Wireless Sitting Processes and Standards - Aug 2020
Wireless Siting Processes and Standards
Prepared for the City of Cupertino, California
August 2020
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Contents
1 Executive Summary 1
1.1 The City Has a Strong Wireless Facility Siting Process 1
1.2 Changes in Wireless Technology and the Carrier Industry Will Require the City’s Processes and Standards to
Evolve 2
1.3 Recommendations 3
2 General Definitions 6
3 Application Types and Requirements 13
3.1 Prerequisites 13
3.2 Application Types 13
3.2.1 Replacement Requirements 13
3.2.2 New Structure Requirements 14
3.2.3 Additional Reviews for New or Replacement Poles 16
3.3 Application Submittals 17
3.3.1 Radio Frequency Analysis 17
3.3.2 Structural Analysis 18
3.3.3 Construction Drawings 18
3.4 Annual Plan 30
3.5 Inventory 31
4 Internal Application Review and Decision-Making Process 32
4.1 Personnel Required 33
4.2 Target Timeframes for Review and Decision-Making Process 34
4.3 Reviews 35
4.3.1 Intake Review 36
4.3.2 Engineering Review 36
4.3.3 City Requirement Review and Site Survey 36
4.3.4 Completeness Review, RFI Issuance, Resubmission Review 37
4.4 Recommendation and Report 38
4.5 Decision 38
4.6 Notification, Construction, and Permit Close-out 39
5 Technical and Aesthetic Standards for Wireless Facilities 41
5.1 General Technical and Aesthetic Requirements and Guidelines 41
5.1.1 Prohibited Structures 41
5.1.2 Location 42
5.1.3 Non-Public Right-of-Way Dimensions 42
5.1.4 Use of Alternative Pole Designs 42
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5.2 Requirements and Guidelines in the Public Right-of-Way 43
5.2.1 Notification 44
5.2.2 Structure Types 45
5.2.3 Location 45
5.2.4 Facilities 47
5.2.5 Electric Supply 48
5.2.6 Backhaul Connections 49
5.2.7 Base-Mounted Equipment 49
5.2.8 Surface-Mounted Equipment 49
5.2.9 Pole-Mounted Equipment 49
5.2.10 Wooden Utility Poles 50
5.3 Undergrounding 50
5.4 RF Exposure 50
5.4.1 RF Signage Requirements 51
5.4.2 Emergency RF/ Power Shut-Off 51
5.4.3 Licensed Frequencies 51
5.5 Lighting and Noise 52
Appendix A: Standard Pre-Approved Designs 53
Design 1 54
Design 2 55
Appendix B: Application Checklist 57
Contact Information 57
Site Information 58
Installation Type 62
6409 – Eligible Facilities Request 63
Small Wireless Facility (Per FCC) 65
Public Right-of-Way 66
Antennas 67
Submittals 68
Appendix C: Site Completion Checklist 72
Appendix D: Process Tasks 73
Intake Review 73
Engineering Review 74
City Requirement Review 76
Completeness 77
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Figures
Figure 1: Sample Plan Sheet with Suitable Line Weights and Annotation 20
Figure 2: Sample Profile Sheet with Suitable Line Weights and Annotation 21
Figure 3: Sample “Total Cubic Feet” 27
Figure 4: Typical Detail 28
Figure 5: Example Underground Communications Demarcation Point 30
Figure 6: Candidate Application Review Process Flowchart 33
Figure 7: Target Number of Workdays per Step in the Wireless Siting Review Process 35
Figure 8: Recommended Request for Information Process 37
Figure 9: RF Signage 51
Figure 10: Standard Design 1 – Streetlight with Pole-mounted Equipment 54
Figure 11: Standard Design 2 – Streetlight with Equipment in Base 55
Figure 12: Conduit Typical Example 56
Tables
Table 1: Target Workdays per Task 34
Table 2: Installation Type Preferences 45
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1 Executive Summary
The City of Cupertino requested that CTC Technology & Energy review the City’s
wireless siting processes and standards and update the City’s Wireless Facilities Master
Plan.1 The City intended the study to include best business practices for deployment of
Small Wireless Facilities (often referred to as small cells); a comparison of the City’s
wireless siting requirements and processes against those of a comparable jurisdiction in
the region; and an analysis and recommended changes to the City’s design and
permitting guidelines for Small Wireless Facility infrastructure.
1.1 The City Has a Strong Wireless Facility Siting Process
To establish a baseline for our analysis, we reviewed the existing guidelines and
standards provided to us by the City, including:
• Wireless Facilities Master Plan
• Guidelines for City-owned poles
• FAQs for wireless facilities on wooden utility poles and streetlight poles2
• Small Wireless Facility design standards
• License agreements with service and infrastructure providers
We found the City has accomplished significant gains since the adoption of its previous
Wireless Facilities Master Plan. In addition to developing Small Wireless Facility design
standards that outline the City’s requirements to potential applicants, City staff maintain
ongoing, informal communications channels with applicants and share long-term plans
to mutual benefit. The City has approved permits for wireless facility siting in locations
that are agreeable both to applicants and the City. There are no unresolved issues relating
to damage to the City’s rights-of-way or private property.
1 “Wireless Facilities Master Plan,” City of Cupertino,
https://www.cupertino.org/home/showdocument?id=385 (accessed May 2020).
2 See, for example: “Frequently Asked Questions about Wireless Facilities on Wooden Utility Poles and
Streetlight Poles,” City of Cupertino, https://www.cupertino.org/home/showdocument?id=23418
(accessed May 2020).
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Importantly, too, the City has established a transparent process for its wireless facility
siting application reviews and approvals—ensuring that members of the public are aware
of applications that have been submitted and related radio frequency (RF) emissions
assessments. And, very importantly in light of requirements established by the Federal
Communications Commission (FCC), the City accomplishes its application reviews in a
reasonable amount of time.
At the request of the City as a benchmarking exercise, we conducted a detailed
comparison of the City’s wireless siting processes and requirements against those of the
City of Palo Alto. We found that Palo Alto’s process is more specific and defined than
Cupertino’s. For example, rather than broad guidelines about the size and type of
equipment it will allow (as is the case in Cupertino), Palo Alto provides numerical
maximums and minimums. However, there are some areas where Palo Alto’s process
would be unnecessarily complex for Cupertino’s needs—such as in its use of a multi-
tiered application approach.
1.2 Changes in Wireless Technology and the Carrier Industry Will Require
the City’s Processes and Standards to Evolve
Changes in wireless technology and the carrier industry’s approach to delivering services
will require the evolution of wireless facility siting processes and guidelines in the City
and nationwide. In this regard, we forecast a number of potential challenges for the City
in the coming years, including:
• Need to accommodate processes and designs of all applicants. While Verizon
Wireless has been the predominant applicant in the City to date (and its
applications generally align with the City’s standards), it is likely that other
providers will begin applying for wireless facility siting in the City. Those
providers may have applications that are technically different from the City’s
standards—and the applicants may be less amenable than Verizon Wireless has
been to informal pre-application planning. Indeed, those providers may feel the
City is making arbitrary choices about which applications to approve if the City’s
policies are too restrictive or not detailed enough. That raises the risk of litigation
if the City does not establish well-defined requirements.
• Need to accommodate providers’ interest in placing infrastructure in
neighborhoods. With new wireless technologies requiring the placement of more
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antennas closer to users, the City will likely see more applications for siting in or
adjacent to residential neighborhoods. Thus, the City will need to define an
approach for placing new poles where none currently exist—and will need to
prepare for increased concern (e.g., about aesthetics and RF emissions) and
engagement by residents.
• Need to accommodate a greater volume of applications within the 10-day
requirement for determining each application’s completeness. The industry will
seek to place millions of wireless facilities nationwide in the coming years—so the
City, like many other jurisdictions, will likely need to handle many more
applications than it is accustomed to processing. Already, the City has seen a sharp
recent increase in applications by Verizon Wireless. And these applications require
relatively quick action; the City needs to be able to accommodate the FCC’s “shot
clock” timeframes 3 —especially the 10-day requirement for determining the
completeness of an application filed with the City.
• Need to review and approve requested modifications to already-installed Small
Wireless Facilities in the City. In addition to applying to construct new wireless
facilities, the carriers and infrastructure companies will also likely be seeking to
replace existing antennas with newer equipment. The City may need a streamlined
process for dealing with those requests.
1.3 Recommendations
We recommend the City take a number of concrete steps that will enable it to adeptly
handle the challenges outlined above (including compliance with FCC requirements)—
while maintaining an open and transparent process for the public, protecting the City’s
rights-of-way and physical assets, and collaborating with applicants to enable the
deployment of wireless infrastructure.
1. Develop application forms that request all necessary information. Developing
standard wireless facility siting applications that require applicants to submit up-
front all information the City will need to conduct a thorough review—and
3 “Wireless Infrastructure,” Federal Communications Commission, https://www.fcc.gov/wireless-
infrastructure (accessed June 23, 2020).
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ensuring that the application submittal forms are prepared in a way that enables
efficient review by City staff—will streamline the application process for both
applicants and the City. This is especially important in cases where an applicant
chooses not to participate in informal pre-application discussions with the City.
Application forms should comprise comprehensive lists of detailed questions to
enable the City’s reviewer to quickly ascertain application completeness and
compliance. Thorough, well-organized, and comprehensive applications will
avoid the need for time-consuming back-and-forth communications with
applicants (e.g., the City’s issuance of requests for information, or RFIs, when an
applicant submits an incomplete application). The City should develop separate
applications for new sites, colocations, and minor modifications.
2. Modify the City’s exiting application review process to increase efficiency. We
recommend modifications including:
o Separate application review processes for new, colocation, and minor
modification applications
o Revisions to the review process to make it more standardized and
repeatable
3. Adopt clear technical and aesthetic standards for wireless facility siting. By
providing the appropriate amount of technical specificity up front (not a specific
design or technology, but a set of standards), the City will ensure that applicants
have sufficient guidance to understand what types of facilities will likely be
approved prior to preparing and submitting an application.
4. Conduct a cost analysis to justify the City’s application fees and yearly fees. A
methodical analysis of the City’s actual costs for reviewing applications and other
expenses related to wireless facility siting will provide the City with data to
support its fee structure. We understand the City is in the process of performing
this analysis.
To support these recommendations, this report includes the following elements for the
City’s consideration, modification, and potential adoption:
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• General definitions related to Small Wireless Facilities, applications, review
processes, and standards (Section 2)
• Detailed descriptions of application type and requirements (Section 3)
• Detailed descriptions of separate application review processes, including a process
flowchart and modified personnel roles (Section 4)
• Detailed aesthetic and technical standards for wireless facilities (Section 5)
• Draft standard pre-approved designs (Appendix A)
• Draft fields for expanded applications (Appendix B)
• A site completion checklist (Appendix C)
• Lists of tasks by process (Appendix D)
• A comparison of wireless facility siting processes in Cupertino and Palo Alto
(Appendix E)
We propose that, once they are finalized, Section 4 and Appendices A through C become
an amendment to the City’s Wireless Facilities Master Plan.
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2 General Definitions
This document assumes the following defined terms:
1. Activation Report means a report that documents that a Wireless Facility is being
operated in compliance with applicable FCC emissions standards.
2. Antenna means an apparatus designed for the purpose of emitting radio
frequency (RF) radiation, to be operated or operating from a fixed location
pursuant to FCC authorization for the provision of wireless service and any
commingled information services. Such apparatus includes, but is not limited to,
directional Antennas, such as panels, microwave dishes, and satellite dishes, and
omni-directional Antennas, such as whips.
3. Antenna Equipment means equipment, switches, wiring, cabling, power sources,
shelters, shrouds, enclosures, or cabinets associated with an Antenna, located at
the same fixed location as the Antenna and, when colocated, mounted or installed
at the same time as such Antenna.
