HomeMy WebLinkAbout2019/11/29 - 1st Peer Review - - Town of North Andloverl, Mr A C11 Pe
Telecommunications Site Review 2423 S. Orange Avenue, #317
New Rooftop WSF Application Orlando, FL 32806
Tel: 877.438.2851 Fax: 877.220.4593
November 29, 2019
Ms. Jean Enright, Director
Town of North Andover Planning Department
120 Main Street
North Andover, Massachusetts 01845
RE: Verizon Application for New Wireless Facility
315 Turnpike Street
Dear Ms. Enright,
At your request, on behalf of the Town of North Andover, Massachusetts ("Town"), CityScape
Consultants, Inc. ("CityScape"), in its capacity as telecommunications consultant for the Town, has
reviewed an application submitted by Victor Manougian, Attorney ("Submitter") on behalf of
Verizon Wireless ("Applicant"). The request is to construct a new wireless facility on the roof of
the Rogers Center for the Arts Building at Merrimack College. The address of the site given in the
application is noted as 315 Turnpike Street in North Andover, which is evidently the college's
general mailing address, but the site is physically located at the northwest comer of Walsh Way and
Cullen Avenue, see Figure 1. Verizon Wireless is an FCC-qualified Personal Wireless Service
Provider ("Provider"), which is afforded special oversight by the Federal Government. The stated
purpose of the proposed facility is to address a significant gap in coverage and a connection
capacity approaching maximum in Verizon's 700 MHz, PCS and AWS services in North Andover.
The City requested CityScape to assist in the disposition of this application to assure
compliance with all related laws, specifically Section 704 of the Federal Telecommunications Act
of 1996, Section 6409 of the Middle Class Tax Relief and Job Creation Act of 2012 and the current
Town of North Andover Code of Ordinances.
The various governmental regulations allow local jurisdictions the ability to regulate all wireless
facilities to include new structures, collocations, modifications and upgrades. Yet along with these
regulations, there are certain restrictions on local governments as to specifically what they can and
cannot do. The Town of North Andover can decide the location of a facility and limit the antenna
structure elevation, along with the type of structure (concealed or non-concealed and the type of
support structure—monopole, lattice, roof-mount, etc.), to assure all safety regulations and building
codes are maintained. Yet, there is an added caveat that no local zoning authority can prohibit a
personal wireless service provider from developing their wireless networks, and no local
jurisdiction can allow any preferential treatment; all wireless service Providers must be treated the
North Andover,Massachusetts
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same. All actions must adhere to a specific time limit and all codes and regulations should be
consistent with federal law. It is under these guidelines that CityScape reviews applications for new
and modified mobile wireless facilities and makes its determinations and unbiased
recommendations.
Description of Proposed Facilities
Page 3 of the RF Report prepared for Verizon describes the proposed wireless facility as follows:
1) An 11'-0" x 18'-8" [205 square feet] equipment lease area with equipment cabinets and
protective ice canopy, enclosed with a brick screen wall to match existing [see Figure 2];
2) Eight (8) panel antennas (two per sector) mounted within 3 0" outer diameter concealed
fiberglass stacks, at a centerline elevation of 54' AGL (6' centerline above existing roof),
[Please note figure A, which show sixteen (16)panel antennas, not eight,four per sector];
3) Remote Radio Heads (RRH) [sixteen (16) RRHs, four per sector, according to Figures 3
and 4] with accessory junction boxes [total of four (4), one per sector] and surge
suppressors mounted alongside the antennas;
4) Power and fiber cables routed inside the building from the equipment area to a proposed
cable hood on the roof, and along horizontal cable trays to the antennas/RRHs.
Figure 4, which is taken from one of the Applicant's construction drawings, shows four (4) ballast
mounts (one per sector) to be attached to the roof and designed to support an array of four (4)
concealed antennas each, for a total of sixteen (16) antennas. Only the concealed antennas and no
other roof-mounted equipment will be visible from ground level, as seen in the simulation photos,
see Figure 7a. The height of the antenna structures, including the fiberglass stacks, is proposed to
be ten (10) feet above roof level, or fifty eight (5 8) feet above ground level.
It should be noted here that the permit application has a discrepancv in the number of antennas
It is not completely certain whether the Applicant is proposing eight (8) antennas (two
per sector) or sixteen (16) antennas, four per sector. The application cover letter, the Construction
Drawings and the photo simulations indicate sixteen (16) total antennas; on the other hand, the RF
Report, the RF Emissions (exposure) Report and the Structural Analysis all state the number of
antennas as eight (8), two per sector. Whichever is the true number of proposed antennas, the
Applicant must revise and submit for review all documents that are affected by the discrepancy
before the Town Planning Board deliberates on the application.
