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Conditional Use Application Narrative/Code Review
AT&T Proposed Stealth Tower
(SD24 Cedar River)
Submitted to City of Renton Planning Division
Prepared for: New Cingular Wireless PCS LLC (AT&T)
16221 NE 72nd Way RTC 3
Redmond, WA 98052
Prepared by: Ryka Consulting
918 S Horton St #1002
Seattle, WA 98134
Contact: Jennifer Taylor
(206) 228-2127
jtaylor@rykaconsulting.com
Prepared November 2nd, 2016
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PROPOSAL SUMMARY INFORMATION
Applicant: New Cingular Wireless PCS, LLC (AT&T)
Representative: Ryka Consulting
Jennifer Taylor
(206) 228-2127
jtaylor@rykaconsulting.com
Property Owner: Seung Sik Paik
Site Name: SD24 Cedar River
Request: ACUP request for proposal to relocate existing rooftop antennas to a
new light pole with concealed antennas.
Parcel Number: 172305-9140 & 172305-9147
Address: 2431 & 2439 Maple Valley Hwy
Renton, WA 98055
INTRODUCTION
In order to upgrade the technology of service provided in Renton along Maple Valley Hwy, AT&T
proposes to modify an existing wireless facility at 2439 Maple Valley Hwy. It is AT&T’s desire to
work with the City of Renton to ensure that this project is consistent with local ordinances and
zoning regulation while providing facilities for communication services.
As shown in this narrative, AT&T’s proposal is the least intrusive means of extending AT&T’s
service to fill its LTE 4G coverage gap. No existing structures were found in the area that would
adequately support the antennas at the height required. See Exhibit 2. The proposed stealth tower is
not above the City’s height limit for stealth towers and is located on a property not developed with a
residential use.
This proposal meets all of City of Renton criteria for siting new telecommunications facilities,
including height and setbacks, and AT&T respectfully requests that City of Renton approve the
modified communication facility.
PROPOSAL DESCRIPTION
AT&T requests approval to relocate existing wireless communication facility antennas. The antennas
are currently located on the rooftop of a building at 2439 Maple Valley Hwy (Parcel 1723059147).
Due to structural concerns about the rooftop of the building it is necessary to remove the antennas
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Conditional Use Permit Application
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and mounts from the rooftop. AT&T proposes to install a new stealth light pole on the adjacent
parcel (Parcel 1723059140) with the antennas located inside the pole. The proposed light pole will
be fifty-nine feet ten inches (59’ 10”) tall and contain four (4) panel antennas. The pole will be
located adjacent to the existing equipment area which will be retained. The parcel is used as a
parking lot.
This project is located within the Commercial/Office/Residential (COR) zone. AT&T’s proposed
light pole would be considered a Stealth Tower according to the definition of the Renton Municipal
Code in 4-11-230
5. Stealth Tower: A freestanding support structure that is disguised as a natural or built
object typically appearing in the natural or urban landscape and is primarily erected to
accommodate wireless communication facilities. Examples include, but are not limited to,
manmade trees, freestanding signs, flag poles, light fixtures and clock towers.
This proposal requires an Administrative Conditional Use Permit according to the RMC Zoning Use
Table 4-2-060:
As the proposed stealth tower is not greater than sixty feet in height, SEPA review is not required. A
Building Permit is required and will be submitted separately.
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AT&T’s proposal complies with all requirements of the City’s code, which are
addressed in the following order:
For Wireless Communication Facilities:
Pages 2-3 4-4-140 D Collocation Required
Pages 4-6 4-4-140 F Standards and Requirements for all types of Wireless
communication facilities
Pages 6 4-4-140 I Stealth Tower Standards
Pages 7-8 4-4-140 J Application Submittal Requirements
Other Code Requirements:
Pages 8-10 4-9-030 Conditional Use Permits
4-4-140.D COLLOCATION REQUIRED:
1. Evaluation of Existing Support Structures: 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.
b. Existing towers or structures are not of sufficient height to meet the applicant’s
engineering requirements.
c. Existing towers or structures do not have sufficient structural strength to support
the applicant’s proposed antenna and related equipment.
d. The applicant’s proposed antenna would cause electromagnetic interference with
the antenna on the existing towers or structures, or the antenna on the existing towers
or structures would cause interference with the applicant’s proposed antenna.
e. The fees, costs, or contractual provisions required by the owner in order to share an
existing tower or structure or to adapt an existing tower or structure for sharing are
unreasonable. Costs exceeding new tower development are presumed to be
unreasonable.
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f. The applicant demonstrates that there are other limiting factors that render existing
towers and structures unsuitable.
