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HomeMy WebLinkAbout2026-10-15 Architectural Review Board Agenda PacketARCHITECTURAL REVIEW BOARD Regular Meeting Thursday, October 15, 2026 Council Chambers & Hybrid 8:30 AM Amended Agenda Amended Agenda Items Appear Below in RED   Architectural Review Board meetings will be held as “hybrid” meetings with the option to attend by teleconference/video conference or in person. To maximize public safety while still maintaining transparency and public access, members of the public can choose to participate from home or attend in person. Information on how the public may observe and participate in the meeting is located at the end of the agenda. Masks are strongly encouraged if attending in person. The meeting will be broadcast on Cable TV Channel 76, live on YouTube https://www.youtube.com/c/cityofpaloalto, and streamed to Midpen Media Center https://midpenmedia.org. Visit https://bit.ly/PApendingprojects to view project plans and details. Board member names, biographies, and archived agendas and reports are available at https://bit.ly/paloaltoARB. VIRTUAL PARTICIPATION CLICK HERE TO JOIN (https://cityofpaloalto.zoom.us/j/96561891491) Meeting ID: 965 6189 1491 Phone: 1(669)900-6833   PUBLIC COMMENTS General Public Comment for items not on the agenda will be accepted for up to three minutes or an amount of time determined by the Chair. In-person comments will be heard at the beginning of the agenda and remote comments will be heard at the end of the agenda. All requests to speak will be taken until 5 minutes after the staff’s presentation. Written public comments can be submitted in advance to arb@PaloAlto.gov and will be provided to the Board and available for inspection on the City’s website three days before the meeting. Please clearly indicate which agenda item you are referencing in your subject line. Spokespersons that are representing a group of five or more people who are identified as present at the meeting at the time of the spokesperson's presentation will be allowed up to fifteen (15) minutes at the discretion of the Chair, provided that the non-speaking members agree not to speak individually. The Chair may limit Public Comments to thirty (30) minutes for all combined speakers. The Chair may reduce the allowed time to speak for Study Sessions and Action Items to two (2) minutes or less to accommodate a larger number of speakers. PowerPoints, videos, or other media to be presented during public comment are accepted only by email to arb@PaloAlto.gov at least 24 hours prior to the meeting. Once received, the Clerk will have them shared at public comment for the specified item. To uphold strong cybersecurity management practices, USB’s or other physical electronic storage devices are not accepted. Signs and symbolic materials less than 2 feet by 3 feet are permitted provided that: (1) sticks, posts, poles or similar/other type of handle objects are strictly prohibited; (2) the items do not create a facility, fire, or safety hazard; and (3) persons with such items remain seated when displaying them and must not raise the items above shoulder level, obstruct the view or passage of other attendees, or otherwise disturb the business of the meeting.  1 Regular Meeting October 15, 2026 Materials related to an item on this agenda submitted to the Board after distribution of the agenda packet are available for public inspection at  www.paloalto.gov/agendas.   CALL TO ORDER/ ROLL CALL   AGENDA CHANGES, ADDITIONS AND DELETIONS The Chair or Board majority may modify the agenda order to improve meeting management.   IN-PERSON PUBLIC COMMENT Members of the public may speak to any item NOT on the agenda. 1-3 minutes depending on number of speakers. In-person comments will be heard at the beginning of the agenda and remote comments will be heard at the end of the agenda.   CITY OFFICIAL REPORTS   1.Director's Report, Meeting Schedule, and Upcoming Agenda Items ACTION ITEMS Public Comment is Permitted. Applicants/Appellant Teams: Ten (10) minutes, plus ten (10) minutes rebuttal. All others: Three (3) minutes per speaker. 2.PUBLIC HEARING / QUASI-JUDICIAL. 250 Hamilton Avenue [26PLN-00229]. Request by AT&T for Review of Two Tier 2 General Wireless Communication Facilities to Collocate New Antennas, Remote Radio Units (RRUs), Seven-Foot Fiberglass Pole Extensions and Associated Equipment on Existing City-Owned Wood Utility Poles in the Public Right-of- Way (ROW) Near 670 Guinda Street and 754 Homer Avenue. CEQA Status: Exempt Pursuant to California Environmental Quality Act (CEQA) Guideline Section 15301 (Existing Facilities). Zoning District: Not Applicable (Public ROW). Supplemental Report Added APPROVAL OF MINUTES Public Comment is Permitted. Three (3) minutes per speaker. 3.Draft Architectural Review Board Meeting Minutes for August 20, 2026 4.Draft Architectural Review Board Meeting Minutes for September 3, 2026 BOARD MEMBER QUESTIONS, COMMENTS, ANNOUNCEMENTS OR FUTURE MEETINGS AND AGENDAS Members of the public may not speak to the item(s).   VIRTUAL PUBLIC COMMENT Members of the public may speak to any item NOT on the agenda. 1-3 minutes depending on number of speakers. In-person comments will be heard at the beginning of the agenda and remote comments will be heard at the end of the agenda.  2 Regular Meeting October 15, 2026 Materials related to an item on this agenda submitted to the Board after distribution of the agenda packet are available for public inspection at  www.paloalto.gov/agendas.   ADJOURNMENT   INFORMATIONAL REPORT The materials below are provided for informational purposes, not for action or discussion during this meeting’s agenda. Written public comments may be submitted in advance and will be provided to the Commission and available for public inspection on the City’s website three days before the meeting. A.Public Comments    3 Regular Meeting October 15, 2026 Materials related to an item on this agenda submitted to the Board after distribution of the agenda packet are available for public inspection at  www.paloalto.gov/agendas.   PUBLIC COMMENT INSTRUCTIONS Members of the Public may provide public comments to teleconference meetings via email, teleconference, or by phone. 1.Written public comments may be submitted by email to arb@PaloAlto.gov. 2.Spoken public comments using a computer will be accepted through the teleconference meeting. To address the Board, click on the link below to access a Zoom-based meeting. Please read the following instructions carefully. ◦You may download the Zoom client or connect to the meeting in- browser. If using your browser, make sure you are using a current, up-to-date browser: Chrome 30, Firefox 27, Microsoft Edge 12, Safari 7. Certain functionality may be disabled in older browsers including Internet Explorer. ◦You may be asked to enter an email address and name. We request that you identify yourself by name as this will be visible online and will be used to notify you that it is your turn to speak. ◦When you wish to speak on an Agenda Item, click on “raise hand.” The Clerk will activate and unmute speakers in turn. Speakers will be notified shortly before they are called to speak. ◦When called, please limit your remarks to the time limit allotted. A timer will be shown on the computer to help keep track of your comments. 3.Spoken public comments using a smart phone will be accepted through the teleconference meeting. To address the Board, download the Zoom application onto your phone from the Apple App Store or Google Play Store and enter the Meeting ID below. Please follow the instructions above. 4.Spoken public comments using a phone use the telephone number listed below. When you wish to speak on an agenda item hit *9 on your phone so we know that you wish to speak. You will be asked to provide your first and last name before addressing the Board. You will be advised how long you have to speak. When called please limit your remarks to the agenda item and time limit allotted. CLICK HERE TO JOIN Meeting ID: 965 6189 1491 Phone: 1-669-900-6833 Americans with Disability Act (ADA) It is the policy of the City of Palo Alto to offer its public programs, services and meetings in a manner that is readily accessible to all. Persons with disabilities who require materials in an appropriate alternative format or who require auxiliary aids to access City meetings, programs, or services may contact the City’s ADA Coordinator at (650) 329-2550 (voice) or by emailing ada@PaloAlto.gov. Requests for assistance or accommodations must be submitted at least 24 hours in advance of the meeting, program, or service.  4 Regular Meeting October 15, 2026 Materials related to an item on this agenda submitted to the Board after distribution of the agenda packet are available for public inspection at  www.paloalto.gov/agendas.   Item No. 1. Page 1 of 2 Architectural Review Board Staff Report From: Planning and Development Services Director Lead Department: Planning and Development Services Meeting Date: October 15, 2026 Report #: 2610-6847 TITLE Director's Report, Meeting Schedule, and Upcoming Agenda Items RECOMMENDATION Staff recommends the Architectural Review Board (ARB) review and comment as appropriate. BACKGROUND This document includes the following items: ARB meeting schedule Upcoming ARB agenda items Recently submitted and pending projects subject to ARB review Board members are encouraged to contact Samuel Tavera (Samuel.Tavera@PaloAlto.gov) to notify staff of any planned absences one month in advance, if possible, to ensure the availability of an ARB quorum. Approved projects can be found by property address, date, or application type on the Palo Alto Permit View webpage: https://www.paloalto.gov/Departments/Planning-Development- Services/Development-Services/Palo-Alto-Permit-View. Any party, including the applicant, may request a hearing by the ARB on the proposed director’s decision(s) within the 10-day or 14-day appeal period by filing a written request with the planning division. There shall be no fee required for requesting such a hearing. However, there is a fee for appeals. Pursuant to 18.77.070(b)(5) any project relating to the installation of cabinets containing communications service equipment or facilities, pursuant to any service subject to Palo Alto Municipal Code Chapter 2.11, Chapter 12.04, Chapter 12.08, Chapter 12.09, Chapter 12.10, or Chapter 12.13 is not eligible for a request for hearing by any party, including the applicant. No action is required by the ARB for this item. Item 1 Item 1 Staff Report     Packet Pg. 5     Item No. 1. Page 2 of 2 UPCOMING ARB AGENDA ITEMS The following items are tentative and subject to change: Meeting Date Topics November 5, 2026 156 California Avenue RECENTLY SUBMITTED PROJECTS No new ARB projects were submitted since the last meeting. ATTACHMENTS Attachment A: 2026 Meeting Schedule & Assignments Attachment B: Draft 2027 Meeting Schedule & Assignments ARB Liaison1 & Contact Information   Steven Switzer, Senior Historic Planner   (650) 329-2321   Steven.Switzer@PaloAlto.gov 1 Emails can be sent directly to the ARB at the following email: ARB@PaloAlto.gov Item 1 Item 1 Staff Report     Packet Pg. 6     Architectural Review Board 2026 Meeting Schedule & Assignments 1 2 4 8 3 2026 Meeting Schedule Meeting Dates Time Location Status Planned Absences 1/1/2026 8:30 AM Hybrid Cancelled 1/15/2026 8:30 AM Hybrid Regular Adcock, Hirsch 2/5/2026 8:30 AM Hybrid Cancelled 2/19/2026 8:30 AM Hybrid Cancelled 3/5/2026 8:30 AM Hybrid Regular 3/19/2026 8:30 AM Hybrid Regular 4/2/2026 8:30 AM Hybrid Cancelled Rosenberg 4/16/2026 8:30 AM Hybrid Regular 5/7/2026 8:30 AM Hybrid Regular Jojarth 5/21/2026 8:30 AM Hybrid Regular 6/4/2026 8:30 AM Hybrid Regular Chen 6/18/2026 8:30 AM Hybrid Cancelled Adcock, Chen, Rosenberg 7/2/2026 8:30 AM Hybrid Cancelled Adcock 7/16/2026 8:30 AM Hybrid Regular 8/6/2026 8:30 AM Hybrid Regular 8/20/2026 8:30 AM Hybrid Regular 9/3/2026 8:30 AM Hybrid Regular 9/17/2026 8:30 AM Hybrid Regular 10/1/2026 8:30 AM Hybrid Cancelled 10/15/2026 8:30 AM Hybrid Regular 11/5/2026 8:30 AM Hybrid Regular 11/19/2026 8:30 AM Hybrid Regular 12/3/2026 8:30 AM Hybrid Regular 12/17/2026 8:30 AM Hybrid Regular Adcock Assignments will be made by the ARB Chair January February March April May June July August September October November December Item 1 Attachment A - 2026 Meeting Schedule & Assignments     Packet Pg. 7     Architectural Review Board Proposed 2027 Meeting Schedule & Assignments 1 2 4 8 4 2027 Meeting Schedule Meeting Dates Time Location Status Planned Absences 1/7/2027 8:30 AM Hybrid Regular 1/21/2027 8:30 AM Hybrid Regular 2/4/2027 8:30 AM Hybrid Regular 2/18/2027 8:30 AM Hybrid Regular 3/4/2027 8:30 AM Hybrid Regular 3/18/2027 8:30 AM Hybrid Regular 4/1/2027 8:30 AM Hybrid Regular 4/15/2027 8:30 AM Hybrid Regular 5/6/2027 8:30 AM Hybrid Regular 5/20/2027 8:30 AM Hybrid Regular 6/3/2027 8:30 AM Hybrid Regular 6/17/2027 8:30 AM Hybrid Regular 7/1/2027 8:30 AM Hybrid Regular 7/15/2027 8:30 AM Hybrid Regular 8/5/2027 8:30 AM Hybrid Regular 8/19/2027 8:30 AM Hybrid Regular 9/2/2027 8:30 AM Hybrid Regular 9/16/2027 8:30 AM Hybrid Regular 10/7/2027 8:30 AM Hybrid Regular 10/21/2027 8:30 AM Hybrid Regular 11/4/2027 8:30 AM Hybrid Regular 11/18/2027 8:30 AM Hybrid Regular 12/2/2027 8:30 AM Hybrid Regular 12/16/2027 8:30 AM Hybrid Regular Assignments will be made by the ARB Chair January February March April May June July August September October November December Item 1 Attachment B - Draft 2027 Meeting Schedule & Assignments     Packet Pg. 8     Item No. 2. Page 1 of 12 Architectural Review Board Staff Report From: Planning and Development Services Director Lead Department: Planning and Development Services Meeting Date: October 15, 2026 Report #: 2608-6703 TITLE PUBLIC HEARING / QUASI-JUDICIAL. 250 Hamilton Avenue [26PLN-00229]. Request by AT&T for Review of Two Tier 2 General Wireless Communication Facilities to Collocate New Antennas, Remote Radio Units (RRUs), Seven-Foot Fiberglass Pole Extensions and Associated Equipment on Existing City-Owned Wood Utility Poles in the Public Right-of-Way (ROW) Near 670 Guinda Street and 754 Homer Avenue. CEQA Status: Exempt Pursuant to California Environmental Quality Act (CEQA) Guideline Section 15301 (Existing Facilities). Zoning District: Not Applicable (Public ROW). RECOMMENDATION Staff recommends that the Architectural Review Board (ARB) conduct a public hearing and take the following action: 1. Recommend that the Director of Planning and Development Services (PDS) approve the Tier 2 General Wireless Communication Facility (WCF) application for collocation of new wireless equipment on two City-owned wood utility poles in the public ROW based on the Architectural Review Findings and Generally Applicable Development Standards set forth in Attachment B and the Conditions of Approval in Attachment C. EXECUTIVE SUMMARY This report provides background and analysis on the Tier 2 General WCF cluster application (26PLN-00229), which includes collocation (defined further in the report) of new wireless antennas, radio units, and associated equipment on two existing City-owned wood utility poles in the public ROW located adjacent to 670 Guinda Street and 754 Homer Avenue. The proposed project constitutes a Tier 2 General wireless project and is therefore subject to ARB review under Palo Alto Municipal Code (PAMC) 18.42.110 (g)(1). Tier 2 General applications are subject to a 90-day “shot clock”, as described further below. The shot clock period is expected to accommodate a potential appeal to Council of the Director’s decision on the project by any party in accordance with the PAMC, and in the case of a project approval decision, issuing all City-required permits. Item 2 Item 2 Staff Report     Packet Pg. 9     Item No. 2. Page 2 of 12 BACKGROUND The City has authority over the siting of WCFs. However, its authority is limited by various Federal and State laws, as detailed further in the July 16, 2026, ARB staff report.1 Within this legal framework, local agencies (i.e., the City) retain authority to enforce reasonable aesthetic design standards, protect community character, and ensure structurally safe deployment of wireless infrastructure. Notably, safety considerations exclude consideration of radiofrequency (RF) emissions that meet the current federal regulatory requirements. Palo Alto Regulations Between April 2019 and July 2025, the City relied on Council-adopted objective standards to review small wireless projects in the public ROW (Attachment D). In May 2025, Council repealed these standards and amended the PAMC through an interim ordinance to direct WCF Tier 2 and Tier 3 applications in the public ROW to a public hearing before the ARB for a recommendation to the Director. In place of the detailed objective standards (which may still be used for guidance), the City’s current published findings for approving a Tier 2 project includes three sections of the PAMC: 1. Confirming the project satisfies all the architectural review findings in PAMC Section 18.76.020(d) Architectural Review Findings (Attachment B); 2. Confirming the project’s compliance with the development standards in PAMC Section 18.42.110(i) Generally Applicable Development Standards (Attachment B); and 3. Confirming the project’s compliance with the conditions of approval in PAMC Section 18.42.110(j) Conditions of Approval (Attachment C). The ARB provided feedback on updates to the proposed ROW WCF standards and the Tier 2 and 3 application review process at its July 16, 2026, and August 6, 2026, hearings. Staff is incorporating this feedback into revised WCF standards and procedures for PTC and City Council consideration. This effort is expected to be complete in early 2027. Under the framework proposed by the ARB, Tier 2 and Tier 3 wireless facilities in the public ROW that meet updated Council-adopted standards would not require a public hearing. Until this new framework is approved by Council, however, all Tier 2 and 3 wireless facility projects in the public ROW require a public hearing at ARB, including the project considered in this report. WCF Permit Tiers and Architectural Review Understanding wireless terminology is essential for determining the appropriate permit type and scope of review. The complete list of definitions is listed under PAMC Section 18.42.110(b) (with references to applicable Federal regulations), but the following are some important terms as relevant to the application in review: 1.Collocation: Mounting or installing an antenna facility on a pre-existing structure. 1 The July 16, 2026 ARB Staff Report Item 2 is available online at: https://cityofpaloalto.primegov.com/Portal/Meeting?meetingTemplateId=19506 Item 2 Item 2 Staff Report     Packet Pg. 10     Item No. 2. Page 3 of 12 2.Structure: a pole, tower, base station, or other building, whether or not it has an existing antenna facility, that is to be used for the provision of personal wireless service (whether on its own or comingled with other types of service). 3.Small Wireless Facility (SWF): Each antenna does not exceed 3 cubic feet and all associated equipment excluding antennas does not exceed 28 cubic feet; subject to specific dimensional criteria under FCC rules. The City’s WCF permitting process is divided into three tiers, each with distinct thresholds, procedures, and review authority outlined in PAMC Section 18.42.110(c). For the purpose of this report, the Tier 2 SWF and Tier 2 General application types are differentiated below. Tier 2 SWF: Applies to qualifying small-cell installations that meet the SWF definition above, typically to be located on an existing utility pole or streetlight in the public ROW. These applications are subject to a 60-day shot clock for collocation on an existing structure and a 90-day shot clock for new or replacement structures. Tier 2 General: Applies to all other qualifying Tier 2 WCF applications that do not meet the definition of SWF. These applications are subject to a 90-day shot clock for collocation on an existing structure and 150-day shot clock for a new or replacement support structure. Planning staff and the applicant have determined that the project qualifies as a Tier 2 General application. The project involves collocation of new wireless equipment on existing wood utility poles within the public ROW that do not currently support WCF equipment. Although the proposed facilities exceed the thresholds for a Tier 1 facility, they do not include new or replacement support structures that would require Tier 3 review. Shot Clock Timelines WCF permit applications have a unique application process involving a “shot clock” timeline, whereby a final decision on each wireless application must take place within a specified period of time that FCC regulations presume to be reasonable, unless the City and applicant mutually agree to a longer time via a Tolling Agreement. This “shot clock” timeframe would include to the City’s final decision on this entitlement application (which could include an appeal to Council), as well as to process any street work and encroachment permit(s) if the project application was conditionally approved. The applicant submitted a Tier 2 General WCF application on August 14, 2026. Under applicable Federal shot clock requirements, the City must make a final decision on a Tier 2 General application for a facility in the public ROW within 90 days of the initial application submittal. Because this application involves a General facility as opposed to a SWF, the 90-day timeline pauses once the initial application is deemed incomplete if the City notifies the applicant of missing items in a timely manner per FCC regulations. Item 2 Item 2 Staff Report     Packet Pg. 11     Item No. 2. Page 4 of 12 For this project, the City determined that the August 14, 2026, application was incomplete on September 10, 2026, within the 30-day initial review period. The shot clock will resume when applicant resubmits a revised application, which applicant anticipates to be on October 9, 2026. If the City receives the resubmittal on that date, the resulting deadline for the City to issue a final decision, and if applicable, to complete any appeal process and issue required permits, would be on December 10, 2026. Although the cluster application consists of two separate WCF sites, the applicable shot clock will be tracked and calculated for the application and not independently for each site. 3 BACKGROUND 3 The repealed Objective Standards previously adopted under Resolution 9873 in 2019 can be viewed in Attachment D. Item 2 Item 2 Staff Report     Packet Pg. 12     Item No. 2. Page 5 of 12 Source: Google Maps Land Use Designation & Applicable Plans Zoning Designation:Not Applicable (Public ROW) Comp. Plan Designation:Not Applicable (Public ROW) Yes Yes Yes Baylands Master Plan/Guidelines (2008/2005) El Camino Real Guidelines (1976) Housing Development Project Downtown Urban Design Guidelines (1993) South El Camino Real Guidelines (2002) Utilizes Chapter 18.24 - Objective Standards Individual Review Guidelines (2005) Within 150 feet of Residential Use or District X Context-Based Design Criteria applicable SOFA Phase 1 (2000)Within Airport Influence Area SOFA Phase 2 (2003) Prior City Reviews & Action The proposed wireless collocations have had no prior review by the Boards and Commissions. PROJECT DESCRIPTION Item 2 Item 2 Staff Report     Packet Pg. 13     Item No. 2. Page 6 of 12 On behalf of New Cingular Wireless PCS, LLC (dba AT&T Mobility), NextEdge Networks Holdings LLC proposes two Tier 2 General WCFs on existing City-owned wood utility poles located adjacent to 670 Guinda Street and 754 Homer Avenue. The scope of work at each of the wood utility poles includes the following: Figure 1: Existing and Proposed Conditions at Wood Pole #6023 (from Forest Avenue looking west at the subject site) Item 2 Item 2 Staff Report     Packet Pg. 14     Item No. 2. Page 7 of 12 Figure 2: Existing and Proposed Conditions at Wood Pole #6010 (from Homer Avenue looking south at the subject site) Item 2 Item 2 Staff Report     Packet Pg. 15     Item No. 2. Page 8 of 12 Requested Entitlements, Findings, and Purview A Tier 2 WCF Permit as outlined in PAMC Section 18.42.110(g). Development Standards, subsection (i) of PAMC Section 18.42.110 (Attachment B); Conditions of Approval in PAMC Section 18.42.110(j) (Attachment C); and Architectural Review Findings in PAMC Section 18.76.020(d) (Attachment B). ANALYSIS Occupational/controlled exposure limits apply to situations in which persons are exposed as a consequence of their employment and in which those persons who are exposed have been made fully aware of the potential for exposure and can exercise control over their exposure. General population/uncontrolled exposure limits apply to situations in which the general public may be exposed or in which persons who are exposed as a consequence of their employment may not be made fully aware of the potential for exposure or cannot exercise control over their exposure. Item 2 Item 2 Staff Report     Packet Pg. 16     Item No. 2. Page 9 of 12 Professionals, Inc. prepared a Radio Frequency Safety Survey Report Predictive on July 31, 2026, to document the predicted General Population (i.e. ground level) and Occupational (i.e. antenna height level) exposure levels (Attachment F). These measurements are often calculated under the scenario where antennas are operating at full power, rather than the normal operating conditions. As a result, on-site measurements, which are required of the applicant pursuant to PAMC Section 18.42.110 (j)(3), are often lower than the predicted levels calculated. 5 and mounting elevation, as documented in the RF emissions report, reducing the potential to exceed MPE limits at any location other than within 6 feet directly in front of the antennas at antenna height (over 48 feet high). The predicted RF emissions at each of the sites are detailed below. Note that these measurements are for the antenna. Other appurtenances such as the RRUs and cabling are not sources of RF emissions. 670 Guinda Street (Pole ID #6023) 754 Homer Avenue (Pole ID #6010) 5 For wireless antenna, Azimuth is the direction an antenna is pointed, measured like a compass. For example, an antenna with an azimuth of 90 degrees faces east, while an antenna at 180 degrees faces south. Item 2 Item 2 Staff Report     Packet Pg. 17     Item No. 2. Page 10 of 12 RF Safety Signage On each of the poles, in front of the antennas, predicted RFE levels will exceed the FCC General Population limits within six feet in front of the antennas at antenna height (51+ feet high) and within three feet below the antennas (48 feet high). RF signage will be posted five feet below the antennas which will be visible upon approach that informs personnel accessing this area of basic precautions to be followed when working around the antennas. Noise As currently designed, the proposed project would not be a source of new ambient noise, since the configurations include convection-cooled radios which are fan-less and utilize natural convection to dissipate heat. Noise Assessment Letters were provided for each of the proposed wireless sites and are included in the applicant’s project description letter in Attachment G. Wireless Communication Facility Development Standards and Architectural Review Findings Staff reviewed the proposed project with respect to the Development Standards in PAMC Section 18.42.110(i), particularly in regard to the utilization of the smallest footprint possible, minimization of overall, mass, and size of the equipment shrouds, minimization of visibility, utilization of stealth or camouflage design, and architectural compatibility. The proposed wireless facility designs are depicted in the renderings included in the project plans (Attachment I). Staff seeks ARB confirmation regarding the overall cohesiveness of the proposed design and the integration of the antenna shroud and radio units with the existing wood utility poles and adjacent light masts, including the equipment’s size, placement, and orientation. In general, wireless equipment installed on wood utility poles is difficult to fully screen from public view. Unlike ground-mounted facilities, pole-mounted equipment is typically located at or above the tree canopy and may extend above surrounding vegetation, limiting the effectiveness of landscaping as visual screening. In addition, wood utility poles support visible overhead wires and related utility infrastructure, rather than the underground service connections commonly associated with streetlight poles. Because these poles are designed to support overhead electric and communications infrastructure, opportunities to fully conceal or disguise new wireless equipment are limited by required utility clearances, safe access, and operational needs. The proposed equipment is consistent with the functional use of the City’s wood utility poles and would not adversely affect the scale, massing, or character of adjacent land uses. Although the project is located in a residential neighborhood, it is not expected to disrupt nearby living conditions because noise impacts would be negligible. Item 2 Item 2 Staff Report     Packet Pg. 18     Item No. 2. Page 11 of 12 Overall, important considerations for placement of wireless equipment include maintaining minimum horizontal and vertical clearances for pedestrians and bicyclist safety, as well as paint color, and other aesthetic cohesiveness factors. Further analysis of the project’s compliance with the wireless development standards and the Architectural Review Findings is included in Attachment B. Planning Department Utilities Department FISCAL/RESOURCE IMPACT STAKEHOLDER ENGAGEMENT Item 2 Item 2 Staff Report     Packet Pg. 19     Item No. 2. Page 12 of 12 substantial visual impact due to the proximity of the utility poles to adjacent residences and the visibility of the proposed equipment from nearby properties. ENVIRONMENTAL REVIEW ALTERNATIVE ACTIONS ATTACHMENTS Report Author & Contact Information ARB7 Liaison & Contact Information 7 Emails may be sent directly to the ARB using the following address: ARB@PaloAlto.gov Item 2 Item 2 Staff Report     Packet Pg. 20     24 24 24 24 24 24 24 24 145.0' 105.0' ' 105.0' 50.0' 105.0' 00.0' 105.0' 50.0' 105.0' 50.0'200.0' 50.0' 200.0' 150.0' 50.0' 150.0' 50.0' 50.0' 100.0' 50.0' 100.0' 50.0' 100.0' 50.0' 100.0' 100.0' 100.0' 50.0'50.0' 150.0' 50.0' 150.0' .' 66.0' 50.0'66.0' 50.0' 150.0' 50.0' 150.0' 50.0' 150.0' 150.0' 150.0' 150.0' 150.0' 50.0' 150.0' 50.0' 50.0' 150.0' 50.0' 150.0' 100.0' 100.0' 100.0' 100.0' 100.0' 50.0' 100.0' 50.0' 200.0' 50.0' 200.0' 50.0' 200.0' 50.0' 200.0' 50.0' 200.0' 50.0' 200.0' 50.0' 200.0' 50.0' 200.0' 50.0' 150.0' 50.0' 150.0' 50.0' 50.0' 100.0' 50.0' 100.0' 50.0' 100.0' 50.0' 100.0' 50.0' 150.0' 50.0' 150.0' 50.0' 150.0' 50.0' 150.0' 200.0' 50.0' 200.0' 50.0' 150.0' 50.0' 150.0' 50.0' 150.0' 50.0' 150.0' 50.0' 150.0' 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107.5' 43.0' 7.5'13.3' 100.0' 56.3' 200.0' 50.0' 200.0' 50.0' 200.0' 50.0' 200.0' 50.0' 150.0' 50.0' 150.0' 50.0' 150.0' 50.0' 150.0' 50.0' 50.0' 200.0' 50.0' 200.0' 200.0' 50.0' 150.0' 175.0'200.0' 50.0' 200.0' 50.0' 150.0' 50.0' 150.0' 50.0' 150.0' 50.0' 150.0' 50.0' 37.6' 141.5' 18.8' 118.2' 125.0' 50.0' 125.0' 50.0' 125.0' 52.0' 140.0' 52.0' 140.0' 50.0' 140.0' 50.0' 140.0' 100.0' 50.0' 100.0' 50.0' 100.0' 50.0' 100.0' 50.0' 50.0' 100.0' 50.0' 100.0' 150.0' 50.0' 150.0' 50.0' 110.0' 50.0' 110.0' 50.0' 46.5' 50.0' 46.5' 50.0' 66.0' 50.0'66.0' 50.0' 46.5' 89.5' 44.5' 25.0' 100.0' 50.0' 9.0' 64.5' 46.5' 50.0' 46.5' 50.0' 46.5' 50.0' 46.5' 50.0' 40.0' 100.0' 37.5' 50.0' 2.5' 50.0' 55.5' 90.5' 46.5' 14.5'9.0' 105.0' 50.0' 145.0' 50.0' 145.0' 50.0' 145.0' 50.0' 145.0' 49.5' 40.0'49.5' 40.0' 49.5' 50.5'49.5' 50.5' 51.5' 49.5' 51.5'49.5' 49.5' 38.0'49.5' 38.0' 50.0' 145.0' 5.0' 5.0' 45.0' 150.0' 145.0' 50.0' 145.0' 50.0' 145.0' 50.0' 145.0' 50.0' 145.0' 75.0' 145.0' 75.0' 50.0' 150.0' 50.0' 150.0' 50.0' 100.0' 50.0' 100.0' 53.0 53.0' 96.9' 150.0' 5 150.0' 50.0' 50.0' 150.0' 50.0' .0' 72.0' 96.9' 57.2' 18.8' 85.0' 125.0' 125.0' 52.5' 125.0' 125.0' 52.5' 120.0' 120.0' 44.0' 120.0'9.1' 77.0' 150.0' 77.0' 150.0'55.5' 50.0' 25.4' 35.0' 75.9' 30.0' 7.1' 50.0' 73.0' 150.0' 73.0' 150.0' 50.0' 100.0' 50.0' 100.0' 94.5' 7.1' 47.0' 99.5' 52.0' 94.5' 50.0' 94.5' 50.0' 100.0' 50.0' 100.0' 50.0' 100.0' 50.0' 100.0' 50.0' 100.0' 62.5' 100.0' 62.5' 75.0' 100.0' 75.0' 100.0' 50.0' 100.0' 50.0' 100.0' 99.5' 7.0' 9.0' 41.0' 108.5' 48.0' 88.4' 25.0' 8.0' 40.0' 87.4' 41.0' 9.0' 24.0' 74.6' 100.0' 54.1' 40.0' 8.0' 25.0' 12.5' 35.0' 50.0' 250.0' 50.0' 250.0' 70.0' 100.0' 70.0' 100.0' 80.0' 100.0' 80.0' 100.0' 150.0' 50.0' 150.0' 50.0' 150.0' 50.0' 150.0' 50.0' 150.0' 50.0' 150.0' 50.0' 150.0' 50.0' 150.0' 50.0' 150.0' 50.0' 150.0' 50.0' 100.0' 50.0' 100.0' 50.0' 100.0' 50.0' 100.0' 50.0' 82.0' 28.3' 32.0' 100.0' 50.0' 117.2' 11.8' 152.6' 102.6'102.6' 76.2' 149.6' 60.0' 149.6' 17.8'35.5'36.0' 125.0' 50.0' 125.0' 50.0' 125.0' 50.0' 35.5' 128.3' 87.6' 15.0' 27.0' 86.0' 50.0' 140.0' 50.0' 140.0' 150.0' 100.0' 150.0' 100.0' 150.0' 50.0' 150.0' 50.0' 150.0' 50.0' 150.0' 50.0' 150.0' 50.0' 150.0' 50.0' 81.1' 102.6' 50.0' 166.4' 50.0' 100.0' 50.0' 100.0' 81.1' 88.8' 50.0' 152.6' 159.0' 18.8' 141.5' 50.0'50.0' 88.8' 100.0' 100.0' 50.0' 100.0' 100.0' 50.0' 2 50.0' 120.0' 120.0' 50.0' 120.0' 120.0' 44.0' 50.0' 18 105.0' 105.0' 50.0' 105.0' 105.0' 50.0' 91.1' 109.1' 50.0' 109.1' 91.1' 50.0' 50.0' 100.5' 100.6' 80.0' 120.1' 120.1' 70.0' 1 50.0' 18 50.0' 1 150.0' 112.5'150.0' 112.5' 120.0' 150.0' 65.0' 60.0' 100.0' 60.0' 100.0' 75.0' 185.0' 75.0' 63.5' 123.7'123.7' 42.7' 16.4' 150.0' 50.0'155 2 50.0' 136.5' 136.5' 50 . 0 ' 79.5' 120.5' 120.5' 120.5' 25.0' 759 619 735 655 801 3 640 829 734- 744 741-747 735 811 801 641 625 623 605 820 836 830 820 812 738 750 781 850 758 764 774 835 827 819 811 770 801 819 831 835 843 851 853 859 865 852 840 832 826 835803 930 918 912 701 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Legend Project Site 0' 107' Attachment A: Location Map CITY OF PALO ALTO I NC O R P O R A TE D CALI FORNIA P a l o A l t o T h e C i t y o f APRI L 1 6 189 4 The City of Palo Alto assumes no responsibility for any errors. ©1989 to 2016 City of Palo Alto nkandik, 2026-09-16 16:37:41 Attachment A. Location Map (\\cc-maps\Encompass\Admin\Personal\Planning.mdb) Item 2 Attachment A - Location Map     Packet Pg. 21     ATTACHMENT B ARB FINDINGS FOR APPROVAL In order for the ARB to make a recommendation of approval, the project must comply with the following Findings for Architectural Review as required in PAMC Chapter 18.76.020. Finding #1: The design is consistent with applicable provisions of the Palo Alto Comprehensive Plan, Zoning Code, coordinated area plans (including compatibility requirements), and any relevant design guides. The project is consistent with Finding #1 because: There are no applicable design guidelines and there is no coordinated area plan relevant to this project. However, the Comprehensive Plan includes Program L9.11.2, which provides that the City identifies City-owned properties where combinations of wireless facilities can be collocated, assuming appropriate lease agreements are in place. The wood utility poles on which the new wireless equipment is proposed presently has no existing antennas. New lease agreements are required for both wireless facilities near 670 Guinda Street (Pole ID #6023) and 754 Homer Avenue (Pole ID #6010). The proposed project also complies with applicable local regulations for WCFs, specifically the development standards listed in PAMC 18.42.110 (i). The Municipal Code provides a process to permit WCFs that blend with their existing surroundings and do not negatively impact the environment, historic properties, or public safety. The proposed equipment will be mounted on a 7-foot tall fiberglass pole extension on top of existing wood utility poles and will not impact the environment or public safety given their negligible ground-level radiofrequency (RF) emissions (approximately 1% of the allowable 100% FCC General Population limits at ground level for both sites) and design that will be painted to match the wood poles. Finding #2: The project has a unified and coherent design, that: a. creates an internal sense of order and desirable environment for occupants, visitors, and the general community, b. preserves, respects and integrates existing natural features that contribute positively to the site and the historic character including historic resources of the area when relevant, c. is consistent with the context-based design criteria of the applicable zone district, d. provides harmonious transitions in scale, mass and character to adjacent land uses and land use designations, e. enhances living conditions on the site (if it includes residential uses) and in adjacent residential areas. The project is consistent with Finding #2 because: Item 2 Attachment B - Draft Architectural Review Findings for Approval     Packet Pg. 22     The project includes the installation of mechanical equipment, antennas and associated cabling on two existing wood utility poles in the public ROW. The wireless facilities are designed to balance the aesthetic interests to minimize the visibility of the wireless equipment in the smallest footprint feasible. The antennas and radio units’ exterior surfaces will be painted to match the existing wood utility poles (brown). The wireless facilities are located on wood utility poles in a non-historic residential neighborhood and are not intended to be occupied. The proposed equipment is not an atypical use of the City’s wood utility poles, which would not impact the scale, mass or character of adjacent land uses. The proposed project, while located in a residential neighborhood will not disrupt living conditions due to negligible noise impact. In fact, many residents may benefit from improved wireless coverage. Finding #3: The design is of high aesthetic quality, using high quality, integrated materials and appropriate construction techniques, and incorporating textures, colors, and other details that are compatible with and enhance the surrounding area. The project is consistent with Finding #3 because: The proposed project includes the addition of mechanical equipment, cabling, antennas and screening material (the shrouds). The components necessarily by design and function must be well-integrated and employ appropriate construction techniques. The proposed materials and colors have been reviewed and determined appropriate for the proposed wireless antenna and associated equipment. The proposed material and colors were selected to blend in with the surrounding environment. Finding #4: The design is functional, allowing for ease and safety of pedestrian and bicycle traffic and providing for elements that support the building’s necessary operations (e.g. convenient vehicle access to property and utilities, appropriate arrangement and amount of open space and integrated signage, if applicable, etc.). The project is consistent with Finding #4 because: The proposed project has been designed in compliance with local, state, and federal safety standards, construction techniques and clearances required to allow for the ease and safety of pedestrian and bicycle traffic. The design is functional for its intended use and includes components necessary for its operation and screening. Finding #5: The landscape design complements and enhances the building design and its surroundings, is appropriate to the site’s functions, and utilizes to the extent practical, regional indigenous drought resistant plant material capable of providing desirable habitat that can be appropriately maintained. The project is consistent with Finding #5 because: Item 2 Attachment B - Draft Architectural Review Findings for Approval     Packet Pg. 23     The project is consistent with the finding in that the project preserves the existing street trees located along Guinda Street and Homer Avenue. The project includes only wireless equipment installation on existing wood utility poles and do not modify existing landscaping elements. Finding #6: The project incorporates design principles that achieve sustainability in areas related to energy efficiency, water conservation, building materials, landscaping, and site planning. The project is consistent with Finding #6 because: The proposed project draws energy from the city’s utility service according to the applicable city rate schedule, requires no water, and is designed with materials appropriate to the proposed wireless facility. Item 2 Attachment B - Draft Architectural Review Findings for Approval     Packet Pg. 24     GENERALLY APPLICABLE DEVELOPMENT STANDARDS PAMC SECTION 18.42.110(i) Unless the City Council has adopted more specific standards, the proposed WCF Project must comply with the standards below, except as otherwise provided in this section. Standards (7), (8), and (9) apply only to building-mounted facilities and stand-alone Tier 3 facilities and therefore do not apply to the proposed project. Staff finds that the project complies with the following applicable general standards: (1) Shall utilize the smallest antennae, radio, and associated equipment, as measured by volume, technically feasible to achieve a network objective; (2) Shall be screened from public view; (3) When attached to an existing structure, shall be shrouded or screened using materials or colors found on existing structure; (4) Shall be placed at a location that would not require the removal of any required landscaping or would reduce the quantity of landscaping to a level of noncompliance with the Zoning Code; (5) An antenna, base station, or tower shall be of a "camouflaged" or "stealth" design, including concealment, screening, and other techniques to hide or blend the antenna, base station, or tower into the surrounding area, such as the use of a monopine design; (6) Shall not be attached on a historic structure/site, as designated by Chapter 16.49; (7) Except as otherwise permitted by the Spectrum Act, a building-mounted WCF may extend no more than fifteen (15) feet beyond the permitted height of the building in the zone district; (8) Except as otherwise permitted by the Spectrum Act, a tower or other stand-alone Tier 3 WCF Project shall not exceed beyond sixty-five (65) feet in height; and (9) A tower or other stand-alone Tier 3 WCF may encroach into the interior/street side and rear setback. Item 2 Attachment B - Draft Architectural Review Findings for Approval     Packet Pg. 25     ATTACHMENT C The approval of this project shall be subject to the following conditions of approval. 1. COMPLIANCE WITH APPROVED PLANS. The proposed project shall be constructed in conformance with the approved plans under 26PLN-00229 uploaded to the Palo Alto Online Permitting Services Citizen Portal on __________ as modified by these conditions of approval. 2. BUILDING PERMIT. This approval letter, including the associated conditions of approval, shall be printed on the plan sets submitted for building permit review. 3. DEVELOPMENT STANDARDS. The proposed collocation and modification shall be screened from public view and shall not defeat any existing concealment elements of the streetlight pole. The proposed top mounted antennas and associated cabling and supporting equipment shall be painted to match the color of the wood utility poles. 4. NOISE ORDINANCE. The project shall not exceed the noise standard specified in Municipal Code Chapter 9.10.050. 5. MODIFICATIONS TO APPROVED PLANS. Any modifications, additions and intensification of use (i.e. additional antennas, change location) shall require an amended entitlement as specified in the Palo Alto Municipal Code. Any amended permits shall be reviewed and approved by the Director of Planning prior to implementation. 6. REMOVAL OF ABANDONED EQUIPMENT. Any components of the Wireless Communication Facility (WCF) that cease to be in use for more than ninety (90) days shall be removed by the applicant, Wireless Communications Service provider, or property owner within ninety (90) days of the cessation of use of that WCF. A new conditional use permit shall not be issued to an owner or operator of a WCF or a Wireless Communications Service provider until the abandoned WCF or its component is removed. 7. ANTENNA CABLING. All cables/wires shall be held as tightly to the tower/structure as possible so that the cabling does not appear loose and mismanaged. 8. COMPLIANCE WITH FCC REQUIREMENTS. The applicant shall comply with all FCC signage and barrier requirements related to siting of wireless equipment to the extent that they can clearly demarcate areas around antennas or EME emitting sources as hazardous to the relevant general or occupational POPULATION thresholds. Item 2 Attachment C - Draft Conditions of Approval     Packet Pg. 26     1 2 6 6 6 9. ANTENNA MODEL NUMBERS, TILTS, AND AZIMUTHS. The antenna model numbers, tilts, and azimuths for the antennas shall remain consistent between the permit plans and RF reports. Any additional azimuths or antennas are not approved. Prior to the issuance of streetwork and encroachment permits, any changes in antenna model numbers, tilts, and azimuths shall be accompanied by updated plans and RF reports; the City may elect to peer review these RF reports at the applicant’s sole expense. 10. RADIO FREQUENCY EMISSION. The applicant shall hire a radio engineer licensed by the State of California to measure the actual radio frequency emission of the WCF and determine if it meets Federal Communications Commission standards. A report, certified by the engineer, of all calculations, required measurements, and the engineer's findings with respect to compliance with the FCC's radio frequency emission standards shall be submitted to the Planning Division within one year of commencement of operation. The report shall have a methodology section outlining instrumentation, measurement direction, heights and distances, and other protocols outlined in FCC Bulletin OET 65. The report shall include a list and identify any nearby RF sources, nearby reflecting surfaces or conductive objects that could produce regions of field intensification, antenna gain and vertical and horizontal radiation patterns, type of modulation of the site, polarization and emissions orientation(s) of the antenna(s), a log of all equipment used, and a map and list of all locations measured indicating the maximum power observed and the percentage of the FCC Uncontrolled/General Population guidelines at the measurement location. At the applicant’s expense, the City may elect to have a City-staff observer during the measurements, may elect to receive raw test measurements by location provided in electronic format to the observer, and may elect to have the report independently peer reviewed prior to report acceptance. Applicant may be required to submit these reports periodically for the life of the project, as determined by the Director of Planning and Development Services. (APPLICANT FOLLOW-UP REQUIRED) 11. AS-BUILT PLANS. An as-built set of plans and photographs depicting the entire WCF as modified, including all Transmission Equipment and all utilities, shall be submitted to the Planning Division within thirty (30) days after the completion of construction. (APPLICANT FOLLOW-UP REQUIRED). 12. SUBJECT TO SITE USES. Any permit to install or utilize poles or conduit in the public rights-of- way is subject to the city’s prior right to use, maintain, expand, replace or remove from use such facilities in the reasonable exercise of its governmental or proprietary powers. Such permit is further subject to the city’s right to construction, maintain, and modify streets, sidewalks, and other improvements in the public rights-of-way. The city, in its sole discretion, may require removal or relocation of a permittee’s equipment, at permittee’s sole cost and expense, if necessary to accommodate a city use. 13. REPLACEMENT OF PROPOSED EQUIPMENT. Where feasible, as new technology becomes available, the applicant shall place above-ground equipment below ground and replace equipment remaining above-ground with smaller equipment, as determined by volume. The applicant shall obtain all necessary permits and approvals for such replacement. Item 2 Attachment C - Draft Conditions of Approval     Packet Pg. 27     1 2 6 6 6 14. INDEMNIFICATION. 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 for its actual attorneys’ fees and costs incurred in defense of the litigation. The City may, in its sole discretion and at Applicant’s expense, elect to defend any such action with attorneys of its own choice. 15. COMPLIANCE WITH APPLICABLE LAWS. The applicant shall comply with all applicable provisions of the Code, any permit issued under this Code, and all other applicable federal, state and local laws (including without limitation all building code, electrical code and other public safety requirements). Any failure by the City to enforce compliance with any applicable laws shall not relieve any applicant of its obligations under this code, any permit issued under this code, or all other applicable laws and regulations. 16. PERMIT EXPIRATION. 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. A written request for a one-year extension shall be submitted prior to the expiration date in order to be considered by the Director of Planning and Development Services. 17. REVOCATION. The Director of Planning and Development Services may revoke any WCF permit if the permit holder fails to comply with any conditions of the permit. The Director's decision to revoke a permit shall be appealable pursuant to the process for architectural review set forth in Section 18.77.070 and the process for conditional use permits set forth in Section 18.77.060. 18. PLANNING FINAL INSPECTION. A Planning Division Final inspection will be required to determine substantial compliance with the approved plans prior to the scheduling of a Building Division final. Any revisions during the building process must be approved by Planning. Contact your Project Planner at the number above to schedule this inspection. Public Works Department 19. PUBLIC WORKS STANDARD CONDITIONS SHEET: The Department of Public Work’s full-sized "Standard Conditions" sheet shall be included in the improvement plans and the applicant shall comply with all conditions listed in the sheet. The sheet can be obtained from a staff member of Public Works Engineering Services or at the following link under “Public Works Plan Review Documents”: https://www.paloalto.gov/Departments/Public-Works/Engineering- Services/Forms-and-Permits. Item 2 Attachment C - Draft Conditions of Approval     Packet Pg. 28     1 2 6 6 6 20. STORM WATER POLLUTION PREVENTION SHEET: The City's full-sized "Pollution Prevention - It's Part of the Plan" sheet shall be included in the improvement plans. The sheet can be obtained from a staff member of Public Works Engineering Services or at the following link under “Public Works Plan Review Documents”: https://www.paloalto.gov/Departments/Public- Works/Engineering-Services/Forms-and-Permits. 21. DEMOLITION PLAN: The following note shall be placed adjacent to all affected trees on the Demolition Plan: “Excavation and trenching is restricted within the Tree Protection Zone (refer to T-1 Tree Protection Sheet) or as approved by the Urban Forestry Division at 650-496-5953. Any changes shall be approved by the same”. 22. EASEMENTS. All existing easements shall be indicated on plan submittal to Public Works for necessary permits. Any proposed items in existing Public Utility Easement areas shall be approved by CPA Utilities and Public Works Engineering. This can be covered under an Encroachment Permit. Include a note on site plan indicating whether easements are present for each location. 23. TRENCH WORK AND FIBER OPTIC CONDUIT. All trench work and placement of fiber optic conduit shall adhere to City of Palo Alto Public Works specifications. Refer to City of Palo Alto Public Works Conduit Location Detail Telecommunications Drawing No. 402. This detail will provide specifics for placement of conduit in both residential and commercial areas. Any deviation from City Standards and Regulations must be approved by Public Works and all other applicable Departments. 24. STREETWORK/ENCROACHMENT PERMIT. A permanent encroachment permit will be required for all equipment that is to be installed in the public right-of-way. This approval letter, including the associated conditions of approval, shall be printed on the plan sets submitted for permit review. The RF report associated with this application shall be printed in the streetwork/encroachment permit plan set. a. Public Works shall determine the number of encroachment permits and associated street work permits, if any, that can be processed in a batch. The applicant will be required to apply for all necessary permits including: Street Work and Encroachment Permit applications. All required applications shall be in the submittal package for Public Works. Any necessary traffic control plans will also be submitted in the permit application packet. Any submitted traffic control plans shall be routed to Transportation Division under Planning & Community Environment for review. These necessary permit applications and requirements are available from Public Works on our website: https://www.paloalto.gov/Departments/Public-Works/Engineering-Services/Forms-and- Permits. 25. SIDEWALK, CURB & GUTTER. In the event existing sidewalks, curbs, gutters, driveway approaches, or street areas in the public right-of-way are disturbed as part of this project, the applicant shall repair or replace those sidewalks, curbs, gutters, driveway approaches, or street areas as directed by and to the satisfaction of the City Engineer. Contact Public Works’ Item 2 Attachment C - Draft Conditions of Approval     Packet Pg. 29     1 2 6 6 6 inspector at 650-496-6929 to arrange a site visit so that the inspector can discuss the extent of replacement work along the public road. The site plan submitted with the building/streetwork/ encroachment permit plan set must show the extent of the replacement work. The plan must note that any work in the right-of-way must be done per Public Works’ standards by a licensed contractor who must first obtain a Street Work Permit from Public Works at the Development Center. Urban Forestry Division – Public Works Department Electrical Utilities Division – Utilities Department Item 2 Attachment C - Draft Conditions of Approval     Packet Pg. 30     1 Resolution No. 9873 Resolution of the Council of the City of Palo Alto Amending Objective Aesthetic, Noise, and Related Standards for Wireless Communication Facilities in the Public Rights of Way The Council of the City of Palo Alto RESOLVES as follows: SECTION 1. Findings and Declarations. a. On April 15, 2019, the City Council adopted Resolution 9825, establishing objective aesthetic, noise, and related standards for Wireless Communication Facilities (WCFs) on Streetlight and Wood Utility Poles in the Public Rights-of-Way. b. On June 17, 2019, the City Council adopted Resolution 9847, amending the standards to delete inadvertently added language, clarify existing standards, and adopt an interim setback from public schools. c. On August 12, 2019, the City Council adopted Resolution 9855, amending the standards to address a conflict with other City standards and to clarify the allowable height for WCFs on Streetlights and Wood Utility Poles. d. The City Council wishes to consolidate the existing objective standards previously described in Resolution 9855 for clarity and update the objective standards in order to address Council specified location, design, and other preferences in the City for WCF on Streetlight Poles and Wood Utility Poles. SECTION 2. Objective Standards for WCFs on Streetlight Poles and Wood Utility Poles in the Public Rights-of-Way Amended. The City Council hereby adopts the objective standards in Exhibit 1, attached to and incorporated into this resolution, for Wireless Communication Facilities in the Public Rights of Way on Streetlight Poles and Wood Utility Poles. The City Council hereby adopts Exhibit 2 that illustrates the Residential Zone of Exclusion and Exhibit 3 that illustrates the City of Palo Alto roadway network and locations of special setbacks relative to generalized zoning designations for the sole purpose of supplementing the objective standards in Exhibit 1. SECTION 3. If any section, subsection, clause or phrase of this resolution or the attached standards is for any reason held to be invalid, such decision shall not affect the validity of the remaining portion or sections of the resolution and exhibits. The Council hereby declares that it should have DocuSign Envelope ID: ECCACC0E-18AC-4D5E-9AEE-0C930810BD0A Item 2 Attachment D - Resolution No. 9873 Wireless Objective Design Standards [Repealed]     Packet Pg. 31     2 adopted the resolution and exhibits, and each section, subsection, sentence, clause or phrase thereof irrespective of the fact that any one or more sections, subsections, sentences, clauses or phrases be declared invalid. SECTION 4. Environmental Review. The Council finds that this resolution is exempt from the provisions of the California Environmental Quality Act (“CEQA”), pursuant to Section 15061 of the CEQA Guidelines, because it does not authorize the construction of Wireless Communication Facilities in any locations where such facilities are not already permitted; therefore it can be seen with certainty that there is no possibility that the ordinance will have a significant effect on the environment. The resolution is further exempt under CEQA Guidelines sections 15301, 15302, 15303 and 15305 because it represents part of a comprehensive regulatory scheme governing minor alterations to existing facilities or small structures. INTRODUCED AND PASSED: December 16, 2019 AYES: CORMACK, DUBOIS, FILSETH, KNISS, KOU, TANAKA NOES: FINE ABSENT: ABSTENTIONS: ATTEST: City Clerk Mayor APPROVED AS TO FORM: APPROVED: Deputy City Attorney City Manager Director of Planning and Development Services DocuSign Envelope ID: ECCACC0E-18AC-4D5E-9AEE-0C930810BD0A Item 2 Attachment D - Resolution No. 9873 Wireless Objective Design Standards [Repealed]     Packet Pg. 32     3 Exhibit 1 Objective Standards for Wireless Communication Facilities in the Public Rights of Way on Streetlight Poles and Wood Utility Poles A Wireless Communication Facility (WCF) proposed for the public right of way must comply with the applicable provisions of the City’s Municipal Code and all of the following objective standards. In each instance where a proposed facility is unable to comply with the City’s objective standards, a WCF Exception may be requested and evaluated in accordance with this resolution and PAMC Section 18.42.110(k).1The following standards apply to both streetlight poles and wood utility poles, unless otherwise noted. WCF SITING STANDARDS Permitted Zoning Districts WCF placement is permitted in non-residential zoning districts. Public School Boundary A WCF shall not be placed within 600 feet of a parcel containing a public school. No WCF Exception shall be granted allowing a WCF to be placed closer than 300 feet to a parcel containing a public school. Residential Zone of Exclusion (this standard applies to WCF Exception requests to locate in residential districts) No WCF shall be placed within the public right of way in the area between the street centerline and the central fifty percent (50%) of the immediately adjacent parcel’s front lot line. The central fifty percent standard shall be based on the parcel’s lot width2. For corner lots, the central fifty percent standard along the street lot line3 shall be based on the parcel’s lot depth4. Exhibit 2 illustrates this requirement. Residential Roadways (this standard applies to WCF Exception requests to locate in residential districts) Any request for a WCF Exception involving placement of a WCF within a residential zoning district shall prioritize WCF placement on the following roadway types (See Exhibit 3):  Expressways  Arterials  Residential Arterials  Roadways identified with a Special Setback (including collector and local streets). 