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;

Ag data statement;

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

11ʺ x 17ʺ copy of the site plan.

Candidate H and Candidate I location with respect to the search ring;

Landowner’s letter explaining the unavailability of candidate H and Candidate I;

RF review of potential search ring expansion

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. Exhibit F evaluates predicted wireless coverage using Reference Signal Received Power (“RSRP”) thresholds of approximately −75, −85, −95, and −105 dBm. Applicant generally associates these levels with progressively weaker service conditions: approximately −75 dBm for strong service in dense or substantial building environments; −85 dBm for suburban residential and light-commercial areas; −95 dBm for rural, suburban, and in-vehicle service; and −105 dBm for weak rural or highway coverage that may be more susceptible to fading, foliage, building penetration loss, and seasonal variation. Areas below approximately −105 dBm are identified as having variable or unreliable service. These thresholds are reasonable for comparative RF-planning purposes and are consistent with values Applicant has used in other recent Verizon applications in the region. They provide a practical basis for comparing existing and proposed lowband and mid-band coverage and for identifying areas where signal levels may be insufficient to support reliable service under typical environmental and clutter conditions. RSRP is only one indicator of network performance and does not, by itself, establish that a particular area has adequate or inadequate service. Actual performance also depends on signal quality and interference, available bandwidth, sector loading, uplink conditions, antenna configuration, building and foliage attenuation, device capability, and short-term fading. Subject to those limitations, the RSRP thresholds used by Applicant are technically reasonable and appropriate for evaluating the relative coverage effects of the proposed Lake Road facility. 2. Applicant has demonstrated a credible need for capacity relief in the Lake Road service area. The capacity-utilization information in Exhibit F indicates that the low-band sectors at East Webster–Alpha, Ginna–Gamma, and, to a lesser extent, Four Mile Creek–Alpha are experiencing elevated utilization, with Forward Data Volume (“FDV”) being the metric most frequently reaching or exceeding Applicant’s stated capacity threshold. The materials further indicate that weak or inconsistent mid-band coverage limits the ability of the existing network to offload traffic from the more heavily utilized lowband layers. Accordingly, the proposed Lake Road facility appears likely to create a new dominant server and provide meaningful capacity relief to the surrounding sectors. However, the submitted capacity plots are scanned, faint, and difficult to interpret reliably, particularly with respect to dates, axes, and trace values. We recommend that Applicant provide Exhibit F in native or high-resolution PDF format, together with clearly legible capacity plots (currently Exhibit F pages 7 through 9) and, preferably, the supporting numerical data necessary to verify the extent of the claimed capacity deficiency and anticipated offload.

