Title
PLN240071 - TOPE ANDREW GERARD TR
Public hearing to consider construction of a wireless telecommunication facility, including the installation of an 85-foot-tall new Monopole wireless telecommunication facility that exceeds the maximum height of 35 feet by 50 feet, and associated site improvements including removal of three Willow trees and underground utility connection.
Project Location: 225 River Road, Salinas, CA 93908
Proposed California Environmental Quality Act (CEQA) action: Find that disapproval of the project is Statutorily Exempt pursuant to CEQA Guidelines sections 15061(b)(4) and 15270.
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RECOMMENDATIONS
It is recommended that the Planning Commission adopt a resolution to:
a. Find that disapproval of the project is Statutorily Exempt pursuant to CEQA Guidelines sections 15061(b)(4) and 15270; and
b. Deny a Combined Development Permit consisting of a:
1. Use Permit and Design Approval to allow the installation of an 85-foot-tall new Monopole wireless telecommunication facility removal of three Willow Trees, and associated ground equipment and improvements; and
2. Use Permit to exceed the maximum allowed height of 35 feet by 50 feet.
The attached draft resolution includes findings and evidence for consideration (Exhibit A). Staff recommends denial of the project.
PROJECT INFORMATION
Agent: Matt Moore with Vertex Towers (T-Mobile)
Property Owner: Andrew and Tracy Tope
APN: 139-021-001-000
Parcel Size: 25.5 acres or 1,110,780 square feet
Zoning: Farmlands with 40 acres per unit density, and Design Control overlay or “F/40-D”
Plan Area: Toro Area Plan
Flagged and Staked: Yes
Project Planner: McKenna Bowling, Associate Planner
bowlingmr@countyofmonterey.gov, (831)755-5298
SUMMARY
The project site is located at 225 River Road, Salinas, within the Toro Area Plan. The proposed project includes the construction of a new wireless telecommunication facility (WCF), including the installation of an 85-foot-tall monopole with six T-Mobile antennas, and three antenna mounts that may be utilized by up to 18 antennas of different carriers in the future, two elevated platforms with equipment cabinets, and associated site improvements, including removal of Willow three trees and underground utility connection. The proposed development takes place within a wetlands boundary and a floodplain, as delineated on the project plans. This project does not include an increase in wastewater generation or installation, upgrade, or repairs to any onsite wastewater treatment system components.
Based on staff’s analysis, the proposed project is inconsistent with the policies and regulations pertaining to zoning uses and any other applicable provisions of the 2010 Monterey County General Plan (General Plan), Toro Area Plan and applicable sections of the Monterey County Inland zoning ordinance (Titles 16 and 21). This is detailed below, and in the draft Resolution (Exhibit A)
DISCUSSION
The subject property is in a Farmland zoning district with a Design Control overlay, located at 225 River Road, Salinas (Assessor’s Parcel Number: 139-021-001-000). The proposed Vertex Towers Wireless facility will be located on the front southeastern portion of the 25.5-acre parcel that is developed with two Single-Family Dwellings, established in 1959. The subject parcel is zoned as Farmland with a 40-acre per unit density, with a Design Control overlay in the Inland area, or “F/40-D”. A Use Permit and Design Approval is required to authorize construction of the proposed WCF, and a Use Permit is required to authorize the exceedance of maximum allowed height.
Wireless Communication Facility Regulatory Framework
Title 21 section 21.64.310 establishes the regulations, standards and circumstances for the siting, design, construction and maintenance of wireless communication facilities (WCF) in the unincorporated area of the County of Monterey. These regulations compliment other visual resource and design standards of the County, including Toro Area Plan Policies and Chapter 20.44 (Design Control Overlay). Compliance with these requirements assures, by regulation of siting WCF’s that the integrity and nature of residential, rural, commercial, and industrial areas are protected from the indiscriminate and inappropriate proliferation of WCF’s, while still complying with the Federal Telecommunication Act of 1996, General Order 159A of the Public Utilities Commission of the state of California and the policies of County of Monterey.
WCF’s are allowed on any lot or parcel in any zoning district, subject to a discretionary permit, and subject to meeting the following regulations:
1. Wireless communication facilities shall comply with all applicable goals, objectives and policies of the general plan, area plans, zoning regulations and development standards.
2. Wireless communication facilities shall comply with all FCC rules, regulations, and standards.
3. Wireless communication facilities shall comply with all applicable criteria from the Monterey County Airport Land Use Commission (ALUC) and the Federal Aviation Administration (FAA).
4. Wireless communication facilities shall be sited in the least visually obtrusive location possible. Appropriate mitigation measures shall be applied in instances where the facility is visible from a public viewing area.
5. A visual simulation of the wireless communication facility shall be provided. Visual simulation can consist of either a physical mock-up of the facility, balloon simulation, computer simulation or other means. In instances where the wireless communication facility is located near or in a residential area, photos shall be submitted of the proposed wireless communication facility from the nearest residential neighbors. In instances where the wireless communication facility is located along a scenic corridor, or within a Historic Resource Area or District, a detailed visual analysis of the facility shall be submitted.
6. Where the wireless communication facility is proposed to be located within a designated historic resource site or district, the applicant shall comply with the regulations for historic resources pursuant to Chapter 21.54 and Chapters 18.25 and 18.26.
7. Where a wireless communication facility exists on the proposed site location, co-location shall be pursued to the maximum extent feasible. If a co-location agreement cannot be met, documentation of the effort and the reasons why co-location was not possible shall be submitted and reviewed by the Director of Planning.
8. Other regulations enacted pursuant to the General Plan and Area Plan, may be applied to the proposed wireless communication facility, depending on the location and type of facility.
In addition to these WCF regulations, the project is also subject to the provisions and polices of Chapter 20.44 (Design Control Overlay), the 2010 General Plan, and Toro Area Plan. Here, pursuant to Figure 16 (Scenic Highway Corridors and Visual Sensitivity) of the Toro Area Plan (TAP), River Road is identified as a proposed scenic highway and route. However, the area visible from River Road is identified as being “Sensitive” and therefore subject to the visual resource policies of the Toro Area Plan. TAP Policy T-3.1 states that development on parcels designated as visually sensitive on according to Figure 16, such as the subject property, may be permitted if the development is located and designed in such a manner that will enhance the scenic value of the area. Further, Policy T-3.2 requires that “land use, architectural, and landscaping controls shall be applied” to preserve Toro's visually sensitive areas and scenic entrances of River Road, Highway 68, and Laureles Grade.
Notwithstanding other Monterey County Code requirements, together with the above WCF regulations, such projects must achieve the following visual resource standards:
1. co-location when it decreases visual impacts as a measure to preserve the visual character and aesthetic values of the surrounding area;
2. be located and designed through use of architectural and landscaping modifications to minimize visual clutter and protect scenic views;
3. remain below ridgelines in visually sensitive areas;
4. be screened from public view as much as feasible;
5. be sited in the least visually obtrusive location possible; and
6. be compatible, and if possible, enhance, the scenic values of the area.
Compliance with WCF Regulations and 2010 General Plan
Co-Location & Site Analysis
The Applicant evaluated 17 potential sites within two miles of the project. According to the Alternative Site Analysis (Exhibit F), 12 property owners declined to lease their properties, and the Applicant determined that the remaining five sites were unsuitable. However, the Applicant has not adequately explained why those five sites were ruled out or whether a smaller facility designed for only the six proposed T-Mobile antennas (rather than with equipment for additional future carriers) could be accommodated.
The Service Coverage Maps (Exhibits C) show a T-Mobile coverage gap extending approximately 1.5 miles along River Road. The gap includes Las Palmas Phase II, Vista Del Rio, Pedrazzi, Indian Springs Ranch, and surrounding agricultural areas. Existing T-Mobile facilities on Portola Drive and near Harris Road/Abbott Street do not adequately serve this area. However, the Applicant has not demonstrated whether co-location on other wireless carriers' facilities could address the coverage gap. Therefore, the Alternative Site Analysis (Exhibit F) does not demonstrate that reasonable co-location and alternative site options have been exhausted. The Applicant has not adequately justified the six-antenna configuration, evaluated reduced-height alternatives, or shown why co-location with other carriers is not feasible. Therefore, the project has not demonstrated compliance with Title 21 section 21.64.310.H.1.b.
Visual Resource Impacts
The project was originally proposed as a 100-foot wireless communication facility (WCF). After staff raised concerns about its impact on public views and consistency with the Monterey County Code, the Applicant reduced the proposed height to 85 feet. The revised design consists of a monopole with six T-Mobile antennas and three additional antenna mounts for future carriers, allowing for up to 18 additional antennas. Staff believes the proposed 85-foot monopole remains inconsistent with Toro Area Plan Policies T-3.1 and T-3.2 and Title 21, Sections 21.64.310.C.4 and 21.64.310.H.1(c-d), for the following reasons.
At approximately 70 feet above the surrounding tree line, the facility would remain visually prominent and detract from the area's scenic character. The Applicant provided visual simulations (Exhibits D and I) and conducted a crane demonstration to show the proposed height from public viewpoints along River Road. Based on these materials and staff's August 25, 2026 site visit, the facility would be visible for approximately 0.35 miles west and 0.30 miles east of the project site. It would also be visible from nearby neighborhoods and public streets. The Applicant has not demonstrated that the facility's location or design adequately minimizes these visual impacts, protects scenic views, or enhances the River Road character.
The Applicant selected a monopole design rather than a monopine or lattice tower. Although the Applicant provided visual simulations of an 85-foot monopine (Exhibit I), adding artificial vegetation would not address the primary concern: the structure's height and visibility within a heavily vegetated scenic corridor. A lattice tower could create similar or greater visual impacts than the proposed monopole.
