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Home My WebLink About1800 Hillside Drive - Staff Report (2)i � euR�-'" ini�an�e AGENDA NO: � STAFF REPORT MEETING DATE: September 4, 2018 To: Honorable Mayor and City Council Date: September 4, 2018 From: Kevin Gardiner, Community Development Director —(650) 558-7253 Subject: City Council Consideration of an Appeal of the Planning Commission's June 11, 2018 Action Denying Without Prejudice an Application for a Conditional Use Permit to Install a New Wireless Facility (Antenna and Equipment) on an Existing Wood Utility Pole Located Within the Right-of- Way Adjacent to 1800 Hillside Drive RECOMMENDATION The City Council should conduct a public hearing, consider all oral and written testimony received during the hearing and, following closure of the hearing and deliberations, take one of the following actions: • Deny the appeal and uphold the Planning Commission's denial of the application without prejudice; • Grant the appeal, overrule the Planning Commission's denial, and approve the application, with or without amended conditions; or • Remand the application to the Planning Commission for reconsideration, with specific direction on aspects of the project to be re-evaluated. Whether the City Council decides to uphold the Planning Commission's denial without prejudice, or approve the application (with or without amended conditions), the City Council should state the finding(s) along with reasons for its decision based on the record and direct staff to prepare a resolution memorializing its decision for consideration and adoption at the next regular City Council meeting. BACKGROUND Wireless Communications Ordinance: The City's authority to regulate the placement of wireless communications facilities in the public rights-of-way is subject to certain limitations in state and federal law. These are discussed in more detail in the attached legal memorandum. In summary, under state law, both wireline and wireless telephone companies have a statutory state franchise to use public rights-of-way for placement of their facilities. The City can, within limited discretion, control the time, place, and manner of installation to ensure that facilities do not "incommode the public use" of the public rights-of-way. Federal law generally preserves local authority to regulate, 1 Appeal — 1800 Hillside Drive September 4, 2018 with some important substantive and procedural restrictions, including the following: (i) the City must act on any permit application within a reasonable period of time; (ii) a local government may not "unreasonably discriminate" in its siting decisions with respect to providers of "functionally equivalent services"; (iii) regulation must not prohibit or have the effect of prohibiting the provision of personal wireless services; (iv) radio frequency ("RF") emissions cannot serve as a basis for denying or regulating wireless facilities to the extent that such facilities comply with the Federal Communications Commission (FCC) regulations concerning such emissions; and (v) denials must be "in writing" and based on "substantial evidence" contained in a written record. The City Council adopted the City's Wireless Communications Ordinance on February 6, 2012. The purpose of this ordinance is to maintain and, more importantly, facilitate modernization of Burlingame's communications infrastructure in a manner that improves the quality of the city's environment, the pleasant aesthetics of the city's neighborhoods, the city's architectural traditions dating to the early 20th century, and the visual quality in the non-residential areas of the city. More specifically, the purpose of this ordinance is to regulate, as allowed by state and federal law and regulations, the placement of wireless communications facilities in Burlingame in a manner that recognizes the community benefits of communications technology, which provides clear guidance to the communications industry but also recognizes the strong need to preserve the city's aesthetic traditions. Burlingame Municipal Code Sections 25.77.080(c) and 25.77.090, which address location preference order and design criteria, respectively, are provided in the attachment titled "Title 25 — Zoning Code — Chapter 25.77 — Wireless Communications Facilities — Code Sections 25.77.080 (c) and 25.77.090". Project Description: The applicant is proposing to install a new wireless communication facility (wireless facility) on an existing wood utility pole jointly owned by public utilities and other entities who are members of the Northern California Joint Pole Association. The project consists of installing a cylindrical antenna and extension on top of the existing utility pole and associated equipment and cabling mounted on the side of the utility pole. The proposed antenna, equipment, and cabling are proposed to be painted to match the utility pole. The PG&E utility pole is located within the right-of-way near the corner of Hillside Drive and Cabrillo Avenue, adjacent to the parcel with an address of 1800 Hillside Drive. The utility pole is located along Hillside Drive, in the planter strip between the sidewalk and street. The proposed site is surrounded by single family residential uses and Our Lady of Angels Catholic Church and School to the east. There are existing street trees on either side of the utility pole, which would not need to be removed to accommodate the proposed wireless facility. An application for a Conditional Use Permit is required because the project consists of installing a new wireless facility (not a co-location) and because it is located in a residential zoning district.' The following application was submitted for the project: ' AT&T's appeal letter dated August 22, 2018 incorrectly states that the proposed facility is within 500 feet of a residential zoning district. It is in fact within a residential zoning district. Zoning districts go to the centerline of the street, consistent with Section 25.12.020(a). 2 ,� . Appeal - 1800 Hil/side Drive September 4, 2018 • Conditional Use Permit to install a new wireless facility (antenna and equipment) on an existing wood utility pole located within the right-of-way (C.S. 25.77.050 (c)). For a full description and analysis of the project, please refer to the attached June 11, 2018 Planning Commission staff report and attachments, as well as the supplemental letter, exhibits, and revised plans submitted by the applicant, dated August 22, 2018. Changes to Proposed Project Since June 11, 2018 Planning Commission Denial Without Prejudice: Since the June 11, 2018 Planning Commission meeting, several changes were made to the proposed wireless facility to address concerns and comments expressed by the Planning Commission. Please refer to the applicanYs attached letter, exhibits, and revised plans, dated August 22, 2018, for additional information. The following changes were made to the project: • AT&T worked with PG&E to allow installation of a smaller meter, called a SmartPole Meter. The previously proposed meter measured 1'-0" wide x 2'-0" tall (2 square feet). The SmartPole Meter measures 4.18 inches wide x 7.17 inches tall (0.2 square feet). • The previous proposal consisted of the electric load center box and fiber distribution panel being attached side-by-side on the pole. The revised project includes installing these two boxes on top of one another, in line with the other equipment boxes on the pole. Required Findings for a Conditional Use Permit for a Wireless Communications Facility (Code Sections 25.77.050(c), 25.77.130, and 25.52.020, a-c): In order to grant a Conditional Use Permit for a Wireless Facility, the City must find: (1) The proposed facility complies with all the requirements of Chapter 25.77 and with all applicable requirements of other chapters of the Burlingame Municipal Code. (2) The proposed use, at the proposed location, will not be detrimental or injurious to property or improvements in the vicinity and will not be detrimental to the public health, safety, general welfare or convenience. (3) The proposed use will be located and conducted in a manner in accord with the Burlingame general plan and the purposes of the Zoning Code. (4) The City may impose such reasonable conditions or restrictions as it deems necessary to secure the purposes of the Zoning Code and to assure operation of the use in a manner compatible with the aesthetics, mass, bulk, and character of existing and potential uses on adjoining properties in the general vicinity. (5) In approving a use permit pursuant to Chapter 25.77, the City may impose conditions, not prohibited by applicable federal and state law, which are deemed necessary to ensure compliance with the provisions of Chapter 25.77, the provisions of the Burlingame Municipal Code and the provisions of any other applicable laws and regulations. 3 Appeal - 1800 Hillside Drive September 4, 2018 Planning Commission Action: At its regular meeting of June 11, 2018, the Planning Commission denied without prejudice the applicanYs request for a Conditional Use Permit to install a new wireless facility on an existing wood utility pole located within the right-of-way adjacent to 1800 Hillside Drive (see attached June 11, 2018 Planning Commission meeting minutes). Appeal of Planning Commission's Action: Subsequent to the Planning Commission's action, Talin Aghazarian, an agent for AT&T, filed a timely appeal of the Commission's action (see attached letter dated June 21, 2018). AT&T followed up its appeal with a letter and several exhibits that explains their reasons for filing the appeal. The letter, dated August 22, 2018 and prepared by John di Bene, General Attorney for AT&T, is attached to this report for the City Council's review and consideration. Factors to Consider on the Appeal: As noted above, federal law prohibits cities from considering radio frequency ("RF") emissions as a basis for denying or regulating wireless facilities if (as is the case here) the applicant has demonstrated that the proposed wireless facility complies with the FCC's RF emissions regulations. The City Council is therefore limited to reviewing and discussing the proposed design and location of the wireless facility and making findings based on the requirements in the ordinance and within the constraints of federal and state law governing the regulation of telecommunications facilities. The City Council should therefore focus its consideration of the appeal and the required findings based on the evidence in the record and considering the wireless facilities design and location criteria set forth in Sections 25.77.080 and 25.77.090, which for convenience are attached to this staff report. AT&T's Effective Prohibition Claim: In its appeal letter dated August 22, 2018 at pages 7-9, AT&T claims that the City may be required to approve its project to avoid violating federal law because denial of the project by the City would "prohibit or have the effect of prohibiting the provision of personal wireless services." (47 U.S.C. Section 332(c)(7)(B)(i)(II)). Because AT&T has raised this issue, if the City Council determines that it cannot make the required findings for granting the appeal and approving the application based on the evidence in the record and considering the wireless facilities design and location criteria set forth in Sections 25.77.080(c) and 25.77.090, then, the City Council should consider the evidence and arguments as to whether its proposed denial would "prohibit or have the effect of prohibiting the provision of personal wireless services" in conflict with federal law, and determine whether or not it must approve the project to avoid such a result. Exhibits: • Legal Memorandum • Title 25 — Zoning Code — Code Sections 25.77.080 (c) and 25.77.090 • Letter and Exhibits Submitted by John di Bene, General Attorney for AT&T, dated August 22, 2018 • Appeal Letter Submitted by Talin Aghazarian (AT&T), dated June 21, 2018 • June 11, 2018 PC Minutes (excerpt) • Correspondence Received After Preparation of the June 11, 2018 Planning Commission Staff Report ..� � Appeal —1800 Hil/side Drive • June 11, 2018 PC Staff Report (including all attachments) • Previously Proposed and Revised Plans September 4, 2018 5 Indian Wells (760)568-2611 Irvine (949)263-2600 Manhattan Beach (310) 643-8448 Ontario (909) 989-8584 Gail A. Karish Partner (213) 617-7491 gail.karish@bbklaw.com i:�:� BEST BEST & KRIEGER � ATTORNEYS AT LAW 300 South Grand Avenue, 25th Floor, Los Angeles, CA 90071 Phone: (213) 617-8100 � Fax: (213) 617-7480 � www.bbklaw.com Memorandum To: From: Meeting Date: Re: Honorable Mayor and City Council City of Burlingame, California Gail A. Karish September 4, 2018 Riverside (951) 686-1450 Sacramento (916) 325�000 San Diego (619)525-1300 Walnut Creek (925) 977-3300 Washington, DC (202) 785-0600 AT&T Wireless Appeals (Adjacent to 701 Winchester Drive and 1800 Hillside Drive) This memo provides guidance on select topics concerning the scope of City Council authority which may be pertinent when considering the above-noted appeals. 1. Consideration of Aesthetics The City can, within limited discretion, control the time, place, and manner of installation to ensure that facilities do not "incommode the public use" of the public rights-of-way. Under California law, telephone companies have state franchise rights to use public rights-of-way pursuant to Public Utility Code Section 7901 ("Section 7901 "). Section 7901 has long been interpreted as a statutory grant of a franchise to telephone companies to use and place "telephone lines" in public rights-of-way, and to "erect poles, posts, piers, or abutments for supporting the insulators, wires, and other necessary fixtures of their lines...".1 Public Utility Code Section 233 deiines "telephone line" broadly to include "all conduits, ducts, poles, wires, cables, instruments, and appliances, and all other real estate, fixtures, and personal property owned, controlled, operated, or managed in connection with or to facilitate communication by telephone, whether such communication is had with or without the use of transmission wires." (emphasis addec�. The courts have held that the statutory definition of "telephone line" is sufiiciently broad to include a wide range of technologies including facilities and equipment installed by carriers in connection with or to facilitate both wireless and landline telecommunications services.z The right of telephone companies to use public rights-of-way to deploy facilities under the state franchise is, however, not unfettered. The City's ability to regulate the public right-of- way is an extension of its police powers under California Constitution, article 11, section 7; ' County ofLosAngeles v. General Tel. Co. (1967) 249 Ca1.App.2d 903, 904. 2 City of Huntington Beach v. Public Utilities Com. (2013) 214 Ca1.App.4th 566, 587-8 ("Ciry of Huntington Beach"); GTE Mobilenet of Cal. Ltd. v. City of San Francisco (N.D. Cal. 2006) 440 F.Supp.2d 1097, 1103. i:�:� BEST BEST & KRIEGER � ATTORNEYS AT LAW Section 7901 is a"limited grant of rights to telephone corporations, with a reservation of local police power that is broad enough to allow discretionary aesthetics-based regulation."3 Specifically, Section 7901 provides that such use must be "in such manner and at such points as not to incommode the public use of the road...". The phrase "incommode the public use" in Section 7901 means "to unreasonably subject the public use to inconvenience or discoinfort; to unreasonably trouble, annoy, molest, embarrass, inconvenience; to unreasonably hinder, impede, or obstruct the public use."4 "Incommode" is "broad enough `to be inclusive of concerns related to the appearance of a facility"', and therefore, Section 7901 does not prohibit local governments from conditioning the approval of a particular permanent siting permit on aesthetic concerns.5 Thus, there is precedent for not only requiring discretionary review and conditioning approvals, but also even denying applications for facilities in particular locations in the public rights-of-way under Section 7901, for example due to aesthetic concerns regarding pole heights or underground districts.6 Further, a local government has the right under Section 7901.1 "to exercise reasonable control as to the time, place, and manner in which roads...are accessed [by telephone companies]."