Zoning Board Meeting
Zoning Attachment 2026.09.08

Supplement

September 8, 2026 · 18 min read · extracted text · View original

William P. Johnson and Steven M. Ciccarelli RF Engineering Consultants P.O. Box 20263

Rochester, New York

14602

August 31, 2026 Town of Webster Planning Board Attn: Josh Artuso, Director of Community Development Town of Webster 1000 Ridge Road Webster, NY 14580 RE:

Proposed Wireless Telecommunications Facility Supplemental RF Site Review, Bell Atlantic Mobile Systems, LLC d/b/a Verizon – “Lake Road” (Tax Parcel # 037.03-1-44) Proposed 125’ New Monopole Tower plus 4’ Lightning Rod (129’ overall)

Dear Mr. Artuso, This supplemental report discusses the radio-frequency (RF) aspects of the proposed Bell Atlantic Mobile Systems, LLC d/b/a Verizon (Applicant) ‘Lake Road’ project in the Town of Webster and Applicant’s supplemental submissions, as detailed below. Subsequent reports, if needed, will address any remaining questions or issues that arise during public hearings at the request of the Town. Additional background information related to technical matters is included in our Preliminary RF Report, dated August 3, 2026. The following materials form the basis for this report: 1. Permit application materials dated January 12, 2026, including Exhibits A through Q: •

Exhibit A

Town-supplied application forms;

•

Exhibit B

Project description;

•

Exhibit C

Applicable legal standards;

•

Exhibit D

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;

•

Exhibit E

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

•

Exhibit F

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

•

Exhibit G

Site selection analysis;

•

Exhibit H

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

08/31/26 Town of Webster – “Lake Road” •

Exhibit I

Verizon’s co-location policy;

•

Exhibit J

Proof of the Landowner’s consent to this Application;

•

Exhibit K

Photosimulation report;

•

Exhibit L

Structural design letter;

•

Exhibit M

Tower removal letter and removal cost estimate;

•

Exhibit N

Verizon’s FCC licenses for Monroe County;

•

Exhibit O

Ag data statement;

•

Exhibit P

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

•

Exhibit Q

11ʺ x 17ʺ copy of the site plan.

2. Applicant’s supplemental materials dated February 26, 2026: Exhibit R – Supplemental Lake Road Height Justification. 3. Applicant’s supplemental materials dated March 31, 2026, including Exhibits S through U: •

Exhibit S

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

•

Exhibit T

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

•

Exhibit U

RF review of potential search ring expansion.

4. Applicant’s supplemental materials received August 13, 2026: •

Exhibit F

The original Engineering Necessity Case (also referred to as the RF Justification or RFJ) in native PDF format;

•

Exhibit R

The supplemental Lake Road Height Justification in native PDF format.

5. Applicant’s supplemental application materials dated August 27, 2026, including: •

Exhibit V

Revised Supplemental Lake Road Height Justification, including low-band and mid-band comparisons at 120-foot and 95-foot ACL;

•

Exhibit W

Town of Webster Two-Year Planned Sites map;

•

Exhibit X

Federal Airways & Airspace Summary Report; and

•

Exhibit Y

EMF/FCC Compliance Report prepared by Airosmith Engineering, dated August 14, 2026.

