Mammoth Lakes City Council
April 3, 2024

Town Council Agenda

Wednesday, April 3, 2024, 4:00 p.m.
437 Old Mammoth Road, Suite Z, Mammoth Lakes
Members of the Town Council:

Mayor Bill Sauser, Mayor Pro Tem Chris Bubser, Councilmember Sarah Rea, Councilmember Amanda Rice, Councilmember John Wentworth NOTE: In compliance with the Americans with Disabilities Act, if you need special assistance to participate in this meeting, please contact the Town Clerk at (760) 965-3602. Notification 48 hours prior to the meeting will enable the Town to make reasonable arrangements to ensure accessibility to this meeting. (28 CFR 13.102-35.104 ADA Title II)
NOTE: Materials related to an item on this agenda submitted after distribution of the agenda packet are available for public inspection in the Town Offices located at 437 Old Mammoth Road, Suite 230 during normal business hours. Such documents are also available on the Town of Mammoth Lakes website at www.townofmammothlakes.ca.gov subject to staff’s ability to post the documents before the meeting.

NOTE: You may attend the Town Council meetings in person or watch them on the Town of Mammoth Lakes' website at www.townofmammothlakes.ca.gov , on the local government cable channel 18, or via Zoom. Public comments can be submitted to the Town Clerk at [email protected]. before and during the meeting, or may be made in person or via Zoom.

NOTE: All comments will be limited to a speaking time of five minutes.

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1. CALL TO ORDER AND ROLL CALL

2. PLEDGE OF ALLEGIANCE

3. PUBLIC COMMENTS
The Public Comment portion of the agenda provides the public with an opportunity to address the Town Council on matters not otherwise listed on the agenda. Under California law the Town Council is prohibited from generally discussing or taking action on items not included in the agenda; however, the Town Council may briefly respond to comments or questions from members of the public. Therefore, the Town Council will listen to all public comment, but will not generally discuss the matter or take action on it. Requests for service from the Town may also be made at the Town offices during regular business hours.

Members of the public desiring to speak on a matter appearing on the agenda should ask the Mayor for the opportunity to be heard when the item comes up for Council consideration.

4. ADDITIONS TO THE AGENDA
Opportunity to add urgency items pursuant to Government Code Section 54954.2(b)2, if necessary.

5. COUNCIL PRESENTATIONS

5.1 Proclamation declaring April as Fair Housing Month.

6. WORKSHOP
Eastern Sierra Community Housing Board Member Brian D'Andrea will attend this workshop remotely from the following address: 1000 Corporate Pointe, Suite 200 Culver City, CA 90230.

6.1 Joint workshop with the Eastern Sierra Community Housing Board of Directors.

7. PUBLIC HEARINGS
Public Hearing Procedure.

The Mayor will open the public hearing and then: Statement and presentation by staff.

Statement and presentation by property owner or appellant. Questions from the Town Council. Call for testimony. Rebuttal to previous testimony by property owner or appellant.

Close the public hearing, terminating public testimony. The Town Council will deliberate the matter and arrive at a decision.

7.1 Public hearing for consideration of an appeal of the February 14, 2024 Planning and Economic Development Commission decision to approve Use Permit Application 23- 002 for the construction of an 80-foot tall “stealth monopine” cell tower located at 1574 Old
Mammoth Road.

8. REPORTS FROM COMMISSIONS AND/OR DEPARTMENTS (AS NEEDED)

8.1 Did you Know? Short-term Rental Moratorium.

8.2 April 2024 PW Engineering CIP Update.

8.3 April 2024 Office of Outdoor Recreation Update.

9. CONSENT AGENDA

9.1 Approve the minutes of the regular meeting of March 20, 2024.

9.2 Award contract for the Community Childcare Center Project to JPB Designs, Inc.

9.3 Adopt resolutions calling and giving notice of a general municipal election on Tuesday, November 5, 2024 for the election of two members of the Town Council and requesting the Mono County Board of Supervisors consolidate the election.

9.4 Waive bidding requirements and award contract for purchase of a new loader to Cashman Cat.

9.5 Re-appoint incumbents Jesse Baldwin, Elliott Brainard, Wes Davis, and Dan Polis to the Building Advisory Committee/Board of Appeals with terms expiring on April 1, 2028.

9.6 Approve Resolution for FY23-24 Measure U Programming funding in the amount of $208,750.

9.7 Resolution to approve the FY2024-25 project list to be submitted to the California Transportation Commission (CTC) for funding from the Road Maintenance and Rehabilitation Account (RMRA) funds under Streets and Highways Code Section 2034.

9.8 Support for SCR-102 “Dave McCoy Memorial Highway.”

9.9 Authorize execution of contract with Gray’s Grasshopper, Inc. for Main St.

Landscaping project Phase 1.

9.10 Accept Check Register 3/21/24 in the amount of $943,859.56.

10. POLICY MATTERS

10.1 Fiscal Year 2024-25 Budget – General Fund Revenue Projections.

11. COUNCILMEMBER REPORTS
Informational reports from Councilmember representatives on committees, commissions, and organizations; general reports on Councilmember activities

12. ADJOURNMENT
The Town Council will adjourn to a regular meeting to be held on Wednesday, May 1, 2024 at 4:00 p.m.

A PROCLAMATION OF THE TOWN COUNCIL OF THE

TOWN OF MAMMOTH LAKES, STATE OF CALIFORNIA,
PROCLAIMING APRIL 2024 AS

FAIR HOUSING MONTH
WHEREAS, April 11, 2024, marks the 56
th anniversary of the passage of the Fair
Housing Act, Title VIII of the Civil Rights Act of 1968, as amended, which enunciates a national policy of Fair Housing that prohibits discrimination in housing based on race, color, religion, sex, familial status, national origin, and disability, and commits recipients of federal funding to affirmatively further fair housing in their communities; and
WHEREAS, the Mammoth Lakes Board of REALTORS•and Eastern Sierra Community Housing are committed to highlight the Fair Housing Act by continuing to address discrimination in our community, to support programs that will educate the public about the right to equal housing opportunities for all, and to plan partnership efforts with other organizations to help assure everyone of their right to fair housing; and
WHEREAS, the National Association of REALTORS• Code of Ethics commits all REALTORS•to provide equal professional services without discrimination based on race, color, religion, sex, familial status, handicap, sexual orientation, gender identity, and national origin.

NOW, THEREFORE, BE IT RESOLVED that the Town Council of the Town of Mammoth Lakes, California, hereby proclaims that the month of April, 2024 is Fair Housing Month in the Town of Mammoth Lakes and urges all citizens to wholeheartedly recognize this commemoration of the Fair Housing Act throughout the year.

PROCLAIMED this 3rd day of April 2024.

_________________________________
ATTEST: BILL SAUSER, Mayor
____________________________
JAMIE GRAY, Town Clerk

Mammoth Lakes Town Council
Agenda Action Sheet
Title: Town Council and Eastern Sierra Community Housing Board of Directors Joint Meeting Council Meeting Date: 4/3/2024
Prepared by: Nolan Bobroff, Community and Economic Development Director Recommended Motion: Participate in a joint workshop with the Eastern Sierra Community Housing Board of Directors.

Summary: The Eastern Sierra Community Housing (ESCH) Board of Directors last met with the Town Council on May 17, 2023. The purpose of these joint workshops is to discuss and provide updates on recent work program items and to discuss other relevant topics related to housing.

Agenda topics for this meeting include:

1. Housing Programs Overview
a. TOML
b. ESCH (Include work being done in the region)

2. Discussion of Homeownership Programs
a. Challenges (Interest Rates; Affordability, HOA fees, insurance, etc.) b. BRIDGE Program
c. Ownership phase at the Parcel (Ph 3)

3. STR Committee Recommendations
a. Rental Subsidies
b. Down-Payment Assistance
c. TOT tax increase (to be committed to housing)

4. Update of the Housing Needs Assessment
a. Timing
b. Goals and desired outcomes

1 TOWN COUNCIL STAFF REPORT
Title: Public hearing for consideration of an appeal of the February 14, 2024 Planning and Economic Development Commission decision to approve Use Permit Application 23-002 for the construction of an 80-foot tall “stealth monopine” cell tower located at 1574 Old Mammoth Road.

Meeting Date: April 3, 2024
Prepared by: Michael Peterka, Associate Planner
Nolan Bobroff, Community and Economic Development Director RECOMMENDATION:

Staff recommends the Town Council deny the appeal of the Planning and Economic Development Commission decision and affirm the approval of Use Permit Application 23- 002.

SUMMARY:

Proposal: The proposed project is an 80-foot tall “stealth monopine” cell tower located at 1574 Old Mammoth Road at Mammoth
Lakes Fire Protection District Station #2. The parcel is within the Resort (R) Zoning District (Snowcreek Master Plan Area) and the project is subject to the Town’s
Telecommunication Facilities standards specified in the Municipal Code. The tower will be located in the rear
northeast corner of the property owned by the Mammoth
Lakes Fire Protection District.

Applicant / Property Owner: Eukon Group on behalf of AT&T / Mammoth Lakes Fire Protection District
Project Name: AT&T Cell Tower at Fire Station #2
Location: 1574 Old Mammoth Road (APN: 040-040-021-000)
Size of Property: 0.91 acres (39,640 sq. ft.)
Zoning: Resort (R) – Snowcreek Master Plan
General Plan: Resort (R)
Environmental Review: Categorically Exempt (CEQA Guidelines Section 15303)

2 BACKGROUND:

An application for a Use Permit was submitted to the Town on July 20, 2023, for the proposed 80-foot tall “stealth monopine” cell tower located at 1574 Old Mammoth Road on a 0.91-acre parcel in the Resort (R) zoning district that is also occupied by Mammoth Lakes Fire Protection District Station #2. The proposed cell tower is intended to improve cellular service in an area that currently has poor service and also improve emergency communications for the Fire District and other first responders. The tower will initially be used by AT&T and there is a potential that another service provider may collocate their equipment on the tower through approval of a subsequent permit, but no such plan exists at this time.

November 8, 2023 PEDC Meeting
This item was originally scheduled for a public hearing at the November 8, 2023 Planning and Economic Development Commission (PEDC) meeting; however, due to an error in the public noticing that inadvertently resulted in a number of property owners not receiving the public hearing notice, the item was continued to a future PEDC meeting.

February 14, 2024, PEDC Meeting
The PEDC held a noticed public hearing for the AT&T Cell Tower at Fire Station #2 Use Permit application on February 14, 2024. Public comments were made during the public hearing which included objections to the project based on visual impacts and impacts to property values. Public comments were also made in support of the project due to its improvements to public safety. The PEDC closed the hearing and approved the project by a 5-0 vote.

Project Appeal:

On February 29, 2023, the Snowcreek VII Condominium Owner’s Association (“Appellant”) submitted an appeal of the decision of the PEDC. The appeal was timely filed within the 15-day appeal period following the project approval. The appeal can be found in Attachment B.

LEGAL BACKGROUND:

Federal Limits on the Town’s Authority. 47 U.S.C. § 332(c)(7) (“Section 332”) is the principal federal law limiting the Town’s authority over placement of wireless facilities.1 Section 332 recognizes and preserves local zoning authority over the placement, construction and modification of wireless communications facilities, provided the locality complies with the following five requirements.
a. The Town Must Act on a Wireless Application Within A Reasonable Time
1 Another federal law, 47 USC 1455, and related FCC rules, also preempt local authority to deny certain insubstantial modifications to existing wireless facilities. This law is known as the Spectrum Act and the modifications it allows are known as eligible facilities requests or EFRs.

3 Section 332(c)(7)(ii) provides that local authorities must make a final decision regarding whether to approve or deny an application within a “reasonable period of time” after the request is filed, taking into account the nature and scope of the request. In 2009, the FCC established “presumptively reasonable periods” for local action on a wireless communications facility siting application—typically referred to as the “shot clocks.” Applications that propose a “collocation” must be approved or denied within 90 days; applications for all other facilities must be approved or denied within 150 days.2 The FCC
has since adopted three other “shot clocks” for other types of wireless applications.

Also worth noting, a California state law, Gov. Code Section 65964.1, provides that if a local government fails to act within the time required by the applicable FCC shot clock, the applicant may pursue a “deemed approval” of its application by providing notice to the local government, and the local government would have to go to court within 30 days to try to challenge the deemed granted assertion. However, this remedy is not available to applications for a wireless telecommunications facility where the project is proposed for placement on fire department facilities.
b. Town Cannot Regulate Based on RF Emissions Exposure Concerns, But Can Require Compliance with FCC Standards
The Federal Communications Commission (“FCC) has exclusive responsibility and authority to set safety standards for public and worker exposure to radio frequency (RF) emissions. Section 332(c)(7)(B)(iv) prohibits the Town from denying a wireless facility application based on concerns about RF emissions so long as the applicant has demonstrated that its facilities will comply with FCC standards.3 The FCC issued OET Bulletin 65, which provides technical guidelines for evaluating compliance with the FCC RF safety requirements.4
Consistent with these limitations, localities can require wireless facility applicants to demonstrate that the maximum exposure levels established by the FCC would not be exceeded. Typically the applicant is required to prepare an RF/EME technical study demonstrating that the proposed facility will comply with the FCC’s standards. 2 Petition for Declaratory Ruling to Clarify Provisions of Section 332(c)(7)(B) to Ensure Timely Siting Review and to Preempt Under Section 253 State and Local Ordinances that Classify All Wireless Siting Proposals as Requiring a Variance, Declaratory Ruling, WT Docket No. 08-165 (2009). 3 47 U.S.C. Section 332(c)(7)(B)(iv); see Guidelines for Evaluating the Environmental Effects of Radiofrequency Radiation, Report and Order, ET Docket No. 93-62, FCC 96-326, para. 166 (F.C.C. 1996), https://transition.fcc.gov/Bureaus/Engineering_Technology/Orders/1996/fcc96326.pdf. On August 1, 1996, the FCC adopted the National Council on Radiation Protection and Measurements' recommended Maximum Permissible Exposure limits for field strength and power density for those transmitters operating at frequencies of 300 kHz to 100 GHz. The FCC adopted the specific absorption rate (SAR) limits for devices operating within close proximity to the body as specified within the ANSI/IEEE C95.1-1992 guidelines. Id.
4 https://www.fcc.gov/general/oet-bulletins-line#65.

4 c. Town Cannot Effectively Prohibit the Provision of Personal Wireless Services
While federal law preserves local authority to establish wireless regulations, Section 332(c)(7)(B)(i)(II) restricts the Town from applying its local regulations to deny an application to the extent that the denial of the proposed facility would result in the prohibition or effective prohibition of the provision of personal wireless services. The Ninth Circuit has held that applying local regulations to deny a wireless facility application can improperly “prohibit” a wireless provider’s provision of personal wireless services if it prevents the wireless provider from closing a “significant gap” in its own service using the least intrusive means, having considered feasible alternatives. When making an effective prohibition claim, the applicant has the initial burden of proof. There is no brightline rule for determining when a gap is “significant;” instead, the conclusion is based on a fact-specific analysis of coverage and demand. To satisfy the least intrusive means standard, the applicant must show that it made a good faith effort to identify and evaluate alternatives, such as considering less sensitive sites, alternative system designs, alternative tower designs, and the use of existing structures for antenna placement, and proposes the least intrusive alternative. The applicant must analyze the specific factors in the locality’s code rather than solely relying upon generalized observations. Once the applicant has done that, the burden shifts to the locality to rebut the applicant’s least intrusive means analysis.

That is, a municipality is not compelled to accept and may reject the provider’s least intrusive means analysis, so long as the locality is able to show that there are some potentially available and technologically feasible alternatives. The provider must be given an opportunity to dispute the availability and feasibility of the alternatives favored by the locality.
d. Any Denial Must Be Supported By Substantial Evidence Section 332(c)(7)(B)(iii) requires that any decision under local regulations to deny a request to construct personal wireless facilities “shall be in writing and supported by substantial evidence contained in a written record.” The reasons for application denial must be provided contemporaneously with the denial decision. 5 To determine whether a
local government’s decision under its local wireless regulations is supported by substantial evidence within the meaning of the statute, a reviewing court “must be able to identify the reason or reasons why the locality denied the application.”6 The rationale behind such a denial need not be “elaborate or even sophisticated”—rather, a local authority must provide a rationale clear enough to “enable judicial review.”7 e. Town Cannot Discriminate Among Providers of Functionally Equivalent Services
Section 332(c)(7)(B)(i)(I) prohibits the Town from “unreasonably discriminat[ing] among providers of functionally equivalent services.” This limitation is intended to prevent 5 47 U.S.C. § 332(c)(7)(B)(iii); see T-Mobile S., LLC v. City of Roswell, Ga., 135 S. Ct. 808, 815 (2015). 6 Id. at 814. 7 Id. at 815.

5 the Town from dictating a preference for certain wireless technologies over others. For example, a local government cannot prohibit 5G wireless facilities.

APPEAL ANALYSIS:

The appeal includes seven topic areas: 1) CEQA and Environmental Impacts; 2) Public Safety; 3) Aesthetic Impacts to the Community; 4) Visual Assessment; 5) Decrease in Property Values; 6) Gaps in Service; and 7) Alternative Site Considerations. • Topic 1: The appeal states that the Class 3 CEQA exemption does not apply to the project because of its height and potential for its materials to be hazardous to the local grounds, flora, and fauna.

Staff Response:

The project was determined to be categorically exempt from CEQA since the project met all of the criteria to qualify for the exemption. In order to qualify for a Class 3 CEQA categorical exemption, a commercial project must not exceed 2,500 square feet in floor area to be considered a small structure and not meet any of the criteria outlined in the exceptions to the exemptions. The area of the proposed monopine and equipment has a total floor area of approximately 640 square feet and therefore does not exceed the 2,500 square foot limit. Additionally, none of the exceptions to the exceptions are applicable, as outlined in the PEDC Staff Report and Resolution and in the Key Issue #2 section, below. Therefore, the project qualifies for use of the Class 3 exemption. The criteria to qualify for the exemption does not take into account the height of a structure, only its total floor area if the project height is consistent with the zoning regulations.

Additionally, the argument that the monopine may be hazardous to local grounds, flora, and fauna is not supported by legal authority and there is no evidence to support the argument that the fake monopine would be hazardous to the environment. • Topic 2: The appeal argues that the proposed cell tower will have a limited improvement on public safety because it will only benefit AT&T customers.

Staff Response:

This appeal topic is not germane to any requirement for telecommunications facilities in the Municipal Code, and it does not relate to any required findings of approval for the use permit sought. Solely for the Council’s information, the FCC requires all wireless carriers to transmit 911 calls regardless of whether the caller subscribes to the wireless carrier's service or not, thus non-AT&T subscribers may utilize the proposed site for 911 calls if their respective wireless carrier does not maintain adequate coverage in the area served by the proposed tower. The cell tower will improve the ability of the Fire District and other emergency service providers to transmit critical health and safety messaging through the Integrated Public Alert and Warning System (IPAWS). Additionally, the cell tower will allow the Fire District to utilize FirstNet, which provides first responders with priority on the tower when the system is at high use. This will allow first responders to communicate when the cell tower is “jammed” by a large number of people using the system, which often takes place during emergencies. The Fire District has indicated that

6 it would like to add an additional wireless carrier, but no such plan has been finalized at this time. The Wireless Alert System cellular phone integration capabilities of the IPAWS system has proven to be the most efficient way to reach the public during emergencies, especially with regards to the large tourist population since they are not aware of any other messaging systems that might be used locally. In addition, the proposed cell tower is designed at a height that could allow for co-location of a second service provider. Verizon has shown interest in the site, but an agreement with them has not been finalized at this time. It is unknown at this time whether Verizon or any other wireless carrier will move forward at this site at this time, but as noted earlier, that issue is not relevant.
• Topic 3: The appeal argues that the proposed cell tower will have a negative impact on the aesthetics of the community.

Staff Response:

The project is subject to the development standards found in Zoning Code Section

17.52.280 (Telecommunication Facilities). The purpose of these wireless development standards according to Section 17.52.280(a) is “to preserve the unique visual character of the Town, promote the aesthetic appearance of the Town, and to ensure public safety and welfare.” The project meets all of the applicable standards. These include locating the facility in the rear of the property (not visible from public right-of-way) and screening (i.e., faux pine tree design) to blend the structure into the surroundings. The proposed faux pine tree design is intended to minimize the visual impacts of providing coverage in the area and that design was chosen to blend in with the surrounding pine trees on the site. The surrounding pine trees have an approximate average height of 55-65 feet.

Furthermore, the Town’s Zoning Code does not protect views from private property, including the views from the entirety of the Snowcreek VII development and the private streets within the development.
• Topic 4: The appeal argues that the visual assessment prepared by the applicant is defective and misleading for failing to utilize images taken from the nearby private residencies that may be impacted by the proposed facility.

Staff Response:

The Code requirement for the visual assessment does not require a wireless applicant to generate photosimulations of a proposed facility from the perspective of the private properties which would be impacted, but rather from the public perspective. Furthermore, a statement confirming the accuracy of the photo-simulations is included in Attachment D-2. The statement is from the independent contractor that was tasked with producing the photo-simulations on behalf of Eukon Group.
• Topic 5: The appeal argues that the cell tower will have a negative impact on the property values of nearby homes.

Staff Response:

As noted above, the purpose of the Code’s wireless standards according to Section

17.52.280(a) is “to preserve the unique visual character of the Town, promote the

7 aesthetic appearance of the Town, and to ensure public safety and welfare.” The Town’s standards and requirements do not include an evaluation of the effect of any particular development on property values. Instead, the Code requires as a necessary finding of approval “that the proposed use and the conditions under which it would be operated or maintained will not be detrimental to the public health and safety nor materially injurious to properties or improvements in the vicinity.” The Code sets applicable design requirements for wireless facilities to address aesthetics. The proposed faux tree design and other screening was intended to avoid unreasonable interference with views and to address the minimal requirements of the Code for telecommunication facilities (i.e., that they are located near existing utility poles, trees, or similar objects, and consist of colors and materials that best blend with the background).

Additionally, any claims that a proposed wireless facility will result in diminished property values that are rooted in a concern about the perceived effects of RF emissions exposure cannot constitute substantial evidence supporting a denial of a wireless facility application.8
• Topic 6: The appeal argues that the applicant is required to prove there are significant gaps in wireless service and that the proposed location will remedy those gaps.

Staff Response:

The Appellant incorrectly attempts to convert the Town’s application requirement into a required finding. Section 17.52.280(F)(1)(a) requires applicants to provide “[a] map showing planned and/or anticipated future needs of wireless communication services and facilities within and throughout the town, including a discussion of existing local network facilities and service gaps.” The applicant has met this application requirement through the submission of their Site Justification Coverage Maps dated January 12, 2024, and their Technical Siting Analysis dated February 8, 2024. The maps display the existing coverage in the area as well as other AT&T cell towers in Town and the surrounding area. The maps show that a large portion of the area around the proposed cell tower currently does not have adequate coverage indoors or in vehicles. The provided map showing coverage with the proposed tower indicates a large improvement in indoor coverage in the area surrounding the tower. The Municipal Code does not require the applicant to demonstrate that there is a significant gap and that the proposed facility will remedy this gap. The Town is limited to making the required findings for a Use Permit listed in Section 17.68.050.
• Topic 7: The appeal argues that the applicant did not in good faith consider alternative sites.

Staff Response:

The Appellant misstates this alternative site analysis requirement in its appeal memorandum. Section 17.52.280(F) instead requires wireless applicants to submit “An 8 California RSA No. 4 v. Madera County, 332 F.Supp.2d 1291, 1309 (E.D. Cal. 2003); AT&T Wireless Services of California LLC v. City of Carlsbad, 308 F.Supp.2d 1148, 1161(S.D. Cal. 2003).

8 alternative site analysis detailing the specific steps undertaken to determine the applicant's selection of a particular site consistent with Subsection 17.52.280F.2.” Subsection 17.52.280(F)(2) sets forth a list of preferences for sites.9 The applicant did
this in their application, a supplemental Technical Siting Analysis, dated February 8, 2024 and at the February 14th meeting by describing in detail their thought process and site selection, which lead them to the currently proposed location.

The submitted documents and the applicant’s statements at the February 14th meeting demonstrate that AT&T and their consultant, Eukon Group, performed a thorough site analysis and determined Fire Station #2 to be the best site for the monopine cell tower.

Other sites that were considered include the St. Joseph’s Catholic Church located at 58 Ranch Road and the Snowcreek Athletic Club located at 51 Club Drive. The church site is not a viable location because it is zoned Residential Multi-Family 2, and telecommunication facilities are not permitted in residential zones. The Snowcreek Athletic Club was not pursued due to lack of landlord interest at the time AT&T was conducting their alternative site analysis. The technical siting analysis (Attachment D5) provides additional information on the thought process related to the site selection for the proposed wireless facility. The Municipal Code does not require the applicant to demonstrate that it considered alternative sites in good faith, though the alternatives analysis submitted suggests that it did do so. The Town is limited to making the required findings for a Use Permit listed in Section 17.68.050.

APPLICANT RESPONSE TO APPEAL:

In response to the appeal, the Applicant, through its attorney Porter Wright Morris & Arthur LLP, submitted a response to the Appellant’s appeal memorandum (“Applicant Response”).

The Applicant Response generally addresses topics related to: 1) AT&T’s need for the facility and apparent gap in service coverage; 2) AT&T’s alternative site analysis; and 3) Responses to various claims outlined in the Appellant’s appeal memorandum including, public safety, aesthetic impact, coverage goals and method to meet such needs, and aesthetic and property value concerns, as more specifically outlined in the Applicant Response which is included as Attachment C. It is important to note that the Applicant has claimed that it has met the Town’s Code requirements and is entitled to approval under the Town’s Code, a conclusion also reached by the Planning and Economic Development Commission in its decision. If Council agrees, there is no need to consider any arguments about effective prohibition claims made by the Appellants or the Applicant. Applicant further argues that even if Council has a basis to deny the application under its Code, it cannot do so because a denial would be an illegal prohibition of wireless service in violation of federal law. To support an effective prohibition claim (if necessary), Applicant has provided documentation 9 Subsection 17.52.280F.2 provides in full: “Sites for cellular wireless communications facilities shall be selected according to the following order of preference: a. On or within existing structures (e.g., church steeple, roof top stairwell or equipment enclosures, etc.). b. Co-location facilities (i.e., locating equipment from more than one provider on a single facility). c. In locations where existing topography, vegetation, or other structures provide the greatest amount of screening. d. On parcels which will not require significant visual mitigation.”

9 identifying what it claims is a significant gap in service and alleging the proposed facility is the least intrusive, feasible means of filling that gap.

PROJECT PROPOSAL:

Project Summary
The proposed project is an 80-foot tall “stealth monopine” cell tower located at 1574 Old Mammoth Road on a 0.91-acre parcel in the Resort (R) zoning district that is also occupied by Mammoth Lakes Fire Protection District Station #2. The proposed cell tower is intended to improve cellular service in an area that currently has poor service and also improve emergency communications for the Fire District and other first responders. The tower will initially be used by AT&T and based on size, there is a potential for another service provider to collocate their equipment on the tower through approval of a sequential use permit at some time in the future. A rendering of the proposed monopine can be seen in Figure 1. See Attachment D-1 for the project plans.

The applicant’s site selection process focused on the Old Mammoth area due to an apparent gap in the acceptable level of cell service in that area of the community. Through a review of the existing AT&T network of towers, the applicant determined that modifications to those existing towers (e.g., increase in height, equipment upgrades, additional antennas) would not provide the necessary coverage for the area, and that the best solution to providing adequate coverage in the area was the installation of a new tower in the Old Mammoth area. According to the applicant, the topography and development pattern (i.e., primarily residentially zoned) of the Old Mammoth area presents challenging circumstances to finding a suitable location for a tower and the applicant analyzed other potential sites in the area (i.e., those with suitable zoning or land uses). Along with the proposed cell tower location at 1574 Old Mammoth Road, two other sites in the vicinity were considered by the applicant. Per the ‘Technical Siting Analysis’ (see Attachment D5) included in the application, the other sites considered were adjacent to the proposed site to the west and south and included the Snowcreek Athletic Club (51 Club Drive) and the St. Joseph’s Catholic Church (58 Ranch Road). Those two sites were not further pursued or analyzed due to a lack of interest from the property owner (the athletic club owner was not previously interested in hosting a cell tower) or non-compatible zoning designation (the church site is zoned Residential Mult-Family 2 and telecommunication facilities are not a permitted use in that zone), among other reasons as outlined in the Technical Siting Analysis. The proposed location allows for the coverage objectives to be met (i.e., provide dependable connectivity for stationary and in-building coverage), as shown in the propagation maps included in Attachment D-3.

The tower height of 80 feet was determined to be the minimum height necessary to achieve the desired coverage objectives, whereas per the attached propagation maps in Attachment D-3, a tower height of 65 feet or 35 feet would decrease the coverage area, especially for in-building coverage. The proposed antennas will be located at 74 feet, but a total tower height of 80 feet is needed in order to create the cone shaped treetop that is intended to mimic a pine tree. Per the applicant, the proposed faux pine tree design is intended to be the least intrusive means of providing coverage in the area and that design was chosen to

10 blend in with the surrounding pine trees on the site. The surrounding pine trees have an approximate average height of 55-65 feet.

As described in this report, staff finds the project consistent with the Town’s General Plan and Municipal Code. Additionally, staff determined the project to be categorically exempt from the California Environmental Quality Act (CEQA), pursuant to Section 15303, New Construction or Conversion of Small Structures.

Based on analysis, staff has determined that the required findings to support the requested approval can be made under the Code without the need to consider the Applicant’s effective prohibition claim and recommends approval of the Use Permit with the conditions of approval noted in the attached resolution, Attachment A.

FIGURE 1: PUBLIC VIEW OF PROPOSED MONOPINE FROM OLD MAMMOTH ROAD (ADDITIONAL VIEW RENDERINGS ARE INCLUDED IN ATTACHMENT D-2) Existing Site and Surrounding Land Uses
The project is located at 1574 Old Mammoth Road, which is the location of Mammoth Lakes Fire Protection District Station #2. The 0.91-acre site is in the Resort (R) Zoning District (Snowcreek Master Plan Area). The surrounding land uses consist of Resort Zoned multi-family residential properties to the north, east, and west; Snowcreek Athletic Club to

11 the west; and St. Joseph’s Catholic Church and a single-family residence to the south. See Figure 2 below for a map showing the site location and surrounding context. Table 1 describes the surrounding land uses and zoning.

FIGURE 2: PROJECT LOCATION MAP
Table 1: Surrounding Land Uses and Zoning.

Location Zoning* Land Use Special Considerations
North R Multi-family: 3-unit building Snowceek VII
East R Multi-family: 3-unit building Snowcreek VII
West R Multi-family: 3-unit building and
Snowcreek Athletic Club Snowcreek VII
South RMF-2 Religious Institution and a SingleFamily Residence St. Joseph’s Catholic Church *R = Resort and RMF-2 = Residential Multi-Family 2
Site Zoning
The project site is zoned R (Resort) and is part of the Snowcreek Master Plan Area. The R zone classification allows for various types of land uses such as: residential, professional, and administrative office uses, hotels, recreational facilities, public or quasi-public uses, or combinations of such uses. The R Zoning District lists utilities as a permitted use within

12 the zoning district (Section 17.32.110(B)(4)) and the Master Plan includes an Infrastructure Plan addressing roads, public transportation, water, sewer, and other utilities within the Master Plan Area. The Master Plan does not contain other detailed development standards for telecommunications facilities, and instead relies on the standards specified in the municipal code. Per Section 2.1.1 of the Master Plan, “where the Master Plan is silent on development standards or other regulations, other provisions of the Town’s Municipal Code apply.”
The proposed project is classified as a Telecommunication Facility use and the facility type is considered a Cellular Wireless Communications Facility. This use type is considered a Utility, which is a permitted use type in the R zone. A use permit is required for the proposed facility as a qualifying cellular wireless communications facility in a nonresidential zone per MC Table 17.52.280(C).

