Nationwide Programmatic Agreement for Collocation of Wireless Antennas
If you are in the business of contructing wireless telecommunications towers, it is more important than ever that you demonstrate compliance with Section 106. Due to the development of the nationwide programmatic agreement (PA), carriers will be seeking to collocate on Section 106-compliant towers in order to take advantage of the programmatic agreement. Since the programmatic agreement generally "grandfathers" all towers built before March 16, 2001 (without documented complaints) to have no effect of historic properties, you should focus on demonstrating compliance for future towers. EBI Consulting is experienced in assisting tower companies by documenting compliance with Section 106, which will facilitate collocation agreements.
On March 16, 2001, the Federal Communications Commission, the National Conference of State Historic Preservation Officers, and the Advisory Council on Historic Preservation (ACHP) entered into a nationwide programmatic agreement to streamline review procedures for antenna collocations under the National Historic Preservation Act (NHPA). Under the programmatic agreement, most collocations on existing structures are exempted from the procedures set forth in the ACHP rules. Complete text of the PA can be found here. The programmatic agreement is intended to relieve unnecessary administrative burdens on the Commission's licensees, tower construction and management companies, State Historic Preservation Officers, and the Commission, while protecting the goals of the NHPA. Other intentions of the programmatic agreement include:
- Streamline Section 106 review (SHPO review) of collocations of antennas on existing towers and other structures
- Encourage collocation of antennas in order to reduce the need for new tower construction, since new tower construction is more likely to effect historic properties than a collocation, which is likely to have minimal/not adverse effect on historic properties
- Recognize that most tower structures have not undergone Section 106 review. Unless documented complaints exist, towers constructed before March 16, 2001, although non-compliant, are assumed to have "no adverse effect" on historic properties, and therefore should be utilized for collocation
- Encourage that all towers constructed after March 16, 2001 comply with Section 106, which creates and incentive for collocation to occur on towers that have "no effect" on historic properties
- Relieve unnecessary burden on licensees, SHPOs and the FCC
As a contributor to the development of the programmatic agreement, EBI Consulting is highly qualified to determine and document whether your proposed collocation meets the stipulations set forth in the programmatic agreement. EBI Consulting specializes in utilizing the programmatic agreement to your advantage, which will facilitate and expedite the construction of the collocation. We document compliance with the programmatic agreement in our NEPA checklist report, which also provides evidence of compliance with NEPA requirements.
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To learn more about programmatic agreement consulting services, contact EBI Consulting at 617.715.1847 or info@ebiconsulting.com. You can also view our sample projects.