Little River Band Trust Acquisition and Caisno Project Final Environmental Impact Statement Appendices U through W [PDF] - Free Document Online (2023)

APPENDIX U SECTION 106 CONSULTATION

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United States Department of the Interior BUREAU OF INDIAN AFFAIRS Midwest Regional Office Nonnan Pointe II, Suite 500 5600 West American Boulevard Bloomington, Minnesota 55437 IN REPLY REFER TO Environmental, Cultural Resource Management and Sarety AUG O3 2016 Ogema Larry Romanelli Little River Band of Ottawa Indians 3 75 River Street Manistee, MI 49660 Re: Section I 06 Consultation - Little River Band of Ottawa Indians Fee-to-Trust Application for the Purpose of Gaming (25CFR151): Proposed Project in Muskegon County, Michigan Dear Ogema Romanelli: We are writing in regard to Section 106, National Historic Preservation Act (NHPA) consultation for the Little River Band of Ottawa Indians (Tribe) Fee-to-Trust application for the purpose of gaming (25CFR151). The Band has requested that the Bureau of Indian Affairs Midwest Region (BIA-MR) transfer approximately 60 acres of the Tribe's fee land located in Muskegon County, Michigan, into federal trust status. The 60 acre parcel as well as an additional approximate 26.5 acres of adjacent land owned by the Tribe (a total of 86.5 acres) is proposed for development. The 86.5-acre project site is referred to herein as the Subject Property. The Proposed Project includes a casino, hotel, conference center, parking, and other supporting facilities. The BIA-MR has determined that the Proposed Project is an undertaking as defined by 36 CFR 800.16(y) because the Tribe has submitted a consolidated request for a "two-part determination" for the Property pursuant to Section 20 of the Indian Gaming Regulatory Act. The Area of Potential Effect (APE) consists of the Subject Property and several road and water infrastructure improvements that will be required to mitigate potential impacts from operation of the Proposed Project. It is anticipated that all construction activities and staging would take place within the APE and that no excavations would be more than eight (8) feet deep. A Phase I archaeological survey of the parcels including a literature search for the APE was conducted by Analytical Environmental Services (AES) in 2016 (Enclosure I). No historic properties were identified. A finding of no historic properties affected was recommended by AES. The BIA-MR has determined that the undertaking will have no effect to historic properties (36 CFR 800.4 (d) (1)). No further archaeological work is recommended. Please let us know if you concur with the BIA's determination. If you have any questions related to the project, please contact Timothy Guyah, BIA Regional Archaeologist, at 612-725-4512.

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Sincerely, Regional Director Enclosure (1 ): Compact Disc (CD) containing the Little River Band of Ottawa Indians Trust Acquisition and Casino Project [Muskegon Site] - Cultural Resources Report dated June 2016 2

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Gaa Ching Ziibi Daawaa J\Uif hffl,q.q,[iek rr :\I• Little River Band of Ottawa Indians 2608 Government Center Dit lllG 22 ~H \I t 34 Manistee, MI 4966o'-u August 15, 20 16 Ms. Diane Rosen, Acting Director Bureau of Indian Affairs Midwest Regional Office 5600 West American Boulevard, Suite 500 Bloomington, MN 55437 Dear Ms. Rosen, We have received your Section 106 consultation letter concerning our proposed project in Muskegon County, Michigan. After review by out Tribal Historic Preservation Office, we too are unaware of any historic prope11ies within the APE, which as you know has been extensively developed and disturbed over the last 20 or more years. Accordingly, we concur with the Bureau of Indian Affairs' determination. Sincerely, ,)J \l-ix-l/ tp () b) i,l.{1 Lal/ykoml.nelli, r.c: ~ Ogema {;:__ ~J:o~~ T!~Council h~~~6> Frank Medacco, C ~fui ~-('. Tribal Council

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United States Department of the Interior BUREAU OF INDIAN AFFAIRS Midwest Regional Office Norman Pointe II, Suite 500 5600 West American Boulevard Bloomington, Minnesota 55437 IN REPLY REFER TO: Environmental, Cultural Resource Management and Safety 2 9 2016 Brian D. Conway, State Historic Preservation Officer 702 W. Kalamazoo Street Lansing, MI 48909 Re: Section 106 Consultation Little River Band of Ottawa Indians Fee-to-Trust Application for the Purpose of Gaming (25CFR151): Proposed Project in Muskegon County, Michigan Dear Mr. Conway: We are writing in regard to Section 106, National Historic Preservation Act (NHPA) consultation for the Little River Band of Ottawa Indians (Tribe) Fee-to-Trust application for the purpose of gaming (25CFR151 ). The Band has requested that the Bureau of Indian Affairs Midwest Region (BIA-MR) transfer approximately 60 acres of the Tribe's fee land located in Muskegon County, Michigan, into federal trust status. The 60 acre parcel as well as an additional approximate 26.5 acres of adjacent land owned by the Tribe (a total of 86.5 acres) is proposed for development. The 86.5-acre project site is referred to herein as the Subject Property. The Proposed Project includes a casino, hotel, conference center, parking, and other supporting facilities. The BIA-MR has determined that the Proposed Project is an undertaking as defined by 36 CFR 800.16(y) because the Tribe has submitted a Fee to Trust Application for the Purpose of Gaming (25CFR151). The Area of Potential Effect (APE) consists of the Subject Property and several road and water infrastructure improvements that will be required to mitigate potential impacts from operation of the Proposed Project. It is anticipated that all constrnction activities and staging would take place within the APE and that no excavations would be more than eight (8) feet deep. A Phase I archaeological survey of the parcels including a literature search for the APE was conducted by Analytical Environmental Services (AES) in 2016 (Enclosure 1). No historic properties were identified. A finding of no historic properties affected was recommended by AES. The BIA-MR has determined that the undertaking will have no effect to historic properties (36 CFR 800.4 (d) (1)). No further archaeological work is recommended. Please let us know if you concur with the BIA's determination. If you have any questions related to the project, please contact Timothy Guyah, BIA Regional Archaeologist, at 612-725-4512.

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Sincerely, ~ __ £ ~ Acting Regional Director Enclosures (3): Compact Disc (CD) containing the Little River Band of Ottawa Indians Trust Acquisition and Casino Project [Muskegon Site] - Cultural Resources Report dated June 2016 Section 106 Consultation letter BIA-MR to the Little River Band Ogema Regarding the Little River Band of Ottawa Indians Fee-to-Trust Application for the Purpose of Gaming (25CFR151 ): Proposed Project in Muskegon County, Michigan - dated August 3, 2016. Response from the Little River Band Ogema to the BIA-MR Regional Director Regarding the Little River Band of Ottawa Indians Fee-to-Trust Application for the Purpose of Gaming (25CFR151): Proposed Project in Muskegon County, Michigan - dated August 15, 2016. cc w/o enclosures: Ogema Lan-y Romanelli 2

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STATE OF MICHIGAN MICHIGAN STATE HOUSING DEVELOPMENT AUTHORITY KEVIN ELSENHEIMER STATE HISTORIC PRESERVATION OFFICE EXECUTIVE DIRECTOR October 27, 2016 TIMOTHY GUYAH BUREAU OF INDIAN AFFAIRS MIDWEST REGIONAL OFICE NORMAN POINTE II SUITE 500 5600 WEST AMERICAN BOULEVARD BLOOMINGTON MN 55437 RE: ER16-453 Little River Band of Ottawa lndtans Casino/Gaming Facllity (Fee-to-Trust Application), Section 15, T9N, R16W, Fruitport Township, Muskegon County (BIA) Dear Mr. Guyah: Under the authority of Section 106 of the National Historic Preservation Act of 1966, as amended, we have reviewed the above-cited undertaking at the location noted above. Based on the Information provided for our review, the State Historic Preservation Officer (SHPO) concurs with the determination of the BIA that no historic properties are affected within the area of potential effects of this undertaking. This letter evidences the BIA's compllance with 36 CFR § 800.4 " Identification of historic properties," and the fulfillment of the BIA's responsibility to notify the SHPO, as a consulting party in the Section 106 process, under 36 CFR § 800.4(d)(1) "No historic properties affected." If the scope of work changes In any way, or If artifacts or bones are discovered, please notify this office Immediately. We remind you that federal agency officials or their delegated authorities are required to Involve the public in a manner that reflects the nature and complexity of the undertaking and its effects on historic properties per 36 CFR § 800.2(d). The Natrona! Historic Preservation Act also requires that federal agencies consult with any Indian tribe and/or Tribal Historic Preservation Officer (THPO) that attach religious and cultural significance to historic properties that may be affected by the agency's undertakings per 36 CFR § 800.2(c)(2)(11). The State Historic Preservation Office is not the office of record for this undertaking. You are therefore asked to maintain a copy of this letter with your environmental review record for this undertaking. If you have any questions, please contact Brian Grennell, Cultural Resource Management Speclallst, at 517-335-2721 or by email at [emailprotected] Please reference our project number In all communication with this office regarding this undertaking. Thank you for this opportunity to review and comment, and for your cooperation. ~fl-~ Brian G. Gren ell Cultural Resour for Brian D. Conway an gement Specralrst State Historic Preservation Officer SAT:BGG ~6. State Historic PreservaUon Office Michigan Library and Hlstork:al Center• 702 West Kalamazoo Street• PO BOX 30740 • Lansing, Michigan 48909-8240 Equal www.michigan.gov/shpo • 517 373 1630 • FAX 517 335.0348 • TIY 800.382.4568 Housing Lender

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NACD Query Results Full Data Report Query input: State = Michigan County = Muskegon The following 5 records for Federally recognized Indian tribe(s), Native Hawaiian organization(s), and/or their designated NAGPRA contact(s) have been identified: • Bay Mills Indian Community, Michigan • Grand Traverse Band of Ottawa and Chippewa Indians, Michigan • Little Traverse Bay Bands of Odawa Indians, Michigan • Red Lake Band of Chippewa Indians, Minnesota • Sault Ste. Marie Tribe of Chippewa Indians, Michigan The following 2 related records have been identified: • Ottawa and Chippewa Indians of Michigan • Red Lake Band There are 7 total records 1 of 20

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Full Data Report Bay Mills Indian Community, Michigan Entity Type(s): Federally Recognized Indian Tribe Authority: BIA Recognized Indian Entities, Federal Register, Nov. 25, 2005 Last Update To Information: 05/12/2016 Contact(s) Authority Veronica Pasfield Bay Mills Indian Community, Michigan 12140 W. Lakeshore Dr. Brimley, MI 49715 734-272-6325 [emailprotected] Representative Letter From Tribal Official Contact(s) Authority Paula Carrick Bay Mills Indian Community, Michigan 12140 W. Lakeshore Drive Brimley, MI 49715 906-248-3241 [emailprotected] Tribal Historic Preservation Officer Federal agency-identified Contact Contact(s) Authority Levi Carrick Sr. Bay Mills Indian Community, Michigan 12140 West Lakeshore Drive Brimley, MI 49715 906-248-8100 906-248-3283 fax [emailprotected] Chairperson BIA Tribal Leaders Directory, Fall/Winter 2015 2 of 20

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Related Tribes/Villages: Used For Sault Ste. Marie Band of Chippewa (Also Known As) Relation Red Lake Band of Chippewa Indians, Minnesota (Federally Recognized Indian Tribe) Used For Bay Mills Indian Community (Also Known As; Plaintiff in Land Claims Case) Used For Bay Mills Indian Community of the Sault Ste. Marie Band of Chippewa Indians, Bay Mills Reservation, Michigan (Also Known As) Used For Chippewa [generic] (Also Known As) Used For Chippewa Tribe of Indians (Also Known As; Plaintiff in Land Claims Case) Used For Ottawa Chippewa (Also Known As) Used For Chippewa (Also Known As) Reservation Name(s): State County Reservation Name MI Chippewa Bay Mills Indian Reservation State(s) and County(ies) Inhabited: State County - Land Area Claims: St MI MI MI MI County Chippewa Alger Alpena Antrim Land Claim Authority Indian Claims Commission decision Indian Claims Commission decision Map ID Land Claims Map ID # 16 Land Claims Map ID # 17 MI Benzie MI Charlevoix MI Cheboygan MI Chippewa MI Clare MI Crawford MI Delta MI Emmet MI Grand Traverse MI Ionia MI Isabella MI Kalkaska MI Kent MI Lake MI Leelanau MI Luce MI Mackinac MI Manistee MI Marquette 3 of 20

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MI Mason MI Mecosta MI Missaukee MI Montcalm MI Montmorency MI Muskegon MI Newaygo MI Oceana MI Osceola MI Oscoda MI Otsego MI Ottawa MI Presque Isle MI Roscommon MI Schoolcraft MI Wexford Identified by Tribe as Being of Particular Interest Not provided 4 of 20

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Full Data Report Grand Traverse Band of Ottawa and Chippewa Indians, Michigan Entity Type(s): Federally Recognized Indian Tribe Authority: BIA Recognized Indian Entities, Federal Register, Nov. 25, 2005 Last Update To Information: 04/29/2015 Contact(s) Authority Cindy Winslow Grand Traverse Band of Ottawa and Chippewa Indians, Michigan 2605 N. West Bayshore Dr. Suttons Bay, MI 49682 231-534-7764 231-534-7568 fax [emailprotected] NAGPRA Contact Letter From Tribal Official Contact(s) Authority Alvin Pedwaydon Grand Traverse Band of Ottawa and Chippewa Indians, Michigan 2605 N. West Bayshore Dr. Suttons Bay, MI 49682 231-534-7750 231-534-7568 FAX [emailprotected] Chairperson BIA Tribal Leaders Directory, Fall/Winter 2015 Related Tribes/Villages: Used For Ottawa [generic] (Also Known As) Used For Chippewa [generic] (Also Known As) Used For Ottawa and Chippewa Indians of Michigan (Plaintiff in Land Claims Case) Used For Ottawa Chippewa (Also Known As) 5 of 20

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Reservation Name(s): State County Reservation Name MI Leelanau Grand Traverse Indian Reservation State(s) and County(ies) Inhabited: State County - Land Area Claims: St MI MI MI MI County Alger Alpena Antrim Benzie Land Claim Authority Indian Claims Commission decision Map ID Land Claims Map ID # 17 MI Charlevoix MI Cheboygan MI Chippewa MI Clare MI Crawford MI Delta MI Emmet MI Grand Traverse MI Ionia MI Isabella MI Kalkaska MI Kent MI Lake MI Leelanau MI Luce MI Mackinac MI Manistee MI Marquette MI Mason MI Mecosta MI Missaukee MI Montcalm MI Montmorency MI Muskegon MI Newaygo MI Oceana MI Osceola MI Oscoda MI Otsego MI Ottawa MI Presque Isle 6 of 20

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MI Roscommon MI Schoolcraft MI Wexford Identified by Tribe as Being of Particular Interest Not provided 7 of 20

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Full Data Report Little Traverse Bay Bands of Odawa Indians, Michigan Entity Type(s): Federally Recognized Indian Tribe Authority: BIA Recognized Indian Entities, Federal Register, Nov. 25, 2005 Congressional Recognition Last Update To Information: 04/29/2015 Contact(s) Authority Regina Gasco-Bentley Little Traverse Bay Bands of Odawa Indians, Michigan 7500 Odawa Circle Harbor Springs, MI 49740 231-242-1418 231-242-1411 fax [emailprotected] Chairperson BIA Tribal Leaders Directory, Fall/Winter 2015 Contact(s) Authority Eric Hemenway Little Traverse Bay Bands of Odawa Indians, Michigan 7500 Odawa Circle Harbor Springs, MI 49740 231-242-1527 231-242-1455 FAX [emailprotected] NAGPRA Contact Letter From Tribal Official Contact(s) Authority Mr. Wes Andrews Little Traverse Bay Bands of Odawa Indians, Michigan Andrews Cultural Resources 524 Bemidji Ct. Ann Arbor, MI 48103 734-585-5033 8 of 20

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[emailprotected] NAGPRA Contact Letter From Tribal Official Related Tribes/Villages: Used For Ottawa [generic] (Also Known As) Used For Ottawa and Chippewa Indians of Michigan (Plaintiff in Land Claims Case) Used For Ottawa Chippewa (Also Known As) Reservation Name(s): State County Reservation Name State(s) and County(ies) Inhabited: State County MI Emmet - Land Area Claims: St MI MI MI MI County Alger Alpena Antrim Benzie Land Claim Authority Indian Claims Commission decision Map ID Land Claims Map ID # 17 MI Charlevoix MI Cheboygan MI Chippewa MI Clare MI Crawford MI Delta MI Emmet MI Grand Traverse MI Ionia MI Isabella MI Kalkaska MI Kent MI Lake MI Leelanau MI Luce MI Mackinac MI Manistee MI Marquette MI Mason MI Mecosta MI Missaukee MI Montcalm MI Montmorency 9 of 20

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MI Montmorency MI Muskegon MI Newaygo MI Oceana MI Osceola MI Oscoda MI Otsego MI Ottawa MI Presque Isle MI Roscommon MI Schoolcraft MI Wexford Identified by Tribe as Being of Particular Interest Not provided 10 of 20

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Full Data Report Red Lake Band of Chippewa Indians, Minnesota Entity Type(s): Federally Recognized Indian Tribe Authority: BIA Recognized Indian Entities, Federal Register, Nov. 25, 2005 Last Update To Information: 04/29/2015 Contact(s) Authority Darrel G. Seki Sr. Red Lake Band of Chippewa Indians, Minnesota P.O. Box 550 Red Lake, MN 56671 218-679-3341 218-679-3378 fax not available Chairperson BIA Tribal Leaders Directory, Fall/Winter 2015 Related Tribes/Villages: Used For Red Lake Band of Chippewa (Also Known As) Used For Pembina Band (Also Known As; Plaintiff in Land Claims Case) Used For Chippewa [generic] (Also Known As) Relation Sault Ste. Marie Tribe of Chippewa Indians, Michigan (Federally Recognized Indian Tribe) Used For Chippewa Tribe of Indians (Also Known As; Plaintiff in Land Claims Case) Relation Bay Mills Indian Community, Michigan (Federally Recognized Indian Tribe) Used For Red Lake Band of Chippewa Indians of the Red Lake Reservation, Minnesota (Also Known As) Used For Red Lake Band (Also Known As; Plaintiff in Land Claims Case) Used For Ottawa Chippewa (Also Known As) Used For Chippewa (Also Known As) Reservation Name(s): State County Reservation Name MN Beltrami Red Lake Indian Reservation MN Clearwater MN Lake Of The Woods 11 of 20

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State(s) and County(ies) Inhabited: State County - Land Area Claims: St MI MI MI MI County Alger Alpena Antrim Benzie Land Claim Authority Indian Claims Commission decision Map ID Land Claims Map ID # 17 MI Charlevoix MI Cheboygan MI Chippewa MI Clare MI Crawford MI Delta MI Emmet MI Grand Traverse MI Ionia MI Isabella MI Kalkaska MI Kent MI Lake MI Leelanau MI Luce MI Mackinac MI Manistee MI Marquette MI Mason MI Mecosta MI Missaukee MI Montcalm MI Montmorency MI Muskegon MI Newaygo MI Oceana MI Osceola MI Oscoda MI Otsego MI Ottawa MI Presque Isle MI Roscommon MI Schoolcraft MI Wexford MN Beltrami Indian Claims Commission decision Land Claims Map ID # 50 MN Clearwater MN Koochiching 12 of 20

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MN Koochiching MN Lake Of The Woods MN Marshall MN Pennington MN Polk MN Red Lake MN Roseau MN Clearwater Indian Claims Commission decision Land Claims Map ID # 51 MN Kittson MN Lake Of The Woods MN Mahnomen MN Marshall MN Norman MN Pennington MN Polk MN Red Lake MN Roseau ND Cavalier ND Grand Forks ND Nelson ND Pembina ND Steele ND Traill ND Walsh Identified by Tribe as Being of Particular Interest Not provided 13 of 20

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Full Data Report Sault Ste. Marie Tribe of Chippewa Indians, Michigan Entity Type(s): Federally Recognized Indian Tribe Authority: BIA Recognized Indian Entities, Federal Register, Nov. 25, 2005 Last Update To Information: 04/29/2015 Contact(s) Authority Mr. Aaron Payment Sault Ste. Marie Tribe of Chippewa Indians, Michigan 523 Ashmun Street Sault Ste. Marie, MI 49783 906-635-6050 906-635-4969 FAX [emailprotected] Chairperson BIA Tribal Leaders Directory, Fall/Winter 2015 Contact(s) Authority Colleen Medicine Sault Ste. Marie Tribe of Chippewa Indians, Michigan 523 Ashmun Street Sault Ste. Marie, MI 49783 906-635-6050 x2614 906-635-8644 FAX [emailprotected] NAGPRA Contact Letter From Tribal Official Related Tribes/Villages: Relation Red Lake Band of Chippewa Indians, Minnesota (Federally Recognized Indian Tribe) Used For Chippewa [generic] (Also Known As) Used For Ottawa and Chippewa Indians of Michigan (Plaintiff in Land Claims Case) Used For Chippewa Tribe of Indians (Also Known As; Plaintiff in Land Claims Case) Used For Ottawa Chippewa (Also Known As) Used For Chippewa (Also Known As) 14 of 20

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Reservation Name(s): State County Reservation Name MI Chippewa Sault Ste Marie Indian Reservation State(s) and County(ies) Inhabited: State County - Land Area Claims: St MI MI MI MI County Alger Alpena Antrim Benzie Land Claim Authority Indian Claims Commission decision Map ID Land Claims Map ID # 17 MI Charlevoix MI Cheboygan MI Chippewa MI Clare MI Crawford MI Delta MI Emmet MI Grand Traverse MI Ionia MI Isabella MI Kalkaska MI Kent MI Lake MI Leelanau MI Luce MI Mackinac MI Manistee MI Marquette MI Mason MI Mecosta MI Missaukee MI Montcalm MI Montmorency MI Muskegon MI Newaygo MI Oceana MI Osceola MI Oscoda MI Otsego MI Ottawa MI Presque Isle 15 of 20

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MI Roscommon MI Schoolcraft MI Wexford Identified by Tribe as Being of Particular Interest Not provided 16 of 20

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Full Data Report Ottawa and Chippewa Indians of Michigan Entity Type(s): Plaintiff in Land Claims Case Authority: Indian Claims Commission Last Update To Information: 05/27/1997 Related Tribes/Villages: Use Grand Traverse Band of Ottawa and Chippewa Indians, Michigan (Federally Recognized Indian Tribe) Use Little Traverse Bay Bands of Odawa Indians, Michigan (Federally Recognized Indian Tribe) Use Sault Ste. Marie Tribe of Chippewa Indians, Michigan (Federally Recognized Indian Tribe) Reservation Name(s): State County Reservation Name State(s) and County(ies) Inhabited: State County - Land Area Claims: St MI MI MI MI County Alger Alpena Antrim Benzie Land Claim Authority Indian Claims Commission decision Map ID Land Claims Map ID # 17 MI Charlevoix MI Cheboygan MI Chippewa MI Clare MI Crawford MI Delta MI Emmet MI Grand Traverse MI Ionia MI Isabella 17 of 20

