DNS BLD2021-1248+Project Narrative+9.8.2021_1.56.00_PM+2397865smartlink
September 3, 2021
City of Edmonds
Development Services, Building Division
121 5t" Ave. N
Edmonds, WA 98020
RE: Project Narrative — SE01451A Woodway — Executive Homeowners Assoc (1001 5t" Ave
S, Edmonds, WA 98020)
To Whom it May Concern:
T-Mobile is currently upgrading and integrating former Sprint sites into its network because of
their recent merger and acquisition of Sprint. The Edmonds area is an area where T-Mobile will
make available improved telephone service and provide wireless coverage and capacity to its
subscribers.
It is T-Mobile's desire to work with the City of Edmonds to ensure that this project is consistent
with local ordinances and zoning regulations while providing excellent wireless coverage to T-
Mobile's customers and provide critical communication services for emergency, business, and
personal use.
The applicant is requesting the following:
• Commercial Building Permit approval
Project Overview
The applicant, T-Mobile, proposes a minor modification to an existing rooftop
telecommunications facility located at 1001 5th Ave S, Edmonds, WA 98020 (Parcel No.
00694700210200).
The proposed modification consists of the following: Remove (3) existing Sprint antennas, (3)
RRU's and (1) coax cables. Install (6) T-Mobile antennas, (6) RRH's, (3) pendants and (3) hybrid
cables behind (1) replaced antenna shroud and (2) new matching antenna shrouds integrated
on the chimney structures. Remove (1) existing Sprint equipment rack. Install (2) T-Mobile
equipment racks and (3) Junction Boxes within the existing equipment room on ground floor.
Please see construction drawings for more detailed information.
T-Mobile
SE01451A Woodway — Executive Homeowners Assoc
Page 7
Please note that this proposed modification is consistent with and meets the criteria for an
Eligible Facilities Request under Section 6409/47 CFR § 1.6100 ("6409") and Federal
Communications Commission ("FCC") rules and ECC Ch. 20.50.080 Eligible Facilities Request,
which has not been updated to reflect the current version of 6409.
Link to the current version: §1.6100 Wireless Facility Modifications.
According to ECC 20.50.080:
3. "Eligible facilities request" means any request for modification of an existing tower or base
station that does not substantially increase the physical dimensions of such tower or base
station, involving:
a. Collocation of new transmission equipment;
b. Removal of transmission equipment; or
c. Replacement of transmission equipment.
This proposal is for the replacement of transmission equipment and collocation of new
transmission equipment.
7. Substantial Change. A modification substantially changes the physical dimensions of an
eligible support structure if it meets any of the following criteria:
a. For towers other than towers in the public rights -of -way, it increases the height of the
tower by more than 10 percent or by the height of one additional antenna array with
separation from the nearest existing antenna, not to exceed 20 feet, whichever is greater;
for other eligible support structures, it increases the height of the structure by more than
10 percent or more than 10 feet, whichever is greater.
This site does not meet the definition of a tower; therefore, it is not applicable to this project.
This site meets the definition of a base station. Accordingly, there will be no increase in height
with this proposal. Please see the plan set for more detailed information.
i. Changes in height should be measured from the original support structure in cases
where deployments are or will be separated horizontally, such as on buildings' rooftops;
in other circumstances, changes in height should be measured from the dimensions of
the tower or base station, inclusive of originally approved appurtenances and any
modifications that were approved prior to the passage of the Spectrum Act;
There will be no increase in height with this proposal. Please see the plan set for more
detailed information.
T-Mobile
SE07457A Woodway — Executive Homeowners Assoc
Page 2
b. For towers other than towers in the public rights -of -way, it involves adding an
appurtenance to the body of the tower that would protrude from the edge of the tower
more than 10 feet, or more than the width of the tower structure at the level of the
appurtenance, whichever is greater; for other eligible support structures, it involves adding
an appurtenance to the body of the structure that would protrude from the edge of the
structure by more than six feet,
This site meets the definition of a base station. Accordingly, there will be no protrusion from
the edge of the structure more than six feet.
c. For any eligible support structure, it involves installation of more than the standard
number of new equipment cabinets for the technology involved, but not to exceed four
cabinets; or, for towers in the public streets and base stations, it involves installation of any
new equipment cabinets on the ground if there are no preexisting ground cabinets
associated with the structure, or else involves installation of ground cabinets that are more
than 10 percent larger in height or overall volume than any other ground cabinets
associated with the structure;
The proposal calls to remove (1) existing equipment rack and install (2) new equipment racks
within the ground level equipment room.
*d. It entails any excavation or deployment outside the current site;
This is an existing roof top site; there will not be any excavation or deployment outside of the
roof area. Please see the plan set for more detailed information.
e. It would defeat the concealment elements of the eligible support structure; or
The existing antennas and radio equipment are concealed within an antenna shroud that's
integrated to look like a chimney structure. The replacement shroud and two additional
shrouds will look similar to the existing antenna shroud in color and texture of the building.
f. It does not comply with conditions associated with the siting approval of the construction
or modification of the eligible support structure or base station equipment; provided,
however, that this limitation does not apply to any modification that is noncompliant only in
a manner that would not exceed the thresholds identified above.
The proposed modifications will not violate any conditions associated with the siting
approval. The proposal does not exceed the thresholds outlined in above.
* The revised and current FCC rule is:... (iv) It entails any excavation or deployment outside of
the current site, except that, for towers other than towers in the public rights -of -way, it entails
any excavation or deployment of transmission equipment outside of the current site by more
T-Mobile
SE01451A Woodway —Executive Homeowners Assoc
Page 3
than 30 feet in any direction. The site boundary from which the 30 feet is measured excludes any
access or utility easements currently related to the site;
Sincerely,
Land Use Specialist
Smartlink Group
bryson.burghardt@smartlinkgroup.com
360-581-8189
T-Mobile
SE01457A Woodway — Executive Homeowners Assoc
Page 4