DNS REVIEWED PLN EFR DocumentationCROWN
CASTLE
Via Online Submittal
February 9, 2022
CITY OF EDMONDS, WA
Development Services
1215th Ave N,
Edmonds, WA 98020
1505 Westlake Ave N, N
Seattle, WA 98109
Phone:
www.crowncastle.com
**********NOTICE OF ELIGIBLE FACILITIES REQUEST**********
RE: Eligible Facilities Request to modify equipment on a communications tower located at:
• 23931 HVV1' 99, Edmonds, WA 98026
• Assessors Tax Parcel ID number: 004519-002-015-04
Jurisdiction: City of Edmonds, WA
Application for Commercial Building Permit
Crown Site Number: 840470
Application ID: 565153
Crown Name: Lake Ballinger
Carrier: AT&T
Carrier site ID: WA6358
Carrier site name: Lake Ballinger
Dear Reviewing Parties:
On behalf of New Cingular Wireless PCS, LLC ("AT&T" or "Applicant"), Crown Castle USA Inc. ("Crown Castle") is pleased
to submit this request to modify the existing wireless facility noted above through the collocation, replacement and/or
removal of the Applicant's equipment as an eligible facilities request for a minor modification under Section 64og, and the
rules of the Federal Communications Commission ("FCC").2
Section 6409 mandates that state and local governments must approve any eligible facilities request for the modification of
an existing wireless tower or base station that does not substantially change the physical dimensions of such tower or base
station. Under Section 6409, to toll the review period, if the reviewing authority determines that the application is
1 Middle Class Tax Relief and Job Creation Act of 2012, Pub. L. No. 112-96, § 6409 (2012) (codified at 47 U.S.C. § 1455).
2 Acceleration of Broadband Deployment by Improving Wireless Facility Siting Policies, 29 FCC Rcd. 12865 (2014) (codified at 47
CFR § 1.6100); and Implementation of State & Local Governments' Obligation to Approve Certain Wireless Facility Modification
Requests Under Section 6409(a) of the Spectrum Act of 2012, WT Docket No. 19-250 (June 10, 2020).
3 See 47 CFR § 1.61oo (c)(3). 4 See 2020 Upgrade Order at paragraph 16.
The Foundation for a Wireless World
CrownCastle.com
CROWN
CASTLE
1505 Westlake Ave N, N
Seattle, WA 98109
Phone:
www.crowncastle.com
incomplete, it must provide written notice to the applicant within 3o days, which clearly and specifically delineates all
missing documents or information reasonably related to whether the request meets the federal requirements.3 Additionally,
if a state or local government, fails to issue any approvals required for this request within 6o days, these approvals are
deemed granted. The FCC has clarified that the 3o-day and 6o-day deadlines begins when an applicant: (1) takes the first
step required under state or local law; and (2) submits information sufficient to inform the jurisdiction that this modification
qualifies under the federal law. Please note that with the submission of this letter and enclosed items, the thirty and sixty-
day review periods have started. Based on this filing, the deadline for written notice of incomplete application is March 11,
2022, and the deadline for issuance of approval is April 10, 2022.
The proposed scope of work for this project includes:
Add, remove, or replace antennas, ancillary equipment and ground equipment as per plans for an existing carrier on an
existing wireless communication facility.
At the end of this letter is a checklist of the applicable substantial change criteria under Section 6409. Additionally, please
find enclosed the following information in support of this Commercial Building Permit Application:
• Applicant Cover Letter with Attachment A: Section 6409 Substantial Change Checklist (see this document);
• City of Edmonds Building Permit (through portal);
• Structural Analysis, by Morrison Hershfield, dated 7/5/21;
• Mount Analysis, by B+T Group, dated 6/28/22 (note: MA is conditionally passing with recommendations- see
Attachment B and sheet C-2 of the Construction Drawings);
• Construction Drawings, by PM8rA, dated 1/27/22;
• Crown Castle Agent Authorization to Submit for Permits.
As these documents indicate, (i) the modification involves the collocation, removal or replacement of transmission
equipment; and (ii) such modification will not substantially change the physical dimensions of such tower or base station.
As such, it is an "eligible facilities request" as defined in the FCC's rules to which the 6o-day deadline for approval applies.
Accordingly, Applicant requests all authorization necessary for this proposed minor modification under Section 6409.
Our goal is to work with you to obtain approvals earlier than the deadline. We will respond promptly to any request for
related information you may have in connection with this request. Please let us know how we can work with you to expedite
the approval process. We look forward to working with you on this important project, which will improve wireless
telecommunication services in your community using collocation on existing infrastructure. If you have any questions,
please do not hesitate to contact me.
