Planning Commission Staff Report Page 1 of 11 October 16, 2025 Agenda Item No. 4.2.1.
DATE: October 16, 2025
TO: Members of the Planning Commission
FROM: Carmela Campbell, Economic and Community Development Director
SUBJECT: Southern Alameda County Buddhist Church, Owner; Use Permit (UP-25-001), Site Development Review (SD-25-001) - Southern Alameda County Buddhist Church, Is Seeking Use Permit (UP-25- 001) Approval for a New Wireless Facility on the Roof of an Existing, One-story, 20,374 Square-Foot Building and to Increase the Height of the Building from 28 Feet 5 Inches to 43 Feet 5 Inches; and Site Development Review (SD-25-001) Approval for the Construction of a New 2,320 Square-Foot Roof-Mounted Enclosure and a 359 Square-Foot Equipment Ground-Mounted Enclosure. The Site Is Located at 32975 Alvarado-Niles Road Within the Private Institutional (PI) Zoning District. Staff Is Recommending This Project Be Considered Categorically Exempt from the California Environmental Quality Act (CEQA) under Section 15303, New Construction or Conversion of Small Structures, of the CEQA Guidelines
SIZE OF PARCEL: 167,378 square feet (3.8 acre)
GENERAL PLAN: Private Institutional (PI)
SURROUNDING LAND USES:
Table 1 – Surrounding Land Uses
Location General Plan Designation Zoning District Land Use North Special Industrial (MS) MS Business/Office
South Residential (6 - 10 du/ac) RS 4500 Single-family Residential East Office Commercial (CO) CPA Office/Commercial
West Residential (10 - 17 du/ac) RM 2500 Multi-family Residential ENVIRONMENTAL ASSESSMENT:
ATTACHMENT 2
Agenda Item No. 4.2.1.
Planning Commission Staff Report Page 2 of 11 October 16, 2025 Staff is recommending this project be considered categorically exempt from the California Environmental Quality Act (CEQA) under Section 15303, New Construction or Conversion of Small Structures, of the CEQA Guidelines LOCATION MAPS:
I. PROPOSAL & BACKGROUND
The project applicant, Carl Jones of AT&T Mobility, on behalf of Southern Alameda County Buddhist Church is seeking Use Permit (UP-25-001) and Site Development Review (SD-25-001) approvals to allow for a new wireless facility on top of the existing building currently used as social hall and gym. The building is one-story and measures 20,374 square feet. The project will increase the height of the building to add a new 2,320 Figure 1 – Zoning Map of 32975 Alvarado-Niles Road
Figure 2 – Location Map of 32975 Alvarado-Niles Road
Project Site
N
N
Project Site
RM 2500
MS
RS 4500
CPA
Agenda Item No. 4.2.1.
Planning Commission Staff Report Page 3 of 11 October 16, 2025 square-foot enclosure to house nine (9) new antennas. The project also includes a 359 square-foot enclosure for ground equipment. The project plans and statement of use are included as Exhibit A and Exhibit B, respectively.
The site is located at 32975 Alvarado-Niles Road within the Private Institutional, (PI), Zoning District. The site includes the original church (Southern Alameda County Buddhist Church), as well as a separate building used as social hall, gymnasium, and classrooms.
There is also one single-family residence on the lot that is being used as a residence.
The site was originally developed in 1963 with the construction of the existing Buddhist church building, approximately 4,228 square feet in size. In 1973, the Southern Alameda County Buddhist Church applied for, and the City approved Use Permit UP-16-73 to construct a new 20,374 square-foot facility for religious, educational, and public assembly purposes.
II. PROJECT ANALYSIS
A. Permit Requirements
New wireless facilities in the PI Zoning District are subject to Administrative Use Permit and Administrative Site Development Review, per Union City Municipal Code (UCMC) Section 18.114.040, Wireless Telecommunication Facilities Use Table. Per UCMC Section 18.51.030, Required Conditions, for the PI Zoning District, the maximum height for buildings is 35 feet, but may be increased to a maximum of 50 feet if the Planning Commission finds that such excess height will not be detrimental to the light, air or privacy of any other structure or use within the surrounding area. Per UCMC Section 18.08.140, "height of building" means the vertical distance from the grade to the highest point of the coping of a flat roof or to the deck line of a mansard roof or to the average height of the highest gable, gambrel or hip roof. The current height of the existing building upon which the wireless facility will be located is 28 feet 5 inches from the ground to the coping. The wireless facility would increase the overall height of the building by 15 feet to a total height of 43 feet 5 inches from the ground to the coping of the wireless facility; therefore, triggering the need for a use permit for the height.
