Bridging the Gap - Joint Venture Silicon Valley

S I L I C O N V A L L E Y

Bridging the Gap21st Century Wireless Telecommunications Handbook

SECOND EDITION - DECEMBER 2019

2Bridging the Gap: 21st Century Wireless Telecommunications Handbook - Second Edition

Acknowledgments

David Witkowski, Executive Director of the Wireless Communications Initiative at Joint Venture Silicon Valley, authored this report. Jill Jennings created the report’s layout and design. Robin Doran served as copy editor.

The author and Joint Venture Silicon Valley would like to thank the following people for their contributions to, and support of, this project:

• William J. McShane II, Director – Americas, ICity Venture, Signify

• Al Brown, President and CEO, SmartWave Technologies LLC

• William Hammett P.E., President & CEO, Hammett & Edison Inc.

• John Lang, Economic Development Manager, City of Morgan Hill, CA

• Joe Madden, Mobile Experts LLC

• Patrick Mulhearn, Policy Director – Board of Supervisors, County of Santa Cruz, CA

• Carlos Ramos, Principal Consultant, Maestro Public Sector

• Richard Tell, President, Richard Tell Associates, Inc.

• Jerrold T. Bushberg, PhD, DABMP, FAAPM, FHPS, Director Emeritus Medical/Health Physics Programs, University of California, Davis – School of Medicine

JOINT VENTURE SILICON VALLEY

Established in 1993, Joint Venture Silicon Valley brings together established and emerging leaders—from business, government, academia, labor and the broader community—to spotlight issues, launch projects, and work toward innovative solutions. For more information, visit www.jointventure.org

For more information or to contact the Wireless Communications Initiative go to www.jointventure.org/wireless.

AUTHOR CONTACT INFO

David Witkowski Executive Director, Wireless Communications Initiative [email protected] (408) 298-9333


Table of Contents

Introduction 4

Factors Driving Change 7

The Evolution of Cellular 10

Societal Value of Wireless Broadband 14

Mobile Network Densification 17

Wireless Telecom Legislation 25

Addressing Common Public Concerns Regarding Wireless 31

Wireless Telecom Roadmap – What Does The Future Hold? 38

Recommendations for Municipal Governments 40

Takeaways for Municipal Leaders 43

Recommendations for Carriers, Operators, and Utilities 44

Glossary of Terms 46

Works Cited 49


Introduction

Wireless technologies have become a fundamental part of our daily life in the 21st century. They connect us to each other and to rich sources of information. They give us the ability to make efficient use of our time, allow us to have remote control over other technologies in our life, and make our lives better in innumerable ways. In order to function, our wireless devices need to connect to cellular sites that provide good coverage both outdoors and indoors. To do that increasingly requires placement of sites closer to populated areas – creating new challenges for both providers and local governments. Next-generation technologies will enable greater functionality, but their complexity places increasing burdens on municipalities.

Written primarily for municipal employees, public officials, and civic leaders, this handbook will help guide understanding of these networks as they deal with very complex and rapidly evolving technologies. We see evidence of the pace of technology evolution in the history of this handbook. First published in 2016, after only three short years so much has changed we needed to publish an update. In this document, we will cover much ground. We will look at what is driving the need for wireless data, the societal value of wireless data networks, the technologies the industry is deploying to build those networks, and the regulatory environment for wireless facilities that govern how carriers and local governments must interact. We will close with an overview of new technologies we can expect in years to come, and provide some forward-looking recommendations for both local governments and wireless carriers.

Wireless networks have come a long way since 1973, when Martin Cooper made the first portable cellular call from the streets of New York City. The number of devices connecting to mobile networks – especially 4G networks – is growing steadily, straining network capacity and necessitating both densification (via small cells and distributed antenna systems) and new technologies like 5G that can handle the subscriber growth.

It is important to consider the economic impact of these networks. The dot-com boom created the internet economy, and now Silicon Valley is the center of the mobile economy. From the largest corporations (e.g. Google, Apple, Amazon, and Facebook) to the smallest seed-funded startup – each has built its success around a “Mobile-First” strategy focused on delivering information and conveniences via smartphone apps, cloud computing, and mobile networks. This economic expansion would not have been possible without the privately-funded 4G network that enabled smartphones to access the rich sources of information that fuel the mobile economy.

Wireless technologies have become a fundamental part of our daily life in the 21st century.


Figure 1: Devices or Connections per year(Figures in parentheses refer to device/connection share by network type for 2017 vs. 2022)

Source: Cisco Visual Networking Index, 2019 Edition (Recreated)

Accenture’s 2017 report on 5G economics projects that the U.S. wireless industry will invest $275 billion during the deployment of 5G – roughly speaking about $800 per resident in areas ranging from major cities to small towns. A private investment of this magnitude in U.S. infrastructure will be easily the largest ever made – it exceeds (in 2019 dollars) the amount spent by the U.S. federal government on the Apollo space program, and approaches the amount of taxpayer dollars invested in construction of the interstate highway system. The Apollo program’s technology developments spun off untold numbers of innovations that are now part of our modern life including solar panels, CAT scans and MRIs, cordless drills, quartz clock movements, and heat-resistant materials for fire-fighting suits – we can only begin to imagine the technology innovations that massive private investment in our national communications infrastructure will enable.

Faced with skyrocketing demand that presents both an enormous opportunity and a seemingly impossible technical challenge, wireless carriers have begun shifting their deployment strategies away from voice telephony towards 4G mobile data for smartphones. Looking forward, carriers will continue to add capabilities in 5G for machine-to-machine communications (the so-called “Internet of Things”) and extremely reliable low-latency networks necessary for ultra-accurate positioning and autonomous vehicles. As we move from 2G/3G networks on towers that serve areas several miles in diameter to low-power 4G and 5G networks focused on serving a few city blocks, the number of sites is also increasing, and their placement becomes increasingly critical.

As we move from 2G/3G networks on towers that serve areas several miles in diameter to low-power 4G networks focused on serving a few city blocks, the number of sites is also increasing, and their placement becomes increasingly critical.


Figure 2: Global Mobile Data Usage (per month)

Source: Mobile Experts LLC

Mobile telephony is a competitive business, and subscribers unhappy with their carrier’s network performance can easily switch their phone number and service to another provider. (The industry term for this is “churn”.) Carriers are so desperate to win customers that they will offer hundreds of dollars to cover early termination fees and give away expensive phones – just to get subscribers to sign a 12-month or 24-month contract.

To build a wireless network, a highly competitive spectrum auction conducted by the Federal Communications Commission (FCC) grants leases to carriers – and this cost is not trivial. Wireless spectrum purchased during one spectrum auction known as “AWS-3” cost the bid winners over $44 billion, paid up front to the U.S. government, and that was a relatively small auction – just one of many over the past three decades (FCC AWS-3 Auction Results, 2015). Having paid to win the spectrum leases, the carriers then must invest in wireless facility siting studies, pre-application meetings, public hearings, permit applications, and engineering designs/redesigns. Costs for deployment are incurred up front; the investment in equipment, personnel, trucks, and tools to install wireless networks are all pre-revenue. It takes years of monthly subscriber revenue before the carriers and site operators can realize a profit on these capital and operational expenses.

At best, every dropped call or slow data connection puts a wireless carrier at risk of losing a customer to churn. At worst, it creates a public safety issue for people who rely solely on mobile phones to call emergency services. If an area experiences excessive dropped calls or slow data, a carrier will want to fix that problem – and that means upgraded equipment or new sites – and navigating a local government permitting process. Unfortunately, these interactions have not always been positive.


Given the urgency placed on carriers to enhance networks, reduce churn, and meet users’ demand for faster data, it was inevitable that conflicts between carriers, operators, and local governments would arise. Carriers and site operators feel that some local governments have treated applications for wireless facilities with either disdain or outright hostility, that application processes are often unclear or arbitrary, and are sometimes subject to repeated demands for eleventh-hour revisions. Local governments feel that some carriers and utilities have been dishonest in their applications, have built sites that do not match the application’s plans and rendered drawings, or have failed to heed requests for integration with local design and architectural standards. Each side has their horror stories, and certainly, each side has made mistakes. Our shared goal for Silicon Valley – and indeed the entire country – should be to move beyond those mistakes and go forward together in partnership between industry and local governments, to create high-performance wireless networks with great coverage that will support current needs and pave the way for future innovation. Fast and ubiquitous wireless networks are critical resources for our country’s residents, and failing to provide them is no different than failing to provide clean drinking water, natural gas, sanitation service, or electricity. Yet we must also respect the need for minimalist, quiet, and aesthetically pleasing infrastructure.

Factors Driving Change

User Demand for Mobile Data

By any measure, the demand for mobile data is enormous and not likely to slow down. Ericsson’s 2019 Mobility Report estimates the consumption of data on mobile devices (smartphones, tablets, and mobile-enabled PCs) worldwide grew by 78 percent between Q2 2018 and Q2 2019 and reached 94 Exabytes (1 Exabyte equals 1 billion Gigabytes) per month in Q2 2019. (To give a sense for scale, an Exabyte is equal to 250 million DVDs of information.) Smartphones drove the majority of that usage (Ericsson AB, 2019). In 2017, the average smartphone subscriber in North America consumed 8.3 GB of data per month, and this will increase to 59 GB per month by 2021.

The Mobile Economy is a heavy driver of wireless data usage – caused by a fundamental shift in user behavior in communication and commerce from PCs connected by wired internet to smartphones and tablets connected by mobile networks. In 2018, mobile technologies and services generated 4.2% of GDP in North America, at a value of $937 billion. This will increase to $1.2 trillion (4.8% of GDP) in 2023 (GSMA, 2019).

By any measure, the demand for mobile data is enormous and not likely to slow down.


Figure 3: Mobile ecosystem contribute to North American economy, 2018

Source: GSMA Intelligence

Users Want More for Less

While the number of users and the amount of mobile data they consume has gone up exponentially, market forces have driven down the average revenue per user. According to GSMA Intelligence reports, for carriers in the United States average revenue per user (ARPU) per month in 2018 was $8.45, a decrease of 0.8% from 2017 (GSMA, 2019). PWC Strategy reports show that ARPU spread was above 75% at the start of the smartphone era in 2010 but had fallen below 50% in 2017 (PWC Strategy, 2018). Free-market competition between carriers has been very successful in making wireless networks more affordable for more residents, but it places enormous downward revenue pressure on the carriers and forces them to compete for a dwindling number of new subscribers in an increasingly saturated market.

Spectrum Scarcity

Wireless services rely on the availability of spectrum – the term for the range of electromagnetic frequencies used to carry signals between the network and users. Spectrum is like land – there is only so much of it. Every bit and byte of information we consume over a mobile network requires a certain amount of spectrum to make the connection. Like constructing a high-rise building to make efficient use of land, we can make our use of spectrum more efficient – but this approach has limits. One approach to improving spectrum efficiency is densification – reusing the spectrum from large macro towers that cover many square miles in systems that cover a few city blocks, the inside of a building, or even a single room. Known collectively as Heterogeneous Networks or HetNets these low-power sites do not replace large macro tower sites, but are supplemental to them – focusing scarce spectrum resources into areas where people tend to use the most data.

There are two types of spectrum – licensed and unlicensed. Regulatory authorities (such as the FCC) lease licensed spectrum to corporations and individuals, who then use the spectrum for various purposes. In most cases, the commercial leaseholders of licensed spectrum must pay the government for an exclusive right to use that spectrum, must meet the requirement that

Wireless services rely on the availability of spectrum – the term for the range of electromagnetic frequencies used to carry signals between the network and users. Spectrum is like land – there is only so much of it.


the spectrum be used to provide a public good of some type, and leaseholders have legal standing to file a complaint against anyone who interferes with those systems. Provided at no cost to the end user, unlicensed spectrum enables consumer devices and conveniences such as garage door openers, cordless phones, and Wi-Fi networks. The consumer or network provider does not need to obtain a license to use this spectrum, but they also have no standing to pursue claims or file complaints about interference.

