21-101703-Project Narrative-ATTCH 1-SC2064 Redondo Beach-04-28-2021-V1
PROJECT NARRATIVE
PWSF Conditional Use Permit Application
AT&T SD2064 Redondo Beach
Submitted to the City of Federal Way of Washington
Planning and Development Services
Applicant: New Cingular Wireless PCS, LLC (“AT&T”)
19801 SW 72nd Avenue Suite 200
Tualatin, OR 97062
(425) 222-1026
Representative: Smartlink LLC
11410 NE 122nd Pl, #102
Kirkland, WA 98034
Contact: Nancy Sears
425-444-1434
Nancy.sears@smartlinkllc.com
Property-Owner: Dan Lourie
PO Box 98258
Federal Way, WA 98198
(206) 391-8750
Utility Pole Owner: Puget Sound Energy
3380 146th Place SE
Bellevue, WA 98007
412-400-9876
Elizabeth.rainier@pse.com
Project Address: 29601 8th Ave SW
Federal Way, WA 98023
Description & Tax Lot: GPS Coordinates: 47.336517 / -122.345075
Parcel No. 062104-9042
Zoning Classification: RS15.0
Smartlink LLC is submitting this application on behalf of New Cingular Wireless PCS, LLC
(“AT&T”) and the underlying property owner.
ATTACHMENT 1—Project Narrative
AT&T’s PWSF CUP Application—SC2064 Redondo Beach
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1. PROJECT OVERVIEW
AT&T is proposing a new personal wireless service facility (“Facility”), SC2064 Redondo Beach, at
the above noted project address. This Facility is a service coverage replacement and capacity site.
Currently, portions in and around Adelaide & Redondo have minimal to no 4G voice service and
AT&T’s existing coverage in the area is at or near its capacity and is insufficient for the volume of
traffic (i.e. though this area already has AT&T coverage, additional capacity is needed to service
the volume of users).
In addition to the Master Permit Application, Commercial Building Permit Application for PWSF,
and pursuant to the PWSF Submittal Checklist (the “Checklist”), AT&T intends its application for
the proposed Facility to include the following documents (collectively, “AT&T’s Application”):
Attachment A—Master Land Use Application
Attachment 1—Project Narrative
Attachment 2—Statement of Code Compliance
Attachment 3—RF Justification
Attachment 4—Zoning Drawings
Attachment 5-Photo Simulations
Attachment 6—NIER Report
Attachment7—Noise Report
Attachment 8-TOWAIR Determination
As shown in AT&T’s Application, this proposed project meets all applicable Federal Way Code
(“SCC”) criteria collocating a new wireless communications facility and complies with all other
applicable state and federal laws and regulations. AT&T’s proposal is also the least intrusive
means of meeting its coverage objectives for this site. Accordingly, AT&T respectfully requests
Federal Way to approve this project as proposed, subject only to Federal Way’s standard
conditions of approval to include a Franchise Agreement for the Right-of-Way.
2. PROPOSED PROJECT DETAILS
Additional detailed information regarding the subject property, proposed lease area, and
proposed wireless support structure and equipment is included in Attachment 3—Site Plan.
2.1. Site Description
Subject property. The subject property of this proposal is located at 29601 8 th Ave SW in
the city of Federal Way (the “Property”). The Property is owned by Dan Lourie.
Zoning. The Property is zoned as RS15.0 (Residential) and is currently vacant land. All
properties surrounding the site are also zoned RS15.0.
ATTACHMENT 1—Project Narrative
AT&T’s PWSF CUP Application—SC2064 Redondo Beach
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Lease area. The proposed 25 x 25ft lease area for the Facility is located near the northeast
end of the Property (the “Lease Area”). The Lease Area will be surrounded by a 6ft sight
obscuring chain link fence and a 5 ft. Type III landscape buffer with access secured by a
locked gate.
2.2. Access, Parking, and Trip Generation
Access. Access to the Lease Area will be from 8th Ave. SW via a proposed 15 ft. wide
gravel driveway. AT&T will obtain any necessary access (and/or utility) easements as part
of the final lease agreement with the property owner.
Parking. The Lease Area is located 69’3” south of the NE corner of the property. Access
will be from the 8th Ave SW, east of the lot, via a 15’ access road with parking space. The
existing parking lot can be used for turn-around.
Trip generation. The proposed Facility will be an unmanned wireless facility. As such, after
the initial construction, AT&T will only regularly access the Facility for maintenance and
inspections, which will likely generate no more than one or two trips per month.
2.3. Wireless Facilities and Equipment
2.3.1. Support structure design.
AT&T is proposing to collocate on a PSE utility pole (the “Pole”) in the right-of-
way. PSE will be replacing the existing utility pole with a 55’ utility pole. PSE’s
power lines located at the 37’7” level and they will install AT&T’s antennas at the
55’ tip height.
