verizon wireless – project description cluster 2 september

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Cluster 2 Project Description - Page 1 Verizon Wireless – Project Description Cluster 2 September 25, 2017 Verizon Wireless is seeking approval for the design of proposed small cell attachments to wood poles owned and operated by the City of Palo Alto Utilities (CPAU). A brief overview is provided of Verizon Wireless’ citywide efforts to provide more robust wireless service to the City of Palo Alto through the colocation of small cells on existing city-owned utility poles and streetlights located in the public Right- of-Way. Small cells are currently proposed in three (3) configurations that are dependent on whether emergency battery backup is needed at a location, as well as the design opportunities and constraints of specific pole locations. This application for Architectural Review encompasses the second “cluster” or grouping of small cells and contains ten (10) proposed nodes, nine (9) of which are located in the Barron Park neighborhood. An additional small cell, proposed to provide service in the area of Stanford Shopping Center is also part of this application. Verizon Wireless sent notices to owners and occupants within over six hundred feet (600') for an April 26, 2017 community meeting, held at the Palo Alto Art Center. Community feedback was obtained and incorporated into the project prior to application submittal. The proposed project meets the requirements of PAMC 18.42.110 regarding Wireless Communication Facilities and supports the goals of Palo Alto Comprehensive Plan, including Goal B-3 for Palo Alto to service as a Regional Shopping, Services and Employment Center. Reliable wireless service is a critical aspect of the city’s infrastructure and these state of the art installations will provide essential communication capability for the citizens of Palo Alto, as well as emergency services for years to come. Project Overview Verizon Wireless has entered a Master License Agreement (“MLA”) with the City of Palo Alto allowing the attachment of antennas and other equipment (“small cells”) on city owned poles in the public Right- of-Way. Based on the need to provide network coverage and capacity, Verizon Wireless Radio engineers identify locations throughout the city that require service. Ninety-three (93) such wireless communication facility (“WCF”) installations are currently planned to be co-located on wood utility poles and metal streetlights. Approximately seventy-nine (79) of these small cells are proposed to be co- located on existing wood utility poles; fourteen (14) small cells are proposed to be installed on existing city streetlights. As such, no streetlight attachments are part of this application. These proposed small cells will provide the City of Palo Alto much needed improvements in network capacity and coverage. The proposal for a small cell network in Palo Alto is consistent with the goals of the comprehensive plan to contribute to economic vitality in the area. The proposed antenna node will provide additional network capacity and enhanced wireless communications services, which will benefit the public health, safety, convenience and welfare. The proposed antenna and equipment will be attached to existing wood utility poles in the public Right-of-Way. The equipment will blend in with the existing utility services to provide essential public infrastructure to the City of Palo Alto. The proposed small cells are an extension of existing utility service and will not conflict with adjacent uses or impede the normal use and development of surrounding properties. The public will be served with enhanced wireless communications services and additional network capacity.

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Page 1: Verizon Wireless – Project Description Cluster 2 September

Cluster 2 Project Description - Page 1

Verizon Wireless – Project Description Cluster 2

September 25, 2017

Verizon Wireless is seeking approval for the design of proposed small cell attachments to wood poles owned and operated by the City of Palo Alto Utilities (CPAU). A brief overview is provided of Verizon Wireless’ citywide efforts to provide more robust wireless service to the City of Palo Alto through the colocation of small cells on existing city-owned utility poles and streetlights located in the public Right-of-Way. Small cells are currently proposed in three (3) configurations that are dependent on whether emergency battery backup is needed at a location, as well as the design opportunities and constraints of specific pole locations. This application for Architectural Review encompasses the second “cluster” or grouping of small cells and contains ten (10) proposed nodes, nine (9) of which are located in the Barron Park neighborhood. An additional small cell, proposed to provide service in the area of Stanford Shopping Center is also part of this application. Verizon Wireless sent notices to owners and occupants within over six hundred feet (600') for an April 26, 2017 community meeting, held at the Palo Alto Art Center. Community feedback was obtained and incorporated into the project prior to application submittal. The proposed project meets the requirements of PAMC 18.42.110 regarding Wireless Communication Facilities and supports the goals of Palo Alto Comprehensive Plan, including Goal B-3 for Palo Alto to service as a Regional Shopping, Services and Employment Center. Reliable wireless service is a critical aspect of the city’s infrastructure and these state of the art installations will provide essential communication capability for the citizens of Palo Alto, as well as emergency services for years to come.

Project Overview Verizon Wireless has entered a Master License Agreement (“MLA”) with the City of Palo Alto allowing the attachment of antennas and other equipment (“small cells”) on city owned poles in the public Right-of-Way. Based on the need to provide network coverage and capacity, Verizon Wireless Radio engineers identify locations throughout the city that require service. Ninety-three (93) such wireless communication facility (“WCF”) installations are currently planned to be co-located on wood utility poles and metal streetlights. Approximately seventy-nine (79) of these small cells are proposed to be co-located on existing wood utility poles; fourteen (14) small cells are proposed to be installed on existing city streetlights. As such, no streetlight attachments are part of this application. These proposed small cells will provide the City of Palo Alto much needed improvements in network capacity and coverage. The proposal for a small cell network in Palo Alto is consistent with the goals of the comprehensive plan to contribute to economic vitality in the area. The proposed antenna node will provide additional network capacity and enhanced wireless communications services, which will benefit the public health, safety, convenience and welfare. The proposed antenna and equipment will be attached to existing wood utility poles in the public Right-of-Way. The equipment will blend in with the existing utility services to provide essential public infrastructure to the City of Palo Alto. The proposed small cells are an extension of existing utility service and will not conflict with adjacent uses or impede the normal use and development of surrounding properties. The public will be served with enhanced wireless communications services and additional network capacity.

Page 2: Verizon Wireless – Project Description Cluster 2 September

Cluster 2 Project Description - Page 2

Community Need for Small Cells The unprecedented current and future demand for wireless service requires the densification of existing cellular networks. As a result, wireless communication facilities are diminishing in height and being located closer to the user to meet both daily needs and provide essential coverage for emergency personnel. While terrain is relatively flat, the dense foliage of the tree canopy combined with difficulty in permitting macro wireless communication facilities presents unique challenges in the provision of wireless service to the City of Palo Alto. Verizon Wireless must increase both coverage and capacity throughout the city to meet current and future customer demand. Attachment A – Coverage Maps contains coverage maps that depict this need in the city. As the map demonstrates, there are significant gaps in the coverage area where Verizon Wireless has proposed the ten (10) Cluster 2 small cells.