Development within the R zone is subject to the development standards found in the applicable master plan (i.e., Snowcreek Master Plan), with additional standards applying to cellular wireless communications facilities found in MC §17.52.280. The proposed project complies with all relevant development standards.

General Plan
The General Plan land use designation for the site is Resort.

ANALYSIS OF KEY ISSUES:

KEY ISSUE #1: Does the proposed project meet the Use Permit criteria and required findings pursuant to Municipal Code (MC) Sections 17.68.050 and 17.52.280? A Use Permit is required for cellular wireless communication facilities. Staff has determined that the required findings can be made for approval of a Use Permit pursuant to MC §17.68.050 (Use Permit Findings) and MC §17.52.280 (Telecommunication Facilities).

The proposed site layout and project design ensure that the cellular wireless communications facility is consistent with all applicable sections of the General Plan and Title 17 (Zoning Code). The proposed use and the conditions under which it will be operated and maintained will not be detrimental to public health and safety nor materially injurious to the properties or improvements in the vicinity.

13 Table 2: Zoning Consistency
General Information
General Plan: Resort (R) Specific Plan: N/A
Zoning: Resort (R) Master Plan: Snowcreek Master Plan
Existing Land Use: Mammoth Lakes Fire
Protection District Station #2 Permit(s) Required for Use: UPA Development Standards
Standard Required Proposed Complies?
Setbacks10
East side yard (feet) 20 feet 20 feet Yes
North Rear yard
(feet)
20 feet 20 feet Yes
Cellular Wireless Communication Facilities (MC §17.52.280) Complies? Site Selection: Sites shall be selected based on the following order:
(1) on or within an existing structure; (2) co-location facilities; (3) in locations where existing topography, vegetation, or other structure provide screening; or (4) on parcels that will not require significant visual mitigation.

Yes (see below)
Location: Facilities shall be located either within a structure, underground, in the rear portion of the property (not visible from the public right-of-way), or on a screened roof top area.

Yes (see below)
Location: Facilities shall not be located in a required parking, maneuvering, or vehicular or pedestrian circulation area.

Yes
Screening: If a new freestanding tower or monopole is necessary for the support of the antennas, it shall be located near existing utility poles, trees, or other similar objects, and consist of colors and materials that best blend with the background.

Yes (see below)
Height: Maximum height is not provided by the zoning code and is to be determined by the Use Permit.

Yes; Determined by the
Use Permit
Height
MC Section 17.52.280 does not establish a maximum height for cellular wireless communications facilities, and instead specifies that the maximum height is to be determined by the use permit. Therefore, the maximum height of the proposed monopine 10 The R zone does not establish setbacks for cellular facilities and the imposed setback standards were instead based off the Public and Quasi-Public (P-QP) zone since that is the zone that most closely matches the use on the site. Per Section 2.1.1 of the Master Plan, “where the Master Plan is silent on development standards or other regulations, other provisions of the Town’s Municipal Code apply.”

14 cell tower is determined by the Use Permit and what is necessary to provide adequate coverage. The height of 80’ was determined to be necessary to provide adequate coverage.

The antennas are located at 74’, but a total height of 80’ is needed in order to create the cone shaped treetop that is aesthetically appropriate. The applicant provided analysis of different heights for the cell tower, which shows that the 80-foot tower is needed to provide the necessary coverage. The analysis is included in Attachment D-3.

Radio Frequency Emissions Exposure
As noted above in Legal Background section above, the Telecommunications Act of 1996 prohibits local agencies from regulating the placement, construction, and modification of cellular wireless communication facilities on the basis of the environmental/health effects of radio frequency (RF) emissions, to the extent that such facilities comply with Federal Communications Commission (FCC) emission standards. The FCC has established maximum permitted exposure (MPE) thresholds to radio frequency emissions, and if the analysis demonstrates that the MPE levels for general population areas are below those thresholds, then local agencies cannot consider those potential effects. For this site, it was determined that the MPE for the adjacent building level at an above ground level (AGL) of 25 feet would be 9.70% of the FCC’s allowable limit for General Population exposure and the MPE for the adjacent building at 45 feet AGL would be 40.30% of the FCC’s allowable limit for General Population exposure. In addition, the report found that the MPE for the ground area immediately beneath the proposed monopine (0’ AGL) would be 4.01% of the FCC’s allowable limit for General Population exposure. Additional information on the radio frequency analysis that was done for the project can be found in the Radio Frequency Safety Survey Report Prediction document, which is included in Attachment D-4.

Site Selection, Location, and Screening
As discussed in Section I above, the site selection process focused on the Old Mammoth area due to an apparent gap in the acceptable level of cell service in that area of the community and the determination that a new tower in the Old Mammoth area was necessary to address this gap in service. When considering potential sites for a cell tower, MC Section 17.52.280(F)(2) specifies the following order of preference for the potential site.
a. On or within existing structures (e.g., church steeple, roof top stairwell or equipment enclosures, etc.);
b. Co-location facilities (i.e., locating equipment from more than one provider on a single facility);
c. In locations where existing topography, vegetation, or other structures provide the greatest amount of screening; or
d. On parcels which will not require significant visual mitigation.

For the Old Mammoth area, criteria (a) and (b) are not feasible since there are no existing structures that could accommodate a cell tower within the Old Mammoth area and there is not an existing cell tower in the area where a new facility could be co-located. Instead, the applicant worked to find a site and design a tower that adhered to criteria (c) and (d). The proposed location on the site is in the rear of the property screened from the public rightPage 19 of 358 15 of-way to the maximum extent possible and will rely on the faux pine tree design to be the least intrusive for the area. That design was chosen to blend in with the surrounding pine trees on the site, which have an approximate average height of 55-65 feet.

General Plan Consistency:

The project is consistent with the following General Plan Vision Statements as described in Table 3:

Table 3: General Plan Vision Statement Conformance
General Plan Vision Statement Explanation of Project Conformance “being a great place to live and work” The project will improve cell reception in an area of Town that is currently lacking, which will
improve livability and safety in Old Mammoth.

The project is consistent with the following General Plan goals, policies, and actions as described in Table 4:

Table 4: General Plan Conformance with Goals, Policies, and Actions Goal, Policy, or Action Explanation of Project Conformance with Goal, Policy, or Action
E.3.H: Encourage expansion of a progressive
telecommunication and internet communication
infrastructure in the community.

The project will expand and improve
telecommunication infrastructure by expanding
service in an area that has insufficient service.

S.10.C: Coordinate with California Public Utilities
Commission, telecommunication, and internet
service providers to improve resilience and
redundancy of telecommunication and broadband
infrastructure.

Through coordination with telecommunication
service providers, service will be enhanced, which
will allow for emergency use by the Mammoth
Lakes Fire Protection District and other first
responders.

KEY ISSUE #2: Is the proposed project consistent with the California Environmental Quality Act (CEQA)?
Staff has determined that the Project is categorically exempt from the provisions of the California Environmental Quality Act (CEQA) pursuant to CEQA Guidelines Section 15303 (New Construction or Conversion of Small Structures) of Title 14 of the California Code of Regulations. CEQA Guidelines Section 15303 applies to projects that consist of the installation of small new equipment and facilities in small structures, which the State has determined to be a class of projects that will not have a significant effect on the environment. CEQA Guidelines Section 15303 applies to projects that consist of (1) a limited number of new, small facilities or structures; and (2) the installation of small new equipment and facilities in small structures, both of which the State has determined to be a class of projects that will not have a significant effect on the environment. For nonresidential uses, this exemption is generally limited to structures that do not exceed 2500 square feet in floor area. The project involves the construction of a new 80-foot tall “stealth monopine” cell tower located in the rear northeast corner of the Old Mammoth

16 Road Fire Station site at 1574 Old Mammoth Road. The proposed tower and associated equipment enclosures are structures that do not involve significant amounts of hazardous substances and do not exceed a combined 2,500 square feet in floor area, as the project only includes approximately 640 square feet of floor area (cell tower and lease area combined). Additionally, none of the exceptions set forth in CEQA Guidelines Section 15300.2, which would preclude a project from using a categorical exemption, are applicable, as described below:
a. The project is not located in a sensitive environment. The project parcel is located on a fully developed and previously disturbed site that contains existing buildings and paving. Furthermore, the site is not located in an area that would be considered environmentally sensitive, as the site and surrounding parcels are fully developed. b. There are no designated scenic highways adjacent to or near the project site. There are no designated farmland areas within the Town boundaries, thus the site is not identified as farmland by the California Resources Agency as part of the Farmland Mapping and Monitoring Program, is not located on or near Prime Farmland, Unique Farmland, or Farmland of Statewide Importance, and is not subject to any Williamson Act Contracts. Furthermore, no portion of the site is zoned for or developed as forest land or timberland as defined in Public Resources Code §12220(g) and Government Code §4526. There are no known sensitive biological resources in the project vicinity, and the project site is not located within the boundaries of a Habitat Conservation Plan or Natural Community Conservation Plan. The project site is currently developed as a public safety use. No classified or designated mineral deposits of statewide or regional significance are known to occur on the project site. The site is not located within a very high fire hazard severity zone, is not located within a state-designated Alquist-Priolo Fault Hazard Zone, does not have any known active faults crossing the site, and the nearest fault to the project site is approximately 1.5 miles to the northwest. There are no hazardous material sites listed within or near the project site per any of the State and Federal databases. There are no known historical or cultural resources on the site.
c. The cumulative impact from successive projects of the same type in the same place over time will not be significant because at this time, there are no applications or proposals submitted to the Town for additional cell towers to be constructed on the site, and the nearest existing tower is located approximately one mile away. d. Given the location, scope, and purpose of the proposed project, there would be no significant impacts or effects on environmental resources during construction of operation, as the site has been previously developed. It is not anticipated that any unusual circumstances exist on the site that would result in significant impacts or increase the severity of any existing less than significant impacts. e. As stated above in response (a), the project site is not located adjacent to or near a scenic highway. The project location is not identified as a Major View Corridor in the Town’s General Plan and views of the project site are not considered scenic.

17 Therefore, the proposed project would not have a substantial adverse effect on a scenic vista or damage scenic resources within a state scenic highway. f. As stated above in response (a), there are no hazardous materials listed within or near the project site. The project site is not listed on the Hazardous Waste and Substances list maintained by the Town; or the State Water Resources Control Board GeoTracker system which includes leaking underground fuel tank sites and spills, leaks, investigations, and cleanup sites; or the Department of Toxic Substances Control EnviroStar Data Management System which includes CORTESTE sites; or the Environmental Protection Agency’s database of regulated facilities.
g. As stated above in response (a), there are no known historical or cultural resources areas on the site, and therefore, there will not be a substantial adverse change in the significance of an established historical resource as a result of the project.

Therefore, the project is exempt from CEQA pursuant to CEQA Guidelines Section 15061(b)(2) since the project meets the criteria for use of the ‘New Construction or Conversion of Small Structures’ categorical exemption and the application of that categorical exemption is not barred by one of the exceptions set forth in Section 15300.2.

Public Comments and Outreach
A notice of the public hearing including a project description was sent to property owners within 400 feet of the subject property; . A total of 376 property owners were notified. A Public Notice was also published in The Sheet on February 3rd and February 10th.

Staff has received a number of written comments on this project as well as in person comments during the November 8 PEDC meeting. Public comments received prior to publishing the staff report are included in Attachment F, and any additional public comments received will be distributed to the Commission separately. The comments have been reviewed and grouped into general categories as described below. - Comments were received expressing concerns of visual impacts.

The project meets the standards found in Zoning Code Section 17.52.280 (Telecommunication Facilities). These include locating the facility in the rear of the property (not visible from public right-of-way) and screening (i.e., faux pine tree design) to blend the structure into the surroundings. The proposed faux pine tree design is intended to be the least intrusive means of providing coverage in the area and that design was chosen to blend in with the surrounding pine trees on the site. The surrounding pine trees have an approximate average height of 55-65 feet. - Comments were received expressing concerns of health and safety related radio frequency emissions.

As stated previously in this report, pursuant to the Telecommunications Act of 1996, the Town is not able to consider the environmental effects of radio frequency, including health, when regulating the placement of a cell tower provided that the FCC Guidelines for maximum permitted exposure (MPE) to radio frequency emissions are adhered to.

For this site, it was determined that the MPE for the adjacent building level at an above ground level (AGL) of 25 feet would be 9.70% of the FCC’s allowable limit for General

18 Population exposure and the MPE for the adjacent building at 45 feet AGL would be

40.30% of the FCC’s allowable limit for General Population exposure. In addition, the report found that the MPE for the ground area immediately beneath the proposed monopine (0’ AGL) would be 4.01% of the FCC’s allowable limit for General Population exposure. Additional information on the radio frequency analysis that was done for the project can be found in the Radio Frequency Safety Survey Report Prediction document, which is included in Attachment D-4. - Comments were received that other locations should be considered.

AT&T and their consultant, Eukon Group, performed a thorough site analysis and determined Fire Station #2 to be the best site for the monopine cell tower. Other sites that were considered include St. Joseph’s Catholic Church located at 58 Ranch Road and the Snowcreek Athletic Club located at 51 Club Drive. The church site is not a viable location because it is zoned Residential Multi-Family 2, and telecommunication facilities are not permitted in residential zones. The Snowcreek Athletic Club was not pursued due to lack of landlord interest at the time AT&T was conducting their alternative site analysis among other considerations as outlined by the applicant in their technical siting analysis. See Attachment D-5 for additional information on the technical siting analysis.
- Comments were received that the proposed telecommunication facility will impact airplanes and the Mammoth Airport.

In the “Technical Siting Analysis” prepared by AT&T and the Eukon group, AT&T acknowledges that the facility will operate in full compliance with the regulations and licensing requirements of the FCC and Federal Aviation Administration (FAA). - Comments were received that the photo-simulations prepared by the applicant are inaccurate and do not accurately portray the proposed telecommunication facility.

A statement confirming the accuracy of the photo-simulations is included in Attachment D-2. The statement is from the independent contractor that was tasked with producing the photo-simulations on behalf of Eukon Group.

Separately from the public noticing, the Mammoth Lakes Fire Protection District discussed the project at their June 27, 2023, Board of Commissioners meeting. The Fire District made an announcement at the June 7, 2023, Town Council meeting during public comment regarding the upcoming Board meeting on the proposed cell tower project at Fire Station

2. At the meeting, three members of the public were in attendance to ask questions about the project.

Additional outreach was done between the November 8, 2023, PEDC meeting and the February 14, 2024 meeting with the neighboring Creekhouse HOA (Snowcreek VII) to review the proposed project and consider alternatives. At the request of the HOA group, Eukon Group had additional photo-simulations prepared that show the proposed tower from within the Creekhouse development looking to the southeast. Ultimately, no resolution on alternative sites was achieved through the outreach, and the Town proceeded with the rescheduled public hearing in order to meet the applicable FCC shot clock deadline as extended to April 19, 2024 by the tolling agreement executed between the Town and the applicant (see Attachment F)

19 FINANCIAL CONSIDERATIONS:

The appeal application was submitted along with the applicable fee of $1,942.00. Pursuant to M.C. § 17.104.030.F – Refund of Appeal Fees, Appeal fees may be refunded only in the following situations:

1. Upon the conclusion of any appeal, where the Council upholds the appeal and overturns the decision of the review authority, the Council may also authorize the return of all, or a portion of the appeal fees; or

2. Upon the conclusion of any appeal, where the Council denies the appeal but finds that the appellant(s) raised issued of substantial merit, the Council may authorize the return of any portion of the appeal fees deemed just.

ATTACHMENTS:

Attachment A: Town Council Resolution
Attachment B: Appeal
Attachment C: AT&T’s Response
Attachment D - 1: Project Plans
Attachment D – 2: Photo-Simulations
Attachment D – 3: Site Justification Maps
Attachment D – 4: RF Safety Report
Attachment D – 5: Technical Siting Analysis
Attachment E: February 14, 2024 PEDC Resolution
Attachment F: February 14, 2024 PEDC Staff Report and All Attachments

Attachment $
Town Council5HVROXWLRQ

RESOLUTION NO. _________

A RESOLUTION OF THE TOWN COUNCIL OF THE TOWN OF MAMMOTH LAKES AFFIRMING THE PLANNING AND ECONOMIC DEVELOPMENT COMMISSION’S APPROVAL OF USE PERMIT 23-002 FOR THE CONSTRUCTION OF A NEW 80-FOOT TALL MONOPINE CELL TOWER
LOCATED AT 1574 OLD MAMMOTH ROAD
(APN: 040-040-021-000)
WHEREAS, a request for consideration of a Use Permit was filed by the applicant, Eukon Group on behalf of AT&T, to allow an 80-foot tall “stealth monopine” cell tower in accordance with Chapter 17.32 (Special Purpose Zoning Districts), Chapter 17.68 (Use Permits), and Section

17.52.280 (Telecommunications Facilities) of the Town of Mammoth Lakes Municipal Code for property located within the Resort (R) zoning district at 1574 Old Mammoth Road; and WHEREAS, the Planning and Economic Development Commission conducted a duly noticed public hearing for the application request on February 14, 2024, and considered, without limitation:

1. The staff report to the Planning and Economic Development Commission with exhibits;

2. The General Plan, Municipal Code, and associated Land Use Maps;

3. Oral evidence submitted at the hearing;

4. Written evidence submitted at the hearing; and

5. Project plans consisting of:
a. Project Plan Sheets T-1, LS-1, LS-2, and A-1 – A-6 dated January 12, 2024, and received by the Town on January 12, 2024;
b. Photo simulations received by the Town on January 31, 2024; c. Project Narrative dated September 22, 2023;
d. Propagation Package dated November 11, 2022; and
e. Interference Analysis Report dated September 19, 2023. f. Radio Frequency Safety Survey Report Prediction dated January 6, 2023 g. Site Justification Coverage Maps dated January 12, 2024 h. Technical Siting Analysis dated February 8, 2024
WHEREAS, on February 14, 2024, the Planning and Economic Development Commission approved Use Permit 23-002 by a 5-0 vote of the Commission.

WHEREAS, during the 15-day appeal period following the Planning and Economic Development Commission Approval, the Town received an appeal of the Commission’s decision on February 29, 2024; and
WHEREAS, the Town Council conducted a duly noticed public hearing on the appeal of the Commission’s approval of the application request on April 3, 2024, at which time all those desiring to be heard were heard; and

Resolution No. __________

WHEREAS, prior to taking action, the Town has heard, been presented with, reviewed and considered all of the information and data in the administrative record and all oral and written evidence presented to it during all meetings and hearings.

NOW THEREFORE, THE TOWN COUNCIL OF THE TOWN OF MAMMOTH
LAKES DOES RESOLVE, DETERMINE, FIND AND ORDER AS FOLLOWS:

SECTION 1. FINDINGS.

I. CEQA.

The project has been determined to be categorically exempt from the provisions of the California Environmental Quality Act (CEQA) pursuant to CEQA Guidelines Section 15303 (New Construction or Conversion of Small Structures) of Title 14 of the California Code of Regulations. CEQA Guidelines Section 15303 applies to projects that consist of (1) a limited number of new, small facilities or structures; and (2) the installation of small new equipment and facilities in small structures, both of which the State has determined to be a class of projects that will not have a significant effect on the environment. For nonresidential uses, this exemption is generally limited to structures that do not exceed 2500 square feet in floor area. The project involves the construction of a new 80-foot tall “stealth monopine” cell tower located in the rear northeast corner of the Old Mammoth Road Fire Station site at 1574 Old Mammoth Road. The proposed tower and associated equipment enclosures are structures that do not involve significant amounts of hazardous substances and do not exceed a combined 2,500 square feet in floor area, as the project only includes approximately 640 square feet of floor area (cell tower and lease area combined).

Additionally, none of the exceptions set forth in CEQA Guidelines Section 15300.2, which would preclude a project from using a categorical exemption, are applicable, as described below:
a. The project is not located in a sensitive environment. The project parcel is located on a fully developed and previously disturbed site that contains existing buildings and paving. Furthermore, the site is not located in an area that would be considered environmentally sensitive, as the site and surrounding parcels are fully developed.

There are no designated scenic highways adjacent to or near the project site. There are no designated farmland areas within the Town boundaries, thus the site is not identified as farmland by the California Resources Agency as part of the Farmland Mapping and Monitoring Program, is not located on or near Prime Farmland, Unique Farmland, or Farmland of Statewide Importance, and is not subject to any Williamson Act Contracts.

Furthermore, no portion of the site is zoned for or developed as forest land or timberland as defined in Public Resources Code §12220(g) and Government Code §4526. There are no known sensitive biological resources in the project vicinity, and the project site is not located within the boundaries of a Habitat Conservation Plan or Natural Community Conservation Plan. The project site is currently developed as a public safety use. No classified or designated mineral deposits of statewide or regional significance are known to occur on the project site. The site is not located within a very high fire hazard severity zone, is not located within a state-designated Alquist-Priolo Fault Hazard Zone, does not have any known active faults crossing the site, and the nearest fault to the project site is approximately 1.5 miles to the northwest. There are no hazardous material sites listed within or near the project site per any of the State and Federal databases. There are no known historical or cultural resources on the site. b. The cumulative impact from successive projects of the same type in the same place over time will not be significant because at this time there are no applications or

Resolution No. __________

proposals submitted to the Town for additional cell towers to be constructed on the site, and the nearest existing tower is located approximately one mile away. c. Given the location, scope, and purpose of the proposed project, there would be no significant impacts or effects on environmental resources during construction or operation, as the site has been previously developed. It is not anticipated that any unusual circumstances exist on the site that would result in significant impacts or increase the severity of any existing less than significant impacts. d. As stated above in response (a), the project site is not located adjacent to or near a scenic highway. The project location is not identified as a Major View Corridor in the Town’s General Plan and views of the project site are not considered scenic. Therefore, the proposed project would not have a substantial adverse effect on a scenic vista or damage scenic resources within a state scenic highway.
e. As stated above in response (a), there are no hazardous materials listed within or near the project site. The project site is not listed on the Hazardous Waste and Substances list maintained by the Town; or the State Water Resources Control Board GeoTracker system which includes leaking underground fuel tank sites and spills, leaks, investigations, and cleanup sites; or the Department of Toxic Substances Control EnviroStar Data Management System which includes CORTESTE sites; or the Environmental Protection Agency’s database of regulated facilities. f. As stated above in response (a), there are no known historical or cultural resources areas on the site, and therefore, there will not be a substantial adverse change in the significance of an established historical resource as a result of the project.

Therefore, the project is exempt from CEQA pursuant to CEQA Guidelines Section 15061(b)(2) since the project meets the criteria for use of the ‘New Construction or Conversion of Small Structures’ categorical exemption and the application of that categorical exemption is not barred by one of the exceptions set forth in Section 15300.2.

II. MUNICIPAL CODE FINDINGS.

A. FINDINGS FOR USE PERMIT (Municipal Code Section 17.68.050 and 17.52.280)

1. The proposed use is consistent with all applicable sections of the General Plan and Title 17 and is consistent with any applicable specific plan or master plan; The proposed use is a telecommunications facility that requires a Use Permit pursuant to the Town Zoning Code (Title 17). The proposed project is located in the Resort (R) Zoning District and is part of the Snowcreek Master Plan Area. The R zone classification allows for various types of land uses such as: residential, professional and administrative office uses, hotels, recreational facilities, public or quasi-public uses, or combinations of such uses. The Master Plan includes an Infrastructure Plan addressing roads, public transportation, water, sewer, and other utilities within the Master Plan Area. Section 7.2.6 (Utilities) requires that all utility facilities and equipment be installed pursuant to the requirements of the relevant utility companies and be placed underground. However, the Master Plan also recognizes that some utility facilities and equipment are required to be above ground, and in such circumstances those above ground utility facilities must be screened with landscaping elements when necessary. The proposed telecommunications facility is a utility facility that is required to be aboveground to operate and is designed as a monopine for screening purposes, consistent with Section 7.2.6 of the Master Plan. The Master Plan does not contain

Resolution No. __________

other detailed development standards for telecommunications facilities, and instead relies on the standards specified in the municipal code.

The R Zoning District lists utilities as a permitted use within the zoning district (Section 17.32.110(B)(4)). The proposed project is consistent with the standards of the R zone. Section 17.52.280 (Telecommunications Facilities) of the Town’s Zoning Code requires a use permit for the proposed facility as a qualifying cellular wireless communications facilities in a nonresidential zone. The R zone and the Town’s Telecommunication Facility standards do not establish a maximum height for cellular facilities, and instead are determined through the use permit process. For this project, the maximum tower height was established through site analysis and testing completed by AT&T and the Fire District which determined that an antenna height of at least 70 feet was necessary to fill the cellular coverage gap in the area. Additionally, the R zone does not establish setbacks for cellular facilities and the imposed setback standards were instead based off the Public and Quasi-Public (P-QP) zone since that is the zone that most closely matches the use on the site. Per Section 2.1.1 of the Master Plan, “where the Master Plan is silent on development standards or other regulations, other provisions of the Town’s Municipal Code apply.”
The project is consistent with the General Plan, including, but not limited to, General Plan Economy Policy E.3.H which states, “Encourage expansion of a progressive telecommunication and internet communication infrastructure in the community” and General Plan Public Health and Safety Policy S.10.C which states, “Coordinate with California Public Utilities Commission (CPUC), telecommunication, and internet service providers to improve resilience and redundancy of telecommunication and broadband infrastructure.”

2. The proposed use and the conditions under which it would be operated or maintained will not be detrimental to the public health and safety nor materially injurious to properties or improvements in the vicinity; and The site layout and project design ensure that the project will not be detrimental to the health and safety of the surrounding community nor injurious to properties or improvements in the vicinity since the project adheres to the Town’s requirements for telecommunications facilities. The project is likely to substantially improve cell service in an area of Town that does not currently provide adequate levels of service, thus increasing safety in the area. Pursuant to Section 332(c)(7)(B)(iv) of the Telecommunications Act of 1996, the Town is prohibited from denying a telecommunications facility application based on concerns about radio frequency emissions so long as the applicant has demonstrated that its proposed facilities will comply with FCC Standards for maximum permitted exposure (MPE) for radio frequency emissions. For this site, the applicant has provided a report certifying that that the proposed facility will be in compliance with all FCC Standards. Specifically the report found that the MPE for the adjacent building level at an above ground level (AGL) of 25 feet would be 9.70% of the FCC’s allowable limit for General Population exposure and the MPE for the adjacent building at 45 feet AGL would be 40.30% of the FCC’s allowable limit for General Population exposure. In addition, the report found that the MPE for the ground area immediately beneath the proposed monopine (0’ AGL) would be 4.01% of the FCC’s allowable limit for General Population exposure.

Resolution No. __________

SECTION 2. TOWN COUNCIL ACTIONS.

The Town Council hereby takes the following actions:

1. Determines that substantial evidence exists to support the Planning and Economic Development Commission’s approval of Use Permit 23-002; and

2. Finds that this project is categorically exempt pursuant to Section 15303, New Construction or Conversion of Small Structures, of the California Environmental Quality Act (CEQA) Guidelines; and

3. Affirms the Planning and Economic Development Commission’s approval of Use Permit 23-002 subject to the following conditions, and denies the appeal:
(SEE EXHIBIT “A”); and

4. Directs staff to file and post a Notice of Exemption with the Office of Planning and Research and the County Clerk.

PASSED AND ADOPTED this 3rd day of April 2024, by the following vote, to wit:

BILL SAUSER
MAYOR
ATTEST:

JAMIE GRAY

TOWN CLERK

Resolution No. __________

APPLICANT:

I, Tayiika Logan Burks, an authorized representative for AT&T, the applicant, do hereby attest that I have read, and agree to, the conditions of approval stipulated within this Resolution. _______________________________ Date: ________________
Tayiika Logan Burks
(Notary Required)

CALIFORNIA ALL-PURPOSE ACKNOWLEDGMENT
A notary public or other officer completing this certificate verifies only the identity of the individual who signed the document, to which this certificate is attached, and not the truthfulness, accuracy, or validity of that document.

State of California
County of Mono }
On , before me, , Notary
Public, personally appeared , who
proved to me on the basis of satisfactory evidence to be the person(s) whose name(s) is/are subscribed to the within instrument and acknowledged to me that he/she/they executed the same in his/her/their authorized capacity(ies), and that by his/her/their signature(s) on the instrument the person(s), or the entity upon behalf of which the person(s) acted, executed the instrument.

I certify under PENALTY OF PERJURY under the laws of the State of California that the foregoing paragraph is true and correct.

WITNESS my hand and official seal.
_
Signature of Notary

Resolution No. __________

PROPERTY OWNER:

I, Ales Tomaier, an authorized representative for the Mammoth Lakes Fire Protection District, the property owner, do hereby attest that I have read, and agree to, the conditions of approval stipulated within this Resolution.
_______________________________ Date: ________________
Ales Tomaier
(Notary Required)

CALIFORNIA ALL-PURPOSE ACKNOWLEDGMENT
A notary public or other officer completing this certificate verifies only the identity of the individual who signed the document, to which this certificate is attached, and not the truthfulness, accuracy, or validity of that document.

State of California
County of Mono }
On , before me, , Notary
Public, personally appeared , who
proved to me on the basis of satisfactory evidence to be the person(s) whose name(s) is/are subscribed to the within instrument and acknowledged to me that he/she/they executed the same in his/her/their authorized capacity(ies), and that by his/her/their signature(s) on the instrument the person(s), or the entity upon behalf of which the person(s) acted, executed the instrument.

I certify under PENALTY OF PERJURY under the laws of the State of California that the foregoing paragraph is true and correct.

WITNESS my hand and official seal.
_
Signature of Notary

Resolution No. __________

EXHIBIT “A”
Resolution No. ________
Case No. UPA 23-002

PLANNING DIVISION CONDITIONS

STANDARD PLANNING CONDITIONS

1. This approval authorizes the following: construction of an 80 foot tall “stealth monopine” cell tower on the 0.91-acre parcel identified as Assessor Parcel No. 040-040-021-000 as shown on Project Plan Sheets T-1, LS-1, LS-2, and A-1 – A-6 dated January 12, 2024.

2. The approved site and building plans including Sheets T-1, LS-1, LS-2, and A-1 – A-6 dated January 12, 2024; shall be adhered to and maintained for the duration of the permit.

3. This permit and all rights hereunder shall automatically terminate unless the site preparation or construction has been commenced within two years after the issuance of this permit and such work is diligently carried on until completion, or an extension of time has been granted in accordance with Municipal Code §17.60.060.B.

4. All new improvements constructed on the site shall be in compliance with all Town of Mammoth Lakes, County of Mono, Mammoth Community Water District, the Mammoth Lakes Fire Protection District, the CRWQCB Lahontan District, Great Basin Air Pollution Control District, OSHA, State of California and United States of America laws, statutes, ordinances, regulations, directives, orders, and the like applicable thereto and in force at the time thereof. Any violation of the above may constitute grounds for revocation under Chapter 17.128 of the Mammoth Lakes Municipal Code.

5. This resolution of approval, as conditioned herein, shall be recorded for the subject property by the Mono County Recorder’s Office to commence the approved use on the property or the issuance of any building permits for new or remodeled structures.

6. The site shall be maintained in a neat, clean and orderly manner. All improvements shall be maintained in a condition of good repair and appearance. Outdoor storage of equipment and other materials, except for firewood, is prohibited. Non-operating vehicles, equipment and materials inappropriate to the site and its use shall not be stored within outdoor areas on the site.

