DIR-2022-024 - Approval Letter CITY OF CUPERTINO
10300 Torre Avenue, Cupertino, California 95014 (408) 777-3308
To: Mayor and City Council Members
Chairperson and Planning Commissioners
From: Luke Connolly, Interim Assistant Director of Community Development
Prepared by: Emi Sugiyama, Associate Planner
Date: March 28, 2023
Subject: Director's Minor Modification, DIR-2022-024, to allow the collocation of
three new antennae and associated equipment to an existing facility located
at 12 Results Way, APN 357-20-046.
Chapter 19.164 of the Cupertino Municipal Code allows for administrative
approval of minor changes in a project. The Director reports his decision
to the City Council and Planning Commission in time to allow an appeal
of the decision within 14 calendar days.
BACKGROUND
The applicant, Derek Turner, of Qualtek Wireless, representing Dish Wireless, is
proposing to collocate three antennae on a personal wireless facility located on an existing
monopine (U-2010-03) in the parking lot of the Apple's Results Way Campus office
buildings located at 12 Results Way
(Figure 1). In addition, the applicant `�"�'
is proposing adding associated
equipment within an expanded
enclosure area. The approved total
number of antennae on the facility
would increase to fifteen.
The existing monopine was ,,
originally approved under Use k
Permit U-2010-03 which is currently
being renewed under Use Permit U- i
2022-007. The project has been ,
McClellan Road
conditioned to ensure that colocation i 11 'fir °�' LAM
Figure 1 Site map
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will not occur on the monopine until such time that the renewal permit is approved and
to ensure consistency with the conditions of approval of U-2022-007 at that time.
DISCUSSION
The proposed Dish Wireless antennae will be collocated on a 75'-10" tall monopine with
twelve other existing antennae from other cell service providers. The equipment will be
screened through use of monopine branches and antenna socks to match the existing
canopy and the overall height of the equipment is proposed to be 42'-0" measured from
equipment centerline.The other existing antennae are between approximately 55'-6" and
68' on the monopine. Adjacent residential properties are located approximately 250 feet
away from the existing pole.
Requirements and Criteria for a "Section 6409" Wireless Facilities Request
The applicant has submitted the application subject to Section 6409 of the Spectrum Act
of 2012. Federal law specifies that a "local government may not deny, and shall approve,
any eligible facilities request for a modification of an existing wireless tower or base
station that does not substantially change the physical dimensions of such tower or base
station." 47 USC 1455(a)(1). This provision appears in Section 6409 of the Spectrum Act
of 2012, which was then codified in the federal government's code. "[T]he term 'eligible
facilities request'means any request for modification of an existing wireless tower or base
station that involves (A) collocation of new transmission equipment; (B) removal of
transmission equipment; or (C) replacement of transmission equipment." 47 USC
1455(a)(2). A local government has 60 days to grant or deny eligible facilities request after
it is submitted.If the local government does not approve or deny the request within those
60 days, unless a tolling agreement is entered into or the shot clock is tolled by a local
government's timely request for additional information to complete an application, the
application can be "deemed granted." 47 CFR 1.6100(c)(4). The deemed grant becomes
effective once the applicant gives the local government written notice that it considers the
application to have been deemed granted.
For carriers seeking to modify an existing wireless tower or base station, to qualify as an
"eligible facilities request" and therefore take advantage of the short shot clock and
streamlined approvals, it needs to establish that the modification doesn't meet any of the
six criteria per Section 6409. Table 1 on the next page provides the criteria details and
comparison with the current application from Dish Wireless. The 6409 Checklist also
demonstrates the eligibility of the project as a streamlined facility.
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Table 1:Project conformance with Section 6409
6409 Checklist
Criteria Application
It increases the height of the tower by more than 10% or by the height The existing monopine
of one additional antenna array with separation from the nearest structure height will not be
existing antenna not to exceed twenty feet, whichever is greater;for increased and proposed antenna
other eligible support structures, it increases the height of the will be added below existing
structure by more than 10% or more than ten feet, whichever is antenna in the existing mock
greater. Changes in height should be measured from the original foliage.
support structure in cases where deployments are or will be separated
horizontally, such as on buildings' rooftops; in other circumstances,
changes in height should be measured from the dimensions of the
tower or base station, inclusive of originally approved appurtenances
and any modifications that were approved prior to February 22,2012.
