Review and Compliance:
Communications towers dot the landscape, both urban and rural, and vary in height, design and also in whether their construction has visual or direct effects to historic properties. Since the towers are licensed through the Federal Communications Commission (FCC), compliance with Section 106 of the National Historic Preservation Act is required.
- Are you submitting a communications tower project for HPD review?
Applicants for certain Federal Communications Commission (FCC) licenses related to communications tower construction are now required to follow 47 CFR Part 1, Nationwide Programmatic Agreement for Review Under the National Historic Preservation Act (NPA). For background information, visit the Federal Communications Commission website. Per the NPA, all applicants should conduct research within HPD's files in order to determine previously identified historic resources. This step requires visiting our office to review files not available through our online database, GNAHRGIS, such as County and City survey, National Register, Centennial Farm, Topical, and Environmental Review files. Contact the National Register Specialist and Environmental Review Historian to set up a research appointment.
Please note, HPD does not participate in the online E-106 system, and therefore, requires that FCC applicants mail submittals to our office. HPD requests that applicants submit the FCC Form 620 or 621 (not the ER form), resume/curriculum vitae, topographic map, site photographs, resource photographs, effects determinations and photographs, photograph key, archaeological survey, research information (including checklist – see guidelines), and evidence of consultation with tribes, local government, and other interested parties, including evidence of public notification.
Due to inconsistencies in resource locations, HPD recommends checking the tax assessor’s site, historic topographic maps, and Google Earth to compensate for errors that may have occurred in existing surveys. Submittals and FCC forms should include all resource identified, whether eligible or not and affected or not, and eligibility and effect determinations then noted under the appropriate question within the forms. HPD requests that if a resource is found in more than one of the file locations to please note all file numbers associated with the resource (ie. a GNAHRGIS number, county survey number, etc.). Finally, if a resource has been demolished, please include evidence of such in the submittal.
In order for HPD to comment on the effects a tower may have on a resource, we recommend including photographs from the resource toward the tower site. An arrow or simulation showing the tower height within the photograph will aid in our ability to more accurately comment on effects.
For more detailed information regarding communication tower research requirements, submittals, and our subsequent reviews, please see our Guidelines for Section 106 FCC tower applicants.
HPD's ability to complete a timely Section 106 review and issue meaningful comments largely depends on the quality of the material submitted. Some applicants may find it advantageous to hire a historic preservation professional who meets the Professional Qualifications Standards for history or architectural history (as required for archaeology). As part of a good faith effort to identify historic resources, although not required by the NPA, HPD also recommends a field survey of the APE for visual effects. The likelihood of unexpected issues or broad local opposition may be diminished if the public understands that the site selection process has been thorough, fair, and open.
Who to Contact:
Meg Richardson, Environmental Review Historian, HUD and FCC projects