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City of Pleasanton City Council February 20, 2019 Page 6 of 6 in the right-of-way under Section 7901, and this requirement is unreasonable and discriminatory. In addition, this requirement steers wireless installations onto city-owned structures in violation of California Government Code Section 65964(c), which prohibits the city from requiring "that all wireless telecommunications facilities be limited to sites owned by particular parties." 16 7. Electric Meters. The proposed prohibition on a separate ground-mounted electric meter pedestal is unreasonable and discriminatory in Section 2.7(b)(13). The need for a separate ground-mounted electric meter pedestal may be driven by the electric service provider. Additionally, the city should limit the use of a shrouded smart meter to the extent it is available. 8. Metal Poles. The requirement that AT&T's new towers,poles, or other freestanding structures"must be made from metal or other composite material capable of concealing all the accessory equipment" in Section 2.7(b)(6) and Section 2.7(c)(5) must also be eliminated because AT&T has the right to install new poles of other materials. Conclusion AT&T appreciates the city's initial efforts to adapt its wireless facility siting regulations to accommodate new and emerging technologies and changes in law. But the city must not enact unreasonable and discriminatory standards, and it must take care to avoid effectively prohibiting AT&T from providing or improving wireless services. By addressing the items we raise here,the city will go a long way toward encouraging deployments consistent with state and federal policies and to the great benefit of the city's residents and businesses. Very truly yours, /s/Jeffrey M Slade Jeffrey M. Slade cc: Daniel G. Sodergren, City Attorney (dsodergren@cityofpleasantonca.gov) 16 Cal.Govt.Code§65964(c).