HomeMy WebLinkAbout08-19-2015 Written Communications - Verizon Wireless -Prospect RoadMACKENZIE & ALBRITTON LLP
220 SANSOME STREET, 14T" FLOOR
SAN FRANCISCO, CALIFORNIA 94104
TELEPHONE 415 ( 288 -4000
FACSIMILE 415 / 288 -4010
August 12, 2015
VIA EMAIL AND FEDEX
Mayor Howard Miller
Vice Mayor Manny Cappello
Councilmembers Emily Lo, Mary -Lynne Bernald
and Rishi Kumar
City Council
City of Saratoga
13777 Fruitvale Avenue
Saratoga, California 95070
Re: Appeals of Verizon Wireless Design Review Applications
PDR15 -0004 (near 19848 Prospect Road)
PDR15 -0005 (near Prospect Road and Kristy Lane)
PDR15 -0006 (near 19700 Prospect Road)
City Council Agenda, August 19, 2015
Dear Mayor Miller, Vice Mayor Cappello and Councilmembers:
We write to youon behalf of our client Verizon Wireless to ask that you follow
the well- reasoned recommendation of planning staff, uphold the unanimous approval of
the Planning Commission and deny the three appeals filed by Jerry Gao and Ying Ding
( "Appellants ") of Verizon Wireless's approved placement of three small wireless
facilities on existing utility poles along Prospect Road (the "Approved Facilities ").
Verizon Wireless is utilizing a design that complies with design review requirements of
the City of Saratoga (the "City") and presents minimal visual impacts. Further, Verizon
Wireless has worked diligently to identify the locations of the Approved Facilities within
the City rights -of -way, where Verizon Wireless is allowed to place its facilities under
state law.
As described below, the appeals must be rejected under the Saratoga Code of
Ordinances (the "Code ") as well as under state and federal law. Appellants' primary
objections are unsupported by the Code. Further, all of Appellants' arguments are
beyond the scope of the City Council's evaluation of Verizon Wireless design review
applications. Verizon Wireless has provided uncontroverted substantial evidence that the
Approved Facilities fully comply with all findings for approval under the Code's design
review requirements. In addition, the Approved Facilities will provide needed
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August 12, 2015
Page 2 of 11
improvements to Verizon Wireless coverage and network capacity in the area with the
minimum number of small facilities, and there are no less intrusive feasible alternatives
in the right -of -way. For these reasons, denial of the applications would violate the
federal Telecommunications Act. We strongly encourage you to follow planning staff's
recommendation and affirm the Planning Commission's carefully considered approvals.
I. The Proieet
The Approved Facilities have been thoughtfully designed to minimize aesthetic
impact to the adjacent community. Verizon Wireless proposes to place a small wireless
facility on each of three existing wooden utility poles 42 to 45 feet tall in the Prospect
Road right -of -way. In each case, small antennas measuring two feet in height and 14.6
inches in diameter will be mounted to a wooden poletop extension that will elevate
antennas six to seven feet above electrical conductors, a separation distance required by
California Public Utilities Commission General Order 95.
Additional equipment will be stacked vertically on the side of the pole, with an
electrical meter mounted at seven feet above the sidewalk in compliance with rules of the
pole owner, the Joint Pole Authority. A small electrical cut -off switch will be placed just
above the electrical meter. Above the cut -off switch, Verizon Wireless will place three
small remote radio cabinets ( "RRUs ") measuring 20.4 inches high, 18.5 inches wide and
7.5 inches deep between approximately nine and 18 feet 10 inches on the pole. All pole -
mounted equipment and conduit risers will be painted "mesa brown" to match the color
of the wooden utility poles, and equipment mounted on to the side of the poles will be
uniformly rotated away from the street, in each case at the angle that most reduces
visibility. On the ground alongside each utility pole, a small equipment cabinet
measuring 39 inches high, 26 inches wide and 20 inches deep will be placed on a
concrete pad, with underground conduit connecting the equipment box to a cable riser
attached to the utility pole. The ground- mounted equipment cabinet will be placed to
avoid impeding traffic and again will be painted mesa brown. Photosimulations of the
Approved Facilities are attached as Exhibit A.
Reports by Hammett & Edison, Inc., Consulting Engineers, dated May 13, 2015
(the "H &E Reports "), attached as Exhibit B, confirm that radio - frequency ("RE")
emissions from the Approved Facilities will fully comply with Federal Communications
Commission ( "FCC ") guidelines. The Approved Facilities will not generate significant
traffic. In short, the Approved Facilities will not have significant adverse impacts of any
kind.
II. The Approved Facilities Fully Comply with All Code Requirements.
As confirmed in the Planning Commission Staff Reports for the May 13, 2015
Planning Commission hearing, the Approved Facilities meet all requirements for design
review approval under the Code. The Approved Facilities are all located on existing
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August 12, 2015
Page 3 of 11
utility poles in the right -of -way as favored under Code § 15- 44.025(a). With equipment
pained mesa brown to match the wooden utility poles, and with other utility poles and
trees of similar height to the Approved Facilities in the vicinity of each location, the
Approved Facilities comply with Code § 15- 44.025(b). With respect to Code § 15-
44.025(c) regarding ground- mounted equipment, staff rightly found that landscaping and
fencing were not appropriate for the Approved Facilities' locations where the ground -
mounted equipment box is "low profile" and other utility cabinets in the right -of -way in
the vicinity are likewise not screened. Presenting minimal additions to existing utility
poles and a small ground- mounted cabinet, the Approved Facilities are also consistent
with General Plan Land Use Goal 13 in that they are compatible with the sites (the
Prospect Road right -of -way) and adjacent surroundings.
Prior to the Planning Commission hearing, the Approved Facilities were reviewed
by the City's Public Works Department, which reviewed the equipment's placement in
the right -of -way and was satisfied with equipment placement. The Approved Facilities
comply with the noise regulations of Code Article 7 -30, and will not generate significant
traffic. In short, Verizon Wireless's Approved Facilities comply with all requirements of
the Code.
III. Verizon Wireless is Authorized to Place the Approved Facilities in the Public
Right -of -Way under State Law.
Verizon Wireless is entitled as a matter of law under California Public Utilities
Code §7901 to install equipment such as the Approved Facilities "along any public road
and highway," subject only to reasonable local restrictions as to the time, place and
manner in which such roads and highways are accessed. Section 7901 provides the state
franchise as follows:
Telegraph or telephone corporations may construct lines of telegraph or
telephone lines along and upon any public road or highway, along or
across any of the waters or lands within this State, and may erect poles,
posts, piers, or abutments for supporting the insulators, wires, and other
necessary fixtures of their lines, in such manner and at such points as not
to incommode the public use of the road or highway or interrupt the
navigation of the waters.
Verizon Wireless is a telephone corporation as defined under the Public Utilities Code.
A "telephone corporation" includes:
every corporation or person owning, controlling, operating, or managing any
telephone line for compensation within this state....
Public Utilities Code §234. "Telephone line" includes:
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August 12, 2015
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all conduits, ducts, poles, wires, cables, instruments, and appliances, and
all other real estate, fixtures, and personal property owned, controlled,
operated, or managed in connection with or to facilitate communication by
telephone, whether such communication is had with or without the use of
transmission wires.
Public Utilities Code §233 (emphasis added). In addition to the state code sections, the
case law in this area is equally clear on the right of Verizon Wireless to place facilities
within the public rights -of -way. See in re GTE MobilNet of San Jose, L.P., Decision 86-
09 -011, 22 CPUC 2d 25, slip op. at 6 -7 (Cal. Pub. Util. Comm. Sept. 4, 1986) (holding
that predecessor of Verizon Wireless was a "telephone corporation" entitled to install
wireless facilities in County right -of -way pursuant to §7901); and GTE MobilNet of
California L.P. v. City and County of San Francisco, 440 F. Supp. 2d 1097, 1103 (N.D.
Cal. 2006) (holding that "wireless carriers are included in the definition of "telephone
corporation" in §7901, and that the definition of "telephone line" in §7901 is broad
enough to reach wireless equipment ").
IV. Federal Law Compels Approval of the Approved Facilities.
Verizon Wireless is licensed by the FCC to provide wireless telecommunications
services throughout the United States, including the City of Saratoga. The siting of
wireless communications facilities ( "WCFs "), including the one at issue here, is governed
by federal law. While reserving to local jurisdictions control over the siting, placement
and modification of WCFs, the federal Telecommunications Act (the "TCA ") places
"certain limitations on localities' control over the construction and modification of
WCFs." Sprint PCS Assets, LLC v. City of Palos Verdes Estates, 583 F.3d 716, 721 (9th
Cir. 2009). Specifically, the TCA preserves local control over land use decisions,
subject to the following explicit statutory restrictions:
• The local government must act on a permit application within a reasonable period
of time (47 U.S.C. §332(c)(7)(B)(ii));
• Any denial of an application must be in writing and supported by substantial
evidence contained in a written record (47 U.S.C. §332(c)(7)(B)(iii));
• The local government may not regulate the placement, construction, or
modification of WCFs on the basis of the environmental effects of radio
frequency emissions to the extent such facilities comply with the FCC's
regulations concerning such emissions (47 U.S.C. §332(c)(7)(B)(iv));
• The local government may not unreasonably discriminate among providers of
functionally equivalent services (47 U.S.C. §332(c)(7)(B)(i)(I)); and
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August 12, 2015
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• The local government's decision must not "prohibit or have the effect of
prohibiting the provision of personal wireless services" (47 U.S.C.
§332(c)(7)(B)(i)(II)).
With this legal framework in mind, we address below the specific federal law
issues before the City Council with respect to this application.
V. Substantial Evidence for Approval, Lack of Substantial Evidence for Denial
As interpreted under controlling federal court decisions, the "substantial
evidence" requirement means that a local government's decision to deny a WCF
application must be "authorized by applicable local regulations and supported by a
reasonable amount of evidence (i.e., more than a `scintilla' but not necessarily a
preponderance)." Metro PCS, Inc. v. City and County of San Francisco, 400 F.3d 715,
725 (9th Cir. 2005). In other words, a local government must have specific reasons that
are both consistent with the local regulations and supported by substantial evidence in the
record to deny a wireless facility permit.
While a local government may regulate the placement of WCFs based on
aesthetics, it must have specific reasons that are both consistent with the local regulations
and supported by substantial evidence in the record. Generalized concerns or opinions
about aesthetics or compatibility with a neighborhood do not constitute substantial
evidence upon which a local government could deny a permit. See City of Rancho Palos
Verdes v. Abrams, 101 Cal. App. 4th 367, 381 (2002).
As set forth above, Verizon Wireless has provided substantial evidence to show
that the Approved Facilities comply with all design review requirements of the Code.
Among other evidence, photosimulations demonstrate compatibility with the surrounding
environment. The H &E Reports confirm that the Approved Facilities will operate well
below the FCC's exposure limits. In contrast, Appellants have provided no evidence — let
alone the substantial evidence required by federal law — to support denial of the
Approved Facilities.
