Title
Report regarding consideration of a Conditional Use Permit and Design Review for a new Wireless Communications Facility on an existing PG&E tower located on APN 012-102-999, adjacent to 200 Armour Avenue, in the Parks and Recreation (PR) Zoning District in accordance with Title 20 of the South San Francisco Municipal Code (SSFMC), and determination that the project is categorically exempt from California Environmental Quality Act (CEQA), per Class 3, Section 15303. (Stephanie Skangos, Associate Planner)
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RECOMMENDATION
Recommendation
1. Staff recommends that the Planning Commission make a determination that the proposed project is categorically exempt from CEQA and approve a Use Permit (UP22-0009) and Design Review application (DR22-0030) based on the attached Draft Findings and subject to the attached Draft Conditions of Approval.
MOTION TO ADOPT STAFF RECOMMENDATION
1. Move to make CEQA determination and approve project entitlements subject to conditions of approval.
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PROJECT OVERVIEW
The project site, located at the corner of Armour Avenue and Airport Boulevard, is owned by PG&E and includes a City maintained park, Irish Town Greens. There are three existing PG&E transmission towers on the site, two of which have existing wireless communications facilities already installed. The proposed new wireless facility will be installed on the existing PG&E transmission tower closest to Armour Avenue that does not currently contain any wireless facilities.
The new wireless facility for Dish Wireless will consist of three panel antennas, six remote radio units (RRUs), an equipment enclosure with associated equipment, and power and fiber lines. The three antennas will be mounted to the 99-foot-tall transmission tower at an elevation of 53’-0” in three sectors: Alpha to the north, Beta to the South, and Gamma to the East. The six RRUs, two per sector, will be mounted behind the antennas. All antennas and RRUs will be painted to match the transmission tower. An equipment enclosure, approximately 100 square feet, consisting of composite fencing, will be located at the base of the transmission tower within a Dish Wireless lease area and painted to match the enclosures for the existing wireless facilities on the project site. Power and fiber lines will be placed in a cable tray within the new equipment enclosure and run to each antenna location. The project description and plans are attached to this staff report (Attachments 2 and 3).
Dish Wireless has submitted a Radio Frequency - Electromagnetic Energy (RF-EME) Report, completed by EBI Consulting (Attachment 4). The purpose of the study is to ensure compliance with the Federal guidelines limiting human exposure to RF energy. The results of the study indicate that for a person anywhere on the ground, the maximum RF exposure due to the proposed wireless facility is calculated to be 0.25% of the applicable public exposure limit, per Federal Communications Commission (FCC) regulations, and complies with the prevailing standards for limiting public exposure. The site is required to be securely controlled to ensure that members of the general public do not access the facility, and that only authorized personnel may enter the site to perform maintenance and repairs. RF warning and controlled access signage is also required as shown in Appendix B to the RF-EME Report (Attachment 4).
ZONING CONSISTENCY
Zoning District
The site is located in the Parks and Recreation (PR) Zoning District and directly abuts the Downtown Residential - Medium (DRM) and T3 Corridor (TC3) Zoning Districts. The location and design of wireless facilities are regulated by SSFMC Chapter 20.370 (Antennas and Wireless Communications Facilities). According to SSFMC Section 20.370.006 (“Review and Approval Procedures”), the Planning Commission may approve a Use Permit for a wireless communications facility that is mounted to an alternative tower structure (20.370.003(D)(1)(d)) in any nonresidential district located less than 600 feet from a residential district (20.370.003(D)(2)(f)) and complies with all of the standards listed in SSFMC Section 20.370.005 (“Location, Design, and Operation Requirements”). The proposed wireless facility will be located on a transmission tower located less than 600 feet from a residential district, and meets the location, design, and operation requirements, described in detail below.
Design Preferences
Section 20.370.003 (D)(1) of the Zoning Code, ranks the preferred approaches for design and siting of new antennas as follows:
a) Building- or structure-mounted antennas that are not readily visible or are completely concealed from view because of integration into design of nonresidential buildings or structures erected and approved for use other than as wireless telecommunications support.
b) Building- or structure-mounted antennas set back from roof edge and not visible from the public right-of-way or from surrounding properties.
c) On existing communication towers, existing signal, light or similar kinds of permanent poles not supplying electric, telephone or similar service and not in the public right-of-way, or utility facilities not subject to the City’s franchise agreements.
d) Non-building- or structure-mounted alternative tower structures.