In addition to the height allowance, the use permit request will address the administrative use permit requirement. Per UCMC Section 18.54.040, Limitations, the Zoning Administrator can determine that an administrative use permit be reviewed by the Planning Commission if an applicant applies for a use permit, which was done. The use permit addresses both the building height, and the wireless facility use and simplifies and streamlines the approval process.
In accordance with UCMC Section 18.114.040.B, when a proposed wireless telecommunications facility would substantially modify an existing building, the Director may require Site Development Review rather than handle the matter administratively.
Because of the proposed modifications and given the site’s location at the intersection of an arterial and a residential collector street, as well as its immediate adjacency to singlefamily homes, the Director has determined Planning Commission review is appropriate.
To ensure that design, compatibility, and technical impacts are evaluated, the Director has required processing under UCMC Chapter 18.76 and has also directed that the application be subject to peer review, per UCMC Section 18.114.120.D. Further, Site Development Review provides greater opportunity for input and oversight.
Agenda Item No. 4.2.1.
Planning Commission Staff Report Page 4 of 11 October 16, 2025 B. Project Design and Development Standards Compliance
The project is subject to UCMC Chapter 18.114 Wireless Telecommunications Facilities, the purpose of which is to provide standards for the development, location, siting, and installation of wireless telecommunication facilities.
Location
Per UCMC Section 18.114.060, the antennas and equipment will be located so as not to be readily visible, as shown in the Photo Simulations, Exhibit C. The proposed antenna facility will be housed in an approximately 2,320 square-foot FRP (fiber-reinforced polymer) enclosure and be located behind the parapet on the highest roof of the existing building. The enclosure will feature a stealth design as a second story addition, designed to match the existing building in terms of architecture, colors, and materials. The wireless facility will be outside of any required setbacks for structures at the site. The proposed structure will be set back 80 feet from the adjacent residential lots at the rear of the site.
A 359 square-foot lease area to accommodate an equipment enclosure, also designed to match the existing building, will be located on the ground, adjacent to the east side of the building. The enclosure for equipment will also be located outside of any required setbacks.
Design
The project meets the design requirements of UCMC Section 18.114.080. Below is the list of requirements, with a description of how the project complies with each. • All wireless telecommunication facilities shall be designed and located so as not to be readily visible, by means of design, placement, screening, and camouflage.
The applicant shall use the smallest and least visible antennas feasible to accomplish the owner or operator's coverage or capacity objectives.
The existing height of the building from the ground to the top of the parapet is 28 feet 5 inches. The enclosure will be architecturally integrated to appear as a second-story addition to the building on which it is mounted. The facility will be constructed on the roof, projecting 15 feet above the parapet, bringing the total height of the building to 43 feet 5 inches.
The existing building has a hipped roof that slopes down on all four sides, and a parapet wall that extends above the roofline. The wireless facility will also feature a hipped roof with a short parapet above.
• Colors and materials for facilities shall be chosen to minimize visibility. All visible exterior surfaces shall be constructed of non-reflective materials. Facilities shall be painted or textured using colors to match or blend with the primary background.
Attached antennas (antennas affixed to an existing structure that is not considered a component of the attached antenna) shall be painted and/or textured to match the existing support structure.
Agenda Item No. 4.2.1.
Planning Commission Staff Report Page 5 of 11 October 16, 2025 The FRP screening will be designed and painted to match the architecture, color, and texture of the existing building on which it will be located. Fenestration will be added to the FRP enclosure, so as to appear as an authentically active space. To address potential visibility and aesthetic concerns, Condition of Approval # 8 requires all visible exterior surfaces, including conduits or other equipment, to be constructed of non-reflective materials, match the existing background, and to be concealed and screened.
• All equipment shelters or cabinets shall be concealed from public view or made compatible with the architecture of surrounding structures.
The separate 359 square-foot equipment enclosure will be located on the ground, adjacent to the building on the east side. It will enclose wireless equipment, cabinets, and a generator to serve the facility. The equipment enclosure will measure nine (9) feet, ten (4) inches in height and be constructed of concrete masonry units (CMU). The equipment enclosure will be camouflaged with paint and exterior materials that will match the existing building that supports the wireless facility.
• Wireless telecommunication facility lighting shall be designed to meet but not exceed minimum requirements for security, safety, or Federal Aviation Administration (FAA) regulations, and in all instances shall be designed to avoid glare and minimize illumination on adjacent properties.
