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Plan Review Detail
Review Status: Approved
Review Details: ENTITLEMENT REVIEW v.2
Plan Number - TP-ENT-0725-00013
Review Name: ENTITLEMENT REVIEW v.2
Review Status: Approved
| Review Date | Reviewer's Name | Type of Review | Description | Status | Comments |
|---|---|---|---|---|---|
| Real Estate | NOT REQUIRED | Any proposed improvements being constructed outside property lines and into public rights-of-way require a right-of-way permit and Private Improvement Agreement with the Department of Transportation & Mobility or Temporary Revocable Easement with the Real Estate Division (separate processes). If any action is required to address property rights (dedications, easements, etc), please contact the Real Estate Division 520-791-4181. | |||
| Signs | NOT REQUIRED | ||||
| Streetcar Track Access Review | NOT REQUIRED | ||||
| Entitlement Review Coordinator Express | REVIEW COMPLETED | ||||
| Entitlements | REVIEW COMPLETED | DATE: October 21, 2025 For November 13, 2025 Hearing TO: James Mazzocco FROM: Koren Manning, Director Zoning Examiner Planning & Development Services SUBJECT: SPECIAL EXCEPTION LAND USE PLANNING & AND DEVELOPMENT SERVICES REPORT TP-ENT-0725-00013 Verizon Relish Monopole, S 12th Ave, (MCSE) C-2 (Ward 1) Issue – This is a request by Pinnacle Consulting for approval of a wireless communication facility (WCF). The special exception site is located at 4775 S 12th Avenue, approximately 700 feet north of the intersection of 12th Ave and Irvington Road, on the east side of the road (see Case Location Map). The preliminary development plan (PDP) proposes a 70-foot wireless communication tower with an antenna array mounted at 69 feet, with opportunities for co-location of up to two arrays below. The project is designed to improve service quality and coverage for safety and general communications needs. The proposed ground equipment, including the monopole, will be placed within an approximately 1,600 square-foot (40 by 40 feet) ground area surrounded by an 8-foot-8-inch-high CMU wall. Service access is provided via a gate on the west-facing wall, with a proposed utility access easement extending west to 12th Ave. A communications use of this type in the C-2 zone is subject to Section 4.9.13.P, and 4.9.4.I.2, .3, and .8 of the Unified Development Code (UDC) and requires approval through a Mayor and Council Special Exception Procedure, in accordance with UDC Sec. 3.4.3, for a new tower less than two times the height from the nearest property zoned residential or office, and less than one mile from any existing tower unless documentation that no practical alternative exists. Documentation provided by the applicant indicates that no practical alternative exists, and the tower will be constructed in a mono-elm camouflage scheme to minimize visual impacts. While there is an existing monopole .8 miles away from the project site, it offers neither sufficient height nor opportunity for colocation to meet coverage requirements for the area, as demonstrated by the applicant’s RF frequency analysis. The Mayor & Council Special Exception Procedure requires a public hearing before the Zoning Examiner, after which the Zoning Examiner forwards a recommendation to the Mayor and Council for a decision to grant the request with, or without, conditions or to deny the request. The Mayor and Council may also forward the request to the Design Review Board (DRB) for design review and recommendation. Planning & Development Services Department Recommendation – The Planning & Development Services Department recommends approval of the special exception request, subject to the attached preliminary conditions. Background Information Existing Land Use: The parcel is currently vacant, with occasional food truck use on the area southwest of the proposed cell tower site. Zoning Description: C-2 (Commercial Zone): This zone provides for general commercial uses that serve the community and region. Residential and select other agricultural, civic, recreational, and utility uses may also be permitted that provide reasonable compatibility with adjoining residential uses. Surrounding Zones and Land Uses: North: Zoned C-2; Vacant commercial structure South: Zoned C-2; Tire and wheel shop East: Zoned R-2; Single-family residential West: Zoned C-2; Produce Sales, intermittent food truck use Previous Cases on the Property: None. Related Cases: None. Applicant’s Request – The applicant requests special exception approval for the placement of a 70-foot-high cellular communications monopole. The monopole’s purpose is to resolve coverage gaps in the area and increase the bandwidth available to nearby wireless customers and provide opportunities for co-location to limit unnecessary proliferation of towers in the future. The pole and ground equipment will be contained within a 40 by 40-foot ground equipment area and screened by a CMU wall. Planning Considerations – Land use policy direction for this area is provided by Plan Tucson. Plan Tucson identifies this area