A reporter called me to ask about distributed antenna systems (DAS). I told him that was not the right first question to ask. Why? Explanation in a moment. His community is hearing its third wireless facility permit application that includes a new tower. This community is part of a national gem, having a majority of its land mass designated a National Park. Naturally, wireless service providers gravitate toward the developed areas where people live, work and play. This is where the privately and municipally owned land is. Rather than try to penetrate the National Park land to site a new tower, it is often most practical to work with the private and municipal land owners where the human activity is concentrated. Residents see a pattern developing and are concerned that the pristine beauty of the area is being steadily eroded with the addition of each new tower.
As often happens in the public permitting process, concerned residents look for what they consider to be a better way to facilitate the provision of personal wireless services. The idea of DAS is very enticing to people who would prefer not to live with towers. Antennas on utility poles. Low power levels. What’s not to like? This begets the question, why can’t we have a DAS in our community? Usually I get a call from a representative of the permitting Board, or a concerned resident. In this case, the local paper was working on a feature story to examine the issues.
Now we are back to the starting point, “Mr. Maxson, what’s keeping DAS from being put in this community?” I thought, should I give him the radio frequency engineer’s answer (“it depends”), or the facilitator’s answer (is this the right first question to ask?)? Since the caller was a reporter, I certainly did not want to start with the pros and cons of DAS when the context of the problem had to be explored first.
So I explained to the reporter that rather than jumping to a conclusion (“we need DAS”), the problem has to be identified in the public process, and the range of potential solutions considered. Certainly the applicants (a tower company and a wireless carrier) have considered ways to find the most “zonable” solution. A tower company, of course, has an interest in building a new asset – the tower – and may be less interested in potential solutions involving existing structures. Nevertheless, the wireless carrier is the driver, and seeks a balance between time to market, development cost, and ability to satisfy the coverage objectives. If local regulations point the carrier to an obvious solution without a new tower, the carrier would almost certainly embrace it. The word “almost” is key here.
The role of the public permitting process is to look over the applicant’s shoulder and validate the proposal against the duly adopted requirements under local ordinances. What is the coverage objective? How much of it, if any, rises to the level of a significant gap in service under the federal law? Is the proposal in keeping with local goals and regulation? To what degree is it not? Height? Visual impacts? Design? Locations affected by its proposed presence?
Once a baseline on the proposal is established by gathering information to answer these questions, the question of alternatives finally comes up. Local regulators should perform due diligence on alternatives anyway, because in addition to analyzing the nature and extent of the gap, evaluating the prospect of alternatives is an element of the permitting board’s responsibility under the ’96 Telecom Act.
Are there other ways to address the coverage objective or the gap? Would they work well enough? Which ones are more consistent with the purpose and intent of local regulations?
Finally, actual options can be put on the table: Upgrades to existing facilities to reduce the extent of the gap? Other sites for new facilities without a new tower? Other sites for a new tower? Other locations on the proposed site? Reduced height? Improve design with suitable camouflage or “stealth” decoy?
These alternatives can be explored in the context of the coverage objective or gap. A single site alternative is not necessary. Are there two sites that collectively have less impact on the community (or are more ordinance-consistent) that could address the coverage objective?
- Hide antennas in steeples in the center of town, reducing the extent of the gap, and allow a new tower more distant from the center of activity to take up the slack (Proposed tower ¼ mile from historic town center denied in Grafton, MA for this reason). A tower a mile away was later approved and some carriers are using a church steeple.
- Find an alternative site that does essentially the same job for coverage with significantly less impact on the ordinance and the community. (Proposed tower in Duxbury, MA was deemed too out in the open and affecting too many residents; applicant and board worked out an alternative at another more wooded and residentially remote site.)
- Double up on sites to increase overall coverage and eliminate undesirable visual impact. (Proposed tower on prominent ridge at gateway to the town of Ashland, NH was denied; alternative was one tower in the river basin illuminating much of the same territory, and a second tower in the trees on a hillside a mile or so up the interstate to make up the rest of the coverage and add more.)
- Now we are at the DAS question! Would interconnecting a series of utility-pole-mounted antenna nodes provide substantial coverage to the gap? Where would it not reach? Is that unreached area material to the overall gap? Would a combination of DAS and strategically placed smaller macro sites achieve the objective in a manner more in keeping with local zoning objectives? ( 1) Wellesley, MA has substantial coverage from towers and buildings; it also has a half-dozen microcells on its utility pole infrastructure where towers don’t reach. It is getting to the point that future installations will be of the DAS flavor rather than microcells. 2) Lower Merion, PA residents sought to avoid a tall tower proposed on a ¼ acre lot at an intersection in the midst of a main line residential area; eight microcells already dotted the area; DAS was developed. 3) According to public record, the well-protected scenic island of Nantucket could have needed eight towers to cover the areas of human activity; a forward-thinking wireless carrier and a DAS company developed a DAS solution, beginning in 2003.)
In sum, while DAS architecture is one of the tools in the box, it is not a panacea. Residents often want to leave no stone unturned before approving a proposed facility. The public process should include due diligence, to the extent the regulating Board finds it appropriate, on any potential alternative. Just as toothbrushing is one activity in an overall plan of oral hygiene, evaluating DAS as a potential alternative to a proposed wireless facility is but one part of an overall, systematic process of evaluating a wireless facility permit application.
Mr. Reporter, thanks for calling. Maybe you can summarize our conversation in a few pithy quotes. Good luck!