Phase I Cultural Resources Survey GA-009 Fitzgerald (Candidate A) Wireless Telecommunications Facility Fitzgerald, Ben Hill County, Georgia

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 site is level and is located on an old building foundation and is covered by asphalt and concrete. The access road extends south from East Oconee Street for approximately 40 feet to the site. The proposed access road easement is covered with asphalt, concrete curbing, and various types of ceramic or rock tile and wood flooring. 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, not surprising as the project site is located on a small portion of the concrete foundations of a large, recently razed warehouse building. However, based on multiple lines of evidence gleaned from the background research, it is unlikely that any subsurface features or cultural deposits exist at this locale, and if any may have been present and not destroyed from construction of the warehouse in 1950, they would most likely be structural remnants. Probability was considered low, especially in terms of prehistoric cultural material, due to repeated episodes of construction and demolition, especially from the construction of the large warehouse building in 1950, likely destroying and/or displacing any previous historic features or structural remnants. 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. The former contains three NRHP-listed individual properties—the Ben Hill County Courthouse, the county Jail, and the Holtzendorff Apartments—and are contributing resources; this district also lies almost entirely within the APE for Visual Effects of the proposed undertaking. Based on a visibility and viewshed assessment, a large percentage of the Fitzgerald Commercial Historic District will be negatively impacted by the proposed undertaking, incurring an adverse indirect (visual) effect to this historic district and to two of the three individually listed properties. A much smaller percentage of the other historic district, largely residential in nature, is within the Visual APE, but will likely not be adversely affected due to distance, orientation of the resources, and intervening vegetation and tree canopy. Thus, this office recommends a determination of No Adverse Effect to the NRHP-listed Holtzendorff Apartments and the South Lee and South Main Streets Historic District, and a determination of Adverse Effect to the NRHP-listed Ben Hill County Courthouse, the Ben Hill County Jail, and the Fitzgerald Commercial Historic District.

Thus, in consideration of these findings, it is the opinion of Environmental, Inc., that Candidate A of the proposed GA-009 Fitzgerald Wireless Telecommunications Facility will create adverse indirect (visual) effects to multiple NRHP-listed properties and districts and located in the town of Fitzgerald and recommends a determination of Adverse Effect. 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.