HomeMy WebLinkAboutAGENDA REPORT 2022 0518 CCSA REG ITEM 09A SUPPLEMENTAL
MOORPARK CITY COUNCIL
SUPPLEMENTAL
AGENDA REPORT
TO: Honorable City Council
FROM: Kevin Ennis, City Attorney
Daniel Kim, City Engineer/Public Works Director
Brian Chong, Assistant to the City Manager
DATE: 05/18/2022 Regular Meeting
SUBJECT: Consider Resolution No. 2022-___ Amending Development Standards
for Small Wireless Facilities; Direct Staff to Pursue Legislative Efforts
to Revisit the Federal Communications Commission’s
Radiofrequency Emissions Standards that were Adopted as Part of the
Telecommunications Act of 1996; and Receive and File a Report on
Small Wireless Facility Regulatory and Legal Considerations
CORRESPONDENCE RECEIVED
Subsequent to the publication of the staff report, the attached correspondence was
received from members of the public and AT&T.
Attachments
Item: 9.A.
SUPPLEMENTAL
1
From:lisa padilla
To:Moorpark
Subject:Comment for city council meeting per small cell wireless
Date:Tuesday, May 17, 2022 11:16:01 PM
My comment for the meeting ..
My frustration with this whole process are these things, you continually put the citizens of
moorpark on hold. We have these town halls and city council meetings as well as zoom calls
and meetings and the same information is regurgitated over and over . Nicole Golden and Rob
Golden are living in a nightmare. First they are told from Professionals that the cell was
placed way to low, then they are told all the measurements for safety were taken from across
the street, then they watch a power pole a few poles down catch on fire and almost burn down
their neighbors home. They are told by SCE employees that if this was at their home they
would remove it themselves . They have given you all the information you as a city council
should have researched and known about. We have Hugh Finlay am expert in the field tell
you what he found. Nicole Golden and Lisa Ciccone and numerous others have done all the
research for you. The placement of this cell is way to close to a playhouse as well as the
Goldens Home. Plain and Simple. You have all stated many times , this was a mistake, I
don’t want this anywhere near my home, and more. In 2019 you were on the path of making
ordinances so this would never ever happen again. What happened ? Who dropped the ball
and why? When asked if you will fight this you spent months stringing us along, for what ? At
our last zoom meeting you literally closed the book folded your arms and said we have the
lawyers and the funds but we are not willing to fight what we can’t win. That’s the most
defeatist attitude I’ve ever heard and to me that proves you don’t care about Moorpark, you
don’t care about the Goldens or their children or the Peach Hill neighborhood this affects.
You want us to vote for you for higher offices? You want us to fight for you to keep your
jobs? Why? You haven’t fought for the Goldens or Moorpark .
Thank you
Lisa Padilla
Sent from Yahoo Mail for iPad
ATTACHMENT
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From:Shank, Aaron M.
To:City Council & City Manager
Subject:AT&T Comments on Proposed Revisions to Small Cell Development Standards
Date:Wednesday, May 18, 2022 9:17:22 AM
Attachments:AT&T Comments May 18 2022.pdf
Dear Mayor Parvin, Mayor Pro Tem Castro, and Councilmembers Enegren, Pollock, and Groff: Please
accept this letter on behalf of AT&T to provide comments on the city’s proposed resolution and
revisions to development standards for small wireless facilities. If you have questions, please feel
free to contact us.
Aaron M. Shank
Outside Legal Counsel for AT&T
AARON M. SHANK
Porter Wright Morris & Arthur LLP
Bio / ashank@porterwright.com
D: 614.227.2110 / M: 614.578.5036 / F: 614.227.2100
41 South High Street, Suites 2800 - 3200 / Columbus, OH 43215
/ MANSFIELD CERTIFIED PLUS
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END OF NOTICE
3
Aaron M. Shank
ashank@porterwright.com
Porter Wright
Morris & Arthur LLP
41 South High Street
Suites 2800-3200
Columbus, OH 43215
Direct: 614.227.2110
Fax: 614.227.2100
Main: 614.227.2000
www.porterwright.com
CHICAGO
CINCINNATI
CLEVELAND
COLUMBUS
DAYTON
NAPLES
PITTSBURGH
WASHINGTON, DC
May 18, 2022
VIA EMAIL
City of Moorpark City Council
799 Moorpark Ave.
Moorpark, CA 93021
RE: AT&T’s Comments on the Proposed Development
Standards for Small Wireless Facilities
Dear Mayor Parvin, Mayor Pro Tem Castro, and Councilmembers
Enegren, Pollock, and Groff:
I write on behalf of New Cingular Wireless PCS, LLC d/b/a
AT&T Mobility (AT&T) to provide comments on the city’s proposed
resolution to adopt development standards for wireless facilities. AT&T
appreciates the city’s efforts to revise its small wireless facility
regulations. The current regulations, however, need further revisions to
ensure the city eliminates provisions that will violate applicable laws.