North Andover,Massachusetts
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General Information
Wireless communications systems depend on the concept of frequency re-use to achieve their
service goals. With some technologies, the individual frequencies are re-used every few cells, but
cells using the same frequencies should not too close to each other as mutual interference would
result. Such interference reduces network capacity and for these reasons, it is not desirable for
personal wireless communications devices such as Cell Phones, iPhones, Androids, Smartphones
and other personal communications devices to interact with more than a few base stations
simultaneously.
Providers obtain service through ground equipment base stations and antennas mounted on
towers, buildings or other elevated structures. Generally, the higher the antennas are mounted on
the supporting structure, the larger the geographic area the wireless signal will cover. However, the
ground equipment at the base station has caller capacity limitations as to the number of
simultaneous connections a Provider is able to serve. This is true in North Andover, where there is
a limited number of base stations. Caller volume will exceed the designed network capacity,
resulting in call busy signals, texts and emails not delivered, dropped calls, slow or halted data
transfers, or "no service" displayed on the mobile device. To help remedy this situation, additional
facilities are constructed; the existing antenna facilities are adjusted accordingly to help control
adjacent facility interference. This application is to remedy a service deficiency directly related to
these over-capacity problems.
In the early development stages of wireless network coverage when there were fewer
subscribers, the networks were designed using taller support structures to provide larger coverage at
a lower cost. In many rural locations, that remains unchanged but in urban and suburban areas,
there is a much greater concentration of subscriber demand for mobile wireless service, so more
base stations with reduce distances between them are required to meet the demand. In the more
densely populated locales such as industrial and business areas, congested roadways, densely
populated neighborhoods and cities, the Provider's network development requires more base
stations because individual facilities have more demand than the available capacity and, with
limited spectrum available, the only solution is to increase the number of facilities to match the
subscriber needs. The current technology is referenced as 4G (4th Generation) and some Providers
still support earlier technologies including 3 G and even 2G. As we progress into the next phase of
wireless services currently referenced as 5G (5th Generation), site locations are anticipated to be
located between 50 meters (165 feet) to 500 meters (1650 feet) apart, depending on the population
density and terrain.
North Andover,Massachusetts
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Site-SDecific Information
Although the documents provided to CityScape do not make completely certain the number of
antennas to be mounted on the building roof, we are able to verify the need for the new Verizon site
and review the Applicant's documents to assure that the pertinent requirements are met.
An important part of any wireless communication facility application is the verification of need
and a narration from the Provider as to meeting all requirements. In order to comply with
telecommunications law, the Town should start by verifying that the Applicant is a qualified
personal wireless service provider and the proposed facility is duly justified. The Applicant for the
subject facility is a licensed provider of personal wireless services and is so qualified. The
Applicant must submit sufficient documentation to support the request for a new site and that the
proposed meets the structure height requirements while conforming with generally accepted
engineering standards. In order to properly justify the need for a new facility, as a first step the
wireless Provider generally would supply a Search Ring (the geographic area within which a new
site would address a service deficiency), an indication of the required antenna height, the current
deficiencies and the proposed solution.
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Search Area Determination
The hexagonal search areas radius is one-quarter of the radius of the cell's coverage less a 20 percent hand-off overlap.
Cellular search areas or "rings" are usually circles of approximately one-quarter the radius of the
proposed cell. In practice, an RF engineer has the ability to quickly determine whether the search
North Andover,Massachusetts
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area radius is reasonable. The distance from the nearest existing site is determined, halved and a
hand-off"overlap" of about 20 percent is added. One-fourth of the coverage radius thus determined
defines the search area radius.
The Applicant did not provide a Search Ring. Cityscape determined there was no need to
provide the Ring because the submittals did provide sufficient documentation for Cityscape to
justify there is evidence supporting the need for a capacity relief facility in the general area. The
Applicant stated in the narrative that the purpose for the new facility is to eliminate a coverage gap.
Whether or not the proposed facility is to remedy a coverage gap or reduced capacity overload, the
submittal requirements are the same.
Cityscape identified the existing facilities that provide Verizon's service around the subject
area, see Figure 5. To best determine the level of service would be to calculate the Applicant's
center of antenna height above sea level because height above sea level will be a significant factor.
Standard practice for cell coverage is involves having three (3) sites intended to provide the services
to the subject location. In this situation, the primary facility is a tower identified as N Andover 4
with one of the highest ground elevations of 375 feet above sea level. At that location, Verizon's
antennas are mounted at 110 feet above ground. Thus, the Verizon signal emanates at around 485
feet above sea level. The next site to the northwest is Andover 2 which has a ground elevation 157
feet lower, or 218 feet above sea level. At that location, Verizon's antennas are at 40 feet above
ground; thus, the Verizon signal from Andover 2 emanates at about 258 feet above sea level.
