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04 28 2026 Planning Commission Packet.pdf CITY OF MENDOTA HEIGHTS PLANNING COMMISSION REGULAR MEETING AGENDA April 28, 2026 at 7:00 PM Mendota Heights City Hall, 1101 Victoria Curve, Mendota Heights 1. Call to Order 2. Roll Call 3. Approval of Minutes a. Approve meeting minutes from the March 31, 2026 Planning Commission Meeting. 4. New and Unfinished Business a. Tabled - CASE No. 2026-02 Variance Application of Clarence Tweh for a Variance to the front yard setback to accommodate the installation of an accessibility ramp at 537 Junction Lane 5. Public Hearings a. CASE No. 2026-06 Lot Line Adjustment Application of Paul Linnell for a Lot Line Adjustment of the properties located at 1603 Dodd Road and 688 Wentworth Avenue b. CASE No. 2026-07 Conditional Use Permit Application of Homes by Tradition for a Conditional Use Permit to allow an attached garage size of 1,499 square feet on the property located at 1961 Glenhill Road c. Tabled - CASE No. 2026-05 Conditional Use Permit Application of Buell Consulting, Inc. on behalf of The Towers LLC, requesting a Conditional Use Permit (CUP) for a new freestanding wireless monopole tower at 739 Wentworth Avenue (Wentworth Park) 6. Updates/Staff Comments 7. Adjourn Auxiliary aids for persons with disabilities are available upon request at least 120 hours in advance. If a notice of less than 120 hours is received, the City of Mendota Heights will make every attempt to provide the aid. However, this may not be possible on short notice. Please contact City Hall at 651.452.1850 with requests. Page 1 of 473 March 31, 2026 Mendota Heights Planning Commission Meeting Page 1 of 16 CITY OF MENDOTA HEIGHTS DAKOTA COUNTY, MINNESOTA DRAFT PLANNING COMMISSION MINUTES MARCH 31, 2026 The regular meeting of the Mendota Heights Planning Commission was held on Tuesday, March 31, 2026, in the Council Chambers at City Hall, 1101 Victoria Curve, at 7:00 P.M. The following Commissioners were present: Commissioners Patrick Corbett, Cindy Johnson, Brian Udell, Jeff Nath, and Steve Goldade. Those absent: Chair Litton Field and Commissioner Brian Stone. Approval of Agenda The agenda was approved as submitted. Election of Planning Commission Chair and Vice Chair for Year 2026 Commissioner Corbett opened the floor for nominations for the positions of Chair and/or Vice Chair. Commissioner Goldade asked if there should be elections with both the Chair and Vice Chair absent. Community Development Manager Sarah Madden commented that typically elections are held at the February meeting, but that was a workshop meeting, so the elections were placed on this agenda. She stated that it would be nice to have the elections so that a Chair or Vice Chair could preside over the meeting tonight. Commissioner Goldade asked if they could postpone the elections to the next meeting. Community Development Manager Sarah Madden confirmed that could be done. COMMISSIONER GOLDADE MOVED, SECONDED BY COMMISSIONER JOHNSON, TO POSTPONE THE ELECTION OF OFFICERS TO THE APRIL MEETING. Further discussion: Commissioner Udell asked if any of the Commissioners present would be absent at the next meeting, to avoid this situation repeating. Commissioner Corbett commented that he would not be present at the next meeting. Commissioner Udell stated that it is also unknown if those absent tonight will be present at the next meeting. Commissioner Corbett stated that if they are going to delay, he would prefer to delay until May so that he could be present as well. Page 2 of 473 3.a March 31, 2026 Mendota Heights Planning Commission Meeting Page 2 of 16 Commissioner Goldade stated that he would be okay with changing his motion to postpone the elections to May. Community Development Manager Sarah Madden commented that the only rule in City Code is to have the administrative meeting in February, and that has already passed. She confirmed that the Commission has postponed this decision in the past. Commissioner Goldade accepted a friendly amendment to change his motion to postpone the election to the May 26, 2026, meeting. Commissioner Johnson agreed. AYES: 5 NAYS: 0 Approval of Minutes COMMISSIONER GOLDADE MOVED, SECONDED BY COMMISSIONER UDELL, TO APPROVE THE MINUTES OF JANUARY 27, 2026. AYES: 5 NAYS: 0 COMMISSIONER UDELL MOVED, SECONDED BY COMMISSIONER NATH, TO APPROVE THE WORK SESSION MINUTES OF FEBRUARY 24, 2026. AYES: 5 NAYS: 0 Hearings A) PLANNING CASE 2026-02 CLARENCE TWEH, 537 JUNCTION LANE – VARIANCE Community Development Manager Sarah Madden explained that the applicant, Clarence Tweh, is requesting approval of a variance to the front yard setback for the installation of an accessibility ramp for the property at 537 Junction Lane. The City Code permits small structures such as accessibility ramps to encroach five feet into the front yard setback without the need for a variance; however, the proposed location of this ramp would encroach more than five feet into the front yard and, as such, requires a variance from the City. Hearing notices were published and mailed to all properties within 350 feet of the site; three comments were received. Community Development Manager Sarah Madden provided a planning staff report and a presentation on this planning item to the Commission (which is available for viewing through the City’s website). Page 3 of 473 March 31, 2026 Mendota Heights Planning Commission Meeting Page 3 of 16 Staff recommended approval of this application based on the findings and with conditions. Commissioner Nath asked if there would be any other way to accommodate the slope without going all the way around. Community Development Manager Saah Madden replied that, based on the contractor's information, an 18-foot width between the stoop and driveway, and the rise would not allow an accessibility ramp without a turnback. She stated that with the landing size and slope required, some sort of turnback would be required. Commissioner Johnson noted information received in a letter related to the dimensions and whether they were accurate. She asked if staff had double-checked the dimensions. Community Development Manager Sarah Madden commented that staff were onsite with the contractor and have no reason to doubt the dimensions. Commissioner Corbett opened the public hearing. Jacob Burke, 533 Junction Lane, commented that he has a good relationship with his neighbor and does not intend to deny access to anyone in the neighborhood, but is opposed to the application as presented. He believed that this alters the character of the neighborhood and noted that he is the resident who questioned the measurements of the contractor. He stated that this variance is also silent on the materials that would be used. He stated that the ramp could better match the character of the neighborhood with other materials. He commented that although he has a great relationship with the property owner, this property is not homesteaded and is used as a group home. He believed that these businesses operating in a residential neighborhood should be required to maintain the character of the neighborhood. Seeing no one further coming forward wishing to speak, Commissioner Corbett asked for a motion to close the public hearing. COMMISSIONER NATH MOVED, SECONDED BY COMMISSIONER UDELL, TO CLOSE THE PUBLIC HEARING. AYES: 5 NAYS: 0 Commissioner Nath asked if this could be approved, with the contingent that the City would double-check the measurements. Community Development Manager Sarah Madden replied that there would be an inspection with a formal building permit. She stated that they are still discussing whether a building permit or an administrative permit would be required and noted that an administrative permit would not require an inspection. Page 4 of 473 March 31, 2026 Mendota Heights Planning Commission Meeting Page 4 of 16 Commissioner Johnson asked and received confirmation that a condition could be added requiring an inspection. Commissioner Corbett asked if the applicant would be required to meet the plan dimensions. Commissioner Udell stated that condition two would require no deviations from the ramp plan. Commissioner Nath asked who would watch to ensure that the applicant follows the requirements. Community Development Manager Sarah Madden stated that a condition could be added requiring an additional staff inspection if one is not required by the Building Code. Commissioner Johnson asked if any rules apply to a group home running as a business in a residential area that would differ from a R-1 standard home. Community Development Manager Sarah Madden replied that a group home is a permitted single- family use within State Statute, so there would not be additional code requirements for structures. She stated that there are no material requirements for an accessibility ramp in the City Code. She stated that the Commission could request different building materials, but that is not something she has discussed with the applicant, and she would need to verify their ability to accommodate that. Commissioner Goldade asked if there would be a way to get a second opinion on the building of the ramp. Community Development Manager Sarah Madden stated that if more information is needed, the application could be tabled and staff could be directed to obtain that information. Commissioner Goldade noted the requirement for the current ramp to be removed within 90 days and asked how tabling would impact that timeline. He stated that he believes that a ramp should be allowed, but would like more information on materials and verification of dimensions. Community Development Manager Sarah Madden replied that the 90 days would start once the variance is approved. Commissioner Johnson stated that she would guess that the objection is related to the silver railings and asked if staff could request a different material. Community Development Manager Sarah Madden confirmed that staff could have those conversations with the applicant. Commissioner Udell recognized that the measurements provided were called into question and asked if the idea would be that if those measurements were inaccurate, the encroachment could be reduced. Page 5 of 473 March 31, 2026 Mendota Heights Planning Commission Meeting Page 5 of 16 Community Development Manager Sarah Madden stated that if the item were tabled, staff could be directed to work with the applicant and bring back additional information on materials, and staff could verify the dimensions. COMMISSIONER GOLDADE MOVED, SECONDED BY COMMISSIONER NATH, TO TABLE THE CASE AND DIRECT STAFF AND THE APPLICANT TO VERIFY THE DIMENSIONS AND PROVIDE MORE INFORMATION ON THE MATERIALS PROPOSED FOR THE RAMP. Further discussion: Commissioner Udell stated that he would push back on the materials piece as he worries that would stray too far from the purview of the Commission. He agreed that the dimensions should be verified, but disagreed with the materials piece. Commissioner Nath stated that they were mostly asking staff to get more information on the materials from the applicant. Commissioner Udell agreed that is fair. Commissioner Johnson stated that the contention would be that the materials would not meet the criteria of the variance relating to altering the character of the neighborhood. Commissioner Corbett agreed that they should be discussing the materials and hoped that would be built into the design. He stated that a chain link fence is allowed, and that color is not dictated. He appreciated the concern for the dimensions but believed that they could move this forward with appropriate conditions. AYES: 4 NAYS: 1 (Corbett) B) PLANNING CASE 2026-04 M&M HOME CONTRACTORS, 655 CALLAHAN PLACE – CONDITIONAL USE PERMIT Community Development Manager Sarah Madden explained that M&M Home Contractors is the applicant and owner’s representative of the property located at 655 Callahan Place and has requested a Conditional Use Permit (CUP) to allow for a residential building height of 20 feet for the construction of a new single-family home located at 655 Callahan Place. Hearing notices were published and mailed to all properties within 350 feet of the site; no comments or objections to this request were received. Community Development Manager Sarah Madden provided a planning staff report and a presentation on this planning item to the Commission (which is available for viewing through the City’s website). Staff recommended approval of this application based on the findings and with conditions. Page 6 of 473 March 31, 2026 Mendota Heights Planning Commission Meeting Page 6 of 16 Commissioner Johnson asked about the roof height of the two neighboring properties. Community Development Manager Sarah Madden provided information on the estimates that were used to determine the average of less than 15 feet. Commissioner Corbett opened the public hearing. Brian Ross, 653 Callahan Place, stated that he lives to the east of this property and expressed concerns with the height of the building proposed. He commented that this home is being setback further on the property, and he expressed concerns with the shadowing that could occur on his property. He asked that the build revise their plan to a lesser building height. Rosemary Husbands, 659 Callahan Place, stated that she lives to the west of the subject property and asked that the builder consider the trees along the property line. She wanted to ensure that the root systems were not damaged during construction. She commented on the drainage patterns from the previous home and expressed concerns that there would be more runoff from a larger roof. She asked that the runoff from this property not go onto her property. She asked that there be consideration for low wattage lighting to ensure that a building of this size remain understanded rather than overstated. She did not want to see bright spotlights or lighting that could impose itself on wildlife or the native habitat. Mike Fritz, M&M Homes, stated that their goal is to work with the neighbors to ensure there are no issues and/or address any existing issues. He stated that they are pulled all the way to the front setback, and 93.4 feet remains from the home to the back of the lot. He stated that the proposed home would be a 4,200 square foot rambler and provided information on the roof pitches. He stated that this application is for a CUP for the building height and noted that he would be willing to speak with the neighbor to address her concerns with the trees and runoff. He stated that they tried to manage the front and back setbacks as best they could. Commissioner Johnson asked if the front setback is in alignment with the other two homes. Mr. Fritz replied that the front setback is 50.5. Public Works Director Ryan Ruzek explained that the garage extends in front of the home, and the front of the garage is evenly aligned with the homes on either side. Commissioner Johnson asked for clarification on the proposed building height. Mr. Fritz replied that the tallest midpoint is 17.6. He recognized that both neighboring homes are around 13 feet, which is under the Code maximum. Seeing no one further coming forward wishing to speak, Commissioner Corbett asked for a motion to close the public hearing. Page 7 of 473 March 31, 2026 Mendota Heights Planning Commission Meeting Page 7 of 16 COMMISSIONER NATH MOVED, SECONDED BY COMMISSIONER UDELL, TO CLOSE THE PUBLIC HEARING. AYES: 5 NAYS: 0 Commissioner Nath noted that the request is related to the peak in the middle of the home, which should alleviate the issue of shade mentioned by the neighbor. He supported the request. Commissioner Johnson stated that while she does have concerns for the neighbors, she was happy to hear that the builder was willing to work with them. She noted that this request falls within the requirements of the City Code. COMMISSIONER UDELL MOVED, SECONDED BY COMMISSIONER GOLDADE, TO RECOMMEND APPROVAL OF THE REQUESTED CONDITIONAL USE PERMIT BY M&M HOME CONTRACTORS FOR THE PROPERTY AT 655 CALLAHAN PLACE WITH THE FOLLOWING CONDITIONS: 1. A BUILDING PERMIT MUST BE APPROVED AND ISSUED BY THE CITY PRIOR TO THE COMMENCEMENT OF ANY WORK. ALL APPLICABLE ZONING AND BUILDING REQUIREMENTS SHALL BE MET PRIOR TO ISSUANCE OF A BUILDING PERMIT. 2. THE BUILDING HEIGHT SHALL NOT EXCEED 20 FEET, AS MEASURED PER THE DEFINITION OF BUILDING HEIGHT IN CITY CODE. 3. THE BUILDING SHALL BE CONSTRUCTED IN SUBSTANTIAL CONFORMANCE WITH THE PLANS SUBMITTED AND DATED JANUARY 29, 2026. AYES: 5 NAYS: 0 Community Development Manager Sarah Madden advised the City Council would consider this application at its April 7, 2026, meeting. C) PLANNING CASE 2026-05 BUELL CONSULTING, INC. ON BEHALF OF THE TOWERS LLC, 739 WENTWORTH AVENUE (WENTWORTH PARK) – CONDITIONAL USE PERMIT Community Development Manager Sarah Madden explained that Buell Consulting, on behalf of The Towers LLC, requests approval of a Conditional Use Permit (CUP) to allow a 149-foot wireless telecommunications monopole tower. The Towers LLC is a partner of Verizon Wireless. The subject property, located at 739 Wentworth Avenue, is owned by the City and utilized as Wentworth Park. Hearing notices were published and mailed to all properties within 1,250 feet of the site; several inquiries have been made, and 29 public comments have been received. Page 8 of 473 March 31, 2026 Mendota Heights Planning Commission Meeting Page 8 of 16 Community Development Manager Sarah Madden provided a planning staff report and a presentation on this planning item to the Commission (which is available for viewing through the City’s website). Staff recommended approval of this application based on the findings and with conditions. She stated that the applicant, in response to the comments received, has requested that the application be tabled until the April meeting, as that would allow the applicant to provide written responses to the comments received. She stated that the public hearing should still be opened tonight, and the item should be tabled with the public hearing remaining open. Commissioner Johnson asked if there was a map identifying freestanding antennas, as well as future planned antennas, within a two-mile radius of the proposed site, as required by City Code. Community Development Manager Sarah Madden replied that information was provided within the packet on the coverage map. Commissioner Johnson stated that the narrative mentioned that this would help with coverage in Ramsey County and asked for more information, as she did not notice that change on the map. Community Development Manager Sarah Madden stated that, from the information provided to staff, the proposed service level would impact the area surrounding the park. She stated that she was unsure if this tower would impact service in Ramsey County. She stated that the service area would improve in this area, noting that staff have received complaints about the current service levels in this area. Commissioner Johnson asked how wide the area is that would improve, as she did not believe that the area of improvement was very large for such a large tower. Community Development Manager Sarah Madden replied that she did not have the dimension for the radius, but noted that the height tends to provide coverage to a larger area. Commissioner Udell recognized that there are many residents present tonight. He understood that the public hearing would remain open and asked if someone speaking tonight would prevent them from speaking at the April meeting. Community Development Manager Sarah Madden replied that if someone speaks today and wants to speak at the next meeting, they could speak if they wanted to say something new, but the intention is that they would not be repeating the same comments. Commissioner Goldade asked if the Commission had considered a telecommunications tower in the past, or whether this is unique in that it would be located in a park. Community Development Manager Sarah Madden replied that there was a similar application in 2006 in a park, which was withdrawn. She stated that there have been some building-mounted towers in the past six years. Page 9 of 473 March 31, 2026 Mendota Heights Planning Commission Meeting Page 9 of 16 Commissioner Johnson stated that the City Code identifies preferred land uses and alternate land uses. She stated that when the Code language was amended, it may have created confusion. She noted that public spaces and parks were to be considered as alternate land uses, not preferred. She asked if the applicant had shown reasonable satisfaction that the applicant could not find a preferred location. Community Development Manager Sarah Madden referenced a memorandum from the applicant describing that sites nearby were not adequate to address the coverage gap. Commissioner Johnson noted that there is a school nearby, and perhaps the tower could be located on the school. Public Works Director Ryan Ruzek stated that the nearby buildings are limited to a 15-foot height, which would not provide the needed coverage. Commissioner Johnson asked that the applicant identify which locations on the map are current towers and which are proposed for the future. Commissioner Corbett opened the public hearing. Sarah Buell spoke in representation of the applicant and asked that this item be tabled until the next meeting. She thanked the public for their feedback, which will help ensure accountability, strengthen the planning process, and provide a higher level of diligence. She stated that they are requesting additional time to process and respond to the feedback and make any necessary changes to their plan. Joan Brandes, 1465 Cherry Hill Road, stated that she has had a cell phone for the last 30 years with service. She commented that sometimes service is not perfect. She stated that she travels a lot in the southern suburbs, and they are lucky to have hills, valleys, and trees. She recognized that there are many places where conversations will drop, and service has continued to get better over the years. She suspected that the service would continue to improve, noting that there is no 5G service near this area. She believed there should have been a longer notification period for residents. She commented on recent activity in the park and stated that it would be a shame that the area where children were playing would be taken up by this equipment. She stated that this is the last clean place in the park and believed that there are other amenities that would better benefit the community. She commented on another tower that is an eyesore, along with the construction equipment that she also believes to be an eyesore. She asked how the rent for the tower was figured out and believed that the lease better served Verizon than the City. She did not believe that $15,000 a year would be enough. She referenced comments recently made by the Mayor, who stated that it is the obligation of the City to ensure proper infrastructure and cell phone service, and that the $15,000 could be used in the park. She did not agree with the comments of the Mayor. She stated that there has been no information on the alternatives, noting that a ten-mile radius would service many other areas outside Mendota Heights. Amelia Vandarious, 1312 Wachtler Avenue, stated that their coverage is delightful and asked if a survey could be completed to determine if there are people without service and whether there are Page 10 of 473 March 31, 2026 Mendota Heights Planning Commission Meeting Page 10 of 16 alternatives that could be considered for those with poor service. She stated that if there is a need for the improved service, perhaps a study could be done to ensure the benefit would outweigh the cost. Jack Evans, 796 Lower Colonial Drive, stated that he supports the request to table this as he agreed that more information is needed on this application. He commented that much more information is needed, including the alternatives. He stated that when the City Council requested the coverage maps in August, the consultant objected, stating that it was proprietary information and asked how modeling could then be done without that information. He stated that the park is the last option to be considered. He commented that there is no information on the impact of the tower, and there are vague renderings within the application. He referenced the before and after views and wanted to better understand what that impact would be for homeowners. He stated that the residents were notified less than one week ago. He asked that the notification for the next meeting be provided earlier to ensure that residents have enough time to respond. He recognized that the prior notice would stand if this were tabled, but asked that another notification be provided prior to the next meeting. Benjamin Paterson, Evergreen Knolls, stated that Mendota Heights prides itself on being the best- kept secret with a small-town feel, and this tower would go against that vision. He stated that studies have shown that a view of a cellular tower can decrease property values by 9.78 percent. He stated that the park is a place for gathering and believed that the tower could be damaging to the feel of the park. He asked if other alternatives had been explored and encouraged the community to continue to pursue alternatives. He asked for an accurate representation of the tower, noting differences in the application information and the pictures shown by the City. He provided additional information on the ownership of Vertical Bridge and asked how Middle Eastern backers based in Tokyo would encourage local businesses to thrive. He provided information on health impacts from 5G towers. He also questioned the timing of the notification, as many people were away on spring break when the notification was received. Ken Noack, 677 4th Avenue, stated that he lives in the cellular dead zone and has experimented with three different carriers. He experienced dropped calls with all three carriers, but noted that he was able to obtain a booster through Verizon, which helped a bit. He stated that he has petitioned the Council to improve the cellular coverage. He stated that there was a storm that came through a few years ago that knocked out the power, which meant that his landline and booster did not work. He stated that the same night, a home was hit by lightning, but luckily, they still had power and could call for help. He stated that if that were to happen to him, he would not have been able to call for help. He stated that his sister was visiting and was trying to rebook her flight home, and it took three hours because of the poor coverage at his home. He recognized that now people often work from home and was unsure how they could do that without coverage. He stated that in this day and age, you would think they would have coverage and service. He understood that people do not want to look at a tower, but the towers are in every community, and it should not be a problem for Mendota Heights. He commented that when Cherryhill was developed, there was an ugly water tower that sat near the park and obstructed the views of others, but they understood that it was necessary infrastructure that was needed to help people in the community. He stated that this is also an important infrastructure that is needed in the city. Page 11 of 473 March 31, 2026 Mendota Heights Planning Commission Meeting Page 11 of 16 Kevin Byrnes, 740 Wentworth Avenue, stated that he submitted questions prior to the meeting. He asked for a quick summary of the entities involved in this, noting more than four entities. He stated that a lease was already negotiated and approved before the public hearing, which seems out of order. He was unsure if Verizon was pushing this or the tower company that convinced Verizon to sign on. George Eliou, 757 Upper Colonial Drive, stated that he is in a unique situation as he has lived in three homes in this area and has never had a problem with cellular phone coverage. He stated that he would like to see more information on the benefits of coverage and stated that perhaps unique things could be considered for the homes experiencing issues. He questioned what they would be gaining out of this in comparison with changing the character of Mendota Heights. Peter Gagnon, 751 Upper Colonial Drive, stated that fiber optics has been put through the neighborhoods, and all cell phones now have Wi-Fi calling. He stated that you do not need as much coverage for phone service as you do for the data side, and believed that this tower would be more for Verizon to provide more data services. He commented that Comcast and CenturyLink already provide internet service. He stated that the City should receive more coverage information and believed that there are other solutions available. He understood that there are dead zones, but believed there are solutions to address those situations. John Huber, 1359 Cherryhill Road, stated that he was the Mayor for eight years and served another eight years on the City Council in the past. He stated that from his experience over the last 65 years, there was a time when there were dead spots in coverage around the community. He stated that the coverage has improved in the community. He hoped that the Commission would look around at the people in attendance tonight, as the public input helps the discussion and guides the decisions made. He stated that he was not in favor of this in 2006 and is not in favor of it now because he did not see the need, although he respected the position of the resident who expressed coverage issues. He did not believe the City needed the $15,000. Sandy McGowan, 774 West Wentworth, stated that she has been trying to review the technical information over the past seven days and did not believe that was enough time to review the information. She stated that she goes through the park twice a day, and she loves the green space, which is the only green space left in the park. She stated that to the north of the pond, there is a little green area, but it is always saturated by the pond. She commented that a monopole is huge and intimidating and believed that it would destroy the ambiance of the park. She sympathized with those who are having service issues, but believed there are alternate areas where a tower could be located. Randy Pentel, 815 Deer Trail Court, provided a number of scientific medical reports related to the risks and dangers, which state that any tower should be at least 500 meters from any residences. He noted that his home is within that area. He noted the area where weak spots were identified on the coverage map, noting that his home is also within that area, and he has excellent in-home coverage. He noted a 4G amplifier near his home. He stated that Highway 35E is also lined with 5G towers. He stated that the $15,000 for the lease breaks down to $1,250 a month and did not believe that was worth the potential health risks. Page 12 of 473 March 31, 2026 Mendota Heights Planning Commission Meeting Page 12 of 16 Commissioner Corbett asked why the towers should not be within 500 meters of homes. Mr. Pentel replied that the reasoning is for health risks and offered to provide the reports to the Commission. He provided some specific information from the reports. David Williams, 755 Wentworth, stated that he is 34 feet from the setback and received this information during spring break. He stated that he could not fathom that a tower of this height could be placed 34 feet from a lot line. He stated that he has an eight-acre parcel and believed that if he submitted a request to place something of this height, 34 feet from the lot line, it would be rejected. He recognized that he does not currently have a structure near the lot line, but he could subdivide and build homes like his neighbor did. He asked that more work be done to determine the impact on property values and the health risks. He stated that this is being done under the premise that it is needed, when only a small portion of the population has service issues. He suggested that the tower instead be placed on the site owned by AT&T nearby, where there is currently a 50-foot tower. He commented that $15,000 is nothing, and the impact on property values will be more than that. He noted that only three to five percent of the population have gaps in coverage and believed that there should be true information should be provided on the actual coverage. He commented that there are antennas from multiple carriers throughout the community, and as a Verizon customer, he has never had issues with coverage. He did not believe that parkland should be given up based on the information provided. John Vaupel, 1299 Laura Street, stated that this could be a precedent-setting vote as they do not currently have towers in the parks. He stated that this is not just an issue for the Wentworth area but throughout the community, as this decision could open up the door for towers in other parks. Dean Simmons, 780 Upper Colonial Drive, stated that he was dismissed by the lack of notification and communication from the City on this issue. He stated that all taxpayers pay for parks in the community, and therefore, this is an issue that affects all residents of Mendota Heights. He believed that the next notification should be sent to all residents in Mendota Heights. Ms. Buell thanked the residents for their feedback tonight and welcomed any additional comments that may come. She noted a question related to the entities involved and explained that Verizon Wireless initiates any proposal like this where there is a clear need. She stated that Verizon initiated the action, but is not in the business of owning towers, and Vertical Bridge (which is also known as The Towers LLC) is in the business of build to suit towers. She stated that Verizon then leases space on the tower. She stated that Buell Consulting was hired by Verizon and Vertical Bridge to assist with zoning, site acquisition, and to assist with the development process. She stated that the lease would be between the property owner and the tower company, and Verizon or any other carrier would lease space from the tower company. She explained that they would not be proposing this if there were not a need, noting the cost for this type of project. COMMISSIONER NATH MOVED, SECONDED BY COMMISSIONER GOLDADE, TO TABLE THE APPLICATION TO THE APRIL 28, 2026 PLANNING COMMISSION MEETING. Page 13 of 473 March 31, 2026 Mendota Heights Planning Commission Meeting Page 13 of 16 Further discussion: Commissioner Corbett stated that he also has concerns with the park, but as a Verizon customer, he does not have coverage in his home. He stated that he would like to see more information on site selection, alternative selections, and why they were deemed non-usable, coverage data, the radius of coverage that would be provided, and the need for the tower. He stated that the mapping would go a long way to show the need. He stated that he personally knows there is a need, but that mapping could show others who do not have a need. Commissioner Johnson stated that she would also want to see the alternative locations within the preferred land use areas. She also wanted to see the current and future tower/antenna placement mapping. AYES: 5 NAYS: 0 Community Development Manager Sarah Madden commented that they will use the same radius of mailed notices for the next meeting. She noted that the radius of 1,250 feet exceeds the requirement of 350 feet. She stated that they would also post this in Friday News, but would not be sending a mailer to every address. She commented that there was also a sign-up sheet in the lobby, which allowed residents to sign up for emailed notices. She stated that agenda reports are released on the Friday before the meeting. Commissioner Corbett recognized the timing of agenda packets before meetings and noted that while it would be nicer to receive that information sooner, it is already a task for staff to have the information prepared by that deadline. The Planning Commission took a brief recess at 9:03 p.m. The meeting reconvened at 9:06 p.m. D) PLANNING CASE 2025-04 CITY OF MENDOTA HEIGHTS – ORDINANCE AMENDMENT Community Development Manager Sarah Madden explained that at the City Council’s goal and priority setting work session early in 2025, the Council identified Title 11: Subdivision Regulations as a priority for future evaluation and revision. Staff began the process of revising the ordinance to improve clarity, update terminology, and reflect the goals and strategic priorities of the City Council. Hearing notices were published in the City’s official newspaper; no comments or objections to this request were received. Community Development Manager Sarah Madden provided a planning staff report and a presentation on this planning item to the Commission (which is available for viewing through the City’s website). Page 14 of 473 March 31, 2026 Mendota Heights Planning Commission Meeting Page 14 of 16 Staff recommended approval of this application based on the findings and with conditions. She recognized that there are some formatting issues that will be corrected before the City Council meeting. Commissioner Goldade commented that the Commission reviewed this at the February worksession meeting. Commissioner Johnson noted page 12 of the February packet, Section 11-1-6, which mentions a forest and tree inventory and the suggested changes. She asked if that language was being moved somewhere else, as she was concerned that the language related to significant vegetation had just been removed. Community Development Manager Sarah Madden noted that on page 142 of the current packet, the forest and significant tree inventory is still listed as required submittal information for a lot split. She reviewed the language that was removed, noting that the only requirements for vegetation removal that exist are within wetland areas or within the MRCCA, noting that both of those areas have their own regulatory requirements. She noted that significant vegetation is also not defined, and if there is a desire to regulate that, it should be within landscaping and not within this section. She stated that the language has been restructured to address the actual requirements and regulations. She stated that significant vegetation is not defined and is not part of a lot split application. Commissioner Johnson was disappointed that was not defined outside of the MRCCA. Commissioner Corbett stated that it is also not mapped out and would be difficult to enforce. Commissioner Johnson referenced Section 11-1-11, violations and penalty, Item D, and asked if the Natural Resources Commission should also be listed. Community Development Manager Sarah Madden provided the page number of the current packet. She stated that the role of the Natural Resources Commission includes specific cases when a planning application would be considered by that group. She provided additional context on the involvement of the Parks and Recreation Commission, as mentioned. Commissioner Johnson referenced Section 11-3-1 related to design standards and asked if they should also include “policies such as the Surface Water Management Policy and NRMP Policy”. Community Development Manager Sarah Madden stated that if they wanted to add an additional item under that for other City plans, they could. She asked if the Surface Water Management Plan had been adopted under Code. Public Works Director Ryan Ruzek confirmed that is adopted under Chapter 14. Community Development Manager Sarah Madden noted that the NRMP is adopted under the Comprehensive Plan. She stated that she would hesitate to use the examples, as the City often Page 15 of 473 March 31, 2026 Mendota Heights Planning Commission Meeting Page 15 of 16 adopts new plans that would then be missing. She confirmed that broad language could be used to provide the desired clarity without calling out specific plans. Commissioner Johnson referenced Section 11-3-8, protected areas, and asked if they should also include primary conservation areas or native species. Community Development Manager Sarah Madden confirmed that could be added. Commissioner Johnson referenced Section 11-4-2 and asked if language related to native plantings requirements should be added or whether that would be found in landscape standards. Community Development Manager Sarah Madden replied that this is specifically for new street construction and provided additional clarification. Public Works Director Ryan Ruzek clarified that he believes that Commissioner Johnson would want to include ground cover in addition to sod. Community Development Manager Sarah Madden commented that this is when roads are built for the first time and not for reconstruction projects. Public Works Director Ryan Ruzek commented that ground cover could also include seed rather than sod. Community Development Manager Sarah Madden commented that they could say ground cover rather than sod. Commissioner Corbett asked for the definition of ground cover. Public Works Director Ryan Ruzek was unsure if that is defined, but stated that they could use the language “ground cover as defined under the Land Disturbance Guidance Document”. COMMISSIONER NATH MOVED, SECONDED BY COMMISSIONER UDELL, TO RECOMMEND APPROVAL OF THE PROPOSED AMENDMENTS TO CITY CODE TITLE 11 – SUBDIVISION REGULATIONS AS OUTLINED IN THE REDLINED ORDINANCE. AYES: 5 NAYS: 0 COMMISSIONER NATH MOVED, SECONDED BY COMMISSIONER UDELL, TO RESCIND THE MOTION. AYES: 5 NAYS: 0 Commissioner Corbett opened the public hearing. Page 16 of 473 March 31, 2026 Mendota Heights Planning Commission Meeting Page 16 of 16 Seeing no one coming forward wishing to speak, Commissioner Corbett asked for a motion to close the public hearing. COMMISSIONER GOLDADE MOVED, SECONDED BY COMMISSIONER UDELL, TO CLOSE THE PUBLIC HEARING. AYES: 5 NAYS: 0 COMMISSIONER NATH MOVED, SECONDED BY COMMISSIONER UDELL, TO RECOMMEND APPROVAL OF THE PROPOSED AMENDMENTS TO CITY CODE TITLE 11 – SUBDIVISION REGULATIONS AS OUTLINED IN THE REDLINED ORDINANCE. AYES: 5 NAYS: 0 Community Development Manager Sarah Madden advised the City Council would consider this application at its April 21, 2026, meeting. New and Unfinished Business Staff Announcements / Updates Community Development Manager Sarah Madden provided an update on recent City Council action on planning-related cases. She noted that the April meeting will include the two tabled applications and one new application. Adjournment COMMISSIONER NATH MOVED, SECONDED BY COMMISSIONER UDELL, TO ADJOURN THE MEETING AT 9:41 P.M. AYES: 5 NAYS: 0 Page 17 of 473 4.a Planning Commission Meeting Date: April 28, 2026 Agenda Item: Tabled - CASE No. 2026-02 Variance Application of Clarence Tweh for a Variance to the front yard setback to accommodate the installation of an accessibility ramp at 537 Junction Lane Department: Community Development Contact: Sarah Madden, Community Development Manager Introduction: The applicant, Clarence Tweh, is requesting approval of a Variance to the front-yard setback for the installation of an accessibility ramp for the property at 537 Junction Lane. The City Code permits small structures such as accessibility ramps to encroach 5-ft into the front yard setback without the need for a Variance, however the proposed location of this ramp would encroach more than 5-ft into the front yard and as such requires a Variance from the City. This item was presented under a duly noticed public hearing process on March 31, 2026. A notice of hearing on this item was published in the Pioneer Press newspaper; and notice letters of this hearing were mailed to property owners within 350 feet from the subject property. Three written public comments were submitted to the City, and at the March 31st public hearing, one member of the public spoke relating to the application. Following the public hearing on March 31st, the Planning Commission discussed the public comments received relating to the application and the proposed Variance request to reduce the front-yard setback for this ramp. As part of their deliberation, the Planning Commission directed staff to work with the applicant to confirm the dimensions shown on the provided plan, and to inquire about alternative materials that could be used for the ramp. On April 8th, staff met with the applicant on-site to field verify the dimensions of the rise between the existing driveway and the existing front stoop and can confirm that a small adjustment has been made to the plans to reflect a rise of 27” as opposed to the original display of 28”. With this update and through discussion with staff, the applicant has updated the ramp plan to reduce the variance request from 10-ft 3-in to 8-ft 9-in. Background: The subject parcel is approximately 7,102 square feet in size and contains a single-family dwelling. The property is zoned R-1 Low Density Residential and guided for low density residential development. The existing single-family home was built in 1968 and is part of the John H Morrison’s Addition subdivision, originally platted in 1923. The lot is substandard in total size to the current base standards for an R-1 lot. There is an accessibility ramp already in place on the property which was identified as a code enforcement violation, leading to this Planning Application being submitted. The current ramp extends from the front stoop of the home towards the street and not only encroaches into the Page 18 of 473 front-yard setback, but encroaches into public right-of-way. With this Variance request, the applicant has committed to relocating the ramp to a new alignment which no longer encroaches onto public right-of-way and which is closer to the existing dwelling. Even with this relocation, a Variance to the front-yard setback is still needed. Analysis: City Code requires structures in the R-1 Low Density Residential District to be setback a minimum of 30-ft from the front property line. The Code provides flexibility on all lots within the City for some encroachments into the yard in cases of decks, stoops, uncovered porches, and accessibility ramps, per 12-4A-3: YARDS AND OPEN SPACE: C1.c (below) c. Uncovered and/or open terraces, steps, porches, decks, egress windows, accessibility ramps, stoops or similar structures that do not extend above the height of the ground floor level of the principal building and do not extend more than five feet (5') in into the front yard or rear yard; or more than three feet (3') into a side yard. The existing home is setback 30-ft from the front property line, consistent with the zoning district requirements. However, in this case the existing front stoop already extends 4-ft 2-in into the front yard. There is an existing sidewalk and small set of stairs that connect to this front stoop, and the connection point is a rise of 27”, which is not sufficient slope for an accessibility ramp. For any accessibility ramp to be installed and to tie into this front stoop, the alignment would always encroach further into the front yard than permitted by City Code. The existing lot width of the subject property is 65-ft, as opposed to the 100-ft minimum required in current City Code standards. This reduction in lot width and the location of the front entrance of the home centered on the lot leaves less space for an alignment of an accessibility ramp that could connect directly to the driveway in the location of the existing sidewalk, and instead requires a turnback to gain more space to achieve adequate slope. The proposed location of the new accessibility ramp (displayed on the revised plan dated 4/12/26) would attach to the existing stoop heading east 4-ft, then turn south for an additional 12-ft 3-in, and finally turn back west towards the driveway for 30-ft 6-in and make a new connection point with the existing driveway. This revised alignment would reduce the front yard encroachment from 15-ft 3-in to 13-ft 9-in, and further reduce the variance request for the ramp's setback from 10-ft 3-in to 8-ft 9-in. With this updated alignment, the proposed ramp extends an additional 5-ft 10.5-in into the front yard beyond the south edge of the existing sidewalk. The existing connection point to the driveway has a rise of 27" from the driveway to the point of the ramp’s beginning at the front stoop, which has been field verified by the City's Engineering staff. There is a small retaining wall at the perimeter of the length of the driveway which is driving the need for additional length of ramp and the turnback in the ramp's alignment, so that the ramp can be constructed at a 1:12 slope. Based on the needed slope for the accessibility ramp, and the existing setback of the home and front stoop, there is not an alternative location where the ramp could be installed without the need for a Variance. Page 19 of 473 City Code Section 12-5B-7 governs variance requests. The city must consider a number of variables when recommending or deciding on a variance, which generally fall into two categories: (i) practical difficulties; and (ii) impact to the community. The “practical difficulties” test contains three parts: (i) the property owner proposes to use the property in a reasonable manner not otherwise permitted by the zoning ordinance; (ii) the plight of the property owner is due to circumstances unique to the property, not created by the property owner; and (iii) the variance, if granted, will not alter the essential character of the locality or neighborhood. It is also noted that economic considerations alone do not constitute practical difficulties. In addition, variances are only to be permitted when they are in harmony with the general purposes and intent of the zoning ordinance and consistent with the comprehensive plan. Section 12-5B-7(E)(1) further provides other issues the city may consider when granting or denying a variance, noted as follows: a. Practical Difficulties exist that apply to the structure or land in question that are unique to such property or immediately adjoining property; and b. Such Practical Difficulties do not apply generally to other land or structures in the Zoning District in which said land is located; and c. That the granting of the Variance is necessary for the preservation and enjoyment of a substantial property right of the Applicant; and d. That granting the proposed Variance will not impair an adequate supply of light and air to adjacent property, unreasonably increase the congestion in the public streets, increase the danger of fire, endanger the public safety, unreasonably diminish or impair established property values in the surrounding area; or e. That granting the proposed Variance will not in any other way impair health, safety, comfort, or in any other respect be contrary to the intent of this Zoning Ordinance; and f. That the granting of such Variance will not merely serve as a convenience to the Page 20 of 473 Applicant but is necessary to alleviate a Practical Difficulty. g. If all the conditions are met, then the City Council may grant such Variance and impose conditions and safeguards therein. When considering a variance request, the Planning Commission must determine if these standards have been met in granting a variance, and provide findings of facts to support such a recommendation to the City Council. If the Planning Commission determines the Applicant has failed to meet these standards, or has not fully demonstrated a reasonableness in the granting of such variance, then findings of fact supporting a recommendation of denial must be determined. As part of any variance request, Applicants are required to prepare and submit their own responses and findings, which for this case, are noted in the application materials (included in the attachments and noted below in italic text). 1. Are there any practical difficulties that support the granting of the Variance? Applicant’s Response: The property is shorter than many and does not provide sufficient space to install a ramp within the location of the city setback. The driveway and property are sloped, requiring the ramp to account for the additional grade. Staff’s Response: The existing single-family home is compliant with the front yard setback of the R-1 zoning district. However, the lot is substandard in total size and width. The existing lot width of the property is 65-ft as opposed to the 100-ft required in current ordinance standards, and the property is an existing lot platted prior to 1982. The City Code provides some flexibility in side-yard setbacks for existing homes on substandard lots, but does not explicitly address additional encroachment for these low-level structures, beyond the exception already granted to all properties and all yards in 12-4A-3. The City’s Comprehensive Plan addresses flexibility in existing lots for the purposes of enhancements to the City’s housing stock. Staff would disagree that the property is shorter than many due to its existing compliance with the front yard setback. However, staff agrees that the slope needed for an accessibility ramp must be accommodated through the use of a turnback, and the slight change in grade and the small retaining wall adjacent to the driveway is a practical difficulty to accommodating a ramp connection within the allotted 5-ft encroachment in City Code. Due to this factor, there is no alternative location for the accessibility ramp that would be able to comply with this front-yard setback standard. 2. The plight of the property owner is due to circumstances unique to the property, not created by the property owner. Applicant’s Response: There is a retaining wall along the driveway, to the grassy area of the yard is elevated from the driveway. Staff’s Response: The existing front stoop encroaches 4-ft 2-in into the front yard setback. With the need for a landing area to tie-in to the stoop, and the slope needed to accommodate this ramp, there is no alternative location for this structure which would not require a Variance. Staff has confirmed with the applicant team that there is a 27" rise between the driveway and the front stoop at the connection point of the existing sidewalk. With the 18-ft distance between the front stoop and the driveway, there is not enough space for a ramp alignment which is within 5-ft of the front wall of the home which would accommodate a 1:12 slope, and a turnback is necessary for any potential alignment of an accessibility ramp on this property. With the revisions to the ramp alignment as part of the Page 21 of 473 updated plans on 4/12/26, the applicant has displayed an alignment that accommodates the appropriate slope for an accessibility ramp on this property while reducing the encroachment into the front-yard setback from what was previously requested. Staff agrees with the applicant that the design, including the turnback, is needed to accommodate the 1:12 slope and cannot be avoided in this case where the property needs the accessibility ramp as an accommodation for the residents of the home. 3. The Variance, if granted will not alter the essential character of the neighborhood. Applicant’s Response: No. Staff’s Response: The proposed accessibility ramp extending into the front yard will not alter the essential character of the neighborhood. The existing ramp which is a code violation cannot continue to be located in its current alignment as it encroaches into the public right-of-way. This alternative alignment which is a 13-ft 9-in encroachment into the 30-ft front yard setback is reasonable for the property and is appropriate in this case where an accessibility ramp is needed to accommodate the residents at this property. Staff has worked with the applicant to address concerns about the extent of the Variance request and the applicant's team has modified the plans to reduce the Variance request to 8-ft 9-in. The applicant team have also indicated that with the updated plans dated 4/12/26, they would be able to construct the ramp with wood as opposed to the existing non-compliant ramp's metal materials. Staff agrees that this material change would increase the compatibility with the neighborhood as a whole. Conclusion: Staff has evaluated the Variance request and finds that the application does demonstrate practical difficulties in its substandard lot size and existing change in grade from the front entrance of the home to the sidewalk connection with the driveway. The slope needed to accommodate an accessibility ramp necessitates a turnback in the ramp alignment which cannot be accommodated within a 5-ft encroachment into the front yard, which would make any ramp installation at this property require a Variance request and approval. The proposed improvement to the property would eliminate an existing code violation and right-of-way encroachment and is less of an encroachment into the setback than the current condition of the violation. The applicant has also worked with city staff to explore alternative materials and adjusted the alignment to reduce the variance request where possible. The installation of an accessibility ramp at this home is not inconsistent with neighborhood character, and would be a reasonable use of a single-family dwelling within the City of Mendota Heights. Alternatives: 1. Recommend approval of the 13-ft 9-in encroachment into the front yard and 8-ft 9-in variance request from the front-yard setback for installation of the new accessibility ramp, based on the attached findings of fact and specific conditions of approval as included herein; or 2. Recommend denial of the Variance request, based on the findings of fact that confirm the Applicant failed to meet the burden(s) of proof or standards in granting of the variance requested herein, noted as follows: A. Under Title 12-1L-5A of the City Code, the City may only grant variances from the strict application of the provisions of the Code in cases where there are “practical difficulties” in carrying out the strict letter of the regulations of the Code. “Practical difficulties” consists of a three-part test: (i) the Applicant proposes to Page 22 of 473 use the property in a reasonable manner not otherwise permitted by the Code; (ii) the plight of the Applicant is due to circumstances unique to the property not created by the Applicant; and (iii) the variance, if granted, will not alter the essential character of the neighborhood. Economic considerations alone do not constitute “practical difficulties.” B. The City hereby determines the Applicant has not met the burden of demonstrating the requisite “practical difficulties” in order to justify the granting of a variance for a 13-ft 9-in encroachment and 8-ft 9-in setback reduction. The level of encroachment into the front yard setback is not reasonable use of the property. The change in grade does not constitute a practical difficulty and an alternative alignment could be found without the need for a Variance; the conditions requiring the ramp structure is therefore not considered a practical difficulty within the property. C. Because the City finds that the second prong of the three-part test (practical difficulty of the property) is not met by the Applicant, the City need not consider the remaining two prongs of the test (reasonableness and essential character of the neighborhood). 3. Table the request and request additional information from the applicant or staff. Staff will extend the application review period an additional 60 days, in compliance with MN Statute. 15.99. Staff Recommendation: Staff recommends approval (Alternative #1) of the proposed Variance as proposed by the applicant, based on the Findings of Fact as included herein, along with the following conditions: 1. The 13-ft 9-in encroachment into the front yard and 8-ft 9-in Variance is exclusively for the installation of an accessibility ramp within the front yard. 2. The Applicant shall not deviate from the ramp plan under this application review without first seeking and receiving city approvals, unless City Code provides for certain or allowable improvements to be made without any additional application review process. 3. No work begins on the proposed ramp installation until an administrative permit has been issued by the City. 4. The existing accessibility ramp which is a violation of City Code and encroaches into the front yard and public right-of-way must be removed within 90 days of this Variance approval. Attachments: 1. Findings of Fact for Approval 2. Site Location Map 3. Narrative Letter 4. Variance Application Checklist 5. Junction Lane Existing Layout 6. Junction Lane Ramp Plan, dated 04/12/26 7. Public Comment - Burke 3/28/26 8. Public Comment - Davis 3/23/26 9. Public Comment - Nadeau 3/28/26 Page 23 of 473 FINDINGS OF FACT FOR APPROVAL Variance 537 Junction Lane The following Findings of Fact are made in support of approval of the proposed request: A. Under Title 12-5B-7 of the City Code, the Council may only grant variances from the strict application of the provisions of the Code in cases where there are “practical difficulties” in carrying out the strict letter of the regulations of the Code. “Practical difficulties” consists of a three-part test: (i) the Applicant proposes to use the property in a reasonable manner not otherwise permitted by the Code; (ii) the plight of the Applicant is due to circumstances unique to the property not created by the Applicant; and (iii) the variance, if granted, will not alter the essential character of the neighborhood. Economic considerations alone do not constitute “practical difficulties.” B. The Applicant has met the burden of demonstrating the requisite “practical difficulties” in order to justify the granting of a Variance to allow a 13-ft 9-in encroachment into the front yard and 8-ft 9-in setback reduction for the installation of an accessibility ramp, by the following: i.) The proposed installation of an accessibility ramp is a reasonable use of property and is consistent with a single-family residential property’s development pattern; ii.) The subject site is a substandard lot, platted prior to current City Code requirements for minimum lot size and setback dimensions; the existing home is compliant with the front yard setback requirements and contains an existing stoop compliant with encroachment flexibilities permitted within City Code. Due to the change in grade from the front stoop to the driveway, and the required slope for an accessibility ramp, there is no alternative alignment for an accessibility ramp to tie into that existing stoop without the need for a Variance from the front-yard setback and encroachment requirements. The alignment is needed due to the grading of the property, and a turnback within the ramp alignment necessitates this Variance request. iii.) The reason for the Variance request is to permit a reasonable installation of an accessibility ramp to serve the residents of the home. This alignment and accessibility ramp installation will correct an existing code violation which is on file against the subject property and remove an encroachment on public right-of- way at cost to the property owner and for this reason the request is not solely based on economic considerations. C. The City has considered the factors required by Title 12-1L-5E1 of the City Code, including but not limited to the effect of the Variance upon the health, safety, and welfare of the community, existing and anticipated traffic conditions, the effect of the Variance on the danger of fire and the risk to public safety, and upon the value of properties in the surrounding area, and upon the Comprehensive Plan, and has determined this Variance will not affect or pose any negative impacts upon the neighborhood or the community in general. Page 24 of 473 Planning Report: Case #2026-02 Page 2 D. Approval of this Variance is for 537 Junction Lane only, and does not apply or give precedential value to any other properties throughout the City. All variance applicants must apply for and provide a project narrative to the City to justify a variance. All variance requests must be reviewed independently by City staff and legal counsel under the requirements of the City Code. Page 25 of 473 666666666666 66666666666666666666 6666666666666666! ! " "!!" " ! !" " ! " " !" " ! *66666 6 6 666666666666!!2!!2!!2 !!2 !!2 !!2 !!2 531 530 554 550 546 524 558 990 995 523 540 536 560 547 1021 553 542 557 554 555 557 1011 1000 548 987991 995 561 999 1050 1027 537543 1015 1003 525535539543 10351041 569 564 1054 987 JUNCTION LN WINSTON CT DIEGO LNESTHER LNNearmap U S Inc, Dakota County, MN Sit e Location/Aerial Map537 Junction Lane Date: 3/27/2026 City ofMendotaHeights0100 SCALE IN FEET GIS Map Disclaimer:This data is for informational purposes only and should not be substituted for a true title search, property appraisal, plat,survey, or for zoning verification. The City of Mendota Heights assumes no legal responsibility for the information containedin this data. The City of Mendota Heights, or any other entity from which data was obtained, assumes no liability for any errorsor omissions herein. If discrepancies are found, please contact the City of Mendota Heights. Contact "Gopher State One Call" at 651-454-0002 for utility locations, 48 hours prior to any excavation. Page 26 of 473 Page 27 of 473 Page 28 of 473 Name: 537 Junction Existing Layout Concept Only Scale: 3/16"= 1' Page 29 of 473 18' Name: 537 Junction Ramp Option A Concept Only Scale: 3/16"= 1' Existing Concrete Level Landing Page 30 of 473 1 | Page RE: CASE No. 2026-02 Variance Application of Clarence Tweh for a Variance to the front yard setback to accommodate the installation of an accessibility ramp at 537 Junction Lane Planning Commission Members, Our original correspondence dated on Wednesday, March 25, 2026, should no longer be considered as the “Planning Commission Agenda Packet” (Packet) was provided by Sarah Madden on March 27, 2026. The Packet contains additional information on the homeowner’s plans to modify the ramp that was not previously available. We remain opposed to the variance as described in the Packet; however, we would not be opposed to the variance if the plan utilized the existing sidewalk space and was made of materials consistent with the character of the home and neighborhood, so the essential character or the neighborhood remains intact. Why we are opposed to the variance as described in the packet: The current design for the variance fails the “practical difficulties” test criteria laid out of Page 12 of the Packet, specifically that it does not alter the essential character of the neighborhood. We contend that the ramp does alter the essential character of the neighborhood as currently designed. The extent of the variance (11’) is only needed because of the chosen design of the ramp. In its current proposed state, the design is unsightly and out of character with the neighborhood. The packet information dismisses a ramp layout that fits the character of the neighborhood by utilizing the grounds under an existing sidewalk. The packet erroneously dismissed this layout configuration based on inaccurate measurements provided by the contractor (Page 13). The packet revealed that the homeowner intends to modify the ramp in alignment with Figure 1 below: Figure 1: Homeowner Proposed Ramp Plan Page 31 of 473 2 | Page We contest the accuracy of a primary measurement. The rise from the building stoop to the driveway is approximately 21”, not 28” (displayed in red in Figure 1). As stated on Page 13 of the Packet states this measurement of 28” was obtained by the applicant’s contractor. Based on improper installation of the existing ramp and conflicting measurements, the contractor’s measurements should, at minimum, be verified by a certified city inspector, prior to granting any variance at this address. This measurement has a material impact on the ramp design because it dictates the design, specifically the run, of the ramp and whether a turnback is required. Based on Figure 1, the existing concrete level landing is 8’ wide. The 5’ x 5’ level landing can be aligned with the right side of the existing concrete level landing, creating a scenario where there is a total of >21’ between the start of the ramp and accommodating 1:12 slope requirement. This would enable the ramp to be built without the turnback and be built as close as reasonably possible to the house (approximately 7’) where the existing sidewalk is located. Utilizing the grounds under the existing sidewalk is essential to having the ramp not alter the essential character of the neighborhood as it fits within the existing design of the home and neighborhood. Another essential factor in determining whether the ramp does not alter the essential character of the neighborhood is the materials of construction. Shiny metallic materials (as currently constructed) are not consistent with the character of the home’s wood siding and the residential nature of the neighborhood. The proposed variance is silent on the materials of construction. While it is understood the variance is specific to city ordinance: 12-4A-3, the ramp materials play a significant role in how the ramp impacts the character of the neighborhood. Because this ramp is intended to be constructed via a variance and the home is being utilized for business purposes, we request that the materials of construction are specified within any updated designs of the variance. In summary, we are opposed to the variance as currently drafted and disagree with “Staff Responses” “Conclusion” and “Staff Recommendation” on pages 13-15 of the Packet as the responses are based on erroneous information provided by the contractor that have not been verified by a well-credentialed individual without a vested interest in the outcome of the project. Therefore, the staff responses, conclusions, and recommendations by staff should not be taken into consideration by the planning commission. Finally, we do not want nor intend to prevent access of any disabled individuals from entering the business located at 537 Junction Lane; however, it is essential for business owners operating in a residential area to ensure they do not alter the essential character of the neighborhood to accommodate their business needs. Kind Regards, Jake & Emily Burke Page 32 of 473 From:Rachel Davis To:Sarah Madden Subject:Planning Case No. 2026-02 Date:Monday, March 23, 2026 6:40:10 PM [You don't often get email from rachel.davis@email.com. Learn why this is important at https://aka.ms/LearnAboutSenderIdentification ] Ms. Madden, I am writing in support of Planning Case No. 2026-02. As a neighbor to this property, I am happy to have this group home part of our community. The residents and staff are wonderful neighbors, and we would like to support this case to make the location safer and more accessible. Best, Rachel and Cory Davis 554 Junction Lane 612-229-0404 Page 33 of 473 RE: CASE No. 2026-02 Variance Application of Clarence Tweh for a Variance to the front yard setback to accommodate the installation of an accessibility ramp at 537 Junction Lane Planning Commission Members, Our names are Nick and Joann Nadeau. Our property extends from 546 Winston Ct down to what would be considered 54X Junction Lane, adjacent to 543 Junction Lane. The proposed ramp is directly visible from our property. We are opposed to the variance. The Planning Commission Packet notes that “Under Title 12-1L-5A of the City Code, the City may only grant variances from the strict application of the provisions of the Code in cases where there are “practical difficulties”. The variance for the ramp does not meet the “practical difficulties” assessment. 1. The change in grade does not constitute a practical difficulty and alternative alignment could be found without the need for a variance. a. We contest the accuracy of the measurements provided by the contractor, specifically the Rise of 28” as we do not believe this is accurate. b. We contend that the grade of the property allows the ramp to be installed with 5’ of the house and that a variance is not required. 2. The variance impacts the essential character of the neighborhood a. The proposed ramp, in its current design and front-yard location, creates a prominent and visually intrusive structure that is not consistent with the open, residential character of the neighborhood. Its size, placement, and clear visibility from the public right-of-way detract from the existing streetscape and risk establishing a precedent for similar intrusions. Feasible alternative designs appear to be available that would provide necessary accessibility while maintaining the essential character of Junction Lane. Sincerely, Nick and Joann Nadeau Page 34 of 473 5.a Planning Commission Meeting Date: April 28, 2026 Agenda Item: CASE No. 2026-06 Lot Line Adjustment Application of Paul Linnell for a Lot Line Adjustment of the properties located at 1603 Dodd Road and 688 Wentworth Avenue Department: Community Development Contact: Sarah Madden, Community Development Manager Introduction: Paul Linnell is requesting consideration of a simple lot line adjustment of the properties located at 1603 Dodd Road and 688 Wentworth Avenue. The application request includes the two addressed parcels and would adjust the shared lot line between the two subject properties by shifting it 42.3-ft to the west, increasing the lot size of 1603 Dodd Road and decreasing the lot size of 688 Wentworth Avenue. A public hearing notice for this planning item was published in the Pioneer Press and notice letters were mailed to all properties within 350-feet of the subject property. As of the date of this report, the City has not received any written public comments relating to this application request. Background: The subject site is located in a residential neighborhood at the southwest corner of Wentworth Avenue and Dodd Road. The property included in this resubdivision request consists of two (2) existing parcels, which are split remnants from Auditor’s Subdivision No. 3, dated 1906. The 1603 Dodd Road parcel is 28,778 square feet in size and contains an existing single-family home constructed in 1880. The 688 Wentworth Avenue parcel is 21,345 square feet in size and also contains an existing single-family home, constructed in 1973. The combined lot area is 1.147 acres. The applicant owns both parcels and has submitted the lot line adjustment in preparation for future sales of both lots. Analysis: This application was submitted prior to the City Council’s approval of the revisions to Title 11: Subdivision Regulations. It is subject to the code in place on the date the application was marked complete. For this case, City Code Title 11 stated: “Lot line adjustment request to divide a lot which is a part of a recorded plat where the division is to permit the adding of a piece of land to an abutting lot and the newly created property line will not cause the other remaining portion of the lot to be in violation with this title or the zoning ordinance. . . The newly described parcel descriptions on the applicant’s survey indicate that the proposed lot line adjustment would shift the shared lot line 42.3-ft to the west. This request to modify Page 35 of 473 each lot’s boundary line meets this section of City Code, as the resulting parcels will be compliant with the minimum dimensional standards of the R-1 Zoning District. For the R-1 District, all new lots must have a minimum of 15,000-sf. of lot area and 100-ft of frontage, or lot width, along a City-approved street. Both parcels meet these minimums, and continue to be compliant with the minimum 10-ft side yard setback requirement. A summary of the existing properties, and the proposed configuration is provided in the following table: 688 Wentworth Avenue 1603 Dodd Road Existing Proposed Existing Proposed Lot Area (sq. ft) 21,345 15,002 28,778 34,952 Lot Width (ft) 142.3 100 223.5 265.8 Side yard setback (shared line - ft) 55 12.8 64 106 This lot line adjustment will have little, if any, impact upon the neighboring properties, nor impede the normal use, enjoyment and purpose of the surrounding residential neighborhood. Alternatives: 1. Recommend approval of the lot line adjustment, based on the attached findings-of-fact and based on certain conditions; or 2. Recommend denial of the lot line adjustment, based on the revised findings-of-fact that the proposed adjustment is not consistent with the City Code or Comprehensive Plan and may have a negative impact on the surrounding neighborhood and/or properties; or 3. Table the request and request additional information from staff and/or the applicant; Staff will extend the review period an additional 60 days, in compliance with Minnesota State Statute 15.99. Staff Recommendation: Staff recommends that the Planning Commission recommend approval of the lot line adjustment based on the attached findings-of-fact supporting the request, and with conditions as follows: 1. The applicant must record the Lot Line Adjustment (minor subdivision) at Dakota County indicating the newly revised property descriptions for the resulting lots. 2. All transfer or deed documents which convey the portion of lands under the lot line adjustment and lot split process shall be recorded with Dakota County. Attachments: 1. Findings of Fact for Approval 2. Site Location Map 3. Letter of Intent 4. Certificate of Survey Page 36 of 473 Planning Case No. 2026-06 FINDINGS OF FACT FOR APPROVAL Lot Line Adjustment Linnell Properties – 688 Wentworth Ave and 1603 Dodd Road The following Findings of Fact are made in support of approval of the proposed request: 1. The proposed lot line adjustment request meets the general purpose and intent of the City Code and is considered consistent with the Comprehensive Plan. 2. Approval of the lot line adjustment will have no visible impact on the subject properties; and poses no threat or creates any negative impacts on the character of the neighborhood. 3. The proposed adjustment does not cause any non-conformities on either parcel, based on the applicable zoning district standards for lot size and frontage requirements. Page 37 of 473 66666666666666666666"³ ³ *** * * * * "" *" " ** * !* "³6666666666666666666666666!!2 !!2 !!2 !!2!!2!!2!!2!!2!!2 !!2 !!2 !!2 !!2 !!2 !!2 !!2 !!2 !!2 !. 