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Testimonyi l l i to Bill 24
Aloha County Council Members,
Thank you all for your wonderful work and congratulations on the beginning of your term!
My name is Naomi Melamed and I live in Havi here on the Big Island. I'm writing on behalf
of Safe Tech Hawaii, a grassroots coalition of residents who promote safer uses and
implementations of technology on our precious island.
We find it very confusing that there are two ordinances on cell towers and antennas - this
newer one, Bill 24, introduced by the former Planning Director and one introduced last
year on August 20 by former Council Member Evans, Bill 194, that had previously been
forwarded in vain to Planning for review and collaboration. We support Bill 194.
Exclusion of Small Cells in 5G Infrastructure
Bill 24 fails to address the inclusion of small cells, a critical component of 5G technology
that is still new and untested. As technology evolves rapidly, it is imperative that we
account for the safety of its new infrastructure. Ignoring small cells in legislation would
continue the feeling that currently exists in Hawaii, that we are a "free-for-all" for
developers and Telcom. More oversight is needed to protect our islands interests.
Excessive Exempt Zones
The bill designates an excessive number of exempt zones, effectively undermining the
purpose of setbacks. These exemptions cover sensitive areas such as downtown Hilo, which
includes many residences and schools. This lack of careful zoning oversight raises
significant concerns about how the infrastructure will integrate into our community and
could result in a disconnect between technological advancement and community needs.
"Relating to Applicability; Use Permit required. Section 25-2-61 is proposed to be amended
as follows: (a) The following uses shall be permitted within designated County zoning
districts only if a use permit is obtained for the use from the commission: [(11)
Telecommunication antennas and towers in RS, RD, RM, RCX, RA, FA, A, IA and 0 districts.]
Reason for the Amendments: This amendment is necessary to expedite the development of
telecommunication infrastructure by removing the requirement for use permits and
comply with the 60-day action requirement on telecommunication permits found in HRS
§46-89. "
Lack of Community Involvement
The development of Bill 24 does not seem to have incorporated input from the community,
which is a significant oversight. The primary commentators have been representatives
from large telecommunications companies, raising concerns about whose interests are
truly being served by this legislation. It is vital that community voices are included in this
process to ensure that the bill reflects the unique needs and concerns of those who will be
most affected by its implementation. Engaging local residents in meaningful dialogue can
lead to better outcomes for everyone involved. In contrast, former Council Member Cindy
Evans, author of Bill 194, engaged numerous citizens and groups like Safe Tech Hawaii for
input when writing the legislation.
Ambiguous Decommissioning Plan
There is no clear decommissioning plan outlined in Bill 24, which is crucial for any
infrastructure project approved on our island. Without a defined strategy for the removal
or repurposing of outdated or unused structures, we risk creating an environment filled
with abandoned and unsightly infrastructure, which can detract from community
aesthetics and potentially hinder future development.
Exclusive Control and Lack of Checks and Balances
Bill 24 gives the Director almost exclusive control over telecom infrastructure, with very
little involvement from other agencies or experts. This excessive reliance on telecom
corporations for compliance highlights the need for outside involvement and checks and
balances. It is crucial to recognize that, unfortunately, telecom companies do not have a
strong reputation for self -policing. Ensuring proper oversight is necessary to maintain
transparency and accountability.
Privacy Concerns Over Surveillance Cameras
Moreover, we disagree with the proposed installation of surveillance cameras on towers,
especially if it will be at the county's expense or if outsourced to private companies. This is
a major threat to our privacy. With data being the current cash cow, there is a risk that this
data could be collected, marketed, and sold to the highest bidder —resulting in a gross
invasion of privacy.
In conclusion, we urge the committee to support Bill 194 instead of Bill 24. It is essential
that any legislation concerning wireless infrastructure is both forward -thinking and
inclusive of community input to ensure that the interests and well-being of all residents are
prioritized. Only through a collaborative approach can we ensure that our community
remains vibrant and fully connected in the years to come.
