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HomeMy WebLinkAboutCOM 0110.080 2024-2026Aloha PCPLUED Committee Members, Thank you for your thoughtful consideration of Bill 24 and for approving the 100mph sustained wind amendment. We appreciate that so very much. As the founding Director of Safe Tech Hawaii, a coalition of residents concerned about the proliferation of wireless technology and supporting safer technology, I'm writing on behalf of our organization. We support the two amendments put forth by CM Villegas, namely: 1) Clarify community notification requirements 2) Adopt an application form that clarifies the clock start date Regarding #1, clarify community notification requirements: Vague language such as "notify", "engage", "affected community" and "adjacent landowners" is confusing and open to dispute Specific requirements need to be defined for clarity and to avoid misinterpretation The vague language in Bill 24 creates confusion and could cause application delays The vague language leaves open a possible loophole to be exploited at the expense of the community Protect the community by specifying notification of those within 500 feet of proposed installation by certified mail that begins within 5 days of application submission The community deserves to be notified, in writing, delivered to their address. Regarding #2, adopt an application form that clarifies clock start date. This is for the County's own protection. Exactly when the 60-day clock begins has been disputed in other jurisdictions This confusion causes delays and provides a potential loophole that has been exploited by applicants Bill 24 should include a form that specifies all permit application requirements must be completed before the 60-day clock begins In a recent Ninth Circuit Court ruling of October, 2024, the Court clarified the 60- day clock regarding modification requests The Court upheld the FCC's decision that the EFIR clock begins when an applicant satisfies both of the following criteria: (1) Takes the first procedural step that the local jurisdiction requires, and (2) Submits written documentation showing that a proposed modification is an eligible facilities request (EFR) Under this rule, the County should adopt its own Permit application form and require that all permit applications, including an EFIR application, must be made on that form to ensure that is the first procedural step in triggering the clock We also need to point out a problem with monopine towers, which are advocated in Bill 24 for concealment purposes because cell towers disturb the beauty of the island. New evidence shows that monopine towers harm the environment by shedding their fake branches and needles and depositing micro plastics into the aina. Like fake Christmas trees, faux pine needles attached to monopine towers are made of plastic, and the monopine's branches are made of fiberglass reinforced plastics. In the exposed natural environments subject to high levels of UV radiation from the sun, dramatic shifts in temperature, high winds and rain, the faux pine needles and branches rapidly degrade and break off from the towers creating widespread plastic debris fields below that degrade into micro plastic and contaminate the environment. In Lake Tahoe, CA, in several existing monopine sites around the Lake Tahoe basin, volunteers found massive amounts of fallen, brittle plastic pine needles at the base of each monopine tower site, along with chunks of broken fiberglass reinforced plastic branches. Large garbage bags have been filled to the brim with plastic waste from the monopine towers. These plastic fragments are carried by wind and rain into adjacent waterways. There is no way to contain these plastics at the tower site! We strongly urge the Committee to remove from Bill 24 the monopine option for concealing telecommunication towers. Thank you for your kind consideration of these amendments which members of the community want to see adopted for their safety and protection. Sincerely, Debra Debra Greene, PhD Founding Director Safe Tech Hawaii PHONE: 808-874-6441 WEBSITE: www.SafeTechHawaii.com Sent from my faster, safer, more secure HARDWIRED computer