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Tom King - COMMENTS REGARDING THE ORDINANCE TO AMEND THE ZONING ORDINANCE OF ORANGE COUNTP <br />r <br />87 <br />section is to overcome past bureaucratic obstacles to this type of installation, that is fine, <br />but distinguish more closely the parameters of collocating on utility poles located on <br />public versus private property. <br />7. ENGINEERING CERTIFICATION. Section 6.18.4.b. Wireless carriers generally utilize professional <br />engineers employed by communications tower manufacturers to design proposed <br />communications towers. These engineers are P.E.s who seal all communications <br />tower drawings and certify the very things referenced in this section. However, <br />generally, to my knowledge, there is no classification or certification possible for <br />'telecommunication facility design'. Therefore, it may not be possible to comply <br />with this provision. The communications tower drawings will be sealed by a <br />professional engineer licensed in the State of North Carolina. This certification will <br />certify the capacity and design of the communications tower, and that the <br />communications tower meets the applicable ANSI standards. That should be <br />sufficient. <br />8. TOWER SEPARATION. Section 8.8.17a.1 a.d. The Ordinance prohibits a new communications <br />tower from being located- within one -half (112) mile of an existing communications <br />tower, without exception. Some exception should be made in those cases where the <br />existing communications tower is at capacity or cannot be expanded to <br />accommodate further colocation. It may be that the only way to provide wireless <br />coverage In a given area is to have a second communications tower in the general <br />vicinity of the existing communications tower. It is unfair and discriminatory to <br />those carriers not located on the existing communications tower to prohibit them <br />from constructing a second communications tower in the general area. In some <br />cases, carriers can design around such a separation requirement, but not in all cases. <br />Most jurisdictions have an exception to communications tower separation rules such <br />as the inability to colocate, or an inability to modify the existing structure to <br />accommodate colocation, etc. In some cases it makes sense to group <br />communications towers together. If the wireless carrier can show by demonstrative <br />evidence that it cannot provide the necessary coverage without locating within the <br />prohibited one -half (112) mile area, it should be allowed to construct a new <br />communications tower in this area if all other criteria of the Ordinance are satisfied. <br />The Impact at the site may be increased, however, the overall visual impact in the <br />general area is decreased by grouping communications towers in some cases. <br />Section B.S.17a.1.a.c. is not clear if grouping of communications towers is allowed. <br />9. APPLICATION FEES. The wireless industry recognizes that there is a trend in North Carolina to <br />Increase application fees for new communications facilities. This is a bad policy, and <br />an unfair policy. Much of this has been driven by the private sector engineering <br />companies seeking to put ordinances in place which they will then be paid to oversee <br />and enforce. To my knowledge, there is no other industry which has such a small <br />footprint on the ground that must pay such an excessive fee. A fair fee is fine, but <br />Ten Thousand and no /100ths ($ 10,000.00) Dollars is excessive. The cost of a fair <br />and unbiased consultant to assist the County is possible without the need of such a <br />large fee. Consultant fees to review these types of applications may be reasonable, <br />3 <br />