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Plan Number: TP-ENT-1224-00030
Parcel: 11918040C

Address:
3410 S 16TH AV

Review Status: Approved

Review Details: ENTITLEMENT REVIEW v.1

Plan Number - TP-ENT-1224-00030
Review Name: ENTITLEMENT REVIEW v.1
Review Status: Approved
Review Date Reviewer's Name Type of Review Description Status Comments
Transportation Landscape Review APPROVED
Fire New Construction NOT REQUIRED
IPC - Fire New Construction NOT REQUIRED
Entitlement Review Coordinator Express REVIEW COMPLETED
Entitlements REVIEW COMPLETED DATE: February 25, 2025
For March 13, 2025 Hearing


TO: Frank Cassidy FROM: Koren Manning, Interim Director
Zoning Examiner Planning & Development Services


SUBJECT: SPECIAL EXCEPTION LAND USE
PLANNING & AND DEVELOPMENT SERVICES REPORT
TP-ENT-1224-00030 Milagros Tower, S 16th Ave, (MCSE) MH-1 (Ward 1)

Issue – This is a request by Native Network on behalf of the Pascua Yaqui Tribe, for approval of a wireless communication facility (WCF). The special exception site is located at 3410 S 16th Avenue, approximately one-half mile north of Ajo Way and 150 feet east of Interstate-19 (see Case Location Map).

The preliminary development plan (PDP) proposes an 80-foot wireless communication tower with three broadband wireless internet antennas mounted at 79 feet, with options for future colocation at 69 feet and 69 feet. The project is designed to provide wireless broadband internet to members of the Pascua Yaqui Tribe living in the neighborhoods north-east of the proposed monopole location.

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-high chain-link fence. Access is provided by a 12-foot access gate on the east side of the lease area which opens to the equipment area. Service access is provided via a gate which opens to the cul-de-sac where 44th street terminates before reaching Interstate-19. No access easement is required as the tower equipment area and surrounding parcel are under the ownership of the Pascua Yaqui Tribe.

A communications use of this type in the MH-1 zone is subject to Section 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 painted to minimize visual impacts. The tower will also be placed in a site adjacent to Interstate 19, and located over 500 feet from the nearest residential land use.

While there is an existing monopole 2,200 feet away from the project site, it offers neither sufficient height nor opportunity for colocation to meet the necessary conditions for use of wireless broadband antennas, which require a line of site between the mounted antenna and an end-user’s household equipment.

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: There is a church towards the center of the parcel. The project area is almost 200 feet away from the existing use.

Zoning Description:

MH-1 (Mobile Home Zone): This zone provides for low to medium density, residential development primarily in mobile home buildings on individual lots and within mobile home parks. Civic, educational, recreational, religious uses, and select other uses, such as day care and urban agriculture, are also permitted that provide reasonable compatibility with adjoining residential uses.

Surrounding Zones and Land Uses:

North: Zoned R-1; Assisted Living Facility
South: Zoned MH-1; Vacant Land, same ownership
East: Zoned R-2; Pueblo High School
West: Zoned R-2; Interstate-19

Previous Cases on the Property:
None.

Related Cases:
None.

Applicant’s Request – The applicant requests special exception approval for the placement of a 80-foot high cellular communications monopole. The monopole’s purpose is the placement of broadband wireless antennas to be used by members of the Pascua Yaqui Tribe. The proposed monopole is 80 feet in height to provide opportunities for future co-location for other telecommunications providers. The pole will be painted to minimize visual impacts, and the pole and ground equipment will be contained within an 8-foot chain link fence surrounding the 40 by 40-foot ground equipment area. Additionally, the surrounding parcel is surrounded by an existing 6-foot chain link fence.

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 "Existing Neighborhoods" 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 an important infrastructure need faced by the Pascua Yaqui tribe, and is proposed with future colocation opportunities in mind which will also help improve telecom services in the area.

The special exception site is located in the northwest corner of a larger parcel which currently has a church owned by the Tribe. The nearest residential land use is single-family residential homes approximately 550 feet east of the project location.

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 are no billboards 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 colocation, and space on other nearby tall objects is limited. By providing space for future carriers on an 80-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. The pole will be of galvanized steel with all antennas, mounts, and associated visible equipment painted to match pole color to minimize visual impacts

The applicant has submitted photo-simulations of the monopole. The proposal is for a monopole rather than a stealth tree design, because there are no existing tall trees nearby to provide context, and because it is not in the immediate vicinity of a residential land use. Cell tower location maps showing the potential coverage areas of co-located equipment were submitted with the special exception materials. Staff acknowledges 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 faced by members of the Pascua Yaqui Tribe in the area.

The nearest residential use is approximately 550 feet away, or almost seven times the height of the proposed monopole.

The monopole and ground equipment will be placed within a 1,600 square foot ground equipment area in the northwest corner of the subject parcel. Ground equipment will be housed inside cabinets within an area secured by an 8-foot chain-link fence preventing access to the substation area. Additionally, the surrounding parcel is secured by a 6-foot chain link fence.

