Carmel-by-the-Sea City Council
March 2, 2026

34 28. Camino Real at 12th Avenue

36.5475834924°, -121.926059818° (R-1 zone)

This location would require the nine exceptions or special considerations listed below, seven more than the Proposed Facility. The adjacent mature tree would have to be
significantly trimmed, which would affect the view. 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)
• 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)
• Replacement pole not as close to the removed pole’s location as possible, Guidelines § II(A)(1)(1)
• More intrusive and incompatible aesthetic design, Guidelines § II(B)(1) ATTACHMENT 8

35 XI. Conclusion
Verizon Wireless has considered preferred zones, collocations, private property, and 28 specific alternatives in the right-of-way to improve its service and fill the significant gap in western Carmel. Based upon the values expressed in the Carmel-by-the-Sea Municipal Code, the Proposed Facility clearly constitutes the least intrusive feasible location for Verizon Wireless’s new facility.

ATTACHMENT 8

YOUR RF SAFETY PARTNER

RADIO FREQUENCY ELECTROMAGNETIC ENERGY EXPOSURE REPORT
PRE-Activation
Prepared for Verizon
Site Name: SF SOUTH CARMEL 001
Site Num: 428216_5000081318
Site Type: Utility Pole
Located at:

IFO Carmelo St, 4 South East of 10th Ave
Carmel by the Sea, CA 93921
Latitude: 36.549322 / Longitude: -121.926922
Report Date: 11/13/2024
Report By: Jamie Santos, RF Engineer
Based on FCC Rules and Regulations, Verizon will be compliant provided recommendation(s) are implemented.

Exhibit H
ATTACHMENT 8

5850 Oberlin Drive, Ste. 300 ▲ San Diego, CA 92121 ▲ 858.792.0066 ▲ www.dtechcom.com Page 2/15

TABLE OF CONTENTS

1.0 EXECUTIVE SUMMARY 3

2.0 SITE DESCRIPTION 3

2.1 Site Map 4

2.2 Antenna Inventory 5

3.0 ANALYSIS 6

3.1 Emission Predictions 6

4.0 CONCLUSION 10

4.1 Results 10

4.2 Recommendation(s) 10

4.3 Statement of Compliance 12

4.4 Engineer Certification 12
Appendix A: Background 13
Appendix B: Measurement and/or Computer Simulation Methods 14 Appendix C: Limitations 14
Appendix D: Sample RF Advisory Signs 15
ATTACHMENT 8

5850 Oberlin Drive, Ste. 300 ▲ San Diego, CA 92121 ▲ 858.792.0066 ▲ www.dtechcom.com Page 3/15

1.0 EXECUTIVE SUMMARY
Dtech Communications, LLC (“Dtech”) has been retained by Verizon, care of Sequoia, to determine whether its wireless communications facility complies with the Federal Communications Commission (FCC) Radio Frequency (RF) Safety Guidelines. This report contains a PRE-activation, computer-simulated analysis of the Electromagnetic Energy (EME) exposure resulting from the facility. The cumulative analysis includes contributions from existing wireless carriers on site, where applicable and information is provided. Results are compared to FCC’s General Population (GP) Maximum Permissible Exposure (MPE) Limits. The tables below summarizes the results of our EME assessment at a glance:

EME Summary
Analyzed
Elevation(s)
Height Above
Ground Level
(ft AGL)
Results
(% GP) Status
Ground 0 0.4 Pass
Adjacent Bldg Roof 20 13 Pass
Antenna Level 47.4 3083 see Page 8

2.0 SITE DESCRIPTION
The wireless telecommunication facility is located on the ground. The facility consists of 1 wireless carrier(s) or operator(s): Verizon. The antennas are typically grouped into sectors pointing in different directions to achieve the desired areas of coverage. Verizon’s antennas are mounted on a wooden utility pole.

ATTACHMENT 8

5850 Oberlin Drive, Ste. 300 ▲ San Diego, CA 92121 ▲ 858.792.0066 ▲ www.dtechcom.com Page 4/15

2.1 Site Map
ATTACHMENT 8

5850 Oberlin Drive, Ste. 300 ▲ San Diego, CA 92121 ▲ 858.792.0066 ▲ www.dtechcom.com Page 5/15

2.2 Antenna Inventory
The table below reflects the technical specifications provided by our clients and/or gathered from physical field surveys where applicable. This final configuration, including power settings and antenna orientations must be maintained to remain in compliance with FCC guidelines. For co-locators or nearby transmitters, conservative estimates are used for purposes of a cumulative study where information is not provided or available.

Site Technical Specifications
ATTACHMENT 8

5850 Oberlin Drive, Ste. 300 ▲ San Diego, CA 92121 ▲ 858.792.0066 ▲ www.dtechcom.com Page 6/15

3.0 ANALYSIS

3.1 Emission Predictions
Plan (bird’s eye) view map of results compared to FCC’s General Population MPE (Maximum Permissible Exposure) Limits for a typical 6-foot person. White represents areas where exposure levels are calculated to be at or below 5%; Green- between 5% & 100% (below MPE limits); blue, yellow & red – greater than 100% (exceeds MPE limits). Individuals can safely occupy areas in white and green for indefinite amount of time; whereas areas in blue, yellow & red must be restricted to RF trained personnel who has been made fully aware of potential for exposure, has control and knows how to reduce their exposure with the use of personal protection equipment or has the ability to power down the transmitters.

ATTACHMENT 8

5850 Oberlin Drive, Ste. 300 ▲ San Diego, CA 92121 ▲ 858.792.0066 ▲ www.dtechcom.com Page 7/15 Plan (bird’s eye) view map of results compared to FCC’s General Population MPE (Maximum Permissible Exposure) Limits for a typical 6-foot person. White represents areas where exposure levels are calculated to be at or below 5%; Green- between 5% & 100% (below MPE limits); blue, yellow & red – greater than 100% (exceeds MPE limits). Individuals can safely occupy areas in white and green for indefinite amount of time; whereas areas in blue, yellow & red must be restricted to RF trained personnel who has been made fully aware of potential for exposure, has control and knows how to reduce their exposure with the use of personal protection equipment or has the ability to power down the transmitters.

ATTACHMENT 8

5850 Oberlin Drive, Ste. 300 ▲ San Diego, CA 92121 ▲ 858.792.0066 ▲ www.dtechcom.com Page 8/15 Plan (bird’s eye) view map of results compared to FCC’s General Population MPE (Maximum Permissible Exposure) Limits for a typical 6-foot person. White represents areas where exposure levels are calculated to be at or below 5%; Green- between 5% & 100% (below MPE limits); blue, yellow & red – greater than 100% (exceeds MPE limits). Individuals can safely occupy areas in white and green for indefinite amount of time; whereas areas in blue, yellow & red must be restricted to RF trained personnel who has been made fully aware of potential for exposure, has control and knows how to reduce their exposure with the use of personal protection equipment or has the ability to power down the transmitters.

ATTACHMENT 8

5850 Oberlin Drive, Ste. 300 ▲ San Diego, CA 92121 ▲ 858.792.0066 ▲ www.dtechcom.com Page 9/15 Vertical view map of results compared to FCC’s General Population MPE (Maximum Permissible Exposure) Limits for a typical 6-foot person.

White represents areas where exposure levels are calculated to be at or below 100%; blue, yellow & red – greater than 100% (exceeds MPE limits).

Individuals can safely occupy areas in white for indefinite amount of time; whereas areas in blue, yellow & red must be restricted to RF trained personnel who has been made fully aware of potential for exposure, has control and knows how to reduce their exposure with the use of personal protection equipment or has the ability to power down the transmitters.

ATTACHMENT 8

5850 Oberlin Drive, Ste. 300 ▲ San Diego, CA 92121 ▲ 858.792.0066 ▲ www.dtechcom.com Page 10/15

4.0 CONCLUSION

4.1 Results
For a typical 6-foot person standing in accessible areas on the Ground and Adjacent Bldg Roof, exposure levels for Verizon's site are calculated to be BELOW the FCC's most stringent General Population MPE Limits.

At antenna elevation, the highest calculated exposure level is above the FCC’s General Population MPE Limits near the Verizon antenna(s). The maximum overexposed areas extend 22 feet from the front face of the Verizon antenna(s). There are no other buildings or surrounding structures at or higher than antenna height within the overexposed areas. Beyond this clearance distance, exposure levels are predicted to be below the FCC’s General Population MPE Limits.

There may be situations where workers may find themselves directly in front of the antennas or in areas where RF exposure levels may exceed the MPE Limits. Such individuals entering the facility or working near the antennas must be made fully aware of areas of potential concern. Implement an RF safety program/plan. Proper notification including identification of restricted areas or RF exposure maps, antenna shutdown procedures and contact information must be provided to the facility's landlord or property owner. This will help ensure that a regional point of contact or the Network Operation Center (NOC) will be contacted in the event maintenance activities are required inside the RF restricted areas.

4.2 Recommendation(s)
The following compliance action(s) would be sufficient to meet the FCC's and Verizon's RF Safety Guidelines:
1) Install RF advisory signs according to the Recommendation diagram.

ATTACHMENT 8

5850 Oberlin Drive, Ste. 300 ▲ San Diego, CA 92121 ▲ 858.792.0066 ▲ www.dtechcom.com Page 11/15 Recommendation(s)
ATTACHMENT 8

5850 Oberlin Drive, Ste. 300 ▲ San Diego, CA 92121 ▲ 858.792.0066 ▲ www.dtechcom.com Page 12/15

4.3 Statement of Compliance
Based on the results, analysis and recommendation(s), it is the undersigned’s professional opinion that Verizon's site will be compliant provided recommendation(s) are implemented.

4.4 Engineer Certification
This report has been prepared by or under the direction of the following Registered Professional Engineer: Darang Tech, holding California registration number 16000. I have reviewed this report and believe it to be both true and accurate to the best of my knowledge.

ATTACHMENT 8

5850 Oberlin Drive, Ste. 300 ▲ San Diego, CA 92121 ▲ 858.792.0066 ▲ www.dtechcom.com Page 13/15 Appendix A: Background
Dtech uses the FCC’s guidelines described in detail in Office of Engineering & Technology, Bulletin No. 65 (“OET-65”) “Evaluating Compliance with FCC Guidelines for Human Exposure to Radiofrequency Electromagnetic Fields”. The table below summarizes the current Maximum Permissible Exposure (“MPE”) safety limits classified into two groups: General population and Occupational.

FCC MPE Limits (from OET-65)
Frequency
(Mhz)
General Population/
Uncontrolled MPE
(mW/cm)
Averaging
Time
(minutes)
Occupational/
Controlled MPE
(mW/cm)

Averaging
Time
(minutes)
30 - 300 0.2 30 1.0 6
300 - 1500 Frequency (Mhz)/1500
(0.2 – 1.0) 30 Frequency (Mhz)/300 (1.0 – 5.0) 6
1500 -
100,000 1.0 30 5.0 6
General population/uncontrolled limits apply in situations in which the general public may be exposed or in which persons who are exposed as a consequence of their employment, and may not be fully aware of the potential for exposure or cannot exercise control over their exposure. Therefore, members of the general public always fall under this category when exposure is not employment-related.

Occupational/controlled limits apply in situations in which persons are exposed as a consequence of their employment, and those persons have been made fully aware of the potential for exposure and can exercise control over their exposure. Occupational/controlled limits also apply where exposure is of a transient nature as a result of incidental passage through a location where exposure levels may be above general population/uncontrolled limits, as long as the exposed person has been made fully aware of the potential for exposure and can exercise control over his or her exposure by leaving the area or by some other appropriate means.

It is important to understand that the FCC guidelines specify exposure limits not emission limits. For a transmitting facility to be out of compliance with the FCC's RF safety guidelines an area or areas where levels exceed the MPE limits must, first of all, be in some way accessible to the public or to workers. When accessibility to an area where excessive levels is appropriately restricted, the facility or operation can certify that it complies with the FCC requirements.

ATTACHMENT 8

5850 Oberlin Drive, Ste. 300 ▲ San Diego, CA 92121 ▲ 858.792.0066 ▲ www.dtechcom.com Page 14/15 Appendix B: Measurement and/or Computer Simulation Methods Spatial averaging measurement technique is used. An area between 2 and 6 feet, approximately the size of an average human, is scanned in single passes from top to bottom in multiple planes. When possible, measurements were made at very close proximity to the antennas and inside the main beam where most of the energy is emitted.

The spatial averaged values were recorded. A result higher than 100% exceeds the FCC’s General Population MPE Limits.

Dtech uses an industry standard power density prediction computer Model1 to assess the worse-case, cumulative
EMF impact of the surrounding areas of the subject site. In addition, the analysis is performed at 80% duty cycle for all (C-Band/CBRS/mmWave/AAH) TDD technologies. All other frequencies are operating at 100% duty cycle transmitting at maximum total power. Lower Interiors (if applicable), were analyzed 10-feet below roof level with a 10dB deck attenuation. For purposes of a cumulative study, nearby transmitters are included where possible. The result is a surrounding area map color-coded to percentages of the applicable FCC’s MPE Limits.

