Section 106 Review TCNS ID 202494 Proposed 149-Foot Monopole Telecommunications Structure (153-Foot Overall Height Including Appurtenances) Harry Driggers 241 Innovation Drive Brunswick, Glynn County, Georgia ECA Project No. W0673

Environmental Corporation of America’s (ECA) client, SandCo Towers, LLC is proposing to construct a telecommunications facility as described in the following FCC Form 620, New Tower (NT) Submission Packet. ECA understands that SandCo Towers, LLC plans to construct a 153-foot tall (overall height) monopole telecommunications structure within a 80-foot by 80- foot (24-meter by 24-meter) lease area. The proposed lease area would be accessible by a proposed approximate 1,025-foot long by 30-foot wide (312-meter by 9-meter) access/utility easement. ECA was unable to research the files at the Georgia Historic Preservation Division (GAHPD) due to mandated self-quarantine protocols associated with the global COVID-19 Pandemic. Therefore, ECA researched on the University of Georgia’s Natural, Archaeological, and Historic Resource Geographic Information System (GNAHRGIS), and we identified no known Historic Properties within the ½-mile Area of Potential Effects (APE) for visual effects. As a result, no Historic Properties that are eligible or are known to be eligible for listing in the NRHP were identified within the project’s visual Area of Potential Effects. As noted above, although no Historic Properties known to be eligible or listed in the NRHP were determined to be located within the APE for visual effects, ECA notes a historic canal (Brunswick-Altamaha Canal) is identified on the Darien, GA (1993) topographic map. While the NPA states "Applicants are not required to undertake a Field Survey or other measures other than reviewing... records" (as available at the offices of the SHPO/THPO or that may be found in publicly available sources identified by the SHPO/THPO), a search of available consultant surveys online shows that multiple consultants have determined this resource to be eligible for the NRHP. As such, ECA considers it to be a probable Historic Property (i.e. one with a high probability of having been previously determined by the GA HPD to be NRHP eligible) and as such, has assessed visual effects to the Brunswick-Altamaha Canal out of an abundance of caution. ECA respectfully notes that field survey for the identification of Historic Properties in the APE for Visual Effects was not completed and is not required as per the NPA. Brunswick-Altamaha Canal (GNAHRGIS 9599) runs from the northeast to the southwest and is located approximately 2,050 feet (625 meters) west of the project area at its nearest point. However, due to private properties, ECA was able to photograph the Brunswick-Altamaha Canal from approximately 2,675 feet (815 meters) northwest of the project area. The proposed tower would not be visible from the Historic Property due to intervening vegetation. ECA notes the presence of mature vegetation lining the location of the probable Historic Property throughout the APE for visual effects. Therefore, ECA believes that the project would have no effect on the Brunswick-Altamaha Canal. A photograph of the resource and a view toward the proposed undertaking are identified as Photographs 1a and 1b in Attachment B-1b/c. 

An Archaeological Assessment was conducted within the APE for direct effects. During the database research, we identified five previously recorded archaeological sites (9GN213, 9GN272, 9GN313, 9GN442, and 9GN443) and four archaeological surveys (1693, 6785, 9599, and 13889. None of the sites or surveys were located within the APE for Direct Effects. During our fieldwork we uncovered no archeological cultural artifacts (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.