20141205171439589.pdfCity of Edmunds
Permit Center
Second Floor City Hall
121 5th Ave N 98020
RE: Response to Plan Review Comments for Plan Check #2014-1043
Antenna Replacement at 23931 Highway 99
Dear Mr. Clugston:
1001 SE Water Ave., Ste 180
F)MIaid, ORI 97214
(503) 708-9200
Per your checksheet dated October 29, 20141 am providing you the materials you have requested to complete
your review of this proposal.
Cover letter describing the projects compliance with ECDC 20.50.050:
20.50.050 General siting criteria and d,esign considerations.
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A. The city of Edmonds encourages wireless communication providers to use existing sites or more frequent, less
noticeable sites instead of attempting to provide coverage through use of taller towers. To that end, applicants shall
consider the following priority of preferred locations for wireless communication facilities:
1. Co -location, without an increase in the height of the building, pole or structure upon which the facility would
In;=.- ' I
This is an existing facility on a monopole. There will not be a change in height. Antennas are being replaced
with new antennas and additional ancillary equipment.
2. Co -location, where additional height is necessary above existing building, pole, or structure;
This is an existing facility on a monopole. There will not be a change in height. Antennas are being replaced
with new antennas and additional ancillary equipment.
3. A replacement pole or structure for an existing one;
Not applicable, utilizing the existing monopole.
4. A new pole or structure altogether.
Not applicable, utilizing the existing monopole
B. Co -location shall be encouraged for all wireless communication facility applications and is implemented through
less complex permit procedures.
1 . To the greatest extent technically feasible, applicants for new monopole facilities shall be required to build
mounts capable ofaccommodating at least one other carrier.
Monopole has capacity for other carriers. Other carriers will need to supply their own mounts. Other carrier
antennas cannot occupy the same elevation because they would cause interference.
2. Any wireless communication facility that requires a conditional use permit (CUP) under the provisions of this
chapter shall be separated by a minimum of 500 feet from any other facility requiring a CUP, unless the
submitted engineering information clearly indicates that the requested site is needed in order to provide
coverage for the particular provider, and other siting options have been analyzed and proven infeasible.
This an update tomnexisting site. ACUP isnot required.
C. Noise. Any facility that requires a generator or other device which will create noise audible beyond the boundaries
of the site must demonstrate compliance with Chapter 5.30 ECC, Noise Abatement and Control. A noise report,
prepared by an acoustical engineer, shall be submitted with any application to construct and operate a wireless
communication facility that will have a generator or similar device. The city may require that the report be reviewed by
othird party expert atthe expense ofthe applicant.
The new equipment will not create additional noise beyond the boundaries ofthe site.
D. Business License Requirement. Any person, corporation or entity that operates a wireless communication facility
within the city shall have a valid business license issued annually by the city. Any person, corporation or other
business entity which owns a monopole also is required to obtain a business license on an annual basis.
AT&T (Now Cingular Wireless LLC) should have a business license on file with the City of Edmonds. Theympenakp
numerous sites within the City,
E. Signage. Only safety signs or those mandated by a government entity with jurisdiction may be located on wireless
communication facilities. No other types of signs are permitted on wireless communication facilities.
Only signs required bythe Federal Commission (FC()will beposted.
F. Any application must demonstrate that there is sufficient space for temporary parking for regular maintenance of
the proposed facility.
There will not be any changes in parking resulting from this proposal.
G. Finish. A monopole may be constructed of laminated wood, fiberglass, steel, or similar material. The pole shall be
a neutral color so as to reduce its visual obtrusiveness, subject to any applicable standards of the FAA or FCC.
The existing monopole is steel and has a neutral unpainted finish.
H. Design. The design of all buildings and ancillary structures shall use materials, colors, textures, screening and
landscaping that will blend the facilities with the natural setting and built environment.
The upgrades to the facility will not alter the fencing or landscaping.
I. Color. All antennas and ancillary facilities located on buildings or structures other than monopoles shall be of a
neutral color that is identical to or closely compatible with the color of the supporting structure so as to make the
antenna and ancillary facilities as visually unobtrusive as possible.
New antennas and equipment will be painted to match the existing facility. See note on sheet A3 of the plans.
J. Lighting. Monopoles shall not be artificially lighted unless required by the FAA, FCC or other government entity
with jurisdiction. If lighting is required and alternative lighting options are permitted, the city shall review the lighting
alternatives and approve the design that would cause the least disturbance to the surrounding area. No strobe
lighting of any type is permitted on any monopole. If FAA guidelines would require a strobe, the location shall be
denied unless no other site or combination of sites would provide adequate coverage in accord with FCC
requirements.
