CFA 20/SEP/18-3


throughout the city
Washington, DC
United States

D.C. Department of Transportation
Small cell infrastructure in public space
Draft guidelines for the installation of low-power antennas for cellular and data communication
Review Type
Previous Review


Dear Mr. Marootian:

In its meeting of 20 September, the Commission of Fine Arts reviewed a proposal for draft guidelines addressing the installation of small-cell telecommunications infrastructure throughout the District of Columbia. The Commission endorsed a programmatic approach for the review of this initiative but did not take an action, providing the following comments to assist in the refinement of these guidelines.

The Commission members expressed appreciation for the continued development of the guidelines intended to regulate the location and appearance of small-cell installations, and they acknowledged the important comments provided by the public—which include concerns regarding aesthetics, public health, and the local and federal review process for this infrastructure. They noted the fundamental inconsistency between the elegance and precision of contemporary consumer cellular devices and the obtrusive appearance of the infrastructure systems required to support them; while most residents would welcome increased service capacity, there is little apparent support from the community for the imposition of more visual clutter in the public realm. They observed that the city’s existing lampposts and fixtures were developed at particular times with particular performance standards, ranging from iconic early twentieth-century Beaux-Arts designs to more functional modern designs; they affirmed that these are not suitable for small-cell equipment installations. They therefore advised the development of an elegant and holistic design typology for the small-cell installations, rather than allowing a discordant kit of parts—antennas, equipment cabinets, and cables—to be clumsily attached to existing or new streetlight poles. They encouraged a more expansive study of best practices and design approaches for similar infrastructure in the U.S. and abroad to help develop a forward-looking solution that is not merely expedient but which appropriately integrates this technology into the public realm.

The Commission members offered several additional suggestions for the guidelines as they are refined, such as incorporating the matrix of allowable small-cell installations developed by the Commission staff. They also commented that the draft guidelines require further changes to meet the stated goal of treating all areas of the city equitably; they suggested consideration of applying consistent standards across the entire city, such as requiring underground equipment vaults in all locations. They noted that the city is composed of numerous types of public spaces with unique experiential qualities, and they advised the development of three-dimensional, parametric design drawings to test the proposed pole type, location, and spacing matrices set forth in the guidelines. They also requested the construction of full-scale mockups to evaluate the design details and overall impact of the complete assemblies.

The Commission anticipates the continued review of the guidelines for this major public infrastructure project and encourages discussions with other stakeholders as the project progresses through the review process. As always, the staff is available to assist you.


/s/Thomas E. Luebke, FAIA

Jeff Marootian, Director
D.C. Department of Transportation
55 M Street, SE, Suite 400
Washington, DC 20003

cc: Marcel Acosta, National Capital Planning Commission
Peter May, National Park Service
Mina Wright, General Services Administration
Eric Shaw, D.C. Office of Planning