Small Cells are the least visually intrusive method to provide the City of Palo Alto the required capacity and coverage. The miniaturization of the equipment used for cellular communications allows for these small cells to be located on existing infrastructure, reducing the need for new WCF structures and minimizing visual impact to the surrounding community. Additionally, these small cells can be located in areas where traditional “macro” wireless communication facilities cannot be located, so that essential communication services can be provided to critical areas all while co-locating on existing infrastructure. Furthermore, the addition of these small cells will both meet the current coverage and capacity needs, as well as provide the road map to future technologies for the next generation of wireless capability to the community in Palo Alto.

Pole Selection / Alternative Site Analysis Based on the need to provide network coverage and capacity, Verizon Wireless Radio Frequency engineers identify target locations or “nodes” throughout the city to improve and optimize network performance. Each proposed node is then visited by a team to identify existing city-owned structures available for attachment within the target engineering area. During this fielding walk, guidelines are applied by City of Palo Alto Utilities Engineering, as well as Verizon Wireless Engineering, Real Estate and Construction to determine the most suitable pole, subsequently identified as the “primary” location. Additional poles within the coverage area are designated as either viable alternatives or eliminated for the various reasons outlined in the Alternative Site Analysis for each node (Attachment D). The criteria used to select a pole in a given area have been compiled into the Small Cell Siting Guidelines (Attachment B).

As mentioned above, the first step when a location is identified by Engineering, is to visit the area and assess suitable structures for attachment. In some cases, there may be an existing WCF located on a utility pole in the area. While it may appear to make sense to collocate on the same pole as an existing WCF, this is not feasible for many reasons. First, Right-of-Way poles are small and can only support limited equipment. Placing additional equipment on a pole will very likely exceed the structural limits of the pole. Additionally, per CPUC General Order 95, a small cell is required to be attached to the pole in a way that preserves climbing space, defined as a quadrant (90-degree section) on the pole, and collocation would not allow for clear climbing space. Additionally, interference can present a problem in locating different carriers’ equipment on the same structure. Some carrier antennas and frequencies used need significant separation to avoid interference and most Right-of-Way poles don’t have enough space to allow for this separation. Additionally, we strive to provide the most seamless aesthetic design possible. Having multiple carriers on a pole means more antennas and more equipment boxes on the pole. For these reasons, Verizon Wireless has not proposed collocation on an existing WCF.

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Cluster 2 Project Description - Page 3

Beyond the Engineering Criteria, pole selection is based on a thoughtful consideration of the surrounding environment in which the proposed small cell is located. Poles with existing favorable site features such as landscaping and tree foliage are prioritized to provide natural screening to reduce the visual impact of small cell attachments. Wherever possible, poles are selected to reduce the impact on views from streets as well as adjacent residences. Site selection was further constrained to avoid poles located in private residential easements (e.g. backyards) and close proximity to second story windows.

Because small cells provide service over a small area, approximately six hundred (600) to twelve hundred (1200) feet, there is less flexibility in how far they can be moved from a defined engineering target. As a result, there are a limited number of existing structures, i.e. existing wood utility poles or streetlights that will meet the required engineering objective for any given small cell node.

In Attachment D – Node Level Small Cell Project Descriptions, Verizon Wireless has demonstrated some of the opportunities and constraints that determine which pole has been selected for each proposed small cell node. For each node, a map of poles located near the engineering target has been provided, along with a detailed table outlining the reasons why the alternate poles were not feasible.

As those alternative site analyses demonstrate, many seemingly suitable poles must be eliminated for engineering or other reasons. In fact, as these examples demonstrate, there is quite often only one suitable pole for a small cell within a designated coverage area.

Siting Guidelines Our team has drafted a list of criteria and constraints used in selecting a pole, presented in Attachment B – Siting Guidelines. Small cells differ from traditional “macro” cells in that their miniature quality dictates that they cover only a very small area and therefore can only move a short distance (measured in feet) within an identified area of need. In selecting a specific pole to serve an area, Verizon Wireless performs a thorough analysis of the existing infrastructure utilizing the to determine the most appropriate location.

The standards contained in the Small Cell Siting Guidelines working document have been developed by compiling the criteria and constraints of various regulating agencies. In siting small cells, Verizon Wireless is required to adhere to the standards of the California Public Utilities Commission (General Order 95 Requirements, Rule 94); the engineering and real estate requirements of property owner City of Palo Alto Utilities (CPAU); Development Standards for wireless communication facility (WCF) locations from PAMC §18.42.110(i); and the Architectural Review Findings of PAMC §18.76.020. Criteria have been further adjusted as city staff from Planning, Urban Forestry, CPAU, and the Art Department have all made time to attend site walks with Verizon Wireless real estate, engineering and construction teams in their fielding efforts. Additionally, previous small cell and DAS installations in the City of Palo Alto were analyzed to consider previous findings and recommendations by staff, the public and reviewing bodies.

Small Cell Node Design Requirements Verizon Wireless has engineered these small cells utilizing the most streamlined equipment currently available to meet the capacity and coverage requirements. For each small cell, Verizon Wireless network engineering requires one (1) antenna, three (3) radios, one (1) small electrical disconnect box, in some cases a battery backup unit located either on the pole or on the ground adjacent to the pole, and associated conduit for RF and electrical cabling. Details of the three various configurations of the

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Cluster 2 Project Description - Page 4

required equipment are depicted in Attachment C – Proposed Configurations. Further specifications of each piece of equipment are outlined on the detail pages (D-1 through D-3) of the site plans.

Much of the design for the pole-mounted equipment has been dictated by regulatory agencies, such as the California Public Utilities Commission (CPUC). It would be impossible within the scope of this document to cover the breadth, but in its General Order 95, the CPUC outlines a set of standards for utility pole attachments meant to ensure safety for the public, workers and equipment. To maintain the required clearance from power distribution, the antenna is mounted “above conductor” on a GO95 approved seven-foot (7') pole-top bayonet mount. If the antenna were to be mounted below conductor, then a two-foot (2’) offset from the pole would be required. Arrangement of the radios and associated equipment along the length of the pole is also fairly constrained. All pole mounted equipment must be located a minimum seven-foot (7') clearance from the ground; in this case CPAU requires a minimum of eight (8) feet. The required minimum four-inch (4") horizontal offset from the pole is maintained using a sled-style mount. Radios and associated equipment are attached to this mount as flush as is physically possible, given existing pole conditions, and in no case, is the distance greater than twelve inches (12"). This equipment must also be arranged on the pole in a manner that will preserve clear climbing space (90-degree quadrant), ensuring that utility workers have safe and reliable access to poles. Required small cell equipment specifications further constrain the way equipment can be attached. For example, the coaxial cable used to connect radios to the antenna must maintain a minimum bend radius of six inches (6"); anything less would cause damage to the cable compromising the performance of equipment.

