Wireless Telecommunication Services (WTS) Facilities (often referred to as cell antennas or cell towers) and Personal Wireless Service Facilities consist of the equipment and structures involved in receiving telecommunications or radio signals from a mobile radio communications source, and transmitting those signals to land-based telephone lines or mobile phones or devices. WTS facilities typically feature antennas/dishes mounted on rooftops, inside business signs, or on steel towers, with supporting equipment (such as computers and batteries) located inside or outside enclosed buildings.
A WTS Facility project will require the submittal of a Building Permit Application, WTS Application Checklists and other forms. Depending on the scope of work and zoning district of a property, a project may also require a "Conditional Use Authorization" (CU). Ensure the wireless carrier’s name is included in the Project Description field (not just the lessee field) on the building permit application.
Personal Wireless Services Facilities (also known as “oDAS” or Small Cells) are not subject to building permits, nor do they require a Conditional Use Authorization, but are subject to Article 25 of the Public Works Code and permitting by the Department of Public Works. These facilities typically involve the attachment of antennas cabling and equipment (batteries, computers, meters) to wooden poles or steel poles used for street lighting, transit support (electric wires for SFMTA buses and rail), and utility (electricity, cable TV and telephone lines) poles.
It is recommended contacting or visiting Planning staff at the Planning Information Center (PIC) early in the planning of your project. The PIC is located at 1660 Mission Street, ground floor, and may also be reached by phone at (415) 558-6377 or via email at email@example.com.
We also recommend contacting the Department of Building Inspection (DBI) to confirm their requirements (which include two sets of plans) before submitting your Building Permit Application. They can be reached at (415) 558-6088, or at 1660 Mission Street.
Understanding What's Allowed
WTS Facility construction is regulated by the San Francisco Planning Code, the WTS Facility Siting Guidelines (and 2003 Supplement), and applicable State and Federal laws. To maintain the character and purpose of distinct areas in San Francisco, the City's geography has been divided into distinct zoning use districts (view these zoning use districts on the San Francisco Zoning Map and Section 201 of the Planning Code).
For each activity or use of land in a given zoning district, the Code states if that activity or use is either “Permitted,” “Conditional,” or “Not Permitted.” Therefore, knowing the zoning district of a property will help identify what specific limits may apply to a project and which application materials will need to be submitted.
You can find the zoning use district and height limits of a property on San Francisco Property Information Map by entering your address or Assessor's Lot and Block number and choosing the "Zoning" tab.
Review Processes for WTS and Personal Wireless Services Facilities
WTS Facilities are conditionally permitted (requiring a Conditional Use Authorization) in most zoning districts in the City; however, there are a few exceptions:
- Qualifying “Micro” WTS Facilities (Accessory Use) require approval of a Letter of Determination by the Zoning Administrator, along with a building permit, neighborhood notification (if applicable), and fulfilling the application checklist. See also Wireless Planning Advisory Bulletin #3.
- Antenna/dishes used solely to provide in-building services may be exempt from some permitting requirements. See references to Indoor Distributed Antenna Systems (iDAS) in Wireless Planning Advisory Bulletin #3 and to Small Receiving Wireless Systems below.
- WTS Facilities are typically principally permitted in zoning districts with a C, M, MB, or PDR (except PDR-1-B) prefix, such as C-3-O or PDR-2. However, a Conditional Use Authorization would be required for any WTS facility that is subject to any of the following:
Macro WTS facilities are prohibited in the RED (Residential Enclave District) zoning district, which is located in the South of Market Area neighborhood. However, a qualifying “Micro” WTS facility is permitted, subject to neighborhood notification.
Wireless Facilities installed in the public right-of-way (e.g. along public streets) are not subject to the San Francisco Planning Code or WTS Facility Siting Guidelines, but are instead subject to permitting by the Department of Public Works. These “Personal Wireless Services facilities are typically attached to either steel or wooden poles used for street lighting, transit support (electric wires for SFMTA buses and rail), and utility (electricity, cable TV and telephone lines) poles.
- 25 feet above roof, grade or height limit (depending on site). This primarily affects proposed freestanding WTS facilities such as faux water tanks. Per Planning Code – Interpretations: This Section requires conditional use authorization for all antennae that exceed the height limit or roof line of the building on the premises by more than 25 feet, whichever is less. The intent of this legislation was to protect view corridors that could be blocked by large rooftop antennae, such as satellite dishes etc. This legislation was not intended to apply to antennae that do not increase the height or bulk of buildings, such as flush-mounted antennae. Therefore, flush-mounted antennae 25 feet above the height limit applicable to the subject site, but not exceeding the height of the noncomplying structure to which they are attached, do not require conditional use authorization.
