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Santa Ana City Council <br />August 20, 2018 <br />Page 5 of 5 <br />Provisions requiring four to six feet of clearance from private property appear to <br />contemplate ground -mounted cabinets that may block pedestrian travel. Draft Ordinance <br />§ 33-247. However, wireless facilities placed entirely on existing poles are elevated well <br />above the sidewalk, generally at least seven or eight feet, and pose no impediment to <br />pedestrians. These provisions should not apply to pole -mounted equipment. Similarly, <br />pole -mounted equipment is elevated above vehicular sightlines, and Section 33-247(d) <br />should not apply. <br />Many jurisdictions approve underground utility districts that take years to <br />implement or are never realized, and the Draft Ordinance should not require relocation <br />simply upon adoption of a Council resolution establishing a new district. Draft <br />Ordinance § 33-255. Antennas must be elevated to provide service, and small radio <br />boxes sharing the same pole pose little additional visual impact. Wireless facilities are <br />unique among public utility infrastructure, and undergrounding of small wireless <br />equipment should not be required. We suggest that the City exempt wireless facilities <br />that are not on utility poles from this requirement. In the alternative, the City could <br />require wireless carriers to consider relocation of facilities when all other utilities place <br />equipment underground pursuant to an underground district. <br />Conclusion <br />Verizon Wireless appreciates the opportunity for advance review of the Draft <br />Ordinance as well as revisions already incorporated by staff. However, the Draft <br />Ordinance is not ready for introduction by Council because there are still provisions that <br />contradict state and federal law. Under state law, applicants cannot be required to review <br />private property locations or demonstrate a prohibition of service under federal law to <br />place new poles. For both the Draft Ordinance and pending design guidelines, the City <br />should provide objective design standards that accommodate typical small cell facilities. <br />We encourage the City to exempt facilities on City -owned poles from permit <br />requirements. We look forward to working with the City to revise the Draft Ordinance. <br />Very truly yours, <br />aPalbritton <br />cc: Sonia R. Carvalho, Esq. <br />Yasmin Vazquez <br />