ATTACHMENTS 17-23f 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
NOTICE OF INCOMPLETE APPLICATION
Application ID: AT&T Site ID: WAALD-003-E/17727-003-E
ENG 2021-0218
Received by City: December 17, 2021 at 3:48 pm
Date of Notice: December 23, 2021
Applicant: Jay Rodriguez
Program Manager-SAQ
MasTec Network Solutions, on behalf of AT&T
Jay. Rod riguez@ mastec. com
The City received the following documents in connection with the above referenced
application:
1. Code Compliance Narrative, undated (12.17.2021 Final 17727-003 Edmonds Code
Compliance Narrative.pdf)
2. Letter in response to the City's June 24,2021 Notice of Incomplete Application
(12.17.2021 Final Edmonds Response Nol ENG2021-0218.pdf)
3. Project Information and Drawings, Sheet numbers T-1; GN-1-2; A-1-8; RF-1; E-1; G-1
(CRAN_RWOR_WAALD-003-E_211129.FCD_compressed (1).pdf)
4. Photograph simulations of proposed installation Sheets 1-3/3
(CRAN_RWOR_WAALD-003-E_211214_Photosim.pdf)
This notice serves to identify areas where the application is incomplete, explaining where the
city needs additional information based on the responses AT&T provided in the above
referenced documents. 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
1-Notice of Incomplete Application
ATTACHMENT 17
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
`nc. I g9v
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).
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:
Application fee received per City fee schedule
ECDC 20.50.070 APPLICATION REQUIREMENTS
A. Project description — "► t G-d-dr.«ed or-e,e .t desc-4pti ,n d,,,,s net include to neie,.,,
desei4ptien which is necessary in evaluating applicant's claim of technical infeasibility for
Location Preference No. 2. ECDC 20.50.070 (A). Addressed in Letter in response to the
City's June 24,2021 Notice of Incomplete Application.
B. Aerial photo or map - Addressed
C. Site information on scaled Dlans. includi
1. Site plan -Addressed
2. Elevation drawings - Addressed
3. Utility Dlan showing existing utilities. Dr000sed facilitv location. and
undergroundinR — N t G,d,dr„sried ► ►tilt„ I ., S►,eWS Sen9e bUt net ell „ ;Ming
utilities.€CDC 2038.070(H(3) 44issing utilities include, but eFe net—lingite,
Gity 4E�ln9ePd-s byeter, sew terns, Gs well Gs City 4Lynnweed sewerfeTcem
line "GturGi gGs need-s be shewn .{„resent. It is necessary to show all existing
utilities so that the City can evaluate the feasibility of all location preferences,
2-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\)
not just the one the applicant applied for. Addressed in Letter in response to the
City's June 24,2021 Notice of Incomplete Application.
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 facilitv deDlovments. the following documentation shall be Drovided
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.
b. Written documentation from all pole owners denying replacement of existing
poles with hollow.
Addressed.
c. Written documentation from Dole 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:
Evidence that design standards for freestandinE small wireless cannot be met.
Not addressed: Establish infeasibility per ECDC 20.50.130 (B) "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." See missing information relating to
sheet A-1 below.
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
3-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
considers a request for confirmation to have been constructively made of the
Director, and the request is being evaluated.
c. Not addressed: Establish infeasibility per ECDC 20.50.130 (B) "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 76' 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.
Please respond: Your response (Letter in response to the City's June 24,2021
Notice of Incomplete Application) states that "In order to construct or maintain a
new 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 bucket crosses through the communications lines, as well as
maintaining required clearances from any nearby energized electrical lines."
Please provide the citation to authority, including the regulation, that prohibits
the arm or bucket from crossing communication lines.
Please respond: Your response (Letter in response to the City's June 24,2021
Notice of Incomplete Application) raised the following unanswered questions: We
understand Snohomish County PUD covers lines with blankets while doing work
near wires. Please explain why (i) covering lines with a blanket shield does not
enable you to place a freestanding facility while complying with the regulations
you cited and (ii) why temporarily shutting off power to lines does not enable you
to place a freestanding facility while complying with the regulations you cited.
Please respond: Your response (Letter in response to the City's June 24,2021
Notice of Incomplete Application) raised the following unanswered questions:
Your Sheet A-1 Survey Plan and Elevations shows the ROW boundary and the
proposed pole at a scale of 1 inch = 10 feet. Although the ROW lines shown are
4-Notice of Incomplete Application
`7C. 199"
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
approximate, the map shows approximately five feet of space between the pole
and the ROW edge. Please explain why a freestanding facility cannot be placed
inside the ROW edge within 150 lineal feet in either direction of the proposed
pole and be more than three feet away from existing lines on the pole. Please
provide a scaled plan view and elevation documents showing the existing
communication and electrical wires on both sides of the street within 150 lineal
feet of the proposed small cell location and showing the ROW boundary and the
distance between the wires and the ROW boundary to establish there is or is not
a three feet buffer between the wires and a freestanding wireless facility placed
inside the edge of the ROW.
