St Vincent High 2021 Wireless Telecommunications Facility Application

Link to Commscope NNV4SSP-360S-F4 Antenna Specifications

Frequencies MHz	Gain dBi	Power Ratio	Max Input Watts	Subtotal Output Watts ERP	Qty Ports	Total Output Watts ERP	Ports
696-896	5.45	3.5	75	262.5	2	525	R1
696-896	5.45	3.5	75	262.5	2	525	R2
1695-2690	8.33	6.8	75	510	2	1020	Y1
1695-2690	8.33	6.8	75	510	2	1020	Y2
1695-2690	8.33	6.8	75	510	2	1020	Y3
1695-2690	8.33	6.8	75	510	2	1020	Y4
3400-3800	6.4	4.4	75	330	2	660	P1
3400-3800	6.4	4.4	35	154	2	308	P2
5150-5925	4.6	2.9	5	14.5	2	29	01
Total: Max ERP Antenna Output Capability						6,127 Watts ERP
With 3 dB override						12,254 Watts ERP

St. Vincent WTF Communications, 2021-2022

Unsafe-at-Any-G: Annotations appear in green boxes, like this.

Subject: New cell tower application submission & new Federal Court Ruling

[Petaluma resident],

Thank you for the information in your email below. I noted the case reference provided at Monday’s City Council meeting and staff will look at this in relation to the work being done to modify the City’s telecommunication ordinance.

With regard specifically to the status of the update to the City’s ordinance, the City is currently reviewing an administrative draft of an updated ordinance and associated procedural policies.

Within the next few weeks staff will have a public review draft to share and solicit comments from the public in advance of presenting the item to the Planning Commission and ultimately the City Council for consideration.

In charting milestones for consideration of the updated ordinance staff recognizes the importance of the public’s engagement and feedback in advance of the Planning Commission’s agenda packet. We anticipate providing several weeks to allow public review and comment ahead of the standard meeting distribution a week before the Planning Commission hearing.

Wire-CA: “Several weeks” means what, exactly? Two weeks? Three? Four? Five? Six? Eight weeks? What is the exact number of days that the public has access to the proposed wireless ordinance before it is heard by the Planning Commission?

Ideally, this would be at least 30-days, 60-days preferable. It seems that the m-Group is making this the minimum number of days possible . . . possibly only 10-14 calendar days. This is what we are talking about . . . the m-Group is consistently on the side of corporations and not the public in this way. We are asking for equal treatment of the public and equal time for presentation every step of the way. That is only fair.

And all this for a proposed wireless ordinance update that is not needed, at all because . . .

We secured the veto of SB.556 on Oct 4, 2021, and
FCC Order 18-133 is only a presumptive order: a statement of FCC guidance that they and the Wireless industry wishes to happen.
FCC Order 18-133 does not have the force of law.

We know that because the FCC admitted as much in Federal Court on Feb 10, 2020 in Oral arguments in Case No. 18-72689 City of Portland et al. v FCC:

Feb 10, 2020 Oral Arguments by Scott Noveck, FCC Attorney:

https://youtu.be/zoZHNSOibmo?t=35m05s

“The Order doesn’t purport to prevent localities from addressing reasonable aesthetic requirements. In fact we say in the small cell order that aesthetic requirements are permitted . . . a locality could say if a 50-foot pole would be out of character with the surrounding neighborhood, you can’t put up a 50 foot pole.”

https://youtu.be/zoZHNSOibmo?t=37m47s

“Localities are still free to craft their own substantive aesthetic requirements”

https://youtu.be/zoZHNSOibmo?t=38m28s

“These Orders [FCC 18-111 and FCC 18-133] are not self-enforcing. They contemplate the need, in many circumstances, for further case-by-case adjudication and in those instances either someone would have to come back to the Commission or go into court.”

https://youtu.be/zoZHNSOibmo?t=40m21s

“Nothing in this order is self-enforcing.”

https://youtu.be/zoZHNSOibmo?t=40m52s

“Anyone of these specific factual disputes that arise, this Order is designed to provide some clarity and narrow the scope of disputes . . . when there are remaining disputes, nothing about this order is self-enforcing.”

https://youtu.be/zoZHNSOibmo?t=51m44s

“These small cells, though they have much less range than macro towers, they have a fair range.”

As soon as that public review draft is available, staff will post the draft on the City’s website and provide public notice to interested members of the public. The updated ordinance and associated policies is being reviewed for consistency with all applicable state and federal requirements while maximizing the City’s local discretion to consider wireless applications.

