Cities Index.
Attachment C - Objective Standards for WCF (proposed for repeal)

Palo Alto City Council
May 19, 2025

Document
Attachment C - Objective Standards for WCF (proposed for repeal)
Meeting
May 19, 2025
Body
Palo Alto City Council
Original file
1.9 MB
Text extracted from the city's file for reading and search. Open the original on cityofpaloalto.primegov.com. That file is the official record.

1 Resolution No. 9873
Resolution of the Council of the City of Palo Alto Amending Objective Aesthetic, Noise, and Related Standards for
Wireless Communication Facilities in the Public Rights of Way The Council of the City of Palo Alto RESOLVES as follows:

SECTION 1. Findings and Declarations.
a. On April 15, 2019, the City Council adopted Resolution 9825, establishing objective aesthetic, noise, and related standards for Wireless Communication Facilities (WCFs) on Streetlight and Wood Utility Poles in the Public Rights-of-Way.
b. On June 17, 2019, the City Council adopted Resolution 9847, amending the standards to delete inadvertently added language, clarify existing standards, and adopt an interim setback from public schools.
c. On August 12, 2019, the City Council adopted Resolution 9855, amending the standards to address a conflict with other City standards and to clarify the allowable height for WCFs on Streetlights and Wood Utility Poles.
d. The City Council wishes to consolidate the existing objective standards previously described in Resolution 9855 for clarity and update the objective standards in order to address Council specified location, design, and other preferences in the City for WCF on Streetlight Poles and Wood Utility Poles.

SECTION 2. Objective Standards for WCFs on Streetlight Poles and Wood Utility Poles in the Public Rights-of-Way Amended.

The City Council hereby adopts the objective standards in Exhibit 1, attached to and incorporated into this resolution, for Wireless Communication Facilities in the Public Rights of Way on Streetlight Poles and Wood Utility Poles.

The City Council hereby adopts Exhibit 2 that illustrates the Residential Zone of Exclusion and Exhibit 3 that illustrates the City of Palo Alto roadway network and locations of special setbacks relative to generalized zoning designations for the sole purpose of supplementing the objective standards in Exhibit 1.

SECTION 3. If any section, subsection, clause or phrase of this resolution or the attached standards is for any reason held to be invalid, such decision shall not affect the validity of the remaining portion or sections of the resolution and exhibits. The Council hereby declares that it should have DocuSign Envelope ID: ECCACC0E-18AC-4D5E-9AEE-0C930810BD0A Attachment C

2 adopted the resolution and exhibits, and each section, subsection, sentence, clause or phrase thereof irrespective of the fact that any one or more sections, subsections, sentences, clauses or phrases be declared invalid.

SECTION 4. Environmental Review. The Council finds that this resolution is exempt from the provisions of the California Environmental Quality Act (“CEQA”), pursuant to Section 15061 of the CEQA Guidelines, because it does not authorize the construction of Wireless Communication Facilities in any locations where such facilities are not already permitted; therefore it can be seen with certainty that there is no possibility that the ordinance will have a significant effect on the environment. The resolution is further exempt under CEQA Guidelines sections 15301, 15302, 15303 and 15305 because it represents part of a comprehensive regulatory scheme governing minor alterations to existing facilities or small structures.

INTRODUCED AND PASSED: December 16, 2019
AYES: CORMACK, DUBOIS, FILSETH, KNISS, KOU, TANAKA
NOES: FINE
ABSENT:

ABSTENTIONS:

ATTEST:

City Clerk Mayor

APPROVED AS TO FORM: APPROVED:

Deputy City Attorney City Manager

Director of Planning and Development
Services
DocuSign Envelope ID: ECCACC0E-18AC-4D5E-9AEE-0C930810BD0A Attachment C
3 Exhibit 1
Objective Standards for Wireless Communication Facilities in the Public Rights of Way on Streetlight Poles and Wood Utility Poles

A Wireless Communication Facility (WCF) proposed for the public right of way must comply with the applicable provisions of the City’s Municipal Code and all of the following objective standards. In each instance where a proposed facility is unable to comply with the City’s objective standards, a WCF Exception may be requested and evaluated in accordance with this resolution and PAMC Section

18.42.110(k).1The following standards apply to both streetlight poles and wood utility poles, unless otherwise noted.

