What goes into Form 620 and Form 621?

At 9AM it was already about 95 degrees with 85 percent humidity. I was walking with my crew through a muddy wash somewhere in Pima County, Arizona. It rained yesterday. The wash was a smoldering sauna. Fifty-foot high cliffs enveloped me on both sides as my boots slipped in the wet sand.

As we trekked through the wash, one of my co-workers stopped in his tracks. “Look,” he said wide-eyed. “Check out that petroglyph.” We all gathered around and stared. There it was. A swirled pattern etched into the cliff’s face about 10 feet above our heads. Amazing.

It was a noteworthy find. I wanted to properly record it and take tons of pictures. But, first, I needed to know if we were within our project’s area of potential effect. I turned on the handheld Trimble GPS only to see were about a half mile away from our project area—too far away to properly document the ancient find. I did take a GPS point and a couple photos so that we could figure out if the State of Arizona already knew about the carving, but this cultural resource wasn’t part of the job this time.

Knowing what is and isn’t part of your project is an essential part of cultural resources work, especially for Federal compliance work.

Form 620 and 621 is the code name for the cultural resources evaluation required for every communication tower in the United States (click here for a better description). Form 620 has six main requirements that must be completed as part of compliance with the FCC permitting process:

1)            The work must be conducted by a qualified cultural resource management practitioner. Form 620 and 621 include a review (and, sometimes, an evaluation) of historic properties as described in Section 106 of the National Historic Preservation Act (NRHP). Because this review has to comply with Section 106, the work has to be done by someone that meets the Secretary of the Interior’s Professional Qualification Standards (36 CFR 61).

For communications tower work, most construction and design firms will need an archaeologist, architectural historian, or historian that fulfills the professional qualification standards. Archaeologists are specifically required to assess any archaeological remains and architectural historians are important to address any effects to the built environment. Historians can provide expert witness services and background research on property boundaries and the spirit of historical land laws.

2)            The project location has to be well-documented. The applicant has to include detailed location information in Form 620 and 621. The form specifically asks for UTM coordinates (in NAD 83) and longitude and latitude. Many states also have regulations on how this information is displayed in the technical report included with the form. For instance, many states require project locations (for Form 620, that’s the communication tower location) to be illustrated on a USGS 7.5’ quadrangle map at 1:24,000 scale for all cultural resources reports.

3)            The communication tower specifications have to be described. You don’t need a full engineering specification, but you have to include the tower’s dimensions in Form 620 and 621. The tower’s height needs to be stated along with the size of the ground disturbing area, which is the tower’s pad and any access roads that may need to be built to the site.

4)            Native American or Native Hawaiians have to be notified. This land was their land before we came here, so Native Americans and Hawaiians may have sacred places that go back further than any non-Native can remember. In order to make sure a communication tower doesn’t impact a place they consider sacred, anyone trying to build or modify a tower has to send a letter to the local Native American and Hawaiian group notifying them of the planned project. In most states, they have 30 days to respond.

5)            Any identified historic properties have to be recorded and reported to the State. Form 620 and 621 provides a place to note the discovery of an archaeology site, historic building, traditional cultural place, or other cultural resource. In order for these properties to be properly documented, they require a site number or other identifier that is issued by the state historic preservation office. When a site number is issued, the state keeps track of the UTM coordinates of the new historic property for their records. The technical report generated under Form 620 has to be submitted to the state historic preservation office for review, which also informs the state of any newly identified historic properties.

6)            Any effects the communication tower will have on historic properties have to be assessed. This is done by the professional cultural resource practitioner after all the data has been collected for the Form 620 process.

Practice makes perfect

Over the past 9 years, I’ve become intimately familiar with completing cultural resource management and heritage conservation projects under local, state, and Federal regulations. The regulations are specific about what historic properties are and how they should be considered in construction projects (click here to learn more about what historic properties have to be considered in Form 620 and 621). Ultimately, it is up to a skilled professional to know how to handle historic properties for a given construction project.

The best cultural resource management professionals know what is and isn’t necessary for every project. By staying true to the project, they are able to effectively and accurately help their clients.

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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