Finally, Shawsheen Village, southwest of Andover 2, has the lowest ground elevation of 166 feet.
The antennas there are at 59 feet above ground; thus, the Verizon signal emanates at about 225 feet
above mean sea level.
The ground elevation generally around the proposed location at Merrimack College is 238
feet above sea level; thus the facility identified as Shawsheen Village would not provide any
reasonable service to the proposed location. Cellular service is defined into four (4) basic signal
levels; the best signal, -75dBm, provides strong service and is defined as in-building; next,
providing reasonable service, -85dBm, is defined as in-vehicle; then, allowing service that may or
may not be reliable inside a building or vehicle, but reasonable outside, -95dBm, is defined as
pedestrian; finally, unreliable service, -105dBm, is hit or miss. Based on the ground elevation in
the subject area, there would be pedestrian level service provided by Andover 2 and N Andover 4,
but that signal would only be reliable generally outdoors and data speed would be reduced.
Therefore, it is Cityscape's opinion that, based on ground elevation alone, a coverage gap along
with reduced service and slower data speed would exist in various areas inside the triangle formed
by the three Verizon facilities (see Figure 5).
North Andover,Massachusetts
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The physical location of a site is paramount to providing reasonable service. To justify a
new facility, a showing of current deficiencies is needed. The Applicant submitted documentation
of its existing and proposed improvement of services in the 700 MHz and 2,100 MHz spectrum
bands. Included in the submittals were various FCC licenses and working spectrum lease
documents to cover the two specific frequency blocks being proposed. Verizon has additional
spectrum allocated in both the cellular range and the PCS range but those were not included in the
mapping display, yet it is not necessary and it is assumed Verizon will utilize this additional
spectrum within these plans. Submitted was a propagation map showing current service levels and
deficiencies, see Figure 6a. The proposed improvement is shown in Figure 6b. Note that Figure 6b
shows both the proposed new service from the applied-for facility (labeled as N Andover 5) and
from a future planned facility on the west edge of the college campus (labeled as N Andover 6).
CityScape is of the opinion that the documents in Figure 6 are sufficient to justify the need for a
new installation. Furthermore, CityScape is of the opinion that the proposed propagation maps in
Figure 6 do show a reasonable solution to the coverage gap and issues caused by insufficient
capacity.
The remaining justification would be the proposed antenna elevation requested. A
Provider's determination of antenna height requires many considerations; does the height satisfy the
purpose for the new installation? Is the height sufficient to reduce need for additional new
facilities? And does the height and design allow ability for future expansion preventing need for
alternative adjacent facilities? The proposed antenna center elevation of fifty four (54) feet above
ground is appropriate as it is compatible with the building height. The proposed height is also
compatible with North Andover's codes generally for the same reasons. To remedy the capacity
overload in this area, the Applicant proposes to add this rooftop installation, identified as N
Andover 5 in Figure 6. The Applicant has identified an additional issue in that the growing number
of subscribers and increased data usage around the college has led to the need for even more
capacity allowing for future increase in demand, not only with the proposed new fifty-four(54) foot
rooftop antenna installation at Rogers Center; Verizon is planning another site called N Andover 6
(see center of triangle in Figure 5), seemingly a capacity relief facility to be rooftop-mounted on
the Monican Centre Building with a proposed elevation of twenty-eight and one-half (28.5) feet,
approximately 1,425 feet at a 240' azimuth from proposed N Andover 5.
CityScabe Analysis and Considerations
Human Exposure to Radio Frequency Energy
The applicant submitted a detailed RF exposure study, prepared by Donald L. Haes, Jr.,
showing that the proposed antenna installation on the rooftop of the Rogers Center building will not
cause RF exposure levels at any location at ground level or inside the building to exceed Maximum
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Permissible Exposure limits, as applied to members of the public i and set by the FCC. Although
the analysis appears to be based on the total number of antennas being eight (8), CityScape believes
this conclusion will be the same for sixteen (16) antennas (nevertheless, the analysis and report
should be revised accordingly). However, we must stress that, while most personal wireless service
antenna installations are safe, RF exposure levels on the roof may exceed MPE limits applicable to
the general public if individuals come too close to the antennas. Thus, it is of paramount
importance that access to the rooftop be restricted only to workers servicing the wireless installation
or other authorized personnel performing duties related to the building rooftop. In addition, areas
around the antennas that may exceed the occupational MPE limits should be clearly defined and
posted so that workers do not inadvertently enter those areas, and all roof entryways should have
signs warning of high RF fields.
