Wireless Building Permits – A Cautionary Tale

One of the great existential conundrums is “How do you know what you know?”  I recently have seen a series of unrelated building permit applications for new or modified wireless facilities that were missing key information and the presenters firmly believed in the diligence of their submissions.  One thing these applications had in common (and not all applications are like this) was that the structural analysis was incomplete.

I read one application with a beautiful analysis of the integrity of the proposed camouflaged antenna mount.  It would hold together in the worst of hurricanes.  A note among many notes said that the analysis did not include analysis of the roof structure to which it would be attached because invasive techniques would be required to do so.  That means someone would have to cut open the flat roof and inspect the underlying joist work and wall connections.  Then a design would have to be created to ensure that the beautifully designed structure would not tear the roof off in the same hurricane. Yet the applicant’s agent and its attorney each firmly believed that all the necessary due diligence had been done and presented in the application.

In another case, a similar claim was made for attaching upgraded equipment to a water tank.  The mount was calculated and the notes indicated the tank was assumed to be in good shape and the existing studs welded to the tank were assumed to be up to the task.  The Professional Engineer stamped a letter certifying this.  Maybe if it is well-known that the tank and bolts are indeed within specification based on recent analysis or recent installation under construction control it might be OK to gloss over how the entire system will work. Not so here.

In this case, the error was compounded by the fact that two years ago, a modification that occurred did not look anything like what was proposed, and included a newly welded mount that had not received the tank owner’s approval or that of the Building Official.  Moreover, the existing mounts had missing studs, which the PE two years ago said should be repaired.  They never were.  So the new PE certification is based on a series of assumptions that a simple visual inspection would have contradicted.

This led to the “How do you know what you know?” question.  An eager project agent assured me that everything in the past had been done by the book, and not to worry.  Nothing would have gone on that water tank without proper structural analysis, owner approval and Building Official approval.  When I asked “How do you know?”  He got a bit testy and sputtered that his employer and the town would never have it any other way.  Digging into the history and making a site visit, I found he did not really know that which he firmly believed.

Then in another case, an applicant proposes to replace a one-foot wide flimsy guyed radio tower with one some seven feet wide, including new foundation and guy anchors.  The only structural analysis was in the form of a “typical” drawing of the new antenna mounts and a note that the tower design was yet to be determined, all with a PE stamp on the drawings.  Building officials are responsible for deciding whether a licensed contractor or a licensed engineer should be controlling construction and signing off.  They usually look for evidence the structural design and foundation design have been produced and signed for in advance of construction.  Construction control is the final step in ensuring the result will be structurally to code.  None of this was imposed by the Building Official.  The tail was wagging the dog on this one.  The antenna and mount would be just fine; never mind that there is a non-existent tower and foundation that will magically appear to hold them up.

In all three cases, the Building Official was unaware there was missing information.  A quick read of the documents would lead one to believe all was in order.  The one question Building Officials can ask when reviewing wireless building permit applications is in two parts: “Is this project going to be code compliant end-to-end when it is done, and how will we know?”

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