CC Resolution No. 11-054 Petition for Reconsideration of Council Decision to Deny an Appeal of DIR-2010-28, 11371 Bubb Rd RESOLUTION NO. 11 -054
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF CUPERTINO
DENYING THE PETITION OF SHAUL BERGER SEEKING COUNCIL
RECONSIDERATION OF ITS DECISION TO DENY AN APPEAL OF DIR- 2010 -28, A
DIRECTOR'S MINOR MODIFICATION TO ALLOW A PERSONALWIRELESS SERVICE
FACILITY ON AN EXISTING PG &E POLE AT 11371 BUBB ROAD
WHEREAS, on November 29, 2010, the Cupertino City Council received a staff report and
recommendation to deny an appeal of a Director's Minor Modification approval of a T- Mobile
personal wireless service facility proposed on an existing PG &E pole at 11371 Bubb Road.
WHEREAS, the Cupertino City Council held a public hearing and at the conclusion of the
hearing denied the appeal filed by Shaul Berger on a 3 -2 vote at its meeting of November 29,
2010, thus approving the project, DIR- 2010 -28, in accordance with Planning Commission
Resolution No. 6616.
WHEREAS, the Cupertino City Council's decision was within its discretion and made at
a properly noticed public meeting.
WHEREAS, Shaul Berger requested that the City Council reconsider its decision under the
provisions of Section 2.08.096 of the City's municipal code; and
WHEREAS, the City Council has considered all relevant evidence presented by the
parties at all hearings, including evidence presented at the April 5, 2011 reconsideration
hearing.
NOW, THEREFORE, IT IS HEREBY RESOLVED AS FOLLOWS:
1. The petitioners' Reconsideration Petition is defective on its face in that it does not offer
proof of facts as required by Municipal Code Section 2.08.096.
2. The petitioners did not provide new relevant evidence which in the exercise of reasonable
diligence, could not have been produced al: any earlier city hearing (See Municipal Code
§ 2.08.096B(1).) Evidence presented did not incontrovertibly prove that federal laws
regarding maximum levels of radio frequency energy exposure would be violated. The
City has required post - construction radio frequency energy monitoring to insure
compliance with federal law.
3. The City Council did not exclude any evidence presented by the petitioners at any prior
city hearing. (See Municipal Code § 2.08.096B(2).)
4. The petitioners have failed to present any evidence that the City Council failed to provide
a fair hearing. (See Municipal Code § 2.08.096B(4).)
Resolution No. 11 -054
5. The petitioners have failed to demonstrate that the City Council abused its discretion
by denying the appeal of a Director's approval (file no. DIR- 2010 -28) of a personal
wireless service facility on an existing PG &E pole located at 11371 Bubb Road. (See
Municipal Code § 2.08.096B(5).) Specifically, the City Council determines that:
a. The City Council's decision is supported by findings of fact attached as Exhibit 1.
b. The findings of fact related to the City Council's decision were supported by
substantial evidence in the record of proceedings.
6. The petitioners' Petition for Reconsideration of the City Council's decision of November
29, 2010 is DENIED, thereby affirming the original decision.
PASSED AND ADOPTED at a regular meeting of the City Council of the City of
Cupertino this 5`" day of April, 2011, by the following vote:
Vote Members of the City Council
AYES: Wong, Santoro, Mahoney, Wang
NOES: Chang
ABSENT: None
ABSTAIN: None
ATTEST: APPROVED:
V
.mod
City Clerk Mayor, City of Cupertino
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Resolution No. 11 -054
EXHIBIT 1
CITY COUNCIL FINDINGS IN RESPONSE TO PETITION FOR RECONSIDERATION
Cupertino Municipal Code section 2.08.096 states:
"A petition for reconsideration shall specify in detail each and every ground for reconsideration.
Failure of a petition to specify any particular ground or grounds for reconsideration precludes
that particular omitted ground or grounds from being raised or litigated in a subsequent judicial
proceeding.
The grounds for reconsideration are limited to the following:
1) An offer of new relevant evidence which, in the exercise of reasonable diligence, could
not have been produced at any earlier city hearing.
2) An offer of relevant evidence which was improperly excluded at any prior city hearing.