� The "time, place and manner" of temporary access refers to "when, where, and how telecommunications service providers gain entry to the public rights- of-way."g In addition to Sections 7901 and 7901.1, Pub. Util. Code Section 2902 also protects a local government's right "to supervise and regulate the relationship between a public utility and the general public in matters affecting the health, convenience, and safety of the general public, including matters such as the use and repair of public streets by any public utility, the location of the poles, wires, mains, or conduits of any public utility, on, under, or above any public streets...within the limits of the municipal corporation." This provision is a further basis for a local government to restrict the location of proposed facilities due to public safety reasons or other local concerns or even deny applications in appropriate circumstances. The Burlingame Municipal Code, including in particular Chapter 25.77 and Sections 25.77.080(c) and 25.77.090, which address location preference order and design criteria, respectively, provide an expression of the City's aesthetic and locational concerns and preferences for what types of deployments would and would not "incommode the public use." 3 T-Mobile West LLC v. City and Cou�ary of San Francisco (2016) 3 Ca1.App.Sth 334, 346 [review granted (Dec. 16, 2016) 385 P3d 411] ("T-Mobile West LLC"). 4Id. at 355, quoting Sprint PCSAssets, L.L.C. v. Ciry of Palos Verdes Estates (9th Cir. 2009) 583 F.3d 716, 723. See also, NextG Networks of Cal., Inc. v. Ciry of Newport Beach (C.D. Cal. Feb. 18, 2011) 2011 U.S. Dist. LEXIS 17013; Western Union Tel. Co. v. Visalia (1906) 149 Cal. 744. 5 T-Mobile West LLC, 3 Ca1.App.Sth at 344. 6 Id. � See City of Huntington Beach, 214 Ca1.App.4th 566 at 569, fn. omitted. g T-Mobile West LLC, 3 Ca1.App.Sth at 358, quoting Sprint PCS Assets LLC v. Ciry of Palos Verdes Estates (9th Cir. 2009) 583 F3d 716, at 725. -2- i:�:� BEST BEST & KRIEGER � ATTORNEYS AT LAW 2. Substantial Evidence Federal law provides that any decision to deny a request to build personal wireless facilities "shall be in writing and supported by substantial evidence contained in a written record" submitted contemporaneously with the denial.9 To determine whether a local government's decision is supported by substantial evidence within the meaning of the statute, a reviewing court "must be able to identify the reason or reasons why the locality denied the application."10 The rationale behind such a denial need not be "elaborate or even sophisticated"—rather, a local authority must provide a rationale clear enough to "enable judicial review."11 In the Ninth Circuit, courts have construed the "substantial evidence" standard as requiring that the local government's decision be (1) authorized by local law and (2) supported by a reasonable amount of evidence.1z There is no precise formula for determining when the "substantial evidence" requirement is met; rather, a reviewing court will affirm when a denial is supported by "such relevant evidence as a reasonable mind might accept as adequate to support a conclusion".13 Considerations of aesthetics in a denial are permissible when based on substantial evidence.14 However, a denial based on aesthetics would not be permissible if such denial would result in an effective prohibition.ls A decision to deny a wireless facility application cannot be based on concerns about RF emissions if the applicant has demonstrated that its facilities will comply with FCC standards.'� Thus, direct or indirect concerns over the health effects of RF emissions may not serve as 9 47 U.S.C. § 332(c)(7)(B)(iii); see T-Mobile S., LLC v. City of Roswell, Ga. (2015) 135 S. Ct. 808, 815. 10 Id. at 814. " Id. at 815. 1z See Sprint PCSAssets, L.L.C. v. Ciry ofPalos Verdes Estates (9th Cir2009) 583 F.3d 716, 721 ("Palos Verdes Estates"); MetroPCS v. City and County of San Francisco (9th Cir.2005) 400 F.3d 715, 725("MetroPCS"). 13 Palos Verdes Estates, 583 F.3d at 726; see MetroPCS, 400 F3d at 725, quoting Cellular Telephone Company v. Town of Oyster Bay (2nd Cir. 1999) 166 F.3d 490 (local government must have "less than a preponderance, but more than a scintilla of evidence."). 14 Sprint PCS Assets LLC v. City of Palos Verdes Estates (9th Cir. 2009) 583 F3d 716, 722-723; NextG Networks of Cal., Inc. v. City of Newport Beach (C.D. Cal. Feb. 18, 2011) 2011 U.S. Dist. LEXIS 17013, * 18 ("In this case, the City was entitled to determine that degrading the aesthetic of the Pacific Coast Highway area decreases the public's ability to enjoy this area. This decreased enjoyment, in tum, quite obviously risks damage to property values and has other `materially detrimental' effects to nearby owners, residents and businesses."). 15 See discussion below. �� 47 U.S.C. §332(c)(7)(B)(iv); Gov. Code §65850.6(fl. -3- i:�:� BEST BEST & KRIEGER � ATTORNEYS AT LAW "substantial evidence" to deny an application if the proposed facilities comply with the FCC's regulations. l� Public concerns about property values sometimes are found to serve as a proxy for impermissible concerns about RF emissions.18 Where the public concerns on property values are relatively generalized and limited, the courts tend to �nd there is no substantial evidence, or if they are contradicted by expert evidence, the expert evidence tends to be favored.19 Case law suggests expert evidence about impacts on property values in other communities is not adequate to respond to local concerns about local property values.20 When faced with credible expert evidence on both sides, a reviewing court is likely to defer to the local jurisdiction's decision.zl 3. Effective Prohibition Standard Under 47 U.S.C. Section 332 ("Section 332"), a local government cannot regulate the "placement, construction, and modification of personal wireless service facilities" where such regulation has the effect of actually or effectively prohibiting service. In the Ninth Circuit, a regulation, or application denial, prohibits or has the effect of prohibiting the provision of '� AT&T Wireless Services of California LLC v. City of Carlsbad (S.D. Cal. 2003) 308 F. Supp. 2d 1148, 1159; MetroPCS, Inc. v. City and Counry of San Francisco (9th Cir. 2005) 400 F.3d 715, 736. i� AT&T Wireless Services of California LLC v. City oJCarlsbad, at 1161; Cellular^ Telepho�ae Co. v. Town of Oyster Bay (2d Cir. 1999) 166 F.3d 490, 496-7 ("Cellular Telephone"). 19 Cellular Telephone Co., 166 F3d at 496 ("the volume and specificity of the comments were not adequate to satisfy the requirement of the substantial evidence standard.... A few generalized concerns about potential decrease in properiy values, especially in light of AT&T's contradictory expert testimony, does not seem `adequate to support a conclusion' that the permits should be denied." (citations omitted)); see also, T-Mobile Northeast LLC v. Ciry Council of Newport News (4th Cir. 2012) 674 F3d 380 (Court upholds lower court holding, stating that "although citizens need not be `armed with a slew of experts,' where `the only cohesive thread' of opposition was found in `four citizens' passing comments on property values,' such opposition was not substantial evidence."). 20 Michael Linet, Inc. v. Vill. of Wellington (l lth Cir. Fla. 2005) 408 F.3d 757, 762 (Court upheld local decision based on public concerns stating: "Linet's expert testimony contradicting the adverse property value iinpact concerns was provided by a telecommunications executive who placed a tower in a different part of the community and a realtor who based his knowledge on condominium sales in a different county. This does not change our conclusion. The residents were worried about the iinpact of this tower on the golf course within their community, not a different tower, different location, or different community.") 21 Primeco Personal Communs., L.P. v. Village of Fox Lake (N.D. Ill. 1999) 35 F.Supp.2d 643, 649 ("[S]ubstantial record evidence supports the Village's decision to deny PrimeCo's application. Pointer's testimony supports both of the Village's major reasons for denying the permit: negative economic impact based on diminished future residential and resort development and decreased enjoyment by current owners of their property. Pointer, an expert in urban planning...relied on his 37 years of experience and various photographs, primarily of the balloon test, which demonstrate the visual impact of the proposed I50-foot tower at the Hellios site. Although PrimeCo's expert, George Baker, disagreed with Pointer's assessment of the proposed tower's impact, the standard of review does not permit us to resolve this conflict anew. The Village chose to believe Pointer's assessment, as it was entitled to do. A reasonable mind could accept Pointer's testimony as sufficient to support the Village's conclusion that the proposed monopole could stunt development and injure residents' enjoyment of their property. We see no reason to disturb the Village's choice."). -4- IC�C� BEST BEST & KRIEGER � ATTORNEYS AT LAW personal wireless services within the meaning of federal law if it: (1) bans the provision of personal wireless services outright or (2) has effectively prohibited the provision of such services.22 Showing the mere potential for prohibition is not sufficient to overcome local discretionary review power.23 A denial can be found to improperly "prohibit" personal wireless services if it prevents a wireless services provider from closing a"signifcant gap" in its own service coverage using the least intrusive means.24 There is no bright-line rule regarding when a gap is "significant," and the determination is based on a fact-specifc analysis.25 To support the contention that a site is necessary to close a significant gap, the provider must in the application process demonstrate that the significant gap exists, and that the manner in which it proposes to fill the significant gap in service is the "least intrusive" means.z� To do so the provider must be able to show that it has made a good faith effort to identify and evaluate less intrusive alternatives, such as consideration of less sensitive sites, alternative system designs, alternative tower designs, placement of antennas on existing structures, etc.27 The burden is on the applicant to submit a"comprehensive application" which shows "a meaningful comparison of alternatives."28 The least intrusive means standard requires an analysis in relation to the factors in the locality's code, not generalized observations.z9 Once the applicant has done that, the burden shifts to the locality. That is, a municipality is not compelled to accept the provider's representations as to the least intrusive means, however, in order to reject them, it must show that there are soine potentially available and technologically feasible alternatives, and the provider must have an opportunity to dispute the availability and feasibility of the alternatives favored by the locality.3o zz Sprint Telephony PCS, L.P. v. Cnty. of San Diego (9th Cir. 2008) 543 F.3d 571, 579 ("Sprint IP'); Metro PCS, 400 F.3d at 730-31. 23 Sprint II, 543 F.3d at 579. Examples of regulations that "effectively prohibit the provision of service" include, e.g., an ordinance requiring that all facilities be underground when, to operate, wireless facilities must be above ground, or, an ordinance mandating that no wireless facilities be located within one mile of a road, where, because of the number and location of roads, the rule constituted an effective prohibition. Id. at 580. 24 Metro PCS, 400 F.3d at 731. 25 Id.; City of Palos Verdes Estates, 583 F.3d at 727. 26 Metro PCS, 400 F.3d at 734. 27 T-Mobile USA Inc. v. Ciry of Anacortes (9th Cir. 2009) 572 F.3d 987, 996, fn. 10. 28 Am. Tower Corp. v. City of San Diego (9th Cir. 2014) 763 F.3d 1035, 1056-7. z9 Id. ("To prevail on this claim, therefore, ATC must show that its facilities were the "least intrusive means" in light of the aesthetic values that motivated the City's decision to deny the CUP applications.") 3o T-Mobile USA Inc. v. City ofAnacortes (9th Cir. 2009) 572 F.3d 987, 999. -5- Alternative Sites Analysis SFOK2 014 ��". - �� pro osed AT&T antenna _ � �«�.,�tib ��.P i... ��r � � � .'� }l%i � �---�... . _.n _.� -�--�.r-�'�=— --^-`�+�F� .�^ a-�r�.,�„� _�=a'�z"�- AT&T Mobility Small Cell Wireless Telecommunications Facility Public Right-of-Way Near 1800 Hillside Drive Burlingame, CA 94010 AT&T Site ID: SFOK2 014 ��'�6",��'r.�:�� E9 �� JA�,! 1 5 2019 �� Y C�F �JRLINGAME �"C:,i:!-,'i_;��,l�;lNC� Gi\; Summary New Cingular Wireless PCS, LLC dba AT&T Mobility (AT&T) is committed to providing wireless telecommunications services and faster data rates throughout the City of Burlingame, and is doing so by installing the least intrusive technology, with the least intrusive design, and at the least intrusive locations in the area. Rather than construct several additional macro facilities throughout the neighborhoods of Burlingame, AT&T is choosing to deploy very small facilities, called "small cells," that can be attached to utility infrastructure in the public rights-of-way. A small cell is a low- powered cell site, which, when grouped with other small cells, can relieve capacity constraints by offloading network traffic carried by the nearby macro antenna sectors, thereby improving signal quality and mobile data speeds. Objective Small Cell Node SFOK2_014 will help close AT&T's significant service coverage gap in this portion of the City by the least intrusive means. The node will enable very high data speeds, and ultimately 5G services, to these nearby users and improve service throughout the sector. Placing small cells on utility infrastructure in the public rights-of-way helps meet this need with minimal visual impact. AT&T conducted a thorough and good-faith analysis of potential sites in the area for the placement of a small cell facility. Working with the City Code and guidelines set forth by the Burlingame Planning Department, we investigated several alternative sites and identified the proposed site as the best available and least intrusive means to address AT&T's service objectives. The proposed site will provide substantial improvement in service to business, residents, pedestrians, and travelers in the area that will allow them to fully experience the advantages of AT&T's high speed 4G LTE service. And with AT&T's selection by the federal First Responder Network Authority, FirstNet, as the wireless services provider to build and manage the first-ever nationwide public safety wireless network, each of its new and modified sites will enhance its capability to improve first responder communications. Methodology and Zoning Criteria The location of a wireless communications facility to provide or improve wireless services is dependent upon topography, building clutter, vegetation, zoning, utilities, access, feasibility and availability. Wireless communication is line-of-sight technology that requires wireless communications facilities to be in relatively close proximity to the wireless handsets to be served. AT&T seeks to close its significant gap in service coverage using the least intrusive means under the community values expressed in the Burlingame Municipal Code. In particular, Section 25.77.80(c) provides location preferences for siting wireless communications facilities. The proposed facilities are situated within 500 feet of residential zoning districts, which is a second- level preference. The primary preference, which consists of sites farther away from residential districts, is not feasible because AT&T needs to place its small cell facility in the right-of-way of this residential area in order to meet the service objectives. Under Section 25.77.80(c)(2)(A), AT&T investigated but found no viable non-residential uses and open space sites. AT&T did not identify an opportunity to place new light poles under Section 25.77.80(c)(2)(C) because the proposed Small Cell Node 14 is adjacent to an existing street light. Placing a new light pole would be more intrusive to neighborhood aesthetics because it would occupy space in the public-right-of-way. The proposed site will not create a footprint in the right- of-way. All proposed equipment would be pole mounted, and all cabling and equipment will be tidy and painted to match the pole. AT&T identified the existing utility pole as the next available and feasible preference under Section 25.77.80(c)(2)(D). To meet Section 25.77.80(c)(2)(D), AT&T proposes to screen the equipment and paint to match the existing structure. In addition, Section 25.77.090 provides design criteria for wireless communications facilities. Consistent with Section 25.77.090, AT&T has sited and designed the proposed small cell to minimize visual and auditory impacts and to preserve overall aesthetics of the neighborhood. Based on these parameters, AT&T investigated site locations that could meet the service objective. AT&T's analysis is set forth below. Analysis AT&T investigated potential alternative sites for Wireless Cell Facilities (WCFs) to fill the identified significant gap. As stated above, no feasible collocation opportunities were identified in the search area. The following map shows the alternative sites in the City, which are discussed below. Location of Candidate Sites c�., �{;� a�; ew , �,� �y �ry 4 e`�` � �. . � r�' r ��',..