654 1416 1635 694 1638 1650 724 662 1620720716702710 670 1648 1630 1603 1656 717 1549723 688 689 739 695 1565 723 711 701707 1658 1623 1629 713 716 709 726 710 688 16607066947001656 729 728 1527 677 669 DODD RD4TH AVE WENTWORTH AVE EVERGREEN KNLS Nearmap US Inc, Dakota County, MN Site Location/Aerial Map Linnell - Lot Line Adjustment Date: 8/22/2025 City ofMendotaHeights0200 SCALE IN FEET GIS Map Disclaimer:This data is for informational purposes only and should not be substituted for a true title search, property appraisal, plat,survey, or for zoning verification. The City of Mendota Heights assumes no legal responsibility for the information containedin this data. The City of Mendota Heights, or any other entity from which data was obtained, assumes no liability for any errorsor omissions herein. If discrepancies are found, please contact the City of Mendota Heights. Contact "Gopher State One Call" at 651-454-0002 for utility locations, 48 hours prior to any excavation. Page 38 of 473 Page 39 of 473 CERTIFICATE OF SURVEY CURRENT LANDOWNER OF BOTH PARCELS SURVEYOR EXISTING LEGAL DESCRIPTION PARCEL 2 LOT LINE ADJUSTMENT PROPOSED PARCEL AREAS WETLANDS PROPOSED IMPROVEMENTS UTILITIES ZONING CERTIFICATION 202516 SISU LAND SURVEYING 2580 Christian Dr. Chaska, MN 55318 612-418-6828 LEGEND EXISTING LEGAL DESCRIPTION PARCEL 1 PROPOSED LEGAL DESCRIPTION PARCEL 2PROPOSED LEGAL DESCRIPTION PARCEL 1 Page 40 of 473 5.b Planning Commission Meeting Date: April 28, 2026 Agenda Item: CASE No. 2026-07 Conditional Use Permit Application of Homes by Tradition for a Conditional Use Permit to allow an attached garage size of 1,499 square feet on the property located at 1961 Glenhill Road Department: Community Development Contact: Sarah Madden, Community Development Manager Introduction: Homes by Tradition is the Applicant and Owners’ Representative of the property at 1961 Glenhill Road, and has requested a Conditional Use Permit (CUP) to allow an attached garage size of 1,499 square feet as part of the new single-family home planned for construction on the subject property. A public hearing notice for this item was published in the Pioneer Press and notice letters were mailed to all surrounding properties within 350-feet of the subject property. No written public comments were received as of the submittal of this report. Background: The subject property is located at the northwest corner of Glenhill Road and Victoria Curve, and is generally east of the boundary with the City of Mendota. The subject site is part of the Valley View Oak 2nd Addition subdivision and has never been developed. A Mississippi River Corridor Critical Area (MRCCA) Permit was approved for this property on February 3rd to authorize the construction of a new home and associated site improvements, as outlined in Resolution 2026-10 which is attached to this report. During the review of the MRCCA Permit earlier this year, the City evaluated the site impacts for the construction of the new home, swimming pool, and grading measures. As part of that application the City needed civil site plans from the applicant, but construction documents and floor plans were not needed to evaluate the proposal for consistency with MRCCA rules and regulations. The City is currently reviewing the building permit for the new single-family home, and notified the applicant that the proposed attached garage size exceeded what was permitted by staff authorization within a building permit. The attached garages proposed for this home construction include two levels of garage, with a smaller lower level garage accessible by a side drive on the north side of the property, and a main level garage accessed directly from the front of the property (facing east). Proposed Improvements The existing lot is vacant. The construction plan for this site is to construct a new 4,214 sq-ft home on the property, generally located at the front of the lot, 33-ft from the front property line abutting Glenhill Road. The proposed improvements with that project include a new driveway, attached screen porch, deck, and patio, a swimming pool, a new infiltration basin, and the Page 41 of 473 development will include several retaining walls of varying heights. These site improvements were authorized with the prior MRCCA Permit approval. The improvements associated with this CUP request include an attached garage size of 1,499 square feet. City Code Section 12-4A-8: ACCESSORY STRUCTURE REQUIREMENTS, Subsection D, Private Garage outlines the size standards for residential garages, limiting attached garages to 1,200 sq. ft., unless a Conditional Use Permit is obtained to allow up to 1,500 sq. ft. The garage for this home will be on two levels, with 1,073 sq. ft. on the main level with a front- facing vehicular entrance to the east towards Glenhill Road, and 426 sq. ft. on the lower level with vehicular access from a curved side drive on the north side of the home. The total garage size of 1,499 sq. ft is within the range permitted by Conditional Use Permit. Additionally, all of the proposed garage doors are consistent with the maximum garage door height of 9-ft and 28 linear feet of garage door width is shown to be visible from the public right-of-way, which is less than the 36-ft maximum. Analysis: Pursuant to Title 12-5B-5, the city recognizes that the development and execution of Zoning Code is based upon the division of the city into districts within which regulations are specified. It is further recognized that the purpose of the Conditional Use Permit is to provide the City with the discretion and flexibility to achieve the goals and objectives of the Comprehensive Plan and to determine what, if any, uses other than those specifically permitted in the Zoning Ordinance may be suitable. To provide for these needs, the city may approve a conditional use for those uses and purposes, and may impose conditions and safeguards in such permits to ensure that the purpose and intent of this chapter is effectively carried out. The City may grant a conditional use provided the proposed use demonstrates the following: a) Use will not be detrimental to the health, safety or general welfare of the community, b) Use will not cause serious traffic congestion nor hazards, c) Use will not seriously depreciate surrounding property value, and d) Use is in harmony with the general purpose and intent of this chapter and the comprehensive plan. a-c) The proposed use will not be detrimental to the health, safety or general welfare of the community; will not cause serious traffic congestion or hazards; nor depreciate surrounding property value. Staff Response: The proposed garage is intended to support the needs of the planned single-family home and use of the property and will provide additional vehicular storage for the homeowner. As designed and shown on the Applicant’s submission, the total garage size includes two levels of private garage, with the lower level not visible from the public right-of-way. The civil site plans for this property were previously reviewed as part of a MRCCA Permit. That review and the site improvements for this parcel show a two-level home with a basement walkout construction style due to the existing grade of the lot as it abuts steep slopes and the Bluff Impact Zone. The lower level of this attached garage is shown to be connected to unfinished storage space within the basement of the home. The structure meets all required setbacks and other dimensional standards of the R-1 zoning district, and will have no adverse impact to traffic or surrounding property values. Page 42 of 473 d) The proposed use conforms to the general purpose and intent of the city code and comprehensive plan, including all applicable performance standards, so as not to be in conflict on an on-going basis. Staff Response: The subject property is guided Low Density Residential (LR) in the City’s comprehensive plan and zoned for R-1. Both establish that use of property should generally be for single- family residential and supporting accessory uses. The Applicant is proposing to use the total garage space for storage of vehicles. Section 12- 8B-1 defines an attached garage as: A private garage that is accessory and attached to the principal structure, that is primarily used for personal vehicles and storage. Staff determines that the proposed project is consistent with the City’s zoning ordinance and comprehensive plan, as well as the City Code as it relates to private garages. Alternatives: 1. Recommend approval of the conditional use permit, based on the attached findings-of- fact and based on certain conditions; or 2. Recommend denial of the conditional use permit, based on revised findings-of-fact that the proposed garage size is not consistent with the City Code or Comprehensive Plan and may have negative impact on the surrounding neighborhood and/or properties; or 3. Table the request and request additional information from staff and/or the applicant; Staff will extend the review period an additional 60 days, in compliance with Minnesota State Statute 15.99. Staff Recommendation: Staff recommends approval of the Conditional Use Permit request by Homes by Tradition for an attached garage size of 1,499 square feet at 1961 Glenhill Road with the following conditions: 1. A building permit, including a grading plan, must be approved and issued by the City prior to the commencement of any work on site. 2. The proposed project must comply with all requirements of the City’s Land Disturbance Guidance Document. All plans must be reviewed and approved by the Public Works Director. 3. All grading and construction activity must comply with applicable federal, state, and local regulations and codes. Attachments: 1. Findings of Fact for Approval 2. Site Location Map 3. Applicant Letter 4. Main Level Floor Plan 5. Lower Level Floor Plan 6. Survey - 1961 Glenhill Road 7. Res 2026-10 Approving MRCCA Permit at 1961 Glenhill Road Page 43 of 473 Planning Case 2026-07 (Conditional Use Permit - Homes by Tradition) Page 1 of 1 FINDINGS-OF-FACT FOR APPROVAL Conditional Use Permit for Planning Case No. 2026-07 (Homes by Tradition) The following Findings of Fact are made in support of approval of the proposed requests: 1. The proposed use of the subject property as a single-family residential dwelling is consistent with City Code and the Comprehensive Plan. 2. The planned construction and use of 1,499 square feet of attached garage is consistent with garage size maximums, and the structure is compliant with the garage door height and width requirements for residential garages, as well as the required setbacks of the R-1 Zoning District 3. The proposed project will not be detrimental to the health, safety or general welfare of the community; should not cause any serious traffic congestion nor hazards; will not seriously depreciate surrounding property value; and said use appears to be in harmony with the general purpose and intent of the City Code and the Comprehensive Plan. Page 44 of 473 66666666666666666666666666666666 6666 66666666666666666666666 6 66 66 6 6 66³ "" " "* !* !"" ! ( ! " ³ * ³ * ! " " " " " " " " """ " " """ !* ! * " " "! " "!" ! "" ! ! "" " " ³ ³* ³! * * * ³ ³" " " " " ! !!!³ ³ 6 6 6 6666666666FMFM !!2!!2 !!2 !!2 !!2 !!2 !!2 !!2 !!2 !!2 !!2 !!2 !!2 2025 1941 370 1310 1215 390 1948 1308 1217 1203 1290 1190 1949 1954 1936 1219 1942 12001206 1310 1300 1230 1224 1920 1290 330 1935 11871199120519211914124219111264 H IG H W A Y 6 2 V I C T O R I A C U R VG ST CENTRE POINTE CURVGLENHILL RDCULLIGAN LN 4TH STHIGHWAY 62 Nearmap U S Inc, Dakota County, MN Sit e Location/Aerial Map1961 Glenhill Road Date: 4/23/2026 City ofMendotaHeights0210 SCALE IN FEET GIS Map Disclaimer:This data is for informational purposes only and should not be substituted for a true title search, property appraisal, plat,survey, or for zoning verification. The City of Mendota Heights assumes no legal responsibility for the information containedin this data. The City of Mendota Heights, or any other entity from which data was obtained, assumes no liability for any errorsor omissions herein. If discrepancies are found, please contact the City of Mendota Heights. Contact "Gopher State One Call" at 651-454-0002 for utility locations, 48 hours prior to any excavation. Page 45 of 473 Page 46 of 473 Page 47 of 473 Page 48 of 473 Page 49 of 473 CITY OF MENDOTA HEIGHTS DAKOTA COUNTY, MINNESOTA RESOLUTION 2026-10 RESOLUTION APPROVING A MISSISSIPPI RIVER CORRIDOR CRITICAL AREA MRCCA) PERMIT TO HOMES BY TRADITION AND FOR THE PROPERTY LOCATED AT 1961 GLENHILL ROAD. PLANNING CASE 2026-01 WHEREAS, Homes by Tradition, (the "Applicant") made an Application for a Mississippi River Corridor Critical Area (MRCCA) Permit to allow for a new single-family home and associated site improvements, located at the vacant property at 1961 Glenhill Road, and legally described in Exhibit A (the "Subject Property"); and WHEREAS, the Subject Property is guided LDR-Low Density Residential in the 2040 Comprehensive Plan, zoned R-1 Low Density Residential, and is situated in the Mississippi River Corridor Critical Area Overlay District; and WHEREAS, pursuant to City Code Title 12-6A-3: Mississippi River Corridor Critical Area Overlay District, a permit is required to approve any new development activities involving a building permit, land disturbance, vegetation removal, or special zoning approval, and the Applicant is seeking permission to make site improvements under the rules and standards established by the R-1 District and the related Mississippi River Corridor Critical Overlay District ordinance and standards; and WHEREAS, on August 26, 2025, the Mendota Heights Planning Commission held a public hearing on this Conditional Use Permit request, whereby planning reports were presented and received by the Commission, and comments from the applicant and public were allowed, and whereupon closing the hearing, the Commission recommended unanimously (5-0 vote) to approve the request from Homes by Tradition for the MRCCA Permit, which would allow the new single- family home and associated improvements, as proposed and presented under Planning Case No. 2026-01, with certain conditions and findings -of -fact to support said approval. NOW, THEREFORE, BE IT RESOLVED by the Mendota Heights City Council that the recommendation from the Planning Commission on Planning Case No. 2026-01 is hereby affirmed, and may be approved based on the following findings -of -fact: I. The proposed construction of anew single family home and associated improvements meets the general purpose and intent of the Mississippi River Corridor Critical Area MRCCA) Separated from River Overlay District, 2. The proposed work and disturbance to construct the new home and associated improvements has no direct impact to the Bluff Impact Zone, and impact to Primary Conservation Areas within the MRCCA Plan are limited to the minimum necessary Resolution No. 2026-10 Page 1 Page 50 of 473 for development, and the project includes restoration of the area once developed with sod cover and perennial plantings and trees. The proposed project is within the spirit and intent of the MRCCA Separated from River Overlay District that provides for flexibility within the management purpose. 3. The proposed project will not be detrimental to the health, safety or general welfare of the community; should not cause any serious traffic congestion nor hazards; will not seriously depreciate surrounding property value; and said use appears to be in harmony with the general purpose and intent of the City Code and the Comprehensive Plan, 4. The construction of the home is shown in the plan to comply with all standards and regulations of the Mississippi River Corridor Critical Area Overlay District and Zoning Ordinance and other applicable ordinances; represents reinvestment in a residential neighborhood that is consistent with the Comprehensive Plan's goals for residential land uses; and is consistent with the current single-family development pattern of the neighborhood. BE IT FURTHER RESOLVED, by the Mendota Heights City Council that the MRCCA Permit requested for the property located at 1961 Glenhill Road is hereby approved, with the following conditions: 1. A building permit, including a grading plan, must be approved by the City prior to the commencement of any site work. 2. The swimming pool and surrounding pool decking/patio area must be removed from the site plan, or relocated elsewhere on the site plan outside the bluffline setback prior to the City taking action on this application. No structures or facilities, including impervious surfaces, may be located within the bluffline setback. A separate Forest Alteration Permit application and Forest Management Plan is required to be submitted to the City prior to building permit issuance. The applicant shall post a tree replacement escrow with the City and shall mitigate tree replacement in appropriate areas of the property as reviewed and approved by the Natural Resources Manager and Community Development Manager. If compliance with the tree replacement requirement is not feasible, the City may approve alternative tree replacement measures within the Forest Alteration Permit, 4. A final landscaping and restoration plan for the developed area of the site must be submitted for review and approval by the Natural Resources Manager as part of the building permit submittal package, including seed mix details, native plant species, and sizing and DSH of replacement trees. 5. In the Bluff Impact Zone, all new vegetation associated with the restoration plan must be native and suitable for the existing conditions of the slope. Resolution No. 2026-10 Page 2 Page 51 of 473 6. In any areas where buckthorn will be removed, a buckthorn replacement groundcover mix must be installed to prevent erosion. The proposed project must comply with all requirements of the City's an Disturbance Guidance Document. All plans must be reviewed and approved by the Public Works Director. 8. All erosion control requirements must be put in place prior to the commencement of any grading and site work activities and must remain in place for the duration of the construction activities until proper site restoration plans are completed, including a dual row of perimeter control at the back of the property adjacent to the bluff, perimeter control surrounding the infiltration basin, and erosion control blankets on any disturbed slopes 3:1 or greater. 9. All grading and construction activity must comply with applicable federal, state, and local regulations and codes. 10. All work on site will only be performed between the hours of 7:00 AM and 8:00 PM Monday through Friday; 9:00 AM to 5:00 PM weekends. 11. The Applicant/Developer shall correct the discrepancy in the provided Tree Inventory prior to issuance of the Forest Alteration Permit. Adopted by the City Council of the City of Mendota Heights this 4th day of February 2026. CITY COUNCIL CITY OF MENDOTA HEIGHTS ATTEST: a y Bau r, City Clerk Resolution No. 2026-10 Page 3 Page 52 of 473 EXHIBIT A Address: 1961 Olemull Road PI1N:27-81251-00-013 Legal Description: That part of Outlot A, VALLEY VIEW OAK 2ND ADDITION, Dakota County, Minnesota, lying south of aline drawn from a point on the east line of said Outlot A, 132.00 feet southerly of the southeast corner of Lot 2, Block 1, said VALLEY VIEW OAK 2ND ADDITION to a point on the west line of said Outlot A. 325.00 feet northerly of the most westerly southwest corner of said Outlot A and said line there terminating. Resolution No. 2026-10 Page 4 Page 53 of 473 5.c Planning Commission Meeting Date: April 28, 2026 Agenda Item: Tabled - CASE No. 2026-05 Conditional Use Permit Application of Buell Consulting, Inc. on behalf of The Towers LLC, requesting a Conditional Use Permit (CUP) for a new freestanding wireless monopole tower at 739 Wentworth Avenue (Wentworth Park) Department: Community Development Contact: Sarah Madden, Community Development Manager Introduction: The subject property located at 739 Wentworth Avenue is owned by the City and utilized as Wentworth Park. The applicant, Buell Consulting, on behalf of The Towers LLC, requests approval of a Conditional Use Permit (CUP) to allow a 149-ft wireless telecommunications monopole tower. The Towers LLC is a partner of Verizon Wireless. The public hearing for this application was opened on March 31, 2026 at the Planning Commission’s regular meeting. In advance of the public hearing, formal notice for this item was published in the Pioneer Press and notice letters were mailed to all surrounding properties within 1,250-feet of the subject property. At the public hearing, 14 residents spoke relating to the application. The applicant requested the Planning Commission table the item to their next available meeting in order to provide supplemental information as a response to questions submitted through public comments. The Planning Commission agreed with the applicant’s request and unanimously moved to table the application and public hearing to the April 28, 2026 regular Planning Commission meeting. As a courtesy, additional mailed notices were sent out to property owners within 2,000-feet of the park boundary for the continued public hearing on April 28th. The City also published a 2nd formal notice in the Pioneer Press, published a meeting announcement in three instances of the Friday News e-mail newsletter, and the Mendota Heights Parks and Recreation Facebook page posted an announcement about the meeting on April 23rd. There have been many inquiries to the City with questions about this application, and 56 public comments have been received as of the submittal of this report. Those comments have been included as an attachment to this report. Any additional public comments received after the publication of this report will be provided to the Commissioners at the meeting. Background: The Towers, LLC is requesting CUP approval in order to allow construction of a new wireless monopole tower at 739 Wentworth Avenue. The proposed improvements include a 145-ft monopole tower within a 50-ft x 50-ft fenced and screened ground space. A lighting rod will be installed at the top of the tower totaling an overall height of 149-ft. Page 54 of 473 The subject property is zoned R-1 Low Density Residential, and is within the Public/Semi- Public Overlay District. Wireless towers are allowed within this zoning district by Conditional Use Permit and subject to applicable zoning standards. The site is home to Wentworth Park and is municipal property of the City of Mendota Heights. Site and Ordinance History The subject site had a previous planning application for a wireless telecommunication tower in 2006, identified as Planning Case No. 2006-10. At that time, the City Code did not permit a freestanding tower in the R-1 Zoning District. Instead, the ordinance required the infrastructure to be collocated on existing utility towers. That prior application included the Conditional Use Permit for the tower itself, as well as a request from the applicant to amend the City Code on “Freestanding Antennas and Towers” to allow a freestanding tower in a Residential Zoning District by CUP when accessory to an institutional principal use, as well as a revision to increase the maximum height of a tower. The application moved forward to the public hearing stage at the Planning Commission and received significant feedback from the public on the land use request. During the same time period, the City Council had been reviewing the terms of the lease for space at Wentworth Park for the tower infrastructure. Ultimately, the prior planning application was withdrawn by the applicant after the City Council voted unanimously to terminate lease negotiations with T- Mobile for space at Wentworth Park. The applicant at the time stated that this decision to withdraw from lease negotiations with T-Mobile led to their decision to withdraw their zoning application. In the years since this prior application was discussed at the City, updates have been made to the City Code regarding wireless towers, antennas, and accessory structures. Specifically, the Zoning Code Update project included revisions to these regulatory standards which went into effect on January 1, 2025. At this time, the City Code permits a freestanding tower up to 150-ft in height by Conditional Use Permit in all Base Zoning Districts, with a preference for certain land use areas. One of the preferred land use areas includes municipal property or Public/Semi-Public uses. The applicant has requested a Conditional Use Permit for this wireless tower under these provisions as outlined in the "Wireless Antennas, Towers, and Accessory Structures" section of City Code, which has been pulled as an excerpt and attached to this report. The City Council approved an Option and Lease Agreement with The Towes, LLC at their regular City Council meeting on February 4, 2026. This agreement authorized the applicant to apply for the Conditional Use Permit which would be required prior to commencement with the project. Analysis: Proposed Use The proposed facility consists of a galvanized steel monopole tower with a structural height of 145-ft, with a lightning rod increasing the overall height to 149-ft. The base of the tower will be within a fenced in compound area, with associated ground-mounted equipment. Verizon Wireless is a partner to The Towers LLC and the primary carrier of the tower, but there would be capacity for additional carriers to co-locate in the future (three total carriers). The applicant has stated that Verizon has identified a significant service capacity gap in their wireless communications network, which cannot be resolved unless a communications tower is constructed within the identified service gap area. The intent of the application is to improve wireless coverage for Mendota Heights residents and business, as well as improved service Page 55 of 473 for emergency response personnel and other City staffmembers. The subject site was selected due to its ability to address documented coverage and capacity needs, while also being located on a preferred land use area: municipal property and Public/Semi-Public property. The Radio Frequency Engineer for the applicant group has identified that the proposed location is optimal because it will allow the cell carrier to cover a substantial area with the single tower. The location is also ideal due to its ground elevation of 885-ft, which when combined with the proposed tower height would increase the ability to provide stronger service within the surrounding topography. The City Code classifies this use as a freestanding wireless tower and it is a listed Conditional Use in all Base Zoning Districts, subject to applicable zoning standards. The proposed location is compliant with the setbacks for a structure in the base zoning district. The underlying R-1 district setbacks are 30-ft for front yard, 10-ft for side yard, and 30-ft for rear yard. The location of the 50-ft x 50-ft site area will exceed each of those setback requirements, located approximately 270-ft from the front property line (facing Wentworth Avenue), 34-ft from the side property line to the west, and 236-ft to the north (rear) lot line. Additionally, the compound area would be over 350-ft setback from the nearest three residential principal structures to the south, west, and north, exceeding the ordinance requirement of 200-ft. The excerpt from the site plan shown on the next page illustrates the location of the 50-ft x 50-ft compound area in comparison to the drive aisle entrance to Wentworth Park. City Code maintains performance and regulatory standards for freestanding antennas and towers including provisions for aesthetics, safety, accessory equipment and/or structures, and architecture. The applicant’s Narrative Letter has been included as an attachment to this report and indicates the applicants’ acknowledgement of and response to the performance standards Page 56 of 473 required for wireless towers. In addition to the site and construction plans required for all Conditional Use Permit applications, the applicant was also required to submit supplemental information to the City including coverage capacity analysis and visual impact demonstrations which have been included as an attachment to this report. Following a request for additional information at the March 31st meeting, the applicant has also provided documentation related to their site search to emphasize the benefit of the proposed location. This document, entitled “Site Search and Zoning Walk Through” illustrates the location of existing towers with the City and surrounding municipalities, as well as existing Verizon sites. The applicant has indicated that although there are existing towers in the general area outside of the search radius, there were none available that would have resulted in increased coverage at the level needed for Verizon to remedy the service gap. The applicant has also stated that no existing buildings within the search area would have been suitable from an engineering standpoint to fulfill the network need for the service gap area. Aesthetics requirements for the proposed monopole include a standard of color, requiring that all portions of a freestanding tower be painted eggshell. The applicant has indicated that their first preference is for a galvanized finish on the structure, but had stated if any painting is required they will comply. There is a condition included in the recommendations section of this report that the tower be painted eggshell in accordance with this standard. Other aesthetic standards required for the monopole include requirements for the accessory building for the tower to be screened from public view by a landscape plan. This information has been submitted to the City. The compound for the tower and associated ground equipment will be within a fenced area surrounded by evergreen plantings (Black Hills Spruce) for immediate screening. The tower itself as well as the ground-based components are not architecturally significant structures. The compound area is designed for function and will include accessory equipment within outdoor cabinets surrounded by fencing; then, the fencing will be surrounded by landscaping to soften the visual impact at the street and ground level. The layout of the fenced compound with carrier equipment is illustrated on the enlarged site plan, sheet “A-2” attached to this report. Also in the applicant’s construction documents, is an illustration of the elevation of carrier ground equipment on Sheet “VZW A-3”. The surrounding evergreen trees will increase the screening of the carrier equipment and generator’s height. From other areas of the park the tower will be partially screened by existing mature trees, dependent on location. The tower itself will be most visible from the south drive aisle and parking lot entrance to Wentworth Park. City Code includes a prohibition of advertising on the tower or accessory structure, and for artificial lighting to be prohibited excluding the minimum required by state or federal regulatory bodies. The applicant has confirmed that there will be no advertising of any kind at the facility. The only signage on the structure would be safety and identification signage, which are illustrated on sheet “A-6” in the construction documents. There would be no artificial lighting except for that which is required by the FCC/FAA. The applicant has submitted a letter from the FAA confirming that no lighting would be required for this proposal. Below is a graphic illustrating the elevation of the tower height of 145-ft, with the total height of 149-ft when including the lightning rod. The graphic shows how Verizon will be the primary carrier at the top slot of the monopole, and there will be available space for two additional carriers to come forward in the future. Page 57 of 473 Conditional Use Permit Pursuant to Title 12-5B-5, the city recognizes that the development and execution of the Zoning Code is based upon the division of the city into districts within which regulations are specified. It is further recognized that there are special or conditional uses which, because of their unique characteristics, cannot be properly classified in any district or districts without consideration, in each case, of the impact of those uses on neighboring land or the public need for the particular location. To provide for these needs, the city may approve a conditional use for those uses and purposes, and may impose conditions and safeguards in such permits to ensure that the purpose and intent of this chapter is effectively carried out. The City may grant a conditional use provided the proposed use demonstrates the following: a. Use will not be detrimental to the health, safety or general welfare of the community, b. Use will not cause serious traffic congestion nor hazards, c. Use will not seriously depreciate surrounding property value, and Page 58 of 473 d. Use is in harmony with the general purpose and intent of this chapter and the comprehensive plan. A-C) The proposed use will not be detrimental to the health, safety or general welfare of the community; will not cause serious traffic congestion or hazards; nor depreciate surrounding property value. Staff Response: The City has received numerous reports of a lack of consistent cellular coverage in Mendota Heights, particularly in the northern area of the City’s boundaries. The proposal would allow for improvements on this issue to residents, and the wireless tower would be available for co-location by other carriers in the future if approved. The location of a wireless tower and telecommunications facility would not be staffed, so the proposed use would not increase traffic to Wentworth Park or add to the existing traffic patterns in the surrounding area. There is no evidence that the proposed use would have an impact on the depreciation of surrounding property value in the surrounding market. The applicant has provided a Value Impact Study (attached) as supplemental information to the application to demonstrate that the proposed cell tower development would not measurably impact the value of surrounding properties. The applicant notes that improved wireless infrastructure supports public safety, particularly given the increasing reliance on mobile devices for emergency communications. The proposed tower is designed to enhance network reliability and capacity without creating adverse impacts on surrounding properties. Radiofrequency emissions are regulated by the Federal Communications Commission (FCC), and applicants are required to comply with all applicable federal standards. D) The use is in harmony with the general purpose and intent of this chapter and the Comprehensive Plan. Staff Response: The purpose of the “Wireless Antennas, Towers, and Accessory Structures” section of the City Code is to: To protect the public health, safety and general welfare of the community while accommodating the communication needs of residents and businesses, the City Council finds that this Section is necessary to: 1. Avoid potential damage to adjacent properties and personal injury from tower collapse through structural standards and setback requirements. 2. Protect the aesthetic qualities of the community by requiring tower and antenna equipment to be designed in a manner to blend in with the surroundings and complement existing structures. 3. Maximize the use of existing and approved freestanding antenna towers, buildings, and existing light poles for new wireless telecommunication antennas. 4. Minimize the number of freestanding antenna towers needed to serve the community by requiring co-location. 5. Facilitate the provision of wireless telecommunication services to the residents and businesses of the City. 6. Ensure that a competitive and broad range of telecommunications services and high- quality telecommunications infrastructure are provided to serve the community, as well as serve an important and effective part of the city’s emergency response network. 7. Place telecommunication facilities in suitable locations, with residential locations being a last resort. The proposed use will be located on a municipal property, and is located within the Public/Semi-Public Overlay district, which are both preferred land use areas under this section Page 59 of 473 of City Code. The construction of a freestanding tower is permitted in the ordinance by Conditional Use Permit, and the approval of this proposal would accomplish items (5) and (6) above, to facilitate the provision of wireless telecommunication services to residents and businesses within the City, and ensuring that high-quality telecommunications infrastructure is provided to serve the community. The construction of the tower would also aid in the effort to accomplish item (4), by constructing a tower with space for three total carriers to co-locate on in the future. The proposed wireless monopole is compliant with setback requirements and includes screening measures to minimize the visual impact where possible. The application, with the inclusion of the suggested conditions of approval, is consistent with the general purpose and intent of City Code and the Comprehensive Plan. Alternatives: 1. Approve the CUP request for a new wireless monopole tower based on the findings-of- fact that the proposed project is compliant with the purpose and intent of the zoning ordinance and Comprehensive Plan, with certain conditions; or 2. Deny the CUP request for a new wireless monopole tower, based on revised or amended findings-of- fact that the application does not meet certain policies and standards of City Code as determined by the Planning Commission; or 3. Table the request and request additional information from staff and/or the applicant; The City's 120-day review deadline for this application is June 27, 2026. Staff Recommendation: Staff recommends that the Planning Commission recommend approval of the requested Conditional Use Permit (CUP) by The Towers LLC for the property at 739 Wentworth Avenue, with the following conditions: 1. A building permit, including all new site grading, utility, and drainage work, must be approved by the City prior to any construction beginning on site. 2. The Developer/Applicant shall submit final grading, utility, and site plans, and architectural construction drawings for permitting, subject to review and approval by the Planning Department and Engineering Department as part of any building permit application. 3. All new construction and grading activities throughout this development site and on each new buildable lot shall be in compliance with all applicable federal, state, and local regulations and codes, as well as in compliance with the City’s Land Disturbance Guidance Document. 4. The maximum tower height shall not exceed 149-ft unless otherwise approved. 5. Landscaping and screening shall be installed as illustrated on the provided plans, dated 2/26/26. 6. All antennas, freestanding antenna towers, and accessory structures shall conform to all building and electrical codes. 7. The proposed freestanding monopole tower shall be painted eggshell in accordance with the design guidelines of the “Wireless Antennas, Towers, and Accessory Structures” ordinance. 8. Advertising of any kind is not permitted on any freestanding antenna tower, antenna, or accessory structure. 9. Artificial lighting of any kind is not permitted on any freestanding antenna tower, antenna, or accessory structure unless such lighting is required by the FCC, the FAA, or another federal or state regulatory body. 10. Structures, functions, uses or activities that are not found by the City to be specifically Page 60 of 473 necessary for the proper functioning of the antennas are prohibited on any antenna or tower without express permission from the City and the City grants a waiver to this requirement. Attachments: 1. Findings of Fact for Approval 2. Site Location Map 3. Cover Letter and Zoning Narrative 4. Map of Adjacent Buildings within 350' of Subject Parcel 5. The Towers LLC Construction Plans, dated 2/26/26 6. Cover Letter and Supplemental Letter, dated 4/23/26 7. Statement of Network Need and Service Maps, dated 4/14/26 8. Photo Simulation/Graphics, dated 4/3/26 9. Value Impact Study, dated 4/21/26 10. Site Search and Zoning Walk-Through, dated 4/23/26 11. Public Comments as of 4/23/26 12. FAA Letter, dated 3/6/26 13. Wireless Towers Ordinance Page 61 of 473 Planning Case 2026-05 (CUP for The Towers LLC) Page 1 of 1 FINDINGS-OF-FACT FOR APPROVAL CUP – Conditional Use Permit for The Towers LLC at 739 Wentworth Avenue (Wentworth Park) The following Findings of Fact are made in support of approval of the proposed requests: 1. The proposed freestanding wireless monopole tower use will not be detrimental to the health, safety or general welfare of the community, nor will cause serious traffic congestion nor hazards, nor depreciate surrounding property values. 2. The proposed freestanding wireless monopole tower use conforms to the general purpose and intent of this code and comprehensive plan, including all applicable performance standards laid out in 12- 3B-5B.7, provided all conditions are met and upheld by the property owner and applicant. 3. With the approval of the freestanding wireless monopole tower and associated conditions of approval, the site will provide needed cellular infrastructure into the community and will benefit the City by addressing documented service needs, allowing for future colocation of carriers, incorporating design and screening measures to minimize visual impacts to surrounding properties, and providing additional coverage to residents and emergency services personnel within the City of Mendota Heights. Page 62 of 473 6666666666* * * ³ ³ *666 66666666666666666666666!!2!!2!!2!!2!!2!!2!!2 !!2 !!2 !!2 !!2 !!2 !!2 !!2 !!2 !!2 !!2 !!2 755 739 723 740 694724728734720716702710768 750 766 760 751 754 730 770 769 768 760 757763 762 1472 713 1480 1627 1623 709 1635 774 1465 1527 1521 1515 688 716 1501 773 774 741 723 721 72916287351631 717 1464 747 721 WENTWORTH AV E U P P E R C O L O N IA L D RCHERRY HI LL RDNearmap U S Inc, Dakota County, MN Sit e Location/Aerial Map739 Wentworth Avenue Date: 3/27/2026 City ofMendotaHeights0210 SCALE IN FEET GIS Map Disclaimer:This data is for informational purposes only and should not be substituted for a true title search, property appraisal, plat,survey, or for zoning verification. The City of Mendota Heights assumes no legal responsibility for the information containedin this data. The City of Mendota Heights, or any other entity from which data was obtained, assumes no liability for any errorsor omissions herein. If discrepancies are found, please contact the City of Mendota Heights. Contact "Gopher State One Call" at 651-454-0002 for utility locations, 48 hours prior to any excavation. Page 63 of 473 BUELL CONSULTING, INC. 9973 Valley View Rd Eden Prairie, MN 55118 (651) 361-8110 www.buellconsulting.com Friday, February 27, 2026 City of Mendota Heights Attn: Sarah Madden 1101 Victoria Curve Mendota Heights, MN 55118 RE: CUP Application for New Tower Site – The Towers LLC Reference: US-MN-5418 BLOWFISH Property Address: 739 Wentworth Ave Dakota County PID: 27-03800-34-010 Dear Ms. Madden, Planning Commission Members, and City Council Members, On behalf of The Towers, LLC, Buell Consulting, Inc. hereby submits a Conditional Use Application for a new Wireless Tower site on Wentworth Park property owned by the City of Mendota Heights. Enclosed with this letter are the following items: • Two fee checks in the amounts of $500 (CUP Commercial Fee), and $500 (Escrow) • Zoning Narrative (see immediately-following pages) explaining how our proposed project complies with the City of Mendota Heights Zoning Ordinance • Planning Application form completed and signed by me on behalf of the applicant, The Towers LLC • Conditional Use Permit Application Checklist - Completed • RF Statement and Map from Verizon Wireless • Photo simulations including three views • Site Plans by Design 1 of Eden Prairie and Herzog Engineering dated 2/27/2026 Please do not hesitate to call for any clarifications or additional questions related to any of the CUP application materials. So that we can monitor various internal and external deadlines, please confirm that this application is complete or, if it is not complete, please provide a detailed description of the required information that is incomplete. Sincerely, Scott Buell Site Development Agent on behalf of The Towers, LLC Phone: 651-225-0793 Email: sbuell@buellconsulting.com Encl. Page 64 of 473 Zoning Narrative | Page 1 of 7 Zoning Narrative Conditional Use Permit Application for a New Communication Tower Dakota County PID 27-03800-34-010 Property address: 739 Wentworth Ave This zoning narrative is included to state how our application complies with the City of Mendota Heights Zoning Ordinance (cited ordinance language is in blue italics, our responses are in normal font). Communication Tower Use: Our proposed use is located on a parcel zoned as R-1 Low Density Residential, and within the Public/Semi-Public (PSP) overlay district. The proposed Wireless Telecommunications Facility is comprised of a 145’ monopole tower within a 50’x50’ fenced and screened ground space. According to Section 12-3B-1 Table of Uses in the City’s ordinance, our proposed use is allowed with a CUP provided we comply with Section 12-3B-5 B.7, which is the section for wireless antennas and towers. Section 12-3B-5 B.7 states that towers are a conditional use in any district. We are therefore requesting that the City approve a Conditional Use Permit for our proposed facility. Performance Standards for the Proposed Tower Use: Per Section 12-3B-5 B.7 Wireless Antennas, Towers, and Accessory Structures: d. Freestanding Antennas and Towers. (1) Location limitations. The location of any antenna support structure on a particular parcel of land shall be located to have the least impact possible on adjoining properties, and so that any negative impacts of the antenna support structure shall be confined as much as possible to the property on which the antenna support structure is located. We’ve tried to locate this site so it’s not directly in line of sight of any neighbors as much as we can, without impacting the flow of park visitors on the parcel. We believe the proposed location will have the lease negative impact possible for park goers and the surrounding neighborhood. (2) Height. The maximum height of a freestanding antenna tower is 150-feet, as measured from the ground to the highest point of any portion of the tower, antenna, or any other component attached thereto, or the distance between the base of the antenna tower and the nearest setback line, whichever is least. The proposed height of the tower is 145’, and with a lightning rod at the top, the total overall height will be 149’, just below the 150’ height limit, so we comply with this requirement. (3) Setbacks. All freestanding antenna towers and accessory structures must adhere to all appropriate setbacks for the Base Zoning District of the property on which the structure is located. (A) Antenna support structures between 75-feet and 150-feet tall shall not be constructed within 200 feet of any residential principal structure. (B) Notwithstanding (A), if an antenna support structure is located on the same parcel of land as a residential structure, the setback to that residential structure may be equal to the height of the antenna support structure plus 15 feet. The underlying district setbacks are 30’ for front yard, 10’ for side yard, and 30’ for rear yard. We exceed each of these setbacks with our location as shown on the site plans included with this application. The edges of our 50’x50’ site area is about 270’ back from the front property line (southern line), and about 34’ from the side property line (west line). Page 65 of 473 Zoning Narrative | Page 2 of 7 Additionally, we are about 400’ from the nearest three residential principal structures to the south, west, and north. There is not a residential structure on the subject parcel. e. Preferences for antenna and support structure locations. When selecting sites for the construction of new antenna support structures and/or for the placement of new antennas, the following preferences shall be followed: (1) Preferred Land Use Areas. (A) Property in the B-1, B-2 or Industrial Zoning District. (B) Athletic complexes, municipal property or Public/Semi-Public uses. (C) Parking lots, if the monopole replicates, incorporates or substantially blends in with the overall lighting standards of the lot. (D) Within the easement of a high-power overhead transmission line, or within 50 feet of the transmission line easement on the same side of the road. (2) Alternate land use areas. (A) Public parks or open spaces. (B) Golf courses. (C) Residential area. (3) Preferred Support Structures. (A) Water towers (B) Co-location on existing antenna support structures. (C) Church steeples. (D) Sides of buildings over two stories high. (E) Existing power, lighting or phone poles. (4) Prohibitions. (A) No new support structures shall be approved at any location other than a Preferred Land Use Area, unless the applicant shows to the reasonable satisfaction of the city that such locations are not feasible from an engineering standpoint. (B) No new support structures shall be approved for construction, unless the applicant shows to the reasonable satisfaction of the city that a preferred support structure is not feasibly available for use from an engineering standpoint. Our proposed project is located in the second-most preferred land use area, which is on a municipal property which also categorized as a Public/Semi-Public use property as well as a public park. There were no business or industrial districts anywhere near the area where we need the network improved. There are no existing support structures we could use to provide the network coverage needed in this area. f. Aesthetics. (1) Design. All freestanding antenna towers shall be of a monopole type design. The use of guyed towers is prohibited. Our proposed facility will include a monopole tower. (2) Color. (A) Those portions of all freestanding antenna towers and all antennas which protrude into the air shall be painted eggshell. (B) Those portions of all antennas that are flush mounted to the sides of buildings shall be painted to match the exterior of the building. We propose that a galvanized finish on the steel structures and the manufacturer’s gray color on the radio and antenna equipment be left unpainted. We’ve found that galvanized steel does the best job of Page 66 of 473 Zoning Narrative | Page 3 of 7 reflecting the sky and surroundings, whereas painted surfaces stand out more than necessary. Furthermore, unpainted surfaces weather the best, whereas painted surfaces need to be repainted. If painting of any of our proposed structure is required, please provide paint color code so we can comply. (3) Screening. All accessory buildings to all freestanding towers shall be screened from public view by a landscape plan according to the landscape standards of the applicable Base Zoning District and as described in [Section 12- 4A-5 ] of this article subject to City Council review. We’ve proposed plantings in the landscape plan included with our site plans made part of this application. Those plantings will screen the fenced compound and it’s equipment on the ground. The tower will be partially screened by existing mature trees as shown on the photo simulations. (4) Advertising. Advertising of any kind is not permitted on any freestanding antenna tower, antenna, or accessory structure. There will be no advertising of any kind at this facility. There will only be safety and identification signage. (5) Lighting. Artificial lighting of any kind is not permitted on any freestanding antenna tower, antenna, or accessory structure unless such lighting is required by the FCC, the FAA, or another federal or state regulatory body. If such a requirement exists, only the minimum amount of lighting required is allowed. There will be no artificial lighting except that which might be required by the FCC/FAA. (6) Prohibitions. Structures, functions, uses or activities that are not found by the City to be specifically necessary for the proper functioning of the antennas are prohibited on any antenna or tower without express permission from the City and the City grants a waiver to this requirement. We will comply with the City with respect to this subsection as needed. g. Safety. (1) Report of Compliance. For a freestanding antenna tower, the applicant must provide a report from a licensed qualified professional structural engineer certifying that the tower will meet or exceed current EIA/TIA-222-E standards including, but not limited to, standards for withstanding meteorological conditions such as high winds and radial ice. We do not yet have the tower drawings from the tower manufacturer, but will provide them prior to construction. We ask that the City approve our CUP and add this requirement as a condition of approval. (2) Compliance with Building and Electrical Codes. All antennas, freestanding antenna towers, and accessory structures shall conform to all building and electrical codes. We will comply with all building and electrical codes. (3) Fencing. The applicant may be required by the City Council to erect a security fence around any freestanding antenna. See the enclosed site plans submitted with this application. We will install a 6’-tall black-vinyl-costed chain link fence (at the request of Public Works to minimize the visual effect of the fence) and without barbed wire. Page 67 of 473 Zoning Narrative | Page 4 of 7 h. Accessory Structures for Antennas. (1) Location and General Requirements. Accessory buildings to antennas or freestanding antenna towers must comply with all applicable setbacks from all property lines and must otherwise conform to all requirements for accessory buildings within the description of the Base Zoning District on which the structure is located. The entirety of our proposed project will be outside of the required underlying district setbacks. i. Architecture. (1) Accessory structures and equipment buildings shall be designed to be architecturally compatible with any principal structures on the site or, in the absence of such structures, with their immediate surroundings in an aesthetically pleasing manner. (2) Accessory structures must be finished on all sides. (3) The Planning Commission must review, and the City Council shall approve, the design of any accessory structures and equipment buildings. A tower, its components, attachments, and ground-based equipment do not have much architectural merit, so we used placement and landscaping to soften the visual impact. And, monopole’s are the cleanest design. The accessory equipment will be in the form of outdoor cabinets within a fenced area at the base of the tower, and the entire fenced area will be screened by new plantings around the base. D. Additional Requirements. 1. Abandoned Structures. a. Removal Required. Unused or obsolete freestanding antenna towers, antennas, structures or apparatus must be removed within six (6) months of when the operation ceases. b. Bond. A successful applicant shall provide an abandonment bond to the City equal to one and a half (1 1/2) times the current cost of removal and disposal of all antennas and accompanying apparatus as estimated by a consultant selected by the City and paid for by the applicant, which bond shall be used by the City to remove the antennas and apparatus should they become unused or obsolete and the applicant or its successors or assigns become disbarred or otherwise fail to remove said antennas and apparatus. The agreement between The Towers LLC and the City of Mendota Heights already has removal requirements in it, so there exists a contractual obligation by The Towers LLC to remove the tower. If the City still required a bond to be in place, too, we ask that such requirement be included as a condition of approval, and we will provide said bond before construction starts. 2. No new antenna support structures shall be constructed if it is feasible to locate the proposed new antenna on existing support structures. Feasibility shall be determined according to generally accepted engineering principles. If a new antenna support structure is to be constructed, it shall be designed structurally to accommodate both the applicant’s antennas and comparable antennas for at least two additional users if the antenna support structure is 75-feet or more. Any antenna support structure must also be designed to allow for future rearrangement of antennas upon the tower and to accept antennas mounted at different heights. Other users shall include, but not be limited to, other cellular communication companies, personal communication systems companies, local police, fire and ambulance companies. As stated earlier in this narrative, there are no existing structures in the area, so this is a new support structure. It is designed to hold three total users as required, and as shown on the site plans enclosed with this application. Page 68 of 473 Zoning Narrative | Page 5 of 7 3. Other Required Licenses. The applicant must submit proof of any applicable federal, state, or local licenses to the City prior to receiving a building permit. We will adhere to this requirement, however, please specify which such licenses the City wants us to share. 4. Interference with Public Safety Systems Prohibited. The applicant must agree in writing to support, participate in and refrain from interfering with public warning systems and public safety communications and other radio frequencies as may be regulated by the Federal Communications Commission (FCC). The Towers, LLC hereby agrees to support, participate in and refrain from interfering with public warning systems and public safety communications and other radio frequencies as may be regulated by the Federal Communications Commission (FCC). 5. Compliance with FCC Regulations; Noninterference Required. All new or existing telecommunications service and equipment shall meet or exceed all Federal Communications Commission (FCC) standards and regulations and shall not interfere with any other communications, computers, laboratory equipment or manufacturing equipment, including television and other home electronics. The applicant shall provide to the City a report from a qualified professional engineer guaranteeing noninterference and a copy of the FCC approval of the antenna in regard to noninterference. The Towers, LLC hereby asserts that the telecommunications service and equipment at this proposed site will meet or exceed all Federal Communications Commission (FCC) standards and regulations. Please advise whether this statement suffices or if a more formal letter or report is required to fulfill this section/requirement. a. Environmental Impact Statement (EIS). In the event that the FCC or other agency or other governmental body having jurisdiction requires the applicant to submit an Environmental Impact Statement or similar document, a copy of this document shall be submitted to the City. We will share any such report if one becomes required by the FCC or other agency. Zoning and CUP Application Requirements: Per Section 12-3B-5 B.7 Wireless Antennas, Towers, and Accessory Structures C. Submission Requirements. 1. Initial Application Requirements. In addition to the information required for a Conditional Use Permit or Administrative Permit, the following additional information must be supplied by the Applicant and a qualified, licensed registered professional engineer: a. Description of the tower height and design, including a cross-section, elevation and site elevation. Included on the enclosed site plans. b. Documentation of the height above grade for all potential mounting positions for co-located antennas and the minimum separation distances between antennas. Included on the enclosed site plans. c. Description of the tower’s capacity, including the number and type of antennas that it can accommodate. Page 69 of 473 Zoning Narrative | Page 6 of 7 Included on the enclosed site plans. The tower and ground space will have space for three tenants. d. Coverage Capacity Analysis. Coverage map and or analysis that demonstrates that no other support structures, or if applicable Preferred Land Use Areas, are available to meet coverage demand. The applicant shall demonstrate, by providing a coverage/interference analysis and capacity analysis, that the location and height of any freestanding antenna tower or antenna as proposed is necessary to meet the communication, frequency reuse and spacing needs of the communication services system, and to provide adequate coverage and capacity to areas that cannot be adequately served by locating the towers in a less restrictive district or on an existing structure, freestanding antenna tower or antenna including such in neighboring municipalities. See enclosed RF statement and map. e. Area Map. All applications for either a freestanding antenna, a freestanding antenna tower, or a building mounted antenna shall be accompanied by a map of all existing towers and antennas of the same provider within a two (2) mile radius of the proposed site and all future planned antennas of the same provider for the next five (5) years within a two (2) mile radius of the proposed site. See enclosed RF statement and map. f. Inclusion of the engineer’s stamp and registration number. See enclosed RF statement and map. This is a Verizon employee with RF expertise. g. The city, at its reasonable discretion, may require visual impact demonstrations including mock-ups and/or photo simulations that provide an accurate visual depiction of the tower. See enclosed photo simulations showing views from three areas near the subject parcel. h. A written description of the type of technology each company/carrier will provide to its customers. See enclosed RF statement and map. i. A listing of all existing, existing to be upgraded or replaced, and proposed communication sites within the city and within five miles of the city for these services. See enclosed RF statement and map. j. An electronic, to-scale copy of a map of the city showing the five-year plan for communication sites, or if individual properties are not known, the geographic service areas of the communication sites. Any existing tower locations must be clearly identified. See enclosed RF statement and map. Note Verizon’s and The Towers LLC’s strategic growth plans are proprietary and confidential, so what we’ve provided is what we are comfortable sharing. Page 70 of 473 Zoning Narrative | Page 7 of 7 Conditional Use Permit Application Criteria for Approval: Per Section 12-5B-5 E.1 and the CUP Checklist: a) The proposed use will not be detrimental to the health, safety or general welfare of the community; The proposed use will not be detrimental to the health, safety or general welfare of the community. Rather, this proposed use will enable an improved network that will allow for more reliable general and emergency communications in the surrounding neighborhoods, which is something that’s been seriously lacking for years. b) the proposed use will not cause serious traffic congestion nor hazards; The proposed use consists of an unmanned facility that will not be a source of traffic or other hazards. During construction, there will be congestion at the site, but once built, this will be a quiet facility with very few visits except during equipment modification or installation activities which do not happen often. c) the proposed use will not seriously depreciate surrounding property value; and The proposed use will not depreciate surrounding property value. Rather, tower sites have been shown to have no effect, or a slight positive effect on property values. Most home buyers want to know that wireless network reliability is present in the area. This site will enable that. d) the proposed use is in harmony with the general purpose and intent of the City Code and the comprehensive plan. The proposed use is in harmony with the general purpose and intent of the City Code and the comprehensive plan. Indeed, wireless network improvement and reliability is part of the City’s strategic plan and goals, and with the revised ordinance, has enabled this project to successfully come to fruition. Thank you for considering our proposed Conditional Use Permit Application and Submittal Package for The Towers LLC’s proposed tower facility. We believe we satisfy the requirements for a CUP to be approved for our proposed facility, and we welcome any questions and comments as you review this application. Please feel free to call me with any questions. Sincerely, Scott Buell, Site Development Agent on Behalf of The Towers, LLC Buell Consulting, Inc. sbuell@buellconsulting.com Direct: 651-225-0793 Page 71 of 473 Map of Buildings within 350’ of Subject Parcel Yellow Outline = Approximate 350’ Distance from Subject Parcel Purple Stars = Buildings IdenƟfied as Being within 350’ of Subject Parcel List of house numbers shown on above map: 750 Upper Colonial Drive 754 Upper Colonial Drive 760 Upper Colonial Drive 766 Upper Colonial Drive 755 Wentworth Ave 760 Wentworth Ave 755 Wentworth Ave 1623 Pamela Ln 740 Wentworth Ave 734 Wentworth Ave 730 Wentworth Ave 728 Wentworth Ave 724 Wentworth Ave 720 Wentworth Ave 716 Wentworth Ave 710 Wentworth Ave 713 Wentworth Ave Page 72 of 473 SHEET CONTENTS:NORTHVICINITY MAPPROJECT INFORMATIONPROJECT DRAWN BY:CHECKED BY:US-MN-5418BLOWFISH739 WENTWORTH AVEMENDOTA HEIGHTS, MN55118US-MN-5418FUZE ID: 17425846T-19973 VALLEY VIEW RD.EDEN PRAIRIE, MN 55344(952) 903-9299DESIGNWWW.DESIGN1EP.COMNOT FORCONSTRUCTIONPREPARED FOR:THE TOWERS, LLC 22 WEST ATLANTIC AVENUE, SUITE 310 DELRAY BEACH, FL 33444TLSSJDREV. A02-27-26CONTACTSCONTACTSDRAWING APPROVALSJOB TITLENAMEDATEVERTICAL BRIDGERF ENGINEERCONSTRUCTION ENGINEERTRANSPORT ENGINEEREQUIPMENT ENGINEERREAL ESTATE SPECIALISTISSUE SUMMARYREVDESCRIPTIONSHEET/DETAILAISSUED FOR REVIEWALLMENDOTA HEIGHTS, MN 55118739 WENTWORTH AVE145' MONOPOLEUS-MN-5418CITY OF MENDOTA HEIGHTS1101 VICTORIA CURVEMEDNOTA HEIGHTS 55118RYAN RUZEK (651) 255-1152BLOWFISHSHEET INDEXPROJECT DESCRIPTIONSCODE COMPLIANCEVICINITY MAPPROJECT INFORMATIONDRAWING APPROVALSCONTACTSISSUE SUMMARYPROPERTY OWNER:XCEL ENERGY(800) 628-2121POWER UTILITYCOMPANY CONTACT:COMPANY CONTACT:TELCO UTILITYDESIGNER:LESSOR / LICENSOR:LESSEE:THE TOWERS, LLC22 WEST ATLANTIC AVENUE, SUITE 310DELRAY BEACH, FL 33444(404) 862-4089BUELL CONSULTING, INC.720 MAIN ST, SUITE 200ST. PAUL, MN 55118SITEACQUISITION:(TOWER):STRUCTURAL ENGINEERTBDDESIGN 1 OF EDEN PRARIE9973 VALLEY VIEW ROADEDEN PRAIRIE, MN 55344(952) 903-9299VERTICAL BRIDGE SITE NUMBER:VERTICAL BRIDGE SITE NAME:VERIZON SITE NAME:VERIZON MDG:VERIZON FUZE PROJECT ID:SITE ADDRESS:COUNTY:LATITUDE (DECIMAL):LONGITUDE (DECIMAL):LATITUDE (DMS):LONGITUDE (DMS):GROUND ELEVATION:STRUCTURE TYPE:STRUCTURE HEIGHT:OVERALL HEIGHT:RFDS FORM DATED:US-MN-5418BLOWFISHMIN BLOWFISH500096932717425846739 WENTWORTH AVEMENDOTA HEIGHTS, MN 55118DAKOTAN 44.898911°W 93.122304°N 44° 53' 56.08"W 93° 07' 20.30"885.4' AMSLMONOPOLE145' AGL149' AGL02-09-26THE TOWERS LLCSHEET INDEXSHEETSHEET DESCRIPTIONT-1:T-2PROJECT TITLE SHEET & GENERAL NOTES-SURVEYA-1:A-1.1OVERALL SITE PLAN, TOWER ELEVATION & LANDSCAPINGPLANA-2ENLARGED SITE PLANA-3SITE PREP & GRADING NOTES AND DETAILSA-4:A-5FENCE DETAILSA-6SIGN DETAILSA-7MISC. DETAILSA-8SITE PHOTOSG-1:G-3GROUNDING NOTES, PLAN, DETAILS AND UTILITY NOTESU-1:U-2SITE UTILITY PLANS, DETAILS AND NOTESVZW A-1VERIZON SITE PLANVZW A-2RFDS INFO, MOUNTING DETAIL AND ONE-LINE DIAGRAMVZW A-3CABINET AND BASE EQUIPMENT DETAILSVZW A-4CABLE ICE BRIDGE, GPS AND MISC. DETAILSVZW A-5GENERATOR DETAILSVZW G-1VERIZON GROUNDING PLANVZW G-2VERIZON GROUNDING DETAILS AND NOTESVZW U-1VERIZON UTILITY PLAN, DETAILS AND NOTESVZW U-2CONDUIT ROUTING PLAN AND ONE-LINE ELECTRIC DIAGRAMVERTICAL BRIDGEVERIZON 10801 BUSH LAKE ROADBLOOMINGTON, MN 55438CONSTRUCTION DEPT. (952) 946-4700SITE NAME: MIN BLOWFISHMDG: 5000969327FUZE PROJECT ID: 17425846VERIZON WIRELESS10801 BUSH LAKE ROADBLOOMINGTON, MN 55438CONSTRUCTION DEPT. (952) 946-4700T.B.D.ENGINEER:GEOTECHNICALT.B.D.1334 81ST AVE NESPRING LAKE PARK, MN 55432612-844-1234WWW.HERZOGENGINEERING.COMI HEREBY CERTIFY THAT THISPLAN, SPECIFICATION, OR REPORTWAS PREPARED BY ME OR UNDERMY DIRECT SUPERVISION ANDTHAT I AM A DULY LICENSEDPROFESSIONAL ENGINEER UNDERTHE LAWS OF THE STATE OFMINNESOTA.NAME:SIGNATURE:DATE:LICENSE NUMBER:Joshua Herzog4239202/27/2026HE #: 261101Page 73 of 473 PROJECT DRAWN BY:CHECKED BY:US-MN-5418BLOWFISH739 WENTWORTH AVEMENDOTA HEIGHTS, MN55118US-MN-5418FUZE ID: 17425846T-29973 VALLEY VIEW RD.EDEN PRAIRIE, MN 55344(952) 903-9299DESIGNWWW.DESIGN1EP.COMNOT FORCONSTRUCTIONPREPARED FOR:THE TOWERS, LLC 22 WEST ATLANTIC AVENUE, SUITE 310 DELRAY BEACH, FL 33444TLSSJDREV. A02-27-26SHEET CONTENTS:GENERAL NOTES1334 81ST AVE NESPRING LAKE PARK, MN 55432612-844-1234WWW.HERZOGENGINEERING.COMI HEREBY CERTIFY THAT THISPLAN, SPECIFICATION, OR REPORTWAS PREPARED BY ME OR UNDERMY DIRECT SUPERVISION ANDTHAT I AM A DULY LICENSEDPROFESSIONAL ENGINEER UNDERTHE LAWS OF THE STATE OFMINNESOTA.NAME:SIGNATURE:DATE:LICENSE NUMBER:Joshua Herzog4239202/27/2026HE #: 261101Page 74 of 473 SITE SURVEY FOR THE TOWERS, LLC SHEET 1 OF 2 SHEETS DESIGN No. FIELD WORK: 1/14/26CHECKED BY: SMK DRAWN BY: JMM DATE REVISION BY CHK APP'D SHAWN M. KUPCHO L.S.LIC. NO.: 49021DATE: 2/17/2026 I HEREBY CERTIFY TO: VERTICAL BRIDGE REIT, LLC, A DELAWARE LIMITED LIABILITY COMPANY, ITS SUBSIDIARIES, AND THEIR RESPECTIVE SUCCESSORS AND/OR ASSIGNS; ITS LENDERS, AND ADMINISTRATIVE AGENTS AND EACH OF THEIR RESPECTIVE SUCCESSORS AND/OR ASSIGNS, AND TOWER TITLE, LLC. CITY OF MENDOTA HEIGHTS FULL SCALE ON 22"X34" HALF SCALE ON 11"X17" PROPERTY OWNER: 27-03800-34-010 PARCEL NO: R-1 LOW DENSITY RESIDENTIAL ZONED: TITLE COMMITMENT NO. VTB-222161-C DEED REFERENCED: VERTICAL BRIDGE SITE NAME: BLOWFISH VERTICAL BRIDGE SITE NUMBER: US-MN-5418 SITE ADDRESS: 739 WENTWORTH AVENUE MENDOTA HEIGHTS, MINNESOTA 55118 I FURTHER CERTIFY THAT THIS DOCUMENT WAS PREPARED BY ME OR UNDER MY DIRECT SUPERVISION AND THAT I AM A DULY LICENSED LAND SURVEYOR UNDER THE LAWS OF THE STATE OF MINNESOTA. 2026-10299 PROPERTY DESCRIPTION: (per Warranty Deed Instrument No. 348426) Lot 34, Auditor’s Subdivision No. 3, Dakota County, Minnesota. SUBJECT TO THE FOLLOWING: (per Tower Title, LLC, Reference No. VTB-222192-C, dated October 7, 2025) 1.) Not related to survey. 2.) Rights or claims of parties in possession not shown by the public record. No known rights or claims of parties in possession. 3.) Easements or claims of easements not shown by the public record. No known easements or claims of easements have been provided that are not shown by public record. 4.) Discrepancies, conflicts in boundary lines, encroachments, overlaps, variations or shortage in area or content, party walls and any other manners that would be disclosed by a correct survey and/or physical inspection of the land. A complete survey, inspecting all of the boundary lines and examining adjacent property descriptions was not performed for the purposes of this survey. Encroachments located for the purposes of this site survey are as shown on the survey. 5-9.) Not related to survey. 10.) Any and all matters disclosed on the map entitled “Plat Map” dated April 18, 1906 and recorded April 18, 1906 in, (instrument) 51282 in Dakota County, Minnesota. The plat of AUDITOR’S SUBDIVISION NO. 3 is as shown on the survey. The subject property is Lot 34, AUDITOR’S SUBDIVISION NO. 3. 11.) Declaration of Restrictions dated January 6, 2021 and recorded January 6, 2021 in (instrument) 3428019, in Dakota County, Minnesota. This document describes a funding restriction and this document is not related to the survey. 12.) Notice of Funding Restrictions for Went Worth Park Property dated January 6, 2021 and recorded January 6, 2021 in (instrument) 3428019, in Dakota County, Minnesota. This funding restriction for Wentworth Park is not related to the survey. 1 2/23/26 REVISED LEASE AND EASEMENT AREA AND REVISE DESCRIPTIONSSMKNTG SMK LEASE AREA DESCRIPTION: That part of Lot 34, AUDITOR’S SUBDIVISION NO. 3, Dakota County, Minnesota, described as follows: Commencing at the Southwest corner of the Northwest Quarter of Section 24, Township 28, Range 23, said Dakota County; thence North 89 degrees 43 minutes 15 seconds East, assumed bearing, along the South line of said Northwest Quarter, 1088.00 feet; thence North 00 degrees 16 minutes 45 seconds West, 300.00 feet to the Point of Beginning of the lease area to be described; thence South 89 degrees 43 minutes 15 seconds West, 50.00 feet; thence North 00 degrees 16 minutes 45 seconds West, 50.00 feet; thence North 89 degrees 43 minutes 15 seconds East; 50.00 feet; thence South 00 degrees 16 minutes 45 seconds East, 50.00 feet to the Point of Beginning. Said lease area contains 2,500 Sq. Ft. or 0.07 Acres. ACCESS AND UTILITY EASEMENT DESCRIPTION: A 30.00 foot wide easement for ingress, egress and utility purposes over, under and across Lot 34, AUDITOR’S SUBDIVISION NO. 3, Dakota County, Minnesota, the centerline of said easement described as follows: Commencing at the Southwest corner of the Northwest Quarter of Section 24, Township 28, Range 23, said Dakota County; thence North 89 degrees 43 minutes 15 seconds East, assumed bearing, along the South line of said Northwest Quarter, 1088.00 feet; thence North 00 degrees 16 minutes 45 seconds West, 300.00 feet; thence South 89 degrees 43 minutes 15 seconds West, 25.00 feet to the Point of Beginning of the centerline to be described; thence South 00 degrees 16 minutes 45 seconds East, 112.00 feet; thence South 35 degrees 00 minutes 00 seconds West; 8.14 feet; thence southwesterly, 138.54 feet along a tangential curve concave to the southeast, having a radius of 225.00 feet and a central angle of 35 degrees 16 minutes 45 seconds; thence South 00 degrees 16 minutes 45 seconds East, tangent to the last described curve, 21.41 feet to the north right of way line of Wentworth Avenue and said centerline there terminating. The sidelines of said easement shall be lengthened or shortened to terminate at said north right of way line of Wentworth Avenue. Said access and utility easement contains 8,404 Sq. Ft. ± or 0.19 Acres. Page 75 of 473 WENTWORTH AVENUE DODD ROADSTATE HIGHWAY NO. 149DELAWARE AVENUEMARIE AVENUEWACHTLER AVENUECOUNTY ROAD NO. 8COUNTY ROAD NO. 8 GAS GAS GAS GAS OHE OHE OHE OHE OHE OHE OHE OHE OHE OHE GAS GAS GAS GAS GAS GAS GAS GAS GAS GAS GAS UGTUGTUGTUGTUGTUGTUGTUGTUGTUGTUGT FOCFOCFOCFOCFOCFOCFOCFOCFOCFOCFOC WENTWORTH AVENUE COUNTY ROAD NO. 8 (PUBLIC RIGHT OF WAY) S WOODS EDGE OF ICE OUTLET STRUCTURE PICKLE BALL COURT PARK SIGNPARK ENTRANCET LOT 34879880881882883884886 887 887 884884885885886886887885 886 887 888 8898858 8 6 8 8 7 8 8 7 888 889 889 889 879 880 881 882883883881886 887 886886 885885885886887884885882880879879878877878880880879DAVID WILLIAMS PID NO. 270380033010 CITY OF MENDOTA HEIGHTS PID NO. 271715000023 CITY OF MENDOTA HEIGHTS PID NO. 278130000011 JOHN AND LINDA WIRT PID NO. 278130000043 1" OAK (PLANTED) 1" ASH (PLANTED) 9" CHERRY 5" MAPLE 18" TRIPLE BIRCH 20" TRIPLE BIRCH 14" ELM 1" LUCUST (PLANTED) 4" ASH23" M A PLE 38" DOUBLE ASH 1" ASH (PLANTED) 22" OAK 20" COTTONWOOD 16" ASH 9" SPRUCE12" SPRUCE1" BIRCH (PLANTED) 20" ASH 1" ASH (PLANTED) 40" MAPLE 1" BIRCH (PLANTED) 36" ASH 19" MAPLE13" DOUBLE PINE48" COTTONWOOD (X3) PARK SHELTER PARK SHELTER 8 8 6 NORTH RIGHT OF WAY LINE OF WENTWORTH AVENUE 3030303027" POPLAR 35" POPLAR 30" POPLAR 19" POPLAR N89°43'15"E 50.00 8 8 3 882881 879 S00°16'45"E50.00N00°16'45"W50.00S89°43'15"W 50.00 15 15 1 5 15 S35°00'00"W8.14S00°16'45"E21.41S00°16'45"E 112.0025.00 N00°16'45"W 300.004233.69N89°43'15"E 1088.00 --N89°43'15"E 5321.69--884883LEASE AREA Contains 2,500 Sq. Ft. or 0.06 Acres 30' WIDE ACCESS AND UTILITY EASEMENT CONTAINS 8,404 SQ. FT OR 0.19 ACRES882 884 885 PROPOSED TOWER CENTER: GROUND ELEVATION = 885.4NAVD88 LATITUDE = N44°53'56.08"NAVD83 LONGITUDE = W93°07'20.30"NAVD83 30' WIDE ACCESS AND UTILITY EASEMENT CONTAINS 8,404 SQ. FT OR 0.19 ACRES POINT OF BEGINNING OF LEASE AREA POINT OF BEGINNING OF 30' WIDE ACCESS AND UTILITY EASEMENT SOUTH LINE OF THE NW 1/4Δ=35°16'45"L=138.54R=225.0034.02 34.87 EAST QUARTER CORNER OFSEC. 24, TWP. 28, RNG. 23SOUTHWEST CORNER OF THENORTHWEST QUARTER OFSEC. 24, TWP. 28, RNG. 23N SITE SITE SURVEY FOR THE TOWERS, LLC 1"=1000' VICINITY MAP 0 SCALE IN FEET 30 60 N SHEET 2 OF 2 SHEETS DESIGN No. FIELD WORK: 1/14/26CHECKED BY: SMK DRAWN BY: JMM DATE REVISION BY CHK APP'D SHAWN M. KUPCHO L.S.LIC. NO.: 49021DATE: 2/17/2026 I HEREBY CERTIFY TO: VERTICAL BRIDGE REIT, LLC, A DELAWARE LIMITED LIABILITY COMPANY, ITS SUBSIDIARIES, AND THEIR RESPECTIVE SUCCESSORS AND/OR ASSIGNS; ITS LENDERS, AND ADMINISTRATIVE AGENTS AND EACH OF THEIR RESPECTIVE SUCCESSORS AND/OR ASSIGNS, AND TOWER TITLE, LLC. CITY OF MENDOTA HEIGHTS FULL SCALE ON 22"X34" HALF SCALE ON 11"X17" PROPERTY OWNER: 27-03800-34-010 PARCEL NO: R-1 LOW DENSITY RESIDENTIAL ZONED: TITLE COMMITMENT NO. VTB-222161-C DEED REFERENCED: VERTICAL BRIDGE SITE NAME: BLOWFISH VERTICAL BRIDGE SITE NUMBER: US-MN-5418 SITE ADDRESS: 739 WENTWORTH AVENUE MENDOTA HEIGHTS, MINNESOTA 55118 I FURTHER CERTIFY THAT THIS DOCUMENT WAS PREPARED BY ME OR UNDER MY DIRECT SUPERVISION AND THAT I AM A DULY LICENSED LAND SURVEYOR UNDER THE LAWS OF THE STATE OF MINNESOTA. 2026-10299 A DAKOTA COUNTY SECTION MONUMENT SIGN - SINGLE EDGE OF WOODS TREE - DECIDUOUS TREE - CONIFEROUS TELECOM PEDESTAL UNDERGROUND FIBER OPTIC LINEFOC UNDERGROUND TELEPHONE LINEUGT T MAJOR CONTOURS MINOR CONTOURS1234 BITUMINOUS SURFACE CONCRETE SURFACE OVERHEAD ELECTRIC LINEOHE STORM SEWER CATCH BASIN STORM SEWER INLET STRUCTURE STORM SEWER GRAVITY MAIN WATER MAIN LINE NATURAL GAS LINEGAS LEGEND SURVEYOR NOTES: 1.)THE UTILITIES SHOWN ON THIS SURVEY ARE ACCORDING TO VISIBLE EVIDENCE ALONG WITH MARKINGS FROM GOPHER STATE ONE CALL LOCATE REQUEST TICKET NO. 260330926, DATED FEBRUARY 2, 2026. WIDSETH ASSUMES NO RESPONSIBILITY FOR THE COMPLETENESS AND ACCURACY OF THESE LOCATIONS AND A PRIVATE LOCATED DONE BY HANCE LOCATING AND SERVICES, LLC. 2.)THE TOWER SITE LIES WITHIN ZONE "X" (AREAS DETERMINED TO HAVE MINIMAL FLOOD HAZARD) AS DEPICTED BY FEMA FLOOD INSURANCE RATE MAP NO. 27037C0040E, DATED 12/02/2011. 3.)THIS SURVEY WAS PREPARED BY WiDSETH. 