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HomeMy WebLinkAboutTC Agd Pkt 1995-06-07 5. GANN ACT APPROPRIATION LIMIT FY95-96 (Adopt Resolution) 6. 1972 OPEN SPACE GENERAL OBLIGATION BONDS, TAX RATE FY95- 96 (Adopt Resolution) 4. TOWN'S MONTHLY INVESTMENT SUMMARY (As of April 30, 1995) 3. APPROVAL OF MINUTES #1051, May 17, 1995; #1052, May 23, 1995; #1053, May 23, 1995 (Joint Meeting) 71lc purpose of the Consent Calendar is to group items together which generally do not require discussion and which will probably be approved by aile motion unless separate action is required on a parlicu/ar item. Any member of the Town COllncil, Town Staff, or the Public may request removal of an item for discussion. D. CONSENT CALENDAR 2. LAFCO HEARING - OLD LANDING ROAD REORGANIZATION (Councilmember Thayer) 1. MARIN COUNTY HAZARDOUS & SOLID WASTE lPA MEETING (Councilmember Nygren) C. COUNCIL. COMMISSION OR COMMIITEE REPORTS Please confine your comments during this portion of the agenda to matters not already on this agenda, other than items on the Consent Calendar. T7le public will be given an opportunity to speak on each agenda item at the time it is called. Presentations OfC limited to three (3) minutes. Matters requin'ng action will be ref CITed to the appropn"ate CommissioJJ, Board, Committee or Staff for consideration and/or placed on a future Council meeting agenda. B. PUBLIC QUESTIONS AND COMMENTS A. ROLL CALL =============================================== In compliance with the Americans with Disabilities Act, if you need special assistance to participate in this meeting, please contact Town Hall (415) 435-7373. Notification 48 hours prior to the meeting will enable the Town to make reasonable arrangements to ensure accessibility to this meeting [28 CFR 35,102-35.104 ADA Titie IIJ (1) AJways Address the Chair; (2) State Name and Address; (3) State Views Succinctly; (4) Umit Presentations to 3 minutes; (5) Speak Directly into Microphone. PLEASE NOTE: In order to give all interested persons an opportunity to be heard, and to ensure the presentation of all points of view, members of the audience should; ============================================== MEETING DATE: JUNE 7, 1995 MEETING TIME: 7:30 P.M. CLOSED SESSION: NONE 1 TOWN 0F TIBURON 1101 mWRON BLVD. REGULAR MEETING ;f;!4sn^. TIBURON TOWN COUNCIL AGENDA " r TO: June 12, 1995, 7:30 p.m., Council Chambers for Budget Hearing and Election Certification L. ADJOURNMENT 17. TIBURON SANITARY DISTRICT NO.5 - PARADISE DRIVE SEWER IMPROVEMENT DISTRICT K. STAFF AND TOWN MANAGER REPORTS 16. LEITER TO TOWN COUNCIL FROM LAFCO DATED 5-17-95 (Sphere of Influence Update) 15. APPLICATION FOR EIGHTH ANNUAL CHILI FESTIVAL (September 9, 1995) J. COMMUNICATIONS 14. DOWNTOWN MAIN STREET ADA REQUIREMENTS (Discussion of Options being Considered by Private Property Owners) 13. TREE ORDINANCE (Review & Discussion of Town's Tree Ordinance Provisions) I. NEW BUSINESS 12. DOWNTOWN FERRY DOCK REALIGNMENT (Report on Meeting with Engineer and Red & White Fleet/Accept Easement - Resolution) 11. GREEN CAN PROGRAM (Approve Proposed Trial Program by Mill Valley Refuse Service) H. UNFINISHED BUSINESS 10. LEAF BLOWER ORDINANCE (Introduction and First Reading) 9. APPEAL OF PLANNING COMMISSION DECISION RE: HAM RADIO ANTENNA at 223 Diviso Street (APPELLANTS: Misuraca/Brieant) 8. APPEAL OF DESIGN REVIEW BOARD DECISION RE: 690 Hilary Drive Proposed Addition (APPLICANTS: Krabbenschmidt/O'Dell- APPELLANTS: McDonnell) G. PUBLIC HEARING 7. POINT TIBURON COMMUNITY FACILITIES DISTRICT, TAX LEVY. FY95-96 (Adopt Resolution) 1994's ABA939 compliance disposal diversion repclct!_; ",'! " lCC':,S' nC"d. Tiburon's rate has improv(~d frr':')nl 23.9'?6 to 29.300. --;-'he d\',-:'~:',F]I' l'dt,:; for the county was 34.100_ The unincorpc)rated arf-:::.as die ot a -1.-1:"0 rate and Belvedere is at 19.t~'\. Thus, Tiburon ha:.; -rp,-H_'}j,;:(i it l'J05 requirement. 1';e nOh need to achieve 500u by 200']. \~:'h' rlll_';'_~~-"~lre::-:; such as diversion of ::'ard hd~-)t:t~:3 a.ppears to be t:h.~' :::L~'J _;('~-;t 1\ t., reach this 50~ requirement. See attached. Only a portion of our 1995-96 budget I'as adopted. Ihe3cc>d:: ,hat would expand into new programs I,as temporarily placed ",n [,,,,d. RAc1h'ooc1 Land Fill informed the ...TP.\ board that ,-1u,~. r,:, (;Ildn~;t':-;: I n }Ij~' refuse program they hould need to subs tan t i d 11 \ l:"_TbL:" tile i L operating expenses hhich ~ould reflect on our 1(:';:31 0Jrt'~00 rates and tipping fees. This is to be reviehed j_)~ t~',> I-!i;i~'j ~tJ.(lilS Committ(~e and brought back to the ,JP,\ at its next me"timj. Our town has asked to hri te let ters in "llpport and oppClsi t 1, 'n uf solid waste legislation. See attached. \,e moved forward on the draft "siting element" reqllir,'c1 fhe state. to support the Bay ."rea Supermarket "Bu\' A one month education progt-am v.-i 1] Li~ and Lucky to encourage shoppers to be more "buy recycled" or "minimum ~dckagi!lg" The JPA gave approval Recycling" program. implemented at Safehay consciences of their purchases. evaluate its Ohn recycling pr()'.jram ,mr] that sets an example for other bllsinesses. to the town giving guidelines. The tOlm is asked to implement it in a manner A packet will be mailed RE: REPORT MARI~ COC\TY HAZARDOUS & SOI.ID WASTE JPA MEETT\G OF MAY 22, 1995 MAY 23, 1995 FROM: KAREN NYGREK TIBURON TOWN COUNCILMEMBER Ikk j}~. / MARIN COUNTY AB939 TASK FORCE May 22, 1995 - AGENDA ITEM 7 AGENDA ITEM 7: Legislative Report STAFF REPORT & . RECOMMENDATIONS: At the request of Task Force member Gloria Duncan and Carol D' Alessio of the Marin Conservation League, staff analyzed four pending state bills which could impact our solid waste planning and diversion efforts. The following presents a brief analysis of the legislation, the bills' status as of May 11, and staft's recommendation for Task Force action. Since several of these bills are moving from committees or from Senate to Assembly. a current update will be available at the Task Force meeting. . 1. AS 696 (Harvev) AS 939 Diversion Goals AS 6996 would permit the CIWMS to exempt low population density counties from AS 939 goals of 25% waste reduction by 1995 and 50% by the year 2000. This is a two- year bill and will not be taken up during the current legislative session. Staff Recommendation: Take no immediate action, since this is now a two year bill, but follow during next legislative session. 2. AS 1773 IOlbero) Severaoe Containers AS 1773 would eliminate the processing fee paid by the beverage manufacturers and delete the Glass Processing Fee Account which funds are used for a market development program. This bill relieves the beverage manufacturer from helping to pay a portion of the recycling costs for the containers they manufacture. Essentially, this bill eliminates the "bottle bill" and redemptions. Opposition: Environmental groups Convenience Zone operators Recyclers Waste haulers Support: Glass Manufacturers Status: AS 1773 is awaiting a rule waiver so that it can be heard in committee. Negotiations are also ongoing to arrive at a compromise between this bill and AS 995 (see below). Staff Recommendation: Send letter of opposition to Assemblymember Olberg and to committee chair and to Assemblymember Mazzoni's office, check with CSAC and League of Cities and continue to follow closely. Page 1 of 2 Page 2 of 2 c:\winword\jpa\tfleg95.doc Staff Recommendation: Send letter of opposition to appropriate committee in the Assembly and Assemblymember Mazzoni's office. Continue to follow closely. The bill passed the Senate Business & Professions Committee by a 6.3 vote. It is now in its third reading in the Senate. May 9, '995 was the filing date for action. It is expected to pass the Senate any day and will be sent to the Assembly and assigned to the appropriate committee. Status: American Forest and Paper Association California League of Food Processors Simpson Paper Company Mead Corporation Weyerhaeuser Company Jefferson Smurfit Corporation & Container Company Kraft Foods, Inc. California Grocers Association California Chamber of Commerce American Electronics Association Grocery Manufacturers of America Support: Californians Against Waste (CAW) Opposition: California law requires that a product or package must have a minimum '0% post- consumer recycled content. SB 426 would remove this requirement and allow products that contain 0% post-consumer recycled content to be labeled as "recycled." SB 426 repeals existing state standards of minimum product and packaging requirements for the use of the terms "recycled", "biodegradable" and .ozone friendly" in advertising. This bill makes the use of the above terms subject to the Guides for Use of Environmental Marketing Claims published by the Federal Trade Commission. The federal guidelines weaken existing requirements inasmuch as the federal standards are guidelines only and not enforceable. State standards provide a more clear definition of these terms and a violation of these standards is a misdemeanor, punishable by law. 3. SB 426 ILesne) Environmental Advertisina StBff Recommendation: Send letter of support to Assemblymember Sher's office, contact Assemblymember Mazzoni's office and follow closely over the next month. AB 995 is the opposing legislation to AB' 773. It is currently being held up from assignment to the Natural Resources Committee to see if a compromise can be worked out with AB '773. Status: AB 995 would extend to January' 998, those provisions in the California Beverage Container Recycling and Litter Reduction Act pertaining to processing fees paid by beverage manufacturers and handling fees paid to supermarket sites for the redemption of empty beverage containers. The provisions currently in the law expire January', '996. 3. AB 995 (SherI Beveraae Containers ffJ '" o '" H > I W <9 ([ Z ([ :E W f- ffJ ([ :3: Z H '" $I ~ o .-< ['1 .-< Lf) 0'> ['1 r'J >- cr :E ill "- ill (L . AS 939 COMPLIANCE 1993.1994 COMPARISON JURISDICTION Diversion Rate % Waste Generated Tonnage Waste Dfvltfted Tonnage Waste Ois sed Tannage 1993 1994 Change 1993 19904 Change 1993 1_ Change 1993 1994 Change 1 8elvedl!l'@ 27.1% 19.6% -7.5% 2.881 3.21. 335 763 1007 2" 2.117 2209 0: Corte Made", 21.3'Il1o 25.1% :>."4 12134 "645 .... 3022 2607 .2" 9112 .838 -27,' Fairfax ,.."" 30.2% 1'.2'lli 9.3<3 7,723 -1620 2,7llO 2180 ./lOO .... 5.542 -,02: Lark~pur 27,'" A2,'" 15,,", 14974 12927 -2047 3,185 3$7' 3B6 """ '356 -24:> 5 MIf~Ylllle 34,9"4 4'.6% 6.7% 20,944 19243 -1701 6,113 0722 -39' 14,830 13,522 -,'" Novato 26.13% 25.6% -1.2% .8,374 "'''7 2m 7,093 a,429 '336 41280 "'<.. 1f8> Ross 38.7% 46.6%- 79% . 4674 4,351 -323 1,657 1,837 ". 3,018 251. _S<> ~selmo 24.4'lfl 24.4% . O.Of{, 15,341 15.331 -'0 4,334 4,146 ".. If 007 'J...'85 I7f San Rafael 27.5% 31.6% 4,1% a'99< 86 437 ..'" 22 2re "'738 7533 S9789 56,698 -3091 Sausalito 23.1'1. 29.8'" 6.7% 13,150 11,856 -1m 3,236 3J192 .'4. 9915 aT"" -1151 Tiburon 239<J. "'.... 5."% 12,0442 11680 -762 3.391 3,= -52 905' 8,341 .71C Uninc~~orated 43,,," 44.5~ 1..3'" 54,2t16 54,048 .218 13163 ..". 117:.> 4t,103 Ml,710 ,139:1 Tot.:J1 County 30.7% 34.1" 3.4% m.519 189,.354 -1165 70943 ",206 92S3 219576 209147 -104Z: 2 , . . 7 8 9 ,. 11 12 f3 t9904OR,WBl AB 539 WASTE DISPOSAL AND OIVERSION MONITORING FOR 1995 GOAL JURISOlcnON Tlburon REPORTING PERIOD Jln.19N ..Oec.1M.. FRANCHJSE. HAULER Mil VaUey Refuse Servic.e, Inc. REPORT DATE 5120195 OTHER HAULER(S) G....ge LANOFIL.US) USED R_ Marin Sanitary StNice Weft Contra Com R!c:hmcnd RECOVERY FACIUTY MRRRC 1atC1r 2nd Qtr 3rd Qu 4tt\Qtr TOTAL MRA:RC FACIUTY RECOVERY RATE 65.8% 62.3% 52.1% 51.0% A. 1994 TOTAL TONS OIVERTED "S US 141 "9 3,339 RECYCLED 43' 449 444 440 1,7ee WOOONARO WASTE COMFOSTED(1) '37 .. 19' '21 m INERTS DIVERTEO 217 28. 302 228 1,036 B, 1994 TOTAL TONS DISPOSED 2,040 2,127 2,168 ~,O(l9 8,341 RE~ULAR MSW OfSPOSEQ 1.349 1.415 ',370 ',407 5,541 DEBRIS BOX & RE.SIOUALS DISPOS~D 216 236 351 259 1,112 WOOOIVARD WAS:'E INCINERATED 247 '54 111 80 592 SEL.F~HAUl OISPOSEE:(2l 228 272 334 263 1.097 C.1994 TOTAL. WASTe GENERATED 2,825 2,951 3.1011 2.798 11,S80 D. COMPLIANCE wrTH AS 939 199$ 25% DJVERSION MANDATE (Based on 1994 Oatal Total Waste Gen~ted in 1990 Base Year (Wl1h lICljuS1ment!}(3) 11,803 MB;mum allcwlIble Cisp08a1 in 1 '95 1759/. ot tQUlI adjusted 1 SSO oase year) a.aS2 1994 ActualOiSJ)osal 8.;141 Ad=l.tionill Diversion Needed to Meet 259;' Goal (511) Percent r:Ii\lerted as Percenlage 011900 AdjUSled Bue Year 29.30;, E. TOTAL OF ALL. DIVERSION ACnVITJ~S INCLUDING INCINERATION tWooC!yatd W~te inc:f1erated dee. ncl counllowardt meellng Ihe t 995 ci'Je/Slon mandate) Cu:bside & Buy-back. Rec'IctnQ 378 411 40' 408 1,537 CUfb:iide GrHll Waste Composling & InCineration 323 154 '90 '0 747 Public Self.Haul Processed af MRRRC 182 242 240 169 B53 Ffancl1ise &. CommerCIal Haul&r(s) Processed at MRRRC 150 172 221 192 73~ TOTAL DNERS10N 1,O.n 979 1,052 9" 3,g32 NOTES 1 Sued on 100.0919 of lotal wood tines and ~rdw~e COmllO$ted as reported MRRRC and haul.,.. :2 Seit-na:Jlallccadcn fotml:la basec:l on a two month venicle C(llJnl iJIIerege 811 repor:ed by MRRRC IInd Fledwood Landfill: inc:udes seJ.haul residl.ial Wi$te processed from MRRRC. 3 Adj"'stment factors for the 1990 b~se year ;Ilcl\,ldlt changes in pO(:l\,llallon, laxat:le tra:1eec-Jans. emp~Oym8nl. and llmrtaDons 01 tnlillts rKyded t:J an amount no ~reale( In.n t'Ht amo\ln1 of Inj!,ttS dlsp:losed. P,2/6 MAY 23 '95 13:07 MARIN WASTE MANAGE!_VIRORS " MAY 23 '95 13:08 MARIN WASTE MANAGE!_VIRORS P.3/6 MATERIAL TYPES DiveRTED FROM LANDFILL DISPOSAL FROM RECYCLING AND COMPOSTING (4) WASTE TYPE DATE 1stOuarter 2nd Quarter 3td Quart8f 4th Quarter TOTALS PAPER CORRUGATED PAPER 53.05 81.74 66.76 65.60 247.95 COMPUTER PAPER MlXEO PAPER NEWSPAPER 233.44 237,54 231.65 231.04 933.67 HIGH GRACE LEDGER SUBTOTAL PAPER 287.29 299.28 298.41 296.64 1,181.62 PLASTICS HDPE PLASTIC PET PLASTIC OTHERPLASTlCS~OT~P~~ 1.03 1.15 1.27 1.20 4.65 SUBTOT~ PLASTIC 1.03 1.15 1.27 1.20 4.65 GLASS GLASS 104.19 112.51 107.80 110.08 434.59 SUBTOTAL GLASS 104,19 112.51 107.50 110.08 434,59 METALS ALUMINUM 5.79 5.76 5.69 5.42 22.66 FERROUS AND TIN 25.05 21.76 22.95 18,51 88,27. NON.FERROUS WHITE GOODS OTHER METALS ~OTAL METALS) 8.10 8.72 8.~5 8.55 33.72 SUBTOTAL METALS 3U5 36.24 36.99 32.48 144.55 YARD WASTE YARD WASTE 75.76 0.00 79.48 0.00 155.24 SUBTOTAL YARD WASTe 75,76 0.00 79.48 0.00 155,24 ORGANICS FOOD WASTE TlRESiRUBBER WOOD WASTE 61,52 86,27 114.28 120,65 382,71 TEXTILES SUBiOTAL ORGANICS 61.52 86.27 114.28 120.66 382.71 SPECIAL WASTE INERTS 216,60 289,12 302.42 227,56 1,035,80 BULKY WASTE MO 0,00 0.00 0.00 SLUOOE SUSTor AL SPECIAL WASTE 216.60 289,12 302.42 227.56 1.035,80 OTHER WASTES 0,00 0,00 0,00 O,QO 0,00 OTHER WASTE TOTAL I 785 825 941 789 3,339 NOTES: 4 Yard/'Wacd W8$te tt'lat IS incine/aled oS not conSidered .:Nerted for pUrpCQ8' cr lTi~'lng the 1;S5 25"'" di'J8rsicn mandale anl1 is nOllnclud.id as par1 gf lne matenals cl\ler:ed from lancllll dis':los2.1. Tibl.1ron en 'l) -L. IlW.BECI 1r'.DMPt,XlWHilu.... 2'J.3~~1 [1'J'J4WASI'~ IJ1VH{SION RATE ..,,, ACTU"'LHl94D1~5"'L '''' "" ''''' '000 1%1,100 n~,IOO -." U19.li56 '''' ,,~ UIJ!! "'" .,., ,'- "HI (l'l{+clllll ,;, (~I':.T~I/l S ADJUSThlENTFAC'TORS RAF. N.ndonl'.' Ad......- """lor CIAF-{...,............-'" lod.....,nol^'~~.........tF..;o, "" lw(WMTE~t.RATE 4- ,^,,'-lI>'>4{)..f")MJ-.~U~".bl..r>.~) M<l,tognoolU-....<>"Nr...J..4~Mftlc-.l t ADJUSTMENTR.",nOS 09!N/199O) ......1.~D"~o Emplo'Jn..."'Roouo T__T____~ 1.&52 (C7:;...tl&l.cy~...G'",nl><><~ l'M....o.xJMlJ"forSI"OS"ll"d.j~""'''1 n,$(l'J (RWG 'UWC) TOTAL BASE YEARCENER'\TION (."<Ii...Ied) r..,.....""" C'''"nlywll~u."f''l.;y_n' T..."'.okTI"'-~ 5,~\!> (\~y_awr. ~ C!A~1 '-TUI'~...I}Jndwl>HJw.....C._.lu;>n("'(lj.>>lO-ll ",lis;.' 11l....Y....lI.w(,;:O. Ki\tJ B"". v.... R...J~lMl Wao...c......41.__'^dj.o.1cd1 J ADJUSTh1ENTINDICATORS ~ TI AJ H :z E ]) U1 ~ r1 TI :z ]) G1 r1 , < H AJ o AJ U-, , COMrllANcERESULTS 2 1990 YEAR WASTE GENERATION AOJUSTBDTO JNCLUDE INERTS ItR>IDFNI'lAt CII TOTAL tU'; SU" fL.\SlO"'EARW~GENERATION 5,0.58 6,110 11.868 RIIl$i<l9t\1ial AdjUllltllUlnt filC10f IRA-FI '" 09'J4 Pooublion!l99Q Po_lIlian) + CI AF 2 CommerciaUlflol,lSuial Adjuslcnenl: Facto.- IClAA... fllJ94 RmblollMl!ntll990 ErrIfIlaymenll'" n9!H T.".bl_ Tranouctionsl1990Tu.bll! Tr~,",M"ll""') 2 1994 Allowable Disposal = 0.75 X (Base Year RWG)(1994 RAF) + (Base Year CIWG)(1994 CIAF)] IS uJ 1 CAlifORNIA INTEGRA TED WASTE M4NAGEMENT SOARO ~SPOS"L BASED COMPLIANCE FORMULA ~ LL TIBURON u: (f .' :3 :r: -( " '" . 1994\OR.WA1 3: D ~.--< I\) W . , Ul ()] Tiburon ..... w OS) \D 3: D ;U H :z E D u) -< f'1 A 1993 1994 CHANGE TOTAL TONS DIVERTED 3391 3339 -52 Recvcled 1796 1766 -3D WoodlYard Waste Comeosled 165 536 353 Inerts Diverted 1410 1036 -374 ~ D :z D u, f'1 I < H ;u o ;U [J) B TOTAL TONS DISPOSED 9051 6341 -710 Regular MSW Disposed 5509 5541 32 Debis Box & Residuals DisDosed 1177 1112 -65 WoodlYard Wasle Incinerated 1295 592 -703 Self-Haul Disposed 1070 1097 27 C TOTAL WASTE GENERATED -7621 124421 116801 " ~ '" 1 5/17/95 TOWN COUNCIL MINUTES #1051 4. Wayne Snow, Chairman of the Parks and Open Space Commission, recommended approval of the Barbara Meislin Swing Bench, and reported that the Commission had discussed the placement of Blackie's statue and proposed Marsh Restoration Plan. Councilmember Nygren had some questions about the alternatives E. COUNCIL. COMMISSION OR COMMITIEE ORAL REPORTS None. D. PUBLIC OUESTIONS AND COMMENTS 2. Council approved RUSD designee Richard Rosen as the at-large delegate to the New Library Board of Trustees. C. APPOINTMENTS TO COMMISSIONS. BOARDS. COMMITIEES 1.a) Public Works Superintendent lacopi introduced new Maintenance Worker I Jennifer Kielar, saying she had scored the highest on both written and oral tests of all 21 applicants for the position. b) Planning Director Anderson introduced new building inspector Bill Talley, formerly with the Town of Corte Madera. B. INTRODUCTION OF NEW TOWN EMPLOYEES Town Manager Kleinert, Town Attorney Ewing, Police Chief Herley, Finance Director Stranzl, Planning Director Anderson, Town Engineer Mohammadi, Public Works Superintendent Iacopi, Town Clerk Crane EX OFFICIO: ABSENT: COUNCILMEMBERS: None PRESENT: COUNCILMEMBERS: Ginalski, Nygren, Thayer, Thompson, Wolf A. ROLL~ALL Mayor Thompson called the regular meeting of the Town Council of the Town of Tiburon to order at 7:35 p.m., Wednesday, May 17, 1995 in Council Chambers, 1101 Tiburon Blvd., Tiburon, California. CALL TO ORDER DRAFT IleAL #0. 3 TOWN COUNCIL MINUTES listed in the Williams & Associates letter to the Audubon Society (re the Marsh). Chairman Snow said the report had not yet had a public hearing, so he was unable to comment on the direction the Commission might take. Councilmember Thayer asked for clarification on the placement of Blackie's statue. On a separate issue, Council member Thayer reported to the Council that the Board of Supervisors had approved the largest ever grant of Community Development money ($82,435) to the Hilarita. He noted that it was an indication of the County's support for that project in the face of potential loss of federal funds. F. CONSENT CALENDAR 5. RESOLUTION DENYING APPEAL/GRANTING VARIANCE (Bronte) 6. VISTA TIBURON SUBDIVISION (Final Map/Resolution) 7. MINUTES #1050, May 3, 1995 (Page 6, Item 9 Amended per Councilmember Wolf) Councilmember Thayer moved for approval of Items 5, 6 & 7 (above), seconded by Councilmember Wolf. All ayes were recorded, except for Councilmember Nygren, who abstained from voting on Item 6 due to proximity conflict. Town Manager Kleinert asked for an item to be added the Consent Calendar regarding the Belveron Gardens pump station and sewer rehabilitation project. Council asked for time to review the project, previously agreed to in concept, at a future meeting. Item was set for hearing on May 23, at 7:15 p.m. Council requested that residents adjacent to project be notified of the meeting. Item 8 (Major Crimes Task Force) was moved off the Consent Calendar. 3. a) Council returned to Committee Reports. Janet Braff, Chair of the Heritage and Arts Commission, gave a report on the newly completed Walking Tour Brochure. Michael Heckmann, architect and contributor of artwork to the brochure, also gave a brief report. Copies of the brochure were made available to those present, and will be available at various locations in Town. Red & White Fleet bought 25,000 of the 50,000 copies printed. Councilmember Nygren and Mayor Thompson thanked the Commission for their efforts, and Town Manager Kleinert thanked the Commission on behalf of the Chamber and the business community. G. PUBLIC HEARING 9. GREEN CAN PROGRAM. Town Manager Kleinert gave the staff report prior to the second public hearing on the proposed yard waste removal ("Green can") program. He reiterated some of the concerns expressed by the public at the April 19 hearing and gave staffs responses. He stated that other Marin County communities had TOWN COUNCIL MINUTES #1051 5/17/95 2 3 5/17/95 TOWN COUNCIL MINUTES #1051 Rick Powell responded to the comments and stated the company's concern about potential workers' compensation claims if bags had to be lifted manually by the sanitation workers. Joy Easom, 1828 Lagoon View Drive, expressed concern about getting the can up their steep driveway, and asked where to put it since they have no sidewalk. She, too, would prefer bags. Fran Mayberry, 1494 Vistazo West, expressed concerns on behalf of her neighbors as to shortage of storage space and unsightliness of the Green Can. She stated they would be more cooperative if they could use bags instead of cans. Ellen Hall, 8 Southridge West, was concerned about being able to fill the Green Cans on a biweekly basis. Frank Allsinger, 525 Comstock Drive, stated that he liked the quarterly yard waste pick-ups and wanted to keep them. He questioned why MVRS (or any sanitation company) needed to raise rates and asked why they couldn't just slash the garbage bags to see if the trash was yard waste or not. Mayor Thompson opened the public hearing. There would be no upfront cost to residents in the pilot program, but Powell estimated the cost of doing a pilot program at $15,000. At the end of the pilot program, MVRS will send out a questionnaire asking for comments about the program. If the program is canceled, the cost would have to be taken into account somehow. Mr. Powell also offered two new features to the proposed Green Can service: 1) a 20 gallon mini-can (which could be used in conjunction with the Green Can for a lower the garbage rate of $11.86 per month); 2) MVRS will pick up one tied bundle of yard waste, maximum 5' long and 1-1/2' in diameter, biweekly. (The latter was in response to concerns expressed at the April 19 hearing about having to further cut and break down large branches, etc.) He also stated that MVRS currently has "hardship" service for people who cannot bring their cans to the curb, and the company would offer the same service as part of the Green Can program upon demonstrable need. . Rick Powell, General Manager of Mill Valley Refuse Service (MVRS) stated that Marin Resource Recovery in San Rafael now composts all clean yard waste, as well as wood waste. He estimated that wood waste probably represents 80% of total yard waste. introduced similar programs and were happy with them, and that the community had an obligation to support such a program in order to raise the Town's 1994 30% diversion rate to the 50% mandate by the year 2000. He said that if the program was instituted on an optional basis it would drive up the overall cost. Mirella Abbo, 90 Raleigh Circle, wanted the Del Mar area to be included in the pilot program. She said that even though the neighborhood currently recycles and takes trash to the landfill, she has heard mostly negative feedback about the Green Can program. Eric Schmidt, Silverado Drive, said that composting was the answer to the yard waste problem and that he didn't want to pay for a program he wouldn't use. Hearing returned to Council. Councilmember Ginalski asked about printing bags with the word "Green." Councilmember Wolf stated that the Green Can program was premature and should be instituted as a last resort after a) increased recycling, especially in the business district, b) education to discourage residents from taking clean yard waste landfill, c) the bags versus can option was explored, and d) composting was promoted. She thought the program should be voluntary at first and, if necessary, changed to involuntary if the percentages didn't rise. Rick Powell said that he had worked with Town Manager Kleinert to increase commercial recycling in Town with some success in that area, but that the 30% current rate would remain flat unless something like the Green Can program was instituted. Council thanked Mr. Powell and MVRS for the Green Can proposal and their willingness to work with the Town. Town Manager Kleinert proposed returning to Council with specific details and list of neighborhoods for the pilot program. H. UNFINISHED BUSINESS 11. CAYFORD PEDESTRIAN/DRAINAGE EASEMENT. Town Engineer Mohammadi gave the staff report on the history and current status of the proposed project. A culvert had been installed on what turned out to be a legal lot, not a street, as shown on the County Assessor's map. The new owner of the lot, Mr. Weiss, has asked the Town to relocate the pipe in exchange for a waiver of building permit fees and an easement on the property. Mayor Thompson opened the public hearing. Bruce Hall, 8 Southridge West, asked whether a residence could be built on the lot. Ann Ross, 16 Reed Ranch Road, wanted to know whether it was two lots or one, and why the purchaser didn't know about the drainage issue. (Town Attorney Ewing said Mr. Weiss had approached the Town about removal of the pipe while the property was in escrow.) Other neighbors expressed concerns about the Town installing lights on the proposed pathway, whether the pathway had to be paved or not, the current use of the TOWN COUNCIL MINUTES #1051 5/17/95 4 5 5/17/95 TOWN COUNCIL MINUTES #1051 Council asked for clarification about ADA regulations and the reason for building a new dock in the first place. Councilmember Nygren asked about what would happen if the DRB rejected the plan. (Attorney Ewing said that Town staff would appeal the decision to Council.) Councilmember Ginalski asked whether the two lots owned by the Town where the new dock would be built were encumbered by Open Space restrictions. Finally, Attorney Ewing said that the entire project would go before the Design Review Board this summer, but asked for Council's direction as to the extent and amount of money that should be spent on (further) design and engineering fees. (Council had previously directed to keep fees at a minimum.) He stated the other considerations as: 1) a two-year limit on project implementation tied to the CALTRANS fees; and 2) suggested that Council decide whether or not it wanted to proceed with the project before any more fees were incurred. He stated that, in his opinion, there was nothing in the Point Tiburon Subdivision Lease Agreement that precluded construction of a new dock. He felt that the language pertaining to other construction and obstruction of view applied to the shoreline park (across from Point Tiburon). Attorney Ewing addressed the issues of the size of the proposed new dock, and its location closer to the shore (near Point Tiburon Bayside development). He also informed Council that a lease between the Town and Mr. Zelinsky was being formalized to ensure that the $1200 monthly fee currently paid by Red & White Fleet to Mr. Zelinsky (for the easement on his property to access the dock) would be transferable to a successor company. 12. FERRY DOCK REAUGNMENT. Attorney Ewing gave the staff report, reiterating that $70,000 had been awarded to the Town by CALTRANS in May, 1993 to build a new ferry dock. One of the State's conditions was that the dock be public, not private, and therefore it became subject to ADA (Americans with Disabilities Act) regulations. In order to comply to ADA regulations, a plan for a larger dock was developed. Hearing returned to Council. Council concurred that negotiations should continue between the Town and Mr. Weiss, and directed that the matter be turned over to the Legal Subcommittee (consisting of Councilmember Ginalski and Thayer). Mr. Weiss gave his comments and suggested changing the angle of the path at one end to coincide with an existing sidewalk. Town Engineer Mohammadi said that paving the path made it easier to maintain, and the width was specified to be able to drive trucks on it. lot by dogs and for dumping garbage. (Attorney Ewing said no.) Mayor Thompson asked why the dock had to be so long. (Carolyn Horton, from Red & White, said it was necessary to achieve a 1 in 12 slopefor ramping.) Mayor Thompson opened the public hearing. John Yoeman, 107 Paradise Drive, expressed concerns about diesel fumes, soot, and the location of the proposed dock being too close to the bedrooms (of some) Bayside condominiums. His other concerns were the east/west placement of the dock in open water, possible larger vessels if Red & White is sold, and degradation of property values. Mr. Yoeman stated that the homeowners would like to see more full-scale drawings of the proposed dock and suggested that each Bayside homeowner be notified of meetings and receive information directly, rather than relying on their association. He also suggested that the Town look at the dock constructed by Pacific Marine Yachts in San Francisco that was built to comply with ADA regulations because it seemed like a good design. (Attorney Ewing said the same engineer had designed the proposed new dock for Tiburon.) He also proposed raising the dock to require less angle in ramping. John Schaller, 102 Paradise Drive, stated he thought the new dock would be an imposing structure from Shoreline Park and would obstruct the view corridor for both the public and the homeowners. He urged the Council to reject the new dock unless there was a compelling need to build it. Hearing returned to Council. Councilmember Nygren stated her preference to have the dock totally within the Town's right of way to avoid having an easement and making payments to Main Street Properties. (Attorney Ewing pointed out that to do this would move the dock closer to Point Tiburon.) Council member Thayer said he was not willing to renegotiate the easement payments to Zelinsky. Councilmember Ginalski said he thought that any negotiations would be premature at this point. Mayor Thompson agreed. Attorney Ewing suggested to Council that he meet with the engineers and Red & White Fleet in order to answer some of the questions raised by Council and the public, and to return to Council with that information. Council directed him to proceed. 8. MAJOR CRIMES TASK FORCE (Adopt Revised JPA - Resolution). Town Manager Kleinert and Police Chief Herley recommended adoption of the resolution and execution of the new JPA which follows the recommendations of the Federal Government's audit and the Civil Grand Jury. 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J - ~ ~ ~ ~ ~ ~ ~ ~ "- ~ ~ ~ - ~ TOWN COUNCIL STAFF REPORT TO: TOWN COUNCIL MEETING DATE: 6/7/95 REPORT DATE: 6/2/95 ITEM NO.: 9' FROM: DAN CATRON, ASSOCIATE PLANNER SUBJECT: APPEAL OF PLANNING COMMISSION'S ACTIONS REGARDING CONDITIONAL USE PERMIT APPLICATION TO ERECT ANTENNAS FOR AMATEUR (HAM) RADIO OPERATION AT 223 DIVISO STREET. PROJECT DATA Address: 223 Diviso Street AP No.: 59-131-07 File No.: CUP 19310 General Plan: MH (Med-High density resid.