Environmental Corporation of America's (ECA) client, Providence Real Estate Consulting, LLC (on behalf of AT&T Mobility, LLC) is proposing to collocate antennas at a centerline height of 105 feet above ground level (AGL) on an existing 144-foot tall monopole telecommunications structure located at 3865 Peachtree Industrial Blvd., Duluth, Gwinnett County, Georgia. Newly proposed ground-level equipment would also be installed within a proposed 40-foot long by 8-foot (12-meter by 2-meter) lease area immediately northwest of the existing fenced monopole telecommunications facility. The subject undertaking is described in the following FCC Form 621, Collocation ("CO') Submission Packet. ECA has discovered possible evidence that the proposed collocation falls outside the categorical exclusions provided by Stipulation IV.A.1-4 of the Nationwide Programmatic Agreement for the Collocation of Wireless Antennas (Collocation NPA) signed into effect on March 16, 2001. Specifically, the installation of the proposed fenced equipment compound within the proposed 40- foot by 8-foot (12-meter by 2-meter) lease area will involve new ground disturbance. In accordance with FCC guidelines and the stipulations contained within the Collocation NPA, and at the request of Providence Real Estate Consulting, LLC (on behalf of AT&T Mobility, LLC), this Section 106 Dr. David Crass Review was prepared for the proposed undertaking to account for new ground disturbance outside of the existing fenced compound. 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. Based on our review of the files at the Georgia Historic Preservation Office (GA HPD), we identified no historic resources located within a ½-mile APE for visual effects. No historic resources were identified in the survey files, Identified Site Files, Environmental Review Files or in the Centennial Farm Files within the ½-mile APE for visual effects. The University of Georgia's Natural, Archaeological, and Historic Resources Geographical Information System (NAHRGIS) did not identify any historic resources within a ½-mile APE for visual effects. An Archaeological Assessment was conducted within the APE for direct effects. During our fieldwork we uncovered no archaeological 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 collocation 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 Providence Real Estate Consulting, LLC (on behalf of 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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