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• Planning
May 30, 2014
Todd Fiebig, Project Manager
New Cingular Wireless PCS, LLC
19801 SW 72nd Avenue
Tualatin, OR 97062
Subject: Completeness Review for New Cingular Wireless Crossfire Ministries (CU 14-3)
DearTodd:
I am writing in response to your Conditional Use Permit application for a new wireless
telecommunication facility on behalf of New Cingular Wireless, PCS, LLC (AT&T) and the property
owner. As referenced above, the City has assigned a file name and number (CU 14-3). We have
already received public testimony about the current name of the church being "Crossfire" rather than
"Calvary." While Cavalry Church still appears to be the current owner of the property, we have
revised the application name to clearly reference Crossfire Ministries. Please update your application
materials accordingly, throughout.
As indicated in the enclosed materials, there are several other additional pieces of information
needed before we schedule a public hearing and start the public notice and review process. The first
step of the application process is "Completeness Review" to determine whether we have enough
information to evaluate the approval criteria and standards. Enclosed is information about the
Completeness Review process, including a form for you to complete and return to me, about how you
would like to proceed (entitled "Incomplete Land Use Application - 180 Day Completeness Review
Process").
We have not completed a full evaluation of the application materials. Completeness Review is a
process by which we outline the minimum expectations of an applicant with regard to evidence and
written text that articulates that evidence to the approval criteria. At this point, the evidence and
narrative are insufficient. Even if you are able to produce the evidence and narrative as expected,
this does not guarantee a favorable outcome, as we have serious concerns about this project being
viable under the applicable approval criteria and standards.
Before proceeding with collecting additional information, I would like to discuss potential
alternatives. Let.me know if you have any questions.
City of Eugene • 99 W. 10th Ave. • Eugene, OR 97401 • S41-682-5481 • S41-682-SS72 Fax
www.eugene-or.gov/planning
Sincerely,
Becky Taylor, Associate Planner
becky.g.taylor@ci.eugene.or.us
541-682-5437
cc: Sharon Gretch, Ken Lyons
. ^-Ak-
• - Planning
Incomplete Land Use Application:
180 Day Completeness Review Process
Please Complete and Return to:
Eugene Planning Division
Attn: Becky Taylor, Associate Planner
File New Cingular Wireless - Crossfire Ministries (CU 143)
99 West 10" Avenue
Eugene, OR 97401
Completeness Review Step (Check ONE box)
❑ I intend to submit all of the missing or incomplete materials as identified by the City in completeness
review. I understand that according to State law I have up to 180 days from the date the application
was submitted to provide the missing or incomplete materials and that after that date, if I have not
submitted the missing information, my application will be void. I also hereby agree to allow the City a
reasonable period of time for a review and determination of completeness upon submittal of the
missing or incomplete materials and the required number of copies.
❑ I intend to submit some, but not all, of the missing or incomplete materials as identified by the City in
completeness review. I understand that according to State law I have up to 180 days from the date
the application was submitted to provide the missing or incomplete materials that I intend to submit
and that after that date, if I have not submitted the missing information, my application will be void. I
also hereby agree to allow the City a reasonable period of time for a review and determination of
completeness, upon submittal of the missing or incomplete materials and the required number of
copies. The materials I do not intend to submit are those items I have listed on the lines below (attach
additional sheets if necessary).
❑ I do not intend to submit any of the missing or incomplete materials as identified by the City in the
completeness review. I understand that the City will proceed with review of the application materials
previously submitted. I also understand that incomplete applications may not provide adequate
evidence to demonstrate compliance with applicable criteria and standards. Please deem my
application complete as of the date this form is received by the City of Eugene Planning Division.
Printed Name of Applicant or Applicant's Representative
Signature of Applicant or Applicant's Representative Date
City of Eugene • 99 W. 10th Ave. • Eugene, OR 97401 • 541-682-5481 • 541.-682-5572 Fax
www.eugene-or.gov/planning
Attachment A
Completeness Review of Conditional Use Permit Criteria:
Excerpt from City of Eugene Land Use Code, Chapter 9
The application materials for New Cingular Wireless Crossfire Ministries (CU 14-3) are lacking
sufficient information to evaluate and determine compliance with the applicable Conditional Use
Permit approval criteria at Eugene Code (EC) 9.8090. The code standard is provided in bold with
staff concerns identified under each.
EC 9.8090(1): The proposal is consistent with applicable provisions of the Metro Plan and
applicable refinement plans.
The written statement does not identify the Metro Plan land use diagram designation, which is
low-density residential. As such, the Metro Plan Residential Land Use policies should be reviewed
with an explanation to determine applicability. More information also appears necessary to show
compliance with Policy E:4 of the Metro Plan, in light of recent case law established in Northgreen
Properties v. City of Eugene. Staff advises the applicant to closely review that recent case history
for the type of findings and evidence that is necessary to demonstrate that the facility is "designed
and located in a manner that preserves and enhances desirable features of the local and
neighborhood areas and promotes their sense of identity."
EC 9.8090(2): The location, size, design, and operating characteristics of the proposal are
reasonably compatible with and have minimal impact on the livability or appropriate
development of surrounding property, as they relate to the following factors:
(a) The proposed building(s) mass and scale are physically suitable for the type and
density of use being proposed.
The written statement needs to better articulate compliance with this criterion with supporting
evidence. The conclusive statement without supporting evidence and findings are insufficient. The
statement says the monopine is designed to look like other evergreen trees in the immediate area,
but the photos show few evergreen trees in close proximity. The statement also concludes that
the ancillary equipment shed will look like an extension of the chapel. This needs to be illustrated
and better explained as to how it fits within the area in terms of mass and scale and impact on the
surroundings. The applicant should also consider the possibility that a variance may not be
granted to allow above ground ancillary facilities, and provide for alternative designs (e.g.
underground or fully enclosed with additional sound buffering) as a contingency or means to
better address the approval criteria.
(b) The proposed structures, parking lots, outdoor use areas or other site
improvements which could cause substantial off-site impacts such as noise, glare
and odors are oriented away from nearby residential uses and/or are adequately
mitigated through other design techniques, such as screening and increased
setbacks.
Completeness Review: New Cingular Wireless Crossfire Church (CU 14-3) Page 1 of 3
Attachment A
Screening is not addressed at all in the written statement or adequately shown on the plans. The
expectation on screening has been clarified in other cases which the applicant should review for a
better understanding of what is required.
Noise -The evidence about noise levels casts doubt regarding compliance.
Glare - Lighting is not discussed (i.e. around the equipment area).
Visual Impacts - The photo simulations show significant visual impacts, which are not adequately
addressed in the written statement or otherwise addressed within the application materials. Staff
believes that the applicant would needs to undertake extensive work to better represent the
visual impact of the tower with more sophisticated and accurate photo simulations, and from a
variety of additional viewpoints (e.g. views from nearby homes). Even then, it may be that a
different design or location would be appropriate under these approval criteria.
Setbacks - While the application mentions that the proposed tower is located at least 75 feet from
property lines in response to the telecommunication standards elsewhere in the application, the
materials do not sufficiently address this related criterion. At a minimum, the application should
include exact measurements from all adjacent property lines as well as nearby residences, and
better explain the choice for siting the proposed tower and ancillary equipment in context with
this standard.
EC 9.8090(3): The location, design, and related features of the proposal provides a
convenient and functional living, working, shopping or civic environment, and is as
attractive as the nature of the use and its location and setting warrant.
The "as attractive as the nature of the use and its location and setting warrant" requirement is not
addressed. Staff is concerned that this particular stealth design may not respond appropriately to
the setting and recommends that the applicant evaluate alternatives or additional comparative
analysis to better show that the proposed design fits the setting.
EC 9.8090(4): The proposal demonstrates adequate and safe circulation exists...
Instead of just saying "no impact," that applicant must explain the existing conditions and how
access to the equipment will be provided.
EC 9.8090(5): The proposal is designed and sited to minimize impacts to the natural
environment by addressing the following...
The statement does indicate that the property is not on the City's acknowledged Goal 5 inventory.
It just says that the project will have minimal impact on the environment. Describe the on-site
vegetation; confirm that there are no rare plants or species, or other features that require review
under this criterion. Discuss trees on the property as required by this criterion; to the extent that
existing trees may need to be preserved in order to assist with the compatibility of the proposed
design, the applicant needs to address the preservation standards. Staff recommends that the
applicant obtain the services of a licensed arborist or landscape architect to provide an evaluation
Completeness Review: New Cingular Wireless Crossfire Church (CU 14-3) Page 2 of 3
Attachment A
of the size, species, health and condition of existing trees and recommendations for ensuring
protection over time. The site plans and elevations should also be revised to clearly depict the
size, location and species of the existing trees in relation to the proposed tower.
EC 9.8090(6): The proposal provides adequate public facilities and services including, but
not limited to utilities, streets, and other infrastructure.
The statement assumes that no new services are necessary. The applicant needs to address
whether impervious surfaces be added or replaced; and if so, how stormwater runoff will be
managed in compliance with applicable standards for stormwater management.
EC 9.8090(7): The proposal does not create any significant risk to public health and
safety, including but not limited to soil erosion and flood hazard, or an impediment to
emergency response.
Public health and safety is primarily addressed in the Telecommunication Standards, but this
criterion also talks about soil erosion, flood hazard, and emergency response, which is not
addressed in the written statement.
EC 9.8090(8): The proposal complies with all applicable standards, including but not
limited to...
Many of the standards referenced under this criterion appear to be inapplicable, but the written
statement should respond to each to confirm applicability. For access, confirm the frequency of
vehicle access to the equipment area. For stormwater, identify any added/replaced impervious
surfaces.
Completeness Review: New Cingular Wireless Crossfire Church (CU 14-3) Page 3 of 3
Attachment B
Completeness Review of Telecommunications Standards:
Excerpt from City of Eugene Land Use Code, Chapter 9
The application materials for New Cingular Wireless Crossfire Church (CU 14-3) are lacking
sufficient information to evaluate and determine compliance with the applicable
telecommunication standards at Eugene Code (EC) 9.5750. The code standard is provided in
bold with staff concerns identified under each.
9.5750 Telecommunication Devices-Siting Requirements and Procedures.
(1) Purpose. The provisions of this section are intended to ensure that
telecommunication facilities are located, installed, maintained and removed
in a manner that:
(a) Minimizes the number of transmission towers throughout the
community;
(b) Encourages the collocation of telecommunication facilities;
(c) Encourages the use of existing buildings, light or utility poles or water
towers as opposed to construction of new telecommunication towers;
(d) Recognizes the need of telecommunication providers to build out their
systems over time; and
(e) Ensures that all telecommunication facilities, including towers,
antennas, and ancillary facilities are located and designed to minimize
the visual impact on the immediate surroundings and throughout the
community, and minimize public inconvenience and disruption.
Nothing in this section shall apply to amateur radio antennas, or
facilities used exclusively for the transmission of television and radio
signals.
While purpose statements are not directly applicable as approval standards, it would be helpful
for context to have the applicant respond to these. In particular, staff is still concerned that the
applicant may not have exhausted other collocation alternatives. Page 4 of the applicant's
written statement has minimal discussion and raises questions or makes comments like "due to
zoning ordinances prohibiting the location" as a reason for not considering light and utility
poles. Staff would like to get more information and discuss the applicant's efforts to collocate
in the area before entirely ruling out alternatives. Consistent with the City's telecom ordinance,
collocation is certainly preferable to a new tower when possible.
(6) Application Requirements.
(b) Construction of Transmission Tower. In addition to standard required
application material, an applicant for a transmission tower shall
submit the following information; additional application material is
required, as specified in paragraph (c) below, for applications
requiring a site review or conditional use process:
1. A description of the proposed tower location, design and height.
Completeness Review: New Cingular Wireless Crossfire Ministries (CU 14-3) Page 1 of 10
Attachment B
The location is shown on the site plans (Sheet SV1). Elevations are shown (SheetA-3.0), but
distance from grade to lowest branches is missing. Please provide this information. Also,
dimension the adjacent building to provide a clearer determination of scale. Additional
measurements including setbacks from all property lines and homes, and the relationship of the
tower to existing trees on the site should also be provided on the site plans and elevations.
Plan note says "Antennas to be painted green to match monopine." Please provide paint color
samples for the pole and faux branches, and discuss the color choice in context with the
surroundings.
The design is required to reasonably blend in with the surroundings and the photo simulation
"View from Amazon Drive" shows that the tower will be about the same height and shape as
the nearby fir tree. Since that tree appears to be on the same property, staff requests that the
applicant gather actual samples of the branches and bark and compare that to the proposed
tower; also, submit a sample of the tower (as an oversized exhibit), which was provided by
AT&T on another case. Provide as much comparative information as possible, like the height of
that tree compared to the tower and the distance between the two.
The tower seems to really stick out in the photo simulation entitled "Intersection of Amazon
Drive and Fox Hollow Road." The tower sticks out amongst the shorter, deciduous trees along
the street. Is there room to plant more fir trees in that area to create an atmosphere that
softens the bulk and scale of the tower? The arborvitae proposed around the fence enclosing
the ancillary facilities seem to only emphasize the monotony; would another plant mix with a
variety of species help create a better blending effect? The applicant should consider
additional screening that may be needed beyond the perimeter of the tower and equipment,
depending on visual impacts from nearby homes and other strategic locations along the
property lines that would help to buffer the facility.
The photo simulation entitled "View NE from Dillard and Fox Hollow" shows the top of the
tower branches rising above the tree-lined ridge line. Conversely, there's a power pole in the
area that appears to be taller. It may be helpful to put those two features into perspective with
the tower- being a utility. Is there any way to vary the branch alignment to more closely
resemble the tree canopy on the horizon? Again, the application needs to better address the
proposed design in context with surrounding features.
2. The general capacity of the tower in terms of the number and
type of antennas it is designed to accommodate.
The explanation to this standard (page 8 of the applicant's written statement) appears to only
discuss carriers, not the number and type of antennas. Please provide more information about
the full extent of collocation and what those visual impacts might be with the maximum
amount of collocated antennas.
3. Documentation demonstrating compliance with non-ionizing
Completeness Review: New Cingular Wireless Crossfire Ministries (CU 14-3) Page 2 of 10
Attachment B
electromagnetic radiation (VIER) emissions standards as set
forth by the Federal Communications Commission (FCC).
Submitted report from Hatfield & Dawson, Consulting Electrical Engineers.
4. A signed agreement; as supplied by the city, stating that the
applicant will allow collocation with other users, provided all
safety, structural, and technological requirements are met. This
agreement shall also state that any future owners or operators
will allow collocation on the tower.
Applicant states that they will sign an agreement if supplied by the City.
5. Documentation that the ancillary facilities will not produce
sound levels in excess of those standards specified in subsection
(7) of this section, or designs showing how the sound is to be
effectively muffled and reduced pursuant to those standards.
The applicant submitted a report prepared by SAA Acoustics. It implies that the greatest sound
generator is from the air-conditioning unit. Are there other devices, like a generator? On
another case, the generator was the greatest sound producer. The noise level provided is 73
dBA, which exceeds the 45 dBA code limitation. The factors for "predicting" noise level
reductions were just the building edge and distance. Even with those factors, the dBA is only
reduced to the maximum allowable. It seems like more sound mitigation is necessary. For
example, how much sound reduction would occur if the equipment were enclosed in a building
or installed underground?
As noted.previously, it is unclear whetherthe requested underground variance would be
granted without more information to justify the request, particularly related to noise and visual
impacts in a residential area. In any event, it seems critical to have comparative evidence about
the effects of undergrounding. For example, would undergrounding require other noise
generating equipment like an elevator? This would also need to be measured and addressed in
the event that undergrounding may be required; alternatively, the applicant should consider an
underground vault design that does not require additional sound generating equipment, or
provide additional sound buffering as necessary.
In another recent case (AT&T at Oakway Golf Course, a.k.a. Northgreen Properties v. City of
Eugene the variance for undergrounding ancillary facilities was denied; as such, the applicant
was required to submit a revised noise study to demonstrate compliance without the variance.
Assuming that could happen in this case, please provide noise studies under both scenarios.
That could be definitive evidence about the basis for a variance.
6. A landscape plan drawn to scale showing proposed and existing
landscaping, including type, spacing, size and irrigation methods.
Completeness Review: New Cingular Wireless Crossfire Ministries (CU 14-3) Page 3 of 10
Attachment B
The proposed landscaping around the tower is shown, but it does not appear adequate to meet
the screening requirements. The landscape of the surroundings needs better illustration,
particularly if this tree design is intended to blend in with surroundings, which would typically
mean other trees. Is there a more vegetated portion of the site that would be a better location?
7. Plans showing the connection to utilities/right-of-way cuts
required, ownership of utilities and easements required.
Shown
8. Documents demonstrating that necessary easements have been
obtained;
Applicant states that easements will be included in the lease of the property.
9. Plans showing how vehicle access will be provided;
Shown
10. Signature of the property owner(s) on the application form or a
statement from the property owner(s) granting authorization to
proceed with development permit and land use processes;
The property owner has signed the application form.
11. Documents demonstrating that the FAA has reviewed and
approved the proposal, and Oregon Department of Aviation has
reviewed the proposal. Alternatively, when a site review or
conditional use process is required, submit a statement
documenting that notice of the proposal has been submitted to
the FAA and Oregon Department of Aviation. The site review or
conditional use process may proceed and approval may be
granted for the proposal as submitted, subject to FAA approval.
