BLD2023-1434+Letter+11.9.2023_11.07.04_AM+3891432RECEIVED BLD2023-1434
November 9, 2023 Nov 09 2023
CITY OF EDMONDS
DEVELOPMENT SERVICES
DEPARTMENT
City of Edmonds
Planning and Development
121 5t' Avenue N.
Edmonds, WA 98020
Re: Application for Land Use for proposed Dish Networks Rooftop Wireless Communications facility on
a building located at 10032 Edmonds Way/SESEA00180C.
Dear Reviewing Parties,
Dish Networks is working to establish wireless coverage and capacity in the vicinity of a residential
building in Edmonds located at 10032 Edmonds Way and the surrounding community with a proposed,
rooftop wireless communications facility located on a 44'2" building. The subject site is zoned Westgate
Mixed Use (WMU), and this review is to be Administrative.
The proposed site would consist of the installation of nine fully screened panel antennas, eighteen RRH
radio units and three surge protector devices. The nine antennas are to be installed in three fully screened
sectors (three antennas per sector). Two of these sectors are to be installed on the north end of the roof
and the third sector on the southern end. The associated equipment cabinets are to be installed and
screened on a 7' x 5' platform located on the west side of the roof.
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As part of the Administrative Review for the proposed Wireless Communications Facility (WCF), a
Narrative Statement addressing relevant questions and criteria is to be completed. Below are the
questions and the associated responses.
Narrative Statement
20.50.010 Purpose
The purpose of this chapter is to regulate the placement, construction, modification and appearance of
wireless communication facilities, in order to protect the health, safety and welfare of the public, while
not unreasonably interfering with the deployment of competitive wireless communication facilities
throughout the city. The purpose of this chapter may be achieved through adherence to the following
objectives:
1. Protect residential areas and land uses from potential adverse impacts that wireless
communication facilities might create, including but not limited to negative impacts on
aesthetics, environmentally sensitive areas, historically significant locations, flight corridors,
and health and safety of persons and property;
Response
The proposed facility is to go on an apartment building with first floor commercial in the
Westgate Mixed Use zone. It will be fully screened and will blend in with the design of the
building so the facility will not be visible. Therefore, this proposal will not have any impact
on aesthetics, environmentally sensitive areas, historically significant locations, flight
corridors, and health and safety of persons and property.
2. Establishment of clear and nondiscriminatory local regulations concerning wireless
communication facilities and services that are consistent with federal and state laws and
regulations.
Response
This facility will obtain all necessary federal, state and local permits needed and will be
consistent with all of these regulations.
3. Encourage providers of wireless communication facilities to locate facilities, to the extent
feasible, in areas where the adverse impact on the public health, safety and welfare is
minimal.
Response
The intent of this proposal is to provide coverage to commercial and residential uses in and
around the Westgate Village area. The proposed building is the only structure tall enough
with availability to install such a facility. It will be fully screened and adhere to all FCC and
local regulations regarding health, safety and noise standards. Therefore, it will be designed
to minimize adverse impact on the public health, safety and welfare.
4. For macro facilities, encourage the location of those facilities in nonresidential areas and
allow macro facilities in residential areas only when necessary to meet functional
requirements of the communications industry as defined by the Federal Communications
Commission.
Response
The proposed facility is to be located in the Westgate Mixed Use (WMU) zone.
5. Minimize the total number of macro facilities in residential areas.
Response
As previously mentioned, this proposal is to be located in a mixed -use zone and it to be
located on the only structure tall enough with the capacity to accommodate such a facility.
Encourage and, where legally permissible, require cooperation between competitors and, as a
primary option, joint use of new and existing towers, tower sites and suitable structures to the
greatest extent possible, where doing so would significantly reduce or eliminate additional
negative impact on the city.
Response
There are three small towers adjacent to the proposed location but due to their size and
capacity, they were not feasible for colocation. Therefore, we chose the proposed building
which provides the height needed for a fully stealth facility, thus eliminating additional
negative impact on the city. The issues associated with these towers are as follows:
• Crown Castle BU# 814645 (Located at 47.7908,-122.362) - Crown has received
a notice of termination at this site, so this site will be taken down in the near
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future and we were advised it would not make sense to start an application for
this tower.
Crown Castle BU# 855640 (Located at 47.7897,-122.366) - This was the B
candidate on this ring. There is no additional ground space available at this site
for Dish's ground equipment due to the jurisdictionally required parking spots
located next to the site.
Crown Castle BU# 826146 (Located at 47.7831,-122.367) - This site is half a
mile away from our proposed site and would not meet our coverage objective of
covering Hwy 104 (Edmonds Way).
