Palos Verdes Estates Affirms Neighborhood Church Cell Tower Denial

Great news, the PVE City Council unanimously affirmed the Planning Commission’s denial of this highly intrusive site at their Jan 24th meeting.  One Councilman summed it up well when he commented how this site seemed to be a test case of the City’s authority; if the City accepted a cell tower in front of this historic church then seemingly nowhere in the city would be off limits.  (For more on the Neighborhood Church check out this post here.)

neighborhood_church_cell_tower_mock-up

Proposed cell tower mock-up on the grounds in front of Palos Verdes Estates’ historic Neighborhood Church

A resident (who will remain nameless) wryly suggested that in addition to the Neighborhood Church Crown Castle might next propose replacement of Neptune’s trident with one of their cell towers.  This famous fountain in Malaga Cove Center is another local icon so it’s apparently fair game too.  Believe it or not, the fountain is actually located in the Public Right of Way according to the L.A. County Assessor’s Office, so we figured we’d help out with the required photo simulation just in case it’s being considered.

neptune_cell_tower

An omen of things to come?  The 5G future we must all enthusiastically embrace according to those who plan on making a lot of money installing cell towers.

Not bad, huh?  Painting the antennas white to tastefully match King Neptune is a nice touch too.  We think the suggestion was tongue-in-cheek but we’ll be on guard nevertheless.  (Ed note: Just to be clear, we’re just trying to make a point here, no one has seriously suggested the fountain be converted to a cell tower!  At least not yet.)

Community Opposition

There was strong community presence speaking in opposition including a representative of the Neighborhood Church itself.  An offer was extended to consider incorporating a stealth implementation into the Church’s structure.  Crown Castle did not respond.  This point was raised during the Planning Commission hearing and Crown Castle rejected it outright, claiming the network was “designed” for the right of way (ROW).  It’s nonsense of course, there is no technical reason the site must be in the ROW.

The real reason is that Crown Castle has no legal obligation to consider any site outside the ROW.  It would seem to be the ideal solution that would satisfy the community, the Neighborhood Church, and the claimed AT&T coverage objectives Crown Castle has made on their behalf.  However, doing so would undermine Crown Castle’s self-proclaimed entitlement to place these in the ROW wherever they please. And we can’t have that.

Fortunately, the City Council understands the stakes and the law, and is taking a very skeptical stance towards Crown Castle’s claims of entitlement and technical justification.  The Mayor asked a series of very tough questions probing how Crown Castle could claim a “significant gap” when other maps submitted over the last fifteen months appeared to show far better coverage and contradicted their claims.  Crown Castle’s answer was non-responsive at best.

The City’s wireless consultant made an interesting and astute observation; the City has repeatedly requested direct AT&T involvement to help clarify these technical inconsistencies.  He further noted that Crown Castle failed to directly engage AT&T in the City process despite numerous requests to do so.  We’re not sure if Crown Castle didn’t invite them or if AT&T declined to participate.  Our suspicion is that Crown Castle is hired to do the dirty work; the carrier’s don’t want to be involved with this mess.  This could make things interesting as courts have ruled a wireless carrier may not have legal standing if they fail to take an active role in the application process (see Verizon vs. Fairfax County here).

att_pv11_coverage_map

ATT coverage map submitted directly to the City without Crown Castle involvement.  Note coverage from site PV11 extends well into Malaga Cove.  As this site is fully active and serving the area it appears to contradict Crown Castle’s claims on AT&T’s behalf.  This is one of many contradictory coverage maps submitted over the last fifteen months.

Going Forward

We were encouraged by a few things we heard.  Crown Castle’s attorney for the appeal (who is well known in the industry) made the comment that he was impressed with the substance of the public comments.  Hopefully, this was in recognition that Crown Castle’s critics on the Peninsula aren’t tin-foil hat wearing NIMBYs, but knowledgeable residents with genuine concerns regarding Crown Castle’s tactics and apparent disregard for neighborhood character and city aesthetics.  Residents are willing to work with Crown Castle but will not do so under their predetermined “rules”.

