Preliminary RF Review

Town-supplied application forms;

Project description;

Applicable legal standards;

Proof of the Project’s compliance with the applicable site plan and special permit review requirements set forth in § § 130-8 through 13013 of the Code;

Proof of the Project’s compliance with the applicable area variance review requirements set forth in § 130-24 of the Code;

Radio frequency search ring justification (“RF Justification”), with propagation studies setting forth the need for the Project;

Site selection analysis;

Long environmental assessment form (“Long EAF”), with visual addendum;

Verizon’s co-location policy;

Proof of the Landowner’s consent to this Application;

Photosimulation report;

Structural design letter;

Tower removal letter and removal cost estimate;

Verizon’s FCC licenses for Monroe County;

Proof of compliance with applicable Federal regulations regarding RF emissions; and

11ʺ x 17ʺ copy of the site plan.

Technical Basis for Findings

Technical Basis for Findings 1. The RF coverage threshold levels upon which the proposed site is designed are reasonable values and are consistent with threshold levels used by Applicant in similar sites in this region. Applicant’s RF Justification (Exhibit F) identifies the propagation-map thresholds used to evaluate service conditions, including -85 dBm RSRP for suburban singlefamily residential/light-commercial service, -95 dBm RSRP for rural/suburbanresidential and in-vehicle applications, and -105 dBm RSRP as the lower threshold for rural highway/variable service, with areas below -105 dBm RSRP treated as variable-to-unreliable/no reliable coverage. Those threshold levels are reasonable for planning-level 4G LTE/5G propagation review and are consistent with the types of low-band and mid-band RF design thresholds commonly used in Verizon applications in this region. Exhibit F uses these thresholds consistently in its existing and proposed low-band and mid-band coverage plots, allowing meaningful comparison of pre- and post-project service conditions. 2. Based on the RF coverage threshold levels and the need to off-load traffic from certain neighbor sites, Applicant has demonstrated need4 to remedy a significant RF coverage service gap and add additional traffic capacity to offload traffic from neighbor base station sites by deployment of a new base station facility or other solution in the general area of the proposed project site. The proposed Webster North site appears to improve both low-band and midband coverage and should fill portions of the identified service area. However, some gaps appear to remain, particularly in mid-band coverage to the north/northwest. The “Holt & Lake (Future SC)” site may be intended to address some of these remaining gaps, but that should not be assumed without confirmation. Because the Holt & Lake site may affect the need, siting, and/or minimum-height analysis for the proposed “Webster North” site, we recommend that Applicant provide detailed information regarding its planned location, status, timing, height, antenna configuration, frequency bands, and RF objectives. Applicant’s RF materials identify the Webster North area as being served by three relatively distant Verizon sites — Webster, Four Mile Creek, and Webster Park — and state that those sites are overloaded or unable to adequately serve the project area because of distance, terrain, foliage, and weak/variable RF conditions. Exhibit F further explains that the project objective is to create a new dominant server in the Webster North area to improve coverage and off-load traffic from those neighboring sites. The low-band and mid-band propagation plots indicate that the proposed facility would improve service in portions of the target area; however, the 4