7. Ensure wireless communication facilities are configured in a way that minimizes the adverse
visual impact of the facilities, as viewed from different vantage points, through careful
design, landscape screening, minimal impact siting options and camouflaging techniques,
dispersion of unscreened features to lessen the visual impact upon any one location, and
through assessment of innovative siting techniques.
Response
As previously mentioned, the proposed facility will be fully screened so the antennas and
proposed equipment cabinets will not be visible. Enclosed with this submittal are photo
simulations of this proposed facility showing how it would be viewed from different vantage
points. Since all the equipment is to be placed on the roof, no landscaping is proposed but it
will be fully camouflage.
8. Enable wireless communication companies to enter into lease agreements with the city to use
city property for the placement of wireless facilities where consistent with other public needs,
as a means to generate revenue for the city.
Response
This proposal is not to be installed on City property.
9. Balance the city's intent to minimize the adverse impacts of wireless communication
facilities with the ability of the providers of communications services to deploy such services
to the community quickly, effectively and efficiently.
Response
Since this facility is fully screened and will adhere to all health, safety and noise regulations,
it will minimize adverse impacts of such facilities and should be able to deploy such services
quickly, effectively and efficiently.
10. Provide for the prompt removal of wireless communication facilities that are abandoned or no
longer inspected for safety concerns and building code compliance and provide a mechanism
for the city to cause these abandoned wireless communication facilities to be removed as
necessary to protect the citizens from imminent harm and danger.
Response
This is understood. This provision is a requirement of the agreement between Dish Wireless
and the landlord.
11. Avoid potential damage to people and adjacent properties from tower failure and falling
equipment, through strict compliance with state building and electrical codes.
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Response
Since this is a rooftop site this is not applicable.
12. Disperse the adverse impacts of small wireless facility facilities as evenly as possible
throughout the community, especially when joint use does not eliminate additional visual
impact.
Response
Since this facility is a "macro" site, this is not applicable.
20.50.50 General Macro Siting Facility Criteria and Design Considerations
A. The city of Edmonds encourages wireless communication providers to use existing sites or more
frequent, less noticeable sites instead of attempting to provide coverage through use of taller
towers. To that end, applicants shall consider the following priority of preferred locations for
wireless communication facilities:
1. Collocation, without an increase in the height of the building, pole or structure upon which
the facility would be located.
2. Collocation, where additional height is necessary above existing building, pole, or structure.
3. A replacement pole or structure for an existing one.
4. A new pole or structure altogether.
Response
As discussed above, this proposal involves installing a fully stealth facility on the roof of the
subject building. We did explore collocating on existing poles since there are three poles in the
general vicinity of this building. These poles were not feasible for the following reasons:
Crown Castle BU# 814645 (Located at 47.7908,-122.362) - Crown has received a
notice of termination at this site, so this site will be taken down in the near future and we
were advised it would not make sense to start an application for this tower.
Crown Castle BU# 855640 (Located at 47.7897,-122.366) - This was the B candidate
on this ring. There is no additional ground space available at this site for Dish's ground
equipment due to the jurisdictionally required parking spots located next to the site.
Crown Castle BU# 826146 (Located at 47.7831,-122.367) - This site is half a mile
away from our proposed site and would not meet our coverage objective of covering Hwy
104 (Edmonds Way).
B. New monopole facilities must include mounts capable of accommodating at least one other
wireless provider.
Response
Since this proposal is a rooftops site, this is not applicable.
C. Noise. Any facility that requires a generator or other device which will create noise audible
beyond the boundaries of the site must demonstrate compliance with Chapter 5.30 ECC, Noise
Abatement and Control. A noise report, prepared by an acoustical engineer, shall be submitted
with any application to construct and operate a wireless communication facility that will have a
generator or similar device. The city may require that the report be reviewed by a third -party
expert at the expense of the applicant.
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Response
A generator is not proposed for this site. However, a noise analysis is included with this
submittal showing how this facility adheres to all state and jurisdictional noise standards.
D. Business License Requirement. Any person, corporation or entity that operates a wireless
communication facility within the city shall have a valid business license issued annually by the
city. Any person, corporation or other business entity which owns a monopole, is required to
obtain a business license on an annual basis.
Response
This requirement is understood.
E. Signage. Only safety signs or those mandated by a government entity with jurisdiction maybe
located on wireless communication facilities. No other types of signs are permitted on wireless
communication facilities.
Response
This requirement is understood. The only Signage proposed for this facility are notice signs
which will be posted adjacent to the facility on the roof as required by the FCC.
F. Any application must demonstrate that there is sufficient space for temporary parking for regular
maintenance of the proposed facility.
Response
There is adequate parking at this location provided by surface lots and the underground parking
garage.
