Preserve Orlando's Neighborhoods

On January 29, 2024, the City of Orlando received an application for the placement of a communications tower at N28.444932, W81.210124. On February 27, 2024, the conditional use permit application was made available to residents. Due to questions from the city, the applicant provided additional information to the city in a resubmittal dated March 8, 2024.

To our knowledge the application provided to the city on 01/29/24 consisted of 6 documents excluding a cover sheet or request for waiver of city ordinances and policies. An additional document was provided on 03/29/24.

The following are our comments on these documents:

In General

The applicant fails to address or adequately address the following in their application:

Alternate site availability and assessment (we note there are several current and future sites that are/will be available for assessment)
Property value impacts
Tax collection impacts
Relevant city ordinances and growth management policies
Research indicating impacts on nature and pets
Park/open space Impacts
24/7 maintenance requirements and associated inconveniences and interruptions to residents

The applicant fails to present the following in their application:

Documented community discourse with current service levels
Documented community supporters for the proposed tower
Required waiver requests

The applicant fails to meet the requirements of requested waivers:

The applicant's camouflaging techniques are inadequate for a 150-foot structure with external antennae being proposed in a residential community with structures or natural elements of significantly less height.
The applicant failed to meet the co-location requirements of a waiver.
The proposed location will NOT minimize the visual impact of the proposed communication tower because the bulk, height, use, or appearance of the adjacent structures and surrounding area will not screen the tower from view or provide a location where the proposed communication [tower] will be visually unobtrusive and unobjectionable.

Applicant Document - Engineering Necessity Case

Page 1, the stated objective for the installation of a cell tower at the proposed site is to "improve service quality in the residential and commercial properties of the new community of Sunbridge." We note that the Sunbridge community is over 7 miles from the proposed site and the objective is unlikely to be met with the installation of the proposed cell tower. Further, the Starwood property does not currently contain commercial properties and once the commercial site is developed it will be a lower impact location for a 15-story cell tower with external antenna.
Page 1, the applicant states, "our engineering data shows that the existing cell sites that serve this area are experiencing 4G data overload". We note that no engineering data was presented and therefore this claim could not be verified. Further, many new phones operate on 5G and therefore we are unsure how this statement applies to the future.
Page 1, the applicant states, "there are no current collocation options that will fulfill this need, as this is a new greenfield community." We note the need is not defined and the primary objective is for a location over 7 miles away. Per FCC and Verizon coverage maps, and applicant studies the site currently has at least minimally required coverage. Many alternate sites that could host a collocation tower exist only a few thousand feet from the proposed site. These sites including the landfill, county pump operations, utility, and future commercial sites were not explored.
Page 1, the applicant states, "The tower we are proposing is a stealth tree...". We note that the proposed stealth tree in no way matches or blends in with the proposed site or neighborhood. It is 15-stories high in a community with structures no taller than 3-stories and it will have several rows of multiple antennae exposed and within view of the public eye. Upon review of like-kind towers located on commercial properties in the Orlando area members of Meridian Parks agree the stealth tactics are insufficient and tower artifacts remain obvious. We further note that "better coverage" can be obtained from alternate sites in the area that have less impact on the local community.
Page 2-4, general information and not specific to the proposed tower.
Page 5, the applicant states, "... it takes an average of 2-3 years to complete a WCF." We note, no data was provided to substantiate this claim and an internet search suggests timetables are under what is presented.
Page 5, the applicant states, "A good capacity WCF needs to be in the center of a user population...with each slice (sector) having 33% of the WCF resources. If one sector is under-utilized, it's resources can not necessarily be diverted to another sector." We note that towers are readily installed outside of the center of populations having one or more sectors under-utilized. On a 30 minute car ride we found these examples:
- N28.450567271487635, W81.14414938232021
- N28.45334662589317, W80.96840726279449
- N28.45530890530602, W80.96968432901626
- N28.478882516696622, W80.83629372797407
Page 6, the applicant states, "each year Verizon sees large increases in how much data its customers need..." We note that the Starwood property has the minimum required coverage as envisioned by the Telecommunications act of 1996 and prohibiting a tower at this site will not prohibit cellular service to users. Furthermore, the applicant generalizes some examples for capacity need growth, but doesn't provide specific capacity usage to clarify if the the magnitude of the increase is an impact to current infrastructure. Usage in these examples may occur only sporadically and at times when the load from other users is low. Finally, enhanced capacity for the designated property could be fulfilled by a tower or towers at alternate sites where those sites principally achieve desired service objectives while reducing impacts on the community. The applicant failed to explore alternative sites or present associated alternative case coverage improvements.
Page 7, regarding radio emission safety we note that the WHO website presented states the following regarding to EMF exposure, "A number of epidemiological studies suggest small increases in risk of childhood leukemia", "some [...] health problems may be caused [...] by anxiety related to the presence of new technologies", and "Large-scale studies are currently underway in several countries and may help resolve [gaps in research related to EMF and cancer]." This clearly indicates the tower will negatively affect the health of residents and more information is needed to assess the effects of transmission towers on humans. We note that the applicant omits to discuss physical safety (cell tower and base station fires, collapse, etc.) and defer to the data we present on the health and safety aspects of towers in whole.
Page 8, general information with estimates.
Page 9, the applicant presents a coverage map for the area surrounding the proposed site.
- The current coverage map shows the proposed site and existing properties with maximum coverage while areas of the county landfill to the north and areas to the Southeast of the Starwood property (East of the county pump operations site) have minimally expected coverage. Current coverage maps support better locations for cell tower siting at the county landfill and the pump operations or utility sites.
- The current coverage map indicates that maximum coverage is achieved for 1-2 miles from any given cell tower reinforcing that cell tower spacing may be roughly every 2-4 miles (each tower providing a radius of coverage for half that distance).
- The current coverage map also shows that the future commercial complex planned for the Starwood property lies relatively in the middle of the space between the proposed site and the "Cape Lane" towers that currently receives predominantly "in-vehicle coverage". This site is likely ideal for improving coverage for the Starwood property in the long term.
Page 10, the applicant fails to provide coverage maps for any potential alternate sites.
Page 11, the applicant states, "Verizon is part of your community...". However, the applicant failed to respond to organized questions and comments from the community and failed to respond to emails and phone calls from community leaders.