Technical Basis for Findings Exhibit F presents capacity-utilization information for the Four Mile Creek–Alpha, East Webster–Alpha, and Ginna–Gamma sectors, which Applicant identifies as the principal existing sectors serving the Lake Road project area. For each sector, Applicant provides three capacity indicators—Forward Data Volume (“FDV”), Average Schedule Eligible User (“ASEU”), and Average Active Connections (“AvgAC”)—with separate traces for low-band and mid-band LTE carriers. The plots appear to show the daily maximum busy-hour utilization relative to a dashed 100-percent threshold that Applicant identifies as the point at which the applicable capacity resource reaches exhaustion and service begins to degrade materially. Applicant describes FDV as a measure of the customer data traffic carried by the sector. As FDV approaches the established capacity limit, the available radio resources must be shared among an increasing volume of traffic, which can reduce user data rates and increase the likelihood of delayed, interrupted, or unreliable data sessions during busy periods. ASEU reflects loading of scheduling and controlchannel resources and may be increased by users located at greater distances or operating under poor RF conditions, because those users generally require additional scheduling resources and repeated or more robust transmissions. AvgAC represents active device connections relative to the sector’s connection-handling capability; reaching that limit can result in connection failures or dropped sessions. Of the three submitted metrics, FDV is the one most frequently shown approaching or crossing Applicant’s stated threshold. Although the precise frequency and magnitude of the threshold exceedances cannot be reliably determined from the supplied copies, the plots appear to show repeated low-band FDV exhaustion at East Webster–Alpha and Ginna–Gamma, with less frequent or less sustained elevated utilization at Four Mile Creek–Alpha. The midband traces generally appear less heavily utilized. This does not necessarily mean that adequate mid-band capacity is effectively available throughout the Lake Road area. Rather, the propagation materials indicate that the existing mid-band signals from the surrounding sites are weak, inconsistent, or absent over portions of the project area. Applicant specifically states that distance, terrain, foliage, and building losses prevent the existing mid-band carriers from effectively serving and offloading the Lake Road area. This relationship between low-band loading and mid-band coverage is technically significant. Lower-frequency 700 and 850 MHz signals generally propagate farther and penetrate buildings more effectively than PCS, AWS, and C-Band signals. Users may therefore remain connected to the low-band layers even where the more capacity-intensive mid-band carriers are unavailable or too weak to provide effective traffic transfer or carrier aggregation. Because the low-band carriers ordinarily have less available bandwidth than the combined mid-band resources, concentrating users and traffic on the low-band layer can produce FDV exhaustion even when the more distant mid-band sectors show relatively low measured utilization. In this circumstance, low mid-band utilization may reflect inadequate mid-band reach rather than an absence of demand.

Technical Basis for Findings Applicant’s existing best-server plots show the Lake Road project area being served irregularly by portions of several distant sector footprints, without a single clearly dominant serving sector. The proposed best-server plots add a substantial Lake Road low-band and mid-band footprint at a 120-foot ACL in the area presently served by Four Mile Creek–Alpha, East Webster–Alpha, and Ginna–Gamma. A closer dominant server would ordinarily cause compatible devices within that footprint to select or be directed to the new Lake Road facility, transferring traffic away from the more distant existing sectors. The proposed site would also introduce stronger local mid-band service, improving the opportunity for higher-capacity carrier use and carrier aggregation. The best-server comparisons therefore support the conclusion that the proposed facility would provide meaningful offload, although the application does not quantify the projected post-construction reduction in FDV, ASEU, or AvgAC at the affected sectors. The submitted capacity information is sufficient to establish a credible capacityrelief need, but it is not sufficiently legible to independently determine the exact date range, number and duration of threshold exceedances, numerical trace values, or trends in demand. A native or high-resolution version of Exhibit F, together with the underlying numerical data, would permit verification of the present loading conditions and a more complete evaluation of the expected benefit of the Lake Road facility 3. The submitted propagation materials in Exhibit F do not clearly demonstrate a significant low-band coverage gap in the vicinity of the proposed site. Existing low-band service appears to be generally available throughout much of the project area, although at varying signal levels. Mid-band coverage appears weaker and more variable, with areas of weak or absent service that may contribute to the identified capacity problem by reducing effective traffic offload and carrier aggregation. However, the existing and proposed low-band and mid-band propagation plots are difficult to evaluate because Exhibit F appears to be a scanned reproduction, and the −105 dBm signal-level category—normally represented by orange—is missing or unreadable on the coverage plots. We recommend Applicant provide native or high-resolution propagation plots (currently Exhibit F, pages 14, 15, 18 and 19) clearly showing all signal-level categories, including −105 dBm, together with clearly legible roads, site labels, legends, and map boundaries, so that the extent and significance of any low-band or mid-band coverage deficiency can be independently evaluated. Exhibit F presents separate existing and proposed propagation maps for Verizon’s low-band 700/850 MHz service and mid-band AWS, PCS, and C-Band services. The existing low-band map shows predicted service throughout most of the Lake Road project area, although at varying signal levels. It does not clearly show a broad, continuous area near the proposed site where low-band service is absent. The proposed low-band map primarily appears to strengthen existing service and create a closer dominant server, rather than fill a clearly defined, substantial lowband coverage gap.