1 The City may hire an independent consultant to evaluate WCF Exceptions at applicant’s expense. 2 Palo Alto Municipal Code Section 18.04.030(a)(93) 3 Palo Alto Municipal Code Section 18.04.030(a)(91)(E) 4 Palo Alto Municipal Code Section 18.04.030(a)(87) DocuSign Envelope ID: ECCACC0E-18AC-4D5E-9AEE-0C930810BD0A Item 2 Attachment D - Resolution No. 9873 Wireless Objective Design Standards [Repealed]     Packet Pg. 33     4 In each instance above, the priority shall be for placement of a WCF most distant from residential property. An additional WCF Exception request must be made to place a WCF on a collector or a local roadway that does not have an identified special setback. Building or Structure Setback A WCF shall not be placed closer than 20 feet from any building used for occupancy in any zoning district. Distance Between WCFs A WCF shall not be placed less than 600 feet away from another WCF. This requirement does not preclude WCFs collocating on the same structure where otherwise allowed. Intersection Corners5 A WCF shall not be placed less than 20 feet away from any roadway intersection. An intersection is measured from the start of the curb radius. Scenic Routes6 A WCF shall not be placed along an identified scenic route. Historic Districts, Sites, and Structures A WCF shall not be placed within a listed historic district, nor immediately adjacent to a parcel with an historic structure, nor immediately adjacent to an historic site, as those terms are defined by PAMC Section 16.49.020. A WCF shall not be placed in a potential historic district, or immediately adjacent to a potential historic structure or site, where the application for historic designation was filed with the City prior to the filing of a WCF application, until a final decision has been made regarding that pending historic designation. WCF DESIGN STANDARDS Underground Design (Preferred Option) Radio equipment shall be placed in an underground vault. The associated antenna(s) shall be placed in a shroud at the top of a nearby pole. Underground vaults shall be the minimum volume necessary to house WCF equipment and include information detailing why the proposed dimensions are required. Maximum vault size shall not exceed 5 feet 8-inches x 8 feet 2-inches x 5 feet 7-inches or 260 cubic feet, excluding space required for ventilation or sump pump equipment. 5 Gateway intersections are identified on Map L-4 in the Comprehensive Plan. 6 Scenic routes are identified in Policy L-9.1 in the Comprehensive Plan. DocuSign Envelope ID: ECCACC0E-18AC-4D5E-9AEE-0C930810BD0A Item 2 Attachment D - Resolution No. 9873 Wireless Objective Design Standards [Repealed]     Packet Pg. 34     5 Top-Mounted Design (Secondary Option) Radio equipment and the associated antenna(s) shall be enclosed within a shroud at the top of the pole. Minimal Sunshield Design Use of this design requires a WCF Exception Radio equipment shall be enclosed within one or two sunshields not exceeding 8 inches wide nor 0.75 cubic feet in volume each, mounted directly to the side of the pole. The associated antenna(s) shall be placed in a shroud at the top of the pole. Sunshields shall be attached at least 12 feet above ground level and, when located on wood utility poles, shall not interfere with the identified communication space. Existing Signage Design Use of this design requires a WCF Exception Radio equipment shall be attached to a pole behind existing signage under the following conditions: i) Radio equipment shall be placed within a shroud that does not exceed the dimensions of the sign in height and width, nor 4 inches in depth, including any required mounting bracket. ii) In no event shall WCF equipment obscure or interfere with the visibility or functioning of the signage. The associated antenna(s) shall be placed in a shroud at the top of the pole. WCF Antenna and Shroud Dimensions (Diameter / Height) Antennas shall have the smallest size possible to achieve the coverage objective. The diameter of the antenna and shroud shall not exceed 15 inches at their widest. For Streetlight Poles: The maximum WCF height shall not exceed 3 feet (or 5.5 feet for top-mounted designs) from the top of the streetlight pole that meets the City standards for the proposed location. The associated “antenna skirt” shall taper to meet the pole above the mast arm. For Wood Utility Poles: In no circumstance shall the total height of a pole and all WCF equipment exceed 55 feet. For wood utility poles carrying power lines, replacement poles shall be the minimum height necessary to provide GO 95 mandated clearance between WC equipment and power lines. For wood utility poles without power lines, any WCF equipment shall not increase the height of the pole by 5.5 feet when compared with the height of the existing pole. DocuSign Envelope ID: ECCACC0E-18AC-4D5E-9AEE-0C930810BD0A Item 2 Attachment D - Resolution No. 9873 Wireless Objective Design Standards [Repealed]     Packet Pg. 35     6 The associated “antenna skirt” shall taper to meet the top of the pole if wider than the pole. WCF Design Quality Antennas and/or equipment at the top of the pole shall be covered by a single integrated shroud and “antenna skirt” designed without gaps between materials or sky visible between component surfaces and between the shroud or skirt and the top of the pole. All components external to the pole shall have an integral color or shall be painted to match the color and/or materials of the pole. Equipment shall be oriented to face in either of the directions of travel in the right of way and shall not face or extend toward private property or the curb line. WCF Equipment Adjustment For Streetlight Poles: Equipment that cannot propagate an adequate signal within the shrouding required by the standard designs shall be attached to a streetlight pole at a height of 2 feet below the light mast or higher. Each instance of such equipment shall not exceed 0.85 cubic feet, nor shall the total volume of such equipment and any shrouding exceed 2.6 cubic feet per streetlight pole. For Wood Utility Poles: Equipment that cannot propagate an adequate signal within the shrouding required by the standard designs shall be attached to the top of the pole or on a cross arm or brace protruding from the pole the minimum extent necessary to comply with safety standards, including GO 95. Such cross arm shall be placed as high on the pole as technically feasible. Each instance of such equipment shall not exceed 0.85 cubic feet nor shall the total volume of such equipment exceed 2.6 cubic feet per wood utility pole. Curb Clearances Any WCF attachments placed below 16 feet above ground level shall not be placed closer than 18 inches to the curb, nor shall they extend over the sidewalk (Caltrans Highway Design Manual Section 309). All WCF equipment shall maintain at least 3 feet from any curb cut. WCF Wires and Cabling For Streetlight Poles: All wires and cabling shall be routed entirely underground and within the pole and any attached shroud. For Wood Utility Poles: All wires and cabling to equipment shall be within the shroud or shall be within conduit. All conduit shall be mounted flush to the pole. DocuSign Envelope ID: ECCACC0E-18AC-4D5E-9AEE-0C930810BD0A Item 2 Attachment D - Resolution No. 9873 Wireless Objective Design Standards [Repealed]     Packet Pg. 36     7 Safety Signs Safety signs shall be the smallest size possible to accomplish its purpose. Power Disconnects For Streetlight Poles: Power disconnects shall be labeled and placed in a vault near the base of the pole. For Wood Utility Poles: Power disconnects shall be labeled and placed on the wood pole or in a vault near the base of the pole. Ground Mounted Equipment Except as provided in these standards, no equipment cabinets may be placed at grade. Existing Pole Locations A WCF shall utilize an existing streetlight pole or wood utility pole location. Any new pole locations are prohibited unless approved through a City Public Works/Utilities pole placement application. WCF PERFORMANCE STANDARDS Pole Replacement For Streetlight Poles: An existing streetlight pole proposed for a WCF installation shall be replaced with a new pole.7 For Wood Utility Poles: An existing wood utility pole proposed for a WCF installation shall be replaced with a new pole.8 Landscaping Replacement Any existing landscaping removed or damaged by installation shall be replaced in kind. Landscape Screening A WCF shall be placed where existing street tree foliage or new street tree or amenity tree foliage within 35 feet of the WCF provides interruption of direct views of the WCF. 7 Replacement streetlight poles must meet the currently applicable City standards for the pole, including foundation and bolt designs, conduit separation, aluminum material, color, width, height, light mast characteristics (examples: orientation, design, height, color temperature and photometrics), and the presence/absence of decorative features. Replacement poles will conform to Public Works Department (PWD) style guidelines and Utilities-Electrical (CPAU) standards where the City has adopted standards and will match the pole being replaced where no standards exist. Standard specifications for streetlight poles in the City can be obtained from the Utilities-Electrical (CPAU) and Public Works (PWD) Departments. 8 Replacement wood utility poles must meet the currently applicable City standards for the pole, including width, height, color, material, structural capacity, and GO 95 compliance. Replacement poles shall be no greater in diameter or other cross-sectional dimension than is necessary for the proper functioning of the pole with all attachments. Existing pole functionality shall be maintained, such as in regard to electrical lines, climbing space, light masts (examples: orientation, design, height, color temperature and photometrics), and provision of communication space, unless existing functionality, such as transformers, can be relocated with the approval of the Utilities-Electrical Department (CPAU). Standard specifications for pole replacement in the City can be obtained from CPAU. For wood utility poles carrying power lines, replacement poles shall be the minimum height necessary to provide GO-95 mandated clearance between WCF equipment and power lines. DocuSign Envelope ID: ECCACC0E-18AC-4D5E-9AEE-0C930810BD0A Item 2 Attachment D - Resolution No. 9873 Wireless Objective Design Standards [Repealed]     Packet Pg. 37     8 Noise9 Noise from a WCF shall comply with PAMC Chapter 9.10 and shall be consistent with noise-related Comprehensive Plan goals and policies. City Marketing Banners WCF installations shall not require any changes in the City’s existing banner marketing program. WCF EXCEPTIONS A WCF applicant may file an application(s) containing a request for one or more WCF Exceptions to the objective standards set forth in this resolution or any other provision of PAMC Section 18.42.110. The request for a WCF Exception(s) does not exempt a WCF from complying with other objective wireless administrative standards adopted by City Council resolution or any other provision of PAMC Section 18.42.110. Each WCF Exception request must be made at the time an application is submitted and must include both the specific provision(s) from which the exception is sought and the basis of the request, including all supporting evidence on which the applicant relies. The applicant has the burden of proving that federal law, state law, or both, compel the decision-making authority to grant the requested exception(s). The WCF Exception must satisfy the requirements of PAMC Section 18.42.110(k) and demonstrate why the standard is infeasible. Failure to identify all required WCF Exceptions upon application submittal may result in application denial. No WCF Exception may be granted that allows a WCF to be placed: 1) within 300 feet of a parcel containing a public school, 2) within 20 feet of a habitable residential building in a residential zoning district, 3) on wood utility poles within the Residential Zone of Exclusion described in this resolution, or 4) in an alley within a residential zoning district. 9 In residential areas with an average 24-hour noise level (Ldn) at or below 60 decibels (dB), noise generated by WCF equipment shall not cause the Ldn to exceed 60dB or to increase by 5.0 dB or more, even if the resulting Ldn would remain below 60 dB. In residential areas with a Ldn above 60 dB, noise generated by WCF equipment shall not cause the average to increase by 3.0 dB or more. DocuSign Envelope ID: ECCACC0E-18AC-4D5E-9AEE-0C930810BD0A Item 2 Attachment D - Resolution No. 9873 Wireless Objective Design Standards [Repealed]     Packet Pg. 38     144.2' 100.1' 70.0' 144.2' 60.0' 100.1' 30.0' 100.1' 60.0' 160.0' 139.1' 160.0' ' 64.9' 100.0' 100.0' 64.9' 100.0' This map is a product of the City of Palo Alto GIS This document is a graphic representation only of best available sources. Legend 0'53' Ex h i b i t 2 WC F RZO E D I A G R A M CITYOF PALOALTO I NC O R P O R A TE D CALI FORNIA P a l o A l t oT h e C i t y o f APRI L 1 6 189 4 The City of Palo Alto assumes no responsibility for any errors. ©1989 to 2016 City of Palo Alto rrivera, 2019-11-25 17:25:35 (\\cc-maps\Encompass\Admin\Personal\rrivera.mdb) ROAD CENTERLINE RZOE - central 50% of parcel's lot width 50% of 139.1 lot width = 69.55 ft RZOE - central 50% of parcel's lot width RZOE - central 50% of parcel's lot width RZOE - central 50% of parcel's lot depth 35 f t 50% of 70 ft lot width = 35 ft ROAD CENTERLINE CURB LIP PARCEL/PROPERTY LINE 30 f t 30.0' 30 f t 30 f t RZO E - c e n t r a l 50 % o f pa r c e l ' s l o t wi d t h RZO E - c e n t r a l 50 % o f pa r c e l ' s l o t wi d t h RZO E - c e n t r a l 50 % o f pa r c e l ' s l o t wi d t h RO A D CE N T E R L I N E RZO E - c e n t r a l 50 % o f pa r c e l ' s l o t wi d t h Residential Zone of Exclusion (RZOE) (this standard applies to WCF Exception requests to locate in residential districts) No WCF shall be placed within the public right of way in the area between the street centerline and the central fifty percent (50%) of the immediately adjacent parcel’s front lot line. The central fifty percent standard shall be based on the parcel’s lot width. For corner lots, the central fifty percent standard along the street lot line shall be based on the parcel’s lot depth. Fr o n t S e t b a c k L i n e 139.1'100.1' 60 . 0 ' 60 . 0 ' 60 . 0 ' 70.0' 64.9'64.9' 30 . 2 4 ft 32.44 ft 50.05 ft32.45 ft 30 . 2 4 ft 35 . 0 7 ft 69.38 ft 30 . 2 4 ft 50.39 ft32.44 ft 32.45 ft 69.55 ft DocuSign Envelope ID: ECCACC0E-18AC-4D5E-9AEE-0C930810BD0A Item 2Attachment D - ResolutionNo. 9873 Wireless ObjectiveDesign Standards[Repealed]   Packet Pg. 39     24 24 24 24 2424 24 24 2424 24 24 24 24 24 24 24 2424 24 24 24 24 24 2424 24 2424 24 24 15 24 24 101010 10 10 24 20 10 1515 15 15 15 10 10 10 1524 15 15 15 15 15 24 24 24 24 20 2424 50 30 30 50 50 24 24 25 25 25 25 25 25 25 25 50 24 24 24 50 24 50 50 50 50 30 50 50 50 25 25 25 25 25 25 25 25 25 25 24 24 50 50 5050 50 50 50 50 50 242424 24 24 24 24 25 25 25 25 25 24 24 24 24 24 30 25 50 24 24 24 24 24 7777 6 6 6 77 77 77 7 7 77 77 77 24 25 6 24 24 24 24 2424 24 2424 24 24 24 2424 2424 24 24 24 24 24 24 24 24 24 2424 3535 351010 24 10 53 204 418 20 10351035 24 24 24 24 24 24 24 24 24 24 24 24 24 24 2424 24 24 24 30 7 7 7 17 24 30 24 24 24 30 177 7 17 7 17 30 24 2424 24 24 24 24 24 30 24 24 24 24 24 24 40 40 24 24 24 24 24 24 40 40 40 24 24 24 24 24 24 40 40 40 40 40 40 40 40 40 40 40 40 2424 24 24 24 24 24 24 2424242424 24 24 24 24 24 60 60 60 30 30 40 30 24 24 24 24 24 24 30 6060 60 60 50 50 40 40 24 24 24 24 242424 24 24 24 24 30 24 24 24 24 24 24 24 24 30 24 24 24 30 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 2424 24 2430 30 24 24 16 8 24 16 8 16 24 24 24 24 24 24 24 24 15 30 24 20 25 24 24 24 24 2424 24 24 24 24 24 24 24 30 24 24 20 20 24 25 25 25 25 2525 252020 2525 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 2424 24 24 24 24 24 24 24 24 24 24 24 24 2424 24 24 24 24 24 24 24 24 24 24 2424 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 50 50 50 50 24 24 Special ConditionsSpecial C onditions Special Condit ions ACK_FOR_MIXED d e l a s Pu l gas d H i l l R o ad J u n i pe r o Serra B o u l evard Page M i l l R o ad Ar as t rade ro Road E l C a m i n o R e a l S a n An t o n i o A v e n u e Cha r l e s t on Roa d Or e gon Exp r e s swa y Mid d lef ie ld Road University Avenue e w a y 1 0 1 A l ma S t r e e t El Camino Real A l p i n e R o a d F o o t h i ll E x p r e s s w a y H i g h Hillview East Bayshore West Bayshore Fabian Central Expressway Sand Hill Road Embarcadero Road Fa b i a n W a y Newell Rd California St Latham St C Pu Middle Ave Welch Coyot e H i l l Rd Hansen Way Matadero Ave Loma Verde Ave Colorado Ave Park Blvd Birch N. California Ave Amaranta El Ca mino Way Lytton Ave Hamilton Ave Homer Ave Channing Ave Channing Ave Guinda Stanford Av e Waverley St. Churchill Ave tPeer C outts Serra S t Arbore tum G a l v ez Park B lvd Amph i t h e a t r e P k w y Charleston RdAlma St Los A ltos A ve Hillview Ave Old Page M i l l Rd o l d e nantes R d This map is a product of the City of Palo Alto GIS This document is a graphic representation only of best available sources. Legend Residential Zone Districts Non- Residential Zone Districts Public Facilities/Open Space Zone Districts Special Setback Frontages Local Collector Residential Arterial Arterial Expressway City Jurisdictional Limits 0'2670' Ex h i b i t 3 Ro a d N e t w o r k a n d S p e c i a l S e t b a c k s wi t h R e s i d e n t i a l , C o m m e r c i a l , an d Pu b l i c F a c i l i t i e s Z o n i n g D i s t r i c t s v. 2 0 1 9 1 1 2 5 CITYOF PALOALTO I NC O R P O R A TE D CALI FORNIA P a l o A l t oT h e C i t y o f APRI L 1 6 189 4 The City of Palo Alto assumes no responsibility for any errors. ©1989 to 2016 City of Palo Alto rrivera, 2019-11-25 13:00:40 (\\cc-maps\Encompass\Admin\Personal\rrivera.mdb) DocuSign Envelope ID: ECCACC0E-18AC-4D5E-9AEE-0C930810BD0A Item 2Attachment D - Resolution No. 9873Wireless Objective Design Standards[Repealed]   Packet Pg. 40     Certificate Of Completion Envelope Id: ECCACC0E18AC4D5E9AEE0C930810BD0A Status: Completed Subject: Please DocuSign: RESO 9873 WCF Resolution with Exhibit 1.docx, RESO 9872 Exhibit 2.pdf, RESO 98... Source Envelope: Document Pages: 10 Signatures: 5 Envelope Originator: Certificate Pages: 2 Initials: 0 Kim Lunt AutoNav: Enabled EnvelopeId Stamping: Enabled Time Zone: (UTC-08:00) Pacific Time (US & Canada) 250 Hamilton Ave Palo Alto , CA 94301 kimberly.lunt@cityofpaloalto.org IP Address: 199.33.32.254 Record Tracking Status: Original 1/7/2020 1:32:22 PM Holder: Kim Lunt kimberly.lunt@cityofpaloalto.org Location: DocuSign Security Appliance Status: Connected Pool: StateLocal Storage Appliance Status: Connected Pool: City of Palo Alto Location: DocuSign Signer Events Signature Timestamp Aylin Bilir Aylin.Bilir@CityofPaloAlto.org Deputy City Attorney Security Level: Email, Account Authentication (None)Signature Adoption: Pre-selected Style Using IP Address: 199.33.32.254 Sent: 1/7/2020 1:36:35 PM Viewed: 1/7/2020 1:40:55 PM Signed: 1/7/2020 4:08:48 PM Electronic Record and Signature Disclosure: Not Offered via DocuSign Jonathan Lait Jonathan.Lait@CityofPaloAlto.org Interim Director Planning and Community Environment City of Palo Alto Security Level: Email, Account Authentication (None) Signature Adoption: Uploaded Signature Image Using IP Address: 199.33.32.254 Sent: 1/7/2020 4:08:51 PM Resent: 1/13/2020 8:54:57 AM Resent: 1/15/2020 8:58:56 AM Resent: 1/16/2020 11:39:30 AM Viewed: 1/16/2020 12:31:49 PM Signed: 1/16/2020 12:32:05 PM Electronic Record and Signature Disclosure: Not Offered via DocuSign Ed Shikada ed.shikada@cityofpaloalto.org Ed Shikada, City Manager City of Palo Alto Security Level: Email, Account Authentication (None) Signature Adoption: Pre-selected Style Using IP Address: 199.33.32.254 Sent: 1/16/2020 12:32:09 PM Viewed: 1/16/2020 5:51:30 PM Signed: 1/16/2020 5:51:37 PM Electronic Record and Signature Disclosure: Not Offered via DocuSign Eric Filseth eric.filseth@cityofpaloalto.org Mayor Security Level: Email, Account Authentication (None)Signature Adoption: Pre-selected Style Using IP Address: 108.169.4.229 Sent: 1/16/2020 5:51:41 PM Viewed: 1/16/2020 11:04:09 PM Signed: 1/16/2020 11:04:20 PM Electronic Record and Signature Disclosure: Not Offered via DocuSign Item 2 Attachment D - Resolution No. 9873 Wireless Objective Design Standards [Repealed]     Packet Pg. 41     Signer Events Signature Timestamp Beth Minor Beth.Minor@CityofPaloAlto.org City Clerk City of Palo Alto Security Level: Email, Account Authentication (None) Signature Adoption: Pre-selected Style Using IP Address: 199.33.32.254 Sent: 1/16/2020 11:04:23 PM Viewed: 1/17/2020 7:52:37 AM Signed: 1/17/2020 7:52:54 AM Electronic Record and Signature Disclosure: Not Offered via DocuSign In Person Signer Events Signature Timestamp Editor Delivery Events Status Timestamp Agent Delivery Events Status Timestamp Intermediary Delivery Events Status Timestamp Certified Delivery Events Status Timestamp Carbon Copy Events Status Timestamp Witness Events Signature Timestamp Notary Events Signature Timestamp Envelope Summary Events Status Timestamps Envelope Sent Hashed/Encrypted 1/16/2020 11:04:23 PM Certified Delivered Security Checked 1/17/2020 7:52:37 AM Signing Complete Security Checked 1/17/2020 7:52:54 AM Completed Security Checked 1/17/2020 7:52:54 AM Payment Events Status Timestamps Item 2 Attachment D - Resolution No. 9873 Wireless Objective Design Standards [Repealed]     Packet Pg. 42     TIER 2 WCF PROPOSED FOR THE PUBLIC RIGHT-OF-WAY APPLICATION SUBMITTAL REQUIREMENTS CHECKLIST April 2019 Page 1 of 7 TIER 2 WIRELESS COMMUNICATIONS FACILITIIES PROPOSED FOR THE PUBLIC RIGHT-OF-WAY APPLICATION SUBMITTAL REQUIREMENTS CHECKLIST In-person appointments are required to submit all applications. Appointments can be scheduled by calling the Planning Division at (650) 329-2442 or scheduled in-person at the City‘s Development Center, located at 285 Hamilton Avenue. The following information is required for the review of Tier 2 Wireless Communications Facilities (WCF) as defined in Palo Alto Municipal Code 18.42.110 and proposed for location in the public right-of-way. Instructions: Complete and submit all items listed in the checklist below that are applicable to the application. The information identified below must be provided in order to accept the application as complete for review. If an item does not apply, write “N/A” (not applicable). The Planning Department is available to answer applicant questions in advance of application submittal and can be contacted at 650- 329-2442. Project Location(s)/Address(es): Project Description (include Applicant name and Carrier name): Application Basic Information (Please circle the applicable response): Y, N, or N/A Materials contain more than one wireless communication facility and the applications are batched. Y, N, or N/A Materials show one or more wireless communication facility designs that meet all of the City’s rules, regulations, and Objective Standards (Refer to City Council Action on December 16, 2019). Y, N, or N/A Materials request one or more WCF exception requests to the City’s rules, regulations, or Objective Standards. Y, N, or N/A Materials show one or more wireless communication facilities that qualify as a “small wireless facility,” as defined by any valid regulations adopted by the FCC. Y, N, or N/A Materials show one or more wireless communication facilities that do not qualify as a “small wireless facility,” as defined by any valid regulations adopted by the FCC. Y, N, or N/A Materials show one or more wireless communication facilities that are subject to the applicant’s Master License Agreement. Y, N, or N/A Materials show one or more wireless communication facilities that are not subject to a Master License Agreement. Application Submittal Requirements: Additional copies of application materials may be required if the application is referred after intake for review by the Architectural Review Board, City Council, Responsible Agency, or other reviewing body.  Application Forms. Per PAMC Section 18.42.110(d) and PAMC Section 18.42.110(e), all required application forms and required application materials necessary to initiate and process all entitlement and all permit reviews and decisions shall be submitted so that they can be processed concurrently. Application forms include the Planning Application with original wet signatures of the applicant and property owner(s). The Planning Application Number will be assigned at application intake. Copies of completed additional application forms are also required, as applicable, including but not limited to: Building Permit Application, Excavating and Grading Permit Application, Electrical or Other Utilities Permit Application, Street Work Permit Application, PROW near 804 Boyce Ave; 670 Guinda St at Forest Ave; 754 Homer Ave, Palo Alto, CA 94301 Applicant: NextEdge Networks Holdings LLC; Carrier: AT&T Mobility. Three Tier 2 small cell WCFs on existing City of Palo Alto wood distribution poles in the PROW. Batched application. Item 2 Attachment E - Submittal Checklist for Tier 2 and 3 WCFs in Public ROW     Packet Pg. 43     TIER 2 WCF PROPOSED FOR THE PUBLIC RIGHT-OF-WAY APPLICATION SUBMITTAL REQUIREMENTS CHECKLIST December 2019 Page 2 of 7 Insurance Certificate, and/or an Encroachment Permit Application. A Master License Agreement Exhibit (commonly referred to as Exhibit G) and a Utility Map Request will have likely been submitted to the City’s Utilities Department as part of the applicant team gathering information necessary to investigate siting and prepare project plans and do not constitute entitlement or permit filing. List the numbers and dates submitted for each applicable application and permit: •Planning Application Number & Date Submitted: ____________________________________ •Building Permit Application Number & Date Submitted: ______________________________ •Excavation and Grading Permit Application Number & Date Submitted: __________________ •Street Work Permit Application Number & Date Submitted: ___________________________ •Encroachment Permit Application Number & Date Submitted: _________________________ •Insurance Certificate Submittal Information & Date Submitted: ________________________ •Electrical Permit Application Number & Date Submitted: _____________________________ •Other Application Number(s) & Date(s) Submitted: __________________________________ •Master License Agreement Exhibit Tracking Information & Date Submitted: ______________ •Utility Map Request Form Tracking Information & Date Submitted: _____________________  One (1) hardcopy of this TIER 2 WIRELESS COMMUNICATIONS FACILITIIES PROPOSED FOR THE PUBLIC RIGHT-OF-WAY APPLICATION SUBMITTAL REQUIREMENTS CHECKLIST completed and signed.  One (1) hardcopy of the Cost Recovery Form with original wet signature of applicant. A signed cost recovery agreement may substitute for the cost recovery form.  Application Fees/Deposits. Application submittal fees/deposits shall be invoiced and submitted during application intake. For batched applications, an invoice shall be prepared and the fees/deposits paid for each proposed location, unless the applicant coordinates with the City to prepare a mutually agreed upon separate cost recovery agreement. Consistent with the City’s Municipal Fee Schedule, a separate deposit(s) may also be necessary to submit after application intake to cover the cost of the City’s use of consultants to conduct independent review of application material(s) and/or serve as an extension of staff to conduct application reviews.  Application numbers for any existing and/or approved wireless communication facilities at the proposed location and/or within 1,500 feet of the proposed WCF location on either public or private property: _______________________________________________________________________  One (1) electronic copy of all application materials listed in this checklist.  Three (3) hardcopies of a Radio Frequency Report, prepared by a professional engineer, that discusses and confirms the wireless communication facility planned compliance with the FCC regulations. The report shall include a list of the proposed equipment models, frequency bands, power, azimuths, minimum and maximum downtilts, distances to ground and adjacent single and multiple-story buildings, clarification if there are any other nearby wireless facilities considered as part of the analysis of cumulative conditions, a description of the standards, equations, and other methodology utilized, color maps and/or statements of distances and zones for public and occupational exclusion and/or exposure limits, and required signage and any other measures necessary for the facility to operate in compliance with FCC standards. The City may elect to have an outside consultant to perform a peer review of this report at the applicant's expense.  One (1) hardcopy of the manufacturer’s specifications for proposed equipment, including power operations and noise generation information.  Three (3) color hardcopies of existing and proposed coverage and capacity maps with a legend and other graphics that describe the goals for the proposed wireless communication facility.  Three (3) hardcopies of the completed “A Local Government Official’s Guide to Transmitting Antenna RF Emission Safety: Rules, Procedures, and Practical Guidance - APPENDIX A Optional N/A, power served overhead Not yet submitted Not yet submitted Verizon streetlight WCF approx. 455 ft SW of PALO4_004; permit no. pending. Further City records pending; to be supplemented. To be assigned at intake Not yet submitted, see cover letter Not yet submitted, see cover letter Not yet submitted, see cover letter Not yet submitted, see cover letter Not yet submitted, see cover letter N/A 4 4 4 4 4 4 4 4 4 Item 2 Attachment E - Submittal Checklist for Tier 2 and 3 WCFs in Public ROW     Packet Pg. 44     TIER 2 WCF PROPOSED FOR THE PUBLIC RIGHT-OF-WAY APPLICATION SUBMITTAL REQUIREMENTS CHECKLIST December 2019 Page 3 of 7 Checklist for Local Government To Determine Whether a Facility is Categorically Excluded” form.  Three (3) hardcopies of the completed “HAZARDOUS MATERIALS DISCLOSURE CHECKLIST” form.  Three (3) hardcopies of the completed “ENVIRONMENTAL IMPACT ACCESSMENT WORKSHEET” form.  One (1) hardcopy of a list of all of the carrier’s existing or entitled antenna locations, including the street address and latitude/longitude coordinates, within the City limits. Each site listed should include the type of installation (e.g. roof-mounted, monopole, faux tree, etc.).  One (1) color hardcopy of the location map from the project plans printed on 11” x 17” paper.  One (1) color and materials board including samples of actual colors and materials mounted on 8” x 14” foam board to be retained by the city as part of the permanent file.  Three (3) hardcopies of a Tree Protection Report (TPR) and arborist assessment. Report shall be required for any new facility or construction within the tree protection zone (TPZ) of a protected and/or designated tree, and may be required for others, including street trees as deemed necessary by the City Arborist. The report shall be consistent with the City Tree Technical Manual and shall be prepared by an ISA certified Arborist. See Overview of Regulated Trees. If required, this report shall also be incorporated into the project plans.  Twelve (12) color hardcopies of a project description that includes the following information, at minimum: • the existing and proposed use at the proposed location, • the proposed wireless carrier, • the purpose and goals for the wireless facility (e.g. network design, frequency bands, new technology use), • the proposed scope of work, including work above and below ground, • the dimensions and volume of the antenna and the dimensions and volume of other additional equipment and the overall facility, • the efforts taken to minimize visual impacts of the proposed design (e.g. substantial setback from major roads, presence of trees, stealth design, slim line monopole, reducing the number of proposed facilities, increasing distances from nearby windows and other openings; placing some equipment in an underground vault, avoidance of scenic corridors or gateways, avoidance of nearby historic buildings), • map and the pole numbers for the alternative project locations considered, including in regard to network design, search ring/polygons, and specific site selection criteria, as well as a description of the reasons why these alternatives were not selected as the WCF proposed, • graphic portrayal and description of the proposed design and the alternative designs considered, • the efforts to locate at existing wireless facilities, • the basis of how the project qualifies as a Tier 2 WCF under PAMC Section 18.42.110, • identification of the underlying Master License Agreement, if any, • statement that clarifies if the application materials contain more than one wireless communication facility, • statement that clarifies that either the application materials show one or more wireless communication facilities that meet all of the City’s rules, regulations, and Objective Standards or a detailed statement detailing any and all requested WCF exceptions to any of the City’s rules, regulations, or Objective Standards (See PAMC Section 18.42.110(k) for more information on requesting exceptions. The WCF exception(s) must satisfy the requirements of PAMC Section 18.42.110(k) and demonstrate why the rule, regulation, or Objective Standard is infeasible), 4 4 4 4 4 Item 2 Attachment E - Submittal Checklist for Tier 2 and 3 WCFs in Public ROW     Packet Pg. 45     TIER 2 WCF PROPOSED FOR THE PUBLIC RIGHT-OF-WAY APPLICATION SUBMITTAL REQUIREMENTS CHECKLIST December 2019 Page 4 of 7 • clarification of the materials, colors, and construction methods to be used, • clarification if one or more wireless communication facilities will generate any noise, • clarification on how any future expansion, including the addition of 5G equipment if not currently proposed, would be designed in accordance with applicable laws and the City’s Objective Standards, • list of all wireless communication facilities proposed in application, including the applicant site identification number, closest adjacent APN, address of closest adjacent APN, existing zoning district, existing underground utility district number (if any), existing pole number, existing pole height, proposed pole height with facility, and proposed color of facility.  Twelve (12) hardcopies of a reduced-size (minimum of 11” x 17” and maximum 18” x 24”) set of bound project plans that include a north arrow, a graphic scale, and a notation of the drawing scale as either at 1/8” or 1/4” scale. All sheets shall be oriented in the same direction. Plans shall be legible and internally consistent. Plans shall include all information necessary for permitting and construction, as they will be the same plans submitted for Electrical permits, Street Work Permits, and/or Encroachment Permits. Applicants are encouraged to provide additional information where helpful. Project data and site information listing the wireless communication facility(ties) proposed in the application, applicant site identification number(s), latitude/longitude coordinates, elevation(s), closest adjacent parcels, address(es) of closest adjacent parcels, historic status of closest adjacent parcels, roadway type at the proposed location (expressway, arterial, residential arterial, collector, or local roadway), existing zoning district(s), existing underground utility district number (if any), existing pole number(s), and a brief description of work. Vicinity map showing the location of the proposed wireless communication facility within the City of Palo Alto. Location map showing north arrow, scale, parcel lines, and the distance and location of scenic routes, residence(s), schools, and other WCF facilities within 600 feet of the proposed wireless communication facility. Stamped and signed site survey of the wireless communication facility site area and pole completed within the last 12 months serving as the basis for other plan sheets. Stamped and signed structural/loading calculations completed for the proposed wireless communication facility design. Separate and detailed existing and proposed site/landscape/utility plans of the wireless communication facility site area including the following information: • North arrow (orient all sheets in the same direction), • Scale (1/8 minimum), • Dimensioned property lines and location of the right of way, including streets, paths, curb lines, sidewalks, planting strips, driveways, curb cuts, and utility lines, • Dimensioned residential zone of exclusion area, if the WCF is proposed in a residential zoning district, • Existing and proposed above ground and underground site improvements in the right-of- way within 50 feet of the proposed wireless communication facility, including signs, light fixtures, bicycle parking, trash and recycling (including proposed containers or related equipment), enclosures, fences, backflow preventers, above-ground electrical utilities, 4 Item 2 Attachment E - Submittal Checklist for Tier 2 and 3 WCFs in Public ROW     Packet Pg. 46     TIER 2 WCF PROPOSED FOR THE PUBLIC RIGHT-OF-WAY APPLICATION SUBMITTAL REQUIREMENTS CHECKLIST December 2019 Page 5 of 7 boxes, transformers, meter mains, fire standpipes, vaults, underground utilities (sewer, gas, electric, water), communication facilities (fiber optic, conduit and any other facilities), and similar. (Applicants must submit a Utility Map Request form in order to receive existing underground utilities information), • Easements, encumbrances, and/or roadway special setback lines, • Proposed species and size for any new trees and the location, species, size, dripline area, and any necessary tree protection zone (TPZ) for all existing trees within 50 feet of the site area, including trees on neighboring properties that overhang the wireless communication facility site area. Dimension the distance from trees to the work area when the tree is located closer than 10’ to proposed construction, • Footprint of all buildings and structures on adjacent parcels with distances from the proposed WCF indicated, • Creeks or waterways on or adjacent to the site, • Azimuth direction(s), • Distance to closest habitable/occupied structure for each azimuth proposed or distance to closest habitable/occupied structures in each direction if an omni-directional antenna is proposed, • Pole quadrants showing proposed and existing risers, location of climbing space and/or working space and location of proposed and existing attached equipment, • Single line diagram, equipment grounding diagrams, and panel schedule, • Plan showing all proposed conduits or substructures, location of directional bores, receiving and exit pits indicated, size(s) of bore pits, boring profiles at utility crossings, location, size and extent of trenching, location and size of potholing, and volume of soil to be disturbed in cubic feet. Additional information to include in project plans: • Information necessary to determine GO 95 compliance, • Model number and manufacturer dimensioned diagrams of proposed equipment, mounting brackets, shrouding, underground vaults and associated equipment, • Manufacturer’s pole specifications, decorative features (if any) and details, • Equipment volume information summary with dimensioned front and side elevations that can be used to confirm equipment volume. Project elevations, sections, and schematic details: • Elevations showing all existing conditions, including all existing pole features and attachments and all proposed pole features and attachments. Elevations shall include all sides of the wireless communication facility, all existing and proposed signage and lighting, notation of grade elevation from where the maximum height is measured, notations of the type, colors, materials and finish for all project elements, notations of the height and dimensions for all project elements, and notations of the point of service for power, fiber, and similar, • Illustrative vertical section including foundation to maximum height in context with surrounding site features, such as curb lines, sidewalks, electrical lines, communication lines, landscaping features, trees, and underground structures (drawing should be at a minimum of ½” = 1’ scale), • Illustrative horizontal section(s) showing the attachments and clearances for equipment and conduit mounted to pole(s), • Schematic details demonstrating the quality and nature of the wireless communication facility design and code compliance of the design, including details of structural Item 2 Attachment E - Submittal Checklist for Tier 2 and 3 WCFs in Public ROW     Packet Pg. 47     TIER 2 WCF PROPOSED FOR THE PUBLIC RIGHT-OF-WAY APPLICATION SUBMITTAL REQUIREMENTS CHECKLIST December 2019 Page 6 of 7 connections and attachments and the aesthetic details of how adjacent, dissimilar materials connect. Examples include: mounting of the equipment to poles and wires and cabling behind shrouds or internal to the pole, • Details, colors, and text of all new safety, power disconnect, and other signage and location/method of attachment. Color photographs: Photos of the existing site showing the relationship of the proposed wireless communication facility to adjacent buildings and to the neighborhood. Color visual simulation(s): Visual simulations prepared to scale comparing existing and proposed conditions and context utilizing views consistent with the existing and proposed elevations. Lighting plan (if any changes to existing lighting are proposed or required) showing photometric drawings including foot-candle numbers and catalog cut sheets of proposed exterior fixtures. Urban Forestry Division Standard Tree Protection Plan Sheet (T-1) filled out and signed by the property owner or applicant. When required, include completed Tree Protection Report(s) as Sheet T-2 and T-3. Current City Standard Specifications sheets: DWGs 401, 402, 403, 404, and 405. Standard Public Works Engineering Services Standard Sheets (Stormwater Pollution Prevention and Standard Conditions). Traffic Logistics and Control Plan. Does Applicant seek an exception from any of the City’s rules, regulations, or Objective Standards applicable to the application? Yes No (If “Yes,” provide a description of the specific exceptions sought and the manner in which the application complies with all applicable rules, regulations, and Objective Standards to the greatest extent feasible.) Does Applicant allege that strict application on a City rule, regulation, or Objective Standard or failure to approve this application will violate preemptive state or federal law? Yes No (If “Yes,” provide all documentation to support allegation.) Certification under Penalty of Perjury I declare under penalty of perjury that the foregoing is true and correct. Executed on (date) at (location), California. Name (print): Signature: Relationship to the Applicant of Record: Allegation is limited to failure to approve; see attached statement. Daly City8/14/2026 Tasha Stack Contractor, NextEdge Networks Holdings LLC, agent for AT&T Mobility 4 4 Item 2 Attachment E - Submittal Checklist for Tier 2 and 3 WCFs in Public ROW     Packet Pg. 48     TIER 2 WCF PROPOSED FOR THE PUBLIC RIGHT-OF-WAY APPLICATION SUBMITTAL REQUIREMENTS CHECKLIST December 2019 Page 7 of 7 Please coordinate with Planning staff regarding the following items: • One (1) hardcopy and one (1) electronic copy of a Community Meeting notice and affidavit containing proof that the applicant noticed and hosted the community meeting and a summary of comments received at the community meeting and what, if any, changes were made to the application as a result of the meeting, per PAMC Section 18.42.100(d)(7). This item may be submitted up to 15 days after initial application submittal. • One (1) electronic copy of photos showing notice board sign installation. During the intake appointment, the applicant will receive a notice board sign from the City for each proposed wireless communication facility location. The applicant shall affix a site plan, elevation, and streetscape image of the proposed wireless facility design to the notice board sign. The notice board sign shall be prominently displayed so that it can be viewed from the sidewalk or elsewhere in the public right of way and shall remain in place until any entitlement decision is effective. Photographs of the notice board sign installed at the proposed location shall be submitted to the City within three (3) days of application submittal. Item 2 Attachment E - Submittal Checklist for Tier 2 and 3 WCFs in Public ROW     Packet Pg. 49     FA #: 16969276 USID: 507989 SITE NAME: CRAN_RSFR_PALO4_005 MobileComm Professionals, Inc. Your ISO 9001-2000 Certified, Quality Centric & Cost effective Services Partner SF_JX_2026 Page 1 of 13 Radio Frequency Safety Survey Report Predictive (RFSSRP) Jurisdictional Report Site Name: CRAN_RSFR_PALO4_005 FA# 16969276 USID: 507989 Site ID: CRAN_RSFR_PALO4_005 Address: (NEAR) 670 GUINDA STREET, PALO ALTO, CA 94301 County: SANTA CLARA Latitude: 37.450339 Longitude: -122.153229 Structure Type: UTILITY Property Owner: CITY OF PALO ALTO UTILITIES RFDS ID: 175558 Desktop Modeler: IXUS VERSION 4.18(0) Item 2 Attachment F - Radio Frequency Emissions Reports for the Two Sites     Packet Pg. 50     FA #: 16969276 USID: 507989 SITE NAME: CRAN_RSFR_PALO4_005 MobileComm Professionals, Inc. Your ISO 9001-2000 Certified, Quality Centric & Cost effective Services Partner SF_JX_2026 Page 2 of 13 Table of Contents 1.0 Introduction ............................................................................................................................................................................................................................................. 3 2.0 Background/FCC Rules and Regulations and Guidelines from OET 65 ............................................................................................................................................... 4 3.0 Review of Cellular Antenna Site Proposals............................................................................................................................................................................................ 7 4.0 Site Scale Map ..................................................................................................................................................................................................................................... 10 5.0 Certification .......................................................................................................................................................................................................................................... 11 Appendix A ................................................................................................................................................................................................................................................. 12 Appendix B ................................................................................................................................................................................................................................................. 13 Item 2 Attachment F - Radio Frequency Emissions Reports for the Two Sites     Packet Pg. 51     FA #: 16969276 USID: 507989 SITE NAME: CRAN_RSFR_PALO4_005 MobileComm Professionals, Inc. Your ISO 9001-2000 Certified, Quality Centric & Cost effective Services Partner SF_JX_2026 Page 3 of 13 1.0 Introduction MobileComm Professionals, Inc. has been contracted by AT&T Mobility LLC to produce a theoretical assessment of the potential radio frequency emissions at the proposed AT&T site. FCC OET Bulletin 65 – Edition 97-01 recommends that theoretical calculations should be done to yield a worst- case scenario. This theoretical analysis will provide a worst-case assessment of potential emissions and will assume all transmitters are operating at highest capacity and power. This will provide AT&T with a guideline of how to proceed with mitigating the site to ensure the site will be compliant with FCC regulations at any instance. For this MPE theoretical analysis, MobileComm considered the accessible areas of site to determine approximate field strength levels and to identify any areas with higher levels exceeding FCC MPE limits and then determined spatially averaged field levels in areas with highest fields. MobileComm has utilized computer generated model(s) in this Site Compliance Report. The modeling software that MobileComm used to create this report is IXUS. General Model Assumptions In this Site Compliance Report, it is assumed that all antennas are operating at full power at all times. MobileComm has furt her assumed 75% duty cycle of maximum radiated power for all TDD & FDD carriers. Obstructions (trees, buildings etc.) that would normally attenuate the signal are not taken into account. MobileComm obtained information used in this Site Compliance Report from AT&T (or approved vendors) which is considered reliable and believes them to be true and correct. Due to the complexity of some wireless sites, MobileComm performed this analysis and created this report utilizing best indus try practices and due diligence. Item 2 Attachment F - Radio Frequency Emissions Reports for the Two Sites     Packet Pg. 52     FA #: 16969276 USID: 507989 SITE NAME: CRAN_RSFR_PALO4_005 MobileComm Professionals, Inc. Your ISO 9001-2000 Certified, Quality Centric & Cost effective Services Partner SF_JX_2026 Page 4 of 13 2.0 Background/FCC Rules and Regulations and Guidelines from OET 65 When considering the contributions to field strength or power density from other RF sources, care should be taken to ensure t hat such variables as reflection and re-radiation are considered. In cases involving very complex sites predictions of RF fields may not be possible, and a measurement survey may be necessary. The process for determining compliance for other situations can be similarly accomplished using the techniq ues described in this section and in Supplement A to this bulletin that deals with radio and television broadcast operations. However, as mentioned above, at very complex sites measurements may be necessary. In the simple example shown in the below diagram, it is desired to determine the power density at a given location X meters f rom the base of a tower on which are mounted two antennas. One antenna is a CMRS antenna with several channels, and the other is an FM broadcast antenna. The system parameters that must be known are the total ERP for each antenna and the operating frequencies (to determine which MPE limits apply). The heights above ground level for each antenna, H1 and H2, must be known in order to ca lculate the distances, R1and R2, from the antennas to the point of interest. Item 2 Attachment F - Radio Frequency Emissions Reports for the Two Sites     Packet Pg. 53     FA #: 16969276 USID: 507989 SITE NAME: CRAN_RSFR_PALO4_005 MobileComm Professionals, Inc. Your ISO 9001-2000 Certified, Quality Centric & Cost effective Services Partner SF_JX_2026 Page 5 of 13 This summarizes the policies, guidelines and requirements that were adopted by the FCC on August 1, 1996, amending Part 1 of Title 47 of the Code of Federal Regulations, and further amended by action of the Commission on August 25, 1997 (see 47 CFR Sections 1.1307(b), 1.1310, 2.1091 and 2.1093, as amended from FCC “OET Bulletin 65”). Commission actions granting construction permits, licenses to transmit or ren ewals thereof, equipment authorizations or modifications in existing facilities, require the preparation of an Environmental Assessment (EA), as described in 47 CFR Section 1.1311, if the particular facility, operation or transmitter would cause human exposure to levels of radiofrequency (RF) electromagnetic fields in excess of these limits. For exact language, see the relevant FCC rule sections. The FCC-adopted limits for Maximum Permissible Exposure (MPE) are generally based on recommended exposure guidelines published by the National Council on Radiation Protection and Measurements (NCRP) in "Biological Effects and Exposure Criteria for Radiofrequency Elect romagnetic Fields," NCRP Report No. 86, Sections 17.4.1, 17.4.1.1, 17.4.2 and 17.4.3. Copyright NCRP, 1986, Bethesda, Maryland 20814. In the frequency range from 100 MHz to 1500 MHz, exposure limits for field strength and power density are also generally based on the MPE limits found in Section 4.1 of, "IEEE Standard for Safety Levels with Respect to Human Exposure to Radio Frequency Electromagnetic Fields, 3 kHz to 300 GHz," ANSI/IEEE C95.1-1992, Copyright 1992 by the Institute of Electrical and Electronics Engineers, Inc., New York, New York 10017, and approved for use as an American National Standard by the American National Standards Institute (ANSI). The exposure guidelines are based on thresholds for known adver se effects and they incorporate a significant margin of safety. The federal health and safety agencies such as: the Environmental Protection Agency (”EPA”), the Food and Drug Administration (”FDA”), the National Institute on Occupational Safety and Health (”NIOSH”) and the Occupational Safety and Health Administration (”OSHA”) have also been actively involved in monitoring and investigating issues related to RF exposure. FCC regulations define two separate tiers of exposure limits: Occupational or “Controlled environment” and General Population or “Uncontrolled environment”. The General Population limits are generally five times more conservative or restrictive than the Oc cupational limit. These limits apply to accessible areas where workers or the General Population may be exposed to Radio Frequency (RF) electromagnetic fields. Occupational or Controlled limits apply in situations in which persons are exposed as a consequence of their employment and w here those persons exposed have been made fully aware of the potential for exposure and can exercise control over their exposure. An area is considered a Controlled environment when access is limited to these aware personnel. Typical criteria are restrict ed access (i.e. locked or alarmed doors, barriers, etc.) to the areas where antennas are located coupled with proper RF warning signage. A site with Controlled environments is evaluated with Occupational limits. All other areas are considered Uncontrolled environments. If a site has no access controls or no RF warning signage it is eva luated with General Population limits. The formulas used in IXUS for calculating Power density is based on FCC “OET Bulletin 65”, Section 2: PREDICTION METHODS, August 1997, Edition 97-01. Power density is converted to Maximum Permissible Exposure Limits (MPE Limits) based on Limits of General population/Uncontrolled Exposure and Limits of Occupational/Controlled Exposure presented in the following table generated from Appendix A of “OET Bulletin 65”. Item 2 Attachment F - Radio Frequency Emissions Reports for the Two Sites     Packet Pg. 54     FA #: 16969276 USID: 507989 SITE NAME: CRAN_RSFR_PALO4_005 MobileComm Professionals, Inc. Your ISO 9001-2000 Certified, Quality Centric & Cost effective Services Partner SF_JX_2026 Page 6 of 13 Limits for Occupational/Controlled Exposure Frequenc y Range (MHz) Power Density (S) (mW/cm2) Averaging Time |E|2, |H|2, or S (minutes) 300-1500 f/300 6 1500- 100,000 5 6 Limits for General Population/Uncontrolled Exposure Frequency Range (MHz) Power Density (S) (mW/cm2) Averaging Time |E|2, |H|2, or S (minutes) 300-1500 f/1500 30 1500- 100,000 1 30 Item 2 Attachment F - Radio Frequency Emissions Reports for the Two Sites     Packet Pg. 55     FA #: 16969276 USID: 507989 SITE NAME: CRAN_RSFR_PALO4_005 MobileComm Professionals, Inc. Your ISO 9001-2000 Certified, Quality Centric & Cost effective Services Partner SF_JX_2026 Page 7 of 13 3.0 Review of Cellular Antenna Site Proposals 1. The location, identity and total number of all operational radiating antennas installed at this site. There are no existing wireless base stations installed at the site. 2. List all radiating antennas located within 100 feet of the site which could contribute to the cumulative radio frequency energy at this location. There are no other radiating antennas/wireless base stations identified facilities within 100 feet of the site. 3. Provide a narrative description of the proposed work for this project. AT&T proposes to install one new omnidirectional/cardioid antenna on top of a Wooden Utility Pole. 4. Provide an inventory of the make and model of antennas or transmitting equipment being installed or removed. The AT&T Equipment proposed to be INSTALLED at this site is as follows: Antenna Mfg Antenna Model Antenna Type Quantity Orientation (°) Antenna Radiation Centerline (ft) Z-Height from Primary Line (ft) Z-Height from Light (ft) Z-Height from Adjacent Roof (ft) Z-Height from Ground (ft) GAMMA NU DY12X360F8T0 Omni 1 0 52.75 7.75 22.92 33.75 51.75 5. Describe the existing radio frequency energy environment at the nearest walking/working surface to the antennas and at ground level. This description may be based on field measurements or calculations. Since there are no antennas existing at this site, there is no current RF Exposure from AT&T. Item 2 Attachment F - Radio Frequency Emissions Reports for the Two Sites     Packet Pg. 56     FA #: 16969276 USID: 507989 SITE NAME: CRAN_RSFR_PALO4_005 MobileComm Professionals, Inc. Your ISO 9001-2000 Certified, Quality Centric & Cost effective Services Partner SF_JX_2026 Page 8 of 13 6. Provide the maximum effective radiated power per sector for the proposed installation. The power should be reported in Watts and reported both as a total and broken down by the frequency band. The Effective Radiated Power (watts) per frequency band and per sector is as follows: ANT ID Operator Antenna Mfg Antenna Model Antenna Type Freq (MHz) Tech Az (°) HBW (°) Antenna Gain (dBd) Antenna Aperture (ft) Transmitter Power (Watts) Total Loss (dB) Total ERP (Watts) Total ERP Per Sector (Watts) Q1 AT&T GAMMA NU DY12X360F8T0 Omni 700(B12) LTE 0 360 4.15 2 240 0.5 912.01 4735.39 850 5G 360 5.65 240 0.5 1288.25 3840 5G 360 10.35 160 0.5 2535.13 7. Based on the antenna orientation, describe the maximum cumulative predicted radio frequency energy level for any nearby publicly accessible building or area. The maximum predicted RF Exposure at any nearby building is to be 0.00183 mW/cm2, which is 1.83% of the FCC GP Limits; this occurs on the top of Adjacent Roof that is located at (Near) 670 Guinda Street, Palo Alto, about 32 feet away the closest AT&T antenna. 