Transmittal - 2/2/2022ERIN MENDENHALL DEPARTMENT of COMMUNITY
Mayor and NEIGHBORHOODS
Blake Thomas
Director
SALT LAKE CITY CORPORATION
451 SOUTH STATE STREET, ROOM 404 WWW.SLC.GOV
P.O. BOX 145486, SALT LAKE CITY, UTAH 84114-5486 TEL 801.535.6230 FAX 801.535.6005
CITY COUNCIL TRANSMITTAL
________________________ Date Received: _________________
Lisa Shaffer, Chief Administrative Officer Date sent to Council: _________________
______________________________________________________________________________
TO: Salt Lake City Council DATE: February 1, 2022
Dan Dugan, Chair
FROM: Blake Thomas, Director, Department of Community & Neighborhoods
__________________________
SUBJECT: Petition PLNPCM2020-00284 - Request to Allow Stealth Wireless
Telecommunication Facilities taller than 35 feet (up to 75 feet) in height within
the PL – Public Lands Zoning District
STAFF CONTACT: Aaron Barlow, Principal Planner
801-535-6182, aaron.barlow@slcgov.com
DOCUMENT TYPE: Ordinance
RECOMMENDATION: The Planning Commission has recommended that the City Council
deny the request to amend the Salt Lake City Zoning Ordinance to allow Stealth Wireless
Telecommunication Facilities taller than 35 feet (up to 75 feet) in height within the PL – Public
Lands Zoning District.
BUDGET IMPACT: None
BACKGROUND/DISCUSSION: Pete Simmons of Cellco Partnership (dba Verizon Wireless)
submitted a request to amend the Salt Lake City Zoning Ordinance to allow Stealth cellular towers
up to 75 feet in height as a Conditional Use in the PL Public Lands Zoning District. Stealth
facilities are currently limited to 35 feet in height. This request is specifically related to a proposal
by the applicant to construct a stealth cellular tower at the Pioneer Police Precinct at 1040 West
700 South, but the proposed text amendment would apply to properties within the PL district
citywide.
Under current regulations in Section 21A.40.090.E of the Zoning Ordinance, stealth wireless
facilities are permitted in all zoning districts provided they are “completely disguised as another
object concealed from view thereby concealing the intended use and appearance of the facility.”
To qualify as a stealth facility, a tower needs to do the following:
1. “Conform with the dimensions of the object it is being disguised as,”
2. “Be in concert with its surroundings,” and
Lisa Shaffer (Feb 2, 2022 14:42 MST)02/02/2022
02/02/2022
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3. Meet “the provisions contained in section 21A.36.020, [including] tables 21A.36.020.B
and 21A.36.020.C.”
Section 21A.36.020 of the Zoning Ordinance regulates lot and bulk controls. It requires that all
lots and structures must meet “the lot area, lot width, yards, building height and other requirements
established in the applicable district regulations.” Exceptions are allowed for certain obstructions
in a required yard (table 21A.36.020.B) and height (table 21A.36.020.C). Allowed height
exceptions include church steeples, elevator/stairwell bulkheads, flagpoles, and light poles for
sports fields. Wireless facilities disguised as trees (or anything else not listed in the height
exceptions table) are not a permitted obstruction beyond the maximum height of a zoning district.
In response to the perceived limitations that the Zoning Ordinance placed on stealth wireless
communication facilities, the applicant submitted a text amendment application to modify sections
21A.32.070 (PL Public Lands District) and 21A.40.090.E (Wireless Telecommunication
Facilities) of the City’s zoning regulations to allow stand-alone stealth cell towers up to 75 feet
tall as a Conditional Use in only the PL Public Lands Zoning District.
At their meeting on December 8, 2021, the Planning Commission voted to send a negative
recommendation to the City Council regarding this proposal because it did not meet the standards
for a zoning text amendment. Specifically, they provided a negative recommendation because the
proposal would also impact residential districts adjacent to properties within the PL district, and
the proposal was a response to a single issue in the ordinance and did not address stealth facilities
more broadly. Additional information regarding this request can be found in Staff’s report for the
Commission. Draft ordinances are not provided with requests that have received a negative
recommendation from the Planning Commission.
