Incompleteness Letter 1 (2019-12-19)
CITY OF CAMPBELL
Community Development Department
via electronic mail and USPS
December 19, 2019
Attn: Carl Jones
AT&T Mobility
605 Coolidge Drive, Suite 100
Folsom, CA 95630
carl.jones@epicwireless.net
Re: File No: PLN2019-231
Address: 1770 W. Campbell Avenue
Application: Wireless Facility Request (Conditional Use Permit) // AT&T Mobility
Status: Incomplete
Dear Mr. Jones,
Thank you for your December 3, 2019 application submittal for a request for a new concealed
wireless facility (PLN2019-231) at 1770 W. Campbell Avenue, in the C-1 (Neighborhood
Commercial) Zoning District. Based on a review of the application materials and the Campbell
Municipal Code (CMC) your application has been deemed incomplete. The following additional
information and revisions to the plans are needed in order to continue processing of this
application.
GLOBAL COMMENTS
1. Address: The application indicates a property address of 1770 W. Campbell Avenue.
Prior permits associated with this facility reflected 1630 W. Campbell Avenue as the
project address. While review of the site map would suggest an address between 1740 &
1806 W. Campbell Avenue to be more accurate (consistent with the proposed address of
1770 W. Campbell Avenue) it is recommended to retain 1630 W. Campbell Avenue as
the address of record (revising the plans accordingly) recognizing that some of the plan
sheets (i.e. Sheet C-1) already indicate a project address of 1630 W. Campbell Avenue in
contradiction to the address provided on the cover sheet (Sheet T-1). Regardless of which
address is used – please ensure a consistent address is used throughout the plan set.
2. Context of Review & Maximum Building Height: The subject site is zoned C-1
(Neighborhood Commercial) which has a maximum height of 35-feet (reference CMC
21.10.040). Any facility other than a stealth facility must comply with this maximum
height limit. The proposed tree pole at +/-61 feet would therefore be ineligible for
consideration at the proposed height unless clear and convincing evidence can be
provided that: A) a significant gap in coverage exists; and B) all alternative sites
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identified in the application review process are either technically infeasible or not
potentially viable in accordance with CMC21.34.070 – General Development Standards,
6. Development and operational standards. & CMC 21.34.160 – Limited exemption
from standards. Due to the limited height of the C-1 (Neighborhood Commercial) zoning
district it may be advisable to consider an alternative facility type (i.e. stealth) which
allows exceptions to the maximum height and/or setbacks.
3. Permit Withdraw: Recognizing a high bar is set in the City’s Ordinance for what
constitutes a significant gap in coverage, and providing adequate documentation to justify
such a determination only after an exhaustive search and elimination of other viable
construction options – it may be instead advisable to withdraw the permit request at this
time and be reimbursed for a substantial portion of your application fees (determined
based on staff time expended to date; the majority of fees have not been expended as the
item has not been taken to a public hearing and only undergone one round of review).
After concluding your sites analysis in the event a new site is selected at that time you
would submit a new permit paying new fees.
ADDITIONAL INFORMATION
1. Collocation: The facility involves the removal and relocation of the equipment of
multiple carriers which have their own prior permit approvals. These prior permit
approvals would need to be rescinded or modified as part of this request. These prior
approvals include but are not limited to:
a. PLN2009-139 // PC Res. 3980: Conditional Use Permit to allow installation of
Clearwire wireless-data (‘Wi-Max’) equipment on an existing monopole.
b. PLN2013-33 // PC Res. 4111: Conditional Use Permit to allow modification and
continued operation of an expired Sprint wireless telecommunications facility.
Please identify all existing carriers and provide true and correct copies of all previously
issued permits as required by CMC 21.34.060.J – Prior Permits. Further, it is unclear if
the subject permit would seek to ‘approve’ the equipment to be added subsequently by
separate carriers or if each of those requests are to be separately processed – please
clarify your intention in this regard.
2. Site and construction plans: Please provide a demolition plan showing the removal of the
existing slimline tower CMC 21.34.060.H – Site and construction plans, .5.
3. Visual Simulations: Please provide a visual simulation showing the maximum expansion
of the facility which could occur as a result of a future eligible facility request pursuant to
Section 6409(a) and FCC rules implementing Section 6409 of the Spectrum Act, codified
at 47 U.S.C. 1455 as required by CMC 21.34.060.I – Visual simulations., 4).
