Zoning Board Meeting
Zoning Attachment 2026.10.13

Supplemental Application (9/29)

October 13, 2026 · 53 min read · extracted text · View original

Nixon Peabody LLP 211 High Point Drive, Suite 110 Victor, NY 14564-1061

Robert W. Burgdorf Partner

T / 585.263.1333 rburgdorf@nixonpeabody.com

September 29, 2026 VIA FEDERAL EXPRESS Town Board, Planning Board and Zoning Board of Appeals Town of Webster 1000 Ridge Rd Webster, NY 14580 ATTN: Josh Artuso, Director of Community Planning & Development RE:

Bell Atlantic Mobile Systems, LLC d/b/a Verizon’s application (the “Application”) to the Town of Webster (the “Town”) for site plan approval, special permit approval, and an area variance to construct and operate a 135ʹ wireless telecommunications facility (with 4ʹ lightning rod) on property located near 1222 Wildflower Drive (Tax Parcel No. 065.05-1-48) in the Town of Webster, Monroe County, New York (Verizon Wireless’ “Webster North” site)

Dear Members of the Town Board, Planning Board and Zoning Board of Appeals: By application dated March 10, 2026 and supplemental application dated August 27, 2026, Bell Atlantic Mobile Systems LLC d/b/a Verizon (“Verizon”) submitted the abovereferenced Application (the “Application”) to the Town of Webster in connection with the above-referenced project. At the September 8, 2026 Zoning Board of Appeals (“ZBA”) meeting, a representative of Webster Presbyterian Church, located at 550 Webster Rd, Webster, New York 14580 (the “Church”), offered the site as a potential alternative location for the Project. Verizon previously evaluated and rejected this location as it does not meet the necessary RF objectives. Nevertheless, to ensure a complete record, an updated RF Justification addressing the Church location is enclosed as Exhibit S (following Exhibits A-R previously submitted). As detailed on pages 41-45, the Church is not a viable alternative to the proposed Site. Its coverage footprint is displaced to the east, which would fail to provide adequate coverage for the western and central corridors of the project area and would not deliver the capacity relief that the Project is designed to provide. Furthermore, as additional accommodation to address neighbors’ concerns, Verizon conducted an additional drone flight on Friday, September 11th, to demonstrate the proposed tower height. The drone was reported to be not visible from neighboring properties, further confirming the limited visual impact of the Project. Having fully addressed all of the questions raised by both the Planning Board and the ZBA, we anticipate that the Planning Board will issue site plan approval at its October 6th meeting, the ZBA will approve the variance at its October 13th meeting, and the Town Board will 4910-1672-2644.1

Town of Webster September 29, 2026 Page 2

consider the Application at its November 5th meeting and grant final approval at its November 19th meeting. By this letter Verizon therefore agrees to extend the Federal shot clock deadline for this Application to November 20, 2026. Should you have any questions or require additional information, please do not hesitate to contact me. Sincerely,

Robert W. Burgdorf RWB/mkv Enclosure cc: Kathy Pomponio, Verizon Nico Facey, Network Building + Consulting

4910-1672-2644.1

EXHIBIT S

Verizon Wireless Communications Facility Engineering Necessity Case – “Webster North” Four Mile Creek Site Webster Park Site Search Area Project Location WEBSTER NORTH

Webster Rd/Rt. 250 Webster Site Xerox Site Holt Rd

Prepared by

Michael R. Crosby, Principal RF Engineer, Verizon Wireless Timothy Zarneke, Senior RF Engineer, Verizon Wireless Project: The project is the installation and operation of a new tower co-located wireless telecommunications site in the Town of Webster, NY (the “Project Facility”). Original: Feb 26th, 2026 Rev/Supplemented Aug 25th and Sept 28th 2026

Introduction The purpose of this subsequent analysis is to summarize and communicate the technical radio frequency (RF) information used in the justification of this new site. Coverage and/or capacity deficiencies are the two primary driving conditions that typically prompt the need for a new wireless communications facility/site. All wireless customers depend on their wireless provider’s ability to provide adequate and reliable coverage where needed. In areas where coverage does not exist the user can not make a connection which is categorized as a “Gap in Service” lacking adequate and reliable coverage. Where coverage exists but is over utilized, this can also result with the user not being able to successfully use the connection which is also a “Gap in Service” and categorized as lacking adequate and reliable coverage. The service deficiencies sought to be remedied by this proposed cell site include a significant number of failed calls, resulting in users being unable to connect and/or maintain a connection capable of supporting a reasonably uninterrupted communication. • Coverage can be defined as the existence of radio frequency signal of usable strength and quality/capacity in an area, including but not limited to in-vehicles or in-buildings. The need for improved coverage is identified by RF Engineers that are responsible for developing and maintaining the network. RF Engineers utilize both theoretical and empirical data sets (propagation maps and real world coverage measurements or other data). Historically, coverage improvements have been the primary justification of new sites. • Capacity can be defined as the amount of traffic (voice and data) a given site can process before significant performance degradation occurs. When traffic volume exceeds the capacity limits of a site serving a given area, network reliability and user experience degrades. Ultimately this prevents customers from making/receiving calls, applications cease functioning, internet connections time out and data speeds fail. This critical condition is more important than just a simple nuisance for some users. Degradation of network reliability and user experience can affect emergency responders and to persons in a real emergency situation can make the difference between life and death.

