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CC SR 20201006 01 - Antenna Code Amendment PUBLIC HEARING Date: October 6, 2020 Subject: Consideration and possible action to amend Sections 17.76.020(C) (Noncommercial Amateur Radio Antennas) and (D) (Noncommercial Amateur Radio Antenna Permit) of Chapter 17.76 (Miscellaneous Permits and Standards) of Title 17 (Zoning) of the Rancho Palos Verdes Municipal Code (RPVMC) to update the regulations and review procedures for noncommercial amateur radio antennas (Case No. PLCA2020-0003). Recommendation: 1) Adopt Ordinance No. _____U, AN ORDINANCE OF THE CITY OF RANCHO PALOS VERDES AMENDING SECTIONS 17.76.020(C) (NONCOMMERCIAL AMATEUR RADIO ANTENNAS) AND (D) (NONCOMMERCIAL AMATEUR RADIO ANTENNA PERMIT) OF CHAPTER 17.76 (MISCELLANEOUS PERMITS AND STANDARDS) OF TITLE 17 (ZONING) OF THE RANCHO PALOS VERDES MUNICIPAL CODE AND DECLARING THE URGENCY THEREOF. 2) Introduce Ordinance No. __, AN ORDINANCE OF THE CITY OF RANCHO PALOS VERDES AMENDING SECTIONS 17.76.020(C) (NONCOMMERCIAL AMATEUR RADIO ANTENNAS) AND (D) (NONCOMMERCIAL AMATEUR RADIO ANTENNA PERMIT) OF CHAPTER 17.76 (MISCELLANEOUS PERMITS AND STANDARDS) OF TITLE 17 (ZONING) OF THE RANCHO PALOS VERDES MUNICIPAL CODE TO UPDATE THE REGULATIONS AND REVIEW PROCEDURE FOR NONCOMMERCIAL AMATEUR RADIO ANTENNAS. 1. Report of Notice Given: Deputy City Clerk 2. Declare Public Hearing Open: Mayor Cruikshank 3. Request for Staff Report: Mayor Cruikshank 4. Staff Report & Recommendation: Jaehee Yoon, Associate Planner 5. Council Questions of Staff (factual and without bias): 6. Testimony from members of the public: The normal time limit for each speaker is three (3) minutes. The Presiding Officer may grant additional time to a representative speaking for an entire group. The Mayor also may adjust the time limit for individual speakers depending upon the number of speakers who intend to speak. 7. Declare Hearing Closed/or Continue the Public Hearing to a later date: Mayor Cruikshank 8. Council Deliberation: The Council may ask staff to address questions raised by the testimony, or to clarify matters. Staff and/or Council may also answer questions posed by speakers during their testimony. The Council will then debate and/or make motions on the matter. 9. Council Action: The Council may: vote on the item; offer amendments or substitute motions to decide the matter; reopen the hearing for additional testimony; continue the matter to a later date for a decision. 01203.0005/665194.1 CITY COUNCIL MEETING DATE: 10/06/2020 AGENDA REPORT AGENDA HEADING: Public Hearing AGENDA TITLE: Consideration and possible action to amend Sections 17.76.020(C) (Noncommercial Amateur Radio Antennas) and (D) (Noncommercial Amateur Radio Antenna Permit) of Chapter 17.76 (Miscellaneous Permits and Standards) of Title 17 (Zoning) of the Rancho Palos Verdes Municipal Code (RPVMC) to update the regulations and review procedures for noncommercial amateur radio antennas (Case No. PLCA2020-0003). RECOMMENDED COUNCIL ACTION: (1) Adopt Ordinance No. _____U, AN ORDINANCE OF THE CITY OF RANCHO PALOS VERDES AMENDING SECTIONS 17.76.020(C) (NONCOMMERCIAL AMATEUR RADIO ANTENNAS) AND (D) (NONCOMMERCIAL AMATEUR RADIO ANTENNA PERMIT) OF CHAPTER 17.76 (MISCELLANEOUS PERMITS AND STANDARDS) OF TITLE 17 (ZONING) OF THE RANCHO PALOS VERDES MUNICIPAL CODE AND DECLARING THE URGENCY THEREOF. (2) Introduce Ordinance No. __, AN ORDINANCE OF THE CITY OF RANCHO PALOS VERDES AMENDING SECTIONS 17.76.020(C) (NONCOMMERCIAL AMATEUR RADIO ANTENNAS) AND (D) (NONCOMMERCIAL AMATEUR RADIO ANTENNA PERMIT) OF CHAPTER 17.76 (MISCELLANEOUS PERMITS AND STANDARDS) OF TITLE 17 (ZONING) OF THE RANCHO PALOS VERDES MUNICIPAL CODE TO UPDATE THE REGULATIONS AND REVIEW PROCEDURE FOR NONCOMMERCIAL AMATEUR RADIO ANTENNAS. FISCAL IMPACT: None Amount Budgeted: N/A Additional Appropriation: N/A Account Number(s): N/A ORIGINATED BY: Jaehee Yoon, Associate Planner REVIEWED BY: Ken Rukavina, P.E., Director of Community Development APPROVED BY: Ara Mihranian, AICP, City Manager ATTACHED SUPPORTING DOCUMENTS: A. Urgency Ordinance No.__U (page A-1) B. Ordinance No.__ (page B-1) C. Draft Ordinance with Strikeouts and Bold/Italics (page C-1) 1 D. Planning Commission Resolution No. 2020-14 (page D-1) E. Sections 17.76.020(C) & (D) of the RPVMC (page E-1) F. Public Comment (page F-1) To view the July 28, August 25, and September 22, 2020 Planning Commission staff reports, click on the following links: July 28 (includes March 4, and April 7, 2020 City Council staff reports): https://rpv.granicus.com/MetaViewer.php?view_id=5&clip_id=3706&meta_id=84912 August 25: https://rpv.granicus.com/MetaViewer.php?view_id=5&clip_id=3717&meta_id=85801 September 22: https://rpv.granicus.com/MetaViewer.php?view_id=5&event_id=1839&meta_id=86584 BACKGROUND: Section 17.76.020 (Antennas) of the Rancho Palos Verdes Municipal Code (RPVMC) regulates the placement of commercial and noncommercial antennas on private property within the City. Commercial antennas are those that are used for the transmission or reception of radio, television, and commun ication signals for commercial purposes. Noncommercial amateur radio antennas are radio operations, as defined by the Federal Communications Commission (FCC), where there is no transmission or propagation on a commercial frequency and where there is no transmission for hire or for material compensation. On April 11, 1983, Ordinance No. 166 was adopted to establish the City’s first antenna ordinance to regulate the development, design, and location of commercial antennas. On April 5, 1988, Ordinance No. 226 was adopted to amend the relevant code section to incorporate additional regulations consistent with the FCC and to ensure satellite dish antennas are installed in a manner minimizing visual impacts. On March 22, 1999, Ordinance No. 345 was adopted t o amend RPVMC Section 17.76.020 and Chapter 17.96 (Definitions) to update the development standards and regulations for commercial antennas and to include provisions for regulating noncommercial amateur radio antennas, both of which have since served as th e regulatory framework in reviewing antenna applications to date. On March 11, 2002, Urgency Ordinance No. 374U was adopted to amend RPVMC Section 17.76.020(C)(3)(c)(ii) to update the regulations of building-mounted noncommercial amateur radio antennas and support structures which can be erected without a permit from the City. On November 15, 2011, Ordinance No. 529 was adopted to amend RPVMC Section 2 17.76.020(A)(11) to add two new requirements for commercial antenna applications, including the submittal of photographic simulations and the installation of mock-ups. On March 4, 2020, the City Council adopted Urgency Ordinance No. 632U, which imposed a temporary, 45-day moratorium on the establishment, expansion, or modification of noncommercial amateur radio antennas associated with RPVMC Sections 17.76.020(C) (Noncommercial amateur radio antennas) and (D) (Noncommercial amateur radio antenna permit). In addition, the City Council initiated code amendment proceedings to amend the aforementioned RPVMC sections to update the regulations and review procedures for noncommercial amateur radio antennas. As amendments were proposed to Title 17 (Zoning), the process required that the Planning Commission review the proposed code language and forward a recommendation to the City Council for its consideration. On April 7, 2020, the City Council adopted Urgency Ordinance No. 634U, extending the moratorium period enacted by interim Urgency Ordinance No. 632U by an additional 10 months and 15 days to allow Staff adequate time to research and prepare code amendment proceedings to amend the aforementioned code sections. This urgency ordinance expires on March 3, 2021. Since then, Staff worked with the Planning Commission’s Zoning Code Update Subcommittee (Commissioners Hamill, Chura, and Saadatnejadi) and the City Attorney’s Office to develop a working draft of the proposed c ode amendment. The primary focus of the draft language considered updating the existing regulations to ensure that proposed noncommercial amateur radio antennas are aesthetically compatible with surrounding uses, and that antennas and associated structures will not adversely alter the visual character of the surrounding areas. After considering all testimony at duly-noticed public hearings on July 28, August 25, and September 22, 2020, the Planning Commission adopted P.C. Resolution No. 2020-14 (Attachment D), recommending that the City Council adopt an ordinance amending Sections 17.76.020(C) (Noncommercial amateur radio antennas) and (D) (Noncommercial amateur radio antenna permit) of Chapter 17.76 (Miscellaneous Permits and Standards) of Title 17 (Zoning) of the RPVMC to update the regulations and review procedures for noncommercial amateur radio antennas. It should be noted that during the September 22 Planning Commission meeting, the Planning Commission revised the draft ordinance and recommends adoption thereof, which maintains the Director’s authority to review proposed antennas above 16 feet in height up to a maximum height of 41 feet, and continuing the Planning Commission’s review of antennas above 41 feet in height. This took into consideration the burden of cost associated with the application fee and submittal requirements in comparison to costs related to purchasing and installing the antenna assembly itself. In addition, the Planning Commission added a new provision to the draft ordinance, which restricted the transferability of noncommercial amateur radio antenna permits in that the entitlement will be nontransferable upon sale or transfer of the property on which the antenna was permitted. 3 DISCUSSION: Summary of Proposed Code Amendments Chapter 17.76 (Miscellaneous Permits and Standards) of the RPVMC includes several permit and development standards for specific applications that can be applied to various zoning districts. The provisions within Chapter 17.76 include, but are not limited to, regulations related to parking lots, grading, fence/wall/hedges, signs, extreme slopes, and antennas. Sections 17.76.020(C) and (D) of the RPVMC regulate the placement of noncommercial amateur radio antennas on private property within the City. The proposed code amendment includes new provisions related to visual impacts, application requirements, and the application review process. A clean version of the Planning Commission-recommended draft ordinance (with no track changes) has been attached to this report (Attachment B) with a strikethrough version with track changes (Attachment C). The Planning Commission-recommended code amendments are summarized in italics below, followed by a discussion of each recommended amendment. 1. Clarify existing regulations and add additional provisions for noncommercial amateur radio antennas (Section 17.76.020(C)(2)) The existing code includes general regulations for noncommercial amateur radio antennas such as height measurements and prohibited use of commercial frequency. The proposed code amendment rephrases legal nonconforming antennas, supplements existing code provisions, and introduces additional regulations for noncommercial amateur radio antennas, which focus on placement and design. With respect to placement, noncommercial amateur radio antennas will be required to comply with the City’s View Ordinance and setbacks, while the design requirements will regulate the structure type, signage, aesthetics, and retracting of antennas when not in use to minimize visual impacts. 2. Expand application requirements and findings for noncommercial amateur radio antennas (Section 17.76.020(C)(4) & (D)(1)&(3)) The current noncommercial amateur radio antenna application requires submittal of plans, mailing labels, and a fee. The code amendment proposes to enhance application requirements that would include an expansion of public notice requirements from adjacent property owners to a 500-foot radius from the project site, and documentation that demonstrates and certifies that the proposed antenna will comply with all FCC regulations related to radio frequency emissions and interference. In addition, the applicant will be required to either construct a temporary silhouette or provide photo simulations of the proposed project, in lieu of a mock-up to serve as a visual aid for staff and the public to further assess antenna impacts. In considering the merits of a noncommercial amateur radio antenna, the code currently requires the Director or the Planning Commission to consider findings that involve 4 safety, building code requirements, and view impacts. In terms of additional findings proposed in the draft ordinance, specific language has been included to find that the antenna has been designed and situated in such a manner so as to minimize visual impacts to the greatest extent practicable, while accommodating an operable antenna on the project site. 3. Allow flexibility for noncommercial amateur radio antennas that meet state and federal law (17.76.020(E)) Staff researched noncommercial amateur radio antenna regulations in other Peninsula cities, as well as the City of Malibu. Based on this research, Staff found that the proposed code amendment will result in more restrictive regulations than these cities, if adopted, in terms of the application requirements and review procedures. Due to the many variables that the City must consider when reviewing an application and applying the regulations of the proposed amendment, a new provision has b een added to ensure that the City will enforce Sections 17.76.020(C) and (D) of the RPVMC only to the extent that it does not violate applicable federal and state laws. By doing so, the City intends to reasonably balance the needs of an applicant seeking a permit to install an operable noncommercial amateur radio antenna while also protecting the general public health, safety, and welfare as well as upholding the goals and policies of the City’s General Plan. In summary, the proposed code amendments are not intended as a comprehensive overhaul of the existing noncommercial radio antenna section of the code (Attachment E), but rather to supplement existing language with additional procedural and application requirements that consider visual impacts of noncommercial amateur radio antennas. Urgency Ordinance Government Code Section 36937 states that an urgency ordinance becomes effective immediately if the City Council finds, by a four-fifths vote, that an urgency ordinance is needed for the immediate preservation of the public peace, health, or safety, and contains a declaration of the facts constituting the urgency. The urgency of the ordinance is to preclude a current and immediate threat to public safety, health, and welfare posed by an existing moratorium on issuing permits or other entitlements for noncommercial amateur radio antennas associated with Sections 17.76.020(C) and (D) of the RPVMC. Specifically, the noncommercial antenna ordinance has not been updated since 2002 to address the City’s concerns including, but not limited to, visual impacts and inconsistencies with the City’s General Plan. As such, lifting the moratorium on noncommercial amateur radio antennas in a timely manner is necessary if the City Council finds that the proposed draft ordinance meets the goals and objectives of the City as initiated at its March 4 meeting. It is recognized that noncommercial amateur radio antennas