Board upholds Planning Department’s categorical exemption for T‑Mobile microcell on Grant Avenue after neighborhood appeal

The Board of Supervisors on April 12 affirmed the Planning Department’s determination that a proposed T‑Mobile microcell antenna at 1653 Grant Avenue is categorically exempt from CEQA review. The decision followed a contested hearing in which neighbors and advocacy groups argued the Department had not adequately considered cumulative radio‑frequency (RF) exposure from multiple sources and that the site is a "disfavored" residential location under the Planning Department’s wireless siting guidelines.

Appellants said there are hundreds of existing and proposed antennas in and near North Beach and presented maps and internet‑sourced counts to argue for cumulative review; they urged the board to reject the categorical exemption and require environmental review of cumulative RF impacts. Appellants also raised siting‑preference concerns set out in the department’s own wireless guidelines and asked that the city examine whether the location was truly "essential".

Planning and Department of Public Health staff testified that San Francisco maintains an extensive review process and that each installation must file RF emissions reports and post‑installation measurements; DPH staff reported on‑site cumulative RF measurements in the neighborhood that were well below federal exposure limits (readings cited at under 1% of the Federal Communications Commission standard and the highest measured point reported at roughly 0.21% near an existing site). Planning staff said the CEQA categorical exemption for small utility structures (Class 3) applies where there is no substantial evidence of unusual circumstances that could create a significant environmental effect.

The city attorney advised the board that federal law preempts local denial of permits that are based solely on RF health concerns if the facility complies with FCC limits; planning and DPH staff described ongoing measurement and monitoring requirements including initial ambient studies, post‑installation readings and periodic remeasurement.

After public testimony from opponents and proponents, the board voted to affirm the Planning Department’s exemption determination (9 ayes, 2 nos). The board also asked planning staff to consider citywide planning options for wireless siting and to evaluate whether additional administrative procedures are warranted for microcells in residential areas.

Why it matters: The decision clarifies that — absent substantial evidence of an unusual circumstance — the city will continue to treat small rooftop microcells as eligible for a Class 3 categorical exemption, while acknowledging neighborhood concerns about density of installations and the need for outreach and improved siting guidance.