HomeMy WebLinkAboutMiscellaneous - 122 FOSTER STREET 9/22/2017 (4) �
Isotrope
WIRELESS
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The Zoning Board of Appeals {"ZBA'') is hearing an application for dimensional variances for a
proposed wireless communications facility and tower at 122 Foster Street. The ZBA engaged
|sotrope to review the application and report. The Planning Board is concurrently hearing an
application for Special Permit and Site Plan Review for the same facility.Isotrope is suipporting the
Planning Board in that hearing. |mfovnum1iom presented in this report may include information
gleaned from the Planning Board hearing.
The application to the ZBA seeks variances for the proposed tower. As the ZBA is aware, it has a
responsibility under state law to review variance applications according to the narrowly scoped
state |ovv. |nadditium, undertheTe|econmmun|catimnsAotof1996 (the °Act"),tNeZRAmayo|so
have the authority to grant the equivalent of variance that might be inconsistent with the
ordinary state-level limitations on variances. Advice of counsel is recommended (and has been
sought by the ZBA).This report supplements the record with facts upon which the ZBA can render
adedsimn.
The applicant seeks wptofour dimensional variances,two performance criteria variances and one
use variance. The dimensional variances relate totower height and setbacks. The performance
criteria relate to camouflage by vegetation and to color.The use in this residential district is not
allowed.
Executive Summary
This report attempts to put the variance requests in context, especially the dimensional issues
created by the competing height limitation clauses. The General Height limit is based on the
average height of buildings (plus 10 feet) yv|tb|n 300 feet, and falls buck to being based on the
district height limit (plus ten feet), presumably when no buildings are within 300 feet. A
camouflage, exception allows the fallback rule to be waived, but does not apply to the 300-foot
buildings ruUe. This report wonders whether having a few small buildings within the 300 foot
distance/ssufficient building density towarrant taking amaverage thereof.
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The Ground-Mounted Height limitation starts with the same bu||d|mgs^mithin-300-feet rule as
above,and appends a tree canopy(plus 10 feet)limit when there are no such buildings, Resolving
these criteria and deciding which, if any, to vary, is discussed. A flow chart providing a proposed
decision-making path ispresented,
The vegetative buffer requirement seems to be misinterpreted bythe applicant. The applicant
sees avegetu1iom height requirement (vertica|). We read itosavegetation depth requirement
(hor|znnta|). The ZQAmust decide which interpretation is correct. Buffers are generally defined
bytheir depth, not their height.
As a depth buffer, it is relatively simple toreview the evidence and decide whether avariance to
the buffer requirement is needed.
The color requirement is in direct conflict with the bylaw's camouflage preference in this instance,
It is questioned whether the ZBA needs to weigh in on this matter or if it can be left to the Planning
Board,
|sotrnpe evaluated alternatives in depth for the Planning 8omnj. That report is incorporated by
reference and should be put on the ZBA record. its most salient conclusions are summarized
below inthis report.
A general discussion of coverage needs and alternatives is provided.The most compelling possible
alternative locations that might be less visually objectionable tothe community are discussed
(further vetting ixmeceoory).The 60Ofoot giant setback from residential properties isimpossible
tosatisfy|nthe area.The fall zone setback will be difficult, ifnot impossible,tn satisfy.
0ygranting a variance to the proposed facility, it raises the question whether that then gives the
location an advantage over the alternatives, considering the proposed location would have
variances that the alternatives lack. Ktmight be advisable to see the Planning Board render
judgment on the least objectionable choice before granting variances for one of the choices.
Advice ofcounsel isrecommended.
The most compelling alternative is at the 489 Foster Street substation parcel. The applicant is
pursuing the owner to determine if the owner would permit a wireless facility to be placed at a
safe distance from utility infrastructure. Fall zone setback might be satisfied, orsubstantially so,
and the vegetative buffer might be more substantially satisfied than with the proposed site. The
substation alternatives (there are at least two spots on the parcel to consider) are farther from
residences and street than the proposed facility. Coverage from the substation provides
substantially more new coverage to North Andover than the proposed facility.