Smart Cities and the Internet of Things

People are not the only users of spectrum. Wireless networks connect machines and autonomous devices to the network. Predicted to reach 5.9 billion devices in 2025, the Internet of Things (IoT) is a major user of wireless spectrum. While not a firm definition, IoT typically refers to connected cars, sensors (including cameras), displays and actuators, utility metering and control, industrial systems, data storage systems and the artificial intelligence algorithms that act on that data, and consumer electronics. There are two IoT classifications: Consumer IoT and Industrial IoT (GSMA, 2019). Systems that use Industrial IoT technology often form the basis of municipal Smart City systems for transportation, resource management, public safety, and other civic applications. IHS Markit Technology forecasts the total installed base will grow to 69.5 billion units in 2025 and device shipments will grow to 18.1 billion units in 2025 (IHS Markit, 2016).

Figure 4: IoT Devices - Installed Base & Device Shipments

Source: IHS Markit

People are not the only users of spectrum. Wireless networks connect machines and autonomous devices to the network.


The Evolution of Cellular

2G -> 3G -> 4G -> 5G

In the early days of digital cellular telephony, the definition of a wireless system’s “generation” was primarily a marketing device not based on standards. Second Generation, or 2G digital cellular, replaced the first analog cellular systems and allowed the use of text messaging. Beginning with the Third Generation, or 3G family of standards, the International Telecommunications Union’s Radiocommunication Sector (ITU-R) began seeking international agreement on, and publishing recommendations for, IMT-2000 – the standardized definition that 3G technologies would have to meet (International Telecommunications Union, 2011). In 2010, the ITU-R defined the Fourth Generation, or 4G family of standards, designated IMT-2010. “Long Term Evolution” or LTE as one technology that meets the ITU-R’s 4G definition, although there is another technology known as WiMAX that also meets the 4G definition. The ITU-R later expanded upon this standard by creating IMT-Advanced, and the ITU’s Fifth Generation, or 5G standard, is designated IMT-2020 (ITU, 2019).

5G Demystified

5G is an increasingly covered topic in the media, but much of that coverage misses the mark because it focuses only on the mobile handset use model that defined 4G. It is critically important that municipal leaders understand 5G is not just another technology for smartphones and tablets. 4G was useful for these devices, but it cannot support use cases where timing and latency are critical, and it cannot handle very large numbers of connected devices. The promise of 5G is that it will address these and other limitations while adding performance to existing systems, and support a wider range of use cases.

Just as LTE was a technology that met the ITU-R 4G definition, “New Radio” or NR is a technology that meets the 5G definition. NR nodes are deployable in a standalone configuration (so-called “Pure 5G”), or in parallel with LTE nodes. We expect that most initial deployments will be parallel LTE + NR configurations, with Pure 5G coming later as more devices are able to leverage 5G connections.

ITU-R has specified performance via the IMT-2020 standard for 5G systems that improves upon 4G LTE and adds new capabilities. 5G will offer support for:

• Enhanced Mobile Broadband (eMBB) – dramatically increasing data throughput for smartphones, tablets, PCs, and other consumer devices. 5G also dramatically increases the ability to serve large numbers of devices – 4G is only able to support a few hundred devices per site, whereas 5G can support millions per site.

It is critically important that municipal leaders understand 5G is not just another technology for smartphones and tablets.


• Ultra-Reliable Low-Latency Communications (uRLLC) – allowing for ultra-fast exchange of data, such as near real-time sensor sharing to enable both semi-autonomous and fully autonomous vehicles.

• Massive Machine-Type Communications (MMTC) – expanding support for large numbers of Internet of Things devices running at minimum power, with batteries that last over 10 years.

• Positioning – an alternative to GPS for underground, indoor, urban canyon, etc. use cases, this enables precise positioning without the need for satellites.

• Time-Sensitive Networking (TSN) – an aspect of uRLLC, TSN will provide support for deterministic networks, Ethernet/Fiber performance over 5G (5G LAN), quality of service control, and ultra-accurate device time synchronization.

• Fixed Wireless Access (FWA) – an alternative to wired broadband, 5G can deliver broadband to home and business consumers without physical lines.

• Network slicing, virtualization, and edge computing – rather than require all data be transported between the users and the 4G core servers, 5G will enable the placement of computing near users. (Note that edge computing is not a new concept, and is not unique to 5G. When combined with edge computing, 5G features like uRLLC will allow the creation of near real-time services.)

• Massive Multi-Input Multi-Output (MIMO) antenna systems, which operate as intelligent phased arrays to electrically steer a 5G site’s RF signal towards the user equipment. Massive MIMO will increase channel efficiency, throughput, and decrease interference. Unlike previous cellular generations, 5G MIMO systems direct their signals only towards 5G users.

The IMT-2020 5G definition specifies three usage scenarios and their performance requirements:

• eMBB – Over 10 Gbps peak data rates on the uplink and downlink, and over 50 Mbps user-experienced data rates on the uplink and downlink. High spectral efficiency. Support for high-mobility connections. High network energy efficiency. High area traffic capacity.

• MMTC – Support for over 1 million connected devices per square-kilometer.

• uRLLC – Latency below 1 millisecond, and support for high-mobility connections.


Figure 5: 5G Usage Scenarios (eMBB, MMTC, uRLLC)

Source: ETSI

As with any wireless technology, the success or failure of 5G networks will depend heavily on the availability of spectrum. The first spectrum bands allocated for 5G were in spectrum above 6 GHz, often called “millimeter wave” spectrum. The media’s coverage of 5G has erroneously implied – or explicitly stated – that 5G is a millimeter wave system. The reality is that 5G will be able to use a wide range of spectrum options including low-band (below 1 GHz), mid-band (1 GHz to 6 GHz), and millimeter wave (above 6 GHz) spectrum bands. 5G will also be able to use both licensed and unlicensed spectrum, and over time will replace older 3G equipment as deployment progresses.

It is important to note the IMT-2020 performance defines requirements by use case, and any technology meeting the definition for that use case is in fact a 5G technology. In fact, some existing sites using LTE-Advanced technologies are able to meet the 5G definition for eMBB, and hence these sites are already technically 5G sites.

Siting Requirements for 5G

5G operating in low-band and mid-band spectrum will have the same coverage pattern as the 3G and 4G Small Cell sites they replace. However, 5G sites in millimeter wave bands do not cover very large areas, because signal levels in millimeter wave bands drop off very quickly over distance (Refer to Figure 6).

As with any wireless technology, the success or failure of 5G networks will depend heavily on the availability of spectrum.


Figure 6: Radio frequency energy loss over distance, by spectrum band

Source: Oku Solutions LLC

Wireless Generation Lifecycles

In parallel with 5G, 4G (both LTE and WiMAX) continues to evolve, with new features added by the IMT-Advanced definition. Historically, each generation of wireless telecom has taken about 12 years to reach its peak – which means 4G deployments will not peak until 2022. Much work remains in 4G deployment, especially in 4G small cells, as users will continue to use that technology for several years while 5G matures and begins entering its main deployment phase.

However, some industry analysts have made arguments that the 5G lifecycle will be different from previous generations. There are two arguments in support of this assertion:

1. 5G will enable IoT devices, automotive, rail/transit, tele-health, utility networks, etc. 5G is not just another technology for handsets and PCs. While the market for 4G has been constrained by subscriber saturation, (the term we coined for this is “Peak Smartphone”) the number of devices that can potentially benefit from 5G is much higher.

5G operating in low-band and mid-band spectrum will have the same coverage pattern as the 3G and 4G Small Cell sites they replace.


2. Previous wireless telecom generations have been revolutionary, meaning that they were radically different from previous generations. In contrast 5G is more evolutionary, e.g. the case where some LTE-Advanced sites can be reclassified as 5G. Thus, the start of the 12-year lifecycle for 5G has already begun.

Figure 7: Mobile Technology Lifecycles (North America)

Source: Chetan Sharma

Societal Value of Wireless Broadband

Wireless Voice and Broadband are Not Luxuries

Mobile networks are increasingly replacing wired telephones, and sometimes even wired broadband service. This is especially true of younger people, but also in economically disadvantaged communities. The reason is simple – given a limited household budget, the convenience of a mobile device both at home and away from home outweighs the inconvenience of lower data rates and possible dropped calls.

Increased Demand for Wireless Telephony

Twice a year the U.S. Department of Health and Human Services publishes the Wireless Substitution Report via the Centers for Disease Control, based on data from the National Health Interview Survey. These reports have consistently shown an increase in the rate at which people are giving up wired phones for wireless. Nationwide results from the May – December 2018 survey show that over one-half of all adults (56.7%) are now wireless-only and 67.5% of all children live in wireless-only households. These numbers are notably higher for the western U.S. region (including California). Results from other demographics

Mobile networks are increasingly replacing wired telephones, and sometimes even wired broadband service. This is especially true of younger people, but also in economically disadvantaged communities.


are striking. Over 3 in 4 adults (76.7%) under the age of 29 do not have wired phones; between age 30-34 the rate is 76.2%. 75.5% of renters are wireless only. 68.1% of Hispanic households, and 67.1% of households below the poverty line, do not have wired phones (Centers for Disease Control, 2019). These numbers have increased in all categories since the first edition of this handbook in 2016, and we expect the trend towards wireless-only connectivity will continue for many years to come.

The reasons for this increased demand are the convenience and efficiency of wireless devices. Wired telephones connected buildings to buildings; wireless phones connect people to both people and buildings. In a shared housing situation, or in multi-generational households, everyone can have his or her own number and direct voicemail or text messaging – instantly delivered anywhere we are – replaces the uncertainty of answering machines and paper messages. Wireless phones are easy to obtain, people with low credit scores can use pre-paid plans – or even buy a phone with cash – and there is a wealth of consumer choice across several carriers.

Figure 8: Percentages of adults and children living in households with only wireless telephone service: United States, 2003-2018

Source: NCHS, Centers for Disease Control, National Health Interview Survey (June 2019)

Wireless Broadband is a Primary Internet Access Tool

Giulia McHenry, Chief Economist, Office of Policy Analysis and Development for the U.S. Department of Commerce, published a blog article which showed that American households are rapidly shifting their broadband connectivity from wired (cable, DSL, etc.) to wireless (McHenry, 2016). The article’s source data comes from the U.S. Census Bureau’s Computer and Internet Use Supplement to the Current Population Survey (CPS), which includes data collected for the NTIA in July 2015 from nearly 53,000 U.S. households. The results of this survey are


striking – Households with annual incomes below $25,000 are 29% likely to be accessing the internet via only mobile broadband, and households between $25,000 and $49,999 annual income are 24% more likely to be mobile-only. McHenry’s results track closely with other research. Survey data from The Field Poll reported in 2016 found that 14% of California residents connect to the internet only through a smartphone. For households earning less than $22,000 per year, the rate is 25% (CETF, 2016). Pew Research’s 2019 report showed that 17% of adults in the U.S. do not have home broadband and access the internet only through a smartphone – either directly, or by sharing the smartphone’s cellular data to other devices. Rates for smartphone data with no home broadband are higher for at-risk demographics; 25% for Hispanics, 32% for people who did not graduate high school, and 26% for people with incomes under $30,000 per year (Pew Research, 2019).

Wireless Access to 911 Emergency Services

The societal shift to wireless telephony creates a challenge to first responders, and underscores a mandate that municipalities must support deployments to create reliable coverage both outdoors and indoors. Various studies find that on average cellular users make 80% of 911 calls. The majority of these calls originate from indoor locations. Groups opposed to wireless deployments often show videos of calls made outdoors to argue there is no need for additional coverage. These videos do not take into account the lack of coverage inside a home, business, or apartment complex – the very locations where people most often call 911.

