Although expanding and improving coverage is a priority for any wireless carrier, speeding up the tower siting process is especially important for carriers that will need to construct more towers to meet E911 location accuracy requirements. Carriers should therefore consider the benefits of using the FCC’s newly launched voluntary internet-based electronic filing system, which will enable licensees and tower proponents to complete the historic review process for the proposed construction of communications facilities under the Nationwide Programmatic Agreement on Tower Siting and Historic Preservation (NPA). The new system is designed to eliminate administrative burdens and streamline the process of clearing communications towers under the NPA.

The NPA applies to any applicant (including some users of “unlicensed” transmitting devices) proposing to construct a new communications tower, modify an existing tower, or collocate an antenna on an existing tower, regardless of whether it is associated with a site-based or geographic license. Licensees and other companies involved in tower construction should implement full compliance procedures for this complex process, which should be initiated several months in advance of construction. Instead of merely assuming that no historic properties will be affected, applicants must take affirmative steps to confirm that construction will not have an adverse effect on historic properties. Failure to adhere to these procedures exposes an FCC licensee to sanctions, including monetary forfeitures or even, in extreme circumstances, an order to dismantle the tower and/or license revocation.