Project Narrative Section 1 – About Commnet Commnet Wireless, LLC (“Commnet”)1 is pleased to submit this application for RBDG-A funds to bring fiber based broadband services to the city of Page, Arizona. Commnet is a wholly-owned subsidiary of ATN International, Inc. (“ATN”)2. Commnet has been a subsidiary of ATN since 2005 and has been one of the premier wireless carriers serving rural America for over twenty years. During that time, Commnet’s focus has been on connecting rural communities with less than a population of 2,500 with affordable, carrier grade communications networks to improve safety and quality of life, and to promote economic development. Through its subsidiaries, Commnet operates hundreds of cell sites including many in the State of Arizona. In addition to being a mobile wireless carrier, Commnet is a high-speed fixed broadband service provider in some of the most rural areas of the country. In fact, Commnet was recently awarded funding via the Connect America Fund (CAF II) to deploy fixed broadband service in six (6) states including the State of Arizona. Therefore, Commnet satisfies the criteria to be an eligible applicant. To complete the proposed project, Commnet will utilize its subsidiary Commnet AZ, LLC (“Commnet AZ”). Commnet AZ is a Competitive Local Exchange Carrier certified by the Arizona Corporation Commission.3 Commnet AZ was formed in 2016 to build and operate fiber networks in rural Arizona. In 2017 Commnet’s affiliate NTUA Wireless, LLC (NTUAW) was awarded a contract by the Apache County Schools Business Consortium (“ACSBC”) to construct a 170-mile fiber network that connects member schools and libraries to a high-speed broadband network. Commnet AZ was contracted to construct and operate a substantial part of this network (i.e., the portion outside the Navajo Nation), enabling fiber based service to be delivered to rural communities such as St Johns, McNary, Vernon, Concho, Greer and Round Valley. This fiber build was completed in June 2019. In 2018, Commnet AZ was awarded an E-Rate Special Construction contract by the Grand Canyon Unified School District (“GCUSD”) to construct approximately 70 miles of new fiber facilities – in Coconino County - from Williams, Arizona to the GCUSD. This funding request is currently under review by the Federal Communications Commission. If approved, Commnet AZ will be able to increase GCUSD’s available bandwidth from less than 10 Mbps to over 1 Gbps. Additionally, Commnet AZ will be the only fiber based broadband service provider in the that part of Coconino county and will serve rural communities such as Tusayan. In May 2019, Commnet submitted a USDA Reconnect Grant application that is currently under review. If awarded, Commnet will deliver fiber based broadband service to rural communities such

1 Commnet Wireless, LLC is authorized to do business in the state of Arizona. Please see Exhibit 1. 2 ATN is a publicly traded company founded in 1987. ATN is traded on the NASDAQ stock exchange and has a market capitalization of nearly . 3 Please see Exhibit 2 for Final Opinion and Order in Docket No. T-20966A-16-0135 granting Commnet AZ’s Application for Certificate of Convenience and Necessity to Provide Intrastate Telecommunications Service in Arizona.

6 as Eager, Springerville, McNary, White River, Canyon Day, Fort Apache, Cibeque, Hon-Duh and Canyon Day. In summary, Commnet through its subsidiaries Commnet AZ and NTUAW are already increasing broadband availability in rural areas of Arizona. Should Commnet be awarded funding through the Arizona Rural Broadband Development Grant it will be able to continue this effort and bring much needed broadband access to Page, Arizona and the surrounding areas such as Kaibeto, Lechee and Tonalea. Section 2 – Project Description and Infrastructure Matters Commnet’s Proposed Infrastructure Improvements Commnet proposes to construct and deploy approx. 15 miles of new fiber – consisting of both aerial and buried fiber – in the city of Page, Arizona to connect anchor institutions, businesses and towers in the area. All last mile connections along the proposed fiber build will be connected via fiber. All other last mile connections will be over fixed wireless technology. Although not directly funded via the RBDG-A award, Commnet expects to leverage a new middle mile build of approximately 34 miles. NTUA, a partner of Commnet, intends to construct a 34 mile middle mile route from the boundary between the City of Page/Navajo Nation to its existing fiber in Tonalea, Arizona. NTUA’s proposed 34-mile route will connect Kaibito, Arizona and Lechee, Arizona, two areas that completely lack fixed broadband service. Significantly, as noted in NTUA’s letter of support for this project, the construction of the new middle mile fiber is largely contingent upon Commnet being granted a RBDG-A award. As noted in Mr. Broyles’ letter, “unfortunately, due to the cost of building this type of network in rural areas with low population density, NTUA’s fiber build from Tonalea to Page is largely contingent upon Commnet being awarded funding through this grant which in turn enables NTUAW to offer broadband services in these underserved and unserved communities. By Commnet being awarded this funding, residents and businesses in Kaibito, Arizona, Lechee, Arizona, and Page, Arizona stand to benefit immensely from NTUAW’s broadband offerings.” Through this newly built fiber network, businesses, hospitals, government offices, schools and residents will have access to affordable broadband at speeds of at least 25/3 for the first time. For residential and small business services, Commnet plans to work with Canyon Country Communications (“CCC”) and deliver to it much needed increased capacity that will enable it to offer broadband at speeds of at least 25/3, even during peak hours. As mentioned in the letter of support for this application from Jon Jones, President of CCC, the existing residential customers and others in the community will benefit from Commnet’s ability to provide increased bandwidth through its fiber network. Additionally, Commnet will work with its subsidiary NTUAW to offer enterprise and carrier-to-carrier services in the City of Page. One immediate benefit, for example, would be increased bandwidth to existing telecommunications companies in Page that currently rely on backhaul through microwave links and are in need of increased capacity. This Project is needed because Page, Arizona is both an unserved and underserved area.