4. Antenna Facility means an Antenna and associated Antenna equipment.
5. Applicant means a Person who submits an Application. The term includes the
Persons who will be the owners of the Facility or on whose behalf the work will
be performed, as well as the Person who may submit an Application, which shall
in any case be signed by the entity which will own the Facility or on whose behalf
the work is performed.
6. Application means a request submitted by an Applicant to the Public Works
Department to review and evaluate a proposed new or modified
Telecommunications Facility within the City. An Application includes all the
requirements for submission of an Application and any subsequent information
to amend the Application or in reply to requests for information (RFI).
7. Base Station means a structure or equipment at a fixed location used for the
provision of wireless services and that enables FCC-licensed or authorized
wireless carrier communications between user equipment and a communications
network. The term includes, but is not limited to, radio transceivers, Antennas,
coaxial or fiber-optic cable at the site, regular and backup power supplies, and
comparable equipment, regardless of technological configuration. The term does
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not include a Tower or other Support Structure, as defined herein, and does not
include Facilities (other than wireless devices at the Base Station) that connect a
Base Station at a fixed location to other elements of a communications network at
other locations. The term does not include metering equipment or disconnects
required to provide power to the Base Station.
8. Capacity means the maximum data rate a Wireless Facility can support, taking
into consideration the network overhead information, the services offered, and the
wireless service provider’s spectrum availability.
9. Cell on Wheels (COW) means a portable self-contained cell site that can be moved
to a location and set up to provide wireless Telecommunications services on a
temporary or emergency basis, for a period up to 120 days but not more than the
period permitted by the Public Works Department. A COW is normally vehicle-
mounted and contains a telescoping boom as the Antenna Support Structure.
10. City means the City of Cupertino.
11. Colocation means
a. the mounting or installation of an Antenna Facility on a preexisting
structure for the purpose of transmitting and/or receiving radio frequency
signals for communication purposes, whether or not there is an existing
Facility on the Tower, building, or structure, or
b. the modification of a preexisting structure for the purpose of mounting or
installing an Antenna on that structure.
12. Concealment means any Wireless Facility or structure that is covered, blended,
painted, disguised, camouflaged, shrouded, or otherwise concealed such that the
Wireless Facility blends into the surrounding environment and is visually
unobtrusive.
13. Construct means to install, erect, build, affix, or otherwise place any fixed
structure or object.
14. Design Manual means the Design Manual for Small Wireless Facilities
promulgated by the City. The Design Manual comprises design standards
including, but not limited to, the appearance, height, and size of Wireless Facilities.
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15. Emergency means a condition that:
a. poses a clear and immediate danger to life or health, or of a significant loss
of property, or
b. requires immediate repair or replacement to restore service to a user.
16. Encroachment Permit means an official document or certificate issued by the
Public Works Department or its duly authorized agent, authorizing performance
of specified construction at a specified location and within a specified time,
together with all supporting documents, agreements, conditions, plans, and
specifications.
17. FAA means the Federal Aviation Administration
18. Facility or Facilities means Facilities, equipment, and installations of any kind,
including but not limited to any lines, pipes, irrigation systems, wires, cables,
conduit Facilities, ducts, Poles, Towers, vaults, pedestals, boxes, appliances,
Antennas, transmitters, gates, meters, appurtenances, or other supporting
infrastructure or equipment. A reference to a Facility refers both to the Facility
considered as a whole and the individual elements of a Facility.
19. FCC means the Federal Communications Commission
20. Install means the placing, constructing, or modifying of a Facility, whether
initially or as part of the repair, modification, replacement, removal, or expansion
of an existing Facility, and includes any process by which a Facility is placed,
including but not limited to attachment, construction, digging , excavation,
placement, pulling, and the like.
21. License means a nonexclusive specific authorization granted to Construct,
operate, and maintain a Small Wireless Facility in the Public Right-of-Way to
provide wireless communication services within all, or a specified area of, the City.
Any such authorization, in whatever form granted, shall not mean or include any
general License or permit required for the privilege of transacting and carrying on
a business as required by the ordinances and laws of the City, or for attaching
devices to Poles or other structures, whether owned by the City or a private entity,
or for excavating or performing other work in the Public Right-of-Way.
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22. Licensee means a natural person, partnership, domestic or foreign corporation,
association, joint venture, or organization of any kind that has been granted a
Master License Agreement by the City, subject to this Subtitle.
23. Material Change means a change that does not qualify as an Eligible Facilities
Request as defined by the FCC in section 6409 of the Middle Class Tax Relief and
Job Creation Act of 2012.4
24. Master License Agreement means a written agreement entered into between the
City and the Wireless Facility Owner that sets forth the terms and conditions under
which a License will be granted and exercised.
25. Minor Modification means changes to an existing Telecommunications Facility
that does not result in a Material Change to the existing Facility or Support
Structure.
26. Monopole means a Tower that is a single, self-supporting pole-type structure,
tapering from base to top and supporting a fixture designed to support
Telecommunications Facilities.
27. Person means any natural or corporate person, business association or business
entity including, but not limited to, an individual, a partnership, a sole
proprietorship, a political subdivision, a public or private agency of any kind, a
utility, a successor or assign of any of the foregoing, or any other legal entity.
28. Pole means a type of structure in the Public Right-of-Way or other structure that
is used in whole or in part for wireline communications, electric distribution,
lighting, traffic control, signage, or similar function, or for Colocation.
29. Private Property means any real property owned or controlled by a single
individual or by a group of individuals collectively. Private Property is any
property that is not Public Property.
30. Protected Area means a site that, as of the date of an Application, is located within
a group of buildings properties, or on a site, that is listed in:
4 See 47 U.S.C. § 1455(a), https://www.congress.gov/112/plaws/publ96/PLAW-112publ96.pdf.
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a. the Cupertino Inventory of Historic Resources, or
b. the National Register of Historic Places (or is formally determined eligible
for listing by the Keeper of the National Register), or
c. the California Inventory of Historic Properties.
31. Public Property means any real property owned or controlled by the City or
another public entity including buildings, lands, and surplus property.
32. Public Right-of-Way means the surface and space above, on, beside, and below
any public highway, avenue, street, lane, alley, boulevard, concourse, driveway,
bridge, tunnel, park, parkway, waterway, dock, bulkhead, wharf, pier, building,
public easement, Right-of-Way, or any other public ground or water belonging to
the City or another public agency.
33. Radio Frequency Propagation Maps (also referred to as coverage maps) means
maps that indicate coverage provided by a Wireless Facility at a specific
geographical location. These maps illustrate target signal levels (set by the wireless
service provider) with different colors. They are calculated using the most suitable
propagation model for the operating frequency bands.
34. Replacement Pole means a new streetlight Pole or utility Pole that is installed
following the removal of an existing Pole.
35. Shot Clock means the timeframes imposed by the FCC on local governments for
the review of Wireless Facility siting applications.
36. Small Wireless Facility (SWF)—referred to colloquially as a “small cell”—means,
consistent with 47 CFR 1.1312(e)(2), a Facility that meets each of the following
conditions:
a. The Facility is mounted on a structure 50 feet or less in height including the
Antenna;
b. Each Antenna associated with the deployment, excluding associated
Antenna equipment, is no more than 3 cubic feet in volume;
c. All other wireless equipment associated with the structure, including the
wireless equipment associated with the Antenna and any pre-existing
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associated equipment on the structure, is no more than 28 cubic feet in
volume; and
d. The Facility does not result in human exposure to RF radiation in excess of
the applicable FCC safety standards.
37. Support Structure means a structure, including, but not limited to, buildings,
monopoles, Towers, Poles, Base Stations, and other free-standing self-supporting
or guyed structures that may support Telecommunications Facilities, whether or
not the structure has an existing Telecommunications Facility.
38. Telecommunications means the transmission, between or among points specified
by the user, of information of the user’s choosing without change in the form or
content of the information as sent and received.
39. Telecommunications Services means the offering of Telecommunications for a
fee, by a person or entity, which the person or entity is authorized to provide under
applicable federal, State, and local law, regardless of the Facilities used. It includes,
without limitation, transmission by optical fiber, coaxial cable, wireless methods,
or any other means, and includes, without limitation, voice, video, data, telephone
service, cellular service, and personal communications services.
40. Telecommunications System means all or any part of a Facility that occupies
property and/or public Rights-of-Way owned or controlled by the City and is used
to provide Telecommunications Services.
41. Wireless Facility Location Plan means a Plan that identifies the location of each
existing Small Wireless Facility and the proposed location of each Facility to be
constructed by or for a Person in the succeeding two-year period in the City.
42. Tower means any supporting structure built for the sole or primary purpose of
supporting any FCC-licensed or authorized Antennas (and related Facilities),
including supporting structures that are constructed for FCC-licensed or
authorized wireless communications including, but not limited to, private,
broadcast, and public safety services, as well as unlicensed wireless services and
fixed wireless services such as microwave backhaul, and the associated site. This
definition does not include a Pole.
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43. Underground District means an area where Poles, utility Poles, overhead wires,
and associated overhead or above-ground structures have been removed and
buried or have been approved for burial underground pursuant to municipal
ordinances, zoning regulations, state law, private deed restrictions, and other
public or private restrictions, that prohibit installing above-ground structures in a
Public Right-of-Way.
44. Underground Facility Area means any area where there currently are no above-
ground utilities or an area that has been designated by the City as an area where
only underground utilities can be placed, including a City-designated
Underground District.
45. Wireless Communication System means all or any part of a Facility that is
licensed by the FCC under Title 47, Code of Federal Regulations, Parts 20, 22, 24,
90, or 101, and is located in whole or in part on public property and/or Public
Rights-of-Way and is used to provide one or more Telecommunications services.
46. Wireless Facility means any infrastructure, including any transmitting device,
tower or Support Structure, and any equipment, Antennas, switches, wiring,
cabling, power sources, shelters, or cabinets, associated with the licensed or
permitted unlicensed wireless transmission or signals, voice data, or images
information. A Small Wireless Facility is a Wireless Facility.
47. Wireless Facility Owner means a Person who owns or operates a Small Wireless
Facility.
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3 Application Types and Requirements
3.1 Prerequisites
The Applicant must have a Master License Agreement (MLA) with the City to operate on
City Poles and/or in the Public Right-of-Way. The MLA may be applied for through the
City Attorney’s office. The MLA also needs to be approved by the City Council. The MLA
will certify that the Applicant is a bona fide company licensed to do business, that it has
the proper insurance and licenses, that the owners are identified and can be found, and
that the Applicant has a process if ownership is to be transferred.
The Applicant must have obtained permission from the structure owner before
submitting an Application. If the structure on which the wireless attachment will be
mounted is owned by any entity other than the City or the Applicant, a copy of any
license, lease, agreement, or other documentation evidencing that the owner of that
structure authorizes the Facilities to be attached must be included with the Application.
The Applicant must have filed an Annual Plan with the City, and paid the annual report
fee.
The Applicant must submit a complete Application with all required submittals (an
Application Checklist is attached as Appendix B), and must submit payment in full for
the Application fee. For applications in the ROW, a notification report must also be
submitted (see Section 5.2.1).
3.2 Application Types
All Encroachment Permit Applications for Small Wireless Facilities shall be submitted to
the Public Works Department for review. An Applicant may apply for a Minor
Modification, Colocation, Replacement, or new structure. The City prefers Colocations
over Replacements, and Replacements over new structures. The City has additional
application requirements and reviews for Replacement and new structures, as described
below.
3.2.1 Replacement Requirements
The City’s existing streetlight Poles typically are not designed to support Small Wireless
Facilities. If the Pole cannot support the equipment, a Replacement Pole will be necessary.
