An Open Letter to the Wireless Industry (Part 1)

We received a thoughtful inquiry on our contact page from someone within the wireless industry asking as to what these companies could do to foster community acceptance of wireless infrastructure (that is, cell towers).  That email prompted this open letter, which we hope the industry takes to heart.

This will be a two-part post.  At the risk of being perceived as overly negative, we’ll start with the DON’Ts and follow up with the DOs in our second post.   In our experience, the behavior of the wireless industry has been nothing short of shameful and has absolutely poisoned the relationship with residents.  No amount of good deeds will change this dynamic if the behavior listed below continues.

DON’T lie to city staff or residents

Far and away the number one item on the list is to stop saying things that aren’t true.  The level of duplicity we’ve seen from the wireless industry in our community has been a shocking eye opener.  False legal claims, misrepresentation of intentions, brazenly misleading technical statements, and deceptive site documentation appear to be the norm, at least from what we’ve seen in Palos Verdes (link).  You can’t get away with this anymore with informed citizen involvement.  One of the main reasons we put this website online was to share what we’ve learned with those in other communities.  Based on the feedback received, others are finding it helpful.

It may work to sneak through a site or two, but these tactics will be exposed in a big rollout such as Crown Castle’s 60-site cell tower network being pushed in Palos Verdes.  Once exposed, you will lose all credibility and nothing you say will be believed, not even stuff you think is true.  Not only that, you will lose what little public support you may have had at the start and greatly reduce the chances of approval for your project.  People don’t like being misled and City decision makers don’t like having their intelligence insulted.  Accept the fact that your project will never be popular and lying in an attempt to ram it through will make things much, much worse.

DON’T arrogantly demand an entitlement to Right-of-Way access

It’s pretty clear you think your “public utility” facade entitles you to place these wherever you please in the Right-of-Way (ROW).  You preach it with the evangelical zeal of a true believer but just saying it over and over doesn’t make it true.

neptune_cell_tower

Our photoshop of PVE’s famous fountain hosting a cell tower.  It’s in the ROW so they are entitled to do it right?  Actually no.  The right to occupy the ROW in California is limited and subject to city police powers.

Quoting court decision excerpts out of context doesn’t change the central fact that your right to place these sites is limited and cities retain police power to regulate them.  There’s a reason you lose lawsuits (Sprint vs. Palos Verdes Estates, Crown Castle vs. Calabasas, T-Mobile et al vs. San Francisco to name a few here in California).  The Calabasas court flat out said you were making the law up when you tried to overturn that city’s cell tower ordinance:

Petitioners (Ed: Crown Castle) concede that that the City can regulate aesthetics, but that a wholly discretionary CUP (Ed: Conditional Use Permit) blind to the existence of a vested right of access to the right-of-way is unlawful.  Petitioners suggest the ordinance could be lawful only if it provided for a ministerial review of aesthetics “that properly presumes the preexisting right of a telephone corporation to use its streets”.

Petitioners cite no authority for the proposition, and the court is aware of none.

Your legal threats can be intimidating to city staff that usually don’t live in the city and don’t want any chance of a lawsuit on their watch.  But they infuriate residents and City Councils, particularly once they are exposed as arrogant, strong-arm tactics with little actual support in law.  About the only thing worse than a liar is a bully.

DON’T try to sneak in sites behind resident’s backs

cell approved 1

These things started showing up all over town without any notice or explanation, sort of like the pods from Invasion of the Body Snatchers.

Across our community you ran underground fiber optic lines up to most of these proposed sites before telling the public about your plans.  You demanded the right to do this despite city objections and warnings that there was no guarantee your antenna sites would be approved.  You thought you could get the network backbone in place before the public realized what was going on.

In Rancho Palos Verdes, you showed up at the first residential neighborhood site and started tearing up the sidewalk and installing the foundation for a brand new streetlight topped with an 18 cubic foot antenna canister.  A 9 cubic foot cabinet was to be attached to the pole reaching twelve feet into the air.  The structure would be nearly 30 feet tall and dominate the view along this quiet underground utility cul-de-sac.  You did this work under the guise of installing a “mock-up” with no advance notice to residents.  Your subcontractor lied to nearby homeowners when asked what they were doing.  Fortunately, our City Council intervened and put a stop to this manipulative nonsense.

