The Advisory Council on Historic Preservation (ACHP) has decided to decline to comment on the Federal Communications Commission’s (FCC) request for the ACHP to issue a Program Comment to address collocations of wireless equipment on “twilight towers.”

These towers, constructed between March 16, 2001, and March 7, 2005, cannot be documented to have undergone the required review under Section 106 of the National Historic Preservation Act. FCC proposed following its 2001 Programmatic Agreement for collocations on “twilight towers,” but this proposal did not address the lack of Section 106 review at the time of the original tower construction.

The ACHP membership believes the Program Comment as submitted is substantively deficient, and more time is needed to work with FCC and consulting parties to revise the proposal in a way that would provide a more appropriate resolution of the issues. 

In reaching this decision, ACHP members expressed their commitment to working closely with FCC and others to develop a revised Program Comment within a reasonable timeframe. Achieving resolution on the use of “twilight towers” is more important than ever, given the increasing reliance on broadband access for telehealth, remote learning, and public safety. The ACHP has worked to advance the nation’s broadband goals as a member of the Administration’s American Broadband Initiative. It has also worked with FCC specifically to achieve some of FCC’s improved communications goals.

ACHP Chairman Aimee Jorjani sent a letter to FCC Commissioner Brendan Carr in response to the FCC’s Program Comment request, detailing the members’ vote and requesting continued consultation to develop an acceptable Program Comment.


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