Technical Basis for Findings The existing mid-band map shows a materially weaker and less continuous coverage pattern. This is technically reasonable because higher-frequency midband signals generally experience greater propagation, foliage, and buildingpenetration losses than 700/850 MHz signals. Where mid-band service is weak or unavailable, users’ equipment may remain connected to the lower-capacity lowband layer instead of transferring traffic to, or aggregating with, the higher-capacity mid-band carriers. The proposed facility appears likely to improve mid-band availability and support traffic offload, although the exact extent of the existing deficiency cannot be verified from the submitted plots. The principal limitation is the quality of Exhibit F. Road names, site labels, map boundaries, and portions of the legends are faint, and the −105 dBm category— apparently intended to be shown in orange—cannot be reliably distinguished from the other map layers. Without a legible −105 dBm category, it is difficult to determine whether an area is predicted to receive weak service, service below Applicant’s lowest displayed threshold, or no modeled service. Native or highresolution plots are therefore needed to independently determine the geographic extent and significance of any low-band or mid-band coverage deficiency. 4. Based on the present record, the proposed facility appears likely to materially improve wireless service in the Lake Road area by creating a new dominant serving site, improving mid-band availability, and providing meaningful capacity relief to the surrounding Verizon sectors. Comparison of the existing and proposed best-server plots, considered together with the capacityutilization information, supports a preliminary conclusion that the facility would address identified network deficiencies and that a valid technical need for an additional site exists. The present materials may also indicate that the proposed facility would remedy portions of an existing service gap; however, the extent and significance of that coverage deficiency cannot be verified from the submitted plots because of their limited legibility and the missing or unreadable −105 dBm signal-level information. Accordingly, we recommend that our final conclusion regarding the precise coverage gap and the extent to which the proposed facility would remedy that gap be deferred until Applicant provides the requested legible capacity data and complete propagation plots requested in Finding 2 and Finding 3. Exhibit F includes existing and proposed best-server plots for both low-band and mid-band service. A best-server plot identifies the sector predicted to provide the strongest usable signal at each location at the selected threshold, rather than merely showing overlapping coverage from every surrounding site. The existing plots indicate that the Lake Road area is served irregularly by portions of the Four Mile Creek–Alpha, East Webster–Alpha, Ginna–Gamma, and other surrounding sector footprints, without a consistently dominant local serving site. The proposed plots add a substantial Lake Road footprint at the proposed 120-foot antenna centerline, indicating that the new facility would become the strongest predicted server over a meaningful portion of the project area. P a g e 11 | 21

Technical Basis for Findings A closer dominant server would generally cause compatible devices in that footprint to connect to, or be directed toward, the Lake Road facility rather than the more distant existing sectors. This would transfer traffic away from the existing low-band sectors and introduce stronger local mid-band service, improving the opportunity for use of PCS, AWS, and C-Band resources and carrier aggregation. When considered together with the elevated low-band capacity-utilization information in Exhibit F, particularly the FDV results, the best-server comparisons support the conclusion that the proposed facility would provide meaningful capacity relief and improve network performance. The application does not quantify the expected post-construction reduction in loading at each surrounding sector, but the predicted change in dominant-server footprint provides a technically reasonable basis for concluding that an additional site is justified. The propagation plots also suggest that the proposed facility would strengthen lowband service and extend more reliable mid-band service into areas currently shown as weak, variable, or unserved. However, the plots do not permit a precise determination of the geographic extent or significance of an existing coverage gap. The reproduced maps are faint, and the approximately −105 dBm category cannot be reliably distinguished from areas below the lowest displayed threshold or from areas having no modeled service. The record therefore supports a preliminary conclusion that the proposed facility would materially improve service and provide needed capacity relief, but a final conclusion regarding the precise coverage gap and the extent to which the facility would remedy it should await the clearer capacity and propagation information requested in Findings 2 and 3. 5. Base-station antennas must be elevated sufficiently to provide reliable RF propagation and achieve the intended capacity relief without creating unnecessary coverage overlap or requiring more height than is technically justified. Applicant proposes Verizon antennas at 120 feet ACL and, in the February 26, 2026 supplemental submission, compared that configuration with a reduced 95-foot ACL configuration using 700 MHz low-band coverage and best-server information. Exhibit R indicates that the lower-ACL configuration would reduce the proposed site’s dominant-server footprint, but the analysis does not identify the specific roads, residences, businesses, public facilities, or other service “focus areas” that would become inadequately served at 95 feet ACL, nor does it explain why those losses are material to the stated service objective. The comparison also does not evaluate mid-band coverage, which Applicant identifies as important to relieving low-band congestion, or quantify the capacity offload expected at either height. Accordingly, we recommend Applicant supplement the height analysis by identifying the specific non-negotiable coverage and capacity objectives or focus areas that the facility must serve and provide legible low-band and midband coverage, best-server, and capacity-offload comparisons for the proposed 120-foot ACL and the alternate, lower-height 95-foot ACL configuration. The additional analysis should explain quantitatively why the reduced-height configuration would not adequately meet those defined objectives, rather than relying solely on the fact that the overall coverage P a g e 12 | 21

