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Attachment 1 Project Narrative
PROJECT NARRATIVE
WCF CONDITIONAL USE APPLICATION
US-CA-5480 MASTERSON WAY
Submitted to County of Butte, California
Planning Division
Applicant: VB BTS III, LLC (“Vertical Bridge”)
22 W. Atlantic Ave Suite 310
Delray Beach, FL 33444
Co-Applicant: T-Mobile West (“T-Mobile”)
1755 Creekside Oaks Drive, Suite 190
Sacramento, CA 95833
Representative: Assurance Development
1499 Huntington Dr. #305
South Pasadena, CA 91030
Contact: Phoebe Moffett
323-979-7914
pmoffett@assurance-group.com
Property-Owner: Gordon Wayne Stout
14439 Skyway
Magalia, CA 95954
Project Address: 6219 McReynolds Ct
Magalia, CA 95954-9727
Description & Tax Lot: GPS Coordinates: 39.859328º / -121.606533º
Parcel No. 065-090-025-000
Zoning Classification: RR-5 Rural Residential
Assurance Development submits this application on behalf of VB BTS III, LLC ("Vertical Bridge")
and T-Mobile West, LLC ("T-Mobile"), collectively referred to as the "Applicants," and the
underlying property owner.
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US-CA-5480 Masterson Way
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Veritcal Bridge specializes in developing, constructing, leasing, and maintaining the physical
components for wireless networks, including cellular towers. Infrastructure providers lay the
physical groundwork that supports wireless communication networks. Wireless carriers, such as
T-Mobile, lease space on this infrastructure to house their equipment and offer wireless
services to end users. Through strategic partnerships with wireless carriers, Vertical Bridge
allows the opportunity for multiple carriers to collocate onto a single tower and reduces the
physical footprint of wireless facilities in the community.
1. REQUEST
Applicants seek a review and approval of a Conditional Use Permit application for their
proposed Wireless Communication Facility (“WCF”). Included with this application are the
following documents for review (collectively, “Applicants’ Application”)
Attachment 1: Project Narrative (this document)
Attachment 2: Statement of Code Compliance
Attachment 3: Application Package
Attachment 4: Owner Letter of Authorization
Attachment 5: Colocation Letter
Attachment 6: Zoning Drawings
Attachment 7: T-Mobile Coverage Maps
Attachment 8: Alternative Sites Analysis
Attachment 9: Photo Simulations
Attachment 10: EME Report
Attachment 11: FCC License
Attachment 12: Grant Deed
Attachment 13: Title Report
2. PROJECT OVERVIEW
Vertical Bridge is proposing to build a new wireless telecommunications facility (“WCF” or
“Facility”), US-CA-5480, at the above noted project address for the colocation of T-Mobile’s
equipment. This Facility is intended to fill a significant gap in T-Mobile’s 5G and 4G LTE coverage
experienced by its customers in Butte County, more specifically the area that encompasses
Magalia Adventist Church, Fire Station, Cedarwood Elementary School and Magalia Grange.
As shown in Applicants’ Application, this proposed project meets all applicable Butte County
Municipal Code criteria for siting new wireless telecommunications facilities and complies with
all other applicable state and federal laws and regulations. The proposal is also the least
intrusive mean of meeting T-Mobile’s coverage objectives for this site. Accordingly, the
Applicants respectfully requests Butte County to approve this project as proposed, subject only
to Butte County’s standard conditions of approval.
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US-CA-5480 Masterson Way
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3. PROPOSED PROJECT DETAILS
3.1. Location
Detailed information regarding the subject property and proposed lease area is included in
Attachment 6, Zoning Drawings, to the Applicants’ application.
3.1.1. Subject property. The subject property of this proposal is located at 6219
Mcreynolds Ct in the County of Butte (the “Property”). The Property is owned by
Gordon Wayne Stout. The Property is zoned as RR-5 (Rural Residential) and is currently
used primarily for rural residential purposes.
3.1.2. Lease area.
• The proposed 50 x 50ft lease area for the WCF is located on the northwestern end of
the property (the “Lease Area”).
