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Home My WebLink About859 Cowan Road - Applicationr �� PLANNING APPLICATION BURLINGAME COMMUNITY DEVELOPMENT DEPARTMENT—PLANNING DIVISION 501 PRIMROSE ROAD, 2ND FLOOR, BURLINGAME, CA 94010-3997 t TEL: 650.558.7250 � FAX: 650.696.3790 � E-MAIL: PLANNINGDEPTna,BURLINGAME.ORG _ 859 �..�N . .,s�_..��...�,H � .,..�.s w ,_ �.�_��_ _.,. ,.m .. . ._ � ., . ,. _aa_a.�..,�..�.._ �._.:�._....�.;.�-� Z� Cowan Road DUP1 024-401-510 �_. PROJECT ADDRESS ASSESSOR'S PARCEL #(APN) ZONING H � '� PROJECT DESCRIPTION p';,`, Modification to existing cell site (see attached project description) z w, �` O �" a • 'i: " PROPERTY OWNER NAME APPLICANT? ADDRESS z� The Church in Buflinqame 859 Cowan Rd, Burlingame, CA 94010 O � PHONE E-MAIL �i!!�` � ?� ARCHITECTIDESIGNER APPLICANT? ADDRESS �'�'� J5 Infrastructure Partners 2030 Main St, Ste 200, Irvine, CA 92614 z � � PHONE E-MAIL Z ;'. Q i' V ! BURLINGAME BUSINESS LICENSE # J : d' ..._ ._. ,,__. . . .,._ _. . ....... ..... ... ,. ....__ . .,__,,, .,.. _ _ __ _ __ _ . _ . _,_ .. ... ._. __..._..,... . . . , ........ a` *FOR PROJECT REFUNDS* - Please provide an address to which to all refund checks will be mailed to: NAME ADDRESS a' I HEREBY CERTIFY UNDER PENALTY OF PERJURY THAT THE INFORMATION GIVEN HEREIN IS TRUE AND CORRECT TO THE BEST OF MY � KNOWLEDGE AND BELIEF. �; z L�;anPe�re Su� 9/ 11 / 2 0 O APPLICANT'S SIGNATURE (IF DIFFERENT FROM PROPERTY OWNERI DATE �: �<' I AM AWARE OF THE PROPOSED APPLICATION AND HEREBY AUTHORIZE THE ABOVE APPLICANT TO SUBMIT THIS APPLICATION TO THE H >' PLANNING COMMISSIONIDIVISION. a 0 �, Q'' PROPERTY OWNER'S SIGNATURE v,a.�� m„�,�.�-�,�.,�.��.a.� -� �.��,n� _ . _ -- �� . .n��.� a.m, � �._ �. .a_�. W...._.� �._� __,..� �,�, .m r _�. ._ .m�,.� �..._.._..�_. �..� �....�.�.w�,_.._.e —�.�...m..�� AUTHORIZATION TO REPRODUCE PLANS ! ` I HEREBY GRANT THE CITY OF BURLINGAME THE AUTHORITY TO REPRODUCE UPON REQUEST AND/OR POST PLANS SUBMITTED WITH THIS ; APPLICATION ON THE CITY'S WEBSITE AS PART OF THE PLANNING APPROVAL PROCESS AND WAIVE ANY CLAIMS AGAINST THE CITY ARISING � OUT OF OR RELATED TO SUCH ACTION C S jINITIALS OF ARCHITECT/DESIGNER) ; s � DATE � ' APPLICATION TYPE �, � � �,"" � � � { Z❑ ACCESSORY DWELLING UNIT (ADU) ❑ VARIANCE (VAR) � a ❑ CONDITIONAL USE PERMIT (CUP) �WIRELESS � �► UP� j � � �(�?�� w,�, _ � � DESIGN REVIEW (DSR) ❑ FENCE EXCEPTION LL� HILLSIDE AREA CONSTRUCTION PERMIT OTHER: ?�-'�{�-'�� "� ', � �, ❑ ❑ N❑ MINOR MODIFICATION ; ❑ SPECIAL PERMIT (SP) DATE RECEIVED: N D � � C tn m O z r � �j� INFRASTRUCTURE O�tobet 22°d, 2020 Planning Division City of Burlingame 501 Primrose Rd Burlingame, CA 94010 RE: Zoning Permit Application and Fees Applicant: New Cingular Wireless PCS, LLC ("AT&T") Property Owner: The Church in Burlingame Properly Address: 859 Cowan Rd DUP1, Burlingame, CA 94010 Dear Planner: Enclosed you will find payment for the fees for a zoning permit to modify an existing wireless facility at the above-referenced property. Also included is a copy of the application. All required documents....Submittal plans, photosims, application, EFR form, Legal letter in lieu of Waiver .....are being shipped to the City planning department in a separate package and should arrive no later than Monday, 10/26/20 AT&T applies for the zoning permit under Section 6409 of the federal Middle Class Tax Relief and Job Creation Act of 2012 (47 U.S.C.A. § 1455). That law provides: "a 5tate or local government 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." AT&T respectfully requests that the zoning permit be issued as soon as possible but no later than 60 days from the receipt of the fees and all required documents, so that AT&T can proceed with this modification immediately. If you have any questions regarding this application, please contact me. Sincerely, C�e�e �'c�i�a�e� Charlene Schlager, JS Infrastructure Partners Authorized Representative of AT&T Mobility Mobile: (773) 732-5497 Email: cschlager@JSIP.com CCL02062 - PROJECT DESCRIPTION MODIFICATION TO AN UNMANNED TELECOMMUNICATIONS FACILITY, CONSISTING OF THE FOLLOWING: AT&T WIRELESS PROJECT SCOPE WILL CONSIST OF THE FOLLOWING: • REMOVE (2) PANEL ANTENNAS FROM EXISTING TRIPOD, (1) PER SECTOR • INSTALL (2) PANEL ANTENNAS ON EXISTING TRIPOD, (1) PER SECTOR • INSTALL (2) RRUS 4478 B14 NEAR ANTENNAS, (1) PER SECTOR • INSTALL (2) 6630 WITHIN EXISTING PURCELL CABINET • REMOVE (4) RRUW FROM EQUIPMENT AREA, (2) PER SECTOR • REMOVE (1) RBS 3518 FROM EQUIPMENT AREA • REMOVE (4) 7/8" AND (4) 1-1/4" COAX • REMOVE (1) 6601 V2 CHASSIS W/(1) XMU WITHIN EXISTING PURCELL CABINET • REMOVE (1) 6601 V2 CHASSIS W/(1) 5216 +(1) XMU WITHIN EXISTING PURCELL CABINET �> � at&t �•.