In addition, the City Council asked insightful, thoughtful questions that clearly demonstrated they understand the importance of not allowing uninformed precedents that could come back to harm the city.

All in all, it was a very good night.

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Crown Castle’s Coverage Map Games

This post gets into technical details regarding existing AT&T coverage in Rancho Palos Verdes.  In it we show that a recently submitted Crown Castle coverage map has a 30 dB discrepancy (that’s off by 1000 times as decibels are logarithmic) that misleadingly depicts existing coverage being much worse than it actually is.  This continues a very troubling pattern in Crown Castle’s submissions.  We’ve tried to make the technical aspects readable to the layman and put the legal implications in context.

 The Importance of Propagation Maps

Rancho Palos Verdes’ comprehensive wireless facility ordinance requires applicants provide propagation maps depicting existing, proposed, and combined/existing proposed wireless service.  Propagation maps are sophisticated computer simulations that depict signal levels and cell tower coverage over a wide geographic area.  They are an industry-standard tool used to assess wireless service coverage.

att_palos_verdes_propagation_map

AT&T propagation map example, submitted to the City of Palos Verdes Estates in October 2015.  Note continuous coverage levels shown over a wide area.  (As an aside, this map was found to have significant errors as it omitted coverage from numerous existing cell towers.  This has been a common and continuing problem with Crown Castle submissions.)

Cities require propagation maps for good reason.  Proposed cell towers are often highly intrusive as the industry wants cheap sites, usually resulting in “cookie cutter” designs in highly prominent locations.  Fortunately, states allow municipal regulation of cell towers, including those in the public right of way.  In our state this power derives from the California Constitution which reserves for municipalities vested police powers to regulate these sites (see this post regarding  T-Mobile et al vs San Francisco, 2016).

Often highly intrusive cell towers are proposed for speculative reasons or to give a wireless carrier a competitive advantage.  Based on all we’ve documented that certainly seems to be the case for much of Crown Castle’s Palos Verdes deployment.  Cities are under no obligation to approve such sites.  Under federal law, municipalities may deny a cell tower if it is not required to close a “significant gap” in service OR if the cell tower proposed (i.e. design/location) is not the “least intrusive means” of doing so.  Cities protect themselves by requiring propagation maps proving the site is truly needed.

The cell towers installers don’t want municipalities challenging their proposed cell towers.  Any challenge can result in delays, increased costs, and could ultimately result in denial of the proposed cell site.  They like the good old days, such as back when Rancho Palos Verdes used to rubber-stamp these cell towers.  Our post on the proliferation of ugly towers in RPV (here) shows what happens without a strongly enforced ordinance.  The propagation map requirement was one of many long-needed reforms implemented to get this problem under control.

Coverage map games

Enter the coverage map games.  If the cell tower installers can create the impression that a significant gap exists (i.e. existing coverage is terrible) then cities will likely think they have no choice but to approve the site.  RF Engineering expertise isn’t commonplace, and few cities have the experience to challenge such claims so they usually go unquestioned.  Fortunately, we have both the experience and the required test equipment to scrutinize what we’re being told.  We documented multiple Crown Castle coverage map discrepancies in an earlier post here, and in every case the errors we found understated the actual existing coverage.  As we’ve seen over and over, Crown Castle’s “errors” almost always seem to be in their favor.  It certainly doesn’t seem random.

It looks like Crown Castle’s string of “lucky” errors continues, as their recent submittals have brought us a new gem.  This is for site ASG53, proposed for the corner or Granvia Altimira and Monero right next to the Palos Verdes Estates city line.  We’ve seen this site before and it’s always been questionable as it’s only 800 feet away from an existing AT&T “macro” high power cell tower.  Here’s the existing coverage map they submitted.

crown_castle_asg53_alleged_significant_gap

Crown Castle coverage map submitted to Rancho Palos Verdes depicting an alleged “significant gap” in coverage.  Map is a public record.  Note it looks nothing like the Palos Verdes Estates propagation map shown above.

