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REPORT TO CITY COUNCIL
To:Honorable Mayor and Members of the City Council
From:Grant Yates, City Manager
Prepared by: Damaris Abraham, Senior Planner
Date:October 11, 2016
Subject:An Amendment to the Lake Elsinore Municipal Code, Title 17 Zoning, adding
Chapter 17.186 providing for the regulation of wireless communications
facilities and amending Chapters 17.60, 17.64, 17.68, 17.72, 17.76, 17.80, and
17.84 regarding antennas, satellite dishes, and similar devices
Recommendation
Waive Further Reading and Introduce by Title Only AN ORDINANCE OF THE CITY OF LAKE
ELSINORE, CALIFORNIA, AMENDING TITLE 17 OF THE LAKE ELSINORE MUNICIPAL CODE
TO: (1) AMEND CHAPTERS 17.60, 17.64, 17.68, 17.72, 17.76, 17.80, AND 17.84 REGARDING
ANTENNAS, SATELLITE DISHES, AND SIMILAR DEVICES; AND (2) ADD CHAPTER 17.186
PROVIDING FOR THE REGULATION OF WIRELESS COMMUNICATIONS FACILITIES AND
MODIFYING VARIOUS CHAPTERS RELATED TO USES; and,
BY MOTION, APPROVE THE EVALUATION CRITERIA AND REQUIRED CONDITIONS OF
APPROVAL FOR WIRELESS COMMUNICATIONS FACILITIES.
Background
The City of Lake Elsinore’s Municipal Code (LEMC) does not currently have specific regulations
and development standards for the placement, construction, or modification of wireless
communications facilities. Wireless communications facilities have in the past been reviewed as
Accessory Structures subject to a design review application. In addition, they would be subject to
a Conditional Use Permit only when they exceed the height limitations of the zone. The increased
demand for new wireless communicationsfacilities and federal and state laws significantly limiting
the City’s ability to regulate Wireless communications facilities has created the need to amend
the LEMC. This amendment will allow the City to have specific regulations and development
standards for wireless communications facilities while complying with state and federal laws.
Planning Commission Review
On September 20, 2016, the City of Lake Elsinore Planning Commission at its regular meeting
passed a resolution unanimously recommending that the City Council adopt the proposed
amendment and the corollary policy.
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Discussion
Wireless communications facilities are regulated by federal, state, and local laws. Under federal
law, a local agency’s decisions cannot have the effect of prohibiting the provision of wireless
service or unreasonably discriminating among wireless service providers. Also, under federal law,
the City may not regulate the placement, construction, or modification of wireless communications
facilities on the basis of the environmental effects of radio frequency (RF) emissions, so long as
the facilities comply with the Federal Communications Commission (FCC) regulations concerning
such emissions. Despite federal limitations, Cities historically have retained ability to regulate
aesthetic issues related to wireless communications facilities, including factors such as height
and property line setbacks.
Below are the existing Federal and State Preemptions applicable to wireless communications
facilities:
A. Telecommunications Act of 1996 §§ 332(c)(7) and 253
The Telecommunications Act of 1996 preserves local authority over individual zoning decisions
regarding the placement, construction, and modification of wireless communications facilities and
requires decision on applications to be made within a reasonable period of time after the request
is filed, taking to account the nature and scope of such request. Any decision to deny a request
to place, construct, or modify personal wireless service facilities must be supported by substantial
evidence contained in a written record.
B. Senate Bill 1627, Sections 65850.6 and 65964
The state legislature enacted SB 1627 in 2006, which is codified as Government Code Sections
65850.6 and 65964. Section 65850.6 permits Cities to require a discretionary permit (such as a
Conditional Use Permit) for a wireless telecommunications collocation facility if the City holds a
Public Hearing and provides notice pursuant to Government Code Section 65091. Upon approval
of a wireless telecommunications collocation facility, Cities are precluded from requiring
discretionary permits for any subsequent collocation facility on the approved wireless
telecommunications collocation facility if certain requirements are met.