VI. Radio Frequency Emissions Comply with FCC Standards.
Appellants raise unfounded concerns over "cumulative effects" of "RF radiation ";
however, local governments are specifically precluded under the federal statute from
considering any alleged health or environmental effects of RF emissions of proposed
WCFs "to the extent such facilities comply with the FCC's regulations concerning such
emissions." 47 U.S.C. §332(c)(7)(B)(iv). As set forth in the H &E Reports referenced
above, the Approved Facilities fully comply with applicable FCC guidelines and will
operate far below all applicable FCC public exposure limits. Indeed, the H &E Reports
calculate that the maximum exposure anywhere at ground level from any of the
Approved Facilities is less than one percent of the applicable FCC public limit.
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August 12, 2015
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Moreover, federal preemption goes beyond decisions that are explicitly based on
RF emissions. It also bars efforts to skirt such preemption through some proxy such as
aesthetics or property values. See, e.g., AT&T Wireless Servs. of Cal. LLC v. City of
Carlsbad, 308 F. Supp. 2d 1148, 1159 (S.D. Cal. 2003) (in light of federal preemption,
"concern over the decrease in property values may not be considered as substantial
evidence if the fear of property value depreciation is based on concern over the health
effects caused by RF emissions "); Calif. RSA No. 4, d /b /a Verizon Wireless v. Madera
County, 332 F. Supp. 2d 1291, 1311 (E.D. Cal. 2003) ( "complaints about property values
were really a proxy for concerns about possible environmental effects of RF [emissions],
which cannot provide the basis to support a decision "). Where, as here, a WCF has been
shown to fully comply with FCC guidelines, neither health concerns nor any proxy for
health concerns can justify denial of the Approved Facilities.
VII. Approval is Required in Order to Avoid Unlawful Prohibition of Service.
A local government violates the "effective prohibition" clause of the TCA if it
prevents a wireless provider from closing a "significant gap" in coverage by the least
intrusive means. This issue involves a two - pronged analysis: (1) whether the provider
has demonstrated the existence of a "significant gap" in service; and (2) whether the
proposed facility is the "least intrusive means," in relation to the land use values
embodied in local regulations, to address the gap. See T- Mobile USA, Inc. v. City of
Anacortes, 572 F.3d 987 (9`' Cir. 2009); see also T- Mobile West Corp. v. City ofAgoura
Hills, 2010 U.S. Dist. LEXIS 134329 (C.D. Cal. 2010).
Recent case law has confirmed that inadequate network capacity to provide
reliable wireless service may constitute a "significant gap" in coverage to the same extent
as inadequate coverage. See Nextel v. City of Mt. Vernon, 361 F.Supp.2d 336 (S.D.N.Y.
2005) (summary judgment for wireless carrier on a claim of "prohibition of service"
based on a demonstration of inadequate capacity).
If a provider demonstrates both the existence of a significant gap, and that the
proposed facility meets the "least intrusive means" standard, the local government is
required to approve the facility, even if there would otherwise be substantial evidence to
deny the permit under local land use provisions. This is because the requirements for
federal preemption have been satisfied; i.e., denial of the permit would "have the effect of
prohibiting the provision of personal wireless services." 47 U.S.C. §332(c)(7)(B)(1)(ii);
T- Mobile v. Anacortes, 572 F.3d at 999. For the local jurisdiction to avoid such
preemption, it must show that another alternative is available, that it is technologically
feasible, and that it is "less intrusive" than the proposed facility. T- Mobile v. Anacortes,
572 F.3d at 998 -999.
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August 12, 2015
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A. Verizon Wireless Has Demonstrated a Significant Gap in Service.
Verizon Wireless has documented the need for improved network capacity in the
north Saratoga area (the "Significant Gap "). The Significant Gap is fully documented in
the Statement of Radio Frequency Design Engineer Brian Ung attached as Exhibit C (the
"RF Engineer's Statement "). The RF Engineer's Statement explains that there is a gap in
service coverage as well as rapidly increasing usage of Verizon Wireless's network in the
north Saratoga area and that the existing sites providing wireless service to the area are
already experiencing "capacity exhaustion" resulting in call blocking, dropped calls and a
lack of access to the network during periods of peak usage. This compromises the
Verizon Wireless network in the north Saratoga until additional capacity is added.
Having established a Significant Gap in coverage, Verizon Wireless has met the
first prong of the two -part test required to presumptively establish a prohibition of service
under federal law.
B. The Alternatives Analysis Confirms that the Approved Facilities are
the Least Intrusive Feasible Means to Fill the Identified Significant
Gap in Verizon Wireless Service.
In an effort to fill the identified Significant Gap, Verizon Wireless evaluated a
total of 20 locations in the right -of -way as shown in the comprehensive Alternatives
Analysis for the three facilities attached as Exhibit D. The result of this analysis is that
the pole locations of Approved Facilities — on existing utility poles in the right -of -way as
favored by the Code — are the least intrusive feasible means of providing wireless service
to the identified coverage and capacity gaps.
When comparing the locations of the Approved Facilities to other potential
alternatives in the right -of -way, it is important to note that federal law does not require
that a site be the "only" alternative, but rather that no feasible alternative is less intrusive
than the Approved Facilities. MetroPCS v. San Francisco, 400 F.3d at 734 -35. In this
case, as explained in the Alternatives Analysis, there is no feasible location that would be
less intrusive than the Approved Facilities.
In short, Verizon Wireless has identified a significant gap in coverage and
network capacity and has shown that the Approved Facilities are the least intrusive means
to address it, based on the values expressed in the Code. Under these circumstances,
Verizon Wireless has established the requirements for federal preemption such that denial
of the permit would constitute an unlawful prohibition of service.
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August 12, 2015
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VIII. Response to Appeals
Appellants raise several grounds for appeal, none of which present the substantial
evidence required under federal law to warrant denial of Verizon Wireless's application.
As a threshold matter, Appellants raise issues that are simply beyond the scope of review
for the design review applications approved by the Planning Commission. In addition, in
a letter dated June 8, 2015, Appellants' counsel attempts to challenge the Approved
Facilities but the challenge relies on inaccurate claims.
1. The Planning Commission's Approval Was Correctly Based on the
Design Review Findings of the Code.
Appellants claim that the Planning Commission based its approvals on a new
federal law pertaining to wireless facilities, but that is not the case. At issue is a law
completely inapplicable to the Planning Commission consideration of the Approved
Facilities, Section 6409 of the Middle Class Tax Relief and Job Creation Act of 2012,
codified as 47 U.S.C. § 1455 ( "Section 6409 "). Section 6409 regulates modification of
existing wireless facilities. Where the Approved Facilities are to be located on utility
poles that do not already support wireless facilities, Section 6409 does not apply, and
Section 6409 was not a deciding factor in the Planning Commission's resolutions of
approval for the Approved Facilities. Similarly, any concerns raised over criteria unique
to Section 6409, such as Appellant's allegation that the Approved Facilities constitute a
"substantial change," are irrelevant where there are not existing wireless facilities on the
utility poles, and that federal law does not apply.
In fact, Planning Commission Resolutions 15 -012, 15 -013 and 15 -014 contain
determinations that the Approved Facilities are exempt from CEQA review, are
consistent with relevant General Plan goals and policies and comply with the Code —the
relevant factors in approving design review applications. As noted above, the Planning
Commission's approvals were based on substantial evidence provided by Verizon
Wireless and thoroughly detailed in the staff reports, which recommended approval.
Appellants' counsel also raises this ground for challenging the Approved
Facilities, but their implication that Section 6409 was a factor in reviewing the Approved
Facilities is similarly irrelevant. This ground for appeal relies on an irrelevant argument
and law and must be rejected.
We also note that Appellants' counsel challenges Verizon Wireless's right to
occupy the right -of -way under California Public Utilities Code §7901. As set forth
above, in detail, Verizon Wireless's rights under California Public Utilities Code §7901
have long since been established through decisions of the California Public Utilities
Commission and federal courts, and Appellants' counsel's challenge to these rights is
entirely baseless and completely without merit.
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August 12, 2015
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2. The Approved Facilities Constitute the Least Intrusive Means of
Closing a Significant Gap in Coverage and Network Capacity.
Appellants attempt to discredit Verizon Wireless's site selection process and site
justification, but not only are these federal case law considerations irrelevant to the City's
design review findings under the Code, Verizon Wireless in fact has demonstrated a
significant gap in coverage and network capacity as described above. With respect to the
scope of review by the City Council, the Code's design review findings do not address
the need for a facility or require that an applicant prove there is a significant gap in its
service. Similarly, the design review findings do not require an applicant to prove that a
proposed facility is the least intrusive location, especially where an applicant has chosen
to place a facility in a most - favored location, which, under Code § 15- 44.025(a), includes
on "an existing utility pole /tower in the public right -of- way."
With the Approved Facilities appealed to the City Council, Verizon Wireless has
demonstrated that there is a significant gap in its service and that the Approved Facilities
are the least intrusive means to close that gap only to show that a City Council denial of
the Approved Facilities would constitute a prohibition of service in violation of 47 U.S.C.
§332(c)(7)(B)(i)(II). Additionally, Appellants raise this ground for appeal with emphasis
on "cumulative effects" of "RF radiation," an allusion to fears over environmental effects
of radio frequency emissions. This unfounded fear is preempted from consideration by
the City Council under 47 U.S.C. §332(c)(7)(B)(iv) because the H &E Reports confirm
that the Approved Facilities will operate far below FCC exposure limits and confirm
there are no nearby wireless facilities that would affect this conclusion. This ground for
appeal must be rejected.
3. The Approved Facilities Do Not Affect the City's Plans for Roadway
Improvements.
Appellants express concern over impacts of the Approved Facilities to the
Prospect Road Beautification and Safety Improvements Project; however, the Approved
Facilities do not interfere with potential improvements. Plans for the road project, which
has not yet commenced in the area of the Approved Facilities, include new landscaped
medians to be placed in the center of Prospect Road, several new bus shelters and certain
bicycle safety measures — improvements which will not affect the locations of the
Approved Facilities. The proposed ground - mounted cabinets will be located adjacent to
existing utility poles in a manner that will not conflict with present or future sidewalks.
As noted above and in the Planning Department staff reports, the Public Works
Department reviewed the applications for the Approved Facilities and recommended
approval.
Appellants' stated concerns over a new federal law that will allow for
administrative approval of certain site modifications are inconsistent with Appellants'
own confirmation that such modifications cannot be made where they will "substantially
Saratoga City Council
August 12, 2015
Page 10 of 11
change the physical dimensions" of a facility. As confirmed by staff's analysis of
Section 6409, Appellants' concerns over future site modifications are misplaced.
Where Verizon Wireless's current applications for design review of the Approved
Facilities have been found to comply with design review findings and do not present any
potential for impact on planned roadway improvement projects, this ground for appeal
must be rejected.