Technical Basis for Findings footprint becomes smaller as a reduced footprint that, by itself, does not establish that the lower antenna height is technically inadequate. Antenna centerline height affects both the strength and geographic extent of a base station’s signal. Increasing antenna height generally improves clearance above terrain, vegetation, and buildings, reducing obstruction losses and allowing the site to become the dominant server over a larger area. A lower antenna height may reduce that footprint and the number of users transferred from surrounding sectors. However, the technically appropriate height is not necessarily the height that produces the largest coverage area; it is the lowest height that reliably serves the locations and provides the capacity offload necessary to meet the defined network objective without creating excessive overlap or interference. Applicant proposes Verizon’s antennas at 120 feet ACL. Exhibit R compares that configuration with a lower 95-foot ACL configuration using 700 MHz low-band coverage and best-server plots. The comparison shows that the 95-foot configuration would produce a smaller dominant-server footprint, particularly near the outer portions of the modeled service area. It does not, however, identify which lost portions correspond to essential roads, residences, businesses, public facilities, or other locations that Applicant considers necessary to serve. Without defined coverage or capacity focus areas, a smaller footprint does not establish that the lower configuration would fail to accomplish the principal purpose of the site. The height comparison is also limited to 700 MHz low-band propagation. Exhibit F identifies inadequate mid-band availability as an important contributor to the loading of the existing low-band sectors, and the proposed 120-foot mid-band bestserver plot shows the Lake Road facility becoming the dominant server over a meaningful portion of the project area. Because PCS, AWS, and C-Band signals are more affected by distance, foliage, and obstructions than 700 MHz signals, midband performance may be more sensitive to antenna height and should be included in the comparison. Applicant also does not quantify the traffic expected to be transferred from Four Mile Creek–Alpha, East Webster–Alpha, and Ginna–Gamma at either height. Low- and mid-band coverage, best-server, and ideally, projected capacity-offload comparisons tied to clearly identified service objectives are therefore needed to determine whether 120 feet ACL is technically necessary or whether the lower configuration could adequately satisfy the site’s intended purpose. 6. §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.” Applicant’s response in Exhibit D refers to Exhibit F; however, Exhibit F identifies only the surrounding sites relevant to the Lake Road RF analysis, including Four Mile Creek, East Webster, Ginna, and Dean Parkway. It does not clearly identify all existing Verizon sites within the Town, and it does not identify any approved, pending, proposed, or projected Verizon installations for the required two-year period—or affirmatively state that none are planned.

