WyoLink and Broadband in Highway Rights-Of-Way

Broadband Task Force Online Meeting June 8, 2020

Version 3F, as of June 5, 2020 WyoLink Re-Cap Current Situation

● Is a Land Mobile Radio (LMR) proprietary technology, is not Cell phone Long Term Evolution (LTE) - 4G or 5G technology ● Awarded in 2005 to vendor after competitive bid process ● System (core and towers) has been designed to/and allows for multiple radio vendors to operate on the system ● Currently 78 towers statewide ● Additional 15 towers under contract – construction ● 500 + users on the system daily ● 16,000 users on the system ● 12,077,923 calls in 2019; up 302,731 from 2018 (11,775,192) ● 98% statewide coverage ● $120 million invested into the system ● Designed to allow local agencies to migrate onto the system as their funding allows ● Built as inter agency (command & control) network; not as a Tactical network

2 WyoLink - Tower Locations

3 As of April 10, 2020 PCE=Portable Coverage Enhancement site WyoLink - Expansion Opportunities Current WyoLink

● Tower site sharing with Internet Service Providers ○ Have already shared tower locations with interested providers ○ Sites have to be analyzed individually ○ Concerns that get addressed: ■ Vertical separation (space available between txm & rcv dishes) ■ Size and weight of provider equipment ■ Wind analysis ■ Interference ■ Security (building and property)

● 16 New Towers ○ Under contract and under construction, utilizing Federal Highway Administration (FHWA) funds: ■ General area of: Buffalo, Wright, Orin Junction, Evanston, Jackson, Rock Springs 1, Rock Springs 2, Newcastle, Alcova, Bondurant, Northern Goshen County, Sundance, Greybull (Basin), Lusk, Ten Sleep, Northern Big Horn

4 WyoLink - Expansion Opportunities Moving Forward - Future WyoLink

● Requested 12 new towers from list of 17 expansion sites ○ Under consideration for utilizing Covid-19 funds if deemed as appropriate: ■ General area of: Saratoga, Northern Sheridan County, North Albany County, South Albany ■ County, Ranchester, Flaming Gorge, South East Sweetwater County, South Uinta County ■ South Jackson/Teton, I-90 East Buffalo/West Gillette, Ethete/Dinwoody (Fremont County) ■ Southern Carbon County, Southern Sublette, U-Cross (Johnson/Sheridan County), Southern ■ Goshen County (Yoder), Togwatee, North Fork West of Cody

5 WyoLink - Tower Locations Tower Locations and Approximate Fiber in Rights-Of-Way

As of April 10, 2020 PCE = Portable Coverage Enhancement site 6 WyoLink - Expansion Opportunities Moving Forward - Future WyoLink ● Additional WyoLink Towers (Could Augment State and Local Broadband Capability) - ($12,000,000) Submitted May 28 (#16) This request would provide coverage to known areas with existing coverage gaps 12 new sites at $1,000,000 each. Note: anticipate 3 could be built by December 30, 2020, contracted for other 9 sites.

● Installation of Fiber Optics at WyoLink sites (map on next slide) - ($1,000,000) Submitted May 28 (#15) This request would harden connectivity for robust reliability and would promote collocation opportunities for Broadband providers.

● WyoLink Inter Subsystem Interface (ISSI) connection - ($150,000) Submitted June 1 (#18) This request would provide expanded interoperability allowing connection with other vendor systems and technologies (LMR Land Mobile Radio /LTE Long Term Evolution 4G/5G).

● WyoLink and WYDOT Microwave/Backhaul Upgrade - ($21,000,000) Submitted May 28 (#13) This request would upgrade the end of life microwave equipment WyoLink utilizes to a state of the art (Broadband Ethernet) network capable of carrying other WYDOT technologies (i.e., cameras, VSL, DMS, etc.). 7 WyoLink - Microwave vs Fiber Tower Locations - Potential for Fiber Connectivity

As of April 10, 2020 PCE - Portable Coverage Enhancement site 8 WYDOT Broadband Procedures Policy and Agreements

● Dig Once ○ Working with service providers in sizing number of conduits and number of fiber strands. Reduces the need to have to revisit additional capacity in already crowded right-of-way (ROW) highway corridors for utilities.

● Utilities Department ○ Works and coordinates with internet service providers and district engineers on broadband in ROW projects ○ Refining policies and procedures ○ Shared Resource Agreement ○ M54 Utility Agreement (standard)

9 WYDOT Broadband Procedures NEPA Requirements

● If there is no federal nexus, NEPA does not apply.

● If there is a federal nexus, NEPA does apply: ○ Projects with a federal nexus (anticipated for CARES Act) ■ Federal nexus = federal funding or action on federal land ○ NEPA document required to provide a review and disclosure of environmental impacts ○ Most WYDOT actions with federal nexus are handled with a Categorical Exclusion (CE): ■ CE used for a project that does not have a significant effect on the human environment ■ Expected time frame: 3 to 6 months • 6 months if wetland, cultural, etc. clearances needed ■ Environmental Assessment or Environmental Impact Statement would take longer

● WYDOT utility permit (required to construct in highway right-of-way) ○ Approval time frame - 2 weeks ■ Final NEPA document (if applicable) required for permit approval

10 WYDOT Broadband Procedures Right-of-Way Acquisition and Eminent Domain

● General Right-of-Way Acquisition Information: ○ Engineering & Appraisal - 100 business days or 5 months ○ Easement or Deed (requires land survey) - 100 business days ○ Landowner negotiation estimate - 60 days ○ Unwilling landowner move to eminent domain (W.S. 1-26-501) ■ WYDOT could condemn for installation of fiber to WyoLink tower ■ Statute requires 90 days for landowner to consider offer ■ WYDOT process: • Initial Offer - 65 day letter • Final Offer - 15 day letter • File condemnation paperwork - 10 days • Landowner served - unknown • Court sets hearing date - unknown ○ With court delays caused by COVID-19, getting a court date will be late 2020 / early 2021 ○ Not feasible to acquire property prior to December 30, 2020 11 Utah Broadband Procedures UDOT General Principles (see attached documents) ● Public Private Partnerships ○ Utah changed its state law in the 1990s to allow companies to lease or barter in-kind for access within interstate rights-of-way under certain conditions. ○ Underserved communities are getting high speed connectivity by partnering with UDOT.

● Value of Interstate and Federal-Aid Rights-of-Way Enables Public/Private Partnerships ○ The property value of linear highway corridors is a major incentive enabling public/private partnerships. ○ Large value of using expansive linear corridors relatively free of obstructions and other utilities.

● States and Local Agencies Control Highway Rights-of-Way ○ A secondary benefit of highway rights-of-way is accommodation of public utilities.

● Interaction with Federal Land Agencies ○ In exchange for use of UDOT right-of-way, telecoms provide fiber and conduit - allowing UDOT to communicate with its variable message signs, CCTV cameras, weather sensors, traffic sensors, traffic signals, maintenance sheds and any other device or location that needs to be connected to the traffic network. 12 WyoLink & Broadband in Rights-Of-Way

Question and Answer

13 Helpful Links to Utah Code and Rules on Telecommunication Facilities & Other Items

72-7-108. Longitudinal telecommunication access in the interstate highway system https://le.utah.gov/xcode/Title72/Chapter7/72-7-S108.html?v=C72-7-S108_1800010118000101

Rule R907-64. Longitudinal and Wireless Access to Interstate System Rights-of-Way for Installation of Telecommunication Facilities. https://rules.utah.gov/publicat/code/r907/r907-064.htm

Rule R907-65. Compensation Schedule for Longitudinal Access to Interstate Highway Rights-of-Way for Installation of Telecommunications Facilities. https://rules.utah.gov/publicat/code/r907/r907-065.htm

Rule R930-7. Utility Accommodation. https://rules.utah.gov/publicat/code/r930/r930-007.htm

UDOT Fiber Map http://projects.horrocks.com/arcgis/udotfiber.html

UDOT Top Ten Fiber Priorities https://uplan.maps.arcgis.com/apps/MapSeries/index.html?appid=43c32f052da8491ab565b1e42e45a1c1

UDOT UPlan http://uplan.maps.arcgis.com/home/index.html

Fiber Optic Trade - Requires a login http://projects.horrocks.com/UDOTTradeTicket/Login.aspx

UDOT Fiber Channels – Requires a login http://projects.horrocks.com/UDOTChannels/Login.aspx?redirect=http%3a%2f%2fprojects.horrocks.co m%2fUDOTChannels%2fOverview.aspx

UDOT System Health – Requires a login http://511.commuterlink.utah.gov:9090/

FIBER AND CONDUIT LEASE AGREEMENT BETWEEN TELECOMMUNICATION PROVIDER AND THE UTAH DEPARTMENT OF TRANSPORTATION

This Master Agreement “Master Agreement” is entered into this ____ day of ______2020 by and between the Utah Department of Transportation, hereinafter designated as “UDOT”, an agency of the State of Utah, whose principal office is located at 4501 S. 2700 West, Salt Lake City, Utah 84119, and TELCO NAME, Inc., hereinafter designated as “TELCO”, whose principal office is located at ADDRESS, CITY, STATE ZIP. UDOT and TELCO are hereafter sometimes collectively referred to as “parties” and either may be individually referred to as a “party”, all as governed by the context in which such words are used.

RECITALS

WHEREAS, UDOT is the owner of several rights of way which UDOT has acquired for the development and expansion of its highway system and the preservation of transportation corridors that could be useful to TELCO;

WHEREAS, UDOT and TELCO own and operate separate fiber optic systems and conduit infrastructures in Utah; and,

WHEREAS, UDOT and TELCO have both determined that the interest and welfare of the public will best be served by the parties cooperating to share each other’s fiber optic system and conduit infrastructure where reasonably possible; and

WHEREAS, the parties have entered this Master Agreement to define a comprehensive process where each party can identify existing excess capacity in the fiber optic system and conduit infrastructure of the other party and utilize that capacity.

AGREEMENT

NOW THEREFORE, in accordance with the foregoing Recitals, which are incorporated into this Master Agreement by reference, and for and in consideration of the mutual covenants and agreements hereafter set forth, the mutual benefits to the parties to be derived herefrom, and for other valuable consideration, the receipt and sufficiency of which the parties acknowledge, it is hereby agreed as follows:

1. Fiber Optic System Capacity. UDOT and TELCO will each identify those fiber optic systems (hereafter generally referred to as “Infrastructure”) owned by the other which potentially provide desirable communication connections. Where the Infrastructure has capacity, the owner shall cooperate in good faith with the requesting party to allow the requesting party to utilize the capacity to meet the requesting party’s communications needs. For purposes of this Master Agreement, Infrastructure includes dedicated fiber optic cables, or individual strands of fiber optic cables. Infrastructure may also include conduits, innerducts, handholes, junction boxes, hubs, other improvements constructed as part of each party’s fiber optic system, and any communication transport service that may be useful to either party. 2. Identification of Initial Infrastructure; Identification of Additional Infrastructure. Prior to the execution of this Master Agreement, the parties identified certain UDOT-owned Infrastructure which TELCO desires to use and certain TELCO-owned Infrastructure which UDOT desires to use. The identified Infrastructure is shown on the Balance Sheet of shared Infrastructure (the “Balance Sheet”) attached as Exhibit “A.” During the term of this Master Agreement, the parties shall continue to cooperate to identify capacity within additional existing and future Infrastructure, and to make that capacity available to each other on a mutually beneficial basis. The parties agree to periodically execute updates to the Balance Sheet as necessary to identify additional Infrastructure for which use rights are granted under this Master Agreement. Each update to the Balance Sheet shall: (a) describe with reasonable specificity the Infrastructure that is subject to this Master Agreement and the corresponding use rights granted with respect to such Infrastructure; and (b) identify the effective date of the use rights granted. Updates to the Balance Sheet shall be executed by the designated representatives of each party. Upon the execution of an updated Balance Sheet as set forth in the preceding sentence, each party shall append and attach the updated Balance Sheet to this Master Agreement and such updated Balance Sheet shall be automatically incorporated into this Master Agreement by reference. Upon execution, such updated Balance Sheet shall replace and supersede all prior Balance Sheets previously executed by and between the parties. As used in this Agreement, the term Infrastructure refers to the fiber optic systems identified in the Balance Sheet and any replacement facilities that are constructed by each party from time to time.

3. Limitation on Each Party’s Commitment under Master Agreement. Neither party shall be required to make its Infrastructure available to the other where such owning party determines, in its sole discretion, that: (a) existing capacity is needed to meet the owner’s projected future needs with respect to the Infrastructure; (b) the other party’s proposed use will have a material, adverse effect upon the ownership, use or maintenance of the owner’s Infrastructure; or (c) the other party’s proposed use will violate any law, administrative rule, restriction, restrictive covenant or other legal requirement applicable to the owner, the Infrastructure or the real property underlying the Infrastructure.

4. Consideration. The purpose of this Master Agreement is to establish a cooperative and equitable process where capacity in parallel corridors is utilized to avoid duplicative Infrastructure. The parties’ mutual goal is to reduce the overall cost of operation for both parties. The parties desire to create a process that will encourage and expedite the shared use of Infrastructure. In this spirit, the parties agree as follows:

4.1 It is intended that both parties will benefit from this Master Agreement and that the respective benefits to each party will be approximately equal over time. The parties agree to grant one another the right to use the Infrastructure with the calculated value for that access mutually agreed upon by both parties. All interstate values as defined by Utah Code – 72-07-108 will also be presented for valuation oversight to the Telecommunications Advisory Council as defined by Utah Code 72-07-109. 4.2 The parties shall strive to ensure that the benefits provided under this Master Agreement, as identified in the Balance Sheet, remain approximately equal over time as defined by Utah Code 72-07-108 –Longitudinal telecommunication access in the interstate highway system.

5. Nature of Rights Granted. The rights granted in accordance with this Master Agreement shall be for the use of the Infrastructure capacity for a period of years. This Master Agreement does not contemplate the sale or transfer of any real or personal property associated with the Infrastructure. Subject to the limitations identified in Paragraph 3, each party has the right to use the Infrastructure capacity for any purpose, consistent with the party’s respective mission(s), provided that such use does not violate the law or does not threaten the technical or operational integrity of the Infrastructure as a whole or the other party’s Infrastructure capacity.

6. Construction and Maintenance Performed Under Master Agreement. The Infrastructure use rights granted pursuant to this Master Agreement will likely require the parties to coordinate construction and maintenance issues that are unique to each portion of the Infrastructure identified in the Balance Sheet. The parties agree to cooperate with respect to such issues in good faith, in a manner consistent with the intent of this Master Agreement and according to the following general principles:

6.1 Unless otherwise agreed, each party shall be responsible for any construction, reconstruction, installation, splicing or other capital project costs that are necessary to connect to the fiber optic system of the other party. This includes, by mutual agreement, costs associated with remediating damaged conduit, junction boxes or fiber optic cables approved for lease. Costs incurred to make such repairs will be included in the Balance Sheet to maintain a fair and equitable trade.

6.2 With respect to each portion of Infrastructure for which use rights are granted under this Master Agreement, the granting party shall have reviewed and approved design, construction and work plans for all construction, reconstruction, installation, connection, splicing or other work to be performed by the other party.

6.3 UDOT and TELCO each agree to not perform any construction, reconstruction, fiber installation, connection, splicing, or other work with respect to the fiber optic system of the other party (including the optical fiber strands for which the other party has granted use rights under this Master Agreement) without providing notice to, and receiving prior approval from, the other party. Access that requires a permit will follow standard permit procedures, including the payment of standard permit fees.

6.4 Each party shall be responsible for the routine costs of operating and maintaining its own Infrastructure, including any conduit, cables, fiber, boxes or other facilities used by the other party pursuant to this Master Agreement. 6.5 Each party will operate and maintain its Infrastructure in a manner that avoids unreasonable disruptions to the service of the other party. Except as otherwise provided in Section 10 of this Master Agreement, in the event of a disruption to service to any Infrastructure for which use rights have been granted to the other party, each party agrees to cooperate with the other party and to use commercially reasonable efforts to reinstate the other party’s communication connection as quickly as practicable.

6.6 TELCO will relocate their facilities on UDOT Right-of-Way in conformance with Utah Administrative Code R930-8, Utility Relocation Required by Highway Projects.

6.7 TELCO shall be responsible for 100 percent of relocation costs of their own infrastructure within the interstate right-of-way as defined by 72-7-108 (5). UDOT shall participate in relocation of infrastructure on highway projects as defined by 72-6-116.

6.8 Any and all infrastructure constructed for UDOT by TELCO shall be built in conformity with the current edition of UDOT Standards and Specifications.

7. Right to Enter. Each party reserves the right to enter the buildings or other structures of the other party (at reasonable times and with notice to the other party) as necessary to inspect and operate any communications systems and equipment that are used pursuant to the use rights granted under this Master Agreement.

8. Duration and Termination of Rights Granted. Unless a shorter duration is specifically provided for herein (or in the Balance Sheet incorporated into this Master Agreement), the use rights granted with respect to any Infrastructure shall be effective on the date first set forth in the Balance Sheet and shall thereafter continue for an initial period of thirty (30) years. At the conclusion of the initial thirty (30) year period, the use rights shall renew automatically for up to four (4) successive, consecutive five-year renewal terms unless and until terminated by written notice delivered by either party at least sixty (60) days prior to the expiration of the initial term or any subsequent five-year renewal term. Should this Master Agreement be terminated neither party shall be permitted to remove any Infrastructure added by such party without the written consent of the other party.

