In July 2001, the Loudoun County Board of Supervisors moved to adopt the "Revised General Plan" and "Revised Countywide Transportation Plan." The "Strategic Land Use Plan for Telecommunication Facilities," adopted in November 1996, was incorporated as part of the "Revised General Plan". In late 2001, the Board authorized a Countywide Telecommunications/Monopole Study to focus on the development of a master plan for wireless facilities.
In April 2002, the Atlantic Technology Consultants/The Atlantic Group presented to the Board the results of their study, entitled "Strategic Plan for Wireless Telecommunication Facilities." The Board then formed a Joint Committee, consisting of three Planning Commissioners, the Chairman of the Fire and Rescue Commission, and three knowledgeable private citizens.
The Board unfortunately subsequently took no action regarding the many excellent recommendations contained in the two resultant reports. In addition, the "Revised General Plan" is currently in limbo due to the Court ruling. The only meaningful extant document relating to cell towers is Section 5-618 of the Loudoun County Ordinance "Telecommunication Use and/or Structures."
Some key wording in that ordinance is:
- Antennas are permitted on structures 40 feet or greater in height and on fire and rescue structures, regardless of height.
- Proposed "monopoles" shall be compatible with development in the vicinity and located in the interior of the property.
- New telecommunications "monopoles" shall be designed to accommodate at least 3 providers unless:
Doing so would create an unnecessary visual impact on the surrounding area, or
No additional need is anticipated for any other potential user in the vicinity, or
There is some valid economic, technological, or physical justification as to why co-location is not possible. - No "monopole" shall be located within a County designated historic district.
- Applicants proposing a new "monopole" within one mile of a County designated historic district or a Virginia Byway shall submit a minimum of 3 visual simulations and written justification as to why the monopole could not be sited elsewhere.
- "Monopoles" shall not be located along ridge lines, but on downslopes from the top of ridge lines, to protect views of the Blue Ridge Mountains.
- Applicants shall submit documentation, in written and graphic form, regarding the service area to be provided by the proposed "monopole".
First, while we understand the original premise that a single, taller antenna structure accommodating three cell companies may be preferable to three single user shorter towers, we believe that this logic is basically faulty, particularly in rural areas. Individual cell companies have unique coverage requirements, driven in large part by the location of their existing towers and resultant network shortfalls. STA is therefore opposed to any cell tower application designed for three users unless the applicant has a prior written agreement with the other two companies.
Second, for those cell tower applications proposed to be located within one mile of a Virginia Scenic Byway, the requirement to justify why alternate locations cannot be used has been inadequately enforced to date. In the future, whenever the County Planning Staff waives this requirement, STA will, prior to the Planning Commission Public Hearing, provide them with one or more alternate locations for consideration, if possible.
Third, the County currently has inadequate means to verify an applicant’s "service area" justification. STA should work with the County to encourage them to contract, on a case by case basis, with a qualified technical analysis company, to corroborate the hearability coverage justification for each proposed site as part of the applicant’s current, proposed, and future network.
Fourth, with regard to antenna heights, STA believes that seventy feet is an adequate height for most locations to assure coverage 95 percent of the time. STA is strongly opposed to any tower over 100 feet tall. Fifth, STA is opposed to any proposed pseudo-silo over 70 feet in height. Existing silo use is strongly supported, but existing silos in Western Loudoun County do not exceed 70 feet. Flag pole-type antennas are acceptable if other criteria are met. STA is opposed to clock tower-type antennas. Pseudo-tree antennas must be compatible with surrounding tree types.
Sixth, in order to affect County decisions regarding cell tower applications, persuasive oral and written arguments in support of STA positions are needed. STA should work with its members and other concerned citizens and organizations during the application process.
Those supporting STA positions should be encouraged not only to attend, but to speak, at the relevant Planning Commission and Board of Supervisor Public Hearings. Consideration should be given to working directly with the applicant with a view toward reaching a compromise conclusion.
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