The application should be denied because it is not needed to provide service in <br />the area. As stated in the Center for Municipal Solutions report, the applicant <br />must provide substantial evidence demonstrating an actual gap in service to <br />justify the need for a new cell tower. Evidence of adequate service coverage is <br />provided below under discussion of EC 9.5750(6)(c)3. <br /> <br />9.5750 (6)(c) Site Review and Conditional Use Permit Applications. In <br />addition to the application requirements specified in paragraph (b) above, <br />applications for site review or conditional use permits also shall include the <br />following information: <br /> <br />2. Documentation that alternative sites within a radius of at least 2000 <br />feet have been considered and have been determined to be <br />technologically unfeasible or unavailable. For site reviews, alternative <br />sites zoned E-1, E-2, I-2, and I-3 must be considered. For conditional use <br />permits, alternative sites zoned PL, C-2, C-3, E-1, E-2, I-2, I-3 and S-WS <br />must be considered. <br /> <br />While the applicant made an effort only to meet the minimum analysis range of <br />2000 feet required by 9.5750(6)(c)(2), they have failed to fully comply with Eugene <br />Code by not examining alternative sites with the suitable zoning indicated which <br />must be considered. Because this is an exclusively residential neighborhood, the <br />applicant must do a much better alternative location analysis over a larger <br />distance. They must identified alternative sites away from residential areas that <br />could provide a high level of service to this area. <br /> <br />While it is not the job of opponents to identify suitable alternative sites for a cell <br />tower, it may be helpful to the Hearings Official to know that such sites do exist. <br />One possibility would be to locate the cell tower in the area used by the <br />Bonneville Power Administration (BPA) powerline easement that runs through the <br />south hills between Dillard Road and Fox Hollow Road. This easement is already <br />heavily impacted by tall transmission towers and high-voltage powerlines. <br />Another powerline easement in the area is owned by EWEB. Both easements are <br />elevated, allowing for good signal dispersion and potential for collocation by <br />other service providers. <br /> <br />9.5750 (6)(c)3. Evidence demonstrating collocation is impractical on <br />existing tall buildings, light or utility poles, water towers, existing <br />transmission towers, and existing tower facility sites for reasons of <br />structural support capabilities, safety, available space, or failing to meet <br /> <br />Fodor & Associates - Page 2 <br />