Table of Contents:

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Goals and Objectives
Methodology
Current Wireless Infrastructure
Future Infrastructure Needs
Maps
Appendix A - Waco Area Wireless Structure Inventory

INTRODUCTION

In the recent past, the City of Waco has received numerous permit applications for new wireless telecommunication support structures. The growing number of permit requests reflects the rapid expansion in wireless infrastructure requirements resulting from phenomenal growth rates in the industry.

Consumer, and therefore citizen, demand is fueling wireless industry growth. We expect to see future growth in wireless tower permit requests as more businesses, public agencies, and the general public increase their use of wireless services.

In order to maintain a high quality of life within the City of Waco, the Wireless Support Structure Master Plan is designed to balance the need for orderly development of wireless communication facilities within the City together with the rights of communication providers to locate and operate within the City.

'This plan will be reviewed regularly to ensure that it reflects advances in wireless communications technology and changes to existing infrastructure and coverage.

BACKGROUND

Wireless telecommunications are an integral part of Waco's communication network. The City's police, fire, and rescue services are highly dependent upon radio receivers, transmitters, and their accompanying antennas for emergency dispatch and response. AM and FM broadcast facilities keep the City's listeners tuned in to their radios, and many viewers still depend on the airways for their television reception. Many businesses such as taxi and wrecker services use radio dispatched vehicles to serve the City. Moreover, many Waco residents and visitors use cellular telephones every day. All of these uses illustrate the importance of wireless communication in our daily lives.

Consumer use of wireless devices is expanding each day as technological innovations lead to new products and lower prices for existing products. For example, the use of cellular phones by businesses and the general public has become very common as a result of the many technological advances of the past 15 years. Many businesses and individuals now rely almost solely on this technology for interpersonal communication.

To satisfy the public's demand for services and to generate revenue, the Federal Communications Commission (FCC) has been and is presently in the process of auctioning licenses for additional broadband and narrow band frequencies servicing the Personal Communications Services (PCS) technology which includes, in addition to the current analog voice transmission, digital voice, video, and data transmission capabilities. We expect to see a continued increase in the number of wireless facilities, based on the increasing number of wireless providers, the proliferation of available services, and price decreases for the services.

PUBLIC CONCERNS

Numerous citizens in Waco and other cities around the nation have expressed concerns about health and safety and aesthetic issues associated with wireless towers.

Health and Safety

Concerns about the effects of long-term exposure to electromagnetic radiation (EMR) are the most prominent among health and safety issues. Public health and safety issues are addressed in detail in Appendix A - The Federal Communication Commission's A Local Government Official's Guide to Transmitting Antenna RF Emission Safety: Rules, Procedures, and Practical Guidance (June 2000).

In general, wireless transmission facilities must comply with Federal Communications Commission (FCC) RF exposure limits. The exposure limits are endorsed by the Environmental Protection Agency as well as the Food and Drug Administration. Most wireless communications facilities create maximum exposures that are only a small fraction of the limits, as discussed in the Guide. Use of the Guide checklist can help identify those facilities that are unlikely to raise compliance concerns.

Aesthetics

Aesthetic issues generally focus on areas that have become "tower farms" or the location of cellular towers within residential neighborhoods. One of the chief goals of this plan is to strike a balance between aesthetics and wireless service availability. Thus, construction of wireless support structures is prohibited or strongly discouraged in visually sensitive areas such as the Brazos River Corridor. In addition, this plan and the City's zoning ordinance encourage the construction of collocatable wireless support structures to reduce the overall number of these structures within Waco.

WIRELESS TECHNOLOGY

Cellular telephone calls are transmitted through the air via radio waves at various frequencies. Cellular transmissions differ from television and radio transmission in that cellular depends on a network of small receiving and transmission stations (cell sites) spread out over the surface area whereas television and radio rely on one tower to provide service throughout a large region.

Calls from cellular handsets send radio signals to the closest cell site. Each cell site has a base station with a transmitter and receiver. Each base station communicates with the company's switching office to send the signal to a "hard wired" phone or send the signal to another mobile phone through a series of cell sites. As a mobile caller moves through the service area, the signals are "handed off" to the next nearest cell site. Microwave radio frequencies are used to coordinate the switching of signals among the cell sites. The radio signal from the cell site base station is directed toward the adjacent cell sites in a beam that is relatively narrow in the vertical plane. The beam must be uninterrupted by buildings or other obstructions, that is, it must have "line of sight" transmission to the next cell site.