WCF SITING STANDARDS
Permitted Zoning Districts WCF placement is permitted in non-residential zoning districts.

Public School Boundary A WCF shall not be placed within 600 feet of a parcel containing a public school. No WCF Exception shall be granted allowing a WCF to be placed closer than 300 feet to a parcel containing a public school.

Residential Zone of Exclusion
(this standard applies to WCF Exception
requests to locate in residential
districts)
No WCF shall be placed within the public right of way in the area between the street centerline and the central fifty percent (50%) of the immediately adjacent parcel’s front lot line. The central fifty percent standard shall be based on the parcel’s lot width2. For corner lots, the central fifty percent standard along the street lot line3 shall be based on the parcel’s lot depth4. Exhibit 2 illustrates this requirement.

Residential Roadways
(this standard applies to WCF Exception
requests to locate in residential
districts)
Any request for a WCF Exception involving placement of a WCF within a residential zoning district shall prioritize WCF placement on the following roadway types (See Exhibit 3):

 Expressways
 Arterials
 Residential Arterials
 Roadways identified with a Special Setback (including collector and local streets).
1 The City may hire an independent consultant to evaluate WCF Exceptions at applicant’s expense. 2 Palo Alto Municipal Code Section 18.04.030(a)(93)
3 Palo Alto Municipal Code Section 18.04.030(a)(91)(E)
4 Palo Alto Municipal Code Section 18.04.030(a)(87)
DocuSign Envelope ID: ECCACC0E-18AC-4D5E-9AEE-0C930810BD0A Attachment C
4 In each instance above, the priority shall be for placement of a WCF most distant from residential property.

An additional WCF Exception request must be made to place a WCF on a collector or a local roadway that does not have an identified special setback.

Building or Structure Setback A WCF shall not be placed closer than 20 feet from any building used for occupancy in any zoning district.

Distance Between WCFs A WCF shall not be placed less than 600 feet away from another WCF. This requirement does not preclude WCFs collocating on the same structure where otherwise allowed.

Intersection Corners5 A WCF shall not be placed less than 20 feet away from any roadway intersection. An intersection is measured from the start of the curb radius.

Scenic Routes6 A WCF shall not be placed along an identified scenic route.

Historic Districts, Sites, and
Structures
A WCF shall not be placed within a listed historic district, nor immediately adjacent to a parcel with an historic structure, nor immediately adjacent to an historic site, as those terms are defined by PAMC Section 16.49.020.

A WCF shall not be placed in a potential historic district, or immediately adjacent to a potential historic structure or site, where the application for historic designation was filed with the City prior to the filing of a WCF application, until a final decision has been made regarding that pending historic designation.

WCF DESIGN STANDARDS
Underground Design
(Preferred Option)
Radio equipment shall be placed in an underground vault. The associated antenna(s) shall be placed in a shroud at the top of a nearby pole.

Underground vaults shall be the minimum volume necessary to house WCF equipment and include information detailing why the proposed dimensions are required. Maximum vault size shall not exceed 5 feet 8-inches x 8 feet 2-inches x 5 feet 7-inches or 260 cubic feet, excluding space required for ventilation or sump pump equipment.

5 Gateway intersections are identified on Map L-4 in the Comprehensive Plan. 6 Scenic routes are identified in Policy L-9.1 in the Comprehensive Plan.

DocuSign Envelope ID: ECCACC0E-18AC-4D5E-9AEE-0C930810BD0A Attachment C
5 Top-Mounted Design
(Secondary Option)
Radio equipment and the associated antenna(s) shall be enclosed within a shroud at the top of the pole.

Minimal Sunshield Design
Use of this design requires a WCF
Exception
Radio equipment shall be enclosed within one or two sunshields not exceeding 8 inches wide nor 0.75 cubic feet in volume each, mounted directly to the side of the pole. The associated antenna(s) shall be placed in a shroud at the top of the pole.