__�� AT&T Services, Inc. 5001 Executive Parkway Room 2W901 San Ramon, CA 94583 925.543.1548 Phone 925.867.3869 Fax jdb@att.com October 20, 2020 VIA E-MAIL kkane (�a,burlin�ame. org plannin�dept(�a,bu_ rlin�ame.o� Kathleen Kane City Attorney 501 Primrose Road Burlingame, CA 94010 JOHN DI BENE Assistant Vice President - Senior Legal Counsel �v,� � ., .._.-� �._.. `i 2 � 20Z0 �Jt= BU�! iC�.:�AME -.,, , Re: Wireless Facility Siting Application AT&T Site ID CCL02062 Property Address: 859 Cowan Road, Burlingame, California 94010 Dear Ms. Kane: I write on behalf of New Cingular Wireless PCS, LLC d/b/a AT&T Mobility ("AT&T") regarding an unlawful submittal requirement that is preventing AT&T from submitting its application to modify an existing wireless telecommunications facility in the City of Burlingame. Specifically, the Planning Department is requiring AT&T to sign an Applicant Waiver of Review Timelines before the City will accept AT&T's application. AT&T requests that the city immediately accept its application, and promptly process it to approval. Federal law prohibits the city from refusing to accept applications. Moreover, federal law requires approval of AT&T's application, which qualifes as an eligible facilities request that the city cannot deny under 47 U.S.C. § 1455(a). AT&T requests that the city immediately accept its application, and promptly process it to approval. The Telecommunications Act of 1996 requires a local government to act on wireless facility permit applications within a"reasonable period of time." � In 2009, the Federal Communications Commission ("FCC") issued a declaratory ruling, commonly known as the "Shot Clock Order," which established a legal presumption that "reasonable period of time" by establishing presumptive maximum periods of time for review of wireless siting applications.2 In 2014, the FCC established a maximum 60-day "shot clock" for eligible facilities requests under 47 U.S.C. § 1455(a).3 The FCC's rule also provides that such an application is deemed approved if the city does not act within the 60-day shot clock.4 � Ms. Kane Burlingame October 20, 2020 Pa�e 2 of 2 The FCC further clarified that local actions to halt or suspend acceptance, processing, or approval of wireless siting applications are unlawful under the Telecommunications Act.S Thus, the city must accept AT&T's application and promptly process it. In addition, federal law requires the city to promptly approve AT&T's application. Under Section 6409(a) of the Middle Class Tax Relief and Job Creation Act of 2012 (commonly known as "Section 6409(a)" and codified at 47 U.S.C. § 1455(a)), the city "may not deny, and shall approve" AT&T's application because it is an eligible facilities request that "does not substantially change the physical dimensions" of the existing base station.6 Applicable FCC regulations provide objective parameters for when modifications "substantially change the physical dimensions" of the existing facility. � AT&T's application materials demonstrate that its proposed modification qualifies as an eligible facilities request that will not substantially change the physical dimensions of the existing facility. Thus, the city must approve it within the applicable 60-day shot clock. AT&T is willing the work with the City to review the application within a reasonable period of time. If the City cannot review the application in a timely manner due to the COVID- 19 pandemic, AT&T would be willing to enter into a tolling agreement. However, AT&T will not waive all of its rights to a timely review. Please do not hesitate to contact me if you would like to discuss these issues. Sincerely, !��- , �;. f �� , �--- John di Bene JDB/j vs Cc: Michelle Markiewicz, Associate Planner (plannin�dept(a�burlin a� me.org) ` See 47 USC § 332(c)(7)(B)(ii). 2 See Petition for Declaratory Ruling to Clar� Provisions of Section 332(c)(7)(B), WT Docket No. 08-165, Petition for Declaratory Ruling to Clarify Provisions of Section 332(c)(7)(B), WT Docket No. 08-165, Declaratory Ruling, 24 FCC Rcd. 13994 (2009). 3 See 47 C.F.R. § 1.6100(c) (former 47 C.F.R. § 1.40001 has been redesignated 47 C.F.R. § 1.6100). 