If FAA approval requires any changes to the proposal as initially
approved, then that initial approval shall be void. A new
application will need to be submitted, reviewed and approved
through an additional site review or conditional use process. No
development permit application shall be submitted without
documents demonstrating FAA review and approval and Oregon
Department of Aviation review.
A letter from the Oregon Department of Aviation dated January 24, 2014 confirms that an
aeronautical study resulted in the determination that notice to the FAA is not required and that
Completeness Review: New Cingular Wireless Crossfire Ministries (CU 14-3) Page 4 of 10
Attachment B
no marking or lighting are necessary for aviation safety.
(c) Site Review and Conditional Use Permit Applications. In addition to
the application requirements specified in paragraph (b) above,
applications for site review or conditional use permits also shall
include the following information:
1. A visual study containing, at a minimum, a graphic simulation
showing the appearance of the proposed tower, antennas, and
ancillary facilities from at least 5 points within a 3 mile radius.
Such points shall be chosen by the provider with review and
approval by the planning director to ensure that various
potential views are represented.
The initial visual study provided is insufficient. The photo simulations provided cast serious
doubt about compatibility with the surroundings. The quality is poor, looking more artificial and
even "cartoonish" than an actual, accurate representation. The number of photos and locations
is also deficient. The applicant needs to provide more extensive analysis of the visual impact
from nearby homes and other potential viewpoints in the area. In addition to photo simulations
of the tree design, that applicant should also consider including scenarios for an alternate
stealth design such as a monopole with enclosed antennas. Elevations should also be verified
with balloon testing as well, to provide a more credible photo simulation and analysis.
2. Documentation that alternative sites within a radius of at least
2000 feet have been considered and have been determined to
be technologically unfeasible or unavailable. For site reviews,
alternative sites zoned CAI-1,11-2, and 1-3 must be considered.
For conditional use permits, alternative sites zoned PL, C-2, C-3,
C-4,11-1,1-2,11-3 and S-WS must be considered.
Does the table provided on pages 10 and 11 of the applicant's statement include all sites zoned
PL, C-2, or C-2 within 2,000 feet?
3. Evidence demonstrating collocation is impractical on existing tall
buildings, light or utility poles, water towers, existing
transmission towers, and existing tower facility sites for reasons
of structural support capabilities, safety, available space, or
failing to meet service coverage area needs.
The reference to utility pole height "guidelines" is not an absolute barrier. This should be
investigated further.
4. A current overall system plan for the city, showing facilities
presently constructed or approved and future expansion plans.
Provided
Completeness Review: New Cingular Wireless Crossfire Ministries (CU 14-3) Page 5 of 10
Attachment B
5. A statement providing the reasons for the location, design and
height of the proposed tower or antennas.
Provided
(7) Standards for Transmission Towers and Antennas. Installation, construction
or modification of all transmission towers and antennas shall comply with
the following standards, unless a variance is obtained pursuant to the
provisions of subsection (9) of this section:
(a) Separation Between Transmission Towers. No transmission tower
may be constructed within 2000 feet of any pre-existing transmission
tower. Tower separation shall be measured by following a straight
line from the portion of the base of the proposed tower which is
closest to the base of any pre-existing tower. For purposes of this
paragraph, a tower shall include any transmission tower for which the
city has issued a development permit, or for which an application has
been filed and not denied. Transmission towers constructed or
approved prior to February 26, 1997 may be modified to
accommodate additional providers consistent with provisions for
collocation in this section.
Applicant confirms no towers within 2,000 feet.
(b) Height Limitation: Transmission tower heights shall be governed by
this section except as provided for below. No transmission tower shall
exceed the maximum heights provided below. In no case shall a
variance be granted from the limitations of subparagraphs (1) through
(4) below.
5. If located within an R-1 zone, the maximum height of a
transmission tower, including antennas, is 75 feet, unless a
variance is granted pursuant to the provisions of subsection (9)
of this section. In no event shall a variance be granted to
construct such a tower in excess of 100 feet.
Proposed height is 75 feet.
(c) Collocation. New transmission towers shall be designed to
accommodate collocation of additional providers:
2. New transmission towers of a height of at least 60 feet and no
more than 80 feet shall be designed to accommodate collocation
of a minimum of 1 additional provider either outright or through
future modification to the tower.
Applicant confirms that the tower can accommodate 2 additional providers. Please provide
Completeness Review: New Cingular Wireless Crossfire Ministries (CU 14-3) Page 6 of 10
Attachment B
additional information as noted above about visual impacts with the maximum amount of
collocated antennas and related equipment.
(d) Setback. The following setbacks from adjacent property lines and
adjacent streets shall be required unless a variance is granted
pursuant to the provisions of subsection (9) of this section:
2. If located within an R-1, C-1, or GO zone, the transmission tower
shall be set back from adjacent property lines a minimum
number of feet that is equal to the height of the transmission
tower.
3. In the R-1, PL, C-1 and GO zones, transmission towers shall be
set back from adjacent public street(s) a minimum number of
feet that is equal to the height of the tower. In all other zones,
the setback from adjacent public streets shall be a minimum of
25 feet.
Sheet A-1.0 clearly shows the tower set back 75 feet from the street, but the distance to
property lines needs to be called out. The dashed "tower setback" line doesn't appear to be to
the same scale to the rear property line.
(e) Buffering. In all zones, existing vegetation shall be preserved to the
maximum extent possible. In the C-4,1-1,1-2 and 1-3 zones, no
buffering is required beyond that required by this land use code. In all
other zones, landscaping shall be placed completely around the
transmission tower and ancillary facilities located at ground level
except as required to access the facility. Such landscaping shall consist
of evergreen vegetation with a minimum planted height of 6 feet
placed densely so as to form a screen. Landscaping shall be
compatible with other nearby landscaping and shall be kept healthy
and well maintained.
Arborvitae hedges surround the facility, but as noted above, about compatibility with
surroundings, more and different landscaping may be necessary.
(f) Noise Reduction. In R-1, R-2, R-3, R-4, C-1; and GO and in all other
zones when the adjacent property is zoned for residential use or
occupied by a dwelling, hospital, school, library, or nursing home,
noise generating equipment shall be sound-buffered by means of
baffling, barriers, or other suitable means to reduce sound level
measured at the property line to 45dBa.
The noise analysis doesn't include any other sound-buffering means, like baffling, other than
distance. And at that, it's just at the limit and based on a prediction. This evidence would be
weak under opposing evidence, of which we've seen plenty of from this neighborhood. See
Completeness Review: New Cingular Wireless Crossfire Ministries (CU 14-3) Page 7 of 10
Attachment B
previous comments about the need for additional information, analysis, and sound buffering
alternatives.
(g) Status of Location. No permit may be issued for the location of a new
telecommunications facility within an R-1 or C-1 zone unless the lot on
which it is to be placed is vacant or developed with a non-residential
use at the time the permit application is submitted. This restriction
does not apply within other zones.
The R-1 property is developed with a church. Are there any residential uses on the site?
(h) Lighting. No lighting shall be permitted on transmission towers except
that required by the Federal Aviation Administration. No high
intensity white lights may be located on transmission towers in an R-1,
C-1, or PRO zone.
Clarify lighting. So the tower won't be lit, but what about the equipment area?
(i) Color. The transmission tower and attached antennas shall be
unpainted galvanized steel or painted neutral colors or such shades as
are appropriate and compatible with the surrounding environment, as
approved by the city.
This standard was developed for a reason. It would be helpful to provide photo simulations of a
tower that meets this standard to determine whether the "stealth" design is any better.
(j) Viewshed. The transmission tower shall be located down slope from
the top of a ridgeline so that when viewed from any point along the
northern right-of-way line of 18th Avenue, the tower does not
interrupt the profile of the ridgeline or Spencer Butte. In addition, a
transmission tower shall not interrupt the profile of Spencer Butte
when viewed from any location in Amazon Park. Visual impacts to
prominent views of Skinner Butte, Judkins Point, and Gillespie Butte
shall be minimized to the greatest extent possible. Approval for
location of a transmission tower in a prominent view of these Buttes
shall be given only if location of the transmission tower on an
alternative site is not possible as documented by application materials
submitted by the applicant, and the transmission tower is limited in
height to the minimum height necessary to provide the approximate
coverage the tower is intended to provide.
The proposed tower doesn't appear to be within these view sheds.
(k) Display. No signs, striping, graphics or other attention getting devices
Completeness Review: New Cingular Wireless Crossfire Ministries (CU 14-3) Page 8 of 10
Attachment B
are permitted on the transmission tower or ancillary facilities except
for warning and safety signage with a surface area of no more than 3
square feet. Such signage shall be affixed to a fence or ancillary
facility and the number of signs is limited to no more than 2.
Applicant states there will be none.
(8) Standards for Ancillary Facilities. All ancillary facilities shall comply with the
standards of subsections (7)(e) and (7)(f) of this section. In addition, all
ancillary facilities within an R-1, PL, C-1, GO, and PRO zone must be located
underground to the maximum extent technology allows, unless a variance is
obtained pursuant to the provisions of subsection (9) of this section. This
restriction does not apply within other zones.
As noted previously, the ability to obtain a variance is questionable. In response to the standard
above, provide information about the technological feasibility of undergrounding and consider
proposing it an alternative design (along with a noise study that addresses an underground
design) in the event that a variance is denied.
(9) Variance.
(c) The city may grant a variance to the setback and undergrounding
requirements of subsections (7)(d) or (8) upon finding that stealth
design, proposed landscaping, configuration of the site, or the
presence of mature trees obviates the need for compliance.
The requested variance for not undergrounding the ancillary facilities is not sufficiently
supported by the application materials. Please refer to the case involving the Oakway Golf
course, in which the variance was denied (City file numbers PDT 10-2 and CU 11-1).
(10) Removal of Facilities.
(a) All transmission towers and antennas shall be removed by the person
who constructed the facility, by the person who operates the facility,
or by the property owner, within 6 months of the time that the
facilities have ceased being used to transmit, receive or relay voice
and data signals to or from wireless communication devices. The city
manager may grant a 6-month extension where a written request has
been filed, within the initial 6-month period, to reuse the tower or
antennas.
(b) If a transmission tower is located within an R-1, PL, C-1 or GO zone,
the provisions of subparagraph (a) also shall apply to the tower
substructure and all above ground ancillary facilities.
(c) The city may require the posting of an open ended bond before
development permit issuance to insure removal of the transmission
tower, substructure or antennas after the facility no longer is being
Completeness Review: New Cingular Wireless Crossfire Ministries (CU 14-3) Page 9 of 10
Attachment B
used.
The written statement did not provide a response to this standard.
(11) Application Review and Fees. The city manager shall retain one or more
consultants to verify the accuracy of statements made in connection with an
application for a building or land use permit for a telecommunications
facility. Notwithstanding any other provision of this code, the city manager
shall require the applicant to pay, as part of the application fees, an amount
sufficient to recover all of the city's costs in retaining the consultant(s).
Th ird-pa rty. review of the application will be required. The applicant will be required to pay an
initial deposit to cover the expense, and additional fees may be required. Staff will provide
more information on the required third-party review when revised application materials are
submitted in response to this completeness review.
Completeness Review: New Cingular Wireless Crossfire Ministries (CU 14-3) Page 10 of 10
f Attachment A
Completeness Review of Conditional Use Permit Criteria: Received
Excerpt from City of Eugene Land Use Code, Chapter 9
OCT 2 7 2014
The application materials for New Cingular Wireless Crossfire Ministries (CU 14-3) are lacking
sufficient information to evaluate and determine compliance with the applicable Cfel4mitifiEw., nQ
Use Permit approval criteria at Eugene Code (EC) 9.8090. The code standard is prB 6q6 61618 ion
with staff concerns identified under each.
RESPONSE: The Applicant has provided supplemental responses to the code criteria listed
below. Responses are in italic text below the staff comment to each code criterion.
EC 9.8090(1): The proposal is consistent with applicable provisions of the Metro Plan
and applicable refinement plans.
The written statement does not identify the Metro Plan land use diagram designation, which
is low-density residential. As such, the Metro Plan Residential Land Use policies should be
reviewed with an explanation to determine applicability. More information also appears
necessary to show compliance with Policy E.4 of the Metro Plan, in light of recent case law
established in Northgreen Properties v. City of Eugene. Staff advises the applicant to closely
review that recent. case history for the type of findings and evidence that is necessary to
demonstrate that the facility is "designed and located in a manner that preserves and
enhances desirable features of the local and neighborhood areas and promotes their sense of
identity."
RESPONSE. The proposed project is within the Urban Growth Boundary as shown on the Metro
Area General Plan-Plan Diagram. The Property is designated as low-density residential, which
allows for up to 10 units (single- or multi family structures) per gross acre, leaving about 31% of
the area available for auxiliary uses. (Metro Plan at 11-G-3.) The Property is also within the
Southeast Neighborhood of Eugene (which is about 5 square miles in area).
(See, www.Eugene-OR.gov/index.aspx?NID=535; http://www.city-
data.com/neighborhood/Southeast-Eugene-OR.html.)
Environmental Design Element, Policy E.4: Policy E.4 of the Environmental Design Element says,
"Public and private facilities shall be designed and located in a manner that preserves and
enhances desirable features of local and neighborhood areas and promotes their sense of
identity." In the recent LUBA case of Northgreen Properties v. City of Eugene, the Board
determined that this guideline must be addressed separately from Eugene code requirements
because the guideline contains a specific directive that a telecommunications tower be designed
and located to preserve and enhance desirable features of the neighborhood. LUBA No. 2011-
099 at p. 6-7.
The desirable features of the neighborhood surrounding the proposed site include abundant
ground flora, mature evergreen trees and shorter deciduous tree and views of treed hillsides.
The existing buildings in the area are mostly older single-family homes, with some multi family
structures and developments. The stretch of West Amazon Drive where the Property is located
Completeness Review: New Cingular Wireless - Crossfire Church (CU 14-3)
Attachment A
is a main thoroughfare with a heavily vegetated buffer island that carries water in the Amazon
Canal. This area is vegetated with a variety of native trees and shrubs. The neighborhood is
developed primarily with single-family homes. There are regularly spaced utility poles with
visible cables and attached equipment and street trees along both East and West Amazon Drive
and Fox Hollow. The Property is developed with a church building, with a parking lot facing
West Amazon Drive and wrapping around the north side of the building.
The proposed project forwards Policy E.4 by preserving the desirable features of the
neighborhood, including the trees and architecture that contribute to the neighborhood's
residential identity. The proposed telecommunication facility, a monopine, is designed to
contribute to the existing backdrop of the other evergreen trees in the area, including species,
size and color. The evergreen trees in the immediate vicinity are predominantly Ponderosa Pine
and Shore Pine. Further away from the site the hillsides are predominantly Douglas Fir with
occasional cedars and spruce trees. From the street, looking toward the site, the monopine
would be set against the backdrop of existing tall evergreen trees, and would be about 125 feet
to the north of a 100 foot tall pine tree; about 75 feet to the north of 2 49 foot tall pine trees,
and about 75 feet to the south of a 63 foot tall pine tree. See Att. 04 (Site Plan) and Att. 10
(Photo Simulations). The ancillary equipment would be within a fully enclosed extension of the
church, matching the church's architecture, roofing, siding and color. See Att. 04 (Site Plan) and
Att. 10 (Photo Simulations).
The proposed project would also enhance a desirable feature in the neighborhood--more
reliable and higher quality wireless service. Wireless service is a critical component of a thriving
community today, with more people relying on wireless devices for everything from information
gathering to financial transactions to primary home and business phone service. Data usage on
AT&T's network has increased more than 50,000% in the past six years and more than 38% of
households have opted out of landline service and rely solely on wireless phone service. Without
landline communications, those homes are entirely dependent on reliable wireless service to
place 911 calls in the event of emergency. See Att. 17 (AT&T Oregon Investment Data Sheet).
This proposed telecommunication facility would improve the service along the Amazon Drive
corridor and the surrounding neighborhood from approximately E. 32nd Avenue, south to about
Nectar Way. See Att. 11 (RF Justification & Coverage Maps).
EC 9.8090(2): The location, size, design, and operating characteristics of the proposal
are reasonably compatible with and have minimal impact on the livability or
appropriate development of surrounding property, as they relate to the following
factors:
(a) The proposed building(s) mass and scale are physically suitable for the type
and density of use being proposed.
The written statement needs to better articulate compliance with this criterion with
supporting evidence. The conclusive statement without supporting evidence and findings are
insufficient. The statement says the monopine is designed to look like other evergreen trees in
the immediate area, but the photos show few evergreen trees in close proximity. The
Completeness Review: New Cingular Wireless - Crossfire Church (CU 14-3) 2
Attachment A
statement also concludes that the ancillary equipment shed will look like an extension of the
chapel. This needs to be illustrated and better explained as to how it fits within the area in
terms of mass and scale and impact on the surroundings. The applicant should also consider
the possibility that a variance may not be granted to allow above ground ancillary facilities,
and provide for alternative designs (e.g. underground or fully enclosed with additional sound
buffering) as a contingency or means to better address the approval criteria.
RESPONSE: The Photo Simulations at Attachment 10 have been revised to show the evergreen
trees in close proximity to the proposed monopine and the proposed equipment shelter. The
Site Plan at Attachment 04 has been revised to include more details about the mass and scale of
nearby structures and trees, and the design of the proposed equipment shelter.