AT&T respectfully requests the city consider additional revisions to
accommodate real-world small wireless facilities, many of which were
previously proposed in connection with the city’s April 2019 small cell
rulemaking effort.
AT&T remains committed to responsibly deploying its wireless
telecommunications facilities in the city. AT&T generally agrees that
codified location and design preferences can be developed to
accommodate providers while protecting the city’s interests to the
extent feasible. AT&T offers the following comments to help the city
adapt its development standards to foster responsible deployments in
line with applicable laws.
Key Legal Concepts
The Federal Telecommunications Act of 1996 (“TCA”)
establishes key limitations on local regulations related to siting wireless
telecommunications facilities. Under the TCA, the city must not
prohibit or effectively prohibit wireless services. See 47 U.S.C. §§
253(a), 332(c)(7)(B)(i)(II). An effective prohibition in violation of the
TCA occurs whenever the decision of a local government materially
inhibits wireless services.1 Under the TCA, wireless providers must be
1 See Accelerating Wireless Broadband Deployment by Removing Barriers to
Infrastructure Investment, Declaratory Ruling and Third Report and Order, FCC 18-
133, 30 FCC Rcd 9088 at ¶¶ 35-42 (September 27, 2018) (“Infrastructure Order”);
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City of Moorpark
AT&T Comments May 18, 2022
Page 2
permitted to deploy facilities to offer more robust and competitive wireless services for the
benefit of the public. The Federal Communications Commission explained that a local
government “could materially inhibit service in numerous ways – not only by rendering a service
provider unable to provide existing service in a new geographic area or by restricting the entry of
a new provider in providing service in a particular area, but also by materially inhibiting the
introduction of new services or the improvement of existing services.”2
The city must act “within a reasonable period of time” on each application. 47 U.S.C. §
332(c)(7)(B)(ii).The FCC has codified “shot clocks” – presumptive maximum timeframes for
processing applications. Violations of the shot clocks may result in unlawful effective
prohibitions under the TCA and deemed approvals under state law.3 The city must grant all
necessary approvals and authorizations within the applicable shot clock as the shot clock applies
“to all aspects of and steps in the siting process.” 4 The FCC has also ruled the shot clock starts
once an applicant takes the first step to meet a locality’s required process, such as scheduling a
pre-application meeting or submittal appointment.5
The FCC’s Infrastructure Order established an aesthetic standard for small cells. To be
lawful, aesthetic requirements must be reasonable, i.e., technically feasible, and published in
advance.6 The essence of the requirements are to allow local regulations that avoid “out-of-
character” infrastructure deployments to the extent feasible.7 Beyond that, aesthetic requirements
may effectively prohibit wireless services in violation of the TCA.
The Infrastructure Order also established a fee standard for small cell wireless facilities.
Similar to state law requirements, such fees must be reasonable, cost-based, and non-
discriminatory.8 Under this fee standard, the city bears the burden to show that any additional
fees are justified under the fee standard.9 To help municipalities avoid imposing unlawful fees,
the FCC established a safe harbor for presumptively reasonable fees: (a) $500 for the total of all
nonrecurring fees for an application including up to five small cells, plus $100 for each small cell
beyond five, or $1,000 for the total of all nonrecurring fees for a new pole to support small cells,
see also, In the Matter of California Payphone Assoc. Petition for Preemption, Etc., Opinion and Order, FCC 97-
251, 12 FCC Rcd 14191 (July 17, 1997).
2 Infrastructure Order at ¶ 37.
3 See id. at ¶ 118; Cal Govt Code § 65964.1(a).
4 See Infrastructure Order at ¶¶ 132-137.
5 Id. at 145.
6 Id. at ¶ 86; City of Portland v. United States, 969 F.3d 1020 (9th Cir. 2020), cert. denied, City of Portland v.
United States, 141 S. Ct. 2855 (2021).
7 See Infrastructure Order at ¶¶ 86-88.
8 Id. at ¶ 50.
9 Id at ¶ 79; see also In the Matter of Petition for Declaratory Ruling that Clark County, Nevada Ordinance No.
4659 Is Unlawful Under Section 253 of the Communications Act as Interpreted by the Federal Communications
Commission and Is Preempted, Order, WT Docket No. 19-230, Doc. DA-21-59 (January 14, 2021) at ¶ 7.