8. Report the estimated cumulative radio frequency fields for the proposed site at ground level. For a person anywhere at ground, the maximum RF exposure level due to the proposed AT&T Operation is calculated to be 0.001 mW/cm2, which is 1.00% of the applicable public exposure limit. Cumulative RF levels at ground level near the site are therefore estimated to be w ell below the applicable public limit Cumulative RF levels at ground level near the site are therefore estimated to be well below the applicable public limit. Item 2 Attachment F - Radio Frequency Emissions Reports for the Two Sites     Packet Pg. 57     FA #: 16969276 USID: 507989 SITE NAME: CRAN_RSFR_PALO4_005 MobileComm Professionals, Inc. Your ISO 9001-2000 Certified, Quality Centric & Cost effective Services Partner SF_JX_2026 Page 9 of 13 9. Provide the maximum distance (in feet) the three-dimensional perimeter of the radio frequency energy level equal to the public and occupational exposure limit is calculated to extend from the face of the antennas. The three-dimensional perimeters of RF levels (General Population & Occupational) are as below: Horizontal Safe Distance (ft.) from Antenna Face (General Population Limits) 18 Exposure is in free space. Vertical Safe Distance Below Lowest Antenna Bottom Tip (ft.) (General Population Limits) 5 Horizontal Safe Distance (ft.) from Antenna Face (Occupational Limits) 6 Vertical Safe Distance Below Lowest Antenna Bottom Tip (ft.) (Occupational Limits) 3 10. Provide a description of whether or not the public has access to the antennas. Describe any existing or proposed warning signs, barricades, barriers, rooftop striping or other safety precautions for people nearing the equipment as may be required by any applicable FCC-adopted standards. Due to the proposed elevated installation of the antenna on top of Wooden Utility Pole, it is considered to be that the antenna(s) is inaccessible to the general public. Since there are no antennas existing at this site, there are no existing RF Signs by AT&T. To comply with the FCC Rules and Regulations, AT&T Mobility is required to take below listed action(s) to make the site compliant. Two Caution Signs with dimensions 7” x 7” to be posted 5 feet beneath the antenna (Ant. #Q1) or, in the event of an obstruction or other impediment to such placement, within 1 foot above or below that location. The Caution signs must specify that a distance of 18 feet must be kept from the antenna as shown in “Site Scale Map” on page 10. Item 2 Attachment F - Radio Frequency Emissions Reports for the Two Sites     Packet Pg. 58     FA #: 16969276 USID: 507989 SITE NAME: CRAN_RSFR_PALO4_005 MobileComm Professionals, Inc. Your ISO 9001-2000 Certified, Quality Centric & Cost effective Services Partner SF_JX_2026 Page 10 of 13 4.0 Site Scale Map Item 2 Attachment F - Radio Frequency Emissions Reports for the Two Sites     Packet Pg. 59     FA #: 16969276 USID: 507989 SITE NAME: CRAN_RSFR_PALO4_005 MobileComm Professionals, Inc. Your ISO 9001-2000 Certified, Quality Centric & Cost effective Services Partner SF_JX_2026 Page 11 of 13 5.0 Certification This report has been prepared by or under the direction of the following Registered Professional Engineer: I, P.E. State: on date: hereby certify that: I am registered as a Professional Engineer with License number: a nd that I am thoroughly familiar with the Regulations of the Federal Communications Commission (FCC), both in general and specifically as they apply to FCC guidelines for human exposure to Radio -frequency electromagnetic radiation and that EME theoretical analysis for site identified as 16969276 located at (NEAR) 670 GUINDA STREET, PALO ALTO, CA 94301 has been performed on 07-31-2026 in order to determine where there might be electromagnetic energy that is in excess of both the Controlled Environment and Uncontrolled Environment levels; and that I have thoroughly reviewed this Site Compliance Report and believe it to be true and accurate to the best of my knowledge. Item 2 Attachment F - Radio Frequency Emissions Reports for the Two Sites     Packet Pg. 60     FA #: 16969276 USID: 507989 SITE NAME: CRAN_RSFR_PALO4_005 MobileComm Professionals, Inc. Your ISO 9001-2000 Certified, Quality Centric & Cost effective Services Partner SF_JX_2026 Page 12 of 13 Appendix A Occupational Safety and Health Administration (OSHA) Requirements OSHA requires that those in the Occupational classification must complete training in RF Safety, RF Awareness, and Utilizatio n of Personal Protective Equipment. OSHA also provides options for Hazard Prevention and Control: Hazard Prevention Control • Utilization of good equipment • Enact control of hazard areas • Limit exposures • Employ medical surveillance and accident response • Employ Lockout/Tag out • Utilize personal alarms & protective clothing • Prevent access to hazardous locations • Develop or operate an administrative control program RF Signage and Barriers All RF signs should be obeyed by at all times. Post the appropriate NOTICE, CAUTION & WARNING sign at the main site access point(s) and other locations as required. The signs below are examples of signs meeting FCC guidelines If there are workers in an area with a sign that they do not understand, they can call the NOC Number at 800-638-2822 for guidance. All persons (arborist, landscapers, construction/utility workers, etc.) that are accessing adjacent elevated surfaces that exceed the General Public (GP) limits MPE must be made aware of these potential exceedances and their fields, where applicable. Item 2 Attachment F - Radio Frequency Emissions Reports for the Two Sites     Packet Pg. 61     FA #: 16969276 USID: 507989 SITE NAME: CRAN_RSFR_PALO4_005 MobileComm Professionals, Inc. Your ISO 9001-2000 Certified, Quality Centric & Cost effective Services Partner SF_JX_2026 Page 13 of 13 Appendix B Occupational limits Apply in situations in which persons are exposed as a consequence of their employment provided those persons are fully aware of the potential for exposure and can exercise control over their exposure. Limits for occupational/controlled exposure also apply in situations when an individual is transient through a location where occupational/controlled limits apply provided he or she is made aware of the potential for exposure. General population limits Apply in situations in which the General Population may be exposed, or in which persons that are exposed as a consequence of their employment may not be fully aware of the potential for exposure or cannot exercise control over their exposure. Controlled Environment Applies to environments that are restricted or “controlled” in order to prevent access from members of the General Population classification. Uncontrolled Environment Applies to environments that are unrestricted or “uncontrolled” that allow access from members of the General Population classification. Contribution to Co-Located areas Any wireless operator that contributes 5% or greater of the MPE limit in an area that is identified to be greater than 100% of the MPE limit is responsible for taking corrective actions to bring the site into compliance. Generic Values The use of “Unknown” for an operator means the information with regard to the carrier, their FCC license and / or antenna information was not available. Generic values are used as estimation for Effective Radiated Power (ERP) and antenna characteristics for unknown antennas. Item 2 Attachment F - Radio Frequency Emissions Reports for the Two Sites     Packet Pg. 62     FA #: 16969268 USID: 508055 SITE NAME: CRAN_RSFR_PALO4_006 MobileComm Professionals, Inc. Your ISO 9001-2000 Certified, Quality Centric & Cost effective Services Partner SF_JX_2026 Page 1 of 13 Radio Frequency Safety Survey Report Predictive (RFSSRP) Jurisdictional Report Site Name: CRAN_RSFR_PALO4_006 FA# 16969268 USID: 508055 Site ID: CRAN_RSFR_PALO4_006 Address: (NEAR) 754 HOMER AVE, PALO ALTO, CA 94301 County: SANTA CLARA Latitude: 37.449048 Longitude: -122.152316 Structure Type: UTILITY Property Owner: CITY OF PALO ALTO UTILITIES RFDS ID: 175562 Desktop Modeler: IXUS VERSION 4.18(0) Item 2 Attachment F - Radio Frequency Emissions Reports for the Two Sites     Packet Pg. 63     FA #: 16969268 USID: 508055 SITE NAME: CRAN_RSFR_PALO4_006 MobileComm Professionals, Inc. Your ISO 9001-2000 Certified, Quality Centric & Cost effective Services Partner SF_JX_2026 Page 2 of 13 Table of Contents 1.0 Introduction ............................................................................................................................................................................................................................................. 3 2.0 Background/FCC Rules and Regulations and Guidelines from OET 65 ............................................................................................................................................... 4 3.0 Review of Cellular Antenna Site Proposals............................................................................................................................................................................................ 7 4.0 Site Scale Map ..................................................................................................................................................................................................................................... 10 5.0 Certification .......................................................................................................................................................................................................................................... 11 Appendix A ................................................................................................................................................................................................................................................. 12 Appendix B ................................................................................................................................................................................................................................................. 13 Item 2 Attachment F - Radio Frequency Emissions Reports for the Two Sites     Packet Pg. 64     FA #: 16969268 USID: 508055 SITE NAME: CRAN_RSFR_PALO4_006 MobileComm Professionals, Inc. Your ISO 9001-2000 Certified, Quality Centric & Cost effective Services Partner SF_JX_2026 Page 3 of 13 1.0 Introduction MobileComm Professionals, Inc. has been contracted by AT&T Mobility LLC to produce a theoretical assessment of the potential radio frequency emissions at the proposed AT&T site. FCC OET Bulletin 65 – Edition 97-01 recommends that theoretical calculations should be done to yield a worst- case scenario. This theoretical analysis will provide a worst-case assessment of potential emissions and will assume all transmitters are operating at highest capacity and power. This will provide AT&T with a guideline of how to proceed with mitigating the site to ensure the site will be compliant with FCC regulations at any instance. For this MPE theoretical analysis, MobileComm considered the accessible areas of site to determine approximate field strength levels and to identify any areas with higher levels exceeding FCC MPE limits and then determined spatially averaged field levels in areas with highest fields. MobileComm has utilized computer generated model(s) in this Site Compliance Report. The modeling software that MobileComm used to create this report is IXUS. General Model Assumptions In this Site Compliance Report, it is assumed that all antennas are operating at full power at all times. MobileComm has furt her assumed 75% duty cycle of maximum radiated power for all TDD & FDD carriers. Obstructions (trees, buildings etc.) that would normally attenuate the signal are not taken into account. MobileComm obtained information used in this Site Compliance Report from AT&T (or approved vendors) which is considered reliable and believes them to be true and correct. Due to the complexity of some wireless sites, MobileComm performed this analysis and created this report utilizing best indus try practices and due diligence. Item 2 Attachment F - Radio Frequency Emissions Reports for the Two Sites     Packet Pg. 65     FA #: 16969268 USID: 508055 SITE NAME: CRAN_RSFR_PALO4_006 MobileComm Professionals, Inc. Your ISO 9001-2000 Certified, Quality Centric & Cost effective Services Partner SF_JX_2026 Page 4 of 13 2.0 Background/FCC Rules and Regulations and Guidelines from OET 65 When considering the contributions to field strength or power density from other RF sources, care should be taken to ensure t hat such variables as reflection and re-radiation are considered. In cases involving very complex sites predictions of RF fields may not be possible, and a measurement survey may be necessary. The process for determining compliance for other situations can be similarly accomplished using the techniq ues described in this section and in Supplement A to this bulletin that deals with radio and television broadcast operations. However, as mentioned above, at very complex sites measurements may be necessary. In the simple example shown in the below diagram, it is desired to determine the power density at a given location X meters f rom the base of a tower on which are mounted two antennas. One antenna is a CMRS antenna with several channels, and the other is an FM broadcast antenna. The system parameters that must be known are the total ERP for each antenna and the operating frequencies (to determine which MPE limits apply). The heights above ground level for each antenna, H1 and H2, must be known in order to ca lculate the distances, R1and R2, from the antennas to the point of interest. Item 2 Attachment F - Radio Frequency Emissions Reports for the Two Sites     Packet Pg. 66     FA #: 16969268 USID: 508055 SITE NAME: CRAN_RSFR_PALO4_006 MobileComm Professionals, Inc. Your ISO 9001-2000 Certified, Quality Centric & Cost effective Services Partner SF_JX_2026 Page 5 of 13 This summarizes the policies, guidelines and requirements that were adopted by the FCC on August 1, 1996, amending Part 1 of Title 47 of the Code of Federal Regulations, and further amended by action of the Commission on August 25, 1997 (see 47 CFR Sections 1.1307(b), 1.1310, 2.1091 and 2.1093, as amended from FCC “OET Bulletin 65”). Commission actions granting construction permits, licenses to transmit or ren ewals thereof, equipment authorizations or modifications in existing facilities, require the preparation of an Environmental Assessment (EA), as described in 47 CFR Section 1.1311, if the particular facility, operation or transmitter would cause human exposure to levels of radiofrequency (RF) electromagnetic fields in excess of these limits. For exact language, see the relevant FCC rule sections. The FCC-adopted limits for Maximum Permissible Exposure (MPE) are generally based on recommended exposure guidelines published by the National Council on Radiation Protection and Measurements (NCRP) in "Biological Effects and Exposure Criteria for Radiofrequency Elect romagnetic Fields," NCRP Report No. 86, Sections 17.4.1, 17.4.1.1, 17.4.2 and 17.4.3. Copyright NCRP, 1986, Bethesda, Maryland 20814. In the frequency range from 100 MHz to 1500 MHz, exposure limits for field strength and power density are also generally based on the MPE limits found in Section 4.1 of, "IEEE Standard for Safety Levels with Respect to Human Exposure to Radio Frequency Electromagnetic Fields, 3 kHz to 300 GHz," ANSI/IEEE C95.1-1992, Copyright 1992 by the Institute of Electrical and Electronics Engineers, Inc., New York, New York 10017, and approved for use as an American National Standard by the American National Standards Institute (ANSI). The exposure guidelines are based on thresholds for known adver se effects and they incorporate a significant margin of safety. The federal health and safety agencies such as: the Environmental Protection Agency (”EPA”), the Food and Drug Administration (”FDA”), the National Institute on Occupational Safety and Health (”NIOSH”) and the Occupational Safety and Health Administration (”OSHA”) have also been actively involved in monitoring and investigating issues related to RF exposure. FCC regulations define two separate tiers of exposure limits: Occupational or “Controlled environment” and General Population or “Uncontrolled environment”. The General Population limits are generally five times more conservative or restrictive than the Oc cupational limit. These limits apply to accessible areas where workers or the General Population may be exposed to Radio Frequency (RF) electromagnetic fields. Occupational or Controlled limits apply in situations in which persons are exposed as a consequence of their employment and w here those persons exposed have been made fully aware of the potential for exposure and can exercise control over their exposure. An area is considered a Controlled environment when access is limited to these aware personnel. Typical criteria are restrict ed access (i.e. locked or alarmed doors, barriers, etc.) to the areas where antennas are located coupled with proper RF warning signage. A site with Controlled environments is evaluated with Occupational limits. All other areas are considered Uncontrolled environments. If a site has no access controls or no RF warning signage it is eva luated with General Population limits. The formulas used in IXUS for calculating Power density is based on FCC “OET Bulletin 65”, Section 2: PREDICTION METHODS, August 1997, Edition 97-01. Power density is converted to Maximum Permissible Exposure Limits (MPE Limits) based on Limits of General population/Uncontrolled Exposure and Limits of Occupational/Controlled Exposure presented in the following table generated from Appendix A of “OET Bulletin 65”. Item 2 Attachment F - Radio Frequency Emissions Reports for the Two Sites     Packet Pg. 67     FA #: 16969268 USID: 508055 SITE NAME: CRAN_RSFR_PALO4_006 MobileComm Professionals, Inc. Your ISO 9001-2000 Certified, Quality Centric & Cost effective Services Partner SF_JX_2026 Page 6 of 13 Limits for Occupational/Controlled Exposure Frequenc y Range (MHz) Power Density (S) (mW/cm2) Averaging Time |E|2, |H|2, or S (minutes) 300-1500 f/300 6 1500- 100,000 5 6 Limits for General Population/Uncontrolled Exposure Frequency Range (MHz) Power Density (S) (mW/cm2) Averaging Time |E|2, |H|2, or S (minutes) 300-1500 f/1500 30 1500- 100,000 1 30 Item 2 Attachment F - Radio Frequency Emissions Reports for the Two Sites     Packet Pg. 68     FA #: 16969268 USID: 508055 SITE NAME: CRAN_RSFR_PALO4_006 MobileComm Professionals, Inc. Your ISO 9001-2000 Certified, Quality Centric & Cost effective Services Partner SF_JX_2026 Page 7 of 13 3.0 Review of Cellular Antenna Site Proposals 1. The location, identity and total number of all operational radiating antennas installed at this site. There are no existing wireless base stations installed at the site. 2. List all radiating antennas located within 100 feet of the site which could contribute to the cumulative radio frequency energy at this location. There are no other radiating antennas/wireless base stations identified facilities within 100 feet of the site. 3. Provide a narrative description of the proposed work for this project. AT&T proposes to install one new omnidirectional/cardioid antenna on top of a Wooden Utility Pole. 4. Provide an inventory of the make and model of antennas or transmitting equipment being installed or removed. The AT&T Equipment proposed to be INSTALLED at this site is as follows: Antenna Mfg Antenna Model Antenna Type Quantity Orientation (°) Antenna Radiation Centerline (ft) Z-Height from Primary Line (ft) Z-Height from Light (ft) Z-Height from Adjacent Roof (ft) Z-Height from Ground (ft) GAMMA NU DY12X360F8T0 Omni 1 0 52.42 8.09 28.92 36.42 51.42 5. Describe the existing radio frequency energy environment at the nearest walking/working surface to the antennas and at ground level. This description may be based on field measurements or calculations. Since there are no antennas existing at this site, there is no current RF Exposure from AT&T. Item 2 Attachment F - Radio Frequency Emissions Reports for the Two Sites     Packet Pg. 69     FA #: 16969268 USID: 508055 SITE NAME: CRAN_RSFR_PALO4_006 MobileComm Professionals, Inc. Your ISO 9001-2000 Certified, Quality Centric & Cost effective Services Partner SF_JX_2026 Page 8 of 13 6. Provide the maximum effective radiated power per sector for the proposed installation. The power should be reported in Watts and reported both as a total and broken down by the frequency band. The Effective Radiated Power (watts) per frequency band and per sector is as follows: ANT ID Operator Antenna Mfg Antenna Model Antenna Type Freq (MHz) Tech Az (°) HBW (°) Antenna Gain (dBd) Antenna Aperture (ft) Transmitter Power (Watts) Total Loss (dB) Total ERP (Watts) Total ERP Per Sector (Watts) Q1 AT&T GAMMA NU DY12X360F8T0 Omni 700(B12) LTE 0 360 4.15 2 240 0.5 912.01 4735.39 850 5G 360 5.65 240 0.5 1288.25 3840 5G 360 10.35 160 0.5 2535.13 7. Based on the antenna orientation, describe the maximum cumulative predicted radio frequency energy level for any nearby publicly accessible building or area. The maximum predicted RF Exposure at any nearby building is to be 0.00175 mW/cm2, which is 1.75% of the FCC GP Limits; this occurs on the top of Adjacent Roof that is located at (Near) 754 Homer Ave, Palo Alto, about 27 feet away the closest AT&T antenna. 8. Report the estimated cumulative radio frequency fields for the proposed site at ground level. For a person anywhere at ground, the maximum RF exposure level due to the proposed AT&T Operation is calculated to be 0.00101 mW/cm2, which is 1.01% of the applicable public exposure limit. Cumulative RF levels at ground level near the site are therefore estimated to be w ell below the applicable public limit Cumulative RF levels at ground level near the site are therefore estimated to be well below the applicable public limit. Item 2 Attachment F - Radio Frequency Emissions Reports for the Two Sites     Packet Pg. 70     FA #: 16969268 USID: 508055 SITE NAME: CRAN_RSFR_PALO4_006 MobileComm Professionals, Inc. Your ISO 9001-2000 Certified, Quality Centric & Cost effective Services Partner SF_JX_2026 Page 9 of 13 9. Provide the maximum distance (in feet) the three-dimensional perimeter of the radio frequency energy level equal to the public and occupational exposure limit is calculated to extend from the face of the antennas. The three-dimensional perimeters of RF levels (General Population & Occupational) are as below: Horizontal Safe Distance (ft.) from Antenna Face (General Population Limits) 18 Exposure is in free space. Vertical Safe Distance Below Lowest Antenna Bottom Tip (ft.) (General Population Limits) 5 Horizontal Safe Distance (ft.) from Antenna Face (Occupational Limits) 6 Vertical Safe Distance Below Lowest Antenna Bottom Tip (ft.) (Occupational Limits) 3 10. Provide a description of whether or not the public has access to the antennas. Describe any existing or proposed warning signs, barricades, barriers, rooftop striping or other safety precautions for people nearing the equipment as may be required by any applicable FCC-adopted standards. Due to the proposed elevated installation of the antenna on top of Wooden Utility Pole, it is considered to be that the antenna(s) is inaccessible to the general public. Since there are no antennas existing at this site, there are no existing RF Signs by AT&T. To comply with the FCC Rules and Regulations, AT&T Mobility is required to take below listed action(s) to make the site compliant. Two Caution Signs with dimensions 7” x 7” to be posted 5 feet beneath the antenna (Ant. #Q1) or, in the event of an obstruction or other impediment to such placement, within 1 foot above or below that location. The Caution signs must specify that a distance of 18 feet must be kept from the antenna as shown in “Site Scale Map” on page 10. Item 2 Attachment F - Radio Frequency Emissions Reports for the Two Sites     Packet Pg. 71     FA #: 16969268 USID: 508055 SITE NAME: CRAN_RSFR_PALO4_006 MobileComm Professionals, Inc. Your ISO 9001-2000 Certified, Quality Centric & Cost effective Services Partner SF_JX_2026 Page 10 of 13 4.0 Site Scale Map Item 2 Attachment F - Radio Frequency Emissions Reports for the Two Sites     Packet Pg. 72     FA #: 16969268 USID: 508055 SITE NAME: CRAN_RSFR_PALO4_006 MobileComm Professionals, Inc. Your ISO 9001-2000 Certified, Quality Centric & Cost effective Services Partner SF_JX_2026 Page 11 of 13 5.0 Certification This report has been prepared by or under the direction of the following Registered Professional Engineer: I, P.E. State: on date: hereby certify that: I am registered as a Professional Engineer with License number: a nd that I am thoroughly familiar with the Regulations of the Federal Communications Commission (FCC), both in general and specifically as they apply to FCC guidelines for human exposure to Radio -frequency electromagnetic radiation and that EME theoretical analysis for site identified as 16969268 located at (NEAR) 754 HOMER AVE, PALO ALTO, CA 94301 has been performed on 07-31-2026 in order to determine where there might be electromagnetic energy that is in excess of both the Controlled Environment and Uncontrolled Environment levels; and that I have thoroughly reviewed this Site Compliance Report and believe it to be true and accurate to the best of my knowledge. Item 2 Attachment F - Radio Frequency Emissions Reports for the Two Sites     Packet Pg. 73     FA #: 16969268 USID: 508055 SITE NAME: CRAN_RSFR_PALO4_006 MobileComm Professionals, Inc. Your ISO 9001-2000 Certified, Quality Centric & Cost effective Services Partner SF_JX_2026 Page 12 of 13 Appendix A Occupational Safety and Health Administration (OSHA) Requirements OSHA requires that those in the Occupational classification must complete training in RF Safety, RF Awareness, and Utilizatio n of Personal Protective Equipment. OSHA also provides options for Hazard Prevention and Control: Hazard Prevention Control • Utilization of good equipment • Enact control of hazard areas • Limit exposures • Employ medical surveillance and accident response • Employ Lockout/Tag out • Utilize personal alarms & protective clothing • Prevent access to hazardous locations • Develop or operate an administrative control program RF Signage and Barriers All RF signs should be obeyed by at all times. Post the appropriate NOTICE, CAUTION & WARNING sign at the main site access point(s) and other locations as required. The signs below are examples of signs meeting FCC guidelines If there are workers in an area with a sign that they do not understand, they can call the NOC Number at 800-638-2822 for guidance. All persons (arborist, landscapers, construction/utility workers, etc.) that are accessing adjacent elevated surfaces that exceed the General Public (GP) limits MPE must be made aware of these potential exceedances and their fields, where applicable. Item 2 Attachment F - Radio Frequency Emissions Reports for the Two Sites     Packet Pg. 74     FA #: 16969268 USID: 508055 SITE NAME: CRAN_RSFR_PALO4_006 MobileComm Professionals, Inc. Your ISO 9001-2000 Certified, Quality Centric & Cost effective Services Partner SF_JX_2026 Page 13 of 13 Appendix B Occupational limits Apply in situations in which persons are exposed as a consequence of their employment provided those persons are fully aware of the potential for exposure and can exercise control over their exposure. Limits for occupational/controlled exposure also apply in situations when an individual is transient through a location where occupational/controlled limits apply provided he or she is made aware of the potential for exposure. General population limits Apply in situations in which the General Population may be exposed, or in which persons that are exposed as a consequence of their employment may not be fully aware of the potential for exposure or cannot exercise control over their exposure. Controlled Environment Applies to environments that are restricted or “controlled” in order to prevent access from members of the General Population classification. Uncontrolled Environment Applies to environments that are unrestricted or “uncontrolled” that allow access from members of the General Population classification. Contribution to Co-Located areas Any wireless operator that contributes 5% or greater of the MPE limit in an area that is identified to be greater than 100% of the MPE limit is responsible for taking corrective actions to bring the site into compliance. Generic Values The use of “Unknown” for an operator means the information with regard to the carrier, their FCC license and / or antenna information was not available. Generic values are used as estimation for Effective Radiated Power (ERP) and antenna characteristics for unknown antennas. Item 2 Attachment F - Radio Frequency Emissions Reports for the Two Sites     Packet Pg. 75     NextEdge Networks Holdings LLC 1355 Windward Concourse, Suite 410, Alpharetta, GA 30005 On behalf of AT&T Mobility FCC LOCAL AND STATE GOVERNMENT ADVISORY COMMITTEE Optional Checklist for Local Government To Determine Whether a Facility is Categorically Excluded Appendix A to A Local Government Official’s Guide to Transmitting Antenna RF Emission Safety: Rules, Procedures, and Practical Guidance (June 2000) Completed for three Tier 2 Wireless Communication Facilities proposed for the public right-of-way, City of Palo Alto, California: CRAN_RSFR_PALO4_004, CRAN_RSFR_PALO4_005 and CRAN_RSFR_PALO4_006. A separate Appendix A is completed for each facility. Each is followed by the page 2 evaluation of categorical exclusion. A technical annex at the end identifies the source document for every value entered. Prepared August 14, 2026. SUMMARY OF RESULT All three facilities satisfy box 16 and are categorically excluded. Each is operated in part in the Cellular Radiotelephone Service, none is mounted on a building, and the lowest point of the antenna at every site is between 50.92 and 51.75 feet above ground, well above the 32.8 foot (10 meter) threshold. Questions 17 through 21 have nonetheless been completed. AT&T does not rely on categorical exclusion alone at these sites. Because the facilities also operate under 47 C.F.R. Part 27, which carries no height exemption, a site-specific maximum permissible exposure evaluation was performed for each facility by MobileComm (RF Site Safety and Regulatory Package, EME analysis dated July 31, 2026). That evaluation, not the checklist, is the operative demonstration of compliance with 47 C.F.R. § 1.1310, and it is provided with this submittal. The General Public compliance boundary at every site lies entirely above 45 feet 11 inches above ground level and is not accessible from any publicly accessible surface. No location accessible to the public at any of the three sites is within the General Public boundary. Item 2 Attachment F - Radio Frequency Emissions Reports for the Two Sites     Packet Pg. 76     CRAN_RSFR_PALO4_004 Public right-of-way near 804 Boyce Avenue, Palo Alto, California 94301 APPENDIX A — BACKGROUND INFORMATION Item Response 1.Facility Operator’s Legal Name New Cingular Wireless PCS, LLC, a Delaware limited liability company, d/b/a AT&T Mobility 2.Facility Operator’s Mailing Address New Cingular Wireless PCS, LLC, Attn: Network Real Estate Administration 12555 Cingular Way, Suite 1300, Alpharetta, Georgia 30004 RF engineering office: AT&T Mobility, Network Planning & Engineering, RAN Design & RF Engineering, 5005 Executive Parkway, San Ramon, California 94583 3.Facility Operator’s Contact Name/Title Jeric Lizardo, Radio Frequency Engineer, AT&T Mobility (technical/RF contact) Tasha Stack, Contractor, NextEdge Networks Holdings LLC (authorized agent and applicant contact) 4.Facility Operator’s Office Telephone AT&T Network Operations Center: (800) 638-2822 · Authorized agent: (925) 954-4885 5.Facility Operator’s Fax None. AT&T Mobility does not maintain a facsimile number for this program. 6.Facility Name CRAN_RSFR_PALO4_004 7.Facility Address Public right-of-way near 804 Boyce Avenue Host structure: City of Palo Alto Utilities wood distribution pole No. 5919 8.Facility City/Community Palo Alto, County of Santa Clara 9.Facility State and Zip Code California 94301 10.Latitude 37.449006 N (NAD83) 11.Longitude 122.150669 W (NAD83) OPTIONAL LOCAL GOVERNMENT CHECKLIST (PAGE 2) — EVALUATION OF CATEGORICAL EXCLUSION Item Response 12.Licensed Radio Service Cellular Radiotelephone Service, 47 C.F.R. Part 22, Subpart H (850 MHz, Band 5 / n5); and Wireless Communications Service, 47 C.F.R. Part 27 (700 MHz Band 12 LTE and 3.7–3.98 GHz C-Band, n77) 13.Structure Type Free-standing. Existing utility pole within the public right-of-way. Not building-mounted and not roof-mounted. 14.Antenna Type Omnidirectional. Gamma Nu DY12X360F8T0 pseudo-omni canister antenna, 360 degrees, single sector. 15.Height above ground of the lowest point of the antenna 50.92 feet (50 -11″) above ground level.′ Radiation center 51 -11″; top of canister 52 -11″.′ ′ Item 2 Attachment F - Radio Frequency Emissions Reports for the Two Sites     Packet Pg. 77     16.☒Checked. All three conditions are true. (a)True. The facility is operated in the Cellular Radiotelephone Service (47 C.F.R. Part 22, Subpart H). (b)True. The facility is not mounted on a building. It is carried on an existing wood distribution pole in the public right-of-way. (c)True. The lowest point of the antenna is 50.92 feet (50 -11″) above ground, which exceeds 32.8 feet (10 ′ meters). Box 16 is checked. Under the instruction on page 2 of the checklist, this facility is categorically excluded and the remainder of the checklist need not be completed. Questions 17 through 21 are answered below on a voluntary basis for the Part 27 component of the facility, for which Table 1 provides no height exemption. Item Response 17.Power threshold for categorical exclusion (Table 1) Part 22, Subpart H (Cellular Radiotelephone Service): 1,000 W ERP (1,640 W EIRP) total of all channels, and only where the lowest point of the antenna is below 10 meters. The height condition is not met here, so no evaluation is required. Part 27 (Wireless Communications Service): 1,640 W EIRP total of all channels. No height condition applies. 18.Total number of channels (omnidirectional antenna) Three, on a single omnidirectional sector: one 700 MHz (Band 12) LTE carrier, one 850 MHz 5G NR carrier, and one 3840 MHz C-Band 5G NR carrier. 19.ERP or EIRP per channel 700 MHz (B12) LTE: 912.01 W ERP (1,495.70 W EIRP) 850 MHz 5G NR: 1,288.25 W ERP (2,112.73 W EIRP) 3840 MHz C-Band 5G NR: 2,535.13 W ERP (4,157.61 W EIRP) Source: RF Site Safety and Regulatory Package, Item 6, effective radiated power per frequency band and per sector. 20.Answer 18 multiplied by answer 19 Total of all channels: 4,735.39 W ERP (7,766.04 W EIRP). Part 22, Subpart H component alone (850 MHz): 1,288.25 W ERP (2,112.73 W EIRP). Part 27 component (700 MHz and 3840 MHz): 3,447.14 W ERP (5,653.31 W EIRP). 21.Is the answer to question 20 less than or equal to question 17? Part 22, Subpart H: not reached. Box 16 establishes categorical exclusion because the antenna is non-building-mounted and the lowest point is above 10 meters. The 850 MHz component is in any event 1,288.25 W ERP against a 1,000 W ERP threshold that applies only below 10 meters. Part 27: No. 5,653.31 W EIRP exceeds 1,640 W EIRP. Routine environmental evaluation is therefore indicated for the Part 27 component, and it has been performed. See below. SITE-SPECIFIC RF EXPOSURE EVALUATION Because question 21 is answered No for the Part 27 component, AT&T did not rely on categorical exclusion at this facility. A site-specific maximum permissible exposure evaluation was performed by MobileComm and is documented in the RF Site Safety and Regulatory Package for this site (MobileComm Professionals, Inc., FA No. 16969274, USID 507990), EME analysis dated July 31, 2026. The evaluation is a free-space calculation and does not credit any attenuation from trees, buildings or other obstructions. Compliance boundary General Public Occupational Horizontal from antenna face 18 feet 6 feet Item 2 Attachment F - Radio Frequency Emissions Reports for the Two Sites     Packet Pg. 78     Compliance boundary General Public Occupational Vertical below the bottom of the antenna 5 feet 3 feet Lowest elevation of the boundary at this site 45 -11″ above ground′— Predicted exposure at the nearest publicly accessible building is 0.00364 mW/cm² (3.64% of the General Public limit), at the top of an adjacent roof near 804 Boyce Avenue, about 24 feet from the nearest antenna. At ground level, anywhere at the site, predicted exposure is 0.00104 mW/cm² (1.04% of the applicable public limit). The General Public compliance boundary at this facility begins at 45 -11″ above ground level. There is no publicly ′ accessible surface at or above that elevation within 18 feet of the antenna. Radio frequency notice signage is installed at 45 -1″ above ground and states that a distance of 18 feet must be kept from the antenna.′ Item 2 Attachment F - Radio Frequency Emissions Reports for the Two Sites     Packet Pg. 79     CRAN_RSFR_PALO4_005 Public right-of-way near 670 Guinda Street, Palo Alto, California 94301 APPENDIX A — BACKGROUND INFORMATION Item Response 1.Facility Operator’s Legal Name New Cingular Wireless PCS, LLC, a Delaware limited liability company, d/b/a AT&T Mobility 2.Facility Operator’s Mailing Address New Cingular Wireless PCS, LLC, Attn: Network Real Estate Administration 12555 Cingular Way, Suite 1300, Alpharetta, Georgia 30004 RF engineering office: AT&T Mobility, Network Planning & Engineering, RAN Design & RF Engineering, 5005 Executive Parkway, San Ramon, California 94583 3.Facility Operator’s Contact Name/Title Jeric Lizardo, Radio Frequency Engineer, AT&T Mobility (technical/RF contact) Tasha Stack, Contractor, NextEdge Networks Holdings LLC (authorized agent and applicant contact) 4.Facility Operator’s Office Telephone AT&T Network Operations Center: (800) 638-2822 · Authorized agent: (925) 954-4885 5.Facility Operator’s Fax None. AT&T Mobility does not maintain a facsimile number for this program. 6.Facility Name CRAN_RSFR_PALO4_005 7.Facility Address Public right-of-way near 670 Guinda Street Host structure: City of Palo Alto Utilities wood distribution pole No. 6023 8.Facility City/Community Palo Alto, County of Santa Clara 9.Facility State and Zip Code California 94301 10.Latitude 37.450339 N (NAD83) 11.Longitude 122.153229 W (NAD83) OPTIONAL LOCAL GOVERNMENT CHECKLIST (PAGE 2) — EVALUATION OF CATEGORICAL EXCLUSION Item Response 12.Licensed Radio Service Cellular Radiotelephone Service, 47 C.F.R. Part 22, Subpart H (850 MHz, Band 5 / n5); and Wireless Communications Service, 47 C.F.R. Part 27 (700 MHz Band 12 LTE and 3.7–3.98 GHz C-Band, n77) 13.Structure Type Free-standing. Existing utility pole within the public right-of-way. Not building-mounted and not roof-mounted. 14.Antenna Type Omnidirectional. Gamma Nu DY12X360F8T0 pseudo-omni canister antenna, 360 degrees, single sector. 15.Height above ground of the lowest point of the antenna 51.75 feet (51 -9″) above ground level.′ Radiation center 52 -9″; top of canister 53 -9″.′ ′ Item 2 Attachment F - Radio Frequency Emissions Reports for the Two Sites     Packet Pg. 80     16.☒Checked. All three conditions are true. (a)True. The facility is operated in the Cellular Radiotelephone Service (47 C.F.R. Part 22, Subpart H). (b)True. The facility is not mounted on a building. It is carried on an existing wood distribution pole in the public right-of-way. (c)True. The lowest point of the antenna is 51.75 feet (51 -9″) above ground, which exceeds 32.8 feet (10 ′ meters). Box 16 is checked. Under the instruction on page 2 of the checklist, this facility is categorically excluded and the remainder of the checklist need not be completed. Questions 17 through 21 are answered below on a voluntary basis for the Part 27 component of the facility, for which Table 1 provides no height exemption. Item Response 17.Power threshold for categorical exclusion (Table 1) Part 22, Subpart H (Cellular Radiotelephone Service): 1,000 W ERP (1,640 W EIRP) total of all channels, and only where the lowest point of the antenna is below 10 meters. The height condition is not met here, so no evaluation is required. Part 27 (Wireless Communications Service): 1,640 W EIRP total of all channels. No height condition applies. 18.Total number of channels (omnidirectional antenna) Three, on a single omnidirectional sector: one 700 MHz (Band 12) LTE carrier, one 850 MHz 5G NR carrier, and one 3840 MHz C-Band 5G NR carrier. 19.ERP or EIRP per channel 700 MHz (B12) LTE: 912.01 W ERP (1,495.70 W EIRP) 850 MHz 5G NR: 1,288.25 W ERP (2,112.73 W EIRP) 3840 MHz C-Band 5G NR: 2,535.13 W ERP (4,157.61 W EIRP) Source: RF Site Safety and Regulatory Package, Item 6, effective radiated power per frequency band and per sector. 20.Answer 18 multiplied by answer 19 Total of all channels: 4,735.39 W ERP (7,766.04 W EIRP). Part 22, Subpart H component alone (850 MHz): 1,288.25 W ERP (2,112.73 W EIRP). Part 27 component (700 MHz and 3840 MHz): 3,447.14 W ERP (5,653.31 W EIRP). 21.Is the answer to question 20 less than or equal to question 17? Part 22, Subpart H: not reached. Box 16 establishes categorical exclusion because the antenna is non-building-mounted and the lowest point is above 10 meters. The 850 MHz component is in any event 1,288.25 W ERP against a 1,000 W ERP threshold that applies only below 10 meters. Part 27: No. 5,653.31 W EIRP exceeds 1,640 W EIRP. Routine environmental evaluation is therefore indicated for the Part 27 component, and it has been performed. See below. SITE-SPECIFIC RF EXPOSURE EVALUATION Because question 21 is answered No for the Part 27 component, AT&T did not rely on categorical exclusion at this facility. A site-specific maximum permissible exposure evaluation was performed by MobileComm and is documented in the RF Site Safety and Regulatory Package for this site (MobileComm Professionals, Inc., FA No. 16969276, USID 507989), EME analysis dated July 31, 2026. The evaluation is a free-space calculation and does not credit any attenuation from trees, buildings or other obstructions. Compliance boundary General Public Occupational Horizontal from antenna face 18 feet 6 feet Item 2 Attachment F - Radio Frequency Emissions Reports for the Two Sites     Packet Pg. 81     Compliance boundary General Public Occupational Vertical below the bottom of the antenna 5 feet 3 feet Lowest elevation of the boundary at this site 46 -9″ above ground′— Predicted exposure at the nearest publicly accessible building is 0.00183 mW/cm² (1.83% of the General Public limit), at the top of an adjacent roof near 670 Guinda Street, about 32 feet from the nearest antenna. At ground level, anywhere at the site, predicted exposure is 0.00100 mW/cm² (1.00% of the applicable public limit). The General Public compliance boundary at this facility begins at 46 -9″ above ground level. There is no publicly ′ accessible surface at or above that elevation within 18 feet of the antenna. Radio frequency notice signage is installed at 46 -2″ above ground and states that a distance of 18 feet must be kept from the antenna.′ Item 2 Attachment F - Radio Frequency Emissions Reports for the Two Sites     Packet Pg. 82     CRAN_RSFR_PALO4_006 Public right-of-way near 754 Homer Avenue, Palo Alto, California 94301 APPENDIX A — BACKGROUND INFORMATION Item Response 1.Facility Operator’s Legal Name New Cingular Wireless PCS, LLC, a Delaware limited liability company, d/b/a AT&T Mobility 2.Facility Operator’s Mailing Address New Cingular Wireless PCS, LLC, Attn: Network Real Estate Administration 12555 Cingular Way, Suite 1300, Alpharetta, Georgia 30004 RF engineering office: AT&T Mobility, Network Planning & Engineering, RAN Design & RF Engineering, 5005 Executive Parkway, San Ramon, California 94583 3.Facility Operator’s Contact Name/Title Jeric Lizardo, Radio Frequency Engineer, AT&T Mobility (technical/RF contact) Tasha Stack, Contractor, NextEdge Networks Holdings LLC (authorized agent and applicant contact) 4.Facility Operator’s Office Telephone AT&T Network Operations Center: (800) 638-2822 · Authorized agent: (925) 954-4885 5.Facility Operator’s Fax None. AT&T Mobility does not maintain a facsimile number for this program. 6.Facility Name CRAN_RSFR_PALO4_006 7.Facility Address Public right-of-way near 754 Homer Avenue Host structure: City of Palo Alto Utilities wood distribution pole (number pending City assignment) 8.Facility City/Community Palo Alto, County of Santa Clara 9.Facility State and Zip Code California 94301 10.Latitude 37.449048 N (NAD83) 11.Longitude 122.152316 W (NAD83) OPTIONAL LOCAL GOVERNMENT CHECKLIST (PAGE 2) — EVALUATION OF CATEGORICAL EXCLUSION Item Response 12.Licensed Radio Service Cellular Radiotelephone Service, 47 C.F.R. Part 22, Subpart H (850 MHz, Band 5 / n5); and Wireless Communications Service, 47 C.F.R. Part 27 (700 MHz Band 12 LTE and 3.7–3.98 GHz C-Band, n77) 13.Structure Type Free-standing. Existing utility pole within the public right-of-way. Not building-mounted and not roof-mounted. 14.Antenna Type Omnidirectional. Gamma Nu DY12X360F8T0 pseudo-omni canister antenna, 360 degrees, single sector. 15.Height above ground of the lowest point of the antenna 51.42 feet (51 -5″) above ground level.′ Radiation center 52 -5″; top of canister 53 -5″.′ ′ Item 2 Attachment F - Radio Frequency Emissions Reports for the Two Sites     Packet Pg. 83     16.☒Checked. All three conditions are true. (a)True. The facility is operated in the Cellular Radiotelephone Service (47 C.F.R. Part 22, Subpart H). (b)True. The facility is not mounted on a building. It is carried on an existing wood distribution pole in the public right-of-way. (c)True. The lowest point of the antenna is 51.42 feet (51 -5″) above ground, which exceeds 32.8 feet (10 ′ meters). Box 16 is checked. Under the instruction on page 2 of the checklist, this facility is categorically excluded and the remainder of the checklist need not be completed. Questions 17 through 21 are answered below on a voluntary basis for the Part 27 component of the facility, for which Table 1 provides no height exemption. Item Response 17.Power threshold for categorical exclusion (Table 1) Part 22, Subpart H (Cellular Radiotelephone Service): 1,000 W ERP (1,640 W EIRP) total of all channels, and only where the lowest point of the antenna is below 10 meters. The height condition is not met here, so no evaluation is required. Part 27 (Wireless Communications Service): 1,640 W EIRP total of all channels. No height condition applies. 18.Total number of channels (omnidirectional antenna) Three, on a single omnidirectional sector: one 700 MHz (Band 12) LTE carrier, one 850 MHz 5G NR carrier, and one 3840 MHz C-Band 5G NR carrier. 19.ERP or EIRP per channel 700 MHz (B12) LTE: 912.01 W ERP (1,495.70 W EIRP) 850 MHz 5G NR: 1,288.25 W ERP (2,112.73 W EIRP) 3840 MHz C-Band 5G NR: 2,535.13 W ERP (4,157.61 W EIRP) Source: RF Site Safety and Regulatory Package, Item 6, effective radiated power per frequency band and per sector. 20.Answer 18 multiplied by answer 19 Total of all channels: 4,735.39 W ERP (7,766.04 W EIRP). Part 22, Subpart H component alone (850 MHz): 1,288.25 W ERP (2,112.73 W EIRP). Part 27 component (700 MHz and 3840 MHz): 3,447.14 W ERP (5,653.31 W EIRP). 21.Is the answer to question 20 less than or equal to question 17? Part 22, Subpart H: not reached. Box 16 establishes categorical exclusion because the antenna is non-building-mounted and the lowest point is above 10 meters. The 850 MHz component is in any event 1,288.25 W ERP against a 1,000 W ERP threshold that applies only below 10 meters. Part 27: No. 5,653.31 W EIRP exceeds 1,640 W EIRP. Routine environmental evaluation is therefore indicated for the Part 27 component, and it has been performed. See below. SITE-SPECIFIC RF EXPOSURE EVALUATION Because question 21 is answered No for the Part 27 component, AT&T did not rely on categorical exclusion at this facility. A site-specific maximum permissible exposure evaluation was performed by MobileComm and is documented in the RF Site Safety and Regulatory Package for this site (MobileComm Professionals, Inc., FA No. 16969268, USID 508055), EME analysis dated July 31, 2026. The evaluation is a free-space calculation and does not credit any attenuation from trees, buildings or other obstructions. Compliance boundary General Public Occupational Horizontal from antenna face 18 feet 6 feet Item 2 Attachment F - Radio Frequency Emissions Reports for the Two Sites     Packet Pg. 84     Compliance boundary General Public Occupational Vertical below the bottom of the antenna 5 feet 3 feet Lowest elevation of the boundary at this site 46 -5″ above ground′— Predicted exposure at the nearest publicly accessible building is 0.00175 mW/cm² (1.75% of the General Public limit), at the top of an adjacent roof near 754 Homer Avenue, about 27 feet from the nearest antenna. At ground level, anywhere at the site, predicted exposure is 0.00101 mW/cm² (1.01% of the applicable public limit). The General Public compliance boundary at this facility begins at 46 -5″ above ground level. There is no publicly ′ accessible surface at or above that elevation within 18 feet of the antenna. Radio frequency notice signage is installed at 45 -7″ above ground and states that a distance of 18 feet must be kept from the antenna.′ Item 2 Attachment F - Radio Frequency Emissions Reports for the Two Sites     Packet Pg. 85     Technical Annex: Source of Each Value Every entry above is traceable to a document in the application record. No value is estimated or derived. Value Source Operator legal name, mailing address Master License Agreement for Use of City-Controlled Space on Utility Poles and Streetlight Poles and in Conduits between the City of Palo Alto and New Cingular Wireless PCS, LLC dba AT&T Mobility, preamble and Section 18 (Notices). Contacts and telephone NextEdge Advanced Engineering Request letter to the City of Palo Alto dated May 13, 2026; AT&T Mobility Radio Frequency Statement signature block; AT&T Network Operations Center number of record for this program. Facility name, address, host pole NextEdge Advanced Engineering Request letter dated May 13, 2026 (site designations and pole numbers); NextEdge 90% construction drawing set, Rev. 06/16/26, sheet T-1. Latitude and longitude Trimble survey coordinates carried on the NextEdge 90% construction drawing set, Rev. 06/16/26, and corroborated by the AT&T Radio Frequency Data Sheet for each node. Licensed radio service AT&T Mobility Radio Frequency Statement, as revised August 14, 2026, and the Radio Frequency Data Sheet for each node: Ericsson Radio 4490 B5/B12A and Ericsson Radio 4461 B77D. Structure type NextEdge 90% construction drawing set, Rev. 06/16/26, sheets A-3 and A-4 (elevations). Antenna type Gamma Nu DY12X360F8T0 datasheet, GNT 031326 Rev. 1.1: pseudo-omni 8-port canister, 698–894 MHz on ports 1–4 and 3300–4200 MHz on ports 5–8. Height of the lowest point of the antenna NextEdge 90% construction drawing set, Rev. 06/16/26, sheets A-3 and A-4, dimension “B.O. (N) antenna canister.” Independently corroborated by the RF Site Safety and Regulatory Package equipment table. Total and per-band effective radiated power RF Site Safety and Regulatory Package (MobileComm), EME analysis dated July 31, 2026, Item 6: 912.01 W (700 MHz B12 LTE), 1,288.25 W (850 MHz 5G), 2,535.13 W (3840 MHz 5G), total 4,735.39 W ERP per sector. EIRP computed as 1.64 × ERP per the checklist. Predicted exposure levels RF Site Safety and Regulatory Package, Items 7 and 8, nearest publicly accessible building and ground level. Compliance boundaries and signage RF Site Safety and Regulatory Package, Section 9, Items 9 and 10; signage elevation from the 90% construction drawing set, dimension “T.O. (N) RF signage.” NOTE ON TWO ENTRIES Question 19. The per-carrier effective radiated power is taken directly from Item 6 of the RF Site Safety and Regulatory Package for each site, which reports power both as a total and broken down by frequency band. No value is derived or averaged. EIRP is computed from ERP using the conversion stated on the checklist, EIRP = 1.64 × ERP. Question 12. The checklist and Table 1 date from June 2000 and predate the Part 27 spectrum on which two of the three carriers at this facility operate. The service is therefore identified by both rule parts, and the evaluation is completed against each. This is disclosed rather than resolved by selecting the more favorable part. Item 2 Attachment F - Radio Frequency Emissions Reports for the Two Sites     Packet Pg. 86     CRAN_RSFR_PALO4_004 · _005 · _006 | Application Cover Letter Page 1 NextEdge Networks Holdings LLC 1355 Windward Concourse, Suite 410, Alpharetta, GA 30005 On behalf of New Cingular Wireless PCS, LLC dba AT&T Mobility August 14, 2026 City of Palo Alto Planning and Development Services 250 Hamilton Avenue Palo Alto, California 94301 Attention: Ms. Nishita Kandikuppa, Planning and Development Services Re: Application Cover Letter and Project Description Tier 2 Wireless Communication Facility Permit Applications, Public Right-of-Way, PAMC Section 18.42.110 CRAN_RSFR_PALO4_004, 804 Boyce Avenue [No longer in the scope of work. Please disregard all references to 804 Boyce Avenue in the project letter.] CRAN_RSFR_PALO4_005, 670 Guinda Street CRAN_RSFR_PALO4_006, 754 Homer Avenue Dear Ms. Kandikuppa: On behalf of New Cingular Wireless PCS, LLC (dba AT&T Mobility), NextEdge Networks Holdings LLC respectfully submits these three batched Tier 2 Wireless Communication Facility Permit applications pursuant to PAMC Section 18.42.110. In modern Palo Alto, reliable wireless service is critical municipal infrastructure: it is how residents contact healthcare providers, connect with local schools, stay close with family, and reach 911 during emergencies. Today, however, AT&T customers in these neighborhoods experience severe in-building coverage deficits: dropped calls, stalled data, and degraded network performance right where they live and rely on it most. As documented in the accompanying Radio Frequency Statements, closing these specific coverage gaps is the core objective of this proposal. AT&T measures success by real-world customer experience, not simply by hardware deployed. That standard requires an equal commitment to public aesthetics and historic neighborhood character. A facility that solves a technical gap while diminishing the visual quality of the streetscape fails both the customer and the community. Palo Alto’s Zoning Code reflects this exact philosophy. Its residential design findings emphasize harmony with nature, privacy, pedestrian safety, and high-quality materials that respect the immediate environment. Rather than treating these standards as a checklist to clear at the end of the process, AT&T adopted them as our primary design brief from day one. To achieve this balance, AT&T rigorously evaluated 15 alternative locations and four distinct concealment configurations. The resulting proposal: •Requires zero new or replacement poles, remaining on existing City of Palo Alto Utilities wood distribution poles within the public right-of-way; •Places no cabinets, vaults, or ground-mounted equipment on the street; •Protects the canopy by requiring no tree removal; and •Consolidates all visible hardware into a single, compact enclosure finished to match the existing utility pole. This letter serves as the formal Project Description required by the Tier 2 checklist, detailing project scope, noise analysis, FCC classification, and applicable review timelines. Enclosed materials are cataloged in Section XI. AT&T respectfully requests a prompt review and looks forward to working collaboratively with City staff throughout the process. Item 2 Attachment G - Applicant's Project Description Letter & Photo Simulations     Packet Pg. 87     CRAN_RSFR_PALO4_004 · _005 · _006 | Application Cover Letter Page 2 I. PROJECT SUMMARY PALO4_004 PALO4_005 PALO4_006 Nearest address 804 Boyce Avenue 670 Guinda Street at Forest Avenue 754 Homer Avenue Host structure Existing CPAU wood distribution pole Existing CPAU wood distribution pole Existing CPAU wood distribution pole Existing pole height 43′-0″ 43′-10″ 43′-6″ Top of pole top extension 50′-0″ 50′-10″ 50′-6″ Antenna RAD center 51′-11″ 52′-9″ 52′-5″ Top of antenna 52′-11″ 53′-9″ 53′-5″ Equipment enclosure, T.O. / B.O. 15′-0″ / 10′-11″ 18′-0″ / 14′-0″ 15′-0″ / 10′-11″ Service disconnect approx. 