Agenda packet, regular meeting, fourth session — San Clemente City Council, January 16, 2024 (part 6 of 7)

broad interpretation in order to maximize protection of the environment. (San Joaquin Raptor/Wildlife Rescue Center v. County of Stanislaus (1994) 27 Cal.App.4th 713, 730.) Even when a developer obtains a right to construct or has completed one or more pieces of a larger project that has so far evaded full environmental review, the City and the courts have the right, indeed the duty, to remedy the wrong. This includes stopping the challenged incomplete parts and ordering a comprehensive environmental review of the entire project using a corrected project description and baseline. (See Arviv Enterprises, Inc. v. South Vallry Area Planning Comm. (2002) 101 Cal.App.4th 1333.) In Arviv, a Los Angeles developer had an overall plan to build 21 homes in the Mulholland community along Woodstock Road. (Id. at p. 1336.) Rather than present the "whole" of its action as part of an EIR or other comprehensive review, the developer chopped the larger project into pieces-one of five homes, another of two homes, and another of 14 homes. (Id. at pp. 1338, 1343.) The developer then separately processed each via CEQA exemptions or J\1NDs.

The City recognized the developer's attempted circumvention of CEQA and required developer to obtain an EIR for a 21-house development rather than proceed in a piecemeal manner. The developer sued the City, arguing against preparation of an EIR. (Id. at p. 1343.) The trial court rejected the developer's position, and the Court of Appeal affirmed, holding that the significance of an accurate project description is manifest, where, as here, cumulative environmental impacts may be disguised or minimized by filing numerous, serial applications. (Id. at p. 1346 (internal quotations omitted).)
"One way to evaluate which acts are part of a project is to examine how closely related the acts are to the overall objective of the project." (Tuolumne County Citizens for Responsible Growth, Inc. v. City of Sonora (2007) 155 Cal.App.4th 1214, 1226.) "Another way to phrase the question of whether a particular act is a step taken towards the achievement of the proponent's objective is to ask whether the act is part of a coordinated endeavor. (POET, LLC v. State Air Resources Bd. (2017) 12 Cal.App.5th 52, 75, fn. 15 (quotations omitted).)
The failure to analyze the whole of the project, and thereby allow the true impacts, including cumulative impacts of the various parts added together, to escape review, is potentially "disastrous," and should not be allowed. (Bozung, supra, 13 Cal.3d at pp. 283-284.) Consistent with Arviv, an EIR is also required on piecemealing grounds to properly analyze regulatory threshold exceedances caused by a project applicant's 524
City of San Clemente - 616 Del Dios Wireless Communications Facility December 5, 2023

Page 41 of 43 ends

coordinated endeavor. For example, under CEQA Guidelines section 15206, subd. (b)(2)(D), a proposed hotel with more than 500 rooms shall be deemed regionally/ area wide significant. This determination may not be possible where a project is piecemealed. Similarly, under Public Resources Code section 2115 5 .1, there are numerous limitations and requirements that the project must meet, including a cap of maximum 200 units, which cannot be properly assessed where a project is piecemealed.

CEQA's piecemealing prohibition-particularly for later phases or last act project components-is also critical as it results in an improperly inflated and inaccurate baseline and fundamentally inaccurate "no project" alternatives designation, which, in turn, taints the entire CEQA review. (POET, ILC v. State Air Resources Bd. (2017) 12 Cal.App.5th 52, 83 [use of an inflated baseline had the effect of understating the increase of impacts, requiring reversal]; see also CEQA Guidelines,§§ 15126.6, subd. (e)(2), 15125, subd. (a)(1) [both the "no project" alternative and the baseline consider the existing environmental conditions].) It is well-settled that, without an adequate baseline, the "analysis of impacts, mitigation measures and project alternatives becomes impossible." ( County of Amador v. El Dorado Counry Water Agenry (1999) 7 6 Cal.App.4th 931, 953.)
Alternatively, even if various parts of the project are sufficiently separate and do not constitute a whole of an action, CEQA requires that the environmental review of the project include impacts of the past, present, and reasonably foreseeable future projects. (See CEQA Guidelines, §§15065, subd. (a)(3); 15130, subd. (b)(1)(A); 15355, subd. (b).) In fact, courts treat piecemealing and failure to study cumulative impacts of related approvals as alternative theories. (San Joaquin Raptor/Wildlije Rescue Center v.

County of Stanislaus (1994) 27 Cal.App.4th 713, 733 ["even assuming the sewer expansion was severable from the development project, the FEIR still did not comply with CEQA" for failure to consider their cumulative impacts].) Thus, in analyzing a Project's cumulative impacts, it's important to analyze not just the impacts of the Project itself but also consider impacts from all other related projects as well.

Evidence of Applicant's "coordinated endeavor" to avoid proper CEQA review is manifest in this case. Currently, the Project involves two building permits-one to decrease the height of the existing tower from 137 feet to 70 feet (permit B23-1495) 525
City of San Clemente - 616 Del Dios Wireless Communications Facility December 5, 2023

Page 42 of 43 ends

and another to collocate wireless infrastructure on the tower. 26 (See Exhibit A [October 17, 2023, Agenda Report], p. 1.) The permit to decrease the height of the existing tower was issued on August 30, 2023, 27 while the permit to collocate new infrastructure is currently under review as permit B23-2265. 28 (Ibid.) Prior to this, on or about September 5, 2023, the Planning Division approved Tower Engineers Professionals ( on behalf of Dish) application for collocation of three new Dish panel antennas to be affixed to the existing tower. (Ibid.) Applicant, in order to reduce the appearance and severity of the Project's impacts and its substantial change of the dimensions of the existing tower, applied, through FCC licensees, for a number of building and collocation permits over the course of several months in violation of CEQA.

As a result of piecemealing or alternatively, the failure to review the cumulative impacts of the Project's related parts or components, there is informational deficiency and overall impossibility to meaningfully assess the Project's impacts or entitlement to ministerial approval, and any CEQA clearance is legally and factually unsupported.

VI. CONCLUSION.

The Project will have significant impacts on the environment and surrounding human beings, including but not limited to aesthetic, fire, hazards, and water impacts. Despite this, the proposed Project has not been subject to any environmental review-not for the 1962 CUP, nor now. In light of the aforementioned concerns, Harbor View HOA respectfully requests that the City: (1) commission the preparation and circulation of a Project-specific Environmental Impact Report; (2) order Applicant to revise the Project to ensure its consistency with all applicable laws and regulations, including but not limited to state and federal requirements concerninAg impacts on the environment and human beings; (3) deem the existing facility ineligible for streamlining under Section 6409 of the Spectrum Act; (4) revoke Conditional Use Permit No. 1021, the Voluntary Compliance Agreement which was entered into under false pretenses, and Wireless Screening Form No. 23-231; and, (4) order Applicant to apply for a new CUP in accordance with current rules and procedures, including 26 The building permit that originally authorized the installation of the wireless equipment (permit B16-2650) was finalized on August 28, 2017.
27 Note that this permit has not been finalized as work to complete the Project remains underway. (October 17, 2023, Agenda Report, p. 2.)
28 Given that the first building permit has already been issued, this comment letter will refer to the portion of the Project which is currently under review as 'Project.' 526
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Page 43 of 43 ends

Chapter 1 7 .16 of the San Clemente Municipal Code.

Sincerely,
Reza Bonachea Mohamadzadeh
Attorney for Harbor View Estates
Homeowners Association
Attached:

October 17, 2023, Agenda Report (Exhibit A);
Conditional Use Permit No. C-1021 (Exhibit B);
Voluntary Compliance Agreement (Exhibit C);
CPRA Production from the City PR-805-2023 (Exhibit D);
Background Information on Microwave Relay Structures (Exhibit E); Destacking Permit (Exhibit F);
Attorney General's Guidance re "Best Practices for Analyzing and Mitigating Wildfire Impacts of Development Projects Under the California Environmental Quality Act" (Exhibit G);
San Clemente Very High Fires Hazard Severity Zones Map (Exhibit H). 527

EXHIBIT A
528
Meeting Date: October 17, 2023

AGENDA REPORT

CITY OF SAN CLEMENTE

CITY COUNCI L MEETING
Department: Community Development
Prepared By: Jonathan Lightfoot, City Planner
Subject:

WIRELESS COMMUNICATIONS FACILITY LOCATED AT 616 DEL D/OS Fiscal Impact:

None to receive and file this report.

Summary:
910 Calle Negoc,o
2nd Floor
San Clemente, Cahfomia
www.san-ciemente.org
Agenda Item: 1 0C
On October 3, 2023, the City Council directed staff to prepare a summary report regarding applications submitted for the modification and construction of wireless communications located at 616 Del Dios, Assessor's Parcel Number 690-552-05. American Tower Management, the applicant and owner, submitted two Building permits to: 1) decrease the height of the tower, and 2) collocate wireless infrastructure on the tower. The Building permit to reduce the height of the tower has been issued, however, the Building permit to collocate new infrastructure is currently under review by City staff. City staff is coordinating a meeting with community members to discuss the proposed project. The meeting is anticipated to occur on October 18, 2023 during a Study Session with the Planning Comm,ission.

Background:

An existing cell facility at the subject site is operated by American Tower Management (Applicant) and was approved under a Conditional Use Permit (CUP) in 1962 by the County of Orange (Attachment 1). Per the CUP, the wireless communications facil ity was approved tor an approximate 28 ft. by 58 ft. building and a 70 ft. antenna tower. Per Applicant representatives, the tower component of the wireless communications facil ity is 137 .6 ft, but is further extended to 156 ft. when the height is measured from the highest existing appurtenance affixed to the tower.

The County, Applicant, and City have not been able to locate any records authorizing the expansion in height beyond the originally permitted height of 70' approved by the County of Orange. As a result, the City denied a collocation request in 2020, which initiated discussions between legal counsel for the Applicant and the City. The Applicant ultimately agreed to voluntarily reduce the height of the existing tower to the 70' maximum permitted by the 1962 County of Orange CUP. A Voluntary Compliance Agreement was executed on July 6, 2023 between the Applicant and the City of San Clemente to reduce the height of the existing antenna tower to the permitted height of 70' (Attachment 2). During the review of records that preceded the compliance agreement, legal counsel for the Applicant noted that the tower is still used today for the wireless transmission of telephone services. Add itionally, the City approved a Building permit (B16-2650), for wireless equipment that was installed and the permit was finaled on August 28, 2017. Existing equipment still present on the tower is proposed to be removed and

CITY OF SAN CLEMENTE
A
529
Meeting Date: October 17, 2023 Agenda Item: 1 0C
replaced by the equipment referenced in permit B23-2265, which is currently under review and described further in the following section.

Discussion:

Due to the public interest regarding proposed work efforts at the site and City Council's request for additional information, City staff has prepared the following summary for the two recent applications submitted for the site.

The requests by the Applicant are to: (1) decrease the height of the tower from 137' to 70' in conformance with the 1962 CUP obtained from the County of Orange, and (2) for the colocation of infrastructure on the existing tower. Proposed collocation infrastructure consists of three (3) panel antennas, three (3) sector mounts, six (6) remote radio units (RRUs), three (3) back-toback mounts, one (1) overvoltage protector (OVP), and one (1) hybrid cable. One (1) new equipment cabinet is also proposed.
• 823-1495: A building permit was issued on 08/30/2023 to reduce the height of the existing tower from 138' to 70' measured from the existing adjacent grade to the highest appurtenance affixed to the tower. This permit has not been finaled as work to complete this project is still underway.
• 823-2265: A "Wireless Communications Facilities" application screening form was submitted by Tower Engineering Professionals (applying on behalf of Dish Wireless) for a Dish collocation of three new Dish Wireless panel antennas that would be affixed to the existing tower. The submitted application is a required screening form submitted prior to a Building permit application to evaluate the proposed collocation, pursuant to Section 6409(a) of the Middle-Class Tax Relief and Job Creation Act of 2012 for facilities outside of the public right-of-way. The applicant submitted a third-party produced Radio Frequency (RF) Compliance Analysis that details the occupational and public exposure levels. The analysis for this site indicated that the RF and power levels will not exceed the FCC established Maximum Permissible Exposure Levels (MPE) for the General Public or Occupational environments. The report recommended the installation of notice/informational signage at the gate entrance to the facility. The screening form was evaluated and approved by the Planning Division on 9/5/2023. The applicant subsequently applied for a Building permit on 9/14/23 for the proposed collocation. This Building permit is currently under review.

The application for modification to the above referenced tower facility, based on initial review, qualifies under Section 6409 of the Spectrum Act (47 U.S.C. § 1455(a), 47 C.F.R. § 1.6100 as an eligible facility for streamlined, ministerial review because it meets the following criteria:

1. It is an existing utility tower.

2. The proposed modification:
• Does not propose a height increase of more than 10% or 20' of the existing height, • Does not propose more than 4 new equipment cabinets,
• Complies with prior conditions of approval, and
• Does not defeat the concealment elements of the existing facility.

CITY OF SAN CLEMENTE 7
530
Meeting Date: October 17, 2023 Agenda Item: 1 QC
The timeframe (also called a "shot clock") for review is 60 days for permits to be issued from the date the application is submitted or the application is "deemed approved" under federal law. Any concerns regarding the completeness of an application must be raised by City staff within 30 days of application submittal.

As part of this process, staff will continue to review plans for the submitted Building permit, B23- 2265, as required under federal law. Staff may require modifications to ensure compliance with the Municipal Code, if enforcing the Municipal Code requirements complies with federal law. City staff is pausing any issuance of building permits regarding the collocation request until staff has convened a meeting with interested members of the community. City Planning staff is coordinating a meeting with community members to discuss the proposed project. The meeting is anticipated to occur on October 18, 2023 during a Study Session with the Planning Commission.

It should be noted that the City lacks discretion with respect to collocation requests if it meets applicable requirements. Federal regulations severely limit a local agencies ability to regulate such facilities. The Telecommunication Act of 1996 expressly prohibits state or local regulations that have the effect of prohibiting the ability of any entity to provide any interstate or intrastate telecommunications service. This has been interpreted very broadly to extremely limit local authority.

Furthermore, under federal law, the City is expressly prohibited from regulating the placement, construction and modification of wireless service facilities on the basis of the environmental effects of radio frequency (RF) emissions, if the facilities comply with the Federal Communication Commission's (FCC's) regulations concerning RF emissions. The FCC guidelines incorporate maximum permitted exposure limits established by the Congressionally-chartered National Council on Radiation Protection. The United States Court of Appeals for the Second Circuit has upheld the FCC guidelines setting health and safety standards on RF emissions and prohibiting local governments from considering health effects of emissions in zoning decisions. Therefore, City decision makers cannot take comments or information concerning potential health effects or other environmental effects into consideration in determining whether to approve permits for cellular facilities.

City decision makers can, however, ensure an individual or collocated wireless communications facility (WCF) will operate within the FCC standards for public exposure. In order to ensure compliance with FCC RF emission standards, the City requires verification from the Applicant that the proposed WCF will either comply with the FCC's guidelines for human exposure to RF emissions or will be categorially excluded from having to determine compliance with the guidelines per 47 CFR §1.1307(b)(1). Information regarding potential health effects is available from the cellular providers upon request and it is also required from the FCC. During the previous City Council meeting, the topic of health effects from the proposed WCF was a large concern of the public; however, as noted above, the City is precluded from considering such effects under federal law, if the RF emissions comply with FCC standards.

Council Options:
• Receive and file the Administrative Report.
• Continue the item and direct staff to provide additional information.

CITY OF SAN CLEMENTE
531
Meeting Date: October 17, 2023 Agenda Item: 1 OC
Environmental Review/Analysis:

Informational reports are not a "project" under the California Environmental Quality Act (CEQA).

Furthermore, the federal process for reviewing eligible facilities requests requires applications be subject to ministerial review only. Therefore, eligible facilities are not subject to the CEQA per§ Section 21080(b)(1) of the California Public Resources Code.

Recommended Actions:

Staff Recommendation
STAFF RECOMMENDS THAT the City Council receive and file this report.

Attachment:

1. County of Orange Conditional Permit (CP-1021), dated December 12, 1962

2. Voluntary Compliance Agreement, dated July 6, 2023
Notification:

Rancho San Clemente Homeowners Association and Interested Parties.

CITY OF SAN CLEMENTE
532
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I • 5
533
ATTACHMENT 2

VOLUNTARY COMPLIANCE AGREEMENT
PARTIES.

This Voluntary Compliance Agreement ("Agreement") is entered into by and between American Tower Management, LLC ("ATCn) and the City of San Clemente ("City"), ATC and the City are sometimes referred to in this Agreement individually as uparty'1 and collectively as the "Parties". This Agreement is entered into as of July 6 , 2023 ('<Effective Date"). ,. -

RECITALS,
This Agreement is made with reference to the following:
l. A TC operates a wireless communication facility (Site No. 89366) ("Wireless Communications Facility"), located at Rancho · San Clemente Trail, Rancho San Clemente, California 92672 (APN: 690-552-tS) C'Property") that was approved under a Conditional Use Permit in 1962 by the Orange County ("County") Planning Division, which then had jurisdiction _.,, over the Property ('~ 1962 CUP").

2. The 1962 CUP permits a wireless communications facility, consisting of "an approximate 28 ft. by 58 ft, building and a 70 ft. antenna tower", in connection with a public telephone service.
3, According to ATC, the tower component of the Wireless Communications Facility is 137.6 ft. iri height, which is further extended to 156 ft. when the height is measured from the highest existing appurtenance affixed to the tower.

4. Neither the City, the Cotmty, nor ATC have been able to locate any records authorizing the expansion in height of the tower from 70 ft. to the current height. •· 6 534

5. Accordingly, because no records of any County or City approvals authorizing the expansion of the tower from 70 ft. to its current height have been located, ATC voluntarily agrees to reduce the height of the existing tower to the 70 fl. maximum identified in the 1962 CVP.

6. To the best of the City's information and knowledge, the only known violation of the 1962 CUP or applicable law with respect to the Wireless Communications Facility is the tower's height.

7. The City and ATC desire to resolve this matter.

AGREEMENT
In consideration of and in return for the promises, covenants, and agreements made herein by the Parties, the sufficiency of which are hereby acknowledged, the Parties agree as follows:

1. The above recitals are incorporated into the terms of this Agreement.

2. The height of the existing tower component of the Wireless Communications Facility will be reduced to a maximum of 70 ft., when the height is measured from the existing adjacent grade to the highest appurtenance affixed to the tower.

3. All work required to reduce the height of the tower to a maximum of 70 ft. shall be performed and completed by ATC, at its sole cost and expense, within 12 months from the date that a building permit is issued by the City in accordance with Section 5, below. ATC shall submit a complete application for a building permit within two (2) months of the Effective Date.

4. ATC agrees that once the height of the tower is reduced, ATC will comply with the 1962 CUP and maintain the Wireless Communications Facility in compliance with all applicable laws, including, but not limited to, the San Clemente Municipal Code and the California Building Code. This includes, but is not limited to, obtaining any necessary permits and other approvals for construction, modifications and/or uses prior to any such changes, to ensure continued compliance -2-
~S33.?i02900i.HMl3538.2
i
I
I ., I
535
with the 1962 CUP and applicable law in effect at that time. ATC shall also maintain the Wireless Communications Facility in compliance with all applicable state and federal laws and regulations, now existing or hereinafter enacted.

5. A TC agrees, prior to commencing any work to reduce the height of the tower stipulated in this Agreement, to obtain a building permit from the City for alterations to the tower, The City agrees to process and issue the building permit with reasonable diligence and without delay.

6. The City agrees that, following the reduction in the height of the tower, the Wireless Communications Facility will be in compliance with the 1962 CUP, and specifically that (i) the 1962 CUP is vested; (ii) the 1962 CUP does not contain an expiration date; and (iii) the 1962 CCP permits the current use of the Wireless Communications Facility for wireless telecommunication purposes; and (iv) the 1962 CUP permits a 70' tower. As a result, the City shall not require a discretionary approval, including but not limited to a new CUP or renewal of the 1962 CUP, in connection with the reduction in height and ongoing operation of the Wireless Communications Facility consistent with the 1962 CUP.

7. In contemplation of, and based on ATC's agreement to reduce the tower height in compliance with this Agreement and to maintain the Wireless Communications Facility in compliance with the law as set forth in Section 4 above, the City hereby will forego any enforcement proceedings for non-compliance related to ATC's tower prior to expiration of the deadline established in Section 3 above.

8. ATC hereby releases the City, its agents, employees, attorneys, elected officials, appointed officials and representatives, from any and all actions, causes of action, losses, claims, demands, damages, costs, loss of use, loss of revenue, expenses, compensation and other form of -3-
4S33ilSO~fJ{M0.113538.2
8 536
damages arising from or relating to any enforcement proceedings for non-compliance as of the expiration of the deadline established in Section 3 above (the <'ATC Released Claims"). However, this release provision does not extinguish, release, or discharge any of the obligations and rights set forth and encompassed in this Agreement. ATC shall indemnify, defend (with counsel acceptable to City) and hold the City its agents, employees, attorneys, elected officials, appointed officials and representatives from any and all actions, causes of action, losses, claims, demands, damages, costs, loss of use, loss of revenue, expenses, compensation and other form of damages by any third party arising from or relating to the A TC Released Claims or this Agreement, the 1962 CUP or ATC construction, operation or maintenance of the Wireless Communications Facility, including, but not limited to, any environmental review or approval in connection therewith.

9. Effective upon ATC's completion of the work on the tower in compliance with applicable laws and as contemplated by this Agreement, the City releases A TC, its agents, employees, attorneys, elected officials, appointed officials and representatives, from any and all known actions, causes of action, losses, claims, demands, damages, costs, loss of use, loss of revenue, expenses, compensation and other form of damages arising from or relating to any non~ compliance of ATC's tower. However, this release provision does not extinguish, release, or discharge any of the obligations and rights set forth and encompassed in this Agreement.

10. ATC also hereby specifically waives the protections of California Civil Code section 1542, which provides:

A general release does not extend to claims that the creditor or releasing party does not know or suspect to exist in his or her favor at the time of executing the release and that, if known by him or her, -4-
!J833:Zi0290Il\H:l,11353 8.2
n
537
would have materially affected bis or her settlement with the debtor or released party.

11. As required by law, the City hereby reserves its right to enforce future violations of law relating to the Wireless Communications Facility or those violations currently unknown, as provided by law, and seek any remedies or rights available to the City. This section is merely intended to clarify that the City is not waiving any future rights or obligations it may have under law pertaining to future occurring or currently unknown, and therefore not contemplated, violations of law that may exist.

12. Advice of Counsel. The Parties represent that they have had the opportunity, whether or not they have chosen to do so, to discuss this Agreement with legal counsel.

13. Entire Agreement. This Agreement is the entire agreement between the Parties with respect to the subject matter hereof and supersedes all prior and contemporaneous oral and written agreements and discussions. This Agreement may be amended only by an agreement in writing signed by all Parties, except that a change in contact information may be made simply by sending notice to the other party.

14. Severability. Each provision of this Agreement is separate, distinct and severable from the others. If any provision is held unenforceable, the rest of the Agreement shall be enforced to the greatest extent possible.

15. Governing Law. This Agreement shall be governed and interpreted in accordance with the laws of the State of California.

16. Choice of Venue. The venue for any disputes arising out of this Agreement shall be in the County of Orange. ATC waives any rights that it may have to removal under Code of Civil Procedure section 395.
-5-
1813250290WIHfil538.2
10 538
I'
j
::

17. Successors and Assigns. This Agreement and all terms, conditions and obligations contained herein arc binding upon and inure to the benefit of any assigns and successors-in-interest of the Parties, and each of them. Each of the Parties represents and warrants that as of the Effective Date none of the claims or causes of action being released herein have been transferred, assigned or otherwise conveyed to any other person or entity, and each of the Parties is the holder of the claims being released.

18. Force Majeure. Neither Party shall be liable for its failure or delay to perform under this Agreement ( a) caused by reason of acts of God, wars, revolution, terrorism, civil commotion, or similar unlawful acts of third parties, fire, flood or other casualty, embargo, acts of government in its sovereign capacity, labor difficulties, including without limitation, strikes, slowdowns, business shutdowns, government regulations preventing performance, epidemics or pandemics preventing performance, labor or supply shortages preventing performance, picketing or boycotts, or· any other similar circumstances beyond the reasonable control and not involving any fault or ..
negligence of such Party, and (b) provided that Party gives prompt notice to the other Party and makes all commercially reasonable efforts to perform.
[ continued on following page J
-6-
4813i?i02'tm.H Ml3 5382
539

19. Signatures. By signing below, the Parties acknowledge tha they haYe read, understoo<l, and agree to all of the te rms of this Agreement.

Dated: June 29, 2023 By:

Dated: June JL, 2023 By:

APPROVED AS TO FORM:

Dated: July~ 2023 By:

Dated: June S., 2023 By:
-7-

CITY OF SA CLEMENTE
AlvfERJCA TOWER MANAGEME T.

LLC
4 ·/L-_ _ Margaret Robinson
Vice President, Legal Operations UST
American Tower lanagemen , LLC
Elizabeth A. Mitchel I
City Attomey for the City of San
Clemente
Emily L. Murr~{ )
Counsel to An1erie.ur-r;;-\.ver Management,
LLC
1?
540

EXHIBITB
541
TAB I• PERMff
MPT
I
-
542
I I
543

EXHIBITC
544
ATTACHMENT 2

VOLUNTARY COMPLIANCE AGREEMENT

PARTIES
This Voluntary Compliance Agreement ("Agreement") is entered into by and between American Tower Management, LLC ("ATC") and the City of San Clemente (''City"), ATC and the City are sometimes referred to in this Agreement individually as ''Parcy/> and collectively as the "Parties11• This Agreement ts entered into as of July~' 2023 ("Effective DateH),

RECITALS,
This Agreement is made with teforence to the following:

1. A TC operates a wireless communication facility (Site No, 89366) ("Wireless Communications Facility"), located at Rancho San Clemente Trail~ Rancho San Clemente, California 92672 (Al>N: 690-552-tS) C'Property'1
) that was approved under a Conditional Use
Permit in 1962 by the Orange County .("Counti') Planning Division, which then hadjurisdictio:1 over the Property (" 1962 CUP").

2. The 1962 CUP pennits a wireless communications facility, consisting of "an approximate 28 ft, by 58 ft. building and a 70 ft, antenna tower", in connection with a public telephone service.
3, According to ATC, the tower component of the Wireless Communications Facility is 13 7. 6 ft. in' height, which is further extended to 15 6 ft. when the height is measured from the highest existing appurtenance affixed to the tower.

4. Neither the City, the ColUlty, nor ATC have been able to locate any records authorizing the expansion in height of the tower from 70 ft, to the cuITent height. •· 545

6. To the best of the City's information and knowledge, fue only known violation of the 1962 CUP or applicable law with respect to the Wireless Communications Facility is the tower's height.

7. The City and ATC desire to resolve this matter.

AGREEMENT
In consideration of and in return for fue promises, covenants, and agreements made herein by the Parties, the sufficiency of which are hereby acknowledged, the Parties agree as follows:

1. The above recitals are incorporated into the terms of this Agreement.

3. All work required to reduce fue height of the tower to a maximum of 7 0 ft. shall be performed and completed by ATC, at its sole cost and expense, within 12 months from the date that a building permit is issued by the City in accordance with Section 5, below. ATC shall submit a complete application for a building permit within two (2) months of fue Effective Date.

4. ATC agrees that once the height of the tower is reduced, ATC will comply with the 1962 CUP and maintain the Wireless Communications Facility in compliance with all applicable laws, including, but not limited to, the San Clemente Municipal Code and the California Building Code. This includes, but is not limited to, obtaining any necessary permits and other approvals for construction, modifications and/or uses prior to any such changes, to ensure continued compliance -2-
4Sll3:z10'29003.4HID538.2
7 546
with the 1962 CUP and applicable law in effect at that time. ATC shall also maintain the Wireless Communications Facility in compliance with all applicable state and federal laws and regulations, now existing or hereinafter enacted.

5. A TC agrees, prior to commencing any work to reduce the height of the tower stipulated _in this Agreement, to obtain a building permit from the City for alterations to the tower.

The City agrees to process and issue the building permit with reasonable diligence and without delay.

8. ATC hereby releases the City, its agents, employees, attorneys, elected officials, appointed officials and representatives, from any and all actions, causes of action, losses, claims, demands, damages, costs, loss of use, loss of revenue, expenses, compensation and other form of -3- 4833i!i09'fllMtM13538.2
0 547
damages arising from or relating to any enforcement proceedings for non-compliance as of the expiration of the deadline established in Section 3 above (the "ATC Released Claims"). However, this release provision does not extinguish, release, or discharge any of the obligations and rights set forth and encompassed in this Agreement. ATC shall indemnify, defend ( with counsel acceptable to City) and hold the City its agents, employees, attorneys, elected officials, appointed officials and representatives from any and all actions, causes of action, losses, claims, demands, damages, costs, loss of use, loss of revenue, expenses, compensation and other form of damages by any third party arising from or relating to the A TC Released Claims or this Agreement, the 1962 CUP or A TC construction, operation or maintenance of the Wireless Communications Facility, including, but not limited to, any environmental review or approval in connection therewith.

9. Effective upon ATC's completion of the work on the tower in compliance with applicable laws and as contemplated by this Agreement, the City releases ATC, its agents, employees, attorneys, elected officials, appointed officials and representatives, from any and all known actions, causes of action, losses, claims, demands, damages, costs, loss of use, loss of revenue, expenses, compensation and other form of damages arising from or relating to any noncompliance of ATC's tower. However, this release provision does not extinguish, release, or discharge any of the obligations and rights set forth and encompassed in this Agreement.

10. ATC also hereby specifically waives the protections of California Civil Code section 1542, which provides:

A general release does not extend to claims that the creditor or releasing party does not know or suspect to exist in his or her favor at the time of executing the release and that, if known by him or her, -4-
~833>!imflil\H Ml353 82
9 548
would have materially affected his or her settlement with the debtor or released party.

12. Advice of Counsel. The Parties represent that they have had the opportunity, whether or not they have chosen to do so, to discuss this Agreement with legal counsel.

15. Governing Law. This Agreement shall be governed and interpreted in accordance with the laws of the State of California.

17. Successors and Assigns. This Agreement and all terms, conditions and obligations contained herein are binding upon and inure to the benefit of any assigns and successors-in-interest of the Parties, and each of them. Each of the Parties represents and warrants that as of the Effective Date none of the claims or causes of action being released herein have been transferred, assigned or otherwise conveyed to any other person or entity, and each of the Parties is the holder of the claims being released.

18. Force Majeure. Neither Party shall be liable for its failure or delay to perform under this Agreement (a) caused by reason of acts of God, wars, revolution, terrorism, civil commotion, or similar unlawful acts of third parties, fire, flood or other casualty, embargo, acts of government in its sovereign capacity, labor difficulties, including without limitation, strikes, slowdowns, business shutdowns, government regulations preventing performance, epidemics or pandemics preventing performance, labor or supply shortages preventing performance, picketing or boycotts, or· any other similar circumstances beyond the reasonable control and not involving any fault or negligence of such Party, and (b) provided that Party gives prompt notice to the other Party and makes all commercially reasonable efforts to perform.
[ continued on following page J
-6-
4833";?;029tIMO113538.2
11 550

19. Signatures. By signing below, the Parties acknowledge that they have read, understoou, nnd agree to all or the terms of this Agreement.

Dated : June 29, 2023 By:

Dated: June J.l_, 2023 By:

APPROVED AS TO FORM:

Dated: July~. 2023 By:

Dated: June ..,,S_ 2023 By:
-7-
/\ndy Hall. City Man ger
AMERICA TOWER MA AGEME T.

LLC 4 ,
Margaret R binson
Vice President, Legal Operations UST
American Tov.,er Management, LLC
' I
Elizabeth A. 1litchell
City Attorney for the City of San
Clemente
Emily L. Murr9"( )
Counsel to Amet=-te-Jrr1-;wer 'lanagement,
LLC
1"
551

EXHIBITD
552

ORAN GE COUNTY FI RE AUTHORITY
Plan Submittal Criteria
COMMERCIAL projects, MULTIFAMILY RESIDENTIAL projects
and RESIDENTIAL TRACT developments

INSTRUCTIONS
• Fill in he project/business address and provide a brie description of the scope of work a d type o business operation that will take place. • Answer questions 1 through 10, read and initial items 11 and 12, the complete and sign the certification section. • If you answer: - "YES" o any part of questions 1 through 0, submit the type o plan indicated i italics to OCFA. • In some cases, o her plan types not indicated herein may also be necessary depending on specific conditions or operations. • Visi www ocfa org for submittal in orma ion and locations. If you need assIs ance in filling out this form or have questio s regarding requirements for review, please contact OCFA at 714-573-6108 or visit us at 1 Fire Authority Road, Irvine, CA 92602.

Address
616 Del Dias
I Suite I c;jty
San Clemente
Project Scope/Business Description
Destack Cell Tower from 138' to 70'
YES NO
I ~ Q Construction of a new building, a new story, or increase the footprint of an existing building? Changes to roadways, curbs, or drive aisles? Addition, relocation, or modification of fire hydrants or fences/gates? Construction within 300 feet of an active or proposed oil well? Fire Jaster Plan (PRI.J5)

2. r:\ 0 Property Is adjacent to a wildland area or non-irrigated native vegetation? ~ Fire /\faster Plan (PR I.J5): a Fuel /llodifica/1 011 Plan may also be required. (PR/ 20, PR/ 2.J) J r:llQ Located in or< 100' from a Division of Oil, Gas, and Geothermal Resources (DOGGR) 1eld boundary, < 300' from ~ an oil/gas seep, or < 1000' from a landfill? A/ethane Work Plan (PH 170) -I l;d Q Installation/modification/repair of underground piping, backflow preventers, or fire department connections serving private fire hydrant/sprinkler/standpipe systems? 11dergro11nd Plan. (PR.J 70. PR-175) 5 n Q Drinking/dining/recreation/meetings/training/religious fu nctions or other gatherings in a room > 750 sq.ft. (> 1,000 14'1 sq.ft. for training/adulteducation) or > 49 people? Healthcare/outpatient services for > 5 people who may be unable to immediately evacuate without assistance? Education for children (academic tutoring for ages 5+ is exempt unless classified as an E occupancy by the Building Officia0? AdulUchild daycare? 24-hour care/supervision? Incarceration or restraint? Hotel/apartment or residential facility with 3+ units and 3+ stories ( 3-story townhouses/rowhouses where an independent direct exit to grade is provided for dwelling are exempt)? Congregate housing/dormitories 10~0
with 17+ people? High-rise structure (55+ feet to highest occupied floor level)? Architectural Plan (PR:!00-PR285) Installation/modification of locks delaying or preventing occupants from~ a space or requiring use of a card , button, or similar action to open a door in the djrectjon of exit travel? A.rchitectuml, Sprinkler, and 'or Alarm Plan depending on the occupancy and type of device installed (PR200-PR280, PR./20-PR-125, PR500-PR520) Installation/modification/use of spray booths; dust collection; dry cleaning; industrial ovens/drying equipment; industrial/commercial refrigeration systems; compressed gasses; tanks for cryogenic or flammable/combustible liquids; vapor recovery; smoke control; battery back-up/charging systems {> 50 gal. electrolyte, > 1,000 lb. lithium ion); welding/brazing/soldering, open flame torches. cutting/grinding; or other similar operations? Special Equipment Plan (PRJ /5, PRJ40-PR382)
Storage/use/research with flammable/combustible liquids or other chemicals? Motor vehicle/aircraft maintenance/repair? Cabinetry/woodworking/finishing facility? Chem Class & floor plan (full architectural plan if H occupancy); ,pecia/ Equipment Plans may be necessa, y. (PR3 I 5-PR360. PR232-PR!.J0) Storage or merchandizing areas in excess of 500 sq. ft. where items are located higher than 12' (6' for high-hazard commodities, plastic, rubber, foam, etc.)? High-piled forage Plan (PRJJOJ Cooking under a Type I commercial hood; installation or modification of a fire extinguishing system located in a commercial cooking hood? Hood & Duct fatinguishing System. not j ust the hood mechanical plan. (PR335) Initial each of the following two items indicating that you have read and understand the statement:
11 • ;~ ~~G Cd ;.u ,: .... *Sprinklers/Alarms: Consult Building/Fire Codes and ordinances to determine sprin ler/alarm requirements; i a syste is required. plans shall be submitted for OCFA review. Existing buildings undergoing remodel must be evaluated by a licensed contractor to deterrr,ine if modification is needed· if so. contractors all submit plans orior to making modi Ica ions. Fire Hazard Seve y Zone: Consult maps available at building department or on OCFA websi e to aetermine if your site is located e ll .::,• in a EH§7 Ruildioos in a EH§Z max be s11hiect to snecial coostn1c1i20 reatJirements detailed in CBC Chaoter ZA or CBC 8327 553
Initials the building department will determine specific requirements.

I certify under penalty of perjury under the laws of the State of California that the above is true:
ame Signature Carr1'anne Cole Carrianne Cole
Carrianne Cole
2023.06.08 09:43:48 -07'00'
Building Department: lfyou have verified that all of the questions have been answered accurately as "NO", and the project does not otherwise require OCFA review of sprinkler or alarm plans*, then you may accept this signed form as a written release that OCFA review is not required Should you still require that the applicant have plans approved by OC FA, please initial here _____ or attach an OCFA referral form and have the applicant submit the form along with the appropriate plans andfeesfor OCFA review. 10-08-14 EE
554
Date:

Application Number:

Address:

Applicant:

Owner:

Contractor:

Project Description:

Construction Valuation:

Description

BLDG PC FEE
Pl N, N'r PC FEES

INVOICE / RECEIPT
City of San Clemente
9 IO Calle egocio, San Clemente, CA 92673
Office: (949) 361-6100
06/08/2023
B23-1495
616 DEL DIOS
Carrianne Cole
TO\VER, AMERICAN
MANAGEMENTINC;
TBD

ES-CELL SITE MODIFICATION
$20,000.00

FEES DUE
Account
EPRS
TOTAL Fees barged:

Payments Received:

Balance Due:

Amount
224 09
$ 0.00
$274 ... 09

0.00 ------
Time Limitation of Plan Chick AppUcatlon An application for a permit for any proposed work shall be deemed to have been abandoned 360 days after the date of filing, 1.mless such application has been pursued in good faith or permit has been Issued; except that the Building Official is authorized to grant one or more extensions of time for additional periods not exceeding 90 days each. The extension shall be requested in writing prior to expiration and justifiable cause demonstrated. lo order to renew action on an application after expiration, the applicant shall resubmit plans and pay a new plan check fee.