PUBLIC PROCESS:
Community Council Notice: A notice of application was sent to all Salt Lake City Recognized
Community Organizations on October 5, 2021, regarding the proposed text amendment. The
Recognized Organizations were given 45 days to respond with any concerns or to ask the applicant
to discuss the proposed amendment at one of their meetings. Three Community Councils
(Sugarhouse, Greater Avenues, and Yalecrest) invited the applicant and Staff to their meetings.
The Sugar House and Greater Avenues Community Councils sent official responses that are
included with Staff’s report to the Planning Commission.
Public Open House: The petition was posted to the Planning Division’s Online Open House
webpage from October 5 to December 1, 2021. Staff received 58 comments from the public, two
of which were in support of the request and the rest opposed. They are included with Staff’s report
to the Planning Commission.
Planning Commission Meeting: On December 8, 2021, the Planning Commission held a public
hearing regarding the proposed zoning text amendment. The only comment was from Judi Short,
representing the Sugar House Community Council, who brought up concerns that she had received
from the neighborhood. The commission voted to provide a negative recommendation to the City
Council with a unanimous vote of 5-0, with one commissioner abstaining.
Planning Commission (PC) Records
a) PC Agenda of December 8, 2021 (Click to Access)
b) PC Minutes of December 8, 2021 (Click to Access, item begins on page 7)
c) Planning Commission Staff Report of December 8, 2021 (Click to Access Report)
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EXHIBITS:
1) Project Chronology
2) Notice of City Council Hearing
3) Comments not included with PC Staff Report
TABLE OF CONTENTS
1. PROJECT CHRONOLOGY
2. NOTICE OF CITY COUNCIL HEARING
3. COMMENTS NOT INCLUDED WITH PC STAFF REPORT
1.Project Chronology
PROJECT CHRONOLOGY
Petition: PLNPCM2020-00284
September 2, 2021 Mr. Simmons submits petition in its current form
October 4, 2021 Petition posted to the Planning Division’s Online Open House
webpage; The public comment period ended November 18, 2021
November 23, 2021 Planning Commission hearing notice posted on City and State
websites.
December 8, 2021 Planning Commission reviewed the petition and conducted a public
hearing. The commission then voted 5-0 to send a negative
recommendation to the City Council.
January 12, 2022 Planning Commission ratified the minutes of the December 8, 2021
meeting
2. Notice of City Council Public Hearing
NOTICE OF PUBLIC HEARING
The Salt Lake City Council is considering Petition PLNPCM2020-00284 - Request to
Allow Stealth Wireless Telecommunication Facilities in the PL – Public
Lands Zoning District – Pete Simmons, representing Cellco Partnership (dba Verizon
Wireless), is requesting to amend section(s) of title 21A.32.070 PL Public Lands District
and 21A.40.090.E Wireless Telecommunication Facilities to increase the allowed height
of stealth wireless telecommunication facilities to 75 feet in the PL Public Lands Zoning
District. Specifically, this request would allow stealth wireless telecommunication
facilities taller than 35 feet in the PL district as a conditional use. The PL district is located
city-wide, so this request would affect all Council Districts. (Staff contact: Aaron Barlow
at 801-535-6182 or aaron.barlow@slcgov.com).
As part of their study, the City Council is holding an advertised public hearing to receive
comments regarding the petition. During this hearing, anyone desiring to address the City
Council concerning this issue will be given an opportunity to speak. The hearing will be
held:
DATE:
TIME: 7:00 p.m.
PLACE: This will be an electronic meeting pursuant to Salt Lake City Emergency
Proclamation No.2 of 2020(2)(b). Please visit slc.gov/council/news/featured-
news/virtually-attend-city-council-meetings-2/ to learn how you can share
your comments live during electronic City Council meetings. If you would like
to provide feedback or comments via email or phone, please contact us
through our 24-hour comment line at 801-535-7654 or by email at
council.comments@slcgov.com.
If you have any questions relating to this proposal or would like to review the file, please
call Aaron Barlow at 801-535-6182 between the hours of 9:00 a.m. and 6:00 p.m.,
Monday through Friday or via e-mail at aaron.barlow@slcgov.com.
The City & County Building is an accessible facility. People with disabilities may make
requests for reasonable accommodation, which may include alternate formats,
interpreters, and other auxiliary aids and services. Please make requests at least two
business days in advance. To make a request, please contact the City Council Office at
council.comments@slcgov.com, 801-535- 7600, or relay service 711.