in the Future Growth Scenario Map as "Neighborhoods of Greater Infill Potential" and supports new services and amenities that contribute further to neighborhood stability. Policy LT28.1.2 requires that, if possible, wireless communication facilities be located, installed and maintained to minimize visual impacts and preserve views. The proposed wireless communication facility will fulfill demonstrated gap in coverage and bandwidth, which in some areas in the RF study area are insufficient for in-vehicle coverage. The special exception site is located in the northeast corner of an undeveloped parcel along 12th Ave which has occasional food truck use. The nearest residential land use is single-family residential housing across an alley to the east of the site. The applicant estimates that the proposed development will not generate additional measurable vehicle trips per day. ADOT and DTM have provided no comments concerning this development. There is one billboard on the special exception site. Design Considerations Land Use Compatibility – The proposed monopole will be designed to accommodate future wireless carriers. The existing monopole in the vicinity of the target neighborhood lacks sufficient height for co-location, and space on other nearby tall objects is limited. By providing space for future carriers on a 70-foot monopole, the opportunity for other carriers to improve their services will be available without the construction of further poles in the area. The proposed height ensures that antennas co-located on the monopole will offer coverage to a wider area without necessitating additional monopoles. While the pole has been proposed as a mono-elm tower, review by the Transportation Landscape team and further investigation of the site indicate that a mono-pole painted to blend with the sky would be more appropriate to minimize visual impacts. Initially, a mono-elm was supported as the preferred treatment due to a mature Aleppo Pine 300 feet from the project location, but that tree appears to be in very poor health and there are no other tall trees in the immediate vicinity to provide context. A mono-palm scheme was considered, but existing examples of a mono-palm with a total of three arrays, such as the tower located at approximately 4801 N Craycroft Road, are unconvincing and an example of how poorly chosen or implemented camouflage can make a palm design more visually intrusive than a bare pole. The applicant has submitted photo-simulations of the mono-pole. After consideration of the alternatives, painting the pole a blue-gray color to blend with the sky is the appropriate visual treatment. Shrouds were also considered, but the visual bulk of the shrouds increased the visual mass and their strange appearance was more visually memorable than painted antennas, which due to their ubiquitousness blend into the background of the urban landscape. Cell tower location maps showing the potential coverage areas of co-located equipment were submitted with the special exception materials. Staff acknowledge that the proposed monopole will help improve telecom services to the area, and also acknowledges the placement of wireless broadband antennas will help fulfill a communications infrastructure need. The monopole and ground equipment will be placed within a 1,600 square foot ground equipment area in the northeast corner of the subject parcel. Ground equipment will be housed inside cabinets within an area secured by an 8-foot-8-inch CMU wall preventing access to the site. Road Improvements/Vehicular Access/Circulation – No road improvements are proposed with this project. Vehicular access to the wireless communications facility is by way of a proposed access easement to 12th Ave. Federal Regulations – Because this Special Exception application involves a request for a wireless communication facility, the Zoning Examiner’s consideration of the application is impacted by the application of federal laws specific to wireless communications. While federal law does not entirely preempt local decision-making authority based on legitimate zoning requirements, such as community aesthetics and compliance with stealthing requirements, it does impose the following limitations: 1) The decision on the application must occur within the “shot clock” period as provided under federal law, which for this type of application is 150 days. In this case, the application was accepted on September 9, 2025 and the “shot clock” period will expire on February 12, 2026. If a decision is not rendered within the “shot clock” period, the review and consideration process is presumed to be unreasonable and affords the applicant the opportunity to file a lawsuit. If sued, the City would need to prove that it acted “reasonably” when it failed to act within the established “shot clock” period. 2) The evaluation of the request cannot include consideration of potential environmental or health effects of radio-frequency (RF) emissions where, as here, the facility will comply with FCC regulations and standard on such emissions. 