Category Archives: Geoenvironmental

Civil crew unearths archaeological remains at cell tower site

Ben Youra Project Manager G2 Chicagoland

Ben Youra
Project Manager
G2 Chicagoland

As reported this month in, a civil crew unearthed what was determined to be human remains while excavating at an existing cell tower site. It is believed the remains were part of an unmarked portion of an adjacent historic cemetery. According to the post, the tower is not registered in the FCC’s database.

While findings like this are extremely rare, this occurrence highlights the need to perform proper due diligence work on proposed tower sites during the National Environmental Policy Act (NEPA) Review process.  In 2015, G2 Consulting oversaw a project associated with a proposed tower site near Lexington, KY. During the NEPA-related work, over 35 pre-historic and historic artifacts were discovered during a Phase I archaeological survey.  The contracted archaeologist determined an enhanced scope of work to ascertain if any intact archaeological resources were present in the project site.

G2 facilitated coordination for concurrence on the enhanced scope of work seeking input from the Kentucky Heritage Council (SHPO), the FCC’s Federal Preservation Officer, and the consulting tribal entities for that area.

G2 worked with the various entities to agree on an approach in a timely manner. The Enhanced Phase I Archaeological Investigation determined that historical agricultural activities within the parcel had resulted in previous disturbance. It was determined that the project should proceed as development of the proposed communications tower would not result in disturbance of any intact historical resources.

G2 was able to utilize its experience to convey fieldwork findings to State, Federal, and Tribal entities and ultimately get clearance for the project with relatively minimal project delays.

G2 advises its clients in every NEPA Report, that should archaeological materials or human remains be encountered prior to or during construction of their telecommunications facilities, construction activities should cease and the SHPO, the Native American tribal entities, and other consulting parties must be contacted for further evaluation.


Telecom Carriers Expand Coverage with DAS • G2 Provides Environmental Due Diligence

Ben Youra Project Manager G2 Chicagoland

Ben Youra
Project Manager
G2 Chicagoland

In the last few years, wireless data traffic has increased exponentially. People are no longer only accessing the Internet at home or in the office, they are doing it wherever they are from their mobile device. Telecommunication carriers have come up with innovative ways to increase their network capacity. One solution is through the use of small cells. Distributed Antenna Systems (DAS) are another solution used to address the need for increased coverage and capacity of wireless networks.

DAS are typically associated with large facilities and venues that may have known peak usage (i.e., a sporting event or concert) as the systems are designed to address the potential for interference from building materials of the structure itself, as well as, simultaneous data usage from a large number of people in a concentrated area.  Thus DAS is a benefit to both the wireless carriers using the system, as well as, the venue owners in providing better service to smartphone users at these locations.
In 2016, G2 has provided environmental due diligence services in the form of Phase I Environmental Site Assessments (ESA), Phase II ESAs, and National Environmental Policy Act (NEPA) Reviews to its telecommunication clients proposing to install DAS at two venues in the greater Chicagoland area.
Our Phase I ESA for one of the projects found the site was utilized for heavy industrial purposes dating back to the 1950’s prior to the redevelopment of the parcel as a sporting venue in the early 2000’s. At least 16 underground storage tanks with two documented leaking incidents were associated with the historical industrial site within the overall property.  However, given the limited nature of the client’s proposed work below grade, we were able to tailor our scope of work for soil testing associated with the Phase II ESA to address only the areas to be impacted by the proposed telecommunications site development and to address the necessary parameters to satisfy the Illinois EPA’s Clean Construction and Demolition Debris requirements. The soil testing results were favorable and our client was able to proceed toward development of the site with no delays or extra costs incurred.

What do I need to know before I buy or lease that property?

Patrick T. Bell G2 Consulting Group Project Manager

Patrick T. Bell
G2 Consulting Group
Project Manager

“Buying or leasing a property is a significant commitment of money and time, says Patrick T. Bell, project manager at G2 Consulting Group. “One of the more stressful aspects of purchasing, owning or leasing property is what kind of investment is required to maintain the value and functionality of the property.”  G2 helps our clients determine its needs with a Property Conditions Assessment.

