HomeMy WebLinkAboutSP199900015 Staff Report Special Use Permit 1999-06-09 STAFF PERSON: SUSAN THOMAS
PLANNING COMMISSION: MAY 4, 1999
BOARD OF SUPERVISORS: JUNE 9, 1999
SP 99-15 CFW WIRELESS CV 113 (Sarge's Trading Post)
Applicant's Proposal:
The applicant is requesting approval to install a self supporting wooden pole approximately 10
feet above tree height(which is approximately 75 feet)to provide improved wireless service for
the Highway 29 South corridor, within Albemarle County. If approved, this site would connect
with the approved and operating CFW Crossroads site approximately one mile to the south; it
would connect with the proposed Arrowhead site to the north. The proposed tower site is a 15-
foot x 15-foot site approximately in the center of Tax Map 87B, Parcel 4, located at the
southwest corner of Routes 29 South and 710 on property presently used for a neighborhood
convenience store and private residence.
Petition:
Request for special use permit to allow for a personal wireless service facility in accordance with
Section 10.2.2.6 of the Zoning Ordinance which allows for radio-wave transmission and relay
towers. The property, described as Tax Map 87B Parcel 4, contains 1.357 acres, and is located in
the Samuel Miller Magisterial District at the intersection of Route 29 South (Monacan Drive)
and State Route 710 (Taylor's Gap Road). The property is zoned RA, Rural Areas and EC,
Entrance Corridor Overlay District. The Comprehensive Plan designates this property as Rural
Area 3.
A location map is included as Attachment A; a plat of the property is Attachment B;the
applicant's justification is Attachment C; the tower and antenna design is Attachment D; a
topographical map is Attachment E.
The applicant is also requesting a site plan waiver and a reduction in setback.
Character of the Area:
Access to the site is a through the parking area of the existing store, which is located on the same
parcel as the proposed tower. This driveway also serves the private residence located on the
parcel, as well as two residences located on the adjacent property to the south (Parcel 4A).
Existing development within the immediate area is relatively dense compared with much of the
southern portion of the county, due to areas of VR, Village Residential zoning. Red Hill
Elementary School lies approximately one-half mile south of the site.
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Properties located within the Hardware Agricultural/Forestal (A/F) District lie within
approximately one mile of the site, to the south, west and north. Attachment D is a topographic
map that shows the location of the proposed tower, nearby house structures, and other features.
The proposed tower site lies at an elevation of approximately 740 feet ASL (Above Sea Level).
The closest dwelling is the residence on the same parcel, approximately 100 feet from the
proposed site. Approximately 36 residences are located within 2,000 feet (0.37 miles) of the
proposed tower. No existing towers are located in the immediate area. The closest existing CFW
Wireless facility is the Crossroads site, located to the south on the west side of Route 29 South.
RECOMMENDATION:
Staff has reviewed this request for compliance with the provisions of Section 31.2.4.1 of the
Zoning Ordinance and recommends denial.
Planning and Zoning History:
None available.
Comprehensive Plan:
Staff notes that the existing driveway and electrical service to the property owner's residence
would be used for the purposes of the proposed tower. A letter from a local nursery owner
regarding impact to existing trees on site has been submitted, and is included as Attachment E.
Staff can identify no provision in the Comprehensive Plan which prohibits or has the effect of
prohibiting the provision of personal wireless communications. This site is located in the Rural
Areas; it is also identified as lying within a designated Entrance Corridor in the Comprehensive
Plan, Open Space Plan and Zoning Ordinance. Currently, the Comprehensive Plan contains
limited review criteria for the siting of telecommunication towers. The Open Space Plan does
provide some guidance for the protection of identified resources of the County. The resources
identified in the plan and potentially affected by this application are limited to the Entrance
Corridor Overlay District, which is currently addressed by the ARB, Architectural Review
Board.
The intent of the Entrance Corridor Overlay District as stated in the Zoning Ordinance is in part
"to implement the comprehensive plan goal of protecting the county's natural, scenic and
historic, architectural and cultural resources including preservation of natural and scenic
resources as the same may serve this purpose," and, "to protect and enhance the county's
attractiveness to tourists and other visitors; to sustain and enhance the economic benefits
accruing to the county from tourism." If this special use permit is approved, the ARB will
review this request for impacts to the Entrance Corridor Overlay District. It appears that this
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tower would be minimally visible from the northbound lane on Route 29 South, due to
topography and trees cover on site. However, it is periodically visible from several locations
along Route 29 South southbound, because the front portion of the site has been cleared for the
commercial use and a relatively small amount of tree cover remains. Additionally, the site layout
and small size of the parcel offer few location options for a facility of this nature. In staffs
opinion, the proposed tower conflicts with the intent of the EC district.
