Arcadia Final List November 20 2008.pdf - Village Of Evendale

Staff response II November 13, 2008 

Arcadia Towers November 10, 2008 Response to 

Planning Commission Wireless Antenna Review 

Arcadia Communications 

Question Summary Document October 31, 2008 

The list of questions below is a compilation of questions from Planning Commission residents, 

staff and residents. The Village of Evendale Planning Commission desires to have this list 

function as a working list of questions and answers to better review the Arcadia Wireless 

Antenna placement on Rest Haven Memorial Park property in the Village of Evendale. 

Questions are sorted into Technical, Planning/Zoning and Miscellaneous. The questions are in 

no particular order nor are they numbered by importance. Numbering and categorizing are done 

for clarification and clarification only. Once complete, this list should contain Question, Staff 

Response, Applicant Response and for some questions Staff 2 nd Response. 

Arcadia Response: Arcadia Responses to each question are noted below in blue text. Expert 

responses and additional information provided will be attached hereto as Exhibits. 

TECHNICAL 

1. Apparently Cricket needs the extra pole height because they have a higher 

frequency than ATT etc. I assume this is because the Higher RF dissipates more 

quickly. Is there any connection between coverage area and power of transmission? 

What are higher frequency carriers going to do if the only pole positions are well 

below 150 ft.? 

a. Staff response: please see Stratum Tower report 

b. Arcadia response: Please see attached response from Cricket Communications. 

2. Why is only the 0.5 Mile area shown? 

a. Staff response: please see Stratum Tower report. 

b. Arcadia Response: Please see attached response from Cricket Communications. 

Cricket provided in the August 2008 Statement of Need for Wireless communications 

facility located in Evendale Ohio a “drawing showing the boundaries of the area 

around the proposed location which would probably also permit the antenna to 

function properly in the company’s grid system” in accordance with Village of 

Evendale Ordinance 1263.05 (A). 

3. I do not believe that the applicant has fulfilled one of the primary standards for 

approval. Section 1263.06(a) of the Village Code is provided below: 

(a) Antenna/tower height. The applicant shall demonstrate that the planned 

height of a cellular or wireless communications tower is no higher than 

necessary to function satisfactorily and to accommodate the co-location 

requirements as set out in division (f) of this section. No tower that is 

taller than the necessary height shall be approved, and the height of any 

tower to be greater than 200 feet must first be approved by the Planning 

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Commission. Cellular towers shall be monopole construction unless it is 

demonstrated upon application that another type of tower is required for 

safety purposes and it has been approved by the Planning Commission. 

Mr. Wahl has testified that Cricket needs their antenna to be at the top of a 150’ 

tower at the Rest Haven sites to “provide reasonable, reliable, and satisfactory 

service to (their) customers”. If they cannot “provide reasonable, reliable, and 

satisfactory service to (their) customers” at a height below 150’ then how can other 

service providers? The Village Code states that a pole at 150’ needs to be able to 

accommodate 4 antennas. I have spoke to cell tower professionals and found out 

that antennas need to be separated by 10’-15’ (Verizon typically wants 15’), 

depending on the frequencies being used. Even assuming that the 10’ separation 

can be obtained, this means that the lowest antenna would be at 120’. The burden 

of proof is for Arcadia to demonstrate that other carriers can “provide reasonable, 

reliable, and satisfactory service to (their) customers” with an antenna at 120’. 

Mr. John B. Scola from Cincinnati Bell Wireless has provided a letter stating their 

intention to collocate on the monopole. I spoke to Mr. Scola regarding this matter. 

He said that he is not an RF engineer, rather he works in the real estate division. I 

asked him about the height of the pole and if they were using some other technology 

that allowed them to go lower on the pole and still provide reliable service. He said 

that they may use different frequencies, but that they are using the same basic 

technology as Cricket. He also said that when he is evaluating a location, they 

always want the highest position they can get, but due to height restrictions or 

community opposition, you have to reduce the height of the antennas. The lower 

you go on the pole, the more dropped calls you get from phones transferring from 

one antenna to another. 

In this case, CBW’s preference would be to locate as high on the pole as possible, 

but their letter of support recognized that in his words “they could live with 140’”. I 

did not ask him if he could live with 120’ because he is not an RF engineer. He said 

that he would send me some coverage maps at different heights, but I have not 

received those yet. 

a) Staff response: please see Stratum Tower report. 

b) Please see attached response from Cricket Communications. Additionally, Section 

1263.06(a) states that applicant shall demonstrate that the tower “is no higher than 

necessary to function satisfactorily and to accommodate the co-location requirements 

as set out in Subsection 1278.06(f).” As the Village of Evendale Ordinance 04-37 has 

no Subsection 1278.06(f), there is no co-location requirement in Section 1263.06(a). 

Arcadia has designed the tower to meet the requirements of Section 1263.06(F)(3.) 

which requires that the tower “be designed, engineered and constructed to support 

antennas installed by at least four cellular or wireless communications service users.” 

There is NO requirement in the ordinance that the applicant demonstrate that any 

other applicant will be able to provide any type of service. 

c) Staff response II: Evendale statute requires co-location. 

4. The last time Arcadia came before the Planning Commission, I had asked that they 

provide coverage maps for elevations at 140’, 130’, and 120’. At that time, it was 

acknowledged that they would do that. In my opinion, Arcadia has not yet satisfied 

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the requirements of 1263.06(a), but could do so be providing coverage maps and/or 

a letter of intent from another carrier to collocate at this site with an antenna at 

120’. 


b. Arcadia response: Please see Cricket Communications response to Stratum which 

includes RF propagations at 120’. 

5. Arcadia has NOT provided any documentation to show why the Search Ring must 

be located in the area they are specifying. They have provided no documentation to 

show why the search ring must be in this location or why the search ring could not 

be located in the close commercial areas in Blue Ash? 



Additionally, please see the previous testimony of Arcadia and Cricket 

Communications and the information provided during that hearing. Cricket provided 

in the August 2008 Statement of Need for Wireless communications facility located 

in Evendale Ohio a “drawing showing the boundaries of the area around the proposed 

location which would probably also permit the antenna to function properly in the 

company’s grid system” in accordance with Village of Evendale Ordinance 1263.05 

(A). Cricket provided detailed RF maps which showed the location of its existing 

sites (including the site in the commercial areas of Blue Ash), the location of the 

Search Ring and demonstrated through RF maps why the tower must be in the 

proposed location. 

6. There are numerous discrepancies in the documents regarding the size of the 

footprint needed for a tower site. The original Evendale Gateway proposal was 

45X45; the Rear of Rest Haven is 50X100 and the Maintenance Shed is 50X60. 

Even within the same location there are inconsistencies on the size of the footprint 

needed. The goal should be to minimize the site footprint. 


b. Arcadia response: No application has been filed by Arcadia Communications for 

either the Evendale Gateway location or a maintenance shed location. Per Ordinance 

1263.06 (F) #3, last paragraph Arcadia, “must demonstrate that the area of acquired 

by lease or otherwise acquired for the use and construction of the cellular tower and 

accessory structures is sufficient in size to accommodate any additional structures that 

may be required if additional users are added to the tower.” As shown in Arcadia’s 

August filing of site plans, Arcadia has demonstrated that the lease area will 

accommodate additional equipment cabinets or shelters of 5 carriers. The size of the 

proposed compound is 50’ x 100’. 

7. If a 150 ft tower is required by Cricket, how will 3 or 4 other carriers find it 

beneficial to locate on this tower? 





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8. In order to close coverage gaps, do you always look for just one location, or do you 

co-locate on multiple towers? 



9. How many customers do you have in the Village of Evendale? How many POPs do 

you need now? What is the coverage subscriber? What is meant by the number 

7,6785.17 on the current cricket coverage slide??? Is this a typo? When you 

indicate covered subscribers for the entire area, what is the entire area you are 

referring to? The whole map? Just the additional coverage by the proposed tower? 

What? 



10. You indicated that as a 1900MHz carrier, you must have as a minimum a 150 foot 

tower, is this correct? You indicated that you requested a taller tower, but were 

rejected. Did you ask for a site with a higher elevation? It would seem logical to 

believe that by putting the tower at a point in the cemetery that is at a higher 

elevation, you would effectively get a ‘taller’ tower. Is this the case? 



11. You indicated that you could not meet your coverage needs without having a 150 

foot tower, but that Cincinnati Bell could co-locate because they had a different 

frequency (800-850MHz I believe). Is this correct? Of the remaining carriers that 

service the 45241 zip code, which of them could successfully co-locate with a 

sufficient coverage area on the bottom 3 locations on the proposed tower? 


b. Arcadia response: Arcadia has designed the tower to meet the requirements of Section 

1263.06(F) (3) which requires that the tower “be designed, engineered and 

constructed to support antennas installed by at least four cellular or wireless 

communications service users.” There is NO requirement in the ordinance that the 

applicant demonstrate that any other applicant will be able to provide any type of 

service. 

PLANNING/ZONING 

1. Can we get bench mark cell tower zoning language from other communities, 

especially regarding set backs, height, order of search, etc. 

a. Staff response: The zoning requirements applicable to this particular application are 

the existing zoning regulations in Chapter 1263 that were in place at the time that 

Arcadia submitted the application. Any future amendments and refinement to 

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Chapter 1263 would only be applicable to any applications submitted following 

Council’s adoption of those amendments. 

b. Arcadia Response: Not applicable to our application. 

2. There are a number of items that were not provided or not answered when 

requested: 

Please provide a complete copy of FAA’s Determination of No Hazard to Air 

Navigation Form 7460-1/2. The copy submitted to the EPC during testimony was 

incomplete (missing pages 3, 6, and 7). 

Please provide documentation of coordination with the Ohio Historic Preservation 

Office and interested tribal authorities. Applicant submitted a response letter from 

OHPO, but not the information that was submitted to the OHPO. Applicant was 

asked during the presentation about the tribal coordination and promised to 

respond or address that in the presentation but failed to do so. 

a. Arcadia Response: As noted in the Tower Review Summary Report October 30, 

2008, page 4 Section 4.1, 6 th bullet point, Village of Evendale expert Stratum 

Broadband notes: “It appears that all standard site development processes have been 

properly managed including lease documentation, site surveys, Phase 1 

Environmentals, SHPO Review, FAA Analysis, etc.” Attached is a complete copy of 

the Determination of No Hazard from the FAA for Aeronautical Study No. 2007- 

AGL-9870-OE dated 4/18/2008 (attached as Exhibit A), along with a Determination 

of No Hazard dated July 1, 2008 (attached as Exhibit B) making the determination 

final in response to petitions received and extending the expiration date to January 10, 

2010. The 7460-1 is the application for a Determination of No Hazard that Arcadia 

filed with the FAA and a copy can be obtained from the FAA web site. A copy was 

included in Arcadia’s August filing in a memorandum to the Evendale Planning 

Commission dated August 2008 from Samuel T. Johnston, Jr. as Exhibit 9. The 

7460-2 is the form that Arcadia will be required to submit to the FAA within 5 days 

after the construction reaches its greatest height, and therefore has not been filed (see 

check box on FAA Determination of No Hazard dated 4/18/2008). 

b. Arcadia Response: As noted in the Tower Review Summary Report dated October 

30, 2008, page 4 Section 4.1, 6 th bullet point, Village of Evendale expert Stratum 



Environmentals, SHPO Review, FAA Analysis, etc.” Arcadia is required by state and 

federal law to comply with SHPO and tribal notice requirements and has done so. 

3. I do not believe that the EPC can approve this application given Section 1263.09(a) 

which states: (a) No cellular or wireless communications tower shall be permitted 

on any lot on which any nonconforming building or structure is located or on which 

any nonconforming use or activity is occurring without first obtaining permission 

from the Village Board of Zoning Appeals. 

a. Staff response: The proposal would require the approval of the Board of Zoning 

Appeals per Section 1263.09(a). Rest Haven has two existing nonconforming 

structures: the front yard fence (fences are not permitted in front yards), and the 

concrete storage vaults that are being stored to the rear of the property. These vaults 

constitute “outdoor storage” which is not permitted in the “R” Residential District. 

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. Arcadia Response: Staff has erroneously asserted that there are nonconforming uses 

on the Rest Haven parcel in question regarding Section 1263.09 (a). Please see 

attached letter to Jack Cameron dated November 7, 2008 from Joseph Trauth, 

Attorney for Rest Haven. 

c. Staff response II: As confirmed with Joe Trauth, legal counsel for Rest Haven 

and Arcadia, the outdoor storage of the burial vaults is a legal non-conforming 

use. Because that nonconforming use exists, the application must be approved 

by the Zoning Board of Appeals. 

4. Kathy Farro’s report clearly identifies that there are non-conforming structures on 

the site and therefore, this application is prohibited unless the Village Board of 

Zoning Appeals gives permission. 






b. Arcadia Response: Staff has erroneously asserted that there are nonconforming uses 








5. There are locations on the Rest Haven property that are 600 feet from any 

residential property NOT owned by Rest Haven. They should show each of these 

locations and indicate why they cannot be used. It appears that rest Haven has 

chosen a location to give favorable appearance to their property while disregarding 

adjacent property owners. 

a. Arcadia Response: See response in 7 (b) below. 

b. Staff Response II: Question not answered as to why locations further from 

adjacent residential houses cannot be used. 

6. Clarification is needed on the ownership of properties located on the corner of 

Glendale-Milford and Plainfield as it relates to the adjacent property diagram (for 

both site plans). 

a. Staff response: Please see property owner attachment. 

b. Arcadia Response: See drawing labeled C6- Adjacent Property Plan in the Arcadia- 

Evendale which lists the ownership of all properties adjacent to the property in 

question as required by the ordinance 1263.06 (J) (13). There is no reference in the 

ordinance to properties adjacent to properties owned by the owner of the property in 

question. The properties listed on the attachment are not adjacent to the property in 

question. 

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7. Marshall Slagle Planning was paid to render his opinion and did not address the 

question asked on the intent of the Evendale ordinance on set back requirements in 

a residential area. 

a. Staff response: The intent of the code language in 1263.04(c) is to buffer uses in 

residential districts (particularly residential uses) from the adverse effects of 

telecommunications towers to the maximum extent possible. 

b. Arcadia Response: See Item #2 in Summary Response to Staff List of Application 

Issues dated August 2008 which references Marshal Slagle Report and testimony 

regarding the setback filing, and Marshall Slagle response to setback as a prohibition 

of service attached hereto as Exhibit C. The zoning code section 1263.04 (C) reads: 

“Cellular or wireless communications sites in a zoning district or area where such use 

is permitted shall be located any closer to any residential zoning district than as 

follows: (1) if a Cellular or wireless communications tower is 100’ or less in height, 

the site shall be located no closer than 500 feet to any residential zoning district; (2) 

For any cellular or wireless communication tower exceeding 100 feet in height, the 

site may not be located closer to any residential zoning district than a distance equal 

to 500 feet plus 2 feet for each foot of height that the tower exceeds 100 feet.” 

Arcadia’s proposed site is located in a residential (R) zoning district. Per 1263.04 

Use Regulations, cellular or wireless communications sites may be permitted in (R) 

district. Since the site is located in (R), it cannot possibly be set back from the (R) 

district. 

c. The intent of Section 1263.04 is to minimize the adverse impacts that wireless 

communication may have on residential uses to the greatest extent possible. The 

intent of this is achieved in two ways: 

(1) By requiring towers, when possible, to locate within one of 

the districts listed in §1263.04(a)(1) through (5) rather than 

within a residential district; and 

(2) By ensuring that all towers, regardless of district, are at 

least 500 feet (or more, depending on height) from residential 

uses. 

8. The summary of response to the Staff report does not address the issue of nonconforming 

structures already on the property as grounds to PROHIBIT a cell 

tower anywhere on the Rest Haven Property. 














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9. We believe that the Planning Commission should allow/encourage Arcadia to 

modify their current application to include BOTH the Rear of Rest Haven Location 

and the Maintenance Shed location. 

a. Staff response: Arcadia has presented various documents indicating a possible 

proposal for a tower at the Gateway site. Until the applicant formally submits this 

proposal per the requirements of Chapter 1263, the Village’s responsibility rests 

solely on evaluating the merits of the current proposal for the larger Rest Haven 

parcel. 

b. Arcadia Response: Arcadia agrees with Staff Response in 9 (a) above. Arcadia 

refers to the maintenance shed location as the “Rest Haven alternate site” and the 

property owned by the Village of Evendale located at the northwest corner of 

Glendale Milford and Plainfield Roads as the “Evendale Gateway” site. Arcadia 

previously prepared proposals to locate a flagpole type tower at the Evendale 

Gateway site to the Village of Evendale. The history and copies of those proposals 

can be found in the previously filed memo to the Village of Evendale Planning 

Commission dated August 2008 from Samuel T. Johnston, Jr., in the text of the 

memorandum and in Exhibits 1 through 7. Arcadia’s proposal for a tower at the 

Gateway location was not accepted, and we were directed by the Village to the Rest 

Haven location per the minutes of the Evendale Council on August 9, 2007, included 

in the August 2008 memo as Exhibit 7. Also noted in the memorandum is 

information regarding the Rest Haven Alternate Site, including balloon fly, discussion 

with residents, aeronautical study, and resident meeting performed by Arcadia. 

Arcadia further agrees with the Tower Review Summary Report October 30, 2008, 

Section 2.1, bullet point 6 which states “If a site is necessary in this area, the 

cemetery seems to be the logical location for placement”. 

c. Staff response II: The Village can only react to those applications submitted for 

review. Please note in Arcadia’s response that they continues to mis-lead and 

inaccurately represent the reference to Rest Haven at the conclusion of their 

initial request to put the wireless antenna pole on Village property. Arcadia was 

not directed anywhere by the Village. Please see the attached minutes from the 

August 9, 2007 Regular Council meeting. Direct except from minutes: 

Mayor Apking discussed Arcadia Communications, LLC Cell Tower 

proposal for Plainfield and Glendale-Milford Road. The proposal 

includes construction a flag pole that is a cell tower 140 ft. tall. Jack 

Cameron explained that Arcadia came in and asked for the Village’s 

regulations on cell towers. They would pay $7,200 per year for five 

years and then would ask for nine five-year renewable terms so it could 

last potentially fifty year. We have asked them to incorporate the 

gateway signage in the design. Mr. Puthoff said it was ubly. Mr 

Schaefer stated that the Federal Government said that the cell towers 

can go in if they have a property owner, including home owners, 

interested regardless of zoning. If we turn down they can approach Rest 

Haven or Evendale School or one of the churches along Glendale- 

Milfrod. Mr. Puthoff said he would rather see it in his backyard against 

the cemetery than in the Village gateway because it is not as noticeable. 