The mass and scale of the proposed project, both the monopole and the ancillary equipment
shelter, are consistent with the mass and scale of structures and trees in the immediate area:
The proposed 75 foot tall monopine would be adjacent to four similar-looking pine trees, 1100-
foot tall pine tree about 125 feet to the south; 2 49 foot tall pine trees about 75 feet to the
southeast, and 1 63 foot tall pine tree about 75 feet to the north. The proposed monopine
would also be against a backdrop of other tall evergreen trees that are about 300 feet to the
west and range in height from 20 to 100 feet. See Att. 10 (Photo Sims, View #8). The fencing
around the base of the monopine would be a 6 -foot tall cedar fence, and would be surrounded
by landscaping that would typically be found on either a residential property or a property (such
as a church) located in a residential neighborhood. See Att. 04 (Site Plan, Sheets A-3.0, 3.1;
L1.1, 2) and Att. 10 (Photo Sims, View #s 2, 10, 14). (The Applicant will change the design of the
fence if City staff and officials believe a different fence design would fit into the neighborhood
better and still provide appropriate screening and safety functions.)
The proposed ancillary equipment shelter is designed to look like an extension of the existing
church, and would, in fact, function, in part, as an additional storage area for the church. The
shelter would be fully enclosed, including a roof, and be built flush against the side of the
church. It would be sided and painted to match the church building. The stepped down scale of
the addition of the equipment shed to the south side of the building would help to soften the
large, nearly blank wall, of the church that faces Fox Hollow. The wall as it exists is
architecturally plain. The new addition would complement the existing church and provide a
more pedestrian-scale element on this facility in keeping with the residential character of the
neighborhood.
The WTF ground equipment would be fully enclosed within the equipment shelter, and noise
produced by the equipment would be further mitigated by sound baffling to levels below the
maximum level allowed. See Att. 04 (Site Plan); Att. 10 (Photo Sims); Att. 07 (Sound Study).
The proposed monopine and equipment shelter is compatible with the existing trees and
structures on the Property. As described and demonstrated in the referenced Attachments, the
mass, scale, and design of the proposed structures is consistent with the existing church building
and surrounding evergreen trees, making the proposed monopole and equipment shelter
suitable for the surrounding low-density residential neighborhood.
Completeness Review: New Cingular Wireless - Crossfire Church (CU 14-3)
Attachment A
(b) The proposed structures, parking lots, outdoor use areas or other site
improvements which could cause substantial off-site impacts such as noise,
glare and odors are oriented away from nearby residential uses and/or are
adequately mitigated through other design techniques, such as screening
and increased setbacks.
Screening is not addressed at all in the written statement or adequately shown on the plans.
The expectation on screening has been clarified in other cases, which the applicant should
review for a better understanding of what is required.
Noise - The evidence about noise levels casts doubt regarding compliance.
Glare - Lighting is not discussed (i.e. around the equipment area).
Visual Impacts - The photo simulations show significant visual impacts, which are not
adequately addressed in the written statement or otherwise addressed within the application
materials. Staff believes that the applicant would needs to undertake extensive work to better
represent the visual impact of the tower with more sophisticated and accurate photo
simulations, and from a variety of additional viewpoints (e.g. views from nearby homes). Even
then, it may be that a different design or location would be appropriate under these approval
criteria.
Setbacks - While the application mentions that the proposed tower is located at least 75 feet
from property lines in response to the telecommunication standards elsewhere in the
application, the materials do not sufficiently address this related criterion. At a minimum, the
application. should include exact measurements from all adjacent property lines as well as
nearby residences, and better explain the choice for siting the proposed tower and ancillary
equipment in context with this standard.
RESPONSE: Off-site impacts of the proposed WTF, including visual impacts and potential noise
impacts, have been mitigated, as addressed below.
Screening: As sited, the proposed monopine would be partially screened by existing trees,
existing structures, and utility poles and wires. See Att. 10 (Photo Simulations). The base of the
monopine would be screened by a 6 -foot tall cedar fence, in turn screened by proposed
landscaping. The landscaping is residential in nature (as opposed to something more typical of a
commercial development). This type of planting keeps with the garden-like style that the
neighbors would typically cultivate: There is a variety of plants which provide a variety of height,
width, seasonal color and foliage texture. The plant heights range from 2' tall to C tall and will
assist in screening the proposed fence, which in turn fully screens the base of the proposed cell
tower.
It would not be unusual to see the proposed planting at the base of a mature tree (the
monopine). When viewing this area, the diversity and texture of the plantings would help the
facility recede into the background of the view. See Att. 04 (Site Plan, Sheets L1.0 and L2.0).
Completeness Review: New Cingular Wireless - Crossfire Church (CU 14-3) 4
Attachment A
Noise: Noise from the proposed WTF would emanate primarily from the air conditioning unit
(AC) and secondarily from the emergency generator. The AC would run intermittently
throughout the day to cool the equipment. The emergency generator would produce noise only
during emergencies and during routine testing, which would take place during daytime hours (7
AM -10 PM) for less than 10 consecutive minutes once a month. This test can be scheduled to
minimize auditory impact. The Applicant has mitigated the potential noise impacts from this
equipment by housing it within o fully enclosed, insulated equipment shelter. The shelter would
include sound baffling to mitigate noise from the AC to well below the 45dBA code limit.
Because the proposed generator would run for such a short amount of time during daytime
hours, it would not be considered a noise disturbance under the code even if the noise level
briefly exceeds 45 dBA. (Per Matt Denberg, City of Eugene Code Compliance, Oct. 22, 2014. See
generally, EC 6.750(b).) However, to minimize the noise levels from the generator, it would be
enclosed within the sound-baffled equipment shelter. See Att. 04 (Site Plan, Sheet A-2.0) and
Att. 07 (Sound Study).
Glare: There is no lighting proposed on the monopine, within the fenced area at the base of the
monopine, or on the exterior of the auxiliary equipment shelter. There would be lighting inside
the equipment shelter, but this would not be visible from the outside. The monopine branches
are and trunk would be an earth brown color and the needles a matte green similar to the
surrounding evergreen trees. The tower would not produce glare.
Visual Impacts: The Applicant has mitigated the potential visual impact of the proposed WTF
antennas and support structure by designing the support structure to look like existing
evergreen trees in the area, with the antennas hidden among the braches. The proposed
monopine is sited against an evergreen treed hill to the east, and near an evergreen treed area
along Dillard Road (roughly 300 feet to the west). The monopine is adjacent to a 100 foot tall
pine tree about 125 feet to the south; 2 49-foot-tall pine trees about 75 feet to the southeast,
and a 63 foot tall pine tree about 75 feet to the north. The location of the proposed monopine,
near several existing mature evergreen trees, mitigates the potential visual impact of the
proposed WTF by disguising it to look like native trees in the area.
The base of the proposed monopine would be screened by a 6 -foot tall cedar fence and a
landscaping buffer. See Att. 04 (Site Plan). The Applicant will work with the City to install
reasonable additional screening to further mitigate visual impacts, if necessary.
The Applicant has mitigated the potential visual impact of the equipment shelter by designing it
to look like an extension of the existing church, as described immediately above in the Response
to EC 9.8090(2)(a). The shelter would be built flush against the existing building and have
matching siding, paint, and roofing.
Setbacks: The proposed project meets or exceeds all setback requirements, as described in the
Response to EC 9.5750(7)(d) and shown of Att. 04 (Site Plan). This location allows the applicant
to take advantage of the existing treed landscape in order to mitigate the visual impacts of the
WTF support structure from nearby residences. Additionally, the WTF's proximity to the church
allows for an equipment building that would seamlessly integrate with the existing building on
Completeness Review: New Cingular Wireless - Crossfire Church (CU 14-3)
Attachment A
the property.
The "as attractive as the nature of the use and its location and setting warrant" requirement is
not addressed. Staff is concerned that this particular stealth design may not respond
appropriately to the setting and recommends that the applicant evaluate alternatives or
additional comparative analysis to better show that the proposed design fits the setting.
RESPONSE: As described above and shown in the attached photo simulations (Att. 10), the
proposed WTF facility is designed as a monopine to match the mass, scale, and color of existing
trees in the neighborhood, thus matching the location and setting of the use. AT&T has chosen
the premium design for the monopine to maximize the visual screening effect of the design of
the facility itself. The enhanced wireless service provided by the proposed project would add
convenience, safety and functionality to the surrounding areas.
The proposed premium monopine is the most effective stealth design for this
telecommunication use and it will also leverage proximity to other mature evergreen trees for
additional visual impact mitigation.
Additionally, the proposed plantings that act as the screen, in conjunction with the fence, are
residential in scale and nature. There is seasonal interest and a variety of foliage and plant
types. This planting is typical to both church properties and residential neighborhoods.
The equipment room is merely an extension of the existing architecture. The south facing wall of
the existing church is fairly tall, as it houses the sanctuary and is typical of churches. The
addition of a smaller, more pedestrian scale facility to the south side adds much-needed
articulation to the architecture. There would also be residential scale plantings around this
facility helping the entire proposed facility compliment and blend into the existing setting.
Nothing about this addition would seem out of place or out of scale considering the immediate
surroundings.
EC 9.8090(4): The proposal demonstrates adequate and safe circulation exists for the
following:
(a) (Vehicular access to and from the proposed site, and on-site circulation and
emergency response.
(b) Pedestrian, bicycle and transit circulation, including related facilities, as
needed among buildings and related uses on the development site, as well
as to adjacent and nearby residential areas, transit stops, neighborhood
activity centers, office parks, and industrial parks, provided the city makes
findings to demonstrate consistency with constitutional requirements.
"Nearby" means uses within 1/4 mile that can reasonably be expected to
be used by pedestrians, and uses within 2 miles that can reasonably be
expected to be used by bicyclists.
Completeness Review: New Cingular Wireless - Crossfire Church (CU 14-3) 6
Attachment A
Instead of just saying "no impact," that applicant must explain the existing conditions and how
access to the equipment will be provided.
RESPONSE! The proposed project would generate minimal traffic in the area, requiring
approximately one routine maintenance visit per month by AT&T personnel in a single vehicle.
The vehicle would enter the property through the existing driveway and park in the existing
parking lot. AT&T personnel would then access the proposed WCF on foot. This monthly
maintenance visit would have no impact on the existing vehicular access to and from the
proposed site, and would not change the existing ingress and egress that functions adequately
for the existing facility. This proposed project would not impede pedestrian, bicycle and transit
circulation.
EC 9.8090(5): The proposal is designed and sited to minimize impacts to the natural
environment by addressing the following:
The statement does [not] indicate that the property is not on the City's acknowledged Goal S
inventory. It just says that the project will have minimal impact on the environment. Describe
the on-site vegetation; confirm that there are no rare plants or species, or other features that
require review under this criterion. Discuss trees on the property as required by this criterion;
to the extent that existing trees may need to be preserved in order to assist with the
compatibility of the proposed design, the applicant needs to address the preservation
standards. Staff recommends that the applicant obtain the services of a licensed arborist or
landscape architect to provide an evaluation of the size, species, health and condition of
existing trees and recommendations for ensuring protection over time. The site plans and
elevations should also be revised to clearly depict the size, location and species of the existing
trees in relation to the proposed tower.
_
RESPONSE: This property is not on the City's acknowledged Goal 5 inventory. The Applicant
has obtained the services of The Schirmer Satre Group landscape architects. Carol Schirmer is
an Oregon licensed landscape architect, and has assisted the Applicant in preparing the
arboriculture information required by the city. See Att. 04b (Arboriculture Report).
(a) Protection of Natural Features.
1. For areas not included on the city's acknowledged Goal 5 inventory, the
preservation of significant natural features to the greatest degree attainable or
feasible, including:
RESPONSE: The proposed project is not on the City's acknowledged Goal 5 inventory, thus the
Applicant addresses the criteria in EC 9.8090(5)(a)1.a-e, below.
a. Significant on-site vegetation, including rare plants (those that are
proposed for listing or are listed under state or federal law), and native
plant communities.
Completeness Review: New Cingular Wireless - Crossfire Church (CU 14-3) 7
Attachment A
RESPONSE: The onsite vegetation is typical of property that is fully developed within the urban
environment. RLID records indicate this property has been in church ownership since 1987.
More than likely, the property has consistently maintained the existing landscape while adding
features like play areas and sand volleyball courts. The existing vegetation is predominantly
manicured lawn. There are a few existing trees on site that have been shown on the existing
vegetation plan. The plant beds around the building are devoid of any plant material, including
weeds, and it is suspected that perhaps herbicidal maintenance has occurred. Given the high
level of maintenance of this property and a search of available data bases, there are no known
rare plants evident.
b. All documented habitat for all rare animal species (those that are proposed
for listing or are listed under state or federal law).
RESPONSE:, The applicant had a National Environmental Policy Act (NEPA) Review completed
for this site. This review did not identify any historical, cultural or environmental concerns,
including rare animal species. This property is not found under any database as a documented
habitat for rare animal species and not rare animal species are typically found in this urban
area.
c. Prominent topographic features, such as ridgelines and rock outcrops.
RESPONSE: This property is not on a ridgeline, there are no prominent topographic features as
the site is fairly flat, and there are no rock outcroppings.
d. Wetlands, intermittent and perennial stream corridors and riparian areas.
RESPONSE: No wetlands, intermittent or perennial stream corridors, or riparian areas were
identified on the City of Eugene Zoning maps (Overlay Zones). A site visit and observation
reveals that there are no intermittent or perennial stream corridors or riparian areas. A search
of wetlands databases also indicates there are no wetlands present.
e. Natural resource areas designated in the Metro Plan diagram as "Natural
Resource" and areas identified in any city-adopted natural resource
inventory.
RESPONSE:; The proposed project is not within a Natural Resource area as defined by the Metro
Plan.
2. For areas included on the city's acknowledged Goal 5 inventory, the
preservation of natural features shall be consistent with the acknowledged
level of preservation provided for the area.
RESPONSE: The proposed project is not on the City's acknowledged Goal 5 Inventory, thus this
criterion does not apply. This property does not show up on any city adopted natural resource
inventory.
Completeness Review: New Cingular Wireless - Crossfire Church (CU 14-3)
Attachment A
(b) Tree Preservation. The proposed project shall be designed and sited to
preserve significant trees to the greatest degree attainable or feasible, with
trees having the following characteristics given the highest priority for
preservation:
1. Healthy trees that have a reasonable chance of survival considering the base
zone or special area zone designation and other applicable approval criteria
RESPONSE:' The existing trees on the site are healthy, for the most part. None of them are
proposed for removal and they are safely out of the construction zone. The only tree that may
be affected by the construction is a 48" spruce tree because of the location of its critical root
zone. See Att. 04 (Site Plan). However, even then the impact will be around 7.7% well below the
30% that triggers a technical felling. This spruce is also the least healthy tree on the property,
with half the tree currently dead or dying. It has a split trunk and the portion that is dead or
dying is a separate trunk from the remainder of the tree.
2. Trees located within vegetated corridors and stands rather than individual
isolated trees subject to windthrow.
RESPONSE; All of the trees on the site are fairly isolated so there are no vegetated corridors on
the site to preserve. All of the trees currently stand as isolated trees. No trees are proposed for
removal as a result of this development.
3. Trees that fulfill a screening function, provide relief from glare, or shade
expansive areas of pavement.
RESPONSE: All trees are being retained. The existing trees on the site, especially the row of trees
along West Amazon, will screen to some degree the proposed monopine. While the trees are
fairly equally spaced, as is fairly typical of parking lot trees, they provide something visual in the
foreground that will be seen in addition to the monopine. The cell tower is not going to
disappear. Anyone can see it if they stand still and look for it. But given the existing topography,
proposed landscaping, existing mature trees and existing evergreen backdrop, as well as the
monopine design itself, the proposed project effectively blends the proposed development into
the existing surroundings.
4. Trees that provide a buffer between potentially incompatible land uses.
RESPONSE:: All trees are being retained. See discussion in 3 above.
5. Trees located along the perimeter of the lot(s) and within building setback
areas.
RESPONSE: All trees are being retained. The majority of these trees are on the perimeter of the
east lot line. There are 2 trees that are in direct line with the proposed monopine and the
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Attachment A
southeast corner of the lot, and one additional tree on the south lot line. See discussion in
subsection 3, above. See Att. 04 (Site Plan, Sheet L1) for existing tree locations.
6. Trees and stands of trees located along ridgelines and within view corridors.
RESPONSE: All trees are being retained. This site is not located on a ridgeline or in a view
corridor.
7. Trees with significant habitat value
RESPONSE:. All trees are being retained.
8. Trees adjacent to public parks, open space and streets.
RESPONSE: All trees are being retained. The majority of the trees to be preserved are along
West Amazon Street. There are a handful of trees is located along Fox Hollow Road. See
discussion in 3 above.
9. Trees along water features.
RESPONSE:: There are no water features on the Property and the site is not located along a
water feature.
10. Heritage trees.
RESPONSE:; All trees are being retained. There are no heritage trees on this site.
(c) Restoration or Replacement.
1. For areas not included on the city's acknowledged Goal 5 inventory, the
proposal mitigates, to the greatest degree attainable or feasible, the loss of
significant natural features described in criteria (a) and (b) above, through the
restoration or replacement of natural features such as:
RESPONSE: The proposed project is not on the City's acknowledged Goal 5 inventory, thus the
Applicant addresses the criteria in EC 9.8090(5)(c)1, below.
a. Planting of replacement trees within common areas; or
b. Re-vegetation of slopes, ridgelines, and stream corridors; or
c. Restoration of fish and wildlife habitat, native plant habitat, wetland areas,
and riparian vegetation.
