Environmental Corporation of America's (ECA) client, Goodman Networks Inc, on behalf of AT&T Mobility, is proposing to construct a telecommunications facility consisting of a 150-foot monopole telecommunications structure (160-foot overall height) within a proposed 315-square foot (29-square meter) lease area as described in the following FCC Form 620, New Tower (NT)Submission Packet. The proposed telecommunications compound would be accessible via an existing paved parking lot. New equipment (cable tray) will be placed on a concrete pad within an adjacent existing AT&T telecommunications compound. A proposed 75-foot by 2-foot (22-meter by x 1-meter) underground conduit (utility easement) will be routed from the new equipment cable tray to the proposed facility. 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 or eligible for the National Register of Historic Places (NRHP) within either APE. Based on our review of the Historic Resource Survey Files at the Georgia Historic Preservation Office (GA HPD), we identified several Historic Resource Surveys for Chatham County and the City of Thunderbolt. A 1991-1993 resurvey of the City of Thunderbolt prepared by Beth Reiter of the Savannah Metropolitan Planning Commission, along with the University of Georgia's Natural, Archaeological, and the Historic Resources Geographical Information System (NAHRGIS) identified 46 historic resources within the ½-mile visual APE of this project. The surveyed resources correspond with those recorded in NARGIS; however, the 1991-1993Thunderbolt survey also revealed that several NAHRGIS resources were incorrectly plotted and labeled. Therefore, the 1991-1993 Thunderbolt survey was relied upon as the definitive source for the purposes of resource identification. Due to location, distance, and similarities of the properties, ECA choose to treat the 46 historic resources (CH-TH-1 though CH-TH-46) within the ½-mile APE as a Multiple Resource Assessment Area, referred to as ECA Resource 1. Resources located within the boundaries of this Multiple Resource Assessment Area may be individually eligible for listing on the NRHP. ECA's site visit revealed that seven resources (CH-TH-12, 16, 34, 35, 41, 42, and 44) are no longer existing. Therefore, the proposed telecommunications facility would have no effect on these non-existent structures. ECA chose to select representative Photograph Locations from which to conduct view shed assessments toward the proposed facility from ECA Resource 1 in order to evaluate the visual effect, if any, the proposed facility might have on the ECA Resource 1. The locations chosen are labeled on the topographic map included in Attachment B-2a-i. The majority of ECA's view shed assessment is focused on the historic properties located closest to the proposed undertaking. Resource photographs and views toward the proposed tower from selected locations are included in Attachment B-1b/c. ECA Resource 1- ECA Resource 1 has irregularly shaped boundaries, but is roughly bounded by Shell Road, River Drive, Dogwood Ave, the canal, U.S. Highway 80, and Mechanics Drive. Boundaries of ECA Resource 1 are outlined in Attachment B-2a. The proposed telecommunications facility is located within the boundaries of ECA Resource 1. Based on ECA's site visit, we believe that the proposed telecommunications facility would be visible from photograph location 9B. However, due to intervening modern structures (such as utility lines and power poles, and the presence of an existing water tower with antenna collocations) and intervening vegetation, we believe the proposed undertaking would have no effect on historic resources located near photograph location 9B. Additionally, we believe that the proposed telecommunications facility would be minimally visible from the closest locations along Russell Street, but would not be visible from the majority of ECA Resource 1 due to distance, intervening modern structures (such as utility lines and power poles) and intervening vegetation. Therefore, we believe the proposed undertaking would have no effect on ECA Resource 1. An Archaeological Assessment was conducted within the APE for direct effects. During our database research, we found three previously recorded archaeological sites (9CH871, 9CH1223, & 9CH1224) and two archaeological survey reports (617 & 5138) within ¾-mile background. An Archaeological Assessment was conducted within the APE for direct effects. During our database research, we found three previously recorded archaeological sites (9CH871, 9CH1223,& 9CH1224) and two archaeological survey reports (617 & 5138) within %-mile background research radius of the subject site. However, no sites were identified within or near the APE for direct effects. During our fieldwork, we uncovered no archaeological cultural artifacts (see Attachment E-lc). 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 NP A. Therefore, we recommend a finding of "No Effect" for the proposed undertaking. We are submitting this letter for Goodman Networks Inc., (on behalf of AT&T Mobility) 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.