- up to 4.4 du/ac.) Zoning: R-1 Property Size: 5,793 sq. ft. Current Use: Single-Family residential Owner: Malcolm Misuraca and victoria Brieant Date Complete: 10-31-94 Permit Streamlining Act Deadline: 4-30-95 (90 day ext'n granted) BACKGROUND On October 1, 1993, Malcolm Misuraca and Victoria Brieant filed an application for a Conditional Use Permit to erect several antennas for amateur radio communications at 223 Diviso Street. The original application proposed the following: 1) a "Yagi" style beam antenna mounted on a retractable mast; 2) either a 45' high vertical antenna (GAP Voyager DX-IV) erected on the ground, or a wire "dipole" antenna supported in the middle by a 30' mast to create an inverted "V" shape; and 3) a 10' high VHF/UHF antenna attached to an existing railing. On October 26, 1993, the application was deemed incomplete pending the receipt of additional information. In subsequent conversations with Staff the applicant indicated that he might consider dropping the potentially controversial Yagi antenna from the application. Staff supported this idea as a way to reduce the potential visual impacts of the project. The application was held in abeyance as incomplete for approximately 1 year. In the meantime the applicant was operating with a 31' high ground mounted vertical antenna (GAP Challenger DX-VIII) and the 10' high VHF/UHF antenna. These antennas presented a minimal visual impact on the neighborhood. In October, 1994, Staff received a complaint from Noushin Samgiss at 239 Diviso street about interference from the applicant's radio activities. This prompted Staff to contact the applicant and remind him that the Conditional Use Permit application needed to move forward. The applicant indicated that he would like to withdraw the request for the Yagi and move forward with only the 45' high GAP Voyager DX-IV and the 10' high VHF/UHF antennas. On November 9, 1994, the Planning Commission held a duly noticed public hearing to consider the request for the 45' tall GAP Voyager and the smaller VHF/UHF antennas. The Planning commission expressed their desire to see a representation of the 45' tall antenna on the site. The applicant advised the Commission that he had already purchased the proposed antenna and could install it for the Commission to review. The Commission adopted Resolution 94-24 which allowed the applicant to continue to use the existing 31' GAP Challenger antenna and the VHF/UHF antenna on an interim basis, and allowed the installation of the 45' tall GAP Voyager on an experimental basis. Resolution 94-24 was set to expire by its own terms on April 15, 1995. The hearing was continued to January 25, 1995, to allow the applicant to install the proposed antenna for the Commission to view in the field, and to allow the Town to have an independent technical consultant review the applicant's proposal. Shortly after the November 9, 1994, Planning commission meeting, the Town retained Mr. Richard Karlquist to provide a technical analysis of the application for the Town. Mr. Karlquist agreed with the applicant that the existing 31' high GAP Challenger antenna would soon be of limited effectiveness because of an upcoming period of low sunspot activity (lasting several years). The technical consultant confirmed that a different antenna would be needed that could operate on longer wavelengths. Mr. Karlquist found that both the proposed 45' tall GAP Voyager or the 30' high dipole antenna would probably provide for reasonable communications ability on the longer wavelengths. Because of unusually heavy and consistent rains through the winter, the applicant was unable to install the proposed GAP Voyager antenna. The Planning Commission had clearly indicated that it was unwilling to consider the application without an accurate visual representation in the field. On January 19, 1995, the applicant granted a 90-day extension of the Permit Streamlining Act deadline, extending the deadline to April 30, 1995. The project was continued without discussion from the January 25, February 8, and March 22, 1995 Planning Commission meetings to allow the applicant to install the proposed 45' tall antenna. In late March/early April, the applicant installed the 45' tall antenna but took it down almost immediately. The applicant found TlBURON TOWN COUNCIL STAFF REPORT 6/7/95 2 that the visual impacts of the antenna were greater than he had anticipated. The applicant indicated that he would like to withdraw the 45' tall GAP Voyager antenna from the application and proposed instead the 30' high wire "dipole" antenna described in the original application materials (to exist in conjunction with the 31' high GAP Challenger and the 10' high VHF/UHF antennas). Staff again supported this modification in the application as working to reduce the visual impacts of the project. The applicant verified this intention in his letter of April 12, 1995. The applicant was absent from the Planning Commission meeting on the evening of April 12th. Staff explained the latest changes in the application to the Commission. The applicant's proposal was also described in the written Staff Report for the meeting. At the April 12th meeting, the commission expressed its concern over the changes to the application so close to the Permit Streamlining Act deadline. The Commission voted to allow the temporary use permit granted by Resolution 94-24 to expire by its own terms on April 15, 1995. The Commission continued the hearing to April 26, 1995 to allow Staff to review the status of the application and to give the applicant a chance to address the Commission. On April 24, 1995, the applicant filed this appeal of the Planning commission's actions of April 12, 1995. The appeal is attached as Exhibit 1. The applicant complained that the Planning Commission's actions were outside of its jurisdiction as defined by FCC Ruling PRB-1, were unreasonable and arbitrary, and did not reflect any effort to accommodate the requirements of the amateur radio operation. On April 26, 1995, the Planning commission took up the matter for a final time with Mr. Misuraca in attendance. Staff advised the Commission that the application before them consisted of a request to allow the existing antennas on the site (the 31' high GAP Challenger and the 10' high UHF/VHF antenna) and to erect a 30' high dipole antenna on an experimental basis. Staff recommended approval of this request. The Commission took testimony from the applicant and a concerned neighbor, Mrs. Samgiss. The Commission deliberated on the item and came to adopt Resolution 95-08 which concluded that a proper application no longer existed after the withdrawal of the GAP Voyager from the application on April 12th. Even though the Commission concluded that a proper application no longer existed and that a new one must be filed, the Commission (out of caution) then denied the project as presented without prejudice. The Planning commission expressed its desire to continue working with the applicant and directed that fees be waived for any substantially similar future application filed neURON TOWN COUNCIL STAFF REPORT 6;7/95 3 within 30 days. The Planning commission urged the applicant to file as soon as possible for a renewal of the temporary permit which had been allowed to expire, and pledged to hear the item at its next meeting if filed in time to allow proper legal notice. ANALYSIS Regulation of amateur radio activities by local governments (including the erection of antennas for this purpose) is limited by Federal Communications commission ruling PRB-1. That ruling holds that local regulations which involve placement, screening, or height of antennas based on health, safety, or aesthetic considerations must be crafted to accommodate reasonable amateur communications, and represent the minimum practicable regulation to accomplish the local authority's legitimate purpose. The Planning commission was aware of the directives of PRB-1, but was frustrated at the final two hearings by the lack of an accurate visual representation of the antenna in the field. The Commission found that it could not adequately address the proposal without this visual representation. The Planning commission further found that the amendment of the application to delete the proposed 45' high GAP Voyager antenna in favor of a 3D' high dipole antenna and a 31' high GAP Challenger antenna was so substantial so as to warrant a new application. The Commission deemed the application withdrawn, but expressed a willingness to work with the applicant under a new permit application. staff, in its communications with the applicant, was working in light of the substance of the application as it was originally proposed (with a yagi antenna). It appeared to Staff, even without visual representations in the field, that the changes made to the application all tended to reduce the visual impacts of the project. For this reason, Staff supported and encouraged the changes proposed by the applicant. Furthermore, based on the recommendations of the Town's technical consultant, the solutions offered by the applicant seemed to represent a good compromise between the interests of the Town and the interests of the applicant. Because of the small size and unique configuration of the lot, it did not appear to Staff that there were many options for the location of the proposed dipole antenna. For these reasons Staff recommended that the commission approve the dipole antenna solution as proposed by the applicant. It was the opinion of Staff at the April 12th and 26th meetings that the withdrawal of the GAP Voyager in favor of the dipole and GAP Challenger antennas did not constitute a withdrawal or invalidation of the application. Staff believes that the efforts of the applicants and the Commission came to such an awkward conclusion as a result of 1) delays caused by exceedingly foul weather through the winter TlBURON TOWN COUNCIL STAFF REPORT 8/7/95 4 months, and 2) the constraints of the Permit streamlining Act. The Commission wanted the opportunity to consider the applicant's proposal in the field. The applicants, on the other hand, saw the Commission's actions to let the interim operating permit expire, declare the application withdrawn, and deny whatever proposal might be left, as representing a general animosity towards the application as well as being arbitrary actions not in keeping spirit or technical requirements of PRB-1 and interpretive case law. Environmental Status The project is categorically exempt from the requirements of CEQA per section 15303 of the CEQA Guidelines. RECOMMENDATION Staff recommends that the Council take public testimony and consider the facts, history, and unique circumstances surrounding this project. Staff hopes that Council direction can help steer the project towards a satisfactory resolution for all parties, as was successfully accomplished with the recent HAM radio application on Meadowhill Drive. EXHIBITS 1. Appeal and additional letter of 5/1/95 2. Planning commission Resolution 95-08 3. Planning commission Resolution 94-24 4. Minutes from 11/9/94, 4/12/95, and 4/26/95 PC meetings 5. Letter from applicant rec'd 4/12/95 6. Memo from Town Attorney dated 12/5/94 7. Letter from applicant to Prichard dated 10/29/94 8. Letter from FCC Observer Grant Prichard dated 11/5/94 9. Report from Richard Karlquist received 1/30/95 10. Vicinity Map \dan\tc19310.rpt TlBURON TOWN COUNCIL STAFF REPORT 6/7/95 5 ~4/21/i995 12:50 4154352438 TOWN OF TI BLRON PAGE 02 . . ( ( \ <, TOWN OF TIBURON NOTICE OF APPEA~ 0 . ~,-# " APPELLANn N~e: Malcolm A, Misuraca and Victoria Eo Rri~Rnt Ad~ 223 Deviso street. Tiburon. CA 94970 Telephone: 415/546-6430 (work) 415/435-3219 (home) ACTION BEING APPFALED: ~ Town of Tiburon -- Planning Commission Date of Action: April 1 2, 1 995 Name: of Applicant: Malcolm A. Misuraca and Victoria E. Brieant Na~eofAppli~tion: 'Earn Radio Antenna Application GROUNDS FOR APPEAL: SEE ATTACHED ,/-7 (./ 6.,... _ 1/L~/7) ;J ,II < -:r//:-( /1 5~ T vI! 1/'1 ,; ) Last Day to File: [ } :L Dale Received: l/Fee ($300.00) Paid: 0(0'.( K Dale of Hearing: Iv~' -)/ 7L/' 4.154352438 EXHIBIT NO. I ,"~:\'",i.<: < ':..' ~'t: 04<~1-9'5 01 :44PM - R-97% POO.2-~0t5 ( ( Grounds for Appeal 1. The planning commission seeks to regulate the operation of an amateur radio station duly licensed by the federal Government under the guise of administering the approval of antennas for high frequency and very high frequency licensed radio transmissions. Grounds for appeal: The Town of Tiburon has no jurisdiction over the operation of a federally licensed amateur radio station. Interference with that operation is preempted by the Interstate Commerce Clause of the U.S. Constitution and federal statute. 2. The planning commission has not acted in the spirit of compromise in exercising its limited discretion over an antenna for licensed amateur radio transmissions. The applicants, as the town's planning staff have emphasized, have acted in a spirit of compromise. Grounds for appeal: The Town of Tiburon is in violation of federal law in seeking to act arbitrarily, restrictively, and without the mandated spirit of compromise in considering the applicants' application for approval of amateur radio antennas. 3. The planning commission regularly has exceeded its jurisdiction in dealing with the applicants' antenna application, as the town attorney has repeatedly warned the commission in writing, by indulging itself in considering claims of radio frequency interference with television or telephone reception. This matter is preempted by federal law. Grounds for appeal: The Town of Tiburon will not confine itself to relevant bases for considering the applicants' application and has conditioned and attempted to prohibit their operation of an licenses amateur radio station on the objections of the Town to the possibility of radio frequency interference with other FCC-licensed or approved products. 4. The planning commission has acted arbitrarily, unreasonably, and antagonistically to federally-licensed amateur radio station operation by attempting to prevent the previously-approved use of the applicants' existing vertical antennas, which were approved for use during the period when the applicants and the town's staff were working out comments from the town's expert witness on radio frequency matters and neighbors of the applicant. The planning commission has done this on expressly impermissible and 1 .,' ( ( punitive grounds, namely, a complaint from neighbor of interference with her phone and television sets. Grounds for appeal: The Town of Tiburon is acting in antagonism to federally-protected rights over which the town has no jurisdiction. 5. The planning commission is acting contrary to the oplillon and advice of the expert witness which it hired to comment on the applicants' application. The expert's opinion places the applicants' current compromise vertical antenna well below the threshold of antenna size and structure that the town's expert has found are the minimum reasonable accommodations to the applicant that fulfill the town's burden to respect federally-protected rights. Grounds for appeal: The Town of Tiburon is acting arbitrarily, unreasonably, and without appropriate discretion in departing from the norms that must be respected for licensed amateur radio transmissions. The commission speaks of limiting the time or duration of operation, the places the applicants will be permitted to talk to, the frequencies used, and the makeup and configuration of antennas necessary for transmission on licensed bands. 6. The planning commission has ignored the advice and knowledge of its planning staff, which have worked with the consistent cooperation of the applicants to reach a compromise on the maintenance of amateur radio antennas for the applicants' federally-licensed radio operations. The staff has made reasonable agreements with the applicants, which the planning commission has refused to honor. Grounds for appeal: The Town of Tiburon is acting unreasonably and in violation of federal mandates that state and local authorities must act in a spirit of compromise and accommodation to federally-licensed amateur radio station transmissions. 7. The planning commission has attempted to force applicants to cease operating their amateur radio station by purporting to revoke permission to operate on an antenna that the commission previously expressly found was at least a reasonable temporary use of their federally-licensed rights. They had no basis for revoking the temporary use of that antenna other than indulging the objection of a single person who complained of interference with her television and radio. That neighbor has moved from the neighborhood as she 2 . ( ( has been seeking some reason to do quite apart from applicants' radio transmissions. The applicants had in a spirit of cooperation installed filters on her phone and television set, which had cured the alleged telephone interference. Nothing satisfied this person, or the commission, for that matter. Her television set contained external wiring to after-market speakers, which do not yield to filters, and which violate FCC regulations requiring manufacturers of appliances to filter out raio frequency energy. These issues are not within the jurisdiction of the town, but are preempted by the Federal Communications Commission. Grounds for aooea!: The Town of Tiburon . is acting on the basis of considerations that are outside its jurisdiction and using those considerations to deny federally-licensed rights to the applicants. The town is acting unreasonably and arbitrarily by forcing applicants to cease using the antenna that the town had previously identified as a good interim or temporary antenna while the applicants and the town staff attempted to work out a compromise for the benefit of both. 8. The applicants discussed with the town staff their original proposal to erect a Yagi or beam antenna; and the town staff stated that if the application were amended to eliminate the Yagi antenna the application for a vertical antenna should be "a piece of cake. II The applicants have removed the Yagi, but without receiving the corresponding fair and even-handed treatment that this compromise required. Grounds for aooea!: The Town of Tiburon has acted arbitrarily and in abuse of discretion in representing that a compromise by elimination of a Yagi antenna would be met by corresponding reasonableness by the town. The application for the Yagi antenna should be reinstated and processed immediately. 9. The planning commission declines to submit to the applicants a written statement of the rulings made by the commission on April 9. That statement was promised, but has not been furnished. The explanation of the staff varies within the staff concerning what was done, and the explanation of the senior staff person varies from the report in the local newspaper of what was done. Grounds for aopea/: The applicants will appeal on any additional grounds disclosed when the town finally issues a written statement of the action taken in the planning commission on April 9. 3 .' , ( ( 10. The Town of Tiburon is obligated to accommodate the licensed rights of the applicants to operate on any approved frequency and to maximize their licensed rights to operate with peak efficiency on all licensed bands. Grounds for avveal: The town violates federal law by attempting to prevent applicants from operating on all approved licensed bands, at approved power, and with the efficiency of the most modern antennas. This is a violation of federal law. 4 : ~ J f',~':, ,. I":]; ,,,~, , ' t..U, I,. ,~, ';i,'," 'I _, ,I.'~ -! .' ~ :; I.~ ~ ' - c ( LA. O"'''Il;C. 0" MALCOLM A. MI3UII.^C^ I.. WA,,,,,,IU aT"IlET .~."Te:: ...0 5AH fRANCI5CO. CAUfOll.NIA 14105 (.41!) ,. 1:100- '''''II' ........ (rACa'MI"'C) May 1, 1995 Via Facsimile Rob Ewing. Esq. Town Attorney Town of Tiburon 1155 Tiburon Boulevard Tiburon, California 94920 Re: Appeal docketed April 24. 1995 Dear Mr. Ewing: This letter is written to discuss the appeal that my wife and I filed from the conduct and decision of the Tiburon planning commission on April 12. The appeal was docketed April 24. as April 22 was the last day to file. but was a Saturday. The planning commission met on April 26. claiming that it had not acted finally and precisely on April 12, and on April 26 it purported to deny my wife and my application. In fact, the application had been denied on April 12, and the planning commission acted on April 26 out of an evident desire to appear to have acted more reasonably and with due appreciation and regard for the federally-protected and preempted rights presented by my wife and my application. It seems apparent to me that when the planning commission adjourned on April 12. a good deal of off-the-record discussion among planning commissioners and staff took place, al\ in what appears to me to be a plain violation of the ~. - . -'~ " j II : 'f ; F t\:.>! 1\.;.~.~ ,'\, ~1;] ,; ".; (; fl. ;., ,~. ~ ,j 4.,';;.4;, ':1 :'JI)' " ( ( Rob Ewing, Esq. May 1, 1995 Page 2 Brown Act. The reason was that the commissioners had at their April 12 meeting summarily denied our application, and staff were concerned that this action would not stand up and reflected a basic animus to our application on grounds that the commission had no business indulging and that could not be sustained. It is about that animus that this letter is written and the appeal was filed. The planning commission lacked jurisdiction to do what it did on April 26, in its effort to tidy up its April 12 action, and if its action was based 011 Brown Act violations--either through direct seriatim contact among commissioners or contact using staff or others as a ~onduit---it will be separately challenged on that basis. The staff on April 26 claimed that our appeal was meant "to keep our options open," as though the planning commission was entitled to place a gloss on our appeal that authorized them to ignore it and the lapse of their jurisdiction. Let me assure you that nothing of the kind is true, and it is the cavalier and peremptory attitude toward this issue reflected in that statement that is swiftly drawing us into an unnecessary risk of litigation. My wife and I have cooperated with staff in the matter of our antenna application in all the months since it was filed. You will find Mr. Catron's staff reports replete with repeated acknowledgements of our spirit of cooperation. This is nothing less than is required under the relevant federal precedent, as your prior opinion letters have attempted to make clear to the commission, but what has been lacking is the slightest semblance from the planning commission of the town's equal burden of cooperation and respect for this federally-regulated and preempted field. The commissioners have been uniformly hostile and invincibly uninformed of the limits of their power; the staff cites to your opinion letters, and there is no hint that the commission pays them the slightest heed, At one point, Chairperson Greenberg wrote a series of questions to the Town's expert on these matters, which were clearly calculated if possible to elicit from him antagonistic and contrary statements to those I had given her and the commissioners. Not only did Mr. Karlquist verify in virtually the same ': - . - ;:: : ,:i: ~ ,",t\i MAL,~CiLM A. :,.:jSt.:,.~c.~ T- 4~:5~'fJ8 FOC4i)ij', " ( ( Rob Ewing, Esq, May I, 1995 Page 3 terms everything that I had told the commission, but he gave his opinion that an antenna 60 feet hi2h was the model for efficiency and adequacy that the commission should afford me. We have heard little of Mr. Karlquist's opinion since that enlightening episode. The planning commission has now purported to revoke our application in its entirety, including the authorization to maintain the Gap DX-Vrn antenna for which authority was granted many weeks ago. No reason has been given for revoking that authority, and the planning commission has none worthy of the name. The chairperson of the commission personally called me several months ago and asked me to move the antenna 15 to 20 feet to the southwest of its original location, which again I did in a spirit of cooperation. She did so as the only request or condition imposed on the operation of that antenna, which the commission has now seen fit to claim must be dismantled. At the beginning of the meeting on April 26, Mr. Schrier was incensed that the Gap antenna was still standing and demanded to know whether the staff had told me to dismantle the anteMa and shut down my ham radio station. Staff explained that I had not been told to do so, to which the commissioner reacted with anger and hostility, At its April 26 meeting, the commission purported to deny the application without prejudice, provided that it be amended only to include a wire antenna. This ignored my express statement to the commission that my wife and I intend to reassert our application for a Vagi antenna mounted on a retractable tower and mast. If we apply for the Yagi, the commission claimed on April 26 that we would be forced to pay a new application fee, which was another evidence of the discrimination and effort to manipulate the application that has become a hallmark of this group. This planning commission is outside the law, and it is apparent that it believes it need merely cite clich6s such as Hfor the good of the people" to overlay successfully its hostility to the rights protected by the Federal Communications Commission, Our appeal, which you may have seen, is meant to penetrate this unlawful and unreconstructed practice. " - . - J ~I . -) : ~ ; FRJM ~ALi:OL~ A. ~;;5UR~(A i\i 'f ;~24 .3::- ?OC5,OiJ:, ,< . . . ~ ( ( j' Rob Ewing, Esq. May 1. 1995 Page 4 My wife and I are not willing to be treated as pariahs and with the hostility and contempt that the chairperson typically shows, followed by the other commissioners. The only commissioner who has been uniformly courteous and determined to find a proper spirit of compromise has been Mr. Perlmutter. I would appreciate your making certain that no effort is made to denigrate or look aside from our appeal and your calling me at your convenience to discuss ways and means to return the planning commission to its appropriate role. Sincerely yours, . Malcolm A. Misuraca (llraphioo .ipWuro) ( ( RESOLUTION NO. 95-08 A RESOLUTION OF THE PLANNING COMMISSION OF THE TOWN OF TIBURON DENYING A CONDITIONAL USE PERMIT APPLICATION TO ERECT HAM RADIO ANTENNAS AT 223 DIVISO STREET CAP 59-131-07) WHEREAS, the Planning commission of the Town of Tiburon does resolve as follows: Section ~ Findinqs. A. The Planning Commission has received an application from Malcolm Misuraca and Victoria Briaent requesting a Conditional Use Permit to install antennas for amateur radio operation at 223 Diviso Street. The originally filed application included a "Yagi" beam antenna on a retractable mast, a 31' high GAP DX-VIII Challenger antenna, and an 11' high VHF antenna. The original application was amended in October 1994, prior to its being deemed "complete" by Town Staff. The October 1994 amendment deleted the Yagi antenna and GAP Challenger antenna from the application and proposed in their stead a 45' tall GAP DX-IV Voyager antenna. The application was deemed complete on October 31, 1994. Said application consists of File #19310. B. The project site is situated in a hillside location with views of the San Francisco Bay and the Golden Gate Bridge. These views are shared by many homes in the neighborhood and are commonly recognized to be of tangible value and importance to local residents. C. The proposed radio antennas, if not properly regulated and restricted in height, have the potential to substantially affect and degrade the views of San Francisco Bay from other homes in the neighborhood, and affect and degrade in general the aesthetic qualities of the neighborhood. D. The Planning Commission held a dUly-noticed public hearing on the application on November 9, 1994. At that hearing the Planning commission considered the applicant's request for a 45' tall GAP DX-IV Voyager antenna. The Planning Commission expressed its desire to see the proposed antenna in order to evaluate its aesthetic and visual impacts. The Commission continued the hearing to the January 25, 1995 meeting to allow the applicant time to erect the proposed GAP Voyager antenna. The Commission requested that the proposed antenna be erected at least two weeks prior to the next hearing in order to allow neighbors and the Commission to evaluate the visual and aesthetic impacts. PLANNING COMMISSION RESOLUTION NO. 95-08 4/26/95 1 EXHIBIT NO. 2- " . . ( ( The Commission also adopted Planning Commission Resolution 94-24 which allowed the applicant interim use of a 31' high GAP Challenger antenna and an 11' high VHF antenna which had been erected on the site without benefit of a permit. The permit also allowed the applicant to erect the proposed GAP Voyager antenna on a temporary basis in order for the Planning Commission to assess visual impacts. This interim permit was set to expire by its own terms on 4-15-95. E. The project was continued (without discussion) from the January 25, February 8, and March 22, 1995 Planning Commission meetings to allow the applicant to erect the proposed GAP DX-IV Voyager antenna. The applicant was unable to erect the antenna as requested by the Commission because of unusually heavy and consistent rains, and the applicant's schedule. F. A Permit Streamlining Act extension was agreed to on 1-19- 95. This extended the Permit Streamlining Act deadline from January 30, 1995 to April 30, 1995. G. The applicant advised Staff that he finally erected the proposed GAP Voyager antenna sometime in late March/early April 1995, but had removed it almost immediately. The applicant stated that he did not wish to pursue the GAP Voyager antenna because the visual impacts were greater than he had anticipated. The applicant withdrew the GAP Voyager antenna from the application on April 12, 1995, and requested instead to erect a "dipole" antenna and retain the 31' high GAP Challenger and 11' high VHF antennas. H. The Planning Commission considered the project for a second time on April 12, 1995. The applicant was not present at the meeting. The Commission expressed its concern about the substantial change in the application so late in the process and the lack of information and visual representation regarding the dipole antenna. The Commission expressed concern that it had never seen any representation of the dipole antenna on paper or erected in the field in order to assess its visual and aesthetic impacts; nor had the commission ever before considered the 31' high GAP Challenger antenna as part of the application nor seen it erected in various locations on the site to assess its relative visual impacts. The Planning Commission decided to allow the interim permit granted by Resolution 94-24 to expire on April 15, 1995. The Commission continued the project to the April 26, 1995 Planning Commission meeting in order to allow Staff to research the status of the application (if any) still pending before them. PLANNING COMMISSION RESOLUTiON NO. 95-08 4/26/95 2 .' 85i'O~/'1995 88:58 ~~f~q/!~~~ li:1! 415-435-b7b4 QJ.::l<I..:I:'~QJt:I R;:..;'-lD\' '3R!::E'lBER3 I UWN Lf" TlBUR'lJN ~''-\':iE 04 P~GE 04 ( ( I. On April 2., 1~~5. the applicant riled an appeal of the .lannlnq Co~mi..ion'. decleion on April 12th to let the inter 1m permit (authorized by P18nnin9 Commi..ion Re.olution 9.-2., .xpir. vithout taking any attlraativ. aotion to ext.1I4 it. J. Tft8 Plannlng Commi..ion consid.red the matt.r tor the thir4 and tlnal time on April 2', 1995. The applicant vae pree.nt at tni. h.aring. The Planning Commi.eion found that the amendm.nt to the application on April 12, 1~95, requesting .to ereot a "dipole. antenna on a 30' ma.t and a 31' hiih GAP Chal1.nger antenna, va. a eubetantlal change in tha application not made at the behe.t of th. Town. The Commie. ion tound th.t thie wae in ....nc. a "nav" project for which tha applioant hed not tiled . nev application. The pravioue application for a GAP voyaqer antenna had ~en withdFawn by the applicant in hi. letter ot April 12, 1995. The Commi.eion telt it va. not .ppropriate tor it to be .Ubjected to a "lIovlnq target" application wh.n raced wit.h a Permlt str..1I1ining Act deadl1ne. K. EV.n though th. Commieeion had determin.d that a proper application no longer .xi.ted .nd that a new One muet b. filed, the Commia.lon deni.d the proj.~ a. pre.ented vithout prejudioe. The Pl.nnin~ commi..ion exprese.d it. de.ire to continu. working vith the applicant and dir.cted that ree. ~ weived for any .ubatentielly similar future epplioation tiled within JO deys. The Planning Cornmis.lon Qrged the applieant to tile ae .oon a. po..ibl. tor a renewal ot tha t..porary p.rmit Which had eXFired, and pledged to h.ar the it.. et its next meet in; it tiled in time to el10w proper leqal notice. S~ction lL oenial& NOW, THEREFORE BE IT RESOLVED that the Plennin; Co=mission of the Town ot Tiburon doe. hereby deny tho .ubject application (Conditionel U.. Permit application 11~310' vithout prejudlce based upon the abOve tindings end oircumstance.. P~SSED AND ADOPTED at a regUlar meeting of the planning Commi..ion ot the Town of Tiburon on April 26, 1995 by the tollowing vot.e: . ATTEST: I AYEs I NOES: ABSENT: COMMISSIONERS: COMMISSIONERS: COMMISSIONERS: Schrier. siewert " ) -fll<<lt, , I l' ( ( I RESOLUTION NO. 94-24 A RESOLUTION OF THE PLANNING COMMISSION OF THE TOWN OF TIBURON APPROVING AN INTERIM CONDITIONAL USE PERMIT TO OPERATE A HAM RADIO STATION WITH TWO EXISTING ANTENNAS AT 223 DIVISO STREET CAP 59-131-07) WHEREAS, the Planning Commission of the Town of Tiburon does resolve as follows: section ~ Findinqs. A. The Planning Commission has received an application from Malcolm Misuraca and Victoria Briaent requesting a Conditional Use Permit to operate a ham radio station and install an antenna for that purpose at 223 Diviso Street. Said application consists of File #19310. B. The Planning Commission has held a dUly-noticed public hearing on November 9, 1994, and has heard and considered testimony from interested persons. C. The Planning Commission has found that the project is categorically exempt from CEQA per Section 15303 of the CEQA Guidelines. D. The Planning Commission has considered FCC ruling PRB-1 in its deliberations. Section ~ Approval. NOW, THEREFORE BE IT RESOLVED that the Planning commission of the Town of Tiburon does hereby approve the Conditional Use Permit subject to the following conditions: 1. This interim Conditional Use Permit approves the temporary use of a 31 foot high GAP Challenger high frequency vertical antenna and a Diamond X2200A VHF-UHF vertical antenna, by amateur radio station KC6VDR and KC6VGU at 223 Diviso Street. The GAP Challenger antenna shall be erected directly on the ground without any additional mast elements. 2. This Conditional Use Permit specifically does not approve the permanent installation of a GAP Voyager DX-IV high frequency vertical antenna, or any other antenna until specifically approved by the Tiburon Planning Commission. The applicant is directed, in conjunction with the PLANNING COMMISSION RESOLUTION NO, 94-24 11/9/94 1 EXHIBIT NO. "3 I I ( ( consideration of the request to erect the GAP Voyager antenna on a permanent basis, to erect the GAP Voyager antenna for a period of two weeks beginning sometime between January 7 and January 14, weather permitting. This trial will be used by the Planning commission to better evaluate the visual impacts of the proposed GAP Voyager antenna. 3. The permitted antennas are being approved on a temporary basis only, while the Planning Commission considers the applicant's request to erect a larger GAP Voyager high frequency vertical antenna. 4. Permittee shall comply at all times with FCC regulations concerning operation of this use. 5. Permittee shall maintain all antennas in an undamaged condition. If visibly damaged, permittee shall repair or replace the antenna to a condition consistent with this permit. 8. This interim Conditional Use Permit shall expire and become null and void on April 15, 1995, unless a time extension is granted by the Planning Commission. 9. The Town of Tiburon reserves the right to amend or revoke this interim Conditional Use Permit for just cause, in accordance with Zoning Ordinance regulations of the Town. PASSED AND ADOPTED at a regular meeting of the Planning Commission of the Town of Tiburon on November 9, 1994, by the following vote: AYES: COMMISSIONERS: Greenberg, Heckmann, Perlmutter, Schrier, Siewert NOES: COMMISSIONERS: None ATTEST: l&7Ct a.J~~ -, S OTT ANDERS N, SECRETARY PLANNING COMMISSION RESOLUTION NO. 94-24 11/9/94 2 ~ " CONSENT CALENDAR 1. Minutes of september 28, 1994. 2. Minutes of October 12, 1994. Greenberg requested the following correction to the September 28, 1994, minutes: * Page 5, the 2nd sentence in the 1st paragraph should read "Anderson stated that you cannot deny the application based on completion or even funding of the improvements." There were no corrections requested to the minutes of October 12, 1994. It was moved and seconded to adopt the minutes of September 28, 1994, as amended. Motion carried 5-0. It was moved and seconded to adopt the minutes of October 12, 1994, as presented. Motion carried 4-0 (Perlmutter abstaining). PUBLIC HEARING ,~ 3. 