To further its commitment to provide essential communications during a disaster resulting in loss of power, Verizon Wireless has proposed four (4) hours of battery backup on the most critical small cell nodes. Battery backup will provide essential network coverage for First Responders and users should power be lost. The City of Palo Alto Emergency Management Services uses the Verizon Wireless network for their cellular communication. Verizon Wireless Engineering has a strong preference to have emergency battery back up on all nodes in Cluster 2. However, Verizon Wireless recognizes the increased visual effect of additional batteries and to reduce that impact, has selected only the most essential locations. The batteries are contained in either one (1) ground mount battery cabinet or one (1) pole mount with an additional disconnect, and the additional associated cabling.

The equipment essential to a small cell has been arranged into the three (3) proposed configurations, with selection dependent on the engineering requirements of the particular small cell, as well as the constraints of a particular pole location. CPAU requires above conductor mounting of antennas, so they are always mounted on the pole top, creating a more streamlined appearance than a side-mount in the middle of the pole. If space exists on the pole, then radios are arranged vertically and as close as possible to the pole to minimize their appearance. For each node, a shade of brown has been selected to blend with the color of the existing utility pole. Conduits for fiber and power will also be painted the same shade of brown to blend with the existing pole. If the location is suitable for a ground box, then that is the preferred method of providing critical battery backup where it is required by engineering (Configuration #1). The three (3) radios are then arranged vertically up the pole. If emergency battery backup is required, but the pole location is not suitable for a ground based cabinet, then the battery unit is placed on the pole. In this case, the three (3) radios must be arranged horizontally to make space for the pole mounted battery unit (Configuration #2). Each small cell is served by both fiber and electrical power; in most cases, this is accomplished via an aerial drop on the pole.

Many of the design criteria for a small cell relate to safety and reducing visual blight. Because all pole mounted equipment must maintain a minimum mounting height of eight (8) feet, the public will not

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Cluster 2 Project Description - Page 5

have access to the equipment, which will prevent vandalism and graffiti. In the case of ground mounted equipment cabinets, they are located a minimum of five (5) feet from the pole. Periodic maintenance (1-2 times per year) is performed by Verizon Wireless technical staff. If maintenance is required, the Network Operations Center (NOC) contact information is located on the signage for each node.

PAMC Section 18.42.110(d)(8) requires that “For Tier 3 WCF Permits, the plans shall include a scaled depiction of the maximum permitted increase in the physical dimensions of the proposed project that would be permitted by the Spectrum Act, using the proposed project as a baseline.” For reasons set for in Attachment J, this is not feasible. Verizon Wireless is proposing all of the required equipment for these small cells.

No lighting or additional lighting is proposed for this project.

This project originally conceived with emergency battery backup in all cases, so all nodes were proposed as Configuration #1, with a ground mounted cabinet. After extensive community outreach and conversations with staff, batteries have been removed from 90% of nodes (11 nodes selected for battery backup). This more streamlined small cell seems appropriate in many of the residential areas, but it is worth noting that during our community outreach, there were also many residents who expressed a desire to have battery backup, so the small cell would remain operational in the event of a catastrophic power outage. If the community does feel strongly about this, Verizon is amenable to adding cabinets where it makes sense.

The assignment of configurations for each proposed small cell in Cluster 2 is provided in Attachment C – Cluster 2 Configurations; a map is provided in Attachment F –Map of Cluster 2 Configurations. As currently conceived, wood pole designs would require all pole mounted equipment to be painted brown to blend with the pole. In recognition that brown is not just brown, paint samples (Kelly Moore: Railroad Ties KMA67, Log Cabin KMA76 and Clay Bath KM4595) are included in Attachment G – Proposed Paint Samples. These are a digital approximation of the color and actual samples have been provided with our application.

Configurations

The three (3) unique equipment configurations are shown on page 2 of the Cluster 2 Plan Set, as well as

in Attachement C – Proposed Configurations.

For all configurations, climbing pegs are place only above eight and one-half feet (8.5') to prevent

unauthorized access.

Configuration #1: Emergency battery backup critical

The proposed Configuration 1 is designed with one (1) antenna, three (3) radios, and one (1) disconnect arranged vertically on the pole and the emergency battery backup cabinet installed on the ground adjacent to the pole. This is the Verizon Wireless Engineering preferred design as it contains emergency battery backup to maintain coverage for all three (3) radios for a total of four (4) hours, in case of a disaster resulting in loss of power. It is assumed that both fiber and power will be provided via an aerial drop from above on the pole minimizing the ground disturbance to a small (approximately five (5) to ten (10) feet) trench for this scenario.

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Cluster 2 Project Description - Page 6

For Configuration 1 only, the ground box is placed on a concrete pad, with a 54" tall cabinet, and is

currently conceived to be painted to blend with the surrounding area. Paint samples (Kelly Moore: Lone

Pine KM4798 and Acanthus Leaf KM4796) are included in Attachment G – Proposed Paint Samples. The

ground box is always placed a minimum distance of five (5) feet from the utility pole to prevent

climbing.

In addition to paint Verizon Wireless has engineered some street furniture options to provide further stealthing in areas where deemed necessary. Available street furniture options include benches, a green relay mailbox or trash can. The emergency battery cabinet also creates a unique opportunity for public art projects such as art wraps. All options are outlined in Attachment H – Proposed Ground Cabinet Stealth Options.

One (1) node in Cluster 2 is designed with Configuration 1. For reference, this location is shown in Attachment F –Map of Cluster 2 Configurations.

Configuration #2: Emergency battery backup essential, but no space

The proposed Configuration 2 is designed with one (1) antenna, three (3) radios, two (2) disconnects, and emergency battery cabinet, all located on the pole. Verizon Wireless selects this scenario for locations where battery is required, but there is insufficient space for a ground cabinet. The radios are arranged horizontally on the pole, to create space for the battery cabinet. The modification from a ground cabinet to a pole mounted design for the emergency does entail a significant concession in the capability. Configuration 2 will provide four (4) hours of battery backup for only one (1) radio on the small cell. In comparison, the ground mounted cabinet from Configurations 1 will provide a full four (4) hours of battery backup for all three (3) radios. As a result, when Configuration 2 is installed, in case of a disaster resulting in loss of power, there would be reduction in network capacity at this particular location. It is assumed that in most cases, both fiber and power will be provided via an aerial drop from above on the pole.

No nodes in Cluster 2 are designed with Configuration 2.

Configuration #3: Emergency battery backup currently not proposed

The proposed Configuration 3 is designed with one (1) antenna, three (3) radios, and one (1) disconnect installed. Battery backup is not proposed in this design.

As previously mentioned, Verizon Wireless Engineering prefers emergency battery backup at all small cell locations. However, given the potential visual impact, Verizon has decided not to request the additional equipment required to provide backup battery service. While the pole mounted battery in Configuration 2 represents a significant concession in emergency battery capability, it is critical to emphasize that Configuration 3 provides absolutely no emergency battery backup and in case of a disaster resulting in loss of power, there would be a significant reduction in network capacity and coverage at this particular location. It is assumed that in most cases, both fiber and power will be provided via an aerial drop from above on the pole.

