APP 26046 (Sequoia Deployment Services,
Inc./Verizon Wireless)
City Council Special Meeting
March 2, 2026
CITY OF CARMEL-BY-THE-SEA
CITY OF CARMEL-BY-THE-SEA 1
Existing PG&E Utility Pole 2
Background/Project Description
• First Application Since
2023 Wireless
Ordinance Adoption
• In Right-of-Way
Fronting Carmelo
Street 4 Southeast of
10th Avenue
• Existing PG&E Utility
Pole Top is 38’-11”
• Type III - Wireless
Facility on a
Replacement Pole in
the Right-of-Way
Looking North Looking South Looking East
Existing PG&E Utility Pole 3
Background/Project Description
• Replacement PG&E
Utility Pole Top is 46’-
4”
• Top of Proposed
Antenna is 49’-10”
• PG&E Utility Pole
Replaced in the Same
Location
• 2.89 Cubic Foot
Antenna
• 16.48 Cubic Feet of
Pole Mounted
Equipment Looking North Looking South Looking East
CITY OF CARMEL-BY-THE-SEA 4
Meeting Timeline
• January 21, 2026 – Planning Commission public hearing continued to February 4, 2026 • February 4, 2026 – Planning Commission public hearing continued to February 10, 2026 • Review of materials submitted by residents, their legal representatives, and applicant
• Obtained supplemental technical analysis from CTC
• February 10, 2026 – Planning Commission denial. Project did not meet required findings for special exceptions to CMC Chapter 17.46
• March 2, 2026 – Staff recommends City Council deny the application because required findings cannot be made
• March 5, 2026 – Shot clock expires unless mutual agreement to extend 5 Grounds for Appeal – Claim 1
Claim 1 – Denial Violates Federal Law: PC Findings Lacked Substantial Evidence • Findings for denial were not supported by substantial evidence • Verizon demonstrated that Golden Bough is not feasible • City did not provide substantial evidence for findings for denial 6 Grounds for Appeal Response 1
• Verizon submitted additional evidence after filing the appeal • City Council must consider all the evidence in making its decision on the appeal and the application
• Staff recommends City Council denial because findings for denial are supported by substantial evidence
• Verizon’s claim that it demonstrated that Golden Bough is not feasible is discussed in response to Claim 3
• Verizon’s claim that City did not provide substantial evidence for findings for denial for other requirements is discussed in response to Claim 5 7 Grounds for Appeal – Claim 2
Claim 2 – Denial Violates Federal Law: City Cannot Dictate Technology • City cannot require Verizon to use macro design at Golden Bough Theater • Verizon showed small wireless design does not work at Golden Bough Theater 8 Grounds for Appeal Response 2
Claim Response 2:
• The City is not dictating technology
• Verizon has the burden of proof for its request for special exceptions • One of Verizon’s claims is that denial of the application would violate federal law because it has a significant gap in its service and the proposed facility is the least intrusive means to fill the gap (discussed in Claim 3) • Verizon is required to do a comprehensive alternatives analysis and evaluate any potentially technically feasible and available alternatives raised by the city. These often include other types of sites and technologies • In response to public and Commission comment, Verizon chose to analyze the macro design at Golden Bough Theater
9 Grounds for Appeal – Claim 3
Claim 3 – Denial Violates Federal Law: Effective Prohibition and Materially Inhibits • Denial would be an effective prohibition under both Ninth Circuit tests:
• Verizon has a significant gap in service and its proposed facility is the least intrusive means to address gap.
