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Pleasanton Planning Commission November 13, 2013 Page 2 of 4 centers, and parks. As the staff report points out, this puts a large part of the City off limits to wireless facilities, and has resulted in coverage gaps and other unintended consequences. Moreover, given that not even "concealed" facilities are allowed in such locations and zones, there is no apparent rationale for ruling them out other than the fear of radio- frequency emissions. As the staff report acknowledges, that concern is preempted by the federal Telecommunications Act and is not a permissible basis for local regulation. 300-foot buffer zones The Proposed Amendments would relax but not dispense with the ban on facilities within 300 feet of dwelling units, schools, senior centers, and parks. While the amendments would exempt facilities that are "concealed,"the 300-foot setback would continue to apply to all other facilities, including those deemed merely"camouflaged," which would include faux trees and antennas flush-mounted against a commercial building and painted to match its exterior. There does not appear to be a legitimate reason to distinguish between concealed and camouflaged facilities. Both should be exempt from the 300-foot buffer. More broadly, the 300-foot buffer simply exacerbates the problems caused by the ban on facilities in certain zones and locations, and here too, the only apparent justification is the preempted concern about RF emissions. If the City really wants to improve wireless coverage, it should dispense with both the 300-foot setbacks and the area-wide bans. Other problems On cursory review, we have identified several other problems that are either created by or not addressed in the Proposed Amendments. These include: • Requiring applicants to demonstrate a coverage gap using a"drive test" as uniquely defined by the City(§ 18.110.040.A.10). While a true drive test is a useful means of identifying a gap in existing coverage, the type of"drive test" contemplated in the ordinance—in which one person places a hand-held transmitter in the location of the proposed facility and another then drives around to measure the signal—is to our knowledge unique to the City's ordinance, and in any event not recognized in the field as an established or reliable technique. • The Proposed Amendments would retain the unworkable requirement for applicants to submit city-wide "master plan" and map of existing and future facilities (§ 18.110.040.A.12-13). While it is possible to map the existing and proposed facilities, we question the value or relevance of mapping any facilities other than those which are in close enough proximity to "hand off' or interact with a proposed facility; in any case, neither Verizon Wireless nor its competitors have a crystal ball that would allow them to predict where they will need facilities at some indefinite time in the future.