HomeMy WebLinkAboutPlan Wireless Newsletter Oct/Nov 2008You may not practice in San Diego, but if your jurisdiction grants Conditional Use Permits with expiration dates, this is about you
Vo1.13,No.6 PlanWireless October/November 2008
A Newsletter About Planning for Personal Wireless Service Facilities
ATC v. City of San Diego (Part Two) The City of San Diego's Premise
This article builds on
the December
2007/January 2008 issue
of PlanWireless where
the complicated lawsuit
by American Tower
Corporation (ATC)
against the City of San
Diego was described
One of the
advantages of reporting
on a lawsuit in limUo,
which this one is, lies in
time. PlanWireless
needed this time to go
to San Diego to visit the
sites involved. ATC v
City, of San Diego is
currently on hold.
ATC's Premise
ATC has made a
major investment in
what most people call
"towers." At least ten
of ATC's Conditional
Use Permits have
expired and no longer
meet the City's
- regulations. All ten of
ATC's towers now
exceed the City's height
limits, although they
did not exceed height
limits when originally
approved. ATC claims
in the lawsuit that they
have a vested right to
maintain their original structures and they refuse to
shorten their towers just because the City lowered its
height restrictions. ATC has sued on a variety of
claims, but the expired CUPS are the major issue.
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ATC's disputed tower at 2222 Verus St. shows only one
personal wireless service facility. The only thing ATC owns is
the monopole topped out at "A." The T-arms for 12 antennas
are empty at "B" and probably intended for Sprint, which never
installed its antennas. The antennas at "N" are for Nextel,
which is a different carrier than Sprint. (The company "Sprint-
Nextel" is not a carrier but a holding company for two separate
and distinct carriers.) If ATC cut its monopole at "C," the City
would give them a new CUP.
If height is so important to ATC why is the top of the
monopole empty? Is it because no carrier wants to be there?
The City finally has a
set of regulations it can
live with and ATC
doesn't meet them in at
least ten Conditional
Use Permit locations.
The City wants ATC to
bring the Wireless
Communication
-Facilities (WCPs) (th'afis
what the City calls
them) into compliance
with the City's new
regulations so the City
can give ATC new
Conditional Use
Permits. The first of the
Conditional Use Permits
expired in 2004 and all
of the towers are still up.
What PlanWireless
Believes This Case is
Really About
The
Telecommwiications Act
of 1996, which is
invoked by both sides in
this lawsuit, is about
"personal wireless
service facilities." It is
not about "towers"
which merely serve as
structures, nor is it
about "WCFs," which
according to the City
mix the tower and the
personal wireless
service facility, nor is it
about Wireless Telecommunication Facilities (WTFs),
which is ATC's preferred term.
By conferring the title of "WCF" on a tower, the
City focused its attention on the infrastructure, rather
than what was on it ATC was allowed to add or
Published by Kreines &Kreines, Inc., Consultants to Cities & Counties on Wireless Planning
58 Paseo Mirasol, Tiburon, CA 94920, (415) 435-9214 phone and (415) 435-1522 fax
e-mail: mail@planwireless.com -web site: http://www.planwireless.com
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~,
change personal
wireless service
facilities on the tower
at will, according to
PlanWireless'
comparison of the
approval documents
compared to the actual
sites, but the City of
San Diego focused on
the tower as the
subject of the
Conditional Use
Permit.
And focusing on
towers is where the
trouble starts and
where both sides'
arguments go astray.
Standing, or Having
the Right to Sue
The City of San
Diego claims that ATC
has no standing to sue
because it is not
licensed as a carrier by
the FCC. True
enough, and that
would still be the case
if the City had limited
its authority to
permitting "personal
wireless service
facilities;' as the
Telecommunications
Act explicitly
__ - _provides._But_only_
perSOnal W1re]e SS
service carriers can
own and operate personal wireless service facilities.
Instead, the City of San Diego (like many cities and
counties) acknowledged a tower company as owner or
a "WCF;' and therefore granted ATC status. Once a
municipality grants status to an applicant or a
permittee, even if it is an alien from another planet,
thatapplicant or permittee may have standing in its
particular application. And when that applicant-or
permittee has complaints about its previously granted
status, it may have standing to sue.
its property.