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City of Moorpark
AT&T Comments May 18, 2022
Page 3
and (b) $270 per small cell per year for the total of all recurring fees.10 In fact, the FCC
explained that these fees would be exceeded in “only very limited circumstances.”11
The TCA also forbids state and local governments from making decisions on wireless
facility siting application based on the effects of radio frequency emissions to the extent such
facilities will comply with the FCC’s rules for such emissions.12 In addition, localities may not
impose their own standards for assessing radio frequency emissions as the federal government
exclusively regulates this topic and there is no room for local regulation of it.13
AT&T has a statewide franchise right to access and construct telecommunications
facilities in the public rights-of-way. Under Public Utilities Code Section 7901, AT&T has the
right to access and construct facilities in public rights-of-way in order to furnish wireless
services, so long as it does not “incommode” the public use of the public right-of-way. And
under Section 7901.1, AT&T’s right is subject only to the city’s reasonable and equivalent time,
place, and manner regulations as to how AT&T constructs in the public rights-of-way.
Specific Comments on the Proposed Policy
1. Site Agreement. The city needs to delete or revise Section 2.2(a)(9), which requires all
applicants to execute an agreement between the applicant and the city to install small cells on
any structure located within the public right-of-way. AT&T does not need an agreement with the
city to exercise its right to attach to non-city-owned structures because it has a state law franchise
right to place its facilities in the public rights-of-way.14 And this requirement is discriminatory to
the extent it is not applied to other infrastructure deployments.
2. Location Preferences. The Proposed Policy, in Section 2.2(a)(12) and Section
2.4(b)(2)&(4), requires the applicant to demonstrate that a proposed project would be in the most
preferred location and on the most preferred support structure that is technically feasible within
500 feet of the proposed location under Sections 2.6’s location requirements. The Proposed
Policy does not indicate what is required to demonstrate that a particular location or structure is
or is not technically feasible.
On this issue, the Agenda Report for this item suggests these provisions are intended to
allow exceptions when providers provide evidence that more preferred sites will not close a gap
10 Infrastructure Order at ¶ 79.
11 Id. at ¶ 80.
12 See 47 U.S.C. § 332(c)(7)(B)(iv).
13 Bennett v. T-Mobile U.S., Inc., 597 F.Supp.2d 1050, 1053 (C.D. Cal. 2008) (localities are preempted from
regulating this topic because the FCC has regulated “every technical aspect of radio communication.); Farina v.
Nokia, 578 F.Supp.2d 740, 762 (E.D. Pa. 2008) (held “Congress has given the FCC exclusive authority over every
technical aspect of radio communication”).
14 See Public Utilities Code Section 7901.
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City of Moorpark
AT&T Comments May 18, 2022
Page 4
in coverage. But the FCC has expressly rejected all such “coverage gap” tests. 15 As the Agenda
Report explains, the Infrastructure Order “was expressly intended to promote” “efforts to densify
commercial cellular networks.” Agenda Report at 2. Thus, the city cannot require this sort of
justification for siting purposes, and it must still authorize exceptions to avoid unlawful
prohibitions.
3. Deemed Withdrawn. Section 2.3(b) provides that an application is deemed withdrawn
when an applicant does not respond to an incomplete notice within 60 calendar days. The city
should eliminate this procedure. This is inconsistent with the mechanics of the FCC shot clocks.
And it is not uncommon for a delayed response by an applicant to be the result of the applicant
and city staff working together to resolve issues, which should be encouraged.
4. Batched Applications. AT&T objects to Section 2.3(c), which limits batched applications
to five small wireless facilities and deems the entire batch incomplete/withdrawn/or denied if any
application in the batch is incomplete/withdrawn/or denied. This is inconsistent with the
Infrastructure Order and the corresponding rule, which do not authorize batching limitations.16
5. Indemnification. The indemnification provision in Section 2.5(a)(10) needs to carve out
exceptions to indemnity in instances of the city’s own negligence. And AT&T must retain the
right to select its own counsel.