Nine (9) nodes of Cluster 2 are designed with Configuration 3. For reference, these locations are shown in in Attachment F –Map of Cluster 2 Configurations.

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Cluster 2 Project Description - Page 7

Submission in Clusters Based on detailed discussions with the city, Verizon Wireless has agreed to submit the Conditional Use and Architectural Review (CUP/ARB) applications for consideration in separate “clusters”, easing the burden on staff with one staff report per cluster. The currently planned small cells have been divided based on geography. Cluster 2 consists of ten (10) proposed small cells, nine (9) of which are located in the Barron Park neighborhood. An additional small cell, proposed to provide service in the area of Stanford Shopping Center is also part of this application. Even though these proposed small cells will be submitted in clusters and are linked to the greater Verizon Wireless network, it is important to note that each wireless communication facility (WCF) acts independently of any other small cell. The utility of each node is therefore not dependent on a neighboring node.

Screening

Shroud

Verizon Wireless installed a temporary “shroud” at the model small cell (see below) to cover the cabling

between the three (3) radios on the pole, as requested by the Architectural Review Board at the May 18,

2017 Preliminary Review hearing. If the proposed shroud is deemed appropriate, it can be proposed on

all Configurations 1 and 3.

Landscaping

Verizon Wireless has worked closely with our project arborist, Urban Forestry and Planning to propose

trees in the public Right-of-Way, where deemed appropriate that will help to screen the proposed

equipment from various surrounding views. The proposed trees have been added to the Site Plan (page

A-1 of each node) and a New Tree Table placed beside the Existing Tree Table for ease of reference.

Careful consultation with Urban Forestry resulted in the species selection and size.

Model Small Cell To make transparent for staff and the community how a small cell will look when constructed, Verizon

Wireless has attached its equipment on a Configuration #1 on the CPAU wood utility pole adjacent to

1350 Newell Road, across from the Palo Alto Art Center. Both pole mounted equipment and the ground

mounted emergency battery backup cabinet are proposed to be located here. The proposed location of

the model small cell is shown in a photo in Attachment I – Model Small Cell. This is the best opportunity

to see a live example of the proposed small cells.

Update: On September 8, 2017 Verizon Wireless installed a temporary “shroud” at the model small cell

to cover the cabling between the three (3) radios on the pole, as requested by the Architectural Review

Board at the May 18, 2017 Preliminary Review hearing. If the proposed shroud is deemed appropriate, it

can be proposed on all Configurations 1 and 3.

Page 8: Verizon Wireless – Project Description Cluster 2 September

Cluster 2 Project Description - Page 8

Attachment A – Coverage Maps

Coverage Map – Cluster 2: Labels

The map below depicts the nodes from Cluster 2, the existing macros sites. For clarity, coverage is not

depicted here, but on the next maps. See legend for details. Blue circles represent a proposed node that

would transmit signal in all directions. “Pie-shaped” proposed sites represent small cell nodes with

fewer than three (3) sectors, i.e. the antenna has a directional signal pattern that is not in all directions.

Map of Labels: Streets, Node Numbers, Existing Macro Sites with Names

Page 9: Verizon Wireless – Project Description Cluster 2 September

Cluster 2 Project Description - Page 9

Coverage Map – Cluster 2: Existing Coverage

The map below depicts the nodes from Cluster 2 without the coverage that will be provided by them.

Only existing coverage provided by “macro” sites is shown (small cells turned off). See legend for details.

For clarity, site names and numbers are shown on the previous page. Blue circles represent a proposed

node that would transmit signal in all directions. “Pie-shaped” proposed sites represent small cell nodes

with fewer than three (3) sectors, i.e. the antenna has a directional signal pattern that is not in all

directions. As demonstrated by the map, coverage is marginal or poor in many locations.

Existing coverage area – 9 proposed small cells in Cluster 2 turned OFF.

Page 10: Verizon Wireless – Project Description Cluster 2 September

Cluster 2 Project Description - Page 10

Coverage Map – Cluster 2: Proposed Coverage

The map below depicts the coverage from the proposed nodes in Cluster 2 (small cells turned on).

Existing coverage provided by “macro” sites is also shown. See legend for details. For clarity, site names

and numbers are shown on the first map page. Blue circles represent a proposed node that would

transmit signal in all directions. “Pie-shaped” proposed sites represent small cell nodes with fewer than

three (3) sectors, i.e. the antenna has a directional signal pattern that is not in all directions. As

demonstrated by the map, coverage is significantly improved in many locations with the addition of

small cells.

Proposed Coverage – 9 small cells in Cluster 2 turned ON.

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Cluster 2 Project Description - Page 11

Coverage Map – SF PALO ALTO 163: Labels

The map below depicts the single node from Cluster 2. For clarity, coverage is not depicted here, but on

the next maps. See legend for details. Blue circles represent a proposed node that would transmit signal

in all directions. “Pie-shaped” proposed sites represent small cell nodes with fewer than three (3)

sectors, i.e. the antenna has a directional signal pattern that is not in all directions.

Map of Labels: Streets, Node Numbers, Existing Macro Sites with Names

Page 12: Verizon Wireless – Project Description Cluster 2 September

Cluster 2 Project Description - Page 12

Coverage Map – Cluster 2: Existing Coverage

The map below depicts coverage without SF PALO ALTO 163. Only existing coverage provided by

“macro” sites is shown (small cells turned off). See legend for details. For clarity, site names and

numbers are shown on the previous page. Blue circles represent a proposed node that would transmit

signal in all directions. “Pie-shaped” proposed sites represent small cell nodes with fewer than three (3)

sectors, i.e. the antenna has a directional signal pattern that is not in all directions. As demonstrated by

the map, coverage is marginal or poor in many locations.

Existing coverage – SF PALO ALTO 163 small cell in Cluster 2 turned OFF.

Page 13: Verizon Wireless – Project Description Cluster 2 September

Cluster 2 Project Description - Page 13

Coverage Map – Cluster 2: Proposed Coverage

The map below depicts the coverage that will be provided by SF PALO ALTO 163. Existing coverage

provided by “macro” sites is also shown. See legend for details. For clarity, site names and numbers are

shown on the previous page. Blue circles represent a proposed node that would transmit signal in all

directions. “Pie-shaped” proposed sites represent small cell nodes with fewer than three (3) sectors, i.e.

the antenna has a directional signal pattern that is not in all directions. As demonstrated by the map,

coverage is significantly improved in many locations with the addition of a single node.

Existing coverage – SF PALO ALTO 163 small cell in Cluster 2 ON.

