RPVCCA_CC_SR_2015_04_07_G_Letters_Oppositon_to_Proposed_LA-RICS_MonopoleCITYOF
MEMORANDUM
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RANCHO PALOS
TO: HONORABLE MAYOR & CITY COUNCIL MEMBERS
FROM: CAROLYNN PETRO, AICP, DEPUTY CITY MANAGE
DATE: APRIL 7, 2015
SUBJECT: LETTERS IN OPPOSITION TO PROPOSED LA-RICS
MONOPOLE AT UPPER POINT VICENTE
REVIEWED BY: DOUG WILLMORE, CITY MANAGER 01A-0
Project Manager: Kit Fox, AICP, Senior Administrative Analyst
RECOMMENDATION
Authorize the Mayor to sign letters expressing the City's opposition to the proposed
monopole for the Los Angeles Regional Interoperable Communication System (LA -RIGS)
project on the U.S. Coast Guard property at Upper Point Vicente.
BACKGROUND
In March 2009, the City Council executed a Joint Powers Agreement (JPA) authorizing
the City's membership in the Los Angeles Regional Interoperable Communications
System (LA-RICS) Authority. LA-RICS was established to engage in a region -wide
cooperative effort to plan and establish a wide -area interoperable public safety
communications network. When commissioned, the system is intended to provide first
responders with the technology to communicate, in real time, to coordinate their response
during times of emergency. The system is expected to include a network of Land Mobile
Radio (LMR) sites (i.e., voice) and Public Safety Broadband Network -Long Term
Evolution (LTE) sites (i.e., data). The system assumes the need to install a 70 -foot -tall
monopole (or equivalent) or a 180 -foot -tall lattice tower (or equivalent) at each LTE and
LMR site. At present, LA-RICS has identified four (4) proposed antenna sites in the City
(i.e., Fire Station No. 83 in Miraleste Plaza for an LTE site, the County "antenna farm" on
Crestridge Road for both LTE and LMR sites, the FAA radar facility at the top of San
Pedro Hill for an LMR site, and the Coast Guard property at Upper Point Vicente for an
LMR site). Staff last reported to the City Council on LA-RICS in the Weekly Administrative
Report of April 1, 2015.
As the City Council may recall, the LA-RICS Board of Directors adopted a funding plan
for the system on May 28, 2014. With this action, LA-RICS initiated a 180 -day "opt out"
period during which participating jurisdictions could withdraw from the JPA without
financial obligation. The "opt out" period was originally set to end on November 24, 2014.
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MEMORANDUM: Opposition Letters for LA-RICS Monopole
April 7, 2015
Page 2
However, since both Staff and the Emergency Preparedness Committee had serious
reservations about the City's continued participation in LA-RICS, Staff presented a
resolution to the City Council on August 19, 2014 to consider withdrawing from the JPA.
At the last minute, LA-RICS agreed to a 1 -year extension of the "opt out" period (now set
to end on November 24, 2015) and waived of any financial obligation by participating
jurisdictions for FY 2014-15. Therefore, the City Council agreed to take "wait and see"
position on the City's continued participation in LA-RICS.
On March 11, 2015, LA -RIGS provide Staff with a status update on several components
of the project, including the following:
In late January 2015, the County issued the building permit for the LTE monopole
at Fire Station No. 83 (FS 83) in Miraleste Plaza. Since that time, there appears
to have been little visible evidence of construction. At the March 11th meeting,
Staff was advised that the FAA has "flagged" the building permit, and installation
of the monopole at FS 83 is on hold until this issue is resolved with the FAA. We
have asked LA-RICS to keep us apprised of any changes to the FS 83 installation
that may arise from the FAA's review.
• LA-RICS had previously proposed an LTE monopole at Fire Station No. 53 (FS 53)
on Palos Verdes Drive South, which would have required the City to issue a coastal
permit. At the March 11th meeting, LA-RICS advised Staff that FS 53 is no longer
included in the LA-RICS proposal for either LTE or LMR systems.