5368 266TH STREET, WYOMING, MN 55092 PHONE NUMBER: 651-464-3130 4.)THIS SURVEY WAS PREPARED FOR DESIGN 1, INC. 5.)DUE TO SNOW AND ICE DURING THE TIME OF THE SURVEY, SOME UTILITIES AND IMPROVEMENTS MAY NOT HAVE BEEN LOCATED. ORIENTATION OF THIS BEARING SYSTEM IS BASED ON THE DAKOTA COUNTY COORDINATE SYSTEM; NAD83 (1996) 1 2/23/26 REVISED LEASE AND EASEMENT AREA AND REVISE DESCRIPTIONSSMKNTG SMK Page 76 of 473 ST881882883883884884882883884885886887887 884 884 885 885 886886 887885886887888889885886887887888889889889 8 8 3 88 3 881 886887886886885885 885886887884885 883 882886 PROJECT DRAWN BY:CHECKED BY:US-MN-5418BLOWFISH739 WENTWORTH AVEMENDOTA HEIGHTS, MN55118US-MN-5418FUZE ID: 17425846A-19973 VALLEY VIEW RD.EDEN PRAIRIE, MN 55344(952) 903-9299DESIGNWWW.DESIGN1EP.COMNOT FORCONSTRUCTIONPREPARED FOR:THE TOWERS, LLC 22 WEST ATLANTIC AVENUE, SUITE 310 DELRAY BEACH, FL 33444TLSSJDREV. A02-27-26SHEET CONTENTS:OVERALL SITE PLANSCALE:1OVERALL SITE PLAN1" = 50'-0"TOWER ELEVATIONSCALE:2TOWER ELEVATION1" = 30'-0"NOTES:1. THESE DRAWINGS DO NOT CONSTITUTE A WARRANTY, EXPRESSED OR IMPLIED, OF THE ACCURACY OF THE STRUCTURALANALYSES AND THE PERFORMANCE OF THE COMPLETED CONSTRUCTION AS SHOWN ON THESE DOCUMENTS AND THESTRUCTURAL ANALYSES.2. NO STRUCTURAL ANALYSIS FOR THE TOWER OR FOUNDATION HAVE BEEN PERFORMED AS PART OF THESE DRAWINGS.THE STRUCTURAL ANALYSIS FOR THE TOWER AND FOUNDATION ARE BY THE TOWER SUPPLIER AND SHALL BE DESIGNED BYA PROFESSIONAL ENGINEER LICENSED IN THE STATE OF THE PROJECT.3. PLEASE COORDINATE ANY STRUCTURAL CONCERNS/MATTERS OR ANY LOADING MODIFICATIONS TO THE CONSULTANTWHO AUTHORED THE ANALYSIS AND NOTIFY DESIGN 1 IMMEDIATELY OF THE ISSUE.4. TOWER FOUNDATION AND THE ACCESS DRIVE TO BE EXCAVATED AND CONSTRUCTED IN ACCORDANCE WITHRECOMMENDATIONS AND SPECIFICATIONS OF THE GEOTECHNICAL REPORT WHICH IS NOT INCLUDED IN THIS PACKAGE.DISCREPANCIES BETWEEN THE REPORT AND THE OTHER DOCUMENTS TO BE IMMEDIATELY REPORTED TO THE DESIGNER.5. TOWER TO BE ERECTED AND INSTALLED IN ACCORDANCE WITH TOWER MANUFACTURER'S DRAWINGS NOT INCLUDED WITHTHIS PACKAGE. DISCREPANCIES BETWEEN TOWER DRAWINGS AND DESIGNER DRAWINGS TO BE REPORTED THE DESIGNERIMMEDIATELY.6. CONTRACTOR TO ENSURE TIP OF ANTENNAS DO NOT EXCEED TOWER HEIGHT.7. ELEVATION IS SHOWN FOR GENERAL DIAGRAMMATIC PURPOSES ONLY. DO NOT SCALE.NORTHNORTH1334 81ST AVE NESPRING LAKE PARK, MN 55432612-844-1234WWW.HERZOGENGINEERING.COMI HEREBY CERTIFY THAT THISPLAN, SPECIFICATION, OR REPORTWAS PREPARED BY ME OR UNDERMY DIRECT SUPERVISION ANDTHAT I AM A DULY LICENSEDPROFESSIONAL ENGINEER UNDERTHE LAWS OF THE STATE OFMINNESOTA.NAME:SIGNATURE:DATE:LICENSE NUMBER:Joshua Herzog4239202/27/2026HE #: 261101Page 77 of 473 881882 883883884884 8828838848858868878878 8 3 88 3 881 886887885 885 88688 7 884 885883 882 PROJECT DRAWN BY:CHECKED BY:US-MN-5418BLOWFISH739 WENTWORTH AVEMENDOTA HEIGHTS, MN55118US-MN-5418FUZE ID: 17425846A-1.19973 VALLEY VIEW RD.EDEN PRAIRIE, MN 55344(952) 903-9299DESIGNWWW.DESIGN1EP.COMNOT FORCONSTRUCTIONPREPARED FOR:THE TOWERS, LLC 22 WEST ATLANTIC AVENUE, SUITE 310 DELRAY BEACH, FL 33444TLSSJDREV. A02-27-26SHEET CONTENTS:LANDSCAPING PLANSCALE:1LANDSCAPING PLAN1" = 20'-0"NORTHNORTH1334 81ST AVE NESPRING LAKE PARK, MN 55432612-844-1234WWW.HERZOGENGINEERING.COMI HEREBY CERTIFY THAT THISPLAN, SPECIFICATION, OR REPORTWAS PREPARED BY ME OR UNDERMY DIRECT SUPERVISION ANDTHAT I AM A DULY LICENSEDPROFESSIONAL ENGINEER UNDERTHE LAWS OF THE STATE OFMINNESOTA.NAME:SIGNATURE:DATE:LICENSE NUMBER:Joshua Herzog4239202/27/2026HE #: 261101Page 78 of 473 SHEET CONTENTS:ENLARGED SITE PLANSEE SHEET G-1 FOR ADDITIONAL NOTES.SCALE:1ENLARGED SITE PLAN1" = 10'-0"NORTHPROJECT DRAWN BY:CHECKED BY:US-MN-5418BLOWFISH739 WENTWORTH AVEMENDOTA HEIGHTS, MN55118US-MN-5418FUZE ID: 17425846A-29973 VALLEY VIEW RD.EDEN PRAIRIE, MN 55344(952) 903-9299DESIGNWWW.DESIGN1EP.COMNOT FORCONSTRUCTIONPREPARED FOR:THE TOWERS, LLC 22 WEST ATLANTIC AVENUE, SUITE 310 DELRAY BEACH, FL 33444TLSSJDREV. A02-27-261334 81ST AVE NESPRING LAKE PARK, MN 55432612-844-1234WWW.HERZOGENGINEERING.COMI HEREBY CERTIFY THAT THISPLAN, SPECIFICATION, OR REPORTWAS PREPARED BY ME OR UNDERMY DIRECT SUPERVISION ANDTHAT I AM A DULY LICENSEDPROFESSIONAL ENGINEER UNDERTHE LAWS OF THE STATE OFMINNESOTA.NAME:SIGNATURE:DATE:LICENSE NUMBER:Joshua Herzog4239202/27/2026HE #: 261101Page 79 of 473 SHEET CONTENTS:PROJECT DRAWN BY:CHECKED BY:US-MN-5418BLOWFISH739 WENTWORTH AVEMENDOTA HEIGHTS, MN55118US-MN-5418FUZE ID: 17425846A-39973 VALLEY VIEW RD.EDEN PRAIRIE, MN 55344(952) 903-9299DESIGNWWW.DESIGN1EP.COMNOT FORCONSTRUCTIONPREPARED FOR:THE TOWERS, LLC 22 WEST ATLANTIC AVENUE, SUITE 310 DELRAY BEACH, FL 33444TLSSJDREV. A02-27-262SILT FENCE DETIAL1CONSTRUCTION EXIT DETAILDRAINAGE,GRADING & EROSIONCONTROL NOTES & DETAILS1334 81ST AVE NESPRING LAKE PARK, MN 55432612-844-1234WWW.HERZOGENGINEERING.COMI HEREBY CERTIFY THAT THISPLAN, SPECIFICATION, OR REPORTWAS PREPARED BY ME OR UNDERMY DIRECT SUPERVISION ANDTHAT I AM A DULY LICENSEDPROFESSIONAL ENGINEER UNDERTHE LAWS OF THE STATE OFMINNESOTA.NAME:SIGNATURE:DATE:LICENSE NUMBER:Joshua Herzog4239202/27/2026HE #: 261101Page 80 of 473 NOTE:FENCE TO BE BLACK COATEDPROJECT DRAWN BY:CHECKED BY:US-MN-5418BLOWFISH739 WENTWORTH AVEMENDOTA HEIGHTS, MN55118US-MN-5418FUZE ID: 17425846A-49973 VALLEY VIEW RD.EDEN PRAIRIE, MN 55344(952) 903-9299DESIGNWWW.DESIGN1EP.COMNOT FORCONSTRUCTIONPREPARED FOR:THE TOWERS, LLC 22 WEST ATLANTIC AVENUE, SUITE 310 DELRAY BEACH, FL 33444TLSSJDREV. A02-27-26SHEET CONTENTS:FENCE DETAILS2MUSHROOM STOP DETAILSCALE:1FENCE DETAIL1/4" = 1'-0"1334 81ST AVE NESPRING LAKE PARK, MN 55432612-844-1234WWW.HERZOGENGINEERING.COMI HEREBY CERTIFY THAT THISPLAN, SPECIFICATION, OR REPORTWAS PREPARED BY ME OR UNDERMY DIRECT SUPERVISION ANDTHAT I AM A DULY LICENSEDPROFESSIONAL ENGINEER UNDERTHE LAWS OF THE STATE OFMINNESOTA.NAME:SIGNATURE:DATE:LICENSE NUMBER:Joshua Herzog4239202/27/2026HE #: 261101Page 81 of 473 PROJECT DRAWN BY:CHECKED BY:US-MN-5418BLOWFISH739 WENTWORTH AVEMENDOTA HEIGHTS, MN55118US-MN-5418FUZE ID: 17425846A-59973 VALLEY VIEW RD.EDEN PRAIRIE, MN 55344(952) 903-9299DESIGNWWW.DESIGN1EP.COMNOT FORCONSTRUCTIONPREPARED FOR:THE TOWERS, LLC 22 WEST ATLANTIC AVENUE, SUITE 310 DELRAY BEACH, FL 33444TLSSJDREV. A02-27-26SHEET CONTENTS:FENCE NOTESFENCE DETAILS1POST FOOTINGS2FABRIC/BAR CONNECTIONS1334 81ST AVE NESPRING LAKE PARK, MN 55432612-844-1234WWW.HERZOGENGINEERING.COMI HEREBY CERTIFY THAT THISPLAN, SPECIFICATION, OR REPORTWAS PREPARED BY ME OR UNDERMY DIRECT SUPERVISION ANDTHAT I AM A DULY LICENSEDPROFESSIONAL ENGINEER UNDERTHE LAWS OF THE STATE OFMINNESOTA.NAME:SIGNATURE:DATE:LICENSE NUMBER:Joshua Herzog4239202/27/2026HE #: 261101Page 82 of 473 PROJECT DRAWN BY:CHECKED BY:US-MN-5418BLOWFISH739 WENTWORTH AVEMENDOTA HEIGHTS, MN55118US-MN-5418FUZE ID: 17425846A-69973 VALLEY VIEW RD.EDEN PRAIRIE, MN 55344(952) 903-9299DESIGNWWW.DESIGN1EP.COMNOT FORCONSTRUCTIONPREPARED FOR:THE TOWERS, LLC 22 WEST ATLANTIC AVENUE, SUITE 310 DELRAY BEACH, FL 33444TLSSJDREV. A02-27-26SHEET CONTENTS:SITE SIGNAGE DETAILSABEFDCDFAECCCCCEADF1SITE SIGNAGEBB1334 81ST AVE NESPRING LAKE PARK, MN 55432612-844-1234WWW.HERZOGENGINEERING.COMI HEREBY CERTIFY THAT THISPLAN, SPECIFICATION, OR REPORTWAS PREPARED BY ME OR UNDERMY DIRECT SUPERVISION ANDTHAT I AM A DULY LICENSEDPROFESSIONAL ENGINEER UNDERTHE LAWS OF THE STATE OFMINNESOTA.NAME:SIGNATURE:DATE:LICENSE NUMBER:Joshua Herzog4239202/27/2026HE #: 261101Page 83 of 473 PROJECT DRAWN BY:CHECKED BY:US-MN-5418BLOWFISH739 WENTWORTH AVEMENDOTA HEIGHTS, MN55118US-MN-5418FUZE ID: 17425846A-79973 VALLEY VIEW RD.EDEN PRAIRIE, MN 55344(952) 903-9299DESIGNWWW.DESIGN1EP.COMNOT FORCONSTRUCTIONPREPARED FOR:THE TOWERS, LLC 22 WEST ATLANTIC AVENUE, SUITE 310 DELRAY BEACH, FL 33444TLSSJDREV. A02-27-26SHEET CONTENTS:GRAVEL DRIVE SECTIONSCALE:3BOLLARD DETAIL1/2" = 1'-0"SURFACING DETAIL 4UTILITY TRENCH DETAILSCALE:1GRAVEL DRIVE SECTION3/8" = 1'-0"2COMPOUND SURFACING DETAILBOLLARD DETAILUTILITY TRENCH DETAIL1334 81ST AVE NESPRING LAKE PARK, MN 55432612-844-1234WWW.HERZOGENGINEERING.COMI HEREBY CERTIFY THAT THISPLAN, SPECIFICATION, OR REPORTWAS PREPARED BY ME OR UNDERMY DIRECT SUPERVISION ANDTHAT I AM A DULY LICENSEDPROFESSIONAL ENGINEER UNDERTHE LAWS OF THE STATE OFMINNESOTA.NAME:SIGNATURE:DATE:LICENSE NUMBER:Joshua Herzog4239202/27/2026HE #: 261101Page 84 of 473 PROJECT DRAWN BY:CHECKED BY:US-MN-5418BLOWFISH739 WENTWORTH AVEMENDOTA HEIGHTS, MN55118US-MN-5418FUZE ID: 17425846A-89973 VALLEY VIEW RD.EDEN PRAIRIE, MN 55344(952) 903-9299DESIGNWWW.DESIGN1EP.COMNOT FORCONSTRUCTIONPREPARED FOR:THE TOWERS, LLC 22 WEST ATLANTIC AVENUE, SUITE 310 DELRAY BEACH, FL 33444TLSSJDREV. A02-27-26SHEET CONTENTS:PHOTOSVIEW: LOOKING NORTH1SITE PHOTOVIEW: LOOKING EAST2DRAINAGE POND PHOTOVIEW: LOOKING SOUTH3SITE PHOTOVIEW: LOOKING NORTH4ACCESS PHOTO1334 81ST AVE NESPRING LAKE PARK, MN 55432612-844-1234WWW.HERZOGENGINEERING.COMI HEREBY CERTIFY THAT THISPLAN, SPECIFICATION, OR REPORTWAS PREPARED BY ME OR UNDERMY DIRECT SUPERVISION ANDTHAT I AM A DULY LICENSEDPROFESSIONAL ENGINEER UNDERTHE LAWS OF THE STATE OFMINNESOTA.NAME:SIGNATURE:DATE:LICENSE NUMBER:Joshua Herzog4239202/27/2026HE #: 261101Page 85 of 473 GENERAL GROUNDING NOTES:·················SYMBOL AND NOTE LEGENDPROJECT DRAWN BY:CHECKED BY:US-MN-5418BLOWFISH739 WENTWORTH AVEMENDOTA HEIGHTS, MN55118US-MN-5418FUZE ID: 17425846G-19973 VALLEY VIEW RD.EDEN PRAIRIE, MN 55344(952) 903-9299DESIGNWWW.DESIGN1EP.COMNOT FORCONSTRUCTIONPREPARED FOR:THE TOWERS, LLC 22 WEST ATLANTIC AVENUE, SUITE 310 DELRAY BEACH, FL 33444TLSSJDREV. A02-27-26SHEET CONTENTS:GROUNDING NOTESSCALE:1EXOTHERMIC WELD DETAILSNTSSCALE:2COMPRESSION CONNECTOR DETAILSNTSUTILITY NOTES1334 81ST AVE NESPRING LAKE PARK, MN 55432612-844-1234WWW.HERZOGENGINEERING.COMI HEREBY CERTIFY THAT THISPLAN, SPECIFICATION, OR REPORTWAS PREPARED BY ME OR UNDERMY DIRECT SUPERVISION ANDTHAT I AM A DULY LICENSEDPROFESSIONAL ENGINEER UNDERTHE LAWS OF THE STATE OFMINNESOTA.NAME:SIGNATURE:DATE:LICENSE NUMBER:Joshua Herzog4239202/27/2026HE #: 261101Page 86 of 473 PROJECT DRAWN BY:CHECKED BY:US-MN-5418BLOWFISH739 WENTWORTH AVEMENDOTA HEIGHTS, MN55118US-MN-5418FUZE ID: 17425846G-29973 VALLEY VIEW RD.EDEN PRAIRIE, MN 55344(952) 903-9299DESIGNWWW.DESIGN1EP.COMNOT FORCONSTRUCTIONPREPARED FOR:THE TOWERS, LLC 22 WEST ATLANTIC AVENUE, SUITE 310 DELRAY BEACH, FL 33444TLSSJDREV. A02-27-26SHEET CONTENTS:NORTHGROUNDING PLANSCALE:1GROUNDING PLANNTS1334 81ST AVE NESPRING LAKE PARK, MN 55432612-844-1234WWW.HERZOGENGINEERING.COMI HEREBY CERTIFY THAT THISPLAN, SPECIFICATION, OR REPORTWAS PREPARED BY ME OR UNDERMY DIRECT SUPERVISION ANDTHAT I AM A DULY LICENSEDPROFESSIONAL ENGINEER UNDERTHE LAWS OF THE STATE OFMINNESOTA.NAME:SIGNATURE:DATE:LICENSE NUMBER:Joshua Herzog4239202/27/2026HE #: 261101Page 87 of 473 PROJECT DRAWN BY:CHECKED BY:US-MN-5418BLOWFISH739 WENTWORTH AVEMENDOTA HEIGHTS, MN55118US-MN-5418FUZE ID: 17425846G-39973 VALLEY VIEW RD.EDEN PRAIRIE, MN 55344(952) 903-9299DESIGNWWW.DESIGN1EP.COMNOT FORCONSTRUCTIONPREPARED FOR:THE TOWERS, LLC 22 WEST ATLANTIC AVENUE, SUITE 310 DELRAY BEACH, FL 33444TLSSJDREV. A02-27-26SHEET CONTENTS:GROUNDING DETAILSSCALE:4GROUND RING & ROD DETAILNONESCALE:2REBAR GROUNDING DETAILNONESCALE:1CONDUIT DETAILNONESCALE:3TOWER GROUND BAR DETAILNONE1334 81ST AVE NESPRING LAKE PARK, MN 55432612-844-1234WWW.HERZOGENGINEERING.COMI HEREBY CERTIFY THAT THISPLAN, SPECIFICATION, OR REPORTWAS PREPARED BY ME OR UNDERMY DIRECT SUPERVISION ANDTHAT I AM A DULY LICENSEDPROFESSIONAL ENGINEER UNDERTHE LAWS OF THE STATE OFMINNESOTA.NAME:SIGNATURE:DATE:LICENSE NUMBER:Joshua Herzog4239202/27/2026HE #: 261101Page 88 of 473 STSHEET CONTENTS:SCALE:1SITE UTILITY PLAN1" = 50'-0"SITE UTILITY PLANENLARGED SITE UTILITY PLANSCALE:2HANDHOLE LOCATION PLAN1/8" = 1'-0"NORTHSCALE:3ENLARGED SITE UTILITY PLAN1/16" = 1'-0"NORTH2U-1PULLBOX LOCATION PLAN3U-1NORTHPROJECT DRAWN BY:CHECKED BY:US-MN-5418BLOWFISH739 WENTWORTH AVEMENDOTA HEIGHTS, MN55118US-MN-5418FUZE ID: 17425846U-19973 VALLEY VIEW RD.EDEN PRAIRIE, MN 55344(952) 903-9299DESIGNWWW.DESIGN1EP.COMNOT FORCONSTRUCTIONPREPARED FOR:THE TOWERS, LLC 22 WEST ATLANTIC AVENUE, SUITE 310 DELRAY BEACH, FL 33444TLSSJDREV. A02-27-261334 81ST AVE NESPRING LAKE PARK, MN 55432612-844-1234WWW.HERZOGENGINEERING.COMI HEREBY CERTIFY THAT THISPLAN, SPECIFICATION, OR REPORTWAS PREPARED BY ME OR UNDERMY DIRECT SUPERVISION ANDTHAT I AM A DULY LICENSEDPROFESSIONAL ENGINEER UNDERTHE LAWS OF THE STATE OFMINNESOTA.NAME:SIGNATURE:DATE:LICENSE NUMBER:Joshua Herzog4239202/27/2026HE #: 261101Page 89 of 473 PROJECT DRAWN BY:CHECKED BY:US-MN-5418BLOWFISH739 WENTWORTH AVEMENDOTA HEIGHTS, MN55118US-MN-5418FUZE ID: 17425846U-29973 VALLEY VIEW RD.EDEN PRAIRIE, MN 55344(952) 903-9299DESIGNWWW.DESIGN1EP.COMNOT FORCONSTRUCTIONPREPARED FOR:THE TOWERS, LLC 22 WEST ATLANTIC AVENUE, SUITE 310 DELRAY BEACH, FL 33444TLSSJDREV. A02-27-26SHEET CONTENTS:METER UTILITY FRAME DETAILSCALE:1METER UTILITY FRAME DETAILNONE1334 81ST AVE NESPRING LAKE PARK, MN 55432612-844-1234WWW.HERZOGENGINEERING.COMI HEREBY CERTIFY THAT THISPLAN, SPECIFICATION, OR REPORTWAS PREPARED BY ME OR UNDERMY DIRECT SUPERVISION ANDTHAT I AM A DULY LICENSEDPROFESSIONAL ENGINEER UNDERTHE LAWS OF THE STATE OFMINNESOTA.NAME:SIGNATURE:DATE:LICENSE NUMBER:Joshua Herzog4239202/27/2026HE #: 261101Page 90 of 473 PROJECT DRAWN BY:CHECKED BY:US-MN-5418BLOWFISH739 WENTWORTH AVEMENDOTA HEIGHTS, MN55118US-MN-5418FUZE ID: 17425846VZW A-19973 VALLEY VIEW RD.EDEN PRAIRIE, MN 55344(952) 903-9299DESIGNWWW.DESIGN1EP.COMNOT FORCONSTRUCTIONPREPARED FOR:THE TOWERS, LLC 22 WEST ATLANTIC AVENUE, SUITE 310 DELRAY BEACH, FL 33444TLSSJDREV. A02-27-26SHEET CONTENTS:NORTHVERIZON SITE PLANSCALE:1VERIZON SITE PLAN1" = 10'-0"NORTHTOWER ELEVATIONSCALE:2TOWER ELEVATION1" = 30'-0"NOTES:1. THESE DRAWINGS DO NOT CONSTITUTE A WARRANTY, EXPRESSED OR IMPLIED, OF THE ACCURACYOF THE STRUCTURAL ANALYSES AND THE PERFORMANCE OF THE COMPLETED CONSTRUCTION ASSHOWN ON THESE DOCUMENTS AND THE STRUCTURAL ANALYSES.2. NO STRUCTURAL ANALYSIS FOR THE MOUNT HAS BEEN PERFORMED AS PART OF THESE DRAWINGS.3. PLEASE COORDINATE ANY STRUCTURAL CONCERNS/MATTERS OR ANY LOADING MODIFICATIONS TOTHE CONSULTANT WHO AUTHORED THE ANALYSIS AND NOTIFY DESIGN 1 IMMEDIATELY OF THE ISSUE.4. EQUIPMENT SLAB AND GENERATOR FOUNDATION TO BE EXCAVATED AND CONSTRUCTED INACCORDANCE WITH RECOMMENDATIONS AND SPECIFICATIONS OF THE GEOTECHNICAL REPORTWHICH IS NOT INCLUDED IN THIS PACKAGE. DISCREPANCIES BETWEEN THE REPORT AND THE OTHERDOCUMENTS TO BE IMMEDIATELY REPORTED TO VERIZON WIRELESS AND THE DESIGNER.5. CONTRACTOR TO ENSURE TIP OF ANTENNAS DO NOT EXCEED TOWER HEIGHT.6. ELEVATION IS SHOWN FOR GENERAL DIAGRAMMATIC PURPOSES ONLY. DO NOT SCALE.7. THE STRUCTURAL ANALYSIS FOR THE MOUNTS (BY OTHERS) SHALL BE PER THE VERIZON NETWORKSTANDARD NSTD-445. ALL LOADING AND DESIGN SHALL BE PER THE TIA-222-H STANDARD.1334 81ST AVE NESPRING LAKE PARK, MN 55432612-844-1234WWW.HERZOGENGINEERING.COMI HEREBY CERTIFY THAT THISPLAN, SPECIFICATION, OR REPORTWAS PREPARED BY ME OR UNDERMY DIRECT SUPERVISION ANDTHAT I AM A DULY LICENSEDPROFESSIONAL ENGINEER UNDERTHE LAWS OF THE STATE OFMINNESOTA.NAME:SIGNATURE:DATE:LICENSE NUMBER:Joshua Herzog4239202/27/2026HE #: 261101Page 91 of 473 SHEET CONTENTS:1ANTENNA KEY2EQUIPMENT KEY4RFDS PLUMBING DIAGRAMSCALE:3ANTENNA MOUNTING DETAIL3/16" = 1'-0"NORTHRFDS INFORMATIONRFDS PLUMBING DIAGRAMANTENNA MOUNTING DETAILPROJECT DRAWN BY:CHECKED BY:US-MN-5418BLOWFISH739 WENTWORTH AVEMENDOTA HEIGHTS, MN55118US-MN-5418FUZE ID: 17425846VZW A-29973 VALLEY VIEW RD.EDEN PRAIRIE, MN 55344(952) 903-9299DESIGNWWW.DESIGN1EP.COMNOT FORCONSTRUCTIONPREPARED FOR:THE TOWERS, LLC 22 WEST ATLANTIC AVENUE, SUITE 310 DELRAY BEACH, FL 33444TLSSJDREV. A02-27-261334 81ST AVE NESPRING LAKE PARK, MN 55432612-844-1234WWW.HERZOGENGINEERING.COMI HEREBY CERTIFY THAT THISPLAN, SPECIFICATION, OR REPORTWAS PREPARED BY ME OR UNDERMY DIRECT SUPERVISION ANDTHAT I AM A DULY LICENSEDPROFESSIONAL ENGINEER UNDERTHE LAWS OF THE STATE OFMINNESOTA.NAME:SIGNATURE:DATE:LICENSE NUMBER:Joshua Herzog4239202/27/2026HE #: 261101Page 92 of 473 74PROJECT DRAWN BY:CHECKED BY:US-MN-5418BLOWFISH739 WENTWORTH AVEMENDOTA HEIGHTS, MN55118US-MN-5418FUZE ID: 17425846VZW A-39973 VALLEY VIEW RD.EDEN PRAIRIE, MN 55344(952) 903-9299DESIGNWWW.DESIGN1EP.COMNOT FORCONSTRUCTIONPREPARED FOR:THE TOWERS, LLC 22 WEST ATLANTIC AVENUE, SUITE 310 DELRAY BEACH, FL 33444TLSSJDREV. A02-27-26SHEET CONTENTS:FOUNDATION PLAN & DETAILSLAYOUT PLANELEVATIONSSCALE:1SLAB LAYOUT PLAN1/4" = 1'-0"SCALE:5FRONT ELEVATION1/4" = 1'-0"SCALE:6SIDE ELEVATION1/4" = 1'-0"SCALE:2CANOPY PLAN1/4" = 1'-0"SCALE:3SLAB PLAN3/8" = 1'-0"7SCALE:4SLAB SECTION3/8" = 1'-0"SCALE:7DETAIL1-1/2" = 1'-0"1334 81ST AVE NESPRING LAKE PARK, MN 55432612-844-1234WWW.HERZOGENGINEERING.COMI HEREBY CERTIFY THAT THISPLAN, SPECIFICATION, OR REPORTWAS PREPARED BY ME OR UNDERMY DIRECT SUPERVISION ANDTHAT I AM A DULY LICENSEDPROFESSIONAL ENGINEER UNDERTHE LAWS OF THE STATE OFMINNESOTA.NAME:SIGNATURE:DATE:LICENSE NUMBER:Joshua Herzog4239202/27/2026HE #: 261101Page 93 of 473 PROJECT DRAWN BY:CHECKED BY:US-MN-5418BLOWFISH739 WENTWORTH AVEMENDOTA HEIGHTS, MN55118US-MN-5418FUZE ID: 17425846VZW A-49973 VALLEY VIEW RD.EDEN PRAIRIE, MN 55344(952) 903-9299DESIGNWWW.DESIGN1EP.COMNOT FORCONSTRUCTIONPREPARED FOR:THE TOWERS, LLC 22 WEST ATLANTIC AVENUE, SUITE 310 DELRAY BEACH, FL 33444TLSSJDREV. A02-27-26SHEET CONTENTS:CABLE BRIDGE DETAILSSCALE:1CABLE BRIDGE SECTION1/2" = 1'-0"NORTHSCALE:2CABLE BRIDGE PLAN1/4" = 1'-0"GPS DETAILSSCALE: N.T.S3GPS ANTENNA MOUNTING1334 81ST AVE NESPRING LAKE PARK, MN 55432612-844-1234WWW.HERZOGENGINEERING.COMI HEREBY CERTIFY THAT THISPLAN, SPECIFICATION, OR REPORTWAS PREPARED BY ME OR UNDERMY DIRECT SUPERVISION ANDTHAT I AM A DULY LICENSEDPROFESSIONAL ENGINEER UNDERTHE LAWS OF THE STATE OFMINNESOTA.NAME:SIGNATURE:DATE:LICENSE NUMBER:Joshua Herzog4239202/27/2026HE #: 261101Page 94 of 473 PROJECT DRAWN BY:CHECKED BY:US-MN-5418BLOWFISH739 WENTWORTH AVEMENDOTA HEIGHTS, MN55118US-MN-5418FUZE ID: 17425846VZW A-59973 VALLEY VIEW RD.EDEN PRAIRIE, MN 55344(952) 903-9299DESIGNWWW.DESIGN1EP.COMNOT FORCONSTRUCTIONPREPARED FOR:THE TOWERS, LLC 22 WEST ATLANTIC AVENUE, SUITE 310 DELRAY BEACH, FL 33444TLSSJDREV. A02-27-26SHEET CONTENTS:GENERATOR DETAILS,STANDARD TANKSCALE:1GENERATOR ASSEMBLY ELEVATIONS1/4" = 1'-0"SCALE:4CONCRETE PAD SECTION3/8" = 1'-0"SCALE:3CONCRETE PAD PLAN3/8" = 1'-0"SCALE:2GENERATOR ASSEMBLY PLAN3/8" = 1'-0"● ● ● ● ● ●●1334 81ST AVE NESPRING LAKE PARK, MN 55432612-844-1234WWW.HERZOGENGINEERING.COMI HEREBY CERTIFY THAT THISPLAN, SPECIFICATION, OR REPORTWAS PREPARED BY ME OR UNDERMY DIRECT SUPERVISION ANDTHAT I AM A DULY LICENSEDPROFESSIONAL ENGINEER UNDERTHE LAWS OF THE STATE OFMINNESOTA.NAME:SIGNATURE:DATE:LICENSE NUMBER:Joshua Herzog4239202/27/2026HE #: 261101Page 95 of 473 PROJECT DRAWN BY:CHECKED BY:US-MN-5418BLOWFISH739 WENTWORTH AVEMENDOTA HEIGHTS, MN55118US-MN-5418FUZE ID: 17425846VZW G-19973 VALLEY VIEW RD.EDEN PRAIRIE, MN 55344(952) 903-9299DESIGNWWW.DESIGN1EP.COMNOT FORCONSTRUCTIONPREPARED FOR:THE TOWERS, LLC 22 WEST ATLANTIC AVENUE, SUITE 310 DELRAY BEACH, FL 33444TLSSJDREV. A02-27-26SHEET CONTENTS:NORTHGROUNDING PLANSCALE:1GROUNDING PLANNTS1334 81ST AVE NESPRING LAKE PARK, MN 55432612-844-1234WWW.HERZOGENGINEERING.COMI HEREBY CERTIFY THAT THISPLAN, SPECIFICATION, OR REPORTWAS PREPARED BY ME OR UNDERMY DIRECT SUPERVISION ANDTHAT I AM A DULY LICENSEDPROFESSIONAL ENGINEER UNDERTHE LAWS OF THE STATE OFMINNESOTA.NAME:SIGNATURE:DATE:LICENSE NUMBER:Joshua Herzog4239202/27/2026HE #: 261101Page 96 of 473 PROJECT DRAWN BY:CHECKED BY:US-MN-5418BLOWFISH739 WENTWORTH AVEMENDOTA HEIGHTS, MN55118US-MN-5418FUZE ID: 17425846VZW G-29973 VALLEY VIEW RD.EDEN PRAIRIE, MN 55344(952) 903-9299DESIGNWWW.DESIGN1EP.COMNOT FORCONSTRUCTIONPREPARED FOR:THE TOWERS, LLC 22 WEST ATLANTIC AVENUE, SUITE 310 DELRAY BEACH, FL 33444TLSSJDREV. A02-27-26SHEET CONTENTS:GROUNDING DETAILSSCALE:5GROUND RING & ROD DETAILNONESCALE:3REBAR GROUNDING DETAILNONESCALE:4CONDUIT DETAILNONESCALE:1TYPICAL CABLE BRIDGE GROUNDING DETAILNONESCALE:2TOWER GROUND BAR DETAILNONESCALE:6TYPICAL ICE SHIELD GROUNDING DETAILSNONE1334 81ST AVE NESPRING LAKE PARK, MN 55432612-844-1234WWW.HERZOGENGINEERING.COMI HEREBY CERTIFY THAT THISPLAN, SPECIFICATION, OR REPORTWAS PREPARED BY ME OR UNDERMY DIRECT SUPERVISION ANDTHAT I AM A DULY LICENSEDPROFESSIONAL ENGINEER UNDERTHE LAWS OF THE STATE OFMINNESOTA.NAME:SIGNATURE:DATE:LICENSE NUMBER:Joshua Herzog4239202/27/2026HE #: 261101Page 97 of 473 PROJECT DRAWN BY:CHECKED BY:US-MN-5418BLOWFISH739 WENTWORTH AVEMENDOTA HEIGHTS, MN55118US-MN-5418FUZE ID: 17425846VZW U-19973 VALLEY VIEW RD.EDEN PRAIRIE, MN 55344(952) 903-9299DESIGNWWW.DESIGN1EP.COMNOT FORCONSTRUCTIONPREPARED FOR:THE TOWERS, LLC 22 WEST ATLANTIC AVENUE, SUITE 310 DELRAY BEACH, FL 33444TLSSJDREV. A02-27-26SHEET CONTENTS:SCALE:1SITE UTILITY PLAN1/8" = 1'-0"NORTHVZW UTILITY PLAN1334 81ST AVE NESPRING LAKE PARK, MN 55432612-844-1234WWW.HERZOGENGINEERING.COMI HEREBY CERTIFY THAT THISPLAN, SPECIFICATION, OR REPORTWAS PREPARED BY ME OR UNDERMY DIRECT SUPERVISION ANDTHAT I AM A DULY LICENSEDPROFESSIONAL ENGINEER UNDERTHE LAWS OF THE STATE OFMINNESOTA.NAME:SIGNATURE:DATE:LICENSE NUMBER:Joshua Herzog4239202/27/2026HE #: 261101Page 98 of 473 ·········PROJECT DRAWN BY:CHECKED BY:US-MN-5418BLOWFISH739 WENTWORTH AVEMENDOTA HEIGHTS, MN55118US-MN-5418FUZE ID: 17425846VZW U-29973 VALLEY VIEW RD.EDEN PRAIRIE, MN 55344(952) 903-9299DESIGNWWW.DESIGN1EP.COMNOT FORCONSTRUCTIONPREPARED FOR:THE TOWERS, LLC 22 WEST ATLANTIC AVENUE, SUITE 310 DELRAY BEACH, FL 33444TLSSJDREV. A02-27-26SHEET CONTENTS:CONDUIT ROUTING PLANSCALE:2ONE-LINE ELECTRIC DIAGRAMNONEONE-LINE ELECTRIC DIAGRAMSCALE:1CONDUIT ROUTING PLAN1/4" = 1'-0"1334 81ST AVE NESPRING LAKE PARK, MN 55432612-844-1234WWW.HERZOGENGINEERING.COMI HEREBY CERTIFY THAT THISPLAN, SPECIFICATION, OR REPORTWAS PREPARED BY ME OR UNDERMY DIRECT SUPERVISION ANDTHAT I AM A DULY LICENSEDPROFESSIONAL ENGINEER UNDERTHE LAWS OF THE STATE OFMINNESOTA.NAME:SIGNATURE:DATE:LICENSE NUMBER:Joshua Herzog4239202/27/2026HE #: 261101Page 99 of 473 BUELL CONSULTING, INC. 9973 Valley View Rd Eden Prairie, MN 55118 (651) 361-8110 www.buellconsulting.com Thursday, April 23, 2026 City of Mendota Heights Attn: Sarah Madden 1101 Victoria Curve Mendota Heights, MN 55118 RE: CUP Application for New Tower Site – The Towers LLC Reference: US-MN-5418 BLOWFISH Property Address: 739 Wentworth Ave Dakota County PID: 27-03800-34-010 Dear Ms. Madden, Planning Commission Members, and City Council Members, On behalf of The Towers, LLC, Buell Consulting, Inc. hereby submits a Conditional Use Application for a new Wireless Tower site on Wentworth Park property owned by the City of Mendota Heights. Enclosed with this letter are the following items: • Written response to public comments (immediately following pages) • Updated RF Statement and Map from Verizon Wireless to correct County, clarify need for height/elevation • Updated photo simulations, revised the first view • Property Value Impact Study concluding the tower will have no measurable impact to property values • Site Search and Zoning Walk-Through explaining the process that led to this location Please consider these additional materials as part of our zoning application file. Sincerely, Scott Buell Site Development Agent on behalf of The Towers, LLC Phone: 651-225-0793 Email: sbuell@buellconsulting.com Encl. Page 100 of 473 Response to Public Comments | Page 1 of 2 Applicant Response to Public Comments from Community Conditional Use Permit Application for a New Communication Tower Dakota County PID 27-03800-34-010 Property address: 739 Wentworth Ave This project has received comments from the public, and those comments fall into a handful of major categories/themes outlined below. This document provides the applicant’s responses to those general collective themes, with the goal of encouraging understanding amongst community members. Most comments from the community that relate to the project elements fall into the following four groups/topics: 1. Health and Radiofrequency Radiation 2. Property Values 3. Incompatibility with Park Character 4. Failure to Exhaust Alternatives Responses to these four topics are in the following sections. Health and Radiation Risks Health and radiation-related concerns was the most frequently cited concern from the public in relation to this application for a new tower site. The Telecommunications Act of 1996, specifically Section 704, establishes the FCC as the federal authority regulating radiofrequency (RF) emissions from wireless facilities. The FCC maintains that wireless facilities, when operating within FCC guidelines, are safe and do not pose any known health risks. This Section also prohibits local governments from regulating the placement of towers based on environmental effects (including health impacts) of RF emissions as long as the licensed user of those RF frequencies complies with FCC regulations. Any antenna equipment installed on this proposed tower site will operate within FCC guidelines and regulations. The operable excerpt from Section 704 of the Telecommunications Act of 1996 is as follows: (iv) No State or local government or instrumentality thereof may regulate the placement, construction, and modification of personal wireless service facilities on the basis of the environmental effects of radio frequency emissions to the extent that such facilities comply with the Commission’s regulations concerning such emissions. Federal agencies are the scientific experts on RF safety standards, and Section 704(a) of the 1996 Telecommunications Act expressly prohibits local authorities from considering these issues as part of the permitting process. Property Values Another widely shared fear amongst community members is perceived negative property value impact due to the proximity of this proposed tower site. Community members provided studies that seemed to show property value declines for homes near cell sites. None of these studies were based on the local real estate market; some were even outside of the United States. Included with this letter, as part of the supplemental materials for The Towers LLC’s zoning application, is a value impact study from a third-party appraiser referencing several recent local real estate transactions in close proximity to a wireless tower (or antenna equipment installed on a structure) which demonstrates that this proposed site will have no measurable impact on home prices in the surrounding area. Again, that report is enclosed with this letter. Page 101 of 473 Response to Public Comments | Page 2 of 2 Incompatibility with Park Character There was strong sentiment that placing the proposed 149-foot tower in Wentworth Park is incompatible with the park’s character. As City Staff wrote in the report for this project ahead of the March 31 Planning Commission meeting, this proposed project “is consistent with the general purpose and intent of City Code and the Comprehensive Plan,” essentially because this project meets the zoning ordinance requirements for the siting of a new tower. A tower site is a critical piece of infrastructure, and the zoning ordinance provides guidance about placement and design. By meeting the requirements in the City’s zoning ordinance, the proposed use is compatible with the subject property. Failure to Exhaust Alternatives Amongst the public comments were repeated questions of whether co-location on existing structures, rooftop antennas, small-cell technology, or alternative municipal sites (water tower, public works garage, commercial corridors) were genuinely evaluated before selecting a neighborhood park. A detailed report is enclosed along with the other supplemental materials and which describes the step-wise process and analysis which was undertaken to arrive at this location at Wentworth, which is the best location to fulfill the RF need while remaining compliant with the zoning ordinance. Thank you for considering these additional written statements and materials as part of The Towers LLC’s conditional use permit and zoning application package for the proposed tower facility. This project continues to satisfy the requirements for a CUP to be approved by the City, and we welcome any questions and comments as you review this additional information. Sincerely, Scott Buell, Site Development Agent on Behalf of The Towers, LLC Buell Consulting, Inc. sbuell@buellconsulting.com Direct: 651-225-0793 Page 102 of 473 1 STATEMENT OF NETWORK NEED New Communications Tower in Dakota County, City of Mendota Heights, Minnesota Christopher Humes, Radio Frequency Engineer Verizon ID: MIN BLOWFISH 1. My name is Christopher Humes and I am a radio frequency (RF) engineer for Verizon Wireless (“Verizon”). I have been employed by Verizon since 2025 and have been the RF Engineer for the Minneapolis/Northern Minnesota Market since 2025. 2. The primary duties of an RF engineer include the design and management of Verizon’s wireless communications network in its Great Plains Market, which includes the area in and around Dakota County, Minnesota. RF Engineers are also responsible for identifying and addressing substantial service and capacity gaps that present themselves in Verizon’s wireless network. These service gaps can be caused by lack of coverage or insufficient system capacity, or both. Service gaps are identified through the use of internal Verizon network monitoring tools and analysis showing the capacity and/or coverage needs in a particular area. 3. There is a significant service capacity gap in Verizon’s wireless communications network in and around Dakota County (the “Gap Area”). As a result of this significant service capacity gap, Verizon customers using their devices in and around the Gap Area are likely to experience diminished call quality, slow data transmission speeds, and blocked calls. Verizon’s service gap in the Gap Area has been amplified by the sharp increase in data usage by Verizon’s customers. 4. This significant service capacity gap will remain and cannot be resolved unless a communications tower is constructed within the Gap Area. Verizon must remedy this service capacity gap in order to provide high-speed wireless broadband access to the communities in and around the Gap Area, to fill in indoor coverage gaps where wireless services are not reliable, and to provide enhanced E911 services. 5. Verizon identified a search area within a one-mile radius, centered on 44.897900°N 93.126200°W which a tower would need to be located in order to resolve the service gap. Before proposing a new communications tower, Verizon first considered whether any existing towers in the search area could be used to resolve the coverage gap in the Gap Area. There were no other structures in the search area on which Verizon could collocate to resolve the service gap in the Gap Area. Although there are existing towers in the general area outside the search ring, none of these towers will allow Verizon to remedy the service gap. 6. Verizon and Vertical Bridge have worked together to identify a property in the area that could accommodate a communications tower to correct the significant service capacity gap in Verizon’s wireless communications network. Vertical Bridge has proposed to build a new 150’ tower at 739 Wentworth Avenue, Mendota Heights, MN 55118 (“Proposed Tower”). The tower height of 150’ at the location’s ground elevation of 885’ AMSL is necessary because of the surrounding topography and the Page 103 of 473 2 size of the area. This particular location is optimal because it will allow Verizon to cover substantially all of the area with a single tower. 7. By co-locating its communications equipment on the Proposed Tower, Verizon will resolve the current significant service capacity gap and will be able to provide improved service to residents, businesses, and emergency service providers in and around the Gap Area. If Vertical Bridge is unable to construct the new telecommunications tower, and Verizon is therefore unable to collocate its equipment on the proposed tower, the significant service capacity gap in Verizon’s wireless communications network will remain, and Verizon will be prohibited from providing reliable wireless service to its customers in the Gap Area. Dated this 14th day of April, 2026 ___________ ______________________ Christopher Humes Engr III Cslt – Radio Frequency Verizon Great Plains – Minneapolis/Northern Minnesota Page 104 of 473 3 CURRENT SERVICE LEVEL MIN Blowfish Page 105 of 473 4 PROPOSED SERVICE LEVEL MIN Blowfish Page 106 of 473 5 Page 107 of 473 DESIGN 9973 VALLEY VIEW ROAD EDEN PRAIRIE, MN 55344 (952) 903-9299 WWW.DESIGN1EP.COM PROJECT:DRAWN BY:VERIZON WIRELESS 10801 BUSH LAKE ROAD BLOOMINGTON, MN 55438 (952) 946-4700 739 WENTWORTH AVE MENDOTA HEIGHTS, MN 55118 17425846 MIN BLOWFISH US-MN-5418 TRDV.102-25-26V.202-26-26V.304-03-26PS-1VIEW 3VIEW 1MAP DATA ©2026 BINGNORTHUPPER COLONIAL DRWENTWORTH AVE WVIEW 48WENTWORTH PARKVIEW 2Page 108 of 473 DESIGN 9973 VALLEY VIEW ROAD EDEN PRAIRIE, MN 55344 (952) 903-9299 WWW.DESIGN1EP.COM PROJECT:DRAWN BY:VERIZON WIRELESS 10801 BUSH LAKE ROAD BLOOMINGTON, MN 55438 (952) 946-4700 739 WENTWORTH AVE MENDOTA HEIGHTS, MN 55118 17425846 MIN BLOWFISH US-MN-5418 TRDV.102-25-26V.202-26-26V.304-03-26PS-2Page 109 of 473 DESIGN 9973 VALLEY VIEW ROAD EDEN PRAIRIE, MN 55344 (952) 903-9299 WWW.DESIGN1EP.COM PROJECT:DRAWN BY:VERIZON WIRELESS 10801 BUSH LAKE ROAD BLOOMINGTON, MN 55438 (952) 946-4700 739 WENTWORTH AVE MENDOTA HEIGHTS, MN 55118 17425846 MIN BLOWFISH US-MN-5418 TRDV.102-25-26V.202-26-26V.304-03-26PS-3Page 110 of 473 DESIGN 9973 VALLEY VIEW ROAD EDEN PRAIRIE, MN 55344 (952) 903-9299 WWW.DESIGN1EP.COM PROJECT:DRAWN BY:VERIZON WIRELESS 10801 BUSH LAKE ROAD BLOOMINGTON, MN 55438 (952) 946-4700 739 WENTWORTH AVE MENDOTA HEIGHTS, MN 55118 17425846 MIN BLOWFISH US-MN-5418 TRDV.102-25-26V.202-26-26V.304-03-26PS-4Page 111 of 473 DESIGN 9973 VALLEY VIEW ROAD EDEN PRAIRIE, MN 55344 (952) 903-9299 WWW.DESIGN1EP.COM PROJECT:DRAWN BY:VERIZON WIRELESS 10801 BUSH LAKE ROAD BLOOMINGTON, MN 55438 (952) 946-4700 739 WENTWORTH AVE MENDOTA HEIGHTS, MN 55118 17425846 MIN BLOWFISH US-MN-5418 TRDV.102-25-26V.202-26-26V.304-03-26PS-5Page 112 of 473 DESIGN 9973 VALLEY VIEW ROAD EDEN PRAIRIE, MN 55344 (952) 903-9299 WWW.DESIGN1EP.COM PROJECT:DRAWN BY:VERIZON WIRELESS 10801 BUSH LAKE ROAD BLOOMINGTON, MN 55438 (952) 946-4700 739 WENTWORTH AVE MENDOTA HEIGHTS, MN 55118 17425846 MIN BLOWFISH US-MN-5418 TRDV.102-25-26V.202-26-26V.304-03-26PS-6Page 113 of 473 DESIGN 9973 VALLEY VIEW ROAD EDEN PRAIRIE, MN 55344 (952) 903-9299 WWW.DESIGN1EP.COM PROJECT:DRAWN BY:VERIZON WIRELESS 10801 BUSH LAKE ROAD BLOOMINGTON, MN 55438 (952) 946-4700 739 WENTWORTH AVE MENDOTA HEIGHTS, MN 55118 17425846 MIN BLOWFISH US-MN-5418 TRDV.102-25-26V.202-26-26V.304-03-26PS-7Page 114 of 473 DESIGN 9973 VALLEY VIEW ROAD EDEN PRAIRIE, MN 55344 (952) 903-9299 WWW.DESIGN1EP.COM PROJECT:DRAWN BY:VERIZON WIRELESS 10801 BUSH LAKE ROAD BLOOMINGTON, MN 55438 (952) 946-4700 739 WENTWORTH AVE MENDOTA HEIGHTS, MN 55118 17425846 MIN BLOWFISH US-MN-5418 TRDV.102-25-26V.202-26-26V.304-03-26PS-8Page 115 of 473 DESIGN 9973 VALLEY VIEW ROAD EDEN PRAIRIE, MN 55344 (952) 903-9299 WWW.DESIGN1EP.COM PROJECT:DRAWN BY:VERIZON WIRELESS 10801 BUSH LAKE ROAD BLOOMINGTON, MN 55438 (952) 946-4700 739 WENTWORTH AVE MENDOTA HEIGHTS, MN 55118 17425846 MIN BLOWFISH US-MN-5418 TRDV.102-25-26V.202-26-26V.304-03-26PS-9Page 116 of 473 Appraisal Report – Impact Study Cell Tower Impact Study 739 Wentworth Ave Mendota Heights, MN 55118 Report Date: April 21, 2026 FOR: Scott Buell Buell Consulting, Inc. 9973 Valley View Road Eden Prairie, MN 55344 Valbridge Property Advisors Minneapolis | St. Paul 1515 Central Parkway, Suite 120 Eagan, MN 55121 (651) 370-1475 Phone Valbridge Job No: 2026-9876 valbridge.com Page 117 of 473 CELL TOWER IMPACT STUDY TABLE OF CONTENTS 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page i 1515 Central Parkway, Suite 120 Eagan, MN 55121 (651) 370-1475 valbridge.com April 21, 2026 Scott Buell Buell Consulting, Inc. 9973 Valley View Road Eden Prairie, MN 55344 RE: Appraisal Report Cell Tower Impact Study 739 Wentworth Ave. Mendota Heights, MN Dear Scott Buell: In accordance with your request, we have prepared a Value Impact Study of the proposed cell tower located at 739 Wentworth Ave, Mendota Heights MN. This report sets forth the pertinent data gathered, the techniques employed, and the reasoning leading to our opinions. The purpose of this report is to examine the potential impact the proposed project could have on property values of adjacent properties. We developed the analyses, opinions, and conclusions and prepared this report in conformity with the Uniform Standards of Professional Appraisal Practice (USPAP) of the Appraisal Foundation. The client and intended user in this assignment is Buell Consulting, Inc. We understand the client may share the report with local public officials as a part of the zoning process. The proposed cell tower will be located in Wentworth Park at 739 Wentworth Avenue and is surrounded by residential uses and a public park. The client is proposing to construct a monopole tower on the site which will have a 145-foot elevation. The intended use is for zoning approval and to determine the effect the project will have on surrounding property values. The value opinions reported herein are subject to the definitions, assumptions limiting conditions, and certification contained in this report. Based upon the analysis, the report demonstrates the following: The proposed cell tower development will not measurably impact the value of surrounding properties. Page 118 of 473 CELL TOWER IMPACT STUDY TABLE OF CONTENTS 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page ii This letter of transmittal is not considered valid if separated from this report, and must be accompanied by all sections of this report as outlined in the Table of Contents, in order for the value opinions set forth above to be valid. Respectfully submitted, Valbridge Property Advisors | Minneapolis | St.-Paul Andrew Baker, MAI Director Valbridge Property Advisors | Minneapolis | St.-Paul Josh Folland, MAI, AI-GRS, CCIM Senior Managing Director Minnesota License No. 20352348 Page 119 of 473 CELL TOWER IMPACT STUDY TABLE OF CONTENTS 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page iii Table of Contents Cover Page Letter of Transmittal Table of Contents ................................................................................................................................................................................ iii Aerial and Front Views ....................................................................................................................................................................... iv Location Map ......................................................................................................................................................................................... v Paired Sales Conclusion .................................................................................................................................................................... vi Introduction ............................................................................................................................................................................................ 1 Scope of Work ....................................................................................................................................................................................... 3 City & Neighborhood Analysis ....................................................................................................................................................... 4 Description of the Project ................................................................................................................................................................. 8 Paired Sales Analysis ........................................................................................................................................................................ 15 Conclusions .......................................................................................................................................................................................... 41 General Assumptions & Limiting Conditions ......................................................................................................................... 49 Certification – Andrew Baker, MAI .............................................................................................................................................. 54 Certification – Josh Folland, MAI, CCIM ................................................................................................................................... 55 Addenda ................................................................................................................................................................................................ 56 Page 120 of 473 CELL TOWER IMPACT STUDY AERIAL AND FRONT VIEWS 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page iv Aerial and Front Views SITE VIEW FRONT VIEW (PROPOSED) Page 121 of 473 CELL TOWER IMPACT STUDY LOCATION MAP 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page v Location Map Page 122 of 473 CELL TOWER IMPACT STUDY PAIRED SALES CONCLUSION 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page vi Paired Sales Conclusion Paired Sales Conclusion Ref. Location Description Sale Date List Price Sale Price Sale/List Price Ratio Days on Market (DOM) Paired Sales Conclusion Broker Survey 1 8507 Campbell Ave Inver Grove Heights MN Single-Family Home Sep-24 $475,000 $475,000 100% 2 In-line with comparable sales No impact on sale price 2 340 18th Ave S. South Saint Paul, MN Single-Family Home Jan-25 $319,000 $307,500 96% 20 In-line with comparable sales No impact on sale price 3 6715 131st St W Apple Valley, MN Single-Family Home Mar-23 $439,900 $424,900 97% 15 In-line with comparable sales No impact on sale price 4 8450 Bechtel Ave Inver Grove Heights, MN Single-Family Home Sep-21 $449,900 $460,000 102% 16 In-line with comparable sales No impact on sale price 5 1196 105th St E. Inver Grove Heights, MN Single-Family Home Mar-25 $1,050,000 $1,050,000 100% 2 In-line with comparable sales No impact on sale price Page 123 of 473 CELL TOWER IMPACT STUDY INTRODUCTION 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 1 Introduction Client and Other Intended Users of the Appraisal The client and intended user in this assignment is Buell Consulting, Inc. We understand the client may choose to share this report with public officials as part of the zoning approval process. Intended Use of the Appraisal The intended use of this report is for zoning approval use. Location of the Proposed Tower Location: 739 Wentworth Ave. Mendota Heights, MN Latitude/Longitude: 44.898911, -93.112304 (Based on survey provided by the owner) Identification of Parcel Location: Wentworth Park Owner: City of Mendota Heights Identification of the Project Our identification of the project is based on our on-site inspection, public records, as well as information provided to us by the client. The purpose of this report is to analyze the potential impact the project could potentially have on the value of adjacent properties. Type and Definition of Value The purpose of this appraisal is to develop an opinion as to the potential impact the proposed project could potentially have on surrounding property values. According to the Dictionary of Real Estate Appraisal, Sixth Edition, “Market Value,” as used in this appraisal, is defined as “the most probable price that a property should bring in a competitive and open market under all conditions requisite to a fair sale, the buyer and seller each acting prudently and knowledgeably, and assuming the price is not affected by undue stimulus.” Implicit in this definition is the consummation of a sale as of a specified date and the passing of title from seller to buyer under conditions whereby: Buyer and seller are typically motivated. Both parties are well informed or well advised, each acting in what they consider their own best interests; A reasonable time is allowed for exposure in the open market; Payment is made in terms of cash in U.S. dollars or in terms of financial arrangements comparable thereto; and The price represents the normal consideration for the property sold unaffected by special or creative financing or sale concessions granted by anyone associated with the sale.” Page 124 of 473 CELL TOWER IMPACT STUDY INTRODUCTION 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 2 The as is value is the value of the property in its present condition under market conditions prevalent on the effective date of value. Please refer to the Glossary in the Addenda section for further definitions of value type(s) employed in this report. Valuation Scenarios and Effective Dates of Value Per the scope of the assignment we developed opinions of value for the subject property under the following scenarios for the identified property right interests as of the corresponding effective dates of value: Value Perspective Value Premise Effective Date of Value Current As Is April 16, 2026 Date of Report The date of this report is April 20, 2026, which is the same as the date of the letter of transmittal. Competency No steps were necessary to meet the competency provisions established by USPAP. We have familiarity and adequate experience with communication towers and impact studies. In addition, we are familiar with the market, geographic area, and applicable laws, regulations, and guidelines. Assumptions and Conditions of the Appraisal If there are extraordinary assumptions and/or hypothetical conditions used in this report, the use of these extraordinary assumptions and hypothetical conditions might have affected the assignment results. Extraordinary Assumptions An extraordinary assumption is defined as “An assumption, directly related to a specific assignment, as of the effective date of the assignment results, which, if found to be false, could alter the appraiser’s opinions or conclusions.” There are no extraordinary assumptions assumed in this appraisal. Hypothetical Conditions A hypothetical condition is defined as “A condition, directly related to a specific assignment, which is contrary to what is known by the appraisers to exist on the effective date of the assignment results, but is used for the purposes of analysis.” The report is based on the hypothetical condition the planned communication tower has been approved by the city and completed to determine any potential diminution in value to the surrounding properties. Page 125 of 473 CELL TOWER IMPACT STUDY SCOPE OF WORK 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 3 Scope of Work The scope of work includes all steps taken in the development of the appraisal. These include 1) the extent to which the subject property is identified, 2) the extent to which the subject property is inspected, 3) the type and extent of data researched, 4) the type and extent of analysis applied, and the type of appraisal report prepared. These items are discussed as follows: Extent to Which the Impacted Properties Was Identified The components of property identification are summarized as follows: Economic Characteristics Economic characteristics of the project were identified via a review of market surveys, interviews with market participants, as well as a comparison to properties with similar locational and physical characteristics. Physical Characteristics The subject area was physically identified via our on-site inspection. We have also analyzed information sent to us by the client, including maps and pictures of the proposed project. Extent to Which the Property Was Inspected Josh Folland, MAI, AI-GRS, CCIM inspected the subject location and surrounding neighborhood on April 16, 2026. Type and Extent of Data Researched We researched the project based upon information provided to us by the client. Based upon these factors, we analyzed the externalities of the project and its potential impact on the surrounding single-family homes. As part of the process, we conducted the following analysis: 1) A paired sales analysis of comparable agricultural properties and single-family homes located adjacent to a communication tower in similar markets in the local area. 2) Analysis of the listing history, including the sales price to list price ratio and the number of days on the market. 3) Interviews with brokers who have experienced selling single-family homes that are located adjacent to similar properties. Appraisal Conformity We developed the analyses, opinions, and conclusions and prepared this report in conformity with the Uniform Standards of Professional Appraisal Practice (USPAP) of the Appraisal Foundation; the Code of Professional Ethics and Standards of Professional Appraisal Practice of the Appraisal Institute; and the requirements of the client as we understand them. Page 126 of 473 CELL TOWER IMPACT STUDY CITY AND NEIGHBORHOOD ANALYSIS 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 4 City & Neighborhood Analysis REGIONAL MAP Overview The subject is located an in Mendota, Heights, MN. The area is suburban in nature. For the purposes of this report, the neighborhood boundaries are considered to be the City of Mendota Heights, which is outlined on the following page. Page 127 of 473 CELL TOWER IMPACT STUDY CITY AND NEIGHBORHOOD ANALYSIS 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 5 NEIGHBORHOOD MAP Demographic Analysis The following demographic information was obtained from the 2000 U.S. Census, 2010 U.S. Census, and Site to do Business (STDB) forecasts for 2025 and 2030. Neighborhood Demographics The following table shows demographics in the local area. Overall, the population is growing at a steady rate. Page 128 of 473 CELL TOWER IMPACT STUDY CITY AND NEIGHBORHOOD ANALYSIS 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 6 Housing Information The following table shows housing information in the local area. The majority of homes within a one-mile radius are owner occupied and the median home price of $610,906, according to ESRI. Neighborhood Demographics Radius (Miles)1 Mile 3 Mile 5 Mile Trade Area (Sq. Mi.)3.14 28.27 78.54 Trade Density (Pop/Sq. Mi.)1,846 3,400 3,668 Population Census Population (2010)4,831 81,366 238,639 Census Population (2020)5,212 86,749 257,026 Current Population (2025)5,216 88,327 264,837 Projected Population (2030)5,329 89,474 270,348 Compound Annual Growth 2010 - 2020 0.8%0.6%0.7% 2020 - 2025 0.0%0.4%0.6% 2025 - 2030 0.4%0.3%0.4% Households Census Households (2010)1,850 35,478 99,807 Census Households (2020)2,100 38,322 108,857 Current Households (2025)2,133 39,384 112,562 Projected Households (2030)2,217 40,015 114,999 Compound Annual Growth 2010 - 2020 1.3%0.8%0.9% 2020 - 2025 0.3%0.5%0.7% 2025 - 2030 0.8%0.3%0.4% Average Household Size (2025)2.43 2.21 2.26 Source: ESRI (ArcGIS)(Lat: 44.899173, Lon: -93.121636) Page 129 of 473 CELL TOWER IMPACT STUDY CITY AND NEIGHBORHOOD ANALYSIS 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 7 Conclusions The local area is suburban in nature, with residential uses in the immediate area. The local area is growing at a steady rate, and we anticipate continued growth for the foreseeable future. Neighborhood Demographics (cont.) Radius (Miles)1 Mile 3 Mile 5 Mile Trade Area (Sq. Mi.)3.14 28.27 78.54 Trade Density (Pop/Sq. Mi.)1,846 3,400 3,668 2025 Housing Units Median Home Value $610,906 $412,381 $392,068 Median Year Built 1976 1962 1956 Total Housing Units 2,282 41,868 119,937 Owner-Occupied Housing %79.1%51.8%47.1% Renter-Occupied Housing %14.4%42.3%46.7% Vacant Housing %6.5%5.9%6.1% 2025 Employment Total Establishments 159 2,841 10,611 Total Employees 1,629 40,426 191,729 Average Commute Time n/a n/a n/a % College Graduates 76.2%54.0%51.1% 2025 Income Summary Median Household Income $141,432 $84,975 $81,334 Average Household Income $177,558 $120,101 $113,068 Avg Spending/Household $48,185 $32,995 $31,031 Per Capita Income $72,956 $53,727 $48,080 Source: ESRI (ArcGIS)(Lat: 44.899173, Lon: -93.121636) Page 130 of 473 CELL TOWER IMPACT STUDY DESCRIPTION OF THE PROJECT 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 8 Description of the Project The following description is based on our property inspection, assessor records, and information provided by the client and owner. General Data Location: 739 Wentworth Ave. Mendota Heights, MN Latitude/Longitude: 44.898911, -93.112304 Tower Height: 145 Style: Monopole Tower Design Street Frontage / Access Access to the site will be provided by Wentworth Avenue, which is located to the south. Tower Design The subject design will be a monopole Tower Design. This type of design as a single tubular steel pole and is designed to carry antennas, mounts, and cabling. The area dedicated to the tower will have approximately 2,500 square feet, or 0.06 acres. Surrounding Uses The uses surrounding the site are primarily single-family in nature. Based on the survey conducted by Vertical Bridge, and included in the addenda of the report, the tower will be at a height of 145 feet. The tower will have a setback of 59.5 feet to the property to the west and 300 feet to the property to the south Based on our aerial measurements in Google Earth, the proposed tower will be approximately 400 feet to the homes to the north, south and west. The tower will have Verizon Wireless as a carrier, with space to add two additional carriers in the future if needed. Page 131 of 473 CELL TOWER IMPACT STUDY DESCRIPTION OF THE PROJECT 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 9 Zoning Designation Zoning Jurisdiction: Mendota Heights, Minnesota Zoning Classification: R-1 Permitted Uses: Low Density Residential Page 132 of 473 CELL TOWER IMPACT STUDY DESCRIPTION OF THE PROJECT 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 10 ELEVATION PLAN Page 133 of 473 CELL TOWER IMPACT STUDY DESCRIPTION OF THE PROJECT 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 11 PHOTOSIMS (PROVIDED BY CLIENT) VIEW FROM WENTWORTH AVE. Page 134 of 473 CELL TOWER IMPACT STUDY DESCRIPTION OF THE PROJECT 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 12 PHOTOSIMS (PROVIDED BY CLIENT) VIEW FROM WENTWORTH AVE. Page 135 of 473 CELL TOWER IMPACT STUDY DESCRIPTION OF THE PROJECT 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 13 VIEW FROM UPPER COLONIAL DR. Page 136 of 473 CELL TOWER IMPACT STUDY DESCRIPTION OF THE PROJECT 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 14 Site area Site area Site Area Wentworth Ave. Page 137 of 473 VALUE IMPACT STUDY PAIRED SALES ANALYSIS 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 15 Paired Sales Analysis Real estate markets are influenced by attitudes, interactions and the motivations of buyers and sellers in a particular market. Real estate values are affected by risk and future expectations. The proposed project will represent an externality to the surrounding residential properties, which is defined as: The principle that economies outside a property have a positive effect on value while diseconomies outside a property have a negative effect on value. In appraisal, off-site conditions that affect a property’s value. Exposure to street noise or proximity to blighted property may exemplify negative externality, whereas proximity to attractive or well- maintained properties or easy access to mass transit may exemplify positive externalities. In order to determine the impact of the externality, we have conducted paired sales analysis. According to The Appraisal of Real Estate, 14th Edition, published by the Appraisal Institute, paired data analysis is defined as follows: A quantitative technique used to identify and measure adjustments to the sale prices or rents of comparable properties; to apply this technique, sales or rental data on nearly identical properties except for one characteristic is analyzed to isolate the single characteristic’s effect on value or rent.1 The text also cautions that paired data analysis should be made with extreme care to ensure that the properties are truly comparable and that other differences do not exist.2 In order to determine the impact that the proposed project could potentially have on the value of surrounding residential properties, we have analyzed sales of homes and vacant lots that are located adjacent to communication towers with similar single-family homes that are not located adjacent to a communication tower. We have used the mapping feature on the North Star MLS and analyzed over 20 sites in the local area with cell towers and analyzed sales data going back to 2021. The majority of these sites did not have any properties that had recently sold near the cell tower site. In total, we have analyzed five sales at four different sites that are relevant to the subject. We have also attempted to interview the listing broker of each sale to determine if the tower impacted on the sale price or was a concern of market participants. For each sale, we contacted the listing broker via email and phone, leaving a voice message if necessary. We have asked open ended questions in a neutral way to determine what, if any, impact the communication tower had on the marketing of the property. Paired Sales Methodology The sales comparison approach is based on the premise that a buyer would pay no more for a specific property than the cost of obtaining a property with the same quality, utility, and perceived benefits of ownership. It is based on the principles of supply and demand, balance, substitution and externalities. In 1 The Appraisal of Real Estate, 14th Edition, Appraisal Institute, page 399 2 Ibid, page 398 Page 138 of 473 VALUE IMPACT STUDY PAIRED SALES ANALYSIS 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 16 the sales comparison approach, an indication of market value is developed by analyzing closed sales of similar properties, using the most relevant units of comparison. The comparative analysis focuses on the difference between the comparable sales and the subject property using all appropriate elements of comparison. Transactional Adjustments These items are applied prior to the application of property adjustments. Transaction adjustments include: 1. Real Property Rights Conveyed 2. Financing Terms 3. Conditions of Sale 4. Expenditures Made Immediately After Purchase 5. Market Conditions Real Property Rights Conveyed Before a comparable sale property can be used in the sales comparison approach, we must first ensure that the sale price of the comparable property applies to property rights that are similar to those being appraised. All of the sales should reflect a similar interest, and no adjustment is required for this element of comparison. Financing Terms The transaction price of one property may differ from that of an identical property due to different financial arrangements. Sales involving financing terms that are not at or near market terms require adjustments for cash equivalency to reflect typical market terms. A cash equivalency procedure discounts the atypical mortgage terms to provide an indication of value at cash equivalent terms. The sales sold as cash or cash equivalent and no adjustment for financing was required. Conditions of Sale When the conditions of sale are atypical, the result may be a price that is higher or lower than that of a normal transaction. Adjustments for conditions of sale usually reflect the motivations of either a buyer or a seller who is under duress to complete the transaction. The sales sold at market terms and no adjustment for conditions of sale was required. Expenditures Made Immediately After Purchase A knowledgeable buyer considers expenditures that will have to be made upon purchase of a property because these costs affect the price the buyer agrees to pay. Such expenditures may include: (1) costs to cure deferred maintenance, (2) costs to demolish and remove any portion of the improvements, (3) costs to petition for a zoning change, (4) costs to remediate environmental contamination and/or (5) costs to occupy or lease-up the property to a stabilized occupancy The relevant figure is not the actual cost incurred but the cost that was anticipated by both the buyer and seller. Unless the sales involved expenditures anticipated upon the purchase date, no adjustments to the comparable sales are required for this element of comparison. Market Conditions Adjustment Market conditions may change between the time of sale of a comparable property and the date of the appraisal of the subject property. Changes in market conditions may be caused by inflation, deflation, Page 139 of 473 VALUE IMPACT STUDY PAIRED SALES ANALYSIS 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 17 fluctuations in supply and demand, or other factors. Market conditions that change over time create the need for an adjustment. If market conditions have changed, an adjustment would be required for this element of comparison. Physical Adjustments Physical adjustments are usually expressed quantitatively as percentages that reflect the increase or decrease in value attributable to the various characteristics of the property. In some instances, however, qualitative adjustments are used. These adjustments are based on locational and physical characteristics and are applied after the application of transaction adjustments. The adjustments include: 1. Location 2. Physical Characteristics Location Location adjustments may be required when the locational characteristics of a comparable are different from those of the subject. These characteristics can include general neighborhood characteristics, freeway accessibility, street exposure, corner versus interior lot location, neighboring properties, view amenities, and other factors. Physical Characteristics Physical characteristics adjustment identifies variances in the physical features of the comparables and the subject improvements. These characteristics can include the size of single-family homes, number of bedrooms, number of bathrooms, year built, condition of the interior, quality of materials in the interior, garage space, and other factors. Paired Sale 1 – 8507 Campbell Ave., Inver Grove Heights, MN The following table summarizes the sales that will be analyzed in Paired Sale 1. The subject is the September 2024 sale of a single-family home located at 8507 Campbell Ave, Inver Grove Heights MN for a price of $475,000. The property had been listed for sale for $475,000 and sold after two days on the market. This home is located approximately 400-feet from a cell tower located to the northwest. This cell tower is about 150 feet in height, based on information from Celltowermaps.com The following shows an aerial map and a view of the sale. Page 140 of 473 VALUE IMPACT STUDY PAIRED SALES ANALYSIS 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 18 Photo from Google Street View Front View-2024 Page 141 of 473 VALUE IMPACT STUDY PAIRED SALES ANALYSIS 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 19 Aerial View We have compared this sale to three sales in the neighborhood that occurred near the same time. These sales were further removed from a cell tower and not considered to be impacted. The following table summarizes the salient data of the comparable sales. Page 142 of 473 VALUE IMPACT STUDY PAIRED SALES ANALYSIS 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 20 Front View - Sale 1 Front View - Sale 2 Front View - Sale 3 Improved Sales Summary SUBJECT Sale 1 Sale 2 Sale 3 Location 8507 Campbell Ave. Inver Grove Heights, MN 8496 Brewster Ave Inver Grove Heights, MN 3500 E. 78th St E. Inver Grove Heights, MN 8541 College Trail Inver Grove Heights, MN Tax ID Sales Data Date of Sale September-24 August-25 March-24 April-24 Property Rights Conveyed Fee Simple Fee Simple Fee Simple Fee Simple Financing Cash to Seller Cash to Seller Cash to Seller Cash to Seller Conditions of Sale Typical Typical Typical Typical Above Grade Finished Area:2,390 1,828 2,024 2,180 Total Finished Area 2,390 2,474 2,892 3,010 Year Built 1994 1993 1998 2001 No. of Bedrooms 4 3 5 4 No. of Bathrooms 3.0 2.0 3.0 4.0 No. of Garage Spaces 3223 Land Size (Ac.)0.481 acres 0.220 acres 0.360 acres 0.377 acres Unadjusted Units of Comparison Sales Price $475,000 $434,000 $495,000 $505,000 Price Per SF:$198.74 $175.42 $171.16 $167.77 Page 143 of 473 VALUE IMPACT STUDY PAIRED SALES ANALYSIS 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 21 Improved Sales Comparison Approach Adjustment Grid Subject Sale # 1 Sale 2 Sale 3 Date of Value & Sale N/A Property Name 8507 Campbell Ave. Inver Grove 8496 Brewster Ave Inver Grove 3500 E. 78th St E. Inver Grove Heights, MN 8541 College Trail Inver Grove Heights, MN GLA (Above Grade)2,390 1,828 2,024 2,180 Number of Units 1 units 1 1 1 Unadjusted Sales Price $475,000 $434,000 $495,000 $505,000 Unadjusted Sales Price per Unit $434,000 $495,000 $505,000FALSEFALSE Transactional Adjustments Property Rights Conveyed Fee Simple Fee Simple Fee simple Fee simple Adjusted Sales Price $434,000 $495,000 $505,000 FALSE FALSEFinancing Terms Cash to Seller Cash to Seller Cash to Seller Cash to Seller Adjusted Sales Price $434,000 $495,000 $505,000 FALSE FALSEConditions of Sale Typical Typical Typical Typical Adjusted Sales Price $434,000 $495,000 $505,000 FALSE FALSEExpenditures after Sale Adjustment -- - Adjusted Sales Price $434,000 $495,000 $505,000 Market Conditions Adjustments Elapsed Time from Date of V September-24 August-25 March-24 April-24 Market Trend Through N/A -- Analyzed Sales Price $434,000 $495,000 $505,000 00%00%Property Adjustments Location 8507 Campbell Ave. Inver Grove Heights, MN 8496 Brewster Ave Inver Grove Heights, MN 3500 E. 78th St E. Inver Grove Heights, MN 8541 College Trail Inver Grove Heights, MN , Adjustment Similar Similar Similar Similar 00%00%Size 2,390 1,828 2,024 2,180 Adjustment Similar Inferior Inferior Similar 00%00%Age/Condition Year Built 1994 1993 1998 2001 Condition Average Average Average Average Adjustment Similar Superior Similar 00%00%Bedrooms/Bethrooms 4/3 3/2 5/3 4/4 Adjustment Similar Inferior Superior Superior 00%r 00%Finished Basement Adjustment Superior Similar Similar 00%00%Land Area 0.481 .22 .36 .377 Adjustment Similar Similar Similar Net Physical Adjustment Inferior Superior Superior Adjusted Sales Price per Unit $434,000 $495,000 $505,000 Page 144 of 473 VALUE IMPACT STUDY PAIRED SALES ANALYSIS 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 22 Property Adjustments - Paired Sale 1 The subject property sold for a price of $475,000, or $181.45 per square foot. The comparable sales sold for a range of $434,000 to $505,000. . Sale 1 is somewhat inferior to the subject as this property only had three bedrooms and two bathrooms. Sales 2 and 3 are considered to be superior to the subject as they each had finished basements. Overall, there were not any nearly identical sales as the subject did not have a finished basement, which was not typical in the neighborhood and is considered inferior to other homes.. Sales History The subject property was listed for sale for a price of $475,000. The property sold for a price of $475,000, which was in-line with the listing price, after only two days on the market. Broker Survey We e-mailed the listing broker, Cari Linn with the Walker Linn Team,, to determine how cell tower had impacted the marketing and sale price. Ms. Linn was acting as the seller’s broker. Here is her response: “The cell towers around this property were not taken into consideration for pricing and it did not play into the negotiation of the sale. To my knowledge, there were no comments from any potential buyers regarding the cell towers, however, this home sold in two days.” Conclusion The sale price was in-line with the list price and occurred after a brief period on the market (two days). The price was in-line other similar homes in the neighborhood. The listing broker said that the sale was not impacted by the presence of the cell tower in this instance. Based upon the evidence, we conclude that cell tower did not impact the sale price. Page 145 of 473 VALUE IMPACT STUDY PAIRED SALES ANALYSIS 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 23 Paired Sale 2 – 340 18th Ave S., South Saint Paul MN The subject is the January 2025 sale of a single-family home located at 340 18th Ave S. that sold for a price of $307,500. The property had been listed for sale for $319,900 and sold after 20 days on the market. This home is located 320 feet from a water tower with cell equipment. The following shows an aerial map and front view of the sale. Front View Page 146 of 473 VALUE IMPACT STUDY PAIRED SALES ANALYSIS 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 24 Aerial We have compared this sale to other similar properties in the neighborhood that occurred near the time of the sale. Page 147 of 473 VALUE IMPACT STUDY PAIRED SALES ANALYSIS 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 25 Front View - Sale 1 Front View - Sale 2 Improved Sales Summary SUBJECT Sale 1 Sale 2 Sale # 3 Location 340 18th Ave. S. South Saint Paul, MN 315 18th Ave. S. South Saint Paul MN 217 22nd Ave South Saint Paul,, MN 208 22nd Ave. S. south Saint Paul MN Sales Data Date of Sale January-25 September-24 April-24 November-24 Property Rights Conveyed Fee Simple Fee Simple Fee Simple Fee Simple Financing Cash to Seller Cash to Seller Cash to Seller Cash to Seller Conditions of Sale Typical Typical Typical Typical Property Type Ranch Ranch Split Level Split Level Above Grade Finished Area 1,131 1,228 1,196 1,125 Total Finished Area 1,761 1,984 1,638 1,700 Year Built 1955 1965 1961 1960 No. of Bedrooms 3334 No. of Bathrooms 2.0 2.0 2.0 2.0 No. of Garage Spaces 1111 Basement:Yes, partially finished Yes, Partially Finished Yes, partially finihsed Yes, Partially Finished Land Size (Ac.)0.231 acres 0.186 acres 0.190 acres 0.182 acres Unadjusted Units of Comparison Sales Price $307,500 $280,000 $300,000 $315,000 Price Per SF:$271.88 $228.01 $250.84 $280.00 Page 148 of 473 VALUE IMPACT STUDY PAIRED SALES ANALYSIS 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 26 Front View - Sale 3 We have compared the subject to similar homes in terms of above grade finished space, year built, number of bathrooms and bedrooms, basement space, and land area. Page 149 of 473 VALUE IMPACT STUDY PAIRED SALES ANALYSIS 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 27 Property Adjustments - Paired Sale 2 Analysis of sale of other properties within this neighborhood report a price ranging from $280,000 to $315,000. Overall, the sale price of the subject is in-line with the other sales. Sales 1 and 2 are deemed be the most similar to the subject. Sale 3 contains an extra bedroom, and is somewhat superior. . Sales History The subject property was listed for sale for a price of $319,000. The property sold for a price of $307,500, Improved Sales Comparison Approach Adjustment Grid Subject Sale # 1 Sale # 2 Sale # 3 Sale ID 340 18th Ave. S. South Saint Paul, MN 315 18th Ave. S. South Saint Paul MN 217 22nd Ave South Saint Paul,, MN 208 22nd Ave. S. South Saint Paul MN Date of Value & Sale N/A Property Name 340 18th Ave. S. South Saint Paul, MN 315 18th Ave. S. South Saint Paul MN 217 22nd Ave South Saint Paul,, MN 208 22nd Ave. S. south Saint Paul MN GLA 1,131 1,228 1,196 1,125 Unadjusted Sales Price $307,500 $280,000 $300,000 $315,000 Unadjusted Sales Price per Unit $280,000 $300,000 $315,000 Market Trend Through N/A -- - Analyzed Sales Price $280,000 $300,000 $315,000 00%00%00%Property Adjustments Location , Relative Comparison Similar Similar Similar 00%00%00%Size 1,131 units 1,228 units 1,196 units 1,125 units Relative Comparison Similar Similar Similar 00%00%00%Age/Condition Year Built 1955 1965 1961 1960 Condition 0 Relative Comparison Similar Similar Similar 00%00%00%Bedrooms/Bathrooms 3/2 3/2 3/2 4/2 Relative Comparison Similar Similar Superior 00%00%00%Finished Basement Relative Comparison Similar Similar Similar 00%00%00%Land Area Relative Comparison Similar Similar Similar Overall Net Relative Comparison Similar Similar Slightly Superior Page 150 of 473 VALUE IMPACT STUDY PAIRED SALES ANALYSIS 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 28 with was 96% of the listing price, after 20 days on the market. Broker Survey We spoke with the listing broker, Kimberly Wong with the Graham Smith Team, over the phone. Here are our notes from the call: I do remember that house and sale. I do not remember any comments from anyone about the tower. Conclusion Overall, the sale price is considered to be in-line with the similar homes in the neighborhood.. According to the MLS Listing, the property sold after a short time on the market. The listing broker informed us that there were no comments from potential buyers about the water tower with cell equipment. Therefore, we conclude that the water tower with cell equipment did not impact the sale or the subject. Page 151 of 473 VALUE IMPACT STUDY PAIRED SALES ANALYSIS 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 29 Paired Sale 3 – 6715 131st St W, Apple Valley MN The subject is the March 2023 sale of a single-family home located at 6715 131st St W, Apple Valley MN. that sold for a price of $424,900. The property had been listed for sale for $439,900 and sold after 15 days on the market. This home is located 320 feet from a water tower with cell equipment. The following shows an aerial map and front view of the sale. Front View Page 152 of 473 VALUE IMPACT STUDY PAIRED SALES ANALYSIS 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 30 Aerial We have compared this sale to other similar properties in the neighborhood that occurred near the time of the sale. Page 153 of 473 VALUE IMPACT STUDY PAIRED SALES ANALYSIS 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 31 Front View - Sale 1 Front View - Sale 2 Improved Sales Summary SUBJECT Sale 1 Sale 2 Sale # 3 Location 6715 131st St W, Apple Valley MN 13770 Fordham Ave Apple Valley MN 13952 Galway Court Apple Valley MN 6161 Fernando Court Apple Valley, MN Sales Data Date of Sale April-23 December-23 September-22 June-23 Property Rights Conveyed Fee Simple Fee Simple Fee Simple Fee Simple Financing Cash to Seller Cash to Seller Cash to Seller Cash to Seller Conditions of Sale Typical Typical Typical Typical Property Type Two Story One Story One Story Split Level Above Grade Finished Area 1,932 1,889 1,744 1,528 Total Finished Area 2,706 2,576 2,646 2,475 Year Built 1989 1970 1969 1973 No. of Bedrooms 3434 No. of Bathrooms 4.0 3.0 3.0 4.0 No. of Garage Spaces 2222 Basement: Yes, Finished Yes, Finished Yes, finished Yes, finished Land Size (Ac.) 0.231 acres 0.590 acres 0.574 acres 0.380 acres Unadjusted Units of Comparison Sales Price $424,900 $420,000 $424,900 $425,000 Price Per SF: $219.93 $222.34 $243.64 $278.14 Page 154 of 473 VALUE IMPACT STUDY PAIRED SALES ANALYSIS 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 32 Front View - Sale 3 We have compared the subject to similar homes in the neighborhood. Page 155 of 473 VALUE IMPACT STUDY PAIRED SALES ANALYSIS 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 33 Improved Sales Comparison Approach Adjustment Grid Subject Sale # 1 Sale # 2 Sale # 3 Sale ID 6715 131st St W, Apple Valley MN 13770 Fordham Ave Apple Valley MN 13952 Galway Court Apple Valley MN 6161 Fernando Court Apple Valley, MN Date of Value & Sale N/A Property Name 6715 131st St W, Apple Valley MN 13770 Fordham Ave Apple Valley MN 13952 Galway Court Apple Valley MN 6161 Fernando Court Apple Valley, MN GLA 1,932 1,889 1,744 1,528 Unadjusted Sales Price $424,900 $420,000 $424,900 $425,000 Unadjusted Sales Price per Unit $420,000 $424,900 $425,000000 Transactional Adjustments Property Rights Conveyed Fee Simple Fee Simple Fee Simple Fee Simple 00Seller Inventive Financing Terms Cash to Seller Cash to Seller Cash to Seller -$2,000.00 0 0 0Conditions of Sale Typical Typical Typical Typical 0 0 0Expenditures after Sale Adjustment -- - Market Conditions Adjustments Elapsed Time from Date of Value 0.00 years 0.00 years 0.00 years Market Trend Through N/A -- - Analyzed Sales Price $420,000 $424,900 $423,000 00%00%00%Property Adjustments Location , Relative Comparison Similar Similar Similar 00%00%00%Size 1,932 1,889 1,744 1,528 Relative Comparison Similar Similar Inferior 00%00%00%Age/Condition Year Built 1989 1970 1969 1973 Relative Comparison Similar Similar Similar 00%00%00%Bedrooms/Bathrooms 3/4 4/3 3/3 4/4 Relative Comparison Similar Inferior Superior 00%00%00%Finished Basement Relative Comparison Similar Similar Similar 00%00%00%Land Area Relative Comparison Similar Similar Similar Overall Net Relative Comparison Similar Slightly inferior Similar Page 156 of 473 VALUE IMPACT STUDY PAIRED SALES ANALYSIS 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 34 Property Adjustments - Paired Sale 3 Analysis of sale of other properties within this neighborhood report a price ranging from $420,000 to $425,000. Overall, the sale price of the subject is in-line with the other sales. Sale 1 and 2 is deemed be the most similar to the subject. Sale 1 and 3 has one more bedroom.. Sale 3 contains less above grade finished space, but a similar level of overall finished space and one more bedroom. Sales History The subject property was listed for sale for a price of $439,900. The property sold for a price of $424,900 with was 97% of the listing price, after 15 days on the market. Broker Survey We spoke with the listing broker, Scott Lindquist with Imagine Realty, over the phone. Here are our notes from the call: With cell towers, you are losing some potential buyers. However, at the end of the day sellers set the price and get the price that they want. Conclusion Overall, the sale price is considered to be in-line with the similar homes in the neighborhood.. According to the MLS Listing, the property sold after a short time on the market. The listing broker informed us that there was no impact on price from the tower. Therefore, we conclude that the water tower with cell equipment did not impact the sale of the subject. Page 157 of 473 VALUE IMPACT STUDY PAIRED SALES ANALYSIS 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 35 Paired Sale 4 – 8450 Bechtel Ave, Inver Grove Heights MN The subject is the September 2021 sale of a single-family home located 8450 Bechtel Ave., Inver Grove Heights MN that sold for a price of $460,000. The property had been listed for sale for $449,900 and sold after 16 days on the market. This home is located about 200 feet from a cell tower that is 150 feet in height. The following shows an aerial map and front view of the sale. Front View Page 158 of 473 VALUE IMPACT STUDY PAIRED SALES ANALYSIS 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 36 Aerial We have compared this sale to other similar properties in the neighborhood that occurred near the time of the sale. Page 159 of 473 VALUE IMPACT STUDY PAIRED SALES ANALYSIS 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 37 Front View - Sale 1 Front View - Sale 2 Improved Sales Summary SUBJECT Sale 1 Sale 2 Sale 3 Location 8450 Bechtel Ave. Inver Grove Heights, MN 9237 Cheny Trail Inver Grove Heights, MN 8462 Bryce Court, Inver Grove Heights MN 8444 Brewster Ave. Inver Grove Heights MN Tax ID Sales Data Date of Sale September-21 February-21 March-21 August-21 Property Rights Conveyed Fee Simple Fee Simple Fee Simple Fee Simple Financing Cash to Seller Cash to Seller Cash to Seller Cash to Seller Conditions of Sale Typical Typical Typical Typical Above Grade Finished Area:2,180 1,871 2,200 2,140 Total Finished Area 3,060 2,757 3,098 2,952 Year Built 1994 2001 1995 1996 No. of Bedrooms 6455 No. of Bathrooms 5.0 4.0 4.0 3.0 No. of Garage Spaces 2333 Land Size (Ac.)0.190 acres 0.231 acres 0.270 acres 0.181 acres Unadjusted Units of Comparison Sales Price $460,000 $447,000 $457,000 $470,000 Price Per SF:$211.01 $238.91 $207.73 $219.63 Page 160 of 473 VALUE IMPACT STUDY PAIRED SALES ANALYSIS 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 38 Front View - Sale 3 We have compared the subject to similar homes in terms of above grade finished space, year built, number of bathrooms and bedrooms, basement space, and land area. Page 161 of 473 VALUE IMPACT STUDY PAIRED SALES ANALYSIS 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 39 Improved Sales Comparison Approach Adjustment Grid Subject Sale # 1 Sale 2 Sale 3 Date of Value & Sale N/A Property Name 8450 Bechtel Ave. Inver Grove Heights, MN 9237 Cheny Trail Inver Grove Heights, MN 8462 Bryce Court, Inver Grove Heights MN 8444 Brewster Ave. Inver Grove GLA (Above Grade) 2,390 1,828 2,024 2,180 Number of Units 1 units 1 1 1 Unadjusted Sales Price $460,000 $447,000 $457,000 $470,000 Unadjusted Sales Price per Unit $447,000 $457,000 $470,000FALSEFALSE Transactional Adjustments Property Rights Conveyed Fee Simple Fee Simple Fee simple Fee simple Adjusted Sales Price $447,000 $457,000 $470,000 FALSE FALSEFinancing Terms Cash to Seller Cash to Seller Cash to Seller Cash to Seller Adjusted Sales Price $447,000 $457,000 $470,000 FALSE FALSEConditions of Sale Typical Typical Typical Typical Adjusted Sales Price $447,000 $457,000 $470,000 FALSE FALSEExpenditures after Sale Adjustment -- - Adjusted Sales Price $447,000 $457,000 $470,000 Market Conditions Adjustments Elapsed Time from Date of V September-21 February-21 March-21 August-21 Market Trend Through N/A -- Analyzed Sales Price $447,000 $457,000 $470,000 00%00%Property Adjustments Location 8450 Bechtel Ave. Inver Grove Heights, MN 9237 Cheny Trail Inver Grove Heights, MN 8462 Bryce Court, Inver Grove Heights MN 31577 Kalla Lake Road Avon Mn , Adjustment Similar Similar Similar Similar 00%00%Size 2,180 1,871 2,200 2,140 Adjustment Similar Inferior Similar Similar 00%00%Age/Condition Year Built 1994 2001 1995 1996 Condition Average Average Average Average Adjustment Similar Superior Similar 00%00%Bedrooms/Bethrooms 6/5 4/4 5/4 5/3 Adjustment Similar Inferior Similar Inferior 00%r 00%Finished Basement Adjustment Similar Similar Similar 00%00%Land Area 0.19 .231 .27 .181 Adjustment Similar Similar Similar Net Physical Adjustment Inferior Similar Similar Adjusted Sales Price per Unit $447,000 $457,000 $470,000 Page 162 of 473 VALUE IMPACT STUDY PAIRED SALES ANALYSIS 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 40 Property Adjustments - Paired Sale 4 Analysis of sale of other properties within this neighborhood report a price ranging from $447,000 to $470,000. Overall, the sale price of the subject is in-line with the other sales. Sale 1 is deemed be inferior to the subject due to its smaller size. Sale 2 is considered to be the most similar. Sale 3 is also considered to be similar, although this property has two fewer bathrooms. Sales History The subject property was listed for sale for a price of $449,900. The property sold for a price of $460,000 with was 102% of the listing price, after 16 days on the market. Broker Survey We spoke with the listing broker, Connie Wolke with Cardinal Realty Corp, over the phone. Here are our notes from the call: Broker had previously acted as the buyer’s broker when the current seller had purchased the property. The towers were behind the house and had trees. Nobody ever said anything during the sales process about the tower. Conclusion Overall, the sale price is considered to be in-line with the similar homes in the neighborhood.. According to the MLS Listing, the property sold after a short time on the market at a price that has higher than the list price. The listing broker informed us that there was no comments on the property from potential buyers. Therefore, we conclude that the cell tower did not impact the sale of the subject. Page 163 of 473 VALUE IMPACT STUDY PAIRED SALES ANALYSIS 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 41 Paired Sale 5 – 1196 105th St E., Inver Grove Heights MN The subject is the March 2025 sale of a single-family home located 1196 105th Street, Inver Grove Heights MN that sold for a price of $1,050,000. The property had been listed for sale for $1,050,000 and sold after four days on the market. This home is located about 300 feet from a cell tower that is 250 feet in height. The following shows an aerial map and front view of the sale. Front View Page 164 of 473 VALUE IMPACT STUDY PAIRED SALES ANALYSIS 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 42 Aerial We have compared this sale to other similar properties in the neighborhood that occurred near the time of the sale. Page 165 of 473 VALUE IMPACT STUDY PAIRED SALES ANALYSIS 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 43 Front View - Sale 1 Front View - Sale 2 Improved Sales Summary SUBJECT Sale 1 Sale 2 Sale # 3 Location 1196 105th St E Inver Grove Heights, MN 11569 Amameda Ave. Inver Grove Heights, 2324 99h St E Inver Grove Heights, MN 8915 Alverno Ave. Inver Grove Heights, MN Sales Data Date of Sale May-25 June-24 November-25 September-24 Property Rights Conveyed Fee Simple Fee Simple Fee Simple Fee Simple Financing Cash to Seller Cash to Seller Cash to Seller Cash to Seller Conditions of Sale Typical Typical Typical Typical Property Type Two Story Two Story Two Story Two Story Above Grade Finished Area 3,124 2,598 2,697 2,708 Total Finished Area 4,323 4,670 4,271 4,410 Year Built 2006 2001 2001 2014 No. of Bedrooms 4544 No. of Bathrooms 4.0 5.0 4.0 4.0 No. of Garage Spaces 6344 Basement:Yes, Finished Yes, Finished Yes, finished Yes, finished Land Size (Ac.)2.510 acres 2.570 acres 2.620 acres 2.910 acres Unadjusted Units of Comparison Sales Price $1,050,000 $920,000 $950,000 $1,070,000 Price Per SF:$336.11 $354.12 $352.24 $395.13 Page 166 of 473 VALUE IMPACT STUDY PAIRED SALES ANALYSIS 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 44 Front View - Sale 3 We have compared the subject to similar homes in terms of above grade finished space, year built, number of bathrooms and bedrooms, basement space, and land area. Page 167 of 473 VALUE IMPACT STUDY PAIRED SALES ANALYSIS 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 45 Property Adjustments - Paired Sale 5 Analysis of sale of other properties within this neighborhood report a price ranging from $920,000 to $1,070,000. Overall, the sale price of the subject is in-line with the other sales. Sale 1 has a smaller size Page 168 of 473 VALUE IMPACT STUDY PAIRED SALES ANALYSIS 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 46 but more bedrooms and bathrooms and is considered to be similar. Sale 2 is deemed be inferior to the subject due to its smaller size. Sale 3 has a smaller size, but more recent construction and it considered to be similar. Sales History The subject property was listed for sale for a price of $1,050,000. The property sold for a price of $1,050,000 with was in-line with the listing price, after two days on the market. Broker Survey We e-mailed the listing broker, Jay Ettinger with Edina Realty, to determine how cell tower had impacted the marketing and sale price. Mr. Ettinger was acting as the seller’s broker. Here is his response: “I don’t remember a cell tower being a consideration positive or negative with the sale of this property.” Conclusion Overall, the sale price is considered to be in-line with the similar homes in the neighborhood. According to the MLS Listing, the property sold after a short time on the market at a price that was in-line with the list price. Therefore, we conclude that the cell tower did not impact the sale or the subject. Page 169 of 473 VALUE IMPACT STUDY PAIRED SALES ANALYSIS 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 47 Conclusions In determining the potential diminution in value due to the proximity of a cell tower, we analyzed sales data and interviewed knowledgeable market participants. We conducted a paired sales analysis of single-family homes located near cell towers in the local area. We analyzed a total of five paired sales, at different neighborhoods, time periods and price points within the local area. Of the paired sales analyzed, each of them was in-line with the paired sales. In addition, we spoke with four local brokers who reported that the cell tower did not impact on the marketing or sale price. Finally, we note that each of the sales sold after a brief time on the market and at a price that was generally in-line with the list price, which is consistent with the market. In summary, real estate markets are influenced by attitudes, interactions and the motivations of buyers and sellers in a particular market. Based upon our interviews with market participants, a review of impacted sales in the local market, we conclude the following: The proposed cell tower will not measurably impact the value of surrounding properties. Paired Sales Conclusion Ref. Location Description Sale Date List Price Sale Price Sale/List Price Ratio Days on Market (DOM) Paired Sales Conclusion Broker Survey 1 8507 Campbell Ave Inver Grove Heights MN Single-Family Home Sep-24 $475,000 $475,000 100% 2 In-line with comparable sales No impact on sale price 2 340 18th Ave S. South Saint Paul, MN Single-Family Home Jan-25 $319,000 $307,500 96% 20 In-line with comparable sales No impact on sale price 3 6715 131st St W Apple Valley, MN Single-Family Home Mar-23 $439,900 $424,900 97% 15 In-line with comparable sales No impact on sale price 4 8450 Bechtel Ave Inver Grove Heights, MN Single-Family Home Sep-21 $449,900 $460,000 102% 16 In-line with comparable sales No impact on sale price 5 1196 105th St E. Inver Grove Heights, MN Single-Family Home Mar-25 $1,050,000 $1,050,000 100% 2 In-line with comparable sales No impact on sale price Page 170 of 473 VALUE IMPACT STUDY PAIRED SALES ANALYSIS 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 48 Respectfully submitted, Valbridge Property Advisors | Minneapolis | St. Paul Andrew Baker, MAI Director Valbridge Property Advisors | Minneapolis | St. Paul Josh Folland, MAI, AI-GRS, CCIM Senior Managing Director Minnesota License No. 20352348 Page 171 of 473 CELL TOWER IMPACT STUDY GENERAL ASSUMPTIONS & LIMITING CONDITIONS 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 49 General Assumptions & Limiting Conditions This appraisal is subject to the following limiting conditions: 1. The legal description – if furnished to us – is assumed to be correct. 