The PG&E transmission tower is the lowest-ranked design alternative, as it is a free-standing tower structure and is visible from the public right-of-way. However, the PG&E transmission tower is existing, and the other two transmission towers on the project site have similar existing wireless facilities installed. The applicant has provided technical information demonstrating that a higher-ranked design option is not technically feasible in light of the provider’s service objectives (Attachment 5). Dish Wireless’s service objectives are to provide coverage in the surrounding residential area.
Location Preferences
In addition to the design preferences, Section 20.370.003 (D)(2) outlines six location preferences in order of most desirable to least desirable. The proposed location is within the least desirable location preference, which is a non-residential district and located less than 600 feet from a Residential district. The project site is within the PR zoning district, but directly abuts the DRM and T3C districts. As mentioned previously, the other two PG&E transmission towers located on the project site already have similar wireless facilities installed, and installation of a new wireless facility on the third transmission tower is reasonable.
The applicant has provided an Alternative Sites Analysis (Attachment 5) which summarizes an investigation of potential alternative sites for facilities to fill the identified gap coverage and finds that the proposed site and facility is the least intrusive means by which Dish Wireless can close its significant service gap.
Development Standards
The proposed project meets the applicable requirements of SSFMC Section 20.370.005 (“Location, Design, and Operation Requirements”). The new wireless facility will not exceed the height of the existing tower. Antennas and RRUs will be painted to match the tower, and the equipment enclosure will be designed to match the enclosures for the two existing wireless facilities on the project site. Additionally, the proposed wireless facility will comply with all required operations and maintenance standards, which are included as draft Conditions of Approval.
GENERAL PLAN CONSISTENCY
The General Plan Land Use designation for the site is Open Space. This land use designation is intended to be reserved land for natural and active open space uses. The site is an existing City-maintained park, and the proposed wireless facility will be an ancillary use on an existing PG&E transmission tower.
DESIGN REVIEW BOARD
The Design Review Board (DRB) reviewed the proposal on November 15, 2022, and had no major issues with the proposed wireless facility. However, there was concern with the lack of proposed landscaping around the new equipment enclosure. The project plans called for providing a defensible space consisting of weed block and gravel 15 feet around the transmission tower and new equipment enclosure. The DRB commented that the plans should be revised to replace the weed block and gravel with native seasonal grass to mimic the current landscaping conditions around the two other towers and equipment enclosures. The applicant was receptive to the comment, and the DRB recommended approval with the revised landscaping as a condition (Attachment 6). However, it has come to the attention of staff that the weed block and gravel is a fire mitigation standard required by PG&E, and the DRB comment will be superseded by PG&E requirements.
ENVIRONMENTAL REVIEW
The proposed project is evaluated to be categorically exempt from environmental review under the provisions of the California Environmental Quality Act (CEQA) Class 1, Section 15301, Existing Facilities. The new wireless facility will be installed on an existing PG&E transmission tower and involves negligible expansion of use.
CONCLUSION
The proposed Dish Wireless facility will be located on an existing PG&E transmission tower on a site with two other transmission towers that have current wireless facilities installed. The new wireless facility will meet the service coverage objectives of Dish Wireless and comply with Federal guidelines limiting human exposure to RF energy. Conditions of approval are included to ensure that the wireless facility is constructed as designed and meets City development requirements. Staff recommends that the Planning Commission take the following action:
1. Determine that the wireless communications facility project is categorically exempt from CEQA and approve the entitlements request for Project P22-0070, including Use Permit UP22-0009 and Design Review Permit DR22-0030, based on the attached draft findings and subject to the attached draft Conditions of Approval.
Attachments
1. Draft Findings and Conditions of Approval
2. Project Plans and Photo Simulations
3. Project Description
4. Radio Frequency - Electromagnetic Energy (RF-EME) Report, prepared by EBI Consulting, dated June 16, 2022
5. Alternative Sites Analysis
6. DRB Comment Letter, dated November 15, 2022