223 DIVISO STREET: Conditional Use Permit to operate a HAM radio station and install a HAM radio antenna. Malcolm Misuraca and victoria Brieant, owners and applicants. Assessor Parcel No. 59-131-07 (Resolution). Greenberg explained the procedure for this public hearing item to the public. Catron stated that the applicants are requesting a Conditional Use Permit to operate a HAM radio station from their residence. The use would consist of a control console located inside of the residence and two antennas located outside of the residence. Catron explained that federal laws allow the operation of HAM radio stations as a constitutional right which supersedes local zoning ordinances. Catron noted that the applicants originally proposed a "Yagi" style antenna, but that was dropped from the application in an attempt to minimize visual impacts on the neighborhood. The applicant now proposes to erect a 45 foot tall high frequency (HF) vertical antenna, and an 11 foot tall very high frequency (VHF) vertical antenna. The proposed HF antenna includes several small elements running parallel to the main vertical element at a distance of approximately 6 to 8 inches, and a 80 inch diameter halo style ring at the top of the antenna. The applicants advise that the larger HF antenna is necessary to operate in the 160 meter band. The existing 31 foot tall HF antenna on the site will not operate in TIBURON PLANNING COMMISSION MINUTES OF NOVEMBER 9, 1994 Minutes No. 726 2 EXHIBIT NO. L.f t ( the 160 meter band. The applicants have proposed two possible locations for the larger HF antenna on the northwest side of the house approximately eight feet apart. . Staff is not aware of any significant difference in impacts between these two locations. The proposed VHF antenna is an eleven foot tall whip style antenna, which Staff considers to be relatively unobtrusive and is used for local and relay applications. Catron stated that correspondence has been received from several neighbors complaining about interference. The Town is preempted from all jurisdiction in interference matters. staff believes that this issue is properly directed to the FCC. staff recommends that the Commission consider the aesthetic impacts of the proposed antennas and weigh those impacts against the applicants rights to erect antennas which provide for reasonable long distance communications. He said that the Commission must show a good faith effort at accommodating the applicant's interests, as the burden of proof is on the Town. Schrier asked Catron if the EMF issue has been addressed and he replied that he did not know if there is enough proven evidence to make a determination. Heckmann asked for basic criteria for what is considered to be "reasonable" use. Anderson stated that there is no fixed standard for this determination. Malcolm Misuraca, applicant, stated that the effectiveness of antennas is affected by their surroundings, including structures and trees. He said that there are limited places on his property that antennas will be effective and would not obstruct the Golden Gate Bridge view from the neighborhood. He said that one location would be the northwest corner of his property. He stated that the antennas do not block the primary view of anyone in the area. The "Yagi" antenna surpasses the effectiveness of a vertical antenna, but due to view obstruction, they went with a vertical antenna. He said that the 11 foot VHF antenna is probably not visible by any of the neighbors. He said that the VHF antenna operates on line of sight for short range use. The 45 foot HF antenna is for long range communication, which is what HAM radio operators use most frequently. Mr. Misuraca explained how the sunspot cycle affects reception. He said that the problem that all HAM radio operators will face for the next five or six years is that we are coming to the low point in the sunspot cycle. The sun operates on 11 years cycles of high and low sunspot activity. In years of high sunspot activity, it is possible to operate on a much higher frequency and as a consequence of that, the antennas can be shorter. He stated that, however, in years of low sunspot acti vi ty, it is necessary to TIBURON PLANNING COMMISSION MINUTES OF NOVEMBER 9, 1994 Minutes No. 726 3 \ " operate on lower frequencies and the antennas must be higher for the world-wide communication that Mr. Misuraca plans to do. Mr. Misuraca said that Amateur Radio Operators have an obligation to try and deal with neighborhood problems. He said that he has tried to do that. He stated that the FCC and the Cable Company say that the Samgiss', 239 Diviso street, reception problems are not related to the operation of his radio. Mr. Misuraca said that he received a letter from Grant Pritchard from the OOC San Francisco Section, dated November 5, 1994, stating that Mr. Misuraca's station is being operated in an appropriate manner. siewert asked Mr. Misuraca how long he has been transmitting and he replied that he started transmitting from the first location seven months ago. She asked him how often he uses the radio and he replied that he usually starts using the radio at 9 p.m. or at 8 a.m. during the weekdays and during the day on weekends. She asked him if the proposed 45 foot antenna could be retractable and he said that this particular type of antenna cannot be retracted, jointed or telescoped. She asked him if he researched the lowest possible height at which he could operate and on what grounds did he base his decision. He stated that in order for an antenna to function on a given frequency, it has to have a certain configuration, which does not vary with location. The configuration is a function of its physical length and its electrical length, based on the laws of physics. siewert asked Mr. Misuraca if the material or the color of the material of the antenna would affect if. He stated that although he has never seen anodizing of the antenna done, he feels that if it was possible, all of the manufacturers would be doing it. Schrier asked Mr. Misuraca what the existing 31 foot antenna is used for and Mr. Misuraca replied that it is made by the same manufacturer as the proposed ones and he replied that it used for higher frequencies. Schrier asked if he planned to take the 31 foot antenna down once the proposed one is approved and he said that he did. Heckmann asked Mr. Misuraca if screening of the proposed antenna by trees would be effective and he replied that it would only be effective on the north side of his property. Mr. Misuraca said that the antenna could be moved approximately 12 or 13 feet to the southwest, away from the Samgiss', and although it would probably reduce the interference, it would be more visually intrusive. Perlmutter asked to whom it would be more visually intrusive and Mr. Misuraca replied that it would be more visible to those driving south on Centro West. Mr. Misuraca said that the antenna would be a little more out in the open than in the other location, as there would not be trees to shield it. Heckmann asked if additional trees will be planted and Mr. Misuraca said that he would plant more trees if it was made a condition of approval. TIBURON PLANNING COMMISSION MINUTES OF NOVEMBER 9, 1994 Minutes No. 726 4 ~ ( Perlmutter asked what the diameter of the proposed 45 foot antenna is and Mr. Misuraca replied 2" at the widest part, which is at the base of the antenna, and 1 1/2" at the narrowest part. He stated that this is slightly wider in diameter that the present antenna. siewert stated that there is also an 80 inch diameter halo style ring at the top of the antenna. Greenberg asked what the purpose of the supports for the halo is and Mr. Misuraca said that their only purpose is to hold the ring in place. Heckmann asked Mr. Misuraca how many licensed HAM radio operators there are in Tiburon and he said that there are 60 HAM radio operators in Town, but he does not know how many actually operate. Greenberg asked Mr. Misuraca to clarify what he needs in order to communicate during high sunspot activity and he replied that 160 meters is the lowest HAM band and consequently offers the best world-wide communication. He said that this lowest HAM band is best for long distance communications, particularly at night during low sunspot activity. Greenberg asked him if he was limited to 80 meters what type of communication would he have to give up. He said that at 80 meters, weeks could go by without world-wide communication. He mentioned that there is a 4 1/2 year trough in sunspot activity and in 1997, we start getting out of the trough. siewert asked if "Yagi" style and vertical antennas are the only types of HAM radio antennas available and Mr. Misuraca agreed. He stated that there are many different models of vertical antennas, but all of them have to be roughly the same length, have the same peripherals on the side and a halo or metal spoke-type structure at the top in order to be operable. Greenberg asked if some vertical antennas may be smaller that the one proposed with the halo at the top and he replied that you would not find any much less obtrusive. schrier asked Mr. Misuraca if his existing 31 foot antenna would be satisfactory in the next few years when we when start getting out of the trough and move into the high sunspot cycle and Mr. Misuraca agreed. He stated that he and most HAM operators would take down the taller antennas at that time in the sunspot cycle and use the shorter ones, as it would give the operators more bands. siewert asked Catron if this Conditional Use Permit runs with the land or the current owner and Catron replied that Use Permits generally run with the land. Anderson pointed out that, as written, this permit would apply only to this particular operator. Greenberg opened the public hearing. Ali Samgiss, 239 Diviso street, said that since mid-January of 1994 he has heard Mr. Misuraca's voice on the HAM radio coming through his television, stereo, telephone and answering machine for up to four hours at a time. He stated that it starts as early as 6:45 TIBURON PLANNING COMMISSION MINUTES OF NOVEMBER 9, 1994 Minutes No. 726 5 ~ ( a.m. He mentioned that the interference problem stopped between May 12 and October 8, 1994, but has resumed again. He contacted Mr. Misuraca about the problem and Mr. Misuraca came to his house and added filters to his equipment. Mr. Samgiss said that Viacom Cable stated in their letter dated November 8, 1994, that the interference was not entering their equipment via the cable system. Mr. Samgiss stated that his equipment is average in quality. He said that he called the manufacturers of his equipment, who stated that his own equipment is in compliance with the FCC. He mentioned that the lots in his neighborhood are small, the roads are narrow and there is no current shielding of the antennas from trees. He said that his neighbors have reported that they have the same problem with interference from Mr. Misuraca's radio. He said that there is also the matter of the aesthetics as it relates to the obtrusive look of an antenna in the landscape of Old Tiburon. schrier asked Mr. Samgiss, with the knowledge that the Planning Commission's role is to consider the aesthetic impacts of the proposed antennas only, what he would like to see the Commission do about this situation and he replied that he would like to see the new antenna placed at a previous antenna site used in August of 1993. He said that, at that site, the antenna was visible, but there was no interference. Perlmutter asked Mr. Samgiss what he heard coming through his equipment and he replied that he has hears only Mr. Misuraca I s voice in a one way conversation as he is communicating with people through his HAM radio. Llewellyn Wommack, 240 Diviso street, stated that she can also hear Mr. Misuraca's voice coming through her equipment and feels that this is an invasion of her privacy. Dick Ward, 1952 Centro West street, said that he is concerned about EMF safety. He would like Mr. Misuraca to transmit on the lowest power possible. He stated that he would like to propose that a temporary permit be granted until more is known about the danger of EMF's emanating from Mr. Misuraca's system. Bob Egner, 243 Loma Avenue, urged moderation of approval for view and aesthetic purposes. He said that he worked eight years to have the Eucalyptus trees removed across the street from the proposed antenna site, on Centro West. He suggested that only a temporary permit be granted to Mr. Misuraca. Christine Bassin, 230 Diviso street, said that she has experienced interference with her telephones and computers. She wanted to know if a retractable antenna or a increased number of shorter antennas could be installed instead of one tall one. She also wanted to know why the story poles had not been erected yet. She requested that when they are finally erected, they also have a representation TIBURON PLANNING COMMISSION MINUTES OF NOVEMBER 9, 1994 Minutes No. 726 6 ~ ( of the halo attached in order to get the full impact. Michael Bennett, 2077 Centro East Street, mentioned that the Buxtons, who live at 220 Diviso street, are having interference problems with their telephones. Mr. Bennett asked Catron if a permit was granted to Mr. Misuraca for his existing HAM Radio operation and Catron replied that no permit had yet been granted. Mr. Bennett said that the planting of trees is not the answer, as they would block views more than an antenna would. He said that the neighbors should contact the FCC about their interference problems. He stated that he appreciates the services that HAM operators provide in emergency situations, but he primarily considers it a hobby, not a necessity. Charles Locati, 260 Diviso street, said that the neighborhood views were returned to them when the Eucalyptus trees on Centro West were cut down. He said that the views will be lost again with the installation of this antenna. He obj ects to approval of this application. Mr. Misuraca stated that he wanted to address the neighbors I comments. He stated that Mr. Samgiss was not home when he filtered their equipment. He also wanted to assure Ms. Wommack that he was not eavesdropping, nor did he have the technical capability of eavesdropping on her conversations. He stated that he has to operate at 1500 watts in order to call his friend in New Zealand. He said that he owns two televisions and has no interference from his HAM radio equipment on his other equipment. He said that he is happy to help any neighbor experiencing interference by adding filters to their equipment. Greenberg asked what is the highest up on the 45' vertical antenna will the guy wires be attached and it was determined to be approximately 38 to 40 feet. siewert asked how many guy wires there will be and Mr. Misuraca replied that there will be four. Schrier asked what the diameter of the guy wires will be and Mr. Misuraca said that, if polypropylene material is used for the guy wires, they will be 3/16" in diameter. Schrier asked Mr. Misuraca if there are satellite dishes available that would be satisfactory for this proposed use, instead of the more visually obtrusive vertical antenna and he replied that there are satellite dishes available that operate on extremely high frequencies, but they are not for world-wide communication. Greenberg asked if multiple short antennas were possible and Mr. Misuraca was unsure what she was referring to unless she meant a phase vertical antenna. Schrier asked Mr. Misuraca how long it would take to erect the proposed vertical antenna and he replied that it would take about a day. Schrier asked if he knows if the antenna will work before TIBURON PLANNING COMMISSION MINUTES OF NOVEMBER 9, 1994 Minutes No. 726 7 ~ ( he puts it up and Mr. Misuraca replied they will not know until it is put up. Schrier asked Mr. Misuraca why he did not obtain a permit for the existing 31' antenna. Mr. Misuraca stated that he filed an application some time ago, but the problem was that once he decided not to use the "Yagi", he has been experimenting with the 31' antenna to see if it would be operable and to see if it would be acceptable within the community to try and avoid the problems and delays that occurred with the Al Burnham's HAM radio application. siewert asked Mr. Misuraca how often he calls his friend in New Zealand and he replied he tries to call him every day, but only gets through occasionally. There being no one else wishing to speak, the public hearing was closed at 9:08 p.m. Siewert stated that story poles, which have not been erected yet, are needed in order to get an idea of the visual impact. Greenberg mentioned that this request was made of the applicant, but due to the major storm this week, Mr. Misuraca could not put the story poles up. She asked Mr. Misuraca to seriously investigate painting or anodizing the antenna, as she said that black or dark brown colored antennas are less obtrusive. She asked Mr. Misuraca to check out other al ternati ves to the 45' vertical antenna. She mentioned that the previous applicant for a HAM radio antenna, Al Burnham, 42 Meadowhill Drive, installed a 30 foot antenna and suggested that perhaps this would work for Mr. Misuraca. She feels that the south side of the site might be less obtrusive. She does not think that planting trees as a buffer would be effective. She said that Mr. Misuraca's main use of the antenna is for his hobby and questioned why a hobby needs to get 100% reception. She said that his use as a hobby must be balanced with his neighbors' views. She recommended that a condition be made that the height of the antenna be lowered as we move into the higher sunspot cycle. She feels that no decision can be made tonight. Schrier stated that he agrees with Siewert. He feels that there should be a three year review period, reduced to a one year review period if an EMF health issue is determined. He does not feel that the fact that this is primarily a hobby should affect his ability to get adequate reception. He want to see the applicant look into alternate, less obtrusive locations. He said that he would like to get advice from an expert in the field of HAM radio antennas. Perlmutter said that he would like to see reduced interference problems, which he realizes is not the in the Commission's hands, and reduced visual impact on the neighborhood. He stated that alternative less obtrusive locations should be sought out. He said that there should be a height limitation of the antenna at 3D', if TIBURON PLANNING COMMISSION MINUTES OF NOVEMBER 9, 1994 Minutes No. 726 8 ~ < feasible. He recommended that there be a one year trial period. Heckmann expressed concerns about the visual impact of such an antenna. He said that the Town wants to maintain views. He has heard from the neighbors that the views have just been opened up with the cutting of the Eucalyptus trees across from the proposed site. He would like to see a shorter antenna used. He said that he would like to see how the antenna will look when it is in place and how it will look from the neighborhood. Schrier stated that he would like Town Attorney Ewing's input. Greenberg said that she agrees with all of the Commissioners comments. She is concerned about view impacts. She said that she can empathize with the impact to all of the neighbors. She did not feel that it was a good idea to allow Mr. Misuraca to operate without permits and that penalties should be charged. Anderson stated that the applicant submitted an application, but it cannot be determined if it is operable until it is used, thus a permit was not given at that time. She said that she could approve this type of vertical antenna. She said that it is not attractive and exceeds the roof height, but it is slender with minimal visual impact. She feels that it is inappropriate to place the structure in of the vicinity of where the eucalyptus trees once were. She stated that she would like the opportunity to look at other types of antennas in Town. Greenberg asked Al Burnham, 42 Meadowhill Drive, HAM Radio Operator with a fairly recent Conditional Use Permit approval, if he painted or anodized his antenna and he said that he did. She asked if his antenna is 30' tall and he agreed. He said that his antenna is a beam with 28' crossbar elements, not a vertical, and the two operate completely differently. He said that the beam antenna works at a different height than the vertical, which needs a particular height in order to work. Greenberg recommended that a neighborhood meeting be held on the site and that story poles placed in different locations in order to get its full impact on the views. She feels that it should be made a condition that Mr. Misuraca lower his antenna during the years of high sunspot activity. She also agrees that an independent expert should be hired. Greenberg asked Don Batten, HAM radio operator, 29 Mercury Avenue, how tall his antenna is and he replied that normally operates at 45' . Greenberg asked Anderson how many of the 60 HAM radio operators in Tiburon have permits and he replied that only one HAM radio operator, AlBurnham, has a permit. TIBURON PLANNING COMMISSION MINUTES OF NOVEMBER 9, 1994 Minutes No. 726 9 { ( Anderson stated that if the Planning Commission requires the antenna to be lower than 45', and since the burden is on the Town, the Town will need to hire an expert. Anderson was not sure if an expert could tell, just by looking at heights and locations, whether or not it would work. Anderson stated that the HAM radio must be operable in order to be able to have an expert test it. The Commission requested that Town Attorney Ewing research other legal cases regarding antennas that would discuss what is considered "reasonable" operation. The Commission requested the applicant to pick the best location, erect a 45' story pole and the Commission will interpolate it in various locations. Mr. Misuraca requested permission to put up the actual 45' antenna that he had already, purchased instead erecting a story pole and the Commission agreed that he could do that. The Commission agreed that the antenna needs to be erected in order to show the aesthetic impacts to the Planning commission and to the neighbors. The 45' antenna is to be up for two weeks with the erection date between January 7 and January 14. Mr. Misuraca is to consult with Mr. Burnham about what color to paint or anodize the pole. The Commissioners are to put their questions in writing for the expert. The Ham Radio Expert is to visit the site and report back to the Commission with his findings. M/S SChrier/Perlmutter (5-0) to grant a temporary Conditional Use Permit to operate a 31' HAM radio antenna until the permanent one is issued. Anderson stated that this application is subject to the Permit streamlining Act and the deadline is sometime in early February 1995, so that the Commission may want to make a decision or ask for an extension of 90 days, if the applicant concurs. The Commission decided not to ask for the extension at this time. It was moved, seconded, and unanimously carried to continue this item to the January 25, 1995, Planning commission meeting. COMMISSION AND STAFF BRIEFING (Continued) Greenberg said that she read that the Martha Company DEIR would be ready approximately six months after the Scoping Session. Anderson stated that he feels that this is optimistic due to the need to conduct the special plant studies which will go on until the end of June or the end of the blooming season. He said that some EIR Consultant proposals have said that they will not have the DEIR ready before Fall 1995 for this reason. The Commission discussed the logistics of the Martha Company field trip with Staff. TIBURON PLANNING COMMISSION MINUTES OF NOVEMBER 9, 1994 Minutes No. 726 10 ( ( more changes to Precise Plans unless there is an overwhelming need. He said that he spoke with Mr. Lang and he is willing to agree to the conditions, as precisely presented in his letter. There being no one else wishing to speak, the public hearing was closed at 8:15 p.m. siewert said that the Planning commission cannot foresee all of the variables that can occur once raw land is developed, and the Town should be able to amend Precise Plans with discretion. She said that there can be reasons to change them. Siewert supports this application. Perlmutter permission Commission said that since the neighbor at 2 Cibrian Drive got for a secondary envelope, this puts the Planning in the position of having to approve this application. Schrier said that the Planning commission is not bound to approve this application. Each Precise Plan amendment should be looked at on its own merits. He still questions whether there is any slide danger, but no evidence has been presented to indicate that there is still danger. He said that he would approve this application. Heckmann said that he supported this application when it previously came to the Planning commission. He feels that the soils concerns have been adequately addressed. He said that with the conditions proposed by the applicant, there should be limited impact. He favors this application. Greenberg said that she cannot support this application. She feels that Precise Plans should be adhered to, unless there is an overwhelming need to change them. It was moved, seconded and unanimously carried to continue this item to the April 26, 1995, Planning Commission meeting, to allow Staff to edit Mr. Lang's additional conditions and attach them to the draft resolution. Chairman Greenberg suggested that Item 2 be heard next and the Commission agreed. vi 2. 223 DIVISO STREET: Conditional Use Permit to operate a HAM radio station and install a HAM radio antenna. Malcolm Misuraca and - victoria Brieant, owners and applicants. Assessors Parcel No. 59-131-07 (Resolution). Catron said that this item was last heard on November 9, 1994. At that time, the Commission approved a temporary permit, which will expire on April 15, 1995, to allow the applicant to use the antennas existing on the site and to erect the proposed antenna. TIBURON PLANNING COMMISSION MINUTES OF APRIL 12, 1995 Minutes No. 735 7 ( ( Catron said tha~ the applicant did erect the proposed 45 foot high antenna, but found that it would be too visually obtrusive. The applicant submitted a letter today stating that he is formally withdrawing his application for this antenna. The applicant is now asking the Commission's approval to experiment with different configurations of a dipole antenna in order to find an optimum configuration. staff appreciates the applicant's efforts to work with the Town to achieve a compromise. staff is proposing that the applicant be allowed to use the existing antennas on the site, which do not pose much of an aesthetic impact on the neighborhood, and be allowed to experiment with a dipole antenna for a period of six months. Once an acceptable configuration is found, the applicant would return to the Commission to secure final approval. Catron said that the applicant's neighbors have complained about interference and EMF's from the existing antennas. While staff can deal with aesthetic issues, the neighbors need to work with the FCC on these other matters. Schrier asked Catron if Staff is recommending that the existing antenna stay where it is located. Catron replied that, aesthetically, this is as good as any other location and if it was moved to the other side of the lot, it would stand out more. Greenberg opened the public hearing. Noushin Samgiss, owner of 239 Diviso Street, said that in December of 1994, her family temporarily moved out, and are now renting their house out, due to problems caused by the applicant's antenna. She played a tape demonstrating interference generated from the antenna through their television set. She said that the interference could be heard four to six hours a day. She said that she was the- one who informed the Town that the applicant was operating a HAM radio. She said that she has no objection to his hobby, but she does not want his antenna next to her house. She suggested that he move the antenna to the middle of his property. She said that it would only block his view. She urged the Commission not to extend his temporary permit. There being no one else wishing to speak, the public hearing was closed at 8:42 p.m. Schrier suggested that the Commission not renew the temporary permit until the applicant comes forward. He said that the applicant should be required to submit a new application for the existing antennas and until he does, he cannot operate his HAM radio. The Commission agreed. Catron stated that it is his interpretation that the applicant is applying for the existing TIBURON PLANNING COMMISSION MINUTES OF APRIL 12, 1995 Minutes No. 73S 8 ( ( antenna with this application. In other words, the applicant has the same application he has always had, he is just amending it. Catron stated that Staff has no control over the use, only over the antennas. siewert asked Ms. Samgiss if she ever contacted the FCC. Samgiss said that she called the FCC in Washington D.C. and said that the Town has jurisdiction over interference. Ms. they Anderson stated that the FCC did send their representative out and subsequently prepared a report that was sent to Staff and then forwarded to the Planning Commission. The FCC identified what they think is the problem causing the interference. In no way did they say it is the Town's issue to deal with, as the FCC has jurisdiction over interference. Heckmann asked if there is a valid application for the existing antenna and Catron replied that he is interpreting this to be correct, based on his conversations with the applicant. Greenberg said that the Town may have an application, but what the Commission has before it formally is a resolution that is asking it to approve permanent use of a 31 foot high GAP Challenger high frequency vertical antenna and a Diamond X2200A VHF-UHF vertical antenna; and to allow the applicant to experiment with different "dipole" antenna configurations. She said that the Commission needs more information from the applicant in order to make a decision. She said that she wanted the total configuration before her for approval, not approval piece by piece. Catron suggested that since the applicant is not here, the Commission may want to continue the whole item. Greenberg expressed that she did not want to continue the item. She stated that the letter from the applicant to Staff dated April 12, 1995, withdrawing his application to erect a Gap DX-IV antenna due to its visual obtrusiveness and asking approval to try a long wire antenna, was just received today by the Commission. She was annoyed that the applicant did not have the courtesy to tell Staff that he would not be here tonight. Catron said that the applicant did intend to be here tonight. M/S Schrier/Perlmutter (5-0) to allow the temporary Conditional Use Permit that was granted to expire after April 15, 1995. Greenberg said that Staff should send a letter to the applicant stating that he is not to operate the antenna after the expiration date. Due to the applicant's request today to be allowed to experiment with various dipole configurations and due to his lack of presence TtBURON PLANNING COMMISSION MINUTES OF APRIL 12, 1995 Minutes No. 735 9 ( ( at tonight's meeting to provide further information, the Commission discussed a future meeting date to discuss this item. Catron mentioned that there is a Permit streamlining Act deadline of April 30, 1995, requiring this to be heard at the next Planning Commission meeting. Greenberg asked Staff to have the Town Attorney do research to see if the Permit Streamlining Act still applies, due to the substantive changes to this application. It was moved, seconded and unanimously carried to continue this item to the April 26, 1995, Planning Commission meeting. PUBLIC HEARING Chairman Greenberg suggested that Item 5 be heard next and the Commission agreed. 5. 1 BLACKFIELD DRIVE; CONDITIONAL USE PERMIT TO ADD A 280 SQ. FT. ADDITION TO MILANO' S ITALIAN RESTAURANT. Assessors Parcel No. 34-212-18, Roger Milano, applicant; Edward and Mary Cheu, owners; Mohamad Sadrieh, Architect (Resolution). Catron stated that this is a request by the applicant, Roger Milano, to add a 280 sq. ft. addition to the rear of his restaurant. The addition would be located in the alley behind the restaurant and would be used for storage, a new walk-in freezer, and a garbage and recyclables collection area. The Zoning Ordinance requires Conditional Use Permits for any additions in the Neighborhood Commercial Zone. The Planning Department has recently allowed the applicant to expand into an adjacent tenant space and increase the seating capacity of the restaurant by 12 seats without a Conditional Use Permit. Staff reasoned that the potential parking demand created by the additional 12 seats was offset by the loss of area in the adjacent retail tenant space (the pharmacy). This property is the only property within the Town which is in the Shopping Commercial Land Use Designation which has a .5 FAR limit and the project meets that. However, it is in the Neighborhood Commercial Zone which has the .17 FAR limit and the project would exceed that. staff recommends that the commission consider pursuant to General Plan Policy DT-12 and resolution granting the Conditional Use Permit. a FAR exception adopt the draft Heckmann asked Catron why there is an inconsistency between the FAR limits in the Land Use Designation and the Neighborhood Commercial Zone and Catron replied that it was an oversight in the General Plan. Greenberg asked Catron if this would go before the Design Review Board. He said that Staff is recommending that the Commission waive Design Review. TIBURON PLANNING COMMISSION MINUTES OF APRIL 12, 1995 Minutes No. 735 10 ( ( construction, a geotechnical engineer will review the site and certify the structural integrity of the soils and the pool." * Page 9, the last sentence in the 4th paragraph should read "She said that she wanted the total configuration before her for approval, not approval piece by piece." Heckmann requested the following correction to the April 12, 1995, minutes: * Page 6, the 5th paragraph from the bottom should read "Perlmutter asked Mr. Lang how he would drain the pool, if needed. Mr. Lang replied that it would drain through the storm drains." Schrier requested the following correction to the April 12, 1995, minutes: * Page 7, the 1st sentence in the 4th paragraph should read "Schrier said that the Planning Commission is not bound to approve this application." It was moved and seconded to adopt the minutes of April 12, 1995, as amended. Motion carried 4-0. UNFINISHED BUSINESS I 2. 