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HomeMy WebLinkAboutCROWN CASTLEINvURANOE NOT REQUIRED A-2018-311 WORK MAY PROCEED CLERK OF COUNCIL ®QTc, FEB 0 5 2019 c(k 0 `j ) SETTLEMENT AGREEMENT AND MUTUAL RELEASE -50\4I ✓ ', This Settlement Agreement and Mutual Release (the "Agreement") is entered into as of December_, 2018 by and between CROWN CASTLE NG WEST LLC, a Delaware limited liability company ("Crown Castle"); and CITY OF SANTA ANA, a charter city and municipal corporation in the State of California (the "City"). Crown Castle and the City are occasionally collectively referred to herein as the "Parties," or individually as a "Party." This Agreement is being made by the Parties based upon the following recitals of facts: RECITALS A. WHEREAS, on September 5, 2017, Crown Castle filed ten (10) applications with the City for permits authorizing the installation of Wireless Telecommunication Facilities ("WCFs") in the public right-of-way (the "Permit Applications") pursuant to and in accordance with Chapter 33, Article X of the Santa Ana Municipal Code ("SAMC"). Pursuant to the Permit Applications, Crown Castle sought to place ten (10) small cell nodes comprised of 2-8 inch radios with integrated antennas on ten (10) new utility poles (each a 31 -foot tapered steel pole). The Permit Applications are identified by the City as follows: SOC101-2800 N. Main Street; SOC102 - 2700 N. Main Street; SOC458 - 310 E. Memory Lane; SOC459 - 15241 E. Memory Lane; S00007 - 1421 West 17t' Street; S00O26 -1011 N. Main Street; S00075 - 1356 E. McFadden Avenue; S00054 - 1630 South Lyon Street; SOC273 - 3506 West Lake Center Drive; and SOC268 - 3401 S. Harbor Boulevard. B. WHEREAS, on September 28, 2017, after the City's initial review of the Permit Applications, the City transmitted by email a notice of incompleteness dated September 28, 2017, for each of the ten (10) Permit Applications; subsequently, Crown Castle responded by delivering additional information by electronic mail on September 28, 2017 and hand -delivering hard copies of additional information on September 29, 2017. C. WHEREAS, on February 5, 2018, the City pursuant to SAMC Sec. 33-239(a) transmitted denials of all ten (10) Permit Applications via individual denial letters from the City's Public Works Agency (the "Denials"). D. WHEREAS, on or about March 26, 2018, Crown Castle transmitted a letter to the City alleging that the Permit Applications were not lawfully denied, and were "deemed approved" pursuant to California Government Code section 65964.1 (the "Crown Castle Letter"). E. WHEREAS, on or about April 25, 2018, the City filed an action seeking judicial review of the alleged deemed approval in the matter of City of Santa Ana v. Crown Castle NG West LLC, Case No. 30-2018-00988490-CU-MC-CJC (the "Action"). On June 22, 2018, the City served the Complaint filed in the Action on Crown Castle. Following two orders extending time for Crown Castle to file a responsive pleading, both granted to allow time for the negotiation of a potential settlement, Crown Castle filed an Answer to the City's Complaint on October 22, 2018, and a First Amended Answer on November 14, 2018. A Case Management Conference for the Action has been set for January 11, 2019. 1129494.1 L/LA 377510-00002/12-19-1 gMm/bsb F. WHEREAS, without either admitting or denying any fact or allegation, by this Agreement, the Parties hereto have agreed to a process to fully and completely resolve all disputes and claims that the Parties now have arising out of or relating to the Permit Applications, proposed WCFs, and/or the Action. G. WHEREAS, a declaratory ruling and order was adopted by the Federal Communications Commission on September 26, 2018 In the Matter of Accelerating Wireless Broadband Deployment by Removing Barriers to Infrastructure Investment, WT Docket No. 17- 79 and Accelerating Wireline Broadband Deployment by Removing Barriers to Infrastructure Investment, WT Docket No. 17-84 (the "FCC Order"), and the FCC Order is the subject of several pending appeals in federal courts of appeal, and a reconsideration petition filed to the FCC. The Parties agree and acknowledge that the FCC Order may have a future impact on rental amounts due and owing under this Agreement, as set forth in detail herein. NOW, THEREFORE, in consideration of the terms, conditions and covenants herein set forth, the Parties hereto agree as follows: AGREEMENT 1. Motion to Stay the Action. On or before January 11, 2019, the 'Parties will file a joint request to stay the Action for six (6) months, to provide time for Crown Castle to submit new information regarding the Permit Applications that were subject to the Denials and for the City to review and act on such new information as set forth in this Agreement. 