Appendix C: Limitations
The conclusions in this document rendered by Dtech are based solely upon the information collected during the site survey and/or furnished by our Client which Dtech believes is accurate and correct. Dtech, however, has no responsibility should such Client provided information prove to be inaccurate or incorrect. Third party specification estimates used for cumulative computer simulation purposes, where applicable, are based on common industry practices and our best interpretation of available information. Data, results and conclusions in this document are valid as of its date. However, as mobile technologies continuously change, these data, results and conclusions may also be at variance with such future changes. Dtech has no responsibility to update its survey or report to account for such future technology changes. This document was prepared for the use of our Client only and cannot be utilized by any third party for any purpose without Dtech’s written consent. Dtech shall have no liability for any unauthorized use of this document and any such unauthorized user shall defend, indemnify and hold Dtech and its owners, directors, officers and employees harmless from and against any liability, claim, demand, loss or expense (including reasonable attorney’s fees) arising from such unauthorized use. 1 Roofmaster(tm)
ATTACHMENT 8

5850 Oberlin Drive, Ste. 300 ▲ San Diego, CA 92121 ▲ 858.792.0066 ▲ www.dtechcom.com Page 15/15 Appendix D: Sample RF Advisory Signs2

GUIDELINES NOC INFORMATION

NOTICE CAUTION

WARNING
2 The above signage is for reference only. Actual signs may be updated in accordance to Verizon RF policy ATTACHMENT 8

Verizon Wireless • Proposed Base Station (Site No. 428216 “SC001 Carmelo Stonewall”) Carmelo Street South of 10th Avenue • Carmel-By-The-Sea, California B2PJ.1

Statement of Hammett & Edison, Inc., Consulting Engineers The firm of Hammett & Edison, Inc., Consulting Engineers, has been retained on behalf of Verizon Wireless, a wireless telecommunications carrier, to evaluate the small cell base station (Site No. 428216 “SC001 Carmelo Stonewall”) proposed to be located on Carmelo Street, in CarmelBy-The-Sea California, for compliance with municipal limits on sound levels from the installation.

Executive Summary
Verizon proposes to install one cylindrical antenna on the utility pole sited in the public rightof-way on the east side of Carmelo Street in Carmel-By-The-Sea, about 80 feet south of its intersection with 10th Avenue. Noise from the proposed operation will comply with the City’s pertinent noise limits.

Prevailing Standard
Carmel-by-the-Sea regulates noise in Chapter 8.56 “Noise Regulations” of its Municipal Code, which classifies noise from equipment operated in the public interest, including public utility equipment, as “Class A” noise. Section 8.56.030 specifically exempts the creation and emission of Class A noise from the provisions of the City’s noise regulations.

Figure 1 attached describes the calculation methodology used to determine applicable noise levels for evaluation against the prevailing standard.

General Facility Requirements
Wireless telecommunications facilities (“cell sites”) typically consist of two distinct parts: the electronic base transceivers (also called “radios”), that are connected to traditional wired telephone lines, and the antennas, that send wireless signals created by the radios out to be received by individual subscriber units. The radios are typically located on or at the base of the pole and are connected to the antennas by cables. Some radios require fans to cool the electronics inside. Some radios are integrated with the antennas as a single unit.

Site & Facility Description
According to information provided by Verizon, including drawings by All States Engineering and Surveying, dated November 12, 2024, that carrier proposes to install a cylindrical antenna on top of a new utility pole to replace the existing one sited in the public right-of-way on the east side of Carmelo Street in Carmel-By-The-Sea, about 80 feet south of its intersection with 10th Avenue.

Two Ericsson radios, one each Models 4890 and 8863 would be mounted lower on the pole, at least 11 feet above ground.

Exhibit I
ATTACHMENT 8

Verizon Wireless • Proposed Base Station (Site No. 428216 “SC001 Carmelo Stonewall”) Carmelo Street South of 10th Avenue • Carmel-By-The-Sea, California B2PJ.1

Study Results
The antenna is passive, generating no noise, and both Ericsson radios are convectively cooled, that is, configured without cooling fans. Since none of the proposed equipment makes noise, the proposed operation will comply with the City’s noise limits.

Conclusion
Based on the information and analysis above, it is the undersigned’s professional opinion that operation of the base station proposed by Verizon Wireless on Carmelo Street in Carmel-By-The-Sea will, under the conditions noted above, comply with the municipal standards limiting acoustic noise emission levels.

Authorship
The undersigned author of this statement is a qualified Professional Engineer, holding California Registration Nos. E-13026 and M-20676, which expire on June 30, 2025. This work has been carried out under his direction, and all statements are true and correct of his own knowledge except, where noted, when data has been supplied by others, which data he believes to be correct.

William F. Hammett, P.E.
707/996-5200
November 15, 2024
ATTACHMENT 8

!"#$%&'%(%)&*+),-)+.#"/&0%.1"2")"34&
"#$%&'&(&)*!
+,)-.#!/!
"&0$!1-2,3,45(,$,#0!52'!&$%#.!5)#23,#0!04#3,6*!2&,0#!(,1,$0!,2! -2,$0! &6! '789! :%,3%! ,0! ,2$#2'#'! $&! 1,1,3! $%#! .#'-3#'! .#3#4$,;,$*! &6! $%#! %-152! #5.! $&! <&-2'! =.#00-.#! >?@=AB! 5$!

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
:%#.#!@=!,0!$%#!0&-2'!4.#00-.#!(#;#(!5$!',0$523#!T4!52'!! !@U!,0!$%#!R2&:2!0&-2'!4.#00-.#!(#;#(!5$!',0$523#!TUD!! G2',;,'-5(! 0&-2'! 4.#00-.#!(#;#(0! 5$!5! 45.$,3-(5.! 4&,2$! 6.&1! 0#;#.5(! ',66#.#2$! 2&,0#! 0&-.3#0!3522&$! N#! 3&1N,2#'! ',.#3$(*!,2! -2,$0! &6! '78D!!V5$%#.9!$%#!-2,$0! 2##'!$&! N#!3&2;#.$#'!$&! 035(5.! 0&-2'!,2$#20,$*! -2,$0!,2!&.'#.!$&!N#!5''#'!$&)#$%#.9!$%#2!3&2;#.$#'!N53R!$&!'#3,N#(!-2,$09!533&.',2)!$&!$%#!6&.1-(5S! :%#.#!@E!,0!$%#!$&$5(!0&-2'!4.#00-.#!(#;#(!52'!!
@/9!@O9!#$3!5.#!,2',;,'-5(!0&-2'!4.#00-.#!(#;#(0D!
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
@=!\!@U!]!OP!(&)>TUWT=B9!
!!YP!'78! (,N.5.*!
!!^P!'78! .-.5(!N53R).&-2'!
!!MP!'78! &66,3#!0453#!
!!_P!'78! 3&2;#.05$,&2!
!!KP!'78! 35.!.5',&!
!!`P!'78! $.566,3!3&.2#.!
!!LP!'78! (5:21&:#.!
@E!\!/P!(&)!>/P@/W/P!]!/P@OW/P!]!aB9!
©2023
ATTACHMENT 8

Radio Frequency Supplemental Report
#2
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
January 30, 2026
10 PARK PLACE BUILDING 6C SUITE 402 , BUTLER , N J 0 7405 PHONE 973 - 628 - 9330 Exhibit J
ATTACHMENT 8

The following addresses additional questions posed after the public meeting on January 21, 2026

1. Will Verizon’s proposal interfere with LMR / Public Safety Radio? No. Verizon’s wireless system operates on frequency bands that are separately licensed and exclusively assigned to Verizon by the Federal Communications Commission (FCC), and are distinct from the frequencies allocated for LMR and public-safety radio services. FCC regulations require all licensed operators to design, operate, and maintain their systems in a manner that prevents harmful interference to other licensed users. In practice, commercial wireless facilities are routinely collocated with public-safety and other LMR systems nationwide without interference issues.

2. Provide clarification on coverage provided from SC002 and SC005.

Please refer to the attached EXHBIT 1 which is a modeled best server plot that demonstrates the contribution of each existing site in the network. Best server plots were prepared representing a threshold of -95 dBm RSRP. Areas without any color represent lack of dominant server in the area, consistent with the drive test poor signal quality areas. • Downtown Carmel’s transmitters provides dominance in the areas illustrated with dark green, blue, and pink in the upper right hand corner of map. • SF South Carmel 003’s transmitters provides dominance in the areas illustrated with burgundy and navy in the center right portion of the map • The Founder’s Building’s transmitters provides dominance in the area illustrated with yellow, appearing along the west portion of the map.

Please refer to the attached EXHBIT 2 which is a modeled best server plot that demonstrates the contribution of each existing and approved site (SF-002 and SF-005)in the network. • Downtown Carmel’s provided coverage is illustrated with dark green, blue, and pink colors in the upper right hand corner of map.
• SF South Carmel 003’s coverage is illustrated with burgundy and navy colors in the center right portion of the map
• The Founder’s Building’s provided coverage is illustrated in a yellow color, appearing along the west portion of the map.
• SF South Carmel 002’s transmitters provides dominance in the area illustrated with a red color appearing in the lower left corner of the map • SF South Carmel 005’s transmitters provides dominance in the area illustrated with a light blue color appearing in the right central part of the map.

As can be seen from Exhibit 2, SF South Carmel 005 extends dominance east of the gap area only. SF South Carmel 002 provides dominance in the southwest portion of the service gap area only.

ATTACHMENT 8

Exhibit 2 demonstrates that the result of the existing and approved sites’ coverage still leaves a coverage deficiency at mid band, which must be addressed by a new facility.

3. Drive Test vs Modeling
Drive testing is conducted to measure existing signal levels from operational wireless facilities.

Modeling is used to plan wireless networks and to evaluate the expected signal levels from future sites, by producing coverage maps. Drive tests collect live data on roads that can be driven while modeling provides coverage across an area. Both are used collectively to design and optimize wireless networks.

4. Activation of approved sites (002/005) on capacity and drop calls Due to the poor signal quality in the area (SINR) a need to provide a dominant serving site is necessary to provide adequate service. Please refer to the attached EXHBIT 2 which is a modeled best server plot that demonstrates the area of dominance of each approved and existing site that will serve at the desired -95 dBm (minimum in-building design level) reference signal power level.

As can be seen from Exhibit 2, only SF South Carmel 002 provides a dominant reference signal power to the southwest portion of the service gap area (grey hashed polygon). It is expected that the existing poor service in this area will be markedly improved once the site is operational. This is because a new reliable dominant signal will be present and overcome the poor signal power (RSRP) level at mid band (see attached Exhibit 3), and poor signal quality (SINR) at low band (see attached Exhibit 4). The extent of SF South Carmel 002’s contribution is limited to the area shaded in red only, as this corresponds to the reliable in-building signal level of -95 dBm RSRP on Exhibit 2. From 12th Avenue to 7th Avenue, between Cassanova Street and San Antonio Ave, the service gap remains unchanged, and therefore a solution is still warranted.

5. Validation of Drive Test Data
The drive test data collected was performed utilizing a calibrated receiver and industry standard equipment. See attached certificate of calibration (Exhibit 7). The methodologies utilized are sound and the data provided has not been adjusted in any manner.

6. Segmenting of 2100 MHz
Verizon deploys its licensed frequency bands in the most efficient means possible to ensure they have a reliable network. The issue here is not with segmentation of the mid-band frequencies. The issue is providing a dominant server in the area where low band is causing poor signal quality and drop calls, and mid-band signal isn’t reaching into the area of the gap.

Therefore, segmentation will have zero impact on improving mid band coverage or improving signal quality (SINR) into the gap area. What is needed is a site that provides a dominant midband serving signal to the area. There currently is none.

ATTACHMENT 8

7. Further explanation of summary table -stats on Golden Bough, interference, overlap
Summary table 3 provided on page 22 of the PierCon RF report provides the statistical analysis comparison between the modeling of the Proposed Site and the Alternate Golden Bough location. The data illustrates that the Proposed Site will address 37 percent of the service gap area (desired), with the predicted signal overlap potential of 48 percent (not desired). By comparison, a two sector site at the Golden Bough will address 31 percent of the service gap area (desired), with the predicted signal overlap potential of 85 percent (not desired). The conclusion is that the Proposed Site is in the proper location, maximizing the desired coverage, and limiting the undesired coverage. The Golden Bough location provides more undesired coverage than desired coverage, indicating it is in the wrong location to meet Verizon’s design objectives.

8. Causation of drop calls -definition and explanation
The dropped calls in the Service Area Gap are the result of the absence of a dominant serving site, which leads to poor signal quality. This condition is clearly reflected in the industrystandard drive test data, including the signal quality (SINR) and best-server maps provided.

Users initially connect to the LTE network through nearby cell sites; however, as they move away from those sites, signal quality degrades rapidly. This degradation occurs first on midband frequencies, followed by a transition to low-band frequencies as distance from the serving site increases. As demonstrated in the drive test data, low-band signal levels are stronger within the gap area, resulting in users primarily operating on low-band spectrum in this region.

Because low-band frequencies propagate over greater distances, they overlap with multiple surrounding sites. The best-server maps confirm that this overlap produces areas where lowband signals from different sites arrive at similar power levels. In the absence of a dominant serving sector, these overlapping signals interfere with one another, resulting in degraded signal quality and poor SINR.

