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Introduction:

We, the undersigned residents and stakeholders of Bainbridge Island, recognize the critical need for reliable cellular coverage to ensure public safety, economic vitality, increased competition for high-speed internet, and an enhanced quality of life. However, the current wireless communication facilities ordinance (Chapter 18.10 of the Bainbridge Island Municipal Code) presents significant barriers to timely and cost-effective deployment of the necessary infrastructure. This outdated ordinance, with its complex and subjective approval processes, hinders the ability of mobile carriers to invest in our community and provide the connectivity we deserve. We urge the Bainbridge Island City Council to modernize this ordinance to reflect the demands of a connected world while balancing the unique character of our island.

Our Objectives:

1.     Enhance Public Safety: Reliable mobile communications are vital for emergency response, disaster preparedness, and everyday safety. Consistent cellular coverage ensures residents can contact emergency services, receive vital alerts, and stay connected during critical situations.

2.     Enhance Competition for High-Speed Internet: Improved cellular infrastructure, particularly robust 5G connectivity, will foster competition among internet service providers, leading to more affordable and diverse high-speed internet options for residents and businesses.

3.     Account for Backup Capabilities During Regional Power Outages: We need resilient infrastructure with backup power solutions to ensure continuous communication during power outages, enhancing community resilience and safety.

4.    Streamline the Regulatory Process: Advocate for a streamlined and objective permitting process for wireless communication facilities, removing unnecessary barriers and promoting efficient deployment.

Specific Needs and Demands:

1️⃣  Available and Improved 5G Signals: We demand the deployment and enhancement of 5G infrastructure to deliver reliable high-speed internet and mobile call capabilities throughout the island.

2️⃣  Elimination of Dead Zones: We seek the elimination of dead zones in commonly accessed areas, including highly traversed roads, dense population centers, and public spaces.

3️⃣  Minimization of Dead Zones in Lesser-Populated Areas: While prioritizing high-traffic areas, we also recognize the need to minimize dead zones in lesser-populated areas to ensure comprehensive coverage for all residents.

4️⃣  Objective Permitting Standards: Replace subjective criteria with clear, measurable standards for evaluating permit applications, such as:

• Specific RF emission limits: Adhere strictly to FCC guidelines for maximum permissible exposure (MPE) limits for radiofrequency (RF) electromagnetic fields. These limits are designed to protect public health and are based on extensive scientific research. (See FCC guidelines: https://www.fcc.gov/engineering-technology/electromagnetic-compatibility-division/radio-frequency-safety/oet-bullettin-65
• Defined setbacks from property lines and structures: Establish clear setback requirements based on the height and type of wireless facility. For example:
  • Macrocell towers: A minimum setback of 1.5 times the tower height from property lines and residential structures.
  • Small cell facilities: A minimum setback of 10 feet from property lines and 25 feet from residential structures.
  • Consider incorporating tiered setbacks based on zoning districts (e.g., greater setbacks in residential zones compared to commercial or industrial zones).
• Objective criteria for "aesthetic compatibility": Develop specific, measurable guidelines for evaluating aesthetic compatibility, such as:
  • Color palettes: Require colors that blend with the surrounding environment (e.g., earth tones, muted greens).
  • Materials: Encourage the use of materials that complement the natural or built environment (e.g., wood, stone, brick).
  • Screening and landscaping: Mandate the use of landscaping and screening elements to minimize visual impact.
  • Example: The City of Boulder, Colorado, has detailed design guidelines for wireless facilities that include specific criteria for color, materials, landscaping, and screening. (See Boulder's Wireless Design Guidelines: https://bouldercolorado.gov/guide/wireless-facilities-design-guidelines

5️⃣  Reduced Approval Timeframes: Establish reasonable and predictable timelines for permit processing, such as:

• Completeness review: 15 business days for the initial review of permit applications to determine completeness.
• Environmental review (if required): 30 business days for environmental review, if applicable, based on the State Environmental Policy Act (SEPA) guidelines.
• Final decision: 45 business days for a final decision on the permit application after the completeness review and environmental review (if required) are completed.
• Example: The City of Bellevue, Washington, has established clear timelines for wireless facility permit reviews, with a goal of completing reviews within 60 days. (See Bellevue's Wireless Communication Facility Permitting Process: https://bellevuewa.gov/city-government/departments/development-services/permits-and-inspections/wireless-communication-facility-permitting-process

6️⃣  Transparent & Reasonable Fee Structure: Implement a clear and predictable fee structure for permit applications, ensuring fairness and minimizing financial barriers.

• Publish a fee schedule: Clearly list all fees associated with the permit application process, including application fees, review fees, and inspection fees.
• Base fees on actual costs: Ensure that fees are reasonably related to the actual costs incurred by the city in processing the application.
• Consider fee waivers or reductions: Explore options for waiving or reducing fees for certain types of facilities, such as small cells deployed on existing structures, to encourage their deployment.

