BookPDF Available

Bridging the Gap - 21st Century Wireless Telecommunications Handbook (2nd Edition, 2019)

Authors:
  • Joint Venture Silicon Valley

Abstract and Figures

Wireless technologies have become a fundamental part of our daily life in the 21st century. They connect us to each other and to rich sources of information. They give us the ability to make efficient use of our time, allow us to have remote control over other technologies in our life, and make our lives better in innumerable ways. In order to function, our wireless devices need to connect to cellular sites that provide good coverage both outdoors and indoors. To do that increasingly requires placement of sites closer to populated areas – creating new challenges for both providers and local governments. Next-generation technologies will enable greater functionality, but their complexity places increasing burdens on municipalities. Written primarily for municipal employees, public officials, and civic leaders, this handbook will help guide understanding of these networks as they deal with very complex and rapidly evolving technologies. We see evidence of the pace of technology evolution in the history of this handbook. First published in 2016, after only three short years so much has changed we needed to publish an update. In this document, we will cover much ground. We will look at what is driving the need for wireless data, the societal value of wireless data networks, the technologies the industry is deploying to build those networks, and the regulatory environment for wireless facilities that govern how carriers and local governments must interact. We will close with an overview of new technologies we can expect in years to come, and provide some forward-looking recommendations for both local governments and wireless carriers.
Content may be subject to copyright.
SILICON VALLEY
Bridging the Gap
21st Century Wireless Telecommunications Handbook
SECOND EDITION  DECEMBER 2019
2Bridging the Gap: 21st Century Wireless Telecommunications Handbook - Second Edition
Acknowledgments
David Witkowski, Executive Director of the Wireless Communications Initiative at
Joint Venture Silicon Valley, authored this report. Jill Jennings created the report’s
layout and design. Robin Doran served as copy editor.
The author and Joint Venture Silicon Valley would like to thank the following
people for their contributions to, and support of, this project:
William J. McShane II, Director – Americas, ICity Venture, Signify
Al Brown, President and CEO, SmartWave Technologies LLC
William Hammett P.E., President & CEO, Hammett & Edison Inc.
John Lang, Economic Development Manager, City of Morgan Hill, CA
Joe Madden, Mobile Experts LLC
Patrick Mulhearn, Policy Director – Board of Supervisors, County of
Santa Cruz, CA
Carlos Ramos, Principal Consultant, Maestro Public Sector
Richard Tell, President, Richard Tell Associates, Inc.
Jerrold T. Bushberg, PhD, DABMP, FAAPM, FHPS, Director Emeritus Medical/
Health Physics Programs, University of California, Davis – School of Medicine
JOINT VENTURE SILICON VALLEY
Established in 1993, Joint Venture Silicon Valley brings together established and
emerging leaders—from business, government, academia, labor and the broader
community—to spotlight issues, launch projects, and work toward innovative
solutions. For more information, visit www.jointventure.org
For more information or to contact the Wireless Communications Initiative go to
www.jointventure.org/wireless.
AUTHOR CONTACT INFO
David Witkowski
Executive Director, Wireless Communications Initiative
wireless@jointventure.org
(408) 298-9333
3
Bridging the Gap: 21st Century Wireless Telecommunications Handbook - Second Edition
Table of Contents
Introduction 4
Factors Driving Change 7
The Evolution of Cellular 10
Societal Value of Wireless Broadband 14
Mobile Network Densication 17
Wireless Telecom Legislation 25
Addressing Common Public Concerns Regarding Wireless 31
Wireless Telecom Roadmap – What Does The Future Hold? 38
Recommendations for Municipal Governments 40
Takeaways for Municipal Leaders 43
Recommendations for Carriers, Operators, and Utilities 44
Glossary of Terms 46
Works Cited 49
4Bridging the Gap: 21st Century Wireless Telecommunications Handbook - Second Edition
Introduction
Wireless technologies have become a fundamental part of our daily life in the
21st century. They connect us to each other and to rich sources of information.
They give us the ability to make ecient use of our time, allow us to have
remote control over other technologies in our life, and make our lives better in
innumerable ways. In order to function, our wireless devices need to connect
to cellular sites that provide good coverage both outdoors and indoors. To do
that increasingly requires placement of sites closer to populated areas – creating
new challenges for both providers and local governments. Next-generation
technologies will enable greater functionality, but their complexity places
increasing burdens on municipalities.
Written primarily for municipal employees, public ocials, and civic leaders,
this handbook will help guide understanding of these networks as they deal
with very complex and rapidly evolving technologies. We see evidence of the
pace of technology evolution in the history of this handbook. First published
in 2016, after only three short years so much has changed we needed to
publish an update. In this document, we will cover much ground. We will look
at what is driving the need for wireless data, the societal value of wireless data
networks, the technologies the industry is deploying to build those networks,
and the regulatory environment for wireless facilities that govern how carriers
and local governments must interact. We will close with an overview of new
technologies we can expect in years to come, and provide some forward-looking
recommendations for both local governments and wireless carriers.
Wireless networks have come a long way since 1973, when Martin Cooper made
the rst portable cellular call from the streets of New York City. The number of
devices connecting to mobile networks – especially 4G networks – is growing
steadily, straining network capacity and necessitating both densication (via
small cells and distributed antenna systems) and new technologies like 5G that
can handle the subscriber growth.
It is important to consider the economic impact of these networks. The dot-
com boom created the internet economy, and now Silicon Valley is the center
of the mobile economy. From the largest corporations (e.g. Google, Apple,
Amazon, and Facebook) to the smallest seed-funded startup – each has built its
success around a “Mobile-First” strategy focused on delivering information and
conveniences via smartphone apps, cloud computing, and mobile networks. This
economic expansion would not have been possible without the privately-funded
4G network that enabled smartphones to access the rich sources of information
that fuel the mobile economy.
Wireless
technologies
have become a
fundamental part
of our daily life in
the 21st century.
5
Bridging the Gap: 21st Century Wireless Telecommunications Handbook - Second Edition
Figure 1: Devices or Connec tions per year
(Figures in parenth eses refer to device/connec tion share by network t ype for 2017 vs. 2022)



     
 

!"#
Source: Cisco Visual Networking Index, 2019 Edition (Recreated)
Accenture’s 2017 report on 5G economics projects that the U.S. wireless industry
will invest $275 billion during the deployment of 5G – roughly speaking about
$800 per resident in areas ranging from major cities to small towns. A private
investment of this magnitude in U.S. infrastructure will be easily the largest
ever made – it exceeds (in 2019 dollars) the amount spent by the U.S. federal
government on the Apollo space program, and approaches the amount of
taxpayer dollars invested in construction of the interstate highway system.
The Apollo program’s technology developments spun o untold numbers of
innovations that are now part of our modern life including solar panels, CAT
scans and MRIs, cordless drills, quartz clock movements, and heat-resistant
materials for re-ghting suits – we can only begin to imagine the technology
innovations that massive private investment in our national communications
infrastructure will enable.
Faced with skyrocketing demand that presents both an enormous opportunity
and a seemingly impossible technical challenge, wireless carriers have begun
shifting their deployment strategies away from voice telephony towards 4G
mobile data for smartphones. Looking forward, carriers will continue to add
capabilities in 5G for machine-to-machine communications (the so-called
“Internet of Things”) and extremely reliable low-latency networks necessary for
ultra-accurate positioning and autonomous vehicles. As we move from 2G/3G
networks on towers that serve areas several miles in diameter to low-power 4G
and 5G networks focused on serving a few city blocks, the number of sites is also
increasing, and their placement becomes increasingly critical.
As we move from
2G/3G networks
on towers that
serve areas several
miles in diameter
to low-power 4G
networks focused
on serving a few city
blocks, the number
of sites is also
increasing, and their
placement becomes
increasingly critical.
6Bridging the Gap: 21st Century Wireless Telecommunications Handbook - Second Edition
Figure 2: Global Mobile Da ta Usage (per month)
Source: Mobile Experts LLC
Mobile telephony is a competitive business, and subscribers unhappy with
their carrier’s network performance can easily switch their phone number and
service to another provider. (The industry term for this is “churn.) Carriers are so
desperate to win customers that they will oer hundreds of dollars to cover early
termination fees and give away expensive phones – just to get subscribers to
sign a 12-month or 24-month contract.
To build a wireless network, a highly competitive spectrum auction conducted
by the Federal Communications Commission (FCC) grants leases to carriers – and
this cost is not trivial. Wireless spectrum purchased during one spectrum auction
known as “AWS-3” cost the bid winners over $44 billion, paid up front to the U.S.
government, and that was a relatively small auction – just one of many over the
past three decades (FCC AWS-3 Auction Results, 2015). Having paid to win the
spectrum leases, the carriers then must invest in wireless facility siting studies,
pre-application meetings, public hearings, permit applications, and engineering
designs/redesigns. Costs for deployment are incurred up front; the investment in
equipment, personnel, trucks, and tools to install wireless networks are all pre-
revenue. It takes years of monthly subscriber revenue before the carriers and site
operators can realize a prot on these capital and operational expenses.
At best, every dropped call or slow data connection puts a wireless carrier at
risk of losing a customer to churn. At worst, it creates a public safety issue for
people who rely solely on mobile phones to call emergency services. If an area
experiences excessive dropped calls or slow data, a carrier will want to x that
problem – and that means upgraded equipment or new sites – and navigating a
local government permitting process. Unfortunately, these interactions have not
always been positive.
7
Bridging the Gap: 21st Century Wireless Telecommunications Handbook - Second Edition
Given the urgency placed on carriers to enhance networks, reduce churn, and
meet users’ demand for faster data, it was inevitable that conicts between
carriers, operators, and local governments would arise. Carriers and site
operators feel that some local governments have treated applications for
wireless facilities with either disdain or outright hostility, that application
processes are often unclear or arbitrary, and are sometimes subject to repeated
demands for eleventh-hour revisions. Local governments feel that some carriers
and utilities have been dishonest in their applications, have built sites that do
not match the application’s plans and rendered drawings, or have failed to heed
requests for integration with local design and architectural standards. Each
side has their horror stories, and certainly, each side has made mistakes. Our
shared goal for Silicon Valley – and indeed the entire country – should be to
move beyond those mistakes and go forward together in partnership between
industry and local governments, to create high-performance wireless networks
with great coverage that will support current needs and pave the way for future
innovation. Fast and ubiquitous wireless networks are critical resources for our
country’s residents, and failing to provide them is no dierent than failing to
provide clean drinking water, natural gas, sanitation service, or electricity. Yet
we must also respect the need for minimalist, quiet, and aesthetically pleasing
infrastructure.
Factors Driving Change
User Demand for Mobile Data
By any measure, the demand for mobile data is enormous and not likely to
slow down. Ericsson’s 2019 Mobility Report estimates the consumption of data
on mobile devices (smartphones, tablets, and mobile-enabled PCs) worldwide
grew by 78 percent between Q2 2018 and Q2 2019 and reached 94 Exabytes
(1 Exabyte equals 1 billion Gigabytes) per month in Q2 2019. (To give a sense
for scale, an Exabyte is equal to 250 million DVDs of information.) Smartphones
drove the majority of that usage (Ericsson AB, 2019). In 2017, the average
smartphone subscriber in North America consumed 8.3 GB of data per month,
and this will increase to 59 GB per month by 2021.
The Mobile Economy is a heavy driver of wireless data usage – caused by a
fundamental shift in user behavior in communication and commerce from PCs
connected by wired internet to smartphones and tablets connected by mobile
networks. In 2018, mobile technologies and services generated 4.2% of GDP in
North America, at a value of $937 billion. This will increase to $1.2 trillion (4.8% of
GDP) in 2023 (GSMA, 2019).
By any measure,
the demand for
mobile data is
enormous and not
likely to slow down.
8Bridging the Gap: 21st Century Wireless Telecommunications Handbook - Second Edition
Figure 3: Mobile ecosys tem cont ribu te to North A meric an economy, 2018
Source: GSMA Intelligence
Users Want More for Less
While the number of users and the amount of mobile data they consume has
gone up exponentially, market forces have driven down the average revenue
per user. According to GSMA Intelligence reports, for carriers in the United States
average revenue per user (ARPU) per month in 2018 was $8.45, a decrease of
0.8% from 2017 (GSMA, 2019). PWC Strategy reports show that ARPU spread
was above 75% at the start of the smartphone era in 2010 but had fallen below
50% in 2017 (PWC Strategy, 2018). Free-market competition between carriers
has been very successful in making wireless networks more aordable for more
residents, but it places enormous downward revenue pressure on the carriers
and forces them to compete for a dwindling number of new subscribers in an
increasingly saturated market.
Spectrum Scarcity
Wireless services rely on the availability of spectrum – the term for the range
of electromagnetic frequencies used to carry signals between the network and
users. Spectrum is like land – there is only so much of it. Every bit and byte of
information we consume over a mobile network requires a certain amount of
spectrum to make the connection. Like constructing a high-rise building to
make ecient use of land, we can make our use of spectrum more ecient –
but this approach has limits. One approach to improving spectrum eciency is
densication – reusing the spectrum from large macro towers that cover many
square miles in systems that cover a few city blocks, the inside of a building,
or even a single room. Known collectively as Heterogeneous Networks or
HetNets these low-power sites do not replace large macro tower sites, but are
supplemental to them – focusing scarce spectrum resources into areas where
people tend to use the most data.
