HomeMy WebLinkAbout20260165 3291 S Broadway Verizon Utility Pole Application
ATTORNEYS AT LAW
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MAIN OFFICE (FOR ALL MAIL): 500 FEDERAL STREET, 5TH FLOOR, TROY, NEW YORK 12180
ALBANY OFFICE: 41 STATE STREET, STE 604-12, ALBANY, NEW YORK 12207
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Phone: 518-438-9907 • Fax: 518-438-9914
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www.youngsommer.com
David C. Brennan, Esq.
Writer’s Telephone Extension: 224
dbrennan@youngsommer.com
February 26, 2026
Via Federal Express
Mark Graham
Administrative Assistant for OPED
City of Saratoga Springs
474 Broadway
Saratoga Springs, New York 12866
RE: Cellco Partnership d/b/a Verizon Wireless Application for DRB Approval
Utility Pole Adjacent to 3291 S Broadway
Dear Mr. Graham:
Please find enclosed an application to the Design Review Board for a proposal to install a
wireless small cell antenna and equipment on a new utility pole in the right of way.
Also enclosed is a check in the amount of $650.00 for the application fee.
We look forward to discussing this further with the Design Review Board at an upcoming
meeting. In the meantime, if you have any questions concerning this letter or the enclosed
materials, please contact me at your convenience.
Very truly yours,
David C. Brennan, Esq.
Encl.
DESIGN REVIEW BOARD
CITY OF SARATOGA SPRINGS, SARATOGA COUNTY, NEW YORK
In the Matter of the Application of
______________________________________________________________
CELLCO PARTNERSHIP
d/b/a Verizon Wireless
Utility Pole Adjacent to 3291 S Broadway
Saratoga Springs, New York 12866
____________________________________________________________
APPLICATION FOR DESIGN REVIEW BOARD APPROVAL
and STATEMENT OF INTENT
Submitted by:
Verizon Wireless
Kathy Pomponio, Manager – Network Real Estate
1275 John Street, Suite 100
West Henrietta, New York 14586
(585) 321-5435
Tectonic Engineering & Surveying Consultants, P.C.
Steven Matthews, P.E.
36 British American Blvd, Suite 101
Latham, New York 12110
(518) 783-1630
Network Building + Consulting
Nico Facey, Project Manager
1777 Sentry Parkway W
VEVA 17, Suite 400
Blue Bell, Pennsylvania 19422
(347) 712-9444
Please Direct All Correspondence To:
Young/Sommer LLC
David C. Brennan, Esq.
500 Federal Street, 5th Floor
Troy NY, 12180
(518) 714-9282
Dated: February 26, 2026
1
DESIGN REVIEW BOARD OF THE CITY OF SARATOGA SPRINGS
SARATOGA COUNTY, NEW YORK
In the Matter of the Application of
___________________________________________________________________
CELLCO PARTNERSHIP d/b/a Verizon Wireless
Premises: Utility Pole -Adjacent to 3291 S. Broadway
Saratoga Springs, New York 12866
___________________________________________________________________
STATEMENT OF INTENT and
APPLICATION FOR DESIGN REVIEW BOARD APPROVAL
I. Purpose and Need
CELLCO PARTNERSHIP d/b/a Verizon Wireless (“Verizon Wireless” or the
“Applicant”) proposes the collocation of an unmanned public utility/personal wireless service
facility (a "communications facility") at the above location. More specifically, Verizon Wireless is
proposing to add wireless telecommunications equipment to a proposed utility pole.
The Applicant proposes to install on a proposed utility pole: a single, cylindrical antenna
(approximately 24” tall x 14.6” in diameter) mounted at the top of the pole at a tip height of 42.3±
feet along with the installation of electric and telecommunications equipment on the utility pole
at a minimum height of 8’ above grade. All proposed equipment will be painted brown as noted on
Sheet C-1 and C-2 and consistent with prior DRB approvals for similar projects. The proposed utility
pole measures 38.5± feet above grade. The property is located in the right of way adjacent 3291
S. Broadway, City of Saratoga Springs, Saratoga County, New York. [Zoning Site Plan Drawings
of Tectonic Engineering & Surveying, PC at TAB 6].
Upon completion, the proposed facility will provide additional wireless network
bandwidth and improved performance to the nearby roads and the surrounding areas, as shown
in the accompanying coverage maps. More specifically, the site as proposed will improve
coverage and network performance along the surrounding portion of Route 9, and portions of
Columbia Ave and Kaydeross Ave W [Proposed Coverage Map at TAB 3].
Verizon Wireless is considered a public utility for land use purposes under New York
decisional law (Cellular Telephone Company v. Rosenberg1, 82 N.Y.2d 364 [1993]), and a provider of
“personal wireless services” under the federal Telecommunications Act of 1996 (the “TCA”).
Verizon Wireless’ equipment will be in operation twenty-four (24) hours a day, seven (7) days a
week, three hundred sixty-five (365) days a year.
1 In Rosenberg, the State’s highest Court determined that the ordinary variance standard is inapplicable and a cellular
telephone company applying for relief need only show that (1) the relief is “required to render safe and adequate
service,” and (2) there are “compelling reasons, economic or otherwise,” for needing the variance. Cellular Telephone
Company v. Rosenberg, 82 N.Y.2d 364, 372 (1993).
2
Verizon Wireless is applying for review by the Design Review Board.2 The proposed
utility pole is located in the Gateway Commercial Residential (GC-R) Zoning District. The facility
is not located in the Historic Review District but is located in the Architectural Review District.
The proposed communications facility is unmanned and will be visited for routine
maintenance purposes approximately two times per year (only as needed). As such, the project
will not have any impact on existing water and sewage services. In addition, neither pedestrian
nor vehicular access to the premises will be impacted [see Zoning Drawings at TAB 6].
II. Compliance with City Requirements
The proposed communications facility complies in all material respects with City
requirements:
1. SEQRA: A Short Environmental Assessment Form is attached as TAB 2.
2. Minimum Visual Impact: As noted above, Verizon Wireless’ proposed facility is
designed to have a minimum possible visual effect on the surrounding community
and neighborhood [TAB 4].
3. Site Plan: The Applicant has provided a Zoning Site Plan that identifies the
proposed improvements [TAB 6].
Based upon the foregoing, Verizon Wireless respectfully submits that approval is
appropriate in this case.
III. Conclusion
The communications facility proposed is a public necessity under Rosenberg in that it is
required to render adequate and safe service to this area of the City of Saratoga Springs. In an
effort to supplement existing telecommunications services to this area of the City, while reducing
the need for a new tower or macro cell collocation, Verizon Wireless has identified an appropriate
location for the deployment of a small cell facility. Verizon Wireless’ existing macro cell sites in
the area do not provide adequate coverage and capacity to this area of the City. The City of
Saratoga Springs will be lacking adequate and safe capacity, and the failure to approve this
application will eliminate the means to provide necessary capacity. This, combined with the
federal mandate to expeditiously deploy advanced wireless services across the nation and
Verizon Wireless’ FCC licenses to provide such services in the City of Saratoga Springs,
demonstrates that Verizon Wireless’ facility is a public necessity. Without the construction of the
communications facility proposed, the public would be deprived of an essential means of
communication, which, in turn, would jeopardize the safety and welfare of the community and
traveling public.
The small cell facility will not be noticeable to the traveling public or nearby property
owners. The communications system proposed has been sited to have the least practical adverse
2 For the reasons set forth herein, Verizon Wireless believes that its project complies in all material respects with the
provisions of the City of Saratoga Springs Land Use Laws and, consistent with the application process established by
the City for prior Small Cell applications, that no additional approvals or relief are required. To the extent that an
additional approval or relief is required, Verizon Wireless submits these materials in support of such approval(s).
3
visual effect on the environment, and any resulting impact(s) may properly be considered as
minimal in nature and scope.
Attached to this Application and Statement of Intent are the following:
1) An Application for Architectural/Historic Review by the Design Review Board;
2) A Short Environmental Assessment Form;
3) Radio Frequency Coverage Plots:
4) Photosimulations of the proposed installation and SEQRA Visual EAF Addendum;
5) Radio Frequency – Site Compliance Report; and
6) Project Zoning Drawings.
Kindly place this matter on the agenda for discussion at the next available meeting of the
Design Review Board. In the meantime, if you should have any questions or require any
additional information concerning this project, I can be reached at (518) 438-9907.
Thank you for your consideration.
Respectfully submitted,
CELLCO PARTNERSHIP d/b/a Verizon Wireless
David C. Brennan, Esq.
Regional Local Counsel
Dated: February 26, 2026
TAB 1
fFOR OFFICE USEl“HANDWRITTEN APPLICATIONS WILL NOT BE ACCEPTED it*
City of Saratoga Springs
DESIGN REVIEW COMMISSION
CITY HALL -474 BROADWAY
SARATOGA SPRINGS,NEW YORK 12866-2296
TEL;518-587-3550 X2533
www.saratoga-springs.org
APPLICATION FOR:
Architectural /Historic Review
(Application #)
(Date received)
(Project Title)
Staff Review
Attorney/AgentOWNER(s')df not applicant)Applicant(s)*
Cellco Partnership d/b/a Verizon Wirele:Young/Sommer LLCName
500 Federal Street,5th Floor1275JohnStreet,Suite 100Address
Troy,New York 12180WestHenrietta,New York 14586
518-438-9907 /Phone 585-321-5390 /
Email
Identify primary contact person:□Applicant
I
dbrennan@youngsommer.com
B Attorney/Agent□Owner
*An applicant must be the property owner,lessee,or one with an option to lease or purchase the property in question.
B Lessee □Under option to lease or purchase□OwnerApplicant’s interest in premises:
Property Information
.N/A.Adj to 3291 S Broadway Tax Parcel #:Property Address/Location:
{for example;165.52 -4-37)
Date Acquired by Owner:
.UR-2 Property use:B Residential
□Historic
B Non-residential/mixed-useCurrentZoningDistrict:
Type of Review:□Extension/modification (of current approval)□Architectural
Summary description of proposed action:
Installation of an unmanned public utility/personal wireless service facility on a wooden utility pole
with the antenna tip 45+/-ft.in height.
Has a previous application been filed with the DRC for this property?H No □Yes -date(s)?
-App.No.(s)?
Revised 01/2021
“complete”application consists of 1 hard copy (original),and I electronic copy of application &ALL other
materials as required below:
New Construction /Additions
H Color photographs showing site/exterior details of existing structures and adjacent properties
H A detailed scaled site plan is essential for achieving minimal zoning compliance,depicting both current and planned structures
along with all building projections such as decks,porches,steps,roof overhangs,and chimneys.This site plan must show all
setbacks from property boundaries and any easements,in addition to the dimensional and bulk standards relevant to the zoning
district on 17"x11"sheet.
H Elevation drawings showing design of all sides of existing &proposed construction -label dimensions,colors,materials,lighting (fixture
&lamp type,wattage),etc.-include compass bearing &scale;no larger than 2’x3’sheet -smaller permitted if legible
□Floor plans for proposed structure;on sheet no larger than 2’x3’-smaller permitted if legible
B Product literature,specifications and samples of proposed materials and colors
Change in exterior building materials (windows,doors,roof,siding,etc.),or color (in non-residential districts only)
□Color photographs showing site/exterior details of existing structures and that illustrate affected features
□Elevation drawings showing all sides of existing &proposed construaion -label dimensions,colors,materials,lighting (fixture &lamp
type,wattage),etc.-include compass bearing &scale;no larger than 2’x3'sheet -smaller permitted if legible
□Product literature,specifications and samples of proposed materials and colors
Within front yard setbacks in Historic Districts only (Front setbacks:ur-i &inst-htr=30';ur-4=2S’;ur-2,ur-3 &ncud-i =lo')
-Installation,removal or change in material of drive-and walkways
-Installation or removal of architectural,sculptural or vegetative screening over 3’in height
-Installation of accessory utility structures or radio/satellit e transmission/reception devices (more than 2’diameter)
For any of above;
□Color photographs showing site/exterior details of existing structures,and of adjacent properties
□Site plan showing existing &proposed construction:include property lines &dimensions,required &proposed setbacks &lot
coverage,site features (fences,walks,trees,etc.)street names,compass bearing &scale;no larger than 2'x3’sheet -smaller
preferred if legible
□Product literature,specifications and samples of proposed materials and colors
Signage /Awnings
□Color photographs showing site/exterior details of existing structures,and adjacent properties
□Plan showing location of proposed sign/awning structure on building/premises;no larger than I I ”x 17”
□Scaled illustration of proposed sign/awning structure and lettering (front view &profile):include all dimensions of structure;type,
dimensions and style of lettering or logo;description of colors,materials,mounting method and hardware
□Descriptions,specifications of proposed lighting including fixture &lamp type,wattage,mounting method,and location
□Product literature,specifications and samples of proposed materials and colors
Demolition
□Color photographs showing site/exterior details of existing structures,and of adjacent properties
□Site plan showing existing and any proposed structures -include dimensions,setbacks,street names,compass bearing,and scale
□Written description of reasons for demolition and,in addition:
□For structures of “architectural/historical significance”,demonstrate “good cause"why structure cannot be preserved
□For structures in an architectural district that might be eligible for listing on National Register of Historic Places,or for a
"contributing”structure in a National Register district (contact City staff),provide plans for site development following demolition -
include a timetable and letter of credit for project completion
Telecommunication facilities
B Color photographs showing site/existing structures,and of adjacent properties
B Site plan showing existing and proposed structures:include dimensions,setbacks,street names,compass bearing,and scale
B Scaled illustration of proposed structures:include all dimensions:colors,materials,lighting,mounting details
B Consult Article 240-12.22 of the City’s Zoning Ordinance and City staff to ensure compliance with requirements for visual impact
assessment and existing and proposed vegetative screening
Revised 01/2021
Request for extension of current approval
□Identify date of original DRC approval: Org.App.No.Current expiration date:
□Describe why this extension is necessary and whether any significant changes have occurred either on the site or in the neighborhood.
SEOR Environmental Assessment Form
B Applicants proposing the following must complete “Part I"of the SEQR Short Environmental Assessment Form (available here:
http://www.dec.ny.gov/docs/permits el operations pdf/seafpartone .pdf):
-Construction or expansion of a multi-family residential structure (4 units 4-)
-Construction or expansion (exceeding 4,000 sq.ft.gross floor area)of a principal or accessory non-residential structure
-Telecommunications facility,radio antennae,satellite dishes
-Demolition
Disclosure
Does any City officer,employee or family member thereof have a financial interest (as defined by General Municipal Law
Section 809)in this application?
B No □Yes -If yes,a statement disclosing the name,residence,nature,and extent of this interest must be filed with this
application.
Certification
I/we,the property owner(s),or purchaser(s)/lessee(s)under contract,of the land in question,hereby request an appearance
before the Design Review Commission.
By the signature(s)attached hereto.I/we certify that the information provided within this application and accompanying
documentation is,to the best of my/our knowledge,true and accurate.I/we further understand that intentionally providing
false or misleading information is grounds for immediate denial of this application.