Applicant Document - March 8, 2024 Boggy-Meridian-Resubmittal

Page 1, the applicant states "The original submittal included a “Zoning Support Letter” from Mattamy Homes, an affiliate of Beachline South Residential and master developer of Meridian Parks, stating they “fully support Anthemnet’s development application to site a 150’ monopine-type telecommunications tower within the Meridian Parks community.”" We would like to note that as landowners and adjacent property owners to the proposed site we are fully opposed to the use of the proposed site and land for a cell phone tower.
Page 1, the applicant states "the proposed Tower is now approximately 220% (330 feet) away from the nearest proposed residential platted lots – six in total. As such, Anthemnet is revising its application to include a Waiver Request from the minimum separation distances to off-site uses set forth in LDC Section 58.844(a)". We would like to note that as current property owners in the community we stand opposed to any waiver being approved to permit a cell phone tower to be constructed at the proposed site. Waiver approval and construction of the cell phone tower will be detrimental to the local community.
Page 2, the applicant states "(2) through the Conditional Use Permit process, in accordance with the procedure set forth in Chapter 65, Part 2D of this Code, when the proposed communication tower is a Conditional Use. Anthemnet is requesting a Waiver pursuant to this subsection (2)." We would like to note that as current property owners in the community we stand opposed to any waiver being approved to permit a cell phone tower to be constructed at the proposed site. Waiver approval and construction of the cell phone tower will be detrimental to the local community.
Page 2, the applicant states "(1) Camouflaging techniques approved by the City are incorporated into the design of the communication tower. Anthemnet is proposing a camouflage technique with a monopine-type design." We would like to note that as presented on the aesthetics page of PreseveOrlando.com the tower will remain fully visible as an obtrusive structure and external antenna will be visible from all areas of the community. The proposed tower will remain an obvious eyesore to all residences in the community. It is simply not reasonable to conclude that a 150-foot industrial tower can be adequately camouflaged in a community that does not contain structures or natural vegetation anywhere near that height. This is why towers of this type should be placed on commercial sites or other non-residential property more suitable to industrial structures.
Page 2, the applicant states "(2) Two (2) or more communication service providers agree to co-locate communication antennas on the same tower. Verizon Wireless is currently committed to co-locating at the 145’ centerline level; see previously submitted Verizon Wireless Zoning Affidavit. Anthemnet has not yet received any additional co-location requests as of the date of this letter; however, the Tower is designed to accommodate three additional service providers." We note that having the capability to add another provider to the tower is not the same as having agreement to co-locate. This requirement for a waiver is not met!
Page 2, the applicant states "(4) The proposed location will minimize the visual impact of the proposed communication tower because the bulk, height, use, or appearance of the adjacent structures and surrounding area will either screen the tower from view or provide a location where the proposed communication [tower] will be visually unobtrusive and unobjectionable. Please see Site Plans, Sheet C1, and the previously submitted Photo Simulation Package. The proposed monopine Tower has been sited in a location that is surrounded by – but does not negatively affect – heavily treed conservation lands. The location on the parent parcel allows for natural buffering of trees and other vegetation to mitigate the view from surrounding properties. Additionally, the perimeter of the Tower will be landscaped in accordance with Section 58.844.(g)." We would like to note that as presented on the aesthetics page of PreseveOrlando.com the tower will remain fully visible as an obtrusive structure and external antenna will be visible from all areas of the community. The vast majority of the 150-foot tower will preside well above the natural tree line. The mentioned heavily treed conservation land, where the trees are rooted below grade in wetland and rise an estimated 40-60 feet, will only block a small fraction of the towers view from adjacent resident yards, patios, balconies, and window views. The proposed tower will remain an obvious eyesore to all residences in the community like the aesthetics of existing monopine towers located on commercial spaces near Good Homes Road and the 408 and near S John Young Parkway and Commodity Circle.