7. Storage of construction materials and equipment off-site shall not be permitted without a permit issued by the Community and Economic Development Department of the Town.

Any public or private property altered, damaged or destroyed by site preparation, grading, construction or use shall be restored to its pre-existing condition by the permittee.

8. All conditions of this permit shall be met or secured prior to final occupancy approval of any tenant improvements or new structures.

9. All uses are subject to review by the Building Official of the Town of Mammoth Lakes and must conform to occupancy ratings of the structures to obtain occupancy.

10. Town staff shall have the right to enter the subject property to verify compliance with these conditions. The holder of any permit associated with this project shall make the premises available to Town staff during regular business hours and shall, upon request make records and documents available to Town staff as necessary to evidence compliance with the terms and conditions of this permit.

Resolution No. __________

11. Prior to the issuance of a building permit, the applicant shall pay all applicable fees as prescribed by ordinance and/or resolution and pay any fees due on this project processing account.

12. Where compliance with the conditions of approval or applicant initiated changes to the plans require additional staff review, that review time shall be billed at the Town’s established billing rates. Prior to the issuance of a building or grading permit, the applicant shall pay all outstanding costs for the processing of this application.

13. The approved site and building plans shall be adhered to and maintained for the duration of the permit.

14. Prior to issuance of a grading or building permit, the applicant shall obtain a secondary source permit or letter of exemption from the Great Basin Unified Air Pollution Control District.

15. The applicant shall defend, indemnify, and hold harmless the Town and its agents, officers, and employees from any claim, action, or proceeding against the Town and its agents, officers, or employees to attack, set aside, void, or annul, an approval of the Town, advisory agency, appeal board, or legislative body concerning this approval. The Town shall promptly notify the applicant of any claim, action, or proceeding and shall cooperate fully in the defense.

16. To the extent permitted by federal law, all exterior lighting shall comply with Chapter

17.36.030 of the Town of Mammoth Lakes Municipal Code, Exterior Lighting. Exterior light fixtures having a total of over 400 lumens of output shall be equipped with shields that extend below the horizontal plane of the light source to direct the light downward onto the structure or surrounding grounds. Accent lighting is permitted as described in Municipal Code Section 17.36.030.F.6. This shall be verified prior to issuance of a certificate of occupancy.

17. If the aggregate landscaped area exceeds 500 sq. ft., a landscape documentation package shall be required prior to issuance of a certificate of occupancy. Said landscape documentation package shall conform with the requirements identified in Municipal Code Chapter 17.40 (Water Efficient Landscape Regulations). The aggregate landscape area is defined as the total horizontal surface area dedicated to plant installation and irrigation plus the wet surface of any decorative water features. The landscape area for shrubs and trees shall be determined using the shrub/tree mature growth diameter or drip line. The landscape area does not include footprints of buildings or structures, sidewalks, driveways, parking lots, decks, patios, gravel or stone walks, or other pervious or non-pervious hardscapes outside of planted areas. Landscape area does not include undisturbed areas with established non-irrigated vegetation, or landscaping that is exempt pursuant to Municipal Code Section

17.40.020.D.

If the project qualifies for an exemption from the landscape documentation requirements pursuant to Municipal Code Section 17.40.020.D, the Water Efficient Landscape Ordinance Exemption form shall be completed by the property owner and the completed form shall be submitted to the Town prior to issuance of a certificate of occupancy.

18. A valid building permit and a permit from the Mammoth Lakes Fire Protection District are required before any building can begin on-site.

19. Zoning entitlement conditions of approval shall be printed verbatim on all of the working drawing sets used for issuance of building permits (architectural, structural, electrical, mechanical, and plumbing) and shall be referenced in the index.

20. The Building Division will require that a string line be run between the property monuments on the north (rear property line) and east (east side property line) at the time

Resolution No. __________

of foundation inspection to verify the actual field distance from the structure to the property line. The outside edge of the tower shall not be located closer than 20 feet to any property line.

21. All ground mounted equipment shall be covered with a clear anti-graffiti type material approved by the Director or shall be adequately secured to prevent graffiti.

22. Facilities shall be secured from access to the general public by fencing, or other deterring device or means as the Town may approve or require, so the facility is not an attractive nuisance.

23. The owner or operator of any facility shall submit and maintain current at all times basic contact and site information. The Department shall be notified by the owner or operator within 30 days of any change, including change of the name or legal status of the owner or operator.

24. All communications facilities and related equipment, including lighting, fences, shields, cabinets, and poles shall be maintained in good repair, free from trash, debris, litter, graffiti, and other forms of vandalism. Any damage from any cause shall be repaired as soon as reasonably possible.

25. The Mammoth Lakes Fire Protection District shall ensure that the approved facility is property maintained and guarantee that the facilities are dismantled and removed from the premises and the site reclaimed if it has been inoperative for a one-year period.

26. Each collocation of an additional service provider’s telecommunications facility upon the approved monopine is required to obtain all permits from the Town of Mammoth Lakes as specified by the Town of Mammoth Lakes Municipal Code.

27. The permittee shall be strictly liable for interference caused by its facilities with Town or other governmental emergency communications systems. The permittee shall be responsible for costs for determining the source of the interference, all costs associated with eliminating the interference (including but not limited to filtering, installing cavities, installing directional antennas, powering down systems, and engineering analysis), and all costs arising from third party claims against the Town attributable to the interference.

28. Testing of any equipment shall take place on weekdays only, and only between the hours of 8:30 a.m. and 4:30 p.m., except that testing is prohibited on holidays that fall on a weekday. In addition, testing is prohibited on weekend days.

29. The facility must at all times comply with all applicable health requirements and standards pertaining to radio frequency emissions.

30. The facility shall at all times maintain compliance with FCC regulations and standards governing the environmental effects of radio frequency emissions.

31. Permittee shall keep up-to-date on current information from the FCC in regards to maximum permissible radio frequency exposure levels. In the event that the FCC changes its guidelines for human exposure to radio frequency, permittee shall, within 30 days after any such change, submit to the Planning and Economic Development Director a report prepared by a qualified engineer that demonstrates compliance with such changed guidelines. The Director may, at permittee’s sole cost, retain an independent consultant to evaluate the compliance report and any potential modifications to the permit necessary to conform to the FCC’s guidelines. Failure to submit the compliance report required under this condition, or failure to maintain compliance with the FCC’s guidelines for human exposure to radio frequency at all times shall constitute grounds for permit revocation.

Resolution No. __________

32. The proposed chain link fencing around the equipment shall have a maximum height of six feet and shall be painted or coated in a dark green, brown, or black color.

33. The branch density, color, and final design of the faux monopine shall be reviewed by the Planning and Economic Development Commission Design Committee prior to building permit issuance. The permittee shall install and maintain during the entire duration of the use permit, a sufficient density of faux branches to completely conceal all transmission equipment, antennas, conduits, and wires installed on the monopine.

Final approval of the design shall be made by the Community and Economic Development Director, based on the recommendations of the Design Committee.

34. The Permittee may not maintain lighting on the wireless facility, except as required by state or federal law.

35. The owner, and any future owner, of the monopine tower shall conduct an annual inspection of the tower to ensure that the tower’s appearance is maintained in substantial conformance with the appearance of the tower as originally installed. Any deterioration of the tower’s physical appearance that substantially changes the appearance from what was originally installed shall be remedied by the owner of the tower within 90 days of the annual inspection of the tower.

36. The installation of the facility and the ongoing operation of the facility shall adhere to all Town Noise regulations pursuant to Municipal Code Chapter 8.16.

Attachment B
Appeal

COMMUNITY AND ECONOMIC DEVELOPMENT DEPARTMENT

PLANNING DIVISION
P.O. Box 1609, Mammoth Lakes, CA 93546
Phone: (760) 965-3630 Fax: (760) 934-7493
www.townofmammothlakes.ca.goY ~l",,~
CAI.IPORICIA

APPEAL OF DECISION OF PLANNING AND ECONOMIC DEVELOPMENT COMMISSION (Municipal Code Section 17.104)
This form must be filed within fifteen (15) days of the stated action in order to be valid.

APPLICATION NUMBER APPEALED UPA 23-002 _;__--'------
DATE OF STATED ACTION February 14, 2024
APPELLANT'S NAME Snowcreek VII Condominium Owner's Association ADDRESS P.O. Box 1999/2 Oak Tree Place
APPEAL FEE: See Community and Economic Development Department Fee Schedule Action taken by the Planning and Economic Development Commission which is being appealed: '
./ Approval
./ Approval with Conditions
(Attach a copy of conditions
and indicate those you wish
waived or modified.)
__ Denial
What is being appealed?
Resolution/Decision of Planning Commission on February 14, 2024.

Rationale for Appeal (use additional sheets if necessary):

See attached.

I certify that I am the: _Legal Owner Authorized Legal Agent _Other Interested Party 2/29/24 iJv,Jy l~__fl .

Date Signature of Appelnt

APPEAL OF PEDC DECISION
---------- - - -------

Attachment C
AT&T's Response

Andrew C. Emerson
[email protected]
www.porterwright.com
Porter Wright
Morris & Arthur LLP
41 South High Street
Suites 2800-3200
Columbus, OH 43215
Direct: 614.227.2104
Fax: 614.227.2100
Main: 614.227.2000
www.porterwright.com
porterwrlght

CHICAGO

CINCINNATI

CLEVELAND

COLUMBUS
DAYTON
NAPLES

PITTSBURGH
TAMPA

WASHINGTON, DC
March 22, 2024
Via Electronic Mail [[email protected]]
Jamie Gray, Town Clerk
Town ofMammoth Lakes
437 Old Mammoth Rd., Suite 230
Mammoth Lakes, CA 93546
RE: AT&T Response to Appeal ofPermit No. 211097
1574 Old Mammoth Rd., Mammoth Lakes, CA 93546
APN 040-040-021-000
AT&T Site ID CSL04615
Dear Town Council members:

I write on behalf of New Cingular Wireless PCS, LLC d/b/a AT&T Mobility (AT&T), to respectfully request the Council reject the appeal ofthe Planning and Economic Development Commission’s approval ofAT&T’s Use Permit Application 23-002 to place a stealth mono-pine wireless telecommunications facility (“Proposed Facility”) at the Mammoth Lakes Fire Protection District Station #2. AT&T has a significant gap in wireless service coverage near the Proposed Facility. In addition to providing more robust and competitive wireless services, including significant improvements to 4G LTE service, the Proposed Facility will provide FirstNet services to support critical first responder communications.

AT&T is proposing to place the Proposed Facility in such a way to minimize visual impacts and to address community concerns. Specifically, since its initial submittal, AT&T relocated the Proposed Facility to the back northeast corner ofthe parcel to address concerns raised by some community members and the Town. Federal law requires approval ofAT&T’s application because denial will effectively prohibit AT&T’s ability to provide and improve wireless services in this portion ofthe Town. Thus, AT&T requests the Council deny the appeal and grant AT&T’s application for the Proposed Facility.

AT&T's Proposed Facility
Consistent with the Town’s General Plan and Title 17 ofthe TownCode, AT&T seeks to place an 80 foot tall stealth mono-pine to provide and improve vital wireless services for the Town’s residents, businesses, and visitors. This proposal meets all applicable Town Code requirements in Section 17.68.050 (Use Permit Findings) and Section 17.52.280 (Telecommunication Facilities).

Specifically, the Proposed Facility is a “Cellular Wireless Communications Facility” under the Town Code, thus, it is a “utility” and a permitted use in the Resort Zoning District where the parcel is located. It satisfies all setback standards and, as covered in detail in Resolution No. PEDC 2024-03, meets all

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the site selection, location, screening, height, and radio frequency requirements set for in Town Code Section 17.52.280.

AT&TNeeds the Proposed Facility to Provide and Improve Wireless Services AT&T’s radio frequency engineers have identified a significant gap in wireless service coverage in the Town, including a large area that is roughly bordered by Minaret Road (south ofEvening Star Drive, but north ofRidge Way) to the north with Resort townhomes, the rural residential/residential multi-family zone homes along Woodman Street to the west, the resort, rural residential, and residential single family zoned homes between Woodcrest Trail and the undeveloped area to the south, and the residential/resort zone townhomes and Snowcreek golf course area along (west of) Fairway Drive, to the east. AT&T’s service coverage gap in this area is significant as it includes hundreds oftourist rental/vacation homes and primary residences that are surrounded by mountainous topography. Placing the Proposed Facility as proposed will close AT&T’s significant service coverage gap.

The Proposed Facility will improve critical wireless services to the area, which are desperately needed especially as customers increasingly use their mobile phones as their primary communication devices. In fact, the Center for Disease Control and Prevention studies the extent ofmobile phone use, and recently found that more than 81% ofCalifornia adults, and more than 98% ofCalifornians under age 18, rely exclusively or primarily on wireless communications in their homes.1 Additionally, customers rely on their mobile phones to do much more than just voice communication, including E911 service, video streaming, GPS, Internet access, and texting. In fact, the Federal Communications Commission conservatively estimates that 74% of 911 calls are placed by people using wireless phones.2 In addition, the Proposed Facility is a part of AT&T’s commitment to supporting public safety through its partnership with FirstNet, the federal First Responder Network Authority. Conceived by the 9/11 Commission Report as necessary for first responder communications, Congress created the federal First Responder Network Authority, which selected AT&T to build and manage FirstNet, the first-ever nationwide first-responder wireless network. The Proposed Facility will provide new service on Band 14, which is the nationwide high-quality spectrum set aside by the U.S. government for public safety.

Deployment of FirstNet in the subject area will improve public safety by putting advanced wireless technologies into the hands ofpublic safety agencies and first responders.

AT&T’s service coverage maps in the record depict coverage simulated by a sophisticated, industry-standard wireless network modeling tool. These coverage maps show the Proposed Facility is necessary to provide and improve AT&T’s 4G LTE service coverage in the gap area. The maps identify the gap and AT&T’s specific service objectives and show how the Proposed Facility will meet those objectives. 1 See Wireless Substitution: State-level Estimates from the National Health Interview Survey, 2019, available at hnps://www.cdc.nov/nchs/data/nhis/earlYrelease/Wireless state 202108-508.pdf. 2 See Thirteenth AnnualReport to Congress on State Collection and Distribution of911 and Enhanced 911 Fees and Charges (Dec. 31, 2021), at 12, available at https://www.fcc.gov/sites/default/files/13th-annual-911-fee-report2021.pdf

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AT&T’sAnalysis ofAlternative Sites
AT&T has worked hard to carefully select a location to reduce impacts to the community while maintaining a clear line-of-sight for signals to provide adequate service coverage to the gap area. In the Old Mammoth area, there are no existing structures or other collocations opportunities (Town Code Section

17.52.280(F)(2)(a) and (b)). AT&T thoroughly investigated alternative sites and designs, evaluating numerous properties in the gap area, to make sure that its Proposed Facility is the least intrusive means to close AT&T’s significant service coverage gap. These alternative locations are listed and analyzed in AT&T’s Technical Siting Analysis, dated February 8, 2024, provided as Attachment A. In sum, based on the Town’s zoning code, AT&T examined the limited alternative properties and determined that each alternative was either unavailable, unviable, or no less intrusive than the Proposed Facility for AT&T to feasibly close its significant service coverage gap.

Approval ofAT&T’s Proposal isRequired Under FederalLaw -Effective Prohibition The federal Telecommunications Act of 1996, 47 U.S.C. § 332 (“Act”) provides rights to wireless service providers and establishes limitations upon state and local zoning authorities with respect to applications for permits to construct personal wireless service facilities. The United States Supreme Court has explained that the Act was enacted in part to prioritize and streamline deployment of wireless technologies on a national basis.3
Under the Act, state and local governments are precluded from taking action that would prohibit or have the effect of prohibiting AT&T from providing personal wireless services. Specifically, the Act prohibits a local government from denying an application for a wireless telecommunications facility where doing so would “prohibit or have the effect of prohibiting the provision of personal wireless services.”4 Courts have found an “effective prohibition” exists where a wireless provider demonstrates (1) a significant gap in its wireless service coverage, and (2) that the proposed facility would provide the “least intrusive means” in relation to the land use values embodied in local regulations, to provide the service coverage necessary to fill that gap.5 The burden then shifts to the local government to prove that another alternative is available, technically feasible, and is less intrusive than the proposed facility.6 In addition, the FCC ruled that an effective prohibition occurs whenever the decision of a local government materially inhibits wireless services.7 The FCC explained that the “effective prohibition 3 City ofRancho Palos Verdes v. Abrams, 544 U.S. 113, 115-16 (2005) (“Congress enacted the Telecommunications Act of 1996 (TCA), 110 Stat. 56, to promote competition and higher quality in American telecommunications services and to ‘encourage the rapid deployment of new telecommunications technologies.’ Ibid. One ofthe means by which it sought to accomplish these goals was reduction of the impediments imposed by local governments upon the installation offacilities for wireless communications, such as antenna towers.”). 447 U.S.C. §332(c)(7)(B)(i)(II).
5 See e.g., Metro PCS, Inc. v. City and County ofSan Francisco, 400 F.3d 715, 734-35 (9th Cir. 2005), abrogated on other grounds, T-Mobile South, LLCv. City ofRoswell, 135 S.Ct. 808 (2015); T-Mobile USA, Inc. v. City ofAnacortes, 572 F.3d 987, 995 (9th Cir. 2009); Sprint PCS Assets, LLC v. City ofPalos Verdes Estates, 583 F.3d 716, 726 (9th Cir. 2009).
6 City ofAnacortes, 5T2. F.3d at 998-999.
7 See Accelerating Wireless Broadband Deployment by RemovingBarriers to Infrastructure Investment, Declaratory Ruling and ThirdReport and Order, FCC 18-133 (September 27,2018) ^Infrastructure Order”) at 34-42; see also,

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analysis focuses on the service the provider wishes to provide, incorporating the capabilities and performance characteristics it wishes to employ, including facilities deployment to provide existing services more robustly, or at a better level ofquality, all to offer a more robust and competitive wireless service for the benefit ofthe public.”8 Thus, a local government “could materially inhibit service in numerous ways - not only by rendering a service provider unable to provide existing service in a new geographic area or by restricting the entry of a new provider in providing service in a particular area, but also by materially inhibiting the introduction of new services or the improvement of existing services.”9 The Ninth Circuit upheld the FCC’s material inhibition test for an effective prohibition.10 Here, AT&T has demonstrated its significant service coverage gap and that the Proposed Facility is the least intrusive means to close that gap. AT&T needs to be able to provide reliable in-building service coverage in the gap area.11 AT&T has also demonstrated that no less intrusive locations are available and feasible to close the gap (Attachment A). Appellants have not demonstrated there are any available, feasible, and less intrusive alternatives for which the Town could request AT&T to evaluate. Thus, pursuant to federal law, the appeal must be denied.

There Is No SubstantialEvidence Under FederalLaw To Support theAppeal The Act also provides that the Town may only deny AT&T’s application based on “substantial evidence.”12 The “substantial evidence” requirement means that a local government’s decision must be “authorized by applicable local regulations and supported by a reasonable amount of evidence.”13 In other words, a local government must have specific reasons that are both consistent with the applicable regulations and supported by substantial evidence in the record to deny a permit. In addition, the Act specifically precludes state and local governments from considering any alleged effects ofradio frequency emissions in making decisions as to the siting ofwireless telecommunications facilities “to the extent such facilities comply with the FCC’s regulations concerning such emissions.”14 In the Matter ofCalifornia Payphone Association PetitionforPreemption, Etc., Opinion and Order, FCC 97-251, 12 FCC Red 14191 (July 17, 1997).
8 Infrastructure Order at n. 95.
9 Id. atU 37.
10 See City ofPortland v. United States, 969 F.3d 1020,1034 (9th Cir. 2020), cert, denied, City ofPortland v. United States, 141 S.Ct. 2855 (2021).
11 See AT&T’s standard is to provide reliable in-building service coverage. Courts in the Ninth Circuit and across the country have held the in-building standard is an appropriate benchmark for finding a significant service coverage gap exists. See, e.g., MetroPCS Inc. v. City & Cnty. ofSan Francisco, No. 4:02-cv-03442-PJH, 2006 U.S. Dist. LEXIS 43985, at *10 (N.D. Cal. June 16, 2006) (held that when large “coverage holes” “extend to the interior ofbuildings,” are actionable under the Act); T-Mobile W. Corp. v. City ofHuntington Beach, No. 2:10-cv-02835-CAS (Ex), 2012 U.S. Dist. LEXIS 148170, *11-12 (C.D. Cal. Oct. 10,2012) (held that “providing reliable in-building wireless service ... is essential, and its absence constitutes a significant gap in coverage”). 12 47 U.S.C. § 332(c)(7)(B)(iii).
13 See, e.g., Anacortes, 572 F.3d at 993 (decision denying wireless siting application “is invalid” ifit not supported by its own regulations); Metro PCS, Inc., 400 F.3d at 725. 14 See 47 U.S.C. § 332(c)(7)(B)(iv).

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There is no need to rehash the General Plan, Town Code, and CEQA allegations raised in the appeal, as the Planning & Economic Development Commission Staff Report and Resolution No. PEDC 2024-03 - as well as the Town Attorney and outside counsel reports at the hearing - addressed each in turn.

As noted above, the proposal is consistent with Town’s General Plan and meets all applicable Town Code requirements in Section 17.68.050 (Use Permit Findings) and Section 17.52.280 (Telecommunication Facilities).

Further, it is beyond dispute that the Proposed Facility will operate well below applicable FCC limits. AT&T’s application included a Radio Frequency Electromagnetic Energy Compliance Report prepared by Fox Hill Telecom, Inc., which was certified by a California Registered Professional Engineer.

The report confirms that the Proposed Facility will operate well within (and actually far below) all applicable FCC exposure limits. Given the compliance with the FCC standards, the appeal cannot be granted and AT&T’s application cannot be rejected based on concerns about radio frequency emissions.

As explained above, even if appellants could identify a code-based reason to disfavor AT&T’s Proposed Facility, which they have not, the Town is preempted by the Act from effectively prohibiting wireless services. Moreover, there is no code-based reason that can support denial based on substantial evidence. The information presented in the appeal falls well short ofsubstantial evidence. In fact, it appears as ifthe lengthy “Memorandum in Support of Appeal” document was borrowed from a template offthe web used in otherjurisdictions (see footnote 4’s reference to another provider - Vertical Bridge) but with some local flavor added, which may explain why it confusingly raises issues already thoroughly addressed in the record and approval. Nonetheless, AT&T responds as follows to some ofthe items presented in the appeal:

Public Safety. Remarkably, Appellants assert that the Mammoth Lakes Fire District will not benefit from the Proposed Facility because the District allegedly uses other frequencies than FirstNet. This is incorrect.

The Mammoth Lakes FireDistrict is a customer ofFirstNet and runs all its apparatus on the FirstNetsystem.

ChiefTomaier could not have been clearer in histestimony in support ofthe Propose Facility at the hearing.

Aesthetic Impact. Appellant’s overstate and inappropriately rely on a Second Circuit’s 2005 Omnipoint decision to assert that their private views are substantial evidence to support a denial. At issue is whether the Planning Commission has substantial evidence to make its limited findings under Town’s General Plan and the Town Code requirements in Section 17.68.050 (Use Permit Findings) and Section 17.52.280 (Telecommunication Facilities), not whether the Proposed Facility may impact private views under New York law as in Omnipoint. The relevant town provisions do not require a finding regarding the impact on private view corridors. In fact, Section 17.52.280(F)(3)(a) concerning location for wireless communications facilities states, “Facilities shall be located either within a structure, underground, in the rear portion ofthe property (not visible from the public right-of-way) . . . f (emphasis added) which is exactly what the Proposed Facility is. And unlike the tower in Omnipoint that was 3 times the height ofthe nearest trees, the Proposed Facility is “located near existing . . . trees.. . and consists of colors and materials that best blend with the background.” Section 17.52.280(F)(3)(b).

Significant Service Coverage Gap. Appellants criticize the way in which AT&T proves its service coverage gap and points to AT&T’s website as proofthat a gap does not exist. It is important to understand that service problems can and do occur for customers even in locations where the coverage maps on AT&T’s “Coverage Viewer” website appear to indicate that coverage is available. As the legend to the Coverage Viewer maps indicates, these maps display approximate outdoor coverage. Actual coverage in an area may differ from the website map graphics, and it may be affected by such things as terrain, weather,

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network changes, foliage, buildings, construction, signal strength, high-usage periods, customer equipment, and other factors.15
It is also important to note that the signal losses, slow data rates, and other service problems can and do occur for customers even at times when certain other customers in the same vicinity may not experience any problems on AT&T’s network. These problems can and do occur even when certain customers’ wireless phones indicate coverage bars of signal strength on the handset. The bars of signal strength that individual customers can see on their wireless phones are an imprecise and slow-to-update estimate ofservice quality. In other words, a customer’s wireless phone can show coverage bars ofsignal strength, but that customer will still, at times, be unable to initiate voice calls, complete calls, or download data reliably and without service interruptions due to service quality issues.

To determine where equipment needs to be located for the provisioning ofreliable service in any area, AT&T’s radio frequency engineers rely on far more complex tools and data sources than just signal strength from individual phones. As noted above, AT&T uses industry standard propagation tools to identify the areas in its network where signal strength is too weak to provide reliable in-building service quality. This information is developed from many sources including terrain and clutter databases, which simulate the environment, and propagation models that simulate signal propagation in the presence of terrain and clutter variation. AT&T designs and builds its wireless network to ensure customers receive reliable in-building service quality using the information from these industry standard tools.

Here, AT&T’s service coverage maps in the record show the Proposed Facility is necessary to provide and improve AT&T’s 4G LTE service coverage in the gap area. The maps identify the gap and AT&T’s specific service objectives and show how the Proposed Facility will meet those objectives. It is worth noting that the Town’s regulations do not require an applicant to demonstrate the elements ofa federal claim for effective prohibition as a precondition to approval of a wireless siting application. Thus, even if AT&T had not proven a significant service coverage gap, which is not the case, it would be improper for the Town to grant the appeal on that basis.16
Even though not required by the Town’s regulations, AT&T has overwhelmingly demonstrated it needs the Proposed Facility to close its significant service coverage gap. The new facility will vastly improve wireless voice and data connections, including providing in-building level of service to the gap area, and it will improve wireless services to the broader area. And AT&T’s gap is clearly significant. As the “after” coverage map shows, a very large portion ofthis coverage area will gain new in-building level of wireless service. That area (the new green-shaded area on the coverage maps) includes hundreds of 15 The notice states as follows: “These maps provide a predicted high-level approximation ofwireless coverage.

There are gaps in coverage that are not shown by this high-level approximation. Actual coverage may differ from map graphics and may be affected by terrain, weather, network changes, foliage, buildings, construction, signal strength, high-usage periods, customer equipment, and other factors. AT&T does not guarantee coverage. Our coverage maps are not intended to show actual customer performance on the network or future network needs or build requirements inside or outside ofexisting AT&T coverage areas...(Emphasis added). e.g., Anacortes, 572 F.3d at 993; T-Mobile Cent., LLC v. Unified Gov’t of Wyandotte County, 546 F.3d 1299, 1308-10 (10th Cir. 2008 ) (holding local government lacks substantial evidence in denying wireless siting application for lack ofproof ofa coverage gap or that the proposal is the ‘least intrusive means’; “the Board erred in requiring TMobile to demonstrate that denying the application would have the effect of prohibiting the provision of personal wireless services [because n]o such criterion appeared in the Code”).

Town Clerk

tourist rental/vacation homes and primary residences and well-traveled roads traversing the area. This is no “mere dead spot.”17 It is indeed a significant service coverage gap.

LeastIntrusive Means. The suggestion that AT&T did not search hard enough to find the best available and least intrusive location for the Proposed Facility is not based on the evidence. AT&T worked hard for a long time (approximately 10 years) to find this site and worked with the community and Fire District to identify the best location on the property for the stealth facility. AT&T’s application materials provide a meaningful comparison ofthe limited alternatives based on the zoning code and explain why these other sites are unavailable or unfeasible and, importantly, no less intrusive than the primary site. There is no substantial evidence to support granting the appeal based on AT&T’s site selection.

Aesthetic & Property Values Concerns. Appellants argue that general aesthetic concerns and speculation about diminishing property values as a result of cell towers should provide as basis to grant the appeal. Yet general concerns about aesthetics are insufficient as a matter oflaw to support denying AT&T’s application.

Courts within the Ninth Circuit and elsewhere have long agreed that general concerns about aesthetics and property values do not constitute substantial evidence to support denial of a permit to install a wireless telecommunications facility.18
The information about property values provided by appellants (anecdotal stories by local agents/no impact study ofproperty values from homes near similar cell sites in Mono County) do not support denial.

In fact, those reports make clear these concerns are likely premised on fears about RF emissions. AT&T has demonstrated that the Proposed Facility will comply with the FCC’s RF exposure standards, and so its application, cannot be rejected whether health concerns are raised explicitly or indirectly through some proxy such as property values.19 The lack of evidence on this point is noteworthy not only because real estate market value predictions are so location specific, but also because California realtor groups have conducted studies that show that residential property values are not negatively impacted by proximity to wireless communications towers.20 Because there is no evidence - let alone substantial evidence - to support these general claims, the Town cannot grant the appeal on this basis.

Section 6409. Appellants allege that Section 6409 ofthe Middle Class Tax Relief and Job Creation Act of 2012 provides AT&T with a unilateral right to expand the Proposed Facility. Appellants fail to acknowledge, however, that any enhancement on the Fire District’s land would need to be consistent with the ground lease between AT&T and the Fire District, and the Fire Chiefstated at the Planning Commission hearing that he anticipates Verizon collocating on the Proposed Facility at a lower centerline height. Thus, 17 AT&T’s gap is extensive and must be addressed. It is far larger than “a small residential cul-de-sac” that might not be significant. City ofHuntington Beach, at *19, 23.
18 See, e.g., California RSA No. 4 v. Madera County, 332 F.Supp.2d 1291, 1308-09 (E.D. Cal. 2003) (generalized expressions of concern regarding aesthetics or the effect on property values fail to meet the substantial evidence threshold under the Act) (citing Omnipoint Corp. v. Zoning Hearing Bd., 181 F.3d 403, 409 (3d Cir.1999); Cellular Telephone Co. v. Town ofOysterBay, 166 F.3d 490 (2nd Cir. 1999)). 19 See AT&T Wireless Services ofCalifornia LLC v. City ofCarlsbad, 308 F.Supp.2d 1148, 1159 (S.D. Cal. 2003) (quoting H.R. Conference Report No. 104-458, 201 (1996)) (held “direct or indirect concerns over the health effects ofRF emissions may not serve as substantial evidence to support the denial ofan application”). 20 See Joint Venture Silicon Valley Network, Wireless CommunicationsInitiative Study: Wireless FacilitiesImpact on Property Values (Nov. 2012)(analyzed property values for over 1,600 single-family homes; concluded “It is quite clear from the data that the distance from a wireless facility has no apparent impact on the value or sale price”).

Town Clerk

Appellant’s concerns regarding non-discretionary approvals ofeligible facility requests that do not cause a significant change when modifying an existing site are overstated and misplaced.

Conclusion
AT&T is working diligently to close its existing service coverage gap and improve wireless services in the Town of Mammoth Lakes. AT&T has shown that federal law strongly supports (indeed, requires) approval, and there has been no substantial evidence proffered by appellants on which the Town could deny AT&T’s application. AT&T urges the Council to deny the appeal.