. .
.. .
. .
. . .
*"A G!L-G -GPGe5 tG which you F^fe -enee. Addressed in Letter in
response to the City's June 24,2021 Notice of Incomplete Application.
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.
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
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
f. Historic property — N/A
g. Wood pole with streetlight — N/A
Location Preference Hierarchy
1. Preference No. 1— hollow utility pole — N/A
2. Preference No. 2 —freestanding small wireless facilitv 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. SianaRe reauirements (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.
6-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\)
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.
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 3311" to 4716".
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 6 of the shot clock period, and the clock will be tolled until a resubmission is
received.
SincerkRobert
ly,
S. En ish
Acting Director of Public Works
7-Notice of Incomplete Application
From: Ken Lyons <ken.lyons@wirelesspolicy.com>
Sent: Monday, January 3, 2022 11:28 AM
To: McConnell, Jeanie
Cc: Gregg Busch; Jay Rodriguez
Subject: AT&T - N01 Request Questions
Hi Jeanie:
I left you a VM as well. Would you please give me a call at your convenience? The N01 sent over is
confusing, and I had a few questions.
Please let me know when you are available.
Best,
Ken Lyons
Senior Vice President —Jurisdiction Relations
Wireless Policy Group LLC
(206) 227-0020 mobile
(425) 483-1070 fax
ken.lyons@wirelesspolicy.com
ATTACHMENT 18
From: McConnell, Jeanie
Sent: Monday, January 10, 2022 2:18 PM
To: Ken Lyons
Cc: Gregg Busch; Jay Rodriguez; Clugston, Michael
Subject: RE: AT&T - NO1 Request Questions
Good afternoon Ken,
Below is some additional information regarding the NOI:
1) The City is asking for a citation to authority as the reason a bucket truck cannot be used to get a
freestanding facility on the east side of 76th Ave W (where there are comm lines only.) The City had
asked for one, but didn't receive one, so we are asking again. If you don't have one, then let us
know. In your Code Compliance Narrative, you cite to WAC 296-24-960 (the ten -foot radial
clearance) as preventing you from working near the power lines on the west side, but you don't cite
any authority why you can't operate a bucket truck on the east side where there's only comm lines.
Same thing in your Response to NOI. (Our code requires the applicant to provide evidence the
design standards for a freestanding facility could not be met/that it's not feasible to place a
freestanding facility)
2) In the resubmittal materials it was stated there isn't room to maintain a three-foot clearance
between the top of a freestanding facility and the comm lines as required by NESC 234B.1.a., but
sheet A-1 Survey Plan and Elevations indicates there is five feet between the proposed PUD pole and
the edge of ROW, with the disclaimer it's approximate and not a boundary survey. Based on the
submitted materials, it looks like there is room, but we are giving you an opportunity to show there
is not by providing a scaled plan view and elevation documents.
I hope this provides some clarity on the NO1.
Regards,
Jeanie
From: McConnell, Jeanie
Sent: Tuesday, January 4, 2022 8:18 AM
To: Ken Lyons <ken.lyons@wirelesspolicy.com>
Cc: Gregg Busch<gregg.busch@wirelesspolicy.com>; Jay Rodriguez <Jay.Rodriguez@mastec.com>
Subject: RE: AT&T - NOI Request Questions
Hi Ken,
I wanted to confirm receipt of your email and also let you know that I was out of the office the past
couple of weeks so before I reach out to you on this I need to get an update from other staff.
Happy New Year!
-Jeanie
ATTACHMENT 19
From: Ken Lyons <ken.lyons@wirelesspolicy.com>
Sent: Monday, January 3, 2022 11:28 AM
To: McConnell, Jeanie<Jeanie.McConnell@edmondswa.gov>
Cc: Gregg Busch<gregg.busch@wirelesspolicy.com>; Jay Rodriguez <Jay.Rodriguez@mastec.com>
Subject: AT&T - NOI Request Questions
Hi Jeanie:
I left you a VM as well. Would you please give me a call at your convenience? The NO1 sent over is
confusing, and I had a few questions.
Please let me know when you are available.