�� '4 q +1. �� "y�°b" _ . . . _..c��'r-.� ''l�t:, � . � 1�:�:.-�• �" � . + x � f�� ,� �''' �`'�''�; � �,, � � '� � �a.�t z, "�� °i�-�.�,,� C` ; " � - --`--'-- _ a '�7,. � _ " � �� i l.t��l;[I��. .� r. *�� ` � - .;, �` � 'rv� � .l� '�'. �.- � +";�� °` � �yt � `s '�" �' � � r � a � .(' :.�U�f `�l:l�io` i ��; f� � � r�`�i°(� ��n .. _ � � 1 . �� Y� f� . � ;:,-.I 6�E'S�' .'� r` � ¢ . "'"��.� .. �� . ` " tft ;� i� �r., �� ' #� � � ��, ` �/ -; �„'` � j " y., ' ' :� . � .I��d? s � J�i .� "' ��v� �� e`� �.7 � r �� ' a :� - � � �.� � ,�, �� ,�� ,�� ,� R.. , : a�,� 4 � � iw �� ..� �� y ��'•L��' . . �+ �a`.� . ., � r : ,,. i ,._..� ._ . '� . � Candidate #1 — Public right-of-way near 1720 Hillside Drive �.,� - �� . -,, �`�... �,�� w: � � `�- '� �'`�~-, � �. :,' :�; � �� .__ .. �. ;« ..�_..� , a. . --._�_ � �� ; � M 't . ;�k � �"''nr' �� ! , � - � a�� r « � -� e -�,-3 r } , . :_:� � �' � � ��"� M `�+,'Af � '�".� . �,.�'�'* * , `�w�_ _'� �e, . - ,�. � '`� � �w�e�ti 9i` ¢ � _.'4' � "-_ ,. �%r �� ' �d R i � �� 2 � �< . !I. . ,. . i �. -- �' � �.:;, _ =-�F,� _ .,nil► � } ` *?- �;s. r ,,Y�° K �:,F * i��'�� ': } .�`','� ;t� �; Y�`�� -� :"'��a�"�. � ,_„ z� �- � l�� , ,� �.�� ;, , � �' , s.. �' y"`� �� . �� ,� ^A' �.. �� " .� -;�i� �-_ � f _ � �<,� Conclusion: Not feasible. This street light utility pole is located in the public right-of-way on the corner of Cabrillo Avenue and Hillside Drive (lat/long 37.585470, -122.373850. This pole would not be viable as it does not meet CPUC G095 requirements. It has a disconnect switch, primary riser, and cut-outs that connect to primary power, all of which disqualify it for usage per PG&E standards. Candidate #2 — Primary Candidate — Public right-of-way near 1800 Hillside Drive � proposed AT&T antenna Conclusion: eest available candidate. This PG&E utility pole is located in the public right-of-way near 1800 Hillside Drive (lat/long 37.585211, -122.37405. Consistent with Section 25.77.090(c) of the Burlingame Municipal Code, AT&T has sited and designed this proposed small cell to minimize visual and auditory impacts and to preserve overall aesthetics of the neighborhood. This pole is located between two residences, and the top-mounted antenna will be sheathed in a radome painted to match the pole. Using pole-top antennas also helps the overall aesthetic by maintaining the existing pole line. The height of nearby trees will help conceal the equipment while still allowing the antennas a clear line-of-site for signals. The pole-mounted equipment will be in small enclosed boxes painted to match the pole. This site is feasible from radio frequency and construction perspectives. Use of this pole has been approved by PG&E. Candidate #3 — Public right-of-way near 1810 Hillside Drive � � `� p ,� �'` � � „�-,.:.. � ,' � � � � -y Conclusion: Not feasible. This utility pole is located in the public right-of-way in front of 1810 Hillside Drive (lat/long 37.585082, -122.374192). This site is not viable because adding a small cell here would not leave sufficient climbing and equipment space. CPUC G095 standards require two of four quadrants of a wood pole to be free for climbing and equipment space, and this pole would not meet that requirement. Therefore, the pole is not viable. Candidate #4 — Public right-of-way at the corner of Hiliside Drive and Drake Avenue F"-,., �<.�-_: _ �.�„_........_ .. -.._,..... .._ :•..:..�. _.. ,�::-.� . '.; ��.�� . . --.:��..�x' M� 5:11i., . .� r . � _ , ,. a , r� y . JG. 3y.. '�p ii' � ,:-0!Y':,:�� .. �.�t , ��A �+l ��jj��:;� ! yy M�_� _ . �4 i��, . Conclusion: Not feasible. This utility pole is located in the public right-of-way at the corner of Hillside Drive and Drake Avenue (lat/long 37.584802, -122.374445). The pole would not meet CPUC G095 requirements, as there are 3 transformers, a disconnect switch, and cutouts connecting to primary power located on the pole. w�: ; ;� `: �: il ti � i i q� nn� y,,;,,,�.,.- =--_ -<.� �' � � -.�-. - .,.,, �. .,., Conclusion: More intrusive than proposed facility. This utility pole is located in the public right-of-way near 1819 Hillside Drive (lat/long 37.584591, -122.374126). The pole is a drop pole with a lower height than other area utility poles. AT&T prefers greater height at this site to meet its service objective with the proposed small cell. The pole is also located directly in front of a residence and therefore more intrusive than the proposed facility. Candidate #5 - Public right-of-way in front of 1819 Hiliside Drive Candidate #6 — Public right-of-way near 1720 Hiliside Drive �� - - - - "� ,�`° :;� � t ,, �ta'� � � vy ^ a; �'` r �,^`�a i .�;;"`� "'�':; i�'� i= ?,,7'�;��a,�� `� ' �� ;� �•: . . . =�,.,v,e_ . �. ,/. � � x`'''��u��. �;w �F� ��., Conclusion: Not feasible. � , :. . �� \ � ! S .. . . . 1 This utility pole is located in the public right-of-way near 1720 Hillside Drive (lat/long 37.585735, -122.373594). This pole would not be CPUC G095 compliant as it has cutouts that connect to primary power and does not have sufficient space for climbing and equipment quadrants. This site is not viable because adding a small cell here would not leave sufficient climbing and equipment space. CPUC G095 standards require two of four quadrants of a wood pole to be free for climbing and equipment space, and this pole would not meet that requirement. Conclusion: More intrusive than proposed facility. � This utility pole is located in an easement behind 1804 Hillside Drive at lat/long (37.585260, - 122.374516). Although this pole is located between six separate residences, AT&T analyzed this site per the City Planning Commission's request. In addition to being located on private residential property, this utility pole closer to a residence than the proposed site. This pole would not be shielded by any vegetation. Pole #7 would be more intrusive than the proposed facility. Candidate #7 — Private property behind 1804 Hillside Drive Candidate #8 — Our Lady of Angels Parish and School, 1721 Hillside Drive _ , .., -y� > �� ,�; - < ;_,,, � t� �'� _.>.�: � `fqh r' � � w -" r . � ti� � ��. C,y ` li , °� ';1 � � � � ✓ t � v:,�, �"�' �. v� � .. _ '� � } �' }t'� !` _ R "L��h�`( - [. < <`�� , � ~ �yr `'�$., , : � ` { `� �.f� l� .�:r f T•M �*y r �'� �}� . �"ys" � t� 'p',ax t�7 . _ '�,��.. F A� , .:, .: - � .., ' f.i�� '.� �, `f.r�j, : .. . ' '. �.§ � A�� '� ....�c� .� r.-;� . '1`":'+ ip',e�."�� .,t,. h ' l �2 �, 1 <q� .�,i �. � .,., y�, - i� y.�S 1 .. � �k 'i � �� 4 .: t + � __ ` { i' '. '., . 1 � : '- . ... L MYF!'d. A �. . _ � _ � ' � R �� N �'� . . � � � .N " :�: �.� ' � � �.. � � � �� ^ � � ::::,� � ��... ; -(i�� wH , � . �""' • �'�, f §� `� �. .. �,� .u' ��' �,�" �": �`.' � �.�, ,� -:j .,; .;�w� .�.-- . , • �- �:. . � ' ` . ; :. :�,� ,w,..�.. _ >..:.�.,�-- �. � � . �, '� - �„'"i..h��+x -'_. �'�k��`"_�"" ... � �� ' , �' �': .._._ =,� • �� "_ . �� -- — -.. � � . ��.'war�'.s�° -�.'?�� .� r �`_.._ � Conclusion: Not feasible. Our Lady of Angels of Angels Parish and School is a private kindergarten through 8t`' grade school approximately 200 feet northeast of the proposed subject site. Although not typical for a small cell facility, AT&T analyzed this site per the City Planning Commissions's request. AT&T reached out to Our Lady of Angels to determine interest in leasing space for a wireless communications facility (WCF). Our Lady of Angels showed interest in leasing space, but only if no changes were made to the appearance of the existing building. To conceal the antenna, the site would need to be located in the church steeple, which consists of thick concrete and metal gratings for ventilation. For the WCF to function effectively, a portion of the steeple would have to be replaced with fiberglass reinforced plastic (FRP) to allow the signal to penetrate the walls. AT&T led a site walk at Our Lady of Angels on 11/19 to determine the steeple viability for the macro site. AT&T Radio Frequency engineer, Phil Dale, determined that the church steeple could fit two small cells but not a macro antenna site. AT&T proposed a lease package to Our Lady of Angels on 12/13 consistent with small cell antenna pricing. Our Lady of Angels subsequently denied the lease offer on 12/14. Therefore, this alternative is not viable. Candidate #9 — Intersection of Hillside Drive and Cabrillo Avenue ,,� , � � _ _ �?��,...."`��\ � r;y.._ .�,. � I��f i��z..,. �- . �a"` ��'�.� � w_..�_+:.�at..`., � '-��`^P� �' . ars.+�� r. _. a4 i-`-`---,N�-, :...r.„ . .. _- �� .� x� b �, � �;r,. ''� � �� "" � _ � '; �i �s="""`.«,_-.: .�;��1., �.� .. H^4:._ � . �::.. , "s' ` - -.;c., � ,'�`�.��3� � r .. �L�I y �t e--). -�� `�... " ._:pd'�-�- b S r��'��vey,��.. . Conclusion: Not feasible. Candidate #9 includes the traffic signals located at the intersection of Hillside Drive and Cabrillo Avenue. The traffic signals at the east and west corners of the intersection are not viable because RF prefers a higher RAD center, the pole would not be able to support the equipment structurally, and there would not be adequate space on the poles to mount the equipment. Attaching to traffic signal poles could also overburden the poles. Therefore, the traffic signals are not feasible. �.., _. � � ;,,�;��-sr ,.._"_` ��; _ - - ._ .. _,'_'� , , >r:�. Conclusion: Not feasible This utility pole is located in the public right-of-way near 1920 Hillside Drive (lat/long 37.584390, -122.374796). This pole would not be CPUC G095 compliant as it has cutouts that connect to primary power. CPUC G095 standards prohibits the attachment of small cells to utility poles with cutouts connecting to primary power. Candidate #10 — Public right-of-way near 1920 Hiliside Drive Conclusion The proposed facility, Candidate #2, is the best available and least intrusive means by which AT&T can close its significant service coverage gap in this portion of the city. Denial of the proposed facility would materially inhibit AT&T's ability to provide and improve wireless services in Burlingame. Title 25 — Zoning Code — Chapter 25.77 — Wireless Communications Facilities Code Sections 25.77.080 (c) and 25.77.090 Code Section 25.77.080 (c) — Location Preference Order (c) Location Preference Order. In determining the location of proposed wireless communication facilities, applicants should use best efforts to comply with the location preference order outlined herein. If applicable, the applicant shall include an explanation of the reason that the proposed facilities cannot be deployed at a higher-preference location. Wireless communication facilities must be located where feasible in the following locations by descending priority: (1) Locations within Non-Residential Zoning Districts, which are more than five hundred (500) feet from Residential Zoning Districts or the Burlingame Downtown Districts and which are not within the Burlingame Downtown Districts: (A) Completely enclosed within existing, permitted buildings. (B) Located on electric power transmission towers. (C) Co-located on existing wireless communications facilities. (D) The roof of existing structures (buildings, water tanks, etc), designed to blend in with the building, camouflaged or screened from the public right- of-way which constitutes a pedestrian travel corridor. (E) The side of existing structures (buildings, water tanks, etc.), designed to blend in with the building, camouflaged or screened from the public right- of-way which constitutes a pedestrian travel corridor. (F) Camouflaged stealth structure (a false tree, building, artifice, etc). (G) Existing utility poles, with all ancillary equipment placed underground if feasible, camouflaged or screened. (H) Existing utility distribution poles and street lights. (I) Slim line monopole, with antennas in a canister at the same diameter as the pole. (J) Standard monopole with attached flush-mounted (not extending more than twenty-four (24) inches from the pole) antenna elements. (2) Non-Residential Zoning Districts within five hundred (500) feet of Residential Zoning Districts or the Burlingame Downtown Districts, and the Burlingame Downtown Districts. (A) Integrated into non-residential uses (libraries, churches, temples, etc.) designed to blend in with open space (playing fields, parking lots, parks, etc.); hidden from pedestrian view by means of stealth design, stealth structures, architectural integration or screening. (B) Co-located on existing wireless communications facilities which are in compliance with the provision of this chapter. (C) In public right-of-way, within new light poles with interior stealth installations of cabling and antenna, and to the extent feasible, control equipment. (D) In public right-of-way, on existing utility or light poles, with all ancillary equipment either underground, if feasible, camouflaged, screened or painted to blend into the surrounding structure. (3) Residential Zoning Districts. (A) Integrated into non-residential uses (libraries, churches, temples, etc.) or designed to blend in with open space (playing fields, parking lots, parks, etc.); hidden from view by means of stealth design, stealth structures, architectural integration or screening. (B) Co-located in existing wireless communications facilities which are in compliance with the provisions of this chapter. (C) In public right-of-way, within new light poles with interior stealth installations of cabling and antennae, and to the extent feasible, control equipment. (D) In public right-of-way, on existing utility or light poles, with all ancillary equipment either underground, if feasible, camouflaged, screened or painted to blend into the surrounding structure. (Ord. 1870 § 2, (2012); Ord. 1869 § 3, (2012)) Code Section 25.77.090 — Design Criteria for Wireless Communications Facilities The goal of these regulations is to reduce to the greatest extent possible all visual impacts resulting from the installation of wireless communications facilities. Stealth design and stealth structures for these facilities shall be considered the normal standard for all wireless communications facilities. Non-stealth designs and structures shall not be approved without evidence, independently verified, that it is not possible (using best efforts by applicant) to stealth such facilities. Applications shall be reviewed to determine compliance with the following criteria. If the applicant's proposed facility cannot comply with the following criteria, the application shall include a detailed explanation of why it is not reasonably feasible to comply with the criteria. (a) Wireless communication facilities should be co-located where feasible and where the co- location does not create an adverse aesthetic impact due to such factors as increasing the bulk, the height or the amount of noise created by the proposed co-located facilities. (b) Wireless communication facilities should to the greatest extent feasible, not be located in Residential Zoning Districts. (c) Wireless communication facilities should be designed, located and constructed in a manner that minimizes visual and auditory impacts of the facilities. The wireless communication facilities shall blend into the surrounding environment and/or shall be architecturally integrated into a structure, considering the color, design and character of the surrounding context (e.g., public art, clock towers, flagpoles, trees/vegetation, rocks, water tank, existing office/industrial buildings, and church steeples). Specifically, the proposed facilities shall