Very truly yours,
Andrew C. Emerson
ACE:mkd
Attachment A: AT&T’s Technical Siting Analysis
CC: Nolan Bobroff [email protected]
Michael Peterka mpeterkaatownofmammothlakes.ca.gov
Ales Tomaier [email protected]

ATTACHMENT A
AT&T lEukon

TECHNICAL SITING ANALYSIS
Proposed Wireless Telecommunications Facility
Project Description
Site Selection
Site Justification
Alternative Site Analysis
Date: 2-8-2024
Jurisdiction: Township of Mammoth Lakes
Site Name: AT&T “CSL04615”
Address: 1574 Old Mammoth Road
Township of Mammoth Lakes, CA 92780
Applicant: AT&T
1452 Edinger Ave
Tustin, CA 92606
Representative: Sonal Thakur
EukonGroup
65 Post, Suite 1000
Irvine, CA 92618
[email protected]
949-557-1616
EukonGroup ■ 65 Post, Suite 1000 • Irvine, CA 92618

AT&T lEukon
Introduction
AT&T requests approval of Wireless Telecommunications Facility (“WTF”) permit for a new wireless telecommunication facility. The proposed facility is located at 1574 Old Mammoth Road. Currently the area is developed with a Township of Mammoth Lakes Fire Department fire station.

AT&T is a telecommunications service provider operating wireless telecommunications sites throughout California and nationwide. AT&T and its affiliates have acquired licenses from the Federal Communications Commission (“FCC”) to provide wireless telecommunication services.

Description of Use
Pursuant to Township of Mammoth Lakes Municipal Code Sec 17.52.280, AT&T has submitted an application for a Wireless Telecommunications Facility Use Permit approval to establish and operate a Wireless Telecommunications Facility (WTF).

AT&T WIRELESS PROPOSES TO CONSTRUCT A WIRELESS INSTALLATION. THE SCOPE WILL CONSIST OF THE FOLLOWING:
• INSTALL (1)80-0" HIGH MONOPINE
• INSTALL (15) AT&T PANEL ANTENNAS
• INSTALL (15) AT&T REMOTE RADIO UNITS (RRUS)
• INSTALL (3) DC9 SURGE SUPPRESSORS
• INSTALL (4)DC12 SURGE SUPPRESSORS
• INSTALL (1) AT&T 4'-O’0 MICROWAVE ANTENNA
• INSTALL 10' x 20' LEASE AREA COMPOUND
• INSTALL (1) POWER PLANT
• INSTALL (1) PURCELL CABINET
• INSTALL (1) 20KW DC POLAR GENERATOR W 125 GAL. FUEL TANK • INSTALL (1) CIENA
• INSTALL (1) TELCO BOX
• INSTALL (1) METER
• INSTALL (1) UTILITY H-FRAME
• REMOVE (1) EXISTING TOWER CONCRETE PAD
Site Selection
Pursuant to the municipal code, AT&T searched the area within the search ring for sites that presented three primary factors. First, the area is analyzed to determine zoning compatibility in a district to allow for the placement of a WTF.

The selection of the proposed site rested on the determination of compatibility with adjacent development and preservation of existing view corridors. Further consideration supporting the proposed location included the availability of adequate space to place the WTF equipment.

The proposed location is in an area that limits the visual impact on adjacent properties and the public traveling along Old Mammoth Road, Club Drive, and Ski Road, yet provides the required performance to close the significant gap in coverage.

EukonGroup • 65 Post, Suite 1000 • Irvine, CA 92618

AT&T ■Eukon
The subject site allows for the proposed project to operate in a manner that precludes adverse impacts to access, path of travel and maintains the current aesthetic condition for the area.

Site Justification
Wireless telecommunication networks operate on a grid system of facilities that establish the functionality and performance of the system. The network is established on a line-ofsight premise that demands each site be situated in a manner that allows adjacent and abutting sites to generate signals that slightly overlap. By establishing this model of network deployment, the objective to provide seamless service is increased.

At this time, AT&T RF engineers have identified a significant gap in the acceptable level of service in the area the proposed project will serve. The network is evaluated continuously in an effort to maintain the standard of service demanded by the public and mandated by governmental regulations. Currently, a significant gap in service exists primarily to the east, south and north of the proposed location. There is also insufficient capacity to provide dependable connectivity for stationary and in-building coverage. This area is comprised of a major highway and medium density residential developments, a church, school and open space. There is existing poor service levels and poor to nonexistent service levels that preclude the required signal strength necessary to establish and maintain in-building service. The proposed facility will upgrade the deficiency within the target area and will fill the significant gap in coverage.

In the absence of the proposed facility, AT&T will be precluded from completing the network deployment and their customers will continue to experience unacceptable levels of service. The detrimental impact may be most pronounced in daily usage and heightened during emergencies and catastrophic events. The system will provide access to “E91T and to first responders during periods that landlines may not be operable.

The project is consistent with the City’s General Plan concerning policies that seek to guarantee the adequate distribution of utility services to the entire community in a manner that is compatible with the character of the City and community. Further, the provision of service of this type supports the City's goal of integrating in a region wide communications network that assists residents and the traveling public in the ability to coordinate with first responders during emergency events or periods of catastrophe.

Project Objectives
To provide coverage in this area of the city, any combination or one of the following reasons may apply. AT&T’s RF Engineering has also submitted coverage maps as part of this application.
• Coverage: No Service in the area (Indoor, Outdoor or Vehicular) and can apply specifically to the type of service provided (Voice or Data - GSM, 3G, 4G).

Specifically, this proposed location addresses the following needs:

EukonGroup • 65 Post, Suite 1000 • Irvine, CA 92618

AT&T ■Eukon
o Urban - Subscriber anticipated to have accessibility to Township of Mammoth Lakes service while even indoors at lower performance levels. o Suburban - Subscriber anticipated to have accessibility to Township of Mammoth Lakes service while in-vehicle.
o Outdoor - Subscriber anticipated to have accessibility to Township of Mammoth Lakes service while outdoors.
• Capacity: Proposed service in surrounding areas is insufficient to meet anticipated demand by customers in and traversing through the area. Furthermore, proposed facilities servicing the surrounding area would be overloaded preventing service, dropped calls or complete denial of service during peak usage hours. • Quality: Township of Mammoth Lakes seeks to improve its wireless services by ensuring sites are located in areas that are expected to produce strong signals for high traffic locations.

Co-Location Statement
AT&T agrees to allow the collocation of other Wireless Carriers on the site, as long as a proposed Carrier’s antennas and equipment do not cause interference with AT&T antenna signal.

Site Maintenance
The site will be periodically visited (typically once a month) for maintenance by AT&T staff.

An emergency number is also provided on site for the reporting of graffiti and vandalism.

FCC Compliance:

Fox Hill Telecom, has analyzed the project and prepared a report that concludes the proposed AT&T site is in compliance with FCC requirements. Additionally, at the direction of the City, Fox Hill also prepared a report to analyze and confirm that AT&T's wireless facility operation would not interfere with any of the existing communications systems that the First Responders use. Fox Hill determined that AT&T’s project does not cause any interference.

AT&T will operate this facility in full compliance with the regulations and licensing requirements of the FCC, Federal Aviation Administration (FAA) and the CPUC, as governed by the Telecommunications Act of 1996, and other applicable laws.

EukonGroup • 65 Post, Suite 1000 • Irvine, CA 92618

AT&T Site ID: CSL04615 - Mammoth Lakes Monopine - Alternative Sites Analysis Mammoth Lakes Zoning
Updated June 2018
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AT&T Site ID: CSL04615 - Mammoth Lakes Monopine - Alternative Sites Analysis The aerial image above shows the location of the current proposed AT&T candidate location, depicted by the teal balloon icon. The blue thumb tacks show the three alternative candidate locations, on the same parcel (Mammoth Lakes Fire Protection District/Fire Station 2) as AT&T's proposed monopine, that were also considered and reviewed. The yellow thumb tacks show alternative candidates, on other parcels, that were also reviewed and considered. The pink balloons show some of the Snowcreek and Creekhouse townhome resort developments, on the parcels adjacent to the alternative candidate parcels. The balloons in red show residential single and multi-family zoned parcels/neighborhoods, where the Town's code prohibits the installation of cellular facilities. These residential zoned parcels and neighborhoods are also where more of the structures are inhabited by occupants who reside in the structures year-round, and use them as their primary homes, as opposed to the townhomes and structures in the Resort zone, which are primarily secondary homes or used for vacation rentals, in comparison.

AT&T Site ID: CSL04615 - Mammoth Lakes Monopine - Alternative Sites Analysis PRIMARY CANDIDATE (1): Fire Station 2 (Teal Marker-AT&T Proposed Monopine) This property is zoned Resort, which is permitted to support cellular wireless towers, with the approval of a CUP. An 80-foot tall, stealth monopine cell tower is proposed at the northeast/rear corner of the Fire Station 2 property, as required by the town's development standards. The wireless tower is located near existing live pine trees, for context, compatibility, camouflaging, and blending with the surrounding environment, as required by the Code's development design standards. The proposed tower is 80 feet in height, to accommodate AT&T's wireless antennas and equipment, to provide the critically needed coverage to this area of Mammoth Lakes, and to also accommodate space for a future wireless carrier to collocate, (below AT&T's equipment) on the same pole, as required by the Code. The wireless tower must "see" and have an unobscured line of sight, over the local topography to provide the effective and much needed coverage to the area. The proposed 80-foot height is the lowest functional height to fill AT&T's service gap in this area of Mammoth Lakes. It is AT&T's understanding that Verizon has already expressed strong interest to the Fire Protection District in collocating on this tower, to also provide much needed coverage to this area of Mammoth Lakes. With the deployment of the AT&T wireless facility at this location, the RF engineers will be able to meet the coverage objectives for this area of the town and strengthen and expand the network. This missing coverage has been severely needed for close to a decade, if not more, especially forthe first responders of this remote and mountainous terrain. As communicated by Mammoth Lakes Fire Chief Ales Tomaier, the need for this coverage has been a high priority and continued concern for first responders in Mammoth Lakes and the larger Mono County area, such that the Mono County Grand Jury recommended that Mono County and the Town of Mammoth Lakes continue to support

AT&T Site ID: CSL04615 - Mammoth Lakes Monopine - Alternative Sites Analysis improvements to needed coverage for cell sites, as part of a unified plan for the entire county. For this reason, first responders in the county as well as Mammoth Lakes Fire have worked hard to develop and deploy the infrastructure needed to protect the public's health, safety, and general welfare. Chief Tomaier has also stated that Mammoth Lakes Fire could also utilize the new AT&T tower to locate some of their equipment in the future.

The top of the telecommunications pole and AT&T's pole mounted antennas and equipment would be at 75 feet. The additional five feet at the top of the pole is to accommodate faux pine branches, which are needed to make the overall monopine as concealed and realistic in form, as possible, to blend with the surrounding environment and live pine trees. The AT&T antennas, radios, and equipment on the monopine will be painted green and screened with faux pine needle socks for additional camouflaging. Without the additional five feet at the top of the pole for the faux branches, the tower would have a flat top, and not have a more realistic pine tree form. The Creekhouse Developer/current HOA President, Chuck Lande, and the HOA's designated Representative, David L. Jordan, asked AT&T to also provide photosims of a 75-foot-tall monopole, with the AT&T equipment, but void of the faux pine branches and pine socks that assist in camouflaging, screening, and blending the tower with the surrounding live pine trees and environment. The photosims of the 80-foot tall monopine and 75-foot-tall monopole were provided.

The proposed 80- foot tall monopine design and location complies with the town's development standards for cellular facilities. The location of the facility on the northeast, rear corner of the Fire Station 2 property allows AT&T to provide First Net coverage to the First Responders, and the critical coverage and signal for the residents, businesses, and tourists in this area of Mammoth Lakes. The associated equipment enclosure for the site is located on the west side of the Fire Station 2 building. Both the location of the equipment enclosure area, and the monopine on the fire station property are very easily accessible, with a clear path of travel, if needed for any AT&T network operations technicians during a routine maintenance visit or an emergency. The path for power and fiber is also very direct and clear. The equipment and tower are situated such that they are out of the way of any vehicular or pedestrian circulation, as required by the town's code, and in optimal locations for providing coverage to the area, while still blending with the surrounding area, land uses and live pine trees. Locating AT&T's cellular facility on the Fire Station property makes the most sense as the property is at a high elevation, has the clear and direct access to the tower and equipment as required by AT&T, and is a use that is consistent and appropriate with the current operations on this Fire Station Facility- responding to emergency calls and ensuring the safety of the residents and visitors of the Mammoth Lakes area. The Mammoth Lakes Fire Department will also have the ability to locate their equipment onto the AT&T monopine in the future. AT&T will be able to provide the town and first responders with the coverage that has been missing in this terrain for many years, for life safety efforts and connectivity in general.

The much-required coverage that AT&T (and a future wireless carrier) will be able to provide once the proposed tower is deployed, will provide first responders like the Mammoth Lakes' Fire and Police Departments with the ability to communicate effectively with one another (First Net- nationwide wireless network for first responders and the extended public safety community), as well as the residents, tourists and businesses in the area, especially during times of extreme weather conditions and emergencies. The reliable and critically needed coverage more this area, provided by a telecommunications tower, is necessary facility for the public, and most compatible and appropriate to the functions and operations of a Fire Station. The tower is more appropriate to be located at the current proposed Fire District location.

The Mammoth Lakes Fire District and the AT&T have already negotiated a lease. With CUP approval and the required city permits, this site could be constructed and go on air in 2024, so that Mammoth Lakes Fire and other first responders in the town can have the critically needed coverage to do their

AT&T Site ID: CSL04615 - Mammoth Lakes Monopine - Alternative Sites Analysis jobs, and to address public safety issues in a timely manner. It is in the best interests of the Town of Mammoth Lakes' general welfare and public safety to have this proposed wireless design and location approved in a timely manner, to avoid further delay of critical coverage being made available.

Zoomed in Aerial View of Alternatives on the Fire Station 2 Property > Alternative A: Fire Protection District Landscape Frontage This is the location AT&T originally proposed to locate their monopine tower. However, the Towne of Mammoth Lakes development standards for cellular wireless require that wireless facility towers are located in the rear portion of the property. As this location was in the front of the Fire Protection District property, the proposed location needed to be moved elsewhere on the Fire Protection District property. This is not a feasible location.

Alternatives B&C
Chuck Lande, President/CEO of Chadmar, the developer of Creekhouse, and David L. Jordan, homeowner in Creekhouse, appointed HOA representative, and President/CEO of SSV Properties, requested to meet, on-site, with Mammoth Lakes’ Community Development Director, Nolan Bobroff and Fire Chief, AlesTomaier.

On December 21,2023, the individuals walked the Fire Protection District property, to discuss alternative locations on the fire district property that the Creekhouse HOA would like explored. The request was to also provide simulations of an 80-foot tall monopine, as well as a 75-foot tall (top of pole steel and antenna equipment)

AT&T Site ID: CSL04615 - Mammoth Lakes Monopine - Alternative Sites Analysis non-stealth monopole, for the locations. Artistic Engineering, a third-party vendor that specializes in Photosimulations prepared the Photosimulations of the Primary candidate location and design, as well as the HOA requested, alternative design and locations on the fire station. These Photosimulations were submitted to the planning department, along with a statement of accuracy, from Artistic Engineering. > Alternative B: At rear of Fire Station building, by the fire engine garage doors and adjacent to the fire training tower.

This was not a feasible alternative for AT&T to locate a non-stealth monopole tower, as there are several manhole covers in this area, whichare likely associated with existing underground utilities. Additionally, this alternative location is located right next to the dual garage doors for the fire truck engines.

Enough clearance from the fire station building's foundation and AT&T's tower caisson would need to be provided. The wireless tower would not only be in the way of the fire engine trucks, but more importantly, would be right next to the fire training tower that would routinely be set on fire fortraining exercises. The proximity of an AT&T tower to this fire training facility puts AT&T's equipment at risk, and is not a viable location for AT&T. > Alternative C: East side Fire building
This was another alternative location the HOA representatives requested AT&T look into. Photosimulations were provided for an 80-foot tall monopine, and 75-foot-tall non-stealth monopole, as requested. The HOA provided no input or comments to the Towne or AT&T, regarding this alternative location, afterthe photosims were requested. However, like AT&T's original Alternative Location A, Alternative Location C is not located near the rear ofthe property, as required in the town's development standards. The current proposed candidate location, therefore, remains the optimal candidate.

AT&T Site ID: CSL04615 - Mammoth Lakes Monopine - Alternative Sites Analysis Alternative 1: St. Peter's Catholic Church (58 Ranch Road, Mammoth Lakes, CA 93546) This property is zoned RMF-2 (Residential Multiple Family 2). The Towne of Mammoth Lakes zoning code prohibits cellular wireless facilities to be located in the residential zones. Therefore, a monopine cell tower is not permitted to be proposed on this property. This is not a viable candidate.

AT&T Site ID: CSL04615 - Mammoth Lakes Monopine - Alternative Sites Analysis Alternative 2: Snowcreek Athletic Club (51 Club Drive, Mammoth Lakes CA) Centered Aerial View of Snowcreek Athletic Club
The Snowcreek Athletic Club is located on a parcel zoned "Resort", west of Club Drive, and north of Old Mammoth Road. It is directly west of the Fire Protection District but sits at lower elevation. If a wireless tower was proposed on the athletic club parcel, per the town's development standards, it would

AT&T Site ID: CSL04615 - Mammoth Lakes Monopine - Alternative Sites Analysis need to be located away from the parcel frontage, and near the rear portion of the property. The code prohibits cellular facilities from locating in required parking, maneuvering, or vehicular/pedestrian circulation areas. Given the use of this property for athletic activities like tennis, swimming, and other activities, locating the tower at this property would be very limited. The cellular tower could not go anywhere in the parking lot. Additionally, to the west of the athletic club building, there are pedestrian walkway paths, leading to the pool and tennis courts. Placing the tower and associated ground equipment in this highly used public pedestrian area is not optimal or desirable.

Locating an 80-foot tall monopine (likely taller due to lower elevation) and associated 200 square foot ground lease area for the required equipment enclosure with an 8-foot-tall chain link fence or CMU wall, would perhaps need to be somewhere near the tennis courts or swimming pool. This location could impact the landlord's pedestrian paths and landscaped areas for his patrons. As there is also more open, public foot traffic for this athletic club use, there are increased concerns of safety with AT&T's equipment. This location also does not provide the most direct, shortest, and clear path of travel to access AT&T's tower and equipment enclosure, like the current Fire Station 2 property does. AT&T's network operations or technicians can more easily access the tower and equipment on the proposed Fire Station 2 property. Additionally, the current proposed location on the Fire Station 2 property has 24/7 fire personnel and security on- site, which also adds another layer of safety that is optimal and best suited for AT&T's.

This Athletic Club location is not optimal or superior to the current proposed candidate at the Fire Protection District property. Locating a monopine tower at this club location locates it where there is a larger volume of public foot traffic, lesser level of equipment security and access for AT&T technicians (in comparison to the Fire Station 2), and less direct access for AT&T's technicians. But locating the AT&T tower on the Snowcreek Athletic Club property also locates the tower closer to the Snowcreek (Phase 4) townhomes to the north, as well as the Aspen Village Apartments immediately west and south of the tennis courts. Proposing the tower on this property simply moves the facility away from the Creekhouse townhomes by the Fire Protection District, and instead moves a tower closer to the Aspen Village Apartments, and the Phase 4 Snowcreek townhomes. This location is not optimal; the Fire Protection District property is still a superior, appropriate, and more preferable candidate. The 80-foot monopine will accommodate AT&T's wireless equipment, as well as allow for the colocation of a future wireless carrier. The Fire District will also have the ability to use the AT&T tower in the future to locate its needed equipment. The much-required coverage that AT&T (and a future wireless carrier) will be able to provide once the proposed tower is deployed, will provide first responders like the Mammoth Lakes' Fire and Police Departments with the ability to communicate effectively with one another, as well as the residents, tourists and businesses in the area, especially during times of extreme weather conditions and emergencies. The reliable and critically needed coverage more this area, provided by a telecommunications tower, is necessary facility for the public, and most compatible and appropriate to the functions and operations of a Fire Station. The tower is more appropriate to be located at the current proposed Fire District location.

AT&T Site ID: CSL04615 - Mammoth Lakes Monopine - Alternative Sites Analysis Alternative 3: Aspen Village Apartments (1700 Old Mammoth Road Trail, Mammoth Lakes) The Aspen Village Apartments is in the Resort zone, and the westerly adjacent parcel to the Snowcreek Athletic Club. The buildings on this parcel are more densely situated, given the apartment uses. The majority of these apartments are more likely to function as the primary residence of renters living in the town year-round, as opposed to rental units for tourists and short-term vacation stays. Additionally, there appears to be no suitable location to situate a monopine tower and associated equipment enclosure area, would be difficult on this parcel, without encroaching into the required parking, or vehicular and pedestrian circulation areas.

AT&T Site ID: CSL04615 - Mammoth Lakes Monopine - Alternative Sites Analysis Alternative 4: Water District
The Water District property is also in the Resort zone, and adjacent to the Aspen Village Apartment buildings, situated to the north, east and the south of the water district parcel. Residential single family area zoned homes are on located on the parcels directly west and northwestofthe water district property.

Residential Multi- Family 1 zoned parcels are also situated along the south side of Old Mammoth Road. The town's code prohibits cellular facilities to be placed on properties with a residential zone designation. Locating a monopine tower here would move the use closer to the residential zone, where a majority of the homes are for primary use, as opposed to units in the resort zones, which are used more as secondary homes and vacation/tourist rentals.

This property is not superior to the current Fire Station 2 location and proposed candidate.

AT&T Site ID: CSL04615 - Mammoth Lakes Monopine - Alternative Sites Analysis Conclusion:

Based on the preceding facts and statements and consistent with the municipal code’s standards for development and operation of WTF’s, AT&T respectfully requests approval of Wireless Use Permit application to construct, operate and maintain a WTF as proposed.

First Responder Network Authority
12201 Sunrise Valley Drive, M/S 243 • Reston, VA 20192 • www.firstnet.gov March 25, 2024
Nolan Bobroff
Community & Economic Development Director
Town of Mammoth Lakes, CA 93546
Ph: (760) 965-3631
Via Email: [email protected]

RE: AT&T MOBILITY - NATIONWIDE PUBLIC SAFETY BROADBAND
NETWORK NEW SITE APPLICATION - CSL04615 - VICINITY OF OLD MAMMOTH ROAD AND CLUB DRIVE, MAMMOTH LAKES, CA 93546
Dear Mr.Bobroff,
Under the Middle Class Tax Relief and Job Creation Act of 2012, Congress established the First Responder Network Authority (FirstNet Authority) and directed it to ensure the building, deployment, and ongoing operation of the Nationwide Public Safety Broadband Network (“FirstNet”), the first nationwide high-speed broadband network dedicated to public safety.1 The FirstNet Authority’s mission is to provide and maintain a single, interoperable platform that consistently satisfies the demanding communications needs of the public safety community in California and across the country. New radio access network (“RAN”) sites are essential to the success of the program and delivering the mission critical coverage public safety needs to communicate and save lives.

This network has been a top priority for first responders and public safety agencies in California and throughout the country, and has been designed based on their specific, expressed needs, with coverage and capacity being paramount. Simply put, coverage enables a first responder to send and receive data, and capacity ensures speed and quality of those communications. New RAN infrastructure connected to FirstNet will improve communication for first responders where that infrastructure has been currently lacking. The FirstNet Authority and our private-sector partner, AT&T, have worked with the California public safety community to identify coverage needs throughout the state to improve emergency communications in everyday use as well as for large-scale emergencies, such as 1 See Title VI of the Middle Class Tax Relief and Job Creation Act of 2012 (P.L. 112-96), https://www.congress.gov/112/bills/hr3630/BILLS-112hr3630enr.pdf

First Responder Network Authority
12201 Sunrise Valley Drive, M/S 243 • Reston, VA 20192 • www.firstnet.gov the past and present wildfires that continue to ravage the state.

In December 2017, Governor Brown opted into the FirstNet Authority plan for RAN deployment in California and thus authorizing construction of the FirstNet network in areas of the state where public safety needs coverage and capacity. By opting-in, the Governor enabled public safety to rapidly access broadband services in California, while also allowing the prompt buildout and deployment of the network which began in March of 2018. His decision also directed the FirstNet Authority to take on all the risks, costs, and responsibilities associated with deploying the network in California for 25 years and take immediate steps to make prioritized services and features available to public safety in the state.

This network not only needs to serve your local community but will also serve the thousands of first responders that have already adopted FirstNet in California that may respond to your next major emergency. The FirstNet Authority requests your consideration in our efforts to build new sites to achieve required coverage and capacity for our vital mission in the service of public safety.

I am your assigned Senior Public Safety Advisor in California and am a retired Chief Fire Officer with extensive fire service, law enforcement, and technical experience. I am available to assist you at any time. I may be reached at [email protected], or (202) 868-7670.

For your reference, attached is additional information about the FirstNet Authority and the network we were entrusted by Congress to establish.

Sincerely,

Kevin R. Nida, Senior Public Safety Advisor
First Responder Network Authority
Attachments:

1. Primer on the FirstNet Authority’s Congressional Mandate to Deploy a Nationwide Public Safety Broadband Network.

2. FirstNet Contractor Officer Letter.

PRIMER ON THE FIRSTNET AUTHORITY’S CONGRESSIONAL MANDATE TO DEPLOY A NATIONWIDE

PUBLIC SAFETY BROADBAND NETWORK
• Top 10 Frequently Asked Questions
(https://firstnet.gov/sites/default/files/TopTenFAQs_190906.pdf) • FirstNet: The Future of Public Safety Communications
(https://firstnet.gov/sites/default/files/Branding_the_Future_of_Public_Safety_Communication s_0.pdf)
• The First Responder Network Authority (FirstNet Authority) was charged by the U.S. Congress to ensure the development, building, and maintenance of a nationwide mobile broadband network dedicated to meeting the needs of the public safety community. Over the past several years, the FirstNet Authority has made great strides toward fulfilling this purpose, including the establishment of a public-private partnership with AT&T, Inc. (AT&T) to deploy the nationwide public safety broadband network across the country and adoption of FirstNet service by hundreds of thousands of public safety professionals. As FirstNet matures and public safety reaps the benefits of a network dedicated to providing them with needed capabilities and features, the FirstNet Authority is focusing on the next stages of fulfilling its mission. The FirstNet Authority is committed to a vision where a dedicated and differentiated broadband communications experience transforms public safety operations to save lives and protect communities. This vision encapsulates the entirety of the “FirstNet Experience” from AT&T’s deployment of the FirstNet network to the FirstNet Authority’s value-adding activities and investments, which make FirstNet different from any other public safety communications experience. Over time, the FirstNet Authority’s work will help enable public safety to communicate in new and ever more useful ways to help transform public safety operations. (First Responder Network Authority Roadmap, at 3, https://firstnet.gov/system/tdf/FirstNet_Roadmap.pdf?file=1&type=node&id=1055&force=0). • As with many bold public policy initiatives, the creation of FirstNet ensued from disaster and tragedy. Although the idea that all first responders across the United States should share one nationwide network existed prior to September 11, 2001, the events of that terrible day inspired collaborative action from public safety and Congress. As Congress directed, FirstNet is working toward the deployment of a single, interoperable platform for public safety communications that will bring dedicated priority wireless broadband services to millions of public safety personnel at the local, state, tribal, and Federal levels. . . . Authorized by Congress in 2012, FirstNet will fulfill a fundamental need of the public safety community and is the last remaining recommendation to be addressed of the 9/11 Commission. FirstNet’s mission is to ensure the deployment, and operation of a nationwide public safety broadband network (network) for public safety entities.

Leveraging Long Term Evolution (LTE)5 technology standards, up to $7 billion in funding from spectrum auctions, and a nationwide license of 20 MHz of radio frequency spectrum, the FirstNet network is intended to dramatically increase the safety and capabilities of all of those who serve in a public safety capacity, and thereby further protect the American people. Public safety, and thus the American people, will benefit from the availability of a dedicated wireless broadband network prioritized for first responders, the economies of scale afforded by a

PRIMER ON THE FIRSTNET AUTHORITY’S CONGRESSIONAL MANDATE TO DEPLOY A NATIONWIDE

PUBLIC SAFETY BROADBAND NETWORK
national, commercial standards-based network, and the force of innovation in applications which to date has only been enjoyed by consumers. (2014 Annual Report to Congress, at 1, https://firstnet.gov/system/tdf/FirstNet_Annual_Report_to_CongressFY_2014.pdf?file=1&type=node&id=644&force=0) • During the events of September 11, 2001 (9/11), first responders could not communicate with each other. Some radios did not work in the high-rise World Trade Center; radio channels were overloaded by the large number of responders trying to communicate; and public safety radio systems operated on various frequencies and were not interoperable. There were also nontechnical issues. Officials struggled to coordinate the multi-agency response, and to maintain command and control of the numerous agencies and responders.

The 9/11 Commission called for the “expedited and increased assignment of radio spectrum for public safety purposes.” Increased spectrum would allow public safety agencies to accommodate an increasing number of users; support interoperability solutions (e.g., shared channels); and leverage new technologies (e.g., live video streams) to enhance response.

In 2012, Congress acted on the recommendation of the 9/11 Commission. In Title VI of the Middle Class Tax Relief and Job Creation Act of 2012 (P.L. 112-96), Congress authorized the Federal Communications Commission (FCC) to allocate additional spectrum for public safety use; established the First Responder Network Authority (FirstNet) and authorized it to enter into a public-private partnership to build a nationwide public safety broadband network; and, provided $7 billion out of revenues from spectrum auctions to build the network….

FirstNet has made progress in implementing the provisions in the act. In March 2017, FirstNet awarded a 25-year, $6.5 billion contract to AT&T to build and maintain the nationwide network for public safety. FirstNet provided AT&T with 20 megahertz (MHz) of broadband spectrum, which AT&T can monetize for public safety and non-public safety use. AT&T is providing FirstNet access to its infrastructure, valued at $180 billion, and $40 billion to maintain and improve the network.

In September 2017, FirstNet/AT&T presented states with plans detailing how the network would be deployed in each state. Governors could opt to have AT&T deploy the network (i.e., opt in), or have the state assume responsibility for the deployment (i.e., opt out). By January 2018, all 50 states and 6 territories opted in. This was viewed as a victory for FirstNet, AT&T, and public safety stakeholders who had long advocated for a nationwide network for public safety. (Congressional Research Service, The First Responder Network (FirstNet) and NextGeneration Communications for Public Safety: Issues for Congress, April 27, 2018, https://crsreports.congress.gov/product/pdf/R/R45179)

May 6, 2020
To Whom It May Concern,
On March 28, 2017, AT&T was awarded the federal government contract to deploy and operate the Nationwide Public Safety Broadband Network (NPSBN), following an open, transparent, and competitive procurement process—as well as consultation with state, local, tribal, and federal stakeholders—consistent with the First Responder Network Authority’s (FirstNet Authority) enabling statute. The NPSBN contract between the FirstNet Authority and AT&T has a period of performance of 25 years from the date awarded.

Per the terms and conditions of the NPSBN contract, and given that all U.S. states and territories and the District of Columbia (states) opted into the FirstNet Authority plan for network deployment, AT&T is responsible for providing a comprehensive network solution to each of the states. This comprehensive network solution includes: the deployment and provisioning of a nationwide Core Network and Radio Access Network equipment and services (e.g., cell sites, backhaul, aggregation, national transport networks and operation centers); a device ecosystem; deployable capabilities; operational and business support systems; an application ecosystem; network services; integration, maintenance, and operational services; and ongoing evolution of these systems required to function fully as an operational wireless 3rd Generation Partnership Project (3GPP) standards-based Long Term Evolution (LTE) NPSBN.

