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HomeMy WebLinkAboutExhibit B - Project Narrative_CSTAM_007 rev2 Exhibit B New Cingular Wireless PCS, LLC d/b/a AT&T Mobility AT&T Site ID: CSTAM_007 and FA#14823074 Project Address: City Streetlight No. SLC0902, located at the northwest corner of 38th Street and Lake Avenue, Newport Beach Project Narrative New Cingular Wireless PCS, LLC d/b/a AT&T Mobility (“AT&T”) is proposing to install a new small cell wireless telecommunications facility to serve residents and businesses in this portion of the community. Small cells are low-power, low-profile wireless communications facilities that improve signal quality and capacity within AT&T’s existing wireless network. The proposed small cell facility will help AT&T provide and improve critical wireless services in this area. AT&T estimates that since the introduction of the iPhone in 2007, mobile data usage has increased 470,000% on its network. AT&T customers’ growing demand for mobile data services will continue to increase. Customer needs require AT&T to design and maintain its network to provide and improve wireless signal quality and to increase data rates sufficient to stream video. Areas that do not meet this minimal standard, or where wireless service is otherwise compromised, represent service issues that must be addressed. Specifically, this proposed small cell facility will improve AT&T’s wireless services by offloading network traffic carried by existing macro facilities in the area. In addition, faster data rates allow customers to get on and off the network quickly, which produces more efficient use of AT&T’s limited spectrum. By placing the small cell facility in areas where AT&T’s existing wireless telecommunications facilities are constrained and where AT&T experiences especially high network traffic, AT&T can address the existing and forecasted demand and support 5G speeds in the near future. Improving signal quality and increasing data speed is critical to providing the mobile experience customers demand and to manage the unprecedented increase in mobile data usage on AT&T’s network. The Center for Disease Control and Prevention (CDC) tracks the rates at which American households are shifting from landlines to wireless telecommunications. According to the CDC’s latest Wireless Substitution Report, more than 70 percent of Americans rely exclusively or primarily on wireless communications in their homes.1 In addition, the FCC estimates that 70 percent of all 911 calls are made from wireless devices.2 And with AT&T’s selection by FirstNet as the wireless service provider to build and manage the nationwide first responder wireless network, each new or modified facility will help strengthen first responder communications. Description of Service and Site Type AT&T selected the proposed facility as the best available means to address its service objectives in this portion of the city. The proposed small cell facility will be located in the public right-of-way, where AT&T has a right to place its equipment pursuant to Section 7901 of the California Public Utilities Code. The proposed node is a Pico cell site and will provide 4G services to the surrounding area. The project will involve the placement of a small antenna and associated small cell equipment enclosed within a replacement streetlight. For this small cell, AT&T proposes to install a 10-inch diameter omni-directional antenna and radios at the 1 See Wireless Substitution: Early Release of Estimates From the National Health Interview Survey, January-June 2018, available at http://www.cdc.gov/nchs/data/nhis/earlyrelease/wireless201812.pdf. 2 See 911 Wireless Services, available at https://www.fcc.gov/consumers/guides/911-wireless-services. Exhibit B Page 2 of 3 top of a replacement streetlight, fully concealed within a 12-inch diameter shroud. The facility will not obstruct pedestrian or vehicular traffic. It will not adversely affect the surrounding properties and will have a minimal physical and aesthetic footprint in this area. In addition, the proposed facility fully complies with applicable design criteria. Therefore, the City can easily make the necessary findings for approval for this small cell facility. The project scope will consist of the following: • Removal and replacement of a streetlight. • Installation of a single omni-directional antenna. • Installation of four remote radio units and raycap disconnect switch within a shroud. • Installation of below grade power and fiber handholds. Project Code Compliance The subject project complies with the City of Newport Beach’s Wireless Telecommunications Facilities Ordinance in the Public Right-of-Way, Chapter 21.49 in the following ways: 1. The proposed wireless facility is a small cell installation to be installed on a replaced streetlight in the public right-of-way to match the existing pole. 2. The project is allowed subject to the city’s approval of a Minor Use Permit. The proposed installation will not interfere with the use of the existing right-of-way. 3. The proposed facility is a low powered antenna designed to work in conjunction with other small cell sites in the area and to off-load capacity from an existing macro facility. The installation will comply with applicable regulations of the Federal Communications Commission as demonstrated in the enclosed FCC Local Official Guide to RF – Appendix A. 4. The replacement streetlight is consistent with the size, shape, style, and design of the existing pole, including the attached light arm. 5. The replacement streetlight, placed within the public right-of-way, does not exceed thirty-five (35) feet in height above the finished grade. 