Feedback after June 8, 2022: PC Wireless Ordinance Meeting
Here some of my thoughts following the June 8th Planning Commission meeting.
Teleconferencing Concerns:
We all have hard-wired broadband access straight into our homes from Comcast for the safest, fastest, most secure and most sustainable internet connection. We each can buy inexpensive new wireless modem and routers that gives us fast access to all internet services, including teleconferencing. Comcast can continue to improve speed or internet delivery through its hard-wired cable system to our homes. That will always be a better solution than placing cell towers every 100 feet throughout our neighborhoods to bring their redundant and harmful 5G service.
Climate Change: State requirement net neutrality by 2045
Listening to City climate change meetings, our city is struggling to find ways to meet the state required net neutrality goals to reduce our carbon emissions by 2045. The facts are clear that massive increases in 5G wireless facilities equal massive increases in energy use and they are not sustainable.
Increased fire & storm dangers: Cell towers on telephone poles create adverse impacts
As we prepare for climate change, such as increasing fires and coastal windstorms, heavy weighted cellular antennas and equipment mounted on 50-foot telephone poles without wires to hold them up, is a massive electrical fire hazard and falling hazard to neighboring people & properties during our coastal windstorms.
The state’s deadly campfire was attributed to power poles loaded down with cellular equipment causing electrical fires destroying 18,000 structures and killing 85 people. Co-locating cell tower equipment on telephone poles around residential homes, set in a forest, is fraught with peril.
5G is dangerous, wasteful and unnecessary
The mistaken upcoming 5G frenzy, with its millions of small cell antennas destined to clutter all neighborhoods and cover our cable, internet & tv wirelessly; not for the sole purpose of cellular service…. Is unnecessary, wasteful and dangerous. The push for all thing wireless in Carmel-by-the-Sea is the wrong direction. Our city needs to rethink a more intelligent and secure future with safe, reliable, secure, wired communications more resilient to storm, flood, fire, and reducing the enormous carbon footprint from the present wireless approach.
Undergrounding our wiring is the safest, fastest, most secure, most reliable & most sustainable option
We need more sophisticated planning to under-ground our telephone poles and our overhead wiring and seek the best hard-wired networks of fiber optic cabling for faster, higher speeds, cyber security, privacy, fire safety, resiliency, energy efficiency and long term sustainability for our future. Our collective energy should be devoted to under-grounding all wire services we receive to our homes in Carmel-by-the-Sea for electricity, cable, and phone. That will make for a more beautiful community with modern and fast connectivity.
Protect the People
Due to our residential community set in an urban forest, it is very important that the city have a special exemption to disallow the co-location of cell towers on telephone poles in the pow near people’s homes. Surely, this is not the least intrusive means to provide cellular service. We can provide good service by utilizing the macro towers on our mountains and limit the number of wireless facilities located near homes.
Create a city inventory of all existing cell towers in the immediate vicinity
Both large & small to determine evidentiary standards for least intrusive means.
I am aware of at least 14 cell towers within 3.2 miles to cover our little 1 square mile town. 1 Pebble Beach macro tower covering south Carmel, 4 in Carmel Woods, 1 on the Doud Arcade, 1 on the police station, 2 on the Sunset Center, i on the AT&T office at 7th & Junipero, 2 in south Carmel in the county, 1 macro tower at Lobos Ridge, 1 macro tower at the Barnyard Shopping Center.
Create a city inventory of all macro cell towers on nearby mountains
To determine evidentiary standards for least intrusive means. A single carrier can use a macro tower on a mountain even 30 miles away with a repeater to one cell tower in Carmel to provide all the service it needs to its customers. Carriers should be held to this least intrusive means standard.
Specify co-location to macro tower facilities on mountains as the least intrusive means for providing service.
For example, in the Carmelo proposal, Verizon could have been required to update its existing equipment on the Lobos Ridge macro tower facility 3.2 miles away to one of its existing facilities in Carmel instead of seeking a permit for a new facility in an R-1 zone. Their Carmelo tower proposal was not the least intrusive means possible.
Specify co-location to macro tower facilities in nearby industrial zones at the 2nd least intrusive means for providing service
During the Carmelo tower application, I understand a macro tower facility was being approved at the Barnyard facility and could have been required as an alternative least intrusive location rather than an R-1 zone location.