Unconnected Cities

It is easy to think the problem of unconnected residents only exists in rural counties or remote towns in the mountains, but this is incorrect. The need for additional sites to improve coverage in urban areas is great, and failure to continue this work creates connectivity gaps for large numbers of urban residents. Research published in 2016 shows that over 25% of residents in major U.S. cities such as Los Angeles and New York do not have readily available access to the internet (Maravedis & Wi-Fi 360, 2016). This tracks with findings from Pew Research, which reported in 2019 that while average urban broadband speeds exceeded the average for rural households, urban households were also more likely to have no options for home broadband; 78.8% of rural households had home broadband, while only 72.7% of urban households had home broadband (Pew Research, 2019).

It is easy to think the problem of unconnected residents only exists in rural counties or remote towns in the mountains, but this is incorrect.


Mobile Network Densification

Densification and Heterogeneous Networks

Densification is the term for adding equipment to augment existing mobile networks and provide additional capacity in areas of high usage. Densification technologies include Distributed Antenna Systems (DAS) and Small Cells. Heterogeneous Networks or HetNets coordinate DAS and Small Cell sites with large macro towers to create a densified network. Emitting much lower RF power than their tower counterparts, Small Cells and DAS focus spectrum resources in a small area; typically, their coverage extends for only a couple of city blocks or within a facility. DAS systems extend and improve coverage in buildings, corporate campuses, shopping malls, and other public venues. Small Cells improve coverage and performance for subscribers in the public rights-of-way, homes, small businesses, and public venues. For the purposes on this handbook, we will focus on Small Cells.

Figure 9: Small Cell and DAS sites add capacity to existing networks


Why are Small Cells Important?

The majority of mobile data usage occurs where humans congregate, and users in fixed locations consume 80% of that mobile data. Draw a box on a map, highlight the areas where 90% of the data are used, and 95% of the map will be dark – we do not typically consume large amounts of data while standing in the middle of an empty field. We use data in our homes, workplaces, vehicles,


restaurants, shopping malls, and sports venues. All users share the total amount of data available – when large numbers of people congregate in a small area, the result is slow connections and poor performance. Small Cell technologies allow network designers to concentrate scarce spectrum resources and serve high-demand areas with dense populations.

HetNet Ordinances and Codes

Most municipal ordinances originally written for permitting macro towers during the early days of cellular telephony do not differentiate between Small Cell wireless facilities attached to a utility pole and a 70-foot tall macro tower – and this has created some issues. It is critical that ordinances and codes account for those differences, as Small Cells are very different from large macro tower systems. Thankfully, in recent years, the number of municipalities that have passed Master Lease Agreements to cover Small Cell deployments has grown – but much work remains.

Municipal ordinances and codes sometimes encourage co-location (the term used when wireless facilities from multiple network operators are attached to the same physical structure) by requiring minimum separation distances between wireless systems. In the early days of cellular telephony, this separation or macro towers made sense, but Small Cells can be located closer together without creating safety, interference, or performance issues. Sometimes these outdated separation ordinances force network operators to locate Small Cell facilities in undesirable locations, which is neither ideal for optimizing network performance nor a good investment for the network operator. Municipal governments should revise separation ordinances to allow closer placement of Small Cell facilities to adjacent sites. This will be especially important for millimeter-wave 5G sites, because signals at those frequencies decrease rapidly over even small distances.

Distributed Antenna Systems

Multiple antenna nodes attached via coaxial cable or fiber to centralized radio equipment creates a Distributed Antenna System or DAS. Typically, the radio equipment connects to the core network via fiber optics. DAS systems provide robust coverage inside convention centers, large buildings, sports venues, and shopping centers. There are some outdoor DAS (o-DAS) networks, typically used along driving routes where the terrain is difficult to cover with macro towers, but they are increasingly less common as Small Cells have become the technology of choice for augmenting coverage in public rights-or-way. The benefit of DAS is that the antennas are typically small and simple to install, with the radio equipment installed remotely in cabinets or equipment closets. Signal levels to and from each antenna must be adjusted carefully to ensure uniform coverage and avoid gaps, which is a downside that has led to reduced usage of DAS in outdoor venues.

Small Cell technologies allow network designers to concentrate scarce spectrum resources and serve high-demand areas with dense populations.


Small Cells Defined

The definition of what constitutes a Small Cell was somewhat fluid until the Federal Communications Commission issued FCC 18-133 “Declaratory Ruling and Third Report and Order”, also known as the “2018 Small Cell Order”. The FCC guidance for “Small Wireless Facilities” is that the facilities:

• Are mounted on structures 50 feet or less in height including their antennas as defined in 47 CFR § 1.1320(d), or;

• Are mounted on structures 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.

The FCC guidance further states:

• Each antenna associated with the deployment, excluding associated antenna equipment (as defined in the definition of antenna in 47 CFR § 1.1320(d)), 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 no more than 28 cubic feet in volume;

• The facilities do not require antenna structure registration under 47 CFR Part 17;

• The facilities are not located on Tribal lands, as defined under 36 CFR 800.16(x);

• The facilities do not result in human exposure to radiofrequency radiation in excess of the applicable safety standards specified in 47 CFR § 1.1307(b).

Prior to the FCC’s Small Cell Order, industry definitions of Small Cells were qualitative and not standardized. Some base their definitions on Radio Frequency (RF) power output levels, which are smaller relative to large macro towers. Others based their definitions on the Small Cell’s Effective Radiated Power (ERP) or Effective Isotropic Radiated Power (EIRP). The FCC’s Small Cell Order removes ambiguity and creates a qualitative basis for standardization.

The Role of Small Cells

Because Small Cells are used in HetNets to provide densification, another common definition is based on the signal coverage area, described rather loosely by the Small Cell Forum as “typically [having] a range from 10 meters to several hundred meters” (Small Cell Forum, 2019).


The benefit of Small Cells is that each acts as an independent node of a network, under control of the carrier’s monitoring and control system. The downside of Small Cell versus DAS is that each node requires fiber and power lines, and because the equipment comprises both the radio and the antenna, the total volume needed to house each node is larger than DAS. The rate of deployment for Small Cells (both 4G and 5G) will grow exponentially over the next five years. The installed base of Small Cells as of 2019 is 250,000, and analyst forecasts show that carrier-owned Small Cell installs will reach nearly 207,000 units per year in North America by 2024 (Mobile Experts LLC, 2019).

Will Small Cells Replace Large Macro Towers?

Small Cells augment, not replace, existing macro networks. Although most typical mobile usage occurs in a small area, occasional use can occur anywhere and failure to provide wide area coverage creates a public safety issue. Large towers provide connection continuity as users move from one Small Cell node to another, ensuring the smooth transfer of the voice or data connection between nodes. We still need the macro tower network to provide this wide area coverage, and the rise of Small Cells deployments does not imply an opportunity to tear down large macro towers. In addition, macro towers often support other purposes such as public safety (police, fire, and emergency medical) two-way radio, private microwave networks, and wireless internet service providers who provide a competitive alternative to wired broadband.

From a network resiliency perspective, most macro tower sites have reserve power (batteries and generators) that allow the site to continue working during disasters such as earthquakes. Small Cell facilities typically do not have large backup batteries, and their placement along public rights-of-way near population centers precludes the use of generators. Thus, large macro towers also remain an important part of our region’s disaster resiliency infrastructure.

Wireless Network Offload

Even with HetNet technology for densification, the amount of information supported by a wireless network directly correlates to the availability of RF spectrum. In 2008, the Cellular Telephone Industry Association (CTIA) told the Federal Communications Commission that mobile carriers would eventually need an additional 800 MHz of RF spectrum to keep up with projected demand (CTIA Filing to FCC, 2009). Unfortunately, this amount of spectrum is simply not available, and the costs to acquire it would be very high. FCC has shifted some unused television spectrum to the wireless carriers, and the estimated costs (as of July 2016) for reclaiming only 100 MHz of this TV spectrum is $86 billion (FCC 600 MHz Auction Dashboard, 2016).

Small Cells augment existing networks, not replace them. Although most typical mobile usage occurs in a small area, occasional use can occur anywhere and failure to provide wide area coverage creates a public safety issue.


In addition to densification via HetNets, carriers are addressing rising user demand and limited spectrum by implementing other capacity-increasing strategies, including a technique called “offload”. Offload refers to a system where the mobile network instructs the user’s device to create parallel connections. These parallel connections are often via unlicensed spectrum under the carrier’s control, using both Wi-Fi and a newer technology called LTE-Unlicensed. For example, if a subscriber wants to watch a streaming video the network would determine if an offload site were within range, and if so divert the user’s data connection to obtain the data via the offload network, leaving the carrier’s core network free to handle other traffic.

Figure 10: Mobile network offload Using Wi-Fi

Source: President’s Council of Advisors on Science and Technology, June 2012

Wi-Fi

Most of us know Wi-Fi as the technology used in our homes and offices to connect devices wirelessly to a local area network. Based on the Institute of Electrical and Electronics Engineers (IEEE) 802.11 family of standards, Wi-Fi has evolved many times over since its first release in the early 1990s. At the technology level modern Wi-Fi shares many traits with mobile broadband standards such as LTE – the difference is in the original target use cases; Wi-Fi is primarily a technology for creating local area networks, whereas LTE is a commercial-grade technology for mobile network operators. As often happens in active technology markets, lines have blurred between these competing technologies as each seeks to dominate the market. Vendors extended Wi-Fi capabilities to meet the needs of commercial and enterprise customers, and Private LTE seeks to address Wi-Fi’s limitations.

Wi-Fi is great for attachment of nearby semi-stationary devices, but unlike LTE, it does not work well when the device is moving quickly. This is because the Wi-Fi standard does not provide a mechanism (a process known as handoff) to shift a

In addition to densification via HetNets, carriers are addressing rising user demand and limited spectrum by implementing other capacity-increasing strategies, including a technique called “offload”.


device’s connection to another access point when the signal becomes weak, and because Wi-Fi uses unlicensed bands its power is limited and thus the range of an unmodified Wi-Fi access point is about 250 – 300 meters. Wi-Fi originated as an extension of Ethernet, so it handles security and authentication in a similar manner, meaning it lacks:

• Standard methods for centralized authentication (user or device onboarding is typically done via the device itself );

• Reliable methods for ensuring security of data transmitted over the network;

• Standard methods for handoff (i.e. “roaming”) between access points; and

• Standard methods for handling congestion avoidance, spectrum/channel steering, and resource allocations.

In the context of an enterprise or public Wi-Fi deployment, these are significant drawbacks. Redirection to login pages makes the login process for a guest Wi-Fi network difficult, and SSID password distribution is not scalable to large numbers of users. Public Wi-Fi networks often use open SSID configurations (with no security at all) because this approach does not require an onboarding and passcode publication process. When used in a public Wi-Fi network, open SSID can expose users to attack, although to accomplish an attack requires sophisticated methods (GCTC Public Wi-Fi Blueprint, 2017). Even with SSID passwords, as of 2019 all Wi-Fi security protocols are subject to known attack methods.

Lack of handoff/roaming is another issue. Per the IEEE 802.11 standard, and unlike LTE, the client is in control of any Wi-Fi connections. A Wi-Fi client will try to retain connection with an access point until the connection becomes completely unusable, at which point the client will begin to seek connection via another access point. This “fail before fix” use model can be problematic in mission-critical applications such as Wi-Fi Calling and video conferencing where even short outages are not acceptable. Enterprise Wi-Fi vendors typically provide tools for setting handoff thresholds to force roaming between multiple network nodes, but creating a reasonable handoff experience requires testing and manual adjustment.