Council did not want the cell tower in the gateway. 

MISCELLANEOUS 

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1. Could the tower at Raymond Walters be increased to allow higher frequency 

carriers? Has Blue Ash been approached about a cell tower site in any of 

their commercial, recreational, or educational areas? Blue Ash golf course, 

Raymond Walters, Lake Forrest commercial buildings, etc? 

a. Arcadia Response: Please see attached response from Cricket Communications. Per 

the Statement of Need for wireless communications facility located in Evendale Ohio 

dated August 2008 submitted by Gregory Wahl, RF Engineer for Cricket 

Communications, Inc. the Raymond Walters tower is outside of the allowable zone. 

Per the same report, Cricket is currently located on a rooftop at 4445 Lake Forest 

Drive, and this area is also outside of the allowable zone. Further, Arcadia further 

agrees with Stratum Broadband’s Tower Review Summary Report October 30, 2008, 

Attachment B, response (2), second paragraph: “Search rings are usually determined 

after considering the location of existing towers, the terrain, coverage objectives, and 

budget. They can range from a radius of 0.5 to 3 miles or more depending on various 

factors. Since this site appears to be required for coverage improvement rather than a 

new network buildout, it would not be uncommon for the requirement of a more 

precise placement”. Additionally, see the attached response from Cricket 

Communications regarding the tower at Raymond Walters. 

2. Where is the documentation for the property value study impacted by cell towers? 

a. Arcadia Response: See Galloway Appraisal letter to David Pike dated August 14, 

2008 included in previous filing. 

3. What reason did the FAA provide to reverse their denial of the tower originally? 

a. Arcadia Response: See the Determination of No Hazard from the FAA for 

Aeronautical Study No. 2007-AGL-9870-OE dated 4/18/2008 (attached as Exhibit 

A). Also noted in the Tower Review Summary Report October 30, 2008, page 4 

Section 4.1, 6 th bullet point, Village of Evendale expert Stratum Broadband notes: “It 

appears that all standard site development processes have been properly managed 

including lease documentation, site surveys, Phase 1 Environmentals, SHPO Review, 

FAA Analysis, etc.” 

b. Staff response II: Question was not answered. 

4. In February, I asked how many Cricket users are in the area and how many 

complaints have been received about poor coverage? 

a. Arcadia Response: see 5 (a) below. 


5. Gregory Wahl testified that there have been numerous customer complaints and 

requests to Cricket for additional/better service in the area. At previous public 

hearings and again at this last public hearing, citizens have requested some factual 

back up of that claim. I believe that it is a reasonable request and if provided will 

bolster the testimony of Mr. Wahl. I understand that sometimes this information is 

proprietary, but I am sure they can give show some statistics on this since they have 

continuously used this as a central argument for the project. 

a. Arcadia Response: Per the Statement of Need for wireless communications facility 

located in Evendale Ohio dated August 2008 submitted by Gregory Wahl, RF 

Engineer for Cricket Communications, Inc. Cricket has demonstrated a lack of 

coverage in their service area due to the coverage gap in Evendale, and has a right to 

provide reliable wireless service per its FCC license. Arcadia further agrees with the 

Stratum Broadband Tower Review Summary Report October 30, 2008, Section 4.1, 

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ullet point 1, which states “Drive testing was performed by Cricket to verify the 

service gap.” 


6. The documentation provided from the Ohio Historical Society indicates the tower 

would be 190 feet. 

a. Arcadia Response: That is the height at which we filed with State Historic 

Preservation Office (SHPO); the tower we are proposing to build is 150’. As noted in 

the Tower Review Summary Report October 30, 2008, page 4 Section 4.1, 6 th bullet 

point, Village of Evendale expert Stratum Broadband notes: “It appears that all 

standard site development processes have been properly managed including lease 

documentation, site surveys, Phase 1 Environmentals, SHPO Review, FAA Analysis, 

etc.” 

b. Staff response II: Stratum technical review is not pertinent to this question. 

Stratum’s stated purpose was defined in the very beginning of their report. 

Purpose - This report reviews all submittals for the proposed tower 

site(s) to ensure that all proper due diligence was done for compliance 

with engineering standards used across the telecommunications 

industry. This review was conducted by Stratum Broadband LLC 

principals, John Foresto and Eugene Currie, each with over thirty years 

experience in the industry. Resumes for both are included as Attachment 

A. 

7. Page 3 of 7 of the FAA documentation provided is missing. 


Aeronautical Study No. 2007-AGL-9870-OE dated 4/18/2008 (attached as Exhibit 

A). As noted in the Tower Review Summary Report October 30, 2008, page 4 

Section 4.1, 6 th bullet point, Village of Evendale expert Stratum Broadband notes: “It 


including lease documentation, site surveys, Phase 1 Environmentals, SHPO Review, 

FAA Analysis, etc.” 

8. The documentation labeled as the Evendale Gateway Plans appears to actually be 

the Rear of Rest Haven location. 

a. Arcadia Response: The Proposed Wireless Communications Facility site plans 

submitted in August 2008 are erroneously labeled “Evendale Gateway” and should 

read “Rest Haven”. 

9. The documentation labeled as #3 appears to actually be the Rest haven Maintenance 

Shed location. 

a. Arcadia Response: No response, unsure of what documentation is being referenced. 

10. There are no corresponding maps provided for the vicinity lot lists provided (for 


a. Arcadia Response: See drawing labeled C7- Vicinity Lot List in the Arcadia- 

Evendale which identifies all buildings and structures on adjacent lots and any 

additional lot within 500’ and the owners as required by the ordinance 1263.06 (J) 

(13). Drawing also includes approximate elevation of highest point of each building 

or structure. 

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11. The coverage maps provided throughout the documentation are misleading as they 

have different scales. Documentation should be provided with the existing coverage 

and then the ability to do overlays showing increased coverage by adding to existing 

locations or adding new locations. 



Engineer for Cricket Communications, Inc. Cricket has demonstrated a lack of 

coverage in their service area due to the coverage gap in Evendale, and has a right to 

provide reliable wireless service per its FCC license. Arcadia further agrees with the 

Stratum Broadband Tower Review Summary Report October 30, 2008 in which no 

mention was made of any issues regarding the scale of the maps in the above 

referenced coverage maps. 

b. Staff response II: Does not answer the question. Maps with consistent scale were 

requested for review purposes. Stratum was not engaged to comment on each 

and every issue and whether Stratum made note of this or not does not relieve 

the applicant from responding to a Planning Commission request. 

12. Cricket sites incremental customers -- they do not indicate if this would increase 

actual overall market penetration in the area or their market share. If they 

currently have less than 3% share in the zip code – how much of the market is unserved 

by them or other carriers? 

a. Arcadia Response: See attached response from Cricket Communications. 

13. Cricket sites communication needs of our community - who had defined these needs 

and what are they? 


14. Cricket document contains 3 set of the same memo – why? 

a. Arcadia Response: 2 extra copies submitted erroneously. 

15. An Edwards Kelsey Report is referenced –we would like a copy. 

a. The Edwards Kelcey study was done for the Village of Evendale, a copy of the page 

with the traffic count is attached as Exhibit D. 

16. Cricket sites files they got from Claritas – we would like them to provide these files. 


17. The Galloway report sites studies -- it should be required that they provide the 

actual studies for review. The Galloway report states that “we know of no study 

that suggests that such objects cause a diminution in value of residential 

properties”. This statement/opinion is in question when a quick search of the 

internet reveals: 

a. Arcadia Response: We are not aware of this study. PIKE TO REVIEW. 

The effect of distance to cell phone towers on house prices in Florida. 

by Bond, Sandy 

Appraisal Journal • Fall, 2007 • 

ABSTRACT 

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This article outlines the results of a study carried out in Florida in 2004 regarding 

the effect that cell phone tower proximity has on residential property prices. The 

study involved an analysis of residential property sales transaction data. Both GIS 

and multiple regression analysis in a hedonic framework were used to determine the 

effect of linear distance of homes to towers on residential property prices. The 

results of the research show that prices of properties decreased by just over 2%, on 

average, after a tower was built. This effect generally diminished with distance from 

the tower and was almost negligible after about 656 feet. 

18. The Marshall report refers to an occupied structure within 300 feet –that structure 

is the Behbehani residence! 

a. Arcadia Response: No response. 

19. Tower dimensions are not consistent – what is base measurement and top 

measurement of mono-poles? 

a. Arcadia Response: Per 1263.06 (J) (13), Arcadia has previously submitted the Sabre 

Structural Design Report dated August 14, 2008 and the Report of Structural 

Considerations by William E. Grigsby submitted in August 2008. 

b. Staff response II: Did not answer the question. 

20. We would like to request the Evendale Council Videos for the council meetings of 

9/20/07 and 12/04/07 as these minutes indicate council discussed the tower and we 

would like to see the full discussion. 

a. Arcadia Response: Arcadia also requests a copy of the video tapes from this 

council meeting. 

b. Staff response II: Public Records requests are made with the Village Clerk, 

Barb Rohs at 10500 Reading Road, Evendale, Ohio (513) 563-2244. 

21. Since the Crown tower was installed prior to our ordinance is there now a way to 

increase the height of that tower to meet Cricket’s needs? 

a. Staff Response: The Village’s approval of any telecommunications tower is 

predicated on a private agreement between tower owners and the owners of the 

property that is to be built upon, or a tower owner’s private purchase of land for tower 

development. Any alterations to Crown Tower are at the discretion of the parties that 

control the Crown Tower. 

b. Arcadia Response: Village of Evendale Ordinance 1263 has no provision for 

replacing an existing tower. 

c. Staff response II: Did not answer the question. Can the Crown tower location be 

used to accomplish what is being proposed for Rest Haven? 

22. Documentation should be provided from tower owners that refused collocation or 

locating a new tower on property. 



Engineer for Cricket Communications, Inc. there are no towers that meet Cricket’s 

service requirements that are located in the allowable zone. 

b. Staff response II: Did not answer the question or provide documentation 

showing refusals from potential property owners to place the tower. 

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23. There are many discrepancies in the distance the tower is from residents(example 

Behbehani shows 300 ft on one document and 275 on another. 

a. Arcadia Response: See Proposed Wireless Communications Facility by Arcadia 

Towers, LLC, page C1 dimension plan which shows the survey of the setback from 

certain residential structures. 

24. Rest Haven has been a good neighbor and none of us objected when they were 

granted multiple variance to expand the nature of their business within their 

industry. They are now asking for additional variances to expand there income 

through non-core activities to the detriment of their neighbors. 

a. Staff Response: Rest Haven has not specifically requested any variances. 

b. Arcadia Response: No Response. 

25. The Evendale gate way location is outside of the “Search Ring” so why was this 

location considered? 



Engineer for Cricket Communications, Inc., see page titled “Search Ring #280” 

which indicates that Evendale Gateway is within the search ring. 

26. There are discrepancies in the current coverage map provided in various 

documents. 

a. Arcadia Response: See 11 (b) above. 

27. In the 9/20/07 council minutes Mr. Puthoff said” he would rather see it in his 

backyard against the cemetery than in the Village Gateway because it is not as 

noticeable”. Since Mr. Puthoff provided his inputs as an owner than the 

Maintenance shed locations allows it to be 600 feet away form all other residential 

properties not owned by Rest Haven. Residents were not given the opportunity to 

voice their opinion on the Gateway location. 

a. Staff Response: Arcadia has presented various documents indicating a possible 




parcel. 

b. Arcadia Response: See Planning/Zoning section 9 (b) above in reference to the 

Gateway location. 

28. Lynn Nordstrom, Verne Kreger and I have thought about Jack Cameron’s offer of 

outside expertise and where particularly we feel that expertise could be used most 

effectively. From our point of view there are three areas that could be reviewed 

more thoroughly for everyone’s benefit. Those three are: 

a. Zoning Issues, specifically setbacks, non-conforming structures, and variance 

issues within the application. 

i. Staff Response: According to Village records, Rest Haven has not 

requested nor been issued any variances. Setback issues are addressed in 

the previous staff report. The proposal would require the approval of the 

Board of Zoning Appeals per Section 1263.09(a). Rest Haven has two 

13

existing nonconforming structures: the front yard fence (fences are not 

permitted in front yards), and the concrete storage vaults that are being 

stored to the rear of the property. These vaults constitute “outdoor 

storage” which is not permitted in the “R” Residential District. 

ii. Arcadia Response: Staff has erroneously asserted that there are 

nonconforming uses on the Rest Haven parcel in question regarding 

Section 1263.09 (a). Please see attached letter to Jack Cameron dated 

November 7, 2008 from Joseph Trauth, Attorney for Rest Haven. 

iii. Staff response II: As confirmed with Joe Trauth, legal counsel for 

Rest Haven and Arcadia, the outdoor storage of the burial vaults is a 

legal non-conforming use and would require the application to be 

reviewed by the Zoning Board of Appeals. 

b. Acoustic Engineering Studies 

i. Plantings should include evergreens that sufficiently shield the base of the 

tower from the abutting residential and go beyond the minimum required 

by the code. This may also be achieved as part of a variance request to 

ZBA. Residents have reported fairly substantial visibility through the 

bases of the trees to this area, particularly in the winter. 

ii. Arcadia Response: Not sure what is being asked for here. 

c. Mitigation factors such as planting, painting, fencing, etc. 

i) Arcadia Response: See Proposed Wireless Communications Facility 

by Arcadia Towers, LLC, page L1 landscaping plan, which shows the 

existing berm and proposed evergreen plantings around the perimeter of 

the compound area and C4 which shows the fencing detail with a 6’ 

shadowbox fence surrounding the compound and page C4 which shows 

the fencing detail with a 6’ shadow-box fence surrounding the compound, 

complies with Village Ordinance 1263.06 (E) Landscaping which states 

that a landscaping plan shall “…screen as much of the support structure 

and ground level features as possible. In addition, existing vegetation on 

and around the site shall be preserved to the greatest extent possible.” 

Our feeling is that the zoning issues attached to this case are significant enough to 

warrant a review by outside legal counsel and that a competent sound engineer 

conduct field test to validate generally the findings of the Arcadia engineers. Finally 

we think that a study of how best to mitigate these kinds of projects to the 

surrounding neighbors in terms of planting and materials would be in order. All of 

this is obviously predicated on sufficient monies being available. 

i) Arcadia Response: See (C) above. 

29. When you speak of Cricket communications having the right to operate its wireless 

communications network in a licensed area. What is meant by that? If there is no 

landowner willing to lease land for a tower in one of your dead zones or ‘Gaps’, 

what options does Cricket have? (Comment: Blue Ash apparently has a lock on all 

of the available land, what will they do about dead zones there? There must be 

other options to tall towers.) 

a. Arcadia response: See attached response from Cricket Communications. 

14

30. What do you mean by degraded E911? Do you know of an instance where E911 

locating in this area of Evendale has been degraded due to poor reception? Can you 

provide documentation? 


b. Staff response II: Did not answer question. Documentation was requested and not 

provided. 

31. Cricket sites customer complaints as justification and provides no DATA to support 

these claims. 


b. Arcadia Response: See attached response from Cricket to #29 above. 

Also, shown below are the results of field testing of a Cricket phone submitted to the 

Planning Commission by residents Susan deRoos and Sheri Torbeck. The data 

gathered shows no evidence of service gaps when the Cricket service was utilized. 

Via email from Susan deRoos to Jack Cameron dated September 22, 2008: 

I purchased the basic lowest price model of Cricket Cell phone 513-386-4880 and 

purchased NO roaming minutes. When I purchased the phone I was shown a coverage 

map that indicated there would be no coverage in certain area with out purchasing a 

roaming package. 

Utilizing the current Cricket coverage map provided by Cricket in the Cricket 

Communications Search Ring CVG-280 Evendale, Ohio RF Engineering study of August 

2008, Shari Torbeck and I used the map to go to locations within the white areas on map 

(per the map “the white area indicate lack of Cricket Coverage”). 

We placed the following calls successfully leaving voice mail messages each time on 

Shari’s cell phone. 

Time Location from which call was placed 

1:20 pm 3753 Monet’s Lane 

1:24 10500 Reading Road (village Municipal Building) 

1:37 Griffith Nature (Wyscarver ) 

1:39 Corner of Sunders Park and Wyscarver 

1:45 Rest Haven Cemetery by the stacked vaults 

1:50 8-9 Hollow Oak (Carpenters Run) 

1:53 Corner of Trailbridge Dr and Carpenters Run 

1:57 Corner of Cooper Road and Carpenters Run (bad reception 

but still able to easily place call) 

1:59 Intersection of Carpenters Green Lane and Mohler Road 

2:02 Corner of Carpenters Creek Drive and Pond Side Ct. 

2:10 Corner of Beavercreek Circle and Robindale Drive 

2:18 Corner of Kingsport Dr and Sherbrook Drive 

2:22 3836 Monet’s Lane 

All calls were made, voice mails recorded of each call, no roaming charges were paid and 

all were made within areas Cricket claims to have lack of coverage. 

15

In order to demonstrate that the Cricket Phone (513-386-4880) could receive as well as 

make calls in the Cricket lack of coverage areas, we conducted a second test. Test 

number 2 included making the following calls from 513-505-8901 (A Verizon cell) to the 

Cricket Cell (513-386-4880) while in the following locations: 

All calls were made on September 22, 2008: 

Time Location of the Cricket Cell when receiving the Call 

5:00 pm 3753 Monet’s Lane 



5:37 Corner of Sanders Park and Wyscarver 











All calls were placed by Susan de Roos using Cricket cell 386-4880 and received by Kay 

Bostrom using Verizon cell 505-8901, no roaming charges were paid and all were made 

within areas Cricket claims to have lack of coverage. 