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• An Applicant seeking to replace an existing streetlight Pole to support a Small
Wireless Facility must provide the functionality of the existing Pole. For instance,
if the existing Pole provides lighting, the Replacement must also provide lighting.
• Aerial wires to Replacement Poles are prohibited unless the existing Pole has aerial
wires.
• A Replacement for a City-owned Pole should use one of the City’s standard
designs shown in Appendix A.
• In the case of the Applicant replacing a non-decorative Pole, the preference is to
use Design 1 if it can provide the technical capability required by the Applicant. If
the Applicant can demonstrate that Design 1 cannot provide the required technical
capability, it should use Design 2.
• Replacement wooden utility Poles shall not be more than 10 feet taller than the
original. Replacement streetlight Poles shall not be more than 10 percent taller than
the original and should maintain the same distance to the curbs and sidewalks as
other Poles in the area.
• The Applicant shall minimize the size and aesthetic difference between a
Replacement structure and the original Pole or structure.
• A Replacement streetlight Pole shall be installed in the same location as the
original Pole location, or as close as reasonably possible to the original pole and to
the property line between the residential or business lots. It shall serve the same
primary purpose as the original Pole, which is the provision of lighting in the
designated area.
• A pre-existing utility Pole shall be removed within 90 days after a Replacement
utility Pole is installed.
• Existing streetlight Pole foundations not utilized for new or Replacement Poles
shall be fully removed from the Public Right-of-Way.
3.2.2 New Structure Requirements
• The new Pole shall use one of the standard designs in Appendix A. The City
requires there be no aerial wires to new Poles, unless existing aerial wires are
present and the Applicant receives explicit written approval from the City to do
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so. Where no overhead wires exist, all power and backhaul connections must be
fed from underground.
• Poles and light fixtures shall match or complement the surrounding Poles and
light fixtures and shall meet the City’s standards.
• Aerial wires to new Poles are prohibited. Any connection to a new Pole shall be
underground.
• New Poles shall be located at the same distance from the curbs and sidewalks as
other Poles in the area.
The Applicant shall also provide the following additional information:
• Justification for why the site was selected. Describe the purpose of the site and, if
applicable, why it is not being colocated. List all existing Colocation choices within
1,000 feet and describe why they cannot be utilized.
• A photographic simulation of the structure and equipment from at least two different
directions. If the new structure is visible from adjoining parcels, consideration
should be given to including views from the adjoining parcels.
• Data for any drive tests that were performed by the applicant in t he course of
design. The Applicant should note that the results are attached.
• RF propagation contour maps (needed only if the justification is coverage-
oriented) showing the site with and without the Small Wireless Facility. The maps
should show calculated signal levels in color at the target signal level and plus and
minus 5 dB. Include a legend indicating the signal levels represented by each color.
Include maps showing coverage at the proposed Antenna elevation and at 10 feet
below the proposed elevation. The maps must be legible and in sufficient detail to
show neighborhood streets around the proposed site and adjacent sites.
• Evidence of Capacity exhaustion of the current serving site (needed only if the justification
is Capacity-oriented). The evidence must demonstrate that the Capacity at the
serving site will be diminished within 18 months of the Application such that it
will have a negative impact on the users within the area if new Capacity is not
added. Examples of this may be time-of-day download speeds, utilization over
time, or cumulative key performance indicator (KPI) reports from the serving site.
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3.2.3 Additional Reviews for New or Replacement Poles
To demonstrate that a replacement or new structure is justified, the Applicant must
submit additional documentation with the Application.
The City will conduct an additional review of the Application for a replacement structure
to determine:
• The demonstrated need for replacing the structure at the requested location to
deliver or enhance service
• Whether the Applicant has demonstrated there are no other effective technological
means for colocating on an existing structure
• Whether the appearance and placement of the requested structure is aesthetically
consistent with the immediate area
• The Applicant’s technical objectives and whether the Applicant should use
available or previously unconsidered alternate locations to place the Support
Structure or Wireless Facility
The City will conduct an additional review of the Application for a new structure to
determine:
• The demonstrated need for placing the Support Structure at the requested location
to deliver or enhance service, and that the Applicant has demonstrated there are
no other effective technological means for delivering the service
• The impact of placing a new Support Structure or Facility in the subject area
• The character of the area in which the Support Structure is requested, including
surrounding buildings, properties, and uses
• Whether the appearance and placement of the requested Support Structure is
aesthetically consistent with the immediate area
• The Applicant’s technical objectives and whether the Applicant should use
available or previously unconsidered alternate locations to place the Support
Structure or Wireless Facility
• Whether streetlight spacing guidelines are in compliance
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3.3 Application Submittals
A complete listing of the required submittals can be found in Appendix B. All required
submittals for a given Application type must accompany an Application.
3.3.1 Radio Frequency Analysis
As a condition of approval for installations on all Poles, Applicants shall provide an
evaluation of proposed wireless equipment to prove compliance with FCC guidelines for
human exposure to radio frequency (RF) fields. Evaluations shall include uncontrolled
exposure in the near field and far field regions. Additional evaluations shall be provided
whenever the transmitting power of existing equipment is increased. The analysis shall
document existing and proposed radio frequencies, and summarize possible RF
interference.
At a minimum the analysis must contain the following items:
• A statement of compliance
• Date of the report
• Date of statement of compliance
• Pole number proposed for the Small Wireless Facility installation
• Applicant’s site or identification number for the Small Wireless Facility installation
• GPS coordinates of the proposed Pole
• Calculation of RF power at the radios or other electronics
• Calculation of RF power at the Antenna
• Calculation of RF power within 6 feet of ground level and at ground level
• Calculation of RF power at windows of residences and businesses in closest
proximity to the Small Wireless Facility
• Calculation of RF power of the closest area that can be occupied by the gener al
public in the main lobe of the Antenna if within 50 feet.
• Location of the applicable signage with above-ground-level height listed
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3.3.2 Structural Analysis
Pole loading analysis with all equipment relating to the deployment of the Small Wireless
Facility based on the latest version of the American Association of State Highway and
Transportation Officials (AASHTO) “LRFD Specifications for Structural Supports for
Highway Signs, Luminaires, and Traffic Signals”5 will need to be conducted. Pole loading
analysis sealed by the Pole manufacturer’s licensed professional structural engineer shall
be provided. Also, foundation analysis and a document sealed by a Professional Engineer
licensed in the state of California certifying that the existing foundations in the f ield can
safely support the additional load from the attachment shall be provided. A 30 percent
load bearing factor of safety must be allowed for each structure.
3.3.3 Construction Drawings
3.3.3.1 General
All design documentation shall be submitted electronically with an Application and shall
fully depict the scope of work to be performed by the Applicant (e.g., a wireless provider
applying for a lease to place a Small Wireless Facility in the Public Right-of-Way).
The Applicant shall indicate the design of the support Pole, the Small Wireless Facility,
and any other attachments (such as fiber demarcations, battery backup, and power
meters) in the design documentation. Design documentation shall include any
handholes, manholes, pedestals, demarcation enclosures, splice cases, and duct
surrounding the Small Wireless Facility and illustrate how the backhaul and power will
interconnect with the Small Wireless Facility.
Design documentation shall be specific to the design with no handwritten or
superimposed annotations other than the professional engineer’s signature and stamp
where required. Design documentation containing strictly generic typicals will not be
accepted. Design documentation shall be original plotted digital renderings created with
computer-aided design software and presented in PDF file format. Design
documentation of poor visual quality (as determined by the City reviewer) may not be
accepted.
5 First edition and interim revisions are available on AASHTO’s website
(https://store.transportation.org/).
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Location information must be provided and shall incl ude the 911 address of the Pole
proposed to be utilized, GPS coordinates of the Pole, and the location of the attachment.
A location/vicinity map identifying the Pole and adjacent Pole infrastructure within a
300-foot radial distance shall be provided.
The attachment installation details shall include detailed information about methods
proposed to be utilized to Install all equipment relating to the deployment of the Small
Wireless Facility. The details shall also identify the existing Pole infrastructure t hat is
proposed to be utilized and the innerduct that needs to be utilized for installing service
cable. Underground conduit entry into the Pole infrastructure shall be the only permitted
access for installing service cable.
3.3.3.2 Paper Size
All design documentation shall be legible when printed on 24 x 36-inch paper.
3.3.3.3 Abbreviations
All annotations, call-outs, notes, and descriptive text shall be in plain language. If
abbreviations are used to promote clarity in the design documentation, a legend shall be
provided that clearly describes the abbreviation.
3.3.3.4 Line Weights and Annotations
Descriptions of existing above-ground features and below-ground utilities in Plan view
and profile view sheets shall have a consistent, screened line weight. All features and
components of the proposed Small Wireless Facility—as opposed to existing conditions—
shall have a consistent, heavier line weight than existing above-ground features. All
annotations for the proposed Small Wireless Facility shall be noticeably heavier than
other annotations on the Plan and profile sheets.
A Plan sheet example with suitable line weights and annotations is shown in Figure 1. A
sample profile sheet with suitable line weights and annotations is shown in Figure 2
(below).
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Figure 1: Sample Plan Sheet with Suitable Line Weights and Annotation6
6 Annotations for travel lanes, road names numbers, clear zone, and Public Right-of-Way were omitted for clarity.
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Figure 2: Sample Profile Sheet with Suitable Line Weights and Annotation
3.3.3.5 Required Sheets and Information
Design documentation shall include, at a minimum, the following sheets for all types of
Applications except for Small Wireless Facility removal:
• Title
• Plan View
ROAD
SOUTH VIEW
ROW
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• Profile
• Equipment
• Traffic Control Plan
• Lighting Plans
• Details
• Photo Simulations
• Circuit Tracing Diagram
Applications to remove a Small Wireless Facility shall include a title sheet, a list of items
that will be removed, traffic control Plans, and a description of proposed restoration.
3.3.3.5.1 Title Sheet Requirements
The title sheet shall include the following items:
• Project site location (with a vicinity map). Indicate the street address(s) for the
nearest building(s).
• A clear project description describing types and numbers of equipment. Also
indicate whether Pole will be replaced (with existing and proposed heights) and
whether any existing road signage is proposed to be relocated or removed.
• Applicant name
• Contractor name or names
• Pole owner name and pole number
• Equipment owner
• Applicant’s site name and/or identifier number
• Full address of proposed Small Wireless Facility location (if none available, use
closest address to assist the reviewer in finding the site)
• Latitude and longitude expressed in degree/decimal format (e.g., XX.XXXXXX) to
the NAD83 standard and accurate to ±1 meter.
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• Email and phone number for the Applicant’s engineer
• Email and phone number for the Applicant’s single point of contact
• 1-square-mile map of the area for orientation purposes
• A list of applicable codes and applicable engineering standards (most recent
version) with which the Application complies
• Sheet index (table of contents) listing only submitted sheets
• Seal and signature from a State of CA-certified Professional Engineer (P.E.)