223 DIVISO STREET: Conditional Use Permit to operate a HAM radio station and install a HAM radio antenna. Malcolm Misuraca and victoria Brieant, owners and applicants. Assessors Parcel No. 59-131-07 (continued from April 12, 1995). (Resolution) Catron said that this item was continued from the April 12, 1995, Planning commission meeting to allow Staff to gather information and to clarify the status of the application, given the withdrawal of the 45 foot tall GAP Voyager DX-IV antenna from the application on April 12, 1995. Catron mentioned that at that meeting, the Commission decided to allow the temporary Conditional Use Permit to let the applicant operate his existing antennas expire after April 15, 1995. Catron stated that the applicant has appealed the April 12, 1995, decision of the Planning Commission. He said that a copy of the appeal has been given to each Commissioner. Catron stated that the application currently consists of: 1. Request for continued use of the existing 31' tall GAP TIBURON PLANNING COMMISSION MINUTES OF APRIL 26, 1995 Minutes No. 736 2 ( ( DX-VIII Challenger antenna and the other smaller VHF antennas existing on the site in their current locations; and, 2. Request for permission to experiment with a dipole antenna, which consists essentially of a long wire. The applicant requests permission to experiment with different configurations of the dipole antenna in order to find an optimum configuration. Once an acceptable configuration is found, the applicant would return to the Commission for approval of a finalized location for the dipole antenna. Staff is recommending that the Town allow the applicant to use up to a 30' structural mast to support the dipole antenna initially in order to see if he can get adequate reception. Staff is very pleased with the applicant's decision to withdraw the GAP Voyager DX-IV from the application. Staff believes that a dipole antenna will be a good compromise between the needs of the applicant and the concerns of the neighbors. Staff believes that the existing 31' tall GAP Challenger antenna has a minimal impact on the neighborhood and views. Staff also believes that the present location is appropriate to minimize visual impacts. Catron mentioned that the Town's technical consultant has acknowledged that this antenna will be of minimal effectiveness in the corning years of low sunspot activity. The applicant is requesting the dipole antenna which will work during periods of low sunspot activity. Staff recommends that the applicant be permitted to experiment with different dipole antenna configurations for a period of 90 days. At the end of the experimentation period, the applicant would return to the Commission with a proposal ,for a permanent configuration. Catron said that the Permit Streamlining Act deadline is April 30, 1995, so the Planning Commission must take action on this project at this meeting or at another meeting held prior to that date. No additional Permit Streamlining Act extensions can be granted. Staff recommends that the Commission take public testimony and adopt the draft resolution which allows the applicant to use the existing antennas on the site, and allows the applicant to experiment with various dipole configurations for a period of 90 days. Schrier asked Catron if the applicant was informed after the April 12, 1995, Planning Commission meeting that he had to take the antenna down after the expiration date of April 15, 1995. Catron TIBURON PLANNING COMMISSION MINUTES OF APRIL 26, 1995 Minutes No. 736 3 ( ( stated that the Commission directed Staff to tell the applicant that he is not to operate the antenna after the expiration date. The Commission only briefly mentioned that the antenna should be taken down if a neighbor complained and none did. Greenberg asked Catron what the applicant was told and he said that the applicant was told that his permit was allowed to expire, and this item was continued to tonight's meeting to allow him to provide additional information. Schrier asked Catron to explain the process for the appeal submitted by the applicant. Catron said that the applicant filed the appeal in the event that it was determined by the Commission that he did not have a proper application and thus he would be left with nothing but a terminated permit. Schrier asked if the appeal would be heard by the Town Council at the next meeting. Catron replied that it would be heard by the Council when it could be agendized. Malcolm Misuraca, applicant, stated that he has -made efforts to compromise. He feels that these efforts have been received well by Staff, but not by the Planning commission. He said that he is a resident of the community who has made a legal application. He stated that he filed the appeal to show where the Commission is off on the wrong foot. Siewert asked Mr. Misuraca if he felt that his lack of attendance at the last meeting would have an effect on the Planning Commission's decision. He replied that he did not. He said that he was ill and he did not think by not attending, he would be taken advantage of by the Commission, who he said proceeded in a very irresponsible way. Heckmann asked Mr. Misuraca about the nature of the dipole antenna mast and if he has a location in mind for the mast. Mr. Misuraca replied that the mast would be made of PVC 'pipe or wood, be approximately 30' in height and about 2" in diameter. He said that the dipole is a wire antenna with the wires extending from either side of a single wire on the mast, would be in an inverted "V" configuration with the two wires being 86' apart. Schrier asked Mr. Misuraca where the least obtrusive location for the mast would be and he replied that it would be next to his house, although it would not operate as well as if it was located out in the open and away from the house. Schrier asked Mr. Misuraca if the smaller antennas he was using before are located in the best location from a visual standpoint versus an operational one. He replied that this type of antenna is a lot less susceptible to location problems as the transmission only has to get to San Francisco, where the repeater station is located. Schrier asked if they could work if they were moved TIBURON PLANNING COMMISSION MINUTES OF APRil 26. 1995 Minutes No. 736 4 . . ( ( against the house and he said that they could. Greenberg asked Mr. Misuraca what he thinks would be the shortest reasonable amount of time he would need to experiment with the dipole antenna. Mr. Misuraca said that two months would probably be sufficient time, but he mentioned that we are at the bottom end of the sunspot cycle, so it is difficult to tell. Schrier asked Mr. Misuraca if the dipole antenna does not work, what would he apply for then and he replied that he would probably ask for the Yagi again, although he knows that it would be visually obtrusive. Schrier asked if the 31' antenna could be moved closer to the house. Mr. Misuraca said that the chicken wire in the lath and plaster of his house would act as a filter for the antenna, and thus would affect its effectiveness. Greenberg opened the public hearing. Noushin Samgiss, owner of 239 Diviso Street, requested that Mr. Misuraca's existing antenna be moved away from her~roperty so that she can move back into her house. She said that she has nothing against his operation. Schrier asked if it is an eyesore for her and she replied that it is not. She is concerned about the possible effects of EMF's on her daughter, whose bedroom is near the antenna. There being no one else wishing to speak, the public hearing was closed at 7:57 p.m. Heckmann has some concern about the nature of the dipole antenna. He said that the mast material is not well defined. He recommends that it be as visually unobtrusive as possible. He said that the mast should be as small in diameter as possible and metal with a dark finish. He feels that the location of the existing 31' antenna is the least obtrusive on the property. He asked that a site plan be done showing the location of the proposed dipole antenna, as the scale on the current plan is too small. . Siewert proposed some clarification of the resolution regarding wavelength versus size of the antenna. She agrees with Heckmann that the mast should be as small as possible and a dark color. Schrier agreed with Heckmann and Siewert about the specifics of the antenna mast, as long as it does not interfere with use. He said that he would like to add a condition that the applicant try other locations on the property for the existing 31' antenna and that he keep a photo log of this. Greenberg said permit for the permit for the that she would prefer to three requested antennas, two existing antennas. issue another temporary rather than a permanent She wanted the Planning TIBURON PLANNING COMMISSION MINUTES OF APRIL 26, 1995 Minutes No. 736 5 ( ( Commission to assess the impacts of the whole proposal, rather than do it piecemeal. Greenberg asked how the Permit streamlining Act would apply in this case. Anderson replied that this is the same application and the applicant has been amending it in response to issues that have been brought forward that were perceived as problems. Anderson said that this is not generally considered grounds for considering this is as whole new application. He said that the applicant is trying to work with the Town to come up with something less obtrusive. Anderson said that one 90 day extension has been given and the Town cannot give any more. Greenberg stated that if the dipole antenna is part of the same application, the Commission does not have enough information to approve it tonight. She said that the application changed radically when an entirely different antenna was requested by the applicant very recently. She said that the Commissioners have not seen it, yet the Commission is under the original timeframe. Anderson said that unless the Commission is going to deny the project, conditional approval needs to be given. .Catron said that whatever restrictions the Commission wants to put on the approval, it should be for the minimal practicable regulation to accomplish the purposes of the Town. The Commission and Staff had an in-depth discussion about this item, whether this is considered one or two applications and the ramifications of approval or denial of the project. Schrier asked Mr. Misuraca to draw a dipole configuration. Mr. Misuraca drew the proposed dipole antenna on a chalkboard and explained the configuration. Siewert feels that the Commission is being put in an awkward position as representatives of the rest of the community, as they never got to see even a representation of the proposed 45 foot antenna. Schrier said that the material difference in this application was that the 45 foot antenna was to replace the 31 foot antenna. Greenberg questions whether the Commissioners really have the same application before them now. Anderson agreed that the application has been amended several times and the Commission has not had an opportunity to visualize different locations in the field. Schrier stated that he would propose to deny the application for the dipole antenna and grant another temporary use permit for 90 days for the existing 31' antenna and the other smaller VHF antennas. He feels that the applicant should submit a new application for the dipole antenna and the Commission could grant a temporary use permit for 90 days to allow the applicant to experiment with the dipole antenna and then return to the Commission for approval of a finalized location. Schrier said that TIBURON PLANNING COMMISSION MINUTES OF APRIL 26, 1995 Minutes No. 736 6 , . ( ( the problems he is having are that he has not seen the dipole antenna in the field and he believes that the applicant's request for a dipole antenna is a new application. Anderson said that if the Commission's reasoning is that this application has been changing so fast and furiously that the Commissioners have not had an opportunity to see what is actually being proposed and analyze it from an aesthetic viewpoint, that would be the basis for denying the application without prejudice for resubmittal. It is the Commission's option to waive the fees. In the meantime, the Commission may want to grant another temporary use permit for the existing antenna. Greenberg pointed out that the application did not move forward quickly because of the inclement weather, because the applicant did not get a chance to test what he initially proposed until very late in the process, and the proposal was meaningfully changed very recently, right up against the Permit streamlining Act deadline. Schrier asked Mr. Misuraca if a new application was approved for the dipole antenna, how long would it take for him.to erect it. He replied that it would probably take a week to prepare it to meet the Commission's requirements and size and color, and to erect it. Schrier asked him it he could use the existing 31' antenna now if he was given permission to use it again and he replied that he could. Catron explained to the Commission how their goals could be achieved by modifying the resolution. The Commission did not support this approach. Anderson mentioned that if a new application is required, it has to be publicly noticed. If Mr. Misuraca turned in a new application immediately, a notice could be published in the I.J. newspaper and this item could heard at the next Planning Commission meeting on May 10, 1995. Schrier asked Staff if the Commission denies the application as submitted, can it grant a temporary use permit for the existing 31' antenna. Anderson replied that if the Commission denies his application, it is no longer valid at all. M/S Siewert/Heckmann (4-0) to deny the Conditional Use Permit application without prejudice, as the application has totally changed and it has changed so recently that there has not been sufficient time for the Commission time to look it. M/S SChrier/Siewert (4-0) to waive the fees for a temporary use permit for the existing antennas if the new application is sUbmitted for a dipole antenna within the next 30 days. TIBURON PLANNING COMMISSION MINUTES Of APRIL 26, 1995 Minutes No. 736 7 > ~':'=<-12-1335 J.3:15 -=RQ"l ~lJ3uPq::~-B;;:IEAr'iT T8 4352433 p.J1 ( \."'N O....,C.E~ OF (J-L'1/Ld MALCOLM A. MISURACA 0$0:- "'''''''~'I:'' $".l:t;~ S.....Tt!. :;''''50 .5M-l FRANCl~CO. CAUFORNIA 94105 (41$; 546-\:430 1~1".l to...,..t;c.... '".~.<:;SlMI...Cl April 12, 1995 Dan Catron Associate Planner Town of Tiburon 11()1 Tiburon Boulevard Tiburon, California 94920 RECEIVED APR 1 2 1995 Re: Assessor's Parcel No, 59-13Hl7 CUP 19310 TOWN OF TI!lUPlQN PLANNINiA A ~WlkIilIN~ gliPT. Dellr Mr. Catron: My wife and I formally withdraw our application to erect a Gap DX-IV antenna at 223 Diviso Street. As your report to the planning commission suggests, we could see as soon as the antenna was erected that it was going to be more visually obtrusive in the neighborhood than we had first thought. COllsequently, we have gone back to the drawing board. We ask the commission's approval to try a long wire antenna, which wilS be erected in the form of an inverted vee. The wire itself is fairly thin copper, and it should be less visible than the aluminum tubing of the Gap. It should be less objectionable than the Gap might have been; the only qu@stion is whether it will work well enough to give us minimal operating conditions considering the sunspot cycle. We can only answer that question by putting it up. EXHIBIT NO. S- . ~~'~-12-19?5 218:17 ;::~Ji'l i'11S'JRHCJ1-B?JE~i'n TO 4352438 P. 02 ( '( DaD Catron April 11, 1995 Page 2 Your suggestion that we erect the antenna and report to the commission whln it has been up and working for a brief time is certainly acceptable. We appreciate your patience. z~ Malcolm A. Misuraca TJT;;,_ p. D2 ., . . ~t\ TOWN OF TIBURON RECEIVED DEe 0 5 1994 MEMORANDUM TOWN OF TIBURON PLANNING & BUILDING DEPT. TO: PLANNING COMMISSION DATE: DECEMBER 5, 1994 FROM: TOWN ATIORNEY SUBJECf: HAM RADIO ANTENNA APPLICATION FOR 223 DIVISO -------------------------------------------------------------------------------------------------------------------------- I have been informed by staff that the Commission would like an update on PRB-l and any cases interpreting that regulation. Of particular interest is what constitutes "reasonable communications" as that term is used in PRB-1. Attached is a copy of a memo sent to the Town Council in October 1992 with th-e operative language from PRB-l and a summary of all cases up to that date. This memo reviews the three cases involving PRB-l which have come out since that memo using the same format. . 1. Brower v. Indian River County Code Enforcement Board (Fla. Cir.Ct 1993) 1993 Westlaw 228785 (unpublished decision). Facts: Brower erected a tower and antenna totalling 95.6 feet in height without seeking approval from the county. The county's zoning ordinance prohibited anything over 70 feet in height. Outcome: The appellate court held that the ordinance was facially invalid because of the absolute height limit. Si~nificance: This case has little significance for us because it simply restates existing law of which the Town was already aware. 2. Evans v. Board of County Commissioners (10th Cir. 1993) 994 F.2d 755. Facts: The same parties were involved in a previous published decision referred to as #9 in the October 1992 memo to the Council. In the previous litigation, the court invalidated the county's ordinance because there it contained an absolute height limit, in this case 35 feet. After the county amended their ordinance, Evans applied again and went through a full hearing process. The county again denied his request for a tower at least 60 feet in height. In denying the application, the county found that Evans' neighborhood featured views of the Rockies, which was one of the primary reasons people purchased there, and that obstructing those views could drive down property values. The county found that there were other ham operators in the neighborhood who worked on 35 foot antennas. Prior to making a final decision, the county proposed a 60 crank up antenna as an alternative but Evans rejected it on the grounds that it would not withstand thc high winds in the area. EXHIBIT NO.~_ . . Outcome: The court of appeal (reversing the trial court) upheld the county's action. In doing so the court of appeal made several interesting rulings. First, they held that PRB- I's requirement to "reasonably accommodate" amateur communications requires more than simply "balancing" the interests of the neighbors with those of the operator (an approach taken by the Fourth Circuit Court of Appeals). The obligation to reasonably accommodate with the minimum practicable regulation clearly weighs in favor of the operator/applicant. Second, the court reiterated that preserving aesthetic views and maintaining property values in the community were legitimate zoning considerations of the county. Because those concerns could not be adequately addressed through screening or the alternatives proposed by Evans and county staff, denial was the "minimum practicable regulation necessary to accomplish their goals." Id. at p. 763. Finally, the court addressed Evans' argument that he needed an antenna over 35 feet in height to effectively communicate. While not set forth in the opinion, it appears that there was evidence in the record before the county as to what level of communications Evans would enjoy at various heights. "Although the County was aware a thirty-five foot tower would not completely meet Evans' legitimate goals, 'the law cannot be that municipalities have no power to restrict antennas to heights below that desired by radio licensees. (Citation omitted)" Id. at p. 762. Shmificance: This case (a copy is attached) does not create any new law but does represent a good discussion of the application of PRB-l based on a full administrative record. The case shows the importance of having a complete record, of examining alternatives and of focussing on how well the antenna will work. It also is a good statement of the importance of local zoning interests. 3. Pentel v. City of Mendota Heights (8th Cir. 1994) 13 F.3d 1261. Facts: Pentel erected a vertical antenna on her roof reaching a height of 56.5 feet from the ground. Using that antenna for two years, she was unable to establish reliable communications in the United States and only one international contact. She then decided to put up a tower which measured 30 feet tall when retracted and 68 feet tall when fully extended. The tower was to be topped with two directional antennas. (See the opinion at p. 1262, footnote 1 for the courts discussion of why the proposed antenna would be more effective.) The city denied her request for this antenna but let her keep her vertical antenna. Outcome: The court of appeal overturned the city's decision. In determining the proper standard of review, the court agreed with the Evans court that "reasonable accommodation" as used in PRB-l requires more than simply balancing the interests of the parties. The court also held that "because there is a direct correlation between an amateur's antenna height and her ability successfully to transmit and reccive radio signals, federal intcrests are furthered when local regulations do not unduly restrict the erection of amateur radio antennas." Id. at p. 1263. . . Turning to the specific facts, one basis for the city's denial of the tower antenna was that Pentel's existing vertical antenna allowed her adequate operation of her station and thus represented a reasonable accommodation. After stating that "what constitutes 'successful' amateur communications is difficult to quantify..." (Id. at p. 1265), the court found that based on the facts in the record, Ms. Pentel could not adequately operate her radio. Also of note, the court noted that the city could not deny the antenna based on interference with neighbors' television and radio reception. Id. at p. 1264. Significance: Again, this case (copy attached) features a good discussion based on a full record. This is the first case of which I am aware in which a vertical antenna is discussed as an alternative to a Yagi. While this court found that the vertical was inadequate in this case, I would emphasize that this is based on the facts developed there . and is not a universal rule. These cases do not establish any clear cut rules regarding reasonable accommodation and it is unlikely that any case ever will given the underlying attempt to reconcile competing interests. However, it is possible to state (or re-state) several key points: -the Town must reasonably accommodate amateur radio communications through the minimum practicable regulations necessary to accomplish our legitimate goals. This does not mean a simple balancing of the Town's goals and those of the applicant, but rather that we work towards reasonable accommodation. -the Commission's decision must be based on a fact specific inquiry. -our legitimate goals include aesthetics, safety, preservation of property values. -the Town need not allow the applicant everything they want in terms of operational ability so long as there is reasonable accommodation. -the Town must explore all viable options, both in terms of height, location, screening ~~~~~ . I hope that this information is of help as you review this application. If I can be of further assistance, please feel free to contact me. ~.~ Robert B. Ewing ? cc: Planning Staff Applicant . . TOWN OF TIBURON MEMORANDUM TO: TOWN COUNCIL DATE: OCTOBER 19, 1992 FROM: TOWN ATTORNEY SUBJECT: HAM RADIO ANTENNA APPLICATION ------------------------------------------------------------------------------------------------------------------------ During the public hearing on October 7, 1992, regarding the Burnham application for a ham radio antenna, references were made to PRB-l (the FCC's ruling) and subsequent court decisions. Vice-Mayor Friedman requested copies of these decisions. If any other councilmember would like these coptes, please let me know. I have also prepared this summary of all cases for those who do not wish to read the actual decisions. My focus is on what is "reasonable communications" as described by the FCC. A. FCC Rutin!!: and Re~lations FCC Ruling PRB-l was issued on September 19, 1985. The American Radio Relay League had requested a complete preemption of all local ordinances "which preclude or significantly inhibit effective reliable amateur radio communications." The FCC did not go that far in its ruling. The most important part of the ruling is Paragraph 25 which reads as follows: "Because amateur station communications are only as effective as the antennas employed, antenna height restrictions directly affect the effectiveness of amateur communications. Some amateur antenna configurations require more substantial installations that others if they are to provide the amateur operator with the communications that he/she desires to engage in. For example, an antenna array for international amateur communications will differ from an antenna used to contact other amateur operators at shorter distances. We will not, however, specify any particular height limitation below which a local government may not regulate, nor will we suggest the precise language that must be contained in local ordinances, such as mechanisms for special exceptions, variances, or conditional use permits. Nevertheless, local regulations which involve placement, screening, or height of antennas based on health, safety, or aesthetic considerations must be crafted to accommodate reasonably amateur communications, and to represent the minimum practicable regulation to accomplish the local authority's legitimate purpose." 1 . . This limited preemption was also incorporated into the FCC's regulations at 47 CFR S97.15(e). B. Caselaw While there are cases involving antennas prior to PRB-I, they are of limited relevance in light of the FCC ruling and I have not researched them. I have also excluded cases dealing with private CC&R's because those present a separate issue. The following list represents every decision involving PRB-l which I can find including some which are not published. 1. Themes v. City of Lakeside Park (6th Cir.1986) 779 F.2d 1187 (also subsequent unpublished district court ruling) Facts: Themes sought a permit to erect a 73 foot high tower with two Yagi antennas on top (one at 65 feet and one at 73 feet) with a radius of 24 feet. At the time of his application, the city's zoning ordinance prohibited all radio towers. During the course of the litigation the ordinance was amended to allow antennas of no greater than 50 feet in height and 8 feet horizontal. Outcome: Themes' application and the first trial court decision (in city's favor) were before PRB-I. The court of appeal remanded for trial court to reconsider in light of PRB-I. On remand, the district court ordered city to allow Themes to erect his proposed antenna. Significance: This is the case which Mr. Burnham says guarantees a right to a 65 foot high tower. This is not true. On remand the district court said that it was convinced that in that case Themes' "interests in engaging in effective national and worldwide amateur radio communications requires antennas supported at a height of sixty-five (65) feet." This does not create an across the board rule of law as made clear in subsequent cases. 2. Bodony v. Incorporated Village of Sands Point (ED. New York 1987) 681 F.Supp.1009 . . Facts: Bodony applied for a building permit and variance for an antenna 86 feet high when extended which would retract to 23 feet when not in use (no information regarding horizontal element). The city denied the permits based on a 25 foot height limit in the ordinance. The city made findings that other ham operators in the city were able to operate with antennas less than 25 feet. Bodony presented evidence that 60 to 70 feet was necessary for "good" reception even under ideal atmospheric conditions. Outcome: The court invalidated the city's ordinance because its maximum height limit was preempted by PRB-1. The court also said that the city's decision was invalid because it failed to make a "reasonable accommodation" between thc two sides. 2 .. . Significance: The neighbors, aesthetics, etc. record. court said that the city made no findings about impacts on Thus, whatever we do must be based on a strong evidentiary 3. Bulchis v. City of Edmonds (W.D.Washington 1987) 671 F.Supp.1270 Facts: Bulchis applied for and was denied a use permit to erect an antenna which would be 70 feet when fully extended and 21.5 feet when retracted. The City's zoning ordinance required a use permit for any antenna over 25 feet in height. Outcome: The court held that the use permit requirement on its face was legal but it had been applied improperly. The matter was sent back to the City Council to review again. Significance: The City had found that the tower would be an "aesthetic blight" and that Bulchis had not shown a "public necessity" for a 70 foot antenna. The court's ruling is vague, but it appears the city should have looked at more alternatives and justifications for a 70 foot height. Also, the applicant did not need to show that his antenna would be a "public necessity." 4. Howard v. Burlingame (N.D. Ca1.1988) 1988 Westlaw 16907 (unpublished decision); 726 F.Supp.770 (1989); and 937 F.2d 1376 (9th Cir.1991) Facts: Howard applied for and was denied a use permit for an antenna which was 51 feet high when fully extended and 21 feet high when retracted with a horizontal element 24 feet long. Howard had an existing 23 foot antenna which by his testimony allowed some long distance communication but operated at only 2-10% capability of the applied for antenna. Outcome: The district court held that the city council did not attempt to reasonably accommodate the federal interests protected by PRB-l and sent the matter back to the city which then approved the 51 foot antenna. The published district court opinion and court of appeals decision deal primarily with attorneys fees. Shmificance: The district court said that the city failed to look at various compromise alternatives such as limits on hours of use, screening or a lower height than 51 feet. In footnotes, the court said that the city might need to obtain expert advice on how reasonable some of its alternatives were. The court of appeal noted that some or all of those costs could be imposed on applicants as in other land use applications. We have used this to defend Mr. Burnham's contention that he should not pay for story poles or even the use permit. We did pay for our consultant, Norm Wilson, because at that time Burnham. and Don Batten on his behalf, had presented technical evidence which we could not rebut without help. 3 . . 5. Williams v. City of Columbia (D. South Carolina 1989) 707 F.Supp.207 and 906 F.2d 949 Facts: Williams applied for and was denied a variance for an antenna which was 55- 65 feet high when fully extended and 23 feet when retracted. Outcome: The trial court found that neither Williams nor the city had considered PRB-l during the application and thus remanded the case to the city for rehearing. The city reconsidered the application and again denied it in light of PRB-l. The district court and court of appeals upheld this denial. Significance: This is the only case since PRB-l upholding a city's denial of a variance or use permit for an antenna. The court of appeal found that the city had made efforts at compromise through various conditions (such as nighttime use only) but that Williams had refused all compromises. PRB-l requires compromise on both sides. In our case Mr. Burnham has agreed to various mitigations and compromises so Williams may be of limited value. 6. People v. Krimko (1989) 548 N.Y. Supp.2d 615 Facts: Krimko installed a ham antenna, without permits, which was taller than allowed by the zoning ordinance. He was criminally prosecuted for this violation. Outcome: Krimko moved to dismiss the complaint alleging that the zoning ordinance was facially invalid in the face of PRB-l. The court rejected his argument. Significance: None to our case. 7. City of Novato v. Norman (Marin Superior Court 1989; Court of Appeal, 1990) Facts: Norman applied for and was granted a use permit for a 50 foot high antenna (no specification was made as ato the horizontal elements) In spite of the approval, Norman then went ahead and put up a 79 foot high tower with three horizontal elements 64 feet long. In addition, he mounted four 30 foot long horizontal elements somewhat below the top in a different location than appraoved. The city then held new hearings and somewhat modified the original conditions of approval. When Norman failed to comply with the new conditions, the city went to court for a nuisance abatement. Outcome: At trial, the judge first ordered both sides to go back for another council hearing. Norman was told to submit information on waht he needed for "reasonable communications" for consideration by the Council. Norman submitted a plan which the Council found was worse than his existing illegal use. The Council then determined that reasonable worldwise communications could be accomplished with a 40 foot high mast and 4 . . horizointal elements not exceeding 35 feet in length. Both the Superior Court and Court of Appeal found that the Council's action complied with PRB-I. Significance: The main significance is that this is a local case. The case also shows that the Town can put the burden on applicants to show what is necessary for "reasonable" reception. 8. MacMillan v. City of Rocky River (N.D. Ohio 1990) 748 F. Supp. 1241 Facts: MacMillan applied for a building permit to erect a thirty foot high radio antenna. His application was denied because it exceeded the maximum height and because it would "result in a substantial impairment of neighboring real estate values..." according to the city. Outcome: The court found tnat the city had not adequately considered PRB-1 or MacMillan's need for "adequate" communications. The case was sent back to the city to reconsider. Significance: The court said that the zoning administrator let "concerns over property values and neighbors' protests" predominate the decision without concern for PRB-l's federal interests of reasonable communications. 9. Evans v. Board of County Commissioners (D. Colorado 1990) 752 F.Supp. 973 Facts: Evans applied for and was denied a permit (and variance) to erect a 125 foot high antenna. That denial was litigated and the county won. Evans then applied for a 60- 100 foot high antenna which did not require a variance. This application was also denied. Outcome: The court found that the county's zoning ordinance established a maximum height of 35 feet with no allowance for going above that height which was facially invalid in light of PRB-I. Si2:nificance: None to our case because our ordinance is different than the one in this case. 10. Goldberg v. Charter Township of West Bloomfield (6th Cir.1990) 922 F.2d 841 (unpublished Disposition, text in Westlaw) Facts: Goldberg was denied a building permit for his antenna because he had failed to apply for a necessary zoning variance. The variance was required not for height, but because he wanted to erect the antenna on a vacant lot. Outcome: The court held that the Town's ordinance was valid on its face and that 5 I - . . because he had failed to apply for a variance, his as applied challenge was premature. Significance: This case shows that applicants must go through the entire zoning process even where PRB-l is an issue. Mr. Burnham has threatened at various times to go to court because the Town is being unreasonable. This case (although it cannot be cited as precedent) shows he cannot do that. C. Conclusions . I draw the following conclusions from these cases: · While in theory a city can deny a ham operator any antenna this is likely to be upheld only if the applicant refuses to cooperate or compromise. The attitude of the courts seems to be that there is always some reasonable accommodation which can be reached and you should keep trying until you find it. 4 · The courts recognize the importance of local zoning concerns including aesthetics, but also require compromise with the communications aspects. · Our ordinance is facially valid and thus could only be challenged on an as- applied basis. · Because the FCC refuses to set nurnmum standards, instead of using a reasonable standard, the courts will look at each case on its individual facts. None of these cases establish any standards as to what is reasonable. · While Burnham's license issued by the FCC authorizes worldwide communica- tions, it does not appear that we need to grant unfettered worldwide communications 24 hours a day, 365 days per year. · The question of a smaller antenna or shorter tower or mast is a difficult one to resolve. Our independent consultant has said that a smaller antenna wiII not give reasonable communications to Mr. Burnham. We may need to speak to someone else on this but we already have something of a record on this. Robert 13. Ewing leak 6 j' . ~:V,\NS v. BO,\IW OF COllNTY COM'RS t:1l~iI~994 r.2d 7!1!'i (I0lhUr. 19931 )" to facilitale hi:- ohservation:-. then :-t1ch HC'- tiom; mig-ht <'On:-;titutp. a sf'an'h. S(',' .I1t'i:mw v. Ilieh. 4Xfl II.S. :l~1. :l~~. 1fl7 S.('I, 1 H!l, llr,I),!Jt1 L.Ed.:::d :1'i711!IS7) ("A truly ('lIrsor,Y in~p,'dilln--otl(' Owl irl\'lllvC's ITu'r.,I.v 1"llkillj.( nt what io.; all'f':ul,v l'XIUIl'lf'd 10 vll'w, will/fw' d;,'llurllillf' if "i.'l 1I0t. II 'Hf':lI'l'h' rill" Fuul'lh ^uu'nrlllll'lIt 'llll'IUI~l'~," (1';IIlI,lla~i~ mill. 'II I), In I.his in:o:lal1(,f', AJ{pnt I'l'lla ollsl'1"\11'1I Hnly what was in pl:dn vif'w, CI":lwlin,l{ undr:r the vehicle difl not !