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HomeMy WebLinkAbout13. 22-101MARCH 8, 2022 22-101 RESOLUTION (CARRIED___7-0____LOST_______LAID OVER_______WITHDRAWN_______) PURPOSE: APPROVE CONDITIONAL USE PERMIT FOR A COMMUNICATION TOWER AT 0 STILLMAN DRIVE INITIATED BY: HARMONI TOWERS LLC PLAN COMMISSION RECOMMENDATION: Approved w/ findings and conditions WHEREAS, the Plan Commission finds that a Conditional Use Permit for a communication tower at 0 Stillman Drive, is consistent with the criteria established in Section 30-382 of the Oshkosh Zoning Ordinance. NOW, THEREFORE, BE IT RESOLVED by the Common Council of the City of Oshkosh that a Conditional Use Permit for a communication tower at 0 Stillman Drive is hereby approved, per the attached, with the following findings: 1. Is in harmony with the Comprehensive Plan. 2. Would not result in a substantial or undue adverse impact on nearby property, the character of the neighborhood, environmental factors, traffic factors, parking, public improvements, public property or rights-of-way, or other matters affecting the public health, safety, or general welfare. 3. Maintains the desired consistency of land uses, land use intensities, and land use impacts as related to the environs of the subject property. 4. The conditional use is located in an area that will be adequately served by, and will not impose an undue burden on, any of the improvements, facilities, utilities or services provided by public or private agencies serving the subject property. 5. The potential public benefits outweigh any potential adverse impacts of the proposed conditional use, after taking into consideration the applicant’s proposal and any requirements recommended by the applicant to ameliorate such impacts. BE IT FURTHER RESOLVED that the following are conditions of approval for the Conditional Use Permit for a communication tower at 0 Stillman Drive: MARCH 8, 2022 22-101 RESOLUTION CONT’D 1. Final fencing (screening) plan shall be approved by the Department of Community Development. 2. Final landscaping plan shall be approved by the Department of Community Development City Hall, 215 Church Avenue P.O. Box 1130 Oshkosh, WI 54903-1130 920.236.5000 http://www.ci.oshkosh.wi.us TO: Honorable Mayor and Members of the Common Council FROM: Mark Lyons, Planning Services Manager DATE: March 3, 2022 RE: Approve Conditional Use Permit for a Communication Tower at 0 Stillman Drive BACKGROUND The applicant is requesting a Conditional Use Permit for installation of a cellular telecommunications tower. Communication Tower land uses are permitted only through a Conditional Use Permit (CUP) in the Heavy Industrial District (HI) as regulated in Section 30- 62 (C) of the Zoning Ordinance. Criteria used for Conditional Use Permits are located in Section 30-382 of the Zoning Ordinance. The subject site consists of a 6.23 acre parcel located on the south side of Stillman Drive. The site is currently vacant and located within the Northwest Industrial Park. The 2040 Comprehensive Land Use Plan recommends Industrial use for the site. The site is surrounded predominantly by industrial uses along with Lakeview Memorial Cemetery to the south. ANALYSIS The applicant is proposing to install a cellular telecommunications tower which will have an overall height of 199’ (including lightning rod). The proposed cell tower will be accessed from Stillman Drive with a 12’ wide access drive. The tower and associated equipment will be enclosed within a 75’ X 75’ fenced in area. Communication towers must be enclosed by solid fencing at least 6' in height or a buffer yard with a minimum opacity of 0.4 and screened so that it is not accessible to the general public. The plans include 6’ tall solid wood fencing (with access gate) surrounding the tower and related equipment. Staff is recommending a condition that final fencing plans be approved by the Department of Community Development. The proposed tower height has been approved by the Federal Aviation Administration (FAA). The applicant has provided a sworn statement attesting that collocation within the applicant’s search ring is economically burdensome, meeting the permit application requirement for a new communication tower. The applicant has provided the required sworn statement attesting that collocation within the applicant’s search ring is economically burdensome, meeting the