HomeMy WebLinkAbout05-11 Statement of JustificationSTATEMENT OF JUSTIFICATION
[To supplement Item No. 12 (additional comments) on the Conditional Use Permit Application]
The Applicant, New Cingular Wireless PCS, LLC dba AT&T Mobility ("AT&T"), is licensed by
the Federal Communications Commission ("FCC") to provide state-of-the-art wireless
communications services within Frederick County, Virginia. Applicant seeks a Conditional Use
Permit ("CUP") pursuant to §§165-103.01-165-103.08 of the Frederick County Zoning Ordinance
("Zoning Ordinance") for a wireless communication facility ("WCF") to be comprised of twelve
(12) antennas mounted at a centerline height of one hundred and seventy feet (170') above
ground level ("AGL") on a new one hundred and seventy foot ("170"')monopole (1T, including
lightning rod). The facility is proposed to be located on Tax Map Parcel No. 12-A-72, 575
Glengary Road, Winchester, Virginia 22603. The proposal will also include the installation of
a11' -5'x20' ancillary equipment shelter and required utility connections near the base of the
monopole. The entire 50'x50' compound will be surrounded by an eight -foot high (8') chain link
fence and five-foot high (5') cattle fence. Access to the facility will be from Glengary Road, an
existing road and will require the proposed twenty -foot wide (20') gravel access road to be
approximately seventy-five feet (750') in length.
COMPLIANCE WITH ZONING ORDINANCE
The subject parcel is located within the Rural Areas ("RA") District. Section 165-204.19 of the
Zoning Ordinance deals with the siting of telecommunications facilities and their consideration
for installation in RA districts through the conditional use permit/public hearing process.
AT&T's CUP application is in compliance with the requirements for submission noted in §165-
204.19(A)(1)-(4) and the standards set forth in §165-204.19(B)(1)-(7). Site plans of the proposal
have been included pursuant to §165-103.06 of the Zoning Ordinance.
The minimum lot area in the RA district is two (2) acres per §165-401.05 of the Zoning
Ordinance. The parcel on which the proposed WCF would be sited ("subject parcel") is 103.48
acres, and because the WCF will be located in a leased area, the lot size of the subject parcel is
not proposed to change with this project. Therefore, lot size remains satisfied.
The only state road adjacent to the subject parcel is Glengary Road. Section 165-401.07(A)(1)
requires a setback of at least sixty feet (60') from the edge of the right-of-way of a secondary
road. As shown on Sheet A-0 of the site plans included with this application, the proposed
improvements will be located approximately three hundred and thirty-one (331') from
Glengary Road. Parcels in the RA district must have side and rear yards of at least fifty feet
(50') (if adjoining parcel is six (6) acres or less) or one hundred feet (100') (if adjoining parcel is
more than six (6) acres). In this case, the improvements will comply because they will be
located 1578'-8", 1317-11", and 720'-6" from the side and rear property lines. Section 165-
401.08(A)(1)(c) mandates that lots fronting on existing state roads have a setback of two
hundred and fifty feet (250') at the front setback line. Here, there is a setback of 331.6'.
AT&T will comply with all applicable federal regulations regarding interference and electro-
magnetic radiation.
The objective of this site is to provide coverage east of Glengary Road (State Highway 690) near
Shockeysville Road, south of State Highway 45, west of Apple Ridge Road and north of State
Highway 127 and to enhance coverage around Little Mountain and the surrounding areas. The
proposed site will provide coverage in an area not currently served by AT&T. Please see the
attached propagation maps showing anticipated coverage from the proposed facility.There are
no existing structures of sufficient height adjacent to the site, and therefore a new tower is
required to provide adequate service in the area. In cases where visibility is a concern, a
monopole design is typically used instead of a lattice or guyed tower. In this case, the use of a
monopole will lessen the visual impact. The Winchester Regional Airport is requesting that the
top of the monopole be marked and lighted. If the Board requires the tower to be lit as a
condition of approval, then AT&T is proposing the installation of a lighting shield which will
minimize the visual impact of the lights to the surrounding area.
An overall pole height of 176' AGL is necessary for radio frequency ("RF") propagation to
sufficiently address the need in this area. The predicted coverage assumes a 12 -antenna array
mounted at 170' AGL. Flush -mounted antennas are not appropriate in this case because this
site is designed to provide coverage to an area not currently served by AT&T and because the
use of flush -mounted antennas would require four (4) centerline heights (with three (3)
antennas each) in order to achieve the 12 -antenna design that the RF engineer has called for.
The use of four (4) flush -mounted arrays at different heights would result in compromised
coverage because antennas mounted at lower heights would not propagate as far. Additionally,
deploying four (4) flush -mounted arrays for one carrier would unnecessarily eliminate the
availability of two (2) rad centers for future collocators and make the remaining available
heights less attractive. This would have the effect of discouraging collocation and would run
contrary to the intent of both the Zoning Ordinance and the Comprehensive Plan.
In compliance with § 86-484.2(5) and as shown on Sheet A-1 of the enclosed plans, the proposed
monopole will be designed to accommodate a total of three additional carriers.
Grading will be limited to the area necessary to construct the WCF and its access road
connecting to Glengary Road.
No painting or staining is proposed, other than that which may be required to meet the
suggestion of the Winchester Regional Airport.
When searching for possible sites to satisfy their RF objectives in a particular search area, AT&T
first looks for existing structures which might be able to accommodate their antennas and
equipment without the need for building a new support structure. In this case, the search area
is generally northwest of Glengary Road, along the border between Virginia and West Virginia.
Aside from existing residences and agricultural buildings, there were no other structures that
were adequate for providing coverage. The search did not reveal any existing WCFs in the area
that could provide opportunity for collocation or mitigation, as the nearest existing WCF is over
four (4) miles away, west of the proposed site, near the intersection of Route 522 and Chapel
Hill Road.
CONSISTENCY WITH THE COMPREHENSIVE PLAN
The 2007 Comprehensive Plan states, "[c]ertain types of business and industrial uses may be
located at scattered rural locations if safe access is available, and if adverse impacts on
surrounding areas and the rural environment can be avoided."
AT&T is committed to providing better coverage to the growing number of subscribers in this
area and doing so with minimal impact to the surrounding community.