2. No responsibility is assumed for legal matters, questions of survey or title, soil or subsoil conditions, engineering, availability or capacity of utilities, or other similar technical matters. The appraisal does not constitute a survey of the property appraised. All existing liens and encumbrances have been disregarded and the property is appraised as though free and clear, under responsible ownership and competent management unless otherwise noted. 3. Unless otherwise noted, the appraisal will value the property as though free of contamination. Valbridge Property Advisors | Minneapolis | St. Paul will conduct no hazardous materials or contamination inspection of any kind. It is recommended that the client hire an expert if the presence of hazardous materials or contamination poses any concern. 4. The stamps and/or consideration placed on deeds used to indicate sales are in correct relationship to the actual dollar amount of the transaction. 5. Unless otherwise noted, it is assumed there are no encroachments, zoning violations or restrictions existing in the subject property. 6. The appraiser is not required to give testimony or attendance in court by reason of this appraisal, unless previous arrangements have been made. 7. Unless expressly specified in the engagement letter, the fee for this appraisal does not include the attendance or giving of testimony by Appraiser at any court, regulatory, or other proceedings, or any conferences or other work in preparation for such proceeding. If any partner or employee of Valbridge Property Advisors | Minneapolis | St. Paul is asked or required to appear and/or testify at any deposition, trial, or other proceeding about the preparation, conclusions or any other aspect of this assignment, client shall compensate Appraiser for the time spent by the partner or employee in appearing and/or testifying and in preparing to testify according to the Appraiser’s then current hourly rate plus reimbursement of expenses. 8. The values for land and/or improvements, as contained in this report, are constituent parts of the total value reported and neither is (or are) to be used in making a summation appraisal of a combination of values created by another appraiser. Either is invalidated if so used. 9. The dates of value to which the opinions expressed in this report apply are set forth in this report. We assume no responsibility for economic or physical factors occurring at some point at a later date, which may affect the opinions stated herein. The forecasts, projections, or operating estimates contained herein are based on current market conditions and anticipated short-term supply and demand factors and are subject to change with future conditions. 10. The sketches, maps, plats and exhibits in this report are included to assist the reader in visualizing the property. The appraiser has made no survey of the property and assumed no responsibility in Page 172 of 473 CELL TOWER IMPACT STUDY GENERAL ASSUMPTIONS & LIMITING CONDITIONS 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 50 connection with such matters. 11. The information, estimates and opinions, which were obtained from sources outside of this office, are considered reliable. However, no liability for them can be assumed by the appraiser. 12. Possession of this report, or a copy thereof, does not carry with it the right of publication. Neither all, nor any part of the content of the report, or copy thereof (including conclusions as to property value, the identity of the appraisers, professional designations, reference to any professional appraisal organization or the firm with which the appraisers are connected), shall be disseminated to the public through advertising, public relations, news, sales, or other media without prior written consent and approval. 13. No claim is intended to be expressed for matters of expertise that would require specialized investigation or knowledge beyond that ordinarily employed by real estate appraisers. We claim no expertise in areas such as, but not limited to, legal, survey, structural, environmental, pest control, mechanical, etc. 14. This appraisal was prepared for the sole and exclusive use of the client for the function outlined herein. Any party who is not the client or intended user identified in the appraisal or engagement letter is not entitled to rely upon the contents of the appraisal without express written consent of Valbridge Property Advisors | Minneapolis | St. Paul and Client. The Client shall not include partners, affiliates, or relatives of the party addressed herein. The appraiser assumes no obligation, liability or accountability to any third party. 15. Distribution of this report is at the sole discretion of the client, but no third-parties not listed as an intended user on the face of the appraisal or the engagement letter may rely upon the contents of the appraisal. In no event shall client give a third-party a partial copy of the appraisal report. We will make no distribution of the report without the specific direction of the client. 16. This appraisal shall be used only for the function outlined herein, unless expressly authorized by Valbridge Property Advisors | Minneapolis | St. Paul. 17. This appraisal shall be considered in its entirety. No part thereof shall be used separately or out of context. 18. Unless otherwise noted in the body of this report, this appraisal assumes that the subject property does not fall within the areas where mandatory flood insurance is effective. Unless otherwise noted, we have not completed nor have we contracted to have completed an investigation to identify and/or quantify the presence of non-tidal wetland conditions on the subject property. Because the appraiser is not a surveyor, he or she makes no guarantees, express or implied, regarding this determination. 19. If the appraisal is for mortgage loan purposes 1) we assume satisfactory completion of improvements if construction is not complete, 2) no consideration has been given for rent loss during rent-up unless noted in the body of this report, and 3) occupancy at levels consistent with our “Income & Expense Projection” are anticipated. Page 173 of 473 CELL TOWER IMPACT STUDY GENERAL ASSUMPTIONS & LIMITING CONDITIONS 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 51 20. It is assumed that there are no hidden or unapparent conditions of the property, subsoil, or structures which would render it more or less valuable. No responsibility is assumed for such conditions or for engineering which may be required to discover them. 21. Our inspection included an observation of the land and improvements thereon only. It was not possible to observe conditions beneath the soil or hidden structural components within the improvements. We inspected the buildings involved, and reported damage (if any) by termites, dry rot, wet rot, or other infestations as a matter of information, and no guarantee of the amount or degree of damage (if any) is implied. Condition of heating, cooling, ventilation, electrical and plumbing equipment is considered to be commensurate with the condition of the balance of the improvements unless otherwise stated. 22. This appraisal does not guarantee compliance with building code and life safety code requirements of the local jurisdiction. It is assumed that all required licenses, consents, certificates of occupancy or other legislative or administrative authority from any local, state or national governmental or private entity or organization have been or can be obtained or renewed for any use on which the value conclusion contained in this report is based unless specifically stated to the contrary. 23. When possible, we have relied upon building measurements provided by the client, owner, or associated agents of these parties. In the absence of a detailed rent roll, reliable public records, or “as-built” plans provided to us, we have relied upon our own measurements of the subject improvements. We follow typical appraisal industry methods; however, we recognize that some factors may limit our ability to obtain accurate measurements including, but not limited to, property access on the day of inspection, basements, fenced/gated areas, grade elevations, greenery/shrubbery, uneven surfaces, multiple story structures, obtuse or acute wall angles, immobile obstructions, etc. Professional building area measurements of the quality, level of detail, or accuracy of professional measurement services are beyond the scope of this appraisal assignment. 24. We have attempted to reconcile sources of data discovered or provided during the appraisal process, including assessment department data. Ultimately, the measurements that are deemed by us to be the most accurate and/or reliable are used within this report. While the measurements and any accompanying sketches are considered to be reasonably accurate and reliable, we cannot guarantee their accuracy. Should the client desire a greater level of measuring detail, they are urged to retain the measurement services of a qualified professional (space planner, architect or building engineer). We reserve the right to use an alternative source of building size and amend the analysis, narrative and concluded values (at additional cost) should this alternative measurement source reflect or reveal substantial differences with the measurements used within the report. 25. In the absence of being provided with a detailed land survey, we have used assessment department data to ascertain the physical dimensions and acreage of the property. Should a survey prove this information to be inaccurate, we reserve the right to amend this appraisal (at additional cost) if substantial differences are discovered. 26. If only preliminary plans and specifications were available for use in the preparation of this appraisal, then this appraisal is subject to a review of the final plans and specifications when available (at additional cost) and we reserve the right to amend this appraisal if substantial differences are discovered. Page 174 of 473 CELL TOWER IMPACT STUDY GENERAL ASSUMPTIONS & LIMITING CONDITIONS 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 52 27. Unless otherwise stated in this report, the value conclusion is predicated on the assumption that the property is free of contamination, environmental impairment or hazardous materials. Unless otherwise stated, the existence of hazardous material was not observed by the appraiser and the appraiser has no knowledge of the existence of such materials on or in the property. The appraiser, however, is not qualified to detect such substances. The presence of substances such as asbestos, urea-formaldehyde foam insulation, or other potentially hazardous materials may affect the value of the property. No responsibility is assumed for any such conditions, or for any expertise or engineering knowledge required for discovery. The client is urged to retain an expert in this field, if desired. 28. The Americans with Disabilities Act (“ADA”) became effective January 26, 1992. We have not made a specific compliance survey of the property to determine if it is in conformity with the various requirements of the ADA. It is possible that a compliance survey of the property, together with an analysis of the requirements of the ADA, could reveal that the property is not in compliance with one or more of the requirements of the Act. If so, this could have a negative effect on the value of the property. Since we have no direct evidence relating to this issue, we did not consider possible noncompliance with the requirements of ADA in developing an opinion of value. 29. This appraisal applies to the land and building improvements only. The value of trade fixtures, furnishings, and other equipment, or subsurface rights (minerals, gas, and oil) were not considered in this appraisal unless specifically stated to the contrary. 30. No changes in any federal, state or local laws, regulations or codes (including, without limitation, the Internal Revenue Code) are anticipated, unless specifically stated to the contrary. 31. Any income and expense estimates contained in the appraisal report are used only for the purpose of estimating value and do not constitute prediction of future operating results. Furthermore, it is inevitable that some assumptions will not materialize and that unanticipated events may occur that will likely affect actual performance. 32. Any estimate of insurable value, if included within the scope of work and presented herein, is based upon figures developed consistent with industry practices. However, actual local and regional construction costs may vary significantly from our estimate and individual insurance policies and underwriters have varied specifications, exclusions, and non-insurable items. As such, we strongly recommend that the Client obtain estimates from professionals experienced in establishing insurance coverage. This analysis should not be relied upon to determine insurance coverage and we make no warranties regarding the accuracy of this estimate. 33. The data gathered in the course of this assignment (except data furnished by the Client) shall remain the property of the Appraiser. The appraiser will not violate the confidential nature of the appraiser- client relationship by improperly disclosing any confidential information furnished to the appraiser. Notwithstanding the foregoing, the Appraiser is authorized by the client to disclose all or any portion of the appraisal and related appraisal data to appropriate representatives of the Appraisal Institute if such disclosure is required to enable the appraiser to comply with the Bylaws and Regulations of such Institute now or hereafter in effect. 34. You and Valbridge Property Advisors | Minneapolis | St. Paul both agree that any dispute over matters in excess of $5,000 will be submitted for resolution by arbitration. This includes fee disputes Page 175 of 473 CELL TOWER IMPACT STUDY GENERAL ASSUMPTIONS & LIMITING CONDITIONS 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 53 and any claim of malpractice. The arbitrator shall be mutually selected. If Valbridge Property Advisors | Minneapolis | St. Paul and the client cannot agree on the arbitrator, the presiding head of the Local County Mediation & Arbitration panel shall select the arbitrator. Such arbitration shall be binding and final. In agreeing to arbitration, we both acknowledge that, by agreeing to binding arbitration, each of us is giving up the right to have the dispute decided in a court of law before a judge or jury. In the event that the client, or any other party, makes a claim against Valbridge Property Advisors | Minneapolis | St. Paul or any of its employees in connections with or in any way relating to this assignment, the maximum damages recoverable by Valbridge Property Advisors | Minneapolis | St. Paul for this assignment, and under no circumstances shall any claim for consequential damages be made. 35. Valbridge Property Advisors | Minneapolis | St. Paul shall have no obligation, liability, or accountability to any third party. Any party who is not the “client” or intended user identified on the face of the appraisal or in the engagement letter is not entitled to rely upon the contents of the appraisal without the express written consent of Valbridge Property Advisors | Minneapolis | St. Paul. “Client” shall not include partners, affiliates, or relatives of the party named in the engagement letter. Client shall hold Valbridge Property Advisors | Minneapolis | St. Paul and its employees harmless in the event of any lawsuit brought by any third party, lender, partner, or part-owner in any form of ownership or any other party as a result of this assignment. The client also agrees that in case of lawsuit arising from or in any way involving these appraisal services, client will hold Valbridge Property Advisors | Minneapolis | St. Paul harmless from and against any liability, loss, cost, or expense incurred or suffered by Valbridge Property Advisors | Minneapolis | St. Paul in such action, regardless of its outcome. 36. The Valbridge Property Advisors office responsible for the preparation of this report is independently owned and operated by Valbridge Property Advisors | Minneapolis | St. Paul. Neither Valbridge Property Advisors, Inc., nor any of its affiliates has been engaged to provide this report. Valbridge Property Advisors, Inc. does not provide valuation services, and has taken no part in the preparation of this report. 37. If any claim is filed against any of Valbridge Property Advisors, Inc., a Florida Corporation, its affiliates, officers or employees, or the firm providing this report, in connection with, or in any way arising out of, or relating to, this report, or the engagement of the firm providing this report, then (1) under no circumstances shall such claimant be entitled to consequential, special or other damages, except only for direct compensatory damages, and (2) the maximum amount of such compensatory damages recoverable by such claimant shall be the amount actually received by the firm engaged to provide this report. 38. This report and any associated work files may be subject to evaluation by Valbridge Property Advisors, Inc., or its affiliates, for quality control purposes. 39. Acceptance and/or use of this appraisal report constitutes acceptance of the foregoing general assumptions and limiting conditions. Page 176 of 473 CELL TOWER IMPACT STUDY CERTIFICATION 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 54 Certification – Andrew Baker, MAI I certify that, to the best of my knowledge and belief: 1. The statements of fact contained in this report are true and correct. 2. The reported analyses, opinions, and conclusions are limited only by the reported assumptions and limiting conditions and are my personal, impartial, and unbiased professional analyses, opinions, and conclusions. 3. I have no present or prospective interest in the property that is the subject of this report and no personal interest with respect to the parties involved. 4. The undersigned has not performed services regarding the property that is the subject of this report within the three-year period immediately preceding acceptance of this assignment. 5. I have no bias with respect to the property that is the subject of this report or to the parties involved with this assignment. 6. My engagement in this assignment was not contingent upon developing or reporting predetermined results. 7. My compensation for completing this assignment is not contingent upon the development or reporting of a predetermined value or direction in value that favors the cause of the client, the amount of value opinion, the attainment of a stipulated result, or the occurrence of a subsequent event directly related to the intended use of this appraisal. 8. My analyses, opinions and conclusions were developed, and this report has been prepared, in conformity with the Uniform Standards of Professional Appraisal Practice. 9. Andrew Baker has not personally inspected the subject property. 10. Nobody provided significant appraisal assistance to anyone signing this report. 11. The reported analyses, opinions and conclusions were developed, and this report has been prepared, in conformity with the requirements of the Code of Professional Ethics and Standards of Professional Appraisal Practice of the Appraisal Institute. 12. The use of this report is subject to the requirements of the Appraisal Institute relating to review by its duly authorized representatives. 13. As of the date of this report, the undersigned has completed the continuing education requirements for designated members of the Appraisal Institute. Andrew Baker, MAI Director Page 177 of 473 CELL TOWER IMPACT STUDY CERTIFICATION 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 55 Certification – Josh Folland, MAI, CCIM I certify that, to the best of my knowledge and belief: 1. The statements of fact contained in this report are true and correct. 2. The reported analyses, opinions, and conclusions are limited only by the reported assumptions and limiting conditions and are my personal, impartial, and unbiased professional analyses, opinions, and conclusions. 3. I have no present or prospective interest in the property that is the subject of this report and no personal interest with respect to the parties involved. 4. The undersigned has not performed services regarding the property that is the subject of this report within the three-year period immediately preceding acceptance of this assignment. 5. I have no bias with respect to the property that is the subject of this report or to the parties involved with this assignment. 6. My engagement in this assignment was not contingent upon developing or reporting predetermined results. 7. My compensation for completing this assignment is not contingent upon the development or reporting of a predetermined value or direction in value that favors the cause of the client, the amount of value opinion, the attainment of a stipulated result, or the occurrence of a subsequent event directly related to the intended use of this appraisal. 8. My analyses, opinions and conclusions were developed, and this report has been prepared, in conformity with the Uniform Standards of Professional Appraisal Practice. 9. Josh Folland has personally inspected the subject. 10. Nobody provided significant appraisal assistance to anyone signing this report. 11. The reported analyses, opinions and conclusions were developed, and this report has been prepared, in conformity with the requirements of the Code of Professional Ethics and Standards of Professional Appraisal Practice of the Appraisal Institute. 12. The use of this report is subject to the requirements of the Appraisal Institute relating to review by its duly authorized representatives. 13. As of the date of this report, the undersigned has completed the continuing education requirements for designated members of the Appraisal Institute. Valbridge Property Advisors | Minneapolis | St. Paul Josh Folland, MAI, AI-GRS, CCIM Senior Managing Director Minnesota License No. 20352348 Page 178 of 473 CELL TOWER IMPACT STUDY ADDENDA 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 56 Addenda Glossary Qualifications  Andrew Baker, MAI - Director  Josh Folland, MAI, AI-GRS, CCIM Information on Valbridge Property Advisors Additional Property Information Page 179 of 473 CELL TOWER IMPACT STUDY ADDENDA 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 57 Glossary Definitions are taken from the Dictionary of Real Estate Appraisal, 5th Edition (Dictionary), the Uniform Standards of Professional Appraisal Practice (USPAP) and Building Owners and Managers Association International (BOMA). Absolute Net Lease A lease in which the tenant pays all expenses including structural maintenance, building reserves, and management; often a long-term lease to a credit tenant. (Dictionary) Additional Rent Any amounts due under a lease that is in addition to base rent. Most common form is operating expense increases. (Dictionary) Amortization The process of retiring a debt or recovering a capital investment, typically though scheduled, systematic repayment of the principal; a program of periodic contributions to a sinking fund or debt retirement fund. (Dictionary) As Is Market Value The estimate of the market value of real property in its current physical condition, use, and zoning as of the appraisal date. (Dictionary) Base (Shell) Building The existing shell condition of a building prior to the installation of tenant improvements. This condition varies from building to building, landlord to landlord, and generally involves the level of finish above the ceiling grid. (Dictionary) Base Rent The minimum rent stipulated in a lease. (Dictionary) Base Year The year on which escalation clauses in a lease are based. (Dictionary) Building Common Area The areas of the building that provide services to building tenants but which are not included in the rentable area of any specific tenant. These areas may include, but shall not be limited to, main and auxiliary lobbies, atrium spaces at the level of the finished floor, concierge areas or security desks, conference rooms, lounges or vending areas food service facilities, health or fitness centers, daycare facilities, locker or shower facilities, mail rooms, fire control rooms, fully enclosed courtyards outside the exterior walls, and building core and service areas such as fully enclosed mechanical or equipment rooms. Specifically excluded from building common areas are; floor common areas, parking spaces, portions of loading docks outside the building line, and major vertical penetrations. (BOMA) Building Rentable Area The sum of all floor rentable areas. Floor rentable area is the result of subtracting from the gross measured area of a floor the major vertical penetrations on that same floor. It is generally fixed for the life of the building and is rarely affected by changes in corridor size or configuration. (BOMA) Certificate of Occupancy (COO) A statement issued by a local government verifying that a newly constructed building is in compliance with all codes and may be occupied. Common Area (Public) Factor In a lease, the common area (public) factor is the multiplier to a tenant’s useable space that accounts for the tenant’s proportionate share of the common area (restrooms, elevator lobby, mechanical rooms, etc.). The public factor is usually expressed as a percentage and ranges from a low of 5 percent for a full tenant to as high as 15 percent or more for a multi-tenant floor. Subtracting one (1) from the quotient of the rentable area divided by the useable area yields the load (public) factor. At times confused with the “loss factor” which is the total rentable area of the full floor less the useable area divided by the rentable area. (BOMA) Common Area Maintenance (CAM) The expense of operating and maintaining common areas; may or may not include management charges and usually does not include capital expenditures on tenant improvements or other improvements to the property. CAM can be a line-item expense for a group of items that can include maintenance of the parking lot and landscaped areas and sometimes the exterior walls of the buildings. CAM can refer to all operating expenses. CAM can refer to the reimbursement by the tenant to the landlord for all expenses reimbursable under the lease. Sometimes reimbursements have what is called an administrative load. An example would be a 15 percent addition to total operating expenses, which are then prorated among tenants. The administrative load, also called an administrative and marketing fee, can be a substitute for or an addition to a management fee. (Dictionary) Page 180 of 473 CELL TOWER IMPACT STUDY ADDENDA 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 58 Condominium A form of ownership in which each owner possesses the exclusive right to use and occupy an allotted unit plus an undivided interest in common areas. A multiunit structure, or a unit within such a structure, with a condominium form of ownership. (Dictionary) Conservation Easement An interest in real property restricting future land use to preservation, conservation, wildlife habitat, or some combination of those uses. A conservation easement may permit farming, timber harvesting, or other uses of a rural nature to continue, subject to the easement. In some locations, a conservation easement may be referred to as a conservation restriction. (Dictionary) Contributory Value The change in the value of a property as a whole, whether positive or negative, resulting from the addition or deletion of a property component. Also called deprival value in some countries. (Dictionary) Debt Coverage Ratio (DCR) The ratio of net operating income to annual debt service (DCR = NOI/I’m), which measures the relative ability to a property to meet its debt service out of net operating income. Also called Debt Service Coverage Ratio (DSCR). A larger DCR indicates a greater ability for a property to withstand a downturn in revenue, providing an improved safety margin for a lender. (Dictionary) Deed Restriction A provision written into a deed that limits the use of land. Deed restrictions usually remain in effect when title passes to subsequent owners. (Dictionary) Depreciation 1) In appraising, the loss in a property value from any cause; the difference between the cost of an improvement on the effective date of the appraisal and the market value of the improvement on the same date. 2) In accounting, an allowance made against the loss in value of an asset for a defined purpose and computed using a specified method. (Dictionary) Disposition Value The most probable price that a specified interest in real property is likely to bring under the following conditions:  Consummation of a sale within a exposure time specified by the client;  The property is subjected to market conditions prevailing as of the date of valuation;  Both the buyer and seller are acting prudently and knowledgeably;  The seller is under compulsion to sell;  The buyer is typically motivated;  Both parties are acting in what they consider to be their best interests;  An adequate marketing effort will be made during the exposure time specified by the client;  Payment will be made in cash in U.S. dollars or in terms of financial arrangements comparable thereto; and  The price represents the normal consideration for the property sold, unaffected by special or creative financing or sales concessions granted by anyone associated with the sale. (Dictionary) Easement The right to use another’s land for a stated purpose. (Dictionary) EIFS Exterior Insulation Finishing System. This is a type of exterior wall cladding system. Sometimes referred to as dry-vit. Effective Date 1) The date at which the analyses, opinions, and advice in an appraisal, review, or consulting service apply. 2) In a lease document, the date upon which the lease goes into effect. (Dictionary) Effective Rent The rental rate net of financial concessions such as periods of no rent during the lease term and above- or below-market tenant improvements (TIs). (Dictionary) EPDM Ethylene Diene Monomer Rubber. A type of synthetic rubber typically used for roof coverings. (Dictionary) Escalation Clause A clause in an agreement that provides for the adjustment of a price or rent based on some event or index. e.g., a provision to increase rent if operating expenses increase; also called an expense recovery clause or stop clause. (Dictionary) Estoppel Certificate A statement of material factors or conditions of which another person can rely because it cannot be denied at a later date. In real estate, a buyer of rental property typically requests estoppel certificates from existing tenants. Sometimes referred to as an estoppel letter. (Dictionary) Page 181 of 473 CELL TOWER IMPACT STUDY ADDENDA 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 59 Excess Land Land that is not needed to serve or support the existing improvement. The highest and best use of the excess land may or may not be the same as the highest and best use of the improved parcel. Excess land may have the potential to be sold separately and is valued separately. (Dictionary) Expense Stop A clause in a lease that limits the landlord’s expense obligation, which results in the lessee paying any operating expenses above a stated level or amount. (Dictionary) Exposure Time 1) The time a property remains on the market. 2) The estimated length of time the property interest being appraised would have been offered on the market prior to the hypothetical consummation of a sale at market value on the effective date of the appraisal; a retrospective estimate based on an analysis of past events assuming a competitive and open market. (Dictionary) Extraordinary Assumption An assumption, directly related to a specific assignment, which, if found to be false, could alter the appraiser’s opinions or conclusions. Extraordinary assumptions presume as fact otherwise uncertain information about physical, legal, or economic characteristics of the subject property; or about conditions external to the property such as market conditions or trends; or about the integrity of data used in an analysis. (Dictionary) Fair Market Value The price at which the property should change hands between a willing buyer and a willing seller, neither being under any compulsion to buy or sell and both having reasonable knowledge of relevant facts. [Treas. Reg. 20.2031-1(b); Rev. Rul. 59-60. 1959-1 C.B. 237] Fee Simple Estate Absolute ownership unencumbered by any other interest or estate, subject only to the limitations imposed by the governmental powers of taxation, eminent domain, police power, and escheat. (Dictionary) Floor Common Area Areas on a floor such as washrooms, janitorial closets, electrical rooms, telephone rooms, mechanical rooms, elevator lobbies, and public corridors which are available primarily for the use of tenants on that floor. (BOMA) Full Service (Gross) Lease A lease in which the landlord receives stipulated rent and is obligated to pay all of the property’s operating and fixed expenses; also called a full service lease. (Dictionary) Going Concern Value  The market value of all the tangible and intangible assets of an established and operating business with an indefinite life, as if sold in aggregate; more accurately termed the market value of the going concern.  The value of an operating business enterprise. Goodwill may be separately measured but is an integral component of going-concern value when it exists and is recognizable. (Dictionary) Gross Building Area The total constructed area of a building. It is generally not used for leasing purposes (BOMA) Gross Measured Area The total area of a building enclosed by the dominant portion (the portion of the inside finished surface of the permanent outer building wall which is 50 percent or more of the vertical floor-to-ceiling dimension, at the given point being measured as one moves horizontally along the wall), excluding parking areas and loading docks (or portions of the same) outside the building line. It is generally not used for leasing purposes and is calculated on a floor by floor basis. (BOMA) Gross Up Method A method of calculating variable operating expense in income-producing properties when less than 100 percent occupancy is assumed. The gross up method approximates the actual expense of providing services to the rentable area of a building given a specified rate of occupancy. (Dictionary) Ground Lease A lease that grants the right to use and occupy land. Improvements made by the ground lessee typically revert to the ground lessor at the end of the lease term. (Dictionary) Ground Rent The rent paid for the right to use and occupy land according to the terms of a ground lease; the portion of the total rent allocated to the underlying land. (Dictionary) HVAC Heating, ventilation, air conditioning. A general term encompassing any system designed to heat and cool a building in its entirety. Page 182 of 473 CELL TOWER IMPACT STUDY ADDENDA 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 60 Highest & Best Use The reasonably probable and legal use of vacant land or an improved property that is physically possible, appropriately supported, financially feasible, and that results in the highest value. The four criteria the highest and best use must meet are 1) legal permissibility, 2) physical possibility, 3) financial feasibility, and 4) maximally profitability. Alternatively, the probable use of land or improved –specific with respect to the user and timing of the use–that is adequately supported and results in the highest present value. (Dictionary) Hypothetical Condition That which is contrary to what exists but is supposed for the purpose of analysis. Hypothetical conditions assume conditions contrary to known facts about physical, legal, or economic characteristics of the subject property; or about conditions external to the property, such as market conditions or trends; or about the integrity of data used in an analysis. (Dictionary) Industrial Gross Lease A lease of industrial property in which the landlord and tenant share expenses. The landlord receives stipulated rent and is obligated to pay certain operating expenses, often structural maintenance, insurance and real estate taxes as specified in the lease. There are significant regional and local differences in the use of this term. (Dictionary) Insurable Value A type of value for insurance purposes. (Dictionary) (Typically this includes replacement cost less basement excavation, foundation, underground piping and architect’s fees). Investment Value The value of a property interest to a particular investor or class of investors based on the investor’s specific requirements. Investment value may be different from market value because it depends on a set of investment criteria that are not necessarily typical of the market. (Dictionary) Just Compensation In condemnation, the amount of loss for which a property owner is compensated when his or her property is taken. Just compensation should put the owner in as good a position as he or she would be if the property had not been taken. (Dictionary) Leased Fee Interest A freehold (ownership interest) where the possessory interest has been granted to another party by creation of a contractual landlord-tenant relationship (i.e., a lease). (Dictionary) Leasehold Interest The tenant’s possessory interest created by a lease. (Dictionary) Lessee (Tenant) One who has the right to occupancy and use of the property of another for a period of time according to a lease agreement. (Dictionary) Lessor (Landlord) One who conveys the rights of occupancy and use to others under a lease agreement. (Dictionary) Liquidation Value The most probable price that a specified interest in real property should bring under the following conditions:  Consummation of a sale within a short period.  The property is subjected to market conditions prevailing as of the date of valuation.  Both the buyer and seller are acting prudently and knowledgeably.  The seller is under extreme compulsion to sell.  The buyer is typically motivated.  Both parties are acting in what they consider to be their best interests.  A normal marketing effort is not possible due to the brief exposure time.  Payment will be made in cash in U.S. dollars or in terms of financial arrangements comparable thereto.  The price represents the normal consideration for the property sold, unaffected by special or creative financing or sales concessions granted by anyone associated with the sale. (Dictionary) Loan to Value Ratio (LTV) The amount of money borrowed in relation to the total market value of a property. Expressed as a percentage of the loan amount divided by the property value. (Dictionary) Major Vertical Penetrations Stairs, elevator shafts, flues, pipe shafts, vertical ducts, and the like, and their enclosing walls. Atria, lightwells and similar penetrations above the finished floor are included in this definition. Not included, however, are vertical penetrations built for the private use of a tenant occupying office areas on more than one floor. Structural columns, openings for vertical electric cable or telephone distribution, and openings for plumbing lines are not considered to be major vertical penetrations. (BOMA) Page 183 of 473 CELL TOWER IMPACT STUDY ADDENDA 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 61 Market Rent The most probable rent that a property should bring in a competitive and open market reflecting all conditions and restrictions of the lease agreement including permitted uses, use restrictions, expense obligations; term, concessions, renewal and purchase options and tenant improvements (TIs). (Dictionary) Market Value The most probable price which a property should bring in a competitive and open market under all conditions requisite to a fair sale, the buyer and seller each acting prudently and knowledgeably, and assuming the price is not affected by undue stimulus. Implicit in this definition is the consummation of a sale as of a specified date and the passing of title from seller to buyer under conditions whereby: a. Buyer and seller are typically motivated; b. Both parties are well informed or well advised, and acting in what they consider their own best interests; c. A reasonable time is allowed for exposure in the open market; d. Payment is made in terms of cash in United States dollars or in terms of financial arrangements comparable thereto; and e. The price represents the normal consideration for the property sold unaffected by special or creative financing or sales concessions granted by anyone associated with the sale. Market Value As If Complete Market value as if complete means the market value of the property with all proposed construction, conversion or rehabilitation hypothetically completed or under other specified hypothetical conditions as of the date of the appraisal. With regard to properties wherein anticipated market conditions indicate that stabilized occupancy is not likely as of the date of completion, this estimate of value shall reflect the market value of the property as if complete and prepared for occupancy by tenants. Market Value As If Stabilized Market value as if stabilized means the market value of the property at a current point and time when all improvements have been physically constructed and the property has been leased to its optimum level of long term occupancy. Marketing Time An opinion of the amount of time it might take to sell a real or personal property interest at the concluded market value level during the period immediately after the effective date of the appraisal. Marketing time differs from exposure time, which is always presumed to precede the effective date of an appraisal. (Advisory Opinion 7 of the Standards Board of the Appraisal Foundation and Statement on Appraisal Standards No. 6, “Reasonable Exposure Time in Real Property and Personal Property Market Value Opinions” address the determination of reasonable exposure and marketing time). (Dictionary) Master Lease A lease in which the fee owner leases a part or the entire property to a single entity (the master lease) in return for a stipulated rent. The master lessee then leases the property to multiple tenants. (Dictionary) Modified Gross Lease A lease in which the landlord receives stipulated rent and is obligated to pay some, but not all, of the property’s operating and fixed expenses. Since assignment of expenses varies among modified gross leases, expense responsibility must always be specified. In some markets, a modified gross lease may be called a double net lease, net net lease, partial net lease, or semi-gross lease. (Dictionary) Option A legal contract, typically purchased for a stated consideration, that permits but does not require the holder of the option (known as the optionee) to buy, sell, or lease real property for a stipulated period of time in accordance with specified terms; a unilateral right to exercise a privilege. (Dictionary) Partial Interest Divided or undivided rights in real estate that represent less than the whole (a fractional interest). (Dictionary) Pass Through A tenant’s portion of operating expenses that may be composed of common area maintenance (CAM), real estate taxes, property insurance, and any other expenses determined in the lease agreement to be paid by the tenant. (Dictionary) Prospective Future Value Upon Completion Market value “upon completion” is a prospective future value estimate of a property at a point in time when all of its improvements are fully completed. It assumes all proposed construction, conversion, or rehabilitation is hypothetically complete as of a future date when such effort is projected to occur. The projected completion date and the value estimate must reflect the market value of the property in its projected condition, i.e., completely vacant or partially occupied. The cash flow must reflect lease-up costs, required tenant improvements and leasing commissions on all areas not leased and occupied. Page 184 of 473 CELL TOWER IMPACT STUDY ADDENDA 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 62 Prospective Future Value Upon Stabilization Market value “upon stabilization” is a prospective future value estimate of a property at a point in time when stabilized occupancy has been achieved. The projected stabilization date and the value estimate must reflect the absorption period required to achieve stabilization. In addition, the cash flows must reflect lease-up costs, required tenant improvements and leasing commissions on all unleased areas. Replacement Cost The estimated cost to construct, at current prices as of the effective appraisal date, a substitute for the building being appraised, using modern materials and current standards, design, and layout. (Dictionary) Reproduction Cost The estimated cost to construct, at current prices as of the effective date of the appraisal, an exact duplicate or replica of the building being appraised, using the same materials, construction standards, design, layout, and quality of workmanship and embodying all of the deficiencies, super-adequacies, and obsolescence of the subject building. (Dictionary) Retrospective Value Opinion A value opinion effective as of a specified historical date. The term does not define a type of value. Instead, it identifies a value opinion as being effective at some specific prior date. Value as of a historical date is frequently sought in connection with property tax appeals, damage models, lease renegotiation, deficiency judgments, estate tax, and condemnation. Inclusion of the type of value with this term is appropriate, e.g., “retrospective market value opinion.” (Dictionary) Sandwich Leasehold Estate The interest held by the original lessee when the property is subleased to another party; a type of leasehold estate. (Dictionary) Sublease An agreement in which the lessee (i.e., the tenant) leases part or all of the property to another party and thereby becomes a lessor. (Dictionary) Subordination A contractual arrangement in which a party with a claim to certain assets agrees to make his or her claim junior, or subordinate, to the claims of another party. (Dictionary) Substantial Completion Generally used in reference to the construction of tenant improvements (TIs). The tenant’s premises are typically deemed to be substantially completed when all of the TIs for the premises have been completed in accordance with the plans and specifications previously approved by the tenant. Sometimes used to define the commencement date of a lease. Surplus Land Land that is not currently needed to support the existing improvement but cannot be separated from the property and sold off. Surplus land does not have an independent highest and best use and may or may not contribute value to the improved parcel. (Dictionary) Triple Net (Net Net Net) Lease A lease in which the tenant assumes all expenses (fixed and variable) of operating a property except that the landlord is responsible for structural maintenance, building reserves, and management. Also called NNN, triple net leases, or fully net lease. (Dictionary) (The market definition of a triple net leases varies; in some cases tenants pay for items such as roof repairs, parking lot repairs, and other similar items.) Usable Area The measured area of an office area, store area or building common area on a floor. The total of all the usable areas or a floor shall equal floor usable area of that same floor. The amount of floor usable area can vary over the life of a building as corridors expand and contract and as floors are remodeled. (BOMA) Value-in-Use The value of a property assuming a specific use, which may or may not be the property’s highest and best use on the effective date of the appraisal. Value in use may or may not be equal to market value but is different conceptually. (Dictionary) Page 185 of 473 CELL TOWER IMPACT STUDY ADDENDA 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 63 Qualifications Page 186 of 473 CELL TOWER IMPACT STUDY ADDENDA 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 67 Valbridge Property Advisors Information / Office Locations Page 187 of 473 CELL TOWER IMPACT STUDY ADDENDA 2021 VALBRIDGE PROPERTY ADVISORS | MINNEAPOLIS | ST. PAUL Page 68 Page 188 of 473 Qualifications of Josh Folland, MAI, CCIM Page 189 of 473 Page 190 of 473 OFFICE WAREHOUSE ADDENDA © 2025 VALBRIDGE PROPERTY ADVISORS | KANSAS CITY PAGE 63 Qualifications Qualifications of Andrew Baker, MAI Page 191 of 473 Site Search Walk-Through | Page 1 of 5 Site Search and Zoning Walk-Through Supporting the Conditional Use Permit Application for a New Communication Tower Dakota County PID 27-03800-34-010 Property address: 739 Wentworth Ave Public commentary on the proposed project has suggested a lack of evaluation of all alternatives prior to proposing this new tower site. Section 12-4A-12.7 of the Mendota Heights zoning ordinance requires the applicant to submit a coverage capacity analysis demonstrating no support structures area available, and an area map showing the proposed site, existing sites within a two-mile radius, and any future planned antenna sites. A Statement of Network Need, including a coverage map, was provided from the Verizon Radio Frequency Engineer, and that document fulfills both of these items. The City’s ordinance does not require the applicant to exhaust all other alternatives; instead, the ordinance only requires that Preferred Support Structures and Preferred Land Use Areas are exhausted if an Alternate Land Use Area is selected. The selected site is located in a Preferred Land Use Area, therefore an exhaustion of all other locations is not required as part of the application. The following pages illustrate the site selection process which ultimately resulted in locating this proposed project at Wentworth Park because that is the best zoning-viable location for a tower site in this part of the City, and the location fulfills the network need for the gap area described by the Verizon Radio Frequency Engineer in the Statement of Network Need. Step 1: Assess RF Need The Statement of Network Need from Verizon RF, which included a coverage map, and which was provided in the original application materials, has been updated and included with the other supplemental materials. This document clearly articulates what elevation and height are needed for a new antenna installation to able to cover a significant “gap area” where coverage is poor. The next page includes a zoomed-in view of the central portion of the map included on that document, plus additional information to provide scale and distance for reference. The green area within and extending northeast of the white circle is the “gap area”. This RF map shows clearly that surrounding existing sites are not providing adequate coverage to the gap area, which is a large area that extends from near City Hall, east to Dodd Rd, and then northeast all the way to near the intersection of Annapolis and Delaware. There are several neighborhoods affected by this poor coverage. The “gap area” is best fulfilled by locating a site closest to the center of the search ring, which is the white circle on the map. The more central a single site is placed, the more of the “gap area” will be covered by that single site. This is supported by the Verizon RF Statement which states at the end of paragraph 6: “This particular location is optimal because it will allow Verizon to cover substantially all of the area with a single tower.” This section clarified Verizon’s network need. The next section builds from that information, and uses the zoning ordinance as a guide for development options. Page 192 of 473 Site Search Walk-Through | Page 2 of 5 Above: RF Coverage Map with Additional Reference Information Search Ring Center Proposed Tower Location Existing Tower Existing Verizon Site 1-mi radius Page 193 of 473 Site Search Walk-Through | Page 3 of 5 Step 2: Use the Zoning Ordinance as the Guide for Development The City of Mendota Heights has a specific section for Wireless Towers, Section 12-4A-12.7, in its ordinance, that sets forth performance standards to guide site design, and siting preferences as a guide to certain types of properties. Existing Structures: Before the City will consider a new tower site, the ordinance requires the applicant to reasonably demonstrate that an existing “Preferred Support Structure” will not work from an engineering standpoint. As part of the zoning application, a Statement of Network Need was provided from Verizon’s RF Engineer, and paragraph 5 of that document states: Before proposing a new communications tower, Verizon first considered whether any existing towers in the search area could be used to resolve the coverage gap in the Gap Area. There were no other structures in the search area on which Verizon could collocate to resolve the service gap in the Gap Area. Although there are existing towers in the general area outside the search ring, none of these towers will allow Verizon to remedy the service gap. The existing towers referenced by RF are shown on the prior page’s coverage map as red triangles. Existing structures include water towers, existing towers, church steeples, side of buildings over two stories high, or existing utility poles. Because Verizon concluded from an engineering standpoint that they could not utilize any existing buildings, towers, or other structures to fulfill the network need for the “gap area” described by Verizon RF, the next step is to proceed toward a new tower site solution. New Tower Site Options: The ordinance requires that if a new tower site is proposed, the applicant must look first at Preferred Land Use Areas, and failing that, look at Alternative Land Use Areas, both as defined in the ordinance (ordinance excerpt screen shot below). The Preferred Land Use Area list appears to require that certain types of properties are explored in the order presented in the ordinance, starting with B-1, B-2, and Industrial zoning districts. There are no B-2 or Industrial zoning districts in or near the search ring. There is one B-1 zoning district area down near Hwy 13 and Lilydale Rd. The underlying B-1 district dimensional standards require that any structure be setback a distance equal to the height of the structure. Based on that setback requirement, none of the B-1 zoned parcels can meet the setbacks to allow a tower with the height Verizon would need according to the Statement of Network Need included in the zoning application for this project. The next group of properties in the Preferred Land Use Area list is “athletic complexes, municipal property or Public/Semi-Public uses.” Starting near the center of the search ring to best fulfill Verizon’s network need, there are just a few options which fall into this category. Based on the ownership information from Dakota County and the City’s zoning map (see map image on later page), some properties near the search ring center were identified as both municipal properties and within the Public/Semi-Public Overlay zoning district. The closest of these properties to the Page 194 of 473 Site Search Walk-Through | Page 4 of 5 search ring center and the one with the best elevation (both elements necessary to meet Verizon’s network need) is Wentworth Park. Because Wentworth Park is municipal property and within the Public/Semi-Public Use Overlay, it qualifies as a Preferred Land Use Area, and no further analysis is required to explore other options according to the City’s zoning ordinance. One concern that was brought up at the March 31 Planning Commission hearing was that the subject property is also defined as a public park, which is an Alternate Land Use Area. The intent of this portion of the ordinance, which seems to have created multiple instances of properties which fall into both Preferred Land Use Areas and Alternate Land Use Areas, is somewhat unclear. Upon review of the entirety of the above-described search effort, and the properties in the search ring, please note that every property in the Public/Semi-Public Overlay district within the search ring is also a public park / open space, a golf course, or both. There are no other properties which are more zoning-viable than the proposed tower location. To meet the needs of the Verizon network, and to meet the requirements of the zoning ordinance, the Wentworth Park location is the best location for this project. Page 195 of 473 Site Search Walk-Through | Page 5 of 5 Above: City Zoning Map Overlaid on Google Earth Image with Search Ring (red circle) and 2-Mile Radius (teal circle) Thank you for considering additional report as part of our zoning application package for a CUP for The Towers LLC’s proposed tower facility. Sincerely, Scott Buell, Site Development Agent on Behalf of The Towers, LLC Buell Consulting, Inc. / sbuell@buellconsulting.com / Direct: 651-225-0793 Page 196 of 473 From:MARY BETH LORENCE To:Sarah Madden Subject:Proposal for Construction of a 149 foot Monopole at Wentworth Park (Planning Case #2026-05 Date:Tuesday, March 24, 2026 2:20:40 PM Attachments:Cell Tower.docx You don't often get email from mblorence@comcast.net. Learn why this is important Sara: Cheryl Bemel recently sent an email, to the Evergreen Knolls Safety List Serv, informing our neighborhood that there is a proposal to erect a 149 foot Monopole at Wentworth Park. After some research, we have decided to veto that proposal. Please see attachment. With respect, David and Mary Beth O'Brien Page 197 of 473 Property Value Effects • Decreased Valuation: Studies have shown that proximity to a cell tower generally has a negative impact on home prices. Homes within 0.72 km (approx. 0.45 miles) have seen average value decreases of roughly 2.65%. • Visibility Penalty: If a tower is clearly visible from a property, the value decrease can be more significant, with some studies reporting drops of up to 9.78%. Health & Radiation Perspectives There is significant debate between regulatory bodies and various scientific researchers regarding the effects of radiofrequency (RF) radiation from these towers. • Official Regulatory Stance: Organizations like the Federal Communications Commission (FCC) and the American Cancer Society state there is currently no strong evidence that exposure to RF waves from cell towers causes noticeable health effects at standard ground-level exposure. • Reported Biological Effects: Numerous independent studies and advocacy groups like Environmental Health Sciences report associations between proximity to towers and symptoms often called "microwave illness," including: o Neuropsychiatric symptoms: Headaches, sleep disturbances, memory changes, and dizziness. o Cellular Impacts: Some research points to oxidative stress, DNA damage, and potential carcinogenic risks, though these are typically not recognized by current national safety standards. • Regulatory Disputes: In 2021, a U.S. federal court ruled that the FCC had not adequately addressed evidence concerning non-cancer health impacts and environmental consequences when it decided not to update its 1996 safety limits. Page 198 of 473 From:G To:Sarah Madden Subject:Comment on Wireless Tower in Wentworth Park: Planning case no. 2026-05 Date:Tuesday, March 24, 2026 8:19:59 PM You don't often get email from ostgaardg0@gmail.com. Learn why this is important Dear Members of the Planning Commission, I am writing to express my concern regarding the proposed 149-foot wireless tower in Wentworth Park. Wentworth Park is not just green space—it is a central gathering place for a neighborhood filled with families and young children. On any given day, the park is used by kids who live nearby to play, explore, and spend time outdoors. Many of these children can walk to the park from their homes, and it serves as an extension of their everyday environment. Placing a structure of this size in the middle of the park would significantly alter the character of a space that is designed and relied upon for safe, open, child-centered recreation. The visual impact alone would change how the park feels, but there are also concerns about introducing infrastructure—such as ground equipment, maintenance activity, and potential noise—into an area primarily used by young families. Additionally, this tower would be located in close proximity to homes where children live, play, and grow. Beyond the immediate use of the park, there are also concerns about the impact on surrounding property values. Infrastructure of this scale, particularly when placed near homes and in a central neighborhood amenity like a park, influences how properties are perceived by prospective buyers and may negatively affect long-term value. While I understand the importance of reliable wireless infrastructure, I believe its placement should be carefully considered when it directly affects a residential, family-oriented neighborhood. I respectfully ask the Commission to consider whether this is an appropriate location given the high use of this park by children, the surrounding concentration of young families, and the potential impacts on nearby homes. Parks like Wentworth are among the few dedicated spaces for kids to safely gather and play, and once their character is changed, it cannot easily be restored. I encourage the Commission to explore alternative locations or less intrusive options that would meet infrastructure needs without compromising a vital community space for children and families. Thank you for your time and for considering community input on this matter. Sincerely, Gayra Ostgaard 757 Upper Colonial Drive Mendota Heights 55118 Page 199 of 473 6513036397 Page 200 of 473 From:Cheryl Jacobson To:Sarah Madden Subject:FW: A personal note on the Wentworth Park cell tower proposal Date:Wednesday, March 25, 2026 3:23:25 PM For your records. -Cheryl From: Stephanie Levine <SLevine@mendotaheightsmn.gov> Sent: Wednesday, March 25, 2026 2:32 PM To: Darcy Mckenzie <darcy.mckenzie@comcast.net> Cc: Dane Mckenzie <dane.mckenzie@comcast.net>; Cheryl Jacobson <CJacobson@mendotaheightsmn.gov> Subject: Re: A personal note on the Wentworth Park cell tower proposal Hi Darcy, Thanks for reaching out regarding your opposition to the proposed cell tower at Wentworth Park. I am copying in City Administrator Jacobson, so that your (and Dane’s) thoughts can be part of the public record. While I understand that that adding this tower to the park is going to change the park’s landscape, I am not sure of a better option. Probably the most persistent complaint we receive from residents is about the lack of good cell service, especially in the north. Our public safety workers also have problems with calls dropping. While we have studied this issue for years, it is possible that there are ideas we have not considered. If there is a better solution, please share your ideas. I want you to know that we looked at “tree like” poles, and it turns out they aren’t going to disguise the tower. I don’t know if you’ve seen them, but they are a little campy looking and expensive. We also considered shorter poles. However, we are hoping that with this height, we can increase cell service and host multiple carriers. We don’t want more poles than necessary. We also picked an area that is nestled in mature trees, separate from the playground, hockey rink and ballfield. A kid on the playground or ballfield will have a sightline that will obscure most of the tower. It will be most visible from the entrance to the parking lot. We value the green space in our city - and for that reason we have historically had few towers approved (the business park has one). In the past, when cell phones weren’t ubiquitous and we used land lines, that was OK. However, we’ve crossed the line where Page 201 of 473 cell services isn’t a nice-to-have, but a must-have. And, in order to have that service, we need to have the required infrastructure. I look forward to seeing you at our next city council meeting. Take Care, Stephanie Stephanie B. Levine Mayor City of Mendota Heights C:651-302-0861 Website | Connect From: Darcy McKenzie <darcy.mckenzie@comcast.net> Date: Wednesday, March 25, 2026 at 1:37 PM To: Stephanie Levine <SLevine@mendotaheightsmn.gov> Cc: Dane Mckenzie <dane.mckenzie@comcast.net> Subject: A personal note on the Wentworth Park cell tower proposal You don't often get email from darcy.mckenzie@comcast.net. Learn why this is important Dear Mayor Stephanie, It was so nice to see you at Scott & Heidi Swank's home and learning about Rethos Circle. Interested in hearing if there has been any further coordination with the city of Mendota Heights. Dane and I are writing to you personally about Planning Case No. 2026-05 — the Page 202 of 473 proposal to construct a 149-foot wireless monopole at Wentworth Park — because we know you understand what this community means to the people who live here. We've called Cherry Hill Road home since 2001, and over those 25 years Mendota Heights has given us so much more than we ever anticipated. Some of our most vivid memories trace back to 2006, when a cell tower proposal at Wentworth Park — a 75- foot structure, less than half the height of what is proposed today — brought our neighborhood together in a way nothing else had. We knocked on doors, showed up to meetings, and discovered just how deeply our neighbors cared about this place. That proposal was denied, and in some ways, the experience of fighting it made us fall even more in love with this community. Neighbors have come and gone since then, as they do. The families who filled the park when our children were young have mostly moved on, replaced by a new generation of kids on the playground and families at the hockey rink. But the feel of this neighborhood — the reason people choose Mendota Heights and stay — hasn't changed at all. Wentworth Park is at the heart of that. A 149-foot commercial monopole in that park would be a permanent alteration to something that took decades to build and can't be rebuilt once it's gone. We are wholeheartedly opposed, and we will be at the March 31st hearing to say so alongside our neighbors. We urge the Council to weigh this history and conclude, as the city did in 2006, that Wentworth Park is not the right place for a cell tower — and that this time, the proposal is twice as tall. With gratitude for all you do for this community, Darcy & Dane McKenzie 1415 Cherry Hill Rd Mendota Heights MN 55118 c) 651.261.3439 c) 651.261.0249 Page 203 of 473 From:Cheryl Jacobson To:Sarah Madden Subject:FW: [POTENTIAL Financial Phone]A note on Planning Case No. 2026-05 — Wentworth Park Cell Tower Proposal Date:Thursday, March 26, 2026 8:49:37 AM Similar to their email to the mayor. I am guessing they reached out with separate emails to council. -Cheryl From: John Maczko <JMaczko@mendotaheightsmn.gov> Sent: Thursday, March 26, 2026 7:07 AM To: Cheryl Jacobson <CJacobson@mendotaheightsmn.gov> Subject: Fwd: [POTENTIAL Financial Phone]A note on Planning Case No. 2026-05 — Wentworth Park Cell Tower Proposal Sent from my iPhone Begin forwarded message: From: Darcy McKenzie <darcy.mckenzie@comcast.net> Date: March 25, 2026 at 15:28:53 EDT To: John Maczko <JMaczko@mendotaheightsmn.gov> Cc: Dane Mckenzie <dane.mckenzie@comcast.net> Subject: [POTENTIAL Financial Phone]A note on Planning Case No. 2026-05 — Wentworth Park Cell Tower Proposal You don't often get email from darcy.mckenzie@comcast.net. Learn why this is important WARNING: Your email security system has determined the message below may be a potential threat. It may trick victims into confirming a bank account change or transaction by calling a phone number and providing sensitive information. If you do not know the sender or cannot verify the integrity of the message, please do not respond or click on links in the message. Depending on the security settings, clickable URLs may have been modified to provide additional security. Dear Councilperson Maczko, Page 204 of 473 We are Mendota Heights residents writing in connection with Planning Case No. 2026-05 — the proposal to construct a 149-foot wireless monopole at Wentworth Park (739 Wentworth Avenue). We have lived on Cherry Hill Road since 2001 and are wholeheartedly opposed to this proposal. In fall 2006, a smaller cell tower proposal at this same location — a 75-foot structure — was denied by the city after significant neighborhood opposition. That history is reflected in city records (WebLink document ID 48168, page 8). The current proposal is nearly twice the height of the one already turned down. Wentworth is a small neighborhood park — 10.5 acres surrounded by homes and families. A 149-foot commercial monopole is out of scale with everything around it and would permanently alter the character of a park that has been the heart of this neighborhood for generations. We will be present at the March 31st public hearing and urge the Council to deny this application, as the city did in 2006. Darcy & Dane McKenzie 1415 Cherry Hill Rd Mendota Heights MN 55118 c) 651.261.3439 c) 651.261.0249 Page 205 of 473 From:Debra Gagnon To:Sarah Madden Subject:No wireless tower at Wentworth Park Date:Wednesday, March 25, 2026 2:07:35 PM [You don't often get email from gagnon.debra@icloud.com. Learn why this is important at https://aka.ms/LearnAboutSenderIdentification ] Hello I received the notification by mail yesterday about the proposed wireless tower to be built at Wentworth Park. My family lives on Upper Colonial Drive, just across the street from the tennis courts at Wentworth Park. We object to the proposal to allow this tower to be built at Wentworth. Sincerely, Deb & Peter Gagnon 751 Upper Colonial Drive Mendota Heights MN 55118 Page 206 of 473 Page 207 of 473 Page 208 of 473 From:Coree Chodek To:Sarah Madden Subject:No cell tower at Wentworth Date:Thursday, March 26, 2026 7:45:10 AM You don't often get email from coree.chodek@yahoo.com. Learn why this is important Hi, just writing to vote not to have a cell tower put into Wentworth park. Thanks, Coree Sent from Yahoo Mail for iPhone Page 209 of 473 From:Leon, Andrea To:Sarah Madden Subject:Against the Cell Tower in Wentworth Park planning Case number 2026 - 05 Date:Friday, March 27, 2026 11:48:08 AM You don't often get email from andrea.leon@jll.com. Learn why this is important Good afternoon, I am writing to express my strong opposition of the proposal to build a cell tower in the beautiful community I live in Mendota Heights in Wentworth Park. I am a life long resident of our city, I grew up here and have countless memories of Wentworth park, and now own here at 1445 Farmdale Road. We purchased our home in 2023 for $705,000 and have since put in $150,000 to the home. My main concern about adding this cell tower to a sanctuary like park setting that is Wentworth Park is the toxic elements it will produce that will affect everyone’s health who lives nearby for years and years to come. I have four young children, spanning from 1 to 10 years old and we are frequent visitors of the park and love playing outside and enjoying the nature and trails in our neighborhood. There are so many young children that live by us, and only more families who want to join this neighborhood as elderly people move on. I am afraid that adding this tower will deter families from wanting to buy here, not to mention our property values will decrease because of this. It is an unsettling and unfair proposal to set this cell tower up in Wentworth Park. I am speaking to many of my neighbors and to people who live in the city, and people from afar who have no connection to this area, and all are shocked and opposed to this proposal. I urge you to deny this proposal. Thank you for your time and consideration. Andrea Leon Vice President JLL | Brokerage Services - Office 250 Nicollet Mall, Suite 1000 Minneapolis, MN 55401 M: 202.817.9565 http://www.jll.com/Minneapoliswww.linkedin.com/in/andreamleon One of the 2025 World’s Most Ethical Companies® Jones Lang LaSalle Page 210 of 473 For more information about how JLL processes your personal data, please click here This email is for the use of the intended recipient(s) only. If you have received this email in error, please notify the sender immediately and then delete it. If you are not the intended recipient, you must not keep, use, disclose, copy or distribute this email without the author's prior permission. We have taken precautions to minimize the risk of transmitting software viruses, but we advise you to carry out your own virus checks on any attachment to this message. We cannot accept liability for any loss or damage caused by software viruses. The information contained in this communication may be confidential and may be subject to the attorney-client privilege. If you are theintended recipient and you do not wish to receive similar electronic messages from us in the future then please respond to the sender to this effect. Page 211 of 473 From:Cristen Ostrom To:Sarah Madden; Cheryl Jacobson Subject:Letter of concern re: proposed Wentworth Park Cell Tower Date:Friday, March 27, 2026 2:29:18 PM You don't often get email from cristen.ostrom@gmail.com. Learn why this is important Dear Mayor Levine and City Council Members, As a resident of the densely populated neighborhood bordering Wentworth Park I am writing to formally oppose the proposed cell tower. I am unable to attend the meeting on Tuesday, which is why I am sending this note. Placing industrial infrastructure in a high-use recreational area—where children play and families gather—is both unnecessary and contrary to the safety and aesthetic standards of Mendota Heights. My opposition is based on the following critical points: • Has there been an independent gap analysis?: If it has not been done already, I would like to request that the City Council require a certified, independent third-party gap analysis to verify claims regarding poor cell phone service. The provider must prove a "significant gap in coverage" exists that cannot be resolved through less intrusive means. In my mind, two or three houses without service does not = significance. Definitely an inconvenience, but other solutions must exist. • Have you exhausted co-location and small-cell alternatives?: My understanding is that under Mendota Heights City Code, the priority must be placed on co-location (using existing buildings, water towers, or utility poles). Has it been demonstrated that the purported gap cannot be filled by a "Small Cell" network (smaller antennas placed on existing light or power poles)? This would be far safer and less of an eyesore for our dense residential neighborhood. • Long-term health and biological concerns: I am deeply concerned about the continuous emission of radiofrequency (RF) radiation so close to homes and play areas. Many peer-reviewed studies link proximity to towers to neurological symptoms, headaches, and sleep disturbances. Organizations like the Environmental Health Trust argue that current FCC standards are outdated and do not account for the biological vulnerability of children who use this park daily. There continues to be significant debate around this exposure, with many independent researchers advising 500m+ distances for schools and homes. This is a very important consideration as we continue to mitigate the risks to our most vulnerable populations. • Physical safety hazard: A freestanding tower in a high-traffic park introduces risks of ice fall, equipment failure, and structural collapse. In our densely populated area, the "fall zone" of a 100+ foot tower creates an unacceptable liability for public walking paths and nearby private property. Children often play within the woods, and it's imperative that we maintain the natural playground that exists at Wentworth. • Aesthetic and property value risks: Our parks are valued for their natural beauty. An industrial monopole would create a permanent visual blight, fundamentally altering the character of the neighborhood and negatively impacting the property values of the surrounding homes. I urge the Planning Commission and City Council to protect our shared green space and the well-being of our citizens by denying this Conditional Use Permit and directing the carrier to Page 212 of 473 pursue existing structures or small-cell technology. Sincerely, Cristen Ostrom 1402 Cherry Hill Road Mendota Heights, MN 55118 Page 213 of 473 From:Stephanie Levine To:Cheryl Jacobson; Sarah Madden Subject:Fw: Opposition to Proposed 149-Foot Wireless Tower Installation Date:Friday, March 27, 2026 4:44:02 PM Attachments:image.png Stephanie B. Levine Mayor City of Mendota Heights C:651-302-0861 Website | Connect From: Isaiah Wallfred <iwallfred@gmail.com> Sent: Friday, March 27, 2026 3:18 PM To: Litton Field <LField@mendotaheightsmn.gov>; Jason Stone <JStone@mendotaheightsmn.gov>; Patrick Corbett <PCorbett@mendotaheightsmn.gov>; Cindy Johnson <CJohnson2@mendotaheightsmn.gov>; Jeff Nath <JNath@mendotaheightsmn.gov>; Brian Udell <BUdell@mendotaheightsmn.gov>; Steve Goldade <SGoldade@mendotaheightsmn.gov> Cc: Stephanie Levine <SLevine@mendotaheightsmn.gov> Subject: Opposition to Proposed 149-Foot Wireless Tower Installation You don't often get email from iwallfred@gmail.com. Learn why this isimportant Dear Members of the Planning Commission, I am writing to express my strong opposition to the proposed installation of a 149-foot wireless tower in the park, approximately 400 feet from our house. My family and I lived in St. Paul for 10+ years before moving to this neighborhood last spring. One of the primary reasons we chose our home was the unique setting. Our backyard opens directly into the park, offering privacy, unobstructed natural views, and a peaceful environment. It has been incredibly meaningful to step out onto our deck or backyard and see nothing but nature, without the visual intrusion of buildings or structures. We have spent countless hours outdoors enjoying this space, and it has truly enhanced our quality of life. The introduction of a large wireless tower would fundamentally change that experience. The idea of walking outside each day and being confronted with a 149-foot structure is deeply disappointing. Quite honestly, I am not sure we would have purchased our home had this tower already been in place. Its presence will not only diminish the natural beauty of the area but will also have a negative impact on property values. Page 214 of 473 Additionally, placing such a structure within a park setting feels inappropriate. Parks are meant to preserve natural landscapes and provide a refuge from development, not serve as sites for large infrastructure projects. I strongly urge the Commission to consider alternative locations, such as areas closer to the freeway or other less intrusive sites, where the visual and community impact would be significantly reduced. I respectfully ask that you reconsider this proposal and prioritize preserving the character, beauty, and value of this neighborhood. Thank you for your time and consideration. Isaiah Wallfred Park High School Head Boys Basketball Coach iwallfred@gmail.com Page 215 of 473 612-559-2395 Page 216 of 473 From:Nicole Gibbs To:Stephanie Levine; Sarah Madden Subject:Opposition to Proposed Cell Tower in Wentworth Park Date:Friday, March 27, 2026 1:24:58 PM Attachments:image003.png You don't often get email from ngibbs@beehivepr.biz. Learn why this is important Dear Mayor Levine, Community Development Manager Madden and Members of the Mendota Heights Planning Commission, I write to share my opposition to the proposal to build a 140' wireless tower in Wentworth Park for the following reasons: 1) Decrease in property values: According to Environmental Health Sciences (a nonpartisan nonprofit dedicated to good science and shaping public opinion), "Realtors and peer-reviewed studies report that cell towers can reduce home property values by up to 20 percent. Buyers avoid properties near towers, citing aesthetics and health concerns. Expert appraisers, municipal filings, and international research document lasting devaluation and loss of marketability from large cell tower structures placed close to residential neighborhoods." Our home, 2 blocks away from the park, is a significant financial asset for our family; construction of this tower may mean a >$150K reduction in property value for us. 2) Daily radiation exposure, which increases year over year. Numerous studies have reported associations between cell tower RF radiation exposure and health effects. A 2022 published review found over 73% of studies on people living near cell towers reported adverse effects such as higher cancer rates, biochemical changes, and radiofrequency sickness symptoms including headaches, sleep issues and memory issues. (https://www.sciencedirect.com/ science/article/abs/pii/S0013935122011781) Cell tower radiation levels typically rise year after year because networks are continually upgraded and expanded, even after a tower is first approved. Note that major insurers classify cell tower radiofrequency (RF) radiation as a high-risk liability, often comparing it to hazards like asbestos and lead due to its potentially serious long-term impacts. The Swiss Re Institute, one of the world’s top reinsurance authorities, has labeled 5G an “off-the-leash” risk—its term for emerging technologies with unpredictable and potentially widespread consequences. Because of this financial exposure, most major U.S. insurance providers now exclude coverage for damages related to non-ionizing electromagnetic fields (EMF), including the RF radiation emitted by cell towers and wireless network infrastructure. 