HomeMy WebLinkAbout04-23-2020 Public Comment - M. Hance - Moratorium on small cells 5GFrom:agenda@bozeman.net
To:Agenda
Subject:Thank you for your public comment.
Date:Thursday, April 23, 2020 7:29:55 AM
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Form Name:Public Comment Form
Date & Time:04/23/2020 7:29 AM
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Submitter ID:26214
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Public comment may be submitted via the form below, or by any of the following options.
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Email:
agenda@bozeman.net
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Attn: City Commission
PO Box 1230
Bozeman, MT 59771
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Due to City Hall's closure in response to the Covid-19 pandemic, in-person delivery of comments is not
available until further notice.
First Name Birgit
Last Name Hance
Email Address hancecamp@yahoo.com
Phone Number 4065872043
Comments
Dear Chris Mehl & City Council Member,
Until studies prove the safety of 5 G Please:
I ask that you impose a moratorium on “small cells” and other wireless infrastructure permits process and
deployment 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
virtually unsupervised deployment of harmful wireless infrastructure. Our local leaders should not have to
dedicate time and resources to policing whether the wireless companies are following local and state law
right now – they need to focus on more important things.
The FCC wireless permit rules allow emergency moratoria. Homeland Security guidelines emphasize that
maintenance of existing communications capability is the priority. But new construction is not “essential.”
The FCC has directly held a local jurisdiction can impose a temporary halt to deployment and permits during
emergencies. 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 a natural 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 of telecommunications services.’”)
Homeland Security has declared that local government is on the forefront and can take control over
determining whether to temporarily halt all non-essential activity. Homeland Security guidance documents
prioritize maintenance of existing Communications Systems, and do not support “essential” status for new
construction. See Homeland Security Cybersecurity & Infrastructure Security Agency, Identifying Critical
Infrastructure During COVID-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 existing systems, but new
communications facilities construction is and should be deemed nonessential, and subject to lockdown 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.
I appreciate your efforts in this matter.
Sincerely,
Birgit Hance
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City Of Bozeman
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