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Tower Height
Tower height under the Zoning Bylaw is limited by two overlapping clauses. This unwieldy bylaw
language propagated across the Commonwealth after the 1996 Act was adopted as towns
borrowed language from other towns,on the faulty assumption that the bylaw language had been
vetted by some expert at its inception.
General Height Clause
The first height clause is Section 8.9 3)c) I) Height,General:
Regardless of the type of mount; wireless service facilities shall be n a higher than
ten feet above the average height of buildings within 300 feet of the proposed
facility, In addition, the height of a wireless service facility shall not exceed by
more than 10 feet the height limitations of the zoning district in which the facility
is proposed to be located, unless the facility is completely camouflaged such as
within aflagpole,steeple, chimney, or similar structure.
There is one building not on the subject parcel that is within 300 feet of the proposed facility. It is
the residence across the street. On the parcel, a residence, a detached garage and part of a barn
are within 300 feet.
In the present case, although there are a few buildings within 300 feet, the average height of
buildings requirement might not be relevant due to terrain elevation changes and a lack of
building density. In short, it is plausible that there are not enough buildings within 300 feet to
meaningfully establish an average. Other height limitations in the first clause and the second
clause overlap this objective.
• The ZBA can decide whether the,height-above-average-building-height limitation is applicable
and needs to be considered for a variance.
The remaining requirement in this general height clause is the ten-feet-above-district-height limit,
with an exception for camouflaged facilities. Because the camouflage exception is embedded in
the district height limit sentence, it seems not to be applicable to the average building height
sentence.
In short, because there literally are a few buildings within 300 feet,the district height limitation
and its camouflage exception are not available, unless the sparse buildings are considered not
applicable to the intent of this limitation.
• The ZBA should consider whether the h eighit-a bove A I strict-height criterion can be applied in
lieu of the height-above-average-building-height criterion. If so, then the camouflage
exception could be available.
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Assuming the average building height criterion is not applicable,the camouflage exception could
app|y.Thaproposodfad||ty|va "monopime"tmvver.Thedefini1imnof°camouOege° is,"Avxine|exs
service facility that is disguised, hidden, part of an existing or proposed structure or placed within
a preexistent or proposed structure is considered to be "camouflaged.""
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If the camouflage rule is available in this situation, the Z8A shmm|6 determine whether the
proposed m000pine design is a valid way of being "completely camouf|aged.^ If it is
"completely camouflaged," this may eliminate a need to vary the district-height-limit-plus-
ten-feet criterion.
istrict-height-||nn|t-p|us'tmn-fcetcriterimn.
o If not"completely camouflaged,"the ZBA will need to determine whether to grant a!
variance Tothe height-above-district-height limit.
Ground~M o tinted Height Clause
The second set of height restrictions is for Height, Ground-Mounted Facilities in 3)c) ii):
Ground-mounted wireless service facilities shall not project higher than ten feet
above the average building height or, if there are no buildings m//U,/n 300 feet,
these facilities shall not project higher than ten feet above the average tree
canopy height, measuredfrom ground level(AGL). If there are no buildings within
300 feet ofthe proposed site nfthe facility, all ground-mounted wireless service
facilities shall be surrounded by dense tree growth to screen views of the facility
/no8directions, These trees may exist ormay heplanted onsite.
This Ground-Mounted Height clause contains duplicative language about the average, building
height limitation found also imthe General Height clause.
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The ZBAcould simply apply its finding onthe General Height average-bw||d|ng-he|ght-w|th|m
3804eeccriteriontothesamcmriterion [nGround-MountedHei8htdouse.