6. No above ground mounted equipment is proposed, and the support equipment is proposed to be placed in underground handholes. 7. All transmission equipment, including remote radio units and the raycap disconnect switch, are fully concealed within the shroud. 8. Signage displayed on the wireless facility will be in the smallest permissible size. There will be no advertising signage. 9. The applicant will conform to all City of Newport Beach requirements. Conformance with FCC Regulations The proposed low powered antenna installation attached to the utility pole is considered categorical excluded by the FCC based on the analysis included in the FCC Optional Checklist for Determination of the Local Official’s Guide to RF (attached). Installations that are categorically excluded are considered to meet or exceed the FCC standards for RF Emissions. Construction, Maintenance and Monitoring Construction of the proposed project will take approximately 30-days. All construction will be done in a manner that minimizes impact to residents and/or businesses in the area. Existing underground or overhead power and fiber connections will be used with minimal trenching. Directional boring will be used when deemed appropriate for each specific location. Exhibit B Page 3 of 3 Maintenance of the subject facility is minimal. The telecom operator will be responsible for maintenance of the telecom facility including, but not limited to, any missing, discolored or damaged screening, all graffiti will be removed promptly, and the facility kept clean and free of litter. Monitoring is typically done from AT&T’s switching offices. If needed, a site visit to change any radio equipment will be coordinated with the city through the appropriate process. Site Preferred Location and Alternative Analysis The City of Newport Beach Code Section 20.49.040 lists the preferred locations for telecommunication facilities to limit adverse visual effects and the proliferation of new or individual telecom facilities in the City. Class 3 is defined as public right-of-way installations where the facility can be installed on a structure located in the public right-of-way. The proposed AT&T small cell facility falls under this category and is the third on the list of preferred locations. The proposed installation is consistent with the approved city designs under the master agreement between AT&T and the City. Due to the slim design, camouflaged antenna, use of existing city structures within the right-of-way, AT&T believes that the changes to the existing streetlights are non-material or aesthetic changes that would not impact the surrounding development of this area. The other preferred locations as listed by code relate to the use of existing non-residential buildings or other structures, which are stealth and fully screened and not visible to the general public. These types of locations or structures are not feasible designs for small cells located within the public right-of-way. AT&T is committed to providing wireless telecommunications services and faster data rates throughout the City of Newport Beach and is doing so by installing the least intrusive technology, with the least intrusive design at the least intrusive locations. Rather than construct traditional tower facilities in or near residential neighborhoods, AT&T is choosing to deploy very small facilities, called “small cells,” that can be installed on utility infrastructure in the public right-of-way. A small cell is a low-powered cell site, which, when grouped with other small cells, can provide coverage in areas where traditional macro wireless facilities are not feasible. Although the signal from each small cell antenna covers a shorter range than a conventional tower site, small cells can be effective tools to help close significant gaps in service coverage or offload capacity with a minimal visual impact. Node CSTAM_007 will help AT&T close a significant gap in this area of the City by the least intrusive means, see attached coverage maps. AT&T has evaluated other locations for this project in the immediate vicinity of the proposed node. Attached is the alternative site analysis with detailed description of each alternative. Statement of Code Compliance The overall site location and design complies with applicable code provisions, the General Plan, and other published siting guidelines. For further analysis regarding the applicable code, please see the attached Statement of Code Compliance. © 2018 AT&T Intellectual Property. AT&T, Globe logo, and DIRECTV are registered trademarks and service marks of AT&T Intellectual Property and/or AT&T affiliated companies. All other marks are the property of their respective owners. AT&T Small Cell Node Site ID: CRAN_RLOS_CSTAM_007 Alternative Sites Analysis May 5, 2020 City streetlight No. SLC0902 located at the northwest corner of 38th Street and Lake Avenue, Newport Beach. 