To the extent applicable, restoration or replacement shall be in compliance
with the planting and replacement standards of EC 6.320.
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Attachment A
RESPONSE: Please see the Responses to EC 9.8090(5)(a) and (b), above, and Attachment 04
(Site Plan, L1.0-L2.0) for a description of appropriate mitigation, restoration and replacement
measures in accordance with EC 6.320.
There will be no removal of existing trees, and therefore no restoration or replacement is
required. There is no disturbance to slopes, ridgelines and stream corridors as there are none
existing on the site. There is also no fish and wildlife habitat, native plant habitat, wetland areas
or riparian vegetation to consider.
The only existing tree that may be affected by the construction is the 48" spruce (Tree #22).
Approximately 7.7 % of the theoretical critical root zone may be affected. The impact to the
existing root system would be easily mitigated by constructing tree protection fencing at the
construction site. See Attachment 04 (Site Plan, Sheet L1.0) for critical root zone and tree
protection fencing.
2. For areas included on the city's acknowledged Goal 5 inventory, any loss of
natural features shall be consistent with the acknowledged level of
preservation provided for the resource.
RESPONSE: The proposed project is not on the City's acknowledged Goal 5 Inventory, thus this
criterion does not apply.
(d) Street Trees. If the proposal includes removal of any street tree(s), removal of
those street tree(s) has been approved, or approved with conditions according
to the process at EC 6.305 of this code.
RESPONSE: The proposed project does not include the removal of any street trees
EC 9.8090(6): The proposal provides adequate public facilities and services including,
but not limited to utilities, streets, and other infrastructure.
The statement assumes that no new services are necessary. The applicant needs to address
whether impervious surfaces be added or replaced; and if so, how stormwater runoff will be
managed in compliance with applicable standards for stormwater management.
RESPONSE:: The proposed project would be unmanned and would not create a need for
additional public facilities or services.
Water/Sewer: The proposed WCF would be unmanned, so it would not require water, sewer or
waste management services. Water requirements for landscaping maintenance would be
adequately provided for by an irrigation system. See Att. 04 (Site Plan, Sheet L2.0).
Power: The WCF would use 200AI1201240 V, single phase, 3 wire service that would be
provided by EWEB. EWEB would need to upgrade its existing pole mounted transformer in order
to provide power to AT&T. EWEB would provide and install a new secondary junction box
approximately 6 feet from its existing power pole #13322. This location has been reviewed and
Completeness Review: New Cingular Wireless - Crossfire Church (CU 14-3) 11
Attachment A
the power route and usage designed with EWEB. See Att. 14 (Utility Coordination Report).
Streets/Traffic: The proposed WCF would require only monthly maintenance visits in a single
vehicle, thus having a negligible impact on streets and traffic.
Stormwater Management: The project has been redesigned to eliminate the tower concrete
pad, and to use pervious paving materials, such as wood chips for the paths. The impervious
surface for this project has been reduced to 30 SF for the tower base and 928 SF for the church
building extension to house the equipment for AT&T and future collocators. The total impervious
surface is 958 SF, well below the code's 1000 SF threshold for stormwater mitigation. These
changes are reflected in ATT 04-Revised Site Plan.
EC 9.8090(7): The proposal does not create any significant risk to public health and
safety, including but not limited to soil erosion and flood hazard, or an impediment
to emergency response.
Public health and safety is primarily addressed in the Telecommunication Standards, but this
criterion also talks about soil erosion, flood hazard, and emergency response, which is not
addressed in the written statement.
RESP0111SE: The proposed facility would not create any significant risk to public health and
safety, including soil erosion, flood hazard or emergency response.
Soil Erosion: The Applicant completed a geotechnical report that confirms the site is
geologically stable for this proposal. See Att. 16 (Geotechnical Report).
Flood Hazard/Storm water Management: The project has been redesigned to eliminate the
tower concrete pad, and to use pervious paving materials, such as wood chips for the paths. The
impervious surface for this project has been reduced to 30 SF for the tower base and 928 SF for
the church building extension to house the equipment for AT&T and future collocators. The
total impervious surface is 958 SF, well below the code's 1000 SF threshold for stormwater
mitigation. These changes are reflected in ATT 04-Revised Site Plan.
Emergency Response: The proposed project can improve emergency response by adding
improved and expanded wireless service for citizens in the surrounding neighborhoods and the
travelling public making emergency calls.
Injury to Person or Property: The proposed facility would transmit radio frequencies well
below the maximum exposure levels set by the FCC. See Att. 06 (NIER Report). The proposed
monopine would be conditioned by the City of Eugene to be engineered to meet all federal,
state and local structural standards.. The proposed monopine complies with the City's setback
requirements, which provide a functional fall zone in the highly unlikely event of collapse or
damage to the monopine.
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Attachment A
EC 9.8090(8): The proposal complies with all applicable standards, including but
not limited to:
Many of the standards referenced under this criterion appear to be inapplicable, but the
written statement should respond to each to confirm applicability. For access, confirm the
frequency of vehicle access to the equipment area. For stormwater, identify any
added/replaced impervious surfaces.
(a) EC 9.2000 through 9.3915 regarding lot dimensions, solar standards, and
density requirements for the subject zone;
RESPONSE: EC 9.2000 through 9.3915 lay out zoning requirements for Base Zones and Special
Zones. The code requirements applicable to the proposed project are the Residential Zone Land
Use and Permit Requirements of EC 9.2740. The proposed project conforms to these
requirements, as described in the Statement of Compliance submitted to the City of Eugene with
this application on April 30, 2014. See Att. 03 (Written Statement of Compliance).
The Solar Standards of EC 9.2780, et seq. apply to the creation of lots within subdivisions. The
proposed project would not create a lot, thus the Solar Standards do not apply. The density
requirements in the Special Area Zone Sections of EC 9.3000, et seq. do not apply to the
proposed project because the project is not within any Special Zone.
Specifically:
Table 9.2750 Residential Zone Development Standards
The subject property is zoned R-1. Minimum density per acre: no minimum. Maximum
density per Acre: 14 units. This proposal does not add any residential units therefor density
is not applicable.
Table 9.2760 Residential Zone Lot Standards.
The cell tower is not required to be placed on its own separate tax lot. No new lots are being
created therefore the lot standards do not apply.
EC 9.2790 Solar Lot Standards
Solar lot standards apply to the creation of lots within subdivisions in R-1 and R-2 zones. This
application is not a proposal for a subdivision, therefore the solar lot standards do not apply.
EC 9.2795 Solar Setback Standards
These standards apply to all structures on R-1 and R-2 zoned lots, 4000 sf or greater, with a
minimum north south dimension of 75 feet. The structure is not over 4000 sf and is not 75
feet long in the north south direction therefor this criterion does not apply.
(b) EC 9.6500 through EC 9.6505 Public Improvement Standards;
RESPONSE: The Public Improvements Standards do not apply because the proposed project is
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Attachment A
not a public improvements project.
Specifically:
EC 9.6500 Easements.
A 10' utility easement has been created along Fox Hollow. See Site Plan.
EC 9.6505 Improvements-Specifications.
(1) Water Supply: The property is currently served by EWEB.
(2) Sewage: The property is currently served by City of Eugene for wastewater.
(3) Streets and Alleys: No new streets and alleys are proposed. The site is currently well
served by Fox Hollow to the south and West Amazon Parkway to the east. The surrounding
properties to the west and north are fully developed with residential buildings.
(4) Sidewalks: No new sidewalks are proposed as no new streets are proposed. Both Fox
Hollow and West Amazon have sidewalks.
(5) Bicycle Plans and Accessways: No new bike paths or accessways are proposed.
(c) EC 9.6735 Public Access Required.
RESPONSE The proposed project would be on Property that fronts a public street, West
Amazon Drive. Access to the proposed project from West Amazon Drive would be through the
existing driveway and parking lot. The project complies with EC 9.6735. (The general public
would not be able to access the WTF ground equipment or monopine because both would be
secured behind locked doors or gates, as required by the Eugene Municipal Code.)
Specifically:
EC 9.6735(2) Access from a public street to a development site shall be located in
accordance with EC 7.420 Access Connections - Location. If a development site will increase
the development site's peak hour trip generation by less than 50% and will generate less
than 20 additional peak hour trips, the development site's existing access connections are
exempt from this standard.
A service vehicle will access the tower facility once a month. The ITE manual suggests that
utilities generate. 76 peak hour trips per 1000 sf. The facility is under approximately 750 sf or
.57 peak hour trips. A church generates.55 peak hour trips per 1000 sf. At 14000 sf the church
generates 7.7 peak hour trips.
The church function generates more peak hour trips than the cell tower, therefore there is no
increase, there are not 20 new trips, and the project is exempt from access management
standards.
(d) EC 9.6791 through 9.6797 regarding stormwater destination, pollution
reduction, flow control for headwaters area, oil control, source control,
easements, and operation and maintenance; and
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Attachment A
RESPONSE : The project has been redesigned to eliminate the tower concrete pad, and to use
pervious paving materials, such as wood chips for the paths. The impervious surface for this
project has been reduced to 30 SF for the tower base and 928 SF for the church building
extension to house the equipment forAT&T and future collocators. The total impervious surface
is 958 SF, well below the code's 1000 SF threshold for stormwater mitigation. These changes
are reflected in ATT 04-Revised Site Plan.
(e) EC 9.6800 through EC 9.6875 Standards for Streets, Alleys, and other Public
Ways;
RESPONSE: The proposed project does not include the creation or modification of any streets,
alleys, or other public ways, thus EC 9.6800 through EC 9.6875 do not apply.
Specifically:
EC 9.6810 Block Length
No new streets are proposed and no new blocks are being created.
EC 9.6815 Connectivity for Streets
The site is bordered by fully developed streets to the south (Fox Hollow) and to the east
(West Amazon). To the north and west are fully developed residential properties. There is no
reason or ability to provide connectivity.
EC 9.6820 Cul de Sacs or Emergency Vehicle Turn Arounds.
EC 9.6830 Intersections of Streets and Alleys.
EC 9.6835 Public Accesswavs
EC 9.6840 Reserve Strips
EC 9.6845 Special Safety Requirements
EC 9.6850 Street Classification Map.
EC 9.6855 Street Names.
EC 9.6860 Street Right-of-Way Map
EC 9.6865 Transit Facilities.
EC 9.6870 Street Width.
EC 9.6873 Slope Easements.
EC 9.6875 Private Street Design Standards.
The site is fully developed with a church facility, parking lot and playground. The proposal is to
place a cell tower on the site with associated equipment room attached directly to the existing
building. The site is fully served by transit facilities on West Amazon, directly adjacent to the
parking lot. No new roads, streets or alleys are proposed or required.
(f) Where the proposal is to establish non-residential uses subject to residential
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Attachment A
density requirements on development sites in the residential zone category, it
shall achieve the minimum and maximum density requirements in accordance
with Table 9.2750 Residential Zone Development Standards, unless specifically
exempted elsewhere in this code or granted a modification through an
approved conditional use permit. For purposes of calculating "net density,"
the acreage of land considered shall include the entire development site and
exclude public property, such as public streets, parks, and other public
facilities. In considering whether to grant a modification to the density
requirements, the hearings official shall evaluate the following factors:
RESPONSE: Table 9.2750 lays out a 0-14 unit density requirement for R-1 zones. Per 9.2751(b)
"net density" is the number of dwelling units per acre of land in actual residential use and
reserved for the exclusive use of the residents in the development, such as common open space
or recreation facilities. As there are no residential dwellings on the property, nor is residential
development sought by this application, this site meets the minimum density requirements of
zero.
No modifications to these standards are requested. Thus, the criteria for modifications are
not included in this analysis.
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Attachment B
The application materials for New Cingular Wireless Crossfire Church (CU 14-3) are lacking
sufficient information to evaluate and determine compliance with the applicable
telecommunication standards at Eugene Code (EC) 9.5750. The code standard is provided in
bold with staff concerns identified under each.
9.5750 Telecommunication Devices-Sitine Reauirements and Procedures.
(1) Purpose. The provisions of this section are intended to ensure that
telecommunication facilities are located, installed, maintained and removed in a
manner that:
While purpose statements are not directly applicable as approval standards, it would be
helpful for context to have the applicant respond to these. In particular, staff is still concerned
that the applicant may not have exhausted other collocation alternatives. Page 4 of the
applicant's written statement has minimal discussion and raises questions or makes
comments like "due to zoning ordinances prohibiting the location" as a reason for not
considering light and utility poles. Staff would like to get more information and discuss the
applicant's efforts to collocate in the area before entirely ruling out alternatives. Consistent
with the City's telecom ordinance, collocation is certainly preferable to a new tower when
possible.
(a) Minimizes the number of transmission towers throughout the
community;
RESPONSE: The Applicant looked at all existing towers within 1.5 miles of the
proposed site in an effort to collocate, rather than seeking to build a new transmission
tower in the City. It should be noted that collocation reduces construction costs for
the Applicant and is always considered before a new tower. Of the 4 towers
identified, AT&T has already collocated antennas on the three towers to the west of
the side (each about 1.3 miles away); and the tower to the south of the site, at 1.2
miles away, is too far away to reach AT&T's 4G LTE 700 coverage gap. See Att. 11 (RF
Justification).
(b) Encourages the collocation of telecommunication facilities;
RESPONSE: The proposed facility is designed to accommodate two carriers so that another
carrier could collocate at the site, rather than construct its own new support structure in the
area.
(c) Encourages the use of existing buildings, light or utility poles or water towers
as opposed to construction of new telecommunication towers;
RESPONSE: The Applicant has examined all existing buildings, light and utility poles, and
water towers in the area looking for collocation opportunities.
Buildings: Most of the buildings in the search ring are residences, which are unsuitable for
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Attachment B
antenna collocation and prohibited under the EC. The other nonresidential buildings within
and near the search ring do not have the height necessary to distribute radio frequencies for
improved service, and a rooftop extension of any of these shorter buildings would have a
much greater visual impact because the mass and scale of the building would be substantially
smaller than the extension and antennas required to fill the coverage gap. The proposed
monopine matches the mass and scale of existing nearby trees on and around the proposed
Property)
Light & Utility Poles: AT&T thoroughly explored the possibility of extending and collocating on
an existing light or utility pole within the search ring, but found that there were no feasible
options in this category.
Generally, the City's Telecommunication Facilities in the Right-of-Way Policies are not
favorable toward a WCF-supporting replacement structure in the ROW at the sites of either of
the above-mentioned light standards. The Guidelines note that a replacement structure
should (1) look similar to the structure that it replaces and (2) if in an R-1 zone, may be
extended to a maximum height of 75 feet. The Applicant would be unable to meet these
Guidelines and still fill its coverage gap.
A stealth tower designed to look like alight standard requires flush-mounted antennas. The
design for a pole collocation to include flush-mounted antennas to mitigate visual impact
would require additional height because only half of the required number of 8-foot-tall
antennas would fit around the circumference of the pole, and the other half would need to be
installed in a second tier up to 10 feet above the minimum required 70 foot height, requiring a
total height of least 88 feet (13 feet above the 75 foot height limit under the EC).
An alternative to a stealth design would be to place an undisguised monopole at the site, with
an attached replacement streetlight painted a non-reflective neutral color to match the
immediate surroundings. This alternative has far greater visual impact and greater potential
to affect the character of the surrounding residential neighborhood.
The utility poles in the search ring all have live power lines, and were eliminated for
collocation because The Eugene Water and Electric Board (EWEB) prohibits collocation of
communications facilities on utility poles with live power lines.
See also, Alternative Site Analysis table at Response to EC 9.5750(6)(c)(2).
Water Towers: There are no water towers in the search ring for this site.
See, alternative site analysis table below.
(d) Recognizes the need of telecommunication providers to build out their
systems over time; and
RESPONSE:: AT&T is currently upgrading its network across the Pacific and recognizes that a
strategically placed WTF that fully addresses a particular coverage gap (rather than
Completeness Review: New Cingular Wireless - Crossfire Church (CU 14-3) 18
Attachment B
significantly overlapping with existing coverage) is a key strategy to avoid the need for
additional towers.
Ensures that all telecommunication facilities, including towers, antennas, and ancillary
facilities are located and designed to minimize the visual impact on the immediate
surroundings and throughout the community, and minimize public inconvenience and
disruption.
RESPONSE: The Applicant has proposed a monopine design that most effectively minimizes
the visual impact on the immediate surroundings. This design will integrate visually into the
existing landscape. See Att. 10 (Photo Simulations). Once constructed, the facility would not
cause public inconvenience or disruption; noise will be mitigated to city standards, minimal
vehicular access is required and will not impede vehicular, bicycle or pedestrian traffic.
Existing access to local utilities will meet the needs of the facility.. See Att. 07 (Sound Study)
and Att. 14 (Utility Coordination Report). The proposed project would add public convenience
by improving wireless coverage in the area.
Nothing in this section shall apply to amateur radio antennas, or facilities used
exclusively for the transmission of television and radio signals.
(6) Application Requirements.
(b) Construction of Transmission Tower. In addition to standard required
application material, an applicant for a transmission tower shall submit the
following information; additional application material is required, as specified
in paragraph (c) below, for applications requiring a site review or conditional
use process:
1. A description of the proposed tower location, design and height.
The location is shown on the site plans (Sheet SV1). Elevations are shown (Sheet A-3.0), but
distance from grade to lowest branches is missing. Please provide this information. Also,
dimension the adjacent building to provide a clearer determination of scale. Additional
measurements including setbacks from all property lines and homes, and the relationship of the
tower to existing trees on the site should also be provided on the site plans and elevations.
