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Crown Castle – 816309 Sunset
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Application for
Wireless Communication Facility
Crown Castle
816309 Sunset
A Proposal Submitted to The City of Renton
Prepared for
CROWN CASTLE
2055 S. Stearman Drive
Chandler, AZ 85286
CrownCastle.com
Prepared by
The North Group, Inc.
Bill North
PO Box 2449
Snohomish, WA 98291
December 16, 2019
RECEIVED
01/08/2020
amorganroth
PLANNING DIVISION
Crown Castle – 816309 Sunset
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I. PROPOSAL SUMMARY INFORMATION
Crown Castle Site: 816309 Sunset
Applicant: CROWN CASTLE
2055 S. Stearman Drive
Chandler, AZ 85286
CrownCastle.com
Prepared By: The North Group, Inc.
Bill North
PO Box 2449
Snohomish, WA 98291
425-876-2909
billnorth@northgroup.net
Property Owner: Renton Housing Authority
Request: Approval of an Administrative Conditional Use Permit for
a Wireless Communication Facility (WCF) with SEPA
determination. Crown Castle in conjunction with AT&T
Wireless proposes to relocate an existing WCF which will
consist of the installation of a new 99’ stealth tower with
attached antennas within a 34’x50’ fenced area along
with ground mounted equipment.
Site Location: 2902 NE 12TH ST, RENTON, WA 98056
Legal Description: See attached legal description
Assessor Parcel Number: 7227802040
Zoning: R-14
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PROJECT DESCRIPTION
II. INTRODUCTION
Crown Castle (“Crown Castle”) is a wireless communications tower company operating in The
City of Renton. AT&T Wireless (“AT&T Wireless”) is licensed to operate in the State of
Washington by the Federal Communications Commission (FCC). AT&T Wireless in conjunction
with Crown Castle is currently designing its networks in the Washington area to improve its
wireless communication service and provide wireless capacity to its subscribers.
This proposal describes the scope of the proposed project by providing specific information
regarding the project location, zoning, specifications, and response to the City of Renton code
requirements pertaining to Wireless Communications Facilities.
It is Crown Castle’s desire to work with the City of Renton to ensure that our project is consistent
with local ordinances and zoning regulations while providing the wireless communications
coverage that is critical for emergency, business, and personal use.
Project Goals
The goal of the Crown Castle 816309 Sunset site is to relocate an existing Wireless
Communication Facility to maintain existing coverage. The existing AT&T site is being
decommissioned due to development. The relocated site will maintain, provide, and enhance
AT&T Wireless communications coverage for business, personal, and emergency purposes in
the immediate vicinity of the proposed tower location including along NE Sunset Blvd in the City
of Renton. Crown Castle intends to achieve these network goals consistent with all policies and
ordinances of the City of Renton.
Application Request
The applicant is requesting the following:
Approval of an Administrative Conditional Use Permit for a Wireless Communication Facility
(WCF) with SEPA determination.
III. GENERAL PROJECT DESCRIPTION
Project Overview
Crown Castle in conjunction with AT&T Wireless is proposing to relocate an existing Wireless
Communication Facility. The proposal is to construct a new 99’ stealth tower resembling a tree
with attached antennas within a 34’x50’ fenced area along with ground mounted equipment.
Crown Castle is obtaining an agreement with the property owner that will allow for construction
and maintenance of this facility, necessary utility connections, and provisions for access to the
site. The proposed facility will be located at 2902 NE 12TH ST, RENTON, WA 98056 and
identified as A.P.N. # 7227802040.
IV. GENERAL SITE ANALYSIS
Zoning General Plan Designation
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The site is located on property zoned R-14. The City of Renton code references Wireless
Communications Facilities in RMC Chapter 4-4-140. The proposal is classified as a Wireless
Communication Facility Stealth Tower (RMC 4-4-140.I.1). A Stealth Tower is permitted in the
R-14 zone with an Administrative Conditional Use Permit (RMC 4-2-060 Zoning Use Table)
SEPA
A wireless service tower less than sixty feet in height that is located in a commercial zone is
exempt from the requirements of RCW 43.21C.030(2)(c), (RCW 43.21C.0384). The proposal is
over 60’ in an R-14 zone and therefore does not meet this requirement. Please find the attached
SEPA checklist attached as EXHIBIT A.
