strengths used when producing them. Thus, the implied ‘weak’ signal that needs to be improved, <br />has not been clearly and convincingly demonstrated technically; only asserted. <br />As submitted, the conclusions represented by the propagation maps are not able to be verified, <br />meaning that, unless the City wishes to simply accept the applicant’s assertions and maps at face <br />value, they are useless from a regulatory perspective. Since it is the technical need for what is <br />requested that determines the location, type and height of the facility, it is difficult to determine <br />definitively the type(s) and height of support structure(s) and the location(s) that would not work to <br />enable the situation to be mitigated or improved and therefore what would work technically to <br />resolve the situation. <br />The propagation maps can be resubmitted and used if done correctly. <br />(6)Application Requirements. <br />(a)Collocation of Antennas. In addition to standard required application material, an <br />applicant for collocation of antennas shall submit the following information; additional <br />application material is required, as specified in paragraph (c) below, for applications <br />requiring a site review or conditional use process. <br />2.Documentation demonstrating compliance with non-ionizing electromagnetic <br />radiation (NIER) emissions standards as set forth by the Federal <br />Communications Commission (FCC) particularly with respect to any habitable <br />areas within the structure on which the antennas are co-locating on or in <br />structures directly across from or adjacent to the antennas. <br />Comment <br />: The report written by Hatfield & Dawson dated January 2014 (Report) would <br />appear to be accurate and the formulas and the approach used are consistent with <br />accepted practice. The numbers arrived at as regards the percentages of the FCC’s <br />thresholds established in OET Bulletin 65 are also not inconsistent with what onewould <br />expect in a similar situation. However, it is not known that any of the assumptions such <br />as the Effective Radiated Power (ERP), Antenna Gain and Suppression Angles stated <br />in the report will reflect the real world operating situation after construction and <br />activation. In that context it is important to note that Footnote 1 on page 2 of the Report <br />expressly states that “. . . the data for the antennas specified by AT&T was unavailable <br />. . .” and an assumption, albeit a conservative one, was used. There is nothing in the <br />report that would indicate that it is not accurate or truthful and thus would appear to be <br />reliable and we would recommend accepting it in compliance with the intent of this <br />subsection. <br />However, since RF emissions is normally one of the two issues the public is most <br />concerned about(the other being visual intrusiveness), and since the report is <br />predictiveas regards its conclusions, to determine actual real-world operating <br />compliance with the FCC’s regulations set forth in OET 65, the City may wish to order <br />an on-site post-construction RF survey to be conducted (under qualified supervision by <br />the City). Such a requirement could be attached as a condition to the CUP. <br />(b)Construction of Transmission Tower. In addition to standard required application <br />material, an applicant for a transmission tower shall submit the following information; <br />additional application material is required, as specified in paragraph (c) below, for <br />applications requiring a site review or conditional use process: <br />2.Documentation that alternative sites within a radius of at least 2000 feet have <br />been considered and have been determined to be technologically unfeasible or <br />unavailable. For site reviews, alternative sites zoned E-1, E-2, I-2, and I-3 must <br />be considered. For conditional use permitsalternative sites zoned PL, C-2, C-3, <br />, <br />4 <br />