary & No Impact; no construction equipment in Greater redhorse Bore all perennial waterways Brookside Creek in Green Bay Shores Wildlife Underground Road river—aerial crossing by hand/boat or (Moxostoma N/A T from late August to early Area; clear water of medium-large rivers w/ ROW & Aerial bore under waterways from July 1 st – April valenciennesi ) May sand, gravel, or boulder substrates 30 th Tibbet Creek, Little Suamico River, & No Impact; no construction equipment in Redfin shiner Bore all perennial waterways unnamed tributary; turbid waters of pools in river—aerial crossing by hand/boat or (Lythrurus N/A T Aerial from late August to early low-gradient streams w/ boulder, cobble, sand, bore under waterways from August 16 th – umbratilis ) May silt or detritus substrates May 31 st Lake Michigan, Pensaukee River, & unnamed Aerial & Bore all perennial waterways Not Significant; access poles by foot & Wood turtle N/A T stream in Green Bay Shores Wildlife Area & Underground Road & complete work w/in 300 m climb manually April-October if can’t (Glyptemys insculpta ) Oconto River; 6 other waterways have ROW of these waterways from access from road shoulder; bore

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Corridor / Species /Natural Federal State Proposed Habitat WiDNR Recommendation Adverse Impact? County Community ¥ Status* Status** Action potential habitat; clean rivers & streams w/ November 1 st to April 8 th ; waterways & maintain a 200ft min. moderate-fast flows & adjacent riparian report any sightings buffer of waterway year-round & hire wetlands & upland deciduous forests monitor if work conducted April 8- November 1 Bore all wetlands; locate Not Significant; hire monitor May–July Morgan Marsh in Oconto Co. Forest & near sandy/gravelly soils/fill w/ to identify turtles & nesting habitat; bore Oconto River; wide variety of aquatic habitats-- soils maps, & reroute Blanding's turtle all wetlands April-October & all marshes, shallow bays of lakes & Underground Road around potential nesting (Emydoidea N/A T inundated wetlands November– March impoundments, sluggish streams, oxbows & ROW & Aerial areas OR place exclusion blandingii ) w/in given area; access poles by foot & other backwaters of rivers, drainage ditches, & fencing between May 6 th climb manually April-October if can’t sedge & wet meadows and May 20 th and work may access from road shoulder proceed Not Significant ; no construction Avoidance measures similar American bullfrog North and south of downtown Oconto; any equipment in river/lakes—aerial Underground Road to those for rare turtles, i.e. (Lithobates N/A SC permanent body of water--lakes, ponds, rivers, crossing by hand/boat or bore under ROW & Aerial bore wetlands & perennial catesbeianus ) and creeks waterways; implement above turtle waterways protection measures Section data not available, northern part of Not Significant; very old occurrence Pygmy shrew county; debris & heavy vegetation in woods, Underground Road (1937), not likely to occur in urban N/A SC None (Sorex hoyi ) clearings, & meadows w/ high grass, drier ROW & Aerial areas or maintained & constructed areas in cold sphagnum or tamarack bogs ROW along US-41/141 Bore all perennial No Impact; no construction equipment waterways, establish bore in streams—aerial crossing by Slippershell mussel Little Suamico River; small to medium-sized pits 50 ft from waterway, & hand/boat or bore under waterways; (Alasmidonta N/A T streams w/ flowing hard water, sand or gravel Aerial implement proper erosion implement redfin shiner protective viridis ) bottoms control measures to prevent measures above & set bore pits back a sedimentation minimum of 50ft Survey for host plant in Not Significant ; no construction wetlands in Oconto Co. not proposed in/near suitable habitat, work Swamp metalmark w/in same section as route; fens & nearby wet Underground Road scheduled for boring or to be completed w/in Road ROW; (Calephelis N/A E meadows, marshes, or tamarack bogs; host ROW & Aerial where boring pits/other implement above Blanding’s turtle muticum ) plant is swamp thistle, Cirsium muticum facilities may be placed in protective measures (bore all wetlands the wetland year-round in given Township/Range) Not Significant; not likely to be Gray wolf ( Canis Aerial & encountered in disturbed ROWs, E SC/FL Northern forested areas None € lupus ) Underground especially given how quickly work will move through any given area Non -essential experimental population that is Not Significant; highly unlikely that Whooping crane raised at the Necedah National Wildlife Refuge whooping cranes will use the habitats NEP SC/FL N/A None € (Grus americana ) over 100 miles west of the proposed project within road and utility ROW’s for feeding route or nesting

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Corridor / Species /Natural Federal State Proposed Habitat WiDNR Recommendation Adverse Impact? County Community ¥ Status* Status** Action Karner blue butterfly No Impact; suitable habitat does not (Lycaeides melissa E SC/FL Oak & oak-pine savanna or barrens N/A None € occur along the route samuelis ) Not Significant; high -medium quality Northwest of Green Bay associated w/ Duck Bore under medium to high examples not likely to occur in Creek; open, marsh, lake, riverine & estuarine Underground Road quality communities; See Emergent Marsh N/A N/A maintained & constructed ROW along communities w/ permanent standing water ROW general recommendations US-41/141/I-43; cross Duck Creek dominated by robust emergent macrophytes below aerially or bore Northwest of Green Bay associated w/ Duck Not Significant; high -medium quality Bore under medium to high Creek; wetland community dominated by tall examples not likely to occur in Underground Road quality communities; See Shrub-Carr N/A N/A shrubs like red-osier & silky dogwood, maintained & constructed ROW along ROW & Urban general recommendations meadowsweet, & willows & Canada bluejoint US-41/141/I-43; cross Duck Creek below grass aerially or bore No Impact; very old occurrence (1881) Crinkled hairgrass Section data not available, northern part of Underground Road See general & no suitable habitat in urban areas or (Deschampsia N/A SC county; pine forests & barrens, mostly near the ROW & Aerial recommendations below maintained & constructed ROW along flexuosa ) Great Lakes US-41/141 No Impact; very old occurrence (1880) Section data not available, central part of Northern bog sedge Underground Road See general & no construction proposed in/near N/A SC county near Green Bay; cold, wet neutral to (Carex gynocrates ) ROW & Urban recommendations below suitable habitat, work to be completed calcareous conifer swamps w/in Road ROW No Impact; no suitable habitat in urban Brown North of Suamico east & west of US-41/141; Indian cucumber-root See general areas or maintained & constructed N/A SC rich hardwood or mixed conifer-hardwood Aerial (Medeola virginiana ) recommendations below ROW along US-41/141 & no woody forests vegetation removal proposed Atkinson Marsh associated w/ Fox River & Seaside crowfoot Lake Michigan; sandy or muddy shores & Not Significant; not likely to occur in See general (Ranunculus N/A T marshes, ditches & harbors along Lake Urban urban areas or maintained & recommendations below cymbalaria ) Michigan, & salted roadsides near the city of constructed ROW along I-43 Superior Blunt -lobe grape -fern Not Significant; not likely to occur in North of Suamico & east of US-41/141; moist, See general (Botrychium N/A SC Aerial urban areas or maintained & often acid depressions in damp open forests recommendations below oneidense ) constructed ROW along US-41/141 North of Suamico & east of US -41/141; mesic No Impact; no construction proposed Male fern (Dryopteris See general N/A SC hemlock-hardwood forests, often on rocky Aerial in/near suitable habitat, work to be filix-mas ) recommendations below basaltic slopes completed w/in Road ROW East of US -41/141 & Suamico; moist prairies, No Impact; very old occurrence (1883) Pale green orchid sedge meadows, shrub-carrs, alder thickets, Underground Road See general & not likely to occur in urban areas or (Platanthera flava N/A T fen & bog mats, conifer swamp margins, & ROW & Aerial recommendations below maintained & constructed ROW along var. herbiola ) ditches US-41/141 Forster's tern (Sterna N/A E Duck Creek Delta in Green Bay Shores Underground Road Complete work adjacent to No Impact; no construction proposed

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Corridor / Species /Natural Federal State Proposed Habitat WiDNR Recommendation Adverse Impact? County Community ¥ Status* Status** Action forsteri ) Wildlife Area & Bayport Industrial Tract just ROW & Urban Green Bay w/in marshes, near suitable habitat adjacent to Green west of Fox River mouth; large semi- beaches, or shorelines from Bay in Brown Co., work to be restricted permanent & permanently flooded wetlands October to early May to to the opposite side of the expressway that support extensive growths of cattail & prevent disturbance during from potential wetland habitat; if route is hardstem bulrush the breeding season realigned adjacent to emergent marsh, then limit construction to non-nesting season from October to early May No Impact; no construction proposed near suitable habitat adjacent to Green Where work to occur outside Duck Creek Delta in Green Bay Shores Bay in Brown Co., work to be restricted of existing Road ROW, Common moorhen Wildlife Area; shallow marshes, especially Underground Road to the opposite side of the expressway N/A SC/M complete cable installation & (Gallinula chloropus ) where shallow lakes are rimmed with ample ROW & Urban from potential wetland habitat; if route is vegetation clearing from marsh vegetation realigned adjacent to emergent marsh, September 1 st to May 15 th then limit construction to non-nesting season from October to early May Nest box on power plant near Fox River; Peregrine falcon relatively inaccessible rock ledges on the sides Underground Road No Impact; no construction proposed at N/A E Impacts are unlikely (Falco peregrinus ) of steep bluffs & ledges on high-rise buildings ROW & Aerial the power plant in urban areas Complete work adjacent w/in 1 mile of route but not in same section; no to Green Bay w/in Township/Range/Section data provided; marshes, beaches, or No Impact; no construction Caspian tern ( Sterna Underground Road N/A E undeveloped sand beaches & islands along shorelines from October proposed near suitable habitat caspia ) ROW & Urban the Great Lakes, typically on sandy or gravelly to early-May to prevent adjacent to Green Bay in Brown Co. coastal islands disturbance during the breeding season Fox River, Suamico River, & un named stream No Impact; no construction equipment in Longear sunfish Bore all perennial waterways north of Suamico; clear, shallow, moderately river—aerial crossing by hand/boat or (Lepomis N/A T Aerial & Urban from late August to early warm, still waters of streams & occasionally in bore under waterways from August 1 st – megalotis ) May lakes May 20 th No Impact; no construction equipment in Redfin shiner Suamico River; turbid waters of pools in low- Bore all perennial waterways river—aerial crossing by hand/boat or (Lythrurus N/A T gradient streams w/ boulder, cobble, sand, silt Aerial from late August to early bore under waterways from August 16 th – umbratilis ) or detritus substrates May May 31 st Not Significant; access poles by foot & 3 unnamed streams in Sensiba State Wildlife Bore all perennial waterways climb manually April-October if can’t Area & Green Bay West Shores State Wildlife Underground Road & complete work w/in 300 m access from road shoulder; bore Wood turtle Area, & Duck Creek; 2 other waterways have N/A T ROW, Aerial, & of these waterways from waterways & maintain a 200ft min. (Glyptemys insculpta ) potential habitat; clean rivers & streams w/ Urban November 1 st to April 8 th ; buffer of waterway year-round & hire moderate-fast flows & adjacent riparian report any sightings monitor if work conducted April 8- wetlands & upland deciduous forests November 1

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Corridor / Species /Natural Federal State Proposed Habitat WiDNR Recommendation Adverse Impact? County Community ¥ Status* Status** Action Bore all wetlands; locate Long Tail Point southwest of Suamico & Brown Not Significant; hire monitor May–July sandy/gravelly soils/fill w/ Co. Reforestation Camp northwest of to identify turtles & nesting habitat; bore soils maps, & reroute Blanding's turtle Suamico; wide variety of aquatic habitats-- all wetlands April-October & all Underground Road around potential nesting (Emydoidea N/A T marshes, shallow bays of lakes & inundated wetlands November– March ROW & Aerial areas OR place exclusion blandingii ) impoundments, sluggish streams, oxbows & w/in given area; access poles by foot & fencing between May 6 th other backwaters of rivers, drainage ditches, & climb manually April-October if can’t and May 20 th and work may sedge & wet meadows access from road shoulder proceed No Impact; no construction proposed East of US-41/141 and south of Suamico; in/near suitable habitat, work to be Mulberry wing marshes & sedge meadows; host plants are Underground Road Bore under medium to high completed w/in Road ROW w/ very low (Poanes N/A SC narrow-leaved sedges including Carex stricta ROW quality wetland communities quality wetlands, if any, which will be massasoit ) & possibly C. aquatilis protected by Blanding’s & wood turtle protective measures above No Impact; no construction proposed in/near suitable habitat, work to be Broad-winged East of US-41/141 and south of Suamico; Underground Road Bore under medium to high completed w/in Road ROW w/ very low skipper ( Poanes N/A SC wetland obligate--sedge marsh/swamp w/ ROW quality wetland communities quality wetlands, if any, which will be viator ) Carex lacustris, C. aquatilis, & C. lasiocarpa protected by Blanding’s & wood turtle protective measures above Dwarf lake iris ( Iris Near Great Lakes shoreline on sand/thin soils No Impact; suitable habitat does not T T N/A None € lacustris ) over calcareous gravel/bedrock occur along the route NORTHERN Pothole Lakes south of US -2 at eastern end of route in Spread Eagle Barrens State Natural No Impact; does not occur in Lake—deep, soft Area; Lake w/ no inlet or outlet, fed by Underground Road See general recommendations maintained & constructed ROW along N/A N/A seepage precipitation, runoff, & groundwater from ROW & Aerial below US-2 & no construction equipment in immediate drainage area; thermally stratified & lakes experience seasonal turnover twice a year Spread Eagle Barrens & New Barrens south of US-2 at eastern end of route in Spread Eagle Barrens State Natural Area & Pine-Popple No Impact; does not occur in urban Florence Underground Road See general recommendations Bracken Grassland N/A N/A Wild Rivers; upland sites w/ infertile sandy areas or maintained & constructed ROW & Aerial below soils dominated by bracken fern, Pennsylvania ROW along US-2 sedge, Kalm's bromegrass, & Canada bluegrass Menominee River/Twin Falls Flowage at Not Significant; per USFWS Step -by - Bald eagle eastern end of route; large trees in isolated Step Guidance, limit construction as Underground Road Follow USFWS Bald Eagle (Haliaeetus N/A SC/P areas in proximity to large areas of surface follows: no activity w/in 330’ of eagle ROW & Aerial Management Guidelines leucocephalus ) water, large complexes of deciduous forest, nest year-round or w/in 660’ of eagle coniferous forest, wetland, and shrub nest from January 1 st to August 1 st ; no

