1. What’s the difference between a small cell equipment installation and a large macro cell tower?
Small cell equipment installations communicate with cell phones and other wireless devices within a smaller coverage area than macro cell towers. For that reason, small cell equipment uses less power, often emitting radio frequency waves ranging from just under 100 watts to 1,000 watts per radio/antenna that are intended to serve a limited number of customers within a radius of approximately 1,500 feet. Another difference is small cell equipment is typically placed on shorter structures in the streets (like streetlights and utility poles).
Macro cell towers, on the other hand, emit radio frequency waves at higher power levels with sectors, typically ranging from 5,000 watts to 65,000 watts, serving a large number of customers within a one-to-three-mile radius. Macro cell tower equipment is typically placed on building rooftops or on taller poles or towers built specifically for wireless facilities.
2. Are wireless telecommunications carriers allowed to install their small cell equipment at locations that don’t experience dropped telephone calls?
The City’s application requires applicants to justify why they need to install their equipment, however, the Federal Communications Commission (FCC) has determined that for small cells, a wireless telecommunications carrier may justify an installation for any number of reasons.
They could show a significant gap in coverage (which might be shown through data showing dropped telephone calls or other means), but that is not the only possible justification.
They may instead indicate that they wish to densify their network (for example, in anticipation of signing up more customers to use their network), or to roll out new services not previously offered to their customers, or to improve their existing services.
Telephone calls are not the only reason small cell wireless equipment is installed. They are also installed to improve use of mobile devices that stream movies along with creating enough bandwidth to support the addition of other wireless gear to their networks such as smart watches, appliances, thermostats, lighting, irrigation, weather stations, home theater, smart door locks, and doorbell cameras or other security systems that stream live audio/video, etc.
3. How much flexibility does a wireless telecommunications carrier have to move their small cell equipment to a different location?
Wireless engineers design placement of their small cell equipment to target areas of need and to maximize their overall effectiveness working with other sites in their existing network. As part of the application process, the City requests information on alternative locations that were considered, but sometimes, given small cell equipment’s limited range, there are not always technically feasible alternatives within the target service area.
4. Isn’t there scientific evidence that demonstrates that small cell equipment installations result in biological harm to those who live near them? Will the City consider establishing setbacks from schools and residential uses to protect the community from these harmful effects?
The FCC, in consultation with other federal agencies, has sole authority to establish safety standards related to radiofrequency (RF) emissions from wireless telecommunications facilities. The FCC believes compliance with the standards they have developed will ensure that there are no short or long-term health effects.
The City’s role is very limited by federal law. The City cannot develop its own standards and it may not regulate wireless installations based on the environmental or health effects of wireless facilities, so long as the applicant demonstrates it is complying with the FCC standards. The City can and does require applicants to submit a report for each proposed facility that demonstrates that the facility will comply with these federal standards.
5. Doesn’t living near small cell equipment reduce property values?
Small cell equipment is being installed in communities all over the state and throughout the country. People certainly may have different opinions on this issue, some seeing a benefit to being near small cell equipment installations because of improved service, and others perceiving a detriment. The City’s cell site design and location standards subject all small cell deployments to aesthetic standards so that unsightly deployments are avoided to the extent allowed by state and federal law.
6. Aren’t wireless telecommunications carriers unable to obtain insurance for bodily injury due to the personal harm their wireless facilities allegedly cause?
The City requires every telecommunications carrier to provide evidence that they maintain an active Commercial General Liability (CGL) insurance policy to cover all property and personal injury claims surrounding the installation and use of their equipment. In addition, they are also required to indemnify and name the City as an “additional insured” on their policies to protect the City from claims.
7. Aren’t shell companies formed by wireless telecommunications carriers to submit their applications so they can skirt responsibility for claims surrounding the personal injuries they allegedly create?
No shell companies have applied to install small cell equipment in Culver City.
8. Weren’t the existing FCC guidelines for radiofrequency (RF) emissions now in place called into serious question recently in the U.S. Court of Appeals?
The FCC guidelines were not called into serious question.
Regarding the court case (Environmental Health Trust, et al. v. FCC & United States, No. 20-1025 (D.C. Cir. 2021), the D.C. Circuit explicitly took “no position in the scientific debate regarding the health and environmental effects of Radio Frequency radiation.” Instead, the court “merely conclude[d] that the Commission’s cursory analysis of material record evidence was insufficient as a matter of law.” The Court ordered the FCC to provide a reasoned explanation for portions of its decision to terminate an inquiry into possibly updating its RF emissions guidelines.
As of now, the FCC guidelines remain in effect as does the law that preempts Culver City from regulating RF emissions.
9. Can’t the City require the small cell antennas to be shielded so that they direct their signaling away from nearby schools and residential uses?
If the City were to impose shielding requirements upon antennas so that they cannot transmit their signals in the target service area, then they would likely be challenged by applicants as unlawfully preventing the wireless telecommunications carrier from providing services to its customers.
10. Does the City require wireless telecommunications carriers to adhere to the National Environmental Protection Act (NEPA) and does the City conduct a California Environmental Quality Act (CEQA) review for each new small cell application?
As a condition of approval, the City requires wireless telecommunications firms to adhere to all state and federal law. Federal agencies such as the FCC are required to comply with NEPA in taking federal action related to wireless. The City is only required to comply with CEQA in taking its action on applications. The City performs a review of each new installation to assure compliance with CEQA.
11. Who oversees the FCC and how do I contact them?
As a federal agency, the FCC is overseen by the U.S. Congress. Culver City is part of the 37th U.S. Congressional District, represented by Karen Bass. The State of California is represented by Senators Dianne Feinstein and Alex Padilla.
Contact the FCC
Contact Congresswoman Karen Bass
Contact Senator Dianne Feinstein
Contact Senator Alex Padilla