• P.E.’s statement with the following signature line placed in the lower right -hand
quadrant of the title page:
I, ___________, a registered Professional Engineer in the State of California, do hereby
certify that this drawing was prepared by me, or under my direct supervision, and that
all information contained herein regarding safety is in accordance with the listed
applicable codes and applicable engineering standards, without exception or exclusion,
stated or otherwise. ________________________________
PE Signature
3.3.3.5.2 Requirements for Plan Sheets
The Plan sheets shall accurately depict existing features that apply, such as:
• State roads and interstates (name and number)
• Municipal roads (name)
• Private roads
• Travel lanes
• Right-of-Way and other property lines
• Sidewalks and accessibility ramps
• Bike trails/lanes/paths
• All existing visible features, street furniture, and structures within the Cit y Right-
of-Way
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• Property addresses for parcels abutting the City Right-of-Way
• Area zoning boundaries and indication of the zone type, if any (e.g., residential,
mixed-use, commercial, industrial)
• Premises outlines with address numbers, if applicable
• Existing underground utilities
• Visible underground utility appurtenances (e.g., valves, fire hydrants)
• Any new proposed vaults
• FEMA Special Flood Hazard Areas (where applicable)
• Stormwater facilities and culverts
• North arrow indication
• Recorded easements (if appropriate)
• Limits/boundary of construction
• Notes to identify method of construction (if not explained on a details sheet)
• Reference to any applicable details
• Any structure proposed to be installed or replaced
• A color photo of the proposed Small Wireless Facility location (with approximate
placement identified) taken during a field survey conducted within 90 days of the
date of the Application submittal; internet street -view photos are not acceptable,
and the size of the photo shall be no less than 3 x 4 inches when printed on an 11
x 17-inch sheet
Plan sheets may have aerial imagery as the base layer. The Applicant’s P.E. shall confirm
that the aerial imagery is suitable to depict current conditions as related t o the
Application. If a Plan sheet with aerial imagery is used, an additional Plan sheet of the
same perspective, orientation, scale, and detail will be required without the imagery.
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Plan sheets shall include the dimensions of all setbacks, offsets, and r oad widths related
to the proposed Small Wireless Facility. Dimensioning should include but not be limited
to:
• Road and City Right-of-Way widths
• Distance from existing and proposed underground Facilities to the City Right-of-
Way and edge of pavement
• Setback to premises
Plan sheet features shall be drawn to scale except for symbols. Symbols are only to be
used to preserve clarity (i.e., an existing 8-inch water line does not need to be drawn to
scale). The main Plan sheet scale must be in the range from 1:20 (inch:foot) to 1:50.
Detailed illustrations can be added to show greater clarity using a larger scale (e.g., 1:10
or 1:5).
3.3.3.5.3 Elevation Sheet Requirements
A profile sheet shall accurately depict the following items:
• View direction (facing)
• The entire dimension of the Pole (new/proposed/existing)
• Existing structure view, if the proposed Small Wireless Facility will replace an
existing structure
• Proposed structure view, or two different adjoining views (e.g., north and west) if
it is a new structure
• All attached Small Wireless Facility equipment (e.g., Antenna, ancillary
equipment)
• Foundation view or reference to detail sheet for proposed foundations
• Buried Pole depth for new or replaced utility Pole without foundation
• Proposed hand boxes, vaults, and hand holes
• Proposed underground conduits (within 10 feet of the network Support Structure)
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• Grounding detail or reference to detail sheet
• Proposed ground-based enclosure (where permitted)
• Roadway features, including driveways, ramps, and sidewalks, to verify Pole
location will not interfere with proposed Improvements
• Minimum depth of cover for proposed power and communications conduit
• Offset from City Right-of-Way line to power
• Location of any warning stickers. RF warning sticker shall be facing out to street
and near Antenna, or away from street and near Antenna if no window within 50
feet.
All the following items shall be dimensioned:
• Antenna height above Pole
• Pole dimension at the base
• Distance from City Right-of-Way line
• Antenna and remote radio unit (RRU) offsets from Pole
• Overall height of the Pole above grade
• Vertical clearance of any adjacent overhanging roadway
• Ground-based enclosures and height of equipment above grade (where permitted)
• Pole-mounted enclosures and height of enclosure above grade
The profile sheet shall also show, to scale:
• Any street signage that is to be placed on the Pole, and that is used to screen Small
Wireless Facility equipment; relocated signage shall be placed at an elevation that
is consistent with the original height of the signs
• Equipment stacked together as close as possible while complying with airflow
requirements
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• Other elements (e.g. NEMA, PBX, or J boxes), ground bus bars, and base plate
mounts, if utilized
• Offset (distance) from the Pole of any equipment cabinets, including the maximum
offset from the Pole to the outermost edge of the Facilities
3.3.3.5.4 Equipment Sheet Requirements
Equipment sheets are specialized typical detail sheets that tabulate cubic volume for a
Small Wireless Facility. An equipment sheet shall accurately include each of the following
that apply:
• List of external components separately in detail
• Length, width, and depth of equipment
• Manufacturer and model number
• Total cubic feet
In addition to the individual component typical detail, each equipment sheet shall
include a separate note box that identifies the total Small Wireless Facility volume, in
cubic feet, as shown in Figure 3.
Figure 3: Sample “Total Cubic Feet”
TOTAL WIRELESS FACILITY CUBIC VOLUME (cu. sf.):
TOTAL ANTENNA CUBIC VOLUME (cu. sf.):
TOTAL ANCILLARY EQUIPMENT CUBIC VOLUME (cu. sf.):
Line work and annotations shall be drafted using computer-aided design software.
Scanned or cropped images are not acceptable. Equipment shall be drawn to the scale per
the dimensions referenced in the Plan view and profile view sheets.
Each typical detail shall be numbered and labeled to reference the typical sheet and
specific individual details. The use of borders around typical details is required (see
Figure 4).
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Figure 4: Typical Detail
3.3.3.5.5 Traffic Control Plans
The Applicant shall provide the City with a set of traffic control Plans that fully detail the
regulation of traffic on the adjacent roadway. The Plans shall specify how traffic will be
regulated before, during, and after any planned construction or maintenance related to
the Small Wireless Facility. The traffic control Plans shall conform to the safety and design
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standards set out in the current version of the California Manual on Uniform Traffic
Control Devices (MUTCD).7
A traffic control Plan for all modes of transportation shall be submitted for the work
proposed to be performed on any part of Pole infrastructure and/or equipment located in
the Public Right-of-Way or easements granted to the City. The traffic cont rol Plan shall
need to be utilized during installation, maintenance and removal of any equipment
relating to the deployment of a Small Wireless Facility.
3.3.3.5.6 Demarcation Point
The City understands that different Applicants, and different Applications by an
Applicant, may take different approaches to backhaul. In some cases, the Applicant may
propose to build and own the backhaul. In others, it may build and own the Small
Wireless Facility and another entity may build and own the backhaul. In others, it may
obtain backhaul from the City.
The Application shall clearly indicate the demarcation between the backhaul and the
Small Wireless Facility.
If Small Wireless Facility equipment is to be located on the Pole itself or in an
underground vault in close proximity to the Pole, the vault containing the Small Wireless
Facility equipment is the demarcation point. Figure 5 illustrates the physical demarcation
between the backhaul and the Small Wireless Facility at a line interface unit (LIU) also
known as the network interface device (NID).
Figure 5 illustrates a scenario in which the backhaul (dotted line) is delivered
underground. The backhaul provider typically builds a handhole containing the
transport cable for the Small Wireless Facility connection. It is recommended that the
handhole be located within 10 feet of the Pole. The demarcation point is the splice point.
7 https://dot.ca.gov/programs/traffic-operations/camutcd
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Figure 5: Example Underground Communications Demarcation Point
3.3.3.5.7 Photo Simulations
Photo Simulations must be submitted with all Colocation, New, or replacement
Applications.
The simulations must correctly show equipment sizes, enclosures, signs, and offsets—as
well as RF warning stickers, if visible from given perspectives.
The photo simulations should use perspectives that provide a true sense of distance to
the nearest residential windows or primary facades of buildings, as well as the scale of
the Facilities.
3.4 Annual Plan
Applicants must submit an Annual Plan that describes its projected growth of Antenna
sites in the City, and must update the Plan at least annually. More frequent updates are
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recommended if the information submitted in the previous Plan changes significantly.
The Plan must include:
• A description of the geographical areas of the City in which new service will be
provided or existing service will be updated
• The location of existing Wireless Facilities, with structure types, on a large -scale
map
• The location of future planned Wireless Facilities (preferred and non-preferred),
with structure types, on a large-scale map
• A list of existing and future Wireless Facilities in digital format such as Excel,
including structure types, proposed City pole numbers, and approximate
addresses
• A deployment Plan and schedule
At the request of the City, the Applicant shall also have an engineer visit each individual
location/area to conduct a field verification that identifies living units, building
addresses, existing Facilities, distance measurements, Public Right -of-Way, and Private
Property lines. The Engineer shall also identify other potential sites for Small Wireless
Facilities in the event that the Applicant’s first choice is not realized. The Applicant shall
consider public safety, aesthetics, the overall network design, and consistency with all
siting criteria agreed to with the City.
3.5 Inventory
The Applicant shall maintain, within or near the City, an inventory of new streetlight
Poles of the same design, size, and color as the new streetlight Poles that hav e been
installed to ensure that new streetlight Poles may be promptly replaced in the event of a
failure of a new streetlight Pole, whether caused by the Wireless Facilities or by any other
event, including an Act of God.
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4 Internal Application Review and Decision-Making Process
This section presents a candidate process for the City’s review of wireless facility siting
applications. Figure 6 shows the workflow step-by-step, identifies a range of review
types, the personnel required to execute them (see Section 4.1), and likely timeframes for
completing each type of review (see Section 4.2). This process is intended as a starting
point for discussion. The review categories and role types may be modified based on the
City’s preferences.
The flowchart breaks the review process into four large components:
1. An intake review
2. An engineering review
3. A City requirement review and site survey
4. A completeness review
Using this segmentation and sequencing makes it possible to organize the process to meet
the FCC’s shot clocks. These reviews are described in more detail in Section 4.3 and
Appendix D. The final steps, including preparation of a recommendation and report, and
the City’s decision-making and permit close-out, are described following the reviews.
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Figure 6: Candidate Application Review Process Flowchart
4.1 Personnel Required
The City needs to maintain staffing with a range of skill sets to perform the reviews and
manage the life cycle of wireless siting applications and inspections, as outlined in Section
4.3. The staffing counts typically are determined by need. The personnel can be a
combination of in-house resources and outside contractors.
The City’s required staffing levels will depend on the number of applications it needs to
process. As of this writing, the City’s assigned staff members each perform more than
one of the roles described here, in addition to other responsibilities. It is likely the City
will continue to task staff to handle a variety of roles.
The needed skill sets include:
• Program Director/Manager – Acts as team lead, provides overall program
guidance, and typically acts as Final Approver
• Permit Coordinator – Performs intake review and support roles
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• Engineer – Responsible for detailed engineering reviews, especially checking for
compliance with FCC requirements, laws, codes, and design standards
• Field Technician – Performs site surveys and engineering reviews as needed
• Legal Support – Provides legal counsel as needed
• Final Approver – Determines final approval or rejection based on
recommendations report
4.2 Target Timeframes for Review and Decision-Making Process
Applications should be processed in a predictable and timely manner . Each of the
reviews should have an expected timeframe, both as a guide and metric for the City’s
staff and to outline a predictable timeframe for applicants. Table 1 and Figure 7 present
candidate timeframes for each typical review task. Some of the reviews may not be
needed for every Application type.
Table 1: Target Workdays per Task
Task Workdays
Intake Review 1
Engineering Review 5
City Requirement Review 2
Site Survey 5
Completeness Review, RFI Issuance, Resubmission Review 6
Recommendation and Report 5
Because some of the tasks can be performed in parallel, the City could potentially
complete the intake, engineering, and City requirement reviews within eight workdays.
After the reviews are completed, the City would either issue an RFI or consider the
application complete. Using this framework, the entire process can be completed within
approximately 30 workdays (assuming the applicant responds to an RFI, if one is issued,
within a few days).8
8 See Section Error! Reference source not found. for details on the RFI process and the shot clock.
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Figure 7: Target Number of Workdays per Step in the Wireless Siting Review Process
The City will consider an Application as submitted only after all prerequisites are met
(see Section 3.1). The City will start the Shot Clock on the first business day after the
Application is submitted. The Shot Clock will stop if the City issues an RFI to the
Applicant, or if the City and the Applicant mutually agree to toll the Shot Clock. The Shot
Clock will restart on the first business day after the Applicant responds to the RFI, or
when the mutually-agreed tolling stops.