I/we hereby authorize the members of the Design Review Commission and designated City staff to enter the property
associated with this application for purposes of conducting any necessary site inspections relating to this application.
Furthermore,1/we agree to meet all requirements under Article VII for Historic Review or Article VIII for Architectural
Revi^’^'oTthe Zoning Cod^f the City of Saratoga Springs.
Date:^
(applicant signature)
Date:
(applicant signature)
If applicant is not the currently the owner of the property,the current owner must also sign.
Owner Signature:Date:
Owner Signature:Date:
Revised 01/2021
TAB 2
TAB 3
4G Coverage: 700 MHz, -95
dBm RSRP
2100 MHz Coverage,-85 dBm RSRP
Proposed New Coverage
TAB 4
Looking south from S Broadway (Rt 9)Proposed equipment will be visible from this location
P-1
11861.059
Looking south from S Broadway (Rt 9)Proposed equipment shown as visible from this location
S-1
11861.059
Looking north from S Broadway (Rt 9)Proposed equipment will be visible from this location
P-2
11861.059
Looking north from S Broadway (Rt 9)Proposed equipment shown as visible from this location
S-2
11861.059
TAB 5
MILLENNIUM ENGINEERING, P.C.
42 Old Barn Drive
West Chester, Pennsylvania 19382
Cell: 610-220-3820
www.millenniumeng.com Email: pauldugan@comcast.net
January 16, 2025
Attn: Rick Andras, RF Engineer
Verizon Wireless
225 Jordan Road,
Troy, NY 12180
Re: RF Safety FCC Compliance of Proposed Communications Facility
Site Name: PJS BBQ, Proposed collocation on proposed 38’ utility pole
Site Address: 3291 S. Broadway, Saratoga Springs NY 12866 (Saratoga County)
Latitude 43° 02' 36.974" N, Longitude 73° 47' 27.114" W (NAD83), G.E. 290’ +/- A.M.S.L.
Dear Mr. Andras,
I have performed an analysis to provide an independent determination and certification that the proposed
Verizon Wireless communications facility at the above referenced property will comply with Federal
Communications Commission (FCC) exposure limits and guidelines for human exposure to radiofrequency
electromagnetic fields (Code of Federal Regulation 47 CFR 1.1307 and 1.1310). As a registered professional
engineer, I am under the jurisdiction of the State Registration Boards in which I am licensed to hold paramount
the safety, health, and welfare of the public and to issue all public statements in an objective and truthful
manner.
The proposed communications facility consists of collocation on a proposed existing 38.5’ utility pole at the
above referenced property. The proposed antenna configuration consists of 1 antenna as follows:
(1) multiband non-directional canister antenna (Commscope V4S4-360S-BF2 or equivalent), at a
centerline of 42.3’, azimuth of 0; transmitting from this antenna will be (1) 1900 MHz LTE wideband
channel, (1) AWS 2100 MHz LTE wideband channel, and (2) AWS3 2100 MHz LTE wideband
channels, and (1) LS6 3700 MHz 5G wideband channel
The following assumptions are made for reasonable upper limit radiofrequency operating parameters for the
proposed facility due to the Verizon Wireless antenna alone:
(1) 1900/2100/3500 MHz (LTE & 5G) multiband non-directional antenna
(1) 1900 MHz LTE wideband channel at 4x20W max power/face before cable loss/antenna gain
(1) 2100 MHz LTE AWS wideband channel at 4X60W max power/face before cable loss/antenna gain
(2) 2100 MHz LTE AWS3 wideband channels at 4x60W max power/face before cable loss/antenna gain
(1) 3700 MHz 5G wideband channel at 8X40W max power/face before cable loss/antenna gain
The facility would be at or near full capacity during busy hour
Using the far-field power density equations from FCC Bulletin OET 65, the power density at any given distance
from the antennas is equal to 0.360(ERP)/R2 where R is the distance to the point at which the exposure is being
Page 1 of 7
calculated. The given equation is a conversion of the OET 65 power density equation for calculating power
density given the distance in feet and the result in metric units (mW/cm2). This calculated power density
assumes the location is in the main beam of the vertical pattern of the antenna. After making an adjustment for
the reduction in power density due to the vertical pattern of the transmit antenna, the calculated ground level
power density is well below 1 % of the FCC general population exposure limit at any distance from the antenna
system of Verizon Wireless.