2. Re -Opening of Permit Applications & Review of Revised Applications. The City will re -open the Permit Applications, accept and consider the New Information identified at Section 3 hereof, and issue a determination in accordance with the modified timeline set forth at Section 6 hereof. The Permit Applications, together with the New Information and the Further Information (if any) submitted pursuant to this Agreement, shall be referred to as the "Revised Permit Applications." For purposes of this Agreement alone, the City and Crown Castle agree to toll the FCC shot clock applicable to the Permit Applications to allow for the City to act on the Revised Permit Applications and, if necessary, the completion of any appeals. Further, for purposes of this Agreement alone, the City hereby expressly waives any and all SAMC requirements that would otherwise prohibit the City's review of the Revised Applications in accordance with this Agreement. 3. Submittal of New Information. Within sixty (60) days of the Effective Date, Crown Castle will submit to City, by personal delivery, the following documents related to the Permit Applications (the "New Information"): a. four (4) sets of modified plans showing: i. the placement of the WCFs on 10 new street light poles to be installed by Crown Castle and owned by the City in accordance with Section 10 of this Agreement (the "City Poles") at the 10 locations mutually selected by the Parties and identified on Exhibit A to this Agreement (the "Revised Locations") rather than the original locations identified on the Permit Applications (the "Original Locations"); 1129494 11/LA 399510-00002/12-19-18k1.A,b -2- ii. the proposed design for the City Poles, using a design consistent with Exhibit B to this Agreement; b. three (3) sets of traffic control plans; however, this requirement shall be waived for any Revised Locations on the same block as the Original Locations; updated radio frequency emission reports or a stamped certification from a California -registered engineer indicating that the proposed WCF equipment and heights of the City Poles meet Federal Communications Commission (FCC) requirements and guidelines; d. permit inspection and issuance fees of $936.10 per site ($9,361.00 total), which represent fees for the 2017-18 fiscal year; however, the Parties agree that all other fees related to the Revised Permit Applications, including but not limited to those identified at Section 5 of this Agreement, shall be waived; and e. revised noticing materials in accordance with Section 4(b) of this Agreement. 4. Notice. In connection with the Revised Permit Applications, the Parties have agreed that the notices pursuant to SAMC Sec. 33-239 shall be provided as follows: a. Notices to owners of adjacent properties within a three -hundred foot radius of the Revised Locations ("Adjacent Properties") shall be provided as follows: Category 1 Revised Locations — New Application Notices Not Required Lor Revised Permit. Applications; Courtesy Notice to be Provided if Approved The Parties acknowledge and agree that for the following seven (7) Revised Permit Applications, the Adjacent Properties to the Revised Locations are the same as the Adjacent Properties to the Original Locations: (1) SOC 101— 2800 N. Main Street; (2) SOC 102 — 2700 N. Main Street; (3) S00007 — 1421 West 17a' Street; (4) S00O26 — 1011 N. Main Street; (5) S00075 — 1356 E. McFadden Avenue; (6) SOC273 — 3506 West Lake Center Drive; and (7) SOC268 — 3401 S. Harbor Boulevard (the "Category 1 Locations"). Accordingly, new application notices will not be provided to owners of the Adjacent Properties to the Category 1 Locations. However, Crown Castle acknowledges and agrees that for any Revised Permit Applications for Category 1 Locations that are approved, the City's approval will include, among other terms and conditions, a requirement that Crown Castle provide a courtesy notice with a color photo simulation of the approved WCF to the owners of the Adjacent Properties advising them of the actual WCF that was approved. ii. Category 2 Revised Locations —Application Notices Required for Revised Applications. The Parties further acknowledge and agree that for the following three (3) Revised Permit Applications, the Adjacent Properties to the Revised Locations are materially different from the Adjacent Properties to the Original Locations: (1) SOC459 —31.0 E. Memory Lane; (2) SOC459 —15241 E. Memory Lane; and (3) S00054 —1630 South Lyon Street (the 1129494.11/LA 377510-00002/12-19-18/elm/hsh -3- "Category 2 Locations"). Accordingly, Crown Castle shall submit to the City the following noticing materials for the Category 2 Locations: new mailing labels for all Adjacent Properties; color photo simulations of the proposed WCFs and City Poles; and radius maps for the new mailer. The City shall then provide the notice required by SAMC Sec. 33-239 to the owners of Adjacent Properties to the Category 2 Locations. b. Application Notices shall be provided to neighborhood associations representing residential properties in Category 2 Locations only. However, Crown Castle acknowledges and agrees that for any Revised Permit Applications for Category 1 Locations that are approved, the City's approval will include, among other terms and conditions, a requirement that Crown Castle provide a courtesy notice with a color photo simulation of the approved WCP to the neighborhood associations representing residential properties in the Category 1 Locations advising them of the actual WCF that was approved. c. Posting of a notice at the proposed installation site on the existing street light or similar structure to be replaced, or as close thereto as reasonably possible shall be required for Category 2 Locations only. 5. Fee Waivers. For the purposes of this Agreement only, the City will honor the 2017-18 fiscal year fees for permit inspection and issuance and will also waive the following fees: (1) accrued and unpaid plan check fees for the Permit Applications in the amount of $9,493.12; and (2) application fees for the Revised Permit Applications; and (3) plan check fees for reviewing the New Information related to the Permit Applications. 