2 Map of Small Cell Node CRAN_RLOS_CSTAM_007 and Alternative Sites On this aerial map, AT&T’s proposed Small Cell Node CSTAM_007 is designated by a red marker and the alternative sites are identified by yellow markers. CSTAM_007 Proposed Node Alt #3 Alt #1 Alt #2 3 Proposed Small Cell Node CRAN_RLOS_CSTAM_007 •AT&T is committed to providing and improving wireless telecommunications services and faster data rates throughout the City of Newport Beach. •Rather than construct traditional macro facilities, AT&T ’s solution is to deploy very small facilities, called “small cells,” that can be installed on utility infrastructure in the public right‐of‐way. •A small cell is a low‐powered cell site,which,when grouped with other small cells,can provide coverage in areas where traditional macro wireless facilities are discouraged. •Small cells are effective tools to provide and improve critical wireless services with a minimal impact. By placing small cells in areas where AT&T’s existing facilities are constrained and where AT&T experiences high network traffic, AT&T can address existing and forecasted demands. •Small Cell Node CRAN_RLOS_CSTAM_007 will improve signal quality and capacity within AT&T ’s wireless network in this portion of Newport Beach. 4 •AT&T proposes to place a Small Cell Node on a replacement streetlight pole in the public right‐ of‐way. (Lat/Long 33.618299, ‐117.934413). The proposed node is located on the northwest corner of 38th Street and Lake Avenue. •AT&T’s proposed node is a stealth facility under City Code §20.49.030(N) and is designed to be as visually inconspicuous as possible. •The proposed node is located within a landscaped planter with tall palm trees, low shrubs and signs. An open area separates this location from nearby residences. •AT&T determined that this location is viable in that necessary utilities are available,and this location is feasible from a radio frequency perspective. The location is free of obstructions and has good line of site to meet coverage objectives.AT&T will need to replace the existing streetlight to accommodate a Small Cell. Small Cell Node CRAN_RLOS_CSTAM_007 -Proposed Location City streetlight No. SLC0902 located at the northwest corner of 38th Street and Lake Avenue •Photo Simulation of Proposed Small Cell 5 •Alternative Site #1 is a city streetlight in the public right‐ of‐way. The site is located approximately 135 feet west of the proposed node.The light is adjacent to a three‐story residential home and fence. •The existing streetlight is approximately 10 feet from the adjacent home and less than 3.5 feet from the existing concrete wall. •Replacement of the existing streetlight will not meet ADA requirements. •A small cell at this alternative location would be infeasible. Small Cell Node CRAN_RLOS_CSTAM_007 –Alternative Site #1 City streetlight No. SLC0903 located on the southwest corner of 38th Street and River Avenue 6 •Alternative Site #2 is a city streetlight in the public right‐ of‐way The site is located approximately 210 feet southeast of the proposed node.The light is adjacent to a two‐ story residential home and fence. •The existing streetlight is approximately 11 feet from the adjacent home and less than 4 feet from the existing fence. •Replacement of the existing streetlight will not meet ADA requirements. •A small cell at this alternative location would be infeasible. Small Cell Node CRAN_RLOS_CSTAM_007 –Alternative Site #2 City streetlight No. SLC0901 located on the southeast corner of 37th Street and Lake Avenue 7 •Alternative Site #3 is a city streetlight in the public right‐ of‐way The site is located approximately 227 feet northwest of the proposed node.The light is adjacent to a single‐story residential home and fence. •The existing streetlight is approximately 7 feet from the adjacent home and less than 3 feet from the existing fence. •Replacement of the existing streetlight will not meet ADA requirements. •A small cell at this alternative location would be infeasible. Small Cell Node CRAN_RLOS_CSTAM_007 –Alternative Site #3 City streetlight No. SLC0904 located on the northwest corner of 39th Street and River Avenue 8 Proposed Small Cell Node CRAN_RLOS_CSTAM_007 Conclusion •The proposed small cell node CRAN_RLOS_CSTAM_007 is an integral part of an overall small cell solution to help close AT&T ’s significant service coverage gap in this portion of Newport Beach. •The proposed small cell will provide wireless telecommunications service and faster data rates to the area residents and visitors. •The proposed small cell is the best available and least intrusive means to help AT&T provide and improve critical wireless services in the surrounding areas, adding low‐power, low‐profile equipment to utility infrastructure in the public right‐of‐way. •The use of a replacement streetlight allows a stealth design for the proposed equipment and antenna. •The proposed installation will enhance wireless communication with the least visual impact to the community. Statement of Code Compliance with Newport Beach Municipal Code (“NBMC”) Chapter 20.49 and Chapter 13.20 Below, we identify the applicable code criteria and demonstrate our compliance or acknowledgement of each provision. 20.49.040 Telecom Facility Preferences and Prohibited Locations. A. Preferred Locations. To limit the adverse visual effects of and proliferation of new or individual telecom facilities in the City, the following list establishes the order of preference of facilities, from the most preferred (1) to least preferred (4). 