7️⃣  Predictable Design Standards: Provide clear and concise design guidelines for wireless facilities, balancing aesthetics with functionality. This could include:

• Preferred types of camouflage for towers: Provide a list of acceptable camouflage techniques, such as monopine designs, faux tree structures, or architectural treatments that blend with the surrounding buildings.
  • Monopine Designs: Towers designed to resemble tall, slender evergreen trees, mimicking the dominant tree species on Bainbridge Island. These designs effectively blend into the natural landscape, especially when placed among existing trees.
  • Faux Tree Structures: More elaborate camouflage techniques that replicate the appearance of specific tree species, including branching patterns, foliage texture, and color. These structures can be particularly effective in visually sensitive areas.
  • Architectural Treatments: Architectural treatments can be used to integrate towers located in or near developed areas with the surrounding buildings. This could include cladding the tower in materials that match the building facades, incorporating architectural details that complement the surrounding structures, or designing the tower to resemble a chimney or other architectural element.
  • Color Matching: Require that the color of the tower and associated equipment be carefully matched to the surrounding environment, using muted earth tones or colors that blend with the natural or built landscape.
  • Landscaping and Screening: Mandate the use of landscaping and screening elements, such as trees, shrubs, and fences, to further minimize the visual impact of the tower.
  • Example: The City of Scottsdale, Arizona, has a comprehensive wireless communication facility design manual that provides detailed guidance on camouflage techniques, including specific examples of monopine designs, faux tree structures, and architectural treatments. (See Scottsdale's Wireless Communication Facilities Design Manual: https://www.scottsdaleaz.gov/Assets/ScottsdaleAZ/Development/Codes+and+Standards/Wireless+Communication+Facilities+Design+Manual.pdf
• Encouraged use of existing structures: Prioritize the collocation of wireless facilities on existing structures, such as streetlights, utility poles, and buildings, to minimize visual impact. Encourage the placement of antennas and equipment underground or on rooftops whenever feasible to minimize visual impact.
  • This could directly support the severe lack of coverage in Lynnwood Center and other “villages” on Bainbridge Island as well as downtown Winslow.
• Limitations on Tower Height in Specific Zones: Establish maximum height limits for towers in different zoning districts, taking into account the surrounding land uses, visual sensitivities, and natural impediments such as evergreen trees common on Bainbridge Island.
  • Balance Height Limits with Natural Screening: While establishing height limits is important, recognize that the dense evergreen canopy prevalent on Bainbridge Island can provide significant natural screening for taller structures.
    • Consider allowing taller towers in areas with dense tree cover: Where the natural landscape provides effective visual buffering, consider allowing taller towers to achieve better coverage and capacity, especially in areas with challenging terrain.
    • Implement a tiered height limit system: Establish different height limits based on zoning districts and the presence of natural screening. For example:
      • Residential zones with minimal tree cover: Stricter height limits (e.g., 60 feet).
      • Residential zones with dense tree cover: More flexible height limits (e.g., 80-100 feet).
      • Commercial and industrial zones: Higher height limits (e.g., 120 feet or more), particularly if located away from residential areas.
      • Example: The City of Seattle's wireless communication facilities regulations take into account natural screening when evaluating tower height and placement. They allow for taller towers in areas with significant tree cover, recognizing that the visual impact is reduced. (See Seattle's Wireless Communication Facilities Regulations: https://library.municode.com/wa/seattle/codes/municipal_code?nodeId=TIT23LASACO_SUBTITLE_IIIBUCO_CH23.52WI
      • Example: The City of Portland, Oregon, has developed a Wireless Communication Facilities Design Manual that provides detailed guidance on camouflage techniques, co-location options, and height limitations. (See Portland's Wireless Communication Facilities Design Manual: https://www.portland.gov/bps/wireless/design-manual
      • Example: The City of Palo Alto, California, has successfully implemented policies that encourage the use of streetlights for small cell deployment and require camouflage for new towers. (See Palo Alto's Small Cell Wireless Facilities Design Guidelines: https://www.cityofpaloalto.org/Departments/Planning-and-Community-Environment/Planning/Wireless-Communication-Facilities/Small-Cell-Wireless-Facilities-Design-Guidelines

Benefits of Enhanced 5G Coverage:

• Improved Emergency Response: Faster and more reliable communication for emergency services.
• Enhanced Telehealth Services: Enabling remote medical consultations and monitoring.
• Support for Remote Work and Education: Facilitating seamless connectivity for remote workers and students.
• Boost to Local Businesses: Enabling businesses to leverage advanced technologies and reach customers more effectively.
• Smart City Applications: Laying the foundation for future smart city initiatives, such as improved traffic management and public safety systems.