WHEN VALIDATED, TIDS IS YOUR RECEIPT

PLEASE TAKE OUR CUSTOMER SURVEY
Scan our QR code or go to www.san-clemente.org/cdsurvey 555
City of San Clemente Building Permit Application BUILDING INFORMATION Permit#: ______ Valuation: .. 20 ... o""' oaa:.:o:.a. o ___ _ Job Address: 616 DEL DIOs SA CLEMENTE, CA 92672
Tract: Lot AP : 690'661-64
JYPf Of BUILDING: Single Family/Duplex Residen ial: __ ADU: _ _ _ Multi Family Residenbal: Number of Units: __ _
M' ed Use Commercial/Residen ·a1: # commercial un~s: _#residential units·_ Name of Owner. American Tower Corp. Phone# ______ _ Com ercial· ~ 0 he . ________ _ Address 10 PRESIDE TAL WAY City Woburn State ~Zip 0180 USE OF BUILOI G: _C_e_ll _T_ow_e_r ___ _ expl. res auran·. factory, dwelling Ema.I _____________ _ CONSTRUCTION TYPE: Modification NUMBER OF STORIES: --- Architect/Designer _ __________ Phone# ______ _
Address _________ Clty. ____ --'State ___ Zip --- -
Em· I. License# _____ _
SPRI KLERS ex sting □ new:O Type ____ expl: NFPA 13. 3R. 13D G: _______ GP: _ ____ CUP: _______ _
Engineer Esha K. Modi Phone# - ------ IRE SEVERITY AREA: YES: o._ Addless 3!,00REGENCY PARKWAY, sum, 100 c,ty Cary Staie ~ Zip 275 8 Em ~=------- -------- ucense # _C_9_2_8_2_7 __ _ AREAS Of EXiSJING Bl llLPINGS: indicate in square feet Contractor:_T_B_D ___________ Phone # ______ _ Residence. ___ Garage: ___ Deck: ___ Porch· __ _ Address _ ________ C1tt _ ____ ,State ___ Zip ___ _ Addition·___ Remodel: __ Repair.__ De ofitlon: __ Ema,I ______________ _ License# _ ____ _ Tenant Improvement· __ _ Contact for Plan Review Comments
Name.· C.Wllf1nc ec .. Ema·I ccole@ runorthe.com Pools area: Spa area: _ _ _ DESCRIPTIO OF WORK: Oest ck a tower from 138' to 70' AREAS Of NEW CON STRUCTION: indicate in square teet Residence.___ Garage:___ Deck:___ Porch. __ _
Addition: _ __ Remodel: __ Repair:__ Demor ion:

Tenant Improvement: __ _
Pools area. Spa area·
SIGNATURE. ________________ DATE. _ ___ _ Reviews: office use only Owner: Agent: [Zl Contractor: 0 ArchitecVOesigner: First submittal: ___ _ Second submittal: ____ Third submittal:

Date Due
910 Calle Negodo. San Clemente CA. 92673. Office (949)361-6100 Notes. 556
From:

Subject:

To:

Sent:

Perez, Rachel </O=EXCHANGELABS/OU=EXCHANGE ADMINISTRATIVE GROUP ( FYDI BOHF23SPDL T)/CN=RECI Pl ENTS/CN=22100061C8F24C479609D150FDB6ACAB-PEREZR> pr-805-2023
Nicholas, Ron <[email protected]>
July 26, 2023 4:30 PM (lJTC-04:00)
This one is a little random, I didn't find anything do you know of any new permit s for this? Any and all records regarding or concerning the application No. WMS23-231 from Dish Wireless, LLC for installation of a new wireless communications facility located at 616 Del Dios (aka APN 690-552-05) Rachel Perez I City of San Clemente
Public Works 1910 Calle Negocio San Clemente CA 92673
office: 949.361 .6113 I eMail: Perezr@sao-clemente org
557
From:

Subject:

To:

Sent:

Hi Kellie,
Planning Mail </O=EXCHANGELABS/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDI BOHF23SPOL T)/CN=RECI PIENTS/CN=E7E565F3DB0543069F7BC5A 1AFBF8280-PLANNI NG SH> RE: 89366 / LSSNA01020A / Cell To-.ver Modification Application Kellie Stremme <[email protected]>
July 10, 2023 7:05 PM (UTC-04:00)
Apologies for the delayed response. Yes, the check has been received and processed today (the City was closed on Friday).

Your project planner will be Jonathan Lightfoot, LiebtfootJ@san-clemente org. Please expect a review within 30 days of payment.

Best,
Karla Morales I Community Development Technician
City of San Clemente I Planning Division
[email protected]
910 Calle Negoc10. Ste 100. CA 9267 3
From: Kellie Strem me <[email protected]>
Sent: Monday, July 10, 2023 10:22 AM
To: Planning Mail <Plann [email protected]>
Subject: Re: 89366 / LSSNA01020A / Cell Tower Modification Application Good morning,
I am checking in to see if you received my previous email. r a lso recei ed notification that the check we mailed to you arri ed on Thur day, July 6th. Did you receive it? Please let me know if you rece ived thi ubmittal and provide a time line of when we can expect corrections or approval as oon as you can. Thank you for your help ! On Fri, Jun 30, 2023 at 12 :44 PM Kellie Stremme <kstremme@tepgroup net> wrote:

Good afternoon,
J am reaching out to ubmit the required documents for yow- review of a Di h Wireless co-location on an existing wireless cell tower located 2M NE of San Clemente in San Clemente, CA 92672 (AP : 690-552-05). I have attached th following docum nts for your review:

Completed pplication
Eligible Facilitie Request ett r
LOA from the ca1Tier and tower owner
Site plans
Photosimulati ons
RF Compliance Analysi
Prior CUP
I have also mailed a check with the application fee to you. Please let me know when you receive it.

If you ha ve any question or need any other information, don't he itate to reach out. Please let me know when you receive this emai l and if possible, provide a timelin of when this project wiU be reviewed/approved. Thank you for your help !
Thank you,
Kellie Stremme
Project SpeciaJist
558
Site .Acquisition Division
Mobile: (480) -
Tower Engineering Professionals, Inc.
4710 E. Elwood St. , Suite 9 I Phoenix, AZ 85040
wW1N teoqrouo net
Thank you,
Kellie Stremme
Project Specialist
Site .Acquisition Division
Mobile: (480)-
Tower Engineering Professionals, Inc.
4710 E. Elwood St. , Suite 9 I Phoenix, AZ 85040
www.teparouo.net
559

VOLUNTARY COMPLIANCE AGREEMENT

PARTIES
This Voluntary Compliance Agreement ("Agreemenfl) is entered into by and between American Tower Management, LLC C'ATC") and the City of San Clemente ("City"), ATC and the City are sometimes referred to in this Agreement individually as 1'Party11 and collectively as the "Parties,). This Agreement !s entered into as of July j__, 2023 ("Effective Date1•).

RECI:.fAL£,
This Agreement is made with reference to the following:
1, A TC operates a wireless communication facility (Site No. 89366) ("Wireless Communications Facility"), located at Rancho San Clemente Trai11 Rancho San Clemente, California 92672 (APN: 690-552-05) C~Propertf1) that was approved under a Conditional Use Permit in} 962 by the Orange County C'Countyn) Planning Division, which then had jurisdictio;i over the Property ("1962 CUP");
2, The 1962 CUP pennits a wireless communications facility, consisting of "an approximate 28 ft. by 58 ft. building and a 70 ft. antenna tower'', in connection with a public telephone service.

3. According to A TC, the tower component of the Wireless Communications Facility is 137.6 ft. in height, which is further extended to 156 ft. when the height is measured from the highest existing appurtenance affixed to the tower.
4, Neither the City, the County, nor ATC have been able to locate any records authorizing the expansion in height of the tower from 70 ft. to the current height. 560

5. Accordingly, because no records of any County or City approvals authorizing the expansion of the tower from 70 ft. to its current height have been located, ATC voluntarily agtees to reduce the height of the existing tower to the 70 ft. maximum identified in the 1962 CC'P.

6. To the best of the City's information and knowledge, the only known violation of the 1962 CUP or applicable law with respect to the Wireless Communications Facility is the tower's height.

7. The City and ATC desire to resolve this matter.

AGREEMENT
In consideration of and in return for the promises, covenants, and agreements made herein by the Parties, the sufficiency of which are hereby acknowledged, the Parties agree as follows:

1. The above recitals are incorporated into the terms of this Agreement

2. The height of the existing tower component of the Wire-less Communications Facility will be reduced to a maximum of 70 ft., when the height is measured from the existing adjacent grade to the highest appurtenance affixed to the tower.

3. All work required to reduce the height of the tower to a maximum of 7 0 ft. shall be petformed and completed by ATC, at its sole cost and expense, within 12 months from the date that a building permit is issued by the City in accordance with Section 5, below. ATC shall submit a complete application for a building permit within two (2) months of the Effective Date.

4. ATC agrees that once the height of the tower is reduced, ATC will comply with the 1962 CUP and maintain the Wireless Communications Facility in compliance with all applicable laws, including, but not limited to, the San Clemente Municipal Code and the California Building Code. This includes, but is not limited to, obtaining any necessary permits and other approvals for construction, modifications and/or uses prior to any such changes, to ensure continued compliance -2-
4SIBi5029005.4O113538.2
561
with the 1962 CUP and applicable law in effect at that time. ATC shall also maintain the Wireless Communications Facility in compliance with all applicable state and federal laws and regulations, now existing or hereinafter enacted.
5, ATC agrees, prior to commencing any work to reduce the height of the tower stipulated in this Agreement, to obtain a building permit from the City for alterations to the tower, The City agrees to process and issue the building permit with reasonable diligence and without delay.

6. The City agrees that, following the reduction in the height of the tower, the Wireless Communications Facility will be in compliance with the 1962 CUP, and specifically that (i) the 1962 CUP is vested; (ii) the 1962 CUP does not contain an expiration date; and (iii) the 1962 CUP permits the current use of the Wireless Communications Facility for wireless telecommunication purposes; and (iv) the 1962 CUP permits a 70' tower. As a result, the City shall not require a discretionary approval, including but not limited to a new CUP or renewal of the 1962 CUP, in connection with the reduction in height and ongoing operation of the Wireless Communications Facility consistent with the 1962 CUP.

7. In contemplation of: and based on ATC's agreement to reduce the tower height in compliance with this Agreement and to maintain the Wireless Communications Facility in compliance with the law as set forth in Section 4 above, the City hereby will forego any enforcement proceedings for non-compliance related to ATC's tower prior to expiration of the deadline established in Section 3 above.

8. ATC hereby releases the City, its agents, employees, attorneys, elected officials, appointed officials and representatives, from any and all actions, causes of action, losses, claims, demands, damages, costs, loss of use, loss of revenue, expenses, compensation and other form of -3-
4833;?i02900lM Mtl 53 8.2
562
damages arising from or relating to any enforcement proceedings for non-compliance as of the expiration of the deadline established in Section 3 above (the "ATC Released Claims"). However, this release provision does not extinguish, release, or discharge any of the obligations and rights set forth and encompassed m this Agreement. ATC shall indemnify, defend (with counsel acceptable to City) and hold the City its agents, employees, attorneys, elected officials, appointed officials and representatives from any and all actions, causes of action, losses, claims, demands, damages, costs, loss of use, loss of revenue, expenses, compensation and other form of damages by any third party arising from or relating to the ATC Released Claims or this Agreement, the 1962 CUP or ATC construction, operation or maintenance of the Wireless Communications Facility, including, but not limited to, any environmental review or approval in connection therewith.

9. Effective upon ATC's completion of the work on the tower in compliance with applicable laws and as contemplated by this Agreement, the City releases ATC, its agents, employees, attorneys, elected officials, appointed officials and representatives, from any and all known actions, causes of action, losses, claims, demands, damages, costs, loss of use, loss of revenue, expenses, compensation and other form of damages arising from or relating to any noncompliance of ATC's tower. However, this release provision does not extinguish, release, or discharge any of the obligations and rights set forth and encompassed in this Agreement.

10. ATC also hereby specifically waives the protections of California Civil Code section 1542, which provides:

A general release does not extend to claims that the creditor or releasing party does not know or suspect to exist in his or her favor at the time of executing the release and that, if known by him or her, -4-
§833li029mUMl3538.2
563
would have materially affected his or her settlement with the debtor or released party.

12. Advice of Counsel. The Parties represent that they have had the opportunity, whether or not they have chosen to do so, to discuss this Agreement with legal counsel.

15. Governing Law. This Agreement shall be governed and interpreted in accordance with the laws of the State of California.

I
;

18. Force Majeure. Neither Party shall be liable for its failure or delay to perform under this Agreement ( a) caused by reason of acts of God, wars, revolution, terrorism, civil commotion, or similar unlawful acts of third parties, fire, flood or other casualty, embargo, acts of government in its sovereign capacity, labor difficulties, including without limitation, strikes, slowdowns, business shutdowns, government regulations preventing performance, epidemics or pandemics preventing performance, labor or supply shortages preventing performance, picketing or boycotts, or any other similar circumstances beyond the reasonable control and not involving any fault or negligence of such Party, and (b) provided that Party gives prompt notice to the other Party and makes all commercially reasonable efforts to perform.
[ continued on following page]
-6-
4S83~029Q{Mhltl538.2
565

19. Signa ures, By signing below, lhe Panies acknowledge Lhat they have read, under·tootl , and agree to all of the terms of this Agreement.

Dated: June 29, 2023 By:

Dated: June JL. 2023 By:

APPROVED AS TO FORM:

Dated: July~- 2023 By:

Dated: June ..:5_, 2023 By:
-1-

CITY OF SAN CLEMENTE
/\ndy Hall. City Man gN
A ,{ERIC AN TOWER 1ANAGEMENT.

LLC 4 _
Margaret R binson
Vice President, Legal Operations UST
American Tower Management, LLC
•• J ' ... . -t. __ ,
Elizabeth A. Mitchell
Ci ty Attorney for the City of San
Clemente
Emily L. Murr f
Counsel to 1~anagement.

LLC
566
Memorandum
Planning Division
6/7/2023
To: City Departments, Regional Agencies, Public Utility Offices, USPS From: Sara Toma, Senior Planner
Subject: Address Confirmation for 616 Del Dies CS
This is to confirm the address for a wireless communication facility at '616 Del Dios CS' on the site below.

Site information
Site Assessor's Parcel Number (APN): 690-552-05
Site Plan
If you have any questions, please contact me at [email protected] Planning Memorandum
567
From:

Subj d :

To;
Cc:

Sent
uaces. Olgalod1a <Olgai [email protected]>
RE: Cell T01Ye1 in San Clemente
Wrighl Chrlstopner <WrightC@saiw:lemente.org>
Glem Francis <gfrancis@fu tonengineenng.com>
Marc 2. 2023 11 ·3S AM(lJTC-05:00)
Greall Thank you.

Have a nice day!
Olgali Luaces
(714) 667-3278
, ·•···· • • • • • ·
Public Works
OC Su rvey
From: Wright, Christopher <Wrich tC@san-clcmcnte org>
Sent: Thursday, March 2, 2023 8:33 AM
To: L aces. Olealldla <0 aa [email protected]> Cc: Glenn Francis <[email protected]>
Subject: RE: Cell Tower In San Clemente
.Attention: This email originated frorn outside the County of Orange. Use c;a ~1t on when opening .at achments or lie1ks.

Use this file. Thanks
From: Wright, Christopher
Sent: Thursday, March 2, 2023 8:32 AM
To: Luace 'Olgalidia <O eahdia Luace,@A(P't'lt' OCiAY corn> Cc: Glenn Francis <afraoqs@fullert:•meceineeooe ·am>
Subj ect: RE: Cell Tower 10 San Clemente
Hello Olgahd1a
The address w,11 be 6ZO Del Dlos CS . The "cs• 1> the Sempra identifier fer ·cell Site.• An addre.- memo is •tta'"ed T~,s ,s being di<tr1buted to our •sency and u, ,tv hst From! Scott. Meredith <S&AI1M l @sao·cleme01e ore>
Sent: Tuesday, February 28, 2023 7:41 AM
To: Luaces. Olgahd <O!safidia luacrs@~cow ou ov ,om>
Cc: G enn Fr dr,c,s <efcanc, ... @Culfcrtnr ene1neer oe com>; Wrrght, Christopher <Wr1ebrC@:wn-clemeole ace> Subject: RE : Cell Tower in San Cleme le
Good morning Olgahd1a,
One of our Planners will be gettin 8 bac k to you with further de:ails ·e, ar Ing his address. ~••ea good day
Meredith
Meredith Scott I City of San Clemente
Admn slrall,e Ass ,;,.an/ I Plarn1ng O!Vl~on ·111'.1, ft, -,)oc.o SanC1en-eritt CA92671 t\4'1. ;6 6183
NJo %»' SAO:Clrmeo, c:ra
from: l uaces, Olgal,dia <Ole a!td.ld I llJCes@occw 0CR0Y (QQJ> Sent: Mond•y, February 27, 2023 1:22 PM
To: Scott, Mered h <$cot1Ml@Jan-cl"'rtJCOte ors>
Cc: Glenn Francis <gfraoctsi'Yb1l lertooenemeer•ne com> Subjoct: FW: Cell Towe, In San Clem re
HeRo,
I am the contact person for the County of Orange addressing. I received an inquiry for an address for• cell tower in Sa n Oemente. Based on the parcel number (690-5S2-0S) provided by the applicant (cc'd on this email), Is IS the 1unsd.ctlon of the city of San Clemente. Below is a screenshot of our landbase that shows it is not unincorporated Applica nt "" attempted to apply 'or an address wi1h the city and is referred back to the County If your records indicate something different than what my landbase shows, please let me know so we could wort together the assi$t the applicant.

Th•nk you
568
Have a nice day'
Olgali Luaces
(714) 667-3278
IT , •• ,. ""., .

Public Works
ocsurvey
from: Luaces, Olgalidia
Sent: Monday, Februarv 27, 2023 10:55 AM
To : f
Subject: Cell Tower in San Clemen te
Hello,
City of San Clemente
L
I called vou lasl week and left you a message. but thought to email vou as well. I apologize. I noticed that you submin ed your inquiry on 2/9, bul I received it t is pastThu·sday Unincorpo
Orange Co
Unfortunately, the County of Orange does not have juriSd1cbon in that area where the cell tower Is (see red square below), It means that we don't have an address point In our syste , nor do we assign an ad dress fer it.

My records clearly show it Is Incorporated to the city of San demente (see map below) 569
Feel free to contact me i you have any fur her Ques ·ons Have a mce day!
Olgali Luaces
(714) 667-32 78
,, ...... ' .... . Public Works
OC Survey
Countv Administration South (CASI
601 N. Ross Street
Santa Ana, CA 92701
Submitted on Thu. 02109/2023 - 09:UO
Name
Glenn Francis
Email
efraor,s@h111° rtnneoetoeenoe ccm
Please direct my me$$age to:

OC Survey (Map Check and Right-of-Way Services, Geospatlal Services, Field Services ... ) Your MtSj age
UnincOIJ)O
Orange Co
I'm a project design eng eer working with DIS Wireless L.L.C and I'm trying lo get the "true• address to a cell tower compound located on a hill. e address I ha,e is: 2M , . of San Clemen te.

Thi is not a real address and SDG&E will not accept our applica on ior new power un ss we have is. This address has eluded me for over a year . No department, co unty, c,ty, esen other power providers that I have cont.>cted knows the addre55 to this cell tower site I have called here be ore last year, to no avail I'm trying agln to see,raybe someone knows ow to locate the address The GPS coord"1ates are: 33.443676, -117.588670 and the parcel number " · 690-552-05 Please can someone holp me locate he address lo this site. Any assistance you can offer would be grea appreciated. I can b reached at: (404 1967-6534 or by em~•I· draom@(u(lerroneo•meenoe CAM Thank you kindly 570
T MJ I • PERMIT !
MPT
571
II
572
From: Ata1111an, Adam </Oa<EXCHANG€L.A8SIOU=EXCHANGE ADMINISTRATIVE GROLf' (FYOIBOtf23SPOL 1)/CN-RECIPIENTSI - BFAAC2DF80AC4BEF8DE9A50A3584E314- ATA ANA>
Sub· ct: J<E· RSC• Cox 5 G An'.enna• American ToNers PN 690-552-05 To: KomeyMolrow -----
Cc: Vome Barnes ~ CodeCompli;;nce <CodeCompience@san-elen-ente o,g>. II, Ar-dy <HaUA@san-cle,.., :e.org> Sharp Sheryl <sst.arp@curtiGITl3nagomonLcorn>; Galardo-Daly Cecila <Galardo- □ lyC@sar>-clementa.org>; Ferguson, Robe<1 <[email protected]>; An<i'ew Morrow/USA Sent. July 14, 2023 8 08 PM (UTC-04'00)
H, Kortnev .

The current tower IS approx, ately 138 fee ta ll, w1U, a total height of 156 feet measured to tile 1op of the hrghest existing appunenance attached to the tower. The apphcant for the current Wor ess Commun'cations Facilities Applica 'on ( o. WMS23 -23 l) ,s Dis Wireless, LLC Please let me know if you have aoy other quesbons. h•n sl Slnc~etr
,ldomAtamian
Deputy Community De11elopmenc Director/
c,cy Planner
p: /949/ J6l,6196
suaro1jlo,1r@$ao-clcmcnte occ
From: Kortney Morrow
Sent: Friday, July 14, 2023 l :32 PM
To: Atamian, Adam <[email protected]>
Cc: Vonne Bar es ........... ;CodeCompliance <[email protected]>; Hall, Andy <r [email protected]>; Sharp Sheryl ~ sharp@curtismanagemenLcom>, Gallardo-Daly, cecn1a <[email protected]>; F rguson, Robert <[email protected]>; Andrew Morrow/USA Subject: Re: RSC• Cox 5 G Antenna• American Towers PN 690-552-0S Ht Adam,
Ca you pleoe clarify whatthe current height of the tower is? Secondly, who submitted the recen: application for the new 'ceflula•' wheless comniunic•tlon, facil,ty? Thank you so uch lor your assistance!
Kortney & Andrew Morrow
On Jul 13* 2023. at 4;53 P , Atamian, Adam <AtoniranA@sao::e;lcmc"tP O'"!P wrote:

Hi \/onne
lhanl you ior your corrcsoondenu Jbout this. !.~LI . , have 1.w-r rtd ..v1tti .:,1y \ ti ff \nth~ S\llld ng nd E.'lg 11eerin101vij:ons to revrew the situation Currant1y , Arneri, dn rower Corporatio<' has a pending appl1caton to <le-stack \he •ower to rPduce thehe,ght lo 70', and mo~t recently mis applied for a permit to replace the emtong wir~s facrlihes. •le,t~er of these permits t'live caen 1Uu@d by the C.ty yet. As far ,u ur dergro .. mdifI9 of pr;va•e cornrnunl(ation Ines. tt-e - liforn,:, E'ectr,cal Code ,ctmpts iuch wor~ froin tequidng perm.ts is;ued by tlle City
I reviewed thelrJct map for thrs area and do not see anv easenents hsted between the tower ,;,roperty and the RSC HOA-owned property between the tower aod the end o' Del o,os, though he•e are ot ers that ~ppear to follcw som<? of e •ccQSs ,o•cl< l<!ading to the tower I have an ched • copy for your reference Plea$e note, not all casements, e,pecoa y private easement. theOty ,snot party to, appear on tnct maps ·n,e,~m•y be other easement:s that e~,st ,11hlch do not app .. ar u, tra maps Regarding what the City can do of work, ct requl•1rg permits, ,s be,ng conduct&! on RSC HOA property w it ou private easement rights or HOA approval, this ,ituatior. is not nf r: eable by Code Comphanc~ I ncommend you contact /Our legal coun• I to determine what remedies you may ~ave. I f theoe,. unauthoro2ed tresparnng on this properly, that ,s an issue enforced by OCSD.

Sincerely,
Adam Ara mion
Depury Commu11lty D•~lopmerrl Oirtctor/
Cily P/onr.tr
p: (949) 361-6196
ar,1miaoa@:sao c1emeoIr oee
F,om: Vonne Barnes
Sent: Thurscay, July 13. 2023 10:36 AM
To: Toma, Sara <lnmaS@sar·clemen1e ace>; Ata Ian. Adam <AtAm1anA@san4 c!emrnte oce>. CodeCompliance ¢odeCamn a1cr@s;m-clemeore me> Cc: Hall, Andy <MaUA@san clcmcolc ors >; Morrow Kort'ley , Sharo S eryl <;sbun@curtism,10aerment ram> Subject : RSC• Cox 5 G Aotenna• Amertcan Towers PN 690-552-05 RSC • Co• S G Antenna• American Towers PN 690-552·05
Sara Toma, Code Compliance, Adam Atamian,
Would you be so kin(! as to review the rollowlng and se d ~• emad reply to this correspondence.

It is our unders tanding that:
• crews associated wi h Cox Cable and American Towers are 1n the process of installing underground fiber optic cables under/ upon property owned by RSCCA/RSCBP Such installation cncrooches upon land outside t e Public ROW along Ocl Doos In Harbor Vi w Estates cas ward up the slope across and under PN 609 552-09 ( RSCCA/ RSCBP) to PN 690 552-05 (Americao Towers)
• American Towers and/or Cox Cable have not applied for a city permit fir Installation of 1bre optic cable and S G Antenna • American Towers and/or Co• Cable do not have a ,ease or easement agreement with RSCCA/RSCBP for access across PN 690-SS2 -09 • American Towe<s does not have a lease or easement agreement with RSCCA/~SCBP property ror access access, 573
If this is correct, will you please issue a notice to American Towers/COX to cease operations until city appllcaitons, including lease and ea sement agreements wit h RSCCA/RSCBP have been submitted for review and approval.

Respeclfully,
Vonne Barnes
RSCCA Board President
574
<AEX32 Print.pd!>
575

CITY OF SAN CLEMENTE
Wireless Communications Facilities Application Screening Form For accommodation under Section 6409(a) of the Middle Class Tax Relief and Job Creation Act of 2012 for facilities outside of the public right of way Project Address: 2M NE of San Clemente San Clemente, CA 92672 Applicant/Carrier: Dish Wireless, L.L.C.

This form serves to assist the City of San Clemente in determining whether a proposed collocation or modification to an existing wireless communications facility qualifies as an eligible facilities request and/or would cause a substantial change as defined by the FCC. Please submit the following:
0 Completed Application Form 0 Application Fee: $47.57
0 Letter of Authorization from Wireless Carrier 0 RF Compliance Analysis (if applicable) 0 Digital Copy of Plans (.pdf)
0 Photosimulations and/or Current Site Photos

1. Is this an existing approved wireless communications facility? 0 Yes □ No If NO, stop filling out this form. The project requires a discretionary permit.

If YES, list previous approvals for cellular installations at the site (include entitlement and building permit numbers). Conditional Permit No. C-1021 . See attached for prior CUP.

2. Describe in detail the existing approved facility. Include facility type, size, height, number of existing antennas, existing equipment, etc.

Exi
(2)
See scope of work on attached site plans for more details.

3. Describe in detail the proposed wireless facility modifications. Include number of antennas, remote radio units, cabinets, and/or equipment proposed for removal, replacement, or addition.

The proposed tower height will decrease from 137' to 75'. There will be (3) panel antennas, (3) sector mounts, (6) RRL.is, (3) Back to Back mounts, (1) OVP. and (1) Hybrid Cable. (1) Equipment cabinet is proposed.

See scope of work on attached site plans for more details.

4. Describe the proposed concealment elements and/or techniques and how, if at all, the project would alter the existing concealment elements.

The proposed tower wiJJ decrease in height by 62.5'. The project will not affect the existing concealment elements.
576

ELIGIBLE FACILITY CRITERIA

5. Does the project increase the facility height by 10% or more than 20 feet?

6. Does the project increase the width by more than 20 feet or protrude beyond the width of the tower at the level of the appurtenance?

7. Does the project involve the installation of four or more equipment cabinets?

8. Does the project defeat the existing concealment elements of the tower?

9. Does the project include any excavation or new ground equipment outside of the current leased/owned wireless facility area?

10. Is the project inconsistent with the original conditions of approval under which the project site was approved and developed?
□ Yes
Yes
Yes
Yes
□ Yes
Yes
If you answered YES to any questions in this section, stop filling out this form. The project requires a discretionary permit.

APPLICANT'S CERTIFICATION
0 No
0 No
0 No
0 No
0 No
0 No
As the ApplicanURepresentative for the Applicant, I acknowledge that the above information and supporting documents are, to the best of my knowledge, an accurate and complete representation of the proposed project. I understand that the City of San Clemente will rely on my responses to evaluate whether to process this application in accordance with the FCC's regulations under 47 C.F.R. § 1.40001 et seq., and I acknowledge that any inaccuracies may result in the application being deemed incomplete or the request for approval pursuant to Section 6409(a) being denied.

Applicant Name: _K_e_l_lie_S_tr_e_m_m_e _____ _ Company: Tower Engineering Professionals E-Mail Address: [email protected] Phone No: 480 ______ _ Signature: -~-~_-_._S_a_~ _____ _ Date: 6-30-23
577
~rotn:

Subject:

To:

Sent:

Cell Tower 1rfo
U5'!ful Links:

P!,W0l9 S-7!t.1
Coury, L!ura <Couyl@san-clomente org~
FW: Cel TO<M!r In San Clemente
Toma, Sara <[email protected]>
February 28. 2023 6:09 PIA (ln"C-05 00)
,\hn rmn COOe <Wt?f
ZPrrcg Look ,o T (setbac s. height limits, etc. for specific address) Please no1e: Coun· ser'lices are currenlly lrriled and av•dable by appoinlmenl orly. Plans can be dropped off and picked up inside the lobby Monday - Thurod:,y 7:30 M l lo 5:30 PM and ar emating Fridays 8:00 AM to 5:00 Pt,t
laura Coury I Assistant Planner
City of San Clemente I Plann ng Division
(0UC\rl@San ·Oemenre OCR
910 Calle Neaoc10 Ste I on CA 92573
from: Scott, eredith <ScottMl@sa -clemPnle.org>
Sent: Mond•y, February 27, 2023 l:24 PM
To: Plan ers <planners@san-c'emente.org>
Subject: FW: Cell Tower in Sa n Oemenl e
H1 all,
I'm not sure who will be th~ point person 'or this
lh• nk vou,
Meredith
From: Luaces, Olgatidi <Olet1lid1a luaccs@«ow OCGPY com> Sent: Monday, February 27, 2023 1:22 P
To: Scott, Meredith 6 rottM1 @sao-demente ore>
Cc: G nn f rane:fs <gftancis@fullert0QenQiOOO!IOR com>
Subject: FW: Cell Tower ,n San Clemen1e
Hello,
I am the contact person for lhe Coun(y of Orange addressing I received an inquiry for an address for a cell tower In San Clemente. Based on the parcel number (690•552--0S} provided by the applicant jcc'd on this email), this is the jurisdiction of the city or San Clemente. Below i a screensho ofour landbaselhatshow it is not unincorporated. Aoplicant as artempted to app for an address with h CIIY and is referred back to the County. I your records indicate something different than what my landbase shows, please let me now so we could worl< together the assist the applicant.

Thank VO".
578
Have a nice day!
Olgali Luaces
(714) 667-3278
Public Works
OCSurvey
From: Luaces, Ofgalld1a
Sent: Monday, February 27, 2023 10:55 AM
To: etcaoc,s@futlertnocne1neenne com
Subject: Cell Tower In San Clemente
Hello,
I City of San Clemente
I caUed you last week and left you a essaee, but thought to email you as well I apologize; I noticed that you submitted your rnquirv on 2/9, but I received it this past Thursday Unincorpo
Orange Co
Unfortunately, til e County o Orange does not have j urisdiction in t hat area where the cell rower rs (see red square below). It means that we don't have an address point in our system, nor do we ass ign an address for It.

My records clearly show~ is incorporated to tile crty of San Clemente(see map below). 579
Feel free to contact me tf you have anv further questions Have a nice day!
Olgali Luaces
(714) 667•327 8
Public Works
OCSurvey
County Adminlsuation South (CAS)
601 N Ross Street
Saota Ana. CA 92701
Submin~d on Thu, 02/09/2023 • 09:00
Name
Glenn Franos
Email
afnnps@f11 ltermnenemeec10e com
Pl ease direct my message to:

QC Survey (Map Check and Right-of-Way Services, Geospatial Services, F,eid Services .) Your M essage
Unincorpo
Orange Co
I'm a proiect des,go engineer wor ,ng with OISH Wireless L.L.C. and I'm trying 10 get the " uue address to a cell tower compound located on a hill the address I have ,s: 2M . of San C mente his Is not a real addr ss and SOG&E will not accep our apphcat,on for new power unless we have this . This aodress has eluded me for over a year. No department. co n y, city, even other power providers lhotl have concactcd knows the address to th,s cell tower Site. I have called here before st year. to no avail I'm lrying agin to see maybe someone knows how to locate th e address. The GPS coordinates are: 33.443676, •117.588670 and th parcel number is: 690-552-05 Please can someone help me loc:ate the address to this site. Any assistance you can offer would be gr atly appreciated. I can be reached at. j404)967·6534 or by mail: •franc-s@l11 ll •noaea 1oe•c □ e rnrn Thank you indly 580
From:

Subject:

To:

Sent:

Will do!
Crockett, Katie </O=EXCHANGELABS/OU=EXCHANGE ADMINISTRATIVE GROUP ( FYDI BOHF23SPDL T)/CN=RECI Pl ENTS/CN=D12BC3D28D6E4DA 79991 F9FF4E7C509F-CROCKETT, K> RE: Wireless site upgrade to PID#690-552-05- LSSNA01020A-89366 Kari Brown <[email protected]>
September 30, 2021 5:26 PM (LJTC-04:00)
Katie Crockett
Associate Planner
[email protected]
(949) 361-6188
From: Kari Brown <[email protected]>
Sent:Thursday, September 30, 20212:12 PM
To: Crockett, Katie <[email protected]>
Subject: RE: Wireless site upgrade to Pl D1#690-552-05- LSSNA0 1020A-89366 Thank you, Katie ! Let me know if I can be of any help.

Have a super rest of the week.

Kari
Kari Brown
Site Acquisition
Tower Engineering Professionals
500 East 84th Road, suite ClO
Thornton, CO 80229
From: Crockett, Katie <[email protected] >
Sent: Thursday, September 30, 20213:09 PM
To: Kari Brown <[email protected]>
Subject: RE: Wireless site upgrade to Pl D1#6 90-552-05- LSSNA01020A-89366 Hi Kari -
I am working on this . We had previously denied modifications under 6409 for modifications as eligible facilities reques ts . ATM has provided us some information from their attorney which we are reviewing with the City Attorney's office. I w ill let you know as soon as I have direction on how to handle this.

Best,
Katie Crockett
Associate Planner
[email protected]
(949) 361-6188
581
From: Kari Brown <[email protected]>
Sent: Thursday, September 30, 20211:22 PM
To: Crockett, Katie <[email protected]>
Subject: RE: Wireless site upgrade to Pl D#690-552-05- LSSNA01020A-89366 HI Katie,
Have you been able to find anything on this site and what my process will be to add antennas and ground equipment to this site?
Looking forward to hearing from you.

Thank you !
Kari
Kari Brown
Site Acquisition
Tower Engineering Professionals
500 East 84th Road, suite Cl0
Thornton, CO 80229
From: Kari Brown <ktbrown@tepgroup net>
Sent: Tuesday, September 28, 20212:20 PM
To: 'Crockett, Katie' <[email protected]>
Subject: RE: Wireless site upgrade to Pl D#690-552-05 LSSNA01020A-89366 Hi Kiltie.

33.443676, - 11 7.58 670
This is a bit bizarre. but I can't seem to find the AP . 1 did find the lat /long (see above) and T took a snip it of the area. 1 also put in the PID # l found:
690-552-05
Please let me 1010 w if th· ge you there.
11umks,
ari
Kari Brown
Site Acquisition
Tower Engineering Professionals
500 East 84th Road, suite Cl0
Thornton, CO 80229
From: Crockett, Katie <CrockettK@san-clemente org>
Sent: Tuesday, September 28, 20211 :59 PM
To: Kari Brown <ktbrown@teogroup .net>
Subject: RE : Wireless site upgrade to Pl 0#690-552-05 LSSNA01020A-89366 582
Hi Kari -
Please provide an address or APN.

Katie Crockett
Associate Planner
CrockettK@s a n-c lemente.org
(949) 36 1-6188
From: Kari Brown <ktbrown@teogrouo net>
Sent: Tuesday, September 28, 202112:23 PM
To: Crockett, Katie <CrockettK@sa n-clemente.org>
Subject: Wireless site upgrade to Pl 0#690-552-05 LSSNA01020A-89366 Hello Katy,
DISH wireless is going to be co locating equipment on this ATC tower. I have been contracted by ATC to zone and permit the site for them. We are adding 3 antennas on the tower with one coax line and a 5 x 7 platform for the cabinets w ith in the lease space of compound. Can you please tell what th e process will entail for zoning? I look forward to hearing from you .

Thank you,
Kari
Kari Brown
Site Acquisition
Tower Engineering Professionals
500 East 84th Roa d, suite ClO
Thornton, CO 80229
583
From: Toma. Sara <TomaS@san-c me te.org>
Subject: RE. Cal TO\•,e, in Sa Clerneote
To: Scott. leredilh <ScottMl@sat>-<:lomente.0<9>; W ght, Christopher <WrightC@san-clemente org> Soni : febr ry 27, 202.3 7:32 PIA (UTC-05:00)
Hi Meredith and C nstopher
P1ease disregard my ema il below Thank you for tak ·ng eariei of this Chrr stopher Thank you.

Sara Toma, AJCP
Senior P!annerl"tln11mc 01 ~sior. ~•l'H':6- !'1.--...Jur.o $:.Ir,,.. rr•'mft! C/. 92bi.J Cltce,o 1MI '-lliO
bln.1/WMftt ,eo-:-:;;leo::e?IB om
From: Tom a, Sara <TomaS@san-clmnent~ org>
Sent: Monday, February 27, 2023 4:02 PM
To: Scott, Meredith <[email protected]>; Planners <planners@s n-c mente.org> Subject: Re: Cell Tower in Sa Clemente
Hi Meredith,
I can assist wi h t his Item. I will con t ac them directly.

Thank you,
Sara
from: Scutt. MereUith <xot1M lr@sao·ilcmcnte urg>
Sent: Monday, f ebruarv 27, 2023 1:23 PM
To: Planners <QlaO,.,PfS@Mn .. cleneotP nor>
Subject: FW. Cell Tower m San Clemente
Hr all.
'm not sure who will be the point person for this.

Thank you.

Meredith
From: Luaces, Olgahd,a <Ol@al1d1a I uaces@ocow nceov com> Sent: Monday, February 27. 2023 1:22 PM
To: Scott, Meredith <S cottMlf@uo·clcroeotc acP
Cc: Glenn FranctS <1 fraac,s@h1llertooenp1oerr1nr com>
SubjMt: FW: Cell Tower In San Oem nte
Hello,
I am the contact person for the County of Orange ad<!re$sing. I received an Inquiry for an •ddress for a t ell towPr in San Clemen e Based on the parcel number (690-552-051 provided by the applrcant (cc'd on this email), this rs the Jurisdiction or the city of San Clemente. Below 1s a screenshot of our landbase that shows it is not un1nto porated. Applicant has attempted 10 app for an •ddress wi the crtv and is re'erred back to the County. If yo ur records rndlc.;te some Ing different than what y land base shows, please let me know so we could work together the assist the applk•nL
Than you.
584
Have a nice day!
Olgali Luaces
(714) 667-3278
, . . .

C Public Works
QC Survey
From: Luaces, Olgalld1a
Sent: Monday, February 27, 2023 10 :55 AM
To : r
Subject: Cell Tower i San Clemente
Hello,
City of San Clemente
I called you last week and left you a message, butt ough to email you as well I apolog1Ze; I noticed that you sub-nined your inquiry on 2/9, but I received it this past Thursday.

Unincorpo
Orange Co
Unfortu atelv, t e County of Orange does not have Jurisdict10n In that area where he cell toweris (see red square below) I means hat we don't have ar address point ,n our syste , nor do we assign an add ess for i
•ly records clear show It Is Incorporated to the city of San Clemente (see map below) 585
Feel tree to contact me tf you have any further questlons.