• Golden Bough alternative is not technically feasible or least intrusive and may not be available
• Denial would materially inhibit Verizon’s ability to “introduce new 5G services, improve existing service, and densify the network”
10 Grounds for Appeal Response 3
• Significant gap:
• Verizon’s technical consultants performed drive tests and other modeling that purported to demonstrate a gap in service affecting a significant portion of Carmel
• CTC’s analysis and modelling confirmed the existence of a gap • Least intrusive means:
• Verizon’s technical consultants admitted Golden Bough site is constructible but provided several reports to try demonstrate that it is not technically feasible • CTC’s analysis disputes this; a macro rooftop facility is technically feasible 11 Grounds for Appeal Response 3
Measured
Significant Gaps in
Golden Bough Area
Slate Dot – SINR <= 5dB
Poor Throughput
Black Dot – SINR <0dB Very
Poor Connection
12 Grounds for Appeal Response 3
Golden Bough Playhouse
Monte Verde Street between 8th & 9th Avenues
13 Grounds for Appeal Response 3
Computer Modeled
Downlink Coverage
• CTC modelling
using applicant’s
suggested macro
technology shows
the Golden Bough
is a technically
viable alternative
• Tree trimming can
address signal
attenuation to
extent needed
2150 MHz Band Coverage Model 3700 MHz Band Coverage Model 14 Grounds for Appeal Response 3
Least Intrusive Means
• Golden Bough is available
• Golden Bough representative confirmed interest in a lease • Golden Bough is less intrusive than proposed facility • Location aligns much better with values in Carmel wireless regulations • Requires 1 exception (height)
• Could meet historic review requirements with good design Claim Response 3:
15 Grounds for Appeal Response 3
• Applicant must show denial would materially inhibit its ability to compete in a fair and balanced regulatory environment considering the totality of circumstances
• Courts consider factors like insufficient coverage, lack of available alternatives, unreasonable costs and unreasonable delay
• An additional facility would improve service capabilities • Golden Bough is available and renting or placing facility on parcel is not unusual or an economic hardship
• FCC shot clock is 90 days for colocation on Golden Bough Materially Inhibits
16 Grounds for Appeal – Claim 4
Claim 4 – Denial Violates State Law: Statewide Franchise Right • California Public Utilities Code Section 7901 grants telephone companies statewide franchise to place their equipment in the public right-of-way. • Listing R-1 zone rights of way as highly incompatible violates franchise rights. • Denial based on preference for private property violates franchise rights. 17 Grounds for Appeal Response 4
Claim Response 4:
• PUC Sec 7901 state franchise is limited
• Franchise facilities cannot “incommode” the public use, which includes not just public use for travel but also safety and aesthetics • City requirement for heightened aesthetic review in particular areas is consistent with City’s authority under state law
• Franchise is also limited grant to the extent necessary for providing service • Right of way use is not necessary to provide wireless service here as a viable site for providing service exists on non-ROW property 18 Grounds for Appeal – Claim 5
Claim 5 – Proposed Project is Consistent With Findings
• Project is consistent with General Plan
• Project will not set precedent for future applications • Safety concerns over fall zone are unfounded
• Tree will not be harmed. Regulation not applicable to replacement poles • Project will not affect adjacent historic resource
• Visual impact and scenic disruption concerns are vague and lack evidence 19 Grounds for Appeal Response 5
Claim Response 5:
• General Plan
• Accessory equipment volume in Administrative Detailed Wireless Design Guidelines not met
• Design Guidelines are part of the General Plan
• Future Application Precedent
• Findings cannot be made, so approval would set precedent • Fall Zone
• Fall zone finding is not applicable
• Safety findings can be made
20 Grounds for Appeal Response 5 (Cont.)
Claim Response 5:
• Trees
• Tree requirements apply to new poles (not replacement poles) • Safety findings can be made
• Visual Impacts
• Project does not comply with Zoning Standards and Design Guidelines • Finding that project will have no visual impact cannot be made • Historic Resource
• No Secretary of the Interior Standards for Small Wireless Facilities in the Right-of-Way • PG&E pole replacement/equipment not uncommon in front of Historic Resources 21 Findings Analysis
Use Permit.
Based on the evidence contained in the record, approval of the project would conflict with the General Plan, not comply with zoning standards, not compatible with surrounding land uses. The project does not meet the design guidelines and approval of the special exceptions cannot be supported resulting in conflict with the requirements of a wireless facility.
Design Review.
Based on the evidence contained in the record, approval of the project would conflict with the General Plan, Local Coastal Program, CMC, design guidelines and neighborhood character, and exceptions to zoning standards. The project does not meet the design guidelines and approval of the special exceptions cannot be supported resulting in conflict with the requirements of a wireless facility.
Coastal Development Permit.
Based on the evidence contained in the record, approval of the project would conflict with the General Plan, not comply with the Local Coastal Program. The project does not meet the design guidelines and approval of the special exceptions cannot be supported resulting in conflict with the requirements of a wireless facility. 22 Findings Analysis
Wireless Type I-IV.
Based on the evidence contained in the record, approval of the project would conflict with the General Plan, not comply with zoning standards and findings for approval of a Use Permit, Design Review, and Coastal Development Permit cannot be made in this case. The project does not meet the design guidelines and approval of the special exceptions cannot be supported resulting in conflict with the requirements of a wireless facility.
Special Exception Findings.
The applicant has requested two special exceptions:
• CMC Section 17.46.040.E.1.a - placement within the single-family residential zoning district which is designated as a highly incompatible location in the public right-of-way
• CMC Section 17.46.040.E.2.a – placement in the public right of way directly in front of the areas which are five feet in either direction from the centerline of each entry door or window in the front façade of any occupied residential building.