6. Cost Reimbursement. Section 2.5(a)(16) states that applicants must “reimburse the city
for all costs incurred in connection with the permit.” It also states that the city has the right to
withhold any permits or other approvals unless any outstanding costs have been reimbursed to
the city by the permittee. This provision must be revised because only objectively reasonable
costs that are recovered on a nondiscriminatory basis can be included in fees. To the extent the
city’s costs exceed the FCC’s safe harbor for presumptively reasonable fees and are not
objectively reasonable, the costs are preempted and unlawful. For example, the city should not
pass on to AT&T the costs for engaging a consultant to investigate coverage gaps (as
contemplated in the Agenda Report) because that is not a relevant inquiry and, therefore, such
costs are not reasonable. AT&T looks forward to working with the city to ensure its proposed
fees comport with state and federal laws.
7. Undergrounding. Several provisions in the Proposed Policy mandate undergrounding of
equipment. These requirements must be revised to the extent necessary to avoid unlawful
discrimination or effectively prohibiting wireless services in violation of the Act. Wireless
facilities cannot operate with all equipment underground. For instance, radio units must be
placed above ground in order to be near enough to the antennas to function properly. Moreover,
15 See Infrastructure Order at ¶ 40, n. 94 (the FCC rejected all “coverage gap” tests, including “the version endorsed
by the Second, Third, and Ninth Circuits (requiring applicants to show that the proposed facilities are the ‘least
intrusive means’ for filling a coverage gap)”).
16 See 47 C.F.R. § 1.6003(c)(2) and Infrastructure Order at ¶114.
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City of Moorpark
AT&T Comments May 18, 2022
Page 5
to comply with the FCC’s aesthetic standard, the city cannot impose undergrounding
requirements in a more burdensome way than applied to other right-of-way users.17
8. Electric Meter Upgrades. AT&T objects to Section 2.5(a)(18). Once AT&T installs a
ground-mounted electric meter, the meter is permitted to remain for ten years. AT&T will
discuss removal of a ground-mounted electric meter in the context of a permit renewal. And to
the extent that power needs to be based on a flat rate, the inability to place meter pedestals will
eliminate the ability to use certain small cell technologies. This, in turn, may effectively prohibit
wireless service in violation of the Act.
9. Prohibited Support Structures. The city should strike the proposed ban on the installation
of enumerated support structures in Section 2.6(d) of the Proposed Policy, which includes
decorative poles, signs and new, non-replacement wood poles. The FCC made clear that its
interpretations apply to all government owned or controlled structures within the right-of-way.18
Many jurisdictions favor decorative pole designs for small cells, subject to a requirement that
new or replacement decorative poles housing small cells are designed to look similar to nearby
decorative poles.
10. Concealment. Many of the city’s design standards in the Proposed Policy for small
wireless facilities require concealment. These requirements should be limited “to the extent
feasible” because some wireless components cannot be concealed. For example, certain antennas
being used for the latest generation of wireless technology cannot propagate an effective signal
through certain forms of concealment.
11. Ground-Mounted Equipment. The city will not approve any ground-mounted accessory
equipment under Section 2.7(b)(2)(E). But sometimes ground-mounted electric meter pedestals
are the only feasible option for providers based on the electric provider’s requirements. AT&T
will certainly work with the city on design, but the city must avoid blanket prohibitions and
dictating AT&T’s infrastructure choices.
12. Pole Top Requirement. Section 2.7(b)(3), (b)(4), (b)(5), (c)(4) and (c)(7)(A) state that
antennas on streetlights, existing or replacement wood utility poles, new, non-replacement poles
and other freestanding structures must be installed above the pole. There may, however, be a
number of reasons that inhibit installations on the top of the pole. In certain instances, top-
mounted antennas may not be technically feasible or network parameters may prevent pole-top
installation. For example, AT&T sometimes deploys a very low-profile collar antenna that is
typically placed lower on the pole. Also, AT&T may only have rights to certain space on the
pole, or the pole owner may impose restrictions on AT&T that prevent extending the height of
the pole. This requirement should, therefore, be limited to the extent practical and feasible.
17 See also Infrastructure Order at ¶ 86.
18 Id. at ¶ 69.
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City of Moorpark
AT&T Comments May 18, 2022
Page 6
13. New, Non-Replacement Poles. Section 2.7(b)(5) allows the city to require that a new,
non-replacement pole be a streetlight, and if there are no existing streetlights nearby, applicants
may only install a metal or composite pole. The city cannot force AT&T to install streetlights,
and cannot ban use of other pole materials. AT&T has a state law right to set a poles in the right-
of-way under Section 7901. In addition, these requirements steer wireless installations onto city-
owned structures in violation of California Government Code Section 65964(c), which prohibits
the city from requiring “that all wireless telecommunications facilities be limited to sites owned
by particular parties.” And these restrictions are preempted by the FCC’s aesthetic standard for
small wireless facilities to the extent they are more burdensome than rules applied to other
infrastructure deployments.