G. Finish. A monopole may be constructed of laminated wood, fiberglass, steel, or similar material.
The pole shall be a neutral color so as to reduce its visual obtrusiveness, subject to any applicable
standards of the FAA or FCC.
Response
This is not applicable since this is to be a rooftop facility.
H. Design. The design of all buildings and ancillary structures shall use materials, colors, textures,
screening and landscaping that will blend the facilities with the natural setting and built
environment.
Response
As you can see from the attached photo simulations, the screening around the antennas match the
color and texture of the exterior of the upper floor of the building. Therefore, the proposed
facility is designed to complement the architectural design of the building.
I. Color. All antennas and ancillary facilities located on buildings or structures other than
monopoles shall be of a neutral color that is identical to or closely compatible with the color of
the supporting structure so as to make the antenna and ancillary facilities as visually unobtrusive
as possible.
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Response
As mentioned above, the screening of the proposed antennas matches the color and texture of the
exterior of the upper floor of the building. Therefore, the proposed facility is designed to
complement the architectural color and design of the building.
Lighting. Monopoles shall not be artificially lighted unless required by the FAA, FCC or other
government entity with jurisdiction. If lighting is required and alternative lighting options are
permitted, the city shall review the lighting alternatives and approve the design that would cause
the least disturbance to the surrounding area. No strobe lighting of any type is permitted on any
monopole. If FAA guidelines require a strobe, the location shall be denied unless no other site or
combination of sites would provide adequate coverage in accord with FCC requirements.
Response
Since this proposal involves a rooftop facility, it is not applicable. No lighting is proposed.
K. Advertising. No advertising is permitted at wireless communication facility sites or on any
ancillary structure or facilities equipment enclosure.
Response
No advertising is proposed for this facility.
L. Equipment Enclosure. Each applicant shall use the smallest equipment enclosure practical to
contain the required equipment and a reserve for required collocation.
Response
As you can see in the attached drawings, only two cabinets are proposed on 7' x 5' platform on
the west side of the roof. This is the minimal number of cabinets needed to operate a macro
wireless facility.
M. Radio Frequency Emissions Compliance. The applicant shall demonstrate that the project will not
result in levels of radio frequency emissions that exceed FCC standards, including FCC Office of
Engineering Technology (OET) Bulletin 65, Evaluating Compliance with FCC Guidelines for
Human Exposure to Radio Frequency Electromagnetic Fields, as amended. Additionally, if the
director determines the wireless communication facility, as constructed, may emit radio
frequency emissions that are likely to exceed Federal Communications Commission
uncontrolled/general population standards in FCC Office of Engineering Technology (OET)
Bulletin 65, Evaluating Compliance with FCC Guidelines for Human Exposure to Radio
Frequency Electromagnetic Fields, as amended, in areas accessible by the general population, the
director may require post -installation testing to determine whether to require further mitigation of
radio frequency emissions. The cost of any such testing and mitigation shall be borne by the
applicant.
Response
Included with this submittal is an EME study which shows how the radio frequency emissions of
this facility adheres and does not exceed FCC standards.
N. Landscaping and Screening
1. The visual impacts of wireless communication facilities should be mitigated and softened
through landscaping or other screening materials at the base of a monopole, facility
equipment compound, equipment enclosures and ancillary structures. If the antenna is
mounted flush on an existing building, or camouflaged as part of the building and other
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equipment is housed inside an existing structure, no landscaping is required. The director or
his designee may reduce or waive the standards for those sides of the wireless communication
facility that are not in public view, when a combination of existing vegetation, topography,
walls, decorative fences or other features achieves the same degree of screening as the
required landscaping; in locations where the visual impact of the facility would be minimal;
and in those locations where large wooded lots not capable of subdivision and natural growth
around the property perimeter provide a sufficient buffer.
Response
As mentioned above, the antennas on this proposed rooftop facility are screened to match the
color and texture of the exterior of the upper floor of the building. Therefore, the proposed
facility is designed to complement the architectural design of the building. Since this
screened equipment is to be installed on the roof of the building and there is to be no ground
equipment, no landscaping is proposed.
2. Landscaping shall be installed on the outside of fences in accordance with
Chapter 20.13 ECDC. Existing vegetation shall be preserved to the maximum extent
practicable and may be used as a substitute for or as a supplement to landscaping or screening
requirements. The following requirements apply:
a. Type I landscaping shall be placed around the perimeter of the equipment cabinet
enclosure, except that a maximum 10-foot portion of the fence may remain without
landscaping in order to provide access to the enclosure.
b. Landscaping area shall be a minimum of five feet in width around the perimeter of the
enclosure.
c. Vegetation selected should be native and drought tolerant.
d. Landscaping shall be located so as not to create sight distance hazards or conflicts with
other surrounding utilities.
