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■ Butte County Planning Commission Agenda Report ■
■ September 26, 2019 ■ AT&T Mobility dba AT&T Wireless - UP19-0001 Agenda Report ■ Page 1 of 12 ■
BUTTE COUNTY PLANNING COMMISSION
AGENDA REPORT – September 26, 2019
Applicant: AT&T Mobility dba AT&T
Wireless c/o Sara King
Parcel Size: 9.98 acres
Owner: Catherine C. Dunning Project Size: 1,200 SF (plus easements)
File #: UP19-0001 G.P.: Foothill Residential
Request: A Conditional Use Permit to
construct a wireless
telecommunication facility that
includes a 150-foot tall lattice
tower.
Zoning: FR-20 (Foothill Residential
20-acre minimum)
Zone Date: December 10, 2012
APN: 072-310-053
Supervisor
District:
1
Planner: Mark Michelena
Location: 129 Rosie O’Grady Lane,
Forbestown
Attachments:
A: Resolution with Use Permit and
Conditions of Approval (Exhibit A)
B: Zoning Map and Vicinity Map
C: Initial Study/Mitigated Negative
Declaration
D: RF Statement & Site Justification
E: Height Justification
F: Photo Simulations
G: Plans
EXECUTIVE SUMMARY:
AT&T Mobility dba AT&T Wireless, is requesting approval of a Conditional Use Permit to construct
a wireless telecommunication facility that includes a 150-foot tall lattice tower, 12 panel antennas,
24 remote radio heads/units, an 8-foot by 8-foot (10 feet tall) walk in equipment shelter and a 30kw
backup diesel generator (with 190 gallon capacity belly tank) within a 1,200 square foot (30 x 40)
lease area. Utilities will be run underground, except for the coax between their equipment, which will
be on an ice bridge to the tower. The lattice tower and ground equipment facility will be situated
within a 1,200 square foot lease area that will be surrounded with a six-foot tall chain link fence with
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barbed wire. Access to the facility will be provided by a 12-foot wide driveway from Rosie O’Grady
Lane.
Staff recommends adoption of the attached resolution, adopting the Mitigated Negative Declaration
pursuant to the California Environmental Quality Act (CEQA), and approving Conditional Use
Permit UP19-0001 with findings and conditions.
PROJECT DESCRIPTION:
The applicant requests a Conditional Use Permit to construct a wireless telecommunication facility
that includes a 150-foot tall lattice tower, 12 panel antennas, 24 remote radio heads/units, an 8-foot
by 8-foot (10 feet tall) walk in equipment shelter and a 30kw backup diesel generator (with 190
gallon capacity belly tank) within a 1,200 square foot (30 x 40) lease area. Utilities will be run
underground, except for the coax between their equipment, which will be on an ice bridge to the
tower. The lattice tower and ground equipment facility will be situated within a 1,200 square foot
lease area that will be surrounded with a 6-ft tall chain link fence with barbed wire. The unmanned
facility will provide enhanced wireless network coverage 24 hours a day, 7 days a week.
Access to the facility will be provided by a 12-foot wide driveway from Rosie O’Grady Lane.
SITE CHARACTERISTICS:
The 9.98-acre project site is developed with a residential dwelling and accessory structures.
The project parcel is located at 129 Rosie O’Grady Lane, approximately 1,400 feet east of
Forbestown Road, east of Oroville.
The project site has an approximate elevation of 2,045 feet above sea level.
The subject property is covered with pines, oaks, manzanita and other ground cover.
There are no waterways on, or near, the project parcel.
The project site vicinity is characterized as primarily rural residential and grazing uses on
parcels ranging in size from 8.2 to 163 acres in size.
The project parcel is identified as being within a flood zone “X” (unshaded) as shown on the
applicable Federal Emergency Management Agency Flood Insurance Rate Map.
The site is not within an Alquist-Priolo Earthquake Fault Zone or an aftershock zone, but is
located approximately 5.43 miles east of the Cleveland Hills Fault, the only known active fault
trace in Butte County.