Your response to the City’s action was a threatening legal letter demanding the city approve all sites within 30 days.  It further infuriated residents and had the opposite effect of what you intended.

How could you possibly think this was an effective method to get your project in place?  Did you think RPV residents were that stupid that they wouldn’t notice these ugly eyesores sprouting like mushrooms on their quiet residential streets?  Your plans were exposed and your deployment ground to a halt before the very first site was in place.  The fact that you thought this would work shows us exactly how much respect you have for our community.

DON’T pit neighbor against neighbor

You offered to “work” with residents in Palos Verdes Estates who objected to having a cell tower plopped in front of their homes.  Residents, without specialized legal or technical knowledge, accepted your offer in good faith.  Your “solution” was to move the cell tower next to another neighbor’s home who wasn’t present at the meeting.  The entirely predictable result had longtime neighbors squabbling with each other, increased tension, and a loss of camaraderie on this residential street.

Residents were surprised by this turn of events but somehow we doubt you were.  The industry would much rather have neighbors fighting with each other rather than united in opposition to your self-proclaimed right to invade their quiet residential street.  Thank goodness the Planning Commission ended this charade by denying the site as incompatible with the neighborhood.

These tactics undermined our community’s trust and we don’t think you’ll get it back anytime soon.

DON’T propose cell towers in residential neighborhoods

hall of shame7

The new normal according to those who make money installing cell towers

Virtually every tactic discussed above stems from the fact you plan to muscle in these cell towers right next to our homes.  We get it; it’s cheap and easy for you.  You think the 5G future is going to normalize these eyesores on our streets, sort of like fire hydrants. No different than the 21st century equivalent of the corner mailbox, you might say.

We view them differently.  These are cash cows for you; they provide a steady stream of revenue and the cheaper you can throw them up the more money you will make.  Residents receive no financial compensation despite the fact these sites are a terrible nuisance.  Your shoddy designs are ugly and prominent with no screening whatsoever.  Your equipment contains large and noisy cooling fans that run 24/7 despite the fact most PV neighborhoods are extremely quiet.  Most important, these sites kill property values.  Would you buy a home with an obvious and highly intrusive commercial telecommunication facility a few dozen feet from the front door?  Yet residents are supposed to suck it up and accept the loss of tens of thousands of dollars in what is likely their biggest investment.  Of course these unfortunate homeowners don’t receive a dime in compensation from you.

We understand it will cause you more work to perform the honest, old-fashioned engineering needed to locate these sites away from homes.  Guess what?  We don’t care, that is your problem not ours.  No one asked you to come here; you showed up and demanded access to our Right of Way.  In public hearings we have repeatedly demonstrated that you ignored less intrusive locations that would provide suitable coverage as they were inconvenient or cost you more money.  You aren’t entitled to place these eyesores wherever you like and you aren’t entitled to perfect coverage.  If you expect to place these in our community then we expect you to do your job and design minimally intrusive sites located away from homes.

DON’T make up technical claims

You’ve probably gotten away with this for a long time as most cities don’t have the expertise to challenge your claims.  That’s one of the reasons we put this site online, we do have the experience and we wanted to document what we’ve found.  It hasn’t been pretty as we’ve shown arbitrarily changed service metrics, omitted existing sites from coverage maps, cherry-picked frequency bands, and submitted data that appears to be grossly in error.

Many of your poorly-maintained existing cell towers haven’t been upgraded to operate on available frequency bands, then you disingenuously point to this absence as justification for new sites!  Your attempts to hand-wave away these discrepancies come off as self-serving and technically shallow, and undermine any claim that you actually know what you’re talking about.  Frankly, it looks like amateur hour to those of us who are professional engineers and are accustomed to a disciplined engineering environment.