Technical Basis for Findings mid-band plots also appear to show remaining weak or gap areas to the north/northwest. Exhibit F also labels “Holt & Lake (Future SC),” but does not provide its location, timing, configuration, frequency bands, or RF objective. Because that future site may affect the need, siting, or minimum-height analysis for Webster North, additional information regarding Holt & Lake is reasonably necessary for a complete review. 3. In this case, in our opinion, the evidence presented in the RF propagation plots demonstrates that (1) the proposed facility would materially remedy a significant service gap in the vicinity of the proposed site; and (2) comparison of the existing and proposed best-server propagation plots, together with the capacity information provided, supports the conclusion that the proposed facility would provide meaningful capacity relief to Applicant’s network, thereby supporting a valid need for the proposed facility. The capacity slides in Exhibit F, pages 7 through 9, indicate that certain neighboring Verizon sectors are experiencing capacity stress or exhaustion. These materials suggest that users in the Webster North area are presently being served, at least in part, by more distant low-band sectors under comparatively poor RF conditions. Such users can consume disproportionate network resources, increase loading on the serving sectors, and reduce available capacity for other users. The proposed Webster North site would create a closer dominant server in the target area and appears likely to off-load traffic from certain existing Verizon sectors. Based on the best-server plots in Exhibit F, pages 12 and 13 (low-band) and 16 and 17 (mid-band), the proposed Webster North facility is likely to provide meaningful off-load to the existing Webster and Four Mile Creek sites, but substantially less direct off-load to Webster Park. The identified “Holt & Lake (Future SC)” site may be relevant to service in the Webster Park/northwestern portion of the study area. Therefore, we recommend that Applicant provide detailed information regarding its planned location, status, timing, height, antenna configuration, frequency bands, and RF objectives. 4. Two presentation issues in Exhibit F should also be corrected or supplemented. First, the ASEU plot for Four Mile Creek – Beta (page 8) is difficult to interpret because the y-axis is scaled from 0 to approximately 4500% due to an apparent spike in network traffic around October/November 2025. We recommend that Applicant provide this plot rescaled to a maximum of approximately 200%, or otherwise provide the underlying data, to allow meaningful review of the ordinary loading conditions. Second, the legends and color schemes for Exhibit F pages 16 and 17 appear to be incorrect and are inconsistent with the other best-server plots. Therefore, we recommend that these be corrected, using the same format and labeling conventions as Exhibit F pages 12 and 13. Exhibit F relies on capacity-utilization plots and best-server propagation plots to support the capacity-relief and off-load justification for the proposed site. Because these figures are intended to show ordinary sector loading and predicted off-load patterns, they should be legible and internally consistent. The Four Mile Creek – Beta capacity slide presents ASEU utilization with an unusually large vertical scale Page 8 of 13

Technical Basis for Findings caused by an apparent traffic spike, making the day-to-day loading conditions difficult to review. Similarly, the mid-band best-server plots on Exhibit F pages 16 and 17 should use consistent legend and color conventions so they can be directly compared with the low-band best-server plots on pages 12 and 13. Without corrected scaling or underlying data, and without corrected legends, it is more challenging to reliably interpret the magnitude of the claimed loading or the predicted distribution of off-load from the proposed Webster North facility. 5. Base station antennas must be elevated to allow efficient RF propagation and achieve the proposed RF coverage and capacity relief to neighboring cells. Applicant has provided propagation plots indicating planned and existing lowband and mid-band coverage at the proposed 130’ ACL (Exhibit F, pages 12 through 19). However, Applicant has not included propagation plots indicating the level of coverage degradation at reduced antenna heights. In order to better evaluate the claimed coverage need and projected capacity relief associated with the proposed facility, we recommend that Applicant submit additional low-band and mid-band RF propagation plots, including Best Server plots at reduced antenna heights of approximately 91 feet ACL (estimated code compliant with § 130-10 , Height, Chapter 130, Article II, Communications Towers) and an intermediate ACL of 111 feet. Specifically, Applicant should provide a complete set of propagation plots materially similar in format and scope to those provided in Exhibit F, pages 12 through 19, but prepared at the lower antenna centerline heights discussed above. Each plot should use the same geographic scale, signal thresholds, color scheme, and legend conventions as the original Exhibit F plots, so that the Town can directly compare the RF consequences of a code-compliant or lesser-variance design against the proposed 130-foot ACL design. Applicant’s RF Justification uses the proposed 130-foot ACL as the basis for the low-band and mid-band coverage and best-server plots in Exhibit F, and states that this height is the “minimum height necessary” to provide the proposed coverage and capacity improvements. However, Webster Code § 130-10 limits communications towers to 100 feet total height, including antennas, extensions, and other devices above the tower structure, and Applicant’s proposed 135-foot tower with 4-foot lightning rod therefore requires height-variance relief. Because the submitted materials do not show how coverage, best-server dominance, or capacity off-load would change at lower antenna centerlines, the record does not yet demonstrate whether a code-compliant or lesser-variance design would fail to meet Applicant’s stated RF objectives. Reduced-height propagation plots using the same scale, thresholds, and legend conventions as Exhibit F pages 12–19 are therefore reasonably necessary to evaluate minimum height, minimum variance, and whether the proposed 130-foot ACL is technically justified. 6. Deployment of cellular base stations can be affected by developing plans for neighboring sites. As a matter of course, we recommend that Applicant discuss with the Board whether any neighbor site deployments are at or near a point where they may allow height reduction of the proposed tower.