This will be an unmanned wireless facility.
2.3.2. Antennas and accessory equipment.
The Pole will contain AT&T 4G LTE equipment (up to 12 panel antennas, 12 remote
radio unites (RRUs), and 3 new surge protectors, with all associated equipment).
The antennas, RRUs, and accessory equipment on the utility pole will be painted
a non-reflective brown to blend with the pole.
2.3.3. Ground equipment.
The ground equipment will be constructed within the Lease Area on the private
property adjacent to the right-of-way.
The ground equipment will be enclosed within a pre-fabricated 7’ x 7’ walk-in
cabinet shelter.
An external redundant diesel generator will be located on a separate pad next to
the cabinet shelter.
2.3.4. Lighting. The Tower will not be artificially illuminated, and no artificial lighting is
required pursuant to state or federal authorities. See Attachment 8 - FAA TOWAIR
Determination.
ATTACHMENT 1—Project Narrative
AT&T’s PWSF CUP Application—SC2064 Redondo Beach
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2.4. Landscaping & Screening
Pursuant to FWMC 19.125 AT&T is proposing to enclose the leased area with a 6’ chain
link fence with privacy slats, three strands of barbed wire will =top the fence and the site
will be secured with a 12’ padlocked gate. , The fence will be surrounded by a five foot
wide Type III visual buffer as outlined in FWMC 19.259.050 . Please see Attachment 4 -
Zoning Drawings.
2.5. Utilities
Power. Underground power will be provided by Puget Sound Energy.
Telecommunications. Telecommunications fiber will be provided by CenturyLink.
Water. As this is an unmanned wireless facility, no water service is needed.
Sewer. As this is an unmanned wireless facility, no sewer service is needed.
3. SITE SELECTION CRITERIA
3.1. Overview—AT&T 4G LTE and 5G Network Coverage and Services
AT&T is upgrading and expanding its wireless communications network to support the latest 5G
and 4G LTE technology. 5G and 4G stand for "5th Generation" and "4th Generation" and LTE
stands for "Long Term Evolution." These acronyms refer to the ongoing process of improving
wireless technology standards, which is now in its 5th generation. With each generation comes
improvement in speed and functionality-4G LTE offers speeds up to ten times faster than 3G and
5G offers speeds up to 1-gigabit per second. See Attachment-3 RF Justification.
This technology is the next step in increasing broadband speeds to meet the demands of users
and the variety of content accessed over mobile networks and is necessary to facilitate
capabilities that are being designed into the latest devices (i.e. Samsung Galaxy S20, iPhone 12).
5G, specifically, is the next generation of wireless technology expected to deliver latency and
capacity enhancements that will help enable revolutionary new capabilities for consumers and
businesses.
There are several components of 5G wireless technology and separate bands of wavelength
spectrum used to build a 5G network-low-band (<2GHz), mid-band (3-10GHz), and high-band
millimeter wave (mmWave) (20-100GHz):
Low-band 5G. Low-band 5G frequencies (generally below 2GHz) are the oldest cellular
(and TV) frequencies and are being used by AT&T to provide widely-available 5G service
ATTACHMENT 1—Project Narrative
AT&T’s PWSF CUP Application—SC2064 Redondo Beach
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in residential, suburban, and rural areas. This is the same spectrum used for 3G and 4G
cellular service today. The low-band 850MHz 5G frequency is proposed for this Facility.
Low-band 5G frequencies are a tradeoff of download speed versus distance and service
area-they are slower than the high-band mmWave and mid-band frequencies (as
described below), but they travel the farthest and can pass through more obstacles to
provide a better, more reliable indoor and outdoor signal for a larger service area (i.e.
miles, not feet).
Mid-band 5G. Mid-band 5G frequencies (generally 3-10GHz) cover most current cellular
and WiFi frequencies and provide broader coverage (typically a half a mile) than high-
band mmWaves but with slower speeds. Use of these frequencies is not as prevalent for
building a 5G network as much of the bandwidth in this range is currently unavailable.
High-band 5G+ mmWave. High-band millimeter wave (mmWave) frequencies (generally
20-100GHz) are the new FCC-approved frequencies most associated with 5G service-
"5G+" is AT&T's name for 5G service delivered using high-band mmWave spectrum. AT&T
offers an enhanced wireless experience on 5G+ with mmWave service though with more
limited coverage. Results continue to be impressive, with peak download speeds up to 1
gigabit per second (Gbps) - fast enough to stream 4K movies.
