Twilight Towers Co-location Resolution Hits Snag


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The Advisory Council on Historic Preservation (ACHP) says it needs more time to work out a resolution with the FCC to address co-location of wireless equipment on twilight towers.  

These towers, built between March 16, 2001, and March 7, 2005, do not have documentation to prove they’ve undergone the required review under Section 106 of the National Historic Preservation Act. The FCC asked the ACHP for input, but the group says the proposal didn’t address the problem, the group told the agency.

In its October 5 vote, ACHP members agreed that 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. However the group took issue with the proposal as submitted, calling it “substantially deficient.”

“A fundamental concern among states and Indian tribes, as well as many of our members, was the lack of sufficient measures to consider past and ongoing effects to historic properties that may have occurred as a result of the original construction of these towers, and the lack of clear measures to resolve such effects when or if they are identified,” ACHP Chairman Aimee Jorjani said in a letter to FCC Commissioner Brendan Carr. “The need for such measures were underscored by the indications we received in consultation with states and Indian tribes that numerous twilight towers which may be having lasting effects to historic properties are known, and efforts to resolve such effects have been unsuccessful.”

The ACHP also cited the lack of information on the tower numbers, locations, and potential for past or existing adverse effects to historic properties. It also said it was unclear how the agency would handle complaints about twilight towers, and whether those would be timely handled.

Yet, the ACHP said it’s committed to assisting the FCC in developing an appropriate solution to enable co-location of additional antennas on these existing structures. “Given that 46,000 towers were approved and constructed in 2019 (according to CTIA), I believe it an entirely reasonable and achievable goal to develop a simple process now, in collaboration with FCC, that would enable co-locations on 4,000 – 5,000 in a timely manner,” said Jorjani.

The ACHP urged the agency to consider a streamlined process for reviewing the underlying twilight towers when they are being proposed for co-location, along with a detailed process for State and Tribal Historic Preservation Officers, Indian tribes, Native Hawaiian organizations, and the general public to file complaints about specific twilight towers and have such complaints resolved in a timely fashion. The membership proposed 90 days to work on this effort, to start from the FCC’s acceptance of the offer, with a vote on a revised program comment to follow shortly afterward.

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