16

EXHIBIT A 

FAA DNH 4/18/2008 

17

EXHIBIT B 

FAA DNH JULY 1, 2008 

18

EXHIBIT C 

MARSHALL SLAGLE SETBACK LETTER 

19

EXHIBIT D 

EDWARDS KELCEY SLIDE OF TRAFFIC COUNTS 

20

November 13, 2008 

Ms. Farro, 

Kathy 

Here is Stratum’s response to the Arcadia, Cricket, and Cincinnati Bell 

documents dated from 11-03-08 to 11-10-08. 

Arcadia Response to the Planning Commission Antennae Review: 

1. Alternative technologies (such as DAS) are an effective way to 

resolve these types of issues of coverage in residential areas. 

Arcadia seems correct that there is nothing in the ordinances to 

force them to even consider other technology alternatives. The 

ordinance might be modified to include this as a consideration in 

residential zones. 

2. Arcadia states that “there is NO requirement that the applicant 

demonstrate that any other applicant will be able to provide any type 

of service.” Although technically correct, what is the sense of 

putting in a collocated tower facility if it cannot provide service to the 

number of carriers for which it was designed? The ordinance 

should be tightened to specifically state the heights that will be 

available to other carriers and show RF coverage plots for those 

locations. 

3. Comment on Susan’s calls: No test calls were made indoors. 

Arcadia Follow-up Submittal: 

1. Is there any relationship between alternative technical solutions and 

Ordinance 1263? 

Cricket Response to Summary Document: 

1. Cricket states that they need this tower to meet their 911 calling 

objectives. Have the Ohio authorities issued a letter to Cricket 

demanding that they meet Phase II E911 requirements? 

Arcadia Response to Stratum Broadband: 

1. The sims photos appear to all have leaves on the trees. As 

previously discussed they have not provided sims without leaves. 

They stated they did the photos for the sims in early November 

2008? Did they mean 2007? Since this is fairly close to residential 

homes, having sims without leaves may eliminate any fears of the 

residents. 

2. Why would you need an ordinance to do a “drop and swap” for a 

tower replacement? 

116 Main Street • Suite 201 • Medway, Massachusetts 02053 • Phone: 508.533.6830 • Fax: 508.533.6436 • www.stratumbroadband.com

Arcadia Response to Stratum Broadband Summary Report of October 12, 

2008: 

1. No comments. 

Cricket Response to Stratum Broadband Sections 2 – 4 

1. Their RF plots for 120 ft, 140 ft, and 150 ft show that the 150 ft 

height is needed to provide the best coverage in the area. 

2. Agree – other existing sites do not meet their coverage objectives. 

Cincinnati Bell Presentation 

1. CBW RF plots show that a radio base station at the proposed site 

will improve their coverage. Their slides are easily viewed to show 

the difference of coverage between sites. 

Recommendations 

1. Consider review and possible tightening of the ordinances for 

residential areas 

116 Main Street • Suite 201 • Medway, Massachusetts 02053 • Phone: 508.533.6830 • Fax: 508.533.6436 • www.stratumbroadband.com

Arcadia Towers November 10, 2008 Response to 


Arcadia Communications 


The list of questions below is a compilation of questions from Planning Commission residents, 

staff and residents. The Village of Evendale Planning Commission desires to have this list 

function as a working list of questions and answers to better review the Arcadia Wireless 

Antenna placement on Rest Haven Memorial Park property in the Village of Evendale. 

Questions are sorted into Technical, Planning/Zoning and Miscellaneous. The questions are in 

no particular order nor are they numbered by importance. Numbering and categorizing are done 

for clarification and clarification only. Once complete, this list should contain Question, Staff 

Response, Applicant Response and for some questions Staff 2 nd Response. 

Arcadia Response: Arcadia Responses to each question are noted below in blue text. Expert 

responses and additional information provided will be attached hereto as Exhibits. 

TECHNICAL 






a. Staff response: please see Stratum Tower report 




b. Arcadia Response: Please see attached response from Cricket Communications. 

Cricket provided in the August 2008 Statement of Need for Wireless communications 

facility located in Evendale Ohio a “drawing showing the boundaries of the area 

around the proposed location which would probably also permit the antenna to 

function properly in the company’s grid system” in accordance with Village of 

Evendale Ordinance 1263.05 (A). 

3. I do not believe that the applicant has fulfilled one of the primary standards for 

approval. Section 1263.06(a) of the Village Code is provided below: 

Arcadia Response 11-10-2008 

1 

(a) Antenna/tower height. The applicant shall demonstrate that the planned 

height of a cellular or wireless communications tower is no higher than 

necessary to function satisfactorily and to accommodate the co-location 

requirements as set out in division (f) of this section. No tower that is 

taller than the necessary height shall be approved, and the height of any 

tower to be greater than 200 feet must first be approved by the Planning

Commission. Cellular towers shall be monopole construction unless it is 

demonstrated upon application that another type of tower is required for 

safety purposes and it has been approved by the Planning Commission. 

Mr. Wahl has testified that Cricket needs their antenna to be at the top of a 150’ 

tower at the Rest Haven sites to “provide reasonable, reliable, and satisfactory 

service to (their) customers”. If they cannot “provide reasonable, reliable, and 

satisfactory service to (their) customers” at a height below 150’ then how can other 

service providers? The Village Code states that a pole at 150’ needs to be able to 

accommodate 4 antennas. I have spoke to cell tower professionals and found out 

that antennas need to be separated by 10’-15’ (Verizon typically wants 15’), 

depending on the frequencies being used. Even assuming that the 10’ separation 

can be obtained, this means that the lowest antenna would be at 120’. The burden 

of proof is for Arcadia to demonstrate that other carriers can “provide reasonable, 

reliable, and satisfactory service to (their) customers” with an antenna at 120’. 

Mr. John B. Scola from Cincinnati Bell Wireless has provided a letter stating their 

intention to collocate on the monopole. I spoke to Mr. Scola regarding this matter. 

He said that he is not an RF engineer, rather he works in the real estate division. I 

asked him about the height of the pole and if they were using some other technology 

that allowed them to go lower on the pole and still provide reliable service. He said 

that they may use different frequencies, but that they are using the same basic 

technology as Cricket. He also said that when he is evaluating a location, they 

always want the highest position they can get, but due to height restrictions or 

community opposition, you have to reduce the height of the antennas. The lower 

you go on the pole, the more dropped calls you get from phones transferring from 

one antenna to another. 

In this case, CBW’s preference would be to locate as high on the pole as possible, 

but their letter of support recognized that in his words “they could live with 140’”. I 

did not ask him if he could live with 120’ because he is not an RF engineer. He said 

that he would send me some coverage maps at different heights, but I have not 

received those yet. 

a) Staff response: please see Stratum Tower report. 

b) Please see attached response from Cricket Communications. Additionally, Section 

1263.06(a) states that applicant shall demonstrate that the tower “is no higher than 

necessary to function satisfactorily and to accommodate the co-location requirements 

as set out in Subsection 1278.06(f).” As the Village of Evendale Ordinance 04-37 has 

no Subsection 1278.06(f), there is no co-location requirement in Section 1263.06(a). 






4. The last time Arcadia came before the Planning Commission, I had asked that they 

provide coverage maps for elevations at 140’, 130’, and 120’. At that time, it was 

acknowledged that they would do that. In my opinion, Arcadia has not yet satisfied 


2

the requirements of 1263.06(a), but could do so be providing coverage maps and/or 

a letter of intent from another carrier to collocate at this site with an antenna at 



b. Arcadia response: Please see Cricket Communications response to Stratum which 

includes RF propagations at 120’. 







Additionally, please see the previous testimony of Arcadia and Cricket 

Communications and the information provided during that hearing. Cricket provided 

in the August 2008 Statement of Need for Wireless communications facility located 

in Evendale Ohio a “drawing showing the boundaries of the area around the proposed 

location which would probably also permit the antenna to function properly in the 

company’s grid system” in accordance with Village of Evendale Ordinance 1263.05 

(A). Cricket provided detailed RF maps which showed the location of its existing 

sites (including the site in the commercial areas of Blue Ash), the location of the 

Search Ring and demonstrated through RF maps why the tower must be in the 

proposed location. 

6. There are numerous discrepancies in the documents regarding the size of the 

footprint needed for a tower site. The original Evendale Gateway proposal was 

45X45; the Rear of Rest Haven is 50X100 and the Maintenance Shed is 50X60. 

Even within the same location there are inconsistencies on the size of the footprint 

needed. The goal should be to minimize the site footprint. 


b. Arcadia response: No application has been filed by Arcadia Communications for 

either the Evendale Gateway location or a maintenance shed location. Per Ordinance 

1263.06 (F) #3, last paragraph Arcadia, “must demonstrate that the area of acquired 

by lease or otherwise acquired for the use and construction of the cellular tower and 

accessory structures is sufficient in size to accommodate any additional structures that 

may be required if additional users are added to the tower.” As shown in Arcadia’s 

August filing of site plans, Arcadia has demonstrated that the lease area will 

accommodate additional equipment cabinets or shelters of 5 carriers. The size of the 

proposed compound is 50’ x 100’. 

7. If a 150 ft tower is required by Cricket, how will 3 or 4 other carriers find it 

beneficial to locate on this tower? 





3





8. In order to close coverage gaps, do you always look for just one location, or do you 

co-locate on multiple towers? 



9. How many customers do you have in the Village of Evendale? How many POPs do 

you need now? What is the coverage subscriber? What is meant by the number 

7,6785.17 on the current cricket coverage slide??? Is this a typo? When you 

indicate covered subscribers for the entire area, what is the entire area you are 

referring to? The whole map? Just the additional coverage by the proposed tower? 

What? 





rejected. Did you ask for a site with a higher elevation? It would seem logical to 

believe that by putting the tower at a point in the cemetery that is at a higher 

elevation, you would effectively get a ‘taller’ tower. Is this the case? 



11. You indicated that you could not meet your coverage needs without having a 150 

foot tower, but that Cincinnati Bell could co-locate because they had a different 

frequency (800-850MHz I believe). Is this correct? Of the remaining carriers that 

service the 45241 zip code, which of them could successfully co-locate with a 

sufficient coverage area on the bottom 3 locations on the proposed tower? 


b. Arcadia response: Arcadia has designed the tower to meet the requirements of Section 

1263.06(F) (3) which requires that the tower “be designed, engineered and 

constructed to support antennas installed by at least four cellular or wireless 

communications service users.” There is NO requirement in the ordinance that the 

applicant demonstrate that any other applicant will be able to provide any type of 

service. 

PLANNING/ZONING 

1. Can we get bench mark cell tower zoning language from other communities, 

especially regarding set backs, height, order of search, etc. 


4

a. Staff response: The zoning requirements applicable to this particular application are 

the existing zoning regulations in Chapter 1263 that were in place at the time that 

Arcadia submitted the application. Any future amendments and refinement to 

Chapter 1263 would only be applicable to any applications submitted following 

Council’s adoption of those amendments. 

b. Arcadia Response: Not applicable to our application. 

2. There are a number of items that were not provided or not answered when 

requested: 

Please provide a complete copy of FAA’s Determination of No Hazard to Air 

Navigation Form 7460-1/2. The copy submitted to the EPC during testimony was 

incomplete (missing pages 3, 6, and 7). 

Please provide documentation of coordination with the Ohio Historic Preservation 

Office and interested tribal authorities. Applicant submitted a response letter from 

OHPO, but not the information that was submitted to the OHPO. Applicant was 

asked during the presentation about the tribal coordination and promised to 

respond or address that in the presentation but failed to do so. 

a. Arcadia Response: As noted in the Tower Review Summary Report October 30, 




Environmentals, SHPO Review, FAA Analysis, etc.” Attached is a complete copy of 

the Determination of No Hazard from the FAA for Aeronautical Study No. 2007- 

AGL-9870-OE dated 4/18/2008 (attached as Exhibit A), along with a Determination 

of No Hazard dated July 1, 2008 (attached as Exhibit B) making the determination 

final in response to petitions received and extending the expiration date to January 10, 

2010. The 7460-1 is the application for a Determination of No Hazard that Arcadia 

filed with the FAA and a copy can be obtained from the FAA web site. A copy was 

included in Arcadia’s August filing in a memorandum to the Evendale Planning 

Commission dated August 2008 from Samuel T. Johnston, Jr. as Exhibit 9. The 

7460-2 is the form that Arcadia will be required to submit to the FAA within 5 days 

after the construction reaches its greatest height, and therefore has not been filed (see 

check box on FAA Determination of No Hazard dated 4/18/2008). 

b. Arcadia Response: As noted in the Tower Review Summary Report dated October 

30, 2008, page 4 Section 4.1, 6 th bullet point, Village of Evendale expert Stratum 



Environmentals, SHPO Review, FAA Analysis, etc.” Arcadia is required by state and 

federal law to comply with SHPO and tribal notice requirements and has done so. 

3. I do not believe that the EPC can approve this application given Section 1263.09(a) 

which states: (a) No cellular or wireless communications tower shall be permitted 

on any lot on which any nonconforming building or structure is located or on which 

any nonconforming use or activity is occurring without first obtaining permission 

from the Village Board of Zoning Appeals. 


5










4. Kathy Farro’s report clearly identifies that there are non-conforming structures on 

the site and therefore, this application is prohibited unless the Village Board of 

Zoning Appeals gives permission. 










5. There are locations on the Rest Haven property that are 600 feet from any 

residential property NOT owned by Rest Haven. They should show each of these 

locations and indicate why they cannot be used. It appears that rest Haven has 

chosen a location to give favorable appearance to their property while disregarding 

adjacent property owners. 

a. Arcadia Response: See response in 7 (b) below. 

6. Clarification is needed on the ownership of properties located on the corner of 

Glendale-Milford and Plainfield as it relates to the adjacent property diagram (for 


a. Staff response: Please see property owner attachment. 

b. Arcadia Response: See drawing labeled C6- Adjacent Property Plan in the Arcadia- 

Evendale which lists the ownership of all properties adjacent to the property in 

question as required by the ordinance 1263.06 (J) (13). There is no reference in the 

ordinance to properties adjacent to properties owned by the owner of the property in 

question. The properties listed on the attachment are not adjacent to the property in 

question. 

7. Marshall Slagle Planning was paid to render his opinion and did not address the 

question asked on the intent of the Evendale ordinance on set back requirements in 

a residential area. 


6

a. Staff response: The intent of the code language in 1263.04(c) is to buffer uses in 

residential districts (particularly residential uses) from the adverse effects of 

telecommunications towers to the maximum extent possible. 

b. Arcadia Response: See Item #2 in Summary Response to Staff List of Application 

Issues dated August 2008 which references Marshal Slagle Report and testimony 

regarding the setback filing, and Marshall Slagle response to setback as a prohibition 

of service attached hereto as Exhibit C. The zoning code section 1263.04 (C) reads: 

“Cellular or wireless communications sites in a zoning district or area where such use 

is permitted shall be located any closer to any residential zoning district than as 

follows: (1) if a Cellular or wireless communications tower is 100’ or less in height, 

the site shall be located no closer than 500 feet to any residential zoning district; (2) 

For any cellular or wireless communication tower exceeding 100 feet in height, the 

site may not be located closer to any residential zoning district than a distance equal 

to 500 feet plus 2 feet for each foot of height that the tower exceeds 100 feet.” 

Arcadia’s proposed site is located in a residential (R) zoning district. Per 1263.04 

Use Regulations, cellular or wireless communications sites may be permitted in (R) 

district. Since the site is located in (R), it cannot possibly be set back from the (R) 

district. 

8. The summary of response to the Staff report does not address the issue of nonconforming 

structures already on the property as grounds to PROHIBIT a cell 

tower anywhere on the Rest Haven Property. 










9. We believe that the Planning Commission should allow/encourage Arcadia to 

modify their current application to include BOTH the Rear of Rest Haven Location 

and the Maintenance Shed location. 

a. Staff response: Arcadia has presented various documents indicating a possible 




parcel. 

b. Arcadia Response: Arcadia agrees with Staff Response in 9 (a) above. Arcadia 

refers to the maintenance shed location as the “Rest Haven alternate site” and the 

property owned by the Village of Evendale located at the northwest corner of 

Glendale Milford and Plainfield Roads as the “Evendale Gateway” site. Arcadia 

previously prepared proposals to locate a flagpole type tower at the Evendale 

Gateway site to the Village of Evendale. The history and copies of those proposals 

can be found in the previously filed memo to the Village of Evendale Planning 

Commission dated August 2008 from Samuel T. Johnston, Jr., in the text of the 


7

memorandum and in Exhibits 1 through 7. Arcadia’s proposal for a tower at the 

Gateway location was not accepted, and we were directed by the Village to the Rest 

Haven location per the minutes of the Evendale Council on August 9, 2007, included 

in the August 2008 memo as Exhibit 7. Also noted in the memorandum is 

information regarding the Rest Haven Alternate Site, including balloon fly, discussion 

with residents, aeronautical study, and resident meeting performed by Arcadia. 

Arcadia further agrees with the Tower Review Summary Report October 30, 2008, 

Section 2.1, bullet point 6 which states “If a site is necessary in this area, the 

cemetery seems to be the logical location for placement”. 

MISCELLANEOUS 

1. Could the tower at Raymond Walters be increased to allow higher frequency 

carriers? Has Blue Ash been approached about a cell tower site in any of 

their commercial, recreational, or educational areas? Blue Ash golf course, 

Raymond Walters, Lake Forrest commercial buildings, etc? 

a. Arcadia Response: Please see attached response from Cricket Communications. 

Per the Statement of Need for wireless communications facility located in 

Evendale Ohio dated August 2008 submitted by Gregory Wahl, RF Engineer for 

Cricket Communications, Inc. the Raymond Walters tower is outside of the 

allowable zone. Per the same report, Cricket is currently located on a rooftop at 

4445 Lake Forest Drive, and this area is also outside of the allowable zone. 

Further, Arcadia further agrees with Stratum Broadband’s Tower Review 

Summary Report October 30, 2008, Attachment B, response (2), second 

paragraph: “Search rings are usually determined after considering the location of 

existing towers, the terrain, coverage objectives, and budget. They can range 

from a radius of 0.5 to 3 miles or more depending on various factors. Since this 

site appears to be required for coverage improvement rather than a new network 

buildout, it would not be uncommon for the requirement of a more precise 

placement”. Additionally, see the attached response from Cricket 

Communications regarding the tower at Raymond Walters. 