Sunshields shall be attached at least 12 feet above ground level and, when located on wood utility poles, shall not interfere with the identified communication space.

Existing Signage Design
Use of this design requires a WCF
Exception
Radio equipment shall be attached to a pole behind existing signage under the following conditions:

i) Radio equipment shall be placed within a shroud that does not exceed the dimensions of the sign in height and width, nor 4 inches in depth, including any required mounting bracket. ii) In no event shall WCF equipment obscure or interfere with the visibility or functioning of the signage.

The associated antenna(s) shall be placed in a shroud at the top of the pole.

WCF Antenna and Shroud
Dimensions (Diameter / Height)
Antennas shall have the smallest size possible to achieve the coverage objective.

The diameter of the antenna and shroud shall not exceed 15 inches at their widest.

For Streetlight Poles: The maximum WCF height shall not exceed 3 feet (or 5.5 feet for top-mounted designs) from the top of the streetlight pole that meets the City standards for the proposed location.

The associated “antenna skirt” shall taper to meet the pole above the mast arm.

For Wood Utility Poles: In no circumstance shall the total height of a pole and all WCF equipment exceed 55 feet. For wood utility poles carrying power lines, replacement poles shall be the minimum height necessary to provide GO 95 mandated clearance between WC equipment and power lines. For wood utility poles without power lines, any WCF equipment shall not increase the height of the pole by 5.5 feet when compared with the height of the existing pole.

DocuSign Envelope ID: ECCACC0E-18AC-4D5E-9AEE-0C930810BD0A Attachment C
6 The associated “antenna skirt” shall taper to meet the top of the pole if wider than the pole.

WCF Design Quality Antennas and/or equipment at the top of the pole shall be covered by a single integrated shroud and “antenna skirt” designed without gaps between materials or sky visible between component surfaces and between the shroud or skirt and the top of the pole.

All components external to the pole shall have an integral color or shall be painted to match the color and/or materials of the pole.

Equipment shall be oriented to face in either of the directions of travel in the right of way and shall not face or extend toward private property or the curb line.

WCF Equipment Adjustment For Streetlight Poles: Equipment that cannot propagate an adequate signal within the shrouding required by the standard designs shall be attached to a streetlight pole at a height of 2 feet below the light mast or higher. Each instance of such equipment shall not exceed 0.85 cubic feet, nor shall the total volume of such equipment and any shrouding exceed 2.6 cubic feet per streetlight pole.

For Wood Utility Poles:

Equipment that cannot propagate an adequate signal within the shrouding required by the standard designs shall be attached to the top of the pole or on a cross arm or brace protruding from the pole the minimum extent necessary to comply with safety standards, including GO 95. Such cross arm shall be placed as high on the pole as technically feasible. Each instance of such equipment shall not exceed 0.85 cubic feet nor shall the total volume of such equipment exceed 2.6 cubic feet per wood utility pole.

Curb Clearances Any WCF attachments placed below 16 feet above ground level shall not be placed closer than 18 inches to the curb, nor shall they extend over the sidewalk (Caltrans Highway Design Manual Section 309).

All WCF equipment shall maintain at least 3 feet from any curb cut.

WCF Wires and Cabling For Streetlight Poles: All wires and cabling shall be routed entirely underground and within the pole and any attached shroud.

For Wood Utility Poles: All wires and cabling to equipment shall be within the shroud or shall be within conduit. All conduit shall be mounted flush to the pole.

DocuSign Envelope ID: ECCACC0E-18AC-4D5E-9AEE-0C930810BD0A Attachment C
7 Safety Signs Safety signs shall be the smallest size possible to accomplish its purpose.

Power Disconnects For Streetlight Poles: Power disconnects shall be labeled and placed in a vault near the base of the pole.

For Wood Utility Poles: Power disconnects shall be labeled and placed on the wood pole or in a vault near the base of the pole.

