Letter
Dear Mr. Acosta:
In its meeting of 19 July, the Commission of Fine Arts was pleased to hear an information presentation regarding the anticipated installation of small-cell telecommunications infrastructure throughout the District of Columbia. The Commission provided comments to assist in the development of guidelines intended to regulate the location and appearance of this equipment.
In their discussion, the Commission members commented on the great potential impact of this new infrastructure—a vast array of thousands of new poles, antennas, and associated equipment in public space across the city; they cautioned that many members of the community may be alarmed by this impact unless it is well controlled. They noted that this proposal for privately operated public infrastructure should be considered similar to other publicly regulated utilities, such as electricity, natural gas, water, and sewers; they emphasized that the small-cell project requires a public advocate to protect public values, not just a facilitator to implement private-sector enterprise. They requested the development of context-sensitive guidelines, such as those used by federal and local transportation agencies that modify standard engineering practices as appropriate for historic districts or sensitive environmental conditions.
The Commission members also raised the concern that this initiative is based on accommodating current technology that may soon become obsolete, leaving communities burdened with unnecessarily large and outmoded infrastructure. They emphasized that successful integration of this new technology into the public realm is a holistic design problem, and they encouraged the direct engagement of artists, architects, industrial designers, and other design professionals, both in the development of guidelines and in the design of the poles and equipment; they suggested that the project sponsors hold a design competition to develop the best solution.
For development of the guidelines, the Commission members supported the use of dedicated poles for this infrastructure and encouraged the maximum use of hoteling, where several vendors share installation sites to reduce the number of new poles; they noted the great impact from multiple poles in public space, especially on streets with narrow sidewalks. Likewise, they recommended that new infrastructure be located first in alleyways, not streets, to reduce visual impact; they also requested further study of the impact of equipment installed in close proximity to residential structures.
The Commission anticipates reviewing the work of the interagency committee as it is developed, as well as further submissions of small-cell installations that fall within its jurisdiction, as required by federal law, including the Shipstead-Luce Act and Old Georgetown Act. As always, the staff is available to assist you.
Sincerely,
/s/Thomas E. Luebke, FAIA
Secretary
Marcel Acosta, Executive Director
National Capital Planning Commission
401 9th Street, NW, Suite 500-N
Washington, DC 20004
cc: Jeff Marootian, D.C. Department of Transportation
Eric Shaw, D.C. Office of Planning