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Corridor / Species /Natural Federal State Proposed Habitat WiDNR Recommendation Adverse Impact? County Community ¥ Status* Status** Action communities known ne sts w/in 660’ of route Where work to occur outsid e Upland sandpiper Spread Eagle Barrens in State Natural Area; of existing Road ROW, Not Significant; work to be completed Underground Road (Bartramia N/A SC/M tallgrass prairies, sedge meadows, unmowed complete cable installation & w/in Road ROW & no vegetation ROW longicauda ) alfalfa/timothy fields and scattered woodlands vegetation clearing from clearing proposed September 1 st to May 15 th Bore all perennial waterways Not Significant; bore Deadman Creek, if Lake Anna & Deadman Creek; 2 other & complete work w/in 300 m encountered, & other waterways noted; Wood turtle waterways have potential habitat; clean rivers Underground Road N/A T of these waterways from maintain a 200ft min. buffer of waterway (Glyptemys insculpta ) & streams w/ moderate-fast flows & adjacent ROW November 1 st to April 8 th ; year-round; hire monitor if work riparian wetlands & upland deciduous forests report any sightings conducted April 8-November 1 Section data not available; Eagle River - Don’t disturb or remove American marten No Impact; no construction equipment Florence District in Chequamegon-Nicolet Underground Road trees, snags, & large woody (Martes N/A E in woodlands—no woody vegetation National Forest; mature, dense conifer, mixed ROW debris where >50% canopy americana ) removal proposed conifer-hardwood, & hardwood forests cover exists No Impact; no construction equipment Elktoe Menominee River/Twin Falls Flowage; various- in river—bore under waterway; Underground Road None specifically; bore (Alasmidonta N/A SC sized stable streams w/ flowing water & sand, implement wood turtle protective ROW under perennial waterways marginata ) gravel or rock substrates measures above (set bore pits back a minimum of 200ft) Florence Barrens; pine barrens, oak savanna, Leonard's skipper & dry prairies; host plants are little bluestem None specifically; avoid host Not Significant; not likely to occur in Underground Road (Hesperia N/A SC (Schizachyrium scoparium ), blue grama plants in Great Lakes urban areas or maintained & ROW leonardus ) (Bouteloua gracilis ), & panic grass ( Panicum Barrens & Pine Barrens constructed ROW along US-2 spp.) Not Significant; not likely to be Gray wolf ( Canis Aerial & encountered in disturbed ROWs, E SC/FL Northern forested areas None € lupus ) Underground especially given how quickly work will move through any given area Not Significant; not likely to b e Canada lynx ( Lynx Aerial & encountered in disturbed ROWs, T SC/P Northern forested areas None € canadensis ) Underground especially given how quickly work will move through any given area DULUTH SPUR No Impact; very old occurrence (1917) & White adder's-mouth Section data not available; south of Saxton & Underground Road See general recommendations no suitable habitat in maintained & (Malaxis monophyllos N/A SC US-2 in Iron County Forest; neutral or ROW & Aerial below constructed ROW along US-2; no woody var. brachypoda ) calcareous conifer or black ash swamps vegetation removal proposed

Little goblin Section data not available; south of US -2 & No Impact; very old occurrence (1938) & Iron Underground Road See general recommendations moonwort N/A E west of Ironwood in Iron County Forest; no suitable habitat in urban areas or ROW & Aerial below (Botrychium mormo ) mature second-growth to old-growth hardwood maintained & constructed ROW along US-

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Corridor / Species /Natural Federal State Proposed Habitat WiDNR Recommendation Adverse Impact? County Community ¥ Status* Status** Action forests w/ hemlock, preferring silt -capped 2; no woody vegetation removal proposed drumlins Section data not available; south of Saxton & No Impact; very old occurrence (1940) & US-2 in Iron County Forest & north of US-2 Braun's holly-fern Underground Road See general recommendations no suitable habitat in maintained & N/A T east of Birch; ravine bottoms in rich hardwoods (Polystichum braunii ) ROW & Aerial below constructed ROW along US-2; no woody or mixed conifer hardwoods, often in areas of vegetation removal proposed cold-air drainage Oregon woodsia Section data not available; south of US -2 & No Impact; very old occurrence (1929) & (tetraploid; Woodsia west of Ironwood in Iron County Forest; moist, Underground Road See general recommendations no suitable habitat in urban areas or N/A SC oregana ssp. shaded (occasionally exposed) basaltic or less ROW & Aerial below maintained & constructed ROW along US- cathcartiana ) commonly dolomite cliffs 2; no construction equipment on cliffs South of US -2 northwest of Ironwood; range of Not Significant; not likely to occur in urban Pale sedge (Carex Underground Road See general recommendations N/A SC moist sites--peaty meadows, borders of mesic areas or maintained & constructed ROW pallescens ) ROW & Aerial below woods, fields & clearings, cedar swamps along US-2 No Impact; not likely to occur in urban Large-leaved South of US-2 northwest of Ironwood; dry to Underground Road See general recommendations areas or maintained & constructed ROW sandwort (Moehringia N/A E partly shaded cliffs in the Penokee Range ROW & Aerial below along US-2; no construction equipment on macrophylla ) cliffs South of US -2 & Cedar in Edgewood Black-throated blue Cemetery; mature lowland deciduous forests & No Impact; no suitable habitat in warbler ( Dendroica N/A T large upland blocks of mature dry-mesic to Aerial None maintained & constructed ROW along US- caerulescens ) mesic forests; nest 20-60 feet above ground 2; no woody vegetation removal proposed on a horizontal limb Pervasive along Duluth Spur; large contiguous Not Significant; not likely to be forest, remote areas w/ high percentage of Impacts are unlikely; inform Gray Wolf ( Canis Underground Road encountered in disturbed ROWs, E SC/FL forest & other wildlands (> 90% wildlands), low contractors of species & report lupus ) ROW & Aerial especially given how quickly work will densities of roads, low human densities, & few any sightings move through any given area farms Lepidostomatid No Impact; no construction equipment in West Fork Montreal River; small None specifically; bore under caddisfly N/A SC Aerial waterway—aerial crossing by hand/boat springs/streams perennial waterways (Lepidostoma libum ) or bore under waterway w/ 50ft min. buffer Not Significant; not likely to be Canada lynx ( Lynx Aerial & encountered in disturbed ROWs, T SC/P Northern forested areas None € canadensis ) Underground especially given how quickly work will move through any given area Fish Creek Sloughs in South Shore Lake Superior Fish & Wildlife Area west of Ashland No Impact; does not occur in downtown along Chequamegon Bay shoreline; open, See general recommendations Ashland Emergent Marsh N/A N/A Urban Ashland or maintained & constructed marsh, lake, riverine & estuarine communities below ROW along Hwy 137 w/ permanent standing water dominated by robust emergent macrophytes

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Corridor / Species /Natural Federal State Proposed Habitat WiDNR Recommendation Adverse Impact? County Community ¥ Status* Status** Action Kakagon Sloughs on Bad River Indian Reservation northeast of Odanah; acidic, low- nutrient peatland dominated by sphagnum No Impact; does not occur in urban areas Underground Road See general recommendations Open Bog N/A N/A mosses; receives nutrients only from or maintained & constructed ROW along ROW below precipitation & limited internal runoff--isolated US-2 from influence of nutrient-enriched groundwater Kakagon Sloughs at mouths of Kakagon & Bad Rivers on Bad River Indian Reservation No Impact; does not occur in urban areas Emergent Marsh- Underground Road See general recommendations N/A N/A north & northwest of Odanah adjacent to Lake or maintained & constructed ROW along Wild Rice ROW & Urban below Superior; Emergent aquatic system w/ wild rice US-2 & Co. Hwy A as dominant macrophyte Kakagon Sloughs between mouths of Kakagon & Bad Rivers on Bad River Indian No Impact; does not occur in urban areas Reservation north of Odanah adjacent to Lake Underground Road See general recommendations or maintained & constructed ROW along Northern Wet Forest N/A N/A Superior; weakly minerotrophic, conifer- ROW below US-2& Co. Hwy A; no woody vegetation dominated, acid peatlands located mostly removal proposed north of the Tension Zone; dominated by black spruce & tamarack No Impact; very old o ccurrence (1896) & Section data not available; in the vicinity of no suitable habitat in urban areas or Braun's holly-fern Birch in northeast part of county; ravine Underground Road See general recommendations N/A T maintained & constructed ROW along US- (Polystichum braunii ) bottoms in rich hardwoods or mixed conifer ROW & Urban below 2 & Co. Hwy. A; not likely to occur in hardwoods, often in areas of cold-air drainage maintained utility ROWs near Odanah No Impact; very old occurrence (1917) & Large roundleaf Section data not available; south of Ashland in See general recommendations no suitable habitat in urban areas or orchid (Platanthera N/A SC vicinity of White River; moist hardwood or Urban below maintained & constructed ROW along US- ororbiculata ) mixed conifer-hardwood forests 2 & Hwy. 137 Section data not available; in vicinity of No Impact; very old occurrence (1917) & Small yellow water Washburn, Ashland, & White River; in cold See general recommendations no suitable habitat in urban areas or crowfoot N/A E Urban brooks and springs, shallow water and muddy below maintained & constructed ROW along US- (Ranunculus gmelinii ) shores of ditches, streams, & lakes 2 Section data not available; south of Ashland in No Impact; very old occurrence (1917) & Northern black vicinity of White River; cold, neutral to See general recommendations no suitable habitat in urban areas or currant (Ribes N/A SC Urban calcareous conifer swamps & algific talus below maintained & constructed ROW along US- hudsonianum ) slopes 2 & Hwy. 137 Fish Creek Sloughs in South Shore Lake No Impact; no construction equipment on Marsh willow-herb Superior Fish & Wildlife Area west of Ashland See general recommendations bog/fen mats; no suitable habitat in N/A SC Urban (Epilobium palustre ) along Chequamegon Bay shoreline; bog and below downtown Ashland or maintained & fen mats constructed ROW along Hwy. 137 Round -leaved orchis N/A T Near Kakagon River on Bad River Indian Underground Road See general recommendations No Impact; very old occurrence (1940) &

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Corridor / Species /Natural Federal State Proposed Habitat WiDNR Recommendation Adverse Impact? County Community ¥ Status* Status** Action (Amerorchis Reservation; cold, springy mixed conifer ROW below no suitable habitat in urban areas or rotundifolia ) swamps maintained & constructed ROW along US- 2 & Co. Hwy. A; not likely to occur in maintained utility ROWs near Odanah No Impact; very old occurrence (1931) & Assiniboine sedge no suitable habitat in urban areas or Near White River on Bad River Indian Underground Road See general recommendations (Carex N/A SC maintained & constructed ROW along US- Reservation; rich alluvial terraces along rivers ROW below assiniboinensis ) 2 & Co. Hwy. A; not likely to occur in maintained utility ROWs near Odanah Just west of county line in Bayfield County in Fish Creek Sloughs in South Shore Lake Where work to occur outside of Superior Fish & Wildlife Area west of Ashland No Impact; no suitable habitat in existing Road ROW, complete Cape may warbler along Chequamegon Bay shoreline; somewhat maintained & constructed ROW along N/A SC/M Urban cable installation & vegetation (Dendroica tigrina ) open coniferous forests of spruce, balsam fir, Hwy. 137; no woody vegetation removal clearing from September 1 st to cedar, & tamarack; nests usually placed near proposed May 15 th top of crown of spruce or fir trees & near the main stem Just west of county line in Bayfield County in Where work to occur outside o f No Impact; no construction proposed American bittern Fish Creek Sloughs in South Shore Lake existing Road ROW, complete in/near suitable habitat, work to be (Botaurus N/A SC/M Superior Fish & Wildlife Area west of Ashland Urban cable installation & vegetation completed w/in Road ROW, & no lentiginosus ) along Chequamegon Bay shoreline; dense clearing from September 1 st to vegetation clearing proposed freshwater marshes & extensive wet meadows May 15 th Complete work adjacent to Lake Superior w/in marshes, Township/Range/Section data not provided; No Impact; no construction proposed Black tern Underground Road beaches, or shorelines from N/A SC/M large shallow marshes w/ abundant vegetation near suitable habitat adjacent to Lake (Chlidonias niger ) ROW & Urban October to early-May to adjacent to open water Superior in Ashland Co. prevent disturbance during the breeding season Complete work adjacent to Township/Range/Section data not provided; Lake Superior w/in marshes, No Impact; no construction proposed near Common tern ( Sterna Great Lakes' shorelines, bays, sand bars of Underground Road beaches, or shorelines from N/A E suitable habitat adjacent to Lake Superior hirundo ) large lakes and rivers, sandy or rocky coastal ROW & Urban October to early-May to in Ashland Co. islands, & marshes prevent disturbance during the breeding season Ashland Ore Dock; relatively inaccessible rock Peregrine falcon No Impact; no construction proposed w/in N/A E ledges on the sides of steep bluffs & ledges on Urban Impacts are unlikely (Falco peregrinus ) suitable habitat or near Ashland Ore Dock high-rise buildings in urban areas Denomie Creek on Bad River Indian Bore all perennial waterways Not Significant; access poles by foot & Reservation; 4 other waterways have potential & complete work w/in 300 m climb manually April-October if can’t Wood turtle Underground Road N/A T habitat; clean rivers & streams w/ moderate- of these waterways from access from road shoulder; bore (Glyptemys insculpta ) ROW & Urban fast flows & adjacent riparian wetlands & November 1 st to April 8 th ; waterways & maintain a 200ft min. upland deciduous forests report any sightings buffer of waterway year-round & hire