Require applicants to activate all of their approved facilities before applying for additional permits so that the city can accurately determine coverage gap claims
Verizon claimed a cell tower was necessary to fill a coverage gap in a residential zone on Carmelo to cover a small geographic area of a few blocks. Verizon did not activate several of its already approved cell towers before applying for new facilities. The 2 cell towers on sunset center were just 1600 steps from the Carmelo location. I also believe 2 other Verizon facilities in south Carmel were not activated yet and the macro tower at the Barnyard Shopping Center was not up and running. Shouldn’t a carrier’s approved cell towers in the city be activated before that carrier requests new facilities so accurate coverage gap claims can be assessed?
Require reasonable & significant burdens of proof with cost placed on applicants (See AC’s draft ordinance)
Prevent misleading propagation maps submissions as evidence. Applicants must provide a higher standard of evidence including both drive test maps & providing significant drop call data. The applicant must cover the cost of any consultation fees to provide this evidence.
Require applicant to mail notice of public hearing to all property owners (within 300 or 1500 feet depending on application type)
During the Carmelo proposal, the applicant was required to hand-deliver public hearing notice to all property owners within only 100 feet of their proposal (this is a city requirement and a state requirement). While the applicant signed an affidavit with the city indicated it hand delivered a public notice to all these property owners, none of my 11 neighbors received it, before both public hearings. Maybe their notification blew away in the wind before both meetings? Maybe they didn’t do as they said? Either way, we didn’t receive their notices. The city must require applicants to notify property owners by certified mail to solve this issue. Especially in a community with so many part-time residents.
I would also like the city to mail a letter of public hearing notice to property owners instead of mailing a post card. During the Carmelo proposal, the city mailed a small rectangle notice on lightweight paper in small font to residents within 300 feet. This notice was not significant enough to get noticed.
Protect people from danger: you are blocked from denials over rf health concerns; but not from denials due to safety
The FCC blocks cell tower denials over health concerns due to rf emissions. Note this law is being challenged as we speak.
However, listing the adverse impacts to people as it relates to safety is not a blocked reason for denial. It is a duty of our city representatives to protect people & property from the adverse safety impacts from cell towers such as electrical fires and determining the impacts to people & property located in cell tower fall zones.
Disallow cell towers in residential zones r-1 & r-4 and public-right-of-ways in all districts as adverse impacts to residents
- See Robert Delves’ 6.8.22 letter defining this importance.
- See Robert Delves’ suggestion to rezone the POW.
- See Robert Delves’ suggestion to coordinate with PG&E.
- It is the city’s duty to protect the welfare & properties of its people.
- It is the city’s duty to uphold our zoning laws and to not degrade the aesthetics of our neighborhoods and the character of our entire community.
- It is the City’s duty to protect us from noise disturbances like humming antennas and noisy battery cooling fans & to prevent ADA issues by further crowded our rights of way.
- Disallow dangerous, tall wireless facilities in all pow and residential zones.
- Protect the residents who are the stakeholders most affected by this city ordinance.
Require applicants to activate approved facilities before applying for new facilites so that the city may accurately determine coverage gap claims
When Verizon submitted application for the Carmelo tower in a residential zone, the 2 approved cell towers on the sunset center just 1600 steps away from the proposed location were not activated yet. We also believe 2 of Verizon’s approved cell towers in south Carmel and its macro tower in the barnyard shopping center weren’t activated yet either. Does the city know if any of these towers are up and running yet?
Require applicants to construct real world models of their cell tower proposals so that City representatives may assess for visual impact
Residents are required to construct story poles and orange netting when rebuilding or remodeling. This is a valuable tool to assess visual impact. For profit telecom carriers seeking facilities on public property should be held to an even higher standard than property owners. During the Carmelo proposal, residents worked with our la playa friends and neighbors to construct a model of the ground equipment and equipment attached to the pole to assess visual impact. We wanted to also have a balloon on a string to demonstrate the visual impact for height, but it was too windy. These types of real-world models are important for assessing visual impact. The model she be constructed by a neutrual outside consultant and the cost should be covered by the applicant.
Organize application types & coordinate shot clocks for tolling based on cause to more easily handle the application process & timetables (See AC’s draft ordinance)
Cell towers can be accepted simply if cities do not meet the shot clock. It is very important that the City has a clear procedure to identify specify application types from the start and know how to toll (stop) the shot clock for cause. Also, each application type comes with a high bar of evidentiary standards of evidence that applicants must provide from the start. Permits may be denied from the start if they do not provide the evidence required.
Expand adverse impacts, visual impact analysis, alternative site analysis, fcc compliance with rf, proof of coverage gaps and design standards
Retain the city’s maxium legal authority to limit the number of cell towers & decide where they are located with a strong & defensible wireless ordinance
Andrew Campanelli’s ordinance accomplishes this goal.
