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HomeMy WebLinkAboutCityScape 11/5/18 Report Town of Southold cKyscape c �� � srrt. rnn •ts � rvc . Telecommunications Site Review 7050 W.Palmetto Park Road#15-652 Supplemental Report to New Tower Application Boca Raton,FL 33433-3483 Tel:877.438.2851 Fax:877.220.4593 November 5, 2018 Mr. Brian Cummings Planner Town Hall Annex Building 53095 Route 25 Southold New York 11971 11,1 lia ma 1:1'oaid RE Town of Southold/ SCTM#1000-122-6-35.4 Verizon Wireless/Laurel Stone Dear Mr. Cummings, This third supplemental report is to address new information regarding the proposal from Elite Towers to construct a new wireless telecommunications support structure and associated ground compound at 7055 Main Road, Mattituck, New York. The Application includes information from both Verizon Wireless and AT&T Mobility (co-Applicants). Background CityScape has provided an initial report and three supplemental reports since this application was filed. The application was filed in August 2017 to improve cellular service for Verizon,AT&T and the Fire Department. The original proposal did not comply with the following sections of the Southold Ordinance: §280-70-1 (2)—Structures in LI, LIO, MI, MII, B, HB restrictions—height limited to 80 feet §280-70-1 (3) — Structures in LI, LIO, MI, Mll, B, HB restrictions — Minimum distance to adjacent residential property lines shall be no less than 500 feet X280-70-N4)—Base equipment landscaping §280-72 (A)(9)—Antenna support structures in or adjacent to residential zones Town of Southold/SCTM#1000-122-6-35.4 cityscape Verizon Wireless/Laurel Stone Paget N S U L I A uNI SouNC Waiver of 80-1bot Hei ht Limit There are two purposes for the proposed tower. Cellular service improvement for Verizon and AT&T and coverage improvement for the Mattituck Fire District. CityScape has continued to state that both cellular co-applicants(Verizon &AT&T) have not adequately justified the need for more than an 80-foot tower at the present location. It is apparent from their coverage maps that additional sites will be needed in the future for handoffs to other locations. Increasing the height of this tower will not eliminate the need for future sites. This need for additional sites due to height limitations does not impede their network buildout. Fire District The Applicant has stated that an 80-foot tower is insufficient elevation for the fire district's needs. CityScape received a report from Mr. Dennis Kenter, consultant to the fire station, on September 21,2018,outlining three purported needs for the fire district: paging; portable coverage (walkie talkies);mobile radio coverage(emergency vehicles). The report provided coverage maps comparing an 80-foot versus 120-foot tower at the proposed Laurel Stone site. It does not provide comparison with the current coverage for the fire district. The coverage goals include paging within the district and service to vehicles in route to and fi•om both the Peconic Bay Medical Center in Riverhead, NY and Eastern Long Island Hospital in Greenport. These hospital locations are very distant from the proposed tower and in opposite directions. Reliable service between these centers cannot be achieved with an installation at this location, it will require towers at multiple other locations. The report did not indicate what other sites (towers) the fire district is using or plans to use, other than the existing 120-foot tower at the headquarters in Mattituck. Also, the coverage maps in the report only depict the areas within the Laurel/Mattituck/Cutchogue areas, Without showing coverage to Riverhead or Greenport. The Peconic Bay Medical Center is more than 7 miles to the southwest of the proposed site while the Eastern Long Island Hospital is more Town of Southold/SCTM#1000-122-6-35.4 Verizon Wireless/Laurel Stone cltyscape Page C 0 N S U u, TANTS . � ,„ C than 13 miles to the northeast of the proposed site. It is not believed that either height (80 or 120 feet) at this location will provide reliable service to either hospital, and Mr. Kenter's conclusion that"the District will see a benefit of the 120-foot monopole versus insignificant benefits of an 80- foot monopole" is unsupported by the data and material provided. Indeed, it would appear that either elevation at this location would provide insignificant benefits to the fire district and would be contrary to the purported need for a robust public safety radio system as expressed in the application. The change in location from the 120-foot Mattituck tower to a proposed tower at the Laurel Stone site will essentially shift the coverage to the southwest. Assuming the recommended 80-foot monopole at Laurel Stone, the coverage footprint would actually be reduced due to the height reduction from 120 feet to 80 feet. The location shift would result in essentially the same coverage to the southwest (the location shift