-\ignifi- cantly add to the intrm:ivenf'f's of thp routine Chpc!{pflint stop_ Aj.!<,nt rena's cr)THhlct \\'llf' no mfll"t' inl,rll~ivp than if hf' had qucstionNi the App('lIc('s concf'rning the :-;uspiriolls cir- curnstan('ps. The insPN'tion of till' vphicl("s under,.arriag(' ]ast('{1 It'ss than two minl1te~ ;:md did not invo]\'(" moJ'{' inll'u:;ivr', tin1l'- ('on~t1mil1l! ml':l~lIn'S ~Ilrh as pullin~! t11(' ('lIr nn a Iif't. III ohtain a lu,uf'!' \'il'w, Thf~ Appdlc'l's tlI'J.!"f' that !ll(' 11:-;(' ur 11 na:-;h- light and mirror to inspect the undercarriage constituted a search. We rlisagree. "[Tlhe use of artifirial m~ans to illuminate a dark- cnf'r] area :-;imply clops not cnm:titutc a sf'arrh, and thus triggers no Fourth Amencl- mpnt pl'otl'C'tiOIl." llJ'flwn, .1lill ".s, at. 7,tn, 1/1:1 S.f ~L HI, Jri12. Cflll,"(pqnl'nt.ly, Agt'nt I'l'lla\ 11:-;(' or a nashliJ.!ht did tlot. transform his oh:-l'rv:lt.ion~ into an lInrC':lSlIllahlf' span'li within tilt' 1Hf':tlliTll( of Uu' FOllrth Anll'lHl- ment. Ulld,.cl Slrfl/::'! I'. [hum, 4HO U.S. 2~11, 30,.. 107 S.Ct. 1134. 1141, !14 L.Ed.2d 326 (1!)R7); Unmm, 4fiO U.S. at 7:m-<IO, lOa S.Ct. at 1M2, Likc\\;sc. we find Ag-ent Pena'1' use of a min'or to rcn0ct and direct the llash- liJ.!"ht's !H':un did not. hy itself, constitute a !':careh as the min'''r wm, simpl~' used as an artifirial mf'HnS of optiral l'nh:IIH'('lllcnt. Our holding- that Ag-I'nt. rl'n:l'S inspc'c,tioll of thf' vehicle's 11lH!i'rrarri;q.!f' did not ('llnsti. tuf,' a ~/':lI'f'h i~ ('lJnSi~'f'nt with llllifrd ......'flll,'.'l r'. !','in', W;!I F,:!d ,~Ol (!ilh Cit'_l~l~!ll. In Pril'f" hurdr'l' p:drlll :lj.!t'nts noticcd hul'll m:lrk~ :tnrl han' :-;tl'pl at till' ('o!'nf'rs of a tnld\ h('d in a \'phil']p "ptaill/'lI at sN'OTulary ;n~pf'l'!inlt, !d. al .-.;0:1. Thf' :l~~/'Tlts 10nl((,1I lIndl.r Ihl' v"hid" :Ind oh~"I'\-'I'd wlllll HI'- 1'1':11"1'11 III Ill' :I qflra~~" l'nrnpal'tIlH'IlI, All :WI'11l fltt'n ITawll'd IIl1d,'1' tIll' \'{'hit,II', III I.! wil h tIll' :lid 1'1' :l l111...ldi,[llt, 111l11wr] illlll :1 ~m:lllIHI].' in till' ('nmll:lrllrwlll :lllclllllsl'n'l'tl ~ wrapping tap~, A ~Ilhs('qtl('nt f'('arch nf the C'ompnrtlllPnt nnf'ovl'rf'c1 Imndi<'~ of clll'ninr 1\"'''I'I,,'d in tllp". Th~ Fifth (,i,'rlllt f"IlI'~ the' :lg't'nt's ohst',"yal iOII!" unde!" thp tnlC'k \\'('I"P P:l1" nf n valid \'iS1WI ln~p('d.lfln Rnd 1//11'(' Illl' 'lillf!l'11 l'IIIlIJI:ll'llllf'lll Wll~ (11~(,fl\'1'1" I,d. lIu' :IJ~I'I1I~ luullll'uhllhl.. "llll~l' III fOl'nrt'li iI. /d, III Hlil. III SIl"IIlJ:lI'~", lhl' AJlpl'lIt,f'~ W('I'(' nflt ,I(,~ t.air]{'d :It t ht' sf'l'ollllnr.v il1~J>(,l:lilln IIrr>R ill violation of theil' (o'olllih AlllPndml'llt right:-l but in~tearl were hl\\full.v refC'rred tn ~l'rond. ary during the conr!':{' of rt roul illC' ('hf'ckpnint stop, .. Furthermore>, Agent Pena'R examina- tion flf the v['hil'lr's unt!<'I'C':lITiag'e did not ('nn~tit,ut(' a !-:l'l'll'l'h ami thus did not vinlah~ tht' Appdlef's' F011l'th Al1lcndn\('nt ,"ight.". Hincf' tlll'll' is no nhjrdioll to pithl'l" thp runinp inslH'rtion or thp St'l\1'rh or tlu' hidtll'll ('omp:u'tlll(,I'II, W(I fill not nddn'ss lht'sc i:'l. !'UP!-l, We REVEI1SE the di,trirt court and RE- MAND for further proceedings consi::tl'nt with thi:- opinion. . o lHY"lIli'l"I"Si'SHM D.R. EVANS. Plaintiff-AppellEe. V. nOAIW OF COUNTY CO~DIISSIOI'iERS OF TilE COUNTY OF BOULDER, COLORADO; r.ary (;cHlrll'II, in his ca. pacity as Chil'f BuildinJ{ Ofrkinl, Dl'frn. danis-Appellants. No. ~2-1021. (Jnitf'd ~tllt('," Court of Appt'lIls, Tf'nth ('ireuil. M ay ~.~, 1 !)!)~. AIrI:ttl'llt' limn radio 1I111'l'alol' l'Imlll'IWt'd l'llUlll,\' hn:u-d nf t'nlllllli."s;IIIlf'r~' dl'l1i:t1l1f "(Pl" ('i1l111~:f' IlI'I'llll1 fHr :1Il1,'1I1l11 IIIW"I', Till"' 1'lIil. I'll ,<';t:ll.,~ Ili,,1,.id ('11111"1 (,,,, 1111' I)i~lrit'\ flf ('Idllr:nln, :--;111'1'111:111 (;, hl1l'sih'l'I", ('hid 7!'i!'i '" ',. t '. . . 991 FIWEJL\L UEI'OltTEU, td SEIUES ~~-',: 'j ,-' ',' G\t1:~), 1'1' ;;'., -i~'{('P d~"v;" li,!t~f1 f:I!'iS,,~U ;~~fA i~"1;;_{ :~'/t:.tl!- '1~1*.,'t.~ :~li~ !~{j.~:';'; h,,',f~'; ~~ttf;t; ~~~(!;: i:fb' '~~~; ,. ..l.lt' .'." (M~~"~,'ltI~''''II.lt:~~~~iJi,\lj' ,,:~. '. ~, ~~., ....~" ,,', ~~W,~!.\,,),,:';' .;'~'n,':<;';;'j'..,,':'~ .~ ' '!tf~l]~,J;m~Wh:,... ;~It~~~::f;'j\~~J \:~~.~,~r~f~.;Jl~i.t[J(}f,~~~,:~.~~W~~(.~'f~ ;:'~~.:t ~!;.r~-:{~i) fi'.~.!i~ :~.:.J+!~~~ ~\-:Vi~r;r::~);1}!:_~i 4; .~:~,~t;(~:~.~~~~~.;.j'{;':",~: ;;';~: ~~'1~:). :~l~,. . ,)..~j,(-~,tt.., 1 >15~!'J~.I.~J"!~-~; ;.~'.'.' \~;J _'..:tu~rr~''''!'q~>.'t ; IIi: "'1I';{'" j:~,-- ''''-::,!''',STJ: J~I:'~':;'I>-'1~~',t~"r' ".f: 'j" ,.;,;....,~ ,:\' .i~""Y\,;_"~"'''''JA~l'', \~t.\i/..,~ .;, :.' <;', ,~. ,.;~ .~.' ,'-, <~t ,':;, ';,','.'_ ":',.1 ~~ii1ffr ;~~~fJ,~~~~~t~'r>t,1;~: !i~~t.~},\.",'~~1n~~~.-;ti~1~;~11~~1~!1~~f,~.;kl>.ir,~~~~~~~:~ls~'I.~~!~~~~.-~itZ~.~f$;i:tr~.~b1nf,~ti;~(}~r;1i;b~~~~~.',~.i0q~~Brl':'.;';.~~;'~j).~:i~~f);; [~;~;';,-~'~,,~'~~~~~~,~~~~' ';:\.v~;<~" ':;;'W''4:.1:'" ..~ .;"".:i,1f~j"...~~P;\:~~"f."'~ 't';""l j>:-~I... '"-,,,-;:~.'-' '0"" '1~1O' .'o!'r.'J:.I T"~,!.: .'t.'.' ,,. )I'\~ ~J"''';'' ~:~J':q ;r:: -':f'~'" ''''j,.' ~" . \ -~,'. '1, . :i';,....(;{1't1l..~": -lti.~,. ~~ ~!.~~, ~!.,l~~~."^: ~ '$~;~;~~'f1';{l\'f~;f~ ,~-~~>~:'"': ,t2~~ J\:~'fJ;:'.r~:1~' "t,.'i.i~~t "~ (.t-r~:.;7'~~I~:~ j,~~,4~~,r}'fJ:J.~~;f~!~, /".r;, ,/:' .~., ,.\"-;!:.;, ~,;:,;,,~,~"!tj.t'-:':,~":\~l;.i~'.:'~~'"~ . 75(; ~ { ~ -:, ~ ,,, .hlllgl', ~T;llllc'd ~Ullllllar'y judg-IIIl'lll 1'111' IIl1t'r. .\tol'. Huard appt'ail'd, Till' Cuurt or Ap- Jll'"b, Urnrlly, Cin'uil ,JUdg-I', IH'ld lhill dl'l'i- ~iull limiting' Ill'ig:ht uf OI'l.'n.ltUI"~ allh'ullu tuWl'1' to :If) fl.'l't WiI:-i Hut I'n't~lllpll-d liy Ft'll- el'ul COllllllUllil.'alilllLS CUlIlIlIis:-iiulI (FCC) ur- d~l'. Hcvcr.seu. ~:!, ,'. ,'.l' J. ZuninK and PlanninK <?I-' lllllh!1' Ft'tlt'l'al COllllllllllil'alhllls COIIl- missioll <F('(') 'rcg-ulatiulls tWltt'ming .1Iua- tl'ur ham radiu Upl~l'atUl's, zolling authuritit's IlIUSt I'l'i.\sunahly ul'l'omnlo<latc amatcur l.'H111- IlUlllkations, )o{'all'l'gulatiolls should b{~ mini- IIIUlIl pr;ll'lkallll' in Ul'dl'f' to ;U'{'olllplish ZUlI- ing- aUllull"ity's ll>g-itilllall~ pUl'pOSt'S, ltK'al au- thOl'itic:-i m~IY nol altogether preclude ama- teur tUlllmuni{'utiullS anti rJ(~c has explil'itly c1l'tlillt'd to I'Ch'1llatl' spel'ifit pt'nllissiule Ill'il-!-'hts 1'01' illllt.>lIl1i1 tll\\'I'l"S. 1;-" ..7..,::.... ,i'. {j.:";./j ;h::~?~ ':~',-;::,~. . - ~'.'_:" -~;:.'> .~:~:,:;',~~:- j~:~:~(r' i;'~~:,; ":; ~-;;:' ~;, \~ ~;. " . :,p.."'-, ~ :,:~ic;,'~ j ,~_' ':~," - , f::.;.~'::~' ~~N;.I, '-S(~~,!,.,:~; :.J., Fl'tlt'rlll ('uurts o-.:-'77li (:uurt lIt' AI1Ilt'<.ds I't'vicws tli:-ilJ'it:ll'oul'l's j.:Tillll uf :-illllllllill'Y .illd~lllt'llt tit' 1111\11, 3. Fl'tll'n.tl <. 'uurt:; c=->77ti CUlII't uf Appc,ds g-iVI'S 1111 dckl'CJll'C ttl distril't ('utirt's prl'cmption dctl'rOliu~ltiun and examines issue as if it was silting a~ trial court in lil'Sl iHslafll:e, 4. Slall's C::=:>IS.:J Pl't'l'lnptloll ilIa)' tltTllr ill allY nm' of ..It Icast fuul' si!u<.tlillll:-i: (Ill'~pn'ss JU'I.'CllLplioll, whkh I'l':;uib Whl'll Congn':-is expresses 1.leal' intent tu Jln~l'llIpl ;-;lalt, lim; (~) illlJllicd Jln'. t'lllpliulI. which 1'l':'>lllb wilt'lI ;-;(01((' law :-itilwb UI'; ohstud" lo ill't'llllLpli:-illllll'lll ;.tud eXl'l'utiull of full (lurpus<':-i and nbjL'l'livcs of Congress; (al cuntlid !In'cllljltiull, whit'h results frulIl al'lUitll'unl1id itdwl'en ft'deral illlll st'-ltL' law t'\'L'lI (lLuugh ('ungrl'~s is :-iill,t1(; alld (.1) field pl't'I'lllpliull, whit'll n':-.ult;-; frum dl'll'l'I11ill;l- lioll lli;tl ('ullr,rl':'>s illklldt'd III J't'llIU\I' Vlltll'L' KIIII.!,"'1 fnllll ...;Iillt' rt'i-.',llbllll)' ilutlllll'1lY, tl.~.(',.-\. l'\lIl,"1. '\1'1. Ii, d. ~, ;). Slall':-i ~IS.~t J'I't'l'lllpliull 111,1)' t'll IIY rcclcl';d dgt'lIl')' Ils l'UJlgn':-.SI11Ildll,\ U,S.C.A. l\lllsL. Art. I't';-.llll 1'1'1I111 ;Idhlll t;d\ adlllg \\'lllllJl :-'{'lJpt' ()f ddt'J..:aLl'd ;lutlilJ!"lly. Ii, d.:!. 6. Z(lllill~ untl Plunnill~ <?ll Ht't'all:">l' "'I'IIPl'lIl (:Olllflllllllt'al illll:-l (~Olll' mis:">ioll (FC'{:) l!xplicit.ly dedlllt'd lo n'g'ulate heig-hl of I'mliu ant{'llllil t1JWl~rS, :-iu('!l re~:IlI;I. tillll rests with lontl zoning- authorilies 11I'0- vided they reasonably ac{'ommodate amateur cornmunkations y,;th minimum pra(:tieahlt~ ..egul~\tion nec{'~sary to ac('omf,li:-ih th(~ir pur. poses, 7, Zuning and ('Ianning ~l)lI~ In rt'\'iewillg: local land u:->e l'eg-ulatiulIS uf alllatelu' nulio antenna luwers, revil'\\-'ill~ court should apply two-part allaly~is, lil'st, CllUl't ShlJuhl cxumille a'JIJlil'ul,le reh'1JI'-lliun:; tll dl:lerllline if thcy uJ't~ fiH'ially euusisLent with Federal CUlIlllluuieatiulls CUllIWissioll (FCC) regulatiull amI sel.:onu, rcviey.;ng court should examine decision of local board to determine if local bIJard's apl'lieatiun of 1'l').:'lIlations is IH't'emllted IIY F(:(: l't'J.(ulalioll. 11.:--1,( ',f', ('011:-;1. Art. ii, 1'1, ~. H, Adlllinistruti\'c I.aw and Prm:cdurc <>.l!lti Fcdl'rall'UUl'l:-i should givl.' pn~dusive d- fcrL lu rad-filldin~ of state 01' lu('al Utllllillis. lrativc triLunals. 9. Zoning aOlI Plallnil1~ <>7Ur; III .H,tiun l'halllm~,,';ng" denial uf special U...;I' /l1'm1lL for anlt~llIl.\ towel', Ui:-;ll'il'L Cuurt's I't'jl'dioll of Cuullty Huard of Com- missitllll~rS' factu<lJ 1'1){l{'!usion w<.\s improper, HI. ZuninK and I'laHnillK (::;lIt CuulIly BoaI'd uf CUllllllissiuIll.'I:S Illildl.' etTul'b to n~asul1ably .lcl.'lJlI\mudate ham radio Iljll.'ratul"s arnall'lIr tOlrllllunil'atiuns utilizing rnillilllUllI IJl'ildil:<lbll' n'g'ul;ltiIJlI and, tbus, 111"'1'11'... dl'l'i:-.illll lilllitillg- 1lt'I!-:hllJf u[JI'l'alur':-. ;Ulll'llll<l Ill\\t'l' tll :;tj fn'l \\;1.., IIl!1 Iln'I'lllpll'd II,\' 1,'I.,lt-ral ('IlI11IIl11llh';dillll:-' ('1l1l111L1,","1ll1l':-; (i-'( '( 'J n'!-:lJ!;{[lllll; l!1'lll;1! or 1"'rIllll. f()r 101111'1' tll\\l'r ,lnt,1' l'\'alll:LlIllll uf llpUlIll:, :uld ('!t'ai' l'llll:,jdl'riltlllll (If t'1,11'\dld t'\idl'II1'I' \\;\:' "1'1,,\. :'>lJlldl,ll' ;(l'{'()lllllllllbtJIIIl," 11L1~lId\ Iq..:ltllll,lt1' IIUl'J'IL...C::. \\'I~n' tu I,n.:-t'nl' ;ll.....llll.tll. \II'W:-, alld 1I1;tllll;llll pl'lIpl'J't)' \ ;dw'...; ;IlHI IlI!.trd tko- ll.'rullIH'd that jJfUPIN'd .dkrll:ltl\l':-; \\lIldd I I. I EVANS v. BOA,m Of' COlINTY ('O~I'IIS Cllt H~ <f94 I'.ld 7~!' (111_" Ur. 19"1.\1 {T.Re.A. (:nnsL Art. nff/'l'H I thi~ ('a~f'. ,. Fil':-;l {If HII. Ilnlllflc'r ('ounty III gNIf'l'ill i~ :10 llnll~11:11 ('nllnh' he('au~l' it has an unusual palln;'nmic mountain \;('\1,". And II lot of I hl' r)('opl(' who IiVl' in IlOllldfll' :m' very ('oll{,l'l'n"d with thp vip\\" fWllplp that Ih'e nn th~' :::.Iol'f' /If Davidsnn !\1t'sa looldllj.! to tllp \\'('~t have :1 \'icw whieh is prohnhly Ollf' (If tlu' W'l'atpst vi{'ws on tlw pastern slop(~ .. people. huy in that aI'PH 11('('l\USe of the view. This is nne of thc' important consid. erations of li,..ing- ill that <tt"('a ... where people bu:-.' lots f01' thf' vipw in such an area as this npighhrll"hond. df'vnlu:1tinn flf "propl'rty mllY Ot'{'1IJ' wilt",p tIll' vie'\!" ill'lull!. Iy is :Ifrl'f'lf'tl. III Of'dp!" 'n IlrI'S('I'\'f' Ihl' \'il'\\'N t'1\;nYI'd hy I"I'sidl'lltS, lIu' ('1I111l1,\' illll'll<"(P~ II gol'lil'l'lIl hl'i~~hl lilllil:llillll IIf flliI'I.\' !in' li''''I 1'III'slnH'- 1111"'.'1, Till' IIl'i~rht Iillli1:.llpll P"I'I,lul1l''' I.~\' ltll~ 1'1'11111 1'/l/lll1l1'lill.1{ Ihl' ":lfli/l 1'II11l11l111lit':I. litlns Ill' dl'sin's, I':\":IIIS, a highly '1u:llilit,tl ham rmlio IlpPl':llnr, SI'ph l/l ('lIlnluel allla. h'tn' ";Hlill l'"s.C'ardl, pl'fI\'idl' C'I111'I',l!f'llI',r l'OIll- mllnil'aflnns.. and I'I1J..!'a~f' in illl('J'('lllllirlt'lIlal {'(Jnlll1\lIlil'aliHI1~ ill (1I'1It'I' In ftl~tt'I' intf'I'I1:I' t.inn;1i ,l!lJnd will. Thl' radio l'xpC'rls agTl'{'d th..t limiting E\';lIIs In ;l lhirly.lin' fnul ;111. 1('llI1a IIl\\'l'I' W/luld sij!llilit';lnlly impair J.;\,. :IllS' ahilily 10 at'I'llIllJlIi:.;h hi... If'/...;Iilllalr' plll'- pIISf'S. Allh/lllgh 11ll' ("flllll,\' ('/llH'I'llt'll Ihi..: poinl, it, ('nnll'lId~'d ullll'l' :lm:lll'llI'S ill 1lH' :U'C':\ ....u{'{'('ssfully ('ondnct SOIlH' ('ommllni(';]- tion~ with thirty-fi\'e foot untcnll:ls. Add i- tionall~'. nrighhorhooc! rl'~idl'nts flt'{'s('nt('d a ~tl'ong intr-t.('sf. in Ol<lintaining- the ~t:ltll~ qlln. TIIl'Y f'XIII'PSSflll ('lll]('l'I'n lllat 111l' ('I'f'rtillll Iff a lar~~t' Ill"lal :lI1II'TlIJ:l 10\\'1'1' would 11111 I'llly itlll'rfl'I'I' witl. lIlt, ~llfH.1'I1 :lI,,,!IH'lk \'il'\\" 111,..'1 1'lIjH.\'I'r/. hut wtl1lld :d"o dl'\':d1l:11C' Ihl'i,' tll'of"'l'ly. r-:\'all~ Iwlin'l'd hi' ~'lllild :dll'l'i:lll' Ifll' prHhll'ln II.\, ':1""'l'llil1l', Illl' 111\\'1'" \l'llh I"('I's. Ih'"pill' !-:\';ltl:';' l'llllll11ilnll'rd III pl:ln! ~Ofl 11'1'1'" 1111 hi:.; fWlqu'1'ly. Ill!' In'l"": \ln1l1t! not hi' of .":llflil'j{'!ll lH'il'l1t to :,,{'I"'1'11 thl' prnpllc;t'd tmH'!" I'll/' ;ll Il':I"t ll'n .\'l':ll":". / '-" n- Ip not nllt'viat.e l)f'ohlt~m, fl, d, 2. St.'C pllhlicaHon Words and Phrases for olher judicial constrllctio"" and dl'r- initiOlI.... :1' n. " .1(> 11. Zonin~ nnd Planl1in~ ~fio6 In r1ptcI'miningo whpther county, utilize'd minimum practicable I"c~rulation in arlclrp:;;~- ing- ham radio operator':;; proposal for anten- na towel', reviewing- court ~hollld examine whether county explored alternativcs to blan. kel denial of application, r. 'l~ 1~ I, Robel't E. YOlllp ;lnn Rrian (~. ElIl'rl!"' of Williams, YHull' &. I(ol'ni~~, P,C., Ih'nvl'I', CO, fot. plainliff.apfll'lIl'('. H, 1.l\\\'I'I'tII'C' lIoyt, HlIllldl'l' COll1lly AUy,. lUll I Mad..finf' ,J. MW'lflll, "1'I1111.Y ('ollllly AlJy.. HI/nldl'l', CO, r,w dl'fPIHll1lll.'l-llflfll'l. 1:U1t~. IJ~ 111 111 ,~ I'll ,d' 'II. 1I,'fl1r" TACHA and IlllOltIlY. Cir('uit _Jud,gf'~, and HHOWN.... District ,'Illlgt'. "(' HIWIWY, Cir('uil .1l1d~('. ,f. Thi.... lIppral spring:;; ft'om a cnl1tl'o\'cr~,\' 1J(,tween an amateur radio operator. Ill{. f-;\,:lns, ani I t.hp HI/uldl'r Connt..v Bwml of (;flmrnl~simH'rs ((;Ilunty Ill' litllll'.I) (.tJJlt'I'I'I1- in,l( thl' IlI'ighl. of an ;mtpnn:l low!'!' in a resid('ntial neil.!hborhoocl. Evans c11'~it'NJ a tower 100 feet hig-h; thc County decided thirty-five feet was ~lIrtici('nt; ar.d the di~. tricl court (h'cirlr'r~ eighty fef't wa~ just Tight. W('P ,"'vl'rsl'. 1'1" ial if.'!. Trl- "1'. d.. It.. FlIds Ev:ms owns ;1 11111111' Ilu':II,,(1 Ilflllll H I.~,'" HlTl' II'ad, ill II 1'.1111"11 1'l'~lilll'lll i:11 an':!. '1'111' al'I':I'~ principal aUr;H'tion is a view of till' nf';Irh.... IVlt'k.v Mountains. Till' dislT'it.t cOllrt jlldgf' who initially hc'ard thp (';{Sf' aptly de- scrilwd thp r('sid{~ntial nl'ighhllrhnnd a" fol. ]QWH: ITh/'rr an'l somp Vl'1'.\, spf'cifi(' intt'J'l'sts of Tlollllll'r (:Ollnr,V in genf'ral anrllhi.': [lal'- [iclll:rr 'll'i~~hh()rhollll in-sp4'('ifirally \,hil'h Ijt~ II", I'\; ,.d 'I'S 'I'" ;11' ';1- ill' ',\'" !l.- dd . Th,. HnrHJf..hlL' \V,....lcv E, Br<l\\'n, ITnrh'd Sl;'lc.. ()i~rr Id (tHll! JIIJ~~l' Inl (hL' Diqr III 01 K.ll1..a.... 7ri7 t" " f ':..l. "l-~l.' ) "-".,1 ,.~.- 1H1t~ ;;:~ ;'';''~'': :'f:I.~~ .(~~~'I ":~ . '':I:!it:J ..".,...,. .;ll..,...., .;f~~~ .':':H t , j 1 ! I I i , t, 1 I II Ila('I\~T(Jtllld This di"JlIIII' orwin:ltl'd III l~ISi \\'llI'n E\'- :lI\S :qll'lIl.d 10 Ihllrld{'r ('lI11llt.\. fill' :l hlJildirw ~i!tilli! h\' <k..ij'n:llrllll L . . 75K UU,I F1WEltAL IlEI'OItTI':lt, 2<1 Simms III I'l'Spollse to the distrid court unit'!' the (:Ultllly ;.llluptt.d ;UIll'lIdllll'lIts which atTlrllla- lively I'l'uvidcd the BlJ<lnlluay appro"t: 0111101- teU'I' I'luhu tHINerS exccedinj!; the :standard ht'il-',ht Iimitalium;, 011 AUJ;usl, :!.t, l~J~H. the Cuunty I'ccun:::;idcl'cd Evan:;' i.lllplkaliull ami once a~aiTl held. a I'ubhl.' hearing:. At tbal hearing; and throughout the t:uur:-;c ul' this di:;putc, the County heard tc::\timony frum a wl(\e variety of sources including expert::. un ham radio, land use zoniiig, and real estate vahtl's, as well ,1:; nci~hhul'ho()cl fl'sillcnts and membl'r:-:. ill' the public. , ~ I ~- 1:, 'l't, , '"I., :.:tt;li. . li~J' , ..f;"," tr- ..: l'l'l'lIIillO l'n'l't a \~f) fuul lllWt'r. Tilt: huilll~ in~ pel'llIit alld subsl'IIUt'nl applit'atioll fill' a vUl'iutlce Wl'rc denil~(l. The liistri('t court dc- tA..rmilu.tl tht' Cuunty\i CHllsillcrutillll uf Ev- am: llilplicatioll conformeu with the FCC's l"c~\\latiolls in "PltH-l",' Evaus v, Hourd of CUHulH ClJtl/m',.~, No, M7-z.-1&~r), We uf- lirmecl the district court decision, evnwi v. HuC/rd of ('olOllu CU1WIl'T:$, No. 88-~22:~ (lOth Cil', Mar. 12, 1~jUU) (unpublished order anu jUtIj.!;llwnll. In l!'S~. Houhil'r County atlIlPh't1 a Sl.t (II' aI1H'l\thHt~lIls whirh in part csu.lhlishl~d l.I lilllited impact special use ('e- vil'''\' I'I'ul'eS:-i fur l'oll:-iidl~l'atioll of propusals III crl'l't anmteur radiu tuwel'S, E\'ans suhsc. quently flll'tl an application with the County I'UI' a :->pedal use permit, 'i'hc application spcl'itil't1 full!' llilTel'Cllt tuwl'r cOllfi~u('aliuIlS and proposed the County :clect the most suitall!L> uptiun, E;'\I:h conlih"\.ll'ation in....olved u llitTen'lI1 lOWI'\' hl'i~ht l'illlgilll!. from sixty tu IUtl fed, TWII of tilt' l'ullfil!,lll'illioll:'> (lirl'd. Iy lillhl:tlllw pl'l'll,i:-.:-.ibit' luWt'r IlI'ij:.ht tu till: ht'i~ht of the \n'I'S lllanh'd tu :-.l'J't'I'1l till' luwel', :i~; : , Aftl'!' l.l pull\i~' hl'arillj.!; 1111 MOlY :a, 1\1\111, thl' L'ollllt,Y t1etl'rmilll't1 thc I'l'opll~al:; hlckctl :llle- Iluatc :il'recnill~ of th~ towl'1' ;.Inti failcJ tll mcet the tritt'ria for SlWl"i<.1l use approvaL EvuJls l.:hH\kll~L'llllle CUUllty':'> dl'lIial 011 fcd- l'I'i.\IIIl'I'I'llllltlllll ~l't\ulHl~, '1'111: ltislrirl l'tllll't in u I'llhli:-.lll'd "pillion, 1':/'111/:1 I', J;ulwl r1' (,'wully ('0111/11',.:1, 7rl~ F,SupP, ~(,:~ (l),('lIln, '~I~lll). Iwhl t.he :-'\It'dalll:-ie l'c\'iL'\\' 1'l'g"ulatinlL~ Wl'l't~ illlil~l'tl pl'l'Clllplcll by I'Ii.B-1. limier the hlllg\la~e uf the (~tlllllty'S 1't~ll.llbtiOIl:-i whclI read ;I:-i a whulv, thl' district l'ourt hell I a spt'l'ial permit cuuld he g-l'alLtl'll unly if it cUllIplied with the thirty-f\\'e fOllt lwig-ht re- quirelllt'lIt. The cuurt found that :-'iuch an ausolute pruhitnlillll un antennas greater thall a certain hl'lgltt was invalitl un its face it:-i It Ctllltl'a\'i'llt::-> lh.' pllrpll:'oe bdLilld the ft'llt'ral )!,II\"I'\'lllll1'lJI 1I'~ublilllL."" ld. at ~177. Al'l'lll'tluq.:,ly, till' l'llUl'l ~ra\ltL'd \-:\'''11:-'.' Illullull rIll' :-'llIlllllary .Ill1If~llll'l\t <lllll IllI"I'I'11'11 tIlt' ....lltlllty lu l'I'Plll:--llh'1' l':\"illl:-" applir'lL1oll Wllhlll siX Il\ullllL,.. ji~ ' , dl,l ~"', ", , , l. (Ill ~"I1l< lub,', I'!, I'J.'\'). lb" I'll 1','>11,,1 " HllLl!!; d".lll'~ \\llll ,,,Illlld'" I" 1\\\'11 1.,,\1.. "1,,'1 ;.ihll'> ,Illd I.",tl '''11111 I! 1.,\\ I Ill'> lllllll!-'- In.lV I" lUll lid 111,\1,:".,,- "I h'.I..,ull'".1I1J!lllJll "I ,'il,a,' ,II 1\1 Thc Board llcdsiun The Cuunty I'cjl~ctdl the special use permit in <.1 written urdcr. 'I'hc pertinent pUltiuns lIf thb order stated: I B lased on the evidcnce presenteu .,' the Hoard fiuds that lhl~ lapplicaliunl doe~ not 1I1l'I'l1lw crilt:l'ia I'UI' lilllill:tl il1lpad :-,pl'l'ial U:->l' apprllval as :-id forth .,' rul' lhe I't~a- t-lllll:-> that lhe pl'upwwll tll\\lt'l' will nul bt~ l:uh'qualdy ~1'I'I't~lU~d, HUt! will IIllt hc ill hill'lIlllny wilh thl~ rharader of the nei~h- horhuud; ,.' 1'1' Ih!.: Uoard hi l'!.:ljuircd not only tu cun:-;idel' the criteria sd furtl. in l the zon- in~ regulalions I, but specitically to balanc~ tlll' m:eds of amaleur radio pl'olJonent:i ag-ainst the impacl:-'. un lhe lIt'ighbol'huutl as tlt:lt'nllinl:d pllrsuant tu llw Zoning lte~. ulutiull; llln pt.'l'rUl'lIIill~ thi;-; I't'qllin~(l IJat- <.1l1t'illg, the Ullilnl rUllb that till: l1l:l,tb of the Applicant "tlo flot uutwt'i~h the atlvcni>c illlpadS un the lIt:ighbul'hllUd, for the I'ea~uns that thert.' is l'vidcllt'e that uthcl' ham radio o[ll'l'atillll:'J currently cxbt in the ncil-{hburhuUl1 and lTll't't the :{;>-(oot ht.:il:!:ht lilllit,ILion; that tbe need or the AppliL'ant fur a highcl' tower hen: is for illll:n'lllltilwI11,d Iran:->lni,.silJII. tl'I.'lllllt'al ;lllaly:-.is .\I111 :;l'wlltirll' n':-.t'art"h; thilt;t 'iO- roul lu lUll ["!llll tuwel' will ~'l:-.u;dl,v alld ;lt~,...tlidil'all.v dq.'r.llk till' /ll'l~hhlll"ltO\JtI, Ita;., lhl: 11()lt'lltl;~1 llJ l'('dIH'I' \ll"llllL'rly \'al- 1.",,11 HO;II/,dl"U' /'..,1<11'111'" I" .\"I,d,I" 11,1,110' Jmdlll(),IUI I ll..:J'J-,":. 1)1"II(,~ l~,,"'li (I'!~'>) "'>1 '<lII"I'llll'L \H' ,~,Il 1..1,1 Lu dll'> IUllll[; .... 1'1{\1 I I'l, it:-- Ii) I" III SI< N HI LI '" I,' ) " " ~ LI 1:( ", H' .' ~ll a: (:1 I' " " " r , r " , " , i' < t' r ,I " EVANS v. 1l0Altn OF COUNTY co~rlts ClleR~994 F.M 7~~ (IOth(:lr. 1993) ue~, amI .....;11 gTf'atly exceed and ishasical. Iy inf'ompatihlc y,;th the onc~stm''y resi. flf'nr('s in Ill(' arl'l1; anr! that olhl'r loca- tiuns mdsl within thl' 1II1i1l('orplwall'd County whl'l'f' :t propos/.r! tUWl'l' flf I his hl'il~ht, wnuld hI' IIlClI'I' ('olllflatihh. with 1111' sUl'rollllllirw Ill'i~hhlll'IIlUlfl alld <'mild hi' :lpprf)vf'rI. IV The Uislrid Cnurt J)("('isinn EVlll1S om'I' ;t~ain appl'JI\{'d to till' district rOllr\. ('(mtr'nrlin~ th,. (;olml..v\ lllIP!ira!.ion of it~ znnin~ ,'pJ:ulatiom.; had hl'l'" pn'I'lllplpd hy Ihr' FCC ol"rll"r.2 ^~ Uwrp Wl'rl' nn dis- IlItl/.1! isslu's fir m:ltl'l'ial fad., hoth partic's mov.." r"r SIlHlIJI:lI''y jlllll-!lJJl'nt. Thp district COlut in an unpuhlished deci~ sion. 1....{l(/II.'i 1'. /lom.rf f~f CfJnnty (,'mnm'nI, No. !)(}-F-ll!iO, Dec. :H, l!J!l1, gl'antl'd Ev. an:;' motion fot' !'ummary judJ..,'TIlent anrl heIr! the I'r~'1Jlations were invalld as applied. The rnur! ha!-'f'd this cJr'('isinn on three "oint~: (1) thl' Zflnin.1.'; Hpsnlution initially was prpl'lllpt- eel hy fl'cl!'J'al law; (2) t1w Board fai\t'd tl) arlc"lllatc'I.\! consiclc'r I':\'ans' nf'f'l!;-; fo/' H .'I.t':lIl'l' :11111'1111:1 Iwivht in vinl:ltiulI or l'I~Il"I; and f:O till' (;OIJllty h:l:--l'd ils dl'llialllr ";\'I.IIlS' afllllkath,n UpllTl illl'Onsislf'llt J,!fllllfUls. TIll' ('flurt Own sdpdl'd flIH~ of Evans' four prn- po:;pd options and ordered the (~Clllnty to upprovp lllf~ application fill' a spf~ci:l! IISf-~ pl'r- mil tu t'!,f'{'t an l~iJ,!hly-fflot antenna \'11\\.1'1'. V The FCC 1{('J[ulatiuns !-;\'I~I' .<.;itH'l~ (;llglil'lrno ~htTnlli ('I'I'dl'cl tIll' lil'~:l radin <Int.e'nlla, cord1ids havf' arisl'n !){'- tm'f'n a!n;lIl'llI. radio tlpf'ratOl's and 111l';11 ZOll' ill).! ;\lIl!lllriti(,,, etlll(,(','ninl! th.' lH'it:hl of :1\1- {I'nn:! 1t!\\'I'rs. AlTlall'lIr rarlit! npI'l.:11lJl':-- wl'!l knlll\. tlll'lI" :lhilit.... tn df"l'li\"f'l.\. n'('l'hT ;llHI tr;u)::nIi1 1''11Illllllllil.:tli!!Il'' dinTl!.\' rl'l;lk.<.; tll 2. 1.\';lrl~' ",it H~I" hrn:Hln lh;11l l"dll;I!<',l ;Ind dk" IIlv"k...J dll.'IL'l~ 'qHHI ilw I:ltl;d I~di,jlll "I II" I "11I11\.~ l"I\IHl' "'I'llbll"I\~ Ill< .diqli,1 ""III I.. 101 i11t. l"llilll' 1"l'ld,oIi"I\" W,.I'. I." i~dh Illll.] .'~ 11\,' . "1111 1"t',IO>I\..1 1110' 1'0111111' 1~,'~"J\1 11"11 ;.1" tl".I..-~ 11.. .,I,....IIIt.. 11O.,~,j,l 1''' .I111llll"ll N, III"., 1'''11 \ It;" ~11'1"..,1...1 II ,i~ 1'''111''" ,01 II... ,1,," h' l "1111. ~ ,t,.C"I"" 75!J the hcig-ht and loeatinn of thpir ,'adio antC'n- na. It i!' dOllht.ful thl'rf' f'xi~t~ an amah'm' radio npPl'atm' who dops not l1f'sil'P n hi~hl'l' lInl1'nnll. On lhp nthl'!' hanel, zunin!! nnthllri- lit's f'\(i~t, in pllt'f. In I'f'l~llbtl' lallllll~p hasl'll npon IH'sllH'lit' CIlIlSidl'I'al;olls. (lndnnhll'dly, l1Iosl zf111inl~ IIlllhol'ilit.s wfluld i1l"I'st rf'W st',,- nal'ill~ mlll'(' 1 hall IIll11 uf II hillh ~tl"f'l tn\\'f'l' nnl! ils aHrlHlanl ~"f~' wil't'!-l pl'otruding- fl'fllll n 1'('sidt'111ial n('i~llllnl'IIPnll :lllll illtl'rfrriI1l! \\~th a ~upt'rh mountain \"if'\v. ! The FCC, I'('l'og'nizill~~ the inhl'rPllt and ('~ntintlillj.! ronllil't ht'tW('('1l radio 41111'rat(}l's :mt! wning :1Ut.!Joritips, nttf'lllpll'd In l'!'~flkt, t.hl" ('onniet h,v ;~~lIillg an fll'dt'r d('~('ribf'rl as PHIl-t, whprt'ln till' FCC Sl~lh'd, in pHrt. as (flllll\\'s: In I his situation, \"'p hf'lil'\'1' it is appnllll'i. ate to strike a halal1l'(' hf'l\\'t'l'll tht, fl'(!l'ral intl'n';;;t in Ill'llllloting- amatt'ur 111ll'r:ltions and the Ip"....itimale inl<'T'l'sl of loeal gnn'rtt- ment in rpgulating local zoning matter:-. The cornf'r~tone on which we \\;11 prpdirate otlr dl'dslon is that a r(,;lsonablp at'('(ltJ1tHII- dation Illay he m:ull' lI('t\\'t'l'lI tht' t\\11 ~hlf's. Stnll' lInd Iclt'JlII,,.~rlll11lilln.>l, Ihlll np ('rail' In I'l't'rllllll' :l11l;ltI'UI' t'OllllTlllllit':lliull!-l ill Ihl'ir rllOll1lllnilif's al'" in din't't l'Oldlid with (('(11'1':\1 objt'rt in's and mllst ill' pn.'l'mptl'cl, WI' will llot sl't'eify any p:wti('\I- lal' hl'ig-ht limitation lu'1nw \\'hi('h n lilt'al ,l!n\'f'I'IlIllC'nl Illay not rt'~\lI:!tt', nor \\;11 WI' Sll~gl'st tll(' pn'dsl' lalWllag-I' that mllst hI' clllltallH'(1 in lncal llnlin:\Ilt'l's. fLlnral 1'l'~!1lt:ltiI1IIS \\'hich illml\'(' pl:H'f'!n{'nt, Sl'l"I'C,t1irw, 01" Ilt'i~~ht of :ll\klll\as ha....I'tJ (,n hl'alth, ~:lff-l.\., 111' ;\I'sllll'li(' l'nll~iltf'r;\li(lIlS mll:o;t hp CI";II.tl'd tn ;\('cfllnrnodal(' !'('asnn. ahl.\. :\Il1at!'\lr t'Ollllllllllll':Ltion.;.!lI ;lnd tn n'IWI'SI'nt (lit, minill1\llll l'ral'li{';dd(' n,\..."d:l- tinn 111 ;It'{'tlfllpli...h till' !(l\';1l :llllhlll"ll\.....: It,. gititl1:ltt. pllrplht'. " ;; .1. .~, '" ..~~:; ....II.. ,"..... n::t'I~; . ~~r. , ''',', " , '!~f'~ <- I"K:" "I;~}\ .:.:[, -" ~~~ "I'" 'l~t, :+ ~. III ;It.Ulrd;ltlll' willi lhe ~lll>~nl1lt."1 I (C paIn ;11111 "liter (~1". hl\. \". 1,..<11 (h,' phi "". .1<, "Ill. Itl"d;,,,' tl':I"'11.1I1h ;UlI;llnH lUllltll11111l ~111"11' ." . '1 '.<I~"T1.lhh ;"" '1111111 ,d.lk ,1111.'(' 111 ,"111111111'" ~l 1l"1I~ . 1 ,~. I :Ii; ! ' .; ~' I . .:1;'1';: ~_~m :~' :iJ;-:' ,,1..:.. _....~ :,. . mil F1WEIL\L ItEl'OItTEH, ~d SEll 760 "-l:~-l: . l;'I,~if . ' :j;'ylfll, ' .-""" ~'f ,H. ;J'~' : '1'111: H '(: 1'0110\\'1'1\ l'li.n I witll all unll'I' 07 Ci"H ~ H1.I(I(t:J), wlllch 1:-'< Ijlllllt'lllL:-I fl1l1pw~: E:\l'l'pt ll::i Iltht'rwi:-:.;' (lruvilll't1 hl~ft'ill, a r,l;ttiull .mtcllllU :;lrudlll'l~ llIay Ill' l'l"l~l'kd atl\l'i~ht~ awl t1illlvlI:,iol\s ::>uITlCil.'lIl to ac- comtnl,tlatc alnatl~IU' service CllllltllUllica. linns. State lllld lllcul rL'~lllatiun or a sta- tiun antenna :-;trul'tun' IHII:1t nuL pl'l'dutlc alllateur service COllU11Unil'atiollS. Rutllel', it must re..\sonahly <.lcl'ummodate such com- munications ;.md must con:stitute the mini- mum l'nlctil'ahlc l"t'g-ubtillll tu al'l'ullIplish tlll' sllllt' III' IUl';1l ;ullhorily's k~ililLl;lh' purpnst.'. t 11 Thl' rq.{uhltions alh'lIIpl tu st.ril,c a l'ulllpnllllisl' bt.'l\\'t'L'1I tWlIl'III1lJldilL~ illtl~n:sl:i ;llld, ;IS is trill' tit" lli<lIIY l'Ollllll'Ulllisl'S, lwvl! ullIiul'll till' ddails Il.'il\'illj..{ bulll sidl's the illlPl'l':-isiulI they rel'l!ivl!d the hi)..1;csl plel'e of till' divided l'ilkt'. Nulwith:-il<llldillg" the in- hl'I'I'lit \"agtlL'IlI.'SS ill lhl' 1;1I1g\ia~l', sevl'ral pl"illl'illlt-:-i Hlay hi' ~h,.ult~t1 frolll lhe FCC l'l'I!.III:ltillllS, I,'il'sl, '1.1lllill~ <Iuthol'ili,'s IIlllst , n'llsllllllhly lII'I'UI\lIllUdatl' ;UUlltl'll!' 1'llllllllUlli- l'atiu1\~. SI'l'UIIlI, l(lml 1'1'~ul;ltiuILS ~huuld ile the minimum (lraL'lil'ahle in Ol'dl'r to accom- plish thl' ZlIuinJ..:" authurity\ legitimate pur- ptJses. Third, local authorilies may nut altu- gether Iln::clude amateur communications. FinaHy, the FCC has explicitly dcdilletl to regulate the spl'l'ific pel'missible heights fur antenna tllWel'S. \'1 1'l"l'l'IUllliun 12,:11 \\'1' n'\'ll'\\' IIH' di:...triet l'll11rt's grant oi" SllIlllll~lI'y jllllg-llll'ul dl' IltlVll, First II/It'/"- :-illite nUll/.: lllkl/I'/'/; N.t\. u. Ilriug, ~lti~J F.:!t1 ~:H, l'J~J~I-~Jli (IUth l'il'.l~j~J~). l"l.'I"l.gl"anl- ed ill part, - U,S. -, 1l;; S.Ct. :!.!J:!.7, t:!,t L.l':,L~d ti7H ,;j lJ~,L'w, :1ltJ;;, JSW IS,CL .hllll: 7, l~I~la) (1\11. ~,~ -S;)-I). '1'llll:-, we ~i\'l.~ 111/ dl'li.'I't'lln: tu till' di:ilril'l l'Olll"l';O; pn'I'lllpliull dt'h'l"Illllliltitlll :llltl I'X:UlliJ\(: thl' Ill'l'I'llqlllltll i:>:"'lh' liS if WI' \\"\'1'1' :-iittilLg .IS till' ll'i.d l'ollrl ill till' fll":it in~l;IIH"l'. Il,jl Till' :--ill]ll't'lll.lt':,' ('\au;;t' (Art. VI) (.1' thl' l'ull:--titutilJll IJI'l)\"idl'~ (~IJ[I~Tl';-i~ \\ith llll' PUWt'f lo Jln:I'lllpt ;-ilall' law. l'I'l'I:lllpU"Jl may un'UI" ill any 0111' uf at It:a~t ("OUI' sitlla- tlullS: (1) t'xl'l"l'SS p"I'I~lIlption, whirh n::sult:-; wllt'n (:lIlq..',n'~;s t'XPI'I':-lSI':-i a dt~;U' illl.\~lIt t.u I'I'l'l'lllpl slntl: law, Mu/"uk.'j /', 'J'/'IIu.'i World Airlilll",-;, 1111'., - U.S. -. -, 11~ S.Cl. :!U;II. :!.U:lli. It!1 L.Ed.~(1 if a (1!)!J:!l; J,(Htisi- (ll/O 1'lIh/ie SIT/!. Cumm''Il j). FC(.', 471i U,S. :!r)~). :Ui~, lOti S.Ct. HmU, lSHl:\, UO L,Ed,:!d :UiH (1!IXlil; (:!) implied preemption, which I'e::iult~ when statl~ law "stand~ i.1:i an oll:;ladc to the l.Il.:l:olllpli.-:;hlllent and executioll of thl: full \lUl'~ pose~ antI ohjectives or C{Jn~J'c:ss," H ine~ "v, /Juvidolvil:, :U2 U.S. [)2, ti7, Hi S.Ct. a!J9, 40\, Hr. l..f;d. fiHl Oil4I1; ell conl1id preelllp- lion, whirh I'l'sults fruln all Hl'lual l'tJlltlkt lIdwCl:n federal allll ~lall~ law l~VI'lI lllllllJ.:h CUllgn:ss iH silent. Florill(l Lime S: A /.'fII:wlu (;mwcr,\ 1m:, v, J.(lIt/, :{7;) U,S. la:.!. H:!. Ha S.Ct. 1~1H, 1~17, 10 L.I~II.~d ~.1r: (l~JIi:"; i.tIHI (4) tidtl IJI'I'l:lIIpUOII, which I'esults 1'1"11111 a dt'tl'1"I11illatiul\ lhal (:llllg:n'ss intl,Uth'll to 1'1'- mOVe an {~tllirc :mbjel'l frum statl' I'Ch'1Jlall)ry authority, Fiddity Fnlerul Suv. & LouII A'is'/1 /', dl' Ill- ('11I'..../1l. ,IllS 1l.K 1.11, lrla, III~ s.n. :1lI1,1, :JU~~, 7:ll..[<:(L~d 1;1>1 (\:JH~J. 1'....- 1:llLptilllllllay also n':'iIllt 1"1"0111 adilJll taken hy II ft,tkrHI HJ.!Yllt''y Itt,tillJ.: wlllllll till' l"it'lIpl~ or its l'llllgrcsslullally lldl:~alt.'ll Hulllll/'lt..v. Capital (.'iti~;<( Cuble, I tit'. v. C'ri.'iIJ, 4li7 U.S. mn, LiH~. IW S.Cl. 2Li'J4. 270U, HI L.Ed.2l1 fl~O (lilM). [61 By applying the basic legal principles undt'r1yin~ the dtlcl,.ilH~ of preemption tu PHil-I. we reach the fHllu\\in~ conclu~ions. Thl' FCC labdl~<l I'lU3-1 a~ a "Iimilcll pl'e~ emption policy", and ~pl'('ilicaHy staled it would \1ot :-;pt~l"ify allY Iwi~ht lilllitatillll, bul l'lal'ifll'd tll.t\. lur.1i autborilit's lIlay Illlt I'n'. dllllt~ alllah'lIr l'OllllllllllicatillllS. Ih'l.':luse the F{ 'C expJieilly dCl'lilwd to I'l'gulali' the Ill'il!,'ht uf radio antl'nlla loWI'I'S, ~uch regula- tiull fl':-its with tbl' IUl'al zOlling auth(Jrilil:~ prilvidt'd the)' n'i1siJllahly :ll't'Ollllllodate ama- h'lll' l'UlllIllullicaliollS with the minilllulIl Jll'ill'- ticalJIt- I'l'~'ulati()ll rWl'l:ssary to ilt'I.'Olllpli"h thl'i!' !lUq)I)SI'S. Ft'lkl'al l:IHlrb !J:tve g-iVl'1l dh:d tll thl' lllllitl'd !1l'l'I'lllptiU/I !Jolicy Ill' l'I{H-l. III 'J'hnil,~ I'. ('It .II ,,"I,IIJ'I.~/d/" l'lI,-k, 77~1 F.:!d 11-"7, \1;><,\1 (lith ('il'.I\'''''lil. It was n'l'll.~llil.t'd Illal ;\ 'l;llJ upllJlLlll' l'l"t'I'UIJIl or allldll'ur radlll :...l~ltIIIIJ ~lllll'llrI<L'" 11l;1:,' t'1l11Lr:I\'I'II\' klkr:d L;w. ('lJurh have :...Ull,"'I'ljUl'IJLl\ Ildd ltJal ;lll) IUI'aJ IInlin;1I1l'e wltlcll dL;-lllull'l,\' [iI'Ullll'lb ~ll\{l'll- !Las IIVL'I' a l"l'rLllll lll'lglll '--> IlI'l"l.'SSanh I ( I I I I I I CIt(' "" '194 L2lI1~~ /lnlhl>lr. 1'19\1 ~~~('fnpt('(1. Sr,. g,vnl.'f H !lflfltYf III ('''WIlly 1"1'\'ir'\\'il1~ ('ullrt s}\lIllhl apply nl\\'u"plll"l nnnl. Cmnm'T.'f, 7r;2 F.Sllpp. at !'I77; flndorJY 1'. .""Hi~. Sf" I/I/frhi~. fiil [".Sl1pp. at 127.1. r1ll'rH7lrm"rd Vi"".'/" (!( Sm'/(I.~ Poin', 1l~1 First.. thl' ('ollrf 5:hollld f'x:unim' thl' llPpliC'l1' ~'.SIIPJl. HlWI. 1111:1 n':.n.N.Y.l!'~7). MflI'P- bll' rf',Io!'ulatilltls tn c1t'tl'l'lniIlP if tlu')' lll'n fa- n"'''T. romts havp 'wid that 10(';\1 orrlinan('PR dall~' ('on~isu'nt with PRB-l. In this {.:t~C' art' pn'f'mptf'r1 wlll"n. a~ appli(ld. 01l"'Y elo not the distrirt court found the' local ,"pglllatioIlR providf' for the rf'ason:Jhl~ al'commodation of facially valid. and ~inC(l nf'ithf'T )lmty :\ppf'nl- amah'ur radio communieation!'. !vfnrj\fifltIH ed that holding, it i~ unnE'ce!o;sary to analyze It City '~f Rnrky Ril'~r, 74R r.supp. 1241, the first prong, Second, the revie"'1ng court 124r: (N.D,Ohio H)~o); Rufchi,'{ II. Cily (l examine!' the decision of the local hoard to Ed'/1/lmrl,'1, n7t F.Supp, t270, 1274 detprminf' if the local hO:lf'(I'~ tlpplit'ation of (W,V, Wash.! !IX7l. the r(,~lIlations is JlI"f'cmptl'd hy PHil-I. :.;1" . IWANS \'. HOAIW OF COJINTY COM'US 761 ;' 't<' Although courts have found local ordi- n:lnrl'S prf'C'mJJt,'d wlwn a lu'h!ht Iimit.Btinn i~ impII.'>{'c1, tllI',V I'('('o~niz{' that zflninj.! is typi- call,y a fllnc'lion ITs('l"\'('d fol' locall"!j..,'lllation, "Land us!' poli('y t'llstoll1:1l'il,Y h:ls h('('1I ('on. :-lid""I'd a [{'atlll'" of lo('al ~lIVI't'IIIlI(,1I1. :nul all an'a in whirll tI\I' tenc.t,<; of fC'c\l'l'alism are partil-ularly strnnl-:"." 1::':::'0 I'. UO/'fJ//.r/h ,~,. flip- cr /';rlW'. :-0\.1:{ F.~d 7fi;l. 71i!! (:{d Cir.l!'~H), Thlls, ('Olll'ls ~hl)\lId 1'1'1)("1'('11 wilh (';\Iltio!\ Whl'll ('on:-:idl't'ing- wlH'L1lt'1' pl'l'ds(', :-\1J('dlil', 111t'al nnlinan{'(~s an~ pret'mpl('d hy V:lj..,'lll' 1'('11- l'!';11 f'f'~\Jlal.iollS. 1':\'1'11 th"ll~h lhf' FCC 'las till' [111\\'('1' III I'nal'!, I'f'h'-II!;ltilJIlS whit'll woult! ,wI'l'mpt 1'f1tlnidillj.!; Ifll'al OI'din:IIH'l's. it SIH'- dli(':dly ,,,1:111,11 "11.1111' ('01'11<'1':-:10111' 011 \\'hirh WI' will pn'llic:ltp 0111' d(!d~ion Il'ltH-11 is that a r('asflnahlp <lecommwlat.itJtl may be mad\' h('lw(,l~n the two f-id('s." I n fact, in PHB-l th{' FCC ("xpre~sed it", desire to give deff'f'(~IICe tu the lotal authorities: "We arc (,Ilnfirl('nt. tll:ll. stall' nnl! lo('al gnV('I'n- ml'nls will l'ndf':lVnl' 10 j('h.;slatt' in a IWlnllE'T' that afrords :IPllI'(lpr;:tlp I'I'f'n~~n;tion 10 t.ht' imporl.ant. f('dt'I':l1 inlf'I'f'sl at sl.:lk(' 111'1'1'." 1'11('1'(.1'''1'1'. thl' H'( ~ has (If'('idl'd 10 tlf'l'nlil IIH':II rl'~ulatlll'.v 1l(,II:I\"illl' \\'hidl ;(('I'111111)1;:.;llI's HIP I(wal :W"flf',V's Il'~~il itllat,(' Plll'flOSI'S lhr!lllvh till' 1l1illittllllll pr;ll'li(';lII1., I'f'vnlalilltl. VII 17J tlOI1:-1 H.'vil'\\, or I Ill' Huard I )l'l'i...illl1 III t"l'Vj"WiIW l!1r:t1 l:l1HI II'" l'q~ld;l or ;lItI:tll'llI' ,'a1l111 :lI1II'nll:L /11\\'1'1":-:, :1 4. Thl' Sllpllllll' (our I in 1-f1"'1/ \"'lll 011 In llO,ld 111;,1 Wlll'll" ',I,lll' :11"IllY j, ,'tllll\' III ;1 ill.llli:,1 1:11,,10 il\' Inh 1.11 ''''Ill'' 111",1 ~'''-,- II... ;1\,,'1)1 \'-'. btl(lIllllllj' 1111' ':lIHI'IHnlll'i\t. dirt 1 C" whill1 il w",dd Iw "'lrltkd in rill" 'LIIL', "llIh 1111"11_ ,171'1 [I... ;1/ 7'1'1, 111(, ....ll ,II 122(, IJI<' .11'1'11< ,,1,r.- LIt\" 111 1 "1".,ld,, i, Ih,d .1 It'\l<"\\IIlL' ,,"HI I ''';1\ Il"[ ,d ;1""1.- II". [I""ld', dt'"i"'I'1l IIllko;, II j, I~. 9,"'n Ill'l'iding \\'hdlll'1' thl' BO:!l'il':-: r('J~lllations an' fll'l'('mp(pd a:-: applil'd to Ev- ails' Kpt'l'ial liSt' JlI'I'l1lil, WI' J!i\'t, 111\(' d('fl'l'- I'W'I' to thl' r:u'ltml dt'tl'I'IlI;lIatiIlH:-l IImill' iI.v t11f' OO:lI'Il. Fl'clPral ('otlrts should ~i\'t' 1'1'1'- clU!-lh'l' l'rrt'l't to the f:\l'UindillJ,! of stall' 01' I,)(.'al i1(lminist.mt.ive ll'illun:lIs. t.'"il'(,I','fit" of Tf'IIUt'.'f,'I.I'I' 1'. f:fljllU, ,17~ 1I.S. 7~~, 7!1~, Hili ~,CL :l~~II, :~2'211, !)