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MI Kalkaska MI Kent MI Lake MI Leelanau MI Luce MI Mackinac MI Manistee MI Marquette MI Mason MI Mecosta MI Missaukee MI Montcalm MI Montmorency MI Muskegon MI Newaygo MI Oceana MI Osceola MI Oscoda MI Otsego MI Ottawa MI Presque Isle MI Roscommon MI Schoolcraft MI Wexford Identified by Tribe as Being of Particular Interest Not provided 18 of 20

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Full Data Report Red Lake Band Entity Type(s): Also Known As Plaintiff in Land Claims Case Authority: Indian Claims Commission Last Update To Information: 05/14/1997 Related Tribes/Villages: Use Red Lake Band of Chippewa Indians, Minnesota (Federally Recognized Indian Tribe) Reservation Name(s): State County Reservation Name State(s) and County(ies) Inhabited: State County - Land Area Claims: St MI MI MI MI County Alger Alpena Antrim Benzie Land Claim Authority Indian Claims Commission decision Map ID Land Claims Map ID # 17 MI Charlevoix MI Cheboygan MI Chippewa MI Clare MI Crawford MI Delta MI Emmet MI Grand Traverse MI Ionia MI Isabella MI Kalkaska MI Kent 19 of 20

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MI Kent MI Lake MI Leelanau MI Luce MI Mackinac MI Manistee MI Marquette MI Mason MI Mecosta MI Missaukee MI Montcalm MI Montmorency MI Muskegon MI Newaygo MI Oceana MI Osceola MI Oscoda MI Otsego MI Ottawa MI Presque Isle MI Roscommon MI Schoolcraft MI Wexford MN Clearwater Indian Claims Commission decision Land Claims Map ID # 51 MN Kittson MN Lake Of The Woods MN Mahnomen MN Marshall MN Norman MN Pennington MN Polk MN Red Lake MN Roseau ND Cavalier ND Grand Forks ND Nelson ND Pembina ND Steele ND Traill ND Walsh Identified by Tribe as Being of Particular Interest Not provided 20 of 20

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United States Department of the Interior BUREAU OF INDIAN AFFAIRS Midwest Regional Office Nonnan Pointe II, Suite 500 5600 West American Boulevard Bloomington, Minnesota 55437 IN REPLY REFER TO Environmental, Cultural Resource Management and Safety JAN 12 2017 Kade Ferris, Tribal Historic Preservation Officer Red Lake Band of Chippewa P.O. Box 274 Red Lake, MN 56671 Re: Section 106 Consultation - Little River Band of Ottawa Indians Fee-to-Trust Application for the Purpose of Gaming (25CFR151): Proposed Project in Muskegon County, Michigan Dear Mr. Ferris: We are writing in regard to Section 106, National Historic Preservation Act (NHPA) consultation for the Little River Band of Ottawa Indians Fee-to-Trust application for the purpose of gaming (25CFR151). The Band has requested that the Bureau of Indian Affairs Midwest Region (BIA- MR) transfer approximately 60 acres of the Tribe's fee land located in Muskegon County, Michigan, into federal trust status. The 60 acre parcel as well as an additional approximate 26.5 acres of adjacent land owned by the Tribe (a total of 86.5 acres) is proposed for development. The 86.5-acre project site is referred to herein as the Subject Property. The Proposed Project includes a casino, hotel, conference center, parking, and other supporting facilities. The BIA-MR has determined that the Proposed Project is an undertaking as defined by 36 CFR 800.16(y) because the Little River Band has submitted a Fee to Trust Application for the Purpose of Gaming (25CFR151). The Area of Potential Effect (APE) consists of the Subject Property and several road and water infrastructure improvements that will be required to mitigate potential impacts from operation of the Proposed Project. It is anticipated that all construction activities and staging would take place within the APE and that no excavations would be more than eight (8) feet deep. A Phase I archaeological survey of the parcels including a literature search for the APE was conducted by Analytical Environmental Services (AES) in 2016 (Enclosure 1). No historic properties were identified. A finding of no historic properties affected was recommended by AES. The BIA-MR has determined that the undertaking will have no effect to historic properties (36 CFR 800.4 (d) (1)). No further archaeological work is recommended. The BIA-MR consulted with the Little River Band Ogema and the Michigan State Historic Preservation Office (SHPO) regarding this undertaking, both the Little River Band and Michigan SHPO concurred with the BIA-MR's determination (Enclosures 2 to 5). If you have any questions or wish to

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swnmit any information related to this project for consideration under Section 106 NHPA, please contact Timothy Guyah, BIA Regional Archaeologist, at 612-725-4512. Sincerely, Acting Regional Director Enclosures (5): Compact Disc (CD) containing the Little River Band of Ottawa Indians Trust Acquisition and Casino Project [Muskegon Site] -Cultural Resources Report dated June 2016 Section 106 Consultation letter BIA-MR to the Little River Band Ogema Regarding the Little River Band of Ottawa Indians Fee-to-Trust Application for the Purpose of Gaming (25CFR151): Proposed Project in Muskegon County, Michigan - dated August 3, 2016. Response from the Little River Band Ogema to the BIA-MR Regional Director Regarding the Little River Band of Ottawa Indians Fee-to-Trust Application for the Purpose of Gaming (25CFR151): Proposed Project in Muskegon County, Michigan- dated August 15, 2016. Section 106 Consultation letter BIA-MR to Michigan State Historic Preservation Office Regarding the Little River Band of Ottawa Indians Fee-to-Trust Application for the Purpose of Gaming (25CFR151): Proposed Project in Muskegon County, Michigan - dated August 29, 2016. Response from the Michigan State Historic Preservation Office to the BIA-MR Regional Director Regarding the Little River Band of Ottawa Indians Fee-to-Trust Application for the Purpose of Gaming (25CFR151): Proposed Project in Muskegon County, Michigan - dated November 4, 2016. · cc: Ogema Larry Romanelli 2

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United States Department of the Interior BUREAU OF INDIAN AFFAIRS Midwest Regional Office Noonan Pointe II, Suite 500 5600 West American Boulevard Bloomington, Minnesota 55437 IN REPLY REFER TO: Environmental, Cultural Resource l\'lanagement end Safety JAN 12 2017 Darrel Seki, Sr., Chairperson Red Lake Band of Chippewa Indians, Minnesota P.O. Box 550 Red Lake, :MN 56671 Re: Section 106 Consultation - Little River Band of Ottawa Indians Fee-to-Trust Application for the Purpose of Gaming (25CFR151): Proposed Project in Muskegon County, Michigan Dear Chairperson Seki, Sr.: We are writing in regard to Section 106, National Historic Preservation Act (NHPA) consultation for the Little River Band of Ottawa Indians Fee-to-Trust application for the purpose of gaming (25CFR151 ). The Band has requested that the Bureau of Indian Affairs Midwest Region (BlA- MR) transfer approximately 60 acres of the Tribe's fee land located in Muskegon County, Michigan, into federal trust status. The 60 acre parcel as well as an additional approximate 26.5 acres of adjacent land owned by the Tribe (a total of 86.5 acres) is proposed for development. The 86.5-acre project site is referred to herein as the Subject Property. The Proposed Project includes a casino, hotel, conference center, parking, and other supporting facilities. The BIA-MR has determined that the Proposed Project is an undertaking as defined by 36 CFR 800.16(y) because the Little River Band has submitted a Fee to Trust Application for the Purpose of Gaming (25CFR151). The Area of Potential Effect (APE) consists of the Subject Property and several road and water infrastructure improvements that will be required to mitigate potential impacts from operation of the Proposed Project. It is anticipated that all construction activities and staging would take place within the APE and that no excavations would be more than eight (8) feet deep. A Phase I archaeological survey of the parcels including a literature search for the APE was conducted by Analytical Environmental Services (AES) in 2016 (Enclosure 1). No historic properties were identified. A finding of no historic properties affected was recommended by AES. The BIA-MR has determined that the undertaking will have no effect to historic properties (36 CFR 800.4 (d) (1)). No further archaeological work is recommended. The BIA-MR consulted with the Little River Band Ogema and the Michigan State Historic Preservation Office (SHPO) regarding this undertaking, both the Little River Band and Michigan SHPO concurred with the BIA-MR's determination (Enclosures 2 to 5). If you have any questions or wish to

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summit any infonnation related to this project for consideration under Section 106 NHPA, please contact Timothy Guyah, BIA Regional Archaeologist, at 612-725-4512. Sincerely, ~ Acting Regional Director Enclosures (5): Compact Disc (CD) containing the Little River Band of Ottawa Indians Trust Acquisition and Casino Project [Muskegon Site]-Cultural Resources Report dated June 2016 Section 106 Consultation letter BIA-MR to the Little River Band Ogema Regarding the Little River Band of Ottawa Indians Fee-to-Trust Application for the Purpose of Gaming (25CFR151): Proposed Project in Muskegon County, Michigan - dated August 3, 2016. Response from the Little River Band Ogema to the BIA-MR Regional Director Regarding the Little River Band of Ottawa Indians Fee-to-Trust Application for the Purpose of Gaming (25CFR151): Proposed Project in Muskegon County, Michigan - dated August 15, 2016. Section 106 Consultation letter BIA-MR to Michigan State Historic Preservation Office Regarding the Little River Band of Ottawa Indians Fee-to-Trust Application for the Purpose of Gaming (25CFR151): Proposed Project in Muskegon County, Michigan - dated August 29, 2016. Response from the Michigan State Historic Preservation Office to the BIA-MR Regional Director Regarding the Little River Band of Ottawa Indians Fee-to-Trust Application for the Purpose of Gaming (25CFR151): Proposed Project in Muskegon County, Michigan - dated November 4, 2016. cc: Ogema Larry Romanelli 2

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United States Department of the Interior BUREAU OF INDIAN AFFAIRS Midwest Regional Office Nonnan Pointe II, Suite 500 5600 West American Boulevard Bloomington, Minnesota 55437 IN REPLY REFER TO: JAN 12 2017 Eavironmeallll, Cultunl Resource Management and Safety Regina Gasco-Bentley, Chairperson Little Traverse Bay Bands of Odawa Indians, Michigan 7500 Odawa Circle Harbor Springs, MI 49740 Re: Section 106 Consultation - Little River Band of Ottawa Indians Fee-to-Trust Application for the Purpose of Gaming (25CFRI 51 ): Proposed Project in Muskegon County, Michigan Dear Chairperson Gasco-Bentley: We are writing in regard to Section 106, National Historic Preservation Act (NHPA) consultation for the Little River Band of Ottawa Indians Fee-to-Trust application for the purpose of gaming (25CFR151). The Band has requested that the Bureau of Indian Affairs Midwest Region (BIA- MR) transfer approximately 60 acres of the Tribe's fee land located in Muskegon County, Michigan, into federal trust status. The 60 acre parcel as well as an additional approximate 26.5 acres of adjacent land owned by the Tribe (a total of 86.5 acres) is proposed for development. The 86.5-acre project site is referred to herein as the Subject Property. The Proposed Project includes a casino, hotel, conference center, parking, and other supporting facilities. The BIA-MR has determined that the Proposed Project is an undertaking as defined by 36 CFR 800.16(y) because the Little River Band has submitted a Fee to Trust Application for the Purpose of Gaming (25CFR151). The Area of Potential Effect (APE) consists of the Subject Property and several road and water infrastructure improvements that will be required to mitigate potential impacts from operation of the Proposed Project. It is anticipated that all construction activities and staging would take place within the APE and that no excavations would be more than eight (8) feet deep. A Phase I archaeological survey of the parcels including a literature search for the APE was conducted by Analytical Environmental Services (AES) in 2016 (Enclosure 1). No historic properties were identified. A finding of no historic properties affected was recommended by AES. The BIA-MR has determined that the undertaking will have no effect to historic properties (36 CFR 800.4 (d) (1)). No further archaeological work is recommended. The BIA-MR consulted with the Little River Band Ogema and the Michigan State Historic Preservation Office (SHPO) regarding this undertaking, both the Little River Band and Michigan SHPO concurred with the BIA-MR's determination (Enclosures 2 to 5). If you have any questions or wish to

32

summit any information related to this project for consideration under Section 106 NHPA, please contact Timothy Guyah, BIA Regional Archaeologist, at 612_.725-4512. Sincerely, Acting Regional Director Enclosures (5): Compact Disc (CD) containing the Little River Band of Ottawa Indians Trust Acquisition and Casino Project [Muskegon Site] - Cultural Resources Report dated June 2016 Section 106 Consultation letter BIA-MR to the Little River Band Ogema Regarding the Little River Band of Ottawa Indians Fee-to-Trust Application for the Purpose of Gaming (25CFR151): Proposed Project in Muskegon County, Michigan - dated August 3, 2016. Response from the Little River Band Ogema to the BIA-MR Regional Director Regarding the Little River Band of Ottawa Indians Fee-to-Trust Application for the Purpose of Gaming (25CFR151): Proposed Project in Muskegon County, Michigan- dated August 15, 2016. Section 106 Consultation letter BIA-MR to Michigan State Historic Preservation Office Regarding the Little River Band of Ottawa Indians Fee-to-Trust Application for the Purpose of Gaming (25CFR151): Proposed Project in Muskegon County, Michigan - dated August 29, 2016. Response from the Michigan State Historic Preservation Office to the BIA-MR Regional Director Regarding the Little River Band of Ottawa Indians Fee-to-Trust Application for the Purpose of Gaming (25CFR151): Proposed Project in Muskegon County, Michigan - dated November 4, 2016. cc: Ogema Larry Romanelli 2

33

United States Department of the Interior BUREAU OF INDIAN AFFAIRS Midwest Regional Office Nonnan Pointe Il, Suite 500 5600 West American Boulevard Bloomington, Minnesota 55437 IN REPLY REFER TO· JAN 12 2017 Environmental, Cultural Resource l\1■oagement and SaCety Alvin Pedwaydon, Chairperson Grand Traverse Band of Ottawa and Chippewa Indians, Michigan 2605 N. West Bayshore Dr. Suttons Bay, MI 49682 Re: Section 106 Consultation - Little River Band of Ottawa Indians Fee-to-Trust Application for the Purpose of Gaming (25CFR151): Proposed Project in Muskegon County, Michigan Dear Chairperson Pedwaydon: We are writing in regard to Section 106, National Historic Preservation Act (NI-IPA) consultation for the Little River Band of Ottawa Indians Fee-to-Trust application for the purpose of gaming (25CFR151). The Band has requested that the Bureau of Indian Affairs Midwest Region (BIA- MR) transfer approximately 60 acres of the Tribe's fee land located in Muskegon County, Michigan, into federal trust status. The 60 acre parcel as well as an additional approximate 26.5 acres of adjacent land owned by the Tribe (a total of 86.5 acres) is proposed for development. The 86.5-acre project site is referred to herein as the Subject Property. The Proposed Project includes a casino, hotel, conference center, parking, and other supporting facilities. · The BIA-MR has detennined that the Proposed Project is an undertaking as defined by 36 CFR 800.16(y) because the Little River Band has submitted a Fee to Trust Application for the Purpose of Gaming (25CFR151). The Area of Potential Effect (APE) consists of the Subject Property and several road and water infrastructure improvements that will be required to mitigate potential impacts from operation of the Proposed Project. It is anticipated that all construction activities and staging would take place within the APE and that no excavations would be more than eight (8) feet deep. A Phase I archaeological survey of the parcels including a literature search for the APE was conducted by Analytical Environmental Services (AES) in 2016 (Enclosure 1). No historic properties were identified. A finding of no historic properties affected was recommended by AES. The BIA-MR has detennined that the undertaking will have no effect to historic properties (36 CFR 800.4 (d) (1)). No further archaeological work is recommended. The BIA-MR consulted with the Little River Band Ogema and the Michigan State Historic Preservation Office (SHPO) regarding this undertaking, both the Little River Band and Michigan SHPO concurred with the BIA-MR' s determination (Enclosures 2 to 5). If you have any questions or wish to

34

summit any information related to this project for consideration under Section 106 NHPA, please contact Timothy Guyah, BIA Regional Archaeologist, at 612-725-4512. Acting Regional Director Enclosures (5): Compact Disc (CD) containing the Little River Band of Ottawa Indians Trust Acquisition and Casino Project [Muskegon Site] - Cultural Resources Report dated June 2016 Section 106 Consultation letter BIA-:MR to the Little River Band Ogema Regarding the Little River Band of Ottawa Indians Fee-to-Trust Application for the Purpose of Gaming (25CFRI 51 ): Proposed Project in Muskegon County, Michigan -dated August 3, 2016. Response from the Little River Band Ogema to the BIA-:MR Regional Director Regarding the Little River Band of Ottawa Indians Fee-to-Trust Application for the Purpose of Gaming (25CFR151): Proposed Project in Muskegon County, Michigan- dated August 15, 2016. Section 106 Consultation letter BIA-MR to Michigan State Historic Preservation Office Regarding the Little River Band of Ottawa Indians Fee-to-Trust Application for the Purpose of Gaming (25CFR151): Proposed Project in Muskegon County, Michigan- dated August 29, , 2016. Response from the Michigan State Historic Preservation Office to the BIA-MR Regional Director Regarding the Little River Band of Ottawa Indians Fee-to-Trust Application for the Purpose of Gaming (25CFRI51): Proposed Project in Muskegon County, Michigan - dated November 4, 2016. cc: Ogema Larry Romanelli 2

35

United States Department of the Interior BUREAU OF INDIAN AFFAIRS Midwest Regional Office Nonnan Pointe Il, Suite 500 5600 West American Boulevard Bloomington, Minnesota 55437 IN REPLY JIEFEll TO; JAN 12 2017 Environmental, Cultunl Resource Management and Safety Paula Carrie~ Tribal Historic Preservation Officer Bay Mills Indian Community, MI · 12140 W. Lakeshore Drive Brimley, MI 49715 Re: Section 106 Consultation - Little River Band of Ottawa Indians Fee-to-Trust Application for the Purpose of Gaming (25CFR151): Proposed Project in Muskegon County, Michigan Dear Ms. Carrick: We are writing in regard to Section 106, National Historic Preservation Act (NHPA) consultation for the Little River Band of Ottawa Indians Fee-to-Trust application for the purpose of gaming (25CFR151). The Band has requested that the Bureau of Indian Affairs Midwest Region (BIA- MR) transfer approximately 60 acres of the Tribe's fee land located in Muskegon County, Michigan, into federal trust status. The 60 acre parcel as well as an additional approximate 26.5 acres of adjacent land owned by the Tribe (a total of 86.5 acres) is proposed for development. The 86.5-acre project site is referred to herein as the Subject Property. The Proposed Project includes a casino, hotel, conference center, parking, and other supporting facilities. The BIA-MR has detennined that the Proposed Project is an undertaking as defined by 36 CFR 800.16(y) because the Little River Band has submitted a Fee to Trust Application for the Purpose of Gaming (25CFR151). The Area of Potential Effect (APE) consists of the Subject Property and several road and water infrastructure improvements that will be required to mitigate potential impacts from operation of the Proposed Project. It is anticipated that all construction activities and staging would take place within the APE and that no excavations would be more than eight (8) feet deep. A Phase I archaeological survey of the parcels including a literature search for the APE was conducted by Analytical Environmental Services (AES) in 2016 (Enclosure 1). No historic properties were identified. A finding of no historic properties affected was recommended by AES. The BIA-MR has determined that the undertaking will have no effect to historic properties (36 CFR 800.4 (d) (1)). No further archaeological work is recommended. The BIA-MR consulted with the Little River Band Ogema and the Michigan State Historic Preservation Office (SHPO) regarding this undertaking, both the Little River Band and Michigan SHPO concurred with the BIA-MR's determination (Enclosures 2 to 5). If you have any questions or wish to

36

summit any information related to this project for consideration under Section 106 NHPA, please contact Timothy Guyaht BIA Regional Archaeologistt at 612-725-4512. Sincerelyt Acting . al n·irector Region Enclosures (5): Compact Disc (CD) containing the Little River Band of Ottawa Indians Trust Acquisition and Casino Project [Muskegon Site] - Cultural Resources Report dated June 2016 Section 106 Consultation letter BIA-MR to the Little River Band Ogema Regarding the Little River Band of Ottawa Indians Fee-to-Trust Application for the Purpose of Gaming (25CFR151 ): Proposed Project in Muskegon County, Michigan - dated August 3, 2016. Response from the Little River Band Ogema to the BIA-MR Regional Director Regarding the Little River Band of Ottawa Indians Fee-to-Trust Application for the Purpose of Gaming (25CFR151): Proposed Project in Muskegon Countyt Michigan -dated August 15t 2016. Section 106 Consultation letter BIA-MR to Michigan State Historic Preservation Office Regarding the Little River Band of Ottawa Indians Fee-to-Trust Application for the Purpose of Gaming (25CFR151): Proposed Project in Muskegon Countyt Michigan - dated August 29, 2016. Response from the Michigan State Historic Preservation Office to the BIA-MR Regional Director Regarding the Little River Band of Ottawa Indians Fee-to-Trust Application for the Purpose of Gaming (25CFR151): Proposed Project in Muskegon County, Michigan - dated November 4, 2016. cc: Ogema Larry Romanelli 2

37

United States Department of the Interior BUREAU OF INDIAN AFFAIRS Midwest Regional Office Nonnan Pointe n, Suite 500 5600 West American Boulevard Bloomington, Minnesota 55437 IN REPLY IIEfEJl TO Environmental, Cultural Resource Management and Safety JAN 12 2017 Levi Carrick, Chairperson Bay Mills Indian Community, Michigan 12140 W. Lakeshore Drive Brimley, MI 49715 Re: Section 106 Consultation - Little River Band of Ottawa Indians Fee-to-Trust Application for the Purpose of Gaming (25CFR151): Proposed Project in Muskegon County, Michigan Dear Chairperson Carrick: We are writing in regard to Section 106, National Historic Preservation Act {NHPA) consultation for the Little River Band of Ottawa Indians Fee-to-Trust application for the purpose of gaming (25CFR151). The Band has requested that the Bureau of Indian Affairs Midwest Region (BIA- MR) transfer approximately 60 acres of the Tribe's fee land located in Muskegon County, Michigan, into federal trust status. The 60 acre parcel as well as an additional approximate 26.5 acres of adjacent land owned by the Tribe (a total of 86.5 acres) is proposed for development. The 86.5-acre project site is referred to herein as the Subject Property. The Proposed Project includes a casino, hotel, conference center, parking, and other supporting facilities. The BIA-MR has detennined that the Proposed Project is an undertaking as defined by 36 CFR 800.16(y) because the Little River Band has submitted a Fee to Trust Application for the Purpose of Gaming (25CFR151 ). The Area of Potential Effect (APE) consists of the Subject Property and several road and water infrastructure improvements that will be required to mitigate potential impacts from operation of the Proposed Project. It is anticipated that all construction activities and staging would take place within the APE and that no excavations would be more than eight (8) feet deep. A Phase I archaeological survey of the parcels including a literature search for the APE was conducted by Analytical Environmental Services (AES) in 2016 (Enclosure I). No historic properties were identified. A finding of no historic properties affected was recommended by AES. The BIA-MR has determined that the undertaking will have no effect to historic properties (36 CFR 800.4 (d) (1)). No further archaeological work is recommended. The BIA-MR consulted with the Little River Band Ogema and the Michigan State Historic Preservation Office (SHPO) regarding this undertaking, both the Little River Band and Michigari SHPO concurred with the BIA-MR's determination (Enclosures 2 to 5). If you have any questions or wish to

