No. In October 2014 the FCC issued a Report and Order which modified its rules in a manner designed to accelerate broadband deployment by changing wireless facilities siting policies. In the Report and Order, the Commission expressed:
We adopt measures to refine our environmental and historic preservation review processes under NEPA and NHPA to account for new wireless technologies, including physically small facilities like those used in DAS networks and smallcell systems that are a fraction of the size of macro-cell installations. In contrast to the large-scale antennas and structures that our review processes were designed to address, these smaller antennas (and their associated compact radio equipment) can operate on existing short structures such as utility poles as well as on rooftops or inside buildings. As described in detail in the Executive Summary and in Section III, we expand an existing categorical exclusion from NEPA review so that it applies not only to collocations on buildings and towers, but also to collocations on other structures like utility poles. We also adopt a new categorical exclusion from NEPA review for some kinds of deployments in utilities or communications rightsof-way. With respect to NHPA, we create new exclusions to address certain collocations on utility poles and other non-tower structures. We take these steps to assure that, as we continue to meet our responsibilities under NEPA and NHPA, we also fulfill our obligation under the Communications Act to ensure that rapid, efficient, and affordable radio communications services are available to all Americans.
In its implementation of the Report and Order in 2016 the FCC executed an amendment to the National Programmatic Agreement for the Collocation of Wireless Antennas (“NPA”) which expanded the categorical exclusions from Section 106 review under NEPA. Based on the Report and Order and the Amended NPA, some small wireless antennas can be installed without first being required to complete Section 106 review.