3) Fire risk. Cell towers and 5G small-cell wireless installations pose recognized fire hazards due to their combination of high-powered electrical equipment, lithium-ion backup batteries, and densely packed electronics. Electrical faults, such as arcing, overheating, insulation failure, or wiring defects, can ignite fires inside equipment cabinets and at the base of towers, and electrical malfunctions are among the most frequently documented causes of tower-related fires worldwide. Fires on energized equipment cannot be extinguished with water until the grid is cut. This shutdown process can take up to an hour, allowing fires to grow unchecked. Page 217 of 473 4) Hazardous waste. Cell tower sites often store hazardous materials that pose chemical and environmental hazards if damaged or improperly maintained. Backup power systems may include lead acid batteries and diesel fuel tanks (some with over 180 gallons of fuel), which can leak during equipment failure, accidents, or natural disasters. Some county fire departments even register tower sites as HAZMAT sites because first responders must be prepared for risks such as battery acid exposure, fuel ignition, groundwater contamination, and toxic smoke if equipment burns. 5) Aesthetics. Wentworth Park is a green oasis in our suburban landscape. It's a place to play, relax, and gather. Imagine holding a baseball game, a National Night Out get together, or an outdoor knitting circle within feet of a wireless tower that is nearly the size of the Statue of Liberty – neither peaceful or healthy. Our neighborhood - and the entire surrounding community - is proud of Wentworth Park. It’s a place where we meet friends and neighbors to play baseball, ice skate, play pickleball, shoot hoops, swing, climb on the playground, watch the neighborhood barred owl, walk dogs, hold picnics, sling hammocks, and gather. This tower not only poses significant risk to our property values and health but will irreparably diminish the community value of Wentworth Park. Sincerely, Nicki Nicki Gibbs (She/her) What’s this? Chief Strategy Officer Phone 651.789.2234 | Cell 651.755.7990 Email ngibbs@beehivepr.biz Beehive Strategic Communication 651.789.2232 | beehivepr.biz Page 218 of 473 From:Norma Farah To:Sarah Madden Subject:MH resident comment on proposed cell tower permit Date:Friday, March 27, 2026 10:13:32 PM You don't often get email from farahnorma2@gmail.com. Learn why this is important Hi Sarah, My name is Norma J Farah and I'm a Mendota heights resident. I want to provide a comment on the proposal in case I can't make it to the meeting on Tuesday. I am strongly for this new cell tower, I think it's desperately needed. On a personal level I have been frustrated for years at the poor cell coverage in the city. I understand that people are concerned about the look of a cell tower in the park but my opinion is that: 1. I'm more concerned with children's safety while playing in the park then the look of a tower. If my son is out there and sprains his ankle or is approached by a stranger I want him to be able to call for help immediately and not have the call potentially drop repeatedly or not even go through at all. This is something that happens to me while walking through the neighborhood constantly and while it's a frustration it's also a genuine safety concern. 2. I understand that towers can be hidden or blended into the environment quite well. While it might still be noticeable I think the concerns by other residents are misguided and overstated. I'm concerned that a few loud voices will overstate the harm of a new tower while the many people frustrated the current cell coverage in the area may not be aware enough to come. A quick search on the local Facebook group shows that over the last several years poor cell coverage has come up multiple times as a concern for residents and these posts often have many comments. What's more, while the lack of cell tower harms Mendota heights residents it also harms our neighbors in West Saint Paul. My mother for example, lives in West Saint Paul right on the border of Mendota heights, her voice can't be heard at the hearing but this affects her as well. I understand that this has been an ongoing discussion for many years but I truly hope that now will be the time that we get this cell tower. Please do not let a few disenting voices harm the quality of life for all of us. The ability to make a timely phone call and get in touch with a guardian or emergency services can be all the difference for an endangered child, an injured senior, or someone in an accident. Thank you, if this is not the place to send my comment please let me know. Norma Farah Page 219 of 473 From:Tony Loftsgaarden To:Sarah Madden Subject:New Tower at Wentworth Date:Friday, March 27, 2026 4:54:07 PM You don't often get email from tlofts1@gmail.com. Learn why this is important Sarah, Call me weird, but I'd actually prefer less 5G and alot less large obstructive towers in my parks and near my home. But thats just me. -- Tony & Jane Loftsgaarden 1565 Dodd Road Mendota Heights MN Page 220 of 473 You don't often get email from ritadesmond656@gmail.com. Learn why this is important From:Cheryl Jacobson To:Sarah Madden Subject:FW: Proposed Cell Phone Tower Date:Monday, March 30, 2026 8:49:36 AM For the record. From: Rita Desmond <ritadesmond656@gmail.com> Sent: Saturday, March 28, 2026 8:56 PM To: Cheryl Jacobson <CJacobson@mendotaheightsmn.gov>; slevine@mendotaheoghtsmn.gov Subject: Proposed Cell Phone Tower Mayor and Council Members: I want to thank you for pursuing the construction of a cell phone tower in Wentworth Park. We have waited for 25 years to get equivalent service enjoyed by other city residents. At the current time, we do not have an option to get rid of our land line. We also are unable to complete a call while driving down our street. Finally we have had friends ask us why we live in Mendota Heights without service; they wouldn't. It will be nice to arrive in the 21st century. Thank you. Page 221 of 473 From:Jackson Evans To:Litton Field; Jason Stone; Patrick Corbett; Cindy Johnson; Jeff Nath; Brian Udell; Steve Goldade Cc:Sarah Madden Subject:Wentworth Park Tower - Request Commission seek information Date:Saturday, March 28, 2026 3:23:17 PM Dear Members of the Planning Commission, I am writing regarding the pending conditional use permit application for the proposed telecommunications tower at Wentworth Park. I respectfully request that this communication be included in the record. Pursuant to City Ordinance Section 12-5B-1 (6), which authorizes the City Staff, Planning Commission, and City Council to request additional information or expert analysis, I respectfully request that the Commission seek consent to obtain expert analysis or in the alternative, additional information from the applicant on two specific issues. First, I request that the Commission require a more accurate visual depiction of the proposed tower, or clarification of the assumptions and methodology used in the submitted renderings (see pages 67 and 69 of the application materials). The City has indicated that the tallest trees within Wentworth Park are approximately 60 to 80 feet in height.* The submitted renderings appear to depict the proposed 149-foot tower as significantly less prominent relative to surrounding tree cover than would be expected at that height. Because visual impact and compatibility with parkland are relevant considerations under the CUP ordinance, it is important that the record contain accurate and representative depictions. Accordingly, I request that the Commission seek the applicant’s consent to retain an independent expert, to conduct a balloon test or other industry-standard visibility analysis and prepare corresponding visual simulations. In the alternative, I request that the applicant provide revised renderings along with a clear explanation of the assumptions and methodology used to generate the depictions. Second, I request that the Commission seek additional information or expert analysis regarding the applicant’s assertion that the proposed tower will not depreciate surrounding property values. In the application (page 59 of the meeting materials), the applicant states that the tower “will not depreciate surrounding property value” and may have “a slight positive effect.” As presented, this statement appears conclusory and unsupported by any site-specific analysis. Accordingly, I request that the Commission seek the applicant’s consent to retain an expert, to evaluate potential property value impacts, or alternatively, request the applicant provide the evidentiary basis for this assertion, including any studies, data, or analyses relied upon in making that statement. Ensuring that these issues are fully and accurately developed in the record will assist the Commission in making findings supported by substantial evidence and will strengthen the the Commission’s ultimate decision. Thank you for your consideration. Jackson Evans *The 60-80 foot tree height reference comes from Meeting Minutes of the City Council of Page 222 of 473 August 19, 2025 available at _08192025-370 Page 223 of 473 From:Rick Kigin To:Sarah Madden Subject:Planning case # 2026-05, Wireless tower in Wentworth Park. Date:Sunday, March 29, 2026 8:36:13 AM You don't often get email from rkigs57@gmail.com. Learn why this is important Ms Madden, We moved into our home at 679 3rd Avenue 11 years ago. We love our neighborhood and Mendota Heights, however, we have had extremely poor cell service for years. We have dropped calls or poor reception all over our house, in our garage and even driveway. We do not have a landline in our home and worry that if there was an emergency, we would not be able to contact the police or fire services. This problem is not just with our provider, Verizon, we have had visitors with other carriers that have experienced problems too. We have a dog that we walk through the neighborhood and cannot carry a conversation on our phones as our calls get dropped. We are very much in favor of having a tower in Wentworth Park if it means getting more reliable cell service in our neighborhood. Rick and Laura Kigin, 679 3rd Ave. 651-270-6948 (Rick) Page 224 of 473 You don't often get email from rachelmlind44@yahoo.com. Learn why this is important From:Cheryl Jacobson To:Stephanie Levine; John Maczko; John Mazzitello; Joel Paper; Sally Lorberbaum; Sarah Madden Subject:FW: cell tower Date:Monday, March 30, 2026 8:49:06 AM Information sharing, in case you didn’t receive this directly. -Cheryl From: Rachel Lind <rachelmlind44@yahoo.com> Sent: Saturday, March 28, 2026 3:10 PM To: Cheryl Jacobson <CJacobson@mendotaheightsmn.gov> Subject: cell tower We are on 2nd Avenue and have bad cell reception from Verizon so we would benefit from a tower. We use Wentworth park for walking often and would not mind a tower near the parking lot. Rachel and Byron Lind Page 225 of 473 From:CityHall To:Sarah Madden Subject:FW: Online Form Submittal: General Inquiry Form Date:Monday, March 30, 2026 8:02:23 AM From: noreply@civicplus.com <noreply@civicplus.com> Sent: Sunday, March 29, 2026 3:16 PM To: CityHall <CityHall@mendotaheightsmn.gov> Subject: Online Form Submittal: General Inquiry Form General Inquiry Form First Name Arnold Last Name London Email arnold.london2516@gmail.com Phone Number 6128122391 Comment or Question After more consideration, the uncertain health effects of the proposed cell tower in Wentworth Park make me less certain that building the tower would be safe. I withdraw my support from the proposed tower. Arnold London How would you like to be contacted? No need to contact me Email not displaying correctly? View it in your browser. Page 226 of 473 You don't often get email from noreply@civicplus.com. Learn why this is important From:CityHall To:Sarah Madden Subject:FW: Online Form Submittal: General Inquiry Form Date:Monday, March 30, 2026 8:02:36 AM From: noreply@civicplus.com <noreply@civicplus.com> Sent: Sunday, March 29, 2026 1:34 PM To: CityHall <CityHall@mendotaheightsmn.gov> Subject: Online Form Submittal: General Inquiry Form General Inquiry Form First Name arnold Last Name london Email arnold.london2516@gmail.com Phone Number 6128122391 Comment or Question Re: the 3/31/26 planning commission meeting re the proposed cell tower in Wentworth Park. I live at 1628 Pamela Lane and am a Verizon cell service customer and have spotty reception. I believe this tower is for Verizon service and will improve my reception. The company Vertical Bridge that constructs the tower is carbon neutral, which is laudable. I would support the construction of this tower. Arnold London How would you like to be contacted? No need to contact me Email not displaying correctly? View it in your browser. Page 227 of 473 From:CityHall To:Sarah Madden Subject:FW: Online Form Submittal: General Inquiry Form Date:Monday, March 30, 2026 10:05:20 AM From: noreply@civicplus.com <noreply@civicplus.com> Sent: Monday, March 30, 2026 8:50 AM To: CityHall <CityHall@mendotaheightsmn.gov> Subject: Online Form Submittal: General Inquiry Form General Inquiry Form First Name Jean Last Name London Email londo005@comcast.net Phone Number 6127992035 Comment or Question I have lived in Mendota Heights for 41 years. I have raised my family here and I have used technology on a regular basis. I am totally opposed to the cell tower for a number of reasons but generally because the potential health risks to the children whose families are enjoying Wentworth Park or living nearby have not been examined closely. I have not found my cell connection particularly problematic and I use it regularly. My address is 1628 Pamela Lane, Mendota Heights MN 55118. How would you like to be contacted? Call me Email not displaying correctly? View it in your browser. Page 228 of 473 From:Tamara Peterson To:Litton Field; Jason Stone; Patrick Corbett; Cindy Johnson; Jeff Nath; Brian Udell; Steve Goldade; Sarah Madden Subject:Objection to proposed cell tower in Wentworth Park Date:Monday, March 30, 2026 9:39:57 AM You don't often get email from tamara0peterson@gmail.com. Learn why this is important Dear Mendota Heights Planning Commission, I am writing as a resident of the Cherry Hill / Wentworth neighborhood to express my opposition to the proposed cell tower installation at Wentworth Park. I fully understand and appreciate the importance of reliable wireless service, particularly as it relates to public safety and emergency response. Strong communication infrastructure is essential for our community, and I support efforts to improve coverage where needed. However, I believe that Wentworth Park is not an appropriate location for this type of development. The presence of a cell tower in this location could have a negative impact on surrounding property values, which is a significant concern of mine as well as many nearby homeowners. In addition, the park serves as an important community space for recreation, natural beauty, and family use. Introducing a cell tower in this setting would negatively impact the character, aesthetics, and overall experience of the park for residents and visitors alike. I respectfully request that the City more thoroughly evaluate alternative locations or technologies that could meet coverage needs without compromising one of our community’s valued green spaces or negatively impacting nearby residents property values. Thank you for your time, consideration, and service to our community. Sincerely, Tamara Peterson 779 Upper Colonial Drive 612-849-7717 -- Tammy Peterson Page 229 of 473 From:Cammie Evans To:Sarah Madden Subject:Petition against the wireless tower in Wentworth Park Date:Monday, March 30, 2026 10:14:36 PM Attachments:Petition Comments - 3.30.2026 10.11pm.pdf [You don't often get email from cammieldowning@yahoo.com. Learn why this is important at https://aka.ms/LearnAboutSenderIdentification ] Hello, Please include this with the written record of public comments concerning the wireless tower proposed for Wentworth Park. On 3/24/2026 we started a petition called "Stop Buell Consulting from building a 149' wireless tower in Wentworth Park." As of 3/30/2026 we have collected nearly 300 signatures from community members who oppose construction of this tower. Several signatories included comments and I have attached those to this e-mail. Concerns about the tower degrading the health, safety and general welfare of the community are a common theme. According to Mendota Heights City Statute, for a Conditional Use Permit to be granted it must NOT adversely affect those conditions. Thank you, Cammie Evans Sent from my iPhone Page 230 of 473 Petition: "Stop Buell Consulting from building a 149' wireless tower in Wentworth Park." Comments as of 3/30/3036, 9:40pm Name City State Postal Code Country Commented Date Comment Jessemy Neiger Mendota Heights MN 55118 United States 3/25/2026 "I think wireless towers are better suited to industrial spaces. Let's keep new construction out of our park. I'm working on finding out where the lease money would go from the lease. It's unclear to me how the revenue would benefit Mendota Heights citizens." Michael Spence Saint Paul MN 55118 United States 3/25/2026 "I am concerned about The large base of this unit and the height of the unit. I am concerned that if it requires lighting at the top that this will add to the light pollution, that’s already present in our area." Stanley Genadek Mendota Heights MN 55118 United States 3/25/2026 "These towers emit radiofrequency electromagnetic fields (RF-EMF) With some people experiencing headaches, sleep issues, fatigue and difficulty concentrating. We don't want this in our community." Kelli Nielsen Minneapolis MN 55407 United States 3/26/2026 "Wentworth park is a beloved green space in our community. My kids and I frequent it often. Part of why people live in Mendota Heights is the natural beauty. Please don't disturb that." Chris E South Saint Paul MN 55075 United States 3/26/2026 "I went to this park a lot as a kid and now I bring my child to play at this park. Please preserve the park's quaint charm for families to continue to enjoy and God bless" Tracy Rydberg Mendota Heights MN 55118 United States 3/27/2026 "Would not like a 150 foot blinking tower just outside my door in my residential neighborhood. There must be a better place like in the village for example where it’s not outside homes or some other industrial area" Page 231 of 473 Petition: "Stop Buell Consulting from building a 149' wireless tower in Wentworth Park." Comments as of 3/30/3036, 9:40pm Name City State Postal Code Country Commented Date Comment Brian Stawarz Mendota Heights MN 55118 United States 3/27/2026 "As a longtime resident of this community, I believe the inappropriate building of this cell tower would permanently disrupt and functionally destroy the quiet and family friendly nature of our park. I vehemently oppose this proposal. Brian Stawarz" Sandra McGown Saint Paul MN 55118 United States 3/28/2026 "A park is not conducive to a wireless tower. The environmental footprint is huge aa it disrupts the habitat for all the wildlife, birds and insects within the park." Chris McGown Mendota Heights MN 55118 United States 3/28/2026 "I’ve lived in this area for 70 years and love the country feel this park gives are neighborhood. A wireless a wireless tower would definitely be unwanted." Jennie Wang-Paterson Mendota Heights MN 55118 United States 3/30/2026 "Wentworth Park is the place where our community congregates with families and friends. It’s such a peaceful and fun place for everyone to enjoy. Not only will the tower take away that sanctuary for the neighborhood, it’s also a safety concern. Please help protect our children by not putting a tower there!!" Sarah Ritter Mendota Heights MN 55118 United States 3/30/2026 "A huge tower like this does not belong in a park nor should it be placed so near a residential area. Aside from the health concerns listed by others, this will also be a complete eyesore. Put it in an industrial part of town zoned for that type of purpose. What are they thinking? $15,000 is not enough annual revenue to justify destroying a greenspace with an unsightly tower." Page 232 of 473 Petition: "Stop Buell Consulting from building a 149' wireless tower in Wentworth Park." Comments as of 3/30/3036, 9:40pm Name City State Postal Code Country Commented Date Comment Benji Paterson Saint Paul MN 55120 United States 3/30/2026 "Mendota Heights' slogan reads: "between St.Paul And Minneapolis The [sic] Best Kept Secret." Installing a 150ft cell tower in a residential neighborhood but refusing to implement street lights to retain a "small- town" feel directly contradicts installing an enormous tower visible for miles around. Refer to other comments and this article (https://kstp.com/kstp- news/top-news/proposed-cell-tower-at-mendota- heights-park-sparks-debate/) for additional info on the harm caused by HF transmitters and cell towers. Priorities, people." Anthony Ferrara Mendota Heights MN 55118 United States 3/30/2026 "This is an issue that needs more study and better communication with needs, risks, and all options. You seem to be rushing to get this done and I don’t agree with that at all." Becky Pentel Mendota Heights MN 55118 United States 3/30/2026 "I’m so surprised that the mayor and some council members are for this. This DOES NOT belong in a residential neighborhood. Do your homework on the damage these can cause to people, CHILDREN and the environment. I’ve lived near this park 61 years and would hate to see this go up and not be able to use this park. Also, I have not noticed any cell service disruption." Amelia Vandarious Saint Paul MN 55118 United States 3/30/2026 "More research should be done (if it has been done then it should be communicated). Are there other ways to address the need? Has a cost benefit analysis done? I am against any cell phone tower builds unless the need is dire and the benefits outweigh the health and aesthetic consequences." Page 233 of 473 From:Mary Walsh To:Sarah Madden Subject:Planning Case No 2026-05 Date:Monday, March 30, 2026 8:52:25 AM You don't often get email from mmkw43@gmail.com. Learn why this is important I support the construction of the 149 foot tall monopole wireless tower. I spend many hours, spring through fall, working in my yard or walking. I would like to have the ability to contact 911 quickly if I see a potential or real emergency where seconds could make a difference. I think having reliable cell phone reception is a necessity in this day and age. Mary Walsh 678 2nd Avenue Page 234 of 473 From:G To:Litton Field; Jason Stone; Patrick Corbett; Cindy Johnson; Jeff Nath; Brian Udell; Steve Goldade Cc:Sarah Madden Subject:Submitting documentation for public record regarding the Wenworth Park Tower Proposal Date:Monday, March 30, 2026 8:20:03 PM Attachments:art2Fs11146-017-9600-9.pdf 8_190520DisamenityValueCellTowers_Hell_Beck_USA_PublishedPaper.pdf ijhma-12-2023-0167.pdf Cell-Towers-Drop-Property-Values.pdf You don't often get email from ostgaardg0@gmail.com. Learn why this is important Hello, I am submitting the attached studies to be entered into the public record regarding the proposed tower at Wentworth Park. These studies indicate that the presence and visibility of cell towers negatively influence residential property values and neighborhood livability, with impacts increasing at closer distances. I respectfully request that members of the Planning Commission and City Council review these materials as part of their evaluation of this proposal. Dr. Gayra Ostgaard 757 Upper Colonial Drive Mendota Heights MN 6513036397 Page 235 of 473 Wireless Towers and Home Values: An Alternative Valuation Approach Using a Spatial Econometric Analysis Ermanno Affuso 1 &J. Reid Cummings 2 & Huubinh Le 3 Published online: 18 February 2017 #Springer Science+Business Media New York 2017 Abstract Thisisthefirststudytouseanhedonicspatialautoregressivemodeltoassessthe impact of wireless communication towers on the value of residential properties. Using quantile analyses based on minimum distances between sold properties and visible and non-visible towers, we examine the relationship between property values and wireless tower proximity and visibility within various specified radii for homes sold after tower construction. For properties located within 0.72 kilometers of the closest tower, results reveal significant social welfare costs with values declining 2.46% on average, and up to 9.78% for homes within tower visibility range compared to homes outside tower visibility range;inaggregate,propertieswithinthe0.72-kilometerbandloseover$24milliondollars. JEL Classifications C5 .K32 .Q51 .R21 .R32 .R38 .R58 Keywords Hedonicanalysis .Housingvalue .Landplanning .Publicplanning .Spatial econometrics .Urbanexternalities .Wirelesstowerimpacts J Real Estate Finan Econ (2018) 56:653–676 DOI 10.1007/s11146-017-9600-9 *Ermanno Affuso eaffuso@southalabama.edu J. Reid Cummings cummings@southalabama.edu Huubinh Le hble@southalabama.edu 1 Department of Economics and Finance, Mitchell College of Business, University of South Alabama, 5811 USA South Drive, Room 314, Mobile, Alabama 36688, USA 2 Department of Economics and Finance, Mitchell College of Business, University of South Alabama, 5811 USA South Drive, Room 126, Mobile, Alabama 36688, USA 3 Department of Economics and Finance, Mitchell College of Business, University of South Alabama, 5811 USA South Drive, Room 312, Mobile, Alabama 36688, USA Page 236 of 473 In less than 20 years, the number of wireless devices in use 1 in the United States increased 1045%, growing from 340,213 in 1985 to over 355 million in 2014 (CTIA 2015). A growing number of Americans now rely solely on their wireless phones for communication. As of the end of 2014, the Centers for Disease Control and Preven- tion’s National Center for Health Statistics reports that 44% of American households no longer subscribe to landline telephone service; they predict that by the end of 2015, a majority will have severed the cord (Centers for Disease Control and Prevention 2015). U.S. wireless device numbers are truly staggering: 2014 usage comprised 2.45 trillion voice minutes, 4.06 trillion megabytes of data, 1.92 trillion text messages, and 151.99 billion multimedia messages (CTIA 2015). Incredibly, even on the heels of a doubling of wireless data usage from 2012 to 2013, analysts expect data use to surge, growing by more than 650% by 2018 (Cisco 2013). In 2012, wireless industry employment topped 3.8 million people—2.6% of the U.S. workforce (Entner 2012). Analysts predict the industry will create 1.2 million new jobs by 2017 (Pearce et al.2013). U.S. wireless carriers’capital investment exceeded $33 billion in 2013—arecordannualhigh—and wireless industry experts project an additional $260 billion in new capital investment over the next 10 years (CTIA 2015), adding $2.6 trillion to U.S. gross domestic product (Summers 2010). Perhaps the most surprising, yet at the same time most impressive statistic is that by comparison, the total value of the U.S. wireless industry—currently $196 billion in 2012—exceeds that of agriculture, hotels and lodging, and air trans- portation (Entner 2012). Without question, there are many societal benefits offered by the last two decades’ myriad advances in wireless technologies. Ease of use and convenience, lower equip- ment pricing, increasingly competitive rate plans, surges in wireless industry employ- ment, considerable economic multiplier effects from large-scale wireless industry capital investment, and significant realized and projected annual contributions to GDP all work to make the U.S. wireless industry an ever-increasing, important part of our daily lives and our national economy. Yet to date, a largely overlooked societal cost is the potential negative impact on residential property values caused by the exponential proliferation of the number of cell sites 2 necessary to support the wireless industry’s rapid growth. In 1985, there were only 900 cell sites in the U.S., but by the end of 2014, the number had increased by 22,778% (CTIA 2015). Of the more than 298,000 cell sites in the U.S., nearly 70% are located on tower structures (Airwave Management, LLC 2013). Amidst intense competition to meet seemingly unceasing demand, providers work continually to improve their wireless service coverage. As they do so, it is logical to expect construction of an increasing number of new wireless towers, located closer and closer together in many urban and suburban areas. As this happens, it is also logical to expect an increasing number of homeowners to question if, and to what extent proximity to a wireless tower affects home values. Those concerned with such questions might also hope that public policy makers will begin asking the same questions, and more importantly, consider the ramifications of the answers as they manage the increasing pressures placed on wireless tower regulatory planning and approval processes. 1 Wireless devices include special feature phones, smartphones, and tablets. 2 CTIA defines a cell site as the location of wireless antenna and network communications equipment necessary to provide wireless service in a geographic area (CTIA 2015). 654 Affuso et al. Page 237 of 473 Considering the expected future increases in wireless device users and the cell sites supporting them, this is a critically important question for our time. However, only a few researchers have examined this issue, all yielding somewhat mixed results. In all, the extant literature includes six relevant studies. The first is perceptions-based, offering residents’opinions of how tower proximity influences property values (Bond and Beamish 2005). The second combines a similar perceptions-based component with an hedonic model to estimate sales price impacts (Bond and Wang 2005). The remaining four studies take a strictly empirical approach using hedonic modeling estimations and different types of spatial analysis techniques (Bond 2007a,b; Filippova and Rehm 2011; Locke and Blomquist 2016). Unfortunately, each study suffers from flaws of one sort or another—time invariant issues, inaccurate spatial modeling techniques, or other troublesome variable misspecifications. In essence, the results of these studies are either inconclusive or show only minimal negative price effects due to wireless tower proximity. In our study though, we use a robust approach for gauging home values relative to tower proximity. Similar to others, our study includes hedonic modeling to capture distinctive property characteristics, yet it is distinctly different from others in two important respects. By performing the analysis within varying radii bands based on quartiles of the distance from the closest wireless tower, we are able to detect potential marginal price gradients of each property across the banded space. More importantly, by conducting a series of robust spatial econometric tests, we are able to identify and use the most unbiased, efficient spatial model that is best suited for the inferential analysis of our research question. The results underscore our concerns that previous studies may potentially suffer from bias due to their failures to address spatial correlation issues typical in hedonic model studies. Two significant reasons contribute to our apprehensions. The first is that Ordinary Least Squares (OLS) estimations are biased and inefficient in the presence of spatial correlations of dependent variables and residuals. The second is that by not accounting for spatial autocorrelation, it is unlikely any hedonic model can correctly disentangle either direct and/or indirect effects of (dis)amenities on housing prices. Research shows the latter is particularly useful when assessing the impact of corrective policy solutions subsequent to market failures (LeSage and Pace 2009). This is important because our research poses potentially signif- icant policy implications, all of which we believe will most likely, yet for substantially different reasons, be of keen interest to governmental and planning officials, wireless tower operators and service providers, neighborhood activist groups, and private property rights’advocates. In the second section of our paper, we discuss the relevant literature. In the third section, we delineate our data and define our variables. In the fourth section, we develop our hypotheses and methodology. In the fifth section, we present our empirical results, and the final section concludes. Literature Review McDonough (2003)statesB…proximity to a wireless tower needs to be considered as a negative amenity that may reduce property valuation^(McDonough 2003,p.29). Wireless Towers and Home Values 655 Page 238 of 473 Despite this recognition and the ongoing rapid expansion of the wireless industry, research examining the relationship between wireless tower proximity and home values remains quite limited. Two early studies commissioned by a major wireless service provider look at potential health and visual impacts that wireless towers 3 may have on property values. Bond and Beamish (2005) report that although the studies’results remain secretive, their private review of the results confirms no statistically significant relationships exist. They note, however, that because the studies involve limited sales data, and the underwriter is also a service provider, the question of biased results is potentially concerning. Some researchers tackle the question using perceptual studies. Bond and Beamish (2005) survey residents in ten Christchurch, New Zealand suburbs—half being study areas (residents living within 300 m of a tower) and half being a control group (residents living more than 1 km from a tower). The authors aim to gauge residents’ perceptions about whether and to what extent wireless tower proximity influences property values. Not surprisingly, those living far from a tower express less concern than those living close to one. Distance from a tower largely drove respondents’ answers, but in sum, the authors find expectations of more than a 20% price reduction for properties within close tower proximity. Bond and Wang (2005) combine a perceptual study with an empirical investigation. The perceptual component outcomes are quite similar to those of Bond and Beamish (2005). Their survey’s respondents believe that proximity to a wireless tower causes property values to decrease from 10% to more than 20%. The empirical portion of their study includes approximately 4000 home sales spanning from 1986 to 2002 in four different suburbs. The authors’hedonic model includes a dummy variable that captures whether sales occur before or after tower construction. A potential shortcoming of this study could be the authors’choice to measure distances from cell towers not to individual homes, but rather, to a particular street within the study area. Their hedonic models do not account for potential spatial dependence of price and error structure. Their estimations produce mixed results, with negative price effects in two suburbs, a positive price effect in a third, and no significance in the fourth. Bond (2007a) offers a methodological improvement by calculating exact distances between towers and included properties. Using a dummy variable to capture if a sale occurs before or after tower construction, the author also accounts for sales price time- effects by deflating sales prices to the consumer price index, and includes a time of sale variable in the estimations. Using four of the same suburbs from the earlier work of Bond and Wang (2005), the results show sales price reductions of approximately 15% after tower construction, diminishing as distance from a tower increases. Past 300 m, the negative price effect is negligible. Unfortunately, the results lack consistency, producing a positive price effect in one of the four neighborhoods. This may suggest a possible model misspecification error, or the effect of some other unobservable externality. Bond (2007b) conducts a similar study using Orange County, Florida wireless tower and sales transaction data. Empirical results indicate a tower’s presence yields a statistically significant and negative impact on price. Even so, the author notes the negative price effects are of little consequence. 3 In their paper, the authors refer to wireless towers as cellular phone base stations. 656 Affuso et al. Page 239 of 473 Filippova and Rehm (2011) investigate tower proximity impacts on property values using property sales data from Auckland, New Zealand. Their final geocoded dataset includes approximately 56,000 sales observations dating from 2005 to 2007, and 521 tower locations. Highly critical of earlier studies’meth- odologies, the authors emphasize they took care to Bensure that integration dates of nearest cell towers did not occur after the date of sale^(Filippova and Rehm 2011, p. 250). To account for negative impacts that non-residential areas might have on residential area property values(forexample,seeBowesandIhlanfeldt 2001;Grass1992;NelsonandMcCleskey1990; Mahan et al.2000), the authors divide their sample into two parts. The first group includes only the 49 towers within residential areas, and all properties within a 500-m radius of existing towers. They also include a dummy variable for tower type, which they describe as lamppost, single monopole, or armed monopole (one with a triangular structure at the top). Generally, their residential area estimations produce no statistical significance. Not surprising, given the extremely close proximity to a tower, the lone exception is for houses located within 100 m of an armed monopole, which suffer a 10.7% price reduction. Estimations for the second group, which includes all towers in the entire study area, yield results similar to those in the first group. As such, the authors conclude that with the exception of a small number of armed monopole towers, wireless tower proximity does not negatively affect sales price. More recently, Locke and Blomquist (2016) explore the question at hand. They use housing sales (including repeat sales) from 2000 to 2012 occurring in Louisville and Elizabethtown, Kentucky, geocoding each sold property to the street address listed in the sales data. They develop a number of tower location- specific characteristics such as census tract, and distances to major roads, railroads, and military bases. The authors state that,BHolding all else constant, the owner of a communication antenna will attempt to locate the antenna in an area that minimizes the antenna owner’scost^(Locke and Blomquist 2016,p. 134). At first glance, this statement seems obvious, if for no other reason than it makes good business sense. Further thought, however, draws question to the authors’additional statement that,BIt appears that communication antennas are in fact located in areas where properties are less valuable^(Locke and Blomquist 2016, p. 134). One might infer from this that carriers strive mainly to construct towers in low-value areas simply to save money. Yet because intuition suggests carriers increase earnings by increasing subscribers, locating towers only in low- valued areas, and hence, providing service coverage only to presumably low- income people does not make good business sense. It seems, therefore, that the authors miss the other side of the coin, which is, in fact, not all towers appear in areas where properties are less valuable, but rather, owners will also construct towers in areas where properties are more valuable in order to fill holes in their service coverage. Indeed, tower location may be a source of endogeneity. How- ever, income, population density, and other unobserved neighborhood character- istics could be instrumental for both homeowners’property and wireless carriers’ tower location choices. Inclusion of spatial considerations in addition to hedonic characteristics in their modeling is a good choice, as it adds robustness to their results. However, as with previous studies, across all model estimations, the authors do not account for potential Wireless Towers and Home Values 657 Page 240 of 473 spatial correlation of price and error structure, finding only slight degrees of price reductions due to tower proximity, again, diminishing with distance. Data To investigate if and to what extent wireless tower proximity impacts home values we combine two datasets. The first includes 23,309 residential property sales occurring in Mobile County, Alabama between 1999 and 2015. 4 We deflate housing prices to a base year of 2014 using the U.S. Bureau of Labor Statistics’Housing Consumer Price Index. The second includes 149 wireless towers located in Mobile County, Alabama. 5 In addition to certain property characteristics, we also include key census tract-level demographic data. 6 Following Locke and Blomquist (2016), we conduct a visibility analysis of the wireless towers located in the study area. We do so using Viewshed 7 and a 30-m resolution digital elevation map of Mobile County, Alabama. 8 Following Paterson and Boyle (2002), we calculate the visibility for a 360° circle and 1-km radius, including the aboveground tower height, and assume that the average height of an observer’seyesis 1.75 m above the ground at each property’s location. Figure 1, Panel A illustrates the spatial distribution of towers, and Fig.1, Panel B illustrates the Mobile County, Alabama property locations. At a larger scale, Fig.2 shows the visibility of towers and properties located in the most urbanized portion of the Mobile County, Alabama. 9 Fig.2 helps to clarify graphically the idea of the indirect effect of a wireless tower. For example, although somepropertieslieimmediatelyoutsideoftheborderofthevisibilityrange(indicatedin the red area), they are contiguous to properties that lie within the border of the visibility range. If there are spatial correlations between property values and tower locations, then we argue that a tower affects both the value of the property location from which the tower is visible, and indirectly, the values of neighboring properties from which the tower is not visible. Additionally, towers that are farther away, but that are still visible from a property, may potentially influence a property’s value through a sort of spillover effect carried over across neighboring properties within the tower visibility space. We compute the minimum distance from each housing unit to the closest wireless tower using the Haversine distance formula, which takes into account the curvature of the Earth. We calculate the distance of housing unit i to the closest wireless tower j as: 4 Sold properties data draw from the Gulf Coast Multiple Listing Service, Inc., a wholly owned subsidiary of the Mobile Area Association of Realtors, Inc. 5 These data draw from the U.S. Federal Communication Commission’s Antenna Structure Registration database, available at http://wireless.fcc.gov/antenna/index.htm?job=home. 6 These data draw from the U.S. Census Bureau, available at http://www.census.gov. 7 The Viewshed tool is available as part ESRI ArcGIS® software package. 8 Digital elevation maps draw from publicly available information hosted by the Geospatial Data Gateway of the U.S. Department of Agriculture’s Natural Resources Conservation Service. 9 An anonymous referee observed that every property within a 1 km radius of a tower is also within the towers’viewshed. We believe that this unusual result is consistent with the average height of a wireless tower in our dataset of approximately 60 m, and, more importantly, with the fact that our property sales data draw from a fairly flat coastal geographical area (i.e., the average housing elevation of our sample ≈11 m above sea level). 658 Affuso et al. Page 241 of 473 d ij ¼min 2rarcsin h haversine φ j –φi þ cos φiðÞcos φ j haversine λ j −λi 0:5 i ð1Þ where r is equal to the Earth’sradiusof6371km,φ and λ are latitudes and longitudes of property and wireless tower locations expressed in radians. The average minimum distance of a property to a tower is 2.98 km, and we expect a negligible price impact for properties located farther away from a tower than this average. To investigate further the impact of towers on those dwellings that are closer, we conduct a sensitivity analysis using four subsamples based on quartiles of the minimum distance to the closest tower. The first, second, third, and fourth subsamples include houses within radii bands of between 0 to 0.72 km, 0.72 km to 1.13 km, 1.13 km to 1.88 km, and 1.88 km to 41 km of the closest tower, respectively. Table 1 lists and defines all of the variables we use in our analysis and summarizes the statistics for the whole sample of 23,309 properties. Table 2 presents the descriptive statistics of the variables across all four subsamples. Methodology Consistent with the literature, we use an hedonic model to investigate the relationship between property value and wireless tower proximity. Rosen (1974) was the first Legend Towers Non Visible Visible Digital Eleveation Value High : 109 Low : 0 sretemoliK502010 Legend Mobile County (CTG) Housing Units sretemoliK502010 (a) Spatial Distribution of Tower (b) Spatial distribution of properties. Fig. 1 Visibility Analysis: smaller scale Wireless Towers and Home Values 659 Page 242 of 473 researcher to derive a relationship between the price of a good and its characteristics. His work is widely used in real estate and urban economics research as an indirect method of revealing preferences used to analyze environmental externalities. As such, we assume that the property price is a function of the intrinsic characteristics of the property, neighborhood qualities, demographic characteristics, distance to wireless towers, and a spatial process (essentially, the spatial relationship between objects). Legend Towers Non Visible Visible Mobile County (CTG) Housing Units 05102.5 Kilometers Fig. 2 Visibility Analysis: larger scale 660 Affuso et al. Page 243 of 473 Hence, the econometric model used to examine the potential external impact of a wireless tower on property price takes the following form: ln PriceðÞi¼β0 þ β1 ln DistanceiðÞþβ2Dþβ3 D⋅ln DistanceiðÞþβ4Vþβ5 V ⋅ln DistanceiðÞþ β6 h toweri þ β7 V ⋅h toweri þ β8 Agei þ β9 Bedroomsi þ β 10 BedroomsiðÞ2þ β11Bathroomsi þ β12 Onestoryi þ β13Twostoriesi þ β14Carshelteri þ β 15Fireplacei þ β16 Fencei þ β17Deck i þ β18 Pooli þ β19Brick i þ β20Rurali þ β21 distCBDi þ β22Towersi þ β23ln IncomeiðÞþβ24lnBlack iðÞþβ25Unemploymenti þ ∑2013 t¼2008 τ t Yearti þ ∑31 j¼1 δ j Zipcodeji þ εi ð2Þ where ln(Price) is the natural log of the property sales price; ln(Distance)isthe natural log of the distance between a property and a wireless tower measured in Table 1 Summary Statistics Variable Definition Full Sample Mean SD Price inflation adjusted property sales price 167,592.3 124,777.1 Distance distance between the property and the tower 2.980 5.453 D* 1 if property sale occurs after tower construction 16,393 69.742 V* 1 if the tower is visible 9448 74.956 h_tower height of the tower 59.148 21.050 Age age of property in years 23.566 19.389 Bedrooms number of bedrooms in a property 3.285 .675 Bathrooms total number of bathrooms in a property 2.135 .671 Onestory* 1 if number of stories is 1 1860 41.371 Twostories* 1 if number of stories is 2 2275 45.310 Car shelter* 1 if a property has a car shelter 15,023 73.078 Fireplace* 1 if a property has a fireplace 15,080 72.965 Fence* 1 if exterior has a fence 9375 74.862 Deck* 1 if exterior has a deck 5377 64.317 Pool* 1 if exterior has a pool 189 13.692 Brick* 1 if construction is primarily brick 16,500 69.426 Rural* 1 if population is less than 2500 per census tract 2644 48.416 distCBD distance to downtown Mobile in kilometers 17.957 8.695 Towers number of wireless towers per census tract 4.305 5.709 Income median income per census tract 66,768.36 20,299.91 Black African-American population per census tract expressed in units 1070.72 812.315 Unemployment unemployment rate per census tract expressed in percentage points 9.207 5.417 N number of observations 23,309 The table above presents the summary statistics for the variables included in the entire dataset; year and zip code dummies are not shown; *binary variables (assumed to follow the binomial distribution): means and standard deviations for these variables are computed for the binomial distribution Wireless Towers and Home Values 661 Page 244 of 473 kilometers;D is a dummy variable that takes the value of one if the property was purchased after tower construction, and zero otherwise;V is a dummy variable that takes the value of one if the closest tower is visible from the property, and zero otherwise;h_tower is a continuous variable that measures the height of the closest tower above the ground in meters;Age is the age of a property in years;Bedrooms is the total number of bedrooms in a property;Bathrooms is the total number of Table 2 Summary Statistics for Variables in Each of the Four Subsamples Sample 1 a (0.00–0.72Km) Sample 2 b (0.72Km –1.13Km) Sample 3 c (1.13Km –1.88Km) Sample 4 d (1.88Km –41Km) Mean SD Mean SD Mean SD Mean SD Price 163,008.8 107,361.6 170,634.6 133,366.5 170,212.1 136,985.5 166,518.6 119,035.9 Distance 0.497 0.156 0.920 0.116 1.425 0.202 9.080 8.295 D*4087 34.942 4256 33.874 4246 33.942 3804 36.341 V*5759 8.257 3667 36.869 22 4.682 0 0 h_tower 53.920 20.199 53.436 19.845 56.434 19.090 72.803 18.778 Age 26.148 21.949 25.455 20.128 23.876 18.816 18.784 15.158 Bedrooms 3.269 0.629 3.322 0.634 3.312 0.735 3.238 0.695 Bathrooms 2.113 0.667 2.156 0.710 2.167 0.700 2.104 0.598 Onestory* 459 20.563 499 21.360 528 21.912 374 18.708 Twostories* 573 22.730 615 23.454 642 23.901 445 20.274 Car shelter* 3832 36.227 3858 36.106 3695 36.769 3638 36.968 Fireplace* 3806 36.338 4028 35.265 3910 35.866 3336 37.764 Fence* 2521 37.822 2576 37.910 2380 37.522 1898 35.774 Deck* 1222 31.077 1404 32.645 1369 32.363 1382 32.469 Pool*51 7.110 44 6.608 47 6.828 47 6.828 Brick* 3856 36.121 4142 34.608 4179 34.379 4323 33.404 Rural* 787 26.091 601 23.217 460 20.584 796 26.216 distCBD 14.625 5.891 15.037 5.601 16.037 5.524 26.131 10.758 Towers 5.523 5.743 5.152 6.474 4.671 6.242 1.875 2.881 Income 68,790.18 23,488.16 69,418.33 22,687.17 67,058.06 20,669.78 61,806.5 10,912.01 Black 1214.973 910.131 1139.579 801.164 1217.888 835.001 710.429 543.371 Unemployment 9.408 6.073 8.900 5.640 8.827 5.130 9.692 4.678 N 5828 5827 5827 5827 The table above presents the summary statistics for the variables within each of the four subsamples included in the analysis; *binary variables (assumed to follow the binomial distribution): means and standard deviations for these variables are computed for the binomial distribution a Sample 1 is a subsample of properties selected within the first quartile of the minimum distance to the closest wireless tower (radius ≤0.72Km); b Sample 2 is a subsample of properties within the second quartile of the minimum distance to the closest wireless tower (0.72Km ≤distance ≤1.13Km); c Sample 3 is a subsample of properties withinthe third quartile of the minimum distanceto theclosest wireless tower (1.13Km ≤distance ≤1.88Km); d Sample 4 is a subsample of properties within the fourth quartile of the minimum distance to the closest wireless tower (1.88Km ≤distance ≤41Km) 662 Affuso et al. Page 245 of 473 bathrooms and/or half-bathrooms in a property;Onestory and Twostories are binary variables equal to one if the property has one story or two stories above the ground level, respectively;Carshelter, Fireplace, Fence, Deck, Pool and Brick are dummy variables that take the value of one if a property has a car shelter, a fireplace, a fence around the house, a deck, a pool and/or the exterior construction is made of bricks respectively, and zero otherwise;Rural is a binary variable proxy for less dense populated areas that takes value one if the number of inhabitants per census tract is less than 2500, and zero otherwise;distCBD is a continuous variable that measures the distance of each property from the Central Business District of Mobile, Alabama, the largest city in the study area;Towers is the number of wireless towers per census tract; ln(Income)is the natural log of the median income per census tract; ln(Black)is the natural log of the African- American population expressed in units per census tract; and,Unemployment is the unemployment rate per census tract expressed in percentage points. As in Jensen et al. (2014), we add the interaction between distance to (dis)amenities and tower visibility (V), which we label ln(Distance)·V.WeuseYear , property sale year dummy variables, to control for the impact of the subprime mortgage crisis. Finally, following Caudill et al. (2014), we include Zipcode, a set of dummy variables that attempt to capture additional unobserved neighborhood heterogeneities at a higher resolution than the census tract. Since we are interested in examining the price sensitivity of buyers of homes closest to a wireless tower, we follow Locke and Blomquist (2016) instatingthedependent variablebeinginlogarithmic form. However, we also use the Akaike Information Criterion (AIC) to test several functional forms for hedonic price equations by varying the specification of the variables in the right-hand side of Eq. (2). We do so because by selecting the functional form having the lowest AIC value, we are able to produce a theoretical specification with the least possible information loss. We calculate the average impact of a wireless tower on housing price by subtracting expected housing values before tower construction from expected housing values after tower construction, using the equation taking the following form: E e Ln cprice jD ¼1 "# −E e Ln cprice jD ¼0 "# :ð3Þ We also calculate the total social welfare impact as: ΔW ¼∑N i¼1 e Ln cprice i jDi ¼1 ! − e Ln cprice i jDi ¼0 !"# :ð4Þ In addition, to examine the spatial price sensitivity of home buyers—the price elasticity of tower proximity—we partially differentiate Eq. (2) with respect to ln(Distance), using the equation taking the following form: ∂ln PriceðÞ ∂ln DistanceðÞ¼β 1 þ β3 D þ β5 V½%:ð5Þ Wireless Towers and Home Values 663 Page 246 of 473 We evaluate Eq. (5)asD=0and V=0(β1)for sales occurring before tower construction, and D=1and V=1(β1 +β3 +β5)for sales occurring after the visible tower construction. We additionally include D=1and V=0(β1 +β3), which accommodates comparison of price sensitivity of buyers of properties from which the closest tower is not visible. In certain hedonic studies, it is appropriate to perform statistical tests for spatial correlation.ThisisaconsequenceofTobler’sfirstlawofgeography,whichpremisesthe interrelationship of all things, but that closer things are more related than distant things (Tobler 1970). We use spatial correlation tests to account for spatial processes in the dependent variable and estimation residuals. In matrix notation, such a model reads as: y ¼ρWy þ Xβ þ I−λWðÞ−1 u ð6Þ where y is a n × 1 vector of property prices (previously defined);ρ is a scalar coefficient of spatial correlation;W is an n x n row, standardized spatial contiguity matrix based on thethreeclosestneighborsasoutlinedbyCaudilletal.(2014);X isann×63(numberof parameters of Eq.1 including intercept) data matrix with first column vector 1n;β is a 63 × 1 vector of parameters;I is an n x n identity matrix,λ is a scalar coefficient of residuals spatial correlation; and,u is an n × 1 vector of Gaussian innovations. We estimate the spatial model by maximizing the log-likelihood function (MLL) with respect to the model’s parameters, coefficients of spatial correlation (ρ and λ), and residual standard errors (σ) using the equation taking the following form: LL β;ρ;λ;σjyðÞ¼−0:5 n ln πðÞ−0:5 n ln σ2 þ ln I−λWjjþlnjI−ρWjðÞ–0:5 σ−2 u’ðÞuðÞ ð7Þ where n is the sample size,u =(I -λW)−1(I -ρW)y -(I -λW)-1Xβ;and,ln|I -λW| and ln|I -ρW| are the terms of the log-Jacobian transformation of u into y.Assuming the same geographic processes for the dependent variable and residuals (same W), the large sample Moran’s I test for spatial correlation of the residuals is: Z I ¼I −EIðÞ½=Var IðÞ0:5 ∼N 0;1ðÞ ð8Þ where I is calculated from the residuals of Eq. (2)asε’Wε/ε’ε. Since this test is asymptotically normal, if ZI > 1.96, with 95% confidence, we reject the null hypothesis that there is no spatial autocorrelation of the residuals. The econometric models presented in Eqs. (6)and(7) are generic representations of a spatial model which includes both a spatial autoregressive model—model with dependent variable spatially autocorrelated:λ = 0, and a spatial error model—model with residuals spatially autocorrelated:ρ = 0. Following Anselin (1988), in practice, we select only one of the two models. Following the suggestion of Anselin et al. (1996), we use Robust Lagrangian Multiplier (RLM) tests (H0: no spatial autocorrelation) of the residuals, using equations taking the following forms: RLMρ ¼ε’Wy=σ2 −ε’Wε=σ2 2 =σ2 WXβðÞ’MWXβðÞþnσ2−n ð9Þ 664 Affuso et al. Page 247 of 473 RLMλ ¼ε’Wε=σ2 −n σ2 hh WXβðÞ’MWXβðÞþnσ2 −1 ε’Wy=σ2 ii2 =n 1−n σ2 hh WXβðÞ’MWXβðÞþnσ2 ii−1 ð10Þ Both Eqs. (9)and(10)followtheχ2 distribution with one degree of freedom and include M = I-X(X’X)-1X as an idempotent projection matrix. Following Florax and De Graaff (2004), we select the model with the largest RLM statistics. Results and Discussion In this study, we conduct a pseudo-quantile analysis based on quartiles of the distance of each property from the closest tower. We refer to it as a pseudo- quantile analysis because we force the estimation of the conditional mean of the response variable on different values of the distance to the closest tower by subsampling the full data set for the four quartiles of this variable. The idea is to test our research hypothesis for properties located within different distance gradients from wireless towers. We do so by creating four spatial contiguity matrices (one for each sample). In Table 3, we report the results of both the Moran’s I and RLM tests for spatial correlation across all four samples. Table 3 Tests for Spatial Correlation Sample 1 a (0.00–0.72Km) Sample 2 b (0.72Km –1.13Km) Sample 3 c (1.13Km –1.88Km) Sample 4 d (1.88Km –41Km) Statistic Value Value Value Value Moran’s I 0.22 0.21 0.20 0.18 ZI 26.43*** 24.81***24.52***21.53*** (0.00)(0.00)(0.00)(0.00) RLMρ 436.83*** 438.42***490.10***365.60*** (0.00)(0.00)(0.00)(0.00) RLMλ 0.041 0.24 0.31 0.49 (0.84)(0.62)(0.58)(0.48) The table above presents the results of spatial correlation tests for all three samples; H0 No Spatial Autocorrelation,ZI follows the standard normal distribution,RLMρand RLMλ follow the χ2 distribution with one degree of freedom Confidence intervals presented as ***99%;p-values in parentheses; a Sample 1 is a subsample of properties selected within the first quartile of the minimum distance to the closest wireless tower (radius ≤0.72Km); b Sample 2 is a subsample of properties within the second quartile of the minimum distance to the closest wireless tower (0.72Km ≤distance ≤1.13Km); c Sample 3 is a subsample of properties withinthe third quartile of the minimum distanceto theclosest wireless tower (1.13Km ≤distance ≤1.88Km); d Sample 4 is a subsample of properties within the fourth quartile of the minimum distance to the closest wireless tower (1.88Km ≤distance ≤41Km) Wireless Towers and Home Values 665 Page 248 of 473 Based on the Moran’s I test results, with 99% confidence for each sample, we reject the null hypothesis that there is no spatial correlation of the residuals. Based on the results of the RLM test for dependent variable spatial correlation, we reject the null hypothesis of no spatial correlation for each subsample with 99% confidence. In contrast, based on the results of the RLM test for residual spatial correlation, we fail to reject the null hypothesis of no spatial correlation across all subsamples. Conse- quently, the spatial autoregressive model is the most appropriate econometric tool to conduct our analysis (Florax and De Graaff 2004). In Tables 4 and 5,wereportthe results of our analysis, comparing the OLS estimates (Table 4) of Eq. (2) to the MLL estimates (Table 5)ofEq.(6)withλ restricted to zero as a natural consequence of the Moran’s I and RLM diagnostic tests discussed above. Although biased, OLS estimates have good explanatory power across all four samples (the coefficient of determination ranges from 60% to 72%). However, com- parison of the lower values of the AIC of the spatial autoregressive models to the corresponding OLS models confirms the hypothesis that the spatial autoregressive models represent the reality with minimum information loss. Therefore, this additional information supports our contention that the spatial autoregressive model is the most appropriate framework for statistical inference in our study. Ingeneral,thespatialautoregressivemodel estimates havegoodstatisticalpowerand the expected coefficient signs across the four subsamples. Curiously, though, we find thatthepricesofpropertiespurchasedin2009aftertheU.S.financialcrisis(comparedto the baseline year 2007) are not statistically significant within 1.88 km from the closest tower(acrossthefirstthreequartilesofthedistancetotheclosestwirelesstower).Onthe other hand, although the coefficients for dwelling age, unemployment rate, and the percentage increase in the African American population per census tract are all statis- tically significant, none seems to be economically significant in Mobile County. As expected, the numbers of bedrooms and bathrooms, as well as income are important predictorsof propertyvalue interms ofeconomicmagnitude.However, asinLocke and Blomquist (2016), it appears that the impact of these variables is relative to property locationwithrespecttothetowers.Forexample,anaveragehouseholdwouldbewilling topay between 7%to 8.5% 10 more than the average price ofa propertyfor an additional bedroom across the four samples while the household’s willingness to pay for an additional bathroom ranges between 21% to 27% more than the average across the four subsamples. Moreover, commensurate with a 10% increase in median income per census tract, the property price increases range from between 18% to 21% for those properties located beyond 1.88 km from the closest tower (across Samples 2–4). However, it seems that the price of properties located within 0.72 km from the closest tower (Sample 1) is only negligibly sensitive to median income changes. Turning our analysis to the impact of the wireless tower on the value of residential properties, our first assessment of the spatial autoregressive model estimate of D for the propertieslocatedwithin0.72kmfromtheclosesttower(Sample1)showsastatistically 10 There is a quadratic relationship between the logarithm of the property price and the number of bedrooms. We evaluate the semi-elasticities at the mean values of the number of bedrooms as reported in Table 2. 666 Affuso et al. Page 249 of 473 Table 4 Ordinary Least Squares Sample 1 a (0.00–0.72Km) Sample 2 b (0.72Km –1.13Km) Sample 3 c (1.13Km –1.88Km) Sample 4 d (1.88Km –41Km) Constant 9.872*** (16.26) 6.362*** (12.2) 6.009*** (15.53) 6.311*** (11.59) Age -0.004*** (−12.86) -0.006*** (−16.64) -0.007*** (−18.07) -0.008*** (−21.77) Bedrooms 0.365*** (7.14) 0.417*** (9.76) 0.074*** (6.15) 0.115*** (9.07) Bedrooms2 -0.043*** (−5.75) -0.041*** (−6.99) -0.002*** (−4.03) -0.003*** (−5.87) Bathrooms 0.329*** (31.83) 0.277*** (30.66) 0.373*** (37.72) 0.278*** (26.44) Onestory (0/1) 0.031* (1.65) 0.06*** (3.34) 0.069*** (3.89) 0.17*** (8.14) Twostories (0/1) 0.058*** (3.28) 0.112*** (6.49) 0.092*** (5.4) 0.191*** (9.50) Car shelter (0/1) 0.179*** (17.32) 0.187*** (17.77) 0.189*** (18.89) 0.239*** (23.03) Fireplace (0/1) 0.203*** (17.87) 0.184*** (15.52) 0.158*** (13.74) 0.179*** (17.01) Fence (0/1) 0.067*** (6.33) 0.019* (1.73) 0.024*** (2.26) 0.036*** (3.23) Deck (0/1) 0.092*** (7.03) 0.065*** (5.02) 0.075*** (5.96) 0.093*** (7.15) Pool (0/1) 0.067 (1.36) -0.004 (−0.08) -0.026 (−0.51) 0.118** (2.20) Brick (0/1) 0.118*** (10.6) 0.098*** (8.48) 0.125*** (11.1) 0.096*** (7.56) Rural (0/1) -0.065*** (−3.07) -0.119*** (−4.93) -0.066** (−2.25) 0.216888 (5.35) ln(distCBD) -0.287*** (−10.06) -0.103*** (−3.44) -0.163*** (−4.67) -0.075 (−1.33) Towers 0.003*** (2.74) 0.003*** (3.63) 0.001 (0.49) -0.002 (−0.75) ln(Income) 0.155*** (5.58) 0.379*** (14.38) 0.478*** (16.27) 0.388*** (8.001) ln(Black) -0.066*** (−6.66) -0.091*** (−9.41) -0.065*** (−6.64) -0.023** (−2.38) Unemployment -0.011*** (−7.44) -0.004*** (−2.68) 0.009*** (5.27) 0.003*** (1.91) Year 2008 0.075*** (3.95) 0.129*** (6.84) 0.111*** (5.8) 0.100*** (5.26) Year 2009 0.009 (0.45) 0.011 (0.54) 0.036 (1.69) 0.019 (0.9) Year 2010 -0.116*** (−5.02) -0.087*** (−3.57) -0.118*** (−5.29) -0.062*** (−3.02) Year 2011 -0.288*** (−12.54) -0.297*** (−13.56) -0.235*** (−10.48) -0.185*** (−8.4) Year 2012 -0.346*** (−15.52) -0.304*** (−13.11) -0.26*** (−11.13) -0.21*** (−9.73) Year 2013 -0.321*** (−14.58) -0.331*** (−14.89) -0.307*** (−13.93) -0.249*** (−11.76) ln(Distance) -1.257*** (−2.95) 0.343 (1.41) 0.055 (0.49) 0.107*** (3.67) D -0.191*** (−4.82) -0.011 (−0.1) 0.005 (0.05) 0.044 (1.200) ln(Distance)∙D 0.51*** (5.41) 0.048 (0.28) 0.009 (0.07) -0.031* (−1.72) V-0.234(−0.67) 0.123 (0.74) -4.314 (−0.54) NA e ln(Distance)∙V 0.829** (1.97) -0.241 (−0.99) 5.59 (0.6) NA e H_tower 0.007 (1.43) 0.001 (0.62) 0.001 (1.62) 0.001*** (3.06) H_tower∙V-0.006(−1.14) 0.001** (2.37) -0.006 (−0.75) NA e Adj. R 2 0.715 0.722 0.714 0.605 Wireless Towers and Home Values 667 Page 250 of 473 significant, negative correlation between property price and sales occurring after tower construction. The same estimate is statistically equally to zero for those properties locatedwithin0.72and1.88kmfromtheclosesttower(Samples2and3).Forproperties that are far from the visibility range of a tower (Sample 4 includes properties located beyond 1.88 km), the correlation between property price and tower becomes positive and statistically different from zero.V, the visibility of the tower, is not statistically significant acrossthefoursamples.However,ln(Distance)·V isstatisticallysignificantat the 5% alpha level for properties that are located within 0.72 km from the closest tower (Sample 1). For these properties, we perform a log-likelihood ratio test for the joint significance of V,ln(Distance)∙V and h_tower∙V, following the χ2 distribution with three degrees of freedom equal to the number of restrictions (three estimates simultaneously equaltozero).Werejectthenullhypothesisthatthesethreeestimatesarejointlyequalto zero (p-value =0.071, 90% confidence). Hence, we must include these parameters to model the relationship between housing price and tower proximity for those properties that are closer to the wireless tower (Sample 1). However, the opposite is true for propertieslocatedbeyond0.72kmaswefailtorejectthenullhypothesiswhenapplying the same test to these properties. In addition, the number of wireless towers per census tract (Towers ) and tower height (h_tower) have no significant impact on housing price across the four samples (statistically and economically). To assess the average social welfare impact of wireless tower proximity on residen- tial property values, we estimate the predicted housing value from sales occurring before and after tower construction using Eq. (3). In Table 6, we report the predicted Table 4 (continued) Sample 1 a (0.00–0.72Km) Sample 2 b (0.72Km –1.13Km) Sample 3 c (1.13Km –1.88Km) Sample 4 d (1.88Km –41Km) AIC 4257 4308 4157 4685 Deg. of Freedom 5773 5774 5774 5773 Sample Size 5828 5827 5827 5827 The table above presents results of the Ordinary Least Square estimates Zipcode parameter estimates are not reported to save space (available upon request). Ten, twelve, twelve and eight Zipcode dummy variables were dropped from the analysis of Samples 1, 2, 3 and 4,respectively, because there were not properties within these zipcode areas Confidence intervals presented as ***99%, **95%, and *90%; t-values in parentheses; a Sample 1 is a subsample of properties selected within the first quartile of the minimum distance to the closest wireless tower (radius ≤0.72Km); b Sample 2 is a subsample of properties within the second quartile of the minimum distance to the closest wireless tower (0.72Km ≤distance ≤1.13Km); c Sample 3 is a subsample of properties withinthe third quartile of the minimum distanceto theclosest wireless tower (1.13Km ≤distance ≤1.88Km); d Sample 4 is a subsample of properties within the fourth quartile of the minimum distance to the closest wireless tower (1.88Km ≤distance ≤41Km); e Visibility variable was dropped from the analysis because there were not visible towers in Sample 4 668 Affuso et al. Page 251 of 473 Table 5 Spatial Autoregressive Models Sample 1 a (0.03Km –0.72Km) Sample 2 b (0.72Km –1.13Km) Sample 3 c (1.13Km –1.88Km) Sample 4 d (1.88Km –41Km) Constant 6.404*** (11.417) 4.315*** (8.984) 4.109*** (11.697) 5.304*** (10.467) Age -0.004*** (−11.15) -0.005*** (−14.236) -0.005*** (−14.209) -0.007*** (−19.002) Bedrooms 0.358 *** (7.728) 0.353*** (9.063) 0.068*** (6.221) 0.104*** (8.902) Bedrooms2 -0.044 *** (−6.522) -0.036*** (−6.755) -0.002*** (−4.066) -0.003*** (−5.887) Bathrooms 0.256*** (26.873) 0.216*** (25.703) 0.279*** (29.698) 0.241*** (24.491) Onestory (0/1) 0.019 (1.111) 0.039** (2.38) 0.042*** (2.591) 0.133*** (6.847) Twostories (0/1) 0.043*** (2.673) 0.077*** (4.884) 0.063*** (4.125) 0.155*** (8.296) Car shelter (0/1) 0.129*** (13.573) 0.136*** (14.052) 0.142*** (15.426) 0.191*** (19.629) Fireplace (0/1) 0.142*** (13.643) 0.134*** (12.346) 0.117*** (11.156) 0.152*** (15.428) Fence (0/1) 0.067*** (6.958) 0.026*** (2.621) 0.04*** (4.164) 0.048*** (4.579) Deck (0/1) 0.08*** (6.74) 0.059*** (5.035) 0.081*** (7.096) 0.084*** (6.965) Pool (0/1) 0.04 (0.898) 0.039 (0.807) 0.003 (0.071) 0.089** (1.786) Brick (0/1) 0.078*** (7.743) 0.076*** (7.249) 0.101*** (9.888) 0.085*** (7.262) Rural (0/1) -0.015 (−0.791) -0.064*** (−2.908) -0.042 (−1.598) 0.153*** (4.063) ln(distCBD) -0.218*** (−8.416) -0.089*** (−3.274) -0.108*** (−3.421) -0.084 (−1.612) Towers 0.002*** (2.666) 0.002** (2.157) 0.001 (0.313) -0.001 (−0.583) ln(Income) 0.09*** (3.557) 0.207*** (8.428) 0.274*** (10.083) 0.179*** (3.908) ln(Black) -0.04*** (−4.359) -0.059*** (−6.655) -0.041*** (−4.66) -0.02** (−2.165) Unemployment -0.007*** (−5.249) -0.003** (−2.204) 0.006*** (3.715) 0.001 (0.779) Year 2008 0.078*** (4.552) 0.128*** (7.504) 0.114*** (6.589) 0.108*** (6.124) Year 2009 0.015 (0.843) 0.007 (0.374) 0.031 (1.615) 0.024** (1.209) Year 2010 -0.117*** (−5.581) -0.095*** (−4.276) -0.12*** (−5.934) -0.071*** (−3.714) Year 2011 -0.300*** (−14.474) -0.304*** (−15.253) -0.236*** (−11.639) -0.189*** (−9.255) Year 2012 -0.340*** (−16.871) -0.306*** (−14.514) -0.296*** (−13.986) -0.228*** (−11.364) Year 2013 -0.328*** (−16.461) -0.331*** (−16.388) -0.322*** (−16.132) -0.257*** (−13.074) ln(Distance) -1.167*** (−3.025) 0.274 (1.232) 0.059 (0.593) 0.09*** (3.318) D-0.12***(−3.35) -0.007 (−0.066) 0.003 (0.031) 0.06* (1.773) ln(Distance)∙D 0.332*** (3.886) 0.043 (0.27) 0.007 (0.062) -0.039** (−2.298) V-0.453(−1.432) 0.118 (0.782) -2.747 (−0.377) NA e ln(Distance)∙V 0.872** (2.291) -0.193 (−0.869) 3.533 (0.421) NA e H_tower 0.001 (0.151) 0.001 (0.436) 0.001 (1.414) 0.001* (1.934) H_tower∙V 0.001 (0.02) 0.001 (1.394) -0.003 (−0.451) NA e ρ 0.362*** (31.59) 0.349*** (30.53) 0.352*** (32.61) 0.310*** (26.89) Wireless Towers and Home Values 669 Page 252 of 473 sales value and t-test results of the sale price means for home sales occurring before and after tower construction. For properties located within a 0.72-km radius of a wireless tower that are sold after tower construction (Sample 1), it appears there is indeed a tower-related negative price effect. We estimate the social cost tower impact as approximately $4132 (p-value =0.014), which corresponds to a 2.65% decrease in property value. As expected, tower impacts are negligible for the stratum of housing units located beyond 0.72 km. Along the same line, we compute the impact of tower visibility for properties sold after tower construction as E(exp(Xβ|D =1;V =1))-E(exp(Xβ|D =1;V = 0)). Our calculations, summarized in Table 7, indicate a tower visible to properties within 0.72 km would effectively depreciate property values an average of 9.78%, equating to an average monetary loss of $17,037 (p-value =0.00). The impact of tower visibility would be statistically equal to zero for those properties beyond the 0.72 km band. In addition, we use Eq. (4) to gauge the overall social welfare resulting from wireless towers. Com- puting the sum of the difference between the predicted housing price before and after tower construction across the sample, we find a staggering aggregate value loss of $24.0811 million dollars. 11 This figure was calculated using equation (4). Let by1 be a column vector (5828 × 1) of predicted housing prices obtained by evaluating exp(Xβ) at the average values of all of the price predictors with D = 1 (sold after tower construction) and yb0 the predicted housing prices counterpart with D = 0 (sold before tower construc- tion). We define the change in welfare of each household i within Sample 1, as the element-by-element subtraction ΔWi =yb1i -yb0i . Finally, the aggregate welfare impact was obtained by taking the sum of the elements of the column vector ΔW, i.e.,∑5;828 i¼1 ΔW i ¼−24;081;385. Table 5 (continued) Sample 1 a (0.03Km –0.72Km) Sample 2 b (0.72Km –1.13Km) Sample 3 c (1.13Km –1.88Km) Sample 4 d (1.88Km –41Km) σ 0.314*** (33.137) 0.317*** (32.781) 0.311*** (33.286) 0.334*** (31.215) AIC 3347 3457 3243 4022 Deg. of Freedom 5571 5572 5572 5571 Sample Size 5828 5827 5827 5827 The table above presents results of the maximum log-likelihood estimations of the spatial autoregressive models Zipcode parameter estimates are not reported to save space (available upon request). Ten, twelve, twelve and eight Zipcode dummy variables were dropped from the analysis of Samples 1, 2, 3 and 4,respectively, because there were not properties within these zipcode areas Confidence intervals presented as ***99%, **95%, and *90%; z-values in parentheses; a Sample 1 is a subsample of properties selected within the first quartile of the minimum distance to the closest wireless tower (radius ≤0.72Km); b Sample 2 is a subsample of properties within the second quartile of the minimum distance to the closest wireless tower (0.72Km ≤distance ≤1.13Km); c Sample 3 is a subsample of properties withinthe third quartile of the minimum distanceto theclosest wireless tower (1.13Km ≤distance ≤1.88Km); d Sample 4 is a subsample of properties within the fourth quartile of the minimum distance to the closest wireless tower (1.88Km ≤distance ≤41Km); e Visibility variable was dropped from the analysis because there were not visible towers in Sample 4 670 Affuso et al. Page 253 of 473 Because we find no evidence that towers impact prices of properties located beyond 0.72 km of a tower, we focus our analysis on the price sensitivity of homebuyers of properties located within 0.72 km of a tower. Earlier, we mention one of the main strengths of a spatial econometric analysis is it enables disentanglement of the direct and indirect effects of tower proximity on property values. This is because of a spatially correlated dependent variable—that the change in price of house i with respect to the distance to the closest tower of the neighbor’shousej within the same sample is not zero (i.e.