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Attachment 14 Public Comment Letter dated 11112025

Union City City Council
November 13, 2025

Document
Attachment 14 Public Comment Letter dated 11112025
Meeting
November 13, 2025
Body
Union City City Council
Original file
1.8 MB
Text extracted from the city's file for reading and search. Open the original on unioncity.primegov.com. That file is the official record.

Note, AT&T already provides their publicly available coverage map here:
https://www.att.com/maps/wireless-coverage.html
From what they're declaring on their public website, which has legal marketing requirements to be correct, there are no holes or gaps in 5G+ coverage in Union City. If they have new data that shows holes or gaps in coverage, they should provide this new data.
- Reminder that the CEQA exemption stated in the Planning Commission resolution (and not by me) was specifically Section 15303. And given the oversize total square footage of the project beyond the Exemption's stated 2500 sq. ft., the Exemption is invalid, and should be considered as enough reason to deny the current Project as it exists.

As you mentioned, it would be great to have a neighborhood coffee chat or update in the coming weeks.

We can coordinate folks to come down to the nearby City Offices if that works best.Thanks again for your help in representing the Residents and making sure Union City gets the best infrastructure it deserves, and not the easiest.

Eugene
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On Tuesday, November 4, 2025 at 08:32:30 PM PST, Eugene Ho wrote:

Mayor Singh, Councilmember Nishihira, Coucilmember Patino, Councilmember Wang, and Vice Mayor Sakakihara:

I just finished watching the Appeals Hearing for the Wireless Communications Facility proposed in our neighborhood. I wish I was able to join in person alongside my fellow neighbors, but I've been out of town.

Thank you for representing our concerns and asking your pointed questions to the Applicant. I appreciate the move to continue the Hearing, pending investigation of an alternative solution of the monopole on the corner of Dowe and Alvarado-Niles. This would be a step in the right direction.

I would like to provide some feedback to the current proposal of exempting monopoles restrictions on all PI zoned sites. The Applicant asked if the exemption was for just this site and application, or for all sites.

It seemed the Planning Commission was quick to respond, saying it would be city-wide, and not opt for a lower-risk, project-only exemption. I would recommend if the monopole on the corner of Dowe and Alvarado-Niles was to be selected and approved, it should be only for this site, to reduce future conflicts and exposure across the remaining PI sites and neighborhoods across the City. The Applicant seemed openly enthusiastic about potentially deploying large monopoles in every PI zone across the City in the future under this new proposed amendment and loophole.

More importantly, I would like to suggest another option, as Councilmember Nishihira may have been leaning towards earlier in the hearing around the quality of the Alternative Sites Analysis, that it was incomplete, lacks transparency, and is likely missing better alternatives than what has been presented. If taller monopoles are within the zoning codes of industrial areas, and the Applicant is recommending anything within 1/2 mile of wherever the other cell locations are, per my earlier mails (different thread with the Planning Commission), there are an abundance of commercial and industrial sites from AlvaradoNiles to Whipple, and between Hop Ranch and Western - I'm sure you all know. Surely there is space for an appropriate monopole in that vast area, starting just across the street? Even public land, e.g. the US Post Office? And if the Applicant is unable to contact relevant property managers or owners, can our Union City Development Office help with these contacts? If the City can issue business permits, surely we can find the right people to address?
Also, in Councilmember Wang's defense, all the neighborhood concerns about the health effects of strong antennas so close to bedroom windows are justified. The Applicant regularly stated that via their peer review, everything is within FCC guidelines, but as the Planning Commission acknowledged, no data was actually submitted. So the approval was based on, "trust us, but we won't show you our work, reviewed by people we paid." Per my other mail (different thread), the Applicant confirms that given the orientation and distance of these 9 antennas to the adjacent homes, exposure will be at 83-85% of maximum, or excessive, radiation levels, as measured against Office of Engineering and Technology Bulletin 65, aka OET-65. The Bulletin was not provided, but I was able to locate it here (see Appendix A, p. 67 for exposure level limits):
https://transition.fcc.gov/oet/info/documents/bulletins/oet65/oet65.pdf What the Applicant does not include is that exposure levels in OET-65 are defined at most with 30 min. of exposure. Per Sunny Talwar's questions at today's meeting, whose 2nd bedroom windows would be facing directly at the site at eye level, is how exposure risks are determined with 24/7 exposure, not just 30 min. It cannot be accepted at face value that the Applicant is being sincere with their statements or thorough with their analyses that everything is compliant with FCC guidelines without releasing the data to back it up. Note, the Applicant had already provided in their earlier material that David Allen Burgess was their consultant who performed their RF Emissions Evaluation. As you saw, David Burgess responded via video on today's call. But there was no account by him on RF exposure or safety. Any subsequent site reviews must include released analysis around RF exposure risks, and reviewed by an independent resource or agency.

