May 27, 2015 <br />Page 3 <br />• The author of the report did not perform a site visit so he does not have the <br />requisite first-hand knowledge to provide factual testimony. <br />Eugene City Code ("ECC") 9.5050c(5) provides the submittal requirement for radio <br />frequency, as follows: "A statement providing the reasons for the location, design and <br />height of the proposed tower or antennas." It should be noted that the RF materials <br />submitted here are in the same format as those submitted and approved in the Rest <br />Haven cell tower application last year. <br />AT&T provided the city with a statement of RF Justification, which has been <br />supplemented to address alternative sites as they were considered. An additional <br />supplement Exhibit 2 attached, further addresses the issues raised by the staff report. <br />It should be noted that the city has performed several reviews of the application <br />materials and did not request any supplemental Radio Frequency("RF") information, nor <br />did it request any underlying data. After the application was deemed complete, AT&T <br />responded to the city's remaining requests for additional information in other areas, <br />made after that date. The first indication that AT&T had that the RF information was <br />being questioned was the consultant's initial report dated April 16, 2015 (HOA Ex.2) , <br />which stated that information was lacking to verify the statements in the record, but <br />failed to specify what information the consultant required to complete his review. <br />The second consultant report was provided to AT&T on May 13, 2015, at the end of the <br />business day. HOA-Ex.3 This second report mentions a copyrighted form the consultant <br />uses to gather information to conduct his review. The form was not provided to AT&T, <br />nor was a request from the city forthcoming for any additional RF information. AT&T's <br />counsel followed up by email asking if additional information was being requested by <br />the city. (Ex 1 attached.) There was no response. <br />B. Staff Report Identified Issues <br />Staff has identified the following areas of concern, which AT&T will address at the <br />hearing, as follows: <br />• EC 9.8090(1): Consistency with Metro Plan Policy E.4 <br />AT&T Response: AT&T has submitted 29 separate photo simulations in response to <br />multiple staff requests for additional vantage points and features. The photo <br />simulations were last supplemented on March 27, 2015 to reflect a slimmed redesign to <br />