Ground Mounted Equipment Except as provided in these standards, no equipment cabinets may be placed at grade.

Existing Pole Locations A WCF shall utilize an existing streetlight pole or wood utility pole location. Any new pole locations are prohibited unless approved through a City Public Works/Utilities pole placement application.

WCF PERFORMANCE STANDARDS
Pole Replacement For Streetlight Poles: An existing streetlight pole proposed for a WCF installation shall be replaced with a new pole.7

For Wood Utility Poles: An existing wood utility pole proposed for a WCF installation shall be replaced with a new pole.8
Landscaping Replacement Any existing landscaping removed or damaged by installation shall be replaced in kind.

Landscape Screening A WCF shall be placed where existing street tree foliage or new street tree or amenity tree foliage within 35 feet of the WCF provides interruption of direct views of the WCF.
7 Replacement streetlight poles must meet the currently applicable City standards for the pole, including foundation and bolt designs, conduit separation, aluminum material, color, width, height, light mast characteristics (examples:
orientation, design, height, color temperature and photometrics), and the presence/absence of decorative features.

Replacement poles will conform to Public Works Department (PWD) style guidelines and Utilities-Electrical (CPAU) standards where the City has adopted standards and will match the pole being replaced where no standards exist.

Standard specifications for streetlight poles in the City can be obtained from the Utilities-Electrical (CPAU) and Public Works (PWD) Departments.

8 Replacement wood utility poles must meet the currently applicable City standards for the pole, including width, height, color, material, structural capacity, and GO 95 compliance. Replacement poles shall be no greater in diameter or other cross-sectional dimension than is necessary for the proper functioning of the pole with all attachments.

Existing pole functionality shall be maintained, such as in regard to electrical lines, climbing space, light masts (examples: orientation, design, height, color temperature and photometrics), and provision of communication space, unless existing functionality, such as transformers, can be relocated with the approval of the Utilities-Electrical Department (CPAU). Standard specifications for pole replacement in the City can be obtained from CPAU. For wood utility poles carrying power lines, replacement poles shall be the minimum height necessary to provide GO-95 mandated clearance between WCF equipment and power lines.

DocuSign Envelope ID: ECCACC0E-18AC-4D5E-9AEE-0C930810BD0A Attachment C
8 Noise9 Noise from a WCF shall comply with PAMC Chapter 9.10 and shall be consistent with noise-related Comprehensive Plan goals and policies.

City Marketing Banners WCF installations shall not require any changes in the City’s existing banner marketing program.

WCF EXCEPTIONS
A WCF applicant may file an application(s) containing a request for one or more WCF Exceptions to the objective standards set forth in this resolution or any other provision of PAMC Section 18.42.110. The request for a WCF Exception(s) does not exempt a WCF from complying with other objective wireless administrative standards adopted by City Council resolution or any other provision of PAMC Section

18.42.110.

Each WCF Exception request must be made at the time an application is submitted and must include both the specific provision(s) from which the exception is sought and the basis of the request, including all supporting evidence on which the applicant relies. The applicant has the burden of proving that federal law, state law, or both, compel the decision-making authority to grant the requested exception(s). The WCF Exception must satisfy the requirements of PAMC Section 18.42.110(k) and demonstrate why the standard is infeasible.

Failure to identify all required WCF Exceptions upon application submittal may result in application denial.

No WCF Exception may be granted that allows a WCF to be placed:
1) within 300 feet of a parcel containing a public school, 2) within 20 feet of a habitable residential building in a residential zoning district, 3) on wood utility poles within the Residential Zone of Exclusion described in this resolution, or 4) in an alley within a residential zoning district.

9 In residential areas with an average 24-hour noise level (Ldn) at or below 60 decibels (dB), noise generated by WCF equipment shall not cause the Ldn to exceed 60dB or to increase by 5.0 dB or more, even if the resulting Ldn would remain below 60 dB. In residential areas with a Ldn above 60 dB, noise generated by WCF equipment shall not cause the average to increase by 3.0 dB or more.