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Corridor / Species /Natural Federal State Proposed Habitat WiDNR Recommendation Adverse Impact? County Community ¥ Status* Status** Action monitor if work conducted April 8 - November 1 Pervasive along Duluth Spur; large contiguous Not Significant; not likely to be forest, remote areas w/ high percentage of Impacts are unlikely; inform Gray Wolf (Canis Underground Road encountered in disturbed ROWs, E SC/FL forest & other wildlands (> 90% wildlands), low contractors of species & report lupus ) ROW & Urban especially given how quickly work will densities of roads, low human densities, & few any sightings move through any given area farms Predaceous diving Bay City Creek south of downtown Ashland & No Impact; no construction equipment in None specifically; bore under beetle ( Hydroporus N/A SC Hwy 137; small-medium sized streams, Urban waterway—aerial crossing by hand/boat perennial waterways vittatus ) adjacent pond & spring ponds or bore under waterway w/ 50ft min. buffer Not Significant; not likely to be Canada lynx ( Lynx Aerial & encountered in disturbed ROWs, T SC/P Northern forested areas None € canadensis ) Underground especially given how quickly work will move through any given area Piping plo ver Shorelines of lakes/rivers, sandy beaches No Impact; suitable habitat does not E E N/A None € (Charadrius melodus ) where vegetation is sparse occur along the route Fish Creek Sloughs in South Shore Lake Superior Fish & Wildlife Area west of Ashland Bore under medium to high No Impact; does not occur in downtown along Chequamegon Bay shoreline; open, quality communities; See Emergent Marsh N/A N/A Urban Ashland or maintained & constructed marsh, lake, riverine & estuarine communities general recommendations ROW along Hwy 137 w/ permanent standing water dominated by below robust emergent macrophytes Bass Lake Bog in Bayfield County Forest west Bore under medium to high No Impact; does not occur in maintained of Iron River & south of US-2; Lake Underground Road quality communities; See Lake—Soft Bog N/A N/A & constructed ROW along US-2; no surrounded by acidic, low-nutrient peatland ROW general recommendations construction equipment in lakes dominated by sphagnum mosses below Associated w/ Bass Lake Bog in Bayfield County Forest west of Iron River & south of Bore under medium to high No Impact; does not occur in maintained Bayfield US-2; weakly minerotrophic, conifer- Underground Road quality communities; See Northern Wet Forest N/A N/A & constructed ROW along US-2; no dominated, acid peatlands located mostly ROW general recommendations woody vegetation removal north of the Tension Zone; dominated by black below spruce & tamarack Section data not available; railroad ballast in Not Significant; very old occurrence Wild licorice Bayfield County Forest; moist prairies & other Underground Road See general recommendations (1923); not likely to occur in urban areas N/A SC (Glycyrrhiza lepidota ) grasslands, streambanks, naturalized on ROW below or maintained & constructed ROW along cinders of railroads & other disturbed areas US-2 Large roundleaf Buck Lake Esker in Chequamegon -Nicolet No Impact; no suitable habitat in urban Underground Road See general recommendations orchid (Platanthera N/A SC National Forest; moist hardwood or mixed areas or maintained & constructed ROW ROW below orbiculata ) conifer-hardwood forests along US-2; no woody vegetation removal Small yellow water Section data not available; in vicinity of See general recommendations No Impact; very old occurrence (1917) & N/A E Urban crowfoot Washburn, Ashland, & White River mostly in below no suitable habitat in urban areas or

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Corridor / Species /Natural Federal State Proposed Habitat WiDNR Recommendation Adverse Impact? County Community ¥ Status* Status** Action (Ranunculus gmelinii ) Ashland Co.; in cold brooks and springs, maintain ed & constructed ROW along US - shallow water and muddy shores of ditches, 2 & Hwy 137 streams, & lakes Large -flowered South of Iron River & US-2 in vicinity of Co. No Impact; no suitable habitat in urban ground-cherry Underground Road See general recommendations N/A SC Hwy. H; mostly in recently burned moist to dry areas or maintained & constructed ROW (Leucophysalis ROW below forests, also gravel bars of large rivers along US-2 grandiflora ) Section data not available; in Ashland Co. No Impact; very old occurrence (1917) & Northern black south of Ashland in vicinity of White River, See general recommendations no suitable habitat in urban areas or currant ( Ribes N/A SC Urban neutral to calcareous conifer swamps & algific below maintained & constructed ROW along US- hudsonianum ) talus slopes 2 & Hwy. 137 Ashland Co. in Fish Creek Sloughs in South No Impac t; no construction equipment on Marsh willow-herb Shore Lake Superior Fish & Wildlife Area west See general recommendations bog/fen mats; no suitable habitat in N/A SC Urban (Epilobium palustre ) of Ashland along Chequamegon Bay below downtown Ashland or maintained & shoreline; bog and fen mats constructed ROW along Hwy. 137 Arrow -leaved s weet - Bibon Swamp in Bibon Swamp State Natural Not Significant; not likely to occur in urban Underground Road See general recommendations coltsfoot (Petasites N/A T Area south of US-2; cold marshes & swamp areas or maintained & constructed ROW ROW below sagittatus ) openings along US-2 Northern yellow Section data not available; in Douglas Co. in No Impact; very old occurrence (1917) & lady's-slipper Douglas County Forest & Brule River State Underground Road See general recommendations no suitable habitat in urban areas or (Cypripedium N/A SC Forest; fens, calcareous swales, & rich springy ROW & Aerial below maintained & constructed ROW along US- parviflorum var. forest edges 2 makasin) Fish Creek Sloughs in South Shore Lake Superior Fish & Wildlife Area west of Ashland Where work to occur outside of No Impact; no suitable habitat in along Chequamegon Bay shoreline; somewhat existing Road ROW, complete Cape may warbler maintained & constructed ROW along N/A SC/M open coniferous forests of spruce, balsam fir, Urban cable installation & vegetation (Dendroica tigrina ) Hwy. 137; no woody vegetation removal cedar, & tamarack; nests usually placed near clearing from September 1 st to proposed top of crown of spruce or fir trees & near the May 15 th main stem Where work to occur outside of Fish Creek Sloughs in South Shore Lake No Impact; no construction proposed American bittern existing Road ROW, complete Superior Fish & Wildlife Area west of Ashland in/near suitable habitat, work to be (Botaurus N/A SC/M Urban cable installation & vegetation along Chequamegon Bay shoreline; dense completed w/in Road ROW, & no lentiginosus ) clearing from September 1 st to freshwater marshes & extensive wet meadows vegetation clearing proposed May 15 th Not Significant; suitable habitat does not Where work to occur outside of occur in urban areas or maintained & Ashland Junction in South Shore Lake existing Road ROW, complete Western meadowlark Underground Road constructed ROW along US-2 & Hwy 137 N/A SC/M Superior Fish & Wildlife Area; meadows, cable installation & vegetation (Sturnella neglecta ) ROW & Urban or at Ashland Hut Sit; work to be plains, prairies, & other open grasslands clearing from September 1 st to completed w/in Road ROW; no grassland May 15 th vegetation clearing proposed

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Corridor / Species /Natural Federal State Proposed Habitat WiDNR Recommendation Adverse Impact? County Community ¥ Status* Status** Action Not Significan t; suitable habitat does not Where work to occur outside of Ashland Junction in South Shore Lake occur in urban areas or maintained & existing Road ROW, complete Dickcissel ( Spiza Superior Fish & Wildlife Area; open pasture & Underground Road constructed ROW along US-2 & Hwy 137 N/A SC/M cable installation & vegetation americana ) fields of clover & alfalfa, grasslands, meadows, ROW & Urban or at Ashland Hut Sit; work to be clearing from September 1 st to & savanna completed w/in Road ROW; no grassland May 15 th vegetation clearing proposed Where work to occur outside of Not Significant; suitable habitat not likely Upland sandpiper Hayfield near North Fish Creek; tallgrass existing Road ROW, complete to occur in urban areas or maintained & Underground Road (Bartramia N/A SC/M prairies, sedge meadows, unmowed cable installation & vegetation constructed ROW along US-2; work to be ROW longicauda ) alfalfa/timothy fields and scattered woodlands clearing from September 1 st to completed w/in Road ROW; no vegetation May 15 th clearing proposed Where work to occur outside of Ondassagon Forest in vicinity of Whittlesey existing Road ROW, complete No Impact; no suitable habitat in Northern goshawk Creek; mature deciduous, coniferous, or mixed Underground Road N/A SC/M cable installation & vegetation maintained & constructed ROW along US- (Accipiter gentilis ) forest w/ mature, closed canopy & large ROW & Urban clearing from September 1 st to 2; no woody vegetation removal proposed diameter trees for nesting May 15 th Near North Fish Creek in South Shore Lake Not Significant; per USFWS Step -by -Step Superior Fish & Wildlife Area; large trees in Guidance, limit construction as follows: no Bald eagle isolated areas in proximity to large areas of Underground Road Follow USFWS Bald Eagle activity w/in 330’ of eagle nest year-round (Haliaeetus N/A SC/P surface water, large complexes of deciduous ROW Management Guidelines or w/in 660’ of eagle nest from January 1 st leucocephalus ) forest, coniferous forest, wetland, and shrub to August 1 st ; no known nests w/in 660’ of communities route Pervasive along Duluth Spur; large contiguous Not Significant; not likely to be forest, remote areas w/ high percentage of Impacts are unlikely; inform Gray Wolf ( Canis Underground Road encountered in disturbed ROWs, E SC/FL forest & other wildlands (> 90% wildlands), low contractors of species & report lupus ) ROW & Aerial especially given how quickly work will densities of roads, low human densities, & few any sightings move through any given area farms Aurora damselfly North Fish Creek in South Shore Lake No Impact; no construction equipment in Underground Road None specifically; bore under (Chromagrion N/A SC Superior Fish & Wildlife Area; pools & slow waterway—bore under waterway w/ 50ft ROW perennial waterways conditum ) backwaters of clean, often spring-fed streams min. buffer Bore under medium to high No Impact; no sui table habitat in Bog fritillary ( Boloria Bass Lake Bog in Bayfield County Forest west Underground Road N/A SC quality bog, spruce/tamarack, maintained & constructed ROW along US- eunomia ) of Iron River & south of US-2; open acid bogs ROW & open wetland communities 2; no construction equipment in bogs Open bog in Bayfield County Forest near Not Significant; suitable habitat not likely Tiger beetle Muskeg Creek; Semi-open pine/oak barrens, Underground Road None specifically; avoid Great to occur in urban areas or maintained & N/A SC (Cicindela longilabris ) jack & red pine stands w/ open areas on sandy ROW Lakes Barrens & Pine Barrens constructed ROW along US-2; no woody soil, sandy firelanes, or trails vegetation clearing proposed Open bog in Bayfield County Forest near Not Significant; suitable habitat not likely Tiger beetle Muskeg Creek; Semi-open pine/oak barrens, Underground Road None specifically; avoid Great to occur in urban areas or maintained & (Cicindela patruela N/A SC jack & red pine stands w/ open areas on sandy ROW Lakes Barrens & Pine Barrens constructed ROW along US-2; no woody patruela ) soil, sandy firelanes, or trails vegetation clearing proposed

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Corridor / Species /Natural Federal State Proposed Habitat WiDNR Recommendation Adverse Impact? County Community ¥ Status* Status** Action Lake Superior slough at mouth of Whittlesey No Impact; no construction equipment in Eastern elliptio None specifically; bore under N/A SC Creek; streams, lakes, impoundments and Urban Lake Superior & no crossing of Whittlesey (Elliptio complanata ) perennial waterways bays of Lake Superior Creek proposed Not Significant; not likely to be Canada lynx ( Lynx Aerial & encountered in disturbed ROWs, T SC/P Northern forested areas None € canadensis ) Underground especially given how quickly work will move through any given area Fassett’s locoweed (Oxytropis Sand-gravel shorelines around shallow lakes No Impact; suitable habitat does not occur T E N/A None € campestris var. fed by groundwater seepage along the route chartacea ) Nemadji River mouth & Allouez Bay/ mouth of Bear Creek & Lake Superior shoreline Not Significant; high-medium quality Emergent southeast of Superior and east of US-2/53; See general recommendations examples not likely to occur in urban N/A N/A Urban open, marsh, lake, riverine & estuarine below areas or maintained & constructed ROW Marsh communities w/ permanent standing water along US-2/53 dominated by robust emergent macrophytes Blueberry Swamp in Blueberry Swamp State Natural Area & Douglas County Forest east No Impact; does not occur in maintained Hardwood of Maple and south of US-2; deciduous Underground Road See general recommendations N/A N/A & constructed ROW along US-2; no Swamp forested wetland w/ muck or mucky sand ROW below woody vegetation clearing proposed soils; dominated by black ash, red maple, yellow birch, & American elm Afterhours Tamaracks in Douglas County Forest & Brule River State Forest southwest of Brule & US-2; weakly minerotrophic, conifer- Underground Road See general recommendations No Impact; does not occur in maintained Douglas Northern Wet Forest N/A N/A dominated, acid peatlands located mostly ROW & Aerial below & constructed ROW along US-2 north of the Tension Zone; dominated by black spruce & tamarack No Impact; occurs along Lake Superior Wisconsin Point & Allouez Bay along Lake shoreline where construction is not Superior shoreline southeast of Superior and proposed; adjacent to major urban- Migratory Bird Sites N/A SC east of US-2/53; important resting & feeding Urban None industrial complex of Duluth-Superior; areas for birds as they fly between their temporary & permanent disturbances breeding & wintering grounds common along US-2/53 ROW Township/Range/Section data not provided; area where more than one pair of birds nest in Underground Road No Impact; does not occur in maintained Wetland Bird N/A SC a group; typically located in inaccessible ROW, Aerial, & None & constructed ROW along US-2/53; no Rookeries locations including forests, shrub communities, Urban woody vegetation clearing proposed wetlands adjacent to water, & islands Purple c lematis N/A SC Ravine in Amnicon Falls State Park; cool Aerial & Urban See general recommendations No Impact; no suitable habitat in