permit application requirement for a new communication tower. City Hall, 215 Church Avenue P.O. Box 1130 Oshkosh, WI 54903-1130 920.236.5000 http://www.ci.oshkosh.wi.us FISCAL IMPACT Approval of this project should result in an increase in the assessed property value for the site. The developer is anticipating spending approximately $360,000 on the development. RECOMMENDATION The Plan Commission recommended approval of the Conditional Use Permit with findings and conditions on March 1, 2022. Please see the attached staff report and meeting minutes for more information. Respectfully Submitted, Approved: Mark Lyons John Fitzpatrick Planning Services Manager Assistant City Manager / Director of Administrative Services ITEM: PUBLIC HEARING: CONDITIONAL USE PERMIT REQUEST FOR A COMMUNICATION TOWER AT 0 STILLMAN DRIVE Plan Commission meeting of March 1, 2022. GENERAL INFORMATION Applicant: Scott Littell, Harmoni Towers LLC. Owner: Michael R. Peerenboom Action(s) Requested: The applicant is requesting a Conditional Use Permit for installation of a communication tower (cellular telecommunications tower). Applicable Ordinance Provisions: Communication Tower land uses are permitted only through a Conditional Use Permit (CUP) in the Heavy Industrial District (HI) as regulated in Section 30-62 (C) of the Zoning Ordinance. Criteria used for Conditional Use Permits are located in Section 30-382 of the Zoning Ordinance. Property Location and Background Information: The subject site consists of a 6.23 acre parcel located on the south side of Stillman Drive. The site is currently vacant and located within the Northwest Industrial Park. The 2040 Comprehensive Land Use Plan recommends Industrial use for the site. The site is surrounded predominantly by industrial uses along with Lakeview Memorial Cemetery to the south. Subject Site: Existing Land Use Zoning Vacant HI Recognized Neighborhood Organizations N/A Adjacent Land Use and Zoning: Existing Uses Zoning North Industrial HI South Railroad HI West Industrial HI East Industrial HI Comprehensive Plan Land Use Recommendation Land Use 2040 Comprehensive Land Use Plan Recommendation Industrial Item II – CUP/Communication Tower – 0 Stillman Dr.. 2 ANALYSIS Use The applicant is proposing to install a cellular telecommunications tower which will have an overall height of 199’ (including lightning rod). Communication towers require a Conditional Use Permit in the Heavy Industrial (HI) district. Site Design & Access The proposed cell tower will be accessed from Stillman Drive with a 12’ wide access drive. The tower and associated equipment will be enclosed within a 75’ X 75’ fenced in area. Item II – CUP/Communication Tower – 0 Stillman Dr.. 3 Required Provided Front Setback (north) 30 ft. 30’ Side Setback (east) 20 ft. 239’ Side Setback (west) 20 ft. 32’ Rear Setback (south) 25 ft. 416’ Impervious Surface 70% max. Approx. 3% The proposed cell tower and equipment are meeting all applicable setback, impervious surface and height requirements of the zoning ordinance, with the exception of a utility transformer pad and fiber handhole shown within the front setback area. These structures will need to be moved further south to meet the 30’ setback requirement. This can be addressed during Site Plan Review. The proposed tower height has been approved by the Federal Aviation Administration (FAA). Communication towers must be enclosed by solid fencing at least 6' in height or a buffer yard with a minimum opacity of 0.4 and screened so that it is not accessible to the general public. Fence design, materials and colors shall reflect the character of the surrounding area. The plans include 6’ tall solid wood fencing (with access gate) surrounding the tower and related equipment. Staff is recommending a condition that final fencing plans be approved by the Department of Community Development. The applicant has provided a sworn statement attesting that collocation within the applicant’s search ring is economically burdensome, meeting the permit application requirement for a new communication tower. Parking The applicant is not proposing any parking on the site. On-site parking is not required for communication tower land uses. Signage and Lighting No lighting or signage is being proposed for the site. Lighting is not required as on-site parking is not being provided. Storm Water Management Finalized storm