~ I..Ed.:!11 l);lrl (1!I~Ii),1 Thf' di~t ri('l ('Hurt. did lIut (,xl','C'i:-:l' !'uc.:h dl'f- pl'l'n('1' \\'111'11 it. I"f'j('(,tl'd thf' HOHl'd's (,olll'ln- :--ioll that tilt' to\\'('I' would II(' il1:uh''l"atl'ly SCI't,(.tll'r1 hy trt'I'S, Thl' l'Olll't Iwlll tlll' 1':llitl- nalt, \Va!' inclInsisll'nt.: "lrl11l1lph'I(' shh'\llinj.! of till' alltl'nna lIy ll'l't':-: would illll':l('{ llIoUJ\- iain view~ no I('~~ than the atllt'una itf-df:' It was improper for the di~tri('t court to reexamim' the Hoard's factual l'ondll:-:ions. Thereforf', upon cxerri~ing- our de no\'o ft.. vi('\\', Wp nt'l'd only dl't('rmillp whd !H'r thl' Count.....s applicatinn of its 1(1(':t1I'('J-..,J1:tt;nn~ to lht~ fads as t1w,v illl<'l'!lI'l'lc.t1 tlu'lll arl' 11I'('I'll1plf'(} iI,v f"df'l'al la\\', PHH-I did:dl'!-' Ih:11 lul'al ordin:llll'('!' arl' PI'l'f'Tllpll'd ;l~ :lpplil'fi III halll ,.:ltl;n IIJlI'I'1l1nl's \\'11f'll tIH'.\' fl.l IH\I I'l':l:-:'ltl:lllly :Il'I'IlIIII1Hulnll' atn:df'llI' ('omnll1nil':ttilln.,: flll"lllt!11 tIll' 11':1:.;1 I'l'SI1'idin' rq~\ll:dilll1 J!l':ld\(';!ill.,. III l1I;1kin~ ;1:.; 1!t'!C'l'lllil1:llillll, 11ll' 10(':11 11":11"11 !llll'" 4'11"- :-:idl'r ;111 rdl,\.;ttll r:l('tlll'~; and 1"I,I,,!"!' pntl'II' ti:tl :l!krl\:,t;\'I''''. /fl!wonl I' l.udulllfll'll'. lltl"lll'l"l1lnt hv ;lllV UHlll'vll'Il1 v,'idl.tll\"' u",,!,j "I .\\\,''''HI'II/ --\/'I,,',iI. ,- ("1"",,/,, .hl/!,-,,: {"lnl" 7(,} 1'1.1 I.lf>. '''I I( "J" l'l,"l.'ll (qIIPlill\' /I",I"l "I ("!I"lf" (""'"!I'I' I ('"/,,,,,,1,,11,/ ,,' """"",'111 ;\/'I"'liI\, t>!,'l J' 2d I ';It, I<;~ l( "I.. ll. /\1'1' I'l~lll Iln;lIt'I' IIlllt' \\;'" ,'01111','1\"111 <"\1 d,-m <" in "UPI'''t I 01 tlll: 11",11.1, IIIHllnl" w,. ;ll'ltlttliTlL'I\ \'t~'l" Illl'm 1'1",-10""" elk,! , '.J.. . nt.', d"'"l.. . ~~I FIWEltAL ItEI'UltTElt, 2<1 SIES 71i2 I" 'to " '.,,:~' w;-;s Wi. lIi~I07.1, 'I':~ (N,D,CaLl~I;-;S) (unpuh- Ibhetl lb.:i:-;iull); ,'WI' u/:w HtJdol/!J, li;-;} F,SujlJl. ul HI}:! 1:1. llU I Tim (joHnl IH'1l1'l1 llll alllllulalll'I' of teslimuny allllrl'~ difknmt hcarilll4s rc1atillJ,!; to CI't'1.:lillll of all allll~nll<l towel' on EVHIlS' fJn'11t'J'ty. 'l'llt: BUill'll e1it:iletl C:OInnwnls frolll E\"alls, hb lll'ig-hbul'S, I'X(lI'l'ls till ham l'Iulill, illHI expl'rls ill n'i.L1 l':-;t<ltl', FOlll' of ~\',lIlS' ;I{ljul'l.'lll Ileighhurs were veill'lIIClllly upposl'd lo the 1'I'cction of a towcr in CXl:ess of thirty-fivc fecl~ EV~UlS was providcd the ul'porlunity tll I't'spllltll lu till' l'UIIl:CI'It:i of thiN' whu upptlsl'd lib ilPplit:atiuu fill' a JlI'I'- Inil. By tIll' 1'lId of llll~ lll'arillJ,!;s, thl~ BIl,\l't1 WIlS \\'1'11 ,tWlln' lit' tilt. I'itllg-I~ of l'UIlITnIIl1iI';t- ~ tiOll l'ilpability thaI l'ould hI! adlil'\'I~t1 with lUllt'nlla IOWI'!"S of val'iolls h{'ighb, In fact, prillI' to lIw last lH'aJ'ill~ Evans wrute a lettt'r to thl' County ill which he sl:rtetl it would hc 1I11IH't'I':->Slll')' to prl':->l'lll furtlll'r l'xpcrt tc:-;li- mUll)" as "most of the issues have hcen thrashed tlu'ough ad il/fil/ituNt in our prcvi- tillS 1H'<t1'i11g-S," .\'..', Tlll~ IIUllldl'l' 1't111l1ly I,lllld (\St. Slilrrdrall- t,tl II f\llll'.llil~'{' lIIt'IIHlrHlH!lllll SUI111llOll'izillJ..: lht' 1'1'l\lIt':-;1 lInd iljlplil';ihlt, slill\llal't1s aud llltilllillt'\y t'\lJIdwling" tht' to\\'I'1' \\'ould ill' inadl't1Uiltt'I,v S<Tl't'lll'd ami would not hc ill hanl\llll.\' \\'ith thl' SIIlT(ll1ll(lill~ L'lIvinlllltll'lll. St;df n'\'Ullllllt'lldl,tl thid il sh.ty-fuul nanh-llP tllWl'r might bl' ;t f"ilsibll' alh'rllilli\'l'. Ev- ans, hO\\'l'vt,,,, te;-:.til'iL'd lhal a l'rank-up tuWl'1' would be implausihle, a::' it would not with- stand tltl' hig-II winds that frequent Boulder, Ultimately, aft!'1' the Aug"llst 21. I!J~J1, Iwal'illg, IIH' ('lIullL.\' again tlt'llil'd the pt'I'lllil. The Coullty inlerpreted till' FCC n'g"ulations tu mandate a b.danving- lwtwl'ell thc needs of thl! alJ1akul' radilJ !Jl'tlI'UIH'lIts and till' ad- \'L'rSe imp;IL'cs Oil the neighborhoud. In pel'- fonning- thb iLn;t!,\':,>is. tilL' Cuunty dl'lel'lllined 1::\'aos' lIet~d rul' ;t hig-Itl'l' tower ......IS olll- wl'iglll'd II)" thl' ill'SlhL'til: \h'gTadatiull of the llcig'hborliumi ilnd putl'lltial n~duc.:ti()ll in prUpl'rty valtu' Till' HUiinl furtlll'l' sug-g-t'st- I,d that lu\:;.ttillll:-; withill tlll' (:UlIllty c.\i:-.t wl1l'l't, :-.lll'h a prlll",;"d {',Hild Ilt' appro\'e'd, I'HlI I l'l'I'llglll/,e':-O lll;ll /"t'guJ.lllIIJI." ;llll't'\ 1111-: till' pl;It'l'IliC'ILl, '''l't"I'l'lllll~. ;Illd lH'i~hl qf ;lll!t'IIIl,I:-o an' I'I'l'Illl:-o..,ilo1c' Wltc'll ha,"'l'd 1111 health, :-akty (II' tll':-.IIll'Ht: CUIISldl'ratJIHls, ;\S long <.I::; they rcasullahl)' <t1'l:otnlTlodate allla- lcur l'lllllllllll1icatiolls with the llIillilllulIIllrac- til'allll' l't:gllluliull IlI'l'eSsaI'Y. TIIlI;;, till: l~j,t1IlIy's jllstilll'util'll Ill' Iln.....ervllJg 1I1l~ Hcslhctil' views wus actllowledg'eu uy Pltll-1 as. a lel-,ritimulc local CUnCl!rn, Murcovcr, the County's decbiun was informed alld recog- nized MI', Evans' ctJlIllllunil:atiun nccds. AI- thoug-h tlte Cuunty was aware a thirty-livc fuollowl~r wuuld Ilut t'uJIIlllcldy lIIeet EVill1:i' lCbritimalc goals, ..thc law cannot be that municipalitics have no power to restrict an- tcrlnas to hdg-hls below that clesin.'d lIy radio lil'I'IlSCI'S." WilliulII.'i /I. City /Jf Cotalll/,ia. WI; F.~t1 !JU.I, t)VS (;Ill. Cil', UJ~J(Jl. III otlwr cu~t:s where IlIl'al rc'glllaliull:i Wl'l'e precmptl.tl as applied, l'lIUrl...; hdd the record Wa..'i devoid of any l'vidcnce demon. st.ratin~ the lloard I'l'a:-;unaLly al:l:oJnlllodatcd the amateur operator. BodO/I!!. GHl F.SUflfl. .1 JllI:l; /iI/kit i.. li71 F.Supp, ill 127,1. lIl1- like the zonin~ huards in H/Jdolllj ami Hilt. elt i,'i, thc record is replete y.;th evidence that Huullll'l' (~OUHty rt'asonallly J:1tCtllHlIIwlali'tl EVill1S' iUlIitlt'UI' t'lJIIlllltlllit'alilJIl gIJ,d:"i, Ilt, spilt~ il:i t1dJittalJll' viability, the (:utlllly wu:-; willillg 10 l'Ullsidt'I' 111(' O(ltillll "I' II ITallk-llp sixty-flllll IUWt'r ill all t'ffurt tu n'a,stlual,ly at'('olltlllodale EVi.IIIS. The Bu,lrd .lbit) ill'- pruvl't1 a sJlccial use pl'nllit fur .uHJlher tow- t~r ill I'XI't'S:; ur thirly-fi\'t' fn.t, whel't' tlw COUllty 1'l'Il that thl'l'!.! was adl'quak :-1'1'1'1:11- ing :wd the ...ie....'s Wl'n' unilllpaired. Finally, the County';.; rCl'ognitiulI tbat otl1\'1' \ultcl1lial locatiuus might be lllurc ~Ilital,le fllr the cUIl- sLrueliulI of thc tuwer dt-lliolJstrales till' COllllty WHS !lut illllt::\ihlc ill its l'IJIISidl~I".ltillll IIf Evans' <Ipplieatiuu. The Huard in draftilJg- its res(llutiorl l11is- characteriZed its rcs(HJ/lslhilit.v tu l'easonafJly at't'tJll1l11e.date as a balalJL'ing- test. "tIjll pel'- fonning- thi:-; requin'd balallL'il1/.{, the Uuanl ti/llb that lIle [l('l.!lb uf till' A!J!Jlil.illll do not outwl'igh the <Idn'rsc impill'l:'. un lllt~ lll'ig-hIJiJrlllHIII." 'l'hi.., balallcillg- appnJilt:h \vas adopt,'d by till' Fourlh e'ln'lIlt. "Thv LlW n'quin..... (Jllly that llll' City fJalOlllCC tilt: f,'dl'I',dly rt'l'tlJ.:,'lIi/.I'd illLIT\':-.L III ,Illl;ltl:ur j";l tlllJ l"lillllIIIIIIJI',ltlllll." with I",.,t! L1,nlllg 1.(JJI. nTlb. H.dl/(/III,~, ~'tJli I'".:':d ;,L ~I~I,"'. W(, lwllt'\l' lilt" h;dillll'lllg ;QIJll'lI;n'il 1I1Ilh'rn.pll' Sl'llt:-.lhc V('(":-; gUill.-, a:> Il :-,pl'l"lfll';.dl) ,,,t,ll-d- t \ I I t IN 1m I1ICIIMWS Cite 1.,,994 1'.2d 7td (llllll tlr. 199.l1 Ja- Il'. 111' Ill' f'>l) the "rf':Jsonahl.v ,I('('ommof!atc" language. NI'\'(~rth("f'S!-\. (l('st1itr. its mis('h:tI':ll'tPl'izlltinn, Houhh'r County rn:ulr efforts to I'f'asnn:lhl~' ll(,f'rHlllTIodalt' EV:tlIS' {'nrnllHlllh'ali'lll f1f'f'<ls. In this {':ISI', df'llial flf till' (l1'I'mil uftl'!' l'\':du- :ltin~ opt.inns and I hOJ'ollghly considl'ting till"' rf.lfI\'anl ('\'idene(' was a ,'(';u.(fHmhle a('('ommo- d:tlion. hI' ~- 11- "f' IS' at n ill [III In rlf'll'I'mining whdhPl' the <:fllUlty utilizl'(J l.hl' minilllllln IW:le!ieahll' I't'J.;!111al ion in addrt'ssill-'! Evans' proposal, Hu' Coullty nmst haw f'xJllof'f'd all('mali\'"s to a lllankd llf'ni;d of till' applil':tlillll. S"" IIrl/nal'd. 1~1,'-:~ WI. Ili!/Oil ;11 .~;t TIll' (:r,llllly's II'J.!'itil1l:lh' fllll'llIISI'!'\ J",hilld dl'rlyirW 111(' JlI'l'Illil \\'I'I'!' 10 111'1'-:"1""(' 1111' af'~lh('lir \'i(.ws mill mailltaill th(' property valtll's in thl' ('ommunity. Sincc the Count..... detcl'mined there would bc imule- fluate scrcpning of the tower and the pro- ro~('d alternatives h.v Evans and the Boulder COllnty Land I r~(' ~t:dT would not alleviate the prohlrom, the denial of the prormit in this case was the minimum practical regulation nrccssary to accomplil"h their goals. In sum- mal:'-', hf't'HtlSe th~ County made efforts to rpa:-;Imahly :l('C'omllllldatt' Evans' amatl'll!' rommunications lltilizinJ.! Uw minimum prac- tirlll 1'(~g11Int ion. thr> COllnty's rf'glllations are not preempted as applied, Conseqm'ntl.v, WP REVERSE thC' dl'cision IIf thl' district Cflllrt and hold the d('{'isinn of thl' BOldt/I'1' ('ollnt,V Board of COllllllission('rs should hI' I'l'inst:ltpd :I.'; it i~ not. pn'I'mptl'll. ". " ,.. ,,- "I 1', ,', ,- " ,01 " " I,\' ,- ," ,- ,'. " w o ~nl'III''''!. i'lf" , " In n' William E. HI< '" \HIlS, pj'hlor. 11~ITED STATES (If '\lTlt'rit'a, Appdll'l'. v. William E, HU'I! \HI>:-i, \Jllwllanl. No. ~J;!-liO!l;!. l;nitl'd ~t;ltl':-; ('ourl of ,\pp,'a]:-;. Tl'Tllh ('ir(,llit. ~by ~s, 1!1~1:1. II{:-; til(.d 1lt'''1I1' of I'\;!irll 111 ('II:lpll'r 1:{ :1",", TIll' 1\:lnL:l'Ilpk\' ('lllll'l allo\\'l'd pl'lnri- '~H r :',j 11} 7ft:! ,-,.., ty ('Iaim, :lOll c1phtor appealed. The Unitpd Statl'~ Distrid Court for thC' Wrstrrn ni~- (,;el of Oklahoma. Wa)'ne K All,')', ,I.. af- nl'nlf'd, 1-11 JUt 7!i1, :\nd dl'hlol" appl'al('\L 1'hl' (~ollrt III' ^ppl':lls, MdVilli:llll:-:, Sl'ninr Cirelli! .Jlldg-('. hl'ld thaI as~pS~llIl'nt Iwrind undf'r Bankt'uptC'y CudI' prlJ\'isinn granting ~e\'('nth priority I'm' unpaid inromf' t:\:'(C':, m;- :-:ps~l'd \\ithin ::!.HJ d:1Y~ Ilrf'lll'titilll1 l'Huld hI' ~n~p{,lldl'rl d\1l'illg' !,,'nnl'o(',V uf dt'htnr':-; IHilll' (:h:lIII('I' I;~ prlwt'l',lill/.!, Affi1'll1Pll. . 11"I1I(ruJlI('~' C=2!lriH A~~t'~sm('nt period under nankruptl'~' Code [lrovi~.;jon ~'Tanting .l!o\'ernment ~€>\'enth priority for unpaid incomE' taxes asse~'$pri within 240 days prf'flC'titinn ma)' hE' ~u~'lt'nd- eel during p€>m!l'nc.v of prior h<lllkrupky ('a:-:p ba~('r1 on hankruptcy cnUl'f~ ('f1uitahle pO\\'- ers. Bankr.Code. 11 U.S.C.A_ ~~ 1O,,(a). r,(Ji(a)(7)(AHii). " , i~~ , : .,~.;~. ['<" "."., "~~!' I)' ~\Ilo:" ......;1r.".'....~ - ! " "i '/" , " .Jam('s L. Bpnlll'.v. Dt'1 City, OK. for apppl. lant Rant S, Holdernpss (f;ar,Y D. Gray, T.lx Oiv,. IlI'Pt. or ,111:-11 il'p, Wa!'hing-lon, DC. and .fanH~s A. Bruton. Ading As~t. Atty. (;('11" or l'oun:-;t'l; Timothy 1>, LI'ollard. 1 J.S. Ally" \\ith hi'" on the Iwil'f). I'llI' aPPt'lIt'('. " r Hr.rlll'l' 1I1\OI:HY :11\11 1,:1:1,:1., {,in'llit ,lwll'I'o..:, :1I111 :\1('\\'11,1.1,\\1:-:, :-:"lIi(11' ('irl'lri! .JlIlh~I', ;\h'WI LLlA;\f:i. :;f'nilll' ('ir('uit -'lId!!!', Thie.; j:-; a h:lnkl'llpte,\' (':t~f' ill\'okill!! ~11('l'I'''~ ,...i\'(' p('litillll~ in 11:lllknlpln', '1'111' 11:IITII\\' isslll' 10 hI' n'~oh'l'd i,.. wIll'! 111'1' 1111' :! 10-41:1,\' :ls~t's"nU'nt ['f'find pro\'idf'r] for 111 II [1,:;,(', ~ :1071:tWj')(AHii) (:;tlpp.PI!I~) ,..;lnpllt'd 1'I11l' nil1J! d\lr;n~ 1111' pl'llfl('rw,\' Ill' 1111' Ii 1'...1 I'l'li!il,n fill' h:lII!O'llplc',v. TIll' H;lld,l'Ilp!I',\' ('''II!'1 fill' Illl' \\'1'..ll'rn Ili"lrir'\ Ill' (11,1:1110111:1 Iwld 111;11 Iht, ~,IO~day pI 'I'IIH I \\-a" ","II"lll'I1c1I'd" dlll'illL! thl' p1'ndl'rw,\' of 11\1' ril'"I II:lIlkJ'llpl.',\' pl'n- . PRNTEL v. CITY OF MRNOOTA ImlC:IITS CIII!Il1113 1'.~(1 1261 (Mlh ('Ir. 1""41 4. ZnninK nnd l'lnnninK <PH Fed~ral Cornmunicationg COmmigRion (FCC) mling felntpei to amalf'ur radio fReili. th~R prp.cmpt..q zoning orctinancl' that. city hm~ not app1i{'rl in mannf'T that TPilRonahly ac- ('(Jmmodltt('~ nrnalC'ur ("ommllni(,lltion~. Sylvia PENTRL. Appellant, 1 i 1 ~ v. CITY OF MENOOTA HRlC:IITS, Appell.e. Nn. 93-11126. 1 I I ! lloit,cd Sbll('~ CHurt or ^pp('nl~. ~~iv:hth Circllit. Suhmill"d Oct, I~, Iml:!. Decided Jan. 18, 1994. 'I i Amateur radio operator sued city, claim- in~ that zoninR ordinance, pur~mant to which she was denied permis~don to erect f>8-foot radio antenna tower, W~ preempted by Fed- ~ral Communication~ CommiRflion (F(X;) nll- ing T(,fllliring re;ll-lnnal,le 3rcOInmnclation (If Amaf.i'ur communicationN. Thp (Jnitt'd RI.nl(,R District Court. for the DifltriC't or MinnC'!-\ota, Donald D. A].op, ,J., entered summary judg- ment for city. and amateur radio operator appealed. Th" Court of Appeals, Bowman, Circuit .Judge, held that city did not reaf1on- ahly accornmnrlatp amat.eur radio opf'ralor when it Iimitf'fi her to continuing- u~e of ineffective !)fi.rr-foot antf'nna. ami thcreforf' city'~ 7.lIning ordinance W3f1 prf'cmptrcl. Jlf'VpnH'fl lUlCl rf'mnndNI. 1. Federal Court. ""'776 DiRtnct court's grant of Rummary jurlg- ment iR reviewed de novo. Fed,RulcR Civ, Proc.Rule Sf/(c), 2R U,S.C.A. 2. Federal Civil Procedure C=:>2.t70,1 Summal'J' judgment is appropriate in fa- vor of party that if1 pntitlcd a~ matler of law to juclgrnC'nt in it... favor whprr prll'tic~ agr('('r1 that nil rnatprial fa('t.'1 arf' in di~p\lt('. Fl'd. Rull'~ Civ.Pr'(}c.l{u!p fJfi(t'), ~H n.S.c.A. 3, Zonil12' and I'lanninl{ C:=>1.t Zf)nin~ ordin:mC'f' that nPlth(>r hannl'd nor imposf'd lIn.....arying lu'ight rf'!-\tricLion nn amati'uT Tadio antf'nna.... \\'a~ not prf'f'JIlpti'd on it<:. f:u'(' h.v Fl'df'ral (~flmmllniration~ (~orn- mi~.~i()n 0.'('(;) nJling J'i'latinj.! to arnaLl'\lf radio fai'iliti(l~. 1261 5. Zunin,R' nnd Plnnninlit ~1.I, 65 Cit.y'~ fh'('ilolinn flC'llyinJ.! 1II1111tPllf rmlin IIpC'rntol"t-I IlJlplil'llt.inn for 1.llnillJ.t' \'lI!'inn{'(I III rrl'd, liX---fuol rndin nnlt'nnn lo\\'('r. Illll! limit. ing opf'rator to ('nnlinuin~ URe or int,rfrct.i\'{~ lifl.f)-foot antenna, did not reprrscnt rp3R0!1- able &rcommodation of amateur ~ommllnica- tions. ann thus city's zoning ordinance Wa."l preempted by Federal Communications Commission (FCC) ruling pert.ainin~ to ama. teur radio facilities; city had no reason to fear that antenna wouM interff're with other frsiclrnts' r(~c('ptinn, npC'ralor addrpsg('d any ('oTlCf')"n for puhliC' HRJ('t.V, llny finrlin~ t11llt. opf'rator ah-f':uly MlIrl'f'~Hrlllly I'nJ.!a~f'd in nm- ateur communication~ wa.'\ lInrea.~onahle, and concerns over aesthetics were undercut by city's agreement to allow operator to main- tain present antenna. 1\. Zonin,R' nnel Plnnninlit ~l.t Frdrral Communicat.ions Commis8ion (FCC) ruling relating to amntf'ur rommunirl\- tinn~ r('(l'tirf'~ muniripnlity Rl'C'kinJ.! to l'"forrl' 7.onin~ ordinnnrp t.n Il('('(llllmol!lllf' I'l'n~nlmhl,\' nmnt.I'UT rOlnnl1ll1i('utinn1<t, nncl d(ll'~ 1101. pl'l" mit munieipalily :-limpl.v tu halam'l' it~~ inll'T. eRtR agaim;t federal governmpnt'~ intE.'rf'st.c:; in promoting amalellr communicationR, 7, Zonin~ nnd Plannin~ (;:::::>14 Requirpment in FedeTal Cornmuni('a~ tionR CommiRRion (FCC) nlling- t.hat city rea- sonably accommodate amat.eur comrnunira- tionR does not require city to allow amateur to PTC'cl any anwnna shE' df\RirC'R; inl'ltcnd, it rf'll\lirl'!'l only that. ('ity rnn~idf'l' lIpplil':ltilm, malH' fHl'luul tindinl!~, lInd :lltl'lllpl to 11t'~()ti- atr ~at.iRfal'l()r:\I l'onlJlrnrni."I' wilh npplirant. R, i\lunicipnl Corpnrntinns ~;,:I Zoninl{ nnd I'lannilll{ c=>t.I Local Tf'gulntion that. impai~ nmatf'llr radio cnmmlllliratinn~ i!'l pfl'f'lllpl('d a.~ ap- r1it,tl h,v Ft'll..ral ('()mmIlTli('atioIlR ('(lllllllis- silln (FCC) ndinj! Tl'btinj.! In anml(',.!' {'PIll- ~ . () 1262 1:1 FELlEltAI. Itl<:l'0I1TEIt. 3~ ~mluw., .1 munkatiunti if city has not cruftcd it to make reasonable accOTnmodatlon for amateur cum- munication:; while using minimum practicable reboulution nccc::;sury to accompli::;h city's le- gitimate purpose. ;,1 John llollow.. St. Paul. MN. argued lChristopher L>. Inlay. WUhhinb>tun. DC, un brien. fur umicws curiae. Eric J. Nystrom. St. Paul, MN, argued, for appellee. Before McMILLIAN. BOWMAN, and MAGILL, Circuit Judge.. UOWMAN, Circuit Judge. Pur~uant to its zoning ordinance, the City of Ml'nllota Height:;, Minn<!tota, denied Syl- viu Pt'nt.e1. un lllllUt.eur radio operator, per- mi~:;i\l1l tll cruct u tiS-fmlt radio nntcmm tow- er in her yard. Pcntcl then ~ucd the city, claiming that tilt! zoning ordinance wa.'i preempted by a Federal Communications Commission ruling known as PRB-l, which requires the city reasonably to accommodate her amateur communications. The District Court granted summary judgment to the city, and Pentel appeals. Because we con- clude that the city did not reasonably accom- modate Pcntel when it limited her to the continuing: use of her indTcctivc f)ti.f>-foot untenna, we rcVel1iC und grant t;ummary judgment tu Penlcl. }~ I. :'Hif:., 'iii,'.i, , :i.,~f::;l' ~L -11':. ~Ft.., 'Ii"~i:!.\. "-lLtJi" .~t" ~'I"i,';.,.r ~.....,.,.J; ",..,.Ii'n:.', :~tilF'''''' - ....~"...' ~:tr;I~:.ie ~,'L~';"o-, {"";;i;'IL; ;'..;",;".. ~.':,""1'''''' : of. ,,~~, i\.j:Fi;:. Penlel i~ an runatcur radio operator who u~e:; I'Udiu cummunicatiow; to .serve the puh- lie intcre.st. After .she wu~ licemicd hy the FCC in DCl'cmum' l~J~ tu operute un ama- \A'ur rutliu 1~lld a Hlutiull from lwl' hOIllt!, hht: iH~Iu.lh'd Illl 11\'1' rUllf 11 IJPrl.kul nulitl Illllt~IIHU l. Pnlld':-, IlLUlJl,:".J ,1I1h'lllLlI \\Iul1l,llw lIUlll' d. Ic-,.i\',' lli.1ll hn ,':"I:-.(;UI\ :....,I-ujlIOl !wn 1,'0.1'..111:'. 1'1I':!;1, PCllld':. ,-\lnt'IIL \'cni,'al Ulltl'lIl1.l JI~:'lp<.lll'l> ~igll"b ill .Ill dilt'l"\hllh, Wlllk her IllOJlIl:>,.J di. icr.:titllli.-ll alllCllll.l wllulJ COl\!.;cIlII'iJ,tc allJ culled ~i~lIab, tilu:> 111'1..:..1:-.1I1~ hl'r ;.IuililY IU 11'<.lIL:>lllil i.lnu ICl-,'lH' ill ... ~p,...:Lll!.: Jin:...tiull. S.:cunu, .III i.l1l1":lLll.l'S dk..:ll~'Cll':~:' illllC.lSo.:S With il~ 1ll..'I~hl. PClll':!''' l'~I,>lllll:: JlIteJII1J i::. tJlud...:u tJy IIt'e::.. IIl:r talkl II:plJ""'lIlelll .lllt':lI11a. Wlil'll c.:AI....lIl.kJ, would bl' '-It lJl 1I1';J.lllu.: lOp::. 01 nCi.lrby IIC":'>, Ihu:> illlpIU\'IIIj,! h,'1 ~1~ll.l1 II ;.111:>1111::'::'1011 allll "c~:l'pliun. thut reuche~ a heighl from the ground (If uti." feet. Ov~r the next two year~, Pentel was unable to etltabli~h reliable radio communica- tionH with other amateurs acrmiS the Uniteu States, and she was able to establbh unly one internutional contact. Pentel concluded that her existing antenna thus Wati not adequate for domegtic, much less international, com- munications. .1 " , Accordingly. Pentel began pr~paring: to in- stall a more sophisticated antenna. The re- placement was to be a retractable steel tower that mea::iured 30 feet when lowered and 6M feet when fully extended. Thh; tower. which P~ntel planned to have installeu prufessional- ly in accordance with its manufaclurer's tlpeci1ications, was to hav~ mounted on iUi tup two directional aluminum antenna.:;.1 Pente! wa.'" unaware when ~hc imiwlled her urig-illul untenna that Hhe WID; vihlaliug' Uu: citY'H zoning urdinance, which Iimitn ull t1truc- tureM, including r;.ulio antenna.'i, to a height of twenty-five feet.2 While preparing to install her new antenna, Pentel became aware of the city's restrictions, and in January 1991 she filed for a variance pursuant to Mendota Heights, Minn., Zoning Ordinance ~ 6.5 (1981). The city evaluated Pente!'s application thruugh a planning: report prcpared by a city Mtuff membcr, u.nu at u vlauning cummb~ion meeting: and two city council Ulccling::1. The city then ticnt Pentel a letter in February 1991 telling her that her application had heen denied. The letter did not state any factual findings, re~ums fur the denial, or what Pcn- tel eLluld do to guin the city'b upproval. In an attempt to uffer Pentcl a rCaHunaLlc ac- cUlUllludatiun, ~ required by I TL -re J-'t:dauL l'n'I:IIt/JtlfJlt uf State uwl LIIl;ul Uryulutioftx !'rrflltltill/J to (l/11ult:ur UwLHI FfLC:iljtu:tI, 101 1. T[l~' p.lIll~'~ [,ilkJ tll hUIII~h 1111:' ellulI" \"1'_\1 III q KBA{ II "I Ill,' i\1l'l1UlIt.! IlI-ll;lll:. (Olllllij III UI 1Ii.ll\ll', "H1J \Ill: nly .....u:> 1I1l.lhl.: III hlll1l~h a u'l'y Wb":ll \'I1111i.ldCU by thl!'> CU1I11, We Ju nul plll::.ue the l~:-'UC. hu.....,.v..:r. UCL.!tl:-.l: Ih,' p<.lllll.... .!~I"C;, i.IIlJ ill..: Ui:.tlld CUllII IlJUlIJ. lli.!l till!'> ~u tHIIl Illlllt!'> 1"'llld':. laJlIJ .llll.:lIUJ !I,wer \u .I I11J!l.I' mUIIl hCIj)llt III 25 kct ~ ~ f ~ ! ,.~~"JY-:'~J,}" /.?itijl!;,:"- ~';"'''~~''''N ',.... "';1/",.1 .l'\ ~ ;:'~~~t.J' ~ .~.'- "~'" .:.~ ~~'. .,.,~ ' ';~W" ~!;:'l ", ,.~r' ' >'~-'J?' _t. ~ ~ ij.,,;, r." ~ " ". " .., .... "- .',., . ~1t~~iiTri~:f~;'~\;!~~~;.t!~!~~~;fi1ti~f-!!~{,,~tWr;;I~~\~':1~11t.!~1~~J~~~~!t1f;~~g~j.l1gi~i;\~~Sf:~~~1.tfi;;,~.i,;(;~:l~lf~~~jJ1\;Wli;~i?'(fli'r<:-!'I~~-J~}~ Jt~'~}~it~!mr1'ii~;1~mf~i$1Q~~~~~}01~?~lt;ll'f;;!1~~ql:~1~~.~~I~f~~;,\~;~M~~~~;i~f~8~1ft!1~:);,.f~~,\!!!.!'\.{!4Wi:V;j\!:w~.:;,;~~:~t",f;~~;'{~;$tM?' .jiii;~.lft,:'~l':"'~r' '~l~?~~..~~~ .j;~'J' ,'f '... \ .,'" .' , 'A,"'''''] . - ~"::f1~''''''''''':-',''''C'f'''11'1~''I;;,,~;,~,'+~.~S~I~~'' ~.~~_'., .,~'(>_.., ,-,r;;H"om~~~"!~.$o:v~;n"Jl~--il' -l, . ' ~.\,.c'''~I~':~ ~}.t.., - . ' -"". " 'I." ';'-' ," '".. ,-', ' \fit l.\\~,~.:t l''l'':'''':'''l"t ~jt~:':,;: 12fi:l PENTE!. v. CITY (11' MENIlOTA lIIm:IITS Clle..U 1'..111 1161 (Rlhl'lr. 1994) .Il .. F.C.C2d 9,,2, 50 Fed.Reg. H8,8\H (19M) (co- dified at 17 C.F.R. ~ 97.1,,(e) (1992)) [herein- .ner rlUl-ll, the city council wanted P!'nld R Hpr'cial-m-l(' pprmit that allowed hPT t.o con- tinue' IIl'dng her f'xiAtinp: nnt~mna, which ~h(' had cTeclC'f! in contravl.'ntion or thf~ cit..v's zoning ordinancf', r,,"14'1 thr'n n1NI fotllit. n~llinl-lt. t.he' rlt.y in ,t.hl' r )j",tric,t Cf)urt" r111hnhlJ! thnt !.II(' ('jt,.v'!4 OI'dimUH'(' wnH prl'(Ompl.roc! h.v rUH..1 in thnt tnr city hall not. rf':11'onnhly Rccnmmnrlatf'd h{'r, AgTC'f!ing that tn€'re were no e1i~put~'d iAR\I('~ of matt'rial ract., PC'ntd nnrl Uw city hot.h IlIOvf'cI ror flurnma1"Y jl1c1wnf'nt. Th" Ilir.;t.rirt (;llIlrt p:rant.ed summary j1ulJr...'TT1f'nt. in favnr of t.hf' city on all c1nim~.:1 Pc'ntc,1 RP- ppal~, a- ..1 '0 at. ,tp '11. in. 1'('- vl'r fiR ir'h ml- 'r'!o\ top II. 111'1' 1hf' 11,21 We' rl'vlf'\V ell' nllvn the' fll~trl('t cflllrt.'~ hrrnnl. of !"llmmary jtlcl~nll'tlt. 1!uikd srn'r~ rx rd. Gln.s,~ t'. MC'rltrrmic. Inr., fI!j7 F.2d 60", 607 (8th Cir.\992). Because the parties agref> that no material facts are in dh~pute, ~;ummary judgment is appropriate in favor of tne party that if> entitled as a mattpr of law to a judgment in it.<.; favor. See FeeL R.Civ,P. "r.(c); Celntox Co,.,., v. CnfTrft. ~77 U.I'. H17, ~22-2H, H2r.. 106 S.C!. 2,,1R, 2",,2- 1;.1, 2",,1, 9\ L,l';d.2(1 2r." (19Rr.), CnH('~ l'l'ntf'ring' on 7.oning- rpJ..,"llalion~ g'llV- erning amalC'ur raelio antlmna t()we~ prp~enl a unique l(>n~ion among the vanou!-\ parties' inv'r('~tfi. On the onp haml, a local munid- p:llity, through th(' ('xerciRe of it~ traditional police powerR, may rpgulale the hf'ighl and placf'mf'nt of radio antC'nna tOWC'nI {'rf'<'t('d in rl'!\idl'lltial c1i~trict.'t A mllnicipalitY'R moti- vations for !-IHrh rPh"llatilln inrll1df' th!' pnssi. hilili('~ that an anti'nna may hlo('k Uw linl' of Kight of }l"fk!-'hi;1n~ or drivf'rR; ('onst.illltf' a prl1minl'nt f'.Vf'Afll'f' lh:\t llhm tllay int('rfl'I'" with a s('enk vii'w; fall nil TH':ll'h.\, n'sidf'tlt'l'~: Of dp('t'('a~(' prllpl'rty \:ahl(,~. Amatl'uf radio npf'ralflfR, on thl' ot.lH'f hane!. plainl.\' have an int(,!'i'st in tnailltaillil1~ M1C- lt of stall , the she dot..'l ~ n.r) alion \dt,y l:-:~i(ln The ruary I heen aclual !.l'pn- 11. In ,Il~ I-I.r. I,(/(oml lI'i()m~ ".>1,1111 ;1 LOpV 'OJ'. nidi. , ~I u,pv 'jlllr..,III' ;1~'nT, ....I'llClO 1 maIO' 3, In addiliolllO her pret'mrtion dl;dlt-nr:l'. PCllll'l rai"l'd ~'arItHl" "thl'r Iflll"litlltional I'h;dkn~o.:' lh;ll ,Ill' n,,1 l('nl'\~TJ here 4. !'!"Ilter, ari-!lImeot lhal till' lity'" (lrJin:ul(l' I'> vnid l(jr V.11!\\t'nl'"'' j" withoul lnlTil ....-n. A-of,'''' C:E.' ~L' '.'- 0',::'" succe~~ft11 amateur communications ami in RURtainin~ a ~tron~ nfltwork of mdio 3ma- tCUrR, Thr fril('TaI ~o\'f'rnmf'nt'~ int('re~ts Rr(~ l\\i,gnl'd with thORP of tht' l\nHl.t('ur~, rtlr nmnt.f'lIr raclio vnhmt(,f'r~ llfrnrd rl'Hahh' emprg-I'ncy prC'p:u'l'clTlf'R~, nntinnal ~f'(,tll'it,\;, Rnd cli!-la....tl'r rrlipf ('nmmllnication~, R('('llllSf' thc'rl' iH n dire'd, t'('l'l'f\lnlion 11l'lwl'('1l nn I-I.lnn. t,l'nr'!o\ nntfll1lll1 11l'I}.!ht. nlld 1\1'1' nhilily ~IU'('P!ol!-t- fully In trllll!4nlil, lllH1 l'I'('I';\'(' nullo !'l-iJr...'tllll~, f(\th'ral inl,l'rI'Hts Nf(' f1wtl"'I'1'11 when IO('l\1 re~'111aUnn~ fin nnl unrltlty ff'l'It.rict thn erpc- tion of amah.tlr rat1i(l ;lOtf'nn;\R. 41h(' Fr:C \Vll!' nt.t(1ll1ptill~ tn rr(rrf'r Ihe' trnsinn hptv."l'f'n thf'1'I1' intf'rf'~t~ whpn it is- f\uC'cI PHB-1, in whi('h it. atlf'mptrrl "to fltrik(' a halam'p l)('t\\'I'(,1\ t.he rpdl'l'al inhlf(lst. in p,'omnting lImatpllr npPI'lIliom:. nnd thf' l,,),..rili. mllll' int.I'I'I'~tH ur Inl'1I1 Wl\'l'l'lllnl'lIl~ in I't'~"l. Int.hlA' 111('111 i.OTlin~~ 1Il1l11('r~." I'Hll1 11 ~~, Anf'r wlq~hiTlJ( loclIl, fPth'ml, lUul 1I1l111h'ur intf'l'l'st..co, tht, FCC iSHUpd a ruling- thai haH It limit-efl preE'mptive efrect on local regula- tions. See PRB-\ ~ 21. The federal courLq that have addre~sed this roling have upheld it.c: prE'emptive effect. Srp, e.g., El'rllls P. Board of County Comm'r~, ~l91 F.2d 7!lfi, 760-<1\ (lOth Cir.199H); Than", J!. Cilrl of IAlkf."irlc I'arl', Krl.. 779 F,2r1 1\R7. \lI~S~~!l (r.th Cir.\~Rm (per cm;am). rH I CnurLq llppl;'in~ PH B-1 hll\'e (lis- C'crnflr! two 1111'l1n~ iI.v whkh rHH-t IlIl\Y preempt. a local ordinanrp. FirRt., the local regulation may he prpemptf>d on its facl'. The city'~ 7.Onin~ orflinancC' dop~ not connirt on it..... face \\ith PHn-l hpcausf' it nl'it.hl'r han~ nOf imr(l~('~ an lln\'ar~'inK h(';ght rp- ~tridinn ('In amatl'lIr radio antpnnaR. S('(' f;I'r"'.~ I'. H(J(lm (~( ('OI/IIfll ('fim",'r.~, 7;12 F.Sllpp. !17:1. !171i-77 l1U'oln.I~I!IOl: HlllI-hi.If 11. ('ifu of ";dmntld.~, liil F.Supp. 1~7n, 1:!7,\ (W,I).\VII~h.1!1.1.(7).1 -::,1';:, ,'-.-',' 'if. ~ri]',H; \;:]~:. :; , , ~, ":' WI;,,: ' :~jj~<';: ~."'~ ~-.' : j,;)~\,., ~~,;::;:. d ~~:;', ~:~1~~- ;'~:." ~;'~i\c, i:<'-:"~ , ;i~t,<: '",'1,-.' ~~:"! ~~\R .!h" ~f,~:.:r:; Vi'!'.'" ~jt~:"~( ...,jl,'" "pi.." ~f:t '7<'-"'/" "":':,1, t,(;::" '''~'.'r ~t~J.;; ',l,-'~:'.l a"" t~:h ~~",,\'i J):.,~,l ~6, ~}\ -i~l. W".. . q"i':. 'r/!'" 1dv; ~;i.' ~',~}~ ~;"~. t~~ ~:;. ~.~ ~. ;>1: '"", ,.,(.;.'" 1,1.:;1 SpelllHI, I'HH 1 :lll'ltl pl"'I't1\pt.~ a 7,onlll~ flnlin:UH'I' th:\l a {'iLy h:L" nol :l\lplil'c1 in a mannE'!' !hnt rl':l:,ollahly :In'llmmndall's amatC'lIl' rOllllnunicatllllls. ,..,'"" I~'/'IIJ/.o.:. !1!1,1 ,!.'r 1'_ f.iIIl'''H1. 461 1l S_ 1"2.1"7 ."K, 10' STl 11\',", 1!I~R--"4. 7<:, LEd 2d '10' 114"Q. Urll1dHl\ \. ('if" Il' ('p/rOlr}.w. 'Jill'> F2d <J',lol. <JlJ~ (~lh fir l(Nm ~ . \~ ~ .. . o '" Wi4 13 ~'EDEI(AL REI'OUTEU, 3d DEitiES e t;i K .it:. ,~tt; ."",.. ~:~%~.; i F.2d at 71il; MacMillaa v. City uf Rucky Ri,,,,,, 74M F.i:iupl'. 12<11, 124M (N.D.Ohio 19UO). The FCC refm;ed to specify a height beluw which local govcrnmt-'n18 could not reg- ulate, and in:;tcad dedared that "local regula- tion::; which involve placement, screening, or height of antennas ba.~ed on health, safety, or Iwsthl'til' cOIl:-;itlerutions mu~t he crafted to Ul'l'Ullll1llltlulll I'cu:;onuhly amuteur conulluni- ,'ulltHlto, nlld tu 1't.\llI'l'ttt'llt thn minimum prul'- tkuhlt' n'~ullLtioll In ul'Cllmplil'lh the luculuu- thol'ity'.s It'j{itimate pUl'pose." PHB-l ~ ~5, "~':' '~i;j :-.~~J- ',)" Ltil lnitially, we mU:-it discUMS lhe extent to which this lanb'Uage rctluires munidpali- tics to yield tu amateur interests. Although sume l'ou~ have evaluated whethcJ' thc mu- nicipality properly balanced its interests against the federal government's interests in promoting amateur comIllunication~, see n'illiulIIs I'. City I{Culumbia, WG F.:!tI U~H, !J!)~ (.lth ril', HJ~IUl; MIlI'AI illu/l., 7'H'i ....::;UJlII. ut 1:!.11:"1, We read PHU-l l~ requiring mUHici~ paUtie:s to do IHllrt..,-PHB-l ~pecitically re- quires the dty to accommodate rea:;onalJly amateur communications.a See Evuus, 994 F .2tl at 7ti:!-G3. This distinction lli impor- tant, ut.'cau.:'Ie a staJUhml that requires a city ~o accolllluodute amateur communication::i in a I"t'aSOllUule fa8hion is certainly more rigur- Oll~ than one thut .:-;illlply requires a dty to hululll't' 1111'111 lIlltl fl'lIt'rill iHtt~n'tob wlltm <le- ddlllK wlll'lIwl' tll }Il'rIllll U l'udiu UlltCllllU, , ~ .: , . 11.til ^11lllil'lItitlll Ill' lllb n~u~(lIIUllle uc- CUIlUIIUllatioll :;lulldllnl, hllwtwt~r, doc:; not rL!- quil't.' the dty to aJlllw the amateur to erect any antenna :she de:sires. Instead, it require::i only that the dty "cunsiderl ) t.he application, malkJt;o factuallinding-s, ami attemptll to ne- gutiate a :satisfactory compromi$e with the appliL'ant." Huwurd v. City of Burlillgwne, !I:n F.:!d tnli, lal'iU Wth Cir.WUl); ;lei e.y., f;I'(/JI.~. HU.t F.~d ill 71i~ (stilling- that tlH~ l'llllllly WilS wlllill!!. III 1lt'r1nll a lTilllk-ul' low- :';~;.j; l:, ; .'J"~.l ~~l. '';':';1 Ij'~, : .~.~<;~ ' _1,-, ;.."r. I'i. ~ i;'- 1:~, ,',' 1 '" ~ , 5. AI \;'.111UUS p1...I~I.-'~ in l'I<i1"I, 1 hI.-' FCC ~I.ttn Ill.11. III Ulll~IJlTIII~ Iii..: b...U": hdUlL' it. il wL.IgIH.:J kJ~'l.d ,IlIJ ..l11\,lll'lll "1'L'I<.IlUI' illh.Tl'~l"> i.I~i.lllbl Ih,,~..: ul 11l~;'IJ h,!\'.:nllll.:llb. AltLT h.d,ll1~'lllg lll~.~"" 1llIl'll'~h. Ill": ~I.llld.lId lh.J1 lhl' FCC lUll' dllJl.d \\,1:> .IPPI"pll.Lll' \\,1:> lh.lt.J IO~.J1 WI\L'lll- 1l1~'llt 111I1~1 I (."""lI,,(,jv .".L"III1\I"d..l" .Llll.Jl':UI ....- Jhl lOllllllllllll.IIIl/ll" ........ I'I<B-I ~i'll !~, !4. er, a shorter tower, or a tower located else- where); Wiltiam., 906 F.2d at 997 (stating that the city suggested a limitation on the hourH the antenna could be extended, and noting that the amateur could apply for a shorter antenna). Under this approach, a local reb'Ulation that impairs amateur radio communil'atiom~ iH preempted aM applied if the city hUH nut crufll:d it "to accommodate rCHliUlUlbly umiLtl~LIJ' CUllllllllllil'utiulIl'I" whil(! utling "the minimum IJructlt~uble fl'gulllliulI lUt..'CCtiMaJ.y I to uccompli.sh the local authuli. tY'H legitimate purpul:l~," PHU-l 11 ~rl. The city illfunneu I'enl.cl that her applica- tion had been denied via a bare-uone!:> ldrer that did nut. list any haKes fur the denial. Because the city council failed to make any factual fiJldingti,li see White Bcar Rud & Glm Club v. City uf Hugu, 3MM NW.2d 73~, 742 (Minn.19~6) (holding in a case revicwing- a tity cuullcil'ti denial of a :;pt~cial-usc pUl'IlIit thaL u cryptic IitltiuK of rcasullli for the dellial did not constitute factual fil1ding-::i); VUlt- I.umJ.:;chuulv, City of Mt:llduta /It:iyhtli, :titi N.W.2d 503, 509 n. 7 (Minn.l~l>3) (.tilting that variances and special-use permits are treated identically on judicial review), We need not comdder whether, if it had, such findings would be atl'ol'dcd preclusive effect here, lice U"i-vul1it/J of Teull. Lt. Elliutt. 47~ U.S. 7~, 7U7-~IH, lOti ti,Ct, a~~o, a:!:!fr~~7. ~~ J..I':d.~d liar, lIllMli). AlthulIl{h the dly t'ailed tu make allY fllclu- ullilldillgli, lhe 1'11111Uillj,{ I'qlurt uwl hl'iH'illgti SUg~l~~t fuut' putential jUHtilkaliuntl fur till! city's denial uf Pen tel's variance application, We now turn to those justificatioll:;, Fir~t, thc city had no reason to fear that the ant..t:n- na would interfere with other resident..;' tele- vision and radio receptiun; the city's plan~ ning repOl1. ~t.ares that Pcnt.el wa.... prohibited by the FCC from causill~, alld that :;lte l'uuld lose hl'r 1ll'I.'Il~l~ if hhc fuih.:d tu t;'OITCd, M.lt.'h iJ Ilrullil'llL th th 1', er CL th ifi cL I" 1'1' W, I!. tu ell p, tb cit re .1, C.'(1i ap JJU co, ad tel tiCl to ~Il,: III., UIl Wl" ',a, I of ti(J1 m,' cun ext ind, tu j tIll' t i ~ r l: b. Mt.:IIJlJt.1 Ill.lghl~, MllIo_, ZUlllllg ()IJlll..I'~": 9 S5(S) (l'Jbll ~L.JLc~ Ih.Jl tbe LJl~ ~UlltlLd'~ ..~ lioll III (kJl\'illg .J ViJrhlllL': .Jpplll..ll"n "h..liJ t.:UII~tl\lll~. .J Il1lJIIlg ..llJ Jdelll'lll..I..,11 I,. tl'L eil\' ("Ullld lh...t Lh.: luILJ'lh'll) 1''1,,1/,.1 1"1 'LI'IHtl>,d dll llul l'\I',1 filL) ~'''L~ld.''!I' 1,,1, J:::ll,'~'l- d",.." 11l.L 11I""f.k .J lUlUl \\It1. ...... .I", LI 11ll.lll~,!, nILrrll~.I.JI..:J l..dLl...IIII'U"''':~ I" .....l" TII..: lll:-- 111..l) Ii....: Illonk 1,'ltLI..l1 IH'U"'I'i'> J.ll Ih PUlllU"c.). bm IL b.J:O Ilut ("1 "Lll' llll:-o IUd l'all cha, ,ulll pen k.\t btilL .1 '; ,> " h '1 " I~ 1- rl{ Ii' n. I, ,. 01 ld ., ,. "I 'W " n ," PENTEr. v. CITY OF MENIlOTi\ llEIWITS Clcu",l.\ 1:..'1112(01 IflthClr. 1<J94) I I j i Second., the city expressed conccrnfi nbout the tower's Rafety in light of the fitrong' wincl~ that frequent the MiRsissippi RiveT valley. Pentell'reRented to the city the manufactur- er's spccificationR, which rate the t.ower Re- ('UI'(> in eighty-milp-per-hollr winch:, AI- thou~h the city generally rc1if-':" on Ruch RpPC- ifictltinm; producer! hy manUr:-ll'tllrcr~. it de- c1inf'r! t.o dn Hfl in t.his (';\."1". In mlclil.ion, Hll' tow"r wnR ret.rad-ahle, unci the city could require Pentel to retract it whenever had weathf'r threatened, Moreover, the city in 19R7 alloweri a ncarby amat.eur radio opera- tor to erect a gimilar tower, amI that one was c!ofiPr to the operator'!' property IilH' than Pentel's W3H to he. The record bpfore us lhw:j doeR not cstahlish a factual ha.~iR for the city's Rafpty rOnt'f'rn~. Third, fill> dt.y 1'Iu_inlt\ t.hnl It. hf-'lif'\,pd it. rf'Ilf4lmll.lly IU'(,lllnmrullll('fl r'l'IlII,1 1II'('II'I~\(' flhll aln'url,V 1411rc'I'R~flllly f'n~;ll!('~ In nlllall'ur cnmmuni('atillnR, Pl'n1.('1 f:lllllnittprl with hc'r application a letter of commcndation for hcr puhlic sel\."'ices. The city's planning report concluded that thi. letIRr demon.trnted the adequacy of Pen tel's current antenna. Pen- tel has pointed out, however, that the puhlic Rervlces cited in tht~ letter were not related to th(~ am:Itpur commllnications in whirh she f'ngagC'rl from hf'l' homf'. In fart, t.hl' If'tlf'r makf'H it rll'ar thnt. thro Il1l1l1t,I'Ur ('onlll1unir:l- tionR for which l'enld \\'a~ 1.0 IJ(~ rOllllnpnc!l.c1 were conducted at the Air National Guard base in MinnC'apolis. In addit.ion, the mayor ami SOIllP mpmlwrs of th{-' ,'it)' (,Ollncil indil'Jlif'd in UH'ir lkpn~i- tinfl~ t.hat l.h,'y ('llndudf'd from Pl'llld':: ;.;l:lt('- nJf'tll.<;. at till' hf-'aring!-; that. ::hf' :iln'ad,\' W:l!-; r(]mnllll1il';lt,ing I'fff-'rth'f'ly, alll('it, not. to th(' !'xif'nt !-il](' df'~il'f'd. Till' hl'al"iIlJ~~' Illirwll'!-I indil,:ttl' that 1'r'lltI'1 ~t:ltf'd !hat. ::Ilf' W:l!-; ahl!' tll rt'ach only !'Jloradically \'ariou~ pla('('~ in I,hl' llnili'fI St~Lt.f'~, alld that 111'1" ('llITI'n! :111- ll'nna did !lot allow rl'liahll' I()ng.ran~p tr:\m~- mission:--. \V1wll prllmptf'd, hpr attorn/'y re- luctantly altpmptcd tn quantiI'.... the communi- cations: h(' rh:lI.actt'nzt'd Pt'ntpl's current ehanel's for making C'ontart at .10 l1I'rl'l'nl. and pslimated I hose ('hanel'S at. Hfl II! !)U perr(-'nt with L111' improv(-'d to\\'l'r. Thl' ('on- If'xt of t1H',<';1' l'f'marks anrl rf-'ntJ'I'~ nthl'l' !'tatf'mi'nts indi('atp tll;lt thl';';l~ chanel'S Ill' i I I I j I I , 126:; SUl'l'e:-1S refcrred to clomf'stic communications only. ThiF\ quantification of renters ahility to communirate wa.