- Within 1,000 feet of an “R” District (e.g. RH, RM, RTO) and includes a parabolic antenna with a diameter in excess of three meters or a composite diameter of antennae in excess of six meters. This item is specific to unscreened antennas or dishes.
- An unscreened (from view along adjacent streets and other public areas) WTS facility within the Waterfront 2 or 3 Special Use Districts.
Wireless Facilities mounted on poles are referred to by the City as Personal Wireless Services Facilities, and referred to by wireless carriers as either Small Cells, or Outdoor Distributed Antenna Systems, or the acronym “oDAS.”
In addition to the zoning district and land use regulations in the San Francisco Planning Code and WTS Facility Siting Guidelines, an application will also be reviewed under provisions in all of San Francisco's Municipal Codes, the San Francisco General Plan, and Department policies based on a number of criteria (e.g. the historical significance of a property, the environmental impact of a project, or other regulations).
Here are the most common regulations to consider:
- Design, Noise, and Historic Preservation Review
All WTS facilities, including those not subject to a Conditional Use Authorization, are subject to design review. Most WTS facilities are also subject to historic preservation review, including locations considered Potential Historic resources, and relatively newer buildings within historic districts. The placement of noise-generating (cooling fans) equipment cabinets or (diesel or natural gas) generators may also require review by the Department of Public Health to ensure compliance with the City’s noise limits (see Article 29 of the Police Code).
- Accessory Use Determinations for “Micro” WTS Facilities
Since 1997, the Zoning Administrator has issued Accessory Use Determinations to allow certain WTS installations to be reviewed administratively where Conditional Use would otherwise be required. These installations are considered to be “Micro” facilities (smaller WTS installations that emit less power). If a project requires Neighborhood Notification, the Planning Department mails a notice alerting neighbors and neighborhood groups in the vicinity of a proposed project who are given a period of 30 days to respond with concerns, or to request a Discretionary Review (DR). For more information see Wireless Planning Advisory Bulletin #3.
- Federal Telecommunications Act of 1996
The Federal Government adopted the Telecommunications Act of 1996 that established limits on local jurisdiction regulation of wireless facilities. Among other things, the Act specifically prohibits local jurisdictions from disapproving wireless facilities for public health concerns or denying a permit without "substantial evidence" in a written record. Local jurisdictions retain land use authority and can regulate the height, location, visual impact, and/or zoning compliance of a new WTS antennas.
The Act's guidelines preserve state and local authority over zoning and land use decisions for personal wireless service facilities, but sets forth specific limitations on that authority. Namely, a state or local government:
- may not discriminate among WTS providers
- may not regulate WTS in a manner that prohibits the provision of personal wireless services
- must act on WTS applications within a reasonable period of time
- must make any denial of an WTS application in writing supported by substantial evidence
The statute also preempts local decisions on the environmental effects (or health concerns) of radio frequency (RF) emissions, assuming that the provider is in compliance with Federal regulations. Allegations that a local jurisdiction has acted inappropriately would be resolved in court. The City requires testing after a facility is built as well as every two (2) years; and after modifications are made that can affect RF emissions output (e.g. antenna swaps or addition of radio relay units). RF emissions testing can be provided for residents (in their homes) at no charge.
- Wireless Telecommunication Services ("WTS") Facilities Siting Guidelines
The Wireless Telecommunication Services (WTS) Facilities Siting Guidelines (and 2003 Supplement) adopted by the Planning Commission on August 15, 1996, created a preference schedule for WTS-friendly zoning districts and land uses and provided procedures for review and approval by the San Francisco Planning Department and the Planning Commission. We suggest reviewing these guidelines and application checklists to further familiarize the WTS permitting procedures in San Francisco.
- Community Meetings for Conditionally Permitted Facilities
A Community Meeting is required before an application for a Conditional Use Authorization is considered complete. The meeting requires notification to all property owners and tenants within 500 feet of the Project site, and neighborhood groups registered with the Planning Department. See the application checklist for Conditionally Permitted WTS Facilities.
- Compliance with Residential Design Guidelines
In addition to the specific requirements of the Planning Code, projects on residential buildings in Residential districts must conform to the Residential Design Guidelines that insure that the project's scale and architectural character are consistent with the surrounding neighborhood.