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Aerial Photo of Subject Property and Surrounding Parcels
ANALYSIS:
Zoning Consistency
The subject property is zoned FR-20 (Foothill Residential 20-acre minimum).
Wireless Communication Facilities are regulated by Article IV, Division 2,
Telecommunication Facilities, of the Butte County Code. The Purpose (Section 24-176) is to:
A. Allow reasonable opportunities for wireless communication providers to provide such
services to the community in a safe effective and efficient manner.
B. Encourage the location of new monopoles, towers and antennas in non-residential areas,
thereby discouraging the need for such facilities in residential areas.
C. Minimize the total number of antennas through the county.
D. Encourage co-location of facilities at appropriate new and existing monopoles, towers and
antenna sites.
E. Encourage wireless communication providers to locate new monopoles, towers and
antennas in areas that minimize adverse impact on agricultural and air navigation.
F. Require wireless communication providers to design and configure wireless
communication facilities in a way that minimizes visual impacts.
G. Protect the public’s interest in the safe operation of emergency services such as air
ambulance, medical and air evacuation, firefighting, law enforcement, search and rescue,
vector control, and resource management.
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The following highlights General Requirements for Telecommunication Facilities:
Section 24-176 (Purpose)
A. Allow reasonable opportunities for wireless communication providers to provide such
services to the community in a safe effective and efficient manner.
B. Encourage the location of new monopoles, towers and antennas in non-residential areas,
thereby discouraging the need for such facilities in residential areas.
C. Minimize the total number of antennas through the county.
D. Encourage co-location of facilities at appropriate new and existing monopoles, towers and
antenna sites.
E. Encourage wireless communication providers to locate new monopoles, towers and
antennas in areas that minimize adverse impact on agricultural and air navigation.
F. Require wireless communication providers to design and configure wireless
communication facilities in a way that minimizes visual impacts.
The proposed lattice tower is located within a residential zone, with surrounding uses
characterized as rural residential and grazing/open land on parcel sizes ranging from 8.2
to 163 acres in size. The proposed site will allow current and future AT&T customers to have
access to wireless services in the areas shown on the Coverage Plots included in this
application. This site is intended to improve wireless coverage to the area consistent with the
applicant’s Service Improvement Objective and will increase the network capacity. The new
wireless communication facility will provide both improved indoor and outdoor service to
residents. This network will provide an extremely valuable service to those who live, travel,
and do business in the local area. It will give people the ability to call for emergency services
in the event of an accident, the ability to communicate with employees or clients outside of the
office, and the ability to communicate with family members when needed. The project
engineer has indicated that the proposed location will provide the necessary coverage and
capacity with the ability to hand off the wireless signal to the next telecommunications site.
This will enable travelers and community members to have reliable and continuous wireless
coverage.
Section 24-181 (General Requirements):
A. Setbacks.
1. Except when specifically allowed, all new telecommunication facilities shall be located
on a parcel so that the distance from the base of facility to the parcel boundary is equal
to or greater than the height of the facility. (Reduced setbacks are allowed in the
agriculture zones and non-residential zones with conditions specified in 24-181 A.2 to
A.4.)
The 1:1 setback was adopted, in part, to minimize impacts to surrounding properties
and residences and minimize potential exposure to RF emissions. The proposed lattice
tower is located 150 feet from the north and east property lines, and well over 150 feet
from the south and west property lines. The proposed tower meets the required setback.
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B. Height.
1. The maximum height for telecommunication facilities in all zones shall be 100 feet,
except in Commercial and Industrial zones where it shall be 150 feet. Section 24-
181B.1 specifies that the review authority may approve additional height based on
justifiable need.
