Friday, April 30, 2010

Cell Phone vs Landline, Let's talk about "staying on task."

A city official asked me last week, "Do you have any solutions for citizens so that we can provide better cell phone service? We need to stay on task as many people have gotten rid of their land lines and now have cell phones for their entire service."

I have a problem with this question on two fronts. First, it asks how the we (citizens) can provide better cell service. As far as I know, the citizens of Duluth are not in the cell phone business, and frankly, some of us could care less about improving service. Do we have people calling city hall and asking for better service? Is the city obligated to approve any proposal that comes before them for improved service? Not without verifying actual need! Should we assume that a private company has the best interest in mind when asking for concessions from the community without first verifying that there is actual need in the community?
Do people really need in car coverage on every inch of road?
Is it the community's responsibility to take care of people who are stupid enough to drop their landline when they don't have reliable in home coverage? Why don't they just get an in home antenna to improve their service?
And what happens to their phone when they forget to charge their battery and the phone dies during a 911 call?
What happens when the power goes out for an extended period of time (think winter blizzards) and there is no power to charge that phone or the backup power to the tower goes out? (Think hurricane Katrina)


I'm pretty sure the question was an attempt to shut me up. What follows is a part of what I sent back. I received a scathing reply that basically did not address anything I had suggested, instead I was attacked personally. All I can say is, nice way to "stay on task".

From my email:

1. Have carriers collocate on towers, and when they say they can't then our zoning must require that they submit a written refusal from the tower owner. We could even offer property tax breaks or reduced permit fees (which should be $5000 for a monopole and $2500 for a collocation) if a company agrees to collocate on other towers. If we don't start requiring collocation now and we continue to listen to arguments about 911 we will have to have a tower every 2-4 square miles. We don't need to have a tower every 2-4 miles, but there can be an "antenna" every 2-4 miles. BIG DIFFERENCE! Antennas do not have to be place at 190 feet, but this is the preferred configuration as it is easiest and cheapest for the carrier, and most lucrative when a community starts to REQUIRE collocation (how nice that they already have a tower that can accommodate 3 or more antenna arrays). There are communities that do not allow any tower to be built above 10- 20 feet above the highest feature. This requires more expensive equipment for a carrier, but a community has the right to set these controls.

"While historically, due to a lack of wireless infrastructure, a tower has often been needed, today significantly fewer new towers are needed. Theoretically, almost anything that can support the structural load of an antenna array and its associated cabling and is of sufficient height can serve in lieu of a tower. The effects of buying into this misconception can be seen when traveling any interstate highway.
How many towers do you see that have only 1 or 2 carriers attached and within a 1/2 mile or so there's another identical situation? Assuming that either tower needs to actually exist, there should only be one tower, not two or more." Source, Center for Municipal Solutions

2. Require that tower companies submit to third party review of RF studies by an engineer chosen by the city. Do we require experts to review building plans and utility plans? Why do we take these at their word, does anyone on City staff actually understand the RF studies that are submitted? (I sent this question to the city administration and the entire council...no answer yet!)

3. The test should always be, actual PROVABLE needs of the COMMUNITY. As far as the 911 issue, no one at St Louis County sees it as a big enough problem to even track it. Therefore, there is no actual way to PROVE that AT&T or any other carrier can solve the problem, and frankly, they are doing a disservice to the community in asserting that they can. If a person in Riverside does not have an AT&T phone, this tower will do them absolutely NO GOOD. (The tower will handle 911 calls from any carrier, as is required by law. But if your phone is not AT&T, the AT&T antennas on this tower will not handle your call. If at some point your carrier collocates on that tower, you will see improved service.)

Here's a good example from the Center for Municipal Solutions regarding need vs desires:

A community is obligated to permit an applicant the means to achieve its 'desires' or 'objectives', as opposed to its 'needs' This should be true, but only when desires and objectives coincide with true needs, such as being able to provide "functionally reliable" service. Notably, "functional reliability", not necessarily the signal strength claimed to be needed by the applicant, should be the test as regards meeting the applicant's needs, It's important to know (and understand) exactly what the carrier's needs are, as opposed to its desires or objectives. If one doesn't know exactly what the problem is and what's causing it, as well as all the options for remedying the problem, the local officials simply can not make informed decisions. Instead, they're relegated to simply relying on the applicant's assertions and what little they know about the cause and the possible solutions to the problem.
Desires are normally couched in terms of the Company's 'objectives', which sounds good, but under the law at (47 U.S.C. 332(c)) a company's desires or objectives are not the test. The test is the actual, provable needs of the Company, i.e. to provide "functionally reliable" service primarily within that community and not an adjacent community.
An example of needs versus desires and objectives happened in a North Carolina county recently when the applicant requested a 300' tower for a gap in a sparsely populated rural area along a major highway. Upon review of the application, it was discovered that the carrier already had sufficient signal to provide 'Rural In-Vehicle' signal strength throughout the majority of the alleged gap in service. As it turned out, the applicant was requesting a 300' tower so it could provide the equivalent of 'Urban In-Building' signal strength at the extremities of the area, even though it was to serve a "Rural In-Vehicle" market. Once this was discovered, the Company agreed that it could fill the few relatively small gaps in service that actually existed by co-locating on existing structures. Result: no new tower. The key was in knowing what propagation studies to request, being able to analyze the propagation studies, knowing and understanding the difference between the applicant's desires and its true needs, and knowing what would enable the applicant to fulfill its real need, i.e. to provide Rural In-Vehicle coverage for the relatively small area not already covered.
As the preceding shows, the effects of not understanding the difference between a carrier's legitimate, provable needs and its objectives/desires, and how they should be treated, are significant and can mean the difference between the construction of a new tower and being able to co-locate on an existing facility of some type, with the facilities often being unrecognizable by the average person. Result: No 300' tower and no physical or visual impact on the community, but with improved and expanded service.
(Read about tower misconceptions at the website http://telecomsol.com/misconceptions.html)

4. Understand that our City does not have to permit carriers to fill a gap from a single location, they can fill from distributed antenna systems, these are mulitple antennas which are placed on power poles, on existing structures, towers, and even buildings. There is quite an array of antennas providing service to Lakeside on top of St Michaels school, not even close 190 feet in the air! The cell companies do not pursue this if there is no push back as it is more expensive.

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