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 C-4, I-1, I-2, and I-3 must <br />be considered. For conditional use permits, alternative sites zoned PL, C-2, C-3, <br />17 <br />C-4, I-1, I-3 and S-WS <br />The applicant has not sufficiently shown that alternative sites have been considered, and <br />this has been confirmed by the expert report from Center for Municipal Solutions (CMS). <br />Friends hereby incorporates by reference the report prepared by CMS. <br />The applicant assumes that the gap in 4G LTE service must be allowed to be filled from a <br />single facility. The applicant opens the door to the issue of gap by arguing that collocation on <br />existing facilities and so forth is not feasible due to coverage limitations. Because the applicant <br />has not demonstrated that it is technologically unfeasible to locate facilities at more than one site <br />using sm <br />documentation is not sufficient to satisfy its burden of proof. The record contains substantial <br />evidence to demonstrate that the applicant has strong coverage in the area at issue, see exhibit A, <br />18 <br /> Thus, it makes <br />little sense why the applicant is proposing to needlessly locate a new tower in the subject <br />neighborhood. <br />The applicant has also provided inaccurate information with regard to collocating on <br />EWEB facilities. The applicant alleged that collocation on EWEB facilities is not permitted. <br />However, that issue has been clarified, and EWEB does allow collocation on some of its <br />facilities, consistent with the statements by CMS. The applicant, therefore, provided inaccurate <br />information that has yet to be remedied. Because utilizing available EWEB facilities is <br />available, the applicant has violated this standard. <br /> <br /> <br /> <br /> <br /> <br />17 <br /> Friends contend that this requirement is a mandatory approval criteria because it is necessary <br />to determine compliance with standards located in 9.5750(7), (11) and applicable Metro plan <br />policies. See Bauer v. City of Portland, 44 Or LUBA 210 (2003); Hausam v. City of Salem, 39 <br />Or LUBA 51 (2000); Le Roux v. Malheur County, 32 or LUBA 124 (1996). <br />18 <br /> e 9.5750(11) requires that the <br />c <br />10 <br /> <br />