Wireless Facilities Siting

Independent, Expert Technical and Business Advice

Since the advent of the cellular industry, CTC has provided expert advisory services on the technical, strategic, and business aspects of wireless facilities siting. Our clients are local governments, state agencies, public utilities, and nonprofits. CTC is independent of the industry, and not affiliated with equipment manufacturers, cable operators, wireless providers, or tower companies.

Every year, small cell wireless siting applications inundate state and local authorities as the wireless industry densifies existing networks, prepares for 5G, and upgrades public safety networks. CTC provides expert, independent guidance and staffing for public agencies seeking to protect their assets and the public interest while facilitating deployment of new services.

Since 1983, CTC’s wireless team has helped public agencies and utilities vet applications for thousands of towers, colocations, small cells, and distributed antenna system deployments. Our expertise includes:

  • Developing best practices in wireless siting to enable efficient deployment while protecting community interests
  • Defining technical standards for wireless facilities that protect public assets and public safety
  • Addressing technical challenges in siting, including ADA violations, radio frequency (RF) interference, and unsightly deployment
  • Developing strategies to comply with state, federal, and local requirements and zoning considerations
  • Vetting applications for zoning compliance, RF coverage, interference, and colocation opportunities
  • Developing local processes and standards to enable deployment while protecting public interests and property

Evaluating and vetting wireless facility siting applications

Our engineers analyze siting applications and RF studies to evaluate the accuracy of applicant-claimed technical service objectives, the extent to which proposed wireless sites are necessary to fill gaps in coverage or capacity, and the significance of such gaps. Analysis typically includes:

  • Vetting an applicant’s application, including RF propagation studies or drive tests
  • Identifying colocation options in the vicinity of a proposed site
  • Considering options to minimize the visual or other community impact of a wireless facility, such as painting antennas to match a mounting location, requiring a stealth monopole design, or requiring that equipment meets local noise ordinances
  • Visiting and reviewing sites to evaluate community impact
  • Reviewing applications and requesting additional information as necessary
  • Evaluating relevant reports, studies, public input, and other materials
  • Presenting findings to planning departments, counsel, and elected bodies
  • Preparing reports, maps, charts, documentation, or presentations to document findings and recommendations

We coordinate the wireless facility siting application and review processes for Montgomery and Prince George’s counties in Maryland; Fauquier and Louisa counties in Virginia; and a dozen local governments in California, including the cities of Palo Alto, Sonoma, Arcadia, Fremont, Hillsborough, Monterey, Napa, Piedmont, Rancho Palos Verdes, Rolling Hills, and Palos Verdes Estates.

Developing technical and safety standards

Our engineers develop and help enforce technical standards to protect the public interest, public safety, public assets, and utility worker safety, including through:

  • Assessing whether proposed attachments increase congestion on a sidewalk or block motorists’ views of traffic
  • Ensuring that proposed installations meet ADA requirements and DOT rules that allocate right-of-way space for varying uses
  • Verifying adherence with pole spacing requirements and—in the case of new tall towers—standards for soil and drainage
  • Confirming clearances between new equipment and roads and buildings, and proper placement of power meters and shutoff devices
  • Verifying compliance with FCC rules on RF emissions and related warning signage
  • Testing RF signals to ensure non-interference with public safety, city, and utility wireless operations

We have developed technical standards for small cell siting in the rights-of-way on behalf of clients that own utility poles, including CPS Energy (San Antonio, Texas), Huntsville (Alabama) Utilities, the City of Opelika, Alabama, and a half-dozen municipal light plants in Massachusetts.

Developing processes to comply with new preemptive laws

In light of the FCC’s wireless preemption Order limiting local agency authority in wireless siting and asset use, CTC’s analysts develop strategies for technical compliance that address policymakers’ desire for new deployment while protecting public assets, interests, and mission-critical public infrastructure.

For example, in response to the FCC’s establishment of fees for small cell applications, CTC’s engineers performed a cost analysis of the City of Baltimore’s small cell and distributed antenna system (DAS) application and review process. By documenting the various elements of the process, we established an accounting of actual costs that the City can use to justify the higher fees it charges applicants.

We have also developed technical and aesthetic standards that our local government clients can apply to wireless facility sitings in light of the FCC’s new limitations. In 2019 we developed such standards for several municipal utilities in Massachusetts. Our work builds on our extensive experience in this area; for many years we have advised a dozen California cities (including Palo Alto and Sonoma) on standards that minimize the visual impact of wireless facilities while improving mobile coverage.

