HomeMy WebLinkAboutCOC Packet 2023-02-15 DEPARTMENT OF PLANNING
215 N. Tioga St 14850
607.273.1747
www.town.ithaca.ny.us
2/7/2023
TO: Codes and Ordinances Committee:
William Goodman, Chair
Rob Rosen
Eric Levine
Eva Hoffmann
Chris Jung
Ariel Casper
FROM: Christine Balestra, Planner
RE: Next Codes and Ordinances Committee Meeting – February 15, 2023
The next meeting of the Codes and Ordinances Committee is scheduled for Wednesday,
February 15, 2023, at 5:30pm in the Shirley A. Raffensperger Board Room, located in Town Hall
at 215 North Tioga Street. A quorum of the Town of Ithaca Town Board may be present at this
meeting. However, no official Town Board business will be conducted.
The following items are attached:
1. Minutes from the December 14,2022, and January 25, 2023, COC meetings.
2. Previously distributed telecommunication setback maps showing 250, 300, 1500-foot
radius between facilities and residences in blue.
3. Draft New Telecom Provisions to Review.
If you cannot attend this meeting, please notify Abby Homer as soon as possible at (607) 273-
1747, or ahomer@town.ithaca.ny.us.
cc: Susan H. Brock, Attorney for the Town
C.J. Randall, Director of Planning
Marty Moseley, Director of Code Enforcement
Abby Homer, Administrative Assistant
Paulette Rosa, Town Clerk (email)
Town Administrative staff (email)
Town Board Members (email)
Town Code Enforcement staff (email)
Town Planning staff (email)
Town Public Works staff (email)
Media
TOWN OF ITHACA CODES AND ORDINANCES COMMITTEE
215 North Tioga Street
Ithaca, New York 14850
(607) 273-1747
PLEASE NOTE: This meeting will be held in person in the Shirley A. Raffensperger Board
Room, Town Hall, located at 215 North Tioga Street, Ithaca, NY, with an option for members
of the public to join the meeting via Zoom. The Zoom link is below. Members of the public
who wish to view the meeting virtually may visit the Town of Ithaca YouTube Channel, where
it will be uploaded after the meeting:
https://www.youtube.com/channel/UCC9vycXkJ6klVIibjhCy7NQ/live
Join Zoom Meeting: https://us06web.zoom.us/j/5063713554
Meeting ID: 506 371 3554
Dial in #: 1(929) 436-2866
Meeting of February 15, 2023– 5:30 P.M.
AGENDA
1. Member comments/concerns.
2. Review of minutes from December 14, 2022, and January 25, 2023, COC meetings.
3. Review of revised draft New Telecommunications Provisions, prepared by Susan
Brock.
4. Other business:
• Next meeting date: March 8, 2023
• Next meeting agenda
Town of Ithaca Planning Department
February 7, 2023
1
TOWN OF ITHACA CODES AND ORDINANCES COMMITTEE (COC)
Meeting of January 25, 2023 – 5:30 pm
Town Hall Aurora Conference Room
Draft Minutes
Members Present: In person: Bill Goodman, Chair, Ariel Casper & Eric Levine.
Excused: Eva Hoffmann & Rob Rosen. Zoom-participant/guest Chris Jung.
Staff Present: Chris Balestra, Planner; Susan Brock, Counsel; and C.J. Randall, Director of Planning.
Staff via Zoom: Marty Moseley, Director of Code Enforcement.
Guests: None
Bill reviewed the agenda aloud and mentioned possibly going into closed session at the end of the
meeting to seek the advice of counsel. C. J. Randall was introduced and welcomed as the new Town of
Ithaca Director of Planning. Bill also noted that the committee did not have a quorum of members, so
there could not be a vote to approve minutes from the December 14, 2022 COC meeting. This will be
done at the February COC meeting.
1. Member comments/concerns: None.
2. Continued review of revised draft local law - §270-219 Personal wireless service facilities:
Susan Brock submitted the latest set of provisions for the committee to review. A summary of the
discussion and COC changes are below:
SUBSTANTIVE PROVISIONS RE: SIGNIFICANT GAPS/LEAST INTRUSIVE MEANS FINDINGS: Susan
asked the committee if this finding should be made for every facility application or only those
which require site plan review by the Planning Board. The committee agreed that these should
be for those requiring site plan review, so all references to the Director of Code Enforcement
should be deleted. Susan will make changes in the next revision to reflect this.
