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August 16, 2001 <br />HARING, LEE AND GRDVES <br />PROFE88IONAL ASSOCIATION <br />ATTORNEYS AND COUNSELLORS <br />SUITE 502 <br />205 WEST JEFFERSON BOULEVARD <br />SOUTH BEND, INDIANA 46601 -1812 <br />Donald E. Inks, Director <br />Division of Economic Development <br />1200 County -City Building <br />South Bend, Indiana 46601 -1830 <br />Re: Verizon Wireless - Resolution No. 1843 <br />Dear Mr. Inks: <br />TELEPHONE (219) 232 -5923 <br />FAX (219) 23L -5942 <br />Please be advised that I represent Verizon Wireless, Inc. which received a notice of a public hearing <br />on a proposed amendment to the South Bend Central Development Area development plan which <br />involves two lots and improvements owned by Verizon Wireless, Inc. at 220 East Side of Sycamore <br />Street and 222 East Side of Sycamore Street. Verizon Wireless, Inc. is the title owner and successor - <br />in- interest of United Tele Spectrum of Indiana, Inc. <br />Verizon Wireless is a company which provides South Bend and other areas with telephonic <br />communications not requiring a direct wire connection to the broader telephone system. This <br />`wireless' communication system is provided by, among other things, the use of towers which relay <br />communication signals to a localized area, thereby negating the necessity for direct wire connection <br />to an individual's telephone. These towers are fundamental to the proper working of the system. <br />When an area lacks a tower that area, in turn, lacks the ability to have wireless communication <br />capabilities. <br />Verizon Wireless, Inc. has placed such a communications tower on the two lots at 220 and 222 East <br />Side of Sycamore Street. This tower provides the downtown area of South Bend with wireless <br />communications capabilities on the Verizon Wireless communications system The taking of these <br />two lots, and the commensurate destruction ofthe tower, will seriously disrupt wireless phone service <br />in the downtown area. The numerous South Bend customers of Verizon Wireless will suffer a loss <br />that cannot be compensated. <br />The taking of the property and the tower, without providing suitable replacement property, could <br />virtually eliminate Verizon service to the downtown South Bend area because this tower primarily <br />EDWARD W. HARDIG <br />ROBERT D. LEE <br />JAMES F. GROVES <br />JAMES P. EHRHARD <br />DAVID E. BALLARD <br />OF COUNSEL <br />August 16, 2001 <br />HARING, LEE AND GRDVES <br />PROFE88IONAL ASSOCIATION <br />ATTORNEYS AND COUNSELLORS <br />SUITE 502 <br />205 WEST JEFFERSON BOULEVARD <br />SOUTH BEND, INDIANA 46601 -1812 <br />Donald E. Inks, Director <br />Division of Economic Development <br />1200 County -City Building <br />South Bend, Indiana 46601 -1830 <br />Re: Verizon Wireless - Resolution No. 1843 <br />Dear Mr. Inks: <br />TELEPHONE (219) 232 -5923 <br />FAX (219) 23L -5942 <br />Please be advised that I represent Verizon Wireless, Inc. which received a notice of a public hearing <br />on a proposed amendment to the South Bend Central Development Area development plan which <br />involves two lots and improvements owned by Verizon Wireless, Inc. at 220 East Side of Sycamore <br />Street and 222 East Side of Sycamore Street. Verizon Wireless, Inc. is the title owner and successor - <br />in- interest of United Tele Spectrum of Indiana, Inc. <br />Verizon Wireless is a company which provides South Bend and other areas with telephonic <br />communications not requiring a direct wire connection to the broader telephone system. This <br />`wireless' communication system is provided by, among other things, the use of towers which relay <br />communication signals to a localized area, thereby negating the necessity for direct wire connection <br />to an individual's telephone. These towers are fundamental to the proper working of the system. <br />When an area lacks a tower that area, in turn, lacks the ability to have wireless communication <br />capabilities. <br />Verizon Wireless, Inc. has placed such a communications tower on the two lots at 220 and 222 East <br />Side of Sycamore Street. This tower provides the downtown area of South Bend with wireless <br />communications capabilities on the Verizon Wireless communications system The taking of these <br />two lots, and the commensurate destruction ofthe tower, will seriously disrupt wireless phone service <br />in the downtown area. The numerous South Bend customers of Verizon Wireless will suffer a loss <br />that cannot be compensated. <br />The taking of the property and the tower, without providing suitable replacement property, could <br />virtually eliminate Verizon service to the downtown South Bend area because this tower primarily <br />