4 See 47 C.F.R. § 1.6100(c)(4). 5 See Accelerating Wireline Broadband Deployment by Removing Barriers to Infrastructure Investment, Third Report and Order and Declaratory Ruling, WC Docket No. 17-84 and WT Docket No. 17-79, FCC 18-111, ¶¶ 140- 68 (rel. Aug. 3, 2018). 6 See 47 U.S.C. § 1455(a)(1). ' See 47 C.F.R. § 1.6100(b)(7). Eligible Facilities Request Application -� � w' � � �'' � �.� (47 U.S.C. § 1455(a)) ' _' ; `� �i 202� Applicant: AT&T � �.JI` ��n� !I T..nr�'viC - . , �t � `. I i ' Applicant/Agent Contact Information: CHARLENE SCHLAGER - AGENT FOR AT&T 442 SYLVIA WAY, SAN RAFAEL, CA 94903 PH: (773) 732-5497 EMAIL: CSCHLAGER@J51P.COM Property Owner: The Church in Burlingame Property Location (e.g., address, parcel no., GPS coordinates): 859 Cowan Rd DUP1, Burlingame, CA 94010 Project Description: SEE ATTACHED PROJECT DESCRIPTION Date of filing: 30 days after filing: "To toll the timeframe for incompleteness, the reviewing State or local government must provide written notice to the applicant within 30 days of receipt of the application, clearly and specifically delineating all missing documents or information. Such delineated information is limited to documents or information meeting the standard under paragraph (c)(1) of this section. " 47 C.F.R. 1.40001(c)(3)(i). 60 days after filing: "Timeframe for Review. Within 60 days of the date on which an applicant submits a request seeking approva! under this section, the State or local government shall approve the application unless it determines that the application is not covered by this section. " 47 C.F.R. 1.40001(c)(2). Page 1 of 4 Applicant Initials Is the proposed modification an Eligible Support Structure? Please check the applicable boxes: An "Eligible Support Structure " means "Any tower or base station as defined in this section, provided that it is existing at the time the relevant application is filed with the State or local government under this section. " 47 C.F.R. 1.40001(b)(4). �"Tower" means "Any structure built for the sole or primary purpose of supporting any Commission- licensed or authorized antennas and their associated facilities, including structures that are constructed for wireless communications services including, but not limited to, private, broadcast, and public safety services, as well as unlicensed wireless services and fixed wireless services such as microwave backhaul, and the associated site. " 47 C.F.R. 1.40001(b)(9). ��' a"Base Station " means "A structure or equipment at a fixed location that enables Commission-licensed or authorized wireless communications between user equipment and a communications network. The term does not encompass a tower as defined in this subpart or any equipment associated with a tower. (i) The term includes, but is not limited to, equipment associated with wireless communications services such as private, broadcast, and public safety services, as well as unlicensed wireless services and fixed wireless services such as microwave backhaul. (ii) The term includes, but is not limited to, radio transceivers, antennas, coaxial or fiber-optic cable, regular and backup power supplies, and comparable equipment, regardless of technological configuration (including Distributed Antenna Systems and small-cell networks). (iii) The term includes any structure other than a tower that, at the time the relevant application is filed with the State or local government under this section, supports or houses equipment described in paragraphs (b)(1)(i)-(ii) of thi.s section that has been reviewed and approved under the applicable zoning or siting process, or under another State or local regulatory review process, even if the structure was not built for the sole or primary purpose of providing such support. (iv) The term does not include any structure that, at the time the relevant application is filed with the State or local government under this section, does not support or house equipment described in paragraphs (b)(1)(i)-(ii) of this section. " 47 C.F.R. 1.40001(b)(1). <� �ati ❑✓ "Existing"— "A constructed tower or base station is existing for purposes of this section if it has been reviewed and approved under the applicable zoning or siting process, or under another State or local regulatory review process, provided that a tower that has not been reviewed and approved because it was not in a zoned area when it was built, but was lawfully constructed, is existing for purposes of this definition. " 47 C.F.R. 1.40001(b)(S). 