6. Timeline for City Action on Revised Permit Applications. a. Submittal of New Information by Crown Castle. Within sixty (60) days of the Effective Date, Crown Castle will submit to City, by personal delivery, the New Information listed at Section 3 of this Agreement. Within ten (10) calendar days of submittal of the New Information related to the Permit Applications, the City will tender any request for clarification or additional information to Crown Castle ("Further Information"). Crown Castle will provide the requested Further Information, or a response regarding the timeline to prepare the same, within five (5) calendar days of such request. b. Revised Permit Applications Deemed Complete. The Revised Permit Applications shall be deemed "complete" and the review periods set forth at Sections 6(c) and 6(d) below shall commence upon any of the following: (i) if the City does not timely request Further Information, at the conclusion of the tenth calendar day following Crown Castle's submittal of the New Information; or (ii) if the City does request Further Information, upon the earlier of (x) City's receipt and written acknowledgment that the Further information or (y) five (5) calendar days after Crown Castle's submittal of the Further Information. 1129494.11/LA 377510-00002112-19-18/,InAsb -4- c. City Review of Category 1 Applications. The City agrees that the executive director of the public works agency, or his or her designee, ("Director," per SAMC Sec. 33-231) will act on each Revised Permit Application for a Category I Location within thirty (30) calendar days after the Revised Permit Application is deemed complete according to Section 6(b). d. City Review of Category 2 Applications. The City agrees the Director will act on each Revised Permit Application for each Category 2 Location within sixty (60) days after the Revised Permit Application is deemed complete according to Section 6(b); provided that, irrespective of whether a Revised Permit Application has already been deemed complete according to Section 6(b), Crown Castle shall work cooperatively with the City in accordance with SAMC Sec. 33-239 to consider or otherwise respond to any comments on the Revised Permit Application received by the Director within thirty (30) days from the date the corresponding notice required by Section 4 is provided. e. Appeals. In the event of any timely appeal of a decision on any of the Revised Permit Applications, the City shall take final action on the appeal within the timeframe set forth under the uniform hearing and appeal procedures set forth at Chapter 3 of the SAMC. The City agrees and acknowledges that in the event the Director conditionally approves or denies a Revised Permit Application, Crown Castle shall retain all rights to appeal the denial or conditions imposed by the Director in accordance with Chapter 3 of the SAMC. f. Independent Review. The City's decision on each Revised Permit Application will be made independently and will not impact the approval or denial of the other Revised Permit Applications. 7. Impact of City Decision on Revised Permit Applications. The City can make no guarantee or assurances that it will approve the Revised Permit Applications. However, the Parties agree that an approval or denial of a Revised Permit Application or Applications will have the following impact on the Parties' respective rights and the Action. a. Director's Decisions. The Director shall issue a decision on each Revised Permit Application. The City agrees and acknowledges Crown Castle shall have the right under the SAMC to appeal those Director's decisions on the Revised Permit Applications which are denials as well as any approvals which it believes include conditions that vary materially from the proposed WCF included in the corresponding Revised Permit Application. b. Impact ol"City Approval of Seven or More Revised Permit Applications — Waiver of Claims & Dismissal ofAction. If the City's final action on at least seven (7) of the Revised Permit Applications is an approval, all the City's decisions replace the Denials for all the corresponding sites and further, (i) Crown Castle will (a) withdraw its 'Letter and (b) agree in writing not to invoke California Government Code section 65964.1 with respect to either the Permit Applications or the Revised Permit Applications; and (ii) City shall, within ten (10) business days of the 1129494.11/LA 377510-00002/12-19-1 N/ahrJbsb -5- expiration of the applicable appeal period(s), file a Request for