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limit the ability to improve and enhance existing service, and limit the ability to introduce new services.” Id. at p. 18. The City’s consultant, CTC Telecommunications, agreed, writing “[b]ased on our review of the more detailed and updated data and analysis provided by PierCon in its reports, the Golden Bough Playhouse would not effectively address the coverage gap and other service deficiencies.” See CTC Telecommunications Review of the Application of Verizon Wireless to Install a New Small Wireless Facility, January 2026, p. 20.

To address questions from the Planning Commission at its January 21, 2026, hearing, PierCon Solutions prepared additional reports. PierCon Solutions modeled various configurations and found that “[t]he only configuration that produced marginally acceptable modeled results” required a score of conditions simultaneously. PierCon Solutions Radio Frequency Supplemental Report #2, January 30, 2026, attached as Exhibit J, at pp. 6-7. These conditions include requiring a six-foot tall antenna (the “Macro Design”) and narrow horizontal beamwidth antennas. Id. Even then, PierCon Solutions found:

When accounting for antenna height limitations, proximity to existing Verizon sites, excessive overlap, and substantial tree-induced signal attenuation, the Golden Bough location cannot provide dominant mid-band coverage to the Service Area Gap and therefore does not represent a feasible or equivalent RF alternative to the Proposed Site.

Id. at p. 7. PierCon then evaluated the signal blockage by nearby trees, determining that “[f]ield verification demonstrates that rooftop siting conditions materially constrain the ability to achieve reliable, localized small cell coverage within the defined service area.” See PierCon Solutions Radio Frequency Supplemental Report #3, February 9, 2026, attached as Exhibit K, at p. 5. Additionally, Verizon Wireless further explained that PreVisualists, Inc., flew a drone at the proposed antenna location and elevation to evaluate if there is clean line of sight from the antenna location to the coverage area.

Verizon Wireless Responses to Comments, Vol. 2, February 6, 2026 (“Verizon Responses Vol. 2”), attached as Exhibit L, at pp. 2-3, 5. The drone photo, which shows the vantage point from the Golden Bough roof facing the coverage objective, demonstrates that there is substantial tree cover between the Golden Bough and the targeted area. These trees would obstruct the signal from the antenna, irrespective of the antenna type, preventing it from serving the coverage area. Id.

There is no substantial evidence in the record to support a conclusion that the Golden Bough is a technically feasible alternative that will meet Verizon Wireless’s network needs and fill the gap. Substantial evidence means “such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” MetroPCS v. City & County of San Francisco, 400 F.3d 715, 723, 725 (9th Cir. 2005), abrogated on other grounds, T Mobile South, LLC v. City of Roswell, 574 U.S. 293 (2015). To meet the substantial evidence test, a denial must be “supported by a reasonable amount of evidence (i.e., more than a ‘scintilla’ but not necessarily a preponderance).” Id. at 725.

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Here, the opponents offered only lay opinion that Verizon Wireless’s expert is wrong, and that they believe that the Golden Bough location would work, without any evidentiary support. The Planning Commission pulls one sentence from a PierCon Report out of context as evidence that the Golden Bough is a viable alternative.

However, they omit PierCon’s final paragraph, which states that “the modeled performance at this location does not reliably translate to real-world conditions” so the Golden Bough “cannot provide dominant mid-band coverage to the Service Area Gap and therefore does not represent a feasible or equivalent RF alternative to the Proposed Site” even using the Macro Design. Exh. J, p. 7.

Therefore, neither the opponents nor the Planning Commission provided substantial evidence to contradict PierCon’s conclusions, which were upheld by the City’s consultant, CTC Telecommunications. See CTC Telecommunications Review of the Application of Verizon Wireless to Install a New Small Wireless Facility, January 2026, p. 20.

PierCon Solutions then prepared an additional report, performing additional technical evaluations, including maximum allowable path loss, comparative AWS path loss modeling, evaluation of antenna constraints, line-of-sight profile and free-space propagation analysis, and assessment of downtilt tradeoffs. PierCon Solutions Radio Frequency Supplemental Report #4, February 9, 2026, at p. 4, attached as Exhibit O. The report yet again confirmed that the Golden Bough “does not represent a technically feasible alternative for achieving the documented service objectives under consistent engineering criteria.” Id. PierCon Solutions included the parameters of their analysis so that it can be duplicated and analyzed by the City’s expert consultant, CTC Telecommunications. Id. at p. 25.

2. The Golden Bough Is Likely Not Available.

Even if the Golden Bough were a technically feasible alternative, which it is not, it is not clear that it is available. Verizon Wireless has had several conversations, in good faith, with the director of the theater and visited the site to determine whether it is constructable. Exh. L – Verizon Responses Vol. 2 at p. 2. While there may be room on the roof for a wireless facility, there are numerous constraints limiting the locations on the roof where a wireless facility could be placed. Verizon Wireless Responses to Comments, Vol. 3, February 24, 2026 (“Verizon Responses Vol. 3”), attached as Exhibit M, at pp. 1-3. These limitations include existing solar panels on the roof, which the Golden Bough intends to expand. Solar panels cause interference with wireless signals (passive intermodulation), causing network disruption. The wireless facility must also be placed in a location that does not interfere with theater activity. Id. The director requested that any wireless facility be located on the north edge of the building, which would require that the wireless facility be 18 feet above the roof to obtain the same antenna elevation as the highest point on the west of the roof. Id.

Further, it not clear that the theater would even approve a lease with Verizon Wireless. The theater representative has already expressed concerns regarding ATTACHMENT 8

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interference from the wireless facility on theater equipment and operations. Exh. M – Verizon Responses Vol. 3 at p. 3. Additionally, one of the Pacific Repertory Theatre1 Board of Directors officers, Karyl Hall,2
opposed the Proposed Small Cell before the
Planning Commission. See January 21 Staff Report, Attachment 11, Resident Correspondence, p. 16.

3. The Golden Bough Is More Intrusive than the Proposed Small Cell.

The Golden Bough is not a superior alternative to the Proposed Small Cell, as it would require a height exception and result in potential impacts to historic resources, with potentially more aesthetic impacts due to required tree trimming.

First, Verizon Wireless would need an exception to allow for a height increase above the 34 feet allowed by the Code, described above. In addition, the Golden Bough is listed on the Carmel Inventory of Historic Resources as a Criteria 1 facility, the highest historic designation. Exh. M – Verizon Responses Vol. 3 at pp. 3-4. Any alterations would be subject to historic impact review not required for the Proposed Small Cell.

Placing a wireless facility on the Golden Bough would require review under the City’s Historic Preservation code, as well as review and consultation with the California State Historic Preservation Officer. Id. The Proposed Small Cell is adjacent to a home listed as Criteria 3 on the City’s historic inventory, a much lower designation. Id.

Additionally, neither the proposed pole nor the right-of-way is historic. Id.

Consequently, the Golden Bough is much more intrusive than the Proposed Small Cell with respect to potential impacts to historic resources.

Furthermore, as demonstrated by the drone picture, the volume of tree trimming, if even possible, would surpass that of the Proposed Small Cell. Exh. L – Verizon Responses Vol. 2 at p. 5. Consequently, even if it were technically feasible and available, it is more intrusive than the Proposed Small Cell.

4. The City’s Preference for Private Property is Preempted by Both Federal and State Law.

Forcing a telephone corporation to relocate a proposed small cell to private property would require a lease, ongoing rental payments, and restrictive terms not required for the right-of-way. That would increase the costs of deployment, inappropriately involve private landowners in the site selection process and operation of a facility, and delay installation. Construction costs for a wireless facility on the Golden Bough would be at least three to four times those of the Proposed Small Cell. Exh. M – Verizon Responses Vol. 3 at p. 3. Rent would be orders of magnitude higher and maintenance costs would also be higher. Id. The additional expense, burdens, and delay of forcing a telecommunication company to lease private property would “materially inhibit” service improvements in violation of the Telecommunications Act. See also T1 The Pacific Repertory Theatre operates the Golden Bough. 2 Board of Directors information available at: https://www.pacrep.org/board-of-directors ATTACHMENT 8

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Mobile v. Anacortes, supra, 572 F.3d 987, 998 (finding that “the environmental impact and additional costs” associated with the city’s proposed two-site alternative did not defeat T–Mobile’s showing that its site was the least intrusive means”). In contrast, Verizon Wireless can attach its equipment to utility poles in the right-of-way as a member of the Northern California Joint Pole Association, with low deployment costs and an established, expedited approval process.

Federal law also bars the City from redirecting the Proposed Small Cell to a building on private property where a different wireless technology may be required, a macro facility instead of a small cell. PierCon determined that a different antenna configuration would be required at the Golden Bough, with two narrow beamwidth antennas at two azimuths, but that factors including low height and nearby tree attenuation still render it to be an infeasible alternative. Exh. J – January 30 PierCon Report at pp. 6-7.

Even if a macro facility were viable, the FCC has exclusive jurisdiction over the technical and operational aspects of wireless networks, so the City cannot directly or effectively dictate the technology that wireless carriers use to provide service. See New York SMSA Ltd. Partnership v. Town of Clarkstown, 612 F.3d 97, 105-106 (2nd Cir. 2010). Accordingly, the City is preempted from requiring certain technologies at the Golden Bough or any wireless facility, such as the high-gain directional antennas suggested by opponents’ counsel Andrew Campanelli, who is not an engineer.

Further, denial due to a preference for private property would directly violate state law by depriving Verizon Wireless of its right to place equipment along any public rightof-way. Pub. Util. Code § 7901.

Because the Golden Bough is an infeasible alternative, and because the preference for private property is preempted by both federal and state law, this ground for denial must be rejected.

B. The Proposed Small Cell Is Consistent with the General Plan.

The Commission vaguely claimed that the General Plan prioritizes community character over infrastructure when alternatives exist, without citing any General Plan goal, objective, or policy. That baseless claim cannot serve as substantial evidence for denial, and it assumes that community character and infrastructure are in conflict.

However, the two are compatible, as confirmed by the City Council’s adoption of a new wireless code in 2023, which it found would “[c]omply with all applicable goals, objectives and policies of the General Plan.” See Ordinance 2023-006; Code §

17.46.010(B)(4)(a).

The General Plan is silent on the topic of wireless facilities but notes the community benefit of “improved communications infrastructure.” General Plan Land Use & Community Character Element, p. 1-25. The only General Plan provision specifically requiring comparison of alternatives is Policy P1-104, which prohibits ATTACHMENT 8

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changes to historic resources inconsistent with the Secretary of the Interior’s Standards unless there are no feasible alternatives that are consistent. Id. at p. 1-48. That provision is irrelevant because the Proposed Small Cell is not on a historic resource, as discussed below. Lacking any evidence of non-compliance with the General Plan, this ground for denial must be dismissed.

C. The Special Exceptions Are Justified.

The Commission confirmed that only two special exceptions are required but provided no explanation for denying them other than “zoning non-compliance” and “Golden Bough Theater is viable less-intrusive alternative.” As described above, Verizon Wireless provided an exception request letter and supporting evidence. Exhs. E, F, and G. Independent expert PierCon confirmed that the Golden Bough is in fact infeasible, and the City has not provided substantial evidence to contest that conclusion.

Accordingly, Verizon Wireless has justified the two special exceptions. This ground for denial must be rejected.

D. Speculation About Future Applications Is Beyond the Scope of this Small Cell Application, Which Must Be Evaluated on Its Own Merits.

Citing one of the general use permit findings, the Commission worried that approval of the Proposed Small Cell “invites similar future applications” so would set a precedent. Speculative concern over future circumstances is not substantial evidence that warrants denial of the present application. Even if there were a future application, it would be subject to the City’s exhaustive review process and additional standards such as the required 500-foot separation of wireless facilities in the right-of-way. Code §

17.46.040(E)(2)(b). To the extent the Commission was concerned about additional wireless equipment on the proposed pole, the Code considers eligible facilities requests as Type V sites. Code § 17.46.020(A)(28). Type V sites require both an administrative use permit and a building permit. Code § 17.46.050(A)(2)(a). Administrative use permits are reviewed by the planning director and appealable to the City Council. Code §

17.46.050(A)(2). Consequently, the City will thoroughly review any future applications for wireless facilities on this pole. It is also unlikely that another carrier would propose equipment for this pole because PG&E and the CPUC both have strict regulations governing wireless facilities on this pole.

Denial of any wireless facility in the R-1 zone based on this ground would constitute an effective prohibition of service, given that the R-1 zone compromises much of the City. It would also violate Section 7901 by excluding wireless facilities from residential rights-of-way. Due to the lack of evidence and the prohibitive effect, this ground for denial must be dismissed.

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E. The Proposed Small Cell Will Comply with Applicable Safety Rules and Regulations.

The Commission alleged non-compliance with the use permit finding regarding health, safety, and welfare due to a “fall zone concern” of a 50-foot structure located 25 feet from a residence. Again, though, the Commission provided no evidence that the Proposed Small Cell or the replacement utility pole would fall. This concern is unwarranted, given that there is presently a 38-foot, 11-inch, 70-plus year-old wooden pole at the location. The structural integrity of the project was confirmed by a registered professional engineer at Allstates Engineering & Surveying, which concluded: “The antenna mounting equipment is adequate for the proposed scope of work and complies with GO95 and ANSI 05. The pole capacity will meet the original pole class requirements after proposed attachment.” See Allstates Engineering & Surveying Structural Analysis Report, p. 1.

PG&E will inspect the utility pole and Proposed Small Cell during and after the installation process. The City will confirm structural adequacy of the pole and equipment through the pending building permit application and subsequent inspections. Lacking substantial evidence, this ground for denial must be rejected.

F. The Proposed Small Cell Will Not Impact the Nearby Tree.

With respect to the nearby tree, the Commission raised concern over root disturbance and encroachment on drip lines. At a February 4, 2026, meeting with City staff, a PG&E arborist confirmed that replacement of the utility pole would not adversely affect the root structure of the tree because the replacement pole will be placed in the same hole as the existing pole. Exh. M – Verizon Responses Vol. 3 at p. 1. The Code’s discouragement of wireless facilities within tree drip lines applies to new poles, not replacement poles. Code § 17.46.040(F)(1)(f). The Commission did not provide evidence that the replacement pole would cause adverse impact to the tree, so this ground for denial must be dismissed.

G. The Proposed Small Cell Will Not Impact Any Historic Resource.

The Proposed Small Cell will be located on a utility pole, which is not a historic resource. The Commission alleged incompatibility with surrounding land uses because the utility pole is near the frontage of a home listed on the Carmel Inventory of Historic Resources. However, that inventory designates the APN of the adjacent private property as the historic resource, whereas the Proposed Small Cell is in the right-of-way, not on private property. Accordingly, the Code does not require review of the Proposed Small Cell by the Historic Resources Board, and in fact, the utility pole is not a “historic resource” as defined. Code §§ 17.46.020(A)(11), 17.46.050(B)(4)(b).

The Commission provided no explanation or evidence as to how placing small equipment components on a utility pole would affect a building 25 feet away. In fact, the Commission conceded that there is no effect. One of the highly incompatible locations in ATTACHMENT 8

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the right-of-way designated by the Code is any location that would trigger review of consistency with the Secretary of the Interior’s standards. Code § 17.46.040(E)(1)(b).

However, the staff reports and the Planning Commission resolution confirmed that only two special exceptions to Code standards are required, and that Code standard is not one of them.

The Secretary of the Interior’s Standards address preservation, rehabilitation, restoration, or reconstruction of a historic property. 36 C.F.R. Part 68. Verizon Wireless is doing none of those. This ground for denial raises an irrelevant subject and must be rejected.

H. The Proposed Small Cell Will Pose Minimal Visual Impact.

The Commission’s denial alleged “visual intrusion,” “adverse visual impacts,” and, with respect to coastal development standards, “inconsistent with highly scenic area designation.” The Commission provided no elaboration or evidence to support those claims. Generalized aesthetic objections do not amount to substantial evidence upon which a local government could deny a wireless facility permit. See City of Rancho Palos Verdes v. Abrams, 101 Cal. App. 4th 367, 381 (2002).

Those vague visual impact claims are unreasonable and prohibitive according to the FCC’s Infrastructure Order, because the Proposed Small Cell is not “out-ofcharacter” compared to the existing utility infrastructure lining Carmelo Street and most other Carmel residential streets.

According to the General Plan, the referenced “highly scenic area” is “the incorporated limits of the City of Carmel-by-the-Sea.” General Plan Land Use & Community Character Element, p. 1-1. By the Commission’s rationale, no new wireless facility could be granted a coastal development permit because the entire City is a “highly scenic area.” This further illustrates the prohibitive effect of the Commission’s vague visual impact claims.

The photosimulations demonstrate the minimal visual impact of the Proposed Small Cell. Exh. C – Photosimulations. The pole-top antenna will not block coastal views of the ocean or the local landscape. Id. Instead, the antenna will be viewed against the sky, like equipment at the top of other utility poles along Carmelo Street, such as the transformer and two crossbars on the pole due north. Verizon Wireless’s equipment shroud will be placed low on the pole, screened by the existing tree, whereas there is an even wider cabinet mounted low on the pole due south with no screening. See photographs of adjacent utility poles, attached as Exhibit N. In responding to opponent claims and photographs purporting to show view impacts, staff noted:

The pictures provided by Strauss do not show any views of hills, homes, ocean, or landmarks obscured or impacted. The baseline condition of these properties is of a view of the existing utility pole. The additional ATTACHMENT 8

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pole height and mounted equipment would not have any consequential view impacts.

February 10 Staff Report at p. 10.

Given the existing utility poles and utility lines along Carmelo Street and other local streets, the Proposed Small Cell will not degrade the local streetscape or block significant views, so it will cause no adverse visual impact. Indeed, in the context of the California Environmental Quality Act (Pub. Res. Code §§ 21000 et seq.) (“CEQA”) and CEQA Guidelines (14 Cal. Code of Regs. §§ 15000–15387), courts have routinely determined that wireless facilities in the public right-of-way generally do not result in significant aesthetic impacts. See, e.g., Aptos Residents Ass’n v. County of Santa Cruz (2018) 20 Cal.App.5th 1039 (10 microcell transmitter units on existing utility poles); Robinson v. City and County of San Francisco (2012) 208 Cal.App.4th 950 (40 wireless equipment cabinets on existing utility poles); San Francisco Beautiful v. City and County of San Francisco (2014) 226 Cal.App.4th 1012 (726 telecommunications cabinets in the public right-of-way).

Verizon Wireless provided evidence confirming that the Proposed Small Cell complies with the specific equipment volume, placement, and height criteria of the Design Standards, which were developed specifically for wireless facilities. Because the Commission provided no substantial evidence of adverse visual impact, this ground for denial must be dismissed.

In sum, the Planning Commission provided no evidence—let alone the substantial evidence required by federal law—to warrant denial of the Proposed Small Cell. In contrast, Verizon Wireless has provided ample evidence supporting approval.

V. Denial Would Constitute an Unlawful Prohibition of Service.

The Telecommunication Act provides that local government regulation of wireless facilities “shall not prohibit or have the effect of prohibiting” the provision of personal wireless service. 47 U.S.C. § 332(c)(7)(B)(i)(II). Under long-established Ninth Circuit case law, a local government’s denial of a wireless facility permit violates the “effective prohibition” clause of the act if a wireless provider can show (1) that it has a “significant gap” in service, and (2) that a facility is the “least intrusive means,” in relation to the land use values embodied in local regulations, to address the gap. See TMobile v. Anacortes, supra, 572 F.3d at 987.

If a provider proves both elements, the local government must approve the facility, even if there is substantial evidence to deny the permit under local regulations (which is not the case here). This is because federal law preempts local regulations when denial of the permit would effectively prohibit the provision of personal wireless services. Id., 572 F.3d at 999. To avoid such preemption, the local government must show that another alternative is available, technologically feasible, and less intrusive than the proposed facility. Id., 572 F.3d at 998-999. For wireless carriers to establish a ATTACHMENT 8

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prohibition case, federal law does not require that a proposed facility be the “only” alternative, but rather that no feasible alternative is less intrusive based on local regulations. See Metro PCS, Inc. v. San Francisco, 400 F.3d at 734-735.

The FCC determined that this two-part test is too narrow and confirmed that a wireless carrier need not show an insurmountable barrier, or even a significant gap, to prove a prohibition of service. Infrastructure Order, 33 FCC Rcd. at 9102-9106, ¶¶ 35,

38. Instead, “a state or local legal requirement constitutes an effective prohibition if it ‘materially limits or inhibits the ability of any competitor or potential competitor to compete in a fair and balanced legal and regulatory environment.’” Id., ¶ 35. Thus, state or local regulations are preempted if they materially inhibit “densifying a wireless network, introducing new services, or otherwise improving service capabilities.” Id. at 9104, ¶ 37.

In this case, denial would not survive judicial review under either standard. First, denial would violate the two-part test for a prohibition of service claim. The PierCon Solutions reports provide evidence of a significant gap in Verizon Wireless service in western Carmel. The Alternatives Analysis evaluated other zones preferred by the Code as well as 28 utility poles, and it confirms that the Proposed Small Cell is the least intrusive feasible option in the right-of-way to serve the significant gap. Detailed analysis and evidence presented by Verizon Wireless and PierCon Solutions confirm that the Golden Bough is not a feasible, less intrusive alternative. Therefore, denial would constitute a prohibition of service according to the two-part test.

Second, the evidence demonstrates that the Proposed Small Cell will improve Verizon Wireless service in the area, densify the network with another facility, and provide new 5G service. A denial redirecting Verizon Wireless to a location such as the Golden Bough would materially inhibit Verizon Wireless’s ability to provide service due to unreasonable costs, delay, and an inefficient network design that would likely require another small cell to provide sufficient service.

In sum, denial of the application would prevent Verizon Wireless from improving its service, and therefore materially limit or inhibit its ability to compete in a fair and balanced legal and regulatory environment. In other words, denial would constitute an effective prohibition of service in violation of the Telecommunications Act. See 47 U.S.C. §§ 253(a), 332(c)(7)(B)(i)(II); Infrastructure Order, 33 FCC Rcd. at 9102-9105, ¶¶ 35, 37.

VI. Conclusion
Verizon Wireless has worked diligently for six years to obtain a permit for a new small cell to provide reliable wireless service in western Carmel. The Proposed Small Cell complies with all City standards, including the findings for approval of two special exceptions. The Planning Commission provided no substantial evidence to support its denial and raised numerous topics that are irrelevant or preempted by federal or state law.

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We urge the Council to overturn the Commission’s denial and approve the Proposed Small Cell.

Very truly yours,

Paul B. Albritton
cc: Brian Pierik, Esq.

Gail Karish, Esq.

Jacob Olander
Schedule of Exhibits
Exhibit A: Plans
Exhibit B: Verizon Wireless Responses to Comments, Vol. 1, January 30, 2026 Exhibit C: Photosimulations
Exhibit D: Verizon Wireless February 10, 2026, Presentation to Planning Commission
Exhibit E: Verizon Wireless Application Letter, October 14, 2025 Exhibit F: PierCon Solutions Radio Frequency Report, October 14, 2025, and Supplemental Report #1, November 19, 2025
Exhibit G: Alternatives Analysis
Exhibit H: Dtech Communications Radio Frequency Compliance Report Exhibit I: Hammett & Edison Noise Compliance Report
Exhibit J: PierCon Solutions Radio Frequency Supplemental Report #2, January 30, 2026
Exhibit K: PierCon Solutions Radio Frequency Supplemental Report #3, February 9, 2026
Exhibit L: Verizon Wireless Responses to Comments, Vol. 2, February 6, 2026 Exhibit M: Verizon Wireless Responses to Comments, Vol. 3, February 24, 2026 Exhibit N: Photographs of Adjacent Utility Poles North and South on Carmelo Street Exhibit O: PierCon Solutions Radio Frequency Supplemental Report #4, February 23, 2026
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Site Plans
Verizon Wireless South Carmel 001
Exhibit A
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DR 25313 & UP 25314 (Verizon Sequoia Deployment) Carmel Planning Commission Verizon Wireless Responses – Volume 1
January 30, 2026
1 Verizon Wireless’s Responses Volume 1
Topic Page

1. Compliance With Code Requirements 1

2. Gap 1

3. Design 3

4. Location 4

5. Property Values 5

6. Environmental Review 6

1. COMPLIANCE WITH CODE REQUIREMENTS
Project opponents have claimed that the proposed facility does not comply with the Code.

The City adopted a new wireless ordinance in the Carmel-by-the-Sea Municipal Code (the “Code”) and Administrative Detailed Wireless Facility Design Guidelines (the “Guidelines”) in September 2023. The California Coastal Commission certified the Code in June 2025. Verizon Wireless studied the detailed Code and Guidelines over several years to develop an application that could comply with as many provisions as possible, given the voluminous restrictions and constraints presented by the regulations and site conditions in the City.

As described in the City’s Planning Staff in its January 21, 2026, Staff Report regarding DR 25313 & UP 25314 Verizon Sequoia Deployment (the “Staff Report”), Verizon Wireless submitted its application materials on October 15, 2025, and responded substantively to two completeness review letters. Staff Report, pp. 80-82.

Those materials, including drive test data, are available on the City’s website.

Planning Staff have concluded that the proposed facility complies with the Code and Guidelines with the addition of the two special exceptions requested. Staff Report, pp. 91-97, Attachment (“Att.”) 9, p. 271. CTC Telecommunications Network Consulting, the City’s consultant, has similarly confirmed compliance with the Code and Guidelines with respect to their areas of expertise.

2. GAP
Commissioners asked why the marketing maps available on Verizon Wireless’s website and the FCC’s National Broadband maps show 4G service in Carmel, but the PierCon and CTC reports state that current service is inadequate.

Marketing maps are of limited applicability to small cell network design. Verizon Wireless’s marketing maps do not take into consideration factors such as network changes, call traffic volume, technical limitations, changing handset capabilities, structures, foliage, and other conditions that may interfere with actual service at any point in time to the same detailed extent as Coverage Maps generated by system design tools.

Additionally, they do not account for interference, signal to noise ratios, nor capacity. All these factors were considered in the site-specific drive tests and professional network design tools that PierCon used to demonstrate the gap.

Exhibit B
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January 30, 2026
2 Verizon Wireless’s marketing maps explicitly include a disclaimer stating: “This map shows approximate outdoor coverage and is not a guarantee of service. Actual coverage may vary and is subject to change.”1 In contrast, Verizon Wireless’s coverage maps provided with the application show in-building coverage as well as in-vehicle and outdoor coverage. The marketing map does not account for the precise coverage mapping and network capacity analyses that Verizon Wireless engineers use to design networks.

Courts routinely reject efforts to use marketing maps to rebut the existence of a service gap. Los Angeles SMSA Limited Partnership v. City of Los Angeles, 2021 WL 3741539 (C.D. Cal. 2021), at *12-13 (holding that map on Verizon website showing “excellent coverage” was not sufficient to overcome professional coverage maps and drive tests); and T-Mobile West Corp. v. City of Huntington Beach, 2012 WL 4867775 (C.D. Cal. 2012), at *12-13 (maps provided to customers on T-Mobile’s website are “not as detailed as the Propagation Maps or Drive Test Maps that T–Mobile uses to plan network integrity and expansion,” and should not be used to determine whether a coverage gap exists).

Similarly, the FCC’s National Broadband Map2is not a network design tool, but rather a federal initiative that identifies underserved communities that need funding for internet infrastructure. Based on the map data, the federal government provides funds to various states, which in turn award grants to internet companies to enhance their networks in underserved communities. The National Broadband Map shows only data for “outdoor stationary coverage and in-vehicle mobile coverage.” However, lack of in-building coverage also proves the existence of a significant gap. T-Mobile W. Corp. v. City of Agoura Hills, 2010 WL 5313398 (C.D.

Cal. Dec. 20, 2010), at *8 (“a gap in a provider’s in-home coverage that consists of more than a few isolated pockets of inadequate in-home coverage suffices to show a significant gap exists”); MetroPCS Inc. v. City and County of San Francisco, 2006 WL 1699580 (N.D. Cal. 2006), at *10 (“any [significant gap] analysis should include consideration of a wireless carrier’s in-building coverage”); Los Angeles SMSA, supra, at *8- 10 (finding gaps in in-building coverage significant); T-Mobile W. Corp., supra, at *6 (finding a significant gap measured by a lack of reliable in-building residential and in-vehicle coverage).

Additionally, courts have held anecdotal experience testimony of neighbors stating that they did not experience coverage issues is not probative of the existence or significance (or lack thereof) of a coverage gap. Los Angeles SMSA, supra, at *9 (“The fact that approximately thirty individuals who strongly oppose the construction of the proposed Facility have submitted declarations stating they enjoy good coverage and are satisfied with Verizon’s existing service is neither statistically nor scientifically meaningful and is insufficient to demonstrate there is no significant gap of coverage within the relevant geographic area.”).

Opponents claim the effective prohibition standard doesn’t include broadband (e.g., fixed wireless).

This claim is false, as Verizon Wireless’s network provides information services through its wireless facilities, which will include the proposed facility. These information services include wireless broadband, mobile data networks, and connection to the internet, which Verizon Wireless provides using the same infrastructure as its personal wireless services. Voice and data services are commingled.

Planning Staff “confirmed with the city’s special counsel that 47 USC Section 332(c)(7) applies to personal wireless facilities used to provide commingled wireless services (both telephone and broadband/data)” and 1 Available at: www.verizon.com/coverage-map.
2 Available at: https://broadbandmap.fcc.gov/home.

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January 30, 2026
3 that “that the city cannot require wireless providers to only use their facilities to provide telecommunications services and not commingled services.” Staff Report, p. 81.

3. DESIGN
We received questions about whether the pole must be replaced, criticisms regarding equipment spacing and placement, and whether the proposed facility can be undergrounded.

PG&E dictates that poles older than 40 years with new wireless attachments need to be replaced. The proposed pole was installed in 1955, making it more than 70 years old. PG&E also dictates where the equipment must be placed on the pole. See, e.g., PG&E Standard 027911. PG&E no longer allows pole extensions to be added to the top of the pole, so they prescribed a taller replacement pole for this site to allow for the required equipment spacing and to comply with safety standards. Not only does PG&E have to accommodate other pole owners and equipment, it must also comply with its own safety rules and those of the California Public Utilities Commission (“CPUC”). Neither Verizon Wireless nor the City can circumvent PG&E and CPUC safety standards.

Undergrounding wireless is also infeasible. Verizon Wireless has explored this possibility with the City for nearly 10 years. Undergrounding equipment would require the construction of a sidewalk with a concrete curb and gutter to direct water away from the underground vault. Vaults require dewatering and ventilation systems. Furthermore, key equipment, such as the antenna, vent stacks, meter pedestal, and bollards, would still have to be placed above ground to serve their respective functions. For instance, PG&E requires metering equipment to be mounted on the same pole as the PG&E service. PG&E Standard 027911, §10. Clear and level working space is required in front of the meter. PG&E Standard 027911, §§20, 21. If a carrier cannot place a meter on the pole because the equipment is not on the pole, the carrier must install a pad−mounted pedestal meter. PG&E Standard 027911, §11 and §B-B on p. 10. PG&E would require the carrier to install bollards to protect someone reading the meters from traffic. PG&E Clearances and Location Requirements For Enclosures, Pads, and Underground Equipment, Document 051122 Rev #22, March 25, 2022 (“General Greenbook 051122”), §12; PG&E Greenbook §§5.4.4-5.4.5. In addition to being more intrusive, the space required for the bollards would likely result in the removal of at least one street parking space. Id.