*Note that, while Verizon Wireless provides sufficient evidence to establish the existence of a coverage gap and capacity need in this case, the FCC has confirmed that federal law does not require a provider to establish the existence of a coverage/capacity gap to establish the need for a site. There are several ways by which an applicant can establish site need. See Accelerating Wireless Broadband Deployment by Removing Barriers to Infrastructure Investment,” FCC 18-133, 85 FR 51867, at ¶ 37 (October 15, 2018) (confirming that the test for establishing an effective prohibition is whether “a state or local legal requirement materially inhibits a provider’s ability to engage in any of a variety of activities related to its provision of a covered service,” and this test is met “not only when filling a coverage gap but also when densifying a wireless network, introducing new services or otherwise improving service capabilities”) (emphasis added).

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Project Need Overview The project area, located in the northern portion of the Town of Webster is currently served by three distant sites. These sites are overloaded requiring capacity relief or otherwise unable to adequately serve the project area from these relatively distant locations. Specifically, the project area is subject to significant terrain and or foliage challenges for RF (signal) propagation. This terrain and or foliage combined with long distance prevent effective propagation of Verizon’s RF signals into this area compounding the capacity issue with areas of variable coverage creating significant gaps in service. • The first serving site is Webster, located in the Town of Webster, is approximately 1.75 miles south west (of the project location) situated on an

existing tower (195’ ACL) located off Picture Parkway. While this site provides weak/variable coverage in portions of the project area, it does so from a terrain and or foliage + distance challenged position making the site not capable of efficiently or effectively providing adequate coverage or capacity. • The second serving site is Four Mile Creek, located in the Town of Webster, is approximately 1.75 miles north east (of the project location) on

an existing tower (146’ ACL) off Phillips Rd. While this site provides weak/variable coverage in portions of the project area, it does so from a terrain and or foliage + distance challenged position making the site not capable of efficiently or effectively providing adequate coverage or capacity. • The third serving site is Webster Park, located in the Town of Webster, is approximately 2 miles west-north west (of the project location)

situated on an existing tower (121’ ACL) off Lake Rd near Pellet Rd. While this site provides weak/variable coverage in portions of the project area, it does so from a terrain and or foliage + distance challenged position making the site not capable of efficiently or effectively providing adequate coverage or capacity. Available (mid band) carriers at these and other area sites are not capable of effectively serving/offloading the project area due to inherent propagation losses from distance, challenging terrain and or in building coverage losses negatively impacting mid band coverage and capacity offload capabilities. There are other Verizon sites in this general area but due to distance and terrain/foliage they also do not provide any significant overlapping coverage in the area in question that could allow for increased capacity and improved coverage from other sources. The primary objectives for this project are to increase capacity and provide and or improve coverage throughout the north central portion of the Town of Webster, more specifically portions of Holt Rd, Webster Rd, Wall Rd, Schlegal Rd, Wall Rd, Shoemaker Rd, Joseph Circle, Appian Dr, Brooktree Ln, Hidden Valley Trail, Woodsboro Farms, Severn Ridge Rd, Stockbridge Rd, Woodhull Rd, Sagebrook Way, Providence Dr, Wildflower Dr, Imperial Dr, Klem Rd, Nestwood Ln, Licia Ln, Sherborne Rd, Marigold Dr, Ohstrom Park as well as neighboring residential and commercial/public areas along and near these roads including portions of Webster Park. In order to offload capacity from Webster, Four Mile Creek and Webster Park sites, a new dominant server must be created. This new dominant coverage will effectively offload the existing overloaded sites/cells as well as provide improved coverage where significant gaps exist today. Following the search for co-locatable structures to resolve the aforementioned challenges and finding none available, Verizon proposes to attach the necessary antenna(s) to a new tower located at 1222 WILDFLOWER DRIVE, WEBSTER, NY 14580. Verizon’s antennas will utilize 130’ ACL (Antenna Center Line) with a top of antenna height of 134’. This solution is the minimum height necessary to provide the coverage and capacity improvements needed. 3

Wireless 4G/5G Safety and Growth

More wireless traffic needs more wireless facilities just like more vehicle traffic needs more lanes. • Many wireless users share each cell site and congestion may result when too many try to use it at the same time. • Wireless coverage may already exist in an area, but with data usage growth increasing exponentially each year,more capacity is needed. • To meet capacity demands, we need to add more sites closer to users and strategically spaced with other cell sites to provide the reliable service customers have come to expect from Verizon. The monthly data traffic in North America is projected to amount to 19.53 exabytes (the equivalent of over four billion DVD’s) by 2027. In 2021, the average data traffic amounted to almost 5 EB per month.*

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Reliable and Critical Communications

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Explanation of Wireless Capacity Capacity in this analysis is evaluated with up to three metrics further explained below. These metrics assist Verizon traffic planning and RF Engineers in determining actual usage for a given site as well as can be used to project when a site is expected to run out of capacity (i.e. reach a point of exhaustion where it can no longer process the volume of voice and data requested by local wireless devices, thus no longer providing adequate service). Unfortunately capacity exhaustion has already occurred which presents an urgent need to deliver the capacity relief necessary in an effort to provide adequate and reliable coverage to this project area. •

Forward Data Volume (“FDV”), is a measurement of usage (data throughput) on a particular site over a given period of time.

•

Average Schedule Eligible User (“ASEU”), is a measurement of the loading of the control channels and systems of a given site.

•

Average Active Connections (“AvgAC”) is a measurement of the number of devices actively connected to a site in any given time slot.