Developing wireless engineering plans and strategy

Our engineers and analysts advise public agencies across a range of tasks related to wireless facilities siting and planning. A few illustrative examples:

For the Texas Department of Transportation (TxDOT), we developed a full strategic plan and guidance for wireless siting requirements, developing technical standards, establishing processes, and recommending appropriate fees—all intended to protect state interests while enabling efficient private use of TxDOT assets.

For Montgomery County, Maryland, we developed a comprehensive wireless siting process, which the National Association of Counties recognized as exemplary and the FCC’s Intergovernmental Advisory Committee recognized as providing notable best practices.

For the City of San Francisco, we evaluated the potential design and cost of 5G fixed and mobile deployment, including adequate fiber backhaul and use of street furniture.

Ensuring coordinated, efficient processes among cities and utilities

We develop processes and standards that align public interests among agencies and among city governments and public utilities. For example, in Huntsville, Alabama, CTC helped the utility and city develop and harmonize complete processes for managing pole attachments so that existing assets could be maximized, and so that wireless carriers would not install new poles just feet away from existing utility poles.

Developing business and revenue strategy

We develop strategy to enable public utilities and localities to maximize public assets to enable wireless service, to deploy new pole and fiber assets as necessary, to lease dark fiber for backhaul, and to realize associated revenues.

Designing infrastructure and business plans for neutral-host infrastructure and Wi-Fi

We also design neutral-host infrastructure and business plans for localities and utilities seeking opportunities to support wireless carriers and expand wireless broadband.

For example, our engineers designed a neutral-host DAS to enable Washington, D.C., to use its fiber network to distribute wireless signals, including within buildings where poor coverage led to public safety challenges. We also developed a program for installing commercial, public safety, and Wi‐Fi wireless DAS networks.

We currently provide strategic and technical guidance to the City of San Antonio’s Aviation Department on the design of a neutral-host DAS and Wi‐Fi implementation in the San Antonio International Airport.

Developing Smart City strategies that benefit from cellular expansion and densification

As wireless carriers densify 4G networks with small cells, there is opportunity for agencies to leverage new infrastructure for public purposes, such as installing public safety cameras, other kinds of sensors, and traffic controls.

In Baltimore, our engineers developed small cell policies and standards that align with Smart City goals. Our analysts developed a public-private partnership strategy for Seattle for deployment of wireless infrastructure and services. In Boulder, Colorado, and Newark, Delaware, we developed wireless plans that leverage public fiber and provide a platform for Smart City and other public applications.

Augmenting technical and administrative staff during application bursts

Not all jurisdictions have the capacity to manage the wireless applications they receive, especially when bursts of applications appear or when the applications involve structures like light poles in addition to utility poles.

CTC’s wireless engineers and analysts have provided staff augmentation services to vet and process thousands of siting applications for towers and antennas. We provide this on-call support to agencies as large as the Northern Virginia Regional Parks Authority and to small communities nationally. Our clients include numerous jurisdictions in the New York, Washington, D.C., and Los Angeles metro areas—as well as rural localities in Tennessee, Michigan, Maryland, Virginia, and Washington.

We have worked with applications from AT&T, American Tower, Clearwire, Cricket, ExteNet, Mobilitie, Sprint, T‐Mobile, Verizon Wireless, and many others.

Advising on public safety wireless and FirstNet

As FirstNet is rolled out, states and localities face challenges related to vetting the adequacy of the service and developing business strategies for public safety broadband, including the degree to which FirstNet can serve public safety needs and potential migration plans.

CTC advises public entities regarding the full range of technical, business, and financial areas of interest in FirstNet. For Delaware, we developed an independent baseline assessment of AT&T and Verizon network performance, and now monitor improvements over time. In suburban New York, we developed a plan for public safety wireless network development and operations. For Kansas DOT, we evaluated a public-private partnership strategy for land mobile radio and wireless broadband.

Recognized expertise

Our engineers are recognized for their national expertise and decades of experience. We have prepared expert filings for the Smart Communities Siting Coalition before the FCC that document the importance of local review processes in the face of efforts to preempt local authority. The analysis demonstrates the value of efficient, mutually beneficial planning.

We have also prepared guidance documents for local governments that provide comprehensive roadmaps for how localities can protect local interests while enabling expansion of mobile service.