7′-0″ AGL approx. 7′-0″ AGL approx. 7′-0″ AGL MPE at nearest building 3.64% of GP limit 1.83% of GP limit 1.75% of GP limit MPE at ground level 1.04% of GP limit 1.00% of GP limit 1.01% of GP limit The following equipment is common to all three facilities. Antenna One Gamma Nu DY12X360F8T0 omnidirectional canister, 24″ high by 16″ diameter, pole - top mounted on a 7′-0″ Shakespeare fiberglass pole top extension Radios One Ericsson 4490 (B5 / B12A) and one Ericsson 4461 (B77D) Power supply One Ericsson 6308 rectifier, convection cooled Enclosure One Ericsson BFL 901 770 multi-radio shroud, 48″ × 24″ × 20″, finished to match the existing pole Service Overhead power from the existing distribution facilities on the host pole; single metered service with pole-mounted disconnect. No battery, energy storage system, UPS, generator, transfer switch or fuel storage. Frequencies 4G LTE at 700 MHz (B12); 5G at 850 MHz (B5); 5G in C-Band (3840 MHz) Radiated power 4,735.39 W ERP total per site (7,766.04 W EIRP), comprising 912.01 W ERP at 700 MHz, 1,288.25 W ERP at 850 MHz and 2,535.13 W ERP in C-Band II. SCOPE OF WORK • Install a 7′-0″ fiberglass pole top extension on the existing wood distribution pole. •Install one omnidirectional canister antenna at the top of the extension. •Install one equipment enclosure on the pole face containing two radios and the power supply unit. • Install one service disconnect at approximately 7′-0″ above grade. •Install conduit and cabling on the pole face between the service point, the enclosure and the antenna, routed within a single climbing quadrant. •Connect to overhead power from the existing distribution facilities on the host pole. No trenching, directional boring, vault or sub box is proposed at any of the three locations. •Drive one grounding rod and set one ground test well at each pole, the only below-grade element of the work. •Finish all new appurtenances to match the existing pole. Item 2 Attachment G - Applicant's Project Description Letter & Photo Simulations     Packet Pg. 88     CRAN_RSFR_PALO4_004 · _005 · _006 | Application Cover Letter Page 3 III. PROJECT DESCRIPTION This section responds to each element the Tier 2 checklist requires of a project description, in the order the checklist states them. Existing and proposed use at the proposed location Each location is an existing City of Palo Alto Utilities wood distribution pole in the public right-of-way, carrying overhead electric distribution and, at PALO4_004, a streetlight on a 12-foot arm. The proposed use adds an unmanned wireless communication facility to the same pole. The facility is unmanned and is not for human habitation. The poles remain in service in their existing utility function and remain the property of the City. Proposed wireless carrier New Cingular Wireless PCS, LLC dba AT&T Mobility, 5005 Executive Parkway, San Ramon, California 94583. The applicant of record is NextEdge Networks Holdings LLC, as AT&T’s authorized agent. The pole owner is City of Palo Alto Utilities. Purpose and goals: network design, frequency bands, technology Each facility closes a significant gap in AT&T’s 4G LTE service coverage in a predominantly residential area of Palo Alto and delivers 5G service in the same installation. The gap for each site, its boundaries and the design principles that govern where a node closing it can be placed are set out in the AT&T Mobility Radio Frequency Statement prepared for each site and depicted on the existing and proposed coverage maps enclosed with each statement. Network design requires the facility to sit near the geometric center of the target gap so that line of sight propagation and uniform power distribution are maintained across the gap, and far enough from adjacent nodes to avoid inter-cell overlap and co-channel interference. Frequency bands and technology: 4G LTE at 700 MHz (Band 12), 5G at 850 MHz (Band 5) and 5G in C-Band at 3840 MHz. 5G is proposed now and is not a future addition. Proposed scope of work, above and below ground Work above ground is set out in Section II. Below ground, the scope at each pole is limited to one driven grounding rod, 5/8 inch diameter by 10 feet, and one ground test well, as shown on sheets E-1 through E-3. Nothing else is placed below grade. No trenching, no directional boring, no bore or receiving pits, no potholing, no vault and no sub box is proposed, because power and communications are served overhead from the existing facilities on each host pole. The project arborist has addressed the grounding work directly. Each tree protection report requires the ground rod and test well location to be confirmed on site relative to trees within ten feet, requires the rod and wells to be set so as to avoid roots one inch and larger, and requires airspade, hand or hydro excavation to assess root locations before the final rod location is fixed. AT&T will perform the grounding work on that basis. Dimensions The antenna is a 2-foot canister, 24 inches high by 16 inches in diameter. The equipment enclosure is 48 by 24 by 20 inches and houses both radios and the power supply unit within a single concealed enclosure. In addition, the facility includes a 7-foot pole top extension continuing the line of the existing pole, an equipment mounting bracket, a service disconnect enclosure 21.25 inches high at approximately 7 feet above grade, and coaxial and power cabling on the pole face. No ground-mounted cabinet, pedestal, vault or enclosure is proposed. Dimensioned front and side elevations are provided with the plans at sheets A-2 through A-4. Antenna diameter and why it serves the least intrusive design The 16-inch diameter of the proposed antenna enclosure is dictated entirely by physical engineering requirements, not aesthetic preference. Two technical realities determine this size: • Four-stream signal paths (4x4 MIMO). To prevent data stalling, these radios operate on four parallel paths rather than two. Just as a four-lane road requires more physical width than a two-lane road, four signal paths require additional radiating elements inside the housing. Item 2 Attachment G - Applicant's Project Description Letter & Photo Simulations     Packet Pg. 89     CRAN_RSFR_PALO4_004 · _005 · _006 | Application Cover Letter Page 4 • Low-band reach. Closing the local in-building coverage gap requires low-band frequencies (700 MHz and 850 MHz). Because lower frequencies demand physically larger elements, much like a bass speaker must be larger than a tweeter, these components cannot be shrunk without weakening the signal. Combining the low-band and C-Band components into a single, unified 16-inch cylinder allows all necessary elements to fit within one clean enclosure on one existing pole. Why this is the least intrusive option for the neighborhood A narrower canister does not make the underlying technology smaller; it simply breaks it apart. Reducing the antenna diameter would create two unacceptable outcomes for Palo Alto: 1. Equipment clutter. It would force the same components out of a single enclosure and into multiple, stacked antennas on the same pole. 2. Infrastructure proliferation. If the antenna array is scaled down below what is needed to bridge the coverage gap, the gap remains. To make up for that lost coverage, AT&T would be forced to deploy additional Tier 2 wireless facilities on additional utility poles throughout the neighborhood. Ultimately, approving one slightly wider, consolidated enclosure on an existing pole prevents the need for a network of new wireless facilities on multiple poles across these residential streets. Efforts taken to minimize visual impact The checklist lists examples of minimization measures. Those that apply to a pole-mounted facility in a residential right-of-way are addressed as follows. Underground vaulting, monopole slimming and setback from major roads are not available measures at these locations and are addressed at the end of this subsection. • No new structure. Each facility collocates on a pole already present in the streetscape. No new pole and no pole replacement is proposed, so no vertical element is added to the streetscape that is not already there. • Reduced number of facilities. Three facilities close three separate coverage gaps. Each was sited to serve the largest practicable area so that no additional node is required within the same gap. • Stealth and concealment. The pole top extension continues the existing pole line and the antenna is contained within a canister of the same diameter family, so the facility reads as a continuation of the pole rather than as an attachment. The radios and power supply are enclosed in a single formed enclosure with a radiused upper profile rather than mounted individually. • Consolidation of otherwise visible apparatus. The alternative configurations place the power supply and AC load center on separate mounted apparatus carried on a sled approximately eleven feet long. The selected enclosure occupies four feet of pole face and conceals those functions. • Single pole penetration. One conduit penetration of the host pole rather than multiple penetrations at multiple elevations, which also preserves the service life of the City’s pole. • Color matching. All AT&T appurtenances are painted non-glossy to match the pole color. • Distance from windows and openings. All equipment other than the service disconnect is mounted at or above approximately 11 feet above grade, and the antenna at approximately 52 feet, well above the openings of adjacent residences. • Avoidance of scenic corridors, gateways and historic resources. None of the three host poles is located on an identified scenic route or gateway, and none is a designated historic structure or site or immediately adjacent to one under PAMC Chapter 16.49. • Trees and landscaping. No tree removal is proposed and no required landscaping is removed or reduced. The tree protection plans and arborist assessment are enclosed. A slim line monopole and a substantial setback from a major road are measures directed at new stand-alone structures on larger sites. Neither applies to a collocation on an existing distribution pole in a residential right-of- way. Underground vaulting of the radio equipment is addressed separately below. Underground vaults for radio equipment As a general design principle, radio units are engineered to sit within a few feet of the antennas they serve, and any wireless architecture a carrier may deploy over the life of a right-of-way will share that constraint. Separating radios into a below-grade vault forces extended feeder runs whose insertion loss degrades both uplink and downlink Item 2 Attachment G - Applicant's Project Description Letter & Photo Simulations     Packet Pg. 90     CRAN_RSFR_PALO4_004 · _005 · _006 | Application Cover Letter Page 5 performance and shrinks the coverage the facility is meant to deliver, an effect that grows worse as carriers add spectrum and higher frequencies where feeder loss is more severe. Ventilation is the governing engineering constraint. Modern radios are convection-cooled units that reject heat passively through open-air heat sinks and depend on continuous, unobstructed ambient airflow across those surfaces to hold junction temperatures within their rated operating envelope. A below-grade vault eliminates that airflow, trapping radiated heat in a confined space so that intake and exhaust air recirculate at rising temperature until the equipment thermally derates, throttles output, or shuts down to protect itself. Restoring adequate airflow means converting the vault to an actively ventilated, forced-air enclosure with powered fans, filtration, and monitored intake and exhaust paths, which introduces mechanical components that fail, draws additional power, generates the very noise a pole-mounted convection unit avoids, and triggers CPUC and confined-space enclosure standards far more intrusive to the right-of-way than a compact pole-mounted radio. Below-grade placement also exposes active electronics to the one environment they are least suited for. Vaults are prone to water intrusion, flooding, and standing moisture from groundwater, storm flows, and the region’s seasonal rains, and pole-mounted radios are rated for open-air weather exposure but not for submersion or sustained saturation, so vault placement raises the risk of moisture ingress, corrosion, and premature failure while complicating the routine access needed to service or swap a failed unit. On a CPUC-governed wood distribution pole the subsurface is typically congested with existing utilities and offers no room for a compliant vault. Undergrounding of active radio equipment is therefore infeasible at these three locations. The facilities are served overhead from the existing distribution facilities on each host pole, and City of Palo Alto Utilities requires a pole- mounted, above-grade disconnect for operational access and safety on distribution assets. No trenching, boring or vault is proposed, and no fiber or power conduit is placed below grade at any of the three sites. The only below- grade element of the work is the grounding rod and test well described in Section III. Alternative project locations considered Fifteen alternative locations were evaluated across the three sites: six for PALO4_004, five for PALO4_005 and four for PALO4_006. The Alternative Site Analysis maps the alternatives against the coverage objective for each site and identifies each alternative by designation, nearest address and coordinates, states its distance and direction from the proposed location, documents it with a photograph, and gives the reason it was not selected. The site selection criteria applied are the criteria the Radio Frequency Statements identify: proximity to the center of the defined coverage gap; sufficient supporting structure height to place the antenna above surrounding obstructions; line of sight across the gap area; separation from adjacent planned or existing nodes sufficient to avoid inter-cell overlap and co-channel interference; and physical feasibility on the host pole, including CPUC General Order 95 climbing space and clearance from existing attachments, vegetation and City equipment. Alternatives that cannot achieve the coverage objective are identified as not technically feasible. Alternatives that could achieve it only through a new or taller structure are identified as more intrusive. The analysis is enclosed with its own cover letter. Graphic portrayal and description of the proposed and alternative designs Four concealment configurations were considered as alternative designs, which were also referenced at the Architectural Review Board on July 16, 2026 during Public Comment. The proposed design and the alternative designs considered are depicted in the enclosed materials, and the photographic simulations show the proposed design in place at each site. Efforts to locate at existing wireless facilities No existing wireless communication facility sits within the coverage objective of any of the three sites at a position that would close the identified gap, so collocation on an existing wireless facility was not available. The proposed facilities are themselves collocations on existing City-owned poles, which is the outcome the collocation preference at PAMC Section 18.42.110(a) is directed at. Item 2 Attachment G - Applicant's Project Description Letter & Photo Simulations     Packet Pg. 91     CRAN_RSFR_PALO4_004 · _005 · _006 | Application Cover Letter Page 6 Basis for Tier 2 qualification under PAMC Section 18.42.110 Each application proposes a collocation on an existing support structure. It is not an eligible facilities request under 47 C.F.R. Section 1.6100 and therefore does not qualify for a Tier 1 WCF Permit, and it is not a new WCF siting and therefore is not a Tier 3 WCF Permit. It is a collocation falling within the Tier 2 category at PAMC Section 18.42.110(c). Under Section 18.42.110(g)(1) as amended by Ordinance 5655, the Director shall refer these applications to the Architectural Review Board because they are installations in the public right-of-way. Underlying Master License Agreement These facilities are subject to the Master License Agreement between the City of Palo Alto and New Cingular Wireless PCS, LLC dba AT&T Mobility. The Master License Agreement contemplates that planning review and encroachment permitting precede execution of the site license for each location. More than one facility in these materials These application materials contain three wireless communication facilities. The applications are batched. Each facility has its own site identification number, its own Radio Frequency Statement, its own coverage maps, its own structural analysis and its own drawing set, and each is subject to its own review period. Objective Standards and exceptions No exception under PAMC Section 18.42.110(k) is requested. The Objective Standards adopted by Resolution 9873 on December 16, 2019 were repealed by Ordinance 5655, Section 2. Section 18.42.110(g)(2) as amended provides that where those objective standards are repealed, a Tier 2 permit shall not be granted unless, in addition to the other requirements of the section, all of the architectural review findings at PAMC Section 18.76.020(d) can be made. The applications are prepared on that basis, and the generally applicable development standards at Section 18.42.110(i), which were not repealed, are addressed in Section IV below. Every checklist item that calls for a response measured against the repealed standards is addressed in the enclosed Statement Regarding Checklist Items Measured Against the Repealed Objective Standards. Materials, colors and construction methods The pole top extension is fiberglass. The antenna canister, equipment enclosure, mounting bracket, conduit and cabling are the manufacturers’ standard materials, and all AT&T-added appurtenances are painted non-glossy to match the pole color. The construction drawings specify non-glossy Sable by Sherwin-Williams or equivalent, and carry a note requiring the final paint color and finish to be confirmed with the City of Palo Alto before installation. A color and materials board will be provided as the checklist requires. Construction method is pole-mounted attachment to the existing wood distribution pole using through-bolted and lag-fastened brackets, with a single conduit penetration for cable pass-through. All equipment is placed within a single climbing quadrant to preserve General Order 95 climbing space, and cabling is installed in a tight, neat manner without excess cable loops. Work is performed from a bucket truck within the right-of-way under an approved traffic control plan. No foundation work is proposed and the existing pole is not replaced. Ground disturbance is limited to driving the grounding rod and setting the ground test well, performed under the arborist’s root protection measures where a tree stands within ten feet. Noise The facilities will generate noise only from the two integral radio cooling fans supplied with the radio units. The full acoustic analysis, including the manufacturer data and the compliance margins against PAMC Sections 9.10.050 and 9.10.030, is set out in Section V. Future expansion, including 5G 5G is proposed now, not as a future addition. Each facility will operate 4G LTE at 700 MHz and 5G at 850 MHz and in C-Band when placed in service, using the equipment shown on the project plans. No additional equipment is proposed at these three poles and no capacity for future equipment is reserved. These three facilities are part of a thirteen-node AT&T program in Palo Alto; the remaining ten are proposed on City streetlight poles and will be submitted under separate Tier 2 applications, each with its own design and supporting record. Any modification to an approved facility would be reviewed under PAMC Section 18.42.110 and the standards in effect at the time it is proposed. Item 2 Attachment G - Applicant's Project Description Letter & Photo Simulations     Packet Pg. 92     CRAN_RSFR_PALO4_004 · _005 · _006 | Application Cover Letter Page 7 List of wireless communication facilities proposed in this application PALO4_004 PALO4_005 PALO4_006 Applicant site ID CRAN_RSFR_PALO4_004 CRAN_RSFR_PALO4_005- D CRAN_RSFR_PALO4_006- G Site address (near) 804 Boyce Avenue (near) 670 Guinda Street (near) 754 Homer Avenue Closest adjacent APN 003-25-024 003-32-006 003-32-080 Address of closest adjacent APN 804 Boyce Avenue 670 Guinda Street 754 Homer Avenue Latitude / longitude (NAD83) 37.449006° N -122.150669° W 37.450339° N -122.153229° W 37.449048° N -122.152316° W Ground elevation 26.00' AMSL 42.15' AMSL 39.32' AMSL Zoning district Public right-of-way; adjacent zoning R-1 (10000) Public right-of-way; adjacent zoning R-1 Public right-of-way; adjacent zoning R-1 Underground utility district None identified None identified None identified Existing pole number 5919 6023 6010 Existing pole height 43′-0″ AGL 43′-10″ AGL 43′-6″ AGL Proposed height with facility 52′-11″ AGL to top of antenna 53′-9″ AGL to top of antenna 53′-5″ AGL to top of antenna Proposed color Non-glossy to match pole; Sable by Sherwin-Williams or equivalent, final color and finish to be confirmed with the City Same Same Distances to nearby structures The location map enclosed for each site tabulates the distance from the proposed facility to the residential structures nearest to it, together with parcel lines, scale and north arrow. Read with the radiofrequency exposure figures in Section VI, those distances establish that no habitable structure lies within the general public exposure boundary in any direction. The inventory of AT&T’s existing and entitled antenna locations within the City limits is enclosed separately. IV. COMPLIANCE WITH THE ACTIVE DEVELOPMENT STANDAR DS The generally applicable development standards at PAMC Section 18.42.110(i) were not repealed and govern these applications. Standards (7), (8) and (9) address building-mounted facilities and stand-alone Tier 3 facilities and do not apply. The remaining standards are addressed as follows. • (1) Smallest equipment technically feasible. The equipment complement is the minimum required to deliver the three frequency bands the coverage objective requires. The enclosure consolidates the radios and the power supply in one enclosure; the alternatives require separate mounted apparatus and an eleven-foot support sled. • (2) Screened from public view. All radios and the power supply are enclosed. The antenna is contained within a canister shroud. • (3) Shrouded or screened using materials or colors found on the existing structure. All new appurtenances are finished to match the existing wood pole. • (4) No removal or reduction of required landscaping. None is proposed. The tree protection inventory, plans and arborist report are enclosed. • (5) Camouflaged or stealth design. The pole top extension and canister continue the line of the existing pole; the enclosure is a single formed enclosure with a radiused upper profile rather than a cabinet with hard terminations. • (6) Not attached to a historic structure or site. None of the three host poles is a designated historic structure or site under PAMC Chapter 16.49. Item 2 Attachment G - Applicant's Project Description Letter & Photo Simulations     Packet Pg. 93     CRAN_RSFR_PALO4_004 · _005 · _006 | Application Cover Letter Page 8 AT&T accepts the conditions of approval at PAMC Section 18.42.110(j). V. NOISE AND ACOUSTIC IMPACT Noise impact and municipal code compliance The proposed facility is essentially silent and will have no noticeable sound impact on the surrounding neighborhood: • Minimal moving parts. The system uses passive natural cooling rather than heavy mechanical equipment. It includes no air conditioners, generators, compressors, or cabinet exhaust fans. The only moving parts are tiny, internal manufacturer cooling fans built directly into the radio units. The antenna itself is completely silent. • Smart and low-volume operation. The radio fans automatically adjust based on outdoor temperature. During cool nighttime hours when the neighborhood is quietest, the equipment operates at near-zero sound levels, adding just 0.11 decibels, an amount completely imperceptible to human ears and unmeasurable by standard equipment. • Peak output aligns with peak ambient noise. The fans only run at higher speeds during the hottest afternoon hours, precisely when local background noise (traffic, wind, neighborhood activity) is already at its daily highest. • Full compliance with Palo Alto code. Even under extreme heat conditions far exceeding historical local weather records, conservative acoustic modeling shows the facility operates comfortably below Palo Alto’s noise limits (PAMC Chapter 9.10). At standard peak summer temperatures, the site operates with a 14-decibel margin under Section 9.10.050 and satisfies the stricter standards of Section 9.10.030. Because the facility meets all city noise thresholds without requiring sound baffles or physical shielding, no acoustical mitigation is necessary. AT&T fully accepts a standard condition of approval requiring ongoing compliance with Chapter 9.10. Technical basis Manufacturer data establishes a sound pressure level of 38.6 dBA at one meter for the Ericsson Radio 4461 and 20 to 29 dBA at one meter for the Ericsson Radio 4490 at temperatures at and below 30 degrees Celsius, rising to 48.7 dBA and 60 dBA respectively at the upper limit of the published range. The applicant analyzed facility emission across that full operating range using spherical spreading with a conservative three-decibel hard-ground correction and taking no credit for enclosure insertion loss. Measured against the forty dBA exterior ambient floor in PAMC Section 9.10.050, the facility raises the sound level by 0.11 dB during night-time hours, by 0.97 dB at the ASHRAE 0.4 percent design ambient of 33 degrees Celsius, by 1.70 dB at 40 degrees Celsius, and by 6.7 dB at the extreme upper bound of the published data, a condition corresponding to a site ambient temperature substantially above any value on record for this location. The facility therefore complies with Section 9.10.050 by no less than 8.3 decibels under every condition within the published operating range and by 14.0 decibels at the site design condition, and satisfies the stricter six-decibel standard of Section 9.10.030 with a margin of 5.0 decibels at the design condition and 4.3 decibels at 40 degrees Celsius. The emission is broadband, steady, and free of tonal, impulsive or cyclic character. VI. RADIOFREQUENCY EXPOSURE Each facility was analyzed for maximum permissible exposure by MobileComm and is documented in the Radio Frequency Safety Survey Report Prediction enclosed for each site. Maximum predicted exposure at the nearest building is 3.64 percent of the FCC general population limit at PALO4_004, 1.83 percent at PALO4_005 and 1.75 percent at PALO4_006. At ground level the figures are 1.04, 1.00 and 1.01 percent. The general public boundary is 18 feet horizontally from the antenna face and 5 feet below the bottom of the canister; the antenna is mounted at a radiation center of approximately 52 feet above grade, so no publicly accessible location falls within that boundary. Signage and access measures are provided as the report recommends. The Part 27 component of the transmitted power exceeds the 1,640 W EIRP threshold in Table 1 of 47 C.F.R. Section 1.1307(b)(1). The facilities therefore do not rely on categorical exclusion, and compliance is demonstrated Item 2 Attachment G - Applicant's Project Description Letter & Photo Simulations     Packet Pg. 94     CRAN_RSFR_PALO4_004 · _005 · _006 | Application Cover Letter Page 9 by the enclosed site-specific exposure study. The completed FCC categorical exclusion checklists are enclosed and reflect that determination on their face. VII. FCC CLASSIFICATION AND EFFECTIVE PROHIBITION Classification These facilities do not qualify as small wireless facilities under 47 C.F.R. Section 1.6002(l). Each is mounted on a structure that, with the facility, exceeds 50 feet in height, and each extends the existing structure to a height of more than 50 feet. At PALO4_004 the existing pole is 43′-0″ and the top of the antenna is 52′-11″; the corresponding figures are 43′-10″ and 53′-9″ at PALO4_005 and 43′-6″ and 53′-5″ at PALO4_006. The classification turns on height. Effective prohibition The checklist asks whether the applicant alleges that strict application of a City rule, regulation or Objective Standard, or failure to approve the application, will violate preemptive state or federal law. AT&T has answered yes, limited to the second clause. AT&T does not allege that strict application of any City rule, regulation or Objective Standard would do so, and requests no exception. Section 332(c)(7)(B)(i)(II) of the Communications Act provides that local regulation of the placement, construction and modification of personal wireless service facilities shall not prohibit or have the effect of prohibiting the provision of personal wireless services, and Section 253(a) provides the same as to telecommunications service. In the Ninth Circuit a denial has that effect where the applicant shows a significant gap in service coverage and that the proposed facility is the least intrusive means of closing it. MetroPCS, Inc. v. City and County of San Francisco, 400 F.3d 715 (9th Cir. 2005); T-Mobile USA, Inc. v. City of Anacortes, 572 F.3d 987 (9th Cir. 2009); American Tower Corp. v. City of San Diego, 763 F.3d 1035 (9th Cir. 2014). The Commission has further held that a local legal requirement is an effective prohibition where it materially inhibits the provision of service, including the improvement of existing service and the introduction of new service. Declaratory Ruling and Third Report and Order, FCC 18-133 (2018), upheld in relevant part in City of Portland v. FCC, 969 F.3d 1020 (9th Cir. 2020). Section 332(c)(7)(B)(iii) requires that any denial be in writing and supported by substantial evidence in a written record. The record supporting that response is in this submittal. The Radio Frequency Statements and coverage maps establish the significant gap at each site. The Alternative Site Analysis evaluates the available locations against the design constraints those statements identify and documents why each was not selected. The plans, elevations and photographic simulations establish the design as the least intrusive means available. The exposure reports establish that no health or safety ground supports denial. A separate statement supporting the preemption response is enclosed. VIII. FCC SHOT CLOCK COMPLIANCE (47 C.F.R. § 1.600 3) Applicable Shot Clock. AT&T proposes to collocate a facility other than a small wireless facility on an existing structure. Under 47 C.F.R. § 1.6003(c)(1)(iii), the presumptively reasonable period of time for the city to review this application is 90 days. Shot Clock Commencement and Computation: The 90-day shot clock commences when AT&T submits this application. 47 C.F.R. § 1.6003(e). AT&T computes the shot clock as follows: Application Submission Date: August 14, 2026 30 Day Completeness Review Deadline: September 14, 2026 Applicable Shot Clock Period: 90 calendar days (47 C.F.R. § 1.6003(c)(1)(iii)) Shot Clock Expiration Date: November 12, 2026 AT&T submits that this application is complete as filed, addressing every element of PAMC § 18.42.110 and the City’s Tier 2 WCF Public Right-of-Way Application Submittal Requirements Checklist and providing all required supporting documentation. AT&T respectfully requests that the City issue a written determination of completeness promptly upon receipt. Item 2 Attachment G - Applicant's Project Description Letter & Photo Simulations     Packet Pg. 95     CRAN_RSFR_PALO4_004 · _005 · _006 | Application Cover Letter Page 10 Interaction with the Tier 2 Permit Process. The 90-day shot clock applies regardless of the procedural track the city employs. If the city requires a public hearing or hearings, including referral to the Architectural Review Board under PAMC § 18.42.110(g)(1), the city’s final decision must be made within the 90-day shot clock. AT&T urges prompt processing and will cooperate fully with the City’s scheduling requirements. IX. SEQUENCING OF COMPANION PERMIT APPLICATIONS The Tier 2 checklist requests application numbers and submittal dates for the Building, Excavating and Grading, Electrical, Street Work and Encroachment applications, together with the Insurance Certificate, the Master License Agreement Exhibit and the Utility Map Request. Planning and Development Services has confirmed that the companion permit applications need not accompany this submittal. The proposed design must first be reviewed by the Architectural Review Board, and the construction documents on which those applications depend cannot be finalized until that review is complete. Filing them now would require their withdrawal and resubmittal following any design direction from the Board. The Master License Agreement contemplates the same sequence, with planning review and encroachment permitting preceding execution of the site license for each location. The Utility Map Request does not apply to these three facilities, because power is served overhead from the existing distribution facilities on each host pole and no underground utility information is required. AT&T will submit each companion application in the ordinary course as the design is finalized and will provide the application numbers and submittal dates as they are assigned. X. COMMUNITY MEETING AND NOTICING Controlling text. PAMC Section 18.42.110(d)(7) provides that the applicant shall give notice of the community meeting to all residents and property owners within 600 feet of the project site at least 14 days in advance of the community meeting; that applicants are encouraged to host the meeting before submitting an application; and that before an application may be approved, the applicant shall provide a proof of notice affidavit to the city containing (A) proof that the applicant noticed and hosted the community meeting no later than 15 days after filing the application, and (B) a summary of comments received at the community meeting and what, if any, changes were made to the application as a result of the meeting. Work performed. Notice was mailed on Thursday, August 6, 2026 to all owners and occupants within 600 feet of each of the three proposed facilities, through Express Notice and Mail LLC. The notification packages establish who was entitled to notice at each site: 228 owners and occupants at PALO4_004, 191 at PALO4_005 and 290 at PALO4_006. The community meeting is scheduled for Tuesday, August 25, 2026 from 6:00 p.m. to 8:00 p.m. at 555 University Avenue, Palo Alto. The enclosed Community Meeting Notices and Affidavit of Mailing contains, in order, the three notification packages with the certification, 600-foot radius map and list of owners and occupants for each site, followed by the Affidavit of Public Noticing. The affidavit comprises a notarised Declaration of Mailing, the USPS Form 3877 firm mailing books stamped by the Post Office, the combined 600-foot radius map for all three sites, the combined owners and occupants list, and the notice as mailed with its vicinity map and photographic simulation. Requirement PAMC 18.42.110(d)(7) Actual Status Notice radius All residents and property owners within 600 feet of the project site 600 feet from each of the three facilities; 709 owners and occupants noticed Met Notice lead time At least 14 days in advance of the community meeting Mailed August 6, 2026 for an August 25, 2026 meeting: 19 days Met Meeting timing Noticed and hosted no later than 15 days after filing the application Filed August 14, 2026; meeting August 25, 2026: 11 days after filing Met Proof of notice affidavit Provided before the application may be approved Enclosed: notarised Declaration of Mailing, USPS Form 3877 Provided Item 2 Attachment G - Applicant's Project Description Letter & Photo Simulations     Packet Pg. 96     CRAN_RSFR_PALO4_004 · _005 · _006 | Application Cover Letter Page 11 Requirement PAMC 18.42.110(d)(7) Actual Status firm mailing books, radius map, owners list, notice as mailed Summary of comments Provided before the application may be approved Follows the August 25, 2026 meeting; will be supplemented Due after meeting Notice preceded the filing of this application by eight days and preceded the community meeting by nineteen days, five days more than the ordinance requires. The meeting falls on the eleventh day after filing, four days inside the fifteen-day limit. The applicant therefore satisfies both timing requirements with margin on each, rather than relying on the compressed schedule that arises when notice is released on the day of filing. To be supplemented. The enclosed affidavit establishes that notice was given. Proof that the meeting was hosted, and the summary of comments received at the meeting together with any resulting changes to the application, necessarily follow the August 25, 2026 meeting. AT&T will supplement the record with both promptly after the meeting. Under PAMC Section 18.42.110(d)(7) those items are required before an application may be approved, not at filing, and their absence at filing is therefore not a completeness defect. XI. ENCLOSED APPLICATION MATERIALS 1. Completed Tier 2 WCF Public Right-of-Way Application Submittal Requirements Checklist, signed 2. Construction drawings, all sheets, for CRAN_RSFR_PALO4_004, _005 and _006 3. Structural analysis reports, stamped and signed, with GO 95 pole loading analysis 4. Traffic control plans 5. Tree protection inventory, tree protection plans and arborist report 6. Location maps with tabulated distances to residential structures, and address tables 7. Photographic simulations 8. AT&T Mobility Radio Frequency Statements and existing and proposed coverage maps, one set per site 9. Alternative Site Analysis, with cover letter 10. Alternative Small Cell Concealment Design Scenarios Considered 11. EME reports and completed FCC categorical exclusion checklists 12. Inventory of AT&T existing and entitled antenna locations within the City of Palo Alto 13. Hazardous Materials Disclosure Checklist, signed 14. Community meeting notices and proof of notice affidavit 15. Statement Regarding Checklist Items Measured Against the Repealed Objective Standards 16. Statement in Support of the Preemption Response on the Tier 2 Checklist AT&T and NextEdge Networks welcome the opportunity to meet with Planning, Public Works, Utilities and the City Attorney’s Office in advance of the Architectural Review Board hearing. Please direct any question on this submittal to the undersigned. Respectfully submitted, Tasha Stack Contractor, NextEdge Networks Holdings LLC Authorized agent for New Cingular Wireless PCS, LLC dba AT&T Mobility 8/14/2026 Item 2 Attachment G - Applicant's Project Description Letter & Photo Simulations     Packet Pg. 97     NextEdge Networks Holdings LLC 1355 Windward Concourse, Suite 410, Alpharetta, GA 30005 On behalf of AT&T Mobility August 14, 2026 City of Palo Alto Planning and Development Services 250 Hamilton Avenue Palo Alto, California 94301 Attention: Ms. Nishita Kandikuppa, Planning and Development Services Re: Statement Regarding Checklist Items Measured Against the Repealed Objective Standards Tier 2 Wireless Communication Facilities Proposed for the Public Right-of-Way CRAN_RSFR_PALO4_004, 804 Boyce Avenue · CRAN_RSFR_PALO4_005, 670 Guinda Street · CRAN_RSFR_PALO4_006, 754 Homer Avenue Dear Ms. Kandikuppa: The Tier 2 WCF Public Right-of-Way Application Submittal Requirements Checklist in use is the December 2019 edition. It predates Ordinance 5655 and repeatedly requires the applicant to measure the proposal against the Objective Standards adopted by the December 16, 2019 Council action. That action is Resolution 9873, which Ordinance 5655 repealed. This statement identifies each affected checklist item, states how the applicant has responded to it, and identifies the currently active policy against which this application is measured. It is submitted so that the City has a single written response to every such item rather than a series of blanks across the package. REGULATORY STATUS Ordinance 5655, Section 2, provides that Resolution 9873, Amending Objective Aesthetic, Noise, and Related Standards for Wireless Communication Facilities in the Public Rights of Way, adopted December 16, 2019, is repealed, and that by the same action the Council repeals all prior versions of those objective standards, including Resolutions 9825, 9847 and 9855. No objective siting, design, noise or distance standards for facilities in the public right-of-way remain in effect. Date Action Status Apr. 15, 2019 Resolution 9825, first objective aesthetic, noise and siting standards for WCFs in the public right-of-way Repealed Jun. 17, 2019 Resolution 9847, amendment Repealed Aug. 12, 2019 Resolution 9855, amendment Repealed Dec. 16, 2019 Resolution 9873, consolidated Objective Standards with Exhibits 1 through 3, including the residential zone of exclusion and the road network map. This is the December 16, 2019 Council action the checklist cites. Repealed Jun. 9, 2025 Ordinance 5655 adopted, 7 to 0. Section 2 repeals Resolution 9873 and, for the avoidance of doubt, all prior versions. Enacted ~Jul. 10, 2025 Ordinance 5655 effective, thirty-one days after adoption In effect Item 2 Attachment G - Applicant's Project Description Letter & Photo Simulations     Packet Pg. 98     Date Action Status Jun. 10, 2027 Ordinance 5655 expires by its own terms unless extended or replaced Scheduled THE POLICY THIS APPLICATION IS MEASURED AGAINST This application is prepared and submitted against the policy in effect on the date of filing, which is PAMC Section 18.42.110 as amended by Ordinance 5655, together with the architectural review findings at PAMC Section 18.76.020(d). Ordinance 5655 makes referral to the Architectural Review Board mandatory for Tier 2 and Tier 3 facilities in the public right-of-way, and approval requires all of the findings at Section 18.76.020(d), which address aesthetic quality, compatibility with the immediate environment and neighborhood character, functional design, landscape design, and sustainability. The application package is built to support those findings. It includes photographic simulations from public vantage points at each site, elevations and sections showing all existing and proposed pole attachments, a description of the concealment design and of the alternative designs considered, and the technical basis for the design selected at each pole type. Where a checklist item asks a factual question that is independent of the repealed standards, the applicant has answered it on the merits rather than declining on regulatory grounds. ITEM BY ITEM RESPONSE The following items call for a response measured against the repealed standards. Each is answered below. Checklist Provision Where It Appears Applicant Response Materials show one or more WCF designs that meet all of the City’s rules, regulations, and Objective Standards (Refer to City Council Action on December 16, 2019) Application Basic Information, page 1 Answered N/A. The December 16, 2019 Council action is Resolution 9873, repealed in its entirety by Ordinance 5655, Section 2. No Objective Standards are in effect against which the designs can be measured. The designs are addressed against currently active policy as described above. Materials request one or more WCF exception requests to the City’s rules, regulations, or Objective Standards Application Basic Information, page 1 Answered N/A. No exception is sought. Ordinance 5655 removed the reference to objective standards adopted by City Council resolution from PAMC Section 18.42.110(k)(1) and deleted subsection (k)(3). Statement that the materials show facilities meeting all of the City’s rules, regulations, and Objective Standards, or a detailed statement of all requested exceptions and why a standard is infeasible Project description This statement is that response. No Objective Standards are in effect, and no exception under PAMC Section 18.42.110(k) is requested. Clarification on how future expansion, including the addition of 5G equipment if not currently proposed, would be designed in accordance with applicable laws and the City’s Objective Standards Project description 5G is proposed now, not as a future addition. Each facility will operate 4G LTE in the 700 MHz band and 5G in the 850 MHz band and in C- Band when placed in service, using the equipment shown on the project plans. No additional equipment is proposed at these three poles. These three facilities are part of a thirteen-node AT&T program in Palo Alto. The remaining ten are proposed on City streetlight poles and will be submitted under separate Tier 2 applications, each with its own design and supporting record. They are identified here so the City has the full program scope at intake. Any modification to an approved facility would be reviewed under Item 2 Attachment G - Applicant's Project Description Letter & Photo Simulations     Packet Pg. 99     Checklist Provision Where It Appears Applicant Response PAMC Section 18.42.110 and the standards in effect at the time it is proposed. The applicant does not represent compliance with standards that are not in effect. Location map showing the distance and location of scenic routes, residences, schools, and other WCFs within 600 feet Plan sheet requirements Provided. The 600 foot threshold and the scenic route designation derive from the repealed standards. The distances are stated as site context and as a factual record, not as a measure of compliance with any standard presently in effect. The applicant has asked the City to confirm whether this item remains applicable and, if so, the standard against which the distances are measured. Dimensioned residential zone of exclusion area where a facility is proposed in a residential zoning district Site plan requirements Not required of this application. Planning staff confirmed in writing on July 29, 2026, given the timing of this submittal in relation to the repeal of the objective standards by Ordinance 5655. No dimensioned residential zone of exclusion is included. Clarification if one or more wireless communication facilities will generate any noise Project description Addressed on its merits. The WCF-specific noise standards were repealed with Resolution 9873. PAMC Chapter 9.10 remains in effect and governs. The facility has no air conditioning, no compressors, no pumps, no generator and no powered enclosure ventilation; the enclosure is passively ventilated and the only moving components are the two integral radio cooling fans supplied with the radio units. The full acoustic analysis is set out in the application cover letter. Certification page questions on exceptions sought and on preemption Certification page, page 6 Answered on the same basis. No exception is sought, so the first question is answered no. The preemption question is answered yes, limited to failure to approve, and is supported by a separate statement submitted with this application. ITEMS NOT AFFECTED Two checklist items reference distances to structures and are not dependent on the repealed standards. Both are provided in the ordinary course. First, the footprint of all buildings and structures on adjacent parcels, with distances from the proposed facility indicated. This is general site plan content. Second, the distance to the closest habitable or occupied structure in each direction where an omnidirectional antenna is proposed. This is radiofrequency exposure documentation and is required independently of any local aesthetic standard. Both PALO4 antenna models are omnidirectional, and the omnidirectional branch of the item applies. WRITTEN CONFIRMATION RECEIVED On July 29, 2026, Ms. Nishita Kandikuppa of the Planning Department confirmed by electronic mail that the residential exclusion area is not required of this application, given the timing of this submittal in relation to the repeal of the objective standards by Ordinance 5655. This application therefore does not include a dimensioned residential zone of exclusion. RESERVATION AT&T reserves all rights under federal and state law, including 47 U.S.C. Sections 253 and 332 and California Government Code Sections 65940 through 65944 and 65964.1, and waives none by submitting these applications or by participating in the City’s review. Item 2 Attachment G - Applicant's Project Description Letter & Photo Simulations     Packet Pg. 100     The applicant welcomes the opportunity to discuss this statement with Planning and with the City Attorney’s Office in advance of the Architectural Review Board hearing, and will revise it to reflect any direction the City provides. Respectfully submitted, Tasha Stack Contractor, NextEdge Networks Holdings LLC Authorized agent for New Cingular Wireless PCS, LLC dba AT&T Mobility 8/14/2026 Item 2 Attachment G - Applicant's Project Description Letter & Photo Simulations     Packet Pg. 101     NextEdge Networks Holdings LLC 1355 Windward Concourse, Suite 410, Alpharetta, GA 30005 On behalf of AT&T Mobility August 14, 2026 City of Palo Alto Planning and Development Services 250 Hamilton Avenue Palo Alto, California 94301 Attention: Ms. Nishita Kandikuppa, Planning and Development Services Re: Statement in Support of the Preemption Response on the Tier 2 WCF Public Right-of-Way Application Submittal Requirements Checklist CRAN_RSFR_PALO4_004, 804 Boyce Avenue · CRAN_RSFR_PALO4_005, 670 Guinda Street · CRAN_RSFR_PALO4_006, 754 Homer Avenue Dear Ms. Kandikuppa: The Tier 2 checklist asks whether the applicant alleges that strict application of a City rule, regulation, or Objective Standard, or failure to approve the application, will violate preemptive state or federal law, and directs that supporting documentation be provided if the answer is yes. The applicant has answered yes. This statement identifies the scope of that answer and the record supporting it. SCOPE OF THE RESPONSE The applicant’s answer is limited to the second clause of the question. AT&T alleges that a failure to approve these three applications would violate preemptive federal law. AT&T does not allege that strict application of any City rule, regulation, or Objective Standard would do so. That distinction is deliberate and is reflected throughout the submittal. Ordinance 5655 repealed the Objective Standards adopted by Resolution 9873 on December 16, 2019, together with all prior versions, and no replacement Objective Standards are presently in effect. The applications are therefore measured against currently active policy: PAMC Section 18.42.110 as amended by Ordinance 5655, together with the architectural review findings at PAMC Section 18.76.020(d). Planning staff confirmed in writing on July 29, 2026 that the residential zone of exclusion established by the repealed standards does not presently apply. No exception under PAMC Section 18.42.110(k) is requested, and the applicant has answered no to the preceding question on the checklist for that reason. Each facility is a collocation on an existing City of Palo Alto Utilities wood distribution pole in the public right-of-way. No new pole is proposed, no pole replacement is proposed, and no ground-mounted equipment is proposed. The response is preserved because the checklist requires the applicant to state its position at the time of submittal, before the City has acted. Federal law attaches to the outcome of the City’s process, not to the content of the City’s standards as applied here. Answering no would waive an issue that has not yet arisen and that the applicant has no present reason to believe will arise. FEDERAL FRAMEWORK Section 332(c)(7)(B)(i)(II) of the Communications Act provides that the regulation of the placement, construction, and modification of personal wireless service facilities by a State or local government shall not prohibit or have the effect of prohibiting the provision of personal wireless services. Section 253(a) Item 2 Attachment G - Applicant's Project Description Letter & Photo Simulations     Packet Pg. 102     provides that no State or local statute, regulation, or legal requirement may prohibit or have the effect of prohibiting the ability of any entity to provide any interstate or intrastate telecommunications service. In the Ninth Circuit, a denial has the effect of prohibiting service when the applicant shows a significant gap in service coverage and that the proposed facility is the least intrusive means of closing that gap. MetroPCS, Inc. v. City and County of San Francisco, 400 F.3d 715 (9th Cir. 2005); T-Mobile USA, Inc. v. City of Anacortes, 572 F.3d 987 (9th Cir. 2009); American Tower Corp. v. City of San Diego, 763 F.3d 1035 (9th Cir. 2014). The Federal Communications Commission has further held that a State or local legal requirement constitutes an effective prohibition where it materially inhibits the provision of service, including the improvement of existing service and the introduction of new service. Declaratory Ruling and Third Report and Order, FCC 18-133 (2018), upheld in relevant part in City of Portland v. FCC, 969 F.3d 1020 (9th Cir. 2020). Section 332(c)(7)(B)(iii) further requires that any denial be in writing and supported by substantial evidence contained in a written record. THE RECORD SUPPORTING THE ALLEGATION The following materials, all submitted with these applications, are the documentation supporting the response. They are identified here so that the City has the complete basis for the answer at intake rather than after a decision. Record Document What It Establishes Element Supported AT&T Mobility Radio Frequency Statement, one per site Existence, location and boundaries of the significant service coverage gap; the design principles that govern node placement Significant gap Existing and proposed coverage and capacity plots, one pair per site Measured and modeled RSRP conditions before and after the proposed facility Significant gap Alternative Site Analysis Fifteen alternative locations evaluated across the three sites, each with distance, direction, photograph and the reason it was not selected Least intrusive means Project plans and elevations Concealment design on the existing City-owned wood distribution pole; no new pole and no ground equipment proposed Least intrusive means Photographic simulations Existing and proposed views from public vantage points at each site Least intrusive means EME reports and FCC categorical exclusion checklists Maximum public exposure at each site is a small fraction of the FCC general population limit No health or safety basis for denial In summary, each Radio Frequency Statement identifies a significant gap in AT&T’s 4G LTE service coverage across a large, predominantly residential area of Palo Alto, and explains the design constraints that govern where a node closing that gap can be placed. The Alternative Site Analysis then evaluates the available locations against those constraints and documents why each was not selected, either because it Item 2 Attachment G - Applicant's Project Description Letter & Photo Simulations     Packet Pg. 103     cannot technically achieve the coverage objective or because it could do so only through a more intrusive structure. The proposed facilities are the least intrusive means identified by that analysis. TIMING Because these facilities do not qualify as small wireless facilities under the FCC’s definition, and because each is a collocation on an existing structure, the applicable Commission review period is 90 days under 47 C.F.R. Section 1.6003(c)(1)(iii). The applicant notes the review period for scheduling purposes only and asks that these applications be processed as promptly as the City’s process allows. AT&T will respond to any request for supplemental information without delay. RESERVATION Nothing in this statement is a claim that the City has acted or will act unlawfully. The applicant has answered the checklist question accurately and has provided the supporting record the checklist requires. AT&T reserves all rights under 47 U.S.C. Sections 253 and 332, under California Government Code Section 65964.1, and under all other applicable law, and waives none by submitting these applications or by participating in the City’s review. The applicant welcomes the opportunity to discuss any of the above with Planning, Public Works, Utilities, and the City Attorney’s Office in advance of the Architectural Review Board hearing. Respectfully submitted, Tasha Stack Contractor, NextEdge Networks Holdings LLC Authorized agent for New Cingular Wireless PCS, LLC dba AT&T Mobility 8/14/2026 Item 2 Attachment G - Applicant's Project Description Letter & Photo Simulations     Packet Pg. 104     NextEdge Networks Holdings LLC 1355 Windward Concourse, Suite 410, Alpharetta, GA 30005 On behalf of AT&T Mobility Photographic Simulations Tier 2 Wireless Communication Facilities Proposed for the Public Right-of-Way City of Palo Alto, California SITES CRAN_RSFR_PALO4_004 Public right-of-way near 804 Boyce Avenue CRAN_RSFR_PALO4_005 Public right-of-way near 670 Guinda Street CRAN_RSFR_PALO4_006 Public right-of-way near 754 Homer Avenue APPLICANT AT&T Mobility PREPARED BY AdvanceSim, Photo Simulation Solutions SIMULATIONS PRODUCED August 6, 2026 COMPILED August 14, 2026 Two viewpoints are provided for each proposed facility. Every sheet pairs the existing condition with the proposed condition from the same camera position, and identifies the proposed AT&T installation by callout. 