Likewise, congestion avoidance and spectrum/channel steering are important for mission-critical use cases, but Wi-Fi does not natively support them. Enterprise Wi-Fi vendors have worked around some of these limitations in their enterprise controllers, but not all vendor workarounds are interoperable – the workarounds are fully functional within the “walled garden” of a single vendor’s system, but another vendor’s access points may not be able to take advantage of the controller vendor’s enhancements.

Wi-Fi benefits from a zero cost of acquisition – nearly all computing devices include Wi-Fi radios as standard equipment. Efforts are underway to extend Wi-Fi


with enhancements for higher throughput, higher efficiency channel usage, more accurate positioning, broadcast, faster wake-up, and even Wi-Fi using light (so-called “Li-Fi” technology) instead of radio frequencies. We expect final approval in mid-2020 of the next-generation IEEE 802.11ax standard, marketed under the trademark “Wi-Fi 6” name. Additionally, there are efforts underway at the FCC to reallocate spectrum in the 6 GHz band to unlicensed use, which would be a benefit to users of the already crowded Wi-Fi bands. However, there are concerns that unlicensed use of the 6 GHz band will cause interference to existing point-to-point microwave links.

LTE Unlicensed

In an effort to secure additional spectrum with limited funds, mobile operators are moving forward with deployment of LTE Unlicensed (LTE-U) technologies, which is an offload technique that uses LTE signals in unlicensed bands. LTE-U is attractive to network operators because it is purely LTE; there are no spectrum auction costs to the operator, and use of unlicensed spectrum requires no license application. The LTE standard natively handles handoff and roaming. However because the spectrum is unlicensed the operators have no ownership rights, so if an LTE-U system experiences interference from another system the operators must work out their differences privately or resolve the problem through other means.

There are in fact multiple variants of LTE-U. The original LTE-U did not have a method for detecting the existence of other signals such as Wi-Fi in the unlicensed band, and this created a problem because European regulations require implementation of co-existence methods in shared spectrum. After a major controversy and debate between the mobile operators and the Wi-Fi industry players, a second method called License Assisted Access (LAA) was developed and standardized via 3GPP. LAA implements methods to help it co-exist with other unlicensed technologies. As of 2019, the question of whether LTE-U can politely co-exist with Wi-Fi in crowded unlicensed spectrum remains unresolved.

CBRS

In April 2015, the FCC created the Citizens Broadband Radio Service (CBRS), a 150 MHz allocation in the 3.5 GHz band intended for use by Small Cell equipment.

CBRS uses a three-tiered spectrum authorization framework to accommodate a variety of governmental, commercial, and private uses on a shared basis. Sometimes called “Private LTE”, CBRS brings elements of 4G and 5G together with an unlicensed spectrum access model. The CBRS Alliance handles CBRS certification, trademarked under the “OnGo” brand. Permission to access spectrum in the CBRS band will be managed by an automated frequency


coordinator, known as a Spectrum Access System (SAS), which will coordinate amongst three tiers of users:

• Incumbent Access: U.S federal users (including the U.S. Navy), Fixed Satellite Service earth stations, and some Wireless Broadband licensees. This user tier has top priority – all users in other tiers must avoid interference to and vacate channels used by IA users.

• Priority Access: Competitive bidding grants Priority Access License (PAL) users access to 10 MHz channels on a county-by-county basis for 10 years. PAL users pay for their access priorities, and have priority over all but IA users.

• General Authorized Access: This is the “unlicensed” tier. GAA permits open, flexible access to the CBRS band for the widest possible group of potential users. Permitted to use any portion of the 3.5 GHz band not assigned to a higher tier user, GAA users can operate opportunistically on unused Priority Access channels.

The Spectrum Access System (SAS) governs channel access and priority. CBRS site equipment regularly queries the SAS to determine what channels are available, and whether to grant access to a user. The SAS coordinates and controls the channels used by subscriber equipment. The SAS must monitor for the presence of Incumbent Access users, and if IA users are detected the SAS will issue channel-shifting orders to the PAL and GAA clients. Municipalities considering CBRS deployments should note that both PAL and GAA users must pay a monthly fee for access to the SAS – so while GAA is unlicensed it is not free in the same way that Wi-Fi is free.

It will take a few years before we understand the practical realities of CBRS. The CBRS band will provide a large amount of spectrum for users seeking to serve user demand, and some analysts believe that CBRS will account for half of all Small Cell installs by 2023 (Mobile Experts LLC, 2016). For indoor venues, the cost to deploy a CBRS network can be 30-50% lower than a DAS network due to advantages in power distribution cabling and the elimination of carrier equipment.

Figure 11: Federal Government tiered structure for 3.5 GHz CBRS


The CBRS band will provide a large amount of spectrum for users seeking to serve user demand, and some analysts believe that CBRS will account for half of all Small Cell installs by 2023.


Backhaul is Critical for Wireless Broadband

Backhaul is the term for connections between a wireless site and the operator’s core network. Every node in a wireless network, from the smallest HetNet node to the largest macro tower, requires a connection to the carrier’s data network. For femtocells and picocells in an enterprise in-building deployment, Ethernet connections over a LAN are used. For Small Cells and DAS, fiber optic connections are used. If neither fiber nor Ethernet are available, wireless connections may be used.

For various reasons, primarily performance and reliability, cellular carriers prefer fiber optic technology for backhaul. There are two kinds of fiber optic networks – lit fiber and dark fiber. Lit fiber describes systems shared between users, typically via a subscription model. Dark fiber describes fiber runs leased solely for one network operator, or installed by a utility provider for later use by a customer. Mobile network operators want dark fiber because it gives them full control and allows them to ensure the highest levels of service quality. If dark fiber is not available, the carrier will install it – either via aerial runs along poles, into existing conduit, or via new conduit. Underground construction is time consuming, expensive, and potentially disruptive to existing underground systems – so installing conduit for future use during other construction projects is increasingly popular.

The availability of dark fiber and conduit is a key enabler to making the transition to HetNets and 5G a reality. Network operators will take advantage of available dark fiber and conduit. Conduit and fiber are relatively inexpensive to install when done during other construction projects, and these latent assets are valuable for future municipal purposes such as business park build-outs, smart city networks, and providing broadband to residents and businesses.

Wireless backhaul is an emerging technology used where aerial runs or conduits are not available. These systems use extremely high frequency channels (in the 60 – 70 GHz range) to pass large amounts of data. Due to limitations in how RF signals behave at these frequencies, designing and deploying a wireless backhaul network requires a level of engineering sophistication beyond that of fiber optics, and as such in most cases, it remains a more complex solution used only when fiber and conduit are not available.

Wireless Telecom Legislation

Overview & Background

Since the early days of cellular telephony, the federal government has sought to encourage deployment of a robust nationwide wireless network. The federal government, recognizing the economic and social benefits of that network, enacted laws that attempt to facilitate and encourage deployment. In some

Backhaul is the term for connections between a wireless site and the operator’s core network. Every node in a wireless network, from the smallest HetNet node to the largest macro tower, requires a connection to the carrier’s data network.


cases, states such as California have encapsulated the federal laws and extended them. Some may argue that these laws are beneficial – others may disagree. The debate, as is the case in many debates throughout American history, hinges on striking a balance between local control and federal oversight.

A full treatment of these laws and their application to real-world situations is beyond our scope, but this handbook provides an overview of the most consequential legislative and regulatory decisions.

Telecommunications Act of 1996

The Telecommunications Act of 1996 (the “1996 Act”) was the federal government’s first attempt to help create a foundation for the wireless communications revolution we are now experiencing. The 1996 Act contained provisions concerning the placement of towers and other facilities for use in providing personal wireless services. Section 704 of the 1996 Act governs federal, state, and local government oversight for placement and construction of “personal wireless service” facilities (FCC – New National Wireless Tower Siting Policies, 1996).

“Personal wireless services” as defined in the 1996 Act included commercial mobile services, unlicensed wireless services, and common carrier wireless exchange access services.

Section 332 of the Communications Act, and the FCC’s rules, define the “Commercial Mobile Service”, regulated under Part 22 of the FCC’s rules for early cellular phones. The Personal Communications Service, originally created for early digital phones (e.g. “Sprint PCS”, “Metro PCS”, etc.), is regulated by Part 24 of the FCC’s rules (FCC – New National Wireless Tower Siting Policies, 1996).

The 1996 Act states that local governments may not take actions to discriminate against or outright prohibit (or have the effect of prohibiting) personal wireless service facilities. It also preempts any local government attempts to regulate on the environmental effects of RF emissions, and requires local governments to act “within a reasonable time” on requests to place, construct, or modify personal wireless service facilities.

Section 332 and the FCC “Shot Clocks”

A problem with the 1996 Act was that it left “reasonable time” open to interpretation. A wireless carrier seeking to solve a critical coverage problem might consider approval within 30 days reasonable. A local government concerned with historical preservation, responding to a citizen opposition group’s concerns about the health effects of wireless technology, or dealing with concerns about maintaining local government authority over public

The debate, as is the case in many debates throughout American history, hinges on striking a balance between local control and federal oversight.


rights-of-way might consider an application process lasting years to be reasonable.

In an effort to resolve this, the FCC in 2009 issued a Declaratory Ruling that 90 days is a presumptively reasonable time frame for processing collocation applications (“collocation” is defined as adding equipment to an existing wireless facility), and that 150 days is reasonable for anything that is not a collocation application. The 90- or 150-day time frames are calendar days, including weekends and holidays, from the date of application filing. Under the FCC’s regulation, the shot clock governing an application may be paused or “tolled” by mutual written consent of both the applicant and the local government, or if the local government notifies the applicant in writing (via a Notice of Incompleteness or “NOI”) that the application is incomplete. Section 332 imposes several requirements on local government if issuing a Notice of Incompleteness:

• The NOI must specify the code provision, ordinance or publicly stated procedures that require the missing information to be submitted;

• The NOI cannot impose new application requirements;

• Supplemental NOIs issued against NOI responses must be based on the original NOI.

Section 6409(a) of the Spectrum Act 2012

The Middle Class Tax Relief and Job Creation Act of 2012 made provisions in Title VI that expedite the availability of spectrum for commercial mobile broadband. The provisions in Title VI – also known as the Public Safety and Spectrum Act (the “Spectrum Act”) contained legislation known as Section 6409(a) that further clarifies how the local governments must respond to applications governed by the 1996 Act and the FCC’s Shot Clocks. Section 6409(a) also adds a requirement to approve minor modifications on existing “eligible facilities” within 60 days; however, this applies only to an “eligible facilities request” (Congressional Research Service, 2014).

Section 6409(a) defines an “eligible facilities request” as any request to modify an existing cell tower or base station that involves collocating new transmission equipment; removing transmission equipment; or replacing transmission equipment. These modifications could include changes that increase the width or girth, but do not “substantially change” the height of a wireless facility, i.e., a tower or monopole.

Section 6409(a) does several things in relation to the 1996 Act and the Shot Clocks. First, it says that the Shot Clock applies regardless of any local moratoria. Second, the date of application starts the Shot Clock, not the deemed complete date. Tolling the Shot Clock happens only after the local government notifies the applicant within a specified time that the application is incomplete, and the Notice of Incompleteness must “specify the code provision, ordinance,

The Middle Class Tax Relief and Job Creation Act of 2012 made provisions in Title VI that expedite the availability of spectrum for commercial mobile broadband.


application instruction, or otherwise publically stated procedures that require the information to be submitted.” Under Section 6409(a), any decision to deny a personal wireless service facility application must be in writing, and the denial must include substantial evidence for denial in a written record.