Dismissal with Prejudice of the Action, thereby terminating the Action. c. Impact of City Approval of Less Than Seven Revised Permit Applications — No Waiver or Dismissal. If the City's final action is to approve less than seven (7) of the Revised Permit Applications, then the City's approval of a Revised Permit Application will replace the Denial of the earlier Permit Application for that site. With regard to any Revised Permit Applications denied by the City by final action and any Denials that are not replaced by a final action on the corresponding Revised Permit Application (the "Denied Sites"), the Parties shall reserve all arguments with respect to the Denied Site, including but not limited to the claims and arguments set forth in the Crown Castle Letter and the Complaint in the Action, except for a denial (if any) of a Revised Permit Application that involves a public hearing before a Hearing Officer on appeal. The Parties agree that any decision on a Revised Permit Application made by a Hearing Officer at a noticed public hearing is final and will replace the Denial of the earlier Permit Application for that site. d. The Parties further agree that, under either scenario outlined at subdivisions (b) and (c) above, Crown Castle will retain the right to challenge any denial of a Revised Permit Application on the merits, regardless of whether that denial is by final action of the Director or of a Hearing Officer on appeal. e. In the event, following City action on the Revised Permit Applications, claims remain as to certain Denied Sites, the Parties will promptly make appropriate filings to narrow the scope of the Action only to Denied Sites that remain the subject of Denials. If there are no such Denied Sites, (i) Crown Castle will instead (a) withdraw its Letter and (b) agree in writing not to invoke California Government Code section 65964.1 with respect to either the Permit Applications or the Revised Permit Applications; and (ii) City shall, within ten (10) business days of the expiration of the applicable appeal period(s), file a Request for Dismissal with Prejudice of the Action, thereby terminating the Action. Crown Castle shall retain all rights and arguments described above with respect any of the Denied Sites until the conclusion of any relevant appeals periods. 8. Decommissioning of Existing Poles at Revised Locations. The Parties agree and acknowledge that there are existing poles located near to the Revised Locations as shown on Exhibit A (the "Existing Poxes"), which are currently owned by Southern California Edison ("SCE") and are a part of SCE's ongoing "buy back" program, in which City is a participant. For Revised Permit Applications that are approved, the Parties agree and acknowledge that SCE and/or City will be responsible for completing the procedures required by the "buy back" program to decommission the Existing Poles, and for removing the Existing Poles, separately and independently from the installation of the City Poles at the Revised Locations by Crown Castle. The Parties also agree to cooperate with regard to the decommissioning and removal of the Existing Poles at such Locations. The Parties further agree that Crown Castle will have no responsibilities or exposure to liability relating to any use, decommissioning, or removal of the Existing Poles. 1129494.1 VLA 397510-00002/12-19-18/ah.bsb -6- 9. Effective Date. The "Effective Date" of this Agreement shall be the date this Agreement is signed by the last party to sign it. 10. Installation of City Poles and WCFs by Crown Castle. The Parties agree and acknowledge that Crown Castle will place a new City Pole at each of the Revised Locations that receives approval of the Revised Permit Application in accordance with the approved Revised Permit Application and plans. The Parties agree that Crown Castle may proceed with installation of the approved City Poles and associated WCFs prior to the completion of the decommissioning and removal process of the Existing ,Poles by SCE or City, and that Crown Castle's installation of such City Poles may proceed and remain in place regardless of the status or success of the decommissioning process. Pursuant to a form mutually acceptable to the Parties, Crown Castle will transfer ownership of the City Poles and any associated manufacturers warranties to the City immediately upon installation at the Revised Locations. 