HomeMy WebLinkAbout2018-02-06 Letter to Takashi Ohno re HB 2651, Relating to Wireless Broadband FaciltiesHarry Kim
Mayor
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Wil Okabe
Managing Director
Barbara J. Kossow
Deputy Managing Director
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February 6, 2018
Representative Takashi Ohno, Chair
Committee on Intrastate Commerce
Hawaii State Capitol, Room 429
Honolulu, HI 96813
Dear Chair Ohno and Committee Members:
Re: Testimony in Opposition of HB 2651,
Relating to Wireless Broadband Facilities
Hearing Date: 02/06/18 — 10:30 am; Conference Room 429
Thank you for this opportunity to testify in opposition of HB 2651.
HB 2651 deals with the installation of telecommunication facilities on state and
county -owned property. This Bill is similar to legislation which was proposed last year
that the County opposed; however, the present version of the Bill has some aspects
which are even more cumbersome than the prior versions.
The County objects to the limitation in the Bill of $40 for annual fees (which is
supposed to, but likely will not, cover the costs of the private company occupying space
in the right of way and using resources such as electricity), the overbroad definitions of
"right of way" (including utility easements) and "state or county pole" (which can include
poles that the County does not solely own, manage, or operate), the lack of discretion
and limited bases for rejecting applications, the dearth of fees and regulation for "micro'
wireless facilities, the limits on bonds of $200 per small wireless facility and $10,000 for
total bonds county -wide for a company's equipment, the prohibition on the County being
named as an additional insured to any insurance policy it may require, the piecemeal
process which will result if an applicant chooses to file a "consolidated" application for
multiple sites and there are problems with some of the sites but the County needs to
continue processing the same application for the other sites, the time -limit on
applications imposing deemed approvals which would even apply to a "consolidated"
applications, the failure to address the requirements of Chapter 205A, the difficulties in
keeping inventories of this equipment and notifying the appropriate party if the
equipment needs to be inspected or repaired, and the twenty-year duration of a
company's permit.
County of Hawaii is an Equal Opportunity Provider and Empllem.
Testimony in Opposition of HB 2651
February 6, 2018
Page 2
The County also repeats its prior objections that this Bill will not allow it to
adequately protect against the overburdening of its equipment, or a wireless facility or
network causing interference with the County's existing equipment or system. The
County is concerned about the effect the bill may have on various utilities' poles that the
County needs for its structures and projects as working with the utilities can already be
a complex process. The colocation raises security concerns, concerns about existing
equipment being damaged by allowing private entities to do installation and other work
on County sites, and will increase the use and wear -and -tear on existing utility poles.
The bill does not a) grant counties immunity for private entities occupying and/or using
county property (it grants immunity for installation, maintenance, and repairs, but not for
claims arising from the private companies' operation or use of their equipment), b) allow
the counties to sufficiently recoup costs due to a small wireless facility or network's use
of counties' utilities, or c) expressly allow counties to require companies that are using a
county's property to assume liability for any damages to existing equipment or
structures and to defend and indemnify a county for any such damages.
The County also notes that it has actually been willing and able to work with
telecommunications companies in their efforts to implement small wireless network(s) in
the right of way; however, it has only been approached by one company that has not yet
proposed an adequate location to install its equipment. Some of that company's
proposals would have violated the Americans with Disabilities Act, others were
technically infeasible, and one proposed installing equipment on property that is not
owned by the County.
For the reasons above, we cannot support HB 2651. The County would consider
legislation that would be limited to Section 10 of the Bill, which requires the State and
counties to adopt their own laws, regulations, or agreements with the cellular
companies.
Respectfully submitted,
Harry Kim
Mayor, County of Hawaii
County of Hawaii is an Equal Opportunity Provider and Employer.