Without a dominant signal, all non-serving signals are treated as interference, creating an unstable RF environment that leads to dropped calls. The dropped-call data further confirms this condition, showing the highest concentration of dropped calls occurring on low-band frequencies from the sites currently serving the area. This relationship is well understood by experienced radio-frequency engineers and directly results from the lack of a dominant serving site within the Service Area Gap.

9. Optimizing existing sites to provide additional bandwidth? No. Additional bandwidth is primarily a capacity-related solution and does not address the underlying cause of the service gap. The deficiency in this area is not due to network ATTACHMENT 8

capacity, but rather the absence of a dominant serving site and adequate mid-band signal coverage.

Optimization of existing sites cannot create a dominant mid-band signal within the gap area.

To meaningfully improve service quality, a new site must first be deployed to establish dominant mid-band coverage. Once a dominant mid-band serving sector is in place, the lowband antennas on surrounding sites can be further downtilted to reduce excessive low-band overlap in the area.

Implementing low-band downtilting prior to establishing a dominant mid-band signal would worsen network performance by further degrading signal quality (SINR), increasing interference, and resulting in additional dropped calls.

10.Frequency shift by users-ability to support users
The LTE network manages frequency selection and transitions seamlessly. User devices are initially served on mid-band frequencies when signal quality allows, as mid-band spectrum provides the best balance of coverage, signal quality, and data throughput.

As a user moves farther from the serving site and mid-band signal quality degrades, the device automatically transitions to the next available lower-frequency band with better propagation characteristics. This progression typically follows the sequence of approximately 3700 MHz, 2100 MHz, 1900 MHz, 850 MHz, and ultimately 700 MHz.

If, upon reaching the 700 MHz band, signal quality remains poor due to the absence of a dominant serving site—where overlapping signals from multiple sites introduce interference and degrade SINR—the RF environment becomes unstable and the call will drop.

11.FCC maps
The FCC coverage maps submitted by Beagle represent modeled outdoor signal levels only and do not reflect indoor service performance. Verizon’s network design objective in this area is to provide reliable in-building service, which is not depicted or evaluated in the FCC maps.

In addition, the FCC maps do not distinguish between individual frequency bands, nor do they provide any indication of signal quality, such as signal-to-interference-plus-noise ratio (SINR). As a result, the maps do not capture the interference conditions or lack of a dominant serving site that are central to the service issues identified in this area.

The FCC itself acknowledges these limitations in the disclaimer on its broadband coverage website, which states in part:
“Please note that the map does not include information on the availability of mobile wireless broadband service while indoors. Moreover, because the coverage map is based on propagation modeling, a user’s actual, on-the-ground experience may vary due to factors ATTACHMENT 8

such as the end-user device used to connect to the network, cell site capacity, and terrain.

The coverage maps on mobile wireless service providers’ websites may be based on different parameters and assumptions, such as service availability provided through roaming agreements, and therefore may differ from the information shown here.” Accordingly, FCC coverage maps are not an appropriate substitute for industry-standard drive test data and frequency-specific RF engineering analyses when evaluating in-building wireless service performance.

12. Alternates

1. The Wastewater District Facility
The Wastewater District Facility was modeled to evaluate what the coverage contribution would be as related to the existing service gap area. Please refer to Exhibit 5 for a graphical representation of the expected -95 dBm coverage to be provided form this location. As can be seen, this site is located well south of the service gap area, and even when modeled at 67 feet above ground level, does not contribute reliable signal level to the service gap area. If the site does not contribute to the reliable in-building signal level, it will have no impact on addressing the poor network service performance items.

2. Golden Bough
As discussed previously in the RF Report, the Golden Bough location is situated approximately 900 feet from the existing Verizon SF South Carmel 003 facility and approximately 1,100 feet from the Proposed Site. When modeled using a canister clover antenna configuration at a height of 24 feet above ground level (AGL), the site produces excessive overlap with existing facilities, resulting in increased interference rather than meaningful coverage extension into the Service Area Gap. Under this configuration, the Golden Bough location does not function as an equivalent alternative to the Proposed Site.

Additional best-server modeling was performed to assess whether the site could be made viable under more aggressive and constrained design parameters. The only configuration that produced marginally acceptable modeled results required all of the following conditions simultaneously:
• Antenna centerline height: 34 feet AGL
• Antenna azimuths: 220° and 330°
• Antenna model: Andrew NHHS4-65B-R3B
• Antenna dimensions: ~ 72 inches (H) × 13.8 inches (W) × 8.2 inches (D) • Narrow horizontal beamwidth antennas
Even under this highly constrained and optimized configuration, the modeling results must be evaluated against actual field conditions. The Golden Bough building is surrounded by mature, tall trees, particularly along the west side of the property, in close proximity to the proposed antenna mounting locations.

ATTACHMENT 8

As shown on Exhibit 6, the Golden Bough Building is located near the center of the map.

The blue lines illustrate the modeled antenna azimuths (220° and 330°), while the red lines depict the corresponding 3 dB horizontal beamwidths. Notably, multiple large trees along Casanova Street fall directly within each antenna’s main radiation pattern. These trees exceed the height of a potential 34-foot antenna installation and would significantly attenuate midband signals.

This attenuation is especially critical given that mid-band frequencies are inherently more susceptible to vegetation loss, particularly when tree canopies are located in close proximity to the antenna. A field-based review of the area west of the building confirms the presence of dense, tall vegetation that would materially degrade signal levels relative to those predicted by the propagation model.

As a result, the modeled performance at this location does not reliably translate to real-world conditions. 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.

12.Design - Ability to reduce equipment to C-band only
No. Verizon designs its network to operate across its full portfolio of FCC-licensed frequency bands to provide reliable and continuous service. The 1900 MHz (PCS) and 2100 MHz (AWS) bands provide substantially greater propagation range than 3700 MHz (C-Band) and are necessary to support seamless band-to-band transitions as users move throughout the network.

Limiting the design to C-Band only would significantly reduce coverage due to its shorter propagation characteristics and would require the deployment of additional facilities to address the Service Area Gap. Such an approach would be inconsistent with sound RF engineering practices and would increase both infrastructure density and visual impact, rather than reduce it.

13.911 calls on any carrier?
No. Emergency calls are routed to another carrier’s network only when a user’s device has no service at all on its home carrier, not when service is present but degraded. In the Service Area Gap, Verizon service is available but inadequate due to the absence of a dominant serving site, resulting in poor signal quality (low SINR).

Under these conditions, user devices remain camped on Verizon’s network and attempt to place calls— including 911 calls—on that network. Because signal quality is poor, calls frequently fail or drop. This behavior is confirmed by the dropped-call data presented, which shows elevated call failures within the gap area.

ATTACHMENT 8

In this location, 911 calls will not reliably transfer to another carrier, as the device continues to recognize Verizon as the serving network throughout the Service Area Gap. As a result, emergency calling performance is directly impacted by the lack of a dominant Verizon serving site in the area.

Prepared by:

Richard Conroy
President / Principal RF System Engineer
PierCon Solutions, LLC
January 30, 2025
Ronald Lukach
Senior RF Engineer
PierCon Solutions, LLC
Date: January 30, 2025
ATTACHMENT 8

nio Ave
St
eal N
Casanova
nte Verde St
St
St
s St
St
St
Sa
a
St
nta Rita St
Del Mar Ave
San Anton oi Ave
8th Ave
Ocean View Ave
Scenic Rd
Martin
Way
Santa Lucia Ave
13th Ave
14th Ave
Valley
View Ave
Carmelo
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
Ridgewood
Rd
Rio
Rd
Franciscan Way
Ladera
Dr
Delores St
Sycamore P
Atherton Dr
Nindth Ave
Court of Golden Bough
Lasuen Dr

00.25 miles

VERIZON WIRELESS

BEST SERVING TRANSMITTER IN AREA OF GAP
Mid Band - Best Serving Transmitters (-95 dBm)
Site sectors
Existing On Air Site
Proposed Site
Mid-Band Gap

0.27 Square Miles
Approved Site
SF-003-Alpha
Downtown Carmel-Beta
Downtown Carmel-Alpha Founders Building-Beta
Downtown Carmel-Gamma
SF-003-Beta
ATTACHMENT 8

nio Ave
St
eal N
Casanova
nte Verde St
St
St
s St
St
St
Sa
a
St
nta Rita St
Del Mar Ave
San Anton oi Ave
8th Ave
Ocean View Ave
Scenic Rd
Martin
Way
Santa Lucia Ave
13th Ave
14th Ave
Valley
View Ave
Carmelo
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
Ridgewood
Rd
Rio
Rd
Franciscan Way
Ladera
Dr
Delores St
Sycamore P
Atherton Dr
Nindth Ave
Court of Golden Bough
Lasuen Dr

00.25 miles

VERIZON WIRELESS

BEST SERVING TRANSMITTER IN AREA OF GAP
Mid Band - Best Serving Transmitters (-95 dBm)
Site sectors
Existing On Air Site
Proposed Site
Mid-Band Gap

0.27 Square Miles
Approved Site
SF-003-Alpha
Downtown Carmel-Beta
Downtown Carmel-Alpha
SF-005
SF-002
Founders Building-Beta
Downtown Carmel-Gamma
SF-003-Beta
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 (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
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%)
ATTACHMENT 8

Wastewater Facility
Dr
W
Live
Oak M
el Ciervo
Rd
N
San Antonio
Ave
N
Carmelo St
Dolores St
2nd
Ave
Monte Verde St
San Carlos St
alupe St
Alta Ave
Torres St
Santa
Fe
St
s Ave
C
arpenter St
M si s oi n St
3rd Ave
Jun pi ero St
Santa Rita St 4th Ave
5th Ave
Upper Trl
H
andley
Dr
Valley Way
Lobos
St
R
and
all Wa
y
H
atton Rd
Valley Pl
Stewart Pl
High Meadow Dr
Edgefield Pl
Outlo
o
k
Dr
Del Mar Ave
8th Ave San Antonio Ave
Ocean View Ave
Scenic Rd
14th Ave
7th Ave
Casanova St
Carme ol St
Lincoln St
9th Ave
Camino Real 10th Ave
11th Ave
13th Ave
Stewart Way
17th Ave
16th Ave
Calle la
Cruz
Ribera
Rd
Arriba Way
6th Ave F
orest Rd
Mountain View Ave
Rio
Rd
Ladera
Dr
Mesa
Dr
Oak Pl
Cabrill
o
Hwy
Mesa Ct
N
M
esa
Dr
S Carmel Hills D
Ath
r
erton Dr
Taylor Rd
Delores St
Sycamore Pl
Oliver Rd
Fisher Dr
Hillcrest Cir
Whitman Cir
Row Pl
Ryan
Carmel Valley Rd
Partridge
Dougherty
Carmel Rancho
Carmel Center Pl
Crossroads Blvd
Flanders Way
mber Dr
Arroy
Lazarro Dr

0.5 miles
0 VERIZON WIRELESS

BEST SERVING TRANSMITTER IN AREA OF GAP
Mid Band - Best Serving Transmitters (-95 dBm)
Site sectors
Existing On Air Site
Proposed Site
Mid-Band Gap

0.27 Square Miles
Approved Site
SF-003-Alpha
Downtown Carmel-Beta
Downtown Carmel-Alpha
Wastewater Facility
SF-005
SF-002
Founders Building-Beta
Downtown Carmel-Gamma
SF-003-Beta
ATTACHMENT 8

Golden Bough Antenna Site Lines Legend
Golden Bough
200 ft
N
➤
Image Landsat / Copernicus
ATTACHMENT 8

ATTACHMENT 8

ATTACHMENT 8

Radio Frequency Supplemental Report
#3
Site ID: “Carmel Node 001”
RF Supplemental Report
Carmelo Street
Carmel-by-the-Sea, CA 93921
Monterey County
P rep a red for
Ve ri zo n Wir ele ss
By
Pi e rC on Solut i ons , LLC
February 9, 2026
1 0 P A R K P L A C E B U I L D I N G 6 C S U I T E 4 0 2 , B U T L E R , N J 0 7 4 0 5 P H O N E 9 7 3 - 6 2 8 - 9 3 3 0 Exhibit K
ATTACHMENT 8

Golden Bough Rooftop Technical Viability Determination
There is a significant gap in wireless service between Ocean Ave and 13th Ave from Scenic Road to Casanova Street. The gap has been determined through field collected drive test data utilizing a calibrated scanning receiver. The data has been presented in raw form with no manipulation in accordance with standard engineering practices. The drive test data demonstrated poor low band signal quality and lack of mid-band signal power for inbuilding services. The gap is due to the lack of a dominant serving site combined with distance away from existing and planned facilities.

The service area surrounding the proposed facility is best characterized as a topographically constrained dense residential coastal environment, where rapidly descending terrain toward the shoreline, mature vegetation, and irregular street layouts produce highly variable propagation conditions. These characteristics limit the effectiveness of broad, directional coverage strategies and instead favor a localized small cell architecture designed to provide reliable in-building service within discrete neighborhood coverage zones.

Residential traffic patterns in this area are distributed rather than corridor-based, further supporting the use of an omnidirectional small cell to deliver balanced signal conditions in all directions without introducing sector boundaries that may degrade signal dominance or mobility performance. The proposed facility is therefore engineered with a low-gain omnidirectional antenna and electrical downtilt to concentrate usable energy into the surrounding residential area while maintaining controlled propagation and minimizing the potential for overshoot toward the coastline.