2. What is the baseline height of the Eligible Support Structure? Please complete the Baseline Height Worksheet and insert baseline height here 31'-9" . For modifications that will not change the height of the Eligible Support Structure, insert "N/A." Page 2 of 4 Applicant Initials 3. Is the proposed modification an Eligible Facilities Request? An "Eligible Facilities Request " means "Any request for modification of an existing tower or base station that does not substantially change the physical dimensions of such tower or base station, involving: (i) collocation of new transmission equipment; (ii) removal of transmission equipment; or (iii) replacement of transmission equipment. " 47 C.F.R. 1.40001(b)(3); 47 U.S.C.1445(a). "Collocation " means "The mounting or installation of transmission equipment on an eligible support structure for the purpose of transmitting and/or receiving radio frequency signals for communications purposes. " 47 C.F.R. 1.40001(b)(2). "Transmission equipment" means "Equipment that facilitates transmission for any Commission-licensed or authorized wireless communication service, including, but not limited to, radio transceivers, antennas, coazial or fiber-optic cable, and regular and backup power supply. The term includes equipment associated with wireless communications services including, but not limited to, private, broadcast, and public safery services, as well as unlicensed wireless services and fixed wireless services such as microwave backhaul. " 47 C.F.R. 1.40001(b)(8). 3.1 Please check all applicable boxes that describe the proposed modification: ✓�Collocation of new transmission equipment �Removal of transmission equipment �Replacement of transmission equipment 3.2 Please complete the Substantial Change Worksheet to determine if the proposed modification substantially changes the physical dimensions of the Eligible Support Structure. Based on the Substantial Change Worksheet, will the proposed modification substantially changes the physical dimensions of the Eligible Support Structure? No If you answered "Yes," stop because the application is not an eligible facilities request. 4. Compliance with State and Federal regulations and codes. The proposed modification— Cl�etk �r�1 ca�plicr��de bt�xn� �Will comply with FCC regulations regarding human exposure to radio frequency electromagnetic fields aWill comply with Federal Aviation Administration (FAA) and FCC tower lighting requirements ✓�Will comply with applicable state environmental regulations �✓ Will comply with applicable building codes Page 3 of 4 Applicant Initials �Will comply with applicable fire codes ✓❑ Will comply with other non-discretionary and generally applicable structural and safety codes ❑✓ Will comply with Section 106 historic preservation review, if applicable �Will comply with the National Environmental Policy Act (NEPA), if applicable 5. Attachments: �Completed Baseline Height Worksheet �Completed Substantial Change Worksheet �Letter of authorization �Applicable non-discretionary permit fees ✓❑Building drawings, including site details and plans �✓ Documentation of property rights to site �✓ Prior approval for Eligible Support Structure ❑ Other: Page 4 of 4 Applicant Initials Baseline Height Worksheet � 2. Does the application seek approval for collocation or replacement of transmission equipment? �No. Stop, the height will not increase for removal of transmission equipment. Continue to #7 and respond "N/A." ❑✓ Yes. Continue to #2. Was the tower or base station subject to previous review and approval by the local jurisdiction (as originally built or as nzodified to its current state)? ❑✓ Yes. Continue to #3. �No. Does the application seek to modify a tower or base station that was in a zoned area when built? A. �No. Was the tower or base station lawfully constructed? i. �Yes. ii. �No. Request. Continue to #3. Stop, the application is not an Eligible Facilities B. �Yes. Stop, the application is not an Eligible Facilities Request (because the tower or base station is not considered "existing"). 