Right off the bat, it’s got lots of problems:

  • It’s not a propagation map as required by RPV’s ordinance but a series of Crown Castle field measurements known as a “drive map”. This is an unacceptable substitute for authentic AT&T propagation maps like the Palos Verdes Estates submission shown at the top of the post.
  • It doesn’t show the frequency at which it was measured. AT&T operates on four frequency bands in our area, which one is it?  (BTW, we know what it is from our measurements, why won’t Crown Castle say?  In October we exposed a coverage map in Palos Verdes Estates that was deceptively marked with the wrong frequency.  The apparent lesson Crown Castle learned is to not list it at all.)
  • It only shows one frequency band. Coverage is the aggregate of all four of AT&T’s operational frequency bands, not some single cherry-picked worst case band
  • It only shows LTE/4G (Long Term Evolution) coverage. AT&T also operates UMTS/HPSA service in our area it markets as “4G” that supplements LTE coverage.  It’s completely omitted.

In short, it’s a misleading and cherry-picked depiction of coverage intended to convey worse coverage than actually exists.  Unfortunately, that’s just the start of it.  It looks as if the data submitted may have been altered from the actual measurements.

 The 30 dB Discrepancy

In addition to submitting the ASG53 site (Granvia Altimira and Monero), Crown Castle also recently submitted a neighboring site at Highridge and Peacock Ridge (ASG15).  Due to their proximity, the submitted drive maps have a significant overlap.  These areas should show identical coverage, but they don’t, the coverage is substantially different.

crown_castle_asg15_asg53_comparison

Top: Drive map allegedly depicting existing coverage submitted with ASG15.  Bottom: Drive map allegedly depicting existing coverage submitted with AG53.  Maps resized to common scaling, red box added to show common area.  ASG15 original available here, ASG53 original available here.

In order to allow a clear comparison between the two, we’ve shown just the common areas between the two maps here.  Note how the signal levels are much lower in the bottom plot.

crown_castle_asg15_asg53_common_area

Top: Common area from ASG15 drive map.  Bottom: Common area from ASG53 drive map.  Scale submitted with drive maps shown on right (poor quality resolution was how scale was submitted.) Note dramatically lower coverage levels in ASG53 (bottom plot) despite supposedly representing the same existing coverage.

So let’s compare the two maps allegedly depicting existing service in the same area.  Remember these are negative numbers so as an example, -85 dBm is a lower signal level than -65 dBm.

  • Areas that are dark green (> -65 dBm) in the top map are either light green (-65 to -75 dBm) or yellow (-75 to -85 dBm) or red (-85 to -95 dBm) in the bottom map
  • Areas that are light green (-65 to -75 dBm) in the top map are generally blue (-95 to -105 dBm) in the bottom map
  • Areas that are yellow (-75 to -85 dBm) in the top map are generally black (<-105 dBm) in the bottom map
  • Areas that are red (-85 to -95 dBm) in the top map are black (<-105 dBm) in the bottom map
  • Areas that are blue (-95 to -105 dBm) in the top map are black (<-105 dBm) in the bottom map

It seems pretty clear the two plots shows comparable distributions (higher in the same areas, lower in the same areas) but that the signal levels shown in the bottom plot are shifted approximately 30 dB lower than in the top plot.  This is a huge discrepancy that can’t be dismissed by some hand-waving excuse.  These values are expressed in decibels and are logarithmic, every 10 dB is ten times lower.  So 30 dB equals 1000 times lower (10 x 10 x 10).  It’s not like they forgot to carry the one or something trivial.

Which is Right and How Did This Happen?

So which map is right?  Based on our field measurements we think the bottom map (ASG53) understates LTE coverage on this band by 30 dB and the top map is accurate for this band.  That doesn’t mean the top map accurately represents service as it’s still a cherry-picked single frequency when there are actually four active bands.

As to how this happened, we don’t know but we certainly aren’t surprised based on what we’ve seen from Crown Castle to date.  We do note that if the ASG53 map showed what we believe are the correct levels (i.e. 30 dB higher) it would be very difficult to justify this new cell tower.  The reason is that the proposed Granvia Altimira and Monero location is only 800 feet from an existing AT&T macro cell tower (shown as a big blue dot on the maps.)  It’s just another one of the coincidental “errors” that happens to help Crown Castle, we suppose.