Consistent with modern small-cell design principles, the proposed node is positioned to function as part of a coordinated network with the previously approved facilities, completing the intended spacing geometry necessary to achieve the identified in-building service objective. This localized design approach is particularly appropriate in environments where terrain transitions and vegetation influence signal behavior and where closer site placement improves both downlink reliability and uplink feasibility for indoor users.

Consistent with the network design approach described above, any alternative facility must be capable of delivering localized, dominant in-building coverage within the defined service area while integrating effectively into the planned small-cell spacing geometry. Equivalency is therefore evaluated based on the ability of a candidate location to provide controlled small cell propagation, maintain predictable signal quality, and support reliable uplink connectivity for indoor users without introducing excessive inter-cell overlap or unintended coverage extension beyond the target neighborhood.

This evaluation applies established RF engineering methodology to determine whether a technically viable solution exists that can reliably achieve the defined in-building service objective within the subject area.

As shown in Exhibit 1A, the Golden Bough rooftop is positioned outside the established small cell spacing geometry relative to the defined service gap.

ATTACHMENT 8

io Ave
St
al N
Casanova
nte Verde St
St
St
St
St
St
Sa
St
anta Rita St
Del Mar Ave
San Anton oi Ave
8th Ave
Ocean View Ave
Scenic Rd
Martin
Way
Santa Lucia Ave
13th Ave
14th Ave
Valley
View Ave
Carmelo
St
7th Ave
9th Ave
10th Ave Casanova St
6th Ave
Ocean Ave
11th Ave
12th Ave
Camino Real
15th Ave
Inspiration Ave
Stewart Way
17th Ave
16th Ave
Walker Ave
Mountain View Ave
Torres St
F
orest Rd
Vizcaino Ave
Crespi Ave
Ridgewood
Rd
Rio
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
Mid Band - Best Serving Transmitters at -95 dBm
Site sectors
Existing On Air Site
Proposed Site
Mid-Band Gap

0.27 Square Miles
Approved Site
SF-003-Alpha
Downtown Carmel-Beta
Downtown Carmel-Alpha Founders Building-Beta
Downtown Carmel-Gamma
SF-003-Beta
SF-002
SF-005
EXHIBIT 1A - SMALL CELL SPACING GEOMETRY RELATIVE TO THE SERVICE GAP ATTACHMENT 8

Alternative configurations that rely on projecting signal over distance, rather than establishing proximity-based service within the residential area, may not achieve these objectives in environments where terrain transitions and vegetation influence propagation behavior. Accordingly, candidate sites were assessed not only through predictive modeling, but also through consideration of physical antenna placement feasibility and the surrounding clutter environment to determine whether they could provide an engineering solution comparable to the proposed facility.

The Golden Bough rooftop was evaluated as a potential alternative location to determine whether it could provide an engineering solution equivalent to the proposed facility under the small cell design criteria described above. While predictive coverage modeling may suggest the ability to extend signal into portions of the service area, field verification and site-specific conditions indicate that the rooftop presents physical and radio-frequency constraints that limit its effectiveness for localized in-building coverage.

Exhibit 2A provides field-verified photographic documentation illustrating the directional constraints associated with the rooftop environment.

ATTACHMENT 8

EXHIBIT 2A – Field-Verified Physical Constraints
Approximate antenna centerline
Vegetation extending above antenna elevation. Primary propagation corridor Extended line-of-sight environment.

Field verification demonstrates that rooftop siting conditions materially constrain the ability to achieve reliable, localized small cell coverage within the defined service area.

Southwest Orientation
Vegetation Encroachment Into Radiation Plane
Northwest Orientation
Extended Line-Of-Site Propagation Environment
ATTACHMENT 8

The southwest antenna orientation is subject to dense near-field vegetation that obstructs the antenna look angle and introduces attenuation not fully captured in predictive modeling.

At mid-band frequencies, such obstruction reduces signal dominance and increases variability in indoor performance, particularly in residential environments where building penetration loss is already a governing factor. Conversely, the northwest orientation presents an extended line-of-sight propagation path across open water. Although favorable for signal travel, this geometry increases the likelihood of unintended coverage extension and inter-cell interference, which is inconsistent with the controlled coverage objectives of small cell architecture.

Additionally, the rooftop’s position relative to the previously approved facilities does not align with the intended spacing geometry necessary to establish proximity-based service within the defined gap area. Small cell networks rely on appropriately distributed node placement to improve both downlink reliability and uplink feasibility for indoor users; locations that primarily project signal over distance rather than reducing separation between the user and serving site are less effective in achieving these outcomes.

Although predictive modeling suggests that a facility located on the Golden Bough rooftop could extend signal into portions of the identified service gap, RF engineering viability must be evaluated based on real-world deployment conditions rather than theoretical propagation alone. Field verification confirms that mature vegetation extends directly into the feasible antenna radiation path at elevations comparable to, and in some cases exceeding, the proposed antenna centerline. Near-field obstruction of this nature is not fully captured in predictive modeling and is well understood to materially reduce signal dominance, increase variability in indoor performance, and limit uplink reliability — particularly at mid-band frequencies where foliage attenuation is pronounced.

Because small cell design relies on controlled, localized propagation and reduced separation between the user and serving site, a configuration that is simultaneously obstructed in the direction of the service objective and prone to unintended coverage extension cannot reasonably be expected to reliably remediate the documented service deficiency. Accordingly, while modeling may indicate theoretical signal reach, the engineering record does not support the Golden Bough rooftop as a technically viable location capable of achieving the defined in-building service objective.

Based on the technical evaluation described above, the proposed facility represents the only technically viable location supported by the engineering record capable of delivering dominant, reliable in-building service within the defined gap area while integrating with the planned small cell spacing geometry. Alternative locations that are constrained by physical siting limitations or that rely on extending signal over distance do not provide the proximitybased coverage necessary to remediate the service deficiency and therefore cannot be considered viable engineering solutions.

Accordingly, based on the technical evaluation described herein, the engineering record demonstrates that the proposed facility is necessary to provide reliable, proximity-based inbuilding service within the defined gap area, and no technically viable alternative location has been demonstrated capable of reliably achieving this objective.

ATTACHMENT 8

Prepared by:

Richard Conroy
President / Principal RF System Engineer
PierCon Solutions, LLC
February 9, 2026
Ronald Lukach
Senior RF Engineer
PierCon Solutions, LLC
February 9, 2026
ATTACHMENT 8

DR 25313 & UP 25314 (Verizon Sequoia Deployment) Carmel Planning Commission Verizon Wireless Responses Volume 2
February 6, 2026
1 Verizon Wireless’s Responses Volume 2
Topic Page

1. Gap Continued 1

2. Alternatives 2

3. Design Continued 3

4. Environmental Review Continued 4

1. GAP CONTINUED
Project opponents allege that there is no significant gap, claiming phones can shift frequencies, so a gap in a particular frequency is not important.

Prior to submitting this application, Verizon Wireless network engineers determined there was a gap in coverage and capacity in the area. PierCon Solutions, a third-party engineering firm, conducted a drive test, reviewed Verizon Wireless’s data, and confirmed the gap. Staff Report, Att. 7, pp. 159-235; Att. 8, p. 238.

After Verizon Wireless submitted its application, the City hired CTC Telecommunications Network Consulting “to conduct a third-party review of the technical aspects of the Verizon application.” Id., Att. 10, p. 286. The Code and Guidelines include rigorous submittal requirements, including drive test and dropped call data.

Wireless Application Checklist Types I-V, Section 15.2.1. PierCon validated the drive test data, stating that the “data collected was performed utilizing a calibrated receiver and industry standard equipment” and included the certificate of calibration. PierCon Suppl. Rpt. 2, p. 3 and Exh. 7. Verizon Wireless provided all the required data, which CTC examined and “performed [their] own independent technical analysis to reach conclusions about the application.” Staff Report, Att. 10, p. 286. CTC concluded that:

Verizon has provided credible evidence of existing wireless service deficiencies in the target area due to overloaded traffic in the 700/850 MHz bands and high levels of signal interference, causing unacceptably high dropped connections/calls. This means the available signal does not actually deliver an acceptable quality of wireless service today.

Additionally, Verizon has shown the area to be served by the small wireless facility lacks reliable 5G service.

Id., Att. 10, p. 287.

In its January 30, 2026, Supplemental Report #2, PierCon has provided best server plots that show the coverage that each wireless facility is contributing to the network. PierCon Suppl. Rpt. 2, pp. 2-3 and Exhs. 1-

2. Best server maps show which Verizon Wireless facility provides the best signal to a certain area. Signal from each antenna sector of a facility is shown in a different color. The best server maps predict which antenna sector generally provides the strongest signal to user devices in a particular location, even if weak and inadequate for reliable service.

As can be seen in PierCon’s Exhibits 1 and 2, the areas around the proposed facility are white, which indicates that there is no dominant signal in the area. PierCon Suppl. Rpt. 2, Exhs. 1-2. Dominant signal is signal that is strong enough to exceed interfering signal levels from other Verizon Wireless facilities and radio frequency noise from other sources. Where there is dominant signal, users can reliably access the network.

Exhibit L
ATTACHMENT 8

DR 25313 & UP 25314 (Verizon Sequoia Deployment) Carmel Planning Commission Verizon Wireless Responses Volume 2
February 6, 2026
2 Where there is no dominant signal, service is unreliable. Phones cannot shift to other frequencies if they are not available.

What will be the coverage provided by Verizon Wireless small cells 002 and 005, located in the County? When will they be on air?
PierCon has supplemented its original report to explain the coverage expected to be provided by small cells 002 and 005. PierCon Suppl. Rpt. 2, pp. 2-3 and Exhs. 1-2. While those two sites will provide additional coverage when they are constructed, they will not alleviate the need for the proposed facility. Id. These sites are currently in process. They will be scheduled for construction as soon as the relevant third parties have provided the required infrastructure for the sites to be operational.

What is the status of Verizon Wireless’s Lobos Ridge site? Verizon Wireless is continually reviewing its network and optimizing based on need, usage, and changing circumstances. At this time, there is not an active decommission project for this site. It has been superseded by subsequent network upgrades.

2. ALTERNATIVES
The Commission and project opponents inquired about the feasibility of a wireless facility at the Golden Bough Theatre or the Water Treatment Plant (Carmel Area Wastewater District) in the County.

PierCon has provided a thorough analysis of the Golden Bough site, which both the City and CTC have confirmed, finding that this site is too far from the gap and causes interference with existing and proposed sites. Staff Report, p. 162; Att. 7, pp, 175-177; Att. 10, pp. 303-304; PierCon Suppl. Rpt. 2, pp. 6-7 and Exh. 6.

PierCon found that the mature trees near the site would “significantly attenuate mid-band signals.” Id. at pp. 6-7 and Exh. 6. Separately, Sequoia Deployment Services has visited the Golden Bough Theatre with the landlord to evaluate the feasibility of a potential wireless facility.

PierCon has provided a thorough analysis of the Golden Bough site, which both the City and CTC have confirmed, finding that this site is too far from the gap and causes interference with existing and proposed sites. Staff Report, p. 162; Att. 7, pp, 175-177; Att. 10, pp. 303-304; PierCon Suppl. Rpt, pp. 6-7 and Exh. 6.

PierCon found that the mature trees near the site would “significantly attenuate mid-band signals.” Id. at pp. 6-7 and Exh. 6.

Separately, Sequoia Deployment Services met with the Golden Bough Theatre on February 4, 2026, to evaluate the property to determine whether there is any equipment configuration that could satisfy the landlord and comply with City requirements. A facility with ground equipment and rooftop antennas is constructable.

Space inside the building for equipment is not available due to heat and noise generation. During this visit, 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. The photo attached as Exhibit A facing the coverage objective confirms substantial tree cover at the proposed antenna elevation, irrespective of whether omnidirectional or high gain, narrow-beam directional antennas focused on the coverage area are modeled.

These trees would obstruct the signal from the antenna, preventing it from serving the coverage area.

Furthermore, it is unknown at this time if agreeable lease terms can be obtained for a facility at this location.

ATTACHMENT 8

DR 25313 & UP 25314 (Verizon Sequoia Deployment) Carmel Planning Commission Verizon Wireless Responses Volume 2
February 6, 2026
3 Verizon Wireless has been trying to provide service around the wastewater district property since 2012.

Verizon Wireless could not negotiate a lease with the landlord for a macro wireless facility on that property.

Part of the difficulty with the wastewater site is that rights to use the access road would be required from California State Parks. That agency is unlikely to approve any development on public lands on the west side of Highway One. Even if Verizon Wireless was to somehow overcome these issues with the landlord and access road, Monterey County is unlikely to approve a permit due to the location and potential impacts on views as well as requirement related to existing eucalyptus trees. Verizon Wireless has unsuccessfully revisited this site several times over the intervening years.

Theoretically, if Verizon Wireless were able to secure the approvals required to construct a macro wireless facility at the wastewater district property, it is located too far south to provide coverage for the gap area that the proposed site seeks to fill. As PierCon has explained in its January 30, 2026, Supplemental Report, even assuming an antenna height of 67 feet on a 75-foot-tall tower, a macro tower at the wastewater district “does not contribute reliable signal level to the service gap area.” PierCon Suppl. Rpt. 2, p. 6 and Exh. 5.