For many local governments, Section 6409(a) creates a key and critical issue because they have not created codes, ordinances, instructions, and procedures for managing modern wireless facility applications. This is especially true for HetNet (DAS and Small Cell) technologies, which are fundamentally very different from the applications for large macro towers that local governments have managed in the past. Smaller communities that have relied on wireless signals from adjacent towns or wireless facilities on private property will likely be faced with applications to install DAS and Small Cell facilities on utility poles or in the public right-of-way – and many are not prepared to respond to applications for large numbers of sites. Regardless of their readiness, the day of submission will start the Shot Clock. Local governments should begin preparing now to respond by adopting ordinances, updating codes, and creating Master Lease Agreements to cover the growing use of HetNet facilities in the public right-of-way.

California Assembly Bill 57

For California’s local governments, there is an additional twist to the Section 6409(a) and Shot Clock story. In October 2015, the California state legislature passed AB 57, which further limits the ability of local governments to apply discretion in approval of wireless service facilities. Following the “Deemed Approved” approach of California’s Permit Streamlining Act, a wireless facility subject to Section 6409(a) that is an “eligible facility” and has not been justifiably denied is “deemed approved” if the applicable FCC Shot Clock runs out. (AB-57’s Shot Clocks are 150 days for new installations, and 90 days for co-locations.) Unlike under the Permit Streamlining Act, AB 57 does not allow the Shot Clock to be paused due to delays in conducting a complex environmental review under the California Environmental Quality Act (CEQA). This means that local governments should be prepared for these applications well in advance, and be prepared to act on applications in a timely manner, or risk lawsuits for failing to respond under the law.

It is important to note that AB 57 has a few exception cases. It does not apply:

• To actions by the California Coastal Commission or other state review agencies such as the San Francisco Bay Conservation and Development Commission;

• To City/Town properties such as parks and city-managed campuses; or

• To facilities at fire stations.

In October 2015, the California state legislature passed AB 57, which further limits the ability of local governments to apply discretion in approval of wireless service facilities.


CPUC Rulemaking 14-05-001

In 1998, the California Public Utilities Commission’s Decision D.98-10-058 provided competitive local exchange carriers and cable television providers with nondiscriminatory access to public utility infrastructure. CPUC Rulemaking 14-05-001 included Decision D.16-01-046 providing commercial mobile radio service (CMRS) carriers with the same nondiscriminatory access. The rulemaking amends most right-of-way rules in D.98-10-058 to apply to CMRS and adopted CMRS-specific pole-attachment fees. It also amends General Order (GO) 95 to ensure that CMRS pole installations are safe, and leaves certain other issues open to later decisions (CPUC R14-05-001, 2016).

For a period, the outcome of this ruling resulted in a large number of requests to install Small Cell antennas on utility poles, because many municipalities were either not ready or not willing to accept Small Cell applications. Because these utility pole installations are private property transactions, many municipal attorneys have determined that they can only enforce GO-95 compliance, but cannot enforce aesthetic requirements on utility sites.

Figure 12: Integrated poles make good Small Cell sites.

FCC Small Cell Order 18-133

In September 2018, the FCC issued a “Declaratory Ruling And Third Report And Order” related to 4G Small Cell and 5G siting. The Order asserts a national interest in deployment of wireless technologies, and sets forth several items intended to streamline processing and approvals. The Small Cell Order:


• Requires municipalities to create ministerial processes for approval;

• Defines a new standard for “Effective Prohibition”;

• Requires cost-based rates for leases and applications, and defines “Safe Harbor” rates if those costs are not known or not calculable;

• Defines a new aesthetics standard, defines a “Small Cell” facility, and requires that aesthetic guidelines be published in advance;

• Creates new 60-day and 90-day Shot Clocks.

On the topic of “Effective Prohibition”, the Small Cell Order asserts itself as the primary standard for preemption of local permitting processes, and any state and local policies that affect competition. It removes the requirement that an applicant must prove a “significant gap” in coverage to justify an application, and states that action at the municipal level cannot “materially inhibit or impede” a carrier’s ability to compete.

The Small Cell Order requires cost-based rates for site leases and application fees. If costs cannot be determined, the Order defines a presumptive rate of $270/year per pole for leases, and application fees of $500 for five small cells.

The FCC also adopted a new three-part test for municipal aesthetic review of small cells. Aesthetic requirements must be (1) reasonable, (2) no more burdensome than those applied to other types of infrastructure deployments, and (3) objective and published in advance. The Order also requires that municipal requirements be technically feasible – for example, a municipality may not require underground installation of Small Cell antennas, because it is not technically feasible.

Finally, the Small Cell Order defines new Shot Clocks: a 60-day Shot Clock for small cells on existing structures, and a 90-day Shot Clock for new poles. The Order requires a single Shot Clock for all authorizations including zoning, encroachment/excavation, traffic, etc. (FCC, 2018).

Appeal of the FCC Small Cell Order

A coalition of local governments originally brought a challenge to the FCC Small Cell Order in the 10th Circuit Court of Appeals. The plaintiffs prevailed in a motion to move the case to the 9th Circuit Court of Appeals, and as of October 2019, the FCC Small Cell Order is in litigation. Oral arguments are scheduled for February 2020, but there is no way to estimate a date for ruling.

We also note that the 10th Circuit court did not grant the appellant’s request for stay of the Order, so it is presumptively in effect at this time and municipalities not in compliance may encounter legal challenges.


Addressing Common Public Concerns Regarding Wireless

Overview and Scope of Authority

Within the confines of existing law and regulation, municipal governments can exercise control over the “time, place, and manner” in which wireless facilities are deployed. In addition, the California Supreme Court ruled that municipalities could exercise control over aesthetics of wireless facilities deployed in the public right of way (T-Mobile West LLC v. City & County of San Francisco, 2019).

During the application and review process for wireless facilities, municipal governments – and especially elected officials – are often in a difficult situation. While they must respond to constituent concerns, they are also constrained by federal regulations that prevents denying permits based on some type of constituent concerns. Failure to adhere to these regulations opens the municipality to possible legal action from the wireless industry, but failure to respond to constituent concerns leaves elected officials open to challenges at the ballot box. It is critical that municipal governments clearly communicate to constituents the scope of their authority in these situations. Under federal regulations concerns about real estate valuations or health effects are not acceptable reasons for denying a permit – despite how the public may feel about them.

Real Estate Impacts of Cell Sites

During public hearings about proposed cellular projects, or consideration of Master Lease Agreements, a claim is sometimes made that proximity to cellular sites can result in up to a 20% reduction in real estate valuation of nearby homes. Often cited as “known fact”, this claim is actually an urban legend passed around in the real estate community, often without attribution to a source. Looking at the source of the claim is revealing; the assertion comes from an article published in the Appraiser’s Journal (Summer 2005 edition) written by Sandy Bond and Ko-Kang Wang in response to concerns about a 120-foot cell tower under consideration in New Zealand. The authors used a case-study survey approach in and around Christchurch, NZ. The problems with this approach cannot be overstated; survey bias, recall bias, audience bias, and a host of other issues certainly affected the results. Furthermore, the behavior of New Zealanders in response to a 120-foot tower site does not necessarily indicate the behavior of U.S. buyers near smaller, concealed, or lower-power sites.

In contrast, Joint Venture Silicon Valley published a real estate impacts report in 2012 based on an objective source; Multiple Listing Service (MLS) transaction data. The report showed no correlation between proximity to cellular sites and real estate valuations. Compiled using over 1,600 single-family home

The report showed no correlation between proximity to cellular sites and real estate valuations.

Within the confines of existing law and regulation, municipal governments can exercise control over the “time, place, and manner” in which wireless facilities are deployed.


transactions, the data set spans January to September 2012 and accounts for sales near 70 wireless sites in Palo Alto, Redwood City, Saratoga, and San Jose. The survey compared the “list” and “sale” price for transactions based on the distance from the sites, grouped by distance from the selected sites; (1) within an eighth of a mile, (2) an eighth to a quarter of a mile, and (3) a quarter to a half of a mile. In addition, the study included all types of wireless sites; (a) a cellular tower, (b) cellular equipment placed on buildings (e.g. churches, office buildings, etc.), and (c) placed on a utility structure (e.g. electrical poles, transmission towers, etc.) (Joint Venture Silicon Valley, 2012).

To our knowledge, there is no other validated study of this type – and thus no scientific or economic basis for the claim that cellular sites have an adverse effect on real estate valuations. It is also important to consider generational effects on real estate valuation. Starting in 2018, income distribution by generational group has shifted away from Baby Boomers to Generation X’ers and Millennials. Both of these groups are very connected and communications-dependent, and their preferred connection method is cellular service.

RF Safety of Wireless

Concerns about aesthetics and real estate valuation are often proxies for concerns about health effects. To date there has not been a conclusive study linking RF radiation to cancer. The World Health Organization (WHO) classified electromagnetic fields (EMF) emitted by wireless devices as a possible carcinogen, which does not mean it is a probable or known carcinogen. The WHO also classifies smoke from wood fires, red meat, pickles, and even drinking very hot liquids as possible carcinogens.

The first studies on health effects of electromagnetic fields started in the 1950s, and literally thousands of studies since then have found no adverse health effects at RF exposure levels below those defined by current published safety standards. Far fewer studies (a few hundred) have claimed to find health effects, and those studies were either inconclusive or were invalidated when subsequent studies failed to reproduce the claimed results.

Reproducibility is a key requirement of proper scientific and medical research. For example, when cellular sites were first being deployed in the 1990s, some smaller studies (using sample sizes of about 1,000 subjects) in Sweden and France suggested that EMF might cause brain cancer, but follow-up studies failed to reproduce those findings. Studies with larger samples (using tens of thousands of subjects across thirteen countries) found no link between RF and cancer. It is also important to note that nearly all EMF health studies focus on impacts from cellular handsets, which due to distance effects have a greater impact on the human body than cellular sites.

The first studies on health effects of electromagnetic fields started in the 1950s, and literally thousands of studies since then have found no adverse health effects at RF exposure levels below current public safety standards.


Figure 13: Electromagnetic Spectrum & RF Uses

Source: Hammett & Edison, Inc.

NIH NTP Rodent Study

A study completed in 2018 by the U.S. National Toxicology Program (often referred to as the “NTP rodent study”) studied the risk of cancer from cellular handsets, not cellular sites, although opposition groups often cite the NTP rodent study as evidence during site permit and planning hearings. The NTP rodent study claimed to find some limited evidence of cancer risk in power levels from handsets, but the results were inconclusive, and there were several unexplained issues with the study animals. The Ramazzini Institute’s study (Falcioni et al., 2018) claimed to reproduce the NTP rodent study results, but the International Commission on Non-Ionizing Radiation Protection (ICNIRP) found significant issues with both studies (ICNIRP, Health Physics Society, 2019).

Reviews of the NTP rodent study results and methodologies have found flaws:

• The study only showed effects in male rats – not female rats, not in male or female mice – and no mechanism has been proposed to account for variance in both species and gender.


• The EMF-exposed male rats actually lived longer than the control group, and the control group rats (for an unknown reason) had significantly shorter lifespans relative to historical control rats.

• The control group male rats had a statistically low incidence of naturally occurring tumors. Statistically speaking, if even one of the control group’s male rats had developed a naturally occurring tumor, the inferred link between EMF and cancer in the exposed male rats would have become meaningless.

• The study exposed the rodents to power levels at or above those experienced by humans using cellular handsets. The exposure was over the rat’s entire body instead of just the head, hand, or other limited areas. The EMF field generator cycled on and off every 10 minutes, for 18 hours each day, over the entire life of the rodent. These conditions are very different from the exposures experienced by humans using handsets in daily life.