Wire-CA: We all recognize that City Attorney Eric Danly and the m-Group have not consulted with its residents (including nationally-recognized Telecom subject matter experts) in crafting this ordinance. Apparently, Danly only worked with Telecom Law Firm’s Tripp May who works for a firm that admitted it is in the Wireless Industry.

Jonathon Kramer says all you need to know about the toxic agent/pollutant called pulsed, data-modulated, Radiofrequency Electromagnetic Microwave Radiation (RF-EMR) — at 30:03-31:25.

“I consider ourselves part of the Wireless Industry . . . Don’t use the term, radiation— it’s technically, absolutely, the most accurate word and it scares the ‘bejesus’ out of people . . . please stop using the R-word. The R-word is the F-word to us because it just makes our job in trying to get small cells approved much more difficult because that’s the trigger word . . . use any other word, emissions, transmissions, any missions you want, but don’t use the R-Word.”

Kramer: Fast, fast, fast . . . (even if there are incomplete applications) at 38:50-39:03

“You want to get the project done as fast as we do, which, by the way is really what we want . . . We like to see projects pushed through and get deployed . . . We as project reviewers for jurisdictions have seen where . . . a Professional Engineer’s stamp has been copied off of one set of plans and put on another. It’s illegal . . . and . . . we’ve seen a PE who has stamped the plans with absolutlely no knowledge of the actual facts. That happens surprisingly often.

In response to your inquiry about the current wireless application, the application was submitted by AT&T on behalf of Saint Vincent High School at 849 Keokuk Street for the stated purpose of serving the school.

Wire-CA: The rest of this email looks like boiler plate copied/pasted from Heather Hines’ earlier email, which we already annotated below.

The application materials are available on the City’s website at the following link:

https://cityofpetaluma.org/849-keokuk-street-att-telecommunications-facility/

The application as submitted is for a five-foot tall telecommunication facility on the roof of an existing building on the school property. The application was initially submitted as an Administrative SPAR application but consistent with the discretion afforded by the City’s telecommunication ordinance the project has been referred to the Planning Commission for consideration at a future public hearing instead of an administrative process.

Staff has requested a number of items to allow for a complete review of the application, including revised site plans, a revised facility design, an alternative site analysis, a map of the service/network area for the proposed antenna, and documentation verifying the property owner’s consent to the application.

Additionally, staff has informed the applicant that a neighborhood outreach meeting is required prior to solidifying a date for public hearing, consistent with City procedures. Based on the missing information the application remains incomplete for processing and public noticing has not yet occurred based on this application status. Although the project was tentatively targeted for the December 14th Planning Commission meeting that date has not been confirmed based on the missing information as referenced above. Additionally, I believe the applicant has requested additional time to submit requested documentation and that tentative hearing date will likely be pushed into 2022.

A neighborhood outreach meeting will be held and notice of that meeting will be sent to all property owners and occupants within a 1,000 foot radius of the project site. It is my understanding that the applicant has not set a date for the neighborhood outreach meeting but has been notified of the requirement and provided the mailing address labels from the City to ensure that notification is provided consistent with City requirements.

Additionally, mailed public notification will be sent to the 1,000 foot radius list at least ten days prior to the Planning Commission hearing along with a published notice in the Argus Courier. A blue public hearing sign will also be erected on the site to further notice the project to the public.

If you have additional questions specific to this application or processing of this application please contact Planning Manager Erica Baptiste directly (ebaptiste@cityofpetaluma.org) and she will be able to assist.

If there is any further information I can provide at this time please let me know.

Heather

Heather Hines
Interim Community Development Director
City of Petaluma
11 English Street
Petaluma, CA 94952
Direct 707.778.4316

———- Forwarded message ———
From: Hines, Heather hhines@cityofpetaluma.org
Date: Wed, Nov 3, 2021 at 8:11 AM

Subject: Re: Cell tower at St. Vincent’s?? and free webinar on cellphone & cell tower radiation health effects

Dear [Petaluma Resident],

Thank you for the detail regarding today’s webinar as well as other information in your email below.

The current wireless application was submitted by AT&T on behalf of Saint Vincent High School at 849 Keokuk Street for the stated purpose of serving the school.

Unsafe-at-Any-G: Stated purpose and real purpose are often different things. If the purpose is to serve the school only, why does the antenna have the capability of sending signals powerful enough for telecommunications service out over a five-mile radius from the school?

The application materials are available on the City’s website at the following link:

849 Keokuk Street – AT&T Telecommunications Facility

The application as submitted is for a five-foot tall [wireless] telecommunication facility on the roof of an existing building on the school property.