Consequently, undergrounding the portions of a wireless facility would require that accessory equipment (an electric meter) be placed in a surface-mounted meter pedestal. The addition of the bollards and pedestal meter could be considered to obstruct views and add unnecessary visual clutter to the right-of-way.

We were asked about compliance with the Code’s height limit and impacts to the adjacent oak tree.

PG&E will replace the existing 38-foot, 11-inch utility pole with a new 46-foot, 4-inch pole. Staff Report, Att. 2, p. 118. When the antenna is installed on the new pole, the total facility height will be 49 feet, 10 inches, increasing the height of the existing pole by 10 feet, 11 inches. Id. The Code and Guidelines allow for this height at this location, since they allow a height increase of up to “10 feet above the height of the replaced pole or existing poles in the vicinity unless additional height is necessary to comply with CPUC safety standards such as General Order 95.” Code §17.46.040(F)(1)(b) (emphasis added); Guidelines Section II(A)(1). As Planning Staff explained at the hearing, wireless facilities mounted on electric utility poles are subject to stringent safety requirements of California Public Utilities Commission General Order 95, including required clearances mandating that antennas and their mounting hardware be elevated at least six feet above electric ATTACHMENT 8

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4 conductors. General Order 95 Rule 94.4. Consequently, the pole height is just slightly more than ten feet to ensure compliance with General Order 95’s six-foot clearance requirement.

As previously stated, PG&E will place the replacement pole in the footprint of the existing pole. A PG&E arborist will inspect the site prior to any construction activity to determine the scope of the project. Planning Staff confirmed that proposed facility with the tree and landscaping requirements. Staff Report, p. 87. In addition, Special Condition No. 3 requires Verizon Wireless to “provide a landscape management plan for any work proposed on the adjacent tree or surrounding public right-of-way” prior to the issuance of a building permit. Staff Report, Att. 1, p. 111. Condition of Approval 10 requires Verizon Wireless to “hire and pay for a licensed arborist to select plant and maintain replacement landscaping in an appropriate location for the species. Any replacement tree must be substantially the same size as the damaged tree or as otherwise approved by the City.” Staff Report, Att. 1, pp. 103-104.

The public asked about the feasibility of potential future collocations on this pole by other carriers and the potential impacts to radiofrequency emission safety as a result of those collocations.

As a preliminary matter, Condition of Approval No. 2 states that the permittee “shall be willing to allow other carriers and site operators to collocate transmission equipment . . . . whenever technically feasible and aesthetically desirable in accordance with applicable provisions in the City’s Municipal Code.” Staff Report, Att. 1, p. 102.

However, it is unlikely that another would collocate on this pole for several reasons. First, the new carrier and Verizon Wireless’s antennas would have to be located far enough apart so as not to create interference with each other’s signal. It is unlikely that both PG&E and the City would approve a height increase big enough to accommodate both carriers. PG&E has its own regulations, and it also must comply with the California Public Utilities Commission’s regulations. Next, the new carrier would have to place its equipment on the ground because there are only certain quadrants and heights on the pole on which PG&E allows wireless carriers to place equipment. Placing the equipment on the ground would likely cause greater aesthetic impacts. It would simply be easier for them to place their facility on a new pole.

With respect to whether the aggregate impact of two small cell facilities on the same pole would exceed the FCC’s exposure thresholds depends upon the new carrier’s choice of equipment. Any addition of equipment to the wireless facility will require a radio frequency exposure analysis confirming compliance with FCC’s exposure guidelines. In any event, no modification could be made that would exceed the FCC’s exposure thresholds.

4. LOCATION
Project opponents complain that the proposed facility is in the public right-of-way of an R-1 zone, adjacent to a City-inventoried historic home.

The gap area requiring service is in a residential zone, and the surrounding area is also residential. Staff Report, Att. 7, p. 225; Att. 8, p. 243. Consequently, the proposed small cell needs to also be in the residential area to provide service. As explained in the Verizon Wireless Alternatives Analysis, a wireless facility on a private residential parcel in the area, even if one were available, could not meet the Code’s and Guidelines’ height and setback requirements. Staff Report, Att. 8, pp. 245-246. Both Planning Staff and CTC confirmed that there are “no technically feasible and viable private parcel locations for placement,” leaving only the public right-ofway. Staff Report, p. 83; Att. 10. The proposed facility also meets the public right-of-way location safety ATTACHMENT 8

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5 considerations in the Code (Staff Report, p. 85), as well as the Guidelines for Facilities in the Public-Right-ofWay. Staff Report, pp. 89-90.

While the home directly to the east of the proposed facility is on the Carmel Inventory of Historic Resources, the proposed facility is not in a “location in the public right-of-way that would trigger review of consistency with the Secretary of the Interior’s standards for potential impacts to a historic resource on a residential parcel in any Tier I zone in subsection (B) of this section.” Code § 17.46.040(E)(1)(b). The closest residential window at the adjacent house is more than 23 feet away from the existing pole, and the pole is more than eight feet from the adjacent property line. Staff Report, Att. 2 at 114-115. Planning Staff confirmed that the proposed facility is not in a location that would trigger Secretary of the Interior’s review. Staff Report, p. 84. The Secretary of the Interior Standards address preservation, rehabilitation, restoration, or reconstruction of a historic property. 36 C.F.R. §§ 68.2, 68.3. Verizon Wireless is only slightly modifying an existing utility pole in the public right-ofway. Furthermore, there is no review by the City Historic Resources Board because the proposed small cell is not “within a historic district or within the boundaries of an historic property.” Code § 17.32.220.

Project opponents complain that the proposed facility will cause adverse visual impacts.

The City’s streets are already lined with utility poles supporting utility lines, transformers, and other utility equipment. For example, a utility pole due south on 11th & Carmelo supports a large, wide utility cabinet and an adjacent ground-mounted cabinet. The utility poles in the City’s right-of-way are not uniform. The equipment they host varies, as well as the heights, which range between roughly 25 feet to 50 feet above grade.

The proposed facility will not be an anomaly. The Code and Guidelines state that wireless facilities should not “significantly impair public or private views” and should be “designed to preserve significant coastal views from the public right-of-way.” Guidelines, § II(B)(1); Code § 17.46.040(F)(1)(k) (emphasis added). The Code even states “[t]he protection of public views should not prevent reasonable development of the site” and wireless facilities “should not present excess visual mass or bulk to public view or to adjoining properties.” Code § 17.46.040(F)(1)(k) (emphasis added). Furthermore, “[w]ireless communications facilities, to every extent possible, should be sited to not create visual clutter or negatively affect important public or private views . . . .” Id.

As described throughout the application, Verizon Wireless has made every effort to make the proposed facility as discrete as possible by minimizing the bulk and height. It is proposed for an existing pole, which will be replaced, rather than a new stand-alone pole, minimizing the amount of street furniture in the public right-ofway. All equipment and cables will be shrouded to blend in with the pole. Even the photos submitted by opponents from nearby residences confirm that the adjacent tree, trimmed to one foot of the equipment shroud, will provide screening or a backdrop, depending on the vantage point. The antenna would be viewed against the sky, and would not impact the view of nearby buildings, hills, or the ocean. The proposed facility is also subject to special conditions of approval which require the facility to be painted in matte, non-reflective paint to match the color of the PG&E utility pole and the applicant to supply a landscape management plan for any work proposed on the adjacent tree or surrounding public right-of-way. Staff Report, Att. 1 at 111.

5. PROPERTY VALUES
Opponents claim that the proposed facility will decrease property values in the area.

Opponents speculate that the proposed facility would decrease property values in the vicinity, stemming from misplaced fears of radio frequency emissions. General concerns about property values or aesthetics do not constitute substantial evidence to support denial of a permit to install a wireless telecommunications facility.

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6 Calif. RSA No. 4, d/b/a Verizon Wireless v. Madera County, 332 F. Supp. 2d 1291, 1308-1309 (E.D. Cal. 2003) (generalized concern on the effect on property values or aesthetics fail to meet the substantial evidence threshold) (citing Omnipoint Corp. v. Zoning Hearing Bd., 181 F.3d 403, 409 (3d Cir.1999); Cellular Telephone Co. v. Town of Oyster Bay, 166 F.3d 490 (2nd Cir. 1999)). Given federal preemption over radio frequency emissions, “direct or indirect concerns over the health effects of RF emissions may not serve as substantial evidence to support the denial of an application.” AT&T Wireless Servs. of Cal. LLC v. City of Carlsbad, 308 F.

Supp. 2d 1148, 1159 (S.D. Cal. 2003); Calif. RSA No. 4, supra, 332 F. Supp. 2d at 1311. Opponent speculation here about property values is premised on fears of radio frequency emissions, so it cannot be considered. In any event, speculation that wireless facilities diminish property values is unfounded.

In 2012, the Joint Venture Silicon Valley Network studied the impact of wireless facilities on property values.3 They partnered with the Santa Clara County Association of REALTORS and the Silicon Valley Association of REALTORS (SILVAR) to study over 1,600 single family home transactions and concluded that “ the distance from a wireless facility has no apparent impact on the value or sale price of a home.” The most relevant study to this site addresses small cell wireless facilities in an equivalent northern California market. The Joint Venture Silicon Valley Network’s 2021 study, Economic Impacts to Residential Real Estate from Small Wireless Facilities found that “[a]t an aggregate statewide level. . . .statistically significant increases in residential real estate valuation at all distances after construction of the proximal wireless sites.”4 It also debunked the foundational study, from which many of the opponents’ studies stem, which was based in New Zealand. The Joint Venture Silicon Valley Network found that the “oft-cited 20% reductions in valuation are not evident in the statewide analysis, nor in any of the metropolitan region analyses.” Id. at p. 6. 5 One opponent at the hearing claimed that the National Association of Realtors conducted a survey concluding that wireless facilities decrease property values. We have not found any such survey.6 We have only found an informational page stating that at ground level near cell phone towers, “the level of radio frequency waves is much lower than limits for safe exposure.”7 Others rely on a discredited study discussed above. That study does not consider the small cell facilities contemplated in this application.

6. ENVIRONMENTAL REVIEW
Project opponents claim that the proposed facility does not qualify for a CEQA exemption. 3 Available at https://jointventure.org/images/stories/pdf/WirelessFacilitiesImpactOnPropertyValues.pdf. 4 Available at: https://jointventure.org/images/stories/pdf/cell-real-estate-study-2021-07.pdf and attached as Exhibit A.
5 The source of this number is from an article in The Appraisal Journal, (Summer 2005) authored by Sandy Bond, Ph.D. and Ko-Kang Wang that “asserted wireless towers could result in a 20% reduction in residential real estate valuations.” Id. at p. 10. This article has largely been discredited because Bond and Wang used surveys to collect data, when surveys are “subject to respondent bias, participation bias, sampling bias, and a host of other factors.” Id. Joint Venture Silicon Valley Network found “evidence that Dr. Bond was consulting in 2005 for the Porirua Residents’ Action Group in Wellington, NZ, and that this group was actively opposed to wireless tower deployments in the area.” Id.
6 The 2021 Joint Venture Silicon Valley Network study, on page 12, observes that the National Association of Realtors links to The Impact of Cell Phone Towers on House Prices: Evidence from Brisbane, Australia (Environmental Economics and Policy Studies, Jan. 1, 2018) behind a member registration wall, which was posted by an anti-EMF activist group that cites Bond/Wang 2005. 7 Available at https://www.nar.realtor/cell-phone-towers#section-references.

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7 Planning Staff has properly determined that the proposed facility is categorically exempt from further review under the California Environmental Quality Act (Pub. Res. Code §§ 21000 et seq.) (“CEQA”) and CEQA Guidelines (14 Cal. Code of Regs. §§ 15000–15387). Staff Report, pp. 97-98. The use of the Class 3 exemption is well-established for a wide variety of wireless facility projects. See, e.g., Don’t Cell Our Parks v. City of San Diego (2018) 21 Cal.App.5th 338 (faux tree telecommunications pole in public park); Aptos Residents Ass’n v.

County of Santa Cruz (2018) 20 Cal.App.5th 1039 (10 microcell transmitter units on existing utility poles); Robinson v. City and County of San Francisco (2012) 208 Cal.App.4th 950 (40 wireless equipment cabinets on existing utility poles); San Francisco Beautiful v. City and County of San Francisco (2014) 226 Cal.App.4th 1012 (726 telecommunications cabinets in the public right-of-way).

Opponents claim that the proposed facility may significantly impact a historical resource, triggering an exception. 14 Cal. Code Regs. § 15300.2(f). As discussed above in Section 4, the proposed facility will not impact a historical resource. It will replace an existing pole in the public right-of-way, not a historical property, with a slightly taller pole and wireless equipment. It will not result in the “physical demolition, destruction, relocation, or alteration of the resource or its immediate surroundings such that the significance of an historical resource would be materially impaired.” 14 Cal. Code Regs. § 15064.5(b); Staff Report, Atts., 2 at 114-155 and 3 at 127-129. The proposed facility is exempt from CEQA.

ATTACHMENT 8

Economic Impacts to
Residential Real Estate from
Small Wireless Facilities
July 2021

SILICON VALLEY
This work is licensed under a Creative Commons Attribution 4.0 International License (CC BY 4.0).

To view this license, visit https://creativecommons.org/licenses/by/4.0/ www.jointventure.org
Joint Venture Silicon Valley, 2021

EXHIBIT A
ATTACHMENT 8

Study Background
Mobile telephone and data networks have existed for several decades, dating back to the late 1960s when “car phones” were first introduced. Mass-adoption began in the late 1990s, when economies of scale and Moore’s Law [1] made affordable mobile handsets possible. The introduction of smartphones in the late 2000s drove mass adoption of mobile connectivity and applications we now rely on for daily life in the 21st century. The usage trends of these technologies are well-known and personally familiar. In 2015 the World Bank reported that 97.4% of the world’s population have cellular phone subscriptions, but only 68% have sanitation service (i.e. toilets, sewers, etc.) [2]
In the United States, over 80% of emergency calls to 911 emergency services originate from mobile phones. [3] Per the Centers for Disease Control’s bi-annual Wireless Substitution Report 62.5% of U.S. adults and 73.6% of U.S. children are living in households that are “wireless-only” in which they’ve replaced their wired telephones with wireless service. [4] For people under the age of 34, the wireless-only rate is nearly 80%, as an increasingly large percentage of the younger population have never owned — or even used — wired telephones. Mobile internet and data usage is also growing exponentially. Globally, in 2020, the amount of data that flowed monthly over mobile data networks exceeded 70 Petabytes. (A Petabyte is equal to 1,000,000 Gigabytes.) [5] To serve this exponentially-increasing demand, wireless carriers are densifying their networks by deploying low-power augmentation sites known as “small cells” because they cover small areas close to population centers and areas where people congregate. Initially, the densification projects used enhanced 4G LTE technology, but are now shifting toward 5G NR (New Radio) to add additional capacity and features.

This expansion of the network, and in particular the introduction of new technologies and spectrum bands, has met with a variety of concerns from a small but vociferous handful of residents, organizations, and even some local governments. The expressed concerns are primarily that electromagnetic fields from these wireless sites will cause health problems, negatively impact local aesthetics, or negatively affect real property valuations. It is this latter concern that our study sought to address.

Study Goals
There are numerous studies on the impact of wireless sites on real estate valuation that used objective and reproducible methods: Joint Venture Silicon Valley 2012, Valbridge 2018, Maennig (University of Hamburg) 2010, and others. [6], [7], [8] However, previous studies focused on wide-area coverage from large towers and monopoles (known as “macro” sites) on hilltops and buildings, rather than small cells on wooden poles and street lights near residences and population centers. None of the previous objective studies found economically-significant impacts — positive or negative — to property valuations, but nevertheless there is an extant belief (or an “urban legend”) held by some real estate agents that wireless sites near residences can cause 2 Economic Impacts to Residential Real Estate from Small Wireless Facilities ATTACHMENT 8

property valuation reductions of up to 20%. A devaluation of residential real estate from proximal wireless sites does not show up in objective peer-reviewed studies, nevertheless a belief that wireless sites cause devaluation persists and is often raised as an objection during planning commission, city council, county board, and permit appeal hearings. Because the previous studies focused on macro sites, and the wireless industry’s current deployment focus is on 4G and 5G small cells, the studies from JVSV, Valbridge, Maennig, etc. are challenged by appellants as not applicable to small cells.

To address the gap between extant belief and evidence-based economics, our study focused on whether residential real estate valuation impacts from small cells were objectively evident in real estate sale records.

Study Methodology
Our study applied a spatial difference-in-differences approach, a well-regarded economic analysis method used to estimate the impacts from proposed shopping centers, liquor stores, sports stadiums, transit centers, and other contentious land uses in and near residential areas. The study examined the question, “Do wireless small cell sites have an effect, either positive or negative, on the valuation of residential real estate?” The study also examined the question of whether or not the oft-asserted 20% reduction in property valuation appeared in the results.

The study used a dataset of 1,734 small cell sites installed in the State of California over the time period from 2010 to 2020, and a dataset of 11,684,458 real estate transactions statewide over the same ten-year period.

The study looked at residential real estate valuations for properties (the study subjects) within 10 kilometers around the constructed small cell sites, compared with residential real estate valuations for similar properties (the control group) not near small cell sites.

The study looked at price variation before and after construction of the small cell sites.

Using the spatial difference-in-differences analysis method, effects on real estate sale prices from wireless small cell sites — if they exist — will show up as variations in sale price trajectories between properties proximal to wireless sites and the non-proximal control group properties, with variation occurring during or after the time point when the small cell sites were built.

Our study methodology also controlled for variations that could affect the sale price.

Controlling for variations included, but was not limited to, defining similarities in the properties based on:
• Type of Transaction: New construction, Re-sale, REO, Foreclosure, etc. • Property Type: Single-Family Attached, Single-Family Detached, Condo, COOP, etc. • Number of bedrooms
Economic Impacts to Residential Real Estate from Small Wireless Facilities 3 ATTACHMENT 8

• Number of bathrooms
• Number of Half Bathrooms
• Square Footage (living area)
• Garage Square Footage
• Lot Size: Number of square feet of lot
• Year Built: Original construction year
• Levels: Number of property stories
• Units: Number of units on property
• Property Condition: Any internal flag/measure of property condition • Arm’s Length: Any internal indicator of arm’s length transaction • Latitude - Property latitude in decimal degrees (ISO 6709) • Longitude - Property longitude in decimal degrees (ISO 6709) The wireless site dataset was provided by Verizon Wireless, and included small cell sites (both 4G and 5G) constructed between 2010 and 2020 in sixteen metropolitan regions in California:
• Sacramento, Roseville, Arden-Arcade
• San José, Sunnyvale, Santa Clara
• San Francisco, Redwood City, South San Francisco
• Oakland, Hayward, Berkeley
• Santa Rosa
• Stockton, Lodi
• Fresno
• Santa Maria, Santa Barbara
• Modesto
• Salinas, Monterey
• San Luis Obispo, Paso Robles, Arroyo Grande
• Santa Cruz, Capitola, Aptos, Watsonville
• Bakersfield
• Vallejo, Fairfield
• Visalia, Porterville
• Napa
4 Economic Impacts to Residential Real Estate from Small Wireless Facilities ATTACHMENT 8

The wireless site dataset defined the latitude and longitude of the site, the date of construction, and the type of attachment structure i.e. wood pole, street light, etc.

The real estate transaction dataset was provided by Black Knight Data & Analytics, LLC, and included all residential real estate transactions in California between the years 2010 and 2020. Extensive and detailed coding of the properties in the dataset enabled accurate comparisons between sales of the study properties and sales of control group properties.

Both the wireless and real estate datasets were provided to a doctoral-level economist skilled in urban planning, policy, land use, and housing. The economist was directed to conduct the analysis objectively. The economist had no contact with the wireless industry before or during the study, and has no previous or current financial relationship with the wireless industry. The analysis was done using the Stata software package from StataCorp LLC. The economist produced a set of statistical coefficients appropriate for a third-order curve analysis of residential real estate sales near wireless sites ranging out to 10 kilometers (32,808 feet) radial distance. The analysis used radial increments of 0.1 kilometers (328 feet). The economist also calculated a coefficient of determination (denoted as R2
) which indicates how well the data fits to the calculated regression line. The analysis was conducted at the aggregate statewide level, and also at the local level for the aforementioned metropolitan regions. No adjustments were made to the real estate dataset by the Joint Venture Silicon Valley or the economist.

The coefficients and analysis results were in turn provided to Joint Venture Silicon Valley for final authorship of this report. Aside from formatting the results as necessary for report authorship production, no adjustments were made to the analysis results.

Study Findings
Statewide (California)
At an aggregate statewide level, the analysis found statistically significant increases in residential real estate valuation at all distances after construction of the proximal wireless sites. However, not all of these valuation variations were economically significant.

Coefficient of determination (R2) for the statewide analysis was very high at 0.97 – in other words, this analysis accounts for nearly 100% of all observed effects on valuation from wireless site deployment near the subject properties.

Statewide, real estate valuation increases from proximal wireless sites ranged from +0.03% (within 0.1 kilometers of a wireless site) to +2.14% (at distances from 8.4 km to 8.9 kilometers). For purposes of illustration: California’s median single-family home price in 2020 was $758,990 thus the price premia found in the analysis would result in valuation increases ranging from $228 (0.03%) to $16,242 (2.14%).

Economic Impacts to Residential Real Estate from Small Wireless Facilities 5 ATTACHMENT 8

The oft-cited 20% reductions in valuation are not evident in the statewide analysis, nor in any of the metropolitan region analyses.

Statistical Significance of Metro Areas
Of the sixteen metropolitan regions analyzed, six regions showed no statistical significance; i.e. wireless sites proximal to residential real estate had no impact on valuation. The six metro regions showing no statistical significance in the analysis were:
• Stockton, Lodi
• Salinas, Monterey
• Santa Cruz, Capitola, Aptos, Watsonville
• Bakersfield
• Vallejo, Fairfield
• Visalia, Porterville
• Napa
Sacramento CA Metro Area
In the Sacramento metro area (Sacramento, Roseville, Arden-Arcade), the analysis found increases in residential real estate valuation after construction of proximal wireless sites.

Looking at 3,796,728 transactions, the valuation variation ranged from +0.01% (within

0.1 km of the wireless site) to +0.53% (at distances from 6.0 km to 6.4 km).

R2 for the Sacramento metro area analysis was 0.92. The oft-cited 20% reductions in valuation are not evident in the Sacramento metro area results.

San José CA Metro Area
In the San José metro area (San José, Sunnyvale, Santa Clara), the analysis found no valuation effects within 0.4 km, and increases in residential real estate valuation at distances greater than 0.5 km, after construction of the subject wireless sites.

Looking at 3,612,141 transactions, the valuation variation ranged from +0.01% (beginning at 0.5 km from the wireless site) to +0.47% (at distances from 8.0 km to 9.0 km).
6 Economic Impacts to Residential Real Estate from Small Wireless Facilities ATTACHMENT 8

R
2 for the San José metro area analysis was 0.93. The oft-cited 20% reductions in valuation are not evident in the San José metro area results.

San Francisco CA Metro Area
In the San Francisco metro area (San Francisco, Redwood City, South San Francisco), the analysis found slight decreases, but also increases, in residential real estate valuation after construction of proximal wireless sites.

Looking at 3,378,178 transactions, the valuation variation ranged from -0.11% (at distances from 0.7 km to 0.9 km from the wireless site) to +3.73% (at distances from 9.1 km to 9.3 km). The decreases observed are not economically signification.

R
2 for the San Francisco metro area analysis was 0.90. The oft-cited 20% reductions in valuation are not evident in the San Francisco metro area results.

Oakland CA Metro Area
In the Oakland metro area (Oakland, Hayward, Berkeley), the analysis found increases in residential real estate valuation at all distances after construction of proximal wireless sites.

Looking at 628,836 transactions, the pricing variation ranged from +0.08% (within 0.1 km of the wireless site) to +3.25% (at 10.0 km from the wireless site).

R
2 for the Oakland metro area analysis was 0.92. The oft-cited 20% reductions in valuation are not evident in the Oakland metro area results.

Santa Rosa CA Metro Area
In the Santa Rosa metro area, the analysis found slight decreases, but also slight increases, in residential real estate valuation after construction of proximal wireless sites.

Looking at 120,937 transactions, the pricing variation ranged from -0.52% (at distances from 2.3 km to 2.7 km from the wireless site) to +0.05% (at distances from 7.5 km to

7.9 km).

R
2 for the Santa Rosa metro area analysis was 0.94. The oft-cited 20% reductions in valuation are not evident in the Santa Rosa metro area results.

Economic Impacts to Residential Real Estate from Small Wireless Facilities 7 ATTACHMENT 8

Fresno CA Metro Area
In the Fresno metro area, the analysis found increases in residential real estate valuation after construction of proximal wireless sites.

Looking at 18,438 transactions, the pricing variation ranged from +0.25% (within 0.1 km of the wireless site) to +3.94% (at distances from 4.4 km to 4.6 km).

R2 for the Fresno metro area analysis was 0.97. The oft-cited 20% reductions in valuation are not evident in the Fresno metro area results.

Santa Barbara CA Metro Area
In the Santa Barbara metro area (Santa Barbara, Santa Maria), the analysis found increases in residential real estate valuation after construction of proximal wireless sites.

Looking at 15,630 transactions, the pricing variation ranged from +0.10% (within 0.1 km of the wireless site) to +2.56% (at distances from 5.0 km to 5.5 km).

R2 for the Santa Barbara metro area analysis was 0.98. The oft-cited 20% reductions in valuation are not evident in the Santa Barbara metro area results.

Modesto CA Metro Area
In the Modesto metro area, the analysis found increases in residential real estate valuation after construction of proximal wireless sites.

Looking at 15,123 transactions, the pricing variation ranged from +1.00% (within 0.1 km of the wireless site) to +16.22% (at distances from 3.7 km to 3.8 km).

R2 for the Modesto metro area analysis was 0.92. The oft-cited 20% reductions in valuation are not evident in the Modesto metro area results.

San Luis Obispo CA Metro Area
In the San Luis Obispo metro area (San Luis Obispo, Paso Robles, Arroyo Grande), the analysis found slight decreases, but also increases, in residential real estate valuation after construction of proximal wireless sites.

Looking at 9,831 transactions, the pricing variation ranged from -0.27% (at distances from 1.7 km to 2.1 km from the wireless site) to +0.91% (at distances from 9.3 km to

9.5 km).
8 Economic Impacts to Residential Real Estate from Small Wireless Facilities ATTACHMENT 8

R2
for the San Luis Obispo metro area analysis was 0.98. The oft-cited 20% reductions in valuation are not evident in the San Luis Obispo metro area results.

Discussion
Economic Significance of Pricing Variations
While some pricing variation was found to be statistically significant, not all variations were economically significant. Economic significance could be interpreted as any variation above the 1 - R2 level, however for purposes of this study, the researchers considered pricing variations over 1% to be economically significant. Variations could be due to factors that this analysis did not consider including weather, crime trends, stock market fluctuations, or population migration trends.

Example: In our study, the maximum valuation decrease was -0.52% (Santa Rosa metro area). The median listing sold price in Santa Rosa CA (Jan 2020, per the National Association of REALTORS® website) was $571,000. A pricing variation of -0.52% would equate to a valuation decrease of $2,969.

The study found three metro areas with statistically significant valuation decreases, but no metro areas with economically significant valuation decreases. The study found six metro areas with economically significant valuation increases: San Francisco (+3.73%), Oakland (+3.25%), Fresno (+3.94%), Santa Barbara (+2.56%), and Modesto (+16.22%).

Metro Area Lowest Variation Highest Variation R2
Sacramento +0.01% +0.53% 0.92
San José (South Bay) +0.01% +0.47% 0.93
San Francisco (-0.11%) +3.73% 0.90
Oakland (East Bay) +0.08% +3.25% 0.92
Santa Rosa (-0.52%) +0.05% 0.94
Fresno +0.25% +3.94% 0.97
Santa Barbara +0.10% +2.56% 0.98
Modesto +1.00% +16.22% 0.92
San Luis Obispo (-0.27%) +0.91% 0.98
Table 1 : Valuation Variation Ranges and Coefficients of Determination, by Metro Area Economic Impacts to Residential Real Estate from Small Wireless Facilities 9 ATTACHMENT 8

Refutation of the “20% Reduction in Valuation” Assertion An article appeared in The Appraisal Journal, (Summer 2005) authored by Sandy Bond, Ph.D. and Ko-Kang Wang that asserted wireless towers could result in a 20% reduction in residential real estate valuations. Reviewing this article reveals that Bond and Wang used a survey methodology to collect data, citing sources (including self-citations to Bond’s own work) that recommended surveys as a valid methodology. In practice, surveys are poor methodologies for analyzing market economics as they are subject to respondent bias, participation bias, sampling bias, and a host of other factors. There is also evidence that Dr. Bond was consulting in 2005 for the Porirua Residents’ Action Group in Wellington, NZ, and that this group was actively opposed to wireless tower deployments in the area. [9] Dr. Bond’s financial relationship with the PRAG (if any) is unknown.

Despite the relative weakness of surveys compared to objective market studies (JVSV 2012, Valbridge 2018, Maennig 2010) the extant belief that wireless sites have negative impacts on real estate valuations persists in the real estate community, and is often cited by resident groups opposed to wireless site deployments. These negative valuation impacts are not evident in this study’s analysis. Indeed, no economically significant valuation decreases are evident in our study.

Demographic Shifts in Attitudes toward Wireless Sites
As evidenced by the CDC’s Wireless Substitution reports [4] younger people rely more heavily on wireless devices for their daily lives. Per the CDC’s report as of December 2019, over 75% of U.S. adults under age 34 rely solely on their wireless devices for telephone calls. Younger generations, sometimes referred to as “Millennials” or “Generation Z”, are now the dominant economic demographic in the U.S. and are increasingly the dominant economic force in real estate markets. An article in the National Association of REALTORS® magazine stated that, after the onset of the SARS-CoV-2 pandemic, 69% of real estate professionals reported that prospective buyers sought information about a home’s access to connectivity, including wireless coverage. [10] The article also stated that 62% of real estate agents believe that within one to two years, 5G home internet (an alternative to DSL, fiber, or cable broadband) will be something they will advertise during the sale process. Younger buyers’ attitudes towards wireless infrastructure stand in somewhat sharp contrast to members of older generations that have traditionally formed the core of opposition to wireless site deployments in and around neighborhoods.

The SARS-CoV-2 pandemic forced a major societal shift in attitudes toward remote work, distance learning, telehealth, online shopping, and delivery services. Many of these shifts will remain, and real estate professionals should expect that, going forward, residents will expect their wireless networks to support the increased levels of wireless data usage we observed during the pandemic. 10 Economic Impacts to Residential Real Estate from Small Wireless Facilities ATTACHMENT 8

Possible Distortions of the Study Data
The datasets for this study’s analysis were purely objective. They comprise the entirety of one wireless carrier’s small cell deployments from 2010 to 2020, and the entirety of real estate transactions in the state of California over the same time period. The R2 values for the observed results are very high, at 0.90 or better, indicating that the observed effects on residential real estate valuation are largely explained by the spatial difference-in-differences approach. Nevertheless, for completeness, we note some possible external effects on the study data.