Structural Analysis
Any new personal wireless facility mounted on a rooftop must include a structural analysis to
confirm the proposed new facility will not cause damage to the supporting structure and the
supporting structure shall be sufficient to support the proposed installation. Within the submittals is
a structural analysis demonstrating that the Rogers Building roof will support the planned
installation. However, the analysis appears to be based on sight total antennas. If the true number of
antennas is actually sixteen, the analysis and report must be revised accordingly.
FCC Compliance of Non-Interference
The RF Report contains a certification statement that "the proposed facility will not cause
interference to any lawfully operating emergency communications system, television, telephone or
radio, in the surrounding area." Indeed, a lawfully and properly operating mobile wireless facility is
not expected to cause interference to any other RF facilities. This would be the case, whether there
are eight antennas or sixteen antennas on the building roof.
Conclusions and Recommendations
CityScape has concluded there is sufficient documentation to justify a new personal wireless
facility within the general vicinity, and has further determined that Verizon has provided sufficient
substantiation of need. CityScape does believe the selected building to be sufficient to locate the
new facility which would alleviate the describe coverage gap and capacity overloading. CityScape
does agree that the proposed new facility is reasonably in concert with the Town's ordinance. In the
1 There are two tiers of MPE limits as described in OET Bulletin 65. One is for the public who may not be aware of
elevated RF fields;the other is for individuals who are aware of RF fields by virtue of their occupations and are able to
control their exposure. The public MPE limit is one-fifth of the occupational MPE limit.
North Andover,Massachusetts
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photo simulations (which show 16 total concealed antennas) the antennas appear not to be
considered "camouflaged" in accordance with the Town Ordinance, but the design is similar to the
architectural roof design of Palmisano Hall, the adjacent building north of the Rogers Building, see
Figure 7. Also, the ground equipment lease area will be surrounded by a brick screening wall that
matches the building exterior and all cables will be routed inside the building.
The Applicant has requested numerous waivers of the filing requirements. CityScape does
not normally provide recommendations regarding waivers based on the anti-discrimination law in
Part 704 of the Telecommunications Act of 1996. This law states that all providers must be treated
the same and what is approved or denied for one must be the same for all. The only way waivers
can be approved without impacting this law is the waiver must be unique to the specific application,
or is not applicable, in some way. The waiver requests in this application do fit into these special
exemptions.
The waiver requests are specific to the North Andover ordinance regarding the filing requirements:
1. A man showiniz existiniz and annroved wireless facilities in the area and GPS
latitudes/lonizitudes of wireless service facilities. CityScape agrees with the Applicant that
this information would only be available to the Town. In any case, the Applicant lists
Verizon's existing, planned and proposed sites in Table 1 of the RF Report (included the
coordinates) and the propagation maps show the proposed and adjacent Verizon sites.
2. Balloon or crane test to illustrate the height of the nronosed facility. CityScape agrees with
the Applicant since this is an installation on an existing building and the height is known.
3. Noise nroiections statement describinz the levels in decibels. Because this facility does not
propose a generator, the noise levels would be insignificant. But under the Middle Class Tax
Relief and Job Creation Act of 2012, the provider may, at their discretion, add various
equipment, to include, but not be limited to, a generator, which could be exempted from
providing the noise statement at the later date. Therefore, the Town should have a
reasonable assurance that a provider, including a subsequent provider, should there be
mergers or license transfers, will not add a generator at a later date.
4. State of Massachusetts Public Health annroval letter. CityScape agrees with the Applicant
in that the FCC, and only the FCC, has jurisdiction over authorizations to operate wireless
facilities.
S. FCC Environmental Assessment. The FCC does require Environmental Assessments for
some support structures, generally antenna—supporting structures on open land, but does not
do so for an antenna installation on an existing building; therefore, this is not applicable.
6. List of materials nronosed for use that are considered hazardous. CityScape agrees with
the Applicant in that there will be no hazardous materials utilized.
North Andover,Massachusetts
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Clearly there is sufficient justification for a new Verizon facility in the vicinity of the
proposed site. The Town should allow the construction of some type of wireless facility; the
location and type is at the Town's discretion. If approved, the Town should conduct a final sight
plan review to assure the design meets the Town's standards. In addition, the areas of excess RF
exposure levels for those authorized roof access should be clearly marked.
Respectfully submitted,
B. Benjamin Evans
Cityscape Consultants, Inc.
North Andover,Massachusetts
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North Andover,Massachusetts
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North Andover,Massachusetts
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North Andover,Massachusetts
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