38

summit any infonnation related to this project for consideration under Section 106 NHPA, please contact Timothy Guyah, BIA Regional Archaeologist, at 612-725-4512. sff Acting Regional Director Enclosures (5): Compact Disc (CD) containing the Little River Band of Ottawa Indians Trust Acquisition and Casino Project [Muskegon Site]-Cultural Resources Report dated June 2016 Section 106 Consultation letter BIA-MR to the Little River Band Ogema Regarding the Little River Band of Ottawa Indians Fee-to-Trust Application for the Purpose of Gaming (25CFR151): Proposed Project in Muskegon County, Michigan -dated August 3, 2016. Response from the Little River Band Ogema to the BIA-MR Regional Director Regarding the Little River Band of Ottawa Indians Fee-to-Trust Application for the Purpose of Gaming (25CFR151): Proposed Project in Muskegon County, Michigan- dated August 15, 2016. Section 106 Consultation letter BIA-MR to Michigan State Historic Preservation Office Regarding the Little River Band of Ottawa Indians Fee-to-Trust Application for the Purpose of Gaming (25CFR151): Proposed Project in Muskegon County, Michigan - dated August 29, 2016. Response from the Michigan State Historic Preservation Office to the BIA-MR Regional Director Regarding the Little River Band of Ottawa Indians Fee-to-Trust Application for the Purpose of Gaming (25CFR151): Proposed Project in Muskegon County, Michigan - dated November 4, 2016. cc: Ogema Larry Romanelli 2

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United States Department of the Interior BUREAU OF INDIAN AFFAIRS Midwest Regional Office Norman Pointe II, Suite 500 5600 West American Boulevard Bloomington, Minnesota 55437 IN REPLY REFEll TO JAN 12 2017 Environmental, Cultunl Resource Management and Safety Beth Moody, Tribal Historic Preservation Officer Nottawaseppi Huron Band of the Potawatomi 1485 Mno-Bmadzewan Way Fulton, MI 49052 Re: Section I 06 Consultation - Little River Band of Ottawa Indians Fee-to-Trust Application for the Purpose of Gaming (25CFR151): Proposed Project in Muskegon County, Michigan Dear Ms. Moody: We are writing in regard to Section 106, National Historic Preservation Act (NHPA) consultation for the Little River Band of Ottawa Indians Fee-to-Trust application for the purpose of gaming (25CFR151 ). The Band has requested that the Bureau of Indian Affairs Midwest Region (BIA- MR) transfer approximately 60 acres of the Tribe's fee land located in Muskegon County, Michigan, into federal trust status. The 60 acre parcel as well as an additional approximate 26.5 acres of adjacent land owned by the Tribe (a total of 86.5 acres) is proposed for development. The 86.5-acre project site is referred to herein as the Subject Property. The Proposed Project includes a casino, hotel, conference center, parking, and other supporting facilities. The BIA-MR has determined that the Proposed Project is an undertaking as defined by 36 CFR 800.16(y) because the Little River Band has submitted a Fee to Trust Application for the Purpose of Gaming (25CFR151). The Area of Potential Effect (APE) consists of the Subject Property and several road and water infrastructure improvements that will be required to mitigate potential impacts from operation of the Proposed Project. It is anticipated that all construction activities and staging would take place within the APE and that no excavations would be more than eight (8) feet deep. A Phase I archaeological survey of the parcels including a literature search for the APE was conducted by Analytical Environmental Services (AES) in 2016 (Enclosure I). No historic properties were identified. A finding of no historic properties affected was recommended by AES. The BIA-MR has determined that the undertaking will have no effect to historic properties (36 CFR 800.4 (d) (1)). No further archaeological work is recommended. The BIA-MR consulted with the Little River Band Ogema and the Michigan State Historic Preservation Office (SHPO) regarding this undertaking, both the Little River Band and Michigan SHPO concurred with the BIA-MR's determination (Enclosures 2 to 5). If you have any questions or wish to

40

summit any information related to this project for consideration under Section 106 NHPA, please contact Timothy Guyah, BIA Regional Archaeologist, at 612-725-4512. Acting Regional Director Enclosures (5): Compact Disc (CD) containing the Little River Band of Ottawa Indians Trust Acquisition and Casino Project [Muskegon Site]-Cultural Resources Report dated June 2016 Section 106 Consultation letter BIA-MR to the Little River Band Ogema Regarding the Little River Band of Ottawa Indians Fee-to-Trust Application for the Purpose of Gaming (25CFR151 ): Proposed Project in Muskegon County, Michigan - dated August 3, 2016. Response from the Little River Band Ogema to the BIA-MR Regional Director Regarding the Little River Band of Ottawa Indians Fee-to-Trust Application for the Purpose of Gaming (25CFR151): Proposed Project in Muskegon County, Michigan - dated August 15, 2016. Section 106 Consultation letter BIA-MR to Michigan State Historic Preservation Office Regarding the Little River Band of Ottawa Indians Fee-to-Trust Application for the Purpose of Gaming (25CFR151): Proposed Project in Muskegon County, Michigan - dated August 29, 2016. Response from the Michigan State Historic Preservation Office to the BIA-MR Regional Director Regarding the Little River Band of Ottawa Indians Fee-to-Trust Application for the Purpose of Gaming (25CFR151 ): Proposed Project in Muskegon County, Michigan - dated November 4, 2016. cc: Ogema Larry Romanelli 2

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United States Department of the Interior BUREAU OF INDIAN AFFAIRS Midwest Regional Office Nonnan Pointe II, Suite 500 5600 West American Boulevard Bloomington, Minnesota 55437 INREPLYREFERTO; Environmental, Cultural Resource Management and Safety JAN 12 2017 Jamie Stuck, Chairperson Nottawaseppi Huron Band of the Potawatomi Council 1485 Mno-Bmedzewen Way Fulton, MI 49052 Re: Section 106 Consultation - Little River Band of Ottawa Indians Fee-to-Trust Application for the Purpose of Gaming (25CFR151): Proposed Project in Muskegon County, Michigan Dear Chairperson Stuck: We are writing in regard to Section 106, National Historic Preservation Act (NHPA) consultation for the Little River Band of Ottawa Indians Fee-to-Trust application for the purpose of gaming (25CFR151). The Band has requested that the Bureau of Indian Affairs Midwest Region (BIA- MR) transfer approximately 60 acres of the Tribe's fee land located in Muskegon County, Michigan, into federal trust status. The 60 acre parcel as well as an additional approximate 26.5 acres of adjacent land owned by the Tribe (a total of 86.5 acres) is proposed for development. The 86.5-acre project site is referred to herein as the Subject Property. The Proposed Project includes a casino, hotel, conference center, parking, and other supporting facilities. The BIA-MR bas determined that the Proposed Project is an undertaking as defined by 36 CFR 800. l 6(y) because the Little River Band has submitted a Fee to Trust Application for the Purpose of Gaming (25CFR151). The Area of Potential Effect (APE) consists of the Subject Property and several road and water infrastructure improvements that will be required to mitigate potential impacts from operation of the Proposed Project. It is anticipated that all construction activities and staging would take place within the APE and that no excavations would be more than eight (8) feet deep. A Phase I archaeological survey of the parcels including a literature search for the APE was conducted by Analytical Environmental Services (AES) in 2016 (Enclosure 1). No historic properties were identified. A finding of no historic properties affected was recommended by AES. The BIA-MR has determined that the undertaking will have no effect to historic properties (36 CFR 800.4 (d) (1)). No further archaeological work is recommended. The BIA-MR consulted with the Little River Band Ogema and the Michigan State Historic Preservation Office (SHPO) regarding this undertaking, both the Little River Band and Michigan SHPO concurred with the BIA-MR's determination (Enclosures 2 to 5). If you have any questions or wish to

42

summit any infonnation related to this project for consideration under Section 106 NHPA, please contact Timothy Guyah, BIA Regional Archaeologist, at 612-725-4512. Sincerely, Acting Regional Director Enclosures (5): Compact Disc (CD) containing the Little River Band of Ottawa Indians Trust Acquisition and Casino Project [Muskegon Site] - Cultural Resources Report dated June 2016 Section I 06 Consultation letter BIA-MR to the Little River Band Ogema Regarding the Little River Band of Ottawa Indians Fee-to-Trust Application for the Purpose of Gaming (25CFRI 51 ): Proposed Project in Muskegon County, Michigan - dated August 3, 2016. Response from the Little River Band Ogema to the BIA-MR Regional Director Regarding the Little River Band of Ottawa Indians Fee-to-Trust Application for the Purpose of Gaming (25CFR151): Proposed Project in Muskegon County, Michigan - dated August 15, 2016. Section I 06 Consultation letter BIA-MR to Michigan State Historic Preservation Office Regarding the Little River Band of Ottawa Indians Fee-to-Trust Application for the Purpose of Gaming (25CFR151): Proposed Project in Muskegon County, Michigan - dated August 29, 2016. Response from the Michigan State Historic Preservation Office to the BIA-MR Regional Director Regarding the Little River Band of Ottawa Indians Fee-to-Trust Application for the Purpose of Gaming (25CFR151 ): Proposed Project in Muskegon County, Michigan - dated November 4, 2016. cc: Ogema Larry Romanelli 2

43

United States Department of the Interior BUREAU OF INDIAN AFFAIRS Midwest Regional Office Nonnan Pointe II, Suite 500 5600 West American Boulevard Bloomington, MinneS

44

summit any information related to this project for consideration under Section 106 NHPA, please contact Timothy Guyah, BIA Regional Archaeologist, at 612-725-4512. Acting Regional Director Enclosures (5): Compact Disc (CD) containing the Little River Band of Ottawa Indians Trust Acquisition and Casino Project [Muskegon Site]-Cultural Resources Report dated June 2016 Section 106 Consultation letter BIA-MR to the Little River Band Ogema Regarding the Little River Band of Ottawa Indians Fee-to-Trust Application for the Purpose of Gaming (25CFR151 ): Proposed Project in Muskegon County, Michigan - dated August 3, 2016. Response from the Little River Band Ogema to the BIA-MR Regional Director Regarding the Little River Band of Ottawa Indians Fee-to-Trust Application for the Purpose of Gaming (25CFR151): Proposed Project in Muskegon County, Michigan - dated August 15, 2016. Section 106 Consultation letter BIA-MR to Michigan State Historic Preservation Office Regarding the Little River Band of Ottawa Indians Fee-to-Trust Application for the Purpose of Gaming (25CFRI51): Proposed Project in Muskegon County, Michigan - dated August 29, 2016. Response from the Michigan State Historic Preservation Office to the BIA-MR Regional Director Regarding the Little River Band of Ottawa Indians Fee-to-Trust Application for the Purpose of Gaming (25CFR151): Proposed Project in Muskegon County, Michigan - dated November 4, 2016. cc: Ogema Larry Romanelli 2

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United States Department of the Interior BUREAU OF INDIAN AFFAIRS Midwest Regional Office Nonnan Pointe D, Suite 500 5600 West American Boulevard Bloomington, Minnesota 55437 JAN 1 2 2017 IN REPLY REfEll TO: Environmental, Cultural Resource Management and Safety Aaron Payment, Chairperson Sault Ste. Marie Tribe of Chippewa Indians, MI 523 Ashmun Street Sault Ste Marie, MI 49783 Re: Section 106 Consultation - Little River Band of Ottawa Indians Fee-to-Trust Application for the Purpose of Gaming (25CFR151 ): Proposed Project in Muskegon County, Michigan Dear Chairperson Payment: We are writing in regard to Section 106, National Historic Preservation Act (NHPA) consultation for the Little River Band of Ottawa Indians Fee-to-Trust application for the purpose of gaming (25CFR151). The Band has requested that the Bureau of Indian Affairs Midwest Region (BIA- :MR.) transfer approximately 60 acres of the Tribe's fee land located in Muskegon County, Michigan, into federal trust status. The 60 acre parcel as well as an additional approximate 26.5 acres of adjacent land owned by the Tribe (a total of86.5 acres) is proposed for development. The 86.5-acre project site is referred to herein as the Subject Property. The Proposed Project includes a casino, hotel, conference center, parking, and other supporting facilities. The BIA-MR has determined that the Proposed Project is an undertaking as defined by 36 CFR 800.16(y) because the Little River Band has submitted a Fee to Trust Application for the Purpose of Gaming (25CFR151). The Area of Potential Effect (APE) consists of the Subject Property and several road and water infrastructure improvements that will be required to mitigate potential impacts from operation of the Proposed Project. It is anticipated that all construction activities and staging would take place within the APE and that no excavations would be more than eight (8) feet deep. A Phase I archaeological survey of the parcels including a literature search for the APE was conducted by Analytical Environmental Services (AES) in 2016 (Enclosure 1). No historic properties were identified. A finding of no historic properties affected was recommended by AES. The BIA-MR has determined that the undertaking will have no effect to historic properties (36 CFR 800.4 (d) (1)). No further archaeological work is recommended. The BIA-MR consulted with the Little River Band Ogema and the Michigan State Historic Preservation Office (SHPO) regarding this undertaking, both the Little River Band and Michigan SHPO concurred with the BIA-MR's determination (Enclosures 2 to 5). If you have any questions or wish to

46

summit any information related to this project for consideration under Section 106 NHPA, please contact Timothy Guyah, BIA Regional Archaeologist, at 612-725-4512. Sincerely, Acting ~ Regional Director Enclosures (5): Compact Disc (CD) containing the Little River Band of Ottawa Indians Trust Acquisition and Casino Project [Muskegon SiteJ- Cultural Resources Report dated June 2016 Section I 06 Consultation letter BIA-MR to the Little River Band Ogema Regarding the Little River Band of Ottawa Indians Fee-to-Trust Application for the Purpose of Gaming (25CFR151 ): Proposed Project in Muskegon County, Michigan - dated August 3, 2016. Response from the Little River Band Ogema to the BIA-MR Regional Director Regarding the Little River Band of Ottawa Indians Fee-to-Trust Application for the Purpose of Gaming (25CFR151): Proposed Project in Muskegon County, Michigan -dated August 15, 2016. Section I 06 Consultation letter BIA-MR to Michigan State Historic Preservation Office Regarding the Little River Band of Ottawa Indians Fee-to-Trust Application for the Purpose of Gaming (25CFR151): Proposed Project in Muskegon County, Michigan - dated August 29, 2016. Response from the Michigan State Historic Preservation Office to the BIA-MR Regional Director Regarding the Little River Band of Ottawa Indians Fee-to-Trust Application for the Purpose of Gaming (25CFR151): Proposed Project in Muskegon County, Michigan- dated November 4, 2016. cc: Ogema Larry Romanelli 2

47

APPENDIX V REVISED EXECUTIVE SUMMARY TABLE

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TABLE 1 SUMMARY OF POTENTIAL ENVIRONMENTAL EFFECTS AND MITIGATION MEASURES No Resource Alternative A Alternative B Alternative C Alternative D Action Geology and Soils Topography Construction would involve Construction would involve Construction would involve Construction would involve NE grading and excavation for grading and excavation for grading and excavation for grading and excavation for building pads, parking lots, building pads, parking lots, building pads, parking lots, building pads, parking lots, and utilities. Balanced and utilities. Balanced and utilities. Balanced and utilities. Balanced cut-and-fill, stockpiled soil, cut-and-fill, stockpiled soil, cut-and-fill, stockpiled soil, cut-and-fill, stockpiled soil, and vegetative landscaping and vegetative landscaping and vegetative landscaping and vegetative landscaping are planned to prevent slope are planned to prevent slope are planned to prevent slope are planned to prevent slope failure. - LS failure. - LS failure. - LS failure. - LS Mitigation NA NA NA NA NA Soils/Geology Disturbance of the soils could Disturbance of the soils could Disturbance of the soils could Disturbance of the soils could NE result in loss of topsoil and a result in loss of topsoil and a result in loss of topsoil and a result in loss of topsoil and a degradation of air and water degradation of air and water degradation of air and water degradation of air and water quality through wind erosion quality through wind erosion quality through wind erosion quality through wind erosion and runoff. - LSM and runoff. - LSM and runoff. - LSM and runoff. - LSM Mitigation MM 5.2 (A) Implement MM 5.2 (A). Implement MM 5.2 (A). Implement MM 5.2 (A). NA The Tribe shall obtain coverage under the United States Environmental Protection Agency (USEPA) General Construction National Pollutant Discharge Elimination System (NPDES) permit under the federal requirements of the Clean Water Act (CWA). As required by the NPDES General Construction Permit, a Stormwater Pollution Prevention Plan (SWPPP) shall be prepared that addresses potential water Note: NE = No Effect LS = Less than Significant Effect LSM = Less than Significant with Mitigation S = Significant Adverse Effect BE = Beneficial Effect NA = Not Applicable October 2020 1 Little River Band Trust Acquisition and Casino Project Executive Summary Table

49

No Resource Alternative A Alternative B Alternative C Alternative D Action quality impacts associated with construction and operation of the project alternatives. As required by the NPDES General Construction Permit, the SWPPP shall include provisions for erosion prevention and sediment control and control of other potential pollutants by describing construction practices, stabilization techniques, and structural Best Management Practices (BMP) that are to be implemented to prevent erosion and minimize sediment transport. BMPs shall be inspected, maintained, and repaired to assure continued performance of their intended function. Reports summarizing the scope of these inspections, the personnel conducting the inspection, the dates of the inspections, major observations relating to the implementation of the SWPPP, and actions taken as a result of these inspections shall be prepared and retained as part of the SWPPP. To minimize the potential for erosion to occur on the site, the following items shall be Note: NE = No Effect LS = Less than Significant Effect LSM = Less than Significant with Mitigation S = Significant Adverse Effect BE = Beneficial Effect NA = Not Applicable October 2020 2 Little River Band Trust Acquisition and Casino Project Executive Summary Table

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No Resource Alternative A Alternative B Alternative C Alternative D Action addressed in the SWPPP and implemented pursuant to the NPDES General Construction Permit: 1. Prior to land-disturbing activities, the clearing and grading limits shall be marked clearly, both in the field and on the plans. This can be done using construction fences or by creating buffer zones. 2. Stripped areas shall be stabilized through temporary seeding using dryland grasses. 3. Conveyance channels and severe erosion channels shall be mulched or matted to prevent excessive erosion. 4. Exposed stockpiled soils shall be covered with plastic covering to prevent wind and rain erosion. 5. The construction entrance shall be stabilized by the use of rip-rap, crushed gravel, or other such material to prevent the track-out of dirt and mud. 6. Construction roadways shall be stabilized through the use of frequent watering, stabilizing chemical application, or physical covering of gravel or rip-rap. Note: NE = No Effect LS = Less than Significant Effect LSM = Less than Significant with Mitigation S = Significant Adverse Effect BE = Beneficial Effect NA = Not Applicable October 2020 3 Little River Band Trust Acquisition and Casino Project Executive Summary Table

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No Resource Alternative A Alternative B Alternative C Alternative D Action 7. Filter fences shall be erected at all on-site stormwater exit points and along the edge of graded areas to stabilized non-graded areas and control siltation of on-site stormwater. 8. Dust suppression measures included in Section 5.4, Air Quality, shall be implemented to control the production of fugitive dust and prevent wind erosion of bare and stockpiled soils. 9. Haul roads and staging areas shall be developed to control impacts to on-site soil. All access points, haul roads, and staging areas shall be stabilized with crushed rock. Any sediment shall be removed daily and the road structure maintained. 10. Concentrated flows create high potential for erosion; therefore, any slopes shall be protected from concentration flow. This can be done by using gradient terraces, interceptor dikes, and swales, and by installing pipe slope drains or level spreaders. Inlets shall be protected to provide an initial filtering of Note: NE = No Effect LS = Less than Significant Effect LSM = Less than Significant with Mitigation S = Significant Adverse Effect BE = Beneficial Effect NA = Not Applicable October 2020 4 Little River Band Trust Acquisition and Casino Project Executive Summary Table

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No Resource Alternative A Alternative B Alternative C Alternative D Action stormwater runoff; however, any sediment buildup shall be removed so the inlet does not become blocked. 11. The SWPPP shall address maintenance and repair of heavy equipment on site to remove the potential for pollution from oil, fuel, hydraulic fluid, or any other potential pollutant. 12. Staging areas and haul roads shall be constructed to minimize future over-excavation of deteriorated sub-grade soil. 13. Temporary erosion control measures (such as silt fence, gravel filter berms, straw wattles, sediment/grease traps, mulching of disturbed soil, construction stormwater chemical treatment, and construction stormwater filtration) shall be employed for disturbed areas. 14. Exposed and unworked soils shall be stabilized by the application of effective BMPs. These include, but are not limited to, temporary or permanent seeding, mulching, nets and blankets, plastic Note: NE = No Effect LS = Less than Significant Effect LSM = Less than Significant with Mitigation S = Significant Adverse Effect BE = Beneficial Effect NA = Not Applicable October 2020 5 Little River Band Trust Acquisition and Casino Project Executive Summary Table

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No Resource Alternative A Alternative B Alternative C Alternative D Action covering, sodding, and gradient terraces. 15. The SWPPP shall address the maintenance of both temporary and permanent erosion and sediment control BMPs. Seismicity The State of Michigan is in an The State of Michigan is in an The State of Michigan is in an The State of Michigan is in an NE area of low seismic risk and area of low seismic risk and area of low seismic risk. - LS area of low seismic risk and buildings would be developed buildings would be developed there are no known fault in compliance with State in compliance with State traces in the vicinity of the building codes. - LS building codes. - LS Custer Site. - LS Mitigation NA NA NA NA NA Mineral Resources The development would not The development would not The development would not The development would not NE adversely affect known or adversely affect known or adversely affect known or adversely affect known or recorded mineral resources. recorded mineral resources. recorded mineral resources. recorded mineral resources. - LS - LS - LS - LS Mitigation NA NA NA NA NA Water Resources Flooding The site is located outside the The site is located outside the The site is located outside the The site is located outside the NE 100-year and 500-year 100-year and 500-year 100-year and 500-year 100-year and 500-year floodplains; therefore, floodplains; therefore, floodplains; therefore, floodplains; therefore, development would not development would not development would not development would not impede or redirect flood flows, impede or redirect flood flows, impede or redirect flood flows, impede or redirect flood flows, alter floodplain elevations, or alter floodplain elevations, or alter floodplain elevations, or alter floodplain elevations, or affect floodplain affect floodplain affect floodplain affect floodplain management. - NE management. - NE management. - NE management. - NE Mitigation NA NA NA NA NA Note: NE = No Effect LS = Less than Significant Effect LSM = Less than Significant with Mitigation S = Significant Adverse Effect BE = Beneficial Effect NA = Not Applicable October 2020 6 Little River Band Trust Acquisition and Casino Project Executive Summary Table