1. Collocation of a new facility at an existing facility. 2. Class 1. 3. Class 2 and Class 3. 4. Class 4. B. Prohibited Locations. Telecom facilities are prohibited in the following locations: Applicant Response: AT&T is proposing a Class 3 facility that replaces an existing concrete designed streetlight with a new similar concrete designed replacement pole. The design is consistent with the design of the existing pole and the type of infrastructure currently in the right of way. The design is consistent with the designs depicted and allowed pursuant to the Master License Agreement Between the City of Newport Beach and New Cingular Wireless PCS, LLC for the Use of City-Owned Streetlights for Telecommunication Facilities (“MLA”). As explained in the previous Alternative Analysis, a collocation or Class 1 or 2 facility would not be technically feasible in this location from an RF or construction perspective. Small cells are low power and must be located at the precise location selected to serve the network traffic demands of that specific and limited area. This type of service enhancement cannot be accomplished with a traditional macro collocation or building mounted site in this area. The site is not located in any of the locations prohibited by NBMC §20.49.040.B.1-4. 20.49.050 General Development and Design Standards. A. General Criteria. All telecom facilities shall employ design techniques to minimize visual impacts and provide appropriate screening to result in the least visually intrusive means of providing the service. Such techniques shall be employed to make the installation, appearance and operations of the facility as visually inconspicuous as practicable. To the greatest extent feasible, facilities shall be designed to minimize the visual impact of the facility by means of location, placement, height, screening, landscaping, and shall be compatible with existing architectural elements, building materials, other building characteristics, and the surrounding area. Applicant Response: The Applicant has selected a design that minimizes visual impacts and is appropriately screened to result in the least visually intrusive means of providing service. The site will be placed in the right- of-way and will be virtually unnoticeable as this is the type of infrastructure one would expect to see in the right-of-way. The facility is compatible with the architectural design of existing right-of-way infrastructure with respect to color, materials, scale and compatibility with the surrounding area. It matches the existing pole in scale and design and will not result in any net add of right-of-way infrastructure. Utilities are placed below grade and are not visible. In addition to the other design standards of this section, the following criteria shall be considered by the review authority in connection with its processing of any MUP, CUP, LTP, or ZC for a telecom facility: 1. Blending. The extent to which the proposed telecom facility blends into the surrounding environment or is architecturally compatible and integrated into the structure. Applicant Response: The facility blends into the surrounding environment and is compatible and integrated into the replacement structure. It matches the existing pole in terms of scale, color and materials and is consistent with expected infrastructure that exists in the right-of-way. 2. Screening. The extent to which the proposed telecom facility is concealed or screened by existing or proposed new topography, vegetation, buildings or other structures. Applicant Response: The site is screened to the extent that it matches and is concealed within a streetlight replacement pole. 3. Size. The total size of the proposed telecom facility, particularly in relation to surrounding and supporting structures. Applicant Response: The scale and total size of the proposed facility is consistent with existing right-of-way infrastructure. The new luminaire is consistent with the size, location and functioning of the luminaire being replaced. The 9.25” diameter of the new pole is consistent with and substantially similar to the diameter of the existing pole which is 9” at the location being measured. The pole height is almost identical except for the antenna enclosure at the top, which is also consistent with the design in terms of scale and width. The presence of communication equipment at this site will be virtually unnoticeable to the casual passerby. 4. Location. Proposed telecom facilities shall be located so as to utilize existing natural or manmade features in the vicinity of the facility, including topography, vegetation, buildings, or other structures to provide the greatest amount of visual screening and blending with the predominant visual backdrop. Applicant Response: The location in the right-of-way is appropriate as it is consistent with infrastructure expected to be located in the right-of-way. One of the purposes of the right-of-way is to accommodate infrastructure that will serve the needs of the community, so it is the appropriate place for this type of facility. 