Tag Archives: NEPA review

Small Cells / Distributed Antenna Systems

Throughout United States


Wireless companies building out small cell networks or in-building systems are required to consider whether their proposed actions may have an adverse effect on historic resources. G2 Consulting Group performs regulatory compliance reviews and tribal consultations for proposed small cell and distributed antenna system (DAS) facilities. These reviews ensure our clients conform with the Federal Communications Commission’s (FCC) Nationwide Programmatic Agreement (NPA) requirements. In the case of DAS installations, hazardous materials (asbestos and lead) surveys and/or abatement work may be warranted to facilitate the safe installation of equipment associated with the DAS. G2 oversees both hazardous material surveys and abatement projects for clients in the telecommunications sector.

Fast Facts

Project Owners

Tower and Fiber Companies, Carriers, and Wireless Service Providers

 G2 Services Provided

Section 106 Review

National Environmental Policy Act Review (NEPA)

Tribal Consultation

Hazardous Materials (Asbestos/Lead) Surveys for In-building Systems



    • G2 assists our clients with interpretation of both the applicable regulatory framework set forth in the FCC’s Nationwide Programmatic Agreement for the Collocation of Wireless Antennas (most recently amended in August 2016), as well as, any carrier-specific processes associated with regulatory review for proposed small cell sites.
    • G2 quickly reviews site information (i.e., project type, pole height, equipment volume, etc.) and the proposed location of small cell nodes to ascertain if they meet criteria for any exemptions from Section 106 Review under the most recent FCC guidelines.
    • G2 provides a written summary with supporting documentation (i.e., state and local maps depicting historically sensitive areas, National Register of Historic Places review, etc.) to clients indicating regulatory compliance due diligence has been completed and no further actions are warranted. If sites are determined to be on or within a designated historic resource, G2 works with an architectural historian, as well as, local, state, and tribal agencies, to achieve a favorable determination or advise clients in the early planning process if a site may involve complications.

Smart. Results. Fast. Telecommunications projects are extremely time-sensitive. G2 conducts thorough Section 106 and NEPA Reviews expediently to provide information to identify sites that require additional regulatory due diligence work in order to maintain client schedules.  Additionally, G2 offers input to clients with respect to site design and/or location to meet certain exemption criteria for Section 106 or NEPA Reviews to minimize costs.


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 wirelessestimator.com, 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.


Environmental Investigations for Telecommunications Towers

Throughout United States

Environmental studies are required prior to construction of telecommunications tower facilities. Often, these studies are critical to the project schedule.  G2 has provided environmental due diligence and regulatory evaluations for telecommunications clients and architectural/engineering firms throughout the United States.

Fast Facts

Project Owner

Tower companies, carriers and wireless service providers

G2 Services Provided

Phase I Environmental Site Assessment
National Environmental Policy Act (NEPA) Review
Environmental Assessments
Environmental Permitting


      • While some properties being considered for telecommunications projects are located in remote areas, others include past uses that may present liability to the next owner if not documented. G2 conducts Phase I Environmental Site Assessments for proposed telecommunication tower facilities in accordance with requirements to identify recognized environmental conditions and recommend appropriate follow up to protect our clients.
      • As a licensing agency, the FCC complies with National Environmental Policy Act (NEPA) by requiring the licensees to review their proposed actions for environmental consequences. Because telecommunications projects are regulated by the FCC, NEPA Reviews are required for proposed sites. G2 performs NEPA Reviews to determine whether the proposed construction is located within an environmentally and/or culturally sensitive area. If the proposed site falls within this category, G2 continues and prepares an Environmental Assessment (EA).

Smart. Results. Fast. Telecommunications projects are extremely time-sensitive. G2 conducts thorough environmental assessments and NEPA Reviews expediently to provide information required to make the site purchase decision and maintain an aggressive schedule.