Road Improvements/Vehicular Access/Circulation – No road improvements are proposed with this project. Vehicular access to the wireless communications facility is by way of existing access to the parcel. The surrounding parcel, equipment area, monopole, and ground equipment are owned by the Pascua Yaqui Tribe.

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 January 10, 2025 and the “shot clock” period will expire on June 9, 2025. 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 80-foot utility pole is located less than two times the height of the structure from the boundary of the residentially zoned property to the north, 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 one-half mile away from the project site. However, there is inadequate height or availability of space for the installation of the Pascua Yaqui Tribe’s wireless broadband antennas. 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 with be painted to blend into the sky, as there are no surrounding tall trees to provide context for a camouflage scheme such as a mono-elm or mono-palm tower.

(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.

Staff recommended in the pre-application meeting for this project to request an 80-foot monopole to provide the opportunity for the colocation of future arrays. This space reduces the need for additional antennas, offers potential coverage to a large area, and satisfies the needs of the Pascua Yaqui Tribe.

(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.
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, P.E., M.S.C.E.

ASSISTANT SOUTHERN REGION TRAFFIC ENGINEER

ARIZONA DEPARTMENT
OF TRANSPORTATION



1221 S 2nd Ave.

Tucson, AZ 85713

Office: 520.388.4203

Cell: 520.576.8614

Website: azdot.gov [azdot.gov]
External Reviewers - AZ State Land REVIEW COMPLETED No Comments - GS
External Reviewers - COT Environmental Services REVIEW COMPLETED ES has no objections to this special exceptions request as pertains to Solid Waste Collection and Storage requirements.

Andy Vera
(520) 837-3798
Andy.Vera@tucsonaz.gov
External Reviewers - COT Parks & Recreation REVIEW COMPLETED No Comments - GS
External Reviewers - Davis Monthan AFB REVIEW COMPLETED Sir/Ma’am



DMAFB Planning Staff has reviewed the Special Exception and find since it is located outside the DM AEZ there shouldn’t be any negative impact to our mission



Thank



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
External Reviewers - PC RFCD REVIEW COMPLETED The Pima County Regional Flood Control District has no objection to this special request.



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
External Reviewers - Pima Association of Governments REVIEW COMPLETED No Comments - GS
External Reviewers - Pima County Addressing REVIEW COMPLETED Good morning,



Pima County Addressing does not have comments on TP-ENT-1224-00030 Milagros Tower – 3410 S 16th Ave.



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
External Reviewers - Pima County Assessor REVIEW COMPLETED Good morning.



I receive these notices for informational purposes only. I have no comments.



Thank you,



Linda Chabot

Senior Property Appraiser

Commercial/Industrial Land

Pima County Assessor’s Office

240 N. Stone, 3rd Floor

Tucson, AZ 85701

(520) 724-7422
External Reviewers - Pima County Development Services REVIEW COMPLETED Anita McNamara<Anita.McNamara@pima.gov>



TucsonRezoning

Thank you for the opportunity to provide input on this application.



Pima County Development Services has no concerns or comments.