To support approval of the requested exceptions, the denial of the application must result in an effective prohibition under Federal law, or a finding that the denial will violate State law. For the reasons discussed in the proposed resolution and staff recommends denial. The City Council must determine if the applicant has met the burden on this exception finding for these two placement restrictions for this proposed facility regarding the effective prohibition claim and the state law claim. • Staff recommends the City Council adopt a
Resolution (Attachment 1):
• Finding the project Statutorily Exempt from the
California Environmental Quality Act (CEQA)
pursuant to Section 15270(a) of the CEQA
Guidelines (Projects Which Are Disapproved)
which states that CEQA does not apply to
projects which a public agency rejects or
disapproves;
• Denying an Appeal of the Planning
Commission’s decision to deny a Use Permit,
Design Review, and Coastal Development
Permit for the construction of a Small Wireless
Facility on a replacement PG&E utility pole in
the public right-of-way in front of Carmelo
Street 4 southeast of 10th Avenue in the
Single-Family Residential (R-1) District; and
• Denying a Use Permit, Design Review, and
Coastal Development Permit for the
construction of a Small Wireless Facility on a
replacement PG&E utility pole in the public
right-of-way in front of Carmelo Street 4
Southeast of 10th Avenue.
CITY OF CARMEL-BY-THE-SEA 23
Recommendation
Carmel-by-the-Sea Planning Commission
February 10, 2026
Carmelo Street
Small Cell Node 001
Pete Shubin, Sequoia Deployment Services
Jay Gruendle, Program Manager, Verizon Small Cells
Jeremy Stroup, Verizon Municipal Engagement Partner
Rich Conroy, PierCon Solutions
David Witkowski, Oku Solutions
Paul Albritton, Mackenzie & Albritton LLP
Golden Bough
Best Serving Transmitter
Existing Network
Golden Bough alternative not
consistent with small cell spacing
geometry
Golden Bough
Looking Southwest
Drone photos show obstruction by trees next to Golden Bough, particularly southwest toward much of gap area
Looking Northwest
Best Serving Transmitter
with Proposed Facility
Proposed facility provides new reliable
service to gap area
Golden Bough
Small Cell EƯects on Property
Valuations
Prepared for Carmel-by-the-Sea PC, February 10th 2024
David Witkowski, CEO, Oku Solutions LLC
[email protected]
+1-408-889-9741
Assertions of Valuation Decrease
• Oft-cited “Up to 20%
reduction” is based primarily
on Bond/Wang in The
Appraisal Journal (2005).
– Sandy Bond was retained in the
late 90’s by a Christchurch NZ
neighbor group opposed to a
tower build.
– Bond’s method was a survey, not
a study of MLS or other data.
Other Works re Valuation Decrease
• Other work claiming
valuation disamenity:
– Affuso et al. 2017,
Hale/Beck 2019, others
– Some (notably not all)
articles in NAR Realtor.
Works re Valuation Amenity
• Some studies show
property valuation
increase or no effect:
– Smaqae / Anwar (2022),
Olukolajo et al. (2013),
Valbridge (2018), Maennig
(2012), others..
Spatial DiƯerence in DiƯerences
• I authored a study on small
cell price effects using an
analysis by Ralph McLaughlin,
PhD in real estate economics.
• Study used 1,700+ small cell
builds and all 11.6 million real
estate transactions between
2010 – 2020, including Central
Coast sites.
Spatial Difference in Differences
• To my knowledge, mine is
the only small cell study.
Others are macro-focused.
• The study showed no
economically-significant
negative impacts, and some
economically-significant
positive impacts, variable by
community.
Design is PG&E Greenbook & GO 95 Compliant
Verizon confidential and proprietary. Unauthorized disclosure, reproduction or other use prohibited. • PG&E pole sides are described as
positions on a clock
o Street side is 6:00
o View looks directly at the pole at
7:30
• Drawing is based on attachment
heights provided by PG&E
• PG&E approved design/drawing:
o PG&E issued construction sketch
o PG&E issued contract
o PG&E application for pole
replacement includes drawing
(TEMP EN 250013 (PG&E -
Carmelo & 11th) PM# 35598210)
Opposition Comments on Attachments
Verizon confidential and proprietary. Unauthorized disclosure, reproduction or other use prohibited.
What would happen if the
attachment heights changed?
• Mismatch of attachment heights
compared to other poles on the
street
• Other GO 95 infractions such as
blocking traffic (driveway)
Impacts to the Adjacent Tree
Verizon confidential and proprietary. Unauthorized disclosure, reproduction or other use prohibited. • Met with PG&E job owner for this site, PG&E arborist, and City Staff at the site on February 4
• PG&E explained design, plans, and pole replacement scope • PG&E confirmed that the pole replacement work will have minimal impact to the health of the tree
Golden Bough – Constructable, BUT DOES NOT WORK
Verizon confidential and proprietary. Unauthorized disclosure, reproduction or other use prohibited. • Met with Golden Bough and worked up
the best possible design for the location
• The design is constructable but does not
work for Verizon Wireless’s network
needs (wrong location and trees)
• Golden Bough has since requested
potential changes to the design and
location that would exacerbate the
reasons why the site does not work
• Those requested changes would violate
the City’s Codes
• The site does not work for Verizon
Wireless
Verizon confidential and proprietary. Unauthorized disclosure, reproduction or other use prohibited.
