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City of Palo Alto (ID # 3239) City Council Staff Report Report Type: Consent Calendar Meeting Date: 11/5/2012 Summary Title: Appeal of AT&T DAS Project - Phase 2 Title: Appeal of Director’s Architectural Review Approval of the Collocation by AT&T Mobility LLC of Wireless Communications Equipment on 15 Pole- Mounted Wireless Communication Antennas and Associated Equipment Boxes on Existing Utility Poles Within City Rights-of-Ways Near the Following Locations: 528 Homer; 896 Melville; 1491 Greenwood; 1061 Fife; 1496 Dana; 697 Wildwood; 973 Embarcadero Rd; 671 Seale; 731 Lincoln; 1594 Walnut/Embarcadero side; 1280 Newell; 643 Coleridge; 401 Marlowe; 1196 Hamilton; 933 N. California. From: City Manager Lead Department: Planning and Community Environment Recommendation Staff recommends that Council uphold the Director of Planning and Community Environment’s decision to approve the Architectural Review application for 15 wireless communication facility (WCF) installations by AT&T Mobility LLC (AT&T), based upon the findings and conditions of approval described in the Record of Land Use Action (Attachment A). Executive Summary AT&T’s application is for Architectural Review of 15 wireless communication facilities (WCFs) collocated on existing utility poles within City rights-of-way and jointly owned by the City and Pacific Bell Telephone Company dba AT&T of California, known as the Palo Alto Outdoor DAS (Distributed Antenna System) project Phase 2. The 15 installations propose one antenna placed on a pole extension at the top of each pole, and equipment cabinets placed lower down on the pole face (between 10 feet and 20 feet above grade). The pole locations were reviewed regarding their aesthetic impacts and consistency with the Phase 1 design approval (Council action 01/23/12), and on September 17, 2012 the staff level Architectural Review approval was issued for the project. Staff received an appeal of this decision by a resident who cited concerns regarding the appropriate application of the Palo Alto Noise Ordinance (Title 9) and suggesting staff has not interpreted this statute correctly for the AT&T DAS projects. Background On March 6, 2012, AT&T submitted an application for Architectural Review for the Phase 2 of Outdoor Distributed Antenna System (DAS) installations at 15 locations. The project was determined to be a collocation project and, according to Palo Alto Municipal Code (PAMC) Section 18.42.110, requires approval of an Architectural Review application, followed by the issuance of encroachment permits. The use itself is considered a permitted use, such that no Conditional Use Permit (CUP) is needed. In January 2012, the Council, on appeal, reviewed the Phase 1 DAS project for 20 installations and upheld the Director’s decision to approve the project (CMR #2393). At that time the issues that were raised by the appellants focused on the need for a wireless master plan for the entire city, and concerns for aesthetic impacts, potential health risks, noise, impacts on property value, type of technology proposed, and the safety and reliability of the actual installations. These issues were discussed in the associated CMR and can be viewed online for additional details. The Council approved the applications. In addition to the Phase 1 and 2 applications, AT&T has submitted for Architectural Review of the remaining two phases of the project, for a total of 75 installations. These four phases are a part of AT&T’s build-out to provide adequate coverage and/or additional capacity for wireless communications. AT&T is subject to a license agreement that allows AT&T to collocate the DAS antennas and equipment on the City’s portion of the utility poles. The Council approved the standard license agreement on July 25, 2011 (CMR #1756). Following the Council’s decision on the Phase 1 application, subsequent Architectural Review applications for DAS installations, following the same prototype design as the approved design, were to be reviewed at staff level and be subject to public notice and Council appeal, but ARB public hearings were not to be required. Neighbor notification is provided and public comments are reviewed by staff for each location. Actions by the Director of Community Environment on the applications are posted on the City’s website and courtesy notices of the actions are mailed to neighbors within 300 feet of each pole. The Director’s decisions on staff level AR applications are also noted on the next available ARB meeting agenda. Review Process The standard procedure for the review of an appealed Architectural Review application is for placement on the Council consent calendar within 30 days of the filing of an appeal. Council can decide to pull the item off consent, only if at least three Councilmembers concur, and then the project is scheduled for a future public hearing date (PAMC 18.77.070(f)). Project Description The approved design for the DAS installations is shown in Figure 1. The existing utility poles range in height from 28 to 52 feet and the pole top extension, on average, is about 8.25 feet. The equipment proposed on the pole face is the same for all the poles and is comprised of (1) a power disconnect box located nine feet above grade; (2) a remote prism cabinet (52.4”H x 12.15”W x 10.125”D) located approximately 10’-5” above grade; (3) a back-up battery cabinet (27”H x 22”W x 18”D) located approximately 15’-9” above grade; (4) an optical network interface box (13”H x 13”W x 3.75”D) located approximately 19’ above grade; and (5) related wiring. At the top of the pole extension, one antenna radome (24”H x 16” Base Diameter) would be placed in-line with the pole. Figure 1: Approved Design Discussion Appeal The appeal of this application was submitted by Mr. Tony Kramer, a resident living on Ferne Avenue. The appeal was directed at the whole project (all 15 sites). The appellant’s stated concern is, “the Planning Department is not correctly applying the Palo Alto Noise Code (PAMC 9.10) to the AT&T DAS applications.” No installation is planned adjacent to Mr. Kramer’s home, however. Mr. Kramer is specifically concerned about the application of the residential noise standards, as opposed to the public property standards, to the AT&T DAS installations. It is his belief that the residential standards for noise should be applied to all installations, because they are within 25 feet of the private residential property. His letter is included as Attachment C of this report and provides additional background on his position. Staff Response to Appeal Issue As outlined in PAMC Section 9.10.050, the public property noise limit specifies that no person shall produce on public property a noise level more than 15 dB above the local ambient at a distance of 25 feet or more from the source. The definition of local ambient means the lowest sound level repeating itself during a six-minute period as measured with a precision sound level meter; the code specifies that the minimum sound level shall be 40 dBA when determining noise levels outside (not inside a structure), and therefore, noise production in excess of 55 dBA at a distance of 25 feet away from the source would violate the noise ordinance. The noise requirements for residential properties, as set forth in PAMC 9.10.030, is that noise levels cannot exceed six dB above the local ambient (40 dBA minimum) at the property plane. According to AT&T, the two pieces of equipment that would produce sound are the back-up battery cabinet and the prism remote. All other elements proposed (antenna and wiring) do not produce noise. On June 6, 2012, Hammett & Edison Inc. performed a noise analysis at a powered installation in front of 255 N. California Avenue. The results of this study state that the noise level produced by the equipment, including the ambient noise, is approximately 44.5 dBA at a distance of 25 feet away from the pole. Based on this data, the conclusion is that the equipment is compliant with the Noise Ordinance. The details of the noise analysis are in Attachment D. Mr. Kramer has also claimed that staff has previously indicated that the stricter residential standard would apply to the AT&T installations. Staff