3) Proof of facts which demonstrate that the City Council proceeded without, or in excess of
its jurisdiction.
4) Proof of facts which demonstrate that the City Council failed to provide a fair hearing.
5) Proof of facts which demonstrate that the City Council abused its discretion by:
a) Not proceeding in a manner required by law; and/or
b) Rendering a decision which was not supported by findings of fact; and /or
c) Rendering a decision in which the findings of fact were not supported by the
evidence."
Original Petition
The petition for reconsideration consists of three pages accompanied by a petition with 31
signatories. Reconsideration of this item constitutes the third full hearing of this matter
conducted by the City. As stated in the petition's introductory paragraphs, the petitioner has
made claims for reconsideration under the above referenced criteria #2, #4, #5b and #5c. The
petitioner submitted his radiation analysis on January 27, 2011, 49 days after the
reconsideration petition was filed on December 9, 2010. The analysis is a claim for
reconsideration under referenced criteria #1. The City's findings of fact on each of these
criteria are set forth below.
1. An offer of new relevant evidence which, in the exercise of reasonable diligence, could not
have been produced at any earlier city hearing.
Finding: The offer of new relevant evidence by the petitioner could have been presented at
the City Council appeal hearing of November 29, 2010 or with the reconsideration petition
submitted on December 9, 2010, instead of 49 days later on January 27, 2011.
Petition Response
In the petitioner's analysis of power The applicant's radio frequency energy
density, assumptions are made about the consultant finds the petitioner's methodology
T- mobile equipment and power density is and calculations to be reasonable, except for
calculated as a percentage of the Maximum an error in using the proposed output power
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Resolution No. 11 -054
Permissible Exposure (MPE) allowed by from the antenna as the output power from the
the Federal Government for uncontrolled transmitter, which according to the consultant
environments (1 milliwatt per centimeter makes all of the petitioner's results too high
squared) There are three pages calculating by a factor of about 15 times (1500 %). The
power density 12 feet, 20 feet and 30 feet consultant also points out that the petitioner is
from the antenna. The results show calculating the power density in front of the
exposures of 632 %, 227.5% and 101.1% of antennas which are 44 feet in the air, instead
the MPE. of where people might be present such as at
ground level or in nearby buildings. The
applicant attempted to contact the petitioner,
providing additional technical specifications
on the T- Mobile cell facility, but has not been
able to meet with the petitioner.
To remove any doubt as to the accuracy of the
consultant's RF energy analysis, the City has
also conditioned the approval to require post -
construction RF monitoring to make certain
the RF energy exposures are within federal
standards.
2. An offer of relevant evidence which was improperly excluded at any prior City hearing:
Finding: The petitioner has offered no new relevant evidence that was excluded at any prior City
meeting, nor has petitioner proven that any evidence was previously excluded by the City
Council. The complaint is an opinion of the petitioner that has not been supported by any facts
or evidence.
Petition Response
The petitioner alleges that his analysis The petitioner claimed at the Nov. 29, 2010
presented at the Nov. 29, 2010 meeting meeting, that his analysis of the calculated
indicates that radio frequency (RF) energy energy levels at 12 feet from the antennas was
exposure was more than 6 times higher than more than six times what was allowed by the
approved government levels. The petitioner federal standard. The petitioner did not offer a
further alleges that the Council voted on this copy of the analysis to the Council or staff.
project without checking these claims that the After the hearing, staff requested that the
RF energy exposure was higher than approved petitioner provide his analysis for the public
government levels. record; the petitioner did not provide any
analysis to the City until 49 days after his
reconsideration petition was filed, and 5 days
before the reconsideration hearing. The City
Council can only act on the facts and evidence
on hand when its decision is rendered.
The City has relied on a reputable firm,
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Hammett & Edison, to prepare the RF energy
analysis. Hammett & Edison have clarified
that the RF energy at this site is well within
the federal safety standards at a level of
0.0012 milliwatt per centimeter squared for all
ground level exposures, and 0.0022 milliwatt
per centimeter squared for second floor
exposures of any nearby residence.