AT&T is proposing a new wireless telecommunication tower at a height of 150 feet
Above Ground Level (AGL) which exceeds the height allowance of 100 feet in a non-
commercial or industrial zone as described in Article 26, Section 24-181-B 1 of the
Butte County Telecommunications Facilities Standards. The request by the applicant’s
engineers for approval of an additional 50 feet of height for the tower is essential for
the site in order to reach as many living units in the area as possible, and provide clear,
consistent indoor-outdoor wireless coverage and broadband internet service to the
community consistent with the Service Improvement Objective. If the proposed lattice
tower was restricted to 100 foot in height it would not be possible for AT&T to reach
its coverage objective, and provide the local community and surrounding area with the
proposed wireless and broadband internet service. See attached coverage maps
showing a 100-foot and 150-foot tall tower.
In support of their proposal, the applicant has provided coverage maps detailing the
coverage that would be provided with a 100-foot lattice tower, versus the coverage
provided by the proposed 150-foot lattice tower. In comparing these two coverage
maps, there is a significant increase in area coverage to surrounding communities, as
a direct result of the increased height of the proposed tower. In addition, approval for
the proposed 150-foot lattice tower will provide capacity for co-location opportunities
for other wireless service providers to the area, leading to a reduced number of cell
towers required to provide coverage in Butte County.
Section 24-183 (Standards for Types of Facilities):
C. Monopoles or Towers.
1. New monopoles or towers proposed in or within 1,000 feet of agriculture and
residential zones require written notice, in a manner approved by the Zoning
Administrator, to be given to owners of parcels located within a minimum radius of
1,000 feet of the parcel on which the proposed monopole or tower will be located.
Property owners within 1,000 feet were notified of the public hearing for the project.
2. Monopoles or towers in agricultural or residential zones shall not exceed 30 feet in
height except when:
a. No feasible alternative site exists;
b. A denial would constitute a prohibition on the provision of the affected wireless
communication service in violation of federal or State law.
The area surrounding the project site is primarily a rural residential area. The
applicant’s Service Improvement Objective requires the communication facility to
be located at a higher elevation to address the service coverage gap for the area.
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There are additional parcels that can provide the necessary parcel size to meet the
required setbacks and the location to provide the necessary additional coverage
area, but do not provide an enough elevation difference to reduce the height of the
tower. Based on this analysis, no feasible alternative site exists that would reduce
the height of the proposed lattice tower to 30 feet or less.
General Plan Consistency
General Plan goals and policies were evaluated in the context of the proposed project. Seven goals
and eleven policies were identified as being applicable to the project. The following table
identifies each applicable goal and policy, and a review of the project’s consistency with each
policy. Policies followed by an asterisk (*) are required by the General Plan as means to mitigate
environmental impacts under the California Environmental Quality Act (CEQA) and are
considered mandatory.
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General Plan 2030 Goals and Policies Consistency Review
CONSERVATION AND OPEN SPACE ELEMENT
GOAL COS-1. Reduce greenhouse gas emissions to
1990 levels by 2020.
Consistent. This goal is more specifically
reviewed in the discussion of the policies
below.
COS-P1.1. Greenhouse gas emission impacts from
proposed development projects shall be evaluated as
required by the California Environmental Quality Act
(CEQA).
Consistent. The Initial Study, prepared
pursuant to the CEQA, evaluated whether the
proposed project would cause an adverse
impact from greenhouse gas emissions, and
whether the project is consistent with the
Butte County CAP.
COS-P1.2. New development projects shall mitigate
greenhouse gas emissions on-site or as close to the site
as possible.
Consistent. Cal Green development
measures will be applied in the design of the
facility, with the use alternative fuels for
construction equipment and limiting
construction equipment idling times applied
during construction.
GOAL COS-2. Promote green building, planning and
business.
Consistent. This goal is more specifically
reviewed in the discussion of the policies
below.
COS-P2.2. New development shall comply with Green
Building Standards adopted by the California Building
Standards Commission at the time of building permit
application, including requirements about low- or no-
toxicity building materials.
Consistent. Cal Green development
measures will be applied in the design of the
facility, at the time of the building permit
application.
GOAL COS-5. Minimize air pollutant emissions. Consistent. This goal is more specifically
reviewed in the discussion of the policies
below.
COS-P5.2. Developers shall implement best
management practices to reduce air pollutant emissions
associated with the construction and operation of
development projects.*
Consistent. The project includes an air quality
mitigation measure that contains best
management practices in the suppression of
dust and other air pollution emissions during
construction activities.
