June 16, 2015 <br />Page 3 <br />collocated on an existing structure. "(Emphasis added). <br />AT&T has demonstrated that the height of the proposed facility at the Crossfire Church <br />cannot be obtained on an existing utility pole, even with a permitted pole extension. <br />AT&T is providing in the attached Exhibit A the technical data requested for the <br />proposed site, which provides sufficient information for CMS to verify that this facility, <br />as proposed, cannot be placed on an existing utility pole or structure. It should be <br />noted that the CMS comments on this code provision in its second report focus only on <br />potential use of multiple structures at lower heights and structurally modifying facilities <br />outside the 2000 foot radius. This is clearly not required by the Eugene code, as <br />interpreted by LUBA in the Johnson case. <br />Sincerely, <br />Kim Allen <br />Attorneys for Applicant AT&T <br />