Form 620 and 621: What happens if there’s historic properties?


Most construction and development companies fear the discovery of historic properties. I’ve talked to dozens of construction head honchos and project managers that absolutely dread the thought of finding a historic building or archaeological site where they propose to build something because it will require them to re-think some major elements of their plan. Sometimes the plan will have to change. Sometimes it won’t. Either way, there’s nothing to be afraid of if a historic property is found in your project area.

Here are three things to think about that may help anyone trying to complete a Form 620 or 621—the cultural resources requirement for building or collocating upon a communications tower in the United States—address effects to historic properties.

Is the historic structure “eligible for listing in the National Register?”: Just because an old building or archaeology site is identified in your project area, it doesn’t mean a significant historic property has been discovered. Form 620 and 621 are an extension of Federally mandated cultural resources compliance that have very specific description of what is considered a significant historic property that may be recommended eligible for listing in the National Register of Historic Places (click here to see a description of what may be considered a historic property for Form 620 and 621). You can go here to see what the Federal government considers a National Register-eligible historic property under Section 106 of the National Historic Preservation Act (NRHP).

Is your project going to adversely affect historic properties?: Again, not all communication tower projects are equal. Building a communication tower has two main effects: disturbing the ground and changing the visual landscape of a given area. In the case of an archaeology site, ground disturbing activities (ex. leveling the ground, digging for the tower’s foundation, and building roads) are most likely to effect the archaeological deposits. The opposite is true for historic buildings. The visual impact from the tower is more likely to affect a historic building, district, or traditional cultural property.

How can you mitigate any impacts?: Can you re-site the tower? Change its height? Disguise it as a cactus or tree? Maybe the local government allows you to mitigate impacts by having a parcel trade or rehabbing some shabby historic buildings nearby. Sometimes you have options that will still allow the project to move forward without delay.

Creativity is Key

Oftentimes, the key to mitigating impacts to historic properties is creativity between the companies that want to build the communication tower, local governments, and local residents. I have seen myriad ways construction projects have gone forward without having to dig up an archaeology site or fight a law suit with angry local residents. The Federal laws regarding historic properties are quite flexible, especially regarding archaeology sites. They were designed to protect our most important cultural resources while allowing us to build our country in the future. Digging up an archaeology site is just one way to mitigate impacts, but creative companies and government agencies have come up with hundreds of other solutions.

Remember, finding an archaeology site or historical building in your project area isn’t the end of the world. Form 620 and 621 is just a tool we can use to find any historic properties that may lie in the path of a communication tower project. Work closely with your cultural resources subcontractor to figure out a way to keep your project on track.
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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