The Virginia Department of Transportation(VDOT) has indicated in its comments of March 25,
1999 that the entrance to the site should meet private street entrance standards. In staffs
opinion, the existing store entrance would be adequate, should the tower be approved.
STAFF COMMENT:
Staff will address the issues of this request in three sections:
1. Section 31.2.4.1 of the Zoning Ordinance.
2. Section 704(a)(7)(b)(I)(II) of the Telecommunications Act of 1996
3. Waiver of a site plan in accord with the provisions of Section 32.2.2 of the Zoning
Ordinance.
4. Reduction in setback in accord with the provisions of Section 4.10.3.1 of the Zoning
Ordinance.
Staff will address each provision of Section 31.2.4.1 of the Zoning Ordinance.
The Board of Supervisors hereby reserves unto itself the right to issue all special use
permits permitted hereunder. Special use permits for uses as provided in this ordinance may be
issued upon a finding by the Board of Supervisors that such use will not be of substantial
detriment to adjacent property,
The proposed tower is located approximately 40 feet from the nearest property line (to the
south); that boundary is shared with Tax Map 87B Parcel 6, which is in residential use. (A
setback reduction is required for this site.) Although the wooden pole proposed resembles
common utility poles, its height(approximately 85 feet), location close to the shared property
line, and the relatively thin tree cover on site are anticipated to create impacts that would be of
detriment to the adjacent property to the south. For the same reasons, the proposed tower can be
expected to have a detrimental visual impact on the property located to the east across Route 710
from this parcel and potentially from a number of other small properties located in the vicinity of
Red Hill School.
The applicant has indicated that CFW Wireless service personnel will visit the site approximately
one time per month, a schedule similar to other utility providers. When electrical power to the
site is interrupted by weather or other factors, service personnel would be required to visit the
site to ensure that back-up power systems are working. This schedule is not expected to create
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adverse impacts to adjacent property. Four wheel drive sport utility vehicles [Jeep type] are
generally used for this purpose.
The proposed tower may offer limited opportunities for collocation in an area which has been
identified as not having substantial collocation options. Staff notes that although the County
encourages collocation of facilities where opportunities exist, future collocation on this tower,
should it be approved, should not introduce telecommunications facilities that more significantly
impact the adjacent property and the district. Because of the wooden pole construction and lack
of capacity for vertical separation of antennae, collocation does not appear probable. If
approved, future facilities should be substantially of the same nature as the panel antennae
proposed with this application so that additional impacts are not created. No lighting
requirement is anticipated since this tower does not penetrate the Airport Overlay District.
that the character of the district will not be changed thereby,
Staff has reviewed the impact of the proposed tower relative to the character of the Rural Areas
District and Entrance Corridor, with particular attention to its potential to establish a precedent
for additional future facilities of this nature on this site which might, perhaps, have a greater
impact than this particular installation. Although physical impacts to the property are anticipated
to be minimal since no clearing is required, and access and electrical service already exist on site,
staff finds that the proposed tower would alter the character of the Rural Areas district and
Entrance Corridor simply because it is plainly visible from the southbound lane of Route 29
South and introduces a use which differs from the rural residential and agricultural uses
characteristic of this district and portion of the county.
Towers have been permitted in the Rural Areas in the past, without a finding of significant
change to the character of the district depending upon the specific site and its surrounding terrain,
land use, etc. However, over time increasing tower density may incrementally change the
character of the district, possibly diminishing the aesthetic qualities for which these districts are
noted. Staff suggests that site specific factors such as size, construction type and site be
considered within the larger context of the pattern of tower location during the special use permit
review process. At the present time, there does not appear to be an excess of tower facilities in
this area. However, this parcel does not offer the opportunities for careful siting that are needed
to avoid visual impacts to the RA district.