Conclusion: Facts
• PierCon and CTC confirm service gap in Carmel-by-the-Sea • The proposed facility complies with City Code use permit and design review findings and wireless design guidelines
Verizon confidential and proprietary. Unauthorized disclosure, reproduction or other use prohibited.
Conclusion: Law
• City cannot require a macro facility over a small cell (New York SMSA Ltd. Partnership v. Town of Clarkstown, 612 F.3d 97, 105-106 (2nd Cir. 2010))
• City cannot bar use of the right-of-way by a telecommunications company (Cal. Pub. Util. Code §7901)
• Requiring installation of a macro facility over a small cell materially inhibits network improvements through unreasonable delay and cost (TowerNorth Development, LLC v. City of Geneva, 2024 WL 621616, *24- 25 (N.D. Ill. Feb. 14, 2024))
• Evidentiary burden on City to prove that any alternative is less intrusive and “technically feasible” (T-Mobile USA, Inc. v. City of Anacortes, 572 F.3d 987, 998-999 (9th Cir. 2009))
Verizon confidential and proprietary. Unauthorized disclosure, reproduction or other use prohibited. Verizon confidential and proprietary. Unauthorized disclosure, reproduction or other use prohibited.
Pete Shubin, Sequoia Deployment Services
Jay Gruendle, Program Manager, Verizon Small Cells
Jeremy Stroup, Verizon Municipal Engagement Partner
Rich Conroy, PierCon Solutions
David Witkowski, Oku Solutions
Paul Albritton, Mackenzie & Albritton LLP
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
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
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
Rid
g
e
wo
o
d
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
Existing, Planned, and Proposed
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
SF-001
Carmelo Street Small
Cell Node 001
RF Engineering Analysis of Golden Bough
as Technically Feasible Alternative
Rich Conroy, PierCon Solutions, LLC for
Verizon Wireless
RF
ENGINEERING
PRESENTATION
CTC ATTACHMENT 6 – REVIEW OF
PIERCON SUP-RPT4
PIERCON - GOLDEN BOUGH
ANALYSIS
CTC ATTACHMENT 5 – GOLDEN
BOUGH ANALYSIS
TECHNICAL FACT CONCLUSIONS
CTC
ATTACHMENT
6 (Review of
PierCon
Sup#4)
1. “REDEFINED GAP” vs. “GAP REMAINING”
2. CTC CLAIM RE: POOR SINR NEAR 8TH & CASSANOVA
STREET HAS NO RELEVANCE
3. CTC USES INCORRECT DOWNTILT ASSUMPTION IN
MODELING
UPLINK MAPL (127) GAP REMAINING – SMALL CELL GEOMETRY EXHIBIT
1. PURPOSE: SITE GEOMETRY/SPACING ANY CANDIDATE SHOULD HAVE WITH REGARD TO EXISTING AND APPROVED SITES.
2. GOLDEN BOUGH IS NOT WITHIN THE GAP AREA AND IS ADJACENT TO EXSTING COVERAGE
3. FACT – GOLDEN BOUGH CAN NEVER BE TECHNICALLY FEASIBLE TO MEET THIS CRITERIA 2100 SINR DT Map
Review
• CTC CLAIMS AREA NEAR 8TH & CASSANOVA HAS POOR SINR
• IT DOES EVEN THOUGH THE AREA IS 1 BLOCK BETWEEN EXISTING DT CARMEL AND SF-003.
• DUE TO CLOSE SPACING DT CARMEL & SF-003 INTERFERING WITH EACH OTHER.
• FURTHERMORE, GOLDEN BOUGH TECHNICALLY CANNOT CORRECT THIS PROBLEM AS IT:
• HAS NO ANTENNAS POINTED IN THIS DIRECTION (AND CANNOT) • WILL, WITH OR WITHOUT ANTENNAS POINTED IN THIS DIRECTION, CAUSE MORE DESTRUCTIVE INTERFERENCE.
• IRRELEVANT –
• DOESN’T CHANGE THE CELL SITE GEOMETRY
• GOLDEN BOUGH CANNOT RECTIFY THIS PROBLEM ANYWAY, IN FACT WOULD MAKE IT WORSE.
