Proposed Cell Tower Statement
THE LAKE FOREST PRESERVATION FOUNDATION’S COMMENTS TO THE PROPOSED AMENDMENT TO CITY CODE SECTION 159.154, TO DESIGNATE A SITE OR SITES FOR TELECOMMUNICATIONS FACILITIES November 13, 2024
The Lake Forest Preservation Foundation (the “LFPF”) is a not-for-profit organization, having over 500 members and supporters, almost all of whom are residents of Lake Forest. For over four decades, the LFPF has been dedicated to the stewardship, safeguarding, and endurance of Lake Forest’s exceptional architectural and landscape legacy for succeeding generations, through public education, historic preservation and advocacy. Among its key beliefs is the preservation of the historic visual character of Lake Forest and thoughtful development that is sensitive to Lake Forest’s surroundings. The LFPF provides these comments to the City Staff’s proposal to amend Zoning Code Section 159.154 in order to designate additional sites for telecommunication facilities in southwest Lake Forest.
Amending Section 159.154 to Designate Additional Sites for Telecommunications Facilities.
The LFPF recognizes that (1) telecommunications services are necessary for public safety and private and business communications, and (2) the City Staff believes there are service coverage issues in southwest Lake Forest. The City Staff recommends that three areas, identified in Attachments A-5, A-6 and F-2, be incorporated into the Wireless Overlay Districts to provide options for additional wireless infrastructure in areas of need. The proposed additions identified in A-5 and A-6 would allow for monopoles of up to 160 feet, while the addition identified in F-2 would allow for co-location on existing structures only.
The City Staff report confirms that all locations are subject to the limitations and requirements of Zoning Code §§ 159.150-159.999, which deals with Personal Wireless Service Facilities. Two of the stated goals of this zoning subchapter are to:
• “Encourage users of towers and antennas to locate them, to the extent possible, in areas where the adverse impact on residential areas of the city is minimal”; and
• “Encourage users of towers and antennas to configure them in a way that minimizes the adverse visual impact of the towers and antennas.”
§ 159.152(B)(3)-(4). Indeed, the City Council found that it was necessary to promulgate this subchapter to, among other things, “minimize adverse visual impacts of towers through careful design, siting, landscape screening and innovative camouflaging techniques.” § 159.152(C)(3). 1 And to help meet this goal, the Code provides that “[t]he person or entity proposing to amend the section is required to demonstrate, using technological evidence, that the amendment to the overlay district is necessary in order to satisfy the service requirement of the respective grid system.” §159.164 (emphasis added).
The City Staff report contains no such technological evidence. In addition, the LFPF has serious concerns that a modern monopole of up to 160 feet, next to the train station and within the west Lake Forest Central Business District (as identified in Attachment A-6), can satisfy the goals of the Zoning Code. Much effort, time and resources have gone into ensuring that Settler’s Square is compatible with the historic visual character of Lake Forest in height, scale and style. Like most towns, the train station is its centerpiece. Siting a 160-foot monopole in this highly visible area, which is adjacent to residences, will not minimize the adverse visual impact of the tower. Just the opposite, it will create such an adverse impact and become the unwelcome focal point of this business district.
Look at it this way. Would anyone consider putting such a monopole next to the UP-train station across from Market Square? The LFPF understands that the City Staff is proposing prohibitions, including no external antenna arrays as seen on the unsightly rooftop antenna on 580 Bank Lane. But the central problem remains. If accepted, there would be a towering monolithic pole that would not only dwarf the structures with which it visually relates but would be visually incompatible with them. In the LFPF’s view, this does not comply with Zoning Code Section 159.152, and cannot be cured by design, screening or creative camouflaging. The issue is the siting of the monopole and its height. And, on the current record, there is no “technological evidence” demonstrating that it is necessary or the only solution to satisfy service requirements for southwest Lake Forest.
As provided in the Zoning Code, the LFPF believes the City should first obtain and review the necessary cellular technological evidence to determine the options for service to this area. And if a monopole of 160 feet is the only viable option, the City should strongly consider alternative sites that would not create an adverse visual impact, as would occur if the proposed monopole was constructed in area A-6. 2