Environmental Corporation of America’s (ECA) client, AT&T Mobility, LLC, is proposing to construct a utility pole as described in the following FCC Form 620, New Tower (NT) Submission Packet. ECA understands that AT&T Mobility, LLC plans to construct a 42-foot overall height utility pole telecommunications support structure within an approximate 10-foot by 10-foot (3-meter by 3-meter) area. Preliminary construction drawings are included in Attachment H.
Due to the setting and the specifications of the proposed undertaking, ECA requested an alternative Area of Potential Effect (APE) for visual effects via email prior to conducting our site visit. Ms. Katie Twomey, Environmental Review Historian with the Georgia Historic Preservation Division (GA HPD), responded in an email on March 27, 2017 stating that the APE for visual effects could encompass the extent of visibility as long as justification is provided through description and photographic evidence within the report. View back locations were determined based on a visual assessment and potential views of the proposed undertaking that were unencumbered by intervening structures and/or vegetation. For selected view back locations, photographs have been annotated in order to better convey the location of the proposed support structure. These photograph annotations only identify approximate locations.
Photographs of the proposed undertaking and of representative locations within the alternative APE for visual effects are included in Attachment B. ECA has identified and evaluated Historic Properties, if any, within the Area of Potential Effect (APE) for visual and direct effects as directed in Section VI.D.1 and 2 of the Nationwide Programmatic Agreement, effective on March 7, 2005. We have found no properties listed in the National Register of Historic Places (NRHP) within either APE.
ECA researched the files at the Georgia Historic Preservation Division (GAHPD) on March 28, 2017 and April 3, 2017. No resources were identified during ECA’s review of the Historic Resources Survey Files, National Register Files, Centennial Farms Files, and Environmental Review Files. Also, the University of Georgia’s Natural, Archaeological, and Historic Resources Geographical Information System (NAHRGIS) identified no additional historic resources within the alternative APE for visual effects. However, based on our review of the Identified Site Files, the proposed undertaking would be located within the boundaries of Historic Dunwoody which appears to be a broad study area encompassing most of the City of Dunwoody for a student project. No assessment of eligibility was provided for the study area or individual resources identified within the study area.
An Archaeological Assessment was conducted within the APE for direct effects. During our database research, we found one previously identified archaeological site (9FU634) and twenty-one surveys (907, 2609, 2615, 2629, 2642, 2643, 2644, 2648, 2854, 3208, 3584, 5415, 5710, 5731, 5733, 5793, 5960, 7970, 8099, 8912, and 9500) within a 1-mile background research radius, but outside the APE for direct effects. The previously recorded survey 3584 encompasses the proposed project area; however, the survey did not identify any archaeological sites within or
near the APE for direct effects. None of the remaining surveys nor the previously recorded archaeological site are located within or near the APE for direct effects. During our fieldwork, we uncovered no archaeological sites (see Attachment E-1c). Based on our findings, we recommend no further consultation under Section 106 Review of the National Historic Preservation Act for this proposed undertaking. Based on this documentation, prepared in accordance with the Nationwide Programmatic Agreement effective March 7, 2005, ECA believes that this proposed facility would have no effect on any Historic Properties identified in accordance with the NPA. Therefore, we
recommend a finding of "No Effect" for the proposed undertaking.
We are submitting this letter for AT&T Mobility, LLC to seek concurrence with this finding and to comply with Federal Communications Commission (FCC) requirements as identified in 47 CFR 1.1307. We request your concurrence with our finding. Please contact our office with any questions or comments.
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