The CTC wireless team

Andrew Afflerbach, Ph.D., P.E., CEO & Chief Technology Officer: Andrew has designed wireless networks for large cities, counties, and regions. Andrew advises local government clients on technical issues related to wireless facility siting in the public rights-of-way. He has written extensively on local governments’ strategic options for addressing the FCC’s wireless preemption Order, and has submitted technical analyses to the Federal Communications Commission on issues related to small cell deployment, and the proposed T-Mobile/Sprint merger. He recently testified before the Maryland House of Delegates’ Economic Matters Committee on pending legislation that would preempt local authority in small cell siting matters.

Andrew leads the CTC team advising Texas DOT on wireless facilities standards and processes. He conceived and developed the super-regional interoperable fiber optic network in the National Capital Region. He leads the technical team conducting FirstNet planning for the District of Columbia and the state of Delaware. Andrew serves as the NATOA representative to SAFECOM and is a licensed Professional Engineer.

Joanne Hovis, Esq., President: Joanne has testified before Congress on the importance of local input in wireless siting in the face of efforts at preemption. She directs the firm’s work in network business planning, market analysis, financial modeling, policy, and strategy. Joanne advises public entities regarding wireless and wired broadband strategy and public–private partnerships.

Lee Afflerbach, P.E., Principal Engineer: Lee is a nationally recognized authority on wireless and cable infrastructure and a licensed Professional Engineer. He has designed, tested, and planned dozens of citywide and state-wide wireless and fiber optic networks for government, public safety, education, and non-profit entities.

Lee oversees the team of CTC engineers who review wireless antenna siting applications and provide technical guidance on small cell deployment options and RF matters for West Coast cities including Arcadia, Burlingame, Fremont, Hillsborough, Monterey, Napa, Palo Alto, Palos Verdes Estates, Piedmont, Rancho Palos Verdes, and Sonoma, California.

These engagements include performing technical reviews of applications, conducting field signal verification measurements, calculating RF emissions for planned installations, negotiating technical issues with carriers, and providing expert witness testimony in legal proceedings as requested.

Shawn Thompson, Principal Engineer: Shawn is a recognized expert in wireless engineering, radio propagation, and issues related to wireless siting in the public rights-of-way and on private property. He manages the CTC teams that provide ongoing wireless facility application review services to Montgomery and Prince George’s counites in Maryland, and Fauquier and Louisa counties in Virginia. He is also supporting the State of Texas Department of Transportation (TxDOT) on strategic planning and the development of standards for its wireless facility siting program. Shawn’s expertise includes strategic approaches that local governments can take to address the FCC’s preemption Order.

Shawn has developed pole attachment policies for electric utilities seeking to support wireless deployment, and has developed assessments and strategies for wireless coverage on college campuses. Prior to joining CTC, he oversaw the design and implementation of more than 1,000 DAS networks nationwide; advised wireless carriers such as Sprint, Verizon, and AT&T in solving their indoor and outdoor coverage and capacity needs; and co-founded and led In-Building-Wireless, a pioneer in DAS networks.

Client Experience

In recent years, we have reviewed applications to construct wireless facilities for Baltimore and Carroll counties in Maryland; Blount County, Tennessee; and the cities of Rolling Hills, California, Scarsdale, New York, and Huntsville, Alabama. As needed, we provide expert testimony at public meetings and in negotiations with wireless carriers and tower companies.

Arlington County, VA

As a result of the passage of Virginia Senate Bill 1282, the County faces new rules concerning wireless siting. To address those new requirements, CTC assisted the County in developing a new streamlined wireless facility application for small cell and microcell attachments. Based on our experience, we drafted an application that requires applicants to demonstrate that the installation conforms to the definition of a small cell or microcell; provide proof of the applicant’s permission to utilize the structure that will be used; and submit engineering specifications and other details essential to the County’s proper evaluation of the application. The application balances the County’s need to improve wireless service for the public while also addressing citizen concerns.

Montgomery County, MD

CTC is the designated Coordinator for the Montgomery County, Maryland Telecommunications Facilities Coordinating Group (TFCG). The TFCG model, which we created for the County, has been highlighted nationally as an example of best practices in this field. We provide technical engineering support, coordinate and review telecommunication carrier applications to site transmission facilities in the County, conduct physical inspections of proposed siting locations, review applicants’ RF engineering submittals, and provide recommendations to the TFCG on each siting request based on zoning standards and other parameters. We also ensure that the County complies with the FCC’s “shot clock” for processing applications.