Hello Everyone,

We are having our team meeting on Tuesday, June 27^th, 2-3:30pm.  Please register here:

https://us02web.zoom.us/meeting/register/tZYtdOGgrzgoG9wxQ1VccN_KAqL04OrLoQB1

We will focus our discussion on the Town Hall scheduled for Wed, June 28^th, 4-6pm.  The purpose is to alert preservation societies city-wide which may not yet be aware of the Sec 106 review and to clarify the process. CityBridge has told us that they will provide their preservation consultant to discuss the process.  We have invited the NY State Historic Preservation Office (SHPO) to also discuss the process. 

It is being sponsored by Wired Broadband, Inc. (non-profit), and co-sponsored by:

• Council Member Erik Bottcher
• Historic Park Avenue
• Manhattan Neighbors for Safer Telecommunications
• Mount Morris Park Community Improvement Association
• Silicon Harlem

If you would also like to co-sponsor, please let us know quickly.

Section 106 review under the National Historic Preservation Act is now underway by the Link5G tower site developer, CityBridge, in accordance with the FCC notice it received on 4-20-23 (attached).  The review focuses on historic districts and structures that are (1) listed on the National Register of Historic Places, and (2) "eligible" for listing on the National Register.

The Town Hall will stress the importance of applying for consulting party status if there are any such areas or structures in our districts. 

We have asked CityBridge to address the following questions (taking into consideration preservation societies which have not yet heard about this process), although there may be further questions during the Q&A:

· procedure for requesting consulting party status

· procedure for registering as a consulting party

· documentation that the party will be receiving

· how to file responses and documentation

· timelines for the above

· timeline for submission to SHPO

· timeline for determinations

· notice of determinations

CityBridge will be there for the first half to present and answer questions.  Afterwards, we will discuss additional resources to use in your analysis of adverse impacts.  One such source is the:

National Register of Historic Places at: https://www.nps.gov/subjects/nationalregister/database-research.htm.

Other sources include NYC library archives of different neighborhoods in NYC.

The initial process of applying for consulting party status and registering as a consulting party is listed below -- we’re re-sending information from last week about the process, as much as we know at this point:

First: Applying for Consulting Party Status 

Send email to:

NEPA-NHPA@link.nyc

Subject Line:  Request for Link5G Consulting Party Status

Fill in: YOU OR YOUR ORGANIZATION AND WHY YOU SHOULD BE A CONSULTING PARTY IN THE LINK 5G PROCESS

Our five NYC boroughs are chock full of historic sites and districts.  Section 106 reviews are required under federal law or any "undertakings" (including ALL FCC regulated wireless facilities) that might be proposed in designated historic "districts", buildings" or "landmarks."

Here is a layman's overview of Section 106:

https://www.achp.gov/sites/default/files/documents/2017-01/CitizenGuide.pdf

Second: Consulting Party Designation 

If you have been designated a "consulting party" to the Section 106 review of the LinkNYC 5G towers, here's how you can obtain access to the FCC's E-106 system, which will enable you to get information about the tower applications and submit comments.

The review is being conducted under the auspices of the Federal Communications Commission. The FCC likes to make things complicated but the process is actually more straight-forward than it seems; bear with it.

Once you are accepted as a consulting party, you should receive a message (copied below) from Marianne Walsh of E2 Project Management. (E2 is a consulting firm that is involved with administering the review; there are several consulting firms that are working on the review, so it's possible that your letter will be from a different consultant). Follow the instructions and send the FRN number, which you will receive instantaneously, to Marianne Walsh (or the consultant named in the message you received). If you haven't received such a message, go ahead and follow the instructions anyway. Send the FRN number to the consultant handling the towers in your area – you should have received an email from them earlier listing the relevant 5G tower locations. If possible, include the 10-digit E-106 "File Number" for each of the towers you are interested in. This number is listed in the tower notification you may have received from the FCC (towernotifyinfo@fcc.gov).

Once the consultant receives your FRN number, they will then enable you to access the FCC's E-106 system. This is the information portal that the FCC uses to distribute information about the towers and through which you will be able to submit comments. You will want to look for the complete "submission package" (also known as a "Form 106") for the towers that interest you. That package will consist of a 40+ page PDF that should contain information about the applicant's determination of the "area of potential effect" (APE), the historic structures or districts that the applicant has identified within that area, the applicant's determination of whether the tower will cause any negative effects to those historic structures/districts, and a brief rationale for that determination. You can question all of the applicant's determinations, and raise your own arguments as to why the towers will have negative effects on historic districts/structures.

 

------Begin forwarded message:------

From: Marianne Walsh <marianne.walsh@e2pm.com>

Subject: Link5G Kiosks: Consulting Party Access to Applications

As an entity that has recently requested Consulting Party status on some or all FCC applications for the proposed ZenFi Link5G Kiosk projects, you may have received an email from the FCC notifying you of the recent update on the application(s) in which you are interested. In order to gain access to the full submittal, the FCC has issued these instructions:

In order to gain access to the FCC’s E-106 system, you must first obtain a Username and FCC Registration Number (FRN).  You accomplish that by registering in the FCC’s CORES system located here:  https://apps.fcc.gov/cores/userLogin.do     For assistance with the CORES registration process please contact the FCC Customer Support Center at 1-877-480-3201.

You must then send the FRN to the consultant with the 10-digit E-106 file number and request they update the filing to add your FRN to your Consulting Party information.  After the update is complete, you will then be able to log into the FCC’s E-106 system (https://wireless2.fcc.gov/ulsclogin/index.htm) and have online access to the submission packet (FCC Form 620 and all uploaded attachments) and all related documents, comments.

Please contact me if you have any questions. Thank you.

Marianne Walsh

Senior Architectural Historian

E2 Project Management LLC 

75 East Main Street                      

Rockaway, NJ 07866

Tel. (973) 625-5600 ext. 406             

Cell (201) 753-1165

www.e2pm.com

Regards,

Odette

-- 

Odette J. Wilkens

President & General Counsel

Wired Broadband, Inc.

a 501(c)(3) non-profit

P.O. Box 750401

Forest Hills, NY 11375

owilkens@wiredbroadband.org

www.wiredbroadband.org

646.939.6855