Have a nice day!
Olgali Luaces
(714) 667-3278
, ... . . C PublicWorks
OCSurvey
County Administration South ICAS)
601 N Ross Strei!!
Santa Ana, CA 9 2701
Submia~d o Tt.L 0:?/091:?013 • 09:00
N•me
Glenn Francis
Email
sfr2nt1s@Ud1
ectooene1oeecme corn
Pleas~ direct my message to:

OC Sur ey (Map Check and Right-of-Way Services, Geospat,al Servttes, field Services .. ) Your Message
Unincorpo
Orange Co
I'm a project design engineer work,ns with DISH Wireless L.L C. and I m trying co get th "true" address to a cell tower compound located on• hill the address I ~av<> is: 2M N of Son Clemente Th,s is not a rea l address and SDG&E will not accept our application for n w oower unless we have this. This address has eluded me for over a year. No department, county, city, even oth r power pr ov ers that I have contacted knows the address to this cell tower site. I have called here bQfore last ye>r, to no avail. I'm trying agin to see maybe someone knows how to locate the address. The GPS coordinates are: 33.443676, -117.588670 and the parcel number,s: 690·552-05. Please can someone help mo locate the address to th is site. Any a<sistance you c.in offer would be greatly appreciated. I can be reached at. 1404)967-6534 or by email: gfrancrs@{µUortgnene aeeCIOR com lhan you kindly 586
From;
Subject:

Ta h, Tamara </O=EXCHAf\.GELABS/OU=EXCl-iANGE ADMINISTRATIVE GROUP (FYO160HF23SPOLl)/CN=RECIPIENTS/C =B49064F481C341AF89-1O8AFFFCE9D0R>- ATICH.

TAM>
RE: Cel Tower n Sen Clemente
To: Sc . Merecl'lh <ScottMl@sa>-c n:e.org>
Sent: Fe~uary 27, 202.3 4.25 PM (UTC-05 00)
Tamara Tatich I City of San Clemente
f'Y'1c 51iec u s'. I t Pkmn I g OM!,, in :;;·uc., r -JfA S;vif'1'H"'l'"' I r.\:i: - :IJ~ .pfl BC8-, t"l tl'I I E,i :!02 t cno·/tw,w Mttcl"ctcntc ::w·
f rom: Scott, Mered, <[email protected]>
Sent: Monday, February 27, 2023 ~ 24 PM
To: Planners <[email protected]>
Subject: FW: Cell Tower b San Clemente
H1all,
I'm not !iure who will b~ the poin p~son for th,s
Thank you,
Merpdith
From; Luaces. Olgahdia <Qle;s ·dta I ua ccs@ocov a~eav cam, Sent: Monday, February 27, 2023 l ·22 PM
To: Scott, Meredith <SconMJ 1@sao-dements au >
Cc: Glenn Francis cetcanc,s tru f ,llertomme oee11 □ e com'.> Subject: FW: Cell Tower in Son Oemente
H lo.

I am che contact person or he Coun;y of Orange addressing. I recer.,ed an inau,ry for an aodress for a cell tower in San Clement . Based on the parcel number (69O-S52·OS1 prov,ded by the applk.>nt (cc'd on his ema1U, thls is e juriSdiction of the city of San Clemen e. Below is a screenshotol ourlandbase that shows it is not unincorporated Apphca nt has attempted to aoply for an address 'lith the city and is referred back to the County If your records indicate something different than what my fandbase shows, please let me ow so we could work togethef lhe assist the applicant.

Thank you.

Have a nice day'
City of San Clemente
Unincorpo
Orange Co
587
Olgafi Luaces
{714) 667-3279
Public Works
OC ·urvey
From: Luaces, Olgalldra
Sent: Mor day, February 27, 2023 10:55 AM
To: gf-.10, "®fyllcrtonl!nq1oeecinl com
Subj ect: cell Tower In San Clemente
Helo1
I called yo~ lasl week and left you a message, but thought to email you as well. I apologize; I noticed that you su bmitted your inquiry on 2/9, butl received il this past Thursday .

Unfottunateiy, the County of Orang does not have jurisd,ctron int at area where he cell tower ,s (sec red square below). It means thal we don't have an address poont on our sy<tem, nor do we assi1n an address for it.

My records cle•rly show ,1 rs Incorporated to the city of San Cl•mente (see map below).

Feel free to contact me rl you have any further questions.

Have a nice day!
Olgali Luaces
{714) 667-3279
Public Works
0 urvey
County Administration South (CAS)
601 . Ross Street
Santa Ana, CA 92701
ubnuned on Thu. 02/09/2023 - 09:00
I City of San Clement~
Unincorpo
Orange Co
588
Name
Glenn Francis
Email
atranck@full•ctooen@1nee-nos com
Plea.e direct my message to:

OC Survey (Map Check and Right-of-Way Services, Geospat,al Services, Field Services .. I Your M essage
I'm a project design engineer work ing with OISH Wireless L.L.C. and I'm lrVtnB to get the ' true• address to a cell tower compound located on a hill t e address I have is; 2M N. of Sao Clemente.

This 1, not a real address and SDG&E will not accept our application for new power unl~s, we have this. Th1S address has eluded me for over a year No department, county, cny, even other power providers that I have cor11acted knows the address to this cell tower site I have called here before last year, to M avail. I'm trying agjn to see maybe someone knows how to locate Lhe address. The GPS coordinates are: 33.443676, -117.588670 and the parcel number IS: 690-5S2-0S. Please ca n someone help me lo<ate the address to th,s site. Any assistance you ca,n offer would be greatly appreciated. I can be reached at. (404)967-6534 or by email, gfranrn@( l'eUP eor ce•II0 11 cam Thank you kindly. 589
From:

Subject:

To:

Ce:

Sant
Wrighl Chrlsiophe< </O=EXCHANGEl.ABSIO.J=EXCHANOE AOMI ISlRATIVE GROUP (FY0I80tf23SPDL DIC RECIPIEl'fTS/C 06EFOCr 14 I064CBCAB64C0258F-IOCF91 WRIGl-llC>
RE: CeN Tower in San Clen-..nle
To-na. Sara <TomaS@san•clemenlo.0<9>
Li(1,tfOOI, Jonalhan <[email protected]>; Scott, Meredith <[email protected]> February 27. 2023 7:04 PM (UTC-05 00)
From: Wright, Christop er
Sant: Monday. February 27, 2023 2:50 PM
To: llghtroo~ Jonathan <Lightfoo\J@sa -c~mente.orp; Scott. Meredith <[email protected]> Subject : RE: C II Tower In San Clemente
Ye 620 Del D1os wor'<s ok
Meredith. please send• temp0<ary reply I'll prepare• me-no tnrsorrow From: Lightfoot, Jon.ath<1n <l ebtfnotl@:s,ao-de:neote m e> Sent : Monday, February 27, 2023 1.51 PM
To: Scou, Meredith 6cottMJ@saa•clcmentr orp; Wnght, Christopher<Wrt:trC@<aa·c1emprte ma> Subject : RE: Cell Tower in San Clemente
Christopher.

If it makes sense to go with 620 Del Oios, would yoJ mind routing c1n address memo JS your schedule lows? If you concur wrth tf-at s the- address. then p ase have Meredith send a pre Im nary response that we will be ass1gnona that.
•JL
From: Scott, W.ered1th <ScnrtM I @sao demente ocp
Sent: Monday, February 27, 2023 l :24 PM
To: P nners <Clanoec$@$dO·dcrocnt1: ore>
Subject: FW: Cell Tower in S.in Clemente
1 'm no sure who will be the point person for this
Thank you,
'llered11~
From: Luaces. Olga1id1a: <Oleahdta I uacest@ocow aceov com> Sent: Monday, February 27, 2023 l :22 P I
To: Stott,. eredith -..5fottMJ@sao-clem0 ote ore>
cc:G nn Francis <dcacns@fullertoneoeineeooe com:>
Subject: FW: Cell Tower in San Clemente
Hello,
I am the contatt person for the Counl'( of Orange addressing. I received an Inquiry ror an add res> for a eel tower in San C mente. Based on the parcel number (690-S52--0S) provided by the applican (cc'd on this email). this is the jurisdittion of the crty of San Clemente. Below is a screenshot of our ndbase thtlt s ows it Is not unincorporated. Applicant has attempted 10 apply for 590
iln address w it the city and ,s referred back to l e County If your records 1nd1cate something different than wha my landbase shows, please !et me now so we could work together the a~~lst the applttanl.

Than you.

Have a mce day!
Olgali Luaces
(714) 667-3278
, ······ ..... (.., PublicWorks
0CSurvey
From: Luace5, 0lgalidla
Sent: Monday, February 27, 2023 10.-55 AM
To: etcaocis@f1 1Uertooe"21oee,ioe rom
Subject: Cell Tower in San Oemente
Hello,
City of San Clemente
I called yoJ las: wee and left you a message, bu thought to email you as well I apologize, I notited mat you submitted your inquiry on 2/9, but I received 11 this past Thutsday.

Un ortunat y, the County or Orange does not have Jurisdiction in that area where the cell towe,· is (see red square below). It means that w e don't have an address point 1n ou· system, nor do we assign ar address for rt.

My records clea rly show it is ,ncorporated to the city of Sao Clemente (see map below). 591
Feel free to cont;,ct me ,r vou have any furt er questions.

Have a nice day!
Olgali Luaces
(714} 667-3278
I .,,... .

C PublicWorks
OCSurvey
County Administrat,on South (CASI
601 . Ross Street
Santa Ana. CA 92701
Submm~d on Thu. 02/09/2023 • 09:00
Name
Glenn Francis
Email
e:fraori,@f1, lecroneoemeerme com
Please direct my message to:

OC Su rvey (Map Check and Right-of-Way Services, Geospatial Servotes, Field Services ... ) -Your M ess,>ge
Unincmpo
Orange Co
Im a projecl design engineer wor ,ng with DI SH Wireless L. L C. and I'm trv ,ng 10 get the "lrue" address to a cell tower compound located on a hrl lhe address I have IS. 2M N of San Clemenle This is not a real address and SOG&E will not accep our apphcat,on for new power unless we have tllls. This address ha, eluded me for over a year. Ntt department, county, city, even other power providers that I have contacted knows he adoress to this cell tower site. I have called here before last year, to no avail I'm trying agin to see maybe someone knows how to locate the address. The GPS coordinaies are: 33.443676, ·117.588670 and the parcel nu ber is 690 552-05 . Please can someone help me locate the •ddress to this <ite. Any assistance you can offer would be grea1ly appreciated. I can be reached at: \404)967-6534 or by email: e{ranc1s@tullertnneng, □ --cio• com hank you lndly. 592
From:

Subject:

To:

Cc:

Sef'tt.

Attached:

Wngni Chnstopher <IO=EXCHANGELABSIOU=EXCHANGE AOMINISTRAilVE GROUP (FYDtBOHF23SPDL T)ICN=RECIPIENTSIC =06EFOEF141064CBCAB64C0258F40CF91- WRIGHTC>
RE· eeu Tower in San Clemente
Luaces Olgaltd1a <[email protected]>
Glenn Fronc1s <[email protected]>
March 2, 2023 :33 AM {VTC-05·001
620 Del Oios c.,a Tower .pdf
IJs, t~ ,s file Thaok1
From: Wright, Christopher
Sent: Thursday, March 2, 2023 8:32 AM
To: Luaces, Olgal1d1a <[email protected]> Cc: Glenn Francis.;[email protected]>
Subject: RE: Cell Tower in San Clemente
HelloOlgalldia,
The addre~s will be 620 Del Dies CS The •c;· 1s the Sempr3 ldenuf1er for ·c~II S1te.' An address 'Tlemo ,s 1trached. This is being d1stnbuted o our agency and u tty 11~1 From: Scott., Meredith<ScortM l@san-clernente ace>
Sent: Tuesday, February 28, 2023 7:41 AM
To: Luaces, Ofgalidia <QJealidt.J I ,mces@occw ornov com> Cc: Glenn Francis <et~aocis@foUeciOnene oeeclo? com:>; Wnght, Chrestopher<Wc ·ebrC@sao:dernenre cr0 > Subject: RE: Cell Tow r in San Clemente
Good morning Olgalld1a,
One of our Planners will be gettms back to you with fu rther details regard,ng this address Have a good day,
Meredith
Meredith Scott I City llf San Cl mente
Admln,strRthe Ass1Sliir t I Pia,·,r,ing D -..,s10-,
lilt ..;~ l"lf>goc . ,ia, . .,.,,,...,,•c .;tl ~ •;T,
"JC! Th• l&'l
t nn JttYNt· >+ Jemrold J r•
From: l uaces, O(gal1dla <Qlealid,a I uaccs@acow ace,v coo:> Sent: Monday, February 27, 2023 I :22 PM
To: Scott, Meredith <ScoUMJ @sao:<lrnem.- nee>
Cc: Glenn Francis qtraocis@fullertonenmoeerme cam>
Subject: FW: Cell Tower In San Clemente
Hello
I am Ille contact oerson lor the County of Orange addressing. I received an inquiry lor an address lor a cell tower ,n San Clemente. Based on the parcel number (690-5S2-051 provoded by the applicant /cc'd on this email), t 1s is the Jurisdiction of the city of San Oemente. Below is a screens hot of our landbase that shows it 1s not unincorporated. Applicant has attempted to apply for an address with the aty and is referred back to the County. If yourrecords mdicate something different than wh>t my tandba,e shows, please let me know so we could wor together the ass ist the applica nt.

Thank you
593
Have a nice day,
Olgali Luaces
(714) 667-3278
, , ..... ... .

Public Works
OCSurv cy
From: Luaces. Olgalidia
Sent: Monday, February 27, 2023 10:55 AM
To~ gfrancrs/@f1 1llectooeoe1oeenoe com
Subject: Cell Tower in San Clemente
Hello,
I called you last week and le~ you • message. but though I to email you as well. I apologize; I noticoo that you submitted your inquiry on 2/9, bL1 I receiv d it this past Thursday.

Uninco1po
Orange Co
Unfortunately, the County of Orange does not haveJurisdoction m that area where e cell tower is (see red square below). It means Iha we don't have an address poi t In our system, nor do we assign an address or it.
y records clear show • is lncorpora ed to the city of San Clemente (see map below). 594
Feel free to contact me 1f you have ary urther questions Have a nice day!
Olgali Luaces
(7 l4) 667•3278
, . . C PublicWorks
OC urvey
County Administratio South (CAS)
601 N. Ross Street
Santa Ana. CA 92701
Subnuuod on Thu. 02/0~/2023 • 09.00
Name
Glenn Franci3
Email
gfrancIS@full"rtonen&ne-:rme; com
Plea.s e direct my [email protected] to:

OC Sun,ey (Map Chee and Right-of-Way Services, Geospa al Services, Field Services ... ) Your Mtssag!:
l City of San Clemente
I'm • proJectdesign eng,neer wor ing with DISH Wirde.ss l.l.C. and I'm trying 10 get e"true• address to a cell tower compound located on a hill. the address I have"· 2M N. of San Clemente This not a real address and SDG&E will not accept our apphcation for new power unless we have this. This address has uded me tor over a year No department, co nty, city, even other power providers that I have contacted knows the address to this c I to\Vet Site. I have <a iled here before last year, 10 no ava,I I'm 1ty1ng >gin o see maybe someone knows how to locate the address. The GPS coordinates are 33.443676, ·117.588670 and the parcel number is: 690·552·0S. Please can someone help ,ne locate the address to this site. Any assostance you can offer would be greatly apprecoated. I can be rea·hed at: (404)967-6534 or by email: gf full cto en•mteCI • rpm. Thank you indly. 595
Memorandum
Planning Division
3/2/2023
To: City Departments, Regional Agencies, Public Utility Offices, USPS From: Christopher Wright, Associate Planner II
Subject: Address Confirmation for 620 Del Oios CS
This is to confirm the address for a wireless communication faci lity at '620 Del Dios CS' on the site below.

Site information
Site Assessor's Parcel Number (APN): 690-552-05
Site Plan
If you have any questions, please contact me at [email protected] Planning Memorandum
596
From: Tauch, Tamara <iO=EXCHANGELABSiOU=0<CHANGE ;.CJ INISTRATIVE GROUP (FYOIBOHF23SPDL l)/CN=RECIPIENTS/CN=B49064F481C341AF894DBAFFFCE900FO-TA11CH.

TAM>
Subject:

To:

Sent:

RE· Cel Tower ,n San Clelrente
Scott, Mered 1h <[email protected]>
February 27, 2023 4·28 PM (lJTC-05 00)
Tamara Tatich I City of San Clem ntlt jf if- Sp !("'d St Pl 11n r190"1 K1fl '.}.(. II;- ~~ t; .., I le 1! 1-.;''}
Mr) U«tM 'ttll 1t:urmlt un
From: Scott, Meredith <ScottM l@san-clemente org>
Sent: Monday, February 27, 2023 1·2d PM
To: Planners <planners@san-cl ente org>
Subject: FW: Cell Tower in San Oemente
H1all,
,•m r ot sure who w,11 be the poonr person for his.

Th•nk you,
Meredith
From: Luaces, O galtdia <Olea! dia I uares@ocaw ocem, com> Sent: Monday, February 27, 2023 1:22 PM
To: Stott, r-v eredrth <SrottMl @:u,n-demente PCl"
Cc: G no Francis <etcaoc1s@ti1Ueoaneoe neeune cam>
Subject: FW· Cell Tower on San Oemente
Hello.

I am the contact person for the County of Orange addressing. I received an inquiry for an address for a cell tower in San Clemente. Based on the parcel number (690-552·05) provided by the applicant (u'd on this email), this Is the Jurlsdlct10n o lhe city of San Clemente Below is a creenshot of our landbase that shows it is not unincorporated. Applicant has attempted 10 apply for an address wI h th e city and is referred bac to the County If your records indicatesomething different than what my landbase shows, please let me know so we could war together the assist the applic.-,nt.

Thank you
Have a nice day•
City of San Clemente J Unincorpo
Orange Co
597
Olgali Luaces
(714) 667-3 278
,, C P~blicWorks
OCSurvey
From: Luaces, Olgal1d1a
Sent: Monday, February 27, 202110:55 AM
To; afraoq5m'lful!rrton111nem°"tme com
Subject: Cell Tower in San Clemente
Hello,
I called you last we k and ft you a message, but thought 10 ema~ you as well I apolog,2e; I noticed that you submitted your inquiry on 2/~. but I rece,ved 1t IS oast Thursday.

Unfortunately, the County of Orange does not have jurisdiction In hat area where the cell tower is (see red square below). It means that we don' t have an addre s point in our system, nor do we assisn an address for it.

My r ords clearly show 1t 1S mcorporoted to the City of San Clemente (see map belowl Feel f ee to cont.ict me f you have any further questions.

Have a nice day!
Olgali Luaces
(714) 667-3278
Public Works
OCSurvey
Cou nty Admin,stration South (CAS)
60) N. Ross Street
Santa Ana, CA 92701
Su mined on Tl1.1, 02/0912013 • 09:00
598
Name
Glenn Francis
Email
[email protected]
Please direct my message to:

OC Survey (Map Check and Right-of-Way Services, Geospatial Services, Field Services ... ) Your Message
I'm a project design engineer working with DISH Wireless L.L.C. and I'm trying to get the "true" address to a cell tower compound located on a hill. the address I have is: 2M N. of San Clemente.

This is not a real address and SDG&E will not accept our application for new power unless we have this. This address has eluded me for over a year. No department, county, city, even other power providers that I have contacted knows the address to this cell tower site. I have called here before last year, to no avail. I'm trying agin to see maybe someone knows how to locate the address. The GPS coordinates are: 33.443676, -117.588670 and the parcel number is: 690-552-05. Please can someone help me locate the address to this site. Any assistance you can offer would be greatly appreciated. I can be reached at: (404)967-6534 or by email: gfrancis@fullertonengineering com. Thank you kindly. 599
From:

Subject:

To:

Sent:

Luaces, OgaiOi,s [email protected]>
RE: Cell TO\\er in San Clemen e
Scot!. Meredlh <Seo [email protected]>
Februa,y 28 2023 I 17 PM (VTC-OS·OO)
Tha ks Meredith.

Have a nice dayl
Olgali Luaces
(714} 667-3278
" ( Public Works
OCSurvey
From: Sc.ott, ered"th <ScortMl@san•c mente.or,s>
Sent: Tuesday, February 28, 2023 7:41 AM
To: Luaces , Olgalidia <[email protected] > Cc: Glenn Francis -:[email protected]=>; Wright, ChnstophPr <[email protected]> Subject : RE: Cell Tower in San Clemente
Attention: ThrS email originated from outside th<! Coom:y of Orange Use caution wh@n opening attachmen o, lin s.

Good morning Olgalid a,
One or out Planners will be gelling back to you w ,th h,rt'"ler deta ils regarding mis acdre5s Ha"e a good day,
Meredith
Moredilh Scott I City of San Clementq
Ad,i11nistrati .e ,lt,.$!,,S n1 I Pfan11,rg :),~s.'°"
1) ~" r,tt,g,11; S.,1r 1
~ ""' I• "':A Q:;',5 •
~'J.Jt\" 1183
blls UVMM m-d,.,M'ltr aco
From: Lu.ac.es., Olgal1d· <Olealid1a I 1,ares@ocow ocaov C01l> Sent: Monday, February 27, 1023 1:22 PM
To: Scott, Meredith QcottM t@sao·tlemeate ace>
Cc: Glen, Francis <efraoric;l'aJfu!lectnoeoeineeci?e com> Subject : FW: Cell Tower m San Clemente
Hello,
I am the con act person lo the County of Orange addressing. I received an inquiry for an addres\ for a cell tower in San Clemente Based on the parcel number (690-552-05) provided by the appheant (cc'd on tl11s email), this is the jurisdic11on of the city of San Cl mente. Below is a screenshot of our landbase that shows it is not unincorporated Applicant has attempted to apply for an address with e city and is re erred bock tot e County. If your records indicate something different :h•n w at my land base shows, please let me know so we could work together the assist theapphcant.

Than you ,
600
Have a nice day!
Olgali Luaces
(714) 667-32 78
, . .

C PublicWorks
OCSurvey
From: Luaces. Olgalidia
Sent: Mond•y, February 27, 2023 1O.SS AM
To: efranc s, fulfecrone111t1new1t 1€ com
Subject: Cell Tower in San Clemente
He o,
San Clemeotej
I called you last wee and I ft you a message, but thought to email you as well. I apologize; I noticed that you subm~t ed your inquiry on 2/9. but I received it this past Thursday Uni ncorpo
Orange Co
Unfortunat y, the County of Orange does not have jurisd1Ct on in tha area where the cell tower is (see red square below). It means at we don't have an adcress point in our system, nor do we assign an address for It.

My records clearly show It Is incorporated to the city of Sa, Clemente (see map b low) 601
Feel free to contJct me if you ave any further ques ·ons.

Have a nice day!
Olgali Luaces
(714} 667-3278
I .... ,. • ••• "
Public Works
OCSurvey
Count)' Admlnistratioo South {CAS)
601 N. Ross Street
Santa Ana, CA 92701
ubn in~d on Tlu~ 02/09/2023 - 09:00
Name
Glenn Francis
Email
efraoe1s@t11 lerroneneroeenn° com
Please direct my message to:

OC Survey (Map Creek and Rrght-of•Wav Services, Geospatlill Services, Field Services ... ) Your M essage
of San Clemente
Unincorpo
Orange Co
l'ma projecldes,gn engineer working with OISH w ,reless L.L.C. a d I 'm trying to get the"true" address roa cem tower compound locilted on a hill the address I have ts . 2M . of San Clemente. lh,s rs not a real address and SOG&E will not accept our application for new power unless we have this. This address has elude me for over a year. No departmen~ counl'(, city, even oh r power providefS that I have contacted know$ the address to this cell tower site I have called here befor£? last year, to no avail. I'm trying agin to Se.? maybe someone knows how to locate the address The GPS coordinates are. 33 443676, •117 S88670 and the parcel number is: 690·5S2·05 Please can someone help me locate the address to th" s~e Any assi,tance you can offer would be gre•tly appreciated. I can be reached a : (404)967-6534 or by email: ofranm@Jullecmoengmecoog mm. Than you kindly. 602
Front
Subject:

To:

Cc:

Sent:

Attached:

Hello Olgalidia
Wnght, Chfls1opher </0:EXCHANGELABS/OJ=EXCHANGE AOMI ISTRATIVE GROUP (FYDIBOH'23SPDL T)ICN=R:CIPIEWSICN=06EFOEF141064CBCA864C02SBF40CF91- WRIGI-ITT>
RE: Cel Tower in San Clemente
Luaces, ()galrdla <Olga [email protected]>
Gl&m Francis <gfrancis@fullertcoongillf!ering.com>
March 2, 2023 11 :32 AM {VTC-05.00)
620 Del Oios Cell TO'MOr .pdf
The address will be 620 Doi Oios cs The · cs•,~ ,t-e Sempra 1dtntlfe1 for •c.,., 51•.e • An ~ddrus, men o Is anached Th is Is being dlmibuted to our •gen<y a,d utilir~ h~t From: Scon, Meredith <[email protected]>
Se nt:Tuesday, February 28, 2023 7:4 1 AM
To : Lua,es, Olgalid,a <Olgalidia.Luac<'[email protected]<gov.com> Cc: Glenn Francis <[email protected]>; Wright, Christopher <[email protected]> Subject: RE: Cell Tower in San Clemente
Good morning Olgalrd1a,
One of our Planners will be getting back to you with fur:h~r d•tails roga, d,ng tnr< addres, Have a good day
Meredith
Meredith Scott I Chy of San Clemente
Adni n1s..,.~,w Ass1~11t I P~ 1tn1ng Oi~s1on
tiiO C-1~ •cy,o 5;.n a ,~,r..,rtia CA Q:._1r:·3
~ W.Jf 1 6111,
tun 'w,,ao, u o:decrrcre cca
From: Luaces, Otgahdia <Ola,1 tdra l uaces@ocaw oreov com> Sent: Monday, February 27, 2023 1:22 PM
To: Scott, Meredith <ScoUMl@s3n-clememe ore>
Cc: Glenn Francis csfraocis@tu!!ecTPnenemeeone com>
Subj~ct: FW. Cell Tower ,n Sa n Clemente
Hello.

I am lhe contact peuon for the County of Orange addressing I received an Inqurry for an address for a cell lower In Sar Clemente. Based on the par<el number (G90-SS2-0S) provided by the applicant tcc'd on this e-naill, this is the jurisdiction or the city of San Clemente 8 low Is a screens hot of our landbase that shows 11 is nol unincorporated. Applicanl has attempted to apply for an address with th• otv and is referred back lo the County II your r ords ind,cate something d',fferen than what mv landbase ,hows. r,lea e let me know so we could work together the assrst the applicant.

Thank you
603
Have a nice day!
Olgall Luaces
(714) 667-3278
ti
C PublicWorks
OCSurvey
From: Luaces, Olgal1dra
Sent: Monday, February 27, 2023 10:55 AM
To~ ., ,-ao,1s u>follpf'l'QOC0£'0 CPC'r.l com
Subject: Cell Tower In San Cle ente
Hello,
City of San Clementrl
I called you la st welk and leh you message, but thoueht to email you as well. I apologize; I noticed tha t vou submitted vour inquiry oo 2/9, but I received il this past hursdav Unincorpo
Orange Co
Unfortunately, the Couniy of Orange d0<!$ not have jurisdicoon In that area where the cell cower is !see red square be'ow) It means that we don't have an address point in our system, nor do we assign an address for it
My records clear show is incorporated to tl1e mv of San Oemente (see map below). 604
Feel free lo contact me f you have any further questions.

Have a mce day!
Olgali Luaces
(714) 667-32 78
, ........... . C PublicWorks
OCSurvey
County Ad ,n,stralion South (CA5)
60: N. Ross Street
Santa Ana. CA 92701
ubmirtcd on Thu. 02/09/2023 -09.00
ame
Glenn Franc,s
Emalt
etcaocis@ti11tectoneog1oetcine com
Please direct mv message to:

OCSurvev (Map Check and R18ht-of-Way Services, Geospa ·a1 Services, Field Services ... ) Your M essage
l City of San Clemente
Unincorpo
Orange Co
I'm a proiect des gn engineer working with DISH Wireless L.LC. and I'm trving to get the "true• address lo a cell tower com pound located on a hill. the address I ave1s. 2M N. of San Clemente This is not a real address and SOG&E will not a cept our appl"cation for now power unless we ve this. This address has eluded e for over a year No depar ment, cou nty, city, even o her power providers that I have contacted knows the address to this cell tower site. I have called here be ore last ye,r, to no avail I'm rylng agln to see maybe someone knows how o locate e address The GPS coord nat s ,re: 33.443676, •117.588670 a d the parcel number is: 690·55Z·05 Please ca n someone help e locate the address to is site. Any assistanc vou can offer would be greatly apprndatcd. I can be reached at: (404 )967-6534 or by email: duoris@fullcrtooGOCIOCCOOf com. hank you kindly. 605
Memorandum
Planning Division
3/2/2023
To: City Departments, Regional Agencies, Public Utility Offices, USPS From: Christopher Wright, Associate Planner II
Subject: Address Confirmation for 629 Del Dios CS
This is to confirm the address for a wireless communication facility at '620 Del Dios CS' on the site below.

Site information
Site Assessor's Parcel Number (APN): 690-552-05
Site Plan
If you have any questions, please contact me at [email protected] Planning Memorandum
606
From:

Subject:

To:

Sent:

Attached:

Hi Katie,
Kari Brown <[email protected]>
RE: Wireless site upgrade to PID#690-552-05 LSSNA01020A-89366 Crockett, Katie <[email protected]>
September 28, 2021 4:20 PM (UTC-04:00)
Screenshot 2021-09-28 141736- see yellow marked area.png

33.443676. -1 17. 8 670
Thi5 is a bit biz.arre, but I can't seem to fmd the AP . I did find the lat /long {see above) and I took a snip it of the area. I also put in the P ID # 1 found:
690- 52-05
Please let me know if this gets you there.

Thanks,
Kuri
Kari Brown
Site Acquis ition
Tower Engineering Professionals
500 East 84th Road, suite C10
Thornton, CO 80229
From: Crockett, Katie <[email protected]>
Sent: Tues day, September 28, 20211 :59 PM
To: Kari Brow n <ktbrown@teogroup net>
Subject: RE: Wireless site upgrade to Pl 0#690-552-05 LSSNA01020A-89366 Hi Kari -
Please provide an address or APN .

Katie rockett
Associate Planner
CrockettK@san-demente. o cg
(949) 361-6188
From: Kari Brown <ktbrown@tepgroup net>
Sent: Tuesday, September 28, 2021 12:23 PM
To: Crockett, Katie <CrockettK@san-clemente org>
Subject: Wireless site upgrade to PID#690-552-05 LSSNA01020A-89366 Hello Katy,
DI SH wireless is going to be co locating equipment on this ATC tower. I have been contracted by ATC to zone and permit the site for them . We are adding 3 antennas on the tower with one coax line and a 5 x 7 platform for the cabinets within the lease space of compound . Can you please tell what the process will entail for zoning? I look forward to hearing from you .

Thank you,
Kari
607
Kari Brown
Site Acquisition
Tower Engineering Professionals
500 East 84th Road, suite Cl0
Thornton, CO 80229
608
609
From:

Subject:

To:

Sent:

Attached:

Good afternoon,
Kellie Stremme <[email protected]>
89366 / LSSNA01020A / Cell Tower Modification Application Planning Mail <[email protected]>
June 30, 2023 3:44 PM (UTC-04:00)
89366_Planning Application.pdf, 89366_Eligible Facilities Request Letter.pelf, 89366_Prior CUP.pdf, 89366_Letter of Authorization.pdf, 89366_Site Plan.pdf, 89366_Photosims.pdf, 89366_RF Analysis.pdf 1 am reaching out to subm.it the required documents fo r your review of a Dish Wireless co-location on an existing wireless cell towe r located 2 E of San Clemente in San Clemente, CA 92672 (AP : 690-552-05). I have attached the following docwnent for your review:

Completed Application
Eligible Facilities Request Letter
LOA from the carrier and tower owner
Site plans
Photo imulations
RF Compliance Analysis
Prior CUP
1 have al o mailed a check with the application fee to you. Plea e let me know when you receive it.

If you have any questions or n ed any other information, don't hesitate to reach out. Plea e let me know when you receive this email and if possible provide a tim line of when thi project will be reviewed/approved. Thank you for yow_· he lp!
Thank you,
Kellie Stremme
Project Specialist
Site Acquisition Division
Mobile: (480) -
Tower Engineering Professionals, Inc.
4 710 E. Elwood St.. Suite 9 I Phoenix, AZ 85040
www 1eoorouo net
610

This form serves to assist the City of San Clemente in determining whether a proposed collocation or modification to an existing wireless communications facility qualifies as an eligible facilities request and/or would cause a substantial change as defined by the FCC. Please submit the following:
ca Completed Application Form 0 Application Fee: $47.57 ca Letter of Authorization from Wireless Carrier
0 Digital Copy of Plans (.pdf)
0 RF Compliance Analysis (if applicable)
0 Photosimulations and/or Current Site Photos

1. Is this an existing approved wireless communications facility? C2I Yes □ No If NO, stop filling out this form. The project requires a discretionary permit.

If YES, list previous approvals for cellular installations at the site (include entitlement and building permit numbers). Conditional Permit No. C-1021 . See attached for prior CUP.

2. Describe in detail the existing approved facility. Include facility type, size, height, number of existing antennas, existing equipment, etc.

Existing wireless fac ility tower is J 37' ta ll with (2} horn mounts O l 8' dipole O} omni antenna. and (2) platforms with handrails.

See scope of work on attached site plans for more details.

3. Describe in detail the proposed wireless facility modifications. Include number of antennas, remote radio units, cabinets, and/or equipment proposed for removal, replacement, or addition.

The proposed tower height will decrease from 137' to 75'. There will be (3) panel antennas, (3) sector mounts, (6) RRUs, (3) Back to Back mounts, (1) OVP, and (1) Hybrid Cable. (1) Equipment cabinet is proposed.

See scope of work on attached site plans for more details.

4. Describe the proposed concealment elements and/or techniques and how, if at all, the project would alter the existing concealment elements.

The proposed tower will decrease in height by 62.5'. he project will not affect the existing concealment elements. 611
EUGIBLE fACjbiTY CRITERIA

5. Does the project increase the facility height by 10% or more than 20 feet?

6. Does the project increase the width by more than 20 feet or protrude beyond the width of the tower at the level of the appurtenance?

7. Does the project involve the installation offour or more equipment cabinets?

8. Does the project defeat the existing concealment elements of the tower?

9. Does the project include any excavation or new ground equipment outside of the current leased/owned wireless facility area?

10. Is the project inconsistent with the original conditions of approval under which the project site was approved and developed?
Yes
Yes
□ Yes
□ Yes
□ Yes
□ Yes
If you answered YES to any questions in this section, stop filling out this form. The project requires a discretionary permit.

APPLICANT'S CERTIFICATION
0No
0No
0No
0No
0 No
0 No
As the Applicant/Representative for the Applicant, I acknowledge that the above information and supporting documents are, to the best of my knowledge, an accurate and complete representation of the proposed project. I understand that the City of San Clemente will rely on my responses to evaluate whether to process this application in accordance with the FCC's regulations under 47 C.F.R. § 1.40001 et seq., and I acknowledge that any inaccuracies may result in the application being deemed incomplete or the request for approval pursuant to Section 6409(a) being denied.

Applicant Name: _K_e_ll_ie_S_t_re_m_m_e _____ _ Company: Tower Engineering Professionals E-Mail Address: [email protected] Phone No: 480 ______ _ Signature:-~-~--· _S_t:-~_____ _ Date: 6-30-23
612
OWER

NEERING
ROF"ESS IONALS
Kellie Strem me
June 30, 2023
To Whom it May Concern:

TEP PHOENIX OFFICE
4710 E. ELWOOD SUITE 9
PHOENIX. AZ 85040
480-
\VW\ .TEPGROUP. ET
RE: Eligible Facilities Request to modify transmission equipment on an existing communications tower located at 2M NE of San Clemente San Clemente, CA 92672.

Site: LSSNA01020A
89366/ San Clemente CA
Attached is an application for modification to the above referenced tower facility. Under Section 6409 of the Spectrum Act (47 lJ SC § 145S(al 47 C ER § 1 6100), this modificat ion qualifies as an eligible facility for streamlined review because it meets the fo llowing criteria (see the attached plans and application for details):
• It is an existing wireless facil ity.
• The proposed modification:
o Does not propose a height increase of more than 10% or 20' of the existing height o Does not propose more than 4 new equipment cabinets
o Complies with prior conditions of approval
o Does not defeat the concealment elements of the existing facility As a reminder, an eligible facilities request, like this one, must be approved because it does not constitute a substantial change to the existing design. The timeframe for review is 60 days for permits to be issued from the date this application is submitted or the site is "deemed approved" by federal law.

Any questions regarding the completeness of this application must be raised within 30 days of application submitt al.

Dish Wireless is committed to working with you to process this request in a timely and efficient manner. Please do not hesitate to contact me if you have any questions using the contact information below.

Sincerely,
'Ketti£ S6l~?v?te
Site Acquisition Agent I Tower Engineering Professionals [email protected]
480-
CIVI L I GEOTECHNI Al. I ·uRVEY 11 PECTIO I STRt:cnJRAL I PM&E I ENVIRONMENTAL. I C.ONSTRUCTION I SITE . 'd ACQUISJTIO Nat1onw1 e Since 1997
613
TAB t - PERMIT
MPT
..
614
II
615
dish wireless.
3/2/2023
RE: TEP as representati e for Dish Wire less
To Whom lt May Concern:

TEP is an authorized representative of Dish Wireless and has been contracted to perform cellular site development (i.e., rea l estate lea ing, land use entitlements. materials procurement, architectural engineering, equipment in ta llation design and con truction. etc.) on behalf of Dish Wireless in connection with their telecommunications facility.

As an authorized r presentative. T P may submit/order (i.e. land use application and permits, utilities, etc.) on behalf of Dish Wire less.

Sincerely,
Lesli . Va1tanian
Market General Manager
616
AMERICAN TOWER• co~rO~A T ION
LETTER OF AUTHORlZA TION FOR PERMITTING
ATC SITE#/NA1"1E/PROJECT: 89366 / SAN LE IENTE CA/ 13688490 SITE ADDRESS: 2M NORTHE T OF SAN LEMENTE SAN CLEME TE CA 92672 APr : 690-552-05
LICENS E: DISH WIRELESS L.L.C. dba DISH WIRELESS L.L.C.

SITE ACQU1STTIO VENDOR (APPLICANT REPRESENTATIVE): TOWER ENGINEERJNG

PROF SSIO AL INC
I. Margaret Robin on, ice President, ST Legal for American ower•. owner/operator of the tower fac ility located at the addre 'S identified above (the "Tower Facility''), do hereby authorize DISH WlRELES L.L.C. dba DJ H WIRELESS L.L.C. TOWER ENGI ERRING PROFESSIONAL INC their successors and assigns, and/or their agent, (collectively the '•Licensee") to act as American Tower·s non-exclusive agent for the sole purpose of filing and consummating any land-use, building, or electrical permit application(s) as may be required by the applicable p rrnitting authorities for DISH WIRELE S L.L.C. telecommunications' in tallaiion on the Tower Facility.

