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32 <br /> July 23, 1996 <br /> Page 3 <br /> jurisdictions like Orange County where the approval process for a new <br /> tower is extraordinarily lengthy and cumbersome. The only effect <br /> that the information required under Section 8.8.17a.1 will have is to <br /> increase the cost to the company of getting a tower site approved. <br /> The typical "search area" for a cellular transmission facility is <br /> 1 /4 to 1 /2 mile. The industry does not object to providing information <br /> regarding existing structures within this radius because all of those <br /> structures will have been thoroughly examined prior to making the <br /> application. If there is a tower in that search area, the company will <br /> have made every effort to locate its facility on that tower because the <br /> cost savings are enormous. The list of towers or other structures <br /> within a one mile radius of towers taller than 200 feet is irrelevant <br /> because most of these towers are too far out of the search area for <br /> the company to use. If the company could use those towers, it would <br /> do so. <br /> If the May draft amendments are to be retained with only minor <br /> changes, then I suggest the following amendments: <br /> 1 ) 1 suggest that the County collect the information required under <br /> Section 8.8.17a.1 when it has some relevance to co-location. The <br /> requirement to list all towers within a one mile radius of proposed towers <br /> taller than 200 feet will produce a list containing towers too distant to be <br /> used for co-location. This requirement will make the process more time <br /> consuming and costly but will not result in fewer towers. <br /> 2) Section 8.8.17a1 .(d) requires applicants to provide all of the <br /> following information for all towers within the search range: <br /> - tower height <br /> - existing and planned users <br /> - can the proposed antennas be accommodated on the existing tower? <br /> - an explanation of why the tower cannot be used by the applicant; <br /> - and "assess whether the existing tower could be structurally <br /> strengthened or whether the antennas, transmitters and related <br /> equipment could be protected from Electro-Magnetic Interference, <br /> and generally describe the means and projected cost of shared use of <br /> the existing tower." <br /> It may not be possible to supply all of the information listed above for <br /> every tower within the search range because some of the information may <br /> be proprietary. If a tower owner refuses an offer of co-location, then it <br />