4. Tree Removal: The new tower would result in the removal of one more tree(s) that were
required as part of an approved landscaping plan. Please disclose the number, species,
and size of each tree proposed for removal on the plans and submit an application (paying
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all applicable fees and providing all required paperwork) as required by CMC
21.34.060.N – Other Permits.
5. Construction Staging/Phasing Plan: Please provide a construction staging/phasing plan
indicating the location and duration of all associated construction activities in accordance
with CMC 21.34.060.S. – Construction Staging/Phasing Plan. Minimally this exhibit
must include staging of large equipment such as cranes and material storage. While a
small depiction of a staging area was provided on the plans, it was unclear how larger
equipment would be accommodated on the site during construction.
6. Alternative Sites Analysis: Please provide a list of all existing structures considered as
alternatives to the proposed location, together with a general description of the site design
considered at each location. The applicant must also provide a written explanation for
why the alternatives considered were unacceptable or infeasible, unavailable or not as
consistent with the development standards in this chapter as the proposed location. This
explanation must include a meaningful comparative analysis and such technical
information and other factual justification as are necessary to document the reasons why
each alternative is unacceptable, infeasible, unavailable or not as consistent with the
development standards in this chapter as the proposed location. If an existing facility is
listed among the alternatives, the applicant must specifically address why the
modification of such existing wireless communications facility is not a viable option in
accordance with CMC 21.34.060.S. – Alternatives Site Analysis.
Please be advised that the proposed faux tree is not considered a ‘stealth facility’ and is
therefore not exempt from this requirement. Minimally this assessment should include an
evaluation of other buildings/towers onsite and why those locations were not evaluated in
the site selection process. Please be advised that the City’s Design Requirements favors
the use of stealth facilities, over concealed facilities such as the faux tree that has been
proposed.
7. Design Requirements: If a faux tree is to be pursued at the site (recognizing the design
requirements would favor a stealth facility type; such as antennas integrated into an
existing building/cupola/tower) please provide additional information to aide in the
assessment of the quality and ‘species’ of the tree selected as follows:
a. Please provide information on the quality and longevity of materials (branches &
bark), paint, and finish.
b. Species selection. Please explain why a Eucalyptus was selected as the appropriate
species based on the surrounding trees in the area. Further, be advised that the City’s
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Design Requirements only encourage the use of faux trees where such placement
would generally occur in a grove of trees of a similar species. Such a grove is then
used to determine the appropriate height, color of the tree – which resultantly become
aspects of its concealment design. In this instance, the tree appears to stand alone in a
parking lot – and vastly exceed the height of typical trees in the area (regardless of
species). It may be advisable to consider planting mature trees with the facility to
create a grove, but it is important to consider a tree may not be appropriate at all for
the location.
c. Please provide a written response and/or exhibits demonstrating compliance with
each of the standard requirements for faux trees (a. through j.) specified on Sheet 10
of the City’s Design Requirements for Wireless Facilities.
d. V-Shaped Trees. The facility design appears to ‘columnar’ where a ‘v-shaped’
appearance would be more appropriate for the selected species (Eucalyptus). It is
therefore recommended to amend the design of the branches to achieve an appearance
more consistent with the species. This may be achieved by extending branch lengths
by using a more reinforced branch.
DEPARTMENTAL REVIEW
This application was also reviewed by the Public Works Department, Fire District, and Building
Division. Preliminary comments and anticipated conditions (where applicable) from their review
have been provided for your reference. Fire Department comments were not available at the
time of this transmittal and will therefore be provided under separate cover.
When resubmitting please be sure to provide three (3) 24x36 sets of plans, three (3) 11x17 sets,
and a digital copy of all resubmittal materials (usb).
PERMIT EXPIRATION
Please be advised that applications that are deemed incomplete must be resubmitted within one
hundred eighty calendar days after notification of incompleteness, or the application shall be
deemed withdrawn without refund of application fees in accordance with CMC Sec.
21.38.040.C. (Expiration of application).
If you should have any questions regarding these comments, I may be contacted at (408) 866-
2142 or by email at stephenr@campbellca.gov.
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Sincerely,
Stephen Rose
Associate Planner
enc: Department Review Comments
cc: Paul Kermoyan, Community Development Director