5. Collocation. In evaluating whether the collocation of a telecom facility is feasible, the criteria listed in subsections (A)(1) through (4) of this section shall be used to evaluate the visual effect of the combined number of facilities at the proposed location. Applicant Response: Collocation on this facility is not technically feasible from an RF and construction standpoint. Requiring a collocation on this facility would increase the visual impact and scale of this site. B. Public View Protection. All new or modified telecom facilities, whether approved by administrative or discretionary review, shall comply with Section 20.30.100 (Public View Protection). Additionally, potential impacts from a new or modified telecom facility to public views that are not identified by General Plan Policy NR 20.3 shall be evaluated to determine if inclusion in Policy NR 20.3 would be appropriate. If deemed appropriate for inclusion, the potential impacts to such public views shall be considered. Applicant Response: This section is not applicable to this facility as it is not in an area that is subject to Public View Protection. C. Height. 1. The Planning Commission or City Council may approve or conditionally approve a CUP for a telecom facility that exceeds the maximum height limit for the zoning district in which the facility is located; provided, it does not exceed the maximum height limit by fifteen (15) feet, only after making all of the required findings in Section 20.49.060(H) (Required Findings for Telecom Facilities). Applicant Response: The height limitation for facilities located in the public right-of-way is 35 feet. NBMC §20.49.050.C.3. The facility complies with this standard as it does not exceed 35 feet. 2. All telecom facilities shall comply with height restrictions or conditions, if any, required by the Federal Aviation Administration, and shall comply with Section 20.30.060(E) (Airport Environs Land Use Plan for John Wayne Airport and Airport Land Use Commission Review Requirements) as may be in force at the time the telecom facility is permitted or modified. Applicant Response: This provision is not applicable to this facility. 3. Telecom facilities installed on streetlights, utility poles, utility towers or other similar structures within the public right-of-way shall not exceed thirty-five (35) feet in height above the finished grade. Applicant Response: The facility complies with this standard as it does not exceed 35 feet. 4. Telecom facilities may be installed on existing utility poles or utility towers that exceed thirty-five (35) feet above the finished grade where the purposes of the existing utility pole or utility tower is to carry electricity or provide other wireless data transmission; provided, that the top of the proposed antennas do not extend above the top of the utility pole or utility tower. Applicant Response: This provision is not applicable to this facility. 5. Telecom facilities disguised as flagpoles may be installed provided they meet applicable height limits for flagpoles provided in Section 20.30.060. Applicant Response: This provision is not applicable to this facility. D. Setbacks. Proposed telecom facilities shall comply with the required setback established by the development standards for the zoning district in which the facility is proposed to be located. Setbacks shall be measured from the part of the facility closest to the applicable lot line or structure. Applicant Response: This provision is not applicable as the facility is located in the right-of-way and replaces an existing structure. Also, the code specifically provides for a setback exception for light standards. NBMC § 20.30.110.D.11. E. Design Techniques. Design techniques shall result in the installation of a telecom facility that is in harmony and scale with the surrounding area, screens the installation from view, and prevents the facility from visually dominating the surrounding area. Design techniques may include the following: Applicant Response: The facility is in harmony and scale with the surrounding area. The new concrete designed pole is substantially similar in size and scale to the existing pole and the materials, design and color match. The facility is compatible with infrastructure that exists in the right-of-way and will be installed in the same location as the pole that is being replaced. The facility will not visually dominate the surrounding area. 1. Screening elements to disguise, or otherwise hide the telecom facility from view from surrounding uses. Applicant Response: The facility is a combination light pole and wireless facility and the antennas and other equipment components will be concealed within the pole. 2. Painting and/or coloring the telecom facility to blend into the predominant visual backdrop. Applicant Response: The facility will be concealed within a light pole and will be the same color and finish as the pole being replaced. 3. Siting the telecom facility to utilize existing features (such as buildings, topography, vegetation, etc.) to screen or hide the facility. Applicant Response: The facility is being sited in the right-of-way and will be installed in the same location as the pole being replaced and will have the same color and finish. 4. Utilizing simulated natural features (trees, rocks, etc.) to screen or hide the telecom facility. Applicant Response: The facility is a light pole replacement, a structure that is expected to be located in the right-of-way, will be installed in the same location as the pole being replaced, and will have the same color and finish. 