FAQ for Buildings Bulletin 2021-011 (Cellular Antennas)

Click a topic, or press the enter key on a topic, to reveal its answer.

Section III-D: Chimneys and Smokestacks as Other Structure

Buildings Bulletin 2021-011 specifies that antennas must be attached to a building or structure with an independent use. If the supporting structure is a chimney or smokestack, must it be currently active?

In the case of a chimney or smokestack, such structures must have been legally approved as part of the building. Therefore, the antenna may be attached to the chimney or smokestack, regardless of its active use. Applicants should confirm the clearance requirements when mounting on active chimneys or smokestacks.

Section V-A: Antennas Attached to Building Façades on a Street Line

What allowances are contained in the Code that address façade or parapet mounted antennas extending beyond the street line?

Allowable projections are based on mounting height. Antennas must comply with Section 3202.2.1.2 of the New York City Building Code.

3202.2.1.2 Architectural details. Details such as cornices, eaves, bases, sills, headers, band course, opening frames, rustications, applied ornament or sculpture, grilles, windows when fully open, air conditioning units, and other similar elements may be constructed:

  1. To project not more than 4 inches (102 mm) beyond the street line when less than 10 feet (3048 mm) above the ground or sidewalk level.
  2. To project not more than 10 inches (254 mm) beyond the street line when more than 10 feet (3048 mm) above the ground or sidewalk level.

The Code text allows projections of not more than 4 inches beyond the street line, when located less than 10 feet about the ground or sidewalk level. Projections located more than 10 feet above the ground or sidewalk level may project up to, but not more than 10 inches beyond the street line.

Section VI-A: Platform and Dunnage as Related Cellular Equipment

Are existing permitted antenna installations that exceeded the area limitation of 440 square feet, specified in Buildings Bulletin 2021-011, allowed to remain?

Yes. Applications for new installations and modifications of existing antennas are required to include documentation of existing conditions. Lawful existing installations that exceeded the 440 square feet limitation may remain. Any new installation or further modifications beyond repair or replacement as described in Part VII(A) will not be permitted. Where a Removal AN filing has been submitted and approved to lawfully remove existing installations to reduce the existing footprint to less than 440 square feet, the Department will accept new applications to occupy the balance of the square footage up to a maximum of 440 square feet.

May a new carrier utilize an existing platform, built for another carrier and that already exceeds the limit of 440 square feet, specified in Buildings Bulletin 2021-011?

Yes, a permitted platform may remain. Provided the installation has not been removed through Removal AN filing, it can be used by another carrier, but the existing square footage cannot be further increased. That means the new carrier may take over the occupied footprint, but any modifications cannot go beyond repair or replacement as described in Part VII(A) of BB 2021-011.

Are ladders or stairs, provided as means of required Fire Department access, included in the maximum area of 440 square feet?

If documentation from FDNY is provided to show that the means of access is required for their operation, or if the Department determines that the means of access is provided solely for FDNY access purposes, it is not counted towards the 440 square feet.

How is the square footage of equipment on grade calculated for each of the following: (a) footprint of equipment; (b) the area occupied by the concrete pad or steel support platform; or (c) the fenced compound?

Where equipment is supported on a platform or pad, the area of such platform or pad is subject to the area limitation. Where the equipment is not supported on a pad or platform, the footprint of the equipment is considered in determining the area. Fences may be provided to address safety concerns related to equipment access but are not considered in the area calculation. Such fences must comply with applicable Code and zoning requirements.

Would the addition of a new cabinet on an existing pad or platform be considered an increase in equipment area?

No, the equipment area is determined by the existing area of the pad or platform. The addition of new equipment on the existing pad or platform is not considered an increase.

Is a platform, provided solely for required Fire Department access, to be included in the maximum area of 440 square feet?

If documentation is provided to show that the means of access is required by FDNY for their operation, it is not counted towards the 440 square feet. A railing may be used to separate the required Fire Department access from the equipment platform. Where no such railing is provided, the access must be separated from the equipment platform.

Is a generator considered related equipment? Is the generator platform or dunnage counted toward the square footage calculation?

A generator that serves the cellular antenna system is considered related equipment and must be included in the area calculation. If a platform or dunnage is supporting the generator, it must be included in the area calculation, but the generator need not be included. A generator not serving the cellular antenna system need not be included in the area calculation but should not be filed as part of the AN application.

Is HVAC considered related equipment? Is HVAC dunnage counted toward the square footage calculation?

Any HVAC equipment and appliances that serve the cellular antenna system are considered related equipment and must be included in the area calculation. If a platform or dunnage is supporting the HVAC equipment and appliances, it must be included in the area calculation, but the HVAC equipment and appliances need not be included. HVAC equipment and appliances not serving the cellular antenna system need not be included in the area calculation.

Section VI-B2: Related Cellular Equipment Floor Space

Should area calculations combine the equipment located on the interior and exterior of the building?

No, Part VI (B)(1) of Buildings Bulletin 2021-011 clarifies that cellular antenna system equipment installed on a building interior is considered independently and will not be included in the area calculation for exterior equipment.

Is the applicant of record responsible for documenting all existing equipment installations – both interior and exterior?

As stipulated in Part VIII of Buildings Bulletin 2021-011, the applicant of record is responsible for documenting the existing and proposed conditions within the scope of work. The Department will require clarification from the applicant regarding the work location, and documentation of the equipment at that location – either interior or exterior, or both. Only when an alteration includes equipment on both the interior and exterior must the applicant document both.

How can an applicant of record document existing equipment installations when he or she might not be allowed access to all building areas?

The applicant should work with the building owner to again access and information on the existing installations. Where access to each individual related cellular equipment room is limited, the applicant may supplement his/her site survey with information from previous filings to substantiate the area occupied by existing installations.

NOTE: DOB does not require the layout of the actual equipment be represented. An outline of the related cellular equipment room is sufficient.

Figure 13

Does the maximum equipment area include kickbacks, which are provided for stability and not part of the platform or antenna frame?

Yes. The area of any structural platforms and dunnage, including any kickbacks that are providing direct or indirect reinforcement in supporting cellular antenna equipment, must be included in the equipment area calculation.

Section VII-A: Lawful Antennas and Equipment Undergoing Ordinary Repairs

Will the replacement of telecommunications equipment cabinets require a permit if the cabinet does not exceed the area or volume indicated on the previous application? Replacement of such equipment cabinets on the roof will most often involve the use of a crane. Will permits be required only for the use of a crane?

Replacements-in-kind and ordinary repairs of lawfully existing installations are addressed in Section 28-105.4.2 of the Administrative Code. Therefore, where the new equipment does not exceed the area and volume of the existing equipment, the repair or replacement in the same location does not require an antenna permit.

NOTE: Applications are required for related permits, such as those for cranes or electrical work.

Section VIII: Existing Conditions Documentation

What is the Department’s acceptable age of photographic documentation, when substantiating existing conditions?

Photographs documenting existing conditions must be sufficiently recent to match the condition represented on the survey drawings at the time of submission.

Helpful Links