can be a means for emergency communications, and therefore, have the potential to provide a valuable communication tool to the City and the general public. Hence, an urgency ordinance (Attachment A) to immediately adopt the proposed code amendments related to noncommercial amateur 5 radio antennas is warranted given the long time lapse since the last update to the ordinance and the current COVID-19 pandemic. General Plan and Coastal Specific Plan Consistency Based on the discussion above, Staff and the Planning Commission determined that the proposed code amendments are consistent with the City’s General Plan and Coastal Specific Plan in that it upholds, and does not hinder, the goals and policies of those plans. Specifically, the proposed amendment will not impact public access to the coa st nor obstruct the use of the public paths and trails as development of noncommercial amateur radio antennas will occur on private property. In addition, compatibility measures and provisions encouraging the minimization of the visual impacts associated with noncommercial amateur radio antennas are being proposed as part of the amendment. ADDITIONAL INFORMATION: Public Notice On September 20 and 24, 2020, a public notice was published in the Daily Breeze and the Palos Verdes Peninsula News, respectively, providing notification of the City Council’s consideration of proposed amendments to the non-commercial amateur radio antenna ordinance at its October 6, 2020, meeting. It should be noted that the public notice inadvertently omitted any reference to an urgency ordinance which does not require public notification. As of the date that this report was completed, Staff has received one correspondence in response to the public notice (Attachment F). The email comment raised questions on the difference between a Director and a Planning Commission review application other than the height threshold , applying setback requirements for exempt antennas and using “antenna assembly” instead of “antenna” in the ordinance; and additional requirements for photo simulations. As discussions with the City Attorney’s office is necessary to address the public comment adequately, no responses have yet been provided. However, Staff will consider the comments and reach out to the interested party as soon as it becomes available. Environmental Assessment Pursuant to the provisions of the California Environmental Quality Act, Public Resources Code Sections 2100 et. seq. (CEQA), the State’s CEQA Guidelines, California Code of Regulations, Title 14, Section 150000 et. seq., the City’s Local CEQA Guidelines, and Government Code §65962.5(f) (Hazardous Waste and Substances Statement), it has been determined that the proposed urgency ordinance is exempt from CEQA because: (a) This ordinance is not a project within the meaning of CEQA Section 15378 because it has no potential for resulting in physical change to the environment, either directly or indirectly; (b) This ordinance is also exempt pursuant to CEQA Section 15061(b)(3) since the proposed ordinance involves an urgency ordinance adopting code amendments that do not have the potential to significantly impact the environment; and , 6 (c) This ordinance is an administrative procedure related to uses, facilities, and regulations identified in the RPVMC and General Plan, and given that the proposed ordinance is not related to a specific project, the ordinance: (i) by virtue of the location of affected improvements, will not impact a sensitive environmental resource of hazardous or critical concern; (ii) will not have a cumulative impact on the environment through successive projects of the same type, in the same place, over time; (iii) does not have any unusual circumstances that will have a significant effect on the environment; (iv) does not impact a scenic highway; (v) is not located on a hazardous waste site; and, (vi) will not adversely impact a historical resource. Furthermore, the proposed code amendments to Sections 17.76.020(C) and (D) of the RPVMC are exempt from CEQA pursuant to Section 15061(b)(3) because they consist only of minor revisions and clarifications to an existing zoning code and will not have the effect of deleting or substantially changing any regulatory standards or findings. The proposed amendments do not have the potential to cause significant effects on the environment, but rather will supplement the regulations and review procedures established in the City’s Municipal Code that do not have the potential to cause significant effects on the environment. Therefore, adoption of this ordinance is also not subject to CEQA. ALTERNATIVES: In addition to the Staff recommendation, the following alternative actions are available for the City Council’s consideration: 1. Do not adopt the urgency ordinance and only introduce on first reading the ordinance for proposed code amendments to RPVMC Sections 17.76.020(C) (Noncommercial Amateur Radio Antennas) and (D) (Noncommercial Amateur Radio Antenna Permit). 2. Provide Staff with further input to consider in the draft ordinance for reintroduction at a future meeting. 3. Take no action at this time. 7 ORDINANCE NO. ____U AN ORDINANCE OF THE CITY OF RANCHO PALOS VERDES AMENDING SECTIONS 17.76.020(C) (NONCOMMERCIAL AMATEUR RADIO ANTENNAS) AND (D) (NONCOMMERCIAL AMATEUR RADIO ANTENNA PERMIT) OF CHAPTER 17.76 (MISCELLANEOUS PERMITS AND STANDARDS) OF TITLE 17 (ZONING) OF THE RANCHO PALOS VERDES MUNICIPAL CODE AND DECLARING THE URGENCY THEREOF WHEREAS, Section 17.76.020 (Antennas) of the Rancho Palos Verdes Municipal Code (RPVMC) regulates the placement of commercial and noncommercial ant ennas within the City. Commercial antennas are those that are used for the transmission or reception of radio, television, and communication signals for commercial purposes, and noncommercial amateur radio antennas are radio operations, as defined by the Federal Communication Commission (FCC), where there is no transmission or propagation on a commercial frequency and where there is no transmission for hire or for material compensation; and WHEREAS, on April 11, 1983, Ordinance No. 166 was adopted to establish the City’s first antenna ordinance, codified as Chapter 17.41 of the RPVMC, to regulate the development, design, and location of commercial antennas; and WHEREAS, on March 22, 1999, Ordinance No. 345 amended Section 17.76.020 of the RPVMC to include provisions for regulating noncommercial amateur radio antennas; and WHEREAS, on March 11, 2002, Urgency Ordinance No. 374U was adopted to amend Section 17.76.020(C)(3)(c)(ii) to update the regulations of building-mounted noncommercial amateur radio antennas and support structures which can be erected without a permit from the City; and WHEREAS, on March 4, 2020, the City Council adopted Urgency Ordinance No. 632U, which imposed a temporary 45-day moratorium on the establishment, expansion, or modification of noncommercial amateur radio antennas associated with Sections 17.76.020(C) and (D) in order to review, research, and initiate code amendments to the aforementioned sections to update the regulations and review procedures for noncommercial amateur radio antennas so as to be compatible with the neighborhoods where they are erected; and WHEREAS, on April 7, 2020, the City Council adopted Urgency Ordinance No. 634U, to extend the moratorium period enacted by interim urgency ordinance No. 632U by an additional 10 months and 15 days, to allow Staff adequate time to research and prepare code amendment proceedings; and A-1 WHEREAS, Government Code Section 36937 expressly authorizes the City Council to adopt an urgency ordinance for the immediate preservation of the public peace, health, or safety, if the ordinance is approved by four-fifths of the City Council. To this end, this urgency ordinance is adopted for the immediate preservation of the public peace, health, and safety, given the long time lapse since the last update to the noncommercial antenna ordinance and the current COVID-19 pandemic in which noncommercial amateur radio antennas have the potential to provide a valuable emergency communication tool to the City and the general public; and WHEREAS, pursuant to the provisions of the California Environmental Quality Act, Public Resources Code Sections 2100 et. seq. (“CEQA”), the State’s CEQA Guidelines, California Code of Regulations, Title 14, §15000 et. seq., the City’s Local CEQA Guidelines, and Government Code Section 65962.5(f) (Hazardous Waste and Substances Statement), it has been determined that the proposed urgency ordinance is exempt from CEQA because (a) this ordinance is not a project within the meaning of CEQA §15378 because it has no potential for resulting in physical change to the environment, either directly or indirectly; (b) this ordinance is also exempt pursuant to CEQA §15061(b)(3) since the proposed ordinance involves an urgency ordinance adopting code amendments that do not have the potential to significantly impact the environment; and (c) as the ordinance is an administrative procedure related to uses, facilities, and regulations identified in the RPVMC and General Plan, and given that the proposed ordinance is not related to a specific project, the ordinance (i) by virtue of the location of affected improvements, will not impact a sensitive environmental resource of hazardous or critical concern; (ii) will not have a cumulative impact on the environment through successive projects of the same type, in the same place, over time; (iii) does not have any unusual circumstances that will have a significant effect on the environment; (iv) does not impact a scenic highway; (v) is not located on a hazardous waste site; and (vi) will not adversely impact a historical resource; and WHEREAS, all legal prerequisites to the adoption of the urgency ordinance have occurred. NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF RANCHO PALOS VERDES, CALIFORNIA, DOES ORDAIN AS FOLLOWS: Section 1. Authority and Effect A. The State Planning and Zoning Law, Government Code Section 65000 et seq., broadly empowers the City to plan for and regulate the use of land in order to provide for orderly development, the public safety, health, and welfare, and a balancing of property rights and the desires of the community and how its citizens envisions their city. Section 2. Findings The City Council of the City of Rancho Palos Verdes hereby finds, determines, and declares that: A-2 A. Subsections (C) (Noncommercial amateur radio antennas) and (D) (Noncommercial amateur radio antenna permit) of 17.76.020 (Antennas) of the RPVMC governs the use and permitting of noncommercial amateur radio antennas on private property. These provisions were adopted in 1999 pursuant to Ordinance No. 345, and since have not been comprehensively reviewed for updates until a moratorium was imposed pursuant to Urgency Ordinance No. 374U, in order to address potential impacts associated with noncommercial amateur radio antennas in the City’s residential zoning districts. C. The City Council recognizes that the City must reasonably accommodate amateur communications and enact the “minimum practicable regulation to accomplish the state or local authority's legitimate purpose,” 47 C.F.R. Section 97.15(b), and that the City can zone for height, safety, and aesthetics concerns, but its restrictions must not be overly restrictive. D. The City Council finds that the proposed draft ordinance amending Sections 17.76.020(C) and (D) of the RPVMC meets the goals and objectives of the City as initiated at its March 4th meeting, in that visual impacts, compatibility with the surrounding uses, compliance with FCC regulations, and consistency with the City’s General Plan have been taken into consideration. E. The City Council wishes to immediately adopt the proposed code amendment in Exhibit “A” attached hereto, and thereby lift the moratorium on the establishment, expansion, or modification of any amateur radio antenna s within the City as noncommercial amateur radio antennas have become a means for emergency communication under the current COVID-19 pandemic, in which the updated regulations should be implemented in a timely manner. Section 3. Urgency Measure The City Council finds that there is a current and immediate threat to public safety, health, and welfare posed by the existing noncommercial antenna regulations, in that the ordinance has not been updated for nearly two decades, and hence, is necessary for the City to immediately adopt the proposed draft ordinance. In addition, noncommercial amateur radio antennas are a valuable communication tool to the City and the general public in times of emergency. The moratorium imposed on noncommercial amateur radio antennas pursuant to Urgency Ordinance No. 374U is no longer necessary if the proposed draft ordinance is adopted, which allows processing applications related to Sections 17.76.020(C) and (D) of the RPVMC without further delay . Section 4. Severability The City Council hereby declares, if any provision, section, subsection, paragraph, sentence, phrase or word of this ordinance is rendered or declared invalid or unconstitutional by any final action in a court of competent jurisdiction or by reason of any A-3 preemptive legislation, then the City Council would have independently adopted the remaining provisions, sections, subsections, paragraphs, sentences, phrases or words of this ordinance and as such they shall remain in full force and effect. Section 5. Publication The City Clerk shall certify as to the passage and adoption of this urgency ordinance and shall cause the same to be published in a manner prescribed by law. Section 6. Effectiveness of Ordinance This Ordinance shall take effect immediately, p ursuant to the authority conferred upon the City Council by Government Code Section 36937. PASSED, APPROVED and ADOPTED this __ day of _____ 2020, by a four-fifths vote of the entire City Council. ________________________________ John Cruikshank, Mayor ATTEST: _______________________________ Emily Colborn, City Clerk STATE OF CALIFORNIA ) COUNTY OF LOS ANGELES ) ss CITY OF RANCHO PALOS VERDES ) I, Emily Colborn, City Clerk of the City of Rancho Palos Verdes, do hereby certify that the whole numbers of the City Council of said City is five; that the foregoing Ordinance No. ___U was duly and regularly adopted by the City Council of said City at a regular meeting thereof held on _________, 2020, by the following vote: AYES: NOES: ABSENT: ABSTAINED: __________________________ Emily Colborn, City Clerk A-4 ORDINANCE NO. AN ORDINANCE OF THE CITY OF RANCHO PALOS VERDES AMENDING SECTIONS 17.76.020(C) (NONCOMMERCIAL AMATEUR RADIO ANTENNAS) AND (D) (NONCOMMERCIAL AMATEUR RADIO ANTENNA PERMIT) OF CHAPTER 17.76 (MISCELLANEOUS PERMITS AND STANDARDS) OF TITLE 17 (ZONING) OF THE RANCHO PALOS VERDES MUNICIPAL CODE TO UPDATE THE REGULATIONS AND REVIEW PROCEDURE FOR NONCOMMERCIAL AMATEUR RADIO ANTENNAS WHEREAS, the City regulates the installation of noncommercial amateur radio antennas pursuant to Sections 17.76.020(C) and (D) of the Rancho Palos Verdes Municipal Code (RPVMC); and WHEREAS, the City desires to update Sections 17.76.020(C) and (D) to ensure antenna structures are aesthetically compatible with surrounding uses that will not adversely alter the visual character of the surrounding area, and are consistent with the goals and policies of the City’s General Plan; and WHEREAS, Government Code Section 36937 expressly