4. The Approved Facilities are Structurally Safe.
Appellants imply that the Approved Facilities will present a public safety hazard
due to their placement on aging utility poles, but offer no specific evidence to confirm a
hazard. The structural integrity of utility poles is closely regulated by the California
Public Utilities Commission under General Order 95. Any addition to a utility pole is
subject to rigorous structural analysis by the pole owner. Where structural integrity is in
question, pole replacement is required. For each of the Approved Facilities, Verizon
Wireless provided structural calculations and plans with the applications to the Joint Pole
Authority for use of the poles. The structural integrity of each utility pole was analyzed
by the Joint Pole Authority, and specifically PG &E, to confirm pole integrity. The
approvals for authorization of pole use by the Joint Pole Authority confirm the Joint Pole
Authority's agreement that the structural capacity of the poles is adequate to support the
facilities.
In this ground for appeal, Appellants again raise preempted fear of environmental
effects of radio frequency emissions, belying the true thrust of the appeals. As noted
above, the H &E Reports confirm that the Approved Facilities will operate far below FCC
exposure limits. As this ground for appeal fails to uncover any public safety hazards, it
must be rejected.
5. Placement of Facility near 19848 Prospect Road is Consistent with
Code Requirements.
Appellants allege that the Verizon Wireless facility in the right -of -way near
19848 Prospect Road (Planning Commission Approval, Application 15 -004) violates a
provision of Code Article 15 -29 which regulates fences. Specifically, Code § 15-
29.010(f) requires that:
No fence, hedge, retaining wall, entryway element, pilaster, gate, or other
similar element located within a triangle having sides twelve feet in length
from either side of a driveway where it intersects with edge of pavement
shall exceed three feet in height above the established grade of the
adjoining street.
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August 12, 2015
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In fact, Verizon Wireless's proposed facility at this location is not subject to this Code
provision, as the proposed ground- mounted equipment cabinet is a utility structure
similar to the existing utility pole already placed at this location and is not similar to a
fence or to any of the other decorative elements listed in the above Code provision.
Further, as noted above, Verizon Wireless's state - mandated right to occupy the right -of-
way allows for the placement of the equipment cabinet in the right -of -way next to the
existing utility pole. Appellants misinterpret the Code article regarding fences. It is quite
simply inapplicable. The 19848 Prospect Road facility complies with all Code
requirements. This ground for appeal must be rejected.
Appellants and Appellants' counsel raise no grounds for appeal that constitute
substantial evidence to deny Verizon Wireless's applications. In contrast, Verizon
Wireless has provided ample evidence that the Approved Facilities comply with all City
requirements. The appeals must be rejected.
Conclusion
Verizon Wireless has worked diligently to identify the ideal locations and design
for three small wireless facilities in the right -of -way to serve the north Saratoga area. As
unanimously approved by the Planning Commission, the Approved Facilities meet the
findings for design review under the Code. The resulting Approved Facilities also
represent the least intrusive means to address the gap in coverage and network capacity.
Bringing Verizon Wireless service to this area is essential to the health, safety, and
welfare of residents, travelers, and emergency services providers in the surrounding
community. We strongly encourage you to follow the recommendations of planning
staff, affirm the Planning Commission approval, and deny the appeals.
Very truly yours,
Paul B. Albritton
cc: Richard Taylor, Esq.
Michael Fossati
Schedule of Exhibits
Exhibit A: Photosimulations
Exhibit B: H &E Reports
Exhibit C: Statement of Verizon Wireless RF Engineer Brian Ung
Exhibit D: Alternatives Analysis
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Verizon Wireless • Proposed Base Station (Site No. 291212 "Prospect & Miller SC1")
19512 Prospect Road • Saratoga, California
Statement of Hammett & Edison, Inc., Consulting Engineers
The firm of Hammett & Edison, Inc., Consulting Engineers, has been retained on behalf of Verizon
Wireless, a personal wireless telecommunications carrier, to evaluate the base station (Site No. 291212
"Prospect & Miller SC F') ") proposed to be located at 19512 Prospect Road in Saratoga, California, for
compliance with appropriate guidelines limiting human exposure to radio frequency ("R-F")
electromagnetic fields.
Executive Summary
Verizon proposes to install an antenna on top of the existing utility pole on the south side of
Prospect Road, opposite Danromas Way, in Saratoga. The proposed operation will comply
with the FCC guidelines limiting public exposure to RF energy.
Prevailing Exposure Standards
The U.S. Congress requires that the Federal Communications Commission ( "FCC ") evaluate its
actions for possible significant impact on the environment. A summary of the FCC's exposure limits
is shown in Figure 1. These limits apply for continuous exposures and are intended to provide a
prudent margin of safety for all persons, regardless of age, gender, size, or health. The most restrictive
FCC limit for exposures of unlimited duration to radio frequency energy for several personal wireless
services are as follows:
Wireless Service
Frequency Band
Occupational Limit
Public Limit
Microwave (Point -to- Point)
5 -80 GHz
5.00 mW /cm2
1.00 mW /cm2
WiFi (and unlicensed uses)
2-6
5.00
1.00
BRS (Broadband Radio)
2,600 MHz
5.00
1.00
WCS (Wireless Communication)
2,300
5.00
1.00
AWS (Advanced Wireless)
2,100
5.00
1.00
PCS (Personal Communication)
1,950
5.00
1.00
Cellular
870
2.90
0.58
SMR (Specialized Mobile Radio)
855
2.85
0.57
700 MHz
700
2.40
0.48
[most restrictive frequency range]
30-300
1.00
0.20
General Facility Requirements
Base stations typically consist of two distinct parts: the electronic transceivers (also called "radios" or
"channels ") that are connected to the traditional wired telephone lines, and the passive antennas that
send the wireless signals created by the radios out to be received by individual subscriber units. The
transceivers are often located at ground level and are connected to the antennas by coaxial cables. A
small antenna for reception of GPS signals is also required, mounted with a clear view of the sky.
GJ .�? HAMMETT & EDISON, INC.
o CONSULTING ENGINEERS J3LA
L SAN FRANCFM Pagel of 3
Verizon Wireless • Proposed Base Station (Site No. 291212 "Prospect & Miller SC1")
19512 Prospect Road • Saratoga, California
Because of the short wavelength of the frequencies assigned by the FCC for wireless services, the
antennas require line -of -sight paths for their signals to propagate well and so are installed at some
height above ground. The antennas are designed to concentrate their energy toward the horizon, with
very little energy wasted toward the sky or the ground. This means that it is generally not possible for
exposure conditions to approach the maximum permissible exposure limits without being physically
very near the antennas.
Computer Modeling Method
The FCC provides direction for determining compliance in its Office of Engineering and Technology
Bulletin No. 65, "Evaluating Compliance with FCC - Specified Guidelines for Human Exposure to
Radio Frequency Radiation," dated August 1997. Figure 2 describes the calculation methodologies,
reflecting the facts that a directional antenna's radiation pattern is not fully formed at locations very
close by (the "near - field" effect) and that at greater distances the power level from an energy source
decreases with the square of the distance from it (the "inverse square law "). The conservative nature
of this method for evaluating exposure conditions has been verified by numerous field tests.
Site and Facility Description
Based upon information provided by Verizon, including construction drawings by V -One Design
Group, Inc., dated February 12, 2015, it is proposed to install one Amphenol Model CWT360X06F
cylindrical antenna on top of the existing 43 -foot utility pole sited in the public right -of -way on the
south side of Prospect Road in Saratoga, near the northeast corner of the parking lot at the Church of
the Ascension, located at 12033 Miller Avenue. The antenna would employ no downtilt, would be
mounted at an effective height of about 50%2 feet above ground, and would provide service in all
directions. The maximum effective radiated power in any direction would be 850 watts, representing
simultaneous operation at 350 watts for AWS, 350 watts for PCS, and 150 watts for 700 MHz service;
no operation on cellular frequencies is presently proposed from this site. There are reported no other
wireless telecommunications base stations at the site or nearby.
Study Results
For a person anywhere at ground, the maximum RF exposure level due to the proposed Verizon
operation is calculated to be 0.0024 mW /cm2, which is 0.34% of the applicable public exposure limit.
The maximum calculated level at the second -floor elevation of any nearby building} is 0.56% of the
public exposure limit. It should be noted that these results include several "worst- case" assumptions
and therefore are expected to overstate actual power density levels from the proposed operation.
* Including the residences located at least 120 feet away, based on photographs from Google Maps.
HAMMETT & EDISON, INC.
o CONSULTING ENGINEERS BLA
] SAN MANCLSM Page 2 of 3
Verizon Wireless • Proposed Base Station (Site No. 291212 "Prospect & Miller SC1")
19512 Prospect Road • Saratoga, California
No Recommended Mitigation Measures
Due to its mounting location and height, the Verizon antenna would be accessible only to authorized
PG &E personnel, and so no mitigation measures are necessary to comply with the FCC public
exposure guidelines. To prevent exposures in excess of the occupational limit, it is expected that
PG &E workers will adhere to appropriate safety protocols adopted by that company.
Conclusion
Based on the information and analysis above, it is the undersigned's professional opinion that
operation of the base station proposed by Verizon Wireless near 19512 Prospect Road in Saratoga,
California, will comply with the prevailing standards for limiting public exposure to radio frequency
energy and, therefore, will not for this reason cause a significant impact on the environment. The
highest calculated level in publicly accessible areas is much less than the prevailing standards allow
for exposures of unlimited duration. This finding is consistent with measurements of actual exposure
conditions taken at other operating base stations.
Authorship
The undersigned author of this statement is a qualified Professional Engineer, holding California
Registration Nos. E -13026 and M- 20676, which expire on June 30, 2015. This work has been carried
out under his direction, and all statements are true and correct of his own knowledge except, where
noted, when data has been supplied by others, which data he believes to be correct.
May 13, 2015
HAMMETT & EDISON, INC.
H, FM CONSUMNG ENGINEERS
SAN FRANUSCO
Is
(� E -13026
C5 M -20676
U w
cc Exp. 6.30 -2015 a
AN �P- dC�� j
LAJ ' - • c.A
William F. H ett, P.E.
707/996 -5200
J3LA
Page 3 of 3
FCC Radio Frequency Protection Guide
The U.S. Congress required (1996 Telecom Act) the Federal Communications Commission ( "FCC ")
to adopt a nationwide human exposure standard to ensure that its licensees do not, cumulatively, have
a significant impact on the environment. The FCC adopted the limits from Report No. 86, "Biological
Effects and Exposure Criteria for Radiofrequency Electromagnetic Fields," published in 1986 by the
Congressionally chartered National Council on Radiation Protection and Measurements ( "NCRP ").
Separate limits apply for occupational and public exposure conditions, with the latter limits generally
five times more restrictive. The more recent standard, developed by the Institute of Electrical and
Electronics Engineers and approved as American National Standard ANSI /IEEE C95.1 -2006, "Safety
Levels with Respect to Human Exposure to Radio Frequency Electromagnetic Fields, 3 kHz to
300 GHz," includes similar limits. These limits apply for continuous exposures from all sources and
are intended to provide a prudent margin of safety for all persons, regardless of age, gender, size, or
health.
