Submitted by Pete Simmons, applicant for petition number PLNPCM2020-00284
Salt Lake City Zoning Amendment Application
Amendment to text of Zoning Ordinance
Applicant: Verizon Wireless
Project Description
1. A statement declaring the purpose for the amendment.
The purpose for the requested amendment is to allow for the deployment of wireless
facilities that are concealed or stealth design within all zoning districts in Salt Lake City with a
maximum height of 60’. Currently, as drafted, the Salt Lake City Land Use Code limits the
deployment of freestanding wireless facilities to certain zoning districts and only up to the height
limit of the zoning district. Sections 21A-40-090E.2.f, 21A-40-090E.5 and Table 21A-40-090E
of the Wireless Telecommunications Facilities currently limit the height for stealth facilities to
the height exception allowed under Section 21A.36.020.C – Conformance with Lot and Bulk
Controls (Height Exceptions). However, Section 21A.36.020.C – Conformance with Lot and
Bulk Controls (Height Exceptions) does not allow for height exceptions for stealth wireless
facilities. As there is no height exception allowed under Section 21A.36.020.C – Conformance
with Lot and Bulk Controls (Height Exceptions) for stealth facilities, the default height limit is
the height limit for the zone district. In certain instances, the height limits may be 30’ or 35’.
There is no mechanism to seek a height exception either through the wireless section or height
exceptions of the code.
Wireless providers often cannot deploy macro facilities that are below 60’ in height as
they cannot meet the RF requirements to provide effective wireless services. Or, in certain
instances, lower heights may have interference from trees, surrounding buildings, etc. The taller
height allows the macro facilities to provide services above clutter that may otherwise cause
signal interference. Further, macro facilities are necessary for the deployment of both 4G and
5G services. Macro facilities are the overlay to small wireless facilities that provide 5G services.
(See attached map). Verizon Wireless requests the proposed text amendment to allow for the
placement of freestanding wireless facilities that are stealth design in all zoning districts up to
60’ so it can provide the necessary wireless services.
Wireless demand was growing exponentially prior to the COVID-19 pandemic, in
particular, in residential areas. Over 50% of all households are wireless now with no wireline
connections. Over 90% of all 9-1-1 calls are made from wireless devices. Now, with the
COVID-19 pandemic, the growth curve for wireless services is even more significant. The
COVID-19 pandemic is the textbook example of why the deployment of wireless services is
critical and necessary, especially in residential areas.
• Emergency Services: All emergency service responders use wireless services to
respond to 911 calls, to locate residences through GPS systems, to utilize medical
equipment, and to provide other critical emergency responses. In addition,
wireless services are critical to allow citizens to place e-911 calls because of the
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rising number of all wireless households. All of these providers are considered
essential, if not critical during this time period.
• Telemedicine: Telemedicine has started to replace in-office patient visits to assist
with reducing the spread of COVID-19. Wireless services allow both citizens and
medical professionals to use telemedicine apps.
• Online Schooling and Remote Work Environments: Schools and higher
education facilities are closed requiring students to use wireless services to
engage and participate in their online learning and virtual classrooms. In almost
every state in the country, a majority of the workforce is working remotely from
home. Online schooling and remote work environments require apps such as
Zoom, Microsoft Meeting, Skype and GoToMeeting, which all rely on wireless
services.
2. A description of the proposed use of the property being rezoned.
As set forth above, Verizon Wireless is proposing an amendment to the City’s Code that
will allow for administrative approval of all wireless facilities that are of stealth design in all
zoning districts and subject to a height limitation of 60’.
By way of example, Verizon Wireless seeks to submit an application for a freestanding
macro facility on the property of the Pioneer Precinct – Salt Lake City Police Department.
Importantly, the proposed facility will substantially improve the wireless services in this area
including for residential areas as well as emergency services provided by Salt Lake City’s Police
Department and other emergency departments. The proposed facility is a stealth design of a
monopine, which will blend in with the surrounding trees on the property.
Verizon Wireless initially submitted an application for an 80’ facility. 80’ is the height
that will allow Verizon Wireless to deploy the most optimal wireless services. However, in
speaking with the City, the City expressed a few concerns: 1) the zoning district height limit is
35’, 2) the facility’s close proximity to residential areas, and 3) the City wants structures to blend
in with the surrounding environments. To address the City’s concerns, Verizon Wireless worked
with its RF engineer who advised that Verizon Wireless could deploy a facility at 60’ as it will
improve the wireless services although not as much as the 80’ facility. The height limit for
Public Lands zone district is 35’. A 60’ facility will blend in more with the building height limit
and not be as obtrusive as the 80’ facility. Additionally, the 60’ facility potentially will allow
other wireless carriers to collocate on the facility. This may reduce the number of freestanding
wireless facilities in the area. Further, the 60’ facility will be designed as a stealth monopine,
which will blend in with existing trees on the property and surrounding areas that are 50-60’.
