TECHNICAL MEMORANDUM
CUP Summary Analysis
City of Camarillo , C A
To: Michelle Glueckert D’Anna, Assistant to the City Manager Mitchell Cameron, Director of Administrative Services/Chief Innovation Officer From: Matt Steadman, Senior Broadband Consultant and Project Manager Mike Johnson, Senior Broadband Consultant
Will Morat, Senior Manager, Consulting
Date: April 17, 2026
The City of Camarillo (City) engaged ENTRUST Solutions Group (ENTRUST) to evaluate eleven previously approved but unconstructed Conditional Use Permit (CUP) applications for wireless communication facilities in order to better understand the factors influencing wireless infrastructure deployment within the City. As part of this effort, ENTRUST reviewed CUP application records and evaluated those locations in the context of prior wireless field survey data, coverage analysis, and applicable municipal code requirements governing wireless facility siting and design.
The purpose of this assessment was to identify likely causes for non-construction of approved facilities, evaluate whether those sites were positioned to address known coverage and performance limitations, and assess how facility design constraints and regulatory conditions may influence both infrastructure performance and deployment outcomes. This includes consideration of how requirements related to antenna height, concealment, and siting approval processes affect coverage efficiency and the feasibility of network deployment.
This memo describes ENTRUST’s approach, findings, and implications related to wireless infrastructure siting, performance, and policy considerations within the City. It begins with a summary of key findings, followed by a description of the analytical approach, and concludes with an evaluation of how observed outcomes relate to existing conditions and the regulatory framework guiding future wireless siting. Please review this memo and provide any comments, clarifications, or additional information that should be incorporated.
Wireless Field Survey Technical Memo Page 2
ENTRUST Solutions Group April 17, 2026 City of Camarillo, California Key Findings
Wireless carriers prioritize predictable design, cost, and deployment timelines to support consistent and repeatable return on investment.
Wireless carriers evaluate potential deployments within the context of broader capital planning, where predictability in design, construction cost, and deployment timelines plays a critical role in determining investment priority. Standardized facility types and consistent siting conditions allow for more reliable cost estimation and scheduling, supporting a clearer path to return on investment. In contrast, sites that require highly customized designs, involve complex regulatory requirements, or introduce uncertainty in construction timelines may be less competitive relative to other opportunities within a carrier’s network. As a result, even where a technical need exists, projects with greater variability in cost or timing may be deferred or not advanced to construction. Permit approval alone does not ensure construction. The specific conditions of that approval, including design requirements, cost implications, and deployment constraints, ultimately inform whether a site meets a carrier’s investment thresholds.
The interaction between technical constraints, regulatory requirements, and investment considerations ultimately determines network outcomes.
Wireless deployment decisions are shaped by the combined effect of physical limitations, policy- driven design constraints, and return-on-investment thresholds. Facilities that are technically feasible and compliant with code may still fail to improve network performance if they are not configured in a way that maximizes coverage efficiency. Addressing observed performance limitations therefore requires consideration of how these factors interact, rather than focusing on any single component in isolation.
Infrastructure approval does not necessarily translate into infrastructure deployment when technical constraints reduce investment viability.
The pattern of approved but unbuilt CUP applications reflects a disconnect between regulatory approval and practical deployment outcomes. When facility designs are constrained in ways that reduce coverage efficiency, the performance gains associated with those sites may not justify the cost of construction. This dynamic is particularly relevant in an environment where carriers prioritize capital efficiency and targeted investment, leading to situations where approved facilities are not advanced to construction.
Wireless Field Survey Technical Memo Page 3
ENTRUST Solutions Group April 17, 2026 City of Camarillo, California Antenna height and installation configuration are primary determinants of coverage efficiency and overall network performance.
Reductions in antenna height and the use of flush-mounted or concealed installations materially reduce the effective coverage area of individual facilities. These conditions limit signal propagation, particularly in areas with terrain variation or structural obstructions, and require additional infrastructure to maintain coverage continuity. The result is a network that must rely on more sites to achieve the same level of service that fewer, but taller, installations could provide.
Municipal code requirements directly shape facility design in ways that constrain technical performance.
Height limitations, concealment standards, and architectural integration requirements influence how and where wireless infrastructure can be deployed. While these provisions support aesthetic and land use objectives, they also restrict antenna placement, elevation, and orientation. The resulting facilities are often compliant with regulatory standards but operate under conditions that reduce their effectiveness in improving coverage and capacity.
Wireless performance limitations in Camarillo are systemic and occur consistently across carriers, not isolated to any single network.
