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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.