Innovative Solutions to Consider:

• Streetlight Utilization for 5G Densification: Explore the feasibility of utilizing existing streetlight infrastructure to deploy small cell sites for 5G, minimizing visual impact and leveraging existing power sources. For example:
  • https://www.lightmart.com/blog/integrating-5g-technology-into-street-lighting-systems/?srsltid=AfmBOooWs6X6u0Q7rQmwCIkDoQeHpdLjDeJFxB3h5gDZ8NY9mCmkGTPB
  • https://about.att.com/innovationblog/2022/streetlights-to-boost-5g-deployments.html
  • https://infralumin.com/blogs/what-is-a-5g-street-light
  • https://www.ubicquia.com/products/ericsson-street-radio (from Fritz Feiten)
• Hidden Cell Towers with Backup Power Capabilities: Investigate the development of strategically placed, aesthetically pleasing cell towers with integrated backup power systems (e.g., battery storage or generators) to ensure continuous operation during power outages.
• Fiber Optic Expansion: Increase the fiber optic backbone on the island to support the backhaul needs of increased cellular traffic.
• Microcell and Picocell Deployment: Implement smaller, low-power cell sites strategically to fill coverage gaps and enhance capacity.
• Public-Private Partnerships: Foster collaborations between the city, mobile carriers, and PSE to share resources and accelerate infrastructure deployment.

Addressing Common Rejections:

It's important to acknowledge and address potential concerns that may arise regarding the improvement of cellular coverage on Bainbridge Island. We aim to be transparent and provide factual information to alleviate these concerns.

• Unsightly Infrastructure (Visual Impact):
  Definition: This concern revolves around the perception that new cell towers, small cell sites, and related equipment will negatively impact the island's aesthetic appeal and natural beauty.
  • Our Response: We understand the desire to preserve Bainbridge Island's natural beauty.
  • Proposed Solutions:
    • We advocate for the collaborative development of design guidelines that prioritize integration and camouflage techniques.
    • We encourage using existing structures, such as streetlights and buildings, for small-cell deployment, minimizing visual impact.
    • Example: The City of San Francisco has guidelines for small cell deployment that prioritize co-location on existing structures and camouflage techniques to minimize visual impact. [Link to SF Planning Code: https://default.sfplanning.org/currentplanning/wireless/FAQ_Small_Cell_Streetlight_and_Transit_Poles.pdf ]
• Limiting Growth" (Preservation of Island Character):
  • Definition: Some residents may fear that improved cellular connectivity will encourage increased development and population growth, potentially altering the island's character.
  • Our Response: Improved connectivity is essential for supporting the existing community and enabling remote work, which can actually reduce the need for commuting and new development.
  • Our Approach:
    • We emphasize that reliable cellular infrastructure is essential for supporting sustainable growth and enhancing the quality of life for existing residents.
      Improved connectivity can facilitate remote work and education, reducing the need for residents to commute off-island, which can mitigate traffic congestion and environmental impact.
    • We support the city's current growth management plan and understand that improved cell service is a utility that supports the residents who already live on the island.
    • Example: A study by the Center for Rural Strategies found that broadband access can help revitalize rural communities and support existing businesses without necessarily leading to sprawl. Link to Study: https://ruralinnovation.us/press-releases/new-research-proves-that-providing-fiber-broadband-experiences-to-rural-communities-boosts-income-entrepreneurship-and-business-investment/
• Health Concerns" (Electromagnetic Fields - EMF):
  • Definition: Concerns exist regarding the potential health risks associated with exposure to radio frequency (RF) electromagnetic fields emitted by cellular infrastructure, particularly 5G technology.
  • Our Approach:
    • We will provide access to credible, science-based information from reputable organizations, such as the Federal Communications Commission (FCC) and the World Health Organization (WHO), which consistently affirm that 5G and other cellular technologies operate within established safety guidelines.
      • The FCC sets strict limits on RF exposure to protect public health, and 5G technology operates within these limits.
        • Federal Communications Commission (FCC):
          RF Safety: https://www.fcc.gov/consumers/guides/radio-frequency-safety
        • World Health Organization (WHO):
          Electromagnetic fields and public health: https://www.who.int/news-room/questions-and-answers/item/radiation-electromagnetic-fields
        • Environmental Protection Agency (EPA):
          Radiation Protection: https://www.epa.gov/radiation
      • We will encourage open dialogue and engage with experts to address specific concerns and provide accurate information to the community.
      • We will point out that the level of RF radiation from cell towers is very low, and far lower than many common household devices.

Call to Action:

We, the undersigned, urge the Bainbridge Island City Council to:

1.    Initiate a comprehensive review and revision of Chapter 18.10 of the Bainbridge Island Municipal Code to streamline the permitting process for wireless communication facilities.

2.    Establish clear, objective, and measurable standards for permit approval, eliminating unnecessary subjectivity.

3.    Reduce approval timeframes to ensure timely deployment of critical infrastructure and establish a transparent and reasonable fee structure.

4.    Establish a task force by engaging with community stakeholders, industry experts, and organizations like the National Association of Telecommunications Officers and Advisors (NATOA) in the ordinance revision process.

5.    Prioritize the improvement of cellular coverage as a critical infrastructure project.

6.     Engage with mobile carriers, PSE, and other stakeholders to implement solutions as required.

7.     Conduct regular community meetings or add to existing COBI meeting agendas to provide updates and gather feedback.

8.     Provide transparent reporting on progress.