Mahalo Nui for reading my testimony, Naomi Melamed, Safe Tech Hawaii, Island Leader
Aloha, This is a list of attached resources mentioned in my testimony PDF attached:
Mahalo, Naomi Melamed
Note: These were compiled from EHT research of various sources and a special thank
you to Physicians for Safe Technology, My Streets My Choice, Scientists for Wired
Technologyand Last Tree Laws for their extensive resources utilized on this page.
Please be sure to go to these pages for more information.
In addition, Americans For Responsible Technology has created a Sample Small Cell
Ordinance that cities can use as a starting point which incorporates several- although
not all- of these issues. Please download their model ordinance and utilize their
extensive resources at this link.
New York
White Plains, New York Wireless Ordinance
• /n order to ensure and maintain the safety, property values, and aesthetic
qualities of White Plains streets and neighborhoods, the following setback
provision shall apply: residential districts, a minimum of250 feet from the nearest
structure;
• Notifications to property owners located within 500 feet shall be written in a
factual manner devoid of marketing promotion and approved by the Commissioner
of Public Works;
• All small wireless facilities... shall at all times be operated in compliance with the RF
standards established by the Federal Communications Commission. These RF
safety standards shall apply to the aggregate emissions of co -located and nearby
facilities not just the emissions of a single antenna;
• Liability insurance without a pollution exclusion, pollution being defined as any
solid, liquid, gaseous or thermal pollutant, irritant or contaminant including but
not limited to artificially produced electric fields, magnetic fields, electromagnetic
fields and all artificially produced ionizing and non -ionizing radiation;
• The following unique clause was also inserted: no new small wireless facilities, as
defined in 47 CFR 111.6002 (1), shall be approved unless the applicant can
establish that failure to approve such an application would violate federal or
state law. This clause was inserted to allow the City of White Plains to deny an
application if federal law continues to uphold the `significant gap' provision. At the
same time, it allows the Clty to approve an antenna if the law changes;
• Link to White Plains New York Ordinance PDF
Ithaca New York Ordinance
• A 1500 foot setback between antennas (otd code: 0 feet)
• A 300 foot setback between antennas and homes (old code: 0 feet)
• Requiring proof of a significant gap in service coverage for any antenna, proven by 'in -kind' testing
(such as drive -by tests and dropped caps)
• Clarifying that an applicant's claim that it needs the proposed tower for "future capacity" is not
sufficient to establish that it suffers from a significant gap in coverage
• Requring the least intrusive methods to fill any coverage gap for antennas
• Requiring that a visual impact analysis be submitted for any new proposed antennas
• Requiring Generat Liability Insurance without a pottution exclusion
• Allowing for random, unannounced radiation testing for att towers done by the City at the expense of
the applicant
• Including fall -zone requirements that wiretess facilities are maintained at a sufficient distance from
other structures and the general public
• Establishing a procedure for any disabled persons suffering from EHS to submit requests/grievances
in accordance with the ADA
• Establishing that the codes apply to atl wireless transmitting antennas, including any on private
homes (OTARD)
• Protecting against reductions in property values of properties situated near wireless facilities
• Requiring that the submittal of key items by the applicant is done so under oath and penalty of
perjury
• Link to Ithaca New York Wireless Ordinance PDF
Massachusetts
Randolph MA
500 foot setback from any residence or business. Randolph requires a certified
engineer to take radio frequency radiation readings of the tower once a year and
requires the tower company to recertify it's tower every year. Link to Code
Lunenburg, MA
500 foot setbacks from any residence. Link to Code
Great Barrington MA has 500 foot setbacks away from residences AND their zoning
ordinances state; "Towers and personal wireless service facilities shall be located so as
to minimize the following potential impacts: Safety from excessive electromagnetic
radiation, in case the tower or personal wireless service facility is found to exceed the FCC
guidelines." https://ecode360.com/28653470
Stockbridge MA prohibits a tower from being built 1000 feet from a school, park or
athletic field and 600 feet away from any residence.