Observed areas of degraded service appear across AT&T, Verizon, and T-Mobile, particularly along major corridors such as Las Posas Road, the 101 Freeway, and portions of Pleasant Valley Road. This consistency indicates that performance challenges are driven by underlying conditions affecting signal propagation and network behavior rather than carrier-specific deployment gaps. As a result, improvements in service quality are unlikely to be achieved through isolated carrier actions alone.
Wireless Field Survey Technical Memo Page 4
ENTRUST Solutions Group April 17, 2026 City of Camarillo, California
Methodology
ENTRUST conducted a targeted review of previously approved but unconstructed Conditional Use Permit (CUP) applications for wireless communication facilities within the City of Camarillo.
This analysis incorporated three primary sources of information: (i) the ENTRUST Wireless Field Survey Technical Memorandum (dated April 29, 2025), (ii) applicable provisions of the Camarillo Municipal Code, specifically Chapter 19.76 governing wireless communication facilities, and (iii) CUP application materials for eleven (11) wireless facility sites filed or approved between October 25, 2021, and August 5, 2024, as summarized in Table 1.
Table 1 Wireless Site CUP Applications
CUP # Location Carrier Status
420 1040 Avenida Acaso AT&T Approved and Not
Built
426 801 Via Zamora
(Springville Dog Park) AT&T Approved, Not Built &
Expired
413 690 Ventura Blvd
(Outlets) AT&T Approved, Not Built &
Expired
415 528 Freedom Park
Drive (Freedom Park) AT&T Approved and Not
Built
410 2301 East Daily AT&T Built
428 4301 Margarita Rd Dish Deemed Incomplete
since 2/22/2024
416 1030 Temple Avenue
(Kildee Park) Dish Approved and Not
Built
417 5501 Mission Oaks Bl
(Mission Oaks Park) Dish Built
418 2275 Las Posas Dish Approved, Not Built &
Expired
421 690 Ventura Blvd
(Outlets) Dish Approved, Not Built &
Expired
433 1305 Del Norte Rd Verizon Deemed Incomplete
since 9/6/2024
Of the eleven CUP applications reviewed, five were submitted by DISH Wireless. These applications were not included in the detailed analysis, as DISH has since exited its planned deployment activities in the market following the transfer of its wireless assets and spectrum Wireless Field Survey Technical Memo Page 5
ENTRUST Solutions Group April 17, 2026 City of Camarillo, California holdings in 2023.1 As a result, these applications were not considered representative of active deployment conditions or current carrier investment behavior.
The analysis therefore focused on the remaining six (6) applications, consisting of five AT&T sites and one Verizon site. For each of these applications, ENTRUST reviewed site characteristics including proposed antenna height, mounting configuration, and concealment approach, cost to build, and evaluated how these factors relate to expected coverage performance based on established wireless propagation principles.
These site characteristics were then considered in the context of findings from the Wireless Field Survey, including observed signal strength and throughput patterns across the City.2 This allowed for comparison between proposed infrastructure locations and known areas of degraded network performance. In addition, Chapter 19.76 of the Camarillo Municipal Code was reviewed to assess how siting and design requirements may influence facility configuration, coverage efficiency, and overall deployment feasibility.
As part of this effort, ENTRUST also conducted outreach to the site acquisition and engineering firms that submitted the CUP applications on behalf of the wireless carriers. Multiple attempts were made via email and phone to schedule interviews to better understand carrier deployment priorities, site selection criteria, and the factors influencing whether approved sites advance to construction. Of the eleven applications reviewed, two interviews were successfully conducted. 3While limited in number, this discussion provided relevant insight into carrier decision-making processes, including the importance of coverage efficiency, site performance expectations, and the role of design constraints in determining deployment feasibility.
The analysis is intended to provide a practical assessment of how approved facility designs align with real-world coverage needs and whether those configurations would be expected to deliver meaningful improvements in service under typical deployment conditions.
1 DISH Network Corporation combined with EchoStar Corporation in 2023, with DISH continuing as a subsidiary of the combined company. See: https://about.dish.com/2023-08-08-DISH-Network- Corporation-and-EchoStar-Corporation-to-Combine. Subsequently, EchoStar entered into an amended network services agreement with AT&T under which Boost Mobile operates as a hybrid mobile network operator, with primary connectivity provided through AT&T’s network. See:
https://about.att.com/story/2025/echostar.html
2 See ENTRUST’s Wireless Field Survey Technical Memorandum (dated April 29, 2025) 3 Both firms contacted routinely perform similar services on a regular basis for all three major wireless carriers (AT&T, T-Mobile-Verizon) throughout Ventura County and the broader Southern California region.