In the Ground-Mounted Height clause, the alternative to the average-building-hmight rule is n
tree-canopy rule. No camouflage exception is available here. If the camouflage, exception in the
General Height clause supersedes the canopy height limitation in, the Ground-Mounted Height
clause, then,the camouflage rule would prevail as an exception for a new camouflaged facility. If
they are of equal weight,the camouflage clause would let the tower be no higher than ten feet
above the canopy, regardless ofdistrict height limitations,
The Ground-Mounted height clause refers to an "average tree canopy height.'^ The applicant
provided an assessment of the trees surrounding the proposed site prepared by a licensed
forester, The forester describes a gradient"of diminishing canopy height and cover from upland
to wetland areas." Because of this gradient, it appears the forester chose to provide a range of
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mean tree heights ratherthan a singlle figure anticipated by the zoning bylaw. In further discussion
below,a the greatest mean height near the proposed facility is 86.3 feet.
Based on the forester's assessment, a tower height of 96.3 feet above ground level would be the
maximum height allowed under the canopy height criterion. Recall that the canopy height
criterion only appifles "if there are no buildings within 360 feet," so this canopy discussion relies
on a finding that the dearth of buildings in the area renders the 300-foot buildings rule
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inapplicable.'
The preceding exposition is layered and decision-dependent. To illustrate the foregoing
discussion,the flow chart below lays out an interpretation of the sequence of decisions the ZBA f
would consider in evaluating the tower-height variances question.
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Meanwhile,a variance to the General Height clause 300-foot-average-building-height requirement would
probably not invoke the fallback rule for district height and camouflage exception. The same thinking
applies to the Ground-Mounted Height clause 300-foot-average-building-height requirement.if it varied,
the fallback canopy height rule is not invoked. If it is deemed inapplicable, the canopy rune could Ibe
triggered.
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Height Variance recision Tree'
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1 toes the Average1�•, Yes•Interpret Rule % District height �, Not compliant
m *° Height of 61dgs In 300�'-- literally.Canstder 0,,,''plus an feel unless ►' with district height Yes.No variance
300 ft bldg / required.
ft rule apply? f camouflaged? Hale.Camouflaged?,
variance.
c
No.Rule is not
First decisions relevant due to the No.Consider
must be same lack of dense Not applicable district height plus
for both because of 1 a rule
clauses building ten variance
development
literal,Interpret rule... Not �e � �
rSoos camouflage,
V f' oes the AverageYescompliant w exception In General
o y.Consider Canopy height plus ten��.
� Height of Bldgs in 300 —t. with canopy height ` height clause supersede ,
300 ft bldg rule applies?
(t rule apply? `' rote.Camouflaged? the canopy height rule,
variance as above. �.. ` here? I
ZEti
2 No.Rule is not
� Na:Consider
relevant due to the Not applicable variance to canopy Yes.No canopy
lack of dense
building because of 1s'rule .height. . variance required.
development requirement:
No.Consider
Move on to other variance to dense "Is there or will there be",..,
valance requests tree growth rota. ,dense tree growth?
Yes.No variance
to dense tree
growth rule
needed.
'This is provided as a suggested aid.Advice of counsel is recommended on matters of process and law.
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Dense 'Tree Growth and Understoi,y Vegetation
Irrespective of whether the variance review finds its way to the question of dense tree growth
under 8.9 3) c) ii),the,term is discussed in more detail in another section of the bylaw, 8.9 4)a) ii)
Camouflage by Vegetation:
If wireless service facilities are not camouflaged from public viewing areas by
existing buildings or structures, they shall be surrounded by buffers of dense tree
growth and under story vegetation in all directions to create an effective year-
round visual buffer. Ground-mounted wireless service facilities shall provide year-
round vertical evergreen vegetated buffer of 50feet, or 75%of the overall height
of the structure, in a// directions. Trees and vegetation may be existing on the
subject property or installed as part of the proposed facility or a combination of
both. Vegetation should be natural in appearance and consistent with
surroundings.
We interpret this clause differently than the applicant. This section is about a buffer of
surrounding understory vegetation and dense tree growth, not about canopy height. Buffers are
generally described by their depth. The awkward wording of the clause does not help with
understanding its meaning, using the word "vertical" to start the specification, "a year-round
vertical evergreen vegetated buffer—" One might think the dimensional requirements apply to
the vertical component (height) of the buffer. To the contrary,the buffer is defined as "a buffer
of 50 feet,or 75%of the overall height of the structure, in all directions."We read this as a buffer
whose horizontal radius is 75%of the structure height in all directions, but not less than 50 feet.
