HomeMy WebLinkAboutIsotrope Report Received 06.30.23
Thinking outside the sphere
www.isotrope.im Isotrope, LLC ◦ 503 Main Street ◦ Medfield, MA ◦ 02052 508 359 8833
Report on: Blue Sky Towers Tower Petition 5005
PETITION 5005: Blue Sky Towers III, LLC dba BSTMA, LLC. Property Location:
1044 Route 28, Yarmouth, MA. Map & Lot #: 50.189.1; Zoning District: B-2,
HMOD-1, VC-3. The Applicant seeks a Special Permit per §103.2.2 and §408 to
construct a 110-foot wireless telecommunications facility tower.
Isotrope, LLC was engaged by the Yarmouth Zoning Board of Appeals (“Board”) to
review the application by Blue Sky Towers to construct a 110-foot-tall wireless
telecommunications tower at the above-captioned address. The Board opened the hearing
on March 9, 2023. In addition to hearing the applicant, the Board decided to engage the
services of a consultant and reflected that two major topics were of primary interest to the
Board in the hearing.
1) Is there a significant gap in service?
2) Are there any less objectionable alternatives?
Service Availability
The applicant obtained approval from the Cape Cod Commission (“Commission”) under
its Development of Regional Impact protocols. The Commission authorized a tower with
external antennas mounted in a relatively narrow configuration. As a result of its pre-
application discussions with the Town, the applicant chose to apply for a clock tower
design instead.
Recommendation: Considering the fact that the Commission approved an exposed-
antenna design and the Town was interested in the difference between a stealth design
and the Commission-authorized design, it would be prudent to put both designs on the
record for consideration.
The coverage maps provided by T-Mobile and by C-Squared Systems on behalf of
AT&T show a large area of substandard coverage in Yarmouth, particularly between the
coverage available from Rt 6 facilities, south past the proposed site, to the coast. The
focus of the proposed tower is the Rt 28 corridor (although we note that the T -Mobile
materials originally submitted to the Cape Cod Commission indicated that T -Mobile was
interested in placing one facility roughly central to the area between Rt 6 and the coast,
so the presently proposed location is not the only one that could significantly improve
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coverage in this large region claimed as a gap; this gives the town some additional
leeway in looking for alternative sites farther from the proposed location.). Samples of
the coverage maps provided by the carriers are shown below. See Application Tabs 7 & 8
for more.
Figure 1 - T-Mobile Existing
Coverage mid-band
Figure 2- AT&T Existing Coverage low-band
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The term “significant gap” is one that is used by the court. There is no engineering
definition of it. We can describe the level of service that the evidence shows but we
cannot stand in the shoes of the court and predict what the court would say. Our role as
the Board’s expert is to teach more than it is to simply give opinions. By becoming
informed about the facts on the record, the Board can determine for itself whether this
area of subpar service is likely to be protected by the Telecommunications Act (TCA).
Another aspect of the idea of a gap is its significance. Much of the area to be served by
the proposed facilities is highly traveled, densely residential and densely commercial.
This points to the dual issues of coverage (signal strength) and capacity (the ability to
serve the numbers of simultaneous users with levels of performance that are satisfactory
to them). It is generally much simpler to provide coverage evidence in the form of
coverage maps than it is to demonstrate current or impending capacity issues with the
local network. Usually, the capacity issue is blended with the coverage claim by pointing
out the density of human activity in the area and implying that capacity is an issue too. If
this were solely a capacity-oriented application, we would suggest there be more
information to be added to the record to substantiate a capacity claim. As it stands, there
is a large area with demonstrably substandard signal strength in the vicinity of the
proposed tower and we rely on the evidence of that for the purpose of this hearing.
Alternatives
There are several approaches to searching for alternatives. Initially, a proposed site could
be considered for alternatives in the form of height reduction, design changes (like a
stealth design or camouflage that might be architecturally/visually more pleasing, and/or
relocation on the parcel.) Meanwhile, alternative locations can be considered including
the use of existing structures or alternative sites for a tower. In some cases, more sites
with less impact per site might be considered (which carriers generally do not prefer)
over a proposed large (“macro”) central facility on a tower or other structure. Such
solutions could include the “small cell” typically mounted on utility poles (height
typically between 25 and 50 ft above ground and limited coverage area, or small tower
implementations like the concealed-antenna-monopole (“CAM”) that the Cape Cod
Commission allows up to 80 feet without Commission review.
The CAM
The Cape Cod Commission exempts 80-foot concealed-antenna monopoles (CAMs) from
DRI review. Verizon has such a monopole nearly across the street from the proposed
tower. The two carriers (T-Mobile and AT&T) that have signed on with the applicant
(Blue Sky) say there is insufficient space and height at the Verizon CAM. We agree. The
limitations on space and height preclude the use of the Verizon CAM for any secondary
user other than for small cell coverage over a limited area near the CAM. If, instead,
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AT&T or T-Mobile were to build 80-foot CAMs in this area, it also would be unlikely
that both could occupy one 80-ft CAM successfully.
Also, we agree with the applicant that to achieve at least the same level of coverage from
CAMs as obtained from the tower, more than one CAM would likely be necessary for
each carrier. Thus, if CAMs were to replace the proposed tower, expect that four CAMs
at four independent locations would be needed by AT&T and T-Mobile in the area (two
for AT&T and two for T-Mobile). Such a solution would likely provide more coverage
than the proposed tower. This is because the proposed facility does not “fill” the area
described as the gap in coverage for each carrier. Having more, shorter facilities spread
around could provide even broader new coverage and reduce the need for future full-size
towers in the town. More analysis of the coverage and the potential locations for these
would be necessary.