There are two types of spectrum – licensed and unlicensed. Regulatory
authorities (such as the FCC) lease licensed spectrum to corporations and
individuals, who then use the spectrum for various purposes. In most cases,
the commercial leaseholders of licensed spectrum must pay the government
for an exclusive right to use that spectrum, must meet the requirement that
Wireless services rely
on the availability
of spectrum – the
term for the range
of electromagnetic
frequencies used
to carry signals
between the
network and users.
Spectrum is like
land – there is only
so much of it.
9
Bridging the Gap: 21st Century Wireless Telecommunications Handbook - Second Edition
the spectrum be used to provide a public good of some type, and leaseholders
have legal standing to le a complaint against anyone who interferes with those
systems. Provided at no cost to the end user, unlicensed spectrum enables
consumer devices and conveniences such as garage door openers, cordless
phones, and Wi-Fi networks. The consumer or network provider does not need to
obtain a license to use this spectrum, but they also have no standing to pursue
claims or le complaints about interference.
Smart Cities and the Internet of ings
People are not the only users of spectrum. Wireless networks connect machines
and autonomous devices to the network. Predicted to reach 5.9 billion devices
in 2025, the Internet of Things (IoT) is a major user of wireless spectrum. While
not a rm denition, IoT typically refers to connected cars, sensors (including
cameras), displays and actuators, utility metering and control, industrial systems,
data storage systems and the articial intelligence algorithms that act on that
data, and consumer electronics. There are two IoT classications: Consumer
IoT and Industrial IoT (GSMA, 2019). Systems that use Industrial IoT technology
often form the basis of municipal Smart City systems for transportation, resource
management, public safety, and other civic applications. IHS Markit Technology
forecasts the total installed base will grow to 69.5 billion units in 2025 and device
shipments will grow to 18.1 billion units in 2025 (IHS Markit, 2016).
Figure 4: IoT Devices - Instal led Base & Device Shipment s
Source: IHS Markit
People are not
the only users of
spectrum. Wireless
networks connect
machines and
autonomous devices
to the network.
10 Bridging the Gap: 21st Century Wireless Telecommunications Handbook - Second Edition
e Evolution of Cellular
2G -> 3G -> 4G -> 5G
In the early days of digital cellular telephony, the denition of a wireless system’s
“generation” was primarily a marketing device not based on standards. Second
Generation, or 2G digital cellular, replaced the rst analog cellular systems
and allowed the use of text messaging. Beginning with the Third Generation,
or 3G family of standards, the International Telecommunications Union’s
Radiocommunication Sector (ITU-R) began seeking international agreement on,
and publishing recommendations for, IMT-2000 – the standardized denition
that 3G technologies would have to meet (International Telecommunications
Union, 2011). In 2010, the ITU-R dened the Fourth Generation, or 4G family of
standards, designated IMT-2010. “Long Term Evolution” or LTE as one technology
that meets the ITU-R’s 4G denition, although there is another technology
known as WiMAX that also meets the 4G denition. The ITU-R later expanded
upon this standard by creating IMT-Advanced, and the ITU’s Fifth Generation, or
5G standard, is designated IMT-2020 (ITU, 2019).
5G Demystied
5G is an increasingly covered topic in the media, but much of that coverage
misses the mark because it focuses only on the mobile handset use model that
dened 4G. It is critically important that municipal leaders understand 5G is not
just another technology for smartphones and tablets. 4G was useful for these
devices, but it cannot support use cases where timing and latency are critical,
and it cannot handle very large numbers of connected devices. The promise of
5G is that it will address these and other limitations while adding performance to
existing systems, and support a wider range of use cases.
Just as LTE was a technology that met the ITU-R 4G denition, “New Radio” or
NR is a technology that meets the 5G denition. NR nodes are deployable in a
standalone conguration (so-called “Pure 5G”), or in parallel with LTE nodes. We
expect that most initial deployments will be parallel LTE + NR congurations,
with Pure 5G coming later as more devices are able to leverage 5G connections.
ITU-R has specied performance via the IMT-2020 standard for 5G systems that
improves upon 4G LTE and adds new capabilities. 5G will oer support for:
Enhanced Mobile Broadband (eMBB) – dramatically increasing data
throughput for smartphones, tablets, PCs, and other consumer devices. 5G
also dramatically increases the ability to serve large numbers of devices – 4G is
only able to support a few hundred devices per site, whereas 5G can support
millions per site.
It is critically
important that
municipal leaders
understand 5G is
not just another
technology for
smartphones
and tablets.
11
Bridging the Gap: 21st Century Wireless Telecommunications Handbook - Second Edition
Ultra-Reliable Low-Latency Communications (uRLLC) – allowing for ultra-fast
exchange of data, such as near real-time sensor sharing to enable both semi-
autonomous and fully autonomous vehicles.
Massive Machine-Type Communications (MMTC) – expanding support for
large numbers of Internet of Things devices running at minimum power, with
batteries that last over 10 years.
Positioning – an alternative to GPS for underground, indoor, urban canyon, etc.
use cases, this enables precise positioning without the need for satellites.
Time-Sensitive Networking (TSN) – an aspect of uRLLC, TSN will provide
support for deterministic networks, Ethernet/Fiber performance over
5G (5G LAN), quality of service control, and ultra-accurate device time
synchronization.
Fixed Wireless Access (FWA) – an alternative to wired broadband, 5G can
deliver broadband to home and business consumers without physical lines.
Network slicing, virtualization, and edge computing – rather than require all
data be transported between the users and the 4G core servers, 5G will enable
the placement of computing near users. (Note that edge computing is not a
new concept, and is not unique to 5G. When combined with edge computing,
5G features like uRLLC will allow the creation of near real-time services.)
Massive Multi-Input Multi-Output (MIMO) antenna systems, which operate as
intelligent phased arrays to electrically steer a 5G site’s RF signal towards the
user equipment. Massive MIMO will increase channel eciency, throughput,
and decrease interference. Unlike previous cellular generations, 5G MIMO
systems direct their signals only towards 5G users.
The IMT-2020 5G denition species three usage scenarios and their
performance requirements:
eMBB – Over 10 Gbps peak data rates on the uplink and downlink, and over 50
Mbps user-experienced data rates on the uplink and downlink. High spectral
eciency. Support for high-mobility connections. High network energy
eciency. High area trac capacity.
MMTC – Support for over 1 million connected devices per square-kilometer.
uRLLC – Latency below 1 millisecond, and support for high-mobility
connections.
12 Bridging the Gap: 21st Century Wireless Telecommunications Handbook - Second Edition
Figure 5: 5G Usage Scenarios (eM BB, MMTC, uRLLC)
Source: ETSI
As with any wireless technology, the success or failure of 5G networks will
depend heavily on the availability of spectrum. The rst spectrum bands
allocated for 5G were in spectrum above 6 GHz, often called “millimeter wave”
spectrum. The media’s coverage of 5G has erroneously implied – or explicitly
stated – that 5G is a millimeter wave system. The reality is that 5G will be able to
use a wide range of spectrum options including low-band (below 1 GHz), mid-
band (1 GHz to 6 GHz), and millimeter wave (above 6 GHz) spectrum bands. 5G
will also be able to use both licensed and unlicensed spectrum, and over time
will replace older 3G equipment as deployment progresses.
It is important to note the IMT-2020 performance denes requirements by use
case, and any technology meeting the denition for that use case is in fact a
5G technology. In fact, some existing sites using LTE-Advanced technologies
are able to meet the 5G denition for eMBB, and hence these sites are already
technically 5G sites.
Siting Requirements for 5G
5G operating in low-band and mid-band spectrum will have the same coverage
pattern as the 3G and 4G Small Cell sites they replace. However, 5G sites in
millimeter wave bands do not cover very large areas, because signal levels in
millimeter wave bands drop o very quickly over distance (Refer to Figure 6).
As with any wireless
technology, the
success or failure
of 5G networks will
depend heavily
on the availability
of spectrum.
13
Bridging the Gap: 21st Century Wireless Telecommunications Handbook - Second Edition
Figure 6: Radio fr equency energy loss ove r distance, by spectrum ban d
Source: Oku Solutions LLC
Wireless Generation Lifecycles
In parallel with 5G, 4G (both LTE and WiMAX) continues to evolve, with new
features added by the IMT-Advanced denition. Historically, each generation of
wireless telecom has taken about 12 years to reach its peak – which means 4G
deployments will not peak until 2022. Much work remains in 4G deployment,
especially in 4G small cells, as users will continue to use that technology for
several years while 5G matures and begins entering its main deployment phase.
However, some industry analysts have made arguments that the 5G lifecycle will
be dierent from previous generations. There are two arguments in support of
this assertion:
1. 5G will enable IoT devices, automotive, rail/transit, tele-health, utility networks,
etc. 5G is not just another technology for handsets and PCs. While the market
for 4G has been constrained by subscriber saturation, (the term we coined for
this is “Peak Smartphone”) the number of devices that can potentially benet
from 5G is much higher.
5G operating in low-
band and mid-band
spectrum will have
the same coverage
pattern as the 3G
and 4G Small Cell
sites they replace.
14 Bridging the Gap: 21st Century Wireless Telecommunications Handbook - Second Edition
2. Previous wireless telecom generations have been revolutionary, meaning that
they were radically dierent from previous generations. In contrast 5G is more
evolutionary, e.g. the case where some LTE-Advanced sites can be reclassied
as 5G. Thus, the start of the 12-year lifecycle for 5G has already begun.
Figure 7: Mobile Technology Lifecycles (North America)
Source: Chetan Sharma
Societal Value of Wireless Broadband
Wireless Voice and Broadband are Not Luxuries
Mobile networks are increasingly replacing wired telephones, and sometimes
even wired broadband service. This is especially true of younger people, but
also in economically disadvantaged communities. The reason is simple – given
a limited household budget, the convenience of a mobile device both at home
and away from home outweighs the inconvenience of lower data rates and
possible dropped calls.
Increased Demand for Wireless Telephony
Twice a year the U.S. Department of Health and Human Services publishes the
Wireless Substitution Report via the Centers for Disease Control, based on data
from the National Health Interview Survey. These reports have consistently
shown an increase in the rate at which people are giving up wired phones
for wireless. Nationwide results from the May – December 2018 survey show
that over one-half of all adults (56.7%) are now wireless-only and 67.5% of all
children live in wireless-only households. These numbers are notably higher for
the western U.S. region (including California). Results from other demographics
Mobile networks
are increasingly
replacing wired
telephones, and
sometimes even
wired broadband
service. This is
especially true of
younger people, but
also in economically
disadvantaged
communities.
15
Bridging the Gap: 21st Century Wireless Telecommunications Handbook - Second Edition
are striking. Over 3 in 4 adults (76.7%) under the age of 29 do not have wired
phones; between age 30-34 the rate is 76.2%. 75.5% of renters are wireless only.
68.1% of Hispanic households, and 67.1% of households below the poverty line,
do not have wired phones (Centers for Disease Control, 2019). These numbers
have increased in all categories since the rst edition of this handbook in 2016,
and we expect the trend towards wireless-only connectivity will continue for
many years to come.
The reasons for this increased demand are the convenience and eciency of
wireless devices. Wired telephones connected buildings to buildings; wireless
phones connect people to both people and buildings. In a shared housing
situation, or in multi-generational households, everyone can have his or her own
number and direct voicemail or text messaging – instantly delivered anywhere
we are – replaces the uncertainty of answering machines and paper messages.
Wireless phones are easy to obtain, people with low credit scores can use pre-
paid plans – or even buy a phone with cash – and there is a wealth of consumer
choice across several carriers.
Figure 8: Percentages o f adults and children liv ing in households with only w ireless telephone ser vice: United States,
2003-2018
Source: NCHS, Centers for Disease Control, National Health Interview Survey (June 2019)
Wireless Broadband is a Primary Internet Access Tool
Giulia McHenry, Chief Economist, Oce of Policy Analysis and Development for
the U.S. Department of Commerce, published a blog article which showed that
American households are rapidly shifting their broadband connectivity from
wired (cable, DSL, etc.) to wireless (McHenry, 2016). The article’s source data
comes from the U.S. Census Bureau’s Computer and Internet Use Supplement to
the Current Population Survey (CPS), which includes data collected for the NTIA
in July 2015 from nearly 53,000 U.S. households. The results of this survey are
16 Bridging the Gap: 21st Century Wireless Telecommunications Handbook - Second Edition
striking – Households with annual incomes below $25,000 are 29% likely to be
accessing the internet via only mobile broadband, and households between
$25,000 and $49,999 annual income are 24% more likely to be mobile-only.
McHenry’s results track closely with other research. Survey data from The Field
Poll reported in 2016 found that 14% of California residents connect to the
internet only through a smartphone. For households earning less than $22,000
per year, the rate is 25% (CETF, 2016). Pew Research’s 2019 report showed that
17% of adults in the U.S. do not have home broadband and access the internet
only through a smartphone – either directly, or by sharing the smartphone’s
cellular data to other devices. Rates for smartphone data with no home
broadband are higher for at-risk demographics; 25% for Hispanics, 32% for
people who did not graduate high school, and 26% for people with incomes
under $30,000 per year (Pew Research, 2019).