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08/31/26 Town of Webster – “Lake Road” Summary of Findings Disposition and Technical Basis The following section summarizes the disposition of the open findings from our August 3, 2026 Preliminary RF Report and identifies the technical basis for each disposition based on Applicant’s supplemental RFJ and related materials. Finding 2 – Capacity Applicant subsequently provided the original RF Justification, dated September 15, 2025, in native PDF format. The capacity-utilization plots on pages 7 through 9 are substantially more legible than those contained in the scanned application packet and allow the utilization trends for Four Mile Creek–Alpha, East Webster–Alpha, and Ginna–Gamma to be evaluated with reasonable confidence. The plots support Applicant’s assertion that the existing low-band sectors are experiencing elevated utilization, with Forward Data Volume (“FDV”) being the capacity metric most consistently approaching or exceeding Applicant’s stated exhaustion threshold. The clearer data, considered together with the propagation and best-server information, supports our conclusion that a credible capacity-relief need exists in the Lake Road service area and that the proposed facility would create a new dominant server capable of transferring traffic from the surrounding sectors. Accordingly, Finding 2 from our Preliminary RF Report is satisfied for purposes of RF review. Finding 3 – Propagation/Coverage The original RF Justification in native PDF format resolved the principal legibility concerns associated with the low-band and mid-band propagation plots. The −75, −85, −95, and −105 dBm signal-strength categories are now clearly distinguishable on the existing and proposed propagation maps on pages 14, 15, 18, and 19. The improved plots confirm that low-band service is generally present throughout much of the project area, although at varying signal levels, while existing mid-band service is substantially weaker and contains meaningful areas of weak or absent service. The native plots therefore allow the extent and character of the existing RF conditions to be evaluated independently. They reinforce our conclusion that the Lake Road project is principally driven by capacity relief and network densification, while also demonstrating that the proposed facility would materially improve mid-band availability and strengthen service within portions of the project area. Accordingly, Finding 3 is satisfied for purposes of RF review. Finding 4 – Technical Need The native RF Justification resolves the data-quality limitations identified in Findings 2 and 3. The capacity plots confirm elevated loading on the surrounding serving sectors, while the existing and proposed best-server and propagation plots show that the proposed Lake Road facility would establish a substantial new dominant-server footprint and materially improve mid-band signal availability. The proposed site would therefore provide a closer serving facility for users presently dependent on more distant sectors and would improve the ability of the network to utilize higher-capacity mid-band resources. Page 3|7

08/31/26 Town of Webster – “Lake Road” Taken together, the supplemental information substantiates a valid technical need for an additional facility in the Lake Road area and supports the conclusion that the proposed facility would materially address the identified capacity and service deficiencies. The need is primarily capacity-driven, with additional benefit from improved mid-band coverage and signal quality. Accordingly, Finding 4 is satisfied for purposes of RF review. Finding 5 – Height Justification Applicant subsequently provided a revised Lake Road Height Justification dated August 24, 2026, and included in the August 27, 2026 supplemental materials as Exhibit V. Unlike the earlier Exhibit R analysis, which was limited principally to 700 MHz low-band performance, the revised submission provides comparative low-band and mid-band bestserver and propagation information for the proposed 120-foot ACL and the reduced 95foot ACL configuration. Applicant also more specifically identifies the intended service objective as extending generally from Lake Ontario south to approximately Boston Road and along Lake Road between Basket Road and Lake Meadow Drive. The revised plots show a materially smaller dominant-server footprint at 95 feet ACL for both low-band and mid-band service. The mid-band comparison is particularly significant because the original RF Justification identifies weak mid-band coverage as an important contributor to low-band congestion. Applicant’s delta analysis identifies losses along or near Lake Road to the east, County Line Road to the south, Boston Road to the southeast, Woodard Road to the southwest and portions of the broader project area when the antenna centerline is reduced from 120 feet to 95 feet. The reduced best-server footprint at 95 feet provides a reasonable engineering basis to conclude that fewer users and less traffic would be transferred from the surrounding sectors. Based on the expanded low- and mid-band comparison and the more clearly defined geographic objectives, the revised submission substantially addresses the technical concerns underlying this finding. Finding 5 is satisfied for the purposes of RF review. Finding 6 – Two-Year Deployment Map In Applicant’s August 27, 2026 supplemental submission, Exhibit W contains a Town of Webster two-year planned-sites map. The map identifies Verizon’s planned sites within the Town during the relevant two-year planning period, including Gravel Rd, Webster North, Holt & Lake, and Lake Road. The RFJ further states that Gravel Rd and Holt & Lake are constructed and awaiting fiber service for activation, and that Webster North and Lake Road are macro sites currently in zoning review. Based on this submission, Applicant has provided the requested Town-wide planned-sites information and has clarified the status of the neighboring planned deployments relevant to the Lake Road review. Therefore, Finding 6 from our Preliminary RF Report has been satisfied for purposes of RF review. Finding 7 – Neighboring Site Deployments The required coverage footprint and antenna height of the Lake Road facility must be considered in the context of the surrounding Verizon network, including facilities that are under construction or sufficiently advanced in planning to affect future network conditions. Page 4|7