https://townofstockbridge.com/wp-content/uploads/2017/10/TOWN-0E-
STOCKBRI DGE-MASSACH USETTS-Zoning-ByLaws-2017.pdf
RESOLUTION NO. 2021-58: RESOLUTION OF THE BOROUGH COUNCIL OF THE
BOROUGH OF LAVALLETTE CONDITIONALLY APPROVING AN APPLICATION OF
VERIZON/TILSON TECHNOLOGY FOR A RIGHT OF WAY PERMIT AT 3 LIGGETT ROAD IN
THE BOROUGH OF LAVALLETTE, COUNTY OF OCEAN
The conditional requirement for deployment in Lavallette, and the City expressly made
this a condition precedent before deployment: "The applicant shall obtain certification
from the Federal Aviation Administration and the United States Department of Defense
demonstrating that the installation does not emit RF frequencies which may interfere
with avionics of any approaching civil or military aircraft."The City also requires the
applicant to provide RF meters used by their technicians and training the City
employees.
Arkansas
Booneville, Arkansas
• Proposed Ordinance would limit cell towers to 250 ft max; industrial zones
• Cell tower ordinance read for first time at council meeting, Sept 5, 2018
Danville, California
Proposed Ordinance No. 2018-07: Wireless Communication Facilities
• Aesthetic requirements (design guidelines may be developed and amended from time to time to
clarify aesthetic and public safety goats and standards)
• Utilities must be underground to extent feasible. "Meters, panels, disconnect switches and other
associated improvements must be placed in inconspicuous locations to the extent possible".
• Permits valid for initial period of 10 years max
• "Where feasible, the location of wireless communication facilities shall be encouraged to be located
on publicly owned or controlled property or right-of-way!
• Would allow small cells in residential districts:
-"All facilities shall be substantially screened from the view of surrounding properties
and the public view or collocated with existing facilities or structures so as not to create
substantial additional visual, noise, or thermal impacts. "
-Property owners within 300 ft of proposed site must be notified
Danville, California: Ordinance No. 2018-07 Wireless Communications Facilities PDF
http://mystreetmychoice.com/danviIle.htmI
http://scientists4wiredtech.com/danville/municipal-wireless-code/
Encinitas, California
Urgency Ordinance
5G opponents cite health concerns in urging city to limit wireless antennas
Fairfax, California
Urgency Ordinance to Establish New Regulations for Wireless Telecommunications
Facilities; Ad hoc committee to study viability of fiber network
Ordinance No.819 An Urgency Ordinance Enacting Title 20 ("Telecommunications") of
the Fairfax Municipal Code to Establish New Regulations for Wireless
Telecommunication Facilities [small cell devices a.k.a. 5G]
• Redtined version
• News: Marin Independent Journal Fairfax to study fiber-optic broadband amid protest against 5G
Los Altos, California
• installation of small cells on public utility easements in residential neighborhoods is prohibited
• 500 foot setbacks for small cells for multi -family residences in commercial districts
• 500 ft separation from schools
• 1500 ft separation between nodes
• Los Altos Urgency Ordinance:
• Los Altos Citing Guidelines:
This ordinance was passed in 2019. Then the Los Altos City Council then rejected 12
applications from AT&T and one from Verizon because they didn't meet those rules. In
response, both cell companies sued in federal court, arguing the denial wasn't based on
evidence. The lawsuit is still pending while consultants hired by the city of Los Altos
worked on a new ordinance. The new ordinance, which was reviewed by the Los Altos
Planning Commission on Thursday, says that cell nodes can go in residential streets as
tong as they are near a main road, within 200 to 500 feet.
According to WireAmerica.org: The new Los Altos ordinance "says the city will grant
exceptions if a cell company has evidence they need a site in a residential
neighborhood to eliminate a significant gap in telecommunications coverage. The
company would have to demonstrate, with substantial evidence in the public record,
that not putting the antenna at that location would result in an effective prohibition of
telecommunications service — a tough row to hoe for Wireless companies because
everyone can make a wireless phone call on every carrier network in Los Altos today.
