Board upholds categorical exemption for small Sutro Tower antenna additions after lengthy debate

The San Francisco Board of Supervisors on Oct. 24 affirmed the Planning Department's categorical exemption under the California Environmental Quality Act (CEQA) for a request to replace four receive-only broadcast auxiliary antennas and add one additional receive-only antenna at Sutro Tower, and directed the clerk to prepare findings. The board tabled a separate motion seeking to overturn the department's exemption determination.

Neighbors and public-health and safety witnesses told supervisors the tower's steady accretion of antennas warrants a fuller environmental review, citing visual impacts, potential interference with nearby city facilities and the presence of large public projects nearby. Planning staff, tower representatives and broadcasters said the proposed equipment is receive-only (it does not transmit RF) and that prior environmental review and technical reports demonstrate no new significant impacts.

The vote on motions to affirm the exemption and to direct the clerk to prepare findings was approved; a motion to disapprove the exemption determination was tabled. Board debate focused on whether a line-by-line, incremental approach to antenna approvals could produce a cumulative impact that would require a supplemental environmental study.

The appellant and neighborhood groups argued the city's historical review of Sutro Tower did not address recent growth in the number and variety of antennas and that nearby projects ' notably the county juvenile hall replacement project and the Laguna Honda Hospital replacement project ' raise the stakes for possible interference or other site-specific impacts. Appellants submitted technical papers and cited research they said supported further review; they also asked the board to consider the tower's history of conditional-use questions and repeated permitting actions.

Planning Department staff, represented at the hearing, told the board the Oct. 3, 2006 determination relied on the Class 1 categorical exemption for minor alterations to existing facilities with negligible or no expansion of use. Staff said prior environmental review, including a 1998 Environmental Impact Report assessing the tower's cumulative effects (prepared for DTV conversion), and subsequent technical studies do not show significant new impacts from the specific receive-only antennas proposed. The planning department further noted federal law restricts local jurisdictions from regulating RF emissions within FCC limits.

Representatives for Sutro Tower and the broadcasters added technical testimony that the requested receive-only antennas emit no radiofrequency radiation and described the additions as small in size and sited either high on the tower or behind rooftop equipment, where they are visually limited. Sprint Nextel and local public safety partners also appeared; Sprint said the broader, citywide equipment realignments are required by an FCC-directed band reconfiguration to protect public-safety communications and that the Sutro work is one element of hundreds of similar, nationwide changes.

Supervisor discussion ranged from the narrow legal question before the board ' whether the Planning Department's categorical exemption was appropriate for this particular application ' to broader concerns about incremental approvals and the point at which cumulative change becomes significant. Several supervisors said the Sutro debate highlights the need for a future, broader evaluation but that the specific receive-only antennas in this application do not, on their own, trigger a deeper CEQA review.

The board approved the motions affirming the exemption and directing the clerk to prepare findings; the motion to disapprove the exemption was tabled. The board record will include the appellants' submissions and the planning department's response materials.

The matter will remain on the record for potential future review if substantially different or larger proposals return to the Planning Department. The board's action affirms the department's use of a Class 1 exemption for this narrow set of equipment changes at Sutro Tower.