Q~h.~gtBT OF Ty <br />United States Department of the Interior <br />OFFICE OF THE SECRETARY <br />WASHINGTON, D.C. 20240 <br />~QRCH 3.,ang FEB - 7 2014 <br />In Reply Refer To: (ER 14/0001) (ER 14/0004). <br />Mr. Eli Veenendaal <br />National Telecommunications and Information <br />Administration <br />U.S. Department of Commerce <br />1401 Constitution Avenue, N.W. <br />Washington, D.C. 20230 <br />Dear Mr. Veenendaai. <br />Q <br />TAKE PRIDE <br />INAMERICA <br />The Department of the Interior (Department) has reviewed the above referenced proposal and <br />submits the following comments and attachment for consideration. Because the First Responder <br />Network Authority (FirstNet) is a newly created entity, we commend the U.S. Department of <br />Commerce for its timely proposals for NEPA implementing procedures. <br />The Department believes that some of the proposed procedures are not consistent with Executive <br />Order 13186 Responsibilities of Federal Agencies to Protect Migratory Birds, which specifically <br />requires federal agencies to develop and use principles, standards, and practices that will lessen <br />the amount of unintentional take reasonably attributed to agency actions. The Department, <br />through the Fish and Wildlife Service (FWS), finds that the proposals lack provisions necessary <br />to conserve migratory bird resources. including eagles. The proposals also do not reflect current <br />information regarding the eft'"i , of c oliununication towers to birds. Our o6mments are intended <br />to further clarify specific issueG and address provisions in the proposals.; <br />The Department recommends revisions to the proposed procedures to better reflect the impacts <br />to resources under our jurisdiction from communication towers. The placement and operation of <br />communication towers, including un-guyed, unlit, monopole or lattice-designed structures; <br />impact protected migratory birds in two significant ways. The first is by injury, crippling loss, <br />and death from collisions with towers and their supporting guy-wire infrastructure, where <br />present. The second significant issue associated with communicatiuri towers invol:vesin pacts <br />from non-ionizing. electromagnetic radiation emitted by_ them (See Vtachment).: <br />In addition to the 147 Birds of Conservation Concern (BCC) species, the FWS has listed an <br />additional 92 species as endangered or threatened under the Endangered Species Act. Together <br />with the bald and golden eagle, this represents 241 species of birds whose populations are in <br />trouble or otherwise merit special protection, according to the varying criteria of these lists. The <br />Department suggests that FirstNet consider preparing a programmatic environmental impact <br />statement (see attachment) to determine and address cumulative impacts from authorizing <br />FirstNet projects on those 241 species for which the incremental impact of tower mortality, when <br />