Lastly, Councilmember Patino's concerns about litigation by the Applicant if a permit denial is actioned must be considered. But as outlined below in this thread, the permit relies on a CEQA exemption that should be invalid in this case, as the site size is beyond the exemption limits. Per CEQA Section 15303, an exemption is limited to 2500 sq. ft. The combined project size is 2679 sq. ft. So the City would have grounds for denial outright, pending complete CEQA compliance. From today's meeting, the Planning Commission said this objection was reviewed, and did not apply, but they did not provide more information around their conclusion. I think this exemption invalidation needs to be reconsidered more closely, and more transparently.

Thank you All again for your support in making sure Union City does the right thing as best it can for its people. This is the Leadership our City needs and deserves.

Eugene Ho and Jean Hsien
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On Monday, November 3, 2025 at 09:33:34 PM PST, Eugene Ho > wrote:

Hi, Thai:

Please add to the the public record an additional written public comment:

The original hearing proposal for Use Permit (UP-25-001), Site Development Review (SD-25-001) - Southern Alameda County Buddhist Church, that was approved during the October 16 Public Hearing, included:

Staff Is Recommending This Project Be Considered Categorically Exempt from the California Environmental Quality Act (CEQA) under Section 15303, New Construction or Conversion of Small Structures, of the CEQA Guidelines
The exemption details are here:
https://govt.westlaw.com/calregs/Document/I8CE6FB435B4D11EC976B000D3A7C4BC3? viewType=FullText&originationContext=documenttoc&transitionType=CategoryPageItem&contextData= (sc.Default)&bhcp=1
The relevant sections to the exemption are:

Class 3 consists of construction and location of limited numbers of new, small facilities or structures; installation of small new equipment and facilities in small structures; and the conversion of existing small structures from one use to another where only minor modifications are made in the exterior of the structure. The numbers of structures described in this section are the maximum allowable on any legal parcel. Examples of this exemption include but are not limited to:
(c) A store, motel, office, restaurant or similar structure not involving the use of significant amounts of hazardous substances, and not exceeding 2500 square feet in floor area. In urbanized areas, the exemption also applies to up to four such commercial buildings not exceeding 10,000 square feet in floor area on sites zoned for such use if not involving the use of significant amounts of hazardous substances where all necessary public services and facilities are available and the surrounding area is not environmentally sensitive.

Note, the proposed new Wireless Carrier Facility includes:
... Construction of a New 2,320 Square-Foot Roof-Mounted Enclosure and a 359 Square-Foot Equipment Ground-Mounted Enclosure.

So 2,320 + 359 = 2,679 sq. ft., is beyond and exceeds the 2500 sq. ft. allowed for an exemption. So the exemption would be invalid, and the Approval from October 16 should be revoked. Subsequent actions should include all required studies and reports as required by the California Environmental Quality Act, to ensure, as the California Governor's Office of Land Use and Climate Innovation states:
... public agencies to “look before they leap” and consider the environmental consequences of their discretionary actions.

Details of the CEQA are here:
https://lci.ca.gov/ceqa/
Thank you.

Eugene Ho and Jean Hsien
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Jingchun Wang
James Brand
Mina Sharma
David Lill
Janet Strickler
Peidong Chen
Geraldine D.

Bonnie Han
Anjana Bai
Minhajur Mohammed
Stiven Shi
Christine Chen
Thitipoon Tang
Sonny Mamari
Mohammad Rahman
Sreenivasa Rao
Kristine Arao

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