08/31/26 Town of Webster – “Lake Road” Exhibit W identifies Verizon’s planned deployments in the Town, including Gravel Rd and Holt & Lake, which are constructed and awaiting fiber activation, and the Lake Road and Webster North macro facilities currently in zoning. Applicant further states in its August 27, 2026 supplemental submission that, “No new sites are anticipated in the near future that would allow for a reduction in the height of the current Project.” This statement directly addresses our request that Applicant consider whether planned neighboring deployments could reduce the service burden or antenna height required at Lake Road. Based on Applicant’s network-planning representation and the information presently available, Finding 7 is satisfied for purposes of RF review. Finding 8 – Alternative Sites/Owner Outreach The original Site Selection Analysis identified Candidates C, D, E, and G as unavailable in part because multiple efforts to contact the respective property owners “resulted in no interest,” but the application did not document the dates, methods, number of contact attempts, persons contacted, or any written responses. This differs from Candidate F, where the owner expressly declined, and Candidates H and I, for which the Windmill Farms owner subsequently provided a detailed written explanation of their unavailability. In response to Finding 8, Applicant states that the record demonstrates no other feasible location or technological alternatives and that Verizon made good-faith efforts to identify and pursue reasonable alternative sites but cannot compel property owners to make their land available for lease. The August 27 submission, however, does not provide the additional outreach documentation requested for Candidates C, D, E, and G, including the dates and methods of contact, number of attempts, persons contacted, or written owner responses. Applicant’s response therefore does not resolve the factual distinction identified in our Preliminary RF Report between an affirmative owner rejection and unsuccessful or unanswered outreach. However, our original recommendation expressly left to the Board the determination of whether additional documentation of Applicant’s outreach efforts is necessary. No further RF engineering analysis is required on this issue at this time. Accordingly, Finding 8 is satisfied for purposes of RF review, subject to the Board’s determination as to whether additional site-acquisition documentation should be requested. Finding 10 – FAA Review Applicant subsequently submitted Exhibit X, a Federal Airways & Airspace Summary Report evaluating the proposed Lake Road facility at a site elevation of 309 feet above mean sea level (AMSL) and a total structure height of 129 feet above ground level (AGL), resulting in an overall elevation of 438 feet AMSL. The report concludes that FAA notice is not required under the evaluated criteria of 14 C.F.R. §77.9, which governs when proposed construction must be reported to the FAA for airspace review. The analysis also identifies no expected impact to FAA Terminal Instrument Procedures (TERPS), no Cband 3.7–3.98 GHz coordination-zone conflict, and no requirement for an AM-station study.