Wireless Field Survey Technical Memo Page 6
ENTRUST Solutions Group April 17, 2026 City of Camarillo, California Results
TECHNICAL CONSIDERATIONS AFFECTING
WIRELESS PERFORMANCE
Wireless network performance is influenced by a combination of antenna height, mounting configuration, structural integration, and terrain. These factors directly affect how signals propagate and how efficiently infrastructure can deliver coverage and capacity.
Antenna Height, Mounting Configuration and Coverage Area Antenna height is one of the most significant drivers of wireless coverage. Higher antenna placements improve line-of-sight conditions and allow signals to propagate over larger geographic areas with fewer obstructions.
As depicted in Figure 1 reductions in antenna height materially decrease the effective coverage radius of a facility. Because coverage area increases as a function of the square of the radius, even modest reductions in height can result in a disproportionate reduction in the geographic area served. In practical terms, a lower-mounted antenna does not simply reduce coverage incrementally, it can significantly reduce the total service area of a single facility. This relationship becomes particularly important in suburban environments, where coverage continuity depends on the ability of each site to serve a broad area.
Figure 1 Coverage Comparison Mounting Configurations
Wireless Field Survey Technical Memo Page 7
ENTRUST Solutions Group April 17, 2026 City of Camarillo, California Beyond height, antenna mounting configuration affects how effectively a facility can transmit signal. Antennas are designed to operate in open environments with defined directional patterns. Flush-mounted or pole-mounted antenna configurations place antennas closer to structures and often lower on the supporting asset. This limits their exposure and reduces their effective transmission range. These configurations are more susceptible to signal blockage, reflection, and attenuation, particularly at the edge of the coverage area where signal strength is already limited. As a result, flush-mounted installations typically serve smaller areas and require additional supporting infrastructure to maintain consistent coverage.
Co-Location Efficiency vs. Distributed Deployment
Efficient co-location allows multiple carriers to operate from a single, taller structure, maximizing coverage while minimizing the number of sites required. As shown in Figure 8, a taller monopole supporting multiple carriers can serve a broader geographic area compared to multiple lower- height installations distributed across rooftops or smaller structures. When height and configuration constraints limit co-location opportunities, networks shift toward more distributed deployments. This results in a more fragmented network footprint, where each site contributes a smaller coverage area and additional sites are required to fill resulting gaps as shown in Figure
2. Figure 2 Coverage Comparisons Efficient Colocation vs Reduced Height
Wireless Field Survey Technical Memo Page 8
ENTRUST Solutions Group April 17, 2026 City of Camarillo, California Terrain and Environmental Factors
Terrain and surrounding development in Camarillo introduce significant constraints on signal propagation that go beyond typical suburban conditions. The City is located within Pleasant Valley and is bordered by surrounding hills that rise sharply from the valley floor. Elevation within Camarillo is approximately 150–180 feet above sea level, while nearby ridgelines such as the Camarillo Hills rise to approximately 875 feet, with broader terrain in the area reaching over 1,700 feet.4
These elevation changes occur over relatively short distances and create line-of-sight obstructions that can block or attenuate wireless signals, particularly where antennas are deployed at lower elevations. Signals originating from facilities located within the valley must traverse rising terrain, which reduces effective propagation distance and creates shadowing effects in hillside and transitional areas.
Vegetation and structural clutter further influence signal propagation within these conditions.
Mature trees and dense foliage can attenuate and scatter radio frequency signals, particularly at higher-frequency bands, reducing signal strength and limiting effective coverage distance. While Camarillo does not contain a significant concentration of high-rise structures, the presence of low- to mid-rise buildings, residential development, and tree-lined corridors introduces additional obstructions that can weaken signals and contribute to localized variability in coverage.
These environmental effects are amplified when antenna height is constrained. Lower-height installations are less able to clear both terrain and surrounding obstructions, requiring signals to propagate through or around these features rather than over them. In combination, terrain, vegetation, and structural clutter reduce coverage efficiency and contribute to the degraded performance patterns.
System-Level Effects and Network Efficiency
These technical factors do not operate independently. Reduced antenna height, constrained mounting configurations, and terrain limitations combine to influence overall network performance.
As illustrated in Figure 3, these constraints can create a reinforcing cycle in which each facility serves a smaller geographic area, requiring additional infrastructure to maintain coverage.