9. Termination of Use Rights for Default. Notwithstanding Section 8 of this Master Agreement, either party may terminate, for default, the use rights it has granted to the other party with respect to any specific portion of the Infrastructure. A party may terminate specified use rights for default in the event that the other party continues in material breach of any provisions of this Master Agreement for a period of thirty (30) days following the delivery of written notice from the non-defaulting party, which notice identifies the breach with specificity and demands the cure thereof (provided, however, that with respect to any breach that is not reasonably capable of cure within 30 days, the breaching party shall not be deemed in default if it commences commercially reasonable efforts to cure the breach within 30 days and thereafter diligently and continually pursues such efforts to completion). 10. Termination of Use Rights for Force Majeure Events. Notwithstanding Section 8 of this Master Agreement, either party may terminate the use rights it has granted to the other party: with respect to Infrastructure that is destroyed or rendered unusable by a Force Majeure Event, and provided that the terminating party does not undertake efforts to reconstruct or repair such Infrastructure within one hundred eighty (180) days following the Force Majeure Event. As used in this Section, the term “Force Majeure Event” means any event, whether foreseeable or unforeseeable, that prevents, nullifies or interferes with the enjoyment of the use rights granted pursuant to this Master Agreement provided that such event is beyond the reasonable control of the granting party and not attributable to fault or malfeasance on the part of the granting party. Force Majeure Events include, without limitation, the following: floods, earthquakes, fires, landslides, tornadoes, explosions, civil disturbances, acts of God or the public enemy, terrorist acts, military actions, actions of a court or public authority or labor disturbances/work stoppages.

11. Limitation on Warranties. Each party agrees that, subsequent to the grant of use rights pursuant to this Master Agreement, such party will not grant any additional rights to third parties, or take other affirmative actions, which materially impair the exercise of the use rights granted to the other party. Except as specifically provided in the preceding sentence, all use rights contemplated under this Master Agreement are granted with respect to the Infrastructure on “AS-IS” “WHERE-IS” basis, subject to all existing conditions, restrictions and encumbrances, and without any express or implied warranties whatsoever.

12. Term of Master Agreement. This Master Agreement shall be effective upon the date that it is fully executed by the parties and shall thereafter continue for thirty (30) years with four (4) five-year automatic renewals, unless earlier terminated as provided herein. Either party may terminate this Master Agreement with cause at any time by providing not less than thirty (30) days written notice to the other party. The termination of this Master Agreement shall not affect any rights granted hereunder prior to termination (which shall continue as set forth in Sections 8, 9 and 10 of this Master Agreement).

13. Mediation. In the event of any action, controversy or claim between the Parties arising out of or relating to this Master Agreement, or the breach thereof, the Parties shall first engage in mediation to attempt to resolve the controversy, claim, or breach or they may select a mutually acceptable mediator to do so. Parties shall bear their respective costs incurred in mediation.

14. Costs of Enforcement. If either party files an action to enforce any covenant or condition of this Master Agreement, the prevailing party shall be entitled to reasonable attorney’s fees, and all costs associated with enforcement of this Master Agreement.

15. Indemnification. Subject to the other provisions of this Section, each party agrees to indemnify and save harmless the other for damages, claims, suits and actions arising out of its own actions or omissions or the acts or omissions of its officers, agents, or employees in connection with this Master Agreement. It is expressly agreed between the parties (i) that the obligation to indemnify is limited to the dollar amounts set forth in the Governmental Immunity Act, Utah Code 63G-7-101 and is further limited only to claims that arise from the negligent acts or omissions of the indemnifying party and (ii) that this provision is not a waiver of the Governmental Immunity Act by either party.

16. Notices. Any notice, demand, request, consent, submission, approval, designation or other communication which either party is required or desires to give under this Master Agreement must be made in writing and mailed to the designated recipient and at the address set forth below. Such notices shall be hand delivered, mailed (by first class mail, postage prepaid) or sent by recognized courier or delivery service. Notices shall be effective upon receipt.

If to TELCO, at: with a copy to: COPY TO COPY TO Address Address City, State ZIP City, State ZIP PHONE PHONE

If to UDOT, at: with a copy to: Utah Department of Transportation Utah Department of Transportation Fiber Optics Manager Assistant Attorney General’s Office Lynne Yocom P.O. Box 148455 2060 South 2760 West Salt Lake City, UT 84114-8455 Salt Lake City, Utah 84104-4592 by courier or overnight mail: Utah Department of Transportation Assistant Attorney General’s Office 4501 South 2700 West Taylorsville, UT 84129

Either party may change its designated representative or the address for the receipt of notices by delivering written notice of such change to the other party according to the provisions of this Section.

17. Governing Law. This Master Agreement will be governed by the laws of the State of Utah, both as to interpretation and performance and without regard to conflict of law. It will be enforced only in a court of competent jurisdiction located in Utah.

18. Severability. If any provision of this Master Agreement will be held or deemed to be or will, in fact, be illegal, inoperative or unenforceable, the same will not affect any other provision or provisions herein contained or render the same invalid, inoperative or unenforceable to any extent whatsoever. 19. Entire Agreement; Amendment. This Master Agreement contains the entire agreement between the parties with respect to the subject matter hereof, and no statements, promises, or inducements made by either party or agents of either party that are not contained in this Master Agreement will be binding or valid. This Master Agreement may not be amended, enlarged, modified or altered except through a written instrument which is signed by both parties.

20. Assignment. Neither party may assign or delegate the rights or obligations of this Master Agreement without the written consent of the other party, provided that consent shall not be unreasonably withheld for assignment to other Governmental entities. Notwithstanding the foregoing, TELCO may assign or transfer its rights, privileges and obligations to a parent, affiliate or subsidiary company with written notice to UDOT or to an entity that succeeds to substantially all of its assets, whether by merger, sale or otherwise, with the prior written approval of UDOT, which approval shall not be unreasonably withheld. It shall be unreasonable for UDOT to fail to approve a transfer of substantially all of TELCO’s assets where TELCO can demonstrate that such successor has obtained a UDOT Statewide Utility License Agreement. For purposes of this Agreement, use of TELCO infrastructure by third parties shall not constitute an assignment or transfer of privileges.

21. Binding Effect. This Master Agreement shall bind the parties, their successors and assigns.

22. Captions. The captions to the various sections of this Master Agreement are for convenience and ease of reference only and do not define, limit, augment, or describe the scope, content, or intent of this Master Agreement or any parts of this Master Agreement.

23. Time. Time is of the essence of each term, provision, and covenant of this Master Agreement.

24. Multiple Counterparts. This Master Agreement may be executed in any number of counterparts and by either of the parties hereto on separate counterparts, each of which when so executed and delivered shall be an original, but all such counterparts shall together constitute but one and the same instrument. Any signature page of this Master Agreement may be detached from any counterpart and reattached to any other counterpart hereof. The facsimile transmission of a signed original of this Master Agreement or any counterpart hereof and the retransmission of any signed facsimile transmission hereof shall be the same as the delivery of an original.

IN WITNESS WHEREOF, the parties have each executed this Master Agreement as of the date first set forth above.

UTAH DEPARTMENT OF TELCO, INC. TRANSPORTATION

By: By: ______

Jason Davis, P.E. SIGNATOR UDOT Director of Operations TITLE

APPROVED AS TO FORM AND CONTENT

______

Jim Palmer Assistant Attorney General

EXHIBIT “A” Balance Sheet

DESCRIPTION OF USE RIGHTS GRANTED UNDER 2016 MASTER AGREEMENT REGARDING SHARED FIBER FACILITIES

The Balance Sheet shall consist of a cumulative compilation of all Conduit Use Request and Authorization forms for each of the trades from either party. Each of the lines on the Balance sheet shall consist of a signed Conduit Use and Authorization Form. The Master Agreement Balance Sheet is based on a foot-for-foot conduit and fiber trade according to Section 4 of this Master Agreement. Any differences between quantities are tracked by the Balance Sheet for each party detailed below, and are based on current Department contract pricing. Any outstanding amounts owed according to the Balance Sheet will be updated during future transactions for the purposes of future trades, land access right-of-way fees or other mutually agreed upon items. Banked values can be converted back to full foot-for-foot or other trade values for subsequent transactions, but are shown in dollar value for outstanding banked balances. The parties shall not provide cash or other direct compensation for amounts shown in the Balance Sheet.

Master Agreement Transaction #1 – Balance Sheet

The following details each of the Conduit Use Request and Authorization forms: Integra Realty Resources Salt Lake City

Appraisal of Real Property Longitudinal Telecommunication Access in the Interstate Highway System

Location Interstates 15, 70, 80, 84 and 215 Utah State

Prepared For Utah Department of Transportation

Effective Date of the Appraisal February 1, 2016

IRR – Salt Lake City File: 160-2016-0139

5107 SOUTH 900 EAST, SUITE 200, SALT LAKE CITY, UT 84117 PHONE 801.263.9700 FAX 801.263.9709

February 19, 2016

Lyle McMillan PIN: 11618 Right of Way Director Program 71622 Phase 10H Utah Department of Transportation Fourth Floor - South 4501 South 2700 West Taylorsville, Utah 84114

RE: Longitudinal Telecommunication Access in the Interstate Highway System - Update

Lyle McMillan:

Thank you for allowing our office to assist in determining a fair and reasonable value of compensation that will allow telecommunication facility providers longitudinal access within the interstate highway system of Utah. The highway system of Utah for this analysis is defined as Interstate 15, Interstate 70, Interstate 80, Interstate 84, and Interstate 215. A market analysis was conducted to determine the fair and reasonable values of the right of way based upon adjacent property values to encourage the deployment of digital infrastructure within the state. Based on market data, land uses, and population, 47 zones are recognized within 9 values.

The report is prepared in a manner to conform to Uniform Standards of Professional Appraisal Practice (USPAP) adopted by the Appraisal Standards Board of the Appraisal Foundation. Summary information of the analysis is contained in the attached report. There is no extraordinary assumption or hypothetical condition made in the analysis.

Respectfully submitted,

Troy Lunt, MAI Utah State - Certified General Appraiser License 5457226-CG-00 (Expires.05/31/17)

Eric Leonhardt, MAI Utah State - Certified General Appraiser License 5450597-CG00 (Expires 03/31/16)

Integra Realty Resources | 5107 South 900 East | Suite 200 | Salt Lake City, Utah 84117 T 801 263 9700 | F 801 263 9709 | www.irr.com/saltlakecity

Table of Contents

Report Summary ...... 1 Report Option ...... 2 Appraisal Date ...... 2 Appraisal Purpose ...... 2 Intended User ...... 3 Real Property Identification ...... 3 Appraisal Scope ...... 4 Extraordinary Assumptions and Limiting Conditions ...... 5 Hypothetical Conditions ...... 5 Property Rights Appraised ...... 5 Fee Simple Estate ...... 5 Real Property Ownership ...... 6 Real Property History ...... 6 Assessment and Taxes ...... 6 Zoning ...... 6 Market Value Definition ...... 7 Market Area ...... 8 Interstate Highway System Description ...... 8 Valuation Process ...... 10 Discounting ...... 11 Determinants of Market Interest Rates ...... 11 Certification Statement ...... 15 Assumptions and Limiting Conditions ...... 16 Qualifications ...... 19 Addendum ...... 23

Report Summary

Subject: Longitudinal telecommunication access in the interstate highway system

Recorded Owners: Public – Utah Department of Transportation

Location: Interstate 15 Interstate 70 Interstate 80 Interstate 84 Interstate 215

Land Use: Express highway

Highest and Best Use: Special-purpose property

Valuation Date: September 30, 2014 Update: February 1, 2016

Value Conclusions: Zone 1 – Barren land: $0.002 per square foot ($0.006 corridor enhancement) Zone 2 – Rangeland: $0.013 per square foot ($0.033 corridor enhancement) Zone 3 – Farmland: $0.10 per square foot ($0.28 corridor enhancement) Zone 4 – Homestead: $0.50 per square foot ($1.33 corridor enhancement) Zone 5 – Neighborhood residential: $1.85 per square foot Zone 6 – Community residential: $4.00 per square foot Zone 7 – Suburban: $7.40 per square foot Zone 8 – Urban: $11.15 per square foot Zone 9 – Prime residential: $15.90 per square foot

Longitudinal Telecommunication Access in the Interstate Highway System Page | 1

Report Option Real property appraisal reports must be prepared under one of the following options: Appraisal Report or Restricted Appraisal Report. This report is prepared following the Appraisal Report option. This means the report content and level of information presented is sufficient to enable the intended user(s) of the appraisal to understand the report properly and is in accordance with Uniform Standards of Professional Appraisal Practice Standard 2-2(a).

Appraisal Date The effective date of the appraisal is September 30, 2014 which is updated to February 1, 2016 to reflect the change in market conditions. The date of the report—or completion date—is February 19, 2016.

Appraisal Purpose Utah Department of Transportation is required to collect compensation from telecommunications facility providers for longitudinal access to highway right of way within the interstate highway system. The appraisal purpose is to provide an opinion of compensation for longitudinal access that is:

- fair and reasonable - competitively neutral - nondiscriminatory - open to public inspection - established to promote access by multiple telecommunication facility providers - established for zones of the state, with zones determined based upon factors that include population density, distance, number of telecommunication subscribers, and the impact upon private right of way users - established to encourage the deployment of digital infrastructure within the state - set after the department conducts a market analysis to determine the fair and reasonable values of the right of way based upon adjacent property values - a lump sum payment or annual installment, at the option of the telecommunications facility provider

Longitudinal Telecommunication Access in the Interstate Highway System Page | 2

Intended User This report is prepared for the use of Utah Department of Transportation, its officers, agents, and representatives.

Real Property Identification The subject appraised is the interstate highway system within Utah State boundaries. Interstate highways are identified as 15, 70, 80, 84, and 215 having a total measured length of 936 miles crossing 17 of Utah’s 29 counties.

Utah Interstate Highway System

Begin Begin End End Interstate Counties Latitude Longitude Latitude Longitude Miles 15 Washington 37.00000 -113.62351 Iron Beaver Millard Juab Utah Salt Lake Davis Weber Box Elder 42.00120 -112.19897 401 70 Millard 38.57735 -112.60337 Sevier Emery Grand 39.19371 -109.05132 232 80 Tooele 40.73808 -114.04356 Salt Lake Summit Rich 41.24752 -111.04668 194 84 Box Elder 41.99942 -112.83357 Weber Davis Morgan Summit 40.97169 -111.43776 80 215 Salt Lake 40.71316 -111.81700 Davis 40.83579 -111.91674 29 Total Miles 936 M ileage is not double counted where highways overlap. M ileage goes to the highway with the lowest designation.

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Appraisal Scope For Utah Department of Transportation to be compensated for longitudinal access within the interstate highway system, Utah Department of Transportation is required to conduct a market analysis to determine the fair and reasonable values of the highways based upon adjacent property values. The appraisal scope is to provide an opinion of fair and reasonable value of the land occupied by the highway system.

Recognizing that land uses and values will differ over the 936 miles of interstate highway, the highway system is distinguished by 47 segments with 9 value zones from a data set of 456 sales. Sales chosen were based on proximity to the interstate highway of which 135 sales have frontage or visibility from the interstate highway. Sources of land value include Wasatch Front Multiple Listing Service, St. George Multiple Listing Service, Integra Realty Resources Datapoint, Beaver County Assessor, Grand County Assessor, Emery County Assessor, Sevier County Assessor, and in-office collection of sales from previous appraisal assignments. No active, expired, or withdrawn listings are used. Sales ranged from less than $0.01 per square foot to $39.83 per square foot over a period of eight years. Each sale is adjusted to market condition of February 1, 2016.

The unit of measure for the interstate highways is a 6-foot wide tract one mile long, or 31,680 square feet (6 feet x 5,280 feet/mile). Unit value is the product of the unit square footage, the zone value per square foot, and a market supported lease rate of 8% annually. The Longitudinal Telecommunication Access in the Interstate Highway System statue allows a maximum term of 30 years with the option to receive the annual payment in a lump sum payment. Using determinants of market interest rates, a discount rate of 8.00%, or a factor of 12.161643 is used to calculate the present value of a 30-year term.

Results of the market research are presented in a table showing the 47 segments with associated zones of value, the annual rent, and the present value of a 30-year term. Segments are identified by the nearest milepost marker moving in the direction of increasing milepost numbering. Segments are not specifically inspected for this assignment. Rather, aerial services were used from online/internet sites.

In some circumstances a corridor, such as a highway or railroad, can have added value. The Dictionary of Real Estate Appraisal defines a corridor as “a strip of land used for transportation or transmission purposes.”1 A corridor has added value because of its ability to connect two points if there is economic advantage to connecting the points. If there are potential users in the market for a corridor, then there is identifiable demand for continued use as a corridor. When the corridor has a definite highest and best use as a corridor, the across the fence methodology with a corridor factor is an acceptable appraisal method. A corridor factor (also called an enhancement factor) is the ratio of market value of a corridor to the corridor’s across the fence value. Some commentators believe the corridor factor multiple is a measure of plottage, an incremental increase in value created by combining separate land parcels to create a corridor.

The derivation of corridor factors from corridor sales is problematic, if not inappropriate as it relates to market value. Although it may seem reasonable to formulate corridor factors from sale transactions, such is dubious because of the conditions surrounding those transactions, including funding sources. For example, 80% of rails-to-trails costs is reimbursed by federal money. So when transaction prices for rails-to-trails transfers are negotiated with both parties knowing the money is coming from a third-party funding source, neither side is negotiating from an economic-based position. Likewise, corridor

1 Source: Appraisal Institute, The Dictionary of Real Estate Appraisal, 5th ed. (Chicago: Appraisal Institute, 2010).

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transactions often involve assemblage considerations, such as expansion of an existing utility distribution system, or some other atypical motivation.