The cellular phone industry is limited by the Federal Communications Commission to 45 MHz of radio spectrum bandwidth, which without reuse, would limit each company to 396 frequencies or voice channels. In order to increase calling capacity, these low power facilities "reuse" frequencies on the electromagnetic spectrum.

Historically, cellular phones have used analog transmission signals. In the analog technology, voice messages are electronically replicated and amplified as they are carried from the transmitting antenna to the receiving antenna. A problem with this technology is that the amplification procedure tends to pick up "noise", sometimes making the message difficult to hear. In order to diminish this noise and to provide greater capacity per channel, the cellular industry is migrating to digital transmission signals. In the digital technology, voice messages are converted into digits (zeros and ones) that represent sound intensities at specific points in time. Because natural pauses in conversation are eliminated, more calling capacity becomes available from the same amount of spectrum and the background noise of analog calls is eliminated. However, due to the digital technology's higher frequencies on the electromagnetic spectrum, the digital cell phone system (Personal Communications Systems-PCS) has a smaller radius than analog cellular sites and will require more transmission sites than the analog cellular system.

A wireless network for Waco has two primary functions:

1. Provide the necessary coverage for the entire city.
2. Provide the necessary capacity to satisfy the demand for calls at any one time throughout the entire city.

Traffic jams on the radio waves for cellular phone use would discourage the growth of the industry and the development of more advanced technology and could disable local emergency communications systems. The dual requirements of coverage and capacity necessitate the need for multiple low-powered sites throughout Waco. Hence, each wireless carrier must erect and maintain multiple facilities to adequately serve the City.

LEGAL CONSIDERATIONS

Wireless communication facilities are regulated at the Federal, State, and Local level. Most of the regulation takes place at the Federal and Local levels in Texas.

Federal

Federal Communication Commission

The Federal Communications Commission (FCC) is an independent federal regulatory agency that answers directly to Congress. Established by the Communications Act of 1934 (Appendix B), the FCC is charged with regulating interstate and international communications by radio, television, wire, satellite and cable. The Wireless Telecommunications Bureau (WTB) handles all FCC domestic wireless telecommunications programs and policies, except those involving satellite communications. Wireless telecommunications services include cellular telephones, Enhanced Specialized Mobile Radio (ESMR), personal paging, personal communication services (PCS), public safety, and other commercial and private radio services. The WTB regulates wireless telecommunications providers and licenses and serves as the FCC's principal policy and administrative resource with regard to federal auctions for the private use of public airwaves. Portions of the frequency spectrum are allocated to specific uses (such as TV broadcast or cellular), and specific frequencies within that part of the spectrum are assigned to licensed operators.

Section 332 of the 1934 Act was revised by Congress in 1993 to refine federal regulatory policy governing commercial mobile radio services ("CMRS"), such as cellular companies, to ensure the development of an efficient federally regulated, competitive market. In revising Section 332, Congress sought to ensure regulatory parity among all CMRS providers because "the disparities in the current regulatory scheme [e.g. private mobile carriers are exempted from state and federal regulation of rates and entry while common carrier mobile services are not] could impede the continued growth and development of commercial mobile services."

The Senate expressly found in its version of the bill that "State regulation can be a barrier to the development of competition in this market" and that "uniform national policy is necessary and in the public interest". The FCC has noted that the 1993 revisions make clear that "Congress intended . . . to establish a national regulatory policy for CMRS, not a policy that is balkanized state-by-state." This national policy is designed to "foster the growth and development of mobile services that, by their nature, operate without regard to state lines as an integral part of the national telecommunications infrastructure."

The Act reserves to the states regulatory authority over "other terms and conditions." The House Report on the 1993 revisions specifically refers to "facilities siting issues (e.g., zoning)" as such "terms and conditions" within the state's purview.

1996 Federal Telecommunications Act

With the potential economic impact of the WTS industry on both the national economy and federal treasury, Congress, in the recently passed Telecommunications Bill, has further deregulated the industry in order to promote the availability of competing and affordable services. President Clinton signed the bill into law in February 1996.