The ordinance has several other restrictions on things like height, noise and Wireless
Telecommunications Facility (WTF) design. Attorney Deborah Fox, who is representing
the city against AT&T and Verizon, said the ordinance is "state of the art" and she is
confident that it meets federal law."
Marin County, California
Draft as of June 21, 2019 The city is mapped to show where the cell towers are
allowed.Marin drafts preferences for 5G rollout, Point Reyes Light
• "Marin's draft rules select industrial, commercial or agricultural sites, or sites near public facilities, as
preferred locations for the antennas; residential and mixed -use sites and areas within 1,500 feet of
schools and daycare centers are the least -preferred tocations.The draft favors placing antennas on
existing street poles or traffic lights, versus new poles or small cell facilities. It limits antennas to one
per pole and stipulates they must be at least 1,000 feet apart. It also includes aesthetic requirements
that aim to blend equipment, and prohibits equipment on historic buildings."
Mill Valley, California
Urgency Ordinance No 18, September 6, 2018
• New or updated facilities prohibited in residential zones. Commercial only.
• Facilities installed on poles in public right of way must be 1,500 feet apart
• Design, noise standards
• Facilities in public right of way that would interfere with future projects / improvements must be
relocated
• Promptly remove facilities when no longer needed; replace with smaller facilities as feasible
• Defend and indemnify the City
• Mitt Valley, California: Urgency Ordinance No 18, September 6, 2018
• Tech Crunch" Bay Area Blocks 5G Deployment Over Cancer Concerns
• Marin Post Milt Valley Council Adopts Wireless Ordinance Protects Community
Palo Alto, California
City Council voted unanimously to approve a Resolution and amended Wireless
Ordinance that City Staff had proposed. Council also voted unanimously in favor of a
motion to direct City Staff "to come back as soon as possible but [in] no more than [one
year], with an updated Ordinance/Resolution that considers" (and e summarizing):
Disfavoring the placement of cell towers in, for example, residential zones and near schools;
Minimum setbacks for cell towers from homes and schools, and minimum distances between cell
towers;
Creating a list of city -owned buildings that would be appropriate sites for macro cell towers (i.e., as an
alternative to small cell node cell towers next to people's homes);
Council also voted to direct City Staff to return to Council with a recommendation for
"best practices" with respect to inspecting antennas.
"Seeking to strike a balance between federal requirements and resident concerns, Palo
Alto approved on Monday night new rules for reviewing the flurry of applications that
the city has been receiving from telecommunication companies seeking to install
antennas on local streetlights and utility poles.
By a 6-0 vote, with Councilman Greg Tanaka absent, the council adopted a set of
"objective standards" for wireless communication facilities, including a menu of
preferred design alternatives for radio equipment and antennas. And in a nod to the
dozens of residents who have raised alarms about the proliferation of cellular facilities
on their blocks, the council launched a new effort to further restrict where such
technology can be installed and to explore "minimum distance" requirements for
wireless equipment in relation to local schools and homes."
Palo Alto looks to distance cell antennas from homes, schools
Palos Verdes, California
According to citizens of the city, after citizen uproar, Crown Castle began complying
with municipal aesthetic requirements and moving proposed locations out of
neighborhoods and away from homes. The ordinance has four key components, if these
are met the site will almost certainly be approved:
• Minimal antenna size with screening
• All accessory equipment underground (everything except the antenna)
• Combining sites with existing vertical infrastructure (streetlights, traffic signals, etc.)
• Strict location restrictions, no sites on local, residential streets without an exception granted
If they don't comply with these, then the applicant must demonstrate the site is required to fill a
significant gap and there is no less intrusive alternative to receive an exception. This is not simply
checking a box (i.e. the applicant just claiming these conditions exist) but has to be demonstrated to
the City planning commission via engineering analysis.