concurs that the initial response from the Planning Director and City Attorney’s Office was to that effect, though the discussion primarily was focused on the installation of equipment in a “public utility easement” (PUE) across private property. After further consultation with the Attorney’s office and comparison to other approvals, however, staff determined that the residential standard would apply in a PUE, since that is an easement across residential property, but is not applicable for installations in the public right-of-way or on public property, such as parkland. Staff does believe that, as indicated in the noise measurements at 255 N. California Avenue, lower noise levels (nearer the residential standard) can be readily achieved and that every effort should be made to attain the lowest level reasonable. To further address the noise concern, therefore, staff has included the following two Conditions of Approval: For installations in the City right-of-way, the Applicant shall endeavor to minimize the noise at the property line boundary with adjacent residential property, and shall attempt to keep such noise below 6dB above the ambient level most of the time, when fans are running at their normal setting. If such a standard is not reasonably achievable for a site, then the Applicant voluntarily agrees to use commercially reasonable efforts to ensure that the noise level does not exceed 6 dB above the ambient noise level at the nearest location of a residential structure. Under no circumstances shall the noise exceed the noise standard in Municipal Code 9.10.050 (i.e., +15dB over ambient at 25 feet). The applicant shall submit a sound analysis of an operating installation within two months of the project installation/operation. The analysis shall clearly delineate how the installation complies with the previously listed condition regarding noise. Applicant may be required to submit these reports periodically for the life of the project, as determined by the Director of Planning AT&T has agreed to the above conditions and has stated that it will make all feasible attempts to minimize the noise production from their installations. AT&T has now installed DAS antennas and equipment on at least five sites, including 255 North California, 464 Churchill, 1720 Webster, 370 Lowell, and 1345 Webster. Council members may wish to visit one or more of these sites to assess the noise impacts from a layperson’s standpoint. Staff has visited the sites and believes that the noise is minimal adjacent to the pole and barely audible from 25 feet away. Citywide Wireless Communications Study The City staff is pursuing a citywide communications study to identify the best approach to providing such service across the city, including the potential use of utility substation sites for wireless communications towers. A Request for Proposal is currently out to possible contractors, and proposal responses should be in within the coming week. Staff will then work with the selected vendor to report back to Council in early 2013 regarding the status and opportunities for the more comprehensive plan. The Utilities Department will also be updating the Council soon regarding its evaluation of a city wi-fi network, as recommended by the Utilities Advisory Committee. Policy Implications The proposed project is consistent with the Comprehensive Plan and staff believes there are no other substantive policy implications. The project is supported by the following Comprehensive Plan Policies: (B-13) Support the development of technologically-advanced communications infrastructure and other improvements that will facilitate the growth of emerging telecommunications industries; and (B-14) Work with electronic information network providers to maximize potential benefits for Palo Alto businesses, schools, residences, and other potential users. Resource Impacts The costs of project review by all staff and consultants is recovered by Architectural Review application fees paid by AT&T. Pursuant to the City’s standard license agreement, AT&T will pay the City $270 per year per installation, or a total of $4,050 per year for the 15 sites. Environmental Review The project is categorically exempt from the provisions of the California Environmental Quality Act (CEQA) per section 15303 of the CEQA Guidelines. Attachments: Attachment A: Record of Land Use Action (DOC) Attachment B: Location Map (PDF) Attachment C: Appeal by Tony Kramer dated October 2, 2012 (PDF) Attachment D: Hammett & Edison Noise Memorandum dated July 27, 2012 (PDF) Attachment E: Applicant's Submittal Information (PDF) Attachment F: Project Plans (hardcopies to Councilmembers and Libraries only) (TXT) Prepared By: Clare Campbell, Planner Department Head: Curtis Williams, Director City Manager Approval: ____________________________________ James Keene, City Manager 1 ACTION NO. 2012-xx RECORD OF THE COUNCIL OF THE CITY OF PALO ALTO LAND USE ACTION FOR AT&T DAS PROJECT PHASE 2: ARCHITECTURAL REVIEW 12PLN-00090 (AT&T, APPLICANT) On November 5, 2012, the Council upheld the Director of Planning and Community Environment’s September 17, 2012 decision to approve the Architectural Review application of the co-location by AT&T of (Distributed Antenna System, a.k.a. DAS) wireless communications equipment on 15 existing utility poles making the following findings, determination and declarations: SECTION 1. Background. The City Council of the City of Palo Alto (“City Council”) finds, determines, and declares as follows: A. On March 6, 2012, AT&T applied for Architectural Review for the co-location of wireless communications equipment (Distributed Antenna System) on 15 existing utility poles located within City rights-of-ways near the following locations: 528 Homer; 896 Melville; 1491 Greenwood; 1061 Fife; 1496 Dana; 697 Wildwood; 973 Embarcadero Rd; 671 Seale; 731 Fulton; 1594 Walnut/Embarcadero side; 1280 Newell; 643 Coleridge; 401 Marlowe; 1196 Hamilton; 933 N. California. The proposed equipment would include one antenna at the top of each pole and two equipment boxes on the side of each pole (“The Project”). B. On September 17, 2012, following staff review, the Director of Planning and Community Environment (Director) approved the Architectural Review (AR) application. Notices of the Director’s decision were mailed notifying neighbors of the decision. D. On October 2, 2012, within the prescribed timeframe, an appeal of the Director’s decision was filed by a resident, Mr. Tony Kramer. SECTION 2. Environmental Review. This project is exempt from the provisions of the California Environmental Quality Act per Section 15303 of the CEQA Guidelines. SECTION 3. Architectural Review Findings. 1. The design is consistent and compatible with applicable elements of the Palo Alto Comprehensive Plan. This finding can be made in the affirmative in that the project, as conditioned, incorporates a more streamlined design that conforms with policies that encourage quality development that is compatible with surrounding development and public spaces. The project is also supported by the following Comprehensive Plan Policies: (B-13) ATTACHMENT A 2 Support the development of technologically-advanced communications infrastructure and other improvements that will facilitate the growth of emerging telecommunications industries; (B-14) Work with electronic information network providers to maximize potential benefits for Palo Alto businesses, schools, residences, and other potential users. 2. The design is compatible with the immediate environment of the site. This finding can be made in the affirmative in that the proposed design, as conditioned, blends with the existing utility poles that are located within various residential neighborhoods within the City. 3. The design is appropriate to the function of the project. This finding can be made in the affirmative in that the design of the equipment is not excessive for the intended utility use and has been improved with the required conditions of approval to streamline the design with the back-up battery cabinet placed above the prism and elimination of one antenna. 4. In areas considered by the board as having a unified design character or historical character, the design is compatible with such character. This finding is not applicable to this project. 