The NTP rodent study used RF power levels at or above those generated from handsets. Handsets generate far greater EMF impacts to the human body than cellular sites, because the major factor in determining the EMF exposure level on humans is the distance between a person and the antenna. Unless you have climbed up a tower and are literally leaning your head against the cell site’s antennas, the levels of RF energy affecting you from cell sites are tens of thousands or millions of times lower than handsets.

After publication of the NTP rodent study, the International Commission on Non-Ionizing Radiation Protection (a group of scientific and technical experts that produce recommendations on safe RF exposure levels) reviewed the study results and methodologies. In response, they stated, “ICNIRP considers that the NTP (2018a, b) and Falcioni et al. (2018) studies do not provide a consistent, reliable and generalizable body of evidence that can be used as a basis for revising current human exposure guidelines. Further research is required that addresses the above limitations.” Further, in 2019 they stated, “The NTP’s outlying finding is further complicated by important methodological limitations including the effect of the greater lifespans of the exposed rats on the statistical analyses, lack of blinding in the pathological analyses, and a failure to account sufficiently for chance in the statistical analyses. Collectively these two studies’ limitations preclude drawing conclusions about carcinogenicity in relation to RF EMF.” (ICNIRP, 2019).

Self-proclaimed “EMF Safety Experts” ignore the math and physics of the NTP, Ramazzini, and other inconclusive studies to create false equivalencies through inference, supposition, and quote mining. Many of these “experts” run websites and businesses that sell products intended to either support and inflame fears (EMF meters and detectors), supposedly reduce RF exposure (low-EMF appliances and EMF shielding products), or perpetuate propaganda via books and videos.


Setting aside the problematic NTP and Ramazzini studies, we note that data from the National Cancer Institute (National Institutes of Health, U.S. Department of Health and Human Services) shows that both incidence and mortality of brain cancer has gone down since the mid-1990s, during the same period when society’s use of wireless devices and sites increased exponentially. This fact alone casts serious doubts about the possibility of a causal relationship between EMFs and cancer. In other words – despite a massive increase in quantity and use of wireless devices over the past two decades, we are not seeing a commensurate increase in the kinds of cancers people commonly associate with RF exposure (National Cancer Institute, 2019).

Figure 14: Cell phone usage does not correlate to cancer incidence

Source: www.xkcd.com (Creative Commons A-NC 2.5)

Danish Cohort Study

The Danish Cohort Study is to date the world’s largest study on mobile phones and cancer in the human population. Countries such as Denmark, because of their high mobile phone use and comprehensive social and medical databases, offer a source and quality of information that is not available elsewhere.

All Danes have a “Social Security” number, what they call a “CPR” number, assigned at birth. Danish mobile phone carriers are link subscriber contracts to the subscriber’s CPR number. The Danish National Cancer Registry tracks all patients – noting the type of cancer and the CPR number of the patient. Thus, the whole population of Denmark is both a subject and control group, because individuals are searchable by their mobile phone numbers and their CPR number. An independent organization, the Danish Cancer Society (comprised of more than 400,000 members, 45,000 volunteers, and 690 full-time employees) conducted the studies using these data sets.

The Danish Cohort study has two important methodological advantages over most other studies. Firstly, it passively followed a computerized cohort of subjects via the Danish registries, and in doing so avoided the need to contact people. Consequently, it eliminated the problems of non-response and self-selection – which has been of considerable concern in studies with other designs. Secondly, it used digitized subscriber data obtained from the mobile

In other words – despite a massive increase in quantity and use of wireless devices over the past two decades, we are not seeing a commensurate increase in the kinds of cancers people commonly associate with RF exposure.


operators, rather than retrospective questionnaires or interview information obtained from users – eliminating survey and recall biases. Results from the Danish Cohort Study are definitive, and have successfully passed through several layers of academic review (BfS, Danish Cohort Study, 2011). Here are the four key documents:

Use of mobile phones and risk of brain tumors: update of Danish cohort study.

• http://bit.ly/1_BMJ_2011

• Participants: All Danes aged ≥30 and born in Denmark after 1925, subdivided into subscribers and non-subscribers of mobile phones before 1995.

• Main outcome measures risk of tumors of the central nervous system, identified from the complete Danish Cancer Registry. Analysis conducted on 358,403 subscribers who accrued 3.8 million person-years of mobile phone ownership.

• Conclusion: In this update of a large nationwide cohort study of mobile phone use, there were no increased risks of tumors of the central nervous system, providing little evidence for a causal association.

Mobile Phone Use and Brain Tumors in Children and Adolescents: A Multicenter Case–Control Study.

• http://bit.ly/2_JCNI_2011

• There is a hypothesis that children and adolescents might be more vulnerable to possible health effects from mobile phone exposure compared to adults. This study investigated whether mobile phone use is associated with brain tumor risk among children and adolescents.

• Conclusion: The absence either of an exposure–response relationship in terms of the amount of mobile phone use, or by localization of the brain tumor, argues against a causal association.

Mobile telephones and brain tumors Evidence is reassuring, but continued monitoring of health registers and prospective cohorts is still warranted.

• http://bit.ly/3_BMJ_2011

• In the linked cohort study, Frei and colleagues found no evidence that the risk of brain tumors was raised in 358,403 Danish mobile phone subscribers. This was also true when the cohort was restricted to people who had been subscribing for more than 10 years, when glioma and meningioma were analyzed separately, and when tumors in the anatomical region closest to the handset were analyzed.


Possible relationship between use of mobile phones and the risk of cancer: Questions and Answers.

• http://bit.ly/hjernekraeft_2011

• Publication sets forth questions and answers intended to address scientific findings on the possible relationship between use of mobile phones and the risk of cancer into a broader context.

Fears of New Technology

Every time there is a new generation of technology, wireless or otherwise, concerns arise that it will be somehow more dangerous than before; 2G was claimed to be more dangerous than 1G, 3G was going to be worse than 2G, etc. Today, people are afraid of 5G. We can see the same pattern throughout history: Starting in the late 19th century and continuing until the 1930s, people feared electricity and incandescent lighting. Then fluorescent light was feared because it was different (and supposedly more dangerous) than incandescent light. Today, we are seeing sensationalized articles about purported dangers from LED lighting. Some people will always be prone to fear what is new (L. Simon, 2005).

Updated FCC Guidance on EMF Safety

A criticism levied by opponents of cellular deployments is that the FCC guidance on electromagnetic safety has not changed since 1996. This is true - because the underlying science and physics have not changed. The FCC’s guidance from 1996 is as applicable to the upcoming fifth-generation “5G” technologies as it was to the original analog “1G” cellular phones carried by our parents. However, because 5G will operate in millimeter wave bands, there is a need to extend the guidance to higher frequencies.

Regulatory agencies like the FCC do not directly conduct scientific and medical investigations – they rely on the expertise of government agencies like the Center for Devices and Radiological Health at the Food and Drug Administration (FDA); the Environmental Protection Agency, the National Institutes for Health, the World Health Organization, and scientific organizations like the National Council on Radiation Protection and Measurements (NCRP) and the Institute of Electrical and Electronics Engineers (IEEE). When the FCC last revised their RF exposure rules in 1996, they followed the recommendations of the EPA and FDA, and used the recommendations made in NCRP Report 85 and some provisions of IEEE C95.1 standard published in 1992. The documents reflected the current understanding of biological effects of RF energy and new technical insights into how RF energy is absorbed by the human body.

While the NCRP is a Congressionally chartered organization and only updates reports at the request of one or more of the Federal agencies or departments, the IEEE is required to periodically update all of their standards including

Every time there is a new generation of technology, wireless or otherwise, concerns arise that it will be somehow more dangerous than before...


C95.1, and has done so several times since 1992. While there have been some clarifications and additions to the standard, the basis of the safety standard has remained the same – and thus the FCC’s safety guidance has not materially changed. In December 2019, the FCC issued a ruling and notice of proposed rulemaking that updates further safety guidance based on the latest IEEE C95.1-2019 standard, and which accounts for other medical findings and research since the previous version (FCC 19-126, 2019).

In conclusion, it is important to note that we are not saying that the science is settled on the question of electromagnetic safety – because good science is never settled. Although thousands of studies have found no health effects from cellular signals, some have reported inconclusive findings, and we believe it is important that researchers attempt to reproduce those findings. Given the exponential rise in our use and deployment of wireless facilities, we should expect that the medical community, academia, and government agencies tasked with human health and the public good will continue to investigate the effects of electromagnetic energy on the human body.

Wireless Telecom Roadmap – What Does The Future Hold?

Increased Deployment of HetNets

For the reasons previously outlined in this handbook, local governments should expect applications for both 4G and 5G Small Cell facilities to increase, especially on utility poles in the public right-of-way. HetNet technologies provide the best opportunity for carriers to make the most efficient use of limited RF spectrum in the face of exponential growth in mobile data usage, and Small Cell technology is a key component in deployment strategies for all wireless carriers. The shorter range of millimeter wave signals means that 5G sites in those bands must be spaced closely together, driving up the number of applications and increasing the possibility of resident objections.

LTE Unlicensed

Local governments, especially those that have deployed – or are considering deployment of – Wi-Fi networks in the 5 GHz band should closely monitor the trials and co-existence tests of LTE-Unlicensed. We do not yet know how well Wi-Fi and LTE-U will behave in large-scale real-world deployments, and procedures for how to test for and mitigate interference are still under development.

In December 2019, the FCC issued a ruling and notice of proposed rulemaking that updates further safety guidance based on the latest IEEE C95.1-2019 standard, and which accounts for findings and research since the previous version.


Wi-Fi Carriers & Voice-over-Wi-Fi

Since 2016, we have seen limited growth in the use of Wi-Fi networks as an alternative to traditional mobile carriers. Subscribers to these “Wi-Fi First” plans use phones that seek out Wi-Fi as a preferred network for both voice and data, only falling back to cellular when necessary. As of 2019, the primary vendors for this model are Comcast’s “Xfinity Mobile” offering, and Google’s “Fi” service.

CBRS, Private LTE, and Private 5G

These technologies present some very interesting opportunities for both private and public entities to deploy next-generation wireless networks. Unlike Wi-Fi, which is very good for local area networks and enterprise deployments but does not scale well to wide area networks and public infrastructure, private cellular networks may be a better path towards creating scalable networks for large numbers of users.

Dedicated IoT Networks

Competing with Wi-Fi and mobile data networks for IoT are several proprietary standards, collectively known as Low Power Wide Area (LPWA) systems. Designed specifically for IoT applications, LPWA technologies offer low power consumption over long distance links, which are often a key design criterion for IoT systems. The downside is that in many locations, the networks do not yet exist, so siting and permitting efforts will be required. In most cases, LPWA facilities are small, with equipment cabinets less than 12 cubic feet and antennas about three feet long, and thus have minimal aesthetic effect. Local governments should consider implementing streamlined review processes for LPWA equipment and sites.

FirstNet – LTE for Public Safety

The Spectrum Act of 2012 contained legislation and funding for a nationwide LTE network dedicated for use by public safety and First Responders, now called FirstNet™. AT&T won the RFP bid to build FirstNet, and the process of building the network has already started. We believe that FirstNet will create a unique challenge for local governments, because the needs of public safety coverage will dictate the locations of FirstNet’s wireless facilities. Local governments that have enacted full or partial moratoriums on wireless facilities will likely find themselves forced to approve a FirstNet site, lest they risk denying public safety the resources they need.

FirstNet technology will look very much like the existing wireless networks, and will use the same HetNet architectures to provide wide-area coverage from large


macro towers, combined with DAS and Small Cell equipment to provide speed and spectrum efficiency in dense populated or hard to cover areas.

