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Telecommunication Tower 106 Review

The State Historic Preservation Office (SHPO) reviews new telecommunication tower constructions that receive a license from the Federal Communications Commission (FCC), pursuant to Section 106 of the National Historic Preservation Act, as amended. Review procedures for FCC undertakings are stipulated in the Nationwide Programmatic Agreement Regarding the Section 106 National Historic Preservation Act Review Process (Nationwide PA), signed in 2004. Please read through these guidelines completely to understand the information our office needs to review projects pursuant to the Programmatic Agreement. Additional information on Section 106 review can be found on the FCC’s website.

Note: We do participate in the FCC’s online E-106/TCNS system. Please do not send us hardcopies if you use the system.

We also review collocations and follow the guidelines set forth in the Nationwide Programmatic Agreement for the Collocation of Wireless Antennas (Collocation PA), signed in 2001. Please refer to this PA when submitting data on collocations. For more information, please see the FCC Fact Sheet (PDF) for the Collocation PA.

We will conduct after-the-fact reviews, but do not require them.

The SHPO expects cell tower clients and their consultants to provide a completed FCC Form 620 or 621 (PDFs) with attachments to ensure that all of the necessary information has been submitted for consultation. The Nationwide Programmatic Agreement makes use of these forms mandatory for consultation between applicants and the SHPO on FCC undertakings that are not excluded from Section 106 review. Note: We do not require a Section 106 Project Review Form for telecommunication tower projects as long as a FCC Form 620 or 621 is completed.

The following FCC undertakings are excluded from Section 106 review and do not need to be submitted to the SHPO:  (Please note that exclusions must be documented and available to the FCC or SHPO upon request)

  • Enhancement of a tower that does not constitute a collocation or substantial increase in size
  • Construction of a replacement tower that does not substantially increase the size, extend the boundary 30+ feet in any direction, or involve excavation in added area
  • Construction of any temporary tower or related structure
  • Tower less than 200 feet in height located in an existing industrial park, commercial strip mall, or shopping center if the development is:
  • larger than 100,000 square feet, and
  • not within 500 feet of a historic property
  • Tower within 50 feet of the outer boundary of a right-of-way for communication towers, above-ground utility transmission/distribution lines if:
  • it does not constitute a sizable increase over structures in the right-of-way within the vicinity, and
  • it is not located within the boundaries of a historic property
  • Construction in an area previously designated by the SHPO (The PA requires that the SHPO document any areas of this type; at this time the SHPO has not designated any additional areas of exclusion)
  • Submission Packets

    Note: Incomplete submission packets will not be reviewed and will receive a letter indicating that inadequate information was submitted.

    When adequate project information has been received, comments will be provided within 30 days of receipt of information.

    A complete submission packet includes Form 620 or 621 and attachments including:

    Resumes/Vitae – a brief statement of the professional qualifications of the Principal Investigator and any other person contributing to the information in the Submission Packet. The SHPO maintains Lists of Preservation Professionals for firms with individuals who document qualifications in one or more of the Secretary of the Interior's Professional Qualifications Standards.

    Site information – description of additional structures, access roads, utility lines, fences, easements, or other construction planned in conjunction with the proposed facility.

    Appropriate Tribal Involvement – a list of Native American Indian tribes that have been consulted. Resources for consultation with Federal and State Recognized Native American Indian Tribes are available on the SHPO's website.

    Local Government Involvement – a statement of whether any local government agencies have been contacted, or when they will be contacted.

    Public Involvement – a description of measures taken to obtain public involvement and relevant documents.

    Additional Consulting Parties – a description of measures taken to contact other interested parties. The SHPO requires that contact be made with owners of historic properties within the areas of potential effects (APE) and local historical or preservation groups in the project area. A list of potential local groups organized by county is available by accessing our Directory of South Carolina's Local History, Historic Preservation, and Cultural Organizations (PDF).

    Areas of Potential Effects (APEs) – descriptions of the APEs for direct and visual effects and an explanation of how each has been determined.

    Information on Historic Properties Identified for Visual Effects – a list of historic properties in the APEs identified in the SHPO inventory or through the comments of the local government, tribes, historical organizations, or members of the public.

    Information on Historic Properties Identified for Direct Effects – a list of above-ground historic properties and archaeological sites in the APEs identified from the South Carolina Institute of Archaeology and Anthropology (SCIAA) or SHPO inventory, consultation through the comments of the local government, tribes, historical organizations, or members of the public, as well as a report on archaeological testing or a statement of why archaeological testing was not performed.

    Assessment of Effects on Identified Historic Properties – a statement of effect, explanation of assessment, supporting documentation, and any alternatives considered to avoid, minimize or mitigate adverse effects. The SHPO recommends submittal of a balloon test or computer simulations showing potential visual effects of the tower on identified historic properties. SHPO staff should be extended an invitation to observe the balloon test.

    Photographs – photographs of the project site, surrounding location, any historic properties identified within the APEs, and photographs of balloon tests or computer simulations taken from historic properties toward the tower site. Photographs should be keyed to a location map. Balloon test photographs should indicate the height of the proposed tower utilizing an arrow.

    Maps – a 7.5-minute USGS topographical map showing the tower site, the APE for visual effects, historic properties identified during background research or comment process, and a key for map symbols. Aerial photographs are also useful. For most projects, ArchSite maps will be sufficient.