DIR-2023-002 Action LetterCommunity Development Department
Planning Division —Cupertino CITY OF CUPERTINO
CUPERTINO ARBBM'Fkre Avenue, Cupertino, California 95014 (408) 777-3308
Case # D I R-2023-002
To: APpficatio�vl!"Vl�nd City Council Members
Approval Body: Director 9�t erson and Planning Commissioners
Approva I Date 07/20/23
Signature Fro anielle Co Bpjamin Fu, Director of Community Developme
Preparedy3e mkt e Condit, Associate Planner
Date: f my 19, 2023
Subject: Director's Minor Modification, DIR-2023-002, to allow collocation at an
existing base station for (3) new antennas and (6) new RRH; including (3)
new FRP screens and the extension of a section of the existing parapet wall
on the southwest corner of the building fronting the 280 freeway for a
rooftop enclosure for equipment lease area located at 10889 North De Anza
Blvd at the existing Cupertino Hotel, APN 326-10-058.
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, Molly Galvin, of Intelocity, representing Dish Wireless, proposes
collocation at an existing rooftop base station to make additional spectrum available for
5G broadband services. The applicant has proposed to install (3) 5'X7' antenna lease areas,
each with (1) panel antenna, (2) RRH, (3) fiber reinforced polymer (FRP) screens; and (1)
10'x15' equipment lease area, screened by a 12'-8" x 15'-8" rooftop enclosure. The project
is located at an existing personal wireless service facility, located at 10889 North De Anza
Blvd —The Cupertino Hotel —within the Homestead Special Area. The Dish Wireless
facility shares rooftop leased area with two other wireless carrier facilities —Sprint and T-
Mobile. The existing unmanned T-Mobile and Sprint personal wireless service facility
consists of nine panel antennas —mounted behind (3) 10' tall FRP screens, at a height of
approximately 50' above grade. The total number of antennae would increase from 9 to
12, with the anticipation that 3 additional DISH antennas will be submitted for review
under a separate permit, at a later date. Please refer to Figure 1 Site Map below.
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Community Development Department
Ff ajmnlri9tDM*n — Cupertino
tUPERTINO t ' APPROVED'
z ore
Case # 'Z0Q2!►j
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Approval Body: Director / Staff-
Approva I date
Signature
J
N
S. 280 Freeway
• Proposed Antenna Locations
Proposed Equipment Lease Area & Extension of Parapet Wall
DISCUSSION
The project plans propose to add (3) new panel antennas at three new sector locations at
the existing rooftop base station. The antennas will be concealed behind new 10' tall FRP
screens —extending approximately 50' above grade.
Additionally, the plans propose to extend a 12'-8" x 15'-8" section of the existing parapet
wall by approximately 4' height. The modified section of the parapet wall is proposed to
measure to 48' above grade. The purpose of the increased parapet height is to create a
rooftop enclosure to provide adequate screening for the telecommunications
transmission equipment within the proposed equipment lease area. The section of the
modified parapet is located at the southwest corner of the building, fronting 280 freeway.
The line -of -sight study on sheet D-5 of the plans (attachment A), illustrates all off -site
views of the antennas and equipment lease area will be adequately screened in all
directions, as demonstrated from a 300' linear distance, from a street level perspective.
Additionally, the parapet wall extension and FRP screen will mirror the existing building
in both texture and color accordingly.
The General Plan regulates the maximum height of development within the Homestead
Special Area to 45'. The existing building height measured from grade to top of parapet
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Community Development Department
isPiar4air-t'pi.mWoUm-tCqwortil ator shaft at 48'. Although the height of the proposed
CUPERTINO screening `AMR -fib the maximum allowed height —the Code of Federal Regulations
Case # (CFR) MR-2U231002s for some modification to the eligible support structure for
applicAOR64tVptnwioa the requirements of "Section 6409" Wireless Facilities Request,
Approva I Bf j irr ct rTSia`fif "''
Approva I Date 07/20/23
Requirements and criteria for a "Section 6409" Wireless Facilities Request
SignatureI Ile Daniellje Condit lication subject to Section 6409 of the Spectrum Act
as a age
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, in order to
qualify as an "eligible facilities request" and therefore take advantage of the streamlined
approval, it needs to establish that the modification doesn't meet any of the six criteria
per Section 6409. Table 1 below 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.