5. Providing telecom facilities of a size that, as determined by the City, is not visually obtrusive such that any effort to screen the facility would create greater visual impacts than the facility itself. Applicant Response: The facility is not visually obtrusive and is consistent with the size, scale, color and appearance of existing right-of-way infrastructure. 6. To the greatest extent practicable, new Class 4 facilities shall be designed and sited to facilitate the collocation of one additional telecom operator. Applicant Response: This criterion is not applicable as this facility is not a Class 4. F. Screening Standards. For collocation installations, the screening method shall be materially similar to those used on the existing telecom facility, and shall not diminish the screening of the facility. If determined necessary by the review authority, use of other improved and appropriate screening methods may be required to screen the antennas and support equipment from public view. The following is a non-exclusive list of potential design and screening techniques that must be considered for all facility installations: Applicant Response: This criterion is not applicable as this facility is not a collocation. 3. For Class 3 (Public Right-of-Way) Installations. a. Whenever feasible, new antennas proposed to be installed in the public right-of-way shall be placed on existing utility structures, streetlights, or other existing vertical structures. Antenna installations on existing or replacement streetlight poles or utility poles shall be screened by means of canisters, radomes, shrouds other screening measures whenever feasible, and treated with exterior coatings of a color and texture to match the existing pole. Applicant Response: The facility design meets this criterion. The antenna is screened behind a cannister that is on top of the pole. It will be the same color and texture as the existing pole. b. New or replacement vertical structures may be allowed when authorized by the Municipal Code and approved by the Public Works Department. Replacement poles or streetlights shall be consistent with the size, shape, style, and design of the existing pole, including any attached light arms. New poles or streetlights may be installed, provided they match existing or planned poles within the area. Applicant Response: The facility design meets this criterion and is allowed pursuant to the NBMC and the MLA. This replacement pole is substantially the same size, shape, style and design of the existing pole. It also has a luminaire that is the same height and brightness as the existing pole. c. If antennas are proposed to be installed without screening, they shall be flush-mounted to the pole and shall be treated with exterior coatings of a color and texture to match the pole. Applicant Response: This provision is not applicable as the antennas will be screened. 6. Support Equipment. All support equipment associated with the operation of any telecom facility shall be placed or mounted in the least visually obtrusive location practicable, and shall be screened from view. Applicant Response: Support equipment is either concealed or installed below grade and has no visual impact. b. Installations in a Public Right-of-Way. The following is a non-exclusive list of potential screening techniques for telecom facilities located in a public right-of-way: i. Where existing utilities services (e.g., telephone, power, cable TV) are located underground, the support equipment shall be placed underground if required by other provisions of the Municipal Code. Flush-to-grade underground vault enclosures, including flush-to-grade vents, or vents that extend no more than twenty-four (24) inches above the finished grade and are screened from public view may be incorporated. Electrical meters required for the purpose of providing power for the proposed telecom facility may be installed above ground on a pedestal in a public right-of-way provided they meet applicable standards of Title 13 unless otherwise precluded by the Municipal Code. Applicant Response: The utilities serving this facility are either installed below grade or are concealed within the replacement pole. No above ground pedestals are proposed. ii. Support equipment approved to be located above ground in a public right-of-way shall be painted or otherwise coated to be visually compatible with the existing or replacement pole, lighting and/or traffic signal equipment without substantially increasing the width of the structure. Applicant Response: This provision is not applicable as no above ground support equipment is proposed. iii. All transmission or amplification equipment such as remote radio units, tower mounted amplifiers, and surge suppressors shall be mounted inside the utility or streetlight pole without materially increasing the pole diameter or shall be installed in the vault enclosure supporting the facility. Applicant Response: The transmission equipment is concealed within the pole. G. Night Lighting. Telecom facilities shall not be lighted except for security lighting at the lowest intensity necessary for that purpose or as may be recommended by the United States Flag Code (4 