Technical Basis for Findings Accordingly, we recommend Applicant submit a complete Town-wide grid or map identifying all existing Verizon communications tower site areas in the Town of Webster and all site areas proposed or projected for installation during the following two years. Section 130-12A(10) requires two distinct categories of information: (1) all of Applicant’s existing communications-tower site areas within the Town of Webster, and (2) site areas that Applicant proposes or projects for installation during the following two years. The provision calls for a grid or map, indicating that the information should be presented on a Town-wide geographic basis rather than limited to the immediate RF study area for the pending application. In Exhibit D, Applicant cites Exhibit F as its response to this requirement. Exhibit F, however, is an engineering-necessity analysis prepared specifically for the Lake Road project. Its maps identify Four Mile Creek, East Webster, Ginna, and Dean Parkway because those neighboring facilities are relevant to the existing coverage, best-server, and capacity analyses. The maps do not state that they constitute a complete inventory of every Verizon site area within the Town, and some identified facilities may be outside the Town but included because their signals serve portions of the project area. Exhibit F also does not provide a separate list or map of approved, pending, proposed, or projected Verizon installations for the required two-year period, nor does it affirmatively state that no additional installations are planned. A complete two-year deployment map is relevant to the technical review because planned facilities or substantial modifications to neighboring sites may alter the coverage and capacity burden assigned to Lake Road. Depending on location, timing, height, spectrum, and antenna configuration, another deployment could affect the need for the proposed site, its required dominant-server footprint, its interaction with surrounding sectors, the minimum antenna height, or the feasibility of alternative locations. The present project-specific maps therefore do not provide enough information to determine whether Lake Road is being evaluated within Applicant’s complete near-term network plan for the Town. 7. Since the deployment of cellular base stations can be affected by developing plans for neighboring sites and 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. One potential example of such a site is the “Holt and Lake (Future SC)” site shown in Exhibit F, pages 12 through 19 of the “Webster North” site application materials submitted on March 10, 2026. These materials are not part of Applicant’s Lake Road submission. The required height and service footprint of a cellular base station are determined in relation to the surrounding network rather than in isolation. Exhibit F assigns the proposed Lake Road facility the combined objectives of creating a new dominant server, improving mid-band service, and offloading traffic from Four Mile Creek– Alpha, East Webster–Alpha, and Ginna–Gamma. The proposed 120-foot antenna centerline is therefore based on the coverage and capacity conditions assumed to exist when the RF analysis was prepared. P a g e 14 | 21

Technical Basis for Findings A new neighboring site, or a material modification to an existing site—such as added spectrum, increased antenna height, changed antenna patterns or downtilt, or additional sector capacity—could alter those assumptions. Such a deployment might serve part of the Lake Road project area, reduce the amount of traffic the proposed facility must offload, or change the desired best-server boundary and overlap with surrounding cells. Under those circumstances, Lake Road might not need as large a dominant-server footprint, and a lower antenna height could potentially satisfy the remaining coverage and capacity objectives. Conversely, a neighboring deployment may have little effect if it does not serve the same geographic area or capacity demand. The application does not identify whether any nearby Verizon facilities are approved, pending, proposed, or sufficiently advanced in planning to affect the Lake Road design. The recommended discussion is therefore intended to determine whether such deployments exist and, if so, whether they were incorporated into Applicant’s height analysis. Any relevant deployment should be evaluated by location, anticipated construction date, antenna height and configuration, spectrum, predicted coverage, and expected capacity contribution before concluding that it would permit a reduction in the proposed tower height. 8. Applicant’s Exhibit G indicates that seven (7) parcels, including the proposed site identified as Candidate A, were considered by Applicant. Four candidates—C, D, E, and G—were rejected at least in part because “Multiple attempts to engage the property owner resulted in no interest” although additional site-specific constraints such as wetlands, tree removal, parcel size, or setbacks were also cited. However, “Multiple attempts to engage the property owner resulted in no interest” is not necessarily the same as an affirmative rejection. Candidate F was rejected because the owner expressly declined. Candidate B was rejected because the owner would consider only a non-farmland location, and Verizon concluded that no suitable non-farmland location existed on that parcel. According to Applicant’s supplemental materials dated March 31, 2026, the Planning Board proposed Candidates H and I during the March 3, 2026 Planning Board Meeting, bringing the total number of documented locations considered to nine (9). Both are under the same Windmill Farms ownership as the selected site. The landowner submitted a detailed letter explaining why neither location was available (Exhibit T). Verizon also asserts that Candidate H would interfere with the neighboring cell to the west and that Candidate I would inadequately cover the near-lake objective and require antenna uptilt that Applicant asserts could cause impermissible interference to Canadian systems. However, no candidate-specific propagation or interference plots were provided to substantiate those RF conclusions. 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.