As shown in the table and chart below, separate limits apply for occupational and public exposure
conditions, with the latter limits (in italics and /or dashed) up to five times more restrictive:
Frequency
Applicable
Range
(MHz)
0.3— 1.34
1.34— 3.0
3.0— 30
30— 300
300— 1,500
1,500— 100,000
1000
.. 100
3•; 10
0 �3
A � 1
0.1
Electromagnetic Fields (f is frequency of emission in MHz)
Electric Magnetic Equivalent Far -Field
Field Strength Field Strength Power Density
(V /m) (A/m) (mw /cm2)
614 614
614 823.81f
1842/f 823.81f
1.63 1.63
1.63 2.191f
4.89/ f 2.191f
61.4
27.5
0.163
0.0729
3.54ff
1.5Kf
4-0106
ff1238
137
61.4
0.364
0.163
Occupational Exposure
` PCS
FM Cell
�
Public Exposure
100
100
900/ fz
1.0
f /300
5.0
0.1 1 10 100 103 104 105
Frequency (MHz)
100
180 /1
18011
0.2
f /1500
1.0
Higher levels are allowed for short periods of time, such that total exposure levels averaged over six or
thirty minutes, for occupational or public settings, respectively, do not exceed the limits, and higher
levels also are allowed for exposures to small areas, such that the spatially averaged levels do not
exceed the limits. However, neither of these allowances is incorporated in the conservative calculation
formulas in the FCC Office of Engineering and Technology Bulletin No. 65 (August 1997) for
projecting field levels. Hammett & Edison has built those formulas into a proprietary program that
calculates, at each location on an arbitrary rectangular grid, the total expected power density from any
number of individual radio sources. The program allows for the description of buildings and uneven
terrain, if required to obtain more accurate projections.
i ' 3•'?-` HAMMETT & EDISON, INC.
CONSULTING ENGINEERS FCC Guidelines
SANFRANCISCO Figure 1
RFR.CALCTM Calculation Methodology
Assessment by Calculation of Compliance with FCC Exposure Guidelines
The U.S. Congress required (1996 Telecom Act) the Federal Communications Commission ( "FCC ") to
adopt a nationwide human exposure standard to ensure that its licensees do not, cumulatively, have a
significant impact on the environment. The maximum permissible exposure limits adopted by the FCC
(see Figure 1) apply for continuous exposures from all sources and are intended to provide a prudent
margin of safety for all persons, regardless of age, gender, size, or health. Higher levels are allowed for
short periods of time, such that total exposure levels averaged over six or thirty minutes, for
occupational or public settings, respectively, do not exceed the limits.
Near Field.
Prediction methods have been developed for the near field zone of panel (directional) and whip
(omnidirectional) antennas, typical at wireless telecommunications base stations, as well as dish
(aperture) antennas, typically used for microwave links. The antenna patterns are not fully formed in
the near field at these antennas, and the FCC Office of Engineering and Technology Bulletin No. 65
(August 1997) gives suitable formulas for calculating power density within such zones.
For a panel or whip antenna, power density S = 180 x 0.1 x Pnet
8 n x D x h' in mW /cm2,
aw .
and for an aperture antenna, maximum power density Smax — x h2 0.1x16x17 xPnet in mW /cm2,
where 013W = half -power beamwidth of the antenna, in degrees, and
Pnet = net power input to the antenna, in watts,
D = distance from antenna, in meters,
h = aperture height of the antenna, in meters, and
71 = aperture efficiency (unitless, typically 0.5 -0.8).
The factor of 0.1 in the numerators converts to the desired units of power density.
Far Field.
OET -65 gives this formula for calculating power density in the far field of an individual RF source:
power density S = 2.56 x 1.64 x 100 x RFF2 x ERP
4 x .rc x D in mW /cm2,
where ERP = total ERP (all polarizations), in kilowatts,
RFF = relative field factor at the direction to the actual point of calculation, and
D = distance from the center of radiation to the point of calculation, in meters.
The factor of 2.56 accounts for the increase in power density due to ground reflection, assuming a
reflection coefficient of 1.6 (1.6 x 1.6 = 2.56). The factor of 1.64 is the gain of a half -wave dipole
relative to an isotropic radiator. The factor of 100 in the numerator converts to the desired units of
power density. This formula has been built into a proprietary program that calculates, at each location
on an arbitrary rectangular grid, the total expected power density from any number of individual
radiation sources. The program also allows for the description of uneven terrain in the vicinity, to
obtain more accurate projections.
HAMMETT & EDISON INC.
CONSULTING F.NGiNEERS Methodology
SAN FRANCISCO
- Figure 2
Verizon Wireless • Proposed Base Station (Site No. 291217 "Prospect & Miller SC2 ")
6585 Prospect Road • Saratoga, California
Statement of Hammett & Edison, Inc., Consulting Engineers
The firm of Hammett & Edison, Inc., Consulting Engineers, has been retained on behalf of Verizon
Wireless, a personal wireless telecommunications carrier, to evaluate the base station (Site No. 291217
"Prospect & Miller SC2 ") proposed to be located near 6585 Prospect Road in Saratoga, California, for
compliance with appropriate guidelines limiting human exposure to radio frequency ( "RF ")
electromagnetic fields.
Executive Summary
Verizon proposes to install an antenna on top of the existing utility pole sited across the
street from 6585 Prospect Road in Saratoga. The proposed operation will comply with the
FCC guidelines limiting public exposure to RF energy.
Prevailing Exposure Standards
The U.S. Congress requires that the Federal Communications Commission ( "FCC ") evaluate its
actions for possible significant impact on the environment. A summary of the FCC's exposure limits
is shown in Figure 1. These limits apply for continuous exposures and are intended to provide a
prudent margin of safety for all persons, regardless of age, gender, size, or health. The most restrictive
FCC limit for exposures of unlimited duration to radio frequency energy for several personal wireless
services are as follows:
Wireless Service
Frequency Band
Occupational Limit
Public Limit
Microwave (Point -to- Point)
5 -80 GHz
5.00 mW /cm2
1.00 mW /cm2
WiFi (and unlicensed uses)
2-6
5.00
1.00
BRS (Broadband Radio)
2,600 MHz
5.00
1.00
WCS (Wireless Communication)
2,300
5.00
1.00
AWS (Advanced Wireless)
2,100
5.00
1.00
PCS (Personal Communication)
1,950
5.00
1.00
Cellular
870
2.90
0.58
SMR (Specialized Mobile Radio)
855
2.85
0.57
700 MHz
700
2.40
0.48
[most restrictive frequency range]
30-300
1.00
0.20
General Facility Requirements
Base stations typically consist of two distinct parts: the electronic transceivers (also called "radios" or
"channels ") that are connected to the traditional wired telephone lines, and the passive antennas that
send the wireless signals created by the radios out to be received by individual subscriber units. The
transceivers are often located at ground level and are connected to the antennas by coaxial cables. A
small antenna for reception of GPS signals is also required, mounted with a clear view of the sky.
j HAmmET"T & EDISON, INC.
CONSULTING ENGINEERS F6ND
=. SAN FRANCISCO Pagel of 3
Verizon Wireless • Proposed Base Station (Site No. 291217 "Prospect & Miller SC2 ")
6585 Prospect Road • Saratoga, California
Because of the short wavelength of the frequencies assigned by the FCC for wireless services, the
antennas require line -of -sight paths for their signals to propagate well and so are installed at some
height above ground. The antennas are designed to concentrate their energy toward the horizon, with
very little energy wasted toward the sky or the ground. This means that it is generally not possible for
exposure conditions to approach the maximum permissible exposure limits without being physically
very near the antennas.
Computer Modeling Method
The FCC provides direction for determining compliance in its Office of Engineering and Technology
Bulletin No. 65, "Evaluating Compliance with FCC - Specified Guidelines for Human Exposure to
Radio Frequency Radiation," dated August 1997. Figure 2 describes the calculation methodologies,
reflecting the facts that a directional antenna's radiation pattern is not fully formed at locations very
close by (the "near - field" effect) and that at greater distances the power level from an energy source
decreases with the square of the distance from it (the "inverse square law "). The conservative nature
of this method for evaluating exposure conditions has been verified by numerous field tests.
Site and Facility Description
Based upon information provided by Verizon, including construction drawings by V -One Design
Group, Inc., dated February 12, 2015, it is proposed to install one Amphenol Model CWT360X06F
cylindrical antenna on top of the existing 45 -foot utility pole sited in the public right -of -way on the
south side of Prospect Road at Clarkspur Lane, across the street from the residence located at
6585 Prospect Road. The antenna would employ no downtilt, would be mounted at an effective height
of about 53 feet above ground, and would provide service in all directions. The maximum effective
radiated power in any direction would be 850 watts, representing simultaneous operation at 350 watts
for AWS, 350 watts for PCS, and 150 watts for 700 MHz service; no operation on cellular frequencies
is presently proposed from this site. There are reported no other wireless telecommunications base
stations at the site or nearby.
Study Results
For a person anywhere at ground, the maximum RF exposure level due to the proposed Verizon
operation is calculated to be 0.0022 mW /cm2, which is 0.31% of the applicable public exposure limit.
The maximum calculated level at the second -floor elevation of any nearby residence* is 0.49% of the
public exposure limit. It should be noted that these results include several "worst- case" assumptions
and therefore are expected to overstate actual power density levels from the proposed operation.
* Located at least 50 feet away, based on photographs from Google Maps.
4 H"METT & EDISON, INC.
CONSULTING ENGINEERS F6ND
=� SAN FRANCISCO Page 2 of 3
Verizon Wireless • Proposed Base Station (Site No. 291217 "Prospect & Miller SC2 ")
6585 Prospect Road • Saratoga, California
No Recommended Mitigation Measures
Due to its mounting location and height, the Verizon antenna would be accessible only to authorized
PG &E personnel, and so no mitigation measures are necessary to comply with the FCC public
exposure guidelines. To prevent exposures in excess of the occupational limit, it is expected that
PG &E workers will adhere to appropriate safety protocols adopted by that company.
Conclusion
Based on the information and analysis above, it is the undersigned's professional opinion that
operation of the base station proposed by Verizon Wireless near 6585 Prospect Road in Saratoga,
California, will comply with the prevailing standards for limiting public exposure to radio frequency
energy and, therefore, will not for this reason cause a significant impact on the environment. The
highest calculated level in publicly accessible areas is much less than the prevailing standards allow
for exposures of unlimited duration. This finding is consistent with measurements of actual exposure
conditions taken at other operating base stations.
Authorship
The undersigned author of this statement is a qualified Professional Engineer, holding California
Registration Nos. E -13026 and M- 20676, which expire on June 30, 2015. This work has been carried
out under his direction, and all statements are true and correct of his own knowledge except, where
noted, when data has been supplied by others, which data he believes to be correct.