8 pages. Item 2 Attachment G - Applicant's Project Description Letter & Photo Simulations     Packet Pg. 105     NextEdge Networks Holdings LLC 1355 Windward Concourse, Suite 410, Alpharetta, GA 30005 On behalf of AT&T Mobility Table of Contents CRAN_RSFR_PALO4_004 Public right-of-way near 804 Boyce Avenue, Palo Alto, CA 94301 View from Boyce Avenue looking southeast at site Landscape sheet, existing and proposed p. 3 View from Guinda Street looking northwest at site Portrait sheet, existing and proposed p. 4 CRAN_RSFR_PALO4_005-D Public right-of-way near 670 Guinda Street, Palo Alto, CA 94301 View from Forest Avenue looking west at site Landscape sheet, existing and proposed p. 5 View from Forest Avenue looking northeast at site Portrait sheet, existing and proposed p. 6 CRAN_RSFR_PALO4_006-G Public right-of-way near 754 Homer Avenue, Palo Alto, CA 94301 View from Homer Avenue looking south at site Landscape sheet, existing and proposed p. 7 View from Homer Avenue looking northeast at site Portrait sheet, existing and proposed p. 8 RELATIONSHIP TO THE TIER 2 CHECKLIST The Tier 2 WCF Public Right-of-Way Application Submittal Requirements Checklist calls for colour visual simulations "prepared to scale comparing existing and proposed conditions and context utilizing views consistent with the existing and proposed elevations." These sheets satisfy that item. They are also responsive to the checklist item requiring colour photographs showing the relationship of the proposed facility to adjacent buildings and to the neighbourhood. On each sheet the existing and proposed images are taken from the same camera position, so the only difference between the two is the proposed installation. The pole top extension, canister antenna and pole-mounted shroud are visible in the proposed image and identified by callout. Simulations prepared by AdvanceSim on behalf of AT&T Mobility. Item 2 Attachment G - Applicant's Project Description Letter & Photo Simulations     Packet Pg. 106     Item 2 Attachment G - Applicant's Project Description Letter & Photo Simulations     Packet Pg. 107     Item 2 Attachment G - Applicant's Project Description Letter & Photo Simulations     Packet Pg. 108     Item 2 Attachment G - Applicant's Project Description Letter & Photo Simulations     Packet Pg. 109     Item 2 Attachment G - Applicant's Project Description Letter & Photo Simulations     Packet Pg. 110     Outlook Re: Please reject AT&T’s proposed neighborhood cell towers From Kandikuppa, Nishita <Nishita.Kandikuppa@paloalto.gov> Date Wed 9/30/2026 8:56 AM To Tran, Vickie <Vickie.Tran@paloalto.gov> Cc Lait, Jonathan <Jonathan.Lait@paloalto.gov> Hi Vickie, Confirming receipt of the public comments. I will include them in the attachments along with other public comments. Best, Nishita Nishita Kandikuppa Planner Planning and Development Services Department (650) 838-2806 | nishita.kandikuppa@paloalto.gov www.paloalto.gov From: Tran, Vickie <Vickie.Tran@paloalto.gov> Sent: Tuesday, September 29, 2026 4:36 PM To: Kandikuppa, Nishita <Nishita.Kandikuppa@paloalto.gov> Cc: Lait, Jonathan <Jonathan.Lait@paloalto.gov> Subject: FW: Please reject AT&T’s proposed neighborhood cell towers   Hi Nishita, Please see below for public comment on AT&T proposed neighborhood cell towers. VICKIE TRAN Administrative Assistant to the Director Planning and Development Department vickie.tran@paloalto.gov www.paloalto.gov From: Velasquez, Ingrid <Ingrid.Velasquez@paloalto.gov> Sent: Monday, September 28, 2026 10:17 AM To: Lait, Jonathan <Jonathan.Lait@paloalto.gov>; Tran, Vickie <Vickie.Tran@paloalto.gov>; Kurotori, Alan <Alan.Kurotori@paloalto.gov> 9/30/26, 5:58 PM Mail - Kandikuppa, Nishita - Outlook https://outlook.office.com/mail/inbox/id/AAQkADVmNWM1NDcyLWQ5YzYtNGI5OS05YmZkLTk0MjdlMmI5OWIwMQAQACUop37qMipNkd4s2QKU0zY…1/3 Item 2 Attachment H - Public Comments     Packet Pg. 111     &nbsp; Cc: Nose, Kiely <Kiely.Nose@paloalto.gov>; Gaines, Chantal <Chantal.Gaines@paloalto.gov>; City Mgr <CityMgr@paloalto.gov> Subject: FW: Please reject AT&T’s proposed neighborhood cell towers Hello, Forwarding the comment below for awareness. Thanks, Ingrid Ingrid Velásquez Administrative Assistant Office of the City Manager (650) 329-2354| Ingrid.Velasquez@PaloAlto.gov www.PaloAlto.gov From: Andrea Helft Sent: Friday, September 25, 2026 9:52 AM To: Architectural Review Board <arb@PaloAlto.gov> Cc: Council, City <city.council@PaloAlto.gov>; Clerk, City <City.Clerk@PaloAlto.gov> Subject: Please reject AT&T’s proposed neighborhood cell towers CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. Dear Chair Adcock, Vice Chair Rosenberg, and Members Chen, Hirsch, and Jojarth,In May 2025, City Council voted unanimously to restore Architectural Review Board review of new cell towers. The Council also expressed a clear preference for placing towers a meaningful distance from homes.I’m writing to i This message needs your attention This is a personal email address. This is their first email to your company. Mark Safe Report CGBANNERINDICATOR Dear Chair Adcock, Vice Chair Rosenberg, and Members Chen, Hirsch, and Jojarth, In May 2025, City Council voted unanimously to restore Architectural Review Board review of new cell towers. The Council also expressed a clear preference for placing towers a meaningful distance from homes. I’m writing to ask the ARB to apply the Municipal Code and its own aesthetic judgment when reviewing AT&T’s proposals, with particular attention to nearby residents. Please require AT&T to move Powered by Mimecast 9/30/26, 5:58 PM Mail - Kandikuppa, Nishita - Outlook https://outlook.office.com/mail/inbox/id/AAQkADVmNWM1NDcyLWQ5YzYtNGI5OS05YmZkLTk0MjdlMmI5OWIwMQAQACUop37qMipNkd4s2QKU0zY…2/3 Item 2 Attachment H - Public Comments     Packet Pg. 112     the towers farther from homes, place radios and related equipment underground, and reduce the height of the poles. Please also ask AT&T to show what alternative sites and designs it considered, and why those options could not meet its service needs with less impact on nearby homes. Thanks, Andrea -- Andrea Helft 9/30/26, 5:58 PM Mail - Kandikuppa, Nishita - Outlook https://outlook.office.com/mail/inbox/id/AAQkADVmNWM1NDcyLWQ5YzYtNGI5OS05YmZkLTk0MjdlMmI5OWIwMQAQACUop37qMipNkd4s2QKU0zY…3/3 Item 2 Attachment H - Public Comments     Packet Pg. 113     Outlook Re: Concerns around new AT&T installations From Kandikuppa, Nishita <Nishita.Kandikuppa@paloalto.gov> Date Thu 8/20/2026 11:40 AM To Darya Nachinkina Bcc Tasha Stack <tasha.stack@nextedgenetworks.com>; GRABISCH, MARC D <mg387k@att.com> Hi Darya, Thank you for taking the time to share your questions and comments regarding the proposed wireless facilities. Please note that your comments will be included in the project’s public record. The project proposes three (3) new wireless facilities on existing wood utility poles near 804 Boyce Avenue, 670 Guinda Street, and 754 Homer Avenue; the poles are not planned for replacement. The facilities are proposed by AT&T to improve wireless service coverage and signal quality in the area where AT&T is experiencing a significant service gap. Wireless facility locations are typically selected based on several practical and technical factors, including where service is needed, the surrounding terrain and buildings, availability of suitable structures or utility poles, and whether the facilities can meet Federal safety requirements which are taken very seriously and reviewed thoroughly by City staff. The City is reviewing applicable local land use, design, location, and permitting considerations under Palo Alto Municipal Code (PAMC) Section 18.42.110 Wireless Communication Facilities , including whether the project is consistent with the applicable zoning and development standards. As part of that review, staff will consider the materials submitted by the applicant, including site plans, visual simulations, coverage information, alternative-location analysis, and Radio Frequency (RF) compliance materials, which are all required per the application checklists for the proposed wireless projects. Regarding the health impacts of wireless projects, Federal law limits the City’s ability to deny or regulate a wireless facility based on RF emissions if the facility complies with Federal Communications Commission (FCC) standards. FCC identifies two separate tiers of exposure pertaining to wireless projects: Occupational exposure limits apply to workers who may be near wireless antennas as part of their job. These limits apply where workers have been informed about the potential for RF exposure and can take steps to manage their exposure. For this project, the antennas would be located approximately 45+ feet above ground level. RF exposure near the antennas depends on the antenna height, orientation, and direction of the signal. General public exposure limits apply to residents, pedestrians, and others who may be near a facility but do not work around the equipment or control their exposure at the height of the antennas. The general public limits are more protective than the occupational limits. The proposed antennas are designed to direct signals outward toward the service area, rather than directly toward the ground. Based on the applicant’s RF compliance analysis, RF exposure at ground level—including areas typically accessible to the public—would remain below applicable FCC limits. Under the Telecommunications Act of 1996, Federal regulations preempt State and local regulation of RF emissions generated by wireless facilities. The City’s authority in this area is limited to ensuring that the proposed installation complies with comprehensive emissions standards established by the FCC. Federal regulations also require signage to be posted that is visible upon approach that informs personnel accessing this area of basic precautions to be followed when working around the antennas. These exposure limits are also shown graphically and explained in the text of the attached RFE Report, but I am including screenshots 9/30/26, 5:57 PM Re: Concerns around new AT&T installations - Kandikuppa, Nishita - Outlook about:blank?windowId=SecondaryReadingPane3 1/5 Item 2 Attachment H - Public Comments     Packet Pg. 114     below for each of the sites identified in the project plans. To reiterate, the submitted RFE analysis would meet applicable FCC exposure limits. 804 Boyce Avenue 670 Guinda Street 9/30/26, 5:57 PM Re: Concerns around new AT&T installations - Kandikuppa, Nishita - Outlook about:blank?windowId=SecondaryReadingPane3 2/5 Item 2 Attachment H - Public Comments     Packet Pg. 115     754 Homer Avenue 9/30/26, 5:57 PM Re: Concerns around new AT&T installations - Kandikuppa, Nishita - Outlook about:blank?windowId=SecondaryReadingPane3 3/5 Item 2 Attachment H - Public Comments     Packet Pg. 116     The applicant has provided all the items you requested as a part of their application materials which can viewed on Permit View. The application number is 26PLN-00229. You will need an account to access the project materials so unfortunately, I am unable to send a link to the project-specific Permit View page. I hope this information is helpful. City staff is reviewing the project materials to determine whether the proposed equipment meets all applicable requirements. Because the proposed facilities would be located in the public right-of-way, the project will also require a public hearing before the Architectural Review Board (ARB). I will send a follow-up email once the hearing date has been scheduled. The ARB hearing will provide an additional opportunity for you to share your concerns, even if you are unable to attend the Community Meeting. Thank you again for taking the time to participate in the review process. Please reach out if you have any additional questions. Best, Nishita Nishita Kandikuppa Associate Planner Planning and Development Services Department (650) 838-2806 | nishita.kandikuppa@paloalto.gov www.paloalto.gov 9/30/26, 5:57 PM Re: Concerns around new AT&T installations - Kandikuppa, Nishita - Outlook about:blank?windowId=SecondaryReadingPane3 4/5 Item 2 Attachment H - Public Comments     Packet Pg. 117     From: Darya Nachinkina Sent: Wednesday, August 19, 2026 9:33 PM To: Kandikuppa, Nishita <Nishita.Kandikuppa@paloalto.gov> Subject: Concerns around new AT&T installations   CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. i This message needs your attention This is a personal email address. This is their first email to you. Mark Safe Report Hi Nishita, I am a property owner at 757 Homer Ave and I am contacting you with regard to a notice I received by mail about a proposed AT&T wireless antenna installation in my immediate vicinity. My house is directly in front one of the proposed wireless antenna (PALO4_006), and in the triangle of all three new proposed towers. I do not feel comfortable with this project, both because I am concerned about its impact on property values and, more importantly, because I am concerned about potential health effects of living in such close proximity to multiple new wireless antennas. The World Health Organization's cancer research agency (IARC) classifies RF radiation a a Group 2B possible carcinogen. Has the City of Palo Alto reviewed the RF emissions report for this type of project, and can this report be shared publicly with residents before the decision is considered? Putting three new antennas in the same neighborhood seems excessive - can the City share spacing regulations for these types of nodes? Unfortunately I am not available for the live hearing on this matter on 8/25 as I will be out of town but I appreciate your attention to this matter and will look forward to your response. Respectfully, Darya Nachinkina Powered by Mimecast 9/30/26, 5:57 PM Re: Concerns around new AT&T installations - Kandikuppa, Nishita - Outlook about:blank?windowId=SecondaryReadingPane3 5/5 Item 2 Attachment H - Public Comments     Packet Pg. 118     Outlook Re: Objection to AT&T Wireless Facility CRAN_RSFR_PALO4_004 — Near 804 Boyce Avenue From Tim Flagg Date Tue 9/1/2026 2:26 PM To Kandikuppa, Nishita <Nishita.Kandikuppa@paloalto.gov> CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. i This message needs your attention This is a personal email address. Mark Safe Report Hi Nishita, Great, yes, that is fine to have my name included in the public record. Regards, Tim On Tue, Sep 1, 2026 at 2:24 PM Kandikuppa, Nishita <Nishita.Kandikuppa@paloalto.gov> wrote: Hi Tim, Thank you for your email. Personal contact information is redacted from public records, but your name will be included in the record, if that's okay? Best, Nishita Nishita Kandikuppa Associate Planner Planning and Development Services Department (650) 838-2806 | nishita.kandikuppa@paloalto.gov www.paloalto.gov From: Tim Flagg Sent: Tuesday, September 1, 2026 1:51 PM Powered by Mimecast 9/30/26, 5:57 PM Mail - Kandikuppa, Nishita - Outlook https://outlook.office.com/mail/inbox/id/AAQkADVmNWM1NDcyLWQ5YzYtNGI5OS05YmZkLTk0MjdlMmI5OWIwMQAQAGRbMIt9myNCqNhSGpQzO…1/9 Item 2 Attachment H - Public Comments     Packet Pg. 119     To: Kandikuppa, Nishita <Nishita.Kandikuppa@paloalto.gov> Subject: Re: Objection to AT&T Wireless Facility CRAN_RSFR_PALO4_004 — Near 804 Boyce Avenue   CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. Hi Nishita, Thank you for your response. Oops, yes, the height of the telephone pole and the added antennas would result to be 53 feet tall, and the antenna itself isn't 53 tall. Thanks for pointing that out! Is it possible to have my comments included in the public record, but not have my email address and phone number also included? (For spam, phishing, etc. reasons) Thank you again, Tim On Mon, Aug 31, 2026 at 2:13 PM Kandikuppa, Nishita <Nishita.Kandikuppa@paloalto.gov> wrote: Hi Tim, Thank you again for taking the time to share your comments regarding AT&T’s proposed wireless infrastructure. I would like to clarify one point: the proposed antennas would be installed on top of existing utility poles; the antennas themselves are not proposed to be 53 feet tall. I appreciate your thorough review of the proposal and your identification of potential next steps in the City’s review process. As requested, your comments will be included in the public record. Please reach out if you have any additional comments or questions. Best, Nishita Nishita Kandikuppa Associate Planner Planning and Development Services Department (650) 838-2806 | nishita.kandikuppa@paloalto.gov www.paloalto.gov From: Tim Flagg Sent: Monday, August 31, 2026 10:51 AM To: Kandikuppa, Nishita <Nishita.Kandikuppa@paloalto.gov> Subject: Objection to AT&T Wireless Facility CRAN_RSFR_PALO4_004 — Near 804 Boyce Avenue   9/30/26, 5:57 PM Mail - Kandikuppa, Nishita - Outlook https://outlook.office.com/mail/inbox/id/AAQkADVmNWM1NDcyLWQ5YzYtNGI5OS05YmZkLTk0MjdlMmI5OWIwMQAQAGRbMIt9myNCqNhSGpQzO…2/9 Item 2 Attachment H - Public Comments     Packet Pg. 120     CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. Dear Ms. Nishita Kandikuppa, I am writing to object to AT&T's proposed wireless facility, CRAN_RSFR_PALO4_004, on the existing utility pole near 804 Boyce Avenue. I recognize the importance of reliable wireless service and am not opposed to AT&T improving its network. My objection is to this particular location and design, and to AT&T's failure to adequately demonstrate that placing the facility at this location is necessary and represents the least intrusive feasible alternative. 1. The claimed service need should be independently evaluated AT&T describes the area as a "significant service coverage gap" and states that the proposed facility is needed to provide reliable 4G LTE and 5G service. At the public meeting, however, two AT&T customers stated that they were not experiencing problems with their AT&T cellular service. Importantly, these were not customers speaking from distant locations. One AT&T customer was located on Boyce Avenue and another was located on Guinda Street, both within the general residential area identified by AT&T in support of the proposed facility. Furthermore, no AT&T customer attended the meeting to advocate for the proposed facility or to report inadequate AT&T service in the area. The customer testimony that was actually presented was from customers who said they were satisfied with their existing AT&T service. I recognize that the experience of two individual customers does not, by itself, disprove an RF coverage deficiency. AT&T's engineering analysis should be considered on its merits. However, the testimony at the public meeting is relevant to the City's evaluation of AT&T's assertion that this residential area represents a significant service coverage gap. It is particularly relevant that the customers who did speak were located on Boyce and Guinda, within the area AT&T identifies as being affected by the proposed facility, yet neither reported a service problem requiring the proposed installation. The absence of customers appearing to advocate for improved AT&T service, combined with the firsthand testimony of two nearby AT&T customers who reported no problems, warrants a careful examination of the claimed service deficiency before the City approves a facility that will have a substantial and permanent impact on a neighboring residence. I am not suggesting that individual customer experience should replace engineering analysis. Rather, the customer testimony should be considered together with the technical evidence and should prompt the City to require AT&T to clearly identify the specific locations and extent of the alleged coverage deficiency, the service levels currently experienced there, and the measurable improvement expected from the proposed facility. 9/30/26, 5:57 PM Mail - Kandikuppa, Nishita - Outlook https://outlook.office.com/mail/inbox/id/AAQkADVmNWM1NDcyLWQ5YzYtNGI5OS05YmZkLTk0MjdlMmI5OWIwMQAQAGRbMIt9myNCqNhSGpQzO…3/9 Item 2 Attachment H - Public Comments     Packet Pg. 121     2. AT&T's coverage analysis has limitations that should be considered AT&T's coverage exhibits are described as free-space calculations that do not account for attenuation from trees, buildings, or other obstructions. That limitation is important in a residential neighborhood such as this one. The City's decision should therefore not rely solely on generalized coverage maps. AT&T should provide sufficient site-specific information to establish where the service deficiency actually exists and how much improvement the proposed facility would provide. Given the substantial impact on 804 Boyce, AT&T should also demonstrate whether the same or substantially similar network improvement could be achieved by moving the facility farther away from the residence. 3. The proposed location should not be treated as the only reasonable location AT&T's Alternative Site Analysis evaluates multiple alternative locations for PALO4_004, including locations on Channing Avenue. I am not asking the City to disregard legitimate RF or utility constraints. However, the analysis should not be limited to asking whether another nearby existing pole can accommodate AT&T's preferred configuration. The more appropriate question is: Where can AT&T provide the necessary service while imposing the least overall burden on surrounding residences? The proposed location is particularly sensitive because of its proximity and position relative to 804 Boyce. The City should therefore require AT&T to investigate locations farther east along Channing Avenue or Guinda Street, rather than focusing only on poles immediately surrounding 804 Boyce. 4. Farther-east locations along Channing or Guinda should be investigated AT&T's own analysis demonstrates that the proposed service area is considerably larger than the immediate area surrounding the 804 Boyce pole. Accordingly, the City should ask AT&T to investigate whether a facility farther east along Channing Avenue or Guinda Street could provide the required network coverage while reducing the impact on 804 Boyce. I am deliberately not asking the City to approve any particular alternative location. The issue is that AT&T should actually investigate and document a broader range of locations before concluding that the proposed pole is the least intrusive solution. 9/30/26, 5:57 PM Mail - Kandikuppa, Nishita - Outlook https://outlook.office.com/mail/inbox/id/AAQkADVmNWM1NDcyLWQ5YzYtNGI5OS05YmZkLTk0MjdlMmI5OWIwMQAQAGRbMIt9myNCqNhSGpQzO…4/9 Item 2 Attachment H - Public Comments     Packet Pg. 122     A farther-east location could potentially provide meaningful coverage to the area identified by AT&T while moving the burden away from the residence most directly affected by the current proposal. Even if such a location requires AT&T to modify the antenna height, configuration, or supporting structure, those factors should be weighed against the impact created by the current proposal. AT&T should explain, with site-specific RF analysis, why moving the facility farther east along Channing or Guinda would result in unacceptable service degradation. 5. AT&T's definition of "least intrusive" should include community impact AT&T states that its proposed location is the least intrusive means of addressing the coverage gap because it can use an existing utility pole and avoid a new pole or pole replacement. That may make the proposed location less intrusive from the standpoint of AT&T's construction and utility infrastructure. It does not necessarily make it the least intrusive location for the surrounding community. A location that allows AT&T to use an existing pole but places a nearly 53-foot antenna immediately in front of a residence may have a greater overall impact than a location farther away that requires a different structure. The City's evaluation should therefore consider the total community and residential impact, not merely whether AT&T can avoid installing or replacing a utility pole. 6. The City should require a broader, site-specific evaluation AT&T states that the proposed location is at or near the geometric center of the RF search area and that placing the facility near that point helps maintain line-of-sight propagation and uniform power distribution. However, the geometric center of a theoretical coverage area should not automatically determine the location of a permanent structure in a residential neighborhood. The City should require AT&T to demonstrate what actual service degradation would result from moving the facility farther east along Channing or Guinda. The City should also evaluate whether a somewhat different antenna height, configuration, or supporting structure could make such a location technically feasible. The fact that a particular location is optimal from an RF modeling perspective does not necessarily mean that it is the best location when network performance, residential impact, neighborhood character, and alternative sites are considered together. 7. The City has previously recognized the special visual importance of this location 9/30/26, 5:57 PM Mail - Kandikuppa, Nishita - Outlook https://outlook.office.com/mail/inbox/id/AAQkADVmNWM1NDcyLWQ5YzYtNGI5OS05YmZkLTk0MjdlMmI5OWIwMQAQAGRbMIt9myNCqNhSGpQzO…5/9 Item 2 Attachment H - Public Comments     Packet Pg. 123     The visual impact of the proposed facility is particularly important because the City has previously recognized the special visual significance of this location. During Agenda Item 12 of the February 2, 1998 Palo Alto City Council meeting, the Council was considering the property then addressed as 805 Channing Avenue, which is the same lot now addressed as 804 Boyce Avenue. The discussion concerned whether development of the property, including the design, architecture, and placement of the house, should be subject to design review and what restrictions should apply to what could be built on the site. The City-provided meeting minutes describe the Council's discussion of the location as recognizing the intersection as a crucial intersection and prominent location, and as visually important and a gateway to the neighborhood. These observations are significant because they were made in the context of determining what development and design should be permitted on this same property. The Council was considering how development of this lot would affect the visual character of the intersection and the neighborhood. The City should therefore not treat the existing utility pole near 804 Boyce as simply an ordinary pole on which telecommunications equipment can be added with minimal consequence. The location has previously been recognized by the City as a prominent and visually important gateway to the neighborhood. That history is particularly relevant to the current proposal. AT&T proposes to add a nearly 53-foot- high telecommunications installation to a pole positioned approximately in front of the middle of the residence. The resulting antenna will be visible from three second-story windows at 804 Boyce. If the City has previously recognized this location as a prominent, visually important gateway to the neighborhood, it is reasonable to require a particularly careful analysis of whether a large new telecommunications installation is appropriate at this location and whether a less visually prominent location farther east along Channing or Guinda could satisfy AT&T's legitimate service objectives. At a minimum, the City's prior recognition of the visual importance of this location warrants heightened scrutiny of the proposed facility's visual impact and a meaningful evaluation of alternatives before approval. 8. The proposed facility will create a substantial visual intrusion into 804 Boyce AT&T proposes to install a 2-foot canister antenna on a new pole-top extension, along with a shroud containing radios and other equipment. The plans show the antenna extending to approximately 52 feet 11 inches above ground level. This is not an abstract or distant visual impact. The existing utility pole is positioned approximately in front of the middle of the 804 Boyce residence, rather than toward the end of the property. That positioning makes the proposed facility particularly prominent. 9/30/26, 5:57 PM Mail - Kandikuppa, Nishita - Outlook https://outlook.office.com/mail/inbox/id/AAQkADVmNWM1NDcyLWQ5YzYtNGI5OS05YmZkLTk0MjdlMmI5OWIwMQAQAGRbMIt9myNCqNhSGpQzO…6/9 Item 2 Attachment H - Public Comments     Packet Pg. 124     The proposed antenna will be visible from three second-story windows at 804 Boyce. The visual impact will be even greater because the nearby tree is deciduous and loses its leaves each year. During the months when the tree has little or no foliage, the antenna and associated equipment will be substantially more exposed and prominent from the residence. This means the proposed equipment will become a persistent part of the residents' normal view from inside their home, with its visual prominence increasing significantly during the portion of the year when the deciduous tree provides less screening. 9. The contractor's statement that the antenna is too high to affect views is not supported by the actual residential sightlines At the public meeting, an AT&T contractor stated that the antenna was so high that it would not block views. That statement does not adequately address the actual sightlines from 804 Boyce. The perspective of a person standing on the street is materially different from that of a person inside a second-story bedroom. A person lying in bed and looking out the window can have a direct line of sight to an elevated object that would not obstruct the view of a person standing at ground level. The relevant question is therefore not whether the antenna blocks an entire view from street level. It is: What will residents of 804 Boyce actually see when looking out of their second-story windows? The antenna can be plainly visible without completely blocking the existing view. The resulting visual intrusion is still significant. The City should therefore require AT&T to demonstrate its assertion using accurate, site-specific visual simulations. 10. The "stealth" designation does not eliminate the visual impact AT&T describes the proposed installation as a "stealth" facility designed to minimize visual impact by placing the equipment in a rounded shroud and painting the antenna, pole extension, bracket and shroud to match the existing wood pole. Those measures may reduce the contrast of the equipment, but they do not eliminate the fundamental visual impact. The existing utility pole is already visually prominent because of its location directly in front of the residence. Adding an antenna and pole extension that reaches approximately 53 feet high changes the visual character of that pole substantially. 9/30/26, 5:57 PM Mail - Kandikuppa, Nishita - Outlook https://outlook.office.com/mail/inbox/id/AAQkADVmNWM1NDcyLWQ5YzYtNGI5OS05YmZkLTk0MjdlMmI5OWIwMQAQAGRbMIt9myNCqNhSGpQzO…7/9 Item 2 Attachment H - Public Comments     Packet Pg. 125     A structure does not become visually insignificant merely because it is painted to match the pole supporting it. The City should evaluate the actual visual experience from the neighboring residence rather than accepting AT&T's general description of the equipment as "stealth." 11. The location of the pole makes the visual impact particularly significant The position of the pole relative to the residence is an important part of the visual-impact analysis. If the pole were toward the end of the property frontage, the antenna could be toward the periphery of the residents' view. Instead, the pole is approximately in front of the middle of the residence. Consequently, the proposed antenna would be prominently positioned within the residents' normal field of view. This is particularly significant because the antenna will be visible from three second-story windows. The City should consider not only the height of the antenna but also its position relative to the residence and the actual windows from which it will be viewed. Requested Action For these reasons, I respectfully request that the City not approve CRAN_RSFR_PALO4_004 at the proposed 804 Boyce location. Specifically, I request that the City: 1. Require AT&T to provide additional site-specific evidence establishing the location, severity, and extent of the claimed service deficiency. 2. Consider the firsthand testimony of the two AT&T customers—one on Boyce Avenue and one on Guinda Street—who stated at the public meeting that they were not experiencing problems with their AT&T service, while recognizing that this testimony should be considered together with, rather than substituted for, technical RF analysis. 3. Require AT&T to address the limitations of its free-space coverage calculations, including the fact that they do not account for attenuation from trees, buildings, or other obstructions. 4. Require AT&T to investigate locations farther east along Channing Avenue and Guinda Street and provide site-specific RF analysis for those locations. 5. Require AT&T to demonstrate why moving the facility farther east would result in unacceptable service degradation, rather than simply stating that the proposed location is closest to the geometric center of the coverage area. 6. Require AT&T to investigate whether a different antenna height, configuration, or supporting structure could allow a less visually intrusive location to meet its legitimate network objectives. 7. Require accurate photo simulations from all three affected second-story windows at 804 Boyce, including realistic viewpoints of residents who are seated or lying in bed. 8. Require AT&T to address its contractor's statement at the public meeting that the antenna is too high to affect views and explain that statement in light of the actual sightlines from the second-story windows. 9/30/26, 5:57 PM Mail - Kandikuppa, Nishita - Outlook https://outlook.office.com/mail/inbox/id/AAQkADVmNWM1NDcyLWQ5YzYtNGI5OS05YmZkLTk0MjdlMmI5OWIwMQAQAGRbMIt9myNCqNhSGpQzO…8/9 Item 2 Attachment H - Public Comments     Packet Pg. 126     9. Recognize that the pole's location in front of the middle of the residence, rather than toward the end of the property frontage, materially increases the visual impact. 10. Consider the City's prior recognition of this location as a crucial intersection, prominent location, visually important location, and gateway to the neighborhood when evaluating the appropriateness of the proposed facility. 11. Evaluate the actual residential visual impact of the proposed facility and each feasible alternative when determining whether the proposed location is the least intrusive option. I support improving wireless service where it is genuinely needed. I am not asking the City to prevent AT&T from improving its network. I am asking the City to ensure that, if a new facility is necessary, it is located where it can provide the required service without unnecessarily imposing the greatest visual burden on the residence most directly affected by the proposal. In this case, AT&T proposes to place a nearly 53-foot antenna directly in front of the middle of 804 Boyce, where it will be visible from three second-story windows. The statement that the antenna is too high to affect views does not withstand examination from the actual perspective of residents inside the home. The City should require AT&T to look beyond the immediate vicinity of 804 Boyce and investigate whether a location farther east along Channing Avenue or Guinda Street can satisfy its legitimate network objectives while materially reducing the visual impact on 804 Boyce. Thank you for your consideration of these concerns. I respectfully request that this objection and the issues raised above be included in the record for CRAN_RSFR_PALO4_004. Sincerely, Tim Flagg 804 Boyce Avenue 9/30/26, 5:57 PM Mail - Kandikuppa, Nishita - Outlook https://outlook.office.com/mail/inbox/id/AAQkADVmNWM1NDcyLWQ5YzYtNGI5OS05YmZkLTk0MjdlMmI5OWIwMQAQAGRbMIt9myNCqNhSGpQzO…9/9 Item 2 Attachment H - Public Comments     Packet Pg. 127     Outlook RE: ATT Mobility Application From GRABISCH, MARC D <mg387k@att.com> Date Wed 8/19/2026 5:21 PM To Kandikuppa, Nishita <Nishita.Kandikuppa@paloalto.gov>; Tasha Stack <tasha.stack@nextedgenetworks.com> CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. Nishita, Thank you for informing us about this resident’s concerns and for sharing your well crafted and thoughtful response. Kind Regards, Marc Grabisch Program Manager NCAL Market, Small Cells at&t Mobility cell: (925) 549-9671 e-mail: mg387k@att.com "This e-mail and any files transmitted with it are the property of AT&T, are confidential, and are intended solely for the use of the individual or entity to whom this e-mail is addressed. If you are not one of the named recipient(s) or otherwise have reason to believe that you have received this message in error, please notify the sender and delete this message immediately from your computer. Any other use, retention, dissemination, forwarding, printing, or copying of this e-mail is strictly prohibited." From: Kandikuppa, Nishita <Nishita.Kandikuppa@paloalto.gov> Sent: Wednesday, August 19, 2026 3:26 PM To: Tasha Stack <tasha.stack@nextedgenetworks.com> Cc: GRABISCH, MARC D <mg387k@att.com> Subject: Fw: ATT Mobility Application Hi Tasha, Happy Wednesday! I'm passing along a neighbor concern regarding the recent wireless application submittal. I will respond to LuAnn and blind copy you, so you are in the loop. Best, Nishita Nishita Kandikuppa Associate Planner Planning Hi Tasha, Happy Wednesday! I'm passing along a neighbor concern regarding the recent wireless application submittal. I will respond to LuAnn and blind copy you, so you are in the loop. Best, Nishita 9/30/26, 5:53 PM RE: ATT Mobility Application - Kandikuppa, Nishita - Outlook about:blank?windowId=SecondaryReadingPane2 1/2 Item 2 Attachment H - Public Comments     Packet Pg. 128     Nishita Kandikuppa Associate Planner Planning and Development Services Department (650) 838-2806 | nishita.kandikuppa@paloalto.gov www.paloalto.gov From: luann schwab Sent: Wednesday, August 19, 2026 3:08 PM To: Kandikuppa, Nishita <Nishita.Kandikuppa@paloalto.gov> Subject: ATT Mobility Application CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. Nishita, I have two meningiomas (brain tumors) that were most likely caused by over exposure to radiation through constant cell phone use prior to the invention of hands free and ear buds. I live close to where the proposed wireless facilities are to be installed and am very opposed to the project. I am trying to understand the need to have 3 towers within a 2 block radius of each other. Why not spread them out for better coverage? Have you considered locating them downtown, away from residential areas which would limit 24/7 exposure? There are many families with small children in our neighborhood and I feel like there is potential danger here. Again, three towers within a two block radius seems like overkill (in more ways than one). I will try to attend the meeting. Please note my strong objection to the project. Regards, LuAnn Schwab 731 Hamilton Avenue 9/30/26, 5:53 PM RE: ATT Mobility Application - Kandikuppa, Nishita - Outlook about:blank?windowId=SecondaryReadingPane2 2/2 Item 2 Attachment H - Public Comments     Packet Pg. 129     Outlook Re: AT&T Mobility application for PALO4_005 From Kandikuppa, Nishita <Nishita.Kandikuppa@paloalto.gov> Date Thu 9/3/2026 5:37 PM To Tom Berson Cc NCA_ATT_CX@nextedgenetworks.com <NCA_ATT_CX@nextedgenetworks.com> Bcc Tasha Stack <tasha.stack@nextedgenetworks.com>; GRABISCH, MARC D <mg387k@att.com> Hi Tom, Thank you for your comments regarding the proposed PALO4_005 installation. The City will consider your concerns as part of its review of the proposed project. Noise The project must comply with applicable City of Palo Alto noise regulations. For stationary equipment on residential property, Palo Alto Municipal Code Section 9.10.030 generally limits noise to no more than 6 dBA above the local ambient noise level at a point outside the property boundary. This standard is intended to address ongoing operational noise, including an audible equipment hum. Construction activity is separately regulated under Palo Alto Municipal Code Section 9.10.060. Construction is generally limited to 8:00 a.m.–6:00 p.m. Monday through Friday and 9:00 a.m.–6:00 p.m. Saturday, with construction prohibited on Sundays and City holidays. During permitted hours, no individual item of construction equipment, or noise at any point outside the project property line, may exceed 110 dBA. The applicant will be advised that equipment should be properly installed, maintained, and operated to avoid unnecessary operational noise. If an ongoing noise issue is reported after installation, the City can evaluate the concern under the applicable Municipal Code provisions and coordinate with the responsible party as appropriate. Radio-frequency interference The City can request that the applicant use properly compliant equipment and respond promptly to substantiated interference concerns associated with the installation. Federal Communications Commission requirements also apply to electrical and electronic equipment. Under FCC rules, equipment operators may not cause harmful interference to authorized radio services and may be required to correct the condition or discontinue operation if harmful interference is found. If interference occurs, please document the date, time, equipment affected, and the nature of the interference, and submit that information to the City and the project contact so the issue can be evaluated promptly. The City may also direct the applicant to coordinate with the affected resident and, where appropriate, the relevant utility or FCC process. Potential electrical outage Any planned electrical outage necessary for installation would be coordinated through the City of Palo Alto Utilities. State law requires utilities, including locally publicly owned electric utilities, to provide customers with outage alerts and updates and to provide a means for customers to maintain or update their preferred contact information. The City will request that any planned outage associated with this work be limited to the smallest feasible area and shortest practicable duration, scheduled to minimize customer impacts, and communicated in 9/30/26, 5:57 PM Mail - Kandikuppa, Nishita - Outlook https://outlook.office.com/mail/inbox/id/AAQkADVmNWM1NDcyLWQ5YzYtNGI5OS05YmZkLTk0MjdlMmI5OWIwMQAQAAFK7feLWUd1gyFr5%2FlkN…1/2 Item 2 Attachment H - Public Comments     Packet Pg. 130     advance to affected customers when the timing and affected area are known. Customers should ensure that their current contact information is on file with City of Palo Alto Utilities so they can receive outage-related notifications. Thank you again for your comments. They will be included in the project record and considered during the City’s review. Best, Nishita Nishita Kandikuppa Associate Planner Planning and Development Services Department (650) 838-2806 | nishita.kandikuppa@paloalto.gov www.paloalto.gov From: Tom Berson Sent: Monday, August 24, 2026 12:40 PM To: Kandikuppa, Nishita <Nishita.Kandikuppa@paloalto.gov> Cc: NCA_ATT_CX@nextedgenetworks.com <NCA_ATT_CX@nextedgenetworks.com> Subject: AT&T Mobility application for PALO4_005   CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. My name is Thomas Berson. I own and occupy residences at 764 Forest Ave and at 776 Forest Ave, both within 150 feet of the proposed PALO4_005. Thank you for the opportunity to comment on the proposed project I have no objection to the visual impact. I do have concerns about acoustic noise the installation may produce. The similar installation PALO1_023 near 1061 Fife Ave. used to call attention to itself by emitting a constant 60Hz hum audible on the sidewalk and presumably to nearby homeowners. That seems fixed now. I would like the city's permit terms to assure that the applicant will promptly resolve any interference to resident's equipment, for instance radio receivers. Lastly, I imagine that our electrical power will have to be turned off during installation. I would like this outage to be notified in advance and to be as brief as possible. Thank you for your consideration. I look forward to your comments. --Thomas Berson 9/30/26, 5:57 PM Mail - Kandikuppa, Nishita - Outlook https://outlook.office.com/mail/inbox/id/AAQkADVmNWM1NDcyLWQ5YzYtNGI5OS05YmZkLTk0MjdlMmI5OWIwMQAQAAFK7feLWUd1gyFr5%2FlkN…2/2 Item 2 Attachment H - Public Comments     Packet Pg. 131     Outlook Re: AT&T Wireless Application - Public Comments From Bob Wedemeyer Date Wed 9/16/2026 1:54 PM To Kandikuppa, Nishita <Nishita.Kandikuppa@paloalto.gov> 2 attachments (434 KB) Notice re Proposed -004.JPEG; Possible 2.JPG; CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. i This message needs your attention This is a personal email address. Mark Safe Report Hi Nishita, I noticed a posting on the pole (see attached) we were hoping would NOT be used for the new AT&T transmitter. Has a decision already been rendered?  I'd assume there would be a hearing of some sort regarding visual impact on the neighborhood.  Was any consideration given to "Proposed 2" (see attached) location? Thanks again for following up. Bob On 9/3/2026 5:46 PM, Kandikuppa, Nishita wrote: Hi Bob, Thank you for attending AT&T’s August 25, 2026, community meeting and for submitting your comments, photographs, and suggested alternative locations. Your input will be included in the project record and considered during the City’s review. The applicant is responsible for providing information regarding its service objectives, network design, and the technical basis for the proposed locations. While the City does not determine a carrier’s network needs, it may review the applications for consistency with applicable land-use, design, and right-of-way requirements. Powered by Mimecast 9/30/26, 5:58 PM Mail - Kandikuppa, Nishita - Outlook https://outlook.office.com/mail/inbox/id/AAQkADVmNWM1NDcyLWQ5YzYtNGI5OS05YmZkLTk0MjdlMmI5OWIwMQAQAGDM3rDAztRCu7rKAs7HF%…1/4 Item 2 Attachment H - Public Comments     Packet Pg. 132     Wireless facilities must comply with Federal Communications Commission (FCC) RF exposure standards. Federal law limits the City’s authority to regulate facilities based on RF emissions when the applicant demonstrates FCC compliance. The City may request RF compliance documentation as part of its review; the applicant has provided an RF Emissions report as a part of their submittal. The City can consider visual impacts, equipment design, streetscape conditions, accessibility, safety, and feasible alternative locations. Staff will ask AT&T to review the alternatives identified in your comments, including the locations near Channing and Guinda and the Adventist Church on Guinda. Approval of one wireless facility does not automatically authorize future facilities by AT&T or other carriers. Each future proposal would require its own review under the applicable federal, state, and City requirements. Thank you again for your thoughtful comments. Hope you have a good long weekend! Best, Nishita Nishita Kandikuppa Associate Planner Planning and Development Services Department (650) 838-2806 | nishita.kandikuppa@paloalto.gov www.paloalto.gov From: Bob Wedemeyer Sent: Thursday, August 27, 2026 2:50 PM To: Kandikuppa, Nishita <Nishita.Kandikuppa@paloalto.gov> Subject: Re: AT&T Wireless Application - Public Comments   CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. Nishita Kandikuppa Associate Planner Planning and Development Hi - My wife and I attended a hearing on August 25, 2026 (6-8 pm) at 555 University Avenue, hosted by AT&T Wireless, regarding a proposal to install three cell towers in our neighborhood. PALO4-004 PALO4-005 PALO4-006 We have lived at our current address 827 Guinda Street (within the triangle formed by these proposed “wireless facilities”) for over 40 years. 9/30/26, 5:58 PM Mail - Kandikuppa, Nishita - Outlook https://outlook.office.com/mail/inbox/id/AAQkADVmNWM1NDcyLWQ5YzYtNGI5OS05YmZkLTk0MjdlMmI5OWIwMQAQAGDM3rDAztRCu7rKAs7HF%…2/4 Item 2 Attachment H - Public Comments     Packet Pg. 133     Here is my take on the meeting and proposal. 1.  There were just under a dozen or so of our neighbors who showed up.  Interestingly, no one had any issues with their current cell service, even those who currently have AT&T. 2.  AT&T claimed that many of their customers complained about reception in the proposed service area. (They said approximately 500 households were sent the letter).  None of those customers, not one, bothered to show up.  AT&T argued that this was (in their experience) typical(?) human nature. 3.  There were concerns expressed regarding RF transmission exposure.  Why three towers with in a couple of blocks of each other, even if “relatively low power”?  ATT had a detailed presentation that basically said the exposure risk was within FCC (or government guidelines) which of course it was impossible to parse the validity of or applicability by the average citizen, at that moment.  (We actually hope/assume the City is monitoring this for both current safety and future upgrades.) 4.  Visual impacts (Architectural Review Board) were also negative.  The quieter air cooled (vs fan) “brown boxes” are necessarily larger and more visible (although they should be quieter).  The pole chosen at Boyce and Channing is especially visible because of a wide sidewalk apron in front of it.  An alternate pole on northeast corner of Channing and Guinda was looked at but AT&T noted the pole was “leaning” too much (a different problem) and had access issues.  Another pole on Guinda in front of the Adventist Church was not considered but could be a less visible alternative.  Please have a look at? 5.  Something that wasn’t mentioned but I can understand being a factor is that once the City grants one carrier a license to place a cell tower in a neighborhood, it is hard to deny others, even if to ultimately provide customers with alternatives. Certainly, if a carrier doesn’t provide a competitive service, one should always have the option to choose another.  Needless to say, a number of our neighbors (including us) are former ATT users. 6.  I guess what this boils down to is where are we headed?  How many providers, how many RF transmitters? I’ve enclosed some pictures of the current proposed RF Transmitter location at Boyce and Channing along with two alternatives. "Possible 2" least visual impact? Thanks for giving us the opportunity to provide feedback -  Bob Wedemeyer On 8/27/2026 2:23 PM, Kandikuppa, Nishita wrote: Hi Bob, Please respond to this email with your comments regarding the proposed AT&T wireless application. Best, Nishita 9/30/26, 5:58 PM Mail - Kandikuppa, Nishita - Outlook https://outlook.office.com/mail/inbox/id/AAQkADVmNWM1NDcyLWQ5YzYtNGI5OS05YmZkLTk0MjdlMmI5OWIwMQAQAGDM3rDAztRCu7rKAs7HF%…3/4 Item 2 Attachment H - Public Comments     Packet Pg. 134     Nishita Kandikuppa Associate Planner Planning and Development Services Department (650) 838-2806 | nishita.kandikuppa@paloalto.gov www.paloalto.gov 9/30/26, 5:58 PM Mail - Kandikuppa, Nishita - Outlook https://outlook.office.com/mail/inbox/id/AAQkADVmNWM1NDcyLWQ5YzYtNGI5OS05YmZkLTk0MjdlMmI5OWIwMQAQAGDM3rDAztRCu7rKAs7HF%…4/4 Item 2 Attachment H - Public Comments     Packet Pg. 135     Outlook Re: Request for more information regarding AT&T application PALO4_004 From Tim Flagg Date Wed 9/30/2026 11:31 AM To Kandikuppa, Nishita <Nishita.Kandikuppa@paloalto.gov> CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. HI NIshita, I assume postcards will be sent out to all neighbors before the October 15 meeting notifying of the correct date of the Architecture Review Board meeting? Thanks, Tim On Wed, Sep 30, 2026 at 10:25 AM Tim Flagg wrote: Hi Nishita, Thanks again for the information. Can you tell me how I can find out the AT&T revision to their scope of work? Thanks, Tim On Wed, Sep 30, 2026 at 9:50 AM Kandikuppa, Nishita <Nishita.Kandikuppa@paloalto.gov> wrote: Hi Tim, Thank you for your email. The applicant made a last-minute revision to their scope of work, so the item got pushed to October 15. Apologies for not having kept you informed. A good reminder for me to email the rest of the public commenters too so please be on the lookout for that! Best, Nishita Nishita Kandikuppa Planner Planning and Development Services Department (650) 838-2806 | nishita.kandikuppa@paloalto.gov www.paloalto.gov 9/30/26, 5:58 PM Mail - Kandikuppa, Nishita - Outlook https://outlook.office.com/mail/inbox/id/AAQkADVmNWM1NDcyLWQ5YzYtNGI5OS05YmZkLTk0MjdlMmI5OWIwMQAQAK3c0yWa2%2F9Dl8MjETIJu9…1/6 Item 2 Attachment H - Public Comments     Packet Pg. 136     From: Tim Flagg < Sent: Wednesday, September 30, 2026 9:03 AM To: Kandikuppa, Nishita <Nishita.Kandikuppa@paloalto.gov> Subject: Re: Request for more information regarding AT&T application PALO4_004   CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. Hi Nishita, I received a postcard about the Architectural Review Board meeting tomorrow, October 1. However, this page says the meeting was cancelled: https://cityofpaloalto.primegov.com/Portal/Meeting?meetingTemplateId=20234 Can you confirm it is canceled and was a notification or postcard sent out that I missed and is the meeting October 15 instead? Than you, Tim On Sun, Aug 30, 2026 at 7:53 PM Tim Flagg wrote: Hi Ms. Nishita Kandikuppa, Thank you for all this information.  It was very helpful. Regards, Tim On Thu, Aug 20, 2026 at 11:37 AM Kandikuppa, Nishita <Nishita.Kandikuppa@paloalto.gov> wrote: Hi Tim, Thank you for taking the time to share your questions and comments regarding the proposed wireless facilities. Please note that your comments will be included in the project’s public record. The project proposes three (3) new wireless facilities on existing wood utility poles near 804 Boyce Avenue, 670 Guinda Street, and 754 Homer Avenue; the poles are not planned for replacement. The facilities are proposed by AT&T to improve wireless service coverage and signal quality in the area where AT&T is experiencing a significant service gap. Wireless facility locations are typically selected based on several practical and technical factors, including where service is needed, the surrounding terrain and buildings, availability of suitable structures or utility poles, and whether the facilities can meet Federal safety requirements which are taken very seriously and reviewed thoroughly by City staff. The City is reviewing applicable local land use, design, location, and permitting considerations under Palo Alto Municipal Code (PAMC) Section 18.42.110 Wireless Communication Facilities , including whether the project is consistent with the applicable zoning and development standards. As part of that review, staff will consider the materials submitted by the applicant, including site plans, visual simulations, coverage information, alternative-location analysis, and Radio Frequency (RF) compliance materials, which are all required per the application checklists for the proposed wireless projects. Federal law limits the City’s ability to deny or regulate a wireless facility based on RF emissions if the facility complies with Federal Communications Commission (FCC) standards. FCC identifies two separate tiers of exposure pertaining to wireless projects: 9/30/26, 5:58 PM Mail - Kandikuppa, Nishita - Outlook https://outlook.office.com/mail/inbox/id/AAQkADVmNWM1NDcyLWQ5YzYtNGI5OS05YmZkLTk0MjdlMmI5OWIwMQAQAK3c0yWa2%2F9Dl8MjETIJu9…2/6 Item 2 Attachment H - Public Comments     Packet Pg. 137     Occupational exposure limits apply to workers who may be near wireless antennas as part of their job. These limits apply where workers have been informed about the potential for RF exposure and can take steps to manage their exposure. For this project, the antennas would be located approximately 45+ feet above ground level. RF exposure near the antennas depends on the antenna height, orientation, and direction of the signal. General public exposure limits apply to residents, pedestrians, and others who may be near a facility but do not work around the equipment or control their exposure at the height of the antennas. The general public limits are more protective than the occupational limits. The proposed antennas are designed to direct signals outward toward the service area, rather than directly toward the ground. Based on the applicant’s RF compliance analysis, RF exposure at ground level—including areas typically accessible to the public—would remain below applicable FCC limits. Under the Telecommunications Act of 1996, Federal regulations preempt State and local regulation of RF emissions generated by wireless facilities. The City’s authority in this area is limited to ensuring that the proposed installation complies with comprehensive emissions standards established by the FCC. Federal regulations also require signage to be posted that is visible upon approach that informs personnel accessing this area of basic precautions to be followed when working around the antennas. These exposure limits are also shown graphically and explained in the text of the attached RFE Report, but I am including screenshots below for each of the sites identified in the project plans. To reiterate, the submitted RFE analysis would meet applicable FCC exposure limits. 