Corridor enhancement is also dependent upon supply and demand. The interstate highway system is an attractive corridor that connects many points throughout Utah. However, there are many competing highways, roads, railroads, and utility corridors. A reasonable supply of alternative corridors to the interstate highway system is available within the Wasatch Front to cause a corridor factor of 1.0. Outside of the Wasatch Front, the interstate highway system has less competition from like routes for telecommunication lines or other utility corridors. For this reason, a corridor enhancement is likely. Areas outside the Wasatch Front are characterized by Zones 1 through 4.

Estimating adjacent property values is the first step in a complex valuation procedure which includes analysis of the highest and best use of the corridor. A factor that reflects the utility of the corridor is developed and applied to adjacent land value to produce a reasonable estimate of market value of the corridor under appraisal. One study showed that this factor ranged from 0.18 to 3.73 times adjacent land value.2 An enhancement factor of 2.5 is reasonable for Zones 1 through 4.

Extraordinary Assumptions and Limiting Conditions An extraordinary assumption is defined as "an assumption, directly related to a specific assignment, which, if found to be false, could alter the appraiser’s opinions or conclusions. Extraordinary assumptions presume as fact otherwise uncertain information about physical, legal, or economic characteristics of the subject property; or about conditions external to the property such as market conditions or trends; or about the integrity of data used in an analysis."3 No extraordinary assumptions or limiting conditions are used for the appraisal.

Hypothetical Conditions A hypothetical condition is defined as "that which is contrary to what exists but is supposed for the purpose of analysis. Hypothetical conditions assume conditions contrary to known facts about physical, legal, or economic characteristics of the subject property; or about conditions external to the property, such as market conditions or trends; or about the integrity of data used in an analysis."4 No hypothetical condition is used for the appraisal.

Property Rights Appraised This appraisal is based on the property rights being in fee simple estate.

Fee Simple Estate Absolute ownership unencumbered by any other interest or estate, subject only to the limitations imposed by the governmental powers of taxation, eminent domain, police power, and escheat. 5

2 See Zoll, “Rail Corridor Sales,” 379-387. 3 Appraisal Institute, The Dictionary of Real Estate Appraisal, 5th ed. (Chicago: Appraisal Institute, 2010). 4 Appraisal Institute, The Dictionary of Real Estate Appraisal, 5th ed. (Chicago: Appraisal Institute, 2010). 5 Appraisal Institute, The Appraisal of Real Estate, 14th ed. (Chicago: Appraisal Institute, 2013), 5. Ownership of the fee simple interest is equivalent to ownership of all individual rights associated with real property – such as the right to sell, lease, give, and mortgage an interest, and the right to occupy the property. Each individual real property right has some potential value. If any or all rights are removed from the fee simple interest, one or more partial interests are created. A true fee simple interest seldom exists. Mortgages, easements, private restrictions, and/or second party mineral right interests encumber most real property. Often the valuation of a fee simple interest is largely theoretical. In this appraisal, valuation of the fee simple estate means ownership not subject to a lease contract.

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Real Property Ownership The 936 miles of interstate highway appraised is publically owned and is managed by Utah Department of Transportation.

Real Property History The interstate highway system was authorized by the Federal Aid Highway act of 1956. The original mileage was complete 35 years later and has expanded since to over 47,000 miles. Final construction of Interstate 80 was near the west edge of Salt Lake City during 1986 making it the first contiguous freeway to span from the Atlantic Ocean to Pacific Ocean.6

Assessment and Taxes Because the interstate highway system is publically owned, it is not subject to county assessment or taxation.

Zoning Traversing the state, left and right of the interstate highways includes recreational, agricultural, residential, industrial, and commercial zones. The most common zone is agricultural in low populated areas and commercial in highly populated areas.

6 "America Celebrates 30th Anniversary of the Interstate System". U.S. Highways (Washington, DC: Federal Highway Administration). Fall 1986. Retrieved March 10, 2012.

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Market Value Definition "Market Value" as used in this report is defined as follows:

"Fair market value" means the amount at which property would change hands between a willing buyer and a willing seller, neither being under any compulsion to buy or sell and both having reasonable knowledge of the relevant facts.7

Market value cannot be predicated upon potential uses that are speculative and conjectural; as the Supreme Court has said:

Elements affecting value that depend upon events or combinations of occurrences which, while within the realm of possibility, are not fairly shown to be reasonably probable should be excluded from consideration, for that would be to allow mere speculation and conjecture to become a guide for the ascertainment of value – a thing to be condemned in business transactions as well as in judicial ascertainment of truth.8

7 Utah Code, 59-2-102 (12)

8 Uniform Appraisal Standards for Federal Land Acquisitions (Washington, D.C.: U.S. Government Printing Office, 2000) 'B-9, pp. 45, 'B-3, pp. 34.

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Market Area The subject is the interstate highway system within the boundaries of Utah State. It crosses 17 of Utah’s 29 counties. Utah is the seventh fastest growing state in the nation over the past year (July 2015).

According to United States Census Bureau, Utah has a population exceeding 2.96 million residents. An estimated 80% of Utah’s population resided within an area known as “Wasatch Front” which basically extends 40 miles north and south of Salt Lake City. The area is known as “crossroads of the west” because two freeway systems pass through Salt Lake City linking Salt Lake City to neighboring population centers. Social, government, economic, and environmental conditions are all favorable.

Interstate Highway System Description The typical interstate highway provides two to six travel lanes with an equivalent travel lane structure in the opposite direction divided man-made barriers or open space. All interstate highways are improved with asphalt or concrete, have no designed interruptions to continuous travel, and no access other than planned interchanges. The interstate highway system within Utah state boundaries is summarized in the following table. Mileage of overlapping interstate is counted to the interstate with the lowest numeral.

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Utah Interstate Highway System

North West Milepost Milepost Name County Latitude Longitude Miles Begin End 15 Washington 37.00000 -113.62351 42 0 42 Iron 37.48188 -113.22076 59 42 101 Beaver 38.14811 -112.61433 31 101 132 Millard 38.57284 -112.60375 62 132 194 Juab 39.32976 -112.08241 48 194 242 Utah 39.93960 -111.81111 44 242 286 Salt Lake 40.45250 -111.91360 26 286 312 Davis 40.82196 -111.91635 26 312 338 Weber 41.15235 -112.02552 14 338 352 Box Elder 41.33624 -112.03435 48 352 400 Total Interstate 15 42.00120 -112.19897 400

70 Millard 38.57735 -112.60337 7 0 7 Sevier 38.59332 -112.50295 87 7 94 Emery 38.78887 -111.29896 69 94 163 Grand 38.97431 -110.15007 68 163 231 Total Interstate 70 39.19371 -109.05132 231

80 Tooele 40.73808 -114.04356 102 0 102 Salt Lake 40.72337 -112.22477 17 102 119 Interstate End 40.76355 -111.91597 Salt Lake 40.71795 -111.90309 16 123 139 Summit 40.75358 -111.62339 53 139 192 Summit Rich 41.20700 -111.10065 4 192 196 Total Interstate 80 41.24752 -111.04668 192

84 Box Elder 41.99942 -112.83357 42 0 42 Interstate End 41.70434 -112.19245 Weber 41.18461 -112.01109 3 81 84 Davis 41.15260 -111.97788 3 84 87 Weber 41.13686 -111.91915 2 87 89 Weber Davis 41.13734 -111.88549 2 89 91 Morgan 41.13852 -111.85635 21 91 112 Summit 41.05280 -111.53002 7 112 119 Total Interstate 84 40.97169 -111.43776 80

215 Salt Lake 40.71316 -111.81700 27 0 27 Davis 40.83224 -111.94456 1 27 28 Total Interstate 215 40.83579 -111.91674 28 Total Interstate 931

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Valuation Process By statue, the interstate highways are valued by using a market analysis of fair and reasonable Sales Data Statistics values of the right of way based upon adjacent Before After property values. Using various sources of land Measure Value Adj $/SF Adj $/SF sales, sales are selected near interstate Sales 456 highways. Statistics of the land sales are shown Highway Exposure 135 in the table to the right. No pending, active, expired, or withdrawn listing/offer is part of the Minimum <$0.01 <$0.01 data. Depending on the number of land sales Maximum $37.94 $42.83 found, sales date back nine years as necessary Mean $4.33 $4.43 to find sales along the interstate highways. For Median $2.10 $2.13 this reason, each sale is adjusted for market Mode $0.02 <$0.01 conditions to represent value expectations as of September 2014. The adjustments are generally positive in years 2006 and 2007, negative during 2008 through 2011, no adjustment for 2012, and positive through 2014. Thereafter, adjustments for market conditions were based on a mass comparison of annual changes in real estate values from 2014 to 2015. Changes varied from -4.25% in communities like Mona and Levan along Interstate 15 to 9.75% in Snyderville Basin along Interstate 80. Adjusted land prices for this assignment found in the addendum are indexed to February 1, 2016 using this method of accounting for market conditions.

Segments of the interstate highways are separated based on population, land use, land value, and competing corridors. Most consideration is given to land values because population and land use are determinants of land value. Nine land values zones are identified from the 456 sales found. The first and last zones are special to a specific location. Zone 1 is the stretch of Interstate 80 from Great Salt Lake to the Nevada state border. Adjacent land to this stretch has poor soil conditions because of salt content. Zone 9 is the east side of Interstate 215 where adjacent land values are prime residential with associated high values. A summary of the sales used for the zone values is located in the addendum to the report.

Segment Summary

Zone Corridor Adj. Zone Zone Value/SF Factor Value/SF Title Description 1 $0.002 2.5 $0.006 Barren Poor soil, salt saturated 2 $0.013 2.5 $0.033 Rangeland Grazing, recreation 3 $0.11 2.5 $0.28 Farmland Irrigated crops 4 $0.53 2.5 $1.33 Homestead Country residential 5 $1.85 1.0 $1.85 Transitional 1 Neighborhood residential 6 $4.00 1.0 $4.00 Transitional 2 Community residential 7 $7.40 1.0 $7.40 Suburban Residential commercial mix 8 $11.15 1.0 $11.15 Urban Business commercial mix 9 $15.90 1.0 $15.90 Bench Prime residential

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Zone 2 – Rangeland These lands are not prime for farm use because of topography or lack of water. The zone includes recreation use but is best suited for grazing. Zone 3 – Farmland These lands are large section of farmable land where water is available for irrigation. The typical price for irrigated land is $2,000 to $3,000 per acre. However, it was found that close proximity to a highway increased the land value. Zone 4 – Homestead These lands are similar to farmland, but measured in acres instead of quarter sections and include a residence. Scenic recreation land with a cabin has similar value. Zone 5 – Transitional 1 These lands are characterized by the beginnings of residential subdivision and public utilities. Zone 6 – Transitional 2 These lands are characterized by a community of residences with a central area containing non-residential improvements such as local retail, post office, chapel, and school. Industrial lands are frequent in this zone. Zone 7 – Suburban These land types exceed community residential in the amount and variety of commercial development and are typically located within 15 miles of government, shopping, and employment centers. Zone 8 – Urban These land types are characterized by a concentration of business and retail uses. Residential use it typically multi-family.

Discounting Telecommunication facility providers have an option to rent interstate highway units for a maximum 30-year term with annual payments or a lump sum. The present value calculation for a 30-year term is requested as part of the assignment. This requires determining a market rate to discount the 30 annual payments into a lump sum payment at the start of the lease.

Determinants of Market Interest Rates In general, the market rate (r) is composed of a pure rate of interest (i) plus several premiums which reflect inflation, the riskiness of the investment, and the marketability (or liquidity) of the investment. This relationship can be expressed as follows:

r = i + IP + DP + LP + MP

Where: i = pure, or real, rate of interest IP = inflation premium DP = default risk premium LP = liquidity premium MP = maturity risk premium

From market analysis of Treasury bills and notes, corporate bonds, and Consumer Price Index, the market interest rate is 10.47%.

10.47% = 1.25% + 2.28% + 1.08%+ 3.50% + 2.36%

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It is common for a lease to include an adjustment to offset the impact of inflation on future monies. Consumer Price Index for all urban consumers is often the measure of adjustment. As of December 2015 the Index is 236.525, which is an annual increase of 0.73% over December 2014. Because a 30-year term is used for the analysis, the mean annual inflation over the past 30 years is used for the lump sum payment calculation. The mean rate of inflation over the past 30 years is 2.70%. Weighting recent years decreases the annual mean to 2.29%. Adjusted for inflation, the discount rate is 8.00% (rounded). The formula is as follows:

1 + 푖 − 1 = 푘 1 + 푔

Where: i = market interest rate g = growth rate k = discount rate

Therefore:

1 + 0.1047 − 1 = 0.079969 1 + 0.0229

Because real estate leases typical require payment at the beginning of the period, the discounting formula is adjusted for one period by multiplying the lump sum or present value of the payments by 1.08. The present value factor is 12.161643.

Table 1 shows the accumulation of analysis for the longitudinal access assignment.

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Table 1 Summary of Segment Values

Segment Values Per Mile Begin End Zone 6-Foot Annual Lease Annual 30-Year Milepost Milepost Miles Zone Value 1 Mile1 ($2016)2 Rate Rent 3 Term4 Interstate 15 0 5 5 5 $1.85 31,680 $58,608 8.0% $4,689 $57,022 5 13 8 7 $7.40 31,680 $234,432 8.0% $18,755 $228,086 13 16 3 6 $4.00 31,680 $126,720 8.0% $10,138 $123,290 16 56 40 4 $1.33 31,680 $42,134 8.0% $3,371 $40,994 56 62 6 6 $4.00 31,680 $126,720 8.0% $10,138 $123,290 62 78 16 4 $1.33 31,680 $42,134 8.0% $3,371 $40,994 78 94 16 3 $0.28 31,680 $8,870 8.0% $710 $8,630 94 109 15 2 $0.033 31,680 $1,045 8.0% $84 $1,017 109 113 4 5 $1.85 31,680 $58,608 8.0% $4,689 $57,022 113 147 34 2 $0.033 31,680 $1,045 8.0% $84 $1,017 147 158 11 3 $0.28 31,680 $8,870 8.0% $710 $8,630 158 186 28 2 $0.033 31,680 $1,045 8.0% $84 $1,017 186 191 5 3 $0.28 31,680 $8,870 8.0% $710 $8,630 191 223 32 2 $0.033 31,680 $1,045 8.0% $84 $1,017 223 227 4 5 $1.85 31,680 $58,608 8.0% $4,689 $57,022 227 243 16 3 $0.28 31,680 $8,870 8.0% $710 $8,630 243 258 15 6 $4.00 31,680 $126,720 8.0% $10,138 $123,290 258 263 5 5 $1.85 31,680 $58,608 8.0% $4,689 $57,022 263 290 27 7 $7.40 31,680 $234,432 8.0% $18,755 $228,086 290 302 12 8 $11.15 31,680 $353,232 8.0% $28,259 $343,670 302 344 42 7 $7.40 31,680 $234,432 8.0% $18,755 $228,086 344 349 5 6 $4.00 31,680 $126,720 8.0% $10,138 $123,290 349 358 9 4 $1.33 31,680 $42,134 8.0% $3,371 $40,994 358 373 15 3 $0.28 31,680 $8,870 8.0% $710 $8,630 373 392 19 4 $1.33 31,680 $42,134 8.0% $3,371 $40,994 392 400 8 3 $0.28 31,680 $8,870 8.0% $710 $8,630 Mean/Total I-15 400 $77,838 $6,227 $75,731

1 6 feet x 5,280 feet 2 Zone Value x 31,680 SF 3 Annual $2016 x Lease Rate 4 Annual Rent x 12.161643 (present value factor)

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Table 1 Summary of Segment Values (continued)

Segment Values Per Mile Begin End Zone 6-Foot Annual Lease Annual 30-Year Milepost Milepost Miles Zone Value 1 Mile1 ($2016)2 Rate Rent 3 Term4 Interstate 70 0 23 23 2 $0.033 31,680 $1,045 8.0% $84 $1,017 23 37 14 3 $0.28 31,680 $8,870 8.0% $710 $8,630 37 40 3 6 $4.00 31,680 $126,720 8.0% $10,138 $123,290 40 57 17 3 $0.28 31,680 $8,870 8.0% $710 $8,630 57 231 174 2 $0.033 31,680 $1,045 8.0% $84 $1,017 Mean/Total I-70 231 $29,310 $2,345 $28,517

Interstate 80 0 98 98 1 $0.006 31,680 $190 8.0% $15 $185 98 99 1 6 $4.00 31,680 $126,720 8.0% $10,138 $123,290 99 112 13 2 $0.033 31,680 $1,045 8.0% $84 $1,017 112 119 7 6 $4.00 31,680 $126,720 8.0% $10,138 $123,290 123 128 5 8 $11.15 31,680 $353,232 8.0% $28,259 $343,670 128 139 11 2 $0.033 31,680 $1,045 8.0% $84 $1,017 139 148 9 6 $4.00 31,680 $126,720 8.0% $10,138 $123,290 148 167 19 4 $1.33 31,680 $42,134 8.0% $3,371 $40,994 167 196 29 2 $0.033 31,680 $1,045 8.0% $84 $1,017 Mean/Total I-80 192 $86,539 $6,923 $84,197

Interstate 84 0 7 7 3 $0.28 31,680 $8,870 8.0% $710 $8,630 7 35 28 2 $0.033 31,680 $1,045 8.0% $84 $1,017 35 42 7 4 $1.33 31,680 $42,134 8.0% $3,371 $40,994 82 88 6 5 $1.85 31,680 $58,608 8.0% $4,689 $57,022 88 92 4 2 $0.033 31,680 $1,045 8.0% $84 $1,017 92 119 27 4 $1.33 31,680 $42,134 8.0% $3,371 $40,994 Mean/Total I-84 79 $25,640 $2,051 $24,946

Interstate 215 0 9 9 9 $15.90 31,680 $503,712 8.0% $40,297 $490,077 9 28 19 7 $7.40 31,680 $234,432 8.0% $18,755 $228,086 Mean/Total I-215 28 $369,072 $29,526 $359,082

1 6 feet x 5,280 feet 2 Zone Value x 31,680 SF 3 Annual $2016 x Lease Rate 4 Annual Rent x 12.161643 (present value factor)

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Certification Statement

We certify that, to the best of our knowledge and belief:

 The statements of fact contained in this report are true and correct.