The FirstNet solution provided by AT&T brings Public Safety Entities across the country a dedicated interoperable broadband network with quality of service, priority usage, and preemption. In addition, the NPSBN is physically hardened, as needed, and is resilient, secure, and highly reliable.

Furthermore, the NPSBN provides to public safety agencies local control over prioritization, preemption, provisioning, and reporting.

The NPSBN and associated devices are branded as FirstNet, consistent with applicable laws and regulations. AT&T is responsible for marketing; product management; sales; distribution; customer care; communications; strategic partnership; and network deployment, operation, maintenance, and evolution. However, in accordance with its statutory duties and responsibilities, the FirstNet Authority maintains rigorous oversight of the NPSBN and AT&T’s obligations under the contract.

If you have any questions with regard to this letter, please contact Kimberly Luke at [email protected], 202-868-3683.

Sincerely,
Kimberly Luke, Contracting Officer
First Responder Network Authority
12201 Sunrise Valley Drive, M/S 243 • Reston, VA 20192 • www.firstnet.gov

Attachment D - 5
Technical Siting Analysis

EukonGroup • 65 Post, Suite 1000 • Irvine, CA 92618

TECHNICAL SITING ANALYSIS
Proposed Wireless Telecommunications Facility
Project Description
Site Selection
Site Justification
Alternative Site Analysis
Date: 2-8-2024
Jurisdiction: Township of Mammoth Lakes
Site Name: AT&T “CSL04615”
Address: 1574 Old Mammoth Road
Township of Mammoth Lakes, CA 92780
Applicant: AT&T
1452 Edinger Ave
Tustin, CA 92606
Representative: Sonal Thakur
EukonGroup
65 Post, Suite 1000
Irvine, CA 92618
[email protected]
949-557-1616

EukonGroup • 65 Post, Suite 1000 • Irvine, CA 92618
Introduction
AT&T requests approval of Wireless Telecommunications Facility (“WTF”) permit for a new wireless telecommunication facility. The proposed facility is located at 1574 Old Mammoth Road. Currently the area is developed with a Township of Mammoth Lakes Fire Department fire station.

AT&T is a telecommunications service provider operating wireless telecommunications sites throughout California and nationwide. AT&T and its affiliates have acquired licenses from the Federal Communications Commission (“FCC”) to provide wireless telecommunication services.

Description of Use
Pursuant to Township of Mammoth Lakes Municipal Code Sec 17.52.280, AT&T has submitted an application for a Wireless Telecommunications Facility Use Permit approval to establish and operate a Wireless Telecommunications Facility (WTF).

Site Selection
Pursuant to the municipal code, AT&T searched the area within the search ring for sites that presented three primary factors. First, the area is analyzed to determine zoning compatibility in a district to allow for the placement of a WTF.

The selection of the proposed site rested on the determination of compatibility with adjacent development and preservation of existing view corridors. Further consideration supporting the proposed location included the availability of adequate space to place the WTF equipment.

The proposed location is in an area that limits the visual impact on adjacent properties and the public traveling along Old Mammoth Road, Club Drive, and Ski Road, yet provides the required performance to close the significant gap in coverage.

EukonGroup • 65 Post, Suite 1000 • Irvine, CA 92618
The subject site allows for the proposed project to operate in a manner that precludes adverse impacts to access, path of travel and maintains the current aesthetic condition for the area.

Site Justification
Wireless telecommunication networks operate on a grid system of facilities that establish the functionality and performance of the system. The network is established on a line-ofsight premise that demands each site be situated in a manner that allows adjacent and abutting sites to generate signals that slightly overlap. By establishing this model of network deployment, the objective to provide seamless service is increased.

At this time, AT&T RF engineers have identified a significant gap in the acceptable level of service in the area the proposed project will serve. The network is evaluated continuously in an effort to maintain the standard of service demanded by the public and mandated by governmental regulations. Currently, a significant gap in service exists primarily to the east, south and north of the proposed location. There is also insufficient capacity to provide dependable connectivity for stationary and in-building coverage. This area is comprised of a major highway and medium density residential developments, a church, school and open space. There is existing poor service levels and poor to nonexistent service levels that preclude the required signal strength necessary to establish and maintain in-building service. The proposed facility will upgrade the deficiency within the target area and will fill the significant gap in coverage.

In the absence of the proposed facility, AT&T will be precluded from completing the network deployment and their customers will continue to experience unacceptable levels of service. The detrimental impact may be most pronounced in daily usage and heightened during emergencies and catastrophic events. The system will provide access to “E911” and to first responders during periods that landlines may not be operable.

The project is consistent with the City’s General Plan concerning policies that seek to guarantee the adequate distribution of utility services to the entire community in a manner that is compatible with the character of the City and community. Further, the provision of service of this type supports the City’s goal of integrating in a region wide communications network that assists residents and the traveling public in the ability to coordinate with first responders during emergency events or periods of catastrophe.

Project Objectives
To provide coverage in this area of the city, any combination or one of the following reasons may apply. AT&T’s RF Engineering has also submitted coverage maps as part of this application.
• Coverage: No Service in the area (Indoor, Outdoor or Vehicular) and can apply specifically to the type of service provided (Voice or Data – GSM, 3G, 4G).

Specifically, this proposed location addresses the following needs:

EukonGroup • 65 Post, Suite 1000 • Irvine, CA 92618
o Urban – Subscriber anticipated to have accessibility to Township of Mammoth Lakes service while even indoors at lower performance levels. o Suburban – Subscriber anticipated to have accessibility to Township of Mammoth Lakes service while in-vehicle.
o Outdoor – Subscriber anticipated to have accessibility to Township of Mammoth Lakes service while outdoors.
• Capacity: Proposed service in surrounding areas is insufficient to meet anticipated demand by customers in and traversing through the area. Furthermore, proposed facilities servicing the surrounding area would be overloaded preventing service, dropped calls or complete denial of service during peak usage hours. • Quality: Township of Mammoth Lakes seeks to improve its wireless services by ensuring sites are located in areas that are expected to produce strong signals for high traffic locations.

Co-Location Statement
AT&T agrees to allow the collocation of other Wireless Carriers on the site, as long as a proposed Carrier’s antennas and equipment do not cause interference with AT&T antenna signal.

Site Maintenance
The site will be periodically visited (typically once a month) for maintenance by AT&T staff.

An emergency number is also provided on site for the reporting of graffiti and vandalism.

FCC Compliance:

Fox Hill Telecom, has analyzed the project and prepared a report that concludes the proposed AT&T site is in compliance with FCC requirements. Additionally, at the direction of the City, Fox Hill also prepared a report to analyze and confirm that AT&T’s wireless facility operation would not interfere with any of the existing communications systems that the First Responders use. Fox Hill determined that AT&T’s project does not cause any interference.

AT&T will operate this facility in full compliance with the regulations and licensing requirements of the FCC, Federal Aviation Administration (FAA) and the CPUC, as governed by the Telecommunications Act of 1996, and other applicable laws.

AT&T Site ID: CSL04615 - Mammoth Lakes Monopine - Alternative Sites Analysis

AT&T Site ID: CSL04615 - Mammoth Lakes Monopine - Alternative Sites Analysis The aerial image above shows the location of the current proposed AT&T candidate location, depicted by the teal balloon icon. The blue thumb tacks show the three alternative candidate locations, on the same parcel (Mammoth Lakes Fire Protection District/Fire Station 2) as AT&T’s proposed monopine, that were also considered and reviewed. The yellow thumb tacks show alternative candidates, on other parcels, that were also reviewed and considered. The pink balloons show some of the Snowcreek and Creekhouse townhome resort developments, on the parcels adjacent to the alternative candidate parcels. The balloons in red show residential single and multi-family zoned parcels/neighborhoods, where the Town’s code prohibits the installation of cellular facilities. These residential zoned parcels and neighborhoods are also where more of the structures are inhabited by occupants who reside in the structures year-round, and use them as their primary homes, as opposed to the townhomes and structures in the Resort zone, which are primarily secondary homes or used for vacation rentals, in comparison.

AT&T Site ID: CSL04615 - Mammoth Lakes Monopine - Alternative Sites Analysis • PRIMARY CANDIDATE (1): Fire Station 2 (Teal Marker – AT&T Proposed Monopine) •
This property is zoned Resort, which is permitted to support cellular wireless towers, with the approval of a CUP. An 80-foot tall, stealth monopine cell tower is proposed at the northeast/rear corner of the Fire Station 2 property, as required by the town’s development standards. The wireless tower is located near existing live pine trees, for context, compatibility, camouflaging, and blending with the surrounding environment, as required by the Code’s development design standards. The proposed tower is 80 feet in height, to accommodate AT&T’s wireless antennas and equipment, to provide the critically needed coverage to this area of Mammoth Lakes, and to also accommodate space for a future wireless carrier to collocate, (below AT&T’s equipment) on the same pole, as required by the Code. The wireless tower must “see” and have an unobscured line of sight, over the local topography to provide the effective and much needed coverage to the area. The proposed 80-foot height is the lowest functional height to fill AT&T’s service gap in this area of Mammoth Lakes. It is AT&T’s understanding that Verizon has already expressed strong interest to the Fire Protection District in collocating on this tower, to also provide much needed coverage to this area of Mammoth Lakes. With the deployment of the AT&T wireless facility at this location, the RF engineers will be able to meet the coverage objectives for this area of the town and strengthen and expand the network. This missing coverage has been severely needed for close to a decade, if not more, especially for the first responders of this remote and mountainous terrain. As communicated by Mammoth Lakes Fire Chief Ales Tomaier, the need for this coverage has been a high priority and continued concern for first responders in Mammoth Lakes and the larger Mono County area, such that the Mono County Grand Jury recommended that Mono County and the Town of Mammoth Lakes continue to support

AT&T Site ID: CSL04615 - Mammoth Lakes Monopine - Alternative Sites Analysis improvements to needed coverage for cell sites, as part of a unified plan for the entire county. For this reason, first responders in the county as well as Mammoth Lakes Fire have worked hard to develop and deploy the infrastructure needed to protect the public’s health, safety, and general welfare. Chief Tomaier has also stated that Mammoth Lakes Fire could also utilize the new AT&T tower to locate some of their equipment in the future.

The top of the telecommunications pole and AT&T’s pole mounted antennas and equipment would be at 75 feet. The additional five feet at the top of the pole is to accommodate faux pine branches, which are needed to make the overall monopine as concealed and realistic in form, as possible, to blend with the surrounding environment and live pine trees. The AT&T antennas, radios, and equipment on the monopine will be painted green and screened with faux pine needle socks for additional camouflaging. Without the additional five feet at the top of the pole for the faux branches, the tower would have a flat top, and not have a more realistic pine tree form. The Creekhouse Developer/current HOA President, Chuck Lande, and the HOA’s designated Representative, David L. Jordan, asked AT&T to also provide photosims of a 75-foot-tall monopole, with the AT&T equipment, but void of the faux pine branches and pine socks that assist in camouflaging, screening, and blending the tower with the surrounding live pine trees and environment. The photosims of the 80-foot tall monopine and 75-foot-tall monopole were provided.

The proposed 80- foot tall monopine design and location complies with the town’s development standards for cellular facilities. The location of the facility on the northeast, rear corner of the Fire Station 2 property allows AT&T to provide First Net coverage to the First Responders, and the critical coverage and signal for the residents, businesses, and tourists in this area of Mammoth Lakes. The associated equipment enclosure for the site is located on the west side of the Fire Station 2 building. Both the location of the equipment enclosure area, and the monopine on the fire station property are very easily accessible, with a clear path of travel, if needed for any AT&T network operations technicians during a routine maintenance visit or an emergency. The path for power and fiber is also very direct and clear. The equipment and tower are situated such that they are out of the way of any vehicular or pedestrian circulation, as required by the town’s code, and in optimal locations for providing coverage to the area, while still blending with the surrounding area, land uses and live pine trees. Locating AT&T’s cellular facility on the Fire Station property makes the most sense as the property is at a high elevation, has the clear and direct access to the tower and equipment as required by AT&T, and is a use that is consistent and appropriate with the current operations on this Fire Station Facility- responding to emergency calls and ensuring the safety of the residents and visitors of the Mammoth Lakes area. The Mammoth Lakes Fire Department will also have the ability to locate their equipment onto the AT&T monopine in the future. AT&T will be able to provide the town and first responders with the coverage that has been missing in this terrain for many years, for life safety efforts and connectivity in general.

The much-required coverage that AT&T (and a future wireless carrier) will be able to provide once the proposed tower is deployed, will provide first responders like the Mammoth Lakes’ Fire and Police Departments with the ability to communicate effectively with one another (First Net- nationwide wireless network for first responders and the extended public safety community), as well as the residents, tourists and businesses in the area, especially during times of extreme weather conditions and emergencies. The reliable and critically needed coverage more this area, provided by a telecommunications tower, is necessary facility for the public, and most compatible and appropriate to the functions and operations of a Fire Station. The tower is more appropriate to be located at the current proposed Fire District location.

The Mammoth Lakes Fire District and the AT&T have already negotiated a lease. With CUP approval and the required city permits, this site could be constructed and go on air in 2024, so that Mammoth Lakes Fire and other first responders in the town can have the critically needed coverage to do their

AT&T Site ID: CSL04615 - Mammoth Lakes Monopine - Alternative Sites Analysis jobs, and to address public safety issues in a timely manner. It is in the best interests of the Town of Mammoth Lakes’ general welfare and public safety to have this proposed wireless design and location approved in a timely manner, to avoid further delay of critical coverage being made available.

Zoomed in Aerial View of Alternatives on the Fire Station 2 Property ➢ Alternative A: Fire Protection District Landscape Frontage This is the location AT&T originally proposed to locate their monopine tower. However, the Towne of Mammoth Lakes development standards for cellular wireless require that wireless facility towers are located in the rear portion of the property. As this location was in the front of the Fire Protection District property, the proposed location needed to be moved elsewhere on the Fire Protection District property. This is not a feasible location.

Alternatives B & C
Chuck Lande, President/CEO of Chadmar, the developer of Creekhouse, and David L. Jordan, homeowner in Creekhouse, appointed HOA representative, and President/CEO of SSV Properties, requested to meet, on-site, with Mammoth Lakes’ Community Development Director, Nolan Bobroff and Fire Chief, Ales Tomaier.

On December 21, 2023, the individuals walked the Fire Protection District property, to discuss alternative locations on the fire district property that the Creekhouse HOA would like explored. The request was to also provide simulations of an 80-foot tall monopine, as well as a 75-foottall (top of pole steel and antenna equipment)

AT&T Site ID: CSL04615 - Mammoth Lakes Monopine - Alternative Sites Analysis non-stealth monopole, for the locations. Artistic Engineering, a third-party vendor that specializes in Photosimulations prepared the Photosimulations of the Primary candidate location and design, as well as the HOA requested, alternative design and locations on the fire station. These Photosimulations were submitted to the planning department, along with a statement of accuracy, from Artistic Engineering. ➢ Alternative B: At rear of Fire Station building, by the fire engine garage doors and adjacent to the fire training tower.

This was not a feasible alternative for AT&T to locate a non-stealth monopole tower, as there are several manhole covers in this area, which are likely associated with existing underground utilities. Additionally, this alternative location is located right next to the dual garage doors for the fire truck engines.

Enough clearance from the fire station building’s foundation and AT&T’s tower caisson would need to be provided. The wireless tower would not only be in the way of the fire engine trucks, but more importantly, would be right next to the fire training tower that would routinely be set on fire for training exercises. The proximity of an AT&T tower to this fire training facility puts AT&T’s equipment at risk, and is not a viable location for AT&T. ➢ Alternative C: East side Fire building
This was another alternative location the HOA representatives requested AT&T look into. Photosimulations were provided for an 80-foot tall monopine, and 75-foot-tall non-stealth monopole, as requested. The HOA provided no input or comments to the Towne or AT&T, regarding this alternative location, after the photosims were requested. However, like AT&T’s original Alternative Location A, Alternative Location C is not located near the rear of the property, as required in the town’s development standards. The current proposed candidate location, therefore, remains the optimal candidate.

AT&T Site ID: CSL04615 - Mammoth Lakes Monopine - Alternative Sites Analysis Alternative 1: St. Peter’s Catholic Church (58 Ranch Road, Mammoth Lakes, CA 93546) This property is zoned RMF-2 (Residential Multiple Family 2). The Towne of Mammoth Lakes zoning code prohibits cellular wireless facilities to be located in the residential zones. Therefore, a monopine cell tower is not permitted to be proposed on this property. This is not a viable candidate.

AT&T Site ID: CSL04615 - Mammoth Lakes Monopine - Alternative Sites Analysis • Alternative 2: Snowcreek Athletic Club (51 Club Drive, Mammoth Lakes CA) Centered Aerial View of Snowcreek Athletic Club
The Snowcreek Athletic Club is located on a parcel zoned “Resort”, west of Club Drive, and north of Old Mammoth Road. It is directly west of the Fire Protection District but sits at lower elevation. If a wireless tower was proposed on the athletic club parcel, per the town’s development standards, it would

AT&T Site ID: CSL04615 - Mammoth Lakes Monopine - Alternative Sites Analysis need to be located away from the parcel frontage, and near the rear portion of the property. The code prohibits cellular facilities from locating in required parking, maneuvering, or vehicular/pedestrian circulation areas. Given the use of this property for athletic activities like tennis, swimming, and other activities, locating the tower at this property would be very limited. The cellular tower could not go anywhere in the parking lot. Additionally, to the west of the athletic club building, there are pedestrian walkway paths, leading to the pool and tennis courts. Placing the tower and associated ground equipment in this highly used public pedestrian area is not optimal or desirable.

Locating an 80-foot tall monopine (likely taller due to lower elevation) and associated 200 square foot ground lease area for the required equipment enclosure with an 8-foot-tall chain link fence or CMU wall, would perhaps need to be somewhere near the tennis courts or swimming pool. This location could impact the landlord’s pedestrian paths and landscaped areas for his patrons. As there is also more open, public foot traffic for this athletic club use, there are increased concerns of safety with AT&T’s equipment. This location also does not provide the most direct, shortest, and clear path of travel to access AT&T’s tower and equipment enclosure, like the current Fire Station 2 property does. AT&T’s network operations or technicians can more easily access the tower and equipment on the proposed Fire Station 2 property. Additionally, the current proposed location on the Fire Station 2 property has 24/7 fire personnel and security on- site, which also adds another layer of safety that is optimal and best suited for AT&T’s.

This Athletic Club location is not optimal or superior to the current proposed candidate at the Fire Protection District property. Locating a monopine tower at this club location locates it where there is a larger volume of public foot traffic, lesser level of equipment security and access for AT&T technicians (in comparison to the Fire Station 2), and less direct access for AT&T’s technicians. But locating the AT&T tower on the Snowcreek Athletic Club property also locates the tower closer to the Snowcreek (Phase 4) townhomes to the north, as well as the Aspen Village Apartments immediately west and south of the tennis courts. Proposing the tower on this property simply moves the facility away from the Creekhouse townhomes by the Fire Protection District, and instead moves a tower closer to the Aspen Village Apartments, and the Phase 4 Snowcreek townhomes. This location is not optimal; the Fire Protection District property is still a superior, appropriate, and more preferable candidate. The 80-foot monopine will accommodate AT&T’s wireless equipment, as well as allow for the colocation of a future wireless carrier. The Fire District will also have the ability to use the AT&T tower in the future to locate its needed equipment. The much-required coverage that AT&T (and a future wireless carrier) will be able to provide once the proposed tower is deployed, will provide first responders like the Mammoth Lakes’ Fire and Police Departments with the ability to communicate effectively with one another, as well as the residents, tourists and businesses in the area, especially during times of extreme weather conditions and emergencies. The reliable and critically needed coverage more this area, provided by a telecommunications tower, is necessary facility for the public, and most compatible and appropriate to the functions and operations of a Fire Station. The tower is more appropriate to be located at the current proposed Fire District location.

AT&T Site ID: CSL04615 - Mammoth Lakes Monopine - Alternative Sites Analysis • Alternative 3: Aspen Village Apartments (1700 Old Mammoth Road Trail, Mammoth Lakes) •
The Aspen Village Apartments is in the Resort zone, and the westerly adjacent parcel to the Snowcreek Athletic Club. The buildings on this parcel are more densely situated, given the apartment uses. The majority of these apartments are more likely to function as the primary residence of renters living in the town year-round, as opposed to rental units for tourists and short-term vacation stays. Additionally, there appears to be no suitable location to situate a monopine tower and associated equipment enclosure area, would be difficult on this parcel, without encroaching into the required parking, or vehicular and pedestrian circulation areas.

AT&T Site ID: CSL04615 - Mammoth Lakes Monopine - Alternative Sites Analysis • Alternative 4: Water District
• The Water District property is also in the Resort zone, and adjacent to the Aspen Village Apartment buildings, situated to the north, east and the south of the water district parcel. Residential single family area zoned homes are on located on the parcels directly west and northwest of the water district property.

Residential Multi- Family 1 zoned parcels are also situated along the south side of Old Mammoth Road. The town’s code prohibits cellular facilities to be placed on properties with a residential zone designation. Locating a monopine tower here would move the use closer to the residential zone, where a majority of the homes are for primary use, as opposed to units in the resort zones, which are used more as secondary homes and vacation/tourist rentals.

This property is not superior to the current Fire Station 2 location and proposed candidate.

AT&T Site ID: CSL04615 - Mammoth Lakes Monopine - Alternative Sites Analysis Conclusion:

Based on the preceding facts and statements and consistent with the municipal code’s standards for development and operation of WTF’s, AT&T respectfully requests approval of Wireless Use Permit application to construct, operate and maintain a WTF as proposed.

Attachment D - 1
Project Plans
Note: Full size plans are available online at:

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TITLE SHEET
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REV DATE DESCRIPTION
REVISIONS:
90% ZONING DRAWING
LICENSEE:

PROJECT INFORMATION:

SHEET TITLE:

SHEET NUMBER:
1574 OLD MAMMOTH ROAD
MAMMOTH LAKES, CA 93546
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EUKON AT&T TEMP V2.0
12/02/21
CHECKED BY:

NOT TO BE USED FOR CONSTRUCTION
CSL04615
APPLICANT:

ENGINEER:

Eukon
www.eukongroup.com
65 POST, SUITE 1000
IRVINE, CA 92618
TEL: (949) 553-8566
an SFC Communications, Inc. Company

THIS PAGE CONTAINS CONFIDENTIAL, PROPRIETARY

OR TRADE SECRET INFORMATION EXEMPT FROM
DISCLOSURE UNDER APPLICABLE LAW.
0 01/28/22 100% ZONING DRAWING
1 11/15/22 DRM COMMENTS
2 09/29/23 ZONING COMMENTS
3 01/12/24 ZONING COMMENTS

VICINITY MAP

SITE INFORMATION

PROJECT TEAM
PROJECT: NEW SITE BUILT
LTE-1C/2C/3C/4C/5C/6C/7C+C-BAND
SITE TYPE: MONOPINE
SITE ADDRESS: 1574 OLD MAMMOTH ROAD
MAMMOTH LAKES, CA 93546
SITE NUMBER: CSL04615

GENERAL NOTES
THE FACILITY IS UNMANNED AND NOT FOR HUMAN HABITATION. A TECHNICIAN WILL VISIT THE SITE AS REQUIRED FOR ROUTINE MAINTENANCE. THE PROJECT WILL NOT RESULT IN ANY SIGNIFICANT DISTURBANCE OR EFFECT ON DRAINAGE; NO SANITARY SEWER SERVICE,

POTABLE WATER, OR TRASH DISPOSAL IS REQUIRED AND NO COMMERCIAL SIGNAGE IS PROPOSED.

DRIVING DIRECTIONS
DIRECTIONS FROM AT&T OFFICE:

AERIAL MAP
SITE
PACE#: MRLOS071118
FA#: 11553744
USID: 312847
PROPERTY OWNER:

ADDRESS:

CONTACT:

APPLICANT:ADDRESS:

ZONING JURISDICTION:

LATITUDE (NAD 83):LONGITUDE (NAD 83):

APN #: 040-040-021-000
AT&T
1452 EDINGER AVENUE TUSTIN, CA 92780
GROUND ELEVATION (NAVD 88): 7925.9'
CONSTRUCTION TYPE: V-B
APPLICANT REPRESENTATIVE:ADDRESS:

EUKON GROUP
65 POST SUITE 1000 IRVINE, CA 92618
OCCUPANCY: U
-37° 37' 48.22" N
(37.630061°)
118° 58' 39.98" W
(-118.977772°)
PO BOX 5,MAMMOTH LAKES, CA 76093
AT&T RF ENGINEER:

SITE ACQUISITION MANAGER:PROJECT MANAGER:ZONING VENDOR:A/E MANAGER:LEASING VENDOR:CONSTRUCTION MANAGER:PROPERTY OWNER:

APPROVED BY: INITIALS: DATE:

AT&T OPERATIONS:

THE FOLLOWING PARTIES HEREBY APPROVE AND ACCEPT THESE DOCUMENTS & AUTHORIZE THE SUBCONTRACTOR TO PROCEED WITH THE CONSTRUCTION DESCRIBED HEREIN. ALL DOCUMENTS ARESUBJECT TO REVIEW BY THE LOCAL BUILDING DEPARTMENT & MAY IMPOSE CHANGES OR MODIFICATIONS.

SUBCONTRACTOR SHALL VERIFY ALL PLANS & EXISTING DIMENSIONS & CONDITIONS ON

THE JOB SITE & SHALL IMMEDIATELY NOTIFY THE ENGINEER IN WRITING OF ANY DISCREPANCIES BEFORE PROCEEDING WITH THE WORK OR BE RESPONSIBLE FOR SAME.

DO NOT SCALE DRAWINGS

APPROVALS

SHEET DESCRIPTION
T-1 TITLE SHEET

SHEET INDEX
REV
A-1
32 SITE PLAN
A-2
3 A-3 PROPOSED EQUIPMENT PLAN
3 PROPOSED ANTENNA PLAN/ANTENNA AND RRU SCHEDULEPROPOSED SOUTH ELEVATION LS-1 SITE SURVEY 2

ALL WORK AND MATERIALS SHALL BE PERFORMED AND INSTALLED IN ACCORDANCE

WITH THE CURRENT EDITIONS OF THE FOLLOWING CODES AS ADOPTED BY THE LOCAL GOVERNING AUTHORITIES. NOTHING IN THESE PLANS IS TO BE CONSTRUCTED TO PERMIT WORK NOT CONFORMING TO THESE CODES.

1. 2022 CALIFORNIA ADMINISTRATIVE CODE

2. 2022 CALIFORNIA BUILDING CODE

3. 2022 CALIFORNIA ELECTRIC CODE

4. 2022 CALIFORNIA MECHANICAL CODE

5. 2022 CALIFORNIA PLUMBING CODE6. 2022 CALIFORNIA FIRE CODE

7. ANY LOCAL BUILDING CODE AMENDMENTS TO THE ABOVE

8. CITY/COUNTY ORDINANCES
HANDICAP REQUIREMENTS:FACILITY IS UNMANNED AND NOT FOR HUMAN HABITATION AND IS EXEMPT FROM ACCESSIBILITYREQUIREMENTS IN ACCORDANCE WITH 2022 CALIFORNIA BUILDING CODE SECTION 11B-203.5

ENGINEERING
IF USING 11"X17" PLOT, DRAWINGS WILL BE HALF SCALE

CONSTRUCTION DRAWING
PROJECT MANAGER:

RF ENGINEER:

A&E CONTACT:

AT&T
1452 EDINGER AVENUE, 3RD FLOOR
TUSTIN, CA 92780
CONTACT: SANDEEP MANGAT
PHONE: (530) 540-4201
EMAIL: [email protected]
EUKON
65 POST SUITE 1000
IRVINE, CA 92618
CONTACT: RICH BRUNET
PHONE: (949) 553-8566EMAIL: [email protected]

AT&T MOBILITY, LA MARKET
1452 EDINGER AVENUE, 3RD FLOOR
TUSTIN, CA 92780
CONTACT: TY LOGAN-BURKS
PHONE: (925) 549-4671
EMAIL: [email protected]
CONSTRUCTION:

QUALTEK WIRELESS
10 PASTEUR, SUITE 100
IRVINE, CA 92618
CONTACT: EDDIE HERNANDEZ
PHONE: (951) 529-3949EMAIL: [email protected] 65 POST SUITE 1000
IRVINE, CA 92618
CONTACT: SONAL THAKUR
PHONE: (949) 557-1616EMAIL: [email protected] LEASING: ZONING:

T-1
EUKON
65 POST SUITE 1000
IRVINE, CA 92618
CONTACT: JON SILVA
PHONE: (714) 393-7963
EMAIL: [email protected]
SITE
Call before you dig.

Know what'sbelow.

R

TO OBTAIN LOCATION OF PARTICIPANTS

UNDERGROUND FACILITIES BEFORE

YOU DIG IN CALIFORNIA (SOUTH), CALL

DIG ALERT
TOLL FREE: 1-800-422-4133 OR
www.digalert.org

CALIFORNIA STATUTE
REQUIRES MIN OF 2

WORKING DAYS NOTICE

BEFORE YOU EXCAVATE

1. CONSTRUCTION TO START APPROXIMATELY 30 DAYS AFTER FINAL APPROVALS AND WILL TAKE 2 MONTHS FOR CONSTRUCTION COMPLETION.

2. NO LANDSCAPE IS PROPOSED IN THIS PROJECT.

A-4
2 AT&T WIRELESS PROPOSES TO CONSTRUCT A WIRELESS INSTALLATION. THE SCOPE WILL CONSIST OF THEFOLLOWING:
x INSTALL (1) 80'-0" HIGH MONOPINEx INSTALL (15) AT&T PANEL ANTENNASx INSTALL (15) AT&T REMOTE RADIO UNITS (RRUS)x INSTALL (3) DC9 SURGE SUPPRESSORSx INSTALL (4) DC12 SURGE SUPPRESSORSx INSTALL (1) AT&T 4'-0"Ø MICROWAVE ANTENNAx INSTALL 10' x 20' LEASE AREA COMPOUNDx INSTALL (1) POWER PLANTx INSTALL (1) PURCELL CABINETx INSTALL (1) 20KW DC POLAR GENERATOR w 125 GAL. FUEL TANKx INSTALL (1) CIENAx INSTALL (1) TELCO BOXx INSTALL (1) METER x INSTALL (1) UTILITY H-FRAMEx REMOVE (1) EXISTING TOWER CONCRETE PAD A-5
2 LEASE AREA: 200 SQ. FT.

ENLARGED SITE PLAN

PROJECT DESCRIPTION
1452 EDINGER AVE, TUSTIN, CA 92780
TURN LEFT ONTO EDINGER AVE; USE THE LEFT 2 LANES TO TURN LEFT ONTO DEL AMO AVE; USE THE RIGHT 2 LANES TO TAKE THE RAMP ONTO CA-55 N/STATE RTE 55 N; FOLLOW I-5 N, CA-14 N AND US-395 N TO CA-203 W IN MONO COUNTY; MERGE ONTO CA-55 N/STATE RTE 55 N; TAKE EXIT 10B TO MERGE ONTO I-5 N TOWARD SANTA ANA; KEEP LEFT TO STAY ON I-5 N; KEEP LEFT TO STAY ON I-5 N; KEEP RIGHT TO STAY ON I-5 N; KEEP LEFT TO STAY ON I-5 N; KEEP RIGHT AT THE FORK TO STAY ON I-5 N, FOLLOW SIGNS FOR I-10 W/SANTA MONICA/INTERSTATE 5 N/SACRAMENTO; KEEP LEFT TO STAY ON I-5 N, FOLLOW SIGNS FOR SACRAMENTO; KEEP RIGHT TO CONTINUE ON I-5 N/GOLDEN STATE FWY, FOLLOW SIGNS FOR SACRAMENTO; KEEP LEFT TO CONTINUE ON I-5 N; KEEPLEFT AT THE FORK TO STAY ON I-5 N; USE THE RIGHT 3 LANES TO TAKE EXIT 162 FOR CA-14 N TOWARD PALMDALE/LANCASTER; CONTINUE ONTO CA-14 N; KEEP LEFT TO STAY ON CA-14 N; TURN RIGHT ONTO CA-14 N/MIDLAND TRAIL; CONTINUE TO FOLLOW CA-14 N; CONTINUE ONTO US-395 N; TAKE THE CA-203 EXIT TOWARD MAMMOTH LAKES/DEVILS POSTPILE; TURN LEFT ONTO CA-203 W; TURN LEFT ONTO MERIDIAN BLVD; TURN LEFT ONTO OLD MAMMOTH RD; DESTINATION WILL BE ON THE RIGHT. 3 LS-2 SITE SURVEY
AIR EASEMENT (MONOPINE): 439 SQ. FT.

