Report On the National Antenna Tower Policy Review
Section F — Appendices A, B, C, D, E & F
Appendix A - User Opinions from the Online Discussion Forums
The qualitative analysis for Appendix A was performed by Student-at-Law (3rd Year), Kirsten Drake-McKnight at the University of New Brunswick.
The online discussion forum on the Antenna Review website was open for comment from September 3rd to October 24th, 2003. Approximately 165 comments were posted in the forum, and comments were viewed approximately 6800 times. While the majority of the users were amateur radio operators, comments were also posted by the general public, EMF sensitive persons, community groups, and there was a small amount of participation from the industry.
Below is a sample of comments posted in the discussion form, categorized generally under the 6 policy questions that the Antenna Tower policy review team was asked to comment on.
1. How can the local consultation process regarding the siting of a specific tower be improved? What are the most appropriate time frames for the processes of approving and resolving debates surrounding specific tower placements?
Participants, in general, seemed to want assurance that consultation would incorporate a true dialogue on the issue. At the very least, they wanted to be assured that their views would be listened to and taken into consideration before making decisions.
"We
all want the same things: to
be heard, and to have a fair
review."
(General
Public)
"The
big picture for me is not based
on a false dichotomy of whether
one is for or against cell phone
towers. Rather, it's a question
of responsible tower siting
where the rights of individuals
and communities are respected
by business and the federal
government in the context of
a gross power imbalance."
(General
Public)
Participants believe that Industry Canada needs to play a stronger role in the consultation process.
"Funny
how you will rarely see any
Industry Canada representatives
at your local town hall meeting.
They are always conspicuous
by their absence. Small town
Canada could be easily being
fed a line of BS.
At least by having an Industry
Canada representative there,
the cell companies wouldn't
try it."
(General
Public)
On a further role for Industry Canada:
"The
last step before a site-specific licence
is granted should be: ‘is
the local land use authority
fully aware of its rights and
knows/understands the process?' ‘Did
a legal representative for the
land use authority sign paperwork
to that effect?'"
(Amateur
Radio Operator)
A majority of participants expressed a desire to see a standardized consultation process across the country.
"It
seems clear that there are pockets
across this great country where
putting up a tower of any sort
has been turned into a political
issue, rather than a rational
decision making process. I think
this highlights the need for
a strong centralized approach.
... A standardized consultation
monitored at the federal level
might not appeal to everyone,
but it would at least, hopefully,
be fair or unfair to everyone.
We the public need time to go
over these issues – to
inform ourselves and our neighbors."
(General
Public)
"The
real problem is that there is
no consistency from one town
to the next or from one province
to the next."
(Other)
"From
start to finish, the consultation
process should take no longer
than 90 days
and the process and guidelines
should be standardized across
the nation."
(Amateur
Radio Operator)
Amateur radio operators are concerned that in some areas they are required to pay a large consultation fee.
"The
consultation process has to
keep in mind the type of radio
use. If we HAMs
are regulated by Industry Canada
to be non-commercial (ie.
cannot make money at our hobby),
then it makes sense that any
policy or process cannot ask
for any unreasonable fees."
(Amateur
Radio Operator)
Amateur radio operators are concerned that public consultation meetings often stir up unwarranted feelings and focus on opinions rather than facts. They would prefer a less emotional consultation process.
"I
firmly believe municipal planning
staff/engineering dept, should
be handling the entire process,
start to finish. They are long
term employees, unlike politicians
who come and go. Town hall meeting
open to the public, press, various "rate
payers groups",
assorted sundry "experts",
nimbys [Not In My Backyard],
et al, are entirely counter-productive,
time consuming, and are generally
used to gauge public anger.
A process whereby the public
could send in written comments
and questions well in advance
would be far better. It would
then give the tower proponent
plenty of time to answer each
and every question in a detailed
fashion."
(Amateur
Radio Operator)
2. What information would most benefit concerned members of the public and how should it be provided?
Amateur radio operators were prompted to participate in the discussion because of difficulties they have had, at the local level, with politicians and residents who are ill-informed about the technical issues surrounding antennas, towers, and RF/EMF issues. In the local consultation process, amateur radio operators would like to see more education about the differences between commercial and amateur antennas. Local community groups also seemed to appreciate the difference between commercial and amateur towers and expressed a need for a distinction between the two.
"In
the eyes of the municipalities,
amateur radio installations
are classified as having the
same type of installation as
a commercial one. ... The land
use authorities don't see the
distinction between the two.
That is the problem."
(Amateur
Radio Operator)
"I
am not a radio amateur (just
a scientist who has worked extensively
with RF)
