FCC Proposing Changes to 106 Compliance Forms

02/18/2020 2:47 PM | ACRAsphere Blog Team

The Federal Communications Commission (FCC) is seeking comments on forms regularly used by Section 106 practitioners. Forms 620 and 621 are used to inform stakeholders, including SHPOs, THPOs, Native Hawaiian Organizations, and other reviewers, of certain proposed wireless infrastructure projects. The reviewers use the information provided in the forms to assess potential effects of such projects on historic properties. 

From the FCC Public Notice:

Forms 620 and 621 have not been substantially revised since they were created in 2004.2 In light of technological and regulatory changes since then, as well as many years of experience using the forms, we believe it should be possible to make them easier to complete and to review without impeding their underlying purpose. 3 Clarifications to the instructions for the forms also may be useful.

Form 620 is used for proposed new towers; Form 621 is used for proposed collocations on existing structures. These forms and the instructions accompanying them require applicants to submit information that is required by the Wireless Facilities NPA for each proposed new tower or collocation. We seek comment on whether to modify any of the forms’ organization, format (including format for downloading or printing out forms), or instructions (including specifications of required attachments). We also invite commenters to address potential changes that might make the forms or attachments more suitable for reviews of small cell facilities being deployed in connection with the introduction of 5G technologies and services.

The FCC is particularly seeking comment on whether the review process can be improved with modification to the following sections:

  • Identification of Applicant and Consultant
  • Site Location
  • Information About the Proposed Deployment
  • Information About Historic Properties

Read the full Public Notice for more information on the feedback the FCC is looking for and for submission instructions. ACRA will be submitting comments as an organization, and members are encouraged to comment in an individual capacity as well. Comments must be received by March 28, 2020.

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