May 13, 2015
HAMMETT & EDISON, INC.
CONSULTING ENGINEERS
SAN FRANCISCO
F.
EA 3026
M -20676
G Exp. 6-30-2015
17 ' V _ t-"
William F. H ett, P.E.
707/996 -5200
F6ND
Page 3 of 3
FCC Radio Frequency Protection Guide
The U.S. Congress required (1996 Telecom Act) the Federal Communications Commission ( "FCC ")
to adopt a nationwide human exposure standard to ensure that its licensees do not, cumulatively, have
a significant impact on the environment. The FCC adopted the limits from Report No. 86, "Biological
Effects and Exposure Criteria for Radiofrequency Electromagnetic Fields," published in 1986 by the
Congressionally chartered National Council on Radiation Protection and Measurements ( "NCRP ").
Separate limits apply for occupational and public exposure conditions, with the latter limits generally
five times more restrictive. The more recent standard, developed by the Institute of Electrical and
Electronics Engineers and approved as American National Standard ANSI/IEEE C95.1 -2006, "Safety
Levels with Respect to Human Exposure to Radio Frequency Electromagnetic Fields, 3 kHz to
300 GHz," includes similar limits. These limits apply for continuous exposures from all sources and
are intended to provide a prudent margin of safety for all persons, regardless of age, gender, size, or
health.
As shown in the table and chart below, separate limits apply for occupational and public exposure
conditions, with the latter limits (in italics and/or dashed) up to five times more restrictive:
Frequency
Applicable
Range
(MHz)
0.3— 1.34
1.34— 3.0
3.0— 30
30— 300
300— 1,500
1,500— 100,000
1000
.. 100
o10
.� 0.1
Electromagnetic Fields (f is freauencv of emission in MHz
Electric
Magnetic
Equivalent Far -Field
Field Strength
Field Strength
Power Density
(V /m)
(A/m)
(mW /cm2)
614 614
1.63 1.63
100 100
614 823.81f
1.63 2.191f
100 18011
1842/ f 823.81f
4.89/ f 2.191f
900/ e 18011
61.4 27.5
0.163 0.0729
1.0 0.2
3.54NFf 1.5KI'
1rf /106 ff1238
f /300 f /1500
137 61.4
0.364 0.163
5.0 1.0
Occupational Exposure
f/ PCs
Cell
FM
Public Exposure
0.1 1 10 100 103 104 105
Frequency (MHz)
Higher levels are allowed for short periods of time, such that total exposure levels averaged over six or
thirty minutes, for occupational or public settings, respectively, do not exceed the limits, and higher
levels also are allowed for exposures to small areas, such that the spatially averaged levels do not
exceed the limits. However, neither of these allowances is incorporated in the conservative calculation
formulas in the FCC Office of Engineering and Technology Bulletin No. 65 (August 1997) for
projecting field levels. Hammett & Edison has built those formulas into a proprietary program that
calculates, at each location on an arbitrary rectangular grid, the total expected power density 'from any
number of individual radio sources. The program allows for the description of buildings and uneven
terrain, if required to obtain more accurate projections.
HAMMETT & EDISON, INC.
r CONSULTING ENGINEERS FCC Guidelines
SAN FRANCISCO Figure 1
RFR.CALCTM Calculation Methodology
Assessment by Calculation of Compliance with FCC Exposure Guidelines
The U.S. Congress required (1996 Telecom Act) the Federal Communications Commission ( "FCC ") to
adopt a nationwide human exposure standard to ensure that its licensees do not, cumulatively, have a
significant impact on the environment. The maximum permissible exposure limits adopted by the FCC
(see Figure 1) apply for continuous exposures from all sources and are intended to provide a prudent
margin of safety for all persons, regardless of age, gender, size, or health. Higher levels are allowed for
short periods of time, such that total exposure levels averaged over six or thirty minutes, for
occupational or public settings, respectively, do not exceed the limits.
Near Field.
Prediction methods have been developed for the near field zone of panel (directional) and whip
(omnidirectional) antennas, typical at wireless telecommunications base stations, as well as dish
(aperture) antennas, typically used for microwave links. The antenna patterns are not fully formed in
the near field at these antennas, and the FCC Office of Engineering and Technology Bulletin No. 65
(August 1997) gives suitable formulas for calculating power density within such zones.
For a panel or whip antenna, power density S = 180 x O x D Pn h ' in mW /cm2,
6
Bw
xr)xPnet
and for an aperture antenna, maximum power density Smax = O.lx 16 x h2 in mW /cm2,
where oBW
Pnet
D
h
71
The factor of 0.1 in i
= half -power beamwidth of the antenna, in degrees, and
= net power input to the antenna, in watts,
= distance from antenna, in meters,
= aperture height of the antenna, in meters, and
= aperture efficiency (unitless, typically 0.5 -0.8).
he numerators converts to the desired units of power density.
Far Field.
OET -65 gives this formula for calculating power density in the far field of an individual RF source:
power density S = 2.56 x 1.64 x 100 x RFF2 x ERP
in mW /cm2,
4x;rxD2
where ERP = total ERP (all polarizations), in kilowatts,
RFF = relative field factor at the direction to the actual point of calculation, and
D = distance from the center of radiation to the point of calculation, in meters.
The factor of 2.56 accounts for the increase in power density due to ground reflection, assuming a
reflection coefficient of 1.6 (1.6 x 1.6 = 2.56). The factor of 1.64 is the gain of a half -wave dipole
relative to an isotropic radiator. The factor of 100 in the numerator converts to the desired units of
power density. This formula has been built into a proprietary program that calculates, at each location
on an arbitrary rectangular grid, the total expected power density from any number of individual
radiation sources. The program also allows for the description of uneven terrain in the vicinity, to
obtain more accurate projections.
HAMMETT & EDISON, INC.
CONSULTING ENGINEERS Methodology
SAN FRANCISCO Figure 2
Verizon Wireless • Proposed Base Station (Site No. 291218 "Prospect & Miller SC3 ")
6175 Prospect Road • Saratoga, California
Statement of Hammett & Edison, Inc., Consulting Engineers
The firm of Hammett & Edison, Inc., Consulting Engineers, has been retained on behalf of Verizon
Wireless, a personal wireless telecommunications carrier, to evaluate the base station (Site No. 291218
"Prospect & Miller SC3") proposed to be located near 6175 Prospect Road in Saratoga, California, for
compliance with appropriate guidelines limiting human exposure to radio frequency ("R-F")
electromagnetic fields.
Executive Summary
Verizon proposes to install an antenna on top of the existing utility pole sited across the
street from 6175 Prospect Road in Saratoga. The proposed operation will comply with the
FCC guidelines limiting public exposure to RF energy.
Prevailing Exposure Standards
The U.S. Congress requires that the Federal Communications Commission ( "FCC ") evaluate its
actions for possible significant impact on the environment. A summary of the FCC's exposure limits
is shown in Figure 1. These limits apply for continuous exposures and are intended to provide a
prudent margin of safety for all persons, regardless of age, gender, size, or health. The most restrictive
FCC limit for exposures of unlimited duration to radio frequency energy for several personal wireless
services are as follows:
Wireless Service
Frequency Band
Occupational Limit
Public Limit
Microwave (Point -to- Point)
5 -80 GHz
5.00 mW /cm2
1.00 mW /cm2
WiFi (and unlicensed uses)
2-6
5.00
1.00
BRS (Broadband Radio)
2,600 MHz
5.00
1.00
WCS (Wireless Communication)
2,300
5.00
1.00
AWS (Advanced Wireless)
2,100
5.00
1.00
PCS (Personal Communication)
1,950
5.00
1.00
Cellular
870
2.90
0.58
SMR (Specialized Mobile Radio)
855
2.85
0.57
700 MHz
700
2.40
0.48
[most restrictive frequency range]
30-300
1.00
0.20
General Facility Requirements
Base stations typically consist of two distinct parts: the electronic transceivers (also called "radios" or
"channels ") that are connected to the traditional wired telephone lines, and the passive antennas that
send the wireless signals created by the radios out to be received by individual subscriber units. The
transceivers are often located at ground level and are connected to the antennas by coaxial cables. A
small antenna for reception of GPS signals is also required, mounted with a clear view of the sky.
HAmmm & EDISON, INC.
a CONSULTING ENGINEERS Q5BV
LJ SAN FRANCEsco Page 1 of 3
Verizon Wireless • Proposed Base Station (Site No. 291218 "Prospect & Miller SC3 ")
6175 Prospect Road • Saratoga, California
Because of the short wavelength of the frequencies assigned by the FCC for wireless services, the
antennas require line -of -sight paths for their signals to propagate well and so are installed at some
height above ground. The antennas are designed to concentrate their energy toward the horizon, with
very little energy wasted toward the sky or the ground. This means that it is generally not possible for
exposure conditions to approach the maximum permissible exposure limits without being physically
very near the antennas.
Computer Modeling Method
The FCC provides direction for determining compliance in its Office of Engineering and Technology
Bulletin No. 65, "Evaluating Compliance with FCC - Specified Guidelines for Human Exposure to
Radio Frequency Radiation," dated August 1997. Figure 2 describes the calculation methodologies,
reflecting the facts that a directional antenna's radiation pattern is not fully formed at locations very
close by (the "near - field" effect) and that at greater distances the power level from an energy source
decreases with the square of the distance from it (the "inverse square law "). The conservative nature
of this method for evaluating exposure conditions has been verified by numerous field tests.
Site and Facility Description
Based upon information provided by Verizon, including construction drawings by V -One Design
Group, Inc., dated February 3, 2015, it is proposed to install one Amphenol Model CWT360X06F
cylindrical antenna on top of the existing 42'/2 -foot utility pole sited in the public right -of -way on the
south side of Prospect Road, across the street from the residence located at 6175 Prospect Road. The
antenna would employ no downtilt, would be mounted at an effective height of about 50'/2 feet above
ground, and would provide service in all directions. The maximum effective radiated power in any
direction would be 850 watts, representing simultaneous operation at 350 watts for AWS,
350 watts for PCS, and 150 watts for 700 MHz service; no operation on cellular frequencies is
presently proposed from this site. There are reported no other wireless telecommunications base
stations at the site or nearby.
Study Results
For a person anywhere at ground, the maximum RF exposure level due to the proposed Verizon
operation is calculated to be 0.0024 mW /cm2, which is 0.34% of the applicable public exposure limit.
The maximum calculated level at the second -floor elevation of any nearby residence* is 0.55% of the
public exposure limit. It should be noted that these results include several "worst- case" assumptions
and therefore are expected to overstate actual power density levels from the proposed operation.
* Located at least 30 feet away, based on photographs from Google Maps.
HAMMETT & EDISON, INC.