5. The design promotes harmonious transitions in scale and character in areas between different designated land uses. This finding is not applicable to this project. 6. The design is compatible with approved improvements both on and off the site. This finding can be made in the affirmative in that the project, as conditioned, is compatible with the existing utility poles. 7. The planning and siting of the various functions and buildings on the site create an internal sense of order and provide a desirable environment for occupants, visitors and the general community. This finding is not applicable to this project. 8. The amount and arrangement of open space are appropriate to the design and the function of the structures. This finding is not applicable to this project. 9. Sufficient ancillary functions are provided to support the main functions of the project and the same are compatible with the project’s design concept. This finding is not applicable to this project. 3 10. Access to the property and circulation thereon are safe and convenient for pedestrians, cyclists and vehicles. This finding can be made in the affirmative in that the circulation under and around the utility pole is not impacted. 11. Natural features are appropriately preserved and integrated with the project. This finding is not applicable to this project. 12. The materials, textures, colors and details of construction and plant material are appropriate expression to the design and function. This finding can be made in the affirmative, see Findings 2, 3, and 4 above. 13. The landscape design concept for the site, as shown by the relationship of plant masses, open space, scale, plant forms and foliage textures and colors create a desirable and functional environment. This finding can be made in the affirmative in that the project, as conditioned, will be required to plant some additional street trees at some locations. The placement and selection of the street trees will be reviewed and approved by Public Works and Utilities to assure the plantings will be consistent with City standards. 14. Plant material is suitable and adaptable to the site, capable of being properly maintained on the site, and is of a variety which would tend to be drought-resistant to reduce consumption of water in its installation and maintenance. This finding can be made in the affirmative, see Finding 13. All City street trees are regularly maintained and will use only the required amount of water needed for establishment and maintenance. 15. The project exhibits green building and sustainable design that is energy efficient, water conserving, durable and nontoxic, with high-quality spaces and high recycled content materials. This finding is not applicable to this project. The scope of the project is small and there is limited opportunity to incorporate green building design into the sign installations. 16. The design is consistent and compatible with the purpose of architectural review as set forth in subsection 18.76.020(a). This finding can be made in the affirmative in that the project design, as conditioned, promotes visual environments that are integrated into the aesthetics of the immediate environment of an industrial utility facility. SECTION 4. Architectural Review Approval Granted. Architectural Review Approval is hereby granted for the Project by 4 the City Council pursuant to Chapter 18.77 of the Palo Alto Municipal Code. SECTION 5. Plan Approval. The plans submitted for Building Permit shall be in substantial conformance with those plans prepared by AT&T titled Palo Alto ODAS, consisting of 48 pages, and received May 15, 2012, except as modified to incorporate the conditions of approval in Section 6. A copy of these plans is on file in the Department of Planning and Community Development. SECTION 6. Conditions of Approval. Planning Division 1. The project shall be in substantial conformance with the approved plans and related documents received May 15, 2012, except as modified to incorporate these conditions of approval. 2. All conditions of approval shall be printed on the cover sheet of the plan set submitted to obtain any permit through the Building Inspection Division. 3. Any modifications/additions to the approved plans shall be approved by Planning prior to construction and installation. 4. The project approval shall be valid for a period of one year from the original date of approval. In the event a building permit(s), if applicable, is not secured for the project within the time limit specified above, the approval shall expire and be of no further force or effect. 5. For all pole installations, the backup battery cabinet shall be placed above the prism box. 6. For the life of the project, the size of the battery cabinet shall be reduced as technology improves so as to maintain the smallest battery cabinet needed. 7. The antenna, cabinet boxes, and pole extension shall be painted either “Rock Brown” or “Sand Brown”, with a matte finish, to match the existing color and finish of the utility pole, and all other equipment (i.e. wiring and related hardware) shall be painted with a matte finish to blend in with the background material/color of the pole. 8. The project shall be reviewed by the Utilities Department to determine if the pole is feasible for the placement of the 5 proposed equipment and antennas. If the Utilities department does not support the placement of the equipment on the pole, the applicant shall submit a new Architectural Review application to the Planning Division for review of proposed alternative pole selection. 9. For sites that require new street tree installations, the applicant shall coordinate with the Public Works Tree Division, Utilities Department, and Transportation Division to gain approval for the placement and selection of tree type. If the City departments do not support the placement of a city tree for screening purposes for the identified locations, then that site is no longer approved for the equipment installation and the applicant shall be required to submit a new Architectural Review application to the Planning Division for review of proposed alternative pole selection. 10. The applicant, in coordination with City departments, shall (1) analyze all proposed sites to determine whether new street trees can be added in the immediate vicinity for screening purposes and (2) add additional trees where feasible. 11. The preferred selection for new street trees shall be evergreen trees, as deemed appropriate by Public Works and the Utilities department. 12. Unless the City agrees to a modification of this condition, the requirements to install new street trees shall be 100% the responsibility of the applicant and shall be completed prior to the installation of pole equipment. 13. For installations in the City right-of-way, the Applicant shall endeavor to minimize the noise at the property line boundary with adjacent residential property, and shall attempt to keep such noise below 6dB above the ambient level most of the time, when fans are running at their normal setting. If such a standard is not reasonably achievable for a site, then the Applicant voluntarily agrees to use commercially reasonable efforts to ensure that the noise level does not exceed 6 dB above the ambient noise level at the nearest location of a residential structure. Under no circumstances shall the noise exceed the noise standard in Municipal Code 9.10.050 (i.e., +15dB over ambient at 25 feet). 14. The applicant shall submit a sound analysis of an operating installation within two months of the project installation/operation. The analysis shall clearly delineate 6 how the installation complies with the previously listed condition regarding noise. Applicant may be required to submit these reports periodically for the life of the project, as determined by the Director of Planning. 15. The applicant shall perform a radio frequency (RF) analysis for each of the twenty installations to document the RF emissions for the installed and operating equipment. This analysis shall be submitted to the City within two months of the project installation/operation. Applicant may be required to submit these reports periodically for the life of the project, as determined by the Director of Planning. 