• The lease area will be surrounded by a 6ft chain link fence with access to the lease
area secured by a locked gate.
3.1.3. Access and parking. Lease area will be accessed be a 12’ wide and 800’ long
gravelled access road stemming from Skyway.
3.2. Wireless Facilities and Equipment
Specifications of the facilities outlined below, including a site plan, can be found in Attachment
6, Zoning Drawings, to Applicants’ Application.
3.2.1. Support structure design. Applicants are proposing to build a new 160 ft tall
monopine (the “Tower”) on the Property. This will be an unmanned wireless
telecommunications facility.
3.2.2. Antennas and accessory equipment.
• The Tower will contain T-Mobile equipment with (11) 8’ antennas, (6) RRU’s, (1) 3’
microwave, (1) GPS antenna, required antenna cabling, and HCS jumpers.
• The antennas, RRHs, and accessory equipment on the Tower will be painted to match.
All paint will have an anti-glare finish.
• Sufficient space will be made available on the Tower as required for future
collocations. The proposed T-Mobile antenna centerline is 151 ft and the proposed T-
Mobile antenna tip height is 155 ft.
3.2.3. Ground equipment.
• The ground equipment will include (2) Ground Mounted Radio Cabinets, (2) raised
concrete pads, cable ice bridge, utility backboard and multi-meter utility service within a
50'x 50' Fenced Lease Area.
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3.3. Additional Details
3.3.1. Lighting. The Tower will not be artificially illuminated, and no artificial lighting is
required pursuant to state or federal authorities. There will be three service lights on
site that will only be utilized during site visits or in case of an emergency, as seen on
Sheet A4 of Attachment 6, Zoning Drawings.
3.3.2. Utilities. No water or sewer service is required. A proposed PG&E transformer
will be added adjacent to the lease area. The proposed utility route is shown on Sheet
A2 of Attachment 6, Zoning Drawings.
4. T-MOBILE NETWORK COVERAGE AND SERVICES
4.1. Overview—T-MOBILE 4G & 5G Coverage
T-Mobile is upgrading and expanding its wireless communications network to support the latest
4G LTE and 5G technology. 4G and 5G stand for “4th Generation” and “5th Generation” and LTE
stands for “Long Term Evolution.” These acronyms refer to the ongoing process of improving
wireless technology standards, now in its 5th generation. With each generation comes
improvement in speed and functionality – 4G LTE offers speed up to ten times faster than 3G,
and 5G can deliver speeds up to 20 Gbps in ideal conditions. That’s nearly 200 times faster than
the 4G network.
Most American consumers currently experience wireless connectivity on 4G networks – and are
aware of the profound impact on daily life that has occurred from this connectivity. The
emerging standard in voice and data telecommunications – 5G – is poised to transform
America’s reliance on densely populated wireless infrastructure.
5G is the latest iteration of cellular technology. While 5G technology operates on the same
radio signals as current 4G/4G LTE networks, it is engineered to transmit data more efficiently.
That means superior speeds and support for more connected devices than ever before. The
ultra-low latency of 5G means quick response times during data-demanding activities.
There are several components of 5G wireless technology and separate bands of wavelength
spectrum used to build a 5G network – low-band (<1GHz), mid-band (1-6GHz), and high-band
millimeter wave (“mmWave”) (24 GHz and higher):
• Low-Band Extended Range 5G. Low-band 5G frequencies are also known as the
“coverage layer.” Low-band 5G refers to frequencies below 1 GHz used to roll out
substantial 5G coverage as quickly as possible. One example is the 600 MHz spectrum
deployed by T-mobile nationwide. A low-band cell site can cover hundreds of square
miles and deliver a downlink data rate from 30-75 Mbps download—ideal for uses like
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streaming HD video. Because low-band signals easily pass through buildings, they offer
solid coverage indoors and outdoors and are an effective way to connect parts of rural
America where even fixed broadband speeds don’t always meet national benchmarks.