Verizon Wireless uses proprietary algorithms developed by a task force of traffic planning engineers to monitor each site in the network and accurately project and identify when sites will approach it’s capacity limits. Using a rolling two-year window for projected exhaustion dates allows enough time, in most cases, to develop and activate a new site. It is critical that these capacity approaching sectors are identified early and the site development process is started and completed in time for new solutions (sites) to be on air before network issues impact the customers. As mentioned previously, actual utilization for the last year indicates several KPI’s have already exceeded 100% utilization creating a more urgent need in this project area. 6

Capacity Utilization (Webster Alpha)

FDV (Forward Data Volume), shown above is a measurement of the customer data usage that this sector currently serves. As this limit is approached, data rates slow to unacceptable levels, potentially causing unreliable service for Verizon Wireless customers.

ASEU (Average Schedule Eligible User), shown above is a measurement of the loading of the control channels and systems of a given site. The ASEU load is heavily impacted by distant users or those in poor RF conditions.

AvgAC (Average Active Connections), shown above is utilization by carrier showing a measurement of max active connection capacity per sector in any given time slot. When this limit is reached, no additional devices will be able to connect to the site, resulting in connection failures and dropped calls.

In each graph above, the purple line represents the daily max busy hour Low Band LTE utilization and the dark red line represents the daily max busy hour Mid Band LTE utilization on the Alpha sector of the Webster site. The red dashed line is the limit where the sector reaches exhaustion and service starts to significantly degrade. The point in time where we see the purple and/or dark red lines reach or exceed the red dashed line is when service quickly degrades as usage continues to increase. Capacity exhaustion can create the same customer experience as a coverage gap. Ideally, capacity relief should be implemented prior to reaching exhausted conditions. In this case the site/sector shown has already exceeded its capability to support one or more of these capacity KPI’s. In order to provide adequate and reliable service to Webster North and the surrounding project area, network densification is required. 7

Capacity Utilization (Four Mile Creek Beta)

FDV (Forward Data Volume), shown above is a measurement of the customer data usage that this sector currently serves. As this limit is approached, data rates slow to unacceptable levels, potentially causing unreliable service for Verizon Wireless customers.

ASEU (Average Schedule Eligible User), shown above is a measurement of the loading of the control channels and systems of a given site. The ASEU load is heavily impacted by distant users or those in poor RF conditions.

AvgAC (Average Active Connections), shown above is utilization by carrier showing a measurement of max active connection capacity per sector in any given time slot. When this limit is reached, no additional devices will be able to connect to the site, resulting in connection failures and dropped calls.

In each graph above, the purple line represents the daily max busy hour Low Band LTE utilization and the dark red line represents the daily max busy hour Mid Band LTE utilization on the Beta sector of the Four Mile Creek site. The red dashed line is the limit where the sector reaches exhaustion and service starts to significantly degrade. The point in time where we see the purple and/or dark red lines reach or exceed the red dashed line is when service quickly degrades as usage continues to increase. Capacity exhaustion can create the same customer experience as a coverage gap. Ideally, capacity relief should be implemented prior to reaching exhausted conditions. In this case the site/sector shown has already exceeded its capability to support one or more of these capacity KPI’s. In order to provide adequate and reliable service to Webster North and the surrounding project area, network densification is required. 8

Capacity Utilization (Webster Park Alpha)

FDV (Forward Data Volume), shown above is a measurement of the customer data usage that this sector currently serves. As this limit is approached, data rates slow to unacceptable levels, potentially causing unreliable service for Verizon Wireless customers.

ASEU (Average Schedule Eligible User), shown above is a measurement of the loading of the control channels and systems of a given site. The ASEU load is heavily impacted by distant users or those in poor RF conditions.

AvgAC (Average Active Connections), shown above is utilization by carrier showing a measurement of max active connection capacity per sector in any given time slot. When this limit is reached, no additional devices will be able to connect to the site, resulting in connection failures and dropped calls.

In each graph above, the purple line represents the daily max busy hour Low Band LTE utilization and the dark red line represents the daily max busy hour Mid Band LTE utilization on the Alpha sector of the Webster Park site. The red dashed line is the limit where the sector reaches exhaustion and service starts to significantly degrade. The point in time where we see the purple and/or dark red lines reach or exceed the red dashed line is when service quickly degrades as usage continues to increase. Capacity exhaustion can create the same customer experience as a coverage gap. Ideally, capacity relief should be implemented prior to reaching exhausted conditions. In this case the site/sector shown has already exceeded its capability to support one or more of these capacity KPI’s. In order to provide adequate and reliable service to Webster North and the surrounding project area, network densification is required. 9

Explanation of Wireless Coverage Generic Coverage Example See color explanations below:

Coverage is best conveyed via coverage maps. RF engineers use computer simulation tools (in this case Verizon uses Forsk Atoll) which takes into account terrain, foliage, building types, and other site/network specifics to model the RF environment. This propagation model is used to simulate the real world network which assists RF Engineers in evaluating the impact of a proposed site (along with industry experience and other tools). Modern network complexity, exponential traffic growth and wide reaching customer utilization areas have evolved the coverage justification discussion far beyond the ability of antiquated justification methods including drive test data and dropped call records. For many years drive data and dropped call data have simply not been able to comprehensively articulate the gaps (need) in coverage or capacity capability for 4 and 5G networks. Upstate NY Verizon Wireless sites provide customers service using several FCC licensed frequencies including 700 and 850MHz. To resolve capacity congestion for these coverage layers higher frequency (and bandwidth) PCS (1900 MHz), AWS (2100 MHz) and C-Band (3700MHz) mid band carriers are added however due to differences in propagation characteristics, many gaps in coverage and capacity still remain requiring network densification to resolve. In some mountaintop or long distance situations the mid band (higher frequency) AWS, PCS and C-Band carriers are either not or not fully effective due to excessive distance (path loss). This is because the site is located too far from the user population to provide adequate and reliable service. Although exclusively regulated by the FCC and subject to market adjustment as needed, it is worth noting that all of the propagation slides in this RF Justification are generated using the max power of the LB and MB Samsung radio capabilities.