As mentioned above, LA-RICS also proposes to establish a countywide land
mobile radio (LMR) system for emergency voice communications. In September
2014, Staff submitted comments on the scope of the environmental impact report
(EIR) being prepared for the LMR system. The LMR system proposes three (3)
antenna sites in the City: the County "antenna farm" on Crestridge Road, the FAA
site at the top of San Pedro Hill and the Coast Guard property at Upper Point
Vicente (which is surrounded by City Hall and the nature preserve). LA-RICS Staff
has advised us that the County -owned Crestridge Road site has been determined
to be exempt from CEQA, and will proceed under County permits for both LMR
and LTE installations in advance of the completion of the EIR. The other two (2)
sites—which are both located on Federal property—are not expected to be exempt
from CEQA, and should be addressed in the Draft EIR. LA-RICS anticipates that
the Draft EIR could be released by late spring/early summer 2015. Staff intends
to review and comment upon the Draft EIR once it is released.
The Palos Verdes Peninsula News recently reported on the controversy that
LA -RIGS' proposed LTE/LMR monopole at Fire Station No. 56 (FS 56) in the City
of Rolling Hills has raised in that community. At its meeting of March 9, 2015, the
Rolling Hills City Council passed a resolution on a 3-2 vote, stating its opposition
to this proposed monopole. It should be noted, however, that Rolling Hills' position
with respect to FS 56 is similar to our position with respect to FS 83, which is
exempt from both our City's zoning and building regulations and CEQA because it
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MEMORANDUM: Opposition Letters for LA-RICS Monopole
April 7, 2015
Page 3
is County -owned property and covered by LA-RICS' temporary CEQA exemption
(granted by the State legislature in 2012).
Mayor Knight has expressed serious concerns about the LMR monopole proposed for the
Coast Guard property at Upper Point Vicente. As such, he has asked Staff to prepare
letters expressing the City's opposition to this specific proposal, to be addressed to the
Coast Guard, Federal and State resource agencies and other appropriate agencies and
legislators in advance of the release of the Draft EIR for the LA-RICS LMR system. Staff
has prepared a draft opposition letter for the City Council's consideration.
DISCUSSION
The draft opposition letter reiterates the points raised by Staff in our scoping comments
for the Draft EIR last September. The primary issues of concern to the City are the
incompatibility of a proposed monopole on this site with the sensitive habitat in the
surrounding Alta Vicente Reserve, and with significant historic resources both on-site (i.e.,
Battery 240 and the WWII -era bunker) and nearby (i.e., the Point Vicente lighthouse and
the Nike missile base). Staff believes that the presence of these biological and cultural
resources at or near the project site will make it very difficult (if not impossible) for LA-
RICS to successfully argue that the proposal at Upper Point Vicente would be exempt
from CEQA. However, even with the preparation of an EIR, the LA-RICS Board will have
the ability to consider adopting a "Statement of Overriding Considerations" in order to
approve any proposed installation that would have significant and unavoidable adverse
impacts upon the environment.
By expressing the City's concerns about the LA-RICS proposal at Upper Point Vicente
directly to other Federal and State agencies that may have a role in reviewing this
proposal, we are hopeful to bring pressure upon LA-RICS to drop this site from
consideration. Staff is still compiling and list of agencies and person to whom this letter
would be sent, but a particular list is expected to include the following:
• U.S. Coast Guard
• U.S. Fish & Wildlife Service
• California Department of Fish & Wildlife
• National Register of Historic Places
• California Office of Historic Preservation
• U.S. Congressman Ted Lieu
• State Senator Ben Allen
• State Assemblymember David Hadley
Staff would appreciate suggestions from the City Council for any additional recipients for
this letter.
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MEMORANDUM: Opposition Letters for LA-RICS Monopole
April 7, 2015
Page 4
CONCLUSION
In conclusion, Staff recommends that the City Council authorize the Mayor to sign letters
expressing the City's opposition to the proposed LA-RICS monopole on the U.S. Coast
Guard property at Upper Point Vicente.
ALTERNATIVES
In addition to the Staff recommendation, the following alternative actions are available for
the City Council's consideration:
Do not authorize the Mayor to sign opposition letters regarding the proposed LA-
RICS monopole on the U.S. Coast Guard property at Upper Point Vicente.
FISCAL IMPACT
There is no fiscal impact associated with authorizing the Mayor to sign letters opposing
the proposed LMR monopole at Upper Point Vicente. During our meeting with LA-RICS
on March 11th, it was noted that the LA-RICS Board would be considering another
alternative for the funding plan for the system, this one to be based upon the number of
"subscribers" (i.e., data units and radios) used in and/or by each participating jurisdiction
rather than the population and geographic area of participating jurisdictions. If this
change is approved by the LA-RICS Board, it remains unclear if this new formula will
come any closer to providing the City with a meaningful estimate of the full cost of its
participation in LA-RICS. The adoption of a revised funding plan may (or may not) result
in a further extension of the "opt out" period. Staff expects to return to the City Council
with a further update on the status of the LA-RICS funding plan sometime before
November 24, 2015 (i.e., the end of the current "opt out" period).