comply, to the greatest extent feasible, with the following: (1) The facilities should be concealed, screened or camouflaged by the surrounding topography, vegetation, buildings, or other setting. (2) The facilities should be proportional in size relative to surrounding and supporting structures and ability for co-location by other providers. (3) Roof-mounted facilities should be, out of view and screened; these facilities shall be set back at least one foot from the edge of the roof for every one foot of antenna height and shall not exceed ten (10) feet in height above the roof surface. (4) Wall-mounted facilities should be compatible in scale and design with the building, shall be flush mounted, i.e., not extending from the face of the building more than twenty-four (24) inches and shall be painted and/or textured to match the wall of the building. All cables and brackets, wires, shall also be hidden. (5) All facilities should be constructed of graffiti-resistant materials. (6) All concealing, screening, painting, camouflaging and/or use of stealth designs and stealth structures should be consistent with Section 25.77.010 (Purpose) including, but not limited to, promoting wholesome, attractive, harmonious and economic use of property, building construction, civic service, activities and operations in conformity with and preserving the overall aesthetics of City neighborhoods including its character and its century old architectural traditions. (d) Where applicable, appropriate landscaping should be installed in and around the proposed wireless communication facilities. (e) Any exterior lighting on the facilities should have a manual on/off switch and be contained on-site. (f) Ground equipment of the facilities should be concealed, screened, camouflaged or hidden using stealth design, stealth structures, underground installation or landscaping and fencing. (g) Signage in, on or near any facilities should be prohibited with the exception of warning and informational signs, which shall be designed with minimal aesthetic impact. (h) Wireless communication facilities should be discouraged in areas subject to the City's hillside construction permit as designated in Section 25.61.010; if facilities cannot be avoided in the hillside areas, then visual impacts should be eliminated through stealth design, stealth structures and landscaping. (i) Support wires for structures should be discouraged. Q) The wireless communication facilities should be designed to discourage unauthorized access. (Ord. 1870 § 2, (2012); Ord. 1869 § 3, (2012)) � �� JOHN DI BENE AT&T Services, Inc. General Attorney 2600 Camino Ramon � Legal Department Room 2W901 San Ramon, CA 94583 August 22, 2018 925.543.1548 Phone 925.867.3869 Fax jdb@att.com ,� � .k :. �s,,,:., Via E-mail �`' C�y�� i� City of Burlingame City Council �� 4'� �� "`�' City Hall ;UG � � 2018 501 Primrose Road Burlingame, CA 94010 "�YY G'r �U�LINGAME �lll CDQ-P!_,L�.�,INING DIV. Re. AT&T Applications for Small Cell Nodes 14 and 19 Appeal from Planning Commission Dear Mayor Brownrigg, Vice Mayor Colson, and Councilmembers Beach, Keighran, and Ortiz: I write on behalf of New Cingular Wireless PCS, LLC d/b/a AT&T Mobility ("AT&T"), regarding AT&T's appeal of the Planning Commission's decision to deny two applications to place small cell wireless facilities. Each application seeks to install a low-profile, low-power small cell wireless telecommunication facility on an existing utility pole in the public right-of- way in the City. AT&T's small cell design is intended to maximize facility concealment while providing vital wireless services to City residents, and these applications meet all of the requirements of the City's wireless ordinance. Given the importance of wireless services and AT&T's streamlined aesthetic design, we respectfully request the City Council reverse the decision of the Planning Commission and either approve AT&T's applications to install these small cells, or remand the matter to the Planning Commission with direction to take all necessary action to issue the appropriate siting permits. AT&T's Proposed Small Cell Facilities The proposed small cells are needed to address wireless service issues in the City. Unlike traditional macro facilities, these small facilities that present a win-win solution for the City and AT&T. They significantly improve service quality for the City's residents and commercial operations in a streamlined installation that can be installed with minimal impact to the City. AT&T's proposed small cell equipment consists of a set of small, enclosed boxes matching the diameter of the pole and painted to match the pole. AT&T's equipment does not stand out; in fact, they look like small utility boxes on a typical utility pole. AT&T also worked with PG&E to allow a smaller meter on the pole. Using pole-top antennas also helps the overall aesthetic by maintaining the e�sting pole line. Burlingame City Council August 22, 2018 Page 2 of 9 AT&T has taken care to select locations to reduce visibility. For example, as you can see in the photosimulations for Small Cell Node 14 (E�ibit A), this facility will be placed on a utility pole with adjacent trees that will help reduce visibility of the facility. The height of nearby trees will help conceal the equipment while still allowing the antennas a clear line-of-site for signals. For Small Cell Node 19, AT&T is planning to improve the overall aesthetic of the existing pole by removing the existing stub pole that is situated immediately adjacent to the utility pole. The photosimulations for Node 19 (E�ibit B) show that the project will transform the site to a more streamlined appearance as compared to existing conditions.l In compliance with the aesthetic requirements of the Burlingame Municipal Code, as explained in greater detail below, AT&T proposes to screen and camouflage the equipment by painting the equipment to match the existing structure and by selecting locations near natural screening of trees. AT&T has designed the proposed small cell to minimize impacts and to preserve overall aesthetics of the neighborhood. Need for Small Cells Small cells give residents and businesses access to the latest and greatest wireless technologies without cluttering the public rights-of-way. Small cells are critical to meet ever- increasing demand for wireless services. Small cells are needed in residential areas, where they can be installed in the public rights-of-way, so that customers are presented with a dominant signal that results in less noise interference and provides faster throughput. This is especially important in today's world where so many people rely on wireless services to do more in their homes. The Center for Disease Control and Prevention tracks the rates at which American households are shifting from landlines to wireless telecommunications. According to the CDC's latest Wireless Substitution Report, more than 70 percent of Americans rely exclusively or primarily on wireless communications in their homes.2 In addition, the FCC estimates that 70 percent of a11911 calls are made from wireless devices.3 And with AT&T's selection by FirstNet as the wireless service provider to build and manage the nationwide first responder wireless network, each new or modified facility will help strengthen first responder communications. AT&T's existing macro facilities that serve the area are under duress due to high and increasing mobile data traffic on AT&T's network. The resulting capacity restraints reduce mobile data speeds to the point where AT&T cannot meet its service objectives in the area. By placing small cells in these high-traffic and poor signal quality areas, they will capture a significant amount of traffic now served by the overloaded macro sectors. Once on air, the � Perhaps because of their experience with other providers who have proposed much more bulky facilities, the Planning Commission was skeptical that AT&T's proposed small cells would be as sleek as they are. One Planning Commissioner suggested that AT&T update its photosimulations to zoom in to the pole-mounted equipment to illustrate its appearance. Exhibits A and B provide those zoomed-in views. � See Wireless Sz�bstita�tion: Early Release of Estimates From the National Health Interview Survey, July-December 2017, available at http://www.cdc.gov/nchs/data/nhis/earlvrelease/wireless201806.pdf. 3 See 911 Wireless Services, available at https://www.fcc.gov/consumers/guides/911-wireless-services. Burlingame City Council August 22, 2018 Page 3 of 9 proposed small cells will help offload network traffic from those macro sectors, which will improve signal quality and data speeds, allowing customers served by that sector to reliably stream video. (See Exhibits C and D.) AT&T's Search forAlternative Sites In order to be certain that AT&T is proposing the best available and least intrusive means to address its significant service coverage gap in these portions of the City, AT&T evaluated many different locations in each area. AT&T's alternative sites analyses for these two small cells are attached as Exhibits E and F. AT&T selected the proposed locations based on their availability — that is, AT&T's ability to gain attachment rights — and feasibility in terms of both constructability and viability from a radio frequency perspective. AT&T also considered the location preferences and design standards articulated in the Burlingame Municipal Code in order to be sure to identify the least intrusive means. In particular, Section 25.77.80(c) provides location preferences for siting wireless communications facilities. The proposed facilities are situated within 500 feet of residential zoning districts, which is a second-level preference. The primary preference in the Code, which consists of sites farther away from residential districts, is not feasible because AT&T needs to place its small cell facilities in these residential rights-of-way in order to meet its service needs. Further, AT&T investigated but found no viable non-residential uses or open space sites. AT&T investigated but found no collocation opportunities in the area. AT&T also did not identify any opportunities to place new light poles because the proposed small cells are near existing light poles. Small Cell Node 14 is adj acent to an existing street light, and Small Cell Node 19 is attached to a light pole. AT&T identified the existing utility poles as the next available and feasible preference under Section 25.77.80(c)(2)(D). During the Planning Commission hearing, the Commissioners asked AT&T to go back and consider certain specific altematives and also to make sure it had investigated available altematives. In response, AT&T redoubled its site selection efforts. Specifically, at the Planning Commission's suggestion, AT&T reached out to Our Lady of Angels as an alternative to Small Cell Node 14. This church and school would only authorize placement of a wireless telecommunications facility if it would not affect the architectural character of its structure. As AT&T would need to replace a portion of the church steeple with materials of significantly different type and texture, this did not present a viable alternative. AT&T also analyzed whether it could place equipment behind a traffic sign based on a question from Planning Commission. This will not be possible. And AT&T again scoured the areas for the small cells to look for any additional candidates. Having canvassed potential alternatives, including those suggested by the City, and given the positive aesthetics of these specific small cell applications, AT&T has confirmed that proposed Small Cell Node 14 and Small Cell Node 19 are the least intrusive means to address AT&T's service needs. (See Exhibits E and F.) Burlingame City Council August 22, 2018 Page 4 of 9 AT&T's Proposals Comply with All Requirements of the City's Municipal Code Chapter 25.77 of the Burlingame Municipal Code regulates wireless facility siting. Although a part of the City's Zoning Code, Section 25.77.030 makes clear that this wireless ordinance also applies to sites in the public rights-of-way. Under Code Section 25.77.010, the overall purpose of the wireless ordinance is "to facilitate modernization of Burlingame's communications infrastructure in a manner that improves the quality of the City's environment, the pleasant aesthetics of the City's neighborhoods, the City's architectural traditions dating to the early 20th century and the visual quality in the non-residential areas of the City." AT&T's small cell facilities will enhance vital wireless communications services while preserving neighborhood aesthetics. Indeed, AT&T's applications fully comply with the City's wireless ordinance. Under the wireless ordinance the City encourages (but does not require) pre-submittal conferences to discuss requirements of the wireless ordinance.4 On July 13, 2017, AT&T's representatives attended a pre-submittal meeting with Public Works staff since Planning staff was not available at the time. Later, AT&T's representatives sat and met with the Planner when the applications were submitted on September 28, 2017. To obtain approval for an application to site a wireless communications facility, a provider must submit the required application materials under Code Section 25.77.060, submit the application fee under Code Section 25.77.070, meet the general requirements under Code Section 25.77.080, and meet the design criteria under Code Section 25.77.090. These applications meet all of these requirements. Pursuant to Code Section 25.77.060, AT&T submitted all required application materials for each small cell, including the City of Burlingame Conditional Use Permit Application form,s a clear written description of the proposed facility,b site plans with relevant photos,� a map of AT&T's existing and proposed sites,8 an explanation of the site selection process,9 photo- simulations of the proposed small cells,10 and additional information requested by the City through the application process and by the Planning Commission at its hearing. Pursuant to Code Section 25.77.070, AT&T submitted the applicable application fees for these small cells. Pursuant to the "general requirements" of Code Section 25.77.080, AT&T's applications show that its small cells will meet or exceed current applicable state and federal standards and 4 See Code Section 25.77.055. 5 See Code Section 25.77.060(a)(1). 6 See Code Section 25.77.060(a)(3). � See Code Section 25.77.060(a)(4). g See Code Section 25.77.060(a)(5). � See Code Section 25.77.060(a)(6). 10 See Code Section 25.77.060(a)(7). Burlingame City Council August 22, 2018 Page 5 of 9 regulations, �� will comply with applicable building codes and safety standards,12 and meet the City's location preferences for wireless facility siting.13 Specifically, the proposed small cells are situated within 500 feet of residential zoning districts, which is a second-level preference. The primary preference in the Code, which consists of sites farther away from residential districts, is not feasible because AT&T needs to place its small cell facilities in these residential rights-of- way in order to meet its service needs. Further, AT&T investigated but found no viable non- residential uses or open space sites.14 AT&T investigated but found no collocation opportunities in the area.15 AT&T did not identify any opportunities to place new light poles because the proposed small cells are near existing light poles.lb Small Cell Node 14 is adjacent to an existing street light, and Small Cell Node 19 is attached to a light pole. AT&T identified the existing utility poles as the next available and feasible preference under the Code.