The wireless bylaw encourages carriers to share towers to reduce the number of towers.
This is a commonly used principle, with one possible down-side: if more, shorter towers
spread around the area are collectively less impactful than a few very tall towers, the
tower-sharing principle might not be the best long-term strategy. This requires a dialog
within the community and identification of likely sites distributed throughout the
community for such CAMs.
It is also difficult to convince carriers – and even more so, tower developers – to accept
an edict to use multiple short CAMs instead of one or more tall towers. Carriers generally
dislike CAMs because they limit the number of antennas one carrier can deploy, require
additional space for their radio heads (if installed in the CAM with the antennas) or add
unnecessary cable loss using coaxial cables (to connect to ground-mounted radio heads).
Suspicions of unnecessarily high heat loading with interior-mounted radio heads have
been raised as a detriment of CAMs, although we have seen no data demonstrating this is
a real issue that cannot be solved with such methods as cooling or ventilation.
Small Cells
Small cells are compact facilities typically mounted to utility poles to provide fill -in
coverage in small gaps or fill-in capacity where the coverage is already adequate, but the
usage is too much for an existing cell site. The underserved area in this part of Yarmouth
is of substantial size and substantial intensity of use. Having an umbrella of coverage
from a macro cell site would provide the general coverage needed, which then could be
supplemented later with small cells as needed. For example, in Burlington, Massachusetts
recently AT&T proposed a small-cell installation on a lamppost in the median of the road
that accesses the Burlington Mall and a Lahey Clinic. Existing cell coverage was
functional but not superb, and AT&T chose to supplement existing coverage with a
highly localized fill-in on a street pole at a busy location.
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Alternative Tower Locations
Alternate locations considered during the Commission hearing have been resurfaced in
the present hearing. Large parcels not in residential use are the likely targets. In the
present hearing, the “property behind Skull Island Golf course” was mentioned as a
possibility (photo below). As we recall, that general location was considered by the two
carriers as being acceptable from a coverage standpoint. It is still generally located in the
corridor between Rt 6 coverage and the south coast and it has the ability to reach Rt 28
commercial areas and adjacent dense residential areas.
A comment in the hearing was made that if it is too close to Seine Pond it could affect
residential views from the north side of the pond, including from the waterside public
boardwalk at the end of Meadowbrook Rd. This can be mitigated by selecting a location
far enough south of the pond that the treeline at the pond’s south edge provides screening
to a tower. In other words, there may be a benefit from setting a tower moderately back
from Rt 28, but not too far back as to encroach upon pond views. Several parcels in this
area could be considered. The parcel adjacent to the east has a shopping center on it,
which also could be a compatible location if there is a place to fit it on the site. A tower
Golf
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could potentially be located 300 feet or more from the street at any of these locations and
still be substantially south of the pond.
One of the disadvantages of the proposed location is that it is particularly open to views
as one travels west on Rt 28, the tower being in line with the bore1 of the roadway. At
Skull Island or another nearby site, the roads do not line up with views to the middle of
the parcels. Moreover, there is more commercial development around some of these
parcels that might be less objectionable visually than that proposed behind a church, 121
feet from the main road and next to residential parcels.
Further discussion pointed toward some large nonresidential parcels (records suggest the
following listed owners: Tedeschi and Davenport) north of the proposed site. (image
below) If available, a tower at one of these locations might be less starkly visible to
passersby.
1 In 1999, working for the Cape Cod Commission and the Lower Cape Towns, we coined a term “boresight
view” to describe the experience of driving/walking/riding down a straight road where at the end of the
straightaway there is a cell tower projecting high above the tr eeline. The “bore” of the road is the area
devoid of vegetation on and beside the paved area which provides an unscreened view of the tower for
the duration of the journey on the road segment. Towers that are off to the side of the road and not
aligned with the bore are generally less noticeable and less visually dominant.
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We also noticed the large industrial parcel identified as 688 Willow St. It hosts a
trailerpark and several industrial/commercial uses. Potentially, a tower at this location
could take advantage of the parcel size, tree cover and mixed industrial use to obtain a
less objectionable appearance than the proposed tower.
Obviously, any of these alternatives would require an effort to address availability,
constructability and potential visual impact in comparison to the proposed tower.
Design
The Cape Cod Commission’s approach was to reduce the visual mass of the proposed
tower by setting a narrower antenna mount than is customary. The busy articulation of
the various tower-mounted components would remain visible and appear in contrast with
light and shadow cast across them. The objective of a concealment, like a clock tower
design, is to create something that has a more appealing look (more architectural and less
industrial) even if it is apparent to the seasoned onlooker that it is a cell tower
concealment. These two objectives – visual mass reduction versus decorative aesthetic –
are sometimes in tension with each other.
Some commenters questioned the use of the proposed lower elevation for the clock
works. If the clock were placed in the top panel, that does not preclude a wireless antenna
installation there. Electric Time Company makes tower clock mechanisms that drive
large hands many feet long. Their standard mechanisms are no more than about 1 foot
square. Wireless antennas often are spaced more than a foot apart, so the mechanism
could be avoided when installing antennas around it. The clock hands can be RF
transparent.
Electric Time also offers an RF transparent clock motion-works to eliminate a need to
avoid the mechanism if antenna positioning is tight. See attached spec sheets for these
two models. There are other models depending on the size of the clock hands required.
We expect there are other producers of such timekeeping products.
David Maxson, WCP
Isotrope, LLC
503 Main St
Medfield, MA 02052
June 12, 2023