Carrier Operational Economics
The most likely distortion of the results is due to the operational economics of wireless carriers. As for-profit companies, wireless carriers must weigh the cost of building a given wireless site against the carrier’s ability to realize a return on investment. Costs associated with wireless deployments are often significant, and realizing a return on investment from deployments in economically-challenged neighborhoods or areas with low population is challenging. If the wireless sites in the study data were deployed more in economically-advantaged neighborhoods, and economically-challenged neighborhoods in the control group were not targets for wireless site deployment, the relative strength of the economically-advantaged neighborhoods chosen for deployment could be affecting the results.

Economic Impacts of the SARS-CoV-2 Pandemic
Because the datasets covered the time period from 2010 to 2020, it is possible that the economic effects of the SARS-CoV-2 pandemic (beginning in early 2020) had some (albeit minimal) effect on the analysis. During the pandemic in 2020, people migrated away from large cities to smaller cities and suburban areas. [11] Despite massive corrections to the economy and significant unemployment due to business closures, real estate transactions rose sharply and valuations increased. It is possible that the 2020 real estate valuation increases could be affecting the results, however given that the study looked at a full decade of transactions, a statistically significant effect from pandemic-driven migration is unlikely.

Racial, Cultural, Age, and Other Factors
The real estate transaction dataset used for this study does not contain information about buyer demographics. Thus, it is impossible to determine if there are demographic effects in the study results. It may be, for example, that younger buyers (who tend to place higher value on network connectivity) will place a higher valuation on a real estate opportunity that has strong wireless coverage. And it may be that some racial, cultural, or other demographic groups will place higher or lower value on Economic Impacts to Residential Real Estate from Small Wireless Facilities 11 ATTACHMENT 8

network connectivity. To help offset this, the researchers studied a large number of metropolitan areas across the state, but in the end, we note that buyer demographics are an uncontrollable variable in this study.

Contradictory Evidence Review
We reviewed previous studies and articles that claimed to find negative impacts to residential real estate valuation. In many cases, these works were not openly available in the peer-review systems.

Bond/Wang 2005
We were able to review a copy of Bond and Wang’s article, The Impact of Cell Phone Towers on House Prices in Residential Neighborhoods, in The Appraisal Journal (Summer 2005) although we note that this article is behind a subscriber paywall. We noted that Bond/Wang’s methodology used surveys, which have inherent issues with respondent bias, participation bias, sampling bias, and a host of other factors.

Affuso/Cummings/Le 2017
We attempted to review the work of Ermanno Affuso, J. Reid Cummings, and Huubinh Le from University of South Alabama. Their paper, Wireless Towers and Home Values:

An Alternative Valuation Approach Using a Spatial Econometric Analysis, in The Journal of Real Estate Finance and Economics (May 2018) appears (from what we could derive from the paper abstract) to be the closest approximation to our study, with the exception that Affuso et al. analyzed effects from macro towers not small wireless facilities. The National Association of REALTORS® links to Affuso et al. 2017 from their “Cell Phone Towers” subpage, but via a NAR member registration wall. [12] Requests to Affuso et al. for a courtesy/peer copy of their paper did not receive a response.

National Association of REALTORS® Website
The NAR also links to The Impact of Cell Phone Towers on House Prices: Evidence from Brisbane, Australia (Environmental Economics and Policy Studies, Jan. 1, 2018) which again is behind a member registration wall. NAR links to Property values, desirability and cell towers (EMFSA, website) an anti-EMF activist group which cites both the survey work from Bond/Wang 2005, and a survey conducted in June 2014 by the National Institute for Science, Law and Public Policy (NISLAPP) in Washington, D.C. [12] 12 Economic Impacts to Residential Real Estate from Small Wireless Facilities ATTACHMENT 8

Conclusions
Across a wide geographic area, using a decade of wireless facility and real estate transaction data, our analysis found effectively zero statistical evidence that proximal small wireless communication facilities or “small cells” negatively impact residential real estate valuations. In fact, there is some evidence that residential real estate valuations increase within 10 km after construction of a small wireless facility. In cases where there is a statistically significant negative impact, the impact is not economically significant.

We note that the body of evidence asserting to show negative impacts to residential real estate from wireless communication facilities appears to come largely from surveybased methodologies. Where previous work has claimed to find negative valuation impacts, there appears to be very little if any available for peer-review. We encourage researchers on this topic to open their work to peer-review and scrutiny.

Support for the extant belief held by some real estate agents that wireless sites near residences can cause residential property devaluations of up to 20% is not evidenced by this study.

About the Researchers
David Witkowski, Joint Venture Silicon Valley
Witkowski is an author, advisor, and strategist who works at the intersection between local government and the telecommunication industry. He is the Executive Director of the Civic Technologies Initiative at Joint Venture Silicon Valley, a Fellow in the Radio Club of America, an IEEE Senior Member, and the Founder & CEO of Oku Solutions LLC. After serving in the U.S. Coast Guard and earning his B.Sc. in Electrical Engineering from the University of California, he held leadership roles for companies ranging from Fortune 500 multi-nationals to early-stage startups. He serves as Co-Chair of the Deployment Working Group at IEEE Future Networks, Co-Chair of the GCTC Wireless SuperCluster at NIST, as a member of the Connected Communities Forum in the Wireless Broadband Alliance, and as an Expert Advisor to the California Emerging Technology Fund.

Dr. Ralph B. McLaughlin, Chief Economist and Senior Vice President of Analytics, Haus
In December 2019, McLaughlin was named Chief Economist and Senior Vice President of Analytics at Haus. He is responsible for leading economic research using data and analytics to expand the visibility of the Haus economic policy unit while enhancing research capabilities and tools for consumers, industry professionals, the public sector and news media.

Economic Impacts to Residential Real Estate from Small Wireless Facilities 13 ATTACHMENT 8

McLaughlin has nearly two decades of experience in the housing and mortgage market. Prior to joining Haus, he served as Chief Economist at Trulia, as Deputy Chief Economist at CoreLogic, as an Assistant Professor in Real Estate Development at San Jose State University, and as a Lecturer at the University of South Australia. He was also recently appointed as an Adjunct Assistant Professor in the Price School of Public Policy at the University of Southern California, where he teaches a masters course in urban economics.

McLaughlin frequently appears on local and national radio and television programs, and has been widely quoted in The Wall Street Journal, New York Times, Washington Post, USA Today, and Los Angeles Times as well as numerous industry trade publications such as HousingWire and National Mortgage News. He has appeared as a regular guest on cable news channels including CNBC, Bloomberg, and Fox Business News.

McLaughlin earned a Ph.D. in Planning, Policy, and Design, specializing in Urban Economics, from the University of California at Irvine, and a B.S. in Geography and Regional Development from the University of Arizona.

Acknowledgements
Richard Lombardi and Damien Weldon
Lombardi and Weldon’s sponsorship and support of this project was key to completing the study. This study is based in part on data provided by Black Knight Data & Analytics, LLC who generously provided the real estate transaction dataset for this study.

Black Knight (NYSE:BKI) is a leading provider of integrated software, data and analytics solutions that facilitate and automate many of the business processes across the homeownership life cycle. Black Knight is committed to being a premier business partner that clients rely on to achieve their strategic goals, realize greater success and better serve their customers by delivering best-in-class software, services and insights with a relentless commitment to excellence, innovation, integrity and leadership.

Radha Sharma
Sharma and her team at Verizon Wireless have been consistent supporters of the Wireless Communications Initiative at Joint Venture Silicon Valley, and they worked tirelessly to navigate the legal and contractual process with Verizon’s legal team in order to provide us with the wireless site dataset.
14 Economic Impacts to Residential Real Estate from Small Wireless Facilities ATTACHMENT 8

Bibliography
[1] Wikipedia, “Moore’s Law,” [Online]. Available: https://en.wikipedia.org/wiki/ Moore%27s_law. [Accessed 11 June 2021].
[2] World Bank, “Are cell phones becoming more popular than toilets?,” 26 August 2019. [Online]. Available: https://blogs.worldbank.org/opendata/are-cell-phonesbecoming-more-popular-toilets. [Accessed 09 June 2021]. [3] NENA - The 9-1-1 Association, “9-1-1 Statistics,” [Online].

Available: https://www.nena.org/page/911Statistics. [Accessed 09 June 2021]. [4] National Center for Health Statistics, “Wireless Substitution: Early Release of Estimates Jan-Jun 2020,” U.S. Department of Health and Human Services, Centers for Disease Control, Washington, D.C., 2020.
[5] Ericsson, “Ericsson Mobility Report,” Telefonaktiebolaget LM Ericsson, Stockholm, Sweden, 2020.
[6] Joint Venture Silicon Valley, “Wireless Facilities Impact on Property Values,” Joint Venture Silicon Valley, San José, CA, 2012.
[7] Valbridge Property Advisors, “Valbridge Market Studies,” Valbridge Property Advisors, Naples, FL, 2018.
[8] W. Maennig and S. Brandt, “Perceived Externalities of Cell Phone Base Stations – The Case of Property Prices in Hamburg, Germany,” Universität Hamburg, Hamburg, DE, 2010.
[9] California State University, Fullerton CA, “Curriculum Vitae: Dr Sandy Bond,” [Online]. Available: https://fullerton.academia.edu/SandyBond/CurriculumVitae. [Accessed 21 June 2021].
[10] National Association of REALTORS, 14 May 2021. [Online]. Available: https:// magazine.realtor/daily-news/2021/05/14/5g-network-availability-becomes-majorselling-point-for-homes. [Accessed 10 June 2021]. [11] J. K. Dineen, “San Francisco Chronicle,” 18 February 2021. [Online]. Available:
https://www.sfchronicle.com/bayarea/article/People-are-leaving-S-F-but-not-forAustin-or-15955527.php. [Accessed 11 June 2021]. [12] National Association of REALTORS(r), “NAR: Cell Phone Towers,” [Online].

Available: https://www.nar.realtor/cell-phone-towers#section-165807. [Accessed 21 June 2021].

Economic Impacts to Residential Real Estate from Small Wireless Facilities 15 ATTACHMENT 8

SILICON VALLEY
84 West Santa Clara Street
Suite 800
San Jose, California 95113
(669) 223-1331
www.jointventure.org
ATTACHMENT 8

Carmelo Street Carmel-by-the-Sea CA 93921
SC 001 Carmelo Stonewall (Opt 2)
Accuracy of photo simulation based upon information provided by project applicant.

Proposed Looking north from Carmelo Street
View 1
Existing
quipment xxxxxxxxxxx
proposed replacement utility
pole with antenna shroud
proposed pole mounted equipment beyond
©2023 Google Maps
Exhibit C
ATTACHMENT 8

Accuracy of photo simulation based upon information provided by project applicant.

Proposed Looking south from Carmelo Street
View 2
Existing
quipment xxxxxxxxxxx
proposed replacement utility
pole with antenna shroud
proposed pole mounted equipment
Carmelo Street Carmel-by-the-Sea CA 93921
SC 001 Carmelo Stonewall (Opt 2)
©2023 Google Maps
ATTACHMENT 8

Accuracy of photo simulation based upon information provided by project applicant.

Proposed Looking east across Carmelo Street
View 3
Existing
proposed replacement utility
pole with antenna shroud
proposed pole mounted equipment
quipment xxxxxxxxxxx
Carmelo Street Carmel-by-the-Sea CA 93921
SC 001 Carmelo Stonewall (Opt 2)
©2023 Google Maps
ATTACHMENT 8

Carmel-by-the-Sea Planning Commission
February 10, 2026
Carmelo Street
Small Cell Node 001
Pete Shubin, Sequoia Deployment Services
Jay Gruendle, Program Manager, Verizon Small Cells
Jeremy Stroup, Verizon Municipal Engagement Partner
Rich Conroy, PierCon Solutions
David Witkowski, Oku Solutions
Paul Albritton, Mackenzie & Albritton LLP
Exhibit D
ATTACHMENT 8

Golden Bough
Best Serving Transmitter
Existing Network
Golden Bough alternative not
consistent with small cell spacing
geometry
ATTACHMENT 8

Golden Bough
Looking Southwest
Drone photos show obstruction by trees next to Golden Bough, particularly southwest toward much of gap area
Looking Northwest
ATTACHMENT 8

Best Serving Transmitter
with Proposed Facility
Proposed facility provides new reliable
service to gap area
Golden Bough
ATTACHMENT 8

Small Cell Effects on Property
Valuations
Prepared for Carmel-by-the-Sea PC, February 10th 2024
David Witkowski, CEO, Oku Solutions LLC
[email protected]
+1-408-889-9741
ATTACHMENT 8

Assertions of Valuation Decrease
• Oft-cited “Up to 20%
reduction” is based primarily
on Bond/Wang in The
Appraisal Journal (2005).
– Sandy Bond was retained in the
late 90’s by a Christchurch NZ
neighbor group opposed to a
tower build.
– Bond’s method was a survey, not
a study of MLS or other data.

ATTACHMENT 8

Other Works re Valuation Decrease
• Other work claiming
valuation disamenity:
– Affuso et al. 2017,
Hale/Beck 2019, others
– Some (notably not all)
articles in NAR Realtor.

ATTACHMENT 8

Works re Valuation Amenity
• Some studies show
property valuation
increase or no effect:
– Smaqae / Anwar (2022),
Olukolajo et al. (2013),
Valbridge (2018), Maennig
(2012), others..

ATTACHMENT 8

Spatial Difference in Differences
• I authored a study on small
cell price effects using an
analysis by Ralph McLaughlin,
PhD in real estate economics.
• Study used 1,700+ small cell
builds and all 11.6 million real
estate transactions between
2010 – 2020, including Central
Coast sites.

ATTACHMENT 8

Spatial Difference in Differences
• To my knowledge, mine is
the only small cell study.

Others are macro-focused.
• The study showed no
economically-significant
negative impacts, and some
economically-significant
positive impacts, variable by
community.

ATTACHMENT 8

Design is PG&E Greenbook & GO 95 Compliant
Verizon confidential and proprietary. Unauthorized disclosure, reproduction or other use prohibited. • PG&E pole sides are described as
positions on a clock
o Street side is 6:00
o View looks directly at the pole at
7:30
• Drawing is based on attachment
heights provided by PG&E
• PG&E approved design/drawing:
o PG&E issued construction sketch
o PG&E issued contract
o PG&E application for pole
replacement includes drawing
(TEMP EN 250013 (PG&E -
Carmelo & 11th) PM# 35598210)
ATTACHMENT 8

Opposition Comments on Attachments
Verizon confidential and proprietary. Unauthorized disclosure, reproduction or other use prohibited.

What would happen if the
attachment heights changed?
• Mismatch of attachment heights
compared to other poles on the
street
• Other GO 95 infractions such as
blocking traffic (driveway)
ATTACHMENT 8

Impacts to the Adjacent Tree
Verizon confidential and proprietary. Unauthorized disclosure, reproduction or other use prohibited. • Met with PG&E job owner for this site, PG&E arborist, and City Staff at the site on February 4
• PG&E explained design, plans, and pole replacement scope • PG&E confirmed that the pole replacement work will have minimal impact to the health of the tree
ATTACHMENT 8

Golden Bough – Constructable, BUT DOES NOT WORK
Verizon confidential and proprietary. Unauthorized disclosure, reproduction or other use prohibited. • Met with Golden Bough and worked up
the best possible design for the location
• The design is constructable but does not
work for Verizon Wireless’s network
needs (wrong location and trees)
• Golden Bough has since requested
potential changes to the design and
location that would exacerbate the
reasons why the site does not work
• Those requested changes would violate
the City’s Codes
• The site does not work for Verizon
Wireless
ATTACHMENT 8

Verizon confidential and proprietary.Unauthorized disclosure, reproduction or other use prohibited.

Conclusion: Facts
• PierCon and CTC confirm service gap in Carmel-by-the-Sea • The proposed facility complies with City Code use permit and design review findings and wireless design guidelines
ATTACHMENT 8

Verizon confidential and proprietary.Unauthorized disclosure, reproduction or other use prohibited.

Conclusion: Law
• City cannot require a macro facility over a small cell (New York SMSA Ltd. Partnership v. Town of Clarkstown, 612 F.3d 97, 105-106 (2nd Cir. 2010))
• City cannot bar use of the right-of-way by a telecommunications company (Cal. Pub. Util. Code §7901)
• Requiring installation of a macro facility over a small cell materially inhibits network improvements through unreasonable delay and cost (TowerNorth Development, LLC v. City of Geneva, 2024 WL 621616, *24- 25 (N.D. Ill. Feb. 14, 2024))
• Evidentiary burden on City to prove that any alternative is less intrusive and “technically feasible” (T-Mobile USA, Inc. v. City of Anacortes, 572 F.3d 987, 998-999 (9th Cir. 2009))
ATTACHMENT 8

Verizon confidential and proprietary. Unauthorized disclosure, reproduction or other use prohibited.

Pete Shubin, Sequoia Deployment Services
Jay Gruendle, Program Manager, Verizon Small Cells
Jeremy Stroup, Verizon Municipal Engagement Partner
Rich Conroy, PierCon Solutions
David Witkowski, Oku Solutions
Paul Albritton, Mackenzie & Albritton LLP
ATTACHMENT 8

MACKENZIE & ALBRITTON LLP
155 SANSOME STREET, SUITE 620
SAN FRANCISCO, CALIFORNIA 94104
TELEPHONE 415 / 288-4000
FACSIMILE 415 / 288-4010
October 14, 2025

VIA EMAIL
Planning Division
City of Carmel-by-the-Sea
Monte Verde Street
Carmel-by-the-Sea, California 93921
Re: Verizon Wireless Application
Small Wireless Facility, Carmelo Street
To Whom It May Concern:

We write on behalf of Verizon Wireless regarding the accompanying application for a small wireless facility on Carmelo Street north of 11th Avenue (the “Application”). This letter supplements the Application with information regarding two special exception requests, as required by the City’s Wireless Facility Application Checklist, Section 15.1.

Verizon Wireless’s proposed facility complies with the Carmel-by-the-Sea Municipal Code (the “Code”) and Administrative Detailed Wireless Facility Design Guidelines (the “Guidelines”), except for two Code standards. The proposed location is:

1. Within the right-of-way in the R-1 single-family residential zone (Code §

17.46.040(E)(1)(a)), and

2. In front of area five feet in either direction from centerline of residential door or window (Code § 17.46.040(E)(2)(a)).

Verizon Wireless requests special exceptions to these requirements in accordance with Code Section 17.46.080(C). The City must approve these special exceptions because denial of the Application would constitute an effective prohibition of service in violation of the federal Telecommunications Act. Further, denial would contradict California Public Utilities Code Section 7901, which grants telephone corporations a statewide franchise right to place their equipment along any right-of-way. Verizon Wireless reserves its rights to challenge the requirements to request special exceptions to preempted or excessive standards, and the general preference to place wireless facilities in the right-of-way, regardless of any availability of private property.

Exhibit E
ATTACHMENT 8

Planning Division
City of Carmel-by-the-Sea
October 14, 2025

Separately, we confirm that the proposed equipment shroud is allowed on the utility pole because an underground vault is infeasible, per the equipment location preferences of Design Guidelines Section II(C)(1).

I. The Proposed Facility Satisfies the Findings for Special Exceptions.

The City must grant the four special exceptions based on the three findings of Code Section 17.46.080(C)(2), as follows.
a. The applicant has shown that denial of an application will result in an effective prohibition or otherwise violate Federal law; or the applicant has shown that denial of an application will violate State law; or the applicant has shown that it is a minor deviation that achieves all of the applicable design objectives of this chapter, as well as, or better than, would be achieved by adherence to the adopted design guidelines.

1. Denial Would Violate the Federal Telecommunications Act.

Denial of a facility because it is located in an R-1 zone right-of-way would constitute an effective prohibition of service in violation of the federal Telecommunications Act. 47 U.S.C. § 332(c)(7)(B)(i)(II). The proposed facility will be a “personal wireless service facility” providing “personal wireless services,” which include “commercial mobile services,” defined as “any mobile service…that is provided for profit and makes interconnected service available (A) to the public or (B) to such classes of eligible users as to be effectively available to a substantial portion of the public, as specified by regulation by the Commission.” 47 U.S.C. §§ 332(c)(7)(C), 332(d)(1).

A local government’s denial of a personal wireless facility is an “effective prohibition” if the wireless provider can show two things: (1) that it has a “significant gap” in service; and (2) that a proposed facility is the “least intrusive means,” in relation to the land use values embodied in local regulations, to address the gap. See T-Mobile USA, Inc. v. City of Anacortes, 572 F.3d 987 (9th Cir. 2009). If a provider proves both elements, the local government must approve the facility, even if there is substantial evidence to deny the permit under local land use provisions (which there is not in this case). This is because the provider has met the requirements for federal preemption, i.e., denial of the permit would “have the effect of prohibiting the provision of personal wireless services.” 47 U.S.C. § 332(c)(7)(B)(1)(ii); T-Mobile v. Anacortes, 572 F.3d at 999.

Verizon Wireless engaged independent engineering firm PierCon Solutions to conduct a drive test and evaluate service in the gap area. On February 19, 2025, a PierCon engineer drove a vehicle along local roadways in west Carmel, with an antenna mounted outside the vehicle connected to equipment that measured signal level and other parameters. PierCon compiled the drive test data and prepared a report, submitted ATTACHMENT 8

Planning Division
City of Carmel-by-the-Sea
October 14, 2025

separately. PierCon confirmed the gap in Verizon Wireless network coverage and capacity in the area. PierCon also confirmed that a new small cell is required to introduce new services, improve existing services and network capacity, and add 5G service.

Verizon Wireless’s Alternatives Analysis confirms that the proposed facility is the least intrusive, feasible means to fill the significant gap, based on the Code’s applicable location preferences and standards.

For wireless carriers to establish a prohibition of service case, federal law does not require that a proposed facility be the “only” alternative, but rather that no feasible alternative is less intrusive based on local regulations. See Metro PCS, Inc. v. San Francisco, 400 F.3d at 734-35. To avoid federal preemption, the City would need to raise another alternative that is available, technologically feasible, and less intrusive than the proposed facility according to the Code, then allow Verizon Wireless to review that alternative. T-Mobile v. Anacortes, 572 F.3d at 998-999.

In a 2018 order, the FCC determined that the Ninth Circuit’s two-part test is too narrow and confirmed that a wireless carrier need not show an insurmountable barrier, or even a significant gap, to prove a prohibition of service. See Accelerating Wireless Broadband Deployment by Removing Barriers to Infrastructure Investment, Declaratory Ruling and Third Report and Order, 33 FCC Rcd. 9088, ¶¶ 35, 38 (September 27, 2018).

Instead, “a state or local legal requirement constitutes an effective prohibition if it ‘materially limits or inhibits the ability of any competitor or potential competitor to compete in a fair and balanced legal and regulatory environment.’” Id., ¶ 35. State or local regulations are preempted if they materially inhibit “densifying a wireless network, introducing new services, or otherwise improving service capabilities.” Id., ¶ 37. The FCC determined that the coverage gap approach is incompatible where new wireless facilities are installed to add network capacity. Id., ¶ 40.

The Ninth Circuit Court of Appeals upheld the “materially inhibit” standard for a prohibition of service and the FCC’s application of the standard to wireless facilities including small cells that provide 5G service, such as Verizon Wireless’s proposed facility. See City of Portland v. United States, 969 F.3d 1020, 1035 (9th Cir. 2020), cert. denied, 141 S.Ct. 2855 (Mem) (U.S. June 26, 2021) (“The FCC here made factual findings, on the basis of the record before it, that certain municipal practices are materially inhibiting the deployment of 5G services.”) In adopting and applying the FCC’s “materially inhibit” standard, another federal appeals court recently confirmed, “not only does ‘insufficiency in coverage’ ordinarily entitle a provider to a variance but so does insufficiency in network capacity, 5G services, or new technology.” Cellco Partnership v. White Deer Township Zoning Hearing Board, 74 F.4th 96, 106 (3rd Cir. 2023).

As noted, the PierCon report demonstrates that the proposed facility will improve service in western Carmel, densify the network with another facility, add network ATTACHMENT 8

Planning Division
City of Carmel-by-the-Sea
October 14, 2025

capacity, and introduce 5G service to the area. Thus, denial of the application would “materially inhibit” Verizon Wireless’s ability to compete in a fair and balanced legal and regulatory environment, effectively prohibiting service in violation of the Telecommunications Act.

2. Denial Would Violate California Public Utilities Code Section 7901.

Denial of the Application would violate California Public Utilities Code Section 7901, which grants telephone corporations a statewide right to place their equipment along any right-of-way. In particular, Section 7901 preempts the Code’s restriction of facilities in the R-1 zone right-of-way.

For over a century, the California Supreme Court has confirmed that Public Utilities Code Section 7901 grants telephone corporations a statewide franchise right to place telephone equipment in the right-of-way without charge. See Western Union Tel. Co. v.

Hopkins, 160 Cal. 106, 123 (Cal. Sup. Ct. 1911) (statute grants “exclusive occupation of portions of the streets…free of charge”); Pacific Tel. & Tel. Co. v. City & Cty. of San Francisco, 51 Cal.2d 766, 771 (Cal. Sup. Ct. 1959) (statute “gives a franchise from the state to use the public highways for the prescribed purposes without the necessity for any grant by a subordinate legislative body”).

The Supreme Court confirmed this statewide franchise right in 2019. T-Mobile West LLC v. City and County of San Francisco, 6 Cal.5th 1107, 1122 (Cal. Sup. Ct. 2019) (“Any wireless provider may construct telephone lines on the City’s public roads so long as it obtains a permit, which may sometimes be conditioned on aesthetic approval”). Local aesthetic review cannot preclude placement of right-of-way facilities, because the court confirmed that a city cannot deprive a telephone corporation of its statewide franchise right to place equipment in the right-of-way. Id. at 1120.

The FCC’s “materially inhibit” standard described above is based on two Telecommunications Act provisions barring a prohibition of service. Infrastructure Order, ¶¶ 36, 82. One of these, Section 253(c), reserves the authority of state governments to manage the public rights-of-way, which the FCC found “includes any conduct that bears on access to and use of those ROW.” 47 U.S.C. § 253(c); Infrastructure Order, ¶ 94. Through Section 7901, California has long granted telephone corporations a statewide right to use the right-of-way with no local franchise requirement.

The City’s management of the right-of-way through the restriction in the R-1 zone is curtailed by state law.

State law is long settled on this matter. Most Carmel rights-of-way are within the R1 zone. Steering a proposed wireless facility to a distant right-of-way in a different zone or denying a proposed facility based on unreasonable aesthetic criteria would deprive Verizon Wireless of its franchise right granted by Section 7901 to use any right-of-way.

ATTACHMENT 8

Planning Division
City of Carmel-by-the-Sea
October 14, 2025

In sum, to avoid violations of federal and state law, and to allow Verizon Wireless to compete in a fair and balanced legal and regulatory environment, the City must grant the exception requests.
b. The special exception requested by the applicant does not compromise or excuse compliance with any fire safety or other public health and safety requirements.

Granting the two special exceptions to the relevant location standards will not compromise public or fire safety standards. Wireless facilities mounted on electric utility poles are subject to stringent safety requirements of California Public Utilities Commission General Order 95, including required clearances mandating that antennas and their mounting hardware be elevated at least six feet above electric conductors.

General Order 95 Rule 94.4. They are also subject to PG&E safety rules. See, e.g., PG&E Installation Details for Service to Pole-Mounted Communication Equipment, Document 027911 Rev #15, June 30, 2023. PG&E will inspect the proposed facility to ensure compliance with applicable safety regulations.

Neither of the two standards requiring an exception bear any relation to fire, health, or safety standards. Small cells are commonly placed in rights-of-way throughout California within residential zones and window viewsheds. c. The special exception is narrowly tailored such that any deviation from the requirements of this chapter is only to extent necessary for compliance with Federal or State law or to achieve all of the applicable design objectives of this chapter, as well as, or better than, would be achieved by adherence to the adopted design guidelines.

We address this finding with respect to each of the two exception requests, as follows.

1. Within the R-1 single-family residential zone (Code § 17.46.040(E)(1)(a)) Any facility in an R-1 zone right-of-way automatically requires a special exception per Code Section 17.46.040(E)(1). Verizon Wireless is complying by requesting the special exception, which the City requires to ensure that it avoids a violation of the federal Telecommunications Act and California Public Utilities Code Section 7901. As explained above, failure to grant an exception would constitute a prohibition of service under the Telecommunications Act, because the proposed facility is the least intrusive feasible alternative to provide coverage to a significant gap in Verizon Wireless service, and denial would materially inhibit Verizon Wireless’s ability to provide service. Further, denial would deprive Verizon Wireless of its state-mandated right to install its equipment in any public right-of-way for the provision of telephone services according to California Public Utilities Code 7901.

ATTACHMENT 8

Planning Division
City of Carmel-by-the-Sea
October 14, 2025

2. In front of area five feet in either direction from centerline of residential door or window (Code § 17.46.040(E)(2)(a))
The proposed replacement utility pole is in the public right-of-way, with the center of the pole located 23 feet, 7 inches from the closest window. Using an existing utility pole location avoids the need for a new pole, which is the least compatible structure option according to the Code. Code § 17.46.040(D)(2). The small, two-foot cylindrical antenna will be mounted above the pole, with a total height of 48 feet 10 inches, well above any residential sight lines. The existing tree adjacent to the utility pole will screen the proposed facility equipment shroud, as shown in Verizon Wireless’s photosimulations. Accordingly, the Proposed Facility location and design satisfy the objectives of Code Chapter 17.46, notably by minimizing adverse aesthetic impacts and preserving residential character. Code § 17.46.010(B)(4).

Verizon Wireless’s Alternatives Analysis evaluates 28 utility poles in the right-ofway and concludes that the proposed facility is the least intrusive, feasible option.

Numerous other poles are infeasible. For example, PG&E rules do not allow an antenna on the utility pole north of the proposed facility because it supports a transformer. The pole to the south is clustered with a second pole, both supporting risers, and one pole supports a large pole-mounted cabinet, leaving insufficient safe climbing space for utility workers.

Of the 12 feasible alternative poles in the search area, six are also within the area five feet in either direction of the centerline of a residential door or window. The other six require more exceptions than the Proposed Facility, so are more intrusive overall.

II. The Proposed Facility Complies with the Equipment Placement Preferences.

For right-of-way facilities, the Administrative Detailed Wireless Facility Design Guidelines express a preference first for equipment in an underground vault, then equipment in a pole-mounted shroud less than six cubic feet, then a shroud more than six cubic feet. Design Guidelines § II(C)(1). In its vaulting analysis accompanying the application, Verizon Wireless explains that an underground vault is infeasible at the proposed location for several reasons. For example, the large excavation area required to install a vault would result in the loss of on-street parking. It would also interfere with the existing trees, tree roots, and underground utilities in the area.

Because vaulting is infeasible, Verizon Wireless may install a pole-mounted equipment shroud per Design Guidelines Section II(C)(1). The second equipment placement preference is a shroud less than 6 cubic feet, but that is infeasible to contain the volume of network equipment requirement required for the proposed facility to fill a significant gap in service: two radios, a fiber demarcation box, two power supply units, and a cable diplexer. A shroud must also provide clearance around each piece of equipment for cables, connections, worker access, and air circulation. Verizon must ATTACHMENT 8

Planning Division
City of Carmel-by-the-Sea
October 14, 2025

install a shroud more than 6 cubic feet, which is allowed as the third equipment placement preference.