Recommendations for Municipal Governments

Understand and Adapt to New Telecom Legislation

Local governments must carefully consider and prepare for responses to wireless facility applications given the complexities of the FCC Small Cell Order, Section 6409(a), and state laws such as California’s AB 57. The alternative is a possible lawsuit, which nobody wants and only serves to suppress cooperation on the shared goal of building critical wireless infrastructure. Local governments must be diligent about creating tools such as a comprehensive pre-application checklist, aesthetic guidelines, and publishing clear application instructions that “specify the code provision, ordinance, application instruction, or otherwise publically-stated procedures that require the information to be submitted.” (Section 6409(a), Spectrum Act of 2012).

At a minimum, local governments should determine if their existing codes and ordinances address wireless facilities in the public right-of-way – and should quickly take action to remedy if they do not. Due to the unique nature of HetNet facilities, these new codes and ordinances should be separate from any existing ordinances that pertain to large macro towers and equipment.

Recognize the Societal Value of Wireless Broadband

The economics of the Digital Divide are plain and striking – internet use by households below $75,000 median income drops off exponentially (White House Council of Economic Advisors, 2016). Elementary and secondary school teachers are increasingly requiring students to complete and submit work online via cloud-based tools such as Office 365™ and Google Docs™. Wireless is increasingly the sole method of internet access for low-income households (McHenry, 2016). How will children of low-income families compete without access to broadband? Access to wireless broadband is critical, and both governments and carriers have a shared social responsibility to ensure equitable access for all residents.

Local governments must carefully consider and prepare for responses to wireless facility applications given the complexities of the FCC Small Cell Order, Section 6409(a), and state laws such as California’s AB 57.


In 2016, the California Emerging Technology Fund (CETF) published a survey of the state’s Digital Divide (CETF, 2016). Almost three out of four (74%) survey respondents cited costs of access or equipment as their reason for not having broadband access. The 2016 survey found broadband adoption rates well below the overall state average of 84% for:

• Households earning less than $22,000 (68%)

• Adults 65 or older (56%)

• Spanish-speaking Latinos (69%)

• Not a high school graduate (63%)

• Adults who identify as having a disability (71%)

A Pew Research report from 2019 shows similar results. Pew reported that for 37% of American adults, their online activity is primarily via a smartphone. This number rises to 58% for people aged 18-29, and 47% for people aged 30-49. These numbers are increasing annually across all age groups; in 2013, only 2% of people over age 65 primarily accessed the internet via smartphones – in 2019, that expanded to 15% for the same age group – a seven-fold increase over six years.

In the past, the thinking was that mobile users are demographically affluent – the stereotypical multi-tasking businessperson with a smartphone – but today’s reality is otherwise. Mobile devices have replaced laptops and PCs in many homes. Families in poverty, unable to afford both mobile data and wired broadband, often opt for mobile data only. Wireless telecom and mobile broadband are not luxuries for the wealthy - they are critical systems for all residents struggling to keep up with (or join) the 21st century. Fast reliable wireless broadband coverage is not a convenience for the privileged few – it is a vital resource for daily life preferred by a majority of our country’s residents. Some municipal governments view telecom projects as an opportunity to increase revenue, which is misguided. Municipal governments need to view communication networks no differently than water or electricity projects, and they should consider legitimate requests for safe and aesthetically reasonable communication equipment projects not as a revenue source, but as an opportunity to secure private sector investment in infrastructure that improves our quality of life and helps bridge the Digital Divide.

Install Conduit, Adopt Dig Once Policies, and Allow Micro-Trenching

The rate at which we consume digital data shows no signs of slowing down. The best technology for carrying large amounts of data is fiber optics. Installing conduit at every opportunity is an inexpensive way to invest in our future, and


conduit installed should be oversized and doubled-up whenever possible to facilitate future growth.

Local governments should create “Dig Once” policies that encourage conduit installation, and should create “Opportunity Alert Systems” that notify wired and wireless telecommunication companies when permits are issued for underground work that could allow conduit to be installed. Local governments should also create codes and ordinances that allow for “Micro-Trenching” – a less disruptive installation process that allows fiber to be deployed using flexible ducts laid into a saw-cut just over one inch wide (Broadband Properties, 2019).

Stay Informed and Educated

Wireless communications is a complex topic, and it is constantly changing. People who have spent their careers in the field struggle to keep up. There is no dishonor in admitting the need for help, and municipalities should hire or retain good sources of information and support to help guide strategy and tactics. Adding wireless expertise to municipal staff, either by hiring or by contracting, is necessary given the highly technical and rapidly evolving nature of the technology.

It is important to stay connected with the wireless community. A good way to do this is to attend local conferences, educational seminars, or by hosting informational study sessions with your review and hearing bodies. This helps build a network of contacts that can offer advice and help to understand technologically feasible options and trade-offs.

Unfortunately in many instances a lack of mutual understanding has arisen between wireless carriers/operators, residents, and municipal governments. This causes protracted negotiations and permitting processes that take many months or even years to complete, and delays projects to the point where they become unprofitable or even impossible. Some local governments, acting to appease objections of residents, have treated applications for wireless facilities with disdain or even outright hostility.

Education of residents is critical to help move projects forward without excessive opposition. Municipal government leaders often sit through hours of citizen objections as to why a site should not be located in a certain spot. Fears of new technology, concerns over aesthetics, fears about the impact of wireless facilities on property values, etc. often drive resident objections.

The “not-in-my-back-yard” (NIMBY) perspective, which gives excess weight to the opinions of a vociferous minority at the expense of the needs of all residents, has led to circumscription of local control – e.g. we see this happening in zoning and planning for housing e.g. CA Senate Bill 50, and in telecommunications legislation and regulation at both the federal and state level. The

Adding wireless expertise to municipal staff, either by hiring or by contracting, is necessary given the highly technical and rapidly evolving nature of the technology.


telecommunications legislation and rules forces local government to publish their application criteria up front, not change application criteria in mid-process, make decisions within a set timeframe on applications, and make decisions on a reasonable and equitable basis.

The complexities of managing telecom applications and permitting will only increase as the wireless telecom industry moves towards HetNets architecture, transitioning from macro towers covering many square miles to densified networks using small low-power sites covering only a few blocks – often in the public right-of-way on streetlights, signs, utility poles, and other street furniture. By approaching these densified networks not as a problem but as a joint opportunity to improve our region’s networks, we can overcome this challenge and move forward with new technologies that benefit our residents and local economies.

There is no dishonor in asking for help. Wireless networks are not simple things. Even senior engineers who have been building wireless networks for decades struggle to keep up with new technologies. Leaders in all departments (planning, public works, economic development, real estate, utilities, etc.) should not be embarrassed to admit what they do not understand, and should bring in qualified help as needed when sorting out options.

Application Processes, Checklists, Codes and Ordinances

When developing codes, ordinances, instructions, and procedures for handling wireless facility applications, local governments should be very specific about what constitutes a “complete application” and be very clear about what must be contained in a complete application. Ordinances should back up these requirements, supported by published instructions and procedures in detailed and specific language. Local governments should publish a wireless facility pre-application checklist, and publish a clear and comprehensive application process.

Takeaways for Municipal Leaders

4G Small Cell and 5G applications are coming – if they are not already on your desk, they will be soon. Ask your Planning and Public Works Directors if they have a review process in place for wireless facilities in the public right-of-way. If there is no defined process, work with your City Attorney to create one (or borrow an example from another city) that meets your needs.

Create specific and detailed aesthetic guidelines, and include these in your application process. If you do not have an aesthetic guideline, work with your Planning Commission to create one, or borrow an example from another city.

Education of residents is critical to help move projects forward without excessive opposition.


Inventory your assets. Get a sense of what utility poles, light poles, and conduit routes your municipality does and does not own. Are certain areas under the jurisdiction of another government agency?

Reach out. Talk with your local electric utility provider about options for metering wireless facilities, and ways to avoid the need for bulky electric meters or disconnect boxes on sidewalks or poles. Electric utilities have rigorous standards for equipment attached to their networks, so be sure to have this conversation early on – slow response on the part of a utility will not freeze a Shot Clock.

Educate. Hold an information session for active community groups, as well as elected leaders and appointed bodies that may have an interest: e.g. Planning Commissions, Design Review Boards, and Historic Preservation Commissions. Provide photo examples of DAS and Small Cell sites installed elsewhere. Invite carrier and utility representatives.

Update Infrastructure. Evaluate whether limited-area micro-trenching can minimize fiber optic deployment costs and reduce the need for major street trenching activity. This option can benefit both cellular providers, wired broadband and cable TV providers, as well as independent/community-based internet service providers and government agencies. Also, consider creating Dig Once policies to expand opportunities to build fiber optic infrastructure over time. Remember that, for the most part, wireless facilities still require fiber optic backhaul. Fiber and conduit are relatively cheap compared to labor and construction costs, so it is an investment worth making to install fiber and conduit while opening up streets or sidewalks.

Recommendations for Carriers, Operators, and Utilities

Understand the Complexities of Local Government

Carriers and network operators need to understand that municipal governments are responsive to all residents, and must balance often-conflicting edicts to move their cities and towns forward in a progressive manner while honoring and maintaining the area’s local history and heritage. Carriers and network operators must also recognize that small cell wireless is a relatively new topic for municipal governments, and so they may not have the staff or expertise to handle applications.

Communicate Clearly and Credibly With Residents

Carriers and network operators need to communicate well with local residents and then commit to hearing out their concerns – even if those concerns might


seem ridiculous or uninformed. They need to credibly and straightforwardly educate the public about the value of communications, and most importantly explain the various technologies and their benefits in practical and meaningful terms.

Commit to Bridging the Digital Divide

It is easy and profitable to focus deployment resources on higher-income areas. The harder thing, but the right thing, is to commit to building networks into underserved areas to help bridge the Digital Divide and protect our most vulnerable residents. It may be that these networks are less profitable, or even take a small loss, but the goodwill they create will ease tensions and concerns – which benefits everyone.

Work to Build and Maintain Trust

Carriers and network operators need to be hyper-vigilant about ensuring that the equipment build matches the application and design documentation. They need to ensure that projects do not include unpermitted modifications, consider the needs of residents and neighborhoods, proactively enforce aesthetic guidelines on contractors, avoid shoddy workmanship, and do everything possible to avoid building wireless facilities that conflict with architectural or historical preservation efforts. They should choose and use equipment that is smaller, quieter, and minimally visible – and always be pushing their component vendors to develop products that help meet these goals. Communication and openness with residents and local governments about even small changes are the keys to building trust – changes slipped in under the radar once discovered breaks trust, and this gives opposition groups a lot of ammunition to protest new projects, which is ultimately counter-productive.

Carriers and network operators need to be hyper-vigilant about ensuring that the equipment build matches the application and design documentation.


Glossary of Terms

Term Definition

2G Second generation cellular.

3G Third generation cellular.

4G Fourth generation cellular, an ITU-R definition governed by the IMT-2010 standard.

4G Advanced An update to 4G, governed by the IMT-Advanced standard.

5G Fifth generation cellular, an ITU definition governed by the IMT-2020 standard.

3GPP Third Generation Partnership Project, a standards body.

ANSI American National Standards Institute, a standards body.

ARPUAverage Revenue per User, a measure of system revenue relative to the number of users – to be profitable, ARPU must be higher than the total costs of building and maintaining the network.

Backhaul The connection used to link a cellular site to the carrier’s core network.

Bit A single unit of digital information.

Boomers Baby Boomers, the age group of individuals born between 1946 and 1964.

Broadband Data that transfers at minimum speeds of 25 Mbps download, 3 Mbps upload (Per the FCC’s 2015 definition).

Byte A block of 8 bits.

CBRS Citizens Broadband Radio Service, a 3.5 GHz band communications standard for Small Cells, used in the USA.

CellularA wide-area mobile wireless technology consisting of many sites interoperating as a network, for the purposes of providing voice and data communications.