We also received questions inquiring about Verizon Wireless’s ability to buy more bandwidth and avoid the low band constraint and optimizing existing sites.

Spectrum and bandwidth are limited resources, which the FCC auctions off every few years. Even if additional bandwidth were available for purchase, PierCon explains why that would not address the underlying cause of the service gap. PierCon Suppl. Rpt. 2, pp. 4-5.

3. DESIGN
Verizon Wireless was asked about whether the accessory equipment can be reduced. For example, does Verizon Wireless need both 5G and mid-band.

As PierCon explains in its supplemental report, Verizon Wireless “designs its network to operate across its full portfolio of FCC-licensed frequency bands to provide reliable and continuous service.” PierCon Suppl. Rpt. 2, p. 7. If the proposed facility proceeded with only 5G/C-Band, Verizon Wireless would have to install additional small cells in the area. Id.

Verizon Wireless could potentially install an alternative configuration that would eliminate C-Band radio from the largest cabinet and reconfigure it to three integrated radio antennas on a mid-mount cross-arm. The total volume of equipment would be reduced by .24 cubic feet. However, we believe this design is disfavored by most communities, as placing antennas lower on the pole is generally considered to have greater impacts since its closer to an average person’s line of sight. There is greater tree blockage at this height as well, further impeding the signal. PG&E would also have to approve the design. Mounting the antennas at this lower height would also result in less coverage. Absent the relocation of the C-Band antennas, eliminating one radio, likely providing AWS and PCS service, will prohibit the proposed facility from fulfilling its coverage objective. PierCon Suppl. Rpt. 2, p. 7. The end result is that Verizon Wireless will have to install more facilities to fill the gap. Id.

The public commented that future collocations on this pole can proceed with minimal review by the City.

We note that eligible facilities requests, or 6409 requests, are contemplated by the Code as Type V sites. Any consideration of such requests is purely speculative at this point, especially in light of the PG&E and California Public Utilities Commission regulations governing wireless facilities on this pole. Furthermore, Type V sites ATTACHMENT 8

DR 25313 & UP 25314 (Verizon Sequoia Deployment) Carmel Planning Commission Verizon Wireless Responses Volume 2
February 6, 2026
4 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.

4. ENVIRONMENTAL REVIEW CONTINUED
Project opponents also claim that United Keetoowah Band of Cherokee Indians in Oklahoma v. FCC, 933 F.3d 728 (D.C. Cir. 2019) invalidated the FCC rule that Verizon Wireless cited for NEPA exclusion. The Keetoowah case invalidated an FCC 2018 exclusion for small cells. Verizon Wireless cited the prior exclusion for certain wireless facilities, 47 C.F.R. § 1.1306(c)(1), which pre-dates the FCC order and is still effective. Verizon Wireless has fully complied with NEPA by self-certifying pursuant to 47 C.F.R. Part 1, Appendix B, Stipulation VI – A – C.

ATTACHMENT 8

EXHIBIT A
ATTACHMENT 8

DR 25313 & UP 25314 (Verizon Sequoia Deployment) Carmel Planning Commission Verizon Wireless Responses Volume 3
February 24, 2026
1 Verizon Wireless’s Responses Volume 3
Topic Page

1. Design Continued 1

2. Alternatives Continued 1

1. DESIGN CONTINUED
We were asked about impacts to the adjacent oak tree.

Verizon Wireless, the City, and a PG&E arborist met at the site on February 4, 2026, to determine what impacts, if any, would impact the adjacent tree. PG&E’s arborist determined that due to the site’s distance from the tree, it would not impact the root system. Furthermore, the replacement pole will be placed in the same hole as the existing pole, so there will be no additional impacts to the roots.

2. ALTERNATIVES CONTINUED
The Commission and project opponents inquired about the feasibility of a wireless facility at the Golden Bough.

Technical Infeasibility
As Verizon Wireless has maintained for the duration of this application, the Golden Bough is not technically feasible and available alternative. To further explain why a rooftop wireless facility on the Golden Bough is not technically feasible PierCon Solutions prepared a new report, Radio Frequency Supplemental Report # 4, dated February 23, 2026. The report summarized the additional technical evaluations PierCon Solutions performed and concludes that the Golden Bough “does not represent a technologically feasible alternative for achieving the documented service objectives under consistent engineering criteria.” Report at p. 4. PierCon included an appendix to the report that includes the parameters of their analysis so that it can be duplicated and analyzed by the City’s expert consultant, CTC. Report at p. 25.

Practical Infeasibility
Sequoia Deployment Services met with the Golden Bough on February 4, 2026, to evaluate the property to investigate the feasibility of locating a wireless telecommunications facility on the property that would meet Verizon Wireless’s needs. The site design concept was to build a site with one equipment cabinet, four remote radio units, four panel antennas, generator receptacle or lug box, electrical power fiber connections, and associated cabling. The antennas and rooftop equipment would be screened with a faux chimney.

The building is approximately 165 feet east to west with a hip roof running in the east-west direction. The east and west ends are a full story lower than the main roof, necessitating that the antennas go on the upper roof.

The south portion of the roof is occupied by a large solar array. The east end of the building is shorter than the west end since the property slopes down approximately 22 feet east to west. The main floor at the east end is below street level while the basement level at the west end is above street level.

Exhibit M
ATTACHMENT 8

DR 25313 & UP 25314 (Verizon Sequoia Deployment) Carmel Planning Commission Verizon Wireless Responses Volume 3
February 24, 2026
2 The exterior of the property is entirely accessible to the public. The roof is only accessible with ladders and climbing equipment. PreVisualists, Inc. flew a drone with a camera to confirm roof conditions and potential surroundings from potential antenna locations. The coverage objective for the site is located west and southwest of the Golden Bough property, which requires antennas with views in those directions without immediate obstructions.

Verizon Wireless discussed height restrictions with the Planning Department prior to the visit, and they noted a ten-foot height limit above the top of the roof. This restriction limits antenna placement to the highest point of the roof near the west end for two reasons.

First, if the antennas were placed easterly on the building, the roof would interfere with the antennas oriented west. This location would diminish the effectiveness of this sector. Moving east also requires that any southwest or south oriented sector would be low compared to the level of the roof resulting in interference from the large solar array.

The second issue with placement off the west end of the roof is structural and equipment conflict. The west end of the roof is situated over a wall that extends backstage to the ground. This wall would support any loads through the building to the ground. This location is also accessible with cabling from below at the very back of the theater which already has utilities routed in this area and would not interfere with theater operations. The ATTACHMENT 8

DR 25313 & UP 25314 (Verizon Sequoia Deployment) Carmel Planning Commission Verizon Wireless Responses Volume 3
February 24, 2026
3 rest of the upper roof is an approximately 55-foot unsupported span north to south over the theater and stage area which already supports considerable stage equipment and the ceiling inside the building. This area is intensely used with cables, supports, HVAC ducting and a central catwalk running most of the upper attic space. It would be difficult to route cabling from equipment below to this central part of the roof without interfering with the theater equipment.

Since that site visit, Golden Bough has requested that the antennas be placed at the north edge of the building.

To accommodate this request, Verizon Wireless would have to install a much taller antenna structure. The structure would need to be 18 feet tall above the roof to maintain the same antenna elevation, where the height limit is ten feet above the roof. However, antennas at that location would likely have to be even taller.

Under either design, a ground cabinet is required to house fiber equipment. Due to the configuration of the available space and its uses inside the building, the best place to locate the cabinet is outside. The cabinet would be attached to the south wall of the building above where a trash dumpster is located.

While a wireless facility may be technically constructable at Golden Bough, it would not meet the Verizon Wireless’s needs. Furthermore, in addition to requesting that the wireless facility be located at the north edge of the roof, the Golden Bough has also expressed a desire to expand its solar panel array. In addition to occupying roof space, solar panel arrays cause interference with wireless signals (passive intermodulation), causing network disruption. Finally, it is not clear that Golden Bough would even lease its property to Verizon Wireless. It has expressed concerns over interference and impacts to their operations.

Increased Costs
In terms of costs, construction of a wireless facility on the Golden Bough roof, even if it were possible, would run at least three to four times as the proposed facility. Because the Golden Bough is not a technically feasible alternative for Verizon Wireless, it has not negotiated a lease with the theater. However, private property rent is generally orders of magnitude greater than the rent associated with a Joint Pole Association pole.

Furthermore, maintenance costs associated with a rooftop facility tend to be higher as well. The Golden Bough has also indicated that they may potentially request accommodations associated with their audio and visual equipment, which would further drive up the costs.

Historic Resource Impacts
The proposed pole is adjacent to a home designated as a Criteria 3 historic resource on the City’s Inventory of Historic Resources.
1 However, the pole itself is located within the public right-of-way. Due to its relatively small physical presence, the proposed wireless facility would have minimal visual impact on the adjacent home. The pole itself is not a protected historic resource.

The proposed alternative structure, Golden Bough, is designated as a Criteria 1 historic resource on the City’s Inventory of Historic Resources, which is a more protected designation than Criteria 3. A wireless facility proposed on the Golden Bough would require a Section 106 review, including completion and submission of Department of Parks and Recreation (“DPR”) forms to the California State Historic Preservation Office (“SHPO”). The Golden Bough is historic, in contrast to the pole in the public right-of-way. Based on the 1 Available at: https://ci.carmel.ca.us/sites/main/files/carmel_inventory_of_historic_resources_v11.2024.pdf ATTACHMENT 8

DR 25313 & UP 25314 (Verizon Sequoia Deployment) Carmel Planning Commission Verizon Wireless Responses Volume 3
February 24, 2026
4 structure types and the footprint associated with each option, the proposed stealth antenna on the pole would have less impact on historic resources in the area than a rooftop wireless facility on the Golden Bough.

ATTACHMENT 8

Utility Pole Due North of Proposed Facility with Transformer Carmelo Street between 10th Avenue & 11th Avenue
Utility Pole Due South of Proposed Facility with Side-Mounted Cabinet Corner of Carmelo Street & 11th Avenue
Exhibit N
ATTACHMENT 8

Radio Frequency Supplemental
Report #4
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
February 23, 2026
10 PARK PLACE BUILDING 6C SUITE 402, BUTLER, NJ 07405 PHONE 973-628-9330 2/23/2026 Page 1 of 25
Exhibit O
ATTACHMENT 8

Contents

1. Executive Summary .............................................................................................................................. 4

2. Background and Prior Engineering Record .............................................................................................. 4

2.1 Initial Engineering Evaluation ............................................................................................... 5

2.2 Subsequent Technical Supplements ................................................................................... 5

2.3 City Determination and Identification of Alternate Location .................................................. 5

2.4 Purpose of This Supplemental Evaluation ............................................................................ 6

3. Engineering Standard for Evaluating Alternatives ................................................................................... 6

4. Small Cell Network Design and Deployment Framework ....................................................................... 7

4.1 Proximity-Based Coverage Design ....................................................................................... 7

4.2 Deployment Architecture Selected for the Subject Area ....................................................... 8

4.3 Coordinated Node Spacing and Network Geometry.............................................................. 8 EXHIBIT A - SMALL CELL GEOMETRY .................................................................................... 10

4.4 Balanced Two-Way Service and Uplink-Limited Design....................................................... 11

4.5 Spatial Containment and Residential Deployment Objectives ............................................ 11

4.6 Application to the Subject Area.......................................................................................... 11

5. Golden Bough Rooftop – Technical Evaluation ..................................................................................... 12

5.1 Evaluation Framework ...................................................................................................... 12

5.2 Spatial Positioning Relative to the Service Gap ................................................................... 12

5.3 Rooftop Physical Constraints and Configuration Considerations ........................................ 12

5.4 Interpretation of Uplink-Limited Path Loss Maps ................................................................ 13

5.5 Uplink-Limited Comparative Path Loss (Omni-Equivalent Evaluation) ................................. 13 EXHIBIT B - UPLINK-LIMITED AWS PATH LOSS COMPARISON (127 dB MAPL) Proposed SF-001 Small Cell vs. Golden Bough Rooftop (Omni-Equivalent Configuration) ................................. 15

5.6 Long-Range Projection Characteristics – Golden Bough Rooftop ........................................ 16 EXHIBIT C - LINE-OF-SIGHT PROFILE - ELECTRICAL DOWNTILT SENSITIVITY 2º vs 8º ............ 17

5.7 Antenna Downtilt Sensitivity – Uplink-Limited Performance Impact .................................... 18 EXHIBIT D - COMPARITIVE UPLINK-LIMITED PATH LOSS (127 Db) Proposed SF-001 vs. Golden Bough (2º Electrical Downtilt) .............................................................................................. 20 EXHIBIT E - COMPARITIVE UPLINK-LIMITED PATH LOSS (127 Db) Proposed SF-001 vs. Golden Bough (8º Electrical Downtilt) .............................................................................................. 21

5.8 Comparative Configuration Summary ................................................................................ 22

5.9 Summary of Golden Bough Technical Evaluation................................................................ 22 2/23/2026 Page 2 of 25
ATTACHMENT 8

6. Conclusion .............................................................................................................................................. 23

7. Appendix - Propagation Parameters ....................................................................................................... 25 2/23/2026 Page 3 of 25
ATTACHMENT 8

1. Executive Summary
This supplemental analysis was prepared in response to the City’s determination that the Golden Bough rooftop may represent a less intrusive alternative to the proposed small wireless facility.