• AS THE FACT REMAINS GOLDEN BOUGH IS NOT CENTRALLY LOCATED WITHIN THE GAP AND NEVER WILL BE.
CTC INCORRECT DOWNTILT ASSUMPTION
• CTC ASSUMES GOLDEN BOUGH CAN BE DESIGNED WITH NO DOWNTILT BECAUSE SURROUNDING
VERIZON SITES CURRENTLY OPERATE THAT WAY
• THAT ASSUMPTION MISUNDERSTANDS WHY THOSE SITES ARE OPERATING WITH MINIMAL DOWNTILT TODAY.
• VZW EXISTING MACRO SITES OPERATING WITH LIMITED DOWNTILT BECAUSE THEY ARE
ATTEMPTING TO STRETCH COVERAGE ACROSS TERRAIN CONSTRAINED AREAS WITH NO INFILL SITES. THAT IS NOT THE OPTIMUM NETWORK CONFIGURATION…THAT IS A COMPROMISE. • SMALL CELLS ARE DEPLOYED SPECIFICALLY SO THAT SURROUNDING MACRO SITES CAN THEN BE
RE-OPTIMIZED W/NECESSARY E-DOWNTILT TO CONTROL INTERFERENCE AND IMPROVE SIGNAL CLARITY.
• CTC’S ROOFTOP MODELING ASSUMES TODAY’S COMPROMISED CONDITION IS A PERMANENT DESIGN STATE…IT IS NOT. AND IT IS NOT APPROPRIATE TO MODEL IT THAT WAY.
GOLDEN BOUGH ANALYSIS – FEASIBILITY CRITERIA
• Deploying small cell network to densify mid-band, inclusive of C-Band (3700 MHz). • SMALL CELL CRITERIA
• Proximity to the area requiring service.
• Alignment with planned small-cell deployment geometry. • Compatibility with intended antenna configuration
• Deploying omni-directional antennas with 4x4 MIMO
• Omni minimizes inter-sector handoffs improving call quality and reliability. • Omni with 10º electrical tilt controls coverage to localized area, minimizes overlap = improved quality/clarity.
• Ability to maintain two-way communication with uplink limited design conditions. • For Alternate to be technically feasible it must be evaluated against same criteria.
GOLDEN BOUGH FEASIBILITY ANALYSIS
• PROPOSED SMALL CELL vs GOLDEN BOUGH AS SMALL CELL EQUIVALENT • PROPOSED SMALL CELL vs. GOLDEN BOUGH W/MACRO STYLE ANTENNAS – 2
DEGREE DOWNTILT
• PROPOSED SMALL CELL vs. GOLDEN BOUGH W/MACRO STYLE ANTENNAS – 8
DEGREE DOWNTILT
GOLDEN BOUGH ROOFTOP IS NOT TECHNICALLY FEASIBLE
OF REMEDYING THE GAP IN SERVICE
SIDE BY SIDE COMPARISON OF PROPOSED SMALL CELL vs. GOLDEN BOUGH SMALL CELL EQUIVALENT Golden Bough With Minimal 2º Electrical Downtilt
• Requires – Macro style high gain panel antenna - violates Verizon Small Cell criteria design; as provides extended signal range.
• Requires two sectors – violates Verizon’s small cell design criteria; as requires inter-cell handoff’s, creates inter-cell SINR issues, poor performance. • Evaluate uplink performance to demonstrate user “reach” to Golden Bough which is at the outermost edge of the gap area.
• Extended signal range creates interference.
• Leaves significant holes through core of gap area.
USERS IN CENTER OF GAP HAVE LONGEST DISTANCE TO
REACH BACK TO SITE. SITE IS NOT LOCATED CORRECTLY
TO BE A FEASIBLE ALTERNATIVE.
GOLDEN BOUGH ROOFTOP IS NOT TECHNICALLY FEASIBLE
OF REMEDYING THE GAP IN SERVICE.
Golden Bough With Minimal 8º Electrical Downtilt
• 8º Comes from basic geometry using antenna height above terrain, the vertical beamwidth, and the target ground intercept distance.
• We solved for the downtilt that places the upper boundary of the main lobe at the ground at about 0.35 miles given the rooftop’s height above terrain and line of sight profile. • Once you apply the level of downtilt needed to control overshoot from that rooftop, you materially reduce the ability to serve the center of the gap – so the rooftop is not a technically feasible alternative. • Requires – Macro style high gain panel antenna - violates Verizon Small Cell criteria design; as provides extended signal range. • Requires two sectors – violates Verizon’s small cell design criteria; as requires inter-cell handoff’s, inter-cell SINR issue, poor performance.
• Evaluate uplink performance to demonstrate user “reach” to Golden Bough which is at the outermost edge of the gap area. • Extended range now better managed.