CONSULTING ENGINEERS Q513V
SAN FRANCISCO Page 2 of 3
Verizon Wireless • Proposed Base Station (Site No. 291218 "Prospect & Miller SC3 ")
6175 Prospect Road • Saratoga, California
No Recommended Mitigation Measures
Due to its mounting location and height, the Verizon antenna would be accessible only to authorized
PG &E personnel, and so no mitigation measures are necessary to comply with the FCC public
exposure guidelines. To prevent exposures in excess of the occupational limit, it is expected that
PG &E workers will adhere to appropriate safety protocols adopted by that company.
Conclusion
Based on the information and analysis above, it is the undersigned's professional opinion that
operation of the base station proposed by Verizon Wireless near 6175 Prospect Road in Saratoga,
California, will comply with the prevailing standards for limiting public exposure to radio frequency
energy and, therefore, will not for this reason cause a significant impact on the environment. The
highest calculated level in publicly accessible areas is much less than the prevailing standards allow
for exposures of unlimited duration. This finding is consistent with measurements of actual exposure
conditions taken at other operating base stations.
Authorship
The undersigned author of this statement is a qualified Professional Engineer, holding California
Registration Nos. E -13026 and M- 20676, which expire on June 30, 2015. This work has been carried
out under his direction, and all statements are true and correct of his own knowledge except, where
noted, when data has been supplied by others, which data he believes to be correct.
May 13, 2015
HAMMETT & EDISON, INC.
CONSULTING ENGINEERS
SAN FRANC5M
Q� ` P�
j E- 13026
M -20676
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cc Ezp.6.30 -2015
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' William F. H ett, P.E.
707/996 -5200
Q513 V
Page 3 of 3
FCC Radio Frequency Protection Guide
The U.S. Congress required (1996 Telecom Act) the Federal Communications Commission ( "FCC ")
to adopt a nationwide human exposure standard to ensure that its licensees do not, cumulatively, have
a significant impact on the environment. The FCC adopted the limits from Report No. 86, "Biological
Effects and Exposure Criteria for Radiofrequency Electromagnetic Fields," published in 1986 by the
Congressionally chartered National Council on Radiation Protection and Measurements ( "NCRP ").
Separate limits apply for occupational and public exposure conditions, with the latter limits generally
five times more restrictive. The more recent standard, developed by the Institute of Electrical and
Electronics Engineers and approved as American National Standard ANSI/IEEE C95.1 -2006, "Safety
Levels with Respect to Human Exposure to Radio Frequency Electromagnetic Fields, 3 kHz to
300 GHz," includes similar limits. These limits apply for continuous exposures from all sources and
are intended to provide a prudent margin of safety for all persons, regardless of age, gender, size, or
health.
As shown in the table and chart below, separate limits apply for occupational and public exposure
conditions, with the latter limits (in italics and /or dashed) up to five times more restrictive:
Frequency
Applicable
Range
(MHz)
0.3— 1.34
1.34— 3.0
3.0— 30
30— 300
300— 1,500
1,500— 100,000
aA3
1000
100
10
1
0.1
Electromagnetic Fields (f is freauencv of emission in MHz
Electric
Magnetic
Equivalent Far -Field
Field Strength
Field Strength
Power Density
(V /m)
(A/m)
(mW /cm2)
614 614
1.63 1.63
100 100
614 823.81f
1.63 2.191f
100 18011
1842/ f 823.81f
4.89/ f 2.191f
900 / f 180/1
61.4 27.5
0.163 0.0729
1.0 0.2
3.54NFf 1.5Kf
4-f /106 if 1238
f /300 f/1500
137 61.4
0.364 0.163
5.0 1.0
Occupational Exposure
` f/ PCS
FM
f ��
Public EExxvosure
Cell
0.1 1 10 100 103 104 105
Frequency (MHz)
Higher levels are allowed for short periods of time, such that total exposure levels averaged over six or
thirty minutes, for occupational or public settings, respectively, do not exceed the limits, and higher
levels also are allowed for exposures to small areas, such that the spatially averaged levels do not
exceed the limits. However, neither of these allowances is incorporated in the conservative calculation
formulas in the FCC Office of Engineering and Technology Bulletin No. 65 (August 1997) for
projecting field levels. Hammett & Edison has built those formulas into a proprietary program that
calculates, at each location on an arbitrary rectangular grid, the total expected power density from any
number of individual radio sources. The program allows for the description of buildings and uneven
terrain, if required to obtain more accurate projections.
s ; 1 HAMMETT & EDISON, INC.
CONSULTING ENGINEERS FCC Guidelines
n >' °`J SAN FRANCISCO Figure 1
RFR.CALCT"' Calculation Methodology
Assessment by Calculation of Compliance with FCC Exposure Guidelines
The U.S. Congress required (1996 Telecom Act) the Federal Communications Commission ( "FCC ") to
adopt a nationwide human exposure standard to ensure that its licensees do not, cumulatively, have a
significant impact on the environment. The maximum permissible exposure limits adopted by the FCC
(see Figure 1) apply for continuous exposures from all sources and are intended to provide a prudent
margin of safety for all persons, regardless of age, gender, size, or health. Higher levels are allowed for
short periods of time, such that total exposure levels averaged over six or thirty minutes, for
occupational or public settings, respectively, do not exceed the limits.
Near Field.
Prediction methods have been developed for the near field zone of panel (directional) and whip
(omnidirectional) antennas, typical at wireless telecommunications base stations, as well as dish
(aperture) antennas, typically used for microwave links. The antenna patterns are not fully formed in
the near field at these antennas, and the FCC Office of Engineering and Technology Bulletin No. 65
(August 1997) gives suitable formulas for calculating power density within such zones.
For a panel or whip antenna, power density S = 180 x 0.1 x Put
8 ,n x D x h' in mW /cm2,
Bw
and for an aperture antenna maximum power density 0.1 x 16 x r1 x Pnet in mW /cm2
P P tY Smax — 7t x h2 f >
where 613W = half -power beamwidth of the antenna, in degrees, and
Pnet = net power input to the antenna, in watts,
D = distance from antenna, in meters,
h = aperture height of the antenna, in meters, and
rl = aperture efficiency (unitless, typically 0.5 -0.8).
The factor of 0.1 in the numerators converts to the desired units of power density.
Far Field.
OET -65 gives this formula for calculating power density in the far field of an individual RF source:
power density S = 2.56 x 1.64 x 100 x RFF2 x ERP
4 x n x D in mW /cm2,
where ERP = total ERP (all polarizations), in kilowatts,
RFF = relative field factor at the direction to the actual point of calculation, and
D = distance from the center of radiation to the point of calculation, in meters.
The factor of 2.56 accounts for the increase in power density due to ground reflection, assuming a
reflection coefficient of 1.6 (1.6 x 1.6 = 2.56). The factor of 1.64 is the gain of a half -wave dipole
relative to an isotropic radiator. The factor of 100 in the numerator converts to the desired units of
power density. This formula has been built into a proprietary program that calculates, at each location
on an arbitrary rectangular grid, the total expected power density from any number of individual
radiation sources. The program also allows for the description of uneven terrain in the vicinity, to
obtain more accurate projections.
HAMMETT & EDISON, INC.
mNSULTING FvciNFEES Methodology
1 SAN FRANCISCO Figure
L
il! riZOnwiretess
2785 Mitchell Drive
Walnut Creek, CA 94598
August 10, 2015
To: Saratoga City Council
From: Brian Ung, Radio Frequency Design Engineer,
Verizon Wireless Network Engineering Department
Subject: Statement in Support of Verizon Wireless's Proposed
Telecommunications Facilities in the Public Right -of -Way
near 19700 Prospect Road, 19848 Prospect Road, and Prospect Road
at Kristy Lane
Executive Summary
Verizon Wireless has identified a significant gap in its wireless services in the
north Saratoga area. This area is currently served by the existing Verizon
Wireless Westgate facility 1.2 miles to the east of the center of the gap; the
Highway 85 Saratoga facility 1 mile to the south; the Pierce Road facility 0.9
miles to the southwest; and the Blue Hills facility 0.75 miles to the northwest.
The nearest existing Verizon Wireless facilities to the north are well over two
miles distant and provide minimal to no service the area of the gap.
As a result of the distance of existing facilities and demands on the existing
network, there is an absence of in- building coverage in the north Saratoga area
as well as areas including important roadways that lack in- vehicle service.
Further, accelerated growth in voice and data usage by Verizon Wireless
customers has increased the demand on the existing Verizon Wireless network
in a manner that compromises network accessibility and reliability. This
accelerating growth in demand has led to capacity exhaustion of nearby facilities
as of 2015. The coverage gap and capacity gap described below constitute the
"significant gap" Verizon Wireless seeks to serve through a new facility (the
"Significant Gap "). To avoid further degradation of Verizon Wireless service in the
north Saratoga area, the Significant Gap must be remedied through construction
of new infrastructure, in this case, three small wireless facilities in the Prospect
Road right -of -way in Saratoga (the "Proposed Facilities ").
Coverage Gap
Verizon Wireless is experiencing a gap in in- building coverage roughly bounded
by Dartmoor Way and Janary Way to the north, Titus avenue to the east,
Somerville Drive to the south, and Highway 85 to the west. This in- building
coverage gap is primarily composed of residential areas. Additionally, a larger
area lacks in- vehicle coverage, particularly the neighborhood south of Rainbow
Drive. Notably, there is a lack of in- vehicle service on a portion of Prospect Road
east of its intersection with Miller Drive, with nearly 18,000 vehicle trips per day.'
(Collectively, the "Coverage Gap. ") A graphic description of the Coverage Gap is
shown in the map below. The Proposed Facility will provide new in- building
coverage to an area of approximately 0.9 square miles and a population of over
6,200 residents.
Coverage plot maps like that below provide important information regarding the
anticipated level of signal, and therefore the projected coverage provided by a
site at a given location. The areas in green reflect good coverage that meets or
exceed thresholds to provide consistent and reliable network coverage in
vehicles and in homes. The areas in yellow and red depict decreasing levels of
coverage, respectively, with yellow areas generally representing reliable in-
vehicle coverage, and red areas depicting poor service areas with marginal
coverage unsuitable for in- vehicle use.
Capacity Gap
The identified gap area is primarily served by the Alpha (east- facing) antenna
sector of the existing Verizon Wireless Pierce Road facility located 0.9 miles to
the southwest of the center of the gap area. This is apparent in the following
best server plot. Best server plots depict the dominant signal provided by each
antenna sector of nearby Verizon Wireless facilities. Signal from each sector is
City of Saratoga - Speed Survey, November 2013.
depicted in a different color. In the following best server plot, the dominant signal
of the Pierce Road facility's Alpha (east- facing) antenna sector is shown in light
brown, and includes the locations of the Proposed Facilities and the Coverage
Gap area.
At times of high traffic volume, the coverage area of this distant site shrinks to
accommodate an increasing number of mobile devices. As a result, the
Coverage Gap area actually expands during times of high customer usage. In
addition, the volume of voice and data services used by Verizon Wireless
customers has been increasing rapidly over time, nearly doubling every year.2
Verizon Wireless has modified its existing facility in an effort to maximize the
capacity available; however, as shown in the graphic below, increased demand
for voice and data services has already outstripped the capacity of the existing
site's Alpha sector that serves the gap area.