water management plans have not been submitted. Plans will be required and reviewed during the Site Plan Review process. Item II – CUP/Communication Tower – 0 Stillman Dr.. 4 Landscaping As no building is being proposed for the site, only street frontage and paved area landscaping are required. Points Required Points Provided Street Frontage 40 (20 medium trees) Not listed Paved Areas 18 (5.4 tall trees, 7.2 shrubs) Not listed TOTAL 58 Not listed Street Frontage The plan set does not show provided street frontage landscaping. Code requires 30 street frontage landscaping points per 100 feet of frontage. These landscaping points will need to be provided and can be addressed during Site Plan Review. Paved Areas The provided site plan shows 5 trees on the north side of the enclosed tower/equipment area, but does not list the species. A combination of trees and shrubs will need to be provided to meet the code requirement of 30 paved area landscaping points per 10,000 sq. ft. of paved area. This can also be addressed during Site Plan Review. RECOMMENDATION/CONDITIONS In its review and recommendation to the Common Council on an application for a Conditional Use Permit, staff recommends the Plan Commission make the following findings based on the criteria established by Chapter 30-382 (F)(3): (1) Is in harmony with the Comprehensive Plan. (2) Would not result in a substantial or undue adverse impact on nearby property, the character of the neighborhood, environmental factors, traffic factors, parking, public improvements, public property or rights-of-way, or other matters affecting the public health, safety, or general welfare. (3) Maintains the desired consistency of land uses, land use intensities, and land use impacts as related to the environs of the subject property. (4) The conditional use is located in an area that will be adequately served by, and will not impose an undue burden on, any of the improvements, facilities, utilities or services provided by public or private agencies serving the subject property. (5) The potential public benefits outweigh any potential adverse impacts of the proposed conditional use, after taking into consideration the applicant’s proposal and any requirements recommended by the applicant to ameliorate such impacts. Item II – CUP/Communication Tower – 0 Stillman Dr.. 5 Staff recommends approval of the proposed Conditional Use Permit for a communication tower at 0 Stillman Dr. as proposed with the findings listed above and the following conditions: (1) Final fencing (screening) plan shall be approved by the Department of Community Development. (2) Final landscaping plan shall be approved by the Department of Community Development Plan Commission recommended approval of the Conditional Use Permit with findings and conditions on March 1, 2022. The following is their discussion on the item. Site Inspections Report: No commissioners reported visiting the site. Staff report accepted as part of the record. The applicant is requesting a Conditional Use Permit for installation of a communication tower (cellular telecommunications tower). Mr. Slusarek presented the item. The applicant is proposing to install a cellular telecommunications tower which will have an overall height of 199’ (including lightning rod). Communication towers require a Conditional Use Permit in the Heavy Industrial (HI) district. The proposed cell tower will be accessed from Stillman Drive with a 12’ wide access drive. The tower and associated equipment will be enclosed within a 75’ X 75’ fenced in area. The proposed cell tower and equipment are meeting all applicable setback, impervious surface and height requirements of the zoning ordinance, with the exception of a utility transformer pad and fiber handhole shown within the front setback area. These structures will need to be moved further south to meet the 30’ setback requirement. This can be addressed during Site Plan Review. The proposed tower height has been approved by the Federal Aviation Administration (FAA). Communication towers must be enclosed by solid fencing at least 6' in height or a buffer yard with a minimum opacity of 0.4 and screened so that it is not accessible to the general public. Fence design, materials and colors shall reflect the character of the surrounding area. The plans include 6’ tall solid wood fencing (with access gate) surrounding the tower