For towers, it involves adding an appurtenance to the body of the None of the added antenna
tower that would protrude from the edge of the tower more than would protrude further than
twenty feet, or more than the width of the tower structure at the level what was part of the original
of the appurtenance, whichever is greater. For other eligible support approval. Thus,no protrusion of
structures, it involves adding an appurtenance to the body of the the structure is proposed that
structure that would protrude from the edge of the structure by more would exceed the allowances
than six feet. listed.
For any eligible support structure, it involves installation of more One new cabinet, with smaller
than the standard number of new equipment cabinets for the supporting equipment will be
technology involved, but not to exceed four cabinets; or for base added and completely screened
stations,it involves installation of any new equipment cabinets on the from public views and views
ground if there are no pre-existing ground cabinets associated with from the adjacent parking lot.
the structure, or else involves installation of ground cabinets that are
more than 10% larger in height or overall volume than any other
round cabinets associated with the structure.
It entails any excavation or deployment outside the current site. None proposed as no
roundwork will be done offsite.
It would defeat the concealment elements of the eligible support The proposed work will have
structure. limited to no effect on the
existing concealment. Should
additional concealment be
required, the project has been
conditioned to provide
additional screening.
It does not comply with conditions associated with the siting approval None of the proposed changes
of the construction or modification of the eligible support structure or exceed the thresholds identified
base station equipment, provided however that this limitation does in 1-4 listed above.
not apply to any modification that is non-compliant with the shin
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approval only in a manner that would not exceed the thresholds
identified in (1) through (4)above. 47 CFR 1.6100(b)(7)(04vi)
Radio Frequency
A joint radio frequency (RF) energy emissions exposure report dated December 16, 2021
was prepared by EBI Consulting to analyze the cumulative RF energy exposure of the
antennae (Attachment A). The calculated RF exposures at the exposure points of concern
are as follows:
Cumulative Maximum RF Energy Exposures
RF Exposure Location % of Cumulative Public Maximum Permissible
Exposure (MPE) Limit
Nearest walking/working surface 14.97%
to each antenna.
The RF consultant notes that RF exposure can be significant around the antennas. While
the tower is inaccessible to the public,the consultant recommends mitigation for wireless
carrier technicians and maintenance staff who service the equipment in order to prevent
occupational exposures above Federal standards. The consultant also recommends
explanatory signage be placed at the base of the tower. Both of these consultant
recommendations are included as conditions of project approval.
The proposed wireless facility complies with the City's Wireless Communications
Facilities Ordinance (CMC 19.136) and conforms with the City's Wireless Facilities
Master Plan by locating wireless facilities on existing structures.
ACTION
The Director of Community Development deems the project categorically exempt from
environmental review under CEQA Guidelines, Article 19, Section 15301: Existing
Facilities and further deems the modification minor and approves the project with the
following conditions of approval:
1. APPROVED EXHIBITS
Approval is based on exhibits titled "SFSFO01053A 12 Results Way, Cupertino, CA
95014" prepared by QualTek Wireless, consisting of 28 sheets labeled T-1, C-1 and C-
2, A-1 through A-4, D-1 through D-4, E-1 through E-3, G-1 through G-3, RF-1, RF-2,
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GN-1 through GN-4, and SA-1 through SA-5 dated on 11/23/2021, except as may be
amended by the conditions contained in this resolution.
2. ACCURACY OF THE PROTECT PLANS
The applicant/property owner is responsible to verify all pertinent property data
including but not limited to property boundary locations,building setbacks,property
size, building square footage, any relevant easements and/or construction records.
Any misrepresentation of any property data may invalidate this approval and may
require additional review.
3. BUILDING PERMIT REQUIRED
This approval does not constitute building permit approval; a separate building
permit is required.
