City Application`nc. 189'j
BUILDING PERMIT
APPLICATION
Development Services
Building Division
121 5th Ave N / Edmonds, WA 98020
425.771.0220
For handouts, submittal requirements go to: www.edmondswa.gov.
To apply for permits, schedule inspections, or check application status
go to: www.mvbuildingpermit.com
JOB SITE INFORMATION/LOCATION: (Where the work is taking place)
Job Site Address: 24329 Highway 99
Parcel: 00491100001605
Lot /Unit/Suite #: Subdivision:
BUSINESS OR PROPERTY OWNER:
Name: American Tower Corporation (tower owner
Mailing Address: 10 Presidential Way
City/State/Zip: Woburn, MA 01801
Phone #: 972-999-8900
Email
OWNER INSTALLATION: *If yes, read and sign*
Will work be performed by the property owner? Yes V No
I own, reside in, or will reside in the completed structure. This
installation is being made on property that I own which is not
intended for sale, lease, rent, or exchange according to RCW
18.27.090.
Owner Signature:
APPLICANT / CONTACT INFORMATION:
Name of Applicant: Katie Kyle - Authorized Agent
Mailing Address: 2918 Clairmont Ave S
City/State/Zip: Birmingham, AL 35205
Phone #: 205-2335-6784
E-mail: kkyle@craftongroup.com
GENERAL CONTRACTOR: (If different from applicant)
General Contractor: Mastec Network Solutions LLC
Mailing Address:22263 68th Ave S
City/State/Zip: Kent, WA 98032
Phone #: 678-457-9066
E-mail: Joy.Davis@MasTec.com
STATE UBI #:
CITY OF EDMONDS BUSINESS LICENSE #:
WA STATE CONTRACTOR L & I #: (CCB) & EXPIRATION DATE:
MASTENS876KN
ATC 414383 - Verizon Upgrade - 13696032
Office Use Only
F77"
- I
TYPE OF PERMIT (Provide
Details on Page 2)
❑Accessory Structure/
Addition
❑
Detached Garage
Demolition
Mechanical
New Single Family/Duplex
Plumbing
Fire Sprinkler
❑ Remodel
New Commercial/Mixed Use
❑ Re -Roof
❑ Signs
❑ Tank
❑ Tenant Improvement
OtherAntenna Upgrade
to Existing Cell To
Remodel Permit fees are based on:
The value of the work performed. Indicate the value (rounded to
the nearest dollar) of all equipment, materials, labor, overhead,
and the profit for the work indicated on this application.
Valuation: $25,000
PROPOSED NEW SQUARE FOOTAGE FOR THIS APPLICATION
Basement scl ft: Finished❑ Unfinished ❑
1st Floor, scl ft:
N/A
2nd Floor, scl ft:
N/A
Garage/Carport:, scl ft:
N/A
Deck/Covered Porch/Patio:
N/A
# of NEW Bedrooms: N/A # of NEW Bathrooms: N/A
PROJECT
ATC 414383 - Verizon Upgrade to existing cell
tower including removing 9 antennas and 9
RRHs, and installing 9 antennas, 9 RRHS,
for details.
Please contact Katie Kyle for all matters
relating to application and permit.
205-235-6784
kkyle@craftongroup.com
I certify that the information I have provided on this form/application is true,
correct and complete, and that I am the property owner or duly authorized
agent of the property owner to submit a permit application to the City of
Edmonds.
Print Name: Katie Kyle
Digitally sI,n,l by Katie Kyle
Katie Kyle Date: 2021.09.151028:48 9/1 5/21
Signature:-05,00, Date
ver
GENERAL COMMERCIAL DATA
Occupancy Group(s): N/A Occupant Load(s): N/A
Type(s) of Construction: 11B Fire Sprinklers: Yes❑ NoFv—(]
WA STATE ENERGY CODE: If your project affects the building envelope,
mechanical systems, and/or lighting, you must complete the
appropriate WSEC forms.
DEFERRED SUBMITTALS: All commercial building permits that will require
associated plumbing, mechanical, fire sprinkler, and/or fire alarm
permits are applied for separately.