RESPONSE: Included with this narrative as Exhibit 1 is a structural report documenting that the
existing building is no longer suitable for rooftop antenna installation. In reviewing the area for
alternative antenna locations AT&T considered an existing utility pole on the adjacent residential
parcel. The utility pole currently holds T-Mobile antennas. This pole was already replaced and
extended in height to allow for the T-Mobile collocation. There is currently no space on the pole for
AT&T to collocate due to the separation requirements from the utility lines and the separation that
would be needed between T-Mobile and AT&T antennas.
As this is a modification of an existing site the antennas need to be located as close to the existing
facility as possible to retain coverage and prevent creation of coverage gaps. There were no other
towers found within .5 miles of the existing site. See Exhibit 2 a list of other facilities within half a
mile. No existing structures and building in the area near the existing site offer the height needed.
Adjacent properties include both nonresidential and residential buildings. However they are only
one-story tall at lower ground elevations than the proposed parcel due to the ground sloping to the
south. Locating on these buildings would not be able to provide comparable coverage to the
proposed stealth pole.
2. Cooperation of Providers in Collocation Efforts: A permittee shall cooperate with other
providers in collocating additional antennas on support structures, provided the proposed
collocators have received a building permit for such use at the site from the City. A
permittee shall exercise good faith in collocating with other providers and sharing the
permitted site, provided such shared use does not give rise to a substantial technical level of
impairment of the ability to provide the permitted use (i.e., a significant interference in
broadcast or reception capabilities as opposed to a competitive conflict or financial burden).
Such good faith shall include sharing technical information to evaluate the feasibility of
collocation. In the event a dispute arises as to whether a permittee has exercised good faith
in accommodating other users, the City may require a third-party technical study at the
expense of either or both the applicant and permittee.
RESPONSE: No support structures were found in the vicinity of the existing facility that are
suitable for collocation of antennas.
3. Reasonable Efforts: All applicants shall demonstrate reasonable efforts in developing a
collocation alternative for their proposal.
RESPONSE: As this is a modification of an existing site the antennas need to be located as close to
the existing facility as possible to retain coverage and prevent creation of coverage gaps. There were
no other towers found within .5 miles of the existing site. See Exhibit 2 a list of other facilities
within half a mile.
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4-4-140 F. STANDARDS AND REQUIREMENTS FOR ALL TYPES OF WIRELESS
COMMUNICATIONS FACILITIES:
1. Equipment Shelters/Cabinets:
a. Location: Equipment……..
RESPONSE: Not applicable as no changes are proposed to the existing equipment enclosure.
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:
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: AT&T’s proposed stealth tower is does not exceed the allowed heights and is well
below the 150’ allowed.
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 equipment shall be uniformly painted a
non-reflective 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: AT&T has chosen a facility modification that is best suited to fit in with the existing
character of the property. The existing equipment is located between the existing commercial
building and the parking lot. As the antennas must be relocated from the rooftop of the building, a
light pole that provides lighting for the parking lot and fully conceals the antennas located within the
pole is not out of place on this commercial property. The pole will be painted a non-glare finish. See
Exhibit 3 for photo simulations of the proposed pole. At the request of the City, we are also
providing images of existing facilities with similar installations. See Exhibit 6 for examples.
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
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abutting properties and the Administrator determines that a reduced setback is appropriate
for the site.
RESPONSE: The parcel is less than 70’ deep therefore it is not possible to place the proposed
stealth light pole to be setback from all property lines a distance equal to the 59’-10” tower height.
As this proposal is for a pole that will provide light to the parking lot it has been located at the edge
of the parking lot 51’2” from the north property line and 12’5” from the south property line. Due to
the unique size of the property and the current development on the property AT&T requests
approval for the reduced setback which is appropriate for this proposed installation.
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: Not applicable as no changes are proposed to the existing equipment enclosure.
6. Fencing: Security fencing shall be required and shall be painted or coated with a non-
reflective neutral color. Fencing shall comply with the requirements listed in RMC 4-4-040,
Fences, Hedges, and Retaining Walls.
RESPONSE: No changes are proposed to the existing equipment enclosure.
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.
RESPONSE: The tower will not be artificially lighted. The tower is designed as a light pole which
will include a down shielded light for the existing parking lot.
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, or a concealed
or camouflaged WCF, shall not be construed to be in violation of this prohibition.
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RESPONSE: No advertising is included in this proposal
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: AT&T will comply with applicable codes with regard to structural integrity of the
support structure. AT&T will provide a structural analysis with the building permit application.
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: If interference is found to be caused by AT&T’s facility it will be addressed as soon as
possible.
4-4-140 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.
RESPONSE: Stealth light poles are not specifically address in this subsection. However, most of
this section provides criteria regarding location, height, authenticity, and concealment. AT&T chose
a stealth light pole as a design for this stealth pole as the site is located by a commercial building and
parking lot. Therefore a light pole would not be out of place in this location. The height proposed is
the same height as a utility pole with wireless facility nearby. The diameter of the pole is the smallest
possible that will still allow for installation of equipment within the pole. All cables and conduit will
be routed through the inside of the pole.
