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9 Mr. Ross’ report also explains that, to comply with FCC RF standards, significant portions of the tower would have to be shut down altogether if multi-story buildings are constructed on the neighboring properties. It is not sensible to approve a large tower of this type to only render it largely unusable when the surrounding land uses are properly improved as desired by the General Plan. This is particularly paradoxical because the tower appears to be designed to serve a growing nearby population but such service will be infeasible from this location if it is curtailed to avoid unsafe RF exposure to adjacent residents. The Housing Element, housing opportunity site analysis, attached as Attachment B, anticipates that the property proposed for the cell tower and the appellant’s property “is lot consolidation potential[.]” Placing the tower in along the lot line makes that impossible. Even if the RF issue was addressed, the location of the tower structure, which exceeds the normal, allowable height for a building in the zone, would have a detrimental impact to the southern views of future occupants of Mr. Russo’s property and, given the southern sun exposure, cast a long shadow over the site. The City must also recognize that, once it approves this facility, under federal law, the site owner or a future wireless service provider can increase the height of the tower by up to 20-feet as a matter of right, provided the expansion is clad with the same faux tree materials.14 Plainly, this is not an intelligent location for this macro tower. V. The tower should be built to public safety standards. The appeal expresses concern that the tower’s height poses a risk to adjacent properties in the event of earthquake or high winds. As explained by Mr. Ross, towers intended for public safety purposes are subject to special engineering standards known as APCO ANS 2.106.1-2019. The 14 47 C.F.R § 1.6100(b)(7). Att B - Page 29 of 46