DocuSign Envelope ID: ECCACC0E-18AC-4D5E-9AEE-0C930810BD0A Attachment C
144.2'
'
100.1'

70.0'
144.2'

60.0'
100.1'

30.0'
100.1'

60.0'
160.0'
139.1'
160.0'
7'
' '

64.9'
100.0'
100.0'

64.9'
100.0'
This map is a product of the
City of Palo Alto GIS
This document is a graphic representation only of best available sources.

Legend
0' 53'
Exhibit 2

WCF RZOE DIAGRAM

CITYOF PALO
ALTO
IN
C
O
R
P
O
R
A
T
E
D
CAL
IFO
RN
IA
P a l o A l t o
T h e C i t y o f
A P
R
I
L
1 6

1 8
94 The City of Palo Alto assumes no responsibility for any errors. ©1989 to 2016 City of Palo Alto rrivera, 2019-11-25 17:25:35
(\\cc-maps\Encompass\Admin\Personal\rrivera.mdb)

ROAD CENTERLINE
RZOE - central 50%
of parcel's lot width
50% of 139.1 lot width
= 69.55 ft
RZOE - central
50%
of parcel's
lot width
RZOE - central
50%
of parcel's
lot width
RZOE - central
50%
of parcel's
lot depth
35 ft
50% of 70 ft lot width
= 35 ft

ROAD CENTERLINE

CURB LIP

PARCEL/PROPERTY LINE
30 ft

30.0'
30 ft 30 ft
RZOE - central
50% of
parcel's lot
width
RZOE - central
50% of
parcel's lot
width
RZOE - central
50% of
parcel's lot
width

ROAD CENTERLINE
RZOE - central
50% of
parcel's lot
width
Residential Zone of Exclusion (RZOE) (this standard applies to WCF Exception requests to locate in residential districts) No WCF shall be placed within the public right of way in the area between the street centerline and the central fifty percent (50%) of the immediately adjacent parcel’s front lot line. The central fifty percent standard shall be based on the parcel’s lot width. For corner lots, the central fifty percent standard along the street lot line shall be based on the parcel’s lot depth.

Front Setback Line
139.1'
100.1'

60.0' 60.0' 60.0'

70.0'

64.9'

64.9'

