TCNS ID 97631 Proposed Collocation on an Existing 150-Foot Monopole Telecommunications Structure (161-Foot Overall Height) and Lease Area Expansion

Environmental Corporation of America (ECA) has completed Section 106 Review documentation, and FCC Form 621, for our client, Crown Castle USA, Inc., concerning the proposed collocation at 2025 Monier Road. Lithia Springs, Douglas County, Georgia. Crown Castle USA, Inc. is proposing to mount additional antennas at a height of 105 feet on an existing 161-foot tall (overall height) monopole tower. The tower height would not be extended. The existing fenced compound would be expanded an additional 23 feet by 34 feet (7 meters by 10 meters). The tower center is located at approximately N33° 46’ 11.9” W84° 38’ 25.2” (UTM: Zone 16 718519E 3739154N). A site reconnaissance to document the existing tower and compound expansion was conducted by Travis B. LaForge of ECA on August 8, 2013. ECA has identified and evaluated Historic Properties, if any, within the Area of Potential Effect (APE) for visual effects as directed in Section VI.D.1 and 2 of the Nationwide Programmatic agreement (NPA), effective on March 7, 2005. We have found no properties listed on the National Register of Historic Places (NRHP) within the APE. Therefore, we believe no NRHP eligible archaeological sites will be impacted by the proposed undertaking. A review of the Georgia Historic Resource Survey files revealed two previously identified standing structures within the ½-mile APE for visual effects. None of these structures were located near or within the APE for direct effects. There is no tower height extension associated with the proposed undertaking. Furthermore, based on distance and intervening vegetation, ECA does not believe that the collocation would be visible from the two identified historic resources (see Attachment B-1b/c). Therefore, ECA believes that the proposed undertaking would have no effect on the identified historic resources. The Georgia Archaeological Site File (GASF) is the official repository for information about known archaeological sites from all periods within the state of Georgia. We conducted a database research within a ¾-mile background research radius for previously identified archaeological sites and surveys. Two previously recorded archaeological sites (9DO4, 9DO30) and five archaeological survey reports (789, 800, 1137, 3800, 4546) were located within the ¾- mile background research radius of the project area. The two identified sites and three of the surveys were not located within or near the area of direct effects. However, two of the previously recorded surveys reports (789, 800) are located within the area of direct effects. Survey report number 789 was conducted for a rerouted transmission line corridor and associated substation. The lease area for the proposed undertaking is encompassed by this previously identified survey. However, there are no identified archaeological sites or historic resources associated with survey report number 789.

Survey report number 800 was also conducted for a transmission line corridor and substation. The lease area for the proposed undertaking is encompassed by this previously identified survey. There are three isolated artifact occurrences associated with survey report 800; all were previously determined to be not significant. Furthermore, none of the isolated artifact occurrences are located within the area of direct effects for the proposed undertaking. The APE for Direct Effects for this project consists of the proposed approximate 23-foot by 34- foot (7-meter by 10-meter) lease area expansion. Based on the extent of the proposed undertaking, ECA originally determined that 1 shovel test pits would be an adequate sampling of the APE for direct effects. The shovel test pit was placed near the center of the proposed undertaking.

Generally, ECA excavates shovel test pits that measure approximately 16 inches ( 41 cm) by 16 inches (41cm) in size, excavated to a depth of approximately 36 inches (91cm), or until sterile subsoil, bedrock, or the water table is encountered. Soils associated with the proposed project area are Madison gravelly sandy clay loam series, 6 to 1 0 percent slopes. Known subsoils for the Madison series occur at depths between 9 and 30 inches (23-76cm) and consist of red (2.5YR 4/8) clay. All excavated soils are screened through a six-millimeter wire mesh archaeology screen to isolate any cultural artifacts. The location of the shovel test pits are shown in Attachment B-2c. Shovel Test Pit One (STP I) consisted of gravelly sandy loam with a Munsell color of 1 OYR 5/4 (yellowish brown) from 0 to 2 inches (0 cm to 5cm) below ground surface . From 2 to 10 inches (5cm to 25cm) below ground surface clay with a Munsell color of2.5YR 4/8 (red) was observed. These observations are generally consistent with the Madison soil series, and it was determined that sterile subsoil had been reached. Further excavation of the shovel test pit was terminated at this point. No NRHP-eligible archaeological sites or features were identified during ECA's subsurface investigation. 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 NP A. Therefore, we recommend a finding of "No Effect" for the proposed undertaking as it relates to archaeology.