11. Rent. Crown Castle will pay an annual rental fee to the City for the non-exclusive use of space on all of the City Poles for the WCFs ("Annual Rent") in accordance with the following terms and conditions: a. Crown Castle will pay Annual Rent in the amount of $1,000 per year, per City Pole with no escalation for an initial two (2) year term (the "Initial Term") commencing on the date of installation of the first City Pole. The Annual Rent for the initial year of the Initial Term shall be due and payable to the City within sixty (60) days after the installation of the first City ,Pole. At the commencement of the Initial Term, Crown Castle shall have the right, but not the obligation, to pre -pay the Annual Rent for both years of the Initial Term. b. At the conclusion of the Initial Tenn, the term will automatically extend for an additional eight (8) years (the "Remaining Tenn"). Crown Castle shall have the right but not the obligation to further extend the Remaining Term for up to two (2) additional five (5) year periods (each a "Renewal Term") by providing written notice to the City at least ninety (90) days prior to the expiration of the then -current term; provided that Crown Castle has no uncured defaults under this Agreement as of the date each such Renewal Term would go into effect. c. At the conclusion of the Initial Term, the Parties agree that for the duration of the Remaining Term, and any Renewal Terms, Crown Castle will pay the following amount of Annual Rent: i. if the FCC Order is final and effective (as evidenced by a final non - appealable order of a court of competent jurisdiction upholding the FCC Order) at the conclusion of the Initial Term, the amount of "fair and reasonable compensation" under Section 253(c) of the Communications Act that is permitted by the FCC Order per year, per City Pole; or ii. if, at the conclusion of the Initial Term, the appropriate rental amount that complies with the FCC Order is unclear, or the FCC Order is not final and effective (as evidenced by a final non -appealable order of a court of 1129494 L VLA 377510-00002/12-19-18/d./b,b -7- competent jurisdiction upholding the FCC Order) — the amount of $1,000 per year, per City Pole, with no escalation. 12. City Poles — Crown Castle Responsibilities. a. Installation (?f Luminaires. Crown Castle will install luminaires on each of the City Poles (the "Luminaires") for the purpose of providing light within the public right- of-way areas surrounding the Revised Locations. The Parties will cooperate in designating the type of luminaire appropriate for the City Poles and agree that the WCF installation design will be generally consistent with the concept photos attached hereto as Exhibit B; or if those are technically infeasible, with an alternative design approved by the City. The Parties agree that Exhibit B is intended to provide conceptual examples of the appropriate design for the WCF installations, and that actual specifications for the same will be included in the design drawings submitted to the City. b. Provision of Electrical Power to WCFs and Luminaires. Crown Castle further agrees that it will, at its sole cost and expense, be responsible for the provision of electrical power to the WCFs and Luminaires. No above -ground meter pedestal will be installed unless unmetered power is technically infeasible or unviable due to SCE policy or requirements. The Parties shall work together to negotiate a flat Wireless Technologies Rate ("WTR") or similar unmetered rate or rates for the WCFs and Luminaires with SCE. If an unmetered solution is not possible or permitted by SCE, the Parties will agree upon an appropriate alternative solution for providing electrical power to the WCFs and Luminaires. c. Maintenance & Inspections. Crown Castle hereby agrees that it will maintain the WCFs and City Poles in accordance with Section 13 of this Agreement. Crown Castle may conduct, at its sole expense, routine inspections of the WCFs and supporting structures. d. Reservation of Rights. Crown Castle reserves the right to operate and maintain its WCFs, to discontinue such maintenance, and to remove its WCFs from the City Poles, in the manner it deems best to fulfill its own service requirements, and its public, employee and worker safety obligations. e. Right of Way Access. To the extent not already governed by applicable law, the City hereby grants access to public rights-of-way as necessary for Crown Castle to conduct the installation, operation, maintenance, and inspection responsibilities for the WCFs, City Poles, and Luminaires as required by this Agreement or any condition to the Revised Permit Application approvals. 13. Maintenance of WCFs, City Poles, & Luminaires. Crown Castle hereby agrees that itwill maintain the WCFs and City Poles in good condition, appearance and operation, and in compliance with all applicable state, county, city, or government agency laws, ordinances and requirements now in force or hereafter enacted (the "Applicable Laws"). Crown Castle, at Crown Castle's sole expense, shall whenever required, promptly make all repairs, replacements, 11294941 I/LA 377510-00002/12-19-1R/elmPoeb -8- alterations, or improvements to the WCFs and/or City Poles needed to comply with the Applicable Laws or the requirements of this Agreement. Crown Castle must take action promptly to correct any conditions related to the WCFs and/or City Poles that threaten the public health or safety. If Crown Castle fails to do so, City may step in and take corrective action at Crown Castle's expense. The Parties acknowledge and agree that during the term set forth in Section 11, Crown Castle shall have the non-exclusive right to install, operate, maintain, modify, and/or repair the WCFs, and the exclusive obligation to install, operate, maintain, modify, and/or repair the City Poles. Notwithstanding the foregoing sentences, Crown Castle understands and agrees that