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Cellular Industry:
Time to Take Ownership of Part of the Wireless Infrastructure Poblem

We have met
Cellular infrastructure is an issue of growing concern in the industry and in Washington. It is also the subject of a draft NPRM/NOI that will be considered at FCC's April 20th meeting. The Commission summarizes the draft as:

The Commission will consider a Notice of Proposed Rulemaking and Notice of Inquiry that commences an examination of the regulatory impediments to wireless network infrastructure investment and deployment, and how the Commission may remove or reduce such impediments consistent with the law and the public interest. (WT Docket 17-79; WT Docket 15-180)


Delays in infrastructure are a major issue in spectrum policy because in reality MOST growth of wireless capacity comes from new infrastructure; the contributions of new technology and new spectrum are minor by comparison - even though both are also needed. But the FCC draft never addresses a basic issue: Why are local government slow in approving new wireless infrastructure?

Let me posit two basic reasons:

  • Wireless infrastructure is often needlessly ugly and often designed with little regard for the environment around it.
  • Lack of confidence in FCC's RF safety policies and resulting safety fears.

pizza box antenna
While the first generation of large base station were often ugly, the concern here is not the large base stations that are getting less common with network densification, today most new construction will the smaller ones at lower heights that are getting more ubiquitous. CTIA has promised a"pizza box" design shown at right. This is a modest size, but it is unlikely that this design will cover all existed cellular bands or even the new incentive auction bands due to its small size compared to the wavelength of these bands. More importantly, the ugliness of today's cellular installations in usually not due to the radiating elements such as the "pizza doc" but rather to the hodgepodge of brackets and tilting elements supporting it and mess of (usually) black cables running in vary directions connecting antenna elements to electronics.

I
scenic byway
have explored these issues in more depth in an filing on the draft NPRM and will summarize the points below. A key issue can be seen in the photo at left taken recently. It shows a small base station with a quite attractive wooden barrel-like antenna (not shown here) at the top of this wooden utility pole next to a labelled "scenic byway". But near eye level is this mess of equipment boxes of various colors connected to each other with a maze of "black spaghetti". Would it be expensive to paint the boxes a uniform color and tidy up the cabling with cable or a cover? Probably not. But someone would have to care! That type of thinking about equipment appearances seems rare in the cellular industry today which wants to through around its political power and show industry members how powerful they are.

Should the industry have a public strategy on the aesthetics of new 5G infrastructure other than vague talk about "pizza boxes" and pictures of them held by a spokesman, not in actual installations? The proposed Mexican border wall will be generally in remote rural locations but the
presolicitation published by DHS clearly states:

"Detailed requirements will be included in the RFP, but for planning we anticipate procuring concrete wall structures, nominally 30 feet tall, that will meet requirements for aesthetics, anti-climbing, and resistance to tampering or damage." (Emphasis added)



While the federal government shouldn't determine aesthetics goals for 5G, shouldn't the industry at least have publicly stated goal for this new ubiquitous addition to our urban design?
Should the public be able to see how well the industry is meeting the goal it sets?

My FCC filing does
not oppose any aspect of the draft NPRM the FCC will vote on soon. It does point out that without attention to the two likely root causes of the local government delays this proceeding, like many other before it, will fail to meet its goals.

Tip on politics
There are few current FCC employees now who worked there during the Ferris chairmanship. (I assume that Amb. Verveer is the only one there now who interacted regularly with Chmn. Ferris — since he was a bureau chief at the time.) Chmn. Ferris was a protege of "Tip" O'Neill, well known for the phrase that is also the title of his autobiography:

"All politics is local".

Placing ugly infrastructure on every block in America and preempting local jurisdiction in order to do this could be a good test of whether Tip's famous phrase is still true. Will it result in a major grassroots backlash if implemented as currently structured? Time will tell! Wouldn't it be better (and even more Republican) to defuse part of the problem with non regulatory approaches?

But wouldn't a better approach include voluntary action from the cellular industry with FCC encouragement to pay more attention to the physical design of its infrastructure and its compatibility with its neighbors? While in a few cases there may a need for very expensive custom designs, more attention to design basics like covering or grouping caring and use of paint to minimize the visual impact of equipment will not be major cost factors. However it will need management attention.

As mentioned at the beginning, RF safety concerns are also a factor in local resistance to wireless infrastructure. While I don't think these concerns are valid, the fact that the basic FCC RF safety rules are decades old and that the most recent rulemaking on the topic, Dockets
03-137 and 13-84, have been stalled for years shows apparent FCC apathy on the topic. FCC's partner with shared jurisdiction on RF safety is EPA and the pending severe budget cuts at that agency will make it even more difficult to update RF safety rules to keep them credible. FCC worked closely with the cellular industry to move the Spectrum Frontiers/5G docket at record pace. Both should realize that updated and credible RF safety rules are important to maintaining public confidence in wireless infrastructure - especially as it starts reaching even block in America!

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