**Dark Green >/= -75dBm RSRP, typically serves dense urban areas as well as areas of substantial construction (colleges, hospitals, dense multi family etc.) Green >/= -85dBm RSRP, typically serves suburban single family residential and light commercial buildings Yellow >/= -95dBm RSRP, typically serves most rural/suburban-residential and in car applications Orange >/= -105dBm RSRP, rural highway coverage, subject to variable conditions including fading and seasonality gaps White = <-105dBm RSRP, variable to no reliable coverage gap area More detailed, site-specific coverage slides are later in the presentation *Signal strength requirements vary as dictated by market and conditions ** Not displayed in example map, layer not used in all site justifications

Signal strength throughout a given site’s coverage area is subject to the limitations of the frequencies used. Lower frequencies with narrower bandwidth propagate further distance, and are less attenuated by clutter than higher frequencies with wider bandwidth. Unfortunately due to relatively narrow spectrum available these low bands can become quickly overloaded especially where similar signal strength from mid band carriers are not available. Similar coverage levels from mid band carriers are needed to resolve capacity issues (including the ability to make and receive voice calls). In order to provide similar coverage levels using the higher capacity/higher frequencies, a denser network of sites is required (network densification). Modern 4 and 5G networks are designed and intended to combine or use more than one frequency band at a time. This is called carrier aggregation which is not effective when the mid band signal is too weak or nonexistent. This means that site justification including ACL requirements must be derived from mid band capabilities. It is critical to understand the relationship between low band capacity and mid band coverage especially when 10 reviewing the need for new suburban and rural morphology sites.

Explanation of the Webster North Search Area A Search Area is the geographical area within which a new site is targeted to solve a coverage and or capacity deficiency. Three of the factors taken into consideration when defining a search area are topography, user density, and the existing network. •

Topography must be considered to minimize the obstacles between the proposed site and the target coverage area. For example, a site at the bottom of a ridge will not be able to cover the other side from a certain height.

•

In general, the farther from a site the User Population is, the weaker the RF conditions are and the worse their experience is likely to be. These distant users also have an increased impact on the serving site’s capacity. In the case of a multi sector site, centralized proximity is essential to allow users to be evenly distributed and allow efficient utilization of the site’s resources.

•

The existing Network Conditions also guide the design of a new site. Sites placed too close together create interference due to overlap and are an inefficient use of resources. Sites that are too tall or not properly integrated with existing sites cause interference and degrade service for existing users.

•

Existing co-locatable structures inside the search area as well as within a reasonable distance of the search area are submitted by site acquisition and reviewed by RF Engineering. If possible, RF will make use of existing or nearby structures before proposing to build new towers.

PROJECT LOCATION

Webster North Search Area

To resolve the coverage and capacity deficiencies previously detailed, Verizon Wireless is seeking to add one new cell facility within this area to improve wireless service capacity and coverage. By providing a new dominant signal area and offloading weak and distant traffic from Webster, Four Mile Creek and Webster Park sites with the proposed site, adequate and reliable service will be restored. The new Webster North site will provide dominant and dedicated signal to the identified portions of the Town of Webster. This helps to improve not only the Webster North project area but will also result with significant improvements to the above mentioned overloaded sites ultimately improving community wide areas in and around the Webster North project area. 11

Existing Low Band (700/850MHz) Best Server -105dBm RSRP Best Server plots depict the actual footprint of each sector in question at one threshold so the viewer can accurately evaluate the area offloaded by the new sites dominant signal area.

Lake Rd (Future)

Holt & Lake (Future SC)

Four Mile Creek

Webster Park

WEBSTER NORTH Klem Rd

On Air Coverage Webster Alpha 146’ Four Mile Creek Beta 121’ Webster Park Alpha Search Area

East Webster

195’

Xerox Webster

The map above represents coverage from existing sites, with the sites in need of capacity offload detailed in the legend above. Blue coverage is from other on air (Low Band) sites. Notice the lack of a dominant server throughout the Webster North project area. This reveals several sites that are stretching their coverage capabilities excessively which results with poor coverage and performance capabilities. 12

Proposed Low Band (700/850MHz) Best Server -105dBm RSRP Best Server plots depict the actual footprint of each sector in question at one threshold so the viewer can accurately evaluate the area offloaded by the new sites dominant signal area.

Lake Rd (Future)

Holt & Lake (Future SC)

Four Mile Creek

Webster Park

WEBSTER NORTH

On Air Coverage 195’ Webster Alpha 146’ Four Mile Creek Beta 121’ Webster Park Alpha 130’ Proposed Coverage Search Area

East Webster

Xerox Webster

The map above adds the footprint of the proposed Webster North site with a 130’ ACL coverage in green. The green best server footprint provides improved coverage and capacity throughout the identified significant gap area. This will improve service to users in the green area as well as help to resolve the coverage and capacity issues impacting the existing overloaded sectors identified in the image above. 13

Existing Low Band (700/850MHz) Coverage (signal strength) This coverage map shows how weak the RF conditions are in portions of the Town of Webster and surrounding area. Refer to slide 10 for further explanation of these color thresholds

Lake Rd (Future)

Holt & Lake (Future SC)