- Compliance with Building and Fire Codes
Ensure project plans, RF emissions reports, and structural analysis demonstrate compliance with Building and Fire Codes, including San Francisco Fire Department Bulletin 2.06
- Compliance with Air Quality Rules
Diesel, natural gas, or propane generators (typically used for backup power in the event of a power outage) require Building and Fire review, as well as permitting by the Bay Area Air Quality Management District. The majority of WTS facilities in San Francisco do not feature generators, as most utilize batteries to provide backup power.
- Compliance with Planning Code. Relevant provisions include height limits, required rear yard area and usable open space requirements (e.g. for equipment areas). WTS facilities are classified as a “Public Use” in neighborhood commercial districts, and are limited to certain floors (roof levels) as noted in the Controls by Story rules in the Inner Sunset, Pacific Avenue, and West Portal Neighborhood Commercial Districts (NCDs). Consult with Planning Department staff in advance of considering specific locations in these three NCDs.
- Compliance with Height Limits
Antennas and towers are exempt from height limits. However, screening elements are not, with a few exceptions:
- Faux vent pipes or stairwell/elevator/mechanical penthouses up to 10 feet (or 16 feet for height districts greater than 16 feet) above the height limit.
- Faux parapets up to four (4) feet above the height limit.
- Modest horizontal-only expansions (typically 18 inches) of existing rooftop penthouses, for existing rooftop elements well above the height limit. Subject to Zoning Administrator review.
- Freestanding panel antennas with a “back wrap” to screen the rear of the panel antenna and the accompanying pipe mount. Please note this is a limited preference design and will typically require placement further back from roof edges.
- Additional siting types require review of Planning Code Section 260 and a determination by the Zoning Administrator.
- There are no variances available to exceed height limits.
Applying for a Permit and Payment of Fees
The following information must be submitted when applying to construct or modify a WTS facility:
- Construction plans and/or drawings (two sets)
A map of your construction site must be submitted as described in the application packet and full-size architectural plans with dimensions in feet of: the building height; any roof or penthouse height; parapet wall height; and existing and proposed WTS equipment.
Photo-simulations are submitted to document the proposed aesthetic impact of an installation. Based on the submitted plans, the applicant should depict the antennas, equipment cabinets and any stealthing/screening component that would be visible from the street. Photo simulations should be based on photos taken from nearby sidewalks and public parks or plazas. If the scope of work involves exterior alterations, copy the photo simulations (in legible format) onto the construction plans, on a sheet preceding the site plan sheet.
- Building Permit Application
A building permit along with materials required in the applicable WTS facility application checklists. Ensure the wireless carrier’s name is included in the Project Description field (in addition to the lessee field, if applicable) on the permit application.
- Section 106 Declaration of Intent
Each site that impacts a resource or potential historic resource must comply with the National Historic Preservation Act by conducting a Section 106 review -- the Federal law establishing Federal agencies' responsibility to take account of the effect of their actions on structures that have been rated historic resources (see Historic Preservation for more info). Although the review for compliance rests outside local jurisdictions, the Planning Department requires a Declaration of Intent to comply.
- Wireless Telecommunications Facility Application Checklist
Based on the type of application needed, complete one of the four WTS applications by which the Planning Department and/or the Planning Commission review new installations or modifications to existing sites (contact the PIC if you are uncertain as to which category applies to your project).
A variance may also be required for facilities that do not comply with applicable required side yard area, rear yard area, or usable open space requirements. Variances are reviewed by the Zoning Administrator.
A Minor Permit to Alter (MPTA) or Administrative Certificate of Appropriateness (ACOA) may also be required for WTS facilities at specific buildings considered historic resources (and subject to Articles 10 or 11); as well as “newer” buildings located in Article 10 or 11 Districts. See references to ACOA in Wireless Planning Advisory Bulletin #3. The process is similar for MTPAs, though with a different application form and approval findings.
An ACOA/MPTA is not required for a scope of work involving only equipment within existing fully enclosed rooms. The addition of radio relay units, for example, on a rooftop would require an ACOA/MPTA.
- Visit the San Francisco Property Information Map, and enter the address of the Project Site, then choose the Preservation tab. If there is a notation in the Article 10 field, then an ACOA will be required. This applies to new buildings in Article 10 Districts as well.
- If there is a notation in both the Article 10 and 11 fields, only an ACOA will be required.
If there is a notation in the Article 11 field, then an MPTA will be required. However, this requirement does not apply if both of the following apply: a) the Project Site is noted as Category V – Unrated Building; and b) the Article 11 district does not mention an actual “named” Article 11 District (e.g. Kearny-Market-Mason-Sutter, or Front-California, etcetera).
