Purcellville’s cell tower approval: Can you hear me now?

By Laura Longley

How does a 156-foot cell tower with arrays for up to five carriers get approved for construction next to an area zoned by a county as an “historic district”?

Take one town with a community desperately in need of cell service; a Town Council trying to meet the need and benefit from a percentage of the tower’s leasing fees; a wireless development, design, and management corporation, which, as is customary, subcontracts jurisdictional, environmental, and historic resources due diligence to a firm that specializes in that work. 

The town, in this instance, is Purcellville. The communities without cell service are Hirst Farm, Locust Grove, and all nearby corridors. Wireless Edge of Ohio and New York State is the contract awardee, and that firm’s due diligence consultant is Trileaf Corporation of Towson, Maryland.  The location of the tower is Basham Simms Wastewater Treatment Facility on S. 20^th St.

For a cell tower to be built, it must receive the necessary Federal Communications Commission permits by meeting the requirements of Section 106 of the National Historic Preservation Act (NHPA) of 1966.

 “The review process requires federal agencies to identify and assess the effects that federal undertakings will have on significant historic resources,” notes Preservation Virginia, a statewide nonprofit. “Federal undertakings can be projects or activities which are funded, permitted, licensed, or approved by any federal agency, and can take place either on or off federally owned or controlled property.”

It is separate from the National Environmental Policy Act. But, as the Advisory Council on Historic Preservation explains, both require federal agencies to “stop, look, and listen” before making decisions that impact historic properties and the human environment.

“If it is determined that the federal project will have adverse effects on the historic resource,” Preservation Virginia makes clear, “the federal agency must begin to explore ways—in consultation with the other parties—to prevent, minimize, or mitigate the adverse effects. This type of checks and balances system found within the Section 106 review process has helped prevent and mitigate the loss of many significant historic sites across the nation.”

What does anyone in Purcellville or western Loudoun know about this tower?

From an informal canvas of Town Council members, the Town Planning Committee, and regional preservation and conservation organization, the answer is “not much.”

The project has not shown up on the radar screen of most of the nonprofits. Even members of communities that will benefit most from the enhanced cell service are, for the most part, in the dark.

One Town Council member says that he has not seen a rendering of the Wireless Edge tower. “They gave a presentation to the Town Council about a year ago,” when the Town Council approved a 40-year contract unanimously. “They did not provide a photograph or drawing of the tower but indicated they intend to install a monopole.”

According to the presentation given by Wireless Edge president and CEO John Arthur, the Purcellville tower will be constructed to accommodate up to five cellular carriers. 

Groups left out of the approval process

Wireless Edge’s consulting firm Trileaf tapped Johnson, Mirmiran and Thompson of Herndon to manage the Section 106. 

A Section 106 requires identification of “consulting parties who are invited to comment. These choices are pivotal, especially when organizations and jurisdictions responsible for historic resources are not invited to the table. 

For Purcellville tower’s FCC permits application, Johnson, Mirmiran and Thompson listed only two “consulting parties:’’ the Purcellville Planning Commission and the Purcellville Historical Society. Their invitations were sent via email to “To Whom It May Concern.” Both the planning commission and historical society report they did not receive invitations. If one did land in their inbox, they were never opened. Bottom line: They did not comment. So noted in the Section 106 filing. 

Meanwhile, there was a host of preservation organizations that could have been contacted given their ongoing work to prevent threats to irreplaceable historic resources: Piedmont Environmental Council, Lincoln Preservation Foundation, Loudoun Historic Village Alliance, Loudoun County Preservation and Conservation Coalition, Loudoun Heritage Commission, and the Loudoun Preservation Association. 

What historic resources were missed given those limited invitations for comment?

Here are a few:

Goose Creek Historic District, which adjoins Purcellville at the cell tower site, is 10,000 acres of open farmland filled with 18^th-century stone houses, barns, Civil War battlefields, and sites of burned mills. The district was placed on the National Register of Historic Places in November 1982. 

Village of Lincoln, settled by Quakers in the mid-1700s, was placed on the National Historic Register 50 years ago.

Lincoln’s historic resources include the 1765 Goose Creek Meeting House, an 1817 meeting house—still an active center of worship—the Goose Creek burying ground, and the 1815 Oakdale schoolhouse. Oakdale was Loudoun’s first public school, which after the Civil War became the first school in the region to offer education to African American children. 

Several more significant African American resources are located in Lincoln: the 1865 Mt. Olive Baptist Church, which has an active congregation; Grace Methodist Episcopal Church, built in 1866 and now undergoing restoration through the work of the Lincoln Preservation Foundation, and Lincoln School B, down a hill from the two churches. It opened its doors to African American students after the Freedmen’s Bureau established schools in Loudoun.

Due diligence in Richmond

The Schedule 106 reached the Virginia Department of Historic Resources in July. After studying the files, the VDHR cell tower reviewer wrote, What about the Goose Creek district?

VDHR requested the Schedule 106 consultants to conduct a tethered balloon test to establish the tower’s visibility in the historic district. A test was conducted on August—at the height of summer, with leaves on the trees and the corn growing at nearby farms that stood six feet high. 

There are other concerning issues about that test. Of the sites chosen to answer the VDHR question, only one was anywhere close to the Goose Creek Historic District. That was at Abernethy and Spencer Garden Center, behind a large stand of trees. None were taken at the Goose Creek Meeting House Complex or elsewhere in the historic district.

VDHR reports that the balloon test results do not indicate who or what company was on site for the test. But the sites for determining visibility from the Goose Creek Historic District were selected by a Johnson, Mirmiran and Thompson archaeologist who is listed as principal investigator.

The way forward?

Moving forward a cell tower approval process should be inclusive and transparent. 

Take the Milestone Towers Mickie Gordon Memorial Park tower approval process. The Loudoun County Board of Supervisors approved the tower in the 100-acre park, but put it right next to the property line of a resident’s house that is listed on the Loudoun County African American Historic Architectural Resources Survey. 

This survey was commissioned by the BOS in approximately 2002, in conjunction with the Black History Committee of the Friends of Thomas Balch Library, to identify threatened African American properties. The stone house, built by Mr. Hall of the Hall family who was from a prominent African American family in Loudoun County, is listed as having historical significance. In addition, the resident’s property which was known as Hall’s Park, “hosted many recreational activities for African Americans during the height of segregation in the early to mid-20^th century,” according to the VDHR property listing.

This was dismissed by the BOS because, they said, the owner is currently renting his house, and because this stone house was compromised by an 1800 log cabin add-on. The log cabin addition was done in the mid 1980’s, and the property was identified as having historical significance in 2002.

Is it possible to bring to the table the appropriate preservation “consulting parties” and at least one Loudoun County official representing the County’s historic districts and villages when considering these projects?

A photo simulation of towers would be good to share with an expanded group of “consulting parties,” including early notification of affected parties – near and far.

It should be said that given everyone’s dependence on cellular service, the residents of Hirst Farm, Locust Grove, Lincoln, and Goose Creek as well—deserve to be able to make or take a call without shouting, “Can you hear me now?”