3. Comments not included with PC Staff Report
ELPCO (East Liberty Park Community Organization) elpcoslc@gmail.com www.facebook/com/ELPCO
December 7, 2021
Dear Salt Lake City Planning Commissioners:
I am writing to oppose the Stealth Towers Text Amendment (PLNPCM2020-00284) on the agenda for the
December 8 meeting.
ELPCO is the East Liberty Park Community Organization, a recognized community organization in Salt Lake City
representing the 4,000 households between Liberty Park and East High School.
ELPCO has been tracking this issue since the initial proposal in 2020 (PLNPCM2020-00284) by Verizon
Wireless to allow stealth towers up to 60 feet tall as conditional uses (i.e., allowable) in all zoning districts.
Along with the Planning Department and several other community councils, we opposed the initial proposal in a
letter dated May 19, 2021, writing, “We believe this proposal goes too far in revising the zoning code and
raising height restrictions to exceed local limits. We believe height limits are one of the most important design
elements of local zoning.”
Now, Verizon has returned with a curtailed proposal to allow taller (75 feet) antennas in more limited areas
(Public Lands-PL districts).
The first thing ELPCO did was seek input from our community. The majority of responses we received have
been favorable or ambivalent to the proposal.
• “Let them install towers so all of us can have service in the area!” wrote BL.
• MH wrote: “Can I put one in my back yard? I can’t get a signal in my house.”
• LB opposes the amendment, writing “We already have their ugly brown cell towers along our
park strips, notably here on the East Bench. This proposal is another step in the wrong
direction.”
• DS replied: “That's the price of technology. If you oppose this don't complain about poor
signal.”
• On Nextdoor.com, DD replied: “I don’t see what the issue is. I don’t see anyone objecting to
electrical poles, and I even tried to rally people to push the city to bury all electrical (which
received a collective groan).”
Improving wireless connectivity and reliability is important to many of our community members. And unlike
utilities, proximity to infrastructure matters when it comes to better cellular service.
Next, we looked at the impact within ELPCO.
There are three major Public Lands-PL districts in ELPCO: East High School, Emerson Elementary, and the SLC
Fire Station #5 on 900 South. Nearby PL districts include Hawthorne Elementary on 700 East and the USPS
Post office on 1100 East. The PL parcel with the densest residential setting is Emerson Elementary, although
any antenna there would likely be sited in the athletic area east of the school and adjacent to the RB zoning
along 1100 East. As a result, the immediate residential impacts of this amendment appear to be limited in
ELPCO… except for the visual impact of a 75-foot metallic brown pine tree with antenna-like foliage jutting
above the 30-foot rooftops of houses so that we can download that 4K Hallmark holiday movie a little bit faster.
ELPCO (East Liberty Park Community Organization) elpcoslc@gmail.com www.facebook/com/ELPCO
Because the potential stealth antennas would be so much taller than any other existing structure in the
neighborhood, this visual impact cannot be ignored.
Lastly, we considered the impact of this amendment on the overall zoning code and application. And based on
this review, we decided to oppose this amendment.
First, the motivation for this amendment appears to be the city’s denial to Verizon to build an 80-foot stealth
antenna at the Pioneer Police Precinct (zoned PL). We don’t think it is wise to change zoning for the entire city
based on the circumstances of one application in a single parcel. Raising the local height restriction for cellular
antennas might work for the Pioneer Police Precinct, but it doesn’t mean that similar zoning changes will
conform with conditions in ELPCO or other neighborhoods with dense, low-scale residential housing.
Second, the scope of the amendment is broad enough to allow Verizon or other wireless carriers to construct
antennas in multiple formats that are not in line with the local height limits and building conditions of
neighborhoods. The juxtaposition of a 75-foot antenna looming above a row of 30-foot rooflines is entirely
plausible under this amendment.
Third, we all know that “conditional use” actually means “this train has already left the station.” Conditional use
applications are not an efficient or truthful approach to zoning decisions. As a result, the wireless carriers
should collaborate with the SLC Planning Department to craft a new zoning code that provides clear,
unconditional height limits based on existing and adjacent zoning without the trapdoor of conditional use to
allow for unforeseen and harmful impacts.