At G2 Consulting Group, we understand how real property conditions impact the business of our clients. Ownership of commercial property requires a continually evolving plan with regard to maintenance, repairs, and long-term capital planning. G2 offers Property Condition Assessments (PCAs) as part of due diligence for clients that may be purchasing, leasing, or simply maintaining a property. PCAs provide valuable information to help owners or potential owners understand what investment is required to maintain the value of a property.

G2’s project professionals follow ASTM E2018 guidelines, the recognized standard of major lenders. PCAs completed under ASTM standards provide estimates of probable costs for changes or repairs that require immediate attention. The PCA also provides opinions concerning probable costs to remedy physical deficiencies that need to be made in the near future, usually within the first year or two.

G2’s four-step PCA process includes:

  1. Walkthrough / Site Visit
  2. Interviews of key site personnel
  3. Document Review
  4. Analysis & Reporting


G2 Consulting Group will provide clients with a comprehensive Property Conditions Assessment Report that includes the following basic scope:


  • Topography and Storm Water Drainage
  • Access and Egress
  • Paving, Curbing and Parking
  • Flatwork
  • Landscaping and Appurtenances
  • Ancillary Structures

Structural Frame and Building Envelope

  • Foundation
  • Building Frame
  • Façades or Curtain Wall
  • Roofing

Mechanical, Electrical and Plumbing System

  • Heating, Ventilation and Air Conditioning
  • Electrical
  • Plumbing
  • Elevators and Escalators

Interior Elements

  • Common Areas
  • Tenant Spaces

Fire/Life Safety

  • Sprinklers and Standpipes
  • Alarm Systems



FCC to Amend Collocation Agreement Enabling Swift Deployment of Broadband Services


Ben Youra, Project Manager

The Federal Communications Commission’s (FCC) Wireless Telecommunications Bureau (WTB) issued a Public Notice on May 12, 2016 seeking comments related to their proposed “Amended Collocation Agreement”. The proposed Amended Collocation Agreement would offer additional exclusions from Section 106 of the National Historic Preservation Act (NHPA), given the limited potential for adverse impacts to historic resources from small cell and Distributed Antenna Systems (DAS) facilities. The FCC’s goal in providing the additional exclusions to the existing Collocation Agreement is to “enable swift and responsible deployment of wireless broadband services.”

The Amended Collocation Agreement would address streamlining deployment of small cells by providing new exclusions related to the following scenarios:

  • The collocation of small cell facilities on buildings and non-tower structures over 45 years old not in historic districts
  • The collocation of minimally visible small cell facilities on buildings and non-tower structures within historic districts or on historic properties (subject to certain visibility limitations)
  • The collocation of visible small cell facilities within historic districts or on historic properties (on utility poles/transmission towers, for in-kind replacements of existing equipment, and on a case-by-case basis for public lighting structures)

The proposed new exclusions for small cell facilities are subject to limitations related to volumetric size limits of the antennas and associated equipment, as well as, limitations on associated ground disturbance, and safeguards on the physical preservation of historic materials. The comment period with the FCC for the proposed Amended Collocation Agreement expires on June 13, 2016 and issuance of the Amended Collocation Agreement is expected later this year.

Please contact G2 to discuss how we can assist in determining how the existing or proposed FCC guidelines may impact your small cell/DAS projects.  Our staff can help in the planning of your projects to apply exclusions where applicable to limit the overall regulatory requirements associated with your small cell projects. Given our experience with regulatory oversight by the carriers, we can help set cost parameters and timelines based on the services that will be required related to any Section 106 review involving SHPO and/or tribal entities.

Below is a link to the FCC’s Public Notice page, which contains a copy of the proposed Amended Collocation Agreement:


Green infrastructure: the next chapter in water quality

Evan Pratt Washtenaw County Drain Commissioner

Evan Pratt
Washtenaw County Drain Commissioner

When water pollution control began in the 1970’s, the first target was industry – stopping discharges of chemicals into the waterways.  This was followed by addressing wastewater treatment, then mitigating the impacts of combined sewer overflow (CSO).  Most recently, pollution in stormwater has been targeted, with federal regulations for urbanized areas coming on line in the late 1990s.

People had realized that hard surface development led to flooding, and some of the first steps to regulate runoff also started in the 1970s.  First, management of stormwater addressed runoff rates, through means such as detention ponds, with the goal of maintaining pre-development conditions and preventing flooding.  This philosophy, however, often falls short.  Addressing only the runoff rate does not address total runoff volumes, which also can cause downstream damage.  Further, studies found that detention basins usually did not address runoff water quality.