High-band mmWave frequencies deliver this unprecedented performance by
transmitting a large amount of data more efficiently than 4G LTE, but can only travel short
distances (~1,000ft). Accordingly, high-band mmWave sites need to be in close proximity
to one another and are typically used in dense, high trafficked areas such as urban areas,
stadiums/arenas, airports, manufacturing and healthcare centers, etc.
5G wireless technology also includes enhanced network radio protocols and other
improvements in data transmission that allow the network to more efficiently use the same
frequencies currently used today for 4G.
As noted, AT&T is proposing to deploy low-band 850MHz 5G at this Facility. Upon completion,
the Facility will become part of AT&T's statewide and nationwide communications networks.
Upon completion of this update, AT&T will operate a state-of-the-art digital network of wireless
communications facilities throughout the proposed coverage area as part of its nationwide
wireless communications network.
3.2. Network Service Objectives for Proposed Facility
The proposed Facility is a coverage replacement site intended to provide improved 4G LTE and
new low-band 5G coverage in and around Adelaide and Redondo (the “Targeted Service Area”).
This area has minimal to no 4G voice service and AT&T’s existing coverage in the area is at or
near its capacity and is insufficient for the volume of traffic (i.e. though this area already has
AT&T coverage, additional capacity is needed to service the volume of users).
ATTACHMENT 1—Project Narrative
AT&T’s PWSF CUP Application—SC2064 Redondo Beach
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The proposed new Facility meets AT&T’s service objectives to provide sufficient continuous and
uninterrupted outdoor, in-vehicle, and in-building wireless service within the Targeted Service
Area, resulting in fewer dropped calls, improved call quality, and improved access to additional
wireless services the public now demands.
This includes emergency 911 calls throughout the area. The service objective and Targeted
Service Area for this site were determined by AT&T’s radio frequency (“RF”) engineers through a
combined analysis of customer complaints, service requests, and RF engineering design. (See
Attachment 3—RF Justification)
3.3. Search Ring
AT&T’s radio frequency (“RF”) engineers performed an RF engineering study, considering
multiple objectives, to determine the approximate site location and antenna height required to
fulfill the noted network objectives for the Targeted Service Area. From this study, AT&T’s RF
engineers identified a specific geographic area, or “search ring” area, where a PWSF may be
located to provide effective service in the Target Service Area.
The search ring established for this proposal, and a description of the methodology used to
identify the search ring, is provided in Attachment 3—RF Justification.
3.4. Priority of Locations and Collocation Attempts
Pursuant to SCC 30.28A.120 all other higher-priority locations for siting the proposed Facility
were reviewed and found to be infeasible, as further discussed below:
(1) Locate on structures in the BPA trail.
The BPA trail is approximately 2.2 miles outside of the search ring for this site and would
not meet the desired coverage objective. Please see Attachment 3—RF Justification.
(2) Locate on existing broadcast, relay, and transmission towers where a legal WCF is
currently located regardless of underlying zoning.
The nearest tower is a 144ft monopole approximately 2.25-mile SE of the search ring near
the I-5 corridor and would not meet the desired coverage objective. Please see
Attachment 3—RF Justification.
(3) Locate on institutional structures not located within public rights-of-way.
While a utility pole would be considered an institutional structure as defined in
FW19.256.100 (3) all utility poles located within the search ring are within the public right-
of-way. The nearest institutional structure not in the right-of-way is a church
approximately 1/2-mile SW of the search ring. The tallest point of this structure is
approximately 36ft which would be a maximum height of 51’. Both the distance from the
search ring and the height restriction would not meet the desired coverage objective.
ATTACHMENT 1—Project Narrative
AT&T’s PWSF CUP Application—SC2064 Redondo Beach
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(4) Locate in appropriate non-residential zoning districts.
Zoning within one mile of the proposed site is residential. Please see Attachment 3—RF
Justification.
As demonstrated above and in the RF Justification, there are no viable locations within the
required order of location. This effectively prohibits AT&T from improving existing service and
providing new service to the residents in the Adelaide, Redondo and Buena neighborhoods.
AT&T’s proposal to collocate on an existing utility pole in the public right-of-way and respectfully
requests the City of Federal Way approve this application.
4. APPLICABLE LAW
4.1. Local Codes and Policies
Unless indicated as exempt or inapplicable, AT&T’s specific responses to the applicable
provisions in the SCC and county policy, as referenced below, are included in Attachment 2—
Statement of Code Compliance.
Zoning—FWMC 19.256.090. Monopoles and other wireless communication facilities other
than small wireless facilities shall be processed as Process II applications.
Wireless Communication Facilities Regulations—Chapter 19.256 FWMC.
Process II – Site Plan Review—Chapter 19.60 FWMC.
4.2. Federal Law
Federal law, primarily found in the Telecommunications Act of 1996 (“Telecom Act”),
acknowledges a local jurisdiction’s zoning authority over proposed wireless facilities but limits
the exercise of that authority in several important ways.