GOAL COS-15. Ensure that new development does
not adversely impact cultural resources.
Consistent. This goal is more specifically
reviewed in the discussion of the policies
below.
COS-P15.1. Areas found during construction to contain
significant historic or prehistoric archaeological artifacts
shall be examined by a qualified consulting
archaeologist or historian for appropriate protection and
preservation. Historic or prehistoric artifacts found
during construction shall be examined by a qualified
consulting archaeologist or historian to determine their
significance and develop appropriate protection and
preservation measures.*
Consistent. Mitigation measures have been
included that address the recovery of cultural
resources, and identification of human
remains, should any be discovered through
future grading activities on the resultant
parcels.
COS-P15.2. Any archaeological or paleontological
resources on a development project site shall be either
preserved in their sites or adequately documented as a
condition of removal. When a development project has
sufficient flexibility, avoidance and preservation of the
resource shall be the primary mitigation measure.*
Consistent. Mitigation measures have been
included that address the recovery of cultural
resources, and identification of human
remains, should any be discovered through
future grading activities on the resultant
parcels.
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General Plan 2030 Goals and Policies Consistency Review
GOAL COS-16. Respect Native American culture
and planning concerns.
Consistent. This goal is more specifically
reviewed in the discussion of the policies
below.
COS-P16.4. If human remains are located during any
ground disturbing activity, work shall stop until the
County Coroner has been contacted and, if the human
remains are determined to be of Native American origin,
the NAHC and most likely descendant have been
consulted.*
Consistent. Mitigation measures have been
included that address the recovery of cultural
resources, and identification of human
remains, should any be discovered through
future grading activities on the resultant
parcels.
GOAL COS-17. Maintain and enhance the quality of
Butte County's scenic and visual resources.
Consistent. This goal is more specifically
reviewed in the discussion of the policies
below.
COS-P17.1. Views of Butte County's scenic resources,
including water features, unique geologic features and
wildlife habitat areas, shall be maintained.*
Consistent. No scenic resources were
identified within the project area that would be
adversely impacted by the proposed project,
including any substantial water features,
unique geological features, or wildlife habitat
areas.
HEALTH AND SAFETY ELEMENT
GOAL HS-1. Maintain an acceptable noise
environment in all areas of the county.
Consistent. This goal is more specifically
reviewed in the discussion of the policies
below.
HS-P1.7. Applicants for discretionary permits shall be
required to limit noise-generating construction activities
located within 1,000 feet of residential uses to daytime
hours between 7:00 a.m. and 6:00 p.m. on weekdays
and non-holidays.
Consistent. The project is subject to the
County's noise control ordinance, which
requires that construction activities occur
during daytime hours to be exempt from the
County's noise standards.
HS-P1.8. Noise from generators shall be regulated near
existing and future residential uses.
Consistent. Proposed use of generators at
the facility are subject to the County's noise
control ordinance.
HS-P1.9. The following standard construction noise
control measures shall be required at construction sites
in order to minimize construction noise impacts: (a.)
Equip all internal combustion engine driven equipment
with intake and exhaust mufflers that are in good
condition and appropriate for the equipment. (b.)
Locate stationary noise-generating equipment as far as
possible from sensitive receptors when sensitive
receptors adjoin or are near a construction project area.
(c.) Utilize quiet air compressors and other stationary
noise-generating equipment where appropriate
technology exists and is feasible.*
Consistent. Noise control measures are
standard in the construction industry and are
commonly used to minimize noise impacts to
surrounding uses.
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Criteria for Granting a Conditional Use Permit
The criteria for granting a conditional use permit for the 150-foot tall lattice tower and ground
equipment derive both from the generally criteria for granting all use permits (BCC Section 24-
222) as well as the specific criteria for Monopole Facilities (BCC section 24-183 C 1 & 2).
