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0 Dan Vozenilek Area Manager August 21, 2018 AT&T Mobility Taig Higgins, P.E. Transportation and Development Manager City of Santa Ana 20 Civic Center Plaza M-43 P.O. Box 1988 Santa Ana, CA 92702 [ Re: AT&T's repeal and replace Article X of Chapter 33 of Santa Ana's Municipal Code to address telecommunications facilities in the public right-of-way Dear Mr. Higgins: AT&T thanks the city for taking industry input into consideration. AT&T particularly appreciates the city's efforts to streamline reviews of eligible facilities requests (EFRs) under Section 6409(a). 1 AT&T looks forward to working with the city on its design guidelines which will surely impact AT&T's plans to deploy wireless facilities. But we need to see the Guidelines in order to properly comment on the proposed ordinance. o For example, the ordinance refers to "Tier 1", "Tier 2" and "Tier 3" facilities which are not defined in the ordinance, but will be defined in the Guidelines. • The city should eliminate the definition for "concealment element." The city cannot circumvent federal law by defining "concealment element" which is a term of art used by the FCC in its regulations implementing Section 6409(a). Plus, using the term could confuse staff and applicants in the context of EFRs. o Instead, the city should adopt or cross-reference its existing definition of "stealth facility" —See Section 41-198.1 of the Santa Ana Municipal Code. AT&T appreciates the reduction of days in the comment period and the reduced notification radius for small cell facilities, but the city should also establish a streamlined administrative process for approving small cells. o Small cells give residents and businesses access to the latest and greatest wireless technologies while helping to preserve aesthetics because they easily blend with utility infrastructure in rights-of-way. o And with AT&T's selection by FirstNet as the wireless service provider to build and manage the nationwide first responder wireless network, each new or modified facility will enhance first responder communications.