NTCA and ACA Connects Support Simplified Historic Preservation Reviews for Federal Broadband Projects

NTCA—The Rural Broadband Association and ACA Connects—America’s Communications Association strongly support the proposal to amend a “program comment” issued by the Advisory Council on Historic Preservation (ACHP) in 2017. Recognizing that telecommunications undertakings “typically [do] not result in adverse effects to historic properties,” in 2017 the ACHP adopted a streamlined process for communications providers’ compliance with Section 106 of the National Historic Preservation Act for the installation of certain categories of wireline and wireless communications infrastructure on federal lands and property. At the request of the National Telecommunications and Information Administration, ACHP now proposes to expand the applicability “from certain Property Managing Agencies and Land Managing Agencies to any federal agency providing funding, licenses, authorizations and approvals for projects that meet the terms.” The Associations hereby submit the following comments on the proposal:

• The proposed amendment will enable broadband providers to meet the broadband availability goals established by the Administration and Congress while protecting and preserving this Nation’s historic legacy. 
• Adoption of the proposed amendment should also include clarifications as to its applicability and scope to ensure the process is utilized as often as possible by agency staff.