The below graphs show the increased usage over the last year as well as
predicted usage through 2016 for the existing Pierce Road facility Alpha sector.
By comparing the trend line of increasing usage (orange line) with the absolute
maximum capacity throughput and spectrum availability of this existing facility
(red line), Verizon Wireless RF engineering demonstrates that the existing site's
Alpha sector has reached capacity exhaustion. Achieving capacity exhaustion
severely compromises the Verizon Wireless network serving Saratoga, leading to
failed call attempts, dropped calls, poor call quality and slow data speeds (the
"Capacity Gap ").
2 Federal Communications Commission Report & Order 14 -153, October 17, 2014, ¶ 7.
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At times of high traffic volume, the coverage area of this distant site shrinks to
accommodate an increasing number of mobile devices. As a result, the
Coverage Gap area actually expands during times of high customer usage. In
addition, the volume of voice and data services used by Verizon Wireless
customers has been increasing rapidly over time, nearly doubling every year.2
Verizon Wireless has modified its existing facility in an effort to maximize the
capacity available; however, as shown in the graphic below, increased demand
for voice and data services has already outstripped the capacity of the existing
site's Alpha sector that serves the gap area.
The below graphs show the increased usage over the last year as well as
predicted usage through 2016 for the existing Pierce Road facility Alpha sector.
By comparing the trend line of increasing usage (orange line) with the absolute
maximum capacity throughput and spectrum availability of this existing facility
(red line), Verizon Wireless RF engineering demonstrates that the existing site's
Alpha sector has reached capacity exhaustion. Achieving capacity exhaustion
severely compromises the Verizon Wireless network serving Saratoga, leading to
failed call attempts, dropped calls, poor call quality and slow data speeds (the
"Capacity Gap ").
2 Federal Communications Commission Report & Order 14 -153, October 17, 2014, ¶ 7.
Capacity Graphs
Existing Pierce Road Facility
Alpha Sector
PIERCE RD - ALPHA
p 4000
2000
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500—
400—
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7/1/2014 111,r2015 7/1/2015 111/2016 7/1/2016
Conclusion
As cellular networks mature, distant sites must be supplemented with more sites
closer to customers, in large measure due to the increase in usage of the
network. In addition, certain fourth- and fifth- generation technologies require
facilities closer to customers and cannot be provided by the current distant site.
These coverage and capacity demands have resulted in the Significant Gap in
Verizon Wireless service in the north Saratoga area. Verizon Wireless must
deploy the Proposed Facilities to provide the in- building service coverage
required by customers and to avoid further degradation of its network in the area
of the identified Significant Gap.
Please feel free to contact me with any questions or comments regarding
Verizon Wireless's proposed facility.
Respectfully submitted,
frn Ung
RF Design Engineer
Network Engineering Department
Verizon Wireless
C
Verizon Wireless
Alternatives Analysis
Prospect & Miller SC1, SC2 and SC3
Verizon Wireless has identified a significant gap in coverage and network capacity in the north Saratoga
area. To remedy this significant gap, Verizon Wireless has investigated placement of new wireless
infrastructure within the area of the gap and proposes to place three new small wireless facilities on
utility poles in the public right -of -way along Prospect Road (the SC 1, SC2 and SC3 facilities).
Under Saratoga Municipal Code Section 15- 44.025(a) (the findings for design review approval of
wireless facilities), utility poles in the right -of -way are a favored location for new wireless facilities.
Verizon Wireless RF engineers determined that the minimum number of small utility-pole mounted
facilities needed to serve the coverage and network capacity gap is three facilities, placed at certain
locations along the Prospect Road right -of -way.
For each of these three locations on Prospect Road, Verizon Wireless evaluated nearby poles, reviewing
both utility poles and street light poles. In each case, Verizon Wireless considered the pole's ability to
support additional equipment, the ability to obtain authorization to use the pole from the pole owner,
equipment mounting specifications of California Public Utilities Commission General Order 95 and
whether the pole height is sufficient for mounting of antennas at a height that can serve the gap.
Additionally, Verizon Wireless has avoided placement of poles in close proximity front of front yards
facing Prospect Road where there is an alternative pole that does not directly impact such front yards.
The new service coverage provided by the Prospect & Miller SC 1, SC2 and SC3 facilities is depicted on
the coverage maps included at the end of this analysis.
For each of the Prospect & Miller SC 1, SC2 and SC3 facilities, Verizon Wireless has selected the pole
that meets the above criteria, each providing the least intrusive feasible means to serve to the gap.
Following are the results of the analysis for each of the Prospect & Miller SC 1, SC2 and SC3 facilities.
Prospect & Miller SC 1
'tight -of -Way near 19700 Prospect Road
PRIMARY CANDIDATE
Right -of -Way near 19700 Prospect Road
37 °17'36.65 "N, 1220 1'1.59 "W
This small wireless facility is proposed to be constructed on a Joint Pole
Authority ( "JPA ") pole located in the public right -of -way on the south
side of Prospect Road. The wooden utility pole is 42 feet 11 inches tall
and is located next to a large parking lot with trees adjacent to the pole
location. Similar -sized utility poles and street light poles are located
nearby along Prospect Road. Verizon Wireless proposed to mount a small
two -foot tall antenna on a wooden poletop extension to elevate antennas a
minimum of six feet above electrical conduits in compliance with
California Public Utilities Commission General Order 95. Small radio
cabinets and an electrical meter will be mounted to the side of the pole and
rotated away from the street to reduce the equipment profile. A small
ground- mounted equipment cabinet will be placed next to the utility pole.
The antenna and all equipment will be painted mesa brown to blend the
facility with surroundings in accordance with City of Saratoga design
review requirements. The coverage and network capacity gap to be served
by this facility is described in the Statement of Verizon Wireless Radio
Frequency Engineer Brian Ung dated August 10, 2015.
.LTERNATIVES - SC1
1. Utility Pole
37 017'36.55 "N 1220 0'58.55 "W
This wooden utility pole is located 240 feet east of the primary candidate.
In evaluating this pole's availability for placement of a wireless facility,
Verizon Wireless was advised by PG &E that the additional equipment could
not be mounted to this pole due to a large primary riser already located on
the side of the pole which carriers electrical conduit. Due to the inability to
locate additional equipment because of this obstruction, this pole is not a
feasible alternative for Verizon Wireless's facility.
2. Street Light
37 017'37.43 "N, 1220 0'58.00 "W
nis slender street light pole is located 300 feet northeast of the primary
candidate across Prospect Road. Verizon Wireless has been unable to
successfully negotiate a license agreement with the street light owner for use
of this pole. Lacking the ability to secure a license or lease agreement, this
is not a feasible alternative for Verizon Wireless's facility.
3. Street Light
37 017'37.65 "N, 1220 1'1.46 "W
This slender street light pole is located 100 feet north of the primary
candidate across Prospect Road. This pole is located adjacent to the front
yards of two homes. Verizon Wireless has been unable to successfully
negotiate a license agreement with the street light owner for use of this pole.
Lacking the ability to secure a license or lease agreement, and given the
high visibility, this is not a feasible alternative for Verizon Wireless's
cility.
4. Telco Pole
37 °17'37.69 "N, 122° 1'2.19 "W
This short pole is located 120 feet northwest of the primary candidate and
supports numerous fiber cables and down guy wires. Cable risers flush with
the pole prevent placement of Verizon Wireless's equipment while retaining
General Order 95 required climbing space. This pole is located adjacent to
the front yards of two homes. The pole is of insufficient height for an
antenna to provide radio frequency propagation to serve the coverage and
network capacity gap. Given the lack of available space on the pole for
mounting of equipment and the high visibility, this is not a feasible
alternative for Verizon Wireless's facility.
6- �,
5. Utility Pole
37 017'36.74 "N, 1220 114.54 11W
_ nis wooden utility pole is located 245 feet west of the primary candidate.
In evaluating this pole's availability for placement of a wireless facility,
Verizon Wireless was advised by PG &E that the additional equipment could
not be mounted to this pole due to a large primary riser already located on
the side of the pole which carriers electrical conduit. Due to the inability to
locate additional equipment because of this obstruction, this pole is not a
feasible alternative for Verizon Wireless's facility.
Conclusion
For SC 1, Verizon Wireless evaluated nearby utility poles and street light poles in the vicinity of
19700 Prospect Road to identify the feasible pole that could provide service to the coverage and
network capacity gap.
Alternative poles are infeasible due to obstructions limiting equipment placement, lack of ability
to obtain a license for use of a pole, insufficient pole height and impacts due to placement in
-)se proximity to front yards. Based on the foregoing analysis, Verizon Wireless considers the
imary candidate to be the least intrusive feasible utility pole for providing service to the
coverage and network capacity gap.
Map of SC1
Primary Candidate and Alternatives
Prospect & Miller SC2
'light -of -Way near 19848 Prospect Road
PRIMARY CANDIDATE
Right -of -Way near 19848 Prospect Road
37 °17'37.19 "N, 122° 1'16.52 11W
This small wireless facility is proposed to be constructed on a Joint Pole
Authority ( "JPA ") pole located in the public right -of -way on the south side
of Prospect Road. The wooden utility pole is 44 feet 9.5 inches tall, and is
located next to a community facility with a lawn that fronts Prospect Road.
Similar -sized utility poles and street light poles are located nearby along
Prospect Road, and there are numerous taller trees in the immediate
vicinity. Verizon Wireless proposed to mount a small two -foot tall antenna
on a wooden poletop extension to elevate antennas a minimum of six feet
above electrical conduits in compliance with California Public Utilities
Commission General Order 95. Small radio cabinets and an electrical
meter will be mounted to the side of the pole and rotated away from the
street to reduce the equipment profile. A small ground- mounted equipment
cabinet will be placed next to the utility pole. The antenna and all
equipment will be painted mesa brown to blend the facility with
surroundings in accordance with City of Saratoga design review
requirements. The coverage and network capacity gap to be served by this
facility is described in the Statement of Verizon Wireless Radio Frequency
ngineer Brian Ung dated August 10, 2015.
ALTERNATIVES - SC2
1. Utility Pole
37 017'37.11 "N 1220 1'13.27 "W
This wooden utility pole is located 260 feet east of the primary candidate.
In evaluating this pole's availability for placement of a wireless facility,
Verizon Wireless was advised by PG &E that the additional equipment
could not be mounted to this pole due to a large primary riser already
located on the side of the pole which carriers electrical conduit. Due to the
inability to locate additional equipment because of this obstruction, this
pole is not a feasible alternative for Verizon Wireless's facility.
2. Telco Pole
37 017'38.09 "N 1220 1'12.15 "W
his short pole is located 360 feet northeast of the primary candidate and
supports numerous fiber cables and down guy wires. There is a ground -
mounted cabinet located immediately adjacent to the pole. Cable risers
flush with the pole prevent placement of Verizon Wireless's equipment
while retaining General Order 95 required climbing space. The pole is of
insufficient height for an antenna to provide radio frequency propagation to
serve the coverage and network capacity gap. Given the lack of available
space on the pole for mounting of equipment, this is not a feasible
alternative for Verizon Wireless's facility.
