2009-0656_AT&T-2nd.pdf
CITY OF EDMONDS
th
121 5Avenue North,Edmonds WA 98020
Phone: 425.771.0220 • Fax: 425.771.0221 • Web: www.ci.edmonds.wa.us
DEVELOPMENT SERVICESDEPARTMENT•PLANNING DIVISION
July 26, 2011
Sunny Kim
AT&T Mobility
st
568 1Avenue South #650
Seattle WA 98104
Richard J. Busch
Busch Law Firm PLLC
th
22525 SE 64Place –Suite 288
Issaquah WA 98027
RE:Planning Division Comments for BLD-2009-0656(Commodore Condo WCF)
Greetings,
In October of 2009 I wrote to you regarding your building permit application for a proposed wireless communication
facility in Edmondsand outlined all of the outstanding issues that need to be address in order to be in compliance
with the zoning code. I understand that you have been working with our staff throughout the recent code amendment
process and now that thenew wireless regulations have been adopted, I’m following up to find out how you would
like to proceed with this application. Because you have not yet proposed changes to meet the code, I’m enclosing all
of my original comments and issues below. Please contact myself or your permit coordinator to discuss how you
would like to move forward with your application.Please make all necessary changes to your application and re-
submit to your permitcoordinator.
unstaffed radio telecommunications facility
Thank you for submitting a building permit application for an
(consisting of a ballasted tripod with unicell antenna on the roof plus site support cabinets at the ground floor of the
546 Alder StreetRM-1.5
Commodore Condominium building)at in thezone. I have reviewed the above building
permit application for the Planning Division and it was found that the following information, corrections, or
clarifications will need to be addressed before the Planning Division review can continue. Please provide a written
1
response to the items mentioned below…
1.Type of Facility:
Specifically what “type” of wireless communication facility are you proposing (micro, mini,
or macro)?You will need to show the dimensions of the antennas to do this –the canister covering will not be
able to meet code. Specifying the dimensions and “type”will help me determine the applicable requirements in
ECDC 20.50 (the Wireless Communications Facilities chapter). Each type is different and each allow you to
extend antennas above the existing structure a small amount without considering it an expansion of the
nonconforming structure(see ECDC 20.50 for details)if a number of conditions are met(the building appears to
1
Please also redline your plans to reflect any changes –or, if you are submitting new plans, please submit three site
plans (one must be reduced size) and two sets of the changed pages of the plans. Please make all submittals to the
Development Services Permit Coordinator:Theresa UmbaughMarie Harrison.All code citations can be found
on the City of Edmonds website: www.ci.edmonds.wa.us.
Page 1of 2
be over the 25-foot stated height limit and is thus nonconforming –nonconforming buildings cannot be altered
in a way that makes them more nonconforming).Please review the following three definitions and provide
additional dimensional informationto show compliance with one of the three types of facilities permitted in this
zone based on your site:
ECDC 21.60.002 Macrofacility.
Macro facility is an attached wireless communication facility which consists of antennas equal to or less than 15
feet in height or a parabolic antenna up to one meter (39.37 inches) in diameter and with an area not more than
100 square feet in the aggregate as viewed from any one point. \[Ord. 3099 § 9, 1996\].
ECDC 21.60.004 Microfacility.
Micro facility is an attached wireless communication facility which consists of antennas equal to or less than
four feet in height (except omni-directional antennas which may be up to six feet in height) and with an area of not
more than 580 square inches in the aggregate (e.g., one-foot diameter parabola or two-foot by one and one-half-
foot panel) as viewed from any one point. The permitted antenna height includes the wireless communication facility
support structure (see Title 22, Plate 1). \[Ord. 3099 § 10, 1996\].
ECDC 21.60.006 Minifacility.
Mini facility is an attached wireless communication facility which consists of antennas equal to or less than 10
feet in height or a parabolic antenna up to one meter (39.37 inches) in diameter and with an area not more than 50
square feet in the aggregate as viewed from any one point. \[Ord. 3099 § 11, 1996\].
2.Height:
The maximum allowable building height for the RM-1.5 zone is 25 feet. Please indicate on an
elevation view how your proposal meets the stated height limit of 25 feet –or if the building is nonconforming,
how your “type” of facility is able to meet the height limit through one of theexceptions providedin ECDC
20.50(specifically ECDC 20.50.010.B, 20.50.020.E, or ECDC 20.50.030.E).
3.Residential Space:
Reading through ECDC 20.50 you’ll notice that the above types of facilities permitted in
this zone are not permitted above or next to designated residential space. Please indicate on the elevations how
your proposal is compliant with this provision or move the antennas as necessary.
4.SEPA:
WAC 197-11-800(25) addresses the SEPA (State Environmental Policy Act) exemptions for personal
wireless service facilities. It appears that because this is proposed on a residentialstructure, it is not expressly
exempt from review by the State. Please submit an Environmental Checklist and review fee ($485) at your
earliest convenience.
5.Screening/Design Review:
ECDC 18.05.030.B requires aboveground utilities to be screened (camouflaged)
from view, as does ECDC 20.50. How do you plan to screen the facility(antennas) from view?
If you have any questions, please do not hesitate to contact me. I look forward to working with you on this project.
Sincerely,
Gina Coccia
Associate Planner
425.771.0220, x 1778
coccia@ci.edmonds.wa.us
cc:BLD-2009-0656
Mike Thies, Code Enforcement Officer
Marie Harrison, Senior Permit Coordinator
enc:ECDC 20.50,Environmental (SEPA) Checklist
Page 2of 2