Attached are three coverage maps provided by Verizon Wireless that demonstrate the proposed
coverage the facility can provide – the first map shows the existing coverage without the wireless
facility, the second map shows the coverage with a 80’ facility, the optimal height for the
facility, and the third map shows the wireless coverage with a 60’ facility, which still allow
Verizon Wireless to significantly improve coverage in the area.
While Verizon Wireless will agree to deploy the facility at 60’, there is no height
exception under Sections 21A-40-090E.2.f, 21A-40-090E.5 and Table 21A-40-090E of the
Wireless Telecommunications Facilities or Section 21A.36.020.C – Conformance with Lot and
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Bulk Controls (Height Exceptions) that allows for Verizon Wireless to seek an exception for a
taller facility. To address this specific application and future applications, Verizon Wireless
requests certain text amendments to the Code to allow for deployment of taller facilities subject
to certain stealth/concealment requirements as set forth below in Section 5.
3. List the reasons why the present zoning may not be appropriate for the area.
As set forth above in Section 2, the present zoning is not appropriate as it substantially
limits the ability of wireless service providers to deploy necessary macro facilities in areas where
service is most critical – residential areas and zones and zones surrounding residential areas.
Further, the height limitation to the height limit of the zoning district without any mechanism for
a height exception under Section 21A.36.020.C – Conformance with Lot and Bulk Controls
(Height Exceptions) effectively prohibits wireless providers from deploying service. 47 U.S.C. §
332(c)(7)(B)(i)(II) (the City may not regulate the construction of wireless facilities in such a way
as to “prohibit or have the effect of prohibiting the provision of personal wireless services.”).
4. Is the requested amending the Zoning Map? No.
5. Is the request amendment the Zoning Ordinance? If so, please include language and the
reference to the Zoning Ordinance to be changed.
Verizon Wireless respectfully request the City Council amend Sections 21A-40-090E.2.f,
21A-40-090E.5 and Table 21A-40-090E of the Wireless Telecommunications Facilities. A copy
of the proposed text amendments in track changes are attached to this application.
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Verizon Wireless
Proposed Facility at
1040 West 700 South
Service Improvement Maps
3/24/2020
Confidential and proprietary materials for authorized Verizon personnel and outside agencies only. Use, disclosure or
distribution of this material is not permitted to any unauthorized persons or third parties except by written agreement.
Signal Strength Map: Today
Green = good
outdoor + indoor
service
Yellow = good
outdoor, mediocre
indoor service
Blue = poor
outdoor, poor
indoor service
White = possibly no
service (mostly
indoor locations)
Confidential and proprietary materials for authorized Verizon personnel and outside agencies only. Use, disclosure or
distribution of this material is not permitted to any unauthorized persons or third parties except by written agreement. 2
Signal Strength Map: With New Facility, 80’ Height
Green = good
outdoor + indoor
service
Yellow = good
outdoor, mediocre
indoor service
Blue = poor
outdoor, poor
indoor service
White = possibly no
service (mostly
indoor locations)
Confidential and proprietary materials for authorized Verizon personnel and outside agencies only. Use, disclosure or
distribution of this material is not permitted to any unauthorized persons or third parties except by written agreement. 3
Signal Strength Map: With New Facility, 60’ Height
Green = good
outdoor + indoor
service
Yellow = good
outdoor, mediocre
indoor service
Blue = poor
outdoor, poor
indoor service
White = possibly no
service (mostly
indoor locations)
Confidential and proprietary materials for authorized Verizon personnel and outside agencies only. Use, disclosure or
distribution of this material is not permitted to any unauthorized persons or third parties except by written agreement. 4
Wireless Ecosystem
Macro Site
Small Small Small Small
Cell Cell Cell Cell
HUB
In-Building In-Building In-Building
MTSO/
Switch
• Coordinate signals between Macros, small cells, and in-building systems
• Reduces interference and improves performance / capacity
VERIZON WIRELESS MONOPINE SAMPLES
Sal Snowbasin- Snowbasin Ski Resort, Hanksville, UT
This is a 67’ Stealth Monopine on Private Property. Access will need to be coordinated.
Sal Gabbro- 9850 South 2700 East, Sandy, UT
This is a 67’ Stealth Monopine on Private Property. Access will need to be coordinated.
Sal Granite- 3340 East 7800 South, Sandy, UT
This is a 62’ Stealth Monopine near the mouth of Little Cottonwood Canyon at a trailhead for the Bells Canyon Trail. The site is
accessible from the parking area.
Sal Rustic Acres - 750 East 10600 South, Sandy, UT
This is a 65’ Stealth Monopine in the rear of commercial business. The site is accessible from the parking lot.
Sal Oquirrh Shadows- 5850 South 5600 West, Kearns, UT
This is a 60’ Stealth Monopine at Thomas Jefferson JR HS. The site is on School Property. Access will need to be coordinated.
Sal Camporee – 9955 South 2300 East, Sandy, UT
This is a 67’ Stealth Monopine at Park Lane Elementary School. The site is on School Property. Access will need to be coordinated.