�� Pursuant to Code Section 25.77.090, AT&T's small cells will meet the City's design criteria for wireless communications facilities. The City's design criteria encourage stealth designs and this section provides that "[t]he goal of these regulations is to reduce to the greatest extent possible all visual impacts resulting from the installation of wireless communications facilities." Again, AT&T's small cells are stealth designs.lg These small cells will have screened antennas in a pole-top radome, painted to match the pole. The equipment will be housed in small, enclosed boxes matching the diameter of the pole and painted to match the pole. AT&T's equipment does not stand out; in fact, they look like small utility boxes on a typical utility pole.19 Using pole-top antennas also helps the overall aesthetic by maintaining the existing pole line. Nearby trees also help to screen the equipment of these small cells. Further with respect to the City's design criteria, AT&T's small cells are "designed, located and constructed in a manner that minimizes visual and auditory impacts" and will "blend into the surrounding environment."20 The small cells will not include exterior lighting,21 ground equipment,22 signage,z3 or support wires.24 In addition, all conditional use permits must meet two specific findings under Code Section 25.52.020. Code Section 25.52.020(a) requires finding that granting the conditional use permit "will not be detrimental or injurious to property or improvements in the vicinity and will not be detrimental to the public health, safety, general welfare or convenience." And Code � � See Code Section 25.77.080(a). �' See Code Section 25.77.080(b). 13 See Code Section 25.77.080(c). �`' See Code Section 25.77.080(c)(2)(A). 15 See Code Section 25.77.080(c)(2)(B). 16 See Code Section 25.77.080(c)(2)(C). �� See Code Section 25.77.080(c)(2)(D). 18 See Code Section 25.77.090(c)(1). 19 See Code Section 25.77.090(c)(2). '0 See Code Section 25.77.090(c). ''� See Code Section 25.77.090(e). "' See Code Section 25.77.090(fl. '`3 See Code Section 25.77.090(g). '4 See Code Section 25.77.090(i). Burlingame City Council August 22, 2018 Page 6 of 9 Section 25.52.020(b) requires finding that "the proposed use will be located and conducted in a manner in accord with the Burlingame general plan and the purposes of this title."ZS The City Council can easily make both of these specific findings. AT&T's small cells will not result in any detriment or injury to properties or the public health, safety, welfare or convenience. Indeed, AT&T's small cells will "facilitate modernization of Burlingame's communications infrastruciure in a manner that improves the quality of the City's environment," which is a primary purpose of the City's wireless ordinance as stated in Code Section 25.77.010. In addition, AT&T's small cells will not adversely affect aesthetics. These small cells are of "stealth design" within the meaning of Code Section 25.77.020 because the antennas and equipment will be screened and sited in a way that "reduces to insignificant the visual impact." Because AT&T has met all of the City's application requirements for placement of wireless communications facilities as well as for approval of conditional use permits, and since these small cells help to fulfill a primary purpose of the wireless ordinance, the City should approve AT&T's applications for Small Cell Node SFOK2_014 and Small Cell Node SFOK2_019. AT&T's Proposals Are Consistent with State Law AT&T has a statewide franchise right to access and construct telecommunications facilities in the public rights-of-way. And AT&T's small cell applications seek to place these facilities consistent with state policy and law. Consistent with the California Constitution, the placement of telecommunications infrastructure in public rights-of-way is a matter of statewide concern.26 Under California Public Utilities Code Section 7901, AT&T has the right to access and construct facilities in public rights-of-way in order to furnish wireless telecommunications services, so long as it does not "incommode" the public use of the public right-of-way. And under Section 7901.1, AT&T's right is subject only to the City's reasonable and equivalent time, place, and manner regulations as to how AT&T constructs in the public rights-of-way. These two proposed small cells will not incommode the rights-of-way. In addition, AT&T's applications propose to place facilities in accordance with the City Code and with careful consideration given to the City's location preferences and design criteria. AT&T's small cells are designed to minimize visual impact and are carefully sited to fit within their surroundings. These will be amenities to the community, improving critical wireless services in the City. `'S Section 25.52.020(c) of the Burlingame Municipal Code also authorizes the Planning Commission to impose additional reasonable conditions or restrictions. `'6 See, e.g., Pac. Tel & Tel. Co. v Ciry & Coa�nty of San Francisco, 51 Cal. 2d 766, 768 (1959) ("the construction and maintenance of telephone lines in the streets and other public places within the city is today a matter of state concern and not a municipal affair"); see also, Cal. Const., Art. XII, § 8("[a] city, county, or other public body may not regulate matters over which the Legislature grants regulatory power to the [Public Utilities] Commission"). Burlingame City Council August 22, 2018 Page 7 of 9 Approval of AT&T's Proposals is Required Under Federal Law The federal Telecommunications Act of 1996, 47 U.S.C. § 332 ("Act") provides rights to wireless service providers and establishes limitations upon state and local zoning authorities with respect to applications for permits to construct personal wireless service facilities. The United States Supreme Court has explained that the Act was enacted in part to prioritize and streamline deployment of wireless technologies on a national basis.Z� The Act defines the scope and parameters of the City's overall review of AT&T's Application. Under the Act, the City must act within a"reasonable period of time."28'29 And its review must consider the applications based on substantial evidence.30 The Act prohibits a local government from denying an application for a wireless telecommunications facility where doing so would "prohibit or have the effect of prohibiting the provision of personal wireless services."31 Courts have found an "effective prohibition" exists where a wireless carrier demonstrates (1) a sigmificant gap in wireless service coverage, and (2) that the proposed facility would provide the "least intrusive means," in relation to the land use values embodied in local regulations, to provide the service coverage necessary to fill that gap.32 If a wireless carrier satisfies both of these requirements, state and local standards that would otherwise be sufficient to permit denial of the facility are preempted and the municipality must approve the wireless facility.33 When a wireless provider presents evidence of a significant gap and the absence of a less intrusive alternative, the burden shifts to the local government to prove that a less intrusive alternative e�sts. In order to meet this burden (and overcome the presumption in favor of federal preemption), the local government must show that another alternative is available that fills the significant gap in coverage, that it is technologically feasible, and that it is "less intrusive" than the proposed facility.34 A key benefit of this "least intrusive means" standard is that it incentivizes prompt results. The municipality has an incentive not to merely deny proposals as they are presented '� City ofRancho Palos Verdes v. Abrams, 544 U.S. 113, 115-16 (2005) ("Congress enacted the Telecommunications Act of 1996 (TCA), 110 Stat. 56, to promote competition and higher quality in American telecommunications services and to `encourage the rapid deployment of new telecommunications technologies.' Ibid. One of the means by which it sought to accomplish these goals was reduction of the impediments imposed by local govemments upon the installation of facilities for wireless communications, such as antenna towers.") 'g See 47 U.S.C. § 332(c)(7)(B)(ii) (City must act on applications "within a reasonable period of time"); Petition for Declaratory Ruling to Clarify Provisions of Section 332(c)(7)(B), WT Docket No. 08-165, Petition for Declaratory Ruling to Clarify Provisions of Section 332(c)(7)(B), WT Docket No. 08-165, Declaratory Ruling, 24 FCC Rcd. 13994 (2009) (establishes a legal presumption that "reasonable period of time" means 90 days to act on an application to collocate a wireless facility or 150 days to act on other requests to construct wireless telecommunications facilities); California Govt. Code § 65964.1(a) (providing state law deemed grant remedy where City fails to act within presumptive FCC review timeframes). '9 The City's review of AT&T's applications already has taken more than eleven months, far longer than permitted under state and federal law to consider such applications. 30 47 U.S.C. § 332(c)(7)(B)(iii) 31 47 U.S.C. �332(c)(7)(B)(i)(II). 3' See e.g., Metro PCS, Inc. v. Ciry and County of San Francisco, 400 F3d 715, 734-35 (9th Cir. 2005), abrogated on other grounds, T-Mobile South, LLC v. City of Roswell, 135 S.Ct. 808 (2015); Sprint PCS Assets, LLC v. City of Palos Verdes Estates, 583 F3d 716, 726 (9th Cir. 2009). 33 See T-Mobile USA, Inc. v. Ciry ofAnacortes, 572 F.3d 987, 999 (9th Cir. 2009). 3a Id., 572 F.3d at 998-999. Burlingame City Council August 22, 2018 Page 8 of 9 because that could result in a more intrusive solution or violation of federal law; the provider has incentive to find the best solution for the community in the first instance. In MetroPCS, the Ninth Circuit observed that this least intrusive standard "allows for a meaningful comparison of alternative sites before the siting application process is needlessly repeated" and "promises to ultimately identify the best solution for the community, not merely the last one remaining after a series of application denials."35 Thus, where the wireless provider analyzes multiple options, it is incumbent upon the local government to identify and approve the least intrusive alternative in the context of pending applications. Here, AT&T has demonstrated its significant service coverage gap (see Exhibits C and D). As AT&T's Radio Frequency Statement explains, the volume of mobile traffic on AT&T's network in this area constrains the capacity of nearby macro telecommunications facilities. The result is poor data rates, meaning customers are experiencing poor signal quality in large portions of the City in the vicinity of the proposed small cells. Specifically, this gap area is significant because it encompasses many hundreds of homes in residential neighborhoods, several schools, numerous commercial buildings, a fire station, a library, health care facilities, parks and a retreat center. According to the most recent traffic data estimate available from the California Department of Transportation, approximately 21,000 vehicles travel along El Camino Real every day in this portion of the City. By placing the proposed small cells in locations where specific and measurable signal quality issues are occurring, AT&T can offload traffic from congested macros in order to alleviate these capacity triggers and ensure adequate signal quality in the larger area served by the affected macros. AT&T has worked hard to identify the right solution to its service needs (see Exhibits E and F). Taking into consideration the City's preferences, AT&T conducted a meaningful comparison of alternatives for each small cell location and identified what it determined to be the best available and least intrusive means for each. Specifically, AT&T has analyzed ten sites for Small Cell 14 and ten sites for Small Cell 19. For Small Cell 14, AT&T concluded that the other nine candidate sites were not feasible because they failed to meet state regulatory standards (CPUC G095), were unavailable or were more intrusive than the proposed small cell. And for Small Cell 19, AT&T concluded that the other nine candidate sites were not feasible because they failed to meet G095 standards, not feasible because radio signals would be blocked by dense foliage, were unavailable or were more intrusive than the proposed small cell. Thus, AT&T identified the least intrusive potential and feasible site for each small cell. AT&T would be willing, within the context of the applicable federal case law, to evaluate a less intrusive location, one for each site, but such an alternative must be both available and feasible.36 To date no such alternative has been proposed. If the City wants to proffer an available and feasible alternative, however, it has to issue the permit for any such alternative site in the context of the pending application, and AT&T would need to confum the feasibility and availability of any such location. If any such alternative site is detennined to be available and feasible, the Council should direct the Planning Commission and staff to take all necessary steps to lawfully issue the permit for 3s Metro PCS, Inc., 400 F3d at 734-35. 36 Id.; T-Mobile USA, Inc. v. Ciry ofAnacortes, 572 F.3d at 999. Burlingame City Council August 22, 2018 Page 9 of 9 such location(s). If no such alternative is identified, the City Council should reverse the decision of the Planning Commission and either approve AT&T's applications to install these small cells, or remand the matter to the Planning Commission with direction to take all necessary action to issue the appropriate siting permits. Conclusion AT&T must improve its wireless service and signal quality in the areas surrounding the proposed small cells. For Small Cell Node 14 and Small Cell Node 19, AT&T has worked diligently to identify the most appropriate locations and to develop the best design possible for the City. Approval is required by the City's wireless ordinance and required by state and federal law. I respectfully request the City Council to grant AT&T's appeal, reverse the Planning Commission's denial, and approve these small cell applications. Very truly yours, /s/John di Bene John di Bene Exhibit A: Photosimulations of AT&T's Small Cell Node 14 Exhibit B: Photosimulations of AT&T's Small Cell Node 19 Exhibit C: Radio Frequency Statement for Small Cell Node 14 Exhibit D: Radio Frequency Statement for Small Cell Node 19 Exhibit E: Alternative Sites Analysis for Small Cell Code 14 Exhibit F: Alternative Sites Analysis for Small Cell Node 19 cc: Kathleen A. Kane, Esq., City Attorney Exhibit A F..; � m ;},' .. . 7.:.....,. i. � T � � ° ... ...r . `I _ -�-_�... d / ' " � // ,_. _ . -- i '%�,,,� _ " � -.� ; , .. : . . .. . .��ra....�.� ��• ,'�X...:.!.�-^p't�•'-�� . .. �. � !a ,�„`_ , _ _ —� Photo simulation as seen looking southwest from Hillside Dr & Cabrillo Ave _.. _. .., , ...r.� ' .� u at&t CRAN_RSFR_SFOK2_014 �� Across from 1800 Hillside Dr, Burlingame, CA .:-- iTR.i. . � G./ '. � .,�'��J '�.;�'II :R .,. �-"" >�, '�L� , � �- �' x �� . ( { � `' 6 � �� '�`N �� 9,; 1 ,6 . �, y,� :� � � ��,/�A . •� r �r �! 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': _ :a. � va"> .�x �i ...:w f � - . _. .__ —. , `� . . - _ �.� _ ,f_ _, �d} �P =� ', � ;;� �.�,� . i �' ,R., . . . ,� :_. - MrtP � �� `,g :�f `- .A �Yi, Photo simulation as seen looking natheast along Oak Grove Avenue i � � Exhibit C �-��;��`�� 1;�JG 2.2 2018 A`�&'I' M.obility Radin Frequency Staternent ,.;� ;-y �� ;,��LlNGAME� f�urli►xg�me, CA Smutl C:eli Node lq �;,_,�_;-;=�'.A�;"�iNING f�IV i'his smell cefl nacie is necess�ry ta ficlp elnse a significanl scrvice cave��agc 6ap in A7'&T wireless netwotic. Specific�lty, en antonna sCccor �n a i7e�srby macro site is experiencing, o� is forecastod to experi�nce, cflpacity restraint� thar reduce rnobile da�a speeds ta tl�e extent that fewer users Served by thAt ae�tur wili be xbla tia reliahly strBarn vide��. Competicion snd customer dernand require that AT&T �lesi�n anci mainiAin its network sa tltnt. uso��s experienoe averxge da�a service suf'fici�nt to reliably stream videa. A»y �reas dlat do n�t meet this minim�F viden streamin� standard represent a service c�verage gap dia� rnusl be clo5ed. The nearby rnacrn ancenna sectur's capacity restraints ere cause by tl3� extraordin�ty increase in mobile cl�ta usagc. 5inc:c Intraduceicm of the iPhnno in 2007, mobilc dat� usaga increosed Z50,000°io on AT&T's network, and AT&T forecasts its custornors' growing demand fnr moUil� data services tn continue. Updating its mohile network to hF�ndl� this surge is critica� as customers incraasingly use their mohile phones as tbeir prirnary carnmunicatian devices (more than 70°l0 of AmoricAn housci�olds raly exclusively or prirnarU�� on wiroless phones) and rely on thcir mnhile phones tu do more (C91 I, video streainin�, GPS, W8i7 AGG055, T4Xt, atcJ, In fact, the I'CC' estimates thsc 70'Yo of 911 calls arc placcd by pcopl� usittg wireless phone�. And with AT&T's selectir,n by tt�e fcderal First Respander Network Authc�rity, FirstNet, z�s ihe wireless service pr�vid�r io build und rnanage tt�� netionwide first responder wir�less network, eech new c�rmndified facility will enhance its capubilit� l� strangthen �rst r�sponder communicHtions. lJsers in poor sfgnal yuAlity �reas use H disprc�pnniunate share oT resources froni ti►e cellutur n�cw«rk. By ptaaing tbe �rupused node in a{�oar signal quality uren where tlicre Is � hi�h density of user tr;�1'f ic, the macro site servirtg the nrea wil l t�e oftic�aded And �vill pmvide beCter service tn other are�s that it eovers. A side henefit is tha! the node wiH enable hi�h dai� speeds, and ultimataly SG services, w thase nesrby users. T� prc�vide the n�cessary capxcily i�:iief'a��cl clnse this service caverage bap, AT&7` plarts to place smr�ll cell nodes in p�or si�nal quetity nreas in high usege ar�as s�rved by the tar�eCed macro antenna sector. Cacl� smafl cell nade wiU w�rk with thc ather small cell nodes in the area ca nFtload netwcark trsi�je carried by the nes�rhy maeto n»tenn� seotor��d imprnve mobile clata service through�ut the effective serviCe urea. A7'&"I' 1�4es industry standard sirnulation toals tt� identify Cl�e nr�ea in its netu-ork wher� c�apacity reatraints and i�ierference will afPeet data spoeds nnd s�rvicn quality. This informatiaa is devcloNed f'rom m�ny sources includin� tertnin And clut�er databr�tes thnt 5i�nulate thc� envir<�nment, tr�f�c map6 that simulate t��e den5ity of users in the rnvironment, snd �u•opn�arion m�dels thut simulatc signa! r�lative to interferenc� in the pr�setice cff tcrrain and cicncet• vuriatioii. AT&"1' evFiluates signal qu�lity b�sed an d7c 5ignal ta Interf'e►�enoe and iJoise RRcio {S{NR), whicll dircc;tly at'fects data spt�eds, �,xhibit 1 depict� data speeds when nc�ise or interference i5 intraduced into the high-b�nd signal oF the existing hi�h-band LTC service (wichout the prvposed sntall cell node(s)). '1't�e grcen shading shows �rexs where users experieoke exc�llent dflta service thet cni► typicully suppcxt high-definition Vide� ctreaming. 7'he yellow stiadin�; porp•ays arcas where users expea•ience ficceptable dutu service rn str�um sc�ndard•detinirion video.'1'ha pi��k sl►ading, huw�ver, depicts ureas whcre users have �roor dgta service or nn datn service nnd, as a result, ure nuc �e tible to reliably �Ir�am video and arc using resources ineFfiaiently. TAe red lines on the map rt�ughly show the eN'ective service �tefl Por the existing macra ontetu�A ihat ttie proppsed smalt cel! r�ode is meont to of�load; end the blue patc;hes desi�nocc err�.s �f hfgh usage. I3�cause an A�'&T r.�si�rner oannoc reliably stream vidso when lvc;aeed in a pink sbadsd aroa, the pink shading within the m�cro antenna sectar where ihe ptopc►scd stnul! Ceil t�ade is looated constitute;t the rel�vent saruice cov�rage ��p arcu. 7`his g�p are� is significant because it encc�mpasses i�any hundteds of hrnnes in residential neighborhoods, sev�ral sci�aals, numei��us com�t►ercial buildin�ts, � fire station, a)fbrary, heulth care faciiities, narks and p re�tres►i cenier. Accordiny ta the mo�i recent traffic data es1imats; av�ilable from the C:alif'ornia Uep�rtrnent of 7'ronspoription, npproxi�nately 2 E,OOU vehicles �rAv�l aloab rl Camino Real every' day in this portion of the ciry. 'fc� provid� the necessary capacity r�licf and close tfte s�rvic� coverage gap, th� srnN,ll cell nodes necd ta be plt+ced in, ar as near as possiblc, ta nte�s with �cror signnl qualiry and bigh usa�� -- the blue patches in pink s�aded flreas at' L:xhibit 1. Oncc an air, the prupe�geci smnll cell :rad�, alon� with othe�� smaU ce) I�+ nodes in the same macro antenna's servic� ara}3, will ��f�loed netwnrk traff3e I�rom that rnacro �ntettntt sector, which wilf impmve signe�l qualiq' and date speeds fnr ull users cuv�red by thp sector, aHowiitig ��are t�sers served hy khai sectot•t.o ��li�bly strc�tm video. My conelusi�ns ar� based on uiy knawledgC of the prc>posed small ceU foc�tioiys end with A1`&T's wireless netwUrk in the sun�undtngar�c,�n. I hnve a I35C Ht�nars Do�reo in fbfieroelectronics Enginc�ring t�om Universiiy of'lJls�er, e�nd httve J3 years-ex�erience itr ti�e wirelvss cqmmunia�tinns ind�istry, � >,�.,._. Philip Dale lET CE;n � AT&T Mobility Servir.es LLC Netwark, l�lanning & Engineerin� ItAN Ik�si�;n & R� Engineering Ati�gust 2?., 2018 Exhibit 1 ., ,,, ., . . � .,..... v �= s�, ��, � o a � : Acceptable Data Service � f"�. - 6� 'tr-„ . :� � Y � ` � � n� � . yw " �, �: Poor Data Service or No Service , .aReSl � � � - . � , .Q ��}a s t �f �ti ,��.4f.,, '�K 4i46 �� '' ' �' 7 ?� �� -- Legend: Traffic .. . . � , .. . Qe o, ``� .� ' •r� � , .. u .. � . . . '�'�`� p� �. +,. :�'� � � i� � B! �' - n . ° .� . I ' , � ' �� .:,�4�y � h 1. 'I �' r, ;��. : ��jL � � � : High wireless traffic area _� . �, � � .� f; + _� � � ..., ,r, � �.>,,._. � °.�J . � �, r,.. _q� � .C�-N RSFR� SFOK .014. :. "'�i R,; „Q{ a. �,. , 4��'�t�,� ,a ' -,'• ,. .�► _, �_ , � . .��: ��i '',��r '" ,:.,,t Legend: Boundaries . �d� .. "•7' ,�' , ' . � � ~' • :. � r•�_ •# �, � ' r .r^ ,, oc�„h� ,�'� .� ' � • r �' .,, r� i 's'CAA1E �' ., �.T s � ;_ y' �C � ,t' ', tia �•, • w.�CE �. �3 * r" � � i.c, „�yr � - : `� , � Macro antenna service area ,� , l:.�� . '<. • ■-. , • � � 4 . . _ . , � . . �.�� i ' � ..�. : . �� f` . r �ti, "�o,v � -F . ,i+�- .� `- . ' ; Y . ; r }� ' . - .U' � ~ , i �� Z' � ', ti�4� ~ ' � ti��i .,�a, �,V�y v Q . fs p.f' . . � � � - . .. , �" J�• o � ,� . � � riiA "" , , . R { F 7 . .V ey ~ . � .. _. JI � . .. Jt� � , _ � 7 I' ..: ' �f T .�y C�t' > � c�mat�•p� �i ,. � . i� . �, � �� ,.'� ` u ,. , � � . . . �� , . . ti �p.;.R . , • . . � ; � . �j � ., �hN i ,. • �" � . a .. ' �jr� - '� �-�� '. �. }. Y� ti � . . � �t .n.;t; � \a0 q .. N�'- � . . (',i Ri,NG�Mc �c*' j � fi:;� h��Ah1f . ' � '� � - i • � �Vt � �. �9v � �q Cii� � �.a � g' .,, AA . � tai� . � .. ' �.. : - •' i.� k � A ` I '� �va -� �44 , '.'+. 1 � R. � ' fi'4'+ih' IRiiC! � . . r,�2 .., a .� .n . .� _ � c� a � � '� . � {� ��, . .. $b . { . .. , � � . y bp . . . �. , . a, 4 � � . � � s. , � .. „ • ., _ . � �:� . � - � .. a .. y ol.. .. , �. r �:''' : r''.. . . , �,� .t� e� . - 2 ,�� ./' lo , s� .T`. � c . . . . . . , ..: � . u•.- . , � _ � w .�:��' � . � .. `�� . . �{ .. . 9 `�e_: �"' r � � . _ : * � �[. ' ah � j-� �, BURtlN., � .. - a,4e�r ¢� {t +,G r� 4 sa � , ,. �� • � � . - • . . . �� + , �3� �.� § ` � � � � • ,�s • e � $, . * . � _ � _ S' i�, ay .. � 7 y - ,sf � � ��. . : 4"- �`' f � ` . `^i � _ � liu n4; . rq � � Pe'�' . .. . .� �' � . .. � �'-�q ! 7 . * .,. . . .. 4 � �S � �. ... . � . w k . ,, " � � .. '� � � � �� . � y� � � ,,�.,. a . . .,_...; �fi� s'i � fY� . . . • � , � s � a' ❑ �j . .F4� .+,p�t,��a�.+�&��• 'I gqc � �a� �� ; " y h � . . . . As� � RY'FARM � e t ? t � � v � r S � � � . ,. , . . . � . . . '-. r . w' ,�-a- . . � . . � .. . 9 r . .:� � , .: �% � c . � ❑ � ai' �P' .r� A11'�{ � �T e � , � .. . . .:A�'�� .. �' . . �s, . � �` ,Fi'}�.fFr,;wC: � o .S�a , C" � o �' � �'� . . •Vi J. �� . � . . "q'.. �.4,3 S� � <~• . x � .:� � z '��' : r`' � , , . . i)y gy� � : �-, d J �.... . + n .- .. •:.' .0 . . � �� AT&T Exhibit D ��r�� uu �2 20�8 �T�&"J' Mc�biliry Iiadia l�c�quency Statect�ent C1 i Y OF 6URLWGAME C�ut•linga.me. C'A Sirall Cell Nod� l) CD�-P��iN�f�G C7i�!, "]'liis smtill cell node is necessary ta help clasc a sig��i�cnne srrvice ccrvert�be �;�ip in AT�iT' wirel�ss �zetwork, 5pecitipr�liy, Fut anteniia sectar on a nearby i��ocro si�c is ea}�eri�n�ing, �r is fnreeayted to experN�nae, c:xp�lcit.y rc�strainis th�t re<lucc itiobilc datA spe:�ds ta the extent thal Fewer uaers seiwed by iliat s�ctor will be �ble tc� rciiably strean7 video. Competifion H:id cusl;ainer �icmand require drr�t A"I'&'1' dcsi�n and m�tiniain ics netwc�rk sa th�t users exF�erience �vemge d�ita si;iviee sufiicient Io rcli�bly str�rym video. Any aref�s il�at da ��oc �»ee� tiiis minin��al video �trc�a�nin� standarc! represent b servic:e ec�verF�ge �ap tht�t mus� be clnsed. The ncarby macm ante��n� sc:ctur'� cstpuc+ty resir�ints rue cEtuse by the eytraartliiiftry incrcas� in inol�ile d�tn us��e, Since intr��ducdon oftllE lf'lione iit 2007, m�bife d�ta usa�e increAsed 2SU,00�%o�t A"f&T's ru:t.work. and AT'&"f' fc�rec�xls its cust�me�s' �Zrawing demf�nd for mobil� data s�rvie4s to continu�, llpdating its n�olril� uettia�ork t�� h�andle this surbe is critica) as custom�rs inerc�singly usc Iheir n�obile pho��c� as Iheir ��rin��ry conrtinunicntion cirvices (iriorr than 7�% o1'�1m�rican l��usehalds i•ely exclusively or ��rim�c•ily on wireless ph�nes) imd rely an their mnbil� phoncc t� do mc�re (C9 E I, vidco slreumin�, CiFS, wcb hcu�ss, tr�t., et�.?, ln t'�cl, the I'CC CSfIlIlAICS tllAt %O4IU 4F�%I � CifIIS tlrr pb�ced by peop(� usitt� ►a�ireiess (�hanes. And wich A"["8c"I"s selectictn by d�e teilerat First ResEzc�ndec Network Auchority, Firsi\`et, as the wireless sc��vice provid4r to buitd end inanng� the nuti��n��ide tii'st resti�oi7der �vireless neiwork, e�ch new n+� modii�ied fn�ility H'III EIlI1i111CC tlS C1j)Ablili�� ta sU•cn�then lirst res�x�nder l'011111'IUI11C�l1(1115. Usc�'S it� ��O�l' S1b11A1 qUzlity erCaS utie ti di5��PCf�)l71'11017211f Sl�fil'e (1� fCSUIiPCCS Frp111 (I1�' L`eIIUI1C ne�work. 13y pla�ing tl�c ��rop��sed nod� in � poor si�nnl qunlity area wliere rhere, is n hi�h densicy ot user IrflFtic, the mac,rc� sit� serving ll�e arca will bc oi'flnadcd and will �arovide bettcr,r•ervicc t�.► uther �itias tlyat it co��ers, � side beneiit is thf�t tlie nadc wil I en�►ble higl� daw spee�!s, anc� ultimately St.i services, 4o tlloSe nrarby usei:s. �1"o;�rovida thc neees�ory capAcity relief nnd close thi> service coveragc �7p> AT�c."f pl,�ns t�� la�e small Cell nOcieti in pqor Si};t1�1 c�u�lily A11� hi�th u5a�C �1i'zAS 3t'I�vecl by ihe tai•�;eted macro t�ntenn� secinr, F;�ich s�zr�ll cell n�xlc wi11 work �vith che ntlier smal! cell nndes in Ihe nrea to o�'flo»d nrtw��rk trt�lfic c�rried by ilie netirliy �nsicru Hnl�nn.n sectar and improvc ntobile dato scrvice �hruugha�a thc e1'I'cctivc; servic:e ��•ca, A'f&'f uses industry statndttrd sitllulcttiatt laols t�� i�i�niify tlte �tr3�s in ils nelwqrk wher� ��nz��ry r�str�inrs and intGrFe�•enc� wifl aticct datfi >��ceds a��d se�vice qE��lity. "!'l�is information is clr�elc�p�d I'rotn m�in�- so��rees incliadin�; ierrain Anci cZutt�r d�l.al�a�es I.hat �imulate the environment, i�'8if C I11E1�5 l�ttl� sintulfl�e 1he density uf us��s in the eitvirc�nn�ent, �ntl proprtg�tion nt�ydols tbAt siiiiulEite si�i�l relfltive tu incerf�rence in the �rsscnce n1'teiYai» xnd clutter variatiun. A'�'!�c'i" �valuates signE31 quality based on the Si};n�l to Interference �ind Noise Ratio (SINR1, which directfy afY4ets dat� s��ceds. E�xhibii I d�:picts d�►t�i speeds �a'Iten nuise t�r interfe►-�nc4 is ii�lrodtyced into Cho high•band yignnl of the e;xisling hi�;li-band 1. i'E servic.�e (withouE Clte pr�.�pnseci sm�U e�tl nude(s)}. 'fl�c� �reen sl}adi�i� shows arcns where users cxperiencN excellc;nt rJc�tss s�rvice thnt can typically su�lport: hi�;h-d�Finitic�n video stret�minb. The ye�low sl�ndin� portrays �►�eas wltierc us�r:� r�,pericncc accept�ble dat�i service to strcatn stt►ndarcl-detinitic�n vic�tc�. TI►o pink shaclinb, l�owever, depicts are�rs wherc users h�ve poc�r d��t» c�rvice or nc� dutr� scrvice �snd, us a result, nre nut bc �rEyle to reliably stream video and are usin�; r�sources incFficicnlly. Tlie red (ines on the mnp roughly show cli� efPective service xrea for the e�eistin�. macro �ntcnna thAl tl�e pr�pnse�f smal) ccU nndc is meani �� offlond; aud !he blue ��atches desi�nnle areus oi' high �is��a, L3ecause un ATbc'�� CU51:OI11CP i:fl1111nC I'CIL�i1Ij' S�iCkttlt VicIL'U WI1CI1 (OCBtI.(I 1t1 tl E71111C Sh�ded �reA, d}e pink sl7E��ii�g �vithan the macra antenna sectnr where the pro}x�sed smt�l) ccll noda is lacuted coi�sticutes the c�l��'�snt seivice r,�verabe g��3 �roa. 1'his gwp area is signiricanl bccausc it cnc�nmp�sses rnany hamdreds of homes in residentinl neighborlio�ids, suverAl scttools, numerous cu�ymte;rti�l buildinbs, a tire sturion, e� librfir,y, hettlth onrE` tacilities, park5 and a reCr�nt ce�tit�r. Acco+�clin�* ln lhe must recenc trat�tic datn estirnate available fruin�the �nlifc�rnia Uepnrdrent uf'1'r�nspc�rtatioa, a.�proximafcly� 2I,0(►U vehicles truvcl .ilnng k:,l (.'.amino Itc�l evcry du�' in this portion o1'the city. To provide the neeessury c�acity r4licf' �nd close 1�lie service cctiver�Ke g��p, tl'�e srnall ccil rn�de:t nee�l 1� be p[7ceti rn, or As i�ear as possible, tx� areas �vitlt pcx�r si�nal c�uality �nJ high usn�e — ti�e blue ��cches i�� pink shaded �tr�as of Exhihit �. �)nce an air, the pro�Sosed srri�ll ceU uodc, alon�; with uth�' srnoll ce:ll:; naciCS 111 �:I1C 9illll� IT1fSCi•a �ntwnrta's se►'vice aret�, wilt 4i'tloud netwcark h�at'tic froit� tl;af mnar� m7tenna sc:ntor, wltieh will irn��rav� sibt�pl quality� ancl dzita speeds I'vr afl users rovercc� by the secCar, �3IIUwll1�;1110�•c users sc�rv�d by that sector tt� i�:lit►hly sircais� 4�ide�. My conclusipns e« ba�ed on my knowleci�;a o1'thc �rapayec� sm�ll cell lo�ativns and witl� A"('&T's wir�less network in the surraundin6 erc;a, f hiavc: A BSC I-Inr►�rs qegree in Microelectronics 1:ngineec•ii�g ti•om Univ�rsify of lJlslcr, and h:iae 3� ye�srs-t:xpci•itsrice in tl�e wireicss caminunic�tioits induvtry. 2 C�� Nhilip ll Ic MIE�r crn�, A"('&'l� N�ohility �crviccs 1.LC hetwark. Plannin� & I:,i��ineering Ctr�N Uesign & RF F..ngiitieerii�g Au��s122, 2U1�3 Exhibit 1 _--- -... - ---.� -- __ --- - .r �� . � ._. , s:� G "�' _ ai �„ �r ��,�� : Acceptable Data Service ce ,�aro. ._ � V�r � Ro16m qd — o�,r` - �` - � ,; `; � �: Poor Data Service or No Service . ' -�, ��''' -� �� ,. ' F. .� .� � �R y,;� � �, ' _. �� . '� � '^9, _ � `� Legend: Traffic ,, , . . '. � � ' 3 . � , ;�..\ � „ � � " �� ' ` . � � p ` • `, .. . r�� _, ' �� , ti , `" ■. ` ;' _ : High wireless traffic area T r�. . �� " � . r � +�i� . � ,,�,+ , � .. �� ''a- �� _ - r '-ti .�i Legend: Boundaries � � � � CRAN R�PR� SFOK2 019 ` � . � `i� � . .:• �- - - �.«, _ > '�., 7 ■ ' 'j y�� , �' � ��Macro antenna service area ` f r �� ■ - .� ■ ■ j ■ ' �a>> �;. ■ JL'� 1 ,,, ', , . = 4 I �-. ,� .' .` .�' . � . . . . Y�y��_ � � � �� ■ • �`� '�'" � . 4�, II _,,--.—�. ■ . � ■ � '� � � . ''4 .. . . . C .. . � �" �� ■ , ■ ■ , C'r� Ll'ntHirtg3nt3 Pa:.: ■ a � � ex . i -', ■ � �� ..�a " CJ `4.� 5.�.� " �J�'�� .�� . � �■ . .� ��:,� . "i . i ' • �'i � 6, �;,� � � •� �� ti �./ � � � �. 4� `4�^ �_--�' �`fXs.�s � . > ... ' �a � � ��• � .i ��5. ■ 1■ � ��F � � `,. ; � �'�" . �� • ` • � -� f � • `5 L �� E �qam�� P r� ■ :,.,... � �t.' ■ :�� ' �i ,�■ . �'', ,�''. . � ■ ��i � e .. Q � c ■ �� . �� ' �,`,. � � ,� ■ ■ ■ . . ... � x a�` � �7 '4 °'r .. �.€':_ � . P ` ..� � � _ � .. � • • L a, � ■L � 1 ,, � ^ y`% ,F'` � ,p � � � r , , _ y, � �, y � . .�. � �, .� _ � Y� p y � 4i � f �� o'" �i" � : .. �`dirlirJlJ K� � 9 i). ,� r•¢ , �t�� r . �u' � �T 'b '�.�� ` ' - � � e ■�°r � `c o �� '� ' a� .. f� .. ^ . .. . . � - - y e . c„ ., � M ;..