and related equipment. Staff is recommending a condition that final fencing plans be approved by the Department of Community Development. Staff recommends approval with the findings and conditions as listed in the staff report. Mr. Perry opened up technical questions to staff. Ms. Propp stated that today the Plan Commission received an objection to this. It is very frustrating because the state ties our hands and really gives us little leeway for saying yes or no on a new cell phone tower and we have no background to discern whether the objection is correct or not. This is becoming a pattern with cell phone tower requests. Item II – CUP/Communication Tower – 0 Stillman Dr.. 6 Mr. Perry asked for any public comments and asked if the applicant wanted to make any statements. Paul Jonas, Attorney at Michael Best & Friedrich LLP, said he represents the applicant Harmoni Towers. Andrew T. Flowers, AT&T, said that AT&T is in the process of upgrading a great number of their facilities through Wisconsin and one of the items that keeps coming up is coverage from our existing sites as opposed to finding another facility to work with to provide better coverage, meaning more height or moving the tower closer to residential or business use. In this particular case, AT&T is asking to build a new facility that is about 50+ feet taller than the existing site to better cover the north end of town including the industrial park and residential areas. We feel as though we cannot meet those requirements at our existing sites. The tower we are proposing to build will be built for multiple co-locators. The tower is going to be built for future use by anybody else that is willing to lease space. This new cell site will also have FirstNet on it for first responders, which is part of AT&T’s requirements with our contract with the federal government and will also have the newest technology added to it. We don’t have any objections to the landscaping and that can be taken care of during the building permit process. Shane Anderson, Attorney at the Law Firm of Conway, Olejniczak & Jerry, S.C., appearing on behalf of SBA Structures LLC. He said the purpose of his attendance is to provide the Plan Commission with information as it relates to the existing cell tower, which ATT&T is currently co-located approximately .2 miles away from this proposed location. The first point is that in negotiating with SBA Structures, ATT&T mentioned that the height of this new tower will provide enhanced capabilities. At this point, SBA has not been approached by ATT&T as it relates to increased height capabilities on this current location. That’s something that SBA Structures would be willing to discuss with ATT&T moving forward. The current tower of SBA at the Algoma Boulevard location is currently at 90.1% capacity and the usual threshold is 105%. There is some room for expansion as it relates to that existing cell tower. The affidavit provided by ATT&T as it relates to this new cell tower, they bring up the disparity and rent. SBA would be willing to engage in further discussion terms. At this point we would just be looking for the Plan Commission at minimum to postpone a decision until further discussion. Mr. Perry closed public comments and asked if the applicant wanted to make any closing statements. Mr. Jonas said that he has done dozens of these hearings over the past few years and this is a frequent exchange between various cell towers and SBA. Most of you are probably familiar with Wisconsin Statute 66.0404 that does put some guidelines around the way cell towers are processed, considered and approved. In the case of SBA, it’s been a unique situation. Among AT&T’s carriers, most have been willing to discuss modifying not only the financial terms, but also the operational terms. Specifically with regards to the ability of carriers. This tower is designed for up to four carriers, not just AT&T. To quickly and efficiently swap out old equipment for new. It’s critically important that the folks working from home have great Item II – CUP/Communication Tower – 0 Stillman Dr.. 7 connectivity using the best technology. SBA, among other tower developers, have elected to stay with their economically burdensome former lease structure that does not allow four carriers to quickly and easily swap out equipment when the situation calls for it. Harmoni on the other hand