If the Applicant does not respond to an RFI within 90 days, the Public Works Department
has the right to withdraw the Application upon written notice to the Applicant.
The permitting office has the right to withdraw the Application if the Shot Clock is tolled
for more than 120 days.
4.3 Reviews
The following sections describe a candidate process for the City’s review of wireless
facility siting applications.
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4.3.1 Intake Review
The Permit Coordinator performs an intake review after the applicant submits the
application. The Permit Coordinator also reviews for overall completeness and accuracy.
In some circumstances, the Permit Coordinator may halt the process if the application i s
incorrect or missing substantial information that would prevent subsequent reviews from
being conducted; in that case, the Permit Coordinator would immediately request
corrections or additional information from the applicant.
Because the comprehensive intake review includes checking the accuracy of items such
as the proposed site’s address and GPS coordinates, technical personnel participate in the
review.
After the intake review is complete, the Permit Coordinator issues subsequent action
items, some of which may run in parallel. This includes an engineering review and a City
requirement review.
4.3.2 Engineering Review
A qualified engineer reviews the application to verify compliance with FCC
requirements, conformance to the City’s specifications, and other safety criteria such as
structural soundness, and evaluate potential alternative locations. The engineer should
have a strong RF background because much of the review will be to analyze RF -related
elements such as coverage, capacity, and antenna height.
The engineer should consider not only the current application, but also previous
applications submitted for attachment at or near the same site for consistency with any
previous recommendations at the site. The engineer should also ensure that the proposed
installation will not cause any RF interference with City-owned and operated systems.
4.3.3 City Requirement Review and Site Survey
The City requirement review checks that the application is compliant with City and
zoning requirements. An example of a local requirement may be specific aesthetic
concerns such as standardizing the shroud heights so there is a similar appearance across
all Small Wireless Facility sites.
For applications for a new or replacement structure, the City performs a survey of the
proposed site to verify there are no nearby structures that could be used instead. The
survey also analyzes sight lights to ensure new or replacement facilities would not
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obstruct vehicular or pedestrian views or create potential safety concerns. Site survey
data are entered into the City’s site database.
4.3.4 Completeness Review, RFI Issuance, Resubmission Review
If more information is required to complete or correct the Application, or if modifications
are needed to comply with the design standards, the Permit Coordinator issues a request
for information (RFI). The City consolidates the information requests related to the intake,
engineering, and City Requirement reviews and issues a single RFI to the Applicant.
(Because each RFI causes a delay in the review process, and to make the review process
more efficient, the City’s goal is to issue as few RFIs as possible.) This proposed
centralized RFI approach is illustrated in Figure 8.
Figure 8: Recommended Request for Information Process
The FCC Shot Clock associated with the City’s review of the Application stops when the
City issues an RFI and restarts once the applicant responds. However, because changes
that could affect the City’s final recommendation may occur at the Applicant’s proposed
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site location, the City imposes a reasonable time limit, 90 days, for the Applicant to
respond to an RFI. If a response is not received within 75 days, the Permit Coordinator
may send a letter informing the Applicant that if the information is not received within15
additional days, the Application will be deemed withdrawn
Once the Applicant responds to an RFI, the Permit Coordinator records the date in the
system and sends the information received to the respective reviewer(s), who continues
the review. Additional RFIs may be required until the application is satisfactory.
If no additional information is needed, the Permit Coordinator updates the status of the
application to “complete” and requests a recommendation.
4.4 Recommendation and Report
After the required reviews are complete, the Permit Coordinator checks that the process
was followed correctly and the application is complete; evaluates the output from each
reviewer; and assigns a status of either Recommended (for approval), Not Recommended, or
Recommended with Conditions. The Permit Coordinator then prepares an application
report9 in a standard format.
The report includes any backup information supporting the recommendation. It provides
a summary of the application with information such as location, characteristics, and
specifications compliance details.
The Permit Coordinator then sends the application and the recommendation report to the
Final Approver (or other responsible entity designated by the City) for a final decision.
4.5 Decision
The responsible decision-maker makes a recommendation of Approved, Approved with
Conditions, or Rejected. The applicant is notified of the decision and receives comments
that explain the decision if the decision is Approved with Conditions or Rejected.
9 We recommend that minor modification and colocation applications not require a formal report unless
compliance cannot be definitively deter mined, in which case the formal report will explain the situation.
Recommendations for new structures or initial colocations should require a formal report.
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4.6 Notification, Construction, and Permit Close-out
The Applicant will deliver a door hanger to residents within 300 feet of the Wireless
Facility after the necessary permits have been issued, and at least one week prior to
commencement of construction.
After the site is constructed per the approved plans, and all necessary site inspections are
performed, the applicant is required to submit as-built plans (if needed) and an activation
report. After the City reviews the as-built plans and the activation report to verify that
the installation conforms to the approved application, the City finalizes and closes out
the permit. A Site Completion Checklist is in Appendix C.
As-built Plans are required if there are any modifications or deviations from the approved
Plan set. In this case, as-built documentation must be submitted to the City within 30 days
of completion. Documentation should include construction drawings showing any
changes to the proposed Application.
After the Facility has been constructed, the Applicant will be required to cover all
reasonable costs associated with the measuring, recording, reporting and monitoring of
emissions, including electromagnetic radiation (EMR)/RF and noise associated with the
Facility. Such information shall be provided, within 30 days of activation of the
equipment, in an Activation Report which shall be made available to any interested party
through the City’s Public Works Department.
The Activation Report shall be prepared by a licensed professional engineer or other
technical expert approved by the City, and shall provide information that demonstrates
the Facility will not cause any potential exposure to RF emissions that exceed adopted
FCC standards for human exposure. Testing shall be conducted in compliance with FCC
regulations governing the measurement of RF emissions; testing shall be conducted
during normal business hours on a non-holiday weekday with the subject equipment
measured while operating at maximum power. For all measurements made, evidence
must be submitted showing that the testing instrument(s) used were calibrated within
their manufacturer’s suggested periodic calibration interval, and that the calibration is by
methods traceable to the National Bureau of Standards. At the sole option of the City
Engineer, an agent of the City may monitor the performance of testing required for
preparation of the Activation Report.
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At least 14 calendar days prior to conducting the testing required for preparation of the
Activation Report, the Applicant shall notify the Public Works Department, and shall
send a letter, via U.S. Postal Service registered mail, to the resident of any dwelling unit
within 100 feet of the Wireless Facility, notifying them of the date on which testing will
be conducted.
Residents notified of the testing may request, in advance of the test, that the Applicant
conduct testing of total power density of RF emissions within their residence on the date
on which the testing is conducted for the Activation Report.
In the event that the Activation Report includes a finding that RF emissions for the site
exceed FCC standards (see Section 5.4), the Applicant will be required to immediately
cease and desist operation of the Wireless Facility until such time that the violation is
corrected to the satisfaction of the City Engineer.
Any Facility owner authorized by the City to operate a specific Wireless Facility
installation may assign the operation of the F acility to another carrier licensed by the
California Public Utilities Commission (CPUC) and FCC for that radio frequency
provided that such transfer is made known to the City Engineer in advance of such
operation, and all conditions of approval for the subject installation are carried out by the
Facility owner.
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5 Technical and Aesthetic Standards for Wireless Facilities
The technical and aesthetic standards presented here (which we refer to as the “Technical
and Aesthetics Standards Manual,” because it can be published separately if the City so
chooses) are intended to govern the access to and use of private and public land and
structures by wireless carriers, infrastructure companies, or others (collectively referred
to as “Applicants”) for installation of wireless facilities and associated equipment as
defined by the FCC.
This Manual is intended to address public safety and employee safety, and to protect the
community’s aesthetic standards.
This Manual is part of an evolving process that considers the ongoing development of
communications technologies. The Manual may be amended to accommodate future
technological and regulatory changes.
All Applicants must follow the National Electrical Safety Code (NESC), General Order 95
of the California Public Utilities Commission, and all other applicable engineering
standards, FCC standards, and federal, state, and local standards and codes that are
effective as of the Application filing date.
5.1 General Technical and Aesthetic Requirements and Guidelines
All Wireless Facilities shall utilize stealth and Concealment methods to limit their visual
impact when feasible. Stealthing features should include blending with the environment,
concealing the equipment and Antennas, matching colors, and limiting the overall size
(including height).
5.1.1 Prohibited Structures
Wireless Facilities shall not be placed, installed, or attached on the following structures:
• Poles containing controls such as fire alarms, police signals, or traffic signals
• Structures on which Wireless Facilities would conflict with existing or planned capital
projects (as listed on the City’s website) or wireless systems
• New wooden Poles, except as a Replacement for an existing utility Pole
• Existing decorative Poles, which are defined as structures specially designed and
placed for aesthetic purposes and on which no appurtenances or attachments, other
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than lighting, specially designed informational or directional signage, or temporary
holiday or special events attachments, shall be placed
5.1.2 Location
Wireless Facilities shall not be installed in or within 50 feet of a Protected Area (as defined
in Section 2) without approval by the Public Works Department. No new structures are
allowed in Protected Areas or residential areas outside the Public Right-of-Way.
5.1.3 Non-Public Right-of-Way Dimensions
The following are recommended criteria for any facilities installed outside the Public
Right-of-Way. (Facilities inside the Public Right-of-Way have more restrictive
dimensions, as described in Section 5.2.) Maximum allowed dimensions for Antennas
installed outside the Public Right-of-Way are:
• Parabolic/Other Antennas – 5 feet 6 inches (maximum length) – 6 cubic feet
• Massive MIMO – 5 feet 6 inches (maximum length) – 46 cubic feet
• Panel Antennas – 9 feet (maximum length) – 13 cubic feet
• Whip Antennas – 20 feet (maximum length) – 4 cubic feet
No new structures over 179 feet above ground level are allowed.
Wireless Facilities shall not extend more than 20 feet above the height of the Tower or
Support Structure to which it is attached.
5.1.4 Use of Alternative Pole Designs
Wireless Facilities on a new or replacement Pole shall follow one of the standard designs
in Appendix A, which establish minimum standards, expedite the review process,
establish consistency in the types of Poles, and provide the Applicant with the flexibility
of a wide range of configurations and potential equipment suppliers.
However, if the Applicant can prove it is not technically feasible to use one of the
standard designs, the Applicant may propose an alternative Pole design. If the Applicant
opts to deviate from a standard design (see Appendix A), it must submit evidence that
the standard designs will not accommodate the proposed Facility. A proposed design
and a structural analysis shall accompany the Application.
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The City will conduct an additional review of the Application for an alternative structure
to determine:
• The demonstrated need for an alternative design at the requested location and
geographic area in order to deliver or enhance service, and that the Applicant has
demonstrated that there are no other effective technological means for delivering the
service with a standard design
• The impact of placing the proposed structure or Facility in the subject area
• The character of the area in which the structure is requested, including surrounding
buildings, properties, and uses
• Whether the appearance and placement of the requested structure is aesthetically
consistent with the immediate area
• The Applicant’s technical objectives and whether the Applicant should use available
or previously unconsidered alternative locations to place the Wireless Facility
The City may seek public comments or require a public hearing as part of the review.
The alternative design must comply with the requirements in Section 5.1.
5.2 Requirements and Guidelines in the Public Right-of-Way
This section outlines additional requirements for Small Wireless Facilities installed in the
Public Right-of-Way (as compared to the general requirements listed in Section 5.1). Only
Small Wireless Facilities may be installed in the Public Right-of-Way (as opposed to larger
facilities that are allowed outside the Right-of-Way).
