Small Cell Infrastructure (5G)

• Small Cell facilities are low-powered antennas that provide cellular and data coverage to smaller geographic areas, which assists in adding additional coverage to a larger cellular network.
• Small Cells are proposed to be located on poles, light poles, and/or traffic signals, but may also be placed on utility poles (with utility provider consent) or on private property (with property owner consent).
• Pursuant to Federal and State law, Small Cell equipment is allowed in public right of way, similar to other utilities.
• Small Cell equipment will initially meet current 4G (LTE) voice and data demands but is rapidly evolving to provide future 5G higher speed data services as technology changes.

• The City reviews and approves license agreements and applications for Small Cell equipment in right-of-way (ROW).
• State and Federal law requires the City to process applications for new freestanding poles in batches and within 90 days or less.
• The City has Design Guidelines that standardize and minimize the physical and aesthetic footprint of equipment while satisfying the legal requirements and equipment needs of wireless Small Cell carriers.
• As permitted by law, the City regulates the look of these Small Cell facilities including pole height, pole color, and spacing between Small Cells.
• To minimize impacts, the City continues to encourage co-location onto existing poles and infrastructure, where possible.

Researchers say mobile data traffic in North America has increased exponentially and is projected to continue at a rapid rate as more people use wireless devices. In Centennial, there has been a surge in economic growth, and wireless carrier companies are indicating that existing infrastructure is becoming congested and cannot continue to meet the demands of their customers.

Existing cell sites are becoming congested and installing more cell towers covering large areas will not keep up with projected demand for high speed wireless data that continues to grow.  To meet demands for wireless data, carriers have begun using new lower-powered (smaller) antenna technology to “offload” data traffic from the traditional cellular antenna towers. Each of these smaller antennas serves a much smaller area (1 -2 blocks) with much higher data volumes. This type of wireless infrastructure is referred to as “Small Cell.”  Small Cell antenna equipment must comply with maximum volume requirements of Federal and State law. The types of equipment and method of deployment being proposed in Centennial will vary widely and depend upon the network needs and technology requirements of the various wireless carriers.  Typical Small Cell locations are expected to be:

• City traffic signal poles or other City-owned poles in right-of-way (ROW);
• Street lighting poles that would be a new/replacement street lighting pole in ROW;
• Carrier installed freestanding poles in ROW;
• Other non-City owned poles in ROW (with the consent of the pole owner); or
• Mounted onto existing buildings on private property (with the consent of the property owner.)

Requests for Small Cell installations in the City and throughout Metro Denver are expected to continue as wireless companies work to meet the increasing wireless data demands of customers. Current projections indicate that thousands of additional Small Cell antennas may be proposed throughout Metro Denver by cellular carrier companies. It appears that most new infrastructure being proposed today is servicing current 4G (“4thGeneration”) cellular and data needs, also known as “LTE.” However, wireless carriers are already proposing to deploy densely spaced antenna equipment for imminent 5G (“5thGeneration”) wireless networks, expected to service even higher speed data demands.

The companies proposing Small Cell infrastructure follow different business and ownership models.  For example, some companies will construct their own infrastructure to service wireless demand from their own customers, such as AT&T and Verizon. Some companies will construct wireless infrastructure and then lease equipment or sell service to wireless providers that do not wish to construct and own their own equipment, such as Crown Castle for T-Mobile and Mobilitie for Sprint. Additionally, other companies such as Zayo are using Small Cell to build out wireless networks for other uses, such as high-speed internet.

Federal and state laws limit the City’s authority over Small Cells and the City cannot prevent the siting of Small Cells in the right-of-way (ROW). Recently, the Federal Communications Commission (the “FCC”) issued guidance and adopted rules to streamline the process for deployment of Small Cells. This process leaves little regulatory authority for local governments other than regulation based upon objective design standards and reasonable aesthetic considerations such as height.  

In 2017, Colorado enacted a law (House Bill 17-1193) making the siting, mounting, placement, construction and operation of small cell facilities and networks a permitted use by right in any land use zone.  As a result, local governments in Colorado cannot prohibit small cell sites in any zone district, including residential. These laws specify that cities may not entirely deny or discriminate against Small Cell infrastructure and must treat the equipment in the same way as other permitted users and utilities in the ROW. To view the City’s regulations concerning Small Cell in the public ROW, see LDC Section 12-2-425, Centennial Small Cell Standards (PDF, 315KB).

The City does not own or maintain most existing street lighting poles or utility poles in the right-of-way (ROW), but the City does own and operate traffic signal poles within ROW that are not Colorado Department of Transportation (CDOT) state highways.  Most street lighting poles and utility poles are owned and maintained by Xcel Energy or IREA. In many areas, however, there are no above-ground utility poles within ROW. The City strongly encourages carriers utilize existing infrastructure such as City owned and operated traffic signal poles or other City owned poles in ROW; street lighting poles that would be a new/replacement street lighting pole in ROW; carrier installed freestanding poles in ROW; and other non-City owned poles in ROW.