Applicant Document - Anthemnet Community Meeting Minutes

As noted on page 10 of this document (Resident Carlos's first statement), the meeting referenced in this document was held on December 14, 2023 with only 4 days notice to residents. The community was not afforded time to perform due diligence on the topic or to coordinate personal needs to attend at the meeting. Many residents were unprepared and unable to attend. As a result, the community submitted a letter to Anthemnet on January 7, 2024 capturing our concerns and questions at that time and after a few weeks digesting potential community impacts. Anthemnet did not respond. After acknowledging receipt of our document, Anthemnet did not response to further communication attempts. We note that the document includes a summary and not actual discussions held.

Applicant Document - Photographic Simulation

We note that simulations include foreground objects that handicap the visual perspective of the tower. Images should provide a clear view of the tower and fairly demonstrate its Aesthetic impact on the community.
We could not locate any assumptions for the trigonometric assessment presented on page 10, which we presume was used to determine simulation perspectives including estimates for the height of the tower in simulations. It appears the treeline height was used to estimate the towers height and therefore it is a critical element that should be presented and validated. We believe the tower heights depicted in the simulations on pages 7 and 9 are shown significantly shorter than they would be if constructed. We have not assessed the other perspectives for relative trigonometric accuracy.
We note that the treeline identified on page 10 sits below grade whereas the tower will sit on grade. It is unknown if this fact was considered in the presented simulations.
We note that the simulations do not show any exposed "trunk" on the tower as visible from any perspective. However, similar towers installed in commercial locations of the Orlando area all have significant trunk exposed.
We could not locate the multiple arrays and levels of exterior antennae that are proposed on the tower (see the site plan document). We believe these elements should be illustrated by the applicant to provide fair simulations of the tower.
Regardless of the above comments it is obvious the tower and its equipment will sit well above the tree line and be visible from all areas of the community, including yard space, balconies, first/second floor windows, roadways, walkways, trails, etc. The applicant's simulations show the tower is clearly visible at close (230') and far proximity (1040'). Even with the planned camouflage techniques the tower and antennae equipment will be seen very obviously as what it is and will be an impacting eyesore for the community.

Applicant Document - Certification of Location and Elevation

We note the GPS coordinates of the tower as slightly different than those provided to us by the applicant.

Applicant Document - Site Plan

Page 6 was the only page reviewed by us in this document. We fully anticipate the city process will address the other elements presented in the site plan.
We note the significant exterior and visually exposed antenna on the proposed tower. We also note the significant height and girth of the tower relative to other structure and natural elements of the community.

Applicant Document - Towair Determination Results

We did not review this document.