• First paragraph under this section, last sentence: add “to and” between the words voice
calls and landlines that are connected…
• Page 2:
o Item (c) - has some wording that needs to be revised and will be revised by counsel.
o Item (d) - Susan will add language related to dropped call and failure rates, along with
whether customers are affected for only a limited period.
o Under 2, second paragraph – remove “Director of Code Enforcement,” change “and” to
“or” just before item (ii).
• Page 3 – at top. More research will be done regarding denying the application where safety
standards are not met.
FINDINGS ON APPLICATIONS: Page 3- The findings will need to be revised to show which apply
to all applications, and which apply only to those applications requiring site plan review
2
(findings for applications requiring site plan review include whether there is a significant gap
and the project is the least intrusive means to address the gap). The list of seven items under
“C. General criteria” will be sorted out.
• Number 7 - The committee agreed to keep the co-location design requirement for proposed
towers (except towers that are small wireless facilities).
REMOVAL PROVISIONS: The language in this section was sent to the Town Engineer for review
and counsel is awaiting comments. There is reference to the value of the security bond for
removal being determined by the Town Engineer. An alternative would be the value being
provided by the applicant in a cost estimate, and a review of the amount by the Town Engineer
or Town consultant. The committee agreed to the applicant providing the cost estimate for
removal.
• Regarding second paragraph – notice provisions. The current telecom law does not have
this. Committee discussed whether it is necessary and how the Town would know if
facilities were obsolete/unused. Final decision – if a facility becomes obsolete or ceases to
be used for its intended function for 120 consecutive days, do not include a requirement
that the Town notify the owner/operator of the obsolete or unused facility, but require
owner/operator removal within 90 days after the 120 day period runs. The security could
then be used to remove it, if necessary.
VISUAL IMPACT ANALYSIS REVISIONS: The committee did not have any changes or comments to
the proposed language.
TOWN CONSULTANTS:
• Revised wording in 270-219.K(4) - Keep or delete “attorneys” on the list of services to be
covered in the escrow fee? The committee agreed to keep attorneys on the list.
• Revised wording in 270-219.K(5) - Remove “or any” seven lines into the paragraph, after
the exceeding 50 feet language. The committee discussed the minimum deposit amount
and ultimately agreed to not put a dollar amount in the local law, rather reference the fee
schedule where the amount would be set by Town Board resolution and could be revisited.
The total would not be more than the greater of any required escrow or 5% of the project
cost, not including SEQRA.
On the topic of town consultants, Chris Balestra reported a conversation with a local resident
who has sat in on the City of Ithaca ‘s recent AT&T telecommunications proposals. It was
observed that large amounts of data were submitted by AT & T and that most of the data did
not include the information required by the city requirements, e.g., dropped call logs. She
noted that FCC shot clock requirements could prohibit internal staff from conducting a
thorough review. The local resident suggested that the town consider hiring an independent
consultant expert to review the applications. The committee agreed that this was a good idea
and considered setting up a system with a list of consultants/contracts ahead of time, so if this
3
situation occurs at the town, then the town would have a list on call who could review
applications in a way that would not conflict with the shot clock.
PERSONAL WIRELESS SERVICE FACILITY PERMIT: Based on recommendation by the Director of
Code Enforcement, the committee agreed that this definition should read that the permit be
issued by the Director of Code Enforcement, after recommendation by the Director of Planning,
only where site plan review is not required.
SETBACK-this language was related to events where an applicant leases only a portion of the
lot. The committee agreed with staff to delete the following sen tence “In the event that an
Applicant leases only a portion of the lot, the Setback shall be measured from the Facility to the
line of that portion of the real property which is leased by the Applicant.”
The review of the revised telecommunications provisions concluded. Additional sections will be
provided for committee review at the next meeting.
3. Other Business:
Next meeting: February 15, 2023, at 5:30 p.m. Bill noted he would allow public comment at
the beginning of the meeting. He also mentioned that he intends this to be the final review of the
telecommunications law language for the committee before recommending it to the town board.
Note: Eva is excused from the 2/15 meeting. Chris B will check in with the member not in attendance
to confirm for 2/15.
Next meeting agenda:
Final review and discussion of draft §270-219 Personal wireless service facilities.
Minutes-tabled from previous meeting due to no quorum. No changes noted.
The meeting concluded at 6:41 p.m.