4. RF SAFETY MITIGATIONS
RF Safety measures are required to protect the health of workers and contractors
authorize to work on equipment located on the tower. Mitigation measures are
detailed in the completed report by EBI Consulting titled: "Radio Frequency
Electromagnetic Energy (RF-EME) Jurisdictional Report" dated December 16, 2021.
5. CONSULTATION WITH OTHER DEPARTMENTS
The applicant is responsible for consulting other departments and/or agencies with
regard to the proposed project for additional conditions and requirements. Any
misrepresentation of any submitted data may invalidate an approval by the
Community Development Department.
6. EQUIPMENT SCREENING
Equipment shall be screened in a manner consistent with the conditions of approval
of U-2010-03 and any new applicable conditions of U-2022-007.
7. CONDITIONAL USE PERMIT RENEWAL
Approval of U-2022-007 shall be obtained prior to the issuance of Building Permits
associated with this project scope.
8. INDEMNIFICATION
As part of the application, to the fullest extent permitted by law, the applicant shall
agree to indemnify, defend with the attorneys of the City's choice, and hold harmless
the City, its City Council, and its officers, employees, and agents (collectively, the
"indemnified parties") from and against any liability, claim, action, cause of action,
suit, damages, judgment, lien, levy, or proceeding (collectively referred to as
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"proceeding")brought by a third party against one or more of the indemnified parties
or one or more of the indemnified parties and the applicant related to any Ordinance,
Resolution, or action approving the project, the related entitlements, environmental
review documents, finding or determinations, or any other permit or approval
authorized for the project. The indemnification shall include but not be limited to
damages, fees, and costs awarded against the City, if any, and cost of suit, attorneys'
fees, and other costs, liabilities, and expenses incurred in connection with such
proceeding whether incurred by the Applicant, the City, or the parties initiating or
bringing such proceeding.
The applicant shall agree to (without limitation) reimburse the City its actual
attorneys' fees and costs incurred in defense of the litigation. Such attorneys' fees and
costs shall include amounts paid to the City's outside counsel and shall include City
Attorney time and overhead costs and other City staff overhead costs and any costs
directly related to the litigation reasonably incurred by City. The applicant shall
likewise agree to indemnify, defend, and hold harmless the indemnified parties from
and against any damages, attorneys' fees, or costs awards, including attorneys' fees
awarded under Code of Civil Procedure section 1021.5, assessed or awarded against
the indemnified parties. The Applicant shall cooperate with the City to enter a
Reimbursement Agreement to govern any such reimbursement.
The Applicant shall agree to (without limitation) reimburse the City for all costs
incurred in additional investigation or study of, or for supplementing, redrafting,
revising, or amending, any document (such as an Environmental Impact Report,
negative declaration, specific plan, or general plan amendment) if made necessary by
proceedings challenging the project approvals and related environmental review, if
the applicant desires to continue to pursue the project.
The Applicant shall agree that the City shall have no liability to the Applicant for
business interruption, punitive, speculative, or consequential damages.
9. NOTICE OF FEES, DEDICATIONS, RESERVATIONS OR OTHER EXACTIONS
The Conditions of Project Approval set forth herein may include certain fees,
dedication requirements, reservation requirements, and other exactions. Pursuant to
Government Code Section 66020(d) (1), these Conditions constitute written notice of
a statement of the amount of such fees, and a description of the dedications,
reservations, and other exactions. You are hereby further notified that the 90-day
approval period in which you may protest these fees, dedications, reservations, and
other exactions, pursuant to Government Code Section 66020(a), has begun. If you
fail to file a protest within this 90-day period complying with all of the requirements
of Section 66020, you will be legally barred from later challenging such exactions.
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This Director's approval is effective March 28, 2023. The fourteen-calendar-day appeal
period will expire on April 11, 2023.
Enclosures:
Attachment A: RF Study completed by EBI Consulting and titled "Radio Frequency
Electromagnetic Energy (RF-EME) Jurisdictional Report" dated December 16, 2021.
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