DIR-2022-011 - Action LetterCITY OF CUPERTINO
10300 Torre Avenue, Cupertino, California 95014 (408) 777-3308
To: Mayor and City Council Members
Chairperson and Planning Commissioners
From: Benjamin Fu, Director of Community Development
Prepared by: Jeffrey Tsumura, Associate Planner
Date: July 13, 2022
Subject: Director's Minor Modification, DIR-2022-011, to allow the renewal of a
previously approved Director's Minor Modification (DIR-2010-44) for the
continued operation of a T-Mobile personal wireless facility, and removal
of nine existing antennas and installation of six new antennas and
associated equipment to the facility located at 10110 California Oak Way,
APN 342-63-001.
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, Eric Lentz, of Lentz Consulting, LLC, representing T-Mobile, is proposing
to renew its current personal wireless facility located on an existing lattice tower located
at the Monta Vista electrical substation located at 10110 California Oak Way (Figure 1).
In addition, the applicant is proposing the removal of nine existing antennae and
replacing with six new antennae and associated equipment. The approved total number
of antennae would decrease from nine to six.
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Site Map
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Figure 1 Vicinity Map
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DISCUSSION
The original T-Mobile antennas were approved on October 27, 2005, under DIR-2005-27
as a collocation with an existing MetroPCS personal wireless service facility. The scope
of work included six T-Mobile antennas at a maximum height of approximately 47'-4"
feet (45'-0" on -center) and base equipment enclosure under the tower. On January 25,
2011, the T-Mobile panels antennas were renewed and extended for an additional 10
years under DIR-2010-44. The DIR expired on October 27, 2020. During this time, three
additional T-Mobile antennas and three RRU's were added under B-2016-1580 and
installed below the existing antenna arrays at a height of 40'-8" (36'-8" on -center).
The applicant is proposing to remove these existing antennas and RRUs and replace these
sectors with a total of six new antennas, for a net loss of three antennas. The mounts will
be reused, and sectors raised to a height new height of approximately 62'-8" feet at the
highest point measured from grade.
The renewal of expired cell site approvals gives the City the opportunity to check facility
maintenance and assess the state of any previously required camouflage technology to
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determine if improvements can be made in the appearance of existing facilities. In this
case, no camouflage methods were previously required. The equipment color does not
contrast greatly with the steel lattice material, and although the overall height of the
equipment is increasing from approximately 45'-0" to 60'-0" measured from equipment
centerline, adjacent residential properties are located far from the cell facility, ranging
from approximately 657 to 998 feet away.
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, in order 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 T-Mobile. 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 antenna arrays are
of one additional antenna array with separation from the nearest
47'4" (45'-0" on -center) above
existing antenna not to exceed twenty feet, whichever is greater; for
grade. The new antennas will be
other eligible support structures, it increases the height of the
located at a height of
structure by more than 10% or more than ten feet, whichever is
approximately 62'-8" (60'-0"
greater. Changes in height should be measured from the original
on -center), which falls under the
support structure in cases where deployments are or will be separated
maximum height allowance of
horizontally, such as on buildings' rooftops; in other circumstances,
20 feet to qualify for an eligible
changes in height should be measured from the dimensions of the
facilities request.
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 existing ground cabinet
than the standard number of new equipment cabinets for the
will be removed and replaced
technology involved, but not to exceed four cabinets; or for base
with two new cabinets of smaller
stations, it involves installation of any new equipment cabinets on the
dimensions that will replace the
ground if there are no pre-existing ground cabinets associated with
footprint of the existing cabinet.
the structure, or else involves installation of ground cabinets that are
This ground equipment is
more than 10% larger in height or overall volume than any other
completely enclosed within an
round cabinets associated with the structure.
existin wood ence enclosure.
It entails any excavation or deployment outside the current site.
None proposed as no
groundwork will be done.
It would defeat the concealment elements of the eligible support
The proposed work will have no
structure.
effect on the existing
concealment.
It does not comply with conditions associated with the siting approval
The cell facility was approved as
of the construction or modification of the eligible support structure or
a collocation under DIR-2005-
base station equipment, provided however that this limitation does
27. None of the proposed
not apply to any modification that is non -compliant with the siting
changes exceed the thresholds
approval only in a manner that would not exceed the thresholds
identified in 14 listed above.
identified in (1) through (4) above. 47 CFR 1.6100(b)(7)(i)-(vi)
Radio Frequency
A joint radio frequency (RF) energy emissions exposure report was prepared by Site Safe
to analyze the cumulative RF energy exposure of the antennae (Attachment B). 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
Anywhere on ground level.
2.4%
The RF consultant notes that RF exposure can be significant around the antennas. The
tower is inaccessible to the public, 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
explanatory signage at the base of the tower.
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 "SF15002A BA5002 PG&E 10110 California Oak
Way, Cupertino, CA 95014" prepared by WSD Engineering, Inc., consisting of 16
sheets labeled T-1 through T-6, A-1 through A-7, E-1, and G-1 dated on 2/15/22, except
as may be amended by the conditions contained in this resolution.
2. PERMIT RENEWAL/EXPIRATION
The permit is granted for the minimum period of 10 years in accordance with State
law. This permit is renewed with the conditions of approval enumerated under DIR-
2005-27, except the Director's approval is extended to October 27, 2030.
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3. PREVIOUS CONDITIONS OF APPROVAL
All prior conditions of approval through past approvals shall remain in effect unless
superseded by or in conflict with subsequent conditions of approval and as
specifically amended by this Director's Minor Modification approval.
4. 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.
5. BUILDING PERMIT REQUIRED
This approval does not constitute building permit approval; a separate building
permit is required.
6. 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 Christopher Stollar titled: "Radio Frequency
Electromagnetic Fields Exposure Report" dated January 27, 2022.
7. 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.
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
"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'
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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.
This Director's approval is effective July 13, 2022. The fourteen -calendar -day appeal
period will expire on July 27, 2022.
Enclosures:
Attachment A: Plan set
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Attachment B: RF Study completed by Christopher Sollar and titled "Radio Frequency
Electromagnetic Fields Exposure Report" dated January 27, 2022.