Palos Verdes, California Ordinance Chapter 12.18 - WIRELESS TELECOMMUNICATIONS
FACILITIES IN THE PUBLIC RIGHT-OF-WAY
Petaluma, California
Ordinance of the City Council of Petaluma
• Protect environmental resources; protect residents against adverse health effects
• Protect visual character; don't create visual blight
• Protect environmental resources; protect residents against adverse health effects
• Commercial or industrial zones
• Antennas must connect to an already existing utility pole that can support its weight.
• Servicing wires must be installed within the width of the existing utility.
• All ground -mounted equipment not to be installed inside the pole must be undergrounded, flush to
the ground, within three (3) feet of the utility pole.
• Dedicated power source to be installed and metered separately.
• 1,500 feet minimum between each Small Cell facility.
• No Small Cell shall be within 500 feet of any residence.
• An encroachment permit must be obtained for any work in the right-of-way.
• Petaluma, California: Ordinance of the City Council of Petaluma PDF
Ross Valley, California
Wireless Telecommunications Facilities
• Modeled after Mill Valley's
• Adopted regulations prohibit facilities in residential and downtown zoning district.
• Facilities proposed in the public right-of-way subject to separate design criteria.
• Limits height and width of facilities to a minimum necessary for property function.
• Maximum height of 24 feet above the height of the existing utility pole and 7 feet above a street tight
standard.
• Requires equipment to be placed underground.
Ross Valley, California: Wireless Telecommunications Facilities PDF
San Anselmo, California
Council Policy
• People within 300 feet of proposed antenna will be notified
• Town is entitled to employ independent consultant at applicant's expense to evaluate exceptions
• San Anselmo, California PDF
San Diego County, California
Draft ordinance (5-31-2019) for small cell antenna sites in San Diego County has the
following requirement:
"SCWs shalt not be located within 1,000 feet of schools, child care centers, hospitals, or
churches. Distance, without regard to intervening structures, shalt be a straight tine
measured from the closest property lines."
San Diego County Ordinance
San Jose, California
Negotiated agreement
"officials made improved access to areas with tow internet participation a precondition
for reducing fees... agreement set tiered costs per network node installation, with Lower
fees for companies deploying more nodes. Along with this incentive, three companies
pledged to contribute a total of $24 million over the next decade to a digital inclusion
fund! (GovTech)
• News Stories The Future of 5G: The Bitter Battle for Local Control
Suisin CA
500 ft setback and all facilities permitted pursuant to this chapter
shalt comply with the ADA.
San Anselmo, CA
300ft setback residents notified
Calabasas, CA
1000 feet setback for small cells.
Westlake, CA
500 feet setback
San Clemente, CA
500 feet setback
San Rafael, California
City Council Report
Dec. 5,2018 front page news story: https://www.marinij.com/2018/12/04/san-rafael-
officiaLs-work-to-tighten-5g-anten na-ru Les/
Dec. 18, 2018 front page story: https://www.marinij.com/2018/12/18/san-rafaet-adopts-
urgency-ordinance-to-keep-grip-on-5g-proliferation/
• City Staff Report: URGENCY ORDINANCE AMENDING THE SAN RAFAEL MUNICIPAL CODE TITLE 14
(ZONING) AND ACCOMPANYING POLICY RESOLUTION TO ESTABLISH PROVISIONS AND PROCEDURES
FOR REGULATING THE PLACEMENT OF SMALL WIRELESS FACILITIES
• San Rafael, California: December 2018 Documentation for City Action on 12/18/2018
"/ want the city and county government to clearly soy no to the FCC," said resident
Arthur Softlos. "No 5G installations of any kind in Morin, until it can be proven safe for
us and the environment."- San Rafael, Calif, Officials Work to Tighten 5G Regulation
• San Rafael Residents Take Pre-emptive Strike Against 5G
Sebastopol, California
City Council Agenda Item Report and Urgency Ordinance (Recommended)
• Purpose: Institute a moratorium on applications for small cells in the public right-of-way until
adoption of a permanent ordinance
Previous regulations on telecommunications facilities (according to the recommended
urgency ordinance, these did not anticipate 5G and do not address installation of
telecommunications facilities in the right-of-way):
• Purpose: Protect visual character, inhabitants, environmental resources
Cannot be located in any required yard setback area
• Facilities within 400 feet of residential areas, schools, churches, hospitals etc must comply with NIER
standards
• Minor facilities must be 75 feet away from a "residential dwelling unit" except 1 single family residence
on the property where it is Located
Sebastopol, California: City Council Agenda Item Report and Urgency Ordinance
Establishing a Moratorium on Small Cells in the Public Right of Way
Other Links
• http://scientists4wiredtech.com/sebastopol/sb-muni-code/
• http://mystreetmychoice.com/sebastopol.htmt
Sonoma, California
Report and Urgency Ordinance
On Nov 5, 2018 Sonoma approved their 5G urgency ordinance.