does not. Putting aside the fact that over the term of the lease AT&T is going to save millions of dollars in rent and those savings will be passed directly onto consumers. There’s also the operational aspect that when combined with the substantial rent savings definitely meet economic burden standard in 66.0404. In addition to that, SBA has a habit of remaining silent until the day of the meeting. And then, as they did here, they send a letter the day of the meeting raising an objection ultimately trying to maintain their monopoly in a market. In the rare case that they are successful, the result is less coverage, poor coverage and more expensive coverage for citizens of whatever community it is that we’re trying to build the new tower. I suggest that Harmoni has met and exceeded the standard under 66.0404. I realized it’s an uncomfortable position to be in the middle of two carriers. AT&T would be happy to have a discussion and is in fact in discussion with multiple carriers and not just about one tower because there are thousands of towers and it’s not possible to have these ad hoc negotiations on a tower by tower basis. They are attempting to negotiate a more global resolution with SBA and other carriers to bring those costs down, but have not been able to do it at this time and thus the new tower application. Mr. Mitchell asked if the closer you are to a cell tower, the better the service. Mr. Jonas said in this case, we do our best to locate these towers in areas that will be sort of the lease obtrusive. We are in an industrial park near a cemetery in this case. Hopefully we have accomplished that goal. Mr. Mitchell said that there’s presumably other cell providers on a given tower. Let’s say that this part of the town is well covered by one tower. There may be another area of town that maybe doesn’t have good coverage. What is the need to go less than a quarter mile away from the existing tower with a second tower. From a land use or planning perspective, it’s permissible and it’s probably going to go through but it’s just sometimes these things don’t seem to be the most sensible. Mr. Flowers said the way that AT&T builds their network is like a 1000 piece jigsaw puzzle. As you put those pieces together, we want to make sure they are seamless. As you’re driving your car from one point to the next, you don’t have dropped calls or if you’re trying to download something, or your kids are watching a movie, we don’t want any disruption of service. When we have to build a tower that we’re on close to another tower, helps us maintain that ability to keep continuous coverage. The existing site is about 140 elevation and the new tower will be at 190 feet. Now going back to the economics if it is one things, but the engineering piece of it, adding 50 feet to a tower is not really a workable solution because the tower would have been built as tall as it should have been from engineering when it was originally constructed. It’s just not made to do what it’s going to be asked to do, which would be adding a 50 foot extension. Hence the reason we’re asking for this tower to be built with the newest engineering standards and have the ability to carry multiple carriers for future use. AT&T does not like having to build site next to another site, because it is cheaper and faster for us to co-locate on something that Item II – CUP/Communication Tower – 0 Stillman Dr.. 8 was built correctly. In this case we feel as though that is not something we can work with today for multiple reasons. Motion by Mitchell to adopt the findings and recommendation as stated in the staff report. Seconded by Propp. Chairperson Perry said that he wants to echo what Ms. Propp has said. Plan Commission has had these cell towers brought before them previously. There is not much that the Plan Commission can do for these types of things. We are here to meet the needs of the community by adhering to the statutes and regulations around this. Our hands are pretty much tied. Motion carried 8-0. CUP STILLMAN DR PC: 03-01-2022 LAKE VIEW MEMORIAL PARK PO BOX 130548 HOUSTON, TX 77219 CORRIM INVESTMENTS LLC 1870 STILLMAN DR OSHKOSH, WI 54901 MVT LLC 2247 RYF RD OSHKOSH, WI 54904 BBB REAL ESTATE LLC 2916 ALGOMA BLVD OSHKOSH, WI 54901 CHICAGO & NORTHWESTERN RR CO 4823 N 119TH ST MILWAUKEE, WI 53225 CAREW CONCRETE & SUPPLY CO INC 1811 W EDGEWOOD DR APPLETON, WI 54913 