Wireless Access to 911 Emergency Services
The societal shift to wireless telephony creates a challenge to rst responders,
and underscores a mandate that municipalities must support deployments to
create reliable coverage both outdoors and indoors. Various studies nd that on
average cellular users make 80% of 911 calls. The majority of these calls originate
from indoor locations. Groups opposed to wireless deployments often show
videos of calls made outdoors to argue there is no need for additional coverage.
These videos do not take into account the lack of coverage inside a home,
business, or apartment complex – the very locations where people most often
call 911.
Unconnected Cities
It is easy to think the problem of unconnected residents only exists in rural
counties or remote towns in the mountains, but this is incorrect. The need
for additional sites to improve coverage in urban areas is great, and failure
to continue this work creates connectivity gaps for large numbers of urban
residents. Research published in 2016 shows that over 25% of residents in major
U.S. cities such as Los Angeles and New York do not have readily available access
to the internet (Maravedis & Wi-Fi 360, 2016). This tracks with ndings from Pew
Research, which reported in 2019 that while average urban broadband speeds
exceeded the average for rural households, urban households were also more
likely to have no options for home broadband; 78.8% of rural households had
home broadband, while only 72.7% of urban households had home broadband
(Pew Research, 2019).
It is easy to think
the problem of
unconnected
residents only exists
in rural counties or
remote towns in
the mountains, but
this is incorrect.
17
Bridging the Gap: 21st Century Wireless Telecommunications Handbook - Second Edition
Mobile Network Densication
Densication and Heterogeneous Networks
Densication is the term for adding equipment to augment existing mobile
networks and provide additional capacity in areas of high usage. Densication
technologies include Distributed Antenna Systems (DAS) and Small Cells.
Heterogeneous Networks or HetNets coordinate DAS and Small Cell sites with
large macro towers to create a densied network. Emitting much lower RF power
than their tower counterparts, Small Cells and DAS focus spectrum resources
in a small area; typically, their coverage extends for only a couple of city blocks
or within a facility. DAS systems extend and improve coverage in buildings,
corporate campuses, shopping malls, and other public venues. Small Cells
improve coverage and performance for subscribers in the public rights-of-way,
homes, small businesses, and public venues. For the purposes on this handbook,
we will focus on Small Cells.
Figure 9: Small Cell a nd DAS sites add capacity to e xisting networks
Source: Oku Solutions LLC
Why are Small Cells Important?
The majority of mobile data usage occurs where humans congregate, and users
in xed locations consume 80% of that mobile data. Draw a box on a map,
highlight the areas where 90% of the data are used, and 95% of the map will
be dark – we do not typically consume large amounts of data while standing in
the middle of an empty eld. We use data in our homes, workplaces, vehicles,
18 Bridging the Gap: 21st Century Wireless Telecommunications Handbook - Second Edition
restaurants, shopping malls, and sports venues. All users share the total amount
of data available – when large numbers of people congregate in a small area, the
result is slow connections and poor performance. Small Cell technologies allow
network designers to concentrate scarce spectrum resources and serve high-
demand areas with dense populations.
HetNet Ordinances and Codes
Most municipal ordinances originally written for permitting macro towers during
the early days of cellular telephony do not dierentiate between Small Cell
wireless facilities attached to a utility pole and a 70-foot tall macro tower – and
this has created some issues. It is critical that ordinances and codes account
for those dierences, as Small Cells are very dierent from large macro tower
systems. Thankfully, in recent years, the number of municipalities that have
passed Master Lease Agreements to cover Small Cell deployments has grown –
but much work remains.
Municipal ordinances and codes sometimes encourage co-location (the term
used when wireless facilities from multiple network operators are attached to the
same physical structure) by requiring minimum separation distances between
wireless systems. In the early days of cellular telephony, this separation or macro
towers made sense, but Small Cells can be located closer together without
creating safety, interference, or performance issues. Sometimes these outdated
separation ordinances force network operators to locate Small Cell facilities in
undesirable locations, which is neither ideal for optimizing network performance
nor a good investment for the network operator. Municipal governments should
revise separation ordinances to allow closer placement of Small Cell facilities
to adjacent sites. This will be especially important for millimeter-wave 5G sites,
because signals at those frequencies decrease rapidly over even small distances.
Distributed Antenna Systems
Multiple antenna nodes attached via coaxial cable or ber to centralized radio
equipment creates a Distributed Antenna System or DAS. Typically, the radio
equipment connects to the core network via ber optics. DAS systems provide
robust coverage inside convention centers, large buildings, sports venues, and
shopping centers. There are some outdoor DAS (o-DAS) networks, typically used
along driving routes where the terrain is dicult to cover with macro towers, but
they are increasingly less common as Small Cells have become the technology
of choice for augmenting coverage in public rights-or-way. The benet of DAS
is that the antennas are typically small and simple to install, with the radio
equipment installed remotely in cabinets or equipment closets. Signal levels to
and from each antenna must be adjusted carefully to ensure uniform coverage
and avoid gaps, which is a downside that has led to reduced usage of DAS in
outdoor venues.
Small Cell
technologies allow
network designers
to concentrate
scarce spectrum
resources and
serve high-demand
areas with dense
populations.
19
Bridging the Gap: 21st Century Wireless Telecommunications Handbook - Second Edition
Small Cells Dened
The denition of what constitutes a Small Cell was somewhat uid until the
Federal Communications Commission issued FCC 18-133 “Declaratory Ruling
and Third Report and Order”, also known as the “2018 Small Cell Order”. The FCC
guidance for “Small Wireless Facilities” is that the facilities:
Are mounted on structures 50 feet or less in height including their antennas as
dened in 47 CFR § 1.1320(d), or;
Are mounted on structures no more than 10 percent taller than other adjacent
structures, or;
Do not extend existing structures on which they are located to a height of
more than 50 feet or by more than 10 percent, whichever is greater.
The FCC guidance further states:
Each antenna associated with the deployment, excluding associated antenna
equipment (as dened in the denition of antenna in 47 CFR § 1.1320(d)), is no
more than three cubic feet in volume;
All other wireless equipment associated with the structure, including the
wireless equipment associated with the antenna and any pre-existing
associated equipment on the structure, is no more than 28 cubic feet in
volume;
The facilities do not require antenna structure registration under 47 CFR Part
17;
The facilities are not located on Tribal lands, as dened under 36 CFR 800.16(x);
The facilities do not result in human exposure to radiofrequency radiation in
excess of the applicable safety standards specied in 47 CFR § 1.1307(b).
Prior to the FCC’s Small Cell Order, industry denitions of Small Cells were
qualitative and not standardized. Some base their denitions on Radio
Frequency (RF) power output levels, which are smaller relative to large macro
towers. Others based their denitions on the Small Cell’s Eective Radiated
Power (ERP) or Eective Isotropic Radiated Power (EIRP). The FCC’s Small Cell
Order removes ambiguity and creates a qualitative basis for standardization.
e Role of Small Cells
Because Small Cells are used in HetNets to provide densication, another
common denition is based on the signal coverage area, described rather loosely
by the Small Cell Forum as “typically [having] a range from 10 meters to several
hundred meters” (Small Cell Forum, 2019).
20 Bridging the Gap: 21st Century Wireless Telecommunications Handbook - Second Edition
The benet of Small Cells is that each acts as an independent node of a network,
under control of the carrier’s monitoring and control system. The downside
of Small Cell versus DAS is that each node requires ber and power lines, and
because the equipment comprises both the radio and the antenna, the total
volume needed to house each node is larger than DAS. The rate of deployment
for Small Cells (both 4G and 5G) will grow exponentially over the next ve years.
The installed base of Small Cells as of 2019 is 250,000, and analyst forecasts show
that carrier-owned Small Cell installs will reach nearly 207,000 units per year in
North America by 2024 (Mobile Experts LLC, 2019).
Will Small Cells Replace Large Macro Towers?
Small Cells augment, not replace, existing macro networks. Although most
typical mobile usage occurs in a small area, occasional use can occur anywhere
and failure to provide wide area coverage creates a public safety issue. Large
towers provide connection continuity as users move from one Small Cell node
to another, ensuring the smooth transfer of the voice or data connection
between nodes. We still need the macro tower network to provide this wide area
coverage, and the rise of Small Cells deployments does not imply an opportunity
to tear down large macro towers. In addition, macro towers often support other
purposes such as public safety (police, re, and emergency medical) two-way
radio, private microwave networks, and wireless internet service providers who
provide a competitive alternative to wired broadband.
From a network resiliency perspective, most macro tower sites have reserve
power (batteries and generators) that allow the site to continue working
during disasters such as earthquakes. Small Cell facilities typically do not have
large backup batteries, and their placement along public rights-of-way near
population centers precludes the use of generators. Thus, large macro towers
also remain an important part of our region’s disaster resiliency infrastructure.
Wireless Network Ooad
Even with HetNet technology for densication, the amount of information
supported by a wireless network directly correlates to the availability of RF
spectrum. In 2008, the Cellular Telephone Industry Association (CTIA) told the
Federal Communications Commission that mobile carriers would eventually
need an additional 800 MHz of RF spectrum to keep up with projected demand
(CTIA Filing to FCC, 2009). Unfortunately, this amount of spectrum is simply not
available, and the costs to acquire it would be very high. FCC has shifted some
unused television spectrum to the wireless carriers, and the estimated costs (as
of July 2016) for reclaiming only 100 MHz of this TV spectrum is $86 billion (FCC
600 MHz Auction Dashboard, 2016).
Small Cells augment
existing networks,
not replace them.
Although most
typical mobile usage
occurs in a small
area, occasional use
can occur anywhere
and failure to
provide wide area
coverage creates a
public safety issue.
21
Bridging the Gap: 21st Century Wireless Telecommunications Handbook - Second Edition
In addition to densication via HetNets, carriers are addressing rising user
demand and limited spectrum by implementing other capacity-increasing
strategies, including a technique called “ooad”. Ooad refers to a system where
the mobile network instructs the user’s device to create parallel connections.
These parallel connections are often via unlicensed spectrum under the carrier’s
control, using both Wi-Fi and a newer technology called LTE-Unlicensed. For
example, if a subscriber wants to watch a streaming video the network would
determine if an ooad site were within range, and if so divert the user’s data
connection to obtain the data via the ooad network, leaving the carrier’s core
network free to handle other trac.
Figure 10: Mobile network ooad Using Wi-Fi
Source: President’s Council of Advisors on Science and Technology, June 2012
Wi-Fi
Most of us know Wi-Fi as the technology used in our homes and oces to
connect devices wirelessly to a local area network. Based on the Institute of
Electrical and Electronics Engineers (IEEE) 802.11 family of standards, Wi-Fi
has evolved many times over since its rst release in the early 1990s. At the
technology level modern Wi-Fi shares many traits with mobile broadband
standards such as LTE – the dierence is in the original target use cases; Wi-Fi
is primarily a technology for creating local area networks, whereas LTE is a
commercial-grade technology for mobile network operators. As often happens
in active technology markets, lines have blurred between these competing
technologies as each seeks to dominate the market. Vendors extended Wi-Fi
capabilities to meet the needs of commercial and enterprise customers, and
Private LTE seeks to address Wi-Fi’s limitations.
Wi-Fi is great for attachment of nearby semi-stationary devices, but unlike LTE, it
does not work well when the device is moving quickly. This is because the Wi-Fi
standard does not provide a mechanism (a process known as hando) to shift a
In addition to
densication via
HetNets, carriers are
addressing rising
user demand and
limited spectrum by
implementing other
capacity-increasing
strategies, including
a technique
called “ooad.
22 Bridging the Gap: 21st Century Wireless Telecommunications Handbook - Second Edition
device’s connection to another access point when the signal becomes weak, and
because Wi-Fi uses unlicensed bands its power is limited and thus the range of
an unmodied Wi-Fi access point is about 250 – 300 meters. Wi-Fi originated as
an extension of Ethernet, so it handles security and authentication in a similar
manner, meaning it lacks:
Standard methods for centralized authentication (user or device onboarding is
typically done via the device itself);
Reliable methods for ensuring security of data transmitted over the network;
Standard methods for hando (i.e. “roaming”) between access points; and
Standard methods for handling congestion avoidance, spectrum/channel
steering, and resource allocations.
In the context of an enterprise or public Wi-Fi deployment, these are signicant
drawbacks. Redirection to login pages makes the login process for a guest
Wi-Fi network dicult, and SSID password distribution is not scalable to large
numbers of users. Public Wi-Fi networks often use open SSID congurations
(with no security at all) because this approach does not require an onboarding
and passcode publication process. When used in a public Wi-Fi network, open
SSID can expose users to attack, although to accomplish an attack requires
sophisticated methods (GCTC Public Wi-Fi Blueprint, 2017). Even with SSID
passwords, as of 2019 all Wi-Fi security protocols are subject to known attack
methods.