In our interpretation of the buffer requirement,for example, a 135-foot tower must have a 101-
foot wide vertical evergreen vegetated buffer. The facility is backed by a densely wooded area,
but faces more sparsely wooded space toward the street.The forester described it this way,"The
subject and abutting tracts are characterized by areas with scattered trees and a more open
canopy, as well as wooded areas with'h complete canopy cover." Note the acknowledgement of a
canopy in the form of an "open canopy" in the areas that are not fully wooded.
The aerial image below shows a 101-foot radius from the proposed tower, The ZBA can review
the evidence submitted by the applicant and this photo to determine whether there is a 101-foot
buffer of dense tree growth and understory vegetation. It is worth noting that there is an
additional 72 feet of wooded space and understory vegetation toward the street that appears to
be denser than within the first 101 feet from the tower. In other words,considering whether it is
a 173-foot buffer of dense tree growth and understory vegetation might be more effective than
merely considering the first 101 feet.
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Proposed Tower Location with 101-foot Buffer Radius
If the ZBA is inclined to read the buffer clause as the applicant did,the height of the trees becomes
a component of the buffer decision, Below,a snapshot of the forester's map shows the measured
canopy near the proposed site. The nearest dense tree growth measurement is to the northeast,
showing white pine with an 86.3-foot average tree height.The number of trees sampled for this
average is not indicated. It seems quite limited.
The small circle to the southeast, marked 0.0,is outside the tree canopy in the open area between
the site and the street.
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Excerpt from Forester Map
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(Brown circle annotated by Isotrope indicates approximate locus of tower)
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If the ZBA invokes a canopy height requirement of 75%of the proposed height,the canopy would
have to be 161 feet tall for a 1.35-foot tower or 86 feet tall for a 115-foot tower. One,small sample
of the canopy is at the 86-foot average height mark.
For emphasis,we do not think this criterion is read this way, but if it is,the applicant would likely
need a variance for the height of the buffer of dense tree growth and understory vegetation.
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+ The ZBA,should interpret the vegetative buffer clause for what the dimensions mean.
+ Based on that interpretation, decide whether there is a dimension in need of variance, and if
there is,whether to grant a variance. P
Setbacks
There are two setbacks,one for a "fall zone" and one for residential properties.
"all Zone
The Zoning Bylaw section 8.9 3) c) v) Setbacks calls for a "fall zone" separating a tower from
property lines by a distance equalto twice the height of the tower.The applicant requests relief,
with a fall-zone distance that is about half of the requirement.. It is difficult to find properties that
can place a tower on the center of a circle with a diameter of four times the tower height without
the circle intersecting property Mines.With a 135-foot tall tower(including appurtenances),about
5.3 acres is required just for the 2x-tower height radius.Considering that parcels are not ordinarily
circular and that tower locations are not likely to be perfectly centered on the parcell, a parcel
substantially larger than 5.3 acres is necessary to satisfy the 2x-tower height requirement..
In an analysis of potential alternative Vocations for the Planning Board, Isotrope developed a table
of potential sites. Of the eleven sites considered potentially constructiblle',two had enough of a
radius to satisfy the fall-zone requirement for a 135-foot tower. One would have placeda tower
in the middle of a large town-owned open-space parcel that is shown on the town GIS as lacking
a conservation restriction (ether use restrictions might apply). The other is on a large wooded
landlocked parcel owned by NE Power,access to which is questionable.
In addition to the above two sites, another site might be able to satisfy the fall-zone for a 140-
foot or 125-foot tower, depending on the spot chosen.This is the NE Power substation parcel at
409 Foster Street (parcel 104.8-0038). Two locations on this site were identified as likely being
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out of wetlands and being more than one tower height away from utility infrastructure.This site
is also accessible and heavily wooded.There is some wetland that appears to be avoidable.