The purpose of this review is not to determine whether measurable signal could be produced from the rooftop, but rather to evaluate whether the Golden Bough location is capable of functioning as a technologically feasible alternative capable of achieving the identified service objectives under realistic deployment conditions.

The original Radio Frequency Report and subsequent supplements established through calibrated drive testing and propagation modeling that a localized service gap exists within this residential coastal area, particularly with respect to reliable in-building performance for mid-band services including AWS (2.1 GHz) and C-Band (3.7 GHz).

Following the hearing, additional technical evaluation was performed, including:
 Application of an uplink-limited maximum allowable path loss (MAPL) threshold of 127 dB to ensure balanced two-way service and conservative in-building performance assessment;
 Comparative AWS path loss modeling of the proposed small cell and the Golden Bough rooftop under identical propagation assumptions;
 Evaluation of antenna configuration constraints associated with rooftop deployment;  Line-of-sight (LOS) profile and free-space propagation analysis toward an unobstructed two-mile northwest path over water; and
 Assessment of electrical downtilt tradeoffs required to control extended signal projection.

The analysis demonstrates that the Golden Bough rooftop cannot simultaneously achieve controlled projection and sufficient uplink margin within the documented service gap area. When configured for reach, the rooftop projects substantial signal energy beyond the intended service area. When adjusted to limit projection through increased downtilt, localized coverage performance is reduced. In addition, rooftop installation constraints necessitate directional antenna configurations inconsistent with the coordinated small-cell deployment architecture established for this area.

Collectively, these findings indicate that while the Golden Bough rooftop may produce modeled signal under certain configurations, it does not represent a technologically feasible alternative for achieving the documented service objectives under consistent engineering criteria.

2. Background and Prior Engineering Record
This supplemental report builds upon the original Radio Frequency Engineering Report and subsequent technical submissions previously provided in support of the proposed small wireless facility.
2/23/2026 Page 4 of 25
ATTACHMENT 8

2.1 Initial Engineering Evaluation
The original RF Engineering Report documented a localized service deficiency within the subject residential coastal area through calibrated drive testing and propagation modeling. The evaluation included:
 Measured RSRP and SINR data collected using industry-standard testing equipment;  Analysis of both low-band and mid-band performance;
 Assessment of in-building service capability based on uplink-constrained design assumptions; and
 Identification of a defined service area requiring densification to support reliable midband service.

The findings demonstrated substandard performance within portions of the neighborhood, particularly with respect to indoor service reliability and mid-band capacity objectives.

The proposed small wireless facility was engineered to operate as part of a coordinated small-cell deployment strategy intended to provide proximity-based coverage and complete the intended node spacing geometry.

2.2 Subsequent Technical Supplements
Following initial review and public proceedings, additional supplemental analyses were prepared to respond to questions raised by the city and members of the public. These submissions addressed, among other topics:
 Clarification of mid-band performance characteristics, including C-Band deployment considerations;
 Technical background and need for the proposed small cell;  Establishing the importance of a dominant signal and a controlled RF design;  Expanded propagation modeling reflecting consistent engineering assumptions;  Clarification regarding the operational status and coverage contribution of previously approved small-cell nodes; and
 Expanded Golden Bough engineering analysis addressing spatial positioning, proximity to the service area, antenna deployment constraints, and observed field conditions to evaluate whether the rooftop can achieve the identified service objectives under consistent engineering assumptions relative to the proposed small cell.

These supplements maintained consistent modeling methodology and applied identical propagation assumptions to ensure objective comparison across candidate locations.

2.3 City Determination and Identification of Alternate Location In its decision, the city determined that the Golden Bough rooftop may represent a less intrusive alternative location capable of addressing the documented service deficiency. 2/23/2026 Page 5 of 25
ATTACHMENT 8

The City’s determination was based primarily on the assumption that signal could be produced from the rooftop location. The engineering question therefore becomes not whether signal can be generated, but whether the Golden Bough rooftop can represent a technologically feasible facility consistent with the established small-cell network design framework.

2.4 Purpose of This Supplemental Evaluation
Following the City’s determination, additional engineering evaluation was conducted to assess the Golden Bough rooftop under realistic deployment conditions. This expanded analysis includes:
 Comparative AWS path loss modeling using an uplink-limited MAPL threshold;  Antenna configuration and rooftop deployment constraint evaluation;  Line-of-sight (LOS) profile and extended propagation assessment;  Electrical downtilt tradeoff analysis; and
 Comparative signal behavior evaluation relative to the proposed small cell.

This report presents the results of that expanded analysis and evaluates the Golden Bough rooftop against established wireless engineering principles governing proximity, link balance, architectural consistency, and operational reliability.

3. Engineering Standard for Evaluating Alternatives
The evaluation of candidate wireless facility locations must be grounded in established radio frequency engineering principles and system-level network design methodology. The objective is not simply to determine whether measurable signal can be produced from a location, but whether that location can reliably achieve the defined service objectives under reasonably expected operating conditions.

Wireless networks are engineered as integrated systems. Accordingly, alternative locations must be assessed based on their ability to function within the intended network architecture and achieve the identified service objectives under consistent engineering criteria.

Sound engineering practice requires that candidate sites be evaluated using consistent modeling assumptions and objective performance criteria, including:
 Proximity to the area requiring service;
 Alignment with the planned small-cell deployment geometry;  Compatibility with the intended antenna configuration and facility type;  Ability to maintain balanced two-way communication under uplink-limited design conditions;
 Availability of sufficient link margin to tolerate normal environmental and operational variability; and
 Deployment conditions that are predictable and operationally controllable over time. 2/23/2026 Page 6 of 25
ATTACHMENT 8

The presence of modeled signal alone does not establish technical viability. Engineering viability is determined by whether a location can deliver reliable, balanced service performance consistent with network design objectives, including in-building service requirements.

Mid-band spectrum deployments, including AWS and C-Band, are particularly sensitive to transmission distance, clutter, and indoor attenuation. As a result, such deployments typically rely on proximity-based small-cell architecture to maintain link balance and predictable performance. Facilities that rely primarily on extended transmission distance or materially different antenna configurations may produce signal; however, they do not necessarily satisfy the deployment and performance criteria governing the coordinated small-cell system.

In evaluating the Golden Bough rooftop, the same propagation models, terrain data, and uplinklimited maximum allowable path loss (MAPL) threshold were applied consistently across all scenarios to ensure objective comparison. The analysis therefore focuses on whether the rooftop can satisfy the above engineering criteria relative to the proposed small cell.

This engineering standard provides the framework through which the Golden Bough rooftop is evaluated in the sections that follow.

4. Small Cell Network Design and Deployment Framework
The proposed facility is part of a coordinated small-cell deployment strategy intended to address a localized service deficiency within a residential coastal environment characterized by varied terrain, closely spaced homes, and mid-band propagation sensitivity.

4.1 Proximity-Based Coverage Design
Mid-band spectrum, including AWS and C-Band, provides higher spectral efficiency and greater user throughput capability than low-band frequencies. While low-band spectrum offers broader coverage reach, it is not well-suited for delivering sustained high data rates or improved signal quality in residential environments.

In the subject area, the service deficiency is characterized not by sector loading or congestion, but by the absence of a dominant serving mid-band layer and suboptimal SINR performance on low-band carriers. Deployment of AWS and C-Band is therefore intended to improve signal dominance, enhance SINR, and increase achievable user throughput, particularly for in-building service.

Proximity-based deployment reduces transmission distance between the antenna and end user, increasing available link margin and improving tolerance for indoor penetration loss, terrain variation, and routine environmental variability.

The proposed facility was engineered to operate within this proximity-based framework. 2/23/2026 Page 7 of 25
ATTACHMENT 8

4.2 Deployment Architecture Selected for the Subject Area Verizon has selected a proximity-based small-cell deployment architecture for this residential coastal area as the appropriate technical method for introducing and densifying mid-band services, including AWS and C-Band.

This architectural approach reflects Verizon’s network design standards for residential environments where:
 Mid-band performance objectives require reduced transmission distance;  In-building service reliability is a defined performance goal; and  Coordinated node spacing is necessary to maintain balanced link conditions.

The proposed facility is engineered as one component of this coordinated small-cell system. Site selection, antenna configuration, and modeled performance were developed within this architectural framework.

Alternative locations must therefore be evaluated not solely on whether signal can be generated, but on whether they can function within the selected small-cell deployment architecture and achieve comparable service performance under the same design principles.

4.3 Coordinated Node Spacing and Network Geometry
Effective small-cell networks are engineered through coordinated node placement such that each facility serves a defined localized coverage area while minimizing excessive overlap and unintended coverage gaps. In mid-band deployments, node placement is derived from link budget constraints, propagation behavior, and the need to position each facility in functional alignment with the area of service demand.

The proposed SF-001 node location aligns with previously approved small-cell facilities to complete the intended coverage geometry within the neighborhood. This coordinated spacing approach:
• Supports continuous localized service;
• Maintains predictable cell dominance;
• Reduces unnecessary long-range projection; and
• Preserves balanced uplink and downlink conditions.

Small-cell placement is highly location-sensitive. Even modest positional shifts can materially alter dominant serving boundaries, uplink margin, and in-building performance. Accordingly, node placement within the service gap area is intentional and derived from propagation modeling and link budget analysis rather than arbitrary siting preference.

Exhibit A, to follow, illustrates the relative positioning of existing, approved, proposed, and alternate facilities in relation to the documented mid-band deficiency gap area. The mid-band 2/23/2026 Page 8 of 25
ATTACHMENT 8

deficiency gap area is defined by the red-dashed polygon. The red-dashed polygon (gap area) was extrapolated by tracing the gap remaining after considering the wireless service contribution from the current on-air and planned facilities based upon the in-building drive test and coverage maps.

As shown in Exhibit A, the proposed SF-001 location occupies a central position within the identified deficiency gap area and maintains geometric alignment with previously approved nodes. The Golden Bough rooftop, while located within the broader neighborhood, is positioned toward the periphery of the deficiency gap area and nearer the edge of existing coverage dominance.

The relevant engineering consideration is whether the alternate location occupies a comparable geometric position within the service gap area sufficient to achieve the identified service objectives. The proposed SF-001 node was engineered to minimize transmission distance to the center of the documented deficiency gap area and to maintain balanced link conditions consistent with proximity-based small-cell architecture.

The Golden Bough rooftop does not occupy the same functional geometric position within the service gap area and would therefore operate under materially different transmission dynamics than the proposed node. Please refer to Exhibit A below for a graphical representation:
2/23/2026 Page 9 of 25
ATTACHMENT 8

EXHIBIT A - SMALL CELL GEOMETRY
2/23/2026 Page 10 of 25
ATTACHMENT 8

4.4 Balanced Two-Way Service and Uplink-Limited Design
Wireless networks operate as two-way communication systems. While downlink signal strength is often visually represented in propagation maps, system performance is typically constrained by the uplink due to the limited transmit power of user devices.

Accordingly, small-cell deployment for mid-band services is commonly designed using uplinklimited maximum allowable path (MAPL) loss thresholds to ensure balanced link conditions and consistent indoor performance.

The proposed facility was modeled using an uplink-limited MAPL of 127 dB, representing a conservative design condition intended to support reliable two-way communication, including in-building service.

This balanced-link design framework governs both node spacing and facility placement within the area of need.

4.5 Spatial Containment and Residential Deployment Objectives In residential environments, small-cell installations are engineered to provide controlled, localized coverage rather than extended signal projection. Spatial containment is an important operational objective, as it:
 Limits unintended signal dominance beyond the intended service area;  Reduces unnecessary handoff activity;
 Minimizes inter-cell overlap; and
 Supports predictable network behavior.

The proposed facility reflects these deployment objectives and is configured to provide localized mid-band service consistent with coordinated small-cell architecture.

4.6 Application to the Subject Area
The small-cell deployment plan for this neighborhood reflects:
 The documented service deficiency;
 The mid-band performance objectives of AWS and C-Band;  The need for in-building reliability; and
 The geometric relationship between existing and approved facilities.

The proposed node location is therefore not arbitrary but is derived from link budget constraints, propagation behavior, and the need to complete the intended spacing geometry within the service gap area.
2/23/2026 Page 11 of 25
ATTACHMENT 8

The sections that follow evaluate whether the Golden Bough rooftop can satisfy these same deployment and performance criteria.

5. Golden Bough Rooftop – Technical Evaluation

5.1 Evaluation Framework
Consistent with established radio frequency engineering practice, alternative wireless facility locations must be evaluated based on their ability to:
• Provide proximity-based coverage within the area requiring service; • Operate within the intended small-cell network architecture; • Maintain balanced two-way communication under uplink-limited design conditions; • Provide sufficient link margin to tolerate normal environmental variability; and • Function predictably under existing, controllable deployment conditions.

The following analysis evaluates the Golden Bough rooftop against these criteria.

5.2 Spatial Positioning Relative to the Service Gap
As illustrated in Exhibit A, the proposed SF-001 small cell occupies a central position within the documented mid-band deficiency gap area and aligns with the coordinated small-cell geometry established by previously approved nodes.

The Golden Bough rooftop, by contrast, is positioned toward the periphery of the deficiency gap area and nearer the edge of existing coverage dominance. Because it does not occupy the same geometric relationship to the service gap area, it would necessarily rely on greater transmission distance to reach portions of the documented gap.