it may not modify the appearance of the approved WCFs, Luminaires, or City Poles without obtaining the prior written approval from the Director or his designee, said approval not to be unreasonably withheld. City may require Crown Castle to relocate, at the City's sole cost and expense, any City Pole, along with the associated Luminaire and WCF, upon ninety (90) days' prior written notice to Crown Castle, whenever City reasonably determines that the relocation is needed for any of the following purposes: (a) if required for the construction, modification, repair, relocation, or maintenance of a City or other public agency project; (b) because the WCF is interfering with or adversely affecting proper operation of City facilities; or (c) to protect or preserve the public health or safety. In any such case, City shall use reasonable efforts to afford Crown Castle a reasonably equivalent alternate location for the City Pole. The Parties agree that Crown Castle shall be responsible for installation and the cost of powering of the Luminaires, and all other responsibilities relating to these fixtures shall be the responsibility of the City. The City understands and agrees that following installation of the Luminaires on the City Poles by Crown Castle, including any re -installation of a Luminaire that may be required during the term of this Agreement due to destruction of the City Pole and replacement of that City Pole, all other responsibility for the maintenance, repairs, light/fixture/part replacements, alterations, or improvements to the Luminaires shall be the responsibility of the City. 14. Termination of Use of City Poles. Crown Castle shall have the right to terminate its use of any City Pole upon thirty (30) days' written notice to City and compliance with this section. If City determines that Crown Castle has violated its obligations under Section 10, 11, 12 or 13 of this Agreement with respect to one or more WCFs, Luminaires, and/or City Poles, City shall have the right to terminate Crown Castle's use of any affected City Pole if Crown Castle does not cure such violation within sixty (60) days following written notice. This sixty (60) day cure period shall not apply to violations that affect the public health or safety. In the event of any termination of Crown Castle's right to use any City Pole, City shall return any annual rent already paid for use of the City Pole following the date of removal of the WCF, and within thirty (30) days after such termination of use of the City Pole, Crown Castle shall safely remove the WCF from the applicable City Pole (and the associated meter, if any), and repair any damage caused by such removal. Once the WCF is removed in accordance with this provision, or upon final removal of all WCFs at the termination of this Agreement, Crown Castle shall no longer be responsible for the City Poles and Luminaires or payment of Annual Rant. 15. Attorneys' Fees and Costs. The Parties shall bear their own attorneys' fees and costs expended in the litigation of the Action and in the preparation of this Agreement. 16. City's Release. Except for the obligations set forth herein, City, on behalf of City and its respective officers, agents, employees, representatives, successors and assigns ("City Releasors"), and each of them, shall and hereby do relieve, release, exonerate and forever discharge 1129494.11/LA 377510-00002/12-19-1 8/d./hb -9- each person or entity comprising Crown Castle and each of their respective officers, directors, shareholders, members, managers, partners, trustees, attorneys, employees, agents, beneficiaries, nominees, affiliates, predecessors, successors and assigns, and each of them (collectively, the "Crown Castle Released Parties"), from any and all claims, debts, liabilities, obligations, costs, fees (including attorneys' or consultants' fees and costs), penalties, fines, judgments, damages, rights, demands, liens, covenants, warranties, suits, actions, and/or causes of action of whatever nature, known or unknown, fixed or contingent, which arise out of or relate to the Permit Applications, Revised Permit Applications, WCFs, and/or the Action which may exist in favor of City Releasors and against the Crown Castle Released Parties as of the date of this Agreement. This release expressly includes claims with respect to the subject matter of the Action, of which City Releasors are presently unaware or which City Releasors do not presently suspect to exist which, if known by City Releasors, would materially affect City Releasors' release to the Crown Castle Released Parties. City, and to the extent allowable by law, City Releasors, expressly waive any of their rights granted under California Civil Code section 1542 (as well as any other statutes or common law principles of similar effect pertaining the foregoing release), which provides as follows: "A GENERAL RELEASE DOES NOT EXTEND TO CLAIMS WHICH THE CREDITOR DOES NOT KNOW OR SUSPECT TO EXIST IN HIS OR HER FAVOR AT THE TIME OF EXECUTING THE RELEASE, WHICH IF KNOWN BY HIM OR HER MUST HAVE MATERIALLY AFFECTED HIS OR HER SETTLEMENT WITH THE DEBTOR" City represents and warrants to Crown Castle that City has executed this Agreement with full knowledge of any and all rights which City or City Releasors may have by reason of any of the matters described herein. City, on behalf of itself and, to the extent allowable by law, on behalf of City Releasors, hereby further assumes the risk of mistake of fact in connection with the true facts involved in connection with the matters described herein, and with respect to any facts which are now unknown to City relating thereto. 