~ thoroug-hly mischaractpr- izrcl hy the mayor at his deposition, when' he fl.tatpci that rente] wa,q able to ('ommuniratR world\\;de HO to 70 pf'rrpnl of thp timp, hut that !'h(> wnnt.f'd to havr rrliahlp worldwirlt\ communicntinnF\ 100 !lrrc:"f'nt. of thp timC'. One city councilmcmb{,1" under~tood Pt'nteJ's st.3tement..~ re~ar(Hng hpr tram~mi:::.sion suc- cess, hut others dE'mon~t,rat{'ri a fuzzy under- ~tanding, at hest. of Ppntpl's situation, Al- thotf'g'h what constit.utps "sucre,<;~ful" arnatl'ur communications is difncult to quantify, t.he c"idf'n('f' in till' I"pcord dol'S not jll~tify a finding' h.v Ill(-' city tlml ppllll'r~ nld lIntl'TII111 f'Tlilblf'd hpr "RlI('rt'~Rflllly" 10 1'1l~a~p in lUllll- IA'ur ('lIl11lllllllh-alloll1'(, llllll Iht' dly \\'ll~ ll11rl'll- ~lInahlf' if it. ~n found, ()II I hf' I't'('ord twflll'!' ll~, thp ('ity'~ fil"fo:l thrl-'t' l'(lrll'rI'nS I:wk f;wtllal f\Upport, The city's la.~t reason for denying P('ntpl's application, that the antenna tower would he unsightly, rest...~ on subjective cnnsidt'rations and is difficult for a r('\'it'\\;ng l'ourt to pvalu- at(', This 1"f':Json is lIndeJ"{'lIt, howl'vt'r. hy thl' ('ity',<; \\;lIin~nf'sg tn allow rt'ntl'l 10 kf'f'P hl'r prps('nl rnnf-llIollntpt! Hlltl'lInn, which rl'll('hf'S lL hl'i~ht. only ~li)~ht\y lu,llIw Ihat {If hpr prnpospd antenna tmwr, and hy t1w city'~ allowancc of a similar anh'nna tOWf'r nearhy, \\I"p acknowll'dgl' th(" p(l~~ihl{' :U'...th- (,tie c1ifrl'I'pn{'t' hl'twl't'n :\11 :mll'nn:\ tllWl'r :lIld a !"ouf-lllounted antl'lIna, hilt llwl.f' i:-l nil indi. ration in till' I'I'l'ord thai tlu' l'it.... attl'llIplNj to liTHI ;lny rlllllJmll1li:,,1' Ill:lt \\'Clllhl h:I\"I' ;1('- 1'lIllll11nd:lll'd 1'l'l1tt'l\ :1111:111'111' l'orl1lnllni(':l- t.illll!-;. Thl' city'!, df't'i::inll to 1:1':1111 a \.:ll"i:lIlt'I' 1 h:lt allow:: l'c'llk! tll contilHll' lI:"inl! a \\ holl,\. in:l<!- equate antenna d(l{'~ nul ('(If):,,tltull' an ;l('('l.m- rnodation in any practical :'f'n::l'. r n addilIoll, hpcau~e the city did lIot rt'a:-:onahl~' accom.modate PI'ntel, it o!1\;flll:-:l,\' did nut ll~t' the ll'a,<;t rl'~tl;eli\"P nH'an:: avallahle to nu'pt it... If'j..'itimat(' 7.oning- IHlrp(l~I's, Wl-' llwn'fnre hold that t.he cit....'... 7.onil1~ ordin:lncp as ap- plipd in lhi~ (':I:-:e i~ prpt'mptl'd hy PitH-I. .' . () 126(; 13 FEIlEltAL HEl'OltTElt, :Jd i:iEIUEi:i . Ill. 'j Wt~ e..xhul't the parties to wurk togcther III ulTivc tlL a lmti:;fw:tury ~iOlulion to lhitl con- trovcrsy. PltH-l l'CllUil'Cli the city rCUt\UIl- ably to accununuda.t~ Puntel'~ n~cds as an amateur ratliu operatur; what i:;; alluwed hi the "millilnulIl practicable I'cgullLtiun tllcCt~H. tIoury) to w.:colllpli:-ih the local uuthority't'i l\~hrit- ilHuttl purptl:-ll'," PHB-l'l :Ul. The llil':lLl'id. Cuurt's ~rulit of SUlUllUll'Y jutlgment tu lhc city i:; 1"l!\'cl'sl'd, antlthc n.L....c i:; remanded tu thl' Dbtrict Cuurt fur the clltry ul' sUlIlmary judl-,'luent in favur uf Pcntcl. Our decision docs not mean that the city neces:;arily mm;l b'Tunt Pentel'.s application as it now stands, but it does mean that the city must make a reasonable accommodation for her interests. . w o ~ U, "'UH8IR ~l$nM T Urian KEENAN, an individual resident of the Stute of Minnesuta, Appellee, v. COMl'lITElt ASi:iOCIATEi:i INTEH- NATIONAL, INC., a foreign \'ul"l'urutiun, Apl)cllunl. No, !):~~J2li 1. United ::)tatt~S Court uf Appeal::;, Eighth Cireuit. Suhmitted June 1H, 1993, Decided Jan, 21, lUV4. EllIpltlj't'C hroug-ht al'tilln cig-ainst former t.:llIphlYI'r fur tldalllatiun awl frauduh'llt mb- n'(lrl'St~ut.Llitln. Tilt' llnitl'd St.ates Disll'il'l CUlll't fllr till' Disu'ld of MilllLc:iOta, ,J. Earl (~udtl, Unitcd Slall'~ Magbtralc JutlJ!,c. CII- tt'n'd jlltl)..;llIcnt tIll jury \'t'l'{lid fur 1'lIIpluYl'e IlIL dl'!':ulLalitJII and fraudulvnt lIliSl'l'lln'senta- tiulI l'j,Lilll:-), allll fOrllwr l'lLlPluYl'1' apPt'alt'd. TIH' COllrt of ^\lpl'o.lb, I LlllSCll, Circuit .ll\ll~t" IIvld that: ll) !'vllh'lln: i"'tUppudt'(t Iindllll! th;lt t'llll'lu)'I'1' did !lilt lJaw qllidtl"ll'tl pn\llt'J!,\' aJ..:ilill~l ddilllL:Llhllllla111illy; (~l t1d- umation danmg-es were not l-':o{ce~sive Of un- tiUlll'Urtcd hy evidelll'c; anti (:I) I!viclcm't~ KUP' ported timJing of fraUllull~nt mbrcprcscnta- tion tla~cd un 1Uitirt~llrcbcntatilJOto l'egur(lin~ jub qualification:.;, Affirmed. 1. Federnl Court. $>776 DUitrict cuurt'::! denial uf motion fur judgnwul a~ muttel" of law i~ rcviewcu de nuvo w:;ing tsal1le tilatulanh; a.... diHll"id court. Fed.ltules Civ.Pruc.Rule 50 note, 2M U.i:i.C.A. 2. Federal Civil Procedure ~2126.1, 2608.1 Judgment as matter of law is appropri- ate only when all of the evidence points one way and is susceptible of no reasonable infer. ence sustaining position of nonmoving party. Fed.ltules Civ.Prue.Rule GO "ote, 2M U.i:i.CA 3. Federal Courts $>763 Where basis of motion for new uial i::i that jury's verdid is against \\-'cight of evi- dtmce, dh~trict court's denial of mution is virtually un~sailable on appeal; key ques- tion is whether neW trial ~huuld have heen granted to avoid miscarriage of justice, Fed. Itules Civ.l'rodtule uV(a), 2S U .i:i.C.A. .J. Lihel ullll Slunder ~ lU H ,1) Untler Minnesuta law, qualified pri\"tll'gt~ frum liability fur defamatory ~latl'lIlenls Cfl- COUlpas:;Cti twu-titep approal:h: defendant must establi::;h exi~tcnce uf privilege, and then burden shifts to (Jlaintiff to prove that defendant abused privilege iJy al:-tual lItalice. 5. Li~c1 and Slander <?111H1J, 1~~(S) Untter t-olinnesuta law, to t':'itahli:-h t'xi~- ll'lll'C of qualilied privileg"l~ 1'1'0111 Iialnlity fur Ih.famatury sLalt'lIlt'Ilt.", clcfl'rulalll Ill'al";" 11\11'. den uf prtlvillg" clllHlIlUnii.:alloll wa,:; Illade upon propL'r ol,ca....;iun, millk fl'lllll \1rlll'l~r pur- pose. and ha......ed upun rea,-,oll,tldl' ,lIld Ill'oba- IJlt~ ~rllulld;-,; prll!ll-'r purpo;.,I' l~;.,lll' <JIlll prop- ('I' un'a~llHI i~sUt' <Jn' ,llwOl.\";" qUl'~lLlJrL-' of law r"r l'OUl't III dt'l'lllt-, wILdt> n';l~lltl;d,jt, allll pl'obalde /..:TtHlfltb i~~llt~ L;-i J..:1't1crally '1'1l'~tllJll of law fill' clJul1, Ulllt,~~ ~\Llil-Iln' 11\'l"llllt~ tiC I I I V " ( ( ~~ FILE COpy RECEIVED NOV 0 8 1994 223 Diviso Street Tiburon, California 94920 TOWN OF TIBURON PLANNING" BUILDING DEPT. October 29, 1994 Grant Pritchard DOC San Francisco Seedon 106 San Carlos Way Novato, California 94945 Re: Your letter of October 25, 1994 Dear Grant; Thank you for your letter of Ocrober 25. I ,,/ill set forrll here the historY of this mauer, which is not reflected in . the mate~ial you have received that origin:uecl willi MI. Samgiss. Inteiference Limired to Samgiss Television Mr. ~"mgi,s i, the l,nJ;: neighbor who has experienced TVI or other interference. I likewise have a te1evisiOll set L."J my ham shack, which has never suffered any sign of audio i.nterfercn'~e, f1ickeTing signe.l, or other problem. There is simply no truth [0 ,t,e elain, t.b:u my signal is being drawn into Mr. Samgiss's house on the cable feed. I sper:t seve!"allL:i.'ys wo'kiilg 'Jil \1r. Sit:ngi::s' television fJroble::n in an effort to be a good neighbor and a rc,;ponsible !Jaru ;:;;tiZCll. He bad complained of television 2.nd w~ephc'ile ;ntener;;;u((;. bilL r could. not dupLicJ.tc: the telephone problem except ,cn a cb..!ld' ~ lOY phone :md an inexpemive intercom, \vruch r fixed wim ftlters. I filterecll1i3 m:lin phone LV salisfy him that every effon was being illade. t'o.ou~il ~lnt pb.one showed no si~'TI of interference. EXHIBIT NO,1 " ( ( Grant Pritchard aae October 29, 1994 Page 2 His television set is in my opinion nor only the culprit in the television interference issue, but a very poor example of engineering, for reasons I will explain. Your letter mentions the findings of the cable company. When the cable company came out, I took time from work and arranged to be 'present. The cable technicians verified that no signal was coming down their line. which makes me surprised when I hear that Mr. Samgiss reponed that th-: cable people believe that "the antenna is toO C lose to the cable feed point. ,. With all respect to Mr. Samgiss, that is not what the cable company found, at least on the day I was there, and it is incompatible with the fact that my own television sets, which utilize a feed much closer TO my antenna man Mr. Samgiss' cable feed, experience no interference, To be certain of doing what I could to verify the cable company's approach, I installed a high-pass filler un Mr. Samgiss' SCL I already have two high-quality low-pass mlers on my rig, one between the transceiver and the amp, and anOL.'1er upstream of the amp. \Vl1en the tirst high-pass did not help, I inst"lled a second high-pass in line with the first, and we gOt little or no attenuation from that entire effort. If a signal is coming down the cable company's line, it is doing so despite their tests and is escaping significant fIltering. The Sony set used by the Samgis~. family is obviously not susceptible to reasonable efferts at filtering 00 ham is burdened under the law with iIllerfe,ence that cannot be cured by l"e:l~f)nable after-market efforts. Filtering is primarily r.he respoDsibiliry of the maIlclfacturer of the equipmem. The S=giss television set has inexpensive exte:-:J.2.1 spe2..k:ers h'lng nn each side of the set, which are fed wilh unsbdded '.vire. :\eedless to say. I zeroed ill on these. I applied sC'/crai tcr:oiLis on ,me wi..re to see if I cotLd discern a difference between the filLered and unfilrered wires---to essemially zero effect. I disconnected Wt;; wit':::; J..U.G believe that th:::rc was no ir;.terfer- ence on the internal speakers. ..... ".'( ( Grant Pritchard aGe October 29, 1994 Page 3 I explained to Mrs. Samgiss, who was present when the cable people were there, that the FCC does not impose the sole burden of avoiding television or other interference on the amateur radio operator, As 'lOll know,. if a manufacturer is determined to cr-::ate a set that will not yield to after- . . market fIltering. it can cert2.ully do so. I have seen many phones, stereos, compact disc players, and television SctS that appe2.l" to violate regulations on filtering. The Samgiss television set is among the worst I have seen. It is \'ery signillcant, in my opin.ion, that the Samgiss television ex- periences this problem whether I transmit at 10 walts or a kilowaLt. We tried transmitting from my rig at both signal strengths without appreciable effect or significant auenuation at the lower power. And remember that it is the only television that experiences prohiems in the neighborhood, including my two sets, which sir within very close proximity of my rig and ?menJla, closer by a factor of five or mure than the Samgiss ser. I \',;ould 'oe happy to try reasonable furdKr filtering, though I am at a loss to know what !liorl: could be appli;.>d, and I believe we would be kidding the Samgiss Lunily by u~ing cosilltl.ics whea cile problem lies elsewhere. Perhaps you can suggest some mare possibilities when you visit the site. My Radio Inswl!ar!on I look forward to your L11spectiofl or my rig and antenna installation, which I have tried to consmlCt ~o the llighest;tandards rl'.a[ are suggested in the ARRL aDd other reference books. I h:.we m IcC'Cl 731, \vl-1ich ;"l1lS to a Commander HF-~500 amp, and on to 2. Gap DX-VIII venical amc!illOl. (Mure \m the ;llltr:nna s!t;.iation in the next .~eC(i~il of thie leC'-c'r.) E\'er;'thing l.:.l cCc' Lnsrall:J.[j()~l is ~ro\lnded to a common copper bus and from the Lus to a gruJ..'r;d ~od. Ground is enh:lIlc~d by an \o1FJ gro\.:Ild wner. W;UCD is as '.'ou ";110W an impedanc," match to ground.. \1;; tra.D.srrllssions pass w:ongh a 0iyc: \'wng 3 KW curler. .The ~ap antenna ha~ S\YR below 2:1 tic lil frcql:<:;lC:::; Oil whkh j, operates, LDc:udmg n_.(. ( Grant Pritchard aae October 29, 1994 Page 4 its narrow llseable bandwidth on 80 meters. I have two Bird wattmeters in line to mea.sure precisely wattage upsrre2.m. and downstream. and I have used the Birds to determine with the appropriate nomograph precise SWR at every 100 k.iloherrz on every band, The anteIlTl:1. perfonm to specs on every test, All coax is highest graue; me antenna i:-; wstalled 1O Gap specs. I Lave had several discussions WiL1 Gap after the Sarngiss interference complai..T1t was first made to me, to be sure that the antenna '.'VaS not in some way amiss, and I replaced the Gap internal coax feeds and inductors at considerable expense, at Gap's suggestion tbat Ll1ere might possibly be a break or sufficient crimp in the coax to have caused a problem. The antenna is perfect. It uses the tr.ree radials prescribed by Gap, and all conne~ti()r,s to ule antenna have been carefully protected from iIlvasion by moist1.:.re and corrosion. It is very important to me L1.3.t YOll inspect my installation, and if there is anything mor~ that could be d(jn~ to bring it to the highest standard. I would be surprised to hear it, but an},jouc. for lie be:l.efit of AR..'li.' s expemse. 171e Location of [he Anrenna I have taken great care and thought to Li.e issue of tocating an antenna and to decidi.ng '""hat antenna to erect. t-,'ly preferer.ee was for a beam antenna for itS superior performance and dir::civity. but I live in a 'lie'.'l corridor to the Golden Gate Brid~e and felt that I could reduce me porenllal of complaints by the lleighbors -by concedin!:( the Y2.gi and living \vith a vertical. I amended my planring approval petition to eliminate the Yagi after carefully advisinz rhe planric.g staff why this \\as d::me J..lld 'Jm r would attempt to experiment Vv'ilt! a veil!cal to see how it worke,i OJ.t. I originally placed the vertical, as Mr. Samgiss has cor:ectly said. behind a trec and wik1.i.~ two or tlu'ee feet of Lb.: extcr;or wall nr my bouse. I wanted co see if it would perfonn reasonably well at a place where it would have the !;:J.st visual impact. Th::, ',v:E th~ [Jla(~ where :he antenna was ( ( Grant Pritchard aae October 29, 1994 Page 5 virtually bldden from anyone's view, except for a few feet over the roof line, and ill fact I believe few neighbors even IOle\V it was there. It performed exactly as anticipatedc--it did not perform at ;ill. My house is pre-war and the walls are loarled wiD1 chicken wire, \vl"lich attenuated and dblorled Lhe antenna in such a way that signals to the east and. north were eliminated. The tree next to the antenna must have had its effect as welL I L.~en relocated the antenna to the only location in which the three criteria most important to me could be met. first, it h:::d to offer reasonable operation ,md minimum attenuation from ne:uby strucrures. Second, it had to offend the neighhor~ in the least way possible, despite being more visible than berore. Tnird, it had to be safe in winds and from passers-by. The resulti.ng installation meets L.'lose criteria reasonably well, although I compromised against criterion no. 1 by putting the antenna about seven feet from a garage wall to keep it as far back from the Slree, as possible a.'1d believe that for UllS reason I gt:l ~igIlifica!ll acttllLl<l.tion to the east and nonb.- east. Using DX packet spots as a guide, I have tuned spots countless times and gotten litHe or not.hing to show for the repol1. The amen.tla is mounted in a base that is sun..1( three feet in concrete, as prescribed by Gap. It has four guy wires, which are probably UQIleCessary according to Gap, but keep the antenna from bending, twisting, and perm- anentlv dist()!ting. It is certainly feasible to move tbe amenna anotber seven to ten J feel to the southwest, but I 1m persuaded tha! the Samgiss lelevision set would nor see a difference Therei" little POlnt in patronizing him with an apparent solution. that in fact is unrealistic. WheIl y,m come to see my in.5tallaticn, I will b~ very open :0 :,'Oll, sug;;estion Oil this sc;)re Ph7.nnin.g COfnmlssion Ccnsideratiutls As you know, Al Bumhalli wenl tlliCug), an crdcal of almost ['0';0 years on his anteana applicalion, '.lihic.:b. was for ? ~lcam antenna La J. d:J.\v where it could te seen from a distance, t,) pis I!lisfGnum:. by DC forme, \hyor of ( ( Grant Pritchard aoe October 29, 1994 Page 6 Tiburon. The former mayor had the clout to make a problem appear where none existed. It has been my hope to spare my neighbors and me this fruitless and misleading experience. A ham is entitled to an effi;:;iem antenna, and the Town here understands that as a matter of law and federal regulation a useful antenna almost dictates a Yagi and possibly a vertical as well, if the amateur demands the right to perform to :.he state of the an. By foregoing the Yagi I hope to introduce a little caLm into the process, but if my appli- cation threatens to tum intO the charade that At went t~rough, 1 will certainly arnend the application, seek an appropriate tOwer and beam, and figure that whatever comes I will have made the effOrt io be civil to my neig.hbors. As you will see when we visit on the site, there is little or no real discretion where the ante una sbould go. The other end of the propertY (the south end) is in the Golden Gate Bridge view corridor, and to relocate an antenna there would produce a serious protes" I counseled with my neigh- bors across the street before experimenting with placemel:t of the amenna, as they would be mOSt affeced by the antenna if it \vere located elsewhere, and they have not said a word of compiaiIlt in the several months that the antenna bas been i:J. its present location. ll/a neighbur has complained of the visual impact cf the antenna, fnc!uding [he Samgiss family. I have recently purchased a Gap DX-IV Voyager amennJ.. and I ha\'e amended my appli.::ation lO so indicate. The Voyager has tile bands that we need for the next three years of dirrJ..n.islled solar flux and the consequent push imo lower bands" Ii has a bandwidth of aboU! 100 KHz on 160, and the full hand on 80, 40. and 20. [wil: r.b.en as>: il sloper for the WARe and higher bands. Th Voyage:- is 4S feet higl.1. wt.::reas the present DX VIn is 33 feet. The Voyager requi.res gl~YS, wb;Ore;:"s ~bey are 'Jptiot121 v:irh [he lower an- tenna. 01ovim: [he ii11tenna loc3.ticm 3. few feet is feasibh:: 3.nd v,,'ould illa.:..:.e ~yli:i.u' (be am;nllcl. easier. Dv movir.," the 2l1tCflQ3. perhaps 10 feet co the o L;' ""'" ~ so{n.b.wcst, away from ,11:: Sal'1giss fa.'Uilv Ilome, we will in.;reasc its visual impact, but move it sum:::whJ.l f"nh:;~ "W3.!, :"romotnJctures and i.c.w a sj.10t ( ( Grant Pritchard aae October 29, 1994 Page 7 where it can probably be guyed with more purchase in all directions, Needless to say, I am entirely open to doing so, but not on the premise that the Samgiss family will feel better about it. because I do not believe Ll:1eir television set \vill be less impacted. What r am not in a position to accept is [lIe eudless "Why can't it go there in.stead of here?" that Al Burnham weD.( through for almost two years, and I am yery concerned that your letter of October 25 may create the im- pression tl"at it should be a simple matter to sarisfy Mr. Samgiss by moving the a.ntenna approximately 45 feet, back where I experimented unsuccessfully with it many months ago. The antenna simply does not work there, and if I were faced with a demand to put it there. I would have to amend my application w erect a tower next to the house and put a beam up over the house where it ',vould annoy everyone who sees it. I don't see a beam as unlovely, but people who are not hams do. I \V;1nt to keep them happy, but Dot at the expense of operating reasonably well. 171e Complaim aoout RF Health Effects It is simply not possible to know how to respond to Mr. Samgiss' complaint of RF effects on his child, because they are /lOC reasonable or- valid. In all the contacts \ve had, nolling of this kind ever came up in his complaints. He has been silem on this alleged issue until now, and I have to believe that he is pulling out ilie stopS simpl>, to force the antenna to be moved, come what mav I dord blame him for being emotior:al, except 'Nhere emotion results in a loss of accuracy. We !ive in an environment in. my neighborhood that is rife with E~lF. The Sarnl!iss family. the Dei9.hbors, and ill\' own f:u.l1ilv ba\'e 2l1tiqu:ucd bigh- VJlcage p~o'.','cr pol~s ru~i1g along m.:' Jo;~gc:sr dimc::~ion of ~lU Olir lars, and there appear to be t',liD 12 KV Enes or; ea:b. p,)Ic. Te.ese insr.all3tions appe~ to be sevenl dc:cJ.dc~ old, and I hc'.\'~ ::10 dOlCbc tb,t tbey leak 8cross msul3.tors and probably from traDsfc.rmers, sirl':-:: I CJ.::l gc: plenEY of evidence of leakage . d . ' '. )nm\'v~mo,l in t.h~ [or Gl ot !:J3.oh, pelt's. an Gt...~er non ;~om~.gD~(1C DOlse c. . L L..u. ( \, Grant Pritchard aoc October 29, 1994 Page 8 Likewise, if r-.-rr. Samgiss wams to elim.i.o.ate the possibility of RF effects or EMF, !'.lS television set no dO!.lbt puts out more radiation than he gets froilllUY signal, aud I noticed the days that I was there that his daughter, like all children, likes to sit close to the set This is not to denigrate his feelings, provided that they are not tor the purpose of visiting unfairly an effect on my antenna. All of us pay attemion to radiation where we did not pay attention a few years ago, but the claims of RF and EMF are entirely speculative. I have \\'3tched the literature on this issue, and as a lawyer, I have had cases over the years involving PG&E and other power lines, which in many cases have been installed for many years over commercial and even residential developmems, especially in the Sacramento area. There has never been a documen:ed ,:ase or statistical ~meeestion of which I am aware that proximity to E.MF of that magnitude yields an enhanced risk of disease, Yet, as we all know, when we drive under those lines on our way up 1-80, we have no doubt th8.t tbev create fields, s;iven the interference on our radios, . - I recall a letter to QST magazine not so long ago from an engineer who had spem a lifetime in RF and E:vl !ldds, ueginuil1g many decades ago when the strength of that radiation must have been many rimes wbat it is today with proper shielding, S\YR control, and so on. He estimated that over 60 or more years he must have received hundreds, if nor thousands, of times the theoretical limits that people now caLk about as control on Rl:-" emisslOns, and he is alive. well, and tOL'111y unaffected by his experience. 111ere have been enough decades now of high exposure in cenam professions and ind'Jstries to RF emission~ that we would have seeD stiHisticaliv significant results if they were there. \Vh:it is [0 be Gone about tllis) EC'w do we 3:itisfy ;.,[r. Samgiss, if anything could" I do not know, bu: of ccmse ..;;,}u:d :e"is~ r\..,e suzgestion w:.u the output from my radio is ~nythic.g but a ;lli.nor cc,ntribuwr to the em'ironrnel1l ill which he and his LU::J;ly live oy cb,}ic~. Wh~o. you -.:oc.si,i~r that my vertical is rac.iating reiati':c:ly low pO'.'i.::r. ornnidireclior::31ly, over a length of antenna of 33 le::;[, ,_he sur.-ac:: :1r':;;1 "vcr which even a kilowatt ( , ( Gram Pritchard aae October 29, 1994 Page 9 signal is thus spread and diffused ca.n have minimum discernable impact even as close as a few feet away. If the FCC or another responsible agency wishes to inspect my installation and apply to it reasonable standards applicable to all installations similarly situated, they will find it within the standard they would expect of a cOillJ.-cercial installation. Conclusion I hope that it is apparem from this letwr that I have taken thoughtful care of the Samgiss' concerns, and I .have to say that they have not been very grateful or considerate in rerum, They call on the phone demanding that all transmissions srop on spot. They react emotionally and without listening to what is said, and they ,tan from the position that I have no right to operate my rig. They show little appreciation for the difference between interference that good oper:l.Cing practice and an efforr at filtering can fix and interference that t!:Je manufacmrer has left essentially irremediable. My own concern is that your letter of October 25, which was based solely Oil ilieir compl8.wt, may be ruisinterpre,d by the p!~"ning commission at the hearing on my application on November 9---and u'1a~ it will start a rounc, of "Why can't it go there instead of here"" C12(;!; tLat starts, the commission feds an obligation [0 let every neighoor---inc!:tding those who are not impacted by the anteillla under 'my scenario---wish the antenna off on everyone else in the usual NI~rBY response. The outCOr.:le would be what Al Burnbar:l wem through. By the rime tbe Clrul or sixth speaker b.as gotten up. all relaticrrship between the level of d~scussion 3..C.d the science and aesthetic issues l)f antenna se!e(;rion and sitins has evaporated. I \,,'i)l "p'1r"~:".l.o "(lU" ill"r.;..,c- rr<' tl''''''''' ',IJ 'eol at wb2..( lS here and to .&. I.... J;-'''' ""....~..... .... J ;. ~::J ~.i.....I.\" ~..l... ..... t2kc into cocsider:nion aU that ha; been done for rr,e S:lli.giss familv and 110\'1 unlikely it is that ::myone can at this point further rectify Sony's \'ialation of the; FCC manufacruring standards in Mr. Samgiss' set. I net'(! a letter fr'Jill you for L.1.e pi:nmiug commission PUtli.c.g your earlier letter l.'JtCJ perspective. veri.f::ing that it was based soleiy on ;he Sarllgi~s complauH, 8nd relterat:.ng *'., . ( (, Graat Pritchard OOC October 29, 1994 Page 10 that I have performed to a high standard in attempting to meet the Samgiss' complaint. Please call me at your earliest converJence. It was a pleasure to speak with you about this issue this morning. v:' Malcolm A. tvIisuraca Copies: AJi Samgiss 239 Diviso Street Tiburon, California 94920 Pbilip Kane, p.E.n.D, Supervisory Engineer FCC John Wallack, W6TLK Section Manager, ARRl. ( ( ~ /nad Grant Pritchard OOC San Francisco Section 106 San Carlos way Novato, California 94945 November 5, 1994 RECe\VED NOV 0 e \994 TOWN OF TI6URNGottEPT. PLANNING eo 6UII.DI . Mr. Malcolm Misuraca, KC6VDR 223 Diviso st. Tiburon, Ca. 94920 Re: Interference Complaint Dear Mal,=,olrn~ I am in receipt of your October 29, 1994, correspondence which has been extremely helpful in putting matters in perspective amid a number of calls from the Samgiss family and an adjacent neighbor. As I stated in my October 25, 1994, correspondence to you, I was referred to you as a result of an interference complaint made to the local FCC Field Office by the Samgiss family. My initial statements regarding the scope of the complaint were based, as my letter clearly states on that initial report and served to advise you of the substance of the complaint. I am pleased to learn that you have now thoroughly investigated all possible alternatives. I would also like to thank you and your family for the opportunity to first hand inspect your installation and discuss the matter further. You should finally note that I was unaware of the planning commission hearing on your application calendared for November 9 . Indeed our involvement was initiated by the complaint. I thought it might be helpful for you to have on file a summary of my findings as they relate to my personal inspection of your installation and our conversation regarding your corrective actions and alternatives. Summary of Inspection Activity: The amateur radio station installation licensed as KC6VDR located at 223 Diviso street, Tiburon, California was personally inspected on November 5, 1994, at approximately 0900 Hrs. I fully inspected all radio equipment, connections, antenna structure(s) and related equipment. Specific attention was noted to cable television feed points and antenna location vis a vis neighboring structures. I also had an opportunity to discuss all matters with Malcolm Misuraca station licensee. EXHIBIT NO. 8 ( ( Amateur radio station KC6VOR mainly consists of an ICOM 781, which incorporates the use of a Commander HF-2500 amp which in combination feed a vertical Gap OX-VIII antenna which is ground mounted within back yard perimeter fencing. The station is common grounded using wire braid, a copper bus and ground rod system. Additionally ground is enhanced with the use of a MFJ ground tuner which supplies an impedance match to ground. All coax (Belden 9913 - double shielded) and connections (PL-259) are of high quality and assembled in good engineering fashion. All transmissions utilizing this equipment pass through a Nye Viking 3 KW tuner. The GAP OX-VIII antenna has been extensively re worked by replacing all internal inductors and coax feed points pursua~t to factory s~ecification. This r~work is considered an optional upgrade, at the owners expense, and is not required to achieve desired performance and operating tolerances. I understand that this antenna will be replaced with the GAP OX-IV Voyager which should provide adequate coverage when used in conjunction with a sloper antenna system to support WARC and higher band coverage. Although this combination will not provide the ultimate efficiency and directivity of a beam antenna, pursuant to our discussion, Mr. Misuraca will proceed with the vertical antenna system in the interest of addressing the concerns of his neighbors. All remaining engineering representations made in the Misuraca letter of 10/29/94, were verified to be accurate statements. Conclusions: o The amateur radio station KC6VOR is of high quality and all engineering aspects have been met to insure that the operation of the station is conducted in leqal fashion pursuant to FCC regulations and guidelines. o Mr. Misuraca has provided his services, personal cost, in an efficient manner, his ability, to alleviate all concerns neighboring parties. o Continuing interference experienced by the Samgiss family has been isolated to external add on speakers connected with unshielded speaker wire to the family television set and/or the use of an unshielded telephone instrument. It is recommended that the Samgiss family replace the speakers with ones of higher quality and also connect them with shielded wire cable such as "monster cable" or similar type. The unshielded telephone should be replaced as well. at his own to the best made by of ( ( o The installation of the new GAP DX-IV voyager antenna by Mr. Misuraca is appropriate even though station efficiency would be improved with the use of a beam antenna system. . o I concur with the comments made by Mr. Misuraca in his October 29 correspondence regarding RF Health Effects. o I conducted a thorough review of operating procedures with Mr. Misuraca specifically as they relate to minimum power settings necessary to maintain contact. I am satisfied that those procedures will continue to be followed. o I am fully satisfied that the, engineering care taken in amateur radio station KC6VDR is above the normal experience, not because of the equipment used, but rather the concern for detail and having a goal of maintaining a high engineering quality standard. I am closing my file on this matter as a result of my findings. I will forward a copy of this letter to both the local FCC office and the Samgiss family. Best R.. egard~/J . / _ ..... -.i~,'-P, (.