16. If for any reason the project requires modification from the approved plans in any way, the applicant shall contact Planning staff for a determination on whether the change requires a new application for Architectural Review and Historic Review, if applicable, to be submitted. 17. Pole 3 (1491 Greenwood): An additional street tree shall be required to the right side of pole. 18. Pole 4 installation shall be at 1061 Fife. 19. Pole 6 (697 Wildwood): An additional street tree shall be required to the west side of pole. 20. Pole 7 installation shall be at 973 Embarcadero. 21. Pole 8 installation shall be at 671 Seale. 22. Pole 9 installation shall be at 731 Lincoln. 23. Pole 10 installation shall be at 1594 Walnut on the Embarcadero side. 24. Pole 12 (643 Coleridge): The unused pole that is proposed to be replaced is supported with the addition of one tree to screen views on the Embarcadero side. The small triangular area where a screen tree could be planted appears to be private land; AT&T will need to discuss the tree planting and maintenance with the property owner. 25. Pole 13 (401 Marlowe): An additional street tree shall be required to the east side of pole. 26. Pole 15 installation shall be at 933 N. California and battery boxes should be mounted towards the tree. 7 27. All cost recoverable charges related to this Planning entitlement process, per the cost recovery agreement, shall be paid in full and in a timely manner; these include charges for two consultants hired for peer review of this project. Non-payment may result in the withholding of other city required permits and or approvals required for the project to move forward to the construction phase. Fire Department 28. The applicant shall submit a completed copy the document entitled “Optional Checklist for Local Government to Determine Whether a Facility is Categorically Excluded.” If the applicant is required to submit an Environmental Assessment (EA) to the FCC, please indicate if it has been submitted and the date submitted. Electric Utility 29. Electric Utility shall not perform any operations and/or engineering until a Master License Agreement is signed between AT&T and the City of Palo Alto. AT&T shall not attach any equipment on the City's portion of any utility pole until the Master License Agreement is signed by both parties. The Master License Agreement will determine the procedures, policies, fees and responsibilities for DAS work on joint utility poles. SECTION 7. Indemnity. To the extent permitted by law, the Applicant shall indemnify and hold harmless the City, its City Council, its officers, employees and agents (the “indemnified parties”)from and against any claim, action, or proceeding brought by a third party against the indemnified parties and the applicant to attack, set aside or void, any permit or approval authorized hereby for the Project, including (without limitation) reimbursing the City its actual attorneys fees and costs incurred in defense of the litigation. The City may, in its sole discretion, elect to defend any such action with attorneys of its own choice. SECTION 8. Term of Approval. Architectural Review Approval. The approval shall be valid for one year from the original date of approval, pursuant to Palo Alto Municipal Code Section 18.77.090. 8 PASSED: AYES: NOES: ABSENT: ABSTENTIONS: ATTEST: APPROVED: _________________________ ____________________________ City Clerk Director of Planning and Community Environment APPROVED AS TO FORM: ___________________________ Senior Asst. City Attorney PLANS AND DRAWINGS REFERENCED: Those plans prepared by AT&T titled Palo Alto ODAS, consisting of 48 pages and received May 15, 2012. © 2010 AT&T Intellectual Property. All rights reserved. AT&T and the AT&T logo are trademarks of AT&T Intellectual Property. Page 1 •P1N2B –671 Seale Ave P1N23B –1061 Fife Ave P1N31A –1591 Walnut •P1N6A –933 California Ave P1N24A –1496 Dana Ln P1N31B –1280 Newell Rd •P1N15A -528 Homer Ave P1N26A –697 Wildwood Ln P1N33A–643 Coleridge Ave •P1N19A -1011 Channing Ave P1N27A–973 Embarcadero Rd P1N35A –401 Marlowe St. •P1N22A -1491 Greenwood Ave P1N30A –731 Lincoln Ave P1N36A –1196 Hamilton Ave Palo Alto Phase 2 Nodes e-mail: bhammett@h-e.com Delivery: 470 Third Street West • Sonoma, California 95476 Telephone: 707/996-5200 San Francisco • 707/996-5280 Facsimile • 202/396-5200 D.C. WILLIAM F. HAMMETT, P.E. DANE E. ERICKSEN, P.E. STANLEY SALEK, P.E. ROBERT P. SMITH, JR. RAJAT MATHUR, P.E. KENT A. SWISHER ANDREA L. BRIGHT ___________ ROBERT L. HAMMETT, P.E. 1920-2002 EDWARD EDISON, P.E. 1920-2009 BY E-MAIL JD3235@ATT.COM July 27, 2012 John di Bene, Esq. AT&T Mobility 4430 Rosewood Drive Pleasanton, California 94588 Dear John: As you requested, we have visited the AT&T Mobility oDAS node recently installed at 255 North California Avenue in Palo Alto, California, in order to assess the noise levels from that installation and to evaluate those actual levels against both the city's noise limit and the projected levels. On the morning of June 6, 2012, using one of our Quest Technologies Type 2200 Sound Level Meters (Serial No. SBF110001, under current calibration by the manufacturer), we observed a minimum* noise level of 44.5 dBA at a distance of 25 feet from the pole. That is the distance specified for compliance with the city's municipal code Section 9.10.050, which limits an increase in noise to 15 dBA, measured at 25 feet, for facilities not located on private property. The ambient reading at that location with the AT&T node shut off was 42.1 dBA, so the actual increase was 2.4 dBA, well below the 15 dBA allowed by the code. Removing† the 42.1 dBA ambient level from the 44.5 dBA level with the AT&T equipment turned on indicates that the equipment by itself produced noise at 25 feet of approximately 40.8 dBA. This compares well with the manufacturer's data, given in our report dated November 1, 2011, which averaged 40.9 dBA to the front and sides. Therefore, we conclude from these measurements that noise from the AT&T Mobility oDAS nodes has been accurately represented by the manufacturer and that, indeed, the noise increase easily meets the Palo Alto limits. Please let us know if any questions arise on these measurements or this analysis. Sincerely yours, William F. Hammett * Intended to represent the noise from continuous, fixed sources, separate from the varying levels due to intermittent sources including traffic, wind, voices, and planes. † Using appropriate mathematical conversions. MACKENZIE & ALBRITTON LLP 220 SANSOME STREET, 14TH FLOOR SAN FRANCISCO, CALIFORNIA 94104 TELEPHONE 415 / 288-4000 FACSIMILE 415 / 288-4010 October 29, 2012 VIA ELECTRONIC MAIL Mayor Yiaway Yeh Vice Mayor Gregory Scharff Council Members Patrick Burt, Sid Espinosa, Karen Holman, Larry Klein, Gail Price, Greg Schmid and Nancy Shepherd City Council City of Palo Alto 250 Hamilton Avenue Palo Alto, California 94301 Re: Appeal of AT&T DAS Project – Phase II 12PLN-00090 Architectural Review City Council Consent Agenda November 5, 2012 Dear Mayor Yeh, Vice Mayor Scharff and Council Members: We write to you on behalf of our client AT&T Mobility (“AT&T”) to recommend that you adopt the findings and decision of the Planning Division to approve AT&T’s distributed antenna system (“DAS”) Phase II (the “Approval”) and not remove the Approval from the Council’s November 5, 2012 consent agenda. The arguments raised in the appeal by Tony Kramer (the “Appeal”) seek to distort the clear and plain meaning of the Palo Alto Municipal Code (the “PAMC”) and have been thoroughly considered and addressed by the Planning Division in Condition 13 of the Approval. The Council should uphold the Approval without further delay, and avoid giving credence to Mr. Kramer’s tortured interpretation of the Palo Alto Noise Ordinance. I. Palo Alto Noise Ordinance It is clear from a full reading of the Palo Alto Noise Ordinance, PAMC Chapter 9.10, that noise thresholds are classified by the land use designation of the source, as follows: • PAMC §9.10.030, Residential property noise limits, limits noise produced on residential property to six dB above ambient outside of the property