City of Reading Adverse Effect Resolution

ACER prepared an adverse effect resolution and Memorandum of Agreement (MOA) to address historic‑property impacts under Section 106 for infrastructure and construction projects. Our services included cultural‑resource assessments, development of mitigation measures, coordination with agencies, tribes, and stakeholders, drafting the MOA terms and appendices, and implementation planning—providing clear, legally defensible agreements, monitoring protocols, and deliverables to resolve adverse effects and keep projects compliant and on schedule.

 

On behalf of a major telecommunications carrier, ACER provided adverse effect resolution for adverse visual effects from a telecommunications tower, which had three (3) eligible to be listed and one (1) National Register listed historic districts within the tower’s area of potential effect.  After evaluating the nature of how and to what level the historical properties were affected by the tower, ACER drafted three (3) potential mitigation plans and presented them to the City of Reading Historic Preservation Specialist, the telecommunications carrier, Pennsylvania State Historic Preservation Office (SHPO) and Federal Communications Commission (FCC).  Following negotiations with these consulting parties, it was determined that contributing funds for the production and placement of historic district signage within the City of Reading would be the acceptable adverse effect mitigation.  ACER drafted and negotiated the signing of a Memorandum of Agreement (MOA) document, which detailed that the mitigation measures constituted full, complete, and adequate mitigation measures under the National Historic Preservation Act (NHPA) and the implementing regulations of the Advisory Council and the FCC.  This agreement was utilized to complete the National Environmental Policy Act (NEPA) Survey Report and NEPA Environmental Assessment Report (EA) for submittal to the FCC for a Finding of No Significant Impact.