Android App

One of many great apps that easily checks claims regarding existing coverage.  It displays the info your Android phone collects and uses in making network cell connection decisions. Cost: $2.  Root the phone for even more info.

The days of needing a $50K spectrum analyzer and a highly compensated “expert” to check your claims are over.  An Android phone with a $2 app allows a tech-savvy resident access to important network parameters and the ability to document cell IDs, active frequency bands, RSRP, and RSRQ of existing coverage.  If the phone is rooted, even more info is available with other apps.  The advent of highly capable software-defined radios enables 90% of that $50K spectrum analyzer’s capability for only a few hundred dollar investment.  Checking your claims is now within the bounds of sharp residents with a technical background.  If you lie about this stuff, there is a pretty good chance it’s going to be exposed.

As to “independent experts” hired to assist cities, you better being doing this stuff yourselves as it’s your job to find these discrepancies, not that of the residents.

DON’T claim your motivation is anything other than to make you money

It’s insulting and ultimately hurts your cause when you make claims that you are motivated to “serve the community”, “improve emergency communications” or “upgrade critical infrastructure”.  Residents know you wouldn’t be giving our community a second thought except for the fact you plan on making a pile of money here.  No one believes you are motivated by any sense of public service; claiming to be so undermines your credibility.

Acknowledge that your presence in our community is first and foremost a business opportunity, nothing more, nothing less.   That business opportunity can be mutually beneficial for both you and the city’s residents if implemented in a thoughtful and coordinated manner.  To date we’ve seen nothing of the sort.

 

Along these lines, part 2 of this post will deal with the DO’s of how to implement such a deployment in a thoughtful and coordinated manner.  Unsurprisingly, it consists of early resident involvement (not just paid staff who don’t live in the city), a clear description of the goals and objectives, aesthetically-pleasing and screened tower designs, and a concerted and diligent engineering effort to locate sites away from homes and outside of neighborhoods.  In other words, common sense city planning.  We should have part 2 up soon.

 

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SB 649 Threatens Cities Rights to Regulate Cell Towers

California Senate Bill 649 is being heard this week in Sacramento.  Please contact your state representatives and make clear your opposition to this terrible bill.

Things have been relatively quiet in Palos Verdes for the past two months as Crown Castle rethinks some of the highly intrusive cell towers they had intended to plop right next to homes.  The sites as proposed were ugly eyesores; virtually guaranteed to detract from neighborhood aesthetics and negatively affect the home values of the nearby residents.

Fortunately, decision makers in both Rancho Palos Verdes and Palos Verdes Estates decided to aggressively assert the city’s right to regulate these sites as allowed under both state and federal law.  Unsurprisingly, the wireless industry doesn’t like this.  They want quick and dirty cookie-cutter sites they can throw up as cheaply as possible.

Cell towers are a multi-billion dollar business and the industry is heavily lobbying Sacramento and Washington to strip municipalities of their right to regulate these sites.  The latest attempt in California is Senate Bill (SB) 649, being heard this week at the state capitol.  SB 649 will override municipal authority to apply common sense local planning review to cell towers.

hall of shame7

An existing dreadful cell tower on a Monero Drive cul-de-sac in RPV, it is only 30 feet from the residence.  This site never should have been approved but it was put in place prior to RPV’s comprehensive wireless facility ordinance.  SB 649 derails the City’s authority to prevent ugly cell towers like this from multiplying throughout the residential neighborhoods.

We need your help to let Sacramento know this unacceptable.  They tried this last year when Assemblyman Mike Gatto attempted to push through a bill stripping cities of the right to regulate ugly and intrusive cell towers.  That bill died in committee after an outcry from concerned residents and the municipalities themselves.  We’ve shown before that the wireless industry can be stopped.

Sacramento needs to again hear from concerned residents.  Also, please urge your city government to contact our local state senators and legislators and voice opposition to SB 649.  In Palos Verdes, our state representatives are:

  • Assembly: Al Muratsuchi, 66th Assembly District, (310) 375-0691   contact (link)
  • State Senate: Ben Allen, 26th Senate District, (310) 318-6994   contact (link)

If you are outside of Palos Verdes, you can find your state representatives here (link).