4.2.1. Local jurisdictions may not materially limit or inhibit. The Telecom Act prohibits
a local jurisdiction from taking any action on a wireless siting permit that “prohibit[s] or
[has] the effect of prohibiting the provision of personal wireless services.” 47 U.S.C. §
332(c)(7)(B)(i)(II). According to the Federal Communications Commission (“FCC”) Order
adopted in September 2018,1 a local jurisdiction’s action has the effect of prohibiting the
provision of wireless services when it “materially limits or inhibits the ability of any
competitor or potential competitor to compete in a fair and balanced legal and regulatory
environment.”2 Under the FCC Order, an applicant need not prove it has a significant gap
in coverage; it may demonstrate the need for a new wireless facility in terms of adding
capacity, updating to new technologies, and/or maintaining high quality service.3
1 Accelerating Wireless and Wireline Broadband Deployment by Removing Barriers to Infrastructure Investment, Declaratory Ruling
and Third Report and Order, WT Docket No. 17-79, WC Docket No. 17-84, FCC 18-133 (rel. Sept. 27, 2018); 83 Fed. Reg. 51867
(Oct. 15, 2018) (“FCC Order”).
2 Id. at ¶ 35.
3 Id. at ¶¶ 34-42.
ATTACHMENT 1—Project Narrative
AT&T’s PWSF CUP Application—SC2064 Redondo Beach
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While an applicant is no longer required to show a significant gap in service coverage, in
the Ninth Circuit, a local jurisdiction clearly violates section 332(c)(7)(B)(i)(II) when it
prevents a wireless carrier from using the least intrusive means to fill a significant gap in
service coverage. T-Mobile U.S.A., Inc. v. City of Anacortes, 572 F.3d 987, 988 (9th Cir.
2009).
Significant Gap. Reliable in-building coverage is now a necessity and every
community’s expectation. Consistent with the abandonment of land line
telephones and reliance on only wireless communications, federal courts now
recognize that a “significant gap” can exist based on inadequate in-building
coverage. See, e.g., T-Mobile Central, LLC v. Unified Government of Wyandotte
County/Kansas City, 528 F. Supp. 2d 1128, 1168-69 (D.Kan. 2007 ), affirmed in part,
546 F.3d 1299 (10th Cir. 2008); MetroPCS, Inc. v. City and County of San Francisco,
2006 WL 1699580, *10-11 (N.D. Cal. 2006).
Least Intrusive Means. The least intrusive means standard “requires that
the provider ‘show that the manner in which it proposes to fill the significant gap
in service is the least intrusive on the values that the denial sought to serve.’” 572
F.3d at 995, quoting MetroPCS, Inc. v. City of San Francisco, 400 F.3d 715, 734 (9th
Cir. 2005). These values are reflected by the local code’s preferences and siting
requirements.
4.2.2. Environmental and health effects prohibited from consideration. Also, under the
Telecom Act, a jurisdiction is prohibited from considering the environmental effects of RF
emissions (including health effects) of the proposed site if the site will operate in
compliance with federal regulations. 47 U.S.C. § 332(c)(7)(B)(iv). AT&T has included with
this application a statement from its radio frequency engineers demonstrating that the
proposed facility will operate in accordance with the Federal Communications
Commission’s RF emissions regulations. See Attachment 6, NIER Report. Accordingly,
this issue is preempted under federal law and any testimony or documents introduced
relating to the environmental or health effects of the proposed Facility should be
disregarded in this proceeding.
4.2.3. No discrimination amongst providers. Local jurisdiction also may not discriminate
amongst providers of functionally equivalent services. 47 U.S.C. § 332(c)(7)(B)(i)(I). A
jurisdiction must be able to provide plausible reasons for disparate treatment of different
providers’ applications for similarly situated facilities.
4.2.4. Shot Clock. Finally, the Telecom Act requires local jurisdictions to act upon
applications for wireless communications sites within a “reasonable” period of time. 47
U.S.C. § 332(c)(7)(B)(ii). The FCC has issued a “Shot Clock” rule to establish a deadline for
the issuance of land use permits for wireless facilities. 47 C.F.R. § 1.6001, et seq. A
presumptively reasonable period of time for a local government to act on all relevant
ATTACHMENT 1—Project Narrative
AT&T’s PWSF CUP Application—SC2064 Redondo Beach
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applications for a collocation on an existing structure is 90 days. 47 C.F.R. §
1.6003(c)(1)(ii). The Shot Clock date is determined by counting forward 90 calendar days
from the day after the date of submittal, including any required pre-application period.
47 C.F.R. § 1.6003(e).
Pursuant to federal law, the reasonable time period for review of this application is 90
days.