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No Resource Alternative A Alternative B Alternative C Alternative D Action Surface Water - Construction Erosion from construction Erosion from construction Erosion from construction Erosion from construction NE Impacts could increase sediment could increase sediment could increase sediment could increase sediment discharge to surface waters discharge to surface waters discharge to surface waters discharge to surface waters during storm events and during storm events and during storm events and during storm events and construction activities could construction activities could construction activities could construction activities could include the routine use of include the routine use of include the routine use of include the routine use of potentially hazardous potentially hazardous potentially hazardous potentially hazardous construction materials. - LSM construction materials. - LSM construction materials. - LSM construction materials. - LSM Mitigation As described above in MM Implement MM 5.2 (A). Implement MM 5.2 (A). Implement MM 5.2 (A). NA 5.2 (A), in accordance with federal regulatory requirements for Alternatives A, B, C, and D, coverage under the NPDES General Construction Permit shall be obtained from the USEPA and a SWPPP shall be prepared. As required by the NPDES General Construction Permit, the SWPPP shall describe construction practices, stabilization techniques, and structural BMPs that are to be implemented to prevent erosion and minimize sediment transport as outlined in MM 5.2 (A). Surface Water - Stormwater All stormwater would be All stormwater would be All stormwater would be All stormwater would be NE Runoff retained and treated onsite retained and treated onsite retained and treated onsite retained and treated onsite through the use of bioswales, through the use of bioswales, through the use of bioswales, through the use of bioswales, rain gardens, and retention rain gardens, and retention rain gardens, and retention rain gardens, and detention ponds. No discharge to ponds. No discharge to ponds. No discharge to basins. No discharge to Waters of the U.S. would Waters of the U.S. would Waters of the U.S. would Waters of the U.S. would occur; therefore, impacts to occur; therefore, impacts to occur; therefore, impacts to occur; therefore, impacts to surface waters would be less surface waters would be less surface waters would be less surface waters would be less than significant. - LS than significant. - LS than significant. - LS than significant. - LS Note: NE = No Effect LS = Less than Significant Effect LSM = Less than Significant with Mitigation S = Significant Adverse Effect BE = Beneficial Effect NA = Not Applicable October 2020 7 Little River Band Trust Acquisition and Casino Project Executive Summary Table

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No Resource Alternative A Alternative B Alternative C Alternative D Action Mitigation NA NA NA NA NA Groundwater Retention ponds could Retention ponds could Retention ponds could Detention basins could NE transport dissolved transport dissolved transport dissolved transport dissolved contaminants into the contaminants into the contaminants into the contaminants into the groundwater through groundwater through groundwater through groundwater through percolation. - LS percolation. - LS percolation. - LS percolation. - LS Mitigation NA NA NA NA NA Air Quality Construction Emissions Construction of Alternative A Construction of Alternative B Construction of Alternative C Construction of Alternative D NE would not cause an would not cause an would not cause an would not cause an exceedance of National exceedance of NAAQS for exceedance of NAAQS for exceedance of NAAQS for Ambient Air Quality CAPs. Emissions of DPM CAPs. Emissions of DPM CAPs. Emissions of DPM Standards (NAAQS) for could impact sensitive could impact sensitive could impact sensitive criteria air pollutants (CAP). receptors. - LS receptors. - LS receptors. - LS Emissions of diesel particulate matter (DPM) could impact sensitive receptors. - LS Mitigation NA NA NA NA NA Operational Vehicle and Area Estimated mobile and Estimated mobile and Estimated mobile and Estimated mobile and NE Emissions stationary emissions of CAPs stationary emissions of CAPs stationary emissions of CAPs stationary emissions of CAPs from operation of Alternative from operation of Alternative from operation of Alternative from operation of Alternative A would not exceed NAAQS. B would not exceed NAAQS. C would not exceed NAAQS. D would not exceed NAAQS. - LS - LS - LS - LS Mitigation NA NA NA NA NA Biological Resources Note: NE = No Effect LS = Less than Significant Effect LSM = Less than Significant with Mitigation S = Significant Adverse Effect BE = Beneficial Effect NA = Not Applicable October 2020 8 Little River Band Trust Acquisition and Casino Project Executive Summary Table

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No Resource Alternative A Alternative B Alternative C Alternative D Action Habitats None of the habitats that None of the habitats that None of the habitats that None of the habitats that NE would be affected by the would be affected by the would be affected by the would be affected by the implementation of Alternative implementation of Alternative implementation of Alternative implementation of Alternative A are considered sensitive B are considered sensitive C are considered sensitive D are considered sensitive communities; therefore, no communities; therefore, no communities; therefore, no communities; therefore, no effect would occur. - NE effect would occur. - NE effect would occur. - NE effect would occur. - NE Mitigation NA NA NA NA NA Federally Listed Species Alternative A has the potential Alternative B has the potential Alternative C has the potential Alternative D has the potential NE to impact federally listed to impact federally listed to impact federally listed to impact federally listed wildlife species; however, with wildlife species; however, with wildlife species; however, with wildlife species; however, with implementation of mitigation implementation of mitigation implementation of mitigation implementation of mitigation measures it is not likely to measures it is not likely to measures it is not likely to measures it is not likely to cause significant adverse cause significant adverse cause significant adverse cause significant adverse impacts. - LSM impacts. - LSM impacts. - LSM impacts. - LSM Mitigation MM 5.5 (B) Implement MM 5.5 (B) and Implement MM 5.5 (B) and Implement MM 5.5 (B). NA To avoid potential adverse MM 5.5 (C). MM 5.5 (C). effects to the eastern MM 5.5 (D) massasauga rattlesnake, a As the forested areas within qualified biologist shall the Custer Site provide conduct two pre-construction suitable summer roosting surveys within all suitable habitat for both the northern habitats of the site. The long-eared bat and the surveys shall be conducted in Indiana bat, the following accordance with the USFWS mitigation measures are accepted protocol for eastern required to avoid potential massasauga (Casper et al., adverse effects to these 2001). If the eastern species. massasauga is not found during the pre-construction If construction-related surveys, no further mitigation activities shall occur during would be required. If eastern the summer roosting season massasauga is observed for the northern long-eared within the site, additional bat (between April 1 and mitigation measures would be September 30 [USFWS, implemented. Additional 2014]) or the Indiana bat (between April 1 and October Note: NE = No Effect LS = Less than Significant Effect LSM = Less than Significant with Mitigation S = Significant Adverse Effect BE = Beneficial Effect NA = Not Applicable October 2020 9 Little River Band Trust Acquisition and Casino Project Executive Summary Table

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No Resource Alternative A Alternative B Alternative C Alternative D Action mitigation measures may 15) (USFWS, 2009), include: pre-construction surveys within the Custer Site and 1. Relocation of eastern immediate vicinity for these massasauga to suitable bat species protected under habitat in the vicinity of the the federal Endangered site Species Act (FESA) would be 2. Installation of exclusion required. Both the northern fencing around long-eared bat and the construction areas prior to Indiana bat use similar eastern massasauga den summer roosting habitats; emergence therefore, completing surveys following the Range-wide 3. Environmental awareness Indiana Bat Summer Survey training for construction Guidelines (USFWS, 2015) personnel should also be sufficient to locate northern long-eared MM 5.5 (C) bat summer roosting habitat. To avoid potential adverse Prior to any construction on effects to the northern the Custer Site and during the long-eared bat and the appropriate survey time Indiana bat, demolition of period (May 15 to August 15), unoccupied structures on the a qualified biologist shall Muskegon Site shall occur complete the necessary between November 1 and surveys determined through March 1, which is well outside coordination with the local of the summer roosting USFWS Field Office following seasons of both species: the below-listed protocols as April 1 to September 30 for presented in the Range-wide the northern long-eared bat Indiana Bat Summer Survey (USFWS, 2014) and April 1 to Guidelines (USFWS, 2015). October 15 for the Indiana bat 1. Presence/Absence (USFWS, 2009). Surveys (Mist-Netting or Acoustic Surveys). As of the Range-wide Indiana Bat Summer Survey Guidelines, presence/probable absence (P/A) of Indiana Note: NE = No Effect LS = Less than Significant Effect LSM = Less than Significant with Mitigation S = Significant Adverse Effect BE = Beneficial Effect NA = Not Applicable October 2020 10 Little River Band Trust Acquisition and Casino Project Executive Summary Table

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No Resource Alternative A Alternative B Alternative C Alternative D Action bats may be determined by conducting either mist-netting or acoustics as outlined below. The Applicant shall choose which option to use.  A qualified biologist shall conduct mist-netting surveys following the Recovery Unit-based Protocols presented in Appendix B of the Range-wide Indiana Bat Summer Survey Guidelines. As the project is within the Midwest Recovery Unit and is non-linear, a minimum of nine net nights per 123 acres of suitable summer habitat shall be required. If no Indiana bats are captured, then no further summer surveys are necessary. If Indiana bats are captured, then either acoustic surveys or further coordination with the USFWS shall be required.  A qualified biologist shall conduct acoustic surveys following protocols presented in Appendix C of the Range-wide Indiana Bat Summer Survey Guidelines. As the Note: NE = No Effect LS = Less than Significant Effect LSM = Less than Significant with Mitigation S = Significant Adverse Effect BE = Beneficial Effect NA = Not Applicable October 2020 11 Little River Band Trust Acquisition and Casino Project Executive Summary Table

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No Resource Alternative A Alternative B Alternative C Alternative D Action project is non-linear, a minimum of four detector nights per 123 acres of suitable summer habitat shall be required. If the acoustic surveys do not positively detect high frequency (HF) calls (>35 kilo-Hertz) or myotid calls, then no further surveys would be necessary. If HF or myotid calls are detected, then either automated acoustic analysis or further coordination with USFWS would be required.  A qualified biologist shall conduct automated acoustic analyses for each site that had HF or myotid calls from the acoustic surveys or ALL sites if the acoustic surveys were not conducted. This step shall be completed using one or more of the currently available “approved” acoustic bat identification programs. If Indiana bat presence is considered unlikely by all of the approved programs used in analysis, then no further summer surveys would Note: NE = No Effect LS = Less than Significant Effect LSM = Less than Significant with Mitigation S = Significant Adverse Effect BE = Beneficial Effect NA = Not Applicable October 2020 12 Little River Band Trust Acquisition and Casino Project Executive Summary Table

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No Resource Alternative A Alternative B Alternative C Alternative D Action be necessary. If presence is likely, then qualitative analysis of probable Indiana bat calls or further coordination with USFWS would be required.  A qualified biologist shall conduct qualitative analysis of probable Indiana bat calls from the automated acoustic analyses. At a minimum, for each site/night that a program considers Indiana bat presence is likely, a qualified biologist shall review all files from the night. If the biologist visually confirms there are no Indiana bat calls recorded, then no further summer surveys would be necessary. If the biologist confirms that Indiana bat calls are recorded, then either mist-netting surveys or further coordination with USFWS would be required. 2. Conduct Mist-Netting Surveys to Capture Indiana Bats. If netting was not conducted as the P/A method, then netting may be conducted during Note: NE = No Effect LS = Less than Significant Effect LSM = Less than Significant with Mitigation S = Significant Adverse Effect BE = Beneficial Effect NA = Not Applicable October 2020 13 Little River Band Trust Acquisition and Casino Project Executive Summary Table

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No Resource Alternative A Alternative B Alternative C Alternative D Action mist-netting surveys to capture and characterize (e.g., sex, age, reproductive condition) the Indiana bats that are present in an area and to facilitate efforts associated with radio-tracking and emergency surveys, described below. If no Indiana bats are captured, then coordination with the USFWS should ensue. If Indiana bats are captured, then radio-tracking and emergence surveys would be required. 3. Conduct Radio-Tracking and Emergence Surveys. In coordination with the USFWS, a qualified biologist shall conduct radio-tracking and emergence surveys following protocols presented in Appendices D and E of the Range-wide Indiana Bat Summer Survey Guidelines. If the above surveys find presence of Indiana bat and/or the northern long- eared bat, then additional coordination with the USFWS would determine how to best prevent impacts to these sensitive species. If construction-related activities only occur outside of Note: NE = No Effect LS = Less than Significant Effect LSM = Less than Significant with Mitigation S = Significant Adverse Effect BE = Beneficial Effect NA = Not Applicable October 2020 14 Little River Band Trust Acquisition and Casino Project Executive Summary Table

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No Resource Alternative A Alternative B Alternative C Alternative D Action the summer roosting season for the northern long-eared bat (between April 1 to September 30 [USFWS, 2014]) or the Indiana bat (between April 1 and October 15 [USFWS, 2009]), then the above described surveys will not be required; however, the following measure will be required. 4. To avoid potential adverse effects to the northern long-eared bat and the Indiana bat, tree removal shall occur between November 1 and March 1, well outside of the summer roosting seasons of both species: April 1 to September 30 for the northern long-eared bat (USFWS, 2014) and April 1 to October 15 for the Indiana bat (USFWS, 2009). State Listed Species Alternative A would have no Alternative B would have no Alternative C would have no Alternative D could result in NE impact on state-listed plant or impact on state-listed plant or impact on state-listed plant or impacts to state-listed plant or wildlife species; therefore, no wildlife species; therefore, no wildlife species; therefore, no wildlife species; however, effect would occur. - NE effect would occur. - NE effect would occur. - NE mitigation for reducing potential impacts on state-listed species is not warranted because the site is held in trust by the federal government and is not subject to the Michigan Natural Resources and Note: NE = No Effect LS = Less than Significant Effect LSM = Less than Significant with Mitigation S = Significant Adverse Effect BE = Beneficial Effect NA = Not Applicable October 2020 15 Little River Band Trust Acquisition and Casino Project Executive Summary Table

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No Resource Alternative A Alternative B Alternative C Alternative D Action Environmental Protection Act. - LS Mitigation NA NA NA NA NA Migratory Birds Construction of Alternative A Construction of Alternative B Construction of Alternative C Construction of Alternative D NE could result in impacts to could result in impacts to could result in impacts to could result in impacts to species protected under the species protected under the species protected under the species protected under the MBTA if active nests are MBTA if active nests are MBTA if active nests are MBTA if active nests are present within shrubs and/or present within shrubs and/or present within shrubs and/or present within shrubs and/or ornamental trees within the ornamental trees within the ornamental trees within the ornamental trees within the Muskegon Site. - LSM Muskegon Site. - LSM Muskegon Site. - LSM Custer Site. - LSM Mitigation MM 5.5 (A) Implement MM 5.5 (A). Implement MM 5.5 (A). Implement MM 5.5 (A). NA If construction-related activities such as tree removal or grubbing of vegetation occur during the nesting bird season (between March 15 and August 31), a qualified biologist shall conduct a pre-construction survey within the site for active nests for bird species protected under the MBTA. The pre-construction survey shall be conducted within seven days prior to commencement of construction activities. If surveys show that there is no evidence of nests, then no additional mitigation would be required so long as construction activities commence within seven days following the survey. If active nests are identified, appropriate, species-specific Note: NE = No Effect LS = Less than Significant Effect LSM = Less than Significant with Mitigation S = Significant Adverse Effect BE = Beneficial Effect NA = Not Applicable October 2020 16 Little River Band Trust Acquisition and Casino Project Executive Summary Table

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No Resource Alternative A Alternative B Alternative C Alternative D Action buffer zones shall be established around the nests. Buffer zones are species dependent, and generally range from 100 to 500 feet from the nest site. The biologist should delimit the buffer zone with construction tape or pin flags and maintain the buffer zone until the end of breeding season or the young have fledged. Guidance from the United States Fish and Wildlife Service (USFWS) would be requested if establishing a buffer zone is impractical. A qualified biologist should monitor nests weekly during construction to evaluate potential nesting disturbance by construction activities. The tree shall not be removed until the biologist determines that the nestlings have successfully fledged. If tree removal or grubbing of vegetation occurs outside of the nesting bird season, a nesting bird survey would not be required and no further mitigation would be required Wetlands and/or Waters of There are no jurisdictional There are no jurisdictional There are no jurisdictional The National Wetlands NE the US Waters of the U.S. located Waters of the U.S. located Waters of the U.S. located Inventory (NWI) has mapped within the Muskegon Site. within the Muskegon Site. within the Muskegon Site. wetlands within the Custer Discharge of soil associated Discharge of soil associated Discharge of soil associated Site; thus mitigation with ground-disturbing with ground-disturbing with ground-disturbing measures are required under activities has the potential to activities has the potential to activities has the potential to Note: NE = No Effect LS = Less than Significant Effect LSM = Less than Significant with Mitigation S = Significant Adverse Effect BE = Beneficial Effect NA = Not Applicable October 2020 17 Little River Band Trust Acquisition and Casino Project Executive Summary Table

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No Resource Alternative A Alternative B Alternative C Alternative D Action impact off-site waterways. - impact off-site waterways. - impact off-site waterways. - Section 404 of the CWA. - LSM LSM LSM LSM Mitigation Implement MM 5.2 (A). Implement MM 5.2 (A) and Implement MM 5.2 (A) and Implement MM 5.2 (A) and NA MM 5.5 (E). MM 5.5 (E). MM 5.5 (E). MM 5.5 (E) A formal delineation and verification of Wetlands and other Waters of the U.S. shall occur if construction-related activities have the potential to affect aquatic resources on the site. If less than 0.5 acres of potential wetlands are going to be disturbed, project activities may fall under an existing nationwide permit. However, impacts to wetlands would likely require a USEPA 401 water quality certification and a U.S. Army Corps of Engineers (USACE) 404 permit before wetland impacts occur, and would likely require mitigation for disturbance. All project activities, including off-site improvement areas, shall comply with these permits, should they be necessary. Cultural and Paleontological Resources Cultural Resources Given the absence of Given the absence of Given the absence of One potentially historic site NE (Known/Existing) pre-contact or historic pre-contact or historic pre-contact or historic was identified within the resources within the resources within the resources within the vicinity of the Custer Site; Muskegon Site, there would Muskegon Site, there would Muskegon Site, there would however, it has not been be no direct adverse effects be no direct adverse effects be no direct adverse effects recommended as eligible for to known National Register of to known NRHP-eligible or to known NRHP-eligible or listing in the NRHP. Note: NE = No Effect LS = Less than Significant Effect LSM = Less than Significant with Mitigation S = Significant Adverse Effect BE = Beneficial Effect NA = Not Applicable October 2020 18 Little River Band Trust Acquisition and Casino Project Executive Summary Table

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No Resource Alternative A Alternative B Alternative C Alternative D Action Historic Places (NRHP)- listed resources as a result of listed resources as a result of Therefore, Alternative D eligible or listed resources as Alternative B. - NE Alternative C. - NE would not adversely impact a result of Alternative A. - NE known historic properties. - NE Mitigation NA NA NA NA NA Cultural Resources Previously unknown cultural Previously unknown cultural Previously unknown cultural Previously unknown cultural NE (Undiscovered) resources may be resources may be resources may be resources may be encountered during ground- encountered during ground- encountered during ground- encountered during ground- disturbing activities. - LSM disturbing activities. - LSM disturbing activities. - LSM disturbing activities. - LSM Mitigation MM 5.6 (A) Implement MM 5.6 (A) and Implement MM 5.6 (A) and Implement MM 5.6 (A) and NA In the event of any MM 5.6 (B). MM 5.6 (B). MM 5.6 (B). inadvertent discovery of prehistoric or historic MM 5.6 (D) archaeological resources or In the event that the BIA paleontological resources selects Alternative D as the during construction-related Proposed Action, consultation earth-moving activities, all under Section 106 of the such finds shall be subject to NHPA for the Custer Site Section 106 of the NHPA as would occur. amended (36 CFR § 800). Specifically, procedures for post-review discoveries without prior planning pursuant to 36 CFR § 800.13 shall be followed, including re-consulting with SHPO and the nearby community and identifying reasonable and prudent measures to avoid, minimize, or mitigate adverse effects to such discoveries. MM 5.6 (B) If human remains are discovered during ground-disturbing activities on tribal lands, if applicable, the Note: NE = No Effect LS = Less than Significant Effect LSM = Less than Significant with Mitigation S = Significant Adverse Effect BE = Beneficial Effect NA = Not Applicable October 2020 19 Little River Band Trust Acquisition and Casino Project Executive Summary Table

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No Resource Alternative A Alternative B Alternative C Alternative D Action finds shall be subject to the requirements of the NAGPRA and/or ARPA. Paleontological Resources Previously unknown Previously unknown Previously unknown Previously unknown NE paleontological resources paleontological resources paleontological resources paleontological resources could be discovered during could be discovered during could be discovered during could be discovered during earth-moving activities. - LSM earth-moving activities. - LSM earth-moving activities. - LSM earth-moving activities. - LSM Mitigation MM 5.6 (C) Implement MM 5.6 (C). Implement MM 5.6 (C). Implement MM 5.6 (C). NA In the event of accidental discovery of paleontological materials during ground-disturbing activities, a qualified professional paleontologist shall be contacted to evaluate the significance of the find and to collect the materials for curation as appropriate. Socioeconomic Conditions Economic Effects Under Alternative A, Under Alternative B, Under Alternative C, Under Alternative D, NE construction activities are construction activities are construction activities are construction activities are estimated to cost estimated to cost estimated to cost estimated to cost approximately $179.6 million, approximately $84.5 million, approximately $38.4 million, approximately $29.7 million, which is expected to generate which is expected to generate which is expected to generate which is expected to generate a one-time total output of a one-time total output of a one-time total output of a one-time total output of approximately $209.8 million approximately $93.0 million approximately $53.2 million approximately $28.4 million within Muskegon County. within Muskegon County. within Muskegon County. within Mason County. New New spending from the New spending from the New spending from the spending from the proposed proposed project is expected proposed project is expected proposed project is expected project is expected to to generate a net annual total to generate a net annual total to generate a net annual total generate a net annual total output of approximately output of approximately $99.4 output of approximately $20.9 output of approximately $31.7 $136.7 million within million within Muskegon million within Muskegon million within Mason County Muskegon County during the County during the operation County during the operation during the operation phase. operation phase. Construction phase. Construction and phase. Construction and Construction and operation of and operation of Alternative A operation of Alternative B operation of Alternative C Alternative D would generate Note: NE = No Effect LS = Less than Significant Effect LSM = Less than Significant with Mitigation S = Significant Adverse Effect BE = Beneficial Effect NA = Not Applicable October 2020 20 Little River Band Trust Acquisition and Casino Project Executive Summary Table

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No Resource Alternative A Alternative B Alternative C Alternative D Action would generate substantial would generate substantial would generate substantial substantial output to a variety output to a variety of output to a variety of output to a variety of of businesses in Mason businesses in Muskegon businesses in Muskegon businesses in Muskegon County which would stimulate County which would stimulate County which would stimulate County which would stimulate its local economy. - BE its local economy. - BE its local economy. - BE its local economy. - BE Mitigation NA NA NA NA NA Substitution Effects Potential substitution effects Potential substitution effects Substitution effects to existing Potential substitution effects NE would be countered by would be countered by gaming venues are not to gaming facilities would be increased activity at local increased activity at local applicable because less than 2 percent of their retail businesses; thus retail businesses; thus Alternative C does not have a projected 2018 gaming non-gaming substitution non-gaming substitution gaming component. Impacts revenue. Additionally, effects would be less than effects would be less than to existing non-gaming Alternative D does not include significant. - LS significant. - LS retailers would be less than a hotel component, and significant. - LS non-gaming substitution effects would be less than significant. - LS Mitigation NA NA NA NA NA Fiscal Effects Because property in trust is Because property in trust is Because property in trust is The Custer Site is already NE not subject to property taxes, not subject to property taxes, not subject to property taxes, held in trust by the federal these taxes would be lost to these taxes would be lost to these taxes would be lost to government. Because state and local governments. state and local governments. state and local governments. property in trust is not subject Lost property tax would be Lost property tax would be Lost property tax would be to property taxes, no taxes more than offset by both tax more than offset by both tax more than offset by tax would be lost to state and revenues generated for state revenues generated for state revenues generated for state local governments. - LS and local governments from and local governments from and local governments from economic activity associated economic activity associated economic activity associated with the construction and with the construction and with the construction and operation of Alternative A and operation of Alternative B and operation of Alternative C. - payments to local payments to local LS governments under the governments under the MSA. Municipal Services - LS Agreement (MSA). - LS Mitigation NA NA NA NA NA Note: NE = No Effect LS = Less than Significant Effect LSM = Less than Significant with Mitigation S = Significant Adverse Effect BE = Beneficial Effect NA = Not Applicable October 2020 21 Little River Band Trust Acquisition and Casino Project Executive Summary Table

