Form 620 and 621: What historic properties need to be considered?


If you’ve worked in cultural resource management, historic preservation, heritage conservation, or architectural preservation you’ve probably had the following conversation:

“What??!! That’s a historic property?  It’s just an ol’ pile of noun that means garbage. Who’d ever wanna preserve that piece of noun that means excrement? What the expletive is there to preserve? ”

It’s never pleasant, but verbal exchanges like this take place all the time during a wide range of projects. While it is sometimes difficult to explain why someone would want to preserve a historic property, it is much easier to explain what historic properties have to be considered in a communication tower’s Form 620 or 621.

Where does it specifically tell you what historic properties are?

Forms 620 and 621 are the required documentation for the construction, collation, or remodel of a communication tower or non-tower structure (click here for a better description of Forms 620 and 621). The “forms” are actually document packages that cover impacts to historic properties due to communication tower-related undertakings.

This document package has to be completed because communications towers must be approved by the Federal Communications Commission (FCC). Because the FCC is a Federal commission, all towers have to comply with Federal laws. Historic properties and cultural resources are addressed in the National Environmental Policy Act (NEPA) and the National Historic Preservation Act (NHPA).

The NEPA is comparatively vague when it comes to historic properties. Fortunately, they are well described in Section 106 of the NHPA.

What historic properties have to be considered for a Form 620 or Form 621?

As explained in the NHPA, historic properties are:

  • Districts, sites (think, archaeology), buildings, structures, and objects that;
  • Retain their integrity of location, design, setting, materials, workmanship, feeling, and association that;
  • Are at least 50 years old, or;
  • Of exceptional value (like Ground Zero at the World Trade Center);
  • Are valuable because they are A) associated with historic events, B) associated with important people, C) have distinctive stylistic characteristics, and/or D) have the potential to yield important prehistoric or historical data, and/or;
  • Are part of an intangible element of a culture’s heritage, arts, skills, folklife, or folkways.

These criteria may be vague for people that don’t work with this all the time like I do, but here are a couple of hypothetical examples:

  1. A house was built in the 1930s and kept in relatively good condition all the way into the present. Over time, the entire surrounding neighborhood was destroyed, as were most of the other buildings built in that town during the 1930s. This house is one of two 1930s houses left in the whole town and is an example of a historic property because it represents a unique architectural style that is rare in that town.
  2. A ranch was built out in the desert in 1870, but was abandoned after about 20 years. This ranch was the first one in that part of the county and no architectural remains of the buildings are left. However, all the trash deposited by the original residents is located in a trash pit along a nearby ditch. This trash pit was used for the entire 20 year occupation and was used by all the inhabitants before it was tightly covered up with dirt. The trash pit remains intact today. This ranch can now be considered an archaeology site and the trash pit has artifacts that can yield important information on the past.
  3. A mountain in a national forest has been used by a local Native American group for hundreds of years. It is part of their origin myth and is believed to be the home of their mother deity. The plants and animals on this mountain are considered gifts from the mother deity and are considered sacred. The mountain has been used by other people for the last 100 years, but many of the native plants and animals remain and are still used by the Native Americans. This mountain can be considered a sacred object, in this case a traditional cultural property, and is an important part of their cultural heritage.

Why does this matter for the Form 620 and Form 621?

Consideration of historic properties in communication tower projects is the primary reason Forms 620 and 621 exist. The two forms are the required documentation for FCC approval for the vast majority of communications towers. It is more difficult to try to move forward with a communication tower project without completing the forms. If done correctly, the 620 and 621 information packets will reveal any potential conflicts over historic properties that may result from a communication tower project. These conflicts can be avoided, mitigated, or reduced through collaboration between the project’s proponent and any adversarial groups.

Knowing what historic properties must be considered for a communication tower is the first step towards successfully fulfilling Federal regulatory requirements for historic properties and historic preservation.

I would really love to hear from you. If you have any questions or comments, write below or send me an email.

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