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CASTLEHonolulu, HI 96825 wwwcrowncastle.com
Via Electronic Submittal at councilremotetestimony@hawaiicounty.gov
RE: Crown Castle Oppose Bill 24 (Draft 2)
Chair Kierkiewicz, Vice Chair Galimba, and members of the Policy Committee on Planning, Land Use and Economic
Development:
On behalf of Crown Castle, a wireless communications infrastructure provider that constructs, operates and
maintains a communications network here on the big Island, I am here today to oppose Proposed Bill 24, Draft 2
as currently drafted and to request amendments that will provide compliance with federal law while also
preserving our ability to provide the critical wireless services that both the County and the community relies upon
as part of their everyday life. Telecommunications infrastructure, including wireless infrastructure, is integral to
daily life, business operations, and government purposes. Wireless connectivity, is an essential service to our
everyday lives and we welcome the opportunity to work with the County to ensure that the regulations adopted
serves doesn't inadvertently create a "prohibition of service", which is explicitly prohibited under federal law.
A summary of our concerns was provided to HI Co. last summer, and we participated in the wireless industry
comments which were submitted on 2/3/25. To date, our concerns have not been addressed and we are
concerned that Proposed Bill 24 will make it extremely difficult to build the critical infrastructure that we all rely
upon for connectivity purposes.
Specifically, we request amendments to address the following:
1. A clear distinction between new tower construction and modifications of existing infrastructure is
needed. Section 6409 of the Middle Class Tax Relief and Job Creation Act mandates approval of
modifications that do not constitute as a substantial change to the facility be approved within 6o days of
submittal. Absent action by the County, the request is deemed approved.
2. Bill 24 conflates antennas and towers which are very different from one another. If the goal is to
encourage collocation on existing infrastructure whenever possible, which we support, please provide
language that recognizes that new antennas on existing infrastructure does not require the same level of
regulation that a new tower might require.
3. Setbacks from residences, schools and hospitals — the current draft requires a 1200' setback from
property lines adjacent to residences, schools and hospitals. No justification for this has been provided.
This is significantly more stringent than current requirements (5 x tower ht) and is not common amongst
other local jurisdictions. This level of setback is not required for safety purposes as towers are designed
to not fail, and regulations that are based on perceived health and safety effects are prohibited by federal
law. We support the proposed 120% setback from all property lines, regardless of the land use.
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The Foundation for a Wireless World. Ref. To:
CrownCastle.com Ref. D au > 1
Alternatively, we recommend a Director waiver of the 1200' setback if needed to avoid an effective
prohibition of service.
4. Minimum lot sizes — Bill 24 proposes minimum lot sizes without any justification. If the purpose of
these requirements is to provide visual screening, this doesn't necessarily accomplish that objective.
Instead, we recommend adoption of objective design standards that takes into consideration some of the
many issues that arise during the siting process.
In summary, we appreciate the County's attention to this important matter and we urge you to postpone adoption
of this ordinance until such time that these issues can be resolved. We stand ready to work with you at your
earliest convenience.
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Sincerely,
Adrian Catalan
Real Estate Specialist
Crown Castle
Adrian.catalan@crowncastle.com
The Foundation for a Wireless World.
CrownCastle.com