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By Bryon Gunnerson and Brett Reall

*There is currently an abundance of information related to ‘small cell’ cellular installations circulating the internet, creating confusion with local governments, property owners, and consumers. This article is intended to be a high-level overview of the industry, and only provides general guidelines related to Small Cell wireless installations. Contact Gunnerson Consulting for information specific to your situation.*

What is a “Small Cell” and a Small Cell facility? Pike Place

  • Each antenna (excluding associated antenna equipment) is no more than three cubic feet in volume;
  • All other wireless equipment associated with the structure, including the wireless equipment associated with the antenna and any pre-existing associated equipment on the structure, is cumulatively no more than 28 cubic feet in volume;
  • The structure on which antenna facilities are mounted:
    • is 50 feet or less in height, or
    • is no more than 10 percent taller than other adjacent structures, or
    • do not extend existing structures on which they are located to a height of more than 50 feet or by more than 10 percent, whichever is greater;

 

This seems to be a pretty simple formula that is now embedded within the wireless code sections of most jurisdictions.    In fact, the key words “small cell” litters the code sections and prescribes fast and streamlined administrative approvals.    Alarmingly, GCCSS is discovering that many code sections describes the process but fails to describe what a small cell is or do not clearly define what separates a small cell from a macro-cell within the wireless code.

 What does a “Small Cell” classification do?

  • If an installation is defined as a Small Cell  = The FCC report and order provides a mandate to jurisdictions.
  • The mandate = jurisdictions must act with an administrative process to approve and never reject.
  • Most jurisdictions have a solidified administrative process to approve within their wireless code.

​​​​​This might appear as a no-harm, no-foul issue and many assume that all the wireless carriers, tower companies and zoning/permitting contractors are playing by the rules as described in the report and order.   What we are seeing is an increased number of applications that include the words “small cell” or “5G” where it’s clearly not a small cell by size or height.   These are in-fact, standard or macro-cells being presented as a small cell.  

Here’s the “foul”:

  1. The jurisdiction in-take desks typically accepts the words on the application and applies an administrative review since it typically says “small cell” or “5G”.
  2. These in-take desks aren’t trained to qualify that the actual application fits the report and order as a small cell.
  3. These applications are fast routed as an administrative process and typically issued construction permits according to the small cell report and order.
  4. More and more wireless applications are being submitted which simply don’t meet the physical test of a small cell.

All cells, small or macro, are being provisioned with 5G technology.    What we are also finding are more applications that state 5G as an interposed term of “small cell” and thereby being rushed through the administrative processes.

IMG 1491Here’s the “harm”:

  1. Most administrative processes don’t require neighborhood notifications.   Hence, neighbors won’t have the ability to obtain or understand the permit application.   This is especially a harm when the permit is not actually a small cell, but a typical cell site.
  2. Most jurisdictions are issuing building permits at the same time as the administrative process and starting the clock for appeals which will run out before the building actually begins further obstructing neighbors from comment periods or administrative objections.
  3. Most jurisdictions don’t post their actions on a publically available space in real time.    Outside of some major cities, must jurisdictions will only post a action sometimes 60-to-120 days after the action and not make available the details of the permit application.   Public records requests are the only means of obtaining this information and is usually far after any appeals process.
  4. As more applications state “small cell” or “5G” on the intake forms the less adhearance to the physical requirements of the report and order are being observed.   We are seeing typical macro-cells installed on roof-tops and light poles, even mono-poles and mono-pines that far exceed 50ft in height.

As the industry rolls into 'high gear' to install the massive amount of small cell antennas anticipated to be needed in the very near future, it is critical for local governments to implement protocols that will allow for timely processing of accurately represented small cell installations, while filtering and addressing sites that may not meet all requirements for small cell installations. Gunnerson Consulting assists local jurisdictions navigate this process. Contact us today to discuss your specific situation.