BCC section 24-222 Findings
A. The proposed use is allowed in the applicable zone.
The project is zoned FR-20 (Foothill Residential 20-acre minimum). The FR-20 Zone
identifies new towers or poles as requiring a conditional use permit.
B. The location, size, design, and operating characteristics of the proposed use will be
compatible with the existing and future land uses in the vicinity of the subject property.
The 9.98-acre project parcel is developed with a residential dwelling and accessory
structures. The project site area has been disturbed and is surrounded by mixture of
pine and oak trees. The project site has an approximate elevation of 2,045 feet above
sea level and slopes from east to west. The proposed project will require the removal
of one pine tree. The subject property is substantially covered with pines, oaks,
manzanita and other vegetation and therefore the removal of one pine tree will not
significantly impact the vegetative canopy coverage of oak trees and pine trees.
This vegetation in the project site area is not particularly dense, but the surrounding
area is particularly dense, which will substantially reduce the facility’s visibility from
public rights of way and surrounding properties. Based on these distances, the location
proposed will not substantially degrade the existing visual character of the site and is
not expected to result in a significant impact to scenic vistas and to the area’s visual
aesthetics.
C. The proposed use will not be detrimental to the public health, safety, and welfare of the
County.
The Federal Communications Commission (FCC) is the government agency
responsible for the authorization and licensing of facilities such as cellular towers that
generate radio frequency (RF) radiation. For guidance in health and safety issues
related to RF radiation, the FCC relies on other agencies and organizations for
guidance, including the Environmental Protection Agency (EPA), Food and Drug
Administration (FDA), the National Institute for Occupational Safety and Health
(NIOSH) and Occupational Safety and Health Administration (OSHA), which have all
been involved in monitoring and investigating issues related to RF exposure. The FCC
has developed and adopted guidelines for human exposure to RF radiation using the
recommendations of the National Council on Radiation Protection and Measurements
(NCRP) and the Institute of Electrical and Electronics Engineers (IEEE), with the
support of the EPA, FDA, OSHA and NIOSH. According to the FCC, both the NCRP
exposure criteria and the IEEE standard were developed by expert scientists and
engineers after extensive reviews of the scientific literature related to RF biological
effects. The exposure guidelines are based on thresholds for known adverse effects, and
they incorporate wide safety margins. In addition, under the National Environmental
Policy Act (NEPA) the FCC is required to evaluate transmitters and facilities for
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significant impacts on the environment, including human exposure to RF radiation.
When an application is submitted to the FCC for construction or modification of a
transmitting facility or renewal of a license, the FCC evaluates it for compliance with
the RF exposure guidelines, which were previously evaluated under the National
Environmental Policy Act (NEPA). Failure to show compliance with the FCC’s RF
exposure guidelines in the application process could lead to the additional
environmental review and eventual rejection of an application. The proposed
telecommunication facility is subject to the FCC exposure guidelines, and must fall
under the FCC’s American National Standards Institute (ANSI) public limit standard
of .58 mW/cm2.
Wireless communication systems are, by design and operation, low-power devices.
Even under maximum exposure conditions, in which all channels are operating at full
power, public exposure from a wireless facility will typically be less than 3 microwatts
per centimeter squared (µW/cm2). This exposure is more than 1,200 times lower than
the current American National Standards Institute (ANSI) and the National Council on
Radiation Protection and Measurement (NCRP) report public exposure standards. The
current ANSI and NCRP maximum allowable exposures are set at levels 50 times
higher than what the majority of the scientific community believes may pose a health
risk to human populations.
An Electromagnetic Energy (EME) Exposure Report (attached to the IS/MND) was
prepared by OSC Engineering on February 18, 2019 to determine RF-EME exposure
levels from the proposed AT&T wireless equipment at the project site (see attached). The
Federal Communications Commission (FCC) has developed Maximum Permissible
Exposure (MPE) Limits for general public exposures and occupational exposures. This
report summarizes the results of RF-EME modeling in relation to relevant FCC RF-EME
compliance standards for limiting human exposure to RF-EME fields.
