CTIA to FCC: We Need Relief for ‘Two Month Towers’

A "COW" (l) and a "COLT" at the Rose Bowl in Pasadena, California.
A Nextel “COW” (l) and a Sprint “COLT” at the Rose Bowl in Pasadena, California. Click on the photo to enlarge.

CTIA – THE WIRELESS ASSOCIATION® petitioned the FCC on December 21, 2012 to relax its rules regarding temporary wireless site installations, typically using “COLTS” and “COWS” (“cells on light trucks”, and “cells on wheels”).  The FCC has responded by opening a proceeding to seek public comment (RM-11688).

The FCC’s current process requires certain types of public notice, which the CTIA says can prevent the wireless industry from bringing in additional call handling capacity for special events.

CTIA seeks a waiver from the public notice requirements for “temporary towers that (i) will be in use for 60 days or less, (ii) require the filing of a Form 7460-1 with the FAA, (iii) do not require marking or lighting pursuant to FAA regulations, and (iv) will be less than 200 feet [sic]” which CTIA calls in its petition “Two Month Towers.”

When are Two Month Towers needed?  In its petition, the CTIA gave some examples:

There are also numerous instances where carriers need to deploy temporary towers in non-emergency situations with less than 30 days of advance notice. These events often occur with only a few days of advance notice, with carriers learning about the need for additional capacity at the last moment. These events nevertheless place significant short-term demands on the local wireless networks and require temporary facilities to address these capacity issues. For example:

  •  In 2011, President Obama vacationed in Martha’s Vineyard. Carriers did not receive sufficient advance notice of the vacation and had to quickly deploy temporary facilities to accommodate the increased capacity necessitated by the influx of press personnel and additional tourists;
  •  States and localities often hold ticker-tape parades to celebrate their teams’ sports championships. Carriers do not have advance notice regarding teams that will win championships and the parades usually are held shortly after the championship game;
  • During presidential campaigns, candidates made stops in various towns and carriers receive less than 30 days notice due, in part, to security concerns. Once carriers learn of planned campaign stops, they mobilize to deploy temporary facilities. The lack of 30 days notice would preclude the deployment of these temporary facilities;

CTIA’s petition provided other examples of requests for temporary sites that had to be deployed could not meet the 30-day notice rule.  The petition did not say how those sites were deployed without complying with the FCC’s present 30-day notice requirement, but I digress.

If you’d like to read the CTIA’s petition, CLICK HERE. To read the FCC’s request for comments on CTIA’s petition, CLICK HERE.  Comments are due on February 25, 2013, with reply comments due on March 12, 2013.  To search for filed comments, CLICK HERE.


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