To safely accommodate all of the equipment as required by the California Public Utilities Commission and PG&E, Verizon Wireless selected a 14.5-cubic foot equipment shroud available from a manufacturer, typically used for small cells mounted to utility poles. Plans Sheet A-5 includes a detailed elevation depicting the equipment layout and clearances within this 14.5-cubic foot shroud, illustrating how a shroud of only six cubic feet—less than half the required volume—is infeasible.

Because an underground vault and a shroud less than 6 cubic feet are infeasible, the City must approve the 14.5-cubic foot pole-mounted shroud per the equipment placement preferences. No special exception is required.

In the alternative, the City could approve the shroud because it “is more consistent with existing poles and the surrounding environment.” Design Guidelines § II(C)(1).

Carmel streets are lined with utility poles supporting fixtures such as electric transformers and utility lines, and the proposed facility will place new utility equipment on this existing utility infrastructure. In fact, the utility pole due south of the proposed facility, at the corner of Carmelo Street and 11th Avenue, supports a large pole-mounted utility cabinet, as shown in the Alternatives Analysis (Alternative 10). Accordingly, the proposed facility would be consistent with existing development in the area.

Verizon Wireless looks forward to working with the City to secure approval of the Application.

Very truly yours,

Paul B. Albritton
ATTACHMENT 8

Independent Radio Frequency Report
Regarding a Proposed
Verizon – Small Cell
Wireless Facility
Site ID: “Carmel Node 001”
Carmelo Street
Carmel-by-the-Sea, CA 93921
Monterey County
Prepared for
Verizon Wireless
By
PierCon Solutions, LLC
October 14, 2025
10 PARK PLACE BUILDING 6C SUITE 402 , BUTLER , N J 0 7405 PHONE 973 - 628 - 9330 Exhibit F
ATTACHMENT 8

TABLE OF CONTENTS
EXECUTIVE SUMMARY ........................................................................................................................................ 3 1 PURPOSE AND SCOPE..................................................................................................................................... 4 2 GENERAL OVERVIEW.................................................................................................................................... 4 3 SERVICE & PERFORMANCE GOALS.......................................................................................................... 6 4 RADIO FREQUENCY ENGINEERING ACTIVITIES PERFORMED....................................................... 7 5 VERIZON’S EXISTING NETWORK IN THE AREA SURROUNDING THE SUBJECT SITE.............. 8 6 INDEPENDENT DRIVE TEST ANALYSIS.................................................................................................... 8 7 KEY PERFORMANCE INDICATORS........................................................................................................ 13 8 VERIZON’S PROPOSED SOLUTION .......................................................................................................... 16

8.1 ALTERNATIVE SITES .................................................................................................................................... 17

8.2 LEAST INTRUSIVE........................................................................................................................................ 19 10 CONCLUSION................................................................................................................................................ 21 10 APPENDIX 1 - EXHIBITS.............................................................................................................................. 23 11 APPENDIX 2 – 3GPP LINK BUDGET.......................................................................................................... 24 12 APPENDIX 3 – DRIVE TEST DATA - TABLE FORMAT......................................................................... 25 ATTACHMENT 8

EXECUTIVE SUMMARY
Purpose and Scope
PierCon Solutions, LLC performed an independent radio-frequency engineering analysis on Verizon Wireless’s proposal to install a small-cell telecommunications facility on Carmelo Street between 10th and 11th Avenues in Carmel-by-theSea. The project’s objective is to improve overall 4G LTE service, densify the network, and introduce new 5G C-band (3700 MHz) service, to remedy a significant service gap within a densely populated residential area.

Engineering Approach
PierCon conducted an independent drive test on February 19, 2025 using a calibrated PCTEL IBFLEX scanner (600 MHz–6 GHz) and analyzed Verizon’s Key Performance Indicator (KPI) data from November 2024 through February 2025. Supporting data included topographical reviews, FCC-licensed spectrum analysis, and EDX Signal Pro simulations.

Key Findings
• Low Band (700/850 MHz): 73% of the test area showed SINR <10 dB, 43% <= 5 dB, and 10% <0 dB— indicating poor signal quality despite acceptable RSRP. The significant gap covers approximately 0.43 sq mi (~1,059 residents).
• Mid Band (1900/2100 MHz): Reliable in-building RSRP not met across approximately 0.27 sq mi (~776 residents). 73% of the area <10 dB SINR, and 9% ≤0 dB—total gap approximately 0.39 sq mi (~994 residents).
• 5G C-Band (3700 MHz): Nearly no in-building 5G coverage; gap approximately 0.47 sq mi (~1,224 residents).

Even post-activation of nearby nodes, geometry would still require a new facility.

Performance Metrics (KPIs):
• Founders Building Beta Sector:
o 700 MHz drop-call >1% for 93% of busy hours (peaks >20%) o 850 MHz VoLTE drop call >1% for 58% of time
o 1900 MHz VoLTE drop call >1% for 56% of time
o Throughput <5 Mbps 88% (700), 10% (850), 39% (1900)
• SF South Carmel 003 Alpha Sector: 700 MHz drop-call >1% for 47% of busy hours (peaks >18%).

These results confirm service below Verizon’s 5 Mbps target and the FCC’s 2024 mobile-broadband benchmark of 35 Mbps per user for 5G services and 7 Mbps for 4G services.

Proposed Solution
Verizon proposes a 50-ft small cell (antenna CL ≈48.7 ft) to be installed on an existing utility pole. The new site would provide reliable in-building mid-band coverage to approximately 0.10 sq mi (~372 residents)—addressing 37% of the ATTACHMENT 8

identified gap. Combined with the approved SF South Carmel 002 site (0.07 sq mi / 201 residents), the two facilities will cover 62% of the mid-band gap and serve 74% of its population.

Alternatives & Least-Intrusive Analysis
Golden Bough Playhouse Alternative: Provides significant redundant overlap and covers 6–11% less area than the proposed site. RF modeling shows increased interference and poorer performance.

Siting Constraints: Among 40 utility poles evaluated, only 6 met RF, code, and topographic requirements. The chosen pole #1 (between 10th and 11th Avenues) is nearest the geometric center of the gap and offers the least visual impact.

Conclusion
Empirical drive-test data and KPI analysis demonstrate a significant service deficiency in Verizon’s network throughout the Carmelo Street corridor. The proposed small cell is technically essential, least intrusive, and well-positioned to deliver reliable in-building LTE and 5G coverage while maintaining Carmel’s aesthetic and zoning standards. Once implemented, the facility will substantially improve signal quality, reduce VoLTE drop calls, enable carrier aggregation, and restore network competitiveness.
1 PURPOSE AND SCOPE
PierCon Solutions LLC, an engineering firm specializing in wireless communications, performed an independent analysis regarding the radiofrequency engineering aspects of the proposal by Verizon Wireless to construct and operate a small cell wireless telecommunications facility consisting of one antenna at Carmelo Street, between 10th and 11th Avenue, Carmel-by-the-Sea, CA. The purpose of this site is to improve overall service on Verizon’s network, introduce new 5G services through deployment of Verizon’s licensed 3700 MHz band, densify the existing network, and to remedy a significant gap in service.

In preparation for conducting this analysis, PierCon Solutions obtained applicable engineering data from Verizon Wireless, and conducted an independent drive test of the surrounding areas.

The following report results from a thorough independent study and analysis (from a radiofrequency engineering perspective) of the applicant’s proposal and provides justification for the site in consideration of Carmel-by-the-Sea’s planning commission’s goals and restrictions.
2 GENERAL OVERVIEW
Verizon Wireless is a commercial wireless communications service provider licensed by the Federal Communications Commission (FCC) to provide wireless service in various frequency bands throughout the Carmel-by-the-Sea area and Monterey County, CA. The frequency bands to which Verizon Wireless is licensed are the 700, 850, 1900, 2100, and 3700 MHz frequency bands.

ATTACHMENT 8

The wireless telecommunications small cell1 facility proposed in this application is to provide reliable service for voice and data in the form of 4G2 LTE and 5G3 technology, deploying the mid band frequencies available, where bandwidth is the most abundant.

Table 1 below provides the Verizon Wireless licensed frequencies and bandwidths in Monterey County:

Table 1
Frequency Band Bandwidth
700 MHz 10 MHz
850 MHz 10 MHz
1900 MHz 5 MHz
2100 MHz 25 MHz
3700-3900 MHz 140 MHz
As can be seen from Table 1, Verizon is licensed for total of 20 MHz of “Low-Band” bandwidth in the 700 MHz and 850 MHz frequency bands. These frequency bands are commonly referred to as low band frequencies and will be referred to as such in this report. Additionally, Verizon is licensed for a total of 170 MHz of “Mid-Band” bandwidth in the 1900 MHz, 2100 MHz and 3700 MHz bands. These frequency bands are commonly referred to as mid band frequencies and will be referred to as such in this report.

Each frequency band has different performance characteristics for both coverage and capacity. From a coverage perspective, the lower frequency bands (700 & 850 MHz) cover a greater distance and are less attenuated by trees and terrain, while the higher frequency bands (1900, 2100, 3700 MHz) cover a lesser distance and are more attenuated by trees and terrain. From a capacity perspective, each frequency band offers a finite amount of spectrum bandwidth. It is through this bandwidth that capacity and throughput is supported. A well designed wireless network is required to provide both reliable coverage levels and sufficient bandwidth, maximizing the spectrum and bandwidths that have been procured for use from the FCC. The purpose of the proposed site is to improve overall service on Verizon’s 1 The FCC defines a small wireless facility as (i) mounted on a structure less than 50 feet in height, (ii) each antenna is no more than three cubic feet in volume; and (iii) all other equipment on the structure must be less than 28 cubic feet in volume. The City of Carmel-by-the-Sea’s Administrative Detailed Wireless Facility Design Guidelines restrict the volume of accessory (non-antenna) equipment for right-of-way facilities to 17 cubic feet, which limits the number of radios that can be installed for the Proposed Facility. 2 4G technology known as Long Term Evolution (LTE) is a wireless communications standard developed by the 3rd Generation Partnership Project (3GPP) that is designed to provide up to 30x the speeds of 3G networks for mobile devices such as smartphones, tablets, netbooks, notebooks and wireless hotspots. The LTE specification provides theoretical downlink peak rates of 300 Mbps, uplink peak rates of 75 Mbit/s and QoS provisions permitting a transfer latency of less than 5 ms in the radio access network. Current industry standard is to provide a minimum downlink user throughput of 5 Mbps. LTE is the current wireless technology allowing for high speed data, support of data demanding applications, implementation of the internet of things (IoT) and the foundation for 5G networks. 3 The Fifth Generation of Mobile Telephony, or 5G, or 5GS, is the system defined by 3GPP from Release 15, functionally frozen in June 2018 and fully specified by September 2019. 5G improves on the 4G services over several areas such as: (1) Enhanced Mobile Broadband (eMBB) offering higher data rates up to 500 Mbps downlink outdoor and 1 Gbps for indoor (5GLAN); (2) Critical Communications (CC) and Ultra Reliable and Low Latency Communications (URLLC) includes remote control of process automation, 99.9999% reliability, user experience data rate of 100 Mbps and end-to-end latency of 50 ms. (3) Massive Internet of Things (mIoT) through supporting very high traffic densities of devices. (4) Flexible Network Operations such as network slicing, network capability exposure, scalability, diverse mobility, security, efficient content delivery and migration and interworking.

ATTACHMENT 8

network, introduce new 5G services through deployment of Verizon’s licensed 3700 MHz band, densify the existing network, and to remedy a significant gap in service.

Long-Term Evolution (LTE), also known as 4G, is the current technology standard. Migration to 5G, which is the next generation network, is currently in progress. When engaging in a voice call, the user device will connect to the public switched telephone network (PSTN) through a gateway in order to complete a call to a non-LTE or non-5G device. For example, a person making an emergency E9114 call from a mobile device to a public safety operator on a landline, such emergency calls will be routed through the PSTN.
3 SERVICE & PERFORMANCE GOALS
Service and performance goals are necessary to provide reliable wireless services across all of Verizon’s FCC licensed frequency bands and technologies. Service and performance goals include providing adequate coverage and capacity for voice and data services, preparing to provide future services, and otherwise improving service capabilities.

Service goals are designed to provide all customers with a positive wireless voice and data experience. Simply put, a positive wireless experience includes the customer connecting to the network on the first try, staying connected throughout the session, and the customer ending the session when ready. For positive experiences with data connections (e.g., internet browsing) the speed is as fast as the technology allows. Unreliable service, meaning service levels that do not meet service and performance goals, causes a negative experience: customers cannot place calls when they want to; when they are connected, voice call quality does not meet customer expectations; or the call simply drops off (disconnects) without notice.

Unreliable service that fails to meet service and performance goals, which include voice and/or data services, can occur if there is: (i) a lack of reliable signal, including poor signal quality; and/or (ii) a lack of a dominant serving transmitter; and/or (iii) a lack of system capacity, or in terms of LTE, insufficient throughput, for any of Verizon’s services and across all of Verizon’s licensed frequency bands. Providing quality in-building voice and data services, with sufficient system capacity and high-speed data rates, is critical to Verizon’s customers and is essential to Verizon’s ability to compete effectively with its competitors in a fair and balanced legal and regulatory environment.

Verizon’s service and performance goals for this area are to provide reliable in-building residential wireless service and provide new 5G services. The information provided in this report demonstrates that the existing wireless sites do not provide adequate signal strength or adequate signal quality to the area, causing a significant gap in coverage. The report will also show that 5G services are not currently deployed in the area and users will benefit from the addition.

Verizon’s specific design and performance requirements are to:
• Provide reliable residential in-building coverage to residential homes to the Carmelo Street area of Carmel-bythe-Sea between 6th Avenue and Santa Lucia Avenue, and between San Antonio Avenue and San Carlos Street.

Reliable residential in-building coverage is defined as a reference signal receive power (RSRP) greater than or equal to -95 dBm5.
4 E911, or Enhanced 911, is a system that automatically identifies the location of a 911 caller and transmits that information to the emergency dispatch center. This system is designed to improve the efficiency and effectiveness of emergency responses by providing dispatchers with accurate location information.
5 Verizon Wireless’ minimum design signal levels used for reliable in-building residential coverage is consistent with the 3rd Generation Partnership Project (3GPP) published values. Attached as Appendix 2 is a link budget demonstrating the necessary criteria and the cited standard references.

ATTACHMENT 8

• Provide for service that meets or exceeds various metrics with regards to key performance indicators, related to VoLTE drop call rates, downlink throughput, and utilization rates to name a few.

Verizon has chosen to meet the service and performance goals above by proposing a small cell in west Carmel-by-theSea. Verizon’s current wireless network in the immediate area consists of one macro site and one outdoor small cell, with two other small cells approved but not yet constructed. With the anticipated coverage and capacity to be provided by the two approved small cells, the overall service gap area expected to be remaining is a smaller portion of the original overall gap area. Verizon’s intent is to address the remaining service gap area, maximizing available spectrum, and minimize the need for large macro wireless facilities.

Macro sites are intended to enhance the wireless network by the use of multiple antennas-(typically 9 to 12) placed at significant heights to achieve broad area coverage. The installation of a macro site requires: sufficient structure space for the antenna array, sufficient building or ground space for the transmitter equipment cabinets, battery backup, emergency generator, and requires commercial grade electrical service and sufficient backhaul infrastructure-often in the means of new fiber installation or microwave antennas. Macro site deployments must meet local and state code requirements, often requiring variances for height, setback, and other specific items to achieve the desired RF coverage. These sites are often seen as the most intrusive means to meet RF performance and coverage objectives, as the antenna array and equipment do not easily blend into the natural aesthetics of a single family residential area. These requirements have traditionally limited the locations for efficient RF designed networks, requiring augmentation in the form of alternate approaches to address coverage and capacity needs. Additionally, as demand for data escalated, the limitations of traditional macro deployments became clear, and the need for network densification emerged.

The coverage and capacity to be provided from the proposed small cell site is expected to meet the design and performance objectives in the least intrusive means, and be part of an overall integrated network solution, working together with the other approved small cells in the area. The proposed small cell is intended to improve existing services, densify the existing network, and offer new services in the form of 5G. 4 RADIO FREQUENCY ENGINEERING ACTIVITIES PERFORMED
The following items were performed, reviewed, and considered in preparation of this report:
• Performed an independent drive test of the subject and surrounding area • Reviewed Radio Frequency coverage maps with respect to the RF design and objective within and surrounding Carmel
• Obtained Verizon Key Performance Indicator (KPI) information for the existing sites • Reviewed USGS Topographical Maps of Carmel-by-the Sea and surrounding areas • Performed Google Earth aerial and street view analysis • Reviewed the location and design of adjacent existing wireless communications facilities • Reviewed proposed and possible alternate site locations • Created maps, tables and charts illustrating pertinent site performance information ATTACHMENT 8

5 VERIZON’S EXISTING NETWORK IN THE AREA SURROUNDING THE SUBJECT SITE Attached as Exhibit A is a Verizon Site Table. The site table includes the Site Name, Frequency Bands / Technology, Antenna Height (ft.), Sector Azimuths, and Latitude, Longitude. This Site Table can be referenced to any of the plots and exhibits contained herein.

Attached as Exhibit B is Verizon’s Site Distance Map. Exhibit B depicts the locations of the surrounding sites and the proposed site as well as the distance away from the proposed site. Verizon has four macro sites currently operating in the area, identified as Downtown Carmel, Pebble Beach Tennis Club, Founders Building, and Chomp Macro. Macro sites are intended to provide coverage to an area, using multiple transmitters and antennas, or sectors. Macro sites typically deploy three to four sectors to allow equal distribution of coverage and capacity. In the area of the proposed site, the closest existing macro site, Downtown Carmel at a distance of 0.45 miles, does not provide adequate coverage to the dense residential area, due to its limited building height of 33 feet above ground. Verizon has decided to address the coverage deficiencies in the area by implementing small cells. Small cells are limited in height, coverage, and spectrum resources, and therefore more small cells are required to address a service gap when compared to a macro site.

The proposed site is located on Carmelo Street which is in the middle of a densely populated residential community and located approximately equally between the SF South Carmel 003 small cell (0.33 mi), Downtown Carmel (0.45 mi.), and the approved SF South Carmel 002 small site (0.38 mi). The neighborhood predominantly consists of medium to large single-family homes, with dense vegetation and mature trees throughout. Ground elevation ranges from 79 feet at the proposed site location to 39 feet along scenic road to the west, and 180 feet on San Carlos Street to the east. Ground elevation also changes from the proposed site at 79 feet heading north on Carmelo Street, reaching 102 feet between 10th Avenue and 9th Avenue, dropping to 85 feet at 9th Avenue, then rising to an elevation of 125 feet between 8th Avenue and 7th Avenue. Elevation along Carmelo Street steadily declines heading south to 68 feet at Santa Lucia Avenue.
6 INDEPENDENT DRIVE TEST ANALYSIS
In this report, we utilized actual drive test maps to scientifically and reliably demonstrate that there is a significant Service Gap in accordance with industry methodology and standards.

Drive tests are a means to evaluate existing coverage. Drive tests are used to produce maps (“Drive Test Maps”), which demonstrate actual signal levels along roadways that are traveled by specially equipped scan test vehicles. In a drive test, the signals from the surrounding on-air sites are collected by a receive antenna mounted to the roof of the drive test vehicle. The data collected by the receive antenna is then processed by computer equipment within the drive test vehicle. The coordinates and signal strength of each collection point are recorded by the computer equipment and ultimately depicted on a Drive Test Map. Literally thousands of data points are collected during a drive test over the roadways driven by the drive test vehicle to ensure that a complete and statistically relevant number of data points can be evaluated6.

PierCon Solutions performed an independent drive test7 of the wireless carrier networks in and around Carmel on February 19th, 2025. This test was conducted using a calibrated PCTEL IBFLEX scanning receiver, capable of scanning 6 Multiple values are collected for any lat long location by the drive test software. PierCon uses the best value measured for any given location in this analysis, i.e., the strongest RSRP values and the largest SINR values. 7 The Verizon Wireless drive test results are provided in table format in Appendix 3 per 15.2.1.a. of the Wireless Application Checklist. Drive test data is provided for 700 MHz, 850 MHz, 1900 MHz, 2100 MHz, and 3700 MHz, which includes signal strength in RSSI and RSRP, among other data collected. The PCTEL IBFLEX receiver recorded RSSI only for the 3700 MHZ band, and the RSRP values shown in Exhibit E are calculated.

ATTACHMENT 8

frequencies from 600 MHz to 6 GHz. Equipment was connected to a laptop computer, including a GPS antenna and multi-band receive antenna mounted on the rooftop of the vehicle. The vehicle was driven along the drive route in the vicinity of the subject site and surrounding areas which is represented by the drive test plots. The drive test factors signals from all Verizon’s facilities currently on air.

LTE (4G) networks utilize reference signal power (RSRP) to define coverage. Verizon’s coverage design thresholdconsistent with 3GPP published values- has determined that a design threshold RSRP of equal to or greater than -95 dBm is necessary for reliable residential in-building LTE service, and a RSRP of less than -95 dBm but greater than or equal to -105 dBm is necessary for reliable in-vehicle LTE service. Although in-vehicle levels are shown, in the modern wireless service market, reliable residential in-building service is necessary.

Low Band Drive Test Analysis
Attached as Exhibit C is a: Verizon Wireless 700 MHz LTE (4G) Drive Test Map that demonstrates the results of a drive test performed for the purpose of evaluating existing 4G (LTE) coverage in the vicinity of the Proposed Site. The map represents 4G (LTE) reference signal strength in the 700 MHz band. The map identifies measured RSRP levels as in the table below. Verizon’s goal is to provide reliable LTE in-building residential service to the Service Gap area.

Color RSRP (dB) Signal Strength Level
Blue -95 <= X Minimum threshold in-building residential Green -105 <= X < -95 In-vehicle minimum threshold
Yellow -110 <= X < -105
Grey -115 <= X < -110
Black 150 <= X < -115
Also attached is Exhibit C1, which is a modified version of Exhibit C, providing the necessary drive test map requested in the City’s wireless application checklist8. Exhibit C1 provides a signal strength map illustrating RSRP levels greater than or equal to -95 dBm as blue circles, RSRP values less than -95 dBm and greater than or equal to -98 dBm as green circles, RSRP values less than -98 dBm and greater than or equal to -101 dBm as yellow circles, RSRP levels less than - 101 dBm and greater than or equal to -104 dBm as grey circles and RSRP values less than -104 dBm as black circles.

As noted in Table 1 above Verizon has over eight times more spectrum bandwidth at the mid-band frequencies compared to the low-band frequencies. This means most services and users will be operating on the mid-band frequencies. As demonstrated by Exhibit C, the RSRP levels in the 700 MHz frequency band are within the design objective for in-building residential service. While RSRP is an important factor, it is not the only factor that determines if there is service. Even with adequate RSRP, if there are high levels of interference from neighboring cells, the overall signal quality can be negatively affected. Interference can result in slower data rates, dropped calls, and reduced overall 8 Carmel-by-the-Sea’s planning commission adopted standard submission requirements for applicants claiming a significant gap in service. The requirement as outlined in the Wireless Application Checklist section 15.2.1 includes providing drive test data for relevant frequencies in a table format, and also graphically. The graphical drive test data is to be provided showing the minimum signal strength required, and three additional levels, binned in 3 dB levels. The PierCon independent drive test data presented in this report provides on a single map the signal strengths greater than or equal to -95 dBm RSRP (Verizon minimum in-building residential signal strength), RSRP values less than -95 dBm and greater than or equal to -98 dBm, RSRP values less than -98 dBm and greater than or equal to -101 dBm, RSRP levels less than -101 dBm and greater than or equal to - 104 dBm, and RSRP values less than -104 dBm.

ATTACHMENT 8

performance. This will also vary throughout the day as usage increases, as will the overall noise level. Since the propagation characteristics at 700 MHz cover a greater distance than the mid-band frequency bands, there is a high likelihood that interference with neighboring 700 MHz cells can be causing performance problems in the Service Gap area due to a lack of a dominant serving cell. The user experience when signal quality is an issue resembles a user exclaiming that they have 4 bars on their device, yet they cannot connect to service.

To demonstrate if there are signal quality issues affecting performance on the 700 MHz low-band frequency, receive quality plots have been prepared from the drive test data. In LTE signal quality is measured through Signal-toInterference-plus-Noise Ratio or (SINR). SINR is the ratio of the power of the desired signal (RSRP) to the sum of interference power from other cells and noise. SINR measures the quality of the received signal by comparing the desired signal strength to the combined strength of interference and noise, with higher values indicating a better, clearer connection. A higher SINR means the user device can more easily and accurately decode the data it receives. A strong desired signal (high SINR) leads to faster speeds, fewer dropped calls, and a better overall user experience. Conversely, a low SINR indicates a weak signal, high interference, lower user throughput, and leads to higher amounts of dropped calls.

A good analogy for SINR is explained as a crowded party with competing speakers as follows:

You’re at a party with multiple DJs set up in different corners of the room (these are the cell towers or sectors). Each is playing music on their own speaker, and you’re standing in a spot where all the sounds reach you clearly — that’s strong RSRP.

But here’s the catch…
• All the DJs are playing different songs, and their speakers are overlapping where you’re standing. • Now even though the volume is high (strong signal power), you can’t enjoy any one song clearly because the different music tracks are interfering with each other.

That messy overlap? That’s inter-cell interference — it’s not just random noise, it’s structured sound from other sources that competes with the one you actually want to hear.

Translation:
• RSRP (Strong Signal) = You hear all the DJs loudly.
• Interference = Other DJs playing at the same time mess up the one you’re trying to follow. • SINR (Signal-to-Interference-plus-Noise Ratio) = Even with a strong signal, your ability to make sense of it is ruined by the competition and background noise.

Attached hereto as Exhibit C2 is a Verizon Wireless 700 MHz LTE (4G) Drive Test Map that demonstrates the results of the drive test PierCon performed for the purpose of confirming Verizon Wireless’s existing 4G (LTE) signal quality in the vicinity of the Site within Carmel and surrounding areas. The map represents 4G (LTE) SINR in the 700 MHz band. The data is represented in ranges of SINR per the table below. Verizon’s performance level is 12.5 for SINR, which is in the lower range of good. Statistics in the SINR maps are provided using the 10 dB level.

Color SINR (dB) Signal Quality Typical Impact
Blue > 20 dB Very Good High data rates, efficient use of spectrum Green 10-20 dB Good Stable, decent throughput
Yellow 5 -10 dB Fair Limited speeds, frequent retransmissions Grey 0-5 dB Poor Low throughput
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Black < 0 dB Very Poor Drop connections or no service
As can be seen in Exhibit C2, the low-band SINR map shows large areas with SINR values less than the minimum design level required. At low-band, 73% of the drive test area has a SINR value less than 10 dB, with 10% of the area showing SINR values less than or equal to zero. Of particular note is that although the low-band frequency demonstrates adequate signal levels (RSRP), the signal quality (SINR) is extremely poor due to the interference levels from distant sites. Exhibit C2 illustrates that an overwhelming percentage of the area driven does not meet the Verizon performance criteria.

Exhibit C2 also demonstrates that although the 700 MHz RSRP was within the design threshold, the signal quality as reported by SINR is mostly poor to no connection, within the area surrounding the proposed site. The significant gap in service at the low-band frequencies is therefore defined by the areas bounded by the grey and black test SINR data plotted on Exhibit C2 identified by a orange hashed polygon. Specifically, the significant gap area is 0.43 square miles including 1.1 miles from Ocean Avenue to Scenic Road, south of 17th Avenue, 0.38 miles from Scenic Road to San Carlos Street near 8th Avenue, and 047 miles from Scenic Road to Mission Street near 13th Avenue and Saint Lucia Avenue. According to the 2020 US Census data there are approximately 1059 residents living in the Service Gap area.

Mid Band Drive Test Analysis
Attached as Exhibit D is a Verizon Wireless 21009 MHz LTE (4G) Drive Test Map that demonstrates the results of a drive test performed for the purpose of evaluating existing 4G (LTE) coverage in the vicinity of the Proposed Site. The map represents 4G (LTE) reference signal strength in the 2100 MHz band. The map identifies measured RSRP levels as in the table below. Verizon’s goal is to provide reliable LTE in-building residential service to the Service Gap area.

Color RSRP (dB) Signal Strength Level
Blue -95 <= X Minimum threshold in-building residential Green -105 <= X < -95 In-vehicle minimum threshold
Yellow -110 <= X < -105
Grey -115 <= X < -110
Black 150 <= X < -115
Exhibit D identifies the service gap with an orange hashed line on the map, and demonstrates that the signal levels measured do not meet Verizon’s standard for the provision of in-building residential coverage within the Service Gap boundary.

Also attached is Exhibit D1, which is a modified10 version of Exhibit D, and also identifies the service gap area with a orange hashed polygon.
9 The 2100 MHz band is utilized to represent the mid-band frequencies inclusive of 1900 MHz and 2100 MHz as their propagation characteristics are very similar.
10 Carmel-by-the-Sea’s planning commission adopted standard submission requirements for applicants claiming a significant gap in service. The requirement as outlined in the Wireless Application Checklist section 15.2.1 includes providing drive test data for relevant frequencies in a table format, and also graphically. The graphical drive test data is to be provided showing the minimum signal strength required, and three additional levels, binned in 3 dB levels. The PierCon independent drive test data presented in this report provides on a single map the signal strengths greater than or equal to -95 dBm RSRP (Verizon minimum in-building residential signal strength), RSRP values less than -95 dBm and greater than or equal to -98 dBm, RSRP values less than -98 dBm and greater than or equal to -101 dBm, RSRP levels less than -101 dBm and greater than or equal to - 104 dBm, and RSRP values less than -104 dBm.

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The Service Gap, represented by a orange hashed polygon on Exhibits D and D1, is approximately 0.27 square miles and is primarily based on the residential homes north and south of the Proposed Site. According to the 2020 US Census data there are approximately 776 residents living in the Service Gap area.

The lack of mid-band (1900 & 2100 MHz) RSRP is due to the propagation characteristics of the frequency range combined with the existing site heights and the distance away from the Service Gap Area. The Downtown Carmel site is a building where existing antennas are at a height of 33 feet above ground, providing approximately 900 feet of reliable in building coverage to the area. The SF South Carmel 003 site is an existing building where the existing antennas are at a height of 57 feet above ground, providing approximately four blocks (0.33 miles or 1716 feet) of reliable in building residential coverage to the area in each direction. We have examined the signal strength levels and now let’s examine the signal quality levels through additional SINR maps, as was provided for low band.

Attached as Exhibit D2 is a Signal to Noise and Interference Ratio (SINR) map for mid-band as per the table below:

Color SINR (dB) Signal Quality Typical Impact
Blue > 20 dB Very Good High data rates, efficient use of spectrum Green 10-20 dB Good Stable, decent throughput
Yellow 5 -10 dB Fair Limited speeds, frequent retransmissions Grey 0-5 dB Poor Low throughput
Black < 0 dB Very Poor Drop connections or not work
Similar to the signal strength RSRP map (Exhibit D) with a orange hashed polygon indicating insufficient signal levels, a orange hashed polygon is shown on Exhibit D2 illustrating the service gap resulting from inadequate SINR levels. As can be seen, the mid-band SINR map shows large areas with SINR values less than the minimum design level required.