Regards,
Fnd& Deacfuunp,3
Emilie Deschamps for Crown Castle on behalf of AT&T
The Foundation for a Wireless World
CrownCastle.com
CROWN
CASTLE
1505 Westlake Ave N, N
Seattle, WA 98109
Attachment A
Section 6409 Substantial Change Checklist
Towers Outside of the Public Right of Way
Phone:
www.crowncastle.com
The Federal Communications Commission has determined that a modification substantially changes the physical dimension of a wireless tower or base
station under 47 U.S.C. § 1455(a) if it meets one of six enumerated criteria under 47 C.F.R. § 1.6100.
Criteria for Towers Outside the Public Rights of Way
YES/NO
Does the modification increase the height of the tower by more than the greater of:
NO
(a) 10%
(b) or, the height of an additional antenna array plus separation of up to 20 feet from the top of
the nearest existing antenna?
YES/NO
Does the modification add an appurtenance to the body of the tower that would protrude from the
NO
edge of the tower more than 20 feet or more than the width of the tower structure at the level of the
appurtenance, whichever is greater?
YES/NO
Does the modification involve the installation of more than the standard number of new equipment
NO
cabinets for the technology involved or add more than four new equipment cabinets?
YES/NO
Does the modification entail any excavation or deployment outside the current site by more than 30
NO
feet in any direction, not including any access or utility easements?
YES/NO
Does the modification defeat the concealment elements of the eligible support structure?
NO
YES/NO
Does the modification violate conditions associated with the siting approval with the prior approval the
NO
tower or base station other than as specified in 47 C.F.R. § 1.6100(c)(7)(i) — (iv)?
If all questions in the above section are answered "NO," then the modification does not constitute a substantial change to the existing
tower under 47 C.F.R. § 1.6ioo.
The Foundation for a Wireless World
CrownCastle.com
NOTES:
1. CONTRACTOR TO VERIFY ALL ANTENNA TIP HEIGHTS DO
NOT EXCEED BEACON BASE HEIGHT,
MOUNT ANALYSIS NOTES:
1. THE DESIGN DEPICTED IN THESE DRAWINGS IS VALID
WHEN ACCOMPANIED BY A CORRESPONDING PASSING
MOUNT ANALYSIS.
2, CONSTRUCTION MANAGER / GENERAL CONTRACTOR SHALL
REVIEW THE MOUNT ANALYSIS FOR ANY CONDITIONS PRIOR
TO INSTALLATION.
3. ANY REQUIRED MOUNT MODIFICATION DESIGN OR MOUNT
REPLACEMENT SHALL BE APPROVED BY EOR.
Attachment B
EXISTING AT&T EQUIPMENT TO REMAIN
- (6) ANTENNAS
- (12) RRH
- (2) DC6-48-60-18-8F RAYCAP SQUID
AT&T EQUIPMENT TO BE INSTALLED
- (3) NOKIA AEQK ANTENNAS
AT&T
CROWN
- (1) DC9-48-60-24-8C-EV RAYCAP SQUID
CCCASTLE
EXISTING AT&T PLATFORM MOUNT TO BE UPGRADED/MODIHED PER THE
1505 WFSTIAKE AVENUE NORTH,SUITE8o0
MOUNT ANALYSIS
SEATTLE, WA 98109
INSTALL (2) STANDOFF MOUNTS (SMEPRO1 IMWM02 - HSS4X4X4 -
PLATFORM FACE
ONTNEW CHANNEL AND THE REINFORCING FACE
HORI LONG), ATTACHED TO THE REINFORCING TALHED PIPElp�vm
' ATTA
WITH NEW ANTENNA MOUNTING PIPE 2' STD X 6'-O' ATTACHED TO
WITH
THE NEW STANDOFF MOUNTS, NEAR POSITION /3 AT GAMMA SECTOR.
MOVE EXISTING ANTENNA MOUNTING PIPE OF POSITION /3 AT A1PHA
SECTOR, 1'-9' TOWARDS POSITION J4.
PROPOSED SITE PRO 1 SCHMT COLLAR MOUNT FOR
P. MARSHALL & ASSOCIATES
RRH MOUNTED 18' BELOW AT&T MOUNT
v-• M
BU #: 840470
LAKE BALLINGER
23931 HIGHWAY 99
EDMONDS, WA 98026
PROPOSED AT&T (1) j6 AWG DC TRUNK(S)
- EXISTING AT&T FEEDLINES
- (18) 7/8' COAX CABLES
- (4) p8 AWG DC TRUNKS
- (2) FIBER TRUNK
1) RET
- EXISTING MONOPOLE
REVI
A
DATE
711MI
I DESCRIPTION
PRELIMS
0
In=
FORCONSTRUCTION
wna-
DESIGNED: JLB
DRAWN: JLB
CHECKED: PWM
21CCAO6M-0080
FINAL SOUTH ELEVATION
NOT TO SCALE
EXISTING & FINAL
ELEVATIONS
C•2