One last note, Crown Castle has stated during  Palos Verdes Estates Planning Commission hearings that they used a third party to collect these drive drive map measurements.  They even had a speaker from that company address the Commission, the clear implication being that the maps were independent and therefore trustworthy.  We spoke to these guys when they were recently conducting measurements in our neighborhood.  We specifically asked them if they made the maps.  We were told no, they give the raw data to Crown Castle and they generate the maps.  Make of that what you will.

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Leveling the Field, Holding the Cell Tower Installers Accountable

This blog has had a huge increase in web traffic over the last month and thanks to all who took a look.  Based on metrics we receive, most of the traffic came from outside Palos Verdes likely from civic groups and even municipalities themselves.  It’s clear there is a real demand for knowledge and it’s no surprise to us.  Knowledge is the key to fighting intrusive cell tower installations.

To be blunt, the wireless industry’s business model counts on uniformed residents and intimidated municipal staff.  Few people want a commercial telecommunications facility near their home, let alone in their front yard.  The industry and its sympathizers count on opposition ignorance to maintain the false impression that there is nothing they can do.  Our first-hand experience has been with Crown Castle, a multi-billion dollar cell tower corporation headquartered out of Texas.  By most accounts it is representative of industry behavior.

The key to protecting your city and your neighborhoods is knowledge.  You fight these tactics by exposing and documenting every discrepancy, every false claim, every exaggeration, and every deception.  Trust us, there is no shortage and this is the stuff that influences municipal decision makers and makes or breaks lawsuits.  We’ve included a sampling of our findings in Palos Verdes below and we really doubt things are any different in other communities.

The long list of “discrepancies”

With that preamble, let’s get to the list.  This isn’t meant to be exhaustive but to give those interested a taste of what we’ve found digging into Crown Castle’s submissions, installations, and tactics on the Palos Verdes Peninsula.  They can’t demand everyone else follow the rules then completely blow them off themselves.

All of this has been meticulously documented; much of it has been submitted to the corresponding municipality.  The rest is available as needed if things get ugly in the future.  Some of it has been discussed on this blog previously and we’ve provided links in places.  Some we are holding close to the chest.  Whether these discrepancies were intentional is really irrelevant, this stuff is damning even if its cause is just plain old incompetence and carelessness.

Site Drawings and Documentation

  • False photo simulations that show proposed installed equipment much smaller than actuality (link)
  • Prominent equipment and cables missing from photo simulations
  • Distorted, not to scale drawings showing proposed equipment too small (link)
  • Distorted drawings that show the existing infrastructure (e.g streetlights) out of proportion thus making the proposed equipment look smaller by comparison (link)
  • Prominent equipment and cables missing from drawings (link)
  • Contradictory drawings, discrepancies between equipment sizes shown on different pages of submitted plans
  • Site plans missing key required elements such as existing and proposed utility routing and adjacent land use

Site Technical Documentation

  • Changing service metrics resulting in a 20 dB drop in “existing” coverage map levels without a corresponding shift in service target levels (RSSI to RSRP) (link)
  • Different “required” service levels in Palos Verdes Estates and Rancho Palos Verdes, PVE is 10 dB higher than RPV without rationale (link)
  • Wildly inconsistent “existing” service coverage maps submitted between Palos Verdes Estates and Rancho Palos Verdes despite both showing the same geographic area (link)
  • Missing known AT&T-owned sites in submitted “existing” network facility maps (link)
  • Missing known AT&T-owned site coverage in “existing” service coverage maps
  • An “existing” coverage map submitted as 1900 MHz service that actually depicts 2100 MHz
  • Cherry-picked worst-case coverage maps from a single frequency band (out of four active bands) misleadingly portrayed as representing “existing” coverage
  • Incorrect antenna orientation shown on proposed facility maps
  • Service coverage maps alleged to depict “proposed” coverage modeled with only one of the two site antennas active (link)
  • Wrong antennas used in RF Emission reports thus reporting inaccurate values

Questionable Legal Claims and Behavior

  • False legal claims that new sites fall under “Section 6409” and thus can’t be denied by the city (link)
  • False claims that a 90 day shot clock applies to brand new sites
  • Misleading statements regarding a municipality’s right to regulate these sites under PUC Section 7901
  • Misleading claims regarding the existence of a “significant gap” based on cherry-picked frequency bands and incomplete coverage maps (link)
  • Underground installation mock-ups using unnecessary intrusive ventilation stacks to make the city-preferred option look unappealing (link) (link)
  • Excessively large and 75% empty ground-mounted cabinets claimed as required after Rancho Palos Verdes rejected pole-mounted equipment (link)
  • Excessively large antennas claimed as required in Rancho Palos Verdes despite using antennas one-third the size in Palos Verdes Estates (link)

Site Approval and Community Engagement Tactics

  • Repeatedly failing to provide residents timely notification for public hearings
  • Construction crews misleading residents when queried as to what they were doing (link)
  • Installations and work performed beyond that authorized by the city
  • Permanent installations constructed as the “mock-up”, then leaving it in place for months longer then required when not immediately approved (link)
  • Underground fiber installed throughout the city before a single antenna installation was approved despite city objections and concerns (link)
  • Failure to provide alleged analysis for alternate locations despite promises to do so (link)
  • Failure to involve AT&T in public hearings or resident meetings despite requests to do so

Issues with Existing Installations

  • Installations on utility poles in violation of CPUC General Order 95 Section 94.4 (safety and reliability regulations) (link)
  • Highly intrusive cable routing and extremely poor workmanship on existing sites (link) (link)
  • Amateurish paint jobs using hardware store spray cans resulting in fading, streaks, uneven coverage, and overspray (link)
  • Existing installations that are far more intrusive than depicted in submitted photo simulations (link) (link)
  • Existing installations that don’t match submitted drawings

Why all this matters

Pretty interesting list, huh?  For those of you still wondering why all this matters we recommend you spend a little time reviewing Verizon vs. Fairfax County (E.D. Virginia, 2015) (available here).  Verizon sued the County after it rejected a cell tower installation under its wireless facility ordinance.  It’s a recent case that’s highly relevant as it discusses LTE technology, a cell tower installer middleman, lousy documentation, and unsubstantiated technical claims.  The court found for Fairfax County on all counts and absolutely shredded Verizon on multiple fronts.  Similar to T-Mobile et al vs. San Francisco, it was a total wipeout.

The court had some really interesting things to say.  First off, the court openly rejected Verizon’s standing in the case as a cell tower installer middleman was the applicant.  The court also questioned the depth of Verizon’s involvement as virtually all the work was done by the middleman with Verizon seemingly out of the loop.  Does this sound familiar?  It sure ought to.  AT&T has been completely absent from the Palos Verdes cell tower project.

Crown Castle repeatedly makes claims allegedly on AT&T’s behalf, yet AT&T itself has been nowhere to be found in this whole fiasco.  This despite the fact the PVE Planning Commission has now twice requested greater AT&T involvement.  The Commission has requested both an AT&T presence at the hearings and in meetings with residents.  Neither has happened.  We don’t blame AT&T as we wouldn’t want to be directly involved with this debacle either.  Unfortunately for them, the Fairfax County decision shows Crown Castle’s failure to engage AT&T could be really problematic.

Next, the court took Verizon to the woodshed for poor documentation, conflicting claims, and a general making-it-up-as-they-went-along approach.  The court outright rejected Verizon’s “expert” claims regarding location requirements and lack of feasible alternatives as lacking substance.  The court praised the citizen group for their detailed records and documentation, and painted a sharp contrast to Verizon’s behavior.   Déjà vu, anyone?

The court also tackled the issue of minimum LTE signal levels.  Verizon’s expert stated under oath that the required LTE signal level for indoor coverage was -95 dBm RSRP, 20 dB (100 times) lower that Crown Castle’s current claim in Palos Verdes Estates.  Despite this, the court still found there wasn’t a significant gap even at these low levels.  (Side note: We now have an AT&T engineering report from another jurisdiction where AT&T states the minimum LTE signal level is -96 dBm RSRP directly contradicting Crown Castle’s “required” signal claims in Palos Verdes on their behalf.  Stay tuned.)