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Cluster 2 Project Description - Page 14

Attachment B – Small Cell Siting Guidelines

Drafted by Vinculums Services, on behalf of Verizon Wireless

Vinculums Services has created this working document on behalf of Verizon Wireless, a compilation of

criteria and constraints of various regulating agencies, regarding the selection of poles for small cells in

Palo Alto. Verizon Wireless is required to adhere to the standards of the California Public Utilities

Commission (General Order 95 Requirements); the engineering and real estate requirements of

property owner City of Palo Alto Utilities (CPAU); and City of Palo Alto Development Standards for

wireless communication facility (WCF) locations from PAMC §18.42.110(i); and the Architectural Review

Findings of PAMC §18.76.020.

Engineering Criteria

Nature of Small Cells--small cells differ from traditional “macro” cells in that their miniature quality

dictates that they can only move a very small distance (measured in feet) and still serve their intended

purpose.

Verizon Wireless engineering proposed locations are fielded using the criteria below to select a utility pole or streetlight from existing city infrastructure:

City of Palo Alto Utility (Pole Owner) Pole Attachment Mandates

All Attachments must meet California Public Utilities General Order 95

o Clear climbing space – minimum of 90-degree quadrant

o Clearances between power conduction and/or other attachments

o Required distances for separation between pole and equipment

o Required distances for separation between equipment

o Minimum height of attachment

City of Palo Alto Utilities (CPAU) prioritizes the provision of service to its customers. The siting of

attachments on poles is secondary and therefore:

o No attachments allowed on poles with primary power risers

o No attachments allowed on poles with transformers or other special equipment

o Primary Line and Buck (primary power lines attaching to the pole at 90 degrees or in

perpendicular fashion) situations have a modified climbing space requirement, requiring

more pole real estate than otherwise required under CA Public Utility Code

o Various other situations where the provision of electrical service would be compromised

by attachment

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Cluster 2 Project Description - Page 15

City of Palo Alto Utility Preferences (in order of importance)

1. Guy stubs - Poles that do not have any electrical or communications; they simply provide a

structural tie point for a guy wire for a neighboring pole

2. Poles with overhead secondary power conductors only – Secondary power (typically) being the

second from the top level of power on the pole and which provides residential power (120/240

Volts AC)

3. Primary dead-end poles – A pole at the end of a line of poles which no poles further down the

line

4. Primary poles with no transformers downstream on the poles to end of line of poles

5. Primary poles with no electric utility equipment on the poles on either side of the proposed pole

Development Criteria

Development Standards from PAMC §18.42.110(i)

Shall utilize the smallest footprint possible

Shall be designed to minimize the overall height, mass, and size of the cabinet and enclosure

structure

Be screened from public view

Be architecturally compatible with the existing site

Be placed at a location that would not require the removal of any required landscaping or would

reduce the quantity of landscaping to a level of noncompliance with the Zoning Code

An Antenna, Base Station, or Tower shall be designed to minimize its visibility from off-site

locations and shall be of a "camouflaged" or "stealth" design, including concealment, screening,

and other techniques to hide or blend the Antenna, Base Station, or Tower into the surrounding

area

Planning and Residential Considerations

Poles preferred in the public Right-of-Way are selected. Poles on Public Utility Easements are

not generally selected for attachment

Prioritize poles which have tree foliage close to help camouflage the pole mounted equipment

Prioritize poles that are located near evergreen trees, rather than deciduous trees

Select a location for ground based emergency battery equipment that meets standards

identified in Tree Technical Manual

Face the pole mounted equipment away from direct views of the adjacent home, toward the

street when no foliage is present to hide the equipment

Consolidate equipment to reduce the visual clutter; move the ground mounted equipment onto

the pole when there is not enough Right-of-Way or deemed too obtrusive to the residents

In general, prefer locations mid-block instead of at more visible corners/intersections

Determine the most advantageous location that is least disruptive to views from both

pedestrian and the adjacent residences

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Cluster 2 Project Description - Page 16

Attachment C – Proposed Configurations

Below is a simplified elevation drawing of all proposed equipment Configurations 1, 2 and 3.

See page 2 of the Cluster 2 plan set provided for examples of each proposed configuration for wood

utility poles.

Configuration #1 Configuration #2 Configuration #3

Page 17: Verizon Wireless – Project Description Cluster 2 September

Cluster 2 Project Description - Page 17

Attachment D – Node Level Small Cell Project Descriptions

Below is a detailed description of each of the selected nodes, including the Alternative Site Analysis

about how we selected the pole, as well as the criteria and constraints surrounding the design

configuration selected for that pole.

SF PALO ALTO 100

Only one pole was available to meet the engineering objective. The pole is well screened by the existing

trees. The pole mounted equipment is proposed to be painted Log Cabin to blend with the reddish-

brown color of the existing wood pole. This node was not selected for emergency battery backup at this

location, so Configuration #3 has been selected (only pole mounted equipment).

Page 18: Verizon Wireless – Project Description Cluster 2 September

Cluster 2 Project Description - Page 18

SF PALO ALTO 100 Alternative Site Analysis

Alternative

Candiate ID

Structure

Type

Fallout

ReasonPole # Fallout Note

100-AWood

Utility Pole

CPAU

EngineeringUnknown

Utility engineering constraints would not allow an attachment. Primary riser located on

pole.

100-BWood

Utility Pole

CPAU

Engineering1653

Utility engineering constraints would not allow an attachment. High voltage lines located on

pole.

100-CWood

Utility Pole

CPAU

Engineering1655

Utility engineering constraints would not allow an attachment. High voltage lines located on

pole.

100-DWood

Utility Pole

VZW RF

Engineering5771

Pole is too short and has significant tree clutter.

100-EWood

Utility Pole

CPAU

Engineering1464

Utility engineering constraints would not allow an attachment. Transformer located on the

pole.

100-FWood

Utility Pole

CPAU

Engineering1462

Utility engineering constraints would not allow an attachment. Transformer located on the

pole. Additionally, high voltage lines located on pole.

Page 19: Verizon Wireless – Project Description Cluster 2 September

Cluster 2 Project Description - Page 19

100 Photo Simulation

Page 20: Verizon Wireless – Project Description Cluster 2 September

Cluster 2 Project Description - Page 20

SF PALO ALTO 101

Only one pole was available to meet the engineering objective. The pole is well screened by the existing

trees. The pole mounted equipment is proposed to be painted Clay Bath to blend with the faded wood

of the existing wood pole. This node was not selected for emergency battery backup at this location, so

Configuration #3 has been selected (only pole mounted equipment).

Page 21: Verizon Wireless – Project Description Cluster 2 September

Cluster 2 Project Description - Page 21

SF PALO ALTO 101 Alternative Site Analysis

Alternative

Candiate ID

Structure

Type

Fallout

ReasonPole # Fallout Note

101-AMetal

Street Light

VZW RF

Engineering419

Pole is too short.

