Final Removal Considerations

• On September 19, 2025, AT&T completed its final activities associated with their commitment to remove lead cables from Lake Tahoe
• While we can confirm this final phase played out over two days, some of the challenges encountered and specific decisions remain unknown
• While our organizers were on site, they were denied access to directly observe and mislead by AT&T’s contractors on the timing of removal from Tallac Creek
• We reached out to U.S. Forest Service and AT&T’s partner, the League to Save Lake Tahoe, with follow up questions but neither answered specifics
• We respect the autonomy of parties involved, and ultimately our organization existed for one purpose - get the lead out - which was achieved as permitted

• While we are closing our work and organization, we would like to conclude our collaboration by providing transparency on what we did observe
• We’d also respectfully present two specific findings appropriate for further examination given their potential to impact or influence other situations
• We view both as representing future risks to Lake Tahoe, and would respectfully ask your agency to take them into consideration
• We’re grateful for your engagement and our organizers will remain available as a resource indefinitely as appropriate
• Thank you for your time and partnership across stakeholders over the 5 years, and for providing permits that authorized the completion of this important work

• On September 18, AT&T and its partners arrived on Baldwin Beach to complete their removal of the lead cable from the water and the sands as previously permitted
• The lead cable was still protruding from the water as previously escalated
• Utilizing an excavator, AT&T’s contractors dug into the sands to locate the lead cable - but were unable to
• After hours of digging, they allegedly located the lead cable but chose to come back the following day

Source: Photos as taken by Tahoe Lead Removal Project Organizers and partners.

• On September 19, AT&T and its partners returned to Baldwin Beach
• They were quickly able to relocate the lead cable from the previous day, and began extraction and cutting into segments

Source: Photos as taken by Tahoe Lead Removal Project Organizers and partners.

• AT&T’s contractors utilized an excavator and a variety of tools to perform the removal
• The lead cable was secured with medal chainlink to extract from the sands of public Baldwin Beach

Source: Photos as taken by Tahoe Lead Removal Project Organizers and partners.

Source: Photos as taken by Tahoe Lead Removal Project Organizers and partners.

• After cutting the lead cable on the northern side of Tallac Creek, the crews continued activities within the TYC enclosure as permitted
• As previously verified earlier in September, there was no TYC contained within the project area

Source: Photos as taken by Tahoe Lead Removal Project Organizers and partners.

• AT&T’s partners failed to extract the lead cable during the afternoon of September 19, due to improper equipment and potentially methods

Source: Photo on left as taken by Tahoe Lead Removal Project Organizers and partners. Photo on right from Tahoe Daily Tribune “Remaining lead cable removed from Tahoe at Baldwin

Beach” September 29, 2025, as provided by the League to Save Lake Tahoe.

• Our organizers were told at ~5pm PST that the crews would be back the following day to continue removal
• However, we were surprised to find that no one returned as apparently all activities were completed
• This was confirmed on September 20th by U.S. Forest Service

Source: Tahoe Lead Removal Project Organizers and partners.

• Evidence of a rushed final job were evident following review the following day

Source: Tahoe Lead Removal Project Organizers and partners on September 19, 2025.

• Indentations in the sands of Baldwin Beach were evident
• This included an underwater review within Tallac Creek
• As shown in the picture to the right, it appears the lead cable was pulled with the excavator after it was cut
• The rationale behind these methods remains unknown as well as what precautions were taken by AT&T’s partners

Source: Tahoe Lead Removal Project Organizers, and petition signers.

• In planning our own potential remove project, we researched a range of best practices
• These precautions were not taken in the final removal on Baldwin Beach
• Uncovered hands directly held the lead cables during activities
• The lead cable was cut with a traditional saw
• Lead cables were placed directly on the sand instead of being wrapped

Source: Tahoe Lead Removal Project presentation as previously submitted May 2024.

