How Many Cell Sites?

According to most sources including the CTIA's database, at the end of 2008 there were 242,130 cell sites in the United States. I am sure this number is representative of only full-blown sites and does not include picocells and in-building systems that are also in operation. And each year, network companies set a target number for new sites to expand coverage, fill in holes in coverage, and increase network capacity. Typically, not all of these sites are built in any given year because of the time it takes to locate a site, negotiate with a potential landlord, and then go through the architectural review and planning permit process.

It is easier to complete the permitting processes in some states, cities, and counties than in others. When the Ninth U.S. Circuit Court of Appeals gave more latitude to the cities and counties when it comes to cell site construction, placements, and aesthetics, some cities responded positively, as has Santa Barbara, where I live, which is developing a five-year plan to make the siting and permitting process simpler and faster. However, other cities such as our neighbor Goleta, rejoiced at the fact that its planning commission can make it more difficult for network operators to construct sites within its city and is in the process of writing a new, and to my mind, onerous, set of guidelines designed to limit the number of cell sites that will find their way into Goleta, even though parts of the city have little or no coverage and its citizens are asking for better wireless coverage.

I recently completed a report for the City of Santa Barbara in which I listed all of the existing wireless network operators, identified the spectrum on which they have licenses, identified spectrum that was turned back over to the FCC and could be re-auctioned, and then went on to identify the number of new network operators and/or new systems that could end up being built in the next five years.

The results for Santa Barbra, a city of 100,000, are as follows:

Existing 800-MHz operators:              2       AT&T and Verizon

Existing 850-MHz operators:              1       Nextel (Sprint/Nextel)

Licensed but not built:                       1       SLO Cellular

2500 MHz:                                        1      Clearwire

Total licensed but not built:                 1      SLO Cellular

This list is made up of commercial wireless networks and does not include the new public safety interoperability system in the planning stages, additional TV White Space systems that might require permitting, or any other unlicensed or licensed systems for public or private use.

And this is only the wireless landscape in Santa Barbara; we have DSL and cable, and the City and several vendors are working on plans to bring fiber to homes and businesses. All of this adds up to fierce competition, and it is my belief that by 2015 at the latest, the number of voice and broadband suppliers will have contracted due to market-driven economics.

But for now, based on this chart, it was easy for the City to understand that the demand for cell sites over the next five years will probably double or more. Today, this City does what most of the rest of the nation does: It waits until it receives a request for zoning for a new site and then begins the tedious and time-consuming process of approving or denying that one site based on a number of factors including public outcry, how it fits into the surrounding area, and other issues. After addressing that one site, it waits until the next network operator files for a permit for a new site and the process is repeated over and over again.

Some of the today's network operators have learned that it is best to file for permits for two, three, or even four sites at once. The applications are moved through the (slow) system in parallel, and the outcome is usually permits that are spaced only weeks apart. However, some have plans for more sites than they can get approved in a specific timeframe, so coverage fill-in and capacity issues are slow to be resolved. New operators coming in will have to spend a lot of time and money finding new sites or co-locating on existing sites. The bottom line is that if the process is not streamlined, the City's planning staff will be overwhelmed with permit requests, hearings for each application will have to be scheduled so the public has its say, and then the architectural review board will have to make its rulings. Only then can a new site be built.

Unlike Goleta, Santa Barbara would like to streamline this procedure and make the process easier for both the planning department and the wireless network operator. The City understands that it needs to balance protection of the community's aesthetics with the demand for wireless services for businesses and its citizens. The City is also interested in gaining income in these tough economic times by offering up City-owned sites to network operators where appropriate. Goleta, on the other, has chosen to use the court ruling as a way to give city planners more clout, and more ways in which to hinder the development of wireless services within its community.

Based on the above, my recommendations to the City of Santa Barbara are below in italics, and I have added some further explanations for this Commentary.