-',l-i. - \ - Grant ~ritchard, OOC San Francisco section cc: Ali samgiss Philip Kane P.E.fJ.D. Supervisory Engineer FCC John Wallack , W6TLK Section Manager ARRL Dan Catron, Associate Planner Tiburon Planning Department Town of Tiburon 1155 Tiburon Blvd, Tiburon, CA. 949~ kc6vdr2 Section 1: Section 2: section 3: section 4 : Section 5: section 6: Appendix: ( ( Page 1 of 15 Richard Karlquist Electronics Consultant PO Box 700009 San Jose, CA 95170 Jan. 27, 1995 RECEIVED JAN 3 0 1995 TOWN OF TIBURON PLANNING & BUILDING DEPT. FINAL REPORT ON MISURACA ANTENNA APPLICATION CONTENTS OF THIS REPORT: Executive summary Answers to commissioner Greenburg's questions dated 12/19/94 Comments on some statements by the applicant dated 11/27/94 Answers to Dan Catron's questions dated 1/13/95 General discussion of antenna tradeoffs Conclusions A strawman antenna Attachments: QST article, various sales literature, figures 1 through 4. -------------------------------------------------------------------- SECTION 1: EXECUTIVE SUMMARY Mr. Misuraca wishes to put up a taller amateur radio antenna to maintain his ability to communicate during the upcoming changes in radio conditions due to decreasing sunspots. This report examines the three way tradeoff between communications effectiveness, visual obtrusiveness, and the degree of difficulty entailed in implementing various alternatives. There are a limited number of options available within the constraints applicable here, and the option chosen by Mr. Misuraca in the present application appears to be the most satisfactory one possible for a reasonable amount of effort. The city staff and planning commission have done a commendable job of learning about the technical aspects of this situation so as to be sufficiently knowledgeable to make a fair decision. As of this writing, Mr. Misuraca has been unable to erect the proposed antenna due to inclement weather, hence the author has not visited the site. However, a site visit prior to the hearing is still planned, in case there are details not apparent from the plat map supplied by the planning department. EXHIBIT NO....:L- ( ( Page 2 of 15 SECTION 2: ANSWERS TO COMMISSIONER GREENBURG'S QUESTIONS DATED 12/19/94 QUESTION 1: "Is there a log that shows use of the existing antenna? If 'yes', please indicate the greographic range of calls and assess ANSWER 1: At one time, amateur radio stations were required by FCC regulations to keep a log of all communications. This regulation is no longer in effect. Most amateurs only log particularly interesting contacts, such as with a country that hasn't been contacted before. The question is in reference to the existing 31 foot antenna, by the way. Refer to my comments elsewhere on this existing antenna. I have not had the opportunity to review any of the logs Misuraca may have kept, but I don't believe they would be especially relevent to this application. QUESTION 2: "Is there any antenna (single/combination of antenna(s)/ dish) with a lower visual profile that could accomplish something approaching, if not achieving, the kind of range that the applicant desires?" ANSWER 2: It is technically possible to make an antenna that actually outperforms the proposed one and has lower visual profile. The current issue of QST magazine has a review of the proposed antenna and notes that it is not as good as another antenna with lower visual profile. However, that antenna is no longer available. There is a Japanese antenna that would approach, but not equal the GAP OX-IV in performance, and is less obtrusive. As of this writing, the author has not been able to verify its availability in the USA. Everything else on the market is either much bigger or much smaller than the GAP OX-IV. The smaller antennas would be much less effective than the GAP and the one larger one, at 65 feet, is clearly a visual problem. [Reference: QST, Jan. 95, pp 75-79, copy enclosed]. QUESTION 3: "Is there some substitute for the 80" diameter halo which would have a lower visual profile?" ANSWER 3: Let me first note that what is referred to in the question as a "halo" is normally called a "top hat" in the technical literature. The term "halo", as used in the literature, refers to an entirely different type of antenna. In any event, I make the observation here that the design of the OX-IV appears to be exactly like an antenna described in Sept. 1978 QST in terms of height and top hat size. [Note I am unable to supply a copy of this article at this time]. without going into technical detail, the net result is that a 45 foot antenna with an 80 inch top hat is equivalent in certain respects to a 55 foot antenna with no top hat. ( ( Page 3 of 15 Hence one answer to the question would be that one could substitute an additional 10 feet of height for the top hat. Of course, it is not possible to start with the OX-IV antenna, which is engineered for a top hat, and simply replace the top hat with an additional ten foot section without re-engineering the rest of the antenna to be compatible with the new scheme. Unless there is a threshold situation regarding height, such as where nothing below 46 feet is visible, it seems to me everyone is better off with a taller antenna with no top hat. As noted above, there is no such commercially available antenna however. Regarding reduced antenna height, the deleterious effects of can be minimized (within limits) by better electrical grounding of the antenna system, which is of a somewhat different nature than the safety grounding of the PG&E electrical power. It turns out that the lot in question is far too small to contain an extensive "ground plane" system, hence short antennas simply won't work well. About the best that could be done would be to run some inconspicuous wires along the wooden fences shown on the map to be used as "tuned counterpoises". Fortuitously, the fences happen to be located in just about the right configuration. The author once used this scheme at his Cupertino residence (Which is also on a long narrow lot), and it worked fairly well, although he had the luxury of a 65 foot high vertical antenna. QUESTION 4: "Could the functional part of the antenna be mounted on some kind of retractable post?" ANSWER 4: The antenna in question is such that it would be impractical to make it retractable in terms of being telescoping or folding. However, it would be quite feasible to simply mount it on a hinged base and pivot he entire antenna intact at the base to a position parallel to the ground and perhaps elevated six inches to keep it out of the dirt. (A trench would have to be dug for the top hat to fit into). If the antenna were located on the south side of the fence, immediately adjacent to its present location on the north side of the fence, it could lie down pointing south southeast along the "concrete walk" shown on the map. The apricot tree would have to be relocated and the prune-plum tree perhaps trimmed. The antenna, when folded down, ought to be hidden by the wooden fence along Centro West Street. I have enclosed some correspondence taken off the Internet (Usenet) discussing the use of a TV antenna rotator laid on its side to pivot a vertical antenna up and down. Another ham used a modified garage door opener to pivot an antenna up and down. It would also be possible, theoretically, to construct a antenna of somewhat different design (but equivalent performance) than the proposed one, but with the ability to retract. However I am not aware of anything available off the shelf along those lines. If it did exist, it would be much more expensive than the proposed antenna. It should also be noted that there is no off the shelf kit for sale than would permit an antenna to pivot down at the base as described above. It would have to be a homemade affair using hardware store parts. ( ( Page 4 of 15 QUESTION 5: "Is it true that a minimum height is required for this kind of antenna to function on a given frequency, regardless of location (see 11/9 minutes, p. 4). . What heights are necessary for what ranges of transmisssion?" ANSWER 5: Ideally, an antenna should be half as long as the wavelength being used. The elements of nearly all Yagi type antennas are close to a half wavelength long. In some of the records pertaining to this application, there are references to the "160 meter band". For that band, the wavelength is 160 meters (about 500 feet). Hence an antenna for that band would preferentially be 250 feet long. In the case of a vertical antenna, it is possible to replace half the antenna with a screen of wires running along the ground, which reduces the recommended height to 125 feet on the 160 meter band. As explained in #3 above, the applicant doesn't have the space for a proper ground screen, so even 125 feet involves some compromise. At the proposed height of 46 feet (with "top hat"), the applicant would be fortunate to get an efficiency of 50% on the 160 meter band, meaning only half his transmitter power would get radiated, but it is still in the "reasonable" category. (It is not possible to predict exactly the efficiency of this type of antenna; only guidelines are possible). At the present height of 31 feet, with no top hat, only a few percent of the transmitter power would get radiated, making operation very difficult on the 160 meter band. It is surprising how much difference the extra 15 feet make. On the other hand, the 46 foot antenna with top hat would work quite well on the other bands (80, 40, 20 meters) which all have shorter wavelenghts. (The 160 meter band has the longest wavelength of any band). The present 31 foot antenna is a poor performer on 80 meters, but is OK on the other bands, according to the Jan. 95 QST article referred to above. The present 31 foot antenna is probably about as good as any other commercially available antenna in the 30 foot class (and there are a lot of "me too" antennas in this class). It would be possible to improve the situation somewhat without exceeding 31 feet by going to a custom antenna, but it is not reasonable to expect every ham operator to be technically proficient enough to construct his own antennas. In any event, no 31 foot antenna (without top hat) is going to work really well on 80 meters with the limited grounding that is possible. See #6 below where I discuss the importance or lack thereof of the 160 meter band. QUESTION 6: "Are the comment in the Planning Commission minutes of 11/9 regarding variations in sunspot activity (as they affect ham radio reception) over the next 50 year period. Is it feasible to permit different antenna heights during different time frames to allow improved reception while minimizing visual impacts?" ( ( Page 5 of 15 ANSWER 6: Propagation of radio signals follows a cyclic pattern related to the time of day, the time of year, and the time within the sunspot cycle. The sunspot cycle refers to the fact that the number of spots (Le. "storms") visible on the sun follows a regular pattern where it reaches a maximum about every 11 years. Halfway in between the maxima, the number of sunspots reaches a minimum. Currently, the sunspot cycle is approaching a minimum. During sunspot minima, it is generally necessary to use the longer wavelength bands to maintain the ability to communicate. Short wavelength bands, by and large, are useless during sunspot minima. During sunspot maxima, short wavelengths become usable. The bands with shorter wavelength are such that less power and smaller antennas are sufficient to communicate. The longer wavelength bands are usable to some extent during sunspot maxima, but more power is needed and less range is generally possible. During a sunspot minimum, 20 meters may be usable only in the middle of the day (which limits the operator to weekends if he works the day shift). In my experience, the longer wavelength bands such as 40, 80 and 160 meters are always usable no matter how low the sunspot count gets. Unfortunately, 40 meters is of limited usefulness for voice mode, for a variety of complicated reasons. It is mainly a radiotelegraphy (Morse code) and data transmission band. Hence, a case could be made that every amateur station ought to be able to operate on the 80 meter band to provide a minimal ability to communicate long distances. The need for the 160 meter band is less clear. It is never as good as the 80 meter band, even with optimum antennas. For many years, the 160 meter band had severe operating restrictions imposed by the FCC and most amateur equipment did not cover the band. Hence, it has traditionally been a "niche" band. More recently, the restrictions have been removed and most transmitters now cover the band, due to technical advancements. However, the antenna size problem and the poor propagation of signals on the band are such that it is still not (and probably never will be) a "mainstream" band. Although transoceanic contacts are possible, most of the activity typically heard is within a thousand miles. It is hard for me to convince myself that the lack of this band would be a severe hardship. QUESTION 7: "Neighbors have expressed concerns about EMF safety and requested that transmission be on the lowest power possible. Please comment." ANSWER 7. It is probably counterintuitive to the layman, but if you are worried about EMF safety then you would want the radio station to use the largest antenna possible. This will permit less power to be used. Obviously, whatever the EMF threat, it is reduced when less power is used. Also, the electromagnetic fields in the immediate vicinity of a small antenna are frequently much higher than for a full size antenna. For example, when using a 1500 watt transmitter with a 6 foot whip antenna on a car, it is not unusual to have electric fields so high that sparks are emitted from the top, unless special precautions are taken to prevent it. With a full size antenna, this is never a problem. ( ( Page 6 of 15 The experts on EMF disagree about the danger of an HF transmitter (i.e. frequency range from 1.8 to 30 MHz.) but all would agree that these low frequencies are far less dangerous than VHF/UHF/microwave frequencies. It is interesting to note, for example, that cellular phones operate on almost the same frequency as the large microwave ovens used in restaurants. Using the lowest power possible is dependent on the discipline of the operator. It is good operating practice to ask the station at the other end if one's signal is strong enough that it would be OK to reduce power. Incidentally, when it comes to EMF safety, the priority item for city governments should be to outlaw the treatment of buildings for termites with microwaves until such time as the safety of such schemes is verified. In my opinion, those devices are far more dangerous than HF ham radio. QUESTION 8: "Grant Pritchard letter, power settings for this application. some physical or other way to insure exceeded?" 11/5/94 refers to minimum What are these? Is there that they will not be ANSWER 8: The only Grant Pritchard letter I have a copy of is dated 10/25/94 (exhibit 7) and I don't see anything about "minimum power settings" in that one, so I can't answer this question at this time. QUESTION 9: "The applicant has stated that he has to operate at 1500 watts to call New Zealand. Is this true? If 'yes', what are the implications in terms of antenna height?" ANSWER 9: I am frequently asked questions such as this, which boil down to "How much power is needed to get how much range?" and the answer is: it depends. I once easily contacted a station in Australia from my car in Seattle running less than 50 watts to a 6 foot antenna, and there are no doubt even more amazing anecdotes than that one. However, that contact was made under ideal conditions on the 20 meter band. On the 80 meter band, even 1500 watts is not necessarily enough power to communicate with New Zealand. My experience on 80 meters using a much bigger antenna than anything being discussed here was that 1500 watts would typically only get as far as Japan. The implications in terms of antenna height are, as I previously stated, that bigger antennas require less power (assuming the operator has the discipline to reduce power). During a sunspot minimum, I am not sure that one could count on regular schedules with New Zealand no matter what antenna were used. QUESTION 10: "What band(s) would provide "reasonable" use and what minimum height anteann or what configuration of antenna(s)/ dish would accomplish this use?" ( ( Page 7 of 15 ANSWER 10: It seems to me that one ought to have use of 80, 40 and 20 meters. And to get on 80 meters, a reasonable antenna height is a minimum of 45 to 60 feet (without top hat) perhaps a bit less with top hat. Those heights would be quite adequate for 40 and 20 meters as well. As far as what configuration would accomplish this (besides the proposed OX-IV), let me first point out that other antennas can be substituted that don't have anywhere near the visual clutter of the OX-IV. All that is really needed is a single vertical pole, say 50 feet high, with a small enclosure (the size of a coffee can) for a tuning network located at about the 15 foot level. The pole can taper from 1 1/4 inches down to 3/8 inch at the top. This would probably actually work better than the OX-IV and have a lot less visual impact. See figure 1 in the attachments. The only disclaimer is that it would have to be a home-built antenna, as there is nothing like that on the market (for marketing reasons, not because there is any technical problem.) I built an antenna similar to this when I lived in San Jose 15 years ago. It worked well. See the attached diagram. ( ( Page 8 of 15 SECTION 3: COMMENTS ON SOME STATEMENTS BY THE APPLICANT DATED 11/27/94. 1. ANODIZING: In the Nov. 9 planning commission minutes (#726), at the end of the second full paragraph, Mr. Miseraca states "although he has never seen anodizing of the antenna done, he feels that if it was (sic) possible, all the of manufacturers would be doing it." Anodizing has been a standard (though not universal) technique used in the TV antenna industry for decades to reduce corrosion. Although simple anodizing is colorless (hence not obvious visually), it is possible to add dye to the process to get any color desired. Frequently, TV antennas use gold colored anodizing, so they look "gold-plated". Black anodizing is very common outside the antenna industry. It is true that commercially available ham radio antennas are not usually anodized, but the parts could be taken to an anodizing shop before assembly and anodizing by the purchaser. Because anodizing is electrically insulating, the ends of the tubing would have to be masked off. On the other hand, it isn't at all clear to me that anOdizing would make much difference in terms of appearance. How many people notice whether TV antennas are gold anodized or not? 2. YAGI AS THE GOLD STANDARD:: On pages 3 and 4 of Mr. Misuraca's letter dated Nov. 27, there is a discussion of the Yagi antenna as the gold standard of amateur radio communication and the assertion that I should be comparing any strawman to a Yagi, not to the DX-IV. This is probably too strong of a statement to make, relecting ham radio folklore as much as technical fact. It is usually connected with the cliche that a "vertical antenna radiates poorly in all directions", which has some truth to it, but it needs clarification. A typical commercial vertical antenna, mounted on the ground, without an extensive ground plane, indeed is greatly inferior to an optimal Yagi. On the other hand, the optimal vertical in the strawman below is close in performance (although slightly lower) to the compromise Yagi that the applicant requested, then withdrew. Besides the slightly lower performance, the vertical also doesn't have directional receive capability. This isn't required 90% of the time, however. Also, directionality can be acheived with a separate directional receive antenna that could be very small (the size of a basketball). These have been discussed recently in the literature. Changing from the current 31 foot vertical to the OX-IV 46 foot vertical would move the 20 meter performance to one cut below a Yagi, as opposed to the 31 foot vertical which is not very good on 20 meters as documented in the QST article. Nevertheless, the increase to 46 feet is considerably more important with respect to 80 meters than 20 meters. ( ( Page 9 of 15 I have enclosed some information on the Will-Burt retractable masts which would allow a Yagi to be raised to over 50 feet when in use, yet lowered to 8 feet when not in use, almost below the fence line. I would encourage the applicant to resubmit the Yagi with one of these masts if he is sufficiently motivated to spend the money on it. (The masts cost around $10,000). It would be up to the participants to negotiate what daytime hours would be available to extend it (assuming all nightime hours are available). Perhaps 4 to 6 daytime hours per weekend would be a good compromise. Perhaps unlimited time should be allowed on days when the view is ruined anyway due to fog or rain. Another popular tactic is to arrange to operate during times when the neighbors are known to be sleeping or absent from the home, if their habits are sufficiently predictable. r ( Page 10 of 15 SECTION 4: ANSWERS TO COMMENTS ON DAN CATRON'S QUESTIONS DATED 1/13/95 QUESTION 1: "I gather from some of the statement in your reports (Greenberg #10) that one of the more important band for ham operators is the 80 meter band. My information indicates that the bandwidth on 80 meters is limited (to 130 kHz.) on the DX- VIII (whereas the DX-IV operates on the 'full bandwidth.') What are the implications of this limitation?" ANSWER 1: As I have indicated elsewhere, 80, 40 and 20 meters are the most important bands in general, and for voice operation, 80 and 20 meters are the most important. (At one time, voice operation was forbidden on 40 meters, and though now legal, isn't very popular) 80 and 20 meters are generally available on a mutually exclusive basis; that is, when one is usable the other is not usable. A short tutorial on "bandwidth" is in order here. Radio bands can be described in terms of either a range of wavelengths or any equivalent range of frequencies. Any given wavelength always corresponds to a certain frequency and vice versa. The so-called 80 meter band actually covers 75 to 85 meters (wavelength) or equivalently 3500 to 4000 kHz., that is a band width of 500 kHz. This can be compared to the dial on any AM radio that goes from 550 kHz. to 1500 kHz. One of the disadvantages of decreasing the height of an antenna is that the frequency range becomes limited to less than the amount permitted by FCC frequency allocations. In the case of the DX-VIII, the user can only utilize 130 of the possible 500 kHz. of the 80 meter band. This is not necessarily a big hardship however. For example, when I operate on the 80 meter band, I rarely go above above the bottom 50 kHz. of the band and there are many others like me. Mr. Misuraca's operating habits may differ, of course. QUESTION 2: "Are there commercially available vertical antennas in the vicinity of 45 feet high that do not include top hats (or are otherwise less visually obtrusive that the DX-IV), that will perform comparable to the DX-IV on 80 meters?" ANSWER 2: Unfortunately, most commercial antennas are in the 20 to 30 foot range and are essentially "me too" versions of the DX-VIII. The only commercial verticals in the DX-IV class that I have been able to locate are the Creative Design CV48 and the KLM SSV-80-40-15. The CV48 is 39 feet high, and is a smooth tube tapering from 2 1/8 inch diameter to less than 1/2 inch at the top. The only protrusions on it are three horizontal rods that look like they're about 3 feet long, located about 2/3 of the way to the top. It weighs 26 Ibs. At this writing, I have not been able to confirm or deny that there is currently a dealer who is importing this antenna from the manufacturer in Japan, although other antennas from the same manufacturer are being imported. ( ( Page 11 of 15 The KLM SSV-80-40-15 vertical is a high performance vertical being "full size" on 80 meters, that is 65 feet high. A general description of it would be a "tower" about 30 feet high with a tubing type extension on top to get the full height. Not very visually obtrusive above the tower part, but below it, rather "busy". The tower is tapered such that it gets bigger as you go lower, resulting in a width of 4 feet at the base. The large base could easily be hinged to allow raising the antenna at sunset when the 80 meter band "opens". Since it weighs only 88 pounds, it might be able to be "walked up" by hand, depending on the person's strength. It is self supporting in winds up to 100 MPH. It is rather expensive at $860 list. QUESTION 3: "I assume that such antennas (45 feet, w/o top hats) would not perform as well as the DX-IV on 160 meters. Is this true?" ANSWER 3: For 160 meters, you either need a lot of height or a top hat or both for good performance. The other tall vertical antennas mentioned in the preceeding paragraph do not even claim to be able to work on 160 meters, although you could get them to work on that band by adding a circuit known as a "loading coil". In that case, the KLM, being tallest would work best, and the Creative Design would be the least effect, being shortest, with the DX-IV in the middle. All would outperform the DX-VIII or similar 30 foot antennas. QUESTION 4: "In your opinion, would it be "reasonable" for the Planning Commission to look towards a solution that focuses on optimizing performance on 80 meter while minimizing visual impacts? (This may be at the expense of performance on 160 meters.)" ANSWER 4: Technically speaking, almost anything you do that improves 80 meter operation also improves 160 meter operation, so it is a moot point. I would however make the comment that I tend to think of the 160 meter band as a place for the ham who has already done everything on the other bands (i.e. contacted every country in the world, etc.) and is looking for new frontiers to conquer. If you just want to communicate, 80 meters is virtually always better. QUESTION 5: "The applicant contends that the Town should compare any alternative antennas with the performance of a yagi as you discuss in your report. Would it be appropriate to compare general effectiveness (for long distance communications) of a yagi operating on 20 meters versus a commercially available vertical antenna operating on 80 meters?" ANSWER 5: When 20 meters is "open" (i.e. usable), it is so much better than 80 meters that a 20 meter vertical will probably outperform an 80 meter Yagi, so that comparing a 20 meter Yagi to an 80 meter vertical is a *very* lopsided comparison. The problem is that 20 meters is unavailable after sunset, so 80 meters becomes the only game in town. ( ( Page 12 of 15 SECTION 5: GENERAL DISCUSSION OF ANTENNA TRADEOFFS INTRODUCTION: I have already covered a lot of the relevant issues in my answers to commissioner Greenberg's questions. However, in this report I am going to summarize a number of important tradeoffs involving antennas that are crucial to the decision making process. Once everyone understands these tradeoffs, the parties involved can make informed decisions. Note that I am writing this report before actually visiting the property, so all I have to go on is the map and other documentation that was furnished. VISUAL IMPACT VS. COMMUNICATIONS EFFECTIVENESS: A 2 dimensional tradeoff between visual impact and effectiveness is implied in many of the discussions here. There is, however, a third dimension of "convenience" or "difficulty". This would take into account cost, effort, time, ease of installation, ease of use, disruption of the applicant's own yard, availability, maintenance, etc. An analogy would be the perceived tradeoff between the performance of a car and its emissions. It is possible to buy cars now that are faster than the unregulated cars of the 1960's, but the cost is much greater. HEIGHT VS. GIRTH (visual): Whenever the subject of regulation of antennas comes up, it seems to get hung up on the issue of a height limit. Certainly it is true that, ALL OTHER THINGS BEING EQUAL, raising the height of an antenna generally increases its visual profile. However, the girth of the antenna is also quite important in terms of visibility, yet "girth limits" are rare. The author lives in Cupertino, which allows a height of 55 feet but has a girth limit of 12 inches for towers. Restricting the size of tower not only decreases tower visibility, but effectively limits the size of the antenna that can be placed on the tower because of structural constraints. Cupertino waives the height limit for vertical antennas of 2 inch diameter or less. This encourages antennas consisting of a plain pole, with no protusions, but perhaps somewhat taller than what would otherwise be used. As far as I know, both the city of Cupertino and the amateurs are reasonably happy with this compromise. HEIGHT VS GIRTH (electrical): For optimum operation, a horizontal antenna should be half as long as the wavelength in use and a vertical antenna should be half as high as the wavelength. The names of the bands indicate the wavelength hence the recommended antenna lengths/heights for the 160 meter, 80 meter, 40 meter and 20 meter bands are (converting from the metric system) 260, 130, 65, and 33 feet respectively. For horizontal antennas, it is recommended that they be at least as high as they are long. These numbers put into perspective the degree of compromise of a 30 foot height limit. If one had available the full height, then a "zero girth" antenna would be possible consisting of just a vertical wire tied to a tall tree branch. It would occupy essentially no lot area and be nearly invisible. ( ( Page 13 of 15 The Misuraca property has no significant trees, so the girth of any antenna would have to be dictated by structural considerations, so it would have to be more than just a wire. In order to get operation on the long wavelengths with reasonable heights, it is possible to decrease antenna height by increasing its girth in one of several ways (which can be used singly or in combination). 1. Make the diameter of the vertical antenna larger; 2. Add a "top hat" (referred to in these proceedings as a halo); 3. Bury a lot of wires in the ground around the base. Of course, option 3 doesn't increase visual girth, but it requires a large lot, which Mr. Misuraca doesn't have. However, it is always better to have more height even if there is no constaint on girth. HEIGHT VS GIRTH (structural): In discussing structural tradeoffs, it is necessary to distinguish between guyed and unguyed structures. In the case of unguyed structures, wind resistance becomes one of the most important factors. Adding a top hat adds considerable wind resistance. I haven't done any rigorous calculations, but I would estimate that in nearly all cases it would be better to make the antenna a little taller in terms of the performance vs. wind resistance tradeoff. Increasing wind resistance forces the use of larger diameter tubing (or thicker wall tubing, or stronger tubing). If larger diameter tubing is used (as is usually the case), the wind resistance is further increased by the increase in diameter, which requires still larger diameter tUbing. In any case, the proposed antenna has not only a top hat, but numerous nonstructural electrical elements that greatly increase its wind resistance. It is no surprise that guys are required. Once the decision to use guys has been made, then wind resistance is much less of a constraint, if sufficient real estate is available for the guys so that the angle of the guys with respect to the ground is less than about 60 degrees. At 60 degrees, the distance from the guy anchor to the base has to be half the height of the guy attachment point to the structure. In the Misuraca case, guys could be attached to the house and garage, thereby raising the anchor points 10 feet or more above ground, which further helps the situation. It appears from a cursory look at the map that sufficient guying for as much as 70 feet of height may be possible. with sufficient guying, the antenna diameter can be made quite small. Again, adding a top hat is a bad idea due to wind resistance. Torsional forces of the top hat limit the ability to use small diameter tUbing. If a plain pole is used, there is essentially no torsional force. Instead of 2 inch (or 1 1/2 inch) diameter all the way to the top as with the GAP DX-IV, it would typically taper down to 3/8 inch at the tip. It is also worth noting that most commercial antennas use thin wall (typically .058 inch) aluminum tubing, because of a number of reasons that are non-essential (at least for vertical antennas). The overall antenna diameter can be decreased to some extent by using thicker wall tubing and/or stronger metals such as copper clad stainless steel. For example, 1 inch diameter tubing with 1/4 inch wall is about as strong as 2 inch diamter tubing with ( ( Page 14 of 15 ANTENNA SIZE/~EIGHT VS. INTERFERENCE AND EMF SAFETY: As a general rule, a taller and/or larger antenna of the type we are discussing will have lower electromagnetic fields (for a given transmitter power) in nearby areas on the ground than will a miniature antenna. This is probably counterintuitive to the impression of the average non-technical person. Furthermore, the better the antenna works, the less transmitter power will be needed, further decreasing the fields. I am not an expert on biological effects of EMF, and the people who are experts frequently disagree among themselves, but there seems to be agreement that EMF at cellular phone frequencies and power line frequencies is far more dangerous than the HF radio frequencies in question here. DAYTIME VS. NIGHTIME BANDS: The bands generally used for long distance communications range in wavelength from 160 meters to 10 meters. The applicant brought up the complicated issue of sunspot numbers while ignoring the straightforward issue of daytime vs. nighttime operation. As a general rule, long wavelength bands are usable only at night and are better in periods of low sunspot activity, such as we are now experiencing. Short wavelength bands are usable mainly during the day and only during periods of high sunspot activity, such as we will experience around the turn of the century. As previously mentioned, long wavelengths tend to require longer/ taller antennas. This suggests the concept explained in the following section on retractable antennas. RETRACTABLE ANTENNAS: The fact that long wavelength nighttime bands require large antennas suggests the following scenario: During the day, when long wavelength bands are unusable, the antenna is retracted. At night, when these bands are usable, the antenna is extended to operational size, but the antenna cannot be seen due to darkness. A seemingly ideal paradigm, unfortunately not proposed by the applicant. For short wavelength bands, the existing 31 foot antenna is actually quite adequate, so there should not be a problem there. I am aware of a case where an amateur used a tower retractable to 11 feet (instead of the usual 22 feet) for a Yagi for the short wavelengths. He got a use permit from the city that allowed him to crank the tower up only at night. During periods of high sunspots, short wavelength bands can be usable as late as midnite, so this was considered worth the trouble. Mechanically, rather than a telescoping antenna, it would probably be better to pivot the whole antenna at the base. I have heard of an amateur who used a modified garage door opener to make an automatic pivoting antenna. Alternately, muscle power can be used. Note that a top hat (as in the proposed antenna) complicates pivoting the antenna since it can no longer be laid completely flat (unless a trench is dug for the top hat to sit in). Many building departments waive the 80 MPH wind requirement of the UBC for retractable antennas based on the idea that the user will be smart enough not to try to raise the antenna during a severe storm. For the same reason, the guys can often be dispensed with or simplified; the usual rule of thumb is to design for 50 MPH winds, when up. Keep in mind that none of the retractable or pivotable schemes is cheap and easy to do. ( ( Page 15 of 15 SECTION 6: CONCLUSIONS It has been shown that decreasing sunspots will force the applicant to rely heavily on 80 meters. He will take a big hit in performance by continuing to use his 31 foot antenna. The proposed 46 foot antenna will a1lieve this problem as well as give him the next best thing to a Yagi on 20 meters. A discussion has been presented of various creative ways to solve the technical problems without creating visual ones. All of these substantially inconvenience the applicant. It would appear that the current proposal is probably a reasonable compromise of all concerns. ----------------------------------------------------------------- APPENDIX: A STRAWMAN ANTENNA It is not my job to furnish the applicant with a turnkey antenna design solution. However, I think is it useful to outline a strawman as an "existence proof" that an effective antenna can be built without the clutter present in the GAP DX- IV. Perhaps something like this will come onto the market in the future. The author once had a job designing HF marine radios. These covered the marine bands from 2 to 12 or 2 to 16 MHz which are very similar to the 160 thru 20 meter bands (1.8 to 14 MHz.) in question here. The standard station on board a boat consisted of a plain fibreglas coated aluminum pole (20 to 40 feet long) connected directly to the marine radio's automatic antenna tuner. (The fibreglas was necessary to prevent the sea water from corroding the aluminum). Essentially, the automatic antenna tuner performed the same function as the non-structural elements hanging off the side of the GAP antenna. Hence what we would have for this application would be just a plain aluminum pole with an automatic antenna tuner in a weatherproof box on the ground at the base of the antenna. This is shown in Fig. 2. There are a couple of complicating factors here that make a slight increase in complexity of the antenna worth considering. If the antenna height exceeeds 33 feet, there will be a loss of effectiveness on the 20 meter band only. This can fixed by operating the top 33 feet as an end fed 1/2 wave on that band using a matching network located 33 feet below the top and running coax down the inside of the lower portion of the antenna. The matching network could probably fit inside a 2 inch diameter tube 6 inches long. (Fig. 3) A relay would bypass this network when other bands were in use. If a somewhat larger tube (say 6 inch diameter by 12 inches long) could be tolerated at this location (33 feet below the top), a "center-loading" inductor could be included to improve efficiency on 160 and 80 meters. (Fig. 4) This would be more effective than the raised feed of the GAP antennas. I would recommend a total height of 45 to 65 feet and no top hat. Finally, it should be noted that when the author once constructed an end-fed half wave vertical on 20 meters with the top at around 45 feet. It compared very favorably with a 2 element Yagi installed at the same location at a height of 40 feet. This kind of high efficiency vertical should not be confused with a quarter wave ground mounted vertical antenna with a mediocre ground plane which is a cut below in performance. . t 1\ .tIA ~lcq. ( .3 ( \ 1\ T '\;), -A L If ~u.. '""t:T J 4:.)? 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