As a result of the 40 years of work noted above, stormwater runoff from roads is now thought to be the biggest source of pollutants today.  While agriculture is in the news for phosphorous loads, roads bring us urban phosphorous from lawns along with over a dozen other common human toxins such as lead, cadmium, copper, iron, and nickel.  Research shows that if you can handle the first inch of rain running off of roadways, you can manage most of this pollutant load.  This philosophy is one of the key drivers behind Washtenaw County’s Stormwater Design Standards, which focus not only on controlling the rate of runoff, but also the quantity and quality of that runoff.

The goal of the program is to allow stormwater to soak into the ground to the extent possible.  This approach provides many benefits:

  • the developer often can reduce the land required for detention ponds and meet landscape requirements at the same time by using raingardens, bio-swales, and other green infrastructure
  • downstream streams experience less scouring, stream bank damage, and other water quality impacts,
  • cost savings result from the use of green infrastructure to handle stormwater instead of investing money in systems to convey or detain the runoff, and
  • natural environmental systems are used to the largest extent possible to do what they were created to do, such as routing rain into the groundwater table to cool it off and slow it down.

Data from the National Oceanic and Atmospheric Administration (NOAA) indicate that Michigan is experiencing heavier rains than in previously recorded times; rainfall totals and peak intensities are 10+% and 15+% respectively over the past 30 years, even greater over the past 55 years. More rain is falling because more falls when it rains, but the dry periods are longer too.  The use of green infrastructure such as rain gardens, bioswales, and infiltration beds help to absorb this additional rain with moderate investment.  Infiltration under roadways has also proven promising, especially where there is native sand or sand backfill for a utility.

To address these issues, the Washtenaw County Water Resources Commissioner started a robust public comment period in late 2013 prior to implementing the current Stormwater Design Standards in August of 2014 and will soon embark on a follow up opportunity to receive additional feedback on the program to help guide the future.   The Commission is bringing in a stakeholder group in the next couple of weeks to get input on modifications to what was adopted in 2014.  That has been a part of the overall plan all along – to implement based on a stakeholder group that included development consultants, developers, municipal consultants, and municipal officials, then to assume there would be a need for minor tweaks after a year or so of use.   The Commission is working with a user group from the applicant side and the municipal agency side, as the standards are adopted by most of the developing communities in Washtenaw County.

I have been very impressed by the reaction of the development community and the ability of the geotechnical engineering community to implement these design regulations.  Partnership from the geotechnical profession has been the critical foundation allowing  implementation to go as smoothly as possible – we couldn’t do this without firms like G2 offering value and turnkey consulting on infiltration feasibility.  Prudent developers have always performed soils investigations early in the project; now data from these inexpensive investigations deliver information to determine how the site can implement needed infiltration – a real benefit since sites are now required to provide 20 percent more detention if they do not infiltrate the first one inch.  At the end of the day, the sooner the owner knows about the soils on the site, the fewer surprises they will experience.  Most have learned to get soil samples before site purchase.

Other communities will be moving in this direction in the near future as well.  The Environmental Protection Agency (EPA) has provided guidance on requiring infiltration in the context of stream channel protection.  In turn the Michigan Department of Environmental Quality (MDEQ) is requiring infiltration for all urbanized areas through their Municipal Separate Storm Sewer System (MS4) permit program which is on a 5-year renewal cycle – Washtenaw was on year 2 of that cycle in 2014-15.  All urban counties and communities – including Kent, Macomb, Livingston, Calhoun, Oakland and Wayne – are already working on revisions to address this approach in their  permitting cycle.

In closing, I see the use of green infrastructure expanding in its role to reduce stormwater runoff.  In fact, we are very encouraged by research documenting the ability of vegetation to transform heavy clay into medium grade soils with absorptive abilities.  The County currently is providing technical support to over 300 rain gardens.  I am planning to take this program to the next step, working with developers to use green infrastructure in place of ponds (as long as it performs) to handle stormwater.  We are currently developing the science to back this approach.

Thoughts? Comments?  Questions?  Check our our website or shoot me an email.