A-6 PROPOSED WEST ELEVATION 3

TOWN OF

MAMMOTH LAKES

RECEIVED
1/12/2024

FBR FBR
FBR
W
W
SD SD

SD SD SD SD SD
GAS
GAS
GAS
W
W W
W W
SD
SD
SD
SD
SD
SD
SD
SD

E E E E E E E E
O/H
O/H
O/H
O/H
O/H
O/H
O/H
GAS
GAS
GAS
O/H
O/H
O/H
O/H
O/H
O/H
O/H
O/H
O/H
O/H
O/H
O/H
O/H

E E E E E E E E E E E E E E E

E E E E E E
WATER
O/H
O/H
O/H
O/H
O/H
O/H
O/H
G

STORM DRAIN

STORM DRAIN

STORM DRAIN

STORM DRAIN

STORM DRAIN

STORM DRAIN

STORM DRAIN
7925
7924
7923
7924
7926
H Y D
WV
WV

MANHOLE
7925
X
7926
DRAIN E"
DRAIN B"
DRAIN B"
DRAIN E"

E E E E E E E E E
E E
E
PWR
PWR

F/P F/P F/P F/P

F/P F/P
F/P
F/P
F/P
F/P
F/P
X
X
DRAWN BY:

AG
RB

REV DATE DESCRIPTION
REVISIONS:
90% ZONING DRAWING
LICENSEE:

PROJECT INFORMATION:

SHEET TITLE:

SHEET NUMBER:
1574 OLD MAMMOTH ROAD
MAMMOTH LAKES, CA 93546
A
EUKON AT&T TEMP V2.0
12/02/21
CHECKED BY:

NOT TO BE USED

FOR CONSTRUCTION
CSL04615
APPLICANT:

ENGINEER:

Eukon
www.eukongroup.com
65 POST, SUITE 1000
IRVINE, CA 92618
TEL: (949) 553-8566
an SFC Communications, Inc. Company

THIS PAGE CONTAINS CONFIDENTIAL, PROPRIETARY

OR TRADE SECRET INFORMATION EXEMPT FROM
DISCLOSURE UNDER APPLICABLE LAW.
0 01/28/22 100% ZONING DRAWING
1 11/15/22 DRM COMMENTS
2 09/29/23 ZONING COMMENTS
3 01/12/24 ZONING COMMENTS

SITE PLAN
90°
135°
45°
270°
225°
180°
315°
0°
SCALE 20' 10' 0 20' 40' 80'
1"=20'-0" 1

SITE PLAN
A-1
SCALE NOTE:

IF DIMENSIONS SHOWN ON PLAN DO NOT SCALE

CORRECTLY, CHECK FOR REDUCTION OR
ENLARGEMENT FROM ORIGINAL PLANS.

PROPOSED AT&T WORK
AREA. SEE ENLARGED

SITE PLAN

PROPERTY LINE
SECTOR "A"
AZIMUTH: 10°
SECTOR "C"
AZIMUTH: 260°
NOTES:

1. THIS SITE PLAN NOT INTENDED TO BE A SITE SURVEY.
1 A-2
APN: 040-040-021-000

PROPERTY LINE

PROPERTY LINE

PROPERTY LINE

PROPERTY LINE
~EXISTING BUILDING~
SECTOR "B"
AZIMUTH: 130°

EXISTING
FIRE HOUSE ~ ~
12'-0"
12'-0"
24'-0"
0+00.00
EXISTING UTILITYPOLE #4261151E
EXISTING UTILITYPOLE #140457E
EXISTING HANDHOLE EXISTING 750-22,500V

OVER HEAD CONDUCTOR

EXISTING SCE DIST
PULLBOX #5305017
EXISTING 750-22,500VUNDERGROUND CONDUCTOR
EXISTING 750-22,500V

UNDERGROUND CONDUCTOR

EXISTING SCE DIST
PAD #5305018

EXISTING SCE DIST
PAD #5567791
28'-0"
1+00.00
0+00.00
10+00.00
11+00.00
40'-0"
40'-0"

PROPERTY LINE
60'-0"
30'-0"
30'-0"
80'-0"
40'-0" 40'-0"

PROPERTY LINE

PROPERTY LINE

EXISTING ROADWAY
EASEMENT [6] SEE LS-1
14'-0"
PROPOSED 381' SQFT AIR EASEMENT

EXISTING CATV VAULT

EXISTING TELCO PEDESTAL
EXISTING 750-22,500V

OVER HEAD CONDUCTOR
80'-0"

NEW FIBER MMP

HANDHOLE

NEW AT&T UNDERGROUND
FIBER RUN [APPROX. 85'-0"]

NEW AT&T UNDERGROUND POWER
RUN [APPROX. 55'-0"]
EXISTING 750-22,500V

UNDERGROUND CONDUCTOR
EXISTING 750-22,500V

UNDERGROUND CONDUCTOR
EXISTING 750-22,500VUNDERGROUND CONDUCTOR
EXISTING LIGHT POLE, TYP.

EXISTING STORM DRAIN, TYP.

APN: 040-321-004-000
APN: 040-311-007-000
APN: 040-070-025-000
APN: 022-350-013-000
14'-0"

EXISTING CMU RETAINING WALL
APN: 040-321-003-000
APN: 040-321-002-000
APN: 040-040-035-000

PROPERTY LINE

PROPERTY LINE
154'-7"

POLE TO PROPERTY LINE
26'-6"

POLE TO PROPERTY LINE
26'-8"

POLE TO PROPERTY LINE
149'-9"

TO PROPERTY LINE

TO PROPERTY LINE
81'-2"
72'-8"

TO PROPERTY LINE

TO PROPERTY LINE
92'-7"

PROPOSED FIBER/POWER RUN

FROM EQUIPMENT TO TOWER
[APPROX. 255'-0"] WITHIN JOINT

COMMUNITY TRENCH FOR BOTH

AT&T AND FUTURE COLLOCATION

MAMMOTH LAKE FPD TO REMOVE STEEL
CHAIR LIFT TOWER, BEFORE START OFCONSTRUCTION. AT&T GC RESPONSIBLE FOR REMOVING THE ASSOCIATED CHAIR LIFT’S
CONCRETE PAD.
10'-0"
20'-0" PROPOSED AT&T LEASE
AREA (200 SQ. FT.)
193'-6"

POLE TO PROPERTY LINE
20'-0"
TO P. LINE
20'-0"
TO P. LINE

BR
FBR
FBR
FBR
FBR
FBR
FBR
SD
SD
SD
SD
SD
SD
SD
SD
SD
SD
SD
SD
SD
SD
SD
SD
SD
SD
SD
SD
SD
SD
SD
SD
SD
SD
SD
SD
SD
SD
SD
E
E
E
E
E
E
E
E
E
E
E
E

STORM DRAIN

STORM DRAIN

STORM DRAIN

STORM DRAIN

STORM DRAIN

STORM DRAIN

STORM DRAIN
7925
7924
7923 7924
7926
DRAIN E"
DRAIN B"
DRAIN B"
DRAIN E" E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
PWR
PWR
PWR
PWR
PWR
PWR

F/P F/P F/P F/P F/P F/P F/P F/P F/P F/P F/P
F/P
F/P
F/P
F/P
F/P

F/P F/P
F/P
F/P
F/P
F/P
F/P
F/P
F/P
F/P
F/P
F/P
F/P
F/P
F/P
F/P
X
X
X
X
X
X
DRAWN BY:

AG
RB

REV DATE DESCRIPTION
REVISIONS:
90% ZONING DRAWING
LICENSEE:

PROJECT INFORMATION:

SHEET TITLE:

SHEET NUMBER:
1574 OLD MAMMOTH ROAD
MAMMOTH LAKES, CA 93546
A
EUKON AT&T TEMP V2.0
12/02/21
CHECKED BY:

NOT TO BE USED FOR CONSTRUCTION
CSL04615
APPLICANT:

ENGINEER:

Eukon
www.eukongroup.com
65 POST, SUITE 1000
IRVINE, CA 92618
TEL: (949) 553-8566
an SFC Communications, Inc. Company

THIS PAGE CONTAINS CONFIDENTIAL, PROPRIETARY

OR TRADE SECRET INFORMATION EXEMPT FROM
DISCLOSURE UNDER APPLICABLE LAW.
0 01/28/22 100% ZONING DRAWING
1 11/15/22 DRM COMMENTS
2 09/29/23 ZONING COMMENTS
3 01/12/24 ZONING COMMENTS
A-2
SCALE NOTE:

IF DIMENSIONS SHOWN ON PLAN DO NOT SCALE

CORRECTLY, CHECK FOR REDUCTION OR
ENLARGEMENT FROM ORIGINAL PLANS.
90°
135°
45°
270°
225°
180°
315°
0°
SCALE NOTE:

IF DIMENSIONS SHOWN ON PLAN DO NOT SCALE

CORRECTLY, CHECK FOR REDUCTION OR
ENLARGEMENT FROM ORIGINAL PLANS.

NOTE:

1. THIS SITE PLAN NOT INTENDED TO BE A SITE SURVEY.

ENLARGED SITE PLAN 1

PROPOSED AT&T
ANTENNA LOCATION.

SEE ANTENNA PLAN
1 A-4
SECTOR "C" AZIMUTH: 260° SECTOR "B" AZIMUTH: 130°
SECTOR "A" AZIMUTH: 10°

EXISTING OMNI

ANTENNAS

EXISTING ASPHALT

PATCH CENTERLINE

EXISTING PANEL

EXISTING GRATE
PROPOSED AT&T 20kW POLAR DC
GENERATOR w/ 54g DIESEL TANK FOR

EMERGENCY BACK-UP POWER ON

CONCRETE CURB
PROPOSED AT&T 10' WIDE

CHAIN-LINK ACCESS GATE
PROPOSED AT&T 8' TALL

CHAIN-LINK FENCE

EXISTING PAD MOUNTED
TRANSFORMER #P5622796 AND

PROPOSED AT&T POWER POC
NEW ±60' 3" SCE CONDUIT
PROPOSED (2) AT&T

PURCELL CABINET
(STACKED)

PROPOSED AT&T

POWER PLANT

PROPERTY LINE
PROPOSED AT&T 80'-0"

HIGH MONOPINE

NEW AT&T UNDERGROUND
FIBER RUN [APPROX. 85'-0"]
EXISTING 750-22,500VUNDERGROUND CONDUCTOREXISTING LIGHT POLE, TYP.

EXISTING 750-22,500V

UNDERGROUND CONDUCTOR

TO BE RELOCATED AS NEEDED
EXISTING STORM DRAIN, TYP.

EXISTING 750-22,500V

UNDERGROUND CONDUCTOR
~EXISTING BUILDING~

EXISTING
FIRE HOUSE ~ ~

EXISTING CURTAIN DRAIN

PROPOSED FIBER/POWER RUN

FROM EQUIPMENT TO TOWER
[APPROX. 255'-0"] WITHIN JOINT

COMUNITY TRENCH FOR BOTH

AT&T AN FUTURE COLOCATION

MAMMOTH LAKE FPD TO REMOVE STEEL
CHAIR LIFT TOWER, BEFORE START OFCONSTRUCTION. AT&T GC RESPONSIBLE

FOR REMOVING THE ASSOCIATED CHAIR
LIFT’S CONCRETE PAD.

EXISTING LIGHT POLE TO

BE RELOCATED AS NEEDED
PROPOSED AT&TEQUIPMENT LOCATION.

SEE EQUIPMENT PLAN
1 A-3

PROPOSED AT&T LEASE
AREA (200 SQ. FT.)
20'-0" MOUNTING TO PROPERTY LINE
26'-6" POLE TO PROPERTY LINE
26'-8" POLE TO PROPERTY LINE
20'-0" TO PROPERTY LINE
20'-0" MOUNTING TO PROPERTY LINE
TO PROPERTY LINE 20'-0"

X

XXXXXXX

X X X X X X X X X X X X X X X X

XXXXXXXX

X X X X X X X X X X X X X X X X
X
X
X
X
X
X
X
X

PWR PWR PWR PWR

PWR PWR PWR PWR

PWR PWR PWR

FBR FBR FBR
DRAWN BY:

AG
RB

REV DATE DESCRIPTION
REVISIONS:
90% ZONING DRAWING
LICENSEE:

PROJECT INFORMATION:

SHEET TITLE:

SHEET NUMBER:
1574 OLD MAMMOTH ROAD
MAMMOTH LAKES, CA 93546
A
EUKON AT&T TEMP V2.0
12/02/21
CHECKED BY:

NOT TO BE USED FOR CONSTRUCTION
CSL04615
APPLICANT:

ENGINEER:

Eukon
www.eukongroup.com
65 POST, SUITE 1000
IRVINE, CA 92618
TEL: (949) 553-8566
an SFC Communications, Inc. Company

THIS PAGE CONTAINS CONFIDENTIAL, PROPRIETARY

OR TRADE SECRET INFORMATION EXEMPT FROM
DISCLOSURE UNDER APPLICABLE LAW.
0 01/28/22 100% ZONING DRAWING
1 11/15/22 DRM COMMENTS
2 09/29/23 ZONING COMMENTS
3 01/12/24 ZONING COMMENTS
A-3
SCALE NOTE:

IF DIMENSIONS SHOWN ON PLAN DO NOT SCALE

CORRECTLY, CHECK FOR REDUCTION OR
ENLARGEMENT FROM ORIGINAL PLANS.
90°
135°
45°
270°225°
180°
315°
0°
SCALE NOTE:

IF DIMENSIONS SHOWN ON PLAN DO NOT SCALE

CORRECTLY, CHECK FOR REDUCTION OR
ENLARGEMENT FROM ORIGINAL PLANS.

PROPOSED EQUIPMENT PLAN SCALE 2' 1' 0 2' 4' 8' 1/2"=1'-0" 1 PROPOSED AT&T 8'

TALL CHAIN-LINK
FENCE

PROPOSED AT&T TELCO

BOX ON NEW H-FRAME
PROPOSED AT&T 10' WIDE

CHAIN-LINK ACCESS GATE
20'-0"

PPROPOSED AT&T LEASE AREA
3'-0"

PROPOSED AT&T
20kW POLAR DC
GENERATOR w/ 125g

DIESEL TANK FOR

EMERGENCY

BACK-UP POWER ON

CONCRETE CURB
4'-0"
2'-5"
3'-0"
4'-0"
1'-0" 3'-0"
6'-0"
2'-2"
3'-0"
10'-0"

PPROPOSED AT&T LEASE AREA
10'-0" 10'-0"
NEW AT&T UTILITY H-FRAME (TYP.)NEW AT&T 100A 480V METER/MAIN PANELNEW AT&T PPCNEW AT&T GPS ANTENNA 7'-10"
50'-7"
59'-9"
3'-0"

PROPOSED AT&T LEASE
AREA (200 SQ. FT.)

DRAWN BY:

AG
RB

REV DATE DESCRIPTION
REVISIONS:
90% ZONING DRAWING
LICENSEE:

PROJECT INFORMATION:

SHEET TITLE:

SHEET NUMBER:
1574 OLD MAMMOTH ROAD
MAMMOTH LAKES, CA 93546
A
EUKON AT&T TEMP V2.0
12/02/21
CHECKED BY:

NOT TO BE USED

FOR CONSTRUCTION
CSL04615
APPLICANT:

ENGINEER:

Eukon
www.eukongroup.com
65 POST, SUITE 1000
IRVINE, CA 92618
TEL: (949) 553-8566
an SFC Communications, Inc. Company

THIS PAGE CONTAINS CONFIDENTIAL, PROPRIETARY

OR TRADE SECRET INFORMATION EXEMPT FROM
DISCLOSURE UNDER APPLICABLE LAW.
0 01/28/22 100% ZONING DRAWING
1 11/15/22 DRM COMMENTS
2 09/29/23 ZONING COMMENTS
3 01/12/24 ZONING COMMENTS
ANTENNA AND RRU SCHEDULE 2

NOTES TO CONTRACTOR

1. CONTRACTOR IS TO REFER

TO AT&T'S MOST CURRENT

RADIO FREQUENCY DATA

SHEET (RFDS) PRIOR TO
CONSTRUCTION.

2. CABLE LENGTHS WERE

DETERMINED BASED ON A

VISUAL INSPECTION DURING
SITE WALK. CONTRACTOR TO

VERIFY ACTUAL LENGTH

DURING PRE-CONSTRUCTION
WALK.

3. CONTRACTOR TO USE
ROSENBERGER FIBER LINEHANGER COMPONENTS (ORENGINEER APPROVEDEQUAL).

4. CONTRACTOR TO USE

CABLES SPECIFIED (OR
ENGINEER APPROVEDEQUAL).

MINIMUM CLEARANCES
SECTOR
A1

RRU TYPE

REMOTE RADIO UNITS

ALPHA SECTOR

ABOVE BELOW SIDES

RRU LOCATION
(DISTANCE FROM

ANTENNA)
±15' 16" 8" 0"
A1 ±15' 16" 8" 0"A1
A2A2A2
A3A3A3
B1B1B1
B2B2B2B3B3
BETA SECTOR B3

ERICSSON RRUSERICSSON RRUS
C1C1C1
C2C2C2
C3C3C3
SCALE NOTE:

IF DIMENSIONS SHOWN ON PLAN DO NOT SCALE

CORRECTLY, CHECK FOR REDUCTION OR
ENLARGEMENT FROM ORIGINAL PLANS.
90°
135°
45°
270°
225°
180°
315°
0°
3 PART NUMBER QTY
RAYCAP

SURGE SUPPRESSION SYSTEM
SYSTEM
3 LOCATION
MOUNTED ON (N) W.I.C.

MANUFACTURER
DC12-48-60-0-25E

RAYCAP MOUNTED ON (N) MONOPOLE

PROPOSED AT&T PANEL
ANTENNAS (TYP.-5 PER
SECTOR, TOTAL OF 15)

PROPOSED AT&T RRUS
(TYP.-12 PER SECTOR,
TOTAL OF 36)
SCALE 2' 1' 0 2' 4' 8' PROPOSED ANTENNA PLAN 1/2"=1'-0" 1

PROPOSED ANTENNA

PLAN/ANTENNA AND

RRU SCHEDULE
A-4
NOTE:

MONOPINE FOLIAGE NOT
SHOWN FOR CLARITY.

ERICSSON RRUS ±15' 16" 8" 0"ERICSSON RRUS
±15' 16" 8" 0"

ERICSSON RRUSERICSSON RRUS
±15'±15'
ERICSSON RRUSERICSSON RRUSERICSSON RRUS ±15'
GAMMA SECTORB1
16" 8" 0"16" 8" 0"16" 8" 0"
A4A4A4
B4B4B4
C4C4C4

ERICSSON RRUSERICSSON RRUS
±15' 16" 8" 0"±15' 16" 8" 0"
ERICSSON RRUS ±15' 16" 8" 0"

ERICSSON RRUSERICSSON RRUSERICSSON RRUSERICSSON RRUSERICSSON RRUSERICSSON RRUSERICSSON RRUSERICSSON RRUSERICSSON RRUSERICSSON RRUSERICSSON RRUSERICSSON RRUSERICSSON RRUSERICSSON RRUSERICSSON RRUSERICSSON RRUSERICSSON RRUSERICSSON RRUSERICSSON RRUSERICSSON RRUSERICSSON RRUSERICSSON RRUSERICSSON RRUSERICSSON RRUS ±15' 16" 8" 0"±15' 16" 8" 0"
SECTOR "A"
AZIMUTH: 10°
SECTOR "C"
AZIMUTH: 260°
SECTOR "B"
AZIMUTH: 130°
3'-0"
TYP.
2'-0"
TYP.
3'-0"
TYP.
14'-2"
TYP.

A4
A1
B5
C5
C1
3'-6"
4'-8"
5'-10"
PROPOSED AT&T 80'-0"

HIGH MONOPINE

PROPOSED AT&T MONOPINE

BRANCH OVERHANG
PROPOSED AT&T DC9 SURGE
SUPPRESSOR (TOTAL OF 3)
A2

SECTOR RAD CENTER
A1
A4A3
B2
B1

OPTIMUM ANTENNA REQUIREMENTS (VERIFY WITH CURRENT RFDS) B4
B3
C2
C1
C4C3

ALPHA SECTOR BETA SECTOR GAMMA SECTOR

ANTENNA

AZIMUTH TECHNOLOGY ANTENNA MODEL LENGTH NUMBER

TRANSMISSION

CABLE ANTENNA SIZE
8'
31"
PANEL ANTENNAS 70'-0"
260°
130°
10°10°
260°
8'
10°
130°
260°
69'-2"
72'-9"
130°
PANEL ANTENNAS 31"
10° 70'-0"

PANEL ANTENNASPANEL ANTENNAS
130°
260°
A5
8'
10° 70'-0"

PANEL ANTENNAS
B5 130°
C5 260°
±150' 3 PWR 1 FIBER±150' 3 PWR 1 FIBER±150' 3 PWR 1 FIBER A5 C4 B4
A2A3
B2
B3
C2
C3
8'
31"
PANEL ANTENNAS 70'-0"
8'
69'-2"
72'-9"
PANEL ANTENNAS 31"
70'-0"

PANEL ANTENNASPANEL ANTENNAS
8'
70'-0"

PANEL ANTENNAS
8'
31"
PANEL ANTENNAS 70'-0"
8'
69'-2"
72'-9"
PANEL ANTENNAS 31"
70'-0"

PANEL ANTENNASPANEL ANTENNAS
8'
70'-0"

PANEL ANTENNAS
±15' 16" 8" 0"±15' 16" 8" 0"±15' 16" 8" 0"±15' 16" 8" 0"±15'±15'±15' 16" 8" 0"16" 8" 0"16" 8" 0"
±15' 16" 8" 0"±15' 16" 8" 0"±15' 16" 8" 0"±15' 16" 8" 0"±15' 16" 8" 0"±15' 16" 8" 0"±15' 16" 8" 0"±15' 16" 8" 0"±15' 16" 8" 0"±15'±15'±15' 16" 8" 0"16" 8" 0"16" 8" 0"
±15' 16" 8" 0"±15' 16" 8" 0"±15' 16" 8" 0"±15' 16" 8" 0"±15' 16" 8" 0" NOTE:ALL ANTENNAS TO BE EQUIPPED WITH
MECHANICAL UPTILT BRACKETS.

PROPOSED AT&T 4'Ø

MICROWAVE ANTENNA
9"
4'-6"
TYP.
3'-6"
TYP.
4'-8"
TYP.
7'-1"
TYP.
7'-1"
TYP.
1'-0" MIN.

TYP.
4'-0" MIN.

TYP. Ø23'-8"
11'-10"
MIN. FOLIAGE COVEAGE @ ANTENNA LEVEL
4'-7"
5'-7"
3'-7"
10"

DRAWN BY:

AG
RB

REV DATE DESCRIPTION
REVISIONS:
90% ZONING DRAWING
LICENSEE:

PROJECT INFORMATION:

SHEET TITLE:

SHEET NUMBER:
1574 OLD MAMMOTH ROAD
MAMMOTH LAKES, CA 93546
A
EUKON AT&T TEMP V2.0
12/02/21
CHECKED BY:

NOT TO BE USED FOR CONSTRUCTION
CSL04615
APPLICANT:

ENGINEER:

Eukon
www.eukongroup.com
65 POST, SUITE 1000
IRVINE, CA 92618
TEL: (949) 553-8566
an SFC Communications, Inc. Company

THIS PAGE CONTAINS CONFIDENTIAL, PROPRIETARY

OR TRADE SECRET INFORMATION EXEMPT FROM
DISCLOSURE UNDER APPLICABLE LAW.
0 01/28/22 100% ZONING DRAWING
1 11/15/22 DRM COMMENTS
2 09/29/23 ZONING COMMENTS
3 01/12/24 ZONING COMMENTS
PROPOSED SOUTH ELEVATION SCALE 4' 2' 0 4' 8' 16' 1/4"=1'-0" 1

PROPOSED SOUTH

ELEVATIONS
A-5
GROUND LEVELELEV. 7924.8 (REF)ELEV. 70'-0"ELEV. 74'-0"PROPOSED AT&T ANTENNA RAD CENTERTOP OF PROPOSED AT&T ANTENNAS PROPOSED AT&T 80' HIGH MONOPINE
ELEV. 80'-0"TOP OF PROPOSED MONOPINE FOLIAGEELEV. 55'-0"PROPOSED AT&T MICROWAVE RAD CENTERELEV. 72'-9"PROPOSED AT&T CBAND ANTENNA RAD CENTER PROPOSED AT&T 4' Ø MICROWAVE
ANTENNA; PAINTED TO MATCH FOLIAGE
ELEV. 69'-2"PROPOSED AT&T CBAND ANTENNA RAD CENTER
1'-0"
PROPOSED AT&T RRUS (TYP.-5 PER
SECTOR, TOTAL OF 15)
PROPOSED AT&T ANTENNA; PAINTED TO

MATCH FOLIAGE W/ STEALTH PINE NEEDLE
SOCKS (TYP.-5 PER SECTOR, TOTAL OF 15)
PROPOSED AT&T DC9 SURGE
SUPPRESSOR (TYP.-3)
ELEV. 29'-11"

TOP OF EXISTING TREE
ELEV. 26'-6"

TOP OF EXISTING TREE
ELEV. 19'-4"

TOP OF EXISTING TREE
NOTES:

1. HEIGHT OF EXISTING TREES IN THE SURROUNDING
VICINITY OF THE PROPOSED SITE ARE 55'-65'.

2. 80' MONO-PINE DESIGNED FOR COLLOCATION OF
FUTURE WIRELESS CARRIER.

FUTURE CARRIER
ANTENNAS (TYP.)
10'-0"
ELEV. 43'-0"TOP OF FUTURE CARRIER ANTENNASELEV. 35'-0"BOTTOM OF FUTURE CARRIER ANTENNAS 26'-8"

TO PROPERTY LINE
ELEV. 75'-0"TOP OF PROPOSED TOWER STEEL

DRAWN BY:

AG
RB

REV DATE DESCRIPTION
REVISIONS:
90% ZONING DRAWING
LICENSEE:

PROJECT INFORMATION:

SHEET TITLE:

SHEET NUMBER:
1574 OLD MAMMOTH ROAD
MAMMOTH LAKES, CA 93546
A
EUKON AT&T TEMP V2.0
12/02/21
CHECKED BY:

NOT TO BE USED FOR CONSTRUCTION
CSL04615
APPLICANT:

ENGINEER:

Eukon
www.eukongroup.com
65 POST, SUITE 1000
IRVINE, CA 92618
TEL: (949) 553-8566
an SFC Communications, Inc. Company

THIS PAGE CONTAINS CONFIDENTIAL, PROPRIETARY

OR TRADE SECRET INFORMATION EXEMPT FROM
DISCLOSURE UNDER APPLICABLE LAW.
0 01/28/22 100% ZONING DRAWING
1 11/15/22 DRM COMMENTS
2 09/29/23 ZONING COMMENTS
3 01/12/24 ZONING COMMENTS
PROPOSED WEST ELEVATION SCALE 4' 2' 0 4' 8' 16' 1/4"=1'-0" 1 A-6

GROUND LEVEL
ELEV.7924.8(REF)
ELEV. 70'-0"ELEV. 74'-0"

PROPOSED AT&T ANTENNA RAD CENTER

TOP OF PROPOSED AT&T ANTENNAS
ELEV. 80'-0"

TOP OF PROPOSED MONOPINE FOLIAGE
ELEV. 55'-0"

PROPOSED AT&T MICROWAVE RAD CENTER
ELEV. 72'-9"

PROPOSED AT&T CBAND ANTENNA RAD CENTER
ELEV. 69'-2"

PROPOSED AT&T CBAND ANTENNA RAD CENTER
1'-0"
PROPOSED AT&T 80' HIGH MONOPINEPROPOSED AT&T DC9 SURGE
SUPPRESSOR (TYP.-3)
PROPOSED AT&T ANTENNA; PAINTED TO

MATCH FOLIAGE W/ STEALTH PINE NEEDLE
SOCKS (TYP.-5 PER SECTOR, TOTAL OF 15)
PROPOSED AT&T RRUS (TYP.-5PER SECTOR, TOTAL OF 15)PROPOSED AT&T 4' Ø MICROWAVE ANTENNA; PAINTED TO MATCH FOLIAGE
NOTES:

1. HEIGHT OF EXISTING TREES IN THE SURROUNDING
VICINITY OF THE PROPOSED SITE ARE 55'-65'.

2. 80' MONO-PINE DESIGNED FOR COLLOCATION OF
FUTURE WIRELESS CARRIER.

PROPOSED WEST

ELEVATIONS
ELEV. 43'-0"

TOP OF FUTURE CARRIER ANTENNAS
ELEV. 35'-0"

BOTTOM OF FUTURE CARRIER ANTENNAS
10'-0"

FUTURE CARRIER
ANTENNAS (TYP.)
26'-6"

TO PROPERTY LINE
ELEV. 75'-0"

TOP OF PROPOSED TOWER STEEL

Attachment D - 2
Photo-Simulations

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

Proposed Looking north from Old Mammoth Road
View 1
Existing
proposed 80 ft. tall monopine
1574 Old Mammoth Road Mammoth Lakes CA 93546
CSL04615
Location 1A
©2024 Google Maps

TOWN OF

MAMMOTH LAKES

RECEIVED
1/31/2024

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

Proposed Looking northwest from Old Mammoth Road
View 2
Existing
1574 Old Mammoth Road Mammoth Lakes CA 93546
CSL04615
Location 1A
proposed 80 ft. tall
monopine
©2024 Google Maps

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

Proposed Looking southeast from Timber Creek Road
View 3
Existing
1574 Old Mammoth Road Mammoth Lakes CA 93546
CSL04615
Location 1A
proposed 80 ft. tall monopine
©2024 Google Maps

1574 Old Mammoth Road Mammoth Lakes CA 93546
CSL04615
Location 1A
Accuracy of photo simulation based upon information provided by project applicant.

Proposed Looking east from Club Drive
View 4
Existing
proposed equipment enclosure
proposed 80 ft. tall monopine
©2024 Google Maps

Regarding Photo-Simulations for:

Site Name: CSL04615
January 29, 2024
To Whom It May Concern:

The submitted photo-simulations were produced employing proprietary methodology and software utilized by Artistic Engineering, Inc. Various onsite and photo conditions were recorded to assist, along with the submitted plans, in generating a CAD model (digital mockup) of both the existing and proposed designs for the purpose of creating an accurate photographic depiction of the proposed site design. The photo-simulations are a digital representation of the proposed design for the site named CSL04615, based on the 100% zoning plans dated 01/1/24 and any other information provided to Artistic Engineering by project applicant at time of the requested work, based on photographs originally shot on 12/21/23.