Giving the Wireless Industry Free Reign in our Cities is a Terrible Idea

We’ve documented the really ugly and highly intrusive cell towers installed before Rancho Palos Verdes implemented its comprehensive wireless facility ordinance (link).  This is what cities can expect with the wireless companies calling the shots.  It isn’t pretty.  Now imagine one of these eyesores in front of your house.

We’ve documented how Crown Castle misrepresented the size and intrusiveness of RPV’s proposed cell towers using misleading photo simulations (link).

We’ve documented how Crown Castle misrepresented the applicable law in wireless facility applications in both RPV and PVE (link).  We also documented how Mobilitie was playing the same games and was formally taken to the woodshed by the state of Minnesota (link).

We’ve documented the misleading technical claims made by the wireless industry to fool municipalities into thinking they can’t deny a proposed cell tower (link).  We’ve also shown how they’ve changed their story when confronted on these claims.

We’ve shown how Crown Castle and the wireless industry used lawsuits and legal threats to intimidate cities.   We documented how they went for broke in 2016’s T-Mobile et al vs. San Francisco and suffered a historic loss before the California Court of Appeals (link).  The court made clear cities maintain the right to regulate these sites despite the wireless industry’s attempts to twist the clear language of state law.

Don’t Let them Change the Law and Handcuff Cities

Now the wireless industry is trying to change state law despite the fact they’ve shown over and over they can’t be trusted to deal openly and fairly with cities.  It’s a terrible idea but it has huge amounts of money behind it.  Our representatives need to hear from the people, please contact Sacramento today and voice your opposition to SB 649.

 

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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:

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Sixteen New Verizon Cell Towers in RPV

It seems that Crown Castle has big plans for our community whether we like it or not.  We’ve discussed in detail the nearly 80 AT&T cell towers Crown Castle is trying to muscle into Palos Verdes neighborhoods.  We’ve now found out they are planning at least 16 new Verizon cell towers in Rancho Palos Verdes (that we know of so far).  As with their highly intrusive AT&T deployment, many are again proposed for residential neighborhoods without regard for community aesthetics or property values.  It looks like we are going to be busy going forward.

A Surprise in the AT&T Resubmissions

Crown Castle has started resubmitting the 26 AT&T cell tower applications that were rejected as incomplete earlier this year.  So far six have been resubmitted, and all six have again been rejected as incomplete since the submitted documentation does not meet the requirements of Rancho Palos Verdes’ comprehensive wireless facility ordinance.  We requested and received copies of the documents for review (they are public records).

RPV’s ordinance wisely requires applicants submit a master plan including all proposed sites for the next two years.  Buried within the documentation was a table that surprisingly also included 16 new cell towers for Verizon.  As far as we know, these have never been publicly announced.  It would appear the city has not been formally notified of these as they are not shown on RPV’s extremely comprehensive cell tower webpage.

In typical Crown Castle fashion, the list didn’t include addresses but only GPS coordinates.  We’ve gotten wise to their tricks and know when they obfuscate like this it’s probably not by accident.  It was simple to plug the coordinates into Google maps and figure out what they are up to.  Yet again, Crown Castle didn’t fail to disappoint.  Here’s the result. (Crown Castle’s full list of proposed sites can be found here)

crown-castle-verizon-cell-tower-map

Crown Castle’s proposed Verizon cell towers plotted out.  Despite the site labels, all sites are in Rancho Palos Verdes.  Note that six sites (PV01, PV02, PV04, PV05, PV06, PV07) are missing from the sequential list.  These are likely in Palos Verdes Estates or Rolling Hills Estates and were omitted from this list submitted to Rancho Palos Verdes.