• Mid-Band 5G. Mid-range frequencies (spanning 1 GHz and 6 GHz) strike a balance
between coverage and capacity. Mid-band 5G base stations can transmit and receive
high-capacity signals over fairly large areas, and they can represent an ideal mix of
performance for the bulk of 5G traffic in metropolitan areas. • High-Band mmWave 5G. High-band 5G uses millimeter-wave (mmWave) frequency bands. High-band is a very specialized part of the 5G offering. Functioning over a shorter radius, it’s particularly useful in urban areas and busy venues like stadiums and shopping malls. High-band can simultaneously provide many high-speed connections focused on an area of just a block or two, from a small cell site mounted close to street level.
Using these frequencies together can help T-Mobile’s 5G network deliver the increased connectivity, reliability, speeds, and security the public demands. Upon completion, the Facility will become part of T-Mobile’s statewide and nationwide communications network. See Attachment 7, T-Mobile Coverage Maps.
3.2 Coverage Objectives for Proposed Facility
This proposed Facility meets T-Mobile’s coverage objectives providing in-vehicle and in-building
wireless coverage within a geographic area not adequately served by T-Mobile’s network.
Specifically, this facility is intended to increase service in the area encompassing Magalia
Adventist Church, Fire Station, Cedarwood Elementary School and Magalia Grange. T-Mobile
has established a need for service in this geographic area, as determined by market demand,
coverage requirements for a specific geographic area, and the need to provide continuous
coverage from one site to another in a particular geographic region. The specific coverage
objective was determined through a combined analysis of customer complaints, service
requests, and radio frequency engineering design. This proposed Facility will allow for
uninterrupted wireless service in the targeted coverage area with fewer dropped calls,
improved call quality, and improved access to additional wireless services that the public now
demands. This includes emergency 911 calls throughout the area (See Attachment 7, T-Mobile
Coverage Maps).
5. SEARCH RING
T-Mobile’s RF engineers performed an RF engineering study, considering multiple objectives, to
determine the approximate site location and antenna height required to fulfill the noted
network objectives for the targeted service area. From this study, T-Mobile’s RF engineers
identified a “search ring” area where a WCF may be located to provide effective service in the
target coverage area.
The search ring established for this proposal, and a description of the methodology used to
identify the search ring, is provided in Attachment 7, T-Mobile Coverage Maps.
6. SITING ANALYSIS
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Pursuant to the Butte County Code Section 24-180, Applicants evaluated alternative site
locations, including collocation opportunities, within the targeted search ring possible locations
for the proposed Facility. See Attachment X, Alternative Sites Analysis for a summary of the
alternative site locations analyzed.
7. APPLICABLE LAW
7.1. Local Codes
Pursuant to BCMC Section 24-179, new WCF support towers in the RR-5 zone are subject to a
Conditional Use Permit in front a planning commission and must comply with the criteria in
Section 24-181. See Attachment 2, Statement of Code Compliance for Applicants’
demonstration of compliance with the applicable code.
7.2. State Law
Wireless telecommunication facilities that require discretionary review also require
environmental review under the California Environmental Quality Act (CEQA). A discretionary
project is one that requires the exercise of judgement or deliberation by a public agency in
determining whether the project will be approved, or if a permit will be issued.
7.3. Federal Law
Federal law, primarily found in the Telecommunications Act of 1996 (“Telecom Act”),
acknowledges a local jurisdiction’s zoning authority over proposed wireless facilities but limits
the exercise of that authority in several important ways.
7.3.1. Local jurisdictions may not materially limit or inhibit. The Telecom Act prohibits
a local jurisdiction from taking any action on a wireless siting permit that “prohibit[s] or
[has] the effect of prohibiting the provision of personal wireless services.” 47 U.S.C. §
332(c)(7)(B)(i)(II). According to the Federal Communications Commission (“FCC”) Order
adopted in September 2018,1 a local jurisdiction’s action has the effect of prohibiting
the provision of wireless services when it “materially limits or inhibits the ability of any
competitor or potential competitor to compete in a fair and balanced legal and
regulatory environment.”2 Under the FCC Order, an applicant need not prove it has a
significant gap in coverage; it may demonstrate the need for a new wireless facility in
terms of adding capacity, updating new technologies, and/or maintaining high quality
1 Accelerating Wireless and Wireline Broadband Deployment by Removing Barriers to Infrastructure Investment,
Declaratory Ruling and Third Report and Order, WT Docket No. 17-79, WC Docket No. 17-84, FCC 18-133 (rel. Sept.
