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Steps for Building a New Cell Site:

  1. Our team of engineers works on a plan to design sites to meet demand and high demand could mean more than one new site is required. If two adjacent sites trigger a capacity site, a new site must be built between them. Other sites are needed to improve coverage quality both indoors and outdoors. Some sites are needed to expand the coverage footprint where coverage had not previously existed.
  2. The New Site Target Locations are passed to the construction team to find suitable locations to lease. Collocation with existing facilities is considered and pursued wherever feasible. Placement on existing structures (building rooftops, sides of buildings, cupolas and other existing structures) is preferred if the existing structure meets the network design objectives and is feasible.
  3. Once a site is leased the Approval/Permit process begins. In addition to local zoning and permitting review from cities, counties or other jurisdictions, often sites require review by other agencies at the local, state and federal level:
    • FAA
    • FCC
    • SHPO (State Historical Preservation Office)
    • THPO (Tribal Historical Preservation Office)
  4. Once all approvals are obtained, we begin building the site and commission it for service.
  5. End-to-end cycle times vary greatly and are heavily influenced by the planning and permitting process of the local jurisdiction. We aim to achieve approvals within timeframes set by the FCC Shot Clock.

What laws exist to guide the process?

Wireless infrastructure-based carriers must obtain spectrum licenses or utilize unlicensed spectrum. The FCC is the agency regulating use of the electromagnetic (radio) spectrum.

All providers of wireless service are subject to a host of regulatory requirements both at the federal and state levels. Providers are subject to FCC rules including some or all of the following:

  • License buildout requirements and timeframes
  • Technical standards, such as power limits
  • E-911 deployment
  • Roaming
  • Hearing aid compatibility requirements for mobile handsets
  • Protection against radio frequency (“RF”) exposure
  • Interconnection and intercarrier compensation obligations and rights
  • Numbering resources administration
  • Universal service obligations

Federal Siting Rules Overview

Recognizing the importance and rapid growth of wireless technology, Congress and the FCC established minimum national standards for processing applications for new cell sites and for the collocation, replacement and removal of wireless equipment on existing cell sites. The U.S. statute and interpreting FCC order govern both the time to process applications and the type of review to which applications are subject.

Review Timeline – Section 332 and the FCC’s Shot Clock Order

Section 332(c)(7)(B)(ii) of the Communications Act requires States and local governments to act on cell site applications
within a “reasonable period of time.” In 2009, the FCC interpreted this statute and ordered that a presumptively
“reasonable period of time” to approve an application is 150 days for a new site and 90 days to collocate on
an existing site.[1] State and local governments and applicants can agree to extend these periods of time. Expedited
approvals in the highly competitive wireless telecommunications industry can benefit local jurisdictions, as carriers and
infrastructure builders are more likely to spend capital first in those places with the shortest approval periods.

Review Type -- Section 6409

In February 2012, Congress passed Section 6409 of the Middle Class Tax Relief and Job Creation Act of 2012 (“Section
6409”), which, among other things, requires State and local governments to approve any application for the collocation,
removal or replacement of transmission equipment on an existing tower or base station that does not “substantially
change” the physical dimensions of a tower or base station.[2]

On January 25, 2013, the FCC’s Wireless Bureau, which has authority to implement and enforce Section 6409, issued a
Notice clarifying certain aspects of Section 6409.[3] In particular, the Bureau clarified that a “substantial increase” in size
occurs if:

    • The mounting of the proposed antenna on the tower increases the existing height of the structure by more than 10%, or by the height of one additional antenna array with separation from the nearest existing antenna not to exceed twenty feet, whichever is greater, except that the mounting of the proposed antenna may exceed the size limits if necessary to avoid interference with existing antennas; or
    • The mounting of a proposed antenna that extends horizontally from the edge of the tower by more than 20 feet, unless the width of the tower structure at the point of attachment is greater than 20 feet, in which case the new antenna can extend as far as the width of the tower structure; or
    • The mounting of the proposed antenna involves the installations of more than the standard number of new equipment cabinets for the technology involved, not to exceed four new equipment cabinets, or more than one new equipment shelter; or
    • The mounting of the proposed antenna involves excavation outside the current tower site, defined as the current boundaries of the leased or owned property surrounding the tower and any access or utility easements currently related to the site.

The Wireless Bureau also reinforced that, although local governments may require applicants to submit an application to approve such collocations, removals or replacements that do not substantially increase the size of a tower, those applications must be approved under an administrative process that invariably ends in approval of the application (presumably, a building permit review process), and that 90 days is the “maximum” presumptively reasonable time to approve.

In summary, to ensure compliance with federal law, State or local governments should first determine if an application is a request to collocate, replace or remove equipment that does not substantially increase the structure on which the equipment will be located. If that is the case, State or local governments must consider and approve those applications as building permit requests that are not subject to zoning or land use review, including any public hearing process, within a maximum of 90 days. If the collocation, replacement or removal will substantially change the structure, then a State or local government may consider that application under traditional zoning or land use processes, but within 150 days.

If the application is for a new tower, then a State or local government may consider that application under traditional zoning or land use processes, but within 150 days. In any event, should the federal or any other rules raise questions or concerns, please feel free to contact AT&T. We stand by ready to help navigate the process and answer any questions.

More Frequently Asked Questions

What is piggybacking or collocating?
  • This refers to sharing space on an existing tower or other sites already developed for communications.
  • These deployments are generally faster.
  • If an existing tower meets our capacity or coverage objectives and the tower can hold our equipment (usually the biggest hurdle) and the tower owner will allow us to co-locate and the zoning board allows it, then we will choose this option.
  • There are some complications with the tuning of AM towers that generally get them excluded from the list of candidates. We also have collocated on high-tension power towers, although this is also a last option given the concerns with maintenance and voltage. Not all electric companies are receptive to locating on their high-tension structures.
Are cell sites safe? What are the health effects of wireless infrastructure?
  • Expert scientists and government agencies have stated repeatedly that wireless antennas in compliance with FCC regulations do not pose health concerns.
  • The radio signals from our cell sites comply with regulations established by the Federal Communications
  • Commission in consultation with federal agencies responsible for protecting public health and the environment, including the Food and Drug Administration and the Environmental Protection Agency. We maintain power levels at most of our sites that are far below the limits established by government regulations.
  • For more information on radio frequency safety, visit or contact the FCC’s RF Safety Program at or 1-888-225-5322. In addition, CTIA, the Wireless Association, also has helpful information available at




* Collocations on existing tower this is not a substantial change prompts building permit review only.
**Collocations on existing tower that is a substantial change includes both zoning and building permit reviews.
1 The FCC’s Order can be found at 24 FCC Rcd 13994.
2 Section 6409 was codified at 47 USCA §1455. The text of Section 6409 can also be found at the following link:
3 The Wireless Bureau’s Notice is available at: