EXHIBIT 22

Visual Assessment of the proposed Verizon wireless communication tower at

16224 Vail Road SE, Yelm Washington.

Prepared by: Jean-Marie: Mason

First let us review the Thurston County Code TCC 20.33.080, Location and

design standards for freestanding WCFs and remote freestanding

WCFs/antenna support structures, Section 2(b), subsections i and ii state:

i. Proposed WCFs/antenna support structures shall be located where

their visual impact is least detrimental to views of recognized

landmarks, such as, but not limited to, Puget Sound, Nisqually Valley,

Mount Rainer, the Black Hills, and the Olympic Mountains. If the

approval authority determines that the proposed location for the

facility would have a significant detrimental impact on a view of a

recognized landmark, she/he shall deny the proposal unless the

applicant demonstrates that a less impacting site is not available.

ii. In order to demonstrate that a less impacting site is not available,

applicants for WCF/antenna support structures impacting the views

listed in subsection (2)(b)(i) of this section shall identify all viable

alternative sites available for accommodating the WCF/antenna

support structure. The applicant shall perform balloon tests for the

proposed and alternative sites, in a manner consistent with Section

20.33.050(3), and submit them for approval authority review.

Facts related to this cell tower location and balloon test:

1. Visual impact along a roadway is influenced by 3 measures:

1) the proximity to the cell tower from the viewer (in this case people

driving along Vail Road SE);

2) the extent or number of people that will be viewing the cell tower;

and,

3) the duration or amount of time viewers can see the cell tower while

driving at the posted speed (US DOT FHA, 2015).

The Camp+ Associates Visual Assessment for Verizon (“Camp Visual

Assessment”) (Figure 1), fails to do this type of analysis, and

assesses only “VISIBLE” or “NOT SEEN” by some unclear method of

Appellants' Exhibit 22 Page 1 of 14

assessment for said 22 numbered stationary viewpoints in the local

area.

In the THURSTON COUNTY RESOURCE STEWARDSHIP PLANNING &

ENVIRONMENTAL SECTION REPORT (“Staff Report”), which is undated

and unsigned by the alleged preparer, Tony Kantas, who is Associate

Planner for Thurston County Resource Stewardship Department, under

the section titled, DEPARTMENT ANALYSIS, B. Wireless

Communications Facilities (TCC 20.33), 2. Siting (b) (on page 5 of the

Staff Report) is stated:

“Prior to submitting the application, the Applicant

performed photo tests at the height of the

proposed tower and took photographs from various

vantage points on area roads and parcels. The photos

demonstrate that the tower will be visible from some

properties and public roads, but that the tower will

not negatively impact views (Attachment z).”

(emphasis added)

It is unclear what is meant by the statement, “...the Applicant

performed photo tests at the height of the proposed tower....” Because

the proposed tower height was initially 150 feet, prior to the additional

six to ten feet which has since been added, it appears that the

statement indicates that whoever took the photos was 150 feet in the

air, ‘at the height of the proposed tower,’ when they took the photos.

This seems an unlikely scenario.

The statement, “...and took photographs from various vantage points

on area roads and parcels...” also does not adequately explain exactly

how the Applicant determined whether a 150 foot tower would be

visible or not from the various locations.

The photos do not appear to have been taken during a balloon test,

which would have shown a red balloon at the then lower tower height

of 150 feet, because there is no red balloon showing in the three

photos taken at viewpoints 1, 2, and 6, which are marked as green

and “VISIBLE” in Figure 1.

The Camp Visual Assessment fails to indicate the dates on which each

of these 22 numbered locations were photographed and assessed for

Appellants' Exhibit 22 Page 2 of 14

‘visibility,’ and also fails to indicate the specific criteria used to

determine whether or not the proposed tower would be visible from

each of the vantage points.

2. A second balloon test was scheduled for August 2, 2014 because the

tower needed to be extended by approximately 10 feet to

accommodate a microwave dish. However, this balloon test was

cancelled, hence there is no accurate balloon test for the current

design height of 156 feet upon which to base a correct visual

assessment, see attachments 1 and 2. Attachment 1 shows copy of

a letter to Interested Property Owners dated July 18, 2014 regarding

the scheduling of a balloon test at 160 feet rather than 150 feet as

was done before, and the scheduling of a community meeting.

Attachment 2 shows copy of a letter to Interested Property Owners

dated July 29, 2014, regarding the cancellation of the balloon test at

160 feet, and the cancellation of the community meeting.