In short, Verizon went in unprepared with sloppy documentation, arbitrary technical claims, and an argument from authority.  They lost because the County and residents had done their homework.

 

Knowledge is power as they say, and in this case it’s certainly true.  The wireless industry counts on you being uninformed and intimidated.  It doesn’t take much digging to bring down the whole house of cards.

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Compromise with Crown Castle?

We received a thoughtful email from an Rancho Palos Verdes resident suggesting we meet with Crown Castle to work out a mutually-agreeable solution in the interest of improving cell service.  We should note that the deployment is only for AT&T thus regardless of what happens there will be no cell service improvement for two-thirds of peninsula residents.  In any case, we welcome the opportunity to work with Crown Castle but have made clear that any such cooperation must focus on overall compliance with RPV’s wireless facility ordinance.  None of the proposed sites come close to doing so.

Crown Castle has met with individual PV residents in the past.  However, at Crown Castle’s insistence, the scope has always been limited to minor changes to an individual site.  For example, discussions might consider moving an intrusive residential site from the initial location to the next adjacent streetlight or utility pole.  In other words, moving it from being your eyesore to being your neighbor’s eyesore.

We refuse to play this game as it doesn’t address the essential fact that every site proposed grossly violates RPV’s wireless facility ordinance without credible justification.  If Crown Castle wants to get these sites approved they need to comply with the ordinance.  There are many details but it really boils down to three core issues:

  • Antenna size – Crown Castle’s proposal to place two 50” tall by 19” wide antennas on residential streetlights is ridiculous and completely unacceptable. These antennas will be three times wider than the streetlight pole itself, each with an area exceeding 6 square feet, and completely at odds with the community architectural character.  Comparable deployments in other cities used antennas only 24” tall by 11” wide, less than one-third the size.  Here’s the antenna size they want to install on a small, residential streetlight.

6 sq ft antenna

Same size antenna on a 42 foot utility pole on industrial-zoned Gaffey Street in San Pedro.  Now imagine two of them on a streetlight half that size in your residential neighborhood.  (Side note: Is it too much to ask that antennas be mounted plumb?  Good grief, there’s a Home Depot right down the street from this site that sells bubble levels for less than ten bucks.)

  • Accessory Equipment location – Crown Castle proposes to place bulky accessory equipment either high on the pole itself or in huge above ground cabinets, often right in front of homes.  This is also unacceptable as RPV’s ordinance requires accessory equipment be located underground.  The carriers have done this many times in the past without problems.  The equipment can be located quite distant from the antenna itself; one proposed installation in Palos Verdes Estates locates the equipment over 70 feet away from the antenna tower.

above_ground_cabinet

Proposed above ground cabinet to be placed directly in front of homes.  Cabinet is 57″ tall.  Crown Castle claims this gigantic box is required despite the fact it will be 80% empty with the equipment they plan to install.  It’s either a scare tactic to gain approval of pole-mounted equipment or they have big plans for the future they aren’t telling us about.

  • Residential neighborhood locations – The majority of Crown Castle’s proposed sites are in the heart of residential neighborhoods, many right in resident’s front yards. RPV’s wireless ordinance prohibits this unless the location is required to prevent an “effective prohibition” of service (this has a specific legal meaning).  Intrusive residential neighborhood locations are intolerable unless there is no feasible alternative to prevent a significant gap in coverage.

We’ve documented on this blog very troubling aspects of questionable behavior on Crown Castle’s part, including highly misleading submissions to the City.  It’s also clear that Crown Castle’s design and site locations were chosen to minimize cost with virtually no consideration of community aesthetics.  Last off, Crown Castle’s claims of design/location being “required” are incredibly weak, reek of engineering perfectionism, omit important technical context, and wouldn’t hold up in court if it came to that.  We know, we’ve analyzed all of them.

We’re sure they aren’t happy with us either.