Lack of hando/roaming is another issue. Per the IEEE 802.11 standard, and
unlike LTE, the client is in control of any Wi-Fi connections. A Wi-Fi client will
try to retain connection with an access point until the connection becomes
completely unusable, at which point the client will begin to seek connection
via another access point. This “fail before x” use model can be problematic in
mission-critical applications such as Wi-Fi Calling and video conferencing where
even short outages are not acceptable. Enterprise Wi-Fi vendors typically provide
tools for setting hando thresholds to force roaming between multiple network
nodes, but creating a reasonable hando experience requires testing and
manual adjustment.
Likewise, congestion avoidance and spectrum/channel steering are important
for mission-critical use cases, but Wi-Fi does not natively support them.
Enterprise Wi-Fi vendors have worked around some of these limitations in their
enterprise controllers, but not all vendor workarounds are interoperable – the
workarounds are fully functional within the “walled garden” of a single vendor’s
system, but another vendor’s access points may not be able to take advantage of
the controller vendor’s enhancements.
Wi-Fi benets from a zero cost of acquisition – nearly all computing devices
include Wi-Fi radios as standard equipment. Eorts are underway to extend Wi-Fi
23
Bridging the Gap: 21st Century Wireless Telecommunications Handbook - Second Edition
with enhancements for higher throughput, higher eciency channel usage,
more accurate positioning, broadcast, faster wake-up, and even Wi-Fi using
light (so-called “Li-Fi” technology) instead of radio frequencies. We expect nal
approval in mid-2020 of the next-generation IEEE 802.11ax standard, marketed
under the trademark “Wi-Fi 6” name. Additionally, there are eorts underway
at the FCC to reallocate spectrum in the 6 GHz band to unlicensed use, which
would be a benet to users of the already crowded Wi-Fi bands. However, there
are concerns that unlicensed use of the 6 GHz band will cause interference to
existing point-to-point microwave links.
LTE Unlicensed
In an eort to secure additional spectrum with limited funds, mobile operators
are moving forward with deployment of LTE Unlicensed (LTE-U) technologies,
which is an ooad technique that uses LTE signals in unlicensed bands. LTE-U is
attractive to network operators because it is purely LTE; there are no spectrum
auction costs to the operator, and use of unlicensed spectrum requires no license
application. The LTE standard natively handles hando and roaming. However
because the spectrum is unlicensed the operators have no ownership rights, so
if an LTE-U system experiences interference from another system the operators
must work out their dierences privately or resolve the problem through other
means.
There are in fact multiple variants of LTE-U. The original LTE-U did not have
a method for detecting the existence of other signals such as Wi-Fi in the
unlicensed band, and this created a problem because European regulations
require implementation of co-existence methods in shared spectrum. After
a major controversy and debate between the mobile operators and the Wi-Fi
industry players, a second method called License Assisted Access (LAA) was
developed and standardized via 3GPP. LAA implements methods to help it
co-exist with other unlicensed technologies. As of 2019, the question of whether
LTE-U can politely co-exist with Wi-Fi in crowded unlicensed spectrum remains
unresolved.
CBRS
In April 2015, the FCC created the Citizens Broadband Radio Service (CBRS), a 150
MHz allocation in the 3.5 GHz band intended for use by Small Cell equipment.
CBRS uses a three-tiered spectrum authorization framework to accommodate
a variety of governmental, commercial, and private uses on a shared basis.
Sometimes called “Private LTE”, CBRS brings elements of 4G and 5G together
with an unlicensed spectrum access model. The CBRS Alliance handles CBRS
certication, trademarked under the “OnGo” brand. Permission to access
spectrum in the CBRS band will be managed by an automated frequency
24 Bridging the Gap: 21st Century Wireless Telecommunications Handbook - Second Edition
coordinator, known as a Spectrum Access System (SAS), which will coordinate
amongst three tiers of users:
Incumbent Access: U.S federal users (including the U.S. Navy), Fixed Satellite
Service earth stations, and some Wireless Broadband licensees. This user tier
has top priority – all users in other tiers must avoid interference to and vacate
channels used by IA users.
Priority Access: Competitive bidding grants Priority Access License (PAL) users
access to 10 MHz channels on a county-by-county basis for 10 years. PAL users
pay for their access priorities, and have priority over all but IA users.
General Authorized Access: This is the “unlicensed” tier. GAA permits open,
exible access to the CBRS band for the widest possible group of potential
users. Permitted to use any portion of the 3.5 GHz band not assigned to a
higher tier user, GAA users can operate opportunistically on unused Priority
Access channels.
The Spectrum Access System (SAS) governs channel access and priority. CBRS
site equipment regularly queries the SAS to determine what channels are
available, and whether to grant access to a user. The SAS coordinates and
controls the channels used by subscriber equipment. The SAS must monitor for
the presence of Incumbent Access users, and if IA users are detected the SAS
will issue channel-shifting orders to the PAL and GAA clients. Municipalities
considering CBRS deployments should note that both PAL and GAA users must
pay a monthly fee for access to the SAS – so while GAA is unlicensed it is not free
in the same way that Wi-Fi is free.
It will take a few years before we understand the practical realities of CBRS.
The CBRS band will provide a large amount of spectrum for users seeking to
serve user demand, and some analysts believe that CBRS will account for half
of all Small Cell installs by 2023 (Mobile Experts LLC, 2016). For indoor venues,
the cost to deploy a CBRS network can be 30-50% lower than a DAS network
due to advantages in power distribution cabling and the elimination of carrier
equipment.
Figure 11: Fed eral Gove rnme nt tiered str ucture for 3.5 GHz CBRS
Source: Oku Solutions LLC
The CBRS band
will provide a large
amount of spectrum
for users seeking to
serve user demand,
and some analysts
believe that CBRS
will account for
half of all Small Cell
installs by 2023.
25
Bridging the Gap: 21st Century Wireless Telecommunications Handbook - Second Edition
Backhaul is Critical for Wireless Broadband
Backhaul is the term for connections between a wireless site and the operator’s
core network. Every node in a wireless network, from the smallest HetNet
node to the largest macro tower, requires a connection to the carrier’s data
network. For femtocells and picocells in an enterprise in-building deployment,
Ethernet connections over a LAN are used. For Small Cells and DAS, ber
optic connections are used. If neither ber nor Ethernet are available, wireless
connections may be used.
For various reasons, primarily performance and reliability, cellular carriers
prefer ber optic technology for backhaul. There are two kinds of ber optic
networks – lit ber and dark ber. Lit ber describes systems shared between
users, typically via a subscription model. Dark ber describes ber runs leased
solely for one network operator, or installed by a utility provider for later use by
a customer. Mobile network operators want dark ber because it gives them
full control and allows them to ensure the highest levels of service quality. If
dark ber is not available, the carrier will install it – either via aerial runs along
poles, into existing conduit, or via new conduit. Underground construction is
time consuming, expensive, and potentially disruptive to existing underground
systems – so installing conduit for future use during other construction projects
is increasingly popular.
The availability of dark ber and conduit is a key enabler to making the transition
to HetNets and 5G a reality. Network operators will take advantage of available
dark ber and conduit. Conduit and ber are relatively inexpensive to install
when done during other construction projects, and these latent assets are
valuable for future municipal purposes such as business park build-outs, smart
city networks, and providing broadband to residents and businesses.
Wireless backhaul is an emerging technology used where aerial runs or conduits
are not available. These systems use extremely high frequency channels (in the
60 – 70 GHz range) to pass large amounts of data. Due to limitations in how
RF signals behave at these frequencies, designing and deploying a wireless
backhaul network requires a level of engineering sophistication beyond that of
ber optics, and as such in most cases, it remains a more complex solution used
only when ber and conduit are not available.
Wireless Telecom Legislation
Overview & Background
Since the early days of cellular telephony, the federal government has sought
to encourage deployment of a robust nationwide wireless network. The federal
government, recognizing the economic and social benets of that network,
enacted laws that attempt to facilitate and encourage deployment. In some
Backhaul is the term
for connections
between a
wireless site and
the operator’s
core network.
Every node in a
wireless network,
from the smallest
HetNet node to
the largest macro
tower, requires
a connection
to the carrier’s
data network.
26 Bridging the Gap: 21st Century Wireless Telecommunications Handbook - Second Edition
cases, states such as California have encapsulated the federal laws and extended
them. Some may argue that these laws are benecial – others may disagree. The
debate, as is the case in many debates throughout American history, hinges on
striking a balance between local control and federal oversight.
A full treatment of these laws and their application to real-world situations
is beyond our scope, but this handbook provides an overview of the most
consequential legislative and regulatory decisions.
Telecommunications Act of 1996
The Telecommunications Act of 1996 (the “1996 Act”) was the federal
government’s rst attempt to help create a foundation for the wireless
communications revolution we are now experiencing. The 1996 Act contained
provisions concerning the placement of towers and other facilities for use
in providing personal wireless services. Section 704 of the 1996 Act governs
federal, state, and local government oversight for placement and construction
of “personal wireless service” facilities (FCC – New National Wireless Tower Siting
Policies, 1996).
“Personal wireless services” as dened in the 1996 Act included commercial
mobile services, unlicensed wireless services, and common carrier wireless
exchange access services.
Section 332 of the Communications Act, and the FCC’s rules, dene the
“Commercial Mobile Service”, regulated under Part 22 of the FCC’s rules for early
cellular phones. The Personal Communications Service, originally created for
early digital phones (e.g. “Sprint PCS”, “Metro PCS”, etc.), is regulated by Part 24 of
the FCC’s rules (FCC – New National Wireless Tower Siting Policies, 1996).
The 1996 Act states that local governments may not take actions to discriminate
against or outright prohibit (or have the eect of prohibiting) personal wireless
service facilities. It also preempts any local government attempts to regulate on
the environmental eects of RF emissions, and requires local governments to act
“within a reasonable time” on requests to place, construct, or modify personal
wireless service facilities.
Section 332 and the FCC “Shot Clocks”
A problem with the 1996 Act was that it left “reasonable time” open to
interpretation. A wireless carrier seeking to solve a critical coverage problem
might consider approval within 30 days reasonable. A local government
concerned with historical preservation, responding to a citizen opposition
group’s concerns about the health eects of wireless technology, or dealing
with concerns about maintaining local government authority over public
The debate, as is
the case in many
debates throughout
American history,
hinges on striking
a balance between
local control and
federal oversight.
27
Bridging the Gap: 21st Century Wireless Telecommunications Handbook - Second Edition
rights-of-way might consider an application process lasting years to be
reasonable.
In an eort to resolve this, the FCC in 2009 issued a Declaratory Ruling that
90 days is a presumptively reasonable time frame for processing collocation
applications (“collocation” is dened as adding equipment to an existing wireless
facility), and that 150 days is reasonable for anything that is not a collocation
application. The 90- or 150-day time frames are calendar days, including
weekends and holidays, from the date of application ling. Under the FCC’s
regulation, the shot clock governing an application may be paused or “tolled”
by mutual written consent of both the applicant and the local government,
or if the local government noties the applicant in writing (via a Notice of
Incompleteness or “NOI”) that the application is incomplete. Section 332 imposes
several requirements on local government if issuing a Notice of Incompleteness:
The NOI must specify the code provision, ordinance or publicly stated
procedures that require the missing information to be submitted;
The NOI cannot impose new application requirements;
Supplemental NOIs issued against NOI responses must be based on the
original NOI.
Section 6409(a) of the Spectrum Act 2012
The Middle Class Tax Relief and Job Creation Act of 2012 made provisions in Title
VI that expedite the availability of spectrum for commercial mobile broadband.
The provisions in Title VI – also known as the Public Safety and Spectrum Act
(the “Spectrum Act”) contained legislation known as Section 6409(a) that further
claries how the local governments must respond to applications governed by
the 1996 Act and the FCC’s Shot Clocks. Section 6409(a) also adds a requirement
to approve minor modications on existing “eligible facilities” within 60 days;
however, this applies only to an “eligible facilities request” (Congressional
Research Service, 2014).
Section 6409(a) denes an “eligible facilities request” as any request to modify
an existing cell tower or base station that involves collocating new transmission
equipment; removing transmission equipment; or replacing transmission
equipment. These modications could include changes that increase the width
or girth, but do not “substantially change” the height of a wireless facility, i.e., a
tower or monopole.
Section 6409(a) does several things in relation to the 1996 Act and the Shot
Clocks. First, it says that the Shot Clock applies regardless of any local moratoria.
Second, the date of application starts the Shot Clock, not the deemed complete
date. Tolling the Shot Clock happens only after the local government noties
the applicant within a specied time that the application is incomplete, and
the Notice of Incompleteness must “specify the code provision, ordinance,
The Middle Class
Tax Relief and Job
Creation Act of 2012
made provisions in
Title VI that expedite
the availability
of spectrum for
commercial mobile
broadband.
28 Bridging the Gap: 21st Century Wireless Telecommunications Handbook - Second Edition
application instruction, or otherwise publically stated procedures that require
the information to be submitted.” Under Section 6409(a), any decision to deny a
personal wireless service facility application must be in writing, and the denial
must include substantial evidence for denial in a written record.