Thirteen Residential Neighborhood Sites

Of the 16 sites, thirteen are located in the heart of residential neighborhoods.  Many of these are also in underground utility districts.  Here’s a few of the offenders:

Verizon Cell Tower PV 03 Location – 30100 block Via Rivera (West Palos Verdes)

verizon-pv03-cell-tower-location

This is an underground utility district and they appear to have targeted this streetlight based on the GPS coordinates.  It’s right in front of a home with houses directly across the street.  There’s an existing Crown Castle cell tower on a streetlight just 300 feet away.  They’ve also submitted an application for an AT&T cell tower for a streetlight just 9 houses down the street.  Talk about chutzpah!

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Crown Castle’s End Game

The Palos Verdes Estates Planning Commission denied another residential neighborhood cell tower at the November 15th Planning Commission hearing.  This is the second residential neighborhood site the PC has denied, both on unanimous votes.  We could not be prouder of the Commission.

Unlike the city’s advisors, the Commissioners live in our community and will be stuck with these highly intrusive cell towers.  Critically, they no longer believe claims that they must accept these sites.

crown-castle-residential-cell-tower

A tranquil residential neighborhood in Palos Verdes Estates (Chelsea and Yarmouth).  The perfect place to put an intrusive cell tower and equipment cabinet according to Crown Castle.  Fortunately, the Planning Commission said no.  Note there is an existing AT&T macro site only 1400 feet away at Lunada Bay Plaza.

It was a long time in coming, some context is warranted.

What Crown Castle is up to

Crown Castle is attempting to place intrusive cell towers in the heart of every neighborhood in Palos Verdes, nearly 80 sites in all.  Despite all their lofty claims of serving the public, their motivation is economic profit.  As we documented here, their sponsoring wireless carrier (AT&T Mobility) wants to sell very expensive wireless data plans in our community.  To do that, they need more extensive infrastructure.  Crown Castle’s role is to browbeat our community into accepting the cheapest possible deployment that gives AT&T a competitive advantage.

palos-verdes-crown-castle-80-cell-towers

Crown Castle’s plan to put 80 cell towers across the Palos Verdes Peninsula.  Most are located within residential neighborhoods.  Note the close proximity, some sites are only 500 feet apart.

Why Palos Verdes?  To quote Willie Sutton when asked why he robbed banks, “because that’s where the money is”.  Crown Castle isn’t placing these in every neighborhood in Carson, Wilmington, Gardena, or other less affluent communities.  Make no mistake, we’ve been targeted and selected.  AT&T Mobility has staked out Palos Verdes as their turf, Crown Castle is the hired muscle, and we are supposed to roll over and welcome these highly intrusive installations into our neighborhoods. This is the 5G future they insist, there is no stopping it, and we have no choice but to accept it.

No one bothered to ask residents what they thought about all this.  They sorely misjudged our understanding of the law, our technical knowledge, and our resolve.  Not to mention we don’t give a damn about Crown Castle’s profitability, promises they’ve made to AT&T, or their highly questionable business model.  We care about our community.

Crown Castle has trotted out every trick in the book to convince Palos Verdes cities that they had no choice but to approve these sites.  Fortunately Crown Castle’s playbook is superficial, once you understand the game plan it’s much easier to fight them.  It’s doesn’t help their cause that virtually every one of their experts and subcontractors looks to be the lowest bidder who seem to have a really hard time keeping their stories straight.  Their book of tricks is a mile wide but only an inch deep.  Once the spell is broken, the illusion of inevitability falls apart.

Palos Verdes Estates now gets this.  Crown Castle’s plan was to carve the Peninsula up into a big grid and plop highly intrusive cell towers into the middle of each square without regard for neighborhood aesthetics or adjacent home values.  They had City staff buffaloed into believing they couldn’t be stopped. The City’s advisor had a long list of things the city supposedly wasn’t allowed to do but was conspicuously quiet regarding Crown Castle’s behavior.  It was strongly implied the city couldn’t deny sites but could only require adjustments to their appearance.

The entire premise of “significant gap” was to be preemptively surrendered despite the fact it protects the city and its residents  (i.e. “significant gap” means a city can deny a cell tower if it is not required to close a significant gap in service.)  If Crown Castle claimed they didn’t have good enough coverage then that was it, they were entitled to a new cell tower.  There would be no challenge of significant gap, end of story.  Or so we were told.  As we’ve now made plainly clear, that isn’t what the law says.