Existing Use
The subject parcel is owned by the Renton Housing Authority and was originally used as a
library.
Access/Circulation
The site will be accessed from the existing entry off Harrington Ave NE via the City of Renton
owned parcel/Right-of-way. There are no traffic impacts associated with these types of facilities
as they are unmanned and require infrequent maintenance.
FCC/FAA
Crown Castle will conform to all FAA regulations. AT&T Wireless has a license from the FCC
to provide wireless communications in the City of Renton.
V. CRITERIA COMPLIANCE NARRATIVE
The City of Renton Code has specific requirements regarding the development of Wireless
Communication Facilities. The following sections address each of the requirements that are
applicable in the order they appear.
4-4-140 WIRELESS COMMUNICATION FACILITIES:
D. COLLOCATION REQUIRED:
1. Evaluation of Existing Support Structures: With the exception of support structures to
facilitate the deployment of small cell facilities, no new support structure shall be permitted
unless the applicant demonstrates to the Administrator’s satisfaction that no existing tower or
support structure can accommodate the applicant’s proposed WCF. Evidence submitted to
demonstrate that an existing tower or structure cannot accommodate the applicant’s proposed
antenna may consist of any of the following:
a. No existing towers or structures are located within the geographic area required to
meet the applicant’s engineering requirements.
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Response: There are no existing structures within the geographic area required to
meet the applicant’s engineering requirements suitable for antenna
attachment or colocation. In compliance with this section.
F. STANDARDS AND REQUIREMENTS FOR ALL TYPES OF WIRELESS COMMUNICATIONS
FACILITIES:
1. Equipment Shelters/Cabinets:
a. Location: Except for equipment related to small cell facilities, equipment shelters and cabinets
used to house related equipment should be located within buildings or placed underground,
unless it is infeasible. However, in those cases where it can be demonstrated by the applicant that
the equipment cannot be located in buildings or underground, equipment shelters or cabinets
shall be screened to the Administrator’s satisfaction.
Response: Ground equipment will be placed within the wood fenced area which will
provide screening in compliance with this section.
b. Screening: Equipment shelters and cabinets for all facilities other than small cell facilities shall
be surrounded by a fifteen-foot (15') wide sight-obscuring landscape buffer along the outside
perimeter of required security fencing with a minimum height that is no less than the height of the
compound fence at any point; however, existing topography, vegetation and other site
characteristics may provide relief from the screening requirement. The required landscaped areas
shall include an automated irrigation system, unless the applicant is able to justify an exception to
this requirement to the Administrator’s satisfaction. Related equipment facilities located on the
roof of any building need not be landscaped but shall be screened on all sides in a manner that
complements and blends with the surroundings so as to be shielded from view. Related
equipment facilities shall not be enclosed with exposed metal surfaces. Equipment shelters and
cabinets for small cell facilities shall be concealed in accordance with subsection J of this Section.
(Ord. 5798, 4-25-2016)
Response: The facility will be placed in an area with existing trees and vegetation.
Proposed landscaping and wood fence will complement the existing vegetation
and will provide adequate screening in compliance with this section. Please see
the attached proposed landscape plan provided.
c. Size: The applicant shall provide documentation that the size of any equipment shelters or
cabinets is the minimum necessary to meet the provider’s service needs, and meets any size
requirements of this Code. The area of the compound may be greater than is necessary in order
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to accommodate future collocations, but the area reserved for future equipment shelters/cabinets
shall be the minimum necessary for the documented WCF capacity. (Ord. 5676, 12-3-2012)
Response: The equipment is the minimum size necessary to meet the providers needs.