17. Crown Castle's Release. Except for the obligations set forth herein, Crown Castle, on behalf of Crown Castle and Crown Castle's respective officers, directors, shareholders, members, managers, parent companies, subsidiary companies, partners, employees, agents, attorneys, nominees, predecessors, successors and assigns ("Crown Castle Releasors"), and each of them, shall and hereby do relieve, release, exonerate and forever discharge City and each of its respective officers, agents, employees, representatives, successors and assigns, and each of them (collectively, the "City Released Parties"), from any and all claims, debts, liabilities, obligations, costs, fees (including attorneys' or consultants' fees and costs), penalties, fines, judgments, damages, rights, demands, liens, covenants, warranties, suits, actions, and/or causes of action of whatever nature, known or unknown, fixed or contingent, which arise out of or relate to the Permit Applications, Revised Permit Applications, WCFs, and/or the Action which may exist in favor of Crown Castle Releasors and against the City Released Parties as of the date of this Agreement. This release expressly includes claims with respect to the subject matter of the Action of which Crown Castle Releasors are presently unaware or which Crown Castle Releasors do not presently suspect to exist which, if known by Crown Castle Releasors, would materially affect Crown Castle Releasors' release to the City Released Parties. Crown Castle, and to the extent allowable by law, 1129494.11/LA 37751 M0007/12-19-1 SM./bsb -to- the Crown Castle Releasors, expressly waive any of their rights granted under California Civil Code section 1542 (as well as any other statutes or common law principles of similar effect pertaining the foregoing release), which provides as follows: "A GENERAL RELEASE DOES NOT EXTEND TO CLAIMS WHICH THE CREDITOR DOES NOT KNOW OR SUSPECT TO EXIST IN HIS OR HER FAVOR AT THE TIME OF EXECUTING THE RELEASE, WHICH IF KNOWN BY HIM OR HER MUST HAVE MATERIALLY AFFECTED HIS OR HER SETTLEMENT WITH THE DEBTOR" Crown Castle represents and warrants to City that Crown Castle has executed this Agreement with full knowledge of any and all rights which Crown Castle or Crown Castle's Releasors may have by reason of any of the matters described herein. Crown Castle, on behalf of itself and, to the extent allowable by law, on behalf of Crown Castle's Releasors, hereby further assumes the risk of mistake of fact in connection with the true facts involved in connection with the matters described herein, and with respect to any facts which are now unknown to Crown Castle relating thereto. GENERAL PROVISIONS 18. Attorneys' Fees and Costs for Future Enforcement or Dispute Over This Agreement. Should any dispute arise between the Parties hereto or their legal representatives, successors and assigns concerning any provision of this Agreement or the rights and duties of any person in relation thereto, the party prevailing in such dispute shall be entitled, in addition to such other relief that may be granted, to recover reasonable attorneys' fees and legal costs in connection with such dispute. 19. Informed Consent. Crown Castle represents and warrants to City, and City represents and warrants to Crown Castle, and the Parties agree with the other, that each Party has either received independent legal advice from its counsel or has been given the option to receive independent legal advice from their respective counsel with respect to the advisability of malting the settlement provided for herein, and with respect to the advisability of executing this Agreement and the respective Releases; and each of the undersigned further declare that they understand the contents hereof, and it is executed voluntarily with full knowledge of its significance. 20. No Admission of Liability. The Parties hereto agree that this Agreement and Release is a compromise settlement of a disputed claim and shall not be construed as an admission of liability by any Party. This Agreement and Release shall not be asserted or relied upon as evidence in any arbitration, litigation, or other administrative or court proceedings for any purpose except to enforce its terms. 