TLRP Project Execution Considerations

As presented May 2024

• We remain grateful that AT&T upheld its commitment to removal the lead cables from Lake Tahoe
• Objectively, they did not act out of an abundance of caution
• Instead, their activities were carried out under the assumption that the lead cables could not possible pose any risk to the environment or water
• This approach is somewhat understandable as it is consistent with the exhibits provided by their paid researchers in connection with their lawsuit with the California Sportfishing Protection Alliance
• However, regardless of the opinions of their paid researchers legacy infrastructure with potentially hazardous material should be treated conservatively

• Given our organizers were denied access to the jobsite, we were not able to properly observe all activities performed
• We submitted a range of follow up questions to U.S. Forest Service as well as AT&T’s self proclaimed partner - the League to Save Lake Tahoe
• Neither entity answered our questions, and instead directed us to ask AT&T’s corporate communications team
• Given AT&T’s previous legal actions against members of the Lake Tahoe community related to these cables we declined to do so
• We would submit the following questions, and encourage follow up with either AT&T or their involved partners

• Following cuts, were all segments of lead cable capped before they came into contact with the sands of Baldwin Beach?
• For avoidance of doubt, was the lead cable entirely removed from the bottom of Tallac Creek?
• If so, how was the lead cable removed from Tallac Creek? Did this include any digging underwater or was it pulled by an excavator through the sand?
• How was the water within the TYC enclosure handled after being pumped away from where the lead cable was cut?
• Where was the water pumped from the TYC enclosure sent? Was it tested prior to movement?

• Our organizers engaged a wide range of organizations in sourcing potential partners in advocating for removal
• This included two nonprofits - League to Save Lake Tahoe and Tahoe Fund
• In conducting due diligence, we discovered that both entities had already taken donations from AT&T from 2014 to 2020
• They also operated differently during the project, showing the range of potential paths that these organizations take, including agency engagement
• Its reasonable for nonprofit to advocate, however it remains unknown whether or not they disclosed potential conflict of interests
• We’d ask for your to consider any previous engagement with these organizations throughout the duration of the removal permitting and execution

Source: League to Save Lake Tahoe annual reports https://www.keeptahoeblue.org/

2020-2021

2021-2022

Source: Tahoe Fund annual reports per https://www.tahoefund.org/

2022-2023

2023-2024

• Met with our organizers in person
• Proactively disclosed AT&T financial relationship
• AT&T in highest donor bracket
• Engaged agencies during AT&T’s permitting process
• Communicated willingness to fund community removal
• Self appointed role as “watchdog” for removal project

• Met with our organizers in person
• Proactively disclosed AT&T financial relationship
• AT&T in highest donor bracket
• Engaged agencies during AT&T’s permitting process
• Communicated willingness to fund community removal
• Self appointed role as “watchdog” for removal project

• Following November 2024 removal activities, the League issued a press releases and engaged media to incorrectly state that removal was completed
• These actions misled the public, and were either intentional or incompetent

League to Save Lake Tahoe November 21, 2024 Press Release

June 27, 2025 August 8, 2025

Source: https://www.keeptahoeblue.org/news/cables-successfully-removed-from-lake-tahoe/. Pictures on the right from TLRP Organizers summer of 2025.

TLRP Organizer Footage

• Despite proclaiming the cables were successfully removed, the League also alluded to the continued presence of lead on Baldwin Beach in their FAQs as well as quotes to national media outlets
• Unfortunately this also stated that the lead cable was about the high water line, and while that level can change what we’ve documented proved this false

Source: Left from https://www.keeptahoeblue.org/news/cables-successfully-removed-from-lake-tahoe/. Pictures on the right from USA Today November 26, 2024 article

https://www.usatoday.com/story/news/nation/2024/11/26/lake-tahoe-lead-cable-att/76591567007/

• As an individual and former donor, our lead organizer repeatedly engaged League CEO Darcie Goodman Collins with questions regarding these dynamics and ties to AT&T
• Across 7 follow ups, she refused to provide context, only responding once
• This included outreach following the discovery of the remaining lead cables in the waters of Baldwin Beach
• We’d encourage all agencies to ask these same questions of the League

Partnership with AT&T

• Did the League accept donations from AT&T prior to the discovery of the lead cables in 2014?
• How many donations, and for what total amount, has the League taken from AT&T since the cables were discovered in 2014?
• Has the League accepted donations from AT&T executives since 2014? If so, which corporate positions did they occupy and for what amount?
• As part of the “partnership”, negotiations, consulting or other workstreams related to the project, has the League taken additional funds from AT&T?
• Does the League agree with AT&T and their experts that the cables did not pose a threat to the environment while in the lake?

