Contract analysis

1. Phase I Environmental Site Assessment Reports. Phase I Environmental Site Assessment reports have been completed for all parcels affected by the Project. These reports were completed on January 22, 2025, by Pinnacle Geotechnical & Environmental Consulting Inc. (Dr. Raymond Ostrowski, PE, Principal-in-Charge). The Phase I reports were prepared in accordance with ASTM Standard Practice E1527-21 and applicable EPA Al

2. Phase I Cultural Resources Survey. A Phase I Cultural Resources Survey was completed on February 10, 2025, by Pinnacle Geotechnical & Environmental Consulting Inc. The survey identified one pre-contact archaeological site, designated as site 45WH-1287, located near the PS-3 site on Parcel 380220-108400 along Hannegan Road at the Nooksack River crossing. No historic structures, traditional cultural properties, or o

3. Wetland Delineation Report. A wetland delineation report was prepared by Pinnacle Geotechnical & Environmental Consulting Inc. in accordance with the U.S. Army Corps of Engineers Wetland Delineation Manual (1987) and applicable regional supplements. The delineation identified approximately 1.4 acres of Category III palustrine emergent wetlands within the PS-1 and PS-3 footprints. Anticipated permanent wetland fill

4. Appraisal Report. An appraisal report for all easement areas on private property was prepared on March 14, 2025, by Northwind Valuation Group LLC (Jocelyn Trueblood, MAI), located at 505 Lakeway Drive, Suite 220, Bellingham, WA 98229. The appraisal was prepared in accordance with the Uniform Standards of Professional Appraisal Practice ("USPAP") and the Uniform Appraisal Standards for Federal Land Acquisitions ("Y

5. ALTA/NSPS Land Title Surveys. ALTA/NSPS land title surveys have been prepared for all affected parcels by Ironclad Surveying & Land Services LLC (Karen Whitfield, PLS), located at 4850 Cordata Parkway, Suite 110, Bellingham, WA 98226. These surveys form the basis for the metes-and-bounds legal descriptions of all proposed easement areas. See Exhibit H for survey plat references.

6. Geotechnical Reports. Geotechnical investigation reports for each pump station site are currently in preparation by Pinnacle Geotechnical & Environmental Consulting Inc. Findings will be incorporated into the technical environmental sections of the consolidated checklist.

7. Title Commitments. Preliminary title commitments have been issued by Cascade Basin Title Company (Diane Ashworth, Title Officer, 119 East Magnolia Street, Bellingham, WA 98225) for all privately held parcels affected by the Project. Title insurance endorsements will be obtained at or prior to closing of each easement transaction. A.9. Do You Know Whether Applications Are Pending for Governmental Approvals of Other

Section 401 Water Quality Certification. Section 401 of the Clean Water Act (33 U.S.C. § 1341) requires that any applicant for a federal license or permit to conduct any activity that may result in a discharge into navigable waters must obtain a certification from the state that any such discharge will comply with applicable water quality standards. CSIA will submit an application for Section 401 Water Quality Certif

Section 404 Clean Water Act Permit. The Project will involve the discharge of fill material into waters of the United States, specifically the placement of fill in approximately 0.38 acres of Category III palustrine emergent wetlands within the PS-1 and PS-3 footprints. A Section 404 permit under the Clean Water Act (33 U.S.C. § 1344) is required from the U.S. Army Corps of Engineers ("USACE"), Seattle District. CSIA

Section 10 Rivers and Harbors Act Permit. Certain components of the Project, including the force-main pipeline crossing at the Nooksack River, may involve work within navigable waters of the United States, triggering the requirement for a permit under Section 10 of the Rivers and Harbors Act of 1899 (33 U.S.C. § 403). CSIA will file for a Section 10 permit concurrently with its Section 404 permit application. The app

Section 106 Consultation. Section 106 of the National Historic Preservation Act (54 U.S.C. § 306108) requires federal agencies to take into account the effects of their undertakings on historic properties and to afford the Advisory Council on Historic Preservation a reasonable opportunity to comment. Because the Project will require federal permits from the U.S. Army Corps of Engineers (Section 404 and Section 10 per

Section 106 Consultation. The Section 106 consultation process under the National Historic Preservation Act (54 U.S.C. § 306108) will be completed in coordination with DAHP and the USACE prior to the issuance of a construction Notice to Proceed for the PS-3 site. CSIA anticipates that the Section 106 consultation will result in a finding of "no adverse effect" with conditions, including implementation of the archaeol