Section 704 of the Act is entitled National Wireless Telecommunications Siting Policy. This Section, while preserving the local jurisdiction's control over the siting process, sets forth certain important limitations. States and localities cannot unreasonably discriminate among providers of various services, and they cannot take action that prohibits or has the "effect" of prohibiting the provision of wireless services. The legislative history of the bill specifically provides that "it is in the intent of this section that bans or policies that have the effect of banning personal wireless services or facilities not be allowed and that decisions be made on a case-by-case basis." States and localities must act on siting requests "within a reasonable period of time", taking all relevant factors into consideration. Determinations to deny wireless facilities must be in writing and supported by substantial evidence.

The 1996 Act prohibits States and localities from denying siting on the basis of Radio Frequency Radiation (RF) emissions so long as such facilities comply with the FCC's regulations concerning such emissions. The FCC regulations currently accept the American National Standards Institute (ANSI) Standards as the acceptable level of Electromagnetic Radiation (EMR) emissions for cellular phone, radio-dispatched mobile services (ESMR) and personal communications services (PCS) facilities. The Act creates a cause of action for parties adversely affected by a locality's decision inconsistent with these provisions, and the Courts are directed to hear and decide such action on an expedited basis.

State

Texas State Government regulates wireless communication facilities only when they are located on State property. The Texas Department of Transportation issues construction permits for wireless communication towers over 200 feet that are near airport flight paths that do not require a FCC construction permit, license, or authorization. Although the Federal Communications Act of 1996, in theory, permits a State to conduct zoning regulation, local governments have traditionally exercised this authority in Texas.

Local

Wireless communication towers are allowed within Waco as a principal use in Industrial Districts (M-2 and M-3) where they conform to spacing and height requirements designated in the Zoning Ordinance. A special permit is required for siting towers in other districts. Wireless communication Towers are not allowed in residential districts, within 200 feet of a residential district, or within the Brazos River Corridor District.

GOALS AND OBJECTIVES

GOAL 1
Provide a proactive and efficient network of wireless infrastructure to the residents and businesses of Waco.

Objectives

A. Require collocation on wireless communication structures as a means to reduce the proliferation of towers.
B. Designate acceptable sites for future location of wireless support structures thereby minimizing the number of facilities and requiring the maximum number of carriers per facility.
C. Discourage wireless communication structures in residential neighborhoods and other visually sensitive areas to the extent necessary to minimize visual obtrusion.
D. Require that ground mounted wireless communication structures follow the schedule of regulations for principal permitted uses and where appropriate, accessory uses of the allowed zoning districts.
E. Screen wireless communication structures at ground level to assure compatibility with surrounding land uses.
F. Expedite the permitting of proposed wireless communication structures that meet all requirements and provide for a consistent and dependable network of structures.

GOAL 2
Provide a system of wireless support structures that meet location, site, and design guidelines as outlined in this Master Plan.

Objectives

A. Encourage and support the development of an advanced wireless service infrastructure in the City of Waco.
B. Promote competition between wireless service providers in order to maintain a cost efficient and effective community wide system.
C. Allow all providers an equal opportunity to site structures in the City of Waco, provided they meet all adopted requirements.

GOAL 3
Allow for a network of wireless communication structures that protect the health, safety and welfare of Waco.

Objectives

A. Require wireless communication structures to meet all minimum requirements for:

1. Federal Communication Commission
2. Federal Aviation Administration
3. Relevant Building Codes
4. Waco Zoning Ordinance

B. Establish and maintain a database of wireless communication structures in the Waco Inspections Department containing such information as may be necessary to update and assure the continued effectiveness of this Master Plan.

METHODOLOGY

The City chose an independent tower development company to assist in the preparation of this Plan. The Plan development process consisted of four phases:

1. Tower inventory.
2. Collocation availability analysis.
3. Coverage deficiency analysis.
4. Identification of potential future wireless tower locations

The study encompassed the City of Waco and adjacent areas. Adjacent areas were included because some wireless communication facilities are located only a short distance from the Waco City Limits.