The 1900 MHz transmit frequencies which Verizon Wireless is licensed by the FCC to operate, have an
uncontrolled/general population maximum permissible exposure (MPE) FCC limit of 1000 W/cm2 or 1
mW/cm2. The 2100 MHz which Verizon Wireless is also licensed by the FCC to operate, have an
uncontrolled/general population MPE FCC limit of 1000 W/cm2 or 1 mW/cm2. The 3700 MHz C-Band
transmit frequencies have an uncontrolled/general population MPE FCC limit of 1000 W/cm2 or 1 mW/cm2.
Therefore, the exposure at ground level at any distance from the structure would be substantially below 1 % of
the FCC general population exposure limits due to Verizon Wireless antennas alone. The extremely low ground
exposure levels are due to the elevated positions of the antennas in the structure and the low power which these
systems operate. See Figures 1 and 2 in the back of this report which discusses the relationship between height,
proximity or distance, and orientation to level of electromagnetic field exposure.
In summary, the proposed communications facility will comply with all applicable exposure limits and
guidelines adopted by the FCC governing human exposure to radiofrequency electromagnetic fields (FCC
Bulletin OET 65). Federal law (FCC Rule Title 47 CFR 1.1307 and 1.1310) sets the national standard for
compliance with electromagnetic field safety. The FCC exposure limits are based on exposure limits
recommended by the National Council on Radiation Protection and Measurements (NCRP) and, over a wide
range of frequencies, the exposure limits developed by the Institute of Electrical and Electronics Engineers, Inc.,
(IEEE) and adopted by the American National Standards Institute (ANSI). Thus, there is full compliance with
the standards of the IRPA, FCC, IEEE, ANSI, and NCRP.
General Information on Electromagnetic Field Safety
Verizon Wireless facilities transmit and receive low power electromagnetic fields (EMF) between base station
antennas and handheld devices (smart phones, ipads, laptops, jetpacks, etc.). The radiofrequency energy from
these facilities and devices is non-ionizing electromagnetic energy. Non-ionizing, unlike X-Rays or other forms of
potentially harmful energy in the microwave region, is not cumulative over time nor can the energy change the
chemical makeup of atoms (e.g. strip electrons from ions). “Non-ionizing” simply means that the energy is not
strong enough to break ionic bonds.
Safe levels of electromagnetic fields were determined by numerous worldwide organizations, such the
International Committee for Non-Ionizing Radiation Protection, a worldwide multi-disciplinary team of
researchers and scientists studying the effects of non-ionizing radiofrequency energy such as that emitted by base
stations or cell phones. The FCC did not arbitrarily establish their own standards, but rather adopted the
recommendations of all leading organizations that set standards and research the subject such as the Institute of
Electrical and Electronics Engineers (IEEE), American National Standards Institute (ANSI), and National Council
on Radiation Protection and Measurements (NCRP).
When Verizon Wireless, or any commercial wireless communications licensee, is located on an antenna structure
such as a self-supporting lattice type tower, lattice tower, guyed tower, watertank, etc. the antennas are typically
10 meters or more above ground level (10 meters = 32.81 feet). With the relatively low power and elevated
positions of the antennas on the structure with respect to ground level, the maximum ground level exposure can
rarely approach 1 % of the applicable FCC exposure limit regardless of how many sets of antennas are collocated
on the structure. For this reason, the FCC considers the facilities “categorically excluded” from routine evaluation
at antenna heights above 10 meters (or above 32.81 feet). Categorical exclusion exempts a site from routine on-
site evaluation. However, the facility is not excluded from compliance with the federal exposure limits and
Page 2 of 7
guidelines. The types of facilities used by Verizon Wireless typically elevated on antenna structures (away from
access to close proximity, i.e. greater than 10 meters or 32.81 feet) simply cannot generate ground level exposure
levels that approach the limits under any circumstances.