For many local governments, Section 6409(a) creates a key and critical issue
because they have not created codes, ordinances, instructions, and procedures
for managing modern wireless facility applications. This is especially true
for HetNet (DAS and Small Cell) technologies, which are fundamentally very
dierent from the applications for large macro towers that local governments
have managed in the past. Smaller communities that have relied on wireless
signals from adjacent towns or wireless facilities on private property will likely
be faced with applications to install DAS and Small Cell facilities on utility
poles or in the public right-of-way – and many are not prepared to respond to
applications for large numbers of sites. Regardless of their readiness, the day of
submission will start the Shot Clock. Local governments should begin preparing
now to respond by adopting ordinances, updating codes, and creating Master
Lease Agreements to cover the growing use of HetNet facilities in the public
right-of-way.
California Assembly Bill 57
For California’s local governments, there is an additional twist to the Section
6409(a) and Shot Clock story. In October 2015, the California state legislature
passed AB 57, which further limits the ability of local governments to apply
discretion in approval of wireless service facilities. Following the “Deemed
Approved” approach of California’s Permit Streamlining Act, a wireless facility
subject to Section 6409(a) that is an “eligible facility” and has not been justiably
denied is “deemed approved” if the applicable FCC Shot Clock runs out. (AB-57’s
Shot Clocks are 150 days for new installations, and 90 days for co-locations.)
Unlike under the Permit Streamlining Act, AB 57 does not allow the Shot Clock
to be paused due to delays in conducting a complex environmental review
under the California Environmental Quality Act (CEQA). This means that local
governments should be prepared for these applications well in advance, and be
prepared to act on applications in a timely manner, or risk lawsuits for failing to
respond under the law.
It is important to note that AB 57 has a few exception cases. It does not apply:
To actions by the California Coastal Commission or other state review agencies
such as the San Francisco Bay Conservation and Development Commission;
To City/Town properties such as parks and city-managed campuses; or
To facilities at re stations.
In October 2015,
the California state
legislature passed
AB 57, which
further limits the
ability of local
governments to
apply discretion in
approval of wireless
service facilities.
29
Bridging the Gap: 21st Century Wireless Telecommunications Handbook - Second Edition
CPUC Rulemaking 14-05-001
In 1998, the California Public Utilities Commission’s Decision D.98-10-058
provided competitive local exchange carriers and cable television providers
with nondiscriminatory access to public utility infrastructure. CPUC Rulemaking
14-05-001 included Decision D.16-01-046 providing commercial mobile radio
service (CMRS) carriers with the same nondiscriminatory access. The rulemaking
amends most right-of-way rules in D.98-10-058 to apply to CMRS and adopted
CMRS-specic pole-attachment fees. It also amends General Order (GO) 95 to
ensure that CMRS pole installations are safe, and leaves certain other issues open
to later decisions (CPUC R14-05-001, 2016).
For a period, the outcome of this ruling resulted in a large number of requests
to install Small Cell antennas on utility poles, because many municipalities
were either not ready or not willing to accept Small Cell applications. Because
these utility pole installations are private property transactions, many municipal
attorneys have determined that they can only enforce GO-95 compliance, but
cannot enforce aesthetic requirements on utility sites.
Figure 12: Integrated poles make g ood Small Cell sites.
FCC Small Cell Order 18-133
In September 2018, the FCC issued a “Declaratory Ruling And Third Report And
Order” related to 4G Small Cell and 5G siting. The Order asserts a national interest
in deployment of wireless technologies, and sets forth several items intended to
streamline processing and approvals. The Small Cell Order:
30 Bridging the Gap: 21st Century Wireless Telecommunications Handbook - Second Edition
Requires municipalities to create ministerial processes for approval;
Denes a new standard for “Eective Prohibition”;
Requires cost-based rates for leases and applications, and denes “Safe Harbor”
rates if those costs are not known or not calculable;
Denes a new aesthetics standard, denes a “Small Cell” facility, and requires
that aesthetic guidelines be published in advance;
Creates new 60-day and 90-day Shot Clocks.
On the topic of “Eective Prohibition”, the Small Cell Order asserts itself as the
primary standard for preemption of local permitting processes, and any state
and local policies that aect competition. It removes the requirement that an
applicant must prove a “signicant gap” in coverage to justify an application, and
states that action at the municipal level cannot “materially inhibit or impede” a
carrier’s ability to compete.
The Small Cell Order requires cost-based rates for site leases and application fees.
If costs cannot be determined, the Order denes a presumptive rate of $270/year
per pole for leases, and application fees of $500 for ve small cells.
The FCC also adopted a new three-part test for municipal aesthetic review
of small cells. Aesthetic requirements must be (1) reasonable, (2) no more
burdensome than those applied to other types of infrastructure deployments,
and (3) objective and published in advance. The Order also requires that
municipal requirements be technically feasible – for example, a municipality may
not require underground installation of Small Cell antennas, because it is not
technically feasible.
Finally, the Small Cell Order denes new Shot Clocks: a 60-day Shot Clock for
small cells on existing structures, and a 90-day Shot Clock for new poles. The
Order requires a single Shot Clock for all authorizations including zoning,
encroachment/excavation, trac, etc. (FCC, 2018).
Appeal of the FCC Small Cell Order
A coalition of local governments originally brought a challenge to the FCC Small
Cell Order in the 10th Circuit Court of Appeals. The plaintis prevailed in a motion
to move the case to the 9th Circuit Court of Appeals, and as of October 2019, the
FCC Small Cell Order is in litigation. Oral arguments are scheduled for February
2020, but there is no way to estimate a date for ruling.
We also note that the 10th Circuit court did not grant the appellant’s request for
stay of the Order, so it is presumptively in eect at this time and municipalities
not in compliance may encounter legal challenges.
31
Bridging the Gap: 21st Century Wireless Telecommunications Handbook - Second Edition
Addressing Common Public Concerns
Regarding Wireless
Overview and Scope of Authority
Within the connes of existing law and regulation, municipal governments can
exercise control over the “time, place, and manner” in which wireless facilities
are deployed. In addition, the California Supreme Court ruled that municipalities
could exercise control over aesthetics of wireless facilities deployed in the public
right of way (T-Mobile West LLC v. City & County of San Francisco, 2019).
During the application and review process for wireless facilities, municipal
governments – and especially elected ocials – are often in a dicult situation.
While they must respond to constituent concerns, they are also constrained
by federal regulations that prevents denying permits based on some type
of constituent concerns. Failure to adhere to these regulations opens the
municipality to possible legal action from the wireless industry, but failure to
respond to constituent concerns leaves elected ocials open to challenges at
the ballot box. It is critical that municipal governments clearly communicate
to constituents the scope of their authority in these situations. Under federal
regulations concerns about real estate valuations or health eects are not
acceptable reasons for denying a permit – despite how the public may feel about
them.
Real Estate Impacts of Cell Sites
During public hearings about proposed cellular projects, or consideration of
Master Lease Agreements, a claim is sometimes made that proximity to cellular
sites can result in up to a 20% reduction in real estate valuation of nearby homes.
Often cited as “known fact”, this claim is actually an urban legend passed around
in the real estate community, often without attribution to a source. Looking
at the source of the claim is revealing; the assertion comes from an article
published in the Appraiser’s Journal (Summer 2005 edition) written by Sandy
Bond and Ko-Kang Wang in response to concerns about a 120-foot cell tower
under consideration in New Zealand. The authors used a case-study survey
approach in and around Christchurch, NZ. The problems with this approach
cannot be overstated; survey bias, recall bias, audience bias, and a host of
other issues certainly aected the results. Furthermore, the behavior of New
Zealanders in response to a 120-foot tower site does not necessarily indicate the
behavior of U.S. buyers near smaller, concealed, or lower-power sites.
In contrast, Joint Venture Silicon Valley published a real estate impacts report in
2012 based on an objective source; Multiple Listing Service (MLS) transaction
data. The report showed no correlation between proximity to cellular sites
and real estate valuations. Compiled using over 1,600 single-family home
The report showed
no correlation
between proximity
to cellular sites
and real estate
valuations.
Within the connes
of existing law
and regulation,
municipal
governments can
exercise control over
the “time, place, and
manner” in which
wireless facilities
are deployed.
32 Bridging the Gap: 21st Century Wireless Telecommunications Handbook - Second Edition
transactions, the data set spans January to September 2012 and accounts for
sales near 70 wireless sites in Palo Alto, Redwood City, Saratoga, and San Jose.
The survey compared the “list” and “sale” price for transactions based on the
distance from the sites, grouped by distance from the selected sites; (1) within
an eighth of a mile, (2) an eighth to a quarter of a mile, and (3) a quarter to a half
of a mile. In addition, the study included all types of wireless sites; (a) a cellular
tower, (b) cellular equipment placed on buildings (e.g. churches, oce buildings,
etc.), and (c) placed on a utility structure (e.g. electrical poles, transmission
towers, etc.) (Joint Venture Silicon Valley, 2012).
To our knowledge, there is no other validated study of this type – and thus no
scientic or economic basis for the claim that cellular sites have an adverse eect
on real estate valuations. It is also important to consider generational eects on
real estate valuation. Starting in 2018, income distribution by generational group
has shifted away from Baby Boomers to Generation X’ers and Millennials. Both
of these groups are very connected and communications-dependent, and their
preferred connection method is cellular service.
RF Safety of Wireless
Concerns about aesthetics and real estate valuation are often proxies for
concerns about health eects. To date there has not been a conclusive study
linking RF radiation to cancer. The World Health Organization (WHO) classied
electromagnetic elds (EMF) emitted by wireless devices as a possible
carcinogen, which does not mean it is a probable or known carcinogen. The
WHO also classies smoke from wood res, red meat, pickles, and even drinking
very hot liquids as possible carcinogens.
The rst studies on health eects of electromagnetic elds started in the 1950s,
and literally thousands of studies since then have found no adverse health
eects at RF exposure levels below those dened by current published safety
standards. Far fewer studies (a few hundred) have claimed to nd health eects,
and those studies were either inconclusive or were invalidated when subsequent
studies failed to reproduce the claimed results.
Reproducibility is a key requirement of proper scientic and medical research.
For example, when cellular sites were rst being deployed in the 1990s, some
smaller studies (using sample sizes of about 1,000 subjects) in Sweden and
France suggested that EMF might cause brain cancer, but follow-up studies
failed to reproduce those ndings. Studies with larger samples (using tens of
thousands of subjects across thirteen countries) found no link between RF and
cancer. It is also important to note that nearly all EMF health studies focus on
impacts from cellular handsets, which due to distance eects have a greater
impact on the human body than cellular sites.
The rst studies on
health eects of
electromagnetic
elds started in the
1950s, and literally
thousands of studies
since then have
found no adverse
health eects at
RF exposure levels
below current public
safety standards.
33
Bridging the Gap: 21st Century Wireless Telecommunications Handbook - Second Edition
Figure 13: Electromagne tic Spectrum & RF Uses
Source: Hammett & Edison, Inc.
NIH NTP Rodent Study
A study completed in 2018 by the U.S. National Toxicology Program (often
referred to as the “NTP rodent study”) studied the risk of cancer from cellular
handsets, not cellular sites, although opposition groups often cite the NTP
rodent study as evidence during site permit and planning hearings. The NTP
rodent study claimed to nd some limited evidence of cancer risk in power
levels from handsets, but the results were inconclusive, and there were several
unexplained issues with the study animals. The Ramazzini Institute’s study
(Falcioni et al., 2018) claimed to reproduce the NTP rodent study results, but the
International Commission on Non-Ionizing Radiation Protection (ICNIRP) found
signicant issues with both studies (ICNIRP, Health Physics Society, 2019).
Reviews of the NTP rodent study results and methodologies have found aws:
The study only showed eects in male rats – not female rats, not in male or
female mice – and no mechanism has been proposed to account for variance
in both species and gender.
34 Bridging the Gap: 21st Century Wireless Telecommunications Handbook - Second Edition
The EMF-exposed male rats actually lived longer than the control group, and
the control group rats (for an unknown reason) had signicantly shorter
lifespans relative to historical control rats.
The control group male rats had a statistically low incidence of naturally
occurring tumors. Statistically speaking, if even one of the control group’s male
rats had developed a naturally occurring tumor, the inferred link between EMF
and cancer in the exposed male rats would have become meaningless.
The study exposed the rodents to power levels at or above those experienced
by humans using cellular handsets. The exposure was over the rat’s entire
body instead of just the head, hand, or other limited areas. The EMF eld
generator cycled on and o every 10 minutes, for 18 hours each day, over the
entire life of the rodent. These conditions are very dierent from the exposures
experienced by humans using handsets in daily life.
The NTP rodent study used RF power levels at or above those generated from
handsets. Handsets generate far greater EMF impacts to the human body than
cellular sites, because the major factor in determining the EMF exposure level
on humans is the distance between a person and the antenna. Unless you
have climbed up a tower and are literally leaning your head against the cell
site’s antennas, the levels of RF energy aecting you from cell sites are tens of
thousands or millions of times lower than handsets.
After publication of the NTP rodent study, the International Commission on
Non-Ionizing Radiation Protection (a group of scientic and technical experts
that produce recommendations on safe RF exposure levels) reviewed the study
results and methodologies. In response, they stated, “ICNIRP considers that the
NTP (2018a, b) and Falcioni et al. (2018) studies do not provide a consistent,
reliable and generalizable body of evidence that can be used as a basis for
revising current human exposure guidelines. Further research is required
that addresses the above limitations. Further, in 2019 they stated, “The NTP’s
outlying nding is further complicated by important methodological limitations
including the eect of the greater lifespans of the exposed rats on the statistical
analyses, lack of blinding in the pathological analyses, and a failure to account
suciently for chance in the statistical analyses. Collectively these two studies’
limitations preclude drawing conclusions about carcinogenicity in relation to RF
EMF.” (ICNIRP, 2019).
