HomeMy WebLinkAboutJ_Justification_191216_v1.pdf
________________________________________________________________________________________________
1420 W. Gilman Blvd. #9030,
Issaquah WA 98027
kim.allen@wirelesspolicy.com
www.wirelesspolicy.com
t 425.628.2666
f 206.219.6717
November 18, 2019
VIA EMAIL AND HAND DELIVERED:
Chip Vincent, Community and Economic Development Administrator
Jennifer Henning, Planning Director
CITY OF RENTON
1055 South Grady Way
Renton, WA 98057
Temporary Use Permit ("TUP") LUA 18-000405-Request For Extension
Verizon is requesting an extension of Temporary Use Permit ("TUP") LUA 18-000405 of
up to two years to allow time to finalize a permanent solution for this site so that
Verizon customers served by this temporary site won't lose the service they depend
upon in their daily lives.
This request is submitted pursuant to Renton Municipal Code Section 4-9-240 (3):An
applicant can request that a permit be valid beyond one year and for up to five (5) years
at time of application or prior to permit expiration. Extension requests do not require
additional fees and shall be requested in writing to the Community and Economic
Development Administrator.
Wireless data is important for public health and safety. 76% of 911 calls originate from
cell phones, and it is now common for first responders to use wireless data networks
from devices in their vehicles and on their person when responding to a crisis.
• Wide ranges of medical devices are connected to wireless networks, helping
doctors to more effectively treat their patients. Devices include smart heart
monitors and smart insulin pumps.
• 52% of American households are wireless-only for voice service. More than 70%
of all adults aged 25-34, and of adults renting their homes, are living in wireless-
only households. People are using mobile devices more than ever before, and
that trend is expected to continue.
November 18, 2019
Page 2
With such a pressing need for additional capacity, Verizon is adding facilities to expand
and add capacity to the network, but permanent macro sites take years to lease, permit
and build.
The original TUP was originally granted on November 6, 2017 and vested under the
temporary-use code in place today, which allows extensions of up to 5 years. 1 This code
section reflects a policy position of the city that a use can be considered temporary, and
not permanent, if it does not exceed 5 years.
LUA 18-000405 requested an extension of the permit and was denied on July 17, 2018
and appealed to the Hearing Examiner. The permit was extended to January 6, 2020 by
the Hearing Examiner who overturned the City's denial of the extension request, based
on Verizon testimony that 18 months would be the maximum amount of time needed
for a permanent solution. There is no prohibition in the decision against further
extensions.
At that time, the intent was to pursue a rooftop site to this location on the Bryant Motor
property, or alternatively, to place it on a ball field light in the city owned park nearby.
Eighteen months was a reasonable time estimate. However, the Bryant Motors
property was subsequently placed on the market and later sold after an extended
escrow in July, 2019. Verizon is in active lease negotiations for a permanent site with
the new owner, but the lease agreement negotiations, permitting and construction of
the roof top site cannot be completed by the January 6, 2020 expiration date. The City
Parks Department has not yet reviewed a proposal requesting the ball field light
solution and that site would take 2 years to permit and build. There are no other
available sites for this temporary facility that would address this network need.
The previous denial of the requested extension was based on a failure to maintain a
landscape buffer and other repairs. As the attached photos show, the landscaping has
been replaced, other than the landscape and screening improvements, there have been
no changes to the approved design of the COW itself and the site complies with the
original conditions of approval.2
In the Decision on Reconsideration, the Hearing Examiner affirmed the denial and
noted that there was a compelling need for this facility:
"The City never took the position that remaining in the same location for an additional
period of time would by itself be materially detrimental to public health, safety and
1 4-9-240(3)
2 Verizon has also provided the City with a maintenance bond.
November 18, 2019
Page 3
welfare; nor is there any evidence or reasonable inference to be made that, as
conditioned by staff, the continued use of the COW would be materially adverse... Given
the importance of cell phone and 911 coverage to the public health, safety and welfare,
using permit denial as an enforcement tool for past noncompliance issues is not a
compelling reason for denial under RMC 4- 9- 240( J)( 1).3"
From a policy perspective, there is no compelling reason to treat this temporary use
differently than other temporary uses, especially at a time when these temporary
wireless facilities are maintaining the network until other solutions are ready to go.
Verizon has been at the table working on a small wireless facility franchise agreement
since August of 2016. The franchise agreement was approved by the Council just 2
weeks ago on November 4, 2019. Small wireless facilities also take time to lease, permit
and build. The small wireless code update was many months in the making and still
needs additional work. In the meantime, temporary cells on wheels have been the
Band-Aid fix for a rapidly growing demand on the network and will continue to be
important until these other tools in the toolbox are up and running. We would request
an extension of up to two years, with a check in at one year to report progress on a
permanent solution.
Sincerely,
Kim Allen, Wireless Policy Group, LLC,
Representative for Verizon Wireless
Enc.
3 Hearing Examiner Decision on City Request for Reconsideration of Final Decision of Appeal of Decision to Deny
Tier 2 Temporary Use Permit dated December 28, 2018.