A wireless provider shall Construct and maintain Small Wireless Facilities and wireless
Support Structures in a manner that does not:
• Obstruct, impede, or hinder public access or impact public safety within a Public
Right-of-Way
• Obstruct the legal use of a Public Right-of-Way by any public or private utility
providers
• Obstruct access to any fire escape, fire hydrant, doors, gates, stoops, public
transportation vehicles, shelters, street furniture, or other improvements at any public
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transportation stop (including, without limitation, bus stops, streetcar stops, and bike
share stations)
• Obstruct the sight line of any street, alley, or driveway
• Obstruct public works projects
In addition:
• Antennas and equipment shall be passively cooled, unless fans are explicitly
approved in writing by the Public Works Department
• Battery backup power devices, where permitted, shall be installed with a transfer
switch to prevent back-feeding into the electrical system; no other types of backup
power shall be permitted
• The Applicant shall repair any damage to Public Right-of-Way incurred as a result of
work performed by or on behalf of the Applicant and return the site to its original
condition prior to installation
• Poles installed in the Public Right-of-Way in a Protected Area shall not exceed 36 feet
in height
• Poles installed in the Public Right-of-Way shall not exceed 41 feet in height
5.2.1 Notification
The Applicant shall mail courtesy letters to all residents within the City’s established
notification radius of the Facility before submitting a final Encroachment Permit
Application package. The notice will alert the residents of the proposed Facility and will
indicate the date on which the notification period ends and resident feedback is due, per
established City guidelines.
The Applicant shall provide a Community Liaison to act as a point of contact for notified
property owners. The Community Liaison will prepare and retain a report documenting
all inquiries received and the disposition of each. The Applicant will respond to all
inquiries within 48 hours. Residents’ concerns will be identified and reviewed by the
Applicant’s Construction and Engineering staff, and the Applicant will work to address
concerns and provide information where feasible.
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The Applicant will provide a report to the City detailing all resident inquiries about the
Application. The information will include resident name, contact information, date of
receipt, date of response, and resolution. The Public Works Department will review
inquiries it receives from residents and will provide recommended actions for the
Applicant to follow. These actions may consist of revising the proposed Wireless
Facility’s location or scope, re-notifying affected residents of modifications to proposed
Facilities, and/or requesting installation of additional screening for Facilities.
5.2.2 Structure Types
The City has established an order of preference for Wireless Facility installation types
within the Public Right-of-Way. The most preferred types are those that have the lowest
incremental impact and use existing resources. Therefore, an underground solution is the
most preferred.
The City’s standard designs for replacement streetlights are the next -most-preferred
installation types, followed by standard designs for new streetlights. (See Appendix A
for the standard designs.) Small Wireless Facilities colocated on wooden utility Poles
(which are less easily concealed) are next, and Facilities on replacement wooden Poles
are least preferred.
Table 2: Installation Type Preferences
Installation Type Preference (Most to Least Preferred)
1. Underground vault
2. Design 1: Replacement streetlight
3. Design 2: Replacement streetlight
4. Design 1: New streetlight
5. Design 2: New streetlight
6. Colocation on wooden Pole
7. Replacement wooden Pole
5.2.3 Location
Small Wireless Facilities must adhere to the following guidelines:
• The City prefers locating new Wireless Facility installations in non-residential
zones.
• The City prefers locating new Wireless Facility installations near property corners
or side property lines, and not directly in front of residences and businesses.
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• The design should minimize views from habitable living areas (such as bedrooms
or living rooms) of residential units that directly face the Antenna.
• Small Wireless Facilities and associated Support Structures shall be located to
avoid any physical or visual obstruction to pedestrian or vehicular traffic or any
other safety hazards to pedestrians, cyclists, or motorists. If the City determines
that a proposed location would present any such hazards, the City shall require
the Applicant to choose an alternate site.
• Small Wireless Facility Poles should be installed, to the maximum extent possible,
with a minimum 20-foot setback from residential buildings as measured from the
center point of the Support Structure.
• Small Wireless Facility Poles shall be installed with a minimum 20-foot setback
from commercial buildings as measured from the center point of the Support
Structure.
• A Small Wireless Facility installation or mounting must be performed in a manner
that attempts to preserve the existing tree canopy.
• A single Applicant’s Small Wireless Facilities shall, to the maximum extent
feasible, be installed with a minimum spacing of 500 feet from the Applicant’s
nearest existing site or the nearest site for which the Applicant has applied to site
a Wireless Facility.
• No Small Wireless Facility shall be installed within 100 feet of a public school
building.
• Any Small Wireless Facility installed in the Public Right-of-Way or in an easement
shall be in alignment with the existing vertical infrastructure, streetlights, utility
Poles, and trees.
• The placement of Small Wireless Facilities shall be consistent with existing
structures and aesthetics, in harmony with the surroundings, and as unobtrusive
as possible. For example, in areas with decorative streetlight Poles, Small Wireless
Facilities on streetlight Poles must be consistent with the existing decorative
streetlight Poles, calling for a design that is comparable in scale and incorporates
the design characteristics of those Poles.
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• A Non-City-owned replacement Pole shall be installed in the same location where
possible, or within 2 feet of the original Pole location, and as close as possible to
the line between residential or business lots. It shall serve the purpose of the
original Pole (i.e., lighting) while also serving as a supporting structure for the
Small Wireless Facility.
• No Small Wireless Facilities shall extend over the roadway.
• To preserve the look and feel of the City’s parks, no Small Wireless Facilities shall
be installed in a park unless approved by the Public Works Department.
5.2.4 Facilities
• Advertising on Support Structures or equipment is prohibited.
• In hollow structures, the wiring and cables should be housed within the Support
Structure.
• Spools and/or coils of excess fiber optic or coaxial cables or any other wires shall
not be stored on the Pole except completely within the approved enclosures or
cabinets.
• Signs or illumination on the Antennas or Support Structure are prohibited unless
required by the FCC, the FAA, or the City.
• Small Wireless Facilities, wireless supporting Poles, and related ground
equipment shall not impede pedestrian or vehicular traffic in the Public Right-of-
Way; if any Small Wireless Facilities, wireless supporting Poles, or ground
equipment is installed in a location that is not in accordance with the Plans
approved by the City and impedes pedestrian or vehicular traffic or does not
comply or otherwise renders the Public Right-of-Way non-compliant with
applicable laws, including the Americans with Disabilities Act, then the Wireless
Facility Owner shall promptly remove the wireless Facility, wireless supporting
Poles, and/or ground equipment.
• A distinct marker (tag) may be placed on Small Wireless Facilities, at the discretion
of the City, that will allow for ready identification of the type of attachment, its
owner, and contact information; the marker shall be limited to a 3-inch by 2-inch
plate.
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• All Antennas and Small Wireless Facility equipment must be placed in-line or be
flush-mounted with the Pole.
• Removal and relocation by the Wireless Facility Owner of its Small Wireless
Facility, wireless supporting Pole, or related ground equipment at its own
discretion shall be in strict accordance with the City’s Municipal Code and Master
License Agreement.
• The Wireless Facility Owner understands and acknowledges that the City may
require the Wireless Facility Owner to remove or relocate its Small Wireless
Facility, wireless supporting Poles, and related ground equipment, or any portion
thereof from the Public Right-of-Way for construction projects as allowed by the
Municipal Code and Master License Agreement.
• When Antennas are placed in-line with the Pole, Antennas must have a smooth
cylindrical shape (ideally, a single canister, or multiple separate Antennas placed
inside sheeting that is flush with the Pole, or a form factor in which multiple
Antennas merge into a single smooth shape); no separately mounted Antennas
will be allowed on a single installation (for example, physically separate panel
Antennas for each sector).
• Antennas on streetlight Poles must be the same color as the Pole.
• Antennas on wooden utility Poles must be a neutral, unobtrusive color (e.g., black,
brown, dark green) and shall match the existing pole color or surrounding
environment as much as is reasonably practicable.
• Small Wireless Facility antennas enclosed in a canister shall substantially comply
with a combined maximum height of 5 feet 6 inches, and diameter of 1 foot 3
inches.
5.2.5 Electric Supply
The City shall have access to the power meter and power disconnect switch if emergency
services or City staff need to have access to the Pole.
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5.2.6 Backhaul Connections
The Small Wireless Facility may be connected via wireless backhaul services. The volume
and height of any Antenna used for wireless backhaul services is counted toward the
maximum height of the Pole and the volume of the Antennas.
5.2.7 Base-Mounted Equipment
When utilizing the base enclosure design as depicted in Design 2 in Appendix A, the
wireless Facility designer shall choose Poles that are located outside of driveway and
intersection sight lines. The City prefers designs that do not incorporate the base
enclosure, and which utilize existing signs to screen SWF equipment to the maximum
extent possible. Base-mounted equipment:
• Must not exceed a maximum volume of 25 cubic feet, a maximum width of 30
inches, and a maximum height of 48 inches
• Must be painted or screened to be the same color or design of the pre-existing
structure
• May be placed inside the Pole (such as in the base of the Pole) in a way that
integrates with the design of the Pole
5.2.8 Surface-Mounted Equipment
Where permitted at the sole discretion of the City, a surface-mounted cabinet must be the
same color as other nearby pedestals or cabinets. Where there are no other nearby
pedestals or cabinets, the cabinets should be the same color as the Pole housing the
Antenna. The length, width, and depth must each not exceed 5 feet.
5.2.9 Pole-Mounted Equipment
The City prefers the use of stealth design elements, such as shapes and colors that match
surrounding infrastructure and minimize adverse visual impacts. Pole-mounted
equipment:
• Shall use a tapered design, instead of a rectangular box shape
• Must be flush-mounted to the Pole
• Must not exceed a maximum cumulative volume of 9 cubic feet and a maximum
width of 1 foot
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• Must be a minimum of 10 feet above ground level
• Must be on the side of the Pole facing away from the roadway, or screened with
existing street signage, or as directed by the City.
5.2.10 Wooden Utility Poles
Wooden utility poles are a less preferred siting location. Applicants should utilize
existing streetlight Poles to the maximum extent possible. The technical standards of the
utility Pole owner apply. In addition, the City requires the following:
• Riser cables to connect Antennas and Antenna accessory equipment, backhaul
services, and power lines on wooden utility Poles shall be in conduit on the side
of the Pole facing away from the roadway.
• Conduit shall be a neutral color or a color matching the Pole. No riser cable slack
shall be stored externally. All slack shall be stored in junction boxes or equipment
cabinets or on snowshoes on the aerial cable.
• Cabinets are allowed on the side of wooden utility Poles facing away from the
roadway.
5.3 Undergrounding
The Wireless Facility owner shall comply with nondiscriminatory undergrounding
requirements, including City ordinances, zoning regulations, State law, private deed
restrictions, and other public or private restrictions, that prohibit installing above-ground
structures in a Public Right-of-Way without first obtaining zoning or land use approval.
Areas may be designated from time to time by the City as Underground Districts, as
allowed by law. Each Application shall disclose if it is within an area that has
undergrounding requirements.
5.4 RF Exposure
Applicants shall comply with all provisions and guidelines of the FCC’s OET Bulletin 65 10
or its successors, as may be amended from time to time.
10 “Evaluating Compliance with FCC Guidelines for Human Exposure to Radiofrequency Electromagnetic
Fields,” OET Bulletin 65, edition 97-01. https://www.fcc.gov/general/oet-bulletins-line#65
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Upon request the Applicant shall perform RF field tests while the Small Wireless Facility
is in operation, supervised by the City, to demonstrate compliance with FCC OET
Bulletin 65.
5.4.1 RF Signage Requirements
Approved signage compliant with FCC OET Bulletin 65 shall be posted at each Pole or
streetlight Pole hosting a Small Wireless Facility, and/or at multiple locations on such
Poles as required by FCC OET Bulletin 65. The RF signage shall comply with the
appropriate and predetermined exposure level applicable to th e “General Public,”
“Occupational Worker[s],” and “Specialized Worker[s]” as shown in Figure 9 below. All
signage shall be the minimum size permitted by law and made of weather-, corrosion-,
and ultraviolet- (UV) resistant materials.