Technical Basis for Findings We recommend that, if the Board determines that the present record does not adequately establish the unavailability of reasonable alternative sites, Applicant be asked to provide additional documentation describing its outreach efforts for Candidates C, D, E, and G, including the dates, methods, and number of contact attempts; the persons contacted; and any written responses received. The Board may also consider requesting that Applicant make an additional documented good-faith effort to contact the owners of those parcels that the Board considers potentially less visually intrusive to determine whether circumstances or owner interest have changed and whether any portion of the properties could now be made available for a technically feasible facility. Exhibit G documents an initial review of seven candidate parcels, A through G. Candidate A, the proposed location, was identified as having sufficient space for the compound and setbacks, meeting the RF objective, and being available through a lease with Windmill Farms LLC. Candidate B was considered available only if the facility could be placed outside active farmland, but Applicant states that no suitable non-farmland location existed. Candidate F was eliminated after the owner expressly declined. For Candidates C, D, E, and G, Exhibit G states that multiple attempts to engage the respective owners “resulted in no interest,” while also identifying physical constraints such as wetlands, wooded areas, tree removal, residential use, limited parcel size, or setback difficulty. The record does not identify the dates, methods, or number of contact attempts or include written responses from those owners. Consequently, it is not possible to determine whether the owners affirmatively rejected a specific lease proposal, failed to respond to general inquiries, or might consider a different location or configuration on their properties. Candidates H and I were subsequently identified by the Planning Board as possible locations elsewhere on property also controlled by Windmill Farms. In Exhibit T, the landowner states that the selected corner parcel is the only location available for lease and explains that the suggested alternatives would affect productive agricultural land enrolled in a USDA Natural Resources Conservation Service conservation program through 2029, an active orchard, or a woodlot intended for conservation and forestry work. This provides a substantially more documented basis for the present unavailability of Candidates H and I. Applicant separately states that Candidate H would create interference with the neighboring cell to the west and that Candidate I would not adequately serve the near-lake objective and could require antenna uptilt resulting in interference with Canadian systems. Those RF conclusions are stated narratively, however, without candidate-specific coverage, best-server, interference, or signal-quality plots showing the predicted effects. A candidate location must generally be both technically feasible and actually available before it can constitute a practical alternative. The submitted record identifies constraints affecting each rejected location, but only Candidate A is documented as satisfying both conditions. Additional outreach documentation for Candidates C, D, E, and G would allow the Board to distinguish an affirmative owner rejection from unsuccessful or unanswered contact efforts. Where a parcel P a g e 16 | 21