 The reported analyses, opinions and conclusions are limited only by the reported assumptions and limiting conditions, and represents personal, unbiased professional analyses, opinions and conclusions.

 We have no present or contemplated future interest in the property that is the subject of this report, and we have no personal interest or bias with respect to the parties involved.

 Our engagement in this assignment was not contingent upon developing or reporting predetermined results.

 Our compensation is not contingent upon the reporting of a predetermined value or direction in value that favors the cause of the client, the amount of the value estimate, the attainment of a stipulated result, or the occurrence of a subsequent event.

 Our analyses, opinions, and conclusions were developed and this report has been prepared in conformity with the Uniform Standards of Professional Appraisal Practice (USPAP).

 There was no personal inspection of the property specific to this assignment.

 We have performed services as appraisers regarding the property that is the subject of this report at various times and places within the three-year period immediately preceding acceptance of this assignment.

 No other person provided assistance to the signers of this report in the development of the conclusions contained in this report.

 The Appraisers have established sufficient competence to appraise this property through education and experience, in addition to the internal resources of the appraisal firm.

 Our value conclusion and other opinions expressed herein are not based on a requested minimum value, a specific value or approval of a loan.

 Troy A. Lunt and Eric Leonhardt have completed the requirements of the continuing education program of the Appraisal Institute.

 The use of this report is subject to the requirements of the Appraisal Institute, relating to review by its duly authorized representatives.

 The reported analyses, opinions, and conclusions were developed and this report has been prepared, in conformity with the requirements of the Code of Professional Ethics & Standards of Professional Appraisal Practice of the Appraisal Institute, which include the Uniform Standards of Professional Appraisal Practice.

Troy A. Lunt, MAI Eric Leonhardt, MAI Utah Certified General Appraiser Utah Certified General Appraiser License 5457226-CG00 License 5450597-CG00 Expires 05/31/2015 Expires 03/31/2016

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Assumptions and Limiting Conditions

This appraisal is based on the following assumptions, except as otherwise noted in the report.

1. The title is marketable and free and clear of all liens, encumbrances, encroachments, easements and restrictions. The property is under responsible ownership and competent management and is available for its highest and best use. 2. There are no existing judgments or pending or threatened litigation that could affect the value of the property. 3. There are no hidden or undisclosed conditions of the land or of the improvements that would render the property more or less valuable. Furthermore, there is no asbestos in the property. 4. The revenue stamps placed on any deed referenced herein to indicate the sale price are in correct relation to the actual dollar amount of the transaction. 5. The property is in compliance with all applicable building, environmental, zoning, and other federal, state and local laws, regulations and codes. 6. The information furnished by others is believed to be reliable, but no warranty is given for its accuracy.

This appraisal is subject to the following limiting conditions, except as otherwise noted in the report.

1. An appraisal is inherently subjective and represents our opinion as to the value of the property appraised. 2. The conclusions stated in our appraisal apply only as of the effective date of the appraisal, and no representation is made as to the effect of subsequent events. 3. No changes in any federal, state or local laws, regulations or codes (including, without limitation, the Internal Revenue Code) are anticipated. 4. No environmental impact studies were either requested or made in conjunction with this appraisal, and we reserve the right to revise or rescind any of the value opinions based upon any subsequent environmental impact studies. If any environmental impact statement is required by law, the appraisal assumes that such statement will be favorable and will be approved by the appropriate regulatory bodies. 5. Unless otherwise agreed to in writing, we are not required to give testimony, respond to any subpoena or attend any court, governmental or other hearing with reference to the property without compensation relative to such additional employment. 6. We have made no survey of the property and assume no responsibility in connection with such matters. Any sketch or survey of the property included in this report is for illustrative purposes only and should not be considered to be scaled accurately for size. The appraisal covers the property as described in this report, and the areas and dimensions set forth are assumed to be correct. 7. No opinion is expressed as to the value of subsurface oil, gas or mineral rights, if any, and we have assumed that the property is not subject to surface entry for the exploration or removal of such materials, unless otherwise noted in our appraisal. 8. We accept no responsibility for considerations requiring expertise in other fields. Such considerations include, but are not limited to, legal descriptions and other legal matters such as legal title, geologic considerations such as soils and seismic stability, and civil, mechanical, electrical, structural and other engineering and environmental matters. 9. The distribution of the total valuation in the report between land and improvements applies only under the reported highest and best use of the property. The allocations of value for land and improvements must not be used in conjunction with any other appraisal and are invalid if so used. The appraisal report

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shall be considered only in its entirety. No part of the appraisal report shall be utilized separately or out of context. 10. Neither all nor any part of the contents of this report (especially any conclusions as to value, the identity of the appraisers, or any reference to the Appraisal Institute) shall be disseminated through advertising media, public relations media, news media or any other means of communication (including without limitation prospectuses, private offering memoranda and other offering material provided to prospective investors) without the prior written consent of the person signing the report. 11. Information, estimates and opinions contained in the report and obtained from third-party sources are assumed to be reliable and have not been independently verified. 12. Any income and expense estimates contained in the appraisal report are used only for the purpose of estimating value and do not constitute predictions of future operating results. 13. If the property is subject to one or more leases, any estimate of residual value contained in the appraisal may be particularly affected by significant changes in the condition of the economy, of the real estate industry, or of the appraised property at the time these leases expire or otherwise terminate. 14. No consideration has been given to personal property located on the premises or to the cost of moving or relocating such personal property; only the real property has been considered. 15. The current purchasing power of the dollar is the basis for the value stated in our appraisal; we have assumed that no extreme fluctuations in economic cycles will occur. 16. The value found herein is subject to these and to any other assumptions or conditions set forth in the body of this report but which may have been omitted from this list of Assumptions and Limiting Conditions. 17. The analyses contained in the report necessarily incorporate numerous estimates and assumptions regarding property performance, general and local business and economic conditions, the absence of material changes in the competitive environment and other matters. Some estimates or assumptions, however, inevitably will not materialize, and unanticipated events and circumstances may occur; therefore, actual results achieved during the period covered by our analysis will vary from our estimates, and the variations may be material. 18. The Americans with Disabilities Act (ADA) became effective January 26, 1992. We have not made a specific survey or analysis of the property to determine whether the physical aspects of the improvements meet the ADA accessibility guidelines. We claim no expertise in ADA issues, and render no opinion regarding compliance of the subject with ADA regulations. Inasmuch as compliance matches each owner’s financial ability with the cost to cure the non-conforming physical characteristics of a property, a specific study of both the owner’s financial ability and the cost to cure any deficiencies would be needed for the Department of Justice to determine compliance. 19. The appraisal report is prepared for the exclusive benefit of the Client, its subsidiaries and/or affiliates. It may not be used or relied upon by any other party. All parties who use or rely upon any information in the report without our written consent do so at their own risk. 20. No studies have been provided to us indicating the presence or absence of hazardous materials on the subject property or in the improvements, and our valuation is predicated upon the assumption that the subject property is free and clear of any environment hazards including, without limitation, hazardous wastes, toxic substances and mold. No representations or warranties are made regarding the environmental condition of the subject property and the person signing the report shall not be responsible for any such environmental conditions that do exist or for any engineering or testing that might be required to discover whether such conditions exist. Because we are not experts in the field of environmental conditions, the appraisal report cannot be considered as an environmental assessment of the subject property.

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21. The person signing the report may have reviewed available flood maps and may have noted in the appraisal report whether the subject property is located in an identified Special Flood Hazard Area. We are not qualified to detect such areas and therefore do not guarantee such determinations. The presence of flood plain areas and/or wetlands may affect the value of the property, and the value conclusion is predicated on the assumption that wetlands are non-existent or minimal. 22. Integra Realty Resources – Salt Lake City is not a building or environmental inspector. Integra Salt Lake City does not guarantee that the subject property is free of defects or environmental problems. Mold may be present in the subject property and a professional inspection is recommended. 23. The appraisal report and value conclusion for an appraisal assumes the satisfactory completion of construction, repairs or alterations in a workmanlike manner. 24. It is expressly acknowledged that in any action which may be brought against Integra Realty Resources – Salt Lake City, Integra Realty Resources, Inc. or their respective officers, owners, managers, directors, agents, subcontractors or employees (the “Integra Parties”), arising out of, relating to, or in any way pertaining to this engagement, the appraisal reports, or any estimates or information contained therein, the Integra Parties shall not be responsible or liable for any incidental or consequential damages or losses, unless the appraisal was fraudulent or prepared with gross negligence. It is further acknowledged that the collective liability of the Integra Parties in any such action shall not exceed the fees paid for the preparation of the appraisal report unless the appraisal was fraudulent or prepared with gross negligence. Finally, it is acknowledged that the fees charged herein are in reliance upon the foregoing limitations of liability. 25. Integra Realty Resources – Salt Lake City, an independently owned and operated company, has prepared the appraisal for the specific purpose stated elsewhere in the report. The intended use of the appraisal is stated in the General Information section of the report. The use of the appraisal report by anyone other than the Client is prohibited except as otherwise provided. Accordingly, the appraisal report is addressed to and shall be solely for the Client’s use and benefit unless we provide our prior written consent. We expressly reserve the unrestricted right to withhold our consent to your disclosure of the appraisal report (or any part thereof including, without limitation, conclusions of value and our identity), to any third parties. Stated again for clarification, unless our prior written consent is obtained, no third party may rely on the appraisal report (even if their reliance was foreseeable). 26. The conclusions of this report are estimates based on known current trends and reasonably foreseeable future occurrences. These estimates are based partly on property information, data obtained in public records, interviews, existing trends, buyer-seller decision criteria in the current market, and research conducted by third parties, and such data are not always completely reliable. Integra Realty Resources, Inc. and the undersigned are not responsible for these and other future occurrences that could not have reasonably been foreseen on the effective date of this assignment. Furthermore, it is inevitable that some assumptions will not materialize and that unanticipated events may occur that will likely affect actual performance. While we are of the opinion that our findings are reasonable based on current market conditions, we do not represent that these estimates will actually be achieved, as they are subject to considerable risk and uncertainty. Moreover, we assume competent and effective management and marketing for the duration of the projected holding period of this property. 27. All prospective value estimates presented in this report are estimates and forecasts which are prospective in nature and are subject to considerable risk and uncertainty. In addition to the contingencies noted in the preceding paragraph, several events may occur that could substantially alter the outcome of our estimates such as, but not limited to changes in the economy, interest rates, and capitalization rates, behavior of consumers, investors and lenders, fire and other physical destruction, changes in title or conveyances of easements and deed restrictions, etc. It is assumed that conditions reasonably foreseeable at the present time are consistent or similar with the future.

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Qualifications

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Integra Realty Resources Troy A. Lunt, MAI, R/W-AC Salt Lake City

Experience 5107 South 900 East Suite 200 Troy is a director and full time commercial real estate appraiser and consultant with Integra Realty Salt Lake City, UT 84117 Resources – Salt Lake City. He has been appraising since 1994 assisting commercial, governmental and private clients across a wide range of property and assignment types. T 801.263.9700 F 801.263.9709 Troy specializes in eminent domain/right-of-way valuation pertaining to surface, subsurface and aerial property interests. He also has considerable experience in forensic appraising and litigation consulting/expert services for a wide range of litigation actions including eminent domain, ad valorem taxation, corporate/partnership dissolution and allocation, estate planning/resolution, divorce, and value impairment from all sources including environmental and regulatory.

Troy has been qualified as an expert witness. Other areas of expertise include fundamental market analyses, feasibility studies, investment consultation and general commercial appraisal. Troy holds the MAI designation issued through the Appraisal Institute. Prior to joining Integra Realty Resources, he was a founding partner in the Fortis Group, a local appraising and consulting firm, and before that was a Director with LECG, an international expert services firm.

Professional Activities & Affiliations MAI, Appraisal Institute R/W-AC, International Right of Way Association Affiliate Member Salt Lake Board of Realtors Member International Right of Way Association President, Utah Chapter International Right of Way Association, 2011-2012 Presenter, Panel Member -- Utah Eminent Domain Law Update, Utah Land Institute, 2011-2012 Utah Appraiser Board Experience Screening Committee, 2004 - present Board of Directors Utah Association of Appraisers, 2009 - present Licenses Utah, Certified General, 5457226-CG00, Expires May 2015 Wyoming, Certified General, Permit #1060, Expires December 2014 Nevada, Certified General, A.0206229-CG, Expires February 2015 Idaho, Certified General, CGA-3399, Expires April 2014

Education Bachelor of Arts, University of Utah, June 1994 Appraisal Principles Basic Income Capitalization Appraisal Procedures Highest and Best Uses Advanced Income Capitalization Report Writing & Valuation Analysis Advanced Applications Advanced Sales Comparison & Cost Approaches Uniform Standards of Professional Appraisal Practice Uniform Appraisal Standards for Federal Land Acquisitions Environmental Contamination Around Hill AFB Understanding Real Estate Investment Eminent Domain New Tools & Strategies Appraisal Laws & Legislation Current State of Wetlands Regulations Planning & Growth Issues Along the Wasatch Front Water Rights Valuation Challenges Environmental Issues in Real Estate Real Estate Finance [email protected] - 801.263.9700 x120 Longitudinal Telecommunication Access in the Interstate Highway System Page | 20

Troy A. Lunt, MAI, R/W-AC

Education (Cont'd) Detrimental Conditions in Real Estate Valuation The Impact on Real Estate Changes in Tax Law Litigation Skills for the Appraiser Evaluating Commercial Construction Eminent Domain & Condemnation Business Practices & Ethics New Technology for Real Estate Appraisers Scope of Work Feasibility, Market Value, Investment Timing: Option Value Condemnation Appraising: Principles & Applications Utah Eminent Domain Update (Presenter) Litigation Appraising: Specialized Topics & Applications International Right of Way SR/WA Comprehensive Exam Challenge Review Course National USPAP Equivalent Update Course Environmental Due Diligence & Liability Project Development & the Environmental Process The Valuation of Partial Acquisitions Eminent Domain Law: Basics for the Right of Way Professional Easement Valuation Articles and Publications None Qualified Before Courts & Administrative Bodies 2007 SL County v. Walgreens 2008 Linda Golub v. Doctorman, et al 2009 UDOT v. Bob's Lock 2010 UDOT v. Wilford J. Harris, et all 2010 Smith v. Simas 2010 Traverse Mountain v. Fox Ridge, LLC (Deposition) 2011 UDOT v. AF 1-15 2011 UDOT v. Brown 2011 UDOT v. Dunsmure Long Term Investments, LLC, et al 2012 Cook v. SITLA 2012 UDOT v. McDougal 2012 Salt Lake City v. Evans Development Group (Deposition) 2012 Rocky Mountain Power v. Millerberg Holdings, LC 2012 Giovengo Properties v. Hallmark Homes & Development 2012 DL Evans Bank v. Clark Real Estate, et al 2013 Traverse Mountain v. Fox Ridge, LLC (Trial) 2013 Windygates, LLC v. BMA Construction 2013 Salt Lake City v. Evans Development Group (Trial)

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Integra Realty Resources Eric Leonhardt, MAI Salt Lake City

Experience 5107 South 900 East Suite 200 Senior Analyst at Integra Realty Resources - Salt Lake City since September 2013. Previous work Salt Lake City, UT 84117 experience includes real estate appraising at Free & Associates from October 1995 to September 2013 and an accountant for Holland Properties in Park City Utah. T 801-263-9700 F 801-263-9709 Professional Activities & Affiliations Real Estate Finance Real Estate Fundamental Appraisal

Appraisal Residences Uniform Standards of Professional Appraisal Practice 310 Basic Income Capitalization 320 General Applications 510 Advanced Income Capitalization 520 Highest and Best Use and Market Analysis 530 Advanced Sales Comparison and Cost Approaches 540 Report Writing and Valuation Analysis 550 Advanced Applications 660 Small Hotel/Motel Valuation Business Practices and Ethics Condemnation Appraising Principles and Applications Litigation Skills for the Appraiser Standards of Professional Practice Eminent Domain Eminent Domain Update Public Roads on Private Lands Land Use Law Utah Land Use Eminent Domain Training for Attorneys and Appraisers 403 Easement Valuation 803 Eminent Domain - Law Basics Licenses Utah, Certified General, 5450597-CG00, Expires March 2016 Education Bachelor of Science in Finance, Utah State University, 1989

[email protected] - 801-263-9700 x115 Longitudinal Telecommunication Access in the Interstate Highway System Page | 22