3) The decision on the application cannot unreasonably discriminate among providers of functionally equivalent services. A denial may be deemed to be “unreasonable discrimination” if the facility is designed and situated similarly to other previously approved facilities and is no more intrusive than those previously facilities. 4) The decision may not have the effect of prohibiting the provision of wireless services, or of causing a significant gap in the applying provider’s coverage. In this context, the relevant issues are: (1) whether the applicant has shown a significant gap in service coverage; and (2) whether the proposal to fill this gap is the least intrusive means of doing so, or whether there are alternative sites that would fill the gap. 5) In the event of a denial, that decision and its reasons must be delivered to the applicant in writing, and must be supported by substantial evidence. Given these constraints, the Zoning Examiner’s recommendation on this application should focus on whether the applicant has demonstrated a significant coverage gap; whether that gap could be addressed through an installation at an alternative site; and whether the proposed concealment/stealthing measures are sufficient to meet the City’s requirements. The Zoning Examiner should also consider how this application compares to other prior applications for similar facilities. In the event of a recommendation for denial, the reasons must be stated so they can be incorporated into a written decision and captured in the meeting minutes. Use-Specific Standards – The applicant’s proposal requires approval as a Zoning Examiner Special Exception and must meet the Use-Specific Standards of UDC Sections 4.9.4.I.2, .3, and .8. The Zoning Examiner shall render a decision to grant the use with or without conditions, or to deny the use. Below is the analysis of the performance criteria. 4.9.4.I.8 The following requires approval as a special exception in accordance with Section 3.4.4, Mayor and Council Special Exception Procedure. The Mayor and Council may forward the request to the Design Review Board (DRB) for design review and recommendation. a. Wireless communication antennas, provided: (1) The tower or antennas are not permitted by other provisions of this Section. The 70-foot utility pole is located less than two times the height of the structure from the boundary of the residentially zoned property to the east, necessitating a Mayor and Council Special Exception. (2) New towers require a minimum separation of one mile from any existing tower, regardless of ownership, unless documentation establishes that no practical alternative exists. The nearest existing wireless communications facilities are located .8 miles away from the project site. However, there is a demonstrated gap in coverage and bandwidth in the vicinity of the project area. There were no other feasibly located vertical objects in the area sufficient to locate the antennas. (3) All appropriate measures shall be taken to conceal or disguise the tower and antenna from external view. The utility pole and associated wireless equipment will be camouflaged by painting a blue-gray color such as Sherwin Williams Bliss Blue (SW6527) or similar. (4) All appropriate measures shall be taken to reduce the negative proliferation of visible towers and antennae by the collocation of new antennae on existing towers or with the facilities of other providers which are located or planned for development within the proposed service area. The proposed 70-foot-high monopole provides the opportunity for the co-location of up to two arrays below the planned antennas. The applicant has demonstrated a coverage gap in the area, and future co-locations will allow other providers to increase the capacity of their own networks without the construction of additional poles. (5) Notice shall be provided to all agents, in accordance with Section 4.9.4.I.2.g, at least 15 days prior to the date of the public hearing before the Zoning Examiner. All policies of the Mayor and Council Special Exception Process shall be followed accordingly. Staff finds the proposal to be in compliance with the UDC’s Use-Specific Standards. Conclusion – The proposal is in compliance with the performance criteria for a wireless communication facility. The special exception request is consistent with policy direction in Plan Tucson, which supports development designed to be compatible with and sensitive to surrounding land uses. Staff acknowledges that the WCF will help improve telecom services in the area. Subject to compliance with the attached preliminary conditions, approval of the requested special exception is appropriate. |
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| External Reviewers - Arizona Department of Transportation (ADOT) | REVIEW COMPLETED | Thank you for the opportunity to review this new special exception. ADOT has no comments. Rick Freije, M.S.C.E., P.E. Assistant Regional Traffic Engineer SOUTHERN REGION TRAFFIC 1221 S 2nd Ave. Tucson, AZ 85713 Office: 520.388.4203 Mobile: 520.576.8614 | azdot.gov [azdot.gov] |