I understand that thesl! applications may approved with conditions. The above authorization is limited Lo the acceptance by Licensee only of conditions related to Licensee' installation and any uch conditions of approval or modifications wil l be Licensee·s sole responsibility.

OTARY BLOCK
Commonwealth of MA SACHU ETTS
County of Middl esex
Signat1.1re :

Print ame: Margaret Robinson
Vice Pre ident, UST Legal
American Tower*
This instrument wa acknowledged before me by Margaret Robinson, Vice President, UST Legal for American Tower*, personally known to me (or proved to me ba ed on ati factory evidence of identification) to be the person whose name is signed on the preceding or attached document and acknowledged to me that they signed it voluntarily for it stated purpose.

WITNESS my hand and official seal. this 81h day of February, 2023 NO l'AR Y \ EAi.
10 Pmidentiaf Way • Woburn, MA 01801 • 781.926.4500 Office • 781.926.4555 Fai • www.americantower.com 617
AMERICAN TOWER• COI\POI\ATIOH
• American Tower is defined as American Tower Corporation and any of its affiliates or subsidiaries. 10 Pres1den11al Way • Woburn, MAO 801 • 781 .926.4500 Office • 781 .926.4555 Fa~ • www.a erican ower.com 618
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DOCUMENTS

REV DATE DESCRIPTION
237240,378860
DISH \l'IR£1.£SS, L LC.

PROJECT IMfORW,TIOH
CA-ATC-T-89366
LSSNA01020A
2M NE OF SAN CLE!.IENTE
SAN CLEMENTE, CA-92672
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GBPIJNDINC NOTES· 1. ALL G/lOUNO El.£CUWOE SYSTEMS (lt<CWDJHG TELECOMMUNICATION. Fi.1,0iO. LIGHTNING Pl'!OTECTION ANO AC POWER GEs's) SHALL eE BONOEO TOGETHER Af OR BO.CW GRADE, BY TWO 00 MOR£ C(J>PER BOHOJNG CONOUCTORS IN ACCORDANCE wm-t rnE tEC.

2. Tl-IE CONiRACf OR SHAl..l.. PERfOOM IEEE FAU.- OF- POlUmAL RCSIS1ANCE f O UJm-1 fESTINC (PER IEEE 1100 AND Bl ) FOR GROUND El...ECTRODE SYSTEMS, THE CONTRACTOR SHAl..l.. RJRNISH ANO INSTALL SUPPLEMENTAL CROUNO ELECTRODES >5 NEIDED fO ACHIEVE A TEST RESULT OF S OHMS OR LESS.

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4. .U ErAl CONDUIT ANO TRAY Sk'.l.l.. BE GROUNDED AHD MAOE a.ECTRICAU.Y CONTINUOUS WITl•-1 LISTED BONDINO FITTINGS OR BY BONDJNC ACROSS TI-lE OGCONTINUlTY Wm< #S COPPER WiRE UL APPROVED GROUNOINO lYPE COHDUIT CVJ.IPS.

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7. CONNECTIONS TO TME GROUND BOS SHAU. NOT BE 00-1.19LEO UP OR STACK(O SAO( TO BACK CONNECTIONS ON <PPOSITE SIDE OF THE GROONO BUS ARE PER.UITTfD.

6. AU. O:TERJOR CROUNO CONOl/CfORS BETVr'EEH EOUJ'MENT/GROUNO 8AAS ANO TI-lE CROUNO Rt,IG SHAU.. BE 12 SOLID TINNED COPPER UNU:SS OTHERWISE INOICATEO.

9. Al..UMINUt.l CONDUCTOR OR COPPER CUD STEil. CONDUCTOR S!-W.l NOf SE USED FOR CROU!«:llNC CONNECTIONS.

10. USE OF 90" BENDS IN THE PROTECTION GROUNOlNG CONOOC~S SI-Urii.L BE AVOIOED JMDI .t5" BENOS CAN BE ~OUATa.Y SUPPORTED.

11. EXOTHERIJC waDS SHALL BE USED FOR ALL CROUNOINC COh'NECTIONS BEi.OW GRADE.

12. ALL CROUNO CONNECTIONS ABO\IE CR,1,0E: (INTEROR ANO O:JERIOR} gw.i. BE FORMED IJSJNG HIGH PRESS CRl.l.t?S.

IJ. COMPRESSION CflOUNO CONNECTIONS MAY BE REPLACED Irr O:OTHERMIC WELD CONNECTIONS.

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18. BONO ALL .UETAUJC 08.JECT"S WITHIN 6 ft Of MAIN GROUND RING WITH (1) 12 BARE SOUO TINNED COPPER GROUHO CONOUCfOR.

19. OROIJNO CONOUCmRS USED FOR THE fACIUTY CROONOING AHO UOHTNINO PROTECTION SYSTOIS StW.L NOT BE ROUTED n!ROUGH f.1ETALUC 00.JECrs TI-IAf fORM A RIHC AROUND THE CONDUCTOR, SUCH AS IJETAUJC CONDUITS, METAL SUPPORT CUPS OR SLEEVES T>iRQUGH WALLS OR FLOORS. WHEN IT IS RtOUlREO fO BE HOUSED IN CONDUIT ro MEET CODE REQUIRt!rdENTS OR LOCAL CONOIT'(lNS, NON-META.LUC MATIJll,t,L SUCH AS PVC CONOUlf SHAU BE USED. WHERE USE Of METAL CONDUIT IS UNAVOOA8U'. (1.,., NONMETAL.UC CONDU1f PROHIBITEl) BY LOCAi. COO£) TI-lE GROUND CONOUCfOR SHALL BE BOtfOEO TO EACH END Of THE ijEJAL CONDUIT.

20. AU.. GROUNDS ™AT TRANSITION FROM Ba.OW CRAil£ TO ABM GRADE MUST l:ll'. J2 ~E SOI.JO TINNED COFPER lN J/4" NON-1,jETAUJC, F\DCflllE COtfOUIT FROM 2.t" BEl..OW GRADE TO WITHIN J" TO 6" OF CN>- WEI..O TERMINATION POINT. THE EXPOSED ENO Of THE CONDUIT MUST BE Sfl,LEO Wf™ SlUCONE CNJU<. (AOD TRANSITIONING GROUND STANDARD DETAIL AS WELL). 2 1. BUILOINGS WHERE TI,( MAIN GROUt..OING C~OUC-TORS ARE REOUlREO TO BE ROUTED fO GRADE, THE CONTRACTOR SHALL ROUTE MO CROUNOING CONDUCTORS FROM n-£ ROOFTOP, !"OWERS, ANO WAJ'CR TOWERS GRCXJNOINC RINC, TI) THE EXISTING CROUNDING SYSTEM, THE GROUNDING COt«>UCf'ORS SKALL NOT SE SNAU.El't fHAN 2/0 COf'f'£R. ROOFTOP CflOUND"NC RING SHALL BE BONDED fO THE EXISTING GROUPONG SYSTEM, fl,£ BUK.OING STEEt. COUJM,"l5. LIGHTNING PRO~CTION SYSTEM. N'IO BUl.DINC t.lAlN WATER LINE. (f"ERROVS OR NONF"ERROUS t.ltTM. P\Pf,IG ONL'f). 00 NOr ATTACH GflOUHOIHG TO flRE. SPRINKL£R SYSTDJ PIPES. dfsh
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PAOJECf KORIU,TION
CA-ATC-T-89366
LSSHA01020A
2M NE Of SAN CLEMENTE
SAN CLEMENTE, CA-92672
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CONSTRUCTION

DOC UMENTS
237240.378860
~~~t'ifH
CA-ATC-T- 69366
LSSNA01020A
2M NE OF SAN CLEMENTt
SAN CLEMENTE, CA- 92672
LEGEN '""''"" D AND ABBREVIATIONS
GN-1
625
$1Tf ACTMlY BfOl!IRO.!FNrs·
1, NOTJCE TO PROCEED - NO WORK SHALL COMI.IENCE PRIOR m CONTRACTOO RECEMNG A WRITT"'JI NOTICC TO PROCEEO O~TP) ANO THE ISSUANCE OF A PURC!,ASE OROER. PRIOR ro A.CCE:SSINC/ENT'ERIHG THE SITE YOU MUST COm'ACT Tl-IE D!SH WlREl.ESS, LLC, ANO TOWER OWNER NOC ,t TI-£ OISH "'IRELESS. L.LC, ANO TOWER OWNER CONSTRUCTION w.NAGER. i.OOK LP" - DISH WIR£1..E5S, L L C. AND TOWER OWNER SAFETY cuue REQUIREUENT:

TI-IE INTEGRllY OF TI-IE SAFITY CLIMB AND ,-.u. COMPONENTS OF THE CLIMBING FACIUT'I' SHALL DE CONSIDERED DURING All STAGES OF OESICN. INSTALLATION, AND INSPECTION. TOWER MOOIFICATION, MOUNT R[INF'ORCEMENTS, ANO/OR EOUIPMEJiT INSTAU.ATIONS SHALL NOT COMPROMISE THE INl"Ec;R11Y OR FlJNCTIONAL USE OF TI-IE ~ CLIMB OR NlY COOPOOENTS OF TH£ CUMB:NC FACILITY ON THE STRUCTURE, THIS SHALL INCLUDE, BUT NOT BE LIMITED TO: PINCHING OF rHE WIRE ROPE, SENDING Of ll!E WIRE ROPE FROM ITS SUP?ORlS, DIRECT CONTACT OR CLOSE PROXIMITY TO THE WIRE ROPE WHICH MAY CAU'S£ FRICTIONAL Wf.AA, IMPACT TO THE ANCH()fl).G£ POINTS IN N« WAY, OR ro IMP£0£/BLOCK ITS INTENDED lJS£. Atf'f COMPROMISf.:O SN'ElY CLIMB, INCLUOINC EXISTING CONDITIONS MUST BE TAGGED our N/0 REPORTED TO YOUR l)jSH WIRELESS, L L.C. AND DISH WlRELESS, LL.C. ANO TOWER OWNER POC OR CAil. TI-lE NOC TO GENERATE A SAf"£1"Y CUMS UAINTEN.-,NCE ANO CONTRACTOR NOTICE TICKET.

J. PRIOR TO THE START Of CONSTRUCTION, AU REQUIRED JURISDICTIONAL PERMITS Sf.W,L 9E OBTAINED. TI-llS INCLUDES, BUT IS NOT LIMITED TO, BUILDING, ELECTRICAL, MECHANICAL, FlR[, F\.000 ZONE, ENVIRONt.4EtiTAl, ANO ZOt-1:NG. AFTER ONSITE ACTMTIES ANO CONSTRUCnON ARE COMPL£TEO, AU. REOUIREO PERMITS SH,\U BE SATISFIED ANO CLOSED OUT ACCOROINC TO LOCAL JURISOICnONAL REOUIR~Elfl'S.

4. ALL CONSTRUCTION MEANS >.ND MCl'l-lJDS; INa..LJOINC BUT ~T LIMITEO TO, EREC □ N PLANS, RIGGING Pl,IJ,JS, CLIMBING Pl.ANS, ANO RESCUE PL.ANS SHALL BE n-lE RE:SPONSIBIUTY OF THE GENER,1,L CONTRACTOR RESPONSIBLE FOR THE EXEClJTION Of lHE WORK CONTAINED HEREIN, ANO SHAU. MEET ANSI/ASS( A10.4B (lATEST EOfflON); FEDERAL, STATE. ANO LOCAL REGULATIONS; ANO #rf APPLICABLE INDUSTRY CONSENSUS STANDARDS RELATED TO Tl-iE CONSTRUCTION ACTMTIES 9EING PERfORMro. ALL RIGGING f>I.ANS ~LL AOI-IERE TO ANSI/ASS[ A10.48 (LATEST EDITION) ANO DISH \l'IREl..ESS, L.LC. AND TOWER OWNER STNIOAAOS, INCWQt,fG THE REOUIRED IHVOLYEMM OF' A OU.WFIEO ENGINEER FOR CUSS t-1 CONSTRUCTIC>t4, TO CERnFY THE SUPPORmG STRUCTURE(S) IN ACCORDANCE WITI-1 ANSI/TIA-J22 (u.TESr EOITION).
s. ALL SITE MlRK TO COMPLY WITH DISH WIRELESS, L.LC. AND TOWER OWNER INSTALL>,TION STANDARDS FOR CONSTRUcnoN ACfMTIES ON DISH WIROESS. LLC. AND TOWER OWNER TOWER SITE ANO LATEST VERSION OF ANSI/TIA-1019- A-201 2 "STA.M:lARO FOR INSTAU.ATION, ALTERATION, ANO MAINTENANCE OF ANTENNA SUPPORTING STRUCTURES AND ANTO-.NAS."

6. IF THE SPECIF1ED EQUIPMENT CAN NOT BE INSTAL.1£D AS SHOWN ON TI-1ESE DRAWINGS. lllE OONTRACTOft SH,t,IJ. PROPOSE AN ALTERNATIVE INSTAllAT10N !"OR APPROVAL DY OlSH WIREU.'.SS, LLC. ANO TOWER OWNER PRIOR TO PROCEEDING W'ITl-1 ANY SUCH CHANGE or INSTAU.ATION.

7. All MATERIALS FURNISHED ANO INSTM.I.EO 51-W.1. BE IN STRICT ACCORDANCE WITH AU APPLICABLE COOES, eiEGUlATIONS ANO OROINANCES. CONTRACTOR SHo\U. ISSUE ALL APPROPRIATE NOTICES ANO CO~Pl.Y WITI-1 ALL LAWS, OR INmCES, RULES, REGUlAflONS ANO LAWFUL ORDERS OF >Hf PUBLIC AUTHORITY REGARDING THE PERFORMANCE OF THE WORK. All WORK CARRIED OUT SHALL COMPLY WITH ALL APPUCABLE MUNICIPAL ANO UTILllY COMPANY SPECIFICATIONS ANO LOCAL JURISOICTIONAL COOES, ORDINANCES AND APPlJCABLE REGULATIONS.

6. TI-£ CONTRACTOR SHAU. INSTfil AU. EQUlPMENl ANO MATERW..S IN ACCOROANCE WITH MANUFACTURER'S RECOMMENDATIONS UNLESSSP£ClF10,i.LYSTAID)0iHERWlSE,

9. THt CONTRACTOR Sl-!ALL CONTACT LmUTY LOCATING SERVICES ll'+CW~G PRIVAlE LOCATES SERVICES PRKlR TO TH£ START Of' CONSrRIJCTION.

ID. ALL COSTING ACTIVE StwER, WNER, CAS, ELECTRIC AND OTHER AVTILITIES WHERE ENCOUNTERED IN TI-1E WORK, SHALL B£ PIWTECTEC AT ALL TIMES ANO WHERE REQUIRED FOR THE PROPER EXECUTION OF TM£ WORK, SI-Wl.. BE REl.OCATED AS DIRECTED BY CONTRACTOR. EXTREME CAUTION SHOULD BE USED BY TI-iE CONTAACTOR WHEN EXCAVATIHG OR ORIWNC PIERS AROUND OR NEAR L/TllJTIES. CONTRACTOR SHALL PROVIDE SAFETY TRAINING FOR THE WORKING CREW. TI-IIS WIU. INCLUDE BVT NOT BE UMITEO TO _.,, FAll PROT(CTION B) CONflllEO SPACE C) fJ.ECTRICAL SAFEJY 0) TRENCHING AND EXC>.VAOON E) CONSTRUCTION SAFE1Y PROCEDURES.
11 . J,U SITE WORK SHAU. BE AS INDICATED ON THE STAMPED CONSTRUCTION DRAWINGS AND DISH PROJECT SPEClflCATIONS, LATEST APPROVED REVISION.

12. CONTR.t.CTOR SHALL KEEP THE SITE FREE FROM ACCUMULATING WASTE MATERIAi., OEaRIS, ANO TRASH .-,y mE COl.!PLfJlON OF THE WORk. IF NECESSARI', RUBBISH, STUM?S, DEBRIS, STICKS, STONES AND OTI-lER REl'US£ SHALL BE REMOVro FROM THE SITE .'.HD OISPOSEll Of LECALLY.

LS. ALL EXISTING INACTIVE SEWER. WATER, GAS, ELECTRIC AND OTHER UTIIJTIES, WHICH INTERf"ERE Will-I THE EXECUTION OF ll!E WORK, SH.\U BE REMCMD Afro/OR CAPPED, PLUGGED OR OTI-lERWISE DISCONTINUED AT POMS WHICH WILL NOT INTERFERE WITH THE E)(ECUTION OF' TiiE WORI<, SU9JECT TO Tl-IE APPROVAf. OF DISH WIRELESS, LL.C. ANO TOWER OWNER, ANO/OR LOCAf. UTILITIES. 14, n£ CO NTAACT fl SHALL PROVIDE SITE SIGNACE IN ACCORDA~E Wln-i n-iE T£CHl'iIC>.l SPEClflc.\TION FOO SIT£ SIGNAGE REQUIRED BY LOCAL JURISDICTION -'HD Sll'.lHAGE REQUIRED ON \NOMOIJJ,L PIECES Of' EQUIPMENT, ROOMS, ANO SHrLTERS.

15. n£ SITE SJ-W..L BE CRADEO TO CAUSE SUltFACE WATER TO FLOW AWAY FROM n!E CAARO'S UI m ANO TOWER AREAS.

15. THE sue CAA0£ sw.t.L OE' l,CTED ANO BROUGHT TO _., SMOOTli UNIFORM CRACE PRIOR TO FINISI-ED SURFACE APPUCATIOH.

17. TH£ AA.EA$ OF THE OWNERS PROP£RTY DISTURBED 8Y THE WORK ANO NOT covrnEO BY THE TOWEFI, EQUIPMENT OR DRIVEWAY, SHALL BE CRADED TO A UNIFORM SLOPE, ANO STABILIZED TO PREVENT EROSION AS SPEC/f1EO ON TI-1E CONSTRUCTIOff OAAWlMGS ANO/OR PROJECT SPECIFICATIONS.
1 B. CONTRACTOR Sf.W.1. MINIMIZE OISTUR8"NCE TO EXISTING SITE DURING CONSTRUCTION. EROSION CONTROL MEASURES, IF RtOUIREO DURING GONSTRUCOON, SHAU. BE IN CONFORMANCE WITH THE l.OCAL OUIDEUNES FOR EROSION ANO SE01MENT' CONTROL

19. THE COHTRACTOR Sf.W.1. PROrECT EXISTING IMPROVEMENTS, PA'.'EYOOS, CURBS, 1.AN05CAPING ANO STRUCltJRES, ANY OAMACED PART SHAU. BE REPAIRED _.,T CONTRACTOR'S £)(PENSE TO n,e: SATISFACTION OF OWNER.

20. CONTRACTOR S1-W..L LEG.A.I.I.I' ANO PROPERLY DISPOSE Of All SCRAP MATERIALS SUCH AS COAXW.. CABLES ANO OTHER ITEMS REMOVE□ FROM THE EXISTliG FACILITY. ANT'ENNAS ANO RAOIOS REMOIIED SHALL BE RETURNED TO THE OWNER'S DESIGN.I.ID>

LOCATION,

21. COt4TRACTOR SHALL LD.VE PREMISES IN CLEAN cooomoN. TRASl-1 ANO OEBRIS SHOULD BE R[f.lOl,/EO FROM SITE ON A OAILY ""'·

22. NO fill OR EMBANKMENT MATERIAL SHAU BE Pl.ACED ON FROZEN GROUND, FROZEN tMTERIALS, SNOW OR ICE SHALL NOT BE PV,CEO IN AfN Fill. OR EIEANKMENT.
1,
~
FOR THE PURJ'OS( OF CONSTRUCTION ORAWING, THE FOLLOWING OEF1NITIONS SHAU. APPLY:

CONTRACTOR:GENEFW. CONTRACTOR RESPON5IBt£ FOR CONSTRUCTION CARRIER ISH WIRELESS, LLC.

TOW(N OwtlER:TOWER OWNER

2. THESE ORAWINCS HJ,V[ O([N PREPARED USING STAN!WlDS or PROFESSIONAL CARE ANO COMPLETENESS NQRt,IALLY EXCRCISED UNOtR SIMII.AR CIRCUMSTANCES BY REPL!TABL.E ENGINEERS IN THIS OR Slf.llLAR l.OCAUTIES. IT IS ASSUMED 11-IAT TI-lE WORK D[PjCTEO WILL 9£ PERFORMED BY AN EXP£RIENCEO CONTRACTOR ANO/OR WORKPEOPLE WHO HA'.'£ A WORKING KNOWLE00£ OF THE APPUCABLE CODE STANDARDS ANO REQUIREMENTS AND OF INDUSTRY ACCEPTED STAlfOAAO 0000 PRACTICE. AS NOT EVERY CONDITION OR ELEMENT IS (OR CAN BE) EXPUClllY SHOWN ON THESE ORAWINCS. Tl£ COmRACTOR SHALL USE INDUSTRV ACCEPTED SlAf.OARO 0000 PRACTICE FOR MISCaJ.ANEOUS WORK NOT EXPUCITLY SHOWN.

J. THESE DRAWINGS REJ'RESENT Tl-IE ~ ISHfII STRUCTURE. TI-IEY 00 NOT INDICATE Tl-IE MEANS OR METI-IODS or COHSTRUCTIOH. TllE CONTRACTOR SHAU. 8£ SOLELY RESPONSIBl.E !"OR THE CONST'RUCTION "4E.I.NS, METHODS, TECHNIQUES, SEOU£NC£S, AND PROCEDURES. ffiE CONTRACTOR SHALL PROVIDE All MEASURES NECESSARY fOR PROTECTION OF LIFE AND PROPERTY DURING CONSTRUCTION. SUCH MEASURES Si-W.I. INCLUDE, BUT NOT BE UMITEO TO, BRACING, FORMWORK, SHOR~C. ETC.

SITE VISITS BY THE ENCINEER OR HIS REPRESENTATI\IE WILL NOT INCW OE INSPECTION OF TtlES£ ITTMS ANO IS F'OR STRUCTURAL OBSERVATION OF THE •INISHED STRUCTUelE ONL\'.
4, NOTES ANO OETAlLS IN J'HE CONSTRUCTIOO DRAWINGS SHALL TAKE PRECEDENCE OVER CE:NERAL NOTES ANO TYPICAL DETAILS.

WHERE NO OET.1.11..S AA[ SHOWN, CONSTRUCTION SHALL CONFORM TO SIMILAR WOR!< ON Tl-!E PROJECT, ANO/OR AS PRO'v'IDED fOR IN THE CONTRACT OOCUMEHTS. WHERE DISCREPANCIES OCCUR BElWEEN PLANS, DETA!l.S, GENERAL NOTES, ANO SPECIFICATIONS, n,,:

GREATER, WORE STRICT REOUIREMHITS, SHALL GOVERN. IF FURTI,ER CLARIF1CATION IS REOUIREO CONTACT TI-1E ENGINEER OF RECORD.

5. SUBSTAf!TIAL EFF'ORT HAS BEEN MADE TO PROVlDE ACCURATE DIMENSIONS ANO MEASURf.:MEHfS ON rHE MA'MNGS TO ASSIST IN THE FABRICATION ,,ND/OR PLACEMENT OF CONsmucTION El.£MEN1'3 BUT If IS rHE sot.£ R(SPONSIBIUTY OF TI-lE CONTRACTOR TO Fle:t..D VERIFY TI-£ OtMENSIONS, Ml:ASUREMEH!'S, N"D/OR CLEAAANCES SHOWN IN THE CONSTRUCTION DRAWlNCS PRIOR TO FABRICATIOfl OR CUTI'INC OF ANY NEW OR EXISTING CONSTRUCTION ELEMENTS. IF IT IS Df.TERMINEO THAT TI-1ERE ARE DISCREPANCIES ANO/OR CONFLICTS WITH THE COKSTRUCTION DRAWINGS THE ENCINEER Of RECORO IS TO BE Non •Ie: □ t,s. SOON AS POSSIBLE.

E. PRIOR TO THE SU91ASSION OF BIOS, THE BIDDING CONTRACTOR 51-W.L ~ SIT THE CELL SITE TO FAfAILIAR!ZE 'Mlrl TI-1E EXISTING CONDITIONS ANO TO CONFlRM T..iAT THE WOOK CAN Gt .-.CCOMPUSHEO AS SHOWN ON n-lE C~STRUCTIOff ORAWINCS. /IHf OiSCREPANC\' FOUND S!,IAU BE BROUGHT TO THE ATTENTION OF CARRIER POC AAO TOWER OWNER.

7. AU. MATERIALS FURNISHED NlJ INSTIJ.U:D SHALL BE IN STRICT ACCOROANCf WITI-1 ALL APPUCAel.E CODES. REClJlAT!ONS ANO OROINN4CES. CQt,,'JRACTOR Stw.1 ISSUE M.1. APPROPRIATE NOTrt:ES ANO COMPl.Y WITH ALL LAWS, OROiNANCES, RULES, REGULATIONS ANO LAWF\JL ORDERS OF Nff PUBLIC >.UTHORITY REGARDING THE PERFORMANCE OF TI-lE WORK. ALL WORK CARRIED OUT S1-1ALL COMPLY WITH A.LL APPLICABLE !AUNJCIPAL AND UTIUTY COMPANY SPECIFICATIONS ANO LOCAl. JURISDICTIONAL CODES, ORDINANCES ANO APPLICABLE REGUlATIONS,
e. UNLESS NOTED OTHERWISE. TI-1E WORK SHAll. INCLUDE FURNISHING MATERW.S, EQUIPMENT, APPURTOW«:ES ANO LABOR NECESSARY TO COMPLETE ALL INSTAU.ATIONS AS INOICAlEO ON THE DRAWINGS.

9. THE COOTRA,CTOff SHALi. INSTALL. ALL [QUIPMO/T N-10 MATERtAI..S IN ACCOAOJ.NC! "WITH ~ANUrACMER'S RECm~MENOATIONS UNLESS SPECIF100.l.Y STATEO 0TI-lmwtS£.

10. IF TH£ SPE,CIFIEO EOVIPMENT U.N NOT BE INSTALLED />S. SI-OWN ON THESE DRAWINGS, n-iE CONTRACTOR SHAU. PROPOSE AN ALTERNATll/1:: INSTALlAnON roR APPROVAL Bl' THE CARRIER AND TOWER OWNER PRIOR m PROCE!OING Willi ANY SIJCH CI-WJCE OF INSTALLATION.

11. CONTRACTOR IS TO PERFORM A SITE INVE:STIGATION, BEFORE SUBMITTING BIOS. TO ocn:RMINE THE 13EST ROUTING OF All CONDUITS F'OR POWER, ANO TElCO ANO FOR CROUNDII«: CABLES AS SHOWN IN TI-IE POWER, mco, NIO OROUNDING PV,N OAAWlNCS.

12. n-lE CONTAACTOR SHALL PROfECT EXISTING IMPROVEMENTS, PAVEMENTS, CURBS, LANDSCAPING ANO STRUCTURES. ANY DAMAOED PART SHALL BE REPAIRED AT CONTRACTOR'S EXPENSE TO THE SATISFACTJON OF OISl-i WIREl..ESS, L L.C. ANO TOWER OWNER 1J. CONTRACTOR SHALL lECiALLY ANO PROPERLY DISPOSE Of ALL SCRAP MATERIA!.S S\JCH AS COAXIAL CABLES ANO OTHER ITOIS REMOVED FROM TI-IE EXISTING FACUT\'. ANTEN~S REMOVED 51-iALL 8E REfURNEO TO THE OWNER'S DESIGNATED LOCATION. 14-, CONTRACTOR SHALL LE,t,','£ PREMISES IN CLEAN CONDITION. TR.ASH ANO DEBRIS SHOULD BE REMOVED FROM SITE O» A D,l,ILY BASIS.
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CONSTRUCTION

DOCUMENTS
MEl'RCJf:C'TM.IMSER
237240.576B60
OOiHl'IIREl.fSS.L.LC. PROJECT IN!'ORMATION
CA-ATC-T-89366
LSSNA0l020A
2M NE Of SAN CLEMENTE
SAN CLEMENTE, CA-92672
=mcc

GENERAL NOTES
GN-2
626
£0':ICBEIE fPUNll.tJIONS ANQ Rfl"fOllC1NC STER • 1. AU COOCRETE WOftl( SHALL 8E IH ACCORDA.'K:E WITH THE ACI J01, AC! 318, N.;:. 3Jt5, ASTM A184, ASTM A185 ANO THE DESION ANO CONSrRUCTION SPECIFlCATIOH FOR CAST- IN-Pl>CE COHCRtTE.

2. UNLESS MOr£D 011-1£RY,1SE, SOIL BfARINC Pfff.SSURE USEO FOR OESICN OF SlABS ANO FOUN~TIONS IS ASSUMED TO BE 1000 per.

J. A1..1. CONCRETE SHAU. HAVE A 1,UN1M'JM COMPRrSSIVE STRENGTH (I'~) OF JOO!> 11sl AT 28 OAYS, UNLESS NOTED OTHER'!ll'ISE. NO MORE TlsAH 90 MINUT[S SHAl.1. El.APSE FROM BATCH TIME TO TIME or PlACEMENT UNLESS APPROVED BY TH[ ENGINEER OF RECORD.

TEIIPERAT1JRE OF CONCRET'E SIV.U. NOT O:CU:O 9171 AT TIME OF PLACEMENT,

4. CONCRETE EXPOSED TO FREEZE-THAW CYCLES SHAl..1. CONTAIN AIR ENTRAINlNC AOMOCTURtS. AMOUNT or AIR ENlRAINt.lENT TO aE BASED ON SIZE OF ACCRECATt ANO F'J Cl.ASS EXPOSl..m: ~ SEVelf:), CEMENT usm T'O SE TYPE U PORTLAND CEMENT WITH A MMIMUl,I WATER-TO-cEMENT RATIO (W/C) OF' 0.45.

5. ALL 5TEEl. RElNf'ORC!NC SH.ALL CONFORM TO ASTM M IS. AU. WElOEO WlRE f.ABRIC (WWF') SHAU. CONFORM TO ASTM A1e5. ALL sPUCES SHALL SE Cl.ASS "8" TV,'SION SPLICES, UNLESS NOTED OlHERWISE. 1'LL HOOICS SHALL SE STANDARD 90 OECftEE HOOKS.

UNL£SS NOTED OTHER'WISC. YIELD STRENGll-1 (Fy) OF STANDARD DEFORMED BARS ARE AS FOLLOWS:
f4 8ARS AHO SMALLER .40 ksl
#5 BNIS AHO LARGER 60 ul 6. TIC FOUOWING M:Nl!.IUM CONCRETE COVER S1-W.L SE PROVIDCD f°OR REINFORCINC STEO. UNLESS SHOWN Oll£RW!SE ON ORAW:NCS:
• CONCRO'E CASr AGAINST AND PERldAfiEHTLY EXPOSED TO EARTH J" • CONCREfE EXPOSED TO £AR1H OR WEATHER:
• f6BARSANOLARCER2'
• f5 BAAS ANO SMAU..ER 1-1/2"
• CONCRETE NOT 0:?0'SEO TO fARTH OR WEATliER;
• SLAB .Atro WALLS J/4"
• llD,WS ANO COI..UIJ.NS 1-1/2"

7. A TOOL£0 mce: OR A J/4" ctW,ffIR SHALL BE PRO'v10e:o AT A1..1. EXPOSED EDGES OF CONCRETE. u~ NOW OTHEJ'!WlS(, IN ACCORDANCE lll'ITH K;l J01 SECTION 4.2.4. •
RfCffllCM IN$Jil,l 1ADON NPJEi· 1. All. ELE:CTRICAL WORK SHAU BE PERFORMED IN ACCORDN+CE WITH THE PROJECT SPECtF\CATIONS, NEC AND All APPUCABI.£ FEOERM.., STATE, ANO LOCAL COOES/ORO'NAWCES.

2. CONDUIT ROUTINGS ARE SCHEMATIC. CONTRACTOR SHALL INSTALL CONDL!ITS SO THAT ACCESS TO EQUIPMENT IS NOT BLOCKED ANO TR!f' HAZARDS ME EUMINATED .
.1. WIR1NC, AACEWAY Al«! SIJPf'ORr METHOIJS ANO tJATERIAI..S SHALL COMPLY WITH TliE REOUIRl\'.MENTS Of ll-lE NEC.

4. ALL CIRCUITS SHAU. SE SEGREGATED AND MA!NrAIN MINIUUM CABLE SEPARATION AS R£0UtREO BY THE NEC. -4. 1. ALL EOUIPl,iENT SHAU BEAA TI-IE UNDERWRITERS LASOAATORIES LAeEL Of APPRO/Al., ANO SHALL CONFORM TO REOIJIREt.lENT OF THE NATIOML ELECTR!CA!. COOE.

4.2. ALL OVERCURRENT OEVICES SHALL HAVE AN INT'tRRVPTIHC CUAAfNT RATING THAT SHALL 6E GREATER THAN THE SHORT CIRCUIT CURROIT TO WI-IICH THEY ARE SUBJECTED, 22,000 .AJC Mt-lJWUM. VERIFY AVAILABLE SHORT CIRCUIT CURRENT DOES NOT EXCEED THE R.ATINC OF E\..ECTRICAL EOUIPMEHT IN ACCORDANCE WtTl-1 ARTlCLE 1 ! 0.24 NEC OR THE MOST CURR(Nf NJOPTED CODE PRE THE

COVERNINC JURISDICTION,

5. EACH END OF EVERY POWER PHASE CONDUCTOR, GROUNOJNG CCHlUCTOR, ANO tELCO CONOUCTOR OR CA8I...E SHALL BE V.SfilO WITH COLOR-COOED 11-tSUt.ATION 0A ELECTIUCAL TAPE (JM BRAND, 1/T Pl.AST1C ELECTRICAL TAPE WITH IN PROrtC'l10,'l, OR EOUlil..). THE tOCNTIF'ICATION METHOD Slw.L CONFORM \IIITM NEC ANO OSHA.

6. AU. ELECTRICAL COMPONENTS SHALL 95: CLEARLY LA8EU:o wmt l..AMICOIO TAGS SHOWINC TiiEJR RATED vot.TAOC, ?HASE CON.,CURATIOH, WIRE CON.,GURATION, POWER OR AU.,w:rrf RATNG AND BRANCH CIRCUIT rD NUMBERS (1.,. PANEL 60ARO ANO CIRCUIT ID'S).

7. PAHEL SOAROS (ID NUMBERS) SHALL SE CLEARLY LABELED wmt PlASTIC l.>.BELS.

6. TIE lll!W'S .ARE NOT At.LOWED,

8. ..U POWER AND EOlliPMOfT CROUMO WlRINC IN TUBING OR CONDI.IT SHALL 6E SINGLE COPPER CONOUCTOR (#14 OR LARGER) wrrn TYPE TI-lHW, THWN, THWN-2. XHHW, XHHW- 2, rnw. THW- 2. RHW, OR RHW- 2 INSULATION UNLESS OntERW.SE: SPECIFlEO. 1 0. SUf'PlEMEHTAl EQUIPMENT CROUNO WlR1NO LOCATED INDOORS SHALL BE Slt«'.ilE COPPER C0"40UCTOR (#6 OR 1..ARCER) WITH TYPE TltHW, n,;wN, THWN-2, XHH'N, XHHW-2, 00.. 11-IW- 2, RH\11, OR RHW-2 INSUl.>.TION UNLESS OJ1,IERWISE SPECIAEO.

11. POWER ANO CONTROL WlR!NG IN FlEXIBi..E CORO SH.ALL SE MULTI-COHOUCTOR, TYPE SOOW CORO C, 1-4 OR l.t.RCER) UNLESS OTiiERWIS!:'. SPEOAED.

12. POWER AND COWlROL WIRINC F'OR US£ IN CABLE TRAY SHAU. SE MULTI - CONOutTOR, TYPE TC CABLE (1 14 OR t.ARCER). WITH T',1>E THHW. THWN. THWJ,i- 2, XHH'IW. XHHW- 2. THW, Tl-lW-2, RHW, OR RHW-2 INSULATION UNl.£SS OTllERWISE SPECIF1EO. 1 J. ALL POWER AND GROUNDING CONNECTIONS SHALL BE CRIMP-sm..E, COMPRESSION WIRE LUGS At«l WIRE NUTS BY Jl,IOMAS ANO 8EITS (OR EDU.Al,). LUOS ANO WIRE NUTS SIW..I. SE RA1EO F"OR OPERATION NOT LESS THAN 75' C (ijO' C If' AVAILABLE).

14. RACEWAY ANO CABLE TRAY SHALL BE LISTED OR l.>.Bll£O FOR ELECTRICAL USE IN ACCORDANCE WITH NEW,.. UL, ».SI/IEEE ANO NEC.

15. ELECffllCAL I.IETAl..1.IC ruBIHG (EMT). INTERMEDIATE MaAL CONDUIT (IMC), OR RIGID METAL CONDUIT (RMC) SHAl.l. BE USED FOR EXPOSED INDOOR LOCATIONS.

16. Et.ECTRICAL METAWC TIJ91NC (EMT) OR METAL-CLAD CABLE {MC) SHALL SE USED FOR CONCEALED JNOOOR LOCATIONS. 17, SCHEDULE 40 PYC UNOERCROIJNO ON S~GHTS ANO SCHEDULE 80 ~ F'OR All. El.BOWS/90, ANO ALL APPROVED ABOVE ORAi)( PVC CONDUIT.

18. UOUID- TICHT Ft.DCIBLE METAU.IC CONDUIT (LJQlllO-TITE FL.EX) SI-W..L BE USED INOOORS AHO OUTDOORS. WHERE VIBRATION OCCURS OR FLEXIBIUTI' IS NEEDCO.

19. CONOUIT ANO TU81NC FTTTINCS SHALL BE THRfAOED OR COi.lPRESSKlN- TYPE AHO Af'PROV[[) FOR nu: LOCATION USED. SET SCREW FTITINGS ARE NOT ACCEPTABLE.

20. CABt-le:TS, BOXES ANO WIRE W.AVS SfV..Ll BE lAEEl..[D FOR EL(CTRlCAL USE IN ACCORDANCE W1J1,I NEMA, Ul, ANSI/IEEE .-.-io nlE NEC. 2 1. WIREWAYS SHALL BE METAi. WITH AN ENAI.\El. RNISH ANO INCLUDE A H'.NCED COVER, DESIGNED TO SWING OPEN OOWl.'W.AROS (WIROIOLD SPECMATI: W!REWAY).

22. st.onm W'R1NC DUCT SH.AU. BE PVC AND IMCLl« COVER (PAHOUIT TYPE E OR EOUAIJ.

23. CONDUITS SHALL BE FASTENED SCCI.JRELY IN Pl.ACE WITH APPROVED NON- PERFORATEO STR,i,PS ANO ~G(RS. EXPlOSIVE DEVICES {I.e. POWDER-ACTUATED) FOR ATTACHING HANGERS TO SlRUCTURE Wl.L NOT BE PERMITTED. CLOSELY r ou.ow rn£ LINES OF THE STRUCTURE. t.WHT.AIN CLOSE PROXIMITY TO THE STRUCTURE ANO KEEP COHDUns IN TIGMT ENYELOPES. CJ.w.CES IN DIRECTION TO ROUTE AROUND OBST.AD.ES SHALL BE lih\OE WITH CONDUIT OIJTlET BODIES. COIOJlt SHAU OE INSlM.lEO IN A NEAT AND WORIOU,:-,UKE M.A.'/NER. PAR.W..£\. AHO PERPOfJICUt.AR TO STRUCTURE WAU. AND CEII.JNG UNES. ..U CONDUIT SHALL BE FISMED TO CL.EAR 08STRUCTION5. ENDS Of CONDUITS SHALL BE TEM?ORARl.Y CAPP'EO flUSH TO FINISH CRACE TO PREVENT CONCRETE. PLASTER OR DIRT Fi.OM OOUIINO. CONDUITS SHAU 9E RKJIOLY Ct.AMPEtl TO eoxts Eh' OALVANIZEO ~LE IRON BUSH.NC ON INSIDE AND GALVANIZED l,,IAJ..WBI...E IRON LOCl<NUT ON OUTSIDE AND INSIDE.

24. EOUIPMENT CABINETS, TERl,miAI... BOXES, JUNCTION 00XES ANO PULL BOXES SHALL et: GAt.VAHJZe:D OR EPOXY- COATED SHEET STER. SHALL MEET OR EXCEEO UL 50 AHO Bf RAfED NEMA. 1 (OR SETTER) fOR INTERIOR LOCAllOtlS ANO NEMA 3 (OR BETTER) FOR

EXTERIOR LOCATIONS,

25. METAL RECEPIACLE, SWITCH AND OE:VICE BOXES SHAJ..l BE GALVAN1ZEO, EPOXY-COATED 00 NON- CORROOING; SHALL MEET OR EXCEEO UL 514A ANO NEW. OS 1 AND BE RATED NEW. 1 (OR E'lCT'l'ER) F'OR INTER!DR LOCATIONS ANO WE:ATtlER PROTEClED (WP OR BETTER)FORD!rERIORLOCATIONS,

26. NONMETALLIC RECEPTACLE, SWITCH ANO DEVlCE BOXES SHAU. MEET OR EXCEEO NO,IA OS 2 (NEWEST RE.'l!SlON) AHO BE RATED NE:MA t (OR BETTER) F'OR tHERIOR LOCATIONS ANO WEATHER PROTECTED (WP OR DCTTER) FOR EXn:RIOR LOCA.TIOOS.

27. THE CONTRACTOR S~ NOTIFY ANO OBTAt-1 NECESSARY AIJTHORJ2A110N FROM THE CARRIER ANO/OR D!SH WIREL.£SS., LLC.. ANO TOWER OWNER BEFORE COI.IMENCINC WORK ON THE N:. POWER OISTRIBIJT10N PANEl.S. 215. THE CONTRACTOR SHALL PROVIDE NECESSARY TACCINC OH THE BREAl<tRS, CA8LES AHO OlSTRIBVTION PANE!..S IN ACCORDANCE WITH TH[ APPUCASLE COOES AND STAH!W<OS TO SWECI.JAAO UfE AND PRDPEJHY.

29. INSTALL LAMICOIO I.ASEL ON THE METER CENTER TO SH0¥1 "DISH wtREl..ESS, L LC.".

JO. AU EMPTY/SPARE CONDUITS THAT ARE INSTALJ.EO ME TO HAVt: A METERED WLE TAPE PULl CORD fNSTALUD. dish
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S70150UTHSolHl'AfEORM
UlTl£10N,C080120
llAAWN ar, ICHEcxm sY:.i,lpplltMD 11'1'
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CONSTRUCTION
DDCU t.tENTS
2l7240.l 78860
DISH'IIIREl.£SS. L-L-C. PIIOJECT INF0AM.\TKlN
CA-ATC-T-89366
LSSHA0 1020A
2M NE OF SAN CLEMENTE
SAN CLE MENTE, CA- 92&72
SMEU mu:

GENERAL NOTES
GN-3
627
CBQUNPUfG NQJ[S· 1. AU GROUNO ELETilODE SYSTEMS (INCLUDINC TELECOMMUNICATION, RADIO, UGHTNlNO PROTECTION AND ,.C. ?OW£R GES'S) SHAI.L BE BONDED TOGETHER AT OR BELOW GRADE, BY TWO OR MORE COPPER BONDtNG CONDUCTORS IN ACCOROANCE WITH THE NEC.

2. THE CONTRACTOR 51-WJ.. PERFORM IEEE F'M.l-OF- POTENTW. RESISTANCE TO EARTH rESTINC (PER IEEE 1100 AND 81) FOR ORDUNO ELECTRODE SYSTEMS, THE CONTR~ SHAI.L FURNISH ANO INSTAU SUPPL.EMO/TAI.. GROUND ELECTRODES AS NEEDED TO ACHIEVE A T£ST RESUt.T OF 5 OHMS OR LESS.

J. THE CONTRACTOR IS RESPOHSIBLE FOR PROPERLY SEOUENCINC GROUNDING ,t.NO UNOERCROUND CONOUtT INSTAL.L>,TION AS TO PREVENT Nft LOSS OF COtmNUfTY IN THE GROUNDING SYSTEM OR DAMAGE TO THE CONOUlr ANO PRO',IIOE TESTING RESULTS. •· METM... CONOUIT ANO TRAY SHALL BE GROUNDED ANO MADE ELECTRICALLY CONTINUOUS WITH LISTED BONDING AmNGS OR BY BONDING ACROSS n.lE OISCONTINUliY WITH 16 COPPER WIRE UL APPROVED GROUNDING TYPE CONClUIT Cl.AMPS. !!. METAL RACEWAY SH,'.U.. NOT BE USED AS THE NEC REQUIRED EOUIP!dENT ORDUNO CONOUCTOR. S~OEO COPPER CONDVCTORS WITJ.I OR£EN INSULATION, SIZED IN ,\CaJRCW.CE WITH TME NEC, SHAU.. BE FURNISHED ANO INSTAll..£0 wrm THE POW(R CIRCUITS TO BTS EQUIPMENT.

6. EACH CABINEl" FRAME SHAU. BE OIRCcnY CONNECTED TO THE MASTER GROUND ~R WITH GREEN INSULATED SUPPLEMENTAL EOUIPI.IENT GROUND WIRES. /fl STIWlDED COPPER OR I.ARCEA FOR INDOOR BTS: #2 BARE SOLID TINNED COPPER FOR O\JTOOOR BTS.

7. CONNECTtONS TO THE GROUND Bl.JS SHAU. NOT BE DOUBLED UP OR STACKED BACK TO BACK CONNECTIONS ON O?POSITt SIDE Of THE GROUNO BUS AR£ PERl,ITTEO.
!I. AU EXTERIOR GROUND CONDUCTORS 8£TWUN EQUIPMENT/GROUND !WIS AND Tl£ GROUND RING SHALL BE 12 SOLID TINNED COPPER UNLESS OTHERWISE INDICATED.

9. AL.UWNUM CONDUCTOO OR COPPER CLAD STEEL CONDUCTOR SHALL NOT BE USED FOR GROUNDING CONNECTIONS.

10. USE Of 90" BENDS IN THE PIWTECTION CROUNDING CONDUCTORS Sl-lALL BE AVOIDED WHEN 45· BENDS CAN 8( ADEQUATELY SUPPORTCO.
1 I. EXOTHERMIC W£L0S StW.L BE UStll FOO ALL OROUNDINO CONNECTIONS BELOW GRADE.

12. ALL GROUND CONNECTIONS ABOVE GRADE (INTERIOR AND EXTERIOR) 5\.IAI.I. BE FORMED USING HIGH PRESS CRIMPS,

13. COMPRESSION GROUND CONNECTIONS MA'r' B£ REPLACED 8'1' EXOTHER'-'IC WELD CONNECTIONS.

1.. ICE BRIDGE BONDING CONDUCTORS SHALL EIE EXOTHERMICN.LY BONOCD OR aoue:o TO nit BRIDGE ANO THE TOWER GROUND ""'· 15. APPROVID ANTIOlaDANT COATINGS (I.e. CONOUCTM'. GEi. OR PASTE) SI-W.l. BE USED ON ALL COMPRESSION ANO BOLTED ORDUNO CONNECTIONS.

ALL EXTERIOR CROUND CONNECTlOt-tS SHALL BE COATED WITH A CORROSION RESISTANT MATERIAL. 17, MISCELLANEOUS ELECTRICAL ANO NON-ELECTRICAL METAL BOXES, FRAMES ANO SUP?ORTS SKA.LL BE B0/.0£0 TO Tl-lE ~D RING, IN ACCORDANCE WITH Tl-lE NEC.

18. BONO AU METAWC OBJECTS WITH~ 6 ft OF f.WN GROUND RING WITI-l ( 1) 12 EIARE SOLID TINNED COf'PER GROUND CONDUCTOR.
19, CROUNO CONOUCTOflS USED FOR THE FACILITY CROUN!)ING MID UCHTN.NG PROTECTION SYSTEMS S1-W.1 NOT BE ROUTED Tl-lROUCH i.lOALUC 08.JECTS THAT FORJ.1 A RING AROUND THE COt«lUCTOR, SUCH AS METAi.UC CONOUITS, METM... SUPPORT CUPS OR st.£EVES TMROVCH WAI.LS OR F1.00RS. WHEN IT 15 REQUIRED TO BE HOUSED IN CONDUIT TO MEET CODE REQLIRE!AENTS OR LOCM..

COHDITIONS, NDN-1,(_ETAU.IC IAATER1AL SUCH AS f>VC CONDUIT SHALL BE USED. WHERE US£ Of" MET.&J. CONDUIT 15 UNAVOIDABLE (i.e., NONMETAWC CONDUIT PROHIBITED B'r' LOCAL CODE) THE GROUND CONDUCTOR SHALL BE BONDED TO EACH END OF nlE METAL CONDUIT.

20. ALL QROUNOS THAT TRANSITION FROM BELOW GRADE TO ABOVE G!M,OE MUST BE #2 BARE SOUO TINNED COPPER IN 3/4-• NON-METALLIC, FLEXIBLE CONDUIT FROM 24" BEl.OW GRADE TO \111Tl-llN J ' m 6" OF' CAO- WEI..O TERUlt4.\TION POINT. THE EXPOSED EOO OF THE CONDUIT MUST BE SEALED WITH SIUCONE CAI.JU<. (ADO TRANSITIONING QROONO STANCWlO OETAll AS Wfl..L).

21. 8UUIINGS WHERE THE I.IAf,l CROUNOING CONOUCTORS ARE REQUIRED TO BE ROUTED TO GRACE, ii-IE CONTRACTOR SHALL ROUT£ TWO GROUNOl-fG CONDUCTORS Fl'WM THE ROOFTOP, TOWERS, ANO WATER TOWERS GROUNDINQ RING, TO TI-IE EXISTING GROUNDING SYSTElil, 1l£ t.ROUNOINO CONDUCTORS SI-W.L NOT BE SMALLER THAN 2/0 COPPER. ROOFTOP GROUNDINQ RINO SHALL BE BONDED TO THE E)OSTINQ CROUNOINO SYSTEM, TH£ BUILOINQ srEEL COLUMNS, LIGHTNING PROTECnON SYSTEM, ANO 9UIL01NG MAlN WATtR LINE (FERROUS OFI NONFERROUS METAL PIPING ONLY). 00 NOT ATTACH GROUNDING TO Ff<E SPR!NKWI SYST"EM PIPES. dish
wireless.
~ 01 SOUTH SNiTAft ORM UTTL£TON,CO B012.0
TCM'EAENClliEERINGF"ROFESSIONALS 326lfrfONRO.RA.UJGH,NC2750J OFFJC~ {11 1i ) 661-5351 DAAWN B"T': ICH EQ<ED s-r:jm,RMDErr.
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RfOSRf:Vf:

CONSTRUCTION

DOCUMENTS
M:E PROJECT NUMBER
2372-40,378!360
DISH WIRELESS, LL.C. /'ROJECT ff'ORW-TION
CA-ATC-T-89366
LSSNA0 1020A
2M NE Of SAN CLEMENTE
SAN CLEMENTE. CA-92672

GENERAL NOTES
GN-4
628
◄+b iii!- C:onnectivlty Solutions +++ifii- Connectlvlty Solutions ODE Enclosure
Fiber, Power Distribution, and
Cable Management Enclosure
Specifications
via Photon's innovative Fiber,
Power Distribution, and Cable
Management Enclosure (ODE)
provides an ease of installation
for small cell and macro sites In
a compact footprint. Toe ODE
offers high levels reliability to radio
equipment wh/le protecting the
Fiber Network Interface Device
(NID) and organizing cable.

Features
• 6LCD~lexSMadaptersfofFlberNIDdamsn:ation
• 10 Amp 48 VDC breakerfbr Fiber NID pcmr
• 4· conduit holes .on top and bO:tt~. with removable seal cap • ~abta bend radius pcotaction
•Wa!fmount
• 12 posttlon ground bUs bar
• Excess'eablamanagement
frontvtew back1.1h,w
-
"'fl viaPhoton Z- vinphoton.cam t. 331.21.0.4040 1) 3557 Suttertleld Rd, StJite 105 • Allforn, ll.60502 'Vf viaPhoton rQUIPMENT DETAILS

PART NUMBER
Dimensions
Weight
Cable Entry
Fiber Bulkhead
Breaker
Enclosure Material

STANDARD FEATURES
Mounting
Enclosure Door
19Inlx16.9InWx9.1inH enclosure
25 !bs
conduit holes. 4 (bottom) 4 (top) with
removab!Et seal cap
6 LC/IJPC4Uplex adapter
10Amp,48 VDC
gray, rugystllzed polycarbolliJte I Wrated
wan mount (318 in bolt) .
hinged.

Enl/iro~mental, Sealln~ NEMA 4X\ !PG6 with 4 corner screws lnst!l!ed securrty- stelnlessstcel latch With pad!Ockciasp
OutdoorTemperaturo Range -4o•cto +B0°C (-4D°'Fto 176°F) Instrumented Dart Impact 7~•F, .. 5~5 in-lb.

Fall!ng Ball Impact 73• 900 f_nl!~. Test Spec. UL-746
Flame Rating UL. SVA. Test Spec. UL-94
Outdoor UV Exposure Fl. Test Spec UL
~~ vlaphOton.com \. 5'31.2t.0.l.040 9 3557 Butt~ffi<?ld hd,Sl.Jlte 105 • Aurora. lL60502

SUPPLEMENTAL
R-1
629
~untington Beach

IIH J')
~~~·~ ... I 0 M v rr'1ft.l
remttllla
Ouol.n).tdle'
Carls d • h cord1dc
San Diego· £1 CaJon
Ci,~~,a---- r,;• .. Tecare T1Juana