Four Mile Creek

Webster Park

WEBSTER NORTH Klem Rd

East Webster

Xerox Webster

The map above represents low band signal strength coverage from existing sites. While low band generally serves this project area it is subject to overloading as shown in the capacity slides. This overloading in part is due to gaps in adequate and reliable mid band coverage as shown in the following slides. Network densification is needed to resolve these coverage and capacity issues. Compare to p12 to better understand the LB best server footprint

*PRO TIP Compare to p15 to visualize the proposed site LB impact

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Proposed Low Band (700/850MHz) Coverage (signal strength) This coverage map shows how improved the RF conditions will be in portions of the Town of Webster and surrounding area. Refer to slide 10 for further explanation of these color thresholds

Lake Rd (Future)

Holt & Lake (Future SC)

Four Mile Creek

Webster Park

WEBSTER NORTH Klem Rd

East Webster

Xerox Webster

The map above adds low band of the Webster North site at 130’ ACL to the existing coverage map. The significantly improved signal strength corresponds to improved coverage and capacity throughout the identified significant gap areas. This will help to resolve the coverage and capacity issues impacting portions of the Town of Webster. Compare to p13 to better understand the LB best server footprint

*PRO TIP Compare to p14 to visualize the proposed site LB impact

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Existing Mid Band (AWS/PCS/C-Band) Best Server -105dBm RSRP Best Server plots depict the actual footprint of each sector in question at one threshold so the viewer can accurately evaluate the area offloaded by the new sites dominant signal area.

Lake Rd (Future)

Holt & Lake (Future SC)

Four Mile Creek

Webster Park

WEBSTER NORTH

On Air Coverage Webster Alpha 31’ Four Mile Creek Beta 118’ Webster Park Alpha Search Area

East Webster

147’

Xerox Webster

The map above represents coverage from existing sites, with the sites in need of capacity offload detailed in the legend above. Blue coverage is from other on air (Mid Band) sites. Notice the lack of signal or where there is signal, a dominant server throughout the Webster North project area. This reveals several sites that are stretching their mid band coverage capabilities which results with unacceptable coverage and performance. 16

Proposed Mid Band (AWS/PCS/C-Band) Best Server -105dBm RSRP Best Server plots depict the actual footprint of each sector in question at one threshold so the viewer can accurately evaluate the area offloaded by the new sites dominant signal area.

Lake Rd (Future)

Holt & Lake (Future SC)

Four Mile Creek

Webster Park

WEBSTER NORTH

On Air Coverage 147’ Webster Alpha 31’ Four Mile Creek Beta 118’ Webster Park Alpha 130’ Proposed Coverage Search Area

East Webster

Xerox Webster

The map above adds the mid band footprint of the proposed Webster North site with a 130’ ACL in green. The green best server footprint provides improved coverage and capacity throughout the identified significant gap area. This will improve service to users in the green area as well as help to resolve the coverage and capacity issues impacting the existing overloaded sectors identified in the image above. 17

Existing Mid Band (AWS/PCS/C-Band) Coverage (signal strength) This coverage map shows how weak the RF conditions are in portions of the Town of Webster and surrounding area. Refer to slide 10 for further explanation of these color thresholds

Lake Rd (Future)

Holt & Lake (Future SC)

Four Mile Creek

Webster Park

WEBSTER NORTH Klem Rd

East Webster

Xerox Webster

The map above represents mid band coverage from existing sites. This mid band signal is very weak to non existent throughout the project area. Additional mid band network densification is required to resolve these conditions. Notice the large orange and blank coverage areas near the proposed Webster North site that are subject to overloaded low band as well as variable coverage conditions including fading and seasonality gaps. Compare to p16 to better understand the MB best server footprint

*PRO TIP Compare to p19 to visualize the proposed site MB impact

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Proposed Mid Band (AWS/PCS/C-Band) Coverage (signal strength) This coverage map shows how improved the RF conditions will be in portions of the Town of Webster and surrounding area. Refer to slide 10 for further explanation of these color thresholds

Lake Rd (Future)

Holt & Lake (Future SC)

Four Mile Creek

Webster Park

WEBSTER NORTH Klem Rd

East Webster

Xerox Webster

The map above adds mid band of the Webster North site at 130’ ACL to the existing coverage map. The significantly improved signal strength corresponds to improved coverage and capacity throughout the identified significant gap areas. This will help to resolve the coverage and capacity issues impacting portions of the Town of Webster. Compare to p17 to better understand the MB best server footprint

*PRO TIP Compare to p18 to visualize the proposed site MB impact

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RF Justification Summary

The network was analyzed to determine whether there is sufficient RF coverage and capacity in the Town of Webster. It was determined that there are significant gaps in adequate LTE service for Verizon Wireless in the Low and Mid Band LTE 4G and 5G frequencies. In addition to the coverage deficiencies, Verizon Wireless’ network does not have sufficient capacity (low band or mid band) to handle the existing and projected LTE voice and data traffic in the area near and neighboring the proposed facilities (“targeted service improvement area”). Based on the need for additional coverage and capacity while considering the topography and specific area requiring service, any further addition of capacity to distant existing sites does not remedy Verizon’s significant gap in reliable service. Therefore, the proposed facility is also needed to provide “capacity relief” to the existing nearby Verizon Wireless sites, allowing the proposed facility and those neighboring sites to adequately serve the existing and projected capacity demand in this area.

Gap Area The proposed site resolves the substantial and significant gaps in coverage and capacity impacting this portion of the Town of Webster. These gaps are shown above: The green shaded area represent the gaps in coverage and capacity that the proposed Webster North site with a 130’ ACL will resolve.