TI / CHANGE OF USE / NEW BLDG: Include TRAFFIC IMPACT worksheet
EQUIPMENTMECHANICAL •
Not Applicable BTUs Gas / Elec / other Qty
A/C Unit /Compressor
Air Handler /VAV
Boiler
Dryer Duct
Exhaust Fans
Fireplace
Furnace
Heat Pump Unit
Hydronic Heating
Roof Top Unit (Provide eleva-
tions if a Commercial Bldg)
Other:
COUNTSPLUMBING FIXTURE
Qty Not Applicable Qty
Clothes Washer
Tub/ Showers
Dishwasher
Backflow Device (RPBA, DCDA, AVB)
Drinking Fountain
Pressure Reduction/ Regulator Valve
Floor Drain/Sink
Refrigerator Water Supply
Hose Bibs
Water Heater - Tankless? Y or N
Hydronic Heat
Water Service Line
Sinks
Other:
Toilets
Other:
CONNECTION COUNTSd or re piped)
BTUs Qty Not Applicable BTUs Qty
A/C Unit
Outdoor BBQ/ Fire pit
Boiler
Stove/Range/Oven
Dryer
Water Heater
Fireplace/ Insert
Other:
Furnace
Other:
COUNTSMEDICAL GAS, AIR VACUUM
(New, Relocated or re piped)
Not Applicable Qty Qty
Carbon Dioxide
Nitrous Oxide
Helium
Oxygen
Medical Air
Other:
Medical - Surgical Vacuum
Other:
DEMOLITION
Type of structure to be demolished: Not Applicable
Square footage of structure to be demolished:
AHERA Survey done? Y❑ / N❑
PSCAA Case #:
Critical Areas Determination:
Study Required ❑ Conditional Waiver ❑ Waiver❑
Fill in Place ❑ Fill Material: Not Applicable
Removal ❑
Size of Tank (Gallons)
Critical Areas Determination:
Study Required Conditional Waiver Waiver
Grading: Cut cubic yards Not Applicable
Fill cubic yards
Cut / Fill in Critical Area: Yes ❑ No ❑
GENERAL PROVISIONS
APPLICATIONS: Applications are valid for a maximum of 1 year.
ESLHA Applications, 2 years.
LICENSING: All contractors and subcontractors are required to be licensed
with Washington State Department of Labor & Industries and have a
current City of Edmonds Business License.
41 CRAFTON
116��4
4600, COMMUNICATIONS
NOTIFICATION OF ELIGIBLE FACILITIES REQUEST
September 15, 2021
City of Edmonds
Development Services Department
121 5th Ave N
Edmonds, WA 98020
RE: Commercial Plan Review and Permitting: 414383 — Verizon Upgrade
Site Address: 24329 Highway 99
The proposed project includes modifying equipment on an existing commercial cell tower. The
scope of work includes:
Tower scope of work:
• Remove (9) antennas and (9) RRHs
• Install (9) antennas, (9) RRHs, (2) OVPs, and (2) hybrid cables
There will be no change to the tower height or size of the existing compound. There will be no
excavation or addition of impervious cover.
Pursuant to 47 USC § 1455 and the Rules adopted by the Federal Communications Commission,
47 C.F.R § 1.6100, the enclosed permit application qualifies as an Eligible Facilities Request.
Federal law provides that a local jurisdiction has 60 days from the date that an Eligible Facilities
Request is filed to approve the application. If more than 60 days elapse from the date this
Eligible Facilities Request permit application is filed, and the local government does not act on
this application, the application will be deemed granted under federal law.
Sincerely,
Katie Kyle
Crafton Communications
205.235.6784 office
kk legcraftongroup.com
2918 Clairmont Avenue South, Birmingham, AL 35205 Phone: 205-682-7525/Fax: 205-682-7501
Birmingham/Dallas/Huntsville
www.CraftonGroup.com
PUBLIC NOTICE
Federal Communications Commission News Media Information 202 / 418-0500
445 12`h St., S.W. Internet: http://www.fcc.gov
Washington, D.C. 20554 TTY: 1-888-835-5322
WIRELESS TELECOMMUNICATIONS BUREAU OFFERS GUIDANCE ON
INTERPRETATION OF SECTION 6409(a) OF THE MIDDLE CLASS TAX RELIEF AND
JOB CREATION ACT OF 2012
DA 12-2047
January 25, 2013
On February 22, 2012, the Middle Class Tax Relief and Job Creation Act of 2012 (Tax Act)' became law.
Section 6409(a) of the Tax Act provides that a state or local government "may not deny, and shall
approve" any request for collocation, removal, or replacement of transmission equipment on an existing
wireless tower or base station, provided this action does not substantially change the physical dimensions
of the tower or base station? The full text of Section 6409(a) is reproduced in the Appendix to this Public
Notice.
To date, the Commission has not received any formal petition to interpret or apply the provisions of
Section 6409(a). We also are unaware of any judicial precedent interpreting or applying its terms. The
Wireless Telecommunications Bureau has, however, received informal inquiries from service providers,
facilities owners, and state and local governments seeking guidance as to how Section 6409(a) should be
applied. In order to assist interested parties, this Public Notice summarizes the Bureau's understanding of
Section 6409(a) in response to several of the most frequently asked questions.s
What does it mean to "substantially change the physical dimensions" of a tower or base station?
