Full Text
PO Box 34628 - #75604 Seattle, WA 98124 [EMAIL REDACTED] www.wirelesspolicy.com t [PHONE REDACTED] f [PHONE REDACTED] February 20, 2019 Via email-- [EMAIL REDACTED] Redmond Planning Commission Roy Captain, Chair Phil Miller, Vice Chair Sherri Nichols Vidyanand Rajpathak Stephanie Rodriguez Vanessa Kritzer Judy East Dear Redmond Planning Commissioners: Thank you for the opportunity to provide feedback on the draft wireless code update. Verizon has been working with staff to provide information about the enormous increase in consumer demand for data capacity and cell service, as well as input on the technical requirements for the new small cell technology. Verizon supports the general direction and language of the draft code and is appreciative of the effort by staff to address the technological needs of the wireless industry. This new technology is vital to address the coverage and capacity needs of Verizon’s customers. More people are using more wireless devices to do more things than ever before, like streaming video and uploading images. In fact, wireless data usage tripled from 2013 to 2015 and is forecast to multiply seven-fold from 2015 to 2019. Verizon is working to stay ahead of the demand by adding fiber optic capacity and small cells to connect people where they need it most. The low visual profile of small cells makes them an excellent solution for delivering capacity and coverage to residential neighborhoods. Small cells will also deliver ---PAGE BREAK--- February 20, 2019 Page 2 connections for “smart communities” services to boost the flow and safety of vehicle traffic, manage resources like light, power and water and improve the quality of life of Verizon’s customers. Moreover, this technology is key to preparing Verizon’s network infrastructure so that it is capable of offering 5G wireless connections when it becomes commercially available. With such a pressing need for additional capacity, we want to work with the city to make sure the city’s draft small cell code will facilitate deployment of this much-needed infrastructure. Requested revisions to the draft code. While Verizon generally supports the changes being proposed, there some targeted concerns we would like to raise: 1. The suggested changes in the RZC 256.050(3)(c) and address the "fully screened" requirement that recurs in several sections of the code. 5G antennas cannot be screened, or even painted, and Verizon is concerned that this requirement will inhibit 5G deployment in areas where Redmond anticipates some of its densest development, like Cleveland, Gilman, Redmond Way and parts of Overlake. Verizon requests that the requirement to fully conceal elements of a small wireless facility be qualified by adding the language: to the fullest extent technologically feasible. 2. Section 21.56.050(3)(c) contains this prohibition: "Antennas for Macro Cell Facilities are not permitted on any building façade other than water towers." This is overly restrictive for buildings in business park, commercial and industrial zones. Verizon requests that attachment to building facades and rooftops be allowed in these zones. 3. Verizon requests that the city clarify why interior conduit is included toward the minimum 28 cubic feet for pole mounted equipment enclosures, unified camouflage designs, and associated transmission equipment (including interior conduit), when it is not visible. Thank you for the opportunity to comment and we look forward to continuing to work with the City to develop a code that preserves the look and feel of your community, while providing an efficient and workable process to deliver the service your residents, visitors and businesses have come to expect. ---PAGE BREAK--- February 20, 2019 Page 3 A Verizon representative will be at your meeting to provide testimony, answer questions and provide additional information, as needed. Sincerely, Kim Allen, Senior Vice President Wireless Policy Group, LLC on behalf of Verizon Wireless