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<br />1467 Mountain Meadow Drv., Oceanside CA 92056 <br />2 <br /> <br />Review of Submittal Completeness <br />Public Safety Towers, LLC is a third-party developer for cellular sites, primarily for <br />AT&T. FirstNet is a nationwide wireless broadband network that provides communications <br />“tools” for public safety and emergency responders. FirstNet was created to improve public <br />safety communications and help save lives. It was established in response to the 9/11 <br />Commission's recommendation to provide public safety agencies with modern communication <br />tools. The City of New York and all the cellular carriers had their communications antennas on <br />top of the Trade Centers, when they both collapse everything went down. Thus this “New” <br />system called FirstNet. The First Responder Network Authority is an independent federal <br />government agency that oversees FirstNet. However, FirstNet is being deployed through a <br />public-private partnership and service is provided commercially by AT&T. Subscribers have <br />access to FirstNet towers and all other AT&T antennas. <br />AT&T offers FirstNet wireless rate plans for public safety professionals, including the <br />FirstNet Wireless Broadband Core plan, which costs $65 per month and includes up to 25Mbps <br />speeds and 175GB of data. This site could provide service for the FirstNet, which is no more <br />than a paid AT&T service for first responders. First responders would be issued a prioritization <br />code per phone number so that when the AT&T system is overloaded, their call will be complete <br />in priority manner. Thes call are all considered “Non-Emergency,” no matter who places the call. <br />For example, a Firefighter can buy into the FirstNet wireless system and could receive a 1C24D <br />priority code. Where as a Fire Chief buying into the same system could receive a 1A400B <br />priority code, which in this case supersede the Firefighter’s 1C24D code. FirstNet is not free, <br />each device on the system is paid for by the individual or the organization if so desired. <br />The antenna equipment on this tower is identical to standard antennas used by AT&T to <br />serve its regular, non-FirstNet customers, and the application itself says as so: “In addition to <br />AT&T LTE-5G commercial facilities, this proposed Public Safety Tower will include facilities <br />to support FirstNet.” (ATTACHMENT C- Attachment 7- Alternative Site Analysis.) The <br />Alternative Sites Analysis claims FirstNet has a gap in LTE 700 in-building coverage. However, <br />because FirstNet subscribers can utilize other bands offered by AT&T, it is not at all clear that <br />there is in fact any gap in in-building LTE coverage offered by any band. Additionally, the <br />Antenna Inventory shows AT&T will also install 850 MHz, 1900 MHz, 2100 MHz, 2300 MHz, <br />3500 MHz and 3700 MHz antennas that do not address any asserted gap on 700MHz band in- <br />building coverage. (See ATTACHMENT C- ATTACHMENT EME Report, p. 7.) The <br />Application similarly does not discuss other means of addressing any LTE 700 in-building gap, <br />such as with multiple small cells in the right-of-way. <br /> <br />Given that the tower is a conventional AT&T tower and FirstNet subscribers have access <br />to all AT&T towers, this Five-Year Plan statement (ATTACHMENT C- Attachment 7) is <br />incomplete: <br />Regarding future tower development in the area, aside from the currently proposed tower, <br />PSTC has no additional projects planned for the next five years within the jurisdiction of <br />the City or within one-quarter mile of the border thereof. <br />The relevant consideration is not just Public Safety Tower, LLC, but rather any planned AT&T <br />towers, as these also provide the proposed service, which are not discussed. <br />Att B - Page 41 of 46