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5 Lane' Code 16.264(3). Application shall indude evidence of compliance with this requirement. EC 9.5750(6)(c) 2. Alternate Sites. The current code allows applicant to consider alternate sites only in more intensively used commerdal ahd industrial zones. In many areas, this results in a dearth of potential alternative sites. AppliCants should be required to submit'documentation of having considered any feasible sites within the required radius, both in more intensively zoned properties, and in the same zone as the subject property. This provides a larger pool of potential alternative sites, and could make it possible to meet both commUnity and telecommunication provider needs more easily. The required radius should be increased from 2000 to 2600 feet. This is because the coverage footprint for PCS antennas has a diameter of approximately 4 miles, and the antennas can be placed anywhere within a 25% radius of the center and still provide adequate service (radius of a 4mile drde -- 2 miles, 25% of 2 miles = one half mile, or 2640 feet). Again, Planning staff lacks the technical expertise to · determine verity of an applicant's statements regarding RF coverage areas. This points to the need for independent review of ALL applications by a qualified RF engineer, whose fee shall be Paid by the applicant. EC 9.5750(6)(c) 3. Collocation on existing structures. Current code language (regarding the applicant's attempt to collocate on existing structures rather than · ! build a new tower) is so broadly written as to allow the applicant to forego collocation at the wave of a hand. Under current code, an applicant can get out of collocation merely by stating that it is "impractical". In general, there are two types of telecommunications applicants: wireless service providers, and tower contractors. Wireless service providers generally are amenable to collocation, because it saves the expense of putting up new towers, and gets them on the air faster. ToWer contractors are more likely to avoid collocation if pOssible, since they make their money by building new towers and leasing space on them to wireless service providers. In order to preserve property values for homeowners, Collocation on existing structures should be required unless the applicant can document with an independenl~RF engineering report that it is impossible. Wherever possible, mini- cell technologY on light and power poles should be required. This is another provision that cannot be administered .effectively without independent review of ALL applications by an RF engineer. EC 9.5750(6)(c) 5. Current code requires the applicant to submit "A statement Providing the reasons for the location, design, and height of the proposed tower or antennas." To ensure that the appliCant's claims are .accurate, a provision needs to be added, either in the telecommunications code 'itself, or better, in site review and conditional use permit criteria, which sPecifies that applications found to contain false or misleading statements or information will be suspended, and if already approved, will be denied. We have found numerous examples from both Lane County and the City of Eugene in which telecommunications providers have stated IV-78