Sprint Site AT999XT107 (UGA Football) Off Cemetery Street

Environmental Corporation of America’s (ECA) client, SprintCom, Inc. is proposing to construct a 90-foot tall (overall height) temporary cell on wheels (COW) telecommunications structure. The purpose of the temporary COW is to provide increased cell reception during the fall 2020 football season. The proposed project would also include a 30-foot by 40-foot by 40-foot by 40- foot (9-meter by 12-meter by 12-meter by 12-meter) temporary fenced compound to accommodate the platform, as described in the following FCC Form 620, New Tower (NT) Submission Packet.

The facility currently consists of a fenced compound surrounding a 90-foot tall temporary cell on wheels Telecommunications structure. In the previous football seasons, the COW was located between the Central of Georgia Railroad Company Railway and the Oconee Hill Cemetery. At the time of our visit, it was moved within the boundaries of the Oconee Hill Cemetery

temporarily this year due to a dispute with the current landowner. No ground disturbing activity took place when the cell on wheels was moved to its current location, flush against the cemetery fence. The proposed COW location for the 2020 football season would be located at the entrance to the Oconee Hill Cemetery in an area of ornamental vegetation that is devoid of burials. The only ground-disturbing activity would be the installation of a power meter. Due to the limited height of the tower, the temporary nature of the COW, and intervening structures, a reduced area

of potential effects (APE) for visual effects would be expedient. A 750-foot APE for visual effects was determined by the Georgia Historic Preservation Division.

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. One Historic Property, the Oconee Hill Cemetery (NRHP# 13000291, CA-8-31/32) listed in the National Register of Historic Places (NRHP) was identified within the APE of direct effects. Based on our review of the files at the Georgia Historic Preservation Division (GAHPD) and theUniversity of Georgia’s Natural, Archaeological and Historic Resource Geographic Information System (NAHRGIS), we identified three historic resources, Memorial Hall (CA-8-27, 4547), Milledge Hall (CA-8-33, 4551), and Payne Hall (4556) within the 750-foot APE for visual effects that have not been previously evaluated for NHRP eligibility. In addition, a railroad was also identified within the visual APE. The Central of Georgia Railway has been determined eligible for the NRHP by GAHPD.

Oconee Hill Cemetery (NRHP# 13000291, CA-8-31/32) was listed on the NRHP in May 2013and encompasses 99-acres east of the University of Georgia. The cemetery was established in 1856 and has numerous forms of decorative burial monuments reflecting popular styles from 1856 to 1963. The proposed undertaking is within the boundaries of the Oconee Hill Cemetery, south of the entrance off East Campus Road. It is the opinion of ECA that the proposed

undertaking would have no adverse visual effect on the Oconee Hill Cemetery even though the temporary COW would be located within the Oconee Hill Cemetery due to its temporary nature and limited visibility throughout the majority of the property. The proposed undertaking will be placed in an area of ornamental vegetation that is devoid of burials adjacent to Cemetery Road.

With these considerations made, it is ECA’s opinion that the proposed undertaking would have no adverse direct effect on the Oconee Hill Cemetery. Central of Georgia Railway historically ran from Savannah, Georgia to all major cities in Georgia and branched out as far as Birmingham, Alabama and Chattanooga, Tennessee. The Central of Georgia Railway began in the 1830s and grew until the 1890s into its current branch map. The railway was purchased by Southern Railway in the 1960s and now operates under Norfolk Southern. The portion of the Central of Georgia Railway that runs parallel to the proposed undertaking is no longer in use. GAHPD has determined that all linear resources, such as the Central of Georgia Railway, are eligible for listing in the NRHP. Though the proposed

undertaking would be visible from the immediately adjacent portions of the Central of Georgia Railway, the temporary nature of the COW means it would only be present and visible during the fall football season. In addition, modern utility poles and modern university buildings, such as the football stadium, are within the viewshed of the Central of Georgia Railway. As the proposed undertaking is not a permanent structure, it is ECA’s opinion that the proposed undertaking would have no effect on the Central of Georgia Railway.

An Archaeological Assessment was conducted within the APE for direct effects. During the database research, we identified twenty previously recorded archaeological sites (9CA67, 9CA79, 9CA86, 9CA116, 9CA119, 9CA131, 9CA132, 9CA139, 9CA173, 9CA174, 9CA175, 9CA178, 9CA182, 9CA200, 9CA207, 9CA216, 9CA220, 9CA221, 9CA222, and 9CA232) and twenty-seven survey reports (1775, 2961, 3403, 4414, 4437, 5791, 5823, 5847, 5848, 5850, 5898, 7074, 7388, 7611, 7648, 9403, 9654, 9654, 9685, 9689, 9950, 10294, 10297, 10299, 10300, 10301, 10304, and 10305) within our standard 1-mile background research radius, but outside of the APE for direct effects. Additionally, 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 facility would have no adverse effect on any Historic Properties identified in accordance with the NPA. Therefore, we recommend a finding of "No Adverse Effect" for the proposed undertaking. We are submitting this letter on behalf of Sprint Com, Inc. 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.