When those additional facilities are subject to the same constraints, the network becomes increasingly inefficient, with diminishing returns in performance improvement relative to the number of sites deployed.
4 Camarillo topographic elevation range and terrain variation (USGS-based mapping), https://en-us.topographic-map.com/map-wkbm2/Camarillo/
Wireless Field Survey Technical Memo Page 9
ENTRUST Solutions Group April 17, 2026 City of Camarillo, California
Figure 3 Cycle of Wireless Deployment Inefficiency
These system-level effects provide a framework for understanding why additional infrastructure does not always translate into proportional improvements in network performance.
MUNICIPAL CODE AND SITING CONSTRAINTS
The technical limitations described earlier are not occurring in isolation, they are directly shaped by the requirements established in Chapter 19.76 of the City’s municipal code. While the stated purpose of the code is to allow wireless service while minimizing aesthetic impacts and encouraging efficient siting, the specific implementation of these requirements introduces constraints that materially influence how wireless infrastructure can be deployed.
The Conditional Use Permit (CUP) analysis prepared for this effort does not include a formal Federal Aviation Administration (FAA) obstruction evaluation, as FAA determinations are conducted on a site-specific basis through the FAA’s Obstruction Evaluation/Airport Airspace Analysis (OE/AAA) system and cannot be generalized at the planning level. Each proposed structure is independently reviewed based on its exact location, elevation, and height relative to surrounding airspace and nearby aviation facilities, including proximity to Camarillo Airport. For planning purposes, structures at or above 200 feet above ground level (AGL) are typically subject to FAA notification and marking and lighting requirements, while structures below 200 feet AGL may still be subject to review if they penetrate protected airspace surfaces, particularly within airport approach and departure corridors.
Wireless Field Survey Technical Memo Page 10
ENTRUST Solutions Group April 17, 2026 City of Camarillo, California Height Limitations and Technical Justification Requirements The code limits facility height to the maximum allowable building height within each zoning district unless the applicant can provide a technical study demonstrating the need for additional height. In practice, this creates a structural bias toward lower-height installations. While the code allows exceptions, the burden of proof placed on applicants to justify additional height introduces uncertainty and risk into the approval process. As a result, applicants often design facilities to remain within default height limits rather than pursue taller installations that would require additional justification.
As described in Figure 1 reductions in antenna height directly reduce coverage radius and overall service area. The code does not prohibit taller structures, but the requirement to justify height creates a condition where lower-height designs become the default outcome. This results in facilities that are technically compliant but less efficient from a network performance perspective.
Concealment and Architectural Integration Requirements
The code requires wireless facilities to be architecturally integrated into existing structures and to be screened from public view, with a preference for stealth or camouflaged installations.
This requirement directly drives the use of concealed installations such as rooftop enclosures, cupolas, stealth trees, and flush-mounted antennas. While these approaches reduce visual impact, they introduce physical constraints on antenna placement, orientation, and exposure.
As shown in Figure 4, antennas are often placed within or behind structural elements, rather than mounted externally at optimal positions. This limits the ability to align antennas for maximum coverage and reduces signal efficiency due to absorption and obstruction from surrounding materials.
Wireless Field Survey Technical Memo Page 11
ENTRUST Solutions Group April 17, 2026 City of Camarillo, California
Figure 4 CUP # 410 2301 E. Daily Drive
The requirement to “match the proportion, style, and design of the building” effectively prioritizes visual conformity over optimal antenna placement. The result is a class of installations that meet aesthetic objectives but operate under constrained technical conditions.
Facility Type Restrictions and Prohibition of Observable Facilities The code prohibits “observable” wireless facilities and permits only stealth or camouflaged installations across most zones. This provision has a significant practical impact. Traditional macro-cell deployments, which rely on externally mounted antennas at elevated positions, are effectively excluded in many areas. Instead, applicants must rely on building-mounted, pole- mounted, or concealed configurations to meet code.
As discussed, these configurations operate at lower elevations and with constrained mounting conditions. This reduces the effective coverage area of each site and increases the number of facilities required to achieve comparable service levels. The prohibition of observable facilities does not eliminate wireless infrastructure, but it shifts deployment toward configurations that are inherently less efficient from a coverage standpoint.
Wireless Field Survey Technical Memo Page 12
ENTRUST Solutions Group April 17, 2026 City of Camarillo, California Residential Siting Limitations
In addition to general zoning provisions, the municipal code establishes explicit limitations on where wireless facilities may be located. Wireless communication facilities are prohibited on properties where the primary use is residential. This restriction removes a significant portion of the City’s land area from consideration for new facility siting, particularly in lower-density areas where coverage gaps are often more likely to occur. As a result, providers must rely more heavily on commercial, industrial, and public right-of-way locations, which may not always align with optimal radio frequency propagation characteristics.