3. Telco Pole and Street Light Pole
37 °17138.13 "N, 122° 1114.36 "W
This telco pole and street light pole are located directly next to one another
200 feet northeast of the Proposed Facility across Prospect Road. With the
poles located only a few feet apart, there is insufficient space for Verizon
Wireless's ground equipment, pole equipment and an antenna. Verizon
'ireless has been unable to successfully negotiate a license agreement with
the street light owner for use of the street light pole. The telco pole is of
insufficient height for an antenna to provide radio frequency propagation to
serve the coverage and network capacity gap, and existing fiber cables
impede placement of a poletop extension. Due to the close placement of
these poles preventing placement of equipment, this is not a feasible
alternative for Verizon Wireless's facility.
4. Telco Pole
37 °17'38.18 "N, 122° 1'16.02 "W
This short pole is located 110 feet north of the primary candidate across
Prospect Road and supports fiber cables and a down guy wire. This pole is ..,�
located adjacent to the front yards of two homes. The pole is of insufficient
height for an antenna to provide radio frequency propagation to serve the
coverage and network capacity gap, and existing fiber cables impede
placement of a poletop extension. Given the high visibility of this pole and
the lack of available space for mounting antennas of sufficient height, this
is not a feasible less intrusive alternative for Verizon Wireless's facility.
5. Telco Pole
37 017138.37 "N 1220 1'17.66 "W
.his short pole is located 135 feet northwest of the primary candidate
across Prospect Road and supports fiber cables. This pole is located
adjacent to the front yards of two homes. The pole is of insufficient height
for an antenna to provide radio frequency propagation to serve the coverage
and network capacity gap, and existing fiber cables impede placement of a
poletop extension. Given the high visibility of this pole and the lack of
available space for mounting antennas of sufficient height, this is not a
feasible less intrusive alternative for Verizon Wireless's facility.
6. Utility Pole
37 017137.47 "N, 1220 1'19.79 "W
This wooden utility pole is located 260 feet west of the primary candidate.
In evaluating this pole's availability for placement of a wireless facility,
Verizon Wireless was advised by PG &E that the additional equipment
could not be mounted to this pole due to a large primary riser already
located on the side of the pole which carriers electrical conduit, as well as
two transformers and an additional equipment box located on the side of the
ile. Due to the inability to locate additional equipment because of this
.,ostruction, this pole is not a feasible alternative for Verizon Wireless's
facility.
Conclusion
For SC2, Verizon Wireless evaluated nearby utility poles in the vicinity of 19848 Prospect Road
to identify the feasible pole that could provide service to the coverage and network capacity gap
with the least impacts.
Alternative poles are infeasible due to obstructions limiting equipment placement, lack of
climbing space, insufficient pole height and impacts due to placement in close proximity to front
yards. Based on the foregoing analysis, Verizon Wireless considers the primary candidate
located in the right -of -way next to 19848 Prospect Road to be the least intrusive feasible utility
pole for providing service to the coverage and network capacity gap.
Map of SC2
Primary Candidate and Alternatives
Prospect & Miller SC3
'tight -of -Way near Prospect Road and Kristy Lane
PRIMARY CANDIDATE
Right -of -Way near Prospect Road and Kristy Lane
37 017'36.12 "N, 1220 0'45.90 "W
This small wireless facility is proposed to be constructed on a Joint
Pole Authority ( "JPA ") pole located in the public right -of -way on the
south side of Prospect Road. The wooden utility pole is 42 feet 9.5
inches tall, and is located in proximity to large mature trees of similar
height to the pole. Similar -sized utility poles and street light poles are
located nearby along Prospect Road. Verizon Wireless proposed to
mount a small two -foot tall antenna on a wooden poletop extension to
elevate antennas a minimum of six feet above electrical conduits in
compliance with California Public Utilities Commission General Order
95. Small radio cabinets and an electrical meter will be mounted to the
side of the pole and rotated away from the street to reduce the
equipment profile. A small ground- mounted equipment cabinet will be
placed next to the utility pole. The antenna and all equipment will be
painted mesa brown to blend the facility with surroundings in
accordance with City of Saratoga design review requirements. The
coverage and network capacity gap to be served by this facility is
described in the Statement of Verizon Wireless Radio Frequency
— ngineer Brian Ung dated August 10, 2015.
ALTERNATIVES - SC3
1. Utility Pole
37 017'36.03 "N, 122° 0'43.84 "W
This wooden utility pole is located 160 feet east of the primary candidate. Close
proximity of adjacent evergreen trees would potentially interfere with RF signal
propagation from a facility at this location. General Order 95 requirements for
separation between foliage and equipment could require undesirable excessive
trimming of adjacent trees. The proximity of tall adjacent evergreen trees make
this location less desirable due to likely impact the trees and restricted RF
propagation. This is not a feasible alternative for Verizon Wireless's facility.
2. Utility Pole
37 017'35.91 "N 1220 0'40.50 "W
. his wooden utility pole is located 440 feet east of the primary candidate and
supports a transformer in addition to electrical cables. In evaluating this pole's
availability for placement of a wireless facility, Verizon Wireless was advised by
PG &E that the additional equipment could not be mounted to this pole due to a
large primary riser already located on the side of the pole which carriers
electrical conduit as well as the transformer. Due to the inability to locate
additional equipment because of these obstructions, this pole is not a feasible
alternative for Verizon Wireless's facility.
3. Utility Pole
37 017136.97 11N 1220 0140.01 "W
This wooden utility pole is located 460 feet northeast of the primary candidate
across Prospect Road and immediately adjacent to a bus stop with a bench. In
evaluating this pole's availability for placement of a wireless facility, Verizon
Wireless was advised by PG &E that, due to existing cross -arms, down guy wires
-td cables, mounting of Verizon Wireless's equipment would leave insufficient
imbing space which is required under California Public Utilities Commission
General Order 95. Due to the climbing space limitations, this is not a feasible
alternative for Verizon Wireless's facility.
4. Telco Pole and Street Light Pole
37 °17'36.98 "N, 122° 0'42.50 "W
This telco pole and street light pole are located directly next to one another 290
feet northeast of the Proposed Facility across Prospect Road. With the poles
located only a few feet apart, there is insufficient space for Verizon Wireless's
ground equipment, pole equipment and an antenna. Verizon Wireless has been
unable to successfully negotiate a license agreement with the street light owner
for use of the street light pole. The telco pole is of insufficient height for an
antenna to provide radio frequency propagation to serve the coverage and
network capacity gap, and existing fiber cables impede placement of a poletop
extension. Due to the close placement of these poles preventing placement of
equipment, this is not a feasible alternative for Verizon Wireless's facility.
5. Telco Pole
37 °17'37.06 "N, 122° 0'44.12 "W
_ nis short pole is located 170 feet northeast of the primary candidate and
supports numerous fiber cables and down guy wires. This pole is located
adjacent to the front yards of two homes. Cable risers flush with the pole
prevent placement of Verizon Wireless's equipment while retaining General
Order 95 required climbing space. The pole is of insufficient height for an
antenna to provide radio frequency propagation to serve the coverage and
network capacity gap. Given the lack of available space on the pole for
mounting of equipment and the high visibility, this is not a feasible alternative
for Verizon Wireless's facility.
6. Utility Pole
37 017'36.19 "N, 1220 0'48.12 "W
This wooden utility pole is located 180 feet west of the primary candidate. In
-aluating this pole's availability for placement of a wireless facility, Verizon
v ireless was advised by PG &E that the additional equipment could not be
mounted to this pole due to conduit risers as well as a transformer and an
additional small equipment box located on the side of the pole. Due to the
inability to locate additional equipment because of this obstruction, this pole is
not a feasible alternative for Verizon Wireless's facility.
Conclusion
N
For SC3, Verizon Wireless evaluated nearby utility poles in the vicinity of Prospect Road and
Kristy Lane to identify the feasible pole that could provide service to the coverage and network
capacity gap with the least impacts.
lternative poles are infeasible due to obstructions limiting equipment placement, lack of
available climbing space, insufficient pole height and impacts due to placement in close
proximity to front yards. Based on the foregoing analysis, Verizon Wireless considers the
primary candidate to be the least intrusive feasible utility pole for providing service to the
coverage and network capacity gap.
Map of SC3
Primary Candidate and Alternatives
Session: Prospect_Miller_SC_Appeal
User: bung
Thu Aug 6 20:08:32 2015
State Plane - California I
Datum: NAD83
Center Lat: 37 -17 -38.70 N
Center Lon: 122 -01 -07.95 W
Cells
Lbl: Cell Name
Sectors 44V;WZN
■ secondary-highway
■ arterial road
LTE RSRP
7CL1
Clr: Sector
❑ 6 -0142- 0000 -D1 APPLE
■ 6 -0142 - 0000 -D2 APPLE
IN 6- 0142 - 0000 -D3 APPLE
❑ 6 -0145- 0000 -D1 DEANZA
1116-0145-0000-132 DEANZA
■ 6- 0145 - 0000 -D3 DEANZA
■ 6- 0146- 0000 -Dt CUPERTINO
■6 -0146- 0000 -D2 CUPERTINO
■ 6- 0146 - 0000 -D3 CUPERTINO
[16-0147-0000-01 HWY 280 SARATOGA
❑ 6- 0147 - 0000 -D2 HWY 280 SARATOGA
® 6 -0147- 0000 -03 HWY 280 SARATOGA
■ 6- 0148 - 0000 -Dt BLUE HILLS
■ 6.0148- 0000 -D2 BLUE HILLS
❑ 6- 0148 -0000 -D3 BLUE HILLS
❑ 6- 0149- 0000 -D7 PIERCE RD
❑ 6- 0149 - 0000 -D2 PIERCE RD
■ 6- 0149- 0000 -D3 PIERCE RD
■6- 0150 - 0000 -Dt WESTGATE
■6- 0150- 0000 -D2 WESTGATE
■6- 0150- 0000 -D3 WESTGATE
❑ 6 -0151- 0000 -D1 HWY 85 SARATOGA
B 6-0151 -0000 -D2 HWY 85 SARATOGA
■ 6- 0151- 0000 -D3 HWY 85 SARATOGA
■ 6- 1026 - OKSC -D1 PROSPECT MILLER SC1
IN 6- 1027 - OKSC -D1 PROSPECT MILLER SC2
■ 6- 1028 - OKSC -D1 PROSPECT MILLER SC3
Shaded Terrain
Scale: 1:14979
1/10 Iles
Vel'Ijmmimless
GeoPlan v6.7
Proprietary and Confidential
Pp
PIE�EEWD
Best Server Plot Surround Prospect Miller SC
Proposed
n on
HWY 8(SA�ATOGA
yr