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No Resource Alternative A Alternative B Alternative C Alternative D Action Property Values Alternative A would not result Alternative B would not result Alternative C would not result Alternative D would not result NE in changes to local property in changes to local property in changes to local property in changes to local property values, and thus would not values, and thus would not values, and thus would not values, and thus would not impact local tax assessor rolls impact local tax assessor rolls impact local tax assessor rolls impact local tax assessor rolls or local property tax or local property tax or local property tax or local property tax revenues. - LS revenues. - LS revenues. - LS revenues. - LS Mitigation NA NA NA NA NA Employment Alternative A is projected to Alternative B is projected to Alternative C is projected to Alternative D is projected to NE create a total of 1,763 create a total of 947 one-time create a total of 506 one-time create a total of 272 one-time one-time construction related construction related jobs and construction related jobs and construction related jobs and jobs and 1,624 permanent 1,128 permanent operations 318 permanent operations 387 permanent operations operations jobs. This would jobs. This would result in jobs. This would result in jobs. This would result in result in employment and employment and wages for employment and wages for employment and wages for wages for persons previously persons previously persons previously persons previously unemployed and would unemployed and would unemployed and would unemployed and would contribute to the alleviation of contribute to the alleviation of contribute to the alleviation of contribute to the alleviation of poverty among lower income poverty among lower income poverty among lower income poverty among lower income households. - BE households. - BE households. - BE households. - BE Mitigation NA NA NA NA NA Housing Alternative A is estimated to Because Alternative B is Because Alternative C is Alternative D is estimated to NE increase housing demand by smaller in scope and would smaller in scope and would increase housing demand by 168 units, or 0.2 percent of have fewer employees than have fewer employees than 12 units, or 0.1 percent of the the projected 74,141 housing Alternative A, impacts to Alternative A, impacts to projected 17,509 housing units in Muskegon County in housing under Alternative B housing under Alternative C units in Mason County in 2019. Due to the number of would be less than those would be less than those 2019. Due to the number of anticipated vacant houses in under Alternative A; therefore, under Alternative A; therefore, anticipated vacant houses in the vicinity of the project, Alternative B is not expected Alternative C is not expected the vicinity of the project, Alternative A is not expected to stimulate regional housing to stimulate regional housing Alternative D is not expected to stimulate regional housing development. - LS development. - LS to stimulate regional housing development. - LS development. - LS Mitigation NA NA NA NA NA Social Effects Implementation of Alternative Implementation of Alternative Because Alternative C does Implementation of Alternative NE A may slightly increase the B may slightly increase the not include a gaming D may slightly increase the Note: NE = No Effect LS = Less than Significant Effect LSM = Less than Significant with Mitigation S = Significant Adverse Effect BE = Beneficial Effect NA = Not Applicable October 2020 22 Little River Band Trust Acquisition and Casino Project Executive Summary Table

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No Resource Alternative A Alternative B Alternative C Alternative D Action prevalence rates of problem prevalence rates of problem component, its prevalence rates of problem gambling in the local gambling in the local implementation would not gambling in the local community. This alternative community. This alternative affect the prevalence rates of community. This alternative may increase demand for law may increase demand for law problem gambling in the local may increase demand for law enforcement services. - LSM enforcement services. - LSM community. This alternative enforcement services. - LSM may increase demand for law enforcement services. - LSM Mitigation Implement MM 5.10 (C) Implement MM 5.7 (A) Implement MM 5.10 (F) Implement MM 5.10 (G) NA Implement MM 5.10 (D) Implement MM 5.10 (C) Implement MM 5.10 (D) MM 5.7 (A) The Tribe shall fund an annual grant in the amount of $25,000.00, to the Muskegon County Community Mental Health Department for training purposes only. This training will include any certification necessary, as well as in-service training necessary for the department’s psychologists and social workers in order to obtain the necessary expertise to respond to problems that may arise as a result of gambling addictions. Community Impacts Due to the limited number of Due to the limited number of Due to the limited number of Due to the limited number of NE employees that are expected employees that are expected employees that are expected employees that are expected to relocate to the project area, to relocate to the project area, to relocate to the project area, to relocate to the project area, effects on Muskegon effects on Muskegon effects on Muskegon effects on Mason County’s County’s schools, libraries, County’s schools, libraries, County’s schools, libraries, schools, libraries, and parks and parks are expected to be and parks are expected to be and parks are expected to be are expected to be minimal. - LS minimal. - LS minimal. - LS minimal. - LS Mitigation NA NA NA NA NA Note: NE = No Effect LS = Less than Significant Effect LSM = Less than Significant with Mitigation S = Significant Adverse Effect BE = Beneficial Effect NA = Not Applicable October 2020 23 Little River Band Trust Acquisition and Casino Project Executive Summary Table

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No Resource Alternative A Alternative B Alternative C Alternative D Action Effects to the Little River Alternative A would generate Alternative B would generate The revenues generated by Alternative D would generate NE Band of Ottawa Indians new income to fund the new income to fund the the proposed retail new income to fund the operation of the tribal operation of the tribal establishment would not be operation of the tribal government as well as create government as well as create collected directly by the Tribe; government as well as create new jobs for Tribal new jobs for Tribal however, the Tribe would new jobs for Tribal members. - BE members. - BE collect revenues from leases members. - BE signed by retailers. - BE Mitigation NA NA NA NA NA Environmental Justice: Effects on the Tribe are Effects on the Tribe are Effects on the Tribe are Effects on the Tribe are NE Minority and Low-income discussed above. No other discussed above. No other discussed above. No other discussed above. No other Communities low-income or minority low-income or minority low-income or minority low-income or minority communities as defined by communities as defined by communities as defined by communities as defined by Executive Order (EO) 12898 EO 12898 were identified in EO 12898 were identified in EO 12898 were identified in were identified in the vicinity the vicinity of the Muskegon the vicinity of the Muskegon the vicinity of the Custer Site; of the Muskegon Site; Site; therefore, Alternative B Site; therefore, Alternative C therefore, Alternative D would therefore, Alternative A would would not result in significant would not result in significant not result in significant not result in significant adverse effects to low-income adverse effects to low-income adverse effects to low-income adverse effects to low-income or minority communities. - NE or minority communities. - NE or minority communities. - NE or minority communities. - NE Mitigation NA NA NA NA NA Transportation Site Access Access to the site would be Access to the site would be Access to the site would be Access to the site would be NE provided by six driveways, provided by six driveways, provided by four driveways, provided by one driveway one along Harvey Street and one along Harvey Street and one along Harvey Street and along East First Street. The five along East Ellis Road. five along East Ellis Road. three along East Ellis Road. driveway would not require The addition of the driveways The addition of the driveways The addition of the driveways any improvements to maintain to the existing roadway could to the existing roadway could to the existing roadway could safe ingress and egress of potentially result in circulation potentially result in circulation potentially result in circulation traffic. - LS and safety impacts. - LSM and safety impacts. - LSM and safety impacts. - LSM Mitigation MM 5.8 (B)(10) Implement MM 5.8 (B)(10). Implement MM 5.8 (B)(10). NA NA Prior to operation of Alternatives A, B, and C, the Note: NE = No Effect LS = Less than Significant Effect LSM = Less than Significant with Mitigation S = Significant Adverse Effect BE = Beneficial Effect NA = Not Applicable October 2020 24 Little River Band Trust Acquisition and Casino Project Executive Summary Table

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No Resource Alternative A Alternative B Alternative C Alternative D Action Tribe shall implement and/or pay a fair share contribution to the following mitigation measures. Install a traffic signal at the intersection of Harvey Street and the proposed site driveway (#29) with permissive-protected left turn phasing for the southbound (SB) left turn movement into the Muskegon Site. Construction Traffic Because construction traffic Because construction traffic Because construction traffic Because construction traffic NE would be temporary, occur would be temporary, occur would be temporary, occur would be temporary, occur outside of peak hours, and outside of peak hours, and outside of peak hours, and outside of peak hours, and would not create level of would not create LOS impacts would not create LOS impacts would not create LOS impacts service (LOS) impacts at at study transportation at study transportation at study transportation study transportation facilities, facilities, no significant effects facilities, no significant effects facilities, no significant effects no significant effects would would occur to from would occur to from would occur to from occur to from Alternative Alternative B-related Alternative C-related Alternative D-related A-related construction construction traffic. - LS construction traffic. - LS construction traffic. - LS traffic. - LS Mitigation MM 5.8 (A) Implement MM 5.8 (A). Implement MM 5.8 (A). Implement MM 5.8 (A). NA A traffic control plan shall be prepared to identify where construction routes are proposed, and other standards set forth in the FHWA, Manual on Uniform Traffic Control Devices for Streets and Highways. The Traffic Management Plan (TMP) shall be submitted to the Michigan Department of Transportation (MDOT) and Muskegon County for approval. Note: NE = No Effect LS = Less than Significant Effect LSM = Less than Significant with Mitigation S = Significant Adverse Effect BE = Beneficial Effect NA = Not Applicable October 2020 25 Little River Band Trust Acquisition and Casino Project Executive Summary Table

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No Resource Alternative A Alternative B Alternative C Alternative D Action Project Traffic The increase in traffic The increase in traffic The increase in traffic All study intersections would NE generated by buildout of generated by buildout of generated by buildout of continue to operate Alternative A would contribute Alternative B would contribute Alternative C would contribute acceptably at LOS D or better to unacceptable traffic to unacceptable traffic to unacceptable traffic conditions with the addition of operations at some of the operations at some of the operations at some of the Alternative D traffic; therefore, study intersections and study intersections and study intersections and Alternative D would not roadway segments causing roadway segments causing roadway segments causing contribute towards significant them to operate below them to operate below them to operate below effects on traffic and acceptable LOS standards acceptable LOS standards acceptable LOS standards circulation. - LS and/or exceed available and/or exceed available and/or exceed available queue lengths. queue lengths. queue lengths. - LSM - LSM - LSM Mitigation MM 5.8 (B) Implement MM 5.8 (B) Implement MM 5.8 (B) NA NA Implement MM 5.8 (C) Implement MM 5.8 (E) Prior to operation, the Tribe shall implement and/or pay a Implement MM 5.8 (E) Implement MM 5.8 (F) fair share contribution Implement MM 5.8 (F) towards the following MM 5.8 (D) improvements. Prior to operation, the Tribe 1. At the intersection of shall implement and/or pay a Airline Highway and fair share contribution to the Airport Road (#1), add following mitigation permissive-protected left measures: turn phasing to the northbound (NB) and 1. At the intersection of southbound (SB) Harvey Street and Hile approaches and upgrade Road (#3), modify signal the existing diagonal operations to run EB and span pre-timed signal to WB approaches as split a fully actuated box span phases; and upgrade the signal. existing diagonal span signal to a fully actuated 2. At the intersection of box span signal with right Harvey Street and turn overlap phasing Independence Drive (#6), provided for the NB restripe to provide a approach. shared left/through lane Note: NE = No Effect LS = Less than Significant Effect LSM = Less than Significant with Mitigation S = Significant Adverse Effect BE = Beneficial Effect NA = Not Applicable October 2020 26 Little River Band Trust Acquisition and Casino Project Executive Summary Table

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No Resource Alternative A Alternative B Alternative C Alternative D Action and an exclusive right turn lane on the westbound (WB) approach along with the addition of the associated right turn overlap phase for the eastbound (EB) and WB approaches. 3. At the intersection of Harvey Street and Sternberg Road (#7), construct a right turn lane on the WB approach; restripe the WB and SB approaches to provide dual left turn lanes; modify the signal phasing to run lead-lag for opposing left turn movements due to conflicting vehicular paths; and add right turn overlap phasing for the EB and WB approaches. 4. At the intersection of Harvey Street and Pontaluna Road (#10), construct a right turn lane on the SB approach and add an associated right turn overlap phase. 5. At the intersection of Airline Highway and the WB I-96 Off-Ramp (#15), install a traffic signal with split phasing for the ramp approach; coordinate the signal with the signal at Note: NE = No Effect LS = Less than Significant Effect LSM = Less than Significant with Mitigation S = Significant Adverse Effect BE = Beneficial Effect NA = Not Applicable October 2020 27 Little River Band Trust Acquisition and Casino Project Executive Summary Table

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No Resource Alternative A Alternative B Alternative C Alternative D Action the intersection of Airline Highway and US-31 Ramps; and construct a right turn lane on the off- ramp approach with 150 feet of storage. 6. At the intersection of Airline Highway and the SB US-31 Ramps (#16), install a traffic signal with split phasing for the ramp approach; coordinate the signal with the signal at the intersection of Airline Highway and the WB I-96 Off-Ramp; construct a right turn lane on the off-ramp approach with 175 feet of storage; construct a WB left turn lane with 50 feet of storage; remove the existing channelizing island at the SB US-31 Ramps; and construct an EB right turn lane along Airline Highway between the SB US-31 Ramps and WB I-96 Off-Ramp. 7. At the intersection of Hile Road and the EB Interstate 96 (I-96) Ramps (#18), install a traffic signal; optimize and coordinate the signal with the signal at the intersection of Harvey Street and Airline Highway; and construct a Note: NE = No Effect LS = Less than Significant Effect LSM = Less than Significant with Mitigation S = Significant Adverse Effect BE = Beneficial Effect NA = Not Applicable October 2020 28 Little River Band Trust Acquisition and Casino Project Executive Summary Table

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No Resource Alternative A Alternative B Alternative C Alternative D Action WB left turn lane along Hile Road with 50 feet of storage. 8. At the intersection of Hile Road and the NB United States Highway 31 (US-31) Off-Ramp (#19), relocate the off-ramp approximately 200 feet to the west along Hile Road. 9. At the intersection of EB Sternberg Road with the NB US-31 Off-Ramp (#20), install a traffic signal; optimize and coordinate the signal with the signal at the intersection of Harvey Street and NB US-31; and construct dual right turn lanes on the NB US-31 Off-Ramp approach. 10. Install a traffic signal at the intersection of Harvey Street and the proposed site driveway (#29) with permissive-protected left turn phasing for the southbound (SB) left turn movement into the Muskegon Site. MM 5.8 (C) Prior to operation, the Tribe shall implement and/or pay a fair share contribution to the Note: NE = No Effect LS = Less than Significant Effect LSM = Less than Significant with Mitigation S = Significant Adverse Effect BE = Beneficial Effect NA = Not Applicable October 2020 29 Little River Band Trust Acquisition and Casino Project Executive Summary Table

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No Resource Alternative A Alternative B Alternative C Alternative D Action following mitigation measures. 1. At the intersection of Harvey Street and Hile Road (#3), stripe the NB approach to provide an exclusive left turn lane, shared through/right turn lane, and exclusive right turn lane; and install signage along the NB approach indicating that EB I-96 traffic should use the outer right turn lane and EB Hile Road traffic should use the inner right turn lane. Restripe the existing WB shared through/right turn lane to provide a shared left/through/right turn lane; modify signal operations to run EB and WB approaches as split phases; and upgrade the existing diagonal span signal to a fully actuated box span signal with right turn overlap phasing provided for the NB approach. MM 5.8 (E) The Tribe shall seek to enter into an agreement with Muskegon Area Transit System (MATS) for transit services to the Muskegon Site, in order to optimize bus Note: NE = No Effect LS = Less than Significant Effect LSM = Less than Significant with Mitigation S = Significant Adverse Effect BE = Beneficial Effect NA = Not Applicable October 2020 30 Little River Band Trust Acquisition and Casino Project Executive Summary Table

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No Resource Alternative A Alternative B Alternative C Alternative D Action routes and timing. If requested by MATS, the Tribe shall construct a bus stop and shelter on the Muskegon Site. MM 5.8 (F) The Tribe shall seek to enter into a Memorandum of Understanding (MOU) with MDOT to address short-term transportation issues, recommend roadway improvements, and longer term areas to monitor for possible future actions as needed. The MOU should address the following items. 1. Review and agreement on the priority transportation issue locations 2. Review and agreement on the recommended roadway improvement options at each location 3. Determination of the cost participation responsibility for each party 4. Schedules for the improvements, based on impacts and funding available from all affected parties 5. Longer term transportation issues to Note: NE = No Effect LS = Less than Significant Effect LSM = Less than Significant with Mitigation S = Significant Adverse Effect BE = Beneficial Effect NA = Not Applicable October 2020 31 Little River Band Trust Acquisition and Casino Project Executive Summary Table

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No Resource Alternative A Alternative B Alternative C Alternative D Action be monitored by the Tribe and MDOT for possible future action 6. An ongoing consultation process between the Tribe and MDOT staff, to review transportation and related issues discovered once the casino is open and operating Transit, Bicycle, and Sufficient parking is available Sufficient parking is available Sufficient parking is available Sufficient parking is available NE Pedestrian Facilities onsite and sidewalk and onsite and sidewalk and onsite and sidewalk and onsite and sidewalk and bicycle facilities currently do bicycle facilities currently do bicycle facilities currently do bicycle facilities currently do not provide direct access to not provide direct access to not provide direct access to not provide direct access to the Muskegon Site. the Muskegon Site. the Muskegon Site. the Custer Site. No significant Alternative A could affect Alternative B could affect Alternative C could affect effects would occur to transit local transit routes due to local transit routes due to local transit routes due to or pedestrian facilities as a increased ridership from increased ridership from increased ridership from result of Alternative D. - LS employees and patrons. - employees and patrons. - employees and patrons. - LSM LSM LSM Mitigation MM 5.8 (E) Implement MM 5.8 (E). Implement MM 5.8 (E). NA NA The Tribe shall seek to enter into an agreement with Muskegon Area Transit System (MATS) for transit services to the Muskegon Site, in order to optimize bus routes and timing. If requested by MATS, the Tribe shall construct a bus stop and shelter on the Muskegon Site. Land Use Land Use Planning There are no potentially There are no potentially There are no potentially There are no potentially NE significant impacts regarding significant impacts regarding significant impacts regarding significant impacts regarding Note: NE = No Effect LS = Less than Significant Effect LSM = Less than Significant with Mitigation S = Significant Adverse Effect BE = Beneficial Effect NA = Not Applicable October 2020 32 Little River Band Trust Acquisition and Casino Project Executive Summary Table

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No Resource Alternative A Alternative B Alternative C Alternative D Action land use planning in land use planning in land use planning in land use planning in Alternative A and therefore no Alternative B and therefore no Alternative C and therefore no Alternative D and therefore no mitigation measures are mitigation measures are mitigation measures are mitigation measures are necessary. - LS necessary. - LS necessary. - LS necessary. - LS Mitigation NA NA NA NA NA Land Use Capability Potentially significant impacts Potentially significant impacts Potentially significant impacts Potentially significant impacts NE regarding land use capability regarding land use capability regarding land use capability regarding land use capability in Alternative A include those in Alternative B include those in Alternative C include those in Alternative D include those relating to air quality and relating to air quality and relating to air quality and relating to air quality and noise effects from noise effects from noise effects from noise effects from construction and operational construction and operational construction and operational construction and operational activities, and congestion on activities, and congestion on activities, and congestion on activities, and congestion on local roads from increased local roads from increased local roads from increased local roads from increased traffic. - LSM traffic. - LSM traffic. - LSM traffic. - LSM Mitigation Implement applicable Implement applicable Implement applicable Implement applicable NA mitigation measures from mitigation measures from mitigation measures from mitigation measures from Section 5.8 Section 5.8 Section 5.8 Section 5.8 Transportation/Circulation. Transportation/Circulation. Transportation/Circulation. Transportation/Circulation. Agriculture Because the Muskegon Site Because the Muskegon Site Because the Muskegon Site Because the Custer Site is NE is not zoned for agricultural is not zoned for agricultural is not zoned for agricultural not zoned for agricultural uses and does not contain uses and does not contain uses and does not contain uses and does not contain any farming operations or any farming operations or any farming operations or any farming operations or infrastructure that would infrastructure that would infrastructure that would infrastructure that would support land cultivation, support land cultivation, support land cultivation, support land cultivation, Alternative A would not result Alternative B would not result Alternative C would not result Alternative D would not result in significant adverse effects in significant adverse effects in significant adverse effects in significant adverse effects to agricultural resources. - LS to agricultural resources. - LS to agricultural resources. - LS to agricultural resources. - LS Mitigation NA NA NA NA NA Public Services Water Supply Option 1 Under Water Supply Option 1, Under Water Supply Option 1, Under Water Supply Option 1, Under Water Supply Option 1, NE with implementation of the with implementation of the Alternative C would require Alternative D would require conditions of the MSA, less- conditions of the MSA, less- connection to Fruitport connection to City of Scottville Note: NE = No Effect LS = Less than Significant Effect LSM = Less than Significant with Mitigation S = Significant Adverse Effect BE = Beneficial Effect NA = Not Applicable October 2020 33 Little River Band Trust Acquisition and Casino Project Executive Summary Table

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No Resource Alternative A Alternative B Alternative C Alternative D Action than-significant effects to the than-significant effects to the Township water water infrastructure. Fruitport Township’s public Fruitport Township’s public infrastructure. Alternative C Alternative D would also water system and LOS would water system and LOS would would also require a water require the extension of water occur as a result of occur as a result of pipeline upgrade along East pipelines from the Custer Site Alternative A. - LSM Alternative B. - LSM Ellis Road. - LSM to the City of Scottville. No agreement with the City of Scottville has been made at this time to provide water services to the site under Alternative D; however, it is assumed that an agreement with the City of Scottville would be executed prior to operation of Alternative D. - LSM Mitigation MM 5.10 (A) Implement MM 5.10 (A), MM Implement MM 5.10 (E). MM 5.10 (G) NA Pursuant to Section 2.3(c) 5.10 (C), and MM 5.10 (E). The Tribe shall seek to enter and Section 2.4(c) of the MM 5.10 (F) into an agreement with the MSA, the Tribe shall pay The Tribe shall seek to enter City of Scottville for water, water and wastewater capital into an agreement with the wastewater, fire protection, connection charges and Township for water, and law enforcement monthly service fees in the wastewater, fire protection, services, as appropriate. same manner as usual and and law enforcement customary for all other users services. The provisions and of the municipal public water payments for services within system. this agreement shall be similar to conditions included MM 5.10 (C) within the MSA provided in Pursuant to Section 3.1 of the Appendix B. MSA, the Tribe shall make the following non-recurring contributions to the Township. 1. The Tribe shall contribute $200,000.00 to the Township in recognition of the expenses the Township would incur to Note: NE = No Effect LS = Less than Significant Effect LSM = Less than Significant with Mitigation S = Significant Adverse Effect BE = Beneficial Effect NA = Not Applicable October 2020 34 Little River Band Trust Acquisition and Casino Project Executive Summary Table