Attachments:
• Draft Opposition Letter for regarding LA-RICS monopole at Upper Point Vicente (Page 5)
MAMunicipal Services\Emergency Comm unications\LA-RICS\20150407_LA-RICSMonopoleOppositionLetters—Staff Rpt.docx
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April 7, 2015
[addressee]
[agency]
[street address]
[city, state & ZIP]
SUBJECT: Opposition to Proposed LA-RICS Monopole on U.S. Coast Guard
Property at Upper Point Vicente in Rancho Palos Verdes
Dear [addressee]:
As you may (or may not) be aware, the Los Angeles Regional Interoperable
Communications System (LA-RICS) authority is proposing to install a 70- to 180 -foot -tall
antenna structure (monopole or lattice tower) on U.S. Coast Guard property at Upper
Point Vicente in the City of Rancho Palos Verdes. The 4.50 -acre Coast Guard property
is surrounded by the City's Point Vicente Park/Civic Center property at 30940 Hawthorne
Boulevard. On behalf of the City Council and residents of Rancho Palos Verdes, I write
to express our deep concerns about LA-RICS' selection of this location for the installation
of an antenna tower, in hopes that you may be able to assist the City in eliminating it from
further consideration. Our specific objections include:
The proposed location for this antenna tower is a visually -prominent site
surrounded by the City's civic center and a portion of its nature preserve. There
also residential neighborhoods surrounding this site where ocean views would be
degraded by the addition of an antenna structure and related support equipment.
The addition of an antenna structure and related support equipment is also likely
to degrade the character of the open space areas surrounding this site. The City
believes that the construction and operation of the proposed antenna tower is likely
to have significant adverse impacts upon scenic vistas and the visual character of
the site and its surroundings.
As mentioned above, the proposed location for this antenna tower would be
surrounded by the Alta Vicente Reserve of the City's Palos Verdes Nature
Preserve. The nature reserve property is enrolled as a part of the City's Natural
Communities Conservation Plan (NCCP). The City believes that construction and
operation of the proposed antenna tower is likely to have significant adverse
impacts upon sensitive species and habitat, and that it may conflict with our NCCP.
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[addressee]
April 7, 2015
Page 2
The proposed antenna location would be on the site of an existing World War II -
era bunker and the remains of gun batteries at Point Vicente. The bunker and
batteries are associated with Fort MacArthur in San Pedro. Furthermore, the
surrounding civic center property is a former, Cold War -era Nike missile base,
which includes the intact missile silos. Finally, the site would be located within a
'h -mile radius of the Point Vicente Lighthouse, which is listed on the National
Register of Historic Places. The City believes that the construction and operation
of the proposed antenna tower is likely to cause a substantial adverse change in
the significance of a historical or archaeological resource, either on the project site
or nearby.
The City of Rancho Palos Verdes expects to continue to participate in the CEQA review
process for this proposed antenna site, including the submittal of comments on the Draft
EIR once it is released. We hopeful that LA-RICS will not attempt to circumvent the CEQA
process for this proposed location by seeking to apply the special, temporary CEQA
exemption granted to LA-RICS by the State legislature in 2012. It is clear to the City that
there are numerous "unusual circumstances" that apply to this site that would make the
application of a categorical exemption from CEQA completely indefensible.
I trust that that the City of Rancho Palos Verdes may rely upon your support to ensure
that LA-RICS' proposal for an antenna tower at Upper Point Vicente is never brought to
fruition. If you have any questions or need additional information, please feel free to
Senior Administrative Analyst Kit Fox in the City Manager's Office at (310) 544-5226 or
via e-mail at kitf@rpv.com.
Sincerely,
Jim Knight
Mayor
cc: Rancho Palos Verdes City Council
Doug Willmore, City Manager
Carolynn Petru, Deputy City Manager
Kit Fox, Senior Administrative Analyst
Pat Mallon, Executive Director, LA-RICS
Wendy Stallworth-Tait, Executive Assistant, LA-RICS
MAMunicipal Services\Emergency Communications\LA-RICS\20150407_LA-RICS_UPVOppositionLetter.docx
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