Michael R. Crosby

With the existing network configuration there are significant gaps in service which restricts Verizon Wireless customers from originating, maintaining or receiving reliable calls and network access. It is our expert opinion that the proposed site will satisfy the coverage and capacity needs of Verizon Wireless and users on it’s network in these portions of the Town of Webster and this project area. The proposed location depicted herein satisfies the identified service gaps and is proposed at the minimum height necessary for adequate and reliable service.

Timothy Zarneke

Michael R. Crosby Timothy Zarneke Principal Engineer– RF Design 1275 John Street, Suite 100 West Henrietta, NY 14586 Verizon Wireless

Senior Engineer– RF Design 1275 John Street, Suite 100 West Henrietta, NY 14586 Verizon Wireless

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Supplemental

Adding in Low-Band Coverage of Holt&Lake SC This coverage map shows the same coverage as slide 13 but adds in the best server coverage (-105dBm) of Holt & Lake SC

Lake Rd (Future)

Holt & Lake (Future SC)

Four Mile Creek

Webster Park

Klem Rd

On Air Coverage 147’ Webster Alpha 31’ Four Mile Creek Beta 118’ Webster Park Alpha 130’ Proposed Coverage 45.6’ Holt and Lake SC Search Area

WEBSTER NORTH

East Webster

Xerox Webster

The map above adds low band of the Holt and Lake site at 45.6’ ACL to the Proposed coverage map. This map can be compared to slide 13 to determine if any future neighboring sites will have any impact on the Webster North proposed site or the required ACL. As can be seen the Holt and Lake SC is a spot solution at the location of the Webster Turkey Trot, Webster Park pavilions, The White House etc…This SC is designed to serve in areas that the Webster North site will not be able to reach due to distance and terrain. It is currently constructed waiting on fiber for activation. 21

Supplemental

Adding in Mid-Band Coverage of Holt&Lake SC This coverage map shows the same coverage as slide 17 but adds in the best server coverage (-105dBm) of Holt & Lake SC

Lake Rd (Future)

Holt & Lake (Future SC)

Four Mile Creek

Webster Park

Klem Rd

On Air Coverage 147’ Webster Alpha 31’ Four Mile Creek Beta 118’ Webster Park Alpha 130’ Proposed Coverage 45.6’ Holt and Lake SC Search Area

WEBSTER NORTH

East Webster

Xerox Webster

The map above adds mid band of the Holt and Lake site at 45.6’ ACL to the Proposed coverage map. This map can be compared to slide 17 to determine if any future neighboring sites will have any impact on the Webster North proposed site or the required ACL. As can be seen the Holt and Lake SC is a spot solution at the location of the Webster Turkey Trot, Webster Park pavilions, The White House etc…This SC is designed to serve in areas that the Webster North site will not be able to reach due to distance and terrain. It is currently constructed waiting on fiber for activation. 22

Supplemental

Alternate Height Discussion (Proposed vs 111’ ACL) This coverage map shows a comparison of the proposed site vs a compromised ACL lowered from 130’ to 111’ ACL

130’ ACL LB (Proposed)

111’ ACL LB (Rejected)

130’ ACL MB (Proposed)

111’ ACL MB (Rejected)

The maps above show the proposed coverage for LB and MB on the left and the suggested alternate lower height of 111’ on the right. In each of these cases the (LB and MB) coverage area of the alternate height is compromised and unacceptable due to area clutter. The surrounding area is dense old growth forested areas and neighborhoods. The area terrain combined with very tall and old growth foliage causes the unacceptable signal strength degradation observed. To better visualize why this is happening, please refer to the following drone fly images showing area clutter as tall as 110-115’. The antenna centerline of 130’ has an antenna “tail’ height of 126’ so the proposed antennas are modestly 10-15’ above area clutter which is typically the minimum height necessary to maintain unobstructed RF performance subject to specific site conditions and coverage objectives. Cellular sites use LOS (Line of Sight) technology/frequencies which require antenna elevations above clutter as described in order to function as needed in the case of the Webster North site/project. 23

Supplemental

Alternate Height Discussion (Proposed vs 91’ ACL) This coverage map shows a comparison of the proposed site vs a compromised ACL lowered from 130’ to 91’ ACL

130’ ACL LB (Proposed)

91’ ACL LB (Rejected)

130’ ACL MB (Proposed)

91’ ACL MB (Rejected)

The maps above show the proposed coverage for LB and MB on the left and the suggested alternate lower height of 91’ on the right. In each of these cases the (LB and MB) coverage area of the alternate height is compromised and unacceptable due to area clutter. The surrounding area is dense old growth forested areas and neighborhoods. The area terrain combined with very tall and old growth foliage causes the unacceptable signal strength degradation observed. To better visualize why this is happening, please refer to the following drone fly images showing area clutter as tall as 110-115’. The antenna centerline of 130’ has an antenna “tail’ height of 126’ so the proposed antennas are modestly 10-15’ above area clutter which is typically the minimum height necessary to maintain unobstructed RF performance subject to specific site conditions and coverage objectives. Cellular sites use LOS (Line of Sight) technology/frequencies which require antenna elevations above clutter as described in order to function as needed in the case of the Webster North site/project. 24

Supplemental

Alternate Height Discussion (Drone Views)

Webster North 130’ North View

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Supplemental

Alternate Height Discussion (Drone Views)

Webster North 130’ East View

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Supplemental

Alternate Height Discussion (Drone Views)

Webster North 130’ South View

27

Supplemental

Alternate Height Discussion (Drone Views)