Height
The most offensive
(according to the City)
characteristic of the original
"WCFs" approved by the
City is excessive height.
The City itself
acknowledged this by
assessing the existing
facility and stating for the
next Conditional Use
Permit:
a substantial
reduction in height will
be expected with the
next submittal.
Since the tower was
considered the principal
part of the "WCF," this
meant either tearing a
monopole down and
rebuilding it or getting out
the chain saws and sawing
most of the tower down.
Had the Conditional Use
Permit been for a personal
wireless service facility, as
authorized by the
Telecommunications Act,
the permittee (a carrier, not
a tower company) would
then have to find another
spot. Instead, the aggrieved
party becomes the tower
owner with a Conditional
Use Permit fora "Wireless
Communication. Facility,"
and the tower owner is
being told to give up part of
The City of San Diego was aware that the FCC-
licensed carriers were the parties that are impacted by
the height reduction. In one of their denials, the
Planning Commission resolved:
The project, as it exists, does not result in n visually
desirable project. If redesigned to eornply with tlxe 30
foot height lintit, Verizon services to the community
and passing commuters woaAld be significantly
reduced. However, Verizon has the responsibility of
exploring available alternatives that would address
Published by Kreines &Kreines, Inc., Consultants to Cities & Counties on Wireless Planning
58 Paseo Mirasol, Tiburon, CA 94920, (415) 435-9214 phone and (415) 435-1522 (ax
e-mail: mail@planwireless.com -web site: http://www.planwireless.com
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the services of a competent professional should be abtatned.
ATC will lose hundreds of thousands of
And so, it is the personal wireless service facility of
Verizon, not the tower of ATC, that is impacted by the
City's actions. Why, then, wasn't Verizon the
applicant for a personal wireless service facility, rather
than a tower company allowed to be a pcrmittee for a
„ W CF"?
Buying the Sky
ATC built several monopoles scores of feet higher
than the San Diego height limit in the 20~h Century.
This now impermissible height gave ATC a
competitive advantage over new applicants by 2000,
when the City's rules forced lower mounts in San
Diego. '
But ATC claims that their rights can't be taken
away, even though ATC and its successors signed 10-
-- yearand 20-year Conditional Use Permits with specific
expiration dates.t
Now ATC claims that its business success depends
on keeping heights high in order to facilitate co-
location as stated:
bi fact, the city has required eitfter removal or
replacement ofATC's facilities with a substantial
reduction in height, effectively removing ATC's
collocation capabilities. As n result of these
' ATCs most common predecessor was Spec[raSite, a tower company
lhat "merged" with ATC several years ago. Spec[raSite should have known
(ts Conditional Use Permits in the Cit)~ had expiration dates and ATC
should have known it was obtaining short term asseLS-
dollars.
But the expected co-locations have not occurred
and, because deployment heights are dropping
everywhere (not just in San Diego), it is not likely that
high positions on the mounts will be sought by
Cellular, PCS, 700 MHz and AWS carriers.
Competition
To add insult to injury, ATC claims that the City is
putting wireless carriers on City-owned monopoles
(only one of which is identified), which are exempt
from the height restrictive regulations. Once again,
ATC is looking at a "Wireless Telecommunication
Facility;' which ie basically a tower. It is not the tower
but the type of wireless services that are attached to a
monopole that invokes the term "personal wireless
service facility' and the protection of the
Telecommunications Act.
For its part, the City defends its right to rent to FCC-
licensed carriers on it own "WCF" when the tower was
built for municipal purposes:
ATC argues that City's esernption for land use
regulations ns it relates fo its own structures cremes
an excessive burden on interstate commerce. City's
exemption is founded in n long line of legal precedence
and supports City's reasonable exercise of ifs police
powers to regulate the health; safety and welfrire of its
citizens. City's wireless strucftrres (sic)~ninih
function is for emergency communications, eg., fire
and police.