Watchdog

• Why did the League refer to the project as "complete" in its press release November 2024 but also suggest further land removal elsewhere?
• Which oversight activities did the League perform during removal?
• Of the two weeks of removal execution in November 2024, how many days were League personnel on site observing activities?
• Do you stand by the work completed by J.F. Brennan and AT&T? Did they uphold the permits and all their conditions? Were there any violations or potential violations?
• Were any removal activities conducted at night?
• Has the League conducted any water sampling after project completion?
• Does the League have a disclosure policy for conflict of interests more generally in situations where you're also acting as a "watchdog"?

• Since the rediscovery of the lead cables, the financial situation of the League has drastically shifted
• Revenue has increased 5x, while reported assets increased 8x and net income went notably positive
• An inflection point in 2021 coincides with the filing of the lawsuit

Source: Article from Tahoe Daily Tribune (https://www.tahoedailytribune.com/news/keep-tahoe-blue-unveils-new-home/) Graph based on data from

https://projects.propublica.org/nonprofits/organizations/946128680

• The League has a Conflict of Interest Policy disclosed on its website
• This document only covers “related persons” which surprisingly does not include donors
• By the League’s own policy, a donor cannot present a conflict of interest
• For an organization that publicly states its intent to advocate, this is an obvious gap that should be addressed
• We’re hopeful that this the League was not influenced by its financial ties to AT&T in any way shape or form

Source: https://www.keeptahoeblue.org/wp-content/uploads/2022/05/the-League-to-Save-Lake-Tahoe-conflict-of-interest-policy.pdf

• Currently, we are unaware of any requirements for 3rd parties to disclose financial relationships in government agencies contact or advocacy
• Its reasonable for a nonprofit to take funds from any donor it views appropriate
• However, to take funds from a corporation with specific interests embroiled in a lawsuit, and engage government agencies without disclosing this connection has the potential for unintended consequences or improper conduct

Please consider asking follow up questions of the League to Save Lake Tahoe

Please consider instituting a 3rd Party Conflict of Interest Disclosure Policy

Any private organization engaging with agencies on projects, legal matters, policy initiatives, permit applications, or enforcement actions must disclose all potential conflicts of interest, including:

• Financial donations from involved parties or their competitors
• Past or current employment relationships or board positions
• Contracts or agreements with any party that could benefit

Organizations must make these disclosures when speaking to media or making public comment regarding any government matter in scope.

Failure to disclose shall result in suspension from engaging Lake Tahoe Basin agencies for 5 years.

• In the original consent decree AT&T clearly stated that they “no longer own the Cables”
• This statement was foundational to our community efforts, providing an impetus to act
• However, by the second consent decree this was apparently no longer their opinion, as ownership was not addressed at all
• It remains to be seen what led to this new perspective, especially related to easements

Source: Courtlistener CA Sportfishing Protection Alliance v. Pacific Bell Telephone Co. Complaint Document #22.

• During the permitting process from 2021-23, California State Lands Commission (CSLC) provided new perspective on the easements
• They clearly stated the term was “continuous use beginning November 14, 1955”, meaning that the easements were not terminated as AT&T claimed to the courts
• CSLC also stated that the consideration was “public use and benefit”
• The proposed amendment also clearly states removal of “all severed segments and debris” which was not done as shown on page 14

Source: California State Lands Commision, Staff Report 29, February 28, 2023.

• As shown on page 34, AT&T stated that they stopped using the cables “around the 1980s”
• This implies that for around 30 years the public was not using or receiving benefit from these cables despite the lease conditions
• CSLC also stated that removal was in the State’s “best interests”
• This provides additional context to the lack of urgency and accountability through multiple years of delays

Source: California State Lands Commision, Staff Report 29, February 28, 2023.

• Infrastructure improvements within the Lake Tahoe Basin have proven to provide tangible public benefit, including these lead cables
• However, once that it became apparent that the improvements no longer provided a public benefit - and never would - they should have been removed
• Once this dynamic was discovered, it should not have been AT&T’s choice on whether or not to perform removal and when

Please consider performing a cross agency review of existing corporate

infrastructure leases in the waters of Lake Tahoe

all 7 government agencies for authorizing removal activities

• We appreciate your engagement not only with our organizers, but AT&T over many years and countless hours
• Despite our open questions, we remain grateful to AT&T for taking action
• Our view remains that orientation should be towards future generations, and are hopeful that the lessons learns and findings escalated are additive
• Lake Tahoe is an extraordinary, singular place on planet earth that will remain subject to a range of forces and influences private and public
• Thank you for investing yourselves so deeply in safeguarding its natural beauty, and everything you do to help make it such a special place for all