Cultural Resource Survey Rochelle Trilead# 645677 Pine City Road Pitts, GA 31072

At the request of Southern Towers, LLC, Environmental, Inc. performed a Phase I Cultural Resources Survey (CRS) for Candidate A of the proposed GA-009 Fitzgerald wireless telecommunications facility to be located in Fitzgerald, Ben Hill County, Georgia. The FCC is the lead oversight agency, and as such this project is subject to review under NEPA and the NHPA, specifically Section 106. The Phase I survey and assessment, following the guidelines set forth in the FCC’s Nationwide Programmatic Agreement, entailed the following aims and objectives: 1) Define the project’s Direct and Visual Area of Potential Effects (APE); 2) Identify any archaeological sites or historic properties within the APE for Direct Effects via a field reconnaissance utilizing both visual inspection and subsurface testing; 3) Identify any archaeological sites or historic properties, as well as previous cultural resource surveys, within the APE for Visual Effects via research utilizing the files and databases of the state SHPO and other appropriate agencies, as well as available aerial photographs and historical records and maps; 4) Review and compile contextual data concerning the project area’s physiography, geology, soils, prior land use, and cultural history; 5) To evaluate the significance of any archaeological sites or historic properties identified, including those historic resources identified during the field reconnaissance (inadvertent discovery), within the guidelines and criteria for establishing eligibility for the NRHP; and 6) To assess the effects of the project (the undertaking) on any identified historic properties.

The undertaking consists of a 100-foot by 100-foot lease area and a 30-foot wide site ingress-egress & utility easement. The subject property was once the site of a turpentine distillery from the mid-century to the early 1970s and is now used for the storage and refurbishment of derelict mobile homes. The access road extends east from Appomattox Road East Oconee Street for approximately 31 feet to the site. The site is relatively level and is grassed except for the southeast corner which is just within a treeline of mixed secondary hardwood and pine. Tower lighting will be in accordance with FAA final determination. Proposed activities consist of construction of a 250-foot (260 feet with appurtenances) lattice wireless telecommunications tower and associated compound, enclosing the compound in a fence, placement of support equipment within the compound, and covering the compound with gravel.

APE for Direct Effects. As a result of the literature and document review, the field reconnaissance and evaluation, and project assessment, no archaeological sites or cultural material was identified within the APE for Direct Effects. Cultural Resource probability was low, largely due to overall distance from water and from repeated episodes of earth moving and grading activity observed on early aerial photographs. Visual inspection of large patches of exposed ground surfaces and the excavation of four shovel tests failed to identify any cultural material. Thus, this office recommends a determination of No Properties/Effect to archaeological resources (APE for Direct Effects).

APE for Visual Effects. The background research indicated there are multiple NRHP-listed or NRHP-eligible properties within the APE for Visual Effects, including the Fitzgerald Commercial Historic District and the South Lee and South Main Streets Historic District. There are four individual NRHP-listed properties within or adjacent the Visual APE—the Ben Hill County Courthouse, the Dominy-Massee House, the Ben Hill County Jail, and the Holtzendorff Apartments. The former two are at the edge of and just outside the boundary of the Visual APE, while the latter two are within the APE. Only the Ben Hill County Jail should be negatively impacted visually by the proposed undertaking. Three of these properties (the courthouse, jail, and apartment building) are also within the boundaries of the Fitzgerald Commercial Historic District for which they are considered contributing resources. lies within the APE for Visual Effects of the proposed undertaking. Based on observations during the pedestrian reconnaissance, it appears that the proposed tower will likely be out of view to some sections of the commercial historic district, while in others the tower would likely be discernible, with only the distance and the intervening tree canopy of the residential areas being lessening factors to potential visible impacts. The South Lee and South Main Streets Historic District lies entirely within the APE for Visual Effects and in fact the southern boundary of the district is directly across Sadie Street from the parent parcel where the proposed undertaking is to be located. Being a residential area, there is vegetation and tree canopy cover to lessen visual impacts. Unfortunately, these factors cannot overcome the proximity of one to the other, and it is likely that the proposed tower would be visible from various sections of the district. The area of greatest visual impacts would be along South Main Street which would be visually on-axis with the proposed tower. Thus, this office recommends a determination of No Effect to the NRHP-listed Ben Hill County Courthouse and the Dominy-Massee House, a determination of No Adverse Effect to the NRHP-listed Holtzendorff Apartments, and a determination of Adverse Effect to the NRHP-listed Ben Hill County Jail, the Fitzgerald Commercial Historic District, and the South Lee and South Main Streets Historic District as they relate to Candidate B of the proposed GA-009 Fitzgerald Wireless Telecommunications Facility in Fitzgerald, Ben Hill County, Georgia. Consequently, this office recommends avoidance or relocation of the proposed undertaking. If this is not a viable option, then this office recommends entering into a dialogue with the GA SHPO in an effort to mitigate these adverse effects.