Collocation Preferences and Practical Limitations
The code encourages co-location and prioritizes the use of existing structures where feasible.
While this aligns with industry best practices in principle, the same code simultaneously requires that any co-located equipment maintain the stealth or camouflage characteristics of the host structure. Co-location is most effective when deployed on taller, unconstrained structures.
When applied within a constrained design environment, the performance benefits of collocation are diminished.
“Least Intrusive Means” Standard and Site Selection Outcomes The code requires that each facility be designed as the “least intrusive means” of achieving the applicant’s technical objectives. This standard shifts the focus of site selection from optimal technical performance to minimal visual impact. Applicants must demonstrate that their proposed design is the least visually intrusive option available, even if alternative configurations would provide better coverage or capacity performance.
In practice, this requirement reinforces the use of concealed and lower-profile installations, further limiting the ability to deploy infrastructure optimized for network performance. It also introduces a subjective element into the approval process, where aesthetic considerations can outweigh technical efficiency.
Application and documentation Requirements
The municipal code also requires a detailed and technically intensive application process for new wireless communication facilities. Applicants must submit propagation maps demonstrating existing and proposed coverage, a comprehensive analysis of alternative sites within a one-mile radius, justification for why collocation is not feasible, and documentation of property access rights, along with engineering plans, photo simulations, and multiple technical studies. These requirements support thorough review and informed decision-making but also increase the level of cost and time required to advance a proposed facility through the approval process.
Wireless Field Survey Technical Memo Page 13
ENTRUST Solutions Group April 17, 2026 City of Camarillo, California Implications for Deployment Outcomes
The combined effect of these requirements is reflected in the CUP applications reviewed as part of this analysis. Facilities are consistently designed within a constrained set of parameters, including reduced height, concealed mounting, and integration within existing structures.
These constraints align directly with the technical conditions and performance patterns for all carrier networks found in Camarillo:
• Reduced antenna height limits coverage area
• Concealment requirements constrain antenna performance • Facility type restrictions limit deployment options
• Co-location occurs within constrained configurations
• Site selection prioritizes visual integration over technical optimization As a result, individual facilities may provide limited incremental improvement in network performance, particularly in areas already experiencing degraded service conditions. This helps explain why multiple approved CUP applications did not proceed to construction, as the resulting designs may not have provided sufficient technical benefit relative to the complexity and cost of deployment.
DEPLOYMENT FEASIBILITY AND CARRIER
INVESTMENT CONSIDERATIONS
The technical and regulatory conditions described earlier have direct implications for how wireless carriers evaluate infrastructure investment decisions. Wireless network deployment is not determined solely by engineering need, but by the relationship between expected performance improvements and the cost required to achieve those improvements.
Reductions in antenna height and constraints on mounting configuration reduce the effective coverage area of individual facilities. This has a direct effect on deployment efficiency. When each individual facility serves a smaller geographic area, additional sites are required to achieve comparable coverage. However, those additional sites are subject to the same constraints, resulting in diminishing incremental benefit from each successive deployment. In this context, infrastructure requirements increase while the performance contribution of each individual site declines.
Observed Deployment Outcomes in Camarillo
The implications of this dynamic are reflected in the CUP outcomes observed in Camarillo. Of the eleven approved wireless facilities reviewed, only a small number were ultimately constructed, while the majority were not built or allowed to expire. As documented in the reviewed materials, approved facilities were generally characterized by lower antenna heights, concealment requirements, and constrained mounting configurations, all of which are associated with reduced coverage efficiency.
Wireless Field Survey Technical Memo Page 14
ENTRUST Solutions Group April 17, 2026 City of Camarillo, California Carrier Investment Strategy and Return on Investment
From an investment perspective, these conditions directly affect the predictability and return on infrastructure deployment. Wireless carriers evaluate potential sites based on expected improvements in coverage, capacity, and network performance relative to the cost of construction and operation. When site configurations are constrained in ways that reduce performance gains, the return on investment for those sites becomes less favorable.
This dynamic is particularly relevant in the current industry context, where wireless carriers have shifted from large-scale network expansion toward more targeted, efficiency-driven investment strategies. As capital expenditures decline following initial 5G deployment phases, carriers are increasingly prioritizing projects that provide the greatest performance benefit relative to cost.