Self-proclaimed “EMF Safety Experts” ignore the math and physics of the NTP,
Ramazzini, and other inconclusive studies to create false equivalencies through
inference, supposition, and quote mining. Many of these “experts” run websites
and businesses that sell products intended to either support and iname
fears (EMF meters and detectors), supposedly reduce RF exposure (low-EMF
appliances and EMF shielding products), or perpetuate propaganda via books
and videos.
35
Bridging the Gap: 21st Century Wireless Telecommunications Handbook - Second Edition
Setting aside the problematic NTP and Ramazzini studies, we note that data from
the National Cancer Institute (National Institutes of Health, U.S. Department of
Health and Human Services) shows that both incidence and mortality of brain
cancer has gone down since the mid-1990s, during the same period when
society’s use of wireless devices and sites increased exponentially. This fact alone
casts serious doubts about the possibility of a causal relationship between EMFs
and cancer. In other words – despite a massive increase in quantity and use of
wireless devices over the past two decades, we are not seeing a commensurate
increase in the kinds of cancers people commonly associate with RF exposure
(National Cancer Institute, 2019).
Figure 14: Cell phone usage d oes not correlate to cancer incid ence
Source: www.xkcd.com (Creative Commons A-NC 2.5)
Danish Cohort Study
The Danish Cohort Study is to date the world’s largest study on mobile phones
and cancer in the human population. Countries such as Denmark, because of
their high mobile phone use and comprehensive social and medical databases,
oer a source and quality of information that is not available elsewhere.
All Danes have a “Social Security” number, what they call a “CPR” number,
assigned at birth. Danish mobile phone carriers are link subscriber contracts
to the subscriber’s CPR number. The Danish National Cancer Registry tracks all
patients – noting the type of cancer and the CPR number of the patient. Thus,
the whole population of Denmark is both a subject and control group, because
individuals are searchable by their mobile phone numbers and their CPR
number. An independent organization, the Danish Cancer Society (comprised of
more than 400,000 members, 45,000 volunteers, and 690 full-time employees)
conducted the studies using these data sets.
The Danish Cohort study has two important methodological advantages over
most other studies. Firstly, it passively followed a computerized cohort of
subjects via the Danish registries, and in doing so avoided the need to contact
people. Consequently, it eliminated the problems of non-response and self-
selection – which has been of considerable concern in studies with other
designs. Secondly, it used digitized subscriber data obtained from the mobile
In other words –
despite a massive
increase in quantity
and use of wireless
devices over the
past two decades,
we are not seeing
a commensurate
increase in the kinds
of cancers people
commonly associate
with RF exposure.
36 Bridging the Gap: 21st Century Wireless Telecommunications Handbook - Second Edition
operators, rather than retrospective questionnaires or interview information
obtained from users – eliminating survey and recall biases. Results from the
Danish Cohort Study are denitive, and have successfully passed through several
layers of academic review (BfS, Danish Cohort Study, 2011). Here are the four key
documents:
Use of mobile phones and risk of brain tumors: update of Danish
cohort study.
http://bit.ly/1_BMJ_2011
Participants: All Danes aged ≥30 and born in Denmark after 1925, subdivided
into subscribers and non-subscribers of mobile phones before 1995.
Main outcome measures risk of tumors of the central nervous system,
identied from the complete Danish Cancer Registry. Analysis conducted on
358,403 subscribers who accrued 3.8 million person-years of mobile phone
ownership.
Conclusion: In this update of a large nationwide cohort study of mobile phone
use, there were no increased risks of tumors of the central nervous system,
providing little evidence for a causal association.
Mobile Phone Use and Brain Tumors in Children and Adolescents:
A Multicenter Case–Control Study.
http://bit.ly/2_JCNI_2011
There is a hypothesis that children and adolescents might be more vulnerable
to possible health eects from mobile phone exposure compared to adults.
This study investigated whether mobile phone use is associated with brain
tumor risk among children and adolescents.
Conclusion: The absence either of an exposure–response relationship in terms
of the amount of mobile phone use, or by localization of the brain tumor,
argues against a causal association.
Mobile telephones and brain tumors Evidence is reassuring, but
continued monitoring of health registers and prospective cohorts is
still warranted.
http://bit.ly/3_BMJ_2011
In the linked cohort study, Frei and colleagues found no evidence that the
risk of brain tumors was raised in 358,403 Danish mobile phone subscribers.
This was also true when the cohort was restricted to people who had been
subscribing for more than 10 years, when glioma and meningioma were
analyzed separately, and when tumors in the anatomical region closest to the
handset were analyzed.
37
Bridging the Gap: 21st Century Wireless Telecommunications Handbook - Second Edition
Possible relationship between use of mobile phones and the risk of
cancer: Questions and Answers.
http://bit.ly/hjernekraeft_2011
Publication sets forth questions and answers intended to address scientic
ndings on the possible relationship between use of mobile phones and the
risk of cancer into a broader context.
Fears of New Technology
Every time there is a new generation of technology, wireless or otherwise,
concerns arise that it will be somehow more dangerous than before; 2G was
claimed to be more dangerous than 1G, 3G was going to be worse than 2G, etc.
Today, people are afraid of 5G. We can see the same pattern throughout history:
Starting in the late 19th century and continuing until the 1930s, people feared
electricity and incandescent lighting. Then uorescent light was feared because
it was dierent (and supposedly more dangerous) than incandescent light.
Today, we are seeing sensationalized articles about purported dangers from LED
lighting. Some people will always be prone to fear what is new (L. Simon, 2005).
Updated FCC Guidance on EMF Safety
A criticism levied by opponents of cellular deployments is that the FCC guidance
on electromagnetic safety has not changed since 1996. This is true - because the
underlying science and physics have not changed. The FCC’s guidance from 1996
is as applicable to the upcoming fth-generation “5G” technologies as it was to
the original analog “1G” cellular phones carried by our parents. However, because
5G will operate in millimeter wave bands, there is a need to extend the guidance
to higher frequencies.
Regulatory agencies like the FCC do not directly conduct scientic and medical
investigations – they rely on the expertise of government agencies like the
Center for Devices and Radiological Health at the Food and Drug Administration
(FDA); the Environmental Protection Agency, the National Institutes for Health,
the World Health Organization, and scientic organizations like the National
Council on Radiation Protection and Measurements (NCRP) and the Institute of
Electrical and Electronics Engineers (IEEE). When the FCC last revised their RF
exposure rules in 1996, they followed the recommendations of the EPA and FDA,
and used the recommendations made in NCRP Report 85 and some provisions
of IEEE C95.1 standard published in 1992. The documents reected the current
understanding of biological eects of RF energy and new technical insights into
how RF energy is absorbed by the human body.
While the NCRP is a Congressionally chartered organization and only updates
reports at the request of one or more of the Federal agencies or departments,
the IEEE is required to periodically update all of their standards including
Every time there is
a new generation of
technology, wireless
or otherwise,
concerns arise that
it will be somehow
more dangerous
than before...
38 Bridging the Gap: 21st Century Wireless Telecommunications Handbook - Second Edition
C95.1, and has done so several times since 1992. While there have been some
clarications and additions to the standard, the basis of the safety standard
has remained the same – and thus the FCC’s safety guidance has not materially
changed. In December 2019, the FCC issued a ruling and notice of proposed
rulemaking that updates further safety guidance based on the latest IEEE C95.1-
2019 standard, and which accounts for other medical ndings and research since
the previous version (FCC 19-126, 2019).
In conclusion, it is important to note that we are not saying that the science is
settled on the question of electromagnetic safety – because good science is
never settled. Although thousands of studies have found no health eects from
cellular signals, some have reported inconclusive ndings, and we believe it
is important that researchers attempt to reproduce those ndings. Given the
exponential rise in our use and deployment of wireless facilities, we should
expect that the medical community, academia, and government agencies tasked
with human health and the public good will continue to investigate the eects
of electromagnetic energy on the human body.
Wireless Telecom Roadmap – What Does e
Future Hold?
Increased Deployment of HetNets
For the reasons previously outlined in this handbook, local governments should
expect applications for both 4G and 5G Small Cell facilities to increase, especially
on utility poles in the public right-of-way. HetNet technologies provide the best
opportunity for carriers to make the most ecient use of limited RF spectrum in
the face of exponential growth in mobile data usage, and Small Cell technology
is a key component in deployment strategies for all wireless carriers. The shorter
range of millimeter wave signals means that 5G sites in those bands must be
spaced closely together, driving up the number of applications and increasing
the possibility of resident objections.
LTE Unlicensed
Local governments, especially those that have deployed – or are considering
deployment of – Wi-Fi networks in the 5 GHz band should closely monitor
the trials and co-existence tests of LTE-Unlicensed. We do not yet know
how well Wi-Fi and LTE-U will behave in large-scale real-world deployments,
and procedures for how to test for and mitigate interference are still under
development.
In December 2019,
the FCC issued a
ruling and notice
of proposed
rulemaking that
updates further
safety guidance
based on the latest
IEEE C95.1-2019
standard, and which
accounts for ndings
and research since
the previous version.
39
Bridging the Gap: 21st Century Wireless Telecommunications Handbook - Second Edition
Wi-Fi Carriers & Voice-over-Wi-Fi
Since 2016, we have seen limited growth in the use of Wi-Fi networks as an
alternative to traditional mobile carriers. Subscribers to these Wi-Fi First” plans
use phones that seek out Wi-Fi as a preferred network for both voice and data,
only falling back to cellular when necessary. As of 2019, the primary vendors for
this model are Comcast’s “Xnity Mobile” oering, and Google’s “Fi” service.
CBRS, Private LTE, and Private 5G
These technologies present some very interesting opportunities for both private
and public entities to deploy next-generation wireless networks. Unlike Wi-Fi,
which is very good for local area networks and enterprise deployments but does
not scale well to wide area networks and public infrastructure, private cellular
networks may be a better path towards creating scalable networks for large
numbers of users.
Dedicated IoT Networks
Competing with Wi-Fi and mobile data networks for IoT are several proprietary
standards, collectively known as Low Power Wide Area (LPWA) systems. Designed
specically for IoT applications, LPWA technologies oer low power consumption
over long distance links, which are often a key design criterion for IoT systems.
The downside is that in many locations, the networks do not yet exist, so siting
and permitting eorts will be required. In most cases, LPWA facilities are small,
with equipment cabinets less than 12 cubic feet and antennas about three feet
long, and thus have minimal aesthetic eect. Local governments should consider
implementing streamlined review processes for LPWA equipment and sites.
FirstNet – LTE for Public Safety
The Spectrum Act of 2012 contained legislation and funding for a nationwide
LTE network dedicated for use by public safety and First Responders, now called
FirstNet™. AT&T won the RFP bid to build FirstNet, and the process of building
the network has already started. We believe that FirstNet will create a unique
challenge for local governments, because the needs of public safety coverage
will dictate the locations of FirstNet’s wireless facilities. Local governments that
have enacted full or partial moratoriums on wireless facilities will likely nd
themselves forced to approve a FirstNet site, lest they risk denying public safety
the resources they need.
FirstNet technology will look very much like the existing wireless networks, and
will use the same HetNet architectures to provide wide-area coverage from large
40 Bridging the Gap: 21st Century Wireless Telecommunications Handbook - Second Edition
macro towers, combined with DAS and Small Cell equipment to provide speed
and spectrum eciency in dense populated or hard to cover areas.
Recommendations for Municipal Governments
Understand and Adapt to New Telecom Legislation
Local governments must carefully consider and prepare for responses to wireless
facility applications given the complexities of the FCC Small Cell Order, Section
6409(a), and state laws such as California’s AB 57. The alternative is a possible
lawsuit, which nobody wants and only serves to suppress cooperation on
the shared goal of building critical wireless infrastructure. Local governments
must be diligent about creating tools such as a comprehensive pre-application
checklist, aesthetic guidelines, and publishing clear application instructions that
“specify the code provision, ordinance, application instruction, or otherwise
publically-stated procedures that require the information to be submitted.
(Section 6409(a), Spectrum Act of 2012).
At a minimum, local governments should determine if their existing codes and
ordinances address wireless facilities in the public right-of-way – and should
quickly take action to remedy if they do not. Due to the unique nature of HetNet
facilities, these new codes and ordinances should be separate from any existing
ordinances that pertain to large macro towers and equipment.
Recognize the Societal Value of Wireless Broadband
The economics of the Digital Divide are plain and striking – internet use by
households below $75,000 median income drops o exponentially (White House
Council of Economic Advisors, 2016). Elementary and secondary school teachers
are increasingly requiring students to complete and submit work online via
cloud-based tools such as Oce 365™ and Google Docs™. Wireless is increasingly
the sole method of internet access for low-income households (McHenry, 2016).
How will children of low-income families compete without access to broadband?
Access to wireless broadband is critical, and both governments and carriers have
a shared social responsibility to ensure equitable access for all residents.