Addendum

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Land Value - Sales

Sale Location Date Freeway Zoning Visible Latitude Longitude Acre Price/SF Adj Price Moving 12-137807 Saint George Oct-12 15 R 37.051264 -113.590726 1.29 $2.40 $2.63 $7.25

1101619 Saint George Jan-13 15 R 37.052799 -113.589870 1.26 $1.73 $1.89 $7.74

1129368 Saint George Jul-13 15 R x 37.056635 -113.588494 1.19 $1.91 $2.06 $7.82 12-138745 Saint George Dec-12 15 C 37.076939 -113.591369 1.60 $12.00 $13.13 $7.30

280564 Saint George Jul-07 15 C-3 37.091344 -113.583521 1.84 $16.73 $14.60 $6.84

725561 Saint George Jul-13 15 C-3 37.092174 -113.583537 1.75 $8.54 $9.20 $6.39

599475 Saint George Feb-12 15 PD-COM x 37.104630 -113.559271 1.25 $9.73 $10.65 $6.31 1062099 Saint George Feb-13 15 C x 37.119707 -113.545970 1.45 $7.68 $8.38 $6.16 955625 Washington Jan-14 15 R 37.137717 -113.520159 0.56 $2.99 $3.18 $6.08

1085667 Washington Jan-13 15 C x 37.141495 -113.505995 2.31 $2.48 $2.71 $5.07 752894 Hurricane Oct-13 15 M-1 37.168519 -113.423331 4.24 $1.76 $1.88 $3.91

1049017 Hurricane Apr-12 15 M-1 37.170910 -113.418544 3.08 $1.59 $1.74 $3.08

1119791 Leeds Jun-13 15 RA x 37.232370 -113.374958 26.30 $0.18 $0.19 $2.15 1237143 Leeds Jul-14 15 R 37.235522 -113.375591 1.01 $1.11 $1.16 $1.42

1198514 Leeds Feb-14 15 R 37.251600 -113.356821 1.00 $1.95 $2.07 $1.16

1111982 Leeds Feb-13 15 R 37.257881 -113.368381 0.55 $1.67 $1.82 $0.97

1097464 Leeds Jul-13 15 R x 37.258885 -113.332005 51.13 $0.09 $0.10 $0.96 748577 Toquerville Feb-14 15 HC x 37.285851 -113.300908 27.44 $0.44 $0.47 $0.97 1075736 New Harmony Jun-14 15 R 37.407982 -113.245989 5.33 $0.28 $0.29 $1.63

709479 New Harmony Apr-12 15 R 37.424511 -113.253819 5.00 $0.33 $0.36 $1.63

1173638 Kanarraville Aug-13 15 RA 37.544237 -113.179919 9.11 $0.62 $0.64 $1.55

570328 Cedar Jun-12 15 R 37.640133 -113.106767 0.05 $1.69 $1.76 $1.52

1134986 Cedar Jul-13 15 C 37.647316 -113.080972 0.72 $1.75 $1.80 $1.67

A1 Cedar Jul-14 15 CC 37.656297 -113.084267 0.94 $7.46 $7.45 $1.65

1170092 Cedar Oct-13 15 R-2 37.659340 -113.070511 0.29 $1.18 $1.20 $1.65

1173408 Cedar Nov-13 15 R-1 37.668077 -113.082125 0.59 $1.19 $1.21 $1.65

Sales Data Summary Page | 1

570770 Cedar May-12 15 I&M-1 37.685749 -113.090202 1.14 $1.41 $1.47 $1.71

1229709 Cedar Jul-14 15 R-1 37.714905 -113.054069 0.32 $1.76 $1.75 $1.56

1126799 Enoch Oct-13 15 R x 37.769960 -113.005560 1.25 $0.26 $0.27 $1.40 1126793 Enoch Oct-13 15 R x 37.770592 -113.004389 1.25 $0.26 $0.27 $0.73 1126804 Enoch Jul-13 15 R 37.770833 -113.009641 1.22 $0.30 $0.31 $0.62

368139 Parawon Jan-07 15 I x 37.832921 -112.875938 15.18 $1.55 $1.33 $0.51 1158559 Paragonah Nov-13 15 C x 37.911609 -112.779613 40.00 $0.07 $0.07 $0.38 1115113 Parowan Nov-12 15 A 37.911695 -112.820831 20.68 $0.09 $0.09 $0.23

449100 Iron County Mar-10 15 AG-20 x 37.941016 -112.758418 142.83 $0.02 $0.02 $0.21 1077696 Beaver Nov-12 15 A x 38.324844 -112.657804 40.00 $0.01 $0.01 $0.18 1192499 Cove Fort Mar-14 15 A x 38.599567 -112.609152 19.00 $0.02 $0.02 $0.16 1192265 Cove Fort Oct-13 15 A x 38.604546 -112.609448 17.05 $0.03 $0.03 $0.04 1192493 Cove Fort Dec-13 15 A x 38.605759 -112.604471 20.00 $0.09 $0.09 $0.03 1048944 Meadow Feb-12 15 AG1 38.876770 -112.395734 6.41 $0.03 $0.03 $0.03

1242611 Meadow Sep-14 15 AG 38.893225 -112.432832 20.00 $0.02 $0.02 $0.03

1242592 Meadow Sep-14 15 AG 38.893251 -112.430929 12.36 $0.02 $0.02 $0.03

1154503 Meadow Jul-13 15 A x 38.903813 -112.400428 18.64 $0.02 $0.02 $0.10 1037847 Fillmore Sep-11 15 A x 38.919190 -112.380073 200.00 $0.01 $0.01 $0.10 1111321 Fillmore Dec-12 15 A 38.924828 -112.322288 9.77 $0.02 $0.02 $0.09

1079196 Fillmore Jun-12 15 A 38.951469 -112.330099 283.00 $0.01 $0.01 $0.09

1189925 Fillmore Mar-14 15 LI 38.954963 -112.353468 45.97 $0.03 $0.03 $0.09

1151596 Fillmore Apr-13 15 R 38.962345 -112.336487 1.26 $0.77 $0.79 $0.09

1029200 Fillmore Mar-12 15 A 39.012251 -112.341437 20.00 $0.01 $0.01 $0.08

1071176 Fillmore Jun-12 15 A 39.021043 -112.322223 19.58 $0.01 $0.01 $0.12

1085057 Fillmore Feb-13 15 AG-20 39.026579 -112.310617 40.00 $0.01 $0.01 $0.15

999759 Fillmore Jul-11 15 AG-20 39.031610 -112.279505 20.00 $0.02 $0.02 $0.15

1165557 Fillmore Aug-13 15 A20 39.032193 -112.344900 26.00 $0.01 $0.01 $0.15

1184193 Fillmore Nov-13 15 A x 39.037833 -112.296999 39.54 $0.01 $0.01 $0.08 1145672 Holden Aug-13 15 R 39.093095 -112.271512 1.14 $0.44 $0.45 $0.19

Sales Data Summary Page | 2

1081965 Holden Oct-12 15 A 39.125216 -112.237262 20.00 $0.32 $0.33 $0.24

1057618 Holden Oct-11 15 AG x 39.142236 -112.239829 505.42 $0.02 $0.02 $0.24 1171882 Holden Jul-13 15 A 39.151754 -112.246585 8.77 $0.02 $0.02 $0.25

1030002 Holden Jun-11 15 RA 39.154700 -112.262007 250.00 $0.02 $0.02 $0.25

1172669 Scipio Mar-14 15 R 39.240895 -112.110211 0.50 $1.15 $1.14 $0.25

1109542 Scipio Jun-13 15 R 39.252723 -112.106085 1.42 $0.61 $0.62 $0.21

1098842 Levan Jan-13 15 RA 39.417629 -112.061641 10.00 $0.02 $0.02 $0.18

550670 Levan Dec-10 15 RA-1 39.418527 -112.057749 10.00 $0.06 $0.06 $0.25

1084127 Levan May-12 15 A 39.580510 -111.844640 80.00 $0.01 $0.01 $0.34

1199823 Levan Mar-14 15 A 39.587434 -111.862707 44.50 $0.01 $0.01 $0.40

1197772 Levan Feb-14 15 A 39.590204 -111.905032 120.00 $0.01 $0.01 $0.45

1197770 Levan Feb-14 15 A 39.606796 -111.861634 80.00 $0.01 $0.01 $0.51

L674587 Nephi Jul-13 15 C 39.685314 -111.837791 13.68 $0.89 $0.88 $0.68

1186731 Nephi Oct-13 15 R x 39.687965 -111.832581 0.46 $1.00 $0.98 $0.86 1178006 Nephi Jan-14 15 C x 39.688093 -111.836608 3.69 $0.69 $0.67 $1.14 1186727 Nephi Oct-13 15 R x 39.688283 -111.832602 0.27 $1.70 $1.67 $1.24 988525 Nephi Jun-11 15 R 39.694272 -111.828611 0.31 $1.30 $1.29 $1.41

1237941 Nephi Jul-14 15 R 39.695651 -111.828198 0.20 $2.01 $1.93 $1.41

1099847 Nephi Jan-13 15 R 39.700036 -111.830446 0.26 $1.94 $1.95 $1.44

1137953 Nephi Oct-13 15 R 39.703233 -111.827246 0.18 $3.19 $3.13 $1.43

1213291 Nephi Aug-14 15 R 39.706551 -111.832251 0.21 $1.20 $1.15 $1.46

1132334 Nephi May-13 15 R 39.709915 -111.827484 0.32 $1.83 $1.82 $1.40

?1070025 Nephi Sep-12 15 RA 39.715778 -111.845466 6.20 $0.04 $0.04 $1.29

1103278 Nephi Oct-12 15 R 39.721417 -111.832277 0.29 $1.19 $1.20 $1.35

1035741 Mona Jul-13 15 R 39.793905 -111.853040 1.05 $0.84 $0.83 $1.50

1218263 Nephi May-14 15 R 39.822558 -111.850466 0.50 $1.06 $1.02 $1.47

1124861 Mona Apr-13 15 R 39.822723 -111.852968 0.54 $1.08 $1.08 $1.61

?1114276 Mona Oct-12 15 A 39.905259 -111.833696 43.10 $0.02 $0.02 $1.64

669650 Santaquin Nov-12 15 PC 39.952684 -111.818570 0.25 $2.30 $2.60 $2.03

Sales Data Summary Page | 3

669661 Santaquin Jun-12 15 PC 39.952946 -111.818893 0.24 $3.16 $3.57 $2.03

669625 Santaquin Mar-13 15 PC 39.958908 -111.820427 0.30 $2.52 $2.83 $2.01

669646 Santaquin Dec-12 15 R-10 39.961368 -111.781761 0.36 $2.38 $2.69 $1.96

669638 Santaquin Mar-13 15 R-10 39.963140 -111.782772 0.30 $1.91 $2.15 $2.18

669722 Santaquin May-12 15 R-12 39.972687 -111.764278 0.24 $3.83 $4.32 $2.92

390982 Utah County Jun-07 15 RA-5 39.997227 -111.781560 5.25 $1.34 $1.21 $2.72

390993 Utah County Jan-06 15 RA-5 40.004300 -111.751253 7.78 $0.65 $0.67 $2.41

390947 Utah County Aug-06 15 TR5 40.013712 -111.769198 51.69 $0.45 $0.44 $2.23

200 Payson Feb-10 15 R-1-12 40.024069 -111.745804 19.95 $3.38 $3.52 $3.02

265247 Payson Feb-07 15 S-1 x 40.029800 -111.755810 1.03 $8.80 $8.18 $5.81 457059 Utah County Nov-10 15 RA-5 40.056126 -111.750603 16.97 $0.28 $0.30 $5.54

390990 Salem Aug-09 15 A-1 40.070321 -111.683305 17.20 $0.20 $0.20 $5.48

653413 Leland May-12 15 RA-5 40.096934 -111.698363 5.25 $0.72 $0.81 $5.59

680351 Spanish Fork Mar-13 15 C-2 40.122773 -111.646167 9.81 $10.14 $11.38 $5.88

680324 Spanish Fork Feb-13 15 C-2 40.123329 -111.650483 0.85 $29.17 $32.84 $5.74

682268 Spanish Fork Feb-11 15 I-1 40.123719 -111.669924 5.40 $1.28 $1.41 $5.15

535810 Spanish Fork Aug-09 15 I-1 40.136128 -111.638721 15.90 $0.54 $0.54 $5.29

175031 Spanish Fork Aug-06 15 I-1 40.153929 -111.653768 12.80 $1.89 $1.84 $5.43

367805 Spanish Fork May-09 15 I-1 40.153978 -111.655294 3.89 $3.78 $3.66 $5.54

192 Springville Sep-06 15 HC 40.159948 -111.660085 51.18 $2.05 $1.97 $4.56

175022 Springville Jul-06 15 I 40.173594 -111.639440 12.27 $1.69 $1.65 $1.63

467057 Springville Jun-10 15 HC 40.182689 -111.652454 7.83 $1.74 $1.85 $1.58

603101 Springville Oct-09 15 HC x 40.183169 -111.647229 20.01 $1.72 $1.74 $5.43 522441 Provo Mar-09 15 I 40.208836 -111.637659 39.00 $2.12 $2.03 $5.99

628973 Provo Nov-06 15 RA-5 40.212933 -111.675911 10.20 $0.72 $0.68 $6.14

649299 Provo Jan-07 15 RA-5 40.213773 -111.677729 52.00 $0.58 $0.54 $6.30

628929 Provo May-06 15 A15 40.219005 -111.687430 7.00 $0.92 $0.92 $6.28

705397 Provo May-12 15 WG 40.233916 -111.673874 0.64 $37.94 $42.83 $6.70

216130 Provo Nov-06 15 CG 40.234287 -111.694912 2.00 $8.43 $8.01 $7.09

Sales Data Summary Page | 4

367816 Provo Sep-08 15 MP 40.244427 -111.689753 1.69 $5.77 $5.28 $8.65

581739 Provo Jun-12 15 M-1 x 40.245178 -111.692233 4.99 $3.35 $3.78 $9.52 100 Provo Nov-09 15 RA-5 40.260745 -111.718823 17.00 $1.39 $1.42 $10.40

240523 Orem Apr-07 15 R-8 x 40.267911 -111.710701 5.40 $7.07 $6.49 $11.23 240528 Orem Apr-07 15 CM 40.274845 -111.730509 1.00 $6.54 $6.00 $8.50

410271 Orem Jan-10 15 PD-21 x 40.275873 -111.725631 2.02 $18.52 $19.19 $8.20 792474 Orem Jul-14 15 PD 40.281876 -111.727936 1.49 $9.48 $10.22 $8.92

379691 Orem Jul-09 15 HS-1 40.310945 -111.723109 0.88 $10.41 $10.26 $9.46

262 Orem Jul-09 15 HS x 40.311718 -111.723363 0.90 $10.16 $10.02 $9.91 373912 Orem Jul-09 15 C-2 40.313561 -111.719772 8.36 $13.00 $12.86 $9.80

265215 Orem Jan-06 15 M2 40.313604 -111.734854 1.32 $4.52 $4.65 $9.67

565260 Orem Dec-07 15 HS 40.313779 -111.724015 2.93 $15.11 $13.20 $8.20

245919 Orem May-07 15 HS x 40.317060 -111.724597 0.50 $10.70 $9.73 $7.53 265217 Orem Feb-06 15 M2 x 40.317912 -111.727143 0.61 $6.30 $6.41 $6.83 316777 Vineyard Sep-08 15 I 40.326330 -111.743268 2.52 $5.79 $5.29 $6.27

316778 Vineyard Jun-08 15 I 40.328643 -111.742721 4.24 $5.00 $4.50 $5.64

682285 Lindon Nov-12 15 LI 40.334570 -111.748641 12.32 $2.70 $3.05 $5.59

525878 Lindon Dec-11 15 LI 40.346233 -111.752350 1.57 $2.52 $2.84 $5.12

367810 American Fork Jun-09 15 BP-1 40.347599 -111.783241 2.11 $2.61 $2.56 $4.67

265201 American Fork Jul-07 15 I-1 40.347615 -111.782112 3.38 $4.31 $3.87 $4.66

239507 American Fork Apr-07 15 GC-2 40.350273 -111.780858 10.66 $6.46 $5.92 $4.47

184 Lindon Feb-06 15 CG 40.350783 -111.752204 30.00 $4.02 $4.09 $4.36

245925 Pleasant Grove Aug-07 15 GW-1 x 40.352953 -111.769393 2.98 $9.00 $8.07 $4.57 175051 American Fork Jul-06 15 AG x 40.356278 -111.774281 10.48 $4.82 $4.74 $4.64 549570 American Fork Dec-13 15 I 40.358474 -111.779335 6.62 $5.75 $6.31 $5.51

617913 American Fork Dec-11 15 GC-2 x 40.359692 -111.788414 3.36 $2.90 $3.27 $5.99 319352 American Fork Feb-07 15 R1-12 40.363554 -111.801472 28.67 $3.52 $3.26 $6.47

526373 American Fork Sep-10 15 BP-1 x 40.363666 -111.793144 4.13 $5.00 $5.38 $6.27 316776 Lindon Jan-08 15 LI x 40.364204 -111.793120 12.36 $4.09 $3.57 $6.06

