210624 Notice of Incomplete Application-ATTf nC. 189\)
Application ID:
Received by City:
Date of Notice:
Applicant:
CITY OF EDMONDS
121 5t" Avenue North, Edmonds WA 98020
Phone: 425.771.0220 • Fax: 425.771.0221 • Web: www.edmondswa
PUBLIC WORKS DEPARTMENT • ENGINEERING DIVISION
NOTICE OF INCOMPLETE APPLICATION
AT&T Site ID: WAALD-003-E/17727-003-E
ENG 2021-0218
June 14, 2021 at 5:45 pm
June 24, 2021
Amber Toropova
SAQ Project Manager
MasTec Network Solutions, on behalf of AT&T
Amber.Toropova@mastec.com
This notice serves to identify areas where the application is incomplete. An indication that an
application requirement has been "addressed" means that the requirement is not incomplete.
It does not mean the City has made a determination as to whether it agrees with any
conclusions made by the applicant.
The City has reviewed the above captioned wireless facilities application/ROW permit
application for compliance with the application requirements of ECDC 20.50.070 and ECDC
20.50.130. Because the City must process an application within FCC imposed shot clocks, it is
critical that the applicant provide a complete application, i.e., provide all the information
required by code so that the City has all the information it needs to determine compliance with
its standards and process the application.
According to published standards, when locating small wireless facilities in the rights -of -way,
wireless providers shall site their facilities pursuant to the adopted siting preferences which are
expressed in descending order, starting with the most preferred. ECDC 20.50.130(B). Wireless
providers may not descend to a lower preference in the list until they have showed that the
higher preference is not feasible. ECDC 20.50.130(B); ECDC 20.50.070(G).
City code sets forth the following location preference hierarchy:
1. Location Preference No. 1— hollow utility pole.
2. Location Preference No. 2 —freestanding small wireless facility or new streetlight.
3. Location Preference No. 3 — existing power pole (installation on top of pole).
1-Notice of Incomplete Application
f nC. 189\)
CITY OF EDMONDS
121 5t" Avenue North, Edmonds WA 98020
Phone: 425.771.0220 • Fax: 425.771.0221 • Web: www.edmondswa
PUBLIC WORKS DEPARTMENT • ENGINEERING DIVISION
4. Location Preference No. 4 — existing power pole (installation in communication space).
5. Location Preference No. 5 — strand -mounted.
If an applicant submits an application for a lower ranked preference in the list, it by definition
must provide more information than would be necessary for a higher ranked preference.
In this case the application is to locate at Location Preference #4. The application is incomplete
in the following respects:
ECDC 20.50.070 APPLICATION REQUIREMENTS
A. Project description — Not addressed. Project description does not include technology
description which is necessary in evaluating applicant's claim of technical infeasibility for
Location Preference No. 2. ECDC 20.50.070 (A).
B. Aerial photo or map - Addressed
C. Site information on scaled Dlans. includi
1. Site plan -Addressed
2. Elevation drawings -Addressed
3. Utility plan showing existing utilities, proposed facility location, and
undergrounding — Not addressed. Utility plan shows some but not all existing
utilities. ECDC 20.50.070 (C)(3) Missing utilities include, but are not limited to,
City of Edmonds water, sewer and storm, as well as City of Lynnwood sewer force
line. Natural gas needs be shown if present. It is necessary to show all existing
utilities so that the City can evaluate the feasibility of all location preferences,
not just the one the applicant applied for.
4. Screening, camouflaging or landscaping plan and cost estimate— N/A if no
portion of the facility is located at ground level.
D. Photos and photo simulations - Addressed
E. Noise report —Addressed
F. Radio Frequency (RF) Emissions Standards - Addressed
G. For small wireless facility deployments, the following documentation shall be provided
as initial justification for the proposed location pursuant to the location preference
criteria set forth in ECDC 20.50.130(B) (i.e., as initial justification to move from Location
Preference 1 to a Location lower in the list level.)
1. Location Preference 1 (hollow utility pole) —
Not proposed. To move to location Preference 2, the following criteria shall be met:
a. Where no poles exist in the area, provide evidence no poles exist within 1501f in
either direction.