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4-4-140 J 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 an alteration pursuant to
subsection E1 of this Section, Minor Alteration. 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: As stated earlier in this document this proposal is a modification of an existing site
that requires removal of antennas due to structural insufficiency of the rooftop. As this is an existing
facility functioning within a network it is important that the relocated antennas remain close to the
existing facility site. Exhibit 1 is a structural report recommending removal of all rooftop antennas
and equipment. Exhibit 4 is a letter from an RF Engineer describing why the height and location is
necessary.
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: As described earlier in this document there are no available towers or structures that
provide space or height necessary in the near vicinity of this site. Exhibit 2 is a list of tower
structures within one half mile.
c. Coverage Map: Map(s) identifying the proposed target coverage that illustrate the
coverage prior to and after the installation.
RESPONSE: Exhibit 5 includes coverage maps that show the importance of this site in the
network. The maps depict how the new location will provide greater coverage with the increased
height afforded by the stealth tower.
d. Noise Report: For projects proposed adjacent to residential uses when generators,
air conditioning units, or other noise-generating devices are utilized.
RESPONSE: No new noise producing equipment is proposed therefore no noise report is
submitted.
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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: Provided with the application include photo simulations depicting the view of the
proposed structure from multiple angles and multiple distances. See Exhibit 3.
3. Method of Attachment/Cabling: Dimensioned details shall be provided of antennas and
mounting hardware used to attach the antennas to the structure.
RESPONSE: Antennas and mounting hardware are located inside the stealth pole. Details will be
provided with the building permit application construction plan set.
4. Visual Mitigation: Any concealment/integration techniques proposed shall be fully
explained, illustrated and detailed.
RESPONSE: The concealment is the stealth light pole tower as shown on the elevation view of the
plan set and the photo simulations.
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 shall be considered in determining whether to issue a Conditional Use
Permit for a wireless communication facility (WCF); 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 44-140, Wireless Communication Facilities, are better
served by:
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: AT&T has designed a facility to reduce visual impacts to the greatest degree possible.
The light pole will contain two rad centers of antennas that are fully screened by the stealth
canisters. The height of the pole is the minimum necessary for improved coverage along the Cedar
River Trail and at the I-405/SR169 interchange.
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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 relocation of antennas onto a new light pole does not introduce a new
use as the communication facility is existing. The adjacent property is used for residential purposes.
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: This project does not introduce a new use to the property and does not create adverse
effects for adjacent properties. There is a similar installation (antennas attached to 60’ pole) on the
adjacent residential property. This proposed installation includes a slim profile pole with fully
screened antennas and will not create adverse effects for adjacent properties.
d. Topography and Vegetation: The surrounding topography and tree canopy
coverage.
RESPONSE: This project does not require removal of trees or vegetation.
e. Ingress/Egress: The proposed ingress and egress.
RESPONSE: No changes are proposed to existing ingress and egress routes onto the property.
f. Impacts: The potential noise, light, glare, and visual impacts.
RESPONSE: Other than noise during the construction phase this proposal will not increase noise.
The proposed parking lot light pole will provide light directed downward only to the parking lot.
The pole has a slim profile and will have a non-glare finish.
g. Collocation Feasibility: The availability of suitable existing towers and other
structures to accommodate the proposal.
RESPONSE: As previously mentioned there are no existing towers or structures that can
accommodate the installation of AT&T antennas at the height or location needed.
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.
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RESPONSE: The proposed facility modification is a passive facility and would not interfere with
the surrounding commercial and residential uses on property in the immediate vicinity. This is not a
new use on the property as the parcel already contains telecommunication facilities onsite. The
proposed facility is intended to address an existing wireless coverage gap and meet coverage
objectives, which will be beneficial for the area.
i. Landscaping: Additional landscaping may be required to buffer adjacent properties from
potentially adverse effects of the proposed use.
RESPONSE: This proposal is not introducing a new use and there are no changes or expansions
proposed for the ground equipment area. The proposed pole is located in a parking lot. No
landscaping is proposed.
CONCLUSION:
The proposed project is consistent with existing uses in the neighborhood. The tower is the
minimum height necessary to meet coverage requirements and allows for the relocation of antennas
from the rooftop of a building that can no longer structurally accommodate rooftop equipment.
AT&T City of Renton approval to for the proposed new stealth light pole.
Supporting Exhibits
o 1 Structural Analysis on Rooftop Facility
o 2 Tower Search Results
o 3 Photo Simulations
o 4 RF Justification Letter
o 5 Coverage Maps
o 6 Examples of Similar Installations
o 7 Landscaping Waiver Request
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