Government Code Section 65964 prevents Cities from, “as a condition of approval for an
application for a permit for construction or reconstruction” of a “wireless telecommunications
facility” such as requiring an escrow deposit for removal of a wireless communications facility,
unreasonably limiting the duration of any permit for a wireless telecommunications facility. Limits
of less than ten years are presumed to be unreasonable absent public safety reasons or
substantial land use reasons, and requiring that all wireless telecommunications facilities be
limited to sites owned by particular parties (i.e., requiring facilities be built on City property).
C. The “Shot Clock” rule issued by the FCC in 2009
In 2009, the FCC issued a ruling adopting what is referred to as the “Shot Clock”, establishing
“presumptively reasonable periods” for local action on a WCF siting application. Under the ruling,
local governments must review WCF applications for completeness within thirty (30) days from
the time the application is submitted by the wireless carrier. Excluding time when the application
is incomplete, the agency has ninety (90) days to review and decide on collocation applications
and one hundred fifty days (150) to review and decide on all other siting applications.
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The FCC’s ruling authorizes applicants to file lawsuits if local agencies fail to act within these
timelines, and, if sued, the agency must prove that it acted “reasonably” when it failed to act within
these time frames. The ruling expressly authorizes these time limitations to be extended by mutual
consent of the parties and tolls the thirty-day period while such an agreement is in place. The
Shot Clock exists independently of state law so Cities must comply with the Shot Clock as well
as applicable state requirements like the Permit Streamlining Act.
D. Section 6409(a) – the Spectrum Act
Congress, as part of the Middle Class Tax Relief and Job Creation Act of 2012 enacted Section
6409(a) now referred to as the Spectrum Act, and codified as 47 U.S.C. § 1455. Section 6409 of
the Spectrum Act provides that the City “may not deny, and shall approve any eligible facilities
request for a modification of an existing wireless tower or base station that does not substantially
change the physical dimensions of such tower or base station.” Section 6409 defines “eligible
facilities request” as “any request for modification of an existing wireless tower or base station
that involves:
a. collocation of new transmission equipment;
b. removal of transmission equipment; or,
c. replacement of transmission equipment.”
The statute does not define any of the other terms, most importantly “substantially change” nor
does it explain the process the City may use to evaluate whether an application qualifies for
federal protection under this section.
E. FCC Regulations Implementing Section 6409(a) adopted December 17, 2014 (the New
Collocation Rule) and became effective on April 9, 2015
In summary, these rules define terms that are not defined in the Spectrum Act, including “eligible
support structure”, “existing”, “substantial change” and “wireless tower”. It is the intent of these
definitions to provide clarity as to which types of projects are covered by the Spectrum Act. The
rules state that an applicant has the right to assert in writing that a project is covered by the
Spectrum Act.
If the project falls within the definition of an eligible facilities request, the City must act on it within
60 days from the date an application is submitted, unless the City determines the request is not
covered by the Spectrum Act. The 60-day time frame may be tolled by the City for incomplete
applications, within 30 days of submittal. The timeframe begins again when the applicant re-
submits material and the City then has 10 days to respond. Failure of the City to act within the
allowed timeframe results in the automatic approval of such applications.
Summary of the Proposed Ordinance
The proposed ordinance will implement the Spectrum Act and the other FCC rules and will provide
specific development standards for wireless communications facilities. It establishes a
straightforward permitting process for wireless communications facility modification requests
covered under the Spectrum Act, codifies other processing time rules (commonly known as the
“Shot Clock”) that have been adopted for all wireless communications facilities, establishes
application requirements, incorporates development standards, and mandates removal of
abandoned equipment.
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The proposedordinance divides permitsrequired into three categories: Eligible Facilities Request,
Collocations or Modifications that do not qualify as an Eligible Facilities Request, and new
Wireless Communications Facilities.