Section 6409(a) does not define what constitutes a "substantial[] change" in the dimensions of a tower or
base station. In a similar context, under the Nationwide Collocation Agreement with the Advisory
Council on Historic Preservation and the National Conference of State Historic Preservation Officers, the
Commission has applied a four -prong test to determine whether a collocation will effect a "substantial
increase in the size of [a] tower."4 A proposed collocation that does not involve a substantial increase in
' Middle Class Tax Relief and Job Creation Act of 2012, Pub. L. 112-96, H.R. 3630, 126 Stat. 156 (enacted Feb. 22,
2012) (Tax Act).
2 Id., § 6409(a).
3 Although we offer this interpretive guidance to assist parties in understanding their obligations under Section
6409(a), see, e.g., Truckers United for Safety v. Federal Highway Administration, 139 F.3d 934 (D.C.Cir. 1998), the
Commission remains free to exercise its discretion to interpret Section 6409(a) either by exercising its rulemaking
authority or through adjudication. With two exceptions not relevant here, the Tax Act expressly grants the
Commission authority to "implement and enforce" this and other provisions of Title VI of that Act "as if this title is
a part of the Communications Act of 1934 (47 U.S.C. 151 et seq.)." Tax Act § 6003.
a 47 C.F.R. Part 1, App. B, Nationwide Programmatic Agreement for the Collocation of Wireless Antennas, § I.0
(Nationwide Collocation Agreement).
size is ordinarily excluded from the Commission's required historic preservation review under Section
106 of the National Historic Preservation Act (NHPA).5 The Commission later adopted the same
definition in the 2009 Declaratory Ruling to determine whether an application will be treated as a
collocation when applying Section 332(c)(7) of the Communications Act of 1934.6 The Commission has
also applied a similar definition to determine whether a modification of an existing registered tower
requires public notice for purposes of environmental review.'
Under Section I.0 of the Nationwide Collocation Agreement, a "substantial increase in the size of the
tower" occurs if:
1) [t]he mounting of the proposed antenna on the tower would increase the existing height of
the tower by more than 10%, or by the height of one additional antenna array with separation
from the nearest existing antenna not to exceed twenty feet, whichever is greater, except that
the mounting of the proposed antenna may exceed the size limits set forth in this paragraph
if necessary to avoid interference with existing antennas; or
2) [t]he mounting of the proposed antenna would involve the installation of more than the
standard number of new equipment cabinets for the technology involved, not to exceed four,
or more than one new equipment shelter; or
3) [t]he mounting of the proposed antenna would involve adding an appurtenance to the
body of the tower that would protrude from the edge of the tower more than twenty feet, or
more than the width of the tower structure at the level of the appurtenance, whichever is
greater, except that the mounting of the proposed antenna may exceed the size limits set
forth in this paragraph if necessary to shelter the antenna from inclement weather or to
connect the antenna to the tower via cable; or
4) [t]he mounting of the proposed antenna would involve excavation outside the current
tower site, defined as the current boundaries of the leased or owned property surrounding the
tower and any access or utility easements currently related to the site.
Although Congress did not adopt the Commission's terminology of "substantial increase in size" in
Section 6409(a), we believe that the policy reasons for excluding from Section 6409(a) collocations that
substantially change the physical dimensions of a structure are closely analogous to those that animated
the Commission in the Nationwide Collocation Agreement and subsequent proceedings. In light of the
Commission's prior findings, the Bureau believes it is appropriate to look to the existing definition of
"substantial increase in size" to determine whether the collocation, removal, or replacement of equipment
5 See 16 U.S.C. § 470f, see also 47 C.F.R. § 1.1307(a)(4) (requiring applicants to determine whether proposed
facilities may affect properties that are listed, or are eligible for listing, in the National Register of Historic Places).
6 See Petition for Declaratory Ruling to Clarify Provisions of Section 332(c)(7)(B) to Ensure Timely Siting Review
and to Preempt Under Section 253 State and Local Ordinances that Classify All Wireless Siting Proposals as
Requiring a Variance, WT Docket No. 08-165, Declaratory Ruling, 24 FCC Rcd. 13994, 14012, para. 46 & n.146
(2009) (2009 Declaratory Ruling), recon. denied, 25 FCC Rcd. 11157 (2010), pet. for review denied sub nom. City
of Arlington, Texas v. FCC, 668 F.3d 229 (5th Cir.), cent. granted, 113 S.Ct. 524 (2012); 47 U.S.C. § 332(c)(7).
' See 47 C.F.R. § 17.4(c)(1)(B); National Environmental Policy Act Compliance for Proposed Tower Registrations,
WT Docket No. 08-61, Order on Remand, 26 FCC Rcd. 16700, 16720-21, para. 53 (2011).