Best,
Ken Lyons
Senior Vice President —Jurisdiction Relations
Wireless Policy Group LLC
(206) 227-0020 mobile
(425) 483-1070 fax
ken.lyons@wirelesspolicy.com
From: Ken Lyons <ken.lyons@wirelesspolicy.com>
Sent: Thursday, January 13, 2022 12:25 PM
To: McConnell, Jeanie
Cc: Gregg Busch; Jay Rodriguez; Clugston, Michael
Subject: Re: AT&T - N01 Request Questions
Good afternoon Jeanie -
Thank you for your email on Monday. While this is helpful, it doesn't address some of the questions I
had.
ECDC 20.50.130.D.2.a.iii.E specifically requires that when evaluating a new pole option, the new pole
must be "...alignment with existing trees, utility poles, and streetlights." There are no existing street
trees or streetlights in this area, but there are, of course, utility poles. The new pole locations the City is
suggesting do not (and could not) meet these requirements. Would you please advise why the City is
asking us to evaluate new pole locations that could not be approved given these requirements?
Further, the NOI does not address AT&T's documentation showing that that height limit un ECDC
20.50.130.D.2.a.i is insufficient for the coverage objectives of the facility. Would you please advise why
the City hasn't commented on this documentation, or why it wouldn't be sufficient for showing new
poles is not feasible?
Finally, I had a question about the clear zone requirements, but it really follows these first two
questions.
Please let me know if you prefer to discuss by phone. I can make myself available under your schedule.
Best regards,
Ken Lyons
Senior Vice President —Jurisdiction Relations
Wireless Policy Group LLC
(206) 227-0020 mobile
(425) 483-1070 fax
ken.lyons@wirelesspolicy.com
From: McConnell, Jeanie <Jeanie.McConnell @edmondswa.gov>
Date: Monday, January 10, 2022 at 2:17 PM
To: Ken Lyons <ken.lyons@wirelesspolicy.com>
Cc: Gregg Busch<gregg.busch@wirelesspolicy.com>, Jay Rodriguez
<Jay.Rodriguez@mastec.com>, Clugston, Michael <Michael.Clugston@edmondswa.gov>
Subject: RE: AT&T - NOI Request Questions
Good afternoon Ken,
ATTACHMENT 20
Below is some additional information regarding the NOI:
1) The City is asking for a citation to authority as the reason a bucket truck cannot be used to get a
freestanding facility on the east side of 76th Ave W (where there are comm lines only.) The City had
asked for one, but didn't receive one, so we are asking again. If you don't have one, then let us
know. In your Code Compliance Narrative, you cite to WAC 296-24-960 (the ten -foot radial
clearance) as preventing you from working near the power lines on the west side, but you don't cite
any authority why you can't operate a bucket truck on the east side where there's only comm lines.
Same thing in your Response to NOI. (Our code requires the applicant to provide evidence the
design standards for a freestanding facility could not be met/that it's not feasible to place a
freestanding facility)
2) In the resubmittal materials it was stated there isn't room to maintain a three-foot clearance
between the top of a freestanding facility and the comm lines as required by NESC 234B.1.a., but
sheet A-1 Survey Plan and Elevations indicates there is five feet between the proposed PUD pole and
the edge of ROW, with the disclaimer it's approximate and not a boundary survey. Based on the
submitted materials, it looks like there is room, but we are giving you an opportunity to show there
is not by providing a scaled plan view and elevation documents.
I hope this provides some clarity on the NO1.
Regards,
Jeanie
From: McConnell, Jeanie
Sent: Tuesday, January 4, 2022 8:18 AM
To: Ken Lyons <ken.lyons@wirelesspolicy.com>
Cc: Gregg Busch <gregg.busch@wirelesspolicy.com>; Jay Rodriguez <Jay.Rodriguez@mastec.com>
Subject: RE: AT&T - NOI Request Questions
Hi Ken,
I wanted to confirm receipt of your email and also let you know that I was out of the office the past
couple of weeks so before I reach out to you on this I need to get an update from other staff.
Happy New Year!
-Jeanie
From: Ken Lyons <ken.lyons@wirelesspolicy.com>
Sent: Monday, January 3, 2022 11:28 AM
To: McConnell, Jeanie<Jeanie.McConnell@edmondswa.gov>
Cc: Gregg Busch<gregg.busch@wirelesspolicy.com>; Jay Rodriguez <Jay.Rodriguez@mastec.com>
Subject: AT&T - NOI Request Questions
Hi Jeanie:
I left you a VM as well. Would you please give me a call at your convenience? The NO1 sent over is
confusing, and I had a few questions.
Please let me know when you are available.