In no event will Artistic Engineering Inc. be held liable for any loss of profit or any other commercial and/or public damage including, but not limited to, special; incidental; consequential; or other damages resulting from the use of the provided information or data.
_________________________________
Brandon Hurley
Project Manager-Artistic Engineering
(877) 923-7467 -Office ext. 707
17602 17th Street, Suite 102-52
Tustin, CA 92780
www.AEsims.com

Attachment D - 3
Site Justification Maps

LTE Justification Plots
Market Name: Los AngelesSite ID: CSL04615Site Address: 1574 Old Mammoth Road, Mammoth Lake CA 93546

TOWN OF

MAMMOTH LAKES

RECEIVED
7/20/2023

© 2008 AT&T Knowledge Ventures. All rights reserved.

AT&T is a registered trademark of AT&T Knowledge Ventures. ™ Propagation of the site plots are based on our current Atoll (Design tool) project tool that shows the preferred design of the AT&T 4G-LTE network coverage. ™ The propagation referenced in this package is based on proposed LTE coverage of AT&T users in the surrounding buildings, in vehicles and at street level . For your reference, the scale shown ranges from good to poor coverage with gradual changes in coverage showing best coverage to marginal and finally poor signal levels. ™ The plots shown are based on the following criteria:
¾ Existing: Since LTE network modifications are not yet On-Air. The first slide is a snap shot of the area showing the existing site without LTE coverage in the AT&T network. ¾ The Planned LTE Coverage with the Referenced Site: Assuming all the planned neighboring sites of the target site are approved by the jurisdiction and the referenced site is also approved and On-Air, the propagation is displayed with the planned legends provided.
¾ Without Target site: Assuming all the planned neighboring sites are approved by the jurisdiction and On-Air and the referenced site is Off-Air, the propagation is displayed with the legends provided.

Assumptions

© 2008 AT&T Knowledge Ventures. All rights reserved.

AT&T is a registered trademark of AT&T Knowledge Ventures.

CSL04615

© 2008 AT&T Knowledge Ventures. All rights reserved.

AT&T is a registered trademark of AT&T Knowledge Ventures.

LTE Coverage Before site CSL04615

LTE Coverage After site CSL04615

LTE Coverage standalone site CSL04615

Coverage Legend
In-Building Service: In general, the areas shown in dark green should have the strongest signal strength and be sufficient for most in-building coverage. However, in-building coverage can and will be adversely affected by the thickness/construction type of walls, or your location in the building (i.e., in the basement, in the middle of the building with multiple walls, etc.)In-Transit Service: The areas shown in the yellow should be sufficient for onstreet or in-the-open coverage, most in-vehicle coverage and possibly some in-building coverage. Outdoor Service: The areas shown in the purple should have sufficient signal strength for on-street or in-the-open coverage, but may not have it for invehicle coverage or in-building coverage.

© 2023 AT&T Intellectual Property. AT&T and globe logo are registered trademarks and service marks of AT&T Intellectual Property and/or AT&T affiliated companies. All other marks are the property of their respective owners AT&T Proprietary (Internal Use Only) - Not for use or disclosure outside the AT&T companies except under written agreement Site Justification Coverage Maps
Market Name : Southern California MarketSite ID : CSL04615Site Address : 1574 Old Mammoth Road, Mammoth Lake CA 93546ATOLL Completion Date: Oct 30, 2023

TOWN OF

MAMMOTH LAKES

RECEIVED
10/30/2023

Assumptions
™ Propagation of the site plots are based on our current Atoll (Design tool) project tool that shows the preferred design of the AT&T 4G-LTE network coverage.
™ The propagation referenced in this package is based on proposed LTE coverage of AT&T users in the surrounding buildings, in vehicles and at street level . For your reference, the scale shown ranges from good to poor coverage with gradual changes in coverage showing best coverage to marginal and finally poor signal levels. ™ The plots shown are based on the following criteria:
¾ Existing: Since LTE network modifications are not yet On-Air. The first slide is a snapshot of the area showing the existing site without LTE coverage in the AT&T network. ¾ The Planned LTE Coverage with the Referenced Site: Assuming all the planned neighboring sites of the target site are approved by the jurisdiction and the referenced site is also approved and On-Air, the propagation is displayed with the planned legends provided. ¾ Without Target site: Assuming all the planned neighboring sites are approved by the jurisdiction and On-Air and the referenced site is Off-Air, the propagation is displayed with the legends provided. 2 CLL05428_Justification_Package / Feb 27, 2023 / © 2023 AT&T Intellectual Property - AT&T Proprietary (Internal Use Only)

CSL04165 (Terrain Map)
3 CLL05428_Justification_Package / Feb 27, 2023 / © 2023 AT&T Intellectual Property - AT&T Proprietary (Internal Use Only)

CSL04165 (Street Map)
4 CLL05428_Justification_Package / Feb 27, 2023 / © 2023 AT&T Intellectual Property - AT&T Proprietary (Internal Use Only)

Existing Coverage Before Site CSL04165
5 CLL05428_Justification_Package / Feb 27, 2023 / © 2023 AT&T Intellectual Property - AT&T Proprietary (Internal Use Only)

Existing Coverage After Site CSL04165 – Tower height top @ 80’ 6 CLL05428_Justification_Package / Feb 27, 2023 / © 2023 AT&T Intellectual Property - AT&T Proprietary (Internal Use Only)

Existing Coverage After Site CSL04165 Tower height top @ 65’ 7 CLL05428_Justification_Package / Feb 27, 2023 / © 2023 AT&T Intellectual Property - AT&T Proprietary (Internal Use Only)

Existing Coverage After Site CSL04165 Tower height top @ 35’ 8 CLL05428_Justification_Package / Feb 27, 2023 / © 2023 AT&T Intellectual Property - AT&T Proprietary (Internal Use Only)

Standalone Coverage Of Site CSL04165 Tower height top @ 80’ 9 CLL05428_Justification_Package / Feb 27, 2023 / © 2023 AT&T Intellectual Property - AT&T Proprietary (Internal Use Only)

Standalone Coverage Of Site CSL04165 Tower height top @ 65’ 10 CLL05428_Justification_Package / Feb 27, 2023 / © 2023 AT&T Intellectual Property - AT&T Proprietary (Internal Use Only)

Standalone Coverage Of Site CSL04165 Tower height top @ 35’ 11 CLL05428_Justification_Package / Feb 27, 2023 / © 2023 AT&T Intellectual Property - AT&T Proprietary (Internal Use Only)

Coverage Legend
In-Building Service: In general, the areas shown in dark green should have the strongest signal strength and be sufficient for most in-building coverage. However, in-building coverage can and will be adversely affected by the thickness/construction type of walls, or your location in the building (i.e., in the basement, in the middle of the building with multiple walls, etc.)In-Transit Service: The areas shown in the yellow should be sufficient for on-street or in-the-open coverage, most invehicle coverage and possibly some in-building coverage. Outdoor Service: The areas shown in the purple should have sufficient signal strength for on-street or in-the-open coverage but may not have it for in-vehicle coverage or in-building coverage. 12 CLL05428_Justification_Package / Feb 27, 2023 / © 2023 AT&T Intellectual Property - AT&T Proprietary (Internal Use Only)

© 2023 AT&T Intellectual Property. AT&T and globe logo are registered trademarks and service marks of AT&T Intellectual Property and/or AT&T affiliated companies. All other marks are the property of their respective ownersAT&T Proprietary (Internal Use Only) - Not for use or disclosure outside the AT&T companies except under written agreement Site Justification Coverage Maps
Market Name : Southern California MarketSite ID : CSL04615Site Address : 1574 Old Mammoth Road, Mammoth Lake CA 93546ATOLL Completion Date: Jan 12, 2024

TOWN OF

MAMMOTH LAKES

RECEIVED
1/12/2024

Assumptions
™ Propagation of the site plots are based on our current Atoll (Design tool) project tool that shows the preferred design of the AT&T 4G-LTE network coverage.
™ The propagation referenced in this package is based on proposed LTE coverage of AT&T users in the surrounding buildings, in vehicles and at street level . For your reference, the scale shown ranges from good to poor coverage with gradual changes in coverage showing best coverage to marginal and finally poor signal levels. ™ The plots shown are based on the following criteria:
¾ Existing: Since LTE network modifications are not yet On-Air. The first slide is a snapshot of the area showing the existing site without LTE coverage in the AT&T network. ¾ The Planned LTE Coverage with the Referenced Site: Assuming all the planned neighboring sites of the target site are approved by the jurisdiction and the referenced site is also approved and On-Air, the propagation is displayed with the planned legends provided. ¾ Without Target site: Assuming all the planned neighboring sites are approved by the jurisdiction and On-Air and the referenced site is Off-Air, the propagation is displayed with the legends provided. 2 CLL05428_Justification_Package / Feb 27, 2023 / © 2023 AT&T Intellectual Property - AT&T Proprietary (Internal Use Only)

CSL04165 (Terrain Map)
3 CLL05428_Justification_Package / Feb 27, 2023 / © 2023 AT&T Intellectual Property - AT&T Proprietary (Internal Use Only)

CSL04165 (Street Map)
4 CLL05428_Justification_Package / Feb 27, 2023 / © 2023 AT&T Intellectual Property - AT&T Proprietary (Internal Use Only)

Coverage Before Site CSL04165
5 CLL05428_Justification_Package / Feb 27, 2023 / © 2023 AT&T Intellectual Property - AT&T Proprietary (Internal Use Only)

Coverage After Site CSL04165 – Center line 70’
6 CLL05428_Justification_Package / Feb 27, 2023 / © 2023 AT&T Intellectual Property - AT&T Proprietary (Internal Use Only)

Coverage After Site CSL04165 – Center line 60’
7 CLL05428_Justification_Package / Feb 27, 2023 / © 2023 AT&T Intellectual Property - AT&T Proprietary (Internal Use Only)

Coverage After Site CSL04165 – Center line 50’
8 CLL05428_Justification_Package / Feb 27, 2023 / © 2023 AT&T Intellectual Property - AT&T Proprietary (Internal Use Only)

Coverage After Site CSL04165 – Center line 40’
9 CLL05428_Justification_Package / Feb 27, 2023 / © 2023 AT&T Intellectual Property - AT&T Proprietary (Internal Use Only)

Coverage After Site CSL04165 – Center line 30’
10 CLL05428_Justification_Package / Feb 27, 2023 / © 2023 AT&T Intellectual Property - AT&T Proprietary (Internal Use Only)

Standalone Coverage Of Site CSL04165 – Center line 70’
11 CLL05428_Justification_Package / Feb 27, 2023 / © 2023 AT&T Intellectual Property - AT&T Proprietary (Internal Use Only)

Standalone Coverage Of Site CSL04165 – Center line 60’
12 CLL05428_Justification_Package / Feb 27, 2023 / © 2023 AT&T Intellectual Property - AT&T Proprietary (Internal Use Only)

Standalone Coverage Of Site CSL04165 – Center line 50’
13 CLL05428_Justification_Package / Feb 27, 2023 / © 2023 AT&T Intellectual Property - AT&T Proprietary (Internal Use Only)

Standalone Coverage Of Site CSL04165 – Center line 40’
14 CLL05428_Justification_Package / Feb 27, 2023 / © 2023 AT&T Intellectual Property - AT&T Proprietary (Internal Use Only)

Standalone Coverage Of Site CSL04165 – Center line 30’
15 CLL05428_Justification_Package / Feb 27, 2023 / © 2023 AT&T Intellectual Property - AT&T Proprietary (Internal Use Only)

Coverage Legend
In-Building Service: In general, the areas shown in dark green should have the strongest signal strength and be sufficient for most in-building coverage. However, in-building coverage can and will be adversely affected by the thickness/construction type of walls, or your location in the building (i.e., in the basement, in the middle of the building with multiple walls, etc.)In-Transit Service: The areas shown in the yellow should be sufficient for on-street or in-the-open coverage, most invehicle coverage and possibly some in-building coverage. Outdoor Service: The areas shown in the purple should have sufficient signal strength for on-street or in-the-open coverage but may not have it for in-vehicle coverage or in-building coverage. 16 CLL05428_Justification_Package / Feb 27, 2023 / © 2023 AT&T Intellectual Property - AT&T Proprietary (Internal Use Only)

Attachment D - 4
RF Safety Report

AT&T Proprietary (Internal use only). Not for use or disclosure outside the AT&T companies, except under written agreement. © 2023 AT&T Intellectual property. All rights reserved.

Radio Frequency Safety Survey Report Prediction (RFSSRP) AT&T Wireless Monopine Facility

Compliance Status:

AT&T will be compliant with FCC Regulations upon installation of recommended mitigation measures as presented in Section 3.0 of this report.

Site ID: CSL04615
Site Name: CSL04615
FA: 11553744
USID: 312847
PACE #: MRLOS071118

Address: 1574 Old Mammoth Road
Mammoth Lakes, CA 93546

County: Mono County
Latitude: 37.629606
Longitude: -118.978303
Site Structure Type: Monopine
Report Date: 1/6/2023

M-RFSC: Essie Polard

Prepared For: SFC Communications, Inc dba
Eukon Group
65 Post, Suite 1000
Irvine, CA 92618

Report Author: Erin Mahaney
Report Reviewer: Scott Heffernan
Fox Hill Project Number: 222119

TOWN OF

MAMMOTH LAKES

RECEIVED
7/20/2023

CSL04615 / CSL04615 / 11553744
AT&T Proprietary (Internal use only). Not for use or disclosure outside the AT&T companies, except under written agreement. © 2023 AT&T Intellectual property. All rights reserved. Page | 2

Table of Contents

1.0 Introduction ................................................................................................................................ 3

2.0 Site Information .......................................................................................................................... 3

3.0 Results Snapshot and Mitigation Measures ................................................................................ 4

4.0 Site Map ...................................................................................................................................... 5

5.0 Antenna Inventory ...................................................................................................................... 6

6.0 RoofMasterTM Export File ............................................................................................................ 8

7.0 Results and Compliance Recommendations ................................................................................ 9

8.0 AT&T Signage Policy .................................................................................................................. 16

9.0 Fall Arrest and Parapet Information .......................................................................................... 17

10.0 FCC Guidelines ........................................................................................................................... 18

11.0 Calculation Methodology .......................................................................................................... 20 The Cylindrical Model Implementation (Sula9) ................................................................................ 21 The Far Field Model ....................................................................................................................... 22

12.0 Certifications ............................................................................................................................. 23

CSL04615 / CSL04615 / 11553744
AT&T Proprietary (Internal use only). Not for use or disclosure outside the AT&T companies, except under written agreement. © 2023 AT&T Intellectual property. All rights reserved. Page | 3

1.0 Introduction
Fox Hill Telecom, Inc. has been contracted by AT&T to produce a theoretical assessment of the potential radio frequency emissions at the proposed AT&T monopine site. FCC OET Bulletin 65 – Edition 97-01 recommends that theoretical calculations should be done to yield a worst-case scenario. This theoretical analysis will provide a worst-case assessment of potential emissions and will assume all transmitters are operating at highest capacity and power. This will provide AT&T with a guideline of how to proceed with mitigating the site to ensure the site will be compliant with FCC regulations at any instance.

Many licensed wireless system operators are required to perform periodic assessments of potential impacts to humans due to radio frequency emissions from active transmitters at the site. The Federal Communications Commission (“FCC”) considers two levels of standards based on access controls to the site and the level of knowledge of the effects of radio frequency to humans.

A controlled/occupational environment assumes that anyone accessing the site is fully trained in RF safety and is aware of the effects of the exposure to radio frequency emissions to humans, An uncontrolled/general population environment assumes that access is not restricted to RF trained individuals and other members of the general population may be able to access the site for any reason, occupation or otherwise.

2.0 Site Information
AT&T has provided the following documents to use in the analysis of this site. x RFDS: LOS-ANGELES_L.A._CSL04615_2023-NewSite_LTE_ja628x_3551A0TJF4_11553744_312847_12-09-2021_Final-Approved_v1.00 o RFDS ID: 4902165
x CDs: CSL04615 - 100ZD - REV 0 - NSB - 10-26-22

CSL04615 / CSL04615 / 11553744

AT&T Proprietary (Internal use only). Not for use or disclosure outside the AT&T companies, except under written agreement. © 2023 AT&T Intellectual property. All rights reserved. Page | 4

3.0 Results Snapshot and Mitigation Measures
Based on the theoretical modeling analysis performed, there are no areas at this site that exceed the FCC’s General Public and Occupational limits. All areas of concern extend into free space. AT&T must ensure proper mitigation is installed at the site in order to bring the site into compliance.

Section 7.0 will show the areas of exposure, if any, at each AT&T Sector.

Signage and barriers are the primary means of mitigating access to accessible areas of exposure. A site scaled map can be found in section 4.0 which details the locations where mitigation should be installed to bring the site into compliance with FCC regulations.

Below is a summary of recommended mitigation at this AT&T facility.

Access:
x Caution 2B sign required at base of monopine near climbing ladder.

Sector A:
x No signage required
Sector B:
x No signage required
Sector C:
x No signage required

CSL04615 / CSL04615 / 11553744
AT&T Proprietary (Internal use only). Not for use or disclosure outside the AT&T companies, except under written agreement. © 2023 AT&T Intellectual property. All rights reserved. Page |5

4.0 Site Map
Proposed Barrier
Proposed Sign

CSL04615 / CSL04615 / 11553744
AT&T Proprietary (Internal use only). Not for use or disclosure outside the AT&T companies, except under written agreement. © 2023 AT&T Intellectual property. All rights reserved. Page |6

5.0 Antenna Inventory
Antenna
ID Operator Antenna Make and Model Type Freq (MHz)
Input Power
(Watts)
# of
TX
ERP
(Watts)
Azimuth
(°)
Gain
(dBd)
BW
(°)
Length
(ft) x y
1 AT&T Mobility Commscope NNH4-65C-R6-V3 Panel LTE 700 B17 40 4 3035 10 12.78 75 8.00 128 62.2 1 AT&T Mobility Commscope NNH4-65C-R6-V3 Panel 5G 850 40 4 3460 10 13.35 72 8.00 128 62.2 1 AT&T Mobility Commscope NNH4-65C-R6-V3 Panel LTE 1900 40 4 5116 10 15.05 60 8.00 128 62.2 1 AT&T Mobility Commscope NNH4-65C-R6-V3 Panel LTE 1900 40 4 5116 10 15.05 60 8.00 128 62.2 2 AT&T Mobility Integrated RRU AIR6419 B77G Panel 5G B77G 3500 54.22 1 11994 10 23.45 13 2.43 124 61.4 3 AT&T Mobility Integrated RRU AIR6449 B77D Panel 5G CBAND 3700 108.4 1 23982 10 23.45 11.7 2.76 124 61.4 4 AT&T Mobility CCI OPA65R-BU8DA-K Panel LTE 700 B14 40 4 3305 10 13.15 61 8.00 122 60.7 4 AT&T Mobility CCI OPA65R-BU8DA-K Panel LTE 2100 40 4 5741 10 15.55 71 8.00 122 60.7 5 AT&T Mobility CCI OPA65R-BU8DA-K Panel LTE 2300 25 4 3427 10 15.35 50 8.00 117 60.1 6 AT&T Mobility Commscope NNH4-65C-R6-V3 Panel LTE 700 B17 40 4 3035 130 12.78 75 8.00 123 77.6 6 AT&T Mobility Commscope NNH4-65C-R6-V3 Panel 5G 850 40 4 3460 130 13.35 72 8.00 123 77.6 6 AT&T Mobility Commscope NNH4-65C-R6-V3 Panel LTE 1900 40 4 5116 130 15.05 60 8.00 123 77.6 6 AT&T Mobility Commscope NNH4-65C-R6-V3 Panel LTE 1900 40 4 5116 130 15.05 60 8.00 123 77.6 7 AT&T Mobility Integrated RRU AIR6419 B77G Panel 5G B77G 3500 54.22 1 11994 130 23.45 13 2.43 126 74.2 8 AT&T Mobility Integrated RRU AIR6449 B77D Panel 5G CBAND 3700 108.4 1 23982 130 23.45 11.7 2.76 126 749 AT&T Mobility CCI OPA65R-BU8DA-K Panel LTE 700 B14 40 4 3305 130 13.15 61 8.00 127 72.3 9 AT&T Mobility CCI OPA65R-BU8DA-K Panel LTE 2100 40 4 5741 130 15.55 71 8.00 127 72.3 10 AT&T Mobility CCI OPA65R-BU8DA-K Panel LTE 2300 25 4 3427 130 15.35 50 8.00 130 69.1 11 AT&T Mobility Commscope NNH4-65C-R6-V3 Panel LTE 700 B17 40 4 3035 260 12.78 75 8.00 114 64.6 11 AT&T Mobility Commscope NNH4-65C-R6-V3 Panel 5G 850 40 4 3460 260 13.35 72 8.00 114 64.6 11 AT&T Mobility Commscope NNH4-65C-R6-V3 Panel LTE 1900 40 4 5116 260 15.05 60 8.00 114 64.6 11 AT&T Mobility Commscope NNH4-65C-R6-V3 Panel LTE 1900 40 4 5116 260 15.05 60 8.00 114 64.6 12 AT&T Mobility Integrated RRU AIR6419 B77G Panel 5G B77G 3500 54.22 1 11994 260 23.45 13 2.43 114 68.4 13 AT&T Mobility Integrated RRU AIR6449 B77D Panel 5G CBAND 3700 108.4 1 23982 260 23.45 11.7 2.76 115 68.4 14 AT&T Mobility CCI OPA65R-BU8DA-K Panel LTE 700 B14 40 4 3305 260 13.15 61 8.00 115 71.2 14 AT&T Mobility CCI OPA65R-BU8DA-K Panel LTE 2100 40 4 5741 260 15.55 71 8.00 115 71.2

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ID Operator Antenna Make and Model Type Freq (MHz)
Input Power
(Watts)
# of
TX
ERP
(Watts)
Azimuth
(°)
Gain
(dBd)
BW
(°)
Length
(ft) x y
15 AT&T Mobility CCI OPA65R-BU8DA-K Panel LTE 2300 25 4 3427 260 15.35 50 8.00 116 75.3 16 AT&T Mobility 4' Microwave Dish LTE 18000 1 1 19717 70 42.95 0.9 4.00 125 67.4 Antenna
ID Operator Ant Z Value Ground Level (ft) Ant Z Value Adjacent Building Level 25 (ft) Ant Z Value Adjacent Building Level 45 (ft) Ant Z Value Antenna Face 1 AT&T Mobility 66.00 41.00 21.00 0 2 AT&T Mobility 71.54 46.54 26.54 0 3 AT&T Mobility 67.87 42.87 22.87 0 4 AT&T Mobility 66.00 41.00 21.00 0 5 AT&T Mobility 66.00 41.00 21.00 0 6 AT&T Mobility 66.00 41.00 21.00 0 7 AT&T Mobility 71.54 46.54 26.54 0 8 AT&T Mobility 67.87 42.87 22.87 0 9 AT&T Mobility 66.00 41.00 21.00 0 10 AT&T Mobility 66.00 41.00 21.00 0 11 AT&T Mobility 66.00 41.00 21.00 0 12 AT&T Mobility 71.54 46.54 26.54 0 13 AT&T Mobility 67.87 42.87 22.87 0 14 AT&T Mobility 66.00 41.00 21.00 0 15 AT&T Mobility 66.00 41.00 21.00 0 16 AT&T Mobility 53.00 28.00 8.00 0 *The Z values refer to the distance from the bottom of the antenna to the referenced level. **The z value of the AIR antenna was adjusted to 0 when bottom tip is between 0 and 8 feet from referenced level for the most conservative results.

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6.0 RoofMasterTM Export File

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7.0 Results and Compliance Recommendations
Based on the theoretical modeling analysis performed, there are no areas at this site that exceed the FCC’s General Public and Occupational limits. All areas of concern extend into free space. AT&T must ensure proper mitigation is installed at the site in order to bring the site into compliance.

AT&T Results:

At the ground level (0’ AGL), the maximum power density value (% MPE) calculated for AT&T’s antennas is 4.01 % of the FCC’s allowable limit for General Population exposure to radio frequency emissions (0.80 % of the FCC’s allowable Occupational limit).

At the adjacent building level (25’ AGL), the maximum power density value (% MPE) calculated for AT&T’s antennas is 9.70 % of the FCC’s allowable limit for General Population exposure to radio frequency emissions (1.94 % of the FCC’s allowable Occupational limit).

At the adjacent building level (45’ AGL), the maximum power density value (% MPE) calculated for AT&T’s antennas is 40.30 % of the FCC’s allowable limit for General Population exposure to radio frequency emissions (8.06 % of the FCC’s allowable Occupational limit).

At the antenna face level, the maximum power density value (% MPE) calculated for AT&T’s antennas is 22,535.01 % of the FCC’s allowable limit for General Population exposure to radio frequency emissions (4,507.00 % of the FCC’s allowable Occupational limit).

AT&T will be compliant with the installation of recommended mitigation measures. Each sector is broken down below.

Sector A:

The maximum power density value (% MPE) calculated for AT&T’s Sector A antennas on the ground level is 4.01 % of the FCC’s allowable limit for General Population exposure to radio frequency emissions (0.80 % of the FCC’s allowable Occupational limit).

There are no accessible areas at any forementioned level that exceed the FCC’s General Population or Occupational limit for exposure to radio frequency emissions in front of the Sector A antennas. All areas of concern extend into free space.

Sector B:

The maximum power density value (% MPE) calculated for AT&T’s Sector B antennas on the ground level is 4.01 % of the FCC’s allowable limit for General Population exposure to radio frequency emissions (0.80 % of the FCC’s allowable Occupational limit).

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There are no accessible areas at any forementioned level that exceed the FCC’s General Population or Occupational limit for exposure to radio frequency emissions in front of the Sector B antennas. All areas of concern extend into free space.

Sector C:

The maximum power density value (% MPE) calculated for AT&T’s Sector C antennas on the ground level is 4.01 % of the FCC’s allowable limit for General Population exposure to radio frequency emissions (0.80 % of the FCC’s allowable Occupational limit).

There are no accessible areas at any forementioned level that exceed the FCC’s General Population or Occupational limit for exposure to radio frequency emissions in front of the Sector C antennas. All areas of concern extend into free space.

The FCC mandates that if a site is found to be out of compliance with regard to emissions that any system operator contributing 5% or more to areas exceeding the FCC’s allowable limits, as outlined in this report, will be responsible for bringing the site into compliance.

There are no other carriers on site.

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The anticipated % MPE for the AT&T antennas at the ground level (0’) is 4.01 % of the FCC’s allowable limit for General Population

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The anticipated % MPE for the AT&T antennas at the adjacent building level (25’) is 9.70 % of the FCC’s allowable limit for General Population

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The anticipated % MPE for the AT&T antennas at the adjacent building level (45’) is 40.30 % of the FCC’s allowable limit for General Population

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The anticipated % MPE for the AT&T antennas at the antenna face level is 22,535.01 % of the FCC’s allowable limit for General Population

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8.0 AT&T Signage Policy
Sign Description
Notice Sign 2
Used to alert individuals that they are entering an area that may exceed either the FCC’s General Population emissions limits.

Caution Sign 2
Used to alert individuals that they are entering an area that may exceed the FCC’s Occupational emissions limit.

Caution Sign 2A Striping
Used to alert individuals that they are entering an area that may exceed the FCC’s Occupational emissions limit. To be used when physical barriers are unable to be mounted on a rooftop per landlord or structural restrictions
Caution Sign 2B Tower
Used to alert individuals that they are entering an area that may exceed the FCC’s Occupational emissions limit. To be placed at the base of tower and monopole sites.

Caution Sign 2C Parapet (5” x 7”)
Used to alert individuals that they are entering an area that may exceed the FCC’s Occupational emissions limit. To be placed on parapet behind antennas for façade mounted sectors
Warning Sign 1B
Used to inform individuals that they are entering an area that may exceed the FCC’s Occupational emissions limit by a factor of 10 or greater. Shall be used when barriers are present or will be deployed around AT&T antennas
Warning Sign 2A
Used to inform individuals that they are entering an area that may exceed the FCC’s Occupational emissions limit by a factor of 10 or greater. Shall be used in lieu of barriers along with striping when barriers are not allowed

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9.0 Fall Arrest and Parapet Information
As per AT&T barrier policy, rooftop edges that are protected with a 39-inch parapet wall or guardrail are safe for work activity within six (6) feet of the edge. OSHA has stated that an existing 39-inch guardrail or parapet provides sufficient protection for employees. The height of the top rail or equivalent component of guardrail systems in new construction shall be at least 42 inches above the walking or working surface.

It should also be noted that the height of the parapet or guardrail may be reduced to no less than 30 inches at any point provided the sum of the depth (horizontal distance) of the top edge, and the height of the top edge (vertical distance from the work surface to the top edge of the top member, is at least 48 inches. If there is no reason for working atop the roof, then edge protection is not required. In addition, workers may use personnel lifts or temporary fall protection measures to perform work within 6 feet of the roof edge in place of permanent edge protection. Reference: 29 CFR 1910.28, 29 CFR 1910.23 (NPRM-1990); OSHA Letters of Interpretation 2/9/83 and 3/8/9

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10.0 FCC Guidelines
All power density values used in this report were analyzed as a percentage of current Maximum Permissible Exposure (% MPE) as listed in the FCC OET Bulletin 65 Edition 97-01and ANSI/IEEE Std C95.1. The FCC regulates Maximum Permissible Exposure in units of microwatts per square centimeter (μW/cm2). The number of μW/cm2 calculated at each sample point is called the power density. The exposure limit for power density varies depending upon the frequencies being utilized. Wireless Carriers and Paging Services use different frequency bands each with different exposure limits, therefore it is necessary to report results and limits in terms of percent MPE rather than power density.

All results were compared to the FCC (Federal Communications Commission) radio frequency exposure rules, 47 CFR 1.1307(b)(1) – (b)(3), to determine compliance with the Maximum Permissible Exposure (MPE) limits for General Population/Uncontrolled environments as defined below.

General Population/Uncontrolled exposure limits apply to situations in which the general Population may be exposed or in which persons who are exposed as a consequence of their employment may not be made fully aware of the potential for exposure or cannot exercise control over their exposure. Therefore, members of the general Population would always be considered under this category when exposure is not employment related, for example, in the case of a telecommunications tower that exposes persons in a nearby residential area.

General Population exposure to radio frequencies is regulated and enforced in units of microwatts per square centimeter (μW/cm2). The general population exposure limit for the 700 MHz and 800 MHz Bands is approximately 467 μW/cm2 and 567 μW/cm2 respectively, and the general population exposure limit for the 1900 MHz PCS band, 2100 MHz AWS band, 2300 MHz WCS band and 3600 MHz C-band is 1000 μW/cm2 (1mw/cm2
). Because each carrier will be using different frequency bands, and each frequency band has different exposure limits, it is necessary to report percent of MPE rather than power density.

Occupational/Controlled exposure limits apply to situations in which persons are exposed as a consequence of their employment and in which those persons who are exposed have been made fully aware of the potential for exposure, have been properly trained in RF safety and can exercise control over their exposure. Occupational/Controlled exposure 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 (see below), as long as the exposed person has been made fully aware of the potential for exposure, have been trained in RF safety and can exercise control over his or her exposure by leaving the area or by some other appropriate means. The Occupational/Controlled exposure limits all utilized frequency bands is five (5) times the FCC’s General Population / Uncontrolled exposure limit.