Thank you.
External Reviewers - Pima County Natural Resources REVIEW COMPLETED No Comments - GS
External Reviewers - Pima County Transportation REVIEW COMPLETED No Comments - GS
External Reviewers - Pima County Wastewater (RWRD) REVIEW COMPLETED REGIONAL WASTEWATER RECLAMATION DEPARTMENT
201 NORTH STONE AVENUE
TUCSON, ARIZONA 85701-1207
JACKSON JENKINS PH: (520) 724-6500
DIRECTOR FAX: (520) 724-9635
January 17, 2025
City of Tucson
Entitlements Section
Attn: Gabriel Sleighter
255 W. Alameda Street
Tucson, Arizona 85701
RE: TP-ENT-2334-00030
Dear Ms. Sleighter:
The Pima County Regional Wastewater Reclamation Department (RWRD) has reviewed the request to
site an 80-foot monopole telecommunications tower on Pima County Assessor’s Parcel Number (APN)
119-18-040C, 3410 S 16th Avenue. RWRD maintains a 24-inch interceptor line within a 15-foot public
sewer easement recorded in Book 698, Page 8 of the Pima County Recorder’s Office.
Based on the information provided RWRD cannot currently comment on the request regarding the
proposed telecommunications pole. RWRD utility coordination will require submittal of a set of plans
detailing the proposed installation including the location of the existing public sewer interceptor.
A paperless submittal and an electronic copy (PDF) of the submittal package can be emailed to:
RWRDUtilityCoord@pima.gov.
More information about the UC process can be found on our webpage at
http://webcms.pima.gov/cms/one.aspx?portalId=169&pageId=177411.
If the applicant has any questions, please email Thomas.Porter@pima.gov or call at (520) 724-6719.
Thank you for the opportunity to review and comment on the proposed action.
Sincerely,
Steven Reuter
Program Manager
RWRD
520.724.6608
Cc: Jaime Rivera, P.E., Deputy Director, Technical Services & Engineering
External Reviewers - Tohono Oodham REVIEW COMPLETED No Comments - GS
External Reviewers - Tucson Airport Authority REVIEW COMPLETED February 4, 2025
Gabriel Sleighter
Public Works Building 1
st Floor
201 N. Stone Avenue
Tucson, AZ. 85701
RE: TP-ENT-1224-00030 – Milagros Tower – 3410 S 16th Ave, New Special Exception, Ward 1,
Received January 15, 2025
Dear Mr. Sleighter,
Thank you for the opportunity to comment on TP-ENT-1224-00030 – Milagros Tower – 3410 S
16th Ave a request by NV5 for a special exception use permit for parcel number 119-18-040C to
establish a new communications monopole. This parcel occupies 12.571 ± acres and is located
500 feet southwest of the intersection South 16th Avenue and West 44th Street. This parcel is
located within the NE ¼ of the SW ¼ of Section 26, Township 14S, Range 13E, of the Gila and
Salt River Meridian.
The Tucson Airport Authority approves the subject special exception request and has no
additional comments to provide.
Please do not hesitate to contact me if you have any questions or concerns regarding this
comment letter. I may be reached by email at srobidoux@flytucson.com or by telephone at 520-
573-4811.
Respectfully,
Scott Robidoux, C.M.
Manager of Planning
External Reviewers - Tucson Electric Power (TEP) REVIEW COMPLETED January 22, 2025
City of Tucson
Gabriel Sleighter
Entitlements Section
RE: TP-ENT-1224-00030 - Milagros Tower – 3410 S 16th Ave
Dear Mr. Sleighter;
On behalf of Tucson Electric Power (TEP), thank you for the opportunity to comment on this
special exception memorandum. TEP has no objections to this memo. This property is located
within TEP’s service territory and will require a new service application from the
owner/developer to extend service to the new location.
Please email me with any questions or concerns. I can be reached at Keri.Tallorin@tep.com, or
by phone at (425) 633-7431.
Respectfully,
Keri Tallorin, AICP
Environmental & Land Use Planner
A consultant for Tucson Electric Power Company
a UNS Energy Corporation
External Reviewers - Tucson Unified School District (TUSD) REVIEW COMPLETED No Comments - GS
Historic REVIEW COMPLETED This project is located in an Archaeological Sensitivity Zone. An Archaeological Monitor hired by the permit applicant is required to be on-site during any digging, unless a waiver is issued. Monitoring reports are to be submitted to the Historic Preservation Office, City of Tucson, P.O. Box 27210, Tucson, AZ 85726. Additionally, any historic or prehistoric features or artifacts discovered during future ground disturbing activities should be reported to the City of Tucson Historic Preservation Officer. Pursuant to A.R.S. 41-865 the discovery of human remains, and associated objects found on private lands in Arizona must be reported to the Director of Arizona State Museum.
If you have any questions on historic, contact Michael.Taku@tucsonaz.gov
IPC - Entitlements REVIEW COMPLETED
IPC - Site Engineering REVIEW COMPLETED Engineering has no comments
IPC - Site Zoning REVIEW COMPLETED 1. Please include a general note stating the existing zoning, the proposed use and list the applicable use specific standards.

Loran Shamis
Loran.Shamis@tucsonaz.gov

***To be addressed in staff report/conditions. -GS
IPC - Traffic Engineering REVIEW COMPLETED No concerns from Traffic Engineering
Real Estate REVIEW COMPLETED The Real Estate Division has no objection or comments for the proposed Exception.



Thank you,



Bob Beecher

Supervisor – Real Estate Division

City of Tucson Department of Transportation and Mobility

Main: 520-791-4181

Direct: 520-837-6784

Mobile: 520-451-4923
ROW Engineering Review REVIEW COMPLETED No Comments - GS
Signs REVIEW COMPLETED All signage to be per current code standards.
Site Engineering REVIEW COMPLETED
Site Landscape REVIEW COMPLETED CDRC TRANSMITTAL
PLANNING AND DEVELOPMENT SERVICES DEPARTMENT
REVIEWER: CHAD KELLER, RLA
PDSD LANDSCAPE/NATIVE PLANT PRESERVATION SECTION

GENERAL SITE LANDSCAPE/NPPO COMMENTS PROVIDED DURING THE PRE-APPLICATION MEETING FOR THIS PROJECT:

1. It appears that a protected native plant may be within the construction area of the new tower. Provide transplant or mitigation measures on your site plan if the tree is on the protected native plant list located here: Technical Standards Manual: 5-03.2.0 PROTECTED NATIVE PLANT LIST, or provide a NPPO Waiver for exception to the Ordinance. If a copy of the NPPO Waiver form is needed, please contact me at the email below.

Thank you.
Chad Keller, RLA
chad.keller@tucsonaz.gov
Site Zoning REVIEW COMPLETED
Streetcar Track Access Review REVIEW COMPLETED No Comments - GS
Sun Tran Review REVIEW COMPLETED No Comments - GS
Transportation - Bike/Ped REVIEW COMPLETED No Comments - GS
Tucson Water New Area Development REVIEW COMPLETED No Comments - GS