250-foot Radius Around Residences in the Town of Ithaca
Map prepared by Town of Ithaca Engineering with data from Tompkins County GIS, October 20, 2021
0 1 20.5 Miles
(Blue circles indicate 250-foot radius)
300-foot Radius Around Residences in the Town of Ithaca
Map prepared by Town of Ithaca Engineering with data from Tompkins County GIS, November 18, 2021
0 1 20.5 Miles
1500-foot Radius Around Residences in the Town of Ithaca
Map prepared by Town of Ithaca Engineering with data from Tompkins County GIS, October 20, 2021
0 1 20.5 Miles
(Blue circles indicate 1500-foot radius)
New telecom law provisions to review at 2/15/23 COC meeting
1
Application Requirements
1. The draft law currently includes submission of “Information required by, and proof of
compliance with, subsection H (Co-location) below," which requires an inventory and analysis
of opportunities to co-locate onto existing telecommunications facilities and other structures.
Where co-location is not proposed or feasible, add a submission requirement for analysis of less
intrusive alternate sites that do not afford a co-location opportunity:
(2) Applications for all other PWSFs must include:
….
New provision:
(r) If site plan approval is required, and if co-location is not proposed and is not feasible, an
alternative site analysis of all potentially less intrusive alternative sites not involving co-location
which the applicant has considered. This alternative site analysis shall document each site’s
respective location, elevation, and suitability to remedy a significant gap in the coverage of the
applicant’s Personal Wireless Services. For suitable alternative sites that an applicant claims are
unavailable, the applicant shall submit evidence of good-faith efforts to secure use of each such
site from its owner.
2. Add this submission requirement:
Where site plan review is required, evidence of the existence of a significant gap in the coverage
of the applicant’s Personal Wireless Services (the ability of wireless telephones to make and
receive voice calls from land-lines that are connected to the national telephone network). Such
evidence shall include the nature of each gap and its geographic location and boundaries.
[Immediately after the above new provision, insert the wording COC reviewed on 01/25/23 re:
evidence that a gap exists. Evidence to be submitted with application includes In-Kind Call
Testing, test maps, dropped call records, and denial of service records.]
Will also add wording in the Adequate Coverage definition (if it is retained) or elsewhere in the
law to make it clear that a claim of a need for “future capacity” does not establish a significant
gap in coverage.
3. Add this submission requirement:
A noise study or written statement, prepared by a qualified engineer, assessing the proposed
Personal Wireless Service Facility’s compliance with the noise requirements in section __. The
assessment shall include noise from equipment, such as air conditioning units and back-up
generators.
4. Add this submission requirement:
Proof of compliance with applicable National Environmental Policy Act requirements. If NEPA
review requirements apply and the applicant asserts the proposed Personal Wireless Service
New telecom law provisions to review at 2/15/23 COC meeting
2
Facility falls under any categorical exclusions, the applicant shall identify which categorical
exclusion(s) the applicant is asserting applies, and submit proof that the Facility falls under the
categorical exclusion(s).
5. Add this submission requirement:
Proof of compliance with applicable National Historic Preservation Act requirements.
NOISE
The Town of Ithaca’s current law does not mention noise. Add a reference to the Town’s Noise
chapter, which was adopted after the current telecom law was put in place:
No Personal Wireless Service Facility shall produce noise in violation of Town of Ithaca Code
Chapter 184 (Noise).
If COC wants to be more specific, could add:
In addition, noise from a Personal Wireless Service Facility shall at no time be audible at the
property line of any lot (i) zoned Residential or Conservation, or (ii) on which a dwelling unit
exists.
HEIGHT
The Town of Ithaca’s current telecom law says this about height: “If the proposed height of the
telecommunications facility exceeds the permitted height of structures in the zoning district in
which the facility is proposed to be located, notwithstanding any other provisions of this chapter,
a height variance from the Board of Appeals shall also be required.” Keep or change this?
VISUAL IMPACT ANALYSIS
COC approved visual impact analysis wording that requires things like line-of-sight drawings;
detailed elevation maps; visual simulations, including photographic images; before and after
renderings; alternate Facility designs and color schemes; and analysis of impacts on
important/scenic views.
Does COC want to add a balloon test requirement, at least under the situation contemplated in
the City of Ithaca’s law? City’s wording:
The photographs described in Subsection C(2)(b) and (c) must be taken from the interior
perspective of the properties situated in closest proximity to the proposed installation, unless the
applicant can show proof that it attempted to secure such images, but that the owners of such
properties refused to grant them access to obtain such images. If the owners of such properties
have refused to grant the applicant access, the applicant may depict the height, distance from the
property, and sight line representation by balloon test.
