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Pleasanton Planning Commission <br /> February 19, 2019 <br /> Page 6 of 6 <br /> Application Procedures Must Comply with New Shot Clock Rules. <br /> Where the Draft Policy limits batching of applications to five facilities of similar <br /> design, the FCC does not limit the number of small cells or the specific designs that can <br /> be batched under one application, and Shot Clock rules contemplate a mix of existing and <br /> new structures under one batch application. Draft Policy § 2.3(c); 47 C.F.R. § <br /> 1.6003(c)(2). We note that as the FCC confirmed that the Shot Clock commences upon <br /> any mandatory pre-application procedure, Verizon Wireless will calculate the Shot Clock <br /> to commence upon the day it requests a required application appointment. Draft Policy § <br /> 2.3(a)(1); 47 C.F.R. § 1.6003(e). <br /> Numerous Draft Policy requirements are unreasonable in contradiction of the <br /> FCC's directives or inconsistent with state law regarding use of the right-of-way. <br /> Standards should allow for typical right-of-way small cells with pole-mounted <br /> equipment, including on utility poles,with no unreasonable requirements for <br /> undergrounding equipment or shrouding of all antennas. We urge you to direct staff to <br /> work with industry on needed revisions to the Draft Policy. <br /> Very truly yours, <br /> Paul B. Albritton <br /> cc: Julie Harryman, Esq. <br /> Ellen Clark <br /> Gerry Beaudin <br />