Technical Basis for Findings §130-12A (10) requires Applicant to submit “A grid or map of all of the owner's/applicant's existing communications tower site areas in the Town of Webster and site areas proposed or projected by the owner/applicant for installations for a period of two years.” Two future sites are indicated in Applicant’s Exhibit F propagation plots: Holt and Lake (Future SC) and Lake Rd (Future). The Lake Rd site application has been submitted to the Town and is currently under review. The proposed Lake Road site is approximately 3.5 miles from the proposed Webster North site. At this separation, the two sites would generally be expected to serve different primary coverage and capacity objectives, and no major direct interaction with the Webster North target area is expected. However, the Holt and Lake (Future SC) site appears to be approximately 1.4 miles from the proposed Webster North site. Given the relatively short separation between the sites and depending on the intervening terrain, this site may affect coverage and capacity in the vicinity of the proposed Webster North site, primarily in the low-bands. Therefore, we recommend that Applicant provide detailed information regarding the planned location, status, timing, height, antenna configuration, and RF objectives for the Holt & Lake (Future SC) site. 7. Applicant’s Exhibit G indicates that eleven (11) parcels, including the proposed site identified as candidate site (C), were considered by Applicant. One parcel was rejected after the Town declined to lease the site, candidate site (A) located at 1209 Creekside Trail. One parcel, candidate site (B) was rejected due to parkland/wetland issues and likely difficulty obtaining the necessary approvals for non-park use. Four parcels, candidate sites (D) through (G) were rejected because the owners were not interested. Four additional parcels, candidate sites (H) through (K) were rejected by RF because they were outside the search area and would not adequately meet Verizon’s needs for this project. Based on the materials submitted, the Board has been presented with only one site identified by Applicant as both technically viable and available for lease. At this point the Board has not been provided with any other feasible location or technological alternatives. If the Holt & Lake (Future SC) site is actually planned and expected to be on-air within the relevant planning period, its operation could affect the RF need and alternate-site analysis for Webster North. In this circumstance, one or more sites rejected by RF because they were outside the Webster North search area may warrant further review as potential alternates, particularly if the Town has concerns with the proposed Wildflower Drive site. For example, Sites H, J, and K appear to be near or just outside the search area and may merit additional explanation. We are not concluding that any of these sites is viable. Rather, if Holt & Lake is part of Verizon’s two-year network plan, then the rejection of these RF-screened alternate sites should be supported with site-specific RF evidence showing why they would not meet Applicant’s coverage and capacity objectives when considered together with the planned Holt & Lake facility. Therefore, we recommend that Applicant provide detailed information regarding the planned location, status, Page 10 of 13

Technical Basis for Findings timing, height, antenna configuration, and RF objectives for the Holt & Lake (Future SC) site. 8. Regarding feasible alternative sites, during site review, municipal staff recommendations and public comments may identify other potential alternative site locations that have not been explicitly considered by Applicant. Local residents and municipal staff often have insights into such locations that come from their familiarity with the area and their knowledge of community values. We recommend Applicant perform an RF analysis for any additional nearby sites identified by municipal staff and others that have potential for improved visual impact. Exhibit G states that Verizon identified candidate sites through its search-area and site-acquisition process, and that eleven parcels were reviewed in or immediately outside the Webster North search area. That process may not capture all potentially relevant sites known to Town staff or nearby residents. Because local review can identify additional properties, structures, municipal lands, or lower-impact locations not expressly evaluated in the application, any such site that appears potentially feasible should be screened by Applicant’s RF engineer. Applicant’s own materials recognize that search-area development depends on topography, user density, and existing network conditions, and that RF Engineering reviews potential co-locatable structures in or near the search area before new towers are proposed. Exhibit G also states that no suitable existing towers or tall structures were found and that eleven parcels were considered, but it does not provide RF plots for alternative sites. Therefore, if municipal staff or public comments identify additional nearby sites with potentially reduced visual impact, site-specific RF analysis would help determine whether those alternatives can meet Applicant’s coverage and capacity objectives while reducing community impact. 9. The proposed tower is 135’ tall (139’ with lightning rod). Structures that exceed 199’ generally require FAA marking and lighting. Shorter structures near controlled airspace may also require FAA marking and lighting. Determination of marking/lighting requirements are made using findings of an airspace study. For this Application, Applicant has not provided an FAA filing or determination confirming whether FAA marking and lighting is or is not required for the proposed Webster North tower. Accordingly, we recommend Applicant provide an FAA aeronautical filing and determination for the proposed facility, together with confirmation as to whether marking and/or lighting is required. The proposed Webster North structure is described as a 135-foot monopole with an additional 4-foot lightning rod, for a highest appurtenance height of approximately 139 feet AGL. Webster’s code states that towers should be designed and sited to avoid FAA lighting and painting requirements where possible, and that towers shall not be artificially lighted except as required by the FAA. The site plan (Exhibit P) states that FAA obstruction lighting is not proposed unless required by the FAA or the local municipality, but the application materials reviewed do not include an FAA filing, Notice Criteria Tool result, or FAA determination. FAA notice is generally required for structures exceeding Page 11 of 13

