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HomeMy WebLinkAboutCOM 0986.903 2018-2020CROWNY I V CAST L E July 21, 2020 Chair Aaron S. Y. Chung and Hawaii County Council County of Hawai'i Hawaii County Building 25 Aupuni Street Hawaii, HI 96720 via email submission: counciltestimony(a')-hawaiicounty.gov RE: County of Hawai'i (the "County") Resolution #678-20 (the "Resolution") Dear Chair Chung and County Councilmembers, Crown Castle 1505 Westlake Avenue North Suite 800 Seattle, WA 98109 COUNTY CLERK COUNTY OF HAWAII RECEIVED TimSy Date 'JUL 2 1 2020 Crown Castle USA Inc. and its affiliated entities (together, "Crown Castle") appreciates the opportunity to comment on the above -referenced Resolution scheduled for a vote by the County Council on July 22, 2020. As a registered telecommunications company operating approximately 50 cell towers in the County and holding a Certificate of Authority to provide telecommunications service from the Hawaii Public Utilities Commission, Crown Castle works closely with the wireless carriers serving the County to provide access to essential data, technology and wireless service — opening the door to countless opportunities and possibilities. As wireless technology becomes an ever-present part of our lives, it's essential that we have infrastructure in place to support it. Whenever you make a call, access the internet from a mobile device for school or work, track how many steps you walked or stream music and video, Crown Castle is providing the infrastructure that makes it all possible. Today, access to technology and information is no longer a luxury, it is a necessity. Crown Castle is concerned and opposed to Proposed Resolution #678-20 because it conflicts with federal law in significant ways. The Resolution is explicit in reflecting the County's desire to regulate the deployment of specific wireless telecommunications technologies based on concerns regarding radio frequency ("RF") emissions. However, it is well-established that the County is preempted from such regulation,. either directly or indirectly. See 47 U.S.C. § 332(c)(7)(B)(iv); In the Matter Petition of Cingular Wireless LLC for a Declaratory Ruling of the Anne Arundel County Zoning Ordinance, -18 FCC Rcd. 13126 (July 7, 2003). Significantly, the Federal Communications Commission ("FCC") recently revisited its RF emission rules in light of 5G and other emerging technologies. After its inquiry, the FCC upheld the sufficiency of existing regulations and terminated the inquiry into the need to revise these standards, finding that there is no basis in the record to conclude these standards need to be revised and then closed the inquiry. See FCC 19-926, November 27, 2099. This is in direct conflict with the Resolution's statement that such standards have not been reconsidered since 1996. COfifr1. i1iQ. _ — Ref. To; CrownCastle.corn Rot. I to II II 9 9 r...�� Additionally, RF emissions are not a new concern. The safety of RF emissions has been studied for more than 60 years and the research is subject to constant review by governmental health agencies and standard-setting organizations. Organizations that regularly review RF research include: the International Commission on Non - Ionizing Radiation Protection (IGNIRP)`,. World Health Organization --Base Stations and Wireless Technologies, Public Health England (Rad'io`Wbves"a'ha Health), Health Canada, US Federal Communications Commission and US Food and Drug Administration. These organ zgtions have all reached the same general scientific conclusion, in .; • . that there are no established health hazards from exposure to RF emissions that are below FCC limits. Finally, Crown Castle believes the Resolution significantly conflicts with federal law and will effectively prohibit the provision of advanced telecommunications services. Though the wording of the Resolution only "calls upon" telecommunications companies to "cease" 5G construction, it is inevitable that adoption of this resolution will serve as encouragement for all local permitting entities in Hawai'i to take active steps to decrease broadband deployment — precisely at a time when the County should be focused on increasing broadband access for its residents Therefore, Crown Castle respectfully urges the County Council to reject Proposed Resolution #678-20 and instead, initiate an effort to adopt streamlined standards and procedures that will allow all broadband technologies, including 5G, to be deployed throughout the County. Sincerely, ka�hh Tw Kathy Putt Government Affairs Manager Crown Castle The pathway to possible. CrownCastle.corn .. ............n ..T calx+:Mf.,.r.•w..-eN.e�S.1u1P�M•..'�. .. ,> •.