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Project Narrative — EFR <br />DAGMAR (L-Sub6) — VERIZON <br />Page 3 of 4 <br />The Proposed Modification Does Not Constitute a "Substantial Change" <br />Below are the FCC's six "substantial change" thresholds for a wireless tower not in the right- <br />of-way,8 each followed by an explanation that the proposed modification does not exceed that <br />threshold. <br />1. It increases the height of the tower by more than 10% or by the height of one <br />additional antenna array with separation from the nearest existing antenna not to <br />exceed twenty feet, whichever is greater. <br />The proposal increases the height of the tower by four feet, which is 2.6% increase. <br />This is less than the allowed 10% height increase. <br />2. It involves adding an appurtenance to the body of the tower that would protrude from <br />the edge of the tower more than twenty feet, or more than the width of the tower <br />structure at the level of the appurtenance, whichever is greater. <br />The proposal replaces an appurtenance to the body of the tower that protrudes from <br />the edge of the tower by six and one-half inches. This is less than the allowed twenty <br />feet. <br />3. It involves the installation of more than the standard number of new equipment <br />cabinets for the technology involved, but not to exceed four. <br />The proposal does not add any additional equipment cabinets. <br />4. It entails any excavation or deployment of transmission equipment outside of the <br />current site by more than 30 feet in any direction. The site boundary from which 30 <br />feet is measured excludes any access or utility easements currently related to the site. <br />The "site" is as defined at 47 C.F.R. § 1.6100(b)(6). <br />The proposal does not entail any excavation or deployment outside the current site. <br />5. It would defeat any concealment elements of the existing facility. <br />The existing facility is a stealth flagpole with a large American flag at the top, and <br />the proposal will not defeat the concealment elements of the existing facility. The <br />proposed replacement canister stack will be painted white to match the existing <br />facility, and the large American flag will remain. <br />6. Does not comply with conditions associated with the prior approval of the existing <br />facility, unless the non-compliance is due only to a change in height, width, etc., that <br />does not exceed the first four thresholds. <br />There are no prior conditions of approval that would render the modification to be <br />non -compliant, aside from any conditions that would be preempted by the first four <br />"substantial change" thresholds. <br />