Figure 9: RF Signage
5.4.2 Emergency RF/ Power Shut-Off
Each approved Small Wireless Facility shall have a clearly marked disconnect switch
located outside areas that exceed RF exposure limits. Once the disconnect switch is placed
in the open position, the electronics equipment related to the installation shall not be
energized. Additionally, no RF transmissions shall be emitted by any Antenna related to
the installation. If the City determines that the Small Wireless Facility is interfering with
public safety communications, the City at its sole discretion may shut it off using the
disconnect switch and notify the owner.
5.4.3 Licensed Frequencies
Antennas shall only transmit or receive frequencies that are licensed by the FCC to the
Applicant or to the carrier the Applicant represents. In the event the Applicant wishes to
add another carrier or change the carrier network using the Wireless Facility, the
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Applicant shall notify the City in writing of the change in carrier and frequencies.
Frequency bands listed by the FCC as unlicensed and available for open use may be
transmitted or received if they do not cause interference with another attaching entity,
FCC-licensed entity, or the City. If the City experiences interference, the Applicant or its
successor shall pay for an expert third-party review and to remediate the interference.
The City reserves the right to remove the Wireless Facility if the interference is not
corrected.
5.5 Lighting and Noise
No lighting is allowed on Wireless Facilities; if there are lights on the supplied equipment,
they must be covered, removed, or deactivated, unless required by the FCC, the FAA, or
the City.
Wireless Facilities must comply with the City’s Noise Ordinance. Applicants are required
to incorporate noise-suppression measures or place equipment in locations where noise
is less likely to impact adjacent residences or businesses to ensure compliance with all
applicable noise regulations. The City reserves the right to require noise-emitting
equipment to be removed or replaced should noise levels be determined to be
unacceptable.
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Appendix A: Standard Pre-Approved Designs
Small Wireless Facilities shall follow one of the following standard designs, which
establish minimum standards, expedite the review process, establish consistency in the
types of Poles, and provide the Applicant with the flexibility of a wide range of
configurations and potential equipment suppliers:
• Design 1 – Streetlight with Pole-mounted equipment
• Design 2 – Streetlight with equipment in base
In addition to following the standard designs, the Small Wireless Facility should adhere
to the Conduit standards as shown in the Conduit Typical.
Typical designs and specifications are provided below.
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Design 1
Figure 10: Standard Design 1 – Streetlight with Pole-mounted Equipment
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Design 2
Figure 11: Standard Design 2 – Streetlight with Equipment in Base
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Figure 12: Conduit Typical Example11
11 In some cases the City may permit connection to power in the light power junction box.
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Appendix B: Application Checklist
Contact Information
Field
Name Description New Replacement Minor
Modifications Colocations Data Type
* Applicant
Name
The entity
representing the
carrier;
typically, the
site acquisition
firm
x x x x Text
* Applicant
Address
The address of
the entity
representing the
carrier;
typically, the
site acquisition
firm
x x x x Text
* Contact
Person
Name
Applicant’s
representative
responsible for
Application
x x x x Text
* Contact
Person
Phone
Applicant's
contact phone
number
x x x x Text
* Contact
Person
Email
Applicant’s
contact email x x x x Text
*Carrier
Name
Name of the
wireless service
provider (WSP)
related to this
Application
x x x x Text
*Carrier
Site Name
Identifier of the
site that the
WSP uses
(common name
or ID)
x x x x Text
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Site Information
Field Name Description New Replacement Minor
Modifications Colocations
*Will the antenna be
installed on an
existing structure?
Yes or No x x x x
If yes, identify type
and Pole number
Type (streetlight or
utility Pole) and
Pole number
x x x x
*Site Address Address of
adjacent property x x x x
* Site Owner/Landlord Per City records x x x x
* Structure Owner x x x x
* Latitude In degree decimal
(xx.xxxxxxx) x x x x
* Longitude In degree decimal
(xx.xxxxxxx) x x x x
*Structure Type
Select the
applicable
structure type
x x x x
* Status of Support
Structure
Existing,
replacement, or
new
x x x x
Does the structure
require an antenna
structure registration
under FCC Title 47
part 17?
Yes or No x x x x
*Zoning Per Cupertino
General Plan x x x x
Proposed height of the
replacement structure
without any antenna
In feet x x
*Justification of why
this site was selected
Describe purpose
of the site, and
why this location is
needed
x x x x
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Field Name Description New Replacement Minor
Modifications Colocations
*Nearby Sites
Provide a listing,
by name and
address, of any
more preferred
existing structures
within a 500-foot
radius (for an
SWF) or within a 1-
mile radius (for
other applications)
from the proposed
site that were
considered in lieu
of the new Support
Structure, along
with a detailed
explanation as to
why these
structures could
not be used to
accommodate the
antennas. If the
alternative
structure(s) were
ruled out for RF or
other engineering
reasons, explain
the reason and
include supporting
RF maps in the
same format
described above
which demonstrate
why the
alternatives could
not be used. If
there were non-RF
reasons why those
alternatives would
not work, provide
an explanation as
to why they could
not be used.
x x
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Field Name Description New Replacement Minor
Modifications Colocations
*Screening
Considerations
State what
considerations
were given to
screening the site
and minimizing
the visual impact
of the proposed
structure,
including any
disguise options
such as a
flag/tree/streetlight
Pole design, low-
profile antenna
attachment
consideration,
concealed/painted
antennas, or other
such designs and,
if not used, why
they were not
used.
x x x
*Will site be used to
support government
Telecommunications
Facilities or other
equipment for
government use?
x x x x
If yes, describe: x x x x
Provide the distance
to the nearest
residential structure
Measured from the
center of the pole
to the nearest
residential
structure (in feet).
x x x
Provide the distance
to the nearest
commercial premises
or school
Measured from the
center of the pole
to the nearest
structure in a
commercial zone
(in feet).
x x x
If a replacement
structure, will the new
structure be installed
at same location as the
original structure?
Yes or No x
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Field Name Description New Replacement Minor
Modifications Colocations
If a replacement
structure, will the new
structure be within 2
feet of the original
structure?
Yes or No x
List adjacent structure
heights In feet x x
*Lease Status
Status of the lease
agreement
permitting the
carrier to operate
at the site.
x x x x
*Has a new or
updated Plan been
filed with the City
within the last year?
x x x x
Is this site on the
Annual Plan?
x x x x
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Installation Type
Field Name Description New Replacement Minor
Modifications Colocations
Application Type
Please select
the Application
type
x x x x
*Insert general
description of work to
be performed to match
all supporting
documents submitted.
x x x x
*Describe area to be
served by the
proposed installation.
Identify the number of
additional carriers the
Facility is capable of
accommodating.
x x
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6409 – Eligible Facilities Request
Field Name Description New Replacement Minor
Modifications Colocations
*Does this qualify as a
6409 Application?
Select whether the
Application should
be treated as a 6409
under FCC ruling.
x x
For Towers outside the
Public Right-of-Way,
will proposed
installation cause an
increase height (i.) more
than 10% or (ii.) the
height of one additional
antenna array with
separation from the
nearest existing antenna
not to exceed 20 feet,
(whichever is greater)?
Yes, No, Not
Applicable (N/A)
x x
For Towers outside the
Public Right-of-Way,
will the proposed
installation increase the
width by adding an
appurtenance to the
body of the Tower that
would protrude from
the edge of the Tower
(i.) more than 20 feet, or
(ii.) more than the width
of the Tower structure
at the level of the
appurtenance
(whichever is greater)?
Yes, No, Not
Applicable (N/A)
x x
Will the proposed
installation increase the
height of the structure
by: (i.) more than 10% or
(ii). more than 10 feet,
whichever is greater?
Yes, No, Not
Applicable (N/A)
x x
Will the proposed
installation increase the
width by adding
appurtenance to the
body of the structure
that would protrude
from the edge of the
Yes, No, Not
Applicable (N/A)
x x
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Field Name Description New Replacement Minor
Modifications Colocations
structure by more than 6
feet?
Will the proposed
installation require
excavation or expansion
outside the current
boundaries of the site?
Yes or No x x
*Does the structure or
current installation have
Concealment
elements/measures?
Yes or No x x
*If yes, describe how the
proposed installation
does not defeat the
existing Concealment.
x x x x
*Will this structure or
proposed installation
have Concealment
elements/measures?
Yes or No x x
*If yes, please describe
the proposed
Concealment
element/measures
x x
Will the proposed
installation require
more than the standard
number of new
equipment cabinets for
the technology
involved, but not to
exceed four cabinets?
Yes or No x x
How many radios will
be removed?
x x x x
How many radios will
be added?
x x x x
How many equipment
cabinets will be added?
x x x x
How many other items
will be added?
x x x x
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Small Wireless Facility (Per FCC)
Field Name Description New Replacement Minor
Modifications Colocations
*Is this installation a
Small Wireless Facility? Yes or No x x x x
Provide the cumulative
volume of the proposed
wireless equipment(s)
exclusive of antennas in
cubic feet
Volume must be
listed in cubic feet
(feet/decimal) to the
nearest 10th.
x x x x
Provide the overall
height of the structure
with antenna
If the structure is to
be replaced, this is
the height with the
antenna. Otherwise
it's the measured
height of existing
structure plus any
antenna.
x x
Provide the cumulative
volume of the proposed
antenna antenna(s)
exclusive of equipment
Volume must be
listed in cubic feet
(feet/decimal) to the
nearest 10th.
x x x x
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Public Right-of-Way
Field Name Description New Replacement Minor
Modifications Colocations
*PROW (Public Right-
of-Way)
Is the site located
within the public
right of way?
x x x x
*Provide the Right-of-
Way width
The Right-of-Way
width is measured at
the centerline of the
structure.
x x x x
*List whose Right-of-
Way the structure is
located on
x x x x
*Attach Right-of-Way
Information
Documents or maps
verifying on whose
Right-of-Way the
structure is located
(i.e. state, City, etc.)
x x x x
Will the proposed Small
Wireless Facility
obstruct, impede, or
hinder the usual travel
or public safety on a
Public Right-of-Way?
x x x x
Will the proposed Small
Wireless Facility
obstruct the legal use of
a Public Right-of-Way
by any public or private
utility providers?
x x x x
Will the proposed Small
Wireless Facility
impede, obstruct,
violate, conflict with, or
hinder any mode of
travel or access to the
Public Right-of-Way, an
alley, or driveway?
x x x x
Will the proposed Small
Wireless Facility
obstruct any access to
any fire escape, fire
hydrant, doors, gates,
stoops, public
transportation vehicles,
shelters, street furniture
or other improvements
x x x X
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Field Name Description New Replacement Minor
Modifications Colocations
at any public
transportation stop
(including, without
limitation, bus stops,
streetcar stops, and bike
share stations)?
Antennas
Field Name Description New Replacement Minor
Modifications Colocations
* Antenna Height AGL
in feet:
Enter center point or
rad center of the
antenna.
x x x x
*Antenna Model: x x x x
* Frequency bands to be
used:
Must be entered in
MHz. List the
beginning/start to
ending/stop of the
operating
frequencies. (Note:
This is less than the
capable frequencies
listed on the antenna
cut sheet.)
x x x x
* Maximum Effective
Radiation (ERP)
Must be in Watts
ERP not EIRP x x x x
*Antenna Dimensions
Must match what is
on the Specification
Sheet provided.
x x x x
*Antenna Volume
Volume must be
listed in cubic feet
(feet/decimal) to the
nearest 10th.
x x x x
* Will the antenna be
located on a rooftop? x x x
If antennas will be
located on a rooftop,
please attach a
description of any steps
that have been or will be
taken to prevent the
aggregate RF from
exceeding exposure
x x x
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68
Field Name Description New Replacement Minor
Modifications Colocations
limits. Include
information regarding
signage, training for
workers accessing
antenna areas, and
precautions against
hazards.
