HomeMy WebLinkAbout04-05-20 Public Comment - M. Low - Stop Deployment of Wireless during QuarantineFrom:Chris Mehl
To:Agenda
Subject:FW: [SENDER UNVERIFIED]Stop Deployment of Wireless during Quarantine
Date:Sunday, April 5, 2020 6:47:25 AM
Chris Mehl
Mayor, City of Bozemancmehl@bozeman.net406.581.4992________________________________________From: Maria Low [yleo.aspirations@gmail.com]Sent: Saturday, April 04, 2020 10:35 PMTo: Chris MehlSubject: [SENDER UNVERIFIED]Stop Deployment of Wireless during Quarantine
Dear The Honorable Mehl,
Dear Mayor & City Council Member,
We ask that you impose a moratorium on “small cells” and other wireless infrastructure permits process anddeployment until the COVID-19 emergency is over.
The wireless providers are using the COVID-19 emergency as cover to expand and cement their rapid and virtuallyunsupervised deployment of harmful wireless infrastructure. Our local leaders should not have to dedicate time andresources to policing whether the wireless companies are following local and state law, they have far more importantthings to do.
The FCC wireless permit rules allow emergency moratoria. Homeland Security guidelines emphasize thatmaintenance of existing communications capability is the priority. New construction is not “essential.”
The COVID-19 emergency has led to a government shut down of non-essential activity. Hospitals, emergencyresponse and local officials are overwhelmed and they must be allowed to focus on what is indeed “essential”. Nowis not the time to be dedicating resources to expanding, rather than just maintaining, our networks.
The FCC has directly held a local jurisdiction can impose a temporary halt to deployment and permits duringemergencies. In the Matter of Accelerating Wireline Broadband Deployment by Removing Barriers, FCC 18-111,33 FCC Rcd 7705, 7784-7785, ¶157 (2018) (“We recognize that there may be limited situations in the case of anatural disaster or other comparable emergency where an express or de facto moratoria that violates section 253(a)may nonetheless be ‘necessary’ to ‘protect the public safety and welfare’ or to ‘ensure the continued quality oftelecommunications services.’”)
Homeland Security has declared that local government is on the forefront and can take control over determiningwhether to temporarily halt all non-essential activity. Homeland Security guidance documents prioritizemaintenance of existing Communications Systems, and do not support “essential” status for new construction. SeeHomeland Security Cybersecurity & Infrastructure Security Agency, Identifying Critical Infrastructure DuringCOVID-19, https://www.cisa.gov/identifying-critical-infrastructure-during-covid-19 (local control); e-Critical
Infrastructure and Key Resources Support Annex, http://www.fema.gov/pdf/emergency/nrf/nrf-support-cikr.pdf(focus on “protection, response, recovery, and restoration”). Homeland Security, like the FCC, understands that it is
essential in an emergency situations justify focusing on protecting, responding, recovering and restoring of existingsystems, but new communications facilities construction is and should be deemed nonessential, and subject tolockdown for so long as we are under emergency conditions.
Cities can and should impose a moratorium on deployment in their local area and freeze the permit process until the
COVID-19 emergency is over.
Sincerely,Maria Lowp.o. box 11734Bozeman, MT 59719