• Leaves little margin in core, reducing link reliability for major central portion of gap. Doesn’t provide service to the southern portion of the gap.
UPLINK 0-5 dB MARGIN IN CENTRAL PORTION OF GAP.
BELOW <0 dB MARGIN IN SOUTHERN PORTION OF GAP.
GOLDEN BOUGH ROOFTOP IS NOT TECHNICALLY FEASIBLE
OF REMEDYING THE GAP IN SERVICE
GOLDEN BOUGH FEASIBILITY ANALYSIS
• Verizon also deploying C-Band (3700 MHz)
• Same issues as AWS Band (2100 MHz)
• Not Modeled by CTC
• Golden Bough cannot provide service to central portion of gap and southern portion of gap.
GOLDEN BOUGH ROOFTOP IS NOT TECHNICALLY FEASIBLE
OF REMEDYING THE GAP IN SERVICE.
C-BAND GAP REMAINS IN CORE CENTRAL PORTION AS
WELL AS SOUTHERN SECTION OF GAP.
CTC GOLDEN BOUGH ANALYSIS – ATTACHMENT #5
• CTC MODELING FLAWED
• MAPL / UPLINK ANALYSIS COULD NOT BE PERFORMED WITHOUT VERIZON INPUT
IS TECHNICALLY INACCURATE
• MAKES INCORRECT ASSUMPTION REGARDING DOWNTILT
• DOES NOT MODEL WITH SAME CRITERIA USED TO EVALUATE PROPOSED SMALL CELL – IGNORING CRITICAL DESIGN CRITERIA
• DOES NOT MODEL INTERFERENCE / SINR – (page 8 makes statement however not represented in plots as noted)
• DID NOT MODEL C-BAND (FIGURE 6 NOTES 3700 BUT IS ACTUALLY 1900) • QUESTION CLUTTER / TERRAIN DATABASE AND WHETHER MODEL WAS TUNED CTC GOLDEN BOUGH ANALYSIS – FLAWED MODELING
• Plot reference mislabeled (1950 / 3700): Is 1950 per callout however. • C-Band plot not provided.
• Signal completely uncontrolled and interfering to south where SF-002 Approved site is set to cover, will interfere to east with existing coverage. • Question if model is “tuned” to drive data
• 2100 Plot showing large scale interference with existing and planned sites. • Signal completely uncontrolled and interfering to south where SF-002 Approved site is set to cover, interferes east into site into existing coverage. • Question if model is “tuned” to drive data
TECHNICAL FACT CONCLUSIONS
• GOLDEN BOUGH ROOFTOP IS NOT A TECHNICALLY FEASIBLE ALTERNATIVE BECAUSE:
• FACT – CANNOT MEET CELL GEOMETRY / PROXIMITY REQUIREMENT • NOT LOCATED NEAR CENTER OF GAP / LOCATED EDGE OF EXISTING COVERAGE • FACT – CANNOT MEET SERVICE REQUIREMENTS UNDER SAME SMALL CELL CRITERIA (SMALL CELL
EQUIVALENT ANALYSIS)
• FACT – CANNOT MEET SERVICE REQUIREMENTS BY CHANGING ANTENNA DESIGN TO MACRO STYLE (HIGH
GAIN / PANEL TYPE)
• LOW DOWNTILT CAUSES DESTRUCTIVE INTERFERENCE
• REQUIRED DOWNTILT DOESN’T PROVIDE EFFECTIVE SERVICE
• REQUIRES SECTORIZED ANTENNAS CREATES INTER-CELL HANDOFF AND POOR QUALITY ON MID
BAND INCLUDING C-BAND
• CANNOT SUPPORT C-BAND COVERAGE WITHIN CORE OF GAP AREA. • CONCLUSION – GOLDEN BOUGH ROOFTOP IS NOT A TECHNICALLY FEASIBLE ALTERNATIVE.
Carmel-by-the-Sea City Council
March 2, 2026
Carmelo Street
Small Cell Node 001
Pete Shubin, Sequoia Deployment Services
Jay Gruendle, Program Manager, Verizon Small Cells
Jeremy Stroup, Verizon Municipal Engagement Partner
Rich Conroy, PierCon Solutions
Paul Albritton, Mackenzie & Albritton LLP
Verizon confidential and proprietary. Unauthorized disclosure, reproduction or other use prohibited.