< _ � . , . c, 201N Miaosolt Ca�poratwnt�e� ?U1R HERE � . A .. .. �' .. � _. . . � ' � �)111(I `,. . f;...' . � � � AT&T Exhibit E Alternative Sites Analysis SFOK2 014 AT&T Mobility Small Cell Wireless Telecommunications Facility Public Right-of-Way Near 1800 Hillside Drive Burlingame, CA 94010 AT&TSite ID: SFOK2 014 �� AUG 2 2 �Oi8 CIiY OF GURL!NGAME CDD-FL.A.f��N�RfG DfV. � � �t&t �� Summary New Cingular Wireless PCS, LLC dba AT&T Mobility (AT&T) is committed to providing wireless telecommunications services and faster data rates throughout the City of Burlingame, and is doing so by installing the least intrusive technology, with the least intrusive design, and at the least intrusive locations in the area. Rather than construct several additional macro facilities throughout the neighborhoods of Burlingame, AT&T is choosing to deploy very small facilities, called "small cells," that can be attached to utility infrastructure in the public rights-of-way. A small cell is a low- powered cell site, which, when grouped with other small cells, can relieve capacity constraints by offloading network traffic carried by the nearby macro antenna sectors, thereby improving signal quality and mobile data speeds. Objective Small Cell Node SFOK2_014 will help close AT&T's significant service coverage gap in this portion of the City by the least intrusive means. As AT&T's Radio Frequency Statement explains, the volume of mobile traffic on AT&T's network in this area constrains the capacity of nearby macro telecommunications facilities. The result is poor data rates, meaning customers are experiencing poor signal quality in large portions of the City in the vicinity of the proposed small cells. Specifically, this gap area is significant because it encompasses many hundreds of homes in residential neighborhoods, several schools, numerous commercial buildings, a fire station, a library, health care facilities, parks and a retreat center. According to the most recent traffic data estimate available from the California Department of Transportation, approximately 21,000 vehicles travel along EI Camino Real every day in this portion of the City. Placing small cells on utility infrastructure in the public rights-of-way helps close this gap with minimal visual impact. AT&T conducted a thorough and good-faith analysis of potential sites in the area for the placement of a small cell facility. Working with the City Code and guidelines set forth by the Burlingame Planning Department, we investigated several alternative sites and identified the proposed site as the best available and least intrusive means to address AT&T's service objectives. The proposed site will provide substantial improvement in service to business, residents, pedestrians, and travelers in the area that will allow them to fully experience the advantages of AT&T's high speed 4G LTE service. And with AT8�T's selection by the federal First Responder Network Authority, FirstNet, as the wireless services provider to build and manage the first-ever nationwide public safety wireless network, each of its new and modified sites will enhance its capability to improve first responder communications. Methodology and Zoning Criteria The location of a wireless communications facility to fill a significant gap in coverage is dependent upon topography, building clutter, vegetation, zoning, utilities, access, feasibility and availability. Wireless communication is line-of-sight technology that requires wireless communications facilities to be in relatively close proximity to the wireless handsets to be served. AT&T seeks to close its significant gap in service coverage using the least intrusive means under the community values expressed in the Burlingame Municipal Code. In particular, Section 2 25.77.80(c) provides location preferences for siting wireless communications facilities. The proposed facilities are situated within 500 feet of residential zoning districts, which is a second-level preference. The primary preference, which consists of sites farther away from residential districts, is not feasible because AT&T needs to place its small cell facility in the right-of-way of this residential area in order to meet the service objectives. Under Section 25.77.80(c)(2)(A), AT&T investigated but found no viable non-residential uses and open space sites. AT&T did not identify an opportunity to place new light poles under Section 25.77.80(c)(2)(C) because the proposed Small Cell Node 14 is adjacent to an existing street light. Placing a new light pole would be more intrusive to neighborhood aesthetics because it would occupy space in the public-right-of-way. The proposed site will not create a footprint in the right-of- way. All proposed equipment would be pole mounted, and all cabling and equipment will be tidy and painted to match the pole. AT&T identified the existing utility pole as the next available and feasible preference under Section 25.77.80(c)(2)(D). To meet Section 25.77.80(c)(2)(D), AT&T proposes to screen the equipment and paint to match the existing structure. In addition, Section 25.77.090 provides design criteria for wireless communications facilities. Consistent with Section 25.77.090, AT&T has sited and designed the proposed small cell to minimize visual and auditory impacts and to preserve overall aesthetics of the neighborhood. Based on these parameters, AT&T investigated site locations that could meet the service objective. AT&T's analysis is set forth below. Analysis AT&T investigated potential alternative sites for Wireless Cell Facilities (WCFs) to fill the identified significant gap. As stated above, no feasible collocation opportunities were identified in the search area. The following map shows the alternative sites in the City, which are discussed below. Location of Candidate Sites , . ,�y� � � �_ �.;� �.�.�,,.„,;.;� � � �`_a�;�. !� `�� "?,;, e d,, ♦ �, s � � . °� , �`f ty►,� ` " �t' ."�"� F �4 � `�. .� K t ;. ��,�J3j ; . Y . , a�� .. � ' �� .. 4 . - ,�1 �p• yyr �.. � �. F 1 „[^ en � �"," ' xi '`R f S�"'��.y 'a' � _ �"" < �T E; � ya._ a ,e� ^?,W � �i°., � � f t' ' �� e �k r ' �'. ' � �/� � ! � •� �� y�, 'i` '� µ�.,a=�� { lot ". �� j,y ` J,/f .�. �.� • y� � ry.�� :� A�� },'�'x" � ,� / � � /% f j�J y • � /'F l.. ' + ,�• � ' � '; �`� ��}'-�,� � f�y� /'s % � � � � � P .MI . , '� �: i _:�` �x; ��,.�."� es�Y�� „:�.��,a� +� �i�' , � �� #, � ,� �,; , ., -., . _:_`�,.. ; ti +%�-' � - '� �+ri; ` - ,� ,�' ,�� " 't .�. � ..,:'� � ' _ � �- � �;, � .l ,y �; � " � _ � �d�_fa� _ _ —�- � ��" � �,� « �, ,Y �� `. c, .� l6r`„ �1 " '� � �"._ � " . » � � m ^_ � j , c , � . : �e � �l � '�"� � � �' � '��.%. -�`'�� ' r FM,,.�,,, . A ,,� ` �.�4•� r�'ik; ,�(, A�"'�. '��r .�. . . .%i'ji"��..-�i�;� 4 . ��i. t y� � „�,, " ^ �° 3" r , � y, • -� . � � ,�. ��' `� �� ,�!'. �' �,'• �" `"' ". � ;?. �¢ . . � � „ , . Y �� .. . �°, ��f � � °�' a"~ h` ,��'� .�'�` �'��'�"., � �'` j ; � �r► Y `� ,� ' `� ,�. �'"` � ' �� , �� .,,;�_ , ,��, �,, . � �. �, ,� � .,� �., �`.��s,°" _ � ' � � � . w �.,, � � �, ,:� •� �'� ,4'� ;�"� a� . �> ` i ,�`, '.. u,,'��'- }�r,. �, •. � , , , ' � � I"� �� : � � ' `�. 4 , � '�` �' " � ;�• . °. . � *' , .. ,. � #� .• � .. s � �";' �' � "� � �! f � ��' '� n�. � 4 � �•°,!�,.,� �� .��,� ,,��. �"`��, `.�� '� + 8 � �,.� . �,,. '` 'r' �` r ' ' y � � ` � " � 'd �"i � � � � j� � �� r � y�r�i '4` � ; � :,l T L. �� 1'" �?'�'�<` �' "� �� " `'i�i'�f�'� � � �',A -..i. �� 'E.`'_'� � �� " k.,� � 4 Candidate #1 — Public right-of-way near 1720 Hillside Drive �� - ,:.e _ � � � �w. .� ��, . ��. � � �� , ' ' y °«,� � ; ° ,�a 3 ��s�ar��"�k� �'� �;d�� e�?«aa� �.v.� s�„„ . �� '�»' .� . x ,5„�;�'r;P �� +�� .zC"','�. t�, , �4, .0 t� ^^�'x , . ,��.x,�... . �.`�"� .a , .� a ,.,m,: �.. � �... h ro y� � ... .� � � � . 1 ., ".�",Y.* '�. d, � , � . .. , . . .. � ,$ { % . . . . �, . ^ � � . , . . . . ��t f� +_ . . � .. . � r , � � ' "'�.��.. �'1 r �,� .�r `. ��c-a Conclusion: Not feasible. This street light utility pole is located in the public right-of-way on the corner of Cabrillo Avenue and Hillside Drive (lat/long 37.585470, -122.373850. This pole would not be viable as it does not meet CPUC G095 requirements. It has a disconnect switch, primary riser, and cut-outs that connect to primary power, all of which disqualify it for usage per PG&E standards. 5 T j �. . � —�#m""` = "�.'."� Candidate #2 — Primary Candidate — Public right-of-way near 1800 Hillside Drive s � propoxd AT&T antenna % 41N . : � �ti�:.: ' . y �� . . � ` _n : _ =- u� - -� ,� ;^� � � �. �`;.,��. ..��: � :. � n .�._---- Conclusion: eest available candidate. ��-,�� '� --r,.� =� #.�"_- - �' �_ .��s.� ._�_ -�= _ This PG&E utility pole is located in the public right-of-way near 1800 Hillside Drive (lat/long 37.585211, -122.37405. Consistent with Section 25.77.090(c) of the Burlingame Municipal Code, AT&T has sited and designed this proposed small cell to minimize visual and auditory impacts and to preserve overall aesthetics of the neighborhood. This pole is located between two residences, and the top-mounted antenna will be sheathed in a radome painted to match the pole. AT&T also worked with PG&E to allow a smaller meter on the pole. Using pole-top antennas also helps the overall aesthetic by maintaining the existing pole line. The height of nearby trees will help conceal the equipment while still allowing the antennas a clear line-of-site for signals. The pole-mounted equipment will be in small enclosed boxes painted to match the pole. This site is feasible from radio frequency and construction perspectives. Use of this pole has been approved by PG&E. .� Candidate #3 — Public right-of-way near 1810 Hillside Drive � �` � � �,N.. �. `, w�` � �:�..� \c ' ;� �. �� --� �" ; . � � ,� �,�----��' �"��a � `� �� ` r. � �� ;s� . � � -' � ,�' �' '� - +� � �c+r : x..: � � � :llt, 1 �� .,��,, � �� . <�x",:+ �' � '- Conclusion: Not feasible. This utility pole is located in the public right-of-way in front of 1810 Hillside Drive (lat/long 37.585082, -122.374192). This site is not viable because adding a small cell here would not leave sufficient climbing and equipment space. CPUC G095 standards require two of four quadrants of a wood pole to be free for climbing and equipment space, and this pole would not meet that requirement. Therefore, the pole is not viable. � Candidate #4 — Public right-of-way at the corner of Hillside Drive and Drake Avenue � ..4 h � k' blm '^�. � �.,/ 4 ' S, �a . a " J �"i" ! `� � � . ' "�/` r . � ! �Y^`/ . / J . � .. .' . .. . . � • ^t �x V.' � � � ��. � . . . . . . � .. � � � � .�' , L �. . ryW � c. , � , . � � - . � � .�y ,� � ��"""� �; �y � y�� y��c�:}' �'y��4':,:,� ^�71'7 ry. ..%�• '��. ��_1'.Gi4A��:�� .Q,�Y FG.+ � 1 �� •�v� 1� . ��:i� . . �� . � , d . `L'J 4 . Conclusion: Not feasible. This utility pole is located in the public right-of-way at the corner of Hillside Drive and Drake Avenue (lat/long 37.584802, -122.374445). The pole would not meet CPUC G095 requirements, as there are 3 transformers, a disconnect switch, and cutouts connecting to primary power located on the pole. E� „ �.� � .,w: , :�'�:' p<' �+!.- ` `T � ~ �`_Y�i� Y, ' � � �4. � n+•� � } �.. .�.y, �� f ja�' �ii` � A � � �, .� � ... ^h+',� . ^n �� -�� r� -� � � �� ” �' ' ,��.,�.-��1►� +� �,�; . =� _. '',. - I' ;�.;,�,�:,. - iiii:a.N+i:'"b+`� . /',"� � , , ,- �" "�d � �'' *, . � � . . � �.*� � a� . $ w� �a ,SiL o.. _ w e . -�. . . Conclusion: More intrusive than proposed facility. This utility pole is located in the public right-of-way near 1819 Hillside Drive (lat/long 37.584591, - 122.374126). The pole is also located directly in front of a residence and therefore more intrusive than the proposed facility. In addition, the pole is a drop pole with a lower height than other area utility poles and a small cell here would not as effectively address AT&T's service objective. �"�'` '.� � ' �, � � _ �� rla C' � ....h�._ Y�ui.'i1 �7 Candidate #5 — Public right-of-way in front of 1819 Hillside Drive Conclusion: Not feasible. This utility pole is located in the public right-of-way near 1720 Hillside Drive (lat/long 37.585735, - 122.373594). This pole would not be CPUC G095 compliant as it has cutouts that connect to primary power and does not have sufficient space for climbing and equipment quadrants. This site is not viable because adding a small cell here would not leave sufficient climbing and equipment space. CPUC G095 standards require two of four quadrants of a wood pole to be free for climbing and equipment space, and this pole would not meet that requirement. 10 Candidate #6 — Public right-of-way near 1720 Hillside Drive Candidate #7 — Private property behind 1804 Hiliside Drive / , / °. . �`� °. ";` �� , <- �� -� � ° „� • �. � ;� =%�` �;��.�i . k5{^? `X. �� . r . .. .. �b�� . � r.e , . � . ,. - `� '�i ... ' . . ... . .....� . .�,:,rj �e..;. � F ��, . . . Ryr ''u�:+� .�?@ V' V "�;� t'�; .. ,._—.£-� . .... �. ....,...� ., .�.. � . �� .. ! Conclusion: More intrusive than proposed facility. This utility pole is located in an easement behind 1804 Hillside Drive at lat/long (37.585260, - 122.374516). Although this pole is located between six separate residences, AT&T analyzed this site per the City Planning Commission's request. In addition to being located on private residential property, this utility pole closer to a residence than the proposed site. This pole would not be shielded by any vegetation. Pole #7 would be more intrusive than the proposed facility. 11 Candidate #8 — Our Lady of Angels Parish and School, 1721 Hillside Drive �. � ,,, ��;�� u,. � � � � �;'",: , , <,, . s � �n , � ,+: � � � .,. �;, �"�� . �* � ��; � � t � � . +�, i—ya,` ' �'+, . � ; � . . * +�, . , � a .a . E ,� '� "` 'y' ' ,. � i 5 � '�� ' »,,yr� � . �,' � �'�,l'�,a r - °� �Y�," t..��`��+ , „�, �� ,� � ' �1, ,-,• � � • t _ ��i' '��i -� ��4;'y;�'•'+� �� e . . r� . � :�, � ' w ' � � ; � � � � .�i% .. �t � � , ,�".� �..... � i �{ . " � ��.. �. � �'t • _ f� .�_ . ' . v],...;. . . F ., !,'„�' Yi a �` � r�`�. � � ; s. R �.�� : ��' �� . �, �� , �� W°F A�kf'+ . .. � . _' � � y,.t . . Pr .-�-., _ , �, � .. . �` . �t. . . �. , . �" .- ° { y�' A . ^�� .. , . . , ,� h _ �y� �' % ��''� �1 a . .. . . � . � . . � ' P�� 7 � !1 ., w.te�xivsava, �_^,�,, - ' . _ �� . , - �:. . .. ,�. . � •s , � . .« `,;-.. ^^ ` q�a,� .,. .. a-- -x.^^�`"", . . .� - -. ti: ... . � _ , , . ,�, .. ... Conclusion: Not available. Our Lady of Angels of Angels Parish and School is a private kindergarten through 8th grade school approximately 200 feet northeast of the proposed subject site. Although not typical for a small cell facility, AT&T analyzed this site per the City Planning Commission's request. AT&T reached out to Our Lady of Angels to determine interest in leasing space for a wireless communications facility (WCF). Our Lady of Angels initially showed some interest in leasing space, but only if no changes were made to the appearance of the existing building. To conceal the antenna, the site would need to be located in the church steeple, which consists of thick concrete. For the WCF to function effectively, a portion of the concrete steeple would have to be replaced with fiberglass reinforced plastic (FRP) to allow the signal to penetrate the walls. It is not feasible to replace the steeple with FRP without significantly altering the architectural integrity of the building. As feasible designs do not meet the requirements of Our Lady of Angels Parish and School, this is not an available alternative. 12 Candidate #9 — Intersection of Hillside Drive and Cabrillo Avenue � � ,, , .• �, � � �,a r , ;r�� _ ' `�« �+.y �'�� a � � � '' , . _ � � � �� . �"1+•r , . �'�'., �' . . >s�x ,..,i�i x ,.�?'a?f$�I . . .. . .. . . }�,� � � � , � �" � '"� � '^ �� >: : ' ` ,. \, � �� ,'�� `� .... �> 1�' `` ^ ' *� f,..�._ _ .c�::� � . � � , v ,� r � � �: � -, � r^� �9� ,�'�y , ' A ' , +.c � . . . � . R��. <t�'` �, � ..' • '_ �'� . r� t � . 't �y : • . "*'�. �3 � s' .. � . \ . � , �' �9 4 . �k t ��,,+�� j„' �' rh=� ".�T _ "a }'�� `dY�� '.:� '� .. 4 � �' fq�-�tt,�� . .. � `'� ; k� �,, { " ,� � `�� ° �x� ` r i � �,,,� �, `�* t � �_��_�.,, � � .�.�r-i�,,� $ r �c r ..,� s �.�.f~ i �� ;� M" < e � i ,��'1 'K s�;t��'�,� �` �,'' ' `.c "�� `� ! `, � �W ��' ` � '+�a' . : : '�. ." b �,�. . � �' >: . , q.a � �+R,� * , , y�e... � . � .., , , c �. ..,� ,�y � �r � � < ` m_.'�- ,� �, � � �,�' ��ry=� �.�.� ° .F y pi > . _ � �) y�..�a �"�, � ��il �'�' � : � - ,� "1v . '� .' � ..�.r'� ��.' . Y��".. . ".�" 4 ' r�""-,. .�..< r�i'•� ' "r�+►�a�� y` � • '� .. ... .... � 8 .�.....��r.�' �7►r � . '�..�� '��.�:...-^".w .. -r �. .. .,... ... � r _ � r^-,eu+�i.".+�'�`� �� '�.,,°"".,�-:, � ; . . ... � , . .. � r • ,.. � � "�.r--_ �� '�'�.�..�' �`' �� .. ' � `�°aw, � � -., " "�a. � •.�as , , . . , i+....�" e: �'��" r �i � ;'�-�5.. . " • S .. n i., -�;,.��"'r • " _ .., w , , .�*�°n. � t +' . . a, . ,��;r -e+_'� �..<- � s. . ,,: �r x ' +,� a 5� q . . �.,��3�� ., , , � • yb� � � �p� " � w� �`"�s � x . � f�� r w�`.�...-'niN�3�} ., . ,.-.. �... ��_ . . �"��.�. �� .-_�',_�. � - �.... �'��,�� t`�:. !. _ �5`. � ' f ti' 1'.I d� � ��.� Conclusion: Not feasible. Candidate #9 includes the traffic signals located at the intersection of Hillside Drive and Cabrillo Avenue. The traffic signals at the east and west corners of the intersection are not viable because the pole would not be able to support the equipment structurally and there is not adequate space on the poles to mount the equipment. Attaching to traffic signal poles could also overburden the poles. In addition, the lower height of these poles would not as effectively address AT&T's service objective. Therefore, the traffic signals are not feasible. 13 Candidate #10 — Public right-of-way near 1920 Hillside Drive ,....: :... ,.. .�_.�„ y;- � c,"�""�y�"�..�,ei,�. �n,,,"�'�x �'J e�''� .�,'`,�, :;:p'.m«� r;��' � �"`--^--;..,_..._.,..��,��-....'"