plane; Palo Alto City Council October 29, 2012 Page 2 of 2 • PAMC §9.10.040, Commercial and industrial property noise limits, limits noise produced on commercial or industrial property to eight dB above ambient outside of the property plane; and • PAMC §9.10.050, Public property noise limits, limits noise produced on public property to 15 dB above ambient at a distance for 25 feet or more. This plain reading – that sound levels are classified by the originating source – has been affirmed by at least three reports to the City regarding the AT&T DAS project, including: • the Staff Report for the January 23, 2012, Council approval of the AT&T DAS Phase I application (“As specified in PAMC Section 9.10.050, the public property noise limit specifies that no person shall produce on public property a noise level more than 15 dB above the local ambient at a distance of 25 feet or more from the source”) (emphasis added); • the third-party engineering report of Hammett & Edison, Inc., Consulting Engineers dated November 1, 2011 (“noise levels originating from property in the zones indicated”); and in • the peer review conducted by RCC Consulting Inc. dated May 4, 2012 (“In my opinion, the noise ordinance seems to be based on the location of the noise source … based on my interpretation of code, Section 9.10.050 would apply to DAS installation on the public right-of-way, even if located immediately next to residential property”). Basing noise thresholds on the source land use designation is internally consistent with the Noise Ordinance as well. PAMC §9.10.060(f)(2) provides differing noise origination limitations between “residential zones” and “public streets, sidewalks and parking lots.” Similarly, unique noise requirements are imposed upon street sweepers and refuse collection activity, which operate on public rights-of-way. Finally, Mr. Kramer’s tortured interpretation of the Noise Ordinance makes no sense and taken to its logical conclusion, would even prohibit casual conversation on Palo Alto sidewalks in residential zones.1 II. Approval Condition 13 Condition 13 of the Approval follows the clear and plain meaning of the Noise Ordinance consistent with prior interpretations for noise originating from public property. This condition states that “Under no circumstances shall the noise exceed the noise standard in Municipal Code 9.10.050 (i.e., +15dB over ambient at 25 feet).” This condition was further modified by Planning Division staff in cooperation with AT&T such that AT&T shall “endeavor to minimize the noise at the property line boundary with adjacent residential property, and shall attempt to keep such noise below 6dB above the 1 Under Mr. Kramer’s interpretation, a casual conversation on a sidewalk in a residential zone (estimated at 60dB) would exceed 6dB above residential ambient noise (assumed at 40 dB) immediately inside the property plane, thereby violating PAMC §9.10.030. Palo Alto City Council October 29, 2012 Page 3 of 3 ambient level.” As written, this condition continues the plain and only clear reading of the noise ordinance while providing additional voluntary concessions from AT&T to minimize noise from its facilities. Any effort to make the voluntary concessions of AT&T into a code requirement would violate the clear meaning and prior consistent interpretations of the Noise Ordinance by the City. Conclusion AT&T has made every effort to be sympathetic to Mr. Kramer’s concerns regarding noise from its DAS network. Mr. Kramer’s concerns cannot, however, justify tortured interpretations of the plain meaning and longstanding consistent interpretation of the Noise Ordinance by the City. We encourage you to avoid creating confusion by parsing words in otherwise clear ordinance language and affirm the Planning Division decision through simple approval of the consent calendar. Very truly yours, Paul B. Albritton cc: Grant Kolling, Esq. Clare Campbell New Cingular Wireless PCS, LLC Application for Development Review Permit Outside Distributed Antenna System (DAS) City of Palo Alto March 6, 2012 3 Project Description AT&T is interested in deploying an outside “distributed antenna system” (DAS) to bolster voice and data capacity in areas of the City of Palo Alto. DAS is comprised of a network of small, low power antennas, usually placed on poles, which are connected to common radio equipment within a limited geographic area. This system would fill coverage and capacity gaps within areas of the City that are experiencing high density demand for mobile wireless services. The DAS proposed by AT&T would support the development of technologically advanced communications infrastructure that will facilitate the growth of emerging wireless telecommunications industries in the City of Palo Alto. In addition, residents as well as public safety are increasingly reliant on mobile devices. Data suggests as much as 70% of all mobile calls are made inside buildings and 50% of all calls to 911 are made on mobile devices.1 The Police Department reminds residents to know where their phones are to help report crimes. Also, in the event of disasters, first responders and affected residents rely on their cell phones. The DAS system thus will help improve service coverage and reliability and thus help enhance public safety efforts within the City. AT&T’s DAS technology is capable of serving multiple carriers with very minimal equipment installation. It is AT&T’s intent that its DAS will not only meet the existing demand but also provide the infrastructure for deployment of future 4G demands. 1 National Emergency Numbers Association - “It is estimated that of the 240+ million calls that were made to 9-1-1 in 2006, at least 100 million of them were made by wireless telephone users—that’s 50 percent. This is a huge increase from nearly 4.3 million wireless 9-1-1 calls just 10 years ago, and it is anticipated that the number will continue to rise, both due to cellular and IP-based WiFi and WiMAX forms of wireless service.” 4 Scope of Work This application is for a Development Review Permit and is being proposed for the construction of the 15 (page 11) of approximately 80 (page 12) DAS nodes on existing utility poles within the City of Palo Alto. The initial application of 20 nodes has already been submitted and approved by the City. This second group of nodes will provide wireless service in the area of northeastern Palo Alto between University Ave. and N. California Ave. The exact locations of the 15 proposed nodes are depicted on exhibit 11 of this application. The remaining node locations will be applied for on separate applications to address the remaining coverage needs within the City of Palo Alto. Under Section 1.1307(b)(1) of the Federal Communication Commission’s rules; the proposed low powered wireless facilities are “categorically excluded” as they are fully compliant with FCC requirements for limiting human exposure to radio frequency (RF) energy and are identified as unlikely to cause exposure in excess of the FCC’s guidelines (page 13 - 18). Please see the attached Federal Communications Commission – Local and State Government Advisory Committee Checklist. The facility also will comply with California Public Utility Commission General Orders - 95 and 170. AT&T intends to utilize its existing infrastructure within the City to minimize the impact of deploying DAS on residents of the City of Palo Alto. The DAS system will primarily use existing underground fiber to connect the DAS nodes to the DAS radio equipment hub which is located inside the local AT&T central switching office. 