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No Resource Alternative A Alternative B Alternative C Alternative D Action properly equip its police department and its fire department to respond to emergencies at or resulting from the Proposed Project. This shall occur in three annual installments of $66,666.66, with the first such installment due and payable no later than 60 days after the Commencement Date (the first day the Gaming Facility is open to the public), the second installment due and payable on the first anniversary of the Commencement Date, and the third installment due and payable on the third anniversary of the Commencement Date. 2. The Tribe shall pay the full cost of on-site water main improvements, which shall be constructed by either the Township or the Tribe. The improvements shall be constructed according to Township standards and requirements and shall be subject to the approval of the Township. MM 5.10 (E) The Tribe shall either construct or offer to pay the Note: NE = No Effect LS = Less than Significant Effect LSM = Less than Significant with Mitigation S = Significant Adverse Effect BE = Beneficial Effect NA = Not Applicable October 2020 35 Little River Band Trust Acquisition and Casino Project Executive Summary Table

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No Resource Alternative A Alternative B Alternative C Alternative D Action full actual cost for the Township to construct a new 12-inch diameter water main to replace the existing 8-inch water main along East Ellis Road adjacent to the Muskegon Site, between Harvey Street and Quarterline Road. Water Supply Option 2 Under Water Supply Option 2, Under Water Supply Option 2, Under Water Supply Option 2, Under Water Supply Option 2, NE Alternative A would not utilize Alternative B would not utilize Alternative C would not utilize Alternative D would not utilize municipal water services. - LS municipal water services. - LS municipal water services. - LS municipal water services. - LS Mitigation NA NA NA NA NA Wastewater Treatment Option Under Wastewater Treatment Under Wastewater Treatment Under Wastewater Treatment Under Wastewater Treatment NE 1 Option 1, with implementation Option 1, with implementation Option 1, Alternative C would Option 1, Alternative D would of the conditions of the MSA, of the conditions of the MSA, require connection to Fruitport require connection to City of no significant effects to the no significant effects to the Township wastewater Scottville wastewater Township of Fruitport’s public Township of Fruitport’s public infrastructure. - LSM infrastructure. It is assumed sewer and wastewater sewer and wastewater that an agreement the City of treatment system LOS would treatment system and LOS Scottville would be executed occur as a result of would occur as a result of prior to operation of Alternative A. - LSM Alternative B. - LSM Alternative D. - LSM Mitigation Implement MM 5.10 (A). Implement MM 5.10 (A) and Implement MM 5.10 (E) and Implement MM 5.10 (G). NA MM 5.10 (B). MM 5.10 (F). MM 5.10 (B) Pursuant to Section 2.3(b) of the MSA, the Tribe shall fund the upgrade of the Township municipal wastewater system to the Muskegon Site. Wastewater Treatment Option Under Wastewater Treatment Under Wastewater Treatment Under Wastewater Treatment Under Wastewater Treatment NE 2 Option 2, Alternative A would Option 2, Alternative B would Option 2, Alternative C would Option 2, Alternative D would Note: NE = No Effect LS = Less than Significant Effect LSM = Less than Significant with Mitigation S = Significant Adverse Effect BE = Beneficial Effect NA = Not Applicable October 2020 36 Little River Band Trust Acquisition and Casino Project Executive Summary Table

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No Resource Alternative A Alternative B Alternative C Alternative D Action not utilize municipal not utilize municipal not utilize municipal not utilize municipal wastewater services. - LS wastewater services. - LS wastewater services. - LS wastewater services. - LS Mitigation NA NA NA NA NA Solid Waste Service The Muskegon Site is located The Muskegon Site is located The Muskegon Site is located The Custer Site is located NE within several solid waste within several solid waste within several solid waste within several solid waste companies’ service areas and companies’ service areas and companies’ service areas and companies’ service areas and it is anticipated that the Tribe it is anticipated that the Tribe it is anticipated that the Tribe it is anticipated that the Tribe would contract with one of would contract with one of would contract with one of would contract with one of these companies for solid these companies for solid these companies for solid these companies for solid waste collection service. waste collection service. waste collection service. waste collection service. Therefore, operation of Therefore, operation of Therefore, operation of Therefore, operation of Alternative A would not result Alternative B would not result Alternative C would not result Alternative D would not result in significant effects to solid in significant effects to solid in significant effects to solid in significant effects to solid waste services or landfill waste services or landfill waste services or landfill waste services or landfill capacities. - LS capacities. - LS capacities. - LS capacities. - LS Mitigation NA NA NA NA NA Law Enforcement Implementation of Alternative Implementation of Alternative Implementation of Alternative Implementation of Alternative NE A would result in an increase B would result in an increase C would result in an increase D would result in an increase in the need for law in the need for law in the need for law in the need for law enforcement. In accordance enforcement. In accordance enforcement. No agreement enforcement. No agreement with Section 2.1 of the MSA, with Section 2.1 of the MSA, with the Township has been with the City of Scottville has municipal services including municipal services including made at this time to provide been made at this time to but not limited to police, fire but not limited to police, fire law enforcement services to provide law enforcement inspection and emergency inspection and emergency the site under Alternative C; services to the site under response, public safety response, public safety however, it is assumed that Alternative D; however, it is dispatch, emergency medical dispatch, emergency medical an agreement similar to the assumed that an agreement and ambulance services and ambulance services MSA provided in Appendix B would be executed prior to would be provided by the would be provided by the would be executed prior to construction of Alternative D. Township and County. - LSM Township and County. - LSM construction of Alternative C. - LSM - LSM Mitigation Implement MM 5.10 (C). Implement MM 5.10 (C) and Implement MM 5.10 (F). Implement MM 5.10 (G). NA MM 5.10 (D). MM 5.10 (D) Note: NE = No Effect LS = Less than Significant Effect LSM = Less than Significant with Mitigation S = Significant Adverse Effect BE = Beneficial Effect NA = Not Applicable October 2020 37 Little River Band Trust Acquisition and Casino Project Executive Summary Table

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No Resource Alternative A Alternative B Alternative C Alternative D Action Pursuant to Section 3.2 of the MSA, the Tribe shall make the following recurring contributions to the Township. 1. The Tribe shall make annual payments to the Township to cover the added personnel, training, and equipment to maintain necessary police and fire service levels. 2. The Tribe shall pay incident-dependent fees, pursuant to Section 3.2 of the MSA, as related to arrests of individuals due to development of the project. 3. The Tribe shall pay a per day charge to the County for the actual use of beds in the County Jail for the use of all prisoners arrested by the Tribe or the Township, pursuant to Section 3.2 of the MSA. Fire Protection and Implementation of Alternative Implementation of Alternative Implementation of Alternative Implementation of Alternative NE Emergency Medical Services A would result in an increase B would result in an increase C would result in an increase D would result in an increase in the need for fire protection in the need for fire protection in the need for fire protection in the need for fire protection and emergency medical and emergency medical and emergency medical and emergency medical services. In accordance with services. In accordance with services. No agreement with services. No agreement with Section 2.1 of the MSA, Section 2.1 of the MSA, the Township has been made the City of Scottville has been municipal services including municipal services including at this time to provide law made at this time to provide but not limited to police, fire but not limited to police, fire enforcement and fire services law enforcement services to inspection and emergency inspection and emergency to the site under Alternative the site under Alternative D; response, public safety response, public safety C; however, it is assumed however, it is assumed that dispatch, emergency medical dispatch, emergency medical that an agreement similar to an agreement would be and ambulance services and ambulance services the MSA provided in executed prior to construction Appendix B would be of Alternative D. - LSM Note: NE = No Effect LS = Less than Significant Effect LSM = Less than Significant with Mitigation S = Significant Adverse Effect BE = Beneficial Effect NA = Not Applicable October 2020 38 Little River Band Trust Acquisition and Casino Project Executive Summary Table

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No Resource Alternative A Alternative B Alternative C Alternative D Action would be provided by the would be provided by the executed prior to construction Township and County. - LSM Township and County. - LSM of Alternative C. - LSM Mitigation Implement MM 5.10 (C) and Implement MM 5.10 (C) and Implement MM 5.10 (F). Implement MM 5.10 (G). NA MM 5.10 (D). MM 5.10 (D). Electricity and Natural Gas Electricity and natural gas Electricity and natural gas Electricity and natural gas Electricity would be provided NE would be provided by would be provided by would be provided by by Consumers Energy. Consumers Energy and DTE Consumers Energy and DTE Consumers Energy and DTE Consumers Energy currently Energy, respectively. Energy, respectively. Energy, respectively. has sufficient capacity to Consumers Energy and DTE Consumers Energy and DTE Consumers Energy and DTE serve Alternative D. Natural Energy currently have Energy currently have Energy currently have gas would be provided by sufficient capacity to serve sufficient capacity to serve sufficient capacity to serve either DTE Gas Company or Alternative A; therefore, Alternative B; therefore, Alternative C; therefore, by on-site propane tanks. Alternative A would not result Alternative B would not result Alternative C would not result Alternative D would not result in significant effects on in significant effects on in significant effects on in significant effects on energy or natural gas energy or natural gas energy or natural gas energy or natural gas services. - LS services. - LS services. - LS services. - LS Mitigation NA NA NA NA NA Noise Construction Noise Alternative A construction Alternative B construction Alternative C construction Alternative D construction NE (Construction Traffic) traffic would result in a 1.72 traffic would result in a 0.94 traffic would result in a 1.48 traffic would result in a 4.37 A-weighted sound level (dBA) dBA Leq increase in the dBA Leq increase in the dBA Leq increase in the equivalent sound level (Leq) existing ambient noise level existing ambient noise level existing ambient noise level increase in the existing which is not an audible which is not an audible which is not an audible ambient noise level which is increase, and thus would not increase, and thus would not increase, and thus would not not an audible increase, and result in a significant adverse result in a significant adverse result in a significant adverse thus would not result in a effect to ambient noise levels effect to ambient noise levels effect to ambient noise levels significant adverse effect to during any phase of during any phase of during any phase of ambient noise levels during construction. - LS construction. - LS construction. - LS any phase of construction. - LS Mitigation NA NA NA NA NA Note: NE = No Effect LS = Less than Significant Effect LSM = Less than Significant with Mitigation S = Significant Adverse Effect BE = Beneficial Effect NA = Not Applicable October 2020 39 Little River Band Trust Acquisition and Casino Project Executive Summary Table

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No Resource Alternative A Alternative B Alternative C Alternative D Action Construction Noise The maximum stationary The maximum stationary The maximum stationary The maximum stationary NE (Construction Equipment) construction noise level for construction noise level for construction noise level for construction noise level for Alternative A at the nearest Alternative B at the nearest Alternative C at the nearest Alternative D at the nearest sensitive noise receptor sensitive noise receptor sensitive noise receptor sensitive noise receptor would be greater than the would be greater than the would be greater than the would be greater than the federal Noise Abatement federal NAC standards used federal NAC standards used federal NAC standards used Criteria (NAC) standards by the FHWA of 72 dBA Leq. by the FHWA of 72 dBA Leq. by the FHWA of 72 dBA Leq. used by the FHWA of 72 dBA - LS - LS - LS Leq. - LS Mitigation NA NA NA NA NA Construction Vibration The predicted vibration levels The predicted vibration levels The predicted vibration levels The predicted vibration levels NE from construction of from construction of from construction of from construction of Alternative A are below the Alternative B are below the Alternative C are below the Alternative D are below the significance threshold for significance threshold for significance threshold for significance threshold for structures at 25 feet and for structures at 25 feet and for structures at 25 feet and for structures at 25 feet and for annoyance of people at 100 annoyance of people at 100 annoyance of people at 100 annoyance of people at 100 feet and would not result in feet and would not result in feet and would not result in feet and would not result in significant adverse significant adverse significant adverse significant adverse effects. - LS effects. - LS effects. - LS effects. - LS Mitigation NA NA NA NA NA Operation Noise (Traffic) Alternative A would increase Alternative B would increase Alternative C would increase With implementation of NE traffic noise, but would not traffic noise, but would not traffic noise, but would not Alternative D, the ambient result in significant adverse result in significant adverse result in significant adverse noise level on East First effects associated with traffic effects associated with traffic effects associated with traffic Street during the peak hour noise levels. - LS noise levels. - LS noise levels. - LS would be 71.5 dBA Leq which is greater than the MDOT threshold of 69.9 dBA Leq for residential sensitive receptors. There are no feasible mitigation measures that could reduce this impact; therefore, increases in operational noise due to increased traffic volumes under Alternative D is Note: NE = No Effect LS = Less than Significant Effect LSM = Less than Significant with Mitigation S = Significant Adverse Effect BE = Beneficial Effect NA = Not Applicable October 2020 40 Little River Band Trust Acquisition and Casino Project Executive Summary Table

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No Resource Alternative A Alternative B Alternative C Alternative D Action considered a significant and unavoidable impact. - S Mitigation NA NA NA None available. NA Operation Noise (Stationary) The noise level generated by The noise level generated by The noise level generated by The noise level generated by NE operation of stationary operation of stationary operation of stationary operation of stationary equipment would not exceed equipment would not exceed equipment would not exceed equipment would not exceed the MDOT standard of 66 the MDOT standard of 66 the MDOT standard of 66 the MDOT standard of 66 dBA and would not result in dBA and would not result in dBA and would not result in dBA and would not result in adverse effects. - LS adverse effects. - LS adverse effects. - LS adverse effects. - LS Mitigation NA NA NA NA NA Operation Vibration The commercial and hotel The commercial uses The commercial uses The commercial uses NE uses proposed under proposed under Alternative B proposed under Alternative C proposed under Alternative D Alternative A do not include do not include sources of do not include sources of do not include sources of sources of perceptible perceptible vibration. perceptible vibration. perceptible vibration. vibration. Therefore, Therefore, operation of Therefore, operation of Therefore, operation of operation of Alternative A Alternative B would not result Alternative C would not result Alternative D would not result would not result in significant in significant adverse effects in significant adverse effects in significant adverse effects adverse effects associated associated with associated with associated with with vibration. - NE vibration. -- NE vibration. - NE vibration. - NE Mitigation NA NA NA NA NA Hazardous Materials Construction There are no reported There are no reported There are no reported There are no reported NE hazardous materials spills, hazardous materials spills, hazardous materials spills, hazardous materials spills, violations, or instances of violations, or instances of violations, or instances of violations, or instances of recorded contamination within recorded contamination within recorded contamination within recorded contamination within the proposed development the proposed development the proposed development the proposed development areas on the Muskegon Site. areas on the Muskegon Site. areas on the Muskegon Site. areas on the Custer Site. Hazardous materials used Hazardous materials used Hazardous materials used Hazardous materials used during construction of during construction of during construction of during construction of Alternative A could pose a Alternative B could pose a Alternative C could pose a Alternative D could pose a risk to human health and/or risk to human health and/or risk to human health and/or risk to human health and/or the environment. Additionally, the environment. Additionally, the environment. Additionally, the environment. Additionally, Note: NE = No Effect LS = Less than Significant Effect LSM = Less than Significant with Mitigation S = Significant Adverse Effect BE = Beneficial Effect NA = Not Applicable October 2020 41 Little River Band Trust Acquisition and Casino Project Executive Summary Table

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No Resource Alternative A Alternative B Alternative C Alternative D Action construction personnel could construction personnel could construction personnel could construction personnel could encounter contamination encounter contamination encounter contamination encounter contamination during earth-moving activities during earth-moving activities during earth-moving activities during earth-moving activities that may pose a risk to that may pose a risk to that may pose a risk to that may pose a risk to human health and/or the human health and/or the human health and/or the human health and/or the environment. - LS environment. - LS environment. - LS environment. - LS Mitigation NA NA NA NA NA Operation Small quantities of hazardous Small quantities of hazardous Small quantities of hazardous Small quantities of hazardous NE materials would be stored, materials would be stored, materials would be stored, materials would be stored, handled, and disposed of handled, and disposed of handled, and disposed of handled, and disposed of during operation of Alternative during operation of Alternative during operation of Alternative during operation of Alternative A; however, adherence to B; however, adherence to C; however ,adherence to D; however, adherence to state, federal, and state, federal, and state, federal, and state, federal, and manufacturer’s guidelines manufacturer’s guidelines manufacturer’s guidelines manufacturer’s guidelines would prevent impacts from would prevent impacts from would prevent impacts from would prevent impacts from use of these materials to the use of these materials to the use of these materials to the use of these materials to the public or the environment. - public or the environment. - public or the environment. - public or the environment. - LS LS LS LS Mitigation NA NA NA NA NA Aesthetics Construction Aesthetic-related impacts Aesthetic-related impacts Aesthetic-related impacts Aesthetic-related impacts NE from construction of from construction of from construction of from construction of Alternative A would be Alternative B would be Alternative C would be Alternative D would be temporary in nature and temporary in nature and temporary in nature and temporary in nature and would not result in obstructed would not result in obstructed would not result in obstructed would not result in obstructed views of scenic resources. - views of scenic resources. - views of scenic resources. - views of scenic resources. - LS LS LS LS Mitigation NA NA NA NA NA Operation (Viewsheds) The development of The development of The development of The development of NE Alternative A on the Alternative B on the Alternative C on the Alternative D on the Custer Muskegon Site would not be Muskegon Site would not be Muskegon Site would not be Site would be visually visually incompatible with visually incompatible with visually incompatible with incompatible with the Note: NE = No Effect LS = Less than Significant Effect LSM = Less than Significant with Mitigation S = Significant Adverse Effect BE = Beneficial Effect NA = Not Applicable October 2020 42 Little River Band Trust Acquisition and Casino Project Executive Summary Table

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No Resource Alternative A Alternative B Alternative C Alternative D Action land uses currently existing in land uses currently existing in land uses currently existing in agricultural and rural the immediate vicinity. The the immediate vicinity. The the immediate vicinity. The residential land uses currently context of the project context of the project context of the project onsite and in the immediate development in relation to the development in relation to the development in relation to the vicinity, with no available larger landscape would be larger landscape would be larger landscape would be mitigation. - S less than significant since the less than significant since the less than significant since the changes would not affect any changes would not affect any changes would not affect any significant visual resources. - significant visual resources. - significant visual resources. - LS LS LS Mitigation NA NA NA None available. NA Operation (Shadow, Light, Alternative A would introduce Alternative B would introduce Alternative C would introduce Alternative D would introduce NE and Glare) new sources of light into the new sources of light into the new sources of light into the new sources of light into the existing setting. Light spillover existing setting. Light spillover existing setting. Light spillover existing setting. Light spillover into surrounding areas and into surrounding areas and into surrounding areas and into surrounding areas and increases in regional ambient increases in regional ambient increases in regional ambient increases in regional ambient illumination could result in illumination could result in illumination could result in illumination could result in potentially significant adverse potentially significant adverse potentially significant adverse potentially significant adverse effects. Additionally, the use effects. - LS effects. - LS effects. - LS of glass panels and reflective ornamental detailing in the project design, including the proposed hotel, could increase the glare to aircraft operations, travelers on I-96, and adjacent residences. - LS Mitigation NA NA NA NA NA Indirect Effects From Off-site Traffic No significant indirect effects No significant indirect effects No significant indirect effects Alternative D would not NE Mitigation to any resource area are to any resource area are to any resource area are require any off-site traffic expected to occur as a result expected to occur as a result expected to occur as a result mitigation. of off-site traffic mitigation of off-site traffic mitigation of off-site traffic mitigation under Alternative A. - LSM under Alternative B. - LSM under Alternative C. - LSM Note: NE = No Effect LS = Less than Significant Effect LSM = Less than Significant with Mitigation S = Significant Adverse Effect BE = Beneficial Effect NA = Not Applicable October 2020 43 Little River Band Trust Acquisition and Casino Project Executive Summary Table

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No Resource Alternative A Alternative B Alternative C Alternative D Action Mitigation Implement mitigation Implement mitigation Implement mitigation NA NA measures for each resource measures for each resource measures for each resource as listed in above sections. as listed in above sections. as listed in above sections. From Water Infrastructure No significant indirect effects No significant indirect effects No significant indirect effects No significant indirect effects NE Improvements. to any resource area are to any resource area are to any resource area are to any resource area are expected to occur as a result expected to occur as a result expected to occur as a result expected to occur as a result of water infrastructure of water infrastructure of water infrastructure of water infrastructure improvements under improvements under improvements under improvements under Alternative A. - LSM Alternative B. - LSM Alternative C. - LSM Alternative D. - LSM Mitigation Implement mitigation Implement mitigation Implement mitigation Implement mitigation NA measures for each resource measures for each resource measures for each resource measures for each resource as listed in above sections. as listed in above sections. as listed in above sections. as listed in above sections. From Wastewater Alternative A would not Alternative B would not Alternative C would not No significant indirect effects NE Infrastructure Improvements. require any off-site require any off-site require any off-site to any resource area are wastewater infrastructure wastewater infrastructure wastewater infrastructure expected to occur as a result improvements. improvements. improvements. of wastewater infrastructure improvements under Alternative D. - LSM Mitigation NA NA NA Implement mitigation NA measures for each resource as listed in above sections. From Gas Infrastructure Alternative A would not Alternative B would not Alternative C would not No significant indirect effects NE Improvements. require any off-site gas require any off-site gas require any off-site gas to any resource area are infrastructure improvements. infrastructure improvements. infrastructure improvements. expected to occur as a result of gas infrastructure improvements under Alternative D. - LSM Mitigation NA NA NA Implement mitigation NA measures for each resource as listed in above sections. Growth-Inducing Effects The minimal amount of The minimal amount of The minimal amount of The minimal amount of NE commercial growth that may commercial growth that may commercial growth that may commercial growth that may Note: NE = No Effect LS = Less than Significant Effect LSM = Less than Significant with Mitigation S = Significant Adverse Effect BE = Beneficial Effect NA = Not Applicable October 2020 44 Little River Band Trust Acquisition and Casino Project Executive Summary Table

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No Resource Alternative A Alternative B Alternative C Alternative D Action be induced by Alternative A is be induced by Alternative B is be induced by Alternative C is be induced by Alternative D is not expected to result in not expected to result in not expected to result in not expected to result in significant adverse significant adverse significant adverse significant adverse environmental effects. - LS environmental effects. - LS environmental effects. - LS environmental effects. - LS Mitigation NA NA NA NA NA Cumulative Effects Geology and Soils All other developments that All other developments that All other developments that All other developments that NE disturb 1 acre or more must disturb 1 acre or more must disturb 1 acre or more must disturb 1 acre or more must comply with the requirements comply with the requirements comply with the requirements comply with the requirements of the NPDES Construction of the NPDES Construction of the NPDES Construction of the NPDES Construction General Permit, which General Permit, which General Permit, which General Permit, which requires BMPs be chosen requires BMPs be chosen requires BMPs be chosen requires BMPs be chosen and implemented to address and implemented to address and implemented to address and implemented to address water quality degradation by water quality degradation by water quality degradation by water quality degradation by preventing erosion. With the preventing erosion. With the preventing erosion. With the preventing erosion. With the implementation of mitigation implementation of mitigation implementation of mitigation implementation of mitigation measures listed above, measures listed above, measures listed above, measures listed above, Alternative A would not result Alternative B would not result Alternative C would not result Alternative D would not result in significant adverse in significant adverse in significant adverse in significant adverse cumulative effects to geology cumulative effects to geology cumulative effects to geology cumulative effects to geology or soils. - LSM or soils. – LSM or soils. – LSM or soils. – LSM Implement mitigation Implement mitigation Implement mitigation Implement mitigation measures for each resource measures for each resource measures for each resource measures for each resource as listed in above sections. as listed in above sections. as listed in above sections. as listed in above sections. Water Resources Development of Alternative A Development of Alternative B Development of Alternative C Development of Alternative D NE would include erosion control would include erosion control would include erosion control would include erosion control measures in compliance with measures in compliance with measures in compliance with measures in compliance with the NPDES permit program the NPDES permit program the NPDES permit program the NPDES permit program and Michigan Department of and MDEQ regulations. In and MDEQ regulations. In and MDEQ regulations. In Environmental Quality addition, Alternative B would addition, Alternative C would addition, Alternative D would (MDEQ) regulations. In treat all stormwater o site, treat all stormwater onsite, treat all stormwater onsite, addition, Alternative A would consistent with current consistent with current consistent with current treat all stormwater onsite, conditions, and would not conditions, and would not conditions, and would not consistent with current contribute to non-point source contribute to non-point source contribute to non-point source conditions, and would not pollution. Therefore, pollution. Therefore, pollution. Therefore, Note: NE = No Effect LS = Less than Significant Effect LSM = Less than Significant with Mitigation S = Significant Adverse Effect BE = Beneficial Effect NA = Not Applicable October 2020 45 Little River Band Trust Acquisition and Casino Project Executive Summary Table