New telecom law provisions to review at 2/15/23 COC meeting
3
RF EMISSIONS
At its 12/14/22 meeting, COC reviewed Certification of Compliance with RF Emission Limits
provisions that require the owner and operator to submit initial and annual certifications and
allow the Town to do random and unannounced testing. Add a provision directly requiring
compliance with RF emissions limits:
A PWSF must comply at all times with applicable FCC Maximum Permissible Exposure (MPE)
limits for General Population/Uncontrolled Exposure codified in 47 CFR § 1.1310(e)(l), Table 1
or any successor regulation.
FINDINGS WHERE SITE PLAN IS REQUIRED
Add these to the findings the Planning Board must make (these are in addition to other findings
COC has reviewed):
[1] Potential adverse aesthetic impacts: whether the proposed installation will inflict a
significant adverse aesthetic impact upon properties that are located adjacent to, or in close
proximity to, the proposed site, or any other properties situated in a manner that would
sustain significant adverse aesthetic impacts by the installation of the proposed facility.
[2] Potential adverse impacts upon real estate values: whether the proposed installation will
inflict a significant adverse impact upon the property values of properties that are located
adjacent to, or in close proximity to, the proposed site, or properties that are otherwise
situated in a manner that would cause the proposed installation to inflict a significant
adverse impact upon their value.
[3] Potential adverse impact upon the character of the surrounding community: whether the
proposed installation will be incompatible with the use and/or character of properties
located adjacent to or in close proximity to the proposed site or other properties situated in a
manner that would cause the proposed installation to be incompatible with their respective
use.
[4] Potential adverse impacts upon historic properties or historic districts: whether the proposed
installation will be incompatible with and/or would have an adverse impact upon, or detract
from the use and enjoyment of, and/or character of a historic property, historic site, and/or
historic district, including but not limited to historic structures, properties and/or districts
which are listed on, or are eligible for listing on, the National Register of Historic Places.
[5] Potential adverse impacts upon ridgelines or other aesthetic resources of the Town: whether
the proposed installation will be incompatible with and/or would have an adverse aesthetic
impact upon or detract from the use and enjoyment of, and/or character of, recognized
aesthetic assets of the Town including, but not limited to, scenic areas and/or scenic
New telecom law provisions to review at 2/15/23 COC meeting
4
ridgelines, scenic areas, public parks, and/or any other traditionally or historically
recognized valuable scenic assets of the Town.
[6] Sufficient fall zones: whether the proposed installation shall have a sufficient fall zone
and/or safe zone around the facility to afford the general public safety against the potential
dangers of structural failure, icefall, debris fall, and fire.
[7] Mitigation: whether the applicant has mitigated the potential adverse impacts of the
proposed facility to the greatest extent reasonably feasible. To determine mitigation efforts
on the part of the applicant, the mere fact that a less intrusive site, location, or design would
cause an applicant to incur additional expense is not a reasonable justification for an
application to have failed to propose reasonable mitigation measures.
REASONABLE DELAYS THAT EXTEND THE SHOT CLOCK
If the Planning Board and/or Director of Code Enforcement acts with reasonable diligence to
complete its SEQRA review and to ascertain the applicant’s compliance with the National
Environmental Policy Act, and these actions require a period of effort that extends beyond the
expiration of the applicable shot clock period, the delays beyond such shot clock period
attributable to such actions shall be deemed reasonable.
If the Planning Board and/or Director of Code Enforcement acts with reasonable diligence to
ascertain the applicant’s compliance with the National Historic Preservation Act, and these
actions require a period of effort that extends beyond the expiration of the applicable shot clock
period, the delays beyond such shot clock period attributable to such actions shall be deemed
reasonable.
If an applicant tenders eleventh-hour submissions to the Town in the form of: a) expert reports;
b) expert materials; or c) materials which require a significant period for review due either to
their complexity or their sheer volume, the Planning Board and/or Director of Code Enforcement
shall be afforded a reasonable time to review such late-submitted materials. If the Planning
Board and/or Director of Code Enforcement acts with reasonable diligence to complete such
review, and the review requires a period of effort that extends beyond the expiration of the
applicable shot clock period, the delays beyond such shot clock period attributable to such
review shall be deemed reasonable.
Force majeure. In the event that the rendering of a final decision upon a site plan application or a
PWSF permit application is delayed due to events and/or forces which are not within the
reasonable control of the Town (including reasonable control of the Planning Board or Town
officers and employees), including, without limitation, acts of God, flood, fire, earthquake,
explosion, governmental actions, war, invasion or hostilities (whether war is declared or not),
terrorist threats or acts, riot, or other civil unrest, national emergency, revolution, insurrection,
epidemic, pandemic, lock-outs, strikes or other labor disputes (whether or not relating to the
Town’s workforce), or power outage, such delays shall constitute reasonable delays and shall be
New telecom law provisions to review at 2/15/23 COC meeting
5
recognized as acceptable grounds for extending the period for review and the rendering of final
determinations and permit issuance beyond the period allotted under the applicable shot clock.