An area has been reserved for future providers as shown on the attached plans
sheet A-3 in compliance with this section.
d. Generators:
Response: Not applicable. No generator is proposed.
2. Maximum Height: All wireless communication facilities shall comply with RMC 4-3-020, Airport
Related Height and Use Restrictions. In addition, all wireless communication facilities shall comply with
the height limitation of the applicable zoning district, except as follows:
a. Monopole I: Less than sixty feet (60') for all zones. Antennas may extend sixteen feet (16')
above the monopole I support structure.
Response: Not applicable. The proposed facility is stealth tower.
b. Monopole II: No more than thirty five feet (35') higher than the maximum height for the
applicable zoning district, or one hundred fifty feet (150'), whichever is less. Antennas may extend
sixteen feet (16') above the monopole II support structure.
Response: Not applicable. The proposed facility is stealth tower.
c. Stealth Towers: The maximum allowed height of a stealth tower shall be one hundred fifty feet
(150'); however, the allowed height for a specific type of stealth facility shall be determined
through the Conditional Use Permit review process and the standards of this Section.
Response: The proposed facility is 99’ stealth tower which falls below the height
maximum in compliance with this section.
3. Visual Impact: Site location and development shall preserve the pre-existing character of the
surrounding buildings and landscape to the extent consistent with the function of the communications
equipment. Towers shall be integrated through location and design to blend in with the existing
characteristics of the site to the extent practical. Existing on-site vegetation shall be preserved or
improved, and disturbance of the existing topography shall be minimized, unless such disturbance
would result in less adverse visual impact to the surrounding area. Towers, antennas and related
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equipment shall be uniformly painted a nonreflective neutral color that best matches the colors within
the immediately surrounding built and natural landscape in order to reduce the contrast between the
WCF and the landscape.
Response: The proposed facility is a stealth tower designed to look like a tree. The facility
will be placed on the property within existing vegetation which include
numerous trees. A wood fence will add additional screening of the facility. The
facility will blend in with the existing characteristics of the site and existing on-
site vegetation shall be preserved to the maximum extent possible. The
proposed site location, development design, and fencing shall preserve the pre-
existing character of the property and landscape to the extent consistent with
the function of the communications equipment in compliance with this section.
4. Setbacks: Towers shall be set back from each property line by a distance equal to the tower height,
unless an engineering analysis concludes that a reduced setback is safe for abutting properties and the
Administrator determines that a reduced setback is appropriate for the site.
Response: The applicant is requesting a reduction in the setback requirement. The facility
minimum height requirement of 99’ will not accommodate a 1 to 1 setback from
property lines. The proposed setbacks are approximately 75’ from the north
property line and 60’ from the west property line. The tower will be designed
and engineered to meet all code requirements for safety.
5. Maximum Noise Levels: No equipment shall be operated so as to produce noise in levels above
forty five (45) decibels as measured from the nearest property line on which the wireless communication
facility is located. Operation of a back-up power generator in the event of power failure or the testing of
a back-up generator between eight o’clock (8:00) a.m. and nine o’clock (9:00) p.m. are exempt from this
standard. No testing of back-up generators shall occur between the hours of nine o’clock (9:00) p.m.
and eight o’clock (8:00) a.m.
Response: All proposed equipment will comply with noise standards below 45 decibels in
compliance with this section. No generator is proposed.
6. Fencing: Security fencing shall be required and shall be painted or coated with a nonreflective
neutral color. Fencing shall comply with the requirements listed in RMC 4-4-040, Fences, Hedges, and
Retaining Walls.
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Response: A six foot wood fence surrounding the facility is proposed and will be stained a
non-reflective neutral color in compliance with his section.
7. Lighting: Towers or antennas shall not be artificially lighted, unless required by the FAA or other
applicable authority. If lighting is required, the Administrator may review the available lighting
alternatives and approve the design that would cause the least disturbance to the surrounding views.
