REVIEWED BLD2022-1650+Letter+12.5.2022_2.00.29_PM+3252503CCCROWN
CASTLE
VIA ONLINE SUBMITTAL
CITY OF EDMONDS, WA
1505 Westlake Ave N Suite 800
Seattle, WA 98109 Phone: (206)336-7382
www.crowncastle.com
December 5, 2022 Reviewed by
City of Edmonds ;
CITY OF EDMONDS, WA Planning Division '
Development Services
1215thAve N, _______________
Edmonds, WA 98020
**********NOTICE OF ELIGIBLE FACILITIES REQUEST**********
RE: Request for Minor Modification to Existing Wireless Facility — Section 6409
Site Address: 9920 EDMONDS WAY, EDMONDS, WA 98020
COMMERCIAL BUILDING PERMIT APPLICATION
Crown Site Number: 855640 / Crown Site Name: BALLINGER
Customer Site Number: 263818/ Application Number: 578053
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 6409, 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 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 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 January 4, 2023, and the deadline for
issuance of approval is February 3, 2023.
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 Suite 800
Seattle, WA 98109 Phone: (206)336-7382
www.crowncastle.com
v CASTLE
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) Eligible Facilities Request cover letter and narrative (see this document) with Attachment "A," Section 6409
Substantial Change Checklist, and Attachment "B," Proposed Scope of work;
(2) Crown Castle Agent Authorization to submit for permits;
(3) City of Edmonds Building Permit application (through portal);
(4) Structural Analysis by Paul J. Ford, dated 6/27/22;
(5) Non -Ionizing Electromagnetic Exposure Analysis & Engineering Certification Report, by Pramira, dated
4/14/22;and
(6) Construction Drawings by Trylon, dated 7/28/2022;
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,
£indie Deocfi anpo
Emilie Deschamps
GMA Network Services, LLC
Agent for Crown Castle
emilie@gmanetworkservices.com
The Foundation for a Wireless World
CrownCastle.com
CROWN 1505 Westlake Ave N Suite 800
Seattle, WA 98109 Phone: (206)336-7382
www.crowncastle.com
Cllmoo CASTLE
Attachment "A"
Section 6409 Substantial Change Checklist
Towers Outside of the Public Right of Way
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
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 of
NO
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 site
NO
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. §
1.6100(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. § 1.61oo.
The Foundation for a Wireless World
CrownCastle.com
CROWN 1505 Westlake Ave N Suite 800
Phone:(206)336-7382
CC Seattle, WA 98109 www.crowncastle.com
CASTLE
Attachment "B"
Proposed Scope of Work
992o EDMONDS WAY, EDMONDS, WA 98020
I PROJECT DESCRIPTION I
THE PURPOSE OF THIS PROJECT IS TO ENHANCE
BROADBAND CONNECTINTITY AND CAPACITY TO THE
EXISTING ELIGIBLE WIRELESS FACILITY.
TOWER SCOPE OF WORK
• REMOVE (6) ANTE�,'NAS
• INSTALL (6) ANTENNAS
• INSTALL (6) TRIPI E3MRS
• INSTALL (3) BIAS-TS
• INSTALL (3) ONPs
• INSTALL (3) HYBRID CABLES
• INSTALL (1) TOWER Eh'TENSION (BY OTHERS)
GROUND SCOPE OF FORK
• REMOVE (6) RRHs
• RE -MOVE (12) DIPLF—XERS
• INSTALL (6) RRHs
• INSTALL (1) OVP
• INSTALL (6) TRIPI FXTM
• INSTALL (2) BBUs
• INSTALL (3) UPCONVERTERS
• INSTALL (1) RECTIFIER
NOTE:
PRIOR TO ACCESSING/ENTERING THE SITE YOU MUST
CONTACT THE CROWN NOC AT (SM) 7BB-7011 & CROWN
CONSTRUCTION MANAGER
The Foundation for a Wireless World
CrownCastle.com