2
on a wireless tower or base station substantially changes the physical dimensions of the underlying
structure within the meaning of Section 6409(a).
What is a "wireless tower or base station"?
A "tower" is defined in the Nationwide Collocation Agreement as "any structure built for the sole or
primary purpose of supporting FCC -licensed antennas and their associated facilities.i' The Commission
has described a "base station" as consisting of "radio transceivers, antennas, coaxial cable, a regular and
backup power supply, and other associated electronics.i9 Section 6409(a) applies to the collocation,
removal, or replacement of equipment on a wireless tower or base station. In this context, we believe it is
reasonable to interpret a "base station" to include a structure that currently supports or houses an antenna,
transceiver, or other associated equipment that constitutes part of a base station.10 Moreover, given the
absence of any limiting statutory language, we believe a "base station" encompasses such equipment in
any technological configuration, including distributed antenna systems and small cells.
Section 6409(a) by its terms applies to any "wireless" tower or base station. By contrast, the scope of
Section 332(c)(7) extends only to facilities used for "personal wireless services" as defined in that
section." Given Congress's decision not to use the pre-existing definition from another statutory
provision relating to wireless siting, we believe the scope of a "wireless" tower or base station under
Section 6409(a) is not intended to be limited to facilities that support "personal wireless services" under
Section 332(c)(7).
May a state or local government require an application for an action covered under Section
6409(a)?
Section 6409(a) states that a state or local government "may not deny, and shall approve, any eligible
facilities request...." It does not say that a state or local government may not require an application to be
filed. The provision that a state or local government must approve and may not deny a request to take a
covered action, in the Bureau's view, implies that the relevant government entity may require the filing of
an application for administrative approval.
8 See Nationwide Collocation Agreement, § I.B.
9 See Implementation of Section 6002(b) of the Omnibus Budget Reconciliation Act of 1993, WT Docket No. 10-
133, Annual Report and Analysis of Competitive Market Conditions With Respect to Mobile Wireless, Including
Commercial Mobile Services, Fifteenth Report, 26 FCC Red. 9664, 9481, para. 308 (2011).
io See also 47 C.F.R. Part 1, App. C, Nationwide Programmatic Agreement Regarding the Section 106 National
Historic Preservation Act Review Process, § II.A.14 (defining "tower" to include "the on -site fencing, equipment,
switches, wiring, cabling, power sources, shelters, or cabinets associated with that Tower but not installed as part of
an Antenna as defined herein").
" 47 U.S.C. § 332(c)(7)(A). "Personal wireless services" is in turn defined to mean "commercial mobile services,
unlicensed wireless services, and common carrier wireless exchange access services." Id. § 332(c)(7)(C)(1).
3
Is there a time limit within which an application must be approved?
Section 6409(a) does not specify any period of time for approving an application. However, the statute
clearly contemplates an administrative process that invariably ends in approval of a covered application.
We believe the time period for processing these applications should be commensurate with the nature of
the review.
In the 2009 Declaratory Ruling, the Commission found that 90 days is a presumptively reasonable period
of time to process collocation applications.12 In light of the requirement of Section 6409(a) that the
reviewing authority "may not deny, and shall approve" a covered request, we believe that 90 days should
be the maximum presumptively reasonable period of time for reviewing such applications, whether for
"personal wireless services" or other wireless facilities.
Wireless Telecommunications Bureau contact: Maria Kirby at (202) 418-1476 or by email:
Maria.Kirby@fcc.gov.
-FCC-
For more news and information about the Federal Communications Commission
please visit: www.fcc.gov
12 See 2009 Declaratory Ruling, 24 FCC Rcd. at 14012-13, paras. 46-47.
4
rd
APPENDIX
SEC. 6409. WIRELESS FACILITIES DEPLOYMENT.
(a) FACILITY MODIFICATIONS.
(1) IN GENERAL. Notwithstanding section 704 of the Telecommunications Act of 1996 (Public Law
104-104) or any other provision of law, a State or local government may not deny, and shall approve, any
eligible facilities request for a modification of an existing wireless tower or base station that does not
substantially change the physical dimensions of such tower or base station.
(2) ELIGIBLE FACILITIES REQUEST. For purposes of this subsection, the term "eligible facilities
request" means any request for modification of an existing wireless tower or base station that involves —
(A) collocation of new transmission equipment;
(B) removal of transmission equipment; or
(C) replacement of transmission equipment.
(3) APPLICABILITY OF ENVIRONMENTAL LAWS. Nothing in paragraph (1) shall be construed to
relieve the Commission from the requirements of the National Historic Preservation Act or the National
Environmental Policy Act of 1969.
5