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No Resource Alternative A Alternative B Alternative C Alternative D Action contribute to non-point source implementation of Alternative implementation of Alternative implementation of Alternative pollution. Therefore, B would not result in C would not result in D would not result in implementation of Alternative significant cumulative effects significant cumulative effects significant cumulative effects A would not result in to stormwater. to stormwater. to stormwater. significant cumulative effects Alternative B would not result Alternative C would not result Alternative D would not result to stormwater. in significant adverse in significant adverse in significant adverse Alternative A would not result cumulative effects on cumulative effects on cumulative effects on in significant adverse groundwater resources. – groundwater resources. – groundwater resources. – cumulative effects on LSM LSM LSM groundwater resources. – Implement mitigation Implement mitigation Implement mitigation LSM measures for each resource measures for each resource measures for each resource Implement mitigation as listed in above sections. as listed in above sections. as listed in above sections. measures for each resource as listed in above sections. Air Quality Alternative A would not Alternative B would not Alternative C would not Alternative D would not NE contribute to an adverse contribute to an adverse contribute to an adverse contribute to an adverse cumulative effect to air cumulative effect to air cumulative effect to air cumulative effect to air quality. quality. quality. quality. After the implementation of After the implementation of After the implementation of No intersections affected by recommended mitigation for recommended mitigation for recommended mitigation for Alternative D would have an Alternative A, no intersection Alternative B, no intersection Alternative C, no intersection LOS or an increase in delay would have an LOS or an would have an LOS or an would have an LOS or an in the cumulative year 2040 increase in delay in the increase in delay in the increase in delay in the that would warrant a carbon cumulative year 2040 that cumulative year 2040 that cumulative year 2040 that monoxide Hot Spot Analysis. would warrant a carbon would warrant a carbon would warrant a carbon Development of Alternative D monoxide Hot Spot Analysis. monoxide Hot Spot Analysis. monoxide Hot Spot Analysis. would result in an increase in Development of Alternative A Development of Alternative B Development of Alternative C CO2e emissions. Therefore, would result in an increase in would result in an increase in would result in an increase in Alternative D would not result CO2e emissions. BMPs CO2e emissions. BMPs CO2e emissions. Therefore, in a significant adverse effect provided in Section 2.3.3 provided in Section 2.3.3 and Alternative C would not result associated with cumulative would ensure compliance with the mtigation measures listed in a significant adverse effect CO2e emissions and climate applicable CO2e reduction above would ensure associated with cumulative change. - LS strategies; therefore, compliance with applicable CO2e emissions and climate Alternative A would not result CO2e reduction strategies; change. - LS in a significant adverse effect therefore, Alternative B would associated with cumulative not result in a significant adverse effect associated with cumulative CO2e Note: NE = No Effect LS = Less than Significant Effect LSM = Less than Significant with Mitigation S = Significant Adverse Effect BE = Beneficial Effect NA = Not Applicable October 2020 46 Little River Band Trust Acquisition and Casino Project Executive Summary Table

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No Resource Alternative A Alternative B Alternative C Alternative D Action CO2e emissions and climate emissions and climate change. - LS change. - LS Biological Resources With the implementation of With the implementation of With the implementation of With the implementation of NE mitigation measures mitigation measures mitigation measures mitigation measures discussed above, Alternative discussed above, Alternative discussed above, Alternative discussed above, Alternative A would not result in B would not result in C would not result in D would not result in cumulative effects to habitat, cumulative effects to habitat, cumulative effects to habitat, cumulative effects to habitat, federally listed species, federally listed species, federally listed species, federally listed species, migratory birds, or potential migratory birds, or potential migratory birds, or potential migratory birds, or potential Waters of the U.S. - LSM Waters of the U.S. – LSM Waters of the U.S. – LSM Waters of the U.S. – LSM Implement mitigation Implement mitigation Implement mitigation Implement mitigation measures for each resource measures for each resource measures for each resource measures for each resource as listed in above sections. as listed in above sections. as listed in above sections. as listed in above sections. Cultural Resources Cultural resources are Cultural resources are Cultural resources are Cultural resources are NE afforded substantial afforded substantial afforded substantial afforded substantial protection through federal and protection through federal and protection through federal and protection through federal and state regulations and county state regulations and county state regulations and county state regulations and county historic preservation historic preservation historic preservation historic preservation guidance. Because guidance. Because guidance. Because guidance. Because Alternative A would not Alternative B would not Alternative C would not Alternative D would not impact cultural resources, it impact cultural resources, it impact cultural resources, it impact cultural resources, it would not contribute towards would not contribute towards would not contribute towards would not contribute towards potential adverse cumulative potential adverse cumulative potential adverse cumulative potential adverse cumulative effects. – LSM effects. – LSM effects. – LSM effects. – LSM Implement mitigation Implement mitigation Implement mitigation Implement mitigation measures for each resource measures for each resource measures for each resource measures for each resource as listed in above sections. as listed in above sections. as listed in above sections. as listed in above sections. Socioeconomic Conditions Planning documents for the Planning documents for the Planning documents for the Alternative D’s specific NE Township and Muskegon Township and Muskegon Township and Muskegon cumulative effects would be County would continue to County would continue to County would continue to similar to those of Alternative designate land uses for designate land uses for designate land uses for A, though the effects would businesses, industry, and businesses, industry, and businesses, industry, and accrue in Mason County housing, as well as plan housing, as well as plan housing, as well as plan rather than Muskegon County public services for anticipated public services for anticipated public services for anticipated and would be significantly growth in the region. Further, growth in the region. Further, growth in the region. Further, less because of the reduced potential socioeconomic potential socioeconomic potential socioeconomic size of the casino. Therefore, Note: NE = No Effect LS = Less than Significant Effect LSM = Less than Significant with Mitigation S = Significant Adverse Effect BE = Beneficial Effect NA = Not Applicable October 2020 47 Little River Band Trust Acquisition and Casino Project Executive Summary Table

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No Resource Alternative A Alternative B Alternative C Alternative D Action effects of Alternative A would effects of Alternative B would effects of Alternative C would Alternative D would not be lessened through BMPs be lessened through BMPs be lessened through BMPs contribute to significant provided in Section 2.3.3 and provided in Section 2.3.3 and provided in Section 2.3.3 adverse cumulative implementation of the implementation of the and. Therefore, Alternative C socioeconomic effects. - LS mitigation measures listed mitigation measures listed would not contribute to above. Therefore, Alternative above. Therefore, Alternative significant adverse cumulative A would not contribute to B would not contribute to socioeconomic effects. - LS significant adverse cumulative significant adverse cumulative socioeconomic effects. – LSM socioeconomic effects. – LSM Implement mitigation Implement mitigation measures for each resource measures for each resource as listed in above sections. as listed in above sections. Transportation The increase in traffic The increase in traffic The increase in traffic The increase in traffic NE generated by buildout of generated by buildout of generated by buildout of generated by buildout of Alternative A in cumulative Alternative B would contribute Alternative C would contribute Alternative D would not year 2040 would contribute to to unacceptable traffic to unacceptable traffic contribute to unacceptable unacceptable traffic operations at the study operations at the study traffic operations at the study operations at the study intersections and roadway intersections and roadway intersections. All would intersections and roadway segments below, causing segments below, causing continue to operate at LOS D segments below, causing them to operate below them to operate below or better standards. - LS them to operate below acceptable LOS standards. acceptable LOS standards. acceptable LOS standards.  Harvey Street and Hile  Harvey Street and Hile  Harvey Street and Hile Road Road Road  Harvey Street and  Harvey Street and  Harvey Street and Independence Drive Independence Drive Independence Drive  Harvey Street and  Harvey Street and  Harvey Street and Sternberg Road Sternberg Road Sternberg Road  Harvey Street and  Harvey Street and  Harvey Street and Pontaluna Road Pontaluna Road Pontaluna Road  WB I-96 Off-Ramp and  WB I-96 Off-Ramp and  WB I-96 Off-Ramp and Airline Highway Airline Highway Airline Highway  East Lake Road approach  SB US-31 Off-Ramp and  East Lake Road approach at WB I-96 Off-Ramp and Airline Highway at WB I-96 Off-Ramp and Airline Highway  EB I-96 Off-Ramp and Hile Airline Highway  SB US-31 Off-Ramp and Road  SB US-31 Off-Ramp and Airline Highway Airline Highway Note: NE = No Effect LS = Less than Significant Effect LSM = Less than Significant with Mitigation S = Significant Adverse Effect BE = Beneficial Effect NA = Not Applicable October 2020 48 Little River Band Trust Acquisition and Casino Project Executive Summary Table

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No Resource Alternative A Alternative B Alternative C Alternative D Action  EB I-96 Off-Ramp and Hile  EB I-96 Off-Ramp and Hile  NB US-31 Off-Ramp and Road Road Sternberg Road  NB US-31 Off-Ramp and  NB US-31 Off-Ramp and  Pontaluna Road and NB Sternberg Road Sternberg Road US-31 Ramps  Pontaluna Road and NB  Pontaluna Road and NB  SB US-31 Off-Ramp and US-31 Ramps US-31 Ramps Pontaluna Road  SB US-31 Off-Ramp and  SB US-31 Off-Ramp and  Casino site driveway and Pontaluna Road Pontaluna Road Harvey Street  Casino site driveway and  NB and SB Harvey Street  NB Harvey Street between Harvey Street between Hile Road and Hile Road and East Ellis  NB and SB Harvey Street East Ellis Road Road between Hile Road and - LSM - LSM East Ellis Road Implement mitigation Implement mitigation - LSM measures for each resource measures for each resource Implement mitigation as listed in above sections. as listed in above sections. measures for each resource as listed in above sections. Land Use With the mitigation above, With the mitigation listed With the mitigation above, With the mitigation listed NE Alternative A would not above, Alternative B would Alternative C would not above, Alternative D would disrupt neighboring land uses, not disrupt neighboring land disrupt neighboring land uses, not disrupt neighboring land prohibit access to neighboring uses, prohibit access to prohibit access to neighboring uses, prohibit access to parcels, or otherwise conflict neighboring parcels, or parcels, or otherwise conflict neighboring parcels, or with neighboring land uses. otherwise conflict with with neighboring land uses. otherwise conflict with Alternative A would not neighboring land uses. Alternative C would not neighboring land uses. convert designated Alternative B would not convert designated Alternative D would not agricultural land to urban convert designated agricultural land to urban convert designated uses, and thus would not agricultural land to urban uses, and thus would not agricultural land to urban contribute to adverse uses, and thus would not contribute to adverse uses, and thus would not cumulative effects to contribute to adverse cumulative effects to contribute to adverse agricultural lands. - LS cumulative effects to agricultural lands. - LS cumulative effects to agricultural lands. - LS agricultural lands. - LS Public Services Approved projects would be Approved projects would be Approved projects would be Approved projects would be NE required to follow the local required to follow the local required to follow the local required to follow the local plans and policies regarding plans and policies regarding plans and policies regarding plans and policies regarding public services and would public services and would public services and would public services and would have to pay connection and have to pay connection and have to pay connection and have to pay connection and Note: NE = No Effect LS = Less than Significant Effect LSM = Less than Significant with Mitigation S = Significant Adverse Effect BE = Beneficial Effect NA = Not Applicable October 2020 49 Little River Band Trust Acquisition and Casino Project Executive Summary Table

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No Resource Alternative A Alternative B Alternative C Alternative D Action monthly fees as appropriate. monthly fees as appropriate. monthly fees as appropriate. monthly fees as appropriate. With the implementation of With the implementation of With the implementation of With the implementation of mitigation measures listed mitigation measures listed the conditions of an the conditions of an above, Alternative A would above, Alternative B would agreement with the Township agreement with the City of not result in cumulative not result in cumulative of Fruitport, Alternative C Scottville, Alternative D would adverse effects associated adverse effects associated would not result in cumulative not result in cumulative with public services. - LSM with public services. - LSM adverse effects associated adverse effects associated Implement mitigation Implement mitigation with public services. - LSM with public services. – LSM measures for each resource measures for each resource Implement mitigation Implement mitigation as listed in above sections. as listed in above sections. measures for each resource measures for each resource as listed in above sections. as listed in above sections. Noise In the cumulative year 2040, In the cumulative year 2040, In the cumulative year 2040, Cumulative noise impacts due NE traffic volumes would traffic volumes would traffic volumes would to Alternative D in addition to increase, but would not result increase, but would not result increase, but would not result background growth rates in significant adverse in significant adverse in significant adverse would result in ambient noise cumulative effects to sensitive cumulative effects to sensitive cumulative effects to sensitive levels above the FHWA receptors. - LS receptors. - LS receptors. - LS threshold of 67 dBA Leq for residential noise receptors. There are no feasible mitigation measures that could reduce this impact; therefore, increases in operational noise due to increased traffic volumes under Alternative D is considered a significant and unavoidable cumulative impact. - S Hazardous Materials Approved projects would be Approved projects would be Approved projects would be Approved projects would be NE required to follow applicable required to follow applicable required to follow applicable required to follow applicable federal and state regulations federal and state regulations federal and state regulations federal and state regulations concerning hazardous concerning hazardous concerning hazardous concerning hazardous materials management materials management materials management materials management through the NPDES through the NPDES through the NPDES through the NPDES permitting process. With the permitting process. With the permitting process. With the permitting process. With the implementation of BMPs implementation of BMPs implementation of BMPs implementation of BMPs provided in Section 2.3.3, provided in Section 2.3.3, provided in Section 2.3.3, provided in Section 2.3.3, Note: NE = No Effect LS = Less than Significant Effect LSM = Less than Significant with Mitigation S = Significant Adverse Effect BE = Beneficial Effect NA = Not Applicable October 2020 50 Little River Band Trust Acquisition and Casino Project Executive Summary Table

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No Resource Alternative A Alternative B Alternative C Alternative D Action Alternative A would not result Alternative B would not result Alternative C would not result Alternative D would not result in cumulative adverse effects in cumulative adverse effects in cumulative adverse effects in cumulative adverse effects associated with hazardous associated with hazardous associated with hazardous associated with hazardous materials. - LS materials. - LS materials. - LS materials. - LS Aesthetics While development on the While development on the While development on the Development on the site NE site would represent a shift site would represent a shift site would represent a shift would represent a shift from from open space to from open space to from open space to open space to commercial commercial development, it commercial development, it commercial development, it development and would be would be visually compatible would be visually compatible would be visually compatible visually incompatible with with urban land uses in the with urban land uses in the with urban land uses in the rural land uses in the project project vicinity. Alternative A project vicinity. Alternative B project vicinity. Alternative C vicinity. Potential cumulative would not result in cumulative would not result in cumulative would not result in cumulative effects to visual resources adverse effects associated adverse effects associated adverse effects associated would be significant, with no with visual resources. - LS with visual resources. - LS with visual resources. - LS available mitigation. - S Note: NE = No Effect LS = Less than Significant Effect LSM = Less than Significant with Mitigation S = Significant Adverse Effect BE = Beneficial Effect NA = Not Applicable October 2020 51 Little River Band Trust Acquisition and Casino Project Executive Summary Table

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APPENDIX W FIGURES

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Figure 2-1. Regional Location ...................................................................................................................... 1 Figure 2-2. Site and Vicinity – Muskegon Site ............................................................................................. 2 Figure 2-3. Aerial Photograph – Muskegon Site .......................................................................................... 3 Figure 2-4. Site and Vicinity - Custer Site .................................................................................................... 4 Figure 2-5. Alternative A - Proposed Project Site Plan ................................................................................ 5 Figure 2-6. Alternative A - Architectural Rendering .................................................................................... 6 Figure 2-7. Alternative A – Grading and Drainage Plan .............................................................................. 7 Figure 2-8. Alternative B – Reduced Intensity Alternative Site Plan ........................................................... 8 Figure 2-9. Alternative B – Grading and Drainage Plan ............................................................................... 9 Figure 2-10. Alternative C - Non-Gaming Site Plan................................................................................... 10 Figure 2-11. Alternative C – Grading and Drainage Plan ........................................................................... 11 Figure 2-12. Alternative D – Custer Site Site Plan ..................................................................................... 12 Figure 2-13. Alternative D – Grading and Drainage Plan .......................................................................... 13 Figure 3.2-1. Soil Types – Muskegon Site.................................................................................................. 14 Figure 3.2-2. Soil Types – Custer Site ........................................................................................................ 15 Figure 3.3-1. Muskegon Site Watersheds ................................................................................................... 16 Figure 3.3-2. Custer Site Watershed ........................................................................................................... 17 Figure 3.5-1. Habitat Types - Muskegon Site ............................................................................................. 18 Figure 3.5-2a. Site Photographs - Muskegon Site ...................................................................................... 19 Figure 3.5-2b. Site Photographs - Muskegon Site ...................................................................................... 20 Figure 3.5-3. Habitat Types - Custer Site ................................................................................................... 21 Figure 3.5-4. Site Photographs - Custer Site............................................................................................... 22 Figure 3.7-1. Census Tracts – Muskegon Site ............................................................................................ 23 Figure 3.7-2. Census Tracts – Custer Site................................................................................................... 24 Figure 3.8-1a. Muskegon Site Study Intersections - Lane Use and Traffic Control ................................... 25 Figure 3.8-1b. Muskegon Site Study Intersections - Lane Use and Traffic Control................................... 26 Figure 3.8-2. Custer Site Lane Use and Traffic Control ............................................................................. 27 Figure 3.9-1. Fruitport Township Zoning Map ........................................................................................... 28 Figure 3.9-2. Custer Township Zoning Map............................................................................................... 29 Figure 3.11-1. Noise Monitoring Locations – Muskegon Site.................................................................... 30 Figure 3.11-2. Noise Monitoring Locations - Custer Site ........................................................................... 31 Figure 3.13-1. Muskegon Site Viewpoints ................................................................................................. 32 Figure 3.13-2. Muskegon Site Photographs ................................................................................................ 33 Figure 3.13-3. Custer Site Viewpoints ........................................................................................................ 34 Figure 3.13-4. Custer Site Photographs ...................................................................................................... 35 Figure 4.13-1. Architectural Rendering – Alternative A from Harvey Street............................................. 36 Figure 4.13-2. Architectural Rendering – Alternative B from I-96 ............................................................ 37 Figure 4.13-3. Architectural Rendering – Alternative C............................................................................. 38 Figure 4.13-4. Architectural Rendering – Alternative D ............................................................................ 39 Figure 4.14-1. Offsite Mitigation Locations – Muskegon Site ................................................................... 41 Figure 4.14-2. Alternative D Off-Site Improvements ................................................................................. 42 October 2020 i Little River Band Trust Acquisition and Casino Project Appendix W

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22 V U 131 £ ¤ 37 V U 131 £ ¤ 66 V U 42 U V Existing Manistee Little River County Casino Resort Wexford 115 V U County 55 V U _ ^ 131 £ ¤ 55 V U Manistee " ) County Mason " ) County Muskegon " ) County 115 U V 37 V U 31 SCALE Mason £ ¤ 131 County Lake £ ¤ Miles Custer County 10 £ ¤ " 0 6 12 31 £ ¤ Osceola Custer Site County 37 U V 66 V U Oceana LA County KE Mecosta County MI Newaygo 20 U V CH 20 V U County IG AN 131 £ ¤ 31 £ ¤ 82 V U 46 U V 82 V U 91 V U Montcalm County Muskegon County Muskegon 46 V U Site Kent 57 County V U 57 U V 31 £ ¤ Ottawa 44 V U Ionia County § ¦ ¨ 96 37 V U County Little River Band of Ottawa Indians Final EIS / 208526 SOURCE:National Geographic, 2015; AES, 12/17/2019 Figure 2-1 Regional Location

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SCALE Fe et ! ¢ Ð N OR TH 0 1 ,000 2 ,000 § ¦ ¨96 Bexley Dr E. Hile Rd E. Hile Rd Musk e gon S i te E. Ellis Rd E. Ellis Rd Ai rli ne Pro po sedFe e-to - Trust Pro pe rty E. Sternberg Rd § ¦ ¨ 96 S. Sheridan Rd S. Harvey St Quarterline Rd £ ¤ 31 Little River Band of Ottawa Indians Final EIS / 208526 S OU RCE:"Musk eg o n Ea st,MI ” U S GS 7 .5Min uteTo po gra phicQu adra n gle , T9N,R16 ES RIDa W,S e ta,20 cti 13; o n s 15a AES ,12 n d22, /17/201 Mi 9 chiga n Ba se li n e& Me ri dia n; Figure 2-2 Si tea n dVi cini ty -Musk e gon S i te

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LEGEND Muskegon Site Proposed Fee-to-Trust Property Parcel Boundaries Feet ! ¢ Ð N OR TH 0 340 680 E. Hile E. Hile Rd Rd E. Hile E. Hile Rd Rd § ¦ ¨96 Dr Bexley Dr Bexley Ai rli ne 15-115-300-0011-10 15-115-300-0026-00 E. Ellis E. Ellis Rd Rd S. Harvey S. St Harvey St Little River Band of Ottawa Indians Final EIS / 208526 SOURCE: USDA aerial photograph, 7/21/2014; Muskegon County Parcels, 2013; AES, 12/17/2019 Figure 2-3 Aerial Photograph - Muskegon Site

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SCALE Feet ! ¢ ÐN OR TH 0 1 ,000 2 ,000 10 £ ¤ Little River Band Custer Site Trust Land Little River Band of Ottawa Indians Final EIS / 208526 SOU RCE:"Sco ttvil le,MI”& "Cus ter, MI ”U SGS7 . 5MinuteTo p o gra p hi cQua dra ngl es , T18N,R16W ,Sec ti ons21& 22,Mi chiga nBa s el ine& Meri dia n; AES, 12/17/ 2019 Figure 2-4 Si tea ndVi cini ty-Cus ter Si te

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SCALE NO RTH 0 150’ 300’ WATER FEATURE / DETENTION Muskegon Site MAIN ENTRY I-96 PARKING GARAGE SURFACE PARKING Proposed Fee-to-Trust ATRIUM Property CASINO PORTE- MULTI- COCHERE HARVEY ST PURPOSE CENTER (13,000 SF) HOTEL PORTE-COCHERE CASINO H OTEL POOL EMPLOYEE PARKING ATRIUM BOH / ADMIN SERVICE EMPLOYEE PARKING DOCK E. ELLIS RD SERVICE ROAD Little River Band of Ottawa Indians Final EIS / 208526 SOURCE: HBG, 2015; AES, 8/23/2019 Figure 2-5 Alternative A – Proposed Project Site Plan

