The rollout of 5G cellular networks is frequently in the news due to conspiracy theories, health concerns, and conspiracy theories about health concerns. Yet the new infrastructure has received little mainstream attention for its effects on historic properties despite the public’s entitlement to comment on proposed cell tower installations.
5G requires a dense network of small installations in order to ensure coverage, which is resulting in an explosion of proposed antennas in communities across the country. From a design perspective, some of these installations are minimally salient, but others adversely affect the fabric or viewsheds of important historic properties. Cities like Philadelphia are currently fielding many proposals for the first wave of 5G infrastructure.
Small cell installations are erected by cellular network corporations, including those who provide cell phone service. Small cells have a wide variety of potential designs: stand-alone poles with 5G equipment, collocation on streetlights, utility poles, existing cell towers, water towers, or electrical transmission towers, and collocation on buildings.
Cellular corporations apply for a wireless antenna license from the Federal Communications Commission (FCC) for each installation. The FCC’s licensing of these installations triggers a federal regulation known as Section 106 of the National Historic Preservation Act.
Section 106 requires every federal agency to consider the effects its undertakings–activities it carries out, assists, funds, licenses, approves, or permits–may have on historic properties. An important goal of Section 106 is to avoid, minimize, or mitigate adverse effects on these properties through consultation with stakeholders, including the public.
If stakeholders believe an undertaking will adversely effect the characteristics that qualify a historic property for listing on the National Register of Historic Places, they may say so and recommend how to avoid these adverse effects. An adverse effect is one which has the potential to alter characteristics that make a property historically significant. Adverse effects include destruction of historic building fabric, damage to archaeologically sensitive areas, and character-altering viewshed impacts.
FCC Section 106 undertakings have been initiated in Philadelphia for many years, yet residents are largely unaware of them. To meet their obligation for public notice, FCC license applicants publish a single-day notice in a general interest newspaper that lists the location and height of the proposed installation and how to comments on potential effects on historic properties. Few people read public notices, and awareness of any particular installation is low. Thus, most of these undertakings receive no public comments.
FCC undertakings move rapidly through the Section 106 process. Consultation may conclude in as little as 30 days from the publication of the public notice. The State Historic Preservation Office (SHPO) must determine whether to concur with the applicant’s determination about the installation’s effects on historic properties within 30 days of receiving the submission.
Comments may be submitted at any time. However, if comments are sent after the SHPO concurred with the applicant’s effects determination, the project may already be underway if the applicant obtained local permits. The local government’s permitting process is separate from Section 106.
Local stakeholders, including the public, municipal government, Indigenous tribes, and historical organizations are the experts on their communities’ historic resources. When they review projects they can alert the applicant and SHPO to potential negative impacts on historic resources and recommend how to avoid or mitigate those adverse effects.
Members of the public have the power to help protect important historic properties in their community. The first step is to read the public notice in the newspaper. Look up the undertaking’s address on a map or visit in in person. Is the proposal for a freestanding pole or new streetlight or is it for a collocation? Small cell poles are often between 25-45 feet in height. Collocation means placing cellular equipment on an existing building, structure, or object.
Are there nearby properties that are listed on or eligible for listing on the National Register of Historic Places? Search the databases for the National Register and local landmarks, which may be eligible. What constitutes nearby will vary based on the height of the small cell installation and if it is a collocation on a building, its placement.
Basic considerations include whether the installation may destroy any portion of a property listed on or eligible for listing on the National Register, and whether it will impact the viewshed of a historic property in a way that detracts from its character.
If either of these occur, the installation may have an adverse effect on one or more historic properties. This should start a conversation about how to avoid, minimize, or mitigate those effects. Common ways of accomplishing this for FCC undertakings are by relocating the installation, hiding it, or painting it to match its surroundings.
Relocation can mean moving a pole down the street, changing the configuration of a collocation on a building, or changing a proposed pole into a collocation on an existing pole. The goal is to minimize modern visual clutter, particularly in front of individually significant buildings and in historic districts.
Hiding an installation, called stealthing, usually involves concealing a stand-alone pole, such as in a flagpole or designing a radio frequency-friendly concealment atop a roof such as a fiberglass faux chimney. Radio frequency waves cannot effectively penetrate most conventional building materials.
Painting to match means painting the installation whatever color will help it best recede into the background. This may be gray on a concrete building. Depending on the angle at which the building will be seen, it may make sense for the installation to match a different building behind it. High-tech wrapping options also exist when painting will not help.
Good proposals do not have a dramatic effect on the existing landscape. For example, installation of a 35-foot small cell pole that is in line with existing 45 feet tall power lines in a newly constructed industrial zone may be minimally salient.
On the other hand, a theoretical proposal to mount antennas on the front of Independence Hall would have an adverse effect on the historic building. That is because mounting on the side of the building would require some destruction of the historic fabric of an exceptionally historically and architecturally significant building. Additionally, cellular antennas on the front of an 18th century building would adversely affect it visually. For a building of this importance, the most acceptable solution would be to entirely relocate the installation to another building or a pole not directly in front of the site.
Few projects will have such obvious adverse effects. Yet, despite the complexity of the regulations, the question is simple: will building the proposed installation take away from characteristics that make a property historically significant?
Answering the question is more challenging and it is often impossible from a brief public notice. After reading a public notice, if the installation seems like it may potentially affect historic properties–perhaps it is a proposed collocation on a National Register-listed building–follow the instructions in the public notice for submitting comments. Most FCC applicants hire a third party consultant to collect their comments and facilitate Section 106 on their behalf.
Comments should note concerns about the installation’s effects on historic properties. It is helpful to share the public notice with relevant community or neighborhood groups, which can also respond to the public notice or tell other residents so that more people comment.
If the installation raises questions and more information is needed, speak with the public notice contact about the proposal. Consider requesting construction drawings, which provide more detail about the placement and design of the proposed installation.
If a community group or member of the public is invested in an undertaking, it may make sense to officially request consulting party status. Consulting parties are entitled to review the complete submission to the SHPO, comment, and attend any meetings.
Along with the public, the local government, tribes, and in most cases a historical organization is notified about the proposal. These stakeholders also have the opportunity to share comments with the applicant and State Historic Preservation Office. Engagement from all of these stakeholders–including the public–helps ensure that 5G installations are built in a historically sensitive manner.