∂ln(Price)i/∂ln(Distance)j ≠0withi ≠j). LeSage and Pace (2009) derive: Average Direct Impact ¼n−1 tr I −ρWðÞ−1 I βk hi Average Indirect Impact ¼n−1 10 n I −ρWðÞ−1 I βk hi 1n −tr I −ρWðÞ−1 I β k hino Average Total Impact ¼n−1 10 n I −ρWðÞ−1 I βk hi 1n 8 >>>< >>>: 9 >>>= >>>; ð11Þ for each predictor βk with k = 1,2,..K. Therefore, we use Eq. (11) to decompose and calculate the average total impact of the wireless tower on property values within Sample 1 as reported in Table 8. Table 6 Social Welfare Analysis of Wireless Tower Impact on Home Values Expected Value Before Tower After Tower Impact a Sample 1 b 155,911 151,779 -4132** (91,553)(89,964)(1681) Sample 2 c 161,865 164,068 2204 (131,195)(133,607)(2453) Sample 3 d 162,249 163,485 1236 (113,627)(114,428)(2113) Sample 4 e 159,752 161,770 2107 (101,244)(103,532)(1897) The table above presents the social welfare analysis of wireless tower impacts on home values After tower = exp.(Xβ)|D = 1,Before tower = exp.(Xβ)|D = 0,Impact = exp.(Xβ|D = 1) - exp.(Xβ|D = 0) **95% confidence interval; standard deviation in parentheses; a standard error t-test in parentheses; t-test H0:E[exp(Xβ|D = 1)] = E[exp(Xβ|D = 0)]; b Sample 1 is a subsample of properties selected within the first quartile of the minimum distance to the closest wireless tower (radius ≤0.72Km –sample size =5828); c Sample 2 is a subsample of properties within the second quartile of the minimum distance to the closest wireless tower (0.72Km ≤distance ≤1.13Km –sample size =5827); d Sample 3 is a subsample of properties within the third quartile of the minimum distance to the closest wireless tower (1.13Km ≤distance ≤1.88Km –sample size =5827); e Sample 4 is a subsample of properties within the fourth quartile of the minimum distance to the closest wireless tower (1.88Km ≤distance ≤41Km –sample size =5827) Wireless Towers and Home Values 671 Page 254 of 473 We then use Eq. (5) to assess the price sensitivity of buyers with respect to the distance to the closest visible and non-visible towers after their construction. It appears that if the tower is not visible, the property price decreases 8.7% for every 10% increase in distance to the closest tower. The spillover effect on property price due to the depreciation of the neighbor’sproperty—the average indirect effect—is 4.41% of price decrease for every 10% increase in the distance to the closest tower. The total Table 7 Social Welfare Analysis of Wireless Tower Visibility on Home Values Expected Value Non-visible Tower Visible Tower Impact a Sample 1 b 174,194 157,157 -17,037*** (104,007)(92,447)(1823) Sample 2 c 161,120 164,370 3251 (132,276)(133,740)(2464) Sample 3 d 163,113 163,335 222 (114,055)(114,297)(2115) Sample 4 e 157,454 NAf NAf (99,875)(NA)f (NA)f The table above presents the social welfare analysis of the visibility impact of wireless tower on home values (after tower construction —D =1) Visible tower = exp.(Xβ|D=1;V=1),Non-visible tower = exp.(Xβ |D = 1;V = 0), Im- pact = exp.(Xβ|D = 1;V = 1) - exp.(Xβ|D=1;V=0); Confidence intervals presented as ***99%; standard deviation in parentheses; a standard error t-test in parentheses; t-test H0:E[exp(Xβ|D = 1;V = 1)] = E[exp(Xβ|D=1;V=0)]; b Sample 1 is a subsample of properties selected within the first quartile of the minimum distance to the closest wireless tower (radius ≤0.72Km –sample size =5828); c Sample 2 is a subsample of properties within the second quartile of the minimum distance to the closest wireless tower (0.72Km ≤distance ≤1.13Km –sample size =5827); d Sample 3 is a subsample of properties within the third quartile of the minimum distance to the closest wireless tower (1.13Km ≤distance ≤1.88Km –sample size =5827); e Sample 4 is a subsample of properties within the fourth quartile of the minimum distance to the closest wireless tower (1.88Km ≤distance ≤41Km –sample size =5827); f Visibility variable was dropped from the analysis because there were not visible towers in Sample 4 Table 8 Decomposition of the Price Sensitivity of Home Buyers to Tower Proximity Average Direct Impact Average Indirect Impact Average Total Impact ln(Distance) -1.213 -0.616 -1.828 ln(Distance)∙D 0.345 0.175 0.520 ln(Distance)∙V 0.906 0.460 1.367 The table above presents the results of the sensitivity analysis designed to compare the price sensitivity of buyers of properties from which the closest tower is not visible Average Direct Impact =∂ln(Price)i/∂ln(Distance)i,Average Indirect Impact =∂ln(Price)i/∂ln(Distance)j with i ≠j,Average Total Impact = Average Direct Impact + Average Indirect Impact 672 Affuso et al. Page 255 of 473 depreciation is 13% for 10% increase in the distance. Therefore, it may well be that non-visible towers are a potential external benefit for properties located within 0.72 km of a tower. Although we cannot affirmatively explain this finding, our sense is it may be due to enhanced wireless coverage resulting in a stronger wireless signal. It is noteworthy that only 69 of 5828 properties within 0.72 km of the closest tower are outside of the visibility range of a tower. In contrast, however, the 5759 homebuyers purchasing properties within 0.72 km of the closest tower that are within visible range of a tower are not particularly sensitive, on average, to the distance to the visible tower, despite their perceptions of a visible tower as a negative externality. In fact, housing prices appreciate approximately 0.4% for each 10% increase in the distance to the closest visible tower. The average indirect impact of towers on those buyers (price spillover due to neighbor’s price movement) is approximately 0.2%. This is to say that buyers of properties located an average of 0.497 km (average minimum distance in Sample 1) to the closest tower are willing to pay a premium of approximately 0.6% of the average housing price for every 10% increase in the average distance from a tower (average total impact). Monetarily, this translates into a value of approximately $962 per 50 linear meters 12 of increase in distance from the closest tower. One limitation of our study is that we cannot control for potential endogeneity associated with the sale date dummy variable (D). Even though homeowners could choose to buy or not to buy a property after tower construction, we have no information as to their motivations for buying. Ideally, a difference-in-differences study restricted to repeat sales of the same property occurring pre- and post-tower construction could potentially mitigate this source of bias. Unfortunately, within the entire sample of 23,309 housing sales there are only 42 repeat sales. A difference-in-differences ap- proach based on a sample of 42 observations would clearly suffer from a micronumerosity problem with negative degrees of freedom (the number of parameters would exceed the sample size), and would, therefore, lack empirical viability. Notwithstanding the slight potential for bias, our results are clear: consumers perceive visible wireless towers as economic externalities. Aggregate social costs are highly significant relative to those properties within a 0.72 Km radius of a tower. Additionally, we must also point out that our study does not assess intangible social benefits of wireless towers, such as high-speed internet access, emergency communi- cations, and digital forensics enabling national security related wireless communication monitoring, all of which provide invaluable services to consumers, businesses, and institutions. Conclusion Truly, we currently live in the Age of Information. According to the International Communication Union of the United Nations, the number of wireless phone subscrip- tions totaled over 7 billion worldwide in 2015, with wireless coverage extending to 95% of the world’s population (United Nations, International Communication Union 2015). U.S. wireless usage is no less astounding, as evidenced by the 1045% increase in 12 We calculate a 10% increase in the average minimum distance for houses in Sample 1 as 0.49 km ∙0.1 ≈50 m. A 0.59% increase in the average housing price of Sample 1 is $163,008.8 ∙0.0059 ≈$ 961.80. Wireless Towers and Home Values 673 Page 256 of 473 wirelessdevise demandoverthe last20years(CTIA 2015).Thefuturelookspromisingas well, with expectations that U.S. wireless industry employment will increase more than 31% from 2012 to 2017 (Pearce et al.2013). Yet, even with the wireless industry poised for continued growth, it is unlikely it will be without consequences. Certainly, there are private benefits associated with the use of wireless service, yet there are costs as well. In this study, we examine one such cost: the impact of wireless towers on home values. Although previous researchers have examined this issue, our study differs in two aspects. First, we address the econometric problem of spatial dependence that typically flaws hedonic price estimation analysis. We contend our empirical analyses are more efficient than those used in other studies, and as result, our results reveal greater consistency and reliability. Second, rather than rely solely on neighborhood-based property sales data, we test our hypothesis using recent property sales and current wireless tower locational data for an entire metropolitan statistical area, 13 which also happens to be one of the busiest port cities in the United States. 14 The results of a series of spatial statistical tests developed by Anselin et al. (1996) suggest that a spatial autoregressive model is the most appropriate econometric ap- proach to test our research hypothesis. We conduct a marginal sensitivity analysis for homes within different radii of distances to the closest visible and non-visible wireless towers, basing the distance bands on quartiles of the distance to the wireless tower. Our results reveal wireless tower capitalization only in the value of those properties that are within approximately 0.72 km of a tower. On average, the potential external cost of a wireless tower is approximately $4132 per resi- dential property, which corresponds to a negative price effect of 2.65%. The negative price impact of 9.78% is much more severe for properties within visible range of a tower compared to those not within visible range of a tower. This negative impact vanishes as radii distances exceed 0.72 km. In aggregate, the social welfare cost for the properties in our sample located within 0.72 km amounts to an approximate loss of $24.08 million dollars of value. U.S. federal law prohibits wireless siting denial if no alternative site is available (FCC 1996;Martin1997). However, given the apparent social costs associated with negative price effects, local zoning and regulatory authorities should consider granting approvals that include impact-minimizing conditions. For example, wireless tower construction approvals could require development and maintenance of visual or veg- etative buffer screening. Concurrently or alternatively, approvals could mandate camouflaging towers to look like trees or flagpoles. Other types of approval conditions could dictate attachment of communication antennae systems to existing structures such as buildings, street light poles, electric utility poles, water towers, billboards, or even sports stadium super-structures. Clearly, society is dependent on wireless communi- cation, and obfuscating efforts to expand or improve coverage makes little sense. Argu- ably,however,authoritiesoverseeingtheprocesshavedefinitiveobligations,perhapseven fiduciary ones, to safeguard the interests and well-being of those whom they serve. 13 The U.S. Census Bureau list of metropolitan statistical areas ranks Mobile County, Alabama at number 127. Data available at http://factfinder.census.gov/faces/tableservices/jsf/pages/productview.xhtml?src=bkmk. 14 The Port of Mobile is home to the twelfth busiest port in the U.S., and ninth busiest port along the Gulf Coast, ranked by cargo tonnage handled as reported by the U.S. Department of Transportation, available at http://www. rita.dot.gov/bts/sites/rita.dot.gov.bts/files/publications/national_transportation_statistics/html/table_01_57.html. 674 Affuso et al. Page 257 of 473 References Airwave Management, LLC (2013). Cell tower lease rates exposed.http://www.cell-tower-leases.com/Cell- Tower-Lease-Rates.html. Accessed 6 March 2016. Anselin, L. (1988).Spatial econometrics: methods and models. Dordrecht: Kluwer Academic Publisher. Anselin, L., Bera, A. K., Florax, R., & Yoon, M. J. (1996). Simple diagnostic tests for spatial dependence. Regional Science and Urban Economics, 26(1), 77–104. Bond,S. (2007a). 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Page 259 of 473 The Empirical Economics Letters, 18(8): (August 2019) ISSN 1681 8997 The Disamenity Value of Cellular Phone Towers on Home Prices in Savannah, Georgia Joseph Hale* and Jason Beck** Georgia Southern University, 11935 Abercorn Street Savannah, Georgia, 31419, USA Abstract: This paper examines the disamenities effect on home values from proximity to cellular phone towers. Previous works have drawn inconsistent conclusions and this study provides an additional data point. A hedonic pricing model is used with transaction data from Savannah, Georgia from 2007 to 2016. Results suggest proximity to cell phone towers can reduce selling price up to 7.6%. This result is consistent with the high end of results found by other stud ies. We also examine the effect of cell tower proximity in rising versus falling markets and find that the negative effect is larger when housing prices are declining. Keywords: Real Estate Brokers, Brokers, Brokerage, Housing JEL Classification Numbers: R23, R31, Q51 I. Introduction Homes can be considered a bundle of characteristics. Some characteristics, such as more bathrooms, more square footage, and being in a good location, are desirable and can be expected to contribute to a higher sales price, ceteris parib us. Undesirable characteristics, then, may be associated with a negative effect on a home’s value. Economists have examined the impacts of disamenities such as airport noise (Mieszkowski and Saper, 1978), toxic waste sites (Kohlhase, 1991), Superfund sites (Kiel and Williamson, 2007), wind turbines (Heintzelman and Tuttle, 2012), high voltage lines (Hamilton and Schwann, 1995) and others. This paper seeks to extend the literature on the effect of disamenities, specifically the home’s proximity to a cellular phone tower, with a new data set. The growth of cellular communication has been accompanied by an increase in the number of cellular communication antennas. While the owner of the land on which the antenna is installed receives a source of income, these towers may generate negative externalities for the nearby residents. One possible externality could come from a (real or perceived) effect on nearby resident health and well being. Some residents have complained that long-term exposure to electromagnetic fields near cellular towers has caused headaches, sleep disturbances, and other health effects (Fillipova and Rehm, 2014, Wyman and Morthope, 2018, Locke and Bloomquist, 201 6, Heintzelman and Tuttle, 2012). While medical studies, such as the report by the National Cancer Institute (2019) * Email: jh27523@georgiasouthern.edu; ** Contact author. Email:jbeck@georgiasouthern.edu Page 260 of 473 The Empirical Economics Letters, 18(8): (August 2019) 872 have offered only weak evidence that long-term health issues are correlated with the extremely low frequency electromagnetic fields that are emitted by cell towers, the perception of these effects could still have an impact on home prices in the adjacent areas. Beyond potential adverse health effects, towers are often highly visible and possibly unpleasant. If an attractive view can increase the value of a home, an unattractive view may have a negative effect. A number of papers have attempted to estimate the impact of cell phone tower proximity on home values, but existing studies fail to reach a consistent conclusion. Work by Filippova and Rehm (2011 and 2014) used transaction data from New Zealand and found little to no negative impact of cell tower proximity on home values. Rajapaksa et al. (2017) used data from Brisbane, Australia, and found a small negative effect. Using data from central Kentucky (USA), Locke and Bloomquist (2016) find a relatively large effect that ranges from 2 to 7.5% across different model specifications. Given the wide ranging and inconsistent conclusions of existing research, another data point may be useful. This paper combines housing transaction data from the Multiple Listing Service of Savannah, Georgia, USA, with GIS maps to provide another set of estimates for the housing price effect of proximity to cell phone towers. We also explore the possibility that the effect differs in upward vs. downward trending markets. 2. Framework for Empirical Analysis Sirmans, Macpherson and Zeitz (2005), Murdoch, Singh, and Thayer (1993), and many others provide a thorough overview of the underlying theory of the hedonic pricing model and thus it is not reviewed in great detail here. The premise is that a house is a bundle of characteristics, both desirable and undesirable, evaluated by utility-maximizing consumers. The sales price of the home represents the capitalization of these features. Observable attributes such as interior and exterior features, locational factors, idiosyncratic characteristics associated with the house, and sales timing can be estimated via the hedonic pricing model. We estimate the hedonic model with a ten-year period of data from January 2007 through December 2016from the Savannah Board of Realtors' Multiple Listing Service (MLS).Observations were restricted to existing homes that sold for between $50,000 and $1 million, and had no missing values. This resulted in a data set comprised of 34,335 usable observations. The average house in the sample was a single family dwelling (i.e. not a townhouse/condominium) with 1940 square feet, had two bathrooms, a fireplace, a two car garage, and sold in 2016. The MLS data are rich enough to allow for the inclusion of a number of observable house characteristics. Table 1 lists, defines, and provides summary statistics for these variables. Page 261 of 473 The Empirical Economics Letters, 18(8): (August 2019) 873 Table 1: Summary Statistics and Variable Descriptions Variable Description Mean Std. Dev. Price Sales price of home 214696.8 138951.6 condo =1 if condo 0.134 0.340 one_bedroom =1 if 1 bedroom 0.018 0.131 two_bedroom =1 if 2 bedrooms 0.105 0.306 three_bedroom =1 if 3 bedrooms 0.587 0.492 four_bedroom =1 if 4 bedrooms 0.243 0.428 five_bedroom =1 if 5 bedrooms 0.043 0.202 sixplus_bedroom =1 if 6+ bedrooms 0.005 0.072 one_fullbath =1 if 1 full bath 0.112 0.315 two_fullbath =1 if 2 full baths 0.699 0.458 three_fullbath =1 if 3 full baths 0.156 0.363 four_fullbath =1 if 4 fullbaths 0.027 0.163 fiveplus_fullbath =1 if 5+ fullbaths 0.006 0.076 one_halfbath =1 if 1 half bath 0.296 0.456 two_halfbath =1 if 2 half baths 0.011 0.104 three_halfbath =1 if three half baths 0.0004 0.020 fourplus_halfbath =1 if 4+ half baths 0.0008 0.009 fireplace =1 if has fireplace 0.618 0.485 one_garage =1 if 1 garage space 0.131 0.336 two_garage =1 if 2 garage spaces 0.485 0.499 threeplus_garage =1 if 3 garage spaces 0.039 0.192 y2008 =1 if sold in 2008 0.079 0.270 y2009 =1 if sold in 2009 0.076 0.265 y2010 =1 if sold in 2010 0.076 0.264 y2011 =1 if sold in 2011 0.087 0.281 y2012 =1 if sold in 2012 0.094 0.292 y2013 =1 if sold in 2013 0.106 0.308 y2014 =1 if sold in 2014 0.111 0.314 y2015 =1 if sold in 2015 0.130 0.336 y2016 =1 if sold in 2016 0.141 0.347 six_ten_years =1 if 6-10 years old 0.194 0.395 eleven_twentyfive_years =1 if 11-25 years old 0.275 0.446 twentysix_fifty_years =1 if 26-50 years old 0.191 0.392 fiftyoneyears_hundred_years =1 if 51-100 years old 0.151 0.358 hundredplus_years =1 if over 100 years old 0.036 0.185 sqft2 =1 if sqft>=1308 &<1574 0.200 0.399 sqft3 =1 if sqft >=1574 &<1919 0.200 0.399 sqft4 =1 if sqft>=1919 &<2515 0.200 0.400 sqft5 =1 if sqft>=2515 0.200 0.399 Page 262 of 473 The Empirical Economics Letters, 18(8): (August 2019) 874 Table 1 continued swimpool =1 if has swimming pool 0.052 0.222 cell0-500 =1 if cell tower 0-500 ft 0.091 0.288 cell501-1000 =1 if cell tower 501-1000 ft 0.229 0.419 cell1001-1500 =1 if cell tower 1001-1500 ft 0.191 0.393 cell1501-2000 =1 if cell tower 1501-2000 ft 0.123 0.328 cell2001-2500 =1 if cell tower 2001-2500 ft 0.055 0.227 cell2501-3000 =1 if cell tower 2501-3000 ft 0.032 0.175 cell3001-3500 =1 if cell tower 3001-3500 ft 0.006 0.076 cell3501-4000 =1 if cell tower 3501-4000 ft 0.009 0.092 cell4001-4500 =1 if cell tower 4001-4500 ft 0.010 0.1 n=34,335 To allow for non-linearity, we operationalize all independent variables as dummy variables similar to Levitt and Syverson (2008) and Beck, Bray, and Trapani (2018). The dependant variable is the natural log of sales price. Note that location of the home is control for via 6-digit zip code fixed effects. These were created by truncating available 9 - digit codes for each observation. This resulted in 167 different locational fixed effects. We used the geo-locational information on each home provided in the MLS in combination with GIS software to calculate the distance of each home to the nearest cell tower at the time of sale. Since information on the date of tower construction was available to us, we were able to measure the distance to the nearest tower at the time of each observation’s sale. Following Locke and Blomquist (2016), distance to nearest tower was controlled for via a series of dummy variables representing 500 feet bands up to 4500 feet. Homes without a tower within 4500 feet are used as the reference group. 3. Empirical Results The estimated coefficients mostly exhibit the expected signs with most reaching high levels of statistical significance. Larger homes and homes with desirable amenities, such as more full and half bathrooms, a fireplace, swimming pool, etc, sell for more. Since newer homes probably better match current buyer preferences and are less likely to need repair, it is unsurprising that older homes sell for less. The exception to this is homes that are one hundred years old or more, which sell for a premium. This is likely due to such homes being located in Savannah’s well known and desirable historic district (see Cebula (2009) for a discussion of real estate in this area). The impact of the rise and fall of the national housing market can be seen in the results. Housing prices in the sample decreased through 2011 before rebounding and approaching their 2007 levels by 2016. 167 six -digit zip code locational controls were included in the model but not reported in Table 2 . They were largely significant, suggesting the importance of house location. Page 263 of 473 The Empirical Economics Letters, 18(8): (August 2019) 875 Table 2: OLS Results with Robust Standard Errors ((Dep Var: ln(price)) Variable Coef. Robust Std. Err. Variable Coef. Robust Std. Err. condo -0.075*** 0.006 y2014 -0.177*** 0.006 onebedroom threebedroom -0.163*** -0.024*** 0.017 0.007 y2015 -0.109*** 0.006 fourbedroom -0.055*** 0.008 y2016 -0.065*** 0.006 fivebedroom -0.089*** 0.012 six_tenyears -0.018*** 0.004 sixplusbedroom -0.138*** 0.032 eleven_twentyfiveyears -0.043*** 0.004 twofullbath 0.186*** 0.007 twentysix_fiftyyears -0.108*** 0.006 threefullbath 0.329*** 0.009 fiftyoneyears_hundredyears -0.061*** 0.010 fourfullbath 0.505*** 0.013 hundredplusyears 0.034* 0.018 fiveplusfullbath 0.630*** 0.027 sqft2 0.157*** 0.005 onehalfbath 0.091*** 0.003 sqft3 0.285*** 0.006 twohalfbath 0.163*** 0.018 sqft4 0.454*** 0.007 threehalfbath 0.289 0.115 sqft5 0.671*** 0.008 fourplushalfbath 0.232*** 0.051 swimpool 0.096*** 0.007 fireplace 0.103*** 0.003 cell0_500 -0.076*** 0.014 onegarage 0.637*** 0.005 cell501_1000 -0.072*** 0.013 twogarage 0.159*** 0.005 cell1001_1500 -0.045*** 0.013 threeplusgarage 0.318*** 0.009 cell1501_2000 -0.003 0.013 y2008 -0.054*** 0.006 cell2001_2500 0.003 0.013 y2009 -0.148*** 0.006 cell2501_3000 0.008 0.013 y2010 -0.214*** 0.007 cell3001_3500 -0.003 0.020 y2011 -0.304*** 0.007 cell3501_4000 -0.004 0.014 y2012 -0.291*** 0.006 cell4001_4500 0.020 0.11 y2013 -0.227*** 0.006 Constant 11.464*** 0.048 Note: n= 34,335; F-Statistic = 558.59; Prob F: = 0.00; R2 = 0.7721. 167 6-digit zip code controls present but not reported Our variables of interest in this model are the one s associated with proximity to cell phone towers. Following the methodology of Locke and Blomquist (2016), we created dummy variables each representing the observation being located within a 500 feet band, up to 4500 feet. Results show a rough taper, with homes closer to cell towers selling at a (generally) larger discounts. This result peeks at 7.6% with homes closest to a tower (within 500 feet) but is still negative and statistically noticeable up to 1500 feet. These results suggest the negative effect disappears beyond 1500 feet. Our results are quite Page 264 of 473 The Empirical Economics Letters, 18(8): (August 2019) 876 similar to those of Locke and Blomquist (2016) through the first three 500 feet bands1. A notable difference between our results and those of Locke a nd Blomquist is that we see the effect disappear by 1500 feet, while they observe it fading, but sti ll present, through 4500 feet. It may be advisable to view the presented results as upper bounds on the disamenities effect in that endogeniety may be a factor. It is possible that cell towers may locate, when possible, to areas where land prices are low and avo id specific areas where land values are high. If this is true, the causal impact of a tower may be lower than the reported regression coefficient. From 2007 through 2011, home prices were falling in the Savannah area. They began rising again in 2012 and continued this trend through the remainder of the sample period. For this reason, 2007-2011 are henceforth considered downward trending years while 2012-2016 are considered upward trending years. We now explore the possibility that disamenities have heterogeneous effects in upward vs. downward trending years. Table 3: Upward vs. Downward Trending Market Comparison Downward Trending Years, 2007-2011 Upward Trending Years, 2012-2016 Coef Std.Error Coef Std.Error cell0-500 -0.088*** 0.024 -0.070*** 0.019 cell501-1000 -0.088*** 0.022 -0.064*** 0.017 cell1001-1500 -0.058*** 0.022 -0.039** 0.017 cell1501-2000 -0.123 0.022 0.004 0.017 cell2001-2500 0.014 0.022 0.001 0.018 cell2501-3000 -0.006 0.022 0.015 0.018 cell3001-3500 -0.014 0.033 -0.043* 0.025 cell3501-4000 -0.028 0.023 0.018 0.018 cell4001-4500 0.028* 0.017 0.014 0.015 n=14,313 n=20,002 Results in Table 3 show that the disamenity effect of cell tower proximity is larger for homes during downward trending years. The estimated effect tops out at 8.8% for homes within 500 feet of a tower for the period 2007-2011, and 7% for homes in the 2012-2016 period. 1 We find the effects to be 7.6%, 7.2% and 4.5%, while their results find the effects to be 7.5%, 6.1%, and 6.3%, for the 0-500ft, 500-1000ft, and 1000-1500ft bands, respectively. Page 265 of 473 The Empirical Economics Letters, 18(8): (August 2019) 877 4. Conclusion Existing studies on the effect of a nearby cell tower on home sales prices have produced a wide range of inconsistent results. Some work finds a large effect, some work finds a small effect, and some work finds no noticeable effect. This paper uses a new data set, ten years of MLS data from Savannah, GA, to add another data point regarding the impact of cell phone towers on nearby home values. We find that homes close to towers sell for a discount of up to 7.6% and that any noticeable effect disappears at 1500 feet. Our results are consistent with the high end of results from other work s. Since we cannot rule out the possibility that towers are endogenously located in areas with low land values, it may be best to view these results as an upper bound. T he temporal effects of cell towers were also examined and it was found that the discount associated with proximity to a tower is smaller during times of upward trending home prices versus times when home prices are falling. References Beck, J., S. Bray, and A. Trapani, 2018, Using Agent Remarks to Explore the Principal- Agent Relationship in Residential Real Estate Brokerage, The Empirical Economics Letters, 17, 1-15. Cebula, R.J., 2009, The Hedonic Pricing Model Applied to the Housing Market of the City of Savannah and Its Savannah Historic Landmark District, The Review of Regional Studies, 39, 9-22. Filippova, O. and M. Rehm, 2014, Cell phone towers and house prices in New Zealand: economic effects and policy implications, International Journal of Housing Markets and Analysis, 7, 18-29. Filippova, O. and M. Rehm, 2011, The impact of proximity to cell phone towers on residential property values, International Journal of Housing Markets and Analysis, 4, 244-267. 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Page 267 of 473 Impact of proximity to cell phone tower base stations on residential property prices in the City of Johannesburg, South Africa Koech Cheruiyot,Nosipho Mavundla,Mncedisi Siteleki and Ezekiel Lengaram School of Construction Economics and Management, University of the Witwatersrand, Johannesburg, South Africa Abstract Purpose –With revolutions in the telecommunication sector having led to wide unprecedented consequences in allfacets of human life, this paper aims to examine the relationship between cell phone tower basestations(CPTBSs)andresidentialpropertypriceswithintheCityofJohannesburg(CoJ),SouthAfrica. Design/methodology/approach –The authors align their work with global literature and assess how the impact of CPTBSs influences residential property values in South Africa. The authors use a semi-log hedonic pricing model to test the hypothesis that proximity of CPTBSs to residential properties does not accountforanyvariationinresidentialpropertyprices. Findings –The results show a significant impact that proximity of CPTBS has on residential property sale prices. However, the impact of CTPBSs’proximity on residential property prices depends on their distance from the residential properties. The closer a residential property is to the CTPBS, the greater the impact that theCTPBSwill haveonthesellingpriceoftheresidentialproperty. Originality/value –With international studies offering mixed findings on the impact of CPTBSs on residential property values, there is limited research on their impact in South Africa. The findings of this study offer crucial insights for the real estate practitioners, property owners, telecommunications companies and the public, providing a nuanced understanding of the relationship between CPTBSs and property values. This research helps property owners understand the effects of CPTBSs on their properties, and it assists propertyvaluersingaugingtheimpactofCPTBSsonpropertyvalues. Keywords South Africa, Impact, Proximity, City of Johannesburg, Cell phone tower base station, Residential property prices Paper type Research paper 1. Introduction The surge in cell phone demand has triggered an unprecedented rise in network connectivity, thus leading to a growth of cell phone tower base stations (CPTBSs) globally (Locke and Blomquist, 2016). These CPTBSs, facilitating wireless communication for mobile devices, are integral to the © Koech Cheruiyot, Nosipho Mavundla, Mncedisi Siteleki and Ezekiel Lengaram. Published by Emerald Publishing Limited. This article is published under the Creative Commons Attribution (CC BY 4.0) licence. Anyone may reproduce, distribute, translate and create derivative works of this article (for both commercial and non-commercial purposes), subject to full attribution to the original publication and authors. The full terms of this licence may be seen at http://creativecommons.org/licences/by/4.0/legalcode This paper forms part of a special section “Spatial analysis and housing markets”, guest edited by Koech Cheruiyot. IJHMA 17,6 1422 Received3December2023 Revised7March2024 Accepted18March2024 International Journal of Housing Markets and Analysis Vol. 17 No. 6, 2024 pp. 1422-1442 EmeraldPublishingLimited 1753-8270 DOI 10.1108/IJHMA-12-2023-0167 The current issue and full text archive of this journal is available on Emerald Insight at: https://www.emerald.com/insight/1753-8270.htm Downloaded from http://www.emerald.com/ijhma/article-pdf/17/6/1422/9471207/ijhma-12-2023-0167.pdf by guest on 30 March 2026 Page 268 of 473 transmission of information through ultra-frequency radio waves (Bond and Wang, 2005). In South Africa, the implementation of the 1996 Telecommunication Act marked a significant shift that opened opportunities for new mobile network operators (MNOs) to enter the South African market (Makhaya and Roberts, 2003). This influx of MNOs sparked the expansion of CPTBS infrastructure across the country (GSMA, 2014). This expansion of CPTBS infrastructure has raised questions regarding its impacton residentialproperty prices and densities, particularly in South Africa. Surprisingly, despite the critical role of CPTBSs in communication, there is limited literature exploring this dynamic in South Africa. Internationally, studies have analyzed the effect of CPTBSs on residential property prices, revealing divergent outcomes. For instance,Bond (2007a,2007b) found a 15% decrease in property prices within a 300-m radius of CPTBSs in New Zealand, contrasting with Smaqae and Anwar (2022)discovery of a positive impact on property prices in Erbil, Iraq. In the USA, studies by Affuso et al.(2018)and Bond and Squires (2007)reported property value decreaseswithin certain proximitiesto CPTBSs, while Olukolajo etal.(2013)inNigeria observed variedimpactsacrossdifferent neighborhooddensities. The scarcity of South African-specific research on this subject and the limited exploration of CPTBS effects on various residential densities necessitates a comprehensive investigation. Hence, this study aims to fill this void by examining the impact of CPTBS proximity on residential property prices within the City of Johannesburg (CoJ). It also seeks to assess if the findings align with existing international literature, thereby contributing valuable insights to this field. Drawing from prior studies’recommendations, this research will evaluate the impact of the proximity of CPTBSs on property prices in South Africa. By undertaking this study, we aim to bridge the gap in literature, providing localized insights intotherelationshipbetweenCPTBSsandresidentialpropertyvalues. Itisfromthisbackdropthatthisstudyteststhefollowinghypotheses: H0.The proximity of CPTBSs to residential properties does not account for any variationinresidentialpropertyprices. H1.The proximity of CPTBSs to residential properties does account for a variation in residentialpropertyprices. These hypotheses form the foundation for examining the nuanced relationship between CPTBS proximity and residential property values, contributing to a more comprehensive understanding of this dynamic in the context of CoJ, South Africa. This study’s findings will help property owners who have telecommunication towers on their properties, owners of neighboring properties, telecommunication companies and the public to understand the implications of having a telecommunication tower on or near their properties. The research findings will raise property owners’consciousness with regard to the CPTBSs’effects and receive improved compensation when there is a loss in their properties’values. It can also be advantageous for propertyvaluatorsto understand theimpactof telecommunication towerson properties. After the introduction, this paper is structured as follows: Section 2 dwells on related literature on the telecommunication sector, telecommunication infrastructure, what influences the residential property market, theoretical framework and the specific impacts of CPTBSs on residential property prices. Section 3 focuses on data and methods, while Section 4 dwells on presentation and discussion ofresults.Section 5offers concluding remarksand possible areasoffuture research. 2. Literature review 2.1 The history of telecommunication sector: an overview The advent of telecommunication in 1870 and the innovation of new information and communications technologies (ICTs), such as the internet in 1980s, changed the traditional Impact of proximity 1423 Downloaded from http://www.emerald.com/ijhma/article-pdf/17/6/1422/9471207/ijhma-12-2023-0167.pdf by guest on 30 March 2026 Page 269 of 473 waysofcommunicationthatwasconsideredslowandineffective(Thornton etal.,2006).The new ICTs have enhanced communication by reducing cost and led to unprecedented consequences in all facets of human life.Castells (2002)further argues that the internet in particular has lowered transaction costs, shortened transactions and short-circuited barriers inawayneverexperiencedinhistory. The telecommunication sector involving telecommunications (e.g.fixed, mobile and internet) and broadcasting (e.g. radio) has faced monumental transformation over the years (Stats SA, 2019). Its growth has seen a decline of fixed landline services and the upsurge of cell phones for data and voice services (Makhaya and Roberts, 2003). Now, mobile phones account for two-thirds of mobile connections globally (GSMA, 2014). As such, there has been the continuous construction, and maintenance of the CPTBSs ensures the latest technology to secure dependable network quality and connectivity overlargegeographical areas(MpwanyaandLetsoalo,2019). During the apartheid era [1], South Africa’s telecommunication services were distributed unequally among different ethnic groups and income levels, with infrastructure predominantly concentrated in white-dominated neighborhoods. This resulted in a 1% teledensity (number of fixed (landline) telephone connections per 100 people) in black rural areas compared to high teledensity in white regions (Gillwald, 2005). Post- apartheid, the democratic government sought to regulate the industry as a public utility to ensure access, as it implemented anti- monopoly oversight to prevent overpricing (Thornton etal.,2006). In 1991, Telkom was the sole state-owned entity providing telecommunication services, but in 1993, new players like Vodacom and MTN entered the market (Henry, 2019). The 1996 Telecommunication Act (RSA, 1996) aimed at creating efficient services and infrastructure, leading to the entry of additional operators (Gillwald, 2005). In particular, the post-apartheid government prioritized the expansionof telecommunicationinfrastructureto underservedareas(Hodge,2004). The shift from fixed landlines to mobile phones starting around the year 2000 transformed the sector (Makhaya and Roberts, 2003;Henry, 2019). The rise of MNOs and increased cell phone subscribers in South Africa further boosted economic growth (Buys et al.,2009). This growth prompted the proliferation of CPTBSs with South Africa having the highest number in Africa by 2014 (GSMA, 2014). The telecommunication sector’s ongoing transformation is driven by the increasing importance of the internet for both businessandindividualcommunication(Henry,2019;SmaqaeandAnwar,2022). 2.2 Types of cell phone tower base stations infrastructure CPTBSs facilitate the art and science of “communicating”over a distance by telephone, telegraph and radio (RSA, 1996). This follows the transmission, reception and the switching of signals, such as electrical or optical, by wire,fiber or electromagnetic (fields) (i.e. through-the- air) (Thornton,et al.,2006). With communication, receipt and sending of communication information through the diverse channels, key concepts in the above definition, CPTBSs offer two functions: a line of communication and sufficient infrastructure to facilitate communication throughvariousavenues,suchasradio,telephone,television and data (Thornton et al., 2006). Dictated by various governing policies, laws and topographical features, there are various CPTBSs permitted in residential neighborhoods. The height of the various CPTBSs range from 5to60m(Szmigielski and Sobiczewska, 2000). The location and topography of a given area can determine the structure height permitted for a CPTBS (Yahya, 2019). Location is crucial to ensure the best network coverage with little to no interference with other CPTBSs and to avoid triggeringenvironmental harmto thesurrounding areas(Bond, 2007a,2007b). There are several types of CPTBS infrastructure, comprising monopole, self-supporting/ lattice,rooftopantenna,steepletower,guyedtowerandcamouflage/palmtree(Yahya,2019). Plate 1 shows the various CTBPSs. The image on the left in Plate 1 displays the camouflage IJHMA 17,6 1424 Downloaded from http://www.emerald.com/ijhma/article-pdf/17/6/1422/9471207/ijhma-12-2023-0167.pdf by guest on 30 March 2026 Page 270 of 473 CPTBS infrastructure. Palm tree/camouflage CPTBS has similar features to a tree. CPTBSs are artificial palm trees and have a limited capacity. The purpose of the camouflage is to blend in with thesurrounding area. In addition, thecamouflage CPTBS addresses thevisual pollutionoraestheticsandthevisualimpactofCPTBSsontheenvironment(Yahya,2019). The image in the middle in Plate 1 presents monopole CPTBS antennas attached to the exterior (XH Tower, 2024).AmonopoleCPTBScanbeeithersingleorarmed(Rajapaksa et al., 2018). The CPTBS reduces the visual impact, and its construction timeline is shorter than that of a self-supportingCPTBS(KMB, 2015).Itsheight variesfrom 15 to 60m (Steelin theAir,2024). The image on the right in Plate 1 depicts the self-supporting CPTBS (Jeff, 2009). A self- supporting/lattice CPTBS has between three and four legs with an angular base of a steel structure (Rajapaksa et al.,2018). The CPTBS can modify itself to cater for electricity transmission and radio towers. In addition, the self-supporting CPTBS can accommodate intensewinds.Itsheightvariesfrom30to120m. 2.3 Location and functionality of cell phone tower base stations The evolution of cell phone technology, spanning from 1G to 5G, has driven the development of CPTBSs, impacting their placement and coverage. As technology advances, the proximity of CPTBSs becomes crucial, with more advanced networks requiring close placement for uninterrupted coverage (Yahya, 2019;Bello, 2007). The coverage area, influenced by factors like population density, communication channels and physical obstructions varies and optimal CPTBS location is vital for maximum capacity operation (Yahya, 2019;Barnes, 1999;Rajapaksa et al., 2018). Interconnected cells are essential for continuous network coverage as users move between them, and the changes from 1G to 5G impact CPTBS infrastructure to support high-speed data transfer, reducing the world into a global village through wireless communication (Filippova and Rehm, 2011). However, this growth poses challenges such as increased demand for land and concerns about electromagnetic field exposure (Olukolajo et al., 2013;Szmigielski and Sobiczewska, 2000). TheconstructionandmaintenanceofCPTBSsentailprohibitivecosts,emphasizingtheneed for strategic placement to meet evolving telecommunication demands influenced by consumer behavior and technological advancements (Bharadwaj et al.,2020;Filippova and Rehm,2014). Plate1. TypesofCPTBSs Impact of proximity 1425 Downloaded from http://www.emerald.com/ijhma/article-pdf/17/6/1422/9471207/ijhma-12-2023-0167.pdf by guest on 30 March 2026 Page 271 of 473 2.4 Theoretical framework This paper adopted the hedonic theoretical framework (Rosen, 1974). The hedonic regression analysis estimates the marginal contribution of the individual characteristics to house price. Given that it is challenging to evaluate the price of a house because it has unique features, the hedonic pricing model breaks housing expenditures into individual components. As such, the hedonic regression approach is the most feasible housing market analysis tool. The paper used unbalanced panel data, combining time series and cross- sectionalhousesales: Yit ¼b0 þ b1 Xit þ b2 Nit þ b3 Tit þ «(1) where Yit denotes the house price (and the dependent variable) measured over time t,Xit denotes property specific attributes;Nit denotes neighborhood specific attributes,Tit denotes time-specific attributes,b0 and b1–b3 are the intercept and slopes, respectively, of the hedonicmodeltobeestimated.«istherandomerrortermthatvariesover i and t andi.i.d. Based on the hedonic regression modeling framework, the property’s price is a function of the physical characteristics and external factors –broadly broken into properties-specificstructural features, and other neighborhood and environmental features. Structural characteristics include lot size, age, square foot, garage,fireplace, size, beds, baths, swimming and distance (from CTBPS in the present paper). Neighborhood characteristics include location, crime, distance, trees and school district, while environmental include lake view, lake front and ocean view (Sirmans etal.,2005). 2.5 Impacts of cell phone tower base stations on residential property prices 2.5.1 Perceptions about cell phone tower base stations’impact on residential property prices based on primary data.The concern over the impact of CPTBSs on residential properties stems from visual appeal and health and safety concerns related to electromagnetic fields they emit (radiation) (Bond, 2007a,2007b;Bello, 2007). Most residents believe CPTBSs are a visual disamenity and pose health complications and environmental issues (Szmigielski and Sobiczewska, 2000;Filippova and Rehm, 2011;Randburg Sun, 2017). Communities negatively perceive CPTBSs as reducing property values (Filippova and Rehm, 2011).Bond and Beamish (2005)revealed negative perceptions from future buyers and researchable information on purchasing a property near a CPTBS (Bond and Beamish, 2005). The installation of CPTBSs is a public concern due to the potential health implications and other effectsoflivingnearaCPTBS(Bond,2007a,2007b). With that in mind, CPTBSs affect perceptions about property values and trigger fear among the population. Using an opinion survey,Bond and Beamish (2005)investigated residents’perceptions of living close to CPTBSs and how this proximity might affect property values in Christchurch, New Zealand. Tencase studieswith all thesuburbs having similar living environments (in socio-economic terms) were used, except that the five case studies were areas where a CPBS is located within 300 m, while the latter five case studies werelocatedover 1 kmaway fromanyCPTBS. Theresults indicatethat residents wholived close to CPTBSs were less concerned than those who lived 1 km from the infrastructure. Participants in Bond and Beamish’s (2005)study discounted the property prices by 10% to 19% for a property close to the CPTBSs. Other authors relying on perception surveys have similarly found respondents discounting residential property prices and expressing concerns about property value, health and aesthetics in relation to the presence of pylons (BondandHopkins,2000;SimsandDent,2005). IJHMA 17,6 1426 Downloaded from http://www.emerald.com/ijhma/article-pdf/17/6/1422/9471207/ijhma-12-2023-0167.pdf by guest on 30 March 2026 Page 272 of 473 Aliyu et al.(2015)investigated the impact of CPTBSs on residential property values in the Bauchi Metropolis (Nigeria) through transaction sales using a questionnaire and interview surveys. The findings indicate that residential property prices decreased by 15% after construction of CPTBSs within 275 m from the property. Residents prefer to live in neighborhoods without CPTBS to avoid health risks associated with CPTBS. The findings indicate negative perceptions from buyers about living close to CPTBSs. Residents who lived 100 m away from the CPTBSs were not concerned about the CPTBS infrastructure (Aliyu etal.,2015). Bond’s (2007a,2007b) study in Christchurch, New Zealand, that focused on opinion survey and an econometric analysis of sales transactions found that residents who lived further away from the CPTBSs were more concerned about the health risks, aesthetics and property values than those who lived near the CPTBSs. Respondents preferred a discounted propertypriceorrentalof20%iftheylivedclosetoaCPTBS(Bond,2007a,2007b). InAkuretown,Nigeria,Olukolajo etal.(2013)focusedonresidentswhorentedaproperty withinthree residential areas with differingdensitiesranging from high tomediumandlow. The rentals were located within a 300-m radius of the CPTBSs. From their perception surveys,Olukolajo et al.(2013)findings showed that 73% of the respondents had no issues with the presence of the CPTBSs in their neighborhood. The low- and high-density renters ranked good network coverage as a factor for living within the community.Olukolajo et al. (2013)also found that residents were concerned about the loss of the aesthetic value of neighboring properties, but this still needs to change the economic value of the properties and rental charges (Olukolajo et al., 2013). Regression analysis findings indicated that the locationof theCPTBSs does notaffect thepropertyvalues withinhigh-andmedium-density neighborhoods. However, for the low-density neighborhoods, there is a positive relationship betweentherentalamountsandtheCPTBSs(Olukolajo etal.,2013). Smaqae and Anwar (2022)demonstrated increased selling and rental prices for properties with rooftop antennas in the city of Erbil in the Kurdistan region of Iraq. Their findingsfrom administered questionnairesshowedthat residents weremore awareof health risks caused by CPTBSs, but probably by property owners who lived close to CPTBSs receivingbenefits,suchasfree electricity andfree recharging, saw that asadequatetradeoff (SmaqaeandAnwar,2022). 2.5.2 Impacts of cell phone tower base stations on residential property prices based on sec- ondary data.LockeandBlomquist (2016)foundoutthat residentialpropertiescomparableto CPTBSs sold at a discounted price compared to houses located further away from the CPTBSs in Central Kentucky, USA. Using housing data covering a period of 12years from 2000 to 2011,Locke and Blomquist (2016)found that a residential property was purchased after the construction of the CPTBS, there is a slight decrease in the house sale price, and that decreases declines with distance further away from the CPTBSs (Locke and Blomquist, 2016).Filippova and Rehm (2011,2014) investigated residential property sales in Aukland’s largest territories (Auckland, Manukau, North Shore and Waitakere), and Christchurch, New Zealand, for different periods, respectively. They focused on properties within specific radius distance of cell phone towers located in residential areas in their studies. Controlling for the contribution of other house structural and neighborhood variables, overall, there was nosignificantimpactofCPTBS onresidentialpropertyprices.However, theauthors founda price discount related to the most visually disruptive armed monopoles. The authors explained that the overall insignificant results could be related to the mature plantings, making CPTBS to be camouflaged in the surroundings and thus less noticeable (Filippova andRehm,2011,2014). Impact of proximity 1427 Downloaded from http://www.emerald.com/ijhma/article-pdf/17/6/1422/9471207/ijhma-12-2023-0167.pdf by guest on 30 March 2026 Page 273 of 473 Rajapaksa et al.(2018)examined the impact of the distance of CPTBS on residential property prices using the market transaction data in Brisbane, Australia. The findings indicate that the distance of CPTBS significantly affects house prices. For example, a 1 m distance from the CPTBS increased the property price by 0.018%. With a dummy variable introduced instead of a direct distance to tower to capture the distance effect, there was a negative impact of the distance from CPTBSs on the property prices within a 150m radius; the property prices decreased by 20%. Property sale prices within a 200m radius are highly affected and discounted by 15%. Although several types of CPTBS have different visual disruptiveness for respondents, CPTBSs did not affect the property prices (Rajapaksa et al., 2018). Bond (2007a,2007b) investigated the effect of the distance of CPTBSs on residential property prices in Florida, USA. Using hedonic modeling technique,Bond (2007a,2007b) found that price of a residential property is significantly impacted by proximity to the towers –with asuggested noticeableincreaseinvalueoftheresidentialpropertyas distance increasesfromthetower. Brandt and Maennig (2012)evaluated the impact of CPTBSs on prices of condominiums in Hamburg metropolis, Germany. Distinguishing between grouped CPTBSs and individual CPTBSs, they found that only immediate proximity to groups of antenna masts is perceived as harmful to health by residents of nearby condominiums in relation to a group of masts. There was no significant impact from individual CPTBSs(BrandtandMaennig, 2012). Affuso et al.(2018)examined the impact of the proximity of CPTBSs on residential property prices for the period 1999 and 2015 in Mobile County, AL, USA, using hedonic spatial autoregressive model. The authors considered CPTBSs that were visible and invisible with a specified radius for properties sold after the construction of the CPTBSs. The authors found that property prices decreased if the CPTBS was visible from a distance. Specifically, the findings indicate a discount of 2.46% to 9.78% for residential properties withinaradiusof0.72km(Affuso etal.,2018). 3. Study area, data and methods 3.1 Study area and unit of analysis Based on the availability of data on residential property prices, the study area covered the residential suburbs in the CoJ, South Africa (Figure 1). In the government structure of South Africa, there are district municipalities, metropolitan municipalities, local municipalities, wards and sub-places. As shown in the inset of Figure 1, CoJ is one of the three metropolitan municipalities in Gauteng province and the largest in South Africa. As such, it is in the CoJ that one finds more telecommunication infrastructure, and thus a fertile ground to test the impacts of CPTBSs on residential property prices. The study considered all the suburbs spreadacrossRegionsA–G. The unit of analysis for this study was residential suburbs with the presence of CPTBSs, as the study was concerned with the distance of properties from the CPTBSs. To determine the distance, a radius from 0 to 1,000 m, increasing by 250 m was chosen, hence the distances 250, 500, 750 and 1,000 m from CPTBSs. Various studies have used distance radii to determine the impact of proximity of HVOLTs, such as Hamilton and Schwann (1995), who used 100 and 200 m distances, as did Strand and Vågnes (2001);Reichert (1997), who used four 2,250ft (658m) concentric zones;Colwell et al.(1990), who used 50ft (15m), 200ft (60m)andmorethan200ft(60m);and BondandHopkins(2000)and desRosiers(2002),who used50m(165ft)concentriczones(Bond,2007a,2007b). IJHMA 17,6 1428 Downloaded from http://www.emerald.com/ijhma/article-pdf/17/6/1422/9471207/ijhma-12-2023-0167.pdf by guest on 30 March 2026 Page 274 of 473 The study only considered residential suburbs with CPTBSs from the year 2010 to 2020. Affuso et al.(2018)considered a visibility study to verify the location of the CPTBSs. They assumed that the spatial correlation between property values and tower locations affects the value of a property. If the CPTBS is visible from other properties, then it can influence the neighboring properties’values. Therefore, CPTBSs that are further yet visible from a property have the potential to affect the property’s value. The Haversine distance formula calculates the distance from the residential property to the closest CPTBS. However, for the present study, the Euclidean distance formula calculated the distance between the residential property (centroid based on the sub-place level) and the CPTBS. The Euclidean distance calculates the distance between two points.Equation (2)is the Euclidean distance formula (Cuemath, 2024). Equation (2)determines the distance betweenthe residential property (centroid) and the CPTBS for thecurrent study: d ¼ ffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffi x2 þ x1ðÞ2y2 y1ðÞ2 q ;(2) where (x1,y1) are the coordinates of the first point, (x2,y2) are the coordinates of the second pointand d isthedistancebetween(x1,y1)and(x2,y2). 3.2 Data Following an extensive review of existing literature (see Section 2.6) and guided by the theoretical framework, the paper used residential house prices and other data obtained from varioussources.Thefollowingdatawereconsideredforthestudy: Figure1. Locationofsuburbs acrossdifferent regionsintheCoJ, SouthAfrica Impact of proximity 1429 Downloaded from http://www.emerald.com/ijhma/article-pdf/17/6/1422/9471207/ijhma-12-2023-0167.pdf by guest on 30 March 2026 Page 275 of 473 Adjusted house sale prices –The property sale transaction data were obtained from Lightstone Property Ltd covered 2010 to 2020. The property sale prices were deflated by using the consumer price index (CPI) with a base year of 2015. This was needed as time affects the overall residential property sale. House sales data had other structural and neighborhood characteristics –property density type (single-dwelling homes (FH) or sectional-title flats (SS), property size, suburb, town, municipality, year the property sold and numbers of bathrooms and bedrooms). Distance of CPTBS from residential properties –As one of the key variables in the study, it was calculated as the distance from the suburb centroid to the nearest CPTBS using nearest analysis tool in ArcGIS software version 10.8.2 (ESRI, 2023), as depicted by equation (2), the Euclidean distance equation. The suburb centroids were used because specific residential address were not available. This was feasible because suburbs are small in sizes, and the centroid would be a good distance proxy. The CPTBS data, which were clipped to the CoJ, were obtained from the South African Civil Aviation Authority (SACAA) website. SACAA publishes all applications for infrastructure with a height that can cause interference with aviation communication. The SACAA data are categorized based on the type of infrastructure. The CPTBS data were filtered from the SACAA data to obtain the CPTBS coordinates. The data cleaning exercise ensured that CPTBS coordinates duplicates were corrected and only singly captured CPTBS data were used in the study. Confirmed through a manual check in Google Earth, the final CTPBS data had the following attributes: location (commercial, industrial or residential location), application status, CPTBS type, the year CPTBS was constructed (as in Filippova and Rehm, 2014). The data focused on CPTBSs constructed before 2010 and not later than 2019, to coincide with the available house sales data that covered 2010–2020 (Rajapaksa et al.,2018). The residential property prices before and after the construction of CPTBSs are crucial to one’s understanding of the impact of CPTBSs on residential property prices and prices of the surrounding properties. The distance variable was captured inradii of 0–250 m,251–500 m,501–750 m and 751–1,000 m. Crime data –Neighborhood crime is postulated to exert an impact on residential property prices (Ihlanfeldt and Mayock, 2010). Crime data were extracted from Quantec (EasyData, 2023), which captures crime statistics as announced by the South African Police Services (SAPS). Income –The income variable from EasyData (2023)was measured as household disposable income. It is hypothesized that as income increases following economic growth, for instance, so does the number of people who are able to budget for housing demand. Several scholars agree that household income is a major determinant of housing affordability, thus the supply- and demand-side of the housing market (Bajari and Kahn, 2005). The number of unemployed –Unemployment has a dampening effect on housing demand as it causes household income to decline. The number of the data was extracted from Quantec (EasyData, 2023). Prime lending rate (%)–This rate related to the South African Reserve Bank’s repo rate and is anticipated that higher prime lending rate makes the cost of home loans expensive, thus dampening sales. Year dummies –m–1 year dummies were included in the panel model to control for time or trend effects. IJHMA 17,6 1430 Downloaded from http://www.emerald.com/ijhma/article-pdf/17/6/1422/9471207/ijhma-12-2023-0167.pdf by guest on 30 March 2026 Page 276 of 473 Residential density –0 if it is a freehold title. 1 if it is a sectional title. D*–a dummy ¼1 if property sale occurs after CPTBS construction; 0 otherwise. 3.3 Hedonic modeling A semi-log hedonic pricing model was estimated to examine the impact of CPTBSs on residential property prices [equation (3)]. The dependent variable is the adjusted house sale price, and the independent variables include property structural and neighborhood attributes: InðPriceÞit ¼b0 þ b1 lnDistance orInverseof lnDistanceðÞþb2Interaction þ b3 Bedrooms þ b4 Bedssquare þ b5 Bathrooms þ b6 Area þ b6 Residentialdensity þ b7 D*þ b8 lnCrime þ b9 lnlabour þ lnincome þ b11 Primelendingrate þ b12 Saleyeardummyi þ eit (3) where In(Price)it is the sale price for residential property i in time t;Saleyeardummyi is m-1 dummies for sale years, for i ¼1–10 (i.e. 2011 through to 2020);«is the random error term that varies over i and t as well as i.i.d.;b0 b11 are estimated regression coefficients of explanatory variables; and b12 allowing for m-1year dummy coefficients as described in Table 1. The excluded dummy variables were used as base year or reference group(s). The adjusted house sale price and some of the explanatory variables were log-transformed because they were skewed –this was necessary as the regression analysis is based on the normalityassumption.DatawereanalyzedinStata17. 4. Results and discussion 4.1 Spatial analysis After cleaning the SACAA data that comprised of masts at various statuses, a total of 1,195 masts were identified to have been constructed. A majority of the CPTBSs were constructed before 2010, with the highest numbers for all the CPTBS types. Out of the 1,195 constructed masts, the camouflage/palm tree was the most constructed type of CPTBS in the CoJ (750), accounting for 63% of all CPTBSs, followed by the monopole CPTBS at 311 (26%). Finally, thenumberoflatticesCPTBSsconstructedintheCoJwas127(11%). Figure 2 depicts the constructed CPTBSs across the CoJ’s suburbs and the centroids for each ofthesuburbs.The figure displays theCPTBSs constructedbefore 2010 to 2023,where one can observe an even distribution of the CPTBSs throughout the suburbs. The property data excluded physical addresses and erf descriptions of the properties sold from 2010 to 2020. The red dots represent centroids in each of the suburbs (defined by Statistics South Africa as a subplace).Figure 2 indicates that there are multiple CPTBSs in each centroid. ThemajorityoftheCPTBSscateredforthecentralsuburbsintheCoJ. Figure 3 illustrates the radius of the centroids from 0 to 1,000m. The centroids had four ranges of radii from the CPTBSs of 0–250m (D1), 251–500m (D2), 501–750m (D3) and 751– 1,000m (D4); only these CPTBSs included in the radius formed part of this study. Distance 0–250m was the control group, and the radii increased by 250m until 1,000m. In some instances, there are multiple CPTBSs within one centroid radius. The distance from the centroid to the nearest CPTBS was calculated using the near analysis on ArcMap software version10.8.2,wheretheinputvariableisthecentroids,andtheoutputistheCPTBSs. Impact of proximity 1431 Downloaded from http://www.emerald.com/ijhma/article-pdf/17/6/1422/9471207/ijhma-12-2023-0167.pdf by guest on 30 March 2026 Page 277 of 473 4.2 Empirical analysis 4.2.1 Descriptive analysis.Table 2 presents the descriptive statistics from a sample of 79,691 observations obtained aftercleaningofthedata (Table1 for all model variables) from Lightstone Property Limited. Lightstone is a private company that supplies data in bulk for various uses as requested by clients. The statistics are given for the full sample and for the proximity categories (0–250m, 251–500m, 501–750m and 751–1,000m). The logged averages were (13.71, 13.37, 13.88, 13.78 and 14.00) for the adjusted property price, (5.26, 5.30, 5.18, 5.37 and 5.37) for the property size, (1.73, 1.54, 1.81, 1.82 and 1.84) for the number of bedrooms and (1.18, 0.98, 1.26, 1.25 and 1.30) for the number of bathrooms. The averages of distances from the CPTBSs were 6.01 for the full sample, 5.20 for those that ranged from 0–250m, 5.95 for 251–500m, 6.38 for 501–750m and 6.75 for 751–1,000m. The average logs were (12.05, 12.20, 11.96, 12.00 and 11.98) for crime, (10.99, 10.99, 10.97, 10.98, 11.06) for household income,(13.36,13.58,13.24,13.30and13.26)for thenumberofunemployedpeople Table 1. Description of model variables used in the study Variables Description Dependent variable Adjusted property price Amount in rands Independent variables Structural variables Plot area Plot area size in sq m Bedrooms Number of bedrooms Bathrooms Number of bathrooms Residential density 0 if it is a single freestanding (freehold title). 1 if it is a sectional flat (sectional title, SS) D* 1 if property sale occurs after CTPBS construction, 0 otherwise Neighborhood variables Log of distances in each of the four radii (i.e. of 0–250m, 251–500m, 501–750m and 751–1,000m) Specific distance in m in relation to each of the residential property to the CPTBSs in each of the radii Interaction D* x lndistance lnCrime Log of number of crimes lnlabor Log of number of the unemployed lnIncome Log of amount of household income in rands Prime lending rate The interest rate at which banks lend to customers Sale year of the property 2010 Defined as base year –excluded in the estimation 2011 0 if sales occur before 2011. 1 if sales occur in 2011 2012 0 if sales occur before 2012. 1 if sales occur in 2012 2013 0 if sales occur before 2013. 1 if sales occur in 2013 2014 0 if sales occur before 2014. 1 if sales occur in 2014 2015 0 if sales occur before 2015. 1 if sales occur in 2015 2016 0 if sales occur before 2016. 1 if sales occur in 2016 2017 0 if sales occur before 2017. 1 if sales occur in 2017 2018 0 if sales occur before 2018. 1 if sales occur in 2018 2019 0 if sales occur before 2019. 1 if sales occur in 2019 2020 0 if sales occur before 2020. 1 if sales occur in 2020 Source:Authors’own creation IJHMA 17,6 1432 Downloaded from http://www.emerald.com/ijhma/article-pdf/17/6/1422/9471207/ijhma-12-2023-0167.pdf by guest on 30 March 2026 Page 278 of 473 (labor) and (9.71, 9.66, 9.72, 9.77 and 9.74) for the lending rate. The standard deviations were allbelowtheaverages. 4.2.2 Correlation analysis.Table 3 presents correlations between the model variables in thispaper.Thenumberofbedroomsandthepropertysizehavethehighestcorrelationthat is statistically significant, followed by the number of bathrooms, sale prices, distance from the CPTBSs, the number of unemployed people and crime in logs. The adjusted price is positive and statistically significantly correlated with the size of the property, the number of beds, the number of bathrooms, the general distance from the CPTBSs, the single-family home property density and the prime lending rate. Whereas, crime, income and unemployment (ln labor) are negatively correlated with the log of adjusted price. Income was expected to be positively correlated with price, contrary to our finding here. This could be due to estimation error, or sampling problem. Among all variables, there is no severe collinearity, which could poseaproblemduringestimatingtheregressionresults. 4.2.3 Hedonic analysis.Table 4 presents estimation results obtained by estimating the effect that CPTBS proximity, which was the variable of interest, has on the residential property prices in the CoJ suburbs. The use of 250m distance increment allows for a more adequate “microspatial”study (des Rosiers, 2002). Sections 4.2.3.1 and 4.3.2.2 present the hedonic model results for the log of distance and the hedonic model results for the inverse of the log of distances 0–250m, 251–500m, 501–750m, 751–1,000m, respectively. In both Sections 4.2.3.1 and 4.2.3.2, all the property-specific structural and neighborhood variables are included as shown in Table 4.Table 4 presents the OLS for each of the sub-samples defined by distance of 0–250m (Column 1), 251–500m (Column 2), 501–750m (Column 3) Figure2. ConstructedCPTBSs andcentroidsin theCoJ Impact of proximity 1433 Downloaded from http://www.emerald.com/ijhma/article-pdf/17/6/1422/9471207/ijhma-12-2023-0167.pdf by guest on 30 March 2026 Page 279 of 473 and751–1,000m (Column 4). Thesamplesize variesfor each sub-sample because thecontrol variables(i.e.structuralandneighborhoodvariables)hadmissingvaluesinsomecases. The model fitting was stable across all models, with the lowest variation of 41% explained (see Adj R2 in Table 4). Most of the regression coefficients are statistically significant, have expected signs and are in the expected direction. The reported results control for heteroscedasticity and multicollinearity in OLS. The variance inflation Table 2. Descriptive statistics Full sample Sample 1 (0–250 m) Sample 2 (251–500 m) Sample 3 (501–750 m) Sample 4 (751–1,000 m) Variable Mean SD Mean SD Mean SD Mean SD Mean SD lnPrice 13.71 0.717 13.37 0.744 13.88 0.630 13.78 0.730 14.00 0.528 Beds 1.734 1.483 1.548 1.438 1.812 1.486 1.823 1.514 1.838 1.503 Bath 1.175 1.134 0.981 1.042 1.261 1.165 1.248 1.154 1.299 1.169 lnIncome 10.99 0.254 10.99 0.214 10.97 0.281 10.98 0.250 11.06 0.256 lnLabor 13.36 0.434 13.58 0.566 13.24 0.289 13.30 0.258 13.26 0.317 lnSize 5.262 1.092 5.301 0.993 5.184 1.100 5.367 1.193 5.340 1.160 lnCrime 12.05 0.431 12.20 0.638 11.96 0.228 12.00 0.198 11.98 0.286 lnDistance 6.005 0.458 5.194 0.291 5.949 0.171 6.375 0.0985 6.745 0.137 Density (SH) 0.428 0.495 0.368 0.482 0.477 0.499 0.406 0.491 0.427 0.495 D* 0.780 0.414 0.733 0.442 0.808 0.394 0.783 0.412 0.798 0.402 Prime lending rate 9.711 0.931 9.663 0.894 9.718 0.943 9.766 0.960 9.744 0.941 Source:Authors’own creation Figure3. Distancefrom centroidsincreasing by250m IJHMA 17,6 1434 Downloaded from http://www.emerald.com/ijhma/article-pdf/17/6/1422/9471207/ijhma-12-2023-0167.pdf by guest on 30 March 2026 Page 280 of 473 coefficients were all below 5, thus no potential multicollinearity problem in the estimated models. 4.2.3.1 Proximity of cell phone tower base stations to residential properties –with the log of distance as the key variable. Column 1 (in Table 4) shows OLS results of the effect of CPTBS proximity on residential property prices for 0–250m. The estimated results show positive and statistically significant coefficients. This implies that for every 1% increase in distance from a CPTBS, the residential property price increases by 1.14%. In terms of CPTBS proximity of 251–500m, presented in Column 2, the coefficient remains positive and significant; however, the size of the coefficient drops significantly to 0.52%. The results concur with those of Bond and Wang (2005),Affuso et al.(2018)and Rajapaksa et al.(2018) who suggest that the location of CPTBS has a significant effect on residential property prices. However,theseresultsdiffer from BrandtandMaennig’s (2012)findingswhofounda negative coefficient within a radius of 100m from the CPTBS.Filippova and Rehm (2014) foundnostatisticallysignificantresultsintheirstudy. For CPTBS proximity of 501–750m, the distance is negative and statistically significant, implying that for every 1% increase distance from the CPTBS, residential property prices decrease by 2.58%.Affuso et al.(2018)obtained similar results for residential properties within the 0.03–0.72km in their study in the USA. Finally, for residential properties, which were within 751–1,000m radius of the CPTBS, the residential property prices decrease by 3.83% for every 1% increase in the distances from the CTPBS. The results clearly show CPTBS negatively influences adjacent property values, although the effect tends to diminish as the distance from the CTPBS increases from the property. This finding validates the conclusion reached by Filippova and Rehm’s (2014)study in New Zealand with regard to proximity effect on residential propertyvalue. In the case of the dummy (D*), which took a value of 1 if the property sale occurred after the CPTBS construction, the results are also interesting. D* captured the impact of the CPTBS on the value of property. Its coefficients with the radii of 0–250m and 251–500m are positive and significant in explaining residential property prices. This means that for residential properties that were sold after the construction of the CTPBS and are within the radii of 0–250m and 251–500m, their prices increased by 5.57% and 4.67%, respectively, compared to those that were not within the above distance bands.Affuso et al.(2018) obtained similar results for properties within the 0.03–0.72km in their study. However, the Table 3. Pairwise correlations Variables (1) (2) (3) (4) (5) (6) (7) (8) (9) (10) (1) lnPrice 1.000 (2) lnSize 0.348* 1.000 (3) Beds 0.264* 0.386* 1.000 (4) Bath 0.324* 0.324* 0.824* 1.000 (5) lnDistance 0.153* 0.029* 0.015* 0.037* 1.000 (6) lnCrime –0.242* 0.121*–0.041*–0.062*–0.042* 1.000 (7) Density (SH) 0.040*–0.007 0.004 0.016* 0.057*–0.004 1.000 (8) lnIncome –0.031* 0.015*–0.021*–0.027* 0.057* 0.152*–0.001 1.000 (9) lnLabor –0.266* 0.135*–0.079*–0.115*–0.100* 0.447*–0.062* 0.143* 1.000 (10) Prime lending rate 0.034* 0.030* 0.022* 0.015* 0.010* 0.132* 0.024*–0.022*–0.048* 1.000 Notes:***p <0.01; **p <0.05; *p <0.1 Source:Authors’own creation Impact of proximity 1435 Downloaded from http://www.emerald.com/ijhma/article-pdf/17/6/1422/9471207/ijhma-12-2023-0167.pdf by guest on 30 March 2026 Page 281 of 473 estimated results of D* for properties located within 501–750m and 751–1,000m (presented in Columns 3 and 4 in Table 4) from the closest CTPBS show a negative and statistically significantrelationshipbetweenresidentialpropertyprices. The findings of this study show that residential property sale prices purchased from 2011 to 2016 have negative and statistically significant regression coefficients within all sub-sample bands (i.e. 0–250m, 251–500m, 501–750m and 751–1,000m), compared to the baseline year of 2010. Conversely, properties purchased in 2017 and within the 0–250m, 501–750m have positive and statistically significant regression coefficients compared to the base year (2010). However, in 2017, properties within the 751–1,000m from the closest CTPBS (Column 4), have negative and statistically significant regression coefficients compared to those in the base year (2010). The same estimate is statistically different from zero for those properties located within 251–500m and 501–750m in 2018.Affuso et al. (2018)and Rajapaksa etal.(2018)obtainedsimilar resultsintheir studyrelatedtotimeeffect onresidentialpropertyprices. The interaction variable –defined as the product of log of distance and the dummy (D*) variables –also suggests a decrease in the price of property sold after CPTBS construction for those properties in the 0–250m and 251–500m proximity distance bands. However, as the distance from the CTPBS increases, the effects become positive and significant. The t-statistics associated with this interaction provide strong evidence that the price of residential properties, while highly associated with the site and Table 4. Estimation results adjusted sale price regressed on distance categories (D1–D4) and other control variables (1) (2) (3) (4) Variables 0–250 m 251 m–500 m 501 m–750 m 751 m–1000 m lnSize 0.262*** (0.006) 0.250*** (0.003) 0.267*** (0.004) 0.203*** (0.006) Beds –0.121*** (0.010)–0.071*** (0.005)–0.005 (0.007) 0.005 (0.011) Beds square 0.010*** (0.001) 0.011*** (0.001) 0.004*** (0.001) 0.006*** (0.002) Bath 0.225*** (0.009) 0.091*** (0.004) 0.070*** (0.007) 0.042*** (0.009) lnCrime –0.100*** (0.035)–0.385*** (0.013)–0.300*** (0.034)–0.240*** (0.027) Density (SH)–0.065*** (0.012) 0.125*** (0.005)–0.072*** (0.011)–0.081*** (0.013) lnIncome –0.790*** (0.054) 0.084*** (0.010) 0.321*** (0.022) 0.511*** (0.042) lnLabor 0.080*** (0.023)–0.290*** (0.009)–0.206*** (0.025)–0.888*** (0.036) Prime lending rate –0.341*** (0.019)–0.201*** (0.007)–0.099*** (0.014)–0.276*** (0.017) D* 5.565*** (0.310) 4.667*** (0.213)–16.300*** (0.856)–12.226*** (0.985) lnDistance 1.141*** (0.058) 0.517*** (0.031)–2.578*** (0.117)–3.828*** (0.178) Interaction (ln Distance x D*)–1.053*** (0.060)–0.793*** (0.036) 2.608*** (0.134) 1.777*** (0.145) 2011 dummy –0.516*** (0.032)–0.437*** (0.013)–0.249*** (0.025)–0.489*** (0.031) 2012 dummy –0.818*** (0.045)–0.577*** (0.018)–0.320*** (0.035)–0.726*** (0.041) 2013 dummy –0.739*** (0.049)–0.602*** (0.019)–0.328*** (0.037)–0.717*** (0.043) 2014 dummy –0.662*** (0.052)–0.540*** (0.020)–0.319*** (0.041)–0.714*** (0.047) 2015 dummy –0.490*** (0.042)–0.387*** (0.016)–0.130*** (0.034)–0.482*** (0.038) 2016 dummy –0.295*** (0.035)–0.286*** (0.015)–0.066** (0.029)–0.404*** (0.034) 2017 dummy 0.107*** (0.026)–0.005 (0.011) 0.048** (0.021)–0.070*** (0.024) 2018 dummy 0.036 (0.026)–0.019* (0.011) 0.102*** (0.020)–0.013 (0.023) Constant 18.485*** (0.770) 19.072*** (0.292) 32.163*** (0.804) 50.861*** (1.226) Observations 9,173 32,805 10,472 3,544 R2 0.435 0.405 0.434 0.547 Adj.R2 0.434 0.405 0.433 0.544 Notes:Standard errors in parentheses; ***p <0.01; **p <0.05; *p <0.10; the year dummy for 2010 was used as a base year, while year dummies for 2019 and 2020 were excluded because of multicollinearity Source:Authors’own creation IJHMA 17,6 1436 Downloaded from http://www.emerald.com/ijhma/article-pdf/17/6/1422/9471207/ijhma-12-2023-0167.pdf by guest on 30 March 2026 Page 282 of 473 structural characteristics may be significantly impacted by proximity to CTPBS. As anticipated, the number of bathrooms, bedrooms and household income are vital drivers of residential property prices. Nevertheless, it appears that the effect of these variables is relative to property location with respect to the CPTBS (Brännlund and Kriström, 2015; Locke andBlomquist, 2016). Forthe sizeofthe property(InSize)withinthe foursub-samples, theestimatesare positive and statistically significant (Columns 1, 2, 3 and 4 in Table 4). Regarding the number of bedrooms (Beds) in the four sub-samples, the coefficients are negative and statistically significant for the properties located within (0–250m; 251–500m) (Columns 1, 2 in Table 4). For the square of bedrooms, which captures the non-linearity impact of the number of bedroomsonresidentialpropertyvalue,thecoefficientispositiveandstatisticallysignificant, although the magnitudes of the coefficient are small. In terms of the number of bathrooms (Bath) within the four sub-samples, the estimated results are positive and statistically significant for every one-unit increase in the number of bathrooms in a property (Columns 1, 2,3and4inTable 4).Filippova and Rehm (2014)obtained similar results for the number of bedsandpropertysize. The effect of household income (lnIncome) on residential property prices within the four sub-samples is as follows. The closer the property is to the CTPBS, the more household income has a negative effect on property value (Column 1 in Table 4). However, as the distance from the CTPBS increases, household income becomes positive and statistically significant in driving the residential property prices (see Columns 2, 3 and 4 in Table 4). Rajapaksa et al.(2018)obtained similar results for income, the size of the property, the number of beds and bathrooms in their study. In terms of the effect of unemployment (lnLabor), the results show that the closer a residential property is to the CTPBS, unemployment has a positive and significant effect on property value, which is unexpected (Column 1 in Table 4). In terms of the number of crimes recorded (lnCrime) within the four sub-samples, the estimated results show negative and statistically significant coefficients for property size located within 0–250m, 251–500m, 501–750m and 751–1,000m (Columns 1,2,3and4in Table4). With sectional flats residential properties within the 0–250m, 501–750m and 751– 1,000m radius from the CTPBS, the regression coefficients are negative and statistically significant. Given the expectation that lending cost adversely affects property prices, in this study, the prime lending regression coefficients are negative and statistically significant acrossallestimatedmodels. 