Security lighting for the equipment shelters or cabinets and other on-the-ground ancillary equipment is
also permitted, as long as it is appropriately down shielded to keep light within the boundaries of the
compound. (Ord. 5675, 12-3-2012)
Response: No lighting is proposed other than may be required by the FAA.
8. Advertising Prohibited: No lettering, symbols, images, or trademarks large enough to be legible to
occupants of vehicular traffic on any abutting roadway shall be placed on or affixed to any part of a
WCF tower, antenna array or antenna, other than as required by FCC regulations regarding tower
registration or other applicable law. Antenna arrays designed and approved to be located on or within
signs or billboards as a stealth tower, small cell, or a concealed or camouflaged WCF, shall not be
construed to be in violation of this prohibition. (Ord. 5676, 12-3-2012)
Response: No lettering, symbols, images, or trademarks large enough to be legible to
occupants of vehicular traffic on any abutting roadway shall be placed on or
affixed to any part of a WCF tower, antenna array or antenna, other than as
required by FCC regulations regarding tower registration or other applicable law
in compliance with this section.
9. Building Standards: Support structures shall be constructed so as to meet or exceed the most
recent Electronic Industries Association/Telecommunications Industries Association (EIA/TIA) 222
Revision G Standard entitled: “Structural Standards for Steel Antenna Towers and Antenna Supporting
Structures” (or equivalent), as it may be updated or amended. Prior to issuance of a building permit the
Building Official shall be provided with an engineer’s certification that the support structure’s design
meets or exceeds those standards. (Ord. 5675, 12-3-2012)
Response: The tower will be designed and engineered to meet or exceed the most recent
Electronic Industries Association/Telecommunications Industries Association
(EIA/TIA) 222 Revision G Standard entitled: “Structural Standards for Steel
Antenna Towers and Antenna Supporting Structures” (or equivalent), as it may
be updated or amended in compliance with this section.
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10. Radio Frequency Standards: The applicant shall ensure that the wireless communication facility
(WCF) will not cause localized interference with the reception of area television or radio broadcasts. If
the City finds that the WCF interferes with such reception, and if such interference is not remedied
within thirty (30) calendar days, the City may revoke or modify a Building and/or Conditional Use Permit.
(Ord. 5675, 12-3-2012)
Response: The proposed facility will comply with all FCC regulations and standards.
I. STEALTH TOWER STANDARDS:
The following standards for each type of stealth tower are the minimum necessary to meet the intent of
effectively disguising the tower. Standards for types of stealth towers not identified within this subsection
will be determined on a case-by-case basis by the Administrator through the Conditional Use Permit
criteria pursuant to RMC 4-9-030E, Decision Criteria – Wireless Communication Facilities.
1. Faux Trees:
a. Location: Faux trees shall be located within one hundred feet (100') of existing trees, unless
photo simulations show, to the Administrator’s satisfaction, that the proposed faux tree would be
appropriate for the site.
Response: The proposed facility will be placed within 100’ of existing trees in compliance
with this section. Please see the Tree Retention and Landscape Plan attached
as Exhibit B.
b. Height: The faux tree may exceed the average height of nearby trees by no more than twenty
percent (20%) or thirty feet (30'), whichever is greater.
Response: The proposed stealth facility will be 99’ in height which exceeds the existing 71’
tree on site by approximately 30’ (Tree no. 4 on plan).
c. Authenticity: Faux trees shall replicate the shape, structure, and color of live trees common to
the area. Plans shall provide detailed specifications regarding the number and spacing of
branches, bark, foliage, and colors. All faux trees shall incorporate a sufficient number of
branches (no less than three (3) branches per linear foot of height) and design materials (e.g.,
faux bark) so that the structure appears as natural in appearance as feasible. Branches shall not
be required for the lowest twenty feet (20') of the trunk.
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Response: The proposed stealth facility faux tree replicates the shape, structure, and color
of live trees common to the area. The design of the structure will appear as
natural in appearance as feasible.
d. Concealment:
i. All cables and antennas shall be painted to match the color of the trunk.
ii. Antenna socks are mandatory for all antennas (and similar components) located on a faux
tree.