804 Boyce Avenue 670 Guinda Street 9/30/26, 5:58 PM Mail - Kandikuppa, Nishita - Outlook https://outlook.office.com/mail/inbox/id/AAQkADVmNWM1NDcyLWQ5YzYtNGI5OS05YmZkLTk0MjdlMmI5OWIwMQAQAK3c0yWa2%2F9Dl8MjETIJu9…3/6 Item 2 Attachment H - Public Comments     Packet Pg. 138     754 Homer Avenue 9/30/26, 5:58 PM Mail - Kandikuppa, Nishita - Outlook https://outlook.office.com/mail/inbox/id/AAQkADVmNWM1NDcyLWQ5YzYtNGI5OS05YmZkLTk0MjdlMmI5OWIwMQAQAK3c0yWa2%2F9Dl8MjETIJu9…4/6 Item 2 Attachment H - Public Comments     Packet Pg. 139     The applicant has provided all the items you requested as a part of their application materials which can viewed on Permit View. The application number is 26PLN-00229. You will need an account to access the project materials so unfortunately, I am unable to send a link to the project-speci fic Permit View page. I hope this information is helpful. City staff is reviewing the project materials to determine whether the proposed equipment meets all applicable requirements. Because the proposed facilities would be located in the public right-of-way, the project will also require a public hearing before the Architectural Review Board (ARB). I will send a follow-up email once the hearing date has been scheduled. The ARB hearing will provide an additional opportunity for you to share your concerns, even if you are unable to attend the Community Meeting. Thank you again for taking the time to participate in the review process. Please reach out if you have any additional questions. Best, Nishita Nishita Kandikuppa Associate Planner Planning and Development Services Department (650) 838-2806 | nishita.kandikuppa@paloalto.gov www.paloalto.gov From: Tim Flagg Sent: Wednesday, August 19, 2026 5:44 PM To: Kandikuppa, Nishita <Nishita.Kandikuppa@paloalto.gov> Subject: Request for more information regarding AT&T application PALO4_004 CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. Dear Ms. Kandikuppa, I am the property owner at 804 Boyce Avenue where the proposed AT&T Mobility wireless facility identified as PALO4_004, is located. I received the August 6, 2026 notice regarding the proposed installation and plan to attend the community meeting on August 25. Before the meeting, I would appreciate receiving the complete public application file for PALO4_004 so that residents can meaningfully review the proposal. In particular, please provide, if included in the application: The City application/permit number and current application status The complete site plan and elevation drawings Existing and proposed pole heights and dimensions The antenna model, dimensions, mounting height, and extension/mast dimensions Dimensions and specifications for the proposed radio units and equipment enclosure 9/30/26, 5:58 PM Mail - Kandikuppa, Nishita - Outlook https://outlook.office.com/mail/inbox/id/AAQkADVmNWM1NDcyLWQ5YzYtNGI5OS05YmZkLTk0MjdlMmI5OWIwMQAQAK3c0yWa2%2F9Dl8MjETIJu9…5/6 Item 2 Attachment H - Public Comments     Packet Pg. 140     Structural calculations or structural analysis for the utility pole The RF engineering report and coverage/capacity analysis supporting the proposed location The RF search ring or other documentation identifying the required service area The alternative-site/pole analysis, including other utility poles or locations that were considered and the reasons they were rejected Any analysis of whether existing wireless facilities in the vicinity could be used or collocated with instead of installing a new facility at this location Any noise, pedestrian/sidewalk, ADA, utility-conflict, tree-impact, or other site-impact analyses Any RF compliance documentation submitted with the application All City staff comments, completeness reviews, applicant responses, and revised plans submitted to date I would also appreciate clarification regarding the wood utility pole. The notice describes the proposed facility as being installed on the existing wood utility pole. Please confirm whether AT&T proposes to retain the existing pole or replace it with a new pole, and identify the applicable Palo Alto standard governing that issue. Please also confirm the Tier classification of PALO4_004 and the anticipated Architectural Review Board review/decision process and timing. I am particularly interested in understanding why this specific pole on Boyce A venue was selected and whether less visually intrusive alternatives were evaluated. Since the proposed facility is located in the middle of the 804 Boyce property frontage and immediately adjacent to a residential neighborhood, I would like to review the engineering and site-selection information before the community meeting rather than relying solely on the photo simulation provided with the notice. Thank you for your assistance. If these documents are available through Palo Alto's Permit View system rather than by email, please provide the application/record number or direct link that will allow me to access the complete file. Thank you very much. Regards, Tim Flagg 804 Boyce Avenue 9/30/26, 5:58 PM Mail - Kandikuppa, Nishita - Outlook https://outlook.office.com/mail/inbox/id/AAQkADVmNWM1NDcyLWQ5YzYtNGI5OS05YmZkLTk0MjdlMmI5OWIwMQAQAK3c0yWa2%2F9Dl8MjETIJu9…6/6 Item 2 Attachment H - Public Comments     Packet Pg. 141     Item 2 Attachment H - Public Comments     Packet Pg. 142     Item 2 Attachment H - Public Comments     Packet Pg. 143     Item 2 Attachment H - Public Comments     Packet Pg. 144     Item 2 Attachment H - Public Comments     Packet Pg. 145     Item 2 Attachment H - Public Comments     Packet Pg. 146     Item 2 Attachment H - Public Comments     Packet Pg. 147     I am writing to urge you to insist that AT&T respect the provisions of our Municipal Code and your own aesthetic judgement, as well as the wishes of our unanimous City Council. In particular, please require AT&T to site its cell towers further from residents’ homes, to locate radios and ancillary equipment underground and to lower the height of the poles. Thank you for your consideration. Sincerely, Bruce W. Phillips Item 2 Attachment H - Public Comments     Packet Pg. 148     Item 2 Attachment H - Public Comments     Packet Pg. 149     Item 2 Attachment H - Public Comments     Packet Pg. 150     1324 Dana Ave hey, we are all just people Item 2 Attachment H - Public Comments     Packet Pg. 151     If you need assistance reviewing the above documents, please contact the Project Planner or call the Planner-on-Duty at 650-617-3117 or email planner@cityofpaloalto.org Project Plans In order to reduce paper consumption, a limited number of hard copy project plans are provided to Board members for their review. The same plans are available to the public, at all hours of the day, via the following online resources. 1. Go to: bit.ly/PApendingprojects 2. Scroll down to find “250 Hamilton Avenue” and click the address link 3. On this project-specific webpage you will find a link to the project plans and other important information https://www.paloalto.gov/Departments/Planning-Development-Services/Current-Planning/Projects/26PLN- 00229-Tier-2-Wireless-Communications-Facility-WCF-in-Public-Right-of-Way A digital color and materials board is included in the project plans. Item 2 Attachment I - Project Plans     Packet Pg. 152     Item No. 3. Page 1 of 1 Architectural Review Board Staff Report From: Planning and Development Services Director Lead Department: Planning and Development Services Meeting Date: October 15, 2026 Report #: 2610-6851 TITLE Draft Architectural Review Board Meeting Minutes for August 20, 2026 RECOMMENDATION Staff Recommends the Architectural Review Board (ARB) adopt the meeting minutes. ATTACHMENTS Attachment A: Minutes of August 20, 2026 AUTHOR/TITLE: ARB Liaison1 & Contact Information   Steven Switzer, Senior Historic Planner   (650) 329-2321   Steven.Switzer@PaloAlto.gov 1 Emails can be sent directly to the ARB at the following email: ARB@PaloAlto.gov Item 3 Item 3 Staff Report     Packet Pg. 153     Page 1 of 35 Architectural Review Board Meeting Draft Summary Minutes: 8/20/2026 ARCHITECTURAL REVIEW BOARD MEETING DRAFT MINUTES: August 20, 2026 Council Chamber & Zoom 8:30 a.m. CALL TO ORDER/ROLL CALL Present: Chair Mousam Adcock, Vice Chair Kendra Rosenberg, Board Member Yingxi Chen, Board Member David Hirsch, and Board Member Marton Jojarth Absent: None Chair Adcock called the meeting to order. Administrative Associate Samuel Tavera called the roll and declared a quorum. AGENDA CHANGES, ADDITIONS, AND DELETIONS None. IN-PERSON PUBLIC COMMENT None. CITY OFFICIAL REPORTS 1. Director's Report, Meeting Schedule, and Upcoming Agenda Items Senior Planner Steven Switzer reported that since the last Architectural Review Board (ARB) meeting, there has been 1 submittal: 690 San Antonio for 66 for-sale townhomes. Mr. Switzer announced that the Boards and Commissions Recognition event will be held on September 26 at the Lucie Stern Community Center at 5:30 p.m. In October, Mr. Switzer anticipates the Council will review and approve the boards' and commissions' work plans. Chair Adcock said Board Member Chen had arrived. Mr. Switzer mentioned that the ARB will have 1 item on September 3: the Victoria’s Secret improvements at Stanford Shopping Mall. Mr. Switzer presented the schedule for the remaining 8 meetings planned for 2026. Mr. Switzer requested that staff be notified of any planned absences. Claire Raybould, Manager of Current Planning, said an ad hoc committee will be formed after the next hearing on the market-rate development under the Sobrato Development Agreement for the 74 market- Item 3 Attachment A - Minutes of August 20, 2026     Packet Pg. 154     Page 2 of 35 Architectural Review Board Meeting Draft Summary Minutes: 8/20/2026 rate townhomes at 340 Portage. Therefore, the ARB needed to assign members to this ad hoc committee. Two minor items will be brought back to the ARB. Vice Chair Rosenberg asked whether the applicant or staff would provide documentation for the ARB to review before the ad hoc meeting. Ms. Raybould confirmed they would include brief information in the packet. Vice Chair Rosenberg and Board Member Chen volunteered to join the ad hoc committee. STUDY SESSION 2. 1185 Skyline Boulevard [26PLN-00157]: Request for Preliminary Architectural Review of a New Skyline Field Office That Includes Approximately 36,480 Square Feet of Buildings and Structures and Associated Facilities for the Midpeninsula Regional Open Space District. Zoning District: OS (Open Space). CEQA Status: Preliminary Review Only, Not A Project. Staff recommended that the ARB review the preliminary project plans and provide comments. No formal action is required. Senior Planner Joey Dinh indicated that staff is seeking high-level design feedback primarily on site layout, visual compatibility with the Open Space District, recommendations for nighttime lighting, and any potential issues that may affect the design or overall layout. This is an early design check-in before submitting a formal site and design application to the City. The site is located along Skyline Boulevard near Page Mill Road, in a rural hillside and open-space setting. The project involves several parcels in both Palo Alto and San Mateo County. Some access and parking improvements extend into San Mateo County, requiring additional coordination; however, staff and Midpen have already begun this process. The project is a field operations and maintenance facility for Midpen's ranger and maintenance staff. It includes approximately 36,500 square feet of buildings and structures, with around 13,400 square feet allocated for the administration building. Long-term staffing is expected to be around 75 to 80 employees. Current plans show about 60 employee parking spaces, 9 visitor spaces, and 51 fleet spaces. The facility will feature a warehouse, fuel and wash stations, a shop for fleet vehicles, covered storage, and parking. Operations typically run from 6:30 a.m. to 11 p.m. The current field office supports about 50 staff members. The principal buildings are clustered together in the site plan, and the overall footprint extends into the employee and fleet parking areas, as well as the access roads. One of the board's main design questions is whether the overall campus remains visually subordinate to the surrounding open-space setting. City of Palo Alto Utilities will not provide wastewater, gas, or water services to the property. Water and wastewater systems will be on-site. Stormwater requirements may influence the final site design. The administration building will be about 13,400 square feet, 2 stories, and about 27 feet tall. The preliminary overall architecture is simple, with a rural gable roof. During the formal review process, the City will require full elevations that include details on materials, colors, screening, and lighting. Today, staff is seeking feedback on whether the proposed massing, roof form, and overall architecture fit in with the hillside open-space setting. The administration building will include locker and break rooms, a board meeting room, and hoteling space for staff to plug in and complete quick reporting tasks. Staff identified several preliminary issues that may affect the project's design. Currently, the interior side setback is shown at 10 feet 5 inches, while a 30-foot setback is required. The proposed administration building is 27 feet tall, exceeding the 25-foot height limit in the Open Space District. The impervious coverage for the main parcel, where most of the development will take place, is currently 10.25 percent before applying our zoning code's weighting methodology, which exceeds the 3.5 percent standard. The Item 3 Attachment A - Minutes of August 20, 2026     Packet Pg. 155     Page 3 of 35 Architectural Review Board Meeting Draft Summary Minutes: 8/20/2026 parking supply may comply with regulations, as the final parking counts will be determined based on Midpen's staff estimates in their final submission. Midpen needs to return to the City to request a Major Site and Design Review. The Planning and Transportation Commission will provide a recommendation, followed by the ARB's recommendation, and the City Council will make the final decision. Midpen is the CEQA lead agency but Palo Alto, San Mateo County, and Caltrans are expected to serve as responsible agencies. Mr. Dinh requested the ARB's comments and feedback on the design, interior setbacks, overall campus layout, landscaping, screening elements, and integration of parking, service, and utility areas, as well as any other issues. Erica Strohmeier, a Planner with the Midpeninsula Regional Open Space District, is the Project Manager for the rebuild of Midpen's Skyline Field Office at 1185 Skyline Boulevard within the Monte Bello Open Space Preserve. Senior Planner Tina Hugg attended the meeting in person, while Project Architect Laura Levenberg from Siegel & Strain Architects joined virtually. Ms. Strohmeier delivered a slide presentation. Midpen is a public agency established in 1972 to preserve, protect, and restore open space and provide opportunities for ecologically sensitive recreation and education. Midpen has protected over 70,000 acres of open space in San Mateo, Santa Clara, and Santa Cruz Counties. Its 26 preserves are open to the public free of charge, 7 days a week. Its jurisdiction encompasses 17 cities, from San Carlos to Los Gatos and from the Pacific Coast to the San Francisco Bay. The pink star on the displayed map represents the proposed new Skyline Field Office; the existing field office is to the left of the pink star, and the preserves are highlighted in green. The new facility and corp yard will support Midpen's restoration, preservation, and wildfire resiliency efforts throughout the Skyline region of the Santa Cruz Mountains. Since the existing field office was established over 30 years ago, Midpen's open-space acreage has more than doubled. The existing field office supports about 50 full-time and seasonal employees, including seasonal open space technicians focused on fuel reduction, rangers, and equipment maintenance operators. The current site cannot accommodate further growth. Midpen conducted a multi-site assessment and feasibility study between 2024 and 2025. Midpen's Board of Directors selected the property at 1185 Skyline Boulevard as the most suitable site for the new Skyline Field Office. Laura Levenberg, Senior Associate at Siegel & Strain Architects, discussed the project's design approach. The field office entrance is on the left side of the plan displayed on the screen, arriving at a 69-space parking area for employees and visitors adjacent to the 2-story administration building. The north-south building is a warehouse for equipment storage, with space for vehicle fueling and washing on one side, and it is located next to the primary fleet parking area. The east-west shop building in the center of the plan is for equipment maintenance and constructing fences and gates. Above that is a turning space for large vehicles, surrounded by bulk material storage and covered equipment storage structures. The buildings and large flat area sit on the flattest part of the site, stepping the development into the natural topography and reducing the need for extensive grading. Skyline Boulevard appears in the top right corner of the 3D view. The dense wooded area is at the bottom of the image. The development was carefully positioned to minimize visibility from Skyline and to reduce disruption to the existing wooded area. The resulting site layout features an L-shaped development that roughly follows the existing grade and vegetation edge. The building design process is in its early stages but the intent is to create a clustered development of simple gable-roof structures. Gable roofs allow good solar access for PV arrays and meet cool-roof requirements without bright or reflective coatings, allowing a subdued color palette that complements Item 3 Attachment A - Minutes of August 20, 2026     Packet Pg. 156     Page 4 of 35 Architectural Review Board Meeting Draft Summary Minutes: 8/20/2026 the natural surroundings. The 2-story administration building's upper floor plan includes a multipurpose room, break room, offices, and hoteling spaces; the lower portion includes locker rooms, a mudroom, laundry room, and a small, flexible meeting space for staff. Stacking these spaces helps minimize the building's footprint. Ms. Strohmeier presented a graphic showing the project footprint within the APN parcel outlined in yellow within the 3,500-acre Monte Bello Preserve. The surrounding green areas represent Midpen's Skyline Ridge, Russian Ridge, Coal Creek, and Los Trancos Preserves. Midpen owns most of the open space lands in this area. Most of the project is proposed within the parcel outlined in yellow. This property is rural, and its parcel boundaries blend indistinguishably with the surrounding larger open space preserves. Given Midpen's ownership of all the parcels and the desire to minimize site impacts, the proposed project considers the entire site, not the parcel lines, to consolidate proposed improvements within the flattest area. All the preserves and parcels in this area, including the one outlined in yellow, are dedicated open space land and cannot be conveyed without a majority district- wide vote in a special election, as outlined in California Public Resources Code Section 5540(c). Ms. Strohmeier stated that the proposed improvements in this application are in 2 legal parcels outlined in orange on the displayed parcel map. These 2 legal parcels encompass 3 APNs; however, APNs do not represent legal property boundaries because their primary purpose is to assess property values. The project site spans 2 legal parcels in Palo Alto and San Mateo County, designated as Parcel A and Parcel B on the parcel map, with the county line marked in red. Although the staff report discussed a lot merger or lot line adjustment, Ms. Strohmeier said pursuing either option would require separate applications and approvals from both the City of Palo Alto and San Mateo County. Additionally, either option would be costly and challenging because it would require significant coordination between the 2 jurisdictions. Ms. Strohmeier emphasized that the parcel lines are arbitrary and do not account for the site’s topography or constraints. The boundary separating Parcels A and B runs through the proposed corp yard area. Midpen is proposing a setback of 10 feet and 5 inches from this boundary. The Open Space Zoning setback requirement is 30 feet. Midpen is its own neighbor for thousands of linear feet from either parcel boundary, so placing buildings closer than 30 feet from either parcel boundary would not impose any undue hardship. Midpen considered the entire 3,500-acre preserve as the property for this project and believes that the setbacks and other zoning requirements do not apply. The green region shown on the Existing Topography slide has a slope of generally less than 10 percent. The plan is to position the 2-story administration building on an area with some slope and to step it in along the existing grade. Midpen proposed a building height of 27 feet to minimize the footprint. The side of the building viewed from Skyline Boulevard will be less than 25 feet tall. The portions of the building exceeding 25 feet will be visible only from other Midpen properties, such as Old Ranch Trail, which is approximately half a mile away across Stevens Creek valley. The proposed view from Skyline Boulevard was presented and showed that the building is visually unobtrusive from the public right-of- way. PUBLIC COMMENTS: None. Board Member Hirsch asked why the fence line extended beyond the parking area on the right side of A5.00 and whether it would be used for anything other than landscaping, as it seemed to allow space for a future building. Item 3 Attachment A - Minutes of August 20, 2026     Packet Pg. 157     Page 5 of 35 Architectural Review Board Meeting Draft Summary Minutes: 8/20/2026 Ms. Strohmeier replied that the proposed fence separating the Skyline Christmas tree farm is preliminary and can be relocated. The fence is to protect their corporate yard, which contains heavy equipment and materials. The Christmas tree farm is open to the public from Thanksgiving to New Year’s. A gravel parking area is adjacent to the fence. Midpen’s board requires that they maintain a rural character. Midpen will collaborate with its landscape architect, MIG, to develop a landscape plan that includes native vegetation and seeding in that area. Vice Chair Rosenberg inquired who owns the Christmas tree lot. Ms. Strohmeier stated that Midpen owns 3,500 acres surrounding this site. Although Midpen owns the Christmas tree lot, it currently leases it to an operator. Midpen’s General Manager’s office is working with the tree farm operator to consider a potential amendment related to the proposed project, with the intention of ensuring that the Christmas tree farm will remain. Board Member Hirsch asked whether Midpen was considering landscaping the water tank and other perimeter areas, and whether staff had discussed security measures for the facility. Ms. Strohmeier said their landscaping consideration must keep WUI requirements in mind. They will ensure that any proposed trees planted in their preserves are either acorns or young seedlings to avoid introducing pathogens, such as those that cause Sudden Oak Death. Additionally, they will position acorns and seedlings well away from the water tank to provide screening while also ensuring safety in the event of a wildland fire. Mr. Dinh has not yet discussed security issues. Most of the staff's preliminary conversations with Midpen have focused on understanding the project's broad direction and vision. Details regarding security, lighting, and other aspects will emerge when the formal application is submitted. Board Member Jojarth asked whether the City has any guidelines or past experience addressing situations where neighbors are remote. Board Member Jojarth noted that once these buildings are constructed, the tree farm lease or public use may change. Claire Raybould, Manager of Current Planning, explained that the finding for reasoning would not be based on current circumstances but on whether sound reasoning supports the design as an improvement. Key considerations include whether the design reduces grading, minimizes the number of trees that must be removed, and decreases visibility from Skyline Boulevard. It is difficult to sell those parcels because parking is being placed on part of another parcel. Chair Adcock pointed out that if this proposal were located on any other property in Palo Alto, it would need to undergo a lot merger if the intent was not to comply with setbacks. Chair Adcock acknowledged that merging the lots is difficult because it straddles 2 jurisdictions. Chair Adcock asked whether there is a valid legal justification for allowing this for Midpen while potentially denying it to others in Palo Alto. Ms. Raybould said the staff will consider how this site differs from other sites in the OS District, why it should be treated differently, and how these factors affect the findings. This is a unique situation, as it spans 2 jurisdictions. Vice Chair Rosenberg referred to the slide showing the boundary in red, which San Mateo County verified. Mr. Dinh confirmed that the Santa Clara County boundary in orange has not been verified. Vice Chair Rosenberg asked where the Christmas tree lot was on the slide. Vice Chair Rosenberg pointed out Item 3 Attachment A - Minutes of August 20, 2026     Packet Pg. 158     Page 6 of 35 Architectural Review Board Meeting Draft Summary Minutes: 8/20/2026 that a lot line adjustment would eliminate the setback issue; however, it would still straddle the San Mateo County line. Vice Chair Rosenberg asked how the City has handled situations where a Palo Alto property overlaps Santa Clara and San Mateo Counties. Vice Chair Rosenberg asked whether a lot line adjustment could keep Santa Clara County and Palo Alto separate, and whether there were any potential complications of having part of these parcels in San Mateo County. Someone owning 2 adjoining properties would never be allowed to cross their boundary without a lot line adjustment. Vice Chair Rosenberg emphasized that it does not matter that they are in a remote location and own both properties and questioned why Midpeninsula should receive an exception when residents have to follow these rules. Vice Chair Rosenberg asked whether all the proposed buildings would be processed through Palo Alto only. Vice Chair Rosenberg asked who was supplying water for the project. Vice Chair Rosenberg asked whether the City could approve the permit to allow construction to begin while a lot line adjustment is in process. Mr. Dinh said the City will not provide water or sewer service. The applicant plans to construct a well on the site. Ms. Strohmeier emphasized that APNs are not legal parcels. Ms. Strohmeier pointed out the ranch road depicted on the plan that leads to the driveway entrance on Skyline Boulevard. The Christmas Tree farm operates in 2 preserves: Monte Bello and, further up the road, across the street in the Skyline Ridge Preserve. Ms. Raybould was uncertain whether she had previously encountered a project with a similar scenario of straddling the county line. The part of the project in Palo Alto's jurisdiction must adhere to the City's regulations. Conversely, the part in San Mateo County's jurisdiction would be subject to their regulations and any applicable permits. Ms. Raybould confirmed that because all proposed buildings are located in Santa Clara County, they will be processed only through Palo Alto. Ms. Raybould stated that a lot line adjustment typically is a condition of approval before issuing a building permit to ensure compliance. Either a variance or a lot line adjustment is necessary for the project as currently proposed. Before granting the building permit, staff needs to know the proposed location of the lot lines and whether it is feasible, in coordination with San Mateo County and Palo Alto, to avoid issuing an unfeasible condition of approval. Vice Chair Rosenberg suggested that staff could grant a variance in the meantime, or make the lot line adjustment a condition of final building approval rather than before issuing the permit. Ms. Raybould was unfamiliar with San Mateo County's process and cautioned that complications may arise. A lot line adjustment is normally a straightforward ministerial process that takes about a month to complete through Palo Alto's Public Works Engineering, if another jurisdiction were not involved. Chair Adcock referred to Sheet C0.01 and suggested a lot line adjustment to incorporate more of the second lot and avoid going into the San Mateo side. Ms. Raybould recalled that Mr. Dinh had mentioned this option to the applicant and encouraged them to explore it further. The applicant mentioned multiple times that the APN boundaries are arbitrary; however, Chair Adcock stated that this has not been her experience, so she sought clarification on the City's perspective. Ms. Raybould was uncertain about what the applicant meant by that comment. APNs are related to tax Item 3 Attachment A - Minutes of August 20, 2026     Packet Pg. 159     Page 7 of 35 Architectural Review Board Meeting Draft Summary Minutes: 8/20/2026 components but they generally reflect the legal boundaries of parcels. Mr. Dinh indicated that staff would refer to the recorded legal parcels. Chair Adcock asked whether the building height of 27 feet instead of 25 feet would require a variance and what the approval process would be. Ms. Raybould said they would need to either demonstrate the findings of a design enhancement exception or make the necessary findings for a variance to exceed the building height. Ms. Raybould did not know what design improvement could be achieved by increasing the height. The height from the bottom to the peak is greater than that shown on the diagram of Administration Building 1 on A4.00. From Skyline, Vice Chair Rosenberg thought that the building appeared about 18 feet tall. Because the building is situated on a downhill slope, Vice Chair Rosenberg asked for clarification on how the building height is calculated. Ms. Raybould responded that the building would be measured from the lowest point of the existing or proposed grade. For a sloped roof, Ms. Raybould believed the measurement would be taken from the midpoint of the slope, rather than from the peak; however, staff would verify this, as it can vary depending on the zoning. Board Member Jojarth pointed out that a slide was displayed, which was not included in the board’s deck, showing the existing grade beneath the building. Senior Planner Steven Switzer clarified the zoning code's definition of height. For all districts, except for RE or R-1 residential districts, height refers to the vertical distance measured from grade to the highest point of the coping on a flat roof, the deck line of a mansard roof, or the average height of the highest gable of a pitched or hip roof. For this project, the relevant measurement would be the average height of the highest gable of the pitched roof. Board Member Jojarth pointed out that the displayed sheet is missing the orange line shown on the other slide. Board Member Chen asked whether Building 5's height measurement starts at the existing or proposed grade, and whether sloped areas are measured differently. For instance, should slopes greater than 10 or 20 percent still start at the lowest point or an average? Ms. Raybould replied that the building height should be measured from the existing grade or the proposed grade, whichever is lower. In this case, the proposed grade appears to be lower. In the OS District, the measurement also depends on the grade. The highest point measured would change as the grade increases. The building height may not have been measured accurately. Vice Chair Rosenberg noted that the applicant is measuring from the existing grade but their proposed grade is lower. Therefore, they should measure from the proposed grade instead. Chair Adcock stated that, based on her experience, it is the adjacent grade. Ms. Raybould confirmed it should be the adjacent grade. The proposed grade is lower but it would depend on the exterior view. The current illustration shows only an interior view. If the building's exterior grade increased, you would measure at the building's midpoint. Item 3 Attachment A - Minutes of August 20, 2026     Packet Pg. 160     Page 8 of 35 Architectural Review Board Meeting Draft Summary Minutes: 8/20/2026 Vice Chair Rosenberg stated that when measuring height, you should use the worst-case scenario. If one side of a building is higher than the other, you should not measure from the middle. Looking at the building's façade, Vice Chair Rosenberg noted that the existing grade follows the orange line; however, it is higher at the farthest corner than at the closest corner, resulting in a significantly different measurement. Ms. Raybould clarified that when there is a 10-foot slope in the OS District, you do not always use the worst-case scenario. If the grade is going up, the building height could increase. Chair Adcock referred to Sheet A5.00 and noted that the slope rises to a single-story height at the east end of the building. This led Chair Adcock to ask whether the applicant gets any leeway because the adjacent grade is higher on the northwest elevation. Mr. Dinh stated that the diagram on the screen came from the Single-Family Technical Manual. The diagram on the right illustrates how the City measures height when grades vary. Ms. Raybould stated that staff will address the height measurement when the project's formal plans are submitted. Chair Adcock asked what findings are required for a variance to exceed the building height and what the typical process is for obtaining a variance. Ms. Raybould replied that staff would need to understand the reasons for exceeding the building height, along with any other relevant information from the applicant. Generally, the variance process involves a staff-level review. For projects undergoing a site and design review, staff would note the variance request for any commission, board, or the Council to provide their comments during the review. If the applicant pursues a design enhancement exception for any code deviations, it will be subject to the ARB's review and the Council's decision. Board Member Chen noted that the applicant mentioned constraints on selecting roof materials and colors due to a different roof slope, and she wanted to confirm whether that was accurate and what the proposed roof slope is. Board Member Chen asked who will use the lockers in the administration building, where they will go after changing clothes, and whether workers in the shop building, warehouse, or equipment area also need to change clothes and use the locker room or if they have their own designated spaces. Board Member Chen asked whether the shop building was intentionally oriented to have a turnaround and separate the equipment yard from the fleet vehicle yard. Ms. Levenberg explained that if they selected a flat roof to lower the building height, they would need materials such as a bright white TPO to meet cool roof requirements. Under the Open Space District zoning code criteria, the applicant must choose materials in more subdued colors, not bright, reflective ones. The proposed roof slope is 3/12; Ms. Levenberg would need to verify that 2/12 is the trigger point for a cool roof. Midpen's field staff is out all day cutting down trees, removing brush, and building trails. As they work, they get dirty and covered in various spores from grasses and other things. When they return to the field office, they will enter the administrative building downstairs, remove their boots and any outer gear that needs washing, and shower in the locker rooms. Afterward, they go upstairs to record their time on timesheets, write reports, or add notes on their tracking projects. They either take their fleet vehicle home or carpool with others. Auto mechanics may need to wash off chemicals from their bodies. Those in the welding shop and wood shop will also use the locker room and shower, track Item 3 Attachment A - Minutes of August 20, 2026     Packet Pg. 161     Page 9 of 35 Architectural Review Board Meeting Draft Summary Minutes: 8/20/2026 their time, and then head home. The vehicles being serviced include tractors, bulldozers, and similar machinery. Large pull-through shop bays in the equipment and fleet vehicle yard are necessary because reversing such equipment is challenging. You drive the vehicle straight in for service, then drive straight out into a spacious yard where you can turn around and head back to the designated parking area for that equipment. Vice Chair Rosenberg assumed the applicant would keep reflectivity levels low in their color selection and asked whether the applicant had a color scheme in mind. Operating hours from 6:30 a.m. to 11:00 p.m. made lighting levels an important topic. The ARB had previously discussed lighting in relation to bird migration patterns and similar issues. Vice Chair Rosenberg asked about the applicant's tentative lighting plan. Ms. Strohmeier stated that the applicant is currently exploring color options; however, they cannot propose options that Midpen's Board of Directors has not reviewed and approved. Siegel & Strain will prepare the color options, and Ms. Strohmeier hopes to begin their board review process this fall. Midpen's preserves are open from dawn to dusk. Rangers open and close the preserves' gates. The visitor services team includes rangers, land stewardship, and trail management, which generally operates between 7 a.m. and 4 p.m. Ms. Levenberg will likely choose warm gray-brown tones that complement the landscape’s palette of greens in winter and browns in summer. Ms. Levenberg has not proposed specific color temperatures but she wants to balance the safety requirements of this rural site, where wildlife and glare on Skyline Boulevard are also considerations. The building code mandates certain levels of egress lighting. Siegel & Strain has a lighting agreement with Portola Valley. Ms. Levenberg wondered if a similar approach could be applied to this site, one that avoids over-lighting while ensuring safety, even if it might deviate from the code. To comply with the building code, Chair Adcock stated that egress lighting must wrap around the building and extend to the parking lot. Chair Adcock asked whether the applicant had considered a second stairway for egress through the building to reduce lighting on the forest side. This may require an agreement between Midpen and the City regarding parking lot lighting. With the parking lot in front of the building, if the lights remain bright at 8 p.m. during winter, it could result in excessive illumination on Skyline. Chair Adcock suggested considering the height of light poles, light levels, and the potential use of motion sensors to minimize lighting. Chair Adcock asked whether the applicant had considered parking lot lighting. Ms. Levenberg had not considered the routing of the egress paths in relation to exterior lighting. The focus was on illuminating the egress area and ensuring safety. Ms. Levenberg found Chair Adcock's lighting suggestions helpful. Ms. Strohmeier assumed Midpen's Board would want to keep lighting levels as low as possible, meet safety and security requirements, and avoid excessively bright lights that could negatively impact local wildlife. Vice Chair Rosenberg anticipated no significant noise at 10 p.m., which Ms. Strohmeier confirmed. Vice Chair Rosenberg inquired whether the applicant planned to add screening along Skyline and whether they would maintain the 100-foot setback from the building for fire safety. Vice Chair Rosenberg asked Item 3 Attachment A - Minutes of August 20, 2026     Packet Pg. 162     Page 10 of 35 Architectural Review Board Meeting Draft Summary Minutes: 8/20/2026 whether the applicant had considered installing solar panels, whether there would be any screening or shading for the parking lots, and whether those elements could be combined. Ms. Strohmeier said the proposal includes a 50-foot setback for landscape screening. One of the primary reasons for proposing this new facility is to fully implement Midpen's wildland fire resiliency program, which it considers in every design decision. Midpen cultivates acorns in pots for a maximum of 18 months before planting them. Midpen will maximize its planting efforts, likely focusing on valley oak species to help restore oak trees in the valley, along with native grasses. All plantings will consist of native species. Ms. Levenberg stated that the plan includes PV panels on the roofs. The roof has sufficient area to meet all of Midpen's PV needs. To avoid the additional cost of constructing structures over the parking area, the applicant has opted not to propose that solution. There will be no shading over the parking areas; however, they plan to apply a cool seal coating to the asphalt to help minimize the heat island effect. Chair Adcock asked whether the asphalt coating meets code requirements for parking lot shading and noted that there is a WUI distance for buildings versus the parking lot next to it. Ms. Levenberg inquired whether Chair Adcock's question pertained to parking lot shading as outlined in the CALGreen requirement. Ms. Raybould pointed out that the City has additional requirements for parking lot shading, so staff needs to explore this further, especially given Midpen's policy of planting acorns rather than trees. The second floor of the administration building consists mainly of office space. Board Member Jojarth wanted to understand the rationale behind the applicant's proposal for such a tall office building. The second floor measures approximately 16 feet, including the roof structure, which seemed excessive. Since the proposal exceeds the maximum building height by only 2 feet, Board Member Jojarth suggested achieving this with a shallower structural solution instead of trusses and potentially reducing the interior height while keeping the gable roof and an efficient, functional office space. Board Member Jojarth inquired whether there were specific reasons justifying the 16-foot height for the second floor. Ms. Levenberg explained that the basement locker rooms require ventilation to exhaust moisture and dampness, which is one factor driving up the building's height. Additionally, the proposed open web joists allow for a flexible, open office layout. This flexibility means that if Midpen's needs change over time, there will be no need to construct another building, as the office spaces can be reconfigured to suit their needs. The third reason for designing a taller structure is to provide attic space for mechanical equipment, eliminating the need to place it on the roof in a well or similar space. Because the preliminary designs make the actual heights difficult to determine, Board Member Hirsch wanted to clarify whether the structure is the height discussed by the board or whether a suspended ceiling will be installed below it to accommodate mechanical equipment. Ms. Levenberg said some spaces will have suspended or acoustical ceilings, while others will be more open. The multi-purpose room will be open to facilitate meetings and gatherings, whereas the smaller offices will have drop ceilings. Vice Chair Rosenberg inquired whether the applicant had considered using open web joists between the flooring to run the ducting and everything through. Item 3 Attachment A - Minutes of August 20, 2026     Packet Pg. 163     Page 11 of 35 Architectural Review Board Meeting Draft Summary Minutes: 8/20/2026 Ms. Levenberg replied that they are still collaborating with their structural team to determine the most efficient method, whether it involves open web joists or TJIs for the floor-ceiling assembly. Board Member Hirsch asked whether there are plans to add more trees within the parking areas to soften the appearance. Board Member Hirsch also asked about the pathway that goes around the building at the lower level. Board Member Hirsch asked how the applicant envisioned the landscaping at the back of the building at the on-grade lower level. The significant slope at the back of the building raises questions about how the building's height will be perceived from that side and whether visitors would access the back of the building. Ms. Strohmeier said they initially proposed trees and tree wells for the parking lot; however, because of the building's proximity to the wildland area, they will now place the trees along the outer edge of the parking area to mitigate fire risk. Though this site could be considered a WUI, it is situated within a wildland area. Referring to Sheet A1.00, Ms. Strohmeier explained that when staff return from the field, they will park in the fleet parking lot or drop off their equipment in designated equipment parking areas. They will then use a pathway behind the warehouse building that leads directly to the administrative building's lower level. An entryway on the lower level opens into either the briefing room or the mudroom. Staff will enter through the mudroom to remove wet coats and boots before heading to the locker room. Boot drying racks will be available in this space. The upper level of the building must accommodate Midpen board meetings, which may take place twice a year, or allow the public to use their conference space for NGO meetings. Thus, the design needs to be inviting. To avoid field staff walking through the reception area with muddy boots, the design includes a dedicated entrance for field staff to access the mudroom or the briefing area downstairs, with easy-to-clean flooring. Ms. Strohmeier clarified that the entryway to the lower level at the back of the building is not a public entryway; it is for field staff only. The applicant plans to use native landscaping that will work in the existing terrain. Upon formal submission, they will present a landscaping plan by MIG, including visual imagery of their proposal. Their goal is to minimize impact on the property, using only native species and a grass seed collection style. The landscaping at the back of the building, possibly for grading or to identify the pathway, will consist of native grasses to maintain low impact. The back of the administrative building will face a dense forest, with Old Ranch Trail located half a mile away, all within the same Monte Bello Preserve. Between Old Ranch Trail and the administrative building lies Stevens Creek Canyon and the San Andreas Fault. Ms. Strohmeier tried to confirm whether it was possible to see the 2-story building via Google Street View from a distance of half a mile but could not determine visibility because the image quality was too low. The City determines setbacks based on the legal parcel description. Chair Adcock asked the applicant to clarify their statement that APNs are arbitrary. The line depicted in the diagram is located within the triangular area and falls within Santa Clara County and Palo Alto. A lot line adjustment between Parcel A and Parcel B to incorporate this triangle into Parcel A could resolve the setback issue. Referring to Slide 8 of the PowerPoint presentation, Ms. Strohmeier stated that Midpen proposed a new field office because it continues to acquire land and incorporate it into its preserves. Midpen's Real Property Division handles real estate transactions and, after investigating this matter for nearly 2 years, has indicated that Parcel A and Parcel B on the parcel map are the legal parcels. Because Midpen operates as a special government district, APNs do not apply to it the same way they do to private property owners; therefore, APNs do not determine the legal parcels. The significant issue is that Parcel Item 3 Attachment A - Minutes of August 20, 2026     Packet Pg. 164     Page 12 of 35 Architectural Review Board Meeting Draft Summary Minutes: 8/20/2026 A and Parcel B are legal parcels located in 2 jurisdictions, which complicates the lot line adjustment process. Ms. Strohmeier believed she provided Mr. Dinh with Mike Schaller's contact information, the San Mateo County Planner working with Midpen. Midpen will need San Mateo County approvals for grading and parking lots. San Mateo County will not accept Midpen's application until Palo Alto recommends approval of the formal application. Midpen, its Real Property Division, and its legal counsel are open to meeting with the City and San Mateo County to discuss this matter further. The triangle does not exist. To resolve the setback issue, one would need to merge Parcel A with Parcel B in coordination with the County because portions of those parcels are in both the County and Palo Alto. Ms. Strohmeier said to disregard the dashed line in the diagram representing the APN, as it is relevant only for taxation purposes. Ms. Raybould confirmed the setbacks are based on the legal parcel. Chair Adcock asked whether a lot line adjustment or merger needed to go to San Mateo County. Chair Adcock asked whether members of the public would come to the site for any reason other than board meetings and whether that would affect parking counts. Referring to the site plan view on A1.00, Chair Adcock noted a relatively large flat area and wondered if it was intended to serve as a patio or another feature on the backside. The plan included a hammerhead turnaround, which seemed to dictate the building's placement, and Chair Adcock asked if a terrain adjustment could accommodate sliding the turnaround further. Chair Adcock requested an explanation for the hammerhead since it appeared that you could turn around without it. Chair Adcock thought a different shape for the portion of the building that sticks out might help minimize the site impact. Chair Adcock asked whether the roof slope could be adjusted from 3/12 to 2/12. Ms. Raybould stated that a lot merger would need to be recorded in both counties, which the staff could explore further. Staff typically considers the highest point of use at any given time to determine an appropriate parking ratio, with the director's decision at their discretion, according to the code. San Mateo County and Santa Clara County share their data with Midpen's GIS team. The red dashed line on the parcel map on the screen represents San Mateo County's verified boundary. In contrast, Santa Clara County's property boundary records appear as a squiggly line. Because the 2 counties' records differ, Midpen is uncertain how this will affect a potential lot merger or lot line adjustment. Ms. Strohmeier hoped the 2 counties would defer to the parcel map, as straight lines are more practical than curved ones. Ms. Strohmeier mentioned that Midpen's existing facility has a gate that requires a code to enter; this project will implement a similar approach. For a public meeting or if a local NGO requests use of the multipurpose room, they could leave the gate open; otherwise, it will remain locked. Ms. Strohmeier stated that public access to the site during operational hours is not permitted. Board meetings will take place after staff has left for the day. As part of this project, Midpen's Board requested an outdoor gathering space to give employees a place to eat lunch and stretch outdoors before and after their shifts. The team has yet to decide whether this space will feature permeable pavers or compacted DG. Ms. Strohmeier explained they want to demonstrate compliance with code vehicle-turning requirements for large delivery trucks; however, it will not function as a hammerhead turnaround and will not be striped on the site. Vehicles will travel through the site and exit through the yard. Ms. Strohmeier needs to verify whether 2/12 is considered a low-slope roof. Item 3 Attachment A - Minutes of August 20, 2026     Packet Pg. 165     Page 13 of 35 Architectural Review Board Meeting Draft Summary Minutes: 8/20/2026 Ms. Levenberg explained that the primary functional requirement driving the building's leftward placement is to accommodate vehicular traffic in the space between the shop building and the adjacent building to its right. A 30-foot clearance is essential to allow vehicles to pass in both directions and to provide space for someone to pull over and load items between the two buildings. The applicant will consider grading implications as they refine the site plan. Mr. Switzer noted it was 10:12 a.m. and informed the Board they had another large proposal to consider after this one. Ms. Strohmeier mentioned that if the test drilling goes as planned, the well to supply water will come from San Mateo County and go into Santa Clara County and the City of Palo Alto. Chair Adcock invited the board members to share their closing comments. Vice Chair Rosenberg suggested that the applicant's next presentation include details on color, material, reflectivity, lighting, noise, screening, solar considerations, landscaping, and fire breaks. Overall, Vice Chair Rosenberg thought the site plan made sense; the layout aligns well with their usage intentions. Vice Chair Rosenberg acknowledged the importance of Midpen's work, especially in light of the recent fires, and the need to manage land effectively to keep California, and particularly the local area, beautiful. Vice Chair Rosenberg identified the lot line adjustment as a concern. Midpen owns a significant amount of land and could have chosen a different property without this hurdle. The plan indicates 10.25 percent impervious coverage, while the required limit is 3.5 percent. A lot line adjustment would alter the boundaries, thus changing those calculations and potentially resolving the issue. Vice Chair Rosenberg emphasized the importance of accurately depicting the heights graphically at the next meeting. The applicant should also present the floor plans for every building, including the warehouse. Vice Chair Rosenberg urged Midpen to use its dedicated real estate team to address the lot line adjustment and to present a plan outlining next steps and the best path forward at the next meeting. Any other property owner in the city would be held to the standards, and granting Midpen an exception would seem unfair. Chair Adcock said the overarching comments from all of the board members is not to push for variances when you can have a solution within code requirements, lot line, all of that. Chair Adcock recognized Midpen as a very special entity and we value their work but to be equitable to everybody in the city, we do not want to have to push boundaries more than necessary. Chair Adcock thanked the applicant for their presentation and it is an exciting project. [At 10:16 a.m., the Board took a 7-minute break] 3. 