4.2.3.2 Proximity of cell phone tower base stations to residential properties with inverse of the log of distance. Toensureconsistencyandreliabilityoftheresults,theestimationwas performed with the inverse of the log of distance and the interaction variables (defined as D*x Inverse of lndistance). Broadly,Table 5 presents results where the regression coefficients of most of the explanatory variables maintain the same signs and magnitudes. However, the regression coefficients for the inverse of log of distance and the interaction variable have their signs changing from either positive to negative or negative to positive, respectively. Property size, number of bedrooms, number of bathrooms, number of crimes recorded, property density, income level, unemployment rate, prime lending rate and the time effect variables are statistically significantand maintained expected signs as discussed inSection4.2.3.1. As shown by the variation in the magnitude from Column 1 to 4 in Table 5, coefficient sizes show that proximity to CTPBS has a significant influence on residential property prices. Regarding distance, the results show that the increase in distance from the CTPBS reduces the residential property sale price. Properties within the 0–500m range of CTPBS Impact of proximity 1437 Downloaded from http://www.emerald.com/ijhma/article-pdf/17/6/1422/9471207/ijhma-12-2023-0167.pdf by guest on 30 March 2026 Page 283 of 473 (1) (2) (3) (4)Variables 0–250 m 251–500 m 501–750 m 751–1,000 mlnSize 0.254*** (0.006) 0.250*** (0.003) 0.268*** (0.004) 0.207*** (0.006)Beds–0.125*** (0.010)–0.072*** (0.005)–0.004 (0.007) 0.005 (0.011)Beds square 0.010*** (0.002) 0.011*** (0.001) 0.003*** (0.001) 0.006*** (0.002)Bath 0.229*** (0.009) 0.092*** (0.004) 0.070*** (0.007) 0.043*** (0.009)lnCrime–0.070** (0.034)–0.389*** (0.013)–0.298*** (0.034)–0.239*** (0.027)Density (SH)–0.075*** (0.012) 0.128*** (0.005)–0.071*** (0.011)–0.080*** (0.013)lnIncome–1.036*** (0.047) 0.094*** (0.010) 0.311*** (0.022) 0.512*** (0.041)lnLabor 0.115*** (0.023)–0.289*** (0.009)–0.204*** (0.025)–0.921*** (0.036)Prime lending rate–0.379*** (0.018)–0.199*** (0.007)–0.099*** (0.014)–0.281*** (0.017)D* 4.435*** (0.265) 4.444*** (0.217)–15.466*** (0.811)–13.073*** (1.001)Inverse–122.305*** (6.404)–170.453*** (11.211) 1,448.218*** (64.830) 3,415.128*** (155.392)Interaction (lnverse x D*)–0.832*** (0.051)–0.756*** (0.036) 2.476*** (0.127) 1.900*** (0.147)2011 dummy–0.571*** (0.031)–0.435*** (0.013)–0.250*** (0.025)–0.498*** (0.030)2012 dummy–0.896*** (0.045)–0.575*** (0.018)–0.321*** (0.035)–0.738*** (0.040)2013 dummy–0.820*** (0.048)–0.599*** (0.019)–0.329*** (0.037)–0.732*** (0.042)2014 dummy–0.769*** (0.051)–0.536*** (0.020)–0.321*** (0.041)–0.728*** (0.047)2015 dummy–0.568*** (0.041)–0.384*** (0.016)–0.131*** (0.034)–0.490*** (0.038)2016 dummy–0.351*** (0.035)–0.285*** (0.015)–0.066** (0.029)–0.412*** (0.034)2017 dummy 0.081*** (0.026)–0.002 (0.011) 0.049** (0.021)–0.071*** (0.023)2018 dummy 0.034 (0.026)–0.018 (0.011) 0.105*** (0.020)–0.012 (0.023)Constant 27.426*** (0.581) 22.532*** (0.212) 13.314*** (0.548) 21.475*** (0.565)Observations 9,173 32,805 10,472 3,544R2Adj.R20.434 0.433 0.404 0.404 0.435 0.433 0.549 0.546Notes:Standard errors in parentheses; ***p<0.01; **p<0.05; *p<0.10; the year dummy for 2010 was used as a base year, while year dummies for 2019 and2020 were excluded because of multicollinearitySource:Authors’own creation Table 5. Estimation results with inverse of log of distance for D1–D4 IJHMA 17,6 1438 Downloaded from http://www.emerald.com/ijhma/article-pdf/17/6/1422/9471207/ijhma-12-2023-0167.pdf by guest on 30 March 2026 Page 284 of 473 tend to have reduced sale prices, while those situated beyond 500m, specifically within the 501–1000m range, show higher and statistically significant residential property sale prices. Locke and Blomquist (2016)obtained similar results when they used the inverse of distance insteadofdistanceintheirstudyintheUSA. In case of the dummy (D*), which took a value of 1 if the property sale occurred after the CPTBS construction, the results are also interesting. D* variable captured the impact of the CPTBS on value of property sold after CPTBS construction relative to value of property before the construction of the CPTBS. The coefficients with the radii of (0–250m) and (251– 500m) are positive and significant, implying that the construction of CTPBS impacted positively residential property value prices relative to when CPTBS were not constructed. Affuso et al.(2018)obtained similar results for properties within 0.03km-0.72km in their study. However, the model estimated results of D* of dummy for properties located within 501–750m and 751–1,000m (presented in Columns 3 and 4 in Table 5) show that the construction of CTPBS impacted negatively residential property value prices relative to whenCPTBSwerenotconstructed. 5. Conclusion The shift from fixed landlines to mobile phones starting around the year 2000 transformed the telecommunication sector and has led to unprecedented consequences in all facets of human life. These include lowering of transaction costs, shortening of transactions and short-circuitingofbarriersinawayneverexperiencedbeforeinhistory. This paper set out to test whether proximity of CPTBSs to residential properties account for anyvariation intheresidential propertypricesintheCoJ, SouthAfrica. Theresults show a significant impact on the proximity of CPTBS to the residential property sale prices. However, the impact of CTPBSs on residential property prices depends on the distance of such CTPBSs from the residential properties. The closer to the CTPBSs a residential property is, the higher the impact that CTPBSs has on its residential sale price. In other words, the impact of proximity of CTPBBs on the residential sale prices seems to decrease as the distance from the CPTBSs increases. This was evident from the estimation results that was based on different interval distance bands of 0–250m, 251–500m, 501–750m and 751–1,000m. The paper has provided a nuanced understanding of the relationship between CPTBSs’proximity and residential property values. Such knowledge will help property owners who have CPTBSs on their properties, their neighbors, telecommunication companies and the public to understand the implications of having CPTBS on or near their properties. Property owners will become conscious of the CPTBSs’effects and receive improved compensation when there is a loss in their properties’values. It can also be advantageous for property valuers to understand the impact of CPTBSs and related towersonproperty values. Possible future research lends itself. First, future research can include a visibility study to assess whether the visibility of and distance from the CPTBSs can affect the property prices, as suggested by previous studies. Second, the centroids radii can be increased to determine the impact of distance on residential property prices. Third, a study can be conducted to compare whether CPTBSs have similar or differential impacts on residential property prices for various metropolitans and municipalities (i.e. developed and undeveloped suburbs). Finally, future research can assess whether the CPTBSs have differential impacts on different land uses, such as commercial and industrial land uses, beyond the present study thatfocusedonresidentialproperties. Impact of proximity 1439 Downloaded from http://www.emerald.com/ijhma/article-pdf/17/6/1422/9471207/ijhma-12-2023-0167.pdf by guest on 30 March 2026 Page 285 of 473 Note 1. Apartheid denotes the formalized segregation of races that was established in South Africa and South West Africa and persisted from 1948 until the early 1990s. References Affuso, E., Reid Cummings, J. and Le, H. (2018),“Wireless towers and home values: an alternative valuation approach using a spatial econometric analysis”,The Journal of Real Estate Finance andEconomics,Vol.56No.4,pp.653-676. 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Filippova, O. and Rehm, M. (2014),“CPTBS and house prices in New Zealand: economic effects and policy implications”,International Journal of Housing Markets and Analysis,Vol.7 No. 1, Gillwald, A. (2005),“Good intentions, poor outcomes: Telecommunications reform in South Africa”, TelecommunicationsPolicy,Vol.29No.7,pp.469-491. GSMA (2014),“Tower power Africa: energy challenges and opportunities for the mobile industry in Africa”, available at:www.gsma.com/mobilefordevelopment/wp-content/uploads/2014/11/ Africa-Market-Report-GPM-final.pdf (accessed19September2022). Hamilton, S.W. and Schwann, G.M. (1995),“Do high voltage electric transmission lines affect property value?”,LandEconomics,Vol.71No.4,pp.436-444. Henry,L. (2019),“South Africa telecoms infrastructure, operators, regulations –statisticsand analyses”, available at:https://www.prnewswire.com/news-releases/south-africa—telecoms-infrastructure- operators-regulations—statistics-and-analyses-300554872.html (accessed:26August2022). Hodge,J.(2004),“Universal service through roll-out targets and licence conditions: lessons from telecommunications in South Africa”,Development Southern Africa, Vol. 21 No. 1, pp. 205-225. Ihlanfeldt, K. and Mayock, T. (2010),“Panel data estimates of the effects of different types of crime on housingprices”,RegionalScienceandUrbanEconomics,Vol.40No.2-3,pp.161-172. Jeff (2009),“How stuff works –CPTBS”, available at:https://technogog.com/information/how-stuff- works-cell-phone-towers/(accessed,23September2022). KMB (2015),“Diverse types of telecom tower designs. What design is right for you?”, available at: www.kmbdg.com/news/different-types-telecom-towers-design-right-site/(accessed, 23 September2022). Locke, S.L. and Blomquist, G.C. (2016),“The cost of convenience: Estimating the impact of communication antennas on residential property values”,Land Economics, Vol. 92 No. 1, pp. 131-147. Makhaya, G. and Roberts, S. (2003),“Telecommunications in developing countries: reflections from the SouthAfricanexperience”,TelecommunicationsPolicy,Vol.27No.1-2,pp.41-59. Mpwanya, M.F. and Letsoalo, M.E. (2019),“Relationship between service quality, customer satisfaction and behavioural intentions in South Africa’s mobile telecommunication industry”,African JournalofBusinessandEconomicResearch,Vol.14No.2,p.67. Olukolajo, M.A., Ezeokoli, N.B. and Ogungbenro, M.T. (2013),“Locational effect of GSM mast on neighbouring residential properties’rental values in Akure, Nigeria”,Academic Journal of InterdisciplinaryStudies,Vol.2No.3,p.147. Randburg Sun (2017),“Is public participation required for cell mast installation?”, available at:https:// randburgsun.co.za/331073/public-participation-required-cell-mast-installation/(accessed, 22 September2022). Rajapaksa, D., Athukorala, W., Managi, S., Neelawala, P., Lee, B., Hoang, V.N. and Wilson, C. (2018), “The impact of cell phone towers on house prices: evidence from Brisbane, Australia”, EnvironmentalEconomicsandPolicyStudies,Vol.20No.1,pp.211-224. Impact of proximity 1441 Downloaded from http://www.emerald.com/ijhma/article-pdf/17/6/1422/9471207/ijhma-12-2023-0167.pdf by guest on 30 March 2026 Page 287 of 473 Reichert, A.K. (1997),“Impact of a toxic waste superfund site on property values”,The Appraisal Journal,Vol.65No.4,p.381. Rosen, S. (1974),“Hedonic prices and implicit markets: product differentiation in pure competition”, JournalofPoliticalEconomy,Vol.82No.1,pp.34-55. RSA(1996),“Telecommunicationsact,1996no.103of1996”,GovernmentPrinter,Pretoria. Sirmans, S., Macpherson, D. and Zietz, E. (2005),“The composition of hedonic pricing models”,Journal ofRealEstateLiterature,Vol.13No.1,pp.1-44. Sims, S. and Dent, P. (2005),“High-voltage overhead power lines and property values: a residential studyintheUK”,UrbanStudies,Vol.42No.4,pp.665-694. Smaqae, A.A. and Anwar, A.L.M.M. (2022),“Analysis of the impact of the presence of mobile phone towers on houses’prices in the city of Erbil 2021”,Tikrit Journal of Administration and EconomicsSciences,Vol.18No.57Part2. Stats, S.A. (2019),“Four facts about the post and telecommunication industry”, available at:www.statssa. gov.za/?p¼14668#::text¼The%20telecommunications%20sector%20dominates%20the,accounted %20for%20the%20remaining%205%25(accessed,27 September 2022). Steel in the air (2024),“Types of cell towers”, available at:www.steelintheair.com/cell-phone-tower/ (accessed,23September2022). Strand, J. and Vågnes, M. (2001),“The relationship between property values and railroad proximity: a study based on hedonic prices and real estate brokers’appraisals”,Transportation, Vol. 28 No.2,pp.137-156. Szmigielski, S. and Sobiczewska, E. (2000),“Cellular phone systems and human health–problems with risk perception and communication”,Environmental Management and Health, Vol. 11 No. 4, pp.352-368. Thornton,L.,Carrim,Y.,Mtshaulana,P.and Reyburn,P.(2006),“Telecommunications lawin South Africa”. XHTower(2024),“Xinhangtower”,availableat:www.xhtower.com/(accessed,15November2022). Yahya, S.I. (2019),“The use of camouflaged cell phone towers for a quality urban environment”,UKH JournalofScienceandEngineering,Vol.3No.1,pp.29-34. Further reading Aliyu, A.A., Monday, I. and Adamu, H. (2024),“Impact of cellular phone-base station towers on residentialpropertyvalueinBauchimetropolis”. Geocaching (2012),“Disguised CPTBS # 5”, available at:www.geocaching.com/geocache/ GC3BP2T_disguised-cell-phone-tower-5?guid=af8ee79e-1204-460d-92c4-4a1c41fd04a5 (accessed 23September2022). Corresponding author Koech Cheruiyot can be contacted at: kenneth.cheruiyot@wits.ac.za For instructions on how to order reprints of this article, please visit our website: www.emeraldgrouppublishing.com/licensing/reprints.htm Or contact us for further details:permissions@emeraldinsight.com IJHMA 17,6 1442 Downloaded from http://www.emerald.com/ijhma/article-pdf/17/6/1422/9471207/ijhma-12-2023-0167.pdf by guest on 30 March 2026 Page 288 of 473 RESEARCH Science and Policy BRIEF C E L L T O W E R S D R O P P R O P E R T Y V A L U E S WOULD YOU BUY A HOME NEAR A CELL TOWER? Realtor Evidence and Published Research on Market Impacts RESEARCH Science and Policy BRIEF Wireless and EMF Program Environmental Health Sciences EHSciences.org “While the magnitude of the impact varies, the studies uniformly indicate that there is a signif icant impact on residential property values f rom installation of cell phone towers…” -Report and Declaration for the Smart Communities Siting Coalition by David E. Burgoyne, ASA, SR/WA Certif ied General Real Estate Appraiser Realtors say visible towers can cut home values by up to 20%, with surveys showing 94% of buyers say they would pay less or avoid such properties. Regulatory filings to the FCC by counties and coalitions representing over 1,800 communities warn of cell towers’ significant negative impacts on aesthetics and property values. Peer-reviewed studies across the U.S., Australia, and South Africa find statistically significant price declines near towers. Realtors on Cell Towers Near Homes “Buyers are extremely hesitant to purchase homes located near cell towers, and in many cases, homes next to towers take longer to sell and ultimately sell for less.” “In my professional experience, a visible cell tower in close proximity to a property can reduce its value by as much as 20%.” “As realtors working in this market, we consistently see that towers negatively impact demand, creating stigma that directly translates into lower property values.” Oakland, MI Realtor Letters Wappinger, NY Realtor Letters Text is hyperlinked to source Page 289 of 473 RESEARCH Science and Policy BRIEF Wireless and EMF Program Environmental Health Sciences Text is hyperlinked to source RESEARCH Science and Policy BRIEF EHSciences.org “Cellphone towers bring extra tax revenue and better reception to a section of the city, but many are skeptical because of the potential health risks and the impact on property values. Increasing numbers of people don’t want to live near cell towers. In some areas with new towers, property values have decreased by up to 20%.” - National Business Post, “Your new neighbor, a cell tower, may impact the value of your home” "An overwhelming 94 percent of home buyers and renters sur veyed by the National Institute for Science, Law & Public Policy (NISLAPP) say they are less interested and would pay less for a property located near a cell tower or antenna." "Of the 1,000 survey respondents, 79% said that under no circumstances would they ever purchase or rent a property within a few blocks of a cell tower or antennas, and almost 90% said they were concerned about the increasing number of cell towers and antennas in their residential neighborhood.” - REALTOR Magazine, "Cell Towers, Antennas Problematic for Buyers" “Wireless companies are installing boxes in front of homes as part of their 5G network rollout. But homeowners aren’t pleased, calling the chest freezer– sized boxes a big eyesore in their front yards.” “Wireless companies do not need to get permission from homeowners before installing the boxes. They don’t even need to notify them beforehand because the boxes are installed on a public right-of-way. This land is owned by the county, even if it does appear in a person’s front yard.” - National Association of Realtors Magazine, “Homeowners Complain About ‘Ugly’ 5G Boxes in Their Yards” REALTORS ON CELL TOWERS Page 290 of 473 RESEARCH Science and Policy BRIEF Wireless and EMF Program Environmental Health Sciences Text is hyperlinked to source RESEARCH Science and Policy BRIEF EHSciences.org In 2017, a coalition of over 1800 local governments known as the Smart Communities Siting Coalition sued to oppose the FCC’s decision to fast track the installation of small cell infrastructure, stripping local authorities of much of their decision-making power. In their filings, the Coalition highlighted the detrimental impacts of cell towers and small cells on nearby property values. “Smart Communities provided an expert analysis to highlight for the Commission the potential impacts of wireless facilities on adjoining property values. Burgoyne concludes many deployments of small cells could affect property values, with significant potential effects.” - Reply Comments of Smart Communities Siting Coalition (representing local governments and associations from 1,854 communities), WT Docket No. 16-421 "Considering that the Smart Communities’ prior filings show that the addition of facilities of this size diminish property values, it is strange for the Commission to assume that approval can be granted in the regulatory blink of an eye…." "...allowing poles to go up in areas where poles have been taken down has significant impacts on aesthetics (not to mention property values).” - Ex Parte Submission of Smart Communities Siting Coalition Letter to Ms. Marlene H. Dortch, Secretary, FCC, WT Docket No. 16-421 “There has been significant research regarding the question of the impact on residential property values from construction of cell phone towers in neighborhoods. The results of these studies vary but they commonly indicate that there is a significant impact. While the magnitude of the impact varies, the studies uniformly indicate that there is a significant impact on residential property values from installation of cell phone towers. Not surprisingly, the studies that show little or no impact are universally commissioned by and paid for by the telecommunications industry.” - Report and Declaration of David E. Burgoyne, ASA, SR/WA, “Impact of Communication Towers and Equipment on Nearby Property Values,” in WT Docket No. 16-421 REGULATORY FILINGS BY CITIES AND MUNICIPALITIES Page 291 of 473 RESEARCH Science and Policy BRIEF Wireless and EMF Program Environmental Health Sciences The impact of cell phone towers on house prices: evidence from Brisbane, Australia by Rajapaksa, D. et al. Environmental Economics and Policy Studies (2018). “Property transaction data collected from two suburbs within the Brisbane City Council were analysed adopting the spatial hedonic property valuation model. The estimated models were statistically significant and were largely in line with theoretical expectations. The results revealed that proximity to cell phone towers negatively affects house values, decreasing as the distance from the tower increases. A suitable compensation programme for nearby property owners is, therefore, suggested as being an appropriate policy response.” Impact of proximity to cell phone tower base stations on residential property prices in the City of Johannesburg, South Africa by Cheruiyot, K. et al. International Journal of Housing Markets and Analysis (2024). “Findings: The results show a significant impact that proximity of [cell phone tower base stations (CPTBS)] has on residential property sale prices. However, the impact of CTPBSs’ proximity on residential property prices depends on their distance from the residential properties. The closer a residential property is to the CTPBS, the greater the impact that the CTPBS will have on the selling price of the residential property.” Wireless Towers and Home Values: An Alternative Valuation Approach Using a Spatial Econometric Analysis by Affuso, E. et al. Journal of Real Estate Finance and Economics (2018). “For properties located within 0.72 kilometers of the closest tower, results reveal significant social welfare costs with values declining 2.46% on average, and up to 9.78% for homes within tower visibility range compared to homes outside tower visibility range; in aggregate, properties within the 0.72-kilometer band lose over $24 million dollars.” The Cost of Convenience: Estimating the Impact of Communication Antennas on Residential Property Values by Locke, S. & Blomquist, G. Land Economics (2016). “We take advantage of a rich dataset of residential housing sales from central Kentucky that contains an extensive set of structural housing characteristics and precise location information. This allows us to overcome endogeneity issues caused by unobservable characteristics correlated with antenna location. The best estimate of the impact is that a property with a visible antenna located 1,000 feet away sells for 1.82% ($3,342) less than a similar property located 4,500 feet away. The aggregate impact is $10.0 million for properties located within 1,000 feet. (JEL Q51, R21)” The effect of distance to cell phone towers on house prices (Florida case study) by Bond, S. The Appraisal Journal (2007). “The research on the possible effect of cell towers on property values is extensive. In general, proximity to a cell tower appears to have a negative effect on property values. A study from the University of South Alabama analyzed over 23,000 home sales in Mobile County, Alabama relative to their proximity to cell towers. The researchers found that homes within 0.72 km of a cell tower decreased in value an average of 2.65%. In addition, if the cell tower was visible from the property, then the properties decreased an average of 9.78%. A similar study in Kentucky found that properties within 1,000 feet of a cell tower sold for 1.82% less than a similar property located 4,500 feet away.” EHSciences.org Text is hyperlinked to source RESEARCH Science and Policy BRIEF CELL TOWERS DROP PROPERTY VALUE Published Analysis Page 292 of 473 Page 293 of 473 Page 294 of 473 Page 295 of 473 From:Corey Gaffer To:Sarah Madden Subject:Proposed Cell Tower Date:Tuesday, March 31, 2026 8:24:38 AM You don't often get email from corey@gafferphotography.com. Learn why this is important Hi Sarah, I am writing to express both support for and concerns about the proposed cell tower. I support improved cell phone coverage in the area due to significant safety concerns and the impact that poor service can have on property values. However, I am opposed to the current proposal for a 149-foot tower because of its potential negative impact on the character and visual appeal of the area, particularly given its design, height, and location. I support the tower because I live in a dead zone near Wentworth Park. Poor cell service inside homes can negatively affect property values, as modern homebuyers increasingly view reliable cell service as essential. Additionally, this dead zone presents serious safety concerns for families. My family relies on Wi-Fi calling, but during power or internet outages, that service becomes unavailable, leaving us without a reliable way to contact emergency services. With landline costs rising and relying on outdated infrastructure, that option is often impractical for many families. This concern is further compounded by the lack of investment in underground fiber optics, which increases the likelihood of internet outages. Finally, the dead zone creates daily challenges when interacting with visitors to the area who struggle to communicate or access information. I am opposed to the 149-foot tower as currently proposed because I believe the design and location should be reconsidered. From my understanding, a tower of this height is uncommon in such close proximity to urban areas. Are there shorter alternatives, or could two smaller towers provide similar coverage? Could the tower be designed to be less visually obtrusive? Additionally, there are existing towers in the area—could Verizon utilize or co-locate on existing infrastructure? Is there an opportunity to partner with Xcel Energy and place the tower on property where utility infrastructure already exists (44.9031, -93.1305)? While I am not an expert, placing a tower of this size in a cherished area seems like a poor choice. Thank you for your consideration. Corey Gaffer 671 2nd Ave. Mendota Heights, MN 55118 Page 296 of 473 You don't often get email from eurekalmo@aol.com. Learn why this is important From:Ryan Ruzek To:Sarah Madden Subject:FW: Opposed to Wentworth cell tower Date:Tuesday, March 31, 2026 10:56:44 AM FYI I did let Leona know we received her comment. Thanks, Ryan From: eurekalmo@aol.com <eurekalmo@aol.com> Sent: Tuesday, March 31, 2026 10:54 AM To: Ryan Ruzek <RRuzek@mendotaheightsmn.gov> Subject: Fw: Opposed to Wentworth cell tower Please forward this email to the MHts Planning commission. I couldn't find the names of members to send this email to. Thanks. Leona Opp ----- Forwarded Message ----- From: eurekalmo@aol.com <eurekalmo@aol.com> To: slorberbaum@mendotaheightsmn.gov <slorberbaum@mendotaheightsmn.gov>; slevine@mendotaheightsmn.govj <slevine@mendotaheightsmn.govj>; maczko@mendotaheightsmn.gov <maczko@mendotaheightsmn.gov>; jmazzitello@mendotaheightsmn.gov <jmazzitello@mendotaheightsmn.gov>; jpaper@mendotaheightsmn.gov <jpaper@mendotaheightsmn.gov> Sent: Tuesday, March 31, 2026 at 10:49:18 AM CDT Subject: Opposed to Wentworth cell tower As a frequent user of Wentworth Park and nearby resident for the last 30 years, I am opposed to constructing a cell tower in the park. The cell tower would ruin one of the few remaining natural places left in our urban area. This current park environment increases property values in our area. A cell tower does not belong in a densely populated area. Please say NO to the cell tower. An alternative would be to place the cell tower on open land in the MHts city administration building area. Other alternatives would be to put it in areas zoned as Page 297 of 473 commercial property and not on city or county property. Mendota Heights city would lose the rental payments but the residents would retain a natural park that can't be replaced. Thanks Leona Opp 789 Evergreen Knolls Mendota Heights, MN 55118 Page 298 of 473 From:Kevin Byrnes To:Sarah Madden Cc:Cheryl Jacobson Subject:Written comments 3/31/26 Planning Commission meeting Date:Monday, March 30, 2026 8:52:39 PM Attachments:KJB Written Testimony.pdf KJB Attachment A.pdf [You don't often get email from kevin@indevu.com. Learn why this is important at https://aka.ms/LearnAboutSenderIdentification ] I apologize for not sending these sooner but I just returned from spring break over the weekend to find the notice about the meeting in my mail. I’d like the attached to be submitted into the public record. If I need to bring paper copy into the meeting or if there is a protocol I need to follow to submit these digitally, let me know. I just want to be sure they are part of the official record even if I don't get a chance to speak or touch on everything if I do. Sarah - It seemed like you are the person I am supposed to send these to. Cheryl - cc-ing you since we go way back to my airport relations commission days! Anyway, let me know if I am good to go on having these submitted officially. Kevin Page 299 of 473 March 30, 2026 City of Mendota Heights Planning Commission 1101 Victoria Curve Mendota Heights, Minnesota 55118 Re: Written Testimony in Connection with Planning Case No. 2026-05 Conditional Use Permit Application of Buell Consulting, Inc. on Behalf of The Towers, LLC — 739 Wentworth Avenue (Wentworth Park) To the Mendota Heights Planning Commission: I am a property owner at 740 Wentworth Avenue, Mendota Heights, Minnesota 55118, directly across the street from the proposed tower site at Wentworth Park. I respectfully submit this written testimony for inclusion in the permanent public record for Case No. 2026-05, and request that it be considered by both the Planning Commission and the City Council. I do not oppose improved wireless coverage in Mendota Heights. The need for better cellular infrastructure in this community is genuine. My concerns are specific to this application, this location, and several significant gaps in the record that must be addressed before this Commission makes any recommendation. I received the notice for the hearing upon returning from a spring break trip and while I have spent considerable time on the issue today, I want to make it clear in advance that I may have some faulty cites or errors in this document – it was a lot to dig through in a day. I was also hampered by the fact that the Mendota Heights Laserfiche link was not working. I received error messages every time I tried to access it. I mention that because there may be documentation that addresses some of my concerns from council or planning commission meetings over the last 5 years that I was not able to access. Regardless, everything I discuss below warrants inclusion in the record for this CUP application and not simply by general reference to poor cellular overage being a long- standing issue in Mendota Heights. My sense from conversations yesterday and today is that many of the residents in the vicinity who are most impacted by the construction of the tower feel a bit caught off guard by a scenario where a notice is mailed around March 21, public comments for a planning commission meeting are scheduled for March 31, and should the CUP request move on to the city council they will be voting on April 7th. It is a quick timetable for a significant project. Staff outlined three options for you in their memo in your meeting packet. I believe the only responsible choice is option three: Table the request and request additional information from staff and/or the applicant; Staff will extend the review period an additional 60 days, in compliance with Minnesota State Statute 15.99. I. The Regulatory Framework for This Proposal Gives The Appearance That It Was Designed to Produce This Outcome - Which Makes Genuine Due Diligence on Alternate Sites Essential Page 300 of 473 Before addressing the specific deficiencies in this application, I ask the Commission to consider the broader context in which it was developed, because that context bears directly on whether the alternate site analysis can be taken at face value. Until January 1, 2025, freestanding wireless towers were prohibited in Mendota Heights' R-1 residential districts entirely. It was that prohibition that caused the prior Wentworth Park tower proposal (filed in 2006 at the same location) to fail. The city council at that time voted unanimously to end lease negotiations, and the applicant withdrew. The January 2025 zoning code update changed that in three specific ways that are directly relevant to this proposal: 1. It created, for the first time, a CUP pathway for freestanding wireless towers up to 150 feet in all base zoning districts, including R-1 Residential. 2. It set the maximum allowable height at exactly 150 feet — and the proposed tower is 149 feet, one foot below that cap. 3. It established a stated preference for siting towers on municipal property and Public/Semi- Public uses if Industrial/Business zoned locations are not viable - a preference that points directly at city-owned parks and public facilities. I am not privy to the work that may have been done as part of the code changes but in notes from an August 2025 City Council working session there was a cell phone tower discussion that began with the following introduction: Public works director Ruzek reported that the city was approached by a representative from a third party consultant to install a new cellular tower at Wentworth Park. There was discussion at the meeting, but not of a particularly detailed nature. From there the topic makes appearances in various meetings and agendas, but the discussions seem to focus more on terms of the lease than the fundamental issues that I discuss below. As I mentioned at the outset, I may have missed something either through oversight or an inability to search older records. The three features described above and the rather perfunctory movement through city council agendas makes it feel as though the three changes in the code noted above were a regulatory framework constructed to enable precisely this type of project at precisely this type of location. Mayor Levine has stated in council meeting notes that the city has been working toward this goal for approximately five years - a timeline that aligns with the period over which the zoning code update was developed and adopted. I am not suggesting this was improper. Cities update their zoning codes in response to evolving needs. My point is narrower: when the regulatory framework was designed with this type of project in mind, an alternate site analysis conducted within that framework cannot be presumed to have been a neutral, open-ended inquiry. It presents a circular logic problem. An alternate site evaluation conducted after the city had already spent years concluding it wanted a tower on city-owned land, and after the zoning code was updated to specifically prefer municipal property, is not the same as an evaluation that started from scratch. If the criteria for site selection were shaped by a conclusion the city had already reached, the analysis would naturally tend to confirm that conclusion rather than genuinely test it. This is Page 301 of 473 precisely why the full alternate site analysis must be placed into the public record where it can be independently scrutinized. The Commission should require that the complete alternate site analysis (every site considered, every criterion applied, every reason for rejection) be placed into the record and evaluated on its merits. That is the minimum showing required under the Telecommunications Act of 1996, which mandates that a carrier demonstrate its proposal is the least intrusive means of addressing a coverage gap. II. The Process Sequence Reinforces Concerns About Predetermination On February 4, 2026 (approximately eight weeks before this public hearing) the Mendota Heights City Council approved Resolution 2026-09, entering into an Option and Lease Agreement with The Towers, LLC for use of Wentworth Park as the tower site. That vote preceded this public hearing process. My understanding is that standard practice in wireless tower permitting would have zoning approval precede lease negotiations. The reversal of that sequence here compounds the concern raised in Section I. The city did not merely conduct an alternate site analysis that may have been framed to favor this outcome, it then committed to the outcome contractually, as landlord, before this Commission had any opportunity to evaluate whether the use is appropriate. A federal court addressed this precise situation in Vertical Bridge Development, LLC v. City of Brawley (E.D. Cal. 2023), in which the same company (Vertical Bridge) signed a nearly identical park lease option before applying for a CUP. When the city subsequently denied the permit following a public hearing, Vertical Bridge argued the prior lease proved the denial was pretextual. The court rejected that argument and upheld the denial, finding that signing a lease does not obligate a city to approve a CUP and that zoning authority remains fully intact notwithstanding a pre-existing lease. This Commission has an opportunity, and an obligation, to ensure that the record developed tonight is sufficient to independently support whatever findings are made, not simply to ratify decisions that were effectively made elsewhere. III. The RF Analysis Is Inadequate and Fails to Establish a Genuine Coverage Gap That Requires This Tower For the reasons described in Sections I and II, the factual basis for this proposal requires rigorous scrutiny. Verizon's RF analysis, as submitted, is minimal and lacks the detail necessary to support the findings this Commission is required to make. Three specific deficiencies must be addressed on the record. A. The RF Analysis Does Not Distinguish Between Outdoor and Indoor Coverage Verizon's coverage materials do distinguish between outdoor/in-vehicle coverage and indoor/in- building coverage beyond a simple map. This distinction is legally and factually critical. The Telecommunications Act's effective prohibition provision was designed to protect the ability of mobile users moving through an area to access the telephone network - not to guarantee cellular signal strength inside private residences. Page 302 of 473 Based on available coverage mapping provided by Verizon, the gap area in question in Mendota Heights appears to have adequate outdoor and in-vehicle Verizon coverage. If the identified gap is primarily an indoor coverage issue (signals that cannot penetrate building materials) that is a materially different and weaker claim than a true outdoor coverage gap. Indoor coverage deficiencies are common across virtually all cellular networks everywhere in the country, and they do not typically justify new tower construction of this scale and intrusiveness. I request that the Commission require the applicant to provide separate RF propagation maps clearly distinguishing outdoor coverage from indoor coverage, and to specify whether the claimed "significant service capacity gap" is an outdoor, indoor, or mixed phenomenon. B. WiFi Calling Is a Less Intrusive Technological Alternative That Verizon Itself Provides And The Application Does Not Explain Why It Is Inadequate If the coverage gap in question is primarily indoor, affecting residents making calls from inside their homes, then a less intrusive technological solution already exists, provided by Verizon at no charge: WiFi calling. WiFi calling allows Verizon customers to route cellular calls seamlessly through a home WiFi network when cellular signal is insufficient. It requires no new infrastructure, no new equipment, and no cost to the user. It is supported natively on all current iPhones and Android smartphones. In a residential neighborhood like Mendota Heights, where virtually every home has broadband internet and a WiFi router, WiFi calling already provides a functional solution to the indoor coverage problem Verizon has identified. I use it myself as I have never had, or expected, good cell service in my basement. Verizon actively promotes WiFi calling as a solution for customers experiencing weak indoor coverage. The fact that Verizon itself markets this technology as a remedy for the precise problem it is now citing as justification for a 149-foot tower in a neighborhood park represents a direct contradiction that the Commission should require the applicant to address on the record. Under the Telecommunications Act of 1996, a carrier seeking to overcome a local zoning decision must demonstrate that its proposed facility is the least intrusive means of addressing a genuine coverage gap. If WiFi calling (a technology Verizon already provides at no cost) adequately addresses indoor coverage needs for residents of Mendota Heights, then a 149-foot monopole in a neighborhood park is not the least intrusive means of solving the problem. It is the most intrusive means of solving a problem that already has a less intrusive solution. The application must explain specifically why WiFi calling is inadequate before this standard can be met. I request that the Commission require the applicant to explain on the record, with specificity, why WiFi calling does not adequately address the indoor coverage gap it has identified in Mendota Heights, and why a large freestanding tower is the least intrusive means of addressing that gap given the widespread availability of home WiFi in this residential community. C. The Application Refers To Coverage Gaps and Capacity Deficiencies - Two Distinct Justifications That Carry Different Legal Weight Verizon's application describes customers experiencing both "dropped calls" and "slower data speeds" as symptoms of the identified problem. These are fundamentally different issues requiring different analysis. Dropped calls indicate a genuine coverage deficit - the signal is too weak to sustain a connection. This is the type of gap that the Telecommunications Act was designed to address through new infrastructure. Page 303 of 473 Slower data speeds, however, indicate a capacity issue. More users are competing for available bandwidth than the existing infrastructure can efficiently serve. This is not a coverage gap in the traditional legal sense. It is a network optimization challenge. The distinction matters because the legal standard for justifying new tower construction is substantially higher for capacity improvements than for genuine coverage gaps. This is particularly true under the "significant gap" test that the Eighth Circuit applies in this jurisdiction. Furthermore, for residents experiencing slow cellular data speeds at home, an immediate and free solution already exists: their home WiFi. Verizon's own broadband service competes with Xfinity in Mendota Heights precisely because home WiFi provides faster and more reliable data than cellular for stationary indoor use. I request that the Commission require the applicant to clearly distinguish between dropped call incidents (a coverage issue) and slow data speed complaints (a capacity issue) in its RF documentation, and to provide objective evidence (including drive test data and complaint records) supporting each category of claimed deficiency separately. IV. The Proposed Location Is Incompatible with the Primary Purpose of Wentworth Park Wentworth Park is a 10.5-acre municipal park serving as one of this community's primary year- round recreational spaces, with a youth softball field, hockey rink, six pickleball courts, two tennis courts, a basketball court, a playground, a pond with walking trails, and two picnic shelters. The proposed 50-by-50-foot fenced compound and 149-foot monopole would introduce permanent commercial wireless infrastructure into the center of this recreational space. The visual dominance of a nearly 150-foot industrial structure over an active neighborhood park with playgrounds and athletic facilities raises legitimate compatibility concerns under the applicable CUP standards. I ask the Commission to make specific written findings regarding the compatibility of this use with the park's primary recreational purpose, the surrounding R-1 residential character, and the visual impact on adjacent properties, including my own at 740 Wentworth Avenue. V. The FAA Aeronautical Determination Has Not Been Disclosed I believe Wentworth Park is located less than 4 miles from the nearest runway end at Minneapolis- St. Paul International Airport. At this distance, the proposed structure likely falls within the FAA's protected airspace zone under 14 CFR Part 77, and the filing of FAA Form 7460-1 is almost certainly required. The application materials do not confirm whether this form has been submitted or what aeronautical determination has been issued. The materials only mention that no lighting is planned unless required by FAA or FCC. The FAA retains discretion to require obstruction lighting on structures below 200 feet near active airport approaches. If aviation beacon lighting is required, a flashing light atop a 149-foot structure in a residential neighborhood park would significantly increase the tower's impact on surrounding properties. Knowing whether there will be a light required on the top of the pole is critical to performing the required impact analysis in a residential neighborhood - it cannot be addressed by saying “there won’t be a light unless we are required to have one.” I request that the FAA's aeronautical determination, including any required lighting or marking specifications, be placed into the record before this Commission makes any final recommendation. Page 304 of 473 VI. Questions the Commission Should Require the Applicant to Answer on the Record Before this Commission takes any action on Case No. 2026-05, I respectfully request that the applicant be required to respond on the record to the following questions. Each goes directly to whether the applicable CUP standards are met. A. Alternate Site Analysis 1. Can you provide the complete alternate site analysis - listing every location evaluated, every criterion applied, and the specific documented reason each was rejected - and submit it as part of the public record? 2. Were any existing structures (rooftops, water towers, church steeples, or existing monopoles) evaluated as co-location alternatives? If so, which, and why were they rejected? 3. Were other city-owned properties, including the water tower and the existing monopole on Northland Drive at Highway 55, evaluated as alternate sites? If so, why were they rejected? 4. What criteria were used to evaluate candidate sites, and when were those criteria established relative to the January 2025 zoning code update? B. RF Analysis, Coverage vs. Capacity, and WiFi Calling 1. Can you provide separate RF propagation maps showing (a) outdoor/in-vehicle coverage and (b) indoor/in-building coverage? Is the identified gap primarily outdoor, indoor, or both? 2. Of the customer complaints cited to justify this tower, how many reflect dropped calls (a coverage issue) as distinct from slow data speeds (a capacity issue)? Please provide objective data (drive test results or complaint records) for each category. 3. Verizon offers WiFi calling at no charge on all current iPhones and Android smartphones, and actively promotes it as a solution for customers with weak indoor coverage. Why does WiFi calling not adequately address the indoor coverage gap you have identified in Mendota Heights? Please explain specifically, given that virtually every home in this residential neighborhood already has broadband WiFi. 4. Why is a 149-foot freestanding monopole the least intrusive means of addressing the identified gap, rather than WiFi calling for indoor needs combined with small cells or distributed antenna systems for any remaining outdoor gaps? C. FAA and Aviation 1. Has FAA Form 7460-1 been submitted? What is the aeronautical determination, and is obstruction lighting required or recommended? 2. If lighting is required, what type, at what intensity, and with what operational schedule? D. Visual Impact and Design 1. Will the tower use a stealth or camouflage design? If not, why not? Note on Attachment A: A complete set of documented questions, each with an explanatory note on its legal relevance, is submitted as Attachment A to this testimony. I respectfully request that both this testimony and Attachment A be made part of the permanent record for Case No. 2026-05. I appreciate this Commission's careful consideration of these concerns. The questions raised here are not a reflexive objection to wireless infrastructure. They are a request that a process that has Page 305 of 473 shown signs of predetermination be held to the standard of genuine, documented, publicly verifiable due diligence that the law requires. I respectfully request that this testimony and its attachment be made part of the permanent public record for Case No. 2026-05. I am asking that a full analysis be conducted and shared with the public with adequate time for residents to respond and engage on the topic. I am hopeful that you will pursue the third option City staff presented you with in your meeting materials: Table the request and request additional information from staff and/or the applicant; Staff will extend the review period an additional 60 days, in compliance with Minnesota State Statute 15.99. Respectfully submitted, ________________________________ Kevin Byrnes 740 Wentworth Avenue Mendota Heights, MN 55118 Attachment A: Questions for the Applicant (submitted separately) Page 306 of 473 March 30, 2026 City of Mendota Heights Planning Commission 1101 Victoria Curve Mendota Heights, Minnesota 55118 Re: Attachment A to Written Testimony of Kevin Byrnes Questions for the Applicant — Planning Case No. 2026-05 To the Mendota Heights Planning Commission: This document is submitted as Attachment A to the written testimony of Kevin Byrnes, 740 Wentworth Avenue, Mendota Heights, MN 55118, in connection with Planning Case No. 2026-05. The questions below are submitted as a formal request that this Commission require the applicant to answer each question on the record - either at tonight's hearing or in supplemental written materials submitted prior to City Council action on April 7, 2026. Each question identifies information directly relevant to whether the applicable CUP standards have been met. Questions that go unanswered, or receive inadequate answers, are part of the evidentiary record and bear on whether the Commission's findings can be sustained on review. How to Read This Document Each question is followed by a brief note explaining its legal relevance to the CUP standards under City Code Section 12-3B-5-B.7 and, where applicable, the federal Telecommunications Act of 1996. These notes are provided for the Commission's reference and are part of the public record. Category 1: Alternate Site Analysis Q1. Can you provide the complete alternate site analysis - listing each location evaluated, the criteria applied, and the specific documented reason each was rejected and submit it as part of the public record? ▶ Why this matters: Federal courts require that a carrier demonstrate its proposed site is the 'least intrusive means' of addressing a coverage gap. Without a disclosed alternate site analysis, that showing has not been made on the record. Q2. Were any existing structures (rooftops, water towers, church steeples, utility poles, or existing monopoles) evaluated as co-location alternatives to a new freestanding tower? If so, which specific structures, and why was each rejected? ▶ Why this matters: Co-location on existing structures is generally less intrusive than a new freestanding monopole in a residential park. Failure to document consideration of co-location weakens the least-intrusive-means showing. Q3. Were other city-owned properties specifically evaluated as alternate sites, including the Mendota Heights water tower, the existing monopole on Northland Drive at Highway 55, and any other city-owned commercial or institutional properties? If so, why were they rejected? Page 307 of 473 ▶ Why this matters: The January 2025 zoning code established a preference for municipal property if business industrial areas are not viable. If multiple city-owned sites were available, the record should explain why Wentworth Park was selected over less intrusive options. Q4. What criteria were used to evaluate and rank candidate sites? Were those criteria developed independently by Verizon, or in consultation with city staff? When were they established relative to the January 2025 zoning code update? ▶ Why this matters: If the evaluation criteria were developed after, or in parallel with, the zoning code change that preferred municipal property, it raises a legitimate question about whether the analysis was designed to confirm a predetermined conclusion. Q5. Mayor Levine has stated publicly that the city looked at 'different locations.' Can you identify those locations for the record and confirm whether they were evaluated by the applicant, the city, or both? ▶ Why this matters: The mayor's statement is already part of the public record. The applicant should be able to confirm or elaborate on what sites were evaluated. Category 2: RF Analysis, Coverage vs. Capacity, and WiFi Calling Q6. Can you provide separate RF propagation maps clearly distinguishing outdoor/in- vehicle coverage from indoor/in-building coverage in the identified gap area? Is the primary deficiency an outdoor coverage gap, an indoor coverage gap, or a capacity limitation? ▶ Why this matters: The Telecommunications Act's 'effective prohibition' provision is primarily concerned with outdoor mobile coverage - the ability of users moving through an area to access the network. Indoor coverage gaps carry different and generally weaker legal weight. If the gap is primarily indoor, the justification for this tower is substantially weaker. Q7. Of the customer complaints and service issues cited to justify this tower, how many reflect dropped calls as distinct from slow data speeds? Please provide objective supporting data (drive test results, dropped call logs, or complaint records) for each category separately. ▶ Why this matters: Dropped calls represent a genuine coverage gap. Slow data speeds represent a capacity or congestion issue. These are legally and factually distinct: the threshold for justifying new tower construction is substantially higher for capacity improvements than for genuine coverage gaps under the Eighth Circuit's analysis of the TCA. Q8. Verizon offers WiFi calling at no charge on all current iPhones and Android smartphones, and Verizon actively promotes it as a solution for customers experiencing weak indoor cellular coverage. Why does WiFi calling not adequately address the indoor coverage gap you have identified in Mendota Heights? Please explain specifically, given that virtually every home in this residential neighborhood already has broadband internet and WiFi. ▶ Why this matters: WiFi calling is a less intrusive technological alternative that Verizon itself provides. The 'least intrusive means' standard requires that carriers consider and explain why less intrusive solutions are inadequate before justifying a large freestanding tower. A carrier cannot claim a coverage gap requires a 149-foot tower while simultaneously offering a no-cost technology that addresses the same gap — without explaining the contradiction. Q9. Why is a 149-foot freestanding monopole the least intrusive means of addressing the identified gap, rather than a combination of (a) WiFi calling for indoor residential coverage, (b) small cells or distributed antenna systems for any remaining outdoor gaps, and (c) co- location upgrades on existing structures? Page 308 of 473 ▶ Why this matters: Under the least-intrusive-means standard, the carrier bears the burden of demonstrating that less intrusive alternatives are insufficient. The application does not address this standard with respect to WiFi calling or distributed antenna alternatives. Q10. For residents who currently experience dropped calls inside their homes, does Verizon offer WiFi calling as a near-term solution while this permitting process proceeds? If so, why has Verizon not promoted this solution to affected Mendota Heights residents rather than pursuing a new tower? ▶ Why this matters: If Verizon has an existing no-cost solution available to affected residents but has not offered it, that is directly relevant to whether the claimed urgency and necessity of this tower is genuine. Category 3: FAA and Aviation Considerations Q11. Has FAA Form 7460-1 been submitted for this structure? What is the current status of the aeronautical study, and has any preliminary or final determination been issued? ▶ Why this matters: Given the proximity to MSP, FAA aeronautical review is almost certainly required. The absence of this determination from the record is a material gap. Q12. Has the FAA indicated whether obstruction lighting will be required or recommended for this structure? If lighting is required, what type, at what intensity, and with what operational schedule? ▶ Why this matters: If aviation beacon lighting is required on a structure in the center of a residential park, that impact has not been evaluated and is directly relevant to the compatibility and general welfare standards. Category 4: Visual Impact and Design Q13. Will the tower use a stealth or camouflage design — such as a flagpole, architectural monopole, or tree design to minimize visual impact? If not, why not, and has such a design been evaluated? ▶ Why this matters: Stealth design is a commonly imposed condition in residential-proximate CUP approvals and is directly responsive to the visual impact and compatibility standards in the ordinance. Q14. What is the precise distance from the proposed compound perimeter to: (a) the playground equipment; (b) the hockey rink; (c) the softball field backstop; (d) the nearest residential structure? ▶ Why this matters: Specific distances allow the Commission to make factual findings on setback standards and compatibility with the park's active recreational uses. Category 5: Lease Terms and Accountability Q15. The lease permits up to three wireless carriers to co-locate. Has any other carrier expressed interest, and what would the visual and operational impact be if additional carriers are added? ▶ Why this matters: The current application describes a single-carrier configuration. If the tower will realistically host multiple carriers, the Commission's compatibility findings should reflect that. Q16. Please clarify the corporate relationship between The Towers, LLC, Vertical Bridge, and Verizon Wireless for the record - specifically, who will own the tower structure, who will operate it, and who is accountable for compliance with the conditions of any CUP that is issued? Page 309 of 473 ▶ Why this matters: Understanding the ownership and accountability structure is relevant to enforceability of any conditions attached to a CUP approval. I respectfully request that the applicant be required to answer each of the above questions on the record, and that their responses (or the absence of responses) be considered part of the evidentiary basis for this Commission's findings. Respectfully submitted, ________________________________ Kevin Byrnes 740 Wentworth Avenue Mendota Heights, MN 55118 Attachment A to Written Testimony in Planning Case No. 2026-05 Page 310 of 473 From:carynaddante@gmail.com To:Sarah Madden Subject:monopole Wireless Tower comments and questions Date:Tuesday, March 31, 2026 1:45:05 PM You don't often get email from carynaddante@gmail.com. Learn why this is important March 31, 2026 Sarah Madden, Community Development Manager City of Mendota Heights 1101 Victoria Curve Mendota Heights, MN 55118 Dear Ms. Madden, I am submitting questions and comments about the proposed 149-foot-monopole Wireless Tower in Wentworth Park since I cannot attend the March 31 meeting. Like many residents, I am concerned about having this large telecommunications structure in our public park and near our homes disrupting the green space we enjoy and cherish. I hope the decision-makers agree this location should be the last choice after reviewing all options including existing towers, commercial and industrial property, and municipal facilities. I am also concerned that while the tower will initially be constructed for one cellular provider, it will expand as the tower owner leases space, making it bulkier and even more unsuitable for our park and neighborhood. Additionally, placing this large industrial tower in Wentworth Park does not align with the city’s 2040 vision nor residents’ desire of preserving “family-friendly community characterized by open, natural spaces”. My questions are as follows: 1. Have cellular providers shown that existing towers cannot meet demand and that adding more antennas is not possible? Publicly available data shows there are 24 Verizon towers, 20 AT&T towers and 20 T-Mobile towers. 2. Has an assessment been done to evaluate adding roof-mounted or water-tower Page 311 of 473 mounted antennas? A February 4, 2014, Star Tribune article about Mendota Heights’ cellphone service reported that a request to install equipment on the water tower was withdrawn. Has that been reconsidered now? Can roof-top antennas be added to one of the existing or new apartment complexes, industrial, commercial, municipal, or retail buildings? 3. If a new tower must be built, why was Wentworth Park selected and what alternate sites were evaluated? Municipal, industrial, and commercial locations would be more appropriate. For instance, can the tower be built near the Mendota Heights Water Tower, the City Public Works Garage, the new City Hall/Police Department, the industrial area on Highway 13 near the Excel Propane Plant, or on open land along the commercial corridor along Centre Point Boulevard where land is currently for sale, to name a few. Placing this tower in Wentworth Park is controversial. It would generate significant revenue for the city and the Tower company as it leases space to other providers, making it bigger and bulkier. Before a final decision is made, I think the right thing to do is show residents that all other co-location options have been assessed and then answer why they were rejected. Thank you in advance for providing answers to my questions. Sincerely, Caryn Addante Page 312 of 473 From:Graham Kerr-van der Leeuw To:Sarah Madden Cc:Tracy Kerr-van der Leeuw Subject:Case No. 2026-05 Conditional Use Permit Application of Buell Consulting, Inc. Date:Tuesday, March 31, 2026 2:06:42 PM You don't often get email from graham@kvdlfamily.com. Learn why this is important Good afternoon, Sarah. We are the owners of the residential property located at 781 Wentworth Ave W, Mendota Heights, MN 55118. We are writing to record our strong objection to the Conditional Use Permit Application of Buell Consulting, Inc. for a new freestanding wireless monopole tower at 739 Wentworth Avenue (Wentworth Park). We understand the need to address cellular coverage needs, but strongly believe that a beloved community park used and enjoyed by many in the Mendota Heights community is the wrong location to consider for a tower of this type. The park is valued for its green spaces, natural beauty and the wildlife that thrives in the nearby creek and wetlands, and in our view the construction of a 149 foot wireless monopole tower is completely inconsistent with this value. The park is enjoyed by pickleball, basketball and softball players (including many children) in the summer and skaters in the winter and, even more importantly by families, including babies, toddlers and young children enjoying the playground. A wireless monopole tower would be a health hazard, especially for the youngest members of our community, and an eyesore for everyone. On a more personal note, we moved from St. Paul to Mendota Heights in 2022 (605 Butler Ave W), valuing the natural environment the city offers as an alternative to more urban landscapes. We have loved living in Mendota Heights so much we purchased our lot at 781 Wentworth Ave W in 2023 and made a substantial investment in the construction of our new home into which we moved last year. We have greatly enjoyed the wildlife that regularly traverses the bottom of our property along the creek and graces the skies in all directions from our home. We also have a new 5-month old grandson with whom we have been looking forward to spending time in the playground at Wentworth Park. We appreciate the great work that Mayor Levine, the members of the City Council and others have done to make Mendota Heights the wonderful community it is, and would be deeply disappointed if this legacy is undermined for generations to come by the approval of this application. We urge the Mendota Heights Planning Commission and City Council to reject the application. Please let us know if you have any questions. Thank you for your consideration. Tracy & Graham Kerr-van der Leeuw Page 313 of 473 781 Wentworth Ave W Mendota Heights, MN 55118 TandG@KvdLfamily.com (847) 343-3413 (Tracy) (651) 245-4189 (Graham) Page 314 of 473 Documents submitted to staff at 3-31-26 meetingPage 315 of 473 Documents submitted to staff at 3-31-26 meetingPage 316 of 473 Documents submitted to staff at 3-31-26 meetingPage 317 of 473 Documents submitted to staff at 3-31-26 meetingPage 318 of 473 Documents submitted to staff at 3-31-26 meetingPage 319 of 473 Documents submitted to staff at 3-31-26 meetingPage 320 of 473 Documents submitted to staff at 3-31-26 meetingPage 321 of 473 Documents submitted to staff at 3-31-26 meetingPage 322 of 473 Documents submitted to staff at 3-31-26 meetingPage 323 of 473 Documents submitted to staff at 3-31-26 meetingPage 324 of 473 Documents submitted to staff at 3-31-26 meetingPage 325 of 473 Documents submitted to staff at 3-31-26 meetingPage 326 of 473 Documents submitted to staff at 3-31-26 meetingPage 327 of 473 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staff at 3-31-26 meetingPage 391 of 473 From:Jeff Nath To:Sarah Madden Subject:Fw: Opposed to wireless tower in Wentworth Park Date:Tuesday, April 14, 2026 4:42:25 PM From: Steve Schley <steve.schley.mn@gmail.com> Sent: Tuesday, March 31, 2026 2:51 PM To: Jeff Nath <JNath@mendotaheightsmn.gov> Subject: Opposed to wireless tower in Wentworth Park You don't often get email from steve.schley.mn@gmail.com. Learn why this is important I’m opposed to the wireless tower and have significant safety concerns related to EMF and RF, both for my family home immediately across from the park (750 ft) and for my grade school children that frequent the park (<100 ft) on a nearly daily basis. Steve Schley +1-612-242-1918 steve.schley.mn@gmail.com Page 392 of 473 Voicem ail Transcription Hey Sarah this is Linda and Ted Harley calling, we live over on Cherry Hill. There’s no need to call us back. [Um], we’re long time residents and we’re just opposing the tower at Wentworth Park, and I’m thinking, could that go, like, where City Hall is, or somewhere like that. [Uh], Because we have that little pristine park, [I’m opp]- we’re opposed to it. So, its, uh, Linda and Ted Harley, if you need to call us for anything its 651[-xxx-xxxx – redacted]. Thank you so much. [Buh]bye. Page 393 of 473 From:Dave Williams To:Sarah Madden Subject:Planning Case No. 2026-05 Date:Tuesday, March 31, 2026 4:45:50 PM Attachments:Wentworth Tower 3312026.pdf You don't often get email from dave@oakgrovecap.com. Learn why this is important Sarah, Please find my comments and request to deny the above referenced Conditional Use Permit for the Tower and Wentworth Park. Thanks, David Sent from my iPhone Page 394 of 473 Page 395 of 473 Page 396 of 473 Page 397 of 473 From:Jennifer Seidl To:Sarah Madden Subject:Opposition to Cell Tower Date:Wednesday, April 1, 2026 7:43:34 PM You don't often get email from jennifer.mccall.seidl@gmail.com. Learn why this is important I am writing to you in response to the proposal to build a 149’ cell tower in Wentworth Park. To be very clear, I am adamantly against this. I am shocked that this is even getting consideration! Only a portion of the community was notified about this objective and given very little time to prepare. I take issue with that approach. I waited to attend the planning commission meeting last night for more information before I expressed my opinion. If you were there, you would have sensed the overwhelming vibe that the majority of our community DOES NOT WANT THIS! Attending the meeting made it absolutely clear that important questions have not been answered and that this will negatively impact our city to only benefit a few. But at what cost? This would tarnish Wentworth park and decrease its use. It would impose a safety and health risk. I do not want my family, my children, living in the immediate perimeter of this! And it absolutely does not align with the aesthetic of our city. Mendota Heights should be known for its charm and character. Not cell towers and apartment buildings. It seems with the very small percentage of our community affected, smaller solutions need to be considered. Not a 149’ eye sore in our most popular park that will be a detriment to your constituents and the value of our homes. Our community deserves better. Jen Seidl Page 398 of 473 From:Meredith Lawrence To:jon.vaupel@gmail.com; Michelle Muller Cc:Cheryl Jacobson; Sarah Madden; Ryan Ruzek Subject:Re: Protect and Preserve Mendota Heights Parks (no cell towers) Date:Friday, April 3, 2026 12:21:50 PM Hi Michelle: I have looped in Cheryl Jacobson, City Administrator and City Staff associated with this item on this email. Enjoy the weekend, Meredith A. Lawrence, CPRE, CPWP-MParks and Recreation Director/Assistant Public Works DirectorCity of Mendota Heights 651-255-1354 From: Michelle O'Connor Muller <michellerachelmuller@gmail.com> Sent: Friday, April 3, 2026 12:09 PM To: Meredith Lawrence <MLawrence@mendotaheightsmn.gov>; jon.vaupel@gmail.com <jon.vaupel@gmail.com> Subject: Fwd: Protect and Preserve Mendota Heights Parks (no cell towers) Thank you, Jon. I greatly appreciate your email. I agree with and support your argument. Meredith — what is the best course of action to forward this to the city council? Jon, would you be willing to send this to city council members? You are welcome to include my name in support of your position. Thank you, Michelle Muller Mendota Heights Park & Recreation Commission ---------- Forwarded message --------- From: Jon Vaupel <jon.vaupel@gmail.com> Date: Tue, Mar 31, 2026 at 8:59 AM Subject: Protect and Preserve Mendota Heights Parks (no cell towers) To: <lfield@mendotaheightsmn.gov>, <jstone@mendotaheightsmn.gov>, <pcorbett@mendotaheightsmn.gov>, <cjohnson2@mendotaheightsmn.gov>, <jnath@mendotaheightsmn.gov>, <budell@mendotaheightsmn.gov>, Page 399 of 473 <sgoldade@mendotaheightsmn.gov> Cc: <KRamirez@mendotaheightsmn.gov>, <JBlanks@mendotaheightsmn.gov>, <jweichert@mendotaheightsmn.gov>, <pcortesvaldes@mendotaheightsmn.gov>, <michael.toth8@gmail.com>, <michellerachelmuller@gmail.com>, <dvanlith@mendotaheightsmn.gov> Dear Planning Commission Members - I am writing to urge you to vote against allowing a 149 foot cell tower to be placed in Wentworth Park. Allowing a cell tower in Mendakota Park sets a precedent to place large cell towers (or other non-parks/recreation infrastructure) in any of our 17 public parks. I would encourage you to use The City of Mendota Heights 2040 Comprehensive Plan Update to guide you in voting and making this precedent setting decision: Chapter 4 on Parks and Trails: "These facilities represent unique features in a park system that helps to shape the character of Mendota Heights beyond the ordinary. They offer a visual identity to the city, in addition to contributing to the quality of life for those who live and recreate in the community." Additionally, voting to allow a cell tower in Mendakota Park (or any of our parks) does not support any of the four goals for Parks and Trails that are outlined in the city's Comprehensive Plan. I ask that you vote to protect and preserve our public parks and vote no on this measure (and explore other options). Respectfully, Jon Mendota Heights Resident, Ivy Falls Neighborhood cc: Parks & Recreation Commission Members Page 400 of 473 From:Cheryl Jacobson To:Sarah Madden Subject:FW: Wentworth Park issue Date:Tuesday, April 14, 2026 8:33:58 AM For the record. From: Stephanie Levine <SLevine@mendotaheightsmn.gov> Sent: Monday, April 13, 2026 2:53 PM To: JP <716@comcast.net> Cc: Cheryl Jacobson <CJacobson@mendotaheightsmn.gov> Subject: Re: Wentworth Park issue Dear John, Thanks for reaching out regarding your opposition to the proposed cell tower being located at Wentworth Park as opposed to the Par 3. I am copying in City Administrator Jacobson, so that your concerns can be made part of the public record. The reason that Wentworth was chosen is that this location will give cell access to homes in the neighborhoods that are currently not reached (called “dead zones”), due to the tricky topography of the area. We have a challenge in our community - the need for these homes to have access to cell service and to minimize dropped calls, especially for our emergency responders - while preserving the natural beauty of our city. Any and all ideas are welcomed and considered. Thank you for sharing your thoughts. Take Care, Stephanie Stephanie B. Levine Mayor City of Mendota Heights C:651-302-0861 Website | Connect Page 401 of 473 From: JP <716@comcast.net> Date: Tuesday, April 7, 2026 at 11:41 AM To: Stephanie Levine <SLevine@mendotaheightsmn.gov> Subject: Wentworth Park issue You don't often get email from 716@comcast.net. Learn why this is important Hi Mayor Levine, In regards to the proposed Cell Tower in Wentworth Park - could I suggest that it instead be located at the Par 3 golf course? I agree with my neighbors that the Cell Tower would be a major public eyesore in Wentworth Park. I agree with my neighbors that it would eat up usable Wentworth Park real estate. I do acknowledge that there is a need for an additional Cell Tower for the neighborhood north of Bachelor Ave., and the area bounded by 1st Avenue, 4th Avenue, and Dodd Road. I currently have excellent cell phone coverage (with Mint Mobile ) at my home. Thank you, John Penfield 716 Wentworth Ave. Mendota Heights Page 402 of 473 From:Cheryl Jacobson To:Sarah Madden Subject:FW: In Support of the Wentworth Cell Tower Date:Tuesday, April 14, 2026 8:36:28 AM Attachments:Outlook-cid_image0.png Follow up from Councilor Lorberbaum. From: Sally Lorberbaum <SLorberbaum@mendotaheightsmn.gov> Sent: Monday, April 13, 2026 3:40 PM To: Tim Milner <tim@jitpowdercoating.com> Cc: Cheryl Jacobson <CJacobson@mendotaheightsmn.gov> Subject: Re: In Support of the Wentworth Cell Tower Thank you, Mr. Milner, for taking the time to write your letter supporting the cell tower in Wentworth Park, allowing us to hear your views on its value, and the reasons behind your views. Listening to residents is an important part of my job. Public safety is my number one priority. Your letter will be included in the public record going to the Planning Commission as they put together a recommendation for the City Council. I will keep your statements in mind as we discuss this matter. Again, thank you for contacting me about this issue. Please feel free to contact me again about matters of concern to you. Best, Sally Website Sally Lorberbaum City Councilor City of Mendota Heights Cellphone: 651-503-5564 Email: slorberbaum@mendotaheightsmn.gov Pronouns: she/her From: Tim Milner <tim@jitpowdercoating.com> Sent: Friday, April 10, 2026 8:21 PM To: Stephanie Levine <SLevine@mendotaheightsmn.gov>; Sally Lorberbaum <SLorberbaum@mendotaheightsmn.gov>; John Maczko <JMaczko@mendotaheightsmn.gov>; John Mazzitello <JMazzitello@mendotaheightsmn.gov>; Joel Paper <JPaper@mendotaheightsmn.gov> Cc: Cheryl Jacobson <CJacobson@mendotaheightsmn.gov>; Ryan Ruzek <RRuzek@mendotaheightsmn.gov> Subject: In Support of the Wentworth Cell Tower Page 403 of 473 [Some people who received this message don't often get email from tim@jitpowdercoating.com. Learn why this is important at https://aka.ms/LearnAboutSenderIdentification ] Mendota Heights City Council Members, As was requested by Council member Lorberbaum at the last City Council meeting, I have taken the time to write a letter in support of installing the cell tower in Wentworth Park. My letter is attached as a PDF file. Thank you for taking my comment under advisement. Feel free to contact me if you have any questions. Tim Tim Milner 834 Park Place Drive Mendota Heights, MN 55118 651-457-7016 (home) 651-303-5440 (mobile) Page 404 of 473 Members of the Mendota Heights City Council Watching the April 7th Council meeting, Council Member Lorberbaum made a comment encouraging people supporting the cell tower in Wentworth Park to make their feelings known. So here goes. I support the cell tower. My reasoning is more detailed than what would normally be allowed in a public hearing, so I am providing the rationale for my support in writing, rather than in person. I live at 834 Park Place Drive. We are the 2nd owners of this home – we bought it in 1996. Absolutely love the City and the neighborhood. (I am about as native as it gets – in my life – I have moved ~2 miles in total (from the Signal Hills area in West St Paul to my current home)) I am in the heart of the dead zone. I do not have a choice on cellular provider; I am with Verizon. My cellphone is provided by my business. My mobile number is the 3rd option in the emergency response notification system tree for any emergency (fire, police, oT shift medical, etc.) that might occur at my Farmington MN, business. Verizon has the best south metro coverage which is why it was selected. At my Park Place Drive home, we must use the WiFi calling feature on our phones. The standard cellular signal is too weak to connect a call. When we move outside into the backyard, we lose the WiFi signal and will drop / not receive any call(s). Any time we have a visitor at our house, we have to connect them to the WiFi and ask them to use WiFi calling. This is our technology life. What frustrated me in the watching the March 31st Planning Commission meeting was the cavalry attitude of the various speakers regarding “alternatives”. I am writing to tell you that, quite frankly, there are very limited alternatives today in Mendota Heights. Furthermore, based on consumer trends, those alternatives are going to soon disappear leaving cellular as the only source. Allow me to explain. At home, we still have a land line with Century Link. For the last several months, there was a humming noise on the line making it diTicult to hear. Century Link came out and investigated. The lines in my home are fine. The lines from the street to the house are OK – not great – but good enough. But the switch box, located near the corner of Park Place Drive and Wachtler Ave is not OK. The connector inside the switch box for my line has corroded and is worn out. That’s what is causing the feedback. The solution was to reroute the copper for my line to another connector in the switch box – one that should be assigned to a diTerent Park Place Drive customer. In essence, my line was “hot wired” to another connector. You might ask – why was the connector not replace it? Because the connectors are obsolete – the switch box was installed in 1983. Why not replace the switch box? Because in the entire Park Place neighborhood (54 homes), Century Link has exactly 2 land line Page 405 of 473 customers!! There is no revenue to justify the expense of replacing a switch box. The Century Link plan, which as a business owner I can fully appreciate, is to keep “hot wiring” connectors whenever the last 2 customers have issues with their lines. Because of this obsolete equipment, Century Link has never oTered DSL internet service in the neighborhood. I was optimistic when their subsidiary, Quantum Fiber, brought a fiber line from the Xcel Energy station on Hwy 13 up Wachtler Ave to Dodd Road. But they choose NOT to bring fiber into the Park Place neighborhood. Reasoning? To o expensive to install the necessary equipment for the limited number of homes in the neighborhood. I was told that if I could get 10 neighbors to indicate interest (via a Quantum website sign up) that they would consider it. I actually got 16. But when I followed up their answer was “No”. It is not a priority. I find it ironic that the people on the other side of Wachtler in Cherry Hill have the Quantum option (as a result of the fiber being laid all the way to Somerset Elementary) because they are feed from a diTerent station. Arvig, an independent internet provider, provides internet to my business. I called them to see what they could do for my home. They have the ability to bring a fiber connection from the corner of Wentworth and Dodd to my Park Place home. They are willing to do it. The upfront cost to me is $17,000!! Because the 1st person that contracts with them pays the cost of bring the fiber into the neighborhood. After that, it would be about a $300 charge for any other home in the neighborhood