3. Does the application seek to collocate transmission equipment that will be separated horizontally on a base station (such as on a rooftop)? � �✓ Yes. Continue to #7. The baseline height is that of the original support structure (e.g., the height of the rooftop, penthouse). �No. Continue to #4. : 4. Has the tower or base station been modified per a previous approval by the local jurisdiction? A. �✓ No. Continue to #7. The baseline height is the originally-approved height of the tower or base station. B. �Yes. Continue to #5. Baseline Height Worksheet Page 1 of 2 Applicant Initials 5. Was the tower or base station modified based on approval by the local jurisdiction issued before February 17, 2012?1 A. �Yes. Continue to #6. B. �No. Continue to #7. The baseline height is the height of the tower or base station as of February 17, 2012. 6. Was the tower or base station modified to the maximum height approved by the local jurisdiction per any approval(s) before February 17, 2012? A. �Yes. Continue to #7. The baseline height is the existing height of the tower or base station. B. �No. Continue to #7. The baseline height is the height as approved by the local jurisdiction before February 17, 2012. 7. Insert baseline height here 31 �-9�� and at item 2 to the Eligible Facilities Request Application. ' The Spectrum Act was passed by Congress on February 17, 2012 and signcd into law by the President on February 22, 2012. The FCC's Report and Order and regulations refer to the date of passage rather than date of enactment as the trigger for the analysis. Approvals issued after February 17, 2012 do not affect the baseline dimensions for determining whether an application proposes a substantial change. Baseline Height Worksheet Page 2 of 2 Applicant Initials Substantial Change Worksheet Definition of "Substantial Change": "Substantial Change " means "A modification substantially changes the physical dimensions of an eligible support structure if it meets any of the following criteria: (i) for towers other than towers in the public rights-of-way, it increases the height of the tower by more than 10% or by the height of one additional antenna array with separation from the nearest existing antenna not to exceed twenty feet, whichever is greater; for other eligible support structures, it increases the height of the structure by more than 10% or more than ten feet, whichever is greater; (A) Changes in height should be measured from the original support structure in cases where deployments are or will be separated horizontally, such as on buildings' rooftops; in other circumstances, changes in height should be measured from the dimensions of the tower or base station, inclusive of originally approved appurtenances and any modifications that were approved prior to the passage of the Spectrum Act. (ii) for towers other than towers in the public rights-of-way, it involves adding an appurtenance to the body of the tower that would protrude from the edge of the tower more than twenty feet, or more than the width of the tower structure at the level of the appurtenance, whichever is greater; for other eligible support structures, it involves adding an appurtenance to the body of the structure that would protrude from the edge of the structure by more than six feet; (iii) for any eligible support stnscture, it involves installation of more than the standard number of new equipment cabinets for the technology involved, but not to exceed four cabinets; or, for towers in the public righls-of-way and base statio�zs, it involves installation of�any new equipment cabinets on the ground if there are no pre-existing ground cabinets associated with the structure, or else involves installation of ground cabinets that are more than 10% larger in height or overall volume than any other ground cabinets associated with the structure; (iv) it entails any excavation or deployment outside the current sitez; (v) it would defeat the concealment elements of the eligible support structure; or (vi) it does not comply with conditions associated with the siting approval of the construction or modification of the eligible support structure or base station equipment, provided however that this limitation does not apply to any rnodification that is noncomplia�st only in a manner that woz�ld not exceed the thresholds identified in � 1.40001(b)(7)(i)-(iv). " 47 C.F.R. 1.40001(b)(7). Check the box that describes the Eligible Support Structure: ❑✓ Base station. Continue to #2. �Tower located in the public right-of-way. Continue to #2. �Tower located outside of the public right-of-way. Continue to #3. z"Site "—"For towers other than towers in the public rights-of-way, the current boundaries of the leased or owned property surrounding the tower