BLD2021-0621+ELIGIBLE FACILITIES REQUEST+4.30.2021_4.16.43_PM+2174203N L Y N X
RECEIVED
May 03 2021
Autharixed Verizon Wireless Representattve
CITY OF EDMONDS
DEVELOPMENT SERVICES
DEPARTMENT
ELIGIBLE FACILITIES REQUEST
BLD2021-0621
VERI20N WIRELESS 60-DAY ELIGIBLE FACILITY REQUEST
MODIFICATION OF EXISTING WIRELESS BASE STATION
Request Date: April 30, 2020
jurisdiction: City of Edmonds
Departments: Planning/Land Use and Engineering Review
Site Address: 100 211d Avenue South (Verizon Wireless SEA Edmonds) Rooftop Facility
Verizon Wireless Contact: Aileen 2avales, Lynx Consulting, 206 972 1368; email:
Azava les @lynxconsulti ng,s �g
This document serves as Verizon Wireless's eligible facilities request to modify an existing wireless
base station at the above -referenced site address. This eligible facilities request must be approved
administratively under Section 6409 of the Federal Spectrum Act and Federal Communications
Commission ("FCC") rules. Review by the City of Edmonds is limited to determining whether the
proposed modification qualifies as an eligible facility request that does not substantially change the
physical dimensions of the wireless base station. All permits necessary to commence construction
must be approved within 60 days of the request date set forth above, subject to tolling for
incompleteness.
For this request, Verizon Wireless attached the following applications for all the permits required by
the City of Edmonds to commence construction of this application:
1. Site Plan Review
2. Construction Plan set for building permit
3. Building permit application
4. Noise Letter
S. Photosims
6. Structural Analysis to support the construction plans
7. Redacted lease to prove Verizon Wireless's ability to modify its facility
8. NIER Report
PROJECT DESCRIPTION:
The existing wireless facility owned by Verizon Wireless was originally permitted thru a permit from
the City of Edmonds. As currently installed, the facility consists of 12 panel antennas on three sector
frames which are shared with other carriers, with leased equipment in a separate room in the garage's
equipment room in the building.
Lynx Consulting, Inc. •17311 135tl, Ave NE, Suite A-100, Woodinville, WA 98072. (
ScLYNX
Authorized Verizon Wireless Representative
To accommodate new wireless technologies, Verlaon Wireless proposes to remove 9 panel antennas, 9
RRUs,12 in -cabinets radios at equipment and remove electrical per plan; and add 6 panel antennas, 3
LSG antennas, 9 RRUs per plan, add electrical per plan and add 12 dummy blocks to existing eHB
cabinet in equipment room.
FCC Rules for Eligible Facilities Request
The Spectrum Act states that "a state or local government may not deny, and small 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." An "EFR" is defined to
include any collocation, removal, or replacement of existing equipment.
The FCC adopted rules providing legally binding guidance on key terms of the Spectrum Act, notably
defining "substantial change" with the six thresholds described below. The FCC requires that
qualifying eligible facilities requests be approved within 60 days, subject to tolling for incompleteness.
The 60-day period begins when an applicant takes the first procedural step required by a local
government and submits written documentation. The only submittal documents a local government
can require are those relevant to determining if a proposed modification qualifies as an eligible
facilities request. if a local government does not render a decision within the 60-day period, an EFR
can be deemed granted by operation of law.
The Proposed Modification does not Constitute a "Substantial Change:
Below are the FCC's six "substantial change" thresholds for a wireless base station, each followed by an
explanation that the proposed modification does not exceed that threshold.
1] It increases the height of the structure by more than 10% or more than ten feet whichever is
greater:
There are no proposed height increases in this proposal. The antenna mounts are not being
increased in height.
2) 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:
There are no new protrusions with this proposal. The antennas and equipment will be
mounted to/installed to existing equipment and antenna arrays.
3] For any eligible support structure, it involves the installation of more than the standard
number of new equipment cabinets For the technology involved, but not to exceed four.
Lynx Consulting, Inc. •17311 1351h Ave HE, Suite A-100, Woodinville, WA 98072 • [
V LYNX
Authorized Verizon Wireless Representative
Or, for base stations, it involves installation of any new equipment cabinets on the ground, if
there are no pre -existing ground cabinets associated with the structure, or else involves
installation of ground cabinets that are more than 10% larger in height or overall volume than
any other ground cabinets associated with the structure:
There are no new cabinets associated with this proposal.
4) Entails any excavation or deployment outside the current site {as defined at 47 C.F.R.
1.6100 (b) (6)):
There is no new excavation with this proposal.
5) Would defeat any concealment elements of the existing facility:
The existing facility is a rooftop installation that is not screened. There are no changes.
6. Does not comply with conditions associated with the prior approval of the existing facility,
unless the non-compliance is due only to a change in height, width, etc., that does not exceed
the first four thresholds:
There are no prior conditions of approval that would render the modification to be non-
compliant, aside from any conditions that would be preempted by the first four "Substantial
change" threshholds.
In sum, the modification clearly qualifies as an "eligible facilities request" under the Spectrum Act and
FCC rules, because it does not exceed any of the thresholds such that is would "substantially change"
the physical dimensions of the existing base station. Failure to process this EFR and approve all
necessary permits within 60 days may result in the request being deemed granted by operation of law.
Thank you for your consideration of this building permit application and proposal for Verizon
Wireless. If you have any questions or need additional information, please let me know at 206 972
1368 or email Azav 1 nxc n ltin r
Sin1re y,
Aileen Zaval
Lynx Consulting, Inc.
Authorized Agent of Verizon Wireless
Lynx Consulting, Inc. ■17311 135th Ave NE, Suite A-100, Woodinville, WA 98072 • t