7 According to the FCC Fixed Broadband Deployment Map no carrier has deployed broadband services that meet the minimum acceptable download/upload speeds of 25Mbps/3Mbps respectively in Page, Arizona. Therefore, Page, Arizona is an unserved area for purposes of the Arizona Rural Broadband Development Grant. A grant of a RBDG-A award will enable Commnet to deploy (1) fiber based broadband services with speeds of up to 1Gbps and (2) fixed wireless internet service with speeds of 25Mbps/3Mbps or higher in Page, Arizona.

Section 3.2 of the Request for Grant Application (RGA) defines an underserved area as follows: “Underserved means an area in which services at minimum speeds of 25/3 are not available to 10 percent or more of the intended beneficiaries.” In its letter of support, Canyon Country Communications states that “it is a small WISP in Page, Arizona serving over 300 residential and small business customers” and that it is “unable to provide service even near to the 25/3, which is the requirement to be considered broadband.” Therefore, Page Arizona is also an underserved area for purposes of the Arizona Rural Broadband Development Grant. A grant of a RBDG-A award will enable Commnet to increase existing speeds in Page, Arizona to a minimum of 25Mbps/3Mbps at costs that are substantially equal to urban areas. The proposed project will enable the people of Page, Arizona to receive affordable broadband services and will provide redundancy. The proposed project will connect the fiber build in Page, Arizona to The Navajo Tribal Utility Authority (NTUA) middle mile at the City of Page/Navajo Nation boundary. NTUA intends to expand its middle mile fiber network from Tonalea, Arizona to the meet point which is largely contingent upon a grant of a RBDG-A award to Commnet to build a fiber network in Page,

8 Arizona. If NTUA expands its middle mile from Tonalea, Arizona Z to the meet point at the City of Page/Navajo Nation boundary, Page, Arizona will be connected all the way to Phoenix, Arizona for the first time via a 100% fiber based diverse path. Specifically, (1) Commnet’s fiber network will connect to the NTUA middle mile at the City of Page/Navajo Nation boundary; (2) the NTUA middle mile will connect to Cable One fiber at Bitahochee; and (3) Cable One fiber will connect Bitahochee to Phoenix. Anticipated Economic Development Benefit The proposed project will benefit the residents, businesses and anchor intuitions in Page, Arizona.

Number of Potential Beneficiary Type Beneficiaries in Page, AZ Carrier-to-carrier Wholesale 10 Education 5 Government 15 Healthcare 4 Hospitality 26 Small Business 310 Residential Households 1066 Residential Population 3,059

In addition to the direct beneficiaries in the City of Page an additional 3,128 individuals totaling 683 households in the communities of Kaibito and LeChee, Arizona stand to benefit from the proposed project. Total Miles of Fiber to be Installed Through this project, Commnet plans to construct approximately 15 miles of new fiber in the City of Page. In addition to its 15 miles of fiber, NTUA has committed to construct approximately 34 miles of new fiber from Tonalea, Arizona to the border of the Navajo Nation in Page, Arizona. Lastly, to complete the build, Commnet intends to leverage approximately 5 miles of existing dark fiber from SRP/City of Page. The fiber will be installed both aerially and underground, depending on the location of the build. Commitment to Operate and Maintain the Network If RBDG-A funding is awarded for this project, Commnet is committed to complete the fiber build within the required 24 months,4 or sooner, and operate and maintain the network for at least five years upon completion of the project. Parties Performing the Infrastructure Construction Commnet will rely on its subsidiary Commnet AZ, to complete the construction of the fiber network in Page. Commnet AZ may utilize contractors to perform the work, and if so, will ensure the contractors are licensed and bonded in accordance with applicable procurement laws and