VICINITY MAP

PROJ CTTEAM
TO
N
AMERICAN TOWER•
SITE NAME: SAN CLEMENTE CA
SITE UMBER: 89366
ATC PROJECT NUMBER: 13688490_C6_04
SITE ADDRESS: 2M NORTHEAST OF SAN

CLEMENTE

SAN CLEMENTE, CA
92672
137.5 FT SELF SUPPORT TOWER MODIFICATIONS

PROJECT DESCRIPTION SHEET
99365
Arr:111,-c
SAN ClE\tENTE CA
R'c\l CALIFORN~
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ITE NUMBER: 89366
SITE NAME: S CLEMENTE CA
DISH SJTE ME: SAN LEME TE C
DISH SITE NUI\iIBER: LSS A01020A

DISH COLLOCATION ON EXISTING SELF UPPORTING TOWER
1M NE OF SAN CLEME TE
SAN CLEME TE. CA 92672
!ORANGE CO iNTY)
PHOTO RENDERED BY TOWER ENGINEERING PROFESSIONALS, INC. 635

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rTE NMIF. 'AN CLEl> l iTE CA
DORESS 2M E OF SAN CL8'1ENTE
SAN CLEMENTE. CA '!2f,72

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EXISTING VIEW: LOCATION 1
PHOTO REI\DERED BY TOWER ENGIN ERi G PROFESSIONALS, I C. 636
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PROPOSED VIEW: LOCATION 1
PROP<.lSED F.Ql;IPl\.lE!'.T \ T
El F\1.-\TION i>' '.()''
1J 1 -\NTENNAS
6 RADIO'-
PHOTO RENDERED BY TOWER E GINEER ING PROFESSIONALS. INC. 637
Street Address
Pramira
Radio Frequency Exposure
RF Safety and NIER Analysis Report
SITE- PECIFIC-1 FORMA TIO
LSSNA01020A Multi-Licensee Facility
2M orthea t of San Is Dish Wireless a Significant
Clemente Contributor to Co-L-ocator ~ ---------+------- ---------1 Dish Wireless's Max
% MPE (Measured -
General Public
Broadcast (AM/FM/TV)
Co-Locators
Compliance Status
San CJemente, CA 92672
0 YES 181 0
1 06/15/2023
□ COMPLIANT AS DESIG
Dish Wireless' Max % MPE
(Predictive - General Public)
Assessment Date
Assessment Purpose
□ COMPLIANT PER RF SAFETY PLA UBMISSIO
l&IMITIGATIO IS REQUffiED
Site Photo
dis
wireless .
□ YES 181 0
DYE □ 0
181 /A

0.83%
SB
638
f:) Pramira
Table of Contents
Certification .......................................... ................................ ............................ ......... . 2 Executive um,nary ....................... .............................................................. ............... 3 -· I Conclusion and Recommendations: ..................................................................... S Introduction .. .... ........ ........... ...... ..... ................................................................... .......... 6

3. l Site Description: ................................................................................................... 6 J._ Site Configuration Being Modeled: ..................................................................... 7 4 Predictive Ana lysi Detail : .......... .. .. .... ................. ....................... .............................. 8

4.1 Analysis Locations: .................... .......................................................................... 8

4._ Antenna In ventory: ..... .. .. ......... ....................................... .. .. ....... ........................... 9

4. RF Emissions Diagram(s) ....... ........ ... ...................................................... .. ........ 10

4.3. 1 RF Emissions Diagram(s)- All Transmitters ................. ................... .......... 11

4. ·- RF Emissions Diagram(s)- Dish Wireless Transmitters Only: .. ..... .. ......... l3 Signage/ Barrier Detail ..... ..................................... ...................... ............................. 13 -. I ignage/ Barrier Diagran1 ................................ ................................................... 15 6 Conclusion and Recommendation : ........................................................................ I 7 7 Appendix A: FCC Compliance and Rf afety Policies .................. ......................... 18 8 Appendix B: Overview of RoofMaster® Functions and Assumptions .................... 21 9 References ......... ............. ..................................... .......... ...... ........... ............. .............. 24 IO Limited Warranty .. ........................... ............................................................ ............. 25

Page 2 ends

Pramira, Inc • 2552 Walnut Ave.. uite 200, Tustin, CA 92780 • 800.678.1169 639
':) Pra'!1ira
1 Certification
This report, prepared by Pramira, Inc. for Dish Wireless, is intended to document compl iance and evaluate power density levels as outlined in the report. The computations, analysis, and re ulting report and conclusions were based on applicable FCC guidel ines and regulations for maximum permissible exposure to humans consistent with FCC OET Bulletin 65, Edition 97-0 I.

Additionally, Pramira, Inc. certifies that Lhe assumptions are va lid and that the data used within Pramira' control are accurate including information collected as part of Pramira· field surveys. Pramira, Inc. does not however certify the accuracy or correctness of any data provided to Pramira, Inc. fo r this ana lysis and report by Dish Wire less or other third pa1tie working on behalf of Dish Wireless.

I ce1tify that the attached RF expo ure ana lysis and repott is correct to the best of m knowledge, and all calculations, a sumptions and conclusions are based on generally acceptable engineering practices:

SIGNED, 15 JUN 2023
Tim Alexander, P. .

This compliance assessment and report has been prepared and reviewed bv:

Name
Title
Date
PreJ>arer Reviewer
Abdelsalam Masoud ike Arnold
RF Engi neer Project Manager
06/15/2023 06/ 15/2023

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Pramira, Inc • 2552 Walnut Ave., Suite 200, Tustin, CA 92780 • 800.678.1169 640
Pramira
2 Executive Summary
his repo1t provides the res ults of an RF power density analysis performed for Dish \Virele s at site LSSNA01020A in accordance with the Federal Communications Commission (FCC) rules and regulations for RF emissions described in OET Bulletin 65 Edition 97-0 I.

This report addresses RF safe ty fo r two classified groups defin ed by OET Bulletin 65:

Occupational/ Controlled and General Population/ ncontrolled. Based on the analysis, this site will be Compliant with FCC rules and regulations and Dish Wireless 's Signage and Barri r Policy if the mitigation detail provided in Table I are implemented. . A _au, w••
(<1>) • ·:=· .

I
'-~-- _I._ I Final Compliant - - Ila••--·· ..._,,, I 1--- -·--- ~.=,:.=.: ====-~ ~::.~- I _ __ , _,_ 4'(1 --:--...:::_-~, Configuration :=~-=-- ---- 1 ..... :z= --- ... ____ 2::-:-'.Z.':"'.: ==-= I•~-- g:~~ - • • - w .... ""::""'...., ::-::::.:=.-:: - a• d "~ • -·-- ... '"4"' ... --; •• d:dl . GlllDELINES NOTICE CAUTION WARNING NOC INF'O BARRTER/MA RKER Access Point(s) 181 [1] " 0 [] □ [] □ [] ~ [ IP □
Alpha D [ J □ [ J □ [] □ [] 0 [] C
Beta o I J □ l J o l J □ [] □ [] □
Gamma □ [] □ [] □ [] □ [] □ [] C
OTE: The table represents either the signage/barriers installed / removed OR items required by the ma rket (if mitigation is not installed by consultant/vendor). ' /J,,, I' RF ~1 <J11s fmuld l•e posred 1.w ti, lccess ( i,11e t,J the. ite f~.:e drawirig 111 ~e,uun: _, , Specialty Sien Detail
Location NIA
Access Point NIA
Aloha NIA
Beta NIA
Gamma NIA
NOTE: The tables above represent EXISTING compliance items implemented at this location.

Notes/ Additional Compliance Requirements(s):

Mitigation i required per the ignage/ Barrier Diagram.

Table l: Mitigation Requirements for Compliance

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Pramira, Inc • 2552 Walnut Ave., Suite 200, ustin, CA 92780 - 800.678.1 169 641
(:)Pramira

2.1 Conclusion and Recommendations:
• The results of the analysis indicate that power density levels in the generally accessible area on the Utility Pole level will not exceed the FCC's MPE limit for General Population environment .
• The max theoretica l % MPE is 0.83% (FCC General Public) directly in front of the antenna beams at the Utility Pole level.
• 0 and Guidelines Signs need to be posted on the Access Gate to the Site. • This site will be operating in general compliance with FCC OET Bulletin 65 and Dish Wireless 's signage policy as the mitigation requirements outl ined in the Executive Summary are implemented. ee Signage/Barrier Diagram section for further details on the recommended ignage placement locations.
·our· Afodi/icaJions to 1he ile: and/or increases in channel co11n1s or power levels exceeding those listed in this repor/ will require addilionnl evahwlion to de/ermine compliance.

Pag 5 of25
Pramira. Inc · 2552 Walnut Ave. Suite 200 Tustin, CA 92780 • 800.678.1169 642
l:):,ramira
3 Introduction
The purpose of this analysis and report is toe aluate the cumulative power den ity levels of all non-excluded antenna located on the site and identify any areas of concern that require mitigation. This report also a sesses the site·s compliance with FCC OET Bulletin 65; • Guidelines for Human Exposure to Radio-frequency Electromagnetic Fields '.

3.1 Site Description:
• Site Name:

Street Address
LS A01020A
2M ortheast of an Clemente
San Clemente, CA 92672
• Latitude: 33.44368333°
• Longitude: -J 17.58865°
• tructure Type Self, Support
• Structure Height: 13 7.5' AGL
• BTS Equipment Location : The BTS Equipment i located on the Ground. • Co-Locators/ Other Antennas: /A
• Access: I

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Pramira, Inc · 2552 Walnut Ave .. Suite 200 Tustin, A 92780 • 800.678.1169 643
':)Pramira.

3.2 Site Configuration Being Modeled:
• This a elf, Support application where Dish Wir less antennas are mounted on the Self, upport.
• This will be a Three-Sector site with One Active in each sector. • The values of the antennas rad center for all sectors (67'), Utility Pole Height (35') and Shelter Height (Io·) are based on the CDs. These values must be verified on the site aud it for the post study.
• Each sector upports 50 Rat 600, 1900. 2100MHz. All L TE supports M[MO. • All technologies were evaluated assuming the maximum number of channels and were running at maximum power 100% of the time .

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Pramira, Inc • 2552 Walnut Ave .. Suite 200, Tustin, CA 92780 • 800.678. I 169 644
l:) ~~amira
4 Predictive Analysis Details:

For purposes of this ana lysis, RootMaster® was configured to provide an output based on the appropriate MPE limit( ) published in the FCC's guidelines. The antenna information was loaded into RoofMaster®, an MPE predictive analy i tool by Waterford Consultants, LL .

4.1 Analysis Locations:

Number of Elevation Analyzed: 1
• Utility Pole Level
• A study at the Other levels was not required as the stud_ at the Util it Pole level show that the PE limit is below the General Population MPE limit on the Other levels.

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Pramira, Inc · 2552 Walnut Ave .. uite 200, Tustin, CA 92780 • 800.678.1169 645
':)Pramira

4.2 Antenna Inventory:

The following table shows all transmitting antennas and contains the technical data used to simulate the power density that may be encountered with all antennas simultaneously operating at full rated power with the exception of any excluded antennas cited in this document. If Co-Locator antennas exist and the u e of" nknown'· as an antenna model that means the specific antenna details cou ld not be ecured, generic antennas, frequencies, and Tx powers were used for modeling. The assumptions used are based on past experience with communications carriers.

Z-height represents the distance from th nearest walking surface to the Centerline of the antenna.
,._ ,.,_ Cltbw Talll""'4
Onll Alpl!A • _Antl MOO 600 --10 -o.s 107 192• 3156 C~IIMu CXJl044• ll.O Ouh Alplw,_Antl Nl900 1900 40 0.5 1•2.6 7924 13000 CtllMa .. CX12044it 32.0 Dish Alph•fatl NUOO 2100 40 o.s 142.6 8689 1•2ss C•IIMa, CX12C•4• 32-0 Ois Beta_Antl N600 600 30 OS !07 191• 3156 CellM'i1.ll CXJ2044, 32.0 Diill SeUI_AAtl 1lJOO l 'X'O 40 0.5 142.6 7924 13000 Ct!IIMa.11. C.Xl2044x 32.0 Dish Beto_Antl NllCJO 2100 40 0.5 142.6 8689 14255 CellMalll CX12044x )2.0 Dl>l1 Gimmo_"'111 600 600 30 0.5 107 192• 3156 C•IIMa.c CXJ 2044• 32.0 Dish Gammo_Antl Nl900 1900 40 0.5 t•2.6 7924 000 C•IIMax CXU044, 32.0 O.i.rhGi1mm AnU NZlOO 2100 •a D.5 JC2,6 8689 l l-2SS CeflMaA CX12044x 32.0 The aritenna Z-heights listed above are referenced to the Top of the Table 2- Antenna Inventory
Panel 6.0 u.ss 71 0
Po.,.1 6.0 17.45 6J 0
PInef 6.0 17.85 66 0
Pancl 6.0 ll.55 71 120
Panel 6.0 11.45 6J uo Panel 6.0 17.85 66 120
Panel 6.0 12.55 71 240
PaneJ 6.0 17.45 63 240
Panel 6.0 17.85 66 l•O
tility Pole Level.

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Pramira, [nc • 2552 Walnut Ave., Suite 200, Tustin, CA 92780 • 800.678.1169 646
':)Pramira

4.3 RF Emissions Diagram(s)
The RF missions Diagram(s) display the Theoretical spatially averaged Maximum Permissible Exposure ( PE) percentag that are expected for each study' e levation for Dish Wireless antennas and all other catTier antennas at the site.

General Popu lation MPE limit is included to demonstrate where Dish Wireless is a significant contributor to accessible areas where mu ltiple carrier's transmitters are present.

These diagram us modeling a pre cribed in OET Bulletin 65 and a umptions detailed in Appendix A.

The key at the bottom of each diagram indicates if percentages displayed are referenced to Occupational Lim it and FCC General Public Maximum Permissible xposure (MP ) limits.
% of FCC General Public Exposure Limits
0% - 50/o 5%- 100% 100% - 500% 500% - 5000% 5000% +
- -- • -'
.:._- -.~~-_-: __ ~
% of FCC Occu ational Ex osure Limits
0%-1% 5%-20% 2ocvo -100% 100% - 1000% 1000% +

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Prarnira. fnc • 2552 Walnut Ave.. uite 200, Tustin, CA 92780 • 800.678.1169 647

4.3.1 RF Emis, ions Diagram(s)- All Transmitters
Reference Plane: Utility Pole Level
[I]
tility
Pole "-.

Dish Gamma
240°
Ground
Dish Beta
120°
':)Pramira
Percent MPE legend
0 07. .5,:
5%· 1~
100~ -500~
D soo-c • sooo%
• 5000% +
Gener Population Limits
Sula9
10 foot grid size
[Avg: 35 1041 feet]
McllC Value· 0.837.

Carrier Color Code
I• Drsh I
The maximum theoretical% MP of the General Population limits =0.83% Page l l of 25
Pramira, lnc • 2552 Walnut Ave., Suite 200, Tustin CA 92780 • 800.678.1169 648
[TI
Reference Plane: Utility Pole Level
tility
Pole
Dish Gamma
240°
Ground
I
l:)Pramira
Pe1cent MPE Legend
0 OY. ·1"
lZ -20,:
20%- 100%
0 100¾ • 10007.
■ 10004+
Occupational Lm
Sula 9
1 0 foot g,id s,ze
(Avg 35 to 41 Feet]
Max Value: 0.17¼
C:a11ie1 Colo, uxle I• Dish
The maximum theoretical % MPE of the Occupational imit =0.17%

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Pramira. Inc • 2552 Walnut Ave., Suite 200 Tustin CA 92780 • 800.678.1169 649
(:) Pramira

4.3.2 RF Emissions Diagram(s)- Dish Wireless Transmitters Only:
w
Reference Plane: Utility Pole Level
tility
Pole •
Ground
- , I
Dh;~;;nma '-.~~""""~
Pe1cent MPE Legend
D 0% -~
54- 100~
ii 1~ -~
D 500% • 5000"•
• 5000,: ♦
Geneial Populalion Limits
Suta9
10 loot g1id size
(Avg. 35 to 41 Feet)
~ ax Value: 1183%
Ca11ie1 Color Code
,. 01$'1
The maximum theor ti ca l % MPE of the General Population limits =0.83%

Page 13 of 25 ends

Pramira, Inc · 2552 Walnut Ave., Suite 200 Tustin, A 92780 • 800.678.1169 650
w
Refe.-ence Plane: tiJity Pole Level
Utility
Pole· '»...

Dish Gamma
240°
Ground
a
0 Pramira
Pe1cenl MPE Legend
□ 0% ·1%

17. -20%
20% -100%
0 100% -10007.
• 1000% +
0 ct.4)allorlal Limts
Sok9
1 0 fool grid size
(Avg: 35 to 41 Feel)
Max Value: 0.17%
C.,mer Colo, Code
,. Dish
The maximum theoretical% M PE of the Occupational Limit =0.17%

Page 14 of 25 ends

Pram ira, Inc • 2552 Walnut A e .. Suite 200, Tu tin. CA 92780 • 800.678.1169 651
':)Pramira
5 Signage/ Barrier Detail

5.1 Signage/ Barrier Detail
. ( ·---· (<'(>)
I & " ":"!'"'" .. . I=~ ~ -= I Final Compliant , __ ~ ··--··'., --../ I ---- .::~--= ! :::.:.:,:-::t ,__wl)Qtl a. ,w __ ,..,.,."-C I --- --- I 1==-- ____ ..,._ __ ...... _,.. __ ... .._ ___ Configuration ·--.-. t ~~~ =:=:- ~~ I • w•-•••- - - ----.....-- -• d,th . -· ~.di . •• d ~U\ . GUIDELI ES NOTICE CA TION WARNI G NOCJNFO BARRIER/MARKER Access Point(s) ~ [ IJ ,. D [ J D [ J D [] 181 [I] * D
Alpha □ [ J □ [] D I] □ [ J □ [] □
Beta □ r J □ [] □ [] □ [] □ [] D
Gamma D [] □ [] □ [] D [ J D [ J D
OT : The table repre ent either the signage/ba rriers installed/ removed OR items required by the market (if mitigation is not installed by consultant/vendor). • These l{F signs should be posted on the . lccess Gare to rile Site (See drawmg in e,·rion 5 21 S1 Jec1a • lty Si2 l D D e t a1 ·1
Location NIA
Access Point NIA
Alpha NIA
Beta NIA
Gamma NIA
NOTE: The tables abo e represent EXISTI G complinnce items implemented at thjs location.

Notes/ Additional Compliance Requirement (s):

Mitigation i required per the ignage/ Barrier Diagram.

Table 3: litigation Requirements for Compliance

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Pramira Inc · 2552 Walnut Ave .. Suite 200, Tustin, CA 92780 • 800.678.1169 652

5.2 Signage/ Barrier Diagram
A
N
Ground
Utility
Pole
Ground
r:) Pramira
OC and Guidelines Signs need to be
posted at the Access Gate to the site.

Page 16 of 25 ends

Pramira, Inc • 2552 Walnut Ave., Suite 200, Tustin, CA 92780 • 800.678. l I 69 653
f:) Pramira
6 Conclusions and Recommendations:
• The resu lts of the analysi • indicate that power density le ve ls in the generally accessible areas on the Utility Pole level will not exceed the FCC's MPE limit for General Population environments.
• The max theoretical % MPE is 0.83% (FCC General Public) directly in front of the antenna beams at the Utility Pole level.
• OC and Guidelines Signs need to be posted on the Acces Gate to the ite. • This site will be operating in general compliance with FCC OET Bul letin 65 and Dish Wireless 's signage policy as the mitigation requirements outlined in the Executive ummary are implemented. See ignage/Barrier Diagram section for further details on the recommended signage placement locations.
ions to the sile,· and1or increases in channel count · or power levels exceeding those listed in this tire additional emluation 10 determine com liance.

Page 17 of 25 ends

Pramira, fnc • 2552 Walnut Ave., Suite 200, Tustin, CA 92780 • 800.678.1169 654
(:)Pran:ira
7 Appendix A: FCC Compliance and RF Safety Policies
In August of 1997, the FCC published OET Bulletin 65 Edition 97-0 I to regulate methods for evaluating compliance with FCC guidelines for human exposure to radio frequency (RF) electromagnetic fields. The FCC guidel ines for human exposure to RF electromagnetic fields incorporate two categories of limits; namely "Controlled" (a.k.a. Occupational) and " ncontrolled" (a.k.a. General Public). The guidelines offer suggested methods for evaluating fixed RF transmitters to ensure that the controlled and uncontrolled limits deemed safe by the FC for human exposure are not exceeded.

OET Bulletin 65 recommended guidelines are intended to allow an applicant to 'make a reasonably quick determination as to whether a proposed facility is in compliance with the limits:' In addition, the guidelines offer alternate supplementary considerations and procedures such as field measurements and more detailed analysis that should be used for multiple emitter situations.
hese guidelines define RF as emissions in the frequency range of 300 kl [z to I 00 GHz.

The FCC define Maximum Penni sible xposure (MP -) limit within thi frequency range based on limits recommended by the ational Council on Rad iation Protection and Measurement, the Institute of Electrical and Electronics Engineers (IEEE), and by th American ational Standards Institute (A Sl).

As sho" n in Table I of Appendix A, the averaging time for Occupational/Controlled exposures is 6 minutes, while the averaging time for general population/uncontrolled exposures is 30 minutes.

As an illustration of the application of time-averaging to Occupational/ ontrolled exposure consider the following.

The relevant interval for tim -averaging for Occupational/Controlled exposures is six minutes. This means, for example, that during any given six-minute period a worker could be exposed to two times the applicable power density limit for three minutes as long as he or she were not exposed at all for the preced ing or following three minutes. Similarly. a worker could be exposed at three times the limit for two minutes as long as no exposure occurs during the preceding or subs quent four minutes, and so fo1th.

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Pramira, Inc · 2552 Walnut Ave., Suite 200, Tustin, CA 92780 • 800.678.1169 655
':) ~ramira
The specific MPE limits defined by the FCC are as follows:

Frequency
Range [MHz]

0.3- 3.0

3.0- 30
30 - 300
300- 1,500
1,500 - 100.000
Frequency
Range [MHz]

0.3 - 3.0

3.0- 30
30- 300
300 - 1,500
1,500 - 100,000
f == frequency
Limits for Occupational/Controlled Exposure
Electric Field Magnetic Field Power Density
Strength (E) [V/m] Strength (H) {Alm] (S) [mW/Cm"2]
614 1.63 100·
1842/f 4.89/f 900/f"2·

61.4 0.163 1
f/300
5 Limits for General Population/Uncontrolled Exposure
Averaging Time IEl"2,
IHl"2 or S [minutes]
6 6
6 6
6 Electric Field Magnetic Field Power Density Averaging Time IE1"2, Strength (E) [V/m] Strength (H) [Alm] (S) [mW/Cm"2] IH1"2 or S [m inutes) 614 1.63 100· 30
642/f 2.19/f 180/f"2' 30

27.5 0.073 0.2 30
f/1500 30
1 30
*Plane-wave equivalent power density
Table 1: The specific MPE limits defined by the FCC
The F states that 'Occupational/ Controlled limits apply in situations in which persons are exposed as a consequence of their employment provided those per ons are fu lly aware of the potential for exposure and can exercise control over their exposure. Limits for Occupational/ Controlled exposure also apply in situations when an individual is transient through a location where Occupational/ Controlled limits apply prov ided he or she is made aware of the potential for expo ure:

For General Population/ ncontrolled limits, the FCC states that 'General Population/ Uncontrolled e 'posures apply in situations in which the general public may be exposed or in \ hich persons that are exposed as a consequence of their employment may not fu lly be aware of the potential for expo ure or cannot exercise control over their exposure:· for purposes of thi analysis, all limits are evaluated against the Power Density limits.

Typical guideline for determin ing whether Occupational/ Controlled limits can be applied include ensuring the environment (such as a rooftop) as limited/contro ll ed acce s via locked doors or physical barrier that are preferably controlled by a landlord that is aware of the situation and can inform anyone going through the locked door of the existence of the RF emission . Such notification/awareness i typica lly accomplished by means of signage on the door. or other acces to the area of concern, as well a 1gnage on or near the antennas. Examples of such signs include the fol lowing:

Page 19 ends

Pramira, Inc • 2552 Walnut A e. uite 200, ustin, CA 92780 • 800.678.1169 656
NOilCE
llWC NITEN
Al!M~llaldl~
O... po11t MAY EXCEED Itta fCC =0-alPllllic=• potllld llldllb ,to, • lnra
nc; ~., ·-....
t.lllheDlllrNOC•t~74
prior ID~ beyond IINI pr:,inl
Sll•~ - --,---
dfSh .....!..
&CAUTION
A
TWANSIIITTNOANTt S)
ltdo~ ... -~ ltila polrfllAY EraEDh FCC
0cn, • • ,,.,...
=~,:
t.111 .. 0illlNOC,tt~J•
p,lciflO--."J'OlldM,-
$1110
dish ...J!...

TIWISlffllNG MTONA('SI
a...tr..-ylloWI~
ttliapoilllacuDhFCC
OcalpdlMI....-.
===rr:
t.llllltOIIIIINOC111~t
p,toflOWOllillg.,...lllillllii'C.
lld> --=--=---- df h .....!..