- 5-Year Plan
A current 5-Year Plan must be on file with the Department in order to process any new applications. The plan must be updated bi-annually April 1, and Oct 1, listing proposed WTS sites over that period and certain other details of equipment such as the type of technology, radio frequencies and types of consumer services (see "Section 10" of the Wireless Telecommunication Services (WTS) Facilities Siting Guidelines). A map of existing WTS Facilities can be found in the Planning Department’s website (choose Resource Center, then Map Library).
- Project Implementation Reports ("PIR") must be up-to-date for your existing WTS sites
PIR are emission reports to demonstrate that each site is within Federal Communications Commission (FCC) established thresholds for emissions. Although Federal regulations prohibit local jurisdictions from denying applications based on the potential/perceived health hazards, the WTS Guidelines require service providers to document that their facilities are operating within the established standards. Based on the PIRs submitted to the Department of Public Health (DPH) for verification, facilities operating at maximum power do not typically approach the maximum threshold for human exposure, rarely exceeding 2% of the maximum exposure level.
- Current Emissions Report
An RF emissions report (template) and project plans reviewed by the Department of Public Health (DPH) for accuracy for your proposed WTS site will be required.
To submit a permit, prepare the Building Permit or Conditional Use Authorization Application and bring it along with all necessary plans and materials as described in the Permit Application Checklist and/or Building Application Packet to the Department of Building Inspection (DBI) at 1660 Mission Street. If you are a new user, we recommend you come to the Planning Information Center (PIC) also at 1660 Mission Street before proceeding to DBI.
Permit fees are based on the construction cost of your project. To estimate permit fees, the Planning Department's fee schedule is available online. There is also a fee calculator for Building Permits reviewed by the Planning Department. If there are any questions, please stop by or call the Planning Information Center (PIC) staff at (415) 558-6377. Depending on location and project type, impact fees may be required for new construction. Contact the PIC to see if these requirements apply to a property. Please note this is for the Planning Department's review fees only. Fees for review by the Building Department are available here. You may also call DBI at 558-6088.
Please Note: Should the cost of staff time exceed the initial fee paid, it is possible an additional fee for time and materials may be billed upon completion of the permit review process. Additional fees may also be collected for preparation and recordation of any documents with the San Francisco Assessor-Recorder’s office and for monitoring compliance with any conditions of approval.
Permit Review Process
WTS Facilities are reviewed and authorized by the Planning Commission through a Conditional Use Application and/or the Planning Department through a Building Permit Application (“BPA”).
Facilities that are conditionally permitted through a Conditional Use Application process are reviewed by the Planning Department and the Planning Commission, and are appealable to the Board of Supervisors.
Facilities that are principally permitted through a Building Permit Application are reviewed only by the Planning Department, unless review is requested by the Historic Preservation Commission, or a Discretionary Review (DR) is filed during the Neighborhood Notification process, which would cause the BPA to be reviewed by the Planning Commission. BPAs (if issued) are appealable to the Board of Appeals.
Preferred Location Sites
Section 8.1 of the WTS Facility Siting Guidelines establishes a “preference schedule” based on the proposed site's zoning district and existing use. Generally:
- Preferred Location Sites include public structures; industrial and commercial structures; mixed use buildings and co-location sites (multiple providers);
- Limited Preference Sites are sited in Neighborhood Commercial Districts;
- Disfavored Sites are residentially zoned sites.
Conditional Use Application Approval
While many Conditional Use applications for WTS facilities are approved, not all Conditional Use applications submitted to the Planning Department are forwarded to the Planning Commission with a recommendation for approval. Many applications that are not supported by the Department are withdrawn by the applicant or cancelled by the Department.
A Shadow Study may also be required for new elements (e.g. screening) over 40 feet in height in locations where it may cast a shadow on a City park (and other properties per Planning Code Section 295).
Other potential requirements may include ACOAs/MPTAs (historic preservation), variances (e.g. required rear yard areas and usable open space), and an environmental evaluation application (typically for freestanding facilities or those involving significant ground disturbances). Civic Design Review, by the San Francisco Arts Commission, may be required for WTS facilities on City properties (not including the Airport, or Port of San Francisco). Diesel, natural gas, or propane generators also require permitting by the Bay Area Air Quality Management District.
Inspection of permitted work is the responsibility of the Department of Building Inspection (DBI). DBI's Inspection Services page explains their inspection function.
For permit scopes involving work outside of an enclosed building (e.g. rooftops or facades), Planning Department staff typically requires site photos to be reviewed by the case planner prior to the contractor requesting a final permit inspection from DBI.
Land Use Jurisdiction
WTS Facility review and permitting is subject to specific land use jurisdiction requirements.