Project Timeline
September 2019
City Council denied five Verizon Wireless
applications, including original Node 001
location on San Antonio Avenue at 10th Avenue
November 2020
Verizon Wireless and City executed agreement
that Verizon Wireless relocate proposed
Node 001 to Carmelo Street south of 8th Avenue
December 2021
City Council denied second Node 001 location
on Carmelo Street south of 8th Avenue
October 2025
Verizon Wireless applied for third Node 001
location on Carmelo Street north of 11th Avenue
Project Design
Verizon confidential and proprietary. Unauthorized disclosure, reproduction or other use prohibited. • Replace 38’ 11” utility pole with 46’ 4” pole
• Mount 2.5’ cylindrical antenna on top of new
pole
• Total facility height 49’ 10”
• Mount 6’ equipment shroud between
11’ and 17’
• Mount small electric meter with disconnect
switch between 7’ and 8’ 10”
2.5’ Antenna
6’ Equipment
Shroud
Electric
Meter
Photo Simulations
This simulation relies upon an artist’s depiction of the information provided by the applicant.
Verizon confidential and proprietary. Unauthorized disclosure, reproduction or other use prohibited.
Looking Northeast Looking East Looking Southeast
Photos of Adjacent Utility Poles
This simulation relies upon an artist’s depiction of the information provided by the applicant.
Verizon confidential and proprietary. Unauthorized disclosure, reproduction or other use prohibited.
Pole to North
With Transformer
Pole to South
With Side-Mounted Cabinet
Verizon confidential and proprietary. Unauthorized disclosure, reproduction or other use prohibited.
Best of 28 Alternatives
• Infeasible per PG&E rules (15)
Transformers, line cutouts,
conduit stub-ups
Safe worker climbing space
• More intrusive (12)
Require more special exceptions
from City requirements (7 to 15)
Proposed small cell requires only
2 exceptions
Verizon confidential and proprietary. Unauthorized disclosure, reproduction or other use prohibited.
Complies with City Standards and Findings
Wireless Facility Design Guidelines
• Height. Replacement utility pole less than 10 feet above existing pole, provides safety clearance for antenna (§ II(A)(1))
• Antenna volume. 2.9 cubic feet, less than 3 cubic feet allowed (§ II(B)(3)) • Equipment volume. Complies absent City-required “wings” • Concealment. Radios and network gear concealed in narrow vertical shroud, as required (§ II(C)(3)(a))
• Pole-mounted equipment. Allowed because undergrounding or smaller shroud are infeasible (§ II(C)(1))
Zoning Code
• View protection. Antenna above sight lines, equipment below (§ 17.46.040(F)(1)(k)) • Permit findings. Proposed small cell satisfies findings for use permit, design review, and coastal development permit, including no detriment to health, safety, or welfare (§§ 17.58.060, 17.64.010)
Wings Included at City’s Request
Verizon confidential and proprietary. Unauthorized disclosure, reproduction or other use prohibited.
Design is PG&E Greenbook & GO 95 Compliant
Verizon confidential and proprietary. Unauthorized disclosure, reproduction or other use prohibited. • PG&E pole sides are described as
positions on a clock
o Street side is 6:00
o View looks directly at the pole at
7:30
• Drawing is based on attachment
heights provided by PG&E
• PG&E approved design/drawing:
o PG&E issued construction sketch
o PG&E issued contract
o PG&E application for pole
replacement includes drawing
(TEMP EN 250013 (PG&E -
Carmelo & 11th) PM# 35598210)
Verizon confidential and proprietary. Unauthorized disclosure, reproduction or other use prohibited.
Complies with FCC Guidelines
• Engineer with Dtech Communications
confirmed that radio frequency exposure
will be less than FCC general population
limit
ā 0.4% at ground level
• Denial based on RF exposure concerns
preempted by federal law
(47 U.S.C. § 332(c)(7)(B)(iv))
Verizon confidential and proprietary. Unauthorized disclosure, reproduction or other use prohibited.
Complies with City Noise Code
• Engineer with Hammett & Edison, Inc.
confirmed all equipment passively
cooled
• Neither antenna nor radios generate
noise
• No noise impact, so complies with
Code Chapter 8.56, Noise Regulations
Golden Bough – Constructable, BUT DOES NOT WORK
Verizon confidential and proprietary. Unauthorized disclosure, reproduction or other use prohibited. • Worked up the best possible design for
the location
• Contemplated Design
o Four panel antennas
o Four remote radio units (“RRUs”)
o Generator receptacle or lug box
o Electrical power and fiber connections
o Associated cabling
o Faux chimney at 4’x4’x10’T (for both the
antennas and RRUs; allows passive ventilation)
• Result Æ The site does not work for
Verizon Wireless for other reasons
Golden Bough – Verizon Contemplated Chimney Design
Verizon confidential and proprietary. Unauthorized disclosure, reproduction or other use prohibited. • Key Requirement
o House antennas and RRUs above roof
• Contemplated Design
o Three sides RF transparent
o East side would be louvered door for air intake
and maintenance
o Top would be open for heat exhaust (passive
convex cooling)
o Four remote radio units (“RRUs”) stacked in
east side by louvers for cooling
o Cabling entry through bottom (hidden)
o Faux chimney at 4’x4’x10’T, 160 cubic feet.
o Chimney placed offset to the north of the roof
ridge for structural and cabling access
purposes.