No new lighting proposed.
K. Advertising. No advertising is permitted at wireless communication facility sites or on any ancillary structure or
facilities equipment enclosure.
There will not be any advertisements added to the facility.
L. Equipment Enclosure. Each applicant shall use the smallest equipment enclosure practical to contain the required
equipment and a reserve for required co -location.
This facility uses outdoor cabinets mounted onto aconcrete slab. These are the smallest possible enclosures for this
type of facility.
M. Radio Frequency Emissions Compliance. The applicant shall demonstrate that the projectwill not result inlevels
of radio frequency emissions that exceed FCC standards, including FCC Office of Engineering Technology (OET)
Bulletin 65, Evaluating Compliance with FCC Guidelines for Human Exposure to Rodin Frequency Electromagnetic
Fields, as amended. Additionally, if the director determines the wireless communication facility, as constructed, may
emit radio frequency emissions that are likely to exceed Federal Communications Commission uncontrolled/general
population standards in the FCC Office of Engineering Technology (OET) Bulletin 65, Evaluating Compliance with
FCC Guidelines for Human Exposure to Radio Frequency Electromagnetic Fields, as amended, in areas accessible
by the general population, the director may require post -installation testing to determine whether to require further
mitigation of radio frequency emissions. The cost of any such testing and mitigation shall be borne by the applicant.
Site easily complies with FCC standards. See attached NIERreport.
N. Landscaping and Screening.
1. The visual impacts of wireless communication facilities should be mitigated and softened through
landscaping or other screening materials at the base of a monopole, facility equipment compound, equipment
enclosures and ancillary structures. If the antenna is mounted flush on an existing bui|ding, or camouflaged as
part of the building and other equipment is housed inside an existing structure, no landscaping is required. The
director or his designee may reduce or waive the standards for those sides of the wireless communication
facility that are not in public view, when a combination of existing wagetmiiun, hopography, weUo, d000miiwa
fences or other features achieve the same degree of screening as the required landscaping; in locations where
the visual impact of the facility would be minimal; and in those locations where large wooded lots not capable
of subdivision and natural growth around the property perimeter provide a sufficient buffer.
There is an existing site obscuring CMU wall that hides the support equipment and the base of the tower. Site
is located inmGeneral Commercial zone.
2. Landscaping shall be installed on the outside of fences in accordance with Chapter 20.1.3 ECDC. Existing
vegetation shall be preserved to the maximum extent practicable and may be used as a substitute for or as a
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a. Type I landscaping shall be placed around the perimeter of the equipment cabinet enclosure, except
that a maximum 10 -foot portion of the fence may remain without landscaping in order to provide access
to the enclosure.
There is not any landscaping around the existing facility. It is located in the middle of a parking lot and
landscaping would restrict traffic flow. See picture below.
b. Landscaping area shall be a minimum of five feet in width around the perimeter of the enclosure.
There is not any landscaping around the existing facility. It is located in the middle of a parking lot and
landscaping would restrict traffic flow.
c. Vegetation selected should be native and drought tolerant.
There, is not any landscaping around the existing facility. It is located in the middle of a parking lot and
landscaping would restrict traffic flow.
d. Landscaping shall be located so as not to create sight distance hazards or conflicts with other
surrounding utilities.
There is not any landscaping around the existing facility. It is located in the middle of a parking lot and
landscaping would restrict traffic flow.
3. When landscaping is used, the applicant shall submit a landscaping bond pursuant to ECDC =20.1-3-,PdO.
There is not any landscaping around the existing facility. It is located in the middle of a parking lot and
landscaping would restrict traffic flow.
4. The use of chain link, plastic, vinyl or wire fencing is prohibited. Ornamental metal or wood fencing materials
are preferred. [Ord. 3961 § 1, 2014; Ord. 3845 § 2 (Att. A), 2011 ].
The facility is currently surrounded by a CMU wall with a wood gate. There is an adjacent dumpeter area not
connected with the facility that is fenced.
The criteria for this facty should have been addressed in previous land use decisions and allowing the
landscaping requirement to be waived,
• NIER Report
• Propagation Plot
as Photosimulations
If you have any questions regarding the submitted materials or the proposal, please contact me at 503/232-5213
or
. ft
,p,!§wwarn m. Thank you for your time and consideration.
Sincerely,