Table 1: Project conformance with Section 6409
6409 Checklist
Criteria Application
1. It increases the height of the tower by more than 10% or by the The existing building height is
height of one additional antenna array with separation from the 40'-5" from grade to the rooftop.
nearest existing antenna not to exceed twenty feet, whichever is The top of the new DISH
greater; for other eligible support structures, it increases the wireless FRP screen and
height of the structure by more than 10% or more than ten feet, equipment lease area enclosure
whichever is greater. Changes in height should be measuredfrom measures at a height of equal to
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Community Development Department
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Pla finimCDiwAsh ,ortGttpxehttini n cases where deployments are or
or less than 50'-2"from grade.
will be p F40Vgvizontally, such as on buildings' rooftops; in
The project scope will not
othgDFW202�PM2changes in height should be measured from
increase the height of the
t A1mugj,. etower or base s ation, inclusive of originally
existing support structure by
a roved a�'purtenances and any modifications that were
more than which falls within the
ody a f 5t*ebruary 22, 2012.
allowed maximum height
ate 07/20/23
increase.
2. DE huemditinvolves adding an appurtenance to the body of the
None of the added antennas
tower tfttP from the edge of the tower more than
would protrude from the edge of
twenty feet, or more than the width of the tower structure at the
the structure.
level of the appurtenance, whichever is greater. For other eligible
support structures, it involves adding an appurtenance to the
body of the structure that would protrude from the edge of the
structure by more than sixfeet.
3. For any eligible support structure, it involves installation of more
The project scope proposes three
than the standard number of new equipment cabinets for the
new cabinets on the eligible
technology involved, but not to exceed four cabinets; or for base
support structure. The project
stations, it involves installation of any new equipment cabinets
does not exceed four cabinets
on the ground if there are no pre-existing ground cabinets
associated with the structure, or else involves installation of
ground cabinets that are more than 10% larger in height or
overall volume than any other ground cabinets associated with
the structure.
4. It entails any excavation or deployment outside the current site.
The project scope takes place on
the rooftop on an existing
building. No excavation is
proposed.
5. It would defeat the concealment elements of the eligible support
The project scope proposes to
structure.
expand upon the existing
concealment element of the
rooftop parapet wall —by
increasing the height of the
existing parapet within the
allotment outline in criteria 1
above. The utilization and
expansion of the existing
parapet wall and FRP screen
will shroud the antennas and
associated wireless equipment —
camouflaging the wireless
facility as part of the building
structure so that the facility
Community Development Department
CUPERTINO
Case #
Approva I E
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Signature
Planning Division — Cupertino
APP-ROVED
looks like something other than a
tower or base station.
6. It cb1pn2b ffdo2with conditions associated with the siting
None of the proposed changes
apRFV(e W�j16 ruc ion or mo a cation of the eligible support
exceed the thresholds identified
structure or base station equipment, provided however that this
in 1-4 listed above.
