DNS BLD2022-0824+NOTICE- EFR +6.23.2022_1.46.04_PM+2951028CROWN 1505 Westlake Ave N, N
CC Seattle, WA 98109
CASTLE
VIA ONLINE SUBMITTAL RECEIVED
EDMONDS, WA
June 23, 2022
CITY OF EDMONDS, WA
Building Division
121 5TH AVE N
EDMONDS, WA 98020
Jun 24 2022
CITY OF EDMONDS
DEVELOPMENT SERVICES
DEPARTMENT
Phone:
www.crowncastle.com
BLD2022-0824
Reviewed by '
City of Edmonds
Planning Division
--------------
**********NOTICE OF ELIGIBLE FACILITIES REQUEST**********
RE: Request for Minor Modification to Existing Wireless Facility — Section 6409
Site Address: 8505 Bowdoin Way, Edmonds, WA 98026
BUILDING PERMIT APPLICATION
Crown Site Number: 824070 / Crown Site Name: Five Corners -Fire Station
Customer Site Number: 263807 / Application Number: 578o95
Dear Reviewing Parties:
On behalf of Seattle SMSA Limited Partnership ("Verizon Wireless" 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 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 30-day and 6o-day deadlines begins when an applicant:
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 1505 Westlake Ave N, N
Seattle, WA 98109 Phone:
www.crowncastle.com
■10 CASTLE
(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 law4. 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 July 23, 2022, and the deadline
for issuance of approval is August 22, 2022.The proposed scope of work for this project includes:
Add 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 request:
(1) EFR Applicant Cover Letter (see this document) with Attachment "A" Section 6409 Substantial
Change Checklist, and Attachment "B", Proposed Scope of Work;
(2) Building Permit Application (through portal);
(3) Construction Drawings, by Trylon, dated 4/21/22;
(4) Structural Analysis Report, by Tower Engineering Solutions, dated 9/15/21;
(5) New/Replacement Antenna Mount Analysis Report, by Tower Engineering Solutions, dated
12/16/21;
(6) FCC Compliance Letter, dated 6/9/22
(7) RF Safety and NIER Analysis Report, by Pramira, dated 6/9/22;
(8) 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,
Emilie Deachamp,3
Emilie Deschamps
Agent for Crown Castle
Emilie@GMAnetworkservices.com
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 Riehts of Way
YES/NO
Does the modification increase the height of the tower by more than the greater
NO
of:
(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
NO
protrude from the 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
NO
of new equipment 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
NO
site by more than 30 feet in any direction, not including any access or utility
easements?
YES/NO
Does the modification defeat the concealment elements of the eligible support
NO
structure?
YES/NO
Does the modification violate conditions associated with the siting approval with the
NO
prior approval the tower or base station other than as specified in 47 C.F.R. §
1. 6 1 00(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
Attachment "B"
Proposed Scope or Work for Verizon
8505 Bowdoin Way
Edmonds, WA 98026
PROJECT DESCRIPTION
THE PURPOSE OF THIS PROJECT IS TO ENHANCE
BROADBAND CONNECTIVITY AND CAPACITY TO THE
EXISTING ELIGIBLE WIRELESS FACILPrY_
TOWER SCOPE OF WORK:
• INSTALL (3) ANTENNAS
NOTE:
PRIOR TO ACCESSING/ENTERING THE SITE YOU MUST
CONTACT THE CROWD NOC AT (800) 788-7011 & CROWD{
CONSTRUCTION MANAGER
CC
CROWN
CASTLE
January 20, 2022
Re: Crown Castle — PNW
Subject: Emilie Deschamps — Authorized Consultant for Crown Castle
Dear Reviewing Parties:
Crown Castle
1505 Westlake Avenue North
Suite 800
Seattle, WA 98109
This letter serves to notify you that Crown Castle has retained the services of Emilie Deschamps, as
approved agent to submit application for and obtain local jurisdiction approvals including but not
limited to zoning and building permits. This includes applicable permitting for any and all customers
seeking to install or modify their equipment on Crown Castle towers.
Please feel free to contact me directly with any questions. Thank you for your expeditious processing of
applications filed by Ms. Deschamps.
Sincerely,
Chris Listfjeld
Site Acquisition Project Manager — Seattle
Chris.Listfj eldkcrowncastle.com
(206) 336-7403
The pathway to possible.
CrcwnCastle.com