CETFCalifornia Emerging Technology Fund, a statewide non-profit organization whose mission is to close the digital divide in California.

Churn A rough metric of the rate at which subscribers change from one carrier to another.

Co-LocationThe installation of wireless equipment and antennas for multiple technologies and/or competing carriers to a single tower or wireless facility.

CPUCCalifornia Public Utilities Commission, oversees and regulates companies that provide utility services using the public right of way.

CTIA A trade association representing the wireless communications industry in the United States.

DAS Distributed Antenna System, can be indoor (typically just called DAS) or outdoor (usually called o-DAS).

Dark Fiber Fiber optic cabling which is unused and reserved for future use.

dB Decibel, a unitless ratio of gain or loss.

dBd Decibels of antenna gain relative to a simple dipole antenna.

dBi Decibels of antenna gain relative to a theoretical point-source antenna.

dBm Decibels of power gain or loss relative to a milliwatt of RF energy.

EB Exabyte, 1x1018 bytes.

EIRPEquivalent Isotropically Radiated Power, the product of transmitter power and the antenna gain in a given direction relative to an isotropic antenna of a radio transmitter.

eMBB Enhanced Mobile Broadband, a 5G use profile primarily focused on handsets and user devices.

EMF Electromagnetic Fields, the combination of time-varying electric and magnetic forces.

ERPEffective Radiated Power, an IEEE standardized definition of RF power, measures the combination of the power emitted by the transmitter and the ability of the antenna to direct that power in a given direction.

FCC Federal Communications Commission.

FirstNet™A nationwide network of LTE and 5G, reserved for use by public safety, first responders, governments, and critical infrastructure users.

FWA Fixed Wireless Access, a use case of 5G providing broadband service to fixed locations.

GAA General Authorized Access, a CBRS user tier.

GB Gigabyte, 1x109 bytes.

Term Definition

GDP Gross Domestic Product, the monetary value of all finished goods and services made during a specific period.

GenX’ers Generation X, the age group of individuals born between 1965 and 1980.

GenZ’ers Generation Z, the age group of individuals born between 1997 and 2012.

GHz Gigahertz, 1x109 hertz.

Gig EconomyThe economic shift of workers away from full-time long-term employment to transient short-term jobs or “gigs” – sometimes called the Contractor Economy.

GSMA GSM Association, a trade body that represents the interests of mobile network operators worldwide.

Handoff The process by which a wireless voice or data connection is seamlessly transitioned from one site to another.

HetNet Heterogeneous Network, a system of dissimilar wireless technologies operating as a whole.

Hz Hertz (cycles per second), a measure of signal frequency.

IA Incumbent Access, a CBRS user tier.

ICNIRP International Commission on Non-Ionizing Radiation Protection.

IEEE Institute of Electrical and Electronics Engineers, a standards body.

IoT Internet of Things, the connection of stand-alone nodes, systems, and devices to the internet.

IP Internet Protocol, the standard for data communications over the internet.

IT Information technology.

ITUInternational Telecommunications Union – the technology standardization and coordination arm of the United Nations.

Lattice TowerA type of communications tower constructed from a lattice of metal sections – can be either guyed (GT) or self-supporting (SST).

Lit Fiber Fiber optic cabling operated by a company that sells capacity on that fiber to multiple users.

LPWALow Power Wide Area, An Internet of Things communications technology that uses low power, low data rate communications for devices.

LTE Long Term Evolution, the name for a 4G-compliant radio standard published by 3GPP.

LTE-A LTE Advanced, a higher performance version of LTE.

LTE-LAA LTE-License Assisted Access, a 3GPP-compliant LTE-U technology.

LTE-U LTE-Unlicensed, a technology to carry LTE waveforms over the 5 GHz unlicensed spectrum bands.

Macro Site or Tower A large tower (either guyed or freestanding) which supports communications equipment and antennas.

Mbps Megabits, 1x106 bits per second.

MBps Megabytes, 1x106 bytes per second.

MHz Megahertz, 1x106 hertz.

Millennials The age group of individuals born between 1981 and 1996.

MIMO Massive Multi-Input Multi-Output, an antenna architecture used to focus RF energy towards a receiver.

MMTC Massive Machine-Type Communications, a 5G use profile.

Mobile Economy The exchange of goods and services delivered to consumers by smartphone apps.

Monopole A type of freestanding wireless tower.

MSO Multiple System Operator, an operator of multiple cable or direct-broadcast satellite television systems.

mW Milliwatt, one thousandth of a watt.

NFV Network Functional Virtualization.

NGHNext Generation Hotspot, a standard that allows Wi-Fi devices to use foreign networks without requiring a manual log in process.

NIHNational Institutes of Health, the primary agency of the United States government responsible for biomedical and public health research, an agency of the U.S. Department of Health and Human Services.

NTP National Toxicology Program, a project within the NIH.


Term Definition

NR New Radio, the name for a 5G-compliant radio standard published by 3GPP.

OffloadA network enhancement technique where parallel networks handle requests for large amounts of data (such as streaming video) – usually through a LTE-U, LAA, or Wi-Fi node.

OnGo The trademarked name for CBRS, governed by the CBRS Alliance.

PAL Priority Access License, a CBRS user tier.

PCS Personal Communications Service, an FCC regulation created for early digital telephony and data services.

PWC Price Waterhouse Coopers, a consulting firm.

RF Radio Frequency.

RoamingThe automatic sharing of networks, used to provide subscribers with a larger number of available sites without requiring user intervention.

SAS Spectrum Access System, a system that governs channel access and priority in CBRS.

SDN Software Defined Networking.

Sharing EconomyRide-sharing from individual contractors (as an alternative to taxi or livery services), Home-sharing from private citizens (as an alternative to hotels or motels), and other models – these are managed and enabled by smartphone apps and mobile networks.

Shot ClockThe period defined by regulation during which a local government or public agency must respond to an application for wireless facilities in the public rights of way.

Small CellA type of communications equipment that operates at lower power levels than a macro site. Small Cells typically cover areas from a single room up to several hundred meters in radius. They are attached to other structures such as building roof perimeters, streetlights, and utility poles.

Spectrum The range of RF frequencies used by a wireless system.

TSN Time Sensitive Networking, a 5G use profile.

uRLLC Ultra-Reliable Low-Latency Communications, a 5G use profile.

VoLTE Voice over LTE.

VoWiFi Voice over Wi-Fi (sometimes referred to as “Wi-Fi calling”).

Watt A measure of power, used to define RF power levels.

WHO World Health Organization, an agency of the United Nations.

Wi-Fi Wireless Fidelity, a trademark name for the IEEE 802.11 data communications standard.

Wi-Fi FirstA type of wireless subscription model where the subscriber equipment prefers to use Wi-Fi calling (VoWiFi) for voice connections. If Wi-Fi is not available, a cellular carrier via a roaming agreement handles the voice call.

WiMAX The trademark name for the IEEE 802.16 family of standards for data communications.

Wireless Telecommunications of voice or data using RF methods.

Glossary of Terms (Continued)


Works CitedBroadband Properties. (2019, July) https://www.bbcmag.com/technology/microtrenching-goes-mainstream

Centers for Disease Control. (2018, December) https://www.cdc.gov/nchs/nhis/releases.htm#wireless

CETF. (2016, July) https://www.tellusventure.com/downloads/cetf/cetf_annual_survey_2016.pdf

CTIA, Ex-parte filing to FCC. (2009, September) https://ecfsapi.fcc.gov/file/7020039747.pdf

Congressional Research Service. (2014, March) https://www.fas.org/sgp/crs/misc/R43256.pdf

CPUC R14-05-001. (2016, August) https://apps.cpuc.ca.gov/apex/f?p=401:56:0::NO:RP,57,RIR:P5_PROCEEDING_SELECT:R1405001

Ericsson AB. (2019) https://www.ericsson.com/en/mobility-report/reports/june-2019

FCC 19-126 (2019) https://docs.fcc.gov/public/attachments/FCC-19-126A1.pdf

FCC 600 MHz Auction Dashboard. (2016) https://fcc.gov/auction/1000

FCC AWS-3 Auction Results. (2015) https://apps.fcc.gov/edocs_public/attachmatch/DA-15-131A1.pdf

FCC – New National Wireless Tower Siting Policies. (1996, April) http://wireless.fcc.gov/fact1.pdf

FCC – Small Cell Order. (2018) https://www.fcc.gov/document/fcc-facilitates-wireless-infrastructure-deployment-5g

Federal Office for Radiation Protection – Bundesamt für Strahlenschutz, (2011)Danish Cohort Study on Mobile Phone Use and Cancer https://www.bfs.de/EN/topics/emf/mobile-communication/research-report/danish-cohort/danish-cohort.html

GCTC Public Wi-Fi Blueprint (2017) Wireless Supercluster, Global City Teams Challenge @ NIST https://pages.nist.gov/GCTC/uploads/blueprints/20170823-GCTC-PWSC-Public-WIFI-Blueprint-FINAL-v2.pdf

GSMA. (2019) https://www.gsma.com/r/mobileeconomy/

ICNIRP, Health Physics Society, (2019) Critical Evaluation of Two Radiofrequency Electromagnetic Field Animal Carcinogenicity Studies https://www.icnirp.org/cms/upload/publications/ICNIRPnote2019.pdf


IHS Markit. (2016, July) IoT Devices - Installed Base & Device Shipments. (IHS Disclaimer: Results are not an endorsement of Joint Venture Silicon Valley. Any reliance on these results is at the third party’s own risk. Visit www.technology.ihs.com for more details.)

International Telecommunications Union. (2011) About mobile technology and IMT-2000. https://www.itu.int/osg/spu/imt-2000/technology.html

International Telecommunications Union. (2019) Minimum requirements related to technical performance for IMT-2020 radio interface(s). https://www.itu.int/pub/R-REP-M.2410-2017

Joint Venture Silicon Valley. (2012) Wireless Facilities Impact on Property Values http://bit.ly/cellsiteMLSstudy

Maravedis & Wi-Fi 360, via the Wireless Broadband Alliance. (2016) http://worldwifiday.com/wp-content/uploads/2016/06/Research-%E2%80%9CMapping-the-Urban-Unconnected%E2%80%9D.pdf

Mobile Experts LLC. (2019, April) https://www.mobile-experts.net/Home/Report/1139

National Cancer Institute. (2019) Cell Phones and Cancer Risk http://bit.ly/2lORsfc

NTIA – McHenry, G. (2016, April) Evolving Technologies Change the Nature of Internet Use. https://www.ntia.doc.gov/blog/2016/evolving-technologies-change-nature-internet-use

Pew Research Center. (2019) Mobile Technology and Home Broadband 2019 https://www.pewinternet.org/2019/06/13/mobile-technology-and-home-broadband-2019/

PWC Strategy. (2018) https://www.strategyand.pwc.com/gx/en/insights/grasping-differentiated-straw.html

Simon, Linda (2005) Dark Light: Electricity and Anxiety from the Telegraph to the X-ray Paperback Edition (via Amazon): https://amzn.to/2VISzQg

Small Cell Forum. (2019) http://www.smallcellforum.org/about/about-small-cells/small-cell-definition/

T-Mobile West LLC v. City & County of San Francisco (2019) Decision of the California Supreme Court

https://law.justia.com/cases/california/supreme-court/2019/s238001.html

White House Council of Economic Advisors. (2016, March)

https://obamawhitehouse.archives.gov/sites/default/files/page/files/20160308_broadband_cea_issue_brief.pdf

Works Cited (Continued)


Notes

KEY POINTS GENERAL NOTES

SUMMARY

S I L I C O N V A L L E Y

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Bridging the Gap - Joint Venture Silicon Valley

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