Environmental Review: Communications Towers

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 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.

Please see our  Research Information for Cell Tower Applicants Guide  for more information about our files. For small cell (50 feet or less) installations, please see our  Interim Small Cell Policy .

Contact the National Register Specialist 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, multiple quality resource photographs, effects determinations and photographs, photograph key, archaeological survey, research information, 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 and eligibility and effect determinations 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 is no longer extant, 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 with an indication of the tower location and height within the photograph. Please see the guidance above for more information regarding communication tower research requirements, and submittals.

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).