Cell Tower Review

The State Historic Preservation Office (SHPO), South Carolina Department of Archives and History, 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.

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 for the collocation agreement.

The SHPO expects cell tower clients and their consultants to provide a completed FCC Form 620 or 621 (both Acrobat 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/THPO on FCC undertakings that are not excluded from Section 106 review. (THPO - Tribal Historic Preservation Office)

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/THPO 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 SC-SHPO has not yet designated any such areas)

I. BACKGROUND RESEARCH
The Nationwide PA encourages but does not require the use of a qualified professional meeting the Secretary of the Interior’s Professional Qualifications Standards (SoI Qualifications) when conducting background research.

Archives & History Center
The SHPO provides a workstation for accessing ArchSite/GIS that has information on archaeological sites, National Register properties, properties determined eligible for listing, county-wide architectural surveys, and numerous review and compliance surveys. First time user? Contact Chuck Cantley, GIS Coordinator, at ccantley@scdah.state.sc.us or (803) 896-6181 to make an appointment to access ArchSite.

Additional survey information is available in the form of reports, survey cards, and maps. These are listed in the finding aid for the South Carolina Inventory of Historic Properties: Surveys by County. See Consultant’s Guide to Survey and National Register Files (pdf) for more guidance.

Researchers are responsible for checking both ArchSite and the finding aid for the South Carolina Inventory of Historic Places, in order to successfully complete background research. Because reconnaissance surveys are no longer required, consultants should carefully search the finding aid, particularly for projects in counties that have not had a comprehensive survey of historic properties. Older, non-comprehensive surveys with eligibility decisions may not be part of ArchSite.

South Carolina Institute of Archaeology and Anthropology (SCIAA)

Archaeological Sites:
The Office of the State Archaeologist, South Carolina Institute of Archaeology and Anthropology (SCIAA) maintains archaeological site files. This is a separate state agency; the records are available only through appointment. The SCIAA contact for site files is Keith Derting, 803-777-8170.

Area of Potential Effect (APE)

Direct Effects
The APE for direct effects is the area of ground disturbance for the tower, including any proposed access roads or other construction activity that will result from the undertaking.

Visual Effects
Standard APEs for visual effects have been suggested by the Nationwide PA and will guide reviews by the SC-SHPO. However, topography and other environmental factors may require an alternate APE.

The SC-SHPO requires that background research be conducted and shown on maps in the submission packet for a one-mile radius from the proposed tower location for a tower of 200 feet or less. For towers over 200 feet, the incremental increase for research is ½ mile for every 50 feet of tower height.

Unless an alternate APE is suggested by the background research the following APEs will be used for assessing visual effects:

• ½ mile radius from the tower, if height is 200 feet or less
• ¾ mile radius from the tower, if height is 200-400 feet
• 1 ½ mile radius from the tower, if height is more than 400 feet

Both the research area and standard APE for visual effects should be shown as part of the maps in the submission packet.

II. ASSESSMENT OF EFFECTS
Direct Effects
A professional meeting the SoI Qualifications for archaeologist is required to determine whether archaeological field survey is necessary. For field surveys please refer to South Carolina Standards and Guidelines for Archaeological Investigations.

If a project will have a direct effect on an above-ground property that is greater than fifty years of age, then identification and evaluation should be done by a professional meeting the Secretary of the Interior’s Professional Qualifications Standards (SoI Qualifications). This may include a field survey where appropriate. For field surveys please complete survey cards for newly identified properties.

Visual Effects
If an identified historic property is located within the APE, then a professional meeting the SoI Qualifications is required to assess the effect of the proposed tower on historic properties according to the Nationwide PA. The SC-SHPO recommends that a professional meeting the qualifications for architectural historian or historian make the assessment of effect for above-ground historic properties.

III. SUBMISSION PACKET
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 SC-SHPO maintains a Project Professionals List for firms with individuals who document qualifications in one or more of the SoI 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 groups that have been consulted. Resources for consultation with Indian Tribes are available on the SC-SHPO website.
  
• Local Government Involvement – a statement of whether any local government agencies have been contacted, or when they will be contacted. List contacts and provide any relevant documents.
  
• 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 and any relevant documents. The SC-SHPO requires that contact be made with owners of historic properties within the APE and local preservation groups in the project area. A list of contacts for local preservation groups is available by linking to the appropriate county on the Historical Organizations Directory page.
  
• Areas of Potential Effects – 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 properties in the APE 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 properties and archaeological sites in the APE identified from the 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.
  *If historic properties are identified within the APE for visual effects, provide the results of a balloon test or computer simulation showing the potential visual effects of the tower installation.
  
• 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. Acceptable photo formats are:

- 35mm color snapshots or
- Digital photos printed at a high resolution on a good-quality color printer.

• Maps – a 7.5-minute USGS topographical map showing the tower site, the background research area, the APE for visual effects, historic properties identified during background research or comment process, and a key for map symbols. For most projects this will be a map from the CRIS database.