What is NEPA review?

NEPA — the National Environmental Policy Act of 1969 — requires federal agencies to assess the environmental impact of actions they fund, permit, or license. For telecom, the FCC is the licensing agency, so any tower build or major modification touching FCC-licensed spectrum triggers a NEPA review pathway.

Standard NEPA review on a macro site covers floodplains, wetlands, endangered species habitat, historic properties (under Section 106 of the NHPA), Tribal consultation, and proximity to sensitive land uses. Most sites qualify for a categorical exclusion, but each must be screened.

Section 106 of the National Historic Preservation Act is a parallel process that runs alongside NEPA. NEPA covers environmental impact; Section 106 specifically covers effects on historic properties. The FCC's Nationwide Programmatic Agreement (NPA) governs how telecom builds work through Section 106.

FCC Form 620 (new tower) and Form 621 (collocation) are the standard submission packages. They bundle the environmental assessment, Section 106 cultural-resources review, Tribal consultation results, and FAA obstruction-marking determinations into one filing.

A categorical exclusion can clear in 2–4 weeks if no flags hit. Sites that surface endangered species habitat, Tribal interest, or historic property concerns can run 60–120 days or longer. NEPA timing is the most common source of pre-construction schedule slip in tower programs.

HexTel coordinates with the owner's environmental consultant and tower owner on NEPA and Section 106 deliverables, and sequences mobilization around clearance. We do not act as the NEPA filer of record — that sits with the licensee or tower owner — but we plan and execute around the clearance window.