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Corridor / Species /Natural Federal State Proposed Habitat WiDNR Recommendation Adverse Impact? County Community ¥ Status* Status** Action (Clematis forests (usually mixed conifer -hardwoods), below maintain ed & constructed ROW along US - occidentalis ) often on cliffs & ravines w/ igneous rock 2/53; no woody vegetation clearing or (basalt, quartzite) construction equipment on cliffs proposed Northern yellow No Impact; very old occurrence (1917) & lady's-slipper Section data not available; in Douglas County Underground Road See general recommendations no suitable habitat in urban areas or (Cypripedium N/A SC Forest & Brule River State Forest; fens, ROW & Aerial below maintained & constructed ROW along US- parviflorum var. calcareous swales, & rich springy forest edges 2 makasin ) No Impact; no suit able habitat in Laurentian bladder Basalt cliffs & ravines in Amnicon Falls State See general recommendations maintained & constructed ROW along US- fern (Cystopteris N/A SC Park; moist, mostly wooded slopes and ledges Aerial & Urban below 2/53; no woody vegetation clearing or laurentiana ) in circumneutral soil construction equipment on cliffs proposed No Impact; no suitable habitat in Fragrant fern Cliffs in Amnicon Falls State Park; on moist See general recommendations maintained & constructed ROW along US- (Dryopteris fragrans N/A SC (but not wet) shaded rock cliffs, usually on Aerial & Urban below 2/53; no woody vegetation clearing or var. remotiuscula ) basalt & rarely sandstone construction equipment on cliffs proposed 27th Ave. near Newton Creek & in FO/SS Not Significant; suitable habitat not likely Slender spike-rush swamp in Mariner Mall Marsh; wet exposed See general recommendations N/A E Urban to occur in urban areas or maintained & (Eleocharis nitida ) clay in ditches & openings in alder thickets & below constructed ROW along US-2/53 marshes, only near City of Superior Shallow marsh at Superior Lift Station 6, sand dunes on Wisconsin Point Bayside Sand Pit, Not Significant; suitable habitat not likely Marsh horsetail shrub-carr on Nemadji Riverbank, City of See general recommendations N/A SC Urban to occur in urban areas or maintained & (Equisetum palustre ) Superior wetlands along 39th Ave.; fens, alder below constructed ROW along US-2/53 thickets, wet sedge meadow, bog & swamp margins Not Significant; suitable habitat n ot likely Alpine cotton-grass Blueberry Site near Blueberry Swamp State Underground Road See general recommendations N/A SC to occur in maintained & constructed (Eriophorum alpinum ) Natural Area; bogs, fens, deciduous woods ROW below ROW along US-2 No Impact; no suitable habitat in Large-leaved avens Amnicon Falls State Park; moist woods, See general recommendations maintained & constructed ROW along US- (Geum macrophyllum N/A SC thickets, and rocky ledges and openings, Aerial & Urban below 2/53; no woody vegetation clearing var. macrophyllum ) sometimes weedy proposed No Impact; no suitable habitat in Wisconsin Point; moist shaded cliffs on the Fir clubmoss See general recommendations maintained & constructed ROW along US- N/A SC Lake Superior shoreline & inland in a black Urban (Huperzia selago ) below 2/53; no woody vegetation clearing or spruce/balsam-fir swamp construction on WI Point proposed Open , level, moist clay sites near Superior & in Not Significant; suitable habitat not likely Vasey rush (Juncus Amnicon Falls State Park; moist old fields, See general recommendations to occur in highly developed urban areas N/A SC Aerial & Urban vaseyi ) ditches, & moist prairies, most commonly on below or maintained & constructed ROW along the Lake Superior clay plain US-2/53

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Corridor / Species /Natural Federal State Proposed Habitat WiDNR Recommendation Adverse Impact? County Community ¥ Status* Status** Action Large -flowered No Impact; very old occurrence (1897) & Township/Range/Section data not provided; Underground Road ground-cherry See general recommendations no suitable habitat in urban areas or N/A SC mostly in recently burned moist to dry forests, ROW, Aerial, & (Leucophysalis below maintained & constructed ROW along US- also gravel bars of large rivers Urban grandiflora ) 2/53 No Impact; no suitable habitat in Adder's-tongue Wisconsin Point Bayside Sand Pit; meadows & See general recommendations maintained & constructed ROW along US- (Ophioglossum N/A SC Urban woods or rarely on sandy beaches below 2/53; no woody vegetation clearing or pusillum ) construction on WI Point proposed No Impact; very old occurrence (1897) & Large Roundleaf no suitable habitat in urban areas or Dwight's Point & Pokegama Wetlands; moist See general recommendations Orchid (Platanthera N/A SC Urban maintained & constructed ROW along US- hardwood or mixed conifer-hardwood forests below orbiculata ) 2/53; no woody vegetation clearing proposed No Impact; very old occurrence (1930) & Arrow-leaved sweet- Mariner Mall Marsh & in vicinity of Superior; See general recommendations no suitable habitat in urban areas or coltsfoot (Petasites N/A T Urban cold marshes & swamp openings below maintained & constructed ROW along US- sagittatus ) 2/53 Open, moist sites near Superior & Newton Not Significant; suitable habitat not likely Seaside crowfoot Creek & Nemadji River; sandy or muddy See general recommendations to occur in highly dveloped urban areas or (Ranunculus N/A T shores & marshes, ditches & harbors along Urban below constructed ROW along US-2/53; appears cymbalaria ) Lake Michigan, & salted roadsides near the to thrive w/ disturbance City of Superior Small yellow water Mariner Mall Marsh; in cold brooks and Not Significant; suitable habitat not likely See general recommendations crowfoot N/A E springs, shallow water and muddy shores of Urban to occur in urban areas or maintained & below (Ranunculus gmelinii ) ditches, streams, & lakes constructed ROW along US-2/53 Brown b eakrush No Impact; no construction equipment on Blueberry Ditch; very wet bog and fen mats, Underground Road See general recommendations (Rhynchospora N/A SC bog/fen mats; no suitable habitat in often near Lake Superior ROW below fusca ) constructed ROW of US-2 No Impact; no suitable habitat in Canada gooseberry Wisconsin Point Wooded Dunes; cool open Underground Road See general recommendations maintained & constructed ROW along US- (Ribes N/A T habitats such as talus forests, bluff edges, ROW, Aerial, & below 2/53; no woody vegetation clearing or oxyacanthoides ) sandscapes Urban construction on WI Point proposed Boreal forest opening in Amnicon Falls State No Impact; no suitable habitat in Park; moist acid sandy meadows; rangewide, Georgia bulrush See general recommendations maintained & constructed ROW along US- N/A SC found in moist meadows (including sedge Aerial & Urban (Scirpus georgianus ) below 2/53; no woody vegetation clearing or meadows), shallow marshes, edges of wet construction in state park forests, & ditches City of Superior; beaches of lakes having No Impact; no construction equipment Marsh ragwort fluctuating levels, based on recent records; See general recommendations in/near Lake Superior; no suitable habitat N/A SC Urban (Senecio congestus ) could also occur in cold marshes & fen-like below in urban areas or maintained & sedge meadows constructed ROW along US-2/53

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Corridor / Species /Natural Federal State Proposed Habitat WiDNR Recommendation Adverse Impact? County Community ¥ Status* Status** Action Mariner Mall Marsh; cold ditches & pools in Northern bur-reed Not Significant; suitable habitat not likely sedge meadows, willow-alder thickets & See general recommendations (Sparganium N/A T Urban to occur in urban areas or maintained & occasionally tamarack stands on the Lake below glomeratum ) constructed ROW along US-2/53 Superior clay plain No Impact; no suitable habitat in Veined meadowrue Wisconsin Point Wooded Dunes; pine forest See general recommendations maintained & constructed ROW along US- (Thalictrum N/A SC Urban on the Lake Superior barrier spit below 2/53; no woody vegetation clearing or venulosum ) construction on WI Point proposed No Impact; no suitable habitat in urban Common bog arrow- Railroad yard in Superior; fen mats, open See general recommendations areas or maintained & constructed ROW grass (Triglochin N/A SC neutral to calcareous conifers swamps, & Urban below along US-2/53; no construction proposed maritime ) Great Lakes swales in railroad yard Near Bois Brule River/Spring Lake in Brule River State Forest, vicinity of Hog Island, & Not Significant; per USFWS Step-by-Step south of Allouez Bay near unnamed stream & Bald eagle Underground Road Guidance, limit construction as follows: no Lake Superior shoreline; large trees in isolated Follow USFWS Bald Eagle (Haliaeetus N/A SC/P ROW, Aerial, & activity w/in 330’ of eagle nest year-round areas in proximity to large areas of surface Management Guidelines leucocephalus ) Urban or w/in 660’ of eagle nest from January 1 st water, large complexes of deciduous forest, to August 1 st coniferous forest, wetland, and shrub communities Blueberry Swamp in Brule River State Forest Complete work in/adjacent to Spruce grouse southwest of US-2; large tracts of lowland No Impact; no suitable habitat in urban Underground Road lowland coniferous forest w/in (Falcipennis N/A T coniferous forests w/ swampy regions; Nest areas or maintained & constructed road & ROW & Aerial or mixed w/ wetlands from canadensis ) under low branches of evergreens, in brush or utility ROWs along US-2 September 1 st to April 30 th deep moss, or adjacent to a tree trunk/stump No Impact; no cons truction proposed near suitable habitat w/in marshes, Complete work adjacent to Township/Range/Section data not provided for beaches, or shorelines adjacent to Lake Lake Superior w/in marshes, WI; Interstate Island per MN DNR; Great Superior in Douglas Co.; waterways Common tern (Sterna beaches, or shorelines from N/A E Lakes' shorelines, bays, sand bars of large Urban crossed too densely vegetated & hirundo ) October to early-May to lakes and rivers, sandy or rocky coastal disturbed by urban development; will prevent disturbance during islands, and marshes restrict construction associated w/ the breeding season Blatnik Bridge to non-nesting season (August 1-March 31) No Impact; no construction proposed Complete work adjacent to near suitable habitat w/in marshes, Lake Superior w/in marshes, beaches, or shorelines adjacent to Lake Superior Sewage Treatment Plant along Lake Piping plover beaches, or shorelines from Superior in Douglas Co.; near the E E Superior shoreline; shorelines of lakes/rivers, Urban (Charadrius melodus ) October to early-May to Superior Sewage Treatment Plant sandy beaches where vegetation is sparse prevent disturbance during construction limited to road ROWs of the breeding season Lenroot Hwy & US-2 south of Lenroot Hwy

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Corridor / Species /Natural Federal State Proposed Habitat WiDNR Recommendation Adverse Impact? County Community ¥ Status* Status** Action Where work to occur outside of Not Significant; suitable habitat not likely Grassy old-fields north of US-2/53 & west of existing Road ROW, complete Western meadowlark to occur in maintained & constructed N/A SC/M Wentworth; meadows, plains, prairies, & other Urban & Aerial cable installation & vegetation (Sturnella neglecta ) ROW along US-2/53; no grassland open grasslands clearing from September 1 st to vegetation clearing proposed May 15 th Mixed forest in Amnicon Falls State Park north Where work to occur outside of No Impact; no suitable habitat in urban Canada warbler of US-2/53; usually wet deciduous & existing Road ROW, complete areas or maintained & constructed ROW (Wilsonia N/A SC/M coniferous forests w/ dense shrub layer; nests Aerial & Urban cable installation & vegetation along US-2/53; no woody vegetation canadensis ) on or near ground on mossy logs/roots, along clearing from September 1 st to removal proposed stream banks, or on hummocks May 15 th Nest on top of grain silo/elevator at General Mills Elevator in Superior; relatively Peregrine falcon No Impact; no construction proposed w/in N/A E inaccessible rock ledges on the sides of steep Urban Impacts are unlikely (Falco peregrinus ) suitable habitat or at the grain elevator bluffs & ledges on high-rise buildings in urban areas St. Louis River/Superior Bay/Allouez Bay in No Impact; no construction equipment in American eel Dwight's Point and Pokegama Wetlands State None specifically; bore under waterways—existing conduit, aerial N/A SC Urban (Anguilla rostrata ) Natural Area & Nemadji River; large streams, perennial waterways crossing by hand/boat, or bore under rivers, & lakes w/ muddy bottoms & still waters waterway w/ 50ft min. buffer Not Significant; access poles by foot & Bois Brule River in Brule River State Forest & Bore all perennial waterways climb manually April-October if can’t Amnicon River in Amnicon Falls State Park; 9 Underground Road & complete work w/in 300 m access from road shoulder; bore Wood turtle other waterways have potential habitat; clean N/A T ROW, Aerial, & of these waterways from waterways & maintain a 200ft min. (Glyptemys insculpta ) rivers & streams w/ moderate-fast flows & Urban November 1 st to April 8 th ; buffer of waterway year-round & hire adjacent riparian wetlands & upland deciduous report any sightings monitor if work conducted April 8- forests November 1 Pervasive along Duluth Spur; large contiguous Not Significant; not likely to be forest, remote areas w/ high percentage of Underground Road Impacts are unlikely; inform Gray Wolf ( Canis encountered in disturbed ROWs, E SC/FL forest & other wildlands (> 90% wildlands), low ROW, Aerial, & contractors of species & report lupus ) especially given how quickly work will densities of roads, low human densities, & few Urban any sightings move through any given area farms Not Significant; not likely to be Canada lynx ( Lynx Aerial & encountered in disturbed ROWs, T SC/P Northern forested areas None € canadensis ) Underground especially given how quickly work will move through any given area Fassett’s locoweed (Oxytropis Sand-gravel shorelines around shallow lakes No Impact; suitable habitat does not occur T E N/A None € campestris var. fed by groundwater seepage along the route chartacea ) Kirtland’s Warbler Large homogenous stands of jack pine w/ No Impact; suitable habitat does not E SC/FL N/A None € (Dendroica kirtlandii ) scattered small openings occur along the route