Thank God the Commissioners live in our community and were willing to listen to us rather than following the word of outside advisors.

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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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Our Biggest Week Ever

We had one thousand page views over the last week (1006 to be exact), a new record for this site.  There have been 27 views in the last hour it took to compose this post alone.  Thanks to all who took a look and a special thanks those who took the time to contact us.

The reason for our blog

We started this blog back in May without much fanfare.  Our intent was to document our findings regarding Crown Castle’s proposed AT&T small cell deployment in Palos Verdes, California.  As you can see from this photo simulation, Crown Castle’s “small cells” aren’t all that small, particularly if they want to locate it in your front yard.

neighborhood cell tower

Crown Castle photo simulation of a proposed streetlight cell tower site in a residential neighborhood (Via Rivera) in Rancho Palos Verdes.

As we dug into it, we were truly astonished by the quantity of misleading site documentation, highly questionable technical claims, and false legal claims of entitlement.  Even more surprising to us was that these tactics were seemingly accepted, no one questioned it, this was just how the game was played.  It sort of reminded us of when you take your car to the body shop and the guy asks you if need a a real estimate or one for the insurance company (wink, wink).

We find this behavior highly offensive.  Consider that Crown Castle and the others claim an entitlement to place highly intrusive cell towers in residential neighborhoods right next to people’s homes.  No one wants a commercial telecommunication facility right next to their house.  They are ugly, often noisy, and have a significant negative impact on neighboring home values. Would you buy a home with an obvious cell tower several dozen feet away?  For most families their home is their biggest investment.  Yet these good folks are just supposed to suck it up and accept it so that these companies can hit their return on investment targets.

When it happens people feel helpless and with good reason.  It’s a David vs. Goliath situation, as a multi-billion dollar corporation has invaded their quiet little street allegedly justified by a bunch lofty legalese and technical mumbo-jumbo.  Even worse, the governing municipality whose primary obligation is to serve residents, often responds with “there is nothing we can do about it”.  It’s not true of course, but no one in City Hall wants a lawsuit on their watch. City staff may not be consciously thinking about it, but who would they rather have mad at them; a few residents or a sue-happy corporation?

Regarding the technical issues, well these guys are the experts and if they say it then it must be true, right?  Actually, no.  The level of false technical claims we’ve found and documented is truly staggering.  These “errors” could conceivably result from carelessness and incompetence rather than deception, though they do always seem to be to the cell tower applicant’s advantage.  It certainly doesn’t seem to be random.  If it is, these guys should head to Vegas as they’re on a hot streak.

What we aim to accomplish

We first started this blog after finding there was nothing on the internet like it.  The problems we were finding in Palos Verdes were systemic and we had a hard time believing they were isolated to our community.  Our goals were four-fold:

  • Maintain an accessible repository for relevant information and documentation regarding Crown Castle’s AT&T deployment
  • Inform Palos Verdes residents regarding the discrepancies we’ve uncovered, of our municipal rights to regulate these sites, and what residents can do about it
  • Provide a resource for those in other communities who may be in a similar situation
  • Document discrepancies in the event of future legal action

With regards to the last point, we’ve only put up a sampling of what we’ve found as it’s probably best not to show all one’s cards.  But here’s the thing, if a multi-billion dollar corporation is going to demand an entitlement to place a highly intrusive cell site right next to someone’s home, they better make sure every freaking “i” is dotted and “t” is crossed.  As anyone who follows these cases closely knows, this type of carelessness is the stuff that loses lawsuits.  Instead the submitted documentation is laughable.  Let’s just say the level of “carelessness” we’ve found is truly astounding.

Thanks!

Thanks to all that have visited the site.  We got a bunch of new emails via our contact page this week and are working to get back to everyone.  Please bookmark us and check back regularly as we usually put up new posts once a week or so.

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