Salt Lake City is facing wireless infrastructure development on multiple fronts. From the proliferation of 5G
monopoles to the demand for self-driving cars and better, faster wireless service, these complex pressures
require a broad, collaborative process to address wireless infrastructure in the city. This is what we called for
in our May 19 letter about the first proposal by Verizon:
“We would also like to see a broader coalition—beyond just wireless carriers—engaged in efforts to
address equity issues between wireline (i.e., wired Internet access) and wireless connectivity. We know
that many residents of ELPCO and other city neighborhoods rely on wireless networks for Internet access
in their homes. We also know this need has increased during the pandemic. But resolving this issue should
engage more actors than wireless carriers, including city agencies, local nonprofits, and the Salt Lake City
Schools. And real and lasting change must involve additional reforms beyond easing zoning and height
limits for cell towers.”
As a result, I request the SLC Planning Commission deny the Stealth Towers Text Amendment (PLNPCM2020-
00284) until it can be considered in context with all of the wireless infrastructure decisions within the city.
Sincerely,
Jason Stevenson
ELPCO, co-chair
1
Barlow, Aaron
From:Margo <becker.margo@gmail.com>
Sent:Monday, December 6, 2021 10:20 PM
To:Barlow, Aaron
Subject:(EXTERNAL) Oppose stealth towers
Hi.
Please add me to the list of those opposed to Verizon’s proposal for taller stealth towers on public lands.
Thanks!
Margo Becker
December 8, 2021
Dear Salt Lake Planning Commissioners:
I am writing to oppose the Stealth Towers Text Amendment (PLNPCM2020-00284) which you
will discuss tonight at your Commission meeting.
In May, when Verizon requested permitted uses to install 60-foot stealth towers in all zoning
across Salt Lake except residential zones, I sent an opposition letter to both the Planning
Commission and City Council. This was my argument: “The 60-foot height is unprecedented in
most low-density commercial zones like CN-Neighborhood Commercial and CB - Community
Business. If the Commission is a pushover for this 60-foot stealth monopole request, then surely
they will give Verizon carte blanche to build a 5G tower forest throughout Salt Lake City.”
Verizon withdrew that request but is back with another – a “conditional use” proposal to place
75-foot stealth (disguised) wireless towers in PL (Public Lands) zones –anywhere in the city.
I urge you to deny the request on these grounds:
1. Conditional use means Verizon has free reign to place their towers indiscriminately in PL
zones throughout the city. It’s the proverbial “keys to the car.” Once granted, Verizon
can pretty much do what they want, which is troubling. This will tie the city’s hands and
hold back residents from determining, or having a say in precisely how many, where and
when these towering behemoths will be placed.
2. Don’t buy the argument that PL zones are in non-descript corners of the city that are
hidden and that no one cares about. We have three PL zones in the beautiful, residential
neighborhood of Yalecrest -- Unitah Elementary School on 1300 South and 1500 East,
Bonneville Elementary School on 1900 East and Harvard Avenue, and the East High
School baseball park at the Southwest corner of Yalecrest on 900 South. Both schools
are surrounded on four sides by single-family homes. There is a neighborhood near the
ball park. We are opposed to 75-foot wireless towers in our beautiful neighborhood.
3. Property devaluation. Have you seen comparative photos of what a 75-foot tower looks
after construction? (See photos below) A 2014 survey by the National Institute for
Science, Law and Public Policy supported the idea that cell towers hurt interest in real
estate properties and value, according to the institute’s website. If you approve this,
you will have to justify your reasoning to 2,750+ homeowners in Yalecrest who live near
Unitah Elementary, Bonneville Elementary and the East High School baseball park.
4. These stealth towers are UGLY. (See pictures below) There is no way to “disguise” a 75-
foot-tall wireless tower and make it look beautiful. They pierce the horizon and scream
“I don’t fit in.”
5. Our understanding is if Verizon is granted conditional use, it opens the door for other
carriers to have the same privileges. There are at least four other major carriers – AT&T,
T-Mobile, US Cellular, and Sprint Nextel. Could we see a veritable forest of these 75-
foot towers? Please think carefully about the consequences.
We support the recommendation from our community council colleague Jason Stevenson, chair
of ELPCO: “Wireless carriers should collaborate with the SLC Planning Department to craft a
new zoning code that provides clear, unconditional height limits based on existing and adjacent
zoning without the trapdoor of conditional use to allow for harmful impacts.” We strongly urge
you to deny this conditional use request.
Respectfully,
Janet (Jan) Hemming
Chair
Yalecrest Neighborhood Council