 Recommendations to the City of Santa Barbara Regarding Cell Site Placement and Permitting

1. The City should develop a five-year master plan for the placement of wireless sites within the City. It should be understood that this plan will provide a guideline and not a cast-in-concrete roadmap. Wireless technology is changing at a rapid pace and demand for services may require some adjustments to the plan over time. Further, market conditions can change. For example, today Sprint is struggling to regain its footing and is facing some financial issues, but when it recovers or is bought, requirements for new build-outs will increase.

2. The City or its agents should hold a meeting with each network operator (including new operators in the planning stages of their networks) and ask them to provide their best estimate of their requirements over the next five years, realizing that these requirements will serve as a guideline for the City plan and that there will be some changes in these requirements over time due to customer demand, the inability for a network operator to obtain a specific site, and advances in technology.

Most of the network operators I talked with while preparing this document agreed that they could work with this type of pre-planning, as long as the City understood that it also must be flexible as times and marketing conditions change. The City would indicate that these planning sessions were non-binding on the network operators but would serve only as a guideline moving forward.

3. During this process, the City should also identify all City-owned property and predetermine which locations would permit the construction of a cell site or a multi-network site and provide the network operators with an incentive in processing time for choosing a City-owned property.

The City, as are all cities, is looking for any additional revenue it can find and offering incentives to network operators to look first at City-owned property makes sense. In the case of Santa Barbara, its main communications site already houses a major AT&T site, and two other operators have asked to be able to co-locate on the site.

4. During this phase of the planning process, each network operator should be encouraged to include as much co-location with existing sites as possible (San Luis Obispo already requires this). The incentive for co-location should be a faster process for approval, for example, making it an administrative approval rather than a full CUP (Conditional Use Permit).

Here again, this would reduce the time of the entire process for the network operators and would save the City's staff hours of work and numerous meetings.

5. This condition should also be included in the development of any new sites. For example, permitting more antennas than have been requested so that co-location requests can be handled on an expedited basis.

6. The Planning Commission should develop a set of guidelines for its staff about what is acceptable so that in most cases the planning staff could easily make a decision about what they can support. Too often, I have found in other cities that the planning staff takes such a conservative approach that unreasonable concessions are required of the network operator but that such concessions offer no real benefit to the project. Network operators would welcome some guidelines within which to work in order to be able to present to the staff plans they can support that could then be expedited.

There are a number of other recommendations I could make and enhancements of the ones listed above. However, this would be a good starting point. All of the network operators want to come to the City with plans that can be approved. It does not make sense for each new application to take two to three years to be approved. As an example, the Verizon/Nextel site at Elings Park took more than three years from conception to approval and then another six months for construction and to put the site into operation. This site provided both Verizon and Nextel coverage to more than 200 homes and Hendry's Beach, which had never had coverage from either of these networks.

Pre-planning and working with existing and new network operators makes sense for the City and it would cut down the time it takes for network operators to obtain permits and, therefore, provide better service to their customers in a more timely fashion. The end result will be a more controlled growth of cell sites, increased revenue to the City, and better wireless services for the citizens of Santa Barbara.

There was a lot more detail in my report, but this is the basis of the cell site recommendations. While the City has yet to enact all of these recommendations and others that are in discussion, its attitude is positive and it is moving forward in this direction. I am sure that some of the network operators will find things that don't please them in my recommendations, but I believe that the outcome here and hopefully in other cities and counties will be a shortened permit cycle, faster acceptance of new locations, reduced costs to network operators, and, of course, if the city or county is interested, a source of revenue that will be collected month after month and year after year.

The placement of cell sites, or the expansion of existing cell sites to permit co-location, should not create an adversarial relationship between governments and wireless network operators. Network operators that question the viability of a five-year plan and want to continue plodding along one permit at a time should be able to do that. However, they may end up in a position where their competitors are out-building them and providing coverage and services more quickly for less cost per site. Citing should be a win-win-win for the network operators, the city or county, and oh yes, for wireless services consumers-you know, the folks who vote the mayors and council members into and out of office.

Andrew M. Seybold