SAFETY/MAINTENANCE
Add from the Town of Ithaca’s current law:
Every Personal Wireless Service fFacility shall be inspected at least every second year for
structural integrity by a New York State licensed engineer. A copy of the inspection report shall
be submitted to the Building and Zoning Enforcement OfficerDirector of Code Enforcement.
Any unsafe condition revealed by such report shall be corrected within 10 days of notification of
same to the record landowner on which the fFacility is constructed. The time period for
correction may, on application of the landowner or owner of the fFacility, be extended by the
Planning Board Director of Code Enforcement if it is impracticable to complete the correction
within said 10 days and if there is no imminent danger to life, limb, or other person's property. If
the unsafe condition is not corrected within the applicable time period, or if the required
inspection is not provided to the Town, the special Personal Wireless Service Facility permit for
construction of the fFacility may, after a hearing by the Planning Town Board on at least 10
days' prior notice to the landowner of record given by overnight mail, certified mail, return
receipt requested, or other equally effective manner of providing notice, be revoked by such the
Town Board. Revocation may occur only if the Town Board finds either a) that the required
inspection has not been provided or b) that there is an unsafe condition which poses a risk of
bodily injury or significant property damage. Upon such revocation, the fFacility shall be
removed or dismantled to the point of removing all unsafe conditions.
MISCELLANEOUS
Add from the Miscellaneous section of the Town of Ithaca’s current law:
Any special permit or site plan or Personal Wireless Service Facility pPermit granted hereunder
shall be valid only for the dimensions and number of structures for the telecommunications
fFacility contained in the original application as so approved. Any subsequent changes or
modifications shall require a new application for same following the procedures set forth in this
section.
-------------------------
Whenever reference is made to an engineer's certificate or report in this section, the same shall
be provided by a professional engineer licensed in the State of New York. who is reasonably
satisfactory to the Planning Board.
PURPOSE
The City of Ithaca’s law includes in its purposes clauses “minimizing the number of facilities
used to provide such coverage, avoid unnecessary, redundant wireless infrastructure”. Add
this? The Town’s draft law purposes include “Encourage the co-location of personal wireless
New telecom law provisions to review at 2/15/23 COC meeting
6
service facilities on existing structures rather than the construction of new support structures,”
which may achieve the same thing with more precise wording. Also, depending on
circumstances, two shorter facilities may sometimes be preferable to one taller facility.
INSURANCE
The following wording is from the City of Ithaca’s law—will wordsmith this if COC wants to
include an insurance provision. Wording should account for the fact that general liability
policies are likely to exclude coverage for radiation and electromagnetic field emissions, so a
separate pollution liability policy likely would be needed. Also need to check whether the Town
can be listed as a “coinsured” on the policy, or if instead the Town would be covered as an
“additional insured.”
The applicant shall maintain adequate and sufficient liability insurance during the construction
period and thereafter, the carrier shall maintain liability insurance meeting the criteria of this
section throughout the life of any PWSF erected within the City of Ithaca. Prior to the issuance
of any necessary permit, whether special permit or building permit, documentation that liability
insurance in the amount of at least $1,000,000 single occurrence, $3,000,000 aggregate has been
secured identifying the City as coinsured shall be submitted to the Department of Planning and
Development, such policy shall not include a pollution exclusion. The carrier’s maintenance
without interruption of liability insurance in like or greater amount with the City named as
coinsured is a continuing condition of any permit or certificate of building compliance.
SEVERABILITY (IN CASE JUDGE FINDS A PROVISION CONFLICTS WITH
FEDERAL OR STATE LAW)
This is the wording in the Town’s Sign Law and it can be used for the telecom law.
Severability. If any clause, sentence, paragraph, section or part of this article § 270-219 shall be
adjudged by any court of competent jurisdiction to be invalid, such judgment shall not affect,
impair or invalidate the remaining portions hereof, but shall be confined to the clause, sentence,
paragraph, section or part thereof directly involved in the controversy in which such judgment
shall have been rendered.
PWSF PERMIT RENEWALS
Town staff will work on a provision about PWSF Permit duration and renewal procedures.
SETBACKS
Any setbacks from dwelling units are TBD.