2022-10-20 AT&T Document Provided at Meeting - Sworn Statement-bocu" recu" t B06 or,hll�
AT&T
AT&T Mobility Services LLC
Tower Strategy
17000 Cantrell Rd.
Little Rock, Arkansas 72201
SWORN STATEMENT OF SPENCER GAMRELL IN SUPPORT OF NEW TOWER
CONSTRUCTION
BY CitySwitch II -A, LLC
PULASKI COUNTY )
) ss.
STATE OF ARKANSAS )
Spencer Gambrell, being first duly sworn on oath, deposes and says that:
I am an adult resident of the State of Arkansas and serve as Director — Network Planning
for AT&T Wireless ("AT&T").
2. I manage AT&T's high -rent relocation program, under which AT&T identifies high -cost or
economically burdensome antenna site leases that accommodate AT&T's communications equipment and
relocates its communications equipment onto lower -cost alternative antenna site lease locations to either
improve or maintain wireless coverage.
3. I am familiar with the proposed tower to be constructed by CitySwitch II -A, LLC
("CitySwitch") at 1117 NW 91' St., Okeechobee, Florida 34972 (the "CitySwitch Tower"). I am also
familiar with the existing communications tower (the "SBA Tower") owned by SBA 2012 TC Assets, LLC
("SBA Communications") which is located at 1678 Northwest Ninth Avenue, Okeechobee, FL 34972. Both
the existing SBA Tower and the location of the proposed CitySwitch Tower are located in AT&T's coverage
search ring for this part of the City of Okeechobee and Okeechobee County.
4. AT&T currently leases space on the SBA Tower, along with related ground space at the base of
the SBA Tower, to locate its communications equipment (the "Wireless Facilities"). AT&T has located its
Wireless Facilities on the SBA Tower since August 2014, but AT&T now desires to relocate its Wireless Facilities
onto the CitySwitch Tower as the SBA Tower has become a high -cost antenna site structure for AT&T.
[Plant City] Page 1 of 4
FA#[15762104]
This swom statement is made to attest that having its Wireless Facilities remain on the SBA Tower,
which is the only existing communications support structure in AT&T's search ring, is economically
burdensome for AT&T and would not result in the same cost-effective operation as compared to what AT&T
could achieve if it relocated its Wireless Facilities to the CitySwitch Tower.
Co -Location on the SBA Tower is Economically Burdensome
6. AT&T maintains a co -location agreement with SBA for the SBA Tower. Under this agreement,
SBA increases the rent, assesses other costs and poses other logistical issues when AT&T installs additional
Wireless Facilities on the SBA Tower. AT&T anticipates future rent increases and costs from SBA if it remains
co -located at the SBA Tower. Those rent increases and costs would result from, among other things, AT&T's
equipment rights on the SBA Tower.
The current rent charged by SBA to co -locate on the SBA Tower is over two- & one-half times
what CitySwitch will charge AT&T to co -locate on the CitySwitch Tower. Pursuant to the agreement between
AT&T and CitySwitch, annual rent increases are less than the annual rent increases charged by SBA. At the
current rate of rent increases, over the next twenty (20) years, the difference in rent paid by AT&T to remain on
the SBA Tower versus relocating on the CitySwitch Tower is well over two million dollars.
8. Since AT&T located on the SBA Tower in August 2014, rent and escalators have become more
competitive in the tower marketplace. New tower companies have entered the marketplace since August 2014,
which has also led to more competitive economic terms in tower lease agreements. Considering these competitive
economic terms from other tower companies, AT&T has requested tower rent reductions from SBA. Unlike other
tower companies, SBA has resisted an economically sustainable cost structure with its existing AT&T co -location
leases, such that many of these leases have become economically burdensome for AT&T.
Decommissioning an existing Wireless Facility in favor of moving to an alternate tower
location is something AT&T will only do in limited circumstances. AT&T will bear a significant capital cost in
decommissioning its Wireless Facilities installation on the SBA Tower and relocating to the CitySwitch Tower.
Despite these relocation costs, the CitySwitch Tower remains a better co -location option for AT&T.
Page 2 of 4
[West Okee Relo]
FA#[ 1561 l 191 ]
10. AT&T has made this determination because the current rents and other charges to co -locate on
the SBA Tower have been categorized as high -cost as compared to other existing sites in AT&T's portfolio and
the rents charged by other tower companies, such as CitySwitch.
11. AT&T has entered into nationwide development and master lease agreements with
CitySwitch, which I am familiar with. Under these agreements, CitySwitch will construct at its own
expense and own communications towers upon which AT&T will lease space to install its Wireless
Facilities. AT&T does not bear any costs for the construction of a tower owned by CitySwitch.
12. Per these agreements and as is the case with the CitySwitch Tower, AT&T pays CitySwitch rent
in return for 30,000 square inches of wind load surface area of loading and defined space on each tower and
does not pay increased rent for additions to its Wireless Facilities provided said facilities remain within the
predetermined space and loading limits. The agreed upon tower space and loading limits have taken into
consideration the future additions and upgrades projected for AT&T's Wireless Facilities.
13. There are no other structures (other than the SBA Tower) located in AT&T's search ring
capable of accommodating its Wireless Facilities.
14. The economic terms imposed upon AT&T by SBA to remain co -located on the SBA Tower
are not cost-effective and are economically burdensome for AT&T especially when the nearby CitySwitch
Tower presents a more competitive and flexible co -location option.
The CitySwitch Tower provides superior mobile service functionality.
15. Technological changes and market trends in the wireless communications industry require
AT&T to continuously upgrade its Wireless Facilities. AT&T is also obligated to build out FirstNet, which
is our country's first nationwide integrated data network for providers of emergency services.
AT&T's lease agreement for the SBA Tower does not include "set aside" capacity reserved for the
future needs of AT&T's Wireless Facilities. Every time AT&T desires to improve the Wireless Facilities
installed on the SBA Tower, it must apply to SBA which then triggers an application fee and a lengthy
administrative review process, which typically includes a structural analysis of the tower and an amendment to
[West Okee Relo] Page 3 of 4
FA#[15611191]
the existing lease agreement. This administrative process may take several months and results in unnecessary
time delay and additional costs in the deployment of the upgraded Wireless Facilities.
16. Conversely, AT&Ts master tower lease agreement with CitySwitch allows AT&T to rent 30,000
square inches of tower space and loading on a CitySwitch Tower. This space and loading capacity is reserved
exclusively for AT&T and will accommodate the needs for AT&Ts Wireless Facilities well into the firture.
This arrangement benefits AT&T because it increases the speed of deploying Wireless Facilities and gives
AT&T greater flexibility to upgrade technologies and respond to the ever -changing coverage and capacity
demands of its wireless network. Provided it does not exceed the reserved space and capacity limits in the co -
location agreement AT&T is fi-ee to upgrade its Wireless Facilities on the CitySwitch Tower with little to no
delay.
Subscribed and sworn to before me
this - 24— day of 2022.
Notary Public State of Ark as
My Commission Expires
[West Okee Relol
FA#[156111911
Spencer Gambrell
BROOKE IRVJNG
MYCMMIS-SION#12706M
�4
EXPIRES: March 3,20n
County Saline -Li
Page 4 of 4