The proposed facility includes six T-Mobile antennas and three additional antenna mounts for future carriers, with capacity for up to 18 additional antennas. This additional capacity contributes to the facility's overall height and visual prominence. A facility designed to accommodate only the six T-Mobile antennas could potentially be reduced by at least 30 feet, resulting in a 55-foot structure. Although the Applicant did not provide a visual simulation of this alternative, a shorter facility would reduce its prominence above the tree line and better protect the area's scenic character. Although not a required finding to support a WCF, the coverage prediction maps indicate that reducing the facility's height from 85 to 55 feet would not significantly affect anticipated T-Mobile coverage (Exhibit G). The Applicant has not adequately justified the need for the additional antenna capacity or demonstrated that a reduced-height facility would be insufficient to address the identified coverage deficiencies while maintaining visual continuity along River Road.
Monterey County Code requires WCFs to minimize visual impacts, protect scenic views, and, where feasible, screen facilities from public viewing areas. Although the Applicant reduced the original proposed height from 100 to 85 feet, the revised design remains visually prominent. The Applicant has not adequately evaluated a reduced-height alternative or justified the need for additional antenna capacity. Accordingly, the project has not demonstrated compliance with the applicable visual resource protections and siting and design requirements of Title 21, Section 21.64.310.
Radio Frequency
The applicant has submitted a report prepared by Bollard Acoustical Consultants (County of Monterey Library No. LIB250031), evaluating the proposed facility (Exhibit E). The report finds that the facility will comply with prevailing Federal Communications Commission (FCC) and Occupational Safety and Health Administration (OSHA) standards for limiting public exposure to radio frequency energy. This finding is consistent with measurements of actual exposure conditions taken at other operating base stations. The site is adequate for the proposed development of the wireless communication facility and the applicant has demonstrated that it is the most adequate for the provision of services as required by the FCC.
Other WCF Regulations and 2010 General Plan Requirements
The project is compliant with all other WCF regulations and applicable Monterey County Code, except for those detailed above.
Development within Floodplain and Wetlands Boundaries
As delineated on the project plans, the property is adjacent to the Salinas River and within the AE Floodway. Pursuant to Title 16 section 16.16.050.K, a setback of 200 feet from the top of bank of a river and 50 feet from top of bank of a watercourse will be established where encroachment will be prohibited, unless it can be proven that: 1) the proposed development shall be sited and designed in a manner that will not significantly reduce the capacity of existing rivers or watercourses, or otherwise adversely affect any other properties by increasing stream velocities or depths, or diverting the flow, and 2) the development will be safe from flow erosion and not cause flow related erosion hazards. The area of proposed development is sited within the AE floodway and cannot comply with the 200 feet setback to top of bank requirement due to the shape and size of the parcel. The associated ground equipment is proposed to be raised about Base Flood Elevation (BFE) and the permitter fencing surrounding the development is a chain-link fence, intended to allow water to pass through as to not alter the flow. However, the Applicant/Owner has yet to provide the requested Hydrologic and Hydraulic Analysis to better analyze potential impacts of the proposed development and its compliance with Title 16 requirements. Such a report is not necessary at this time as staff is recommending denial of the project due to its inconsistency with applicable Monterey County code, as described above.
CEQA:
California Environmental Quality Act (CEQA) Guidelines sections 15061(b)(4) and 15270 statutorily exempts a project that is rejected or disapproved by a public agency which a public agency rejects or disapproves. The County is a public agency disapproving of the project. Statutory exemptions from CEQA are not qualified by the exceptions applicable to categorical exemptions in CEQA Guidelines section 15300.2.
LUAC:
The proposed project was reviewed by the Toro Land Use Advisory Committee on July 27, 2026, and then continued to October 26, 2026, to allow the applicant time to install staking and flagging of the proposed development. The LUAC voted unanimously to recommend disapproval of the project, citing concerns of visual impacts and project location (Exhibit J).
OTHER AGENCY INVOLVEMENT
The following agencies have reviewed the project, have comments, and/or have recommended conditions:
HCD-Engineering Services
Environmental Health Bureau
HCD-Environmental Services
Monterey County Regional Fire Protection District
Prepared by: McKenna Bowling, Associate Planner, x5298 and Fionna Jensen, Principal Planner x6407
Reviewed by: Fionna Jensen, Principal Planner
Approved by: Melanie Beretti, AICP, Chief of Planning
The following attachments are on file with HCD:
Exhibit A - Draft Resolution including:
• Site Plans
Exhibit B - Vicinity Map
Exhibit C - Coverage Map
Exhibit D - Photo Simulations
Exhibit E - Radio Frequency Study
Exhibit F - Alternative Sites Analysis
Exhibit G - Height Comparison Coverage Maps
Exhibit H - Noise Study
Exhibit I - Monopine Simulations
Exhibit J - Toro LUAC Minutes dated October 26, 2026
cc: Front Counter Copy; Monterey County Regional Fire Protection District; HCD-Environmental Services; HCD-Engineering Services; Environmental Health Bureau; McKenna Bowling, Planner; Fionna Jensen, Principal Planner; Andrew and Tracy Tope; Property Owner; Matt Moore, Agent; The Open Monterey Project (Molly Erickson); Landwatch: Planning File PLN240071.