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Message from Ann Loikow regarding hearings on antenna placement

Public comments accepted until November 8 at 3:00 pmsee below ]

November 3, 2002


Testimony of the Cleveland Park Citizens Association
Statement of the Office of the People's Counsel
Zoning Commission notice of public hearing: PDF | Word
Office of Planning memorandum: PDF | Word

The Zoning Commission completed its hearing on Case No. 01-02 (Text Amendment - Regulation of Antennas, Antenna towers, and Monopoles) on Monday, Oct. 21, when it heard the rest of the witnesses opposing the Office of Planning's proposed revisions to the District's zoning regulations governing antennas.  Witnesses who supported the OP proposal, but were unable to come to the first session of the hearing on Oct. 17, were not allowed to testify and had to submit their comments for the record.

The two major things the opponents (primarily the wireless telecommunications industry) opposed were:

  1. the proposed ban on new antenna towers (broadcast towers) and monopoles in residential districts and the C-1 (neighborhood commercial) district; and
  2. the requirement in the new section 2601 that applicants for new transmitting antennas certify that the proposed antenna will comply with FCC radio frequency (RF) radiation emission guidelines and OSHA health and safety regulations and that the certification include information on the RF to be generated by the proposed antenna and the cumulative RF radiation generated by all other antennas at the proposed site and within 200 feet.

The opponents argued that, outside of NW, many areas are zoned residential and there are few tall buildings on which to mount antennas so that they will need to build new monopoles in order to increase their coverage.  As demand increases, they said they have to point the antennas down more, making the "cell" smaller, and thus need to add many more antennas for new cells to have the same area of coverage.  They also argued that providing the information on RF radiation emissions, particularly regarding cumulative RF radiation, would be overly burdensome adn that all they should be required to do is just "certify" that they comply.

It is very important that citizens go on the record supporting OP's proposals.  The first provision protects our neighborhoods and homes. As OP has stated, antenna towers and monopoles are inconsistent with the purposes of these zoning districts adn that is why they proposed prohibiting the construction of new ones there.  The second provision provides the city (and citizens), for the first time, real information on what is out there, what levels of RF radiation are around the city and gives the District Government (through the Department of Health) a baseline from which it can monitor RF radiation levels and take enforcement action if the FCC guidelines are exceeded in any location.

As I mentioned in an earlier email, Peter Roy, Deputy Director OCTO (DC Government's technology office), testified asking for total exemption from any zoning regulation for the District Government's 911 and emergency services. His presentation sounded virtually like DDOT's presentation on street furniture before Carol Schwartz's committee a few weeks ago.  He basically asked to have the law not apply to OCTO because they want to avoid the hassle of going through the right process and don't appear to think they could get their act together in time to do things properly and legally.  Commission Chair Carol Mitten asked him to submit pictures of what his antennas would look like and a list of the 10 places they wanted to put them so the Commission could determine whether there really was an issue. We need citizens to write in and oppose exempting the District Government from the antenna regulations.  The regulations are in place to ensure that any new antenna is properly reviewed and sited so as to serve its function and yet avoid or minimize harm to the public.  It is becoming a pattern that the Executive Branch of the DC Government comes in seeking exemptions from the rules and law on the flimsiest of excuses.

Also, you should be aware that the opponents said they would like to be able to more freely put antennas in public space, such as on parkland and school property, or on utility poles (see Foxhall Road for some existing installations). The monopole at Garfield Elementary on Alabama Avenue in Ward 8 (to serve the Suitland Parkway) was cited as a model solution on antenna siting. Also, note that the stealth provisions in the proposed regulation, which OP amended to request that they be subject to the special exception process, are another way antennas (and monopoles in disguise, such as the flagpole at St. John's College High School on Military Road) may be built in residential areas. Citizens generally opposed the stealth provisions and urged that the matter of right antenna provisions apply instead, with perhaps some additional language regarding screening.

I have attached the testimony of the Cleveland Park Citizens Association and the Office of People's Counsel on the proposed OP regulation the end of this e-mail so you can read a fuller discussion of the issues in the case. The OP proposals are also attached as MS Word documents [ see links above ].

The hearing record is open until Nov. 8 at 3:00 pm.  Send comment letters regarding Zoning Commission Case No. 01-02 to

Mr. Alberto P. Bastida, AICP
Secretary to the Zoning Commission
Office of Zoning
441 4th St. NW, Suite 210
Washington, DC 20001.

They can also be faxed to 202-727-6072 or e-mailed to  Please send me a copy of any letter you submit.

Remember this is the "war" (as this case sets the rules that will apply to every antenna and antenna tower for years to come); Rock Creek Park, Tenley, and Penn Branch were just the opening "battles."

Thanks so much.

Ann Loikow

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