Sales Data Summary Page | 5

261 Pleasant Grove Oct-07 15 C 40.369286 -111.769023 0.99 $13.78 $12.17 $6.18

264 American Fork Aug-08 15 GC-2 40.369391 -111.785506 1.01 $9.98 $9.11 $6.46

260 American Fork Mar-10 15 GC-1 40.373585 -111.784427 0.45 $10.69 $11.20 $7.14

538616 Lehi Dec-11 15 TR5 40.380617 -111.839785 12.00 $1.72 $1.94 $7.76

486 Lehi Dec-12 15 C 40.383109 -111.834888 4.64 $5.09 $5.75 $8.68

183 Lehi Oct-06 15 RC x 40.422191 -111.881713 118.50 $6.35 $6.06 $9.21 755220 Lehi Jun-14 15 RC 40.424270 -111.893477 9.14 $8.63 $9.35 $8.71

564763 Lehi Feb-12 15 RC 40.431113 -111.896608 10.18 $9.50 $10.72 $8.93

439 Lehi Dec-11 15 RC 40.432257 -111.897251 1.51 $8.98 $10.13 $9.35

244826 Lehi Jun-07 15 C x 40.432947 -111.893918 1.15 $17.00 $15.45 $9.72 289 Lehi Sep-10 15 PC x 40.436804 -111.894977 14.89 $8.75 $9.45 $9.62 576618 Lehi Mar-10 15 LI x 40.440329 -111.901057 2.59 $6.39 $6.67 $9.49 705368 Lehi Aug-13 15 C x 40.441414 -111.902443 0.93 $10.37 $11.49 $9.38 558 Draper Sep-13 15 CI x 40.482240 -111.896854 1.50 $14.54 $15.82 $9.80 249 Bluffdale Sep-09 15 HC x 40.483054 -111.902700 6.03 $6.05 $6.00 $9.81 568 Bluffdale Jul-13 15 MU 40.486054 -111.906302 7.10 $4.29 $4.70 $8.86

288 Draper Sep-10 15 CR x 40.491569 -111.890983 5.84 $4.32 $4.59 $9.58 418 Draper Aug-12 15 OC 40.495958 -111.884809 5.29 $7.38 $8.20 $9.78

367 Draper Mar-11 15 CC 40.498865 -111.884851 2.12 $14.13 $15.36 $10.31

75 Draper Nov-07 15 CO x 40.502754 -111.888518 4.36 $11.84 $10.22 $10.12 487 Draper Mar-13 15 CR 40.514117 -111.886217 1.33 $4.49 $4.95 $10.61

559 Draper Mar-14 15 CR x 40.518738 -111.890615 0.32 $16.18 $17.33 $10.97 188 Draper Jan-10 15 MU 40.526831 -111.876460 28.65 $8.60 $8.93 $11.89

495 South Jordan Apr-13 15 C-F x 40.548093 -111.897635 3.43 $15.75 $17.33 $12.19 554 South Jordan Nov-13 15 CF x 40.550956 -111.897258 3.62 $12.68 $13.73 $11.53 287 South Jordan Feb-07 15 C-F x 40.551589 -111.899738 1.16 $12.49 $11.38 $11.69 35 South Jordan Jan-08 15 C-F 40.571922 -111.912776 15.97 $10.13 $8.70 $12.68

245 Sandy Jun-10 15 RD x 40.580582 -111.901415 2.47 $14.00 $14.62 $12.01 553 Sandy Jun-13 15 RP x 40.580614 -111.901913 6.50 $10.50 $11.51 $11.84

Sales Data Summary Page | 6

383 Sandy Sep-11 15 RC 40.580776 -111.894409 1.06 $7.35 $8.09 $10.81

384 Sandy Jan-12 15 RC 40.583500 -111.890683 0.81 $10.77 $11.96 $10.85

459 Sandy Aug-12 15 CvC 40.587625 -111.911349 1.76 $14.31 $15.90 $10.66

580 Sandy Jan-14 15 CRC x 40.588177 -111.898177 1.36 $9.26 $9.98 $11.11 319 Sandy Mar-11 15 ID 40.590786 -111.906390 7.04 $6.52 $7.07 $10.94

5 Sandy Jun-08 15 CR 40.597088 -111.906370 3.47 $6.75 $5.98 $10.90

72 Midvale Aug-07 15 HC 40.613427 -111.910195 0.29 $16.00 $14.13 $11.29

167 Midvale Sep-09 15 I x 40.616952 -111.907063 0.23 $9.48 $9.33 $11.38 437 Midvale Oct-12 15 BJ 40.619109 -111.912124 1.63 $12.29 $13.65 $10.57

314 Midvale Apr-11 15 RC 40.620750 -111.893424 0.82 $11.75 $12.77 $10.27

461 Midvale Mar-13 15 BJ 40.625691 -111.914170 2.85 $10.00 $11.04 $10.03

69 Murray Mar-07 15 CDC x 40.653852 -111.900044 0.73 $13.71 $12.41 $11.20 457 Murray Jun-12 15 M-U 40.661208 -111.897689 4.75 $11.60 $12.89 $10.51

168 Murray Feb-10 15 MGC x 40.665981 -111.899121 0.48 $6.87 $7.04 $10.19 177 Murray Oct-09 15 MGC 40.665984 -111.898969 0.50 $6.66 $6.65 $9.38

427 Murray Jan-13 15 M-U x 40.666083 -111.902086 3.35 $4.00 $4.43 $9.75 70 Murray Dec-08 15 MGC x 40.672790 -111.902560 0.92 $20.59 $18.89 $9.40 345 South Salt Lake Jul-11 15 I x 40.707750 -111.904432 0.64 $5.91 $6.47 $8.84 528 West Valley Dec-12 15 M 40.718286 -112.021371 9.46 $5.25 $5.83 $9.03

318 West Valley Apr-11 15 M 40.725740 -111.973792 8.13 $4.35 $4.73 $9.81

1076229 Salt Lake City Apr-12 15 MU 40.760771 -111.923997 0.34 $15.19 $16.88 $9.99

1188230 Salt Lake City Apr-14 15 R 40.760884 -111.924668 0.16 $6.67 $7.14 $9.86

1157288 Salt Lake City May-13 15 R 40.765599 -111.915505 0.14 $5.74 $6.31 $8.43

440 Salt Lake Dec-12 15 TSA x 40.771713 -111.947477 1.36 $13.50 $15.00 $7.95 299 Salt Lake Dec-10 15 CB 40.780133 -111.900416 0.63 $14.51 $15.62 $7.53

1142973 Salt Lake City Jul-13 15 R 40.782449 -111.899011 0.10 $7.81 $8.54 $7.21

195 Salt Lake Apr-08 15 M-1 40.794184 -111.903852 0.84 $3.44 $3.01 $5.87

1141671 Salt Lake City Apr-13 15 C 40.810343 -111.920708 0.75 $2.91 $3.21 $5.55

2 Salt Lake May-05 15 OS 40.813865 -111.905784 19.89 $1.11 $1.17 $5.78

Sales Data Summary Page | 7

477 Salt Lake Mar-13 15 M-1 40.816840 -111.931015 4.49 $1.15 $1.27 $4.90

1 Salt Lake Sep-08 15 A-2 x 40.829996 -111.953467 8.75 $1.31 $1.18 $6.56 191 North Salt Lake Nov-07 15 CH x 40.837142 -111.911266 62.00 $2.50 $2.16 $6.78 226929 North Salt Lake Jul-07 15 CG 40.843968 -111.940939 3.58 $4.01 $3.55 $6.94

121 North Salt Lake Feb-09 15 C-H 40.844610 -111.908635 1.08 $9.57 $8.86 $7.46

194 North Salt Lake Aug-08 15 MD 40.853096 -111.917851 1.40 $6.00 $5.37 $8.60

612903 Bountiful Aug-12 15 C-H 40.891455 -111.891659 0.45 $30.61 $33.89 $9.69

297482 West Bountiful Mar-07 15 CG 40.893213 -111.892240 0.19 $12.15 $10.97 $9.69

328211? Centerville Jan-08 15 I-M 40.916958 -111.900143 3.00 $5.55 $4.77 $10.39

443 Centerville May-11 15 C-VH 40.919504 -111.896825 4.20 $8.12 $8.83 $10.75

575009 Centerville May-11 15 C-VH 40.919525 -111.896809 4.20 $12.63 $13.73 $10.09

674200 Centerville Sep-12 15 C-VH 40.920043 -111.894853 3.58 $12.03 $13.32 $10.17

330 Centerville May-11 15 RP 40.932962 -111.895966 4.86 $1.06 $1.15 $7.85

798255 Farmington May-13 15 R 40.968814 -111.905582 0.32 $8.97 $9.83 $6.97

133074 Farmington Sep-06 15 MU 40.982101 -111.905525 61.50 $8.00 $7.58 $6.66

186 Farmington Jan-07 15 A x 40.991463 -111.912254 15.50 $1.70 $1.55 $6.55 179168 Farmington Dec-06 15 R-4 40.998378 -111.909978 2.69 $6.83 $6.27 $5.82

798127 Kaysville Sep-13 15 R 41.003766 -111.937816 0.46 $7.69 $8.35 $5.29

468942 Kaysville Nov-09 15 A-5 41.012054 -111.948946 13.48 $1.33 $1.33 $5.98

107 Kaysville Nov-09 15 A-5 41.012057 -111.948969 12.73 $1.27 $1.27 $5.65

798246 Kaysville Apr-13 15 R? x 41.022308 -111.947029 0.33 $6.95 $7.63 $5.35 391625 Kaysville May-08 15 GC x 41.028286 -111.950217 10.00 $6.56 $5.77 $6.63 505716 Kaysville Mar-11 15 GC x 41.041123 -111.950096 0.44 $6.89 $7.46 $6.79 369385 Layton May-08 15 RM-1 41.047098 -111.954003 4.15 $9.96 $8.74 $6.86

117 Layton Mar-08 15 M-U 41.058743 -111.965009 3.12 $7.14 $6.18 $7.53

525 Layton Jun-12 15 M 41.064853 -111.978350 12.43 $3.90 $4.32 $8.91

506846 Layton Apr-08 15 C-H x 41.067384 -111.972911 2.33 $17.93 $15.59 $8.98 123 Layton Apr-07 15 C-H 41.072072 -111.983721 1.02 $9.00 $8.09 $9.09

425476 Layton Nov-10 15 CP-3 41.080740 -111.980464 1.60 $8.47 $9.06 $9.18

Sales Data Summary Page | 8

124 Layton Sep-09 15 B-RP 41.083249 -111.980794 1.83 $8.85 $8.68 $9.01

425480 Layton Dec-10 15 CP-2 41.087907 -112.000095 0.71 $15.28 $16.43 $8.60

505270 Clearfield May-11 15 C-2 41.103411 -112.011104 0.92 $7.75 $8.42 $9.13

119 Clearfield May-08 15 C-2 41.112446 -112.026138 1.07 $8.02 $7.06 $8.02

575281 Clearfield Aug-12 15 C-2 41.114675 -112.026121 2.34 $7.60 $8.41 $7.57

527924 Ogden Feb-12 15 OCIP x 41.212845 -112.001375 2.87 $6.00 $6.81 $7.16 305672 Ogden Mar-08 15 M-3 41.212884 -112.010926 10.44 $1.89 $1.68 $6.90

388041 West Haven Sep-08 15 C-3 x 41.228374 -112.009389 0.47 $11.00 $10.14 $5.62 690482 West Haven Dec-12 15 C-2 x 41.228791 -112.015325 10.87 $3.06 $3.47 $5.33 183233 Marriott-Slaterville Feb-06 15 A-1 41.244456 -112.005661 12.97 $3.00 $3.08 $5.23

330437 Marriott-Slaterville Jun-09 15 A-1 41.244514 -112.007385 10.95 $4.61 $4.53 $4.85

692617 Marriott-Slaterville Mar-12 15 C 41.244722 -112.019839 2.68 $5.14 $5.84 $4.44

187 Marriott-Slaterville Apr-07 15 C-3P x 41.246686 -112.019961 44.67 $2.52 $2.32 $4.38 408575 Farr West Apr-10 15 C-2 x 41.282255 -112.027969 0.58 $4.95 $5.23 $3.79 651402 Farr West May-13 15 C-2 x 41.283156 -112.027955 1.39 $5.36 $6.01 $3.72 637862 Pleasant View Sep-12 15 MCM 41.311188 -112.017681 0.82 $3.70 $4.20 $3.46

770568 Farr West Dec-13 15 M-1 x 41.317899 -112.028543 2.00 $2.07 $2.28 $3.11 331 Pleasant View Nov-10 15 M 41.320630 -112.016397 7.79 $0.96 $1.05 $2.63

368576 Pleasant View Jun-09 15 MCM 41.326809 -112.021023 1.14 $3.73 $3.69 $2.47

464138 Willard Sep-07 15 CG x 41.422641 -112.048981 3.77 $3.10 $2.73 $2.07 786554 Perry Sep-12 15 AL 41.473651 -112.047066 20.22 $0.17 $0.19 $1.55

86 Brigham Jan-05 15 M-D 41.510696 -112.043531 20.47 $0.56 $0.61 $1.20

90 Brigham Mar-09 15 M-D 41.524632 -112.031842 7.00 $0.62 $0.59 $1.16

91 Brigham Oct-06 15 A-5 41.529309 -112.051568 56.40 $0.57 $0.54 $1.09

468077 Brigham Nov-08 15 A-20, C x 41.538029 -112.071367 7.56 $0.97 $0.89 $0.77 1218298 Honeyville May-14 15 A x 41.631863 -112.103950 22.50 $0.24 $0.26 $0.55 140 Box Elder Mar-07 15 A x 41.635155 -112.108208 36.56 $0.35 $0.32 $0.59 1205151 Elwood Jan-14 15 R 41.658177 -112.130011 0.56 $1.78 $1.93 $0.57

139 Box Elder Dec-07 15 R 41.659892 -112.150181 26.67 $0.24 $0.21 $0.61

Sales Data Summary Page | 9

414752 Box Elder Oct-08 15 A 41.661014 -112.150243 26.00 $0.25 $0.23 $0.62

786567 Honeyville Feb-10 15 A 41.663751 -112.104363 35.55 $0.31 $0.32 $0.56

1155959 Tremonton Jul-14 15 R 41.669213 -112.152418 4.50 $0.61 $0.65 $0.56

414765 Tremonton Dec-07 15 A 41.681839 -112.193606 19.72 $0.34 $0.29 $0.56

1102716 Elwood Nov-12 15 R 41.683409 -112.131915 0.52 $0.97 $1.08 $0.39

85 Tremonton Jul-06 15 MD-B x 41.721158 -112.195730 28.17 $0.69 $0.67 $0.41 414758 Garland Jan-08 15 U x 41.738400 -112.184158 33.86 $0.28 $0.24 $0.43 513415 Box Elder Jul-11 15 A 41.789666 -112.125287 12.91 $0.23 $0.25 $0.44

138 Box Elder Jul-09 15 AR 41.823261 -112.125993 15.00 $0.27 $0.26 $0.42

544700 Plymouth Jan-08 15 A 41.870436 -112.146720 134.15 $0.12 $0.10 $0.44

1145410 Sevier Jun-13 70 A x 38.589294 -112.268933 7.22 $0.06 $0.06 $0.59 1116868 Joseph Apr-11 70 A 38.619280 -112.220036 20.00 $0.03 $0.03 $0.50

1116690 Elsinore Jun-10 70 R x 38.684850 -112.152815 0.50 $1.08 $1.08 $0.44 1182044 Elsinore Oct-13 70 C 38.683100 -112.149535 0.40 $1.15 $1.20 $0.49

1100125 Elsinore Nov-12 70 R 38.675457 -112.148403 1.09 $0.11 $0.12 $0.53

1110058 Elsinore Oct-12 70 A 38.673965 -112.146893 8.38 $0.16 $0.17 $0.55

1116830 Elsinore Jul-10 70 R 38.690484 -112.144802 1.40 $0.76 $0.77 $0.41

1116785 Elsinore Apr-10 70 A 38.694855 -112.137301 4.87 $0.33 $0.33 $0.25

1117131 Monroe Jul-08 70 A 38.632804 -112.135187 13.95 $0.20 $0.17 $0.73

1116886 Richfield Oct-11 70 A x 38.716808 -112.133288 40.00 $0.11 $0.12 $1.15 1123517 Venice Jun-13 70 A 38.693174 -112.115661 149.28 $0.09 $0.09 $1.17

1100182 Richfield Jun-13 70 R x 38.742130 -112.109728 0.28 $3.28 $3.46 $1.60 1154680 Richfield Sep-13 70 R 38.743616 -112.100383 0.28 $2.95 $3.09 $1.78

1116720 Richfield May-10 70 MG 38.747373 -112.098248 3.55 $0.97 $0.97 $2.32

1135014 Richfield Jul-14 70 R 38.753397 -112.097994 0.27 $3.25 $3.32 $2.63

1116375 Richfield Jan-06 70 R 38.773726 -112.088431 1.70 $1.43 $1.39 $2.16

777069 Richfield Sep-12 70 CG 38.780940 -112.084848 0.66 $3.65 $3.90 $1.74

464148 Richfield Apr-07 70 C-1 38.776503 -112.083002 1.78 $2.66 $2.31 $1.65

1144101 Venice Apr-13 70 A 38.823561 -112.030120 28.60 $0.14 $0.15 $1.19

Sales Data Summary Page | 10

646795 Aurora Mar-07 70 A x 38.876079 -111.966332 86.93 $0.17 $0.15 $1.07 1151104 Sigurd May-13 70 A 38.868781 -111.965525 12.40 $0.29 $0.31 $0.53