Condition of Approval # 9 will require that facility lighting be designed to meet requirements for security, and Federal Aviation Administration (FAA) regulations, as well as to be designed to prevent light spillage, or glare, onto adjacent properties.
• No advertising shall be placed on telecommunication antennas or other equipment.
Condition of Approval # 10 will require that no advertising be placed on any part of the wireless facility, equipment, or the equipment enclosure. • All wireless telecommunication facilities shall be designed to be resistant to and minimize opportunities for unauthorized access, climbing, vandalism, graffiti, and other conditions that would result in hazardous conditions, visual blight, or attractive nuisances.
Condition of Approval # 11 will require the provision of warning signs, anti-climbing devices, etc., to prevent unauthorized access and vandalism and to reduce the potential for the wireless facility to become an attractive nuisance. • Building-mounted antennas and any ancillary equipment shall not be permitted unless they are on scale and architecturally integrated and camouflaged with the building design in such a manner as to be visually unobtrusive.
The enclosure will provide ladder access from the ground to the lower roof of the existing building and then to the upper roof where the new wireless facility will be Agenda Item No. 4.2.1.
Planning Commission Staff Report Page 6 of 11 October 16, 2025 located. The ladders and all exterior equipment will be camouflaged to match the existing surroundings and buildings.
• Where feasible, antennas should be placed directly above, below or incorporated with vertical design elements of a building to help in camouflaging.
As detailed above, the enclosure will be architecturally integrated to appear as a second-story addition to the building on which it is mounted. • Roof-mounted antennas shall be screened from public view and located the maximum distance from the edge of the roof as technologically feasible.
The applicant positioned the antennas to reduce emission exposure as much as technologically feasible.
Easements
The project proposes a fiber conduit from an existing AT&T fiber box at the northwest corner of the lot to connect to the proposed equipment enclosure through a new, six-footwide AT&T non-exclusive utility easement. A second, 15-foot-wide, non-exclusive access easement is proposed at the easterly driveway on Alvarado-Niles Road. The easements will allow AT&T to access the ground equipment enclosure and the wireless facility on the roof. The easements are non-exclusive in the event of a collocation for an additional wireless facility by another provider. No aspect of the project, including the easements, will eliminate parking spaces at the site. See Condition of Approval # 21 for requirements for applicant to coordinate the execution of the non-exclusive easements with the relevant agency or company.
Peer Review
Per UCMC Sec. 18.114.120.D, the Director has the discretion to authorize peer review by independent technical experts to review any material submitted as part of this application. The City authorized a peer review of the applicant’s required application materials, which included the Radio Frequency (RF) Emissions Compliance Report, noise analysis, coverage, and the alternative site analysis. The City’s consultant, Douglas Herring & Associates (DHA), provided services to conduct a professional peer review of the applicant’s submitted technical studies. DHA procured the expertise of subcontractors that specialize in the fields as related to the various analyses provided by the applicant. The coverage analysis and evaluation of radio frequency (RF) emissions was performed by cellular technology expert David Allen Burgess. Peer review of the noise analysis was performed by acoustical expert Michael Thill of Illingworth & Rodkin, Inc.
Finally, the evaluation of the alternative sites analysis was performed by Doug Herring, Principal of DHA.
The federal Telecommunications Act of 1996, requires the City of Union City to act “within a reasonable period of time.” Under rules adopted by the FCC, there is a legal presumption that a local government has violated this “reasonable period of time” requirement if it takes longer than 150 days to act on an application to deploy a wireless facility using a new structure. However, the period of time for review of an application may be extended by written agreement between the applicant and the City. Due to the required Agenda Item No. 4.2.1.
Planning Commission Staff Report Page 7 of 11 October 16, 2025 peer review of the application, the applicant and the City of Union City agreed in writing to extend the 150-day “shot clock” deadline to October 27, 2025.
The project has been determined to comply with relevant federal standards from the FCC.
Materials related to the peer review and radio frequency levels have not been included as attachments to this staff report, as they are not relevant to the findings needed for a conditional use permit application or site development review.
Radio Frequency Emissions
Per the author of the RF emissions standards peer review, FCC OET Bulletin 65, “Evaluating Compliance with FCC Guidelines for Human Exposure to Radio Frequency Electromagnetic Fields”, defines methodologies for estimating whether or not a particular radio system installation exposes people to excessive levels of radio energy. This document may be referred to as “OET-65” (Office of Engineering and Technology Bulletin 65). This technical bulletin provides guidelines for evaluating compliance with the FCC's RF safety standards.
The peer review of the applicant’s initial RF report submittal concluded that the closest rooftops on Condor Street would be as high as 94% of the OET-65 limit. Though the level did not exceed the FCC OET Bulletin 65 recommendations for general public exposure, it was very close. In light of this conclusion, staff requested that the applicant move the antennas farther from the residences so the emissions levels would be reduced.
The applicant resubmitted plans to show a repositioning of the antennas, as well as an updated Radio Frequency Report. The peer review of the updated plans and report concluded the exposure on the closest rooftops of the Condor Street residences would be reduced from 94% of the OET-65 limit to 83% - 85% and recommends that the updated Waterford report of September 5, 2025, be accepted as a valid exposure estimate.
Mr. Burgess concludes that the expected RF exposure levels for surrounding residences are below the recommended safety limits, even for people standing on rooftops outside the structures under all possible conditions and that there is no reason to expect that this system would present any hazard to residents at those locations.
Noise
The ground equipment enclosure supporting the wireless facility will include a generator and an air conditioning unit for one of the cabinets, both of which will generate noise. The applicant provided a noise analysis, Attachment 2, for the project, which was peer reviewed by the City’s Environmental Consultant. Per UCMC Section 9.40.041, Residential Property Noise Limits, no noise shall be produced on residential property by a noise level more than 10 dBA above local ambient outside of the property. Under UCMC Section 9.40.030, local ambient noise is not less than 40 dBA. The peer review concluded that the calculated noise levels from the project as proposed will comply with the noise limits established by the City of Union City. The peer reviewer’s calculation accounted for the attenuation provided by the proposed CMU wall enclosure, which will shield the equipment’s operational noise levels from the nearest sensitive receptors.
Wireless Coverage
Agenda Item No. 4.2.1.
Planning Commission Staff Report Page 8 of 11 October 16, 2025 The purpose of the installation is to help AT&T bring improved wireless communication capacity and coverage, which would benefit residents, public services, and roadway safety in Union City. The wireless facility will close a demonstrated coverage gap that currently exists in Union City. The coverage map is excluded as an exhibit because it includes proprietary information.
The peer review concluded that based on publicly available information, AT&T does have a coverage problem in the area around the proposed site, and that the projected coverage improvement appears valid according to the analysis.
Alternative Sites Analysis
Per the applicants’ Alternative Site Analysis, Attachment 3, nine alternative sites in the general vicinity of the proposed wireless facility were evaluated. However, the peer review concluded that the sites available for leasing were infeasible for technical reasons, or contact was not able to be made for the sites in the analysis.
Consistency with the General Plan
The project is consistent with the subject property's General Plan designation of Private Institutional (PI). The PI designation provides for private institutional uses that include but are not limited to cemeteries, churches, private educational facilities, private nonprofit and service organizations, and continuing care retirement communities. The wireless facility, which is a conditionally permitted use in the PI Zoning District, will utilize an existing building at the site for the project.
The Public Facilities and Services Element of the 2040 General Plan includes Policy PF- 8.8 Minimize Visual Impacts concerning the siting and screening of wireless communications facilities. This policy requires that wireless facilities meet the following conditions:
To minimize the visual impact of wireless communication facilities, the City shall ensure that these facilities meet the following conditions:
1. Monopoles and large cellular infrastructure are located away from residential and open space areas;
The proposed wireless facility would be located within a roof-mounted facility on the roof of an existing building used as a faith-based organization, or church. The location of the facility ensures the radio frequency levels would not exceed the FCC’s limits for exposure to the general public.
2. Small cell sites and supporting infrastructure are designed to minimize visibility in the public rights-of-way and residential areas;
The proposed wireless facility would be located within a structure on the roof of an existing building used for a faith-based organization. The roof-top structure would be designed to integrate with the existing building’s architecture to appear as a second-story addition. All conduit and supporting Agenda Item No. 4.2.1.
Planning Commission Staff Report Page 9 of 11 October 16, 2025 infrastructure would be enclosed and screened, minimizing potential visual impacts.
3. When possible, are located on existing buildings, existing poles, or other existing support structures;
The proposed wireless facility would be located behind the parapet on the roof of an existing building that is currently used as a faith-based organization.
4. Are collocated with other compatible facilities whenever possible; Currently, there are no existing wireless facilities on the roof of building or at the site, in general.
5. Are painted, camouflaged, textured, or disguised to resemble trees, flag poles, etc., to better blend with the surrounding environment; and All of the antennas would be entirely enclosed within the rooftop structure and not visible. The wireless facility structure would be designed to match the existing building, in terms of colors and materials.
6. Include well-designed equipment enclosures that incorporate walls or fences and landscaping to provide screening and deter graffiti or are installed in underground vaults where feasible.
The cabinets and equipment will be enclosed in a 359 square-foot concrete masonry units (CMU) structure on the ground, adjacent to the east side of the existing building, measuring nine feet, four inches in height and will be camouflaged to match the colors and materials of the existing building so as not to be visible.
The General Plan supports the ongoing expansion and enhancement of modern communication infrastructure in the City. The presence of the antennas will improve the coverage for AT&T by adding to the existing coverage in the City while meeting the intent of the telecommunication infrastructure objectives that the General Plan encourages in developing and maintaining modern communication infrastructure that supports the City’s economy, businesses, and residents. Overall, this project is consistent with the applicable policies in the General Plan.
C. Noticing & Communication
Consistent with State law noticing requirements, public hearing notices were published in the newspaper on September 28, 2025, and mailed to neighbors within 300 feet of the project site boundary on October 1, 2025. As of October 8, 2025, Staff has not received any public feedback regarding the project.
D. Conclusion
The project is consistent with the applicable policies in the General Plan and is compliant with the Union City Municipal Code. DRC recommends that the Planning Commission Agenda Item No. 4.2.1.
Planning Commission Staff Report Page 10 of 11 October 16, 2025 approve UP-25-001 and SD-25-001 and make the required findings as provided in Section III of this report and discussed in the attached resolution, in support of this approval.
III. REQUIRED FINDINGS
Use Permit
Section 18.56.060 of the Zoning Ordinance requires that the Planning Commission make a recommendation to the City Council based on the following findings in granting Use Permit approval.
1. That the proposed location of the conditional use is in accord with the purposes of Title 18 and the purposes of the district in which the site is located;
2. That the proposed location of the conditional use and the conditions under which it would be operated or maintained will not be detrimental to the public health, safety or welfare, or materially injurious to properties or improvements in the vicinity;
3. That the proposed conditional use is consistent with the general plan, any applicable specific plans, and will comply with each of the applicable provisions of Title 18.
Private Institutional (PI) District
Per UCMC Section 18.51.030, the maximum height limit shall be 35 feet. This height limit may be increased to a maximum of 50 feet subject to a use permit. Before the approval of any structure which exceeds 35 feet, the Planning Commission must make the following finding.
1. That any such excess height which exceeds 35 feet to a maximum of 50 feet will not be detrimental to the light, air or privacy of any other structure or use within the surrounding area.
Wireless Telecommunication Facilities
All of the following findings are required for approval of any use permit, administrative use permit, site development review, or administrative site development review under UCMC Section 18.114.130:
1. That the proposed project is consistent with the requirements of Chapter 18.114;
2. That the proposed wireless telecommunication facility will not be readily visible, unless it is demonstrated that it is not technically feasible to incorporate additional measures that would make the facility not readily visible; and
3. That the wireless telecommunication facility is necessary to prevent or fill a significant gap in coverage or capacity shortfall in the applicant's service area and is the least intrusive means of doing so.
Site Development Review
Agenda Item No. 4.2.1.
Planning Commission Staff Report Page 11 of 11 October 16, 2025 Section 18.76.045 of the Zoning Ordinance requires that the Planning Commission make the following findings in granting Site Development Review approval.
1. Approval of this application is consistent with the General Plan and any applicable specific plans;
2. Approval of this application is consistent with the purpose of Title 18 and the requirements of the PI, Private Institutional, Zoning District; and
3. Approval of this application is consistent with the purpose of Site Development review as outlined in Section 18.76.010.
IV. ALTERNATIVES
1. Approve Use Permit (UP-25-001) and Site Development Review (SD-25-001), as proposed;
2. Approval of Use Permit (UP-25-001) and Site Development Review (SD-25-001), with modified conditions;
3. Denial of Use Permit (UP-25-001) and Site Development Review (SD-25-001), with stated findings; or
4. Continue the matter for further consideration.
V. RECOMMENDATION
Staff recommends that the Planning Commission approve Use Permit (UP-25-001) and Site Development Review (SD-25-001) subject to conditions, and make the required findings discussed in the attached resolution in support of this approval.
Prepared by
Natalie Dean, Associate Planner
Attachments
1. Attachment 1: Draft Planning Commission Resolution Approving UP-25-001, SD-25- 001.
2. Exhibit A - Project Plans
3. Exhibit B - Statement of Use
4. Exhibit C - Photo Simulations
5. Attachment 2 - Noise Analysis
6. Attachment 3 - Alternative Site