Response: All cables and antennas will be painted to match and placed to blend with the
tree design in compliance with his section.
K.. APPLICATION SUBMITTAL REQUIREMENTS:
In addition to application materials and information required pursuant to RMC 4-8-120C, Table 4-8-120C
– Land Use Permit Submittal Requirements, the following materials are the minimum required to
complete a review of any WCF, other than a minor alteration pursuant to subsection E1 of this Section
or small cell facilities pursuant to subsection J of this Section. Additional materials and information may
be required.
1. Technical Analysis:
a. Site Justification Letter: This report shall justify the need or requirement for the proposed
WCF location and design. An analysis of other available sites shall be included as well as
determination as to why these sites were not selected.
Response: Please see the site justification letter outlining the need for the
proposed WCF location and height attached as Exhibit C.
b. Justification Map: A map identifying the zoning districts, search area, alternative sites, the
selected site, and all existing and approved WCFs within a one-half (1/2) mile radius.
Response: Please see the site justification map identifying the search area as
Exhibit C along with inventory list existing WCFs attached as Exhibit D.
c. Coverage Map: Map(s) identifying the proposed target coverage that illustrate the coverage
prior to and after the installation.
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Response: Please see the site justification letter with map identifying the proposed
target coverage attached as Exhibit C.
d. Noise Report: For projects proposed adjacent to residential uses when generators, air
conditioning units, or other noise-generating devices are utilized.
Response: All proposed equipment will comply with noise standards below 45
decibels. No generator is proposed.
2. Photo Simulations: Photo simulations shall be required with each plan set. The photo simulations
shall illustrate the proposed WCF from at least four (4) vantage points and show the existing view
(without the proposed WCF) and proposed view (with the proposed WCF) from each vantage point.
Response: Please see the photo simulations attached as Exhibit E.
3. Method of Attachment/Cabling: Dimensioned details shall be provided of antennas and mounting
hardware used to attach the antennas to the structure.
Response: Please see the proposed submitted plans outlining design and details.
4. Visual Mitigation: Any concealment/integration techniques proposed shall be fully explained,
illustrated and detailed.
Response: The proposed facility is a stealth tower designed to look like a tree. The
facility will be placed on the property within existing vegetation which
include numerous trees. A wood fence will add additional screening of
the facility. The facility will blend in with the existing characteristics of the
site and existing on-site vegetation shall be preserved to the maximum
extent possible. The proposed site location, development design, and
fencing shall conceal and integrate the facility in compliance with this
section.
4-9-030 CONDITIONAL USE PERMITS:
E. DECISION CRITERIA – WIRELESS COMMUNICATION FACILITIES:
1. Decision Criteria: In lieu of the criteria in subsection D of this Section, Decision Criteria, the following
criteria in subsections E1a through i of this Section shall be considered in determining whether to issue
a conditional use permit for a wireless communication facility (WCF) except a small cell facility;
however, the Administrator may waive or reduce the burden on the applicant of one or more of these
criteria if the Administrator concludes that the goals of RMC 4-4-140, Wireless Communication
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Facilities, are better served by the applicant’s proposal. In lieu of the criteria in subsection D of this
Section, Decision Criteria, the following criteria in subsections E1a through d and f of this section shall
be considered in determining whether to issue an administrative conditional use permit for a small cell
facility; however, the Administrator may waive or reduce the burden on the applicant of one or more of
these criteria if the Administrator concludes that the goals of RMC 4-4-140, Wireless Communication
Facilities, are better served by the applicant’s proposal:
a. Height and Design: The height of the proposed tower and/or antenna as well as incorporation
of design characteristics that have the effect of reducing or eliminating visual obtrusiveness.