2. Where is the documentation for the property value study impacted by cell towers? 

a. Arcadia Response: See Galloway Appraisal letter to David Pike dated August 14, 

2008 included in previous filing. 

3. What reason did the FAA provide to reverse their denial of the tower originally? 


Aeronautical Study No. 2007-AGL-9870-OE dated 4/18/2008 (attached as 

Exhibit A). Also noted in the Tower Review Summary Report October 30, 


Broadband notes: “It appears that all standard site development processes have 

been properly managed including lease documentation, site surveys, Phase 1 

Environmentals, SHPO Review, FAA Analysis, etc.” 

4. In February, I asked how many Cricket users are in the area and how many 

complaints have been received about poor coverage? 

a. Arcadia Response: see 5 (a) below. 


8

5. Gregory Wahl testified that there have been numerous customer complaints and 

requests to Cricket for additional/better service in the area. At previous public 

hearings and again at this last public hearing, citizens have requested some factual 

back up of that claim. I believe that it is a reasonable request and if provided will 

bolster the testimony of Mr. Wahl. I understand that sometimes this information is 

proprietary, but I am sure they can give show some statistics on this since they have 

continuously used this as a central argument for the project. 

a. Arcadia Response: Per the Statement of Need for wireless communications 

facility located in Evendale Ohio dated August 2008 submitted by Gregory Wahl, 

RF Engineer for Cricket Communications, Inc. Cricket has demonstrated a lack of 

coverage in their service area due to the coverage gap in Evendale, and has a right 

to provide reliable wireless service per its FCC license. Arcadia further agrees 

with the Stratum Broadband Tower Review Summary Report October 30, 2008, 

Section 4.1, bullet point 1, which states “Drive testing was performed by Cricket 

to verify the service gap.” 

6. The documentation provided from the Ohio Historical Society indicates the tower 

would be 190 feet. 

a. Arcadia Response: That is the height at which we filed with State Historic 

Preservation Office (SHPO); the tower we are proposing to build is 150’. As 

noted in the Tower Review Summary Report October 30, 2008, page 4 Section 

4.1, 6 th bullet point, Village of Evendale expert Stratum Broadband notes: “It 


including lease documentation, site surveys, Phase 1 Environmentals, SHPO 

Review, FAA Analysis, etc.” 

7. Page 3 of 7 of the FAA documentation provided is missing. 


Aeronautical Study No. 2007-AGL-9870-OE dated 4/18/2008 (attached as 

Exhibit A). As noted in the Tower Review Summary Report October 30, 2008, 

page 4 Section 4.1, 6 th bullet point, Village of Evendale expert Stratum 

Broadband notes: “It appears that all standard site development processes have 

been properly managed including lease documentation, site surveys, Phase 1 

Environmentals, SHPO Review, FAA Analysis, etc.” 

8. The documentation labeled as the Evendale Gateway Plans appears to actually be 

the Rear of Rest Haven location. 

a. Arcadia Response: The Proposed Wireless Communications Facility site plans 

submitted in August 2008 are erroneously labeled “Evendale Gateway” and 

should read “Rest Haven”. 

9. The documentation labeled as #3 appears to actually be the Rest haven Maintenance 

Shed location. 

a. Arcadia Response: No response, unsure of what documentation is being 

referenced. 

10. There are no corresponding maps provided for the vicinity lot lists provided (for 


a. Arcadia Response: See drawing labeled C7- Vicinity Lot List in the Arcadia- 

Evendale which identifies all buildings and structures on adjacent lots and any 


9

additional lot within 500’ and the owners as required by the ordinance 1263.06 (J) 

(13). Drawing also includes approximate elevation of highest point of each building 

or structure. 

11. The coverage maps provided throughout the documentation are misleading as they 

have different scales. Documentation should be provided with the existing coverage 

and then the ability to do overlays showing increased coverage by adding to existing 

locations or adding new locations. 

a. Arcadia Response: Per the Statement of Need for wireless communications 

facility located in Evendale Ohio dated August 2008 submitted by Gregory Wahl, 

RF Engineer for Cricket Communications, Inc. Cricket has demonstrated a lack of 

coverage in their service area due to the coverage gap in Evendale, and has a right 

to provide reliable wireless service per its FCC license. Arcadia further agrees 

with the Stratum Broadband Tower Review Summary Report October 30, 2008 in 

which no mention was made of any issues regarding the scale of the maps in the 

above referenced coverage maps. 

12. Cricket sites incremental customers -- they do not indicate if this would increase 

actual overall market penetration in the area or their market share. If they 

currently have less than 3% share in the zip code – how much of the market is unserved 

by them or other carriers? 


13. Cricket sites communication needs of our community - who had defined these needs 

and what are they? 


14. Cricket document contains 3 set of the same memo – why? 

a. Arcadia Response: 2 extra copies submitted erroneously. 

15. An Edwards Kelsey Report is referenced –we would like a copy. 

a. The Edwards Kelcey study was done for the Village of Evendale, a copy of the 

page with the traffic count is attached as Exhibit D. 

16. Cricket sites files they got from Claritas – we would like them to provide these files. 


17. The Galloway report sites studies -- it should be required that they provide the 

actual studies for review. The Galloway report states that “we know of no study 

that suggests that such objects cause a diminution in value of residential 

properties”. This statement/opinion is in question when a quick search of the 

internet reveals: 

a. Arcadia Response: We are not aware of this study. PIKE TO REVIEW. 

The effect of distance to cell phone towers on house prices in Florida. 

by Bond, Sandy 

Appraisal Journal • Fall, 2007 • 


10

ABSTRACT 

This article outlines the results of a study carried out in Florida in 2004 regarding 

the effect that cell phone tower proximity has on residential property prices. The 

study involved an analysis of residential property sales transaction data. Both GIS 

and multiple regression analysis in a hedonic framework were used to determine the 

effect of linear distance of homes to towers on residential property prices. The 

results of the research show that prices of properties decreased by just over 2%, on 

average, after a tower was built. This effect generally diminished with distance from 

the tower and was almost negligible after about 656 feet. 

18. The Marshall report refers to an occupied structure within 300 feet –that structure 

is the Behbehani residence! 

a. Arcadia Response: No response. 

19. Tower dimensions are not consistent – what is base measurement and top 

measurement of mono-poles? 

a. Arcadia Response: Per 1263.06 (J) (13), Arcadia has previously submitted the Sabre 

Structural Design Report dated August 14, 2008 and the Report of Structural 

Considerations by William E. Grigsby submitted in August 2008. 

20. We would like to request the Evendale Council Videos for the council meetings of 

9/20/07 and 12/04/07 as these minutes indicate council discussed the tower and we 

would like to see the full discussion. 

a. Arcadia Response: Arcadia also requests a copy of the video tapes from this 

council meeting. 

21. Since the Crown tower was installed prior to our ordinance is there now a way to 

increase the height of that tower to meet Cricket’s needs? 

a. Staff Response: The Village’s approval of any telecommunications tower is 

predicated on a private agreement between tower owners and the owners of the 

property that is to be built upon, or a tower owner’s private purchase of land for tower 

development. Any alterations to Crown Tower are at the discretion of the parties that 

control the Crown Tower. 

b. Arcadia Response: Village of Evendale Ordinance 1263 has no provision for 


22. Documentation should be provided from tower owners that refused collocation or 

locating a new tower on property. 



Engineer for Cricket Communications, Inc. there are no towers that meet Cricket’s 

service requirements that are located in the allowable zone. 

23. There are many discrepancies in the distance the tower is from residents(example 

Behbehani shows 300 ft on one document and 275 on another. 

a. Arcadia Response: See Proposed Wireless Communications Facility by Arcadia 

Towers, LLC, page C1 dimension plan which shows the survey of the setback from 

certain residential structures. 


11

24. Rest Haven has been a good neighbor and none of us objected when they were 

granted multiple variance to expand the nature of their business within their 

industry. They are now asking for additional variances to expand there income 

through non-core activities to the detriment of their neighbors. 

a. Staff Response: Rest Haven has not specifically requested any variances. 

a. Arcadia Response: No Response. 

25. The Evendale gate way location is outside of the “Search Ring” so why was this 

location considered? 



Engineer for Cricket Communications, Inc., see page titled “Search Ring #280” 

which indicates that Evendale Gateway is within the search ring. 

26. There are discrepancies in the current coverage map provided in various 

documents. 

a. Arcadia Response: See 11 (b) above. 

27. In the 9/20/07 council minutes Mr. Puthoff said” he would rather see it in his 

backyard against the cemetery than in the Village Gateway because it is not as 

noticeable”. Since Mr. Puthoff provided his inputs as an owner than the 

Maintenance shed locations allows it to be 600 feet away form all other residential 

properties not owned by Rest Haven. Residents were not given the opportunity to 

voice their opinion on the Gateway location. 

a. Staff Response: Arcadia has presented various documents indicating a possible 




parcel. 

b. Arcadia Response: See Planning/Zoning section 9 (b) above in reference to the 

Gateway location. 

28. Lynn Nordstrom, Verne Kreger and I have thought about Jack Cameron’s offer of 

outside expertise and where particularly we feel that expertise could be used most 

effectively. From our point of view there are three areas that could be reviewed 

more thoroughly for everyone’s benefit. Those three are: 

a. Zoning Issues, specifically setbacks, non-conforming structures, and variance 

issues within the application. 

i. Staff Response: According to Village records, Rest Haven has not 

requested nor been issued any variances. Setback issues are addressed in 

the previous staff report. The proposal would require the approval of the 

Board of Zoning Appeals per Section 1263.09(a). Rest Haven has two 

existing nonconforming structures: the front yard fence (fences are not 

permitted in front yards), and the concrete storage vaults that are being 

stored to the rear of the property. These vaults constitute “outdoor 

storage” which is not permitted in the “R” Residential District. 


12

ii. Arcadia Response: Staff has erroneously asserted that there are 

nonconforming uses on the Rest Haven parcel in question regarding 

Section 1263.09 (a). Please see attached letter to Jack Cameron dated 

November 7, 2008 from Joseph Trauth, Attorney for Rest Haven. 

b. Acoustic Engineering Studies 

i. Plantings should include evergreens that sufficiently shield the base of the 

tower from the abutting residential and go beyond the minimum required 

by the code. This may also be achieved as part of a variance request to 

ZBA. Residents have reported fairly substantial visibility through the 

bases of the trees to this area, particularly in the winter. 

ii. Arcadia Response: Not sure what is being asked for here. 

c. Mitigation factors such as planting, painting, fencing, etc. 

i) Arcadia Response: See Proposed Wireless Communications Facility 

by Arcadia Towers, LLC, page L1 landscaping plan, which shows the 

existing berm and proposed evergreen plantings around the perimeter of 

the compound area and C4 which shows the fencing detail with a 6’ 

shadowbox fence surrounding the compound and page C4 which shows 

the fencing detail with a 6’ shadow-box fence surrounding the compound, 

complies with Village Ordinance 1263.06 (E) Landscaping which states 

that a landscaping plan shall “…screen as much of the support structure 

and ground level features as possible. In addition, existing vegetation on 

and around the site shall be preserved to the greatest extent possible.” 

Our feeling is that the zoning issues attached to this case are significant enough to 

warrant a review by outside legal counsel and that a competent sound engineer 

conduct field test to validate generally the findings of the Arcadia engineers. Finally 

we think that a study of how best to mitigate these kinds of projects to the 

surrounding neighbors in terms of planting and materials would be in order. All of 

this is obviously predicated on sufficient monies being available. 

i) Arcadia Response: See (C) above. 

29. When you speak of Cricket communications having the right to operate its wireless 

communications network in a licensed area. What is meant by that? If there is no 

landowner willing to lease land for a tower in one of your dead zones or ‘Gaps’, 

what options does Cricket have? (Comment: Blue Ash apparently has a lock on all 

of the available land, what will they do about dead zones there? There must be 

other options to tall towers.) 

a. Arcadia response: See attached response from Cricket Communications. 

30. What do you mean by degraded E911? Do you know of an instance where E911 

locating in this area of Evendale has been degraded due to poor reception? Can you 

provide documentation? 


31. Cricket sites customer complaints as justification and provides no DATA to support 

these claims. 



13

. Arcadia Response: See attached response from Cricket to #29 above. 

Also, shown below are the results of field testing of a Cricket phone submitted to the 

Planning Commission by residents Susan deRoos and Sheri Torbeck. The data 

gathered shows no evidence of service gaps when the Cricket service was utilized. 

Via email from Susan deRoos to Jack Cameron dated September 22, 2008: 

I purchased the basic lowest price model of Cricket Cell phone 513-386-4880 and 

purchased NO roaming minutes. When I purchased the phone I was shown a coverage 

map that indicated there would be no coverage in certain area with out purchasing a 

roaming package. 

Utilizing the current Cricket coverage map provided by Cricket in the Cricket 

Communications Search Ring CVG-280 Evendale, Ohio RF Engineering study of August 

2008, Shari Torbeck and I used the map to go to locations within the white areas on map 

(per the map “the white area indicate lack of Cricket Coverage”). 

We placed the following calls successfully leaving voice mail messages each time on 

Shari’s cell phone. 

Time Location from which call was placed 

1:20 pm 3753 Monet’s Lane 



1:39 Corner of Sunders Park and Wyscarver 











All calls were made, voice mails recorded of each call, no roaming charges were paid and 

all were made within areas Cricket claims to have lack of coverage. 

In order to demonstrate that the Cricket Phone (513-386-4880) could receive as well as 

make calls in the Cricket lack of coverage areas, we conducted a second test. Test 

number 2 included making the following calls from 513-505-8901 (A Verizon cell) to the 

Cricket Cell (513-386-4880) while in the following locations: 

All calls were made on September 22, 2008: 

Time Location of the Cricket Cell when receiving the Call 

5:00 pm 3753 Monet’s Lane 



5:37 Corner of Sanders Park and Wyscarver 


14











All calls were placed by Susan de Roos using Cricket cell 386-4880 and received by Kay 

Bostrom using Verizon cell 505-8901, no roaming charges were paid and all were made 

within areas Cricket claims to have lack of coverage. 


15

EXHIBIT A 

FAA DNH 4/18/2008 


16


17


18


19


20


21


22


23

EXHIBIT B 

FAA DNH JULY 1, 2008 


24


25


26


27


28


29

EXHIBIT C 

MARSHALL SLAGLE SETBACK LETTER 


30


31


32


33


34


35


36


37


38


39


40


41


42


43


44


45


46

EXHIBIT D 

EDWARDS KELCEY SLIDE OF TRAFFIC COUNTS 


47


48

TECHNICAL 

Cricket Communications Response to 








Cricket Response: Multiple point question, herewith break down to each point: 

Q: Apparently Cricket needs the extra pole height because they have a higher 

frequency than ATT etc. I assume this is because the Higher RF dissipates more quickly 

A: Cricket’s requested RAD height of 150ft is the minimum height feasible for the resultant 

RF propagation to cover the targeted areas previously highlighted. Cricket operates on the 

PCS1900 band, which is a higher frequency when compared to those operators using the 800 

MHz band. Basic law of physics, the higher the frequency, the more it is susceptible to fade. 

Q: Is there any connection between coverage area and power of transmission? 

A: Yes and no. Yes that in the higher the transmission power, the larger the resultant 

footprint of the site could be. No in that your handset is a limited power unit, and as such, can 

only transmit a much weaker signal back to the site. In designing a cellular network, one of the 

parameters you work to is a Link Budget. This takes into account both the Forward and Reverse 

Paths. The Forward path is the tower transmission and the Reverse path is the handset 

transmission. Balancing these two is essential. If not, you would end up with a large amount of 

network noise, effectively interference. 

Q: What are higher frequency carriers going to do if the only pole positions are well 


A: Cricket cannot speak for other carriers, but the basic rule of thumb is, the lower the 

available collocation opportunities, the higher the number of sites it would take to effectively 

cover an area. One 150ft site, dependant on terrain and local clutter (buildings, trees, etc), could 

theoretically cover an area that would demand three (3) or more sites of 100ft or less. Please note 

the fact that Cincinnati Bell currently has a number of these lower cells, some are located along 

Cooper Road, and yet they are a co-applicant on this proposed tower. 


A: Cricket has been looking for a suitable site capable structure in this immediate vicinity 

since September 2005. We know this area well, and have reviewed land use and the feasibility 

of a site in this area. 

1

3. Mr. Wahl has testified that Cricket needs their antenna to be at the top of a 150’ 

tower at the Rest Haven sites to “provide reasonable, reliable, and satisfactory service to 

(their) customers”. If they cannot “provide reasonable, reliable, and satisfactory service to 

(their) customers” at a height below 150’ then how can other service providers? The 

Village Code states that a pole at 150’ needs to be able to accommodate 4 antennas. I have 

spoke to cell tower professionals and found out that antennas need to be separated by 10’- 

15’ (Verizon typically wants 15’), depending on the frequencies being used. Even assuming 

that the 10’ separation can be obtained, this means that the lowest antenna would be at 

120’. The burden of proof is for Arcadia to demonstrate that other carriers can “provide 

reasonable, reliable, and satisfactory service to (their) customers” with an antenna at 120’. 

A: Cricket has identified that 150ft allows us (Cricket) to meet the majority of the coverage 

footprint we require for this immediate area. We cannot comment on how other service providers 

have configured their networks. Your information on the antenna separation on a tower is 

correct, 10ft tip to toe typically being the minimum. Returning to previous statements, other 

carriers would have the option of collocating on the proposed tower, at what heights are 

available. Yes, their resultant coverage footprint may not be the same as the carrier above them, 

but you fail to take into account their neighboring cell configuration or antenna configuration. 

Cricket has endeavored to explain at length what our current footprint is, and how this site assists 

in us meeting our customer coverage expectations, and network integrity. And again, we cannot 

comment on how other service providers have configured their networks. 





A: There are a number of factors that were considered before the search ring was issued: 

These are: 

• Blue Ash airport close proximity to the coverage objective 

• FAA limitations on where and how high a structure can be erected. 

• Cricket currently has a site located on a building rooftop opposite the airport. Due to it 

being so low a platform, the resultant coverage footprint is small. 