We welcome the opportunity to set this aside and work together.  However, any such collaboration must correct the three core issues listed above with genuine, good-faith compliance with RPV’s wireless facility ordinance.  We will not accept window dressing or “throw them a bone” concessions, nor will we accept unsupported claims that ordinance compliance is infeasible.  Fortunately, we have the technical and legal expertise to test any such claims.  Simply put, the deployment as proposed is fatally flawed and requires a fundamental rethinking with community aesthetics as the top priority.

We await Crown Castle’s response, we check our contact form submissions daily.

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Reports of a Significant Gap are greatly exaggerated…

(NOTE: This is the second part in our series on Crown Castle’s Bad Plan for Palos Verdes, part 1 is here.  The post gets into technical details that may not be for everyone, but we hope readers will stick through it and apologies for the length.  As we’ve seen before, there’s plenty of troubling, unanswered questions that need an explanation.  It’s important to understand exactly what is taking place when exercising our right to regulate highly intrusive cell towers.)

The Meaning of Effective Prohibition

prop map example

A propagation map used in significant gap analysis

Under state law, cities in California can deny cell towers in the public Right of Way on aesthetic grounds (PUC 7901, Sprint vs PVE).  However, if a site is required to prevent an “effective prohibition” in service, then a city may be required to approve the tower despite this under the Telecommunications Act of 1996.  Federal law supersedes state law.

Two key concepts that have evolved in federal law are “significant gap” and “least intrusive means”.  If the applicant can prove:

  1. The site is required to close a significant gap in service AND
  2. The proposed method for doing so is the least intrusive means

THEN failure to approve the site is likely an effective prohibition of service.

However, it’s not an easy threshold to meet as evidenced by a string of lost lawsuits brought by the carriers.  If cities do their homework, and don’t do something stupid (such as denying sites based on perceived RF health effects), then they’ll be on firm ground.

But the carriers and their tower installers realize most cities don’t understand the law.   They can often be intimidated by a bunch of technical mumbo-jumbo, legal bluster, and copy and paste claims of entitlement.  We’ve certainly seen that tried in Palos Verdes.  The ridiculous sites proposed by Crown Castle were all claimed to be “least intrusive means” despite the fact they were shoddy designs, plopped right in peoples front yards, with a primary goal of minimizing costs.

Significant Gap in Rancho Palos Verdes?

So with that background, it’s not surprising that the carriers and tower installers claim virtually every proposed site is required to close a significant gap.  Fortunately, we have RF engineering expertise and can test Crown Castle’s claims to see how well they hold up.  (Spoiler alert: they don’t)

Here’s the “significant gap” narrative from the site justification for proposed site ASG 53 in Rancho Palos Verdes (highlight added, original here):

Crown Castle significant gap claim

In summary, Crown Castle claims the entirety of RPV is just one giant significant gap.  No joke, in the highlighted red box they state “AT&T has in effect little to no coverage for the balance of the city”.  Sounds pretty bad, and they submit a “drive map” as evidence.  (Side note: RPV’s wireless ordinance requires propagation maps, drive maps are not an acceptable substitute.)

 

Crwon Castle drive map RPV

Drive map submitted to Rancho Palos Verdes by Crown Caste showing alleged ATT LTE coverage.  Note red box added to plot, it will be important below. Source: RPV public records, original here

Wow, that looks like awful LTE coverage.  Crown Castle states a signal level of -85 dBm or greater is required for adequate coverage thus only the dark green, light green, and yellow streets have sufficient coverage.  All the streets shown in red, light blue, or dark blue are lower than -85 dBm (more negative) thus they supposedly have a significant gap.

Fortunately, we’ve got a pretty good BS detector and let’s just say this claim set off bells like a three-alarm fire.  Over on the right hand side it shows the percentages for each of the coverage levels.  Signal levels of -85 dBm or greater (more positive) totaled 9.5%.  Thus Crown Castle claims 90.5% of the streets they drove have a significant gap in service.  Does anyone really believe this?  Cell coverage in Palos Verdes is not great, but it’s not that bad.  Time to call BS on these guys.