101-BWood

Utility Pole

CPAU

Engineering1606

Utility engineering constraints would not allow an attachment. Transformer located on the

pole.

101-CMetal

Street Light

VZW RF

Engineering418

Pole is too short.

101-DWood

Utility Pole

CPAU

Engineering1628

Utility engineering constraints would not allow an attachment. High voltage lines located on

pole.

101-EWood

Utility Pole

CPAU

Engineering1629

Utility engineering constraints would not allow an attachment. High voltage lines located on

pole.

101-FWood

Utility Pole

CPAU

Engineering

Unknown

Backyard

Pole

Utility engineering constraints would not allow an attachment. Transformer located on the

pole. Additionally, poles located in private property (residential easements) are only selected

as a last resort, given potential disturbance to adjacent neighbor.

Page 22: Verizon Wireless – Project Description Cluster 2 September

Cluster 2 Project Description - Page 22

SF PALO ALTO 101 Photo Simulation

Page 23: Verizon Wireless – Project Description Cluster 2 September

Cluster 2 Project Description - Page 23

SF PALO ALTO 102

There was only one viable pole available in this area. This node was not selected for emergency battery

backup and so Configuration #3 with only pole is proposed to be painted Railroad Ties to blend. While

siting on a corner is not preferred, there is an existing tree adjacent to the proposed site that will help to

conceal the small cell.

SF PALO ALTO 102 Alternative Site Analysis

Alternative

Candiate ID

Structure

Type

Fallout

ReasonPole # Fallout Note

102-AWood

Utility Pole

CPAU

Engineering201

Utility engineering constraints would not allow an attachment. Primary riser located on

pole.

102-BWood

Utility Pole

VZW RF

EngineeringUnknown

Pole is too short and has significant tree clutter. Additionally, power lines are located over

the pole.

102-CWood

Utility Pole

CPAU

Engineering200

Utility engineering constraints would not allow an attachment. Transformer located on the

pole.

102-DWood

Utility Pole

CPAU

Engineering0198

Utility engineering constraints would not allow an attachment. Primary riser located on

pole.

102-EWood

Utility Pole

CPAU

Engineering0196

Utility engineering constraints would not allow an attachment. Transformer located on the

pole.

Page 24: Verizon Wireless – Project Description Cluster 2 September

Cluster 2 Project Description - Page 24

SF PALO ALTO 102 Photo Simulation

Page 25: Verizon Wireless – Project Description Cluster 2 September

Cluster 2 Project Description - Page 25

SF PALO ALTO 103

Two poles were viable in this service area. Both are similarly situated along Alma Street, but the primary

pole was selected as existing trees and vegetation provide better screening. This node was not selected

for emergency battery backup and Configuration #3 with only pole mounted equipment was chosen.

The pole mounted equipment will be painted Log Cabin to blend with the reddish-brown wood pole.

SF PALO ALTO 103 Alternative Site Analysis

Alternative

Candiate ID

Structure

Type

Fallout

ReasonPole # Fallout Note

103-AWood

Utility Pole

CPAU

Engineering2302

Utility engineering constraints would not allow an attachment. CPUC GO95 rules require

clear climbing space. There is not enough climbing space on this pole to safely allow a VZW

103-BWood

Utility Pole

VZW RF

Engineering2303

Pole is too short.

103-CWood

Utility Pole

CPAU

Engineering2304

Utility engineering constraints would not allow an attachment. Transformer located on the

pole.

103-DWood

Utility PoleN/A 2306

Pole is viable alternate, but was not selected as primary. It is first alternate candidate.

103-EMetal

Street Light

VZW RF

Engineering371

Pole is too short.

Page 26: Verizon Wireless – Project Description Cluster 2 September

Cluster 2 Project Description - Page 26

SF PALO ALTO 103 Photo Simulation

Page 27: Verizon Wireless – Project Description Cluster 2 September

Cluster 2 Project Description - Page 27

SF PALO ALTO 104

Only one pole in this area would meet the required engineering objective. The selected primary pole is

located between two driveways, which is preferred to siting directly in front of a residence. This node

was not selected for emergency battery backup and so Configuration #3 with only pole mounted

equipment was selected. This utility pole is a chocolate brown and so Railroad Ties has been selected to

paint the equipment to blend with the pole.

SF PALO ALTO 104 Alternative Site Analysis

Alternative

Candiate ID

Structure

Type

Fallout

ReasonPole # Fallout Note

104-AMetal

Street Light

VZW RF

Engineering061

Pole is too short.

104-BWood

Utility Pole

CPAU

Engineering0001

Utility engineering constraints would not allow an attachment. Primary riser located on

pole.

104-CWood

Utility Pole

CPAU

Engineering0003

Utility engineering constraints would not allow an attachment. Transformer located on the

pole.

104-DWood

Utility Pole

CPAU

Engineering0016

Utility engineering constraints would not allow an attachment. Transformer located on the

pole.

Page 28: Verizon Wireless – Project Description Cluster 2 September

Cluster 2 Project Description - Page 28

SF PALO ALTO 104 Photo Simulation

Page 29: Verizon Wireless – Project Description Cluster 2 September

Cluster 2 Project Description - Page 29

SF PALO ALTO 153

Only one pole was viable for this service area. The primary pole along Whitsell is located between two

residences adjacent to a large redwood tree, which provides natural screening. This node was selected

for emergency battery backup and so Configuration #1 with only ground mounted equipment was

selected. This utility pole is a chocolate brown and so Railroad Ties has been selected to paint the

equipment to blend with the pole. The ground mounted cabinet is proposed to be painted Railroad Ties

to blend with the fence.

SF PALO ALTO 153 Alternative Site Analysis

Alternative

Candiate ID

Structure

Type

Fallout

ReasonPole # Fallout Note

153-AWood

Utility Pole

CPAU

Engineering0345

Utility engineering constraints would not allow an attachment. Transformer located on the

pole.

153-BWood

Utility Pole

VZW RF

Engineering0301

Pole not plumb. Significant leaning.

153-CWood

Utility Pole

CPAU

Engineering0300

Utility engineering constraints would not allow an attachment. Transformer located on the

pole.

153-DWood

Utility Pole

CPAU

Engineering0317

Utility engineering constraints would not allow an attachment. Transformer located on the

pole. Additionally, this is a line and buck situation.

153-EWood

Utility Pole

CPAU

Engineering0303

Utility engineering constraints would not allow an attachment. Line and buck situation on

pole - wireless equipment not permitted.

Page 30: Verizon Wireless – Project Description Cluster 2 September

Cluster 2 Project Description - Page 30

SF PALO ALTO 153 Photo Simulation

Page 31: Verizon Wireless – Project Description Cluster 2 September

Cluster 2 Project Description - Page 31

SF PALO ALTO 154

Three poles in this area would meet the required engineering objective. The small cell along Barron Ave.

is proposed to be located on the existing wood utility pole between two driveways. This node was not

selected for emergency battery backup and so Configuration #3 with only pole mounted equipment was

selected. This utility pole is a chocolate brown and so Railroad Ties has been selected to paint the

equipment to blend with the pole.

