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Pleasanton Planning Commission February 19,2019 Page 5 of 6 in connection with or to facilitate communication by telephone, whether such communication is had with or without the use of transmission wires." State law clearly grants Verizon Wireless the right to place ground-mounted telephone equipment. Ground cabinets are occasionally deployed to enclose batteries that provide continued service during emergencies. Instead of banning ground-mounted cabinets, the City should provide reasonable, non-discriminatory and objective standards for them. Right-of-Way Height Limits May Lead to More Facilities. The Draft Policy limits antennas in the right-of-way to four feet above either a pole itself or any separation distance required by Public Utilities Commission General Order 95 (six feet over electric supply conductors). Draft Policy § 2.7(b)(1). For the right-of-way, the height limit is unreasonable as it would prohibit use of four-foot antennas. Antennas above utility poles require a mount underneath the antenna that attaches the antenna to the pole or pole-top extension. Antenna mounts are conical in shape, one to two feet in height, and conceal cables. As elements associated with antennas, the mounts are also subject to separation requirements of General Order 95 Rule 94. The proposed right-of-way height limits will not accommodate both a four-foot antenna and a mount, limiting wireless carriers to two-foot antennas which generally have a smaller coverage footprint. This will lead to the unintended consequence of more facilities required to serve an area. We suggest a height increase limit of six feet, plus any additional state-mandated safety clearance distance. Antenna Standards are Unreasonable or Subjective. The blanket requirement for shrouding of all small cell antennas contradicts the FCC's directive regarding aesthetic criteria. Draft Policy §§ 2.7(b)(2)(A), 2.7(b)(4-6). The referenced Draft Policy definition of"concealment" includes a subjective criterion to "integrate...into the surrounding natural and/or built environment,"with mention of an "untrained observer." Draft Policy § 1.2(b)(7). Aesthetic criteria for small cells should be objective. Further, antenna shrouds or radomes may impede frequencies recently licensed from the FCC for new wireless technology including 5G service, rendering them technically infeasible and the requirement unreasonable. Any antenna standards for right-of-way facilities must accommodate new higher-frequency facilities that integrate antennas and radios in one small box. We suggest that, at a minimum, any antenna shrouding requirements be qualified by the term"to the extent technically feasible." The Draft Policy errs in limiting cumulative antenna volume to six cubic feet. While the FCC defined small cell to specify individual antennas up to three cubic feet, it did not place limit on total antenna volume. Draft Policy § 2.7(b)(2)(B), 47 C.F.R. § 1.6002(1). The cumulative volume limit must be stricken.