14. New Pole Diameter. Section 2.7(b)(5) and Section 2.7(c)(4) limits the diameter of new
poles to 12 inches. The city may want to consider expanding allowable new pole diameter to 18
inches because AT&T’s pole-top shroud is 18 inches in diameter to fit all of the equipment.
Conclusion
AT&T urges the Council to take a step back to consider further revisions to its proposed
small wireless facility development standards so that they will foster responsible deployments
and avoid violating important laws.
Sincerely,
Aaron M. Shank
20872938v1
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From:Lisa Cirricione
To:City Council & City Manager; Daniel Kim; Brian Chong
Subject:Small Cells and Communication Transparency
Date:Wednesday, May 18, 2022 4:24:15 PM
Dear Council Members, Mr. Kim, Mr. Brown, and Mr. Chong,
My apologies for the prior blank email, I hit a wrong button. I wanted to thank those of
you present for the zoom meeting held on 5/16 in preparation for the council meeting.
I am very encouraged and happy to hear that the city has decided to put out requests
for proposals on the subject of an INDEPENDENT RF emissions readings entity that
will at least provide some meaningful data and accountability for the new small cells
being located in very close proximity to areas in which residents live, play and work.
This is a great way for us to hold the telecoms accountable and have meaningful data
about what we are being exposed to. Again, those 1996 limits were based on an
adult’s body, not a child’s or pregnant woman, so we have never had any data on
what is truly safe for them.
I am also glad that the ordinance is being strengthened, something the community
asked to be done back in July of 2019.
What is still unfortunate is that the Golden’s didn’t have any say, choice or notice in
what they will be exposed to now with the small cell installed literally in their back
yard. Since AT&T will not bend an inch, I am also greatly looking forward to what
attorney Scott McCullough’s input would be at this point as well. Please do
keep us all informed of the results of that call. We appreciate that greatly!!
What continues to grieve me is that I know (and knew in 2019) that once a cell is
installed you’re going to be very hard pressed to get it taken down. That is why I
continuously asked for locations of proposed cell sites in residential areas in 2019,
and in 2020. I was NOT ever informed of this particular address. City staff kept telling
me it was also on Peach Hill (along with the Golondrina site) but they didn’t “know
exactly where on Peach Hill”, or when they would know. I didn’t find out until it was
installed, and Nicole sent out an SOS to the community.
Yesterday a number of you mentioned the reason I was not told, was because an
application form had not been provided to AT&T until dates after my inquires, if I am
understanding correctly. However, the permit for this location that was provided
to us mere minutes after our zoom call, reveals that the location paper trail
began in July of 2019, and as you can see below, from the AT&T architectural
drawings, technical information relating to the proposed site etc., that the
location address was specifically chosen and provided as early as July 2019. In
fact, the Golden's home was singled out with their parcel number clearly
labeled. It was incredibily obvious that it was going in someone's backyard.
How is it that city staff did not know the address in 2019, and in 2020?
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Mayor Parvin, you are at the helm. Can you please give us information on what kind
of direction city staff will be given in regards to providing timely, accurate and
COMPLETE information when requests about potential new cell site locations are
made?
Troy said that residents have the right to this information. What are the
reprecussions if those rights are violated? PLEASE respond to this question. I
have been asking this repeatedly. Somehow my questions keep being diverted into
the semantics of permits, applications and forms, which has been frustrating and
somewhat disingenuous as well.
Had there been transparency on this, the reality of our situation could have been very
different today. We understand your hands are tied to certain extents but ours are not.
The public can take that information and use it to assert its own action strategies and
when we know in advance of proposed locations, those of us who don’t want to live
near such sites can make home buying choices accordingly. Whether or not these
things are effective or not is beside the point. The point is that we had a right to know,
and the loss of that information has had very detrimental effects.
Living safely doesn’t just mean you are keeping crime low. It also means that your
environment is safe health-wise and that public trust in local government is high. A
lack of transparency like this undermines public trust and further disengages people
from feeling like they matter or can make a difference in the very communities they
live in.
Moving forward, I hope we can be genuine, honest and work together on the things
that matter to us the most.
Please keep us updated on the call to Scott Mccullough and if we can generate
some type of web page that updates regularly of where current and proposed
small and large cell sites are located within the city. It doesn’t seem like it would
be that difficult to list addresses of current and proposed sites. Again, it doesn’t have
to be directly advertised but readily available to those who seek this information out.
Thank you and Best Regards,
Lisa Cirricione
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