3997 Fabian Way [24PLN-00280]: Request for Streamlined Housing Development Review to Construct a New Seven-Story Multi-Family Residential Development Containing 273 Rental Units. The Project is Proposed in Accordance with State Density Bonus Law. Environmental Assessment: The Project is Being Processed as a Streamlined CEQA Review Under Section 15183. Zoning District: General Manufacturing (GM) within GM/ROLM Focus Area. Chair Adcock stated that staff recommends that the board hold a study session to provide feedback on whether adjustments to the application would improve adherence to the objective design standards in Item 3 Attachment A - Minutes of August 20, 2026     Packet Pg. 166     Page 14 of 35 Architectural Review Board Meeting Draft Summary Minutes: 8/20/2026 Palo Alto Municipal Code Chapter 18.24, consistent with the streamlined review process in Section 18.77.073 for housing development projects. This project is subject to the director's decision and does not require an ARB recommendation. Principal Planner Garrett Sauls delivered a slide presentation on the new housing development project at 3997 Fabian Way. This proposal includes combining a cluster of 6 parcels. This site is adjacent to the Moldaw Residences, JCC, Girls' Middle School, and other office and manufacturing buildings along East Charleston Road and Fabian Way. The City is processing this Focus Area plus State Density Bonus application through its streamlined housing review process. Staff review has been ongoing since the formal project submission in 2024. The streamlined housing review process requires an ARB study session. The director will decide on the application once the City completes its CEQA analysis. Staff has received public comments throughout this process and shared them with board members. Staff was open to additional discussions with the public as needed. In 2023, the Council adopted the GM and ROLM focus areas, which modified the base allowances for floor area, parking requirements, and various coverage standards for housing projects. The proposal includes 273 one-, two-, and three-bedroom units; of these, 12 will be BMR at very low income, and 9 will be paid through the housing impact fee. As proposed, it has a 3.0 floor area ratio and 78 percent lot coverage. The building will be 95 feet tall and have 332 vehicle parking stalls, 273 long-term bike parking stalls, and 28 short-term bike parking stalls. It will be a 7-story building with a 2-story above-grade garage. The building will have 3 large outdoor amenity areas on the ground floor. The application requested 8 waivers, and the applicant may request additional waivers or concessions as staff continues its review. The applicant has not yet requested to utilize the 1 concession they qualify for. Mr. Sauls presented the general site plan, floor plans, and streetscape elevations. The site plan showed East Charleston on the right side and Fabian Way at the bottom of the screen. Near Fabian Way, the building will include co-working spaces for residents. The project design includes multiple courtyards (A, B, C, D, and E). The top of the streetscape elevations show the widest angle facing the building on Fabian Way, with the existing JCC building on the left, and the Moldaw Residences on the East Charleston Road- facing elevation. Mr. Sauls displayed the interior elevations facing the Moldaw Residences and the JCC. The planned materials include brick veneer, stucco, wood soffit materials, metal awnings, and storefront materials. Mr. Sauls explained that the base GM zoning standards are modified by the Focus Area, and the City's objective design standards in 18.24 further modify them. This project is currently under consideration for the 15183 infill exemption through CEQA. Two alternative projects have been submitted: the initial proposal was a Focus Area and State Density Bonus application for 292 units, and a Builder's Remedy application for 350 units is still active. Staff requested the board's guidance on how this project can better comply with the objective standards in 18.24, particularly the requirements for 1 tree for every 25 feet along the shared property line with the Moldaw Residences, the base-middle-top design, and establishing a vertical rhythm along the rear and interior-facing sides of the building toward the JCC and the Moldaw Residences. Since this project was submitted under multiple applications, Board Member Jojarth asked about the legal context of what the board is considering and the process involved, the purpose of the tolling agreement, and whether the applicant intends to revive the Builder's Remedy if this application is not approved. Item 3 Attachment A - Minutes of August 20, 2026     Packet Pg. 167     Page 15 of 35 Architectural Review Board Meeting Draft Summary Minutes: 8/20/2026 Mr. Sauls explained that the City received 2 applications: one for the Focus Area plus State Density Bonus Law and the other for Builder's Remedy. The Builder's Remedy application is on hold. The City has a tolling agreement with the applicant that will remain in effect until the City decides on the Focus Area plus State Density Bonus Law project. Currently, only the Focus Area plus State Density Bonus Law application is being processed, which is what is before the ARB. Chair Adcock asked whether the Builder's Remedy version has 7 stories. Mr. Sauls believes the Builder’s Remedy application is also for a 7-story building but it will feature a different design than the one currently before the board. Vice Chair Rosenberg noted that the packet indicates the Builder’s Remedy proposal includes 350 units and an 88-foot height; however, the current plan appears to have 273 apartments and a height ranging from 96 to 102 feet. Vice Chair Rosenberg inquired how common it is for an applicant to submit 2 separate applications for 2 distinct projects on the same parcel. Claire Raybould, Manager of Current Planning, added that the Builder's Remedy project alternative included fewer parking spaces. Mr. Sauls stated that about 10 applicants filed dual applications with the City for various projects: one as a Builder's Remedy alternative and the other intended to meet certain standards. Two examples of projects with dual applications are 3150 El Camino Real and 3400 El Camino Real. Part of the reason for dual applications was to initiate discussions with the City about denser development projects in the context of the Focus Area. A handful of those Builder's Remedy applications may still be lingering. Board Member Hirsch requested more information about the land situation and why there is no below- grade parking. Board Member Hirsch also inquired whether a study has been conducted to determine how much of the site is covered by the flume area. Mr. Sauls indicated that the proposed project is located within a flood zone. A subterranean garage is not permitted under residential uses in a flood zone unless the building includes a commercial component, which Mr. Sauls thought must be approximately 25 to 30 percent of the building. This project is situated downgradient from the nearby Superfund site at the Space Systems/Loral facility, where cleanup efforts are currently underway under a remedial action order issued by the Water Quality Control Board to the applicant. Currently, the site has no buildings, partly because remediation efforts are underway in preparation for a future residential project. Ms. Raybould added that FEMA requirements do not allow a subterranean garage for an exclusively residential project. It is difficult, if not impossible, to build below grade in a flood zone. Additionally, this site is located within a flume area, which adds to the complexity and costs associated with below-grade construction. Board Member Chen inquired whether the Housing Accountability Act applies to Builder's Remedy projects. The Housing Accountability Act allows local agencies to deny or reduce a project's density if it would have a specific adverse impact on public health or safety. Since this project falls under SB 330, Board Member Chen asked whether this meeting counted as 1 of the 5 meetings and whether this project could return to the ARB. Item 3 Attachment A - Minutes of August 20, 2026     Packet Pg. 168     Page 16 of 35 Architectural Review Board Meeting Draft Summary Minutes: 8/20/2026 Ms. Raybould confirmed that the Housing Accountability Act applies to Builder's Remedy. Today's meeting counts as 1 of the 5 meetings. As part of the streamlined housing development review process, the Architectural Review Board has 1 study session. Board Member Hirsch asked whether there were any limits on the building's height or number of stories. Mr. Sauls stated that the maximum height is 60 feet under the Focus Area standards; however, the applicant can request a Density Bonus Law waiver of the height standard. The waiver relates to the proposed density of the affordable units offered and the affordability level of those units. Lisa Majchrzak, a studio director at TCA Architects, presented on behalf of the applicant. John Favreau of Juno Realty Partners attended online. Lisa Ring of LOR Planning & Environmental Consulting and Teresa Ruiz of TCA Architects attended in person. Holland Partner Group has partnered with Juno on this project for the past 2 years, and several members were present. Ms. Majchrzak said the site is currently empty and offers an opportunity to complete the block, create an urban edge, and add housing in the area. Ms. Majchrzak highlighted the opportunity to create an appealing corner while incorporating public space. It fits the contemporary style established in the neighborhood. This project is proposed on a housing inventory site, thus supporting the City’s goal for more housing. This will be a 7-story building with 5 levels of residential units above 2 levels of above-grade structured parking screened by the building. The proposal includes 273 units, which is fewer than the previous plan. This project has evolved over the past 5 years. When TCA became involved, revisions to the schemes replaced the central courtyard and long continuous façade with finger courtyards to break up the massing. The developer, JCC, and Moldaw held a private meeting, during which the applicant received feedback. The design progressed through multiple submissions to the City. The current design was shown. The vertical massing along Fabian is designed as 3 massing pieces with setbacks for the courtyards. At the rear, the exterior-facing courtyards allow more light and space for neighboring properties rather than the previous continuous façade. The exterior courtyard facing Fabian pulls back the massing, casting fewer shadows onto the community pool. The view was shown from East Charleston, illustrating the closest distance between the proposed building and the neighboring residences. This proposal complies with setbacks, including a 10-foot rear setback, and the distance from the neighboring residences is approximately 29 feet, expanding to 43 feet where the building steps back. Because this site is within a floodplain and is 100 percent residential, it was raised 1 foot above the base flood elevation. Due to contaminated soils, no dwelling units can be placed on the ground level. Instead, fitness and amenity spaces, as well as leasing offices, will occupy the ground level on that corner. There is a grade differential. As you go to the left, it becomes steeper toward the garage level, forcing the driveway closer to the center. The building includes 2 levels of garage parking, with the first set of residential units located at the podium level on the third story. The courtyard on the left corner and the courtyard facing Moldaw are passive, while the courtyard with a pool and the courtyard on Fabian are active. Adding more courtyards reduced the unit count from 295 to 273. Item 3 Attachment A - Minutes of August 20, 2026     Packet Pg. 169     Page 17 of 35 Architectural Review Board Meeting Draft Summary Minutes: 8/20/2026 Ms. Majchrzak explained that the steep overhang provides protection and definition for an outdoor plaza space for pedestrians. The top is angled. The base-middle-top on this edge accentuates the top element and features a discontinuous façade on the Fabian side. As the building wraps around, a continuous datum runs at the garage level along the Level 3 line. On the back side facing Moldaw, the middle and upper sections have greater color differentiation. Vertical recesses run along the JCC and the neighboring 1-story building. The exterior elevations palette of fine-grain brick material and color differentiates the forms and adds visual interest. This color differentiation is also visible in the materials on the backside. An existing row of dense trees and a 6-foot fence on the neighboring property prompted Ms. Majchrzak to seek input on how to approach landscape screening. PUBLIC COMMENTS: 1. Stuart Klein spoke on behalf of 5 people, the Taube Koret Campus for Jewish Life, the Oshman Family Jewish Community Center, and the Moldaw Senior Residences. Their campus borders 2 sides of the Fabian Way parcel, making them the neighbor most impacted by the proposed project. Mr. Klein opposed the current project design, citing concerns about the health and safety of vulnerable populations. Moldaw Residences houses 230 seniors with an average age of 86 years. The JCC's preschool and after-school programs enroll 500 children. The JCC has 2,000 adult visitors daily. The JCC has an elevated risk of targeted violence and receives FEMA security grants. Mr. Klein outlined 3 main health and safety concerns. First, sunlight. Their shadow study indicates that the proposed massing would block sunlight, putting 32 units in near-total shadow. Loss of daylight is a documented medical risk for seniors. Second, emergency access. In the event of a fire, earthquake, or anti-Semitic attack, increased traffic congestion will slow down first responders, delay evacuations, and lengthen travel times to hospitals beyond established city and state standards. Moldaw calls an ambulance approximately 5 times weekly. Third, pedestrian safety. The proposed project would increase traffic at the intersection of San Antonio Road and East Charleston, which the City describes as its most unsafe intersection. This would endanger seniors, JCC visitors, students traveling to 3 nearby schools, and cyclists heading to the Baylands. Mr. Klein noted that they have raised these health and safety concerns with the applicant in 3 letters over the past 5 years. They have received no response and have only seen 1 small mitigation. The staff report mentions a 2025 meeting between the applicant and Moldaw but Mr. Klein had no record of it, so he requested the date and attendees. Today, the applicant stated they met with the JCC; however, the JCC president, who will speak next, will confirm that no such meeting occurred. Mr. Klein requested the following: Where redesign can solve the problem, the City should require it. For instance, stepping the building back from the property line to preserve sunlight for Moldaw residents and maintain safety and privacy for the JCC pool deck can be done without losing any units. Where redesign cannot mitigate the issues, shrink the project. Mr. Klein's group provided evidence of degraded pedestrian safety and extended emergency response times that exceed state and city guidelines. If this evidence persuades the City, they should reduce the scale of this project. As they have said for 5 years, Mr. Klein's group is ready to collaborate with the applicant to address these concerns. 2. Zack Bodner, President and CEO of the Oshman Family Jewish Community Center (OFJCC), spoke on behalf of 5. Nearly 20,000 people come through their doors every week, including fitness Item 3 Attachment A - Minutes of August 20, 2026     Packet Pg. 170     Page 18 of 35 Architectural Review Board Meeting Draft Summary Minutes: 8/20/2026 center members, to attend events, or those whose children are enrolled in their preschool, after-school care programs, and camps. The OFJCC supports residential development in Palo Alto, has previously supported their neighbors at Altaire and Alta Torre, and is eager to welcome the project at 3997. Mr. Bodner is eager to meet with the developers and architects to address the JCC’s concerns but they have yet to receive a response to their requests to meet. First, the additional traffic generated by this project will further burden East Charleston and Fabian Way, which are critical emergency access routes to the OFJCC campus. Publicly available traffic and emergency response information indicates that the added congestion could push emergency response times below acceptable City standards. Second, the building's windows and roof could pose security and harassment risks. The proposed building towers over the OFJCC campus and has a direct, unprotected line of sight to the outdoor pool. According to the FBI, the U.S. has experienced a 400 percent increase in anti-Semitic incidents since October 7, 2023. Locally, there has been graffiti with swastikas, anti-Semitic flyers, vandalism, and violent assaults. Residents have the right to express their political views; however, given the building's proximity, prominently displayed anti-Semitic or intensely anti-Israel messaging overlooking a Jewish institution could be deeply disturbing. Third, the structure's large physical profile close to their property line raises privacy concerns. The JCC offers one of the few outdoor swimming pools available to Palo Alto residents, and this massive structure would cast significant shadows on their pool deck, diminishing its use as an enjoyable, sunny gathering spot and creating privacy issues for swimmers who would be seen from the windows. Ultimately, this could decrease the value of a JCC membership. On behalf of the OFJCC, Mr. Bodner asked the ARB to recommend that these documented health, safety, security, privacy, and operational impacts be satisfactorily mitigated before the project moves forward. 3. Ben Chaika, Chief Financial Officer of Moldaw, spoke on behalf of 5. Currently, Moldaw houses approximately 230 vulnerable community members. The average age of residents is 86, with the oldest resident nearing 104. Of these, 24 residences, or 1 out of every 8, are below-market-rate housing for the financially vulnerable. Many residents are disabled, and all face the challenges associated with aging. As proposed, this project will negatively impact the health and safety of Moldaw's seniors. Mr. Chaika was accompanied by many of these seniors, along with several department heads and board members. Mr. Chaika asked everyone from Moldaw to raise their hands for the ARB to see them. Mr. Chaika highlighted 2 major safety concerns. First, Moldaw is worried the project will lengthen emergency response times, which is literally a matter of life and death. Moldaw receives an average of over 21 ambulance visits per month. The Palo Alto Fire Department has an 8-minute response-time standard but travel from the closest fire station can already take about 7 minutes during school pick-up and drop-off. The state mandates a 30- minute travel time standard from a residence to the nearest hospital, yet travel from Moldaw to Stanford Hospital can take 28 minutes in traffic. The project is expected to add approximately 1,240 vehicle trips per day to an already heavily congested area, making it likely that these travel-time safety standards for fire response and hospital access will be exceeded. The second safety concern is that the proposed project will exacerbate the neighborhood's existing traffic safety issues. The City's 2025 Safe Streets for All Action Plan identified San Antonio Road from Alma Street to East Charleston Road as part of the high injury network, based on crash history and collision severity. Approximately 30 percent of reported crashes have Item 3 Attachment A - Minutes of August 20, 2026     Packet Pg. 171     Page 19 of 35 Architectural Review Board Meeting Draft Summary Minutes: 8/20/2026 occurred along Fabian Way. The City's Bicycle and Pedestrian Transportation Plan ranks the intersection of Fabian and East Charleston as having the highest level of traffic stress for bicycles. Approving a project that significantly increases traffic in a City-identified dangerous area needs to be carefully considered in light of the City's commitment to reducing traffic fatalities and serious injuries on Palo Alto roadways to zero by 2035. Without additional interventions, the project's massive size will make the area even more hazardous for Moldaw's elderly residents. Mr. Chaika urged the board to imagine their own parents or grandparents facing such dangers and consider how reduced direct sunlight in their homes could harm their physical, mental, and sleep health, especially for those with mobility issues who spend most of their time indoors. On behalf of Moldaw Residences and its senior residents, Mr. Chaika asked the ARB to recognize these specific, measurable health and safety impacts based on the City's adopted safety standards and policies, and to recommend that these impacts be satisfactorily mitigated before the project moves forward. 4. Randy Popp, an architect who previously served for 3 years on the ARB, spoke on behalf of 5. Mr. Popp emphasized that while Palo Alto needs more housing, not all housing is good. Unit count matters but so do quality, relationship to surroundings, and the impact on neighbors. The Toby Koret Campus was built in 2009 and includes 193 senior residences. Zoning allowed a building height of about 35 feet, which influenced Moldaw's design, placement, massing, residential units, light, views, and its relationship to the neighboring property. The physical environment influenced how residents chose their homes within the building. The proposed 7- story building, approaching 100 feet tall, is immediately adjacent to an existing senior community center and across the street from much lower-scale development. The average age at Moldaw is 86. Many residents cannot relocate. Architecture extends beyond property lines. Height, setback, massing, orientation, privacy, and sunlight determine how a new building affects nearby residents. The applicant's data indicates a 7-foot-5-inch increase in building height. The seventh floor is now 4 feet higher, the roof is more than 6 feet higher, and the parapet is more than 7 feet higher. The building lacks a meaningful upper-story transition toward Moldaw. Placing such a tall building so close to an existing residential community affects daylight and shadow. Mr. Popp referenced an updated analysis that was commissioned to evaluate the current design. Existing and proposed views from 4 units were shown to illustrate the condition affecting 32 Moldaw residences. The new building occupies the full visual field and materially reduces daylight reaching the window of Unit H104 at the podium level. At the fourth level, the proposed building presents a wall directly across from the residence. The proposed configuration dramatically impacts the daylight and outlook for Unit K106 at the podium level. Unit K406, despite greater separation, still experiences a substantial impact. Images of June 21 and September 21 showed the proposed building casting a shadow on the Moldaw residential wings, reducing daylight. To understand the implications of reduced daylight for elderly residents, they consulted Dr. Jamie Zeitzer, a Professor of Psychiatry and Co-Director of the Stanford Center for Sleep and Circadian Sciences, who is a recognized expert on light, sleep, and circadian biology. Dr. Zeitzer explained to Mr. Popp that adequate daytime light is crucial for regulating sleep, circadian rhythms, mood, alertness, and physical and mental health. Older adults are more vulnerable to Item 3 Attachment A - Minutes of August 20, 2026     Packet Pg. 172     Page 20 of 35 Architectural Review Board Meeting Draft Summary Minutes: 8/20/2026 reduced daylight exposure. Professor Zeitzer's written conclusion is that this project would directly cause a specific adverse impact on physical and mental health, including leading to premature mortality of approximately 32 elderly residents by significantly reducing their access to natural, window-filtered daylight. Furthermore, the study indicates substantial impact to the JCC pool and pool deck from the proposed building's height, location, and massing. The staff report independently identified potential noncompliance with the City's objective design standards, such as landscape screening along the Moldaw property line, required façade breaks, and the base-middle-top articulation standard. Clustering trees along the Moldaw edge while leaving gaps is not a continuous buffer. The project should be modified to comply with objective standards or the applicant must clearly identify and justify any waivers or concessions, while another legal path addresses specific adverse impacts on public health or safety. As an architect, Mr. Popp would place more building where it can be accommodated and less where it would negatively impact existing residents. Rather than a large amount of full-height building mass along the Moldaw edge, Mr. Popp would concentrate more of the building toward Fabian and create a stronger height transition as the project approaches Moldaw. Along Fabian, the project could maintain a more continuous urban edge with courtyards organized within the site. The building could terrace down meaningfully toward Moldaw with reductions in height and mass. Minimizing the building's tall wall as much as possible would greatly improve daylight, privacy, perceived scale, and the relationship between the 2 residential communities. Reducing the garage to approximately 1 story along the Moldaw edge while shifting more structured parking toward Fabian could substantially reduce the mass and health impacts on the existing senior community. Mr. Popp urged the board to address the objective standard issues identified by staff and to note whether the project complies, needs modification, or relies on a justified waiver or concession. Second, Mr. Popp asked the board to recommend that the significant health impacts that the building's height and massing will impose on Moldaw residents be satisfactorily mitigated before the project is approved. These impacts result from design choices, and architectural approaches could substantially mitigate them. Mr. Popp emphasized that people deliberately choose the home, community, and environment they expect to spend an important, often final, chapter of their lives, and the current Moldaw residents made this choice long before this project was proposed. This project's impacts will be felt in the daylight that reaches someone's home, in what they see when they look out their window, in their privacy, their health, and the overall quality of the place they chose to live. Mr. Popp urged the board to recommend mitigation of impacts before this project moves forward in its present form. 5. Camas Steinmetz, speaking on behalf of 5, is a land use attorney at Jorgenson, Siegel, McClure & Flegel in Menlo Park. Ms. Steinmetz represents the Oshman Family Jewish Community Center (OFJCC) and Moldaw Residences, both located on the Campus for Jewish Life and bordering the proposed project on 2 sides. While her clients strongly support more housing in Palo Alto, they do not approve of the project's current design configuration. As previous speakers outlined and as detailed in a letter sent on Friday, this project negatively impacts nearby children, seniors, and JCC visitors. Ms. Steinmetz emphasized that the City can deny this project if it poses a specific adverse impact on public health or safety. State law defines a specific adverse impact as a significant, quantifiable, direct, and unavoidable impact based on objective, identified written Item 3 Attachment A - Minutes of August 20, 2026     Packet Pg. 173     Page 21 of 35 Architectural Review Board Meeting Draft Summary Minutes: 8/20/2026 public health or safety standards, policies, or conditions. After reviewing the applicable state laws and evidence on record, Ms. Steinmetz believes the health and safety thresholds have been met. At nearly 100 feet tall, this project would tower over and cause a specific adverse impact on the health of the residents of 32 Moldaw units by depriving them of the sunlight that is important for their health, according to U.S. Green Building Code standards and the medical guidelines explained by Stanford University Professor Zeitzer in his letter attached to hers. This project is expected to generate an additional 1,240 vehicle trips, which would cause a specific adverse impact on the safety of neighboring Moldaw residents, JCC visitors, and employees. This increase in traffic could delay emergency response times for ambulances and first responders beyond the Palo Alto Fire Department's established 8-minute standard and extend travel time to the nearest hospital beyond the 30-minute state standard. Because this project is located near senior housing, a community center, and several schools, populations at heightened risk for adverse health outcomes from environmental impacts, Ms. Steinmetz anticipated that these and other public health and safety impacts would be further substantiated in the record through the environmental analysis required by CEQA. If these identified specific adverse health and safety impacts are not mitigated, the legal basis for denying the project under the Housing Accountability Act, State Density Bonus Law, and the Palo Alto Municipal Code would be satisfied, thus justifying the City's denial. However, Ms. Steinmetz did not request outright denial of the project. Instead, her clients are seeking design modifications to mitigate the identified health and safety impacts. Massing modifications could substantially reduce or eliminate sunlight deprivation without decreasing the number of housing units. If the safety impacts stemming from project-generated traffic cannot be mitigated, then reducing the project's density to lessen the adverse impact may be warranted. On behalf of Moldaw and the JCC, Ms. Steinmetz asked the ARB to consider the specific adverse public health and safety impacts identified and to encourage the developer to work with her clients to mitigate these impacts satisfactorily. 6. Dr. Henry Lew, the medical co-chair of Moldaw's Health Committee, is a clinical associate professor of medicine at Stanford and a board-certified cardiologist. Dr. Lew explained that morning sunlight activates melatonin, which promotes good sleep. Seniors often struggle with sleep already, as they may wake up multiple times during the night. Sunlight activates vitamin D, improving the immune system. Sunlight also stimulates serotonin production, a brain hormone that elevates mood and reduces anxiety. Similarly, jet lag and seasonal affective disorder stem from sunlight loss. Dr. Lew emphasized that losing sunlight can be harmful, and cited the medical motto, "primum non nocere" or "first, do no harm." Dr. Lew warned that when seniors lose sunlight, it can negatively impact their health, potentially leading to increased depression and a shorter lifespan. 7. Marilyn Levy lives in the Moldaw Senior Residences on the west side of the building, directly overlooking the proposed construction site. An architect's rendering of the view from her apartment, H104, was shown. The loss of sunlight would severely impact Ms. Levy. Ms. Levy moved into the Moldaw community in 2024 with her late husband, Michael. Before moving in, they toured the available units in the complex, each having a similar layout and proximity to the community rooms. They chose apartment H104 for its sun-filled windows and a balcony deck Item 3 Attachment A - Minutes of August 20, 2026     Packet Pg. 174     Page 22 of 35 Architectural Review Board Meeting Draft Summary Minutes: 8/20/2026 brushed by trees. As Michael's condition worsened, he became increasingly confined to their apartment. One of the few sources of relief for him was sitting on their breezy deck, soaking up the afternoon sun. As time passed, Michael's mobility and overall health deteriorated. After returning home from one of his many hospital visits, he remarked on the sense of relaxation he felt just crossing the threshold into their bright, airy home. Unfortunately, his growing discomfort and reduced strength required Michael to spend extended periods indoors in a medical recliner. During this time, they were both grateful for the large picture windows and the sunlight that streamed in. Research from the Mayo Clinic indicates that adults over 70 require more natural sunlight than younger populations. Sunlight helps the body absorb calcium, which maintains bone strength, and supports the immune system. The research also reveals that any reduction in sunlight exposure can negatively affect mental health and disrupt sleep, 2 factors that directly affect the immune system. The Mayo Clinic draws a direct connection between ample sunlight and senior health. Michael passed away in February. Had his decline been coupled with a window view of a parking garage or a building face and little sunshine, his spirit may have failed long before his body did. 8. Janie Newell lives in Charleston Village, diagonally across from the JCC. Ms. Newell noted that another equally dense development is planned for the other side of Charleston on Fabian. There is also a proposal for the Hengehold lot at San Antonio and Charleston, as well as a condominium complex on San Antonio and Middlefield. Ms. Newell’s concern was regarding the density of these developments and the concentration of large complexes in such a small area. This situation is contributing to increased traffic, which is already extremely bad. Travel on Charleston from Middlefield to San Antonio is often gridlocked. Ms. Newell has waited through 2 or 3 traffic lights to cross Middlefield because of congestion from vehicles heading to the freeways. In terms of public transportation, the train station is a mile away but it is only 2 blocks to the 101. 9. Stevan Chandler, a resident of Moldaw, said the new building's wall, along with the walls of his building, would form a 3-sided box canyon. The proposal indicates that the windows on the new building's first and second levels will primarily consist of cyclone fencing or equivalent materials, intended to provide passive ventilation for over 325 vehicles parked on those 2 floors. The submitted plan to the City does not include any exhaust fans; however, given the number of cars, there will need to be some exhaust fans sucking poisonous carbon monoxide from the proposed two-level garage and blowing it into the box canyon created by both buildings. Since carbon monoxide is the same weight as oxygen, it does not rise or settle to the floor; instead, it mixes with oxygen and remains. The combination of exhaust fans and passive ventilation will fill the box canyon with poisonous gas. 10. Beth Roth has lived in Moldaw for the past 13 years. Before retiring, Ms. Roth worked in healthcare as a registered nurse. Ms. Roth is deeply concerned about the significant impact the proposed development project will have on the Moldaw campus, where Moldaw residents, along with hundreds of children and youth, are present every day. The development is located directly across the street from Kehillah High School and Girls' Middle School, and is adjacent to the JCC's preschool, after-school program, and summer school. From a healthcare and Item 3 Attachment A - Minutes of August 20, 2026     Packet Pg. 175     Page 23 of 35 Architectural Review Board Meeting Draft Summary Minutes: 8/20/2026 community safety perspective, traffic safety is Ms. Roth's primary concern. First, the development will increase traffic congestion and delays, particularly during school drop-off and pickup times. Second, adding bicycle traffic from the new building's residents, along with student bicycle traffic in the area, will increase risk. Third, it will make it more hazardous for older and younger people crossing the streets. Ms. Roth loves her home at Moldaw. Ms. Roth hopes the Moldaw residents and young children will continue to have a safe and healthy future. 11. Ron Shapera is a retired physician who has been living at the Moldaw Senior Residences for the past 9 months. Moldaw averages 21 calls to 911 each month, requiring a response from either a fire truck with paramedics or an ambulance staffed with appropriate personnel. The elderly residents at Moldaw frequently experience serious emergencies, including heart attacks, strokes, and severe falls. Rapid access to Moldaw is crucial for ensuring timely transport to hospital emergency departments or for acute treatments. Any transport delays could put lives at risk. Currently, traffic in the Moldaw area is very congested, and the proposed project would worsen this situation. For this reason, Moldaw Management and its residents are here today to protest such future construction. 12. Sue Hartenbaum stated that she has been driving for over 40 years without any accidents. While pulling out of the Moldaw valet's driveway onto Charleston Road, she was turning right toward Fabian. The traffic lights were in her favor, and all traffic was stopped for a pedestrian crossing Charleston at San Antonio. As Ms. Hartenbaum entered her lane, she noticed a car running a red light on San Antonio, speeding toward her. Ms. Hartenbaum quickly hit the brakes and backed up as fast as she could to get out of the way. Ms. Hartenbaum hit another vehicle that had pulled in close behind her while she avoided a crash with the oncoming car that zoomed past her. Fortunately, no one was injured but her insurance premium doubled. Ms. Majchrzak acknowledged the public comments and thanked everyone for the input and feedback. The front, as it goes toward Fabian, has an angled parapet that is the building's highest point, measuring 95 feet from the lowest adjacent grade to the top of the parapet. The typical parapet height is 89.5 feet. The online meeting held between the applicant and the neighbor took place on April 3, 2024. [The Board took a break] Vice Chair Rosenberg asked who participated in the online meeting on April 3, 2024, whether a follow- up meeting occurred after the April 2024 meeting, and whether any meeting notes, follow-up emails, or records were available. Because there were several design iterations, Vice Chair Rosenberg wanted to know which design was presented at the April 2024 meeting and whether the applicant met with anyone from Moldaw or JCC after the design revisions. Vice Chair Rosenberg asked when the current design was finalized and when the applicant put the paperwork together. Ms. Majchrzak replied that Juno Partners, John Favreau, and JCC Moldaw attended the online meeting on April 3, 2024. The current design has evolved since January 2025, when the applicant submitted the second version. The third submission in June added the corner courtyard. John Favreau, Founder and Managing Partner at Juno Realty Partners, stated that the online meeting held on April 3, 2024, included him, Jeff Farrar (the landowner), Tony Klein (representing the Moldaw Board of Directors), Mark Holtzman (CFO of the OFJCC), as well as Stuart Klein, Randy Popp, and Sally Item 3 Attachment A - Minutes of August 20, 2026     Packet Pg. 176     Page 24 of 35 Architectural Review Board Meeting Draft Summary Minutes: 8/20/2026 Lynchbaugh (representing the OFJCC). Mr. Favreau first contacted Stuart on March 19, 2024. The OFJCC representatives sent a follow-up letter in July 2024. No follow-up meeting was held after the April 2024 meeting. Mr. Favreau had the agenda for the April 3, 2024 meeting. The purpose of the meeting was to inform JCC and Moldaw about the upcoming formal application submission. They discussed the general plan-compliant 292-unit design and the preliminary Builder's Remedy design. The presentation included the design drivers. Additionally, they discussed public comments received during a pre-screen in 2021, noting the number of speakers who supported the project, those who opposed it, and the representation from the OFJCC and Moldaw Residences. No further meetings occurred between the applicant and JCC and Moldaw at the time of the most recent submittal. Board Member Hirsch asked whether the applicant had presented a design at the April 2024 meeting that faces the Moldaw, similar to the one shown in this set of drawings. Ms. Majchrzak explained that today's design is different from previous versions. Slide 5 illustrates the design's evolution. Initially, only 1 courtyard faced Moldaw. In the June 2026 submittal, the applicant added courtyards, increasing the total from 2 to 5. Two courtyards will now face Moldaw, along with an additional courtyard on the corner facing the pool. Chair Adcock asked whether the applicant had conducted any studies comparing the existing and proposed buildings’ heights. The new building will be 10 feet from the property line, while the neighboring building is set back further. Although there are existing trees nearby, they are not 95 feet tall. It is important to understand how the proposed building's height, particularly the sections closest to the Moldaw Residences, will compare floor by floor with the existing building and to evaluate the potential impact on daylight. Ms. Majchrzak said the Moldaw Residences has 5 stories, while the proposed building will have 7 stories, making it about 20 to 25 feet taller. It is close to 40 feet at the pinch points in horizontal distance, so the proposed building is an additional 25 feet taller from there. The wings are about 70-foot sections but there is a gap of approximately 47 feet between them. Referring to Page AA1.4, Board Member Jojarth stated that the project needs to provide more daylight to the neighboring building. To do so, the rear of the new development would need to be stepped back. Depending on the light study, if this change affected 6 units across 4 floors, 24 units would be eliminated. Board Member Jojarth inquired whether the applicant had considered how they might recover those 24 units, potentially through additional waivers. Board Member Jojarth thought it would be worthwhile to understand what the City can give in return if the applicant removes those 24 units, exploring possible trade-offs such as a code exemption or allowing an additional story on the Fabian side. Ms. Majchrzak stated that stepping back the rear of the proposed development would affect the total unit count. Ms. Majchrzak acknowledged that Board Member Jojarth had presented an interesting suggestion but losing that many units is significant; therefore, they would need to confer with the applicant. Board Member Hirsch suggested 2 approaches for the applicant to consider. You could step back each floor progressively as you go up the building, removing sections from the back. Light studies would Item 3 Attachment A - Minutes of August 20, 2026     Packet Pg. 177     Page 25 of 35 Architectural Review Board Meeting Draft Summary Minutes: 8/20/2026 ensure the units facing this project have significantly more daylight. Alternatively, the applicant could consider raising the portion of the building that faces Charleston by 1 level. Ms. Majchrzak said the Builder's Remedy version was an 8-story building. The fire department must be able to access the building within a certain height from grade. Because of the floodplain, the building must be set higher on the site, which reduces the available height and makes it difficult to stay below the CBC definition of 85 feet for Type 3 construction while keeping the lowest occupied floor at 75 feet so it is not classified as a high-rise. The team and the applicant decided to maintain the height at 7 stories to avoid compressing the floor-to-floor heights. Chair Adcock asked whether Type 2A or Type 1A construction would allow a taller building on the Charleston-Fabian side, which could help keep heights lower in the rear section. Currently, the proposed building is 2 stories taller than the adjacent neighbors, which is around 40 feet, while the proposed building is 95 feet. This results in an almost 1:2 proportion taller than the space between them. The wings are heavily impacting the adjacent neighbors. The neighboring building has more site space and trees but the proposed 10-foot setback places the 95-foot building close to the property line, reducing the west-side light for the adjacent building. Ms. Majchrzak stated that the construction type and the high-rise definition limit the building's maximum height. Even for Type 2 construction, the applicant preferred not to be classified as a high- rise. If a building is labeled as a high-rise, it requires additional structural elements and cores designed in a certain way, which is often not cost-feasible unless the building is between 11 and 20 stories. Teresa Ruiz, Principal and VP of Business Development at TCA Architects, serves as a Planning Commissioner for the City of Alameda. Ms. Ruiz clarified that the proposed building is not uniformly 95 feet tall. While it reaches 95 feet at the parapet on the corner facing Charleston, it is not 95 feet tall facing the Moldaw Residence. The proposed building is 2 stories taller than Moldaw but the stories are shorter due to the difference in floor-to-floor height. Vice Chair Rosenberg asked what the height is of the rear side toward the Moldaw Residences. Ms. Majchrzak replied that the height of the rear side facing the Moldaw Residences is approximately 89 feet, 6 inches to the top of the parapet. The rooftop is 42 inches below that, as required by safety codes. The 3 courtyards on the Fabian Way side were not included in previous versions of the plans. Board Member Jojarth questioned whether the applicant broke up the façade to comply with the objective guidelines for massing. Board Member Jojarth noted that reducing the number of courtyards or making the courtyards smaller on the Fabian side would give you more space in the back. There may be opportunities to increase the building's mass on the Fabian side while reducing massing on the backside. Ms. Majchrzak explained that breaking up the façade to follow objective design standards for massing was part of the reason for adding courtyards. In residential architecture, you must work within double- loaded corridor increments. For a long site like this, you could either do the donut shape, which was tried and abandoned, or a finger-courtyard design if you are not doing a centralized courtyard. Board Member Hirsch noted that there is a swimming pool and active spaces on that side of the site, so they would also want daylight in those courtyards. If there are fewer courtyards, you cannot put the swimming pool on the back side of the site. Item 3 Attachment A - Minutes of August 20, 2026     Packet Pg. 178     Page 26 of 35 Architectural Review Board Meeting Draft Summary Minutes: 8/20/2026 This project provides more parking spaces than similar projects the board has reviewed recently. Board Member Chen inquired whether the applicant had considered reducing the number of parking spaces, given that ridesharing has become common and the Builder’s Remedy application included fewer parking spaces. Because several members of the public commented on traffic concerns, Board Member Chen asked whether a traffic study was conducted. Significant changes are anticipated along Fabian in the coming years due to new housing developments, including this project, as well as new schools across the street. During peak hours, traffic conditions could worsen. Board Member Chen asked whether the applicant had considered moving the trash staging area on-site instead of along the street. Board Member Chen asked whether the applicant had considered reducing the floor-to-ceiling height for tenant levels from 9 feet 7 inches to 9 feet, and also lowering the garage ceiling height from 12 feet. The ADA requirement is less than 9 feet. On Sheet A2.6A, the elevations label the floor-to-ceiling height, which also includes space for ducts, mechanical systems, and lighting. Zooming in on the right side, the green dimension label represents the floor-to-ceiling height. Perhaps some height reductions could help reduce the building's overall massing. Vice Chair Rosenberg added that the black text on Sheet A2.6A indicates floor-to-floor height, while the green text indicates floor-to-ceiling height. Ms. Majchrzak said they had not considered reducing the number of parking spaces, as they are aiming for a parking ratio that aligns with market demand. They determined the number of parking spaces by calculating how many spaces to provide per bedroom to meet the development partner's standards. The applicant's trash consultant is conducting some studies. After the team develops solutions for trash staging, they will reach out to City staff and various City departments. Ms. Majchrzak explained that the garage must have a certain slab thickness; therefore, the thickness at the podium is about 12 or 15 inches. Additionally, the utilities for all the units run through this area, including plumbing lines that must descend through the slab and travel horizontally to exit the building. Sprinkler lines and possibly suspended light fixtures also run through the garage. The remaining garage height cannot be lowered because that would conflict with the ADA-required height standards. Mr. Sauls confirmed that the City will provide the traffic study once it completes the CEQA analysis. CEQA primarily focuses on the VMT model to assess potential impacts, rather than evaluating the level of service. Mr. Sauls mentioned he had discussed with the applicant that the City did not want trash staging in the public right-of-way, especially as the South Palo Alto Bikeways plan is being developed. To avoid storing trash bins on public property, the applicant is considering staging them on-site on a concrete pad adjacent to the drive area. The waste collector would come to retrieve the bins, maneuvering them in front of vehicles for collection, and put them back in the same space. Vice Chair Rosenberg believed the parapet is actually 4 feet 6 inches, not 42 inches. This represents an extra foot of height for the parapet wall that may not be necessary. Reducing the 9-foot 7-inch ceiling heights by 7 inches per floor, multiplied by 5 floors, adds up significantly. The third story has a 10-foot 7- inch ceiling height, not 9 feet 7 inches. Thoughtful planning could route ducting and mechanical systems through lower-traffic areas or around the perimeter. Each garage elevation has a 12-foot ceiling clearance with a 1-foot structural element. Vice Chair Rosenberg asked why garage parking needs a 12- foot clearance when the board has seen similar garages in downtown Palo Alto with only 6 feet of clearance. Item 3 Attachment A - Minutes of August 20, 2026     Packet Pg. 179     Page 27 of 35 Architectural Review Board Meeting Draft Summary Minutes: 8/20/2026 Vice Chair Rosenberg highlighted the applicant's parking garage levels and the Moldaw Residences on the floor plan sheets. Parking levels 1 and 2 are 12 feet high, 13 feet plate to plate, which could potentially encroach upon the third level of the Moldaw Residences based on the heights. Vice Chair Rosenberg asked whether the applicant considered adding a few habitable residential units across the backside, or if that is a non-starter due to parking counts. Vice Chair Rosenberg reiterated that the number of parking spots the applicant is aiming for is based on what they believe potential buyers or renters would prefer, rather than meeting the minimum code requirement. While Vice Chair Rosenberg acknowledged the importance of parking, she expressed concerns regarding the architectural screening along the façade facing the residences. In their experience, Ms. Majchrzak noted that a 12-foot clearance for each garage level provides extra room to avoid issues during construction. Additionally, there is a pool on that deck, so they need to ensure there is enough space to accommodate the pool structure on the second level. At the roof, the 4- foot-6-inch measurement includes the build-up for tapered insulation needed for drainage, so it is not solely the parapet guardrail height. Ms. Majchrzak explained that when they considered an 8-story option, they planned to place units across the back because they had an extra floor of parking. Ms. Majchrzak said they proposed perforated screens to cover the openings. Vice Chair Rosenberg pointed out that when someone pulls into their parking space, their headlights will shine through the perforated screens directly across into the residences. In theory, during both day and night, when a resident parks their vehicle, the headlights will be directed toward the residences. Vice Chair Rosenberg asked what the screen perforation percentage was. Vice Chair Rosenberg inquired if there was any intention to plant along the screening façade. Ms. Majchrzak thought the screens might be around 50 percent perforated. Ms. Majchrzak could consider a gradient solution for the screening, denser at the bottom and more open at the top. The applicant had no intention of planting along the screening façade. Ms. Majchrzak thought the first level would be blocked by their fence, providing direct screening. Vice Chair Rosenberg pointed out that it is a 6-foot fence and a 12-foot parking garage. Mr. Favreau believed the Moldaw Residences were situated above a garage. Therefore, on the ground floor, the lights will shine into the garage. Regarding the back façade, Vice Chair Rosenberg asked whether headlights from only the second parking level would negatively impact the Moldaw Residences. Mr. Favreau was uncertain whether headlights from the second parking level would impact the Moldaw Residences because he did not know the height of Moldaw's podium. Chair Adcock stated that, as a board, they request that the applicant conduct a sectional analysis of their impact. The room was full of neighbors concerned about this development. At the very least, the applicant could provide a sectional study between their building and the adjacent building to illustrate what the board is asking for. Mr. Favreau believed they had the information but it was not included in this plan set. As shown on the elevation, Ms. Ruiz noted a low wall along the Moldaw Residences that prevents headlights from shining into the buildings. In that area, the proposed building is about 35 feet away Item 3 Attachment A - Minutes of August 20, 2026     Packet Pg. 180     Page 28 of 35 Architectural Review Board Meeting Draft Summary Minutes: 8/20/2026 from the Moldaw Residences. Most openings are above the low wall and above the headlights, unless it is a Cybertruck. Board Member Hirsch wondered if the applicant should propose openings that prevent headlights from shining through. Vice Chair Rosenberg emphasized that plantings would dramatically filter the headlights and provide screening. There are various options available. Referring to the floor plan on A1.3, Vice Chair Rosenberg asked whether the applicant considered a larger courtyard in the back, perhaps with the pool, and front- loading the housing toward Fabian. Ms. Majchrzak explained that the previous design was solid across the back with 1 courtyard and more massing at the front, including a narrower courtyard that opened onto Fabian. The plan was reconfigured to create a more open courtyard, reducing shadow on the pool. Mr. Favreau explained that they wanted to keep their active courtyard away from the Moldaw side to protect the privacy of the adjacent building. Mr. Favreau believed Moldaw residents would prefer apartment complexes overlooking them rather than a large open courtyard with a pool and all the activities associated with it. The plan was to create 2 passive courtyards and no units facing the Moldaw residents. Originally, the design included 13 or 14 units with balconies facing Moldaw but the current plan has eliminated that concept. Instead, the rear courtyards are now passive, with the active courtyard on Fabian. Vice Chair Rosenberg inquired whether the applicant asked Moldaw about their preferences or assumed that residents would prefer units across from them rather than a courtyard with a pool. Mr. Favreau responded that they did not discuss this with Moldaw. Board Member Chen thought that having 1 large open space on the Moldaw side made sense. However, they should be careful about putting a pool in that area because of potential noise levels. The proposed project mainly consists of studios and 1-bedroom units. Younger residents' daily schedules may differ from seniors'. Regarding Finding 2 on Packet Page 46, Chair Adcock asked whether the City must prove that a specific adverse impact is occurring to the neighbors or whether the applicant must demonstrate that no specific adverse impact is occurring. The neighbors have submitted letters and presented studies claiming they will experience specific adverse impacts. Chair Adcock asked what responsibility the City or the applicant has to address these claims and whether the City was looking into them. Ms. Raybould stated that the City must demonstrate a significant impact if it intends to deny a requested waiver under that provision of law. The objective standard must be in the law. Emergency response time and fire-access height requirements could be objective standards. To deny the application, there needs to be an objective and quantifiable standard, and the impact must be measurable and have no mitigation measures. City staff are reviewing the questions Chair Adcock raised. If there is a basis to require changes to address an unavoidable health and safety impact, the City will exercise its discretion to do so. Board Member Hirsch asked whether the board should focus on the complaints, such as the daylight concern. Board Member Hirsch recalled that the board has seen other applicants' presentations showing daylight throughout the day in areas adjacent to other buildings and demonstrating shadow lines Item 3 Attachment A - Minutes of August 20, 2026     Packet Pg. 181     Page 29 of 35 Architectural Review Board Meeting Draft Summary Minutes: 8/20/2026 throughout the year. Board Member Hirsch asked whether the applicant should provide those types of drawings to illustrate the daylight descriptions. Mr. Sauls stated that we could address the City's published standard for the daylight plane that is in the objective design standards. However, neither the City's checklist nor the objective design standards require a shadow study. Chair Adcock noted that the ARB has only 1 hearing for this project but the submitted documents are incomplete. The applicant is requesting Waiver 5 to avoid following the daylight plane requirement. However, as part of the waiver request, the applicant provided no supporting study demonstrating that complying with this requirement would reduce a specific number of units. Mr. Sauls noted that the information is included in the packet under the project description provided by the applicant. The applicant submitted a study indicating that following the daylight plane would reduce the project by 30 units. Mr. Sauls shared his screen to display the 30 units that would be lost. Board Member Jojarth saw the project description in the packet but found it to be a vague statement that complying with the daylight plane would reduce the number of units. It does not consider alternative designs that could preserve at least some units while respecting the daylight plane to some extent. Many architectural solutions could address the neighbors' concerns if the applicant held a couple of meetings with them to explore options. Board