Wireless performance is directly influenced by transmission distance. As separation between the antenna and end user increases, path loss increases and available link margin decreases. Facilities positioned outside the service gap area therefore operate with reduced tolerance for indoor attenuation, terrain variation, and normal environmental variability.

The question is not whether measurable signal can be generated from the rooftop, but whether it can provide the same proximity-based service performance as the proposed node under realistic operating conditions.

5.3 Rooftop Physical Constraints and Configuration Considerations The Golden Bough rooftop presents physical and geometric constraints that preclude deployment of a true omnidirectional small-cell configuration. The sloped roof geometry, ridgeline obstruction, and mounting limitations restrict the ability to achieve uniform 360-degree radiation without pattern shadowing and structural interference. Furthermore, due to the Golden Bough’s 2/23/2026 Page 12 of 25
ATTACHMENT 8

location projecting coverage in the north, east, or south directions would conflict with coverage from the existing on-air facilities.

Accordingly, a sectorized rooftop configuration was modeled to approximate the gain and tilt characteristics of the proposed omnidirectional small-cell design while limiting radiation to feasible southwest and northwest sectors. This configuration represents the most favorable practicable approximation of small-cell performance achievable at the rooftop location.

The uplink-limited comparative modeling of this omni-equivalent configuration is presented in Section 5.5.

5.4 Interpretation of Uplink-Limited Path Loss Maps
The comparative modeling exhibits presented in this report utilize an uplink-limited maximum allowable path loss (MAPL) threshold of 127 dB. Path loss represents the total signal attenuation between the base station and user device. Areas where modeled path loss exceeds 127 dB indicate insufficient uplink margin to reliably sustain communication under the applied design criteria.

The color scale applied in the exhibits reflects relative uplink margin with respect to the 127 dB threshold:
 Areas depicted with positive margin values represent locations where modeled path loss remains below the threshold and sufficient link margin is maintained.  Areas depicted near 0 dB margin indicate minimal tolerance for additional attenuation, such as indoor penetration or terrain variability.
 Areas depicted with negative margin values represent locations where modeled path loss exceeds the allowable threshold and reliable uplink performance is not supported under the applied design assumptions.

All comparative exhibits utilize identical propagation parameters, clutter assumptions, antenna heights, and MAPL thresholds to ensure consistency and direct comparability between configurations.

5.5 Uplink-Limited Comparative Path Loss (Omni-Equivalent Evaluation) To evaluate technological feasibility under balanced two-way communication conditions, a conservative uplink-limited maximum allowable path loss (MAPL) threshold of 127 dB was applied uniformly across all modeling scenarios.

MAPL represents the maximum allowable signal attenuation between the base station and user device while maintaining reliable communication. The 127 dB threshold reflects an uplinkconstrained design condition and incorporates appropriate margin to support in-building service objectives.
2/23/2026 Page 13 of 25
ATTACHMENT 8

Exhibit B presents a side-by-side comparison of AWS path loss modeling for:
 The proposed SF-001 omnidirectional small-cell configuration; and  The Golden Bough rooftop modeled using an omni-equivalent sectorized configuration.

Identical terrain, clutter, antenna height, and MAPL assumptions were applied in both scenarios.

Under these consistent modeling conditions, the proposed small cell maintains positive uplink margin throughout the deficiency gap area. By contrast, the Golden Bough rooftop configuration exhibits predominantly sub-threshold performance (≤ 0 dB margin) across substantial portions of the documented deficiency gap area.

Areas operating at or below the MAPL threshold do not maintain usable uplink margin and therefore lack tolerance for indoor attenuation, terrain variability, and normal environmental fluctuation. As a result, the Golden Bough configuration does not sustain balanced two-way communication conditions within the deficiency gap area under uplink-limited evaluation.

The relevant engineering question is not whether isolated signal presence can be produced, but whether sufficient positive link margin is maintained to support predictable in-building performance. Based on the modeling reflected in Exhibit B, the Golden Bough rooftop does not maintain sufficient uplink margin to achieve the identified service objectives within the documented service gap area.

Comparable modeling under C-Band using identical assumptions demonstrates consistent relative behavior; therefore, redundant frequency-specific exhibits are not included. 2/23/2026 Page 14 of 25
ATTACHMENT 8

2/23/2026 Page 15 of 25
EXHIBIT B - PATH LOSS COMPARISON SF-001 VS GOLDEN BOUGH OMNI-EQUIVALENT

ATTACHMENT
8

5.6 Long-Range Projection Characteristics – Golden Bough Rooftop When modeled using a sectorized rooftop configuration with low electrical downtilt (0–2 degrees), the Golden Bough location exhibits extended line-of-sight propagation toward the northwest over open water.

Open-water paths introduce minimal clutter attenuation and therefore allow signals to propagate efficiently over extended distances.

Under low-downtilt conditions, modeled signal strength persists well beyond the intended residential service area.

Extended projection of this nature is inconsistent with proximity-based small-cell design, which is intended to localize coverage within the immediate service gap area. Excessive projection increases the potential for:
• Unintended service area expansion;
• Overlapping coverage with distant cells; and
• Reduced control over dominant serving boundaries.

To limit long-range projection and concentrate coverage within the intended residential area, increased electrical downtilt is required.

Exhibit C presents a line-of-sight profile comparison of the Golden Bough rooftop under 2° and 8° electrical downtilt configurations, illustrating the corresponding change in propagation geometry.

Under a 2° electrical downtilt configuration, the antenna’s upper radiation lobe projects outward at a shallow angle. In the northwest direction, there are no terrain obstructions and the signal travels over open water, where there is very little natural attenuation. As a result, free-space calculations incorporating antenna gain show that the signal level remains approximately –76 dBm at a distance of two miles from the rooftop.

A signal at –76 dBm is strong enough to influence device selection and serving boundaries well beyond the intended residential service area. In practical terms, this means the rooftop would project energy far outside the localized service gap it is intended to address.

When electrical downtilt is increased to 8°, the signal at that same two-mile location drops to approximately –94 dBm; an 18 dB reduction. An 18 dB decrease represents more than a sixtyfold reduction in received signal power. While this higher downtilt improves containment of the signal and reduces extended projection, it does not uniformly improve localized coverage within the service gap area.

In this specific terrain environment, the Golden Bough rooftop is elevated relative to portions of the service area but not centrally positioned within it. Increasing downtilt redirects energy downward; however, due to the rooftop’s position near the edge of the service gap and the downward terrain profile toward the water, portions of the service area fall outside the strongest portion of the vertical radiation pattern. This results in uneven margin and localized areas where uplink-limited performance remains constrained despite increased downtilt.

Accordingly, the Golden Bough rooftop presents a configuration tradeoff: lower downtilt produces excessive projection beyond the intended area, while higher downtilt improves containment but does not produce continuous positive margin throughout the documented service gap under the applied design criteria. 2/23/2026 Page 16 of 25
ATTACHMENT 8

Golden Bough Rooftop – Sectorized Configuration
(8º Electrical Downtilt)
Unobstructed LOS
over water (~ 2 miles)
Minimal clutter attenuation over
open water
Golden Bough Rooftop –
Sectorized Configuration (2º
Electrical Downtilt)
2º Electrical
Downtilt Receive
Point
8º Electrical
Downtilt Receive
Point
Golden Bough Rooftop –
Sectorized Configuration (8º
Electrical Downtilt)
Golden Bough Rooftop (2º Downtilt Configuration)Unobstructed Over-Water Propagation Path (~ 2 Miles) Golden Bough Rooftop (8º Downtilt Configuration)Reduced Long-Range Projection; Localized Ground Intercept Exhibit C – Line-of-Sight Profile – Golden Bough Rooftop – Electrical Downtilt Sensitivity (2º vs. 8º)

ATTACHMENT
8

5.7 Antenna Downtilt Sensitivity – Uplink-Limited Performance Impact To quantify the service impact of downtilt selection, additional uplink-limited path loss modeling was performed for the Golden Bough rooftop under two electrical downtilt conditions: 2° and 8°, using identical MAPL (127 dB) assumptions and propagation parameters.

Under 2° electrical downtilt, extended propagation persists toward the northwest, consistent with the geometric behavior described in Section 5.6. While measurable signal is present within portions of the service area, the configuration does not maintain positive uplink margin within the central portion of the documented deficiency service gap area.

Specifically, the area where drive testing previously measured degraded SINR values corresponds to modeled path loss exceeding the 127 dB uplink-limited threshold, resulting in <0 dB margin. In such conditions, the Golden Bough configuration would not be expected to establish a dominant serving signal within that portion of the service gap area.

Under 8° electrical downtilt, long-range projection toward the northwest is reduced, and modeled signal containment improves relative to the 2° configuration. However, uplink-limited modeling indicates that margin within portions of the central deficiency service gap area remains constrained.

Specifically, while certain areas previously modeled below threshold under the 2° configuration improve slightly, the resulting uplink margin within much of the service gap area is limited to approximately 0 to <5 dB. Margin within this range provides minimal tolerance for indoor attenuation, terrain variability, or routine environmental fluctuation and may not establish a consistently dominant serving condition.

In addition, modeling along portions south of 11th Avenue up to the southern edge of the deficiency area indicates path loss exceeding the 127 dB threshold, resulting in negative uplink margin in those locations. Such conditions suggest that even with increased downtilt, the Golden Bough rooftop configuration does not provide continuous positive margin throughout the intended service gap area and may require additional network densification to address remaining sub-threshold areas.

Exhibits D and E present the comparative uplink-limited path loss results for the Golden Bough rooftop under 2° and 8° electrical downtilt configurations.

In addition to the modeled geometric and uplink-margin limitations, field inspection confirms the presence of mature vegetation located within close proximity to the potential antenna mounting area in the southwestern direction on the Golden Bough rooftop. The propagation modeling performed herein utilized standard clutter assumptions and did not incorporate discrete nearfield foliage obstruction at the antenna aperture.

Close-in vegetation within the primary radiation path can introduce additional attenuation, multipath variability, and time-varying signal fluctuation that are not fully captured in 2/23/2026 Page 18 of 25
ATTACHMENT 8

generalized propagation modeling. Even with selective tree trimming, residual foliage and seasonal regrowth may materially affect signal stability in the immediate service direction.

Accordingly, real-world performance from the Golden Bough rooftop would reasonably be expected to be more variable than reflected in the idealized modeling results presented above.

The modeling demonstrates that tilt adjustment at the Golden Bough location produces a performance tradeoff: lower tilt results in extended projection, while higher tilt reduces projection but does not simultaneously achieve controlled projection and continuous positive uplink margin across the documented service gap area.
2/23/2026 Page 19 of 25
ATTACHMENT 8

ATTACHMENT 8

ATTACHMENT 8

5.8 Comparative Configuration Summary
The following table summarizes the comparative modeling results under identical uplink-limited MAPL (127 dB) assumptions and consistent propagation parameters.

Evaluation
Criterion
Proposed Small
Cell (SF-001)
Golden Bough –
OmniEquivalent
Golden Bough –
2° Electrical
Downtilt
Golden Bough –
8° Electrical
Downtilt
Located within
documented
service gap area
Yes No No No
Proximity-based
coverage
geometry
Yes No No No
Maintains
positive uplink
margin across
service gap area
Yes No No
No (service gap
area margin
limited to 0–<5
dB in central
zone)
Central
deficiency area
margin
Positive
<0 dB (majority
of service gap
area)
<0 dB 0–<5 dB
Southern / 11th
Ave margin Positive <0 dB 0–<5 dB <0 dB
Long-range
projection
behavior
Localized Limited
coverage
Extended Reduced
Sensitivity to
downtilt
adjustment
Low N/A High High
Near-field
vegetation
influence
Minimal Present Present Present
Indicates need
for additional
densification
No Yes Yes Yes

5.9 Summary of Golden Bough Technical Evaluation
The expanded modeling and field evaluation demonstrate that the Golden Bough rooftop is constrained by geometric separation, configuration sensitivity, and physical site conditions that materially limit its ability to achieve the identified service objectives.

The rooftop is positioned outside the documented service gap area and therefore must rely on transmission distance rather than proximity-based coverage to serve the central service gap area. 2/23/2026 Page 22 of 25
ATTACHMENT 8

Under an omni-equivalent configuration evaluated using a conservative uplink-limited MAPL threshold of 127 dB, modeling indicates that positive uplink margin is not maintained throughout the central deficiency area.

When configured with low electrical downtilt (2°), the rooftop produces extended line-of-sight projection over open water while still failing to establish consistent positive margin within the central portion of the documented service gap. Increasing electrical downtilt (8°) reduces longrange projection; however, uplink margin within the service gap area becomes constrained to minimal levels (approximately 0 to <5 dB), and certain portions of the southern and eastern service area remain below threshold.

The modeling therefore reflects a configuration sensitivity in which reduced projection and adequate margin cannot be simultaneously achieved from the Golden Bough location under consistent uplink-limited design assumptions.

By contrast, the proposed SF-001 small-cell configuration is positioned within the service gap area and maintains positive uplink margin throughout the documented deficiency area without reliance on extended projection or aggressive downtilt adjustment.

Based on uniform modeling assumptions and consistent application of uplink-limited performance criteria, the engineering record does not support the Golden Bough rooftop as a technologically feasible alternative for achieving the documented service objectives within the identified deficiency area.