SUTTON PROPERTIES LLC 8011 SCHOFIELD AVE SCHOFIELD, WI 54476 FOX VALLEY & WESTERN LTD 17641 S ASHLAND AVE HOMEWOOD, IL 60430 TOWN OF OSHKOSH 1076 COZY LN OSHKOSH, WI 54901 MICHAEL R PEERENBOOM 2561 VINLAND ST OSHKOSH, WI 54901 SCOTT LITTELL (HARMONI TOWERS) 1026 SOUTH 57TH ST WEST ALLIS, WI 53214 Oshkosh City LimitOshkosh City Limit STILLMAN DRSTILLMAN DR C:\Users\Public\Desktop\2020 Plan Commission Site Plan Map Template.mxd User: hannahs Prepared by: City of Oshkosh, WI Printing Date: 2/7/2022 1 in = 120 ft1 in = 0.02 mi¯STILLMAN DRSTILLMAN DR City of Oshkosh maps and data are intended to be used for general identification purposes only, andthe City of Oshkosh assumes no liability for the accuracy of the information. Those using theinformation are responsible for verifying accuracy. For full disclaimer please go towww.ci.oshkosh.wi.us/GISdisclaimer I I HI SMU SR-5 MR-12 UI-PD SR-5 SMU-PD MR-12-PD DR-6 MR-12-PD Ken Robl Conservation Park Oshkosh City LimitOshkosh City Limit!"#$41 AAL L GGOOMMAABBLLVVDDWWFFEERR NNAAUUAAVVWWAALLTTEERRSSTTW PACKER AVW PACKER AVCLOVER STCLOVER STSSTTIILLLLMMAANN DDRR MINERVA STMINERVA STHAMILTON STHAMILTON STPROGRESS DRPROGRESS DRWALTER CTWALTER CTC:\Users\Public\Desktop\2020 Plan Commission Site Plan Map Template.mxd User: hannahs Prepared by: City of Oshkosh, WI Printing Date: 2/7/2022 1 in = 500 ft1 in = 0.09 mi¯STILLMAN DRSTILLMAN DR City of Oshkosh maps and data are intended to be used for general identification purposes only, andthe City of Oshkosh assumes no liability for the accuracy of the information. Those using theinformation are responsible for verifying accuracy. For full disclaimer please go towww.ci.oshkosh.wi.us/GISdisclaimer C:\Users\Public\Desktop\2020 Plan Commission Site Plan Map Template.mxd User: hannahs Prepared by: City of Oshkosh, WI Printing Date: 2/7/2022 1 in = 100 ft1 in = 0.02 mi¯STILLMAN DRSTILLMAN DR City of Oshkosh maps and data are intended to be used for general identification purposes only, andthe City of Oshkosh assumes no liability for the accuracy of the information. Those using theinformation are responsible for verifying accuracy. For full disclaimer please go towww.ci.oshkosh.wi.us/GISdisclaimer 231 South Adams Street • Green Bay, WI 54301 P.O. Box 23200 • Green Bay, WI 54305-3200 • Phone: 920.437.0476 • Fax: 920.437.2868 www.lcojlaw.com March 1, 2022 Attorney Shane A. Anderson SAA@lcojlaw.com Via E-Mail c/o Hannah Schueler, Office Asst., Planning Svcs. HSchueler@ci.oshkosh.wi.us City of Oshkosh Plan Commission 215 Church Avenue P.O. Box 1130 Oshkosh, WI 54903-1130 Re: Objection to Application of Harmoni Towers, LLC Dear Commissioners: I represent SBA Structures, LLC. The purpose of this correspondence is to object to the application of Harmoni Towers, LLC for a new communication tower. Attached please find information from an engineer retained by SBA to analyze the RF coverage related to this application. The attached maps document that the new tower duplicates SBA’s tower which is located only 0.2292 miles from this new proposed tower. AT&T claims its current lease is economically burdensome. AT&T has not contacted my client to negotiate lease terms or a lease extension. Instead, AT&T proposes to build a new tower that duplicates an existing tower. My client is ready and willing to negotiate lease terms with AT&T. SBA has another tenant on its current tower and that lease extends for several more years. Therefore, if the City of Oshkosh approves this application, the City will have two towers in the same area when only one tower is needed. I encourage the Plan Commission to deny this application until AT&T can demonstrate that it has exhausted all avenues to collocation as required by Wisconsin Statutes Section 66.0404 (2)(b)(6). Thank you for your consideration. Should you or your staff have any questions, please do not hesitate to contact me. Sincerely, LAW FIRM OF CONWAY, OLEJNICZAK & JERRY, S.C. By: Shane A. Anderson SAA/plh/Enclosures:4137449 TO: SBA Subject: RF Coverage Plot Analysis: City of Oshkosh, WI Date: February 28, 2022 1. METHODOLOGY. The attached plots depict broadcast radio frequency (RF) coverage from the existing site to City of Oshkosh, WI and a proposed site approximately 0.2292 miles to the Northeast. At each location, cellular industry typical LTE operating parameters were considered for omnidirectional antennas mounted at 120 feet above ground level at the existing site, and at 190 feet above ground level for the proposed site. Ground elevations are 755 and 771 feet above mean sea level, respectively. 