At mid-band, 73% of the drive test area has a SINR value less than 10 dB, with 9% of the area showing SINR values less than or equal to zero. The mid-band SINR gap is approximately 0.39 square miles, including 1.1 miles from Ocean Ave to Scenic Road, south of 17th Avenue, and that an overwhelming percentage of the area driven does not meet the Verizon performance criteria. According to the 2020 US Census data there are approximately 994 residents living in the Service Gap area.

Mid C-Band Drive Test Analysis
Attached as Exhibit E is a: Verizon Wireless 370011 MHz LTE (5G) Drive Test Map that demonstrates the results of a drive test performed for the purpose of evaluating existing 5G (LTE) coverage in the vicinity of the Proposed Site. The map represents 5G (LTE) reference signal strength in the 3700 MHz band. The map identifies RSRP levels greater than or equal to -95 dBm as blue circles, RSRP values less than -95 dBm and greater than or equal to -98 dBm as green circles, RSRP values less than -98 dBm and greater than or equal to -101 dBm as yellow circles, RSRP levels less than - 101 dBm and greater than or equal to -104 dBm as grey circles and RSRP values less than -104 dBm as black circles.

Verizon’s goal is to provide reliable 5G in-building residential service to the Service Gap area. The existing service gap area is identified with a orange hashed polygon.
11 The 3700 MHz band, known as C-Band, due to its higher frequency range has even more limitation with regard to coverage range. Additional CBand offers 140 MHz of bandwidth which will require more overall power to penetrate buildings. Utilization of beamforming techniques can help extend the coverage range to mimic the range of the 1900 & 2100 MHz bands, however; even with advanced beamforming techniques, the midband significant gap would still exist and be no less than what is currently represented by the 2100 MHz band gap defined herein.

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As can be seen on Exhibit E, almost the entire drive test area fails to meet the residential in-building coverage requirement. This is due to the fact that Verizon has not yet deployed C band at the Downtown Carmel site or the SF South Carmel 003 node, and the approved small cells SF South Carmel 002 and SF South Carmel 005 are not yet operational. The deployment of the C band is planned as part of an overall introduction of new 5G services to the area.

It should be noted that even if the C Band 3700 MHz frequencies were deployed at these locations, the resulting drive test signal strength data values would be equivalent to or less than those measured for the mid-band, and would still illustrate a service gap, requiring a new facility to introduce the new 5G service.

The Service Gap, represented on Exhibit E by the red hashed polygon, is approximately 0.47 square miles and is primarily based on the residential homes north, south, and east of the Proposed Site. According to the 2020 US Census data there are approximately 1224 residents living in the Service Gap area.

Based upon the drive test map data collected and analyzed, Verizon is unable to meet the service goals with respect to coverage as specified in section 3 of this report. Specifically, the drive test maps indicate the existence of significant gaps in 4G & 5G LTE reliable in-building residential coverage as demonstrated by the RSRP maps, and inadequate signal quality as demonstrated by the SINR maps.
7 KEY PERFORMANCE INDICATORS
In addition to confirming that Verizon Wireless has a significant gap in its 4G & 5G service with Drive Test Maps, we have also evaluated Verizon’s Key Performance Indicator Data (“KPIs”). The KPIs utilized consist of VoLTE drop call failure rates, user downlink utilization data, and call quality indicator data. The KPI data that is relevant is based upon the surrounding sites and sectors that are providing signal, albeit poor signal or poor signal quality, to the significant gap area. The KPIs analyzed and provided herein are for the 4G/LTE services in each of the frequency bands referenced. The KPI data collected and analyzed consists of busy hour data over a 90-day period from November 15, 2024, through February 11, 2025. The data analyzed and provided herein in the form of charts are for the sites and sectors that have been determined to provide the best (not necessarily adequate) serving signal within the Service Gap areas.

When reviewing KPI data, it is important to understand how the wireless connection operates from one frequency band to another. As noted earlier in this report, the propagation characteristics and capacity within each band differ. A 4G/5G LTE connection is based upon signal quality and where adequate signal is available, is prioritized to the midband higher capacity frequencies. For example, if a wireless user is within good signal range of a nearby cell site, the user’s device will connect on a mid-band frequency and as the user moves away from the facility, the user’s device will continuously be updated with neighboring cell signal quality information. As the signal quality degrades on the current connected frequency band, the connection will move to the next better quality frequency band. The logical connection flow is illustrated in the diagram below:

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In regard to the diagram above, the green shaded hexagon area represents the coverage range of the mid-band frequencies. The blue (and green) shaded hexagon area represents the coverage range of the low-band frequencies. As a user moves away from a serving sector, the LTE connection will transition from 3700/2100 MHz down to a 1900 MHz connection. This will occur, up, and until, the signal quality on the last mid-band frequency needs to transition to a low-band frequency. This transfer is called a handover or hand-down.

The diagram above can also be used to understand carrier aggregation. Carrier aggregation is a feature of LTE that allows a user device to utilize resources from multiple different frequency bands (low-band and mid-band) at the same time. This feature allows for increased capacity and throughput. However, for carrier aggregation to work, there must be adequate signal strength and quality in the frequencies. From the graphic above, for example, if the mid-band coverage isn’t adequate, carrier aggregation can only be supported on the low-band frequencies. If the low-band frequency coverage is provided from the cell edges of the surrounding sites, for example, with no dominant server, then the signal quality will be poor, and even with carrier aggregation on low-band, the service will be inadequate.

Key Performance Indicator (KPI) Analysis
Each of Verizon’s active sites are monitored continuously for various performance metrics which are known as key performance indicators or KPIs. In order to determine which sites and sectors the KPIs are coming from the RF engineer must determine what are the dominant serving transmitters in the area of the gap. This is often referred to as a “dominant server”. Dominance refers to the best or strongest whereas server refers to a particular transmitter. Each site includes a series of antennas which are oriented in a particular direction. Each antenna is connected to a transmitter at the base of the structure. The antennas and transmitters together provide signal to a given area.

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Table 2 below represents the relevant sites and sectors that have been determined to provide a dominant signal to various areas of the coverage gap. The KPIs from these sites are analyzed in the section to follow.

Table 2
SITE & SECTOR Low Band % Mid Band %
Downtown Carmel Gamma 10% 7%
Founders Building Beta 31% 41%
Pebble Beach Tennis Club Beta 5% 8%
SF South Carmel 003 Alpha 37% 28%
SF South Carmel 003 Beta 8% 5%

From the table above the Founders Building Beta and SF South Carmel 003 Alpha provide the majority of the dominant signal in the area, therefore, the KPIs for these two sectors will be the most applicable. Please refer to Exhibit F (Low Band Best Serving Transmitter), and Exhibit G (Mid Band Best Serving Transmitter) for a graphical representation of the areas of signal from the surrounding sites and sectors in the table above.

VoLTE Drop Call Rate (KPI) Analysis12
The VoLTE drop call rate from the KPI charts provided in Exhibit H indicate, as expected, the highest rate of drop calls in low band frequencies. This is due to the lack of mid-band signal suitable for use forcing all wireless traffic onto the low band frequencies which eventually drop. A description of each drop call rate chart from the applicable sectors is as follows:
• Founders Building Beta – Provides low band dominant signal to 31% of the significant gap area as illustrated on Exhibit F and 41% of mid-band dominant signal as illustrated on Exhibit G. o The 700 MHz chart, (page 24 of the Exhibits) indicates that the drop rate exceeded 1% for 93% during the busy hour (with peaks over 20% failure rate) over the 90 day period evaluated. This demonstrates that while 700 MHz provides the greatest range of coverage, the system is experiencing an excessive amount of drop calls. Therefore, regardless of the adequate RSRP levels found, there remains a significant gap in the area of the Proposed Site. o The 850 MHz chart, (page 25 of the Exhibits) indicates that the drop rate exceeded 1% for 58% of the time during the busy hour (with peaks over 12% failure rate) over the 90 day period evaluated.

Similar to the 700 MHz band, the system is experiencing an excessive amount of drop calls. o The 1900 MHz chart, (page 26 of the Exhibits) indicates that the drop rate exceeded 1% for 56% of the time during the busy hour over (with peaks over 7% failure rate) the 90 day period evaluated. Similar to the low bands, the mid band system is experiencing an excessive amount of drop calls.
• SF South Carmel 003 Alpha - Provides low band dominant signal to 37% of the significant gap area as illustrated on Exhibit F and 28% of the dominant signal at mid band illustrated on Exhibit G. 12 In LTE networks, the dropped call rate (DCR) refers to the percentage of calls that are unexpectedly terminated or dropped due to network issues, rather than a user hanging up. International Telecommunication Union ITU-T E.807 specifies a threshold of 1% or less for call drop rates (CDR) as part of its QoS guidelines for mobile networks. All drop call rates provided in this report are specifically VoLTE drop call rates.

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o The 700 MHz chart, (page 27 of the Exhibits) indicates that the drop rate exceeded 1% for 47% of the time during the busy hour (with peaks over 18% failure rate) over the 90 day period evaluated.

This demonstrates that while 700 MHz provides the greatest range of coverage the system is experiencing an excessive quantity of drop calls. Therefore, regardless of the adequate RSRP levels found, there remains a significant gap in the area of the Proposed Site. o The 850 MHz chart, (page 28 of the Exhibits) indicates that the drop rate exceeded 1% for 18% of the time during the busy hour (with peaks over 13% failure rate) over the 90 day period evaluated.

Similar to the 700 MHz band, the system is experiencing an excessive amount of drop calls.

Downlink Throughput (Capacity13) Analysis
The downlink utilization from the KPI data analyzed, based on busy hour data, for the entire 90-day time period analyzed from November 15, 2024, through February 11, 2025, indicated several sectors with periods with downlink throughput less than 5 Mbps. Verizon’s performance requirement is to provide a minimum of 5 Mbps consistently to its users. Note, the FCC as recently as last March 2024 increased the mobile broadband benchmark to 35 Mbps downlink throughput per user. See attached charts in Exhibit I (pages 30 to 32 of the Exhibits). The relevant sectors and frequency bands are as follows:
• Founders Building Beta 700 MHz- Downlink user throughput was less than 5Mbps for approximately 88% of the busy hour 90 day time period analyzed. Verizon holds 10 MHz of spectrum in this frequency band. • Founders Building Beta 850 MHz- Downlink user throughput was less than 5 Mbps for approximately 10% of the busy hour 90 day time period analyzed. Verizon holds 10 MHz of spectrum in this frequency band. • Founders Building Beta 1900 MHz - Downlink user throughput was less than 5 Mbps for approximately 39% of the busy hour 90 day time period analyzed. Verizon holds 5 MHz of spectrum in this frequency band.

The data above indicates the Founders Building site providing signal to the service gap area (31% at low band and 41% and mid band) cannot meet the 5Mbps performance requirement, specifically in the three frequency bands with the limited licensed 10 MHz and 5MHz of spectrum. This is an indication that the site is currently providing inadequate signal strength (RSRP) and contributing to interference (SINR) resulting in lower throughput levels. 8 VERIZON’S PROPOSED SOLUTION
In seeking to remedy the significant gap in coverage and compromised network performance, due to the lack of reliable inbuilding signal strength, the Verizon Wireless radio frequency engineering department is seeking to place a third small cell in the gap area. Small cell placement requires precise location planning, as a small cell is limited in height, coverage, and spectrum allocation. A small cell will provide reliable coverage for a typical range of four blocks, and the location must fit in like a piece of a missing puzzle. The following information provided will demonstrate that the proposed small cell location is properly chosen and will optimally integrate with Verizon’s existing and approved site coverage.

Referring to exhibits C2 , D1 and D2, the proposed wireless communication site is located logically and in the center of the mid-band coverage gap (D1) and centrally located in the center of the SINR gap area for low band (C2) and mid13 LTE capacity issues, often manifesting as slow speeds or dropped connections, arise from factors like network congestion, signal interference, and poor coverage, impacting user experience and data throughput.

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band (D2) SINR gap14. When proposing a new wireless communications facility, it is extremely important to have the location as near the center of the service gap area as possible. Having a small cell facility at the center of a service gap area provides omnidirectional service, allowing for optimal performance of the site. This design approach assumes the intended overall coverage area is very similar in topography and morphology. Equally as important to the location, is the required height necessary to remedy the significant coverage gap for the carrier’s licensed frequency bands.

Insufficient height at a location will not maximize the site’s ability to remedy the coverage gap and therefore require additional wireless facilities.

In addition to identifying the location of the proposed small cell in relation to the current coverage gap, the effects of expected coverage from the approved small cells in the immediate area must also be evaluated. To remedy the Service Gap Verizon has proposed a 50-foot small cell, with their antennas located at a 48.7 foot centerline elevation. The proposed site is located on Carmelo Street between 10th Avenue and 11th Avenue, and approximately 0.43 miles north of the approved small cell SF South Carmel 002. Attached as Exhibit J is an EDX Signal Pro15-generated map illustrating the drive test signal levels measured with the overlaid expected coverage from the approved SF South Carmel 002 and SF South Carmel 005 small cells. The SF South Carmel 002 is a 50 foot small cell expected to provide reliable 4G LTE residential in-building coverage utilizing the Mid-band PCS and AWS frequency bands, and reliable 5G services utilizing the C-band 3700 MHz frequencies. The SF South Carmel 005 small cell is located 0.64 miles to the east and will provide minimal coverage to the gap area due to its limited 50’ height, and the topographical change in elevation between Junipero Street and San Carlos Street.

As can be seen on Exhibit J, SF South Carmel 002 will provide reliable in-building residential coverage to a portion of the overall service gap area, however, as expected, this small cell will not address the entire service area gap. This site is expected to provide reliable in-building mid band coverage to 0.07 square miles, and 201 residents, addressing 25% of the overall mid band gap area16.

Attached as Exhibit K is an EDX Signal Pro-generated map illustrating the drive test signal strength data measured and overlaid with: (1) the expected coverage provided by the approved SF South Carmel 002 and SF South Carmel 005 small cells, and (2) the expected coverage from the proposed small cell site SF South Carmel 001. The drive test data is shown as blue circles indicating measured RSRP levels greater than or equal to -95 dBm. Expected -95 dBm RSRP coverage provided by the approved locations is shown in blue, and the expected -95 dBm RSRP coverage provided by the proposed site is shown in green. As can be seen on Exhibit K, the proposed site will provide reliable in-building residential coverage to .1 square miles, 372 residents, and remedy an additional 37% of the gap area. The proposed site is expected to provide reliable in-building residential coverage to the immediate area which includes Ocean Avenue to 13th Avenue, and San Antonio Avenue to Dolores Street.

8.1 ALTERNATIVE SITES
As part of our overall analysis, PierCon reviewed a report dated November 2021 prepared by Columbia Telecommunications Corporation providing the City of Carmel-by-the-Sea with a review of Verizon’s wireless application. The report included an analysis of Verizon’s existing coverage provided by surrounding sites, and the recommendation of an alternative site location at the Golden Bough Playhouse.

The report states on page 5 “We found evidence of a lack of in-building coverage as defined by Verizon’s coverage standards in the low-band 700MHz spectrum and high-capacity PCS/AWS mid-band spectrum in the area targeted by this facility” which would be consistent with the findings in this report. Specifically for low band, poor signal quality is 14 Proposed small cell location accounts for the approved small cell SF South Carmel 002 located 0.44 miles to the south. 15 EDX Signal Pro is an industry standard software used to create radio frequency coverage maps for radio frequency bands from 138 MHz (VHF) to 5 GHz.
16 Area and population data provided is calculated using MapInfo Professional, which is an industry standard Geographic Information System (GIS) software, used to analyze geographical data, integrating data from various sources, including 2020 census data for population.

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present as demonstrated with poor SINR levels measured, appearing as inadequate coverage levels. Inadequate mid band coverage levels are also demonstrated by the drive test maps included in this report, including the RSRP and SINR maps. Furthermore, the CTC report also states on page 5, “Approval of this application will enhance Verizon Wireless’ service to customers in the vicinity of the proposed site”. PierCon also agrees with this statement.

The CTC report provides an alternate site location at the Golden Bough Playhouse, which is located between Monte Verde Street and Cassanova Street between 9th and 8th Avenue, two blocks north and three blocks east of the proposed site and located in a Tier II A-1 Theatrical zone. The Golden Bough Playhouse site is a building rooftop approximately 23’ in height above ground, compared to the 47.5’ height for the proposed small cell.

The CTC report uses computer simulation coverage maps to compare the coverage expected from Verizon’s proposed site and the Golden Bough site, along with Verizon’s existing coverage, and suggests the results are equivalent, if not better with the Golden Bough location.

Attached as Exhibit L is a map showing the current and approved Verizon in-building residential coverage, defined as RSRP greater than or equal to -95 dBm. The map shows RSRP signal level collected during the drive test indicated by blue circles. The expected in-building coverage from the approved sites is also indicated by a blue color. For clarity, only RSRP levels greater than or equal to -95 dBm are shown. The existing, approved and proposed sites are labeled, as well as the CTC proposed Golden Bough site location. The coverage gap is identified with an orange hashed line. As can be seen from Exhibit L, reliable in-building coverage levels are currently provided by the SF South Carmel 003 between Mission Street to four blocks west to Monte Verde Street, and the existing Downtown Carmel site also provides reliable in-building coverage to Cassanova Street, which is four blocks west of that site. The location of the Golden Bough site is at the edge of Verizon’s existing reliable coverage. Using EDX Signal Pro-to generate coverage (shown in green) with an omni directional antenna, much of the coverage expected from the Golden Bough site would be redundant to the north, east, and south, making it a poor site location to address the coverage gap. Substantial coverage overlap will appear as interference, such as demonstrated in the poor SINR maps, due to improper site placement. The Golden Bough Playhouse will provide reliable in building coverage to .07 square miles, 241 residents, addressing 25% of the coverage gap. This expected coverage is 11% less area and 17% less population compared to that expected from the proposed site. The in-building coverage overlap (interference) provided by the Golden Bough Playhouse is approximately .09 square miles, which is 129% interference compared to new coverage offered to the area17. The deployment of an omni directional antenna at this location would provide more interference than new coverage to the area, rendering the site extremely inefficient to meet Verizon’s coverage objectives.

Attached as Exhibit M is a modified version of Exhibit L, illustrating the expected coverage from the Golden Bough site, using a clover shape omni antenna with only two sectors active to minimize overlap with existing coverage. These canister antennas are fixed with 120 degrees of spacing between sectors, and azimuths of 200 degrees and 320 degrees were chosen to best address the service gap area. As can be seen on Exhibit M, even with the use of antenna directionality, a substantial amount of coverage overlap would occur with the existing coverage provided by the Downtown Carmel site and the SF South Carmel 003. Substantial coverage overlap will appear as interference, such as demonstrated in the poor SINR maps, due to improper site placement. In this configuration, the Golden Bough site would provide reliable in building coverage to .085 square miles, 372 residents and address 31% of the coverage gap.

This expected coverage is 6% less area when compared to that expected from the proposed site. In this configuration, the Golden Bough Playhouse would provide .072 square miles of in-building coverage overlap (interference), or 85% interference compared to new coverage offered to the area, also making this site and configuration inefficient to meet Verizon’s coverage objectives.

The alternative Golden Bough Playhouse will not effectively address the coverage gap, limit the ability to improve and enhance existing service, and limit the ability to introduce new services. The expected coverage from the Golden Bough site would be mostly redundant if using a small cell omni type antenna and offer limited coverage as a sectored site, if 17 The 129% was calculated by comparing the undesired overlap region to the desired covered area.

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using a low profile canister clover type antenna. From an RF perspective, the Golden Bough site and location is not an equivalent to the proposed site, as it is located on the edge of existing Verizon service, and offers mostly redundant inbuilding coverage. The location limits the overall effectiveness of a new wireless facility to provide new services by restricting the coverage area to the west. This geographic coverage restriction further limits Verizon’s ability to enhance the network and optimally balance user demand by limiting the site to two of three sectors, or 33% reduction in otherwise available spectrum resources.

8.2 LEAST INTRUSIVE
The Proposed Site is the least intrusive because it remedies a significant portion of the service gap area (37% of the mid band gap, and 372 residents), without the need for a macro wireless facility, requiring significant infrastructure. As stated previously, the installation of a macro site requires: sufficient structure space for the antenna array, sufficient building or ground space for the transmitter equipment cabinets, battery backup, emergency generator, and requires commercial grade electrical service and sufficient backhaul infrastructure-often in the means of new fiber installation or microwave antennas. Meeting these requirements are infeasible in a single family residential neighborhood, and the aesthetics of such an installation would not minimize the adverse aesthetic impacts to Carmel-by-the-Sea’s “village in a forest by the sea character.

The proposed small cell site will replace an existing 38 foot 11 inch utility pole with a taller 49 foot 10 inch pole, inclusive of a 2 foot 6 inch cylindrical antenna at the top, and associated radio equipment located on the side between 7 and 17 feet above ground. This small cell structure design is already present throughout Carmel with six Verizon small cells operational in the Carmel Woods/Northeast Carmel area, and two other small cell sites approved in the South Carmel area.

The proposed replacement utility pole is the most compatible structure selection type in the Public Rights-of-Way per code section 17.46.040 D.2, and second most compatible structure selection type per code section 17.46.040 D.1.d, seemingly making the proposed site a desired location and structure type most compatible with the City’s code requirements, given the limiting compatibility rankings. The additional special considerations requirement identified in section 17.46.40.E then further states “Applicants shall not propose to install wireless facilities in/on a highly incompatible location in the public right-of-way unless the application is accompanied by a request for a special exception finding under CMC 17.46.080(C)”, immediately followed by “The following is a list of highly incompatible locations: a. Any location in the public right-of-way within the single-family residential zoning district.” Attached as Exhibit M1 is a zoning map of the subject area within the city limits, with existing Verizon site locations, and the mid band gap area shown in previous exhibits. The zoning map clearly shows that only R-1 (light yellow) and R-4 (orange) zones are present in the service gap, with the one exception of the A-1 Theatrical zone parcel (light blue).

In an attempt to satisfy the City’s requirements, Verizon identifies the following:

There are no Tier III (most compatible) Central commercial (CC), service commercial (SC), and community and cultural (A-2) zones that are available or feasible for a new Verizon facility.

There are no Tier II (compatible) Improved parklands (P-2), natural parklands and preserves (P-1), and theatrical (A-1) zones available or feasible for a new Verizon facility.

Both items above lead to the conclusion that a new needed Verizon facility must be placed in a Tier I location, consisting of the following zones: Senior citizen facility (A-3), multifamily residential (R-4), single-family residential (R1), and residential and limited commercial (RC). As mentioned previously, there only exists predominately an R-1 zone and one R-4 zone. The one A-1 zone is not a feasible location.

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The code specifies a preference of public and private parcels to Public Rights-of-Way, however given the prior logical conclusions, only single family residential homes are present in the final remaining zone, leaving the Public Rights-ofWay the last remaining feasible option. With regard to meeting the most compatible structure selection type identified in 17.46.040D.1.e as “Existing nonbuilding structures with existing wireless facilities”, there are no existing wireless facilities in the subject area that Verizon can co-locate on. Furthermore, any existing small wireless facilities will not support co-location due to restrictions on height and equipment space. The conclusion is that the only remaining feasible option is a new small wireless facility located in a residential zone in the Public Rights-of Way.

Carmel-by-the-Sea’s code further restricts the replacement of existing structures or placement of new structures, requiring the structure not to be placed “Directly in front of the areas which are five feet in either direction from the centerline of each entry door or window in the front facade of any occupied residential building” or “Within a 500-foot radius from another wireless facility within the public rights-of-way” A topographical Google Earth review of the residential area was conducted where the new Verizon small cell facility would have to be located, centered on Carmelo Street between 10th and 11th Avenues, and bounded by the area between 9th Ave and 12th Ave, and San Antonio Ave to Camino Real, to minimize coverage overlap with existing and approved sites, and to maximize the ability to provide new 5G services. Attached as exhibit M2 is a Google Earth map of the subject area, identifying the existing utility poles marked as colored circles numbered 1 to 40, and the center of the area marked with a green bullseye. Utility poles with transformers are identified with red circles and are prohibited locations for wireless equipment.. The remaining utility poles are identified by either orange or green circles, indicating the pole may be a viable location subject to additional evaluation. The Google Earth imagery date for the information in this analysis is 9/2024, and is subject to final field verification.

There were a total of 40 utility pole locations identified in the area above. Of the 40 utility pole locations, 17 utility poles have existing transformers located on them, eliminating 42.5% of the utility poles as possible small cell site locations and leaving 23 (57.5%) possible existing locations. Of the remaining 23 utility poles, poles 38, 18, 20, 21 and 22 appear to violate 17.46.40.E.2.a. Poles 21 and 22 are short utility poles requiring a greater than 10’ extension as well. This leaves 18 pole locations (45%). Pole 39 is a short utility pole that would require a greater than 10’ extension to provide the necessary coverage leaving 17 pole locations (42.5%). Poles 28 and 29 are located under larger trees, and the replacement of the existing pole with a taller one does not appear feasible leaving 15 pole locations (37.5%). Poles 32, 34, and 36 are at the lowest ground elevation between 60 and 63 feet (compared to 79 feet at the proposed location), and the furthest west in or just outside the service gap area, limiting coverage to the east as the elevation on Cassanova Street rises from 100’ near 12th Avenue to 122’ at 9th Avenue. These 11 poles have been marked in orange on the map, indicating they are not adequate RF locations, or they would represent more intrusive locations. This leaves 12 possible remaining locations for a small cell location (30%). Of the 12 pole locations remaining, those north of 10th Avenue (poles 17 and 19) will be much more likely to produce redundant coverage with that existing at mid-band. (Refer to Exhibit J). Similarly, those pole locations south of 11th Avenue (poles 14, 25, 26, 27) will be very likely to provide redundant coverage to that expected from the approved SF South Carmel 002 site. (Refer to Exhibit J). These 6 poles have also been marked in orange on exhibit M2. This leaves the optimal RF placement between 10th and 11th Avenues, and between Carmelo Street and Camino Real and 6 utility pole locations (15%) (pole numbers 1, 8, 10, 12, 20, 24 marked as green circles). The reader will note that the proposed Verizon small cell location is one of the optimal 6 remaining locations nearest the center of the identified area and labeled as pole 1.

The proposed small cell antenna support structure would be of similar height and type as that existing to minimize visual impact and is comparable to existing transformers at the top of utility poles throughout neighborhoods. The proposed site is centrally located in the service gap area, allowing even distribution of coverage and capacity, maximizing the site’s potential to address Verizon’s design and performance goals. In doing so, the number of overall wireless telecommunications sites required is minimized.

ATTACHMENT 8

10 CONCLUSION
PierCon Solution’s analysis of Verizon Wireless’ existing network coverage indicates that a significant coverage gap in wireless service exists in the Carmelo Street area. The service gap area is 0.27 square miles at mid-band, 0.43 square miles at low band, and 0.47 square miles at C-band. The areas are primarily based on the residential homes north and south of the Proposed Site. According to the 2020 US Census data there are approximately 776 residents living in the low band service gap area, 994 residents in the mid band service gap area and 1224 residents in the C-band service gap area. Drive test data provided in this report demonstrates the specific geographic area lacking reliable in-building coverage for Verizon’s FCC licensed mid band frequencies. Further Key Performance Indicator (KPI) data provided demonstrates the existing wireless sites providing service to the subject area are not meeting the industry standard performance metrics and cannot be altered or upgraded to address the subject area.

Both aforementioned items lead to the conclusion that a new wireless facility is necessary to address these network reliability issues. Verizon proposes a new small cell facility which has been evaluated to remedy the lack of in-building coverage and network KPI issues. By proposing a small cell capable of providing coverage and capacity in the FCC licensed mid-bands, where Verizon has 175 MHz of spectrum available, the proposed small cell can remedy a significant portion of the service gap with minimal infrastructure and intrusion. Even though the drive test analysis demonstrates a significant gap in low-band reliable signal quality, the deployment of low band spectrum provides a limited 20 MHz of licensed spectrum resources. A small cell deployed establishing reliable in building residential signal levels at mid band frequencies would also allow optimization of the existing Verizon sites providing coverage at the low band frequencies and provide the ability to reduce the existing interference. Only once the proposed small cell is installed, and network optimization is completed can Verizon evaluate the Carmel-by-the-Sea wireless network to determine the extent of any further service enhancements.

The location of a new Verizon wireless facility must be located in an R-1 zone to perform optimally with the existing sites and minimize the need for additional wireless facilities. The proposed small cell location allows for the provision of enhanced 4G services and new 5G services where there is a current deficiency. The new Verizon facility will integrate with the existing infrastructure and allow for competitive services to be provided. 40 utility poles in the service gap R-1 area were identified, and 62.5% (25 of the 40) were not feasible locations, leaving a total of 15 pole locations to provide the needed RF service. The remaining 15 utility pole locations were further reviewed for compliance with code requirements, feasibility, and the ability to integrate with Verizon’s existing wireless sites to provide the necessary RF coverage to the service gap area, leaving 6 viable locations for a new small cell site.

Having reviewed the proposed site and other technical information evaluated in this report, PierCon Solutions believes the proposed small cell site location and height is the best suited from an RF perspective to remedy the significant coverage gap and address the current compromised network performance. The proposed installation will aid in improving coverage to the area, providing reliable mid-band coverage, and thus improving Verizon Wireless customers’ experience on the network throughout the area immediately surrounding Carmelo Street. The proposed small cell site is located in a densely populated residential area, centered between approved small cell sites SF South Carmel 002 and SF South Carmel 005.

The small cell design allows for the replacement of an existing utility pole with a similar structure and would minimize the visual impact of a needed new wireless facility. The proposed small cell site will provide enhanced reliable 4G inbuilding residential coverage to 0.1 square miles, 372 residents, and introduce new 5G coverage and services, remedying 37% of the identified service gap area. The proposed site, together with the approved SF South Carmel 002 small cell will address 62% of the of the overall mid band gap area, and 74% of the overall population in the mid band gap area, surpassing the results obtained from other alternate site combinations evaluated. The proposed site best integrates with the existing Verizon network and minimizes site-to-site interference, maximizing the site’s ability to remedy the significant coverage gap and address the poor network key performance indicators. A coverage summary for in building residential reliable service is provided in Table 3 below.

ATTACHMENT 8

Table 3 – Summary of Expected In-building coverage from reviewed sites Area/Covered
area (sq mi)
% Area
coverage
provided
% area
coverage
including
SF South
Carmel
002
Coverage
Overlap
(sq mi)
Interference
Contribution %
(Overlap Coverage
area to Desired
Coverage area)
Mid Band Gap 0.27
Proposed Site 0.1 37% 62% 0.048 48%
Golden Bough
Omni 0.07 25% 50% 0.09 129%
Golden Bough
2 sector Clover 0.085 31% 56% 0.072 85%
Pole 14 0.08 29% 54% 0.045 56%
SF South
Carmel 002 0.07 25% NA NA NA
Finally, the proposed new facility will be an integral part of an overall network upgrade providing new 5G services to the area. The reliable in-building residential coverage expected includes Carmelo Street from Ocean Ave to Santa Lucia Ave, and between San Antonio Ave to Lincoln Street.