Plan note says "Antennas to be painted green to match monopine." Please provide paint color
samples for the pole and faux branches, and discuss the color choice in context with the
surroundings.
RESPONSE; A sample piece of bark, branch and foliage is being submitted with this application.
Index at Att. 15 (Samples). The samples are earth-toned and green, as are the surrounding trees
in the area. The match to the existing trees is appropriate. When viewed up close, these appear
manmade, but this would not be apparent when viewed from a distance, as a greater part of
the landscape. Given the context of the surroundings, the colors and textures of the cell tower
are as close a companion to the existing colors and textures in the surroundings as can be
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Attachment B
expected.
The design is required to reasonably blend in with the surroundings and the photo simulation
"View from Amazon Drive" shows that the tower will be about the same height and shape as
the nearby fir tree. Since that tree appears to be on the same property, staff requests that the
applicant gather actual samples of the branches and bark and compare that to the proposed
tower; also, submit a sample of the tower (as an oversized exhibit), which was provided by
AT&T on another case. Provide as much comparative information as possible, like the height of
that tree compared to the tower and the distance between the two.
The tower seems to really stick out in the photo simulation entitled "Intersection of Amazon
Drive and Fox Hollow Road." The tower sticks out amongst the shorter, deciduous trees along
the street. Is there room to plant more fir trees in that area to create an atmosphere that
softens the bulk and scale of the tower? The arborvitae proposed around the fence enclosing
the ancillary facilities seem to only emphasize the monotony; would another plant mix with a
variety of species help create a better blending effect? The applicant should consider additional
screening that may be needed beyond the perimeter of the tower and equipment, depending
on visual impacts from nearby homes and other strategic locations a long the property lines
that would help to buffer the facility.
RESPONSE. Regardless of color and height the proposed monopine does a great job of blending
into the context within which it sits. There is an existing stand alone tree on the site that is even
taller than this one. And yet, one wouldn't point at it and say it stands out because it is real. The
cell tower is the best approximation of the surrounding vegetation that a man made object can
achieve. Once it is constructed and the focus is no longer one of "looking directly at the
monopine from one viewpoint" it will "disappear into the context like all the other offending
elements that have been placed there (i.e. utility poles, bad architecture, dilapidated homes,
fences in disrepair, transformer boxes, electrical wires, etc.)
The photo simulation entitled "View NE from Dillard and Fox Hollow" shows the top of the
tower branches rising above the tree-lined ridgeline. Conversely, there's a power pole in the
area that appears to be taller. It may be helpful to put those two features into perspective with
the tower - being a utility. Is there any way to vary the branch alignment to more closely
resemble the tree canopy on the horizon? Again, the application needs to better address the
proposed design in context with surrounding features.
RESPONSE:` AT&T proposes installation of a 75 foot monopine located at the southeast corner
of church property at 4060 West Amazon Drive in an R-1 Low Density Residential zone. As
described above, the mass and scale of the proposed monopine would match the mass and scale
of 4 adjacent pine trees: a 100 foot tall pine tree about 125 feet to the south; 2 49-foot-tall pine
trees about 75 feet to the southeast, and a 63 foot tall pine tree about 75 feet to the north. See
Att. 04 (Site Plan, Sheets SV1 and L1.0) and Att. 10a (Photo Simulations). The branches toward
the top of the monopine would come to a short, round taper, rather than the steep taper seen
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Attachment B
on most of the existing evergreen trees in the area. This is because a more gradual taper would
require additional height, which would preclude compliance with the 75 foot height limit for the
proposed WTF in an R-1 zone under EC 9.5750(7)(b)5. (The top of the antennas must be at 70
feet to meet AT&T's coverage objectives, and the Applicant has already added 5 additional feet
to the height to allow for taper). As demonstrated by Att. 15 (Samples & Photos), the branches
and trunk of the monopine would match the colors of existing trees near the property. (Staff
has agreed to the Applicant's submittal of close-up photos of nearby trees, rather than a
collection of branch and bark samples.
The entire monopine would be surrounded by a 6 -foot tall cedar fence and a landscaping buffer.
See Att. 04 (Site Plan, Sheets A-3.0, A-3.1 and Sheet L1.0). The landscaping buffer has been
revised to include a variety of plants typical to residential garden design. The type, variety, and
size will create a place of visual interest and be more in keeping with landscaping typically found
in the surrounding neighborhood. This further mitigates the visual impact of the proposed
monopine by softening the bulk and scale of the tower compared to several shorter, deciduous
trees, and mitigating the visual impact from adjacent properties.
Additionally, as noted in a conversation with Eugene Planner Becky Taylor, the photo
simulations submitted are static images. The shortcoming of these is that they presume that this
is how something is viewed. But people typically view their surroundings is as a whole. They see
foreground, middle ground, background and everything in between, and they scan their
surroundings based on where they are going-where they are placing their feet if they are
walking, or if driving or cycling the direction they're steering, traffic signals and signs,
pedestrians, bicyclists, etc. This monopine would be no more visible in the landscape than the
EWEB utility poles, transformers, backflow prevention devices and other elements we consider
less appealing on an aesthetic level.
The existing trees on the site are mostly individual trees and "stick out" somewhat, because they
are not in a grouping. Yet, the view of these individual trees is not undesirable. The monopine,
with its green foliage and dark earth tone bark, would blend into the surroundings better than
the stand-alone utility poles with transformers and cobra-head lights.
All associated equipment would be located in a proposed equipment shelter designed to look
like an extension of the existing church building. It would be constructed flush against the
existing building; and sided, roofed, and painted to match. Details of the design are shown at
Att. 04 (Site Plan). The shelter would be lined with baffling to mitigate any sound from the air
conditioning unit and emergency generator. See Att. 07 (Sound Study).
This smaller addition to the church actually mitigates the large blank south face of the church. In
this manner the architecture is improved and the south side of the building has a more
pedestrian scale, providing articulation and visual interest. Additionally, there would be
plantings around these new walls, further lending the project to blend in with the residential
character of the neighborhood.
2. The general capacity of the tower in terms of the number and type of
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Attachment B
antennas it is designed to accommodate.
The explanation to this standard (page 8 of the applicant's written statement) appears to only
discuss carriers, not the number and type of antennas. Please provide more information about
the full extent of collocation and what those visual impacts might be with the maximum
amount of collocated antennas.
RESPONSE. The proposed monopine is designed to accommodate two carriers. The proposed
.
project includes 12-panel antenna array (3 sectors at 4 antennas each) at an antenna tip height of
70 feet, and a smaller microwave antenna below. See Att. 04 (Site Plan, Sheets A-3.0 and A-3.1). The
proposed monopine could accommodate an additional carrier's 12-panel antenna array and an
additional microwave antenna below. The design and type of antennas would be chosen by the
additional carrier and would be subject to the permitting process and the city's evaluation of the
visual impacts at that time.
3. Documentation demonstrating compliance with non-ionizing
electromagnetic radiation (NIER) emissions standards as set forth by the
Federal Communications Commission (FCC).
Submitted report from Hatfield & Dawson, Consulting Electrical Engineers.
No additional response.
4. A signed agreement, as supplied by the city, stating that the applicant
will allow collocation with other users, provided all safety, structural,
and technological requirements are met. This agreement shall also state
that any future owners or operators will allow collocation on the tower.
Applicant states that they will sign an agreement if supplied by the City.
No additional: response.
S. Documentation that the ancillary facilities will not produce sound levels
in excess of those standards specified in subsection (7) of this section,
or designs showing how the sound is to be effectively muffled and
reduced pursuant to those standards.
The applicant submitted a report prepared by SAA Acoustics. It implies that the greatest sound
generator is from the air-conditioning unit. Are there other devices, like a generator? On
another case, the generator was the greatest sound producer. The noise level provided is 73
dBA, which exceeds the 4S dBA code limitation. The factors for "predicting" noise level
reductions were just the building edge and distance. Even with those factors, the dBA is only
reduced to the maximum allowable. It seems like more sound mitigation is necessary. For
example, how much sound reduction would occur if the equipment were enclosed in a building
or installed underground?
Completeness Review: New Cingular Wireless - Crossfire Church (CU 14-3) 22
Attachment B
As noted previously, it is unclear whether the requested underground variance would be
granted without more information to justify the request, particularly related to noise and visual
impacts in a residential area. In any event, it seems critical to have comparative evidence about
the effects of undergrounding. For example, would undergrounding require other noise
generating equipment like an elevator? This would also need to be measured and addressed in
the event that undergrounding may be required; alternatively, the applicant should consider an
underground vault design that does not require additional sound generating equipment, or
provide additional sound buffering as necessary.
In another recent case (AT&T at Oakway Golf Course, a.k.a. Northgreen Properties v. City of
Eugene), the variance for undergrounding ancillary facilities was denied; as such, the applicant
was required to submit a revised noise study to demonstrate compliance without the variance.
Assuming that could happen in this case, please provide noise studies under both scenarios.
That could be definitive evidence about the basis for a variance.
RESPON k: The proposed ground equipment includes AC units and an emergency generator, which
would both be fully enclosed within a sound-baffled equipment shelter, built to look like a seamless
extension of the church building. The AC units would run intermittently to cool equipment. The
emergency generator would run only in emergencies and for about 10 consecutive minutes during
monthly testing. The proposed design incorporates additional baffling sufficient to reduce the sound
from the AC units to 35 dBA, well below the 45 dBA code limit for R-1-zoned properties. Because the
proposed generator would run for such a short amount of time during daytime hours, it would not
be considered a noise disturbance under the code even if the noise level briefly exceeds 45 dBA. (Per
Matt Denberg, City of Eugene Code Compliance, Oct. 22, 2014. See generally, EC 6.750(b).)
However, to minimize the noise levels from the generator, it would be enclosed within the sound-
baffled equipment shelter. See Att. 07 (Sound Study) and Att. 04 (Site Plan, Sheet A-2.0).
6. A landscape plan drawn to scale showing proposed and existing
landscaping, including type, spacing, size and irrigation methods.
The proposed landscaping around the tower is shown, but it does not appear adequate to
meet the screening requirements. The landscape of the surroundings needs better
illustration, particularly if this tree design is intended to blend in with surroundings, which
would typically mean other trees. Is there a more vegetated portion of the site that would be
a better location?
RESPONSE: There is not a more vegetated portion of the site. The majority of the trees stand
individually and not in groupings. By placing the monopine near the existing church, it sits
individually on the site just as all the other trees do. Having it stand along the reference point
of other trees to this tree is more at a distance and stands to allow the tree to fade into the
less focused field of view. The proposed 75 foot monopine location is adjacent to 4 other stand-
alone mature pine trees, at 100, 63, 50, and 48 feet tall, making the location favorable for
mitigating visual impact.
The base of the monopine and equipment room are screened by both the existing topography
Completeness Review: New Cingular Wireless - Crossfire Church (CU 14-3) 23
Attachment B
and the proposed fencing and landscaping. The play area is at an elevation of 468 to 470
feet. The proposed equipment room will be placed below this, at elevation 464 feet. For
approximately 213 of the view looking north from Fox Hollow the equipment room is screened
by this landform that is 4' - 6' higher than the finish floor elevation of the proposed room.
The proposed fencing is 6' tall fully obscures the base of the monopine. The fenced area
would be surrounded by plantings typically found in a residential neighborhood, further
enhancing the screening.
Appropriate and quality planting also acts in another way. If it is attractive enough and well
maintained then something that is pleasing also draws the eye. While the focus of this
application is on the cell tower, the focus of the individual will also be on all of the
surroundings.
The monopine does a good job of "screening itself" (that is the purpose of a monopine design
as opposed to a naked monopole). And the elevation change of the site, although slight, is an
advantage when trying to screen the exposed area of the monopine. As you can see from the
elevation on the plans, the existing trees along the perimeter of the parking lot screen the cell
tower the viewpoint of passers-by.
This is also a mature neighborhood and the trees on the surrounding properties are quite
thick. In addition, the Amazon Canal that runs down the middle of East and West Amazon
Parkway also contains mature trees. The fact that this monopine is placed in a neighborhood
with mature vegetation contributes to screening as well.
The cell tower is not going to disappear. Anyone can see it if they stand still and look for it.
But given the existing topography, proposed landscaping, existing mature trees and existing
evergreen backdrop, as well as the monopine design itself, the proposed project does a good
job of blending the proposed development into the existing surroundings.
The Applicant has submitted arboriculture information that describes the vegetation on the
property and has prepared a revised landscape plan that provides additional screening around
the facility, as well as irrigation methods. See Att. 04 (Site Plan, Sheets L1.0 and L2.0).
7. Plans showing the connection to utilities/right-of-way cuts required,
ownership of utilities and easements required.
Shown.
No:additional response.
.
8. Documents demonstrating that necessary easements have been
obtained;
Applicant states that easements will be included in the lease of the property.
No additional response.
Completeness Review: New Cingular Wireless - Crossfire Church (CU 14-3) 24
Attachment B
9. Plans showing how vehicle access will be provided;
Shown.
No additional response.
10. Signature of the property owner(s) on the application form or a
statement from the property owner(s) granting authorization to
proceed with development permit and land use processes;
The property owner has signed the application form.
No, additional `response:
11. Documents demonstrating that the FAA has reviewed and approved the
proposal, and Oregon Department of Aviation has reviewed the
proposal. Alternatively, when a site review or conditional use process is
required, submit a statement documenting that notice of the proposal
has been submitted to the FAA and Oregon Department of Aviation.
The site review or conditional use process may proceed and approval
may be granted for the proposal as submitted, subject to FAA approval.
If FAA approval requires any changes to the proposal as initially
approved, then that initial approval shall be void. A new application will
need to be submitted, reviewed and approved through an additional
site review or conditional use process. No development permit
application shall be submitted without documents demonstrating FAA
review and approval and Oregon Department of Aviation review.
A letter from the Oregon Department of Aviation dated January 24, 2014 confirms that an
aeronautical study resulted in the determination that notice to the FAA is not required and that
no marking or lighting are necessary for aviation safety.
No additional response:
(c) Site Review and Conditional Use Permit Applications. In addition to the
application requirements specified in paragraph (b) above, applications for
site review or conditional use permits also shall include the following
information:
1. A visual study containing, at a minimum, a graphic simulation
showing the appearance of the proposed tower, antennas, and
ancillary facilities from at least 5 points within a 3 mile radius. Such
points shall be chosen by the provider with review and approval by
the planning director to ensure that various potential views are
represented.
Completeness Review: New Cingular Wireless - Crossfire Church (CU 14-3) 25
Attachment B
The initial visual study provided is insufficient. The photo simulations provided cast serious
doubt about compatibility with the surroundings. The quality is poor, looking more artificial and
even "cartoonish" than an actual, accurate representation. The number of photos and locations
is also deficient. The applicant needs to provide more extensive analysis of the visual impact
from nearby homes and other potential viewpoints in the area. In addition to photo simulations
of the tree design, that applicant should also consider including scenarios for an alternate
stealth design such as a monopole with enclosed antennas. Elevations should also be verified
with balloon testing as well, to provide a more credible photo simulation and analysis.
RESPONSE. A revised package of photo simulations that include balloon test photos is provided
at Att. 10 (Photo Simulations). The proposed 75 foot monopine is the least intrusive design
feasible. A monopole with enclosed antennas is not feasible at this location because this would
require about 6 feet of additional height to accommodate two tiers of flush-mounted antennas,
thus exceeding the 75 foot height limit for the R-1 zone. Fewer antennas fit around a pole when
flush mounted, so they would have to be separated into two tiers of 8 -foot tall antennas with up
to 10 feet of separation distance. Since the minimum antenna tip height of the bottom tier
would remain at 70 feet, the tip height of the antennas in the top tier would be 88 feet 13 feet
over the maximum height allowed.
2. Documentation that alternative sites within a radius of at least 2000
feet have been considered and have been determined to be
technologically unfeasible or unavailable. For site reviews,
alternative sites zoned C-4,1-1,1-2, and 1-3 must be considered. For
conditional use permits, alternative sites zoned PL, C-2, C-3, C-4, 1-1,
1-2,1-3 and S-WS must be considered.
Does the table provided on pages 10 and 11 of the applicant's statement include all sites zoned
PL, C-2, or C-2 within 2,000 feet?
RESPONSE: Based on an extensive RF design analysis, a search ring was issued to locate a site
to fill a significant low band 4G LTE (700 MHz) coverage gap and improve service in the area
around Fox Hollow and Amazon Drive. The area at the center of the search ring is zoned R-1,
with one Public Lands-zoned (PL) parcel at the northeast edge of center. This PL-zoned property
is Kincaid Park and is discussed in the table below. There is a C-2 zone west of the search ring,
which is also addressed below.
Significant deviation from the center of the search ring would make any attempt to fill the 4G
LTE coverage gap in the area ineffective. See the April 30, 2014 Statement of Compliance,
Section 3.2 (Site Selection), for further explanation about AT&T's site selection process.
The table below outlines the analyses of sites considered. The alternative sites considered
include sites zoned PL, C-2 and R-1. There are no C-3, C-4, 1-1, 1-2, 1-3 or S-WS zones in or near
the search ring.