Webster North 130’ West View

28

Supplemental

Alternate Height Discussion (Drone Views)

Webster North 120’ North View

29

Supplemental

Alternate Height Discussion (Drone Views)

Webster North 120’ East View

30

Supplemental

Alternate Height Discussion (Drone Views)

Webster North 120’ South View

31

Supplemental

Alternate Height Discussion (Drone Views)

Webster North 120’ West View

32

Supplemental

Alternate Height Discussion (Drone Views)

Webster North 110’ North View

33

Supplemental

Alternate Height Discussion (Drone Views)

Webster North 110’ East View

34

Supplemental

Alternate Height Discussion (Drone Views)

Webster North 110’ South View

35

Supplemental

Alternate Height Discussion (Drone Views)

Webster North 110’ West View

36

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Alternate Height Discussion (Drone Views)

Webster North Area Clutter exceeding 105-110’

For the Webster North project to effectively “clear” this area clutter using the FCC licensed LOS frequencies designated for Cellular/Personal Communication Services an antenna centerline of 130’ is required in order to provide adequate and reliable service to the coverage objectives listed on p3 of this RFJ document. The height of area clutter is a factor in this application when addressing the question of whether the tower could be lower or not. In this case it can not be lower due to clutter however that same area clutter provides substantial screening from area residents. Any lowering of the tower would compromise the site’s performance and not provide any improved visual impact as there is little to none as proposed. 37

Supplemental

Alternate Height Discussion (Drone Views)

Webster North Area Clutter exceeding 105-110’

For the Webster North project to effectively “clear” this area clutter using the FCC licensed LOS frequencies designated for Cellular/Personal Communication Services an antenna centerline of 130’ is required in order to provide adequate and reliable service to the coverage objectives listed on p3 of this RFJ document. The height of area clutter is a factor in this application when addressing the question of whether the tower could be lower or not. In this case it can not be lower due to clutter however that same area clutter provides substantial screening from area residents. Any lowering of the tower would compromise the site’s performance and not provide any improved visual impact as there is little to none as proposed. 38

Supplemental

Alternate Height Discussion (Drone Views)

Webster North Surrounding Clutter ~115’

For the Webster North project to effectively “clear” this area clutter using the FCC licensed LOS frequencies designated for Cellular/Personal Communication Services an antenna centerline of 130’ is required in order to provide adequate and reliable service to the coverage objectives listed on p3 of this RFJ document. The height of area clutter is a factor in this application when addressing the question of whether the tower could be lower or not. In this case it can not be lower due to clutter however that same area clutter provides substantial screening from area residents. Any lowering of the tower would compromise the site’s performance and not provide any improved visual impact as there is little to none as proposed. 39

Supplemental

Town of Webster 2 Year Planned Sites

LAKE ROAD HOLT & LAKE

WEBSTER NORTH

GRAVEL RD

The sites planned in the Town of Webster during the next two years are shown above with the red rings and site name label. Gravel Rd (small cell) is constructed waiting on fiber for activation. Holt & Lake (small cell) is constructed waiting on fiber for activation. Webster North and Lake Road macro sites are in zoning. If conditions develop that warrant the addition of other sites they will be developed as needed. 40

Supplemental

Alternate Location Discussion (Proposed vs Church) This LB coverage map shows a comparison of the proposed site vs a RF Rejected Church location at 130’ ACL

130’ ACL LB (Proposed) RF Approved

130’ ACL LB (Church) RF Rejected

The above images display the low band (LB 700/850MHz) coverage comparison between the proposed Webster North site location and the suggested alternate church location. The top two images show this comparison side by side. Using the red circle (search area) provides reference to see some of the coverage delta. To help enhance the ability to determine where each site provides coverage the bottom two images overlay these two coverage images. The bottom left shows the proposed site coverage on the top layer. Clearly the proposed site coverage almost everything the church does with the exception of some exclusive green areas primarily found to the eastern portion of the coverage area (where it is not needed and likely to cause interference issues). The bottom right image shows the proposed church coverage in green with the proposed red coverage underneath. This image reveals a clear coverage footprint deficiency in the western portion of the coverage area…this is the most critical of the coverage objective areas so the church location is not capable of serving the objectives. 41

Supplemental

Alternate Location Discussion (Proposed vs Church) This MB coverage map shows a comparison of the proposed site vs a RF Rejected Church location at 130’ ACL

130’ ACL LB (Proposed) RF Approved

130’ ACL LB (Church) RF Rejected

The above images display the mid band (MB 1900, 2100, 3700MHz) coverage comparison between the proposed Webster North site location and the suggested alternate church location. The top two images show this comparison side by side. Using the red circle (search area) provides reference to see some of the coverage delta. To help enhance the ability to determine where each site provides coverage the bottom two images overlay these two coverage images. The bottom left shows the proposed site coverage on the top layer. Clearly the proposed site coverage almost everything the church does with the exception of some exclusive green areas primarily found to the eastern portion of the coverage area (where it is not needed and likely to cause interference issues). The bottom right image shows the proposed church coverage in green with the proposed red coverage underneath. This image reveals a clear coverage footprint deficiency in the western portion of the coverage area…this is the most critical of the coverage objective areas so the church location is not capable of serving the objectives. 42