After performing the independent radiofrequency analysis, PierCon Solutions concludes that this facility is essential to Verizon Wireless’ network design in and surrounding the Carmel-by-the-Sea immediate area.

Report Prepared by:

Ron Lukach
Senior RF Engineer
PierCon Solutions, LLC
10/14/2025
Richard Conroy
Principal RF / Systems Engineer /President
PierCon Solutions, LLC
10/14/2025
ATTACHMENT 8

10 APPENDIX 1 - EXHIBITS
Exhibit A Verizon Site Table
Exhibit B Verizon’s Site Distance Map
Exhibit C Verizon Wireless 700 MHz LTE (4G) Drive Test Map Exhibit C1 Verizon Wireless 700 MHz LTE (4G) Drive Test Map Exhibit C2 Verizon Wireless 700 MHz LTE (4G) Drive Test Map -SINR Exhibit D Verizon Wireless 2100 MHz LTE (4G) Drive Test Map with Service Gap Exhibit D1 Verizon Wireless 2100 MHz LTE (4G) Drive Test Map with Service Gap Exhibit D2 Verizon Wireless 2100 MHz LTE (4G) Drive Test Map SINR with Service Gap Exhibit E Verizon Wireless 3700 MHz LTE (5G) Drive Test Map Exhibit F Verizon Wireless 700 MHz LTE (4G) Drive Test Map Exhibit G Verizon Wireless 2100 MHz LTE (4G) Drive Test Map Exhibit H VoLTE Drop Call Rate (KPI) Analysis
Exhibit I Downlink Throughput Analysis
Exhibit J Verizon's Existing Coverage with Approved Sites Coverage Exhibit K Verizon's Existing Coverage with Approved and Proposed Coverage Exhibit L
Verizon's Existing Coverage with Approved and Alternative Coverage -Small Cell
Exhibit M Verizon's Existing Coverage with Approved and Alternative Coverage -Sectors Exhibit M1 Zoning Map with Verizon Sites and Mid Band Gap Exhibit M2 Google Earth Image with Utility Pole Locations and Mid Band Gap Area ATTACHMENT 8

11 APPENDIX 2 – 3GPP LINK BUDGET
ATTACHMENT 8

12 APPENDIX 3 – DRIVE TEST DATA - TABLE FORMAT
ATTACHMENT 8

Exhibit A
Verizon Site Table
10/10/2025
ATTACHMENT 8

Existing Site Frequency Bands/Technology Antenna Height (ft) Azimuth (°) Longitude Latitude Type SF SOUTH CARMEL 003 L700, L850, L1900, L2100 57 210, 330 -121.921208 36.550992 ROOFTOP

DOWNTOWN CARMEL
L700, L850, L1900, L2100, N850,
N3700 33 20, 140, 260 -121.922197 36.554658 EME_Building

PEBBLE BEACH TENNIS
CLUB L700, L850, L1900, L2100, N3700 30 15, 115, 275 -121.9439806 36.56653333 ROOFTOP FOUNDERS BUILDING L700, L850, L1900, L2100 65 0, 120, 240 -121.957136 36.580394

CARMEL CYPRESS
L700, L850, L1900, L2100, N850,
N3700 45 30, 160, 280 -121.9070361 36.54169722 STEALTH STRUCTURE CHOMP MACRO L700, L850, L1900, L2100 42, 45 55, 145, 235, 325 -121.9133278 36.57833611 ROOFTOP SF NORTH CARMEL 001 L1900, L2100 48 0 -121.9177639 36.56883333 UTILITY POLE/TOWER SF NORTH CARMEL 002 L1900, L2100 51 0 -121.9153694 36.56880556 UTILITY POLE/TOWER SF NORTH CARMEL 003 L1900, L2100 52 0 -121.9185167 36.56674444 UTILITY POLE/TOWER SF NORTH CARMEL 004 L1900, L2100 36 0 -121.9150111 36.56546944 UTILITY POLE/TOWER SF NORTH CARMEL 005 L1900, L2100 42 0 -121.9190333 36.56441944 UTILITY POLE/TOWER SF NORTH CARMEL 006 L1900, L2100 47 0 -121.9156028 36.56271389 UTILITY POLE/TOWER AGUAJITO RD SC1 L700, L850, L1900, L2100 27 340 -121.9099778 36.57294722 UTILITY POLE/TOWER AGUAJITO RD SC2 L700, L850, L1900, L2100 53 295 -121.9043417 36.57153056 POLE UTILITY Approved Site Frequency Bands/Technology Antenna Height (ft) Azimuth (°) Longitude Latitude Type SF SOUTH CARMEL 002 L1900, L2100, N3700 49 0 -121.929726 36.543588 POLE UTILITY SF SOUTH CARMEL 005 L1900, L2100, N3700 43.9 0 -121.915316 36.548868 POLE UTILITY Subject Site Frequency Bands/Technology Antenna Height (ft) Azimuth (°) Longitude Latitude Type SF SOUTH CARMEL 001 L1900, L2100, N3700 48.7 0 -121.926922 36.549322

PUBLIC LIGHTING STRUCTURE
(FREE STANDING)
L=LTE, N=5G

STEALTH STRUCTURE
10/10/2025
ATTACHMENT 8

Exhibit B
Verizon’s Site Distance Map
10/10/2025
ATTACHMENT 8

0.5 miles
0 VERIZON WIRELESS

EXISTING SITES & SITE SEPARATION MAP
Distance Measured from
Subject Site to Relevant Sites
Site sectors
Existing On Air Site
Proposed Site
Approved Site
10/10/2025
ATTACHMENT 8

Exhibit C
Verizon Wireless 700 MHz LTE (4G) Drive Test Map
10/10/2025
ATTACHMENT 8

onio Ave
o
St
Real N
Casanova
onte Verde St St St s St St StSaSa
e St
Carpenter St
Del Mar Ave
San Anton oi Ave
8th Ave
Ocean View Ave
Scenic Rd Martin
Way
Santa Lucia Ave
13th Ave
14th Ave
Val ey
View
Ave
C
arm
elo
St 7th Ave
Cam ni o Real 9th Ave
10th Ave
Casanova St 6th Ave
Ocean Ave
11th Ave
12th Ave
15th Ave
Inspiration Ave
Stewart Way
17th Ave
16th Ave
Walker Ave
Mountain View Ave
Torres St F
orest Rd Vizcaino Ave
Crespi Ave
Rid
g
ew
o
od
RdRio
Rd
Franciscan Way
Ladera
Dr Delores St
Sycamore Pl
Atherton Dr
Trail View
Nindth Ave
Court of Golden Bough
Lasuen Dr
0 0.25
miles
Drive Test RSRP Signal Level (dBm)

VERIZON WIRELESS
700 MHz LOW BAND - ON AIR DRIVE (SCAN TEST) DATA
TESTED 2/19/2025
-95 <= X (Minimum Threshold)
-105 <= X < -95
-110 <= X < -105
-115 <= X < -110
-150 <= X < -115
Site sectors
Existing On Air Site
Proposed Site
Approved Site
10/10/2025
ATTACHMENT 8

Exhibit C1
Verizon Wireless 700 MHz LTE (4G) Drive Test Map
10/10/2025
ATTACHMENT 8

nio Ave
St
eal N
Casanova
nte Verde St
St St s St StStSaSSt arpenter St
Del Mar Ave
San Anton oi Ave
8th Ave
Ocean View Ave
Scenic Rd Martin
Way
Santa Lucia Ave
13th Ave
14th Ave
Val ey
View
Ave
C
arm
elo
St 7th Ave
Camino Real 9th Ave
10th Ave
Casanova St 6th Ave
Ocean Ave
11th Ave
12th Ave
15th Ave
Inspiration Ave
Stewart Way
17th Ave
16th Ave
Walker Ave
Mountain View Ave
Torres St F
orest Rd Vizcaino Ave
Crespi Ave
Rid
g
ew
o
od
RdRio
Rd
Franciscan Way
Ladera
Dr Delores St
Sycamore Pl
Atherton Dr
Trail View
Nindth Ave
Court of Golden Bough
Lasuen Dr

0.25 miles
0 Drive Test RSRP Signal Level (dBm)

VERIZON WIRELESS
700 MHz LOW BAND - ON AIR DRIVE (SCAN TEST) DATA
TESTED 2/19/2025
-95 <= X
-98 <= X < -95
-101 <= X < -98
-104 <= X < -101
-150 <= X < -104
Site sectors
Existing On Air Site
Proposed Site
Approved Site
10/10/2025
ATTACHMENT 8

Exhibit C2
Verizon Wireless 700 MHz LTE (4G) Drive Test Map - SINR 10/10/2025
ATTACHMENT 8

VERIZON WIRELESS
700 MHz LOW BAND - ON AIR DRIVE (SCAN TEST) DATA
TESTED 2/19/2025
Drive Test SINR Signal Level (dB)
nio Ave
St
eal N
Casanova
nte Verde St
St St s St StStSaSSt
Del Mar Ave
San Anton oi Ave
8th Ave
Ocean View Ave
Scenic Rd Martin
Way
Santa Lucia Ave
13th Ave
14th Ave
Val ey
View
Ave
C
arm
e
ol St 7th Ave
Camino Real 9th Ave
10th Ave
Casanova St 6th Ave
Ocean Ave
11th Ave
12th Ave
15th Ave
Inspiration Ave
Stewart Way
17th Ave
16th Ave
Walker Ave
Mountain View Ave
Torres St F
orest Rd Vizcaino Ave
Crespi Ave
Rid
g
ew
o
od
RdRio
Rd
Franciscan Way
Ladera
Dr Delores St
Sycamore Pl
Atherton Dr
Trail View
Nindth Ave
Court of Golden Bough
Lasuen Dr
0 0.25
miles
Site sectors
Existing On Air Site
Proposed Site
Low Band Gap

0.43 Square Miles
Approved Site
x > 20 Very Good High data rates, efficient use of spectrum (3%) 10 < x <= 20 Good Stable, decent throughput (24%)
5 < x <= 10 Fair Limited speeds, frequent retransmissions (30%) 0 < x <= 5 Poor Low throughput (33%)
x < 0 Very Poor Drop connections or no service(10%)
10/10/2025
ATTACHMENT 8

Exhibit D
Verizon Wireless 2100 MHz LTE (4G) Drive Test Map
with Service Gap
10/10/2025
ATTACHMENT 8

nio Ave
St
eal N
Casanova
onte Verde St St St s St StStSaSa
e St
Del Mar Ave
San Anton oi Ave
8th Ave
Ocean View Ave
Scenic Rd Martin
Way
Santa Lucia Ave
13th Ave
14th Ave
Val ey
View
Ave
C
arm
elo
St 7th Ave
Cam ni o Real 9th Ave
10th Ave
Casanova St 6th Ave
Ocean Ave
11th Ave
12th Ave
15th Ave
Inspiration Ave
Stewart Way
17th Ave
16th Ave
Walker Ave
Mountain View Ave
Torres St Vizcaino Ave
Crespi Ave
Pine Rid
Rid
g
ew
o
od
RdRio
Rd
Franciscan Way
Ladera
Dr Delores St
Sycamore Pl
Atherton Dr
Trail View
Nindth Ave
Court of Golden Bough
Lasuen Dr
0 0.25
miles

VERIZON WIRELESS
2100 MHz MID BAND - ON AIR DRIVE (SCAN TEST) DATA
TESTED 2/19/2025
-95 <= X Minimum Threshold (48%)
-105 <= X < -95 Minimum Threshold (36%)
-110 <= X < -105 (8%)
-115 <= X < -110 (7%)
-150 <= X < -115 (2%)
Drive Test RSRP Signal Level (dBm)

VERIZON WIRELESS
2100 MHz MID BAND - ON AIR DRIVE (SCAN TEST) DATA
TESTED 2/19/2025
Site sectors
Existing On Air Site
Proposed Site
Mid-Band Gap

0.27 Square Miles
Approved Site
10/10/2025
ATTACHMENT 8

Exhibit D1
Verizon Wireless 2100 MHz LTE (4G) Drive Test Map
with Service Gap
10/10/2025
ATTACHMENT 8

nio Ave
St
eal N
Casanova
nte Verde St
St St s St StStSaS
e St arpenter St
Del Mar Ave
San Anton oi Ave
8th Ave
Ocean View Ave
Scenic Rd Martin
Way
Santa Lucia Ave
13th Ave
14th Ave
Val ey
View
Ave
C
arm
elo
St 7th Ave
Cam ni o Real 9th Ave
10th Ave
Casanova St 6th Ave
Ocean Ave
11th Ave
12th Ave
15th Ave
Inspiration Ave
Stewart Way
17th Ave
16th Ave
Walker Ave
Mountain View Ave
Torres St F
orest Rd Vizcaino Ave
Crespi Ave
Rid
g
ew
o
od
RdRio
Rd
Franciscan Way
Ladera
Dr Delores St
Sycamore Pl
Atherton Dr
Trail View
Nindth Ave
Court of Golden Bough
Lasuen Dr

0.25 miles
0 Drive Test RSRP Signal Level (dBm)

VERIZON WIRELESS
2100 MHz MID BAND - ON AIR DRIVE (SCAN TEST) DATA
TESTED 2/19/2025
-95 <= X (48%)
-98 <= X < -95 (17%)
-101 <= X < -98 (10%)
-104 <= X < -101 (8%)
-150 <= X < -104 (17%)
Site sectors
Existing On Air Site
Proposed Site
Mid-Band Gap

0.27 Square Miles
Approved Site
10/10/2025 EXHIBIT D1
ATTACHMENT 8

Exhibit D2
Verizon Wireless 2100 MHz LTE (4G) Drive Test Map
SINR with Service Gap
10/10/2025
ATTACHMENT 8

VERIZON WIRELESS
2100 MHz MID BAND - ON AIR DRIVE (SCAN TEST) DATA
TESTED 2/19/2025
nio Ave
St
eal N
Casanova
onte Verde St St St s St StStSaSa
e St
Del Mar Ave
San Anton oi Ave
8th Ave
Ocean View Ave
Scenic Rd Martin
Way
Santa Lucia Ave
13th Ave
14th Ave
Val ey
View
Ave
C
arm
elo
St 7th Ave
Cam ni o Real 9th Ave
10th Ave
Casanova St 6th Ave
Ocean Ave
11th Ave
12th Ave
15th Ave
Inspiration Ave
Stewart Way
17th Ave
16th Ave
Walker Ave
Mountain View Ave
Torres St F
orest Rd Vizcaino Ave
Crespi Ave
Rid
g
ew
o
od
RdRio
Rd
Franciscan Way
Ladera
Dr Delores St
Sycamore Pl
Atherton Dr
Trail View
Nindth Ave
Court of Golden Bough
Lasuen Dr
0 0.25
miles
Drive Test SINR Signal Level (dB)
Site sectors
Existing On Air Site
Proposed Site
Mid-Band Gap

0.39 Square Miles
Approved Site
x > 20 Very Good High data rates, efficient use of spectrum (3%) 10 < x <= 20 Good Stable, decent throughput (23%)
5 < x <= 10 Fair Limited speeds, frequent retransmissions (27%) 0 < x <= 5 Poor Low throughput (37%)
x < 0 Very Poor Drop connections or no service (9%)
10/10/2025
ATTACHMENT 8

Exhibit E
Verizon Wireless 3700 MHz LTE (5G) Drive Test Map
10/10/2025
ATTACHMENT 8

nio Ave
St
eal N
Casanova
nte Verde St
St St s St StStSaSa
e St arpenter St
Del Mar Ave
San Anton oi Ave
8th Ave
Ocean View Ave
Scenic Rd Martin
Way
Santa Lucia Ave
13th Ave
14th Ave
Val ey
View
Ave
C
arm
elo
St 7th Ave
Cam ni o Real 9th Ave
10th Ave
Casanova St 6th Ave
Ocean Ave
11th Ave
12th Ave
15th Ave
Inspiration Ave
Stewart Way
17th Ave
16th Ave
Walker Ave
Mountain View Ave
Torres St F
orest Rd Vizcaino Ave
Crespi Ave
Rid
g
ew
o
od
RdRio
Rd
Franciscan Way
Ladera
Dr Delores St
Sycamore Pl
Atherton Dr
Trail View
Nindth Ave
Court of Golden Bough
Lasuen Dr
0 0.25
miles
Drive Test RSRP Signal Level (dBm)

VERIZON WIRELESS
3700 MHz MID C-BAND - ON AIR DRIVE (SCAN) RSRP DATA
TESTED 2/19/2025
Drive Test RSRP Signal Level (dBm)
-95 <= X (0%)
-98 <= X < -95 (0%)
-101 <= X < -98 (0%)
-104 <= X < -101 (0%)
-150 <= X < -104 (99%)
Site sectors
Existing On Air Site
Proposed Site
C-Band Gap

0.47 Square Miles
Approved Site
10/10/2025 EXHIBIT E
ATTACHMENT 8

Exhibit F
Verizon Wireless 700 MHz LTE (4G) Drive Test Map
Best Serving Transmitter
10/10/2025
ATTACHMENT 8

tonio Ave
lo
St
Real N
Casanova S Monte Verde St St s St os St St o StSan San
pe St
Del Mar Ave
San Anton oi Ave
8th Ave
Ocean View Ave
Scenic Rd Martin
Way
Santa Lucia Ave
13th Ave
14th Ave
Val ey
View
Ave
C
arm
elo
St 7th Ave
Cam ni o Real 9th Ave
10th Ave
Casanova St 6th Ave
Ocean Ave
11th Ave
12th Ave
15th Ave
Inspiration Ave
Stewart Way
17th Ave
16th Ave
Walker Ave
Mountain View Ave
Torres St F
orest Rd Vizcaino Ave
Crespi Ave
Rid
g
ew
o
od
RdRio
Rd
Franciscan Way
Ladera
Dr Delores St
Sycamore P
Atherton Dr
Trail View
Nindth Ave
Court of Golden Bough
Lasuen Dr

0.25 miles
0 VERIZON WIRELESS

BEST SERVING TRANSMITTER IN AREA OF GAP
Downtown Carmel Gamma (3) Sector - 10%
Founders Building Beta (2) Sector - 31%
Pebble Beach Tennis Club Beta (2) Sector - 5%
SF South Carmel 003 Alpha (1) Sector - 37%
SF South Carmel 003 Beta (2) Sector - 8%
Other Servers - 9%
Low Band - Best Serving Transmitter
Site sectors
Existing On Air Site
Proposed Site
Approved Site
10/10/2025
ATTACHMENT 8

Exhibit G
Verizon Wireless 2100 MHz LTE (4G) Drive Test Map
Best Serving Transmitter
10/10/2025
ATTACHMENT 8

nio Ave
St
eal N
Casanova
nte Verde St
St St s St StStSaS
e St
Del Mar Ave
San Anton oi Ave
8th Ave
Ocean View Ave
Scenic Rd Martin
Way
Santa Lucia Ave
13th Ave
14th Ave
Val ey
View
Ave
C
arm
e
ol St 7th Ave
Cam ni o Real 9th Ave
10th Ave
Casanova St 6th Ave
Ocean Ave
11th Ave
12th Ave
15th Ave
Inspiration Ave
Stewart Way
17th Ave
16th Ave
Walker Ave
Mountain View Ave
Torres St F
orest Rd Vizcaino Ave
Crespi Ave
Rid
g
ew
o
od
RdRio
Rd
Franciscan Way
Ladera
Dr Delores St
Sycamore Pl
Atherton Dr
Trail View
Nindth Ave
Court of Golden Bough
Lasuen Dr
0 0.25
miles

VERIZON WIRELESS

BEST SERVING TRANSMITTER IN AREA OF GAP
Downtown Carmel Gamma (3) Sector - 7.19%
Founders Building Beta (2) Sector - 41.56%
Pebble Beach Tennis Club Beta (2) Sector - 8.08%
SF South Carmel 003 Alpha (1) Sector - 28.19%
SF South Carmel 003 Beta (2) Sector - 5.35%
Other Servers - 9.64%
Mid Band - Best Serving Transmitters
Site sectors
Existing On Air Site
Proposed Site
Mid-Band Gap

0.27 Square Miles
Approved Site
10/10/2025
ATTACHMENT 8

Exhibit H
VoLTE Drop Call Rate (KPI) Analysis
10/10/2025
ATTACHMENT 8

Drop Call Data
Indicates that the drop rate exceeded 1% for approximately 93% of the 90 day time period. 0 5
10 15
20 25
11/15/2024 17:0011/17/2024 15:0011/19/2024 15:0011/21/2024 17:0011/23/2024 16:0011/25/2024 16:0011/27/2024 12:0011/29/2024 14:00 12/1/2024 18:0012/3/2024 15:0012/5/2024 17:0012/7/2024 16:0012/9/2024 15:00 12/11/2024 16:0012/13/2024 15:0012/15/2024 16:0012/17/2024 15:0012/19/2024 17:0012/21/2024 15:0012/23/2024 12:0012/25/2024 19:0012/27/2024 15:0012/29/2024 15:0012/31/2024 14:00 1/2/2025 16:001/4/2025 16:001/6/2025 15:001/8/2025 16:00 1/10/2025 15:001/12/2025 16:001/14/2025 15:001/16/2025 15:001/18/2025 18:001/20/2025 14:001/22/2025 15:001/24/2025 15:001/26/2025 16:001/28/2025 16:001/30/2025 15:00 2/1/2025 16:002/3/2025 15:002/5/2025 15:002/7/2025 15:002/9/2025 18:00 2/11/2025 15:00
Drop Call Rate (%)
Daily Busy Hour
Founders Building - Beta Sector
700 MHz VoLTE Drop Call Rate
Drop Rate (%)
1% Drop Call
Criteria
10/10/2025
ATTACHMENT 8

Indicates that the drop rate exceeded 1% for approximately 58% of the 90 day time period. 0 2
4 6
8 10
12 14
11/15/2024 17:0011/17/2024 15:0011/19/2024 15:0011/21/2024 17:0011/23/2024 16:0011/25/2024 16:0011/27/2024 12:0011/29/2024 14:00 12/1/2024 18:0012/3/2024 15:0012/5/2024 17:0012/7/2024 16:0012/9/2024 15:00 12/11/2024 16:0012/13/2024 15:0012/15/2024 16:0012/17/2024 15:0012/19/2024 17:0012/21/2024 15:0012/23/2024 12:0012/25/2024 19:0012/27/2024 15:0012/29/2024 15:0012/31/2024 14:00 1/2/2025 16:001/4/2025 16:001/6/2025 15:001/8/2025 16:00 1/10/2025 15:001/12/2025 16:001/14/2025 15:001/16/2025 15:001/18/2025 18:001/20/2025 14:001/22/2025 15:001/24/2025 15:001/26/2025 16:001/28/2025 16:001/30/2025 15:00 2/1/2025 16:002/3/2025 15:002/5/2025 15:002/7/2025 15:002/9/2025 18:00 2/11/2025 15:00
Drop Call Rate (%)
Daily Busy Hour
Founders Building - Beta Sector
850 MHz VoLTE Drop Call Rate
Drop Rate (%)
1% Drop Call
Criteria
10/10/2025
ATTACHMENT 8

Indicates that the drop rate exceeded 1% for approximately 56% of the 90 day time period. 0 1
2 3
4 5
6 11/15/2024 17:0011/17/2024 15:0011/19/2024 15:0011/21/2024 17:0011/23/2024 16:0011/25/2024 16:0011/27/2024 12:0011/29/2024 14:00 12/1/2024 18:0012/3/2024 15:0012/5/2024 17:0012/7/2024 16:0012/9/2024 15:00 12/11/2024 16:0012/13/2024 15:0012/15/2024 16:0012/17/2024 15:0012/19/2024 17:0012/21/2024 15:0012/23/2024 12:0012/25/2024 19:0012/27/2024 15:0012/29/2024 15:0012/31/2024 14:00 1/2/2025 16:001/4/2025 16:001/6/2025 15:001/8/2025 16:00 1/10/2025 15:001/12/2025 16:001/14/2025 15:001/16/2025 15:001/18/2025 18:001/20/2025 14:001/22/2025 15:001/24/2025 15:001/26/2025 16:001/28/2025 16:001/30/2025 15:00 2/1/2025 16:002/3/2025 15:002/5/2025 15:002/7/2025 15:002/9/2025 18:00 2/11/2025 15:00
Drop Call Rate (%)
Daily Busy Hour
Founders Building - Beta Sector
1900 MHz VoLTE Drop Call Rate
Drop Rate (%)
1% Drop Call
Criteria
10/10/2025
ATTACHMENT 8

Indicates that the drop rate exceeded 1% for approximately 47% of the 90 day time period. 0 2
4 6
8 10
12 14
16 18
20 11/15/2024 17:0011/17/2024 15:0011/19/2024 15:0011/21/2024 17:0011/23/2024 16:0011/25/2024 16:0011/27/2024 12:0011/29/2024 14:00 12/1/2024 18:0012/3/2024 15:0012/5/2024 17:0012/7/2024 16:0012/9/2024 15:00 12/11/2024 16:0012/13/2024 15:0012/15/2024 16:0012/17/2024 15:0012/19/2024 17:0012/21/2024 15:0012/23/2024 12:0012/25/2024 19:0012/27/2024 15:0012/29/2024 15:0012/31/2024 14:00 1/3/2025 15:001/5/2025 15:001/7/2025 15:001/9/2025 16:00 1/11/2025 18:001/13/2025 15:001/15/2025 15:001/17/2025 15:001/19/2025 14:001/21/2025 15:001/23/2025 15:001/25/2025 18:001/27/2025 15:001/29/2025 15:001/31/2025 15:00 2/2/2025 16:002/4/2025 15:002/6/2025 15:002/8/2025 17:00 2/10/2025 15:002/12/2025 15:00
Drop Call Rate (%)
Daily Busy Hour
SF South Carmel 003 - Alpha Sector
700 MHz VoLTE Drop Call Rate
Drop Rate (%)
1% Drop Call
Criteria
10/10/2025
ATTACHMENT 8

Indicates that the drop rate exceeded 1% for approximately 18% of the 90 day time period. 0 2
4 6
8 10
12 14
11/15/2024 17:0011/17/2024 15:0011/19/2024 15:0011/21/2024 17:0011/23/2024 16:0011/25/2024 16:0011/27/2024 12:0011/29/2024 14:00 12/1/2024 18:0012/3/2024 15:0012/5/2024 17:0012/7/2024 16:0012/9/2024 15:00 12/11/2024 16:0012/13/2024 15:0012/15/2024 16:0012/17/2024 15:0012/19/2024 17:0012/21/2024 15:0012/23/2024 12:0012/25/2024 19:0012/27/2024 15:0012/29/2024 15:0012/31/2024 14:00 1/3/2025 15:001/5/2025 15:001/7/2025 15:001/9/2025 16:00 1/11/2025 18:001/13/2025 15:001/15/2025 15:001/17/2025 15:001/19/2025 14:001/21/2025 15:001/23/2025 15:001/25/2025 18:001/27/2025 15:001/29/2025 15:001/31/2025 15:00 2/2/2025 16:002/4/2025 15:002/6/2025 15:002/8/2025 17:00 2/10/2025 15:002/12/2025 15:00
Drop Call Rate (%)
Daily Busy Hour
SF South Carmel 003 - Alpha Sector
850 MHz VoLTE Drop Call Rate
Drop Rate (%)
1% Drop Call
Criteria
10/10/2025
ATTACHMENT 8

Exhibit I
Downlink Throughput (KPI) Analysis
10/10/2025
ATTACHMENT 8

Downlink Throughput Data
Indicates that the downlink throughput falls below 5 Mbps for approximately 88% of the 90 day time period. 0 1
2 3
4 5
6 7
8 11/15/2024 17:0011/17/2024 15:0011/19/2024 15:0011/21/2024 17:0011/23/2024 16:0011/25/2024 16:0011/27/2024 12:0011/29/2024 14:00 12/1/2024 18:0012/3/2024 15:0012/5/2024 17:0012/7/2024 16:0012/9/2024 15:00 12/11/2024 16:0012/13/2024 15:0012/15/2024 16:0012/17/2024 15:0012/19/2024 17:0012/21/2024 15:0012/23/2024 12:0012/25/2024 19:0012/27/2024 15:0012/29/2024 15:0012/31/2024 14:00 1/2/2025 16:001/4/2025 16:001/6/2025 15:001/8/2025 16:00 1/10/2025 15:001/12/2025 16:001/14/2025 15:001/16/2025 15:001/18/2025 18:001/20/2025 14:001/22/2025 15:001/24/2025 15:001/26/2025 16:001/28/2025 16:001/30/2025 15:00 2/1/2025 16:002/3/2025 15:002/5/2025 15:002/7/2025 15:002/9/2025 18:00 2/11/2025 15:00
Downlink Throughput (Mbps)
Daily Busy Hour
Founders Building - Beta Sector
700 MHz LTE Downlink Throughput
Average DL
Throughput
5 Mbps DL
Throughput
Criteria
10/10/2025
ATTACHMENT 8

Indicates that the downlink throughput falls below 5 Mbps for approximately 10% of the 90 day time period. 0 5
10 15
20 25
11/15/2024 17:0011/17/2024 15:0011/19/2024 15:0011/21/2024 17:0011/23/2024 16:0011/25/2024 16:0011/27/2024 12:0011/29/2024 14:00 12/1/2024 18:0012/3/2024 15:0012/5/2024 17:0012/7/2024 16:0012/9/2024 15:00 12/11/2024 16:0012/13/2024 15:0012/15/2024 16:0012/17/2024 15:0012/19/2024 17:0012/21/2024 15:0012/23/2024 12:0012/25/2024 19:0012/27/2024 15:0012/29/2024 15:0012/31/2024 14:00 1/2/2025 16:001/4/2025 16:001/6/2025 15:001/8/2025 16:00 1/10/2025 15:001/12/2025 16:001/14/2025 15:001/16/2025 15:001/18/2025 18:001/20/2025 14:001/22/2025 15:001/24/2025 15:001/26/2025 16:001/28/2025 16:001/30/2025 15:00 2/1/2025 16:002/3/2025 15:002/5/2025 15:002/7/2025 15:002/9/2025 18:00 2/11/2025 15:00
Downlink Throughput (Mbps)
Daily Busy Hour
Founders Building - Beta Sector
850 MHz LTE Downlink Throughput
Average DL
Throughput
5 Mbps DL
Throughput
Criteria
10/10/2025
ATTACHMENT 8

Indicates that the downlink throughput falls below 5 Mbps for approximately 39% of the 90 day time period. 0 2
4 6
8 10
12 14
16 18
20 11/15/2024 17:0011/17/2024 15:0011/19/2024 15:0011/21/2024 17:0011/23/2024 16:0011/25/2024 16:0011/27/2024 12:0011/29/2024 14:00 12/1/2024 18:0012/3/2024 15:0012/5/2024 17:0012/7/2024 16:0012/9/2024 15:00 12/11/2024 16:0012/13/2024 15:0012/15/2024 16:0012/17/2024 15:0012/19/2024 17:0012/21/2024 15:0012/23/2024 12:0012/25/2024 19:0012/27/2024 15:0012/29/2024 15:0012/31/2024 14:00 1/2/2025 16:001/4/2025 16:001/6/2025 15:001/8/2025 16:00 1/10/2025 15:001/12/2025 16:001/14/2025 15:001/16/2025 15:001/18/2025 18:001/20/2025 14:001/22/2025 15:001/24/2025 15:001/26/2025 16:001/28/2025 16:001/30/2025 15:00 2/1/2025 16:002/3/2025 15:002/5/2025 15:002/7/2025 15:002/9/2025 18:00 2/11/2025 15:00
Downlink Throughput (Mbps)
Daily Busy Hour
Founders Building - Beta Sector
1900 MHz LTE Downlink Throughput
Average DL
Throughput
5 Mbps DL
Throughput
Criteria
10/10/2025
ATTACHMENT 8