500 ft setback and residents notified.
"Based on the foregoing, the City Council finds and determines that the immediate
preservation of the public health, safety and welfare requires that this Ordinance be
enacted as an urgency ordinance pursuant to Government Code Section 36937(b), and
take effect immediately upon adoption. Therefore, this Ordinance is necessary for the
immediate preservation of the public peace, health, safety and welfare and its urgency
is hereby declared."
• The City also has a Small Cell Tower page.
• Sonoma California Ordinance on 5G
Walnut City, California
• "Telecommunication towers and antennas shall not be located within 1,500 feet of any school
(nursery, elementary, junior high, and high school), trail, park or outdoor recreation area, sporting
venues, and residential zones."
• Screenshot of Ordinance from Walnut Website,
• To see the code online go to https://gcode.us/codes/walnut/, Click on "Title 6: Planning and Zoning"
Click on "Chapter 6.88 ANTENNAS AND COMMUNICATION FACILITIES", Click on "6.88.060 Design
standards, See Item "O.
Warren, Connecticut
This policy defines adequate coverage and adequate capacity. It details that it was
designed "to locate towers and/or antennas in a manner which protects property
values, as well as the general safety, health, welfare and quality of life of the citizens of
Warren and all those who visit this community, minimize the total number and height of
towers throughout Warren, and provide standards and requirements for the regulation,
placement, design, appearance, construction, monitoring, modification and removal of
telecommunications facilities and towers."
• "Coverage is considered to be "adequate" within that area surrounding a Base Station where the
predicted or measured median field strength of the transmitted signal is such that the majority of the
time, transceivers properly installed and operated will be able to communicate with the base station.
In the case of cellular communications in a rural environment like Warren, this would be a signal
strength of at least -90 dBm for at least 75% of the coverage area. It is acceptable for there to be holes
within the area of Adequate Coverage where the signal is less than -90 dBm, as long as the signal
regains its strength to greater than -90 dBm further away from the Base Station."
"Capacity is considered to be "adequate" if the Grade of Service (GOS) is p.05 or better for median
traffic levels offered during the typical busy hour, as assessed by direct measurement of the Personal
Wireless Service Facility in question"
TOWN OF WARREN SECTION 29 - SPECIAL PERMIT FOR TELECOMMUNICATIONS:
FACILITIES AND TOWERS December 11, 2012, Warren website link
Burlington, Massachusetts
Town of Burlington Policy Applications for Small Cell Wireless Installations, October 22,
2018
• Small Cell Committee drafted a policy with annual recertification fees. Verizon withdrew its
application, concerned by the precedent it would set and questioning its legality.
• Verizon attorney Mr. Klasnick stated "My client respectfully requests to withdraw the petition rather
than have a fee," he said.(BCATTV)
The Town of Burlington Policy / Application for Small Cell Wireless Installations
approved by the Burlington Board of Selectmen on October 22, 2018 PDF.
According to BCATTV Verizon Drops Small Cell Wireless Booster Application in Face of
Fees:
"This week Selectman Jim Tigges, the board's representative on the Small Cells
Committee, said the group had come up with a new policy for small cell applications.