To remove any doubt as to the accuracy of the
consultant's RF energy analysis, the City has
also conditioned the approval to require post -
construction RF monitoring to make certain
the RF energy exposures are within federal
standards.
4. Proof of facts which demonstrate that the City Council failed to provide a fair hearing:
Finding: The petitioner has not provided any proof of facts that demonstrate the Council failed
to provide a fair hearing. To the contrary, a review of the hearing on November 29, 2010 shows
that the Council heard lengthy testimony from the petitioner and neighborhood residents, as well
as information presented by staff and the applicant. The Council asked questions and received
responses before deliberating on the project.
Petition Res . onse
The petitioner alleges that the City did not Since this project has been heard by both the
provide a fair hearing because the Community .Planning Commission and the City Council,
Development Director did not convene a public any alleged processing flaw at the Director
design review hearing before acting to approve revel has been overcome at this point. At both
the application. lie Planning Commission and City Council
hearings, the petitioner has had opportunities
to review and influence the design of the
wireless facility. The Director's approach was
riot based on a determination that the item
would not be controversial; rather, the
Director determined that the placement of the
wireless equipment on an existing utility pole
constituted a minor design change to the
appearance of the pole. The City's adopted
Wireless Facilities Master Plan indicates that
the Director's approval is the proper
processing o stion for such a facility design.
5. Proof of facts which demonstrate that the City Council abused its discretion by:
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b) Rendering a decision which was not supported by findings of fact; and /or
c) Rendering a decision in which the findings of fact were not supported by the
evidence.
Finding: The petitioner has not provided any proof of facts that demonstrate the Council abused
its discretion by rendering a decision which was not supported by findings of fact, or rendering a
decision in which the findings of fact were not supported by the evidence.
Petition Response
The petitioner alleges that the City Council There is no requirement that the best solution
never reviewed alternative cell site options that be found, only that a project is determined
provide a better solution to all parties. The appropriate. The City's Wireless Facilities
petitioner alleges that an alternative solution Master Plan expresses a design preference that
involving a taller tower in a more remote wireless facilities in residential areas be sited
location would provide better coverage and on existing utility towers and poles, rather
collocation "savings" and result in a different than building new structures. Thus the
decision. proposed site meets the requirements of the
City's Wireless Facilities Master Plan. The
City Council did discuss three alternative sites
in its deliberations on November 29, 2010.
One site was Linda Vista Park on a hill. This
park was estimated to be about % of a mile
away and was felt to be too far away to
provide good coverage to the Bubb Road area.
The second suggested alternative was the
proposed AT &T monopine at Results Way
which had the potential to serve another
carrier at a lower height on the pole. It was
inappropriate to consider the Results Way site
as an alternative because no decision on the
project appeal had been granted by Nov. 29,
2010. The Council knew that the AT &T
monopine was 19 feet lower than the ground
to the south, so any T- Mobile collocated
antennas (at 46 feet, effectively 27 feet)
would be similar to two nearby T- Mobile
facilities and too low in height and too far
away (1+ mile) to provide cell coverage to
southern Bubb Road.
The third site alternative considered by the
Council was the San Jose Water Company
water storage facility at Regnart Road and
Lindy Lane. This facility is a covered earthen
reservoir. Staff indicated that the structure
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lacked height and a monopole would have to
be built. The City Council rejected the
concept of erecting a new, tall monopole cell
site at the edge of the reservoir next to the
existing houses.
The petitioner alleges that T- Mobile could not This claim is immaterial to any basis for
provide any information about the number of reconsideration. Also, the 1996
subscribers that would benefit from the Telecommunications Act, section
proposed wireless facility. The Council "704(7)(B)(i)(I) prohibits any local decision -
rendered a decision on this facility without making agency from unreasonably
knowing if there was any public benefit. discriminating among providers of
functionally equivalent (personal wireless)
services.
The petitioner alleges that his analysis See City Response to Petitioner's claim under
presented at the Nov. 29, 2010 meeting Municipal Code section 2.08.096(B)(1) and
indicates that radio frequency (RF) energy (B)(2).
exposure was more than 6 times higher than
approved government levels. The petitioner
further alleges that the Council voted on this
project without checking these claims that the
RF energy exposure was higher than approved
government levels.
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