6. Conclusion
This supplemental evaluation applied uniform uplink-limited modeling criteria (127 dB MAPL), consistent propagation assumptions, and documented field conditions to assess whether the Golden Bough rooftop represents a technologically feasible alternative.

Under all evaluated configurations—including omni-equivalent, 2° electrical downtilt, and 8° electrical downtilt—the Golden Bough location does not maintain continuous positive uplink margin across the documented service gap area. Low-downtilt configurations result in extended projection beyond the intended residential area while failing to remediate the central deficiency zone. Increased downtilt reduces projection but constrains uplink margin within the service gap area and leaves portions of the southern service area below threshold.

The modeling further reflects configuration sensitivity and geometric limitations inherent to the rooftop’s position outside the service gap area. These constraints are not attributable to tunable parameters but to spatial separation and physical site conditions, including near-field vegetation.

By contrast, the proposed SF-001 small-cell facility is positioned within the documented service gap area and maintains positive uplink margin under the same modeling assumptions without reliance on extended projection or aggressive downtilt adjustment. 2/23/2026 Page 23 of 25
ATTACHMENT 8

Based on consistent engineering criteria and comparative analysis, the Golden Bough rooftop does not represent a technologically feasible alternative for achieving the identified service objectives to the identified deficiency area. The proposed SF-001 small-cell configuration remains the technically appropriate solution supported by the engineering record.

Report Prepared by:

Rich Conroy, President Ron Lukach
Senior RF Engineer Senior RF Engineer
February 23, 2026 February 23, 2026
2/23/2026 Page 24 of 25
ATTACHMENT 8

7. Appendix - Propagation Parameters
Carmel 127 dB Pathloss Model Parameters
Site SF S Carmel
001
Golden Bough Golden Bough Golden Bough
Latitude 36.549322 36.551884 36.551884 36.551884
Longitude -121.926922 -121.924606 -121.924606 -121.924606 Site AMSL
(ft)

82.3 156.9 156.9 156.9
AGL CL (ft) 47 34 34 34
Antenna
Model
Omni_10DT CUUT070X06Fxyz NHHSS-65C-HGTR3B_02DT NHHSS-65C-HGTR3B_08DT Antenna
Type
Omni Clover Directional Directional
E Downtilt
(degrees)
10 10 2 8
Azimuth
(degrees)
360 220
340
220
300
220
300
Gain (dBi) 8 14 19.4 19.4
HBW (deg) 360 77 62 62
VBW (deg) 20 15 4.7 4.7
Dimensions 29.8" H x 14.6"
D
24" H x 14.6" D 96"H x 11.9" W x 7.1" D 96"H x 11.9" W x 7.1" D Clutter 1 sec 2021 USGS tuned to drive test data
Terrain 2016 30m
Frequency
(MHz)
2100
Model COST-231 Hata
ERP (dBm) 51.3 51.3 59.8 59.8
2/23/2026 Page 25 of 25
ATTACHMENT 8

DR 25313 & UP 25314 (Verizon Sequoia Deployment) Carmel Planning Commission Verizon Wireless Responses Volume 3
February 24, 2026
1 Verizon Wireless’s Responses Volume 3
Topic Page

1. Design Continued 1

2. Alternatives Continued 1

1. DESIGN CONTINUED
We were asked about impacts to the adjacent oak tree.

Verizon Wireless, the City, and a PG&E arborist met at the site on February 4, 2026, to determine what impacts, if any, would impact the adjacent tree. PG&E’s arborist determined that due to the site’s distance from the tree, it would not impact the root system. Furthermore, the replacement pole will be placed in the same hole as the existing pole, so there will be no additional impacts to the roots.

2. ALTERNATIVES CONTINUED
The Commission and project opponents inquired about the feasibility of a wireless facility at the Golden Bough.

Technical Infeasibility
As Verizon Wireless has maintained for the duration of this application, the Golden Bough is not technically feasible and available alternative. To further explain why a rooftop wireless facility on the Golden Bough is not technically feasible PierCon Solutions prepared a new report, Radio Frequency Supplemental Report # 4, dated February 23, 2026. The report summarized the additional technical evaluations PierCon Solutions performed and concludes that the Golden Bough “does not represent a technologically feasible alternative for achieving the documented service objectives under consistent engineering criteria.” Report at p. 4. PierCon included an appendix to the report that includes the parameters of their analysis so that it can be duplicated and analyzed by the City’s expert consultant, CTC. Report at p. 25.

Practical Infeasibility
Sequoia Deployment Services met with the Golden Bough on February 4, 2026, to evaluate the property to investigate the feasibility of locating a wireless telecommunications facility on the property that would meet Verizon Wireless’s needs. The site design concept was to build a site with one equipment cabinet, four remote radio units, four panel antennas, generator receptacle or lug box, electrical power fiber connections, and associated cabling. The antennas and rooftop equipment would be screened with a faux chimney.

The building is approximately 165 feet east to west with a hip roof running in the east-west direction. The east and west ends are a full story lower than the main roof, necessitating that the antennas go on the upper roof.

The south portion of the roof is occupied by a large solar array. The east end of the building is shorter than the west end since the property slopes down approximately 22 feet east to west. The main floor at the east end is below street level while the basement level at the west end is above street level.

ATTACHMENT 9

DR 25313 & UP 25314 (Verizon Sequoia Deployment) Carmel Planning Commission Verizon Wireless Responses Volume 3
February 24, 2026
2 The exterior of the property is entirely accessible to the public. The roof is only accessible with ladders and climbing equipment. PreVisualists, Inc. flew a drone with a camera to confirm roof conditions and potential surroundings from potential antenna locations. The coverage objective for the site is located west and southwest of the Golden Bough property, which requires antennas with views in those directions without immediate obstructions.

Verizon Wireless discussed height restrictions with the Planning Department prior to the visit, and they noted a ten-foot height limit above the top of the roof. This restriction limits antenna placement to the highest point of the roof near the west end for two reasons.

First, if the antennas were placed easterly on the building, the roof would interfere with the antennas oriented west. This location would diminish the effectiveness of this sector. Moving east also requires that any southwest or south oriented sector would be low compared to the level of the roof resulting in interference from the large solar array.

The second issue with placement off the west end of the roof is structural and equipment conflict. The west end of the roof is situated over a wall that extends backstage to the ground. This wall would support any loads through the building to the ground. This location is also accessible with cabling from below at the very back of the theater which already has utilities routed in this area and would not interfere with theater operations. The ATTACHMENT 9

DR 25313 & UP 25314 (Verizon Sequoia Deployment) Carmel Planning Commission Verizon Wireless Responses Volume 3
February 24, 2026
3 rest of the upper roof is an approximately 55-foot unsupported span north to south over the theater and stage area which already supports considerable stage equipment and the ceiling inside the building. This area is intensely used with cables, supports, HVAC ducting and a central catwalk running most of the upper attic space. It would be difficult to route cabling from equipment below to this central part of the roof without interfering with the theater equipment.

Since that site visit, Golden Bough has requested that the antennas be placed at the north edge of the building.

To accommodate this request, Verizon Wireless would have to install a much taller antenna structure. The structure would need to be 18 feet tall above the roof to maintain the same antenna elevation, where the height limit is ten feet above the roof. However, antennas at that location would likely have to be even taller.

Under either design, a ground cabinet is required to house fiber equipment. Due to the configuration of the available space and its uses inside the building, the best place to locate the cabinet is outside. The cabinet would be attached to the south wall of the building above where a trash dumpster is located.

While a wireless facility may be technically constructable at Golden Bough, it would not meet the Verizon Wireless’s needs. Furthermore, in addition to requesting that the wireless facility be located at the north edge of the roof, the Golden Bough has also expressed a desire to expand its solar panel array. In addition to occupying roof space, solar panel arrays cause interference with wireless signals (passive intermodulation), causing network disruption. Finally, it is not clear that Golden Bough would even lease its property to Verizon Wireless. It has expressed concerns over interference and impacts to their operations.

Increased Costs
In terms of costs, construction of a wireless facility on the Golden Bough roof, even if it were possible, would run at least three to four times as the proposed facility. Because the Golden Bough is not a technically feasible alternative for Verizon Wireless, it has not negotiated a lease with the theater. However, private property rent is generally orders of magnitude greater than the rent associated with a Joint Pole Association pole.

Furthermore, maintenance costs associated with a rooftop facility tend to be higher as well. The Golden Bough has also indicated that they may potentially request accommodations associated with their audio and visual equipment, which would further drive up the costs.

Historic Resource Impacts
The proposed pole is adjacent to a home designated as a Criteria 3 historic resource on the City’s Inventory of Historic Resources.
1 However, the pole itself is located within the public right-of-way. Due to its relatively small physical presence, the proposed wireless facility would have minimal visual impact on the adjacent home. The pole itself is not a protected historic resource.

The proposed alternative structure, Golden Bough, is designated as a Criteria 1 historic resource on the City’s Inventory of Historic Resources, which is a more protected designation than Criteria 3. A wireless facility proposed on the Golden Bough would require a Section 106 review, including completion and submission of Department of Parks and Recreation (“DPR”) forms to the California State Historic Preservation Office (“SHPO”). The Golden Bough is historic, in contrast to the pole in the public right-of-way. Based on the 1 Available at: https://ci.carmel.ca.us/sites/main/files/carmel_inventory_of_historic_resources_v11.2024.pdf ATTACHMENT 9

DR 25313 & UP 25314 (Verizon Sequoia Deployment) Carmel Planning Commission Verizon Wireless Responses Volume 3
February 24, 2026
4 structure types and the footprint associated with each option, the proposed stealth antenna on the pole would have less impact on historic resources in the area than a rooftop wireless facility on the Golden Bough.

ATTACHMENT 9

Please find linked here the Staff Report from the February 10, 2026 Planning Commission Meeting for DR 25313 & UP 25314 (Verizon Sequoia Deployment). 2/10/2026 Staff Report attachments

1. Attachment 1 – Resolution Approval

2. Attachment 2 – Resolution Denial

3. Attachment 3 – Project Plans

4. Attachment 4 – CTC Report

5. Attachment 5 – PierCon Supplemental Report 2

6. Attachment 6 – VzW Response Volume 1

7. Attachment 7 – VzW Response Volume 2

8. Attachment 8 – Strauss Letter

9. Attachment 9 – Previous Report and Reference Materials ATTACHMENT 10

Please find linked here the Staff Report from the January 21, 2026 Planning Commission Meeting for DR 25313 & UP 25314 (Verizon Sequoia Deployment). 1/21/26 Staff Report attachments

1. Attachment 1 - Resolution

2. Attachment 2 - Project Plans

3. Attachment 3 - Photo Sims

4. Attachment 4 - RF Compliance Report

5. Attachment 5 - Acoustic Analysis

6. Attachment 6 - Structural Analysis

7. Attachment 7 - PierCon Report

8. Attachment 8 - Technically Feasible and Available Alternatives Analysis

9. Attachment 9 - Special Exception Letters

10. Attachment 10 - CTC Report

11. Attachment 11 - Resident Correspondence
Reference Materials
Wireless Design Guidelines
Carmel Municipal Code Section 17.46
Wireless Application Checklist
ATTACHMENT 10

Jacob Olander <[email protected]>
Fwd: Confirmation of Interest – Verizon Installation at Golden Bough Playhouse Brandon Swanson <[email protected]> Wed, Feb 25, 2026 at 4:16 PM To: Anna Ginette <[email protected]>, Jacob Olander <[email protected]>, Gail Karish <[email protected]>, "Pierik, Brian A." <[email protected]>
Here ya go...

Take care,
-Brandon
Brandon Swanson [he, him, his]
Acting City Administrator
City of Carmel-by-the-Sea
(831) 620-2024
---------- Forwarded message ---------
From: STEPHEN MOORER <[email protected]>
Date: Wed, Feb 25, 2026 at 2:22 PM
Subject: Confirmation of Interest – Verizon Installation at Golden Bough Playhouse To: Brandon Swanson <[email protected]>
External Sender - From: (STEPHEN MOORER <[email protected]>) This message came from outside your organization.

Hi Brandon,
This email is to confirm Pacific Repertory Theatre’s interest in having a Verizon telecommunications installation placed on the roof of the Golden Bough Playhouse, subject to mutually agreeable lease terms.

We look forward to continuing the conversation, when appropriate.

Best,
Stephen Moorer
2/26/26, 12:19 PM Carmel-by-the-Sea Mail - Fwd: Confirmation of Interest – Verizon Installation at Golden Bough Playhouse https://mail.google.com/mail/u/0/?ik=9618bd4ac3&view=pt&search=all&permmsgid=msg-f:1858144827739771266&simpl=msg-f:1858144827739771266 1/2 ATTACHMENT 11

Executive Director
Pacific Repertory Theatre
Sent from 9 to 5 ~ what a way to make a living!
2/26/26, 12:19 PM Carmel-by-the-Sea Mail - Fwd: Confirmation of Interest – Verizon Installation at Golden Bough Playhouse https://mail.google.com/mail/u/0/?ik=9618bd4ac3&view=pt&search=all&permmsgid=msg-f:1858144827739771266&simpl=msg-f:1858144827739771266 2/2 ATTACHMENT 11