21. Choice of Law/Venue. This Agreement shall be governed by and construed under the laws of the State of California. If any provision of this Agreement is invalid or contravenes California law, such provision shall be deemed not to be a part of this Agreement and shall not affect the validity or enforceability of the remaining provisions. Nothing contained herein shall be construed so as to require the commission of any acts contrary to law, and wherever there is a 1129494.1 I/LA 347510-00002/12-19-18/d.A,* -11- conflict between any provisions of this Agreement and any present or future statute, law, ordinance or regulation, the former shall be curtailed and limited only to the extent necessary to make it comply with such statute, law, ordinance or regulation. Any action arising out of this Agreement, or the matters addressed herein, shall be brought within the Superior Court for the State of California, County of Orange. 22. Construction and Interpretation. The Parties hereto agree that this Agreement and Release shall be construed and interpreted in accordance with the laws, rules and regulations of the State of California. The headings in this Agreement and Release are inserted for convenience only and shall not be deemed a part of this Agreement for construction or interpretation. 23. Counterparts. This Agreement may be executed in counterparts, including signatures of any party to a counterpart which is delivered by fax or email, each of which shall be deemed an original, but such counterparts, when taken together, shall constitute one agreement. 24. Successors and Assigns. Except as otherwise set forth herein, this Agreement shall be binding upon and inure to the benefit of the Parties and their respective heirs, beneficiaries, legal representatives, successors and assigns. 25. Integrated Agreement. This Agreement expresses the entire agreement of the Parties hereto relating to the claims released herein. There are no other agreements, written or oral, express or implied, between the Parties, and/or their successors and assigns, with respect to the matters released herein. 26. Modification. This Agreement may not be altered, amended or modified in any respect except by written agreement of the Parties, duly executed by the Party or Parties to be charged. 27. Authority. Each individual executing this Agreement represents, warrants and certifies that he or she has full power and authority to execute and bind his or her respective principal and his or her execution of the Agreement is valid and enforceable against the principal in accordance with its terms. 28. Further (Documents. The Parties hereto agree to execute and deliver such other additional documents as may be required to effectuate each of the terms of this Agreement. 29. Notices. All notices which shall or may be given pursuant to this Agreement shall be in writing and delivered personally or transmitted (a) through the United States mail, by registered or certified mail, postage prepaid; or (b) by means of prepaid overnight delivery service, addressed as follows: if to City: City of Santa Ana Executive Director of Public Works 20 Civic Center Plaza Santa Ana, CA 92701 1129494.11/LA 377510-00002/12-19d8/,1nA,b -12- With copy to: City Attorney (same address) if to Crown Castle: Crown Castle NG West LLC c/o Crown Castle 2000 Corporate Drive Canonsburg, PA 15317 Attn: Ken Simon, General Counsel With a copy to: Crown Castle NG West LLC c/o Crown Castle 2000 Corporate Drive Canonsburg, PA 15317 Attn: SCN Contracts Management Notices shall be deemed given upon receipt in the case of personal delivery, three days after deposit in the mail, or the next business day in the case of facsimile, email, or overnight delivery. Either party may from time to time designate any other address for this purpose by written notice to the other party delivered in the manner set forth above. [SIGNATURES FOLLOW] t 129494 1 VLA 377510-00002/12-19-18/elm/bh -13- IN WITNESS WHEREOF, the Parties have executed this Agreement as of the day and year first above written. —P, s is f�� Norma Mitre Acting Clerk of the Council "CROWN CASTLE": CROWN CASTLE NG WEST LLC, a Delaware limited liability company By: / Name: Vw?Ry /t*stc✓Z Title: PIRee- bg 01061 0133 "CITY": CITY OF SANTA ANA, a charter city and municipal corporation in the State of California By: �a —AA� Name: 'aWt.v tnAev -rA Title: Ac-lhaa e—al hno "a c - y�- APPROVED AS TO FORM LI iMtOk. AuiMut City Atlooey 1129494.1 VLA 377510-00002/12-19-18/eIm/bsb -14- EXHIBIT A Locations Crown Node Site ID 2017 Lat 2018 Lat ID 2018 Long Street Address/Cross Street S00007 Gold 27 33.76015 33.76017 -117.88791 1421 West 17th Street S00O26 Gold 30 33.75341 33.75343 -117.86703 1011 North Main Street S00054 IE09_003 33.72553 33.72553 -117.84528 1630 South Lyon Street S00075 IE09 025 33.73357 33.73357 -117.85164 1356 East McFadden Avenue SOC101 IE09 051 33.77425 33.77422 -117.86717 2805 North Main Street SOC102 IE09 052 33.77355 33.77352 -117.8672 2753 North Main Street SOC268 IE10 001 33.70163 33.70164 -117.91939 3599 South Harbor SOC273 IE10 003A 33.69915 33.69913 -117.91723 3562 West Lake Center Dr. SOC458 IE09_049 33.77295 33.77298 -117.8647 310 East Memory Lane SOC459 IE09_050 33.77342 33.77342 -117.86287 15241 East Memory lane 1129494 11 LA EXHIBIT A 377510-00002/12-19-18/eIMbsb -I- Design 1 (Preferred): Side -Mounted Node Attachment 1129494.1 LL.4 EXHIBIT B 379510-00002/12-19-19 d.bsb -2- Design 2 (Alternative): Pole Top Canister 11'9414 11 i LXI IIBI I B -.?- Design 2 (Alternative): Pole Top Canister 1129494_II/LA EXHIBIT B 377510-00002/12-19-18/elm/bsb -4-