Under these conditions, sites that require higher cost to construct while delivering reduced coverage or capacity improvements may be less likely to advance to construction, even after receiving regulatory approval (see Table 2). This helps explain the observed pattern in Camarillo, where approved facilities are not consistently built, and where infrastructure deployment does not fully align with areas of observed performance degradation.
Table 2 CUP Site Characteristics
CUP
Number Carrier Built Height
in Ft. Type Zoning
District
Network
Sites in
area5
Network
Capacity
in Area
Cost to
Build
410 AT&T Yes 48 Rooftop
Extension PO 0.40 Very
High
Very
High
413 AT&T No 44 Rooftop
Extension CPD 0.25 Below
Average
Very
High
415 AT&T No 80 Flush
mount pole R-E 0.10 Above
Average Average
420 AT&T No 42 Clock
Tower M-1 0.20 Average Very
High
426 AT&T No 40 Stealth Tree R-E 0.05 Average High
433 Verizon No 42 Concealed
Rooftop CPD 0.90 Low High
5 Distance in miles to nearest Cell Site Location
Wireless Field Survey Technical Memo Page 15
ENTRUST Solutions Group April 17, 2026 City of Camarillo, California Site-Level Constraints and Network-Level Considerations In addition to technical and regulatory considerations, site-specific factors such as property access, lease terms, and landlord negotiations can also influence whether an approved facility advances to construction. Wireless facilities are typically deployed on privately owned properties, and the ability to secure and maintain site access on commercially reasonable terms is a key component of deployment feasibility. In some cases, lease costs, restrictive property conditions, or delays in reaching agreement with property owners may reduce the viability of a site, even where technical need and regulatory approval are present. These factors introduce an additional layer of variability into deployment outcomes that is not directly reflected in the CUP approval process.
From a network planning perspective, wireless network deployment is evaluated at a system level rather than on a site-by-site basis. In some cases, coverage gaps identified at the time of a CUP application may be partially or fully addressed by other infrastructure deployed in the surrounding area, including nearby sites constructed by the same carrier or adjacent network upgrades. As a result, the relative priority or necessity of a previously approved site may change over time as network conditions evolve. This dynamic can reduce the need to advance certain approved facilities to construction, even where an initial coverage objective was identified.
Wireless Capital Investment Trends
Wireless carrier investment patterns provide additional context for the observed deployment outcomes. Following a period of elevated capital expenditure associated with initial 5G deployment, major carriers have shifted toward more targeted and efficiency-driven investment strategies. Public disclosures from carriers, such as Verizon and AT&T, indicate a transition away from peak deployment spending toward more selective infrastructure investment focused on performance and return on capital.6 7
This shift in investment strategy aligns with stakeholder input gathered as part of this analysis.
Discussions with industry representatives involved in site acquisition and deployment indicate that carriers are placing greater emphasis on deployment efficiency, site performance, and return on investment when evaluating new infrastructure.
6 Verizon Communications Inc., Annual Reports
https://www.verizon.com/about/investors/annual-reports
7 AT&T Inc., Annual Reports
https://investors.att.com/financial-reports/annual-reports
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ENTRUST Solutions Group April 17, 2026 City of Camarillo, California
NETWORK PERFORMANCE SUMMARY
AT&T
AT&T’s network in Camarillo provides relatively consistent performance across both speed and reliability, with fewer instances of severe degradation compared to other carriers. As shown in Figure 5,8 weaker performance (designated most severely in gray), is concentrated north of Las Posas Road, including the Spanish Hills area and along Crestview Avenue, with additional gaps observed along portions of Las Posas Road and near the Camarillo Premium Outlets. These locations reflect persistent coverage limitations where both signal strength and data performance are reduced.
AT&T’s 5G network provides broad coverage with generally stable performance where available; however, in weaker coverage areas, devices transition to LTE, resulting in reduced speeds and more variable performance. Overall, service remains dependable in well-covered areas but becomes less consistent in identified gap and transition zones.
Figure 5 - AT&T Signal Strength – RSRP9
8 Signal levels approaching -116 dBm represent conditions where connectivity is unstable or effectively unavailable. At these levels, connections, if present, are unreliable, with frequent call drops, failed messaging, and severely limited or non-functional data performance. Devices may revert to legacy network technologies or lose service entirely
9 RSRP (Reference Signal Received Power) is a standardized wireless signal strength metric originally defined for LTE networks and also used in 5G New Radio (NR) systems to measure the average power level received from a cell’s reference signals, expressed in decibels relative to one milliwatt (dBm), and used to evaluate coverage quality and network performance.
