AT&T Mobility is interested in Witter Ranch Park as a leasing site in which they propose to construct, operate, and maintain a wireless communications facility. As the established neighborhood association that represents the area in which the park is located, Witter Ranch Community Alliance leadership was approached early in the proposal’s life cycle for its feedback. Many hours of meetings and study were conducted between March 2011 and March 2012 to influence the design of the proposed build and to explore opportunities to maximize benefits to the community, all within the context of the principle that if our community is to host such a facility in our neighborhood park, then the benefits to the community must exceed its costs. The aim of this report is to cover all of the pertinent facts: what the proposed facility would look like, why certain design decisions were made, what measures ensure the public’s safety, how WRCA conducted an outreach campaign to maximize awareness of the proposal at this stage with residents nearest the proposed site, what feedback WRCA leadership has received to date, and what position WRCA’s leadership is prepared to take on this proposal.
The Design Process
Wireless communications facility designs range widely, from highly industrialized towers with no effort to mitigate their visual impact, to moderately camouflaged structures, to cleverly designed solutions that conceal nearly all components to such a degree that their function is virtually undetectable.
AT&T’s initial approach involved replacing our park’s northwest 92-foot tall field light standard with a larger one that would host antennas in a low profile configuration towards the top of the pole and would accommodate the lights as well. This concept has been done before in our city, such as at Inderkum High School behind the bleachers and at George Sim Park in South Sacramento. The design was proposed because the method avoids erecting an additional tower which communities often find objectionable. However, since the Witter Ranch community has a longstanding issue with the existence of the field lights (they are not included in the park’s master plan, community members objected to the lights when they were proposed, and it is the community association’s stance that they never should have been installed and should be relocated to a larger and more suitable park in Natomas), plus the fact that an additional freestanding building to house equipment would need to be constructed in the park near the tower, WRCA’s Board of Representatives reacted quickly to discourage such a design and proposed alternate design ideas that it believed would be a better fit for the community.
The board’s position throughout the design process has been one of advocacy for the community, not the applicant or their project, all in accordance with our purpose, core values, and goals.
A number of alternate designs were presented, however, WRCA leadership believed that a more creative solution was in order.
A New Design — A Witter Ranch Landmark
AT&T listened to the feedback it received from WRCA leadership and responded with a design proposal that they believed would have a greater opportunity for community acceptance — a concept that would completely conceal the tower and antennas inside a faux wooden water tower atop a steel structure painted to match the color scheme of the adjoining restroom building. The water tower concept was proposed for two primary reasons — one reason being that the park, the school, and the neighborhood association itself were named after The Historic Witter Ranch Farm and the tank design pays homage to the ranch; and the other reason being the fact that a lack of tall mature trees in the area makes it impossible to camouflage a 70-foot tall structure from the skyline. Since it was evident from the beginning that “it” would be visible for miles in several directions, it seemed to make sense for “it” to be a work of art — and the only “it” that seemed to make practical sense in context of a park with a playground already designed with a ranch motif was a water tank.
Since the tank would be so visible, a unique design element was added that gives the tank an additional prospective benefit. The historic ranch has an iron gate and fencing that includes the words “WITTER RANCH” and a prominent capital “W,” so it seemed fitting to feature a similar logo design on the tank itself. The design features the logo emblazoned in two locations, one visible from the direction of the elementary school and the other from the direction of Arena Blvd. near the freeway overpass. This allows the water tank to perform better as a landmark for the Gateway West and Park View neighborhoods where there is otherwise little to distinguish it from other neighborhoods in Natomas.
Since AT&T requires nearly 400 square feet for their ground-level equipment cabinets, a split-face concrete wall enclosure is proposed to extend out southeastward from the existing restroom structure directly under the location of the proposed tank. Although the wall would be constructed with materials to match the restroom building, WRCA’s board advocated for all of the walls (including the restrooms) be covered in ivy, and that specification was indeed added to the blueprint. This serves not only to beautify the restroom and the expanded footprint that the facility would require, but also to act as a deterrent to graffiti on the restroom building which has been a problem in the past. None of the equipment cabinets would be visible from outside the enclosure and all cables and conduits would be hidden from view.
Due to the de facto building moratorium that has been in effect since Natomas levees lost their certification on December 8, 2008, it is not possible to build a grade-level structure at this time with a roof on it, which explains why the equipment enclosure has no lid.
In accordance with city policy regarding the construction of new wireless communications facilities, this project is engineered to accommodate equipment and antennas for a secondary carrier besides AT&T. The size height and form factor of the tank allows the antennas of a secondary carrier to be completely concealed from view. However, the ground-level equipment of the secondary carrier would not fit in the enclosure, so when that carrier is added to the facility in the future, their cabinets would be located in a similar enclosure off the northeast corner of the restroom structure. The size and shape of that enclosure has not been determined because it depends on the needs of the carrier — some carriers, like MetroPCS, only require a couple of cabinets, whereas Verizon requires a footprint similar to AT&T’s.