U.S.C. Section 1 et seq.). Such lighting shall be shielded so that direct illumination does not directly shine on nearby properties. The review authority shall consult with the Police Department regarding proposed security lighting for facilities on a case-by-case basis. Applicant Response: No lighting is proposed other than the replacement luminaire which is being installed at substantially the same height and is the same brightness as the existing pole. H. Signs and Advertising. No advertising signage or identifying logos shall be displayed on any telecom facility except for small identification, address, warning, and similar information plates. Such information plates shall be identified in the telecom application and shall be subject to approval by the review authority. Signage required by State or Federal regulations shall be allowed in its smallest permissible size. Applicant Response: The facility complies with this criterion. The only signage proposed is the required notice signage, facility owner information and signage and banners required to be installed by the City. I. Nonconformities. A proposed or modified telecom facility shall not create any new or increased nonconformity as defined in the Zoning Code, such as, but not limited to, a reduction in and/or elimination of, required parking, landscaping, or loading zones unless relief is sought pursuant to applicable zoning code procedures. Applicant Response: The facility complies with the code and will not create a zoning code nonconformity. J. Maintenance. The telecom operator shall be responsible for maintenance of the telecom facility in a manner consistent with the original approval of the facility, including but not limited to the following: 1. Any missing, discolored, or damaged screening shall be restored to its original permitted condition. Applicant Response: The Applicant acknowledges that it is responsible for maintaining the site consistent with its original permitted condition. 2. All graffiti on any components of the telecom facility shall be removed promptly in accordance with the Municipal Code. Applicant Response: The Applicant acknowledges this requirement. 3. All landscaping required for the telecom facility shall be maintained in a healthy condition at all times, and shall be promptly replaced if dead, dying, or damaged. Applicant Response: No landscaping is proposed for this installation. 4. All telecom facilities shall be kept clean and free of litter. Applicant Response: The Applicant acknowledges this requirement. 5. All equipment cabinets shall display a legible contact number for reporting maintenance problems to the telecom operator. Applicant Response: The Applicant is not proposing equipment cabinets. 6. If a flagpole is used for a telecom facility, flags shall be flown and shall be properly maintained at all times. The use of the United States flag shall comply with the provisions of the U.S. Flag Code (4 U.S.C. Section 1 et seq.). (Ord. 2014-1 § 10 (part), 2014) Applicant Response: The Applicant is not proposing a flagpole. 20.49.060 Permit Review Procedures. H. Required Findings for Telecom Facilities. The following findings shall apply to all facilities requiring discretionary review: 1. General. The review authority may approve or conditionally approve an application for a telecom facility only after first finding each of the required findings for a MUP or CUP pursuant to Section 20.52.020 (Conditional Use Permits and Minor Use Permits), or an LTP pursuant to Section 20.52.040 (Limited Term Permits), and each of the following findings: a. The proposed telecom facility is visually compatible with the surrounding neighborhood. Applicant Response: The facility is visually compatible with the surrounding area. The facility design is allowed pursuant to the MLA and applicable code and is substantially similar in design, shape, size, color and texture as the existing pole. All related equipment is either installed below grade or is concealed within the interior of the replacement light pole. b. The proposed telecom facility complies with height, location and design standards, as provided for in this chapter. Applicant Response: The 27.5-foot-tall facility complies with the height, location and design standards. It is a Class 3 facility located in the right-of-way and meets the City approved design standards per the code and the MLA. c. An alternative site(s) located further from a residential district, public park or public facility cannot feasibly fulfill the coverage needs fulfilled by the installation at the proposed site. Applicant Response: The Applicant has provided an alternative analysis that addresses this criterion. No alternative site locations would fulfill the network needs that are fulfilled by this installation at this proposed specific location. d. An alternative plan that would result in a higher preference facility class category for the proposed facility is not available or reasonably feasible and desirable under the circumstances. Applicant Response: As explained previously, small cells are designed to enhance network capacity and must be precisely located in a specific area to properly function due to their low power and limited range. A higher preference class facility would not be technically feasible and would not fulfill this specific network need.