HomeMy WebLinkAboutPN_AT&T_1160_Duvall_Ave_NE_Project_Narrative_220111_v1
The Foundation for a Wireless World
CrownCastle.com
1505 Westlake Ave N, N
Seattle, WA 98109
Phone:
www.crowncastle.com
January 11, 2022
Via Online Submittal
CITY OF RENTON, WA
Community & Economic Development
1055 South Grady Way, 6th Floor
Renton, WA 98057
**********NOTICE OF ELIGIBLE FACILITIES REQUEST**********
RE: Eligible Facilities Request to modify equipment on a communications tower located at:
• 1160 Duvall Ave NE, Renton, WA 98059
• Assessors Tax Parcel ID number: 102305-9091
Jurisdiction: City of Renton, WA
Application for Commercial Building Permit
Crown Site Number: 846429
Application ID: 565170
Crown Name: May Creek
Carrier: AT&T Mobility
Carrier site ID: SS11
Carrier site name: May Creek
Dear Reviewing Parties:
On behalf of New Cingular Wireless PCS (”AT&T” or “Applicant”), Crown Castle USA Inc. (“Crown Castle”) is pleased to
submit this request to modify the existing wireless facility noted above through the collocation, replacement and/or removal
of the Applicant’s equipment as an eligible facilities request for a minor modification under Section 64091 and the rules of
the Federal Communications Commission (“FCC”).2
Section 6409 mandates that state and local governments must approve any eligible facilities request for the modification of
an existing wireless tower or base station that does not substantially change the physical dimensions of such tower or base
station. Under Section 6409, to toll the review period, if the reviewing authority determines that the application is
incomplete, it must provide written notice to the applicant within 30 days, which clearly and specifically delineates all
1 Middle Class Tax Relief and Job Creation Act of 2012, Pub. L. No. 112-96, § 6409 (2012) (codified at 47 U.S.C. § 1455).
2 Acceleration of Broadband Deployment by Improving Wireless Facility Siting Policies, 29 FCC Rcd. 12865 (2014) (codified at 47
CFR § 1.6100); and Implementation of State & Local Governments’ Obligation to Approve Certain Wireless Facility Modification
Requests Under Section 6409(a) of the Spectrum Act of 2012, WT Docket No. 19-250 (June 10, 2020).
3 See 47 CFR § 1.6100 (c)(3). 4 See 2020 Upgrade Order at paragraph 16.
RECEIVED
01/12/2022 striplett
BUILDING DIVISION
B22000184
The Foundation for a Wireless World
CrownCastle.com
1505 Westlake Ave N, N
Seattle, WA 98109
Phone:
www.crowncastle.com
missing documents or information reasonably related to whether the request meets the federal requirements.3 Additionally,
if a state or local government, fails to issue any approvals required for this request within 60 days, these approvals are
deemed granted. The FCC has clarified that the 30-day and 60-day deadlines begins when an applicant: (1) takes the first
step required under state or local law; and (2) submits information sufficient to inform the jurisdiction that this modification
qualifies under the federal law4. Please note that with the submission of this letter and enclosed items, the thirty and sixty-
day review periods have started. Based on this filing, the deadline for written notice of incomplete application is February
10, 2022, and the deadline for issuance of approval is March 12, 2022.
The proposed scope of work for this project includes:
Add and or replace antennas, ancillary equipment and ground equipment as per plans for an existing carrier on an existing
wireless communication facility.
At the end of this letter is a checklist of the applicable substantial change criteria under Section 6409. Additionally, please
find enclosed the following information in support of this Commercial Building Permit Application:
(1) Applicant EFR Cover Letter and Section 6409 Substantial Change Checklist (see this document);
(2) City of Renton Commercial Building Permit application;
(3) MOL (Memorandum of Lease)
(4) Construction Drawings, by PM&A, dated 12/20/21;
(5) Structural Analysis, by Tower Engineering Professionals, dated 7/17/21;
(6) Mount Modification Analysis Report, by POD Group, dated 11/23/21;
(7) Crown Castle Agent Authorization to Submit for Permits.
As these documents indicate, (i) the modification involves the collocation, removal or replacement of transmission
equipment; and (ii) such modification will not substantially change the physical dimensions of such tower or base station.
As such, it is an “eligible facilities request” as defined in the FCC’s rules to which the 60-day deadline for approval applies.
Accordingly, Applicant requests all authorization necessary for this proposed minor modification under Section 6409.
Our goal is to work with you to obtain approvals earlier than the deadline. We will respond promptly to any request for
related information you may have in connection with this request. Please let us know how we can work with you to expedite
the approval process. We look forward to working with you on this important project, which will improve wireless
telecommunication services in your community using collocation on existing infrastructure. If you have any questions,
please do not hesitate to contact me.
Regards,
Emilie Deschamps
Emilie Deschamps for Crown Castle on behalf of Dish Wireless
The Foundation for a Wireless World
CrownCastle.com
1505 Westlake Ave N, N
Seattle, WA 98109
Phone:
www.crowncastle.com
Section 6409 Substantial Change Checklist
Towers Outside of the Public Right of Way
The Federal Communications Commission has determined that a modification substantially changes the physical dimension of a wireless tower or base
station under 47 U.S.C. § 1455(a) if it meets one of six enumerated criteria under 47 C.F.R. § 1.6100.
Criteria for Towers Outside the Public Rights of Way
YES/NO
NO
Does the modification increase the height of the tower by more than the greater of:
(a) 10%
(b) or, the height of an additional antenna array plus separation of up to 20 feet from the top of
the nearest existing antenna?
YES/NO
NO
Does the modification add an appurtenance to the body of the tower that would protrude from the
edge of the tower more than 20 feet or more than the width of the tower structure at the level of the
appurtenance, whichever is greater?
YES/NO
NO
Does the modification involve the installation of more than the standard number of new equipment
cabinets for the technology involved or add more than four new equipment cabinets?
YES/NO
NO
Does the modification entail any excavation or deployment outside the current site by more than 30
feet in any direction, not including any access or utility easements?
YES/NO
NO
Does the modification defeat the concealment elements of the eligible support structure?
YES/NO
NO
Does the modification violate conditions associated with the siting approval with the prior approval the
tower or base station other than as specified in 47 C.F.R. § 1.6100(c)(7)(i) – (iv)?
If all questions in the above section are answered “NO,” then the modification does not constitute a substantial change to the existing
tower under 47 C.F.R. § 1.6100.