The property is also zoned EC, Entrance Corridor. If approved, the tower will be reviewed by
the Architectural Review Board (ARB). In staffs opinion, introduction of this use in a location
where it is visible from the Entrance Corridor does change the character of the district.
and that such use will be in harmony with the purpose and intent of this ordinance,
Staff has reviewed the purpose and intent of the Zoning Ordinance as stated in Sections 1.4, 1.5
and 1.6 with particular reference to Sections 1.4.3, 1.4.4, 1.4.5, 1.4.8, and 1.5. Sections 1.4.3,
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1.4.4, and 1.5 address, in one form or another, the provision of public services. The use of
mobile telephones clearly provides a public service as evidenced by the expanded and rapid
increase in use. Based on the provision of a public service, staff opinion is that this request is in
harmony with the purpose and intent of these sections of the ordinance. Sections 1.4.5 and 1.4.8
address preservation of historic areas and agricultural, forestal and other lands significant to the
natural environment [the Hardware A/F District is located to the south, west and north of this
property]. Staff finds that negative impacts which would result from the proposed tower in this
location conflict with these provision of the ordinance.
Because of the absence of existing telecommunication facilities in the area and limitations
imposed by other utility service providers (Virginia Power) on their existing towers, collocation
on an existing telecommunication or electric power facility appears problematic or impossible as
an alternative to the new tower.
Staff opinion is that this request does not comply with this provision of Section 31.2.4.1 of the
Ordinance.
with the uses permitted by right in the district,
The proposed tower will not restrict the convenience store or residential use on this parcel, or
other by-right uses available on this site or by-right uses on any other property.
with additional regulations provided in Section 5.0 of this ordinance,
Section 5.1.12 of the ordinance contains regulations governing tower facilities and appropriate
conditions are proposed to ensure compliance with this provision of the ordinance.
and with the public health, safety and general welfare.
The provision of increased communication facilities may be considered consistent with the
public health and safety and general welfare by providing increased communication services in
the event of emergencies and increasing overall general communication services. The
Telecommunications Act addresses issues of environmental effects with the following language,
"No state or local government or instrumentality thereof may regulate the placement
construction, and modification of personal wireless service facilities on the basis of the
environmental effects of radio frequency emissions to the extent that such facilities comply with
the Commission's regulations concerning such emissions." In order to operate this facility, the
applicant is required to meet the FCC guidelines for radio frequency emissions. This
requirement will adequately protect the public health and safety.
Section 704(a)(7)(b)(I)(II) of the Telecommunications Act of 1996.
The regulation of the placement, construction and modification of personal wireless facilities by
any state or local government or instrumentality thereof shall not prohibit or have the effect of
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prohibiting the provision of personal wireless services.
Neither the Comprehensive Plan nor the Zoning Ordinance prohibits the provision of personal
wireless service. Staff opinion is that the County has no ban or policies that have the effect of
banning personal wireless services or facilities and that decisions regarding the approval of
facilities to provide service is done on a case-by-case basis. Staff does not believe that the
special use permit process nor the denial of this application has the effect of prohibiting the
provision of personal wireless services. The applicant has not demonstrated that there are no
other locations within the proposed area of service currently available for new tower
construction. For this reason, staff does not believe that denial of this application would have the
effect of prohibiting the provision of services.
Because of the absence of existing towers along this section of the Route 20 South corridor, as
previously mentioned, it has not been possible to identify any suitable collocation opportunity
which would address the applicant's desire to provide an improved level of service in the area.
The applicant has stated that alternate sites at Red Hill School and on property across Route 29
South were considered and found to be infeasible for the tower use. Staff requested that the
applicant consider alternative sites. The applicant reported to staff that it considered two
alternative sites, at Red Hill School and on property across Route 29 South. The applicant was
unable to negotiate a lease on either site. Staff has no independent verification available
concerning the engineering requirements of the applicant's network or the location needs relative
to this site, or other sites that would accomplish the applicant's service objective in this area.
Waiver of a site plan in accord with the provisions of Section 32.2.2 of the Zoning Ordinance.