Exhibit J
Verizon's Existing Coverage with Approved Sites
Coverage
10/10/2025
ATTACHMENT 8

Mission St L ni coln St Monte Verde St
nio Ave
St
eal N
Casanova St s St StSaSSt arpenter St
Del Mar Ave
San Anton oi Ave
8th Ave
Ocean View Ave
Scenic Rd Martin
Way
Santa Lucia Ave
13th Ave
14th Ave
Val ey
View
Ave
C
arm
elo
St 7th Ave
Cam ni o Real 9th Ave
10th Ave
Casanova St 6th Ave
11th Ave
12th Ave
15th Ave
Inspiration Ave
Stewart Way
17th Ave
16th Ave
Walker Ave
Torres St Mountain View Ave
Ocean Ave
F
orest Rd Vizcaino Ave
Crespi Ave
Rid
g
ew
o
od
RdRio
Rd
Franciscan Way
Ladera
Dr Delores St
Sycamore Pl
Atherton Dr
Trail View
Nindth Ave
Lasuen Dr

0.25 miles
0 -95 <= X
Coverage from Existing and Approved Sites
RSRP Signal Level (dBm)
Site sectors
Existing On Air Site
Proposed Site
Mid-Band Gap

0.27 Square Miles
Approved Site
Alternate Site - Golden Bough Playhouse

VERIZON WIRELESS
2100 MHz MID BAND - COVERAGE FROM APPROVED SITES

AND EXISTING SITES
10/10/2025
ATTACHMENT 8

Exhibit K
Verizon's Existing Coverage with Approved and Proposed
Sites Coverage
10/10/2025
ATTACHMENT 8

Mission
St L ni coln St Monte Verde St
nio Ave
St
eal N
Casanova St s St StSaSa
e St arpenter St
Del Mar Ave
San Anton oi Ave
8th Ave
Ocean View Ave
Scenic Rd Martin
Way
Santa Lucia Ave
13th Ave
14th Ave
Val ey
View
Ave
C
arm
elo
St 7th Ave
Cam ni o Real 9th Ave
10th Ave
Casanova St 6th Ave
11th Ave
12th Ave
15th Ave
Inspiration Ave
Stewart Way
17th Ave
16th Ave
Walker Ave
Torres St Mountain View Ave
Ocean Ave
F
orest Rd Vizcaino Ave
Crespi Ave
Rid
g
ew
o
od
RdRio
Rd
Franciscan Way
Ladera
Dr Delores St
Sycamore Pl
Atherton Dr
Trail View
Nindth Ave
Lasuen Dr

0.25 miles
0 RSRP Signal Level (dBm)
Site sectors
Existing On Air Site
Proposed Site
Mid-Band Gap

0.27 Square Miles
Approved Site
Alternate Site - Golden Bough Playhouse

VERIZON WIRELESS
2100 MHz MID BAND - ON AIR DRIVE (SCAN TEST) DATA
TESTED 2/19/2025
2100 MHz MID BAND - COVERAGE FROM EXISTING,
PROPOSED (49 FEET AGL), AND APPROVED SITES
-95 <= X
Coverage from Existing and Approved Sites
-95 <= X
Coverage from Proposed Site
10/10/2025
ATTACHMENT 8

Exhibit L
Verizon's Existing Coverage with Approved and
Alternative Coverage – Small Cell
10/10/2025
ATTACHMENT 8

Mission
St Monte Verde St L ni coln StJunipero St
nio Ave
St
eal N
Casanova St s St TSaSt an at Ri at St
Del Mar Ave
San Anton oi Ave
8th Ave
Ocean View Ave
Scenic Rd Martin
Way
Santa Lucia Ave
13th Ave
14th Ave
Val ey
View
Ave
C
arm
elo
St 7th Ave
Cam ni o Real 9th Ave
10th Ave
Casanova St 6th Ave
11th Ave
12th Ave
15th Ave
Inspiration Ave
Stewart Way
17th Ave
16th Ave
Walker Ave
Ocean Ave
Mountain View Ave
F
orest Rd Vizcaino Ave
Crespi Ave
Rid
g
ew
o
od
RdRio
Rd
Franciscan Way
Ladera
Dr Delores St
Sycamore Pl
Atherton Dr
Trail View
Nindth Ave
Lasuen Dr

0.25 miles
0 RSRP Signal Level (dBm)
Site sectors
Existing On Air Site
Proposed Site
Mid-Band Gap

0.27 Square Miles
Approved Site
Alternate Site - Golden Bough Playhouse

VERIZON WIRELESS
2100 MHz MID BAND - ON AIR DRIVE (SCAN TEST) DATA
TESTED 2/19/2025
2100 MHz MID BAND - COVERAGE FROM EXISTING,
ALTERNATE (SMALL CELL AT 20 FEET AGL), AND APPROVED SITES -95 <= X
Coverage from Existing and Approved Sites
-95 <= X
Coverage from Alternate Site
10/10/2025
ATTACHMENT 8

Exhibit M
Verizon's Existing Coverage with Approved and
Alternative Coverage - Sectors
10/10/2025
ATTACHMENT 8

Monte Verde St Mission
St Lincoln St nio Ave
St
eal N
Casanova St s St StSa
e St an at Ri at St arpenter St
Del Mar Ave
San Anton oi Ave
8th Ave
Ocean View Ave
Scenic Rd Martin
Way
Santa Lucia Ave
13th Ave
14th Ave
Val ey
View
Ave
C
arm
elo
St 7th Ave
Cam ni o Real 9th Ave
10th Ave
Casanova St 6th Ave
11th Ave
12th Ave
15th Ave
Inspiration Ave
Stewart Way
17th Ave
16th Ave
Walker Ave
Torres St Mountain View Ave
F
orest Rd Vizcaino Ave
Crespi Ave
Rid
g
ew
o
od
RdRio
Rd
Franciscan Way
Ladera
Dr Delores St
Sycamore Pl
Atherton Dr
Trail View
Nindth Ave
Lasuen Dr
0 0.25
miles
Drive Test RSRP Signal Level (dBm)
Site sectors
Existing On Air Site
Proposed Site
Mid-Band Gap

0.27 Square Miles
Approved Site
Alternate Site - Golden Bough Playhouse

VERIZON WIRELESS
2100 MHz MID BAND - ON AIR DRIVE (SCAN TEST) DATA
TESTED 2/19/2025
2100 MHz MID BAND - COVERAGE FROM EXISTING,
ALTERNATE (MACRO SITE AT 20 FEET AGL), AND APPROVED SITES -95 <= X
Coverage from Existing and Approved Sites
-95 <= X
Coverage from Alternate Site
10/10/2025
ATTACHMENT 8

Exhibit M1
Zoning Map with Verizon Sites and Mid Band Gap
10/10/2025
ATTACHMENT 8

10/10/2025
ATTACHMENT 8

Exhibit M2
Google Earth Image with Utility Pole Locations
and Mid Band Gap Area
10/10/2025
ATTACHMENT 8

10/10/2025 EXHIBIT M2 Page 44 of 44
ATTACHMENT 8

Radio Frequency Supplemental Report
Site ID: “Carmel Node 001”
RF Supplemental Report
Carmelo Street
Carmel-by-the-Sea, CA 93921
Monterey County
Prepared for
Verizon Wireless
By
PierCon Solutions, LLC
November 19, 2025
10 PARK PLACE BUILDING 6C SUITE 402, BUTLER, NJ 07405 PHONE 973-628-9330 ATTACHMENT 8

Table of Contents
Introduction ....................................................................................................................................................................... 3

1. Section 15.2.2 – Materially Inhibits Claim ................................................................................................... 3

2. Compliance with Section 15.2.2 Requirements ......................................................................................... 3

3. Technical Background and Need for the Proposed Small Cell ............................................................ 4

4. Effect of Denial on Meeting Service and Performance Goals ............................................................... 6

5. Clarification Regarding SF South Carmel 002 and 005 ........................................................................... 7

6. Conclusion ................................................................................................................................................................. 8

ATTACHMENT 8

Introduction
This Supplemental Radio Frequency report is submitted in response to the City of Carmel-by-theSea’s request for clarification under Section 15.2.2 of the Wireless Application Checklist. It confirms PierCon Solutions’ compliance with each element of the City’s materially inhibits claim requirements and addresses both radio frequency questions posed by the City. This supplemental report reaffirms that the proposed small wireless facility is technically necessary to introduce new 5G service, including Verizon’s licensed C-Band (3700 MHz), densify the network with mid-band coverage, remedy a significant gap in service and ensure Verizon Wireless can operate its licensed network within a fair and balanced regulatory environment.

1. Section 15.2.2 – Materially Inhibits Claim
Section 15.2.2 of the Carmel Wireless Application Checklist (Adopted August 23, 2023) requires applicants asserting a material inhibition claim to provide the following information:
 A street-level map showing the geographic area of service to be densified, improved, or expanded.
 Full-color signal propagation maps, in scale, for all active frequencies with clear signallevel legends.  A written narrative describing the new or improved services, the area’s land use, and potential user impact if unaddressed.
 All drive test results and supporting reports describing methodology.  An explanation demonstrating how inability to meet the identified goals would materially inhibit the carrier’s ability to operate in a fair and balanced regulatory environment.

2. Compliance with Section 15.2.2 Requirements
City Requirement (Section 15.2.2) PierCon Exhibit(s) and Response Summary Street-level map of Service Area Exhibit C2 – Low band SINR map demonstrating .43 square mile service gap.

Exhibit D2 - Mid band SINR map demonstrating
.39 square mile service gap.

Exhibit E - Mid band (3700) RSRP map
demonstrating .47 square mile service gap.

Full-color signal propagation maps Exhibits C, C1, C2, D, D1, D2, and E provide all measured RSRP and SINR drive-test data at street
level in accordance with Section 15.2.2
Exhibits K-M – Include before/after coverage
maps, existing vs. proposed signal levels, and
modeled performance at 2100 MHz mid-band.

ATTACHMENT 8

One of the mid-band frequencies necessary for
densification.

Written narrative describing
new/improved service
Report Section 3 describes the service and
performance goals. Noting the need to add new
services (3700 MHz), 5G, and densify the network
with mid-band service. Provide residential
inbuilding service to the area.

Report Section 10 describes the improvements
made through the use of the proposed small cell.

Drive test data and methodology Report Section 6 - Provides detailed description of the drive test data and methodology.

Report Exhibits - C, C1, C2, D, D1, D2, and E
provided demonstrate the results of the drive
testing
Explanation of material inhibition
(technical impact)
Section 4 of this supplement provides the
required explanation of material inhibition,
demonstrating how a denial would prevent
Verizon from meeting its service and performance
objectives consistent with 47 U.S.C. §
332(c)(7)(B)(i)(II).

3. Technical Background and Need for the Proposed Small Cell PierCon’s independent RF engineering analysis (October 14, 2025) demonstrates that Verizon Wireless’s existing network in Carmel-by-the-Sea experiences substandard RSRP (< –95 dBm) and SINR (< 10 dB) values, resulting in poor in-building coverage, low throughput (< 5 Mbps), and call-drop rates exceeding 1%. This is evident in both low-band and mid-band frequencies.

Verizon’s technical approach for improving service to this area is through small cells. This is evident as there is already two approved, but unbuilt small cells (SF South Carmel 002 and 005) which will address only a portion of the residential area. The proposed facility is required as part of Verizon’s small cell design to provide continuous reliable mid-band coverage and enable new 5G C-Band service, working in conjunction with the already approved small cells.

Macro sites, as pointed out in the initial RF report (section 3 page 7 paragraph 2), are much more extensive installations as compared to small cells, and are not the method Verizon is using to improve services and provide new services to this dense residential area. Verizon’s method is through the deployment of strategically placed small cells. Each small cell provides a small area of coverage and capacity. To provide full coverage to the residential area, a series of small cells must be deployed to serve individual micro-coverage zones while limiting excessive overlap into adjacent sectors. As noted in the RF report, two (2) small cells in the adjacent ATTACHMENT 8

residential area have been approved (SF South Carmel 002 and 005), and this is the next in the series of small cells; see Exhibit K. This is Verizon’s design for this area.

Section 8, paragraph 3 of the RF report, describes the current small cell design which consists of the two approved small cells (002 and 005) that will serve a portion of the gap, along with the proposed small cell (001) which is geographically placed to work with those two approved small cells and the 57’ rooftop identified as SF Carmel 003 (see Exhibit J). Exhibit J demonstrates the location of the Small Cell (001) fits well within the existing and proposed mid-band coverage; i.e. meets the RF engineering geometric grid plan. Exhibit K demonstrates the proposed Small Cell 001 mid-band coverage operates efficiently with the existing and proposed mid-band coverage from SF South Carmel 002 and 005. The purpose of these small cells is to provide mid-band service and capacity (densification) as well as new 5G services and new C-band (3700 MHz frequency band signal).

There is no viable alternative to the small cell SF-001 proposed to be located between 10th and 11th Avenue on Carmelo Street. Macro sites on private property are not an option (refer to Verizon Alternatives Analysis South Carmel Small Cell 001 section IX (B.) for discussion regarding macro sites). Alternate pole locations would need to be near the current proposed small cell pole and as per the Verizon Alternative Analysis South Carmel Small Cell 001 section X (E. & F.) from 27 alternative pole locations 15 were discounted due to infeasibility of use, and another 12 were discounted due to being more intrusive.

Without approval, Verizon cannot densify its network, or introduce new technologies such as 3700 MHz and 5G. Such denial would constitute a material inhibition under the FCC’s 2018 Declaratory Ruling (WT Docket 17-79, WC Docket 17-84), which defines effective prohibition as any action that materially inhibits a provider’s ability to densify, expand, add new services, or improve its network. As stated in FCC Declaratory Ruling (2018) ¶37, the selection of technology, facility type, spectrum layer, and network architecture is determined by the wireless provider, not the locality. Furthermore, the small cell design is the least intrusive design whereby it blends well with the existing utility pole infrastructure while not impeding any foot-traffic along the right-of-way as all equipment is neatly installed on the pole. See ATTACHMENT 8

illustration below for reference:

4. Effect of Denial on Meeting Service and Performance Goals Verizon Wireless’ service and performance objectives for this area are based on its RF design standards, which establish minimum in-building RSRP better than –95 dBm, acceptable SINR for reliable data performance, and median downlink throughput consistent with modern 5G service tiers. Current drive test measurements in the Carmel-by-the-Sea service area show that although low-band signal exists, the network does not meet required performance thresholds, with SINR typically below 10 dB and median throughput generally below 5 Mbps during busy hours.

The proposed facility is required to introduce the mid-band (3.7 GHz) layer that provides the spectral efficiency and bandwidth necessary for Verizon to achieve its identified service and performance goals. Without this facility, the network remains constrained to low-band operation only and cannot meet Verizon’s engineering design targets for 5G performance, capacity, or in-building reliability. Low-band coverage alone cannot meet Verizon’s 5G design thresholds for throughput, latency, or in-building performance, and therefore does not satisfy the service-level objectives for this area.

ATTACHMENT 8

From an RF engineering perspective, denial of the application would materially inhibit Verizon’s ability to:
 densify the network to meet projected traffic demand;  utilize its FCC-licensed mid-band spectrum in this service area; and  implement the layered spectrum architecture required for modern 5G performance.

This conclusion is based solely on measurable RF performance metrics and Verizon’s documented service objectives. These RF engineering performance thresholds are applied uniformly across Verizon’s national network and form the technical basis for system design, regardless of geographic area. The inhibition described is technical in nature, not a comparison to other carriers: it reflects the inability to implement the required network architecture and spectrum utilization necessary for Verizon to operate its system as designed within the current legal and regulatory framework.

5. Clarification Regarding SF South Carmel 002 and 005
In response to the City’s second question regarding approved but unbuilt sites:

SF South Carmel 002 and SF South Carmel 005 are listed as approved in the site table and noted on all drive-test exhibits (A through G). They are not yet operational and therefore do not contribute to measured drive or KPI data.

Exhibits J, K, L, and M illustrate modeled future coverage including those approved nodes, identified as follows:
 Exhibit J – Coverage from Existing and Approved Sites  Exhibit K – Coverage from Existing, Approved, and Proposed (49 ft AGL)  Exhibit L – Coverage from Existing, Approved, and Alternate (Small Cell 20 ft AGL)  Exhibit M – Coverage from Existing, Approved, and Alternate (Macro 20 ft AGL) ATTACHMENT 8

6. Conclusion
The data and documentation provided by PierCon Solutions satisfy every element of Section 15.2.2. The proposed small wireless facility is technically necessary, the least intrusive means to close the identified gap, and essential for Verizon Wireless to maintain engineered service objectives and lawful use of its licensed spectrum. Denying this application would materially inhibit Verizon’s ability to densify, deploy 5G C-Band, and operate in a fair and balanced legal and regulatory environment.

Prepared by:

Richard Conroy
President / Principal RF System Engineer
PierCon Solutions, LLC
November 19, 2025
Ronald Lukach
Senior RF Engineer
PierCon Solutions, LLC
Date: November 19, 2025
ATTACHMENT 8

Alternatives Analysis
South Carmel Small Cell 001
Carmelo Street between 10th Avenue & 11th Avenue
Carmel-by-the-Sea, California
October 14, 2025
Summary of Site Evaluations
Conducted by Verizon Wireless
Exhibit G
ATTACHMENT 8

2 TABLE OF CONTENTS
I. Executive Summary .............................................................................................. 3 II. Site History ............................................................................................................ 3 III. Search Area ........................................................................................................... 3 IV. Map of Utility Poles Considered .......................................................................... 4 V. Technical Feasibility Considerations .................................................................. 5 VI. Federal and State Law .......................................................................................... 5 VII. Carmel Municipal Code ....................................................................................... 6 A. Location Preferences ................................................................................. 6 B. Structure Preferences ................................................................................ 6 C. Design Standards and Exceptions ............................................................. 6 VIII. Evaluation of Preferred Zones ............................................................................. 8 IX. Evaluation of Collocation and Private Property .............................................. 10 A. Collocation ............................................................................................... 10 B. Macro Facility or Small Cell Facility on Private Property .................... 10 X. Evaluation of Utility Poles in the Right-of-Way ............................................... 12 A. Preferred Option – Small Cell on an Existing Utility Pole .................... 12 B. Least Compatible Option – New Stand-Alone Pole ................................ 12 C. Summary of Site-Specific Evaluation ..................................................... 12 D. Proposed Facility (Alternative 1) ............................................................. 13 E. Poles Discounted Due to Infeasibility (Alternatives 2-16) ..................... 14 F. Poles Discounted as More Intrusive (Alternatives 17-28) ...................... 22 XI. Conclusion ........................................................................................................... 35 ATTACHMENT 8

3 I. Executive Summary
To improve network service and fill a gap in service in western Carmel-by-the-Sea, Verizon Wireless proposes to install a small cell wireless facility on a utility pole in the right-of-way of Carmelo Street between 10th and 11th Avenue (the “Proposed Facility”). Verizon Wireless first searched the area for private property and collocation candidates. It found no technically feasible nor available alternative that was more compatible than the Proposed Facility. Verizon Wireless then analyzed 28 potential utility poles in the public right-of-way within the target search area. A map depicting the locations of these utility poles is found on Page 4.

After careful review, Verizon Wireless determined that the Proposed Facility is the least intrusive, technically feasible alternative in the right-of-way to improve network service and fill the significant gap, based on requirements of the Carmel Municipal Code (the “Code”) and Administrative Wireless Facility Design Guidelines (the “Guidelines”).

II. Site History
In 2018, Verizon Wireless identified a significant gap in western Carmel-by-the-Sea area. Since then, Verizon Wireless has sought to improve 4G services, fill a gap, and provide new 5G services to the area. Verizon Wireless initially proposed a network of five small cell wireless facilities. Through a series of compromises, litigation, and settlements over nearly a decade, three facilities have been either built or permitted and slated to be built. These accommodations included relocating two facilities outside of the City limits and placing another facility on private property, adversely affecting optimal network design. This application addresses the last remaining site required to complete Verizon Wireless’s original 2018 coverage objective. In addition to filling the previously identified gap, the Proposed Facility will introduce new services, improve existing services, and cure an insufficiency in network capacity.

III. Search Area
The Verizon Wireless network provides limited service in western Carmel. However, due to the exponential growth of mobile devices and increased mobile data traffic across the entire Verizon Wireless network, Verizon Wireless must improve and augment its network. The lack of adequate coverage from existing wireless facilities results in poor service such as poor call quality or inability to access the network altogether.

Verizon Wireless commissioned PierCon Solutions, LLC to conduct a drive test on February 19, 2025, and evaluate its service levels in western Carmel. In an October 2025 report, PierCon determined that the Proposed Facility is required to introduce new services, improve existing services and network capacity, and add 5G service. PierCon also confirmed the gap in Verizon Wireless network coverage and capacity in the area and the lack of a dominant signal. It found inadequate service, particularly in the midband frequency range.

Verizon Wireless must install a new facility to ensure reliable network service. PierCon determined that the optimal location for a new facility to improve service and fill the significant gap is an area bounded by 10th Avenue to the north, Camino Real to the east, 11th Avenue to the south, and Carmelo Street to the west. According to PierCon, a ATTACHMENT 8

4 wireless facility in this search area would minimize coverage overlap with existing and approved facilities and maximize the ability to provide new 5G services.

IV. Map of Utility Poles Considered
With these parameters in mind, Verizon Wireless reviewed zoning districts preferred by the Code, potential collocation, and private property locations. Because those options are infeasible, Verizon Wireless analyzed 28 utility poles in the right-of-way in the search area defined by PierCon. The utility pole locations are shown on the following map.

ATTACHMENT 8

5 V. Technical Feasibility Considerations
Attachments to utility poles are subject to California Public Utilities Commission (“CPUC”) Rules for Overhead Electric Line Construction, General Order No. 95 (“GO 95”), which imposes strict rules for equipment placement and safe utility worker climbing space. GO 95 includes standards for placement of wireless facility antennas and associated equipment. For example, pole-top antennas and their mounting hardware must be elevated at least six feet above electric conductors. GO 95 Rule 94.4.

Additionally, PG&E has adopted numerous rules for attachments to electric utility poles. For example, PG&E prohibits antennas and communication equipment on utility poles with PG&E distribution equipment such as transformers, line cutouts, and primary risers. See, e.g., PG&E Installation Details for Service to PoleMounted Communication Equipment, Document 027911 Rev #15, June 30, 2023 (“PG&E Standard 027911”). Verizon Wireless must comply with PG&E’s rules to place wireless equipment on utility poles. Both the CPUC and PG&E rules and regulations have been accounted for in this analysis.

VI. Federal and State Law
The Federal Communications Commission (“FCC”) defines “small wireless facilities” with certain dimension and height thresholds, providing for extension of existing structures up to 50 feet or by 10 percent, whichever greater, as well as new structures up to 50 feet tall or 10 percent taller than adjacent structures. Accessory (non-antenna) equipment is limited to 28 cubic feet. 47 C.F.R. § 1.6002(l).

The FCC determined that a local government’s aesthetic criteria for small cells must be “reasonable,” that is, technically feasible and meant to avoid “out-of-character” deployments, and also “published in advance.” See Accelerating Wireless Broadband Deployment by Removing Barriers to Infrastructure Investment, Declaratory Ruling and Third Report and Order, 33 FCC Rcd. 9088, ¶¶ 86-88 (September 27, 2018). The FCC also found that local regulations that “materially inhibit” service improvements constitute a prohibition of service that violates the federal Telecommunications Act. Id., ¶ 37; see also 47 U.S.C. §§ 253(a), 332(c)(7)(B)(i)(II).

California Public Utilities Code Section 7901 grants telephone corporations a statewide right to place their telephone equipment along any public right-of-way.

ATTACHMENT 8

6 VII. Carmel Municipal Code
A. Location Preferences
The Code imposes ranked location preferences as follows, ordered most-favored to leastfavored:
• CC and SC commercial zones, A-2 cultural zone (Tier III) • P-2 and P-1 parkland zones, A-1 theatrical zone (Tier II) • R-1, R-4, and RC residential zones, A-3 senior citizen facility zone (Tier I) Applicants proposing facilities in the Tier I and II locations must show that no locations in a Tier III location are technically feasible and available. Code § 17.46.040(B).

The Code considers locations in the right-of-way of the R-1 single-family residential district to be highly incompatible locations, requiring a special exception request and special findings. Code §§ 17.46.040(E)(1), 17.46.080(C).

The Code prefers placement on public/private parcels over the right-of-way. Code §

17.46.040(C). However, that preference is preempted by California Public Utilities Code Section 7901, which grants telephone corporations such as Verizon Wireless a statewide franchise right to place their equipment along any right-of-way. In any event, placement of a wireless facility on a private single-family residential property is infeasible in the search area due to the Code’s height and setback requirements, as discussed in Section IX(B) below.

Furthermore, requiring a wireless carrier to place a wireless facility on private property rather than in the right-of-way would unnecessarily require that carrier to incur the cost associated with the delay and expense of finding a willing landlord, if one exists. Even if a landlord was identified, the carrier would again incur costs associated with the delay and expense associated with negotiating a lease, as well as ongoing costly rental payments and restrictive terms not required for the right-of-way. The additional delay, expense, and burdens of a lease would “materially inhibit” service improvements in violation of the Telecommunications Act. In contrast, Verizon Wireless can attach its equipment to utility poles as a member of the Northern California Joint Pole Association (“JPA”), with lower deployment costs and an established, expedited approval process.

B. Structure Preferences
In the right-of-way, existing/replacement structures are preferred over new structures of any type. Code § 17.46.040(D)(2).

C. Design Standards and Exceptions
Both the Code and Guidelines impose numerous design standards, special considerations, and other preferences, which express the City’s values related to aesthetics. The Code requires approval of an exception for certain standards not met by a proposed wireless facility. The exception findings require an applicant to prove that that denial of a ATTACHMENT 8

7 proposed facility would constitute a prohibition of service or otherwise violate federal or state law. Code § 17.46.080(C)(2). The more exceptions required, the more intrusive a proposed or alternative location.

ATTACHMENT 8

8 VIII.Evaluation of Preferred Zones
Verizon Wireless first considered locations in zones preferred according to the Code, as follows. The preferred zones are all northeast or east beyond the significant gap area and are infeasible for a new small cell.

Tier III Locations (Preferred). Per the Code, applicants proposing a Tier I or II location must show that no Tier III location is technically feasible or available. Verizon Wireless reviewed the Tier III zones as follows.

CC. The closest location is 0.4 miles
northeast of the Proposed Facility, and only
400 feet southwest of the Verizon Wireless’s
existing Downtown Carmel facility. A
wireless facility here would duplicate the
coverage of that facility.

SC. The closest location is 0.35 miles
northeast of the Proposed Facility, and only
580 feet southwest of the Downtown Carmel
facility. A wireless facility here would
duplicate the coverage of that facility.

A-2. The closest location is 0.3 miles east of
the Proposed Facility. This zone is the
location of Verizon Wireless’s Sunset
Center facility. A wireless facility here
would duplicate part of the coverage of that
facility.

Tier II Locations. Verizon Wireless also
considered Tier II zones, though the Code
does not require a showing that these are
infeasible.

P-1. The closest location is 0.5 miles east of the Proposed Facility, the Mission Trail Nature Preserve. This is even farther east than Verizon Wireless’s Sunset Center facility, which cannot serve the significant gap in service in western Carmel. A wireless facility in the more distant P-1 zone likewise could not serve the gap. Additionally, Verizon Wireless has already planned a small cell facility in unincorporated Monterey County east of this zone.

P-2. The closest location is 0.4 miles northeast of the Proposed Facility, and only 170 feet west of the Downtown Carmel facility. A wireless facility here would duplicate the coverage of that facility.

Preferred Zones Closest to Proposed Facility
ATTACHMENT 8

9 A-1. The closest A-1 zone is 0.2 miles northeast of the Proposed Facility, the Golden Bough Playhouse property. The Golden Bough property is beyond the search area. A rooftop or tower facility on this private property would be limited to 34 feet in height.

Code §§ 17.10.030(B), 17.18.100, 17.46.040(F)(1)(b), Guidelines § I(B)(2). At 15 feet less than the Proposed Facility height, a 34-foot facility would provide much less coverage and could not serve the gap. Located 0.25 miles southwest of Verizon Wireless’s existing Downtown Carmel facility, a wireless facility here would duplicate some of the coverage of that facility. The area east along Monte Verde Street in front of the Playhouse is private property, not right-of-way, and lacks utility poles.

Due west of the Golden Bough Playhouse, the two existing utility poles in the A-1 zone along Casanova Street, shown in the photographs below, are both infeasible and unavailable due to primary risers and a transformer that preclude installation of a wireless facility per PG&E rules. As described above, a new stand-alone pole next to the Golden Bough Playhouse would be more intrusive than the Proposed Facility, because a new structure is the least-preferred structure option in the right-of-way.

Lacking feasible alternatives in preferred zones, Verizon Wireless examined rights-ofway in the search area within the Tier I R-1 zone.

Infeasible Utility Poles in A-1 Zone
Behind Golden Bough Playhouse, Casanova Street
ATTACHMENT 8

10 IX. Evaluation of Collocation and Private Property
A. Collocation
Verizon Wireless first looked for opportunities for collocation, as encouraged by the Code. Code § 17.46.040(F)(1)(k). It found no viable options in the search area. The only existing wireless facilities sites nearby are on rooftops that already support Verizon Wireless facilities: the Downtown Carmel facility and Node 003 on Sunset Center. As explained in the PierCon report, those facilities do not serve the gap.

B. Macro Facility or Small Cell Facility on Private Property Verizon Wireless could not identify a viable larger “macro” facility alternative to serve the gap. Macro facilities generally require too large of a footprint to be in the public right-of-way. A macro facility would need to be installed on private property in the search area, where the only structures are single-family homes. The Code and Guidelines render a facility on private property to be technically infeasible for several reasons.

First, it is highly unusual to place a wireless facility on rooftops of private homes, or on a new tower adjacent to a home, especially in a jurisdiction such as Carmel where the lot sizes are relatively small and the homes are close together. A wireless facility also requires a secure, fenced lease area in which macro wireless towers are typically placed along with equipment cabinets and other network gear, with space for safe worker access and maintenance.

The Code and Guidelines limit wireless facilities on private property to 10 feet over the zone height limit, which is 24 feet in the surrounding R-1 zone, allowing a total facility height of only 34 feet. Code §§ 17.10.030(B), 17.46.040(F)(1)(b), Guidelines § I(B)(2).

At 15 feet less than the Proposed Facility height, a 34-foot tower or rooftop facility would provide much less coverage and could not serve the gap. A 50-foot facility on private property would require a special exception for additional height.