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| External Reviewers - AZ State Land | REVIEW COMPLETED | ||||
| External Reviewers - COT Environmental Services | REVIEW COMPLETED | ES has no objections or adverse comments to this proposed special exception request. Andy Vera (520) 837-3798 Andy.Vera@tucsonaz.gov |
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| External Reviewers - COT Parks & Recreation | REVIEW COMPLETED | ||||
| External Reviewers - Davis Monthan AFB | REVIEW COMPLETED | Sir/Ma’am We’ve reviewed this proposed reasoning and find it will not impact our mission Thank you Kacey V/r B. Kacey Carter, DAFC, USAF ≡✪≡ Installation Community Planner 355th Civil Engineer Squadron/CENPL Davis-Monthan AFB AZ ☎DSN: 312-3291 ☎Comm: 520-228-3291 bonnie.carter@us.af.mil |
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| External Reviewers - PC RFCD | REVIEW COMPLETED | The Regional Flood Control District has no objection to this special exception. Patricia Gilbert Hydrologist III Floodplain Management Division Pima County Regional Flood Control District 201 North Stone Ave 9th Floor Tucson, Arizona, 85701 Direct - 520.724.4606 |
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| External Reviewers - Pima Association of Governments | REVIEW COMPLETED | ||||
| External Reviewers - Pima County Addressing | REVIEW COMPLETED | The proposed project will need a new address specific to the wireless facility. Please contact Pima County Addressing at 520-724-9512 for guidance. Nicholas Jordan Site Review Project Manager II – Addressing Official Pima County Development Services Department 201 N Stone AV – 1st Floor Tucson, AZ 85701 (520) 724-9623 |
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| External Reviewers - Pima County Assessor | REVIEW COMPLETED | ||||
| External Reviewers - Pima County Development Services | REVIEW COMPLETED | Pima County Development Services Dept. has reviewed Special Exception TP-ENT-0725-00013 – Verizon Relish Monopole, a proposed wireless communication facility with 70' mono-elm in a 35'x45' leased area in a C-2 zoned lot located at the northeast corner of S. 12 Avenue and E. Oklahoma Street. The department has no comment nor objection to the proposed special exception. Thank you for the opportunity to review and comment, Mark Holden Mark Holden, AICP Planner III Pima Co. Development Services Dept. Planning Division (520) 724-6619 |
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| External Reviewers - Pima County Natural Resources | REVIEW COMPLETED | ||||
| External Reviewers - Pima County Transportation | REVIEW COMPLETED | ||||
| External Reviewers - Pima County Wastewater (RWRD) | REVIEW COMPLETED | ||||
| External Reviewers - Tohono Oodham | REVIEW COMPLETED | ||||
| External Reviewers - Tucson Airport Authority | REVIEW COMPLETED | ||||
| External Reviewers - Tucson Electric Power (TEP) | REVIEW COMPLETED | ||||
| External Reviewers - Tucson Unified School District (TUSD) | REVIEW COMPLETED | ||||
| Fire New Construction | REVIEW COMPLETED | ||||
| Historic | REVIEW COMPLETED | Project is not in a HPZ, historic district, or archaeology sensitivity zone. Neither monitoring nor a monitoring waiver is required. | |||
| IPC - Entitlements | REVIEW COMPLETED | ||||
| IPC - Fire New Construction | REVIEW COMPLETED | ||||
| IPC - Site Engineering | REVIEW COMPLETED | ||||
| IPC - Site Zoning | REVIEW COMPLETED | ||||
| IPC - Traffic Engineering | REVIEW COMPLETED | No comments | |||
| ROW Engineering Review | REVIEW COMPLETED | ||||
| Site Engineering | REVIEW COMPLETED | Permit: TP-ENT-0725-00013 Location: 4775 S 12TH AV Review Date: 10/6/2025 Site Engineering Comments: 1. The proposed 8’-8” CMU wall will require a structural wall permit for development. If you have any questions or concerns, please contact Marco Contreras Marco.contreras@tucsonaz.gov |
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| Site Landscape | REVIEW COMPLETED | Consider Transportation Landscape review comment with regard to replacing the mono-elm with the palm tree. Once this design feature has been decided upon, then PDSD Site Landscape will give full approval. Thank you. Chad Keller, RLA chad.keller@tucsonaz.gov |
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| Site Zoning | REVIEW COMPLETED | No comments. | |||
| Sun Tran Review | REVIEW COMPLETED | ||||
| Transportation - Bike/Ped | REVIEW COMPLETED | ||||
| Transportation Landscape Review | REVIEW COMPLETED | A palm tree treatment is more appropriate to this area of town please resubmit with rendering of palm tree treatment instead of the monoelm ***Plans updated to painted monopole -GS |
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| Tucson Water New Area Development | REVIEW COMPLETED | Tucson Water – New Area Development has no comments at this time. There is no observable impact on the existing potable water distribution main. For any questions, contact Mario Rivera Alvarez at mario.riveraalvarez3@tucsonaz.gov |