Ing eneral, it is difficult to find viable sites that can satisfy the fall zone setback. one key location
of interest is the power substation parcel at 409 Foster Street, mentioned above. In the Planning
Board hearing, the applicant said', the owner is unwilling to place a tower near its critical utility
infrastructure. The applicant is asking the owner whether a location that is safely spaced from
utility infrastructure could be available. 1
3 Preliminary criteria were apparent lack of wetlands and apparent physical way in. Owner availability, j
utilities availability,access availability,and permissibility of use were not considered in generating this first-
pass at a list of alternatives.
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There are few locations that can satisfy the fall zone setback. The most viable-appearing
alternative is on the substation property at 409, Foster Street, about which the applicant is
contacting the owner.A few others have substantial obstacles and uncertainties that would have
to be resolved before cons,ider|ngthemo truly viable.
Giant Setback
In 1999, Isotrope's David Maxson first used the term "giant setback"to refer to setbacks that are
hundreds of feet from certain [and use targetu.certainAt the time, it was not uncommon for
municipalities to adopt giant setbacks of 300 to 1000 feet to keep tall cell towers isolated
physically from certain uses, with the thinking that physical isolation meant visual obscurity.
Typically, those giant setbacks were intended to protect residential parcels, residences, schools,
day care m/other similar uses.
The North Andover 6QO'foot giant setback protects the "adjacent property line ofproperties
which are either zoned for, or contain, residential and or educational uses ofany types." When
building awireless communications facility|n m residential district, this standard is impossible to
satisfy. As a practical matter, nonresidential districts in small suburban towns tend to be small
and unable to accommodate the giant setback. In North Andover, the zoning district that
encompasses Lawrence Municipal Airport is the only non-residential area that is significantly
larger than the 1200-foot diameter required to satisfy the giant setback(assuming the area is not
encumbered by a residential use outside the residential districts). The airport is over 21,000 feet
northwest of the 122 Foster Street site.The airport is simply too distant to be a viable alternative.
There are about three other areas that are in nonresidential districts that might fit a 1200-foot
diameter giant setback circle (assuming there is no residential use in these areas outside the
residential districts). One is the VViUmvv Street industrial area. Several parcels near the center of
this industrial area:could potentially host a tower that complies with the giant setback,
Another industrial area that might fit a tower that complies with the giant setback is the parcel at
1101 Turnpike Street. There is an area with perhaps 200 feet myscope tn place a tower in
compliance with the giant setback. This area and the Willow Street area are more than 10,000
feet from the proposed location, which istoo far away (and close to existing facilities).
*Report uothe Lower Cape Cod Wireless Working Group,1999.
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The last industrial area like this includes a set of town-owned industrial parcels off Sharpners Pond
Road.'There areas where a tower might be placed to satisfy the giant setback.This area is more
than 14,0010 feet from the proposed site, and too far away.
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In short,there is no way to improve wireless service in the Foster Street area in compliance with
the 600-foot giant setback. .A variance to the giant setback will be necessary at any location
selected for a new tower here,
Color
The color rule states:
8.9 4)a) M) (2)
To the extent that any wireless service facilities extend above the height of the vegetation
immediately surrounding it, they must be pointed in a light gray or light blue hue which blends
with sky and clouds.
This rigid requirement is based on the idea that the facility is a cell tower with no redeeming visual
aesthetic and needs to be of minimal visual density.In contrast,the bylaw emphasizes camouflage
in, its many forms,
8.9 3) b) H)
if the applicant demonstrates to the,satisfaction of the SPGR (Special Permit Granting Authority)
that it is not feasible to locate on a preexistent structure, wireless service facilities shall be
camouflaged to the greatest extent possible...
The proposed facility follows the camouflage path as a monopine, which is clearly incompatible
with the color requirement. Does the ZBA need to address this, or would the Planning Board, as
SPCA, have the latitude to resolve this conflict?