154 Alternative Site Analysis

Alternative

Candiate ID

Structure

Type

Fallout

ReasonPole # Fallout Note

154-AWood

Utility Pole

CPAU

Engineering0239

Utility engineering constraints would not allow an attachment. Transformer located on the

pole.

154-BWood

Utility Pole

CPAU

Engineering02344

Utility engineering constraints would not allow an attachment. CPUC GO95 rules require

clear climbing space. There is not enough climbing space on this pole to safely allow a VZW

attachment.

154-CWood

Utility PolePlanning 0253

High visibility corners are not preferred per the planning siting guidelines.

154-DWood

Utility PoleN/A 0256

Pole is viable alternate, but was not selected as primary. It is first alternate candidate.

154-EWood

Utility Pole

CPAU

Engineering0233

Utility engineering constraints would not allow an attachment. Transformer located on the

pole.

Page 32: Verizon Wireless – Project Description Cluster 2 September

Cluster 2 Project Description - Page 32

SF PALO ALTO 154 Photo Simulation

Page 33: Verizon Wireless – Project Description Cluster 2 September

Cluster 2 Project Description - Page 33

SF PALO ALTO 155

The primary pole for this node was selected along Los Robles Ave., where the existing trees and

vegetation provide natural screening. This node was not selected for emergency battery backup and so

Configuration #3 with only pole mounted equipment was selected. The pole mounted equipment will be

painted Railroad Ties to blend with the wood pole.

A second pole located on Amaranta Ave. is also viable for attachment. SF PALO ALTO 155-F will also

meet the required engineering objective and Verizon is willing to attach its small cell equipment to this

existing wood utility pole, if that is a preferred location.

SF PALO ALTO 155 Alternative Site Analysis

Page 34: Verizon Wireless – Project Description Cluster 2 September

Cluster 2 Project Description - Page 34

Alternative

Candiate ID

Structure

Type

Fallout

ReasonPole # Fallout Note

155-AWood

Utility Pole

VZW RF

Engineering0125

Low height. Located in yard. Significant tree clutter around pole and difficult to mount

pole equipment with tree.

155-BWood

Utility Pole

CPAU

Engineering0113

Utility engineering constraints would not allow an attachment. Transformer located on the

pole.

155-CWood

Utility Pole

CPAU

Engineering0111

Utility engineering constraints would not allow an attachment. Transformer located on the

pole.

155-DWood

Utility Pole

CPAU

Engineering0108

Utility engineering constraints would not allow an attachment. Line and buck situation on

pole - wireless equipment not permitted.

155-EWood

Utility Pole

CPAU

Engineering0110

Utility engineering constraints would not allow an attachment. Line and buck situation on

pole - wireless equipment not permitted.

155-FWood

Utility PoleViable Unknown

Viable alternate, although a little far from original target.

Page 35: Verizon Wireless – Project Description Cluster 2 September

Cluster 2 Project Description - Page 35

SF PALO ALTO 155 Photo Simulation

SF PALO ALTO 155-F (ALTERNATE)

Page 36: Verizon Wireless – Project Description Cluster 2 September

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SF PALO ALTO 157

This node was not selected for emergency battery backup and so Configuration #3 with only pole

mounted equipment was selected. This node was not selected for emergency battery backup and so

Configuration #3 with only pole mounted equipment was selected. The pole is a reddish-brown and so

Log Cabin has been selected to paint the equipment to blend.

SF PALO ALTO 157 Alternative Site Analysis

Alternative

Candiate ID

Structure

Type

Fallout

ReasonPole # Fallout Note

157-AWood

Utility Pole

VZW RF

Engineering0524

Utility engineering constraints would not allow an attachment. Line and buck situation on

pole - wireless equipment not permitted.

157-BWood

Utility Pole

CPAU

EngineeringJPA

Pole not plumb. Significant leaning. Additionally, there is existing equipment on the pole.

157-CWood

Utility Pole

CPAU

Engineering0533

Not selected as primary because high visibility corners are not preferred per the planning

siting guidelines.

157-DWood

Utility Pole

VZW RF

Engineering0534

Pole not plumb. Significant leaning.

157-EWood

Utility Pole

CPAU

Engineering0540

Utility engineering constraints would not allow an attachment. Transformer located on the

pole.

Page 37: Verizon Wireless – Project Description Cluster 2 September

Cluster 2 Project Description - Page 37

SF PALO ALTO 157 Photo Simulation

Page 38: Verizon Wireless – Project Description Cluster 2 September

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SF PALO ALTO 163

Only one pole was viable to service this area. This node was not selected for emergency battery backup

and so Configuration #3 with only pole mounted equipment was selected. The pole has faded and

therefore all pole mounted equipment will be painted Clay Bath to blend. The cabinet has been

proposed to be painted Acanthus Leaf, to blend with the lighter green color on existing utility cabinets in

the Right-of-Way.

SF PALO ALTO 163 Alternative Site Analysis

Alternative

Candiate ID

Structure

Type

Fallout

ReasonPole # Fallout Note

163-AWood

Utility Pole

CPAU

Engineering6447

Utility engineering constraints would not allow an attachment. High voltage lines located on

pole.

163-BWood

Utility Pole

CPAU

Engineering6448

Utility engineering constraints would not allow an attachment. High voltage lines located on

pole.

163-CWood

Utility Pole

CPAU

Engineering6450

Utility engineering constraints would not allow an attachment. High voltage lines located on

pole.

163-DMetal

Street Light

VZW RF

Engineering31

Pole is too short.

163-EMetal

Street Light

VZW RF

Engineering32

Pole is too short.

Page 39: Verizon Wireless – Project Description Cluster 2 September

Cluster 2 Project Description - Page 39

SF PALO ALTO 163 Photo Simulation

Page 40: Verizon Wireless – Project Description Cluster 2 September

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Attachment E – List of Cluster 2 Nodes

Cluster 2 contains ten (10) proposed small cell nodes.

