1STATEMENT OF
COMMISSIONER AJIT PAI
Re: Acceleration of Broadband Deployment by Improving Wireless Facilities Siting Policies, WT 
Docket No. 13-238; Acceleration of Broadband Deployment: Expanding the Reach and 
Reducing the Cost of Broadband Deployment by Improving Policies Regarding Public Rights 
of Way and Wireless Facilities Siting, WC Docket No. 11-59; Amendment of Parts 1 and 17 of 
the Commission’s Rules Regarding Public Notice Procedures for Processing Antenna 
Structure Registration Applications for Certain Temporary Towers, RM-11688; 2012 Biennial 
Review of Telecommunications Regulations, WT Docket No. 13-32.
In July 2012, I met some entrepreneurs in San Francisco who were developing cutting-edge 
applications for mobile devices. I was impressed by their work on things like instant video optimization 
and mobile cloud computing. But what I found most striking—and not in a good way—was their 
response to a question about bottlenecks in the wireless industry. They brought up the usual suspects like 
spectrum, but they also mentioned how ridiculous it was that they couldn’t get a good signal in their own 
building. Why? Because regulations made it nearly impossible for any wireless company to deploy more 
physical infrastructure in the city.
So what did these innovators do? They innovated. On the roof of their building, they built a 
wireless mesh network using chicken wire. Let me posit here that something has gone wrong with 
regulation—really wrong—if the best wireless solution for entrepreneurs in San Francisco is the same 
technology that farmers in Kansas use to keep wayward birds in the coop.
This experience informs my view that wireless infrastructure often seems to be the unsung hero 
of the ongoing mobile broadband revolution.  We don’t talk about it much, but without vast networks of 
towers, rooftop antennas, microcells, picocells, distributed antenna systems (DAS), and other types of 
physical infrastructure, Americans wouldn’t be able to send emails, surf the web, or watch video over 
their wireless devices.  And as our use of tablets and smartphones proliferates, so too does the need to 
deploy more wireless infrastructure to accommodate more mobile data traffic.
But as my opening suggests, it’s not easy to deploy wireless infrastructure in the United States.  
The federal government has erected some unnecessary obstacles. Federal regulations that were written 
with two-hundred-foot tall towers in mind just don’t make sense when applied to recent innovations like 
small cells.  State and local governments have slowed deployment as well.  Every consumer wants fast, 
dependable wireless service in his or her neighborhood.  But many aren’t as enthusiastic about having 
nearby the physical infrastructure that makes such service possible.  This kind of “not in my back yard” 
sentiment can lead municipalities to needlessly delay or block the installation of wireless infrastructure.
To remove these roadblocks, I proposed last fall a comprehensive set of reforms to expedite the 
deployment of wireless infrastructure.  Specifically, I called for the Commission to: (1) exempt DAS from 
our environmental processing requirements; (2) update our historic preservation regulations to take 
account of DAS and small cells; (3) declare that the shot clock adopted by the Commission in 2009 
applies to DAS; (4) make clear that local moratoria on the approval of new wireless infrastructure that 
evade the Commission’s shot clock violate section 332(c)(7) of the Communications Act; and (5) provide 
that if a local government does not act on a wireless facilities application by the end of our shot clock, 
that application will be deemed granted, as is the case in the video franchising context.
1
I’m excited that, less than a year later, the Commission is seeking comment on all of these ideas
in today’s Notice of Proposed Rulemaking (NPRM).  I’m also pleased that we are soliciting feedback on 
                                                     
1
Remarks of Commissioner Ajit Pai at CTIA’s MobileCon, San Diego, California (Oct. 10, 2012), 
http://go.usa.gov/Dd6k.
2other worthwhile proposals to implement Section 6409(a) of the Spectrum Act and to permanently 
exempt temporary towers from pre-construction environmental notification requirements.
I am particularly happy that we seek comment on whether to adopt a “deemed granted” remedy 
for violations of both Section 6409(a) of the Spectrum Act and Section 332(c)(7) of the Communications 
Act.  Right now, if a city does not process an application by the end of the FCC’s shot clock, an 
applicant’s only remedy is to file a lawsuit. In other words, the solution to municipal delay is . . . 
litigation, a word that is often synonymous with delay. In one case, for example, Sprint was forced to 
battle for seven years in federal and state courts as it attempted to build two towers in Los Angeles 
County.
If a local government does not act on a wireless facilities application by the end of the shot clock, 
I believe that application should be deemed granted. This would maximize the incentive for local 
governments to rule on applications promptly.  It would allow companies to stop litigating over 
infrastructure and start building it.
On all of the issues that are teed up in today’s NPRM, it is critical that we move forward with 
alacrity.  Indeed, we should bring the same urgency to the task that animates our push to make available 
additional spectrum for mobile broadband.  For if our efforts on wireless infrastructure falter, much of our 
work on spectrum will be for naught.  After all, even an unlimited supply of spectrum won’t mean much 
without the infrastructure to carry wireless traffic to its destination.
I thank Chairwoman Clyburn for her leadership on this item and the staff in the Wireless 
Telecommunications Bureau for all of their hard work:  Jeffrey Steinberg, Peter Trachtenberg, Mania 
Baghdadi, Won Kim, Michael C. Smith, Joyce Jones, Ivy Harris, Donald Johnson, Saurbh Chhabra, 
Stephen Delsordo, Weiren Wang, Ruth Milkman, Jane Jackson, Maria Kirby, and Jessica Almond.  The 
success of your efforts is evident to us today and will be evident to consumers in years to come when they 
enjoy better, more reliable, more advanced wireless services.