If a permit is granted to AT&T, that permit will not cover the secondary carrier’s enclosure. The secondary carrier would be required to submit its own permit application for their enclosure, a process which also would require community outreach.
It is estimated that the combined overall width of both enclosures plus the restroom building would be up to 55 feet long.
Safety Concerns Addressed
As soon as the idea of a wireless communications facility in Witter Ranch Park surfaced, a number of safety concerns were raised — from EMF energy levels in the playground and the surrounding homes, to the prospect of youths climbing the structure, to the risk of electrocution by copper thieves. A detailed EMF report that assumes two carriers operating at maximum capacity was provided that demonstrates extremely low EMF levels at ground level in the area surrounding the facility to be so far below federal standards as to be barely measurable — according to the report, antennas for modern wireless communications facilities such as this one “require line-of-site paths for good propagation, and are typically installed above ground level. Antennas are constructed to concentrate energy towards the horizon, with as little energy as possible scattered towards the ground or the sky. This design, combined with the low power of PCS facilities, generally results in no possibility for exposure to approach Maximum Permissible Exposure (MPE) levels, with the exception of areas directly in front of the antennas . . . Based on worst-case predictive modeling, there are no modeled areas on any accessible ground-level walking/working surface related to the proposed AT&T antennas that exceed the FCC’s occupational or general public exposure limits at this site.” In addition, the steel structure was designed in such a way to deter climbing.
EMF can be controversial and has been cited as justification to deny applications to construct cell towers around the country. There is no shortage of opinions on the safety of such facilities and their fitness for locations in or around parks or schools often comes into question. WRCA’s board researched the matter and determined that a credible neutral third party on the subject is the American Cancer Society which published a statement on its Web site that concludes, for a number of reasons, that such concerns are not warranted, and the EMF report that was produced at the behest of AT&T for this particular facility supports that conclusion. In the absence of credible peer-reviewed scientific evidence to the contrary, WRCA’s board saw no credible or compelling reason to oppose the proposal for safety reasons related to EMF.
Revenue from Lease Payments
Early in discussions with the councilmember’s office and AT&T, WRCA leadership expressed that community support would likely not occur unless revenue from the lease is directed back into this community for the life of the contract and our neighborhood association had oversight in the use of those funds. It was discovered that the only way that can occur with certainty for the life of the lease is to have a Capital Improvement Project (CIP) approved by council at roughly the same time as the council votes on the project. From the beginning, Councilmember Ashby has pledged to support the community’s wishes and that includes ensuring the funds are handled as described. While that support is not a guarantee that the majority of the council would vote similarly, councilmembers have a history of voting in solidarity with the councilmember of the district where the project is located.
How the funds would be used has not been determined. The board has purposefully not pursued any specific investment plans or ideas for use of the funds at this point in the belief that would be premature. When and if the time comes to explore those decisions, a steering committee will be created and community members will be invited to participate in that process. Some ideas for exploration might include: completing development of Witter Ranch Park and other parks within our neighborhood association boundaries that may lack amenities promised by the city, planting trees along the Natomas Crossing Drive right-of-way, traffic calming measures and control features, beautification projects, and/or if at all possible, private security patrols. Anyone interested in participating in the steering committee if the project moves forward is encouraged to contact WRCA’s board.
According to our city’s ordinance regulating telecommunications facilities located on city-owned property and its published fee schedule, the annual rental rate for a “macrocell” is $21,000 per year, indexed annually for inflation, plus additional one-time fees that apply when certain impacts or benefits are involved.
WRCA’s Community Outreach Effort
Subscribers to WRCA’s Yahoo Group and attendees at all of WRCA’s general meetings since May 2011 have been updated on the status of the proposal at a high level, including the fact that WRCA leadership continued to work with AT&T on design considerations. The applicant’s presentation was added to WRCA’s general meeting agenda for March 26, 2012, which was published on WRCA’s Web site on February 29, 2012. In addition, the meeting was heavily promoted via the Yahoo Group and an extra effort was made to deliver notices to front doors of homes in the area surrounding the park (highlighted section at left). In the case of Atrium Court Apartments, whose eastern buildings have some units that have line of sight to the park, more than two dozen notices were delivered to the property management office and staff was encouraged to post or otherwise distribute the notices in whatever way suited them. Anticipating a record crowd, WRCA and AT&T worked with the councilmember’s office to book the multipurpose room at Witter Ranch Elementary school for the meeting.