Technical Basis for Findings appears potentially less visually intrusive and its physical constraints may be manageable, an additional documented inquiry could also determine whether owner interest or site circumstances have changed. 9. During site review, municipal staff recommendations and public comments may identify additional potential locations that were not explicitly considered by Applicant. We recommend that Applicant perform a preliminary availability and RF-feasibility review of any reasonably specific location identified by the Board that is within or near the technologically feasible search area, appears potentially available, and may offer reduced community or visual impact. Applicant’s site-selection analysis initially considered Candidates A through G, while Candidates H and I were added only after they were identified by the Planning Board. This demonstrates that municipal review and local knowledge can reveal potential locations that may not have been included in Applicant’s original search. Residents and Town staff may be aware of publicly owned land, commercial or industrial parcels, large agricultural properties, existing utility structures, or less visually sensitive portions of parcels that are not readily apparent from Applicant’s initial desktop search or property-owner outreach. An identified location would not automatically constitute a feasible alternative. It would need to fall within or reasonably near the RF search area and be capable of meeting the Lake Road facility’s principal coverage and capacity objectives. A preliminary technical review should consider the location’s relationship to the intended near-lake service area, predicted low-band and mid-band coverage, bestserver footprint, expected offload from the surrounding sectors, potential overlap or interference, achievable antenna height, terrain, vegetation, access, utilities, setbacks, wetlands, and parcel availability. A site materially outside the search area or unable to become an effective dominant server would not be a practical alternative merely because it may have less visual impact. 10. The proposed tower is 125’ tall (129’ 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 Lake Road 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 Site Plan identifies a 125-foot monopole with a four-foot lightning rod, resulting in a maximum overall height of approximately 129 feet AGL. The tower notes state that no FAA obstruction lighting is proposed unless required by the FAA or the municipality. The application also represents generally that the project will comply with applicable FAA requirements, but the submitted materials do not include an FAA Notice Criteria Tool result, FAA Form 7460-1 filing, P a g e 17 | 21

Technical Basis for Findings aeronautical-study number, Determination of No Hazard, or other site-specific FAA documentation establishing whether notice, marking, or lighting is required. Under 14 C.F.R. §77.9, proposed construction more than 200 feet AGL generally requires notice to the FAA. Structures below that height may also require notice if they penetrate specified imaginary surfaces extending outward and upward from certain airports, runways, or heliports. The applicability of these criteria depends on the proposed structure’s exact coordinates, site elevation, total height including appurtenances, and its relationship to nearby aviation facilities. When notice is required, the FAA conducts an aeronautical study to evaluate the effect on navigable airspace and determine whether marking, lighting, or other measures are appropriate. Thus, a structure’s height alone does not establish whether FAA review or lighting is required. The FAA’s OE/AAA Pre-Screening or Notice Criteria Tool is intended to determine whether a proposed structure meets the Part 77 filing criteria. Applicant should therefore submit the tool result using the Lake Road coordinates, site elevation, and full 129-foot height. If that evaluation indicates that notice is required, Applicant should then provide the FAA Form 7460-1 filing and resulting aeronautical determination, including any marking or lighting conditions. This documentation would confirm compliance while avoiding unnecessary obstruction lighting and its associated visual effects. 11. FCC regulations3 require Applicant to perform a preliminary analysis to ascertain whether or not it is likely the proposed site will expose members of the “General Population”4 to excessive electromagnetic energy. The application includes a general representation that the proposed facility will comply with applicable FCC radiofrequency emissions standards. Specifically, the application states that Exhibit P contains “Proof of Compliance with applicable federal regulations regarding RF emissions.” However, Exhibit P contains only a letter from Timothy Zarneke, Senior Engineer – RF System Design, Verizon Wireless, that states that Verizon performed a routine RFemissions compliance evaluation and concluded that the site complies with the FCC Maximum Permissible Exposure limits under 47 CFR §1.1310, with reference to FCC OET Bulletin 65. Exhibit P does not include a clearly detailed, site-specific RF exposure analysis showing the underlying MPE calculations, accessible areas, or the percentage of the FCC limits expected at the site. Therefore, it is a compliance statement, not a complete predictive MPE report. Accordingly, we recommend that Applicant provide the underlying sitespecific RF-exposure compliance report supporting Exhibit P, including the predicted maximum percentage of the applicable FCC limits at publicly and occupationally accessible locations. This information would allow the Board