Alternative Sites Within 2000 Feet
Completeness Review: New Cingular Wireless - Crossfire Church (CU 14-3) 26
Attachment B
Property Type
Description
Summary
Existing
1
Existing Eugene Water and
Per Jamie Breckenridge, Utility Joint Use
Structures
Electric Board (EWEB) poles
Coordinator at EWEB, it is EWEB policy to allow
within the search ring
communication facilities only on poles with no live
power lines. All EWEB poles in this area carry live
Zoned R-1 (Low Density
power lines except the two light poles noted
Residential); Water
below.
Resource overlay
2
Existing 30' Light Pole in
Extension of and co-location on an existing light
ROW along West Amazon
pole would require height above the 75 foot height
Drive; and
limit for an R-1 zone.
3
Existing 30' Light Pole in
Additionally, light pole along Dillard & Fox Hollow
ROW along Dillard & Fox
Roads is not a viable location per EWEB policy
Hollow Roads.
prohibiting co-location on poles hosting live power
lines. (See above.)
Zoned R-1 (Low Density
Residential)
Raw Land
4
Kincaid City Park
Conversations with Pam Berrion,
Sites
Telecommunications & Cable Program Manager,
Zoned PL (Public Lands)
indicated that there is no process for leasing space
to wireless carriers in city parks. Further, staff at
the pre-application meeting indicated that this
location would not be ideal as it would be more
visually impactful than the site proposed.
5
Parker Elementary School
Belongs to the 4J school district. The 4J School
(adjacent to Kincaid Park)
District was not interested in leasing space for
wireless facilities on any of their properties.
Zoned PL (Public Lands)
6
Emerald Valley Assisted
Property owners did not return AT&T's multiple
Living Residence (located
calls regarding leasing.
just outside of search ring
to the south)
Zoned C-1 (Neighborhood
Commercial)
In summary, there are no feasible alternative sites in PL, C-2, C-3, C-4, 1-1, I-2, 1-3 and S- WS
zones that would fill the subject 4G LTE (700 MHz) coverage gap.
Completeness Review: New Cingular Wireless - Crossfire Church (CU 14-3) 27
Attachment B
3. Evidence demonstrating collocation is impractical on existing tall
buildings, light or utility poles, water towers, existing transmission
towers, and existing tower facility sites for reasons of structural
support capabilities, safety, available space, or failing to meet
service coverage area needs.
The reference to utility pole height "guidelines" is not an absolute barrier. This should be
investigated further.
RESPONSE. AT&T investigated the option of collocating on an existing tall building, utility or
light pole, and existing transmission towers, but did not find any feasible options. See thorough
explanation in the Response to EC 9.5750(1)(c), above.
4. A current overall system plan for the city, showing facilities presently
constructed or approved and future expansion plans.
Provided.
NO.additional response.
.
S. A statement providing the reasons for the location, design and
height of the proposed tower or antennas.
Provided.
No additional response:
(7) Standards for Transmission Towers and Antennas. Installation, construction or
modification of all transmission towers and antennas shall comply with the following
standards, unless a variance is obtained pursuant to the provisions of subsection (9) of
this section:
(a) Separation Between Transmission Towers. No transmission tower may be
constructed within 2000 feet of any pre-existing transmission tower. Tower
separation shall be measured by following a straight line from the portion of
the base of the proposed tower which is closest to the base of any pre-
existing tower. For purposes of this paragraph, a tower shall include any
transmission tower for which the city has issued a development permit, or
for which an application has been filed and not denied. Transmission towers
constructed or approved prior to February 26, 1997 may be modified to
accommodate additional providers consistent with provisions for collocation
in this section.
Applicant confirms no towers within 2,000 feet.
No additional "response.
Completeness Review: New Cingular Wireless - Crossfire Church (CU 14-3) 28
Attachment B
(b) Height Limitation: Transmission tower heights shall be governed by this
section except as provided for below. No transmission tower shall exceed the
maximum heights provided below. In no case shall a variance be granted
from the limitations of subparagraphs (1) through (4) below.
5. If located within an R-1 zone, the maximum height of a transmission
tower, including antennas, is 75 feet, unless a variance is granted
pursuant to the provisions of subsection (9) of this section. In no
event shall a variance be granted to construct such a tower in excess
of 100 feet.
Proposed height is 75 feet.
No additional response.
(c) Collocation. New transmission towers shall be designed to accommodate
collocation of additional providers:
2. New transmission towers of a height of at least 60 feet and no more
than 80 feet shall be designed to accommodate collocation of a
minimum of 1 additional provider either outright or through future
modification to the tower.
Applicant confirms that the tower can accommodate 2 additional providers. Please provide
additional information as noted above about visual impacts with the maximum amount of
collocated antennas and related equipment.
RESPONSE. Collocated antennas would be installed below AT&T's antennas and would also be
screened by the monopine branches. Either AT&T or the city could condition any collocation on
the collocator's agreement to paint the antennas to match the monopine trunk or branches.
The site plans show the estimated mass of a collocator's antennas. See Att. 04 (Site Plans, Sheet
A-3.0).
(d) Setback. The following setbacks from adjacent property lines and
adjacent streets shall be required unless a variance is granted pursuant
to the provisions of subsection (9) of this section:
If located within an R-1,C-1,or GO zone, the transmission tower shall
be set back from adjacent property lines a minimum number of feet
that is equal to the height of the transmission tower.
3. In the 11-1,13I,C-land GO zones, transmission towers shall be set back
from adjacent public street(s) a minimum number of feet that is
equal to the height of the tower. In all other zones, the setback
from adjacent public streets shall be a minimum of 25 feet.
Completeness Review: New Cingular Wireless - Crossfire Church (CU 14-3) 29
Attachment B
Sheet A-1.0 clearly shows the tower set back 75 feet from the street, but the distance to
property lines needs to be called out. The dashed "tower setback" line doesn't appear to be to
the same scale to the rear property line.
RESPONSE: The site plans have been revised to address these issues. See Att. 04 (Site Plans).
The proposed facility has a setback from all adjacent property lines of at least 75 feet, which is
equal to the total height of the proposed tower.
(e) Buffering. In all zones, existing vegetation shall be preserved to the maximum
extent possible. In the C-4, 1-1,1-2 and 1-3 zones, no buffering is required
beyond that required by this land use code. In all other zones, landscaping
shall be placed completely around the transmission tower and ancillary
facilities located at ground level except as required to access the facility. Such
landscaping shall consist of evergreen vegetation with a minimum planted
height of 6 feet placed densely so as to form a screen. Landscaping shall be
compatible with other nearby landscaping and shall be kept healthy and well
maintained.
Arborvitae hedges surround the facility, but as noted above, about compatibility with
surroundings, more and different landscaping may be necessary.
RESPONSE. The landscape plans have been revised to address these issues. See Att. 04 (Site
Plans, Sheets L1.0 and L2.0). The plantings have been revised to be more representative of
typical residential planting design. There is a variety of species as well as a variety of foliage
texture, seasonal color, height and width. Additionally, the mature trees and existing vegetation
along the perimeter of the property would be preserved to buffer the view of the site from
adjacent properties. The Applicant's Landscape Plan would augment this buffer, further
mitigating any visual impacts. This project is also in a neighborhood full of mature trees. The
neighbors' own trees will help screen and mitigate any visual disruption to their view from their
homes.
(f) Noise Reduction. In R-1, R-2, R-3, R-4, C-1, and GO and in all other zones when
the adjacent property is zoned for residential use or occupied by a dwelling,
hospital, school, library, or nursing home, noise generating equipment shall
be sound-buffered by means of baffling, barriers, or other suitable means to
reduce sound level measured at the property line to 45dBa.
The noise analysis doesn't include any other sound-buffering means, like baffling, other than
distance. And at that, it's just at the limit and based on a prediction. This evidence would be
weak under opposing evidence, of which we've seen plenty of from this neighborhood. See
previous comments about the need for additional information, analysis, and sound buffering
alternatives.
RESPONSE: Sound from the proposed WCF would come primarily from the proposed air
conditioning unit (AC) or emergency generator. The AC would run intermittently as required to
Completeness Review: New Cingular Wireless - Crossfire Church (CU 14-3) 30
Attachment B
cool the equipment. The emergency generator would produce noise only during emergencies
and during routine monthly testing (for 5-10 minutes per test). The proposed equipment shelter
design has been revised to include sound baffling to reduce the sound to 35 dbA. See Att. 07
(Sound Study).
(g) Status of Location. No permit may be issued for the location of a new
telecommunications facility within an R-1 or C-1 zone unless the lot on which
it is to be placed is vacant or developed with a non-residential use at the
time the permit application is submitted. This restriction does not apply
within other zones.
The R-1 property is developed with a church. Are there any residential uses on the site?
RESPONSE. This proposal is located on a property zoned R-1 currently developed with a non-
residential use, a Church. There are no residential uses on the Property.
(h) Li htin . No lighting shall be permitted on transmission towers except that
required by the Federal Aviation Administration. No high intensity white
lights may be located on transmission towers in an R-1, C-1, or PRO zone.
Clarify lighting. So the tower won't be lit, but what about the equipment area?
RESPONSE- There is no lighting proposed on the monopine, within the fenced area at the base
of the monopine, or on the exterior of the auxiliary equipment shelter. There would be lighting
inside of the equipment shelter, but this would not be visible from the outside.
(i) Color. The transmission tower and attached antennas shall be unpainted
galvanized steel or painted neutral colors or such shades as are appropriate
and compatible with the surrounding environment, as approved by the city.
This standard was developed for a reason. It would be helpful to provide photo simulations of a
tower that meets this standard to determine whether the "stealth" design is any better.
RESPONSE. The antennas and monopine branches would be a neutral green and the support
structure "trunk" would be brown to match the existing trees in the immediate vicinity. See Att.
10 (Photo Simulations) and Att. 15 (Samples & Photos).
(j) Viewshed. The transmission tower shall be located down slope from the top
of a ridgeline so that when viewed from any point along the northern right-
of-way line of 18th Avenue, the tower does not interrupt the profile of the
ridgeline or Spencer Butte. In addition, a transmission tower shall not
interrupt the profile of Spencer Butte when viewed from any location in
Amazon Park. Visual impacts to prominent views of Skinner Butte,ludkins
Point, and Gillespie Butte shall be minimized to the greatest extent possible.
Approval for location of a transmission tower in a prominent view of these
Buttes shall be given only if location of the transmission tower on an
Completeness Review: New Cingular Wireless - Crossfire Church (CU 14-3) 31
Attachment B
alternative site is not possible as documented by application materials
submitted by the applicant, and the transmission tower is limited in height to
the minimum height necessary to provide the approximate coverage the
tower is intended to provide.
The proposed tower doesn't appear to be within these view sheds.
No`odditional response.
(k) Display. No signs, striping, graphics or other attention getting devices are
permitted on the transmission tower or ancillary facilities except for warning
and safety signage with a surface area of no more than 3 square feet. Such
signage shall be affixed to a fence or ancillary facility and the number of signs
is limited to no more than 2.
Applicant states there will be none.
No additional response.
(8) Standards for Ancillary Facilities. All ancillary facilities shall comply with the
standards of subsections (7)(e) and (7)(f) of this section. In addition, all ancillary
facilities within an R-1,PL, C-1,GO, and PRO zone must be located underground to
the maximum extent technology allows, unless a variance is obtained pursuant to
the provisions of subsection (9) of this section. This restriction does not apply within
other zones.
As noted previously, the ability to obtain a variances questionable. In response to the standard
above, provide information about the technological feasibility of undergrounding and consider
proposing it an alternative design (along with a noise study that addresses an underground
design) in the event that a variance is denied.
RESPONSE. The Applicant seeks a variance to place the ancillary facilities for this project
aboveground, pursuant to the specific variance criteria listed in subsection (9) below. The
applicable criteria for the variance to the undergrounding requirement are contained in (9)(c)
and subject to review as outlined in (9)(a) and (9)(e). Staff has agreed that a noise study that
addresses an underground design is not necessary at this time.
(9) Variance.
(c) The city may grant a variance to the setback and undergrounding
requirements of subsections (7)(d) or (8) upon finding that stealth
design, proposed landscaping, configuration of the site, or the presence
of mature trees obviates the need for compliance.
The requested variance for not undergrounding the ancillary facilities is not sufficiently
supported by the application materials. Please refer to the case involving the Oakway Golf
Completeness Review: New Cingular Wireless - Crossfire Church (CU 14-3) 32
Attachment B
course, in which the variance was denied (City file numbers PDT 10-2 and CU 11-1).
RESPONSE. AT&T requests a variance to the undergrounding requirement based on (1) the
practical difficulties and safety issues related to undergrounding ancillary equipment at this site;
(2) the proposed, stealth design and landscaping of the equipment enclosure and (3) the
planned use of noise baffling within the shelter.
AT&T is required to equip certain telecommunication facilities with an emergency power supply
in the case of a disaster that cuts off local power supply to the facility. Emergency generators,
like the one proposed at this site, use a diesel combustion engine to supply power.
Undergrounding a combustion engine poses several safety risks, including the risk of explosion
and risks to maintenance personnel who would have to service combustible equipment in a
confined space. (Maintenance of undergrounded facilities requires at least two maintenance
people, so that one can perform safety checks when the other is servicing equipment.) These
safety risks make undergrounding prohibitive. Additionally, an undergrounded equipment
shelter (compared to an above ground equipment shelter) requires a larger construction
footprint, additional belowground impervious surface, and several above ground ventilators and
air pumps (which could generate additional noise) to provide cooling for the equipment and
resolve air quality issues for maintenance personnel.
The proposed design is a fully enclosed equipment shelter, designed to resemble the existing
church building, with compatible architecture and matching roofing, siding, and paint. The
shelter would be lined with extensive sound baffling to reduce noise produced by the WTF's
ancillary equipment well below the city's limit of 45 dBa at the adjacent property lines. See Att.
07 (Sound Study).
The Applicant would construct the equipment shelter so that part of it is allocated to the
telecommunication facility, and the other part would function as a storage area for the property
owner so that it appears and functions as an extension of the existing church building. Unlike
the Northgreen application, where no generator was proposed, there is an emergency
generator needed for this location. As described above, it is not feasible to locate the generator
underground and its contribution to the noise output is de minimus, as the generator would only
operate during one monthly 5-10 minute maintenance test during daytime hours (7 AM-10
PM). This test can be scheduled at a time designed to have the slightest impact on surrounding
property owners. Of course, in the event of emergency, the generator would operate for the
time required within the heavily baffled equipment enclosure to provide critical wireless service
to the neighborhood during an emergency. See Att. 04 (Site Plan) and Att. 07 (Sound Study).
(10) Removal of Facilities.
(a) All transmission towers and antennas shall be removed by the person who
constructed the facility, by the person who operates the facility, or by the
property owner, within 6 months of the time that the facilities have ceased
being used to transmit, receive or relay voice and data signals to or from
Completeness Review: New Cingular Wireless - Crossfire Church (CU 14-3) 33
Attachment B
wireless communication devices. The city manager may grant a 6-month
extension where a written request has been filed, within the initial 6-month
period, to reuse the tower or antennas.
(b) If a transmission tower is located within an R-1, PL, C-1 or GO zone, the
provisions of subparagraph (a) also shall apply to the tower substructure and
all above ground ancillary facilities.
(c) The city may require the posting of an open ended bond before
development permit issuance to insure removal of the transmission tower,
substructure or antennas after the facility no longer is being used.
The written statement did not provide a response to this standard.
RESPONSE: The Applicant agrees that, if the facility ceases to be used for transmission for
wireless communication devices, the Applicant must remove the proposed tower and all
aboveground ancillary facilities within 6 months unless an extension is granted by the City
Manager. The Applicant understands that the City may require an open-ended bond in order to
ensure removal of the tower.
(11) Application Review and Fees. The city manager shall retain one or more
consultants to verify the accuracy of statements made in connection with an
application for a building or land use permit for a telecommunications facility.
Notwithstanding any other provision of this code, the city manager shall require the
applicant to pay, as part of the application fees, an amount sufficient to recover all of
the city's costs in retaining the consultant(s).
Third-party review of the application will be required. The applicant will be required to pay an
initial deposit to cover the expense, and additional fees may be required. Staff will provide
more information on the required third-party review when revised application materials are
submitted in response to this completeness review.
RESPONSE The Applicant understands from City Planner, Becky Taylor, that third-party review
of this application will be required. The Applicant understands that it will be responsible for a
deposit and additional fees to cover this expense.
Completeness Review: New Cingular Wireless - Crossfire Church (CU 14-3) 34
Technology `t Associates
March 26, 2015
Nick Gioello, Planner
City of Eugene
Planning and Development Department
99 W. 10th Ave.
Eugene, OR 97401
Re: Cingular Wireless at Crossfire Church (CU 14-3)
Received
i.aR 2 7 2015
City of Eugene
Planning Division
Please accept this response to the letter dated November 4, 2014 requesting additional items
for this application. In addition to the below responses, attached please find the following: 1)
revised zoning/landscape drawings; 2) photo simulations; 3) revised RF justification report; 4)
alternate site analysis with declaration; and 5) signing authority for Aaron Taylor of Crossfire
Church.
Please note below are Staff's comments and questions followed by Applicant's responses in
italics. If you have any questions, please contact me at (323) 559-4103 or
iacob.finnev@taec.net.
1. EC 9.8090(1): The proposal is consistent with applicable provisions of the Metro Plan and
applicable refinement plans.