Member Jojarth thought that the comment about the pool could be a reasonable compromise. While no one may get everything they want, neighbors might prefer a pool even if it is not ideal, as it would at least allow for some daylight. Board Member Jojarth does not believe that the daylight plane would eliminate units because other designs could be considered. Chair Adcock agreed that there were alternative ways to reorganize the building to comply with the daylight plane, respect the neighbors, and still have 273 units. Ms. Majchrzak stated that the waiver requests pertain to the project as designed; they do not consider multiple alternative design options when requesting a waiver. Chair Adcock said that the board can only analyze what the applicant has presented today, along with the waiver requests containing blanket statements. Board Member Chen suggested that the ARB, being the only board in the City that reviews materials, should provide feedback on the material selections before discussing the objective standards. Overall, the building appears to feature dark materials or colors contrasted with very bright white. Board Member Chen asked if the lower portion of the building would be all brick and where the wood selection would be used. Vice Chair Rosenberg inquired about the LRV of the white paint. Ms. Majchrzak explained that the garage façade features a fine-grain brick material wrapping around it, with dark stucco masses on the front. The lighter stucco is recessed on Fabian, with an accent color in the corners. The wood-grain material is used more sparingly as an accent, such as for awnings. A soffit material is used at ground level. At the corner, where there are 2 columns and a 2-story outdoor space in front of the leasing office and lobby, there is a soffit material and wood on its underside, as well as on the underside of the canopy at the entrance bay. Item 3 Attachment A - Minutes of August 20, 2026     Packet Pg. 182     Page 30 of 35 Architectural Review Board Meeting Draft Summary Minutes: 8/20/2026 Board Member Hirsch asked about the façade material at the corner where it turns and steps down, set back from the base of the lobby and exercise area. Ms. Majchrzak referred to Page 2. At the first level, where the sloped head is, the brick material will wrap around from the face of the garage. The brick material will be there along with the wood soffit, and then stucco above that. Given that the entire space is 2 stories high, including the exercise area, Board Member Hirsch questioned using such a heavy element. Board Member Hirsch asked whether it would be possible to use a type of metallic screening instead. The board began discussing the 8 waiver requests. Waiver 1 requests an increase from the 60-foot height limit to 95 feet. Chair Adcock asked if the applicant had considered maintaining a height of at least 60 feet toward the neighboring property. Chair Adcock urged the applicant to conduct a section study to examine the impact of the proposed building’s height on the neighbors. Ms. Majchrzak explained that they initially considered 2 levels of subterranean parking and 5 levels of residences when the project began. However, once issues related to the floodplain and soil contamination were identified, it prevented any ground-floor units. This forced the applicant to elevate the project. Removing 2 levels may render the project unfeasible. Part of it is architectural expression. Board Member Jojarth visually liked the slanted parapet on Charleston or Fabian but it increases the building height. The ARB has reviewed several buildings in this neighborhood and on San Antonio, and the board encourages applicants to use architectural techniques to make the building appear smaller than its actual size. However, in this case, the applicant's approach seems to be the opposite. If the applicant increases the massing on Fabian Way, they can also find ways to make it appear less tall. Vice Chair Rosenberg liked the angles and cohesiveness at JCC's visual corner at Charleston and San Antonio. Most of the concerns regarding height are related to the Moldaw Residences side, rather than the corner. Vice Chair Rosenberg asked whether the applicant had considered respecting the daylight planes, since they already exceed the height limit on the front side. Mr. Sauls clarified that the consideration of waivers was based on the applicant’s request relative to the density and the number of affordable units provided. Ms. Majchrzak stated that the applicant opted for a waiver. They believed that being close and tall in certain areas and pulling it back for the most part would be sufficient. No one commented on Waiver 2. Regarding Waiver 3, Chair Adcock expressed concern that not providing a loading dock on the interior rear-facing façade, as required by the objective standard, could impact safety. Fabian is a busy street and is expected to become even busier. Chair Adcock asked the applicant for their thoughts on the safety impact of placing a loading dock at the turn onto Fabian, especially with schools across the street. Ms. Majchrzak explained that there are no streets behind them, so there is no alternative access. The loading zone was designed primarily for move-ins and move-outs, allowing trucks to back in and exit more safely. Waiver 3 seemed reasonable to Board Member Hirsch. Item 3 Attachment A - Minutes of August 20, 2026     Packet Pg. 183     Page 31 of 35 Architectural Review Board Meeting Draft Summary Minutes: 8/20/2026 Chair Adcock asked whether the staff had any data to support the justification for Waiver 3 and whether the applicant had provided any studies. Mr. Sauls explained that part of the applicant's request to provide a loading dock on the Fabian frontage relates to their claim that a different configuration would require a pull-in drive area, limiting their ability to provide the necessary number of parking spaces on the property, thereby preventing their ability to comply with other City objective standards and precluding construction of this project. The applicant did not provide any diagrams or studies to support this point. The applicant is offering about 20 more parking spaces than required. Waiver number 5 seeks to exceed the daylight plane along the shared interior property line with the Moldaw Residences, starting at 25 feet and at a 45-degree angle. Chair Adcock said the only justification she had seen for Waiver 4 was the drawing showing the angle and the 30-unit reduction. Chair Adcock asked the staff if that was all the applicant needed to prove. Assistant City Attorney Madeleine Salah explained that the City cannot require the applicant to redesign the project to better align with our requirements while theoretically preserving the unit count. Although the statute appears to allow us to deny the waiver if a possible design could maintain the unit count, case law indicates that we cannot require a hypothetical redesign that would sacrifice amenities to preserve the unit count. Ms. Raybould stated that the City would bear the burden of conducting and paying for the study and analysis and hiring someone to evaluate it. Board Member Jojarth suggested that board members include their feedback in their final recommendations. Waiver 4 allows an exemption from providing an upper-floor step back starting within 2 vertical feet of the adjacent building to be on 70 percent of the adjoining front façades of the building as required by the objective design standard. Vice Chair Rosenberg thought that Waiver 4 is related to the daylight plane discussion. The applicant designed the building with straight towers that have no relief and no step back. The applicant is not providing the façade breaks the board typically sees, which relates to Waiver 6; instead, the design features ins and outs. When the applicant requests a waiver, the board may disagree and state that it does not find it necessary. Vice Chair Rosenberg sought clarification on the board's burden of proof. Chair Adcock asked whether the applicant must show how each requested waiver corresponds to a specific number of units being reduced, which was not included in the submitted materials. Mr. Sauls stated that the City bears the burden of proving something is true, which is incredibly complex and resource-intensive given the numerous projects being examined simultaneously. However, the ARB can provide valuable feedback, even though it may not result in many physical changes to the project. Ultimately, state law has framed this conversation such that the City sets standards, applicants may request waivers or concessions from those standards but there is not much of a dialogue. Board Member Hirsch noted a direct conflict between granting a waiver for the alleyway area between the building and the neighboring property and the reasonable request to use the daylight plane on that Item 3 Attachment A - Minutes of August 20, 2026     Packet Pg. 184     Page 32 of 35 Architectural Review Board Meeting Draft Summary Minutes: 8/20/2026 side of the building, where the proposed units will impact the neighbors' light and air. Board Member Hirsch asked how the City could use this to address the neighbors' concerns. Mr. Sauls mentioned that the City currently lacks objective, quantifiable standards for the types of impacts it uses as metrics, making it difficult to develop one under these circumstances, especially since they were not published before the project came in. Daylight planes seem to be a major concern, so Board Member Hirsch urged the developer to consider this very seriously. Waiver 7 is to not provide commercial habitable uses along the 2-story above-grade parking structure as required by the standard. Chair Adcock understood that including commercial space would reduce residential space. Waiver 8 is to not provide 1 on-site short-term passenger loading space for vehicles and/or taxicabs as required. Chair Adcock inquired about the plan for managing services like DoorDash and Uber pickups without a loading zone. There is an additional level of safety needed for the bike route underway. Chair Adcock asked the applicant to share their thoughts on requesting this waiver and how it might affect their unit count. Ms. Majchrzak mentioned that Waiver 8 is being considered for the trash staging solution, making it difficult for her to comment. In the buffer zone where the bike lane was located, the applicant indicated an area for loading and for pickups, drop-offs, and USPS vehicles to park. Ms. Majchrzak also noted that someone could park in the driveway. Mr. Sauls clarified that the proposed moving/loading space Ms. Majchrzak mentioned, where U-Haul, pick-ups, and drop-offs will occur, is sufficient to meet this requirement, eliminating the need for a waiver. Staff told the applicant to keep the side door open during certain hours, possibly during normal business hours, to facilitate Uber and Lyft drop-offs and pick-ups without causing vehicles to queue into the right-of-way. This project does not require a traditional vehicle loading zone; instead, it needs a short-term vehicle stall or space for pick-up and drop-off. The board members shared their final thoughts. Chair Adcock noted that Waiver 5 regarding the daylight plane causes a substantial impact. There are ways to address the neighbors' concerns while still proceeding with the construction of 273 units. Chair Adcock said the board is generally okay with most of the applicant's waiver requests, except for the light impact on the elderly neighbors who are home all day. Chair Adcock urged the applicant to listen to the neighbors' concerns and, if possible, avoid Waiver 5. Board Member Hirsch expressed a few concerns while reviewing the plans. On Page A2.3 and S1, the typical floor loading for people entering the building conflicts with the corridor immediately behind the elevator, so Board Member Hirsch thought the applicant should address it. Aesthetically, Board Member Hirsch appreciated the building's front design; although it lacks intricate details, it effectively breaks up the structure's mass, likening it to the Three Musketeers. The lobby, exercise space, and office areas on the main floor were nicely placed. Repositioning the elevator and stairs was an excellent way to divide functions and entry. The entryway is very appealing. Item 3 Attachment A - Minutes of August 20, 2026     Packet Pg. 185     Page 33 of 35 Architectural Review Board Meeting Draft Summary Minutes: 8/20/2026 Furthermore, Board Member Hirsch thought the building is nicely built out to the street. The loading area is appropriately placed at the garage entrance. Board Member Hirsch wished the applicant could lower the garage, which would allow for a reduction in the overall height of the building, a change he believed was worth exploring the ground issues. Board Member Hirsch suggested the applicant consider whether the building could be cantilevered or columned out at the front so the upper residential floors could extend over the garage's edge. This adjustment might create a visually appealing projection, offering the opportunity to pull it in from the opposite side. It would also help clean up the main corridor running to the back, which currently creates circulation issues. Board Member Hirsch asked whether the building could extend by up to 4 feet. If the compactor could be repositioned to the opposite wall, it would go straight down. The bicycle room is well placed, and the exit to the street is effective. The garbage seems to be fine. Board Member Hirsch asked why the units in the back did not have balconies. Ms. Majchrzak explained that the absence of balconies on the back units was intended to provide neighbors with more privacy by avoiding occupied outdoor space. Board Member Hirsch suggested positioning the balconies at the intersection, similar to the arrangement at the back in the courtyard areas. Mr. Sauls noted that a previous design included balconies but the applicant removed them to avoid needing an additional waiver from the objective design standards. Board Member Hirsch felt that having fresh air in an apartment is nice, so he suggested that the applicant consider operable windows. Board Member Jojarth said the project was well designed; however, it would be worthwhile to scale back the aesthetics and emphasize function and respect for the neighbors. Board Member Jojarth hoped the applicant's experience over the last 5 years would not discourage them from doing business in Palo Alto again. If the applicant could make adjustments that would benefit the neighbors without costing too much money or time, it would be greatly appreciated. The ARB has noticed that, with many Builder's Remedy projects, after applicants come for feedback, even though the City has no legal power to enforce changes, they often incorporate at least some of the board's comments when they return a couple of months later. The board and the Planning Department appreciate this collaborative approach. Board Member Jojarth appealed to the applicant for civility and collaboration, and to do something if possible. Vice Chair Rosenberg acknowledged that the applicant invested significant time and effort in multiple redesigns. However, it is disappointing that the applicant met with the neighbor only once throughout this process. While you are not required to design for your neighbors, it is common practice because architecture is integrative. You relate to neighbors through the scope, scale, and setbacks. More thoughtfulness and consideration could have been applied. As a human being, you can look around this room and see that 70 people are present today because this project is of a profound concern to them. Vice Chair Rosenberg hopes that, as humans and as a company, the architectural team takes these concerns seriously. Regarding Objective Standard 2, site access, trash management, Uber, and Lyft are important, especially on Fabian. The traffic impact matters not just because of the Moldaw Residences, but also because of the middle school down the street where children will be biking. It is critical to consider how vehicles will enter and exit the site, and that ambulances will be coming through 5 times a Item 3 Attachment A - Minutes of August 20, 2026     Packet Pg. 186     Page 34 of 35 Architectural Review Board Meeting Draft Summary Minutes: 8/20/2026 week. This cannot be waived away. This is part of integrating into this city. Therefore, Vice Chair Rosenberg urged the applicant to reassess this aspect. For Objective Standard 3, building orientation and setbacks, another option is available. The applicant can maintain their unit counts while also being more respectful of their neighbors and more accommodating to daylight planes, shading, shadow, and fresh air. The applicant can use their ample frontage on Fabian. The ARB has reviewed many other projects that successfully front-oriented their buildings, so it is feasible. Regarding building massing, Vice Chair Rosenberg thought the courtyards toward the Moldaw Residences could have been pushed further. Vice Chair Rosenberg noted more base-middle-top on the back of the building than the front. The applicant could consider more articulation where the angle is picking up the top on the front side. Vice Chair Rosenberg liked the materials board, describing it as earthy, rich, and warm. Maybe the white is too white, too much of a glare, and is a stark contrast with the dark black. Vice Chair Rosenberg asked the applicant to reconsider the color choices. Architecture is an iterative process, and while trying new approaches can be challenging, it is worthwhile in this instance. Doing so will benefit residents because they will not be staring directly into their neighbors' windows. Vice Chair Rosenberg urged the applicant to carefully review and consider their project. Board Member Chen acknowledged the improvements from previous versions of the proposal. Board Member Chen thanked the public for attending and sharing their thoughts and concerns. Board Member Chen expressed appreciation for many features of the proposed design, such as the provided amenities and the courtyards designed to break up the building's massing and set certain areas farther from neighbors. From the elevations, Board Member Chen appreciated the angled parapet wall at the top of the building, noting that it echoed the sloping brick wall at street level and contributed to an attractive and inviting building corner. Board Member Chen raised concerns about the material choices. When driving along the street, the building's proximity to the corner makes it appear as several dark black towers, so Board Member Chen suggested adding more warmth to the building. Although Board Member Chen liked the site plan overall and supports housing projects, she believes the proposed density of nearly 300 units is too much for this site, given the existing conditions, existing context, and neighboring tenants. Traffic and other public safety issues are significant concerns for the entire community. Although it is a good location for housing, the density and number of units are excessive for this location. Chair Adcock thank the community for attending and expressing their concerns. APPROVAL OF MINUTES 4. Draft Architectural Review Board Meeting Minutes for July 16, 2026 Administrative Associate Samuel Tavera confirmed that everyone attended the July 16 meeting, so no one needed to abstain. MOTION: Vice Chair Rosenberg moved to approve the minutes as written. Chair Adcock seconded the motion. VOTE: Motion carried 5-0. Item 3 Attachment A - Minutes of August 20, 2026     Packet Pg. 187     Page 35 of 35 Architectural Review Board Meeting Draft Summary Minutes: 8/20/2026 VIRTUAL PUBLIC COMMENT None. BOARD MEMBER QUESTIONS, COMMENTS, ANNOUNCEMENTS OR FUTURE MEETINGS AND AGENDAS Vice Chair Rosenberg is 1 of the 6 architects whose homes will be featured on the AIA Home Tour on Saturday, September 19th. Chair Adcock encouraged the board to purchase their tickets to attend the event. ADJOURNMENT Chair Adcock adjourned the meeting at 1:28 p.m. Item 3 Attachment A - Minutes of August 20, 2026     Packet Pg. 188     Item No. 4. Page 1 of 1 Architectural Review Board Staff Report From: Planning and Development Services Director Lead Department: Planning and Development Services Meeting Date: October 15, 2026 Report #: 2610-6852 TITLE Draft Architectural Review Board Meeting Minutes for September 3, 2026 RECOMMENDATION Staff Recommends the Architectural Review Board (ARB) adopt the meeting minutes ATTACHMENTS Attachment A: Minutes of September 3, 2026 AUTHOR/TITLE: ARB Liaison1 & Contact Information   Steven Switzer, Senior Historic Planner   (650) 329-2321   Steven.Switzer@PaloAlto.gov 1 Emails can be sent directly to the ARB at the following email: ARB@PaloAlto.gov Item 4 Item 4 Staff Report     Packet Pg. 189     Page 1 of 4 Architectural Review Board Meeting Draft Summary Minutes: 9/3/26 ARCHITECTURAL REVIEW BOARD MEETING DRAFT MINUTES: September 3, 2026 Council Chamber & Zoom 8:30 a.m. CALL TO ORDER / ROLL CALL Present: Chair Mousam Adcock, Vice Chair Kendra Rosenberg, Board Member David Hirsch, Board Member Yingxi Chen Absent: Board Member Marton Jojarth Chair Adcock welcomed all to the meeting. The clerk called roll and declared there was a quorum. AGENDA CHANGES, ADDITIONS AND DELETIONS Senior Historic Planner Steven Switzer stated no changes were planned. IN-PERSON PUBLIC COMMENT None. CITY OFFICIAL REPORTS 1. Director’s Report, Meeting Schedule, and Upcoming Agenda Items Mr. Switzer announced that a new project submitted was a Tier 2 Wireless Communication Facility with review of 3 poles that would be having some upgrades with AT&T. There would be a Boards & Commissions recognition event at Lucie Stern Community Center on September 26 and a Council Approval of Workplans on October 5. The next meeting on September 17 would address a Master Sign Program. The remaining 2026 meeting schedule was presented on a slide. Planned absences should be directed to staff. Chair Adcock suggested showing the schedule for the following year and noted she would have an expected absence in February. Mr. Switzer said they would add some tentative dates in the next packet. Chair Adcock thought the Boards & Commissions recognition event would be at the Junior Museum & Zoo rather than Lucie Stern. After double checking, Mr. Switzer confirmed it would be at the Junior Museum & Zoo. ACTION ITEMS 2. : PUBLIC HEARING / QUASI-JUDICIAL. 180 El Camino Real [26PLN-00186]: Recommendation on Applicant’s Request for a Minor Board-Level Architectural Review to Allow Storefront Item 4 Attachment A - Minutes of September 3, 2026     Packet Pg. 190     Page 2 of 4 Architectural Review Board Meeting Draft Summary Minutes: 9/3/26 Modifications Including Refinishing Façade and New Signage for a Relocated Tenant, Victoria’s Secret (Building C, Space #16B), at the Stanford Shopping Center. CEQA Status: Exempt per CEQA Section 15301 (Existing Facilities). Zoning District: CC (Community Commercial) Chair Adcock noted that the recommendation from staff is to approve the proposed project and recommend for the Director of Planning and Development Services to approve. Associate Planner Nishita Kandikuppa presented the project, noting the existing tenant is Peloton and the new tenant would be Victoria's Secret. The project needs to comply with the Master Tenant Façade & Sign Program. She showed a map of the shopping center, including the project site on the east side. Since the tenant space frontage is greater than 35 ft, it requires Board-level ARB review. The project description includes refinishing the existing façade to accommodate the new relocated tenant, Victoria's Secret. The previous tenant space was in Building CC, Space #1220, which was inferior facing. The new tenant space will be exterior facing in Building C, Suite #16B. The existing glazing/mullion system, entry doors, and illuminated portal frame will be reused and repainted. The new signage will reflect the new tenant. She showed a daytime view of the proposed façade modifications and the materials that would be used, as well as a nighttime rendering with lighting. The staff report indicated 3 proposed signs, but that was an error. Only 2 signs were proposed, an illuminated wall sign with edge-lit characters and a non-illuminated blade sign, which is required. They are both on the east elevation and consistent with the Palo Alto sign code as well as the requirements within the Master Façade & Sign Program. There is also a proposed digital display, which is actually a static image within a lightbox. These signs are considered display signage and don't have restrictions within the Master Façade Program. If it had an LED display, there would be restrictions. Advertisement signs and graphic signs are regulated differently from television displays. Ms. Kandikuppa asserted that the project shall comply with the ARB findings, which were included in the staff report, the Master Façade Program, the City's sign regulations under Chapter 16.20, and the context-based design criteria, which was also included in the staff report. The staff recommends that the ARB recommend approval of the proposed project to the Director of Planning and Development Services based on findings and subject to conditions of approval. Alternatively, the ARB may approve the project with modified findings and conditions, continue the project to a date uncertain with specific direction, or recommend project denial based on revised findings. Jason Smith, Owner/Operations Director at Landshark Development Services Group, greeted the group and introduced Devin Wood to proceed with the presentation. Devin Wood, Store Designer at VS&Co, said the design is intended to feel elevated and feminine while maintaining the sophistication and timelessness of the Victoria's Secret brand. The primary façade is finished in an iridescent finish that gives the storefront a subtle pearl quality and creates dimension and sparkle as the light changes throughout the day. They also get extra presence from reusing the previous tenant's LED lighting, and the iridescence of the storefront provides a soft effect that adds a luxury feel to the façade. This clean, monolithic façade allows the VS logo to remain the main focal point while the black framing creates a contrast that gives the storefront more presence. The finish is exterior and interior rated, and they have never had complaints about durability. It is the same material used at top- line exterior centers. As they were designing the storefront, they determined that the existing tenant's storefront and LED light had the same proportions as their design intent and was waterproof, so there was no waste of material or labor. They will apply the finish on top of the previous tenant's finish. Item 4 Attachment A - Minutes of September 3, 2026     Packet Pg. 191     Page 3 of 4 Architectural Review Board Meeting Draft Summary Minutes: 9/3/26 Vice Chair Rosenberg thanked Ms. Kandikuppa and Mr. Smith and asked for more detail about the exterior metal frame and its dimensions. She asked if they planned to powder coat the metal perimeter, to which Ms. Wood answered yes. Chair Adcock questioned the front-face dimension, which Ms. Wood clarified was 3 inches. Chair Adcock asked if there was a thickness to one of the materials and whether it would be over the plaster finish. She asked if it was a thin metal or a composite metal. Ms. Wood answered that it was a thin metal. Chair Adcock showed a sample of the plaster finish and asked if there were joints necessary at the corners. Ms. Wood answered that no joints were required on the face of the storefront and that it would be a smooth finish. Chair Adcock asked if there was any concern about cracking for the large center panel. Ms. Wood said there were no concerns with cracking and asked Joe Webber if there was anything he could add. Joe Webber, Senior Project Manager at VS&Co, said they have used the finish over larger expanses and have had no problem. There are no expansion joints within the system. He said they would power wash the existing tile, apply a bonding agent, and then the whole façade would be covered with a fiberglass mesh. Then the finishing product would be applied over that. Chair Adcock asked if they typically layer new finishes on top of old finishes. Mr. Webber said it's on a case-by-case basis, and there was no reason to have the old finish removed in this case. Board Member Chen was in favor of the project. She appreciated that the applicant could reuse most of the existing structures and she liked the materials selected. Vice Chair Rosenberg echoed what Board Member Chen said. She thought it was simple and elegant and made the brand stand out. She thought reusing the LED portal was clever and she appreciated the metal banding around the perimeter. She echoed Chair Adcock's sentiments about the layering but thought it was a reasonable request considering that removing the tile could compromise the waterproofing. Board Member Hirsch noted that he was around for the first project and thought this project adds to it. The lettering is even better proportioned. As long as they watch the construction and make sure the façade is smooth and clean, he thought it would be an improvement. He liked the white material and the contrast and was in favor of the project. Chair Adcock expressed appreciation for the presentation. She supported the comments from the Board and thought it was a simple, elegant solution. PUBLIC COMMENT None. MOTION: Vice Chair Rosenberg moved to approve the project as designed and presented, seconded by Board Member Hirsch. VOTE: Motion carried, 4-0 (Board Member Chen, Board Member Hirsch, Vice Chair Rosenberg, Chair Adcock). APPROVAL OF MINUTES 3. Draft Architectural Review Board Meeting Minutes for August 6, 2026 Item 4 Attachment A - Minutes of September 3, 2026     Packet Pg. 192     Page 4 of 4 Architectural Review Board Meeting Draft Summary Minutes: 9/3/26 Chair Adcock asked if there were comments or corrections to the minutes of August 6. Vice Chair Rosenberg said she had some comments on the minutes and questioned if they could email them ahead of time or if it would be better to do them during the hearings. Mr. Switzer said both were acceptable but emailing is easier for staff. Vice Chair Rosenberg wanted a correction on Packet Page 46 to the phrase "they should take up the responsibility." She said the City should not be responsible. Mr. Switzer said they could review and revise the record. Vice Chair Rosenberg wanted a correction on Packet Page 53 to the phrase "if such a scenario was likely to happen." She thought it was supposed to say "unlikely to happen." Mr. Switzer noted the correction. Board Member Hirsch asked if there was any method for notification for the location of the daycare facilities. Chair Adcock noted that was not an agenda item. Board Member Hirsch said it was in relation to comments on the specifics of the language. Mr. Switzer said it is regulated by size. if it meets one of the qualifying factors based on size or number of children, it would require a city permit or a state permit. He would be happy to take up the issue offline. Board Member Hirsch agreed, as he wanted to finish the discussion. Vice Chair Rosenberg moved to approve the minutes as written with the 2 minor adjustments. Board Member Chen seconded the motion. Motion passed 4-0 by roll call vote. VIRTUAL PUBLIC COMMENT None. BOARD MEMBER QUESTIONS, COMMENTS, ANNOUNCEMENTS, OR FUTURE MEETINGS AND AGENDAS None. ADJOURNMENT Chair Adcock adjourned the meeting at 9:03 a.m. Item 4 Attachment A - Minutes of September 3, 2026     Packet Pg. 193     Item No. 2. Page 1 of 1 Architectural Review Board Supplemental Report From: Planning and Development Services Director Lead Department: Planning and Development Services Meeting Date: October 15, 2026 Report #: 2610-6872 TITLE PUBLIC HEARING / QUASI-JUDICIAL. 250 Hamilton Avenue [26PLN-00229]. Request by AT&T for Review of Two Tier 2 General Wireless Communication Facilities to Collocate New Antennas, Remote Radio Units (RRUs), Seven-Foot Fiberglass Pole Extensions and Associated Equipment on Existing City-Owned Wood Utility Poles in the Public Right-of Way (ROW) Near 670 Guinda Street and 754 Homer Avenue. CEQA Status: Exempt Pursuant to California Environmental Quality Act (CEQA) Guideline Section 15301 (Existing Facilities). Zoning District: Not Applicable (Public ROW). This supplemental report conveys a summary of comments received by the applicant at the community meeting they hosted on August 25, 2026 (Attachment A) and additional public comments received by the City between the publication of the staff report (Report #: 2608- 6703) for the above referenced project on October 8, 2026, and noon on October 14, 2026 (Attachment B). ATTACHMENTS Attachment A: August 25, 2026, Community Meeting Comment Summary Attachment B: Additional Public Comments Received Before 12:00 p.m. on October 14, 2026 APPROVED BY Claire Raybould, AICP, Manager, Current Planning Item 2 Item 2 Supplemental Staff Report     Packet Pg. 194     NextEdge Networks Holdings LLC | on behalf of AT&T Mobility 26PLN-00229 Community Meeting Comment Summary | Page 1 of 6 October 8, 2026 Nishita Kandikuppa, Associate Planner Planning and Development Services City of Palo Alto 250 Hamilton Avenue Palo Alto, CA 94301 RE: Community Meeting Comment Summary, Application 26PLN-00229 Response to Notice of Incomplete dated September 10, 2026, Planning comment: summary of comments received at the community meeting Site Location CPAU Pole CRAN_RSFR_PALO4_004 Near 804 Boyce Avenue (withdrawn; new location under search) 5919 CRAN_RSFR_PALO4_005 Near 670 Guinda Street at Forest Avenue 6023 CRAN_RSFR_PALO4_006 Near 754 Homer Avenue 6010 Dear Ms. Kandikuppa: Purpose NextEdge Networks Holdings LLC, authorized agent for New Cingular Wireless PCS, LLC dba AT&T Mobility (AT&T), submits this summary of the community meeting AT&T hosted on Tuesday, August 25, 2026. It responds to the Planning comment in the City's Notice of Incomplete dated September 10, 2026, which identified the community meeting comment summary as incomplete. The City has marked the community meeting notice and affidavit of mailing received and complete. Per PAMC Section 18.42.110(d)(7) and page 7 of the Tier 2 WCF Submittal Requirements Checklist, this letter provides: • Proof that AT&T hosted the meeting, through the sign-in sheets transcribed below and enclosed; • A summary of comments received at the meeting, with AT&T's response to each; and • A statement of any changes made to the application as a result of the meeting. Item 2 Attachment A - August 25, 2026, Community Meeting Comment Summary     Packet Pg. 195     NextEdge Networks Holdings LLC | on behalf of AT&T Mobility 26PLN-00229 Community Meeting Comment Summary | Page 2 of 6 Meeting record AT&T hosted the meeting as noticed. Eight neighbors signed in, and 1 submitted a written comment card. Item Detail Date and time Tuesday, August 25, 2026, 6:00 PM to 8:00 PM Location 555 University Avenue, Palo Alto, CA 94301 Notice mailed August 6, 2026, 19 days before the meeting Notice radius 600 feet from each proposed facility Notice recipients 709 total: PALO4_004, 228; PALO4_005, 191; PALO4_006, 290 Mailing agent Express Notice and Mail LLC, with notarized Declaration of Mailing AT&T representatives 5, listed below Format AT&T representatives answered neighbors' questions in person throughout the meeting Attendance 8 signed in; approximately 8 to 12 people attended over the course of the evening Written comments 1 comment card, unsigned The following representatives attended on behalf of AT&T: Name Role Tasha Stack NextEdge Networks, on behalf of AT&T Mobility Marc Grabisch Small Cell Program Lead, AT&T Mobility Courtney Perillo Market Director, AT&T Mobility Vernon Ponio RAN Design Engineer, AT&T Mobility David Witkowski Founder and CEO, Oku Solutions LLC; engineer and EME subject matter expert. Chair, Deployment Working Group, IEEE Future Networks; Secretary, Committee on Man and Radiation, IEEE EMBS; Member, International Committee on Electromagnetic Safety, IEEE-SA; Member, RF Safety Committee, ARRL Item 2 Attachment A - August 25, 2026, Community Meeting Comment Summary     Packet Pg. 196     NextEdge Networks Holdings LLC | on behalf of AT&T Mobility 26PLN-00229 Community Meeting Comment Summary | Page 3 of 6 The City separately received 3 email comments on August 19, 2026, before the meeting. Staff responded to each, and those comments are already in the City's record. Sign-in record Eight attendees from 6 households on Boyce Avenue and Guinda Street signed in across 3 sheets. # Name, as written Address, as written Sheet 1 Jim Wang 820 Boyce Avenue 1 2 Bernard Gifford 842 Guinda Street 1 3 Bob Wedemeyer 827 Guinda Street 1 4 Teresa Flagg 804 Boyce Avenue 1 5 Lyn Chambers 811 Guinda Street 1 6 Doris Ann Girard 808 Boyce Avenue 2 7 Melinda Wedemeyer 827 Guinda Street 3 8 Denis Tim Flagg 804 Boyce Avenue 3 Names are transcribed as handwritten. Entry 1 may also read "Wans." The sheets listed telephone numbers as optional; those numbers are omitted here. The original sheets are enclosed. Written comment card One comment card was submitted. It bears no name, address, or signature. The text, transcribed verbatim: Do not like or want any of these cell antennas. The coverage is already good and this is not needed. Verizon added an antenna near the corner of Channing and Middlefield and hasn't needed additional antennas in this area. The new antennas appear to cover areas to the east while new antennas should be located east and not 804 Boyce and west. Visual blight results to 804 Boyce and neighborhood, especially 2nd floor of 804 Boyce. The card raises 3 concerns. AT&T's response to each follows. Concern AT&T response Need. Coverage is already good; a Verizon antenna at Channing Avenue and Middlefield Road has met demand in the area. AT&T's Radio Frequency Statements and existing and proposed coverage maps, filed for each site, document the gap in AT&T service these facilities are designed to close. Verizon operates a separate network, and its facilities do not carry AT&T customer traffic. See item 7 below. Item 2 Attachment A - August 25, 2026, Community Meeting Comment Summary     Packet Pg. 197     NextEdge Networks Holdings LLC | on behalf of AT&T Mobility 26PLN-00229 Community Meeting Comment Summary | Page 4 of 6 Concern AT&T response Location. The facilities should be placed farther east, not at 804 Boyce Avenue and to the west. AT&T has withdrawn PALO4_004 near 804 Boyce Avenue from this application and is searching for a new candidate location. See item 2 below. Any new location will be evaluated against the same criteria: proximity to the center of the coverage gap, structure height, line of sight, separation from adjacent nodes, and host-pole feasibility under CPUC General Order 95. Visual impact. The facility creates visual blight for 804 Boyce Avenue and the neighborhood, especially from the second floor of 804 Boyce. With PALO4_004 withdrawn, no facility is proposed at 804 Boyce Avenue. PALO4_005 and PALO4_006 collocate on existing City of Palo Alto Utilities wood poles and require zero new or replacement poles. Each antenna mounts on a pole-top extension, and the radio equipment is enclosed in a single shroud finished to match the pole. Photographic simulations are in the application, and the Architectural Review Board will review the design at a public hearing. Questions and concerns raised at the meeting Neighbors raised approximately 7 questions and concerns. AT&T representatives responded to each in person. The responses below summarize those answers and add detail from the application record where helpful. 1. Why the pole near 804 Boyce Avenue was selected Raised: Neighbors asked why AT&T chose the existing wood pole near 804 Boyce Avenue for PALO4_004. AT&T response: AT&T selected the pole to close a gap in AT&T service in the surrounding neighborhood. The facility would improve service for AT&T customers at home and on the street, and provide continuous coverage for customers driving through the area. Site selection followed the criteria in AT&T's Radio Frequency Statement: proximity to the center of the coverage gap, height above surrounding obstructions, line of sight across the gap, separation from adjacent nodes, and feasibility on the host pole under CPUC General Order 95. 2. Whether PALO4_004 can move farther west Raised: Neighbors asked whether AT&T could relocate PALO4_004 farther west. AT&T response: AT&T took the request seriously and evaluated it after the meeting. AT&T has withdrawn PALO4_004 near 804 Boyce Avenue from this application and is actively locate to redesign the network node location and search for a new candidate location. Any new location will be submitted for City review, with notice to neighbors as the Municipal Code requires. 3. Radio frequency emissions Raised: Neighbors asked about radio frequency (RF) emissions from the facilities. AT&T response: David Witkowski, engineer and EME subject matter expert, addressed this concern on behalf of AT&T, referring to the EME reports filed with the application. MobileComm prepared a Radio Item 2 Attachment A - August 25, 2026, Community Meeting Comment Summary     Packet Pg. 198     NextEdge Networks Holdings LLC | on behalf of AT&T Mobility 26PLN-00229 Community Meeting Comment Summary | Page 5 of 6 Frequency Safety Survey Report for each site. Maximum predicted exposure at ground level is 1.00 to 1.04 percent of the FCC general population limit across the 3 sites. At the nearest building, it is 3.64 percent at PALO4_004, 1.83 percent at PALO4_005, an d 1.75 percent at PALO4_006. The general public boundary extends 18 feet horizontally from the antenna and 5 feet below the antenna canister. The antenna sits about 52 feet above grade, so no publicly accessible location falls inside that boundary. Under 47 U.S.C. Section 332(c)(7)(B)(iv), the City may not regulate the placement of facilities on the basis of RF emissions that comply with FCC rules. 4. Noise Raised: Neighbors asked about noise, citing older AT&T installations. AT&T response: AT&T addressed noise at these specific facilities, as documented in Section V of the application cover letter. Unlike installations that use equipment cabinets with air conditioning or exhaust fans, these facilities use passive natural cooling. They include no air conditioners, generators, compressors, or cabinet exhaust fans, and the antenna is silent. The only moving parts are small cooling fans built into the radio units, which adjust to outdoor temperature. At night, the equipment adds 0.11 decibels to ambient sound, which is not perceptible. At typical peak summer temperatures, the facility operates 14 decibels below the limit in PAMC Section 9.10.050 and meets the stricter standard in Section 9.10.030. AT&T accepts a standard condition of approval requiring ongoing compliance with PAMC Chapter 9.10. 5. Property values Raised: Neighbors expressed concern about the effect of the facilities on home values. AT&T response: AT&T understands that neighbors want to protect the value of their homes. Reliable wireless service is now part of what buyers expect from a home, alongside power, water, and broadband. In 2022, 25 percent of Bay Area workers primarily worked from home (Bay Area Council Economic Institute, from U.S. Census Bureau 2022 American Community Survey ). In Palo Alto's technology economy, and in professions from healthcare to law, finance, and education, remote and hybrid work depend on dependable coverage at home. Video meetings, secure sign-in codes, and calls on the move all run over the wireless network. In a national RootMetrics survey of 2,000 adults, 76 percent said a good mobile signal is very or somewhat important when buying or renting a home, compared with 60 percent for school districts (GeekWire, June 2015). Coverage also matters in an emergency. The FCC notes that for many Americans, the ability to call 911 is one of the main reasons they own a wireless phone (FCC, 911 Wireless Services). These facilities are designed to bring that reliability to AT&T customers in this neighborhood, including future buyers. 6. Additional carriers on the same pole Raised: Neighbors were concerned that other wireless carriers would add equipment to the same poles. AT&T response: AT&T explained that each of these poles supports one carrier's facility. CPUC General Order 95 requires minimum clearances between wireless equipment and the power and communication lines on a pole. The antenna sits on a 7-foot pole-top extension to keep at least 6 feet from the energized primary conductors, and the communication lines below require their own 2-foot safety zone. Item 2 Attachment A - August 25, 2026, Community Meeting Comment Summary     Packet Pg. 199     NextEdge Networks Holdings LLC | on behalf of AT&T Mobility 26PLN-00229 Community Meeting Comment Summary | Page 6 of 6 Together, these clearances leave space for one carrier's antenna and equipment, which AT&T's facility occupies. Any future attachment to these City-owned poles would also require the City's approval as pole owner. 7. Sharing equipment with Verizon Raised: Neighbors asked why AT&T cannot share Verizon's network equipment instead of installing its own. AT&T response: AT&T and Verizon operate separate networks on different radio frequencies, each licensed by the FCC to that carrier. Each carrier's radios transmit on that carrier's licensed frequencies and connect to its own core network. Verizon's equipment does not carry AT&T customer traffic, and AT&T's equipment does not carry Verizon's. Each carrier also places sites to close gaps in its own network. AT&T's Alternative Site Analysis found no existing wireless facility within the coverage objective at a position that would close AT&T's gap. AT&T instead proposes to collocate on existing City-owned poles, the approach PAMC Section 18.42.110(a) prefers. Changes to the application As a result of neighbor comments at the meeting, AT&T has withdrawn PALO4_004, near 804 Boyce Avenue, from this application and is searching for a new candidate, and possibly relocating the search ring. The PALO4_004 sign-in entries and comments remain part of this meeting record. AT&T made no changes to the location or design of PALO4_005 or PALO4_006 as a result of the meeting. Revisions in this resubmittal respond to the City's Notice of Incomplete dated September 10, 2026. AT&T thanks the neighbors who attended and looks forward to the Architectural Review Board hearing. Please direct any question on this summary to the undersigned. Respectfully submitted, Tasha Stack Contractor, NextEdge Networks Holdings LLC Authorized agent for New Cingular Wireless PCS, LLC dba AT&T Mobility 415-770-8404 | tasha.stack@nextedgenetworks.com Enclosure: AT&T Community Meeting Sign-In Sheets (3 pages) and Comment Card (1 page), August 25, 2026 Item 2 Attachment A - August 25, 2026, Community Meeting Comment Summary     Packet Pg. 200     From:Mary Dimit To:Architectural Review Board Cc:Council, City; Clerk, City Subject:Support Palo Alto Residents over AT&T Date:Wednesday, October 14, 2026 3:02:23 AM To ARB members Adcock, Rosenberg, Chen, Hirsch, and Jojarth, Please support the wishes Palo Alto residents as well as City Council when they transferred the review for new cell towers to the Architectural Review Board (ARB) last year. At that time, the City Council supported meaningful setbacks (much more than the original 20-ft rule) from homes. In addition, they wanted the locations & appearance of the cell tower to comply with the provisions of Palo Alto’s Municipal Code including the aesthetic judgments of the ARB. We request you require AT&T abide by the provisions of our Municipal Code and your own aesthetic judgement, as well as the direction from our unanimous City Council to: Locate its cell towers farther from residents’ homes, Locate radios and ancillary equipment underground instead of on the poles, and Lower the height of the poles. Please support the wishes of Palo Alto residents over AT&T. Thank you for your service to Palo Alto, Mary Dimit & Mark Sauer Neighbors who live near two of the proposed cell towers Item 2 Attachment B - Additional Public Comments Received Before 1200p.m. on October 14, 2026     Packet Pg. 201     Item 2 Attachment B - Additional Public Comments Received Before 1200p.m. on October 14, 2026     Packet Pg. 202     Item 2 Attachment B - Additional Public Comments Received Before 1200p.m. on October 14, 2026     Packet Pg. 203     Item 2 Attachment B - Additional Public Comments Received Before 1200p.m. on October 14, 2026     Packet Pg. 204     Nate Saal 10/14/26, 10:58 AM Inbox - Kandikuppa, Nishita - Outlook https://outlook.office.com/mail/inbox/id/AAQkADVmNWM1NDcyLWQ5YzYtNGI5OS05YmZkLTk0MjdlMmI5OWIwMQAQAFK9J%2BcXPbZEi243jmQj0b…2/2 Item 2 Attachment B - Additional Public Comments Received Before 1200p.m. on October 14, 2026     Packet Pg. 205     Item 2 Attachment B - Additional Public Comments Received Before 1200p.m. on October 14, 2026     Packet Pg. 206     Item 2 Attachment B - Additional Public Comments Received Before 1200p.m. on October 14, 2026     Packet Pg. 207     Item 2 Attachment B - Additional Public Comments Received Before 1200p.m. on October 14, 2026     Packet Pg. 208     Item 2 Attachment B - Additional Public Comments Received Before 1200p.m. on October 14, 2026     Packet Pg. 209     Thank you for your leadership. Daniel and Jennifer Orr 3030 Cowper St., Palo Alto 10/14/26, 10:49 AM Inbox - Kandikuppa, Nishita - Outlook https://outlook.office.com/mail/id/AAQkADVmNWM1NDcyLWQ5YzYtNGI5OS05YmZkLTk0MjdlMmI5OWIwMQAQAEOcRmk1Ckfbsa9cOWNrnuE%3D/…2/2 Item 2 Attachment B - Additional Public Comments Received Before 1200p.m. on October 14, 2026     Packet Pg. 210     Item 2 Attachment B - Additional Public Comments Received Before 1200p.m. on October 14, 2026     Packet Pg. 211     Item 2 Attachment B - Additional Public Comments Received Before 1200p.m. on October 14, 2026     Packet Pg. 212     Item 2 Attachment B - Additional Public Comments Received Before 1200p.m. on October 14, 2026     Packet Pg. 213     Item 2 Attachment B - Additional Public Comments Received Before 1200p.m. on October 14, 2026     Packet Pg. 214       Thank you for your consideration. Sincerely, Michael Fallon 10/14/26, 10:53 AM Inbox - Kandikuppa, Nishita - Outlook https://outlook.office.com/mail/id/AAQkADVmNWM1NDcyLWQ5YzYtNGI5OS05YmZkLTk0MjdlMmI5OWIwMQAQAAVbWFG8xEzspko6iaks9SM%3D/s…2/2 Item 2 Attachment B - Additional Public Comments Received Before 1200p.m. on October 14, 2026     Packet Pg. 215     Item 2 Attachment B - Additional Public Comments Received Before 1200p.m. on October 14, 2026     Packet Pg. 216     require AT&T to site its cell towers further from residents’ homes, to locate radios and ancillary equipment underground and to lower the height of the poles.   Thank you for your consideration. Sincerely, Sheree 10/14/26, 10:53 AM Inbox - Kandikuppa, Nishita - Outlook https://outlook.office.com/mail/id/AAQkADVmNWM1NDcyLWQ5YzYtNGI5OS05YmZkLTk0MjdlMmI5OWIwMQAQAAVbWFG8xEzspko6iaks9SM%3D/s…2/2 Item 2 Attachment B - Additional Public Comments Received Before 1200p.m. on October 14, 2026     Packet Pg. 217     Item 2 Attachment B - Additional Public Comments Received Before 1200p.m. on October 14, 2026     Packet Pg. 218     Item 2 Attachment B - Additional Public Comments Received Before 1200p.m. on October 14, 2026     Packet Pg. 219     Nate Saal 10/14/26, 10:51 AM Inbox - Kandikuppa, Nishita - Outlook https://outlook.office.com/mail/id/AAQkADVmNWM1NDcyLWQ5YzYtNGI5OS05YmZkLTk0MjdlMmI5OWIwMQAQAEOcRmk1Ckfbsa9cOWNrnuE%3D/…2/2 Item 2 Attachment B - Additional Public Comments Received Before 1200p.m. on October 14, 2026     Packet Pg. 220     Item 2 Attachment B - Additional Public Comments Received Before 1200p.m. on October 14, 2026     Packet Pg. 221     Item 2 Attachment B - Additional Public Comments Received Before 1200p.m. on October 14, 2026     Packet Pg. 222     Item 2 Attachment B - Additional Public Comments Received Before 1200p.m. on October 14, 2026     Packet Pg. 223     Item 2 Attachment B - Additional Public Comments Received Before 1200p.m. on October 14, 2026     Packet Pg. 224     Palo Alto Resident 10/14/26, 10:51 AM Inbox - Kandikuppa, Nishita - Outlook https://outlook.office.com/mail/id/AAQkADVmNWM1NDcyLWQ5YzYtNGI5OS05YmZkLTk0MjdlMmI5OWIwMQAQAEOcRmk1Ckfbsa9cOWNrnuE%3D/…2/2 Item 2 Attachment B - Additional Public Comments Received Before 1200p.m. on October 14, 2026     Packet Pg. 225     Item 2 Attachment B - Additional Public Comments Received Before 1200p.m. on October 14, 2026     Packet Pg. 226     Item 2 Attachment B - Additional Public Comments Received Before 1200p.m. on October 14, 2026     Packet Pg. 227     -- lynn hollyn 1   10/14/26, 11:09 AM Inbox - Kandikuppa, Nishita - Outlook https://outlook.office.com/mail/id/AAQkADVmNWM1NDcyLWQ5YzYtNGI5OS05YmZkLTk0MjdlMmI5OWIwMQAQAIgbCyXwp0J1iP5HmZXbpic%3D/sx…2/2 Item 2 Attachment B - Additional Public Comments Received Before 1200p.m. on October 14, 2026     Packet Pg. 228     Item 2 Attachment B - Additional Public Comments Received Before 1200p.m. on October 14, 2026     Packet Pg. 229     Item 2 Attachment B - Additional Public Comments Received Before 1200p.m. on October 14, 2026     Packet Pg. 230     Item 2 Attachment B - Additional Public Comments Received Before 1200p.m. on October 14, 2026     Packet Pg. 231     Item 2 Attachment B - Additional Public Comments Received Before 1200p.m. on October 14, 2026     Packet Pg. 232     Item 2 Attachment B - Additional Public Comments Received Before 1200p.m. on October 14, 2026     Packet Pg. 233     Item 2 Attachment B - Additional Public Comments Received Before 1200p.m. on October 14, 2026     Packet Pg. 234     Item 2 Attachment B - Additional Public Comments Received Before 1200p.m. on October 14, 2026     Packet Pg. 235     Sincerely, Amy Kacher  Dana Ave  hey, we are all just people 10/14/26, 11:07 AM Inbox - Kandikuppa, Nishita - Outlook https://outlook.office.com/mail/id/AAQkADVmNWM1NDcyLWQ5YzYtNGI5OS05YmZkLTk0MjdlMmI5OWIwMQAQAIgbCyXwp0J1iP5HmZXbpic%3D/sx…2/2 Item 2 Attachment B - Additional Public Comments Received Before 1200p.m. on October 14, 2026     Packet Pg. 236     Item 2 Attachment B - Additional Public Comments Received Before 1200p.m. on October 14, 2026     Packet Pg. 237     Item 2 Attachment B - Additional Public Comments Received Before 1200p.m. on October 14, 2026     Packet Pg. 238     directly affected. Thank you for your time, consideration, and commitment to preserving the character of Palo Alto’s residential neighborhoods. All best, Marianne Jacobi 10/14/26, 11:08 AM Inbox - Kandikuppa, Nishita - Outlook https://outlook.office.com/mail/id/AAQkADVmNWM1NDcyLWQ5YzYtNGI5OS05YmZkLTk0MjdlMmI5OWIwMQAQAIgbCyXwp0J1iP5HmZXbpic%3D/sx…2/2 Item 2 Attachment B - Additional Public Comments Received Before 1200p.m. on October 14, 2026     Packet Pg. 239     Item 2 Attachment B - Additional Public Comments Received Before 1200p.m. on October 14, 2026     Packet Pg. 240     Item 2 Attachment B - Additional Public Comments Received Before 1200p.m. on October 14, 2026     Packet Pg. 241     Item 2 Attachment B - Additional Public Comments Received Before 1200p.m. on October 14, 2026     Packet Pg. 242     Tellingly, in restoring ARB review, City Council unanimously expressed a preference for a significant setback from homes. This stands in sharp contrast to the twenty- foot rule that existed in the now defunct “objective standards” ordinance. I am writing to urge you to insist that AT&T respect the provisions of our Municipal Code and your own aesthetic judgement, as well as the wishes of our unanimous City Council. In particular, please require AT&T to site its cell towers further from residents’ homes, to locate radios and ancillary equipment underground and to lower the height of the poles. Thank you for your consideration. Sincerely, [Your Name] 10/14/26, 11:09 AM Inbox - Kandikuppa, Nishita - Outlook https://outlook.office.com/mail/id/AAQkADVmNWM1NDcyLWQ5YzYtNGI5OS05YmZkLTk0MjdlMmI5OWIwMQAQAIgbCyXwp0J1iP5HmZXbpic%3D/sx…3/3 Item 2 Attachment B - Additional Public Comments Received Before 1200p.m. on October 14, 2026     Packet Pg. 243     Item 2 Attachment B - Additional Public Comments Received Before 1200p.m. on October 14, 2026     Packet Pg. 244     Item 2 Attachment B - Additional Public Comments Received Before 1200p.m. on October 14, 2026     Packet Pg. 245     Item 2 Attachment B - Additional Public Comments Received Before 1200p.m. on October 14, 2026     Packet Pg. 246     Item 2 Attachment B - Additional Public Comments Received Before 1200p.m. on October 14, 2026     Packet Pg. 247     Item 2 Attachment B - Additional Public Comments Received Before 1200p.m. on October 14, 2026     Packet Pg. 248     Item 2 Attachment B - Additional Public Comments Received Before 1200p.m. on October 14, 2026     Packet Pg. 249     Item 2 Attachment B - Additional Public Comments Received Before 1200p.m. on October 14, 2026     Packet Pg. 250     Item 2 Attachment B - Additional Public Comments Received Before 1200p.m. on October 14, 2026     Packet Pg. 251     Item 2 Attachment B - Additional Public Comments Received Before 1200p.m. on October 14, 2026     Packet Pg. 252     Item 2 Attachment B - Additional Public Comments Received Before 1200p.m. on October 14, 2026     Packet Pg. 253     the height of the poles. Thank you for your consideration. Sincerely, Ronald Chun 580 Suzanne Ct. Palo Alto, CA 94306 Item 2 Attachment B - Additional Public Comments Received Before 1200p.m. on October 14, 2026     Packet Pg. 254     Item 2 Attachment B - Additional Public Comments Received Before 1200p.m. on October 14, 2026     Packet Pg. 255