1170574 Sigurd Jun-13 70 A 38.864707 -111.961683 33.00 $0.09 $0.09 $0.20

562278 Salina May-07 70 C x 38.933033 -111.823073 36.95 $0.70 $0.60 $0.18 1116901 Salina Apr-12 70 REC 38.921412 -111.478314 5.02 $0.07 $0.07 $0.18

6650841 Salina Sep-07 70 REC 38.905612 -111.461624 743.22 $0.04 $0.03 $0.14

839515 Emery Mar-09 70 A 38.879533 -111.289102 11.32 $0.04 $0.03 $0.15

997167 Green River Mar-11 70 R 38.999000 -110.164053 1.24 $0.10 $0.09 $0.06

1088001 Thompson Jan-14 70 REC 39.454848 -109.301860 320.00 $0.05 $0.05 $0.05

963035 Wendover Jun-10 80 C 40.734054 -114.038719 0.34 $3.03 $3.28 $5.20

988547 Grantsville Feb-12 80 MU-40 40.671875 -112.457246 48.51 $0.04 $0.05 $6.19

716710 Stanbury Park Mar-13 80 CS 40.653908 -112.289634 1.25 $13.10 $15.02 $5.55

717439 Stanbury Park Nov-06 80 CS 40.651569 -112.289253 27.22 $5.06 $4.89 $5.07

704067 Lake Point Oct-07 80 CN 40.681045 -112.271243 2.25 $3.06 $2.76 $4.62

734599 Lake Point Feb-14 80 CH x 40.684102 -112.270899 1.27 $10.00 $11.16 $4.43 618783 Lake Point Apr-07 80 CN 40.681012 -112.270363 2.23 $1.81 $1.69 $4.75

614709 Lake Point Apr-07 80 CN 40.681029 -112.269269 2.24 $1.79 $1.67 $3.25

1125213 Lake Point Dec-12 80 R1 40.682477 -112.266948 5.08 $0.90 $1.04 $2.93

873490 Lake Point Jun-09 80 RR-1 40.675349 -112.255474 1.77 $1.62 $1.62 $3.12

174 Salt Lake Jun-07 80 M-2 40.718957 -112.078593 2.00 $3.21 $2.86 $2.41

79 Salt Lake Jun-08 80 AG 40.725616 -112.067898 46.99 $1.73 $1.53 $2.50

97 Magna Jul-08 80 A-20 40.725513 -112.066188 4.76 $2.27 $2.02 $2.55

526 Salt Lake Jun-12 80 M 40.781290 -112.036307 16.16 $4.00 $4.44 $2.66

529 Salt Lake May-13 80 M 40.778868 -112.034893 6.16 $4.35 $4.78 $2.60

347 Salt Lake Dec-09 80 M-1 40.760532 -112.027395 39.56 $2.47 $2.49 $2.47

82 Salt Lake Sep-07 80 M-1 40.758188 -112.024880 153.91 $2.50 $2.19 $2.49

81 Salt Lake Aug-07 80 M-1 x 40.765817 -112.024804 2.47 $2.32 $2.04 $3.02 338 Salt Lake Dec-09 80 M-1 x 40.769810 -112.013637 23.23 $1.06 $1.08 $3.41 77 Salt Lake Mar-07 80 M-1 x 40.769216 -112.013136 23.23 $1.78 $1.62 $3.69

Sales Data Summary Page | 11

4 Salt Lake Jan-08 80 M-1 40.784142 -112.006072 352.49 $2.00 $1.71 $3.85

40 Salt Lake Jun-08 80 M-1 40.779800 -112.005669 8.38 $7.73 $6.86 $4.11

175 Salt Lake Oct-09 80 M-1 x 40.771379 -112.003502 2.18 $7.96 $7.90 $4.16 43 Salt Lake Jul-08 80 M-1 x 40.770740 -112.003318 3.83 $8.20 $7.29 $4.72 180 West Valley Mar-08 80 M 40.725507 -111.996958 85.92 $4.50 $3.93 $4.95

176 Salt Lake May-09 80 M-1 40.726852 -111.992750 2.39 $4.78 $4.58 $5.25

350 Salt Lake Feb-10 80 M-1 40.754659 -111.992118 15.95 $2.45 $2.51 $5.08

169 West Valley Apr-10 80 M 40.721845 -111.991241 0.50 $5.89 $6.08 $4.57

173 Salt Lake Jan-10 80 M-1 40.754787 -111.991029 1.09 $3.58 $3.65 $4.17

283 Salt Lake Jun-10 80 M-1 40.754790 -111.989887 1.13 $4.26 $4.45 $4.23

172 Salt Lake Jan-09 80 M-1 40.757660 -111.984804 1.05 $5.71 $5.29 $5.76

282 Salt Lake Feb-10 80 M-2 40.752310 -111.972052 3.00 $3.25 $3.33 $6.00

196 Salt Lake Aug-08 80 M-1 40.758515 -111.957682 0.59 $4.09 $3.67 $5.78

39 Salt Lake Aug-07 80 CC x 40.771401 -111.945990 18.82 $5.06 $4.47 $6.56 255 Salt Lake Nov-10 80 CSH 40.772679 -111.939446 1.03 $17.18 $18.36 $8.80

83 Salt Lake Sep-09 80 R-1-5000 40.761913 -111.919551 0.24 $4.76 $4.71 $12.32

18 Salt Lake May-09 80 RMF x 40.763751 -111.918344 0.86 $4.27 $4.06 $12.28 496 South Salt Lake May-12 80 MU 40.715497 -111.891235 4.05 $9.64 $10.71 $12.25

344 South Salt Lake Jul-11 80 CC x 40.718968 -111.888493 0.42 $22.46 $24.61 $11.84 343 Salt Lake Apr-11 80 CSH 40.724664 -111.853971 0.26 $34.00 $36.98 $10.26

986744 Park Nov-10 80 R x 40.750539 -111.612408 0.24 $2.63 $2.92 $10.31 1147152 Park Jul-13 80 R x 40.749950 -111.611025 0.27 $2.98 $3.38 $10.50 1106857 Park Jul-13 80 R 40.745643 -111.605688 3.25 $0.72 $0.82 $9.54

1148587 Park Oct-13 80 R x 40.748897 -111.602832 0.50 $3.65 $4.11 $7.84 1039735 Park Nov-11 80 R x 40.752425 -111.600338 1.10 $4.55 $5.22 $5.01 1051039 Park Jul-12 80 R x 40.752374 -111.599714 0.92 $4.99 $5.75 $6.04 1200599 Park Apr-14 80 R x 40.749719 -111.599430 0.81 $1.85 $2.05 $5.98 1220392 Park May-14 80 R x 40.753308 -111.598677 0.91 $8.45 $9.35 $6.10 1146825 Park Aug-14 80 R x 40.753630 -111.598075 0.66 $10.43 $11.45 $5.75

Sales Data Summary Page | 12

1196548 Park Mar-14 80 R 40.755341 -111.591205 0.25 $11.02 $12.25 $5.85

905471 Park Aug-11 80 MU x 40.752677 -111.573749 11.08 $2.49 $2.83 $5.53 1158876 Park Dec-13 80 R x 40.726001 -111.508513 1.56 $1.65 $1.85 $5.35 1075982 Park Jun-12 80 R 40.725035 -111.505453 2.81 $0.90 $1.04 $4.84

980040 Park Apr-11 80 R 40.734775 -111.495968 0.91 $5.42 $6.12 $3.65

1233994 Park Jun-14 80 R 40.735786 -111.495553 0.93 $2.59 $2.86 $2.40

913333 Park May-10 80 R x 40.754895 -111.476788 13.10 $0.35 $0.38 $2.18 1195750 Park Jan-14 80 R 40.757939 -111.469744 1.04 $4.30 $4.80 $2.08

1002658 Park Aug-11 80 R x 40.760385 -111.468994 1.03 $0.67 $0.76 $1.99 987735 Park Mar-11 80 R x 40.759020 -111.468888 1.07 $0.86 $0.97 $1.31 998038 Park Dec-12 80 R x 40.761804 -111.468746 1.25 $0.73 $0.84 $1.00 960842 Park Mar-11 80 R x 40.763976 -111.467940 1.13 $0.86 $0.97 $0.98 1085045 Wanship Aug-13 80 R 40.801824 -111.426852 20.45 $0.17 $0.19 $0.58

618739 Wanship Aug-06 80 RA x 40.808793 -111.420213 46.24 $0.03 $0.03 $0.73 729085 Wanship Jun-12 80 AP 40.820496 -111.417677 40.00 $0.06 $0.07 $0.80

625530 Wanship Oct-06 80 R 40.822032 -111.405555 19.00 $0.17 $0.17 $0.83

597758 Wanship Aug-06 80 R 40.816890 -111.403742 2.99 $1.21 $1.20 $0.75

668356 Hoytsville May-07 80 RA 40.889601 -111.402019 2.88 $2.27 $2.11 $0.77

1173709 Coalville Apr-14 80 R-2 40.921242 -111.401355 1.03 $1.44 $1.60 $0.94

649662 Coalville May-07 80 RA 40.858346 -111.397170 11.29 $1.27 $1.18 $1.10

448546 Summit County Mar-07 80 AP 40.830664 -111.396110 133.68 $0.26 $0.24 $1.08

1150245 Coalville May-13 80 A x 40.893948 -111.395345 6.35 $0.27 $0.31 $1.18 1159573 Coalville Jun-13 80 RA 40.941308 -111.395081 0.75 $1.38 $1.57 $1.37

1154450 Wanship May-13 80 R 40.829064 -111.390981 1.87 $1.31 $1.49 $1.24

505430 Summit County Aug-07 80 AG-160 41.054154 -111.386749 2,569.49 $0.02 $0.02 $1.20

680756 Coalville May-07 80 RA x 40.839145 -111.385401 0.75 $2.30 $2.14 $1.32 913137 Coalville Jan-10 80 R 40.870047 -111.381093 0.50 $3.54 $3.74 $1.46

969349 Hoytsville Sep-10 80 RA 40.887903 -111.377657 8.75 $0.46 $0.51 $1.44

877861 Hoytsville Feb-10 80 R 40.883872 -111.377047 2.88 $0.72 $0.76 $1.43

Sales Data Summary Page | 13

919758 Snowville Aug-10 84 A 41.965641 -112.775023 10.24 $0.03 $0.03 $0.16

1025860 Snowville May-11 84 R 41.970164 -112.710564 1.14 $0.45 $0.49 $4.70

986330 Howell Jan-11 84 R x 41.845676 -112.436872 27.80 $0.03 $0.04 $0.22 145338 Box Elder Apr-99 84 A 41.738721 -112.274308 80.00 $0.06 $0.06 $0.24

453218 Bothwell Feb-05 84 R x 41.753497 -112.261364 3.00 $0.23 $0.25 $0.30 544684 Bothwell May-07 84 R x 41.728224 -112.255511 6.08 $0.50 $0.45 $0.31 1032121 Bothwell Feb-12 84 R 41.727395 -112.253864 5.09 $0.31 $0.35 $0.52

1219224 Bothwell Jun-14 84 R x 41.723900 -112.246628 5.00 $0.44 $0.47 $0.69 1009462 Bothwell Jun-11 84 R 41.720681 -112.239608 1.11 $0.52 $0.57 $0.82

1126374 Tremonton Feb-13 84 R 41.729001 -112.212247 0.44 $1.33 $1.48 $0.98

1153949 Tremonton Aug-13 84 R 41.730150 -112.212110 0.47 $1.16 $1.27 $1.03

1091747 Tremonton Nov-13 84 R 41.727303 -112.211963 0.78 $1.03 $1.12 $1.00

625505 Tremonton Mar-07 84 R 41.727568 -112.203525 0.56 $1.74 $1.59 $0.93

418567 Tremonton Dec-04 84 R 41.721218 -112.200794 1.00 $0.64 $0.69 $0.89

1178489 Tremonton Sep-13 84 A x 41.696452 -112.188070 98.70 $0.22 $0.24 $1.54 470920 Box Elder Nov-10 84 A 41.653114 -112.169917 57.10 $0.13 $0.14 $1.86

468099 Elwood Dec-07 84 CP2 41.688393 -112.141314 3.90 $1.38 $1.20 $1.69

895151 Riverdale Oct-10 84 C x 41.173558 -112.014000 9.03 $5.35 $5.82 $1.65 638073 Riverdale May-12 84 R-2 41.182691 -112.009397 0.40 $2.93 $3.33 $1.63

295075 Riverdale Jan-08 84 A-1 41.171705 -111.992966 1.45 $0.47 $0.41 $1.66

295075 Riverdale Jan-08 84 A-1 41.171172 -111.992759 1.45 $0.47 $0.41 $1.91

544806 Davis Apr-11 84 A 41.150853 -111.987730 27.58 $0.10 $0.11 $1.12

425 South Weber Jul-12 84 A 41.146216 -111.978469 6.57 $0.30 $0.33 $0.67

350695 South Weber May-03 84 R 41.144533 -111.968858 0.21 $2.73 $2.94 $0.79

10076161 South Weber Jun-96 84 R x 41.147072 -111.959889 12.01 $0.32 $0.34 $1.39 451 Weber Jul-12 84 G 41.149940 -111.940464 53.86 $0.15 $0.17 $1.77

791748 Uintah Apr-09 84 R x 41.139391 -111.939799 1.50 $1.29 $1.25 $2.02 1223168 Uintah Jul-14 84 R 41.139462 -111.939362 0.49 $4.22 $4.58 $2.21

284616 South Weber Sep-02 84 R 41.139452 -111.937774 0.45 $2.60 $2.80 $2.36

Sales Data Summary Page | 14

418264 South Weber Jun-04 84 R x 41.139377 -111.936792 0.75 $1.89 $2.03 $2.51 1186124 South Weber Jan-14 84 R 41.133866 -111.936510 0.47 $4.01 $4.30 $2.34

1165950 Uintah Jul-13 84 R x 41.139534 -111.935425 2.41 $1.24 $1.39 $2.00 170941 South Weber Dec-00 84 R 41.135099 -111.927504 1.00 $1.12 $1.20 $1.92

12030459 South Weber Jun-97 84 A-1 x 41.133896 -111.920986 21.73 $0.04 $0.04 $2.26 408570 Davis Jul-10 84 C 41.126932 -111.906379 4.49 $2.10 $2.26 $1.76

664721 South Weber Jul-10 84 A-1, C 41.127090 -111.906255 4.33 $2.10 $2.20 $1.74

582674 Mountain Green Mar-07 84 CS 41.142936 -111.799171 2.62 $4.99 $4.40 $1.62

1091114 Peterson Aug-12 84 A 41.109282 -111.775667 3.08 $0.74 $0.80 $1.91

910661 Morgan Sep-09 84 R 41.113174 -111.753584 2.92 $1.30 $1.25 $1.80

637934 Morgan Dec-06 84 RA x 41.065456 -111.712943 20.44 $0.39 $0.35 $1.59 1006486 Morgan Dec-10 84 R 41.067039 -111.708645 1.16 $2.02 $2.11 $1.03

1064062 Stoddard Oct-12 84 R 41.070822 -111.704865 1.82 $1.35 $1.46 $1.32

1063809 Stoddard Jul-12 84 R 41.068812 -111.703502 2.73 $0.67 $0.72 $1.80

1062180 Stoddard Aug-13 84 R 41.071651 -111.701324 5.20 $0.51 $0.54 $2.07

1143733 Morgan Nov-13 84 R 41.043777 -111.689603 0.39 $2.65 $2.79 $2.60

1202234 Morgan Jun-14 84 R 41.056618 -111.682184 0.34 $4.45 $4.61 $2.65

818751 Morgan May-10 84 I x 41.046816 -111.678754 5.28 $2.25 $2.27 $2.91 582679 Morgan Nov-07 84 C 41.044629 -111.676865 0.74 $6.89 $5.80 $2.97

1123116 Morgan Jul-13 84 R 41.049617 -111.675156 0.67 $1.71 $1.82 $2.70

1112925 Morgan Nov-12 84 RM15 41.042203 -111.673392 3.68 $2.37 $2.56 $2.12

868915 Morgan Dec-10 84 CH x 41.040949 -111.665672 6.46 $0.91 $0.95 $2.10 464862 Morgan Aug-06 84 C 41.037307 -111.658425 30.00 $0.99 $0.92 $1.58

1042994 Morgan Nov-11 84 A 41.040245 -111.654010 130.02 $0.47 $0.51 $1.40

1158710 Henefer Dec-13 84 R 41.023248 -111.503264 0.37 $1.90 $2.13 $1.23

1128640 Henefer Feb-13 84 R 41.005988 -111.494039 0.75 $1.88 $2.16 $1.12

1035880 Henefer Jul-11 84 A 40.998514 -111.482053 6.87 $0.53 $0.60 $1.04

553731 Henefer Dec-05 84 R 40.997627 -111.477311 1.32 $1.30 $1.37 $0.97

462327 Henefer May-06 84 AP x 40.995326 -111.473923 302.15 $0.17 $0.17 $0.67

Sales Data Summary Page | 15

564817 Henefer May-06 84 A x 40.996592 -111.462868 29.33 $0.31 $0.32 $0.36 1172667 Echo Sep-13 84 A-20 x 41.044382 -111.312112 67.75 $0.01 $0.01 $0.28 617324 Echo Jan-07 84 A-20 x 41.049718 -111.298542 20.02 $0.03 $0.03 $0.09 1030201 Echo Sep-11 84 A-20 x 41.051446 -111.296981 21.23 $0.02 $0.02 $0.08 1249189 Echo Sep-14 84 A-20 41.048695 -111.293883 21.18 $0.04 $0.04 $0.03

1173382 Echo Sep-13 84 A-20 41.049718 -111.293361 20.03 $0.05 $0.06 $0.04

248 Midvale Jan-10 215 RC 40.628843 -111.865623 0.54 $12.52 $12.76 $15.87

11 Murray Mar-09 215 G-O 40.631699 -111.864657 1.87 $17.50 $16.42 $16.31

493 Cottonwood Heights May-13 215 O-R-D 40.632476 -111.813540 8.86 $16.79 $18.43 $16.24

13 Murray Dec-07 215 CNC 40.636796 -111.834455 4.87 $20.51 $17.62 $17.67

58 Holladay Jul-09 215 R-1-87 40.645066 -111.817812 1.68 $16.40 $15.99 $19.21

279 Holladay Aug-10 215 R-1-10 40.659957 -111.814890 0.38 $18.87 $19.89 $17.70

374 Holladay Mar-11 215 R-1-10 40.664767 -111.813014 0.32 $22.24 $24.14 $17.29

62 Holladay Oct-08 215 R-1-10 40.667290 -111.812219 1.23 $11.95 $10.87 $16.82

276 Millcreek Jan-10 215 R-1-8 40.686322 -111.803944 0.18 $15.30 $15.55 $14.90

61 Salt Lake County Jul-09 215 R-1-10 40.692556 -111.792125 0.54 $14.08 $13.65 $12.05

222 West Valley Mar-10 215 M 40.705920 -111.948063 5.80 $10.00 $10.29 $11.19

438 West Valley Dec-12 215 M 40.707702 -111.944541 7.92 $8.88 $9.86 $8.98

41 Salt Lake Jan-08 215 M-1 x 40.731171 -111.951888 2.33 $7.69 $6.59 $7.22 352 Salt Lake Jun-11 215 M-1 40.735397 -111.968794 4.69 $4.10 $4.49 $5.56

527 Salt Lake Sep-13 215 M x 40.741907 -111.945900 7.17 $4.47 $4.86 $4.59 335 Salt Lake Sep-11 215 M-1 x 40.762969 -111.957995 8.93 $1.83 $2.02 $4.37 42 Salt Lake Jun-07 215 BP x 40.773708 -111.951212 3.69 $5.60 $4.99 $4.34 197 North Salt Lake Jan-08 215 MD 40.836262 -111.932643 1.14 $6.43 $5.50 $4.17

Sales Data Summary Page | 16

From: Leslie Peterson To: BOCrfc2015 Cc: Richard Manser; Lynne Yocom; Linda Hull; Park, Randy; [email protected] Subject: Broadband Opportunity Council Date: Wednesday, June 10, 2015 4:36:29 PM Attachments: UDOT Comments to Docket no. 1540414365-5365-01 (1)_S2.pdf

Please see the attached UDOT Comments to Docket no. 1540414365-5365-01 (1).

Thank you, Leslie Peterson Administrative Assistant Utah Department of Transportation Project Development (801) 965-4826 [email protected]

Please note: To better serve the public, our hours of operation are now 8 a.m. to 5 p.m. Monday to Friday.

June 10, 2015

National Telecommunications and Information Administration (NTIA) U.S. Department of Commerce Broadband Opportunity Council 1401 Constitution Avenue NW, Room 4626 Washington, DC 20230 (sent via email to: [email protected])

Comments to the Broadband Opportunity Council in response to the Council’s Notice and Request for comment published in the Federal Register April 29, 2015 (Docket No. 1540414365-5365-01)

Dear Broadband Opportunity Council,

The Utah Department of Transportation (UDOT) appreciates the opportunity to provide comments to the Broadband Opportunity Council in response to the Council’s Notice and Request for comments on expanding broadband deployment and adoption by addressing regulatory barriers and encouraging investment and training.

UDOT supports the Council’s goals of providing broadband service to unserved and underserved populations and believes this is best accomplished through public-private partnerships and streamlining federal regulations which in some cases are a significant barrier. Any proposed changes to federal regulations should recognize these successes, promote their continuation, and remove unnecessary barriers where appropriate.

General Principles The following general principles should be understood from a highway operating agency’s perspective and protected when considering changes in federal regulations.

Project Development  Telephone (801) 965-4173  Facsimile (801) 965-4564  www.udot.utah.gov

Calvin Rampton Complex  4501 South 2700 West  Mailing Address P.O. Box 148380  Salt Lake City, Utah 84114-8380

A. Public Private Partnerships. UDOT has successfully used public-private partnerships to enable expansion of service provider networks to unserved and underserved areas of the state for many years. These partnerships began in the late 1990s when a change in federal law allowed the states to accommodate longitudinal access of telecommunications facilities within interstate rights-of-way under certain conditions. Utah subsequently changed its state law to allow companies to lease or barter in-kind for this access. These successful public private partnerships have enabled UDOT to significantly expand its highway operations over large remote expanses of the state as well as enabling private providers to expand their service. An example of a successful public private partnership is the Scipio to Holden interstate project that included fiber and conduit. Scipio is a very rural town close to the center of Utah. The current incumbent local exchange carrier (ILEC) was a copper only plant that was out of space and did not have the ability to provide good broadband services. Even though system upgrades were needed the ILEC was not in any hurry to provide them because there was no competition. The Scipio school was not connected to high speed internet because there was no service available. Cell phones in the area had very poor connectivity because they were not connected to fiber backbones. A rural competitive local exchange carrier (CLEC) decided that by partnering with UDOT it could afford to provide service to Scipio and the surrounding area. The big difference between the ILEC and CLEC service is that the CLEC built a new high speed fiber network to deliver services. The town of Scipio now has two choices for phone service and business, schools and residents now can get high speed internet. As a result of the new CLEC service the ILEC decided it needed to upgrade and provide better service. An area that was underserved now has great service and cell phones now have strong signals. Broadband prices are reasonable because of two competing providers. By partnering UDOT facilitated a rural community getting high speed connectivity.

B. Value of Interstate and Federal-aid Rights-of-Way Enables Public Private Partnerships. A key principle to the success of public private partnerships is the property value of interstate right-of-way. When the interstate system was built, billions of dollars were spent to purchase expansive linear corridors, remove all longitudinal utility lines and consolidate utility crossings. This initial investment is fiercely protected by the states to keep the interstates operating efficiently without constant interruptions for utility work, to minimize risks imposed by utility lines in the roadway, and to keep future reconstruction and repair costs low. Experience has shown that road project schedules and costs are significantly impacted by utility relocations. With these principles in mind, states are sensitive to allowing any longitudinal utilities in interstate right-of-way. Where the return on investment can be justified to the state, and a private partner recognizes the value of using expansive linear corridors relatively free of obstructions and other utilities, public private partnerships make sense for all parties. The property value of linear highway corridors is a major incentive enabling public private partnerships. Proposed policy changes need to retain this principle.

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C. States and Local Agencies Control Highway Rights-of-Way. The primary purpose of a highway is to move people and goods by vehicles. A secondary benefit of highway rights-of-way is accommodation of public utilities. Construction, maintenance and operation of highways are primarily paid with user fees. Use of a highway right-of-way by utilities is subordinate to vehicular usage. States and local government agencies have enacted legal frameworks to manage highways and balance secondary uses. Permission is required prior to any third party encroaching on the highway right-of-way. Strict requirements may also be imposed depending on the nature of the encroachment and proposed work. State and local control of activities within highway rights-of-way is paramount to protecting their primary usage, and accomplishing community goals. These goals include protecting the public, minimizing delays, enhancing the environment, aesthetics, and promoting economic development. Control of highway rights-of- way needs to remain with the owners.

D. Interaction with Federal Land Agencies. In Utah federal agencies own two thirds of all lands. When interstates and other federal-aid highways were constructed, many easements were granted by federal agencies rather than fee title. A specific highway may traverse UDOT- owned fee title and easements from multiple federal agencies along its route. The practice of issuing highway easements rather than fee title of federal property has led to conflicts operating, maintaining and improving the state highway system.

UDOT practice is to obtain fee title property when building a new road or widening an existing road. This standard practice facilitates operational decisions, permitting decisions, and negotiations with third parties. UDOT is unable to obtain fee title from federal land owners. When there are two owners of the land, confusion arises as to what rights are included/excluded within the easement and who the deciding parties are, mistakes are inadvertently made, and decisions by federal agencies are not always made promptly and transparently. These challenges are compounded an order of magnitude when UDOT is required to interact with multiple federal agencies when installing fiber optics along the highway and partnering with telecommunication companies.

A recent fiber optic and conduit build with a partner telecommunication company highlights exactly these issues. The telecom worked with UDOT and installed more than 100 miles of conduit and fiber on UDOT right of way. In exchange for use of UDOT right-of-way, the telecom provided fiber and conduit - allowing UDOT to communicate with its variable message signs, CCTV cameras, weather sensors, traffic sensors, traffic signals, maintenance sheds and any other device or location that needed to be connected to the traffic network. The telecom company benefitted from the partnership by gaining additional capacity to provide broadband service to underserved communities. UDOT cleared all the environmental requirements because it owns the conduit and part of the fiber optics. The telecom purchased the materials and did the installation.

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While this completed public private partnership is now very successful, it almost didn’t happen due to federal bureaucratic delays. UDOT works closely with FHWA when completing work on federal-aid highways. The installation of fiber optics and traffic systems on federal-aid highways known as Intelligent Transportation Systems (ITS) in public private partnerships is encouraged by FHWA in accordance with Title 23 of the U.S. Code section 514 b. (4) “to promote the innovative use of private resources in support of intelligent transportation system development”. When the project was about 60% complete, Bureau of Land Management (BLM) notified the telecom and UDOT that both were in violation of BLM land rights. The BLM then required UDOT’s telecom partner to obtain land use permits for any portion of the route that traversed easements on BLM land granted to FHWA/UDOT as part of the interstate system. Furthermore, the BLM would not issue any permits to the telecom company for work in areas that were not part of the partnership with UDOT until permits were obtained for work within the UDOT highway easements across BLM land. Project construction came to a complete halt while the BLM and the Federal Highway Administration (FHWA) disagreed about federal policies, definitions and which agency was allowed to make the decision. As a last resort, the telecom went ahead and obtained permits from BLM for the partnered work. The process caused significant and costly delays which threatened the telecom with loss of a major contract. In desperation the telecom reached out to a state senator’s office for help. Completion of the project was delayed by over 8 months. These bureaucratic delays are costly and unnecessary. One agency not multiple agencies should control the permitting and usage of a parcel of land. One federal agency issuing partial oversight of an easement to another federal agency is a confusing and costly practice that needs to be changed.

Response to RFC Questions In addition to the general principles stated above, UDOT offers the following responses to questions specified in the RFC document numbered to correspond with those questions:

5. How can the federal government best collaborate with stakeholders (state, local, and tribal governments, philanthropic entities, industry, trade associations, consumer organizations, etc.) to promote broadband adoption and deployment? Response: Identify and authorize a single federal agency to collaborate with the state when it is partnering with a private provider to barter or share facilities which cross federal lands.

10. Are there federal policies or regulations within the Executive Branch that create barriers for communities or entities to share federally-funded broadband assets or networks with other non-federally funded networks? Response: UDOT has led the way in partnering with telecommunication companies to facilitate broadband builds in urban and rural areas. Public private partnering encourages competition, enhances service in underserved areas, and provides service to unserved areas. UDOT uses highway right-of-way to install conduit and fiber systems in public private partnerships which 4

support Intelligent Transportation Systems (ITS) used to manage traffic throughout the state. This is in accordance with Title 23 of the U.S. Code section 514 b. (4) “to promote the innovative use of private resources in support of intelligent transportation system development”

During federal highway project F-I15-5(54)179, the Bureau of Land Management (BLM) informed UDOT that there was a violation of the use of BLM land on the interstate project. BLM had heard that UDOT was partnering with telecommunication companies along the interstate right of way and allowing commercial traffic within UDOT conduit and fiber lines. BLM informed UDOT that the highway easement allowed use of the fiber and conduit systems for road purposes only and did not provide for private partner usage of UDOT conduits and fiber that crossed BLM managed land. UDOT assumed that since the Interstate was granted highway easements that UDOT, working closely with FHWA, would handle permitting for telecommunication access. BLM referenced an agreement between BLM and the FHWA known as the “Interagency Agreement between the Bureau of Land Management and the Federal Highway Administration Dated July 27, 1982” Section 3 of the agreement states:

“BLM retains the authority to grant additional right-of-way uses within and across the appropriated highway or material site right-of-way. Such additional uses include, but are not limited to, transportation and utility systems for water, power, communications, oil and gas, or any other facilities which are in the public interest, are not directly associated with highway use, operation and related highway purposes, and are not inconsistent with Title 23 of the U.S. Code. The FHWA shall be consulted prior to the issuance of such authorizations”.

UDOT completed the project in partnership with the telecom company. UDOT built 10 miles of conduit and fiber and the telecom company built an additional 15 miles. This public private partnership effectively doubled the fiber miles available through this rural area for both entities. Of the 25 total miles of the newly installed communication system about 3.5 miles crossed the interstate highway easement that was granted by BLM for the Interstate. The telecom company was required to obtain an additional permit from BLM for the 3.5 miles prior to transmitting any commercial broadband traffic. These permit fees are in addition to what UDOT charged the company for ROW fees for use of the 25 miles of interstate right-of-way. The company is being charged twice for the same use authorized separately by FHWA and BLM. This is one example of a recurring problem throughout the state.

The 1982 agreement between BLM and FHWA needs to be updated to enable states to use public private partnerships and reflect numerous changes such as:  The 1998 FHWA policy change allowing states to accommodate longitudinal access of utilities within interstate rights-of-way;  The 1996 Telecommunications Act authorizing states to enter into agreements with telecom companies;

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 USC 23.514b(4) promoting innovative use of public private partnerships to promote development of ITS for highway operations; and  Subsequent changes in state laws allowing longitudinal access to interstate highway right-of- way such as Utah Code Subsection 72-7-108(2)(a), “except as provided in Subsection (4), the department may allow a telecommunication facility provider longitudinal access to the right-of- way of a highway on the interstate system for the installation, operation, and maintenance of a telecommunication facility”

Highway right-of-way should be controlled by the states with FHWA as the lead federal agency when the right-of-way is granted by easement across federal lands. The double standard of state-owned interstate highway rights-of-way (with states having full control of fee title property purchased with federal monies during initial construction of interstate highways) versus easements across federal lands needs to be eliminated. This is primarily an issue in rural areas with a higher percentage of federal lands – in many cases directly impacting the same populations who are unserved and underserved with Broadband.

This one regulation creates the biggest barrier to getting broadband deployment to rural areas. UDOT has transportation corridors that can also be used as broadband corridors. UDOT needs the ability to continue promoting the build out of communication systems without highway projects being held hostage as federal agencies sort out old agreements from the 80’s. UDOT encourages the correction or replacement of this agreement, or new policy that would grant the authority to permit public private partnerships for communication facilities on federal-aid highway rights-of-way that cross BLM lands to state Departments of Transportation through FHWA.

11. Should the federal government promote the implementation of federally-funded broadband projects to coincide with other federally-funded infrastructure projects? For example, coordinating a broadband construction project funded by USDA with a road excavation funded by DOT? Response: As a practice, UDOT accommodates coincidental utility projects where they do not interfere with or add additional cost/schedule to the highway projects. In some cases, this is as simple as coordinating the work. Where a high risk of impact to the highway project exists, the utility work may need to be performed in advance of the highway project or included in UDOT’s project contract and paid for by the utility owner. In some cases, having the utility work included in a highway project contract may cost the utility owner more. Coincidental work typically minimizes overall costs and impacts to the public. Promotion of coincidental work is a good practice, but should not interfere with highway project work. If there are additional costs to the highway project, these should be the responsibility of the utility owner.

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18. What barriers exist at the state, local, and/or tribal level to broadband deployment and adoption? How can the federal government work with and incentivize state, local, and tribal governments to remove these barriers? Response: Define a highway easement across federal lands to include private broadband service providers when the facilities are part of a public private partnership and the public partner is the highway owner. This would allow the highway owner to permit and manage the facilities like it does on all other highway rights-of-way. This would also resolve an internal disagreement between BLM and FHWA regarding language in Title 23 of the U.S. Code section 514 b. (4) “to promote the innovative use of private resources in support of intelligent transportation system development”. UDOT, in close coordination with the local FHWA office, has successfully used this law to enable numerous public private partnerships with broadband service providers. Where UDOT has tried to barter conduits and fiber within highway easements, and the easements cross BLM land, BLM is regulating these uses as they would for a utility company with no public partnership. In this situation BLM permitting has thwarted the public private partnerships for two reasons: 1) the BLM wants a fee from the utility company to locate on “BLM property” even though the facilities are in UDOT’s highway easement and in UDOT’s conduits; 2) the BLM requires a permit for this use and the approval process in some cases has taken over a year.

Summary

Providing broadband access to unserved and underserved populations is best accomplished by public private partnerships where the public partner is the highway owner. The value of highway right-of-way is the keystone that enables partnerships. Control of highway right-of-way needs to remain with the owners – state and local agencies. Where highways cross federal lands by easement, clarify the highway easement rights include broadband service providers who have entered into public private partnerships with the highway owner.

Thank you for the opportunity to share UDOT’s perspective on this important topic. UDOT remains committed to promoting expanded access to broadband services where this can be accomplished through successful public private partnerships.

Sincerely,

Randy Park, P.E. Director of Project Development

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