In a similar vein, the Planning Board is hearing a Special Permit application on this facility, and
presumably has the last word on what height is most compatible with the neighborhood. If the
award of variances is not a final grant of authority to build to a certain height, the ZBA might
consider avoiding duplicating the minimum-height necessary review and leave that to the SPCA.
5 Because this area is town-owned,it could be in the town's interest to start the process of making this land
available for a wireless communications facility before it is too late.This appears to be one of the few places
in town where a facility could be placed without setbacl(variances. Height variances might still be required.
More analysis is necessary to assess the potential of this location.
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Variances for the requested height could be granted in anticipation of the Planning Board's final
ruling onalesser height, ms |tsees fit.
The strategy of which board should rule first is important.There is a concern that if the ZBA grants
a variance to the proposed site before the Planning Board approves it, the proposed site would
have anadvantage over any a|ternativeconsidered bythe Planning Board.Only the proposed site
would have the necessary variances. We leave this sequence to counsel and the boards to
consider,
Alternatives Review
The Z8Ahas aduty umdertheActtnavoid effectively prohib|dn8theprovision ofpersonal wireless
services in North Andover. The applicant has laid out its interpretation on how tmproceed with
variance requests under state law and under the Act. The ZBAhas the advice,ofcounsel aswell.
There are two tests generally considered by local land use boards for compliance with the Act:
w is there a significant gap in the provision of Verizon's personal wireless service and/or in
AT&7s?
w Are,there alternatives to the proposed facility that would substantially address the Dap
that the proposed facility would serve?
Gap in Service
The term "significant gap" is one based on interpretation. It is a legal term, not an engineering
one. Isotrope provides techn,ical information on the coverage of the two wireless carriers named
in the application as the initial tenants of the proposed new tower. The Z8A is responsible for
determining whether itbelieves the facts point toward afinding ofasignificant gap.
The following excerpt is taken from Isotrope's September 13, 2017 report to the Planning Board.
The applicant "must demonstrate that the facility is necessary in order to provide
adequo1eservicetuthepub|lc.''Theapp|icamtprovidescoxero0eeno|ysisfortwow/ire|eo
services (AT&T and Verizon Wireless) who are planning to use the facility, In short, the
coverage ana|ysesfor both carriers are similar, showing a region within North Andover
that ixnot receiving the level ofcoverage that meets the carrier design requirements for
rm|[aib|e service.Verizon analysis isfar more detailed both graphically and verbally. AT&T
ama|yn|a is limited to some general coverage maps. The coverage issues are nearly
identical between the two carriers because they occupy some of the same sites in the
surrounding areas.
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Verizen"o network is supplemented by new network of utility-pole-mounted antenna
nodes that provide fill-in capacity relief. The additional analysis and maps that Verizon
provided illustrate howthese nodes each serve relativelysmall areas near their poles,The
typical approach in network design using these "small oeNs" is to have general overall
coverage from"macro"cell sites,with thesmall cells�lling in areas of small coverage gaps
or with high capacity demand,There does not appear to be a practical way to simply add
more and more nodes to utility poles to provide the macro-scale coverage thutVerizmn
seeks from the new tower facility.
In the application to the ZBA,the same coverage information is provided as was provided to the
Planning Board.* Our conclusions remain the same aswell. The Planning Board did receive
additional information on how Verizon's coverage would change with reductions in tower height.
VVerecommend the applicant provide this information 1athe ZBA. [tspeaks tothe question of
the height required.
The supplemental report provided to the Planning Board by the applicant determined that the
minimum height that would remain reasonably effective for Verizmn"s planned coverage
improvement[u87feet above ground.This is the antenna centerline,with aworking aperture for
its antennas from 90 to 108 feet, and a five-foot extension above the tower for the tip of the
monnpine camouflage. Isotrope reviewed that information and agreed that the 97-foot antenna
centerline height was a reasonable compromise between height and coverage for Verizon using
this proposed tower.