would account for the height reduction in this direction), but the coverage to the northeast would be reduced. For an assumed 120-foot tower at the Laurel Stone site the new footprint would essentially be a 1.2-mile shift to the southwest with little change in total area served. It is not believed that a shift in coverage to improve service to the southwest at the expense of losing it to the northeast is a benefit to the fire district when the stated goal is pagers and mobile radios in the district and vehicle service enroute to the Eastern Long Island Hospital. Furthermore, the fire district is essentially abandoning the Mattituck location which it had previously sought and obtained a prior Ordinance waiver because of a stated need for the additional height. CityScape's opinion is that another waiver is not justified in this case when the applicant's report intended to justify the increased height does not depict service to the two hospitals that need this service improvement. Town of Southold /SCTM#1000-122-6-35.4 Cityscape Verizon Wireless/Laurel Stone Page C0N �' Uu, TA "� 'rS , uNc CityScape does agree that increasing the height does offer an incremental benefit by permitting a larger coverage area, when the same locations are considered. Should the 80-foot Laurel Stone monopole be approved, Federal law would permit an applicant to increase the tower height by 20 feet (to 100 feet) irrespective of Town regulations. This further increase in height would permit additional improvement for the fire district when compared to the proposed 80-foot monopole, without the need for a waiver of the height requirement as it would essentially split the difference in coverage between an 80-foot and 120-foot monopole. An approximation of the increase in service footprint to emergency vehicles would be about 0.75 mile from 80 to 100 feet and from 100 to 120 feet or 1.5 miles from 80 to 120 feet. However, the Fire District should strongly evaluate if the proposed shift in coverage to the west will ultimately improve or reduce their overall service. For these reasons, CityScape believes that approval for this site should be based on an 80- foot tower for personal wireless services purposes only. Setback Concerns There are no areas on the subject property that a tower could be placed which would remedy these setbacks. Thus,the proposal will require this waiver to all five of these properties. For such a waiver to be justified, there needs to be proof that no other properties of similar zoning could support a new tower, meet the setbacks and meet the Applicants' coverage goals. CityScape does not believe the Applicant has thoroughly addressed the option of using other parcels. Additionally, in connection with the applicant's suggestion that the applicable"shot clock" under federal rules has been exceeded for Southold to make a determination on this proposal, the applicant's substantive modification of the proposal on July 9, 2018, when the fire district services/needs were revised and used as justification for the proposed elevation reset the shot clock Town of Southold/SCTM#1000-122-6-35.4 Verizon Wireless/Laurel Stone CKYSCape Page 5 �;' a�:a ;� ���, r ii, q, A T S u X C . as a new application, subject to applicable tolling of same during periods of deficiencies in the new application content, and as a result Southold remains within the applicable period for making a determination as to this application under federal law. Tolling of the July 9'", 2018 application commenced when deficiencies to the application and additional questions were identified to the Applicant which tolled the shot clock. On July 26, CityScape asked the Applicant specific questions about how the proposed tower would achieve the fire district's coverage goals. On August 28, CityScape asked for the CV (Curriculum vitae) for the new consultant, Mr. Dennis Kenter. The Town also asked some specific questions about the site on August 21. Each of these items were responded to on September 21, 2018. That correspondence provided a full report from Mr. Kenter, his CV and responses to the Town's questions, which released the tolling period. Assuming no other tolling, the 150-day shot clock would end on February 1, 2019. Conclusion As explained above, CityScape Consultants believes a new, 80-foot concealed tower is justified in the general area for cellular use. Should the Town approve this site, it is important to clarify the justification for this waiver is specific to this location. Section 6409(a) of the Middle- Class Tax Relief and Job Creation Act of 2012 allows immediate approval of up to a 20-foot height increase to eligible facilities (which this new tower would be) for personal wireless service providers. Thus, any future wireless service provider could trigger a one-time 20-foot height increase to this tower. Respectfully submitted, Jonathan N. Edwards, P.E. CityScape Consultants, Inc.