Standards for when to use ach of the above signs are as fo llows:

No sign required: <100% of Public Limit MPE
Blue Sign, Notice: 100% to <500% of Public Limit MPE
Yellow Sign, Caution: 500% to <5000% of Public Limit MPE Red Sign, Warning: ?:5000% of Public Limit MPE
A/1 lvlPE references are to the FCC Public limits.

No sign required: <20% of Occupational MPE
Blue Sign, Notice: 200/o to < 100% of MPE
Yellow Sign, Caution: 1000/o to <10000/o of MPE
Red Sign, Warning: ?:10000/o of MPE
All i'v!PE references are lo the FCC Occupational limits r:) Pramira

Page 20 ends

Prarnira, Inc • 2552 Walnut A e.. uite 200 Tustin, A 92780 • 800.678.1 I 69 657
8 Appendix B: Overview of RoofMaster® Functions and
Assumptions
f':) Pr_ar,:iira
RoofMa ter® is a RF Compliance software package designed to enable the analysis, assessment and mitigation of communications site with respect to human exposure to radiofrequency electromagnetic fields.

Rao aster® was developed in 2008 by Waterford Consultants to support compliance assessments pe1formed at single and multi-operator wireles locations throughout orth America and has been in service since 2008. Real-world experience in evaluating thousands of base station installations are reflected in the Rooflvlaster® design approach.

This document provides a guide for creating simulation of RF hazard conditions through the characterization of antenna systems and ite features and through F C- pecified computational analysis.

On any structure, one may encounter antennas installed by wireless service providers public safety and other FCC-licensed and unl icensed operators. Siting constraints have resu lted in diverse and complex environments accessible to people performing a variety of activities around these antennas. RoofMaster® supports the characterization of these locations to convey important information regarding RF sources and accessib le areas nece ary to evaluate d1e potential for human exposure to hazardous level of RF energy.

RootMaster® support the depiction of communications sites throLtgh the disp lay of construction drawing or aerial photography image files as well a provid ing line drawing tools. These representation are scalable to enable the modeling of any location.

RoofMaster® utilize a three-dimensional spatial framework consisting of a 1000 x 1000 grid with unlimited e1tical dimensions necessary for the positioning of antennas and modeling of RF conditions at each grid point throughout the spac . Predictive analysi is performed on a study plane at a specified elevation. The sLtbsequent sections of this guide provide the steps necessary to create a site representation and conduct these studies.

RoofMaster® 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 Field , OET Bulletin 65. This guideline utilizes several antenna and operational parameters in calculating the power density contributions from each emitter at specified points throughout the study space. Root aster® enables antenna to be fully defined in site specific aspects as well as through the use of a library of manufacturer data. The parameter include:

Page 21 of 25 ends

Pramira, Cnc • 2552 Walnut Ave., Suite 200, Tustin, CA 92780 • 800.678.1 L69 658
§ Antenna model
Radiation patterns
Aperture length
Gain
Beam-.. idth
§ Antenna radiation center
§ zirnuth
§ Mechanical down-ti It
§ Location
Frequency
§ Power into antenna
In OET-65, the Cylindrical Model is presented as an approach to dete1mine the spatially averaged power density in the near field directly in front of an antenna. In order to implement this model in all directions, RoofMaster® utilizes the antenna manufacturer horizontal pattern data. Additionally. RootMaster® incorporates factors that reduce the power density by the inverse square of horizontal and ve1tical distance beyond the near field region.

Power density is calculated as follows:
( 1
S=
Beamwidth
~11GHI-I) ; ) p1V
2 ltR/1 ,,,-
• S is the spatially averaged power density value
• R is the horizontal distance meters to the study point • h is the aperture length in meters
• Pin is power into the antenna input port in Watts
RoofMaster® Implementation:
• OH is gain offset to study point as specified in manufacturer horizontal pattern • P,n i adju ted by the portion of the antenna apertur in the 0-6 ft vertical study zone • Hr accounts for I /R 2 Far Field roll off which starts at 2 *h • Yr 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)

Page 22 ends

Pramira, Inc· 2552 Walnut Ave., uite 200, Tustin, CA 92780 • 800.678.1169 659
z
R• Hor1 20 1a1 01sunce
VenfQI
Oimnce
• •• . . . ....•....... . . . . ... . . . . ......... ................................ . .... .. I ,~ . .... .
! 0 h -·--·-·····L...-------- -------------_._.;;.;;_
Horizontal Distance,
ot to Scale
(:) Pramira

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Pramira, lnc • 2552 Walnut Ave .. Suite 200, Tustin, CA 92780·800.678. 1169 660
':)Pramira
9 Ref ercnces
FCC (1997). "Evaluating Compliance with FCC Guidelines for Human Exposure to Radiofrequency Electromagnetic Fields"'; Federal Communicati ons Commission: Office of ngineering and Technology, OE Bull ti n 65. Edition 97-0 I, August.

Waterford Consultants, LLC. (2008).

Consu ltants, LLC.

RoofMa ter® User Guide, Waterford

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Pramira, Inc • 2552 Walnut Ave., Suite 200, Tustin, CA 92780 • 800.678.1169 661
':) Pramira
10 Limited Warranty
Pramira Inc. warrants that this ana lysis was performed in good faith using the methodologies and a ·umplions covered in th is repo1t and that data used for the analysis and report were obtained by Pramira Inc. employees or representatives via site surveys or research of Dish Wire less ·s available information. In the event that specific third-party details were not ava ila ble, best efforts wer made to use assumptions that are based on industry exp rience of various carriers' standards without violating any confidential information obtained under non-disclosure terms.

Pramira, Inc . also \; arrants that this analysis was pe1formed in accordance with industry acceptable tandards and methods.

There are no other warranties, express or implied, including but not limited to, the imp lied warranties of merchantability and fitness for a pa1ticular purpose, re lating to this agreement or to the services rendered by Pramira hereunder. In no event shall Pramira be held liable to Dish Wire less, or to any third party, for any ind irect, spec ial, incidental or consequential damages, including but not limited to loss of profits, los of data, loss of good wi ll , and increased expens s. Ln no event ha ll Pramira be liable to Dish Wireless for damages, whether based in contract, tort. negligence, strict liabi lity or otherwise, exceeding the amount payable hereunder for the services giving rise to such liabil ity.

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Pramira, Inc • 2552 Walnut Ave., Suite 200, Tustin, CA 92780 • 800.678.1169 662

EXHIBITE
663
1118/23, 12:33 PM Vintage Skynet: AT&T's Abandoned "Long Lines" Microwave Tower Network- 99% Invisible

ARTICLE BY KURT KOHLSTEDT
Vintage Sl<ynet: AT&T's Abandoned "Long
Lines" Microwave Tower Networl<
MI Infrastructure 110.20.17
B etween early wired networks and today's fiber optics sat a system of microwave relay towers transmitting information from coast to coast across the United https://99percent1nvisible.org/article/vintage-skynet-at s-abandoned-tong-lines-microwave-tower-network/ 1/11 664
11/8/23, 12:33 PM Vintage Skynet: AT&T's Abandoned "Long Lines" Microwave Tower Network- 99% Invisible States. Built in the early 1950s, this line-of-sight network spanned the continent using :zig~zc;ig patterns to avoid signal overlap. It conveyed phone conversations and television signals from thE era of the Kennedy assassination through the resignation of Nixon. ... i ,.,,.. ... , .. -
.. ,,_. ;· . ~ ,,_k· ~ .. ....__...._....J.. ... - .... J -,
\, ,.,--, .... j '\
\
~M,•
~4)\l)j(t '-fUJi S"tsrtMS.
1960s map of AT&T nationwide microwave tower relay network (click to enlarge) The towers were generally spaced 30 to 40 miles apart and can be hunted using old official charts or this unofficial Google Map It was the largest network of its kind when it opened, and unique in relying on microwaves rather than transmission wires. https://99percentinvisible.org/article/vintage-skynet-atts-abandoned-long-lines-microwave-tower-network/ 2/10 665
11/8/23, 12:33 PM Vintage Skynet: AT & T's Aba doned "Long Lines" Microwave Tower Ne two - 99% Invisible A few years back, photographer Spencer Harding got interested in the history of these towers and ra ised funds to shoot and publish a book about themThe Long Lines collects dozens of Californian towers from six weeks on the road spent documenting them (excerpts above). h tps://99percentinvisible.org/article/vintage-skynet-atts-abandoned-lo g-lines-microwave-tower-network/ 3/11 666
11/8/23, 12:33 PM Vintage Skynet: AT&T's Abandoned "Long Lines" Microwave Tower Network • 99% Invisible ht ps://99percentinvisible.org/article/vintage-skynet-atts-abandoned-long-lines-microwave-tower-network/ 4/10 667
11/8/23. 12:33 PM Vintage S ynet· AT& T's Abandoned "Long Lines· Microwave Tower Network - 99% Invisible Qwest Building in Minneapolis, Minnesota topped with microwave tower array Today, many of the towers are in disrepair or have been taken down entirely, but some are built into the very design of urban architecture. Others can be easy to miss among HVAC outcroppings, cell towers and other antennas but are possible to spot if you know what you're looking for. In the countryside, old towers are often found adjacent to concrete bunkers (some are even occasionally for sale). At times, you can even catch a glimpse them itate night show backgrounds.

Copy of Long Lines sites ,n U.S
Tn , m~p ~1a; r;iade w th Ge.ogle 1,1,. Maos Create your own.

Map data ©2023 Imagery ©2023 Terms 2,000 mi
The microwave relay system was part of thl:AT&T Long Lines network, which included wire and cable connections. 99pi fan and Long Lines aficionado Corey Carlson explains that "the Long Lines network relayed analog data from one horn to another, with polarization of radio waves to expand the signal capacity." Their "SUV-sized 'horn' antennas" were designed to focus radio signals out horizontally toward other towers and be durable, "resistant to the pressure wave from a nuclear blast."
https: //99perccntinvis ib le. org/article/vint a ge-skynet-atts-a band oned-long-lines-m1crowave-tower -network/ 5/1 668
Vintage Skynet: AT&T's Abandoned "Long Lines" Microwave ower Network - 99% Invisible -- - ------ "
Microwave relay towers in beautiful downtown Oakland, California, image by Kurt Ko Obsolete in today's world of fiber optics, satellites and wire less internet, many of the towers have been taken down or swa pped out for cellular use. Some, however, serve as emergency backups in rural areas. And others, it would seem, are so built into the aesthetic of their associated buildings that owners have seen no reason to remove them .

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. ~ EP I SOD E 97 . • i,
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- N umbers Stations L. \.
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For those looking t o learn more about this tech nology, there's a wealth of information on these systems - includ ing images, maps, diagrams, magazine and newspaper cl ippings - to be founc on Long-Lines.net.
ht ps://99percentinvisible.org/article/vintage-skynet-atts-abandoned-long-lines-microwave-tower-network/ 6/1 0 669
11/8/23, 12:33 PM Vintage Skynet: AT&TsAbandoned "Long Lines" Microwave Tower Network • 99% Invisible Microwave relay towers around 16th and Franklin as seen from Frank Ogawa Plaza, image by Kurt Kohlstedt Enjoy 99pi?
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EXHIBITE.2
674
The Microwave Radio and Coaxial Cable Networks
of the Bell System
Telephone Men on a coaxial-cable project in w York tate, ca . 1970 Contents
• Places and Routes
• TechnologY. and E~u1p_m_rnt
• .Operations
• Documents
• Sources of iofoOJJatioo
• Link
• Organizati n , Mu eums. and Archives
• E-mail Lists
• Site Hi. tO[Y.

Upcoming Events
• one currently - please let me know of any!
nnouncernent of updates to this site (and lots more interesting information and di cu ions) will be posted on the old War ommunications e-mai l li t. To join, or to learn more about the list, go to the Cold War 0111111s web !kg~.

If you have information about the Bell System's n tworks you'd like to share, or ha e any questions about the material posted here, l look forward to hearin° from you. I'd also welcome your comments about the implementation of this web site.

Last updated on A pri I 11 , 20 13 at 2 1 :31 by lbert LaFrance 675
EXHIBIT E.3
676
AT&T Long Lines Technology and Equipment
Switching
• No 5 Crossbar (a collection of article from the Bell Laboratories Record,1949-195 l • courtesy of Sam Etler)
• "The Evolution of Telephone Switching~ (article from the Bell laboratories Record, June 1965) • Western Electric No. 4 Eiectronjc Switchfog..SY.stem
introduced in 1976 and still the foundation ofAT&T's switching network • Tugramming the Number 101 ESS" (article from the Bell Laborafories Record, Apr. i965) • "The 304 Conference Swjtching..Sxsrem" (article from the Bell Laboratories Record, Jan. l965) • ''Th~ Cros bar Switch" (article from the Bell Laboratories Record, July 1937) • A ew 11 B" Board for Panel Offices (article from the Bell Laboratories Record, December 1930) Analog Frequency Division Multiplexing
• Multiplex hjerarchy~gram
Frequency Control
• The Bell Sxstem Pamary~quen Y. Standard
advertisementfrom 1952
Microwave Radio
General Information
• "The TD2 Story" a three-part article from the Bell Laboratories Record:
o Part 1 - "From Resear h to f ield Trial" (October 1967) o Part 2 - "Vacuum Tubes and System .. Eng~g~ ( ovemb r 1967) o Part 3 -.:.changing for the Future" (D cember 1967)
• "TD2: Eighteen Years And Still Growing~, from the Bell Laboratories Record, July-Augu t 1968 • Booklet "Radio Re!av: Commun ications by Microwave"
Thanks to Al Haj11y, P. E.forproviding these scanned images. • "Microwaves for Relaying TV Programs"
From the November 1948 issue o_f "Radio and Television News " • "The Microwave Era Begifil'.'..

From the October 1950 issue of"Radio and Televi ion News" Transmitter-Receivers
• TD-2 Microwave Radio Tran mitter-Receiver Bax Descnption Bell System Practice 410-410-100, Issue l, March 1975
• List of microwav ~ radios used in the Bell SY.stem
.from Bell System Practice 0 10-150-002, April 1968
• TD-2 radio bay, showing...!fill.jor compon nts
From: "TD-2 Radio Channel Maintenance", OJT 57, 1. sue I, June 1971, AT&T Long lines, p. 16 • TD-2 radios bays undergQIDg facto~')'.'. checkout
Advertisement, circa 1953-1954
677
• D-? vacuum-tube transmit amplifier
From: "TD-2 Radio Channel Maintenance", OJT 57, Issue I, June 1971, AT&T long Lines, p. 1 4 • "Mier electronics R place Vacuum uhes in the Micro1v ave Network" .from the Bell Laboratories Record, Febmary 1983
Data Transmission
• "The lA Radio Digilill..S:ctem Makes 'Data Under Vojce' A Reality..'.:
from the Bell Laboratories Record, December 1973
• "I A Radio Digital T rmin, ls Put 'Data Under Voice"' fi·om the Bell Laboratories Record, Mav 1974 . ,
Alarm and Control
• Adverti ement for alarm nnd control sy tem, from I 952 • C-1 Alarm SY.stem indicator P.anel lnmr. assignments illustration from a Bell System Practice Antenna Systems
Delay Lens Antennas
• The K -5r9 DelaY. Lens Antenna: De crjpJ.iQ.n
• Bell Telephone aboratories drawing E -877600, "TD 2 Radio KS-5759 L 1 Delay Lens Antenna Assembly" (sheet 1 of 2 heets) Location: TOI
• Bell Telephone Laboratories drawing S-882975, "TD 2 Radio KS-5759 LI Delay Lens Anlenna Bracing A mbly" (2 heets) Location: TOI
• We tern Electric drawing ED-63953-70, "Toll Systems I TD-2 Radio / Waveguide lri for KS-5759 Antenna" Location: TOI
Horn-Reflector Antennas
• The KS-15676 Hom-Reflector Antenna: De crip..ll.Q.U
• "Broadband Hom Reflector Antenna" (article from the Bell Laboratories Record, Nov. 1955) • Drawjng..Q..l.Qri)nal hom-re0ector concept for U.S. P.atent am:iiication Systems Combining etworks
• "A Mtcrowave System CombITTing etwork" (from the arch 1963 Bell laboratories Record) Waveguide
• Western Electric Waveg ud~ Products brochure (December 1967) Towers
• Mark Fo. ter's AT&T tower (lilg~
Lists AT&T's tower type designations, with example photographs • Western Electiic IxRe "E" tower brochure ( ovember 1967). • We t m Ele hi Mi ro1vvave Tower Services brochure (MaKh 1963). • The oncrete microwave tm ers
• TV Towers Sprout from Sliding Form (from Popular Science magazine, June 1950) 678
Coaxial Cable
• "Stevens Point and Minneapolis Linked by Coaxial Sy -tern" article from the Bell Laboratories Record, January 1942 • 20-tube coaxial cable description
• 20-tube coaxial cable diag@m, bowing order-wire a ignments • Cross-section image of 20-tube coaxial cable
• Advertisement: 4000-Mile Trench
• Photo of coax1al-cabl sP-li£ing training, from I 970s • Close-uR photo of coaxial-cables~
• "New York - Chicago L3 System"
article from the Bell Laboratorie Record, May 1954
• Bell Laboratories Record,1.u.ly.LA.ugust 1967
entire issue devoted to the L4 coaxial system
Alarm, Control, Te ting and ~lonitoring
The L4 Remote Control Center
• PhoLo I
• PhoLo 2
Maintenance Repairs and Emergency Restoration
• Richmond. YA "Flyiog~llill.L
• Photo of submarine coaxial cable renair, from 1973
• AT&T Job Aid 26, "Basic Coaxial Cable Maintenance", Issue 1, 1989 (onjrle) • Restoration after bombings of microwave and cable stations i o Utah and Nevada in 1961 (by David Massey)
Communications Satellites
• Booklet "The Telstar Experiment: The Bell System' Role in Communications Satellite Development" [copy on.file]
• _ngular Calibration ing Celestial Radio ources" (from the January 1965 Bell Laboratories Record) The Testboard
• A Private Line Testboard
• The Switched Access Remote Test Sxstcm ,s RTS)
• Carrier Transmission Maintenance System 1CIMS)J.QgQ.

The Power Room
• Gould PAT/PCT Data Sheet
describe a typical " ubmarine cell" u ed in Long Lines station batteries Wire-Pair (non-coaxial) Carrier Systems
• Ad\·ertjsement for open-wire carrier SY.film!, from 1952 679
• P- of K-carrier route in P onsylvania. from 1937
• ~g de5cription ofC-carrieuquiR™1. from 12-+S
• J-Caujer twelve one-way voice circuits multiplexed on a single open-wire pair Local Loop (Exchange) Plant
• "Dedicated Outsjdt; Plant" (from the January 1965 Bell laboratories Record) Related Technologies
• Teletypewritct:S - by Vaux Electronics
Teletypewriters were used in Lbe Bell System both for internal communications and for text communications services offered to subscribers, and for many years AT&T owned the Teletype Corporation, a major manufacturer of th is equipment.

Support Systems
• Electric incinerating oilet - used at many tations in i olated area . • Rack for storing.spare fluorescent lamp~ - everything had its place in the Bell ystem. • Bell Sxstem waterless hand cleaner - for hard-working Telephone hands. • Bell System floor finish - helping AT&T keep tho e floors looking great.

Mobile Communications
• "Telephones Aboard the 'MetroHner'" from the Bell Laboratories R cord, March 1969 The Picturephone
• Bell Laboratones RerorJ Pi n..1reP.hone issue, May-June 1969 Adobe PDF file, 8.9 MB Courtesy of David Massey
Return
Updated oil April 15, 2014 at 08:47 by Albert Lafrance
680
EXHIBIT E.4
681
AT&T Long Lines Places and Routes
Maps, Diagrams and Lists
• ew· York-Boston Radio Re laY. lnaug~ - article from The Telephone News, February 1948 • Route maP- from 1898 (Thanks to Keith Cheshire.for contributing this link) • Ne\v Plan for Designation of Radio Repeater and Tem1ina) Stations -from June 1960 - explains how station nal'nes were assigned
• Stations in Iowa, Il linois, Indiana, Michigan, 1inne ota, New York, Ohio, Pennsylvan ia, and Wisconsin (compiled by Al Hajny, PE.)
o Lis..ting_bY. state (468KB)
o 1.i.:iling..by FCC cnllsigu (517KB)
• AT &T's First Transcontinental Microwave Radio Route
o Teleg./1011e Sky11·a,• brochure (2.3 B PDF file)
o "34 Jumps to ChicagQ'.'.. from the Sep. 1949 Long Lines magazine o Li. t of stations
o Artide from Radio & Television Ne1 ,,5. Nov, l9S l
o Artjcle from Vie C&P "V,ansmirter". No ,-Dec . L95 I
o Pages from l 952 Bell Telephone Almanac:
• Cover showing two type of microwave tower
• ''Electronic Ponx ExP-re s" ■ Mention of planned Pittsburgh-SL. Louis route (one sentence) ■ Muhi P- le it m
• Rebus I1l.lZZk
• icrowave rout between Blue Ridge Sllmrnir N . 2 . ..£6...(Sit R) and Washington o 4. YA.I Mount v aLher .
• AT&T's first fiber-optic cable route - between Cambridge, A to Washington, DC; placed in erv1ce 1983/84
• Long Lines routes in the WashjngtQn. DC area. Jan. 1970 (267KB) • Richmond-Greensboro "C" Cable route map_{partial) L3 coa ial cable between Lombardy Grove and Virgi lina, VA
• Long Lines routes in the Philadelr.hia, PA area, Jan. 1970 (288KB) • Long Lines routes in Virginia (and adjoining areas), Jan. 1970 (344KB) • !&.J)g Lines routes in Georgia (ancladjoining areas), Jan. I 976 (260KB) • LillJg Lins:s route map.J.L.S... 1952
• Microwave route map. U.S. and Canada. March 1960 (2 .1 MB) • Microwave route map , . . and anada , October 1966
o Eastern Section small (722 KB)
• fnsct 2 - ew York City.Eg!Qll
• ln et 1 - Washingl.Qn, DC region
• lnset 4 - CT
• Detailed Extract l
Approximate boundaries:
• Center: Clarksville, NY
• W corner: N 011h Bay, Ont.
■ E corner: Grove, ME
■ SW corner: Malaga, OH
■ SE comer: Cape May, J
o Central ection. mall (6 1 KB)
• D tailed Extract l : Minnesota, Wjsconsin and surrounding area (incl. ChicagQ. Des Moines. and Omaha).
o Western Section . ..!illlil.ll (604 KB)
682
• Detail d Extract l : Colorado, Wyoming
• lw L-Cacrier System (by Mark Foster)
• New York and New England Tower Listji-om 1982, a list of AT&T 1owers and their complemellfs of antennas
• 1983 High Frequency Line Schedule - C&P Telephone area 0 )2...J_
0 p......2.
0 µ
0 p_,__1
• 1983 High Frequency Line Schedule - Pennsylvania and Delaware 0 )2...J_
0 p......2.
0 p_.__1
o u 0 p~
• I 982 High Frequency Lin chedule - Pennsylvania and Delaware 0 p.......l
• TD,, Radio Route DiagrnJIL.Sycamore, PA - Cbenyville, NJ dated 1-29-81 • includes Fairchance, alisbury, Chaney ville, McConnellsburg, Ca btown, Hanover, Frey ville, Cornwall, Centerport, and Lanark, PA
• List of coaxial-cable routes, Washington e uipment engmeenng area.~y_JJ, 1972 • List of Omaha District 'L" Cables. Jan. 1977
Facilities by State
Note: AT&T Corporal Security has reque ted that the names and exact locations of acti ve AT&T network facilities not be published. Accordingly, such facilities are identified on this web site by fictitious names, shown in [brackets], or by Co1nmon Language Location Identifier (CLLI) codes.

Arizona
• Apache Junction
• Kingman L-31 station on ':first blast-resi tant coast-to-coast underground communications cable system" (by Chad Perkins)
• rncle
• Phoenix "Main''
• Seligman L-3I station on "first blast-resistant coast-to-coast underground communications cable system" (by Chad Perkins)
• fugstaff L-31 station 011 ''fir t bla t-resistant coast-to-coast underground communications cable system" (by Chad Perkins)
• flag~ (downtown).
• Holbrook L-31 station on "first blast-resistant coast-to-coast 11nde1grou11d communications cable j)'Stem" (by Chad Perkins)
Arkansas
• Al exander - integrated building-tower station on the TD-3 field trial route • Palmer - integrated building-tower station on the TD-3 field trial route • West Helena - integrated building-tower station on the TD-3 field trial route California
683
• AT&T Long Lines M_jc ro,vave Sites jn California (Multiple locations) • ~ - a hardened underground cable and microwa e station (by Michael W. Jacobs) • Bernal Heigb.ts
• BIY.the L-1.Ll, Radio (by Chad Perkins)
• Corona (by Mark Foster)
• EasLB.ay Hills
• Kelso Ps:ak
• I oma Prieta
• Los ngek (Pacific Bell)
• Los Angeles Grande complex (by Mark Foster)
• Mount Vaca
• .Mi)jave (by Daryl Gibson)
• Oak Hill
• Oat Mountain
• Point rena (Manchester). - terminal station for undersea cables to Hawaii • Sacramento - AT& Long Line and Pacific Bell
• San Luis Obispo Junction (by Mark Foster)
• Santa Rosa - Pacific Bell
• Strawbmy Peak (by Mark oster)
• Toilil.D ga..Rll:! g~
• Turguoise
• -filP-en Ri g~
Colorado
Route Maps
• Long Line routes i.n Colorado (~j2.i.ning~) Jan. l 976 (240 KB) Locations
• Atwood tation on. the.first transcontinental microwave route • Buckhorn Mountain station on the first transcontinental microwave route • ". Blast-Resi rant Communi ations Network" - Cheyenne Mountain Comp~ (from the Oct. 1965 Bell laboratories Record).
• Cortez Mou11tain Bell/Long Lines
• Julesburg station on the first tra11sconti11 e11tal microwave route • Peetz station on the first transco11ti11enta/ microwave route • £1:ruiP-ecl ValleY. station on the.first transcontinental microwave route Connecticut
• Bald Hill near Stafford Springs - a relay station on AT&T' first microwave route, which began operation in 1947
• Cheshire undergtvwid main station
• Durhnm
• John Tom Hill near Gla.stonbwy- also a relay station 011 AT&T' fit'. I microwave route • l-Y~
Delaware
• ~P- ater hut north of Wilmington
684
District of Columbia
Florida
• Pennsuco (o erseas and high-sea HF radio, microwave) - by ark Foster Georgia
• Rockdale CCony:ers) Facility 1aintenance Center and former Regional enter (by Will Cardwell) • Dahlonega
o Dahlonega_
o Dahlonega 2 (by Chtis Ness)
Illinois
Locations
• Chadwick
• ChamP-aigu
• c..hill! gQJ::.ki gh ts
• Chi.c..a,,,o No.
• Sb.ir.-to-shore station WAY, ChicagQ (operated by Illinois Bell, providing communications for Lake Michigan shipping)
• Cisc
• Clo erdale
• DeKalb
• DL on
• Eola
• lizabeth
• Hanover CS (satellite earih station)
• Hanover R
• Lake Zmich
• ue
• Monroe Center
• Morris (K-carrier repeater Ottawa KIE)
• NRWYJLNO (C I code for active facility)
• Odell No. I
• Plano
• Plato Center
• Beach (K-caoier repeater)
• k
•
Radio Routes
• Hanover CS, IL - Lee,.11
Cable Routes
685
• Plano.J.L..:...Ly:ons, NE Cable
Indiana
• Mishawaka
• Morgantown by Michael W. Jacobs)
• Orleans (by Harold Peach)
• South Bend
• Vala,P-raiso
Iowa
Locations
• cl::iir
• Boone (underground main station and A TOYO switch)
• llin.
• lk Hom
Kansas
Locations
• Concordia
• Fairvjew (by Mark Fo ter)
• llin1
• L ui.·burg
Cable Routes
• airview. KS - Offutt AFB. NE Cable
Louisiana
• New Orleans - ho'v'ving installation of a KS-15676 horn-reflector antenna in J 974 Maine
Route Maps
• l&ng Lin s route> i11 Maine (and adjoining~), Jan. 1979 (122KB) Locations
686
• Andover -America's.first commercial communication satellite earth statfon o Ftrst Transatlantic Transmission of a Television Signal via Satellite. 1962 by the IEEE History Center
a ceremony commemorating the 40th anniversa,y of the event was lleld OJI July 1 I, 2002 o lark Foster' . ndover Jlli8~
Maryland
• Clarksvilk
• FLKNMDFK (CLLI code/or acr;vefacility)
• Gem1anto, n
• HGTWMDQQQJ.Q (CLLJ code for active facility)
• lambs Knoll (und r construction)
• Lewistown
• [MD-1 ) (fictitious name for active facility)
• North Barnab:x:
• RandaIIstown
• Thunnont <passive microwave re~).
• Wa ldorf Blue Ridge Surnmj {the; Alternate Nationa l Military Command C nter) (by Michael W. Jacobs) • Yellow SpriDg~
Massachusetts
Routes
• Talk lo Boston! -from the Ap1il 1924 i sue of Long Lines magazine, on the 40th anniver ary of the first Boston- ew York telephone line
Locations
• P~ru
Michigan
Route Maps
• Long Lines routes in Detroit area. Jan. 1970 ( 11 5 KB) Locations
• Dans ti le
• Milford (includes adjacent stations: Atlas Detroit, Dansville, Pontiac CO, and Southfield) • Plxmoucb Junction
• Pontiac
Minnesota
Locations
• Minneapolis Downrown
687
Routes
• "Stev >n Point < nd Minneapolis Linked by Coaxial Sy..::.1....!.... article from the January 1942 issue of the Bell Laboratories Record Mississippi
•
Missouri
• Q.@Y. umm1 t
• Ht!nnann
• Hill born
• L plin
• Kansas City_
l\llontana
Route Maps
• Long Lines routes in Montana (illl.d..a.djill!llllg~). Jan. 127 1 (368 KB) Locations
• Mac Pass Radio, LLC (M11ltiple locations)
• Brad Cobo's Montana AT&T stat10n p~ (Multiple locations) ebraska
Locations
• ha P-R!tll
• LY.om, - a hardened mah, station and "Combat Ciders" Ground EntTy Point • t. LibofY.

Cable Route
• 1Y.ons. NE - North Bend. NE "A" Cable
• Fairyiew. KS - O[utt AFB. NE Cable
• Plan(), TL - Ly ~ abl~
Nevada
• ose highest elevation on AT&T's.fir t transcontinental microwave route • er
New Jersey
688
• Bedminster AT&T's Nariollal Netv.•ork Operations Center • Cedarbrook (by Mi chael W. Jacob )
• Q!Lrryvillc
• Holmdel Bell l aboratories transmission research.facility • illlin
• Lawrenceville Former overseas transmitting station
• Manahawkin Former overseas and high-seas shortwave receiving station, and Bermuda undersea cable terminal
• Murray Hill Bell Telephone Laboralories location
• Ocean Gate Former overseas and high-seas shortwave transmitting station • Cherryvill e (by Michael W. Jacobs)
• Quinton
• Stockton
New Mexico
• _rgan
New York
Routes
• Talk to Boston! - from the Ap,il 1924 issue of Long lines magazine, on the 40th anniversary of the fir t Bo lon-New York telephone line
Locations
• Ainnon - a hardened underground cable and microwave station (by Michael W Jacobs) • Attica - a hardened unde1ground cable and microwave station (by Michael T1V. Jacobs) • .chilly...YalkY.
• Clarksville - a hardened underground cable and microwave station (by Michael W Jacob ) • Farnham (by Michael W Jacobs)
• Jackie Jones Mountain - a station on AT& T's first microwave route • W a k
• Putnam ValleY. (by Michael W Jacobs)
• TnllY. - a hardened underground cable and microwave station (by Michael W Jacobs) • ~ - an early rectangular concrete toiver
North Carolina
• Gibsonv1 lie (underground l 4 po1-ver-feed station)
• Stanfield (hardened underground main station)
o Stanfield (by Dexter Afclntyre)
o Bell Laboratories Record article about the L-4 coaxial-cable svst m, and a constrnct1on P-hoto of Stanfield
• Chatham (hardened troposcatter "Proj ect 0/jzce ")
Ohio
Route Maps
• Long Lines routes in Ohio (and adJoining areas). Jan. l 970 (278 KB) 689
Locations
• Bluffton - underground coaxial-cable main station
• a tatia
• atc wbu
• Cleveland (by David Lesher)
• Lorain
• Medina - underground coaxial•cable main station (by David Lesher) • .s,m.o gQQIQ
• _gringfi Id
• wanton
• White Oak
• Xenia - a hardened u11de1grou11d able station (by Michael W Jacobs) Oklahoma
• llil.i.SY.
• Mounds - former AUTOVO switch
• Noble
• Oklahoma City
• Sentinel
Oregon
Locations
• Day..Y.ill.e. Hoodoo Butte, Long~, MauQin (by Rich Williamson) • John Day .P-assive rep~
• King Mountain
• Portland
Route Maps
• .bQ.!Jg Lines routes io OregQil.Jand adjoining~). Jan I 976 (252KB) Pennsylvania
Locations
• BaileyviJJe (by ichael W. Jacobs)
• Buckingham
• 1kn:y..s.b.!J.rg - Restoration Plot Plan
• Casbtown (by Brady Alleman)
• Clark'. Knob - Restoration Plot Plan
• Ikall (by Michael W. Jacob )
• Dillsburg
• lderton (by Michael W. Jacobs)
• Finland
o Web p~g!Llzy Michael W. Jacobs 0 lliaft press release. from I 969 o Fact ;heet
0 Shock-mounted al rm r.anel
690
0 Nuclear bla;;,t detector control box (.s.pare unit) - exterior o Nuclear blast detector control box (:;pare unit) - interior o Portion of architectural PMP-lan
• Hallam
o Hallam (by Michael W. Jacobs)
0 Restoration Plot Piao
• Harrow
• ~Y. Communications satellite earth station
• Jennerstown (by Michael W. Jacobs)
• Johnstown
• Laurelton (by Michael W. Jacobs)
• Lilly.::yille (by Michael W. Jacobs)
• Lionvilk
• L,Qgan (by Michael W. Jacobs)
• LY.nTIP.Ort
• McConnellsburg (by Brady Alleman)
• New Holland - Restoration Plot Plan
• e_ottstown - an early underground main station
• idelina Hill
• Swjssdale (by Michael W. Jacob )
• Thomas Hill - Restoration Plot Plan
• Unionville
• Waggoners GaP- (by Michael W. Jacobs)
• _xndmoor
Route Maps
• Pittsburgh - New Castle K-carrier cable route ( l 937) Rhode Island
Route Maps
Tennessee
• Tennessee Valle)'. TelWeb (multiple sites - by atthew Sadler, K.F4LHP) • Cutleoka (by Middle Tenne see Two-Way)
Texas
Route Maps
• Multiple roule maps. (also Western nion and MCI maps) Locations
691
• e (Belk vi \\'
•
•
• nd
Utah
• Path Pre ervation (multiple sites - by Daryl Gibson)
• Ceda • Mountain
• Kno lls
• Stansbury Island
Virginia
Locations
• ld1c
• ARTNVACKT20 (CLLI for active facility)
• 6Yl...il
• Buckingham -formerly Ct hardened troposcatter relay station in a national-security network (External link - updated May 1 J, 2002)
• [VA-6] (fictitious name for active facility; formerly a hardened troposcatter relay station in a nar.ionalsecuril) 11 en,1ork) ( xtemal link - created Aug. 27, 2005)
• (VA-2] (fictitious name for active facility)
• E.dge..Hill
• Flint Hill (under con trnction)
• Garden City - includes photos of ham a11te1111as being removed from tower • Hamilton
• lli!ynwrk t
• Le~ ·burg_
• [VA- I] (fictitious name for active facility)
(External link - created May 9, 2004)
• Linden
• Middletown
• Nokesvi le
• Oak Grove
• Qmns
• Oakton - Long Line Ea tern Region Headquarters
Cable Routes
• marker_ - Mount Weather to Winchester.~~-
• reP.eaters - Mount W ather to Winchester ......... .....,.=aa Washington
Route Maps
• 1,Qng Lin s routes in Washin,qton (and adj.o.inin~). Jan. 1976 (262KB) 692
A1·ticles
• Articl\! about Washington microwave nute
Microwave and Cable Stations
• Enumclaw (by Casey Halverson)
• Moses Lake
• akima
West Virginia
• Kates Ytountain The AT&T micro-..vave network interface.for the Greenbrier congressional relocation facility
• Laurel Mountain
Wisconsin
• Eden central office
• Eden K K-carrier auxilimy . talion
• Palmyra Showing the installation ofhom-rejlector antennas in 1956 • PrOSJ::!eCl a cylindrical concrete tower
Route
• "Stevens Point and Mion,,apolis Linked by Coaxial System" a1ticle from the January 1942 i su of the Bell Laboratories Record Wyoming
Route Maps
• Long Lines routes in Wx.runingJ~.cinm~• Jan 1976 (246 KB) International Communications
Japan - undersea cable
Comic-strip-style advertisement for the U.S. - Japan undersea cable from the June 1965 issu of Boys' Life magazine. (PDF file 9 MB)
Thanks to Steve Cichorsky for contributing this item
Return to ...
• Long Lines main p~g~
Updated on April 11, 2013 at 2 1 :3 1 by Albert Lafrance 693
EXHIBIT E.5
694
A,,,. LONG LINES MICROWAV O ERS AND SIT S

IN CALIFORNIA
M,crowa 1e radio ',Siem:; \\,ere first introduced by t11e AT&T Long L·nes O-apartment or the teleco111,qun1cati1 ,nc: 11 i:1u t')' in tha 1 ~;50 . , s long distance traffic arid ne work reilab1rt)' grew microvrwe tmver·s w re een sprouting up on rPmote rnoui 1ta111 tops oos-n fields and central city d stncts, Short towers were used on sites Wtre topograph1 had hi: adva•1tage si.Kh a~ a rnou11 ain r dge 01 hill I 11i:::. The ial!er towers. s rn~ rea::;r11r1g 300 feet into the ..:il<-y were usually located on flal terrain sue as tne desert valleys or endl :s s plains of 1he Midwest state:. Trapezoidal "horns' were initially used and later high;3r capaclty "corrnicopia'' horns supi::le -nented th~ rapRza s.

California hac a strong "backbone'' c,f tl1 1s rrnc:rowave system v.-hict, conne,Jted the ~. ate to neighboring cities and !hs rest of the nation. The m1cro1
-haves would carry both tel~phone, tele1,;is,on and ltrn1 ed data •raffle streams. ,t,e microwavs network also played a vital role dunng he "Cold War' for ooth secure a11d l risecured military cornrnu111cat1011s.

There were basically two types of m1cruwave sites, junction (swit:hed) and repeater (relay).

Ju11ction/switd1ed s le-::, were 1:.irger ometimes manned. whirh provided switchtnD of m1crowav'? ignals from one pa'.h to anct 11er. Signals could b- rerouted to various p.atl1s or underground C-"lbles depend119 on tr<:ittic l·J3d, bandwidtt1 2. nd location. E:.nd po1n s o these r1 crowa'.e paths were usi.1all, located a~ 21 toll office or tandem : antral office 1n the ma·or cities Repeater sites were 1n a sen~;e relays that provided a point t8 allow ampl1ficafr:i11 of the signal and a "Jump" to tre next tower or site. These sites were usually placsd to reoirsct (not reroute) signals around obstructions (hills mountains) or on long routes.

