` <br />Assisting more than 800 communities in 34 states for more than 2 Decades <br />Specializing in Regulating Towers & Wireless Facilities <br />The largest & most experienced organization of its kind in the nation <br />3113BC.WF,NC27587 <br />ILLIARD TAKE ORESTORTHAROLINA <br />E-Mail: Lmonroe8@nc.rr.com <br />Office (91)9 266-5990 Mobile (518) 573-8842 <br />Web Site: www.telecomsol.com <br />Report Submitted April 16, 2015 <br />COMMENTS RELATED TO THE FOLLOWING APPLICATION <br />File #: CU 14-3 New Cingular Wireless –Crossfire Ministries <br />Applicant <br />: Lexcom Development on behalf of New Cingular Wireless PCS (AT&T) <br />Requested <br />: A new 75’ tall tower (monopine) located at 4060 West Amazon Drive, Eugene, Oregon <br />Stated Purpose <br />: To fill a gap in 4G LTE service and ‘improve’ all AT&T service in the area. <br />Introductory Remarks <br />Monroe Telecom Associates, LLC (dba CMS or The Center for Municipal Solutions) was retained by the <br />City of Eugene (City) as its consultant to comment on the adequacy and usefulness of information <br />submitted in support of permitting a new tower. This report is comprised of comments and explanations <br />relatedto the adequacy, completeness, accuracy and ability to verify the material submitted by the <br />applicant in support of its proposal to construct a 75’ tall monopine at 4060 West Amazon Dr. in Eugene. <br />The codified authority for such is found in Section 9.5750(11), to wit: <br />Application Review andFees.The city manager shall retain one or more <br />consultants to verify the accuracy of statements made in connection with an <br />applicationfor a building or land use permit for a telecommunications facility.. . <br />(emphasis added) <br />Before getting into the specific issues, it is noteworthy that in several respects the City’s regulations refer <br />to subjective determinations that are to be made with respect to applications. In that context, terms such <br />as “Suitability” and “impact” as used in the City’s regulations are subjective terms, to best be interpreted <br />by City officials. CMS would not presume to supplant the City’s [sole] right to interpret its regulations, <br />much less make subjective determinations. Rather, CMS’s job is essentially to enable the City to make <br />informed decisions, including knowing the options available to which the City has a right to avail itself <br />and/or require of an applicant and to place matters in context. Thus, this report does not address matters <br />of opinion that are of a subjective nature. <br />1 <br />