From a regulatory perspective, the FCC has sole jurisdiction over the regulation of electromagnetic fields from all
facilities and devices. The FCC has established guidelines and limits over emissions and exposure to protect the
general public. The FCC also has certain criteria that trigger when an environmental evaluation must be
performed. The criteria are based on distance from the antennas (accessibility) and transmit power levels.
CONCLUSIONS:
1) The proposed Verizon Wireless communications facility will comply with electromagnetic field safety
standards by a substantial margin (well below 1 %) in all publicly accessible areas. This includes the base
of the proposed structure and any areas in proximity to the structure.
2) Verizon Wireless takes appropriate measures to ensure that all telecommunications facilities (including
this proposed facility) comply with applicable exposure limits and guidelines adopted by the FCC
governing human exposure to radiofrequency electromagnetic fields (FCC Bulletin OET 65).
3) In cases where such compliance exists, the subject of electromagnetic field safety is preempted. The
Telecommunications Act of 1996 states that: “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 [FCC’s]
regulations concerning such emissions.” Telecommunications Act of 1996, § 332[c][7][B][iv].
Respectfully,
Paul Dugan, P.E.
Registered Professional Engineer
New York License Number 79144
Page 3 of 7
FIGURE 1: Diagram of Electromagnetic Field Strength as a Function of Distance and
Antenna Orientation
The above diagram illustrates the conceptual relationship of distance and orientation to
directional panel antennas used in wireless communications. At the base of the structure (x = 0),
the distance R is a minimum when the angle of the direction of propagation θ is a maximum. As
one moves away from the antenna structure, the horizontal distance X increases as well as the
distance R to the antennas while the angle below the horizon decreases. For this reason,
electromagnetic fields from these facilities remain fairly uniform up to a few hundred feet and
continue to taper off with distance. As noted in the report, the electromagnetic fields from these
types of facilities are hundreds of times below safety standards at any distance from the antenna
structure, making them essentially indistinguishable relative to other sources of electromagnetic
fields in the environment due to the elevated heights of the antennas and the relatively low power
at which these systems operate.
R
X
Angle below horizon, θ
Directional
Panel Antenna
Main direction of signal
propagation is directed
on the horizon at
antenna height
Wireless
Communications
Antenna
Structure
Ground Level
Page 4 of 7
% General Population MPE vs. Distance
0
20
40
60
80
100
120040801201602002402803203604004404805205606006406807207608008408809209601000Distance (ft)
%
G
e
n
e
r
a
l
P
o
p
u
l
a
t
i
o
n
Ma
x
i
m
u
m
P
e
r
m
i
s
s
i
b
l
e
E
x
p
o
s
u
r
e
(
M
P
E
)
VZW MPE Contribution FCC Limit
FIGURE 2: Graph of MPE Contribution vs. Distance
The above graph represents the contribution of VZW to the composite electromagnetic field
exposure level at any distance from the base of the structure. The contribution of VZW will
remain well under 1% of the FCC general population maximum permissible exposure (MPE) at any
distance as shown.
Page 5 of 7
DECLARATION OF ENGINEER
Paul Dugan, P.E., declares and states that he is a graduate telecommunications consulting engineer (BSE/ME
Widener University 1984/1988), whose qualifications are a matter of record with the Federal Communications
Commission (FCC). His firm, Millennium Engineering, P.C., has been retained by Verizon Wireless to perform
power density measurements or calculations for an existing or proposed communications facility and analyze
the data for compliance with FCC exposure limits and guidelines for human exposure to radiofrequency
electromagnetic fields.