authorizes the City Council to adopt an urgency ordinance for the immediate preservation of the public peace, health, or safety, if the ordinance is approved by four-fifths of the City Council; and WHEREAS, on March 4, 2020, the City Council adopted Urgency Ordinance No. 632U, which imposed a temporary 45-day moratorium on the establishment, expansion, or modification of noncommercial amateur radio antennas associated with Sections 17.76.020(C) and (D) in order to review, research, and initiate code amendments to the aforementioned sections to update the regula tions and review procedures for noncommercial amateur radio antennas so as to be compatible with the neighborhoods where they are erected; and WHEREAS, on April 7, 2020, the City Council adopted Urgency Ordinance No. 634U, to extend the moratorium period enacted by interim Urgency Ordinance No. 632U by an additional 10 months and 15 days, to allow Staff adequate time to research and prepare code amendment proceedings; and WHEREAS, on July 28, 2020, the Planning Commission held a duly-noticed public hearing, at which time the draft ordinance was reviewed and discussed among the Planning Commission, Staff, and interested parties. The item was continued to August 25, 2020, and subsequently to September 22, 2020, to allow Staff additional time to incorporate the input received and reach out to interested parties for comments on the revised draft ordinance; and B-1 WHEREAS, on September 20 and 24, 2020, a public notice was published in the Daily Breeze and the Palos Verdes Peninsula News, respectively, providing a notice of a public hearing before the City Council on October 6, 2020; and WHEREAS, on September 22, 2020, the Planning Commission held a duly-noticed public hearing, and adopted P.C. Resolution No. 2020-14, recommending that the City Council adopt this Ordinance; and WHEREAS, on October 6, 2020, the City Council conducted a duly noticed public hearing on this Ordinance, and all testimony was received was made a part of the public record; and WHEREAS, the City Council has duly considered all information presented to it, including the Planning Commission findings, P.C. Resolution No. 2020-14, written staff reports, and any testimony provided at the public hearing; and WHEREAS, the City’s standards constitute “the minimum practicable regulations” to accomplish the City’s legitimate purpose and will “reasonably accommodate amateur radio service communications and allow those structures to be erected at heights and dimensions sufficient to accommodate amateur radio service communication per California Government Code Section 65850.3 and Section 97.15 of the Title 47 of the Code of Federal Regulations; and WHEREAS, all legal prerequisites to the adoption of the Ordinance have been met. NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF RANCHO PALOS VERDES DOES ORDAIN AS FOLLOWS: Section 1. The City Council of the City of Rancho Palos Verdes hereby makes the following findings: A. The above recitals are true and correct and incorporated fully herein by reference. B. It is the intent and purpose of this Ordinance that Sections 17.76.020(C) (Noncommercial Amateur Radio Antennas) and (D) (Noncommercial Amateur Radio Antenna Permit) of Chapter 17.76 (Miscellaneous Permits and Standards) of Title 17 (Zoning) of the RPVMC be amended to update the development standards for noncommercial amateur radio antennas. Section 2. The proposed code amendment to Title 17 adopted he rein is consistent with the Rancho Palos Verdes General Plan and Coastal Specific Plan in that it uph olds, and does not hinder, the goals and policies of those plans. Section 3. Sections 17.76.020(C) (Noncommercial Amateur Radio Antennas) and (D) (Noncommercial Amateur Radio Antenna Permit) of Chapter 17.76 (Miscellaneous Permits and Standards) of Title 17 (Zoning) of the RPVMC is hereby amended as follows: B-2 “17.76.020 – Antennas. … C. Noncommercial Amateur Radio Antennas. 1. Applicability. This subsection C regulates noncommercial amateur radio antennas that are affixed to real property and antennas that are located on vehicles parked on lots which exceed sixteen feet in height, as measured pursuant to the residential building height measurement methods described in Section 17.02.040 (View preservation and restoration) of this title. This subsection does not regulate hand held antennas or antennas located on vehicles parked on lots which are sixteen feet or less in height, as measured pursuant to the residential building height measurement methods described in Section 17.02.040 (View preservation and restoration) of this title. 2. General Regulations. The installation, erection and/or replacement of noncommercial amateur radio antenna assemblies on lots for noncommercial purposes shall be reviewed by the Director through either an antenna Site Plan Review application or by the Planning Commission through a noncommercial amateur radio antenna permit application. a. Antenna assemblies which meet the following criteria shall be considered legal nonconforming: i) legally permitted by the City or the County prior to City incorporation, and which conform to the codes in effect when installed, but do not meet the provisions of this code; and are ii) existing as of the effective date of this code. b. Antenna assembly height shall be measured as follows: i. The height of the antenna assembly shall include the antenna(s) support structure and shall be the maximum to which it is capable of being extended; ii. For a ground mounted assembly or one mounted on an accessory structure, the height shall be measured from the highest point of the existing grade covered by the foundation of the structure to the maximum height to which the antenna assembly is capable of being extended; and iii. Except for exempt antennas described in subsection (C)(3)(c)(ii) of this Section, for an antenna assembly mounted on a main building or an accessory structure, height shall be measured from existing grade to the maximum height to which the antenna assembly is capable of being extended, pursuant to the residential building height measurement methods described in Section 17.02.040 (View preservation and restoration) of this title. B-3 c. Noncommercial amateur radio antennas shall not be located within any front yard area, without approval of a variance pursuant to Chapter 17.64 (Variances) of this title. d. The use of antennas for noncommercial purposes shall mean that no commercial frequency is used for transmission or propagation, that there is no communication for hire or for material compensation, except as allowed by Federal Communications Commission (FCC) regulations, and that all applicable regulations are complied with at all times, including, without limitation, FCC regulation 97. e. A noncommercial amateur radio antenna assembly shall not include oil derrick style structures and no structures with guy wires shall be used or constructed, except as provided for in this Section. f. No signage shall be allowed on any noncommercial amateur radio antenna assembly, except for requisite safety text and other labeling required by law. g. A noncommercial amateur radio antenna assembly shall comply with all City, State and Federal laws including the City’s view preservation requirements in Section 17.02.040. h. A noncommercial antenna assembly subject to this Section shall not be any closer to the property line than the required minimum side and rear yard setbacks for the subject lot without written City approval which shall take into consideration the site specific conditions. i. All antennas capable of being retracted and extended shall be retracted to its minimum size and height when not in use or retracted as required in any conditions of approval issued by the City . j. Each noncommercial amateur radio antenna shall be of a color or painted to minimize its reflectivity and blend with its surroundings as much as possible. k. Upon the sale or transfer of the subject property any permit issued under this section shall not be transferable to any other person including a new property owner. 3. Antennas Exempt. The following noncommercial amateur radio antenna assemblies may be constructed or installed on a lot without the approval of an antenna Site Plan Review application or noncommercial radio antenna permit; a. The replacement of an existing antenna or antenna support structure with an outside diameter of three inches or less with a similar B-4 antenna or support structure. b. Parabolic dish antennas which are one meter (39.37 inches) or less in diameter. This exemption shall not apply to parabolic dishes located on a mast which is greater than twelve feet in height. Freestanding masts shall be measured from existing adjacent grade. Masts located on a building shall be measured from the point where the mast meets the roof surface. c. Any combination of two different antenna assemblies from the following categories: i. One antenna assembly which is located outside of any required setback areas and which is sixteen feet or less in height, as measured pursuant to the residential building height measurement methods described in Section 17.02.040 (View preservation and restoration) of this title. ii. One building mounted antenna assembly, located outside of any required setback areas, which does not exceed twelve feet in height, as measured from the point where the antenna assembly meets the roof surface, and which contains radiating elements, each of which does not exceed six feet in total length. If the antenna assembly is mounted onto the roof, or if any portion of the antenna assembly projects above the roofline, not more than one antenna may be affixed to antenna support structure. iii. One wire antenna assembly consisting of a single flexible wire, with a diameter not to exceed one-half inch, suspended between two supports, which if man-made do not exceed forty-one feet in height as measured from adjacent existing grade, and located outside of any required setback areas. iv. One vertical antenna assembly, located outside of any required setback areas, consisting of a single pole or mast with a maximum outside diameter of three inches or less with no guys or horizontal elements located higher than two feet above the ridgeline of the residence, and which does not exceed forty-one feet in total height, as measured from adjacent existing grade. 4. Antenna Site Plan Review Approval. a. Director review. Director approval of an antenna Site Plan Review application is required for more than two antenna assemblies which are exempt pursuant to subsection (C)(3) of this Section, and for any other nonexempt antenna assembly which does not exceed forty-one feet in height. The application may be approved provided the Director finds as follows: B-5 i. That adequate provision is made for safety; ii. That all applicable building code requirements, such as wind load and seismic design criteria, and development code requirements, such setbacks, are met; iii. That no more than one nonexempt antenna support structure will be located on the lot; iv. That the placement of the antenna assembly does not significantly impair a view from any surrounding properties, as defined in Section 17.02.040 (View preservation and restoration) of this title; and, v. That the antenna assembly shall be designed to minimize the visual impact to the greatest extent feasible by means of placement, screening, camouflaging, painting and texturing and to be compatible with existing architectural elements, building materials and other site characteristics. The applicant shall use th e smallest and least visible antennas possible to accomplish the coverage objectives. b. Application. The antenna Site Plan Review application shall be made upon forms provided by the City and shall be accompanied by the following: i. Two copies of a scaled site plan showing the location of the antenna assembly, and its relation to property lines, topography and all structures on the property, and two copies of an elevation drawing showing the proposed height, size, vertical and horizontal components, dimensions, color and material of the antenna(s) and antenna support structure. If a building permit is required pursuant to the California Building Code, three copies of the above plans are necessary; ii. A typed mailing list of all property owners within a five hundred-foot radius to the subject property, using the last equalized tax roll of the county assessor and any affected homeowners associations, and a vicinity map identifying all properties included on the mailing list. iii. A fee, as established by resolution of the City Council. iv. Documentation demonstrating that the antenna assembly will comply with all other FCC standards related to radio frequency emissions in OET Bulletin 65, Supplement B. Said B-6 documentation shall state if the antenna is categorically exempt or demonstrate compliance with the standards of OET Bulletin 65. v. The applicant shall certify that the proposed antennas and installation, comply with FCC regulations related to interference and in the event the interference occurs, the applicant will take all steps necessary to resolve the same. vi. The applicant shall, as part of the application, construct at the applicant's expense, a mock-up of the proposed antenna at the proposed location. Said mock up shall be the same size and dimensions as the proposed antenna. The mock-up shall be coordinated under the direction of the Director or his/her designee. Once constructed, the silhouette shall be certified by a licensed engineer on a form provided by the City. In the alternative, the applicant may submit a photo simulation depicting the proposed antenna in size, height and dimensions, as required by the City to depict the proposed antenna as it would appear from the surrounding area. c. Notice. Upon receipt of a complete antenna Site Plan Review application, the Director shall provide written notice of the application to the applicant, property owners within a five hundred-foot radius, any affected homeowners associations and any interested parties. No sooner than fifteen days after the application notices are mailed, the Director shall make a decision on the application. Notice of the Director's decision shall be provided to the applicant, adjacent property owners, any affected homeowners associations, and any interested parties. The Director's decision may be appealed to the Planning Commission and the Planning Commission's decision may be appealed to the City Council pursuant to Chapter 17.80 (Hearing Notice and Appeal Procedures) of this title. D. Noncommercial Amateur Radio Antenna Permit. Except for antenna assemblies which are exempt pursuant to subsection (C)(3) of this Section, antenna assemblies which exceed forty-one feet in height or which involve the placement of more than one nonexempt antenna support structure on a lot shall require the approval of a noncommercial amateur radio antenna permit by the Planning Commission. 1. Application. Application for a noncommercial amateur radio antenna permit shall be made on forms provided by the City and shall include such plans and documents as may reasonably be required by the Director , including submittal requirements for the antenna Site Plan Review application in subsection (4)(b), for a complete understanding of the proposal and a filing fee in an amount established by resolution of the City Council. 