Throughout Centennial, there are many cellular antennas already located on antenna towers and on top of buildings on private property.  However, because of the cost and the complexities and length of time to create lease agreements with individual property owners (carriers have to lease land and pay rent to a property owner if on private property) many companies have disclosed to the City that it is not always feasible to deploy Small Cell equipment in this manner and still meet current data demands.  However, if a company locates equipment in public right-of-way (ROW) that is not on a City owned pole, the City is not able to require payment to occupy the ROW.

If and when a company identifies a location for mounting Small Cell infrastructure on private property, it will be regulated by the City using requirements of LDC Section 12-2-425, Centennial Small Cell Standards (PDF, 315KB). The City’s regulations include parameters for height, size, placement, aesthetic design, etc. on private property to preserve the intent and character of the community.

The City encourages and does not prohibit equipment for multiple carriers being combined into a single pole.  The long-term goal of the City is to minimize the amount of new infrastructure placed in the right-of-way (ROW), while meeting the requirements of the carriers along with Federal and State law.

For now, the siting of Small Cell Infrastructure is dictated by the wireless provider and its customers’ needs, terrain, and modeling results. Each wireless provider has different objectives and may not need the same locations. Each carrier, who owns rights to a spectrum of broadband operating frequency, states that some separation with competing antennas is necessary to avoid signal interference. With that said, the City understands that Small Cell technology is evolving rapidly towards the ability to share antennas or even poles between multiple carriers.

Centennial reviews all new pole applications in conjunction with applicable laws, each carrier’s Master License Agreement (MLA) and the City’s Land Development Code (LDC). The City’s Community Development and Public Works Departments are responsible for permitting infrastructure, objects, or construction within the ROW. City Staff consults with each wireless provider about proposed infrastructure programs to understand their deployment intentions to ensure consistent approaches and communicate policies and permitting procedures at the outset.

The City must offer permitting procedures that can process “bulk” Small Cell programs in batches, in 90 days or less, rather than requiring individual permits for each pole or antenna. Each application will result in a revocable Supplemental Site License (SSL). Additionally, Applicants will require an address assignment, electrical permit, and right-of-way (ROW) permit.  This batch permitting system ensures that each Small Cell application follows the same procedures and standards as any other user of the ROW.

Each SSL requires a complete review process. The City logs each application for review using an electronic plan review website. Any comments received from the permit review process are accepted and must be addressed by the applicant.  Comments that are deemed to have technical merit (identifying unlawful or conflicting proposed infrastructure) are required to be fully resolved by the applicant. If the SSL is issued, the new poles may be constructed. Additionally, any Small Cell facility that is attached to an existing City facility (such as a City-owned streetlight or traffic signal pole, requires a $200 annual fee (akin to rent). The City is prohibited from assessing any annual fee for the placement of Small Cells in the ROW that are freestanding and not attached to any City-owned facilities. In situations where a Small Cell Carrier replaces a City-owned streetlight or traffic signal pole or constructs and dedicates a new streetlight or traffic signal pole to the City, the City does not require a $200 annual fee. Every SSL is revocable by the City under specified circumstances.

The City continues to improve Design Guidelines for Small Cell infrastructure to maximize its ability to protect the health, safety and welfare of the citizens and residents of Centennial within the parameters of Federal and State law. As of fall 2018, the City has been able to work with Small Cell Carriers to come up with a standard for new poles. For poles located within right-of-way (ROW), the standards generally:

• Normalize pole design elements, color and location to be uniform throughout the City.
• Limit pole heights to 30 feet in agricultural and residential zone districts, to 35 feet when within 250 feet of open space zone districts, and to 40 feet in all other zone districts.
• Require poles be no closer than 600 feet to other poles within ROW. 
• Require poles near residential properties be placed as close to property lines as possible to minimize poles being located directly in “front” of a home.
• Any ground equipment is located in an underground equipment vault or within the pole itself.

Radiofrequency (RF) emissions are a common concern heard from citizens and are regulated by the FCC, not the City. Federal law prevents local governments from regulating wireless facilities based on health or environmental effects of RF emissions. Local governments can only require that carriers certify that they comply with the federal regulations for RF emissions.

LDC Section 12-2-425, Centennial Small Cell Standards (PDF, 11MB)

Small Cell Exhibits (PDF, 3MB)

Photograph of installed Small Cell Pole (PDF, 19MB)

The City of Centennial strongly encourages direct communication with the specific wireless provider or company who is installing specific equipment. Centennial staff is also available to discuss processing and policy related questions by calling the Centennial Planning and Zoning Hotline at 303-754-3308.