5G Broadcast RF coverage was not reviewed since it is not operational as of this date. Plots for both locations were generated for 700, 850, 1900 and 2100 MHz operations. The signal levels depicted are associated with LTE service reliability where the strong coverage levels in green and blue occur near the towers and decrease with distance from the sites and intervening terrain obstructions. Signal levels greater than -70 dBm shown as blue are associated with feasible coverage within buildings. Marginal coverage is provided in the regions depicted in yellow between -90 dBm and -80 dBm and signal levels between -100 dBm and -90 dBm shown as red represent poor coverage associated with call failures. A comparison of coverage performance for each site is based on low band (700 and 850 MHz) and high band (1900 and 2100 MHz) prediction results. Radiowave propagation conditions between these bands differ because of terrain and ground clutter (e.g. vegetation) effects at different frequencies. Generally, low band operations provide greater area coverage. Therefore, high band operations provide additional customer traffic capacity closer to the cellular site. 2. COMPARISON. The sites considered in these coverage plots provide service to the depicted locations and roads leading to City of Oshkosh, WI. For low band operations, the existing site provides strong coverage approximately 0.25 miles in all directions and to non-contiguous areas to 0.6 miles from the site. This includes 0.7 miles of Algoma Blvd. The proposed site provides similar strong coverage 0.3 miles in all directions and to non-contiguous areas to 0.6 miles. This includes 0.7 miles of Algoma Blvd. Both sites provide marginal coverage to non-contiguous areas up 0.7 miles from the site. For high band operations, both sites provide strong coverage to non-contiguous areas 0.5 miles in all directions. 3. CONCLUSION. Based on the coverage comparison presented above, the proposed site provides comparable coverage to City of Oshkosh, WI due to its close proximity to the existing site. For wireless operators with antennas mounted on the existing site, the installation of additional antennas on the proposed site would be considered to be an “overbuild” or impractical given the coverage overlap. Site Name WI21324-A Algoma Blvd Antenna:15.15 dBi Omni Latitude:N44.052358 Alpha Rad Center (ft):120 Longitude:W88.571583 Azimuth (Deg):0 ERP per RS (W):2.0 RSRP: < -100 dBm >= -100 dBm >= -90 dBm >=-80 dBm >=-70 dBm Existing Site 700 MHz Coverage Site Name Proposed Antenna:15.15 dBi Omni Latitude:N44.054081 Alpha Rad Center (ft):190 Longitude:W88.567622 Azimuth (Deg):0 ERP per RS (W):2.0 RSRP: < -100 dBm >= -100 dBm >= -90 dBm >=-80 dBm >=-70 dBm Proposed Site 700 MHz Coverage Site Name WI21324-A Algoma Blvd Antenna:15.15 dBi Omni Latitude:N44.052358 Alpha Rad Center (ft):120 Longitude:W88.571583 Azimuth (Deg):0 ERP per RS (W):2.0 RSRP: < -100 dBm >= -100 dBm >= -90 dBm >=-80 dBm >=-70 dBm Existing Site 850 MHz Coverage Site Name Proposed Antenna:15.15 dBi Omni Latitude:N44.054081 Alpha Rad Center (ft):190 Longitude:W88.567622 Azimuth (Deg):0 ERP per RS (W):2.0 RSRP: < -100 dBm >= -100 dBm >= -90 dBm >=-80 dBm >=-70 dBm Proposed Site 850 MHz Coverage Site Name WI21324-A Algoma Blvd Antenna:17.15 dBi Omni Latitude:N44.052358 Alpha Rad Center (ft):120 Longitude:W88.571583 Azimuth (Deg):0 ERP per RS (W):4.7 RSRP: < -100 dBm >= -100 dBm >= -90 dBm >=-80 dBm >=-70 dBm Existing Site 1900 MHz Coverage Site Name Proposed Antenna:17.15 dBi Omni Latitude:N44.054081 Alpha Rad Center (ft):190 Longitude:W88.567622 Azimuth (Deg):0 ERP per RS (W):4.7 RSRP: < -100 dBm >= -100 dBm >= -90 dBm >=-80 dBm >=-70 dBm Proposed Site 1900 MHz Coverage Site Name WI21324-A Algoma Blvd Antenna:17.15 dBi Omni Latitude:N44.052358 Alpha Rad Center (ft):120 Longitude:W88.571583 Azimuth (Deg):0 ERP per RS (W):4.7 RSRP: < -100 dBm >= -100 dBm >= -90 dBm >=-80 dBm >=-70 dBm Existing Site 2100 MHz Coverage Site Name Proposed Antenna:17.15 dBi Omni Latitude:N44.054081 Alpha Rad Center (ft):190 Longitude:W88.567622 Azimuth (Deg):0 ERP per RS (W):4.7 RSRP: < -100 dBm >= -100 dBm >= -90 dBm >=-80 dBm >=-70 dBm Proposed Site 2100 MHz Coverage