30.24 ft

32.44 ft

50.05 ft

32.45 ft

30.24 ft

35.07 ft

69.38 ft

30.24 ft

50.39 ft

32.44 ft

32.45 ft

69.55 ft
DocuSign Envelope ID: ECCACC0E-18AC-4D5E-9AEE-0C930810BD0A Attachment C
24 24
24 24
24 24 2424
24 24
24 24
24 24
24 24
24 24
24 24
24 24 24
24 24
24 24
24 24
24 24
15 24 24
10 10
1010
10 24
2010
1515
15 15
15 10
10 10
15 24
15 15
15 15
15 24
24 24
24 20
24 24
50 30
30 50
5024
24 25
25 25
25 25
25 25 25
50 24
24 24
50 24
50 50
50 50
30 50 50
50 25
25 25
25 25
25 25
25 25
25 2424
50 50
50 50
50 50
50 50
50 24
24 24
24 24
24 24
25 25
25 25
25 24
24 24
24 24
30 25
50 24
24 24
24 24
7 7
7 7
6 6
6 7
7 7
7 7
7 7
7 77 77
77 24 25
6 24
24 24
24 24
24 24
24 24
24 24
24 24
24 24
242424
24 24
24 24
24 24
24 24
24 35
35 35
1010
24 10
53 20 4
4 1820
10 35
10 3524
24 24
24 24
24 2424
24 24
24 24
24 24
24 24
24 24
2430
7 7
7 17
24 30 2424
24 30
17 7
7 17
717
30 24 24
2424
24 24
24 24
30 24
2424
2424
24 40
40 24
2424
24 24 24
40 40
40 24
2424
24 2424
40 40
40 4040
40 40 40
40 40
40 40
24 24
24 24 24
24 24
24 24
24 24
24 2424
24 24
24 24
60 60
60 3030 40
30 24
24 24
24 24
24 30
60 60 60 60
50 50
40 40
24 24
24 24
2424
24 24
24 24
24 30
24 24
24 24
24 24
24 24
30 24
24 24
30 24
24 24
24 24
24 24
24 24
24 24
24 24
24 24
24 2424
24 24
24 24
24 24
24 24
30 30
24 24
168
24 16
8 16
24 24
24 24
24 24
24 24
15 30
24 20 25
24 24
24 24
24 24
24 24
24 24
24 24
24 30
24 24
20 20
24 25
25 25
25 25
25 25
20 20
25 25
24 24
24 24
24 24
2424
24 24 24
24 24
24 24
24 24
24 24
24 24
24 24
24 24
24 24
24 24
24 24
24 24
24 2424
24 24
24 24 24
24 24
24 24
24 24 24
24 24
24 24
24 24
24 24
24 24
24 24
24 24
24 24
24 24
24 24
24 24
24 24
24 24
24 24
24 24
24 24
24 24
24 50
50 50 50
24 24
Special ConditionsSpecial Conditions
Special Conditions
ACK_FOR_MIXED
d e
l
a
s
P
u
l
g
a
s
n
d
H i
l
l
R
o
a
d
J
u
n
i
p
e r o
S
e
r
r
a
B
o
u
l
e
v
a
r
d P
a
geMillRoad
A
ra
s
t
rade r
o
R
oadE
l
C
a
m
i
n
o
R
e
a
l
San AntonioAvenue
C
ha
r l
e
s
t
o
n
R
o
ad
O
r
e
g
o
n
E
x
p
r
e
s
sw
a
y
M
i
d d
l
e
f
i
e
l
d

R
o
a
d
University
Av
enue
e
e
w
a
y
1 0
1 A
l
m
a
S t
r
e
e
t
El Camino Real
AlpineRoa
d
F
o
o
t
h
i
l
l

E
x
p
r
e
s s w a y
H
i
g
h
Hillview
East Bayshore
West Bayshore
Fabian
Central Expressway
Sand Hill Road
Embarcadero Road
Fabian Way
Newell Rd
California St
La
tham St
Cl
Pu
Middle Ave
Welch
C
o
yote
H
i
l
l
R
d
Hansen Way
Matadero Ave
Loma Verde Ave
Colorado Av
e
Park Blvd
Birch
N. California Ave
Amaranta
El Ca
mino Way
Lytton Ave Hamilton Ave Homer Ave
Channing Ave
Channing Ave
Guinda
Stanford Av
e
Waverley St. Churchill Ave
t
P
e
e
r
C o u t t s
Serra
S
t
A
rbo
re
tum
Galvez
Park
B
l v
d
Am
ph
ith
ea
t
re
P
kw
y
Charleston Rd
Alma St
Los Altos Ave
Hillview Ave
Old
PageMill
R
d
o
l
d
e
n O
v
a
ntesR d
This map is a product of the
City of Palo Alto GIS
This document is a graphic representation only of best available sources.

Legend
Residential Zone Districts
Non- Residential Zone Districts
Public Facilities/Open Space Zone Districts
Special Setback Frontages
Local
Collector
Residential Arterial
Arterial
Expressway
City Jurisdictional Limits
0' 2670'
Exhibit 3
Road Network and Special Setbacks
with Residential, Commercial, and
Public Facilities Zoning Districts
v.20191125

CITYOF PALO
ALTO
IN
C
O
R
P
O
R
A
T
E
D
CAL
IFO
RN
IA
P a l o A l t o
T h e C i t y o f
A P
R
I
L
1 6

1 8
94 The City of Palo Alto assumes no responsibility for any errors. ©1989 to 2016 City of Palo Alto rrivera, 2019-11-25 13:00:40
(\\cc-maps\Encompass\Admin\Personal\rrivera.mdb)
DocuSign Envelope ID: ECCACC0E-18AC-4D5E-9AEE-0C930810BD0A Attachment C

← All documents from this meeting