With the invention and in~tallation of higher capacity fiber optic lines in he 1970s microwave use slowly dwindled to serving as 2 back up syst~m, or serving telecommunications in remote areas where fiber optic installation was cost prohibitive. By the mid 1990's though, microwave tran~miss1011 had all but been reti1ed permanently. The towers that stood the test of time were lured down for good, tne1r site being sold to wireless telecommunication companies or even private parties. Horns and equipment have saaly been removed from numerous sites The towers now stand bare but proviJe the height and location now to serve the modern technological revolution of cellular, paging and wireless
SOUTHERN CALIFORNIA MW SITES NORTHERN CALIFORNIA MW SITES CABLE STATIONS:

POINT ARENA
- ' -:;: - - , • I
, - ~-'
- ·_ ~ I ~T& T North Cal. Map 1987
Also Please visit NORTHERN CAUFORNJA MW 1978 A wonderfu collection of vintage sites from old slides
695
Note: Sorry for the crudene s of tne maps. They were taken with c1 digital camera ofi the master. The maps should give a basic idea of routes and locations 1n the Cal fornia region. Symbols are: round dot ls a microwave repeater site and Triangular shapes me Junction or switching po nts The flJzzy l'nes are cable or FO routes.

Thanks to Wayne HaY.eS for the use of these maps.

Back to Telephone Central Offices
696
EXHIBIT E.6
697
AT&T Long Lines
Operations
Switched Network Management
• Network Ianagem~nt of the DOD et work and Dia l dministrntjon an instructional text from the era of cro sbar switches Radio-Frequency Interference Investigation
The Eastern Region of AT&T Long Lines used this ~pec ially~lli.pped motor home to search for "quiet" sites for satellite earth stations and to locate sources of interference to terrestrial microwave transmis ion.

Training
The following lists of courses are from:

Long Lines Operations Catalogue of Training Cour es
Headquarters Operations Training
Cincinnati, Ohio
vlarch 1973
Course materials are not available from this site but individual course description can be po t d upon req ue t.

Contribution of course tex ts and audio-visual materials, in physical or electronic fom1, will be much appreciated.
• Fo1mal courses,_p._l
• Formal courses._p......2,
• Q1I [On-the-Job Training] Course. ,_p...J..
• O.JT Courses._!Ll
• Job Aids
• Booklets
• Standard Plant Training Courses,_pJ
• Standard Plant Training Courses,.)::!. 2
• Standard Plant Training Cou ·ses,_p._l
• Standard Plant Training Courses,_p.....,1
• Standard Plant Training Courses,.P.- 5
• l&ng Lines Enginee ng Training Courses
• l&ng Lines Management Courses
• Long Lines ales Training Courses
• Management Technical fnformarion
• Management DeveloP.ment Training Comses
Lenkurt Technical Training School,..liSft
Traffic Operations
• Overs as switchboard. ca. 1940
698
Plant Operational Error prevention
In a complex acti ity like the operation of a nationwide broadband telecommunications system, there are numerous opportunitie for human error. In the Bell System, such mistakes were called Plant Operational En-ors, or PO Es. Examples of PO Es would be shutting down a piece of equipment while it wa carrying traffic, or connecting a plug to the wrong jack causing communication to be mi routed.

Because a single coaxial conductor or microwave radio channel could cany thousands of simultaneou telephone ca lls, or a television network's programming for the entire country, Long Lines personnel took great care to avoid service disruptions on these broadband facilitie . Motivational displays like those shown below served as day-to-day reminders of the need to be vigilant in pr venting POEs. • POE scoreboard
• "No POEs" sticker
any Long Line tations had the capability of establishing temporary connections among the tation's broadband communications channels and among various device within the station. These connections, called "patches", were used to bypass equipment and channels which failed or were being taken out of service for routine maintenance, and to reconfigure the network to meet unusual, short-tenn service n eds. For example, a spare radio channel could be patched to cany a special television broadcast from the town where it originate to a nearby city, where it would be patched into one of the national network "loops".

Patches were established by plugging "patch cord " - lengths of flexible cable with plugs at both end - into jacks located on "patch bays". A "patch bay" was a vertica l panel holding a number of jack , each jack being permanently wired to an individual broadband communications channel or piece of equipment. A given function might require more than one patch connection. For example since a broadband channel carries communications in only one direction, patches on two channels would be required in order to establish a two-way link for voice n·affic.
o indicate the purpose of a pa11icular patch and help prevent the accidental removal of active connections, an A &T committee dev loped paper patch cord identification tag which would be attached to the patch cords being used. The tags were furnished in various colors to distinguish among multiple patches which might be in place simultaneously for different purposes allowing technicians to easily locate all of the patch cords being used for a given task.

Disaster Recovery
• "Miracle on Second Avenue" - booklet de cribing er ice restoration after a major fire at a Manhattan central office in 1975.
• "Mi chief'? Malice? Or Mother amre?" - adverti ement from 1968 Safety
• Wall thermometer with safety slogan
• Coaxial-cable reps:acer hut enrrv-exit procedures sign Other Motivational items
• "AIJ We Have to Offer is Servjc :" poster
Western Electric
699
• We tern Electric Washington Service Center booklet - from 1969 Return to ...
• Long Lines main (llig~
Updated on May 13, 20 l O at 20:25 by Albert LaFrnnce
700

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ROB BONTA

ATTORNEY GENERAL
Best Practices for Analyzing and Mitigating Wildfire Impacts of Development Projects Under the California Environmental Quality Act I. Introduction
Wildfires are part of California's present, and with the effects of climate change, an increasing part of our future. Development in fire-prone areas increases the likelihood that more destructive fires will ignite, fire-fighting resources will be taxed, more habitat and people will be put in harm's way or displaced, and more structures will burn. It is therefore imperative that local jurisdictions making decisions to approve new developments carefully consider wildfire impacts as part of the environmental review process, plan where best to place new development, and mitigate wildfire impacts to the extent feasible.

This guidance is designed to help lead agencies1 comply with the California Environmental Quality Act, Public Resources Code, section 21000 et seq. (CEQA), when considering whether to approve projects in wildfire-prone areas. These areas are often in the wildland-urban interface, generally defined as the area where the built environment meets or intermingles with the natural environment. 2 The California Department of Forestry and Fire Protection (CAL FIRE) has classified lands based on fire risk, the highest being those classified as high or very high fire hazard severity zones. It has also identified areas where the State (as opposed to a local agency) has responsibility for fire-fighting. 3 Particularly in these high-risk areas, but also throughout the 1 Lead agencies are any public agencies with "principal responsibility for carrying out or approving a project which may have a significant effect upon the environment." (Pub. Resources Code,§ 21067.) 2 CAL FIRE has published an instructive map on the wild land-urban interface in California: https://frap. fire.ca.gov/media/10300/wui 19 ada.pdf. The wildland-urban interface is defined differently by different agencies for different purposes, but the most widely used definition for wildfire purposes include the intermix and interface areas mapped by Radeloff et al. 2005, 2018. See Volker C. Radeloff, et al., Rapid Growth of the us Wild/and-Urban Interface Raises Wildfire Risk. PROCEEDINGS OF THE NATIONAL ACADEMY OF SCIENCES USA, 115(13):3314-3319 (2018), available at https:ljwww.pnas.org/doi/10.1073 /pnas.1718850115.
3 See https://osfm.fire.ca.gov/divisions/community-wildfire-preparedness-and-mitigation/wildlandhazards-building-codes/fire-hazard-severity-zones-maps/. Note that areas mapped by CAL FIRE as high or very high fire risk are not always coextensive with the wildland-urban interface. In addition, CAL FIRE's maps are currently in the process of being updated and lead agencies should consult with CAL 704
wildland-urban interface, wildfire risks must be considered during the environmental review process for individual development projects.

This guidance provides suggestions for how best to comply with CEQA when analyzing and mitigating a proposed project's impacts on wildfire ignition risk, emergency access, and evacuation. 4 This guidance is aimed at proposed development projects, such as residential, recreational, or commercial developments.5 The extent to which it applies will inherently vary by project, based on project design and location. This document does not impose additional requirements on local governments or alter any applicable laws or regulations. Rather, it is intended to provide guidance on some of the issues, alternatives, and mitigation measures that should be considered during the environmental review process. This guidance is based on the Office of the Attorney General's experience reviewing, commenting on, and litigating CEQA documents for projects in high wildfire prone areas, and is intended to assist lead agencies with their planning and approval of future projects. The guidance reflects current requirements and conditions and may need to be updated as changes occur.

II. Background
Although wildfires are and have been an important natural process throughout California's history, recent changes in fire frequency, intensity, and location are posing increasing threats to the residents and environment of California. More acres of California have burned in the past decade than in the previous 90 years6 and eight of the State's ten largest fires since 1932 have occurred in the last decade.7 While lightning is a common cause of some of the State' s largest FIRE before relying on the classifications listed on this map. CAL FIRE's list of state responsibility areas (defined as areas where the State of California, as opposed to a local agency, is financially responsible for prevention and suppression of wildfires) can be found at: https://calfire-forestry.maps.arcgis.com/ apps/webappviewer/index.html?id=468717e399fa4238ad86861638765cel. Each county should have a map of the very high or high fire hazard severity zones in its jurisdiction, and they are also included on the CAL FIRE zone map: https://egis.fire.ca.gov/FHSZ/.
4 Readers who want to determine their legal obligations under CEQA should consult their own attorney for legal advice.
5 This guidance is not intended to apply to state and local agency fire management activities, such as prescribed burns, approval of vegetation management plans to reduce wildfire risk, and review of timber harvesting plans.
6 CAL FIRE, Top 20 Largest California Wildfires (Jan. 13, 2022), available at https://www.fire.ca.gov /media/ 4jandthh/top20 acres.pdf. See also Hugh D. Safford et al., The 2020 California Fire Season: A Year Like No Other, a Return to the Past or a Harbinger of the Future? (Apr. 17, 2022) GLOBAL ECOLOGY AND BIOGEOGRAPHY, available at ht ps://onlinelibrary.wiley .com/doi/10.llll/geb.13498?af=R. 7 Pau l Rogers, Map: 1 of Every 8 acres in California has Burned in the Last 10 Years. Here's Where the Biggest Fires Spread-and are Burning Now, Mercury News (Sept. 29, 2021), available at https://www.mercurynews.com/2021/09/29/top-10-california-wi ldfires-megafires-ma p/. Nata bly, the large fires of late are not unprecedented in the State's history with similarly large fires occurring specifically during the 1920s. See Jon E. Keeley & Alexandra D. Syphard, Large California Wildfires: 2020 2 705
fires, in recent years, many of the State's most destructive fires have been caused by human activity, such as downed powerlines or electrical sources associated with residential development or industrial facilities. 8
Wildfires can have dramatic, adverse ecological impacts. Frequent wildfires can result in habitat loss and fragmentation, shifts in vegetative compositions, reductions in small mammal populations, and accelerated loss of predatory species.9 Wildfire can also have adverse impacts on erosion and water quality. During active burning, ash and associated contaminants can enter water supplies. Later, after large burns, rainstorms can flush vast amounts of sediment from exposed soils into those same water supplies. 10
Wildfires also have tragic consequences for California's res idents. Since 2010, wildfires have killed nearly 150 people in California11 and, since 2005, wildfires have destroyed over 97,000 struct ures,12 requiring mass evacuations and exacerbating the State' s already-pressing need for more housing. In addition, wildfire smoke is unhealthy to breathe and is a publ ic health concern . 13 Further, wildfire losses are not experienced equally. Lower-income households are more likely to lose all of their assets and less likely to have adequate insurance to cover their losses.14 Meanwhile, the costs of wildfire suppression and resiliency have become significant. In Fires in Historical Context (Aug. 25, 2021) FIRE ECOLOGY, available at https://fireecology.springeropen.com /articles/10.1186/s42408-021-00110-7.
8 See CAL FIRE, Top 20 Largest California Wildfires (~an . 13, 2022), available at https://www.fire.ca.gov /media/4jandlhh/top20 acres. pdf; Ca lFire, Top 20 Most Destructive California Wildfires (Jan. 13, 2022), available at https:ljwww.fire.ca.gov/medla/t1rdhizr/top20 destruction.pdf. 9 See Alexandra D. Syphard, et al., Human Influence on California Fire Regimes. ECOLOGICAL APPLICATION 17:1388-1402 (2007).
10 United States Environmental Protection Agency, Wildfires : How do They Affect Our Water Supplies? (Aug. 13, 2019), available at https:ljwww.epa.gov/sciencematters/wildfires-how-do-they-affect- ourwater-suppJies#:~:text=Vegetation%20that%20holds%20soil%20in,%2C%20rivers%2C%20and%20 downstream%20reservoirs .
11 CAL FIRE, Top Deadliest Ca lifornia Wildfires (Oct. 22, 2021), available at https://www.fire.ca.gov/ media/lbfd0m2f/top20 deadliest.pdf.
12 Headwaters conomics, Wildfires Destroy thousands of structures each year (Nov. 2020, updated Aug. 2022 ), available at https :// headwate rsecon om ics.org/natura I-hazards/ stru ctu res-d estroyed-by-wi ldfi re/. 13 See Kurtis Alexander, California Ranks Worst in Nation for Air Pollution Because of Wildfire Smoke, S.F.

Chronicle (June 23, 2022), available at https:Uwww.sfchronicle.com/bayarea/article/california-airguality-17259687.php. See also Lora Kolodny, The West Coast Is Suffering from Some of the Worst Air in the World - These Apps Show How Bad it Is, C BC (Sept. 13, 2020), available at https://www.cnbc.com/ 2020/09/12/a ir-qua lity-apps-purpleair-ai rnow-iqair-esse ntial-in-western-us.html; and California Air Resources Board, Protecting Yourself from Wildfire Smoke, available at https://ww2.arb.ca .gov/ protecting-you rse lf-wi Id fire-smoke.
14 California Council on Science and Technology, The Costs of Wildfire in California (Oct. 2020), at p. 69, available at https:ljccst.us/reports/the-costs-of-wildfire-in-california/. 3 706
2021, the State invested $1.5 billion in wildfire resiliency efforts, and the 2022-2023 budget includes an additional $1.2 billion to support wildfire and forest resilience. 15 The changing nature of wildfires, under various metrics- frequency, area burned, adverse ecological impacts, the number of Californians displaced-is a worsening crisis that will unfortunately be part of California' s future. 16
As of 2010, about one-third of California' s housing units were located within the wildland-urban interface.17 Residentia l developments in the wi ldland-urban interface and other wildfire prone areas can significantly increase the risks of wildfires and the risk to publ ic safety for several reasons. First, introducing more people-via additional development-into a flammable landscape increases the likelihood of: (1) a wildfire igniting due to the increased presence of people; and (2) t e ignition becoming a wildfire because of the placement of homes amongst the flammable vegetation. 18 Second, building housing units in the wildland-urban interface puts more people in harm's way.19 Wildfires, particularly those that impact developments in relatively remote locations, may impede the evacuation of commun ities and emergency access, making it more difficult to ensure publ ic safety and to limit, control, or extinguish wildfires.

Finally, fires in remote locations require significant fire-fighting resources and mobilization of fire-fighters from all over the State-putting a major strain on the State's fire-fighters and the State's budget. Put simply, bringing more people into or near flammable wildlands leads to more frequent, intense, destructive, costly, and dangerous wildfires.20 15 Gavin Newsom, California State Budget (2022-2023), at p. 61, available at https://www.ebudget.ca. gov/FullBudgetSummary.pdf; California State Budget, Budget Addendum (2021-2022), at p. 3, available at https://www.ebudget.ca.gov/BudgetAddendum. pdf.
16 See California Counci l on Science and Technology, The Costs of Wildfire in California (Oct. 2020), at p. 17, available at https://ccst.us/reports/the-costs-of-wildfire-in-california/. 17 Community Wildfire Planning Center, Land Use Planning Approaches in the Wildland-Urban Interface (Feb. 2021), at p. 7, available at https://www.communitywildfire.org/wp-content/uploads/2021/02/ CWPC Land-Use-WU I-Report Final 2021.pdf: see also Heather Anu Kramer, et al., High Wildfire Damage in Interface Communities in California (2019) I ERNA IONALJOURNALOF WILDLA o FIRE, available at https://www.fs .usda.gov/nrs/pubs/jrnl/2019/nrs 2019 kramer 001.pdf. At the current rate of growth and under current growth patterns, lt is anticipated that an additional 645,000 housing units wi ll be developed in areas designated by CAL FIRE as very hlgh fire hazard severity zones by 2050. Next 10, Rebuilding for a Resilient Recovery: Planning in Ca lifornia's Wildland Urban Interface (June 2021), at p. 9, avai lable at https://www.nextlO.org/publ ications/rebuilding-resilient. 18 See Alexandra D. Syphard, Why Are so Many Structures Burning in California? (2020) Fremontia, 47(2), at p. 29; Volker C. Radel off, et al., Rapid Growth of the US Wild/and-Urban Interface Raises Wildfire Risk.

PROCEEDINGS OF HE NATIONAL ACADEMY OF SCIENCES USA, 115(13):3314-3319 (2018). 9 See Heather Anu Kramer, et al., High Wildfire Damage in Interface Communities in California (2019) International Journal of Wildland Fire, available at https://www.fs .usda.gov/nrs/pubs/jrnl/2019/ nrs 2019 kramer 001.pdf: Volker C. Radeloff, et al., Rapid growth of the US wild/and-Urban interface raises wildfire risk. PROCEEDINGS OF THE NATIONAL ACADEMY OF SCIENCES USA, 115(13):3314-3319 (2018). 20 See Michael L. Mann, et al., Incorporating Anthropogenic Influences into Fire Probability Models:

Effects of Human Activity and Climate Change on Fire Activity in California (Apr. 28, 2016) PLOS ONE 4 707
Ill. Wildfire and Land Use Planning
While this guidance is focused on best practices to disclose, analyze, and mitigate wildfire impacts in compliance with CEOA, it is important to note that general planning also provides a critical opportunity for local jurisdictions to think proactively about how to accommodate their housing and development needs while reducing the risks of wildfire. 21 In the last ten years, new legislation has passed requiring local jurisdictions to consider wildfire risks in their general planning processes.22 The Governor's Office of Planning and Research (QPR) recently published comprehensive guidance to help local agencies comply with these requirements. 23 We encourage local jurisdictions to consult this guidance and to thoughtfully plan for new development given the increasing risk of wildfires throughout the state. 24 11(4), available at https://journals.plos.org/plosone/article?id=l0.1371/journal.pone.0153589; Alexandra D.

Syphard, Why Are so Many Structures Burning in California? (2020) FREMONTIA, 47(2), at pp. 28-35, available at https://pubs.er.usgs.gov/publication/70215982; Alexandra D. Syphard, et al., Land Use Planning and Wildfire: Development Policies Influence Future Probability of Housing Loss (2013) PLOS ON E, available at https://iou rnals.plos.org/plosone/a rtic!e/file ?id= 10.13 71/j ournal. pone .0071708& type=printable; see also Final Statement of Reasons for Regulatory Action re Amendments to the State CEQA Guidelines OAL Notice File No. Z-2018-0116-12 ("Statement of Reasons"), at p. 87, available at https://resources.ca.gov/CNRAlegacyFiles/cega/docs/2018 CEQA Final Statement of%20Reasons 111218.pdf.
21 See Alexandra D. Syphard, Why Are so Many Structures Burning in California? (2020) FREMONTIA, 47(2), at p. 33, available at https://pubs.er.usgs.gov/publication/70215982 [concluding t hat "the most effective strategy at reducing future structure loss would focus on reducing the extent of low-density housing via careful land planning decisions"].
22 See Sen Bill No. 1241 (2011-2012 Reg. Sess.), amending and/or adding Gov. Code,§§ 65302, subd. (g)(3), 65302.5, subd. (b), and 66474.02) [requiring local jurisdictions within state responsibility areas or very high fire hazard severity zones to address wildfire risk when updating their safety elements and to submit their draft updates to the State Board of Forestry and Fire Protection for review]; Sen . Bill No. 99 {2019-2020 Reg. Sess.), amending Gov. Code,§ 65302, subd. (g)(5) [requiring updated safety elements to identify residential developments within hazard areas that do not have at least two evacuation routes]; Assem. Bill No. 747 (2019-2020 Reg. Sess.), adding Gov. Code, § 65302.15 [requiring local jurisdictions to update their safety element to address the capacity of evacuation routes under a range of various emergency scenarios]; Assem. Bill No. 1409 (2020-2021 Reg. Sess .), amending Gov. Code, § 65302.15 [requiring that safety elements identify locations where people can evacuate to]. 23 Governor's Office of Planning and Research, Fire Ha2ard Planning Technical Advisory, 2022 Update (Aug. 2022), available at https://opr.ca.gov/docs/20220817-Fire Hazard Planning TA.pdf; and Wildland-Urban Interface Planning Guide: Examples and Best Practices for California Communities (Aug. 2022), available at https://opr.ca.gov/docs/20220817-Complete WU I Planning Guide.pdf. 24 Local jurisdictions that have complied with their general planning obligations, including incorporating wildfire and evacuation planning considerations into their general plans, may benefit from st reamlined CEQA requirements at the project approval level. If a development project is consistent with an updated general plan and an environmental impact report (EIR) was prepared fort at plan, the CEQA review for the project may be limited to the parcel-specific impacts of t he project or impacts that new information, 5 708
IV. Analyzing and Mitigating Wildfire Risk Impacts Under CEQA A. CEQA's requirements for analyzing wildfire risks
CEQA requires local jurisdictions considering development projects to prepare an environmental impact report (EIR) or a mitigated negative declaration25 if the project may potentially have a significant impact on the environment and is not otherwise exempt from CEQA. 26 Under CEQA, local jurisdictions may act as lead agencies with responsibility for preparing the EIR (or other CEQA document), or as responsible agencies relying on an EIR prepared by a lead agency. CEQA provides a critical process for local jurisdictions to understand how new developments will exacerbate existing wildfire risks, allowing them to consider project design features, alternatives, and mitigation measures that provide for smarter development and the protection of existing communities.

The CEQA Guidelines 27 require that an EIR include a description of the physical environmental conditions in the vicinity of the project, at the time the notice of preparation is published, or if no notice of preparation is published, at the time environmental analysis is commenced. 28 This "baseline" of existing environmental conditions is generally used to determine the significance of project-related impacts. In the El R's discussion of the existing environmental conditions, lead agencies should include information about open space areas and habitats within the project area that may be fire prone, as well as a discussion of fire history and fuels on the project site.

Including a discussion of existing available water supplies for fire-fighting is also critical.

Providing detail about existing environmental conditions at the project site that may exacerbate or minimize wildfire impacts will help ensure that the EIR fully considers the project's impacts on wildfire risk.

The CEQA Guidelines require an analysis of "any significant environmental effects the project might cause or risk exacerbating by bringing development and people into the area affected," including by locating development in wildfire risk areas. 29 The "environmental checklist form" in Appendix G of the CEQA Guidelines, Section XX, directs lead agencies to assess whether arising since adoption of the general plan, shows will be more significant than described in the prior EIR. (Pub. Resources Code,§ 21083.3; CEQA Guidelines,§ 15193}. 25 Where "EIR" is used in this guidance it should also be considered to refer to a mitigated negative declaration.
26 Pub. Resources Code, § 21067; CEQA Guidelines,§§ 15050 and 15367. 27 The CEQA Guidelines are found at California Code of Regulations, title 14, section 15000, et seq. 28 CEQA Guidelines,§ 15125.
29 CEQA Guidelines,§ 15126.2.
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projects located in or near state responsibility areas or lands classified as very high fire hazard severity zones,30 would:
a) Substantially impair an adopted emergency response plan or emergency evacuation plan;
b) Due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire;
c) Require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment; or d) Expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes. 31
In addition to the four questions above, Section IX(g) of the checklist broadly directs lead agencies to consider whether a project will "expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires." 32 In answering these questions, lead agencies must consider both on- and off-site impacts.33 B. Analyzing a project's impact on wildfire risks
Several variables should be considered in analyzing a project's impact on wildfire risk, including:
• Project Density: Project density influences how likely a fire is to start or spread, and how likely it is that the development and its occupants will be in danger when a fire starts. Fire spread and structure loss is more likely to occur in low- to intermediatedensity developments.34 This is because there are more people present to ignite a fire (as compared to undeveloped land), and the development is not concentrated enough 30 See footnote 1 for more information on state responsibility areas and very high fire hazard severity zones.
31 CEQA Guidelines, Appendix G, XX.
32 CEQA Guidelines, Appendix G, IX{g). This Guidance focuses on these key wildfire-related questions in Sections IX(g) and XX of the checklist, but in conducting environmental review, lead agencies must continue to thoroughly address the other questions identified in Section XX and the checklist more generally.
33 CEQA Guidelines, § 15360 [defining the environment to be considered as "the area in which significant effects would occur either directly or indirectly as a result of the project"]. 34 Alexandra D. Syphard, The Relative Influence of Climate and Housing Development on Current and Projected Future Fire Patterns and Structure Loss Across Three California Landscapes {2019) GLOBAL ENVIRONMENTAL CHANGE; Alexandra D. Syphard, et al., Housing Arrangement and Location Determine the Likelihood of Housing Loss Due to Wildfire {Mar. 28, 2012) PLOS ONE, available at https://journals.plos .org/plosone/ article ?id=10.13 71/jou rna I. pone. 0033954. 7 710
(as compared to high-density developments) to disrupt fire spread by removing or substantially fragmenting wildland vegetation.35 "Isolated clusters of development and low housing density mean that homes are embedded within, and more exposed to, a matrix of wild land vegetation."36 Moreover, fire-fighters may have difficulty accessi ng more remote and disconnected developments.37
• Project Location in the Landscape: Project placement in t he landscape relative to fire history, topography and wind patterns also influences wildfire risk. Although wildfire ignitions are primarily human-caused in California, wildfire behavior is largely driven by topography, fuel, climatic conditions, and fire weather (such as low humidity and high winds). How a development project is planned within the landscape determines to what extent it will influence fire risk.38 For example, if a project site is located in a wind corridor, above-ground power lines may become a source of ignition. Similarly, siting residential structures in rugged terrain or on the top of steep hills may increase the wildfire risk. By contrast, if a project site includes landscape features that cou ld prevent or slow the spread of fire, such as a lake or an irrigated golf course, the development may be strategically located so as to capitalize on that feature as a natural fuel break.39 ~s See g1:111:rdliy Aiexdntlrd D. Syµhdrd, et. al., Mu/tiple-Scole Relation hips between Vegetation, the Wild/and-Urban Interface, and Structure Loss to Wildfire in California (Mar. 12, 2021) MOPI FIRE 2021. 36 Max A. Moritz, et al., Learning to Coexist with Wildfire (2014) NATURE 515(7525), at p. 64; see also Alexandra D. Syphard, et. Al., Multiple-Scale Relationships between Vegetation, the Wild/and-Urban Interface, and Structure Loss to Wildfire in California (March 12, 2021) MDPI FIRE 2021. 37 See Alexandra D. Syphard, Why Are so Many Structures Burning in California? (2020) FREMO TIA, 47(2), at p. 31.
38 See generally Max Moritz, et al., Building to Coexist with Fire: Community Risk Reduction Measures for New Development in California (Apr. 2020) University of California Agriculture and Natural Resources, Publication 8680, available at https://escholarship.org/uc/item/6n12m6pn: Alexandra D. Syphard, Why Are so Many Structures Burning in California? (2020) FREMO TIA, 47(2), at pp. 28-35, avai lable at https ://pubs.er. usgs.gov/pu blication/70215982.
39 See Max Moritz, et al., Building to Coexist with Fire: Community Risk Reduction Measures for New Development in California (Apr. 2020) University of California Agricu lture and Natural Resources, Publication 8680, at p. 10, available at https://escholarship.org/uc/item/6n12m6pn; see also Conservation Biology Institute, Paradise Nature-Based Fire Resilience Project Final Report (June 2020), available at https://d2k78bk4kdh bpr.cloudfront. net/media/reports/files/CBI Paradise Final Report for Posting Online.pdf [An examination of how siting and greenbelts may have protected homes during the Paradise fire]. Sit ing of a new fire-resistant development between wild la nds and existing development may even serve as a protective barrier for the existing development. But there can still be some risk of ember spread if the new development succumbs to fire. See Alexandra 0. Syphard, Why Are so Many Structures Burning in California? (2020) FREMONTIA, 47(2), at pp. 28-35, available at https://pubs.er.usgs.gov/publication/70215982; Ca lifornia Council on Science and Technology, The Costs of Wildfire in California (Oct. 2020), at p. 67, available at https://ccst.us/reports/the-costs-of-wildfire-incalifornia/. 8 711
• Water Supply and Infrastructure: As part of evaluating a project's wildfire risk impacts, an EIR should analyze the adequacy of water supplies and infrastructure to address firefighting within the project site. 40 This analysis should consider the potential loss of water pressure during a fire, which may decrease available water supply41 and the potential loss of power, which may eliminate the supply. 42 To understand how a project may exacerbate the risk of wildfire, an EtR should qualitatively assess these variables and also use fire modeling and other spatial and statistical analyses to quantify the risks to the extent feasible. Experts should utilize fire models to account for various siting and design elements, as well as a variety of different fire scenarios. The modeling should include scenarios for fires that start in, near, and far from the project site, as well as extreme weather conditions that exacerbate fire spread.

Lead agencies are encouraged to develop thresholds of significance that either identify an increase in wildfire risk as a significant impact or determine, based on substantial evidence, that some increase in the risk of wildfires is not considered a significant impact. Relevant factors should include the project's impact on ignition risk, the likelihood of fire spread, and the extent of exposure for existing and new resi dents based on various fire scenarios. Modeling the various scenarios enables local agencies to quantify increased wildfire risks resulting from a project adding more people to wildfire prone areas and to assess the risks according to the threshold of significance.

Some EIRs have concluded that the conversion of some wildland vegetation into paved development reduces or does not increase wildfire risk. This conclusion is contrary to existing evidence and the well-accepted understanding that the fundamental driver of increased wildfire risk is the introduction of people into a flammable landscape. 43 Accordingly, the conversion of vegetation into developed land does not obviate the need for lead agencies to carefully consider and model how the addition of development into wildfire prone areas contributes to the risk of wildfire.
40 See Max Moritz, et al., Building to Coexist with Fire: Community Risk Reduction Measures for New Development in California (Apr. 2020) University of California Agriculture and Natural Resources, Publication 8680, at p. 19 and Appendix B, available at https://escholarship.org/uc/item/6n12m6pn . 41 See Max Moritz, et al., Building to Coexist with Fire: Community Risk Reduction Measures for New Development in California (Apr. 2020), at p. 19, University of California Agriculture and Natural Resources, Publication 8680, avai lable at https:llescholarship.org/uc/item/6n12m6pn. 42 See Alexandra D. Sypha rd, Nexus Between Wildfire, Climate Change and Population Growth in California (2020) FRE lONTIA, 47(2), at p. 26.
~ See Heather Anu Kramer, et al., High Wildfire Damage in Interface Communities in California (2019) INTERNATIONALJOURNAL OF WILDLA o FIRE, available at https://www.fs.usda.gov/nrs/pubs/ jrnl/2019/nrs 2019 kramer 001.pdf; see also Exhibit A to the Final Statement of Reasons for Regulatory Action re Amendments to the State CEQA Guidelines, OAL Notice File No. Z-2018-0116-12, at p. 212, available at https://resources.ca.gov/CNRALegacyFiles/ceqa/docs/2018 CEQA ExA FSOR.pdf. 9 712
C. Analyzing the project's impact on evacuation and emergency access The addition of new development into high wildfire risk or adjacent areas may impact the evacuation of project residents, as well as the existing population (e.g., residents, workers, students, visitors, and possibly livestock) in the area and the ability of emergency responders to simultaneously access the area to fight wildfire. This can, in turn, impact the risk and extent of large-scale fire spread and community safety within and around the new development. The EIR should evaluate these impacts both during construction and over the life of the project. The required analysis is relative to a project's impacts and risks; e.g., a higher density infill project within an already developed area would likely not require the same level of analysis as a new low-density development within the wildland-urban interface and surrounded largely by open space.44
For projects located in high wildfire risk areas that present an increased risk of ignition and/or evacuation impacts, evacuation modeling and planning should be considered and developed at the time of project review and approval-when there is greater flexibility to modify a project's design, density, siting, and configuration to address wildfire considerations-rather than deferred to a later stage of the development process. Lead agencies will be best-positioned to ensure proposed development projects facilitate emergency access and ease constraints on evacuation with this information in hand prior to project approval. The ultimate objective is to allow for informed decision-making that minimizes the environmental and public safety hazards associated with new developments that increase the risk of ignition and impede evacuation in high wildfire prone areas.

Evacuation modeling and analysis should include the following:
• Evaluation of the capacity of roadways to accommodate project and community evacuation and simultaneous emergency access.
• Assessment of the timing for evacuation.
• Identification of alternative plans for evacuation depending upon the location and dynamics of the emergency.
• Evaluation of the project's impacts on existing evacuation plans. • Consideration of the adequacy of emergency access, including the project's proximity to existing fire services and the capacity of existing services. • Traffic modeling to quantify travel times under various likely scenarios. 44 See Max Moritz, et al., Building to Coexist with Fire: Community Risk Reduction Measures for New Development in California (Apr. 2020), University of California Agriculture and Natural Resources, Publication 8680, at p. 5, available at https://escholarship.org/uc/item/6n12m6pn [describing the benefits of infill development].
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In considering these evacuation and emergency access impacts, lead agencies may use existing resources and analyses, but such resources and analyses should be augmented when necessary.

For example, agencies should:
• Utilize information from the El R's analysis of traffic/transportation impacts, but they should not limit themselves to that information, which may not reflect the impact of emergency conditions on travel times.
• Consult with local fire officials and ensure that assumptions and conclusions regarding evacuation risk are substantiated with sound facts. Emergency conditions may not allow for ideal evacuation scenarios-staggered, staged, or targeted evacuation in response to a wildfire may sometimes be possible, but human behavior is difficult to predict and wildfires can be erratic, unpredictable, and fast-moving. 45 • Consider impacts to existing evacuation plans, but recognize that, depending on the scope of an existing evacuation plan, additional analyses or project-specific plans may be needed. Community evacuation plans often identify roles and responsibilities for emergency personnel and evacuation routes, but do not necessarily consider the capacity of roadways, assess the timing for community evacuation, or identify alternative plans for evacuation depending upon the location and dynamics of the emergency.
• Avoid overreliance on community evacuation plans identifying shelter-in-place locations. Sheltering in place, particularly when considered at the community planning stage,46 can serve as a valuable contingency, but it should not be relied upon in lieu of analyzing a_nd mitigating a project's evacuation impacts. 47 Local jurisdictions are encouraged to develop thresholds of significance for evacuation times.

These thresholds should reflect any existing planning objectives for evacuation, as well as 45 See FEMA and U.S. Fire Administration, Wild/and Urban Interface: A Look at Issues and Resolutions (June 2022), available at https://www.usfa.fema.gov/downloads/pdf/publications/wui-issuesresolutions-report.pdf. 46 FEMA, Planning Considerations: Evacuation and Shelter-in-Place (July 2019), available at https://www. fema.gov/sites/default/files/2020-07 /planning -considerations-evacuation-and-shelter-in-place.pdf. The distinction between temporary shelter-in-place locations and buildings designed or retrofitted for longer term shelter-in-place should also be considered. See Max Moritz, et al., Building to Coexist with Fire:

Community Risk Reduction Measures for New Development in California (Apr. 2020) University of California Agriculture and Natural Resources, Publication 8680, at p. 17, available at https://escholarship .org/uc/item/6n12m6pn !discussing the difference between "safety zones"-areas with little flammable vegetations, such as golf courses-versus buildings that are designed to provide protection from heat and embers while the front of a fire passes, typically for a duration of at least 30-60 minutes]. 47 See Mejia, Pepperdine University Defends 'Shelter in Place' Decision During Woolsey Fire, Los Angeles Times (Nov. 13, 2018), available at https://www.latimes.com/local/lanow/la-me-ln-pepperdine-shelter20181113-story.html; Chandler, Am I Going to Stay in the Parking Lot . . . While the Fires Burn Around Me?, Record Searchlight (Dec. 12, 2019), available at https://www.redding.com/in-depth/news/ 2019/04/25/california-wildfire-shelter-place-plans-guestioned-evacuation-preparation/3427075002/. 11 714
informed expert analysis of safe and reasonable evacuation times given the existing and proposed development. Local jurisdictions should consider whether any increase in evacuation times for the local community would be a significant impact. A conclusion that an increase in evacuation times is a less than significant impact should be based on a threshold of significance that reflects community-wide goals and standards.

In establishing thresholds, local jurisdictions should consider referring to successful evacuations from prior emergencies within their community or similarly situated communities. The thresholds should include, but not be limited to, whether the project creates an inconsistency with: (1} an adopted emergency operations or evacuation plan; (2} a safety element that has been updated per the requirements in Government Code sections 65302{g}(5} and 65302.15 to integrate wildfire and evacuation concerns; or {3} recommendations developed by the California Board of Forestry and Fire Protection regarding the safety of subdivisions pursuant to Public Resources Code section 4290.5.

D. Mitigating wildfire risk, evacuation, and emergency access impacts If a project presents significant increased wildfire risks and/or evacuation and access impacts, CEQA requires the lead agency to consider and adopt feasible alternatives and mitigation measures to avoid or reduce the project's impacts {or make a finding of overriding consideration}. 48 Not all project design features or mitigation measures will achieve the same reduction in impacts for every project-the effects and effectiveness of measures will vary geographically and by project. An EIR that baldly concludes that certain project design features or mitigation measures will reduce or eliminate all potential wildfire risks, without first describing those risks, fails to fully analyze the project's impacts. Compressing the analysis of impacts and mitigation deprives decision makers of a full description of the project's adverse impacts and, therefore, fails to equip the decision makers with the necessary information to properly address the impacts by adopting project design features, mitigation measures, or alternatives. To avoid this error and provide for better project design, the project EIR should first analyze the increased wildfire risks and evacuation impacts, and then consider feasible mitigation and alternatives to avoid or reduce those impacts.

Set forth below are some examples of potential mitigation measures and design alternatives that m·ay reduce wildfire risk impacts. This list is not exclusive and a lead agency's adoption of some or all of these mitigation measures for a particular project may not be sufficient to comply with CEQA's requirement to adopt all feasible mitigation measures. • Increasing housing density and consolidated design, relying on higher density infill developments as much as possible.
• Avoidance and minimization of low-density exurban development patterns or leapfrogtype developments {i.e., those with undeveloped wildland between developed areas}. 48 Pub. Resources Code,§ 21081.
12 715
• Decreasing the extent and amount of "edge," or interface area, where development is adjacent to undeveloped wildlands.
• Creation of buffer zones and defensible space within and adjacent to the development, with particular attention to ensuring that vegetation will not touch structures or overhang roofs.49 It is also important that legal obligations are structured so that defensible space measures are retained over time. 50
• Siting projects to maximize the role of low-flammability landscape features that may buffer the development from fire spread.
• Undergrounding power lines.
• Limiting development along steep slopes and amidst rugged terrain, so as to decrease exposure to rapid fire spread and increase accessibility for fire-fighting. • Placement of development close to existing or planned ingress/egress and designated evacuation routes to efficiently evacuate the project population and the existing community population, consistent with evacuation plans, while simultaneously allowing emergency access.
• Placement of projects close to adequate emergency services. • Construction of additional points of ingress and egress and modification of evacuation routes to minimize or avoid increasing evacuation times or emergency access response times.
• Fire hardening structures and homes-upgrading the building materials and installation techniques to increase the structure's resistance to heat, flames, and embers-beyond what is required in applicable building codes, both for new structures and existing structures in proximity to the new development.
• Requiring fire-hardened communication to the project site including high-speed internet service.
• Enhanced communication to the project population about emergency evacuation plans and evacuation zones.
• Parking limitations to ensure access roads are not clogged with parked vehicles. • On-site water supply/storage to augment ordinary supplies that may be lost during a wildfire.