Local governments
must carefully
consider and
prepare for
responses to
wireless facility
applications given
the complexities
of the FCC Small
Cell Order, Section
6409(a), and
state laws such as
California’s AB 57.
41
Bridging the Gap: 21st Century Wireless Telecommunications Handbook - Second Edition
In 2016, the California Emerging Technology Fund (CETF) published a survey
of the state’s Digital Divide (CETF, 2016). Almost three out of four (74%) survey
respondents cited costs of access or equipment as their reason for not having
broadband access. The 2016 survey found broadband adoption rates well below
the overall state average of 84% for:
Households earning less than $22,000 (68%)
Adults 65 or older (56%)
Spanish-speaking Latinos (69%)
Not a high school graduate (63%)
Adults who identify as having a disability (71%)
A Pew Research report from 2019 shows similar results. Pew reported that for
37% of American adults, their online activity is primarily via a smartphone. This
number rises to 58% for people aged 18-29, and 47% for people aged 30-49.
These numbers are increasing annually across all age groups; in 2013, only 2% of
people over age 65 primarily accessed the internet via smartphones – in 2019,
that expanded to 15% for the same age group – a seven-fold increase over six
years.
In the past, the thinking was that mobile users are demographically auent
– the stereotypical multi-tasking businessperson with a smartphone – but
today’s reality is otherwise. Mobile devices have replaced laptops and PCs
in many homes. Families in poverty, unable to aord both mobile data and
wired broadband, often opt for mobile data only. Wireless telecom and mobile
broadband are not luxuries for the wealthy - they are critical systems for all
residents struggling to keep up with (or join) the 21st century. Fast reliable
wireless broadband coverage is not a convenience for the privileged few – it is
a vital resource for daily life preferred by a majority of our country’s residents.
Some municipal governments view telecom projects as an opportunity to
increase revenue, which is misguided. Municipal governments need to view
communication networks no dierently than water or electricity projects, and
they should consider legitimate requests for safe and aesthetically reasonable
communication equipment projects not as a revenue source, but as an
opportunity to secure private sector investment in infrastructure that improves
our quality of life and helps bridge the Digital Divide.
Install Conduit, Adopt Dig Once Policies, and Allow
Micro-Trenching
The rate at which we consume digital data shows no signs of slowing down.
The best technology for carrying large amounts of data is ber optics. Installing
conduit at every opportunity is an inexpensive way to invest in our future, and
42 Bridging the Gap: 21st Century Wireless Telecommunications Handbook - Second Edition
conduit installed should be oversized and doubled-up whenever possible to
facilitate future growth.
Local governments should create “Dig Once” policies that encourage conduit
installation, and should create “Opportunity Alert Systems” that notify wired
and wireless telecommunication companies when permits are issued for
underground work that could allow conduit to be installed. Local governments
should also create codes and ordinances that allow for “Micro-Trenching” – a less
disruptive installation process that allows ber to be deployed using exible
ducts laid into a saw-cut just over one inch wide (Broadband Properties, 2019).
Stay Informed and Educated
Wireless communications is a complex topic, and it is constantly changing.
People who have spent their careers in the eld struggle to keep up. There is no
dishonor in admitting the need for help, and municipalities should hire or retain
good sources of information and support to help guide strategy and tactics.
Adding wireless expertise to municipal sta, either by hiring or by contracting,
is necessary given the highly technical and rapidly evolving nature of the
technology.
It is important to stay connected with the wireless community. A good way
to do this is to attend local conferences, educational seminars, or by hosting
informational study sessions with your review and hearing bodies. This helps
build a network of contacts that can oer advice and help to understand
technologically feasible options and trade-os.
Unfortunately in many instances a lack of mutual understanding has arisen
between wireless carriers/operators, residents, and municipal governments. This
causes protracted negotiations and permitting processes that take many months
or even years to complete, and delays projects to the point where they become
unprotable or even impossible. Some local governments, acting to appease
objections of residents, have treated applications for wireless facilities with
disdain or even outright hostility.
Education of residents is critical to help move projects forward without excessive
opposition. Municipal government leaders often sit through hours of citizen
objections as to why a site should not be located in a certain spot. Fears of new
technology, concerns over aesthetics, fears about the impact of wireless facilities
on property values, etc. often drive resident objections.
The “not-in-my-back-yard” (NIMBY) perspective, which gives excess weight to
the opinions of a vociferous minority at the expense of the needs of all residents,
has led to circumscription of local control – e.g. we see this happening in zoning
and planning for housing e.g. CA Senate Bill 50, and in telecommunications
legislation and regulation at both the federal and state level. The
Adding wireless
expertise to
municipal sta,
either by hiring or
by contracting, is
necessary given
the highly technical
and rapidly
evolving nature of
the technology.
43
Bridging the Gap: 21st Century Wireless Telecommunications Handbook - Second Edition
telecommunications legislation and rules forces local government to publish
their application criteria up front, not change application criteria in mid-process,
make decisions within a set timeframe on applications, and make decisions on a
reasonable and equitable basis.
The complexities of managing telecom applications and permitting will only
increase as the wireless telecom industry moves towards HetNets architecture,
transitioning from macro towers covering many square miles to densied
networks using small low-power sites covering only a few blocks – often in the
public right-of-way on streetlights, signs, utility poles, and other street furniture.
By approaching these densied networks not as a problem but as a joint
opportunity to improve our region’s networks, we can overcome this challenge
and move forward with new technologies that benet our residents and local
economies.
There is no dishonor in asking for help. Wireless networks are not simple
things. Even senior engineers who have been building wireless networks for
decades struggle to keep up with new technologies. Leaders in all departments
(planning, public works, economic development, real estate, utilities, etc.) should
not be embarrassed to admit what they do not understand, and should bring in
qualied help as needed when sorting out options.
Application Processes, Checklists, Codes and Ordinances
When developing codes, ordinances, instructions, and procedures for handling
wireless facility applications, local governments should be very specic about
what constitutes a “complete application” and be very clear about what must
be contained in a complete application. Ordinances should back up these
requirements, supported by published instructions and procedures in detailed
and specic language. Local governments should publish a wireless facility
pre-application checklist, and publish a clear and comprehensive application
process.
Takeaways for Municipal Leaders
4G Small Cell and 5G applications are coming – if they are not already on your
desk, they will be soon. Ask your Planning and Public Works Directors if they
have a review process in place for wireless facilities in the public right-of-way.
If there is no dened process, work with your City Attorney to create one (or
borrow an example from another city) that meets your needs.
Create specic and detailed aesthetic guidelines, and include these in your
application process. If you do not have an aesthetic guideline, work with your
Planning Commission to create one, or borrow an example from another city.
Education of
residents is critical
to help move
projects forward
without excessive
opposition.
44 Bridging the Gap: 21st Century Wireless Telecommunications Handbook - Second Edition
Inventory your assets. Get a sense of what utility poles, light poles, and conduit
routes your municipality does and does not own. Are certain areas under the
jurisdiction of another government agency?
Reach out. Talk with your local electric utility provider about options for metering
wireless facilities, and ways to avoid the need for bulky electric meters or
disconnect boxes on sidewalks or poles. Electric utilities have rigorous standards
for equipment attached to their networks, so be sure to have this conversation
early on – slow response on the part of a utility will not freeze a Shot Clock.
Educate. Hold an information session for active community groups, as well as
elected leaders and appointed bodies that may have an interest: e.g. Planning
Commissions, Design Review Boards, and Historic Preservation Commissions.
Provide photo examples of DAS and Small Cell sites installed elsewhere. Invite
carrier and utility representatives.
Update Infrastructure. Evaluate whether limited-area micro-trenching can
minimize ber optic deployment costs and reduce the need for major street
trenching activity. This option can benet both cellular providers, wired
broadband and cable TV providers, as well as independent/community-based
internet service providers and government agencies. Also, consider creating
Dig Once policies to expand opportunities to build ber optic infrastructure
over time. Remember that, for the most part, wireless facilities still require
ber optic backhaul. Fiber and conduit are relatively cheap compared to labor
and construction costs, so it is an investment worth making to install ber and
conduit while opening up streets or sidewalks.
Recommendations for Carriers, Operators,
and Utilities
Understand the Complexities of Local Government
Carriers and network operators need to understand that municipal governments
are responsive to all residents, and must balance often-conicting edicts to
move their cities and towns forward in a progressive manner while honoring
and maintaining the area’s local history and heritage. Carriers and network
operators must also recognize that small cell wireless is a relatively new topic
for municipal governments, and so they may not have the sta or expertise to
handle applications.
Communicate Clearly and Credibly With Residents
Carriers and network operators need to communicate well with local residents
and then commit to hearing out their concerns – even if those concerns might
45
Bridging the Gap: 21st Century Wireless Telecommunications Handbook - Second Edition
seem ridiculous or uninformed. They need to credibly and straightforwardly
educate the public about the value of communications, and most importantly
explain the various technologies and their benets in practical and meaningful
terms.
Commit to Bridging the Digital Divide
It is easy and protable to focus deployment resources on higher-income
areas. The harder thing, but the right thing, is to commit to building networks
into underserved areas to help bridge the Digital Divide and protect our most
vulnerable residents. It may be that these networks are less protable, or even
take a small loss, but the goodwill they create will ease tensions and concerns –
which benets everyone.
Work to Build and Maintain Trust
Carriers and network operators need to be hyper-vigilant about ensuring that
the equipment build matches the application and design documentation. They
need to ensure that projects do not include unpermitted modications, consider
the needs of residents and neighborhoods, proactively enforce aesthetic
guidelines on contractors, avoid shoddy workmanship, and do everything
possible to avoid building wireless facilities that conict with architectural or
historical preservation eorts. They should choose and use equipment that is
smaller, quieter, and minimally visible – and always be pushing their component
vendors to develop products that help meet these goals. Communication and
openness with residents and local governments about even small changes are
the keys to building trust – changes slipped in under the radar once discovered
breaks trust, and this gives opposition groups a lot of ammunition to protest
new projects, which is ultimately counter-productive.
Carriers and network
operators need to
be hyper-vigilant
about ensuring
that the equipment
build matches
the application
and design
documentation.
46 Bridging the Gap: 21st Century Wireless Telecommunications Handbook - Second Edition
Glossary of Terms
Term Denition
2G Second generation cellular.
3G Third generation cellular.
4G Fourth generation cellular, an ITU-R denition governed by the IMT-2010 standard.
4G Advanced An update to 4G, governed by the IMT-Advanced standard.
5G Fifth generation cellular, an ITU denition governed by the IMT-2020 standard.
3GPP Third Generation Partnership Project, a standards body.
ANSI American National Standards Institute, a standards body.
ARPU Average Revenue per User, a measure of system revenue relative to the number of users – to be protable,
ARPU must be higher than the total costs of building and maintaining the network.
Backhaul The connection used to link a cellular site to the carrier’s core network.
Bit A single unit of digital information.
Boomers Baby Boomers, the age group of individuals born between 1946 and 1964.
Broadband Data that transfers at minimum speeds of 25 Mbps download, 3 Mbps upload (Per the FCC’s 2015 denition).
Byte A block of 8 bits.
CBRS Citizens Broadband Radio Service, a 3.5 GHz band communications standard for Small Cells, used in the USA.
Cellular A wide-area mobile wireless technology consisting of many sites interoperating as a network, for the purposes
of providing voice and data communications.
CETF California Emerging Technology Fund, a statewide non-prot organization whose mission is to close the digital
divide in California.
Churn A rough metric of the rate at which subscribers change from one carrier to another.
Co-Location The installation of wireless equipment and antennas for multiple technologies and/or competing carriers to a
single tower or wireless facility.
CPUC California Public Utilities Commission, oversees and regulates companies that provide utility services using the
public right of way.
CTIA A trade association representing the wireless communications industry in the United States.
DAS Distributed Antenna System, can be indoor (typically just called DAS) or outdoor (usually called o-DAS).
Dark Fiber Fiber optic cabling which is unused and reserved for future use.
dB Decibel, a unitless ratio of gain or loss.
dBd Decibels of antenna gain relative to a simple dipole antenna.
dBi Decibels of antenna gain relative to a theoretical point-source antenna.
dBm Decibels of power gain or loss relative to a milliwatt of RF energy.
EB Exabyte, 1x1018 bytes.
EIRP Equivalent Isotropically Radiated Power, the product of transmitter power and the antenna gain in a given
direction relative to an isotropic antenna of a radio transmitter.
eMBB Enhanced Mobile Broadband, a 5G use prole primarily focused on handsets and user devices.
EMF Electromagnetic Fields, the combination of time-varying electric and magnetic forces.
ERP Eective Radiated Power, an IEEE standardized denition of RF power, measures the combination of the power
emitted by the transmitter and the ability of the antenna to direct that power in a given direction.
FCC Federal Communications Commission.
FirstNet™ A nationwide network of LTE and 5G, reserved for use by public safety, rst responders, governments, and
critical infrastructure users.
FWA Fixed Wireless Access, a use case of 5G providing broadband service to xed locations.
GAA General Authorized Access, a CBRS user tier.
GB Gigabyte, 1x109 bytes.
Term Denition
GDP Gross Domestic Product, the monetary value of all nished goods and services made during a specic period.
GenX’ers Generation X, the age group of individuals born between 1965 and 1980.