The applicant's October 24th response to staff's May 30th comment regarding Policy E.4 of the
Metro Plan states that the proposed monopine is designed to contribute to the existing
backdrop of other evergreen trees in the area. The site plans, however, show that the trees
abutting the site are primarily maples. The proposed monopine is located in a very visible
location, abutting the parking lot and facing the street. The narrative and supporting photos do
not appear to adequately address how the facility is "designed and located in a manner that
preserved and enhances desirable features of the local and neighborhood areas and promotes
their sense of identity."
7117 SW Beveland Street, Suite 101
Tigard, OR 97223
(323) 559-4103
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Technology ` I t Associates
RESPONSE: The proposed project is located on a parcel surrounded by a variety of existing trees
and vegetation, including red maples, a spruce tree, shore pine, paper birch and Ponderosa pine
trees. The Ponderosa pines are similar height and density as the proposed monopine. To
further enhance desirable features of the area and promote their sense of identity, AT&T is
proposing additional landscape around the base of the monopine and the proposed building
extension which will house ancillary equipment. The proposed landscaping (Att.1) as shown on
plans includes a variety of vegetation and shrubbery as well as vine maples.
The desirable features of the surrounding neighborhood include a variety of flora, mature
evergreen trees and deciduous trees. The proposed monopine and additional landscaping will
preserve the desirable features of the neighborhood by contributing the abundant flora and
mature trees. Additional photo simulations (Att. 2) clearly demonstrate the abundance and
f variety of vegetation, including native trees and shrubs, surrounding the subject property.
' 2. EC 9.8090(2) The location, size, design, and operating characteristics of the proposal are
reasonably compatible with and have minimal impact on the livability or appropriate
r development of surrounding property, as the relate to the following factors:
t (a) The proposed building(s) mass and scale are physically suitable for the type and
l density of use being proposed.
The statement says the monopine is designed to look like other evergreen trees in the
immediate area, but the site plans show few evergreen trees in close proximity. The
additional photo simulations help support the argument about there being a
backdrop of trees, but it appears that these photos were taken at strategic locations,
rather than representing actual impacts. This criterion is about the location of the
facility to minimize impacts on surrounding properties. As noted above, the narrative
and supporting photos simulations don't appear to accurately describe the setting,
nor do they fully address how the facility will be reasonably compatible with
surrounding properties who would view the tower without any backdrop of trees. It
may be helpful to review the Rest Haven cell tower findings, which provide extensive
discussion of this criterion.
7117 SW Beveland Street, Suite 101
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The statement also concludes that the ancillary equipment shed will look like an
extension of the chapel. This needs to be illustrated and better explained as to how
it fits within the area in terms of mass and scale and impact on the surroundings. The
supplemental information only shows a side view {View #10). What does the building
addition look like from West Amazon Road?
RESPONSE: The landscape plans of the proposed project indicate that the parcel is a host of a
mix of existing deciduous and coniferous trees, including pine trees of similar height to the
proposed monopine. Additional photo simulations from views across Amazon Road, south of
Fox Hollow and Potter Street have been provided to demonstrate the mix of abundant
vegetation and mature trees in the surrounding neighborhood as well as proposed
landscaping. The existing variety of trees and vegetation in addition to the trees and
landscaping proposed with this application provide context for the monopine to blend into the
environment.
The ancillary equipment will be housed in an extension of the existing building that will also
be utilized as Church storage. It is a minor addition in comparison to the size of the existing
structure and has no impact on the surroundings following completion of construction. The
extension will be finished to match the existing building and will also be surrounded by
landscape as shown in the additional photo simulations.
3. The applicant should also consider the possibility that a variance may not be granted to
allow above ground ancillary facilities, and provide for alternative designs (e.g.
underground or fully enclosed with additional sound buffering) as a contingency or means
to better address the approval criteria.
(b) The proposed structures, parking lots, outdoor use areas or other site
improvements which could cause substantial off-site impacts such as
noise, glare and odors are oriented away from nearby residential uses
and/or are adequately mitigated through other design techniques, such
as screening and increased setbacks.
RESPONSE: To meet the above criteria, the equipment shelter extension has been oriented
away from nearby residential uses to face the church playground and Fox Hollow Road. In
addition, all substantial offsite impacts have been mitigated through design of the
7117 SW Beveland Street, Suite 101
Tigard, OR 97223
(323) 559-4103
Email: jacob.finnev@taec.net
www.taec.net
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Technologyt Associates
equipment enclosure as an architecturally compatible extension of the existing church with
extensive sound baffling which will reduce the noise levels of the facility equipment to well
below the City's noise limits. The proposed ground equipment includes AC units and an
emergency generator, which would both be fully enclosed within a sound-baffled equipment
shelter, built to look like a seamless extension of the church building. The AC units would run
intermittently to cool equipment. The emergency generator would run only in emergencies and
for about 10 consecutive minutes during monthly testing. The proposed design incorporates
additional baffling sufficient to reduce the sound from the AC units to 35 dBA, well below the 45
dBA code limit for R-1-zoned properties. Because the proposed generator would run for such a
short amount of time during daytime hours, it would not be considered a noise disturbance
under the code even if the noise level briefly exceeds 45 dBA. (Per Matt Denberg, City of Eugene
Code Compliance, Oct. 22, 2014. See generally, EC 6.750(b).) However, to minimize the noise
levels from the generator, it would be enclosed within the sound-baffled equipment shelter and
additional noise control can be added to assure that all substantial offsite impacts have been
mitigated and that the 45dBA noise level at the property lines is achieved.
Because testimony at hearing will demonstrate that the emergency generator cannot be safely
placed underground and because the criteria for a variance from that requirement have been
met, the Applicant is not proposing an underground alternative. The proposed design is fully
enclosed with additional sound baffling. Att. 1, 2.
"C the screening shown on Sheet L2.0 is not reflected in the photo simulations. The mono-
pine design shown on Sheet A-3.0 is also not reflected in the photo simulations. We
believe you will need better evidence to show what the actual visual impacts will be.
In addition to screening around the base of the facilities, consider additional screening.
There appears to be an opportunity to provide additional landscape screening on Tax Lot
701-the portion of the site abutting Dillard Road and Fox Hollow Road. It looks like a
visual from the intersection of Dillard Road and Fox Hollow Road is needed.
RESPONSE: The screening and monopine design are depicted in the new photo
simulations with a very high degree of accuracy. A 3D photo rendering has been created
to provide a fully accurate depiction of the proposed monopine. Additional landscaping
can be added on the Tax Lot 701 as specified by Staff.
7117 SW Beveland Street, Suite 101
Tigard, OR 97223
(323) 559-4103
Email: iacob.finney@taec.net
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Technology 4 Associates
5. The supplemental noise report (dated October 22, 2014) contains edits on page 3 that
makes the findings difficult to interpret. The statement refers to the City's noise
ordinance relative to the generator; remember that this is CUP in which all impacts are
evaluated against subjective approval criteria, above and beyond basic code standards.
Did the acoustical engineer take into account any grade differences between the subject
property and adjacent properties? (This was an issue in the Rest Haven case, in which
abutting neighbors successfully argued that the noise travel path was different because their
homes were located at a higher elevation.)
The acoustical report still needs to be verified by our consultant (the related review fees
must be paid for by the applicant.)
RESPONSE: The acoustical engineer took into account any grade differences between the
subject property and adjacent properties. The noise study and its supplement provide
evidence that the proposed wireless facility will meet Eugene's noise limits on the
surrounding properties. The amount of the additional fees to be paid for the consultant to
verify the acoustical report has been requested by the Applicant and Applicant was informed
1 that the fee amount would not be provided until zoning materials have been re-submitted.
6. EC 9.8090(3): The location, design, and related features of the proposal
provides a convenient and functional living, working, shopping or civic
environment, and is as attractive as the nature of the use and its location and
setting warrant.
The "as attractive as the nature of the use and its location and setting warrant"
requirement is not addressed. Staff is concerned that this particular stealth design may
not respond appropriately to the setting and recommends that the applicant evaluate
alternatives or additional comparative analysis to better show that the proposed design
fits the setting.
7117 SW Beveland Street, Suite 101
Tigard, OR 97223
(323) 559-4103
Email: iacob.finnev@taec.net
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Technology ~t Associates
RESPONSE: To meet the "as attractive as the nature of the use and its location and
setting warrant" requirement, the Applicant has re-designed the antenna array to provide
more stealthing of the facilities. The new configuration, as show on site plans and in
photo simulations, reduces the number of antennas from a total of 12 to 6 (2 antennas
per sector) with a shorter 3' antenna frame and a shorter stand off from the pole, so the
proposed antennas will more closely "hug" the pole, further concealing it within the
branches. In addition, the Applicant is proposes landscaping around the base of the pole
as well as the building extension that will house the ancillary equipment to promote as
attractive an environment as possible that blends in with the existing buildings, flora and
mature trees on the subject property as well as the surrounding neighborhood.
7.
s
I
_--1
9.5750 Telecommunication Devices-Siting Requirements and Procedures.
(6) Application Requirements.
(a) Construction of Transmission Tower. In addition to standard
required application material, an applicant for a transmission
tower shall submit the following information; additional
application material is required, as specified in paragraph (c)
below,for applications requiringa site review orconditional
use process:
i. A description of the proposed tower location, design and
height.
The photo simulations are inconsistent with the plans regardingthe tower design and
the landscaping.
RESPONSE: The proposed monopine is a total of 75' tall, the pole itself and antenna tip
height is 70' and then we have added an additional 5' of branches to the top to resemble
the tapering of a natural pine tree. The antenna configuration has been revised from the
initial application and Applicant has reduced the number of panel antennas from 12 to 6
to bring them closer into the pole and provide greater concealment. New photo
7117 SW Beveland Street, Suite 101
Tigard, OR 97223
(323) 559-4103
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Technology `t Associates
simulations have been to provide the new tower design and landscaping with a very high
degree of accuracy. Att. 2.
8. The supplemental noise report has notes that make it difficult to read. Please clarify
the generator noise level, as the written statement seems to rely on our citywide noise
standards.
What would be the noise generation if all facilities were underground? It would be
helpful to show a comparison, to justify a variance to undergrounding.
RESPONSE: Because the proposed generator would run for such a short amount of time during
daytime hours, it would not be considered a noise disturbance under the code even if the noise
level briefly exceeds 45 dBA. (Per Matt Denberg, City of Eugene Code Compliance, Oct. 22,
2014. See generally, EC 6.750(b).) However, to minimize the noise levels from the generator, it
would be enclosed within the sound-baffled equipment shelter and the Engineer stated in a
March 26, 2015 conversation, that additional noise control can be added to assure that all
substantial offsite impacts have been mitigated and that the 45dBA noise level at the property
lines is achieved.
Because testimony at hearing will demonstrate that the emergency generator cannot be safely
placed underground and because the criteria for a variance from that requirement have been
met, the Applicant is not proposing an underground alternative. The proposed design is fully
'enclosed with additional sound baffling. Please see revised drawings and photosims, Att.1 and
A tt. 2.
9.
10. Signature of the property owner(s) on the application
form or a statement from the property owner(s)
granting authorization to proceed with development
permit and land use processes;
Please verify that the person who signed the application form is the property owner or
has the authority to sign on behalf of the property owner.
7117 SW Beveland Street, Suite 101
Tigard, OR 97223
(323) 559-4103
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Technology `1# Associates
RESPONSE: Please see Att. 5 - Crossfire Church giving Aaron Taylor the power to sign on
behalf of Calvary Fellowship regarding the placement of a cell tower on Calvary
Fellowship's property.
10.
(a) Site Review and Conditional Use Permit Applications. In
addition to the application requirements specified in paragraph (b)
above, applications for site review or conditional use permits also
t shall include the following information:
1. A visual study containing, at a minimum, a graphic
simulation showingthe appearance of the proposed
r{,, tower, antennas, and ancillary facilities from at least 5
points within a 3 mile radius. Such points shall be chosen
by the provider with review and approval by the
planning director to ensure that various potential views
are represented. The photo simulations and site plans
(which are inconsistent) leave unanswered questions about
how the project adequately addresses compatibility with
the surroundings. Further, additional viewpoints may be
necessary, such as from the intersection of Dillard Road and
Fox Hollow Road.
(7) Standards for Transmission Towers and Antennas. Installation,
construction or modification of all transmission towers and antennas
shall comply with the following standards, unless a variance is
obtained pursuant to the provisions of subsection (9) of this section:
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(323) 559-4103
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Technology Associates
(e) Buffering. In all zones, existing vegetation shall be preserved
to the maximum extent possible. In the C-4, 1-11-2 and 1-3
zones, no buffering is required beyond that required by this
land use code. In all other zones, landscaping shall be placed
completely around the transmission tower and ancillary
facilities located at ground level except as required to access
the facility. Such landscaping shall consist of evergreen
vegetation with a minimum planted height of 6 feet placed
densely so as to form a screen. Landscaping shall be
compatible with other nearby landscaping and shall be kept
healthy and well maintained.
More and different landscaping may be necessary to address compatibility with
surrounding properties.
RESPONSE: Additional photo simulations have been provided from 6 different viewpoints that
were not previously provided. The additional viewpoints include views from across Amazon
Road, south of Fox Hollow and Potter Street, and demonstrate the proposed monopine's
compatibility with the existing trees and vegetation. In addition, the photo simulations depict
the proposed landscaping and the extension to the existing Church building that will house the
ancillary equipment.
11.
(f) Noise Reduction. In R-1,11-2, R-3, R-4,C-1,and GO and in all other
zones when the adjacent property is zoned for residential use
or occupied by a dwelling, hospital, school, library, or nursing
7117 SW Beveland Street, Suite 101
Tigard, OR 97223
(323) 559-4103
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Technology Associates
home, noise generating equipment shall be sound-buffered by
means of baffling, barriers, or other suitable means to reduce
sound level measured at the property line to 45dBa.
The noise report is difficult to read. Please be clear about mitigation for the generator.
RESPONSE: The acoustical report prepared by SSA Acoustics dated October 22, 2014 indicates
that the predicted sound level generated by the generator will exceed the Eugene's 45 dBA
requirement for the receiving properties to the south and west. The Engineer states that, while
the generator is excluded from the noise ordinance, to achieve a level near the 45 dBA level in
the code, Applicant must Install a louver equivalent to Vibro-Acoustics ALV-MV-8 at the air
discharge; sound absorbing material with a minimum NRC rating of 0.90 on at least 96 square
feet of the ceiling and 300 square feet of the walls of the generator room; install a sheet metal
hood on the outside of the air intake opening, to be lined with 1" duct liner, install a critical
grade exhaust stack muffler on the engine exhaust stack that provides 25-40 dBA noise
reduction equivalent to GT Exhaust Muffler 201-5100.
Per a follow up conversation with the Engineer on March 26, 2015, additional noise control can
o be added to assure that the generator meets the 45dBA noise level at the property lines.
12.
(8) Standards for Ancillary Facilities. All ancillary facilities shall
complywith the standards of subsections (7)(e) and (7)(f) of this
section. Inaddition, all ancillary facilities within an R-1,1PL,C-1,GO,
and PRO zone must be located underground tothe maximum
extent technology allows, unless a variance is obtained pursuant
to the provisions of subsection (9) of this section. This restriction
does not apply within other zones.
7117 SW Beveland Street, Suite 101
Tigard, OR 97223
(323) 559-4103
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Technology i Associates
As noted previously, the ability to obtain a variance is questionable. In response to the
standard above, provide information about the technological feasibility of
undergrounding and consider proposing it an alternative design (alongwith a noise study
that addresses an underground design) in the event that a variance is denied.
RESPONSE: AT&T requests a variance to the undergrounding requirement based on (1) the
technological difficulties and safety issues related to undergrounding ancillary equipment at this
site; (2) the proposed, stealth design and landscaping of the equipment enclosure and (3) the
planned use of noise baffling within the shelter.
AT&T equips certain telecommunication facilities with an emergency power supply in the case of
a disaster that cuts off local power supply to the facility. Emergency generators, like the one
proposed at this site, use a diesel combustion engine to supply power. Testimony at hearing will
demonstrate that undergrounding a combustion engine poses several safety risks, including the
risk of explosion and risks to maintenance personnel who would have to service combustible
equipment in a confined space. (Maintenance of undergrounded facilities requires at least two
maintenance people, so that one can perform safety checks when the other is servicing
equipment.) These safety risks make undergrounding prohibitive. Additionally, an
undergrounded equipment shelter (compared to an above ground equipment shelter) requires a
construction footprint, additional belowground impervious surface, and several above
ground ventilators and air pumps (which could generate additional noise) to provide cooling for
the equipment and resolve air quality issues for maintenance personnel.
The proposed design is a fully enclosed equipment shelter, designed to closely resemble the
existing church building, with compatible architecture and matching roofing, siding, and paint.
The extension is minimal in proportion to the size of the existing building and will be painted and
finished to match the existing structure. Applicant also proposes new landscaping around the
perimeter of the building extension so the ancillary equipment stored inside it will be completely
stealthed and have minimal visual impact. The shelter would be lined with extensive sound
baffling to reduce noise produced by the WTF's ancillary equipment below the city's limit of 45
d8A at the adjacent property lines.