In all situations, mitigation measures should be combined and tailored to the specifics of the project, the surrounding landscape, and nearby existing uses. In some contexts, the mitigation measure itself may have an adverse impact that should be evaluated in an EIR. In addition, 49 Note, however, that defensible space around homes does not alone tend to account for structural survival. See Alexandra D. Syphard, Why Are so Many Structures Burning in California? (2020) FREMONTIA, 47(2), at p. 32, available at https://pubs.er.usgs.gov/publication/70215982; Alexandra D.

Syphard et al., The Role of Defensible Space for Residential Structure Protection During Wildfires (Oct. 14, 2014) INTERNATIONALJOURNAL OF WILDLAND FIRE, available at http://dx.doi.org/l0.l071/WF13158. 50 See Max Moritz, et al., Building to Coexist with Fire: Community Risk Reduction Measures for New Development in California (Apr. 2020), at p. 12, University of California Agriculture and Natural Resources, Publication 8680, available at https://escholarship.org/uc/item/6n12m6pn. 13 716
mitigation measures may not provide the same level of protection or mitigation in all scenarios.51 For example, home hardening has been shown to be an extremely effective measure for preventing structure loss during a wildfire. The California Building Code was updated in 2008 to require more advanced fire hardening and homes built to the revised standards were shown to be 40 percent less likely to be destroyed by a wildfire than similarly situated homes built prior to the update. 52 However, home hardening by itself may not be an adequate mitigation measure in all situations. During the Camp Fire, which swept through Paradise in 2018, homes built before and after the 2008 Building Code update were destroyed at roughly equal rates.53 Home hardening in conformance with the 2008 Building Code alone did not meaningfully effect survivability; rather, proximity to other destroyed structures, the extent of vegetative overstory, and defensive space around homes was more relevant to whether or not a home survived.54 While home hardening may be a worthy measure, this highlights the importance of combining measures, with an awareness to overall landscape conditions, to maximize public safety and minimize wildfire-related losses. It also demonstrates that defensive measures can improve but do not guarantee survivability, which highlights the continued importance of planning for evacuation and emergency access.

VII. Conclusion
As climate change and housing pressure continue to impact the State's landscape, wildfire risks, and development needs, local agencies need to thoroughly evaluate where and how new development is planned and constructed. With careful forethought during the various planning processes and thoughtful environmental review at the individual project development stage, new development can be designed and positioned to minimize future wildfire risks, enhance fire resiliency of our communities, and protect the health and safety of California's residents and natural resources. While the applicable rules, requirements, and analytical tools to reduce wildfire risk are evolving, this guidance is intended to provide suggestions for how best to comply with CEQA when analyzing and mitigating the wildfire risks of development projects in the wildland-urban interface and other fire prone areas. 51 See Alexandra D. Syphard, et. al., Multiple-Scale Relationships between Vegetation, the WildlandUrban Interface, and Structure Loss to Wildfire in California (Mar. 12, 2021), at p. 13, MDPI FIRE 2021 [noting that "the most effective fire risk reduction approach will account for multiple factors at multiple scales and will incorporate simultaneous strategies"].
52 Patrick W Baylis, et al., Mandated vs. Voluntary Adaptation to Natural Disasters: the Case of U.S.

Wildfires (Dec. 2021}, National Bureau of Economic Research, available at https://www.nber.org/ papers/w29621.
53 Eric E. Knapp, et al., Housing Arrangement and Vegetation Factors Associated with Single-Family Home Survival in the 2018 Camp Fire, California (2021} FIRE ECOLOGY 17:25, available at https://fireecology. springeropen.com/track/pdf/10.1186/s42408-021-00117-0.pdf [37 percent of homes built between 1997 and 2008 survived, while 44 percent of homes built between 2008 and 2018 survived]. 54 Eric E. Knapp, et al., Housing Arrangement and Vegetation Factors Associated with Single-Family Home Survival in the 2018 Camp Fire, California (2021} FIRE ECOLOGY 17:25, available at https://fireecology. springeropen.com/track/pdf/10.1186/s42408-021-00117-0. pdf. 14 717

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By signing, I am a concerned residence and oppo$e any new tower·use and will fight for our property vah.1es, security, health, inclusion in planning and other .c0ncerns. I also oppose the antenna citing Ordinance 16.90 that prohibits tele.communi-eation con,panies from pladngcell towers within 500 feet of a school or residence, or within 300 feet from another cell tower. ----···
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By signing, I am a concerned resi9ence and oppose any new tower use and will fight for our property values, secur.ity, health, inclusion in plannt,ng and other concerns. I also oppose the antenna ctting Ordinance 1690 that prohibits teleccimmunication companies from.pJacing cell . towers within 500 feet of a school or residence, or within 300 feet from another cell tower. ; ,.
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By signing, I am a concerned residence and oppose any new tower use and will fight for our property values, security, health, inclusion in planning and other concerns. I also oppose the antenna citing Ordinance 1690 that prohibits telecpmmunication companies from placing cell towers within 500 feet of a school or residence, or within 300 feet from another cell tower. 723
REGARDING THE AMERICAN TOwER

RANCHO SAN CLEMENTE
By signing, I am a concerned resident and opposed to
any new tower use and will fight for our property
values, . security, health, inclusion in planning and
other concerns. I also oppose the antenna citing
Ordinance 1690 that prohibits telecommunication
companies from placing cell towers within 500 feet
of a school or ·residence, or within 300 feet from
another cell tower.

Signed:

Susan Sost
724
REGARDING THE AMERICAN TO wER

RANCHO SAN CLEMENTE
By signing, I am a concerned resident and opposed to
any ne.w tower use and will fight for our property •
values, security, health, inclusion in planning and
other concerns. I also oppose the antenna citing
Ordinance 1690 that prohibits telecommunication
companies from placing cell towers within 500 feet
of a school or residence, or within 300 feet from
another cell tower.

Signed:

Craig Sost
725
REGARDING THE AMERICAN TOwER

RANCHO SAN CLEMENTE
By signing, I am a concerned resident and opposed to
any new tower use and will fight for our property
values, security, health, inclusion in planning and
other concerns. I also oppose the antenna citing
Ordinance 1690 that prohibits telecommunication
companies from placing cell towers within 500 feet
of a school or residence, or within 300 feet from
another cell tower.

Signed:

Ruthie Spaethe
726
REGARDING THE AMERICAN TO\v'ER

Signed:

Lindsey Spaethe
727
REGARDING THE AMERICAN TO\v'ER

RANCHO SAN CLEMENTE
By .signing, I am a concerned resident and opposed to
any new tower use and will fight for our property
values, security, health, inclusion in planning and
other concerns. I also oppose the antenna citing
Ordinance 1690 that prohibits telecommunication
companies from placing cell towers within 500 feet
of a school or residence, or within 300 feet from
• another cell tower.

Signed:

Suzana Corritori
728
REGARDING THE AMERICAN TOwER

Signed:

Jess Corritori
729
REGARDING THE AMERICAN TO'w'ER

Signed:

Shayne Corritori
730
REGARDING THE AMERICAN TO'w'ER

Signed:

David Shick
731
REGARDING THE AMERICAN TOwER

Signed:

Darlene Shick
732
REGARDlNG THE AMERICAN TOwER

Signed:

Norm Petersen
733
REGARDING THE AMERICAN TOwER

Signed:

Catherine Petersen
734
REGARDING THE AMERICAN TO\v'ER

Signed:

Lina Yecpot
735
REGARDING THE AMERICAN TOwER

RANCHO SAN CLEMENTE
By signing, I am a concerned resident and oppose_d to
any new tower use and will fight for our property
values, security, health, inclusion in planning and
other concerns. I also oppose the antenna citing
Ordinance 1690 that prohibits telecommunication
companies from placing cell towers within 500 feet
of a school or residence, or within 300 feet from
another cell tower.

Signed:

Rudy Yecpot
I
I
736
REGARDING THE AMERICAN TOwER

Signed:

Rosa Christensen
737
REGARDING THE AMERlCAN TOwER

Signed:

Greg Osendorf
738
REGARDING THE AMERICAN TOwER

Signed:

Bryan Berman
739
REGARDING THE AMERICAN TOwER

RANCHO SAN CLEMENTE
By signing, I am a concerned resident and opposed to
any new tower use and will fight for our property
values, security, health, inclusion in planning and
other concerns. I also oppose the antenna citing
Ordinance 1690 that prohibits telecommunication
companies from placing cell towers within 500 feet
of a school-or residence, or within 300 feet from
another cell tower.

Signed:

Karen Berman
740
REGARDING THE AMERICAN TO'v/ER

RANCHO SAN CLEMENTE
By signing, I am a concerned resident and opposed to
any new tower use and will fight for our prop·erty
values, security, health, inclusion in planning and
other concerns. I also oppose the antenna citing
Ordinance 1690 that prohibits telecommunication
companies from placing cell towers within 500 feet
of a school or residence, or within 300 feet from
another cell tower.

Signed:
741

REGARDING THE AMERICAN TOWER

Signed:
742
REGARDING THE AMERICAN TOwER

RANCHO SAN CLEMENTE
By signing, I am a concerned resident and opposed to
any new tower use and will fight for our property
values, security, health, inclusion in planning and
other concerns. I also oppose the antenna citing
Ordinance 1690 that prohibits telecommunication
co~panies from placing cell towers within 500 feet
of a school or residence, or within 300 feet from
another cell tower.

Signed:
743
REGARDING THE AMERICAN TOwER

Signed:

James Shaw
744

REGARDING THE AMERICAN TOWER

Signed:

Pamela Shaw
745
REGARDING THE AMERICAN TOwER

Signed:

Monica Giacobelo
746
REGARDING THE AMERICAN TOwER

RANCHO SAN CLEMENTE
By signing., I am a concerned resident and opposed to
any new tower use and will fight for our property
values, security, health, inclusion in planning and
other concerns. I also oppose the antenna citing
Ordinance 1690 that prohibits telecommunication
companies from placing cell towers within 500 feet
of a school or residence, or within 300 feet from
another cell tower.

Signed:

Scott Giacobelo
747
REGARDING THE AMERICAN TOwER

Signed: _
Kay Kouris
748

REGARDING THE AMERICAN TOWER

Signed:

Randy Bennett
749
REGARDING THE AMERICAN TOwER

Signed:

Jessica Bennett
750
REGARDING THE AMERICAN TOwER

Signed:

Cara Black
751
REGARDING THE AMERICAN TOwER

Signed:

Ruthe Spear
752
REGARDING THE AMERICAN TOwER

Signed:

Kylee Spear
753
REGARDING THE AMERICAN TOwER

Signed:

Dora Carrion
754
REGARDING THE AMERICAN TOwER

Signed:

Denise Carrion
755
REGARDING THE AMERICAN TO\r/ER

Signed:

Sara Richards
756
REGARDING THE AMERICAN TOwER

Signed:

Allison Adams
757
REGARDING THE AMERICAN TO'v/ER

Signed:

Glenn Anderson
758
REGARDJNG THE AMERICAN TOwER

Signed:

Eduardo Padilla
759
REGARDING THE AMERICAN TO\v'ER

Signed:

Robert Nagel
760
REGARDING THE AMERICAN TOwER

RANCHO SAN CLEMENTE
By signing, I am a concerned resident and opposed to
any new tower use and wi ll fight for our property
values, security, health, inclusion in planning and
other concerns. I also oppose the antenna citing
Ordinance 1690 that prohibits telecommunication
companies from placing cell towers within 500 feet
of a school or residence, or within 300 feet from
another cell tower.

Signed:
761
REGARDING THE AMERICAN TOwER

Signed:

Sarah Creek
762
REGARDING THE AMERICAN TOwER

Signed:

Michele Bulka Veicer
763
REGARDING THE AMERICAN TO'v/ER

Signed:

Tatiana Bulka Veicer
764
REGARDING THE AMERICAN TO\v'ER

Signed:

Vada Lehan
765
REGARDING THE AMERICAN TOwER

Signed:

Lyndie O'Toole
766
REGARDING THE AMERICAN TOwER

Signed:

Frankie Henderson
767
REGARDING THE AMERICAN TOwER

Signed:
768
REGARDING THE AMERICAN TO'v/ER

Signed:

Brett O'Toole
769
REGARDING THE AMERICAN TOwER

Signed:

Steve Sparks
770
REGARDING THE AMERICAN TOwER

Signed:

Kristan Crotchfield
771
REGARDING THE AMERICAN TOwER

Signed:

Kortney Morrow
772
REGARDING THE AMERICAN TOwER

Signed:

Andrew Morrow
773
REGARDING THE AMERICAN TO'w'ER

RANCHO SAN CLEMENTE
By signing, I am a concerned resident and opposed to
any new tower use and wil l fight for our property
values, security, health, inclusion in planning and
other concerns. I also oppose the antenna citing
Ordinance 1690 that prohibits telecommunication
companies from placing cell towers within 500 feet
of a school or residence, or within 300 feet from
another cell tower.

Signed:

Nichelle Stevens
774
REGARDING THE AMERICAN TO~/ER

RANCHO SAN CLEMENTE
By signing, I am a concerned resident and opposed to
any new tower use and will fight for our property
values, security, health, inclusion in planning and
other concerns. I also oppose the · antenna citing
Ordinance 1690 that prohibits telecommunication
companies from placing cell towers within 500 feet
of a school or residence, or within 300 feet from
another cell tower.

Signed:

Ben Stevens
775
REGARDING THE AMERICAN TOwER

Signed:

Glenda Underwood
776
REGARDING THE AMERICAN TOwER

RANCHO SAN CLEMENTE
By signing, I am a concerned resident and opposed to
any new tower use and will fight for our property
values, security, health, inclusion in planning and
other concerns. I also oppose the antenna citing
Ordinance 1690 that prohibits telecommunication
companies from placing cel l towers within 500 feet
of a school or residence, or within 300 feet from
another cell tower.

Signed:

Larry Underwood
777
REGARDING THE AMERICAN TOwER

Signed:

Underwood
778
REGARDING THE AMERICAN TO'w'ER

RANCHO SAN CLEMENTE
By signing, I am a concerned resident and opposed to
any new tower use and will fight for our property
_ values, security, health, inclusion in planning and
other concerns. I also oppose the antenna citing
Ordinance 1690 that prohibits telecommunication
companies from placing cell towers within 500 feet
of a school or residence, or within 300 feet from
another cell tower.

Signed:
.Cole Underwood
779
REGARDING THE AMERICAN TO'w'ER

Signed:

Arthur Crockett
780
REGARDING THE AMERICAN TO'w'ER

RANCHO SAN CLEMENTE
By signing, I am a concerned resident and opposed to
any new tower use and will fight for our property
values, security, health, inclusion in planning and
other concerns. I also oppose the antennai ~iting
Ordinance 1690 that prohibits telecom .unication
companies from placing cell towers within 50 feet
of a school or residence, or within 300 rfeet fir.om
another cell tower.

Signed:

Art Wesselman
781
REGARDING THE AMERICAN TOwER

Signed:
782
REGARDING THE AMERICAN TOwER

Signed:
783
REGARDING THE AMERICAN TOwER

Signed:

David Armstron
784
REGARDING THE AMERICAN TO'v/ER

Signed:

Lindsay Armstrong
785
REGARDING THE AMERICAN TO\v'ER

Signed:
786
REGARDING THE AMERICAN TOwER

Signed:

Crista Levesque
787
REGARDING THE AMERICAN TOwER

Signed:

James Hammer
788

REGARDING THE AMERICAN TOWER

RANCHO SAN CLEMENTE
By signing, I am a concerned resident and opposed to
any new tower use and will fight for our property
values, security, health, inclusion in planning and
other concerns. - I also oppose the antenna citing
Ordinance 1690 that prohibits telecommunication
companies from placing cell towers within 500 feet
of a school or residence, or within 300 feet from
another cell tower.

Signed:
789

REGARDING THE AMERICAN TOWER

Signed:

Thomas Roberts
790
REGARDING THE AMERICAN TOwER

Signed:

Teresa P. Chicki
791
REGARDING THE AMERICAN TO\v'ER

RANCHO SAN CLEMENTE
By signing, I am a concerned resident and opposed to
any new tower use and will fight for our property
values, security, health, inclusion in planning and
other concerns. I also oppose the antenna citing
Ordinance 1690 that prohibits telecommunication.
companies from placing cell towers within 500 feet
of a school or residence, or within 300 feet from
another cell tower.

Signed:

Dolores Gomez
792
REGARDING THE AMERICAN TOwER

Signed:

Yolanda Gomez
793
REGARDING THE AMERICAN TOwER

RANCHO SAN CLEMENTE
By signing, I am a concerned resident and opposed to
any new tower use and will fight for our property
values, security, health, inclusion in planning and
other concerns. - I also oppose the antenna citing
Ordinance 16~0 that prohibits telecommunication
companies from placing cell towers within 500 feet
of a school or residence, or within 300 feet from
another cell tower.

Signed:

Tony Gomez
794
REGARDING THE AMERICAN TOwER

RANCHO SAN CLEMENTE
By signing, I am a concerned resident and opposed to
any new tower use and will fight for our property
values, security, health, inclusion in planning and
other concerns . . I also oppose the antenna citing
Ordinance 1690 that prohibits telecommunication
companies from placing cell towers within 500 feet
of a school or residence, or within 300 feet from
another cell tower.

Signed:

Mike Allen
795
REGARDING THE AMERICAN TOwER

Signed:

Michelle Allen
796
REGARDING THE AMERICAN TOwER

Signed:

Diane Van Mierlo
797
REGARDING THE AMERICAN TO\v"ER

RANCHO SAN CLEMENTE
By signing, I am a concerned resident and opposed to
any new tower use and will fight for our property
values, security, health, inclusion in planning and
other concerns. I also oppose the antenna citing
Ordinance 1690 that prohibits telecommunication
companies from placing _cell towers within 500 feet
of a school or residence, or within 300 feet from
another cell tower.

Signed:

Chris Van Mierlo
798
REGARDING THE AMERICAN TO'w'ER

Signed:

Mark Moran
799
REGARDING THE AMERICAN TOwER

Signed:

Frazier Moran
800
REGARDING THE AMERICAN TO\v'ER

Signed:

Verse Lovullo
801
REGARDING THE AMERICAN TOwER

Signed:

Christian Kockstroh
802

REGARDING THE AMERICAN TOWER

Signed:

Dana Kotte
803
REGARDING THE AMERICAN TO \v'ER

Signed:

Karen Olvera
804
REGARDING THE AMERICAN TO\v"ER

Signed:

Laurie Melb
805
REGARDING THE AMERICAN TO\v'ER

Signed:

Michelle O'Neill
806

REGARDING THE AMERICAN TOWER

RANCHO SAN CLEMENTE
By signing, I am a concerned resident and opposed to
any new tower use and will fight for our property
values, security, health, · inclusion in planning and
other concerns. I also oppose the antenna citing
Ordinance 1690 that prohibits telecommunication
companies from placing cell towers within 500 feet
of a school or residence, or within 300 feet from
another cell tower.

Signed:

Paul O'Neill
807
REGARDING THE AMERICAN TO \v'ER

Signed:

Daniel Simmons
808
REGARDING THE AMERICAN TO\v'ER

RANCHO SAN CLEMENTE
By signing, I am a concerned resident and opposed to -
any new tower use and will fight for our property
values, security, health, inclusion in planning and
other concerns. I also oppose the antenna citing
Ordinance 1690 that prohibits telecommunication
companies from placing cell towers within 500 feet
of a school or residence, or within 300 feet from
another cell tower.

Signed:

Lynn Simmons
809

REGARDING THE AMERICAN TOWER

Signed:

Gerard Sabat
810
REGARDING THE AMERICAN TO\v'ER

RANCHO SAN CLEMENTE
By signing, I am a concerned resident and opposed to
any new tower use and will fight for our property
values, security, health, inclusion in planning and
other concerns. I also oppose the antenna citing
Ordinance 1690 that prohibits telecommunication
companies from placing cell towers within 500 fe~t
of a school or residence, or within 300 feet from
another cell tower.

Signed:

Bob Carson
811
REGARDING THE AMERICAN TO \v'ER

Signed:

Denise Carson
812

REGARDING THE AMERICAN TOWER

Signed:

Danielle Carson
813
REGARDING THE AMERICAN TO\vER

RANCHO SAN CLEMENTE
By signing, I am a concerned resident and opposed to
any new tower use and will fight for our property
values, security, health, inclusion in planning and
other concerns. I also oppose the antenna citing
Ordinance 1690 that prohibits telecommunication
companies from· placing cell towers within 500 feet
of a school or residence, or within 300 feet from
another cell tower.

Signed:

Jerry Holdner
814
REGARDING THE AMERICAN TO\v'ER

RANCHO SAN CLEMENTE
By signing, I am a concerned resident and opposed to
any new tower use and will . fight for our property
values, security, health, inclusion in planning and
other concerns. I also oppose the antenna citing
Ordinance 1690 that prohibits telecommunication
companies from placing cell towers within 500 feet
of a school or residence, or within 300 feet from
another cell tower.

Signed:
815
REGARDING THE AMERICAN TO\v'ER

Signed:

Karen Dugan
816
REGARDING THE AMERICAN TO'w'ER

Signed:

Sharon McKinstry
817
REGARDING THE AMERICAN TO \v'ER

Signed:

Jenny Langrell
818
REGARDING THE AMERICAN TO\.v'ER

Signed:

Joel Rumerman
819
REGARDING THE AMERICAN TO 'w'ER

Signed:

Shawn Nelson
820
REGARDING THE AMERICAN TO\v'ER

Signed:

Karen Savas
821
REGARDING THE AMERICAN TO'v/ER

RANCHO SAN CLEMENTE
By signing, I am a concerned resident and opposed to
any new tower ·use and will fight for our property
values, secur.ity, health, inclusion in planning and
other concerns. I also oppose the antenna citing
Ordinance 1690 that prohibits telecommunication
companies from placing cell towers within 500 feet
of a school or residence, or within 300 feet from
another cell tower.

Signed:

Jon Savas
822
REGARDING THE AMERICAN TO 'w'ER

Signed:
823
REGARDING THE AMERICAN TO \v'ER

RANCHO SAN CLEMENTE
By signing, I am a concerned resident and opposed to
any new tower use and will fight for our property
values, security, health, inclusion in planning and
other concerns. I also oppose the antenna· citing
Ordinance 1690 that prohibits telecommunication
companies from placing cell towers within 500 feet
of a school or residence, or within 300 feet from
another cell tower.

Signed:

Dan Goldstine
824
REGARDING THE AMERICAN TO'w'ER

Signed:

Karinne Nelson
825

REGARDING THE AMERICAN TOWER

RANCHO SAN CLEMENTE
By signing, I am a concerned resident and opposed to
any new tower use and will fight for our property
values, security, health, inclusion in planning and
other concerns. I also oppose the antenna citing
Ordinance 1690 that prohibits telecommunication
companies from placing cell towers within 500 feet
of a .school or residence, or within 300 feet from
another cell tower.

Signed:

Jose Lavenant
826
REGARDING THE AMERICAN TO'v/ER
• RANCHO SAN CLEMENTE
By signing, I am a concerned resident and opposed to
any new tower use and will fight for our property
values, security, health, inclusion in planning and
other concerns. I also oppose the antenna citing
Ordinance 1690 that prohibits te.lecommunication
companies from placing cetl towers within 500 feet
of a school or residence, or within 300 feet from
another cell tower.

Signed:

Maria Lavenant
827
REGARDING THE AMERICAN TO \v'ER

Signed:

Dorothy (Dolly) Erickson
828
REGARDING THE AMERICAN TO\v'ER

Signed:

Lance Erickson
829
REGARDING THE AMERICAN TO'w'ER

RANCHO SAN CLEMENTE
By signing, I am a concerned resident and opposed to
any new tower use and will fight for our property
values, security, health, inclusion in planning and
. other concerns. I also oppose the antenna citing
Ordinance 1690 that prohibits telecommunication
companies from placing cell towers within 500 feet
of a school or residence, or within 300 feet from
another cell tower.

Signed:

Larry Woenka
830
REGARDING THE AMERICAN TO'v/ER

Signed:

Tina Johnson
831
REGARDING THE AMERICAN TO'v/ER

Signed:

Samira Gonzalez
832
REGARDING THE AMER!CAN TO\v'ER

Signed:

Marco Gonzalez
833
REGARDING THE AMERICAN TO\v'ER

Signed:

Caria Dack
834
REGARDING THE AMERICAN TOv/ER

Signed:

Martin Dack
835
REGARDING THE AMERICAN TO\v'ER

RANCHO SAN CLEMENTE
By signing, I am a concerned resident and opposed to
any new tower use and will fight for our property
values, security, health, inclusion in planning and
ot_her concerns. I also oppose the antenna citing
Ordinance 1690 that prohibits telecommunication
companies from placing cell towers within 500 feet
of a school or residence, or within 300 feet from
another cell tower.

Signed:

Elizabeth Friedl
836
REGARDING THE AMER!CAN TO'v/ER

Signed:

Richard Friedl
837
REGARDING THE AMERICAN TO\v'ER

Signed:

Monica Golden
838
REGARDING THE AMERICAN TO\v'ER

Signed:

Peggy Lobdell
839

REGARDING THE AMERICAN TOWER

Signed:

Lori Sanders
840

REGARDI G THE AMERICAN TOWER

RANCHO SAN CLEMENTE
By signing, I am a concerned resident and opposed to
any new tower use and will fight for our property
values, security, health, inclusion in planning and
other concerns. I also oppose the antenna citing
Ordinance 1690 • that prohibits telecommunication
companies from placing cell towers within 500 feet
of a school or residence, or within 300 feet from
another ce-11 tower.

Signed:

Kent Sanders
841
REGARDING THE AMERICAN TOwER

Signed:

Joel Hutak
842
REGARDING THE AMERICAN TO\v'ER

Signed:

Melia Hutak
843
REGARDING THE AMERICAN TO'v/ER

Signed:

Gregory Lewis
844
From:

To:

Cc:

Subject:

Date:

Aramiao Adam
C".ampagnolo Laura
Jimenez Memm • l IA btfoot Jonathan FW: City Councll• Dec S• ltem IOB •American Tower Hearing Monday, December 4, 2023 5:07:01 PM
FYI on public comment sent to CC regarding item lOB.

Sincerely,
Adam Atamian
Community Development Director
p· (949) 361-6196
atamiana@san-clemente erg
~ Please COn.5ider the erwiroomenl be.fore prlntJng trus e-mai l From: Vonne Barnes
Sent: Monday, December 4, 2023 1:29 PM
To: CityCouncil Mail <[email protected]>; Hall, Andy <[email protected]> Cc: Atamian, Adam <AtamianA@sa n-clemente.org>; Lim, Jonathan <[email protected]>; Sharp Sheryl <[email protected]>; Vonne Barnes
Subject: City Council• Dec 5• Item lOB •American Tower Hearing City Council Members and Andy Hall.

Many residents have come forth with ATC violations of the 1962 Penni! that warrant a public hearing for Coun ii review.

Please approve a public hearing fur this purpose.

Respectfully,
Venne Barnes
RSCCA Board President
845
American Tower Non-Compliance
• 1962 Conditional Use Permit
• Public Resource Code 4291 a
• Rancho San Clemente Specific Plan
• Hillside Ordinance & Building Code
Approval sets a city
precedent to allow
towers in fire-prone
areas close to homes.
846
From:

To:

Subject:

Date:

Neeti Bahadur
Hall. Andy: CityHall Mail
Agenda item 10b
Monday, December 4, 2023 4:18:07 PM
City Council Members and Andy Hall,
Many residents have come forth with ATC violations of the 1962 Permit that warrant a public hearing for Council review.

Please approve a public hearing for this purpose.

Respectfu I ly,
neeti bahadur
-
Resident of Harbor View Estates HOA
847
From:

To:

Subject:

Date:

Lisa Bothwell
Hall. Andy: CityHall Mail
Agenda Item 10B
Monday, December 4, 2023 3:22:27 PM
City Council Members and Andy Hall,
Many residents have come forth with ATC violations of the 1962 Permit that warrant a public hearing for Council review.

Please approve a public hearing for this purpose.

Respectfu I ly,
Cameron & Lisa Bothwell
Resident of Harbor View Estates HOA
848
From:

To:

Subject:

Date:

Jim Fitzpatrick
Hail. Andy: CityHall Mai!
Agenda Item 108
Monday, December 4, 2023 3:06:36 PM
City Council Members and Andy Hall,
Many residents have come forth with ATC violations of the 1962 Permit that warrant a public hearing for Council review.

Please approve a public hearing for this purpose.

Respectfully,
James F. Fitzpatrick
Resident Harbor View Estates HOA
Sent from my iPhone
849
From:

To:

Subject:

Date:

Attachments:

Jennifer Fitzpatrick
CjtyHall Mail: Hall, Andy
Agenda Item 10B
Monday, December 4, 2023 2:28:36 PM
1maae001.ona
City Council Members and Andy Hall,
Many residents have come forth with ATC violations of the 1962 Permit that warrant a public hearing for Council review.

Please approve a public hearing for this purpose.

Respectful ly,
Jim & Jennifer Fitzpatrick
San Clemente
Resident of Harbor View Estates
Jennifer Fitzpatrick I Project Manager
HOLLAND ca•s.Ta .. ,,-,:0111
Main Office: 5000 E. Spring Street, Long Beach, CA 90815 Jobsite Office : 225 West B Street, San Diego, CA 92101 Project Address: 220 West Broadway, San Diego, CA 92101 Cell: I Fax:
850
From:

To:

Subject:

Date:

Importance:

Beth Foskett
CityHaJI Mail
ATC Violations and Request for Critical Public Hearing
Monday, December 4, 2023 1:16:41 PM
High
City Council Members and Andy Hall,
Many residents have come forth with ATC violations of the 1962 Permit that warrant a public hearing for Council review.

Please approve a public hearing for this purpose.

Respectfully,
Beth Foskett, HOA Board Member-Harbor View Estates
851
From:

To:

Subject:

Date:
kiley riggs
Hall. Andy: CityHall Mail
Agenda item 10b
Monday, December 4, 2023 1:07:40 PM
City Council Members and Andy Hall,
Many residents have come forth with ATC violations of the 1962 Permit that warrant a public hearing for Council review.

Please approve a public hearing for this purpose.

Respectfully,
Kiley Riggs
Resident of Harbor View Estates HOA
...

Sent from my iPhone
852
From:

To:

Subject:

Date:

Lindsay Armstrong
Hall Andy: CityHall Mail
Agenda item 10B
Monday, December 4, 2023 1:04:48 PM
City Council Members and Andy Hall,
Many residents have come forth with ATC violations of the 1962 Permit that warrant a public hearing for Council review.

Please approve a public hearing for this purpose.

Thank You,
Lindsay Armstrong
Resident of Harbor View Estates HOA
853
From: Mike Blackwell
To: CityHall Mall; [email protected]
Subject: December 5th City Council Meeting to Consider Item 10B_Resolution No. 23-159 Date: Monday, December 4, 2023 12:51:24 PM
City Council Members and City Manager,
Regarding the upcoming City Council meeting on December 5, 2023, council will consider a resolution will be consider as summarized below. In addition to staffs recommendations, please consider that many residents have come forth with concerns about the facility approved in 1962 and the violations that have occurred the property. We now have an opportunity to correct something that has negatively impacted not only the adjacent residents but our entire city for many years. The opportunity before you now will give the owner a way to bring its property into compliance as well as allow the community to be a part of redesign of the property in a way that meets all of the development standards and integrate into the character of the community which it is intended to serve.

Please restore our community's confidence in our leadership and approve a public hearing for the reasons summarized as follows:

1. The County of Orange approved Conditional Permit ("CP") 1021 in 1962 to permit the establishment of a microwave relay station in connection with a public telephone service at 616 Del Dios, Assessor's Parcel Number 690- 552-05 ("Property"), The "CP" or "Use" was approved and intemfod for wireless and public communication services.

2. March 19, 2020, City staff denied an Eligible Facilities Request (EFR) for a collocation of wireless transmission equipment at the Property; Subsequent requests for collocation were rejected as the originally intended use was no longer valid.

3. American Tower Management, LLC ("ATC") entered into a Voluntary Compliance Agreement "Agreement" with the City on or about July 6, 2023 to reduce the height of the lattice tower back to the 70-foot height stated within CP 1021; The "Agreement" was based on statements made by the applicant that led the city to believe the use was valid and without violation. Part 11 of the "Agreement" provides an opportunity to terminate the agreement and reestablish the use.

4. The City issued building permit B23-1495 on August 30, 2023 to reduce the height of the existing tower from 137.6' to 70' measured from the existing adjacent grade to the highest appurtenance affixed to the tower; Again, the permit was issued based on a statement made by the applicant that confirmed the continued and valid use of the property pursuant to the original grant. The corrected height was based on the original CUP that allowed an extension of height up to 35' above the allowable height for the zone. A height of 70' would not be allowed under today's standards under the County of Orange and City of San Clemente.

5. Dish Wireless submitted an Eligible Facilities Request (Wireless Screening Form WMS 23-231) to collocate equipment on the reduced-height tower on 854
July 10, 2023 with revisions submitted on August 31, 2023, which rely on the validity of CP 1021; As a matter of proper practice, Dish Wireless should have independently confirmed the validity of the use upon which their request for expedited review without public hearing under the Middle Class Tax Relief ACT Section 6409 was based rather than relying solely on the statement made by a hopeful and non-compliant fam:Uord.

6. During public comment at the City Council Meeting on October 17, 2023 and at a Joint Study Session of the Planning Commission and City Council on November 8, 2023, the City received public testimony that: (1) called into doubt the validity of the Applicant's assertion that the facility is eligible for streamlining under Section 6409 of the Spectrum Act ( 4 7 U.S.C. § 1455(a), 47 C.F.R. § 1.6100); (2) suggested that the Owner and Applicant had provided incorrect, false or misleading information to the City; (3) indicated that the Property was not maintained in conformance with the applicable conditions of approval; and ( 4) alleged a history of nuisance activity at the Property; For, but not limited to these reasons, the City must invalidate the "Agreement" made in July 2023 as well as revoke the permits recently issued. Further, the City nmst require that if the property owner wishes to exercise its right to use the property, a new use permit must be established under the current rules of the day.

7. The San Clemente Municipal Code (SCMC) provides a process by which the City may change or revoke approved applications (Section 17.12.175) and that existing approvals are deemed to have lapsed if they are inactive for a period of at least one year (Section 17 .12.150). Unless adequate proof that the intended wireless communications use (by an FCC licensee) had never lapsed for greater than what either County of Orange or City of San Clemente considers a legal lapse in use, a new request for wireless telecommunications must be re-established through a new use permit with an of the legal findings made. Such proof could include, finalized building permits, electric and telco meter history and other compliance and :FCC filings.

Thank you for your consideration.

Mike Blackwell
San Clemente Resident
855
From:

To:

Cc:

Subject:

Date:

David Armstrong
CityHall Mail
Hall. Andy
Agenda Item 108
Monday, December 4, 2023 12:21:57 PM
City Council Members and Andy Hall,
Many residents have come forth with ATC violations of the 1962 Permit that warrant a public hearing for Council review.

Please approve a public hearing for this purpose.

Respectfu I ly,
David Armstrong
Resident of Harbor View Estates HOA
856
From:

To:

Subject:

Date:

Agenda Item 10B
Sam Houghton
Hall. Andy: CityHa!I Mail
Agenda Item 108
Monday, December 4, 2023 12:30:42 PM
City Council Members and Andy Hall,
Many residents have come forth with ATC violations of the 1962 Perm it that warrant a public hearing for Council review.

Please approve a public hearing for this purpose.

Thanks
Sam Houghton
-
Harbor View Estates

SAM HOUGHTON
License Number: 0772408
Producer
Venture Pacific Insurance Services
111 CORPORATE DRIVE, SUITE 200, LADERA RANCH, CA 92694
857
From:

To:

Subject:

Date:

Brandon Riggs
Hall. Andy: CityHall Mail
Agenda Item 10B
Monday, December 4, 2023 12:20: 13 PM
City Council Members and Andy Hall,
Many residents have come forth with ATC violations of the 1962 Permit that warrant a public hearing for Council review.

Please approve a public hearing for this purpose.

Respectfu I ly,
Brandon Riggs
Resident of Harbor View Estates HOA

BRANDON RIGGS
License Number: 0D43203
President
Venture Pacific Insurance Services
111 CORPORATE DRIVE, SUITE 200, LADERA RANCH, CA 92694
858
From:

To:

Subject:

Date:

Bert Levesgue
QtyHall Mail: [email protected]: Loeffler. Rick: Knoblock sreve: Enmeier. Marie Duncan Chris: QibcaJ. Y1ctQr Harbor View - ATC
Monday, December 4, 2023 11:40:25 AM
Gentlemen, please be prepared to review and discuss the ongoing issue with the Tower at Harbor View, specifically to address the many residents that have come forth wit h ATC violations of the 1962 Permit that warrant a public hearing for Council review, the validity of the 1962 CUP and how poorly ATC has misrepresented its continuous use, not adhering the CUP to begin with, using pri vate streets and our police to bully residents whi le it's on our property and the gross negligence it has shown maint aining their property at the expense of the residents. Please approve a public hearing for this purpose. Thank you.

BTW, I really like the Mayor Duncan's shorts and rainbows at the Pickleball awards ... representing San Clemente perfectly!
Bert Levesque I Vice President
5000 E. Spring St., Suite 500 I Long Beach, CA 90815
Direct: I Fax: ■■■■ 1 Cell:
1>[email protected]
ATTACHMENT 9
Public Comments Received After December 5, 2023 City Council Meeting 859
P: (626) 314-3821
F: (626) 389-5414
E: [email protected]
Mitchell M. Tsai
Law Firm
139 South Hudson Avenue
Suite 200
Pasadena, California 91101
VIA E-MAIL and PERSONAL SERVICE
January 4, 2024
Jonathan Lightfoot, City Planner
City of San Clemente
910 Calle Negocio, Suite 100
San Clemente, CA 92673
P: (949) 361-8254
E: [email protected]
E: [email protected]
E: [email protected]
E: [email protected]
E: [email protected]
E: [email protected]
County of Orange
County Administration North
400 West Civic Center Drive
Santa Ana, CA 92701
P: (855) 886-5400, (714) 744-2211
E: [email protected]
American Tower Management, LLC
VIA: Allen Matkins Leck Gamble Mallory & Natsis LLP
ATTN: Emily L. Murray
865 South Figueroa Street, Suit 2800
Los Angeles, CA 90017
P: (213) 622-5555
E: [email protected]
DISH Wireless LLC
ATTN: Timothy A. Messner
9601 South Meridian Boulevard
Englewood, CO 80112
DISH Wireless LLC
VIA: Tower Engineering Professionals
Kellie Stremme, Site Acquisition Agent
860
City of San Clemente, 616 Del Dios Wireless Communications Facility – Notice of Intent to Sue January 4, 2024

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San Clemente City CouncilJanuary 16, 2024

San Clemente City Council
January 16, 2024