Node Adjacent Address Pole Type Config CPAU Pole

#

1A Verified Adjacent APN

Adjacent APN

Zoning Class

SF PALO ALTO 100 4104 EL CAMINO

WY Wood Utility

Config 3 1656 13246090 R-1

SF PALO ALTO 101 4193 WILKIE WAY Wood Utility

Config 3 1608 13245049 R-1

SF PALO ALTO 102 4010 VILLA VERA Wood Utility

Config 3 0197 13723056 PC-2390

SF PALO ALTO 103 3715 STARR KING CL Wood Utility

Config 3 2305 13230009 R-1

SF PALO ALTO 104 4206 SUZANNE DR Wood Utility

Config 3 0002 16707018 R-1

SF PALO ALTO 153 3715 WHITSELL AVE Wood Utility

Config 1 0302 13711001 R-1

SF PALO ALTO 154 785 BARRON AVE Wood Utility

Config 3 0238 13713022 R-1

SF PALO ALTO 155 792 LOS ROBLES AVE Wood Utility

Config 3 0112 13713113 R-1

SF PALO ALTO 157 3993 LAGUNA AVE Wood Utility

Config 3 0523 13714012 R-1

SF PALO ALTO 163 180 EL CAMINO

REAL Wood Utility

Config 3 6884 14201009 CC

Page 41: Verizon Wireless – Project Description Cluster 2 September

Cluster 2 Project Description - Page 41

Attachment F –Map of Cluster 2 Configurations

Ten (10) proposed nodes from Cluster 2 are identified, along with their proposed Configurations 1, 2

and 3.

Configuration 1 (1 nodes): Emergency battery backup critical, placed in ground mounted box adjacent to

pole.

Configuration 2 (0 nodes): Emergency battery backup essential, but no space; small battery placed on

pole.

Configuration 3 (11 nodes): Emergency battery backup currently not required. No emergency battery.

Page 42: Verizon Wireless – Project Description Cluster 2 September

Cluster 2 Project Description - Page 42

Attachment G – Proposed Paint Samples

Pole Mounted Equipment (all Kelly Moore durable metal paint)

Railroad Ties (KMA67) Log Cabin (KMA76)

Clay Bath (KM4595)

Ground Mounted Equipment (all Kelly Moore durable metal paint)

Lone Pine (KM4798) Acanthus Leaf (KM4796

Page 43: Verizon Wireless – Project Description Cluster 2 September

Cluster 2 Project Description - Page 43

Attachment H – Proposed Ground Cabinet Stealth Options

Landscaping

Ground mounted emergency battery equipment with landscaping.

Street Furniture Options

Concrete Bench

Page 44: Verizon Wireless – Project Description Cluster 2 September

Cluster 2 Project Description - Page 44

Relay Mailbox

Metal Bench

Garbage Can

Page 45: Verizon Wireless – Project Description Cluster 2 September

Cluster 2 Project Description - Page 45

Art-Wrapped Cabinets

Ground mounted emergency battery cabinet without wrap.

Examples of Existing Art Wraps (located Downtown Walnut Creek)

Please note that these cabinets are significantly larger than the proposed emergency battery cabinet,

which is placed on a 32" x 43" concrete pad, with a 54" tall cabinet.

Page 46: Verizon Wireless – Project Description Cluster 2 September

Cluster 2 Project Description - Page 46

Page 47: Verizon Wireless – Project Description Cluster 2 September

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Attachment I – Model Small Cell Location

Verizon Wireless has constructed a non-operational “mock” site for public and staff viewing. The central

location adjacent to 1350 Newell, across from the Palo Alto Art Center was selected because that

particular pole has no overhead transmission. Placing the model small cell near existing residences was

avoided, given the expectation that the public will go out to view the site. Additionally, Verizon Wireless

has selected the auditorium at the Palo Alto Art Center as a location to host community meetings.

Page 48: Verizon Wireless – Project Description Cluster 2 September

Cluster 2 Project Description - Page 48

Attachment J – Statement Regarding Spectrum Act

Palo Alto Municipal Code Section 18.42.110(d)(8) provides: “For Tier 3 WCF Permits, the plans shall

include a scaled depiction of the maximum permitted increase in the physical dimensions of the

proposed project that would be permitted by the Spectrum Act, using the proposed project as a

baseline.”

Verizon Wireless cannot submit a scaled depiction of the maximum permitted increase in the physical dimensions of the proposed small cell facilities on Palo Alto utility poles under the Spectrum Act for the following reasons: 1. Spectrum Act “Substantial Change” Criteria Are Indeterminate Spectrum Act “substantial change” criteria theoretically allow the expansion of a wireless facility in the Right-of-Way by ten feet in height and six feet in width. However, any such expansion cannot defeat existing “concealment elements” of the facility (see 47 C.F.R. §1.40001). Verizon Wireless small cells are designed with vertically integrated and oriented radio equipment as well as a vertical cylindrical antenna that matches the shape and size of the utility pole to which it is mounted. It is not clear what increase in size, if any, could be accomplished without defeating the concealment elements of the Verizon Wireless design. 2. Modifications To The Verizon Wireless Small Cell Allowed Under The Spectrum Act Must Comply With Health And Safety Requirements (CPUC G.O. 95) The Spectrum Act accommodates regulations for health and safety, such as the requirements of G.O. 95, that are generally observed by the City. G.O. 95 places strict limitations on the placement of attachments on utility poles. Specifically, continuous climbing space must be maintained in one quadrant of the pole from top to bottom. A six-foot separation is required between antennas and transmission lines. Equipment must be more than seven feet from the ground, and pole capacity must be restricted to accommodate the structural limitations of each pole. These limitations severely restrict the modifications that can be made to the Verizon Wireless small cell and would likely prevent modifications of the scale allowed under the Spectrum Act. Any modification that requires the replacement of the utility pole, for structural reasons or lack of space, is disqualified as an eligible facility request under the Spectrum Act. In nearly all cases, Palo Alto utility poles are near capacity and cannot accommodate modifications of the dimensions allowed under the Spectrum Act. 3. Verizon Wireless Has No Plans To Modify Its Small Cell Design And Any “Spectrum Act” Modification Would Be Speculative Verizon Wireless cannot predict the customer demand or technological changes that would lead to a modification of the proposed small cell design. Similarly, Verizon Wireless cannot predict what another utility or wireless provider may propose to add or attach to a utility pole. In the same way, the City cannot be obligated to pre-approve hypothetical designs as “eligible facility requests” under the Spectrum Act that may or may not defeat existing concealment or violate health and safety laws.

Page 49: Verizon Wireless – Project Description Cluster 2 September

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4. Hypothetical Maximum Build-Out Under The Spectrum Act Is Irrelevant To Required Approval Findings For Verizon Wireless Small Cells While theoretically interesting, the potential future expansion of a project is not the subject of any of the 16 Architectural Review findings nor the two conditional use findings required for approval of the Verizon Wireless small cell design under the Palo Alto Municipal Code. Projects must be evaluated as proposed and not on future hypothetical modification. There are no reasonably foreseeable modifications to the proposed Verizon Wireless small cell design that can be reviewed by the City at this time. Simply put, speculation cannot form the basis for any findings. Similarly, speculative future modifications do not constitute the substantial evidence required to deny approval of a wireless facility under federal law. For all of the reasons stated above, Verizon Wireless will not revise plans to show a scaled depiction of the maximum permitted increase in the physical dimensions of its small cell project.