Item 1.4 - Additional Material posted 8-6-19Glt { OF POIV�y
City of Poway
MEMORANDUM
ADDITIONAL MATERIAL
(Agenda Related Writings/Documents provided to City Council or Staff after distribution of the
Agenda Packet for the August 6, 2019 Council Meeting)
DATE: August 6, 2019
TO: Honorable Mayor and Members of the City Council
FROM: Faviola Medina, CMC, City Clerk ?U
CONTACT: (858) 668-4535 or FMedina(ab-poway.org
SUBJECT: Item 1.4 - Second Reading and Adoption of Ordinance No. 829 entitled "An
Ordinance of the City of Poway, California, Adding Chapter 17.56 to the
Poway Municipal Code Regulating Wireless Communication Facilities."
Attached please find correspondence received on Tuesday August 6, 2019, after the distribution
deadline.
Reviewed/Approved By
Wendy Kaserman
Assistant City Manager
Reviewed By:
Alan Fenstermacher
City Attorney
Approved By:
"4c
Ch 's Haz ine
City Manager
1 of 3 August 6, 2019, Item #1.4
ADDITIONAL MATERIAL
From: Salas. Adrian
To: agendadocs resource
Cc: afenstermacherCalrutan.com: Carol Leaa
Subject: Crown Castle Comments on City of Poway Second Reading and Adoption of Ordinance No. 829 Regulating
Wireless Communications Facilities.
Date: Tuesday, August 6, 2019 12:03:12 PM
Hon. Mayor, City Councilmembers, and staff of City of Poway,
Regarding draft ordinance no. 829, Crown Castle would like to submit the comments below:
First, we thank the City on the collaborative edits made after the first reading which we feel will
make this ordinance stronger, and more practical in the long term. We continue to have objections
and suggestions to the items below:
17.56.060 D-14 Sites are selected to fill gaps in coverage/relieve capacity constraints. Submitting a
justification letter for each site will add extra time and costs to each project, while not advance the
city's siting preferences. Additionally, WCF permitting cannot be more burdensome than what is
required for other users of the Right of Way.
17.56.060 D -1-f: Small WCF installations must comply with FCC levels before they are
installed/energized. We follow FCC guidelines and install equipment that is compliant with all
regulations. Requiring post -installation testing as a part of the permitting process is again unduly
burdensome, costly, and redundant.
17.56.090-A: The City is proposing to prohibit siting WCFs on existing overhead utility poles or lines.
These poles are often used to site WCFs and would greatly reduce the need for new verticality. The
next section, Section B, states that applicants must make all commercially reasonable efforts to
collocate WCFs on existing structures. Removing existing overhead utility poles from the possible
options is directly in conflict with the City's objective to collocate as many sites as possible.
Additionally, when a CPUC Rule 20 (undergrounding) project is declared, those portions to be
undergrounded would not be targeted for siting WCFs, and any existing WCFs would be removed
without impeding undergrounding schedules. We suggest removing Section A, or at minimum
revising language to make utility poles allowable if no other existing support structures can be used.
17.56.090 D-2: WCF siting best practices utilize existing vegetation to assist in the screening
equipment. We recommend removing the clearance and adding the ability to trim vegetation with a
statement from an arborist that trimming will not be detrimental to the tree.
Last, the draft references the City's Master Fee Schedule. We remind the city that the FCC Order
clearly established 'safe harbor' fees for WCF permitting. We ask that the City align the fees
associated with WCF permitting to the FCC Order. Additionally, the required security (17.56.060-F)
amount is not determined. Crown Castle proposes $1,000.00 per site, as is common for projects of
this nature.
We thank the City for the ongoing conversation, and look forward to our continued partnership with
the City.
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ADRIAN SALAS
Government Affairs Manager, San Diego
T:(858) 935-3831
M:(619) 917-6116
CROWN CASTLE
10301 Meanley Dr. Ste. 200 San Diego, CA 92131
CrownCastle.com
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email.
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