Section 32.2.2 allows the Commission to waive the drawing of a site plan if requiring a site plan
would not forward the purpose of the ordinance or otherwise serve the public interest. Based on a
review of existing conditions on the property and the proposed lease area, staff is unable to
identify any purpose which would be served by requiring the submission of a site plan. Should
the Commission recommend approval of SP 99-15, staff recommends approval of a full site plan
waiver subject to the following conditions:
1. Should the area of disturbance exceed 10,000 square feet (including the access road), an
erosion and sediment control plan shall be approved prior to the issuance of a building
permit;
2. Issuance of Certificate of Appropriateness prior to final zoning approval.
Reduction in setback in accord with the provisions of Section 4.10.3.1 of the Zoning Ordinance
Section 4.10.3. 1 states:
"The height limitations of this chapter shall not apply to barns, silos, farm buildings,
agricultural museums designed to appear as traditional farm buildings, residential
chimneys, spires, flag poles, monuments or transmission towers and cables; smokestack,
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water tank, radio or television antenna or tower, provided that except as otherwise
permitted by the commission in a specific case, no structure shall be located closer in
distance to any lot line than the height of the structure; and, provided further that such
structure shall not exceed one hundred (100) feet in height in a residential district. This
height limitation shall not apply to any of the above designated structures now or
hereafter located on existing public utility easements".
According to the requirements of this provision, the proposed tower would need to be located a
minimum of 85 feet from the edge of the property, which would place it closer to Route 29
South. The current location is approximately 40 feet from the closest property line, that
boundary shared with the parcel to the south; the residence on the parcel to the south is located
50 to 60 feet from the shared boundary. An existing row of trees parallels the boundary between
the two parcels. In staffs opinion, granting of the setback reduction is not appropriate in this
case due to the proximity of the residence on the adjacent parcel. It should be noted that the
residence of the property owner of the subject parcel lies approximately 100 feet from the tower
location, also of some concern to staff
SUMMARY:
Staff has identified the following factors which are favorable to this request:
1 . The tower will provide increased wireless capacity which may be considered consistent
with the provisions of Sections 1.43, 1.4.4 and 1.5;
2. The tower will not restrict permitted uses on adjacent properties;
3. Access to the tower will be from an existing driveway, through an existing
entrance;
4. In addition to residential use, the parcel is presently used for a convenience store;
Staff has identified the following factors which are unfavorable to this request:
1. A non-agricultural/forestal use will be introduced into a rural area;
2. The tower is visible from Route 29 South, a designated Entrance Corridor;
3. Staff is not able to verify that all alternative locations for this tower have been fully
explored;
4. As proposed, the tower will require a setback reduction from the property: in the event of
failure, or falling ice or debris resulting from the telecommunications use, concerns exist
regarding potential impacts to the existing residence on the adjacent property;
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5. In the event of failure of the tower, or falling ice or debris resulting from the
telecommunications use, concerns exist regarding potential impacts to the existing
residence and the convenience store, a public business, on the property.
The following factor is relevant to this consideration:
1. There is existing reasonable uses of the property [residential and commercial use].
Staff opinion is that this request does not comply with the provisions of the ordinance and the
Comprehensive Plan, and recommends denial of the applicantion.
RECOMMENDED ACTION:
Staff opinion is that this request does not comply with the provisions of the ordinance and the
Comprehensive Plan. Staff feels that negative impacts from the tower would be substantial and
cannot be mitigated on this site. However, should the Commission recommend approval of this
application, staff offers the following recommended conditions of approval.
RECOMMENDED CONDITIONS OF APPROVAL:
1. The height of the tower shall not exceed ten (10) feet above the height of the large
oak tree located west of the proposed lease site. The applicant shall provide a
certified statement on the height of this tree. A lightning rod approximately one
(1) inch in thickness may extend two (2) feet above the height of the tower;
2. The tower shall be designed, constructed and maintained as follows:
a. The tower shall be wood;
b. Guy wires shall be not permitted;
c. The tower shall have no lighting;
d. The tower shall not be painted and shall be natural wood color;
3. The tower shall be located on the site as follows:
a. The tower shall be located on the site as shown on the attached plan entitled
"Survey of a Lease Parcel & Ingress Egress Easement for CFW Wireless on the
Land of J& F Ekman, Inc." dated February 25, 1999 and initialed "SET, 3/15/99;"
b. The lease area shall not be fenced;
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4. Antennas may be attached to the tower only as follows:
a. Antenna shall be limited to two (2)panel antenna not to exceed six
(6) feet in height, mounted flush against the wooden pole and not
to extend above the top of the pole;
b. Satellite and microwave dish antennas are prohibited;
5. The tower shall be used, or have the potential to be used, for the collocation of other
wireless telecommunications providers, as follows:
a. The permittee shall allow other wireless telecommunications providers to
locate antennas on the tower and equipment on the site, subject to these
conditions:
1. Prior to approval of a final site plan for the site or the waiver of the
site plan requirement, the permittee shall execute a letter of intent
stating that it will make a good faith effort to allow such location
and will negotiate in good faith with such other provider requesting
to locate on the tower or the site;
2. The permittee shall provide to the County, upon request, verifiable
evidence that it has made a good faith effort to allow such location.