Continue reading

Anatomy of a Terrible Cell Tower

On AT&T’s behalf, Crown Castle has proposed some really awful cell towers for Palos Verdes.  The designs are so bad, we can’t think of any reason other than greed and sloth.  Fortunately, RPV has a strong new wireless facility ordinance to protect our city’s aesthetics from low-ball bidders and lazy engineering.  Going forward, AT&T might want to take a closer look at who they partner with.

Proposed site on Verde Ridge Road

This site is proposed for the heart of a residential neighborhood directly in front of two homes.  As we’ve seen from Crown Castle before, they don’t accurately show the installation size in their photo simulations so we’ve added outlines showing the true size.  Note the poor photo resolution and that the simulation is missing all cables.  The street sign moved up the pole 16 feet in the air is a nice touch.

Crown Castle terrible cell site.png

Photo simulation of proposed residential neighborhood site on Verde Ridge Road in Rancho Palos Verdes.  Red outlines show actual antenna size and protrusion.  RF Cables and proposed electrical power conduit are missing from simulation.

This eyesore is proposed in the heart of a residential neighborhood, despite the fact RPV’s ordinance prohibits these locations unless required to prevent an effective prohibition of service.  That’s going to be tough to show, particularly since it’s close to an existing ATT macro site.  The site justification documentation submitted so far hasn’t been impressive, and it’s directly contradicted by prior submissions.

Crown Castle residential neighborhood cell tower.jpg

Aerial view of proposed site and surrounding area.  Note heavy residential character.

Impact on Home Values

Due to insane coastal California real estate prices, Zillow states the two homes shown behind the proposed cell tower are valued at 1.5 million dollars each.  Now think about what happens if this eyesore is built how and where Crown Castle wants.  Pretty much no one wants a highly intrusive and ugly cell tower next to their house.  If the residents try to sell their home, it’s entirely realistic they will lose 5% or even more of their home’s value.

As to home value, would you buy a house with an intrusive cell tower in the front yard when you could get another in the same beautiful neighborhood without it?

That 5% home value hit just turned into a 75 thousand dollar loss for these residents, yet they didn’t make a dime from the cell tower.

Here’s a look at the “plans” for the site.  As we’ve commented before, the industry only seems able to hire really terrible draftsmen.  The drawing is not to scale, and the size is distorted.  Important features such as cable routing is missing entirely.  No dimensions are shown for the height of the added equipment other than the antenna.  This was the only view submitted so it’s impossible to see how far the equipment actually protrudes from the pole.

Crown castle shoddy drawing

Plans are not drawn to scale and are extremely misleading.  Mast arm and luminaire is shown ridiculously oversized making the new equipment look smaller by comparison.  Pole-mounted equipment is too low on pole.  Antenna width is actually 19” but it’s shown as barely wider than the 6” pole.  Calling this amateur hour would be charitable.

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What is going on with Cell Towers in Palos Verdes Estates?

This is a lengthy post that provides some background and context regarding the cell tower fight in Palos Verdes Estates.  We hope readers find it informative.

In late 2014, Crown Castle approached PVE regarding 22 new cell towers in the City for ATT.  Up to this point, the entire City had been served by about half a dozen ATT sites.   It was not explained, or seemingly even questioned, why the City needed a 350% increase in the number of cell towers.  Planning Commission hearings started in October 2015, and by January ten had been approved.  As of 7/5/2016, only one new site has been approved since then.  The approval process has clearly stalled.

Palos Verdes Estates cell tower sites

Approved sites shown by dark blue dots, proposed (not approved) sites shown by light blue dots.  Note most of the remaining proposed sites are in the heart of residential neighborhoods.  Source: Crown Castle

So why the change?  Well, a number of reasons but the foremost is a striking difference in the Planning Commission’s demeanor in recent months.  The Commission no longer appears willing to simply accept they must approve sites based on Crown Castle’s vague claims sites are “required”.  The Commission had been led to believe that they had no ability to question any aspect of Crown Castle’s proposed deployment beyond the appearance of an individual site.  Their thinking has clearly changed.

There are likely many reasons for the sea shift, but here’s our take:

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