Wireless Field Survey Technical Memo Page 17
ENTRUST Solutions Group April 17, 2026 City of Camarillo, California As shown in Figure 6, clusters of low-throughput observations (<2 Mbps) occur along key corridors including Las Posas Road, the 101 Freeway, and portions of Pleasant Valley Road.
Across the study area, a total of 247 instances of throughput below 2 Mbps were recorded, despite the presence of approximately 21 existing AT&T tower sites within the City.10 These clusters represent locations where users consistently experience degraded performance.
Additionally, these conditions are observed both in proximity to existing tower infrastructure and in areas with fewer nearby facilities, indicating that performance limitations are not limited to areas lacking coverage.
When considered alongside signal strength conditions, the distribution of low-throughput observations can be further differentiated. Areas exhibiting both low signal strength (generally below -100 dBm) and low throughput are indicative of coverage limitations, where distance, terrain, or antenna configuration reduce the ability of the device to maintain a reliable connection. In contrast, areas where signal strength remains moderate to strong, but throughput is degraded suggest localized capacity constraints or network loading conditions.11 12 The review of approved AT&T CUP applications indicates that only one of the five analyzed sites was ultimately constructed, while the remaining four did not advance despite receiving approval, as summarized in Table 2. Comparison of these sites with observed performance conditions indicates a mixed relationship between proposed infrastructure and areas of degraded service.
Several proposed sites are located near identified performance degradation areas and could contribute to improved service if constructed. However, in locations where degraded performance occurs despite proximity to existing infrastructure, additional sites may provide limited benefit unless they materially improve network configuration, such as antenna elevation or placement, as described earlier in this memo. Taken together, these observations indicate that AT&T performance limitations in Camarillo are driven by a combination of coverage and capacity conditions, and that the effectiveness of proposed infrastructure depends on how well site placement and configuration align with these underlying factors.
10 Data Provided by City of Camarillo.
11 Moderate to strong signal strength is generally defined as Reference Signal Received Power (RSRP) values above approximately -100 dBm, with strong signal conditions typically exceeding -90 dBm and very strong conditions above -80 dBm.
12 Throughput performance is measured directly during wireless drive testing through active data sessions, capturing both downlink and uplink speeds in Mbps. For purposes of this analysis, low - throughput conditions are defined as instances where observed speeds fall below 2 Mbps for either download or upload, indicating degraded user experience and potential network performance limitations. For additional details about network throughput results reference ENTRUST Wireless Field Survey Technical Memorandum (dated April 29, 2025).
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ENTRUST Solutions Group April 17, 2026 City of Camarillo, California
Figure 6 AT&T Tower Locations and Download Speed Drops
Verizon
Verizon’s network in Camarillo is characterized by consistent LTE-based performance, with no measurable 5G presence observed during testing. As shown in Figure 7,13 areas of reduced performance are distributed across the City, with more noticeable degradation along Las Posas Road, near the Springville exit along the 101 Freeway, and in hillside areas around Crestview Avenue, as well as portions of Pleasant Valley Road and the eastern edge of the City. These locations reflect areas where both signal strength and data performance are reduced.
Because Verizon operates without observable 5G service in the study area, all user experience is dependent on LTE performance. While LTE provides a relatively stable baseline for connectivity, overall performance is more limited compared to networks operating across both 5G and LTE, resulting in lower average speeds and reduced capacity for higher-demand applications.
As shown in Figure 8, clusters of low-throughput observations (<2 Mbps) are distributed throughout the City, including along major corridors such as Las Posas Road, the 101 Freeway, and Pleasant Valley Road. Across the study area, a total of 532 instances of throughput below 2
13 All recorded Verizon samples were identified as LTE, with no measurable 5G signal observed during testing.
Wireless Field Survey Technical Memo Page 19
ENTRUST Solutions Group April 17, 2026 City of Camarillo, California Mbps were recorded, despite the presence of approximately 10 existing Verizon tower sites within the City. These clusters represent locations where users consistently experience degraded performance. These low-throughput conditions occur both in proximity to existing tower infrastructure and in areas with fewer nearby facilities, indicating that performance limitations are not limited to areas lacking coverage.
When considered alongside signal strength conditions, as shown in Figure 6, the distribution of low-throughput observations can be further differentiated. Areas exhibiting both low signal strength (generally below -100 dBm) and low throughput are indicative of coverage limitations, where distance, terrain, or antenna configuration reduce the ability of the device to maintain a reliable connection. In contrast, areas where signal strength remains moderate to strong, but throughput is degraded, suggest localized capacity constraints or network loading conditions.