GenZ’ers Generation Z, the age group of individuals born between 1997 and 2012.
GHz Gigahertz, 1x109 hertz.
Gig Economy The economic shift of workers away from full-time long-term employment to transient short-term jobs or “gigs”
– sometimes called the Contractor Economy.
GSMA GSM Association, a trade body that represents the interests of mobile network operators worldwide.
Hando The process by which a wireless voice or data connection is seamlessly transitioned from one site to another.
HetNet Heterogeneous Network, a system of dissimilar wireless technologies operating as a whole.
Hz Hertz (cycles per second), a measure of signal frequency.
IA Incumbent Access, a CBRS user tier.
ICNIRP International Commission on Non-Ionizing Radiation Protection.
IEEE Institute of Electrical and Electronics Engineers, a standards body.
IoT Internet of Things, the connection of stand-alone nodes, systems, and devices to the internet.
IP Internet Protocol, the standard for data communications over the internet.
IT Information technology.
ITU International Telecommunications Union – the technology standardization and coordination arm of the United
Nations.
Lattice Tower A type of communications tower constructed from a lattice of metal sections – can be either guyed (GT) or
self-supporting (SST).
Lit Fiber Fiber optic cabling operated by a company that sells capacity on that ber to multiple users.
LPWA Low Power Wide Area, An Internet of Things communications technology that uses low power, low data rate
communications for devices.
LTE Long Term Evolution, the name for a 4G-compliant radio standard published by 3GPP.
LTE-A LTE Advanced, a higher performance version of LTE.
LTE-LAA LTE-License Assisted Access, a 3GPP-compliant LTE-U technology.
LTE-U LTE-Unlicensed, a technology to carry LTE waveforms over the 5 GHz unlicensed spectrum bands.
Macro Site or Tower A large tower (either guyed or freestanding) which supports communications equipment and antennas.
Mbps Megabits, 1x106 bits per second.
MBps Megabytes, 1x106 bytes per second.
MHz Megahertz, 1x106 hertz.
Millennials The age group of individuals born between 1981 and 1996.
MIMO Massive Multi-Input Multi-Output, an antenna architecture used to focus RF energy towards a receiver.
MMTC Massive Machine-Type Communications, a 5G use prole.
Mobile Economy The exchange of goods and services delivered to consumers by smartphone apps.
Monopole A type of freestanding wireless tower.
MSO Multiple System Operator, an operator of multiple cable or direct-broadcast satellite television systems.
mW Milliwatt, one thousandth of a watt.
NFV Network Functional Virtualization.
NGH Next Generation Hotspot, a standard that allows Wi-Fi devices to use foreign networks without requiring a
manual log in process.
NIH National Institutes of Health, the primary agency of the United States government responsible for biomedical
and public health research, an agency of the U.S. Department of Health and Human Services.
NTP National Toxicology Program, a project within the NIH.
48 Bridging the Gap: 21st Century Wireless Telecommunications Handbook - Second Edition
Term Denition
NR New Radio, the name for a 5G-compliant radio standard published by 3GPP.
Ooad A network enhancement technique where parallel networks handle requests for large amounts of data (such
as streaming video) – usually through a LTE-U, LAA, or Wi-Fi node.
OnGo The trademarked name for CBRS, governed by the CBRS Alliance.
PAL Priority Access License, a CBRS user tier.
PCS Personal Communications Service, an FCC regulation created for early digital telephony and data services.
PWC Price Waterhouse Coopers, a consulting rm.
RF Radio Frequency.
Roaming The automatic sharing of networks, used to provide subscribers with a larger number of available sites without
requiring user intervention.
SAS Spectrum Access System, a system that governs channel access and priority in CBRS.
SDN Software Dened Networking.
Sharing Economy
Ride-sharing from individual contractors (as an alternative to taxi or livery services), Home-sharing from
private citizens (as an alternative to hotels or motels), and other models – these are managed and enabled by
smartphone apps and mobile networks.
Shot Clock The period dened by regulation during which a local government or public agency must respond to an
application for wireless facilities in the public rights of way.
Small Cell
A type of communications equipment that operates at lower power levels than a macro site. Small Cells
typically cover areas from a single room up to several hundred meters in radius. They are attached to other
structures such as building roof perimeters, streetlights, and utility poles.
Spectrum The range of RF frequencies used by a wireless system.
TSN Time Sensitive Networking, a 5G use prole.
uRLLC Ultra-Reliable Low-Latency Communications, a 5G use prole.
VoLTE Voice over LTE.
VoWiFi Voice over Wi-Fi (sometimes referred to as “Wi-Fi calling”).
Watt A measure of power, used to dene RF power levels.
WHO World Health Organization, an agency of the United Nations.
Wi-Fi Wireless Fidelity, a trademark name for the IEEE 802.11 data communications standard.
Wi-Fi First A type of wireless subscription model where the subscriber equipment prefers to use Wi-Fi calling (VoWiFi) for
voice connections. If Wi-Fi is not available, a cellular carrier via a roaming agreement handles the voice call.
WiMAX The trademark name for the IEEE 802.16 family of standards for data communications.
Wireless Telecommunications of voice or data using RF methods.
Glossary of Terms (Continued)
49
Bridging the Gap: 21st Century Wireless Telecommunications Handbook - Second Edition
Works Cited
Broadband Properties. (2019, July)
https://www.bbcmag.com/technology/microtrenching-goes-mainstream
Centers for Disease Control. (2018, December)
https://www.cdc.gov/nchs/nhis/releases.htm#wireless
CETF. (2016, July)
https://www.tellusventure.com/downloads/cetf/cetf_annual_survey_2016.pdf
CTIA, Ex-parte ling to FCC. (2009, September)
https://ecfsapi.fcc.gov/le/7020039747.pdf
Congressional Research Service. (2014, March)
https://www.fas.org/sgp/crs/misc/R43256.pdf
CPUC R14-05-001. (2016, August)
https://apps.cpuc.ca.gov/apex/f?p=401:56:0::NO:RP,57,RIR:P5_PROCEEDING_SELECT:R1405001
Ericsson AB. (2019)
https://www.ericsson.com/en/mobility-report/reports/june-2019
FCC 19-126 (2019)
https://docs.fcc.gov/public/attachments/FCC-19-126A1.pdf
FCC 600 MHz Auction Dashboard. (2016)
https://fcc.gov/auction/1000
FCC AWS-3 Auction Results. (2015)
https://apps.fcc.gov/edocs_public/attachmatch/DA-15-131A1.pdf
FCC – New National Wireless Tower Siting Policies. (1996, April)
http://wireless.fcc.gov/fact1.pdf
FCC – Small Cell Order. (2018)
https://www.fcc.gov/document/fcc-facilitates-wireless-infrastructure-deployment-5g
Federal Oce for Radiation Protection – Bundesamt für Strahlenschutz, (2011)Danish Cohort Study on Mobile Phone Use and Cancer
https://www.bfs.de/EN/topics/emf/mobile-communication/research-report/danish-cohort/danish-cohort.html
GCTC Public Wi-Fi Blueprint (2017)
Wireless Supercluster, Global City Teams Challenge @ NIST
https://pages.nist.gov/GCTC/uploads/blueprints/20170823-GCTC-PWSC-Public-WIFI-Blueprint-FINAL-v2.pdf
GSMA. (2019)
https://www.gsma.com/r/mobileeconomy/
ICNIRP, Health Physics Society, (2019)
Critical Evaluation of Two Radiofrequency Electromagnetic Field Animal Carcinogenicity Studies
https://www.icnirp.org/cms/upload/publications/ICNIRPnote2019.pdf
50 Bridging the Gap: 21st Century Wireless Telecommunications Handbook - Second Edition
IHS Markit. (2016, July)
IoT Devices - Installed Base & Device Shipments.
(IHS Disclaimer: Results are not an endorsement of Joint Venture Silicon Valley. Any reliance on these results is at the third party’s own
risk. Visit www.technology.ihs.com for more details.)
International Telecommunications Union. (2011)
About mobile technology and IMT-2000.
https://www.itu.int/osg/spu/imt-2000/technology.html
International Telecommunications Union. (2019)
Minimum requirements related to technical performance for IMT-2020 radio interface(s).
https://www.itu.int/pub/R-REP-M.2410-2017
Joint Venture Silicon Valley. (2012)
Wireless Facilities Impact on Property Values
http://bit.ly/cellsiteMLSstudy
Maravedis & Wi-Fi 360, via the Wireless Broadband Alliance. (2016)
http://worldwiday.com/wp-content/uploads/2016/06/Research-%E2%80%9CMapping-the-Urban-Unconnected%E2%80%9D.pdf
Mobile Experts LLC. (2019, April)
https://www.mobile-experts.net/Home/Report/1139
National Cancer Institute. (2019)
Cell Phones and Cancer Risk
http://bit.ly/2lORsfc
NTIA – McHenry, G. (2016, April)
Evolving Technologies Change the Nature of Internet Use.
https://www.ntia.doc.gov/blog/2016/evolving-technologies-change-nature-internet-use
Pew Research Center. (2019)
Mobile Technology and Home Broadband 2019
https://www.pewinternet.org/2019/06/13/mobile-technology-and-home-broadband-2019/
PWC Strategy. (2018)
https://www.strategyand.pwc.com/gx/en/insights/grasping-dierentiated-straw.html
Simon, Linda (2005)
Dark Light: Electricity and Anxiety from the Telegraph to the X-ray
Paperback Edition (via Amazon): https://amzn.to/2VISzQg
Small Cell Forum. (2019)
http://www.smallcellforum.org/about/about-small-cells/small-cell-denition/
T-Mobile West LLC v. City & County of San Francisco (2019)
Decision of the California Supreme Court
https://law.justia.com/cases/california/supreme-court/2019/s238001.html
White House Council of Economic Advisors. (2016, March)
https://obamawhitehouse.archives.gov/sites/default/les/page/les/20160308_broadband_cea_issue_brief.pdf
Works Cited (Continued)
51
Bridging the Gap: 21st Century Wireless Telecommunications Handbook - Second Edition
Notes
KEY POINTS GENERAL NOTES
SUMMARY
SILICON VALLEY
100 West San Fernando Street, Suite 310
San Jose, California 95113
(408) 298-9330
info@jointventure.org | www.jointventure.org
ResearchGate has not been able to resolve any citations for this publication.
July) IoT Devices -Installed Base & Device Shipments. (IHS Disclaimer: Results are not an endorsement of Joint Venture Silicon Valley. Any reliance on these results is at the third party's own risk. Visit www.technology.ihs.com for more details.) International Telecommunications Union
the Gap: 21st Century Wireless Telecommunications Handbook -Second Edition IHS Markit. (2016, July) IoT Devices -Installed Base & Device Shipments. (IHS Disclaimer: Results are not an endorsement of Joint Venture Silicon Valley. Any reliance on these results is at the third party's own risk. Visit www.technology.ihs.com for more details.) International Telecommunications Union. (2011) About mobile technology and IMT-2000. https://www.itu.int/osg/spu/imt-2000/technology.html International Telecommunications Union. (2019) Minimum requirements related to technical performance for IMT-2020 radio interface(s).
Cell Phones and Cancer Risk
National Cancer Institute. (2019) Cell Phones and Cancer Risk http://bit.ly/2lORsfc
April) Evolving Technologies Change the Nature of Internet Use
  • G Ntia -Mchenry
NTIA -McHenry, G. (2016, April) Evolving Technologies Change the Nature of Internet Use. https://www.ntia.doc.gov/blog/2016/evolving-technologies-change-nature-internet-use Pew Research Center. (2019) Mobile Technology and Home Broadband 2019 https://www.pewinternet.org/2019/06/13/mobile-technology-and-home-broadband-2019/
Disclaimer: Results are not an endorsement of Joint Venture Silicon Valley. Any reliance on these results is at the third party's own risk. Visit www.technology.ihs.com for more details.) International Telecommunications Union
  • Ihs Markit
IHS Markit. (2016, July) IoT Devices -Installed Base & Device Shipments. (IHS Disclaimer: Results are not an endorsement of Joint Venture Silicon Valley. Any reliance on these results is at the third party's own risk. Visit www.technology.ihs.com for more details.) International Telecommunications Union. (2011) About mobile technology and IMT-2000. https://www.itu.int/osg/spu/imt-2000/technology.html International Telecommunications Union. (2019) Minimum requirements related to technical performance for IMT-2020 radio interface(s).
Ex-parte filing to FCC
  • Broadband Properties
Broadband Properties. (2019, July) https://www.bbcmag.com/technology/microtrenching-goes-mainstream Centers for Disease Control. (2018, December) https://www.cdc.gov/nchs/nhis/releases.htm#wireless CETF. (2016, July) https://www.tellusventure.com/downloads/cetf/cetf_annual_survey_2016.pdf CTIA, Ex-parte filing to FCC. (2009, September) https://ecfsapi.fcc.gov/file/7020039747.pdf Congressional Research Service. (2014, March) https://www.fas.org/sgp/crs/misc/R43256.pdf CPUC R14-05-001. (2016, August) https://apps.cpuc.ca.gov/apex/f?p=401:56:0::NO:RP,57,RIR:P5_PROCEEDING_SELECT:R1405001