Addressed. N/A because poles do exist.
2-Notice of Incomplete Application
f nC. 189\)
CITY OF EDMONDS
121 5t" Avenue North, Edmonds WA 98020
Phone: 425.771.0220 • Fax: 425.771.0221 • Web: www.edmondswa
PUBLIC WORKS DEPARTMENT • ENGINEERING DIVISION
b. Written documentation from all pole owners denying replacement of existing
poles with hollow.
Addressed.
c. Written documentation from sole owners denvinR installation of small cell
within existing hollow poles.
Addressed.
2. Location Preference 2 (freestanding small wireless facility or new streetlight) —
Not proposed. To move to location Preference 3, the following criteria shall also be
met:
a. Evidence that design standards for freestanding small wireless cannot be met.
Not addressed: Establish infeasibility per ECDC 20.50.130 (8) "Failure to show
lack of feasibility of a higher preference shall be grounds for denial of an
application," ECDC 20.50.070(G)(3)(a), and ECDC 20.50.130 (D)(2)(a) and (b):
Please specifically state the height of electrical lines and facilities on the existing
pole. Your application narrative states, "The energized power lines consist of
distribution lines at the top of the poles and an energized neutral line
approximately 25 feet above ground level."
b. Confirmation by PW Director that a new streetlight is not needed.
AT&T did not attempt to obtain confirmation from the Director of Public Works
that a new streetlight pole capable of hosting a fully concealed small wireless
facility is not needed. ECDC 20.50.070 (G)(2)(c). HOWEVER, The City now
considers a request for confirmation to have been constructively made of the
Director, and the request is being evaluated.
Not addressed: Establish infeasibility per ECDC 20.50.130 (8) "Failure to show
lack of feasibility of a higher preference shall be grounds for denial of an
application," ECDC 20.50.070(G)(3)(a), and ECDC 20.50.130 (D)(2)(a) and (b):
Please cite the authority(ies) on which you rely in support of your assertions
made in your application that "[i]n order to construct or maintain a new
[freestanding wireless facility or streetlight] pole on the east side of 76t" Avenue
West without interfering with existing communications lines, the position of a
bucket truck must be such that neither the arm nor the bucket crosses through
the communications lines, as well as maintaining required clearances from any
nearby energized electrical lines." Please include: the regulation establishing the
clearances to communications lines to which you reference, the regulations
prohibiting installation using the city's right-of-way, prohibiting the use of a
bucket truck here, and why the use of a bucket truck is the sole reasonable
method of installation.
3-Notice of Incomplete Application
fhb. 10"
CITY OF EDMONDS
121 5ch Avenue North, Edmonds WA 98020
Phone: 425.771.0220 • Fax: 425.771.0221 • Web: www.edmondswa
PUBLIC WORKS DEPARTMENT • ENGINEERING DIVISION
Not addressed: Establish infeasibility per ECDC 20.50.130 (8) "Failure to show
lack of feasibility of a higher preference shall be grounds for denial of an
application," ECDC 20.50.070(G)(3)(a), and ECDC 20.50.130 (D)(2)(a) and (b):
Please cite the authority(ies) on which you rely in support of your assertions
made in your application that "any arm or mounting for such a luminaire [a
luminaire that would extend beyond the diameter of the new pole] would violate
clearance from the communications lines[]" Please include: the regulation
establishing the clearances to which you reference.
3. Location Preference 3 (on top of existing power pole) —
Not proposed. To move to location Preference 4, the following criteria shall also be
met:
a. Evidence that no power poles exist that would allow for installation on top of the
pole. Addressed.
b. Where power poles exist, written documentation from pole owner denying
request to locate on top of pole.
Addressed.
4. Location Preference 4 (in communication space on existing power pole)
Proposed.
5. Location Preference 5 (strand -mounted) — N/A
6. Pole owners consent where applicable —Addressed
7. Demonstration of compliance with National Electrical Safety Code - Addressed
H. A copy of the provider's approved master permit —Addressed.
I. Any other documentation deemed necessary by the Director
While not a deficiency in the application, the City makes this request for information:
You mentioned in your application at page 7 that AT&T has freestanding SWF poles.
