Palo Alto ARB reviews wireless siting standards, urges clear criteria as AT&T prepares cluster applications

The Palo Alto Architectural Review Board on July 16 held a study session on revising process and design standards for tier 2 and tier 3 wireless facilities in the public right of way, with staff seeking the board’s guidance before drafting a replacement ordinance for council consideration.

The session followed the City Council’s May direction to revisit standards that were repealed in 2025. Nishita Kamekopa, the city project lead, told the board that council also asked staff to study “the technical feasibility of placing cell towers at a 100-foot setback from residential structures in Palo Alto and a 1,500-foot setback from schools and day care facilities.” She showed a map of Downtown North demonstrating that a 100-foot residential buffer would severely limit pole-mounted installations in parts of the city.

Why it matters: the prior objective standards were a predictable checklist for applicants; without them, the city must balance federal shot-clock deadlines that force decisions within 60–90 days for tier 2 applications against community design and safety preferences. The board’s input will shape whether some routine installations can be streamlined or require full ARB review.

Legal limits and local discretion

Gail Karish, special counsel advising the city, summarized the legal background: a Federal Communications Commission order setting small‑cell rules had required objective aesthetic standards, but the 9th U.S. Circuit Court of Appeals later removed the ‘‘objective-only’’ requirement and said aesthetics must be reasonable and published in advance. Karish said that change gives cities more discretion on aesthetic review but does not restore authority that federal law preempts, such as setting new RF-emission limits.

Staff and counsel repeatedly told the board that radio-frequency (RF) safety standards remain federal and the city cannot substitute its own exposure limits. Kyle Arellano, chief assistant city attorney, said the remaining local tools are design, concealment, routing and process; objective standards can help the city meet required shot-clock timelines by clarifying expectations for applicants.

Public comment and carrier designs

AT&T representatives addressed the board during public comment and described a cluster application they plan to file. Courtney Perillo, AT&T wireless construction director for Northern California, said the company expects most of its sites to be categorized as tier 2 — subject to a 60–90 day shot clock — and asked for clear, consistent approval criteria so applicants can meet the deadline and reduce revisions. “We want to partner with you,” Perillo said, urging criteria that are both usable and technically feasible.

AT&T presenters showed concealment options for wood utility poles and streetlight poles, with some shrouds listed under the 28-cubic-foot threshold that defines many tier 2 cases. Mark Grabisch, program manager, said manufacturers limit the extent to which active radio equipment can be undergrounded and that underground vaults are often too large or conflict with existing utilities.

Board concerns and process options

Board members asked detailed questions about what must remain above ground, how to measure ‘‘substantial changes’’ that trigger tier 3 review, and whether RF heat maps or directional antenna characteristics will be part of staff review. Several members proposed a two‑track approach: maintain tier 3 applications for full ARB review, while allowing a limited set of toleranced or ‘‘preapproved’’ designs (for example, specific streetlamp types and maximum volume) to be handled administratively to speed tier 2 decisions and meet shot clocks.

Nishita Kamekopa said staff supports the idea of objective standards as a starting point and that some categories of application could be cleared without full ARB hearings if the board identifies them.

Next steps

The board asked staff for example drawings of previously approved pole-mounted installations and agreed to form an ad hoc committee (two board members volunteered) to draft recommended edits to the prior objective standards. Staff asked the ad hoc to provide track changes by the end of next week so staff can prepare a short packet and memo for the board’s August 6 meeting; the board’s recommendations will then feed into Planning & Transportation Commission and council consideration.

What was not decided

No ordinance was adopted at the meeting; the board provided direction and asked for concrete examples and draft edits to consider at the next meeting. Staff and counsel emphasized that any locally adopted standards must still respect federal timelines and preemptions, including RF safety limits and certain FCC-prescribed dimensional rules.

The study session concluded with staff committing to gather prior project drawings and to use the board’s feedback to prepare a draft for the next packet.