Best,
Ken Lyons
Senior Vice President —Jurisdiction Relations
Wireless Policy Group LLC
(206) 227-0020 mobile
(425) 483-1070 fax
ken.lyons@wirelesspoiicy.com
From: McConnell, Jeanie
Sent: Monday, January 24, 2022 8:42 AM
To: Ken Lyons
Cc: Gregg Busch; Jay Rodriguez; Clugston, Michael
Subject: RE: AT&T - NOI Request Questions
Hi Ken,
City staff are in the fact gathering stage of the process and ask that you provide what we have requested
so that we can do our analysis. The City disagrees with your interpretation that a freestanding pole could
not meet the code requirements of ECDC 20.50.130(D)(2)(a)(iii)(E).
Regards,
Jeanie
From: Ken Lyons <ken.lyons@wirelesspolicy.com>
Sent: Thursday, January 13, 2022 12:25 PM
To: McConnell, Jeanie<Jeanie.McConnell@edmondswa.gov>
Cc: Gregg Busch<gregg.busch@wirelesspolicy.com>; Jay Rodriguez <Jay.Rodriguez@mastec.com>;
Clugston, Michael<Michael.Clugston@edmondswa.gov>
Subject: Re: AT&T - NOI Request Questions
Good afternoon Jeanie -
Thank you for your email on Monday. While this is helpful, it doesn't address some of the questions I
had.
ECDC 20.50.130.D.2.a.iii.E specifically requires that when evaluating a new pole option, the new pole
must be "...alignment with existing trees, utility poles, and streetlights." There are no existing street
trees or streetlights in this area, but there are, of course, utility poles. The new pole locations the City is
suggesting do not (and could not) meet these requirements. Would you please advise why the City is
asking us to evaluate new pole locations that could not be approved given these requirements?
Further, the NOI does not address AT&T's documentation showing that that height limit un ECDC
20.50.130.D.2.a.i is insufficient for the coverage objectives of the facility. Would you please advise why
the City hasn't commented on this documentation, or why it wouldn't be sufficient for showing new
poles is not feasible?
Finally, I had a question about the clear zone requirements, but it really follows these first two
questions.
Please let me know if you prefer to discuss by phone. I can make myself available under your schedule.
Best regards,
Ken Lyons
Senior Vice President —Jurisdiction Relations
ATTACHMENT 21
Wireless Policy Group LLC
(206) 227-0020 mobile
(425) 483-1070 fax
ken.lyons@wirelesspoiicy.com
From: McConnell, Jeanie <Jeanie.McConnell @edmondswa.gov>
Date: Monday, January 10, 2022 at 2:17 PM
To: Ken Lyons <ken.lyons@wirelesspolicy.com>
Cc: Gregg Busch <gregg.busch@wirelesspolicy.com>, Jay Rodriguez
<Jay.Rodriguez@mastec.com>, Clugston, Michael <Michael.Clugston@edmondswa.gov>
Subject: RE: AT&T - NO1 Request Questions
Good afternoon Ken,
Below is some additional information regarding the NOI:
1) The City is asking for a citation to authority as the reason a bucket truck cannot be used to get a
freestanding facility on the east side of 76th Ave W (where there are comm lines only.) The City had
asked for one, but didn't receive one, so we are asking again. If you don't have one, then let us
know. In your Code Compliance Narrative, you cite to WAC 296-24-960 (the ten -foot radial
clearance) as preventing you from working near the power lines on the west side, but you don't cite
any authority why you can't operate a bucket truck on the east side where there's only comm lines.
Same thing in your Response to NOI. (Our code requires the applicant to provide evidence the
design standards for a freestanding facility could not be met/that it's not feasible to place a
freestanding facility)
2) In the resubmittal materials it was stated there isn't room to maintain a three-foot clearance
between the top of a freestanding facility and the comm lines as required by NESC 234B.1.a., but
sheet A-1 Survey Plan and Elevations indicates there is five feet between the proposed PUD pole and
the edge of ROW, with the disclaimer it's approximate and not a boundary survey. Based on the
submitted materials, it looks like there is room, but we are giving you an opportunity to show there
is not by providing a scaled plan view and elevation documents.
I hope this provides some clarity on the NOI.
Regards,
Jeanie
From: McConnell, Jeanie
Sent: Tuesday, January 4, 2022 8:18 AM
To: Ken Lyons <ken.lyons@wirelesspolicy.com>
Cc: Gregg Busch <gregg.busch@wirelesspolicy.com>; Jay Rodriguez <Jay.Rodriguez@mastec.com>
Subject: RE: AT&T - NOI Request Questions
Hi Ken,
I wanted to confirm receipt of your email and also let you know that I was out of the office the past
couple of weeks so before I reach out to you on this I need to get an update from other staff.
