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Telecommunications NEPA Compliance

The Situation

A nationwide tower company required environmental and cultural compliance support for a proposed 285-foot self-supporting lattice tower in Loysburg, PA. As part of the Federal Communications Commission (FCC) licensing process, the project triggered review under the National Environmental Policy Act (NEPA) and Section 106 of the National Historic Preservation Act (NHPA). During coordination with the Pennsylvania State Historic Preservation Office (SHPO), the FCC and SHPO determined that the proposed tower would result in an adverse visual effect to the nearby South Morrison Cove Historic District. The area was eligible for listing in the National Register of Historic Places (NRHP).

Our Solution

Eocene lead the full NEPA review and managed the Section 106 consultation process on behalf of the tower company. We initiated and coordinated review through SHPO and worked closely with both regulatory agencies and the client to address concerns related to historic resources. To resolve the adverse effect determination, Eocene collaborated with the tower company to develop comprehensive alternatives analysis documentation demonstrating efforts to avoid and minimize visual impacts on the historic district. We facilitated direct coordination among the FCC, SHPO and the tower company, ultimately guiding the project toward a mutually agreed-upon resolution.


This resulted in the development and execution of a Memorandum of Agreement (MOA), outlining mitigation measures required to offset impacts. Following MOA execution, Eocene was selected to implement mitigation stipulations, including conducting a historic resources survey of three villages within the South Morrison Cove Historic District—New Enterprise, Waterside and Woodbury. We also managed the collection and integration of survey data into PA-SHARE, SHPO’s GIS-based project management system, and produced a comprehensive architectural survey report detailing findings, including site plans, photographs, historic context, and supporting documentation.


  • 25,000 acres of land involved in mitigation
  • 150 historic resources were surveyed across three townships

Eocene’s proactive coordination and technical expertise have enabled the tower company to successfully navigate the complex Section 106 process. The executed MOA cleared the path for tower construction to proceed while ensuring that impacts to historic resources were appropriately addressed and mitigated. Through ongoing mitigation efforts, including detailed documentation and data reporting to SHPO, Eocene has contributed to the preservation and understanding of the South Morrison Cove Historic District.

Learn More About the Eocene Environmental Group Team/

Eocene has an experienced and passionate team of biologists, archaeologists, environmental planners, foresters, arborists, agronomists, animal scientists, sustainability risk specialists, software developers and engineers. Check out the “Our People” page to learn more about our team.

Our People