Please share information about AT&T's freestanding poles and how they differ from the
City's published requirements for a freestanding pole.
ECDC 20.50.130 SMALL WIRELESS STANDARDS AND APPROVAL PROCESS
A. Permitted Locations
a. Attachments to buildings — N/A
b. Concealed freestanding —Allowed in proposed zone
c. Dispersion requirement —Addressed
d. BD Zone — N/A
e. Existing underground utilities — N/A
4-Notice of Incomplete Application
CITY OF EDMONDS
121 5t" Avenue North, Edmonds WA 98020
Phone: 425.771.0220 • Fax: 425.771.0221 • Web: www.edmondswa
PUBLIC WORKS DEPARTMENT • ENGINEERING DIVISION
f nC. 189\)
f. Historic property — N/A
g. Wood pole with streetlight — N/A
B. Location Preference Hierarchy
1. Preference No. 1— hollow utility pole — N/A
2. Preference No. 2 — freestanding small wireless facility or new streetlight — Not
proposed
3. Preference No. 3 — existing power pole (installation on top of pole) — N/A
4. Preference No. 4 — existing power pole (installation in communication space) —
Current proposal
5. Preference No. 5 — strand -mounted — N/A
C. General Design Standards
1. Collocation with concealment — N/A
2. Ground -mounted equipment — N/A
3. No equipment to produce noise in violation of Chapter 5.30 ECC - Addressed
4. ADA and clearance requirements for replacement poles, new poles, and all
equipment —Addressed. As a courtesy we are informing the applicant that this
existing pole appears to be out of compliance state and federal regulations
related to providing sufficient clear zone. ECDC 20.50.130(C)(4)
5. Replacement pole near existing with removal of old —Addressed.
6. Signage requirements (all wireless facilities shall have affixed to them a health
warning sign) —Application narrative states "This provision of the Edmonds City
Code is preempted by the Federal Communications Commission's 2019 Second
Report and Order, FCC 19-126, stating that local jurisdictions are prohibited from
requiring additional signs and access restrictions beyond the Commission's
requirements." The City considers the signage requirement to be addressed.
7. No illumination of antennas and equipment —Addressed
8. Director authorization to deviate —Authorization to deviate has not been
requested.
D. Specific Design Standards — Current proposal is for Location Preference No. 4 — Existing
Power Pole (Installation in Communication Space).
a. Antennas placed to minimize visual clutter. One antenna array permitted. Side
mounted canister not more than 12 inches from surface of wooden pole.
Addressed.
b. Unified enclosure, if proposed, shall not exceed four cubic feet. Unified
enclosure placed to appear integrated with pole and placed not more than six
inches from surface of pole.
N/A — unified enclosure not proposed.
5-Notice of Incomplete Application
f nC. 189\)
CITY OF EDMONDS
121 5t" Avenue North, Edmonds WA 98020
Phone: 425.771.0220 • Fax: 425.771.0221 • Web: www.edmondswa
PUBLIC WORKS DEPARTMENT • ENGINEERING DIVISION
c. Equipment/enclosures/boxes color matched. Equipment mounted not more
than 6" from pole.
Addressed.
d. Cables and wires in color matched conduit. Number of conduit minimized to
number technically necessary and shall not increase number on pole by more
than three conduit.
Addressed.
e. Visual effect of facility shall be minimized to greatest extent possible.
Addressed.
f. Wooden pole replacement not to extend more than 10-feet above height of
existing pole unless required (in writing) by pole owner proposal is minimum
necessary.
Addressed. PUD requires increased height from 33'1" to 47'6".
g. Use of pole for small wireless facility shall be secondary to primary function of
pole.
Addressed.
The proposed small cell wireless location is considered a Collocation which has a 60-day shot
clock in accordance with ECDC 20.50.060(B). This Notice of Incomplete Application is being
provided on day 10 of the shot clock period, and the clock will be reset to zero until a
resubmission is received. If no resubmission is received within three weeks of the date of this
notice, then the above referenced application will be considered to be void.
Sincerely,
Jeanie McConnell
Engineering Program Manager
Michael Clugston
Senior Planner
6-Notice of Incomplete Application