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08/31/26 Town of Webster – “Lake Road” Based on this submission, Applicant has provided airspace documentation addressing the requested FAA/airspace item. Therefore, Finding 10 from our Preliminary RF Report has been satisfied for purposes of RF review. Finding 11 – FCC RF-Exposure Compliance Applicant subsequently provided an EMF/FCC Compliance Report prepared by Airosmith Engineering and dated August 14, 2026. The report evaluates the proposed Verizon installation using IXUS EMF Compliance Management Software and identifies the modeled antenna types, frequencies, centerline elevations, transmitter powers, and sector azimuths. The analysis includes 700 MHz, 850 MHz, 1900 MHz, 2100 MHz, and 4 GHz facilities and applies the FCC Maximum Permissible Exposure criteria discussed in OET Bulletin 65. The report concludes that the proposed Verizon installation complies with the FCC General Population/Uncontrolled exposure limits and calculates a maximum predicted ground-level exposure of 3.27% of the applicable FCC MPE limit. The modeling methodology is described as a conservative ray-tracing analysis, and the report is reviewed and approved by a New York-licensed Professional Engineer. For the presently proposed Verizon installation, the report provides sufficient site-specific technical information to substantiate Applicant’s RF-exposure compliance representation. Accordingly, Finding 11 is satisfied for purposes of RF review. Site Details from Preliminary RF Report Applicant proposes a new unmanned wireless telecommunications facility on lands of Windmill Farms LLC near the southwest corner of Lake Road and Monroe-Wayne County Line Road, Town of Webster, Monroe County, New York, identified as Tax Parcel No. 037.03-1-44. The proposed wireless facility is to be located within a 100' x 100' lease area, with ground equipment enclosed within an approximately 36' x 76' fenced compound. The proposed tower is described as a new 125-foot monopole, with an overall height of approximately 129 feet including a proposed 4-foot lightning rod. Verizon’s antennas are proposed at an antenna centerline height (ACL) of 120 feet AGL, with a top of antenna height of approximately 124 feet AGL. The tower is proposed to be designed for a total of three wireless carriers, with Verizon at the upper position and two future co-locator positions located at 109 feet ACL and 99 feet ACL, respectively. The Site Plan (PDF page 137 of 140 of the original permit application materials dated January 12, 2026) depicts three Verizon antenna sectors, with three antenna units per sector, for a total of nine antennas. Based on the RF Justification and application narrative, Applicant proposes to provide service using low-band and mid-band spectrum, including 700/850 MHz, PCS 1900 MHz, AWS 2100 MHz, and C-Band spectrum. The RF materials state that the proposed Lake Road facility is intended primarily to provide capacity relief and network densification while also improving coverage in the project area, including portions of the Great Lakes Seaway Trail/Lake Road, County Line Road, Basket Road, and nearby residential, commercial, and public areas. The proposed facility is intended to create a new dominant

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08/31/26 Town of Webster – “Lake Road” server and offload traffic from the Four Mile Creek–Alpha, East Webster–Alpha, and Ginna–Gamma sectors. Ground equipment consists primarily of Verizon exterior equipment cabinets on an approximately 11' x 12.5' concrete slab with ice canopy, a Verizon battery cabinet, utility and RF equipment on an H-frame, cable bridge, associated conduits, and related appurtenances, together with a proposed 50 kW diesel generator with tertiary containment tank on a separate 4' x 8' concrete slab. Access is proposed directly from Lake Road by way of a new 12-foot-wide gravel access driveway located within a 30-foot-wide access and utilities easement, with approximately 180 feet of proposed underground utilities extending to the compound. Conclusion Overall, Applicant’s supplemental submissions resolve or substantially address the remaining technical findings identified in our Preliminary RF Report. Based on the materials submitted to date, Findings 2 through 7, 10, and 11 are satisfied for purposes of RF review. Finding 8 requires no further RF engineering analysis at this time but remains subject to the Board’s determination as to whether additional documentation of Applicant’s site-acquisition efforts should be requested. The general recommendations in Findings 9 and 13 from our Preliminary RF Report remain applicable, although they are not treated here as unresolved technical-information requests. Applicant has also responded to Findings 9, 13, and 14 in its August 27, 2026 memorandum; to the extent those responses raise legal or procedural issues, they should be reviewed by the Board’s counsel. The information in this report concerns RF engineering issues related to the proposed project and is intended to assist the Board in weighing alternatives and planning for the future of the community. Engineering design choices may also implicate aesthetic and legal issues. However, this report must not be relied upon for legal advice or direction. Legal advice regarding action on these issues should be obtained from the Board’s counsel. Thank you for the opportunity to assist the Town of Webster. We will stand by to assist as the Town’s review of the project progresses. Please feel free to contact us if you have additional questions or concerns at this time. Sincerely,

William P. Johnson Consultant

Steven M. Ciccarelli Consultant

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