5 AT&T Mobility will purchase local fiber transport from AT&T California. If AT&T California does not have fiber to any node location, it will be necessary to place new fiber and in a few instances new conduit. In these instances, new conduit will be necessary only from the nearest manhole or pole to the node; generally, this should be between 50 to 250 feet. If fiber or power is not already located in the manhole, it generally can be pulled through existing conduit without the need for additional trenching or new conduit. In an effort to minimize trenching, power and fiber can share the same trench where feasible. All of the DAS nodes will be located within the public ROW on existing utility poles. Replacement of a utilities pole will be necessary if the pole is found to be noncompliant with General Orders - 95 and 170. For utility poles that must be replaced, it will remain at the existing height unless a change is requested by AT&T California or Palo Alto Utilities. On August 4th, 2011 AT&T attended a preliminary study session for this DAS project with the Palo Alto Architectural Review Board. As a result each node locations were reviewed and aesthetics guidelines from the ARB panel were adhered to where possible. The battery cabinets were moved higher on the pole to avert it from line of sight. And where applicable, nodes were moved to avoid being in front of second story windows. Also, nodes locations were reassessed to account for maximum screening with the available foliage. (page 19 - 20) The DAS nodes consist of a remote prism antenna (which is 24 inches tall with a 16-inch diameter) that is mounted on top of the existing/replacement poles. The antenna is mounted at the top of a 6 feet tall fiber glass extension that is mounted to the top of the pole. In total, the extension will be 8 feet above the top of the utility pole in order to maintain GO95 separation. This is shown on page 21. 6 For a utility pole mounted cabinet design, a 10 inches high by 5.5 inches wide by 5 inches deep quick disconnect, a 11 inches high by 4 inches wide by and 3/8 inches deep ground bus bar mounted 9 feet above the ground line. Above that sits a Tyco remote cabinet that is 52.4 inches tall by 12.2 inches deep by 11.2 inches wide. And above that is the Alpha battery cabinet that is 27 inches high by 22 inches wide by 18 inches deep. Lastly, above that is a demark box that is 13 inches tall by 13 inches wide by 3.75 inches deep. This is shown on page 30. All the attached equipment is configured such that it blends into the width of the pole. Equipment is tan/beige, and designed to blend in with equipment usually found in the streetscape. Two of the cabinets produce measureable acoustical results. Both have theoretical maximum acoustical performance of 46dB, without isolating ambient noise from the environment, at a distance of 20 feet, which is a rough approximation of the typical distance from a user on the ground. AT&T Mobility expects the actual acoustical performance of the cabinet to be quieter than these theoretical maximums. Description of Construction The antenna structure installation may involve the removal and replacement of the utility poles. A new foundation will be excavated (size dependent on soil conditions), and conduits containing coaxial cables (from the Remote cabinet), and power. Trenching will typically extend to a depth of 36 inches below grade. The following is a description of the work involved in the installation of the Myers cabinet and ground mounted remote. The typical sequence for construction of these nodes will be as follows: 7 · Remote & Myers cabinet excavation and trenching -- An excavation will be made via backhoe to accommodate the proposed concrete slab for the equipment/meter cabinet with trenching from the cabinet location to the pole(s) and/or power connection point, as necessary. An additional trunk will haul and hold supplies. Excavated material will be exported from the site using a dump truck. Backhoe and dump truck will be manned and idling throughout the excavation process and then turned off; generator on truck will run during construction. · Utility pole replacement -- The existing foundation will be removed and replaced with new foundation adequate for new pole installation. · Electrical Installation -- Once conduit and cabinet are in place, cables will be installed to connect the new cabinet to the serving manhole. The power panel will be set by an electrical contractor. SCE will then be called to set the power meter. · Testing -- Final testing of cabinet equipment and antennas will be performed after electrical power is provided to the site. · Duration and Estimated Personnel -- Typical duration for active construction of each node will be 10 days with 2 trucks and 1-3 workers, with traffic control and Department of Transportation approvals required for lane closures associated with trenching, excavation of pad and caisson foundations, and setting of the pole. 8 NORTH PALO ALTO Polygon1 Existing Coverage In-Building Service In-Transit Service Outdoor Service Legend Existing Site City Boundary 9 NORTH PALO ALTO Polygon1 Proposed (Top) Coverage In-Building Service In-Transit Service Outdoor Service Legend Existing Site City Boundary 10 Palo Alto DAS all forecasted Nodes 0 0.4 0.8 1.2 1.6 20.2 Miles PALO ALTO 280 280 101 101 82 114 109 82 MI D D L E F I E L D R D AL M A S T SAN D H I L L R D OR E G O N E X P Y EMBARCADERO RD CO U N T Y R O U T E G 3 UNI V E R S I T Y A V E W B A Y S H O R E R D JU N I P E R O S E R R A B L V D FOOT H I L L E X P Y SA N A N T O N I O A V E SAN T A C R U Z A V E FA B I A N W A Y GA R C I A A V E PU L G A S A V E CHAR L E S T O N R D AMPHITH E A T R E P K W Y E B A Y S H O R E R D W M I D D L E F I E L D R D N S H O R E L I N E B L V D AR A S T R A D E R O R D OLD M I D D L E F I E L D W A Y E CHA R L E S T O N R D W C H A R L E S T O N R D BA Y S H O R E P K W Y AL M A S T OR E G O N E X P Y FO O T H I L L E X P Y CO U N T Y R O U T E G 3 CHAR L E S T O N R D Legend Polygon 1 Polygon 2 City Bounds 1212 13 14 15 16 FCC Radio Frequency Protection Guide FCC Guidelines Figure 1 Frequency (MHz) 1000 100 10 1 0.1 0.1 1 10 100 103 104 105 Occupational Exposure Public Exposure PCS CellFMPo w e r De n s i t y (m W / c m 2 ) The U.S. Congress required (1996 Telecom Act) the Federal Communications Commission (“FCC”) to adopt a nationwide human exposure standard to ensure that its licensees do not, cumulatively, have a significant impact on the environment. The FCC adopted the limits from Report No. 86, “Biological Effects and Exposure Criteria for Radiofrequency Electromagnetic Fields,” published in 1986 by the Congressionally chartered National Council on Radiation Protection and Measurements (“NCRP”). Separate limits apply for occupational and public exposure conditions, with the latter limits generally five times more restrictive. The more recent standard, developed by the Institute of Electrical and Electronics Engineers and approved as American National Standard ANSI/IEEE C95.1-2006, “Safety Levels with Respect to Human Exposure to Radio Frequency Electromagnetic Fields, 3 kHz to 300 GHz,” includes similar limits. These limits apply for continuous exposures from all sources and are intended to provide a prudent margin of safety for all persons, regardless of age, gender, size, or health. As shown in the table and chart below, separate limits apply for occupational and public exposure conditions, with the latter limits (in italics and/or dashed) up to five times more restrictive: Frequency Electromagnetic Fields (f is frequency of emission in MHz) Applicable Range (MHz) Electric Field Strength (V/m) Magnetic Field Strength (A/m) Equivalent Far-Field Power Density (mW/cm2) 0.3 – 1.34 614 614 1.63 1.63 100 100 1.34 – 3.0 614 823.8/ f 1.63 2.19/ f 100 180/ f2 3.0 – 30 1842/ f 823.8/ f 4.89/ f 2.19/ f 900/ f2 180/ f2 30 – 300 61.4 27.5 0.163 0.0729 1.0 0.2 300 – 1,500 3.54 f 1.59 f f /106 f /238 f/300 f/1500 1,500 – 100,000 137 61.4 0.364 0.163 5.0 1.0 Higher levels are allowed for short periods of time, such that total exposure levels averaged over six or thirty minutes, for occupational or public settings, respectively, do not exceed the limits, and higher levels also are allowed for exposures to small areas, such that the spatially averaged levels do not exceed the limits. However, neither of these allowances is incorporated in the conservative calculation formulas in the FCC Office of Engineering and Technology Bulletin No. 65 (August 1997) for projecting field levels. Hammett & Edison has built those formulas into a proprietary program that calculates, at each location on an arbitrary rectangular grid, the total expected power density from any number of individual radio sources. The program allows for the description of buildings and uneven terrain, if required to obtain more accurate projections. 