The policy contains a number of provisions while filing an application, including setting
installation fees, listing the town department that must receive a copy for review and
setting up the timeline for approval.
The Verizon application, however, would not be subject to the policy because it was
submitted before its adoption. However, Tigges and the committee did have a number
of conditions for the project it recommended to the board. They included:
- No apparatus on double poles
- An agreement to annual recertification
- Equipment shall be located on top of the poles, colored similarly to the poise so as to
blend in.
- Equipment shall not interfere with other equipment on the pole, nor obstruct or
interfere with access to or operation of street lights or traffic controls devices on the
pole.
- Poles must meet ADA standards!
-NEWS: Verizon Drops Small Cell Wireless Booster Application in Face of Fees, October
r
Holyoke, Massachusetts
• Draft policy $500 fee for city inspection of rooftop poles/roofs every 2 years
• Holyoke has submitted an order from councilor Bartley Roman to limit equipment and require $500
apiece per small cell-$500 may exceed FCC limits. At -large councilor Rebecca Lisi, on behalf of a
Holyoke resident, recently submitted to the town lawyer a copy of the ordinance drafted by Pittsfield.
Information from https://www.lasttreelaws.com/ordinances.htmt
Pittsfield, Massachusetts
Proposed Section: Wireless Communications Facilities
Telecom company must prove prefered site/existing structure does not work
Above ground aesthetic requirements
Sound and light restrictions with emphasis on industry proving compliance
Pittsfield, Massachusetts: Proposed Section: Wireless Communications Facilities PDF
Little Silver, New Jersey
• Carriers should provide notice to property owners within five hundred (500') feet of the proposed
Telecommunications Facility.
• The applicant must demonstrate to the reasonable satisfaction of the Borough that no existing
personal wireless Telecommunication Service Facility within a reasonable distance can accommodate
needs.
• Indemnification clause: "Each license grantee shall indemnify and hold the Borough and its officers,
employees, agents and representatives harmless from and against any and all damages, losses and
expenses, including reasonable attorney's fees and costs of suit or defense, arising out of, resulting
from or alleged to arise out of or result from the negligent, careless or wrongful acts, omissions,
failures to act or misconduct of the grantee or its affiliates, officers, employees, agents, contractors or
subcontractors in the construction, operation, maintenance, repair or removal of its
Telecommunications Facilities, and in providing or offering Telecommunications Services over the
facilities, whether such acts or omissions are authorized, allowed or prohibited by this Chapter or by a
grant agreement made or entered into pursuant to this Chapter."
• "Little Silver New Jersey: AN ORDINANCE AMENDING AND SUPPLEMENTING CHAPTER 16A "LAND
USE AND DEVELOPMENT ORDINANCE" OF THE REVISED GENERAL ORDINANCES OF THE BOROUGH
OF LITTLE SILVER, COUNTY OF MONMOUTH, STATE OF NEW JERSEY AMENDING SECTION 16A-2
"DEFINITIONS" AND 16A-5 GENERAL PROVISION ADDING NEW SUBSECTION 5-28 "PLACEMENT OF
TELECOMMUNICATIONS FACILITIES"
New York
Ithaca, New York
Ithaca's code of 250 feet
• A 1500 foot setback between antennas (old code: 0 feet)
• A 250 foot setback between antennas and homes/schools (old code: 8 feet)
• Requiring proof of a significant gap in service coverage for any antenna, proven by `in -kind' testing
(such as drive -by tests and dropped calls)
• Clarifying that an applicant's claim that it needs the proposed tower for "future capacity" or to
"improve coverage" is not sufficient to establish that it suffers from a significant gap in coverage
• Requring the least intrusive methods to fill any coverage gap for antennas
• Requiring that a visual impact analysis be submitted for any new proposed antennas
• Requiring General Liability Insurance without a pollution exclusion
• Allowing for random, unannounced radiation testing for all towers done by the City at the expense of
the applicant
• Including fall -zone requirements that wireless facilities are maintained at a sufficient distance from
other structures and the general public
• Allowing for revocability (a clause allowing the voiding of any contract requiring its modification in the
event of a regulatory change)
• Mandating certified mail notices of any proposed tower be sent to people living near a proposed site
before approval, paid for by the applicant.