2. Notice. Upon receipt of a complete application for a noncommercial B-7 amateur radio antenna permit, the Director shall provide written notice of the application to all owners of a property shown on the last known county assessor tax roll and homeowner associations located within a radius of five hundred feet of the external boundaries of the property where the antenna assembly is proposed. 3. Action by Planning Commission. In granting a noncommercial amateur radio antenna permit, the Planning Commission shall consider: a. The extent to which the proposed antenna assembly significantly impairs a view, as defined in Section 17.02.040 of the developm ent code, from a surrounding lot; b. With respect to an antenna assembly that is used for amateur radio purposes, the degree to which refusing or conditioning the permit would interfere with the applicant's ability to receive and/or transmit radio signals on amateur frequencies. In evaluating this criterion the Planning Commission may establish a maximum height for the antenna assembly that reasonably accommodates the applicant's ability to receive and/or transmit radio signals on amateur frequencies and appropriately balances that right with the goals of the City's general plan and development code; c. That adequate provision is made for safety and that all applicable building code requirements such as wind load and seismic design criteria, and development code requirements such as setbacks, are met; d. That the antenna assembly shall be designed to minimize the visual impact to the greatest extent feasible by means of placement, screening, camouflaging, painting, and texturing and to be compatible with existing architectural elements, building materials and other site characteristics. The applicant shall use the smallest and least visible antennas possible to accomplish the coverage objectives; e. Appropriate conditions to minimize significant view impa irment and to promote the goals of the general plan and development code, such as, but not limited to: i. Location restrictions, ii. Nesting restrictions, iii. Array size restrictions, iv. Mass of tower restrictions, v. Height restrictions, vi. Elimination of guy wires, B-8 vii. Addition of guy wires, if in the opinion of the Planning Commission allowing guy wires would minimize the aesthetic impacts, vii. Screening or camouflaging requirements, provided said requirements have not been shown to be cost prohibitive by the applicant, in which case a less costly alternative shall be imposed, and viii. Compliance with any or all applicable regulations listed in subsection 17.76.020(C)(2) above. f. That the following additional findings can be made for approval of more than one nonexempt antenna assembly: i. The additional antenna assembly cannot be reasonably located on the existing antenna assembly; ii. The additional antenna assembly does not significantly impair a view from surrounding properties; and iii. The additional antenna assembly balances the effects on the character of the neighborhood while reasonably accommodating the radio amateur operator's ability to transmit and receive radio amateur signals. 4. If the application is granted or conditionally granted, notice of the Planning Commission's decision shall be given to the applicant and to all interested persons. Notice of denial shall be given only to the applicant. The applicant or any interested person may appeal the Planning Commission's decision to the City Council pursuant to Chapter 17.80 (Hearing Notice and Appeal Procedures) of this title. 5. The noncommercial amateur radio antenna permit shall be valid only so long as all conditions imposed are fully complied with, and the antenna structure is maintained in good repair. E. State and Federal Law. The implementation of this Section and decisions on applications for placement of Noncommercial Amateur Radio Antennas shall, at a minimum, ensure that the requirements of this Section are satisfied, unless it is determined that the applicant has established that denial of an application would, within the meaning of federal law, prohibit or effectively prohibit use of the Noncommercial Amateur Radio Antenna, or otherwise violate applicable laws or regulations including but not limited to California Government Code section 65850.3 and section 97.15 of the Title 47 of the Code of Federal Regulations. If that determination is made, the requirements of this Section may be waived, but only to the minimum extent required to avoid the B-9 prohibition or violation. If an applicant contends that denial of the application would prohibit or effectively prohibit the use of the antenna in violation of federal law, or otherwise violate applicable law, the application must provide all information on which the applicant relies on in support of that claim. Section 4. This ordinance is exempt from the California Environmental Quality Act (“CEQA”) pursuant to Section 15061(b)(3) because it consists only of minor revisions and clarifications to an existing zoning code and will not have the effect of deleting or substantially changing any regulatory standards or findings. The proposed ordinance is an action that does not have the potential to cause significant effects on the environment, but rather will supplement the regulations and review procedure established in the City’s Municipal Code. Section 5. If any s ection, subsection, sentence, clause, or phrase of this ordinance is for any reason held to be invalid or unconstitutional by a decision of any court of any competent jurisdiction, such decision shall not affect the validity of the remaining portions of this ordinance. The City Council hereby declares that it would have passed this ordinance, and each and every section, subsection, sentence, clause and phrase thereof not declared invalid or unconstitutional without regard to whether any portion of the ordinance would be subsequently declared invalid or unconstitutional. Section 6. The City Clerk shall certify to the passage and adoption of this ordinance, and shall make a minute of the passage and adoption thereof in the records of and the proceedings of the City Council at which the same is passed and adopted. This Ordinance shall take effect immediately, pursuant to the authority conferred upon the City Council by Government Code Section 36937. The City Clerk shall cause a summary of this ordinance to be published in accordance with Government Code Section 36933 in a newspaper of general circulation which is hereby designated for that purpose. Section 7. Effective Date. This Ordinance shall go into effect on the 31st day after its passage. B-10 PASSED, APPROVED AND ADOPTED this ___ day of _____, 2020. John Cruikshank, Mayor Attest: Emily Colborn, City Clerk STATE OF CALIFORNIA ) COUNTY OF LOS ANGELES )ss CITY OF RANCHO PALOS VERDES ) I, EMILY COLBORN, City Clerk of the City of Rancho Palos Verdes, do hereby certify that the whole number of members of the City Council of said City is five; that the foregoing Ordinance No. passed first reading on____________, 2020, was duly adopted by the City Council of said City at a regular meeting thereof held on ________, 2020, and that the same was passed and adopted by the following roll call vote: AYES: NOES: ABSENT: ABSTAIN: ______________________ Emily Colborn, City Clerk B-11 ORDINANCE NO. AN ORDINANCE OF THE CITY OF RANCHO PALOS VERDES AMENDING SECTIONS 17.76.020(C) (NONCOMMERCIAL AMATEUR RADIO ANTENNAS) AND (D) (NONCOMMERCIAL AMATEUR RADIO ANTENNA PERMIT) OF CHAPTER 17.76 (MISCELLANEOUS PERMITS AND STANDARDS) OF TITLE 17 (ZONING) OF THE RANCHO PALOS VERDES MUNICIPAL CODE TO UPDATE THE REGULATIONS AND REVIEW PROCEDURE FOR NONCOMMERCIAL AMATEUR RADIO ANTENNAS WHEREAS, the City regulates the installation of noncommercial amateur radio antennas pursuant to Sections 17.76.020(C) and (D) of the Rancho Palos Verdes Municipal Code (RPVMC); and WHEREAS, the City desires to update Sections 17.76.020(C) and (D) to ensure antenna structures are aesthetically compatible with surrounding uses that will not adversely alter the visual character of the surrounding area, and are consistent with the goals and policies of the City’s General Plan; and WHEREAS, Government Code Section 36937 expressly authorizes the City Council to adopt an urgency ordinance for the immediate preservation of the public peace, health, or safety, if the ordinance is approved by four-fifths of the City Council; and WHEREAS, on March 4, 2020, the City Council adopted Urgency Ordinance No. 632U, which imposed a temporary 45-day moratorium on the establishment, expansion, or modification of noncommercial amateur radio antennas associated with Sections 17.76.020(C) and (D) in order to review, research and initiate code amendments to the aforementioned sections to update the regulations and review procedures for noncommercial amateur radio antennas so as to be compatible with the neighborhoods where they are erected; and WHEREAS, on April 7, 2020, the City Council adopted Urgency Ordinance No. 634U, to extend the moratorium period enacted by interim Urgency Ordinance No. 632U by an additional 10 months and 15 days, to allow Staff adequate time to research and prepare code amendment proceedings; and WHEREAS, on July 28, 2020, the Planning Commission held a duly-noticed public hearing, at which time the draft ordinance was reviewed and discussed among the Planning Commission, Staff, and interested parties. The item was continued to August 25, 2020, and subsequently to Sep tember 22, 2020, to allow Staff additional time to incorporate the input received and reach out to interested parties for comments on the revised draft ordinance; and C-1 WHEREAS, on September 20 and 24, 2020, a public notice was published in the Daily Breeze and the Palos Verdes Peninsula News, respectively, providing a notice of a public hearing before the City Council on October 6, 2020; and WHEREAS, on September 22, 2020, the Planning Commission held a duly-noticed public hearing, and adopted P.C. Resolution No. 2020-14, recommending that the City Council adopt this Ordinance; and WHEREAS, on October 6, 2020, the City Council conducted a duly noticed public hearing on this Ordinance, and all testimony was received was made a part of the public record; and WHEREAS, the City Council has duly considered all information presented to it, including the Planning Commission findings, P.C. Resolution No. 2020-14, written staff reports, and any testimony provided at the public hearing; and WHEREAS, the City’s standards constitute “the minimum practicable regulations” to accomplish the City’s legitimate purpose and will “reasonably accommodate amateur radio service communications and allow those structures to be erected at heights and dimensions sufficient to accommodate amateur radio service communication per California Government Code Section 65850.3 and Section 97.15 of the Title 47 of the Code of Federal Regulations; and WHEREAS, all legal prerequisites to the adoption of the Ordinance have been met. NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF RANCHO PALOS VERDES DOES ORDAIN AS FOLLOWS: Section 1. The City Council of the City of Rancho Palos Verdes hereby makes the following findings: A. The above recitals are true and correct and incorporated fully herein by reference. B. It is the intent and purpose of this Ordinance that Sections 17.76.020(C) (Noncommercial Amateur Radio Antennas) and (D) (Noncommercial Amateur Radio Antenna Permit) of Chapter 17.76 (Miscellaneous Permits and Standards) of Title 17 (Zoning) of the RPVMC be amended to update the development standards for noncommercial amateur radio antennas. Section 2. The proposed code amendment to Title 17 adopted herein is consistent with the Rancho Palos Verdes General Plan and Coastal Specific Plan in that it uph olds, and does not hinder, the goals and policies of those plans. Section 3. Sections 17.76.020(C) (Noncommercial Amateur Radio Antennas) and (D) (Noncommercial Amateur Radio Antenna Permit) of Chapter 17.76 (Miscellaneous Permits and Standards) of Title 17 (Zoning) of the RPVMC is hereby amended as follows, with the remaining portions of Section 17.76.020 remaining unchanged (new text in bold C-2 italics, deletions in strikethrough): “17.76.020 – Antennas. … C. Noncommercial Amateur Radio Antennas. 1. Applicability. This subsection C regulates noncommercial amateur radio antennas that are affixed to real property and antennas that are located on vehicles parked on lots which exceed sixteen feet in height, as measured pursuant to the residential building height measurement methods described in Section 17.02.040 (View preservation and restoration) of this title. This subsection does not regulate hand held antennas or antennas located on vehicles parked on lots which are sixteen feet or less in height, as measured pursuant to the residential building height measurement methods described in Section 17.02.040 (View preservation and restoration) of this title. 2. General Regulations. The installation, erection and/or replacement of noncommercial amateur radio antenna assemblies on lots for noncommercial purposes shall be reviewed by the Director through either an antenna Site Plan Review application or by the Planning Commission through a noncommercial amateur radio antenna permit application. a. Existing aAntenna assemblies which were meet the following criteria shall be considered legal nonconforming: i) legally permitted by the City or the County prior to City incorporation, and which conform to the codes in effect when installed, but do not meet the provisions of this code; and are ii) existing as of the effective date of this code shall be considered legal nonconforming. b. Antenna assembly height shall be measured as follows: i. The height of the antenna assembly shall include the antenna(s) support structure and shall be the maximum to which it is capable of being extended; ii. For a ground mounted assembly or one mounted on an accessory structure, the height shall be measured from the highest point of the existing grade covered by the foundation of the structure to the maximum height to which the antenna assembly is capable of being extended; and iii. Except for exempt antennas described in subsection (C)(3)(c)(ii) of this Section, for an antenna assembly mounted on a main building or an accessory structure, height shall be measured from existing grade to the maximum height to which the antenna C-3 assembly is capable of being extended, pursuant to the residential building height measurement methods described in Section 17.02.040 (View preservation and restoration) of this title. c. Noncommercial amateur radio antennas shall not be located within any front yard area, without approval of a variance pursuant to Chapter 17.64 (Variances) of this title. d. The use of antennas for noncommercial purposes shall mean that no commercial frequency is used for transmission or propagation, that there is no communication for hire or for material compensation, except as allowed by Federal Communications Commission (FCC) regulations, and that all applicable regulations are complied with at all times, including, without limitation, FCC regulation 97. e. A noncommercial amateur radio antenna assembly shall not include oil derrick style structures and no structures with guy wires shall be used or constructed, except as provided for in this Section. f. No signage shall be allowed on any noncommercial amateur radio antenna assembly, except for requisite safety text and other labeling required by law. g. A noncommercial amateur radio antenna assembly shall comply with all City, State and Federal laws including the City’s view preservation requirements in Section 17.02.040. h. A noncommercial antenna assembly subject to this Section shall not be any closer to the property line than the required minimum side and rear yard setbacks for the subject lot without written City approval which shall take into consideration the site specific conditions. i. All antennas capable of being retracted and extended shall be retracted to its minimum size and height when not in use or retracted as required in any conditions of approval issued by the City. j. Each noncommercial amateur radio antenna shall be of a color or painted to minimize its reflectivity and blend with its surroundings as much as possible. k. Upon the sale or transfer of the subject property any permit issued under this section shall not be transferable to any other person including a new property owner. 