o dy:lArt%pW 4Aaffot apply to any modification that is non -
ate conWIMQ12ith the siting approval only in a manner that would
D6gc0bkIte thresholds identified in (1) through (4) above. 47
CFR 1.&Q6fh Wi)-(vi)
Radio Frequency
A joint radio frequency (RF) energy emissions exposure report was prepared by EBI
Consulting to analyze the cumulative RF energy exposure of the antennae (Attachment
B). The calculated RF exposures assesses the proposed (3) panel antennas in the project
scope and (3) future panel antennas —the exposure points of concern are as follows:
Cumulative Maximum RF Energy Exposures
RF Exposure Location
% of Cumulative Public Maximum Permissible
Exposure (MPE) Limit
Ground level
0%
Roof level
3,298.70%
Based on worst -case predictive modeling, the worst -case emitted power density may
exceed the FCC's general public limit within approximately 122' of Dish's proposed
antennas at the main roof level (see Figure 2 below). Modeling also indicates that the
worst -case emitted power density may exceed the FCC's occupational limit within
approximately 36' of Dish's proposed antennas at the main roof level. There are no
structures over one story, within 122' of The Cupertino Hotel within the worst -case
emitted power density radius. Additionally, rooftop access will not be available to the
general public. The RF consultant notes that RF exposure can be significant for
authorized personnel on the rooftop immediately surrounding the antenna. The rooftop
is inaccessible to the guest of the hotel, but the consultant recommends mitigation for
wireless carrier technicians and maintenance staff who service the equipment to prevent
occupational exposures above Federal standards. The consultant recommends control
measures as outlined in the RF report.
Safety Information and Signage has been recommended within Appendix B of the Site
Safety Plan of the RF Report. Safety signage is to be posted at all rooftop access points.
Implementation of the signage and installation of the recommended barriers
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Community Development Department
rlltieimingiffi isin rhhe &1pekifwy Plan will bring this site into compliance with the FCC's
CUPERTINO rules and rApkgv )
Case # D I R-2023-002
Applicat pmb9(RF Report Main Roof Level Simulation
Approva I Body: Director / Staff
Approva I Date 07/29/23 GROUND LEFEL•P
Signature Danielle CI ndit — — — — — — _ i _ _ — ELr„R
Case M pager l
G E G i. R B BM.:IN FOOF. Sff ``
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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. Further, the proposal
complies with Section 6409 of the Spectrum Act of 2012 as detailed in Table 1 above.
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 "Dish Wireless Site ID: SFSF001042A: 10889
North De Anza Blvd Cupertino, CA 95014" prepared by Qualtek Wirless., consisting
of forty-one sheets labeled T-1, A-1 thru A-8, D-1 thru D-5, E-1 thru E-3, G-1 thru G-3,
RF-1 thru RF-5, GN-1 thru GN-4, EME-1, S-1 thru S-4 and RF-1 thru RF4 dated on
5/22/23, except as may be amended by the conditions contained in this resolution.
Community Development Department
Planning Division — Cupertino
CUPERTINO 2. ACCUI Y -' f'HE PROTECT PLANS
Case # TheappJig2*DWerty owner is responsible to verify all pertinent property data
inck�aiag,bnf"Qimited to property boundary locations, building setbacks, property
size, buildi s uare footage, any relevant easements and/or construction records.
Approval BodyA yrec or rreesentation of any property data may invalidate this approval and may
Approva I Date ��
ecluire auuiLicuizti review.
Signature Danielle Condit
Case Manager
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: EBI Project No. 6222002350,
10889 N De Anza Blvd, Cupertino, CA" dated April 11, 2022.
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. 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
"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.
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Community Development Department
P1Th.nirgpp1-W n "Upagom- to (without limitation) reimburse the City its actual
CUPERTINO attorneygi5o,p�0Vpd costs incurred in defense of the litigation. Such attorneys' fees and
Case # costUj"62dtoWamounts paid to the City's outside counsel and shall include City
Atterrtie5ri6 emta d overhead costs and other City staff overhead costs and any costs
Approva I BodYdi�tel�toeetaffto the litigation reasonably incurred by City. The applicant shall
1ikeW��d)��ee to indemnify, defend, and hold harmless the indemnified parties from
Approva I Date
and against any damages, attorneys' fees, or costs awards, including attorneysfees
Signature Danielle Qondit, _ of r„ _„
ode Pr cedure section 1021.5, assessed or awarded against
ase anager
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.
7. 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.
This Director's approval is effective July 19, 2023. The 14-calendar-day appeal period will
expire on August 2, 2023.
Enclosures:
Attachment A: Plan Set
Attachment B: RF Study completed by EBI Consulting titled: EBI Project No. 6222002350,
10889 N De Anza Blvd, Cupertino, CA" dated April 11, 2022.