Verifiable evidence of a good faith effort includes, but is not
limited to, evidence that the permittee has offered to allow other
providers to locate on the tower and site in exchange for reciprocal
rights on a tower and site owned or controlled by another provider
within Albemarle County;
6. Each outdoor luminaire shall be fully shielded such that all light emitted is
projected below a horizontal plane running though the lowest part of the shield or
shielding feature. For purposes of this condition, a "luminaire" is a complete
lighting unit consisting of a lamp or lamps together with the parts designed to
distribute the light, to position and protect the lamps, and to connect the lamps to
the power supply. Outdoor lighting shall only be on during periods of
maintenance;
7. Prior to beginning construction or installation of the tower or the equipment building, or
installation of access for vehicles or utilities, the permittee shall obtain authorization from
the Director of Planning to remove existing trees on the site. The Director of Planning
shall identify which trees may be removed for such construction or installation. Except
for the tree removal expressly authorized by the Director of Planning, the permittee shall
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not remove existing trees within two hundred (200) feet of the tower, the equipment
building, or the vehicular or utility access;
8. The permittee shall comply with section 5.1.12 of the Zoning Ordinance. Fencing of the
lease area shall not be required;
9. Access road improvements shall be limited to drainage improvements and
minimal grading necessary to improve the travel surface and the application of
gravel. Should installation of the tower require provision of greater access
improvements, these improvements shall be removed or reduced after installation
is completed;
10. The regular service interval shall be as indicated by the applicant and described
herein, except as necessary for repair and restoration of service;
11. The tower shall be disassembled and removed from the site within ninety (90)
days of the date its use for wireless communications purposes is discontinued;
12. The permittee shall submit a report to the zoning administrator once per year, by
not later than July 1 of that year. The report shall identify each user of the tower
and shall identify each user that is a wireless telecommunications service
provider;
15. No slopes associated with construction of the tower and accessory uses shall be
created that are steeper than 2:1 unless retaining walls, revetments, or other
stabilization measures acceptable to the County Engineer are employed.
The Planning Commission only must take the following action in order to authorize a site plan
waiver:
A waiver of the drawing of a site plan has been granted in accord with the provisions of Section
32.2 subject to the following conditions:
1. Should the area of disturbance exceed 10,000 square feet (including the access
road), an erosion and sediment control plan shall be approved prior to the issuance
of a building permit;
2. Provision of one parking space;
3. Issuance of Certificate of Appropriateness prior to final zoning approval.
The applicant's proposal requires approval of a setback reduction for the lease area. Should the
Planning Commission recommend approval of the special use permit for the tower use, staff
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recommends that the relocation of the lease area on the parcel be explored, so that in the event of
tower failure, a setback as required by Section 4.10.3.1 can be maintained. This recommendation
is offered based on the proximity of private residences.
ATTACHMENTS:
A—Location Map
B — Survey of Property
C—Applicant's Justification
D—Tower and Antenna Design
E—Topographical Map
F—Letter from Nursery
C•I PLANNING I TOWERSI Red Hill(Sarge's)SP rpt.doc
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TAX PARCEL 87B 4A
DEED BOOK 1276 PG. 32
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IATTACHMENTC
Section 31.2.4.1 of the Albemarle County Zoning Ordinance states that, "The board a supervisor
hereby reserves unto itself the right to issue all special use permits permitted hereunder. Special use
permits for uses as provided in this ordinance may be issued upon a finding by the board of supervisors
that such use will not be of substantial detriment to adjacent property, that the character of the district
will not be changed thereby and that such use will be in harmony with the purpose and intent of this
ordinance,with the uses permitted by right in the district,with additional regulations provided in section
5.0 of this ordinance, and with the public health, safety and general welfare.
The items which follow will be reviewed by the staff in their analysis of your request. Please complete
this form and provide additional information which will assist the County in its review of your request.
If you need assistance filling out these items, staff is available.
What is the Comprehensive Plan designation for this property?