3. Antennas Exempt. The following noncommercial amateur radio antenna assemblies may be constructed or installed on a lot without the approval of an C-4 antenna Site Plan Review application or noncommercial radio antenna permit; a. The replacement of an existing antenna or antenna support structure with an outside diameter of three inches or less with a similar antenna or support structure. b. Parabolic dish antennas which are one meter (39.37 inches) or less in diameter. This exemption shall not apply to parabolic dishes located on a mast which is greater than twelve feet in height. Freestanding masts shall be measured from existing adjacent grade. Masts located on a building shall be measured from the point where the mast meets the roof surface. c. Any combination of two different antenna assemblies from the following categories: i. One antenna assembly which is located outside of any required setback areas and which is sixteen feet or less in height, as measured pursuant to the residential building height measurement methods described in Section 17.02.040 (View preservation and restoration) of this title. ii. One building mounted antenna assembly, located outside of any required setback areas, which does not exceed twelve feet in height, as measured from the point where the antenna assembly meets the roof surface, and which contains radiating elements, each of which does not exceed six feet in total length. If the antenna assembly is mounted onto the roof, or if any portion of the antenna assembly projects above the roofline, not more than one antenna may be affixed to antenna support structure. iii. One wire antenna assembly consisting of a single flexible wire, with a diameter not to exceed one-half inch, suspended between two supports, which if man-made do not exceed forty-one feet in height as measured from adjacent existing grade, and located outside of any required setback areas., and having a transmission line connected to a receiver and/or a transmitter. iv. One vertical antenna assembly, located outside of any required setback areas, consisting of a single pole or mast with a maximum outside diameter of three inches or less with no guys or horizontal elements located higher than two feet above the ridgeline of the residence, and which does not exceed forty-one feet in total height, as measured from adjacent existing grade. 4. Antenna Site Plan Review Approval. a. Director review. Director approval of an antenna Site Plan Review C-5 application is required for more than two antenna assemblies which are exempt pursuant to subsection (C)(3) of this Section, and for any other nonexempt antenna assembly which does not exceed forty-one feet in height. The application may be approved provided the Director finds as follows: i. That adequate provision is made for safety; ii. That all applicable building code requirements, such as wind load and seismic design criteria, and development code requirements, such setbacks, are met; iii. That no more than one nonexempt antenna support structure will be located on the lot; and iv. That the placement of the antenna assembly does not significantly impair a view from any surrounding properties, as defined in Section 17.02.040 (View preservation and restoration) of this title; and, v. That the antenna assembly shall be designed to minimize the visual impact to the greatest extent feasible by means of placement, screening, camouflaging, painting and texturing and to be compatible with existing architectural elements, building materials and other site characteristics. The applicant shall use the smallest and least visible antennas possible to accomplish the coverage objectives. b. Application. The antenna Site Plan Review application shall be made upon forms provided by the City and shall be accompanied by the following: i. Two copies of a scaled site plan showing the location of the antenna assembly, and its relation to property lines, topography and all structures on the property, and two copies of an elevation drawing showing the proposed height, size, vertical and horizontal components, dimensions, color and material of the antenna(s) and antenna support structure. If a building permit is required pursuant to the Uniform California Building Code, three copies of the above plans are necessary; ii. A typed mailing list of all property owners within a five hundred-foot radius adjacent to the subject property, using the last equalized tax roll of the county assessor and any affected homeowners associations, and a vicinity map identifying all properties included on the mailing list. C-6 iii. A fee, as established by resolution of the City Council. iv. Documentation demonstrating that the antenna assembly will comply with all other FCC standards related to radio frequency emissions in OET Bulletin 65, Supplement B. Said documentation shall state if the antenna is categorically exempt or demonstrate compliance with the standards of OET Bulletin 65. v. The applicant shall certify that the proposed antennas and installation, comply with FCC regulations related to interference and in the event the interference occurs, the applicant will take all steps necessary to resolve the same. vi. The applicant shall, as part of the application, construct at the applicant's expense, a mock-up of the proposed antenna at the proposed location. Said mock up shall be the same size and dimensions as the proposed antenna. The mock-up shall be coordinated under the direction of the Director or his/her designee. Once constructed, the silhouette shall be certified by a licensed engineer on a form provided by the City. In the alternative, the applicant may submit a photo simulation depicting the proposed antenna in size, height and dimensions, as required by the City to depict the proposed antenna as it would appear from the surrounding area. c. Notice. Upon receipt of a complete antenna Site Plan Review application, the Director shall provide written notice of the application to the applicant, adjacent property owners within a five hundred-foot radius, any affected homeowners associations and any interested parties. No sooner than fifteen days after the application notices are mailed, the Director shall make a decision on the application. Notice of the Director's decision shall be provided to the applicant, adjacent property owners, any affected homeowners associations, and any interested parties. The Director's decision may be appealed to the Planning Commission and the Planning Commission's decision may be appealed to the City Council pursuant to Chapter 17.80 (Hearing Notice and Appeal Proced ures) of this title. D. Noncommercial Amateur Radio Antenna Permit. Except for antenna assemblies which are exempt pursuant to subsection (C)(3) of this Section, antenna assemblies which exceed forty-one feet in height or which involve the placement of more than one nonexempt antenna support structure on a lot shall require the approval of a noncommercial amateur radio antenna permit by the Planning Commission. 1. Application. Application for a noncommercial amateur radio antenna permit shall be made on forms provided by the City and shall include such plans C-7 and documents as may reasonably be required by the Director, including submittal requirements for the antenna Site Plan Review application in subsection (4)(b), for a complete understanding of the proposal and a filing fee in an amount established by resolution of the City Council. 2. Notice. Upon receipt of a complete application for a noncommercial amateur radio antenna permit, the Director shall provide written notice of the application to all owners of a property shown on the last known county assessor tax roll and homeowner associations located within a radius of five hundred feet of the external boundaries of the property where the antenna assembly is proposed. 3. Action by Planning Commission. In granting a noncommercial amateur radio antenna permit, the Planning Commission shall consider: a. The extent to which the proposed antenna assembly significantly impairs a view, as defined in Section 17.02.040 of the development code, from a surrounding lot; b. With respect to an antenna assembly that is used for amateur radio purposes, the degree to which refusing or conditioning the permit would interfere with the applicant's ability to receive and/or transmit radio signals on amateur frequencies. In evaluating this criterion the Planning Commission may establish a maximum height for the antenna assembly that reasonably accommodates the applicant's ability to receive and/or transmit radio signals on amateur frequencies and appropriately balances that right with the goals of the City's general plan and development code; c. That adequate provision is made for safety and that all applicable building code requirements such as wind load and seismic design criteria, and development code requirements such as setbacks, are met; d. That the antenna assembly shall be designed to minimize the visual impact to the greatest extent feasible by means of placement, screening, camouflaging, painting, and texturing and to be compatible with existing architectural elements, building materials and other site characteristics. The applicant shall use the smallest and least visible antennas possible to accomplish the coverage objectives; de. Appropriate conditions to minimize significant view impairment and to promote the goals of the general plan and development code, such as, but not limited to: i. Location restrictions, ii. Nesting restrictions, iii. Array size restrictions, C-8 iv. Mass of tower restrictions, v. Height restrictions, and vi. Elimination of guy wires, vii. Addition of guy wires, if in the opinion of the Planning Commission allowing guy wires would minimize the aesthetic impacts, vii. Screening or camouflaging requirements, provided said requirements have not been shown to be cost prohibitive by the applicant, in which case a less costly alternative shall be imposed, and viii. Compliance with any or all applicable regulations listed in subsection 17.76.020(C)(2) above. ef. That the following additional findings can be made for approval of more than one nonexempt antenna assembly: i. The additional antenna assembly cannot be reasonably located on the existing antenna assembly; ii. The additional antenna assembly does not significantly impair a view from surrounding properties; and iii. The additional antenna assembly balances the effects on the character of the neighborhood while reasonably accommodating the radio amateur operator's ability to transmit and receive radio amateur signals. 4. If the application is granted or conditionally granted, notice of the Planning Commission's decision shall be given to the applicant and to all interested persons. Notice of denial shall be given only to the applicant. The applicant or any interested person may appeal the Planning Commission's decision to the City Council pursuant to Chapter 17.80 (Hearing Notice and Appeal Procedures) of this title. 5. The noncommercial amateur radio antenna permit shall be valid only so long as all conditions imposed are fully complied with, and the antenna structure is maintained in good repair. E. State and Federal Law. The implementation of this Section and decisions on applications for placement of Noncommercial Amateur Radio Antennas shall, at a minimum, ensure that the requirements of this Section are satisfied, unless it is C-9 determined that the applicant has established that denial of an application would, within the meaning of federal law, prohibit or effectively prohibit use of the Noncommercial Amateur Radio Antenna, or otherwise violate applicable laws or regulations including but not limited to California Government Code section 65850.3 and section 97.15 of the Title 47 of the Code of Federal Regulations. If that determination is made, the requirements of this Section may be waived, but only to the minimum extent required to avoid the prohibition or violation. If an applicant contends that denial of the application would prohibit or effectively prohibit the use of the antenna in violation of federal law, or otherwise violate applicable law, the application must provide all information on which the applicant relies on in support of that claim. Section 4. This ordinance is exempt from the California Environmental Quality Act (“CEQA”) pursuant to Section 15061(b)(3) because it consists only of minor revisions and clarifications to an existing zoning code and will not have the effect of deleting or substantially changing any regulatory standards or findings. The proposed ordinance is an action that does not have the potential to cause significant effects on the environment, but rather will supplement the regulations and review procedure established in the City’s Municipal Code. Section 5. If any s ection, subsection, sentence, clause, or phrase of this ordinance is for any reason held to be invalid or unconstitutional by a decision of any court of any competent jurisdiction, such decision shall not affect the validity of the remaining portions of this ordinance. The City Council hereby declares that it would have passed this ordinance, and each and every section, subsection, sentence, clause and phrase thereof not declared invalid or unconstitutional without regard to whether any portion of the ordinance would be subsequently declared invalid or unconstitutional. Section 6. The City Clerk shall certify to the passage and adoption of this ordinance, and shall make a minute of the passage and adoption thereof in the records of and the proceedings of the City Council at which the same is passed and adopted. This Ordinance shall take effect immediately, pursuant to the authority conferred upon the City Council by Government Code Section 36937. The City Clerk shall cause a summary of this ordinance to be published in accordance with Government Code Section 36933 in a newspaper of general circulation which is hereby designated for that purpose. Section 7. Effective Date. This Ordinance shall go into effect on the 31st day after its passage. C-10 PASSED, APPROVED AND ADOPTED this ___ day of _____, 2020. John Cruikshank, Mayor Attest: Emily Colborn, City Clerk STATE OF CALIFORNIA ) COUNTY OF LOS ANGELES )ss CITY OF RANCHO PALOS VERDES ) I, EMILY COLBORN, City Clerk of the City of Rancho Palos Verdes, do hereby certify that the whole number of members of the City Council of said