Technical Basis for Findings 200 feet AGL, but shorter structures may also require notice depending on proximity to airports and applicable Part 77 surfaces; the FAA provides an online Notice Criteria Tool to determine whether filing is required. Accordingly, an FAA filing/determination or FAA notice-criteria result is reasonably necessary to confirm whether marking or lighting is required for this specific site. 10. FCC regulations5 require Applicant perform a preliminary analysis to ascertain whether or not it is likely the proposed site will expose members of the “General Population”6 to excessive electromagnetic energy. Applicant has provided a Site Compliance Report (Exhibit O) dated February 01, 2026 generated by Mamta Verma, Circet USA that indicates the proposed site will not exceed the FCC General Population limits. This exhibit provides an analysis of the Applicant’s proposed tower's compliance with Federal Communications Commission (FCC) guidelines for radio frequency (RF) exposure. The report confirms that the tower's operation will not expose the general public to hazardous levels of RF energy, remaining well below the FCC's Maximum Permissible Exposure (MPE) limits. Specifically, the maximum predicted power density at ground level from all Applicant’s operations at this site is less than 1% of the FCC's General Population limits. This is a small fraction of the allowable exposure, meaning the RF emissions from the site are far below any hazardous thresholds. 11. If the proposed site is ultimately approved it, like the existing neighbor sites currently in operation, will serve as a fixed area of coverage to which future neighbor sites must connect. Applicant’s RF materials explain that the Webster North area is currently served by more distant Verizon sites and that a new dominant server is needed to improve coverage and off-load weak and distant traffic from the existing Webster, Four Mile Creek, and Webster Park sites. Once placed in service, the Webster North facility would become part of Verizon’s surrounding network geometry and would itself define a new serving area that future neighboring sites would need to account for. Applicant’s search-area discussion also recognizes that existing network conditions guide new-site design, and that sites placed too close together, too tall, or not properly integrated with existing sites can create interference and degrade service for existing users. Accordingly, if approved and constructed, Webster North should be treated as an established neighboring cell site for purposes of future Verizon site planning, capacity off-load analysis, and alternate-site review.

Technical Basis for Findings 12. If the proposed site is ultimately approved, it will meet the FCC requirements in 47 C.F.R. §1.6100 as an “Existing” structure. Modifications of “Existing” structures that fall outside of that section’s definition of “Substantial Change” are subject to mandatory local approval. We recommend that review of this proposed site consider the possibility that such a request will come before the Town in the future as a co-location request by another wireless service provider or modification to improve Applicant’s service levels. If the proposed site is ultimately approved and constructed, it will become an “existing” tower and eligible support structure for purposes of 47 C.F.R. §1.6100. Future requests for collocation, replacement, or modification of transmission equipment that do not constitute a “substantial change” are subject to mandatory local approval under federal law. For towers outside the public right-of-way, certain height increases may qualify for this treatment, including increases not exceeding 10% or the height of one additional antenna array with allowable separation, whichever is greater. Accordingly, review of the proposed facility should recognize that future collocation or modification requests may come before the Town under a more limited federal review framework than the present new-tower application. 13. Wireless networks consist of individual cells that function as a whole. Approval of any one particular site should consider the future need for additional neighbor sites and the locations of those sites. A new tower in a more controversial area may be required to address the remaining coverage gaps, extend the coverage area, off-load traffic from future saturated sectors, and properly integrate the currently-proposed site into the larger network. Applicant’s project description explains that each cell site serves a limited geographic area, that cells must overlap to provide uninterrupted service, and that a wireless provider must place each cell site to provide service within a particular cell while also overlapping, but not duplicating, existing or planned surrounding cells. Exhibit F similarly explains that search-area development depends in part on existing network conditions, and that sites placed too close together, too tall, or not properly integrated with existing sites can create interference and degrade service for existing users. The Webster North proposal is therefore not an isolated facility; if approved, it becomes part of the surrounding Verizon network and may affect the technical need, siting, and minimum height of future neighboring facilities.