---^-'-__.... . . ��. . . st x;. � . . . .. . ...,. � � . .. __ __ . _ „ -,._.__ , � ..... -_.. - _.. ..,__._ . . t .. �._. . ... __ . . ; . .. .. . . .. . � w .,""�-'. ��-"��"- � �� . .. . . ,.. �-�..'^ y � � , . ., .. .. . .. ! . . ... ...k �. :, . . .. � �.._ �� _ V - � - ,, _ __. _ , _ �f� . w, � ,- � _ .., � � , . �� r�� ° �� . . �, /� > � � .x :� �, .~', �,� :- � � � � � �: -� r, -�-�� r �ts.. 1�---�-�`'�� µ'; _ .R . �.� � � �K�� 2� ��i � � � ��3 ��' �r� '��_��.�� ,� '� �� :;�„�r � _� , �� m, . � 3�;s *,`� � .. a - ; - -�. � �: ��::,.�°^e..� - �� ., '� ��s ��.� �,.�.� _. _ Conclusion: Not feasible This utility pole is located in the public right-of-way near 1920 Hillside Drive (lat/long 37.584390, - 122.374796). This pole would not be CPUC G095 compliant as it has cutouts that connect to primary power. CPUC G095 standards prohibits the attachment of small cells to utility poles with cutouts connecting to primary power. Conclusion The proposed facility, Candidate #2, is the best available and least intrusive means by which AT&T can close its significant service coverage gap in this portion of the city. 14 Exhibit F Alternative Sites Analysis SFOK2 019 �. � ats�t �- AT&T Mobility Small Cell Wireless Telecommunications Facility Public Right-of-Way Near 701 Winchester Drive Burlingame, CA 94010 AT&T Site ID: SFOK2 019 t.� ,9, K•.,��e ^1s^'' � ! � � � �',UG 2 2 2018 :,ITY OF �3URLINGAME C�D-P��lNING DIV. Summary New Cingular Wireless PCS, LLC dba AT&T Mobility (AT&T) is committed to providing wireless telecommunications services and faster data rates throughout the City of Burlingame, and is doing so by installing the least intrusive technology, with the least intrusive design, and at the least intrusive locations in the area. Rather than construct several additional macro facilities throughout the neighborhoods of Burlingame, AT&T is choosing to deploy very small facilities, called "small cells," that can be attached to utility infrastructure in the public rights-of-way. A small cell is a low- powered cell site, which, when grouped with other small cells, can relieve capacity constraints by offloading network traffic carried by the nearby macro antenna sectors, thereby improving signal quality and mobile data speeds. Objective Small Cell Node SFOK2_019 will help close AT&T's significant service coverage gap in this portion of the City by the least intrusive means. As AT&T's Radio Frequency Statement explains, the volume of mobile traffic on AT&T's network in this area constrains the capacity of nearby macro telecommunications facilities. The result is poor data rates, meaning customers are experiencing poor signal quality in large portions of the City in the vicinity of the proposed small cells. Specifically, this gap area is significant because it encompasses many hundreds of homes in residential neighborhoods, several schools, numerous commercial buildings, a fire station, a library, health care facilities, parks and a retreat center. According to the most recent traffic data estimate available from the California Department of Transportation, approximately 21,000 vehicles travel along EI Camino Real every day in this portion of the City. Placing small cells on utiliry infrastructure in the public rights-of-way helps meet this need with minimal visual impact. AT&T conducted a thorough and good-faith analysis of potential sites in the area for the placement of a small cell facility. Working with the City Code and guidelines set forth by the Burlingame Planning Department, we investigated several alternative sites and identified the proposed site as the best available and least intrusive means to address AT&T's service objectives. The proposed site will provide substantial improvement in senrice to business, residents, pedestrians, and travelers in the area that will allow them to fully experience the advantages of AT&T's high speed 4G LTE service. And with AT&T's selection by the federal First Responder Network Authority, FirstNet, as the wireless services provider to build and manage the first-ever nationwide public safety wireless network, each of its new and modified sites will enhance its capability to improve first responder communications. Methodology and Zoning Criteria The location of a wireless communications facility to fill a significant gap in coverage is dependent upon topography, building clutter, vegetation, zoning, utilities, access, feasibility and availability. Wireless communication is line-of-sight technology that requires wireless communications facilities to be in relatively close proximity to the wireless handsets to be served. 2 AT&T seeks to close its significant gap in service coverage using the least intrusive means under the community values expressed in the Burlingame Municipal Code. In particular, Section 25.77.80(c) provides location preferences for siting wireless communications facilities. The proposed facilities are situated within 500 feet of residential zoning districts, which is a second-level preference. The primary preference, which consists of sites farther away from residential districts, is not feasible because AT&T needs to place its small cell facility in the right-of-way of this residential area in order to meet the service objectives. Under Section 25.77.80(c)(2)(A), AT&T investigated but found no viable non-residential uses and open space sites. Under Section 25.77.80(c)(2)(B), AT&T investigated but found no collocation opportunities in the area. AT&T did not identify an opportunity to place new light poles under Section 25.77.80(c)(2)(C) because the proposed Small Cell Node 19 is an existing street light. Placing a new light pole would be more intrusive to neighborhood aesthetics because it would occupy space in the public-right-of-way. The proposed site will not create a footprint in the right-of- way. All proposed equipment would be pole mounted, and all cabling and equipment will be tidy and painted to match the pole. AT&T identified the existing utility pole as the next available and feasible preference under Section 25.77.80(c)(2)(D). To meet Section 25.77.80(c)(2)(D), AT&T proposes to screen the equipment and paint to match the existing structure. In addition, Section 25.77.090 provides design criteria for wireless communications facilities. Consistent with Section 25.77.090, AT&T has sited and designed the proposed small cell to minimize visual and auditory impacts and to preserve overall aesthetics of the neighborhood. Based on these parameters, AT&T investigated site locations that could meet the service objective. AT&T's analysis is set forth below. Analysis AT&T investigated potential alternative sites for Wireless Cell Facilities (WCFs) to fill the identified significant gap. As stated above, no feasible collocation opportunities were identified in the search area. The following map shows the alternative sites in the City, which are discussed below. 3 Location of Candidates Sites � � _ ,�: , ��r* a�F� ; �a�ry r:� i'��as� � % � e ,�' :, �} � ��rt" � ��;'� ^ �" �� '�� y �' � '"' �'. Y" " .:. :,_ � � � n �` , � �" � + r'ri 1 � f ��s�* '.;�k r ;.J � 'iy; +� � ',t,� �< �.� Y+►'�., - .�.t� `t. °s . �. . . ��.v, ' � r �"' M � � w�� '��",r' l,q rs �, ' ^�.-��._ � ��, � ^�"�� % �� Y.�� ,�,�,��' 'i�dr. _�' �...M1y ' ��r� _ _ _ �,` � . . a 1� ` b i ',,�` \ e� ' ,y� „y.,. . f �y, / �.T � � ��. � �F \ �� •I;�`J�� 5�� _� . ,. �" � � ' �`, '�"� �". � , �, , u� �� .;- • '"'"` �° j° �'�; ,�.. „� ° ; t$�.� � '�' r�` , � « � :� �'�� , �«"v� � � r . � w;;'�,. • . - � . . � _y � r't"' �_,, • , , � ., / � . � Y�`��'. � � . � �i �.. � .�� .r�: � � f � � �� r '� � , . . , . �.�,�,��j',��y,�.� .1F� �'� � .I �.a. � V �\ � .�-� �'Nrf . . � �`54`� . � y � � ,�� .. .. ✓' �, s:.";�,a� � ' , � �"� � ;�' , t�'�`j � , .. +� � � �+ / ` ',. ' / � , �.z � . ".R. . 'p .�. ;f�_ � "''p ., . ..a • , . . � • . "_ 1c .� y, ,a� � yy, .'� � �� - �� fA" . .., �y,,, T 1��r°� � si. t^.<t` ryy. � Y�� , AAa��"' � . �. , .X�'�'`�. s�;* . . ��,�a,W . ,. ' y: . y. n „ /�//� �¢ : r . ��Mv��i'�✓ s"'✓ � �.i„" "• ? . . d* yF � , Y J - � 1 . s � � C , ,�,d" . . ' or � �� • �� ..�• � \' ' ��✓� � =.L�� . � ` . t �� ~ � �,� � '.,; � . . . . .� � � t ,'4�'•e •�?'�!• ! _i`�� .r�: i-,:^�,^a. , _.�_.. . tia, .-' ,� " . r . � -- ,. - . � . � �S!� , �! �4 , . - � ,, � „ . � . �-y,� � `� s� :.�,' � �C�` ,�,�r�""" � �� ..rq' � , 9:'�y� �'J ' � �. � m, .,. � .'�, . Yr A°�i��r�� ;. . .+... ^� m � . �, }�a . �:,;• � , t, , , �. . 7 . F, r . .� , � �. ,,yy �, � > ., . � � . , ' �� . ,...# � C.Ti."� �r_ ..9 _ .� � / .�i-- � — ---- — * f -- - - . _. 4 Candidate #1 — Public right-of-way across from 704 Winchester Drive .-,�-_.r fi��.-�-�,�. R-t_a_.�;�� , - � � .�� a�::-r�' m l'.. '.�..+s;ei.s�-.�... . � � � l•�/ �k:.+s,.�.., . ', , ;� : � `� , �:_ '��-r - \. ' ��.�, . ,�-� F r :� : �~ �� + .,n '� �� "�'; �= �� , ,' - � �. -�'� � �n ..�. . a� y.k p � . �..411� � �'� � 4 � y Y ��! t k�� r:�� ..4. t r '� , .�.,, ti � 1 S � .�� '� " 9' 'R,: ,..,I ,�'+� .} � � Y� . -+4$°� .� + "k 'a L " 3'� twC e '� � .� '" .«s. *� � ast ,, � `� ' +`� �` ,S �� ^i � a �ry �` .�`. k +v � a+ P, - � � �M1� �9 x3 ��:� � ,n ��u�a�'.r��u' a $ �'� �� £3 �� .$" ' f � �� +�ii�� .n», ._'_ �- ,��: �:3 Conclusion: Not feasible. ..../� r � ti .' :�� . �w:._ . �, .� ;� . � This pole is located in the public right-of-way at the intersection of Winchester Drive and Oak Grove Avenue (lat/long (37.584545, -122.347785). This pole was originally the primary candidate but PG&E indicated that Verizon has reserved that pole for their use. There is not sufficient space on the pole to mount both Verizon and AT&T equipment, so this pole would not be viable. . ..},i`— / � �� . � r � � ''�� N Y % � f_ .r- ` � fy.�. T.., 4 '�x �� r* � ' .,.e_ � . _ - � � � � . ' , l... .� �'V.'- 4'.' : � "F� T, _ , �w`'., °z� ° 5 Candidate #2 — Primary Candidate — Public right-of-way at 701 Winchester Drive Conclusion: eest available and least intrusive candidate. This street light utility pole is located in the public right-of-way near 701 Winchester Drive (lat/long 37.584364, -122.348219). Consistent with Section 25.77.090(c) of the Burlingame Municipal Code, AT&T has sited and designed this proposed small cell to minimize visual and auditory impacts and to preserve overall aesthetics of the neighborhood. The pole is located between two residences, and the top-mounted antenna will be sheathed in a radome painted to match the pole. AT&T also worked with PG&E to allow a smaller meter on the pole. Using pole-top antennas also helps the overall aesthetic by maintaining the existing pole line. The height of nearby trees will help conceal the equipment while still allowing the antennas a clear line-of-site for signals. The pole-mounted equipment will be in small enclosed boxes painted to match the pole. This is the best available location from a radio frequency perspective. This site is feasible from radio frequency and construction perspectives. Use of this pole has been approved by PG&E. 0 Candidate #3 — Public right-of-way at 700 Laurel Avenue Conclusion: Not feasible. Pole #3 is located in the public right-of-way near the intersection of Laurel Avenue and Oak Grove Avenue (lat/long 37.584014, -122.348569). This pole is not feasible from radio frequency perspective because the pole is surrounded by trees that will block the antenna signal. Therefore, this pole is not viable. Conclusion: More intrusive than Proposed Small Cel/ SFOK2 019. This pole is located in the public right-of-way near 707 Laurel Avenue (lat/long (37.584292, - 122.349216). The pole would be more intrusive than the proposed candidate as it is directly in front of a residence. In addition, major tree trimming would be required to attach a small cell to this pole. Therefore, the candidate is more intrusive than the proposed facility. Candidate #4 — Public right-of-way at 707 Laurel Avenue ,� ,;, � ,. � ,. � , ��+ � � , d ' / i �4 � £y �.� r ",�,7� � ,o � , � � , , - -' . � � � : s � � S : ' ..r1 � � { . �. .. i +�,1�y, � � a� . � , � �� . .. . �. .1�. .. . . . . .. u. �, � . + t �� •".'�[' . . �..,�,,... ° � �� r h. ' �� M- , . . ..� . . � . x1 . h ' ; ,0�. `# .�� ,�.�� .� ��' � .� .✓�f�v �� I� � `a4 • .. � z� ��,• .� �' �=� r� '"�'x ��,: �' �� "� ��,,a � - � � � � � .�, � --�� k �,.. �, � �,,� . #,�, +ca"ws�s ;� , :r. � "" } LL ., ,. < t 3 �� x w" � � '� � �d�a,e", �' ..i < � , • „ , .,, -, , . ; � � . .. � ,�� . � � �., u } '�i � ax�q� � # ��,�'� , ��ty�`s°�; " ¢��R'? ( �III�I IIIiI�i�11II�Il,��, '''k,,,,»�•,�i',r--�` �' �'� " �� ` � � � �_i I�� ,�, �' { � { � •: e 9 ' �� .�Ittw.4!?��4�., � �< ^�r's.. ;+;d �. � �! � ,fi A � � � � ��) �',�"'" m";�y� r , i . ,. �«ll . . � t� IL� �A . . �� '�' ��"�� j � � � � / � � � �t.l�ia—. ...�. � �- � '� e R �t t � � � „w,,rw� � , ,�. ,� ��, ��.m-� _� > _� - ��,�"'�P . _ _ . . : ,.,��..�""` �.��'"" : "r � � �y-�°..�„ _ . � � � rt �, � ,�."', � .�,��. ; � , � �� . a ._ _ _ _ � �_ ' . ., . .� . , Conclusion: More intrusive than Proposed Small Cell SFOK2 019. This pole is located in the public right-of-way in front of 908 Oak Grove Avenue (lat/long (37.583831, -122.349009). This pole more intrusive than the Primary Candidate because it is directly in front of a residence. E Candidate #5 — Public right-of-way at 908 Oak Grove Avenue Candidate #6 — Public right-of-way across from 704 Winchester Drive � ' . �„�- ... ..� � Conclusion: Not feasible. --� � This pole is located in the public right-of-way on Oak Grove Avenue (lat/long (37.584719, - 122.347522). The pole would not be CPUC G095 compliant with a small cell attachment. Adding a small cell here would not leave sufficient climbing and equipment space. It is also likely that the pole would not be structurally sound due to the six attached guy wires. This pole is not feasible. 10 Candidate #7 — Public right-of-way across from 700 Laurel Avenue ;-, k „ p 1 S� { „ ! }�t �=�r � � ��} � g,� S. �;a a" Conclusion: Not feasible. �' .� �. _ �., �,.. `<�,,.. '� This pole is located in the public right-of-way on Oak Grove Avenue (lat/long (37.584164, - 122.348314). This pole is not feasible from radio frequency perspective because the pole is surrounded by trees that will block the antenna signal. Therefore, this pole is not viable. 11 a Conclusion: Not feasible. This pole is located in the public right-of-way on Laurel Avenue (lat/long (37.584103, -122.348792). With a small cell attachment, this pole would not be G095 compliant due to the existing utility boxes located on the pole shown in the image above. There would not be sufficient climbing and equipment space. Therefore, this pole is not viable. 12 Candidate #8 — Public right-of-way at 900 Oak Grove Avenue Candidate #9 — Public right-of-way at 705 Winchester Drive , , �� ;ili:l,ll:) �' -�..-..._.. '� ,�;' �; - ; w, . �.s• .� . . A; , x*� � �'��:..� p� Conclusion: Not feasible; more intrusive than proposed facility. This pole is located in the public right-of-way in front of 705 Winchester Drive (lat/long (37.584761, - 122.348131). This pole is not feasible from radio frequency perspective because the top of the pole is fully covered by tree canopy which would block signals. In addition, this pole is located directly in front of a residence. Therefore, this pole is not viable. 13 Candidate #10 — Public right-of-way at 719 Winchester Drive � --%i �.�'"i" �,„� � d �� _�'� � ,.'",�'��` � '. 'y�, �},.,�, Y �. ` � _ � .. . , . ,.x. ..�� i:�':�'t`d��' �� :. ! � � � ' . . .. .. . . . � �Z 1r. � -- �',`'.�_�.�•- ... .-�",....,.._..�'� �`:��._�._-� . -�� .�. � . .. .. .. . ' _ l,� '. . . . . , �.. .. , . ... � .. /� Y\� �� .. l_\ `t� 3 . 1 `: sc-:, "'" ,�, � i . y$, � �� :�t ai ..... � t. � ..;. , � { �i$`v�'i,....` � �fl tP �n �f�*" + f 3 : J �'� � $� `�� .� .. ` ..... ^^ �\ . '�� ; ��,�, y%' r�. / 1 � ' � i� � � � ' .. -' fa.q ab�,� / � �' ,.7 Conclusion: Not feasible; more intrusive than proposed facility. This pole is located in the public right-of-way in front of 719 Winchester Drive (lat/long (37.585023, - 122.348511). This pole is located directly in front of a residence. Adding a small cell attachment to this pole would not be CPUC G095 compliant as it would not leave sufficient climbing and equipment space. Therefore, the pole is not viable. Conclusion: The proposed facility, Candidate #2, is the best available and least intrusive means by which AT&T can close its significant service coverage gap in this portion of the city. 14