Technical Basis for Findings and its consultant to evaluate Applicant’s stated compliance with §130-12F and applicable FCC requirements. FCC rules require fixed RF sources to be evaluated under 47 C.F.R. §1.1307(b) to determine whether they qualify for an exemption from routine RF-exposure evaluation or whether a technical evaluation is required. Where an evaluation is required, predicted exposure must be compared with the frequency-dependent Maximum Permissible Exposure (“MPE”) limits in 47 C.F.R. §1.1310. The rules distinguish between general population/uncontrolled exposure, applicable where members of the public may be present without RF-safety training or control over their exposure, and occupational/controlled exposure, applicable to trained workers who understand and can control their exposure. FCC OET Bulletin 65 provides recognized engineering guidance for evaluating fixed transmitting facilities, although it does not prescribe the only acceptable calculation method. Exhibit P is a one-page letter stating that Verizon performed a routine RF-emissions compliance evaluation and concluded that the proposed Lake Road facility would comply with the FCC MPE limits. The letter cites §1.1310 and OET Bulletin 65 but does not include the technical analysis supporting that conclusion. It does not identify the antenna models, operating frequencies, maximum transmitted powers or effective radiated powers, antenna gains, mounting heights, azimuths, downtilts, duty-cycle assumptions, calculation method, or locations evaluated. It also does not state the maximum predicted exposure as a percentage of the applicable FCC limit. The submitted material therefore documents Verizon’s conclusion but does not provide sufficient information for an independent technical review. 12. 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. A cellular network is composed of overlapping sector coverage areas that operate together rather than as independent facilities. Each sector’s effective service area is influenced by antenna height, azimuth, downtilt, power, frequency, terrain, vegetation, buildings, interference, and loading. Exhibit F’s existing best-server plots show portions of the Lake Road area being served by Four Mile Creek–Alpha, East Webster–Alpha, Ginna–Gamma, and other existing sectors. The proposed best-server plots show the Lake Road facility becoming the strongest predicted server over a substantial portion of that area, thereby replacing portions of the surrounding sectors’ existing dominant-server footprints. Once the Lake Road facility is placed in service, subsequent neighboring facilities or material modifications to existing facilities would need to be engineered with respect to its coverage footprint. Appropriate overlap is generally required near cell boundaries so that mobile devices can transition between sectors without interrupted service. At the same time, excessive overlap can create interference, unstable server selection, repeated handoffs, or inefficient loading. Future network design would therefore need to consider Lake Road’s antenna configuration, frequencies, signal levels, handoff relationships, interference contribution, and available capacity when determining the locations and configurations of adjoining sectors. P a g e 19 | 21

Technical Basis for Findings 13. 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. 14. 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, offload traffic from future saturated sectors, and properly integrate the currently-proposed site into the larger network. A wireless network is composed of interconnected sectors whose coverage, interference, handoff boundaries, and traffic loading must be coordinated. Applicant’s Exhibit F shows that the proposed Lake Road facility would become a new dominant server over portions of the area presently served by Four Mile Creek–Alpha, East Webster–Alpha, Ginna–Gamma, and other surrounding sectors. The proposed site would therefore change the existing best-server boundaries and redistribute traffic within the network rather than operate as an isolated facility. Construction of the Lake Road facility would not necessarily eliminate all remaining weak-service areas or prevent future capacity limitations. Coverage beyond the proposed site’s effective footprint may still be constrained by distance, terrain, vegetation, buildings, or interference. In addition, continued growth in users and data demand, deployment of additional spectrum, or changes in network technology may eventually require modifications to existing facilities or additional sites. Any future neighboring facility would need to be located and configured to provide appropriate coverage overlap and handoff performance while avoiding excessive overlap, interference, or inefficient traffic distribution. Applicant itself explains that sites placed too close together, or sites that are too tall or poorly integrated, can create interference and degrade service.

Technical Basis for Findings The application does not provide a complete two-year deployment plan showing whether Applicant anticipates additional facilities in the Town or surrounding area. The Board therefore cannot determine from the present record whether Lake Road is expected to be the final facility needed in this portion of the network or one step in a broader deployment plan. Future sites are not certain, but they remain technically possible where coverage, capacity, or network-integration needs persist.