Mr. Dugan also states that the calculations or measurements made in the evaluation were made by himself or his
technical associates under his direct supervision, and the summary letter certification of FCC compliance
associated with the foregoing document was made or prepared by him personally. Mr. Dugan is a registered
professional engineer in the Jurisdictions of Pennsylvania, New Jersey, Delaware, Maryland, Virginia, New
York, Connecticut, District of Columbia, West Virginia and Puerto Rico with 40 years of engineering
experience. Mr. Dugan is also an active member of the Association of Federal Communications Consulting
Engineers, the National Council of Examiners for Engineering, the National Society of Professionals Engineers,
the Pennsylvania Society of Professional Engineers, and the Radio Club of America. Mr. Dugan further states
that all facts and statements contained herein are true and accurate to the best of his own knowledge, except
where stated to be in information or belief, and, as to those facts, he believes them to be true. He believes under
penalty of perjury the foregoing is true and correct.
______________________________
Paul Dugan, P.E.
Executed this the 16th day of January, 2025.
Page 6 of 7
PAUL DUGAN, P.E.
42 Old Barn Drive
West Chester, PA 19382
Cell: 610-220-3820
Email: paul.mepc@gmail.com
Web Page: www.millenniumeng.com
EDUCATION: Widener University, Chester, Pennsylvania
Master of Business Administration, July 1991
Master of Electrical Engineering, December 1988
Bachelor of Science, Electrical Engineering, May 1984
PROFESSIONAL Registered Professional Engineer in the following jurisdictions:
ASSOCIATIONS:
Pennsylvania, License Number PE-045711-E
New Jersey, License Number GE41731
Maryland, License Number 24211
Delaware, License Number 11797
Virginia, License Number 36239
West Virginia, License Number 20258
Connecticut, License Number 22566
New York, License Number 079144
District of Columbia, License Number PE-900355
Puerto Rico, License Number 18946
Colorado, License Number PE.0065295
Full member of The Association of Federal Communications Consulting Engineers
(www.afcce.org) January 1999 to Present
Elected and served on the Board of Directors for five year term 2006-2011
Full member of The National Society of Professional Engineers (www.nspe.org) and the Pennsylvania
Society of Professional Engineers (www.pspe.org) June 2003 to Present
Currently serving as PSPE State Director and Past President on the Board of Directors of the Valley
Forge Chapter and the South East Region Vice-Chair for the “Professional Engineers in Private Practice”
Executive Committee. Actively participated in NSPE Annual Conferences 7/2005 to Present.
Actively participate in Chester County ARES/RACES Amateur Radio (CCAR www.w3eoc.org)
which prepares and provides emergency backup communications for Chester County Department of
Emergency Services, March 2005 to Present
Full member of The National Council of Examiners for Engineering
(www.ncees.org) May 2001 to Present
Full Member of The Radio Club of America
(www.radio-club-of-america.org) December 2003 to Present
Pennsylvania Real Estate License Number RS347405 Keller Williams 2/2019 to Present
PROFESSIONAL Millennium Engineering, P.C., West Chester, Pennsylvania
EXPERIENCE: Position: President, August 1999 to Present (www.millenniumeng.com)
Verizon Wireless, Plymouth Meeting, Pennsylvania
Position: Cellular RF System Design/Performance Engineer, April 1990 to August 1999
Communications Test Design, Inc., West Chester, Pennsylvania
Position: Electrical Engineer, May 1984 to April 1990
PERSONAL: Date/place of birth: November 21, 1961, West Chester, Pennsylvania; United States Citizen
Page 7 of 7
TAB 6
NY industrial code rule 753 requires no less than two
working days notice, but not more than ten days notice.
Before You Dig, Drill Or Blast!
CALL US TOLL FREE 1-800-962-7962
UNDERGROUND FACILITIES
PROTECTIVE ORGANIZATION
New York
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