Verizon confidential and proprietary. Unauthorized disclosure, reproduction or other use prohibited.
Golden Bough Tree Obstruction – Southwest View
Golden Bough – CTC Chimney Design Infeasible
Verizon confidential and proprietary. Unauthorized disclosure, reproduction or other use prohibited. • Only 2 antennas, not 4
• Insufficient size for Verizon contemplated
antennas and radios at 28 inches in diameter
• Placement neglects cable access needs;
blocked by roof framing
• Total volume = 43 cubic feet; too small for
proposed equipment and air flow (Verizon
design is 4’x4’x10’T, 160 cubic feet)
• Note at bottom places equipment out of order
requiring excess cabling
• Note at bottom places heat-generating
equipment inside the building
Golden Bough – CTC Chimney Design Infeasible Cont.
Verizon confidential and proprietary. Unauthorized disclosure, reproduction or other use prohibited. • Top cap exceeds allowable height by
approximately 2 feet
• Insufficient size for Verizon-contemplated
antennas and radios
• Placement neglects cable access needs;
blocked by roof framing
• Total volume = 43 cubic feet; too small for
proposed equipment and air flow (Verizon
design is 4’x4’x10’T, 160 cubic feet)
• No air intake accommodation for RRU cooling
• No fan accommodation for RRU cooling; fans
required for active cooling in confined space
• Conclusion: CTC design is not feasible
o Insufficient design missing required
features for proper function
Verizon confidential and proprietary. Unauthorized disclosure, reproduction or other use prohibited.
Golden Bough is Not an Alternative
• Not technically feasible
o CTC reports inconclusive; do not address signal quality and uplink
o Small cells densify network and introduce new services, not just coverage
o Trees: removal unrealistic and not a solution to technical infeasibility
• More intrusive
o Larger footprint
o Height exception
o Historic resource
o Delay and expense
Verizon confidential and proprietary. Unauthorized disclosure, reproduction or other use prohibited.
Denial Violates Federal and State Law
• Telecommunications law violations:
o Prohibition of service
o As-applied code effectively prohibits wireless service • FCC’s Moratorium Order (de facto moratorium)
• City cannot dictate technology: macro vs. small cell
• State law violation of Cal. Pub. Util. Code Section 7901 Verizon confidential and proprietary. Unauthorized disclosure, reproduction or other use prohibited.
What’s Next?
Verizon confidential and proprietary. Unauthorized disclosure, reproduction or other use prohibited.
Underground Equipment Infeasible
Verizon confidential and proprietary. Unauthorized disclosure, reproduction or other use prohibited. • Reviewed with City over past
eight years
• Requires construction of formal
sidewalk with concrete curb and gutter
to direct water away from underground
vault
• Still requires above-ground equipment
(vent stacks, bollards, meter pedestal)
• Other vault locations infeasible due to
distance, physical obstructions, trees,
underground utility lines
Impacts to the Adjacent Tree
Verizon confidential and proprietary. Unauthorized disclosure, reproduction or other use prohibited. • Met with PG&E job owner for this site, PG&E arborist, and City Staff at the site on February 4
• PG&E explained design, plans, and pole replacement scope • PG&E confirmed that the pole replacement work will have minimal impact to the health of the tree
Councilmember Buder slides rec'd 3-2-2026 (next 3 pages) • Text….
Re-adjusted Boundaries of Identified Verizon
Mid-Band Service Gap Area – 2.23.2026
Boundaries of Identified
Verizon Mid-Band Gap – 10.10.2025
• “Figure 2 is a map provided by PierCon in this latest report, dated February 23, 2026, RF Supplement #4. Note that they have redefined the boundary of the gap area (now shown as a red dotted line). The gap which used to include the area surrounding the Golden Blough Playhouse has been shifted without explanation such that it is no longer within the gap area. In fact, the new gap boundary has become Casanova Street, due west of the Playhouse.
Yet the actual field measurements make it clear that one of the larger clusters of the worst-case coverage areas can be found around the intersections of Lincoln Street and Eighth Avenue.” [Emphasis added]
CITY OF CARMEL-BY-THE-SEA 2
The City’s consultant questions the shift in the
boundary of the alleged coverage gap
The City’s consultant showed mid-band option
at Golden Bough can cover the gap
The Gap In-Building Coverage from Golden Bough