Tower Siting and the Environment

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Although not specifically listed in the NPA, Section 1.1307(b) requires tower owners to assess RF emissions for compliance. There are some exclusions that can be applied, such as a tower enhancement (rather than a new installation), replacement for an existing tower, construction of a temporary tower or construction of a facility less than 200 feet in overall height above ground level in an existing business area. A tower siting consultant can provide advice in specific situations.

The environmental assessment

The bottom line is that every licensee is required to perform and submit an environmental assessment (EA) when making application for a new structure, an existing structure when adding new antennas or making a major change to an existing installation against the NPA categories. How you perform the evaluation is not specified and could be performed without a professional consultant, however it is recommended you engage an environmental consultant who is familiar with the requirements of the NPA and has the proper experience to perform the study. Section 1.1312 requires a licensee filing an EA to await commission approval of its proposed project before commencing any construction, even if commission approval is not otherwise required for such construction.

Historic preservation offices

As part of the EA, a submission packet must be submitted to both the applicable State Historic Preservation Office (SHPO) and Tribal Historic Preservation Office (THPO) for your state. According to Section 106, you are required to get concurrence from these organizations prior to submitting the EA. My experience is that each state is different in terms of how it operates the SHPO. Some are fully staffed, and some are volunteer staffed. The Indian organizations are even more random. These tribal groups sometimes operate over several states, so it can be difficult to find the appropriate organization to deal with.

According to Section 106, the SHPO/THPO offices are required to provide a decision within 30 days or it can be assumed that concurrence has been provided. You (or your consultant) should keep good communications records of the contacts (or attempted contacts) to these offices as well as documentation that the packages or any requested information were delivered. The FCC has the right to arbitrate any disputes that may arise from a determination of adverse effect.

The FCC's Tower Construction Notification System (TCNS) can be used to upload the EA and supporting information, where it will be delivered to the proper offices. The system facilitates the Section 106 requirements but not intended to replace normal communications between the offices and the applicant. TCNS can be accessed through the FCC website.

I can't stress the importance of taking the proper steps to ensure compliance with section 106 before an application is filed. There have been cases where the FCC has ordered structures removed and issued fines due to noncompliance. In addition, the siting portal on the FCC website has a wealth of information that will help in the process.

Online Resources

  • NPA
  • Environmental checklist for Section 106
  • FCC siting portal

    McNamara is president of Applied Wireless, Cape Coral, FL.

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