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International Public Safety Grade Site Hardening Requirements ANS 2.106.1, the National <br />Electric Code (NEC) 2020 edition and the National Fire Protection Association Fire Code 1 <br />(2024).1 <br />It is also recommended that the following items be required in any telecommunications permit <br />application: <br />• A detailed list of all associated equipment necessary for operation, with load <br />calculations. <br />• A one-line diagram of the electrical system, and a plot plan showing the location of the <br />service disconnecting means. <br />• A short circuit and coordination study (“SCCS”) calculated pursuant to the IEEE 551- <br />2006: "Recommended Prac7ce for Calculating AC Short-Circuit Currents in Industrial <br />and Commercial Power Systems" or the latest version of that standard. <br />• A set of structural plans demonstrating that the supporting structure will be able to <br />sustain the burden imposed by the equipment pursuant to APCO requirements. <br />For an example of an updated code, please see the Malibu, California "Fire & Safety <br />Protocol" contained on pp. 3 and 4, items 16 and 17. <br />https://malibucity.org/DocumentCenter/View/28468/PLN-WP_WRP- Submittal- <br />Checklist# <br /> <br />In addition, it is strongly recommended that <br />• The code allows the municipality, at its discretion, to select and retain independent <br />consultant(s) with expertise and appropriate credentials in telecom and/or electrical and <br />fire safety to review and assess all applications for small cell and macro tower antenna <br />installations, including, but not limited to, application completeness and accuracy, <br />engineering analysis, and compliance with fire and safety codes and FCC radio frequency <br />emissions limits. <br />• Where codes permit, retroactive analysis of existing antennas for structural integrity, and <br />conformity with recently upgraded electrical and fire safety recommendations should be <br />performed to ensure citizen safety. <br />• Require review by non-industry-aligned experts of the “technical feasibility” assertions <br />made by cell tower applicants. <br /> <br /> <br />Thank you for your foresight and consideration. <br /> <br />Cindy Russell, MD <br />Executive Director, Physicians for Safe Technology <br /> <br />References <br /> <br />City Wireless Ordinances <br /> <br /> <br />Wireless Permit (WP) and Wireless ROW Permit (WRP) Submittal Checklist / Packet. <br />City of Malibu. https://malibucity.org/DocumentCenter/View/28468/PLN-WP_WRP-Submittal- <br />Checklist?bidId=