Based on worst-case predictive modeling, there are no modeled exposures on any
accessible rooftop or ground walking/working surface related to AT&T's proposed
antennas that exceed the FCC's occupational and/or general public exposure limits at this
site.
The proposed communications facility is expected to have a 30kw backup diesel
generator (with 190-gallon capacity belly tank) on a concrete slab. The proposed
communications facility will also have large batteries within the equipment cabinets.
Such batteries are typically classified as non-hazardous material for transportation.
The use of these batteries on the project site is not expected to create any hazardous
materials or emissions. The Butte County Environmental Health Division requires that
the applicant complete a “Hazardous Materials Release Response Plan” pursuant to
the California Health and Safety Code”.
A building permit is required for construction of the proposed communications facility,
which will ensure the engineered structure will adhere to building safety standards in
the California Building Code.
D. The proposed use is properly located within the County and adequately served by
existing or planned services and infrastructure.
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Implementation of the project would not require domestic water or wastewater
treatment, or solid waste facilities. It would not be in conflict with any statutes or
regulations relating to solid waste, nor would it employ equipment that would introduce
interference into any system.
The project would not increase the level of demand for fire protection service needed
on the site because communication towers do not normally require such services.
The proposal would not result in an increase in demand for school facilities in the area.
The project would not result in any impacts to area parks and facilities.
E. The size, shape, and other physical characteristics of the subject property are adequate
to ensure compatibility of the proposed use with the existing and future land uses in the
vicinity of the subject property.
The project site is zoned FR-20, with rural residential development in the surrounding
area. The overall size of the project, approximately 1,200 square feet, along with the
12 foot wide access and utility easement, on the 9.98-acre parcel, encompasses
approximately 2.5% of the project parcel. The project, together with the required
conditions, complies with the required findings to approve a use permit.
Land Use
The project would not result in a significant increase in air emissions, fugitive dust
emissions, light, noise, or vehicle traffic.
Only a minor amount of construction activity would be required to install the proposed
tower and ground related equipment.
The project site is not located within an Airport Compatibility Zone.
The project site is located with the General Plan’s Military Airspace Overlay (MAO).
This area applies to all structures over 500 feet above ground level.
Agency Review
The project application materials were circulated to, Environmental Health, Public
Works/Land Development, Cal Fire/Butte County Fire, Assessor’s Office, and
NAVFACSW Intergovernmental Branch AM-3.
ENVIRONMENTAL REVIEW:
In compliance with Section 15073(a), the Initial Study/Mitigated Negative Declaration (IS/MND),
application, and reference documents for this project were placed on file for public review and
comment for a thirty day period starting August 27, 2019 through September 25, 2019. Notices
regarding the 30-day review period were mailed to landowners near the project site, and a notice
was placed in the Chico Enterprise Record and Oroville Mercury Register. Pursuant to California
Public Resources Code Section 15073(d), the Department of Development Services determined
that this project is not a project where one or more state agencies would be a “responsible” or a
“trustee” agency or would exercise jurisdiction by law over natural resources affected by the
project. Therefore, this project is not of statewide, regional, or area wide environmental
significance.
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The Initial Study prepared for this project determined there may be potential environmental
impacts to the following areas:
Air Quality
Biological
Cultural Resources
Tribal Cultural Resources
The Initial Study, which is attached to this agenda report, recommended four mitigation measures
to reduce environmental impacts to a less than significant level. The collection of fees pursuant to
Fish and Game Code Section 711.4 is required, prior to filing a Notice of Determination for the
project, unless the project proponent provides verification from the California Department of Fish
and Game that the project is exempt from the fee requirement. If a required fee is not paid for a
project, the project will not be operative, vested or final and any local permits issued for the project
will be invalid (Section 711.4 (c) (3)).
PUBLIC COMMENTS:
Staff received one public comment prior to completion of this staff report. A nearby property
owner wanted to know where the tower was going to be located on the subject parcel and whether
or not it would impact any access easement that they have. Staff discussed the location and
informed them the tower, and the access for the tower, would not impact any existing easement,
including, Rosie O’Grady Lane.