For example, a WTS facility proposed in areas under jurisdiction of the Port of San Francisco would not typically be reviewed by Planning Department staff, or the Planning Commission. However, WTS facilities within Port areas that also fall within the Northeast Waterfront Landmark District would require an Administrative Certificate of Appropriateness (if eligible). See BSM Map Viewer, choose Jurisdiction, then Port of San Francisco.
WTS facilities in portions of Candlestick Point, Hunters Point, and Mission Bay, Transbay and Rincon Point (South Beach) fall under jurisdiction of the Office of Community Investment and Infrastructure (OCII). To determine if a Project Site falls within OCII jurisdiction look up the Project site on the Property Information Map, then choose the Zoning tab.
For more information review the Land Use Jurisdiction section of Wireless Planning Advisory Bulletin #3. The jurisdiction list within Bulletin #3 also applies to most Macro WTS facilities.
Small Receiving Wireless Facilities
Small satellite dishes used for indoor video (TV) reception, as well as small microwave dishes (or similar antennas) installed by Wireless Internet Service Providers (WISPs) to provide indoor internet access are typically exempt from permitting requirements (with typically two dishes allowed per customer).
However, there are three primary exceptions where permitting or City review may be required:
- Structural Safety. Antennas/dishes mounted on masts or new structures over six (6) feet typically require review by the Department of Building Inspection. A key concern would include, but is not limited to, ensuring that antennas/dishes are securely installed, taking into account wind loads and attachment mechanisms.
- Historic Preservation. Antennas/dishes mounted in certain locations may not comply with the US Secretary of the Interiors Standards for the Treatment of Historic Properties. For example, mounting locations on the primary facades (main building walls facing streets) or street facing roof edges of buildings over 45 years of age may not be allowed. Generally, antennas/dishes should be:
- Moved far back enough from roof edges so as to be minimally visible from view along surrounding sidewalks.
- Not attached to elements considered character-defining or demonstrating detailed craftsmanship.
- Be painted (antenna, brackets, cabling, dishes, mounting elements) light (non-glossy) grey (using a paint type that will not block transmission), with no large logos or decals visible from surrounding sidewalks.
- Installed so that any indicator lights or other illumination is shielded from view.
- Hub/Relay Facilities. Antennas/dishes used as part of a hub to relay signals among multiple locations (or off-site) are subject to permitting (and Planning review).
For more information review the Over the Air Receiving Device Rules adopted by the Federal Communications Commission (FCC).
Amateur Radio (Citizens Band/HAM Radio) is subject to separate rules established by the FCC that seeks to balance local jurisdiction review (e.g. height, visibility, environmental and historic preservation) with the unique technical radio operation requirements for a given system. It is recommended operators discuss the specific antenna proposal with Planning Department staff. Most freestanding antennas and support structures for these facilities require permitting by the Department of Building Inspection.
Consumer grade Wi-Fi antennas (or access points) used to provide on-site internet access within a building or “campus” is not typically subject to permitting requirements (or Department of Public Health review). However, antennas installations in buildings considered historic resources should ensure installations do not damage or impair character-defining elements (e.g. original murals). If in doubt, please provide site photos depicting installation locations to a Preservation Planner at the Planning Information Center.
Cell-On-Wheels (COWs) – Temporary Wireless Facilities
COWs are typically used to provide additional temporary wireless coverage/capacity for large events such as parades and festivals, or to provide coverage during redevelopment of project site where major renovation or demolition is occurring at a building with an existing (permanent) rooftop-mounted WTS facility. A COW usually consists of a truck with a 15- to 45-foot tall mast that holds up cell antennas and microwave dishes. Electrical power may be provided by a nearby building or a generator.
Permits for COWs to support temporary events where the COW is proposed on a public street or sidewalk are administered by the Department of Public Works – Bureau of Street Use & Mapping (Temporary Occupancy Permit Requirements).
Permits for COWs at City parks (e.g. for festivals) are typically administered by the Recreations and Parks Department.
Permits for COWs along the eastern waterfront (e.g. piers) are typically reviewed by the Port of San Francisco. See BSM Map Viewer, choose Jurisdiction, then Port of San Francisco.
Permits for COWs (or temporary rooftop-mounted antennas/dishes) on private property are subject to building permits (with the carrier name and the length of the permit clearly noted in the building permit description and on the cover sheet of the project plans), and are reviewed by Planning Department staff and the Zoning Administrator. Ensure a structural analysis (e.g. wind load) is prepared, if needed for temporary rooftop-mounted facilities.
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