4 Please see Exhibit 3 for Proposed Timeline.

9 regulations. For the build from Tonalea, Arizona to the border of the Navajo Nation, Commnet will rely on the Navajo Tribal Utility Authority who currently operates a fiber network on the Navajo Nation. Intended Uses of RBDG A Funds Commnet intends to use the RBDG A funds as reimbursement for construction of its fiber network in Page, Arizona. This construction includes materials, electronics and labor needed to complete the project. Section 1.4 Requirements As provided above, this project is eligible for RBDG A grant funding:  Page, Arizona is both unserved and underserved  The project will make broadband at speeds of at least 25/3 available to the intended beneficiaries and at affordable rates  The project will provide redundancy  Build out of middle mile and last miles connections are included and will enable speeds of at least 25/3 to the intended beneficiaries. Timeline of Completion of Infrastructure Improvements Commnet anticipates completing the project within 13 months of beginning work following an award. Please see Exhibit 3 for Proposed Timeline. Cash Match Contribution The cash match will be provided throughout the project and will be used for construction costs. Commnet itself will provide at least a cash match, as provided in the Letter of Commitment from Joe Moravec, Commnet’s President of US Telecom5. The current estimated cost of the project is of which Commnet is requesting to be provided in grant funds and will pay the remaining 6 Should the project cost less than , Commnet’s cash match will decrease accordingly, but nevertheless, Commnet commits to provide at least a cash match as required by the grant. The Project would not occur in the absence of an RBDG-A award. Commnet does not intend to move forward with the proposed fiber build in Page, Arizona in the absence of an RBDG-A award. Additionally, NTUA’s middle mile project from the City of Page/Navajo Nation boundary to Tonalea is largely contingent upon Commnt being granted a RBDG-A award. Section 3 - Project Description and Timeline – Development Matters Description of Project Including Nature and Scope, Type of Technology, and Type of Construction

5 Letter of Commitment to provide at least a cash match is attached hereto as Exhibit 4. 6 Please see Exhibit 5 for audited financials of Commnet’s parent ATN as reported on its 2018 Form 10-K.

10 According to the FCC Fixed Broadband Deployment Map no carrier has deployed broadband services that meet the minimum acceptable download/upload speeds of 25Mbps/3Mbps respectively in Page, Arizona. Commnet AZ will construct and deploy approx. 15 miles of new fiber – consisting of both aerial and buried fiber – in the city of Page, Arizona to connect anchor institutions, healthcare facilities, educational institutions, businesses and towers in the area. The proposed fiber route will start near the SRP Power Station and traverse via Highway 89, Lake Powell Blvd, 7th Avenue and end at South Lake Powell Blvd and Sunrise Street. The proposed project anticipates connecting all anchor institutions, businesses, healthcare facilities, schools and government offices to its network almost exclusively via underground fiber within the city and delivering up to 1Gbps broadband service. The project will connect Canyon County Communications’ – a competitive broadband service provider in Page, Arizona - towers to the new fiber network. By doing so, Canyon County Communications will be able to deliver 25Mbps/3Mbps or better fixed wireless broadband service offerings to its small business and residential customers including the 300 or so existing customers. The fact that Canyon County Communications is unable to deliver speeds of 25Mbp/3Mbps today to its 300 or so customers is clear evidence that broadband speeds of at least 25Mbps/3Mbps is not readily available to at least 10% of the community’s businesses and residents of Page, Arizona. The project also intends to connect mobile/wireless towers in the area to the proposed fiber network. By doing so, the project will enable and expedite the deployment of 5G mobile broadband service in Page, Arizona. Additionally, Commnet is ready and willing to provide carrier-to-carrier service on a wholesale basis to all broadband service providers in Page, Arizona. Commnet AZ intends to leverage approximately 5 miles of existing dark fiber owned by SRP/City of Page to connect the new fiber from the City of Page to the boundary between the City of Page and the Navajo Nation. Commnet AZ will also leverage approx. 34 miles of new fiber that NTUA intends to construct from the boundary between the City of Page/Navajo Nation to connect Page, Arizona to its existing fiber in Tonalea, Arizona. The proposed 34-mile route will connect Kaibeto, Arizona and Lechee, Arizona to Tonalea, Arizona in addition to Page, Arizona which are areas that completely lack fixed broadband service. Although NTUA’s fiber build is not part of this Application, it is largely contingent upon the grant of an award to Commnet to construct fiber in the City of Page. Commnet AZ will also seek to cross connect the new fiber at South Lake Powell Blvd and Sunrise Street to UPN/City of Page Dark Fiber to serve the Page Unified School District and other government institutions. Finally, the proposed project will provide a 100% fiber based diverse path that will connect Page, Arizona to Phoenix, Arizona for the first time. Therefore, as described above, the proposed project will:  Bring broadband service with speeds of 25Mbps/3Mbps or above to unserved and underserved areas of Arizona;  Increase existing speeds to a minimum 25Mbps/3Mbps to the intended beneficiaries of the project at costs that are substantially equal to urban areas;