Furthermore, a proposed wireless facility on an R-1 parcel could not satisfy the Code’s setback requirements. The Guidelines require a setback of at least 110% of the height of the tower from habitable structures approved for residential occupancy. Guidelines § I(A)(2). Additionally, the R-1 zone front/rear setbacks range between 10 to 15 feet and the side yard setbacks between 3 to 9 feet, depending on lot characteristics such as interior site, corner site, or street side. Code § 17.10.030(A), Guidelines § I(A)(3). A tower setback less than 110% would require a special exception.

Alone or in combination, these restrictive setbacks would not accommodate a tower and its surrounding equipment area on the residential properties in or around the search area.

For example, a wireless facility would need to be at least 15 feet from a parcel line, with the tower 55 feet from a home, requiring at least 70 feet of available space.

ATTACHMENT 8

11 The properties in the vicinity around the
search area include residences that are
generally significantly less than 55 feet
from property lines, as shown on the map
to the right. These parcels are plainly not
large enough to accommodate both the R-1
zone setback and the 110% tower setback.

Finally, fiber and power would need to be
supplied to a facility on private property by
trenching underground to the nearest points
of connection in the public right-of-way.

Guidelines § 1(A)(5).

These same factors would apply to a
proposed small cell facility on private
property.

In contrast, wireless facilities are permitted
on utility poles in the public right-of-way
by both the Code and State Law. Existing
utility poles in the right-of-way are
generally taller than residential homes.

The Proposed Facility complies with the
City’s height limit for right-of-way
facilities, because it does not exceed the
height of the replaced pole by more than 10
feet, and does not require a special
exception. Code § 17.46.040(F)(1)(b).

The Code does not require any setbacks for
wireless facilities in the right-of-way. The
Proposed Facility does not require any
underground trenching because the subject
utility pole will support electric and communications lines.

If located in the Carmel right-of-way, wireless facilities can serve a larger area due to greater allowed height, and fewer facilities would be required.

Vicinity around Search Area
ATTACHMENT 8

12 X. Evaluation of Utility Poles in the Right-of-Way
A. Preferred Option – Small Cell on an Existing Utility Pole Verizon Wireless radio frequency design engineers determined that a small cell wireless facility is the best facility design due to the location, size, and nature of the significant gap area as well as the community characteristics. “Small wireless facility” is defined with certain height and dimension thresholds, according to the FCC rules described in Section VI.

Verizon Wireless analyzed solutions that utilize existing infrastructure locations, minimizing any impacts associated with the wireless facility. The gap area includes numerous existing utility poles in the public right-of-way that support PG&E electric equipment and communications lines, where small cell wireless facilities can be installed.

State law grants telephone corporations, including wireless carriers, the right to place their equipment along any public right-of-way. Verizon Wireless accesses utility poles as a member of the JPA, which is composed of various electric and communication utilities that share utility poles. In addition to using infrastructure already present in the public right-of-way, the utility poles support PG&E lines, which already provide electricity, minimizing trenching associated with a wireless project (none is required for the Proposed Facility).

As discussed above, the Proposed Facility is a small piece of a larger network in the area.

The network includes existing small cell wireless facilities as well as small cells that have been approved but not yet constructed. The Proposed Facility must be strategically located to compliment and not interfere with the service provided by existing and approved wireless facilities.

B. Least Compatible Option – New Stand-Alone Pole
Given the presence of existing utility poles throughout the search area and the City’s preference for collocation, a new stand-alone pole in the public right-of-way would be more intrusive than adding wireless equipment to an existing utility pole. Code §

17.46.040(D)(2) (“New (nonreplacement) structures of any type (pole or nonpole) are the least compatible structures to use on public rights-of-way. Existing (or replacement) utility poles are the most compatible structures.”).

C. Summary of Site-Specific Evaluation
Verizon Wireless evaluated 28 utility poles within the search area defined by PierCon.

Verizon Wireless determined that the Proposed Facility pole on Carmelo Street between 10th Avenue and 11th Avenue is the least intrusive, feasible alternative to improve service and fill the significant gap (Alternative 1). 15 poles were determined to be infeasible, primarily due to PG&E rules (Alternatives 2-16). 12 poles were determined to be more intrusive because they would require more exceptions or special considerations under the Code, or they exhibit other disfavored site characteristics, as established by the Code, such as excessive height, removal of existing landscape, and elimination of street parking (Alternatives 17-28).

ATTACHMENT 8

13 D. Proposed Facility (Alternative 1)

1. Carmelo Street North of 11th Avenue

36.549322°, -121.926925° (R-1 zone)
Verizon Wireless can replace this 38-foot 11-inch
utility pole with a taller pole supporting a 2.5-foot-tall cylindrical pole-top antenna, for a total height of 49
feet 10 inches. Associated network equipment would
be placed on the side of the pole between 7 and 17
feet, including radios and power supply units
concealed within a narrow shroud as well as an electric meter/disconnect switch. A photosimulation appears
to the right.

The Proposed Facility requires the two exceptions
listed below, fewer than any other alternative. This is the least intrusive, feasible alternative to improve
Verizon Wireless service in western Carmel.
• Right-of-way in single-family residential zone, Code
§ 17.46.040(E)(1)
• In front of area five feet in either direction from
centerline of residential door or window, Code §

17.46.040(E)(2)(a)

ATTACHMENT 8

14 E. Poles Discounted Due to Infeasibility (Alternatives 2-16)

2. Carmelo Street at 9th Avenue

36.5513758012°, -121.92692698° (R-1 zone)

This utility pole supports a transformer and line cutouts.

PG&E prohibits wireless equipment on a utility pole with such distribution equipment. PG&E Standard 027911, §5.

This pole is technically infeasible.

3. 9th Avenue East of Carmelo Street

36.5513672161, -121.926579151° (R-1 zone)

This utility pole supports a transformer. PG&E prohibits wireless equipment on utility poles with transformers.

PG&E Standard 027911, §5. This pole is technically
infeasible.

ATTACHMENT 8

15 4. Carmelo Street South of 9th Avenue

36.5511228965°, -121.926927495° (R-1 zone)

This utility pole supports three transformers. PG&E
prohibits wireless equipment on utility poles with
transformers. PG&E Standard 027911, §5. This pole is
technically infeasible.

5. Carmelo Street South of 9th Avenue

36.5509104235°, -121.926923861° (R-1 zone)

This utility pole supports a transformer. PG&E prohibits wireless equipment on utility poles with transformers.

PG&E Standard 027911, §5. This pole is technically
infeasible.

ATTACHMENT 8

16 6. Carmelo Street at 10th Avenue

36.5501477909°, -121.926921786° (R-1 zone)

This utility pole supports a transformer and line cutouts, along with numerous conduits and risers. An antenna
cannot be placed on a utility pole with such distribution equipment per PG&E rules. PG&E Standard 027911, §5.

This pole is technically infeasible.

7. Carmelo Street South of 10th Avenue

36.5497875003°, -121.92692919° (R-1 zone)

This utility pole supports a transformer and line cutouts.

An antenna cannot be placed on a utility pole with such distribution equipment per PG&E rules. PG&E Standard
027911, §5. This pole is technically infeasible.

ATTACHMENT 8

17 8. Camino Real South of 10th Avenue

36.5497910094°, -121.926070174° (R-1 zone)
This utility pole supports a transformer. PG&E prohibits wireless equipment on utility poles with transformers.

PG&E Standard 027911, §5. This pole is technically
infeasible.

9. Camino Real South of 10th Avenue

36.5493466957°, -121.92607197° (R-1 zone)
This utility pole supports a transformer. PG&E prohibits wireless equipment on utility poles with transformers.

PG&E Standard 027911, §5. This pole is technically
infeasible.

ATTACHMENT 8

18 10. Carmelo Street at 11th Avenue

36.5488957352°, -121.926925005° (R-1 zone)

This utility pole supports primary line cutouts. An
antenna cannot be placed on a utility pole with such
distribution equipment per PG&E rules. PG&E Standard
027911, §5. There are also several communication boxes, which already occupy space on the side of the pole,
limiting climbing space and occupying the space
available for equipment on the pole. PG&E Standard
027911, §§16A-B, 25. This pole is technically infeasible.

11. 11th Avenue East of Carmelo Street

36.5488966718°, -121.926555923° (R-1 zone)

This utility pole supports a transformer. PG&E prohibits wireless equipment on utility poles with transformers.

PG&E Standard 027911, §5. This pole is technically
infeasible.

ATTACHMENT 8

19 12. Camino Real at 11th Avenue

36.5489094311°, -121.926063821° (R-1 zone)

This utility pole supports a transformer. PG&E prohibits wireless equipment on utility poles with transformers.

PG&E Standard 027911, §5. This pole is technically
infeasible.

13. Carmelo Street South of 11th Avenue

36.5484285316°, -121.926924351° (R-1 zone)

This utility pole supports a transformer and line cutouts.

An antenna cannot be placed on a utility pole with such distribution equipment per PG&E rules. PG&E Standard
027911, §5. This pole is technically infeasible.

ATTACHMENT 8

20 14. Camino Real South of 11th Avenue

36.5484408592°, -121.926069457° (R-1 zone)

There are numerous conduit stub-ups at the base of this utility pole as well as cable risers on the rear and side of the pole.

The stub-ups contain cables that run up the pole and occupy the space where the equipment would be located, rendering that space unavailable. The wireless equipment would have to be installed streetside and not block climbing space, which would violate PG&E’s rules. GO 95, Rule 93; PG&E
Standard 027911, §16A, C. The power riser also occupies the 9-12 quadrant, which makes it unavailable. Id. This is not a feasible alternative.

15. Carmelo Street North of 12th Avenue

36.5481124343°, -121.926921994° (R-1 zone)

This utility pole supports a transformer and line cutouts. An antenna cannot be placed on a utility pole with such
distribution equipment per PG&E rules. PG&E Standard
027911, §5. This pole is technically infeasible.

ATTACHMENT 8

21 16. Camino Real at 12th Avenue

36.5480078375, -121.926056812° (R-1 zone)

This utility pole supports a transformer. PG&E prohibits wireless equipment on utility poles with transformers. PG&E Standard 027911, §5. This pole is technically infeasible.

ATTACHMENT 8

22 F. Poles Discounted as More Intrusive (Alternatives 17-28)

17. Camino Real at 9th Avenue

36.5513838458°, -121.926071779° (R-1 zone)

This pole is on a roadway with no curb, making it difficult to comply with PG&E’s metering requirements related to
the safety of its employees. PG&E requires metering
equipment to be mounted on the same pole as the PG&E
service. PG&E Standard 027911, §10. Clear and level
working space is required in front of the meter. PG&E
Standard 027911, §§20, 21. If a carrier cannot place a
meter on the pole because it would not meet PG&E
requirements, the carrier must install a pad−mounted
pedestal meter. PG&E Standard 027911, §11 and §B-B on
p. 10. PG&E would require the carrier to install bollards to protect someone reading the meters from traffic. PG&E
Clearances and Location Requirements For Enclosures,
Pads, and Underground Equipment, Document 051122
Rev #22, March 25, 2022 (“General Greenbook 051122”),
§12; PG&E Greenbook §§5.4.4-5.4.5. In addition to being more intrusive, the space required for the bollards would likely result in the removal of at least one street parking space. Id. Consequently, a wireless facility on this utility pole would require that accessory equipment (an electric meter) be placed in a surface-mounted meter pedestal. The addition of the bollards and pedestal meter could be considered to obstruct views and add unnecessary visual clutter to the right-of-way.

In contrast, the Proposed Facility would include all required equipment on the pole and no bollards. This location would also require the eight exceptions or special considerations listed below, six more than the Proposed Facility. This is alternative is more intrusive than the Proposed Facility.
• Right-of-way in single-family residential zone, Code § 17.46.040(E)(1) • In front of area five feet in either direction from centerline of residential door or window, Code § 17.46.040(E)(2)(a)
• Adversely affects normal drainage of surface water, Code § 17.46.040(E)(3)(b) • Adversely affects tree roots or reduce greenbelt area, Code § 17.46.040(E)(3)(d) • Displaces any existing tree or landscape and/or hardscape features, Code §

17.46.040(F)(1)(f)
• Obstructs views enjoyed by neighboring parcels and/or presents excess visual mass or bulk to public view or to adjoining properties, Code § 17.46.040(F)(1)(k) • Creates visual clutter or negatively affects important public or private views, Code §

17.46.040(F)(1)(k)
• Not designed to resemble existing poles, including an overall height that is greater than 10 feet taller than the replaced pole, or the additional height necessary to comply with CPUC safety standards such as General Order 95, Guidelines § II(A)(1)(3) ATTACHMENT 8

23 18. Camino Real South of 9th Avenue

36.5509102607°, -121.926082459° (R-1 zone)

This location would require the 15 exceptions or special considerations listed below, 13 more than the Proposed
Facility. There are no adjacent trees to screen a wireless facility so views could potentially be obstructed. This is a more intrusive alternative than the Proposed Facility.
• Right-of-way in single-family residential zone, Code §

17.46.040(E)(1)
• In front of area five feet in either direction from centerline of residential door or window, Code § 17.46.040(E)(2)(a) • Adversely affects tree roots or reduce greenbelt area, Code § 17.46.040(E)(3)(d)
• Displaces any existing tree or landscape and/or hardscape features, Code § 17.46.040(F)(1)(f)
• Fails to maintain existing native vegetation to the
maximum extent feasible, Code § 17.46.040(F)(1)(f)
• Location or design obstructs significant coastal views from public right-of-way, Code § 17.46.040(F)(1)(k)
• Obstructs views enjoyed by neighboring parcels and/or presents excess visual mass or bulk to public view or to adjoining properties, Code § 17.46.040(F)(1)(k)
• Creates visual clutter or negatively affects important public or private views, Code §

17.46.040(F)(1)(k)
• Substantially eliminates an existing significant view enjoyed on another parcel, Code §

17.46.040(F)(1)(k)
• Replacement pole not as close to the removed pole’s location as possible, Guidelines § II(A)(1)(1)
• Not aligned with other existing poles along public right-of-way, Guidelines § II(A)(1)(2)
• Antennas placed on the pole in a way that significantly impairs public or private views, Guidelines § II(B)(1)
• More intrusive and incompatible aesthetic design, Guidelines § II(B)(1) • Pole-mounted accessory equipment oriented toward prominent views, Guidelines § II(C)(3)(a)
• Extends over any roadway for vehicular travel, any pedestrian path of travel, or any abutting private property, Guidelines § II(C)(3)(c)
ATTACHMENT 8

24 19. Carmelo Street North of 10th Avenue

36.5505702698°, -121.926928081° (R-1 zone)

This pole is on a roadway with no curb, making it difficult to comply with PG&E’s metering requirements related to
the safety of its employees. PG&E requires metering
equipment to be mounted on the same pole as the PG&E
service. PG&E Standard 027911, §10. Clear and level
working space is required in front of the meter. PG&E
Standard 027911, §§20, 21. If a carrier cannot place a
meter on the pole because it would not meet PG&E
requirements, the carrier must install a pad−mounted
pedestal meter. PG&E Standard 027911, §11 and §B-B on
p. 10. PG&E would require the carrier to install bollards to protect someone reading the meters from traffic. General Greenbook 051122, §12; PG&E Greenbook §§5.4.4-5.4.5.

In addition to being more intrusive, the space required for the bollards would likely result in the removal of at least one street parking space. Id. Consequently, a wireless
facility on this utility pole would require that accessory equipment (an electric meter) be placed in a surface-mounted meter pedestal. The addition of the bollards and pedestal meter could be considered to obstruct views and add unnecessary visual clutter to the right-of-way.

In contrast, the Proposed Facility would include all required equipment on the pole and no bollards. This location would require the seven exceptions or special considerations listed below, five more than the Proposed Facility. This alternative is more intrusive than the Proposed Facility.
• Right-of-way in single-family residential zone, Code § 17.46.040(E)(1) • Adversely affects vehicular/pedestrian traffic or parking, Code § 17.46.040(E)(3)(c) • Location or design obstructs significant coastal views from public right-of-way, Code §

17.46.040(F)(1)(k)
• Obstructs views enjoyed by neighboring parcels and/or presents excess visual mass or bulk to public view or to adjoining properties, Code § 17.46.040(F)(1)(k) • Creates visual clutter or negatively affects important public or private views, Code §

17.46.040(F)(1)(k)
• Not designed to resemble existing poles, including an overall height that is greater than 10 feet taller than the replaced pole, or the additional height necessary to comply with CPUC safety standards such as General Order 95, Guidelines § II(A)(1)(3) • More intrusive and incompatible aesthetic design, Guidelines § II(B)(1) ATTACHMENT 8

25 20. Camino Real North of 10th Avenue

36.5505221883°, -121.926073091° (R-1 zone)

This location would require the nine exceptions or special considerations listed below, seven more than the Proposed Facility. There are no adjacent trees to screen a wireless facility so views could potentially be obstructed. This is a more intrusive alternative than the Proposed Facility.
• Right-of-way in single-family residential zone, Code §

17.46.040(E)(1)
• In front of area five feet in either direction from
centerline of residential door or window, Code §

17.46.040(E)(2)(a)
• Adversely affects vehicular/pedestrian traffic or parking, Code § 17.46.040(E)(3)(c)
• Obstructs views enjoyed by neighboring parcels and/or presents excess visual mass or bulk to public view or to adjoining properties, Code § 17.46.040(F)(1)(k)
• Creates visual clutter or negatively affects important public or private views, Code § 17.46.040(F)(1)(k)
• Substantially eliminates an existing significant view enjoyed on another parcel, Code §

17.46.040(F)(1)(k)
• Antennas placed on the pole in a way that significantly impairs public or private views, Guidelines § II(B)(1)
• More intrusive and incompatible aesthetic design, Guidelines § II(B)(1) • Extends over any roadway for vehicular travel, any pedestrian path of travel, or any abutting private property, Guidelines § II(C)(3)(c)
ATTACHMENT 8

26 21. 10th Avenue West of Carmelo Street

36.5501076964°, -121.927209896° (R-1 zone)

The PG&E replacement pole required to place a
wireless facility at this location would result in an
overall ten-foot height increase compared to the
existing pole. This height increase could be considered an obstruction or clutter depending on the vantage
point. Additionally, this location would require the 12 exceptions or special considerations listed below, ten
more than the Proposed Facility. This is a more
intrusive alternative than the Proposed Facility.
• Right-of-way in single-family residential zone, Code §

17.46.040(E)(1)
• Adversely affects tree roots or reduce greenbelt area, Code § 17.46.040(E)(3)(d)
• Overall height exceeds height of the existing pole by more than 10 feet, Code § 17.46.040(F)(1)(b)
• Displaces any existing tree or landscape and/or
hardscape features, Code § 17.46.040(F)(1)(f)
• Fails to maintain existing native vegetation to the
maximum extent feasible, Code § 17.46.040(F)(1)(f)
• Location or design obstructs significant coastal views from public right-of-way, Code §

17.46.040(F)(1)(k)
• Obstructs views enjoyed by neighboring parcels and/or presents excess visual mass or bulk to public view or to adjoining properties, Code § 17.46.040(F)(1)(k) • Creates visual clutter or negatively affects important public or private views, Code §

17.46.040(F)(1)(k)
• Substantially eliminates an existing significant view enjoyed on another parcel, Code §

17.46.040(F)(1)(k)
• Not designed to resemble existing poles, including an overall height that is greater than 10 feet taller than the replaced pole, or the additional height necessary to comply with CPUC safety standards such as General Order 95, Guidelines § II(A)(1)(3) • Antennas placed on the pole in a way that significantly impairs public or private views, Guidelines § II(B)(1)
• More intrusive and incompatible aesthetic design, Guidelines § II(B)(1) ATTACHMENT 8

27 22. 10th Avenue West of Carmelo Street

36.5501093609°, -121.927167035° (R-1 zone)

The PG&E replacement pole required to place a wireless
facility at this location would result in an overall ten-foot height increase compared to the existing pole. This height increase could be considered an obstruction or clutter
depending on the vantage point. Additionally, this
location would require the 12 exceptions or special
considerations listed below, ten more than the Proposed Facility. This is a more intrusive alternative than the Proposed Facility.
• Right-of-way in single-family residential zone, Code §

17.46.040(E)(1)
• Adversely affects tree roots or reduce greenbelt area, Code § 17.46.040(E)(3)(d)
• Overall height exceeds height of the existing pole by more than 10 feet, Code § 17.46.040(F)(1)(b)
• Displaces any existing tree or landscape and/or hardscape features, Code §

17.46.040(F)(1)(f)
• Fails to maintain existing native vegetation to the maximum extent feasible, Code §

17.46.040(F)(1)(f)
• Location or design obstructs significant coastal views from public right-of-way, Code §

17.46.040(F)(1)(k)
• Obstructs views enjoyed by neighboring parcels and/or presents excess visual mass or bulk to public view or to adjoining properties, Code § 17.46.040(F)(1)(k) • Creates visual clutter or negatively affects important public or private views, Code §

17.46.040(F)(1)(k)
• Substantially eliminates an existing significant view enjoyed on another parcel, Code §

17.46.040(F)(1)(k)
• Not designed to resemble existing poles, including an overall height that is greater than 10 feet taller than the replaced pole, or the additional height necessary to comply with CPUC safety standards such as General Order 95, Guidelines § II(A)(1)(3) • Antennas placed on the pole in a way that significantly impairs public or private views, Guidelines § II(B)(1)
• More intrusive and incompatible aesthetic design, Guidelines § II(B)(1) ATTACHMENT 8

28 23. 10th Avenue East of Carmelo Street

36.5501351381°, -121.926555448° (R-1 zone)

This location would require the 12 exceptions or special considerations listed below, ten more than the Proposed Facility. There are no adjacent trees to screen a wireless facility so views could potentially be obstructed. This is a more intrusive alternative than the Proposed Facility.
• Right-of-way in single-family residential zone, Code §

17.46.040(E)(1)
• In front of area five feet in either direction from
centerline of door or window of residence, Code §

17.46.040(E)(2)(a)
• Displaces any existing tree or landscape and/or
hardscape features, Code § 17.46.040(F)(1)(f)
• Fails to maintain existing native vegetation to the
maximum extent feasible, Code § 17.46.040(F)(1)(f)
• Location or design obstructs significant coastal views from public right-of-way, Code § 17.46.040(F)(1)(k)
• Obstructs views enjoyed by neighboring parcels and/or presents excess visual mass or bulk to public view or to adjoining properties, Code § 17.46.040(F)(1)(k) • Creates visual clutter or negatively affects important public or private views, Code §

17.46.040(F)(1)(k)
• Substantially eliminates an existing significant view enjoyed on another parcel, Code §

17.46.040(F)(1)(k)
• Antennas placed on the pole in a way that significantly impairs public or private views, Guidelines § II(B)(1)
• More intrusive and incompatible aesthetic design, Guidelines § II(B)(1) • Pole-mounted accessory equipment oriented toward prominent views, Guidelines § II(C)(3)(a)
• Extends over any roadway for vehicular travel, any pedestrian path of travel, or any abutting private property, Guidelines § II(C)(3)(c)
ATTACHMENT 8

29 24. Camino Real and 10th Avenue

36.5501316789°, -121.926070976° (R-1 zone)

This pole is on a roadway with no curb, making it difficult to comply with PG&E’s metering requirements related to the safety of its employees. PG&E requires metering equipment to be mounted on the same pole as the PG&E service. PG&E Standard 027911, §10. Clear and level working space is
required in front of the meter. PG&E Standard 027911,
§§20, 21. If a carrier cannot place a meter on the pole because it would not meet PG&E requirements, the carrier must install a pad−mounted pedestal meter. PG&E Standard 027911, §11 and §B-B on p. 10. PG&E would require the
carrier to install bollards to protect someone reading the meters from traffic. General Greenbook 051122, §12; PG&E Greenbook §§5.4.4-5.4.5. In addition to being more
intrusive, the space required for the bollards would likely result in the removal of at least one street parking space. Id.

Consequently, a wireless facility on this utility pole would require that accessory equipment (an electric meter) be placed in a surface-mounted meter pedestal. The addition of the bollards and pedestal meter could be considered to obstruct views and add unnecessary visual clutter to the right-of-way.

In contrast, the Proposed Facility would include all required equipment on the pole and no bollards. This location would require the 13 exceptions or special considerations listed below, eleven more than the Proposed Facility. This alternative is more intrusive than the Proposed Facility.
• Right-of-way in single-family residential zone, Code § 17.46.040(E)(1) • Adversely affects normal drainage of surface water, Code § 17.46.040(E)(3)(b) • Adversely affects tree roots or reduce greenbelt area, Code § 17.46.040(E)(3)(d) • Displaces any existing tree or landscape and/or hardscape features, Code §

17.46.040(F)(1)(f)
• Fails to maintain existing native vegetation to the maximum extent feasible, Code §

17.46.040(F)(1)(f)
• Obstructs views enjoyed by neighboring parcels and/or presents excess visual mass or bulk to public view or to adjoining properties, Code § 17.46.040(F)(1)(k) • Creates visual clutter or negatively affects important public or private views, Code §

17.46.040(F)(1)(k)
• Substantially eliminates an existing significant view enjoyed on another parcel, Code §

17.46.040(F)(1)(k)
• Antennas placed on the pole in a way that significantly impairs public or private views, Guidelines § II(B)(1)
• More intrusive and incompatible aesthetic design, Guidelines § II(B)(1) • Pole-mounted accessory equipment oriented toward prominent views, Guidelines § II(C)(3)(a)
• Antennas placed on the pole in a way that significantly impairs public or private views, ATTACHMENT 8

30 Guidelines § II(B)(1)
• More intrusive and incompatible aesthetic design, Guidelines § II(B)(1) ATTACHMENT 8

31 25. Camino Real North of 12th Avenue

36.5480085503°, -121.926180926° (R-1 zone)

This location would require the ten exceptions or special considerations listed below, eight more than the Proposed Facility. There are no adjacent trees to screen a wireless facility so views could potentially be obstructed. This is a more intrusive alternative than the Proposed Facility.
• Right-of-way in single-family residential zone, Code §

17.46.040(E)(1)
• In front of area five feet in either direction from centerline of residential door or window, Code § 17.46.040(E)(2)(a) • Displaces any existing tree or landscape and/or hardscape features, Code § 17.46.040(F)(1)(f)
• Fails to maintain existing native vegetation to the
maximum extent feasible, Code § 17.46.040(F)(1)(f)
• Location or design obstructs significant coastal views from public right-of-way, Code § 17.46.040(F)(1)(k)
• Obstructs views enjoyed by neighboring parcels and/or presents excess visual mass or bulk to public view or to adjoining properties, Code § 17.46.040(F)(1)(k) • Creates visual clutter or negatively affects important public or private views, Code §

17.46.040(F)(1)(k)
• Substantially eliminates an existing significant view enjoyed on another parcel, Code §

17.46.040(F)(1)(k)
• Not aligned with other existing poles along public right-of-way, Guidelines § II(A)(1)(2)
• Not designed to resemble existing poles, including an overall height that is greater than 10 feet taller than the replaced pole, or the additional height necessary to comply with CPUC safety standards such as General Order 95, Guidelines § II(A)(1)(3) ATTACHMENT 8

32 26. 12th Avenue West of Carmelo Street

36.547552135°, -121.927233821° (R-1 zone)

This location would require the 14 exceptions or special considerations listed below, 12 more than the Proposed
Facility. There are no adjacent trees to screen a wireless facility so views could potentially be obstructed. This is a more intrusive alternative than the Proposed Facility.
• Right-of-way in single-family residential zone, Code §

17.46.040(E)(1)
• In front of area five feet in either direction from centerline of residential door or window, Code § 17.46.040(E)(2)(a)
• Adversely affects vehicular/pedestrian traffic or parking, Code § 17.46.040(E)(3)(c)
• Displaces any existing tree or landscape and/or hardscape features, Code § 17.46.040(F)(1)(f)
• Location or design obstructs significant coastal views from public right-of-way, Code § 17.46.040(F)(1)(k)
• Obstructs views enjoyed by neighboring parcels and/or presents excess visual mass or bulk to public view or to adjoining properties, Code § 17.46.040(F)(1)(k) • Creates visual clutter or negatively affects important public or private views, Code §

17.46.040(F)(1)(k)
• Substantially eliminates an existing significant view enjoyed on another parcel, Code §

17.46.040(F)(1)(k)
• Not aligned with other existing poles along public right-of-way, Guidelines § II(A)(1)(2)
• Not designed to resemble existing poles, including an overall height that is greater than 10 feet taller than the replaced pole, or the additional height necessary to comply with CPUC safety standards such as General Order 95, Guidelines § II(A)(1)(3) • Antennas placed on the pole in a way that significantly impairs public or private views, Guidelines § II(B)(1)
• More intrusive and incompatible aesthetic design, Guidelines § II(B)(1) • Pole-mounted accessory equipment oriented toward prominent views, Guidelines § II(C)(3)(a)
• Extends over any roadway for vehicular travel, any pedestrian path of travel, or any abutting private property, Guidelines § II(C)(3)(c)
ATTACHMENT 8

33 27. Carmelo Street at 12th Avenue

36.5476580885°, -121.926920897° (R-1 zone)

This pole is on a roadway with no curb, making it difficult to comply with PG&E’s metering requirements related to the safety of its employees. PG&E requires metering equipment to be mounted on the same pole as the PG&E service. PG&E Standard 027911, §10. Clear and level working space is
required in front of the meter. PG&E Standard 027911,
§§20, 21. If a carrier cannot place a meter on the pole because it would not meet PG&E requirements, the carrier must install a pad−mounted pedestal meter. PG&E Standard 027911, §11 and §B-B on p. 10. PG&E would require the
carrier to install bollards to protect someone reading the meters from traffic. General Greenbook 051122, §12; PG&E Greenbook §§5.4.4-5.4.5. In addition to being more
intrusive, the space required for the bollards would likely result in the removal of at least one street parking space. Id.

Consequently, a wireless facility on this utility pole would require that accessory equipment (an electric meter) be placed in a surface-mounted meter pedestal. The addition of the bollards and pedestal meter could be considered to obstruct views and add unnecessary visual clutter to the right-of-way.

In contrast, the Proposed Facility would include all required equipment on the pole and no bollards. This location would require the 10 exceptions or special considerations listed below, eight more than the Proposed Facility. This alternative is more intrusive than the Proposed Facility.
• Right-of-way in single-family residential zone, Code § 17.46.040(E)(1) • Adversely affects normal drainage of surface water, Code § 17.46.040(E)(3)(b) • Adversely affects tree roots or reduce greenbelt area, Code § 17.46.040(E)(3)(d) • Displaces any existing tree or landscape and/or hardscape features, Code §

17.46.040(F)(1)(f)
• Fails to maintain existing native vegetation to the maximum extent feasible, Code §

17.46.040(F)(1)(f)
• Obstructs views enjoyed by neighboring parcels and/or presents excess visual mass or bulk to public view or to adjoining properties, Code § 17.46.040(F)(1)(k) • Creates visual clutter or negatively affects important public or private views, Code §

17.46.040(F)(1)(k)
• Antennas placed on the pole in a way that significantly impairs public or private views, Guidelines § II(B)(1)
• More intrusive and incompatible aesthetic design, Guidelines § II(B)(1) • Pole-mounted accessory equipment oriented toward prominent views, Guidelines § II(C)(3)(a)
ATTACHMENT 8