At our general meeting on January 30, 2012, it was suggested that we give community members an opportunity to provide questions that the AT&T representative can be prepared to answer at the meeting, so we published a Questions and Answers page on our Web site and encouraged community members to pose additional questions. Only one question was submitted via that process pertaining to why a location closer to the freeway is not being pursued.
Community’s Attendance and Reaction
In spite of all of the promotion effort, fewer than two dozen community members attended the meeting, including all five WRCA board members. The hour-long presentation, the contents of which are linked above, covered AT&T’s justification and purpose for expanding their infrastructure in Natomas, why the site of Witter Ranch Park became their first and arguably only practical choice, how they worked for the past year with WRCA leadership in improving the design of the proposed facility, an electromagnetic frequency (EMF) report that demonstrates energy levels at ground level throughout the area surrounding the park are well below federal guidelines, and how the proceeds from lease payments for the facility would be allocated within the construct of a CIP to ensure Witter Ranch Community long-term benefit. A question and answer session lasting about 20 minutes covered virtually every aspect of the proposal.
Following the presentation, those still in attendance completed survey forms developed by WRCA leadership that solicited their opinions on the proposal. The results of that survey were compiled and analyzed.
Forming WRCA Leadership’s Position
WRCA’s board met the week of April 1, 2012 to review the survey results and discuss how to address this proposal. Based on WRCA bylaws, practices, and input from community members, WRCA’s board determined that this project should be further considered before WRCA assumes a position for or against the proposed project. To this end, WRCA’s board will work with interested community members to convene a special working group that will better characterize our community’s predominant opinion about the proposed project and to suggest whether WRCA should offer its support or opposition. In the spirit of WRCA’s bylaws and our community ethos, this working group will continue to support a timely, objective process that best represents the interests of our neighborhoods. Objectives for the working group are to include:
- Further publicizing the project within WRCA boundaries and particularly the area near Witter Ranch Park;
- Determining which objective criteria must be met for WRCA to take a position for or against this proposed project;
- After measuring those criteria in our community, drafting a letter for WRCA’s board that consolidates community input and the predominant neighbor sentiments toward this project; and
- At the May 26, 2012 WRCA general meeting, initiating a motion to facilitate a vote for WRCA to issue a letter supporting or opposing this proposed project.
WRCA’s board has gone to great lengths over the last year to engage with our neighbors, AT&T, and Councilmember Ashby regarding this potential project. If the working group findings suggest community support for the potential project, WRCA’s board recommends including the following provisions, at a minimum, in any conditional letter of support:
- Binding financial agreement in place that assures all funding for the life of the lease and any renewals are to be appropriated to projects within Witter Ranch Community Alliance boundaries with WRCA leadership oversight
- Properly designed, maintained, and operated irrigation system to support rapid growth of ivy vegetation (or similar vine) in the planter along the perimeter of the restroom building and equipment enclosure
- Properly maintained, manicured, and trained ivy vegetation in the planter area as described above
- Bottom two sections of water tank diagonal cross members equipped with antipersonnel spikes to discourage or prevent climbing the tower (the current design specifies only one section of antipersonnel spikes)
- All public facing materials to be covered and maintained with special paint or coating material that allows for easy removal of graffiti
- Process developed for requesting AT&T’s attention to vandalism or other concerns about the facility after it is built, including a small sign posted on the door to the equipment enclosure that contains a telephone number and an email address to direct citizen complaints
- AT&T to be accountable to a seven calendar day turnaround time to abate graffiti and vandalism with $200 in additional rent to be assessed for each day beyond seven such issues are not resolved, enforceable by City of Sacramento’s Code Enforcement Division
- 24-hour centrally monitored silent alarm system with video surveillance and two-way audio communication of the site to deter unauthorized penetration of the equipment enclosure
- Design features to deter trespass within the AT&T equipment enclosure (e.g., concertina wire on inside edge of enclosure wall, not visible from outside)
- No part of the facility or the utilities required to support it to interfere with the Witter Ranch Park Master Plan that includes tennis courts east of the restroom structure, which may require that subterranean conduits for power and telecommunications cables from Saintsbury Drive be routed a longer distance
- AT&T to establish process whereby unforeseen circumstances can be adaptively addressed with community input and identify the best possible outcome
If AT&T moves forward with filing its official application for a permit, the project will be the subject of several public hearings —the Planning Commission, the Parks and Recreation Commission, and of course, the Sacramento City Council. Typically, residents within a 500 foot radius of a proposal such as this will receive Planning Commission notification alerting them to the date, time, location, and subject matter so that they can express their support or lack of support for the proposed project. It is expected that residents who receive such notification from the city will have been notified as a result of WRCA’s outreach efforts described above.
It is estimated that it may be up to a year or more before the project would be completed if it moves forward.