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Dan Vuxenllek ATAT MWIlty Area Manager August 21, 2018 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). + 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. U��M I0J