and any access or utility easements currently related to the site, and, for other eligible support structures, further restricted to that area in proximity to the structure and to other transmission equipment already deployed on the ground. " 47 C.F.R. 1.40001(b)(6). Substantial Change Worksheet Page 1 of 4 Applicant Initials 2. Answer the following questions about the proposed modification and proceed as instructed: A. Is the baseline height for the Eligible Support Structure greater than 100 feet? �Yes. Continue to item 2B. �No. Continue to item 2C. B. Does the proposed modification increase height by more than 10°/a of the baseline height? �Yes. Continue to item 11. �No. Continue to item 2D. C. Does the proposed modification increase height by mare than 10 feet? �Yes. Continue to item 11. �✓ No. Continue to item 2D. D. Does the proposed modification add any appurtenance that would protrude more than 6 feet from edge of the Eligible Support Structure? �Yes. Continue to item 11. �No. Continue to item 4. 3. Answer the following questions about the proposed modification and proceed as instructed: A. Will the proposed modification increase height by more than 10% of the baseline height of the Eligible Support Structure? �Yes. Continue to item 3B. �No. Continue to item 3C. B. Will the proposed modification increase height by more than the height of one additional antenna array with separation from the nearest existing antenna not to exceed 20 feet? �Yes. Continue to item 11. ❑No. Continue to item 3C. Substantial Change Worksheet Page 2 of 4 Applicant Initials C. Does the proposed modification add any appurtenance that would protrude more than 20 feet from the edge of the Eligible Support Structure? �Yes. Continue to item 3D. �No. Continue to item 4. D. Does the proposed modification add any appurtenance that would protrude more than the width of the tower structure at the level of the appurtenance? �Yes. Continue to item 11. �No. Continue to item 4. 4. Does the proposed modification involve installation of more than standard number of equipment cabinets for the technology involved, not to exceed four? �Yes. Continue to item 11. �No. If the Eligible Support Structure is a base station, continue to item 5. If the Eligible Support Structure is a tower in the public right-of-way, continue to item 5. If the Eligible Support Structure is a tower outside of the public right-of- way, continue to item 8. 5. Does the proposed modification involve installation of any new equipment cabinets on the ground? �Yes. Continue to item 6. �No. Continue to item 8. 6. Are there any pre-existing ground cabinets associated with the Eligible Support Structure? �Yes. Continue to item 7. ❑No. Continue to item 11. 7. Are the proposed new ground cabinets more than 10% larger in height or overall volume than any other ground cabinets associated with the Eligible Support Structure? �Yes. Continue to item 11. ❑No. Continue to item 8. Substantial Change Worksheet Page 3 of 4 Applicant Initials 0 . 8. Does the proposed modification involve excavation or deployment outside of the current site3? �Yes. Continue to item 11. �No. Continue to item 9. 9. Will the proposed modification defeat the existing concealment elements of the Eligible Support Structure? �Yes. Continue to item 11. �No. Continue to item 10. 10. Will the proposed modification comply with conditions associated with the siting approval(s)? A. �✓ Yes. Continue to item 12. �No. Describe the non-compliance: Continue to item l OB. �Not applicable. Continue to item 12. B. Is the non-compliance with conditions associated with the siting approval(s) based on any of the following: (a) height, (b) protrusion of any appurtenance from edge of the Eligible Support Structure, (c) number of equipment cabinets to be installed, (d) location of excavation, ar(e) impact to concealment elements that would not exceed the thresholds outlined above? ❑Yes. Continue to item 12. �No. Continue to item 11. 11. The proposed modification is a substantial change to the physical dimensions of the existing tower or base station. Insert "Yes" in item 3.2 of the Eligible Facilities Request Application. 12. The proposed modification is not a substantial change to the physical dimensions of the existing tower or base station. Insert "No" in item 3.2 of the Eligible Facilities Request Application. 3 See footnote 2. Substantial Change Worksheet Page 4 of 4 Applicant Initials