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Little River Band of Ottawa Indians Final EIS / 208526 SOURCE: HBG, 2015; AES, 8/23/2019 Figure 2-6 Alternative A - Architectural Rendering

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SCALE NO RTH 0 150’ 300’ NO WATER FEATURE / DETENTION 631.5 630.5 631.5 630.5 0 631.0 63 630.5 Muskegon Site 630 629.5 628.0 630.0 631.0 632.0 629.0 MAIN ENTRY 629.0 I-96 IN 0 63 TE RS PARKING TA TE 632.5 GARAGE 96 SURFACE 629.0 632.0 PARKING 63 0 631.0 627.0 ATRIUM 631.0 FF 633.50 629.0 629.0 Proposed 632.5 633.0 63 0 628.0 Fee-to-Trust 63 0 CASINO Property 631.0 PORTE- 632.0 632.5 MULTI- COCHERE 633.0 631.5 HARVEY ST 628.0 PURPOSE 631.0 CENTER 629.0 (13,000 SF) FF 633.50 633.0 HOTEL PORTE-COCHERE 632.5 633.0 633.0 CASINO L FF 633.50 HOTE 632.0 630.0 633.0 FF 633.50 POOL EMPLOYEE PARKING 630 635 ATRIUM 631.0 FF 633.50 BOH / ADMIN 632.5 632.5 0 63 FF 633.50 633.0 631.0 633.0 SERVICE 630.5 EMPLOYEE 632.0 PARKING 632.5 632.5 632.0 631.0 DOCK 631.0 630.5 E. ELLIS RD SERVICE ROAD Little River Band of Ottawa Indians Final EIS / 208526 SOURCE: Fleis & Vandenbrink, 2015; AES, 8/23/2019 Figure 2-7 Alternative A – Grading and Drainage Plan

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SCALE NO R TH 0 150’ 300’ WATER FEATURE / DETENTION Muskegon Site MAIN ENTRY I-96 PARKING GARAGE SURFACE PARKING Proposed Fee-to-Trust CASINO Property PORTE- COCHERE HARVEY ST CASINO EMPLOYEE PARKING BOH / ADMIN SERVICE EMPLOYEE PARKING DOCK E. ELLIS RD SERVICE ROAD Little River Band of Ottawa Indians Final EIS / 208526 SOURCE: HBG, 2015; AES, 8/23/2019 Figure 2-8 Alternative B – Reduced Intensity Alternative Site Plan

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SCALE NO RTH 0 150’ 300’ NO WATER FEATURE / DETENTION 631.5 630.5 631.5 630.5 0 631.0 63 630.5 Muskegon Site 630 629.5 628.0 630.0 631.0 632.0 629.0 MAIN ENTRY 629.0 I-96 IN 0 63 TE RS PARKING TA TE 632.5 GARAGE 96 SURFACE 629.0 632.0 631.0 PARKING 63 0 627.0 ATRIUM 631.0 631.0 629.0 629.0 Proposed 632.5 633.0 63 0 628.0 Fee-to-Trust 63 0 CASINO Property 631.0 PORTE- 632.0 632.5 MULTI- COCHERE 633.0 631.5 HARVEY ST 628.0 PURPOSE 631.0 CENTER 629.0 (13,000 SF) 633.0 HOTEL PORTE-COCHERE 632.5 633.0 633.0 CASINO L FF 633.50 HOTE 632.0 630.0 633.0 POOL EMPLOYEE PARKING 630 635 ATRIUM 631.0 BOH / ADMIN 632.5 632.5 0 63 FF 633.50 631.0 633.0 SERVICE 630.5 EMPLOYEE 632.0 PARKING 632.5 632.5 632.0 631.0 DOCK 631.0 630.5 E. ELLIS RD SERVICE ROAD Little River Band of Ottawa Indians Final EIS / 208526 SOURCE: Fleis & Vandenbrink, 2015; AES, 8/23/2019 Figure 2-9 Alternative B – Grading and Drainage Plan

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SCALE NO RTH 0 150’ 300’ WATER FEATURE / DETENTION Muskegon Site MAIN ENTRY I-96 SURFACE PARKING Proposed Fee-to-Trust Property HARVEY ST RETAIL / F&B EMPLOYEE PARKING & SERVICE DOCKS E. ELLIS RD SERVICE ROAD Little River Band of Ottawa Indians Final EIS / 208526 SOURCE: HBG, 2015; AES, 8/23/2019 Figure 2-10 Alternative C – Non-Gaming Site Plan

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SCALE NO RTH 0 150’ 300’ NO WATER FEATURE / DETENTION 631.5 630.5 631.5 630.5 0 631.0 63 630.5 Muskegon Site 630 629.5 628.0 630.0 631.0 629.0 MAIN ENTRY 629.0 I-96 IN 0 63 TE RS PARKING TA TE GARAGE 96 SURFACE 629.0 632.0 631.0 PARKING 63 0 ATRIUM 631.0 629.0 629.0 Proposed 631.0 63 0 628.0 Fee-to-Trust 633.0 63 0 CASINO Property PORTE-633.0 632.0 632.5 MULTI- COCHERE 631.5 HARVEY ST 628.0 PURPOSE 631.0 CENTER 633.0 629.0 (13,000 SF) FF 633.50 HOTEL PORTE-COCHERE CASINO L HOTE 632.0 630.0 POOL EMPLOYEE PARKING 635 ATRIUM BOH / ADMIN 632.5 0 63 SERVICE EMPLOYEE PARKING DOCK E. ELLIS RD SERVICE ROAD Little River Band of Ottawa Indians Final EIS / 208526 SOURCE: Fleis & Vandenbrink, 2015; AES, 8/23/2019 Figure 2-11 Alternative C – Grading and Drainage Plan

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30’ EASEMENT Little River Trust Land MAIN ENTRY E. 1ST ST GUEST PARKING Custer Site PORTE-COCHERE EMPLOYEE PARKING GUEST PARKING CASINO (CLUB) SERVICE DRIVE / DOCK SCALE NORT H 0 125’ 250’ Little River Band of Ottawa Indians Final EIS / 208526 SOURCE: HBG, 2015; AES, 8/23/2019 Figure 2-12 Alternative D – Custer Site Site Plan

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Little River Trust Land E. 1st STREET 652.0 651.0 650.0 651.5 651.5 651.5 652.0 652.0 652.0 652.0 652.2 652.5 650.0 651.0 649.5 649.5 649.5 651.0 649.5 648.0 0 65 648.0 651.0 651.0 651.0 651.0 651.0 651.0 652.0 649.0 649.0 652.0 652.0 649.0 651.0 651.5 651.5 651.0 FF 652.50 652.0 648.0 Custer Site SCALE N O R TH 0 100’ 200’ Little River Band of Ottawa Indians Final EIS / 208526 SOURCE: Fleis & Fandenbrink, 2015; AES, 8/23/2019 Figure 2-13 Alternative D - Grading and Drainage Plan

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LEGEND 1St St Custer Site Soil Type Boundaries 60 SOIL TYPES ON THE PROJECT SITE 57B 57B - Grattan sand, 0 to 6 percent slopes 58B 58B - Covert sand, 0 to 6 percent slopes 60 - Kingsville mucky sand 67B - Plainfield sand, 0 to 6 percent slopes 60 Feet ! N OR TH 58B ¢ Ð 57B 0 170 340 59B 60 67B 57B 57B 67B Little River Band of Ottawa Indians Final EIS / 208526 SOURCE: USDA NRCS SSURGO Soil Survey of Mason County, Michigan, 2015; USDA NAIP Aerial Photograph, 7/21/2014; AES, 12/17/2019 Figure 3.2-2 Soil Types - Custer Site

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Cooper Creek Po r Bi g S te r a b le R iv er Cr ee k er F r l e Riv e em an g Sab Cr Bi D avis e Cr ek ee k eek is Cr DennD en n i s C reek Li n c o l n R ch iv e th B ran r N or reek llo C te Cos ch Linc h Branch Linc oln River So ut Br an oln uth So Ri ve r r eek Cr Linco l n R rr iv e Bu on Cre ek k Cre l B lac We d Bla c k Rive ek Custer Site r e ek reek rq Cr Ma uette R ive L A SB e re r ir C a P ran Cl ito ch St P Pe s qu K E ere M re arq u M Mo In e tte R ive r ar qu dia et te Cr ee M I L ic k Ri ht ve eC S w an C reek r C H reek I G A N k ree yC Cre bb in e k Ki Qu n ver te r Ri k a re e nch Pent w th Bra nC Nor ek ma y Cr e Du ub e r Riv er R LEGEND wat en t Ce d tal Cre ar r ys P ek Crystal Creek Custer Site C re e C ran ch Watersheds k rt h B Pere Marquette-White Watershed No Pe Cleveland Creek Feet nt w ! N OR TH at e ¢ Ð rR 0 9,000 18,000 iv e r Little River Band of Ottawa Indians Final EIS / 208526 SOURCE: USDA NRCS Watershed Boundary Dataset, 2012; AES, 12/17/2019 Figure 3.3-2 Custer Site Watershed

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E. Hile E. Hile Rd Rd LEGEND Action Area Roadside Drainage Ditch HABITAT TYPES Detention Basin Ai Ruderal/Developed rli ne Rd Feet ! ¢ ÐN OR TH 0 200 400 Detention Basin 1 96 § ¦ ¨ Detention Basin 2 S. Harvey S. St Harvey St Detention Detention Detention Basin Basin Basin 5 4 3 E. Ellis E. Ellis Rd Rd Little River Band of Ottawa Indians Final EIS / 208526 SOURCE: USDA NAIP Aerial Photograph, 7/21/2014; Muskegon County Parcels, 2013; AES, 12/17/2019 Figure 3.5-1 Habitat Types - Muskegon Site

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PHOTO 1: View of ruderal/disturbed habitat, debris pile, PHOTO 2: View of ruderal/disturbed habitat and debris pile and vacant building facing east. Photo date: 8/18/2015 facing west. Photo date: 8/18/2015 PHOTO 3: View of ruderal/disturbed habitat facing north. PHOTO 4: View of ruderal/disturbed habitat facing south. Photo date: 8/18/2015. Photo date: 8/18/2015 PHOTO 5: View of Detention Basin 1 facing northeast. PHOTO 6: View of Detention Basin 2 facing southeast. Photo date: 8/18/2015 Feature is surrounded by dense willow stand. Photo date: 8/18/2015 Little River Band of Ottawa Indians Final EIS / 208526 SOURCE: AES, 11/22/2019 Figure 3.5-2a Site Photographs - Muskegon Site

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PHOTO 7: View of Detention Basin 3 facing southeast. Photo date: 8/18/2015. PHOTO 9: View of ruderal/disturbed habitat near eastern boundary facing north. Photo date: 8/18/2015. PHOTO 8: View of conrete debris pile facing east. Debris pile is potential upland foraging and refuge habitat for eastern rattlesnake. Photo date: 8/18/2015. PHOTO 10: View of ruderal/disturbed habitat near center facing west. Photo date: 8/18/2015. Little River Band of Ottawa Indians Final EIS / 208526 SOURCE: AES, 11/22/2019 Figure 3.5-2b Site Photographs - Muskegon Site

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LEGEND Custer Site NATIONAL WETLANDS INVENTORY PEM1Ad - Palustrine, Emergent, Persistent, Temporarily Flooded, Partially Drained/Ditched PFO1C - Palustrine, Forested, Broad-Leaved Deciduous, Seasonally Flooded PSS1C - Palustrine, Scrub-Shrub, Broad-Leaved Deciduous, Seasonally Flooded HABITAT TYPES Feet Mixed Hardwood/Conifer Woodland ! N OR TH Pastureland ¢ Ð Spruce Plantation 0 150 300 1St St Little River Band of Ottawa Indians Final EIS / 208526 SOURCE: USFWS, National Wetlands Inventory, 2005; USDA aerial photograph, 7/21/2014; AES, 12/17/2019 Figure 3.5-3 Habitat Types - Custer Site

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PHOTO 1: General habitat from the northern boundary of PHOTO 2: General habitat from the southern boundary of the Custer Site. the Custer Site. PHOTO 3: Northern portion of the Custer Site. PHOTO 4: Southern portion of the Custer Site. PHOTO 5: Eastern portion of the Custer Site. PHOTO 6: Western portion of the Custer Site. Little River Band of Ottawa Indians Final EIS / 208526 SOURCE: AES, 11/22/2019 Figure 3.5-4 Site Photographs - Custer Site

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Tract 0042 Tract 0001 Tract 0019.01 Tract 0032 Tract 0003 V U46 Mclaughlin Ave Eva nst Tract 0019.02 Mill Iron Rd o nA ve Sheridan Dr Tract 0004.01 Brooks Rd Rd Broadmoor St Tract 0005 ine Tract 0020 Tract 0031 erl Laketon Ave Laketon Ave art Qu Dangl Rd Getty St Wood St Tract 0004.02 Evanston Ave Tract 0013 Sherman Blvd Tract 0043 Broadway Ave vd Bl n so Milliron Rd Brooks Rd rri Ha Tract 0014.02 72 Tract 0026.01 Tract 0029 Tract 0024 Tract 0027 Shettler Rd Sheridan Rd Airport Rd 31 £ ¤ Tract 0025 Hile Rd Ai rli ne 31 Rd Ellis Rd £ ¤ Grand Haven Rd 96 Tract 0028 § ¦ ¨ Ai r Tract 0026.02 lin e Hwy LEGEND Muskegon Site Pontaluna Rd Project Census Tract Census Tracts Walker Rd 3Rd Ave Miles ! N OR TH Bridge S t Fruitport Rd ¢ Ð 0 0.5 1 Little River Band of Ottawa Indians Final EIS / 208526 SOURCE: US Census, 2010; State of Michigan Open Data, 2016; ESRI Street Map, 2016; AES, 12/17/2019 Figure 3.7-1 Census Tracts - Muskegon Site

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LEGEND Custer Site Census Tracts Project Census Tract Miles ! N OR TH Tract 9502 ¢ Ð 0 1.5 3 Tract 9501 Tract 9503 Tract 9506 Tract 9504 Tract 9505 Tract 9507 Tract 9508 N H I G A M I C E L A K Tract 0108 Tract 0105 Little River Band of Ottawa Indians Final EIS / 208526 SOURCE: US Census, 2010; State of Michigan Open Data, 2016; ESRI Street Map, 2016; AES, 12/17/2019 Figure 3.7-2 Census Tracts - Custer Site

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NB BU S-3 1 EN TR AN 1 2 3 4 5 CE AIRPORT ROAD 14 1 BU US-31 GRAND HAVEN ROAD S- 31 NB US IT EX -31 EN 1 -3 IT 15 US EX TRAN SB 6 W B I-9 16 CE SB US 17 6 7 8 12 14 -31 EN TRAN CE 15 16 17 18 19 I-9 6 HILE ROAD 4 19 3 18 2 MP HARVEY STREET RA EB I-96 RAMPS IT EX 1 US-3 NB AI RL IN 20 21 22 28 29 EH IG HW AY 28 SITE DRIVE US-31 ELLIS ROAD 5 INDEPENDENCE DRIVE NB 6 US PS -3 M 1 A RA R M 1 PS S-3 U SB NB US-31 EXIT LEGEND STERNBERG ROAD ROADS 8 22 29 21 20 7 12 NORTH LANE USE NOT TO SCALE SB US-31 EXIT SIGNALIZED INTERSECTION UNSIGNALIZED INTERSECTION Little River Band of Ottawa Indians Final EIS / 208526 SOURCE: F&V, 2016; AES, 8/23/2019 Figure 3.8-1a Muskegon Site Study Intersections – Lane Use and Traffic Control

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LEGEND ROADS LANE USE SIGNALIZED INTERSECTION UNSIGNALIZED INTERSECTION 13 26 25 WB I-96 ENTRANCE I -9 WB I-96 EXIT 6 NORTH NOT TO SCALE EB 9 I-96 E XIT 27 9 MT. GARFIELD ROAD EB I-96 EN TR AN GRAND HAVEN ROAD CE AIRLINE HWY HARVEY STREET NB US US-31 -31 T XI EN 1E 10 TR -3 AN US CE SB 11 24 23 10 PONTALUNA ROAD SB T US XI 1E -3 1 -3 EN US TR NB AN CE 11 13 23 24 25 26 27 Little River Band of Ottawa Indians Final EIS / 208526 SOURCE: F&V, 2016; AES, 8/23/2019 Figure 3.8-1b Muskegon Site Study Intersections - Lane Use and Traffic Control

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STILES ROAD N. MAIN STREET BRYE ROAD 31 US- MAIN STREET US-10 1ST STREET CUSTER ROAD SITE DRIVE LEGEND ROADS LANE USE US-31 SIGNALIZED INTERSECTION UNSIGNALIZED INTERSECTION SITE NORTH NOT TO SCALE Little River Band of Ottawa Indians Final EIS / 208526 SOURCE: F&V, 2016; AES, 8/23/2019 Figure 3.8-2 Custer Site Lane Use and Traffic Control

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NORTON SHORES LEGEND ZONING DESIGNATIONS C-2 - General Retail Fruitport Township Boundary Muskegon Site C-3 - Major Commercial FRUITPORT TWP GI - General Industrial ZONING DESIGNATIONS PUD - Planned Unit Development R-2 Single Family Residential PURD - Planned Unit Residential Development SUD - Special Use Development Bexley Dr Feet ! ¢ ÐN OR TH 0 625 1,250 E. Hile Rd E. Hile Rd § ¦ ¨ 96 Ai Norton Shores Fruitport TWP rli ne £ ¤ 31 E. Sternberg Rd SOURCE: Fruitport Township, MI/Prein & Newhof Engineers, Little River Band of Ottawa Indians Final EIS / 208526 January, 2007; AES, 12/17/2019 Figure 3.9-1 Fruitport Township Zoning Map

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Little River Band Trust Land LEGEND Little River Band Trust Land Custer Site MASON COUNTY ZONING DESIGNATIONS Feet ! ¢ ÐN OR TH 0 3,100 6,200 SOURCE: Mason County Zoning Map, Effective 12/1/2014; Little River Band of Ottawa Indians Final EIS / 208526 AES, 12/17/2019 Figure 3.9-2 Custer Township Zoning Map

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LEGEND 15-Minute Monitoring 24-Hour Monitoring NO RTH Site A WATER FEATURE / 0 225’ 450’ DETENTION Site B Muskegon Site MAIN ENTRY I-96 PARKING GARAGE SURFACE PARKING Site D HARVEY STREET ATRIUM Proposed Fee-to-Trust CASINO PORTE- MULTI- COCHERE PURPOSE CENTER (13,000 SF) HOTEL PORTE-COCHERE CASINO L HOTE POOL EMPLOYEE PARKING ATRIUM BOH / ADMIN SERVICE EMPLOYEE PARKING DOCK ELLIS RD. SERVICE ROAD Site C Little River Band of Ottawa Indians Final EIS / 208526 SOURCE: HBG, 2015; AES, 8/23/2019 Figure 3.11-1 Noise Monitoring Locations - Muskegon Site

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Site 1 " ) " ) Site 2 LEGEND Custer Site " ) 15-Minute Monitoring Feet ! ¢ ÐN OR TH 0 125 250 Little River Band of Ottawa Indians Final EIS / 208526 SOURCE: HBG, 2015; AES, 12/17/2019 Figure 3.11-2 Noise Monitoring Locations - Custer Site

130

LEGEND Muskegon Site Proposed Fee-to-Trust Property (# ! Viewpoints Photos E Feet E. Hile E. Hile Rd Rd E. Hile E. Hile Rd Rd ! ¢ ÐN OR TH 0 300 600 96 § ¦ ¨ Dr Bexley Dr Bexley Ai rli ne 1 ¬ « ! ( 1 ¬ « ! ( 5 6 E E 2 2 ¬ « ! ( E E 4 6 4 ¬ « ! ( 5 E 3 ¬ 3 E. Ellis E. Ellis Rd Rd « ! ( E S. Harvey S. St Harvey St Little River Band of Ottawa Indians Final EIS / 208526 SOURCE: USDA aerial photograph, 7/21/2014; Muskegon County Parcels, 2013; AES, 12/17/2019 Figure 3.13-1 Muskegon Site Viewpoints

131

PHOTO 1: View of the Muskegon Site from the north PHOTO 2: View of the Muskegon Site from the west facing facing south. east. PHOTO 3: View of the Muskegon Site from the southwest PHOTO 4: View of the Muskegon Site from the center facing east. facing north. PHOTO 5: View of the Muskegon Site from the center PHOTO 6: View of the Muskegon Site from the northeast facing east. facing southwest. Little River Band of Ottawa Indians Final EIS / 208526 SOURCE: AES, 8/23/2019 Figure 3.13-2 Muskegon Site Photographs

132

1St St 2 ¬ «A ! ( 3 B ¬ « E 1 ! ( E 4 E E 5 ¬ C « ! ( E LEGEND Custer Site (# ! Viewpoints Photos E Feet ! ¢ ÐN OR TH 0 175 350 Little River Band of Ottawa Indians Final EIS / 208526 SOURCE: HBG, 2015; AES, 12/17/2019 Figure 3.13-3 Custer Site Viewpoints

133

PHOTO 1: View of the Custer Site from the north facing south. PHOTO 2: View of the Custer Site from the north facing east. PHOTO 3: View of the Custer Site from the northeast facing west. PHOTO 4: View of the Custer Site from the northeast facing southwest. PHOTO 5: View of the Custer Site from the east facing west. Little River Band of Ottawa Indians Final EIS / 208526 SOURCE: AES, 8/23/2019 Figure 3.13-4 Custer Site Photographs

134

Little River Band of Ottawa Indians Final EIS / 208526 SOURCE: HBG, 2015; AES, 8/23/2019 Figure 4.13-1 Architectural Rendering – Alternative A from Harvey Street

135

Little River Band of Ottawa Indians Final EIS / 208526 SOURCE: HBG, 2015; AES, 8/23/2019 Figure 4.13-2 Architectural Rendering – Alternative B from I-96

136

Little River Band of Ottawa Indians Final EIS / 208526 SOURCE: HBG, 2015; AES, 8/23/2019 Figure 4.13-3 Architectural Rendering – Alternative C

137

Little River Band of Ottawa Indians Final EIS / 208526 SOURCE: HBG, 2015; AES, 8/23/2019 Figure 4.13-4 Architectural Rendering – Alternative D

138

Tuttle Rd Darr Rd £ 10 ! ( ¤ Bean Rd Tuttle Rd Darr Rd Jefferson St 1St St ! ( LEGEND Feet Custer Site ! ¢ ÐN OR TH City of Scottville 0 750 1,500 ! ( Proposed Lift Station Proposed Water Infrastructure Improvements Proposed Wastewater Infrastructure Improvements Potential Gas Pipeline Improvements Little River Band of Ottawa Indians Final EIS / 208526 SOURCE: Fleis & Vandenbrink, 2016; USDA NAIP Aerial Photograph, 7/21/2014; AES, 12/17/2019 Figure 4.14-2 Alternative D Off-Site Improvements

139