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Planning commission recommends new Tier 4 to allow monopole wireless towers up to 160 feet to address local coverage gaps
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Summary
The Brentwood Planning Commission recommended that the city commission consider an ordinance amendment adding a Tier 4 for personal wireless service facilities allowing new monopole towers (up to 160 feet) on government or HOA-owned open space if applicants show technical need, submit a third‑party propagation review, provide certified notice to residents within 1,000 feet, and meet stealth and engineering requirements.
Todd, a city planning staff member, presented proposed revisions to Brentwood’s Personal Wireless Service Facilities (PWSF) ordinance on Feb. 2, saying the current Chapter 78 rules — adopted in 2001 — have made it difficult for wireless providers to address service gaps.
“The proposed Tier 4 will allow new monopole structures, not to exceed 160 feet, subject to very defined criteria,” Todd said, outlining requirements including a propagation study reviewed by a third party, camouflage or stealthing, engineering to include pinch points so towers collapse inward, co‑location for multiple carriers and a visual‑impact analysis. Todd said the changes aim to close gaps in coverage, particularly east of Wilson Pike, and to improve emergency call capabilities and general service for residents.
Under the proposal, Tier 4 sites would generally need to be on land owned or leased by a government or quasi‑government entity, a public utility district or homeowners association open space. Applicants would be required to notify residents within 1,000 feet by certified mail and pay for the required third‑party review and notification costs. Todd also said existing towers would remain grandfathered and upgrades to existing structures would continue to be handled under the expedited Tier 1–2 processes.
Commissioners pressed for safeguards. Several asked how the removal of the current 110% fall‑zone requirement would affect nearby properties; Todd replied that the ordinance would eliminate the fall zone in favor of engineered collapse designs and that established zoning setbacks (for example, 50–75 foot buffers and roughly 100‑foot setbacks for some government properties, and ~35–40 feet from HOA open‑space property lines) would still apply. Commissioners also emphasized that the commission retains discretion to find a proposed tower “too close” to neighboring properties even if it meets minimum technical requirements.
On cost and ownership, Todd reiterated that the city would not pay to construct towers: private tower companies would own structures and lease space to carriers, and applicants would bear review and mailing costs. Commissioners further sought assurance that the ordinance would tie any approved height to documented technical need; Todd said the code would allow up to 160 feet but that the approved height could be lower if the applicant’s propagation study showed a lesser height would meet coverage needs.
After discussion, Committee member S6 moved and S3 seconded that the commission recommend approval of the ordinance amendment to the city commission. The planning commission approved the recommendation by voice vote and will forward the ordinance to the city commission for a public hearing on Feb. 9 and second and final reading on Feb. 23.
What happens next: the city commission will hold the public hearing on Feb. 9, where residents within notification range and other stakeholders may comment. If the city commission approves the ordinance at second reading, applicants would be expected to meet the ordinance’s technical, visual and notification requirements when proposing new Tier 4 towers.