• Establishing a procedure for any disabled persons suffering from EHS to submit requests/grievances
in accordance with the ADA
• Establishing that the codes apply to all wireless transmitting antennas, including any on private
homes (aimed at the OTARD challenge)
• Deputizing any citizen to test for RF emissions
• Protecting against reductions in property values of properties situated near wireless facilities
• Requiring that everything submitted by the applicant is done so under oath and penalty of perjury
• Download PDF of Ithaca code here.
Scarsdale, New York
Scarsdale, New York Passed a Wireless Ordinance To Limit Cell Antennas 500 Feet From
Homes, Schools and Daycares
1. Pre- and post -installation RF testing requirements by independent contractor; additionally, routine
annual monitoring
2. Pre -notification of small cell application to residents within a 1,000-foot radius of proposed
installation
3. Pre -notification of small cell application to President -At -Large of the neighborhood association and to
the president of neighborhood association in which the wireless facility is proposed
4. Location preferences (restricted zones) that require special exceptions for installations
• Any location within 500 feet from a residential dwelling unit
• Any location within 500 feet from a daycare facility or school
• Any location within 500 feet from a house of worship
• Any location within parkland
5. Village is insured against any liability for personal injury or property damage or claims pertaining to RF
exposure
6. Existence of appeals process (de novo hearing in front of Planning Board)
(Link to Copake NY code)
Pretesting and post testing by RF engineer
Annual monitoring of RF emissions by the independent RF engineer using actual field
measurements
Hempstead, New York
Wireless Communications Facilities
• Requires a special use permit for cell towers that encourages location of new wireless facilities so as
to minimize their impact on historically sensitive areas around residences, schools, houses of worship,
day-care centers. Seven consideration factors are listed in order from more to least preferred, with
existing towers being most preferred and new towers in residential zones least preferred.
• Prohibits towers from exceeding a height that permits it to operate without artificial lighting
• Allows the town to hire consultants and do inspections
• Set a fee schedule of $500 per pole
• Requires a 4 foot warning sign on the pole
• Utilities at wireless installations should be underground when possible
• Hempstead, New York: Wireless Communications Facilities Ordinance eCodeChapter 142
• Other Links
• https:Hmdsafetech.org/cell-tower-and-city-ordinances/
• https:Hhempsteadny.gov/permits-and-applications/wireless-telecom-ordinance
Zoning Ordinance - Wireless Communications Systems
• No small cells in residential areas or within 100 feet of property used for residential use
• Small cells must be 2000 feet apart (unless colocated)
• Small cells are between 20-30 ft high (may be able to exceed 30 ft if colocated)
• Every attempt shall be made to locate small cells on existing structures; if not available, within public
right of way
• All related equipment should be underground or wholly contained so not visible
• Each facility shall consist of no more than 1 antenna/user and capable of providing communication for
at least 2 users
Mason, Ohio Zoning Ordinance PDF
Lancaster, Pennsylvania
Zoning Changes via Ordinance 9-2016
• City Council rushed through zoning changes to declare many streets off limits to new poles (said they
could be much taller than existing ones)
• Public Utility Commission stripped Mobilitie and other distributed -antenna companies of utility
status, meaning that they would not get any more "certificates of public convenience" in
Pennsylvania.
Lancaster, Pennsylvania Ordinance No. 9-2016 PDF
News Stories
• http://www.philly.com/phi[ly/business/comcast/philly-and-suburbs-brace-for-attack-of-the-small-
cells-20170601. htm l? arc404=tru e
• http://www.govtech.com/dc/articles/Philadelphia-Braces-For-Small-Cell-Future.htmt
Note: This list was compiled from EHT research of various sources and a special thank
you to Physicians for Safe Technology, My Streets My Choice and Last Tree Laws for
their extensive resources.