City is five; that the foregoing Ordinance No. passed first reading on____________, 2020, was duly adopted by the City Council of said City at a regular meeting thereof held on ________, 2020, and that the same was passed and adopted by the following roll call vote: AYES: NOES: ABSENT: ABSTAIN: ______________________ Emily Colborn, City Clerk C-11 P.C. Resolution No.2020-14 Page 1 of 15 P .C. RESOLUTION NO. 2020-14 A RESOLUTION OF THE PLANNING COMMISSION OF THE CITY OF RANCHO PALOS VERDES RECOMMENDING THAT THE CITY COUNCIL ADOPT PROPOSED AMENDMENTS TO SECTIONS 17.76.020(C) (NONCOMMERCIAL AMATEUR RADIO ANTENNAS) AND (D) (NONCOMMERCIAL AMATEUR RADIO ANTENNA PERMIT) OF CHAPTER 17.76 (MISCELLANEOUS PERMITS AND STANDARDS) OF TITLE 17 (ZONING) OF THE RANCHO PALOS VERDES MUNICIPAL CODE TO UPDATE THE REGULATIONS AND REVIEW PROCEDURE FOR NONCOMMERCIAL AMATEUR RADIO ANTENNAS (CASE NO. PLCA2020-0003) WHEREAS, the City regulates the installation of noncommercial amateur radio antennas pursuant to Sections 17.76.020(C) & (D) of the Rancho Palos Verdes Municipal Code (RPVMC); and WHEREAS, the current RPVMC provisions governing the use and permitting of noncommercial amateur radio antennas are outdated and inconsistent with the goals and policies of the City’s General Plan; and WHEREAS, the City desires to update Sections 17.76.020(C) & (D) to ensure antenna structures are aesthetically compatible with surrounding uses that will not adversely alter the visual character of the area , and are consistent with the goals and policies of the City’s General Plan; and WHEREAS, Government Code Section 36937 expressly authorizes the City Council to adopt an urgency ordinance for the immediate preservation of the public peace, health, or safety, if the ordinance is approved by four-fifths of the City Council; and WHEREAS, on March 4, 2020, the City Council adopted Urgency Ordinance No. 632U, which imposed a temporary 45-day moratorium on the establishment, expansion, or modification of noncommercial amateur radio antennas associated with Sections 17.76.020(C) & (D) in order to initiate code amendments to the aforementioned sections to update the regulations and review procedures for noncommercial amateur radio antennas so as to be compatible with the neighborhoods where they are erected; and WHEREAS, on April 7, 2020, the City Council adopted Urgency Ordinance No. 634U, to extend the moratorium period enacted by interim Urgency Ordinance No. 632U by an additional 10 months and 15 days, to allow Staff adequate time to research and prepare code amendment proceedings; and WHEREAS, on July 9, 2020, a public notice was published in the Palos Verdes Peninsula News and sent out to interested parties, announcing code amendment proceedings to be heard by the Planning Commission, pursuant to the requirements of the RPVMC; and D-1 P.C. Resolution No.2020-14 Page 2 of 15 WHEREAS, on July 28, 2020, the Planning Commission held a duly-noticed public hearing, at which time the draft ordinance was reviewed and discussed among the Planning Commission, Staff, and interested parties. The item was continued to August 25, 2020, and subsequently to September 22, 2020, to allow Staff additional time to incorporate the input received and reach out to interested parties for comments on the revised draft ordinance; and WHEREAS, on September 22, 2020, the Planning Commission held a duly-noticed public hearing, at which time all interested parties were given an opportunity to be heard and present evidence on the draft ordinance. NOW, THEREFORE, THE PLANNING COMMISSION OF THE CITY OF RANCHO PALOS VERDES, HEREBY FINDS, DETERMINES, AND RESOLVES AS FOLLOWS: SECTION 1. The above recitals are true and correct and incorporated fully herein by reference. SECTION 2. The Planning Commission has reviewed and considered the proposed code amendments to Sections 17.76.020(C) (Noncommercial Amateur Radio Antennas) and (D) (Noncommercial Amateur Radio Antenna Permit) of Chapter 17.76 (Miscellaneous Permits and Standards) of Title 17 (Zoning) of the RPVMC to update the development standards for noncommercial amateur radio antennas regarding the height threshold, general regulations, application requirements, and review procedures , addressing the community concerns related to compatibility with the surrounding uses and mitigation of visual impacts, while complying with the Federal Communications Commission standards, as presented in ‘Exhibit A’. SECTION 3. The proposed amendment is consistent with the Rancho Palos Verdes General Plan and Coastal Specific Plan in that they uphold, and not hinder, the goals and policies of those plans. SECTION 4. The proposed amendment is exempt from the California Environmental Quality Act (“CEQA”) pursuant to Section 15061(b)(3) because it consists only of minor revisions and clarifications to an existing zoning code and will not have the effect of deleting or substantially changing any regulatory standards or findings. The proposed amendment is an action that does not have the potential to cause significant effects on the environment, but rather will supplement the regulations and review procedures established in the City’s Municipal Code. SECTION 4. For the foregoing reasons and based on the information and findings included in the Staff Report, Minutes and other records of proceedings, the Planning Commission of the City of Rancho Palos Verdes he reby recommends to the City Council that an Ordinance be adopted entitled, "AN ORDINANCE OF THE CITY OF RANCHO PALOS VERDES AMENDING SECTIONS 17.76.020(C) (NONCOMMERCIAL AMATEUR RADIO ANTENNAS) AND (D) (NONCOMMERCIAL AMATEUR RADIO ANTENNA D-2 P.C. Resolution No.2020-14 Page 3 of 15 PERMIT) OF CHAPTER 17.76 (MISCELLANEOUS PERMITS AND STANDARDS) OF TITLE 17 (ZONING) OF THE RANCHO PALOS VERDES MUNICIPAL CODE TO UPDATE THE REGULATIONS AND REVIEW PROCEDURE FOR NONCOMMERCIAL AMATEUR RADIO ANTENNAS”. PASSED, APPROVED AND ADOPTED this 22nd day of September, 2020. AYES: COMMISSIONERS HAMILL, JAMES, SAADATNEJADI, SANTAROSA, VICE- CHAIRMAN PERESTAM, AND CHAIRMAN LEON NOES: COMMISSIONER CHURA ABSTENTIONS: NONE RECUSALS: NONE ABSENT: NONE Gordon Leon Chair of the Planning Commission Ken Rukavina, PE, Director of Community Development Secretary of the Planning Commission D-3 P.C. Resolution No.2020-14 Page 4 of 15 EXHIBIT “A” DRAFT ORDINANCE NO. __ Please see attached. D-4 P.C. Resolution No.2020-14 Page 5 of 15 ORDINANCE NO. AN ORDINANCE OF THE CITY OF RANCHO PALOS VERDES AMENDING SECTIONS 17.76.020(C) (NONCOMMERCIAL AMATEUR RADIO ANTENNAS) AND (D) (NONCOMMERCIAL AMATEUR RADIO ANTENNA PERMIT) OF CHAPTER 17.76 (MISCELLANEOUS PERMITS AND STANDARDS) OF TITLE 17 (ZONING) OF THE RANCHO PALOS VERDES MUNICIPAL CODE TO UPDATE THE REGULATIONS AND REVIEW PROCEDURE FOR NONCOMMERCIAL AMATEUR RADIO ANTENNAS WHEREAS, the City regulates the installation of noncommercial amateur radio antennas pursuant to Sections 17.76.020(C) and (D) of the Rancho Palos Verdes Municipal Code (RPVMC); and WHEREAS, the City desires to update Sections 17.76.020(C) and (D) to ensure antenna structures are aesthetically compatible with surrounding uses that will not adversely alter the visual character of the surrounding area, and are consistent with the goals and policies of the City’s General Plan; and WHEREAS, Government Code Section 36937 expressly authorizes the City Council to adopt an urgency ordinance for the immediate preservation of the public peace, health, or safety, if the ordinance is approved by four-fifths of the City Council; and WHEREAS, on March 4, 2020, the City Council adopted Urgency Ordinance No. 632U, which imposed a temporary 45-day moratorium on the establishment, expansion, or modification of noncommercial amateur radio antennas associated with Sections 17.76.020(C) and (D) in order to review, research and initiate code amendments to the aforementioned sections to update the regulations and review procedures for noncommercial amateur radio antennas so as to be compatible with the neighborhoods where they are erected; and WHEREAS, on April 7, 2020, the City Council adopted Urgency Ordinance No. 634U, to extend the moratorium period enacted by interim Urgency Ordinance No. 632U by an additional 10 months and 15 days, to allow Staff adequate time to research and prepare code amendment proceedings; and WHEREAS, on July 28, 2020, the Planning Commission held a duly-noticed public hearing, at which time the draft ordinance was reviewed and discussed among the Planning Commission, Staff, and interested parties. The item was continued to August 25, 2020, and subsequently to September 22, 2020, to allow Staff additional time to incorporate the input received and reach out to interested parties for comments on the revised draft ordinance; and D-5 P.C. Resolution No.2020-14 Page 6 of 15 WHEREAS, on September 20 and 24, 2020, a public notice was published in the Daily Breeze and the Palos Verdes Peninsula News, respectively, providing a notice of a public hearing before the City Council on October 6, 2020; and WHEREAS, on September 22, 2020, the Planning Commission held a duly-noticed public hearing, and adopted P.C. Resolution No. 2020-14, recommending that the City Council adopt this Ordinance; and WHEREAS, on October 6, 2020, the City Council conducted a duly noticed public hearing on this Ordinance, and all testimony was received was made a part of the public record; and WHEREAS, the City Council has duly considered all information presented to it, including the Planning Commission findings, P.C. Resolution No. 2020-14, written staff reports, and any testimony provided at the public hearing; and WHEREAS, the City’s standards constitute “the minimum practicable regulations” to accomplish the City’s legitimate purpose and will “reasonably accommodate amateur radio service communications and allow those structures to be erected at heights and dimensions sufficient to accommodate amateur radio service communication per California Government Code Section 65850.3 and Section 97.15 of the Title 47 of the Code of Federal Regulations; and WHEREAS, all legal prerequisites to the adoption of the Ordinance have been met. NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF RANCHO PALOS VERDES DOES ORDAIN AS FOLLOWS: SECTION 1. The City Council of the City of Rancho Palos Verdes hereby makes the following findings: A. The above recitals are true and correct and incorporated fully herein by reference. B. It is the intent and purpose of this Ordinance that Sections 17.76.020(C) (Noncommercial Amateur Radio Antennas) and (D) (Noncommercial Amateur Radio Antenna Permit) of Chapter 17.76 (Miscellaneous Permits and Standards) of Title 17 (Zoning) of the RPVMC be amended to update the development standards for noncommercial amateur radio antennas. SECTION 2. The proposed code amendment to Title 17 adopted herein is consistent with the Rancho Palos Verdes General Plan and Coastal Specific Plan in that it uph olds, and does not hinder, the goals and policies of those plans. SECTION 3. Sections 17.76.020(C) (Noncommercial Amateur Radio Antennas) and (D) (Noncommercial Amateur Radio Antenna Permit) of Chapter 17.76 (Miscellaneous Permits and Standards) of Title 17 (Zoning) of the RPVMC is hereby amended as follows, with the remaining portions of Section 17.76.020 remaining unchanged (new text in bold D-6 P.C. Resolution No.2020-14 Page 7 of 15 italics, deletions in strikethrough): “17.76.020 – Antennas. … C. Noncommercial Amateur Radio Antennas. 1. Applicability. This subsection C regulates noncommercial amateur radio antennas that are affixed to real property and antennas that are located on vehicles parked on lots which exceed sixteen feet in height, as measured pursuant to the residential building height measurement methods described in Section 17.02.040 (View preservation and restoration) of this title. This subsection does not regulate hand held antennas or antennas located on vehicles parked on lots which are sixteen feet or less in height, as measured pursuant to the residential building height measurement methods described in Section 17.02.040 (View preservation and restoration) of this title. 2. General Regulations. The installation, erection and/or replacement of noncommercial amateur radio antenna assemblies on lots for noncommercial purposes shall be reviewed by the Director through either an antenna Site Plan Review application or by the Planning Commission through a noncommercial amateur radio antenna permit application. a. Existing aAntenna assemblies which were meet the following criteria shall be considered legal nonconforming: i) legally permitted by the City or the County prior to City incorporation, and which conform to the codes in effect when installed, but do not meet the provisions of this code; and are ii) existing as of the effective date of this code shall be considered legal nonconforming. b. Antenna assembly height shall be measured as follows: i. The height of the antenna assembly shall include the antenna(s) support structure and shall be the maximum to which it is capable of being extended; ii. For a ground mounted assembly or one mounted on an accessory structure, the height shall be measured from the highest point of the existing grade covered by the foundation of the structure to the maximum height to which the antenna assembly is capable of being extended; and iii. Except for exempt antennas described in subsection (C)(3)(c)(ii) of this Section, for an antenna assembly mounted on a main building or an accessory structure, height shall be measured from existing grade to the maximum height to which the antenna D-7 P.C. Resolution No.2020-14 Page 8 of 15 assembly is capable of being extended, pursuant to the residential building height measurement methods described in Section 17.02.040 (View preservation and restoration) of this title. c. Noncommercial amateur radio antennas shall not be located within any front yard area, without approval of a variance pursuant to Chapter 17.64 (Variances) of this title. d. The use of antennas for noncommercial purposes shall mean that no commercial frequency is used for transmission or propagation, that there is no communication for hire or for material compensation, except as allowed by Federal Communications Commission (FCC) regulations, and that all applicable regulations are complied with at all times, including, without limitation, FCC regulation 97. e. A noncommercial amateur radio antenna assembly shall not include oil derrick style structures and no structures with guy wires shall be used or constructed, except as provided for in this Section. f. No signage shall be allowed on any noncommercial amateur radio antenna assembly, except for requisite safety text and other labeling required by law. g. A noncommercial amateur radio antenna assembly shall comply with all City, State and Federal laws including the City’s view preservation requirements in Section 17.02.040. h. A noncommercial antenna assembly subject to this Section shall not be any closer to the property line than the required minimum side and rear yard setbacks for the subject lot without written City approval which shall take into consideration the site specific conditions. i. All antennas capable of being retracted and extended shall be retracted to its minimum size and height when not in use or retracted as required in any conditions of approval issued by the City . j. Each noncommercial amateur radio antenna shall be of a color or painted to minimize its reflectivity and blend with its surroundings as much as possible. k. Upon the sale or transfer of the subject property any permit issued under this section shall not be transferable to any other person including a new property owner. 