27, 2018); 83 Fed. Reg. 51867 (Oct. 15, 2018), affirmed in part and vacated in part, City of Portland v. United
States, 969 F.3d 1020 (9th Cir. 2020), cert. denied, 594 U.S. ___, 141 S.Ct. 2855 (June 28, 2021)(No. 20-1354) (“FCC
Order”).
2 Id. at ¶ 35.
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service.3
While an applicant is no longer required to show a significant gap in service coverage, in
the Ninth Circuit, a local jurisdiction clearly violates section 332(c)(7)(B)(i)(II) when it
prevents a wireless carrier from using the least intrusive means to fill a significant gap in
service coverage. T-Mobile U.S.A., Inc. v. City of Anacortes, 572 F.3d 987, 988 (9th Cir.
2009).
• Significant Gap. Reliable in-building coverage is now a necessity and
every community’s expectation. Consistent with the abandonment of land line
telephones and reliance on only wireless communications, federal courts now
recognize that a “significant gap” can exist based on inadequate in-building
coverage. See, e.g., T-Mobile Central, LLC v. Unified Government of Wyandotte
County/Kansas City, 528 F. Supp. 2d 1128, 1168-69 (D.Kan. 2007), affirmed in
part, 546 F.3d 1299 (10th Cir. 2008); MetroPCS, Inc. v. City and County of San
Francisco, 2006 WL 1699580, *10-11 (N.D. Cal. 2006).
• Least Intrusive Means. The least intrusive means standard “requires that
the provider show that the manner in which it proposes to fill the significant gap
in service is the least intrusive on the values that the denial sought to serve.’”
572 F.3d at 995, quoting MetroPCS, Inc. v. City of San Francisco, 400 F.3d 715,
734 (9th Cir. 2005). These values are reflected by the local code’s preferences
and siting requirements.
7.3.2. Environmental and health effects prohibited from consideration. Also under
the Telecom Act, a jurisdiction is prohibited from considering the environmental effects
of RF emissions (including health effects) of the proposed site if the site will operate in
compliance with federal regulations. 47 U.S.C. § 332(c)(7)(B)(iv). The Applicants have
included with this application a statement from T-Mobile’s radio frequency engineer
demonstrating that the proposed facility will operate in accordance with the Federal
Communications Commission’s RF emissions regulations. See Attachment 10, EME
Report. Accordingly, this issue is preempted under federal law and any testimony or
documents introduced relating to the environmental or health effects of the proposed
facility should be disregarded in this proceeding.
7.3.3. No discrimination amongst providers. Local jurisdiction also may not
discriminate amongst providers of functionally equivalent services. 47 U.S.C. §
332(c)(7)(B)(i)(I). A jurisdiction must be able to provide plausible reasons for disparate
treatment of different providers’ applications for similarly situated facilities.
3 Id. at ¶¶ 34-42.
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7.3.4. Shot Clock. Finally, the Telecom Act requires local jurisdictions to act upon
applications for wireless communications sites within a “reasonable” period of time. 47
U.S.C. § 332(c)(7)(B)(ii). The FCC has issued a “Shot Clock” rule to establish a deadline
for the issuance of land use permits for wireless facilities. 47 C.F.R. § 1.6001, et seq.
According to the Shot Clock rule for “macro” wireless facilities, a reasonable period of
time for local government to act on all relevant applications is 90 days for a collocation,
with “collocation”4 defined to include an attachment to any existing structure regardless
of whether it already supports wireless, and 150 days for a new structure.
The Shot Clock applies to all authorizations required for siting a wireless facility and all
application notice and administrative appeal periods.
Pursuant to federal law, the reasonable time period for review of this application is
150 days.
4 47 C.F.R. § 1.6002(g).