How will the proposed special use affect adjacent property? 11 r(I nn-1 Qf(erf -/ t 7 propeA-Ft/
How will the proposed special use affect the character of the district surrounding the property? / ',1/1( tir?f (. rec.-i"
-iLe c1 iron-feit r^-t ltu) ('Iicfrrcf st(wound(lr;J pop.er-/y.
How is the use in harmony with the purpose and intent of the Zoning Ordinance? L orally-14 G`t Al"pphnrtc ,DDIPS
170 G1icbtor --fZw oliPv�9e free Gto,.9ht ILi 4144% avez (poke Ps/_bltch✓nent nt �ZtrS
-Puri Ill C'rdv y OLIS * 4 rauPiTy c (est(.164- s.
How is the use in harmony with the uses permitted by right in the district? OW ?fly/Wed by Vic ti f,
What additional regulations provided in Section 5.0 of the Zoning Ordinance apply to this use? See#1O1/i S / /2
How will this use promote the public health,safety,and general welfare of the community? YrOVi(( c 0/-/e6'/1((-/jVe
irealgj Of (0114 ltirc.v4.rra17-Wi via wirers -1-etepkome arid a(,So fvDVideS ewerce✓1C
� y
Means & eovu tt-+ ;rafi2,n r,vr -tiny o-r [i,P.
2
Describe your request in detail and include all pertinent information such as the numbers of persons
involved in the use,operating hours,and any unique features of the use:
CFiA1 U/iv_Cpss lb1) '7(f5 k erect- Qv; 'O" o tree Gte5I4 level -f he(epovie pale
wiltt« icy Wee5 w( -Iwo ganef no-levtiv_s avid ve(a-Fed tiewiort ocn -f1ito 5r� rv�rf.
-atitS sae t(/,1( O1;edccie 2g y'I uic a day TUi pptt ik 5Pyuice -t ,itw Sllvo,(nciLm
eovomt,Cvtct) .
ATTACHMENTS REQUIRED -provide two(2) copies of each:
1. Recorded plat or boundary survey of the property requested for the rezoning. If there is
no recorded plat or boundary survey,please provide legal description of the property and
the Deed Book and page number or Plat Book and page number.
Note: If you are requesting a special use permit only for a portion of the property, it
needs to be described or delineated on a copy of the plat or surveyed drawing.
❑ 2. Ownership information -If ownership of the property is in the name of any type of legal
entity or organization including,but not limited to,the name of a corporation,partnership
or association,or in the name of a trust,or in a fictitious name,a document acceptable to
the County must be submitted certifying that the person signing below has the authority
to do so.
If the applicant is a contract purchaser, a document acceptable to the County must be
submitted containing the owner's written consent to the application.
If the applicant is the agent of the owner, a document acceptable to the County must be
submitted that is evidence of the existence and scope of the agency.
OPTIONAL ATTACHMENTS:
ai 3. Drawings or conceptual plans, if any.
❑ 4. Additional Information, if any.
I hereby certify that I own the subject property, or have the legal power to act on behalf of the owner in
• filing this application. I also certify that the information provided is true and accurate to the best of my
knowledge.
Sign• - '17;1/ s .--1( -77)/arilL
Date /
IP t/7,/4/ &' m . 0/ � _ "730
Printed Name Daytime phone number of Signatory
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ATTACHMENT F
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5-eM 69„
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aynesboro
LANDSCAPE& GARDEN CENTER
P. 0. Box 717 • 2032 West Main Street • Waynesboro,Va. 22980 • Phone: 540/942-4646 • 540/942-5194
April 8, 1999
Steve Yancey
CFW Wireless
PO Pox 1328
Waynesboro, VA 22980
Re: Site CV 113-Red Hill
Dear Steve
The proposed pole at the above site should not be detrimental to the nearby Oak tree.
The tree is located 48' from the proposed pole location. The drip line is 30' out from the
trunk leaving clearance of 18' for future growth at its closest point. I would, however,
caution the installation contractor to not drive equipment within the drip line as this may
cause damage to the tree. If you should have any questions please do not hesitate to
contact me.
Sincerely
it4., ,DC. , ,
Atif,
Lee Quillen
LQ:ph
RECEWED
aNM f ,
Planning Dept.
AMERICAN ASSOCIATION OF NATIONAL LANDSCAPE VIRGINIA NURSEYMEN'S
NURSEYMEN. INC. NURSEYMEN'S ASSOCIATION ASSOCIATION, INC.
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