3. Antennas Exempt. The following noncommercial amateur radio antenna assemblies may be constructed or installed on a lot without the approval of an D-8 P.C. Resolution No.2020-14 Page 9 of 15 antenna Site Plan Review application or noncommercial radio antenna permit; a. The replacement of an existing antenna or antenna support structure with an outside diameter of three inches or less with a similar antenna or support structure. b. Parabolic dish antennas which are one meter (39.37 inches) or less in diameter. This exemption shall not apply to parabolic dishes located on a mast which is greater than twelve feet in height. Freestanding masts shall be measured from existing adjacent grade. Masts located on a building shall be measured from the point where the mast meets the roof surface. c. Any combination of two different antenna assemblies from the following categories: i. One antenna assembly which is located outside of any required setback areas and which is sixteen feet or less in height, as measured pursuant to the residential building height measurement methods described in Section 17.02.040 (View preservation and restoration) of this title. ii. One building mounted antenna assembly, located outside of any required setback areas, which does not exceed twelve feet in height, as measured from the point where the antenna assembly meets the roof surface, and which contains radiating elements, each of which does not exceed six feet in total length. If the antenna assembly is mounted onto the roof, or if any portion of the antenna assembly projects above the roofline, not more than one antenna may be affixed to antenna support structure. iii. One wire antenna assembly consisting of a single flexible wire, with a diameter not to exceed one-half inch, suspended between two supports, which if man-made do not exceed forty-one feet in height as measured from adjacent existing grade, and located outside of any required setback areas., and having a transmission line connected to a receiver and/or a transmitter. iv. One vertical antenna assembly, located outside of any required setback areas, consisting of a single pole or mast with a maximum outside diameter of three inches or less with no guys or horizontal elements located higher than two feet above the ridgeline of the residence, and which does not exceed forty-one feet in total height, as measured from adjacent existing grade. 4. Antenna Site Plan Review Approval. a. Director review. Director approval of an antenna Site Plan Review D-9 P.C. Resolution No.2020-14 Page 10 of 15 application is required for more than two antenna assemblies which are exempt pursuant to subsection (C)(3) of this Section, and for any other nonexempt antenna assembly which does not exceed forty-one feet in height. The application may be approved provided the Director finds as follows: i. That adequate provision is made for safety; ii. That all applicable building code requirements, such as wind load and seismic design criteria, and development code requirements, such setbacks, are met; iii. That no more than one nonexempt antenna support structure will be located on the lot; and iv. That the placement of the antenna assembly does not significantly impair a view from any surrounding properties, as defined in Section 17.02.040 (View preservation and restoration) of this title; and, v. That the antenna assembly shall be designed to minimize the visual impact to the greatest extent feasible by means of placement, screening, camouflaging, painting and texturing and to be compatible with existing architectural elements, building materials and other site characteristics. The applicant shall use the smallest and least visible antennas possible to accomplish the coverage objectives. b. Application. The antenna Site Plan Review application shall be made upon forms provided by the City and shall be accompanied by the following: i. Two copies of a scaled site plan showing the location of the antenna assembly, and its relation to property lines, topography and all structures on the property, and two copies of an elevation drawing showing the proposed height, size, vertical and horizontal components, dimensions, color and material of the antenna(s) and antenna support structure. If a building permit is required pursuant to the Uniform California Building Code, three copies of the above plans are necessary; ii. A typed mailing list of all property owners within a five hundred-foot radius adjacent to the subject property, using the last equalized tax roll of the county assessor and any affected homeowners associations, and a vicinity map identifying all properties included on the mailing list. D-10 P.C. Resolution No.2020-14 Page 11 of 15 iii. A fee, as established by resolution of the City Council. iv. Documentation demonstrating that the antenna assembly will comply with all other FCC standards related to radio frequency emissions in OET Bulletin 65, Supplement B. Said documentation shall state if the antenna is categorically exempt or demonstrate compliance with the standards of OET Bulletin 65. v. The applicant shall certify that the proposed antennas and installation, comply with FCC regulations related to interference and in the event the interference occurs, the applicant will take all steps necessary to resolve the same. vi. The applicant shall, as part of the application, construct at the applicant's expense, a mock-up of the proposed antenna at the proposed location. Said mock up shall be the same size and dimensions as the proposed antenna. The mock-up shall be coordinated under the direction of the Director or his/her designee. Once constructed, the silhouette shall be certified by a licensed engineer on a form provided by the City. In the alternative, the applicant may submit a photo simulation depicting the proposed antenna in size, height and dimensions, as required by the City to depict the proposed antenna as it would appear from the surrounding area. c. Notice. Upon receipt of a complete antenna Site Plan Review application, the Director shall provide written notice of the application to the applicant, adjacent property owners within a five hundred-foot radius, any affected homeowners associations and any interested parties. No sooner than fifteen days after the application notices are mailed, the Director shall make a decision on the application. Notice of the Director's decision shall be provided to the applicant, adjacent property owners, any affected homeowners associations, and any interested parties. The Director's decision may be appealed to the Planning Commission and the Planning Commission's decision may be appealed to the City Council pursuant to Chapter 17.80 (Hearing Notice and Appeal Procedures) of this title. D. Noncommercial Amateur Radio Antenna Permit. Except for antenna assemblies which are exempt pursuant to subsection (C)(3) of this Section, antenna assemblies which exceed forty-one feet in height or which involve the placement of more than one nonexempt antenna support structure on a lot shall require the approval of a noncommercial amateur radio antenna permit by the Planning Commission. 1. Application. Application for a noncommercial amateur radio antenna permit shall be made on forms provided by the City and shall include such plans D-11 P.C. Resolution No.2020-14 Page 12 of 15 and documents as may reasonably be required by the Director, including submittal requirements for the antenna Site Plan Review application in subsection (4)(b), for a complete understanding of the proposal and a filing fee in an amount established by resolution of the City Council. 2. Notice. Upon receipt of a complete application for a noncommercial amateur radio antenna permit, the Director shall provide written notice of the application to all owners of a property shown on the last known county assessor tax roll and homeowner associations located within a radius of five hundred feet of the external boundaries of the property where the antenna assembly is proposed. 3. Action by Planning Commission. In granting a noncommercial amateur radio antenna permit, the Planning Commission shall consider: a. The extent to which the proposed antenna assembly significantly impairs a view, as defined in Section 17.02.040 of the development code, from a surrounding lot; b. With respect to an antenna assembly that is used for amateur radio purposes, the degree to which refusing or conditioning the permit would interfere with the applicant's ability to receive and/or transmit radio signals on amateur frequencies. In evaluating this criterion the Planning Commission may establish a maximum height for the antenna assembly that reasonably accommodates the applicant's ability to receive and/or transmit radio signals on amateur frequencies and appropriately balances that right with the goals of the City's general plan and development code; c. That adequate provision is made for safety and that all applicable building code requirements such as wind load and seismic design criteria, and development code requirements such as setbacks, are met; d. That the antenna assembly shall be designed to minimize the visual impact to the greatest extent feasible by means of placement, screening, camouflaging, painting, and texturing and to be compatible with existing architectural elements, building materials and other site characteristics. The applicant shall use the smallest and least visible antennas possible to accomplish the coverage objectives; de. Appropriate conditions to minimize significant view impairment and to promote the goals of the general plan and development code, such as, but not limited to: i. Location restrictions, ii. Nesting restrictions, iii. Array size restrictions, D-12 P.C. Resolution No.2020-14 Page 13 of 15 iv. Mass of tower restrictions, v. Height restrictions, and vi. Elimination of guy wires, vii. Addition of guy wires, if in the opinion of the Planning Commission allowing guy wires would minimize the aesthetic impacts, vii. Screening or camouflaging requirements, provided said requirements have not been shown to be cost prohibitive by the applicant, in which case a less costly alternative shall be imposed, and viii. Compliance with any or all applicable regulations listed in subsection 17.76.020(C)(2) above. ef. That the following additional findings can be made for approval of more than one nonexempt antenna assembly: i. The additional antenna assembly cannot be reasonably located on the existing antenna assembly; ii. The additional antenna assembly does not significantly impair a view from surrounding properties; and iii. The additional antenna assembly balances the effects on the character of the neighborhood while reasonably accommodating the radio amateur operator's ability to transmit and receive radio amateur signals. 4. If the application is granted or conditionally granted, notice of the Planning Commission's decision shall be given to the applicant and to all interested persons. Notice of denial shall be given only to the applicant. The applicant or any interested person may appeal the Planning Commission's decision to the City Council pursuant to Chapter 17.80 (Hearing Notice and Appeal Procedures) of this title. 5. The noncommercial amateur radio antenna permit shall be valid only so long as all conditions imposed are fully complied with, and the antenna structure is maintained in good repair. E. State and Federal Law. The implementation of this Section and decisions on applications for placement of Noncommercial Amateur Radio Antennas shall, at a minimum, ensure that the requirements of this Section are satisfied, unless it is D-13 P.C. Resolution No.2020-14 Page 14 of 15 determined that the applicant has established that denial of an application would, within the meaning of federal law, prohibit or effectively prohibit use of the Noncommercial Amateur Radio Antenna, or otherwise violate applicable laws or regulations including but not limited to California Government Code section 65850.3 and section 97.15 of the Title 47 of the Code of Federal Regulations. If that determination is made, the requirements of this Section may be waived, but only to the minimum extent required to avoid the prohibition or violation. If an applicant contends that denial of the application would prohibit or effectively prohibit the use of the antenna in violation of federal law, or otherwise violate applicable law, the application must provide all information on which the applicant relies on in support of that claim. SECTION 4. This ordinance is exempt from the California Environmental Quality Act (“CEQA”) pursuant to Section 15061(b)(3) because it consists only of minor revisions and clarifications to an existing zoning code and will not have the effect of deleting or substantially changing any regulatory standards or findings. The proposed ordinance is an action that does not have the potential to cause significant effects on the environment, but rather will supplement the regulations and review procedure established in the City’s Municipal Code. SECTION 5. If any s ection, subsection, sentence, clause, or phrase of this ordinance is for any reason held to be invalid or unconstitutional by a decision of any court of any competent jurisdiction, such decision shall not affect the validity of the remaining portions of this ordinance. The City Council hereby declares that it would have passed this ordinance, and each and every section, subsection, sentence, clause and phrase thereof not declared invalid or unconstitutional without regard to whether any portion of the ordinance would be subsequently declared invalid or unconstitutional. SECTION 6. The City Clerk shall certify to the passage and adoption of this ordinance, and shall make a minute of the passage and adoption thereof in the records of and the proceedings of the City Council at which the same is passed and adopted. This Ordinance shall take effect immediately, pursuant to the authority conferred upon the City Council by Government Code Section 36937. The City Clerk shall cause a summary of this ordinance to be published in accordance with Government Code Section 36933 in a newspaper of general circulation which is hereby designated for that purpose. SECTION 7. Effective Date. This Ordinance shall go into effect on the 31st day after its passage. PASSED, APPROVED AND ADOPTED this ___ day of _____, 2020. John Cruikshank, Mayor D-14 P.C. Resolution No.2020-14 Page 15 of 15 Attest: Emily Colborn, City Clerk STATE OF CALIFORNIA ) COUNTY OF LOS ANGELES )ss CITY OF RANCHO PALOS VERDES ) I, EMILY COLBORN, City Clerk of the City of Rancho Palos Verdes, do hereby certify that the whole number of members of the City Council of said City is five; that the foregoing Ordinance No. passed first reading on____________, 2020, was duly adopted by the City Council of said City at a regular meeting thereof held on ________, 2020, and that the same was passed and adopted by the following roll call vote: AYES: NOES: ABSENT: ABSTAIN: ______________________ Emily Colborn, City Clerk D-15 17.76.020 - Antennas. ... C. Noncommercial Amateur Radio Antennas. 