Response: The proposed facility is a 99’ stealth tower designed to look like a tree. The
facility will be placed on property within existing vegetation which include
numerous trees. A wood fence will add additional screening of the facility. The
facility will blend in with the existing characteristics of the site and existing on-
site vegetation shall be preserved to the maximum extent possible. The
proposed site location, development stealth design, and fencing shall have the
effect of reducing or eliminating visual obtrusiveness in compliance with this
section.
b. Proximity to Surrounding Uses: The nature of uses on adjacent and nearby properties and
the proximity of the tower and/or antenna to residential structures and residential district
boundaries.
Response: The proposed 99’ stealth tower will be approximately 80’ or more from any
adjacent residential structure. The adjacent uses of nearby properties are
residential.
c. Nature of Surrounding Uses: The nature of uses on adjacent and nearby properties. The
proposed use at the proposed location shall not result in substantial or undue adverse effects on
adjacent property.
Response: The proposed facility is a 99’ stealth tower designed to look like a tree. The
adjacent uses of nearby properties are residential. The current use of the
proposed site is not residential. The original use was a public Library. The RHA
intends to continue to use the property for community purposes. The proposed
facility will not change the property use by the RHA. The impact of the
proposed facility on residential uses nearby should by immaterial shall not
result in substantial or undue adverse effects on adjacent property. The
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proposed facility is unmanned and will have infrequent maintenance personnel
visiting the site periodically. The proposed stealth facility will blend with the
existing vegetation on the site.
d. Topography and Vegetation: The surrounding topography and tree canopy coverage.
Response: The proposed facility is a stealth tower designed to look like a tree.
The facility will be placed on the property within existing vegetation
which include numerous trees. The facility will blend in with the
existing characteristics of the site and existing on-site vegetation shall
be preserved to the maximum extent possible. Please see the Tree
Retention and Landscape Plan attached as Exhibit B.
e. Ingress/Egress: The proposed ingress and egress.
Response: The site will be accessed from the existing entry off Harrington Ave NE
via the City of Renton owned parcel/Right-of-way. There are no traffic
impacts associated with these types of facilities as they are unmanned
and require infrequent maintenance.
f. Impacts: The potential noise, light, glare, and visual impacts.
Response: The proposed facility will meet all noise requirements. The stealth
facility will be designed to look like a tree and painted with non- glare
colors. Lighting is not proposed. The proposed site location,
development stealth design, and fencing shall have the effect of
reducing visual impacts in compliance with this section.
g. Collocation Feasibility: The availability of suitable existing towers and other structures to
accommodate the proposal.
Response: The proposed facility will replace the existing Crown Castle/AT&T
facility in order to maintain current coverage. There are no available
existing towers within the vicinity to meet the coverage objective.
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h. Consistency with Plans and Regulations: The compatibility with the general purpose, goals,
objectives and standards of the Comprehensive Plan, this Title, and any other City plan, program,
map or ordinance.
Response: The proposed facility is compatible with the general purpose, goals and
standards of the Comprehensive Plan Utilities Element Goal U-Q: “Promote the
timely and orderly expansion of all forms of telecommunications service within
the City and its planning area.” The proposed stealth facility project is
consistent with local ordinances and zoning regulations particularly RMC
Chapter 4-4-140.
i. Landscaping: Additional landscaping may be required to buffer adjacent properties from
potentially adverse effects of the proposed use. (Ord. 5675, 12-3-2012)
Response: Please see the Tree Retention and Landscape plan showing proposed
landscaping attached as Exhibit B.
Summary:
The proposed Crown Castle facility meets the requirements of The City of Renton Code RMC Chapter
4-4-140 & 4-9-030.
We appreciate the opportunity to make our proposal and to provide quality wireless
communication services to the residents of the City of Renton.
Sincerely,
Bill North
The North Group, Inc
on behalf of Crown Castle.
Attachments:
SEPA Checklist – Exhibit A
Tree Retention and Landscape Plan – Exhibit B
Site Justification Letter & Map - Exhibit C
WCF inventory list – Exhibit D
Photo Simulations – Exhibit E