State of Georgia 7050 W. Palmetto Park Road #15-652 Boca Raton, FL 33433-3483 Phone: 877-438-2851 Fax: 887-220-4593 Mr. John Butler Project Planner Metropolitan Planning Commission 110 East State Street Savannah, Georgia 31412 Dear Mr. Butler, RE: At the request of the Metropolitan Planning Commission ( MPC ), Chatham County Savannah, Georgia, CityScape Consultants, in its capacity as telecommunications consultant for the MPC, has considered the merits of an application submitted by Vantage Tower ( Vantage ) on behalf of AT&T Mobility ( Applicant ). An application for a new facility is qualified for federal oversight and special conditions if the purpose of the application is for a wireless service provider, licensed or unlicensed, to develop their wireless network. For that reason the Applicant shall be considered as AT&T Mobility. The application is to support the construction of a new monopole type tower which is to be located on property owned by Victory Harvest Ministries of Savannah, Inc. and is located at 630 Fort Argyle Road in Chatham County, see figure 1. Vantage/AT&T is requesting an elevation of one hundred ninety (190) feet for the low profile style of monopole tower. The tower will have positions for six (6) antenna arrays. AT&T will require two (2) of the slots which leaves four (4) additional slots for other service providers. AT&T requires two (2) antenna slots; one for their standard cellular-type phones and the other slot for the advanced systems such as third generation (3G) and future fourth generation (4G) service which is intended for high speed wireless broadband operation. The subject area is along an existing roadway and has minimal to no current wireless service. Because of the poor service AT&T released a search ring, see figure 2, to begin the process to provide new service. To support the Applicant s needs AT&T submitted a propagation map showing the existing service level, see figure 3. The proposed new service is shown in figure 4; which is sufficient justification for a new facility in order to meet the federal mandate for wireless service. With no qualified existing support structures there are no possible alternative candidates within the targeted Search Ring. The Applicant has proposed a one hundred ninety (190) foot low profile monopole tower. The Applicant (AT&T) intends to locate antennas at the one hundred eighty-six (186) foot level and the one hundred seventy-eight (178) foot of the proposed tower. Remaining is additional collocation antenna space at one hundred sixty-five (165) feet, one hundred fifty-eight (158) feet, one hundred forty-eight (148) feet and one hundred-thirtyeight (138) feet, see figure 5.
Page 2 CityScape has studied the application and believes the proposed facility will qualify as a low profile support structure and is below two hundred feet which is the desire of the MPC. The tower is not required by the FAA to have lights, but the Applicant is willing to install lighting and can include reflective marking tape should the MPC request. On recent new tower applications Chatham County Mosquito Control has requested tower markings due to aircraft flying just above treetops at a level of about one hundred (100) feet. The one hundred ninety (190) foot structure would be a hazard to the County flight staff. That determination is at the sole responsibility of the MPC. The application does have a deficiency. The setback is below the requirements allowed for that zoning district. The MPC has relief for such issues; it is called Breakpoint Technology, a tower industry standard that assures safety within more restricted areas. The Vantage provided a structural analysis from Sabre Industries (Towers and Poles) and a letter that better described the necessary justification according to the ordinance, see figure 6. CityScape reviewed the analysis and found reference to a force coefficiency pressure at 32.7 feet of the pole. That does match the parameters of the ground compound and should be sufficient to qualify. As required under federal law the Applicant provided in their submittal package the required NEPA environmental and SHPO historic preservation documentation. The Applicant has submitted a letter of compliance with all FCC rules regarding interference to another radio services and compliance with all FCC rules regarding human exposure to radio frequency energy, see figure 7. The Applicant has proposed a plan with minimal landscaping and requested a variance because the surround area has existing mature vegetation. CityScape Consultants, Inc., as wireless telecommunications consultant for the MPC, confirms this application meets the requirements as specified within the MPC codes with one exception regarding landscaping. The MPC has the right to modify the plan, to allow for a variance or to eliminate any need for landscaping. Therefore CityScape Consultants recommends this application from AT&T Mobility should be approved with the following conditions: 1. The MPC makes a determination regarding landscaping. Is it sufficient, does it need modifications, or should it be waived completely? and, 2. MPC determination regarding marking the tower with lights and/or reflective tape. Should lighting be required, lights should be dual system. Daytime could be white strobe lighting with acceptable yet minimal intensity lighting which should be shielded or filtered to concentrate lighting away from the ground. At dusk the lighting should convert to flashing red with levels in accordance with FAA requirements; and, 3. The Applicant shall provide an approved NEPA compliance report; and, 4. All feed lines shall be contained within the spine of the support structure; and, 5. All feed line ports shall be properly sealed to prevent access by wildlife. Respectfully submitted, Richard L. Edwards FCC Licensed PCIA Certified CityScape Consultants, Inc.
Page 3 Figure 1. Site Location
Page 4 Figure 2. Search Ring
Page 5 Figure 3. Existing Service (Grey Indicates Target)
Page 6 Figure 4. Proposed New Service
Page 7 Figure 5. Tower and Antenna Design
Page 8 Figure 6. Breakpoint Fall Zone Statement
Page 9 Figure 7. Compliance Statements
Page 10 Exhibit A. State Historic Compliance Letter