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wĻĬĻĭĭğ \[źĻĬĻƩƒğƓ <br />Director <br />State Government Affairs <br />October 29, 2025 <br />źğ 9ƒğźƌ Λ‘t/ƷĻƭƷźƒƚƓǤθŷğǞğźźĭƚǒƓƷǤ͵ŭƚǝΜ <br />Windward Planning Commission <br />101 Pauahi Street, Suite 3 <br />Hilo, HI 96720 <br />Re: County Council Initiated Bill 194 - (PL-CCI-2024-000009) <br />Dear Chair Lin and Commissioners, <br />Thank you for the opportunity to provide comments on the County Council initiated Bill 194 to amend Chapter 25, <br />Articles 1, 2, 4, 5, and 7 of the Hawai'i County Code 1983 (2016 Edition, as amended) relating to <br />telecommunication antennas and towers ("Bill 194"). <br />with state and federal law and the effects it will have on broadband deployment. <br />First, <br />for the regulation of the small wireless facilities in the County. See Haw. Rev. Stat. Ann. §§ 206N-1 206N-10. Bill <br />No. 194 expands the defin <br />applicable to large format macro-wireless towers. That expansion is in direct contradiction to State law, which <br />or zoning approval if they are deployed: (1) in the right of way in any zone; or (2) outside the right of way in <br />-4. <br />- <br />technical or operational basis - including <br />wireline facilities and network hardware <br />Federal law. If adopted, Bill No. 194 has the real potential to lead to the illogical, and unlawful, result that <br />deploy its facilities in the public rights of way, and to use those facilities for both cable and non-cable services, <br />pursuant to its cable franchise and the federal Cable Act. In addition, Section 5 of Bill No. 194 introduces a <br />plethora of new siting constraints, preconditions, and clearances into the application process, several of which are <br />unnecessary, burdensome, counterproductive and potentially in conflict with applicable law. <br />Bill No. 194 would have a significant negative impact on deployment on equipment essential to providing services, <br />including broadband access, to communities throughout the County of Hawaii. Both the state and county have <br />made deployment of broadband services a priority in recent years and Bill No. 194 undermines those goals. <br />As the largest broadband provider in the state, Charter supports efforts to expand broadband access. Charter <br />believes that every Hawaii resident should have reliable access to the Internet. We will continue to help bring the <br />benefits of broadband and access to the internet to those who need it most. From 2021-23, Charter extended its <br />network to reach an additional 36,000 homes and small businesses in the State, investing more than $296 million <br />151 PALII STREET, MILILANI, HI 96789 h 808.695.3154 a 808.481.1007 <br />Rebecca.Lieberman@charter.com <br /> <br /> <br />