to connect to that fiber. Obviously, that initial cost is prohibitively expensive for me and I have not pursued it. Comcast is my internet provider (and my source for WiFi calling). Comcast wired the neighborhood in 1985 using standard coaxial copper wire. Nearly every home in the the Park Place neighborhood uses Comcast. We are a neighborhood of larger homes – meaning more people and more internet usage. The bandwidth needs of the neighborhood are exceeding the capacity of the old style coaxial cable. The neighborhood experiences more than its share of “jitter” (unstable network latency). I need to take 2 video calls each month from home. With standard Comcast service, I could not use my camera nor could I be the host. The bandwidth available from Comcast is simply not good enough based on the neighborhood’s usage. Comcast knows this problem exists but has no plans to upgrade the copper wire. They are losing customers to the “cord cutting” streamers and to install new copper wire does not make financial sense. (As an interesting side note, this will also have impact on the City’s franchise fee revenue in the future) Comcast’s solution was to give me a business line for my home – but as an additional expense to my residential service. While the wire is the same, the traTic on that “business” wire is far less so I can successfully have video conferences. (I may be the only one in the neighborhood with a Comcast business line – they would not confirm this). The net result - it costs me double what it should to have internet video conferencing speed at my Mendota Heights home. Page 406 of 473 Why are none of these companies willing to invest? Because they are losing their customers to cellular technology!! The generations behind me (I’m in my mid 60’s), have chosen to invest in cellular technology for all their communication needs. They don’t have land lines. They stream, they don’t have cable TV. Their 5G phones are more than adequate for all their needs. A long read to get to my point. Based on my experiences, I’m guessing that within a decade, the alternate communication infrastructure (land lines, cable) is going to continue to deteriorate to the point of not being usable. The Comcast copper cable is not going to be replaced unless a high volume customer neighborhood seriously complains. Century Link is not going to upgrade the switch gear not matter what. These alternatives will simply disappear. Leaving cellular technology as the ONLY voice, TV and internet technology available in Mendota Heights. The City of Mendota Heights is going to be forced to work out a process to accommodate cell towers to eliminate all the dead zones. If the City does not do so, it will ultimately result in a situation where people will not be able to contact someone in case of a health and safety emergency. Since providing those services is a fundamental responsibility for City government, the City does need to ensure every resident has a communication option. Delaying the tower today will not prevent the tower from ultimately being installed. It is going to be installed at some future point when the other technologies deteriorate to the point of being unusable. The alternative would be to leave some future residents in certain neighborhoods within the City of Mendota Heights without a communication technology. I hope my rather long writing sparks further debate about the long term future of communications in Mendota Heights when you make the decision on this particular tower request. It is a bigger issue than this one tower. And not nearly as simple as people seem to believe it is to “use something else”. Tim Milner 834 Park Place Drive Mendota Hts 651-457-7016 (my landline!) Page 407 of 473 From:Cheryl Jacobson To:Sarah Madden Subject:FW: Cell phone tower in Wentworth Park Date:Tuesday, April 14, 2026 8:33:31 AM For the record. From: Stephanie Levine <SLevine@mendotaheightsmn.gov> Sent: Monday, April 13, 2026 3:27 PM To: Kathryn Short <kathrynmshort@gmail.com> Cc: Cheryl Jacobson <CJacobson@mendotaheightsmn.gov> Subject: Re: Cell phone tower in Wentworth Park Dear Kathryn, Thanks for reaching out regarding your opposition to the proposed cell tower being located at Wentworth Park. I am copying in City Administrator Jacobson, so that your concerns can be made part of the public record. The reason that Wentworth was chosen is that this location will give cell access to homes in the neighborhoods that are currently not reached (called “dead zones”), due to the tricky topography of the area. Regarding the exposure to RF, my understanding is that there is no conclusive data (which would impact cell phone users even more). We have a challenge in our community - the need for these homes to have access to cell service and to minimize dropped calls, especially for our emergency responders - all while preserving the natural beauty of our city. We welcome all ideas that can help solve this issue! Thank you for sharing your thoughts. Take Care, Stephanie Stephanie B. Levine Mayor City of Mendota Heights C:651-302-0861 Website | Connect Page 408 of 473 From: Kathryn Short <kathrynmshort@gmail.com> Date: Saturday, April 11, 2026 at 9:26 PM To: Stephanie Levine <SLevine@mendotaheightsmn.gov> Subject: Cell phone tower in Wentworth Park You don't often get email from kathrynmshort@gmail.com. Learn why this is important Mayor Levine, I hope you’re doing well. I’m reaching out as a Mendota Heights resident to express my strong opposition to the proposed cell phone tower in Wentworth Park. This park is a treasured community space, and placing a tower there would significantly change the character of an area that so many families rely on for recreation and green space. Additionally, I am concerned about the negative health impacts associated with long- term exposure to radio-frequency emissions, particularly in a setting where children and families spend extended periods of time (neighborhoods and the park). Thank you. Kathryn Short Page 409 of 473 From:Cheryl Jacobson To:Sarah Madden Subject:FW: Tower proposal Date:Tuesday, April 14, 2026 2:23:48 PM Follow up to an initial email. From: Stephanie Levine <SLevine@mendotaheightsmn.gov> Sent: Tuesday, April 14, 2026 2:22 PM To: Patrice Sullivan <pmsullivan2.ps@gmail.com> Cc: Cheryl Jacobson <CJacobson@mendotaheightsmn.gov> Subject: Re: Tower proposal Dear Patrice, Many of our residents do have land lines, but they are telling us that they are not always supported, as customers are switching to cell phones. I’m not sure what you mean by wireless - maybe wifi? That is also something that people have but residents have told us that it is unreliable in an emergency, when the power is out. Residents are concerned about safety, which is a responsibility of government. I hope this helps answer your question. Sincerely, Stephanie Stephanie B. Levine Mayor City of Mendota Heights C:651-302-0861 Website | Connect From: Patrice Sullivan <pmsullivan2.ps@gmail.com> Date: Monday, April 13, 2026 at 4:33 PM To: Stephanie Levine <SLevine@mendotaheightsmn.gov> Page 410 of 473 Cc: Cheryl Jacobson <CJacobson@mendotaheightsmn.gov> Subject: Re: Tower proposal You don't often get email from pmsullivan2.ps@gmail.com. Learn why this is important Why can’t the residents who are in the dead zone get a land line or use wireless calling? The city and tax payers should not have to be responsible. On Mon, Apr 13, 2026 at 3:33 PM Stephanie Levine <SLevine@mendotaheightsmn.gov> wrote: Dear Patrice, Thanks for reaching out regarding your opposition to the proposed cell tower being located at Wentworth Park. I am copying in City Administrator Jacobson, so that your concerns can be made part of the public record. The reason that Wentworth was chosen is that this location will give cell access to homes in the neighborhoods that are currently not reached (called “dead zones”), due to the tricky topography of the area. I understand the impact to the park - and we tried to do our best by locating it in an area which is to the side, separated from the playground and picnic shelter by a mature stand of trees. We even considered trying to camouflage it - but I think everyone can agree that it is an eyesore, regardless. We have a challenge in our community - the need for these homes to have access to cell service and to minimize dropped calls, especially for our emergency responders - all while preserving the natural beauty of our city. We welcome all ideas that can help solve this issue! Sincerely, Stephanie Stephanie B. Levine Mayor City of Mendota Heights C:651-302-0861 Website | Connect Page 411 of 473 From: Patrice Sullivan <pmsullivan2.ps@gmail.com> Date: Saturday, April 11, 2026 at 3:22 PM To: Stephanie Levine <SLevine@mendotaheightsmn.gov> Subject: Tower proposal You don't often get email from pmsullivan2.ps@gmail.com. Learn why this is important Hi Stephanie, I am writing to inform you my disappointment about a possible wireless tower being put in a wentworth park. I have lived my entire life in Mendota heights and I have spent hours playing at went worth park as a child. I now bring my own children to play at that park. Allowing this project to take place would be a major disappointment to our community. Please keep in mind of how this can impact our children in this community. Patrice Lindh Page 412 of 473 Page 413 of 473 From:Cheryl Jacobson To:Sarah Madden Subject:FW: Wentworth Park cell tower Date:Wednesday, April 15, 2026 3:06:50 PM For the record. From: Stephanie Levine <SLevine@mendotaheightsmn.gov> Sent: Wednesday, April 15, 2026 1:35 PM To: Joan Penfield <jodiepenfield@gmail.com> Cc: Cindy Johnson <CJohnson2@mendotaheightsmn.gov>; Litton Field <LField@mendotaheightsmn.gov>; Jason Stone <JStone@mendotaheightsmn.gov>; Patrick Corbett <PCorbett@mendotaheightsmn.gov>; Brian Udell <BUdell@mendotaheightsmn.gov>; Steve Goldade <SGoldade@mendotaheightsmn.gov>; Jeff Nath <JNath@mendotaheightsmn.gov>; Cheryl Jacobson <CJacobson@mendotaheightsmn.gov> Subject: Re: Wentworth Park cell tower Dear Joan, Thank you for contacting the Planning Commission and mayor regarding your opposition to the proposed cell tower in Wentworth Park. I am copying in our city administrator, Cheryl Jacobson, so that she can add your email to the public comments. Sincerely, Stephanie Stephanie B. Levine Mayor City of Mendota Heights C:651-302-0861 Website | Connect From: Joan Penfield <jodiepenfield@gmail.com> Sent: Tuesday, April 14, 2026 4:08 PM To: Cindy Johnson <CJohnson2@mendotaheightsmn.gov>; Litton Field <LField@mendotaheightsmn.gov>; Jason Stone <JStone@mendotaheightsmn.gov>; Patrick Corbett <PCorbett@mendotaheightsmn.gov>; Jeff Nath <JNath@mendotaheightsmn.gov>; Brian Udell <BUdell@mendotaheightsmn.gov>; Steve Goldade <SGoldade@mendotaheightsmn.gov>; Stephanie Levine <SLevine@mendotaheightsmn.gov> Subject: Wentworth Park cell tower Page 414 of 473 You don't often get email from jodiepenfield@gmail.com. Learn why this is important Mayor Levine and the Mendota Heights planning commission. This letter is to voice my strong objection to the proposed Wentworth Park cell tower and to offer alternate ideas. First and foremost is that we purchased in MH for the parks and green space. We pay taxes to keep our parks. Second, the size is unnecessary anywhere you put it. We do not need to destroy ( and it will ) our park to give west st paul cell coverage. Third, Wentworth avenue is one of the most scenic RESIDENTIAL roads in MH. Please keep it that way. Any tower much less this oversized nightmare proposed sitting right out in the open would turn our highly used park into an industrial park. Not just the height but the base. This does not even mention the constant upkeep with trucks and equipment. What happens in 25 years when its obsolete? Alternate business locations would be either end of the par 3 golf course, on trail road off bachelor where contruction is currently happening, somerset school, anywhere along hwy 13. Please keep researching this issue. There is a much better solution out there and we are counting on you to find it. Sincerely, Joan Penfield 716 Wentworth avenue jodiepenfield@gmail.com Page 415 of 473 From:Cheryl Jacobson To:Sarah Madden Subject:FW: Opposed to Wentworth Cell in Wentworth Park Date:Tuesday, April 21, 2026 3:20:06 PM For the record. From: Stephanie Levine <SLevine@mendotaheightsmn.gov> Sent: Monday, April 20, 2026 8:02 AM To: Cheryl Jacobson <CJacobson@mendotaheightsmn.gov> Subject: Fw: Opposed to Wentworth Cell in Wentworth Park Stephanie B. Levine Mayor City of Mendota Heights C:651-302-0861 Website | Connect From: Stephanie Levine <SLevine@mendotaheightsmn.gov> Sent: Monday, April 20, 2026 8:00 AM To: Forouhari Family <forouhari_family@yahoo.com> Subject: Re: Opposed to Wentworth Cell in Wentworth Park Hi Magda, It’s great to hear from you, and I hope your family is doing well, too (big news is that my daughter is getting married in September). The proposed cell tower’s location was chosen because of the tricky topography of the underserved area (considered a “dead zone”). While many areas of the city have low- quality signals and dropped calls, the priority area is the avenues neighborhood, and the north part of the city where we receive the most complaints. Unfortunately, the areas you mention -as well as other locations that were considered - won’t produce the results that are needed. The tower placement in Wentworth was sited in an area of the park that is separated from the playground, shelter and field by a large stand of mature trees, which will limit Page 416 of 473 (but not fully) the sight line to the tower. We are also requiring vegetation around the tower, that will, at least, partially shield some of the lower elements of the tower from site. We are also requiring that the tower be painted eggshell, the least intrusive color. We are in a tough situation. We have a responsibility to allow infrastructure that will provide necessary communication for all of our residents while minimizing the impact to our beloved green spaces. Please let me know if you have more questions or ideas. I am also forwarding your email on to our city administrator, Cheryl Jacobson so that it can be part of the public record. Take Care, Stephanie Stephanie B. Levine Mayor City of Mendota Heights C:651-302-0861 Website | Connect From: Forouhari Family <forouhari_family@yahoo.com> Sent: Sunday, April 19, 2026 6:35 PM To: Stephanie Levine <SLevine@mendotaheightsmn.gov> Subject: Opposed to Wentworth Cell in Wentworth Park [You don't often get email from forouhari_family@yahoo.com. Learn why this is important at https://aka.ms/LearnAboutSenderIdentification ] Hi Stephanie, I hope you and your family are doing well! Sounds like Mendota may have a need for a cell tower near by? The plan for Wentworth is quite an interruption to the Park’s beauty and dog walking area by many. I am opposed to that because there may be other areas available that are not as natural. What about using the Fire-station location on Dodd Road? Or the City council/ police property on Victoria? Or the Dakota property on Wentworth? These city-owned properties are already Page 417 of 473 denaturalized. Thanks for preserving our natural areas! It’s why we all moved here. Best, Magda Sent from my iPhone Page 418 of 473 From:Cheryl Jacobson To:Sarah Madden Subject:FW: Cell tower support Date:Tuesday, April 21, 2026 3:21:08 PM For the record. From: Stephanie Levine <SLevine@mendotaheightsmn.gov> Sent: Saturday, April 18, 2026 10:31 AM To: Cheryl Jacobson <CJacobson@mendotaheightsmn.gov> Subject: Fwd: Cell tower support Please share w council. Thanks! Stephanie B. Levine Mayor City of Mendota Heights C:651-302-0861 Website | Connect Begin forwarded message: From: dhanson1333@comcast.net Date: April 17, 2026 at 9:57:13 AM CDT To: Stephanie Levine <SLevine@mendotaheightsmn.gov> Subject: Cell tower support You don't often get email from dhanson1333@comcast.net. Learn why this is important Madame Mayor, I support the installation of a cell tower in Wentworth Park. We can't get Version or T-Mobile internet because of the cell coverage in Mendota Heights. You have my support for the cell tower! Thanks for all you do! Page 419 of 473 David Hanson 1333 Delaware Ave Mendota Heights, MN 55118 651-278-7956 Page 420 of 473 From:Jean Tuohy To:Sarah Madden; Jean Tuohy Subject:Wentworth Park Cell Tower Date:Friday, April 17, 2026 11:23:48 AM Dear Sarah Madden, I have been a Mendota Heights resident for 50 years. I take my daily walks through Wentworth Park. We have had many picnics, family parties and gatherings in that park for many years. I have had NO difficulty with service in my area. I am against the proposed Cell tower not only for ruining the esthetics of the park but several other reasons. With the fast paced development of technology today cell towers will become obsolete. We are then 'Stuck" with an ugly tower that will be left in place and the area not maintained. Please note how many rusty, broken Comcast boxes throughout Mendota Heights. There are other options available to cellular network connections. There are fiber optics, Star Link, terrestrial modalities and other satellite technology. I have other ideas of where to place or upgrade our present towers. The cell tower located at St Stephen's Church on Wentworth and Charlton (note this is just a few blocks from Wentworth Park) could be made taller for better connection. Also, extend the height on the tower off of Lexington Ave or the tower in West St Paul. Another location could be the publicly owned Par 3 golf course. There is open space as well as topographical height. Please take my concerns into consideration and present them at the meeting on April 28th. I appreciate your work and help with this matter. My vote is "NO" for a cell tower in Wentworth Park. Sincerely, Jean Tuohy 808 Park Place Drive Mendota Heights, MN 55118 Page 421 of 473 From:JOHN RAAK Owner To:Sarah Madden Subject:Cell Tower Date:Monday, April 20, 2026 8:49:45 AM You don't often get email from braak@centurylink.net. Learn why this is important External Email: Please note this email is from an external source that failed a DKIM verification check. Please be suspicious of the contents, attachments, links and request for any information. Subject: Cell Tower From: JOHN RAAK Owner <braak@centurylink.net> Envelope Sender: braak@centurylink.net ============================================================= We are writing you to voice our opinions about installing a cell tower in Wentworth Park. We think it is a bad situation. Here are some of our reasons: 1). Young Children use the park everyday. The tower would be a health risk for them and the surrounding neighborhood. 2) Our property value will drop. If you do go ahead with the tower, would you lower our taxes? 3) It would be an eye sore and we would have to look at it everyday. 4). We would be losing valuable park space. There would be better places for it. Such as on Par 3 Golf Course where it could be hidden better, or the industrial area off of Highway 13. Mendota Heights is known for it green spaces and being a beautiful place to live. Why would you even consider putting something like that is any of our parks. I think there are ways to make money for the city other than destroying it with a cell tower We hope you will take into consideration our thoughts on the subject. Respectfully, Beverly and John Raak 728 West Wentworth Avenue Mendota Heights, MN. 55118 Page 422 of 473 From:Cheryl Jacobson To:Sarah Madden Subject:FW: Monopole Wireless Tower Date:Tuesday, April 21, 2026 2:53:24 PM For the record. From: Stephanie Levine <SLevine@mendotaheightsmn.gov> Sent: Tuesday, April 21, 2026 2:05 PM To: Sandra McGown <mcgown_s@comcast.net> Cc: Cheryl Jacobson <CJacobson@mendotaheightsmn.gov> Subject: Re: Monopole Wireless Tower Dear Ms. McGown, Thank you for sharing your thoughts that the proposed cell tower be placed in a different location, that isn’t a park. The reason that Wentworth was chosen is that this location will give cell access to homes in the neighborhoods that are currently not reached (called “dead zones”), due to the tricky topography of the area. Unfortunately, we don’t have other feasible options that would solve this issue. We have a challenge in our community - the need for these homes to have access to cell service and to minimize dropped calls, especially for our emergency responders - all while preserving the natural beauty of our city. The safety and security of our residents is of paramount importance, and we are trying our best to serve our residents. I am forwarding this email on to our city administrator, Cheryl Jacobson, so that your thoughts can be part of the public record. Sincerely, Stephanie Stephanie B. Levine Mayor City of Mendota Heights C:651-302-0861 Website | Connect Page 423 of 473 From: Sandra McGown <mcgown_s@comcast.net> Sent: Monday, April 20, 2026 3:16 PM To: Stephanie Levine <SLevine@mendotaheightsmn.gov> Subject: Monopole Wireless Tower [You don't often get email from mcgown_s@comcast.net. Learn why this is important at https://aka.ms/LearnAboutSenderIdentification ] Dear Mayor, I am a resident of Mendota Heights and I live on Wentworth Avenue . Of course I am extremely disappointed in our city council trying to push thru a wireless tower in Wentworth Park. If this area is considered a “dead area” for cellphone service there should be an alternative location than our beautiful park. I will quote your message in the spring Heights Highlights. “Maintaining safe roads, accessible sidewalks and VIBRANT GREEN SPACES is to preserving the high quality of life we all value”. Why is our park and neighborhoods in the immediate area being sacrificed in property value and beautiful park space for a few residents with poor cell service? There must be another location to accommodate these people. Sincerely, Sandra McGown Page 424 of 473 hps://walkerconsultants-my.sharepoint.com/personal /cschneeman_walkerconsultants_com/Documents/Desktop/stuff/ltr 2026-04-20 mh planning case 2026-05.docx April 20, 2026 City of Mendota Heights Planning Commission Members Re: Case No. 2026-05 – New Freestanding Wireless Monopole CUP Request Good day! Thank you for your service on the planning commission. I appreciate your hard work, as well as your commitment of service to the City. I wanted to provide a comment of support for approval of the condi&onal use permi’ed related to the above-noted request for the new wireless monopole proposed for Wentworth Park. These topics, as with many others presented to the commission, are difficult to navigate. However, I am apprecia&ve of the diligence presented by staff and the applicant in examining this request. It appears that an objec&ve review of the request has been performed, including sensi&vity toward the historical concerns for structures of this type. I live at 714 Stanwich Lane near the Par 3 and have been there since November 2020. I also grew nearby up in the Park Place neighborhood on Wachler, a’ending primary and secondary schools in Mendota Heights and West St. Paul. With this, I am sensi&ve toward protec&ng available use of our parklands within the City and frequently visit Wentworth Park. It is a special place for me, our children, and was one of the reasons why my family moved back to Mendota Heights. However, I do sympathize with others concerns regarding poor cellular coverage within the city. I personally experience very poor to non-existent coverage at home. This has been a consistently poor experience for us, despite our use of mul&ple major carriers (T-Moblie, Verizon). We presently have to rely on wifi-calling from our home’s internet provider (Comcast) for cellular connec&vity, and with that it only works within the interior of our home. Frankly, we live in a world where the ability to have reliable service is an impera&ve from a safety standpoint that extends beyond one’s home. I do not view reliance upon wifi-calling as a prac&cal method of connec&vity in our community. For example, our teenage children have mobile phones but they only work at home. Our children ride bicycles to work, and during their travel they are generally unreachable. Should an accident occur, they generally are unable to reach someone for help. Page 425 of 473 hps://walkerconsultants-my.sharepoint.com/personal /cschneeman_walkerconsultants_com/Documents/Desktop/stuff/ltr 2026-04-20 mh planning case 2026-05.docx Further, wifi-calling does not work when power goes down. Yes, there are ba’ery systems that can be purchased, but there’s no guarantee that the home internet stays online either. We have witnessed this on mul&ple loca&ons when power goes out, so does our home internet. We personally observed this in a more extreme sense in the recent past. A vehicle was traveling on Dodd Road and struck a power pole near the intersec&on of Batchelor and Dodd. The pole was severed, and power went offline for the neighborhood. Luckily, we were at home and heard the collision. I personally walked up the street to see what had occurred, and occupants of the vehicle were injured. I contemplated calling for aid, but I was without a connec&on. Fortunately, it was a day where mul&ple neighbors were home, and someone else was able to call for emergency services. However, this could have been more severe. I urge the commission and Council to recognize that having connec&vity is an important safety item. The proposed project appears to be well-located and sufficiently tall to provide coverage in a well-known coverage gap area in the Par 3 neighborhood, Cherry Hill, and beyond. We live in a great community, and the carefully considered project appears to be aligned in the public interest. Thank you again for your considera&on, Carl L. Schneeman 714 Stanwich Ln 612.508.7509 Page 426 of 473 From:Cheryl Jacobson To:Sarah Madden Subject:FW: Invitation to view comparable tower in person Date:Tuesday, April 21, 2026 3:12:26 PM Attachments:image.png For the record. From: Stephanie Levine <SLevine@mendotaheightsmn.gov> Sent: Tuesday, April 21, 2026 1:42 PM To: G <ostgaardg0@gmail.com>; John Mazzitello <JMazzitello@mendotaheightsmn.gov>; Sally Lorberbaum <SLorberbaum@mendotaheightsmn.gov>; John Maczko <JMaczko@mendotaheightsmn.gov>; Joel Paper <JPaper@mendotaheightsmn.gov> Cc: ryanrydberg1@gmail.com; Cheryl Jacobson <CJacobson@mendotaheightsmn.gov> Subject: Re: Invitation to view comparable tower in person Dear Gayra and Ryan, Thank you for contacting the city council, with your suggestion to view a comparable tower in Burnsville. Unfortunately, due to the Open Meeting Law, our city council (or more than 2 council members) can not meet there as a group. However, I plan to drive there and view the tower myself, and I am guessing that the other members of the council will do that too. We appreciate this information. I am going to copy on our city administrator, Cheryl Jacobson, so that she is aware of this cell tower as well. Sincerely, Stephanie Stephanie B. Levine Mayor City of Mendota Heights C:651-302-0861 Website | Connect From: G <ostgaardg0@gmail.com> Sent: Tuesday, April 21, 2026 9:50 AM To: Stephanie Levine <SLevine@mendotaheightsmn.gov>; John Mazzitello <JMazzitello@mendotaheightsmn.gov>; Sally Lorberbaum <SLorberbaum@mendotaheightsmn.gov>; John Maczko <JMaczko@mendotaheightsmn.gov>; Joel Paper <JPaper@mendotaheightsmn.gov> Page 427 of 473 Cc: ryanrydberg1@gmail.com <ryanrydberg1@gmail.com> Subject: Re: Invitation to view comparable tower in person You don't often get email from ostgaardg0@gmail.com. Learn why this is important Hello Mayor and City Council, I wanted to briefly follow up on the invitation to view a comparable 149’ tower. I’ve heard that the map link doesn’t always display the address clearly when opened on a phone, which may make it harder to locate the correct site. To make this easier, I’ve included a screenshot showing the full address as it appears on a desktop. The tower is located in Burnsville. We believe seeing a structure of this height in person provides valuable context— especially given the proposed placement in a neighborhood park used by children and families and the long-term nature of this decision. Please feel free to reach out if it would be helpful to coordinate a time or if you’d like any additional information. Thank you again for your time and consideration. Gayra and Ryan Gayra cell (6513036397) On Mon, Apr 20, 2026 at 1:50 PM G <ostgaardg0@gmail.com> wrote: Dear Mayor and City Council, Page 428 of 473 We hope you are doing well. Thank you for your continued time and attention to the proposed cell tower in Wentworth Park. We are writing to respectfully invite you to view an existing tower of the same height (149 feet) so that you can better understand the true scale of what is being proposed. While plans and renderings are helpful, they often don't fully convey how prominent a structure of this size is - particularly in a residential setting. There is a comparable tower located here: 2223 144th St W - Google Maps (149 feet) If it would be helpful, we would be glad to coordinate a time to meet there or even drive anyone who is interested. Alternatively, you may wish to visit the site independently at your convenience. Experiencing a structure of this height in person provides a level of clarity that drawings and descriptions cannot fully replicate - especially when considering its placement in a neighborhood park regularly used by children and families. Given the long-term nature of this infrastructure, including the proposed 50 year- lease, ensuring a full and shared understanding of its real-world impact before a decision is made feels both reasonable and important. We also have information on comparable towers that are slightly shorter and slightly taller, if additional context would be useful. Our goal in sharing this is to support thoughtful, fully informed decision-making on an issue that will shape the character and use of this public space for decades. Thank you again for your service and careful consideration of this matter. Sincerely, Gayra Ostgaard and Ryan Rydberg Page 429 of 473 From:G To:Litton Field; Jason Stone; Patrick Corbett; Cindy Johnson; Jeff Nath; Brian Udell; Steve Goldade Cc:ryanrydberg1@gmail.com; Sarah Madden Subject:Re: Invitation to view comparable tower in person Date:Tuesday, April 21, 2026 9:54:48 AM Attachments:image.png Hello Planning Committee, I wanted to briefly follow up on the invitation to view a comparable 149’ tower. I’ve heard that the map link doesn’t always display the address clearly when opened on a phone, which may make it harder to locate the correct site. To make this easier, I’ve included a screenshot showing the full address as it appears on a desktop. The tower is located in Burnsville. We believe seeing a structure of this height in person provides valuable context—especially given the proposed placement in a neighborhood park used by children and families and the long-term nature of this decision. Please feel free to reach out if it would be helpful to coordinate a time or if you’d like any additional information. Thank you again for your time and consideration. Gayra and Ryan Gayra cell number (6513036397) On Mon, Apr 20, 2026 at 1:35 PM G <ostgaardg0@gmail.com> wrote: Dear Planning Committee, We hope you are doing well. Thank you for your continued time and attention to the proposed cell tower in Wentworth Park. We are writing to respectfully invite you to view an existing tower of the same height (149 feet) so that you can better understand the true scale of what is being proposed. While plans and renderings are helpful, they often don't fully convey how prominent a structure of this size is - particularly in a residential setting. Page 430 of 473 There is a comparable tower located here: 2223 144th St W - Google Maps (149 feet) If it would be helpful, we would be glad to coordinate a time to meet there or even drive anyone who is interested. Alternatively, you may wish to visit the site independently at your convenience. Experiencing a structure of this height in person provides a level of clarity that drawings and descriptions cannot fully replicate - especially when considering its placement in a neighborhood park regularly used by children and families. Given the long-term nature of this infrastructure, including the proposed 50 year- lease, ensuring a full and shared understanding of its real-world impact before a decision is made feels both reasonable and important. We also have information on comparable towers that are slightly shorter and slightly taller, if additional context would be useful. Our goal in sharing this is to support thoughtful, fully informed decision-making on an issue that will shape the character and use of this public space for decades. Thank you again for your service and careful consideration of this matter. Sincerely, Gayra Ostgaard and Ryan Rydberg Page 431 of 473 From:felsh001 To:Sarah Madden Subject:cell tower Date:Wednesday, April 22, 2026 1:31:58 PM Hello Sarah Madden, I live at 650 1st Ave where cell signal is very weak or nonexistant. I would appreciate a new cell tower at wentworth park. I don't think it would ruin the park. Thanks, Rod Page 432 of 473 From:Graham Kerr-van der Leeuw To:Sarah Madden Cc:Tracy Kerr-van der Leeuw Subject:Case No. 2026-05 Conditional Use Permit Application of Buell Consulting, Inc. Date:Thursday, April 23, 2026 11:54:35 AM Attachments:Letter from Austen Kordosky, Realtor, Coldwell Banker Realty - April 23, 2026.pdf Cell Towers drop Property Values - Realtor Evidence and Published Research on Market Impacts.pdf Alternatives to Traditional Monopole Cell Towers for Improving Neighborhood Coverage.pdf Good morning, Sarah. In anticipation of the continued public hearing on this matter on Tuesday, April 28, we have attached to this email the following documents for inclusion in the public record: Letter from Austen Kordosky, Realtor, Coldwell Banker Realty, received today April 23, 2026, regarding the impact of the proposed monopole on property values. Mr. Kordosky represented us in the purchase (in 2022) and subsequent sale (in 2025) of our first Mendota Heights home at 605 Butler Ave W, as well as in the purchase of the lot at 781 Wentworth Ave W, Mendota Heights in 2023 and the construction of our current home at this address during 2024 and 2025. Research Science and Policy Brief titled "Cell Towers drop Property Values - Realtor Evidence and Published Research on Market Impacts" published by Environmental Health Sciences, a nonpartisan, 501(c)(3) nonprofit organization based in Bozeman, Montana. Alternatives to Traditional Monopole Cell Towers for Improving Neighborhood Coverage, reflecting results of personal online research regarding alternatives to monopoles. We plan to speak to the negative impact on property values, the need for independent evaluation of cellular coverage issues and less impactful solutions than the proposed monopole and other considerations relating to the Conditional Use Permit Application, at the continued public hearing next week. We would appreciate it if these documents could be included in the packages we understand you prepare for distribution to the members of the planning commission the Friday before the scheduled meeting on April 28. Please let us know if you have any questions. Thank you for your assistance. Tracy & Graham Kerr-van der Leeuw 781 Wentworth Ave W Mendota Heights, MN 55118 TandG@KvdLfamily.com Page 433 of 473 (847) 343-3413 (Tracy) (651) 245-4189 (Graham) Page 434 of 473 Page 435 of 473 Page 436 of 473 Page 437 of 473 Page 438 of 473 Page 439 of 473 Alternatives to Traditional Monopole Cell Towers for Improving Neighborhood Coverage Alternatives to traditional monopole cell towers for improving neighborhood coverage focus on network densification—placing smaller, less obtrusive equipment closer to users. Key options include small cells on existing infrastructure, distributed antenna systems (DAS), stealth "concealed" towers, and in-building signal boosters.1,2 Top Alternatives to Monopoles Small Cells: These are low-power, compact radio nodes that provide coverage over small areas (up to 2 miles, but often much less).2 They are typically installed on existing street furniture like utility poles, streetlight poles, or even on top of traffic lights.1 They are less visually disruptive than large towers and can handle high data traffic.3 Distributed Antenna Systems (DAS): DAS uses a network of multiple, low-power antennas (nodes) connected by fiber-optic cable to a central hub. This allows the system to disperse coverage evenly across a neighborhood rather than relying on one high-power source. These antennas can be mounted on existing utility poles and are often used when zoning laws prevent new, large towers.2 Stealth/Concealed Towers: These are designed to blend into their surroundings to mitigate visual impact. Examples include: Monopoles disguised as trees (pines, palm trees) Flagpoles or church steeples2 Light poles or billboards3 Rooftop Sites: Instead of new ground-level structures, carriers can install equipment on the roofs of existing, tall commercial or residential buildings.2 Water Tower Collocation: Placing antenna arrays on existing water towers.3,4 In-Building Solutions for Neighborhoods If the issue is primarily indoor coverage rather than outdoor, several personal or building-level solutions can act as alternatives: Cell Phone Signal Boosters (Passive DAS): These systems use an antenna on the roof to catch weak signals, an amplifier to strengthen them, and an indoor antenna to rebroadcast it, supporting multiple carriers. 5 Femtocells/Microcells (Network Extenders): These connect to a home’s broadband internet to generate a localized cell signal.5 They are ideal for areas with no outside signal but require a strong, stable internet connection. 6 Wi-Fi Calling: A software feature on modern smartphones that routes calls over the home’s Wi- Fi network rather than the cellular network.5 Page 440 of 473 References: 1CTC Technology & Energy (2016, December 1)How Localities Can Improve Wireless Service for the Public While Addressing Citizen Concerns - ctc technology & energy. 2Delaney, B. (2018, March 7) Types of Cell Towers and Cell Sites You Need to Know. 3Foresight Group (accessed 4/22/2026) TYPES OF CELL TOWERS. 4Cellnet (accessed 4/22/2026) Overcoming the Challenge of Poor Mobile Signal in New Buildings - Cellnet. 5SureCall (accessed 4/22/2026) A Guide to Cell Phone Signal Boosters. 6Jasso, A. (2025, March 5). Femtocell or Cell Signal Booster: Which One Do You Need? Page 441 of 473 From:rtlgroup@aol.com To:Sarah Madden Cc:Ryan Ruzek; Cheryl Jacobson Subject:Re: Mendota Heights - Planning Case No. 2026-05 - Additional Information Date:Thursday, April 23, 2026 6:29:48 PM Attachments:Lachenmayer Appraisal Letter re cell tower.pdf Richard Forsythe Appraisal letter re cell tower.pdf Hi, Sarah, Please find attached the two appraisal letters I have received from two independent appraisers. I think the people in the area should know what the financial impact would be, should the cell tower be allowed. In my opinion, the first priority they are clearly ignoring is the adverse health consequences to the unborn, newborn, children, and the elderly. If the insurance industry has a standard exclusion as it relates to a claim of harm from cell tower radiation, you have to ask yourself, WHY? What do they know that would cause them to exclude claims in this specific area? The reports I submitted already show increases in cancer, tumors, headaches, sleeplessness, and other symptoms of "microwave syndrome." We can expect these to be experienced by our residents and neighbors if the installation of the tower is allowed to go forward. Why is health and welfare not at the top of the priority list?! If they will not listen to common sense regarding the health and welfare of our residents and neighbors, I suppose "money talks." The attached letters from 2 licensed appraisers both indicate reduced property values for the surrounding area, thus, that item alone should trigger a "no" response to the CUP request, since one of the requirements is no serious impact to the values of the homes in the area. These letters clearly indicate that it will have a serious financial impact. Lastly, the coverage map that you sent to us today, and represented to be for Verizon, and only Verizon and no other carrier, shows my house in a weak spot. As I mentioned to the Commission at the last meeting, this is misleading and not accurate. No one in our home has any problems with making or receiving calls. So, in my opinion, this map is a misrepresentation of reality being used for an ulterior motive. Again, the decision is clear; NO to the CUP. Randy Pentel PH: 612.910.6868 On Thursday, April 23, 2026 at 01:54:33 PM CDT, Sarah Madden <smadden@mendotaheightsmn.gov> wrote: Good Afternoon, You are receiving this e-mail as a courtesy because you have previously expressed interest in the application of Buell Consulting/The Towers LLC for a Conditional Use Permit (CUP) for a new wireless monopole at Wentworth Park (Planning Case No. 2026-05) Page 442 of 473 The City has received supplemental information from the applicant related to their CUP request. The information provided by the applicant is attached to this e-mail. The Planning Commission is scheduled to continue the public hearing on this application request at their April 28th regular meeting (this upcoming Tuesday). This meeting begins at 7:00pm, and there are four items on the agenda. This item is fourth on the agenda schedule. The full agenda packet will be available on the City’s website tomorrow (Friday April 23rd). This e- mail list will receive an additional notification e-mail once the agenda packet has been published, with a link to view the packet. A paper copy of the packet will also be available in the lobby at City Hall. All public comments received relating to this application will be made part of the record and provided to the Planning Commission and City Council. All of the public comments received so far will be included as an attachment to the Planning Commission agenda packet for April 28th. Please reach out to City staff if you have any questions. Website | Connect Sarah MaddenCommunity Development ManagerCity of Mendota HeightsD: 651-255-1142 smadden@mendotaheightsmn.gov Page 443 of 473 2855 Anthony Ln S, Suite#110, Minneapolis, MN 55418 612-200-8740 info@lachenmayerappraisals.com Lachenmayer Appraisals, Inc 04/20/2026 To whom it may concern, From direct communication with Randy Pentel, who resides near Wentworth Park, I have learned that the city of Mendota Heights is considering plans for a cell phone tower construction in Wentworth Park. Randy, along with fellow neighbors, are concerned with adverse effects a cell phone tower will present to the neighborhood. As a full-time certified residential real estate appraiser, license d since 2002, I can speak to the adverse physical effects the tower presents. Living near a neighborhood park, or more notably, having unobstructed park views, is universally considered a beneficial characteristic. Meaning, potential buyers will generally pay a premium for park proximity, especially if the home has direct views of the park. In its as-is state, Wentworth Park positively impacts the area due to its features such as a playground, ballfield, ice rink, outdoor courts, as well as an abundance of green space and marshland. The erection of a cell phone tower, the required surrounding infrastructure, and the ensuing adverse views it would create would have direct negative impacts on the park’s appeal, and for those homes who currently possess beneficial views of the park. These properties would essentially be having a current beneficial characteristic flipped to an adverse view characteristic, thus diminishing the ir market appeal. It is my professional opinion, from a physical aspect alone, the construction of this cell phone tower will negatively impact views, diminish neighborhood home demand and value, and reduce Wentworth Park’s desirability due to the surrounding infrastructure required thus reducing usable green space. I also highly suggest that the city of Mendota Heights does their due diligence in researching the adverse health concerns cell phone towers are said to create. I am not a scientist or health care professional, therefore, cannot factually speak to the potential health concerns cell phone towers create. However, a quick Google search provides the reader an abundance of articles and studies completed by health organizations outlining documented cases of the negative health impacts cell phone towers create, most notably in adolescence. Page 444 of 473 From my understanding, the purpose of the cell phone tower is to create a revenue source for the city of Mendota Heights. At what negative cost to the neighborhood is the city willing to invest in for a minimal revenue source? Sincerely, James Lachenmayer Lachenmayer Appraisals, Inc Chief Appraiser, CRRPA License# 20372570 Cell: 651-260-4807 Work: 612-200-8470 jim@lachenmayerappraisals.com Page 445 of 473 To client: Randy Pentel, 815 Deer Trail Ct, Mendota Heights, MN 55118 I have been made aware of the proposed cell phone tower to be located at Wentworth Park in Mendota Heights Minnesota. Property value impacts: In my opinion (as a real estate appraiser), all residential properties within a visual proximity would be adversely affected by the impact of a (proposed) cell phone tower as related to the diminished views from windows, yards, decks, etc. It is reasonable to assume that this would have a negative impact on not only property values of homes within sight of the proposed cell tower but also to potential buyers of said properties (overall “marketability” adversely impacted). Health concern impacts: As a real estate appraiser, I am not qualified to expertly address the possible health concerns related to proximity to cell towers; however, I can attest to my experience as an appraiser with property owners expressing said health (and view) concerns over the past 30+ years as it relates to their concerns over negative value impacts and soliciting my opinion as an appraiser. Furthermore, I can attest to my experience as a Minnesota citizen who has seen local and national news stories and articles related to this topic. Therefore, it is reasonable to assume that the proposed cell tower would raise serious health related concerns to not only nearby property owners but to residents who frequent the affected park with small children. In my opinion, many would likely choose a different (cell tower free) park to visit . Lastly, in my years as Minnesota resident, I cannot recall seeing a cell tower built in a public city park. Qualifications: I, Richard Forsythe have over 40 years of residential appraisal experience (see attached license) and over 20 years of eminent domain appraisal experience involving partial and total acquisitions to residential properties in greater Twin cities metro area of Minnesota. Note, although this is not an actual appraisal with a valuation conclusion, I have lent opinions as an appraiser; therefore, a copy of my appraiser license is attached. Sincerely, Richard J Forsythe/Appraiser Page 446 of 473 Page 447 of 473 Superimposed view of proposed Cell Tower in park Page 448 of 473 Superimposed (before & after) view of proposed Cell Tower from residence Page 449 of 473 Circled location of proposed Cell Tower in park Page 450 of 473 Radius showing location of proposed Cell Tower in park Page 451 of 473 Page 452 of 473 Page 453 of 473 Page 454 of 473 Page 455 of 473 Kevin Byrnes April 23, 2026 740 Wentworth Ave Mendota Heights, MN 55118 Mendota Heights Planning Commission City of Mendota Heights 1101 Victoria Curve Mendota Heights, MN 55118 Re: Case No. 2026-05, Proposed Wireless Telecommunications Tower at Wentworth Park Dear Members of the Planning Commission: I submit this comment for the record in connection with Case No. 2026-05, the Conditional Use Permit (CUP) application for the construction of a 150-foot freestanding wireless telecommunications tower at Wentworth Park. After reviewing the Community Development staff memorandum and the governing provisions of City Code Title 12, Chapter 4, Article A, Section 12 (hereinafter “Section 12-4A-12B.7”), I believe the application as submitted cannot be approved because the proposed tower height exceeds the maximum height permitted by the plain language of the Zoning Code at the proposed location. The tower height limitation in Section 12-4A-12B.7.d.(2) does not appear to have been applied in the staff analysis. I would request that the Planning Commission apply it before making any recommendation. Absent some provision that I have overlooked, it appears the code would limit the height of a tower in the proposed location to 49ft. This is based on the proximity to the Williams property line. 1. The Zoning Code Contains Two Separate Requirements Section 12-4A-12B.7.d establishes two distinct requirements for freestanding antenna towers. These are not redundant, and compliance with one does not establish compliance with the other: Subsection (2) — Height. "The maximum height of a freestanding antenna tower is 150-feet, as measured from the ground to the highest point of any portion of the tower, antenna, or any other component attached thereto, or the distance between the base of the antenna tower and the nearest setback line, whichever is least." Subsection (3) — Setbacks. "All freestanding antenna towers and accessory structures must adhere to all appropriate setbacks for the Base Zoning District of the property on which the structure is located." Subsection (3) governs where the tower and accessory structures may be placed on the parcel. Subsection (2) separately governs how tall the tower may be once its location is established. The height test in subsection (2) uses the setback lines as inputs, but it produces a distinct, location-specific height cap that operates independently of — and in addition to — the setback requirement in subsection (3). Page 456 of 473 2. The Staff Memorandum Applies Only the Setback Requirement The Community Development memorandum for Case No. 2026-05 states: “The proposed location is compliant with the setbacks for a structure in the base zoning district. The underlying R-1 district setbacks are 30-ft for front yard, 10-ft for side yard, and 30-ft for rear yard. The location of the 50-ft x 50-ft site area will exceed each of those setback requirements, located approximately 270-ft from the front property line (facing Wentworth Avenue), 34-ft from the side property line to the west, and 236-ft to the north (rear) lot line.” This analysis correctly addresses subsection (3) — setback compliance for the physical location of the 50-ft x 50-ft compound. However, the memorandum does not apply the separate height test required by subsection (2). Subsection (2) requires the City to determine the distance between the tower base and the nearest setback line, and to cap the tower height at that distance if it is less than 150 feet. 3. Application of Subsection (2) Yields a 49-Foot Height Limit Applying the plain language of Section 12-4A-12B.7.d.(2) to the dimensions provided in the application: • The west edge of the 50-ft x 50-ft enclosure is 34 feet from the west property line. • The base of the tower is set approximately 25 feet east of the west edge of the enclosure. • The base of the tower is therefore 34 + 25 = 59 feet from the west property line. • The R-1 side yard setback is 10 feet, so the side setback line is located 10 feet inside the west property line. • The distance from the base of the tower to the nearest setback line (the west side setback line) is therefore 59 − 10 = 49 feet. Under Section 12-4A-12B.7.d.(2), the maximum allowed tower height at this location is the lesser of 150 feet or 49 feet. The maximum permissible tower height at the proposed location is therefore 49 feet. The proposed 150-foot tower exceeds this limit by more than three times. The application as submitted does not comply with subsection (2) and cannot be approved at the proposed height. 4. No Exception in the Code Permits the Proposed Height I have reviewed Section 12-4A-12 in its entirety and cannot identify any exception that would relieve the applicant from the height limitation in subsection (2) at this location: • Subsection (3)(A) (the 200-foot residential structure separation requirement for towers between 75 and 150 feet) is an additional restriction layered on top of subsection (2); it does not replace or override the height cap derived from setback lines. Page 457 of 473 • Subsection (3)(B) (the height-plus-15-feet exception) applies only when the tower is “located on the same parcel of land as a residential structure.” Wentworth Park contains no residential structure; this exception is inapplicable. • Section D.4.d (Variances) permits the City Council, at its discretion, to waive requirements to approve a “stealth” or “camouflage” design. This is a discretionary variance and has not been invoked in the application; it also does not apply to a conventional 150-foot monopole. Furthermore a variance has a higher threshold for approval than an condition use. Absent a qualifying exception, subsection (2) applies in full. 5. The Outcome Is Consistent with the Stated Purpose of the Ordinance This is not a hypertechnical reading of the Code. The height-limited-by-setback rule exists precisely to accomplish the purposes stated in Section 12-4A-12B.7.a, which include: • “Avoid potential damage to adjacent properties and personal injury from tower collapse through structural standards and setback requirements” (subsection (a)(1)); and • placing telecommunication facilities in suitable locations, “with residential locations being a last resort” (subsection (a)(7)). Separately, Section 12-4A-12B.7.d.(1) (Location Limitations) requires that any antenna support structure “shall be located to have the least impact possible on adjoining properties, and so that any negative impacts of the antenna support structure shall be confined as much as possible to the property on which the antenna support structure is located.” A 150-foot tower sited 59 feet from a residential property line — such that its fall zone and aesthetic impact extend substantially onto adjacent private property — is directly at odds with this requirement. 6. Requested Action I request that the Planning Commission: 1. Apply Section 12-4A-12B.7.d.(2) to the proposed site and confirm the maximum permissible tower height at the proposed tower-base location; 2. Recommend denial of the Conditional Use Permit, on the ground that a 150-foot tower at the proposed location is not permitted by the plain language of the Zoning Code. I believe there are many other factors that support the denial of this application, but before even considering those, the application must meet the baseline requirements of the zoning ordinance. Thank you for your careful consideration of this comment. I appreciate the Commission's attention to the plain language of the Zoning Code and the interests of adjoining property owners that the setback and height provisions are designed to protect. Thank you, Kevin Byrnes Page 458 of 473 Mail Processing Center Federal Aviation Administration Southwest Regional Office Obstruction Evaluation Group 10101 Hillwood Parkway Fort Worth, TX 76177 Aeronautical Study No. 2026-AGL-3933-OE Page 1 of 7 Issued Date: 03/06/2026 THE TOWERS, LLC RICHARD HICKEY 22 West Atlantic Avenue Suite 310 Delray Beach, FL 33444 ** DETERMINATION OF NO HAZARD TO AIR NAVIGATION ** The Federal Aviation Administration has conducted an aeronautical study under the provisions of 49 U.S.C., Section 44718 and if applicable Title 14 of the Code of Federal Regulations, part 77, concerning: Structure:Antenna Tower US-MN-5418 - BLOWFISH County, State:Dakota, Minnesota Collected Point(s): Label Latitude Longitude SE DET AGL AMSL pt-1 44-53-56.08N 93-7-20.30W 885 Ft 155 Ft 1040 Ft This aeronautical study revealed that the structure does not exceed obstruction standards and would not be a hazard to air navigation provided the following condition(s), if any, is(are) met: Emissions from this site must be in compliance with the parameters set by collaboration between the FAA and telecommunications companies and reflected in the FAA 5G C band compatibility evaluation process (such as power, frequencies, and tilt angle). Operational use of this frequency band is not objectionable provided the Wireless Providers (WP) obtain and adhere to the parameters established by the FAA 5G C band compatibility evaluation process. Failure to comply with this condition will void this determination of no hazard. It is required that FAA Form 7460-2, Notice of Actual Construction or Alteration, be e-filed any time the project is abandoned or: _____ At least 10 days prior to start of construction (7460-2, Part 1) __X__ Within 5 days after the construction reaches its greatest height (7460-2, Part 2) See attachment for additional condition(s) or information. Based on this evaluation, marking and lighting are not necessary for aviation safety. However, if marking/ lighting are accomplished on a voluntary basis, we recommend it be installed in accordance with FAA Advisory circular 70/7460-1 M Change 1. This determination expires on 09/06/2027 unless: Page 459 of 473 Page 2 of 7 (a)the construction is started (not necessarily completed) and FAA Form 7460-2, Notice of Actual Construction or Alteration, is received by this office. (b)extended, revised, or terminated by the issuing office. (c)the construction is subject to the licensing authority of the Federal Communications Commission (FCC) and an application for a construction permit has been filed, as required by the FCC, within 6 months of the date of this determination. In such case, the determination expires on the date prescribed by the FCC for completion of construction, or the date the FCC denies the application. NOTE: REQUEST FOR EXTENSION OF THE EFFECTIVE PERIOD OF THIS DETERMINATION MUST BE E-FILED AT LEAST 15 DAYS PRIOR TO THE EXPIRATION DATE. AFTER RE-EVALUATION OF CURRENT OPERATIONS IN THE AREA OF THE STRUCTURE TO DETERMINE THAT NO SIGNIFICANT AERONAUTICAL CHANGES HAVE OCCURRED, YOUR DETERMINATION MAY BE ELIGIBLE FOR ONE EXTENSION OF THE EFFECTIVE PERIOD. This determination is based, in part, on the foregoing description which includes specific coordinates, heights, frequency(ies) and power. Any changes in coordinates, heights, and frequencies or use of greater power, except those frequencies specified in the Colo Void Clause Coalition; Antenna System Co-Location; Voluntary Best Practices, will void this determination. Any future construction or alteration, including increase to heights, power, or the addition of other transmitters, requires separate notice to the FAA.This determination includes all previously filed frequencies and power for this structure. If construction or alteration is dismantled or destroyed, you must submit notice to the FAA within 5 days after the construction or alteration is dismantled or destroyed. This determination does include temporary construction equipment such as cranes, derricks, etc., which may be used during actual construction of the structure. However, this equipment shall not exceed the overall heights as indicated above. Equipment which has a height greater than the studied structure requires separate notice to the FAA. This determination concerns the effect of this structure on the safe and efficient use of navigable airspace by aircraft and does not relieve the sponsor of compliance responsibilities relating to any law, ordinance, or regulation of any Federal, State, or local government body. A copy of this determination will be forwarded to the Federal Communications Commission (FCC) because the structure is subject to their licensing authority. If we can be of further assistance, please contact our office at 1-817-222-5323, or Marla.Duchatellier@faa.gov. On any future correspondence concerning this matter, please refer to Aeronautical Study Number 2026- AGL-3933-OE. Signature Control No: 694867820-695864739 ( DNE ) Marla Duchatellier Technician Attachment(s) Additional Information Frequency Data Page 460 of 473 Page 3 of 7 Map(s) cc: FCC Page 461 of 473 Page 4 of 7 Additional information for ASN 2026-AGL-3933-OE BASIS FOR DECISION Part 77 authorizes the FAA to evaluate a structure or object's potential electromagnetic effects on air navigation, communication facilities, and other surveillance systems. It also authorizes study of impact on arrival, departure, and en route procedures for aircraft operating under visual or instrument flight rules, as well as the impact on airport traffic capacity at existing public use airports. Broadcast in the 3.7 to 3.98 GHz frequency (5G C band) currently causes errors in certain aircraft radio altimeters and the FAA has determined they cannot be relied upon to perform their intended function when experiencing interference from wireless broadband operations in the 5G C band. The FAA has adopted Airworthiness Directives for all transport and commuter category aircraft equipped with radio altimeters that prohibit certain operations when in the presence of 5G C band. This determination of no hazard is based upon those mitigations implemented by the FAA and operators of transport and commuter category aircraft, and helicopters operating in the vicinity of your proposed location. It is also based on telecommunication industry and FAA collaboration on acceptable power levels and other parameters as reflected in the FAA 5G C band evaluation process. The FAA 5G C band compatibility evaluation is a data analytics system used by FAA to evaluate operational hazards related to aircraft design. The FAA 5G C band compatibility evaluation process refers to the process in which the telecommunication companies and the FAA have set parameters, such as power output, locations, frequencies, and tilt angles for antenna that mitigate the hazard to aviation. As the telecommunication companies and FAA refine the tools and methodology, the allowable frequencies and power levels may change in the FAA 5G C band compatibility evaluation process. Therefore, your proposal will not have a substantial adverse effect on the safe and efficient use of the navigable airspace by aircraft provided the equipment and emissions are in compliance with the parameters established through the FAA 5G C band compatibility evaluation process. Any future changes that are not consistent with the parameters listed in the FAA 5G C band compatibility evaluation process will void this determination of no hazard. Page 462 of 473 Page 5 of 7 Frequency Data for ASN 2026-AGL-3933-OE LOW FREQUENCY HIGH FREQUENCY FREQUENCY UNIT ERP ERP UNIT 6 7 GHz 42 dBW 6 7 GHz 55 dBW 10 11.7 GHz 42 dBW 10 11.7 GHz 55 dBW 17.7 19.7 GHz 42 dBW 17.7 19.7 GHz 55 dBW 21.2 23.6 GHz 42 dBW 21.2 23.6 GHz 55 dBW 614 698 MHz 1000 W 614 698 MHz 2000 W 698 806 MHz 1000 W 806 824 MHz 500 W 806 901 MHz 500 W 824 849 MHz 500 W 851 866 MHz 500 W 869 894 MHz 500 W 896 901 MHz 500 W 901 902 MHz 7 W 929 932 MHz 3500 W 930 931 MHz 3500 W 931 932 MHz 3500 W 932 932.5 MHz 17 dBW 935 940 MHz 1000 W 940 941 MHz 3500 W 1670 1675 MHz 500 W 1710 1755 MHz 500 W 1850 1910 MHz 1640 W 1850 1990 MHz 1640 W 1930 1990 MHz 1640 W 1990 2025 MHz 500 W 2110 2200 MHz 500 W 2305 2360 MHz 2000 W 2305 2310 MHz 2000 W 2345 2360 MHz 2000 W 2496 2690 MHz 500 W 3700 3980 MHz 3280 W Page 463 of 473 Page 6 of 7 Verified Map for ASN 2026-AGL-3933-OE Page 464 of 473 Page 7 of 7 TOPO Map for ASN 2026-AGL-3933-OE Page 465 of 473 Wireless Towers Ordinance INDUSTRIAL, TRANSPORTATION AND UTILITY USE SPECIFIC REGULATIONS: 7. Wireless Antennas, Towers, and Accessory Structures. Wireless telecommunication towers, antennas, and accessory structures, including, but not limited to, cellular, Personal Communications Service (PCS) technology, and wireless internet, are a Conditional Use in all Base Zoning Districts, subject to the requirements and exceptions of this Section. a. Purpose. To protect the public health, safety and general welfare of the community while accommodating the communication needs of residents and businesses, the City Council finds that this Section is necessary to: (1) Avoid potential damage to adjacent properties and personal injury from tower collapse through structural standards and setback requirements. (2) Protect the aesthetic qualities of the community by requiring tower and antenna equipment to be designed in a manner to blend in with the surroundings and complement existing structures. (3) Maximize the use of existing and approved freestanding antenna towers, buildings, and existing light poles for new wireless telecommunication antennas. (4) Minimize the number of freestanding antenna towers needed to serve the community by requiring co-location. (5) Facilitate the provision of wireless telecommunication services to the residents and businesses of the City. (6) Ensure that a competitive and broad range of telecommunications services and high-quality telecommunications infrastructure are provided to serve the community, as well as serve an important and effective part of the city’s emergency response network. (7) Place telecommunication facilities in suitable locations, with residential locations being a last resort. b. Definitions. The defined terms identified in this subsection are provided in Chapter [8] of this Zoning Ordinance. c. Building Mounted Antennas. (1) Permitted Buildings. Antennas may be mounted on institutional buildings (churches, schools, businesses, etc.) or multiple-family dwellings two (2) stories or higher. Page 466 of 473 Wireless Towers Ordinance Wireless telecommunications antennas are not permitted on attached or detached single- family homes or attached single-family (townhome) homes. (2) Flush Mounting; Color. (A) Building mounted antennas must be flush mounted to the sides of the building and painted the color of the building exterior unless the applicant can demonstrate to the City Council that protrusion above the roofline is necessary for communication effectiveness. (B) In no case shall building mounted antennas or any attachment thereto be allowed to protrude more than 15-feet above the roofline of the building. (C) Agreement to Mount on City Property. If both the applicant and the City consent to mounting the antennas on the City’s water tower or other municipal building, a developer’s agreement may be necessary at the discretion of the City in addition to a Conditional Use Permit. d. Freestanding Antennas and Towers. (1) Location limitations. The location of any antenna support structure on a particular parcel of land shall be located to have the least impact possible on adjoining properties, and so that any negative impacts of the antenna support structure shall be confined as much as possible to the property on which the antenna support structure is located. (2) Height. The maximum height of a freestanding antenna tower is 150-feet, as measured from the ground to the highest point of any portion of the tower, antenna, or any other component attached thereto, or the distance between the base of the antenna tower and the nearest setback line, whichever is least. (3) Setbacks. All freestanding antenna towers and accessory structures must adhere to all appropriate setbacks for the Base Zoning District of the property on which the structure is located. (A) Antenna support structures between 75-feet and 150-feet tall shall not be constructed within 200 feet of any residential principal structure. (B) Notwithstanding (A), if an antenna support structure is located on the same parcel of land as a residential structure, the setback to that residential structure may be equal to the height of the antenna support structure plus 15 feet. Page 467 of 473 Wireless Towers Ordinance e. Preferences for antenna and support structure locations. When selecting sites for the construction of new antenna support structures and/or for the placement of new antennas, the following preferences shall be followed: (1) Preferred Land Use Areas. (A) Property in the B-1, B-2 or Industrial Zoning District. (B) Athletic complexes, municipal property or Public/Semi-Public uses. (C) Parking lots, if the monopole replicates, incorporates or substantially blends in with the overall lighting standards of the lot. (D) Within the easement of a high-power overhead transmission line, or within 50 feet of the transmission line easement on the same side of the road. (2) Alternate land use areas. (A) Public parks or open spaces. (B) Golf courses. (C) Residential area. (3) Preferred Support Structures. (A) Water towers (B) Co-location on existing antenna support structures. (C) Church steeples. (D) Sides of buildings over two stories high. (E) Existing power, lighting or phone poles. (4) Prohibitions. (A) No new support structures shall be approved at any location other than a Preferred Land Use Area, unless the applicant shows to the reasonable satisfaction of the city that such locations are not feasible from an engineering standpoint. (B) No new support structures shall be approved for construction, unless the applicant shows to the reasonable satisfaction of the city that a preferred support structure is not feasibly available for use from an engineering standpoint. f. Aesthetics. Page 468 of 473 Wireless Towers Ordinance (1) Design. All freestanding antenna towers shall be of a monopole type design. The use of guyed towers is prohibited. (2) Color. (A) Those portions of all freestanding antenna towers and all antennas which protrude into the air shall be painted eggshell. (B) Those portions of all antennas that are flush mounted to the sides of buildings shall be painted to match the exterior of the building. (3) Screening. All accessory buildings to all freestanding towers shall be screened from public view by a landscape plan according to the landscape standards of the applicable Base Zoning District and as described in [Section 12-4A-5 ] of this article subject to City Council review. (4) Advertising. Advertising of any kind is not permitted on any freestanding antenna tower, antenna, or accessory structure. (5) Lighting. Artificial lighting of any kind is not permitted on any freestanding antenna tower, antenna, or accessory structure unless such lighting is required by the FCC, the FAA, or another federal or state regulatory body. If such a requirement exists, only the minimum amount of lighting required is allowed. (6) Prohibitions. Structures, functions, uses or activities that are not found by the City to be specifically necessary for the proper functioning of the antennas are prohibited on any antenna or tower without express permission from the City and the City grants a waiver to this requirement. g. Safety. (1) Report of Compliance. For a freestanding antenna tower, the applicant must provide a report from a licensed qualified professional structural engineer certifying that the tower will meet or exceed current EIA/TIA-222-E standards including, but not limited to, standards for withstanding meteorological conditions such as high winds and radial ice. (2) Compliance with Building and Electrical Codes. All antennas, freestanding antenna towers, and accessory structures shall conform to all building and electrical codes. (3) Fencing. The applicant may be required by the City Council to erect a security fence around any freestanding antenna. h. Accessory Structures for Antennas. Page 469 of 473 Wireless Towers Ordinance (1) Location and General Requirements. Accessory buildings to antennas or freestanding antenna towers must comply with all applicable setbacks from all property lines and must otherwise conform to all requirements for accessory buildings within the description of the Base Zoning District on which the structure is located. i. Architecture. (1) Accessory structures and equipment buildings shall be designed to be architecturally compatible with any principal structures on the site or, in the absence of such structures, with their immediate surroundings in an aesthetically pleasing manner. (2) Accessory structures must be finished on all sides. (3) The Planning Commission must review, and the City Council shall approve, the design of any accessory structures and equipment buildings. C. Submission Requirements. 1. Initial Application Requirements. In addition to the information required for a Conditional Use Permit or Administrative Permit, the following additional information must be supplied by the Applicant and a qualified, licensed registered professional engineer: a. Description of the tower height and design, including a cross-section, elevation and site elevation. b. Documentation of the height above grade for all potential mounting positions for co-located antennas and the minimum separation distances between antennas. c. Description of the tower’s capacity, including the number and type of antennas that it can accommodate. d. Coverage Capacity Analysis. Coverage map and or analysis that demonstrates that no other support structures, or if applicable Preferred Land Use Areas, are available to meet coverage demand. The applicant shall demonstrate, by providing a coverage/interference analysis and capacity analysis, that the location and height of any freestanding antenna tower or antenna as proposed is necessary to meet the communication, frequency reuse and spacing needs of the communication services system, and to provide adequate coverage and capacity to areas that cannot be adequately served by locating the towers in a less restrictive district or on an existing structure, freestanding antenna tower or antenna including such in neighboring municipalities. e. Area Map. All applications for either a freestanding antenna, a freestanding antenna tower, or a building mounted antenna shall be accompanied by a map of all Page 470 of 473 Wireless Towers Ordinance existing towers and antennas of the same provider within a two (2) mile radius of the proposed site and all future planned antennas of the same provider for the next five (5) years within a two (2) mile radius of the proposed site. f. Inclusion of the engineer’s stamp and registration number. g. The city, at its reasonable discretion, may require visual impact demonstrations including mock-ups and/or phot simulations that provide an accurate visual depiction of the tower. h. A written description of the type of technology each company/carrier will provide to its customers. i. A listing of all existing, existing to be upgraded or replaced, and proposed communication sites within the city and within five miles of the city for these services. j. An electronic, to-scale copy of a map of the city showing the five-year plan for communication sites, or if individual properties are not known, the geographic service areas of the communication sites. Any existing tower locations must be clearly identified. D. Additional Requirements. 1. Abandoned Structures. a. Removal Required. Unused or obsolete freestanding antenna towers, antennas, structures or apparatus must be removed within six (6) months of when the operation ceases. b. Bond. A successful applicant shall provide an abandonment bond to the City equal to one and a half (1 1/2) times the current cost of removal and disposal of all antennas and accompanying apparatus as estimated by a consultant selected by the City and paid for by the applicant, which bond shall be used by the City to remove the antennas and apparatus should they become unused or obsolete and the applicant or its successors or assigns become disbarred or otherwise fail to remove said antennas and apparatus. 2. No new antenna support structures shall be constructed if it is feasible to locate the proposed new antenna on existing support structures. Feasibility shall be determined according to generally accepted engineering principles. If a new antenna support structure is to be constructed, it shall be designed structurally to accommodate both the applicant’s antennas and comparable antennas for at least two additional users if the antenna support structure is 75-feet or more. Any antenna support structure must also be designed to allow for future rearrangement of antennas upon the tower and to accept antennas mounted at different heights. Other users shall include, but not be limited to, other cellular Page 471 of 473 Wireless Towers Ordinance communication companies, personal communication systems companies, local police, fire and ambulance companies. 3. Other Required Licenses. The applicant must submit proof of any applicable federal, state, or local licenses to the City prior to receiving a building permit. 1. Interference with Public Safety Systems Prohibited. The applicant must agree in writing to support, participate in and refrain from interfering with public warning systems and public safety communications and other radio frequencies as may be regulated by the Federal Communications Commission (FCC). 4. Compliance with FCC Regulations; Noninterference Required. All new or existing telecommunications service and equipment shall meet or exceed all Federal Communications Commission (FCC) standards and regulations and shall not interfere with any other communications, computers, laboratory equipment or manufacturing equipment, including television and other home electronics. The applicant shall provide to the City a report from a qualified professional engineer guaranteeing noninterference and a copy of the FCC approval of the antenna in regard to noninterference. a. Environmental Impact Statement (EIS). In the event that the FCC or other agency or other governmental body having jurisdiction requires the applicant to submit an Environmental Impact Statement or similar document, a copy of this document shall be submitted to the City. b. Nonconformances. Existing nonconforming freestanding antenna towers, antennas, or accessory structures shall be allowed to continue operation unless use of the freestanding antenna tower, antenna, or accessory structure for its intended purpose ceases for a continuous period of six (6) months, in which case, resumption of use shall require a reapplication for a Conditional Use Permit. c. Costs to Applicant. All costs of an application, including, but not limited to, those incurred by City staff time and resources, engineering studies by consultants, and other data as may be required by the City staff, the planning commission or the City council shall be borne in full by the applicant. d. Variances. The City Council may at its discretion waive any or all of the requirements of this Section in order to approve a unique “stealth” or “camouflage” design of freestanding antennas or poles or building mounted antennas if, in the opinion of the City Council, said apparatus will be sufficiently disguised as trees, light poles, church steeples, or other similar objects. Page 472 of 473 Wireless Towers Ordinance e. Prohibitions. Use of mobile cell/PCS sites or COWs (cell sites on wheels), or any other temporary antenna apparatus is strictly prohibited except in the case of emergency equipment used for public safety purposes for a limited time during or in the immediate aftermath of a natural disaster or other emergency. f. Administrative Procedures and Exemptions. The Zoning Administrator will review Conditional Use Permit requests for improvements to existing wireless antenna facilities and follow the process as established in Chapter [5] of this Zoning Ordinance. The City may impose such conditions and require such guarantees deemed reasonable and necessary to protect the public interest and ensure compliance with the standards and purposes of this code. g. Exceptions for Administrative Permit. An Administrative Permit may replace the need for Conditional Use Permit when all of the following conditions exist: (1) Requirements in of this Section [D] are met and submitted for review. (2) Request seeks to adjust, maintain, repair, or replace existing antennas and accessory structures or the elements of an antenna array, including remote radio units (RRU), affixed to a tower or antenna. (3) No increase in the total number of the existing antennas. (4) No increase in the total height of the existing antenna structure. Height of individual building mounted antennas may be increased in compliance with [Section 12- 4A-12 B.7.c.(2)(B)] of this Section. (5) No external modification or expansion of the existing accessory structure. (6) Existing wireless antenna facility, including the wireless antenna structure and accessory structure, is compliant with all conditions contained in the original Conditional Use Permit. (Ord. 592, 9-17-2024; amd. Ord. 603, 10-7-2025) Page 473 of 473