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¥ Important Note: The specific locations and identities of endangered resources included in the Wisconsin Endangered Resources Review are 1) sensitive, 2) not subject to Wisconsin’s Open Records Law, and 3) may not be released or reproduced in any publicly disseminated document. Therefore, if NTIA deems that this document must become public, any reference to a specific species, natural community, or other natural featured derived from the Wisconsin Natural Heritage Inventory Database within the document’s text and agency correspondence must be redacted. *C = federal candidate species, E = federally endangered species, SOC = federal species of concern, T = federally threatened species **E = state endangered species, SC = state special concern species, SC/FL = federally protected as endangered or threatened, but state special concern, SC/M = fully protected by federal & state laws under the Migratory Bird Act, SC/P = fully protected state special concern, T = state threatened species To minimize impacts to rare plants & natural communities: identify undisturbed natural communities, prefer more disturbed side of road, work from road shoulder & during non-growing season when feasible, minimize trenching/large equipment use, avoid woody vegetation removal, adhere to invasive species & erosion control BMPs & regulations. €Element occurrences identified by USFWS review but not included in WiDNR review.

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Many of the T&E species listed in Table 4.5.4.2 will not be adversely affected by the proposed Project, because suitable habitat does not occur for these species where fiber infrastructure installation is proposed within the disturbed road and utility ROW’s or certain construction methods will be selected to minimize habitat disturbance. As specific examples, eastern elliptio ( Elliptio complanata ) (mussel), greater redhorse ( Moxostoma valenciennes ) (fish), and Aurora damselfly ( Chromagrion conditum ) (insect) occupy streams, rivers, and lakes. Their aquatic habitats will not be impacted by the proposed Project, due to: 1) aerial installation methods on existing poles occurring from the road shoulder or disturbed ROW’s with no equipment use in the waterways; and, 2) the underground installation method of directionally boring beneath waterways. Aerial construction on existing poles in existing, regularly disturbed ROWs and the use of directional boring, where required, minimize the Project’s impact on T&E species and their associated habitats. Minor, temporary disturbances associated with underground construction will result in the ground surface being returned to its original grade and stabilized.

Special precautions to minimize impacts to rare species that are known to occur within the road and utility ROW’s and have been identified in consultations with WiDNR Office of Energy will be implemented. Timing of construction and selection of the installation method for the fiber have been adjusted per direction from the agency to limit impacts to known element occurrences. For example, adverse impacts to wood turtle ( Glyptemys insculpta ), which is known to occur near certain portions of the route, will be minimized for underground construction by utilizing directional boring beneath occupied waterways with bore pits set back a minimum of 200 feet from both sides of the waterways and having a monitor present during the turtle’s active season from April through October to work ahead of the construction crew and identify turtles and suitable nesting habitat for avoidance. For aerial construction, the turtle will be protected by limiting construction equipment to the road shoulder whenever feasible, and, if crews must leave the road shoulder during the months of April through October, they will access the utility poles on foot and climb them manually (i.e., no vehicular traffic off of the road). Construction crews will be advised that late May to early July is the most active period for turtles and that the most common source of fatality to turtles occurs during road crossing. Therefore, crews will be instructed to be vigilant, even when working from the road. Construction crews will be made aware of federally and state listed species and their habitats and will implement the protective measures detailed in correspondence with the USFWS field offices and WiDNR Office of Energy (see Appendix F). All agency requirements will be adhered to throughout the construction of the Project.

Given the relative lack of suitable habitat within the disturbed and regularly maintained road and utility ROW’s where temporary Project impacts are proposed and the protective measures outlined in correspondence with WiDNR Office of Energy, the Project Team determined that potential adverse impacts, if any, resulting from the proposed Project would be limited to the construction phase and would be short-term and minor. The Project Team received concurrence with these findings and Project clearance from the WiDNR Office of Energy on April 18, 2011. Following this clearance, three minor route changes were required to avoid impacts to cultural resources in Wisconsin. These route changes remained within the two-mile zone on either side of the route originally cleared, and are not anticipated to adversely impact additional T&E element occurrences. The WiDNR Office of Energy issued a statement of continued concurrence and Project clearance on June 20, 2011. Refer to Appendix F for WiDNR Office of Energy correspondence. .

The No Action Alternative would have no adverse impact on federal and state T&E species and critical habitat resources in Wisconsin.

Merit REACH-3MC II Final Environmental Assessment (7/15/2011) 120 4.5.4.4 Minnesota Threatened and Endangered Species Per MnDNR review letters dated January 12 and February 28, 2011, only two of the 24 element occurrences, including several species of fish, shore birds, and vascular plants which are known to occur within one mile of the Project route in Minnesota, have the potential for being adversely impacted by the proposed Project. Refer to Appendix F for MnDNR correspondence and a complete list of element occurrences within one mile of the Project route, including federally and state listed species and unique natural features. These two state listed species, Peregrine falcon ( Falco peregrinus ) and Common tern ( Sterna hirundo ), are known to nest on the Blatnik Bridge and on Interstate Island west of the Bridge in St. Louis Bay, respectively. The Project Team proposed that these birds would not be adversely affected by the Project with the implementation of a seasonal protection measure that restricts construction activity on and in the immediate vicinity of the Blatnik Bridge to the non-nesting season between August 1 st and March 31 st to avoid disturbing the nesting activities of these birds. Construction crews will be made aware of these state listed species and will implement the protective measures detailed in correspondence with the MnDNR (see Appendix F). All agency requirements will be adhered to throughout the construction of the Project.

Given the general lack of suitable habitat for rare species in downtown Duluth and the protective measure outlined in correspondence with the MnDNR, the Project Team determined that potential adverse impacts, if any, would be limited to the construction phase and would be short-term and minor. The Project Team received concurrence with these findings and Project clearance from MnDNR on April 7, 2011. Refer to Appendix F for MnDNR correspondence. Important Note : The information provided in the correspondence from the MnDNR may include specific location information that is considered non-public data under Minnesota Statutes Section 84.0872 subd. 2. Written permission is required to reprint or publish the data.

The No Action Alternative would have no adverse impact on federal and state T&E species and critical habitat resources in Minnesota.

4.5.5 Wetland Habitat Wetland permits will be acquired from the applicable federal, state, and local agencies. All wetland permit requirements will be adhered to throughout construction of the Project. Since Project impacts to wetlands are anticipated to be minor, short-term, and temporary, no wetland mitigation is proposed for the Project. Refer to Refer to Chapter 5 for a list of wetland permits that may be required for the Project and Appendix F for agency correspondence and meeting minutes.

Aerial construction on existing poles in existing, regularly-disturbed road and utility ROW’s and the use of existing underground conduit minimize the Project’s impact on wetland habitats. Minor, temporary disturbances associated with underground construction and pole replacement would result in the ground surface being returned to its pre- construction grade. Therefore, the adverse impacts to wetlands associated with the Project would be limited to the construction phase, short-term, and minor.

The telecommunication huts will be installed on previously disturbed uplands in developed areas and no adverse impacts to wetland habitat would occur.

The No Action Alternative would have no adverse impact on wetland habitat resources.

Merit REACH-3MC II Final Environmental Assessment (7/15/2011) 121 4.6 HISTORIC AND CULTURAL RESOURCES

4.6.1 Archaeological Resources The proposed fiber optic cable will be located in existing previously-disturbed road and utility ROW’s which will minimize the potential to impact archaeological resources. Aerial construction on existing poles in existing, previously disturbed road and utility ROW’s and the use of existing underground conduit minimize the Project’s impact on archeological resources.

In its review, Michigan SHPO noted that numerous archaeological sites have been recorded in and around St. Ignace, indicating high archaeological sensitivity in the general vicinity of St. Ignace. On May 9, 2011, the Michigan SHPO issued a letter stating that the proposed Project will have:

“no adverse effect [36 CFR § 800.5(b)] on historic properties within the area of potential effects for the above-referenced undertaking, provided the following condition is met: • Installation of the fiber optic cable shall be monitored by a professional archaeologist beginning at the Chambers Street-Business Route 75 intersection, and continuing northward through St. Ignace and Evergreen Shores to the north section line of Section 36 of Moran Township (T41N-R4W). If archaeological deposits are encountered during cable installation,, work must stop to give the monitoring archaeologist ample opportunity to evaluate the deposits, contact ECT, the State Archaeologist, and other parties as appropriate, and determine steps to be taken to minimize the effect of the project on the deposits.”

Merit has indicated its concurrence with the conditions outlined in the May 9 letter. The Michigan SHPO reviewed minor root changes submitted on June 30 and issued a subsequent clearance letter on July 15, 2011. Agency correspondence can be found in Appendix F.

The Project Team refined the proposed fiber optic route in Wisconsin to avoid impacts to the Oconto site listed on the National Register of Historic Places and the remaining catalogued and uncatalogued burial sites. In Marinette, the Marinette CAI Service Alternative was deleted from the Project to avoid potential conflicts with several uncatalogued burial sites in the area. And, in Peshtigo, the route was shifted south to the US 41 By-Pass to avoid potential conflicts with several burial sites in downtown Peshtigo. All of the route refinements are shown on the maps in this Environmental Assessment and the correspondence in Appendix F.

The Wisconsin SHPO issued a letter on June 23, 2011 stating that the proposed Project has been redesigned to avoid the Oconto site all catalogued and uncatalogued burial sites will be avoided by at least 100 feet and that no protective fencing will be necessary. If human bone is discovered during subsurface investigations, work must stop immediately and the Burial Sites Preservation Officer must be contacted for compliance with Wisconsin Statute §157.70 which provides for the protection of human burial sites.

The Minnesota SHPO issued a letter on March 22, 2011 stating that no properties listed in or eligible for listing in the National Register of Historic Places will be affected by the Project. No further conditions were identified.

Merit will provide training materials to Project contractors to assist in identification of any unforeseen cultural resource sites that may be revealed during construction. These materials will include procedures for stopping work in the immediate area and contacting the Merit project manager who will be responsible for coordinating with NTIA, the applicable SHPO and other parties as described below to determine the significance of the find and the steps to be taken to secure the clearances needed to resume construction in the area.

Merit REACH-3MC II Final Environmental Assessment (7/15/2011) 122 project construction uncover cultural materials (i.e. structural remains, historic artifacts, or prehistoric artifacts), all work in the immediate vicinity shall cease and interested Tribes, the State Historic Preservation Office, and NTIA shall be notified immediately. Such construction activities may then only continue with the written approval of NTIA. If earth disturbing activities during any area of the Project uncover human remains, all work shall cease immediately in accordance with the Native American Graves Protection and Repatriation Act of 1990 (NAGPRA) and relevant state statutes. The area around the discovery shall be secured and the relevant law enforcement personnel (e.g. local police or County Coroner) and NTIA shall be notified immediately. Such construction activities may then only continue with the written approval of NTIA.

Based on the fact that the Project is located exclusively within existing disturbed road and utility ROW’s, the responses received from the Michigan, Wisconsin and Minnesota SHPO’s and Merit’s commitment to comply with the conditions therein and as stated above, adverse impacts to archeological artifacts and remains associated with the Project are anticipated to be very limited in extent if they occur at all. Therefore, adverse impacts from the Project, if any, would be minor and limited to inadvertent discoveries of cultural artifacts or human remains during construction.

The No Action Alternative would have no adverse impact on archeological resources.

4.6.2 Architectural Resources Neither the hanging of new fiber-optic cable from existing utility poles, underground installation of new fiber-optic cable, nor the operation of that cable to provide data transmission within existing road and utility ROW’s would impact architectural resources, including those that are listed in, or eligible for listing in, the National Register of Historic Places. Consultations conducted to-date with CAI’s that will be directly connected to the proposed fiber optic segments or last mile connections have indicated that any of these sites are listed in, or eligible for listing in, the National Register of Historic Places. If architectural resources that are listed or eligible for listing are identified during the process of finalizing negotiations with CAI’s, Merit will comply with NTIA guidance for providing connections to those buildings as outlined in Best Management Practice: Attaching Broadband Equipment to Historic Buildings.