The application was initially submitted as an Administrative SPAR application but . . .
consistent with the discretion afforded by the City’s telecommunication ordinance the project
[the project] has been referred to the Planning Commission for consideration at a future public hearing instead of an administrative process.

Unsafe-at-Any-G: This is the current Petaluma Wireless Ordinance working on behalf of Petaluma residents. The proposed changes to the Wireless Ordinance should not allow administrative/ministerial approval of any new installations of wireless antennas. The City’s WTF approval processes need to remain discretionary for Wireless Telecommunications Facilities (WTFs) of any size or any “G”.

Staff has requested a number of items to allow for a complete review of the application, including

revised site plans,
revised facility design, an
alternative site analysis, a
map of the service/network area for the proposed antenna, and
documentation verifying the property owner’s consent to the application.

Additionally, staff has informed the applicant that a neighborhood outreach meeting is required prior to solidifying a date for public hearing, consistent with City procedures.

Unsafe-at-Any-G: This neighborhood outreach meeting has to be carefully structured to benefit to the City of Petaluma’s discretionary process. We have video evidence of Complete Wireless hosting an alleged “community meeting” in Sebastopol in 2018 in which they stated it was a “private meeting” and they then proceeded to bar members of the public from attending or participating in the meeting. A similar travesty cannot be allowed to happen in Petaluma.

Instead, the City of Petaluma needs to rent the space or host the Zoom meeting as a public meeting sponsored by our local government and allow equal time for presentation for proponents and opponents of this project, in addition to any public comment/Q&A time. A reasonable format for this actual community meeting would be as follows:

20 minutes presentation from Complete Wireless/AT&T
20-minute presentation from Wire California/Petaluma-VHP
20-minutes Q&A

Based on the missing information the application remains incomplete

Unsafe-at-Any-G: Incomplete applications cannot proceed to the Planning Commission. All should insist on application completeness before this so-called “small” Wireless Telecommunications Facility (sWTF) starts its deliberations. We will verify if the m-Group has executed its letters to the applicant properly to preserve the maximum time on the shot clock and not fumble the City of Petaluma’s processing time, per CA Bill AB.57.

. . . for processing and public noticing has not yet occurred based on this application status.

Unsafe-at-Any-G: For all WTF applications, the m-Group should post an entry on the City of Petaluma web site on the very first day it receives any communication expressing an applicant’s interest in a WTF location. For this WTF, how many days elapsed from Day One to the publishing of this web page https://cityofpetaluma.org/849-keokuk-street-att-telecommunications-facility/ ? Answer: TBD

Although the project was tentatively targeted for the December 14th Planning Commission meeting that date has not been confirmed based on the missing information as referenced above. Additionally, I believe the applicant has requested additional time to submit requested documentation and that tentative hearing date will likely be pushed into 2022.

Unsafe-at-Any-G: As long as this does not eat up time on the City’s WTF, shot clock that should not be a problem.

A neighborhood outreach meeting will be held and notice of that meeting will be sent to all property owners and occupants within a 1,000 foot radius of the project site.

Unsafe-at-Any-G: Why is “1,000 foot radius of the project site” sufficient? Shouldn’t notice be given to the full radius of the wireless signal broadcast circle for telecommunications service? That would be a five mile radius for notification.

Alternatively, the City could cap the power of the WTF to ensure that its wireless signal broadcast circle for telecommunications service travels no further than its notification requirement: 1,000 feet.

The City and the applicant have to be consistent: notify everyone that would be affected by this WTF. No more double-standards. Full stop.

It is my understanding that the applicant has not set a date for the neighborhood outreach meeting but has been notified of the requirement and provided the mailing address labels from the City to ensure that notification is provided consistent with City requirements.

Unsafe-at-Any-G: Don’t stop there. Also notice the meetings on the home page of the City of Petaluma web site, as well as on any City of Petaluma social media presences on Facebook, Twitter and Nextdoor. This is 2021; most Petalumans DO NOT subscribe to or regularly read the Argus Courier. Petaluma-VHP will be passing flyers out to everyone affected by this WTF.

If there is any further information I can provide at this time please let me know.

Heather

Unsafe-at-Any-G: We have specific questions on how the City of Petaluma is handling the shot clock on this WTF. We would appreciate you returning the calls: we left voicemails for you on Oct 29 and Nov 1 . . . we have not received your return call.

Heather Hines, Interim Community Development Director
City of Petaluma | 11 English Street, Petaluma, CA 94952
Direct 707.778.4316