Happy New Year!
-Jeanie
From: Ken Lyons <ken.lyons@wirelesspolicy.com>
Sent: Monday, January 3, 2022 11:28 AM
To: McConnell, Jeanie<Jeanie.McConnell@edmondswa.gov>
Cc: Gregg Busch<Bregg.busch@wirelesspolicy.com>; Jay Rodriguez <Jay.Rodriguez@mastec.com>
Subject: AT&T - NOI Request Questions
Hi Jeanie:
I left you a VM as well. Would you please give me a call at your convenience? The NO1 sent over is
confusing, and I had a few questions.
Please let me know when you are available.
Best,
Ken Lyons
Senior Vice President —Jurisdiction Relations
Wireless Policy Group LLC
(206) 227-0020 mobile
(425) 483-1070 fax
ken.lyons@wirelesspoiicy.com
From: McConnell, Jeanie
Sent: Thursday, February 10, 2022 7:24 AM
To: ken.lyons@wirelesspolicy.com
Cc: Clugston, Michael
Subject: ROW Permit ENG2021-0218 - 20901 76th Ave W
Attachments: Attachment A - ROW Construction Permit Application_06.14.21.pdf
Good morning Ken,
I wanted to follow-up with you on the subject small wireless facility application (ENG2021-0218). The
City has completed review of the application based on the information we have and no longer requires
supplemental information from the applicant. We've determined that the criteria to move beyond
Location Preference 2 has been satisfied and we're continuing to analyze the application. It appears as
though we will be able to issue the right-of-way permit application soon.
As the City received the right-of-way permit application last year, can you please confirm that the
contractor information remains correct. I have attached a copy of the application for your reference.
Thank you,
Jeanie
Jeanie McConnell I Engineering Program Manager
City of Edmonds
425-771-0220, ext 1338
6eanie.mcconnell@edmondswa.gov
City Hall is currently closed. Remote and online permitting services are available Monday -Friday,
including Zoom meetings. For general inquires please email EngineeringPermitsCa>edmondswa.gov or
call 425-771-0220.
ATTACHMENT 22
McConnell, Jeanie
From: Ken Lyons <ken.lyons@wirelesspolicy.com>
Sent: Thursday, February 10, 2022 10:00 AM
To: McConnell, Jeanie
Cc: Clugston, Michael; Gregg Busch; Jay Rodriguez; mg454q@att.com
Subject: Re: ROW Permit ENG2021-0218 - 20901 76th Ave W
Hi Jeanie:
I left you a VM this morning as well. Let us know if you have a minute to discuss.
We did confirm that Mastec is the contractor. The info they sent over appears to match the application -
MASTENS876KN ; expires 5/23 also WA UBI # 603 235 974
However, please note the Amber is no longer with Mastec. Suggest using Moriah Gould, the AT&T project manager as
the updated contact:
Moriah Gould
cRAN Site Acquisition PM - WA
AT&T Mobility
Cell: (971) 832-3579 1 mg454q@att.com
Best regards,
Ken Lyons
Senior Vice President —Jurisdiction Relations
Wireless Policy Group LLC
(206) 227-0020 mobile
(425) 483-1070 fax
ken.lyons@wirelesspolicy.com
From: McConnell, Jeanie<Jeanie.McConnell @edmondswa.gov>
Date: Thursday, February 10, 2022 at 7:24 AM
To: Ken Lyons <ken.lyons@wirelesspolicy.com>
Cc: Clugston, Michael <Michael.Clugston@edmondswa.gov>
Subject: ROW Permit ENG2021-0218 - 20901 76th Ave W
Good morning Ken,
I wanted to follow-up with you on the subject small wireless facility application (ENG2021-0218). The City has completed
review of the application based on the information we have and no longer requires supplemental information from the
applicant. We've determined that the criteria to move beyond Location Preference 2 has been satisfied and we're
continuing to analyze the application. It appears as though we will be able to issue the right-of-way permit application
soon.
ATTACHMENT 23
As the City received the right-of-way permit application last year, can you please confirm that the contractor
information remains correct. I have attached a copy of the application for your reference.
Thank you,
Jeanie
Jeanie McConnell I Engineering Program Manager
City of Edmonds
425-771-0220, ext 1338
jeanie.mcconnell@edmondswa.gov
City Hall is currently closed. Remote and online permitting services are available Monday -Friday, including Zoom
meetings. For general inquires please email Engineerin@Permits@edmondswa.gov or ca11425-771-0220.