Therefore, the Project would have no adverse impacts to architectural resources.

The No Action Alternative would have no adverse impact on architectural resources.

4.6.3 Native Resources The Shawnee Tribe, Miami Tribe of Oklahoma, and Wyandotte Nation requested additional information about the Project after being notified through the TCNS. Upon receipt of that information, all three tribes have issued correspondence indicating no further consultation is required prior to construction but requested to be notified if archeological remains or resources are discovered during Project construction or installation to end users requires archaeological surveys by the State Historic Preservation Office. Merit will comply with this request.

Twelve additional tribes were individually contacted based on supplemental information provided by NTIA. Of these, three, Ottawa Tribe of Oklahoma, Lac du Flambeau Band of Lake Superior Chippewa Indians, and Sault, Ste. Marie Tribe of Chippewa Indians of Michigan requested additional information. The Sault Ste. Marie Tribe stated that it had no information concerning the presence of Native American Traditional Cultural Properties that may be affected by the Project but would be willing to assist in the event of an inadvertent discovery of human remains or artifacts. The Ottawa Tribe of Oklahoma stated its concurrence that no known historic properties will be negatively impacted by the Project and requested to be notified in the event that archaeological materials, including human remains, are encountered during construction. The Lac du Flambeau Band requested copies of the archaeological reports that have been prepared for the Project. They concurred with the recommendations of the report and recommended monitoring of activities where uncatalogued sites exist. Clearance letters were received from each of these tribes on March 17, April 21, and March 17, 2011 respectively.

Merit REACH-3MC II Final Environmental Assessment (7/15/2011) 123 The Project team contacted the Lac Vieux Desert Band (LVD Band) of Lake Superior Chippewa Indians (Ketegitigaaning) to discuss the Project. The Project Team had consulted with the LVD Band during Round One of the REACH 3MC project and initiated consultation for Round Two. The LVD Band provided a letter on January 28, 2011 stating that they have no objections to the Project; however, they requested to be contacted immediately if the scope of the Project changes or is artifacts or human remains are discovered. Merit will comply with this request. Copies of tribal correspondence can be found in Appendix F.

The proposed Project crosses lands within the Bad River Indian Reservation in Ashland County, Wisconsin. The Project Team and NTIA staff have consulted with the Bad River Band of the Lake Superior Tribe of the Chippewa to identify a project route that minimizes potential impacts to cultural and natural resources within the Reservation. During this consultation, a fiber optic route was identified that maximizes the use of existing utility poles for aerial construction; the Bad River crossing will be directionally drilled (Figure 3.6.3.1).

On May 27, 2011, the Tribal Historic Preservation Officer issued a letter stating that:

“although the entirety of the Bad River Indian Reservation is considered a Historic and Traditional Cultural Property by the Tribe which contains Significant Cultural Resources, Historic Landscapes, and registered National natural Landmarks that are inextricably linked to inherently tangible and intangible values, beliefs and the current culture of the Bad River Tribe and its members; that this federal undertaking will have No Adverse Effects to Historic Properties present in the area of potential effect provided the following provisions are in place to ensure that inadvertent discoveries are addressed immediately and avoidance measures are implemented properly:

1. Merit Network, Inc. provide the resources for Tribal Monitoring in sensitive areas described by the THPO Office along the route during project excavations at a rate of $125.00 plus travel/mileage expenses, per Tribal Monitor; 2. A Post-Installment Maintenance Agreement is developed by Merit Network, Inc. or the U.S. Department of Commerce with the Bad River Tribal Natural Resources Department for implementation by the time of installation; 3. Impacts to White Cedar trees are avoided within or adjacent to intended areas of excavation as the tree roots may also be impacted in the excavation process; 4. Aerial installation of the Fiber Optic Infrastructure from the intersection of U.S. Highway 2 and Dock road to the intersection of U.S. Highway 2 and Caville Road as depicted on the attached map. 5. Installation of new poles shall be in the same location that current poles are located. 6. All equipment used in the excavation and installation process be cleaned prior to transport onto the Bad River Reservation and that silt fencing is used in areas adjacent to waterways. 7. Borrow pit are inspected by qualified Bad River Natural Resource staff to ensure that they are not subject to invasive plant species that may directly, or indirectly provide an impact within waterways, and wetlands of the reservation; and the resources expended for such inspections is reimbursed to the Bad River Tribe by Merit Network, Inc.. 8. Water Quality inspections are conducted periodically by qualified Bad River natural Resource Department staff and the expense of such inspections is reimbursed by the Department of Commerce or Merit Network, Inc. during a two-year post-installation period.”

NTIA, in its letter to the Bad River THPO dated June 23, stated that:

• the Post- Installment Maintenance Agreement should be between the Tribe and Merit directly, • NTIA will document the Post-Installment Maintenance Agreement and other conditions identified in the Tribe’s May 27 letter as mitigations to NTIA’s Finding of No Significant Impact (FONSI) and post-FONSI Special Award Conditions of BTOP grant funding; and,

Merit REACH-3MC II Final Environmental Assessment (7/15/2011) 124 • NTIA will require Merit to document the Tribe’s approval and acceptance that these conditions have been met before allowing any site preparation or construction-related disturbance to take place within the Reservation.

Merit agrees to comply with the conditions stated in the May 27 letter and efforts are underway to finalize a Post- Maintenance Agreement as soon as possible. In addition, Merit will comply with any post-FONSI Special Award Conditions identified by NTIA.

Copies of correspondence with the Bad River Band can be found in Appendix F.

For all ground disturbing activities that occur during project development in the vicinity of known archaeological sites or suspected or known burials (as identified above), Merit will ensure that an archaeologist who meets the Secretary of the Interior’s Professional Qualification Standards monitors ground disturbance. If earth disturbing activities during project construction uncover cultural materials (i.e. structural remains, historic artifacts, or prehistoric artifacts), all work in the immediate vicinity shall cease and interested Tribes, the State Historic Preservation Office, and NTIA shall be notified immediately. Such construction activities may then only continue with the written approval of NTIA. If earth disturbing activities during any area of the Project uncover human remains, all work shall cease immediately in accordance with the Native American Graves Protection and Repatriation Act of 1990 (NAGPRA) and relevant state statutes. The area around the discovery shall be secured and the relevant law enforcement personnel (e.g. local police or County Coroner) and NTIA shall be notified immediately. Such construction activities may then only continue with the written approval of NTIA.

The proposed Project creates opportunities to provide high-speed capabilities to four Native American tribes in the region: Sault Ste. Marie Tribe of Chippewa Indians, Little Traverse Bay Band of Odawa Indians, Hannahville Indian Community, and the Bad River Band of Lake Superior Chippewa.

The No Action Alternative would have no adverse impact on tribal land; however, members of the tribes identified above would not have the opportunity to benefit from access to low-cost broadband services.

No telecommunication huts are proposed on tribal land.

4.7 AESTHETIC AND VISUAL RESOURCES

No vegetation clearing, new utility corridors or access roads are proposed. Neither the hanging of new fiber-optic cable from existing utility poles, underground installation of new fiber-optic cable, nor the operation of that cable to provide data transmission within existing road and utility ROW’s would create any new long-term changes to visual aesthetics along the Project route. Aesthetic changes associated with the construction phase of the Project would be temporary and comparable to those associated with regular maintenance activities along the existing ROW’s. Merit will comply with existing local ordinances. Therefore, impacts associated with the Project, if any, would be limited to the construction phase and would be short-term and minor.

The telecommunication huts will be installed on previously disturbed lands in developed areas and the appearance of these huts would be compatible with the surrounding landscape.

Merit REACH-3MC II Final Environmental Assessment (7/15/2011) 125 The majority of the Project in the Chequamegon, Ottawa, Hiawatha and Huron National Forests will be located underground in existing road ROW’s. In the limited areas where aerial construction is proposed in National Forests, the fiber optic cable will be located on existing utility poles in existing regularly-maintained utility ROW’s. No vegetation clearance, new pole runs, or new access roads are proposed.

Merit will continue to coordinate with National Forest staff to ensure that the Project does not conflict with the Scenic Integrity Objectives or Visual Quality Objectives outlined in the Forest Plans for each Forest. Impacts to aesthetic and visual resources associated with the Project, if any, would be limited to the construction phase and would be short-term and minor. No telecommunication huts are proposed on National Forest land.

The No Action Alternative would have no adverse impact on aesthetic and visual resources.

4.8 LAND USE

No changes to existing land uses are proposed. In addition, the Project location within existing road and utility ROW’s limits the potential for the Project to conflict with future land uses. Access to existing land uses will be maintained during Project construction. Therefore, no adverse impacts would occur.

The proposed telecommunications huts are located within existing developed areas and are compatible with the existing land uses adjacent to each site. The proposed location of each hut has been determined, in part, by the willingness of the current land owner to have their land used for this purpose. No adverse impacts to existing or future land uses would occur as a result of the proposed telecommunications huts.

Public Lands The Project crosses lands within four National Forests; the Huron, Hiawatha, Ottawa, and Chequamegon. The location of the proposed Project within existing road and utility ROW’s would minimize the potential for conflicts with existing and future uses within each Forest. The Project Team will continue to coordinate with staff from each National Forest to secure the Special Use Permits needed to cross each Forest and Merit will comply with all permit conditions. Impacts if any, resulting from the Project would be limited to the construction phase and would be short- term and minor.

No telecommunication huts are proposed on National Forest lands.

The No Action Alternative would have no adverse impact on land uses.

Tribal Lands Refer to Section 4.6.3 for a detailed discussion of tribal lands.

4.9 INFRASTRUCTURE

The location of the proposed Project within existing road and utility ROW’s creates the potential for conflicts with existing infrastructure resources such as sewer, water, electricity, natural gas, telecommunication utilities and transportation networks that are located within the same ROW. Merit will undertake the following actions to minimize the potential for inadvertent conflicts:

• Merit is coordinating with state and local road departments to minimize potential conflicts with proposed and future road improvement projects and identify measures to be taken to minimize the potential for traffic disruptions that may occur during construction. • In areas where aerial construction is proposed, Merit is coordinating with the owners of the existing utility poles that will be used to attach the proposed fiber optic cable to minimize conflicts with existing and future utilities that currently utilize these poles or may want to use them in the future.

Merit REACH-3MC II Final Environmental Assessment (7/15/2011) 126 • In areas where underground construction is proposed, Merit will consult with underground utility location services such as Miss Digg prior to construction to locate existing underground utilities and minimize potential for inadvertent service disruption.

These measures will minimize the potential for disruption to existing infrastructure services and conflicts with future infrastructure expansion. Therefore, potential adverse impacts resulting from the Project will be limited to the construction phase and would be short-term and minor.

However, the Project would positively impact the availability of communication infrastructure by providing affordable, high-performance broadband to homes, businesses, CAIs, and critical community facilities in underserved areas. The Project would extend Merit’s existing 1,600+ mile fiber network and provide advanced services previously unavailable to many parts of rural Michigan, northern Wisconsin, and northeast Minnesota.

The No Action Alternative would have a significant adverse impact on infrastructure resources, as unserved and underserved areas in the 38 counties affected by the Project would continue to go without affordable, high- performance broadband access.

4.10 SOCIOECONOMIC RESOURCES

The Project will bring high-performance, low-cost broadband service and badly-needed jobs to underserved areas of Michigan, Wisconsin and Minnesota. Using the results from the 2006 report “Measuring Broadband’s Economic Impact” by the U.S. Department of Commerce Economic Development Administration, Merit anticipates the addition of 946 jobs per year beyond what can otherwise be expected without the Project.

The Project would not harm or disadvantage any incumbent ISP in the proposed service area. It would substantially reduce backhaul costs. In the remote and rural areas that the Project seeks to serve, up to 80% of delivering broadband service to the community can be the cost of obtaining backhaul. With the Project absorbing a large portion of that cost, existing providers would be able to invest more in their service and their local communities. Merit has developed an open model and would address non-discrimination and interconnection obligations. The fact that Merit and one other sub-recipient are strictly middle mile providers ensures open access over the proposed network. Two other sub-recipients would expand into middle mile services, offering competitive rates. All parties have agreed to follow the non-discrimination and interconnection obligations and have posted appropriate policies on their web sites. Michigan, Wisconsin and Minnesota will have an infrastructure that supports a breadth of technologies like fiber strands, wave services, and IP services of today and tomorrow.

From an environmental justice perspective, the Project would have a positive impact on the socioeconomic resources of the low-income and minority populations living in the underserved areas within the Project. Having purposefully targeted underserved areas, the Project includes environmental justice populations in 14 of the 38 counties served by the proposed route, e.g. counties that have a higher percentage of a given vulnerable population compared to that population’s state percentage (Refer to Table 3.10.1). Environmental justice populations identified, based upon county level population data for the Project, include African American, American Indian, Hispanic/Latino, Asian, and Individuals Below Poverty Level populations. The potential impacts associated with the Project are anticipated to be so minor and temporary that there would be no potential for significant disproportionate impacts to these environmental justice populations.

The No Action Alternative would have a significant adverse impact on socioeconomic resources. Unserved and underserved areas in 29 Michigan, eight Wisconsin, and one Minnesota counties including low-income and minority populations living in these areas, would continue to go without affordable, high-performance broadband access. Citizens in these states would miss out on important job and educational opportunities and would continue to be disengaged from the digital economy.