Response
Since no landscaping is proposed for this rooftop facility, this is not applicable.
3. When landscaping is used, the applicant shall submit a landscaping bond pursuant to
ECDC 20.13.040.
Response
Since no landscaping is proposed for this rooftop facility, this is not applicable.
4. The use of chain link, plastic, vinyl or wire fencing is prohibited. Ornamental metal or wood
fencing materials are preferred. [Ord. 4147 § 2 (Att. A), 2019; Ord. 3961 § 1, 2014; Ord.
3845 § 2 (Att. A), 2011].
Response
Since fencing is not proposed for this facility, this is not applicable.
20.50.090 New Building -Mounted Macro Wireless Communications Facility Standards
A. General. Wireless communication facilities located on the roof or on the side of the building shall
be grouped together, integrated to the maximum possible degree with the building design, placed
toward the center of the roof and/or thoroughly screened from residential building views and from
public views using radio frequency -transparent panels. Building -mounted wireless
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communication facilities shall be painted with nonreflective colors to match the existing surface
where the antennas are mounted.
Response
Due to the size of the roof of the building and the 9-foot height limit for antennas, it is not
possible to place the antennas in the middle of the roof and be able to transmit signal over the
edges of the building. The proposed Alpha and Beta sectors are grouped together in order to
transmit to the north and east. But due to the north/south length of the roof, the only way to
transmit to the south is install the Gamma sector at the southern end of the roof. If the antennas
could be installed higher than 9 feet above the roof, they could be located closer towards the
center of the roof. But this is not possible due to the height limit of the antennas.
B. Height. The following requirements shall apply:
Downtown Waterfront/Activity Center (as Identified in the Edmonds Comprehensive Plan).
For buildings at, or which exceed, the height limit of the underlying zone, antennas shall be
flush -mounted and no portion of the antenna may extend above the building on which it is
mounted. For buildings below the height limit, antennas may be built to the maximum height
of the zone provided they are screened consistent with the existing building in terms of color,
architectural style and material. Flush -mounted antennas may encroach into a required
setback or into the city right-of-way if a right-of-way use agreement is established with the
city. Antennas shall not project into the right-of-way by more than two feet and shall provide
a minimum clearance height of 20 feet over any pedestrian or vehicular right-of-way.
Response
Since this building is not located in the Downtown Waterfront/Activity Center, this is not
applicable.
2. Outside the Downtown/Waterfront Activity Center. The maximum height of building -
mounted facilities and equipment shall not exceed nine feet above the top of the roof on
which the facility is located. This standard applies to all buildings regardless of whether they
are at or above the maximum height of the underlying zone. Such antennas must be well
integrated with the existing structure or designed to look like common rooftop structures such
as chimneys, vents and stovepipes.
Response
As shown on pages A-4.0, A-4.1 & A-4.2 of the enclosed drawings, the tip of the antennas
for this proposed facility are 9' above the roof parapet. Therefore, this facility adheres to this
standard.
C. Equipment Enclosure -Equipment enclosures; for building -mounted wireless communication;
facilities shall first be located within the building on which the facility is located If aneguipmenti
enclosure within the building is reasonably unavailable, then an equipment enclosure may be
eight incorporated into the xoof design provided the enclosure meets the hrequirement for the
p - --
zone. If the equi ment' can be screened by placing the lequipment below existing parapet walls, no
additional screening is required. If screening is required, then the screening must, be consistent
with the existing building in terms of color, architectural style and material. Finally, if there is no
other choice but to locate the equipment enclosure on the ground, the equipment must be
enclosed within an accessory ,structure which meets the setbacks of the underlying zone and be
screened in accordance with ECDC 20.50.050
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Response
For this proposal, there is no adequate space within the building to accommodate the proposed
equipment cabinets, so they are to be installed on a platform on the west side of the roof. The
total height of the platform and cabinets are about 7' in height which is below the 9' height limit
for the antennas in this zone. These cabinets are to be located on the western edge of the roof but
centrally located in regards to the north and south directions. Since there are mature trees to the
west of the building, the roof is only visible from the north, east and south. As you can see from
the enclosed photo simulations, these cabinets are not visible from any direction due to their
location and size of the roof, so screening is not needed for this equipment.
D. Feed Lines and Coaxial Cables. Feed lines and cables should be located below the parapet of the
rooftop, if present. If the feed lines and cables are visible from a public right-of-way or adjacent
property, they musi be painted to match the color scheme of the building.
Response
The proposed cabling will be run on the roof and internally to connect the equipment to the
electrical and fiber sources within the building. Therefore, no cables will be visible from the
public right-of-way or the adjacent properties.
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