The applicant assumes that AT&T would! have to be at or above that Vehzmn-nnim|mwm height,
forcing the tower to be ten feet taller(110-foot tower with five-foot extension to 115 feet above
ground for the camouflage). There is not sufficient evidence from AT&T to corroborate this
assumption. It is plausible that because AT&T and Verizon share many of the same cell sites in the
area,AT&rscoverage needs would parallel Vmdzmn'm.
Of course,allowing greater heights increases the capability of the tower to invite other carriers to
co-locate umit(currently Sprint and T-Mnhl|m).
ThmVerizonnarrmdveintheZQAoppUicatiomme|dsthenmedofor"coveraQm° and "capadty."The
evidence is most convincingly about Verizon's coverage from its existing macro cell sites.Verizon
uses a network ofuti|ity-po;e-mounted antennas (°C-RANs") in North Andover (existing and
approved locations), including on Salem and Boxford Streets within the area of influence of the
aThere are some AT&T coverage maps included inthe submission,but the bulk ofthe information and the
accompanying narrative apply tothe Verizon network coverage.
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proposed tower. These antenna nodes are Vodzom's "small-cell" solutions intended to bolster
capacity in high demand areas and coverage in weaker coverage areas. TheaesmaU| ueOy have
correspondingly small coverage areas.
There isnmdata showing a capacity issue that the proposed tower would solve.Some ufVerizom~s
coverage mapping shows a substantial amount ofoverlap from the new tower with existing
coverage from the existing cell site at Boston Hill Road. This kind pfoverlap can provide capacity
relief to existing cell sites, however there is no capacity demand evidence to support this
aasumption.
Based unthe foregoing, the primary evidence inthis application relates tou coverage issue for
Verizon,and secondarily to the AT&T coverage concerns which are much I ike Verizon's.
AT&T has not been deploying C-RAN orother small-cell solutions in the metro Boston area to the
extent that Verizon is. Regardless of the degree to which AT&T can or might use utility-pole
mounted solutions, the neighborhoods connecting to Foster Street, Winter Street and Boxford
Street are almost exclusively without above-ground utHities. This prevents utility-pole mounted
wireless, infrastructure for either carrier from covering all the residential areas that the proposed
tower targets.
Alternative Sites
The alternative sites were discussed in detail in o separate report, Coverage Assessment of
Alternatives to Proposed 122 Foster StTower, that |ootrwpu prepared for the Planning Board,
which |sincorporated herein byreference.
Alternatives are divided into several categories. Simplest and fastest to implement would be an
alternative on the same parcel, Isotrope Identified a general location toward the rear of the same
parcel that would be farther from the street. It would have to be taller, which is not necessarily
more visually objectionable if the context ofthe location isconducive toit. Further visual analysis
and other assessments are needed to consider such on alternative. The advantage iythat ifit is
preferable to the community, the applicant might need only to negotiate with the owner and
modify the current application. This spot will not satisfy the fail zone setback. It might qualify for
the vegetation buffer.
The second tier of alternatives contains one potential option.The adjacent parcel to the northeast
is under the same ownership as the proposed parcel. Although it is a smaller parcel, and
moderately lower elevation than the proposed, it is densely wooded. This might be less visible to
the cormmunity. This would involve the same owner, but new application might he needed for
the new pmme|.
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Isotrope, LLC
Other alternatives are on other parcels not in common ownership with the proposed. Among
these,the power substation at 409 Foster Street is the most com,pelling. Pending clearance from
the owner to consider locations that are a safe distance from utility infrastructure,this parcel has
the potential to satisfy the fall zone setback and the vegetative bluffer requirement. It provides
significantly more new coverage to North Andover than the proposed facility does, while still
providing overlap to existing coverage from the Boston Hill Road cell site.
The other parcels of some interest are town-owned parcels indicated as open space but not listed
on the town GIS as being conservation restricted.There remains,a possibility that the use is limited
to exclude wireless facilities. It is also a time-consuming process with uncertain outcome to make
such property available for lease.The locations of these potential spots may do more to mar the
scenery than the proposed facility. Further analysis would be needed to vet them for visual
impact.
David Maxsoni,WCP
December 13, 2017
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