• No other existing co locatable structures in the vicinity. 

7. If a 150 ft tower is required by Cricket, how will 3 or 4 other carriers find it beneficial 

to locate on this tower? 

A: Please refer to answer to point # 3 above. 

8. In order to close coverage gaps, do you always look for just one location, or do you colocate 

on multiple towers? 

A: It is preferred that we co locate on any existing structure/s. If there are such suitable 

structures available we approach the owners to verify heights available. For each of these 

candidates there are some factors we have to consider: 

Height available (determines the coverage footprint) 

Can the existing structure support our antennas, i.e. is it structurally strong enough? 

2

Is there ground space available for our equipment? 

In the case of search ring CVG-280 Cricket has been unable to find one suitable 

candidate, let alone multiple candidates. 

9. How many customers do you have in the Village of Evendale? How many POPs do you 

need now? What is the coverage subscriber? What is meant by the number 7,6785.17 

on the current cricket coverage slide??? Is this a typo? When you indicate covered 

subscribers for the entire area, what is the entire area you are referring to? The whole 

map? Just the additional coverage by the proposed tower? What? 


Q: How many customers do you have in the Village of Evendale. 

A: Cricket has quite a few subscribers living in the area under discussion. The exact number 

fluctuates on a monthly basis, as Cricket works on a prepaid basis, and subscribers are not 

contractually bound to retain our service for a number of years. 

Q: How many POPs do you need now? 

A: It is not a question of how many pops we need now, for Cricket it is a question of 

providing contiguous coverage along area roads, and decent indoor coverage to all current and 

prospective future customers, whomever they may be, or reside. Once again, may we reiterate 

the fact that Glendale Milford Rd is a very heavily travelled route, and many of our current 

customers travel through here, but may not necessarily reside in the City of Evendale. 

Q: Is this a typo? When you indicate covered subscribers for the entire area, what is 

the entire area you are referring to? The whole map? Just the additional coverage by the 

proposed tower? What 

A: Please see Stratum Tower report 



rejected. Did you ask for a site with a higher elevation? It would seem logical to believe 

that by putting the tower at a point in the cemetery that is at a higher elevation, you 

would effectively get a ‘taller’ tower. Is this the case 

A: Please refer to the terrain map provided in the August 2008 filing. The cemetery is near 

the highest point in the vicinity, and the terrain drops drastically to the West. This was discussed 

during the town’s review meeting. We also have to take into consideration the FAA limitations 

for the area, further making the feasible site location area smaller. 

Under Miscellanous section: 

Point #1: Could the tower at Raymond Walters be increased to allow higher frequency 

carriers? Has Blue Ash been approached about a cell tower site in any of their commercial, 

recreational, or educational areas? Blue Ash golf course, Raymond Walters, Lake Forrest 

commercial buildings, etc 

3

A: Cricket has a site located on the Lake Forrest Commercial building on Glendale Milford Rd in 

Blue Ash. As the rooftops are so low due to the close proximity of the airfield, the resulting 

coverage footprint of this site is very low. The Raymond Walters tower, FCC # 1239953, is 

limited by the FAA to its current height of 100ft due to it being in the approach and depart lanes 

of the local Blue Ash airfield, airport code “ISZ”.(FAA study # 2003-AGL-200-OE) 

Point # 12: Cricket sites incremental customers -- they do not indicate if this would 

increase actual overall market penetration in the area or their market share. If they 

currently have less than 3% share in the zip code – how much of the market is un-served 

by them or other carriers 

A: Incremental pops covered is the amount of people per latest census data that reside in the 

area where cricket currently shows we do not cover, but would cover with the resultant coverage 

provided by the proposed tower/site. Cricket cannot comment on what other service providers’ 

coverage or customer base metrics are. 

Point #13: Cricket sites communication needs of our community - who had defined 

these needs and what are they? 

A: Cricket is a federally licensed PCS1900 cellular provider. We currently serve thousands 

of Cricket customers in the greater Cincinnati area. Evendale falls within this area. When Cricket 

cites communication needs of the community, we are citing any person who is a subscriber and 

who uses our service. “Communication needs” – can be defined as making or receiving a call, 

checking e-mails, downloading songs and ringtones, text messaging etc. The only way cricket 

can meet these requirements is to provide continuous coverage through the area. 

Point #16. Cricket sites files they got from Claritas – we would like them to provide 

these files. 

A: Cricket purchases data from Claritas, a census data clearing house, under a licensing 

agreement These files are in MapInfo format, allowing the data to be geographically mapped 

over areas. Within the data are such details of median income, demographic grouping, gender 

data, ethnic data, and population count. The Village of Evendale and the expert group who has 

reviewed our presentation material can also purchase this data from Claritas. 

Point#29. When you speak of Cricket communications having the right to operate its 

wireless communications network in a licensed area. What is meant by that? If there is no 

landowner willing to lease land for a tower in one of your dead zones or ‘Gaps’, what 

options does Cricket have? (Comment: Blue Ash apparently has a lock on all of the 

available land, what will they do about dead zones there? There must be other options to 

tall towers.) 


Q: When you speak of Cricket communications having the right to operate its wireless 

communications network in a licensed area. What is meant by that? 

A: Cricket is a license cellular provider by the FCC, call sign for the Cincinnati BTA#81 is 

WQDI523. In order for a service provider to operate and sell service in a federally mandated 

area, the provider has to purchase spectrum, register with the FCC, and meet all guidelines and 

4

mandates as specified in numerous federal legal documents. This applies to all wireless service 

providers nationwide. 

Q: If there is no landowner willing to lease land for a tower in one of your dead zones 

or ‘Gaps’, what options does Cricket have? (Comment: Blue Ash apparently has a lock on 

all of the available land, what will they do about dead zones there? There must be other 

options to tall towers.) 

A: This is a continual problem for all wireless service providers. We all try to provide good 

coverage to our subscribers, if there is an area with poor to no coverage we try to optimize the 

existing network by reconfiguring adjacent sites. We have exhausted all option available to us, 

and have been forced to admit that we need this site. 

What options are there to tall towers? More short towers! The issue is compounded when you 

have more than one service provider looking to meet their customer requested coverage, and 

shorter towers tend to exclude co location opportunities. The result is multiple short towers in 

multiple locations. For this reason, a taller tower, capable of 4 co locates is preferred, one 

location, one tower, 4 vendors who can meet the ever increasing customer demand. 

Point #30. What do you mean by degraded E911? Do you know of an instance where 

E911 locating in this area of Evendale has been degraded due to poor reception? Can you 

provide documentation 

A: Degraded E911 – connectivity to the system. Cincinnati emergency services and the 

federal government are requiring all service providers to upgrade their networks to E911 Phase 

This allows for GPS positioning of later model handsets. Now, if you have poor coverage, and 

the call setup fails (the GPS positioning portion takes all of 5 to 10 seconds depending on the 

local switch-board setup) you have what we call degraded 911 conditions. Poor coverage = poor 

911 capability. 

5

Arcadia Towers, LLC Response to 

The Village of Evendale Tower Review Summary Report prepared by 

Stratum Broadband 

October 30, 2008 

Sections 2‐4 

Arcadia Response: Arcadia Responses to each question are noted below in blue 

text. Expert responses and additional information provided will be attached 

hereto. 

2. Arcadia’s January 2008 Submittal This section contains 

observations and follow-up questions relating to Arcadia’s January 2008 submittal to the Village of 

Evendale. 

2.1. General Observations 


1 

• RF search ring seems to be centered on the proposed site rather than a larger area. 

Arcadia Response: See Cricket Response letter. Please see previous testimony 

from Cricket and Arcadia and the pertinent information provided during that 

hearing. Cricket provided in the August 2008 Statement of Need for Wireless 

communications facility located in Evendale Ohio a “drawing showing the 

boundaries of the area around the proposed location which would also probably 

permit the antenna to function properly in the company’s grid system” in 

accordance with Ordinance 1263.05 (A). 

• RF Plots were performed for only existing coverage, the church, the Crown Castle 

tower and 150 foot proposed tower. No RF plots were provided at lower levels to 

show that a shorter tower would not meet their design needs. 

Arcadia Response: See Cricket Response letter. 

• RF Plots have been provided for the church and Crown Castle but not other towers 

or industrial sites. 

Arcadia Response: See Cricket Response letter. Additional Cricket RF Plots were 

provided in the August 2008 filing by Arcadia. The allowable zone is located 

100% in a Residential (R) zoning district, therefore none of the Industrial Truck 

Center (ITC) zoned properties, or any other zoning district properties, are located 

within that allowable zone. All other zoning districts are located west of the 

allowable zone, and are at lower elevations as indicated in the Cricket Statement 

of Need for Wireless communications facility submitted in August 2008, 

paragraphs 3-5. Further, the General Commercial (GC) zone located to the west 

has a lower preference for location of a wireless communications facility per 

1263.04 (A) and (B). Ordinance 1263.04 (A) (5), states a cellular or wireless 

communications site may be permitted in a Residential (R) district.

• Although the Sims provided were good, they were performed when the trees were 

fully leaved. 

Arcadia Response: Arcadia had the photo simulations (Sims) for this filing performed 

in early November, 2008 in accordance with Village of Evendale Ordinance 163 

1263.06 (J) (14). 

• The equipment compound is located in a residential area and consideration has to 

be given to hide as many aspects as possible such as the addition of tree topped 

berms. 

Arcadia Response: See Arcadia’s August 2008 filing Proposed Wireless 

Communications Facility by Arcadia Towers, LLC, page L1 landscaping plan, 

which shows the existing berm and proposed evergreen plantings around the 

perimeter of the compound of the compound area and page C4 which shows the 

fencing detail with a 6’ shadow-box fence surrounding the compound, complies 

with Village Ordinance 1263.06 (E) Landscaping. 

• If a site is necessary in this area, the cemetery seems to be the logical location for 

placement. 

Arcadia Response: SEE CRICKET RESPONSE LETTER and Cricket’s August 2008 

Statement of Need for Wireless communications facility located in Evendale Ohio 

demonstrating that the allowable zone is located 100% in a Residential (R) 

zoning district. Per Village of Evendale Ordinance 1263.04 (A) (5), a cellular or 

wireless communications site may be permitted in a Residential (R) district. 

Arcadia agrees with Stratum’s statement that the cemetery is the logical location 

for placement. 

• The existing Crown Castle site is too short as shown on the RF plots. 

Arcadia Response: See Cricket’s August 2008 Statement of Need for Wireless 

communications facility located in Evendale Ohio demonstrating that the Crown 

tower does not meet their coverage requirements. 

2.2. Follow-Up Questions 


2 

• What was the original search ring for this coverage area? 

Arcadia Response: Cricket provided in the August 2008 Statement of Need for 

Wireless communications facility located in Evendale Ohio a “drawing showing 

the boundaries of the area around the proposed location which would probably 

also permit the antenna to function properly in the company’s grid system” in 

accordance with Village of Evendale Ordinance 1263.05 (A). The original site 

location was at the Evendale Gateway location. Arcadia previously prepared 

proposals to locate a flagpole type tower at the Evendale Gateway site to the 

Village of Evendale. The history and copies of those proposals can be found in 

the previously filed memo to the Village of Evendale Planning Commission dated 

August 2008 from Samuel T. Johnston, Jr., in the text of the memorandum and in 

Exhibits 1 through 7. Arcadia’s proposal for a tower at the Gateway location was 

not accepted, and we were directed by the Village to the Rest Haven location per 

the minutes of the Evendale Council on August 9, 2007, included in the August 

2008 memo as Exhibit 7. 

• What site(s) do you currently have on air that provides service to this area. 

Arcadia Response: See Cricket’s August 2008 Statement of Need for Wireless 

communications facility located in Evendale Ohio showing the adjacent site 

locations. 

• Provide RF Plots for a minimum of 120 foot level.

a) Arcadia Response: SEE CRICKET RESPONSE LETTER. Section 1263.06(a) states that 

applicant shall demonstrate that the tower “is no higher than necessary to function 

satisfactorily and to accommodate the co‐location requirements as set out in Subsection 

1278.06(f).” As the Village of Evendale Ordinance 04‐37 has no Subsection 1278.06(f), there 

is no co‐location requirement in Section 1263.06(a). Arcadia has designed the tower to meet 

the requirements of Section 1263.06(F)(3.) which requires that the tower “be designed, 

engineered and constructed to support antennas installed by at least four cellular or 

wireless communications service users.” There is NO requirement in the ordinance that the 

applicant demonstrate that any other applicant will be able to provide any type of service 


3 

• Did you look at other sites in the area including all existing towers and industrial 

areas? Should provide RF plots for those areas that were considered. 

Arcadia Response: SEE CRICKET RESPONSE LETTER. Additionally, please 

see the previous testimony of Arcadia and Cricket Communications and the 

information provided during that hearing. Cricket provided in the August 2008 

Statement of Need for Wireless communications facility located in Evendale Ohio 

a “drawing showing the boundaries of the area around the proposed location 

which would probably also permit the antenna to function properly in the 

company’s grid system” in accordance with Village of Evendale Ordinance 

1263.05 (A). Cricket provided detailed RF maps which showed the location of its 

existing sites (including the site in the commercial areas of Blue Ash), the 

location of the Search Ring and demonstrated through RF maps why the tower 

must be in the proposed location. 

• Sims should be provided of both the tower and ultimate equipment site without 

leaves. This should be done from various angles. 

Arcadia Response: Arcadia had the photo simulations (Sims) for this filing performed 

in early November, 2008 in compliance with Ordinance 263.06 (J) (14). 

• Can the Crown Castle tower be replaced in a ‘drop and swap’ scenario? 

Arcadia Response: Village of Evendale Ordinance 1263 has no provision for 

replacing an existing tower.

3. August 2008 Staff Report by Kathleen Farro 

This section contains observations and follow-up questions relating to the August 2008 staff report by 

Kathleen Farro summarizing the deficiencies in the January submittal. 


• We agree that there was no documentation other than a statement that attempts 

were made to find suitable locations in other zoning districts or neighboring 

villages. 

Arcadia Response: SEE CRICKET RESPONSE LETTER. See Cricket’s August 

2008 Statement of Need for Wireless communications facility located in Evendale 

Ohio demonstrating that the allowable zone is located in 100% in a Residential 

(R) zoning district per 1263.05 (A) and within the Village of Evendale. Any 

locations outside of the allowable zone would not function in the company’s grid 

system. Cricket provided RF propagation maps showing Cricket’s coverage at 

nine (9) site locations adjacent to the proposed site which demonstrate these 

sites are not sufficient to function in the company’s grid system. Per Village of 

Evendale Ordinance 1263.04 (A) (5), a cellular or wireless communications site 

may be permitted in a Residential (R) district. Arcadia agrees with Stratum’s 

statement above that the cemetery is the logical location for placement. 



4 

• Applicant should provide more specific documentation for the other districts. 

Arcadia Response: See response in 3.1 above.

4. Arcadia’s August 2008 Follow-Up Submittal 

This section contains observations and follow-up questions relating to the accordion folder containing the 

contents of Arcadia’s follow-up August 2008 submittal, including a memo response to the August staff 

report. 


• Drive testing was performed by Cricket to verify the service gap. 

Arcadia Response: Arcadia agrees, see Cricket’s August 2008 Statement of Need 

for Wireless communications facility located in Evendale Ohio. 

• Documentation of the RF Propagation maps provided show 9 existing towers, but 

have plots for four existing towers, one rooftop and a Duke Energy pole. 






system. Cricket provided in the August 2008 Statement of Need for Wireless 

communications facility located in Evendale Ohio a “drawing showing the 

boundaries of the area around the proposed location which would probably also 

permit the antenna to function properly in the company’s grid system” in 

accordance with Village of Evendale Ordinance 1263.05 (A). Cricket provided 

RF propagation maps showing Cricket’s coverage at nine (9) site locations 

adjacent to the proposed site which demonstrate these sites are not sufficient to 

function in the company’s grid system. Per Village of Evendale Ordinance 

1263.04 (A) (5), a cellular or wireless communications site may be permitted in a 

Residential (R) district. 

• Crown Castle stated it was not feasible to replace the existing monopole. 


replacing an existing tower. See attached Crown letter. 

• The search ring #280 is one-half mile radius. 

Arcadia Response: Cricket provided in the August 2008 Statement of Need for 

Wireless communications facility located in Evendale Ohio a “drawing showing 

the boundaries of the area around the proposed location which would probably 

also permit the antenna to function properly in the company’s grid system” in 

accordance with Village of Evendale Ordinance 1263.05 (A). 

• There are other alternative technical solutions to provide service (eg. Distributed 

Antenna Systems) that were never considered by Cricket. 

Arcadia Response: Village of Evendale Ordinance 1263 does not require that 

alternative technical solutions be considered by Cricket. 

• It appears that all standard site development processes have been properly 

managed including lease documentation, site surveys, Phase 1 Environmentals, 

SHPO Review, FAA Analysis, etc. 

Arcadia Response: To the best of its knowledge, Arcadia has complied with all 

Federal, state, and local site development processes as required by Village of 

Evendale Ordinance 1263. 



5


6 

• What engineering criteria did Cricket use to verify the service gaps and what were 

the results of the drive testing? 

Arcadia Response: SEE CRICKET RESPONSE LETTER. 

• Were all of the towers on the maps considered for co-location? Plots should be 

done for all existing towers or should be explained why they were not considered. 












• What was the reason for Crown Castle stating it was not feasible to replace the 

tower? 



• Can the search ring be expanded to include all tower sites in the area? 












• Has Cricket ever used alternative technologies? 

Arcadia Response: SEE CRICKET RESPONSE LETTER. Village of Evendale 

Ordinance 1263 does not require that alternative technical solutions be 

considered by Cricket.





Sections 5 & 6 

Arcadia Response: Arcadia Responses to each question are 

noted below in blue text. Expert responses and additional 

information provided will be attached hereto. 

5. Kathleen Farro Email to Jack Cameron – Summary 

of August 2008 Submittal Deficiencies 

This section contains observations and follow-up questions relating to an email from Kathleen Farro to 

Jack Cameron summarizing the submittal deficiencies of the August 2008 submittal. 


• Kathy Farro’s review appears to be complete and additional engineering 

documentation she referred to is detailed in Section 4 of this report. 