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Table 1: Limits for Maximum Permissible Exposure (MPE)
(A) Limits for Occupational/Controlled Exposure
Frequency Range
(MHz)
Electric Field Strength (E)
(V/m)
Magnetic Field Strength (H)
(A/m)
Power Density (S)
(mW/cm2)
Averaging Time [E]
2 ,
[H]
2 , or S
(minutes)

0.3-3.0 614 1.63 (100)* 6

3.0-30 1842/f 4.89/f (900/f2)* 6
30-300 61.4 0.163 1.0 6
300-I,500 -- -- f/300 6
1,500-100,000 -- -- 5 6
(B) Limits for General Population/Uncontrolled Exposure Frequency Range
(MHz)
Electric Field Strength (E)
(V/m)
Magnetic Field Strength (H)
(A/m)
Power Density (S)
(mW/cm2)
Averaging Time [E]
2 ,
[H]
2 , or S
(minutes)

0.3-1.34 614 1.63 (100)* 30

1.34-30 824/f 2.19/f (180/f2)* 30
30-300 27.5 0.073 0.2
30 300-I,500 -- -- f/1,500 30
1,500-100,000 -- -- 1.0
30 f = Frequency in (MHz)
* Plane-wave equivalent power density

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11.0 Calculation Methodology
Fox Hill Telecom has performed theoretical calculations on all transmission equipment located on this facility. All calculations have been performed using Waterford Consultants’ RoofMaster™ 2020 Version

35.5.26.2022. RoofMasterTM employs several power density prediction models based on the computational approaches set forth in the Federal Communications Commission’s Evaluating Compliance with FCC Guidelines for Human Exposure to Radiofrequency Electromagnetic Fields, OET Bulletin 65 utilizing both cylindrical and far-field modelling (calculated using antenna manufacturers pattern data).

For this analysis, power density calculations were performed by Fox Hill Telecom on two antenna models including a static beam antenna used for the UMTS and 4G radios and a dynamic beam-forming antenna for the 5G radio broadcast. The static beam results in a fixed coverage area based upon the electrical characteristics of the antenna as specified by the antenna manufacturer. The dynamic beam-forming antenna functions by allowing the carrier to shift a narrow “talk channel” beam to each user in the antennas service area for the provision of service to the user’s device by varying the phase of transmission by each active element in the element array inside the antenna to produce the desired resulting vector for the narrow beam. This allows greater gain in a given direction while producing intentional nulls in non-service areas to produce greater signal quality.

For the power density calculations for the UMTS / 4G static beam antennas the Cylindrical (Sula9) model was used to allow for a more pessimistic approach resulting from the transmission power being captured within the 3dB power roll off points of the antennas horizontal pattern. Calculations performed for the narrow beam 5G Traffic Beams were performed using a Far Field model based upon the antenna manufacturers antenna pattern data for both horizontal and vertical gain values. The selection of the Far Field model was done to prevent large overprediction areas of power density values close in to the antenna resulting from the extremely narrow window produced by the 3db power roll off points which define the power spreading area with a Cylindrical Model. Both models are discussed in further detail below.

A statistical factor which reduces the transmit power of the 5G beam forming antennas identified in this report to 32% of maximum theoretical transmit power for this antenna was used in the outlined calculations. This factor was utilized to account for the spatial distribution of users, network utilization, time division duplexing, and scheduling time typically experienced in these dynamic radio environments.

This power factor more accurately predicts the emitted radio frequency energy in any given direction based upon test results from the antenna system manufacturers and AT&T recommends the use of this factor based on this guidance from its antenna system manufacturers as well as supporting international industry standards, industry publications, and its extensive experience.

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The Cylindrical Model Implementation (Sula9)

In OET-65, the Cylindrical Model is presented as an approach to determine the spatially averaged power density in the near field directly in front of an antenna. In order to implement this model in all directions, RoofMasterTM utilizes the antenna manufacturer horizontal pattern data. Additionally, RoofMasterTM incorporates factors that reduce the power density by the inverse square of horizontal and vertical distance beyond the near field region.

Power density is calculated as follows:
ƒ S is the spatially averaged power density value
ƒ R is the horizontal distance meters to the study point ƒ h is the aperture length in meters
ƒ Pin is power into the antenna input port in Watts
ƒ RoofMasterTM Implementation:
ƒ GH is gain offset to study point as specified in manufacturer horizontal pattern ƒ Pin is adjusted by the portion of the antenna aperture in the 0-6 ft vertical study zone ƒ Hr accounts for 1/R2 Far Field roll off which starts at 2xh ƒ Vr accounts for 1/ (vertical distance)2 roll off from antenna bottom to the top of the 0-6ft study zone (or antenna top to bottom of 0-6ft study zone) Figure 1: Cylindrical Model Implementation.

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The Far Field Model

In OET-65, a far field model is presented to calculate the spatial peak power density. The RoofMasterTM implementation of this model incorporates antenna manufacturer’s horizontal and vertical pattern data to determine the power density in all directions. Power density is calculated as follows:
ƒ Does not include 100% reflection factor
ƒ Pin is Watts
ƒ R is meters to study point
ƒ G is gain to study point as specified in manufacturer horizontal and vertical patterns A worst-case prediction is described in OET-65 where field strength may double due to 100% reflection of the incoming radiation. Considering an EPA recommendation that a multiplier of 1.6 is a more realistically representation of this effect is rewritten as follow:

This model yields the power density at a single point in space. In order to determine the spatial power density for comparison to the FCC limits, the average of several points calculated within the human profile (0 to 6 feet) must be conducted.

RoofMasterTM calculates seven power density values between 0 and 6 feet above the specified study plane and performs a linear spatial average.

Figure 2 Far Field Model Implementation.

Predicted power densities are displayed as a percentage of the applicable FCC standards

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12.0 Certifications
I, Erin Mahaney, preparer of this report certify that I am fully trained and aware of the Rules and Regulations of both the Federal Communications Commissions (FCC) and the Occupational Safety and Health Administration (OSHA) with regard to Human Exposure to Radio Frequency Radiation. I have been trained in the procedures and requirements outlined in AT&T’s RF Exposure: Responsibilities, Procedures & Guidelines document.

1/6/2023
___________________________
I, Scott Heffernan, reviewer and approver of this report certify that I am fully trained and aware of the Rules and Regulations of both the Federal Communications Commissions (FCC) and the Occupational Safety and Health Administration (OSHA) with regard to Human Exposure to Radio Frequency Radiation. I have been trained in the procedures and requirements outlined in AT&T’s RF Exposure: Responsibilities, Procedures & Guidelines document.
_________________________ 1/6/2023

CO-LOCATION INTERFERENCE ANALYSIS REPORT
AT&T
CSL04615
Mammoth Lakes Fire Protection District
1574 Old Mammoth Lakes Road
Mammoth Lakes, CA 93546
Delivered: September 19, 2023
Fox Hill Telecom Project Number: 230987
Prepared by:

Fox Hill Telecom, Inc
79 Fox Hill Drive
Holden, MA 01520
Professional Engineer Review Stamp
sealed 20sep2023

TOWN OF

MAMMOTH LAKES

RECEIVED
9/22/2023

Table of Contents

1.0 Executive Summary .............................................................................................................. 1

2.0 Site Description .................................................................................................................... 2

2.1 Communications Systems ................................................................................................... 3

2.2 Antenna Systems ................................................................................................................. 4

3.0 Transmitter Frequencies ...................................................................................................... 5

4.0 Receiver Frequencies ........................................................................................................... 7

5.0 Transmitter Noise Analysis ................................................................................................. 9

6.0 Receiver Desensitization Analysis .................................................................................... 12

7.0 Intermodulation Interference Analysis ............................................................................. 15

7.1 Transmitter Generated Intermodulation Analysis ............................................................... 17

7.2 Receiver Generated Intermodulation Analysis ................................................................... 18

8.0 Transmitter Harmonic Output Interference Analysis ....................................................... 19

9.0 Transmitter Spurious Output Interference Analysis ........................................................ 20

10.0 Summary & limitations .................................................................................................... 21

AT&T CSL04615_Mammoth Lakes Fire (Mammoth Lakes CA)
Fox Hill Telecom, Inc Holden, MA | Charleston, SC Page 1

1.0 Executive Summary
This report presents a radio frequency interference (RFI) analysis which was performed on the AT&T CSL04615_Mammoth Lakes Fire (Mammoth Lakes CA) site. The RFI analysis consists of transmitter noise, receiver desensitization, intermodulation, harmonic and transmitter spurious output interference. The report consists of Sections that provide details of the communications site, antenna systems, operational frequencies and each interference analysis mode.

A summary of the interference analysis results is depicted in the following Table.

Interference Analysis Mode
Type
Mix Status Summary
Worst-Case
Margin (dB)
Transmitter Noise N/A Passed No Interference was predicted 17.1 Receiver Desensitization N/A Passed No Interference was predicted 32.3 Transmitter Intermodulation 1 Tx Passed No Interference was predicted N/A Transmitter Intermodulation 2 Tx Passed No Interference was predicted N/A Transmitter Intermodulation 3 Tx Passed No Interference was predicted N/A Transmitter Intermodulation 4 Tx Passed No Interference was predicted N/A Transmitter Intermodulation 5 Tx Passed No Interference was predicted N/A Receiver Intermodulation 1 Tx Passed No Interference was predicted N/A Receiver Intermodulation 2 Tx Passed No Interference was predicted N/A Receiver Intermodulation 3 Tx Passed No Interference was predicted N/A Receiver Intermodulation 4 Tx Passed No Interference was predicted N/A Receiver Intermodulation 5 Tx Passed No Interference was predicted N/A Transmitter Harmonics N/A Passed No Interference was predicted N/A Transmitter Spurious Output N/A Passed No Interference was predicted N/A The analysis was performed with the setup options depicted in the Table below.

Analysis Description
Receiver Performance Receiver Sensitivity Threshold
Receiver Bandwidth Receiver Dependent
Antenna Patterns Considered Yes
Measured Antenna Isolation Data No
Filters/Multicouplers Considered Yes
Number of Simultaneous Transmitters Mixed 5
Highest Intermodulation Order Tested 7
Condense Intermodulation Hit Quantity Yes - 1000/Order
TX IM Bandwidth Multiplication No
Tx/Rx Systems Excluded None
Site File Name AT&T CSL04615_Mammoth Lakes Fire.dta
Report File Name AT&T CSL04615_Mammoth Lakes Fire.docx
WirelessSiteRFI Software Version 10.1.20C

AT&T CSL04615_Mammoth Lakes Fire (Mammoth Lakes CA)
Fox Hill Telecom, Inc Holden, MA | Charleston, SC Page 2

2.0 Site Description
The communication systems located at this site are described in this section as well as the configuration of the antenna systems.

The site parameters are:

Site Name: AT&T CSL04615_Mammoth Lakes Fire (Mammoth Lakes CA) Owner: Mammoth Lakes Fire Protection District
Site Description: Monopine Facility
Address: 1574 Old Mammoth Road, Mammoth Lakes, CA 93546 Latitude: 37.630061 N
Longitude: -118.977772 W
Elevation: 7925.9 feet AMSL
Notes: This analysis was performed between the AT&T proposed radio systems to be installed on a tower facility at the Mammoth Lakes Fire Protection District property at 1574 Old Mammoth Road in Mammoth Lakes, CA and several radio systems owned and operated by the Mammoth Lakes municipal public safety agencies as well as county and state agencies. The radio system data for the entities that requested to be considered in this study are listed in the Communications Systems table in Section 2.1 and further detailed in the following sections.

The radio systems provided by the Mammoth Lakes Fire Protection District are located at facilities in various locations around the county. To produce a worst-case isolation scenario, it was assumed that all radio systems provided by the Mammoth Lakes Fire Protection District were located on the rooftop of the 35-foot fire department building located on the subject property.

Since many of these radio systems are located at further distances from the proposed AT&T tower facility, the isolation between these systems will be greater than detailed in this report which should result in a further reduction in interference potential.

The scope of this analysis was limited to the proposed AT&T radio systems to be installed at the proposed tower facility on the subject property as well as the systems and data provided by the Mammoth Lakes Fire Protection District.

AT&T CSL04615_Mammoth Lakes Fire (Mammoth Lakes CA)
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2.1 Communications Systems
System Provider Technology Frequency Band
1 AT&T LTE 700 MHz Band
2 AT&T 5G 850 MHz - Cellular Band
3 AT&T LTE 1900 MHz PCS
4 AT&T 5G C Band
5 AT&T 5G DoD Band - B77D
6 AT&T LTE / Band 14 700 MHz Band (Band 14)
7 AT&T LTE 2100 MHz AWS
8 AT&T LTE 2300 MHz WCS
9 AT&T Microwave 11 GHz Microwave
10 County Fire - Mono Co Fire Dispatch (Channel 1) FM Land Mobile 150 - 174 MHz - Land Mobile 11 CMD Lincoln - MLFD Command Lincoln (Channel #2) FM Land Mobile 150 - 174 MHz - Land Mobile 12 MLFD TAC 3 (Channel #3) FM Land Mobile 150 - 174 MHz - Land Mobile 13 USFS INF_INF North (Channel #5) FM Land Mobile 150 - 174 MHz - Land Mobile 14 MLPD - MLPD Dispatch (Channel #4) FM Land Mobile 150 - 174 MHz - Land Mobile 15 CLEMARS - CA Law Enf Mutual Aid (Channel #14) FM Land Mobile 150 - 174 MHz - Land Mobile

AT&T CSL04615_Mammoth Lakes Fire (Mammoth Lakes CA)
Fox Hill Telecom, Inc Holden, MA | Charleston, SC Page 4

2.2 Antenna Systems
Ant
# Mfg Antenna Model
Gain
(dBd)
Hgt
(ft)
Orient
(deg) Sector
Ant
Use
Transmission
Line Type
Line
Loss
(/100')
Line
Length
(ft)
1 Commscope NNH4-65C-R6-V3 14.91 70 10 A Dplx 1/2 in. Foam 0.5 10 2 Commscope NNH4-65C-R6-V3 14.91 70 130 B Dplx 1/2 in. Foam 0.5 10 3 Commscope NNH4-65C-R6-V3 14.91 70 260 C Dplx 1/2 in. Foam 0.5 10 4 Ericsson AIR6449_B77D 23.4 69.3 10 A Dplx 1/2 in. Foam 0.5 10 5 Ericsson AIR6449_B77D 23.4 69.3 130 A Dplx 1/2 in. Foam 0.5 10 6 Ericsson AIR6449_B77D 23.4 69.3 260 A Dplx 1/2 in. Foam 0.5 10 7 Ericsson AIR6419_B77G 23.4 66.1 10 C Dplx 1/2 in. Foam 0.5 10 8 Ericsson AIR6419_B77G 23.4 66.1 130 A Dplx 1/2 in. Foam 0.5 10 9 Ericsson AIR6419_B77G 23.4 66.1 260 B Dplx 1/2 in. Foam 0.5 10 10 CCI OPA65R-BU8DA-K 13 70 10 A Dplx 1/2 in. Foam 0.5 10 11 CCI OPA65R-BU8DA-K 13 70 130 B Dplx 1/2 in. Foam 0.5 10 12 CCI OPA65R-BU8DA-K 13 70 260 C Dplx 1/2 in. Foam 0.5 10 13 CCI OPA65R-BU8DA-K 15.3 70 10 A Dplx 1/2 in. Foam 0.5 10 14 CCI OPA65R-BU8DA-K 15.3 70 130 B Dplx 1/2 in. Foam 0.5 10 15 CCI OPA65R-BU8DA-K 15.3 70 260 C Dplx 1/2 in. Foam 0.5 10 16 CCI VHP4-107 38.2 55 100 A Dplx 1/2 in. Foam 0.5 10
17 Celwave PD200 5.6 35 0 A Dplx 7/8 in. Foam 0.45 65
18 Celwave PD200 5.6 35 0 A Dplx 7/8 in. Foam 0.45 65
19 Celwave PD200 5.6 35 0 A Tx/Rx 7/8 in. Foam 0.45 65
20 Celwave PD200 5.6 35 0 A Dplx 7/8 in. Foam 0.45 65
21 Celwave PD200 5.6 35 0 A Dplx 7/8 in. Foam 0.45 65
22 Celwave PD200 5.6 35 0 A Tx/Rx 7/8 in. Foam 0.45 65

AT&T CSL04615_Mammoth Lakes Fire (Mammoth Lakes CA)
Fox Hill Telecom, Inc Holden, MA | Charleston, SC Page 5

3.0 Transmitter Frequencies
Freq
#
Ant
# Provider Model Technology Channel Label ID
Frequency
(MHz)
Power
(Watts)
BW
(KHz)
1 1 AT&T Ericsson LTE 1 A 740.000000 160 10000
2 2 AT&T Ericsson LTE 1 B 740.000000 160 10000
3 3 AT&T Ericsson LTE 1 C 740.000000 160 10000
4 1 AT&T Ericsson LTE / 5G 2 D 875.000000 160 10000
5 2 AT&T Ericsson LTE / 5G 2 E 875.000000 160 10000
6 3 AT&T Ericsson LTE / 5G 2 F 875.000000 160 10000
7 1 AT&T Ericsson LTE 1 G 1955.000000 160 20000
8 2 AT&T Ericsson LTE 1 H 1955.000000 160 20000
9 3 AT&T Ericsson LTE 1 I 1955.000000 160 20000
10 1 AT&T Ericsson LTE 1 J 1985.000000 160 10000
11 2 AT&T Ericsson LTE 1 K 1985.000000 160 10000
12 3 AT&T Ericsson LTE 1 L 1985.000000 160 10000
13 4 AT&T Ericsson 5G C1 M 3870.000000 20 20000
14 4 AT&T Ericsson 5G C2 N 3890.000000 20 20000
15 4 AT&T Ericsson 5G C3 O 3910.000000 20 20000
16 4 AT&T Ericsson 5G C4 P 3930.000000 20 20000
17 4 AT&T Ericsson 5G C5 Q 3950.000000 20 20000
18 4 AT&T Ericsson 5G C6 R 3970.000000 20 20000
19 5 AT&T Ericsson 5G C1 S 3870.000000 20 20000
20 5 AT&T Ericsson 5G C2 T 3890.000000 20 20000
21 5 AT&T Ericsson 5G C3 U 3910.000000 20 20000
22 5 AT&T Ericsson 5G C4 V 3930.000000 20 20000
23 5 AT&T Ericsson 5G C5 W 3950.000000 20 20000
24 5 AT&T Ericsson 5G C6 X 3970.000000 20 20000
25 6 AT&T Ericsson 5G C1 Y 3870.000000 20 20000
26 6 AT&T Ericsson 5G C2 Z 3890.000000 20 20000
27 6 AT&T Ericsson 5G C3 AA 3910.000000 20 20000
28 6 AT&T Ericsson 5G C4 AB 3930.000000 20 20000
29 6 AT&T Ericsson 5G C5 AC 3950.000000 20 20000
30 6 AT&T Ericsson 5G C6 AD 3970.000000 20 20000
31 7 AT&T Ericsson 5G DoD_1 AE 3460.000000 20 20000
32 8 AT&T Ericsson 5G DoD_1 AF 3460.000000 20 20000
33 9 AT&T Ericsson 5G DoD_1 AG 3460.000000 20 20000
34 7 AT&T Ericsson 5G DoD_2 AH 3480.000000 20 20000
35 8 AT&T Ericsson 5G DoD_2 AI 3480.000000 20 20000
36 9 AT&T Ericsson 5G DoD_2 AJ 3480.000000 20 20000
37 7 AT&T Ericsson 5G DoD_3 AK 3500.000000 20 20000
38 8 AT&T Ericsson 5G DoD_3 AL 3500.000000 20 20000
39 9 AT&T Ericsson 5G DoD_3 AM 3500.000000 20 20000
40 7 AT&T Ericsson 5G DoD_4 AN 3520.000000 20 20000
41 8 AT&T Ericsson 5G DoD_4 AO 3520.000000 20 20000
42 9 AT&T Ericsson 5G DoD_4 AP 3520.000000 20 20000
43 7 AT&T Ericsson 5G DoD_5 AQ 3540.000000 20 20000
44 8 AT&T Ericsson 5G DoD_5 AR 3540.000000 20 20000
45 9 AT&T Ericsson 5G DoD_5 AS 3540.000000 20 20000
46 10 AT&T Ericsson LTE 1 AT 763.000000 160 10000
47 11 AT&T Ericsson LTE 1 AU 763.000000 160 10000
48 12 AT&T Ericsson LTE 1 AV 763.000000 160 10000
49 10 AT&T Ericsson LTE 1 AW 2135.000000 160 10000
50 11 AT&T Ericsson LTE 1 AX 2135.000000 160 10000
51 12 AT&T Ericsson LTE 1 AY 2135.000000 160 10000
52 13 AT&T Ericsson LTE 1 AZ 2355.000000 120 10000
53 14 AT&T Ericsson LTE 1 BA 2355.000000 120 10000
54 15 AT&T Ericsson LTE 1 BB 2355.000000 120 10000
55 16 AT&T Other Microwave MW1 BC 10850.000000 .63 5000 56 17
County Fire - Mono Co
Fire Dispatch (Channel
1) Motorola FM Land Mobile CH 1 BD 155.760000 25 11.2

AT&T CSL04615_Mammoth Lakes Fire (Mammoth Lakes CA)
Fox Hill Telecom, Inc Holden, MA | Charleston, SC Page 6 57 18
CMD Lincoln - MLFD
Command Lincoln
(Channel #2) Motorola FM Land Mobile CH 2 BE 158.985000 25 11.2 58 19
MLFD TAC 3 (Channel
#3) Motorola FM Land Mobile CH 3 BF 153.950000 25 11.2
59 20
USFS INF_INF North
(Channel #5) Motorola FM Land Mobile CH 5 BG 165.012500 25 11.2 60 21
MLPD - MLPD Dispatch
(Channel #4) Motorola FM Land Mobile CH 4 BH 159.012500 25 11.2 61 22
CLEMARS - CA Law
Enf Mutual Aid
(Channel #14) Motorola FM Land Mobile CH 14 BI 154.920000 25 11.2

AT&T CSL04615_Mammoth Lakes Fire (Mammoth Lakes CA)
Fox Hill Telecom, Inc Holden, MA | Charleston, SC Page 7

4.0 Receiver Frequencies
Freq
#
Ant
# Provider Model Technology Channel Label ID
Frequency
(MHz)
Sen
(dBm)
BW
(KHz)
1 1 AT&T Ericsson LTE 1 A 710.000000 -110 10000
2 2 AT&T Ericsson LTE 1 B 710.000000 -110 10000
3 3 AT&T Ericsson LTE 1 C 710.000000 -110 10000
4 1 AT&T Ericsson LTE / 5G 2 D 830.000000 -110 10000
5 2 AT&T Ericsson LTE / 5G 2 E 830.000000 -110 10000
6 3 AT&T Ericsson LTE / 5G 2 F 830.000000 -110 10000
7 1 AT&T Ericsson LTE 1 G 1875.000000 -110 20000
8 2 AT&T Ericsson LTE 1 H 1875.000000 -110 20000
9 3 AT&T Ericsson LTE 1 I 1875.000000 -110 20000
10 1 AT&T Ericsson LTE 1 J 1900.000000 -110 10000
11 2 AT&T Ericsson LTE 1 K 1900.000000 -110 10000
12 3 AT&T Ericsson LTE 1 L 1900.000000 -110 10000
13 4 AT&T Ericsson 5G C1 M 3870.000000 -110 20000
14 4 AT&T Ericsson 5G C2 N 3890.000000 -110 20000
15 4 AT&T Ericsson 5G C3 O 3910.000000 -110 20000
16 4 AT&T Ericsson 5G C4 P 3930.000000 -110 20000
17 4 AT&T Ericsson 5G C5 Q 3950.000000 -110 20000
18 4 AT&T Ericsson 5G C6 R 3970.000000 -110 20000
19 5 AT&T Ericsson 5G C1 S 3870.000000 -110 20000
20 5 AT&T Ericsson 5G C2 T 3890.000000 -110 20000
21 5 AT&T Ericsson 5G C3 U 3910.000000 -110 20000
22 5 AT&T Ericsson 5G C4 V 3930.000000 -110 20000
23 5 AT&T Ericsson 5G C5 W 3950.000000 -110 20000
24 5 AT&T Ericsson 5G C6 X 3970.000000 -110 20000
25 6 AT&T Ericsson 5G C1 Y 3870.000000 -110 20000
26 6 AT&T Ericsson 5G C2 Z 3890.000000 -110 20000
27 6 AT&T Ericsson 5G C3 AA 3910.000000 -110 20000
28 6 AT&T Ericsson 5G C4 AB 3930.000000 -110 20000
29 6 AT&T Ericsson 5G C5 AC 3950.000000 -110 20000
30 6 AT&T Ericsson 5G C6 AD 3970.000000 -110 20000
31 7 AT&T Ericsson 5G DoD_1 AE 3460.000000 -110 20000
32 8 AT&T Ericsson 5G DoD_1 AF 3460.000000 -110 20000
33 9 AT&T Ericsson 5G DoD_1 AG 3460.000000 -110 20000
34 7 AT&T Ericsson 5G DoD_2 AH 3480.000000 -110 20000
35 8 AT&T Ericsson 5G DoD_2 AI 3480.000000 -110 20000
36 9 AT&T Ericsson 5G DoD_2 AJ 3480.000000 -110 20000
37 7 AT&T Ericsson 5G DoD_3 AK 3500.000000 -110 20000
38 8 AT&T Ericsson 5G DoD_3 AL 3500.000000 -110 20000
39 9 AT&T Ericsson 5G DoD_3 AM 3500.000000 -110 20000
40 7 AT&T Ericsson 5G DoD_4 AN 3520.000000 -110 20000
41 8 AT&T Ericsson 5G DoD_4 AO 3520.000000 -110 20000
42 9 AT&T Ericsson 5G DoD_4 AP 3520.000000 -110 20000
43 7 AT&T Ericsson 5G DoD_5 AQ 3540.000000 -110 20000
44 8 AT&T Ericsson 5G DoD_5 AR 3540.000000 -110 20000
45 9 AT&T Ericsson 5G DoD_5 AS 3540.000000 -110 20000
46 10 AT&T Ericsson LTE 1 AT 793.000000 -110 10000
47 11 AT&T Ericsson LTE 1 AU 793.000000 -110 10000
48 12 AT&T Ericsson LTE 1 AV 793.000000 -110 10000
49 10 AT&T Ericsson LTE 1 AW 1735.000000 -110 10000
50 11 AT&T Ericsson LTE 1 AX 1735.000000 -110 10000
51 12 AT&T Ericsson LTE 1 AY 1735.000000 -110 10000
52 13 AT&T Ericsson LTE 1 AZ 2310.000000 -110 10000
53 14 AT&T Ericsson LTE 1 BA 2310.000000 -110 10000
54 15 AT&T Ericsson LTE 1 BB 2310.000000 -110 10000
55 16 AT&T Other Microwave MW1 BC 11675.000000 -83 5000 56 17
County Fire - Mono Co
Fire Dispatch (Channel
1) Motorola FM Land Mobile CH 1 BD 153.860000 -116 11.2

AT&T CSL04615_Mammoth Lakes Fire (Mammoth Lakes CA)
Fox Hill Telecom, Inc Holden, MA | Charleston, SC Page 8 57 18
CMD Lincoln - MLFD
Command Lincoln
(Channel #2) Motorola FM Land Mobile CH 2 BE 155.145000 -116 11.2 58 19
MLFD TAC 3 (Channel
#3) Motorola FM Land Mobile CH 3 BF 153.950000 -116 11.2 59 20
USFS INF_INF North
(Channel #5) Motorola FM Land Mobile CH 5 BG 173.800000 -116 11.2 60 21

MLPD - MLPD
Dispatch (Channel #4) Motorola FM Land Mobile CH 4 BH 155.595000 -116 11.2 61 22
CLEMARS - CA Law
Enf Mutual Aid
(Channel #14) Motorola FM Land Mobile CH 14 BI 154.920000 -116 11.2

AT&T CSL04615_Mammoth Lakes Fire (Mammoth Lakes CA)
Fox Hill Telecom, Inc Holden, MA | Charleston, SC Page 9

5.0 Transmitter Noise Analysis
Transmitter noise interference occurs because a transmitter radiates energy on its operating frequency as well as frequencies above and below the assigned frequency. The energy that is radiated above and below the assigned frequency is known as sideband noise energy and extends for several megahertz on either side of the operating frequency. This undesired noise energy can fall within the passband of a nearby receiver even if the receiver's operating frequency is several megahertz away. The transmitter noise appears as "on-channel" noise interference and cannot be filtered out at the receiver. It is on the receiver's operating frequency and competes with the desired signal, which in effect, degrades the operational performance.

The analysis predicts each transmitter’s noise signal level present at the input of each receiver. It takes into account the transmitter’s noise characteristics, frequency separation, power output, transmission line losses, filters, duplexers, combiners, isolators, multi-couplers and other RF devices that are present in both systems. Additionally, the analysis considers the antenna separation space loss, horizontal and vertical gain components of the antennas as well as how they are mounted on the structure. The gain components are derived from antenna pattern data published by each manufacturer.

The analysis determines how much isolation is required, if any, to prevent receiver performance degradation caused by transmitter noise interference. The Table below depicts the results of this analysis. For each receiver, the transmitter that has the worst-case impact is displayed. The Signal Margin represents the margin in dB, before the receiver’s performance is degraded. A negative number indicates that the performance is degraded and the value indicates how much additional isolation is required to prevent receiver performance degradation.

Receiver
Provider
Receive
Channel
Receive
Frequency
(MHz)
Transmitter
Provider
Transmit
Channel
Transmit
Frequency
(MHz)
Attn
Required
(dB)
Attn
Provided
(dB)
Signal
Margin
(dB)
AT&T 1 710.000000 AT&T 1 740.000000 48 97 49
AT&T 1 710.000000 AT&T 1 740.000000 48 97 49
AT&T 1 710.000000 AT&T 1 740.000000 48 97 49
AT&T 2 830.000000 AT&T 2 875.000000 51.6 96.8 45.2
AT&T 2 830.000000 AT&T 2 875.000000 51.6 96.8 45.2
AT&T 2 830.000000 AT&T 2 875.000000 51.6 96.8 45.2
AT&T 1 1875.000000 AT&T 1 1955.000000 54.6 96.5 41.9
AT&T 1 1875.000000 AT&T 1 1955.000000 54.6 96.5 41.9
AT&T 1 1875.000000 AT&T 1 1955.000000 54.6 96.5 41.9
AT&T 1 1900.000000 AT&T 1 1985.000000 54.6 96.5 41.9
AT&T 1 1900.000000 AT&T 1 1985.000000 54.6 96.5 41.9
AT&T 1 1900.000000 AT&T 1 1985.000000 54.6 96.5 41.9
AT&T C1 3870.000000 AT&T C1 3870.000000 56.6 102 45.4
AT&T C1 3870.000000 AT&T C1 3870.000000 56.6 101.8 45.2 AT&T C2 3890.000000 AT&T C1 3870.000000 54.4 96.5 42.1
AT&T C2 3890.000000 AT&T C2 3890.000000 56.6 102 45.4
AT&T C2 3890.000000 AT&T C2 3890.000000 56.6 101.9 45.3 AT&T C3 3910.000000 AT&T C2 3890.000000 54.4 96.5 42.1
AT&T C3 3910.000000 AT&T C3 3910.000000 56.6 102 45.4
AT&T C3 3910.000000 AT&T C3 3910.000000 56.6 101.9 45.3 AT&T C4 3930.000000 AT&T C3 3910.000000 54.4 106.9 52.5 AT&T C4 3930.000000 AT&T C4 3930.000000 56.6 102 45.4
AT&T C4 3930.000000 AT&T C4 3930.000000 56.6 102 45.4