7117 SW Beveland Street, Suite 101
Tigard, OR 97223
(323) 559-4103
Email: jacob.finnev@taec.net
www.taec.net
11
01
Technology
Associates
Unlike the Northgreen application referenced in staff's letter, where no generator was
proposed, there is an emergency generator at this location. As described above, it is not
feasible to locate the generator underground and its contribution to the noise output is de
minimus, as the generator would only operate during one monthly 5-10 minute maintenance
test during daytime hours (7 AM-10 PM). This test can be scheduled at a time designed to have
the slightest impact on surrounding property owners. In the event of emergency, the generator
would operate for the time required within the heavily baffled equipment enclosure to provide
critical wireless service to the neighborhood during an emergency.
The proposed design of the ancillary equipment eliminates the need for undergrounding, as
demonstrated in the site plans, photo simulations and noise study. The equipment will be
located within an extension of the existing building, which will also serve as storage for the
Church. The extension is minimal in proportion to the size of the existing building and will be
i painted andfmished to match the existing structure. Applicant also proposes new landscaping
around the perimeter of the building extension so the ancillary equipment stored inside it will be
completely stealthed and have minimal visual impact. See Att. 1 and 2.
13.
i
(9) Variance.
The city may grant a variance to the setback and
undergrounding requirements subsections (7)(d) or (8) upon
findingthat stealth design, proposed landscaping,
configuration of the site, orthe presence of maturetrees
obviates the need for compliance.
7117 SW Beveland Street, Suite 101
Tigard, OR 97223
(323) 559-4103
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Technology t Associates
The requested variance for not undergrounding the ancillary facilities is not
sufficiently supported bythe application materials. Please respond to the above
criterion.
RESPONSE: To meet the above criterion, the equipment shelter extension has been oriented
away from nearby residential uses to face the church playground and Fox Hollow Road. In
addition, all substantial offsite impacts have been mitigated through design of the
equipment enclosure as an architecturally compatible extension of the existing church with
extensive sound baffling which will reduce the noise levels of the facility equipment to well
below the City's noise limits. The proposed ground equipment includes AC units and an
emergency generator, which would both be fully enclosed within a sound-baffled equipment
shelter, built to look like a seamless extension of the church building. The AC units would run
intermittently to cool equipment. The emergency generator would run only in emergencies and
for about 10 consecutive minutes during monthly testing. The proposed design incorporates
additional baffling sufficient to reduce the sound from the AC units to 35 dBA, well below the 45
dBA code limit for R-1-zoned properties. Because the proposed generator would run for such a
short amount of time during daytime hours, it would not be considered a noise disturbance
under the code even if the noise level briefly exceeds 45 dBA. (Per Matt Denberg, City of Eugene
Code Compliance, Oct. 22, 2014. See generally, EC 6.750(b).) However, to minimize the noise
levels from the generator, it would be enclosed within the sound-baffled equipment shelter and
additional noise control can be added to assure that all substantial offsite impacts have been
mitigated and that the 45dBA noise level at the property lines is achieved.
Because testimony at hearing will demonstrate that the emergency generator cannot be safely
placed underground and because the criteria for a variance from that requirement have been
met, the Applicant is not proposing an underground alternative. The proposed design is fully
enclosed with additional sound baffling.
Applicant also proposes new landscaping around the perimeter of the building extension so the
ancillary equipment stored inside it will be completely stealthed and have minimal visual
impact. Moreover, Applicant has provided a noise study that includes mitigation measures
ensuring that the site meets or exceeds Eugene's noise reduction code requirements.
7117 SW Beveland Street, Suite 101
Tigard, OR 97223
(323) 559-4103
Email: jacob.finney@taec.net
www.taec.net
13
Technoiogy Associates
Thank you for consideration of this application. Please contact me if you have any questions or
comments about the enclosed materials.
Sincerely,
V Z~
cob Finney
K
•
i
N~
.1J:
7117 SW Beveland Street, Suite 101
Tigard, OR 97223
(323) 559-4103
Email: iacob.finnev@taec.net
www.taec.net
14
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HATFIELD & DAWSON
BENJAMIN F. DAWSON III, PE
THOMAS M. ECKELS, PE
STEPHEN S. LOCKWOOD, PE
DAVID J. PINION, PE
ERIK C. S WANSON, PE
THOMAS S. GORTON, PE
MICHAEL H. MEHIGAN, PE
CONSULTING ELECTRICAL ENGINEERS
9500 GREENWOOD AVE. N.
SEATTLE, WASHINGTON 98103
TELEPHONE (206) 783-9151
FACSIMILE(206)789-9834
E-MAIL hatdaw@hatdaw.com
JAMES B. HATFIELD, PE
CONSULTANT
MAURY L. HATFIELD, PE
(1942-2009)
PAUL W. LEONARD, PE
(1925-2011)
NON-IONIZING ELECTROMAGNETIC EXPOSURE ANALYSIS
PREPARED FOR AT&T
EG46 Fox Hollow Road & Amazon Road
January 2014
CALCULATIONS OF RADIOFREQUENCY POWER DENSITY
This report contains calculations of predicted ground level Radiofrequency (RF) power densities
resulting from the proposed installation of a new AT&T wireless communications facility in
Eugene, OR. These power densities have been computed in accordance with methods
described in Evaluating Compliance with FCC Guidelines for Human Exposure' to
Radiofrequency Electromagnetic Fields, OET Bulletin 65, August 1997. Licensees of wireless
communications facilities such as the proposed AT&T facility are required to comply with the
FCC "Rules & Regulations" 47 CFR §1.1310, Radiofrequency radiation exposure limits.
PREDICTED CONDITIONS AT GROUND LEVEL
Site plans provided by AT&T indicate that the antennas for the proposed Fox Hollow Road
wireless facility will be mounted at a height of 71 feet (21.6 meters) above ground level. The
proposed antennas are highly directional in the vertical plane, and will therefore project the
transmitted RF energy away from all nearby ground level accessible areas. Thus it is unlikely
that anyone other than authorized RF workers could approach near enough to the proposed
antenna to cause those persons' RF exposure to exceed FCC limits. It is expected that
exposure conditions at ground level due to the contributions from the proposed AT&T
transmitting antennas will be well below the FCC public exposure limits.
All calculations in this report are referenced to the FCC limits for areas accessible to the
general public, which are the most restrictive FCC limits.
The proposed AT&T facility will operate in the 850 MHZ cellular band with an Effective Radiated
Power ("ERP") of 1,398 Watts, in the 700 MHZ LTE band with an ERP of 484 Watts, and in the
1900 MHZ PCS band with an ERP of 966 Watts. Assuming 15 dB of antenna signal
suppression at angles greater than 20° below horizontal (a factor of 31.6)' yields an effective
ERP toward the ground of 44.25 Watts in the cellular band, 15.2; Watts in the LTE band and
30.6 Watts in the PCS band.
'This is a conservative assumption. While data for the antennas specified by AT&T was
unavailable, similar antennas have suppression figures on the order of 20 dB.
Hatfield & Dawson Consulting Engineers
The power density resulting from the operation of the proposed AT&T facility can be calculated
using the formula below:
S = 33.4 ERP
R2
Where
S = Power Density in pW/cm2 (microwatts per square centimeter)
ERP = Effective Radiated Power from an antenna in Watts
R = distance in meters from the antenna to the location under study
This is formula #9 from OET-65, found on page 21 of the OET bulletin.
Using this formula with an ERP of 44.25 Watts and a height of 19.6 meters (the height of the
proposed antenna, minus 2 meters -to approximate the location of the head of a person
standing on the ground near the tower) the maximum power density for AT&T's proposed
operations in the cellular band is calculated to be 3.85 pW/cm2, which is 0.67% of the FCC limit
at the lowest AT&T frequency in the 850 MHZ cellular band.
Using the formula with an ERP of 15.3 Watts and a height of 19.6 meters the maximum power
density for AT&T's proposed operations in the LTE band is calculated to be 1.33 pW/cm2, which
is 0.29% of the FCC limit at the lowest AT&T frequency in the 700 MHZ LTE band.
Using the formula with an ERP of 30.6 Watts and a height of 19.6 meters the maximum power
density for AT&T's proposed operations in the PCS band is calculated to be 2.66 pW/cm2,
which is 0.266% of the FCC limit at the lowest AT&T frequency in the 1900 MHZ PCS band.
These calculations show that the maximum calculated power density produced at two meters
above ground level by the proposed AT&T facility alone is less than 1.3% of the applicable FCC
exposure limit at all ground level locations. Section 1.1307(b)(3) of the Commission's Rules
excludes applications for new facilities or modifications to existing facilities from the requirement
of preparing an environmental assessment when the calculated emissions from the applicant's
proposed facility are predicted to be less than 5% of the applicable FCC exposure limit.
Hatfield & Dawson Consulting Engineers
Therefore, the proposed facility is in compliance with Section 1.1301 et seq and no further
analysis of non-ionizing radiation at this site is required in this application. Furthermore, the
proposed AT&T facility is excluded from the requirement to perform a routine environmental
evaluation under §1.1307(b)(1) of the FCC's rules, as the proposed AT&T antennas will be
mounted on a tower at a height of more than 10 meters above ground level.
ANALYSIS OF MICROWAVE OPERATIONS
Microwave dish antennas are highly directional and project the majority of the transmitted RF
energy horizontally in a narrow beam towards a fixed receiving location, and well above all
nearby accessible areas. To avoid reflections and signal attenuation, microwave antennas are
pointed away from all portions of adjacent buildings and other nearby obstructions.
Because microwave dish antennas are orientated towards the horizon and away from habitable
structures, RF exposure conditions within nearby buildings and near ground level due to dish
antennas are well below the FCC public exposure limits. The contributions of tower-mounted
microwave facilities to the ground-level RF exposure environment are negligible and not worthy
of further consideration.
Hatfield & Dawson Consulting Engineers
QUALIFICATIONS
I am an experienced radio engineer whose qualifications are a matter of record with the Federal
Communications Commission. I am an engineer in the firm of Hatfield and Dawson Consulting
Engineers, I am Registered as a Professional Engineer in the States of Oregon and
Washington, and I hold an FCC General Radiotelephone Operator License PG-13-10466.
All representations contained herein are true to the best of my knowledge.
January 29, 2014
Thomas S. Gorton, P.E.
Hatfield & Dawson Consulting Engineers
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Stewart ua • Bun • Mtl1er-Kie n
October 22, 2014
Kimberly Spongberg
Site Acquisition - NSB
Velocitel, Inc.
4004 Kruse Way PI, Suite 220
Lake Oswego, OR 97035
Re: Acoustical Report - AT&T EG46 Fox Hollow Road & Amazon Road
Site: 4060 W. Amazon Drive, Eugene, OR 97405
Dear Kimberly,
This report presents a property line noise study for the proposed AT&T telecommunications facility
at 4060 West Amazon Drive in Eugene, Oregon. This noise study extends from the proposed
equipment to the nearest receiving properties. The purpose of this report is to document the
existing conditions and the impacts of the acoustical changes due to the proposed equipment.
This report contains data on the existing and predicted noise environments, impact criteria and
an evaluation of the predicted sound levels as they relate to the criteria.
Ambient Conditions
Existing ambient noise levels were measured on site with a Larson-Davis 820 sound level meter
on February 6, 2014. Measurements were conducted as close to the receiving property lines
nearest the proposed location as possible in accordance with Oregon Administrative Rules (OAR)
340-35-035 subsection (3)(b). The average ambient noise level was 49 dB(A), primarily due to
local traffic on Amazon Road. The weather during the measurements was cloudy and the roads
were snowy.
Code Requirements
The site is located within the City of Eugene Zoning jurisdiction on property with an R-1
(Residential) zoning designation. All of the receiving properties are also zoned Residential.
The proposed new equipment consists of equipment support cabinets and an emergency
generator. The cabinets are expected to run intermittently 24 hours a day. The emergency
generator would be in operation for less than 10 consecutive minutes during routine monthly
testing (during daytime hours) and during a power outage.
Eugene City Code Chapter 9.5750.7.f limits noise being received by an R-1 or other residential
property to 45 dBA.
Additionally, for this particular site the City has recommended that the equipment meet 35 dBA at
the nearest receiving properties.
222 Etruria Street, Suite 100
Seattle, WA 98109
206.839.0819 P H 206.839.0824 F
AT&T EG46 Fox Hollow Road & Amazon Road
Predicted Equipment Sound Levels
Page 2
24-Hour Operation Equipment
The equipment will be located in a shelter served by two Marviar air conditioning units. According
to manufacturer data, the Marvair AVP48 air-conditioning which each produce 72 dB(A) at 5 feet.
The equipment will operate on a lead/lag cycle such that one unit will be in operation at a time.
To predict equipment noise levels at the receiving properties, this survey uses the methods
established by ASHRAE and AHRI Standard 275-2010. Application factors such as location,
height, and reflective surfaces, and noise reduction from intervening elements are accounted for
in predicting the sound level at the receiving properties.
The nearest receiving properties are approximately 90 feet to the west, 180 feet east across W.
Amazon Road, and 200 feet south across Fox Hollow road. The building blocks the equipment
noise to the property to the west, and the cedar fence surrounding the tower blocks the equipment
to the east. The predicted sound levels are shown in the table below.
Table 1
Application Factors and Predicted Noise Levels
Proposed New Equipment
Application Line 1 Equipment Sound Pressure Level at 5 ft., LPs
72
72
72
2 Building / Wood Fence Reduction
-20
-6
3 Distance Factor (DF)
DF = 20 to io Dl/D2
-25
90 ft
-31
180 ft
-32
200 ft
4 New Equipment Sound Pressure Level at Receiver, LPR
27
35
40
According to the predicted noise levels, the equipment would be below the 45 dBA code limit, but
would not meet the City's recommended 35 dBA level at the south property line. Mitigation
measures to meet this recommended noise level are provided below.
Noise Mitigation:
The following noise mitigation must be implemented for the AC units:
• Install a Marvair External Low Noise Blower (ELNB) kit on each unit. The kit replaces the
condenser prop fan and motor with a sound absorbing hood, blower and motor and
controls to reduce external sound levels. The kit will reduce noise levels by 6 dBA.
With the noise mitigation installed, noise levels from the AC units will be 34 dBA at the south
property line and will meet the City's recommended 35 dBA level.
AT&T EG46 Fox Hollow Road & Amazon Road
Emergency Equipment
Page 3
The proposed equipment includes one Kohler 50 kW Generator. According to the manufacturer,
the generator will produce the following sound levels:
Source
Sound Level
Engine - unhoused
80 dBA 23 feet
Exhaust - open
102 dBA 3 feet
The emergency generator would be in operation for less than 10 consecutive minutes during
daytime hours on a monthly basis for routine testing, and for longer periods during emergencies.
The generator will be located within a room on the south end of the existing church building. The
nearest receiving properties are approximately 70 feet to the west and 200 feet south across Fox
Hollow road. The building blocks the receiving property to the west.
Because the proposed generator would run for less than 10 consecutive minutes at an agreed
upon time during daytime hours (7 AM-10 PM), it would not be considered a noise disturbance
under the code even if the noise level briefly exceeds the 45 dBA limit. However, to minimize the
noise levels from the generator, implement the following noise control measures for each source:
Engine Discharge:
• Install a louver equivalent to Vibro-Acoustics ALV-MV-8 at the air discharge.
Engine Intake:
• Install sound absorbing material with a minimum NRC rating of 0.90 on at least 96 square
feet of the ceiling and 300 square feet of the walls of the generator room. Recommended
products for this application are minimum 2" thick F-Sorb or T-Max.
• Install a sheet metal hood on the outside of the air intake opening. Hood to be lined with
1" duct liner.
Exhaust stack:
• Install a critical grade exhaust stack muffler on the engine exhaust stack that provides 25-
40 dBA noise reduction equivalent to GT Exhaust Muffler 201-5100.
AT&T EG46 Fox Hollow Road & Amazon Road
PREDICTED NOISE LEVELS - WITH MITIGATION
The following are the predicted noise levels with the mitigation implemented:
Receiving Property: West
Page 4
Source
Sound Level
Distance To
Receiver
Building
Factor'
Noise
Control
Distance
Factor3
dBA Level
Discharge
80 dBA @ 23 feet
70
-15
-17
-10
38
Intake
80 dBA 23 feet
70
-15
-17
-10
38
Exhaust
102 dBA 3 feet
70
-30
-27
45
Total
46
Table Notes:
1. Building factor is plenum reduction / increase of building or interfering building element.
2. Noise Control is mufflers, silencers, or lined hoods.
3. Distance Factor = -10'LOG(Q)+20'LOG(R2/R1) for dBA or -10'LOG(Q)+20`LOG(R)+0.5 for LwA
Receiving ProDertv: South
Source
Sound Level
Distance To
Receiver
Building
Factor'
Noise
Control
Distance
Factor'
dBA Level
Discharge
80 dBA 23 feet
200
-17
-19
44
Intake
80 dBA 23 feet
.200
-10
-17
-19
43
Exhaust
102 dBA 3 feet
200
-30
-36
36
Total
46
Table Notes:
1. Building factor is plenum reduction / increase of building or interfering building element.
2. Noise Control is mufflers, silencers, or lined hoods.
3. Distance Factor = -10'LOG(Q)+20'LOG(R2/R1) for dBA or -10'LOG(Q)+20'LOG(R)+0.5 for LwA
With the mitigation implemented, noise from proposed emergency generator will be very close to
the 45 dBA code at the nearest residential properties when in operation.
Please contact our office if you have questions or need further information.
Sincerely,
SSA Acousti S, LLP
Alan Burt, P.E.
ASSOCIATE PARTNER
ACOUSTICAL CONSULTANT