17 RFR.CALC™ Calculation Methodology Assessment by Calculation of Compliance with FCC Exposure Guidelines Methodology Figure 2 The U.S. Congress required (1996 Telecom Act) the Federal Communications Commission (“FCC”) to adopt a nationwide human exposure standard to ensure that its licensees do not, cumulatively, have a significant impact on the environment. The maximum permissible exposure limits adopted by the FCC (see Figure 1) apply for continuous exposures from all sources and are intended to provide a prudent margin of safety for all persons, regardless of age, gender, size, or health. Higher levels are allowed for short periods of time, such that total exposure levels averaged over six or thirty minutes, for occupational or public settings, respectively, do not exceed the limits. Near Field. Prediction methods have been developed for the near field zone of panel (directional) and whip (omnidirectional) antennas, typical at wireless telecommunications base stations, as well as dish (aperture) antennas, typically used for microwave links. The antenna patterns are not fully formed in the near field at these antennas, and the FCC Office of Engineering and Technology Bulletin No. 65 (August 1997) gives suitable formulas for calculating power density within such zones. For a panel or whip antenna, power density S = 180 BW 0.1 Pnet D2 h , in mW/cm2, and for an aperture antenna, maximum power density Smax = 0.1 16 Pnet h2 , in mW/cm2, where BW = half-power beamwidth of the antenna, in degrees, and Pnet = net power input to the antenna, in watts, D = distance from antenna, in meters, h = aperture height of the antenna, in meters, and = aperture efficiency (unitless, typically 0.5-0.8). The factor of 0.1 in the numerators converts to the desired units of power density. Far Field. OET-65 gives this formula for calculating power density in the far field of an individual RF source: power density S = 2.56 1.64 100 RFF2 ERP 4 D2 , in mW/cm2, where ERP = total ERP (all polarizations), in kilowatts, RFF = relative field factor at the direction to the actual point of calculation, and D = distance from the center of radiation to the point of calculation, in meters. The factor of 2.56 accounts for the increase in power density due to ground reflection, assuming a reflection coefficient of 1.6 (1.6 x 1.6 = 2.56). The factor of 1.64 is the gain of a half-wave dipole relative to an isotropic radiator. The factor of 100 in the numerator converts to the desired units of power density. This formula has been built into a proprietary program that calculates, at each location on an arbitrary rectangular grid, the total expected power density from any number of individual radiation sources. The program also allows for the description of uneven terrain in the vicinity, to obtain more accurate projections. 18 FID Design_Sta Site Sector Node_numCNU_NUM Lat_Pole Long_Pole Pole_Ht PA_Pole_no Locations Fielding Notes 13 in-design 2 A N15A CCU1331 37.446331 -122.155006 48' 5267 520 Homer Ave near Cowper Ave Feasible - Channing House Health Care Center under construction (2 stories). No tree screening. Equipment streetside. alternate 2 A N15A CCU1331 37.446148 -122.155241 5270 Side of 803 Cowper (on Homer Ave) Probably not feasible - End pole. Small deciduous street trees to rt and left. Small 2nd story window. Pole probably too full. Not adequate climbing space. No more poles SW of this. alternate Not feasible 2 A N15A CCU1331 Not Feasiible Not Feasiible 5266 520 Homer Ave near Cowper Ave Not feasible - Channing House Health Care Center under construction (2 stories). No tree screening. 60 AZM blocked by tall residential Channing House. alternate Not feasible 2 A N15A CCU1331 Not Feasiible Not Feasiible 5265 Side of 850 Webster (on Homer Ave)Not feasible - Blocked by Channing House and trees. 17 in-design 2 A N19A CCU1331 37.448408 -122.146441 42' 5120 875/895 Melville Ave near Channing Ave Feasible - On property line. Screened by evergreens from left and rear. 2nd story window, but screened by trees. Equipment streetside. alternate Not feasible 2 A N19A CCU1331 Not Feasiible Not Feasiible 5119 895 Melville (corner of Channing Ave)Not feasible - On corner. Trees blocking antennas. Cable box on side. alternate 2 A N19A CCU1331 Not Feasiible Not Feasiible 5118 1011 Channing Ave Feasible with pole replacement - Guy pole. Too short. Screened. No 2nd story window. Could only work if replace with 50' pole. alternate Not feasible 2 A N19A CCU1331 Not Feasiible Not Feasiible 5122 869 Melville Ave Not feasible - Antennas blocked by pine tree. 2nd story window. alternate Not feasible 2 A N19A CCU1331 Not Feasiible Not Feasiible 5123 863 Melville Ave Not feasible - Antennas blocked by pine tree. 2nd story window. 20 in-design 2 B N22A CCU1331 37.447890 -122.139826 42' 5156 1491 Greenwood Ave @ Newell Rd Feasible - One deciduous street tree on left (S). No second story window. Equip streetside. alternate Not feasible 2 B N22A CCU1331 37.448238 -122.139846 5155 930 Newell Rd Not feasible - Redwood behind would block 300 AZM. alternate 2 B N22A CCU1331 37.447521 -122.139845 5157 1010 Newell Rd Feasible - Mature deciduous street tree on right (N). No 2nd story window. alternate 2 B N22A CCU1331 37.447222 -122.139722 5158 1050 Newell Rd Feasible - Mature deciduous street tree on right (N). No 2nd story window. 21 in-design 1 A N23B CCU1331 37.451381 -122.148860 38' 5905 991 Addison Ave near Fife Ave Feasible - Between properties. No 2nd story window. Tree on S side but not tall enough to provide screening. Equipment could fit under the streetlight on street side. alternate 1 A N23B CCU1331 37.451608 -122.148886 5885 1091 Fife Ave Feasible - Trees screen from W, N and E. Partially screened second story across the street. Equipment could go streetside under streetlight. alternate 1 A N23B CCU1331 37.451600 -122.148529 5883 1115 Fife Ave Feasible - No tree screening and no room to add tree. No 2nd story window. Equipment could go on S or E side of pole. alternate 1 A N23B CCU1331 37.451608 -122.149395 5887 1061 Fife Ave Feasible - 2nd story window across the street. Screened by Magnolia on E side. Equipment to go streetside. Would have to move riser to make room to attach. alternate Not feasible 1 A N23B CCU1331 37.450916 -122.148889 5906 971 Addison Not feasible - Tree blocks 210 sector. Equipment not screened. Screened 2nd story window across the street. 22 in-design 1 B N24A CCU1331 37.451500 -122.138589 43' 5002 Side of 1496 Dana, across from 705 Newell Rd Feasible - Tree behind pole, Equipment in front. No 2nd story. Pole is by garage and between houses. Trees across street. alternate 1 B N24A CCU1331 37.452011 -122.138280 5001 670 Newell Feasible - Corner pole, but 20' back from corner. Across street from 2nd story window. Tree on north side of pole. alternate 1 B N24A CCU1331 37.451315 -122.138729 7062 1499 Kings Lane side (on Newell) Feasible - No 2nd story, no trees by pole. Equipment on west side of pole (toward corner). No place for tree because of corner and guy wires. alternate 1 B N24A CCU1331 37.450921 -122.138984 5004 1498 Kings Lane side (on Newell) Feasible - Screened by deciduous street trees in both directions, equipment on street side. On side of and between properties. Best back- up. 24 in-design 1 C N26A CCU1331 37.448356 -122.127112 38' 4340 Side of 697 Wildwood Ln (on Channing) Feasible - Have to replace pole. Already has an extension. Between properties. No 2nd story. Evergreen screening from E. Place equipment on W (left side). alternate Not feasible 1 C N26A CCU1331 Not available Not available Rear of 693 Wildwood Ln Not feasible - Pole in yard. No access. alternate Not feasible 1 C N26A CCU1331 Not available Not available Rear of 703 Wildwood Ln Not feasible - Pole in yard. No access. 