Former Western Union Telegraph Company microwave beam terminal, Washington, DC. Designed by architect Leon Chatelain Jr. and built 1946-47.

Dear Preservation 911,

There are nearly 200,000 communications towers registered with the Federal Communications Commission. These represent a fraction of the overall population of structures used to mount radio, microwave, and personal wireless services (cellular and PCS) antennas. Since the earliest days of broadcasting, the manufacturers of forest fire lookout towers marketed their structures to the government and communications companies to be used as antenna structures.

Lookout towers, like high-voltage electricity transmission structures, evolved from nineteenth century windmill tower designs. Windmill towers were engineered to support the windmill apparatus while also ensuring protection against wind stresses and ice loads. They were the prototype antenna structure: a functional trestle or derrick built solely to securely hold aloft the intended object, be it a windmill, power lines, or antennas.

In selecting a uniform tower type for the nation's first private sector microwave relay system, Western Union Telegraph Company engineers experimented with several tower forms before settling on what they described as the "Department of Agriculture Heavy Type Forestry Tower." In a summary of the system that was built in the Mid-Atlantic states between 1945 and 1947, Western Union engineers wrote, "This design was familiar to many fabricators and permitted obtaining standardized towers of various heights by eliminating sections from the top or bottom."

The towers in the former Western Union system and others today are endangered by FCC policies that exclude existing communications towers from compliance with Section 106 of the National Historic Preservation Act. In 2001, the FCC signed a programmatic agreement with the Advisory Council on Historic Preservation and the National Conference of State Historic Preservation Officers to streamline the National Historic Preservation Act (Section 106) compliance process for communications tower builders and wireless telecommunications carriers. One of the provisions in this agreement excludes actions such as the removal or addition of antennas (antenna collocation) from existing towers from review under Section 106 (Section 106 of the National Historic Preservation Act requires federal agencies and entities issued federal licenses, permits or funds, to take into account the effects of their undertakings (such as the construction of towers) to historic properties.

Over the past year, the FCC, under pressure from the broadcast and wireless industries, has sought to further streamline the Section 106 process. In addition to excluding antenna collocation from Section 106 compliance, the FCC now is on the verge of issuing rules and a new programmatic agreement that will exclude the construction of "replacement towers" from the Section 106 review process. This means that parties who own or buy a historic communications tower may demolish the old tower to build a new one in its place.

The former Western Union system provides one tangible illustration of the implications of the earlier and proposed FCC preservation policy changes. In the fall of 1945 Western Union began buying and leasing property along its proposed microwave relay system routes linking its New York headquarters with Washington, D.C., Pittsburgh, and Philadelphia. Western Union's sites included forested mountaintops in central Pennsylvania and Maryland and farm fields in Delaware and New Jersey. By early 1947, Western Union had built 21 prefabricated lookout towers as antenna structures and the brick and limestone Tenley tower in Washington, D.C. Western Union's prefabricated towers were 60-, 100-, and 120-foot steel Aermotor-style towers of the sort sold to the US Forest Service and states for use as forest fire lookouts. The towers were outfitted with parabolic antennas attached to transmitters and receivers designed by RCA to handle the new microwave telegraphy and facsimile traffic. The former Western Union Telegraph Company microwave relay system, and others like it, may be demolished without any efforts to document or otherwise mitigate the adverse effects to these historic structures.

The FCC's National Historic Preservation Act policies threaten to eliminate much of the agency's own engineering history by failing to take into account the sites that its actions made possible. Licensed by the FCC and designed by radio and television's brightest engineers in the years enveloping World War II, many of the nation's earliest communications facilities were supported by fire lookout towers. Soon, these towers may disappear much like black and white televisions and rotary telephones unless the FCC develops a policy not to preserve old communications towers as impediments to progress but a policy meant to ensure that these historic properties are taken into account in the Section 106 process.

Sincerely,

David S. Rotenstein

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