11  Provide redundancy to the region and connect Page, Arizona to Phoenix, Arizona with a 100% fiber route; and  Build out middle mile or last mile connections with a minimum speed of 25Mbps/3Mbps as described in this Application. Qualifications of Vendors/Contractors If Commnet is awarded funding for this project, Commnet will likely use a subcontractor to complete the build. Although a contractor has not yet been identified, Commnet will ensure the contractor is licensed and bonded in accordance with Arizona procurement laws and has sufficient experience designing and constructing fiber networks. Background of the Project As discussed above, according to the FCC Fixed Broadband Deployment Map Page, Arizona is both an underserved and unserved area. Canyon Country Communications – one of the largest competitive broadband provider in Page – in unable to deliver speeds to its existing 300 customers due to lack of capacity and reliance on microwave links. Separately, the businesses and anchor institutions in Page, Arizona currently lack access to bandwidth at affordable rates that is needed for them to conduct business. Project Design

A design diagram showing the proposed fiber build in the City of Page is attached as Exhibit 6. Households, Anchor Institutions and Business to be Served

Number of Potential Beneficiaries Beneficiary Type in Page, Arizona Carrier-to-carrier Wholesale 10 Education 5 Government 15 Healthcare 4 Hospitality 26 Small Business 310 Residential Households 1066 Residential Population 3,059

In addition to the direct beneficiaries in the City of Page an additional 3,128 individuals totaling 683 households in the communities of Kaibito and LeChee, Arizona stand to benefit from the proposed project. Section 4- Other Project Outcomes The proposed project to deliver fiber to Page, Arizona will support and enhance economic development, community resiliency, educational and healthcare advancements and public safety. As explained above, Commnet’s proposed design will leverage existing dark fiber in addition to

12 deploying new fiber to deliver speeds of up to 1Gbps over the fiber network, and will therefore, deliver a cost efficient, fiber based, broadband solution. One immediate improvement will be seen by Canyon County Communications’ existing customers. As referenced in Jon Jones’ letter of support for this project, its existing customers do not receive adequate speeds during peak usage times and it is in need of increased capacity. Because Commnet will provide bandwidth on a wholesale basis, Canyon Country Communications’ existing customers will see improved service availability and speeds. Additionally, because Canyon Country Communications has more access to bandwidth it can add new customers without degrading service for existing customers and offer new rate plans comparable to urban areas. Similarly, because Commnet is providing access to its network on a wholesale basis, NTUAW will be a new market entrant in the City of Page. More competition will drive prices down and give more choice to customers both in terms of service providers and rate plans. In addition to improved residential and small business services, existing mobile providers in the City of Page will also see an immediate benefit. Because Commnet plans to provide fiber based backhaul service to these mobile service providers, the backhaul networks to their towers will be more resilient and they will be able to expedite the deployment of 5G service in Page. Lastly, because Commnet’s proposed project plans to connect to NTUA’s fiber network on the Navajo Nation, for the first time, there will be a 100% fiber based connection from the City of Page to Phoenix, Arizona. This connection will allow for deployment of improved government services and open telehealth, distance learning and business opportunities. Section 5 - Project Budget Attached to this application as Exhibit 7 is a line-item budget showing the RBDG A funds sought and the cash match committed by Commnet. Section 6 - Documentation Commitments Attached to this application as Exhibit 4 is a Letter of Commitment from Commnet signed by its President of US Telecom. As stated in the letter, should the project be awarded, Commnet is committed to provide at least a cash match based on the final costs of the project. Furthermore, as confirmed in the letter, Commnet is ready and able to execute a contract with the Arizona Commerce Authority within sixty (60) days of notification of a grant award. Section 7 - Letters of Support Attached to the application as Exhibit 8 are letters of support from the following individuals: 1. Christopher Becenti – Director of Telecommunications and Regulatory Commission 2. Ken Buchanan – Interim City Manager, City of Page 3. Jon Jones – Canyon Country Communications, President 4. Neil Broyles – Navajo Tribal Utility Authority, Communication Systems Manager 5. Clyde Casciato – NTUA Wireless, LLC, General Manager

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