Tower Inventory

The consultant mobilized a team of site development professionals that worked with City staff to complete an Existing Tower Inventory within the City limits and the immediate surrounding areas. Tower locations were entered in a Geographic Information System (GIS). The consultant identified the owner of each tower where possible. A list of carriers located on each tower was compiled wherever possible. Finally, local wireless carriers were contacted to obtain location information for non-tower facilities such as roof-tops, water towers, etc.

Potential Collocation Availability Analysis

Potentially collocatable towers were identified via visual inspection of each tower included in the inventory. These towers were identified as potentially collocatable on the basis of apparent structural suitability, ground space availability, and the availability of space for additional carrier antennas and equipment. More specific information would be needed to determine the actual suitability of existing towers for collocation.

Coverage Deficiency Analysis

The consultant utilized their working knowledge of wireless industry RF design strategies and equipment to perform a rough coverage analysis for each carrier. A 2-mile radius of coverage for each existing antenna/tower was used to identify current coverage area. This was applied as a general rule of thumb not as a definitive analysis of each antenna or towers actual capability. The compilation of this data provided the consultant with the information necessary to develop a pattern of the approximate coverage of the carriers within the City. Potential coverage deficiencies were identified as those areas without carrier coverage that lack collocatable towers.

CURRENT WIRELESS INFRASTRUCTURE

As of the date of this Master Plan, there are approximately 80 wireless communication towers in the Waco area (Map 1; Appendix C). The inventory attached as Appendix C contains a list of all known facilities within the City of Waco. As new facilities are permitted in the City, this inventory will be revised and updated.

Approximately one half of these support the six cellular carriers active in the Waco market (Table 1). AT&T has, by far, the most extensive infrastructure with 14 facilities. Note that not all of these facilities are located on towers. Some are co-located on rooftops, water towers, and other structures. In addition, multiple carriers may collocate on a single tower, so each facility in Table 1 does not represent a unique tower.

Table 1. Wireless facility counts for Waco area cellular carriers.

There are 34 collocatable towers in the Waco area (Map 2). Only nine of the 34 towers have room for multiple co-location. Towers that will accept multiple carrier collocations are concentrated in the downtown area, in the IH-35 corridor, and along south Loop 340.

The Coverage Deficiency Map (Map 3) depicts those areas most likely to require additional support structures for wireless facilities. The greatest deficiencies exist in western portion of the study area, including the China Spring and the Highway 84 Corridor areas of Waco.

FUTURE INFRASTRUCTURE NEEDS

Areas with Coverage Deficiencies

The consultant identified four areas within the City with coverage deficiencies as a result of this study (see Map 3).

1. Northwest Waco, along China Spring Road, west of the Waco Regional Airport. The recommended height is 199 ft at an approximate elevation of 550 ft. There are several commercial properties and municipal facilities that could be good tower sites.
2. North Waco, at the northeast intersection of Steinbeck Bend drive and Lake Shore Drive. The recommended height is 199 ft. at an approximate elevation of 420 ft. There are several properties with industrial zoning at this location, which would be suitable.
3. Southwest Waco, along Highway 84, west of Woodway. The height would depend on the proximity to the McGregor Regional Airport. The approximate ground elevation should be 550 ft. There is industrial zoned land and several suitable commercial properties that would make a good site.
4. East Waco, along E. Loop 340, South of Bellmead. The recommended height is 199 ft. at an approximate elevation of 475 ft. There is industrial zoned property and several commercial uses along E. Loop 340 where a tower could be built.

Preferred Locations for Future Infrastructure

While these areas have been identified as deficient, the City recognizes that additional cell sites will be needed for both coverage and capacity problems. The City also recognizes that a properly designed tower can support cell sites of many carriers and can serve as both coverage and capacity sites depending on the needs of the individual carrier.

In order to promote the responsible placement of new cell sites, the City has determined that co-location should be promoted whenever possible. Towards that end, the permitting process for any co-location on an existing structure will be expedited. The City also understands that co-location is not always possible and has identified certain zoning classifications and uses that are deemed compatible with new towers. Where a need for a new facility can be shown, location in these zones will have a lower regulatory threshold. Any new facilities in these areas must be designed to maximize potential co-locations.

Map 1 - Existing Wireless Support Structures Inventory

Map 2- Collocatable Support Structure Inventory

Map 3- Coverage Deficiencies

Appendix A - Waco Area Wireless Structure Inventory