1. Eligible Facilities Request. To meet the strict timelines established by the new rules, the
ordinance would require Minor Design Review applications for Eligible Facilities Request
to be reviewed by the Community Development Director or his designee. The Community
Development Director’s decision will not be appealable. This would only apply to
collocations that meet the definition of “eligible facilities” under the Spectrum Act and
would provide a streamlined review by the Community Development Director. The
Community Development Director’s purview would be limited to ensuring that the project
meets the definition of an existing “eligible facility” and that it does not defeat existing
concealment elements. Under federal law, the City has limited discretion to deny these
types of requests.
2. Other Collocation or Modification Requests. These types of wireless communications
facility projects would typically involve towers on private property where the height of the
tower is proposed to increase by more than ten percent, towers in the Public right of way
is proposed to be increased by ten feet or more, or projects that will be adding more than
four cabinets. To encourage collocations, the ordinance would also require Minor Design
Review applications for Collocations or Modifications that do not qualify as an Eligible
Facilities Request to be reviewed by the Community Development Director. However, they
would be appealable like other design review applications.
3. New Wireless Communications Facilities. The ordinance would require a Conditional Use
Permit for all new facilities in addition to a Design Review application. This will grant the
City the most discretion over applications for new facilities because once a facility is
permitted it gains “eligible facility” status and will be permitted to increase by right under
the Spectrum Act and will also provide a consistent process for all new facilities.
The ordinance will establish the processing time for the three different permit types as follows:
Type of Wireless Facility Timeline for
City Decision
Type of Permit Required
Eligible Facilities Request
(Section 6409(a)
Facilities)
60-days after
application is
submitted
Minor Design Review – Community
Development Director review; non-appealable
Other collocations that
“substantially change the
physical dimensions of
the existing wireless
tower or base station.”
90-days after
Application is
submitted
Minor Design Review – Community
Development Director review; appealable per
Chapter 17.184 LEMC
New Wireless
Communications
Facilities
15- days after
application
submitted
Conditional Use Permit and Design Review –
Planning Commission review; appealable
pursuant to Chapter 17.168 LEMC and
Chapter 17.184 LEMC
The proposed ordinance also incorporates development standards for new and collocated
wireless communications facilities, imposes key conditions of approval, and mandates removal of
abandoned equipment. Some of the development standards include:
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•Requiring applicants to provide justification demonstrating that a proposed facility cannot
be placed on an existing building or cannot be collocated.
•Requiring monopoles to be designed as stealth facilities.
•Requiring monopoles be designed to allow for collocation of additional antennas.
•Restricting new wireless facilities in residential districts to a non-residential structure such
as a church, school, or recreational facility, including those mounted on light standards
within a public or private park.
The ordinance will also eliminate the reference to Chapter 17.67 LEMC in various chapters
(Chapters 17.60, 17.64, 17.68, 17.72, 17.76, 17.80, and 17.84) and will clarify the reference to
antennas, satellite dishes, and similar devices in those chapters is for an accessory use for non-
commercial purposes.
Summary of the Evaluation Criteria and Required Conditions of Approval Policy
In order to provide specific aesthetic design standards, staff has prepared a policy which
incorporates evaluation criteria and standard conditions of approval for wireless communications
facilities. These provisions are provided to ensure that the facilities are well maintained throughout
the life of the permit, appropriate maintenance and/or repair is done in a timely manner, and that
the facility is removed upon its abandonment. Standard Conditions of Approval have also been
developed with specific design standards to ensure that the design and placement of wireless
communications facilities will blend in with the surrounding area and will have minimal visual
impacts. The draft Evaluation Criteria and standard Conditions of Approval are included in the
attached policy (Exhibit B).
Environmental Determination
This ordinanceis not subject to the California Environmental Quality Act (CEQA) Guidelines under
the General Rule (Section 15061(b)(3)). The project involves updates and revisions to existing
regulations. The proposed code amendment is consistent with California Law, specifically
Government Code Section 65850.5 and Civil Code Section 714. Because it can be seen with
certainty that the proposed Municipal Code text amendment will have no significant negative
effect on the environment.
Fiscal Impact
Costs have been incurred for staff time to research, draft, and process the ordinance. No increase
in expenditures or revenues are anticipated as a part of this Municipal Code Amendment.
Exhibits
A – Ordinance
B – Policy No. W-1