Verizon failed to conduct a new balloon test for the raised tower height

since the first balloon test at 150 feet.

Verizon also failed to conduct a community meeting.

3. The Camp Visual Assessment viewpoint location #2 on Vail Road SE is

located at a popular viewpoint offering one of the last pristine, pastoral

foreground views of Mount Rainier in Thurston County (Figure 2a and

Figure 2b).

4. Average daily traffic past this #2 viewpoint location in 2013 was 1,274

vehicles per day (US DOT, FHA NBI; August 2013).

5. Camp Visual Assessment viewpoint #2 current/proposed photographs

erroneously or purposely fail to show the unobstructed view of Mount

Rainier to the east (Figure 3).

6. The average height of 10 dominate trees at the tower site is 102 feet

using a laser hypsometer, a common forester’s tool used in the field,

according to measurements taken by Alex Foster on November 14,

2015.

7. The May 10, 2014 balloon test was to evaluate the preliminary tower

height of 150 feet; the balloon is clearly visible in this photo. (Figure 4).

Appellants' Exhibit 22 Page 3 of 14

8. From the junction of Reichel Road at Camp Visual Assessment

viewpoint #1 (Figures 5 and 6), the top 54 feet of the tower antenna

array will be seen directly ahead and above the trees tops for 26

seconds driving at 45 mph along a 1,750 foot section until reaching

the trees where the tower is located.

9. The tower will be seen contrasting with unobstructed views of Mount

Rainier for 950 feet along this 1,750 foot scenic section of roadway

and will dominate the view shed at this location (Figure 7).

Another unexpected but possible negative visual consequence is if the trees

surrounding the tower are removed, by the land owner deciding to log the

trees, or from other causes. Currently, there is no moratorium or ordinance

which would prohibit the land owner from logging timber around the

proposed tower, hence the visual impact of that future scenario would be

negatively significant.

Also for further consideration, the tower at its proposed location may forever

preclude adoption of scenic Vail Road SE as a future County scenic byway,

and inclusion to similar programs such as the Thurston Bountiful Byway

loop.

References

U.S. Dept. of Transportation, Federal Highways Administration. 2015.

Guidelines for the Visual Impact Assessment of Highway Projects. Handbook

FHWA-HEP-15-029. 104 pp.

U.S. Dept. of Transportation, Federal Highways Administration. 2013.

National Bridge Inventory (NBI) data for Deschutes River Bridge on Vail

Roads SE in Thurston County. Located at https://www.fhwa.dor.gov.nbi.cfm

Appellants' Exhibit 22 Page 4 of 14

Figure 1. Camp+ Associates photo view point map.

Appellants' Exhibit 22 Page 5 of 14

Figure 2a. Wide angle stitch photo taken at Camp+ Associates photo view

point #2, by Alex Foster (12/30/15).

Appellants' Exhibit 22 Page 6 of 14

Figure 2b. Photo taken at Camp+ Associates photo view point #2, by Alex Foster (12/30/15).

Appellants' Exhibit 22 Page 7 of 14

Figure 3. Camp+ Associates current/proposed photos from view point #2

Appellants' Exhibit 22 Page 8 of 14

Figure 4. May 10, 2014 balloon test photo, taken by Chris Nubbe.. The scheduled

second balloon test to assess extending the tower height another 10 feet on

August 2, 2014 was cancelled, and never performed, see attachment 1 and 2.

Appellants' Exhibit 22 Page 9 of 14

Figure 5. Camp+ Associates viewpoint #1; junction of Reichel and Vail Road SE.

Appellants' Exhibit 22 Page 10 of 14

Figure 6. Rendering of cell tower to scale adding an extra 10 feet to the

height to compensate for the for the cancelled August 2, 2014 balloon test

results. As seen from Camp+ Associates viewpoint #1 at junction Reichel

and Vail Road in the rain on January 07, 2016. Start of the 26 second at 45

mph tower viewing section.

Appellants' Exhibit 22 Page 11 of 14

Figure 7. Rendering of cell tower to scale as seen from Camp+ Associates

viewpoint #2 with view of Mount Rainier (12/30/2015). Adding an extra 10

feet to the height to compensate for the cancelled August 2, 2014 balloon

test results.

Appellants' Exhibit 22 Page 12 of 14

Attachment 1

Appellants' Exhibit 22 Page 13 of 14

Attachment 2

Appellants' Exhibit 22 Page 14 of 14