The review of approved Verizon CUP applications identified one site (1305 Del Norte Road), as summarized in Table 2. This site is configured at approximately 42 feet and is located within a commercial zoning district (CPD), with relatively close proximity to existing infrastructure.
Comparison of this site with observed performance conditions indicates that while it is located near areas of degraded performance, the surrounding network conditions suggest a combination of coverage and capacity influences. As a result, the potential effectiveness of this site (if built), in resolving observed performance limitations, depends on how it would interact with existing infrastructure and whether it would provide meaningful improvement in network configuration.
Overall, Verizon’s performance profile in Camarillo reflects a network that is broadly available but constrained in its ability to deliver higher levels of performance, particularly in areas with elevated demand or more challenging coverage conditions.
Figure 7 - Verizon Signal Strength - RSRP
Wireless Field Survey Technical Memo Page 20
ENTRUST Solutions Group April 17, 2026 City of Camarillo, California Unlike its competitors, Verizon’s test results showed all recorded data as 4G, suggesting that its network is still operating on a 4G LTE core rather than fully utilizing 5G SA. This may limit future speed improvements and advanced 5G capabilities, such as network slicing and ultra-low latency applications. While Verizon maintained steadier speeds than T-Mobile, it still recorded instances of throughput dropping below 2 Mbps, as seen in Figure 8 (530 recorded instances compared to 591 for T-Mobile and 240 for AT&T), indicating potential network strain or capacity constraints in certain areas.
Figure 8 Verizon Tower Locations and Download Speed Drops T Mobile
T-Mobile’s network in Camarillo delivers the highest overall data speeds among the carriers, driven by strong mid-band 5G performance. As shown in Figure 9,14 signal strength conditions vary across the City, with weaker coverage observed along Pleasant Valley Road, near freeway interchanges along the 101, and in areas around the Camarillo Premium Outlets and Town Center extending toward Lewis Road. Additional variability is observed along Las Posas Road, particularly near its intersection with Lewis Road. In contrast, fewer weak signal areas are observed north of Las Posas Road in the residential neighborhoods around Spanish Hills and Camarillo Hills.
14 Signal levels approaching -116 dBm represent conditions where connectivity is unstable or effectively unavailable. At these levels, connections, if present, are unreliable, with frequent call drops, failed messaging, and severely limited or non-functional data performance. Devices may revert to legacy network technologies or lose service entirely.
Wireless Field Survey Technical Memo Page 21
ENTRUST Solutions Group April 17, 2026 City of Camarillo, California
Figure 9 T Mobile Signal Strength - RSRP
T-Mobile’s 5G network provides high peak performance in areas with strong signal conditions; however, overall signal quality is more variable, with a significant portion of coverage classified as average.15 This results in a user experience that can be very fast under optimal conditions but less consistent in areas with obstructions, indoor environments, or transitions between coverage zones.
As shown in Figure 10, clusters of low-throughput observations (<2 Mbps) are distributed throughout the City, particularly along Pleasant Valley Road, freeway interchanges, and portions of Las Posas Road. Across the City, a total of 591 instances of throughput below 2 Mbps were recorded, representing the highest number among the three carriers. These clusters indicate areas where performance degrades more noticeably under certain conditions.
15 Average signal strength is generally defined as Reference Signal Received Power (RSRP) values between approximately -99 dBm and -90 dBm, representing moderate coverage conditions that are typically usable but may not consistently support optimal data performance.
Wireless Field Survey Technical Memo Page 22
ENTRUST Solutions Group April 17, 2026 City of Camarillo, California
Figure 10 T Mobile Tower Locations and Download Speed Drops When considered alongside signal strength conditions, the distribution of low-throughput observations reflects a combination of coverage and capacity influences. Areas with both low signal strength and low throughput are indicative of coverage limitations, while areas where signal remains moderate, but throughput degrades suggest localized congestion or network loading conditions. The variability observed across these conditions contributes to a less predictable performance profile compared to other carriers.
No approved CUP applications associated with T-Mobile facilities were identified as part of this review. As a result, no site-specific analysis could be performed to evaluate the potential impact of new T-Mobile infrastructure on observed network performance conditions. Overall, T-Mobile’s network in Camarillo is characterized by high peak performance combined with greater variability, where strong performance in optimal conditions is offset by more frequent fluctuations in signal quality and throughput across the network.