Published by Kreines &Kreines, Inc., Consultants to Cities & Counties on Wireless Planning
58 Paseo Mirasol, Tiburon, CA 94920, (415) 435-9214 phone and (415) 435-1522 fax
e-mail.' mail@planwireless.com -web site: http.'//www.planwireless.com
However, the City fire, police and public safety
wireless facilities are not personal wireless service
facilities, and City users arc not protected by the
Telecommunications Act. The fact that police and fire
responders are on a monopole does not make them
identical to FCC-licensed carriers ... their frequencies
are allocated, not auctioned. Because public safety
facilities are hung on a pole that looks like a monopole
accommodating personal wireless service facilities
does not make the pole a "WCP." Only when aFCC-
licensed carrier's facilities are hm~g on the City-owned
monopole should the carrier apply for and be granted
a personal wireless service facility permit. This the
City did not do. Personal wireless service facilities can
be attached anywhere: rooftops, water tanks, city
halls, light standards ... who owns the mount and
what it looks like is immaterial to determining whether
the attachment is a personal wireless service facility or
not.
Conclusion of Part Two
ATC v. City of San Diego will be around a long time
because it is held up pending a decision in Sprint v San
Diego County. Readers of PlanWireless will recall that
San Diego County won in Superior Court but lost in
federal District Court and at the Ninth Circuit Court of
Appeals. Since then, many objectors to the decision
have forced an eii bdnc proceeding by the Ninth Circuit.
En Banc means that all judges in the Ninth Circuit will
look at the Sprint v. San Diego County case instead of
the three judges who found for Sprint.
In the Sprint v San Diego County case, Sprint
mounted a facial attack on San Diego County's
ordinance So, similarly, has ATC launched a facial
attack against the City of San Diego, claiming the
City's ordinance is burdensome and overreaching.
Our subscribers can look Forward to more on ATC v.
- Snn Diego as well'as Sprinl~v: Sun Diego in future issues.
California Public Utilities Commission
Investigates T-Mobile Over Deployment Practices
On August 30, 2008, the Sari Francisco Chronicle
reported that the California PUC ...
is investigating claims tlmt cell phone giant T-
Mobile has been improperly putting up new cell
transmission sites throughout Northern California
without complying with local building laws.
PlanWireless would like to clarify that cell sites in
California are normally permitted by zoning, usually a
Conditional Use Permit (CUP), after which any
building permits would need to be consistent with the
underlying CUP. If investigators are looking for code
violations, the CUP for each approved site is the first
point of reference.
As PlanWireless has been telling its readers for years,
cell sites rarely look like the drawings they were
approved by. In many jurisdictions, the drawings are
often called "as-builts;' meaning they are faithful
representations to what was constructed. Since the
"as-builts" were drawn prior to construction, what
happens in the field is often improvised and therefore
different than the "as-builts ° Building permits rarely
show the complete "as-builts," referring instead to the
CUP drawings.
The notion that a state agency can crack down on
activity that is endemic and longstanding in the
wireless industry is laughable. Where would the PUC
begin? What would the PUC do if alleged faulty
practices were confirmed? The California PUC can
allege wrong-doing under their General Orders 7.59
and subsequent revisions and then invoke state
sovereignty over cities and counties. But if the PUC
tried to shut down a cell site that is "on the air" they
would probably be told by the FCC to back off.
The FCC just received $4.2 billion from T-Mobile for
Advanced Wireless Services auctioned in 2006, and
they aren't about to jeopardize their relationship with a
foreign government
Did PlanWireless say a "foreign government"? Yes,
T-Mobile is wholly owned by the Lerman State
Telecommunications Agency, Deutsche Telekom. They
use T-Mobile as a carrier name in fhe U.S., much as
they once used names such as Omnipoint,
VoiceStream, Powertel and APT.
It's easy to pick on T-Mobile, because it is the
smallest of the four national carriers. But the. big four
carriers all source work to other companies and some
of these companies may be less honorable than others.
Until local governments ensure that wireless projects
are maintained according to the local government's
approvals, the incidence of building and modifying cell
sites without proper authorization from local
governments will continue unabated. And with little
oversight, tower companies such as ATC (see the other
article in this PlanWireless issue), may claim rights they
never had in the first place.
Published by Kreines 8 Kreines, Inc., Consultants to Cities & Counties on Wireless Planning
58 Paseo Mirasol, Tiburon, CA 9492Q (415) 435-9214 phone and (415J 435-1522 fax
e-mail: mail@planwireless.com -web site: http://www.planwireless.com