*Type of compliance
study required under
§1.1307 of the FCC
Rules and Regulations:
Cannot select
“categorically
excluded” if it
exceeds the FCC
limits
x x x x
* Will the cumulative
antenna installation be
in compliance with the
maximum permissible
RF exposure limits set
forth in §1.1310 of the
FCC Rules and
Regulations?
x x x x
If the answer is no,
please attach an
explanation
Note: this could be a
certification letter
from the responsible
RF Engineer for
operation at the site.
x x x x
Submittals
Field Name Description New Replacement Minor
Modifications Colocations
*Attach a map of the
general area showing
the location of the site
Map should be
obtained from
System Record. Use
the print to pdf
feature available
from System Record.
x x x x
*Attach manufacturer
specification sheets for
radios, antennas, etc.
Upload the
manufacturer's cut
sheet for all
proposed antennas
and accessories
listed.
x x x x
Attach construction
drawings/pictures
Needs to be 24" x 36
format. Photos
submitted must be
*x *x x *x
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Field Name Description New Replacement Minor
Modifications Colocations
annotated and
clearly show
proposed scope of
work.
*Attach RF propagation
studies showing service
area coverage
surrounding the
proposed site with and
without the site
(Only needed In
cases where the
proposed work is
not at a most
preferred location
and the justification
for the location is
RF-based.) Provide a
copy of the RF
propagation contour
maps showing the
site with and
without the site with
calculated signal
levels in color at the
target signal level
and plus and minus
5dB. Include a
legend that shows
what signal level
each color
represents. Include
maps showing
coverage at the
proposed antenna
elevation and at 20
and 40 feet below the
proposed elevation
for sites outside the
Public Right-of-Way
and 5 feet and 10 feet
below the proposed
height for SWFs.
x x
Attach Capacity
exhaustion justification
(if site is selected to
enhance the Capacity)
(Only needed In
cases where the
proposed work is
not at a most
preferred location
and the justification
for the location is
capacity-based.) The
x x
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70
Field Name Description New Replacement Minor
Modifications Colocations
evidence must
demonstrate that the
Capacity at the
serving site will be
diminished within
18 months of the
Application such
that it will have a
negative impact on
the users within the
area if new Capacity
is not added.
Examples of this
may be time-of-day
download speeds,
utilization over time,
or cumulative key
performance
indicator (KPI)
reports from the
serving site.
Attach drive test
documents
If any drive tests
were performed,
provide copies of the
data with the
Application and
make note that they
are attached.
x x
*Attach property owner
consent form x x x x
*Provide photos and
photo simulations
Provide a
photographic
simulation of the
structure and
equipment from at
least two different
directions. For sites
outside the Public
Right-of-Way,
provide photo from
approximately 1/4
mile away. If SWF,
provide photo that
includes the entire
structure and its
x x
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71
Field Name Description New Replacement Minor
Modifications Colocations
surroundings. If the
new structure is
visible from
adjoining parcel,
include view from
the adjoining
parcels. If a new
structure, please
provide copies of the
photographs with
balloon and the
result with
simulation.
Attach structural
analysis
If a structural
analysis has been
performed, attach
here.
x x x
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72
Appendix C: Site Completion Checklist
Item Requirement YES NO
1
Spacing of Support Elements: Support equipment (e.g. Disconnect
Switch and RRUs) to be clustered (vertically) as close as technically
feasible on Pole.
2
Logo Removal: All equipment logos, other than those required by
regulation (e.g. node identification of shutdown signage) shall be
painted over or removed. Raised/Depressed logos/text on
equipment enclosures (e.g. RRUs), if present to be sanded off, or
covered with a sticker, and then painted.
3
Signage: FCC mandated RF warning signage shall face out to street
when wireless Facility is located in front of, or near a window.
Signage shall face toward building if there are no windows present.
4
Notification: No less than 14 days prior to performing emissions
testing, Applicant shall inform residents of dwelling units within
100 feet and offer to perform a test in their dwelling.
5 Testing: Measure and record emissions, including EMR/RF and
noise.
6 Report: Within 30 days of activation, Applicant will submit an
Activation Report to the Public Works Department.
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73
Appendix D: Process Tasks
Intake Review
Task
Import Application into database.
Note whether the Applicant has indicated that the Application submitted is 6409 or Small
Wireless Facility.
Determine what FCC shot clock this Application falls under.
Check that the address is correct for location listed in Application.
Check that the assessor’s parcel number is correct for location listed.
Check that the address for this location is in the jurisdiction that it was submitted for.
Check that the land and structure owner match what the jurisdiction has on file.
Check that the Lat/ Long are for the location listed in the Application.
Check that the type of structure on the Application matches the structure at the address
provided.
Verify the structure height listed matches all other supporting documents.
Determine if a site visit is needed.
Ensure cutsheets have been submitted for all proposed antennas.
Verify there are no missing required documents such as Area Maps, Structural, Plans, Cut
Sheets, Balloon Test, Photo Sims, Microwave Pathing Studies, RF Maps, Tow Air Check, etc.
Ensure the Applicant has submitted an Annual Plan to the City (described in Section 3.3).
Review whether this site is on the carrier's Annual Plan.
Annotate any discrepancies or missing/incorrect information to pass along to Engineering
Review.
Gather all supporting documents and Application and pass along to Engineering Review
with any comments.
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Engineering Review
Task
Verify that the quantities of removed/added/relocated antennas match on the Application
and all the supporting documents.
Verify that the antennas indicated in the Application are the same antennas (model number
and quantity) indicated in the Plans, structural, and any other supporting documents
accompanying the Application.
Ensure that the height (RAD Center) of the proposed antennas indicated in the Application
are consistent with the antenna height indicated in all supporting documents.
Review scope for consistency and continuity to other supporting documents.
Ensure that the stated value of the height of the structure on the Application matches the
Plans and other Supporting Documents submitted.
Review area map to determine suitable scale, clarity, identification of the site. Ensure that the
area map submitted correctly calls out the location of the structure on the site.
Review the dimensions of the proposed antenna models. Ensure that the dimensions match
the cutsheets submitted.
Review the dimensions of the proposed antenna model.
Review the dimensions of the proposed antenna cabinets/shrouds.
Ensure the Applicant has indicated the particular frequency bands on which the carrier will
be operating (not, for example, the frequencies on which the Applicant’s proposed antennas
are capable of operating).
Review whether the frequency bands listed are relevant to the operational capability of the
antenna model and pertain to the bands in which the carrier is allowed to operate.
Ensure that the ERP indicated in the Application does not exceed FCC limits as outlined in
FCC OET Bulletin 65.
Ensure that the Applicant has checked the appropriate boxes for the Section 1.1307 & 1.1310
questions (i.e., will the antenna installation be in compliance with the maximum permissible
RF exposure limit set forth in Sec 1.1310 of the FCC Rules and Regulation?). Note the steps
taken to determine that the correct compliance study was selected.
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Review whether the Applicant indicated that the installation is in compliance with the
maximum permissible RF exposure limits set forth in FCC Section 1.1310. If not, list what
explanation was included to show that this installation will be in compliance and whether it
is satisfactory.
Review whether this Application is Section 6409 eligible. If not, list reason for non-eligibility.
Review whether an Application for an FAA review been submitted.
Review that the level of drawing details is suitable and customary as compared with the
scope.
Check drawings for setback distances and adjacent parcel owner’s details (when required).
Ensure the antennas and equipment cabinets of any other carriers at the site are identified in
the Plans.
Examine the Structural Analysis accompanying the Application to ensure that all existing
antennas on the Monopole, Tower, or rooftop are properly accounted for in the analysis.
Ensure that the Structural Analysis indicates that the structure is structurally sound and can
accommodate the proposed installation.
Review whether the Applicant stated what considerations were given to screening the site
and minimizing the visual impact of the proposed structure, including any camouflage
options such as a flag/tree/streetlight pole design, low-profile antenna attachment
consideration, concealed/painted antennas, or other such designs and, if not used, why they
were not used. Is the screening method described the best option?
Review RF maps provided by the Applicant to ensure they meet all the following criteria:
Contour maps of the service area illustrating, in color, current coverage with existing sites,
with and without the proposed antennas and with antennas at elevations of 20 feet and 40
feet lower than proposed. Include maps illustrating the calculated coverage from the site
alone and with antennas at those three elevations. Illustrate signal levels in colors
representing the target signal level and at least plus and minus 5 dB. Include a legend
indicating colors and corresponding signal levels. Specify the target levels for the site.
Identify the antenna elevations upon which the model is based. Do they meet all
requirements?
If provided, examine RF maps provided by the Applicant to ensure that, based on the
coverage areas of the carrier’s nearby sites, the proposed structure is justified.
Review whether or not the proposed structure height is needed to provide coverage or
Capacity based on RF Maps.
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If provided, ensure that RF maps are provided showing what the Applicant’s coverage would
be at any nearby structures that potentially could be used for the proposed installation.
Compare RF maps at the proposed site to RF maps showing what the Applicant’s coverage
would be at the nearby structures. (If coverages from any of the nearby structures are
sufficiently close to the coverage that would be provided at the proposed site, then the
Applicant could possibly locate at one of those structures and the proposed structure might
not be necessary.)
List why alternative sites are not viable colocation structures. Has the Applicant provided
adequate evidence that all alternative sites have been ruled out from use?
For proposed microwave (dish) transmissions, ensure that maps are provided showing path
studies from potential structures that could be used as relay stations to send transmissions
from the proposed site to receive sites. (If path studies show that transmissions to receive
sites could be achieved using one or more relay stations, then the proposed structure
might not be necessary.)
Review any included Application photos that depict the installation or proposed site.
Determine if photos are recent, clear, and a suitable level of aspect to support scope.
Ensure that the location of the proposed Monopole and equipment compound, based on the
Plans, is consistent with photos taken of the site by the carrier (i.e., to ensure that the
Applicant will construct the Monopole and equipment compound at the location indicated in
the Plans).
Compile and highlight Engineering/Zoning comments (if further information is needed from
Applicant).
Pass along comments for City Requirement review.
City Requirement Review
Task
Review zoning/engineering comments for local review.
Review that the proposed installation is mindful of possible Colocation opportunities.
Review that the Application offers justification for Colocation due diligence.
Review installation for verification that Pole number/Pole identifier is accurate on all
documents.
Review installation for Small Wireless Facility compliance.
Review installation for 6409 compliance.
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77
Review any documents submitted showing that the property owner has allowed the
Applicant to attach to their structure.
Review all information provided for Right-of-Way.
Review installation for City requirements regarding height of structure.
Review installation for City requirements regarding setbacks.
Review installation for City requirements regarding antenna size.
Review installation for City requirements regarding stealthing.
Determine whether the antenna dimensions listed on the Application match the cut sheet
provided.
Check database for site ID consistencies or duplication of site ID for the same structure.
Check database of previous history of Application to the structure for conflict or duplication.
Check the description of the proposed installation provided. Review scope for consistency
and continuity to other supporting documents. Verify that the quantities of
removed/added/relocated antennas match on the Application and all the supporting
documents.
Make sure that any requirements (such as Plans being signed and sealed by Engineer) have
been fulfilled, and that Application and supporting documents have matching addresses.
Compile all notes from Intake, Engineering, and Local Review and send to Technical Project
Manager to compose a Request for Information if one is needed.
Completeness
Task
Review the Application for the site that will be inspected.
Once on site, verify that the site is as shown on the Plans including location, setbacks, etc.
Verify that the equipment used is the same as on the Application and plans. Verify that the
installation locations are the same as on the Application and plans.
Prepare inspection documentation.