Merit REACH-3MC II Final Environmental Assessment (7/15/2011) 127 4.11 HUMAN HEALTH AND SAFETY

4.11.1 Public and Worker Safety Public and worker safety along road and utility ROW’s will be an important component of the Project. All construction crew members will be trained and familiar with local, state, and federal traffic control and safety regulations and specifications and will comply with applicable Occupational Health and Safety Administration (OSHA) and State Highway Department (SHD) regulations. To mitigate the potential for automobile accidents, signs will be posted in both directions to denote construction work along road shoulders and in road rights-of-way, per SHD Maintenance Work Zone Traffic Control Guidelines. It is anticipated that along the majority of the Project route, road shoulders will be large enough to accommodate construction workers and equipment, such that vehicles and other equipment will be located completely off of the road. Therefore, road shoulder closures are anticipated for most of the route, but frequent lane closures or complete road closures are not anticipated. In the event that traffic needs to be routed around a vehicle for aerial construction, a flagman will be posted to safely direct traffic per SHD procedures. Underground installation crews will be located completely off of the road and will be relatively stationary each day, so underground work areas will be demarked with regulation-sized road cones. As most of the Project route is rural in nature, traffic control will be most important near anchor institutions in urban areas with higher traffic volumes. All required permits for roadside work would be obtained and complied with throughout Project construction. Potential adverse impacts resulting from the Project, if any, would be limited to the construction phase and would be short-term and minor.

The No Action Alternative would have no adverse impact on public and worker safety.

4.11.2 Brownfields The methods that will be employed to install the utility are generally recognized not to have a significant adverse impact to human health and safety. The risks associated with the proposed construction methods are far less than with other methods, such as trenching. Any soil removed from the ground would be returned to the position from which it was removed thus minimizing potential exposure to contaminated soils. Potential impacts resulting from construction on brownfield sites will be limited to construction and will be minimized through the use of recognized construction techniques designed to minimize potential for exposure. Therefore, potential adverse impacts, if any, would be limited to the construction phase and would be short-term and minor.

4.12 CUMULATIVE IMPACTS

Construction of the proposed Project is expected to result in additional spin-off fiber projects as other broadband providers seek to build upon the REACH 3MC Project and expand broadband service beyond the areas that will be served by the Project. Over 100 broadband service providers have expressed an interest in building spin-off projects since the REACH 3-MC project was announced in early 2010. Most of these spin-off projects are expected to be less than 10 miles in length and associated with existing facilities. The economic and engineering considerations for building fiber infrastructure make it likely that these spin-off projects will utilize existing disturbed road and utility ROW’s and install the fiber on existing utility poles or utilizing underground methods similar to those proposed by the Project in areas where utility poles are not available. Therefore, the impacts of these spin-off projects is expected to be limited to short-term and minor impacts associated with construction.

There may be minor cumulative impacts to infrastructure resulting from the addition of fiber optic cable to existing utility poles in that these poles can only accommodate a finite number of cables and associated equipment making less space available for future cables and lines on the poles used for the Project and future spin-off projects. Likewise, installing the fiber optic cable underground in road ROW’s utilizes finite space within the ROW that could potentially be available for other utilities in the future or may be needed for future road expansion projects. Merit is coordinating with state and local highway departments and road commissions to minimize the potential for conflicts with future utility and road expansion projects; therefore the potential for adverse impacts to future road and utility projects would be minor.

Merit REACH-3MC II Final Environmental Assessment (7/15/2011) 128

There is a substantial positive cumulative impact of the Project on socioeconomic resources. The purpose of the Project is to bring high-performance, low-cost intermediate or middle mile service to underserved areas. The Project is designed to foster economic development and growth in underserved areas of Michigan and improve broadband access for more than 932,000 community anchor institutions, households and businesses including public safety sites. As a result, residents within the area served by the Project will have access to increased opportunities for economic development and education, and improved public safety. These positive socio-economic benefits will be further increased through the development of spin-off projects.

4.13 SUMMARY OF IMPACTS TO RESOURCE AREAS

The REACH-3MC II Project proposes the expansion of Merit’s existing 1,600+ mile fiber backbone network by an additional 1,263 miles of multi-strand fiber infrastructure via a combination of aerial and underground installation techniques. It proposes the selection of the most appropriate fiber installation methodology for a given site, thus allowing the Project to be responsive to existing site conditions and local, state, and federal regulations that apply to each mile of the extensive fiber route. The Project leverages the time, cost, and environmental benefits of utilizing existing utility poles and underground utility conduits, while saving more expensive and time-consuming underground installation techniques for areas with no available poles, restrictive utility ordinances, and/or special natural, historical, and cultural resources. Potential adverse environmental impacts resulting from the REACH-3MC II Project would be minimized through the utilization of existing, previously disturbed utility and road rights-of-way for the entire length of the Project. Potential adverse impacts, if any, would be limited to the construction phase and would be short-term and minor. Table 4.13.1 provides a comparative summary of impacts to resource areas by the No Action and Preferred Alternatives.

The Project Team has reviewed the Project for potential impacts to the human and natural environment. No significant adverse environmental impacts have been identified in this Environmental Assessment. Positive impacts to infrastructure, socioeconomic resources and environmental justice populations have been identified. Based on the information in this Environmental Assessment and coordination with regulatory agencies, it is anticipated that the REACH-3MC II Project will have no long-term significant adverse impacts on the human and natural environment. Therefore, further environmental review is not warranted, and issuance of a Finding of No Significant Impact (FONSI) is recommended.

Merit REACH-3MC II Final Environmental Assessment (7/15/2011) 129 Table 4.13.1 Summary of Impacts to Resource Areas

No Action Alternative Preferred Alternative Resource Area Impact? Type of Impact Impact? Type of Impact Noise No N/A No N/A Air Quality No N/A No N/A Geology & Soils No N/A Yes Not Significant Water Surface Water No N/A No Not Significant Groundwater No N/A No N/A Wetlands No N/A Yes Not Significant Coastal Zones No N/A Yes Not Significant Environmental Areas No N/A Yes Not Significant Critical Dunes No N/A No N/A Floodplains No N/A Yes Not Significant Wild & Scenic Rivers No N/A Yes Not Significant MI Natural Rivers No N/A Yes Not Significant Biological Ecoregions No N/A No N/A Vegetation No N/A Yes Not Significant Wildlife No N/A Yes Not Significant T&E Species & Critical Habitats No N/A Yes Not Significant Wetland Habitat No N/A Yes Not Significant Historic & Cultural No N/A Yes Not Significant Archeological No N/A Yes Not Significant Architectural No N/A No N/A Native No N/A Yes Not Significant Aesthetic & Visual No N/A No N/A Land Use No N/A No N/A Public Land No N/A Yes Not Significant Infrastructure Yes Significant Adverse Yes Significant Positive Socioeconomic Yes Significant Advers e Yes Significant Positive Environmental Justice Yes Significant Adverse Yes Positive Human Health & Safety No N/A Yes Not Significant Public & Worker Safety No N/A Yes Not Significant Brownfields No N/A Yes Not Significant

Merit REACH-3MC II Final Environmental Assessment (7/15/2011) 130 5.0 CHAPTER 5 – APPLICABLE ENVIRONMENTAL PERMITS & REGULATORY REQUIREMENTS

FEDERAL

Army Corps of Engineers, Clean Water Act and Rivers and Harbors Act The Michigan Department of Natural Resources and Environment (MiDNRE) is responsible for administering Section 404 of the Clean Water Act. Whereas in other states, where an applicant must apply to the U.S. Corps of Engineers and a state agency for wetland and waterway crossing permits, applicants in Michigan generally submit only one wetland and waterway crossing permit application to the MiDNRE. A permit application for crossing rivers, streams and wetlands will be submitted to the MiDNRE as soon as engineering plans are finalized. The Project qualifies as a minor project; the agency has up to 60 days to respond to a permit application request.

The Project Team has contacted Wisconsin’s Green Bay District Field Office in order to determine all necessary permits and clearances. The Agency stated that while the project includes components in three states, staff from the Green Bay Field office of the St. Paul District would take the lead in reviewing permit applications and coordinating with Corps colleagues in Michigan’s Upper Peninsula and Minnesota. Two kinds of permits may be needed for the project:

• Section 404 permit for impacts to streams and wetlands • Section 10 permits for crossings of navigable waters.

Section 404 Permits (Clean Water Act) Section 404 permits are needed to excavate or place fill in wetlands or trench across streams. Specific Project activities that would require a permit under this section include replacing existing utility poles in wetlands, excavating bore pits in wetlands, or placing telecommunications huts in wetlands. A permit is not required to bore under wetlands or streams or to plow in wetlands.

Directional drilling can often result in inadvertent releases of drilling mud to the surface (“frac out”). If a frac out occurs in a stream or wetland, the discharge is considered fill that would require a permit. Some applicants expect frac outs to occur and include potential discharges resulting from a frac out in a permit application. If an unexpected, unpermitted frac out occurs, it will be necessary to contact the Corps to request an emergency permit.

If the Project does include activities that would require a Section 404 permit, they would likely be covered under the General Permit 2 (GP-002-WI).

Section 10 Permits (Rivers and Harbors Act of 1899) Section 10 permits are needed to install fiber optic cable across navigable waterways using either aerial or underground methods. Navigable Waters of the United States within the State of Wisconsin that will be crossed by the Project include: • Bad River • Bois Brule River • Duck Creek • Nemadji River • Oconto River • Peshtigo River • St. Louis River • Suamico River (Big Suamico River)

Utility crossings of navigable waters would be addressed under the Nationwide Permit 12.

Merit REACH-3MC II Final Environmental Assessment (7/15/2011) 131 Application Process It is likely that the Project would require multiple permits given the fact that the two spurs are proposed in Wisconsin, and the potential for activities that would require permits under both Section 404 and Section 10. The process of applying for permits from the Corps begins with submitting an application to the Wisconsin Department of Natural Resources who will distribute the application to the appropriate Corps personnel.

The timeframe for reviewing the application is typically 60 days but may be as long as 120 days for larger projects.

U.S. Fish and Wildlife Service, Endangered Species Act , Section 7(c) NTIA contacted the U.S. Fish and Wildlife Service (USFWS) in October 2010. Since then the Project Team has contacted the Field Offices located in East Lansing, MI, Green Bay, WI, and Bloomington, MN (Twin Cities).

The East Lansing Field Office coordinated its review with the Green Bay Field Office and issued a clearance letter for Michigan and Wisconsin on June 23, 2011. The Twin Cities Field Office issued its clearance on April 7, 2011.

No further coordination is necessary.

National Historic Preservation Act, Section 106 NTIA initiated correspondence with the State Historic Preservation Offices in Michigan, Wisconsin and Minnesota on September 24, 2010.

An Application for Section 106 Review was sent to the Michigan State Historic Preservation Office on December 22, 2010. The Michigan SHPO issued its clearance letter on July 15, 2011.

No further coordination is necessary.

An Application for Section 106 Review was sent to the Wisconsin State Historic Preservation Office on November 10, 2010. The Wisconsin SHPO issued its clearance letter on June 23, 2011.

No further coordination is necessary.

An Application for Section 106 Review was sent to the Minnesota State Historic Preservation Office. The Minnesota SHPO issued its clearance letter on March 22, 2011.

No further coordination is necessary.

U.S. Forest Service, Special Use Permits The proposed Project will cross four rights-of-way in four U.S. National Forests:

• Huron-Manistee National Forest • Hiawatha National Forest • Ottawa National Forest • Chequamegon-Nicolet National Forest.

The Project Team initiated correspondence with each of the National Forests on November 30 and December 1, 2010. Representatives of all four National Forests have responded that a Special Use Permit will be needed to cross National Forest lands.

Representatives from each of the four National Forests have issued a letter to the Regional Forester (Region 9) requesting that the Special Use Permit be administered by the individual forests in lieu of a Regional Permit. A response to that letter has not been issued yet.

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The Project Team will coordinate with the appropriate National Forest representatives to obtain the necessary permits prior to beginning construction.

MICHIGAN

Wetland and Waterway Crossings, Michigan Natural Resources and Environmental Protection Act (Act 451 of 1994), Parts 31 (floodplains), 301 (inland lakes and streams), 303 (wetlands) A permit application for crossing rivers, streams and wetlands will be submitted to the MiDNRE as soon as engineering plans are finalized. The Project qualifies as a minor project; the agency has up to 60 days to respond to a permit application request.

Endangered and Threatened Species Protection, Michigan Natural Resources and Environmental Protection Act (Act 451 of 1994), Part 365 Endangered Species Protection The Project Team initiated consultation with the MiDNRE Wildlife Division on November 8, 2010; a response providing a list of listed species that may be impacted by the Project was received on January 7, 2011. A clearance letter was issued on April 26, 2011.

No further coordination is necessary.

Coastal Zone Management Program, Coastal Zone Management Act, PL 92-583, Section 307 The Project Team initiated correspondence with the MiDNRE Great Lakes Shorelands Unit on December 16, 2010.

A response stating that receipt and compliance with applicable permits constitutes certification of consistency with Michigan’s Coastal Zone Management Program was received on January 13, 2011.

No further coordination is necessary.

Natural Rivers Crossings, Michigan Natural Resources and Environmental Protection Act (Act 451 of 1994), Part 305 A permit application for crossing state-designated Natural Rivers will be submitted to MiDNRE as soon as engineering plans are finalized.

National Pollution Discharge Elimination System (NPDES) Permit Program, Construction Storm Water Coverage under Permit by Rule, Michigan Natural Resources and Environmental Protection Act (Act 451 of 1994), Part 31 Administration of the NPDES Stormwater Program has been delegated to the MiDNRE. Construction activities that disturb 5 acres or more, with a point discharge to surface waters of the state, are required to submit a Notice of Coverage to obtain an NPDES stormwater permit. Prior to submitting the Notice of Coverage, the permittee must first obtain a Soil Erosion and Sedimentation Control permit from the local permitting agency for earth disturbances greater than 1 acre in size or within 500 feet of a lake or stream.

The Project Team will coordinate with the state and local agencies responsible for administering the NPDES Permit Program to obtain the necessary permits prior to beginning construction.

Merit REACH-3MC II Final Environmental Assessment (7/15/2011) 133 WISCONSIN

Wetland and Waterway Crossings, Wisconsin Statute Chapter 30 (Placing a utility line across waterways), Wisconsin Administrative Code, NR 299 (water quality certification) Projects that involve trenching or plowing a utility line through a waterway require a Chapter 30 (Wis. Stats.) permit from the Wisconsin Department of Natural Resources (WiDNR). A permit is not required to directionally bore a utility line under waterways.

Projects that involve placing fill in a wetland require a NR299 (Wis. Adm. Code) water quality certification (WQC) permit from the Department. Fill can include a pedestal, pole, or backfilling a trench or bore pit. Projects involving directional boring or vibratory plowing do not require a permit.

The Project Team will continue to coordinate with the WiDNR staff to ensure that the necessary permits are acquired.

Endangered and Threatened Species Protection, Wisconsin Statute 29.604 Endangered and Threatened Species Laws and Administrative Rule NR 27 The Project Team initiated consultation with the WiDNR Office of Energy on November 8, 2010; a response providing a list of listed species that may be impacted by the Project was received on December 15, 2010. The WiDNR issued its clearance letter on June 20, 2011.

No further coordination is necessary.

Wisconsin Coastal Management Program The Project Team initiated correspondence with the Wisconsin Coastal Management Program on December 15. 2010.

A response stating that receiving Chapter 30 permits from WDNR will result in federal consistency concurrence was received on January 12, 2011.

No further coordination is needed.

Wisconsin Pollutant Discharge Elimination Program, Wisconsin Administrative Code, NR 216 The Project Team will coordinate with the state and local agencies responsible for administering the NPDES Permit Program to obtain the necessary permits prior to beginning construction.

MINNESOTA

Wetland and Waterway Crossings, Minnesota Statutes 84.415 and Minnesota Rules Parts 6135.0100 to 6135.1800 A Utility License from the Minnesota Department of Natural Resources (MnDNR) Division of Lands and Minerals will be needed to install a utility under public waters or wetlands.

The Project Team will coordinate with the MnDNR staff responsible for administering the Utility License Permit Program to obtain the necessary permits prior to beginning construction.

Endangered and Threatened Species Protection, Minnesota Endangered Species Statute, Chapter 84, Department of Natural Resources 84.0895 The Project Team initiated consultation with the MnDNR on November 8, 2010. A response stating that the Project will no negatively affect any known occurrences of rare features was received on April 7, 2011...

Merit REACH-3MC II Final Environmental Assessment (7/15/2011) 134 No further coordination is needed.

Minnesota Lake Superior Coastal Program The Project Team initiated correspondence with the Minnesota Lake Superior Coastal Program on December 16, 2010. A response stating that the Project falls below the mandatory federal consistency review threshold was received on January 28, 2011.

No further coordination is needed.

TRIBAL NATIONS

Tower Construction Notification System (TCNS) Responses NTIA notified tribal entities of the proposed project through the Tower Construction Notification System. Three tribes expressed an interest in participating in the Section 106 review process for the Project. These tribes are the Shawnee, Miami Tribe of Oklahoma and the Wyandotte Nation. Clearance from the Shawnee was received on December 14, 2010. Clearance from both the Miami Tribe of Oklahoma and the Wyandotte Nation was received on December 10, 2010.

No other tribal organizations expressed interest in participating in the Section 106 review for the project; several tribes requested to be notified in the event that artifact or human remains are encountered during construction of the Project.

Bad River Band of the Lake Superior Tribe of Chippewa Indians The Project Team contacted the Bad River Band of the Lake Superior Tribe of Chippewa Indians as the Project was originally routed through a known burial ground at Bad River/U.S.-2 crossing. The Project Team met with Tribal representatives to identify routes that would avoid burial ground. A revised route that avoids existing burial ground has been agreed upon. A clearance letter was issued on May 27, 2011.

The Project Team will coordinate with Tribal representatives to meet the conditions outlined in the clearance letter prior to beginning construction.

Lac Vieux Desert Band of the Lake Superior Tribe of the Chippewa Indians As with Round 1 of the REACH-3MC project, the Project Team contacted the Lac Vieux Desert Band of the Lake Superior Tribe of the Chippewa Indians. A clearance letter was issued on January 28, 2011.

Merit REACH-3MC II Final Environmental Assessment (7/15/2011) 135 6.0 CHAPTER 6 – LIST OF AGENCIES AND PERSONS CONSULTED

MICHIGAN

MERIT NETWORK, INC. Phone: (734) 527-5700 Fax: (734) 527-5790 E-mail: [email protected]

Ryan J. Kunzelman Grant Compliance Manager Merit Network, Inc. 1000 Oakbrook Drive, Suite 200 Ann Arbor, MI 48104-6794 Phone: (734) 527-5739 Fax: (734) 527-5790 Cell: (419) 957-6211 E-mail: [email protected]

Bob Stovall Pete Empie VP, Network Operations and Engineering Cell: (517) 420-1600 Phone: (734) 527-5704 E-mail: [email protected] Cell: (734) 476-2288 E-mail: [email protected] Sue Pandian Phone: (734)527-5728 E-mail: [email protected]

MICHIGAN DEPARTMENT OF NATURAL RESOURCES AND ENVIRONMENT

Kate Hayes MDNRE – LWMD Ms. Lori Sargent Permit Consolidation Unit MDNRE- Wildlife Division P.O. Box 30204 Endangered Species Specialist Lansing, MI 48909-7704 P.O. Box 30473 Phone: (517) 241-1578 Lansing, MI 48909-7973 Fax: (517) 241-9003 Phone: (517) 373-9418 E-mail: [email protected] E-mail: [email protected]

Steve Sutton MDNRE – LWMD Chris Antieau Natural Rivers Program Manager MDNRE – LWMD Habitat Management Unit Great Lakes Shorelands Unit P.O. Box 30446 525 West Allegan Street Lansing, MI 48909 P.O. Box 30458 Phone: (517) 241-9049 Lansing, MI 48909-7958 E-mail: [email protected] E-mail: [email protected]

Merit REACH-3MC II Final Environmental Assessment (7/15/2011) 136 (MICHIGAN) SHPO

Dean Anderson Historical Archaeologist State Historic Preservation Office Phone: E-mail: [email protected]

Brian D. Conway Brian G. Grennell State Historic Preservation Officer Cultural Resources Protection Specialist State Historic Preservation Office State Historic Preservation Office Michigan Historical Center Michigan Historical Center 702 West Kalamazoo St. 702 West Kalamazoo St. P.O. Box 30740 P.O. Box 30740 Lansing, MI 48909-8240 Lansing, MI 48909-8240 Phone: Phone: (517) 335-2721 E-mail: [email protected] Fax: (517) 335-0348 E-mail: [email protected]

MINNESOTA

MINNESOTA DNR

Minnesota Department of Natural Resources Central Office 500 Lafayette Road St. Paul, MN 55155-4040 Phone: (651) 296-6157

Mr. Rian Reed Ms. Lisa Joyal Regional Environmental Assessment Ecologist Natural Heritage Review Coordinator Minnesota Department of Natural Resources Division of Ecological Resources 1201 East Highway 2 Minnesota Department of Natural Resources Grand Rapids, MN 55744 500 Lafayette Road, Box 25 218-999-7826 St. Paul, Minnesota 55155 [email protected] 651-259-5109 [email protected] MINNESOTA WILD & SCENIC RIVERS PROGRAM

Rebecca Wooden, Land Use Programs Unit Jennifer Shillcox, Land Use Planner Supervisor Phone: (651) 259-5727 Phone: (651) 259-5717 E-mail: [email protected]

Minnesota Coastal Program Mr. Cliff Bentley, Area Hydrologist Lake Superior Coastal Program 1568 Hwy 2 Two Harbors, MN Phone: 218-834-1441 Fax: 218-834-6639 [email protected]

Merit REACH-3MC II Final Environmental Assessment (7/15/2011) 137

MINNESOTA HISTORICAL SOCIETY

Ms. Mary Ann Heidemann, Manager Governmental Programs and Compliance State Historic Preservation Office Minnesota Historical Society 345 W. Kellogg Blvd. W. St. Paul, MN 55102-1903 Phone: (651) 259-3450 Fax: (651) 282-2374 E-mail: [email protected]

WISCONSIN

WISCONSIN DEPARTMENT OF NATURAL RESOURCES

Benjamin Callen Shari Koslowsky, Conservation Biologist Wisconsin Department of Natural Resources Office of Energy, OE/7 101 S. Webster St. 101 S. Webster St. P.O. Box 7921 P.O. Box 7921 Madison, Wisconsin 53707 Madison, WI 53707-7921 Phone: (608) 261-4382 Phone: (608) 266-2621 Fax: (608) 266-5226 Fax: (608) 261-4380 [email protected]

WISCONSIN COASTAL MANAGEMENT PROGRAM

Kate Angel / Anne Iwata Program and Policy Analyst E-mail: [email protected] Wisconsin Coastal Management Program Michael Friis (contact while K. Angel on leave) DOA/DIR 9th Floor Admin. Bldg. Program Manager 101 East Wilson Street Wisconsin Coastal Management Program Madison, Wisconsin 53708 (608) 267-7982 Phone: (608) 267-7988 [email protected] E-mail: [email protected] [email protected]

WISCONSIN STATE HISTORIC PRESERVATION OFFICE

State Historic Preservation Office Sherman Banker, Compliance Archeologist Division of Historic Preservation and Public History State Historic Preservation Office Wisconsin Historical Society Division of Historic Preservation and Public History 816 State Street, Room 305 Wisconsin Historical Society Madison, WI 53706 816 State Street, Room 306 Phone: (608) 264-6493 Madison, WI 53706 Phone: (608) 264-6504

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FEDERAL

US FOREST SERVICE

Huron-Manistee National Forest Hiawatha National Forest Pat Thompson, Huron Zone Special Uses Sue Alexander, Realty Specialist Mio District, Huron Manistee National Forests US Forest Service 107 McKinley Hiwatha National Forest Mio, Michigan 48647 2727 Lincoln Road Phone: (989)826-3252 ext.3321 Escanaba, MI 48929 Fax: 989-826-6073 Phone: 906-789-3327 E-mail: [email protected] E-mail: [email protected]

OTTAWA NATIONAL FOREST

Ottawa National Forest Michelle Holland, Realty Specialist Supervisor’s Office E 23979 U.S. 2 E6248 US 2 Watersmeet, MI 49969 Ironwood, MI 49938 Phone: 906-358-4021 E-mail: [email protected] Phone: (906) 932-1330

Chequamegon-Nicolet National Forest Joan Cervenka, Special Uses Coordinator Chequamegon National Forest 1170 4th Avenue, South Park Falls, WI 54552 Phone: 715-762-5174 E-mail: [email protected]

US ARMY CORPS OF ENGINEERS

Cale Richter US Army Corp of Engineers Old Fort Square. 211 N. Broadway, Ste. 221. Green Bay, WI 54303 Phone: (920) 448-2824

Merit REACH-3MC II Final Environmental Assessment (7/15/2011) 139

TRIBAL NATIONS

TRIBAL HISTORIC PRESERVATION OFFICES

Bad River Band of Lake Superior Chippewa Indians Tribe Edith Leoso, Tribal Historic Preservation Officer Bad River Band of Lake Superior Tribe of Chippewa 1 Maple Lane P.O. Box 39 Odanah, WI 54861 Phone: 715-682-7123 Cell: 715-682-8286 E-Mail: [email protected]

Ms. Giiwegiizhigookway Martin THPO and NAGPRA Representative Ketegitigaaning Ojibwe Nation Lac Vieux Desert Band of Lake Superior Chippewa Indians P.O. Box 249 E23857 Poplar Circle Watersmeet, MI 49969 Phone: (906) 358-0137 Fax: (906) 358-4850 Cell: (906) 284-3536 E-mail: [email protected]

MIAMI TRIBE OF OKLAHOMA

Rebecca Hawkins, Archaeologist for Shawnee Tribe George Strack, Tribal Historic Preservation Officer Kim Jumper Miami Tribe of Oklahoma Historic Preservation Dept. 202 South Eight Tribes Trail 29 South Highway 69A Miami, Oklahoma 74354 Miami, OK 74354 E-Mail: [email protected] Phone: 918-542-2441

WYANDOTTE TRIBE

Rebecca Hawkins, Archaeologist for Sherri Clemons, Tribal Historic Preservation Officer Tribal Heritage Department Wyandotte Nation 64700 East Highway 60 Wyandotte, Oklahoma 74370 Cell phone: 918-541-0782 E-Mail: [email protected]

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OTTAWA TRIBE OF OKLAHOMA

Rhonda (Dixon) Hayworth Ottawa Tribe of Oklahoma P.O. Box 110 Miami, OK 74355

LAC DU FLAMBEAU BAND OF LAKE SUPERIOR CHIPPEWA INDIANS

Melinda Young, Tribal Historic Preservation Office Lac du Flambeau Band of Lake Superior Chippewa Indians P.O. Box 67 Lac du Flambeau, WI 54538

SAULT STE. MARIE TRIBE OF CHIPPEWA INDIANS OF MICHIGAN

Cecil E. Pavlat, Sr., Cultural Repatriation Specialist Sault Ste. Marie Tribe of Chippewa Indians of Michigan 523 Ashmun Sault Ste. Marie, MI 49783

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