Supplemental

RF Analysis: Alternate Church Location — RF Rejected At the request of the Town of Webster, Verizon's RF Engineering team conducted a technical evaluation of a proposed alternate location at a nearby church site as a potential substitute for the proposed tower at 1222 Wildflower Drive. Following a thorough review of the site's geographic position relative to the defined search area, coverage modeling at both Low Band (LB) and Mid Band (MB) frequencies, and capacity offload objectives, this alternate location has been RF Rejected and cannot be considered a viable alternative to the proposed project site. The technical basis for this rejection is detailed below. 1. Location Outside the Defined Search Area The alternate church location is situated too far to the east, placing it outside the boundaries of the established RF search area for the Webster North project. The search area was carefully defined based on the geographic centroid of the coverage gaps and capacity deficiencies identified in the project area — specifically the residential and commercial corridors along Holt Rd, Webster Rd, Wall Rd, Schlegal Rd, Shoemaker Rd, Klem Rd, Sagebrook Way, Providence Dr, Wildflower Dr, and surrounding neighborhoods. A tower's dominant coverage footprint is largely a function of its geographic position relative to the target service area. By virtue of its easterly displacement from the search area centroid, the church site is fundamentally mispositioned to serve the intended coverage and capacity objectives. 2. Inability to Create the Required Dominant Server in the Correct Geographic Area The primary RF objective of the Webster North project is to establish a new dominant serving cell that offloads traffic from the three existing overloaded sites — Webster (~1.75 mi SW), Four Mile Creek (~1.75 mi NE), and Webster Park (~2 mi WNW) — while simultaneously filling significant coverage gaps across the north-central portion of the Town of Webster. Achieving this requires that the new site be positioned at or near the geographic center of the target area so that it can establish dominant signal strength over the full extent of the intended service footprint. The alternate church location, due to its easterly offset, shifts the predicted coverage footprint away from the western and central portions of the project area that contain the highest concentration of underserved residents, roads, and community assets. As demonstrated in the attached coverage comparison maps (Low Band and Mid Band), the proposed site at 1222 Wildflower Drive produces a well-centered dominant coverage footprint that squarely addresses the identified gaps. The church alternate, by contrast, produces a coverage footprint that is skewed to the east, leaving the western and central portions of the project area — the very corridors that are the subject of long-standing customer complaints and documented coverage deficiencies — inadequately served. This means the existing overloaded sites, Webster and Webster Park in particular, would receive less than intended capacity offload, as the church site's dominance boundary would not extend far enough west to capture traffic from those areas.

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Supplemental

RF Analysis: Alternate Church Location — Continued 3. Mid Band Capacity Offload Deficiencies The capacity relief objectives for this project are not limited to Low Band coverage. Mid Band carriers, which provide the higher throughput necessary to meaningfully offload data capacity from the surrounding congested sites, are even more sensitive to distance and terrain/foliage losses than Low Band. The easterly displacement of the church alternate further exacerbates Mid Band propagation challenges into the western and central portions of the project area, where terrain and foliage already present significant RF attenuation. As shown in the Mid Band coverage comparison maps, the proposed Wildflower Drive location provides materially superior Mid Band dominance across the target corridors compared to the church alternate, which fails to deliver meaningful Mid Band penetration into the areas most in need of capacity relief. Without adequate Mid Band dominance, the new site would be unable to effectively offload data traffic from Webster, Four Mile Creek, and Webster Park, leaving the capacity challenge unresolved. 4. Coverage Modeling Results — Summary (p41 and 42) The coverage comparison maps (Low Band and Mid Band, Proposed vs. Church Alternate, both modeled at 130' ACL) clearly illustrate the following: - Proposed Site (1222 Wildflower Drive) — RF Approved: Coverage footprint is well-centered over the project area, achieving dominant signal levels across the full target service area at both Low Band and Mid Band. The new dominant server boundary appropriately overlaps with the fringe areas of Webster, Four Mile Creek, and Webster Park sites, enabling effective capacity offload. - Webster Presbyterian Church - (550 Webster Rd)— RF Rejected: Coverage footprint is displaced to the east, failing to achieve dominance over the western and central corridors (and residential areas) of the project area. The coverage boundary does not extend sufficiently to overlap the capacity-limited portions of the Webster and Webster Park sites' coverage areas. Mid Band performance in the western project area is particularly deficient, rendering this site incapable of providing the capacity relief required. 5. Land Use and Community Impact Beyond the RF technical deficiencies, the alternate church location also presents a significantly more intrusive community impact profile compared to the proposed site. The church alternate is located in closer proximity to a higher density of residential properties and sits nearer to adjacent property lines, resulting in a more intrusive visual presence for neighboring residents. In contrast, the proposed location at 1222 Wildflower Drive sits on a large set back parcel surrounded by mature old-growth trees that provide substantial natural screening, significantly reducing the visual impact of the tower structure from surrounding properties and roadways. The proposed site's natural vegetative buffer represents a meaningful land use advantage that the church alternate cannot replicate. 44

Supplemental

RF Analysis: Alternate Church Location — Continued Conclusion The alternate church location does not satisfy the RF engineering requirements established for the Webster North project. Its easterly position outside the defined search area prevents it from establishing the centered dominant coverage footprint necessary to: (1) fill the documented coverage gaps in the north-central portion of the Town of Webster (2) provide effective Mid Band capacity offload for the overloaded Webster, Four Mile Creek, and Webster Park sites, and (3) serve the full breadth of the target residential and community corridors that are the subject of this project. The coverage modeling results at both Low Band and Mid Band frequencies confirm that the church alternate site produces materially inferior coverage compared to the proposed location. Additionally, the church alternate presents a greater community and land use impact relative to the proposed site. For these reasons, the alternate church location is RF Rejected and is not a viable substitute for the proposed tower at 1222 Wildflower Drive, Webster, NY 14580.

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End of document