Arcadia Response: See Section 4 above. 



7 

• None 

Arcadia Response: None.

6. Various Emails and Questions by Adjacent 

Residents 

This section contains observations and follow-up questions relating to various emails and letters 

submitted by adjacent residents. 


• Residents have expressed concern about existing coverage and questioned the 

need for improvement. Some stated that they already had coverage with 

documentation showing completed test calls assuming that there was no existing 

coverage. Cricket has stated that they had complaints about spotty coverage and 

were attempting to improve coverage and E911 services by deploying an 

additional site. Without drive testing data, which would show actual coverage vs 

theoretical RF plot data, there is no realistic way of determining actual existing 

coverage. 

Arcadia Response: SEE CRICKET response letter. 



8 

• White space is shown on RF plots as no coverage with a level of -95 Db. Some 

handsets will work at -103. An RF plot of existing RF ‘Rx Qual’ up to level 4 

would show a truer picture of existing theoretical coverage. 

Arcadia Response: SEE CRICKET response letter.





Sections 5 & 6 

Arcadia Response: Arcadia Responses to each question are 

noted below in red text. Expert responses and additional 

information provided will be attached hereto. 

Attachment B: Immediate Concerns Document 


Ms. Farro, 

Kathy 

In response to your request, here are some thoughts on the questions that have been raised in your 

email. 

1) Apparently Cricket needs the extra pole height because they have a higher frequency than ATT etc. I 

assume this is because the Higher RF dissipates more quickly. Is there any connection between 

coverage area and power of transmission? What are higher frequency carriers going to do if the only pole 

positions are well below 150 ft.? 

Response: 

Cricket is licensed for a PCS C band which is in the 1.9 GHz range. ATT, T-Mobile and CBW are also 

licensed in this range with their own assigned frequency bands. This frequency does not propagate as 

well as lower frequencies used for cellular service. Some cell sites can be optimized for up to 2-3 miles in 

a direct line of site arrangement. We reviewed the topographical map for this area (see attached PDF) 

and found the terrain is somewhat challenging due to the topography. An RF propagation plot should be 

done for 120 foot AGL (Above Ground Level) as requested previously by the Planning Commission to 

determine if Cricket truly requires a 150 foot level. 

Factors that influence service range in order of importance include: 

Frequency 

Height above terrain 

Topography including vegetation and manmade obstacles 

Antenna gain 

Equipment processing gain 

Radio Power 

Arcadia Response: Section 1263.06(a) states that applicant shall demonstrate that the tower “is no 

higher than necessary to function satisfactorily and to accommodate the co-location requirements as 

set out in Subsection 1278.06(f).” As the Village of Evendale Ordinance 04-37 has no Subsection 

1278.06(f), there is no co-location requirement in Section 1263.06(a). Per Arcadia’s August filing of 

site plans, Arcadia has designed the tower to meet the requirements of Section 1263.06(F)(3.) which 

requires that the tower “be designed, engineered and constructed to support antennas installed by at 

least four cellular or wireless communications service users.” There is NO requirement in the 


9

ordinance that the applicant demonstrate that any other applicant will be able to provide any type of 

service. 

2) Why is only the 0.5 Mile area shown? 

Response: 

In the documentation it shows that Arcadia asked Cricket RF Engineering if this site would meet their RF 

coverage requirements before proceeding with the pursuit of this site. It appears that the site was then 

chosen after performing satisfactory RF plots. A 0.5 mile circle was then drawn on the map after the fact 

since the site is in the center of the ring. 

Search rings are usually determined after considering the location of existing towers, the terrain, 

coverage objectives, and budget. They can range from a radius of 0.5 to 3 miles or more depending upon 

various factors. Since this site appears to be required for coverage improvement rather than a new 

network buildout, it would not be uncommon for the requirement of more precise placement. 

Arcadia Response: Arcadia concurs with Stratum Broadband’s comment that “Since this site appears to 

be required for coverage improvement rather than a new network buildout, it would not be uncommon 

for the requirement of more precise placement”. Cricket provided in the August 2008 Statement of 

Need for Wireless communications facility located in Evendale Ohio a “drawing showing the 

boundaries of the area around the proposed location which would probably also permit the antenna to 

function properly in the company’s grid system” in accordance with Village of Evendale Ordinance 

1263.05 (A). 

3) I do not believe that the applicant has fulfilled one of the primary standards for approval. Section 

1263.06(a) of the Village Code is provided below: 


10

a. Antenna/tower height. The applicant shall demonstrate that the planned height of a cellular or wireless 

communications tower is no higher than necessary to function satisfactorily and to accommodate the colocation 

requirements as set out in division (f) of this section. No tower that is taller than the necessary 

height shall be approved, and the height of any tower to be greater than 200 feet must first be approved 

by the Planning Commission. Cellular towers shall be monopole construction unless it is demonstrated 

upon application that another type of tower is required for safety purposes and it has been approved by 

the Planning Commission. 

Mr. Wahl has testified that Cricket needs their antenna to be at the top of a 150’ tower at the Rest Haven 

sites to “provide reasonable, reliable, and satisfactory service to (their) customers”. If they cannot “provide 

reasonable, reliable, and satisfactory service to (their) customers” at a height below 150’ then how can 

other service providers? The Village Code states that a pole at 150’ needs to be able to accommodate 4 

antennas. I have spoke to cell tower professionals and found out that antennas need to be separated by 

10’-15’ (Verizon typically wants 15’), depending on the frequencies being used. Even assuming that the 

10’ separation can be obtained, this means that the lowest antenna would be at 120’. The burden of proof 

is for Arcadia to demonstrate that other carriers can “provide reasonable, reliable, and satisfactory service 

to (their) customers” with an antenna at 120’. 

Mr. John B. Scola from Cincinnati Bell Wireless has provided a letter stating their intention to collocate on 

the monopole. I spoke to Mr. Scola regarding this matter. He said that he is not an RF engineer, rather he 

works in the real estate division. I asked him about the height of the pole and if they were using some 

other technology that allowed them to go lower on the pole and still provide reliable service. He said that 

they may use different frequencies, but that they are using the same basic technology as Cricket. He also 

said that when he is evaluating a location, they always want the highest position they can get, but due to 

height restrictions or community opposition, you have to reduce the height of the antennas. The lower you 

go on the pole, the more dropped calls you get from phones transferring from one antenna to another. 

In this case, CBW’s preference would be to locate as high on the pole as possible, but their letter of 

support recognized that in his words “they could live with 140’”. I did not ask him if he could live with 120’ 

because he is not an RF engineer. He said that he would send me some coverage maps at different 

heights, but I have not received those yet. 

Response: 

There are various reasons why a tower of 150 ft would be advantageous over a shorter tower of 120 feet. 

As stated in #1 - the terrain is somewhat challenging and the higher the antenna the better the coverage. 

We have not seen any RF propagation study data at the 120 foot level and can not reliably judge whether 

this height would meet their design requirements. Also if a shorter tower is placed the economic value of 

the site is decreased and the lower slots become less desirable. It was stated that either/both CBW 

and/or T-Mobile would possibly be interested in co-locating on this site, but it is unknown whether the 

lower heights would meet their coverage objectives. 

Arcadia Response: See attached Cricket response and RF data showing Cricket RF propagation at 140’ 

and 120’. Section 1263.06(a) states that applicant shall demonstrate that the tower “is no higher than 

necessary to function satisfactorily and to accommodate the co-location requirements as set out in 

Subsection 1278.06(f).” As the Village of Evendale Ordinance 04-37 has no Subsection 1278.06(f), there 

is no co-location requirement in Section 1263.06(a). Arcadia has designed the tower to meet the 

requirements of Section 1263.06(F)(3.) which requires that the tower “be designed, engineered and 

constructed to support antennas installed by at least four cellular or wireless communications service 

users.” There is NO requirement in the ordinance that the applicant demonstrate that any other applicant 

will be able to provide any type of service. Arcadia has exceeded the requirement by designing the tower 

to support antennas installed by 5 carriers. 

4) The last time Arcadia came before the Planning Commission, I had asked that they provide coverage 

maps for elevations at 140’, 130’, and 120’. At that time, it was acknowledged that they would do that. In 

my opinion, Arcadia has not yet satisfied the requirements of 1263.06(a), but could do so be providing 

coverage maps and/or a letter of intent from another carrier to collocate at this site with an antenna at 


Response: 


11

We agree this data would be appropriate. However, if a tower is 120 feet or less it is likely that only three 

carriers would be able to co-locate at that site. 

Arcadia Response: See attached Cricket response and RF data showing Cricket RF propagation at 140’ 

and 120’. Section 1263.06(a) states that applicant shall demonstrate that the tower “is no higher than 

necessary to function satisfactorily and to accommodate the co-location requirements as set out in 

Subsection 1278.06(f).” As the Village of Evendale Ordinance 04-37 has no Subsection 1278.06(f), there 

is no co-location requirement in Section 1263.06(a). Arcadia has designed the tower to meet the 

requirements of Section 1263.06(F)(3.) which requires that the tower “be designed, engineered and 

constructed to support antennas installed by at least four cellular or wireless communications service 

users.” There is NO requirement in the ordinance that the applicant demonstrate that any other applicant 

will be able to provide any type of service or to provide coverage maps and/or a letter of intent from 

another carrier to collocate at the site. Arcadia has exceeded the requirement by designing the tower to 

support antennas installed by 5 carriers. Arcadia has also provided a letter from Cincinnati Bell Wireless 

in the August 2008 filing stating Cincinnati Bell Wireless’ intent to collocate on the tower, as well as a 

letter from T-Mobile stating that they would look at the site as a possible collocation at a height of 140’. 

5) Arcadia has NOT provided any documentation to show why the Search Ring must be located in the 

area they are specifying. They have provided no documentation to show why the search ring must be in 

this location or why the search ring could not be located in the close commercial areas in Blue Ash? 

Response: 

See response on #2. 

Arcadia Response: Cricket provided in the August 2008 Statement of Need for Wireless communications 

facility located in Evendale Ohio a “drawing showing the boundaries of the area around the proposed 

location which would probably also permit the antenna to function properly in the company’s grid system” 

in accordance with Village of Evendale Ordinance 1263.05 (A). Cricket has a site in the close commercial 

area of Blue Ash as indicated in this report. The area of the allowable zone in Blue Ash is the Blue Ash 

Airport. As shown in Arcadia’s August filing in a memorandum to the Evendale Planning Commission 

dated August 2008 from Samuel T. Johnston, Jr. Exhibit 2 contains a report from Walter Wulff dated May 

15, 2007 that demonstrates that the height of a tower at the airport would be limited by its proximity to the 

airport. 

6) There are numerous discrepancies in the documents regarding the size of the footprint needed for a 

tower site. The original Evendale Gateway proposal was 45X45; the Rear of Rest Haven is 50X100 and 

the Maintenance Shed is 50X60. Even within the same location there are inconsistencies on the size of 

the footprint needed. The goal should be to minimize the site footprint. 

Response: 

The size of the footprint is related to the number of carriers and the technology and standards that they 

deploy. Not all carriers use shelters and emergency generators. The 50x100 represents a worse case 

scenario and it is better to have the space allocated than to attempt to expand at a later date since there 

are significant conduit and grounding considerations. 

Arcadia Response: Per ordinance 1263.06 (F) #3, last paragraph Arcadia, “must demonstrate that the 

area of acquired by lease or otherwise acquired for the use and construction of the cellular tower and 

accessory structures is sufficient in size to accommodate any additional structures that may be 

required if additional users are added to the tower.” As shown in Arcadia’s August filing of site plans, 

Arcadia has demonstrated that the lease area will accommodate additional equipment cabinets or 

shelters of 5 carriers. 


12

7) If a 150 ft tower is required by Cricket, how will 3 or 4 other carriers find it beneficial to locate on this 

tower? 

Response: 

Co-location allows carriers to share common infrastructure. Reducing the height reduces co-location 

opportunities. 

See #2 & #5 

Arcadia Response: Arcadia generally agrees with Stratum that reducing the height reduces collocation 

opportunities. Arcadia has designed the tower to meet the requirements of Section 1263.06(F)(3.) which 

requires that the tower “be designed, engineered and constructed to support antennas installed by at 

least four cellular or wireless communications service users.” There is NO requirement in the ordinance 

that the applicant demonstrate that any other applicant will be able to provide any type of service or to 

provide coverage maps and/or a letter of intent from another carrier to collocate at the site. Arcadia has 

exceeded the requirement by designing the tower to support antennas installed by 5 carriers. 

8) In order to close coverage gaps, do you always look for just one location, or do you co-locate on 

multiple towers? 

Response: 

To locate on additional tower locations versus a single location for the same coverage would increase the 

capital and operating expenditures of the carrier. 

Arcadia Response: In Cricket’s August 2008 Statement of Need for Wireless communications facility 

located in Evendale Ohio, Cricket has provided propagation maps showing the multiple towers adjacent 

to the proposed site on which they have collocated for the purpose of closing their coverage gaps. 

9) How many customers do you have in the Village of Evendale? How many POPs do you need now? 

What is the coverage subscriber? What is meant by the number 7,6785.17 on the current cricket 

coverage slide??? Is this a typo? When you indicate covered subscribers for the entire area, what is the 

entire area you are referring to? The whole map? Just the additional coverage by the proposed tower? 

What? 

Response: 

Typically a site is built to provide coverage for a particular population density. This data is embedded in 

various software tools to determine the economic value of the site. It does not represent the actual 

number of Cricket customers. 

Two types of customers would be served from this site. These would include actual Cricket customers 

who live in the area and customers that would be ‘visiting’ the area and able to connect to the network. 

The customer data would only be available from Cricket. 

Arcadia Response: Per the Statement of Need for wireless communications facility located in Evendale 

Ohio dated August 2008 submitted by Gregory Wahl, RF Engineer for Cricket Communications, Inc. 

Cricket has demonstrated a lack of coverage in their service area due to the coverage gap in Evendale, 

and has a right to provide reliable wireless service per its FCC license. Arcadia further agrees with the 

Stratum Broadband Tower Review Summary Report October 30, 2008, Section 4.1, bullet point 1, which 

states “Drive testing was performed by Cricket to verify the service gap.” 

10) You indicated that as a 1900MHz carrier, you must have as a minimum a 150 foot tower, is this 

correct? You indicated that you requested a taller tower, but were rejected. Did you ask for a site with a 

higher elevation? It would seem logical to believe that by putting the tower at a point in the cemetery that 

is at a higher elevation, you would effectively get a ‘taller’ tower. Is this the case? 

Response: 


13

The height of the tower is not a function of frequency. Granted higher frequencies do not propagate as 

well as lower frequencies, but as a rule the higher the site the greater distance that can be covered by 

that site. 

Height is only one of the factors in designing a site. 

Arcadia Response: See Statement of Need for wireless communications facility located in Evendale Ohio 

dated August 2008 submitted by Gregory Wahl, RF Engineer for Cricket Communications, Inc. 

11) You indicated that you could not meet your coverage needs without having a 150 foot tower, but that 

Cincinnati Bell could co-locate because they had a different frequency (800-850MHz I believe). Is this 

correct? 

Response: 

All carriers have different licensed frequencies and up to four carriers can be co-located on a 150 foot 

tower of this type. 

The lower the height the less coverage is provided from that site. The coverage that is expected to be 

provided can not be determined without performing RF propagation studies as discussed previously. 

Arcadia Response: Cincinnati Bell stated its intent to collocate on the tower in the letter dated August 8, 

2008 from John Scola and part of Arcadia’s August 2008. 


14

Cricket Communications Response to 

The Village of Evendale Tower Review Summary Report 

prepared by Stratum Broadband 


Sections 2-4 

2. Arcadia’s January 2008 Submittal 

This section contains observations and follow-up questions relating to Arcadia’s January 

2008 submittal to the Village of Evendale. 


• RF search ring seems to be centered on the proposed site rather than a larger area. 

A: This was done internally by Cricket for simplifying our internal project management process and to 

remove any confusion for our site development team. The original search ring center was on the “Gateway” 

location, with the current proposed site location falling well within said search ring. 

• RF Plots were performed for only existing coverage, the church, the Crown Castle tower and 150 foot 

proposed tower. No RF plots were provided at lower levels to show that a shorter tower would not meet their 

design needs. 

A: Please see attached RF plots at 140’ and 120’. 

• RF Plots have been provided for the church and Crown Castle but not other towers or industrial sites. 

A: Cricket did provide additional coverage plots in the initial presentation showing that utilizing what 

available tower heights there were on existing co location opportunities did not help us in providing coverage 

in our targeted area. 

• Although the Sims provided were good, they were performed when the trees were fully leaved. 

• The equipment compound is located in a residential area and consideration has to be given to hide as many 

aspects as possible such as the addition of tree topped berms. 

• If a site is necessary in this area, the cemetery seems to be the logical location for placement. 





• Provide RF Plots for a minimum of 120 foot level. 

A: Please see attached RF plots at 120’. 

• Did you look at other sites in the area including all existing towers and industrial areas? Should provide RF 

plots for those areas that were considered. 

A: Yes, all possible existing structures were considered. 

• Sims should be provided of both the tower and ultimate equipment site without leaves. This should be 

done from various angles. 


1


This section contains observations and follow-up questions relating to the August 2008 staff report by 

Kathleen Farro summarizing the deficiencies in the January submittal. 


• We agree that there was no documentation other than a statement that attempts were made to find 

suitable locations in other zoning districts or neighboring villages. 

Comment: We currently have operational sites active and providing service in all neighboring districts and 

villages. The fact that Cricket has a demonstrable coverage issue within the confines of Evendale is due to 

the fact that there are no existing suitable co location opportunities and the local terrain works against us 

“bleeding in coverage from neighboring sites at an acceptable signal level. We have provided plots 

indicating where Cricket has existing sites on air, zoned through neighboring districts. 




This section contains observations and follow-up questions relating to the accordion folder containing the 

contents of Arcadia’s follow-up August 2008 submittal, including a memo response to the August staff 

report. 



• Documentation of the RF Propagation maps provided show 9 existing towers, but have plots for four 

existing towers, one rooftop and a Duke Energy pole. 

A: See attached Cricket provided drive test plots. 