1. Applicability. This subsection C regulates noncommercial amateur radio antennas that are affixed to real property and antennas that are located on vehicles parked on lots which exceed 16 feet in height, as measured pursuant to the residential building height measurement methods described in Section 17.02.040 (View preservation and restoration) of this title. This subsection does not regulate hand held antennas or antennas located on vehicles parked on lots which are 16 feet or less in height, as measured pursuant to the residential building height measurement methods described in Section 17.02.040 (View preservation and restoration) of this title. 2. General Regulations. The erection and/or replacement of noncommercial amateur radio antenna assemblies on lots for noncommercial purposes shall be reviewed by the director through either an antenna site plan review application or by the planning commission through a noncommercial amateur radio antenna permit application. a. Existing antenna assemblies which were legally permitted by the city or the county prior to city incorporation, and which conform to the codes in effect when installed, but do not meet the provisions of this code and are existing as of the effective date of this code shall be considered legal nonconforming. b. Antenna assembly height shall be measured as follows: i. The height of the antenna assembly shall include the antenna(s) support structure and shall be the maximum to which it is capable of being extended; ii. For a ground mounted assembly or one mounted on an accessory structure, the height shall be measured from the highest point of the existing grade covered by the foundation of the structure to the maximum height to which the antenna assembly is capable of being extended; and iii. Except for exempt antennas described in subsection (C)(3)(c)(ii) of this section, for an antenna assembly mounted on a main building, height shall be measured from existing grade to the maximum height to which the antenna assembly is capable of being extended, pursuant to the residential building height measurement methods described in Section 17.02.040 (View preservation and restoration) of this title. c. Noncommercial amateur radio antennas shall not be located within any front yard area, without approval of a variance pursuant to Chapter 17.64 (Variances) of this title. E-1 d. The use of antennas for noncommercial purposes shall mean that no commercial frequency is used for transmission or propagation, that there is no communication for hire or for material compensation, except as allowed by FCC regulations, and that all applicable regulations are complied with at all times, including, without limitation, FCC regulation 97. 3. Antennas Exempt. The following noncommercial amateur radio antenna assemblies may be constructed or installed on a lot without the approval of an antenna site plan review application or noncommercial radio antenna permit; a. The replacement of an existing antenna or antenna support structure with an outside diameter of three inches or less with a similar antenna or support structure. b. Parabolic dish antennas which are one meter (39.37 inches) or less in diameter. This exemption shall not apply to parabolic dishes located on a mast which is greater than twelve feet in height. Freestanding masts shall be measured from existing adjacent grade. Masts located on a building shall be measured from the point where the mast meets the roof surface. c. Any combination of two different antenna assemblies from the following categories: i. One antenna assembly which is located outside of any required setback areas and which is 16 feet or less in height, as measured pursuant to the residential building height measurement methods described in Section 17.02.040 (View preservation and restoration) of this title. ii. One building mounted antenna assembly which does not exceed twelve feet in height, as measured from the point where the antenna assembly meets the roof surface, and which contains radiating elements, each of which does not exceed six feet in total length. If the antenna assembly is mounted onto the roof, or if any portion of the antenna assembly projects above the roofline, not more than one antenna may be affixed to antenna support structure. iii. One wire antenna assembly consisting of a single flexible wire, with a diameter not to exceed one-half inch, suspended between two supports, which if man-made do not exceed forty-one feet in height as measured from adjacent existing grade, and having a transmission line connected to a receiver and/or a transmitter. iv. One vertical antenna assembly, located outside of any required setback areas, consisting of a single pole or mast with a maximum outside diameter of three inches or less with no guys or horizontal elements located higher than two feet above the ridgeline of the residence, and which does not exceed forty-one feet in total height, as measured from adjacent existing grade. 4. Antenna Site Plan Review Approval. E-2 a. Director review. Director approval of an antenna site plan review application is required for more than two antenna assemblies which are exempt pursuant to subsection (C)(3) of this section, and for any other nonexempt antenna assembly which does not exceed forty-one feet in height. The application may be approved provided the director finds as follows: i. That adequate provision is made for safety; ii. That all applicable building code requirements, such as wind load and seismic design criteria, and development code requirements, such setbacks, are met; iii. That no more than one nonexempt antenna support structure will be located on the lot; and iv. That the placement of the antenna assembly does not significantly impair a view from any surrounding properties, as defined in Section 17.02.040 (View preservation and restoration) of this title. b. Application. The antenna site plan review application shall be made upon forms provided by the city and shall be accompanied by the following: i. Two copies of a scaled site plan showing the location of the antenna assembly, and its relation to property lines, topography and all structures on the property, and two copies of an elevation drawing showing the proposed height, size, dimensions, color and material of the antenna(s) and antenna support structure. If a building permit is required pursuant to the Uniform Building Code, three copies of the above plans are necessary; ii. A typed mailing list of all property owners adjacent to the subject property, using the last equalized tax roll of the county assessor and any affected homeowners associations, and a vicinity map identifying all properties included on the mailing list. iii. A fee, as established by resolution of the city council. c. Notice. Upon receipt of a complete antenna site plan review application, the director shall provide written notice of the application to the applicant, adjacent property owners, any affected homeowners associations and any interested parties. No sooner than fifteen days after the application notices are mailed, the director shall make a decision on the application. Notice of the director's decision shall be provided to the applicant and any interested parties. The director's decision may be appealed to the planning commission and the planning commission's decision may be appealed to the city council pursuant to Chapter 17.80 (Hearing Notice and Appeal Procedures) of this title. D. Noncommercial Amateur Radio Antenna Permit. Except for antenna assemblies which are exempt pursuant to subsection (C)(3) of this section, antenna assemblies which exceed forty-one feet in height or which involve the placement of more than E-3 one nonexempt antenna support structure on a lot shall require the approval of a noncommercial amateur radio antenna permit by the planning commission. 1. Application. Application for a noncommercial amateur radio antenna permit shall be made on forms provided by the city and shall include such plans and documents as may reasonably be required by the director for a complete understanding of the proposal and a filing fee in an amount established by resolution of the city council. 2. Notice. Upon receipt of a complete application for a noncommercial amateur radio antenna permit, the director shall provide written notice of the application to all owners of a property shown on the last known county assessor tax roll and homeowner associations located within a radius of five hundred feet of the external boundaries of the property where the antenna assembly is proposed. 3. Action by Planning Commission. In granting a noncommercial amateur radio antenna permit, the planning commission shall consider: a. The extent to which the proposed antenna assembly significantly impairs a view, as defined in Section 17.02.040 of the development code, from a surrounding lot; b. With respect to an antenna assembly that is used for amateur radio purposes, the degree to which refusing or conditioning the permit would interfere with the applicant's ability to receive and/or transmit radio signals on amateur frequencies. In evaluating this criterion the planning commission may establish a maximum height for the antenna assembly that reasonably accommodates the applicant's ability to receive and/or transmit radio signals on amateur frequencies and appropriately balances that right with the goals of the city's general plan and development code; c. That adequate provision is made for safety and that all applicable building code requirements such as wind load and seismic design criteria, and development code requirements such as setbacks, are met; d. Appropriate conditions to minimize significant view impairment and to promote the goals of the general plan and development code, such as: i. Location restrictions, ii. Nesting restrictions, iii. Array size restrictions, iv. Mass of tower restrictions, v. Height restrictions, and vi. Elimination of guy wires. e. That the following additional findings can be made for approval of more than one nonexempt antenna assembly: i. The additional antenna assembly cannot be reasonably located on the existing antenna assembly; E-4 ii. The additional antenna assembly does not significantly impair a view from surrounding properties; and iii. The additional antenna assembly balances the effects on the character of the neighborhood while reasonably accommodating the radio amateur operator's ability to transmit and receive radio amateur signals. 4. If the application is granted or conditionally granted, notice of the planning commission's decision shall be given to the applicant and to all interested persons. Notice of denial shall be given only to the applicant. The applicant or any interested person may appeal the planning commission's decision to the city council pursuant to Chapter 17.80 (Hearing Notice and Appeal Procedures) of this title. 5. The noncommercial amateur radio antenna permit shall be valid only so long as all conditions imposed are fully complied with, and the antenna structure is maintained in good repair. E. Noncommercial Nondish Antennas. Building mounted television, FM radio, or any other similar noncommercial nondish antennas may be installed and/or replaced without approval provided the following standards are met: 1. A maximum of two antennas shall be allowed per lot; and 2. The maximum height of the antenna shall not exceed 12 feet, as measured from the point where the antenna meets the roof surface antennas which do not conform to the above standards shall require approval through a site plan review application pursuant to subsection (C)(4) of this section. (Ord. 374U § 1, 2002; Ord. 345 § 6, 1999: amended during 11-97 supplement; Ord. 320 § 7 (part), 1997: Ord. 226 §§ 12, 13 (part), 1988; Ord. 166 § 8 (part), 1983) (Ord. No. 529, § 35, 11-15-11) E-5 1 Jaehee Yoon From:Al and Kathy Edgerton <alnkathye@msn.com> Sent:Monday, September 28, 2020 11:12 AM To:Jaehee Yoon Subject:Draft Antenna Ordinance Hi Jaehee,    Below are a few questions and comments regarding the draft of the antenna code approved by  the Planning Commission last week.   The sections in the draft code addressing the Director‐level and Planning Commission  reviews of visual impacts of antenna assemblies are similar in that they generally refer  to the same parameters to be used for minimizing impacts (placement, screening,  camouflaging, painting, texturing, architectural materials, site‐specific characteristics,  etc.). However, the section discussing the Planning Commission review contains more  detail regarding how to apply the parameters. Please explain the reason for the  different wording in the two cases. Was there an intention to reflect a difference in the  level of discretion between the two levels of review? If the two reviews were intended  to be the same except for the height limitation, why were the exact same words not  repeated in both areas ‐ or why were the words not stated once, with both sections  (Director‐level and Planning Commission reviews) referring to the same language?  This issue is particularly significant since the height for review by the Planning  Commission was increased at the September 22nd meeting from 28 ft. to 41 ft. (back to  the current code threshold).   Do sections C.2.c (prohibiting antennas within front yard areas) and C.2.h (prohibiting  antenna assemblies within side or rear yard setbacks without City approval) apply to all  amateur radio antenna assemblies regardless of height ‐ i.e., including those less than  16 ft. in height?   Should the wording in section C.2.i be changed from "All antennas capable of being  retracted..." to "All antenna assemblies capable of being retracted..."? It is my  understanding that the tower on which an antenna is mounted is retractable, not the  antenna itself.   Similar to the previous comment, should the wording in section C.2.j be changed from  "Each noncommercial amateur radio antenna shall be of a color or painted to minimize  its reflectivity..." to "Each noncommercial amateur radio antenna assembly..." since the  same reflectivity issues likely apply to the antenna structure as well?   In sections C.4.a.v and D.3.d, should the last sentence read "The applicant shall use the  smallest and least visible antenna assemblies possible to accomplish the coverage  objectives, consistent with the first sentence of each of those sections?  F-1 2  In section C.4.b.vi, there appear to be four places where the word "assembly" should be  added following "antenna", as follows: "The applicant shall, as part of the application,  construct at the applicant's expense, a mock‐up of the proposed antenna assembly at  the proposed location. Said mock‐up shall be the same size and dimensions as the  proposed antenna assembly. The mock‐up shall be coordinated under the direction of  the Director or his/her designee. Once constructed, the silhouette shall be certified by a  licensed engineer on a form provided by the City. In the alternative, the applicant may  submit a photo simulation depicting the proposed antenna assembly in size, height, and  dimensions, as required by the City to depict the proposed antenna assembly as it  would appear from the surrounding area.   In section C.4.b vi, the requirement for a certification by a licensed engineer should  apply to a photo simulation as well as a mock‐up. In addition, the wording should be  clarified to require photo simulations from multiple views to allow assessment of all  visual impacts.   Kathy Edgerton    F-2