25 in-design 1 C N27A CCU1331 37.445766 -122.130796 43' 4447 985 Embarcadero Rd Feasible - Screened from N, E and W. Well screend from 2nd story window. Equipment on NW side of pole. alternate 1 C N27A CCU1331 37.445925 -122.130291 4446 993 Embarcadero Rd Feasible - Cable Box. Screened from N by Oak and E by mature evergreen tree. No 2nd story window. Equipment on streetside (S) of pole alternate 1 C N27A CCU1331 37.445623 -122.131351 4448 973 Embarcadero Rd Feasible - Between properties. No 2nd story window. Mature evergreen trees on N and S side. Equipment on street side. 1 in-design 2 C N2B CCU1331 37.439269 -122.139951 42' 5" 4662 655 Seale Feasible - Mature deciduous street tree on right. No 2nd story window. alternate 2 C N2B CCU1331 37.439293 -122.139986 4661 651 Seale Feasible - End pole. Deciduous street trees on both sides and pine tree behind. No 2nd story. alternate 2 C N2B CCU1331 37.439093 -122.140188 4663 627 Seale Feasible - No tree screening. 2nd story house next store, but set back behind front section of house. 28 in-design 2 A N30A CCU1331 37.446718 -122.148728 53' 5981 1061 Fulton St @ Lincoln Ave Feasible - Corner pole with plenty of space. Screened on rt and left with deciduous trees. Equipment streetside on Fulton. alternate Not feasible 2 A N30A CCU1331 37.446955 -122.148493 5991 Side of 1061 Fulton (on Lincoln) Borders 1090 Lincoln Not feasible - Pine tree blocks antennas. alternate 2 A N30A CCU1331 37.447214 -122.148248 5965 1090 Guinda St. Feasible - Corner pole with 2nd story window across street. Mature deciduous tree on left (south) side. alternate 2 A N30A CCU1331 37.446389 -122.149167 5990 731 Lincoln Ave Feasible - Deciduous trees on all sides. 2nd story window across street. 29 in-design 2 C N31A CCU1331 37.443233 -122.139106 52' 4617 1806 Mark Twain St. (on Embarcadero)Feasible - Evergreen street tree to left. No 2nd story. alternate 2 C N31A CCU1331 37.443413 -122.138449 4618 836 Embarcadero Rd (Corner of Emb and Mark Twain) Feasible - Evergreen street tree to left (east). No 2nd story window. Art Center and Library across street, set back. alternate 2 C N31A CCU1331 37.443137 -122.139428 4616 816 Embarcadero Rd (25' from corner of Newell) Feasible - 25' from corner. No 2nd story window (dormer only). Art Center and Library across street, set back. 10 original candidate 2 B N31B CCU1331 37.444572 -122.139812 43 5165 1497 Hopkins Ave - Corner of Newell Rd Feasible - Corner pole not preferred by Planning. On corner by Rinconada Park Tennis Courts and power substation. PA Main Library across the street. Equipment placed under streetlight. in-design 2 B N31B CCU1331 37.444568 -122.140333 42' 8" 5183 1497 Hopkins Ave Feasible - Not corrner, in front of tennis court, substation across the street. Decid street trees to rt and left and redwoods across street, and not in direction of intended coverage (AZM 280 only). alternate Not feasible 2 B N31B CCU1331 37.444669 -122.139721 5166 1213 Newell Rd. Not feasible - In front of Palo Alto Main Library. 25' guy pole located within the branches of large deciduous tree which would block coverage. alternate 2 B N31B CCU1331 37.444410 -122.139869 7423 Side of 1498 Hopkins Ave. On Newell 15' frm corner Feasible - on Newell 15' from corner. Adjacent to power substation and tennis courts. Across the street from Main library. No adjacent house. Alternative Aesthetics Fielding Analysis 19 Alternative Aesthetics Fielding Analysis alternate Not feasible 2 B N31B CCU1331 37.444333 -122.139877 5167 Side of 1498 Hopkins Ave. Not feasible - No room to attach at top. In front of substation, so no adjacent house. Large tree for screening. 30 in-design 2 C N33A CCU1331 37.441983 -122.143388 22' 6" 27Embarcadero Rd & Middlefield Rd (opposite 668 Coleridge) Feasible - Pole away from house with screening to north and west. House has 2nd story window, but not close. Pole is only 25' high and RF requires 40'. Pole will have to be replaced. alternate Not feasible 2 NPL N33A CCU1331 37.441983 -122.143388 5433 643 Coleridge Ave Not Feasible - Redwoods behind block 300 AZM. Pole adjacent to sideyard about 50' from house. alternate 2 NPL N33A CCU1331 37.442004 -122.143495 5406 Side of 643 Coleridge Ave - on Embarcadero Feasible - No tree screening. 300 AZM faces tall redwood across street. Not sure if is an RF issue. PA sub-transmission pole (No ATT). 32 original candidate 1 A N35A CCU1331 37.457016 -122.150827 56' 6" 6122 Palo Alto Ave (side of 400 Marlowe St) Feasible - House to on south side ot the pole w/ visible 2nd story window. Attach to N side of pole. Some tree screening on east side of pole. in design 1 A N35A CCU1331 37.457089 -122.150427 44' 1" 6123 Across from side of 400 Marlowe St on Palo Alto Ave. Feasible - On Palo Alto Ave., adjacent to (on south side of) creek. Not in front of a house. Trees on 3 sides. Attach to west side to preserve climbing space. Streetlight and transformer on the pole. alternate 1 A N35A CCU1331 37.457097 -122.151232 6120 1184 Palo Alto Ave. Feasible - No tree cover. Not directly adjacent to a house. Equipment could go on N or E side. alternate Not feasible 1 A N35A CCU1331 37.457223 -122.151239 6121 Across from 1184 Palo Alto Ave. Not feasible - Guyed pole supporting 6120. Would have to remove top of oak to use the pole and replace with taller pole. Tree blocking antenna coverage. alternate Not feasible 1 A N35A CCU1331 37.456476 -122.150528 6124 456 Marlowe St. Not feasible - No room to attach. No tree cover. 2nd story window across the street. 33 in-design 1 A N36A CCU1331 37.454153 -122.146945 43' 6" 5850 Side of 1196 Hamilton Ave @ Lincoln Ave Feasible - Set back 30' from corner. Screened on 3 sides by trees. No adjacent 2nd story window. alternate Not feasible 1 A N36A CCU1331 37.453986 -122.147003 25'?Side of 1196 Hamilton Ave @ Lincoln Av (next pole to S) Not feasible - Old pole w/ no significant attachments, probably to be removed. No pole number or readable markings. Too short. alternate Not feasible 1 A N36A CCU1331 37.453832 -122.147014 1245 1187 Lincoln Ave. Not feasible - Some tree screening but there is cable box on pole and no room to attach our equipment. Between two houses. alternate Not feasible 1 A N36A CCU1331 37.453515 -122.147007 5856 1145 Lincoln Ave Not feasible - One deciduous tree screening from north. Between properties. Climbing space is all taken up on pole. Not feasible unless conduits can be moved. 5 original candidate 1 C N6A CCU1331 37.443041 -122.131179 42' 4469 917 N California Ave near Louis Rd Feasible - Screened on both sides by magnolias w/ deciduous tree behind. 2nd story window behind, but mostly screened by trees. Equipment on left. in-design 1 C N6A CCU1331 37.442816 -122.131445 41' 4470 Side of 2181 Louis (on N California) Feasible - Good screening by hedge in back. No 2nd story window. Equipment streetside. Might have to move conduit to accommodate equipment. Best candidate. alternate 1 C N6A CCU1331 37.443316 -122.130950 4468 Side of 2170 Bellview Dr (on N California) Feasible - No tree screening, 2nd story window, 25' from corner. Equipment on rt. alternate 1 C N6A CCU1331 37.443653 -122.130619 4467 933 N. California Ave Feasible - Screened by magnolia tree on left that encompasses pole. No 2nd story window. Equipment on street. Good back-up candidate. 20 PRISM REMOTE INSTALLATION !"# $ % & ' % & & ( # $ %'& ) % * & * % & % # & + + $ % & & , & % % & % - - % #!$& % . %' / & % & /0 1 2 1 3 4 5 6 1 7 6 8 9 :;1 <2 :6 1 =2 5 >7 0 1 8 7 0?@ A>7 0 B >5 C C D 6 :>7 0 :5 6 2 :6 1 =2 5 >7 0 1 8 7 0?E A ******PROPRIETARY INFORMATION****** NOT FOR USE OR DISCLOSURE OUTSIDE OF ADC TELECOMMUNICATIONS OR THEIR CUSTOMERS FGHIIJJJKLJGJLMNOGPQOKRGHIS JT U V W X X Y Y Y Z [Y V Y [\]^V _`^Z a V W X b Y c 50 ' - 0 " 6' 6 " 43 ' - 6 " 21 ' - 1 0 " 12 ' - 4 " 12 ' - 4 " 2'-0" 1'- 0 " 4" U GUARD EXOTHERMIC (CAD) WELD TO GROUND ROD 10'-0" 9'- 0 " 20 ' - 8 7 / 8 " QUAD BAND/ QUAD BAND BATTERY CABINET-ALPHA MMOE 24 ' - 1 / 8 " 24 ' - 1 1 7 / 8 " d e f ghijklmnoplq DUAL BAND X-POL TRI-SECTOR ANTENNArstuvswvx y w z {|}~ € ‚|}‚{ ƒ ‚„}‚|{ …†‡ˆr€‡v v x w x ‰y…x x s ‰r u Š ‹‡y y w s Œ‹‡ Ž ‰rz| € || ƒ ‚ …† ‘ƒr ’‰r u ‚~„„„„{„ ’‚“”•–—˜™š –›œ š ž Ÿ Ÿ ¡›¢£¤–¥¦™— §¥¥™§¥¨™š© ª‰‡…‹‡«…¬’r x ˆy st’u w y x s ‡«y w ««‡z |~ € ‚‹‡u w…t ‡v w y w s †x r yt ‡ˆ«w yƒx s Ž t «y w s‘‡ w z ‚® € ‚® ƒ ®} { …†r ¯°w r s x ±t…w…v w y w s‹‡u w z ‚ € ²}{ ƒ …†¯s x ‰«…‹‡s z ‚‚ € ~ ƒ ®Š …†Ž ‚ ‚{Ž y u y ‡«…x‘‘rt r w v x ‰«yz®€ |~ ƒ |®Š x…†Ž ³´µ ¶·¸ ¹‡¹´·¹¹³v º»¹´z |„ € ‚‚ ƒ† 52 ' - 3 " CABLE GAUGE BETWEEN UTILITY POLE GROUND BAR AND GROUND ROD #2 AWG SOLID PLACED IN LIQUID TIGHT NON METALIC CONDUIT COAXIAL CABLE WILL BE ½” FOR ALL RUNS >/= 1'-0" 5" x 5 " F I B E R G L A S S E X T E N S I O N 6'- 0 " 6" 21 6500 Note Only Page 1