• There are other alternative technical solutions to provide service (eg. Distributed Antenna Systems) that 

were never considered by Cricket. 

• It appears that all standard site development processes have been properly managed including lease 

documentation, site surveys, Phase 1 Environmentals, SHPO Review, FAA Analysis, etc. 


• What engineering criteria did Cricket use to verify the service gaps and what were the results of the drive 

testing? 

A: Current contour depiction is at -95dBm. This is a level we consider verifies quality signal to the 

customer. Our modeling of coverage is based on CW test data, and utilizing both DEM data (30m 

resolution) and clutter (land use – 1m resolution). See attached drive-test data. 

• Were all of the towers on the maps considered for co-location? Plots should be done for all existing towers 

or should be explained why they were not considered. 

• What was the reason for Crown Castle stating it was not feasible to replace the tower? 


A: We have shown that all of the neighboring current co-location structures resultant coverage does 

not meet our coverage requirement. Moving the search ring or expanding it does not change the fact that 

none of these towers work for us. 


A: Cricket is a licensed cellular provider by the FCC, call sign for the Cincinnati BTA#81 is WQDI523. 

Our license is for PCS broadband, including CDMA PCS1900. 

2

5. Kathleen Farro Email to Jack Cameron – 

Summary of August 2008 Submittal Deficiencies 

This section contains observations and follow-up questions relating to an email from Kathleen Farro to Jack 

Cameron summarizing the submittal deficiencies of the August 2008 submittal. 


• Kathy Farro’s review appears to be complete and additional engineering documentation she referred to is 

detailed in Section 4 of this report. 


• None 


Residents 

This section contains observations and follow-up questions relating to various emails and letters submitted 

by adjacent residents. 


• Residents have expressed concern about existing coverage and questioned the need for improvement. 

Some stated that they already had coverage with documentation showing completed test calls assuming 

that there was no existing coverage. Cricket has stated that they had complaints about spotty coverage 

and were attempting to improve coverage and E911 services by deploying an additional site. Without drive 

testing data, which would show actual coverage vs theoretical RF plot data, there is no realistic way of 

determining actual existing coverage. 

Multiple items here: 

• Residents have expressed concern about existing coverage and questioned the need for improvement. 

Some stated that they already had coverage with documentation showing completed test calls 

assuming that there was no existing coverage 

A: Cricket is working to a -95dBm contour. This is a signal level we consider a good quality level for our 

customers. Yes, a handset sensitivity in the lab can be down to -103dB, however, we have to take into 

account many real world issues. These include fade, masking and handset performance. 

Fade = Link to better explain it = http://en.wikipedia.org/wiki/Fading 

Multi-path = Link to better explain it = http://en.wikipedia.org/wiki/Multipath 

Handset performance = Cricket sells multiple brands and models of handset. Not all are alike in 

performance. Customers also tend to abuse their handsets, which could include dropping them. 

• Cricket has stated that they had complaints about spotty coverage and were attempting to improve 

coverage and E911 services by deploying an additional site. Without drive testing data, which would 

show actual coverage vs theoretical RF plot data, there is no realistic way of determining actual existing 

coverage 

A: See attached Cricket provided drive test plots. 


• White space is shown on RF plots as no coverage with a level of -95 Db. Some handsets will work at -103. 

An RF plot of existing RF ‘Rx Qual’ up to level 4 would show a truer picture of existing theoretical coverage. 

A: What does Stratum assume is Level 4 signal? 

3

Cricket Communications 

Search Ring CVG-280 

Evendale, , Ohio 

RF Engineering 

November 2008

Introduction 

• The Ohio RF engineering team has identified a large 

coverage hole in the vicinity of Evendale and the western 

portion of Blue Ash. The key area of coverage need is along 

Glendale Milford Rd. and Plainfield Rd. 

• We have completed extensive analyses of any and all 

collocation opportunities in this area, including the use of 

utility u y poles, po , any a y rooftops, oo op , and a d existing g sites. Three possible po b 

options were identified. 

• These options include the following: 

− Crown existing 66’ Monopole 

− Arcadia proposed Rest Haven 150’ Monopole 

− Arcadia alternate Rest Haven 150’ monopole p 

2 Confidential/Proprietary

Review of Candidates – Option 1 

• Crown Monopole: 

− Coordinates (39.252N , -84.4013W) 

− Address : 3853 Glendale Glendale- Milford Rd Rd, Cincinnati, Cincinnati OH, OH 45241 

− Site description: Monopole, 66ft in height, located off parking 

lot behind church. 

− Concerns : 

3 Confidential/Proprietary 

• Monopole height is too low. low 

• Current tenant is T-Mobile at 65’. Next available height 

is 55’, which will not meet our coverage objective. 

• As the site is located down the grade from Glendale 

Milford road, road a transmission height of 55 55’ would be well 

below tree height, and not give us the coverage 

footprint we require 

• Crown Castle has been approached on the possibility of 

a tower extension. However, to attain the height we 

need would require replacement of this monopole and 

lease changes to a bigger compound, which they 

indicated was not feasible.


• Arcadia Rest Haven proposed 150’ monopole: 

− Coordinates (39.250242 , -84.403333W) 

− Address : 10209 Plainfield Rd, Rd Cincinnati, Cincinnati OH, OH 

45242 

− Cricket has approached Arcadia 

Communications for collocation on this 

proposed p p site build. 

− Configuration is that of a 150’ monopole, 

capable of collocating multiple carriers. 

− This location would meet our coverage 

requirements. 

− A height of 150’ is required for us to meet our 

coverage objectives. 


Arcadia Rest Haven


• Arcadia Rest Haven alternate 150’ 

Monopole: 

− Coordinates (39 (39.252092 252092 , -84 84.397475W) 397475W) 

− Address : 10209 Plainfield Rd, Cincinnati, 

OH, 45242 

− This site Arcadia Towers has proposed as an 

alternative at the Rest Haven site. 

− The proposed configuration is a 150’ 

monopole, capable of collocating multiple 

carriers. 

− This location would meet our coverage 

requirements. 

− A height of 150’ is required for us to meet 

our coverage objectives. 


Arcadia alternate

Existing towers 


Search Ring # 280 

Existing towers 

• The Search ring radius is 

0.5 miles. 

• The minimum height 

required for this Site is 

150’. 

• The small symbols in the 

plot represent the existing 

tower collocation 

opportunities in the area. 

• Only one existing tower 

falls within the search 

ring, the Crown Castle 65’ 

tower. 

• Th The 0.5 0 5 miles il radius di is i 

determined by the local 

topography, which is very 

dynamic in this area, 

falling sharply to the 

west. 

• Current motivation for 

this site is improved 

coverage and the high 

number of customer 

complaints due to lack of 

such coverage. 

coverage


Search Ring # 280 Mapped 

Crown 66’ monopole 

• Search ring radius is half 

a mile. 

• There is only one current 

collocation opportunity 

inside this Search ring 

area, the Crown Castle 

66’ 66 monopole which is 

insufficient to meet our 

coverage requirements.


Search Ring # 280 Mapped 

• Search ring radius is half 

a mile. 

• Terrain topography 

• The yellow rings 

represent the two focus 

areas where we require 

imp improved o ed coverage. co e age


Current Cricket Coverage 

Search Ring 

• The white areas indicate 

lack of Cricket coverage. 

• Note that we suffer in 

coverage on both the 

north and south sides of 

Glendale Milford Rd and 

along Plainfield Rd (circled 

in yellow). 

• Cricket currently receives 

many customer 

complaints on the lack of 

coverage in this area. 

• A further key concern is 

E911 locating is degraded 

due to this poor reception.


Option 1 Added coverage 

Coverage shown with the 

proposed Crown Castle 

monopole result included, 

transmission height of 55’. 

The existing coverage holes 

show insufficient 

improvement in coverage 

gaps. 

This Option is not feasible 

for Cricket as it will not 

meet our coverage needs. 

Crown Castle has indicated 

to Cik Cricket that h the h pole l has h 

a single carrier capability.



(Rest ( est Haven) a e ) 150ft 50 t 

• Coverage shown with the 

proposed Arcadia Rest 

HHaven 150’ monopole. l 

• The existing coverage holes 

are significantly reduced, 

both north and south of 

Glendale Milford Rd. 

• The coverage in Plainfield 

Rd. has improved as well, 

and will meet our coverage 

need.



(Rest ( est Haven) a e ) 140ft 0 t 


proposed Arcadia Rest 

Haven site propagating at 

140ft. 

• Note the difference we 

experience in dropping 

down from 150ft to 140ft. 

• The results clearly show us 

opening up some coverage 

holes vs the proposed 

150ft.



(Rest ( est Haven) a e ) 120ft 0 t 


proposed site propagating 

at 120ft. 

• The results show that we 

have opened coverage 

holes, both North and South 

of Glendale Milford Rd. 

• The coverage along 

Plainfield Rd. has also been 

diminished. 

• The height of 120ft will not 

meet a majority of our 

current iintent for f providing idi 

good coverage.


Coverage for 3 poles on Cooper Rd 

Coverage for the poles along Cooper rd. 

• Coverage Plot shows 

coverage if using 

transmission Poles along 

Cooper rd. 

• The assumed pole height 

is around 52ft tall. These 

are bigger than usual 

poles. p


Satellite view of the target area 

• Satellite view with the 

proposed site location 

included. 

• Note the dense 

residential 

neighborhoods which 

currently fall in 

coverage holes (yellow 

circles). 

• Cricket’s preferred 

location is the Arcadia 

Rest Haven site.

Collocation Analysis 

Crown Sharonville Exon Dr. 


• Coverage shown Crown 

monopole located at 

Sharonville. 




gaps. 

• This Option is not feasible 

ffor CCricket i k t as it will ill not t 

meet our coverage needs. 

• The height available 114ft, 

resultant coverage plotted 

• Monopole Information: 

− Monopole height:134ft 

− Monopole ID:875912 

− Available heigth:114ft



American Tower Reading Road 

• Coverage shown American 

Tower monopole located at 

Reading Road. 

• The existing g coverage g holes 



gaps. 

• This Option is not feasible for 

Cricket as it will not meet our 

coverage needs needs. 

• The height available 130ft, 



− Monopole height:150ft 

− Monopole ID:307704 




Current Cricket Rooftop Site 

• Current Cricket Site on this 

rooftop. 

• The Sector facing west along 

Glendale Milford Rd is getting 

around 8% DC in the busiest 

hour per day. 

• It is no way to provide 

coverage going west of the 

intersection Plainfield Rd and 

Glendale Milford Rd from this 

Site. The terrain goes down 

and we lost the signal. 

• Duke Rooftop information. 

− Lake Forest drive 

− Height of roof:105ft 

− Height available: 

105ft



Duke pole Plainfield Road 

• Coverage shown Duke power 

pole located at Plainfield Road. 


show insufficient improvement 

in coverage gaps. 

• This Option is not feasible for 

Cricket as it will not meet our 

coverage needs. 

• The height projected is for 

45ft 

• Duke Utility pole Information: 

− Utility pole height:55ft 

− Utility pole ID:oh-01- 

001 


20 Confidential/Proprietary 


RW tower Plainfield Road 

• Coverage shown Raymond 

Walters tower located at 

Plainfield Road. 

• This Option p was looked at 

by Cricket, however, the 

current tower is structurally 

limited, it would not be able 

to support our antennas. 

The tower would have to be 

replaced, including new 

foundations. FAA limitation 

is 100ft at this location due 

to airfield flight path 

• The site owner is not 

interested in such an 

investment. 

• The height g available 90ft, , 



− SS tower height:100ft 




Jewish Hospital rooftop Reading Road 

• Coverage shown Jewish 

Hospital rooftop located at 

Reading Road. 


show insufficient improvement 

in coverage gaps. 

• This Option only assists us on 

the West portion of our target 

area. 

• Rooftop opportunity. 

− Jewish Hospital 

− Height of roof:50ft 

− Height available: 50ft


Current Cricket Coverage with User test locations shown


Drive test results, collected 110708 with leaves off the 

trees, shown with User test locations


Drive test plot results overlaid on project coverage, 

collected 110708 with leaves off the trees, shown with 

User Use test locations ocat o s 

• Current plot 

shows a overlaid 

between Drive 

test data 

collected 11-07- 

08 and the 

prediction on 

the coverage 

plot. 

• In some areas 

the predictions 

coverage plots 

looks better 

than the current 

drive test 

collected data.

• Satellite view of the 

proposed location 

with current sites. 

• The blue polygons 

show areas with 

coverage gaps.

• Current 

Coverage in 

Evensdale. 

• The pink 

polygons show 

coverage gaps 

in the 

Cincinnati Bell 

network. 

>= -75 dBm 

< -75 dBm >= -85 dBm 

< -85 dBm

• Coverage with 

site at Jewish 

Hospital rooftop 

at Reading 

road. 

• Th The option i does d 

not improve the 

Cincinnati Bell 

coverage in the 

area. 

Jewish Hospital 

rooftop Reading Road 

>= -75 dBm 

< -75 dBm >= -85 dBm 

< -85 dBm


site at Crown 

Sharonville. 

• The option does 


Ci Cincinnati i i Bell B ll 


area. 

Crown Sharonville Exon Dr. 

>= -75 dBm 

< -75 dBm >= -85 dBm 

< -85 dBm


site at AMT- 

Matthews. 





area. 

AMT-Matthews 

>= -75 dBm 

< -75 dBm >= -85 dBm 

< -85 dBm


site at Duke 

pole. 





area. 

Duke pole Plainfield Road 

>= -75 dBm 

< -75 dBm >= -85 dBm 

< -85 dBm


site at Raymond 

Walters tower. 





area. 

Raymond Walters tower 

>= -75 dBm 

< -75 dBm >= -85 dBm 

< -85 dBm

• Cincinnati Bell 

has a tower at 

the 4445 Lake 

Forest Drive. 

4445 Lake Forest Drive 

>= -75 dBm 

< -75 dBm >= -85 dBm 

< -85 dBm

• The preferred 

location of 

Arcadia towers 

improves the 


area area. 

• The location 

best suits 

Cincinnati Bells 

coverage 

improvement 

plan for the 

area. 

Arcadia’s preferred location. 

>= -75 dBm 

< -75 dBm >= -85 dBm 

< -85 dBm

Tower Review Summary Report 


Prepared by: 


116 Main Street, Suite 201 

Medway, Massachusetts 02053

Table of Contents 

1. Introduction...................................................................................................................3 

1.1. Purpose..................................................................................................................3 

1.2. Methodology and Report Format ...........................................................................3 

2. Arcadia’s January 2008 Submittal................................................................................5 

2.1. General Observations ............................................................................................5 

2.2. Follow-Up Questions..............................................................................................5 

3. August 2008 Staff Report by Kathleen Farro ...............................................................6 



4. Arcadia’s August 2008 Follow-Up Submittal ................................................................7 



5. Kathleen Farro Email to Jack Cameron – Summary of August 2008 Submittal 

Deficiencies ..................................................................................................................8 



6. Various Emails and Questions by Adjacent Residents ................................................9 



Attachment A: Stratum Broadband Resumes...................................................................10 

Attachment B: Immediate Concerns Document................................................................14

1. Introduction 


Evendale, Ohio 


On behalf of the Village of Evendale, Ohio, Manley Burke requested that Stratum 

Broadband review a submittal by Arcadia Communications to locate a cellular tower site 

in the Village. This report summarizes the findings, observations/interviews, and 

recommendations Stratum Broadband LLC made on that submittal. 

1.1. Purpose 

This report reviews all submittals for the proposed tower site(s) to ensure that all proper 

due diligence was done for compliance with engineering standards used across the 

telecommunications industry. This review was conducted by Stratum Broadband LLC 

principals, John Foresto and Eugene Currie, each with over thirty years experience in the 

industry. Resumes for both are included as Attachment A. 

1.2. Methodology and Report Format 

Manley Burke submitted to Stratum Broadband a binder containing documents pertinent 

to Arcadia’s request for a tower site. Those documents were categorized into five 

different parts. Mr. Foresto and Mr. Currie of Stratum Broadband reviewed all the 

documents in the binder and organized their observations and follow-up questions into 

this report. 

The format for this report corresponds to the order of the original parts. Hence, in the 

table below, the Documentation column summarizes the documents from each part of 

the original binder and the Section column indicates which section of this report contains 

the reviewers’ findings. 

Section Documentation 

2 A binder containing Arcadia’s January 2008 submittal to the Village 

3 An August 2008 staff report by Kathleen Farro summarizing the deficiencies 

in the January submittal 

4 An accordion folder containing the contents of Arcadia’s follow-up August 

2008 submittal, including a memo response to the August staff report 

5 An email from Kathleen Farro to Jack Cameron summarizing the submittal 

deficiencies of the August 2008 submittal 

6 Various emails and letters submitted by adjacent residents 

In each section the findings are divided into two subsections: General Observations and 

Follow-Up Questions. In addition, Stratum Broadband prepared a brief document for 

Stratum Broadband Confidential October 30, 2008 

Page 3




Kathleen Farro (City Planner/Town of Evendale) addressing her immediate concerns. 

That document is included as Attachment B. 

Stratum Broadband did not review issues related to zoning such as required setbacks. 


Page 4

2. Arcadia’s January 2008 Submittal 




This section contains observations and follow-up questions relating to Arcadia’s January 

2008 submittal to the Village of Evendale. 


• RF search ring seems to be centered on the proposed site rather than a larger 

area. 

• RF Plots were performed for only existing coverage, the church, the Crown 

Castle tower and 150 foot proposed tower. No RF plots were provided at lower 

levels to show that a shorter tower would not meet their design needs. 

• RF Plots have been provided for the church and Crown Castle but not other 

towers or industrial sites. 

• Although the Sims provided were good, they were performed when the trees 

were fully leaved. 

• The equipment compound is located in a residential area and consideration has 

to be given to hide as many aspects as possible such as the addition of tree 

topped berms. 

• If a site is necessary in this area, the cemetery seems to be the logical location 

for placement. 





• Provide RF Plots for a minimum of 120 foot level. 

• Did you look at other sites in the area including all existing towers and industrial 

areas? Should provide RF plots for those areas that were considered. 

• Sims should be provided of both the tower and ultimate equipment site without 

leaves. This should be done from various angles. 



Page 5





This section contains observations and follow-up questions relating to the August 2008 

staff report by Kathleen Farro summarizing the deficiencies in the January submittal. 


• We agree that there was no documentation other than a statement that attempts 

were made to find suitable locations in other zoning districts or neighboring 

villages. 




Page 6





This section contains observations and follow-up questions relating to the accordion 

folder containing the contents of Arcadia’s follow-up August 2008 submittal, including a 

memo response to the August staff report. 



• Documentation of the RF Propagation maps provided show 9 existing towers, but 

have plots for four existing towers, one rooftop and a Duke Energy pole. 



• There are other alternative technical solutions to provide service (eg. Distributed 

Antenna Systems) that were never considered by Cricket. 

• It appears that all standard site development processes have been properly 

managed including lease documentation, site surveys, Phase 1 Environmentals, 

SHPO Review, FAA Analysis, etc. 


• What engineering criteria did Cricket use to verify the service gaps and what 

were the results of the drive testing? 

• Were all of the towers on the maps considered for co-location? Plots should be 

done for all existing towers or should be explained why they were not considered. 

• What was the reason for Crown Castle stating it was not feasible to replace the 

tower? 




Page 7




5. Kathleen Farro Email to Jack Cameron – 

Summary of August 2008 Submittal Deficiencies 

This section contains observations and follow-up questions relating to an email from 

Kathleen Farro to Jack Cameron summarizing the submittal deficiencies of the August 

2008 submittal. 


• Kathy Farro’s review appears to be complete and additional engineering 

documentation she referred to is detailed in Section 4 of this report. 


• None 


Page 8


Residents 




This section contains observations and follow-up questions relating to various emails and 

letters submitted by adjacent residents. 


• Residents have expressed concern about existing coverage and questioned the 

need for improvement. Some stated that they already had coverage with 

documentation showing completed test calls assuming that there was no existing 

coverage. Cricket has stated that they had complaints about spotty coverage 

and were attempting to improve coverage and E911 services by deploying an 

additional site. Without drive testing data, which would show actual coverage vs 

theoretical RF plot data, there is no realistic way of determining actual existing 

coverage. 


• White space is shown on RF plots as no coverage with a level of -95 Db. Some 

handsets will work at -103. An RF plot of existing RF ‘Rx Qual’ up to level 4 

would show a truer picture of existing theoretical coverage. 


Page 9

Attachment A: Stratum Broadband Resumes 

John Foresto 




Summary Telecom engineering and operations professional with over 30 years experience in planning, 

designing, building, and operating carrier-class voice and data networks. Proven large team 

management skills with a successful track record in delivering new technology and large projects 

on time and within budget. 

Experience Stratum Broadband, LLC February 2003 – Present 

Managing partner 

Provides consulting/management services to municipalities, hospitals, colleges and universities 

on network convergence, sustainable business models, and support system development, 

architecture, and utilization. 

JF Consulting February 2002 –January 2003 

Principal 

Provided consulting/management services to major ISP on scaling wholesale VoIP operations, 

work center consolidations, and support system development, architecture, and utilization. 

Verizon Advanced Data Services Inc. July 1999 – February 2002 

Senior Vice President – Engineering, Planning, and Implementation 

Led successful separation of VADI engineering from ILEC to meet conditions mandated by Bell 

Atlantic/GTE merger. Implemented complete new suite of systems required to support 

$900M/year build out of Verizon DSL and fast packet networks and scaled provisioning processes 

from 1000 orders a day to 20,000 orders a day. 

Bell Atlantic Global Networks Inc. October 1997 – July 1999 

Vice President – Engineering, Planning, and Provisioning 

Managed the design, engineering, and build of the Bell Atlantic next-generation data/voice 

network for long distance entry. Built “Greenfield” organization and serviced first switch within 

eight months of business launch. Network build on time and on budget. 

NYNEX 1996 - 1997 

General Manager – Network Operations: Massachusetts 

Managed organization of over 1800 people. Responsible for service delivery and maintenance for 

all inside work within Massachusetts. Re-created “network-focused” organization from prior 

“market-area” organization. Improved both service performance and financials. 

NYNEX International, Philippine Islands 1996 

Senior Consultant 

Led team to architect and design network for Bayantel, the NYNEX affiliate in the Philippines. 

Recommended a series of acquisitions and network builds to establish the infrastructure for the 

national network. 

NYNEX 1994 - 1996 

Executive Director – Technical Support 

Managed second tier technical support group for enterprise-wide organization across all 

technologies. Responsible for network management and overall network performance. Reviewed 

performance statistics with major customers and directly supported sales activities. 


Page 10

New England Telephone Company 1992 - 1994 

Executive Director – Technical Services 




Managed second tier technical support organization. Responsibilities beyond technical support 

included network management and management of access tandems and operator services 

networks throughout the region. Project managed signaling network buildout ($300M). 

Director of Operations 1990 – 1992 

Directly supervised six reporting managers responsible for providing second tier surveillance for 

switching and facilities network management. Also provided second tier field support for all NET 

service offerings (analog and data) and system administration for transmission and test 

operations support systems. Dealt directly with internal and external customers. 

District Manager and Manager Positions 1972 – 1992 

Held various management-level positions within NET in operations, network planning, and engineering. 

Education Rutgers University – Advanced Management Program, 1990 

Northeastern University, MBA, 1972 

University of Massachusetts, BS ChE, 1968 


Page 11

Eugene Currie 




Summary Telecom engineering and operations professional with over 35 years experience in planning, 

designing, building, and managing carrier-class voice and data networks. Proven technical ability 

with extensive training and hands-on experience in many technologies. Subject matter expert in 

various technologies. 

Experience Stratum Broadband, LLC February 2003 – Present 

Senior Consultant and Partner 

Provides consulting/management services to municipalities, hospitals, colleges and universities 

on network convergence, sustainable business models, and support system development, 

architecture, and utilization. Performed all aspects of a major project at a large university which 

resulted in the completion of a cellular carrier distributed antenna system, remote transmitter 

system, twenty eight point-to-multipoint wireless links and a wireless network security system. 

Designed and implemented a pre-WiMax wireless data system for a pilot in the State of Rhode 

Island. 

Accelera Wireless, LLC, Westwood, MA 2000 – 2003 

Vice President, Quality Systems and Partner 

Developed and executed a formal corporate-wide Quality Plan which included the development 

and implementation of all process flows, procedures, and forms for most administrative functions 

as well as field related disciplines for wireless site development. Played a key role in the 

development and implementation of the corporate integrated Web-based project tracking system. 

Teligent, Inc., Boston, MA 1998 - 2000 

Manager, Central Office 

Supervised all aspects of implementation for a central office facility in the Teligent Boston 

Wireless Telecommunications Market including building construction, switch installation and 

acceptance, facility entrance design, voice and data communications, integration testing and 

market launch. Set corporate standards for switch performance, remote node capacity planning, 

and environmental alarms. Selected for the Teligent’s President Circle, a program honoring the 

top 100 performers in the company. 

Boston Communications Group, Woburn, MA 1997 - 1998 

Senior Manager, SS7 Network Engineering 

Implemented a state-of-the-art SS7 platform used for ISUP communications to remote voice 

nodes in the pre-pay cellular industry. Scheduled, installed and tested all SS7 signaling links and 

network route-sets. Developed numerous UNIX shell scripts and system customizations to 

mechanize and simplify trouble resolution as well as associated documentation. 

NYNEX Video Services Operations, Needham, MA 1996 - 1997 

Director, Network Operations 

Designed, planned, scheduled, and implemented a centralized monitoring and control 

environment for the operation of a digital head-end facility. Performed all aspects including 

scheduling, budgeting, staffing, design, hardware and software integration, vendor coordination, 

installation, and process development. Redesigned the overall support system architecture to 

accommodate a diverse multi-vendor environment.. 


Page 12

NYNEX (New England), Boston, MA 1971 - 1996 

Operations Manager, Network Reliability 




Selected to head a then newly formed team of subject-matter-experts to identify risk factors and 

improve overall performance and survivability of NYNEX’ telecommunications network in the 

areas of fiber, SS7, switching, E911, and network timing. Improved overall network survivability, 

identified various network design deficiencies and provided recommendations for improvement. 

Operations Manager, Systems Implementation 

Operations departmental coordinator and project manager for the successful deployment of 

Signaling System 7 network as well as all requirements for the FCC mandated 800 Number 

Portability Project. Project was completed successfully in a compressed interval of time with very 

little service impact. 

Operations Manager, Technical Support / Maintenance Engineering 

Managed group of telecommunications experts who provide technical support for electronic 

switches throughout the New England area. Systems supported included Lucent’s 1ESS, 

1AESS, 2BESS, 5ESS and Nortel’s DMS10 and DMS100. Also managed the team, which 

maintained the overall integrity of the Signaling System 7 network in the New England area as 

well as all testing for conformance certification of interconnecting switches. 

Operations Manager & Supervisor, Field Operations 

Managed field operations center, which supported twenty-two central offices, and work force of up 

to 95 people through eight supervisors. Managed all aspects of daily operations including the 

administration, provisioning, and maintenance of various types of telephone switches serving 

Southeastern Massachusetts. Supervised all maintenance, administration, and personnel 

activities for a 1ESS Electronic Switching Central Office in Southeastern Massachusetts. 

Education Eastern Nazarene College, BS Business Administration, 1996 - Summa Cum Laude 

ALPHA IV Program, NYNEX, 1995 - 1996 

Technical Training, NYNEX / New England Telephone / BELLCORE, 1971 - 1997 

1ESS, 1AESS, 2BESS, 5ESS, DMS100, SS7, AIN, Video Digital Encoding, Support Systems, and 

PC Applications 

Northeastern University, Electrical Engineering Program, 1968-1970 

Boston Latin School, Diploma, 1962-1968 

Member of Institute of Electrical and Electronic Engineers 


Page 13

Attachment B: Immediate Concerns Document 


Ms. Farro, 

Kathy 




In response to your request, here are some thoughts on the questions that have been raised in your 

email. 

1) Apparently Cricket needs the extra pole height because they have a higher frequency than 

ATT etc. I assume this is because the Higher RF dissipates more quickly. Is there any connection 

between coverage area and power of transmission? What are higher frequency carriers going to 

do if the only pole positions are well below 150 ft.? 

Response: 

Cricket is licensed for a PCS C band which is in the 1.9 GHz range. ATT, T-Mobile and CBW are 

also licensed in this range with their own assigned frequency bands. This frequency does not 

propagate as well as lower frequencies used for cellular service. Some cell sites can be optimized 

for up to 2-3 miles in a direct line of site arrangement. We reviewed the topographical map for 

this area (see attached PDF) and found the terrain is somewhat challenging due to the 

topography. An RF propagation plot should be done for 120 foot AGL (Above Ground Level) as 

requested previously by the Planning Commission to determine if Cricket truly requires a 150 foot 

level. 

Factors that influence service range in order of importance include: 

Frequency 

Height above terrain 

Topography including vegetation and manmade obstacles 

Antenna gain 

Equipment processing gain 

Radio Power 

2) Why is only the 0.5 Mile area shown? 

Response: 

In the documentation it shows that Arcadia asked Cricket RF Engineering if this site would meet 

their RF coverage requirements before proceeding with the pursuit of this site. It appears that the 

site was then chosen after performing satisfactory RF plots. A 0.5 mile circle was then drawn on 

the map after the fact since the site is in the center of the ring. 

Search rings are usually determined after considering the location of existing towers, the terrain, 

coverage objectives, and budget. They can range from a radius of 0.5 to 3 miles or more 

depending upon various factors. Since this site appears to be required for coverage improvement 

rather than a new network buildout, it would not be uncommon for the requirement of more 

precise placement. 

3) I do not believe that the applicant has fulfilled one of the primary standards for approval. 

Section 1263.06(a) of the Village Code is provided below: 


Page 14




a. Antenna/tower height. The applicant shall demonstrate that the planned height of 

a cellular or wireless communications tower is no higher than necessary to function 

satisfactorily and to accommodate the co-location requirements as set out in division (f) 

of this section. No tower that is taller than the necessary height shall be approved, and 

the height of any tower to be greater than 200 feet must first be approved by the Planning 

Commission. Cellular towers shall be monopole construction unless it is demonstrated 

upon application that another type of tower is required for safety purposes and it has 

been approved by the Planning Commission. 

Mr. Wahl has testified that Cricket needs their antenna to be at the top of a 150’ tower at the Rest 

Haven sites to “provide reasonable, reliable, and satisfactory service to (their) customers”. If they 

cannot “provide reasonable, reliable, and satisfactory service to (their) customers” at a height 

below 150’ then how can other service providers? The Village Code states that a pole at 150’ 

needs to be able to accommodate 4 antennas. I have spoke to cell tower professionals and 

found out that antennas need to be separated by 10’-15’ (Verizon typically wants 15’), depending 

on the frequencies being used. Even assuming that the 10’ separation can be obtained, this 

means that the lowest antenna would be at 120’. The burden of proof is for Arcadia to 

demonstrate that other carriers can “provide reasonable, reliable, and satisfactory service to 

(their) customers” with an antenna at 120’. 

Mr. John B. Scola from Cincinnati Bell Wireless has provided a letter stating their intention to 

collocate on the monopole. I spoke to Mr. Scola regarding this matter. He said that he is not an 

RF engineer, rather he works in the real estate division. I asked him about the height of the pole 

and if they were using some other technology that allowed them to go lower on the pole and still 

provide reliable service. He said that they may use different frequencies, but that they are using 

the same basic technology as Cricket. He also said that when he is evaluating a location, they 

always want the highest position they can get, but due to height restrictions or community 

opposition, you have to reduce the height of the antennas. The lower you go on the pole, the 

more dropped calls you get from phones transferring from one antenna to another. 

In this case, CBW’s preference would be to locate as high on the pole as possible, but their letter 

of support recognized that in his words “they could live with 140’”. I did not ask him if he could 

live with 120’ because he is not an RF engineer. He said that he would send me some coverage 

maps at different heights, but I have not received those yet. 

Response: 

There are various reasons why a tower of 150 ft would be advantageous over a shorter tower of 

120 feet. As stated in #1 - the terrain is somewhat challenging and the higher the antenna the 

better the coverage. 

We have not seen any RF propagation study data at the 120 foot level and can not reliably judge 

whether this height would meet their design requirements. Also if a shorter tower is placed the 

economic value of the site is decreased and the lower slots become less desirable. It was stated 

that either/both CBW and/or T-Mobile would possibly be interested in co-locating on this site, but 

it is unknown whether the lower heights would meet their coverage objectives. 

4) The last time Arcadia came before the Planning Commission, I had asked that they provide 

coverage maps for elevations at 140’, 130’, and 120’. At that time, it was acknowledged that they 

would do that. In my opinion, Arcadia has not yet satisfied the requirements of 1263.06(a), but 

could do so be providing coverage maps and/or a letter of intent from another carrier to collocate 

at this site with an antenna at 120’. 


Page 15




Response: 

We agree this data would be appropriate. However, if a tower is 120 feet or less it is likely that 

only three carriers would be able to co-locate at that site. 

5) Arcadia has NOT provided any documentation to show why the Search Ring must be 

located in the area they are specifying. They have provided no documentation to show why the 

search ring must be in this location or why the search ring could not be located in the close 

commercial areas in Blue Ash? 

Response: 

See response on #2. 

6) There are numerous discrepancies in the documents regarding the size of the footprint 

needed for a tower site. The original Evendale Gateway proposal was 45X45; the Rear of Rest 

Haven is 50X100 and the Maintenance Shed is 50X60. Even within the same location there are 

inconsistencies on the size of the footprint needed. The goal should be to minimize the site 

footprint. 

Response: 

The size of the footprint is related to the number of carriers and the technology and standards 

that they deploy. Not all carriers use shelters and emergency generators. The 50x100 

represents a worse case scenario and it is better to have the space allocated than to attempt to 

expand at a later date since there are significant conduit and grounding considerations. 

7) If a 150 ft tower is required by Cricket, how will 3 or 4 other carriers find it beneficial to 

locate on this tower? 

Response: 

Co-location allows carriers to share common infrastructure. Reducing the height reduces colocation 

opportunities. 

See #2 & #5 

8) In order to close coverage gaps, do you always look for just one location, or do you colocate 

on multiple towers? 

Response: 

To locate on additional tower locations versus a single location for the same coverage would 

increase the capital and operating expenditures of the carrier. 

9) How many customers do you have in the Village of Evendale? How many POPs do you 

need now? What is the coverage subscriber? What is meant by the number 7,6785.17 on the 

current cricket coverage slide??? Is this a typo? When you indicate covered subscribers for the 

entire area, what is the entire area you are referring to? The whole map? Just the additional 

coverage by the proposed tower? What? 

Response: 

Typically a site is built to provide coverage for a particular population density. This data is 

embedded in various software tools to determine the economic value of the site. It does not 

represent the actual number of Cricket customers. 


Page 16




Two types of customers would be served from this site. These would include actual Cricket 

customers who live in the area and customers that would be ‘visiting’ the area and able to 

connect to the network. The customer data would only be available from Cricket. 

10) You indicated that as a 1900MHz carrier, you must have as a minimum a 150 foot tower, is 

this correct? You indicated that you requested a taller tower, but were rejected. Did you ask for a 

site with a higher elevation? It would seem logical to believe that by putting the tower at a point in 

the cemetery that is at a higher elevation, you would effectively get a ‘taller’ tower. Is this the 

case? 

Response: 

The height of the tower is not a function of frequency. Granted higher frequencies do not 

propagate as well as lower frequencies, but as a rule the higher the site the greater distance that 

can be covered by that site. 

Height is only one of the factors in designing a site. 

11) You indicated that you could not meet your coverage needs without having a 150 foot tower, 

but that Cincinnati Bell could co-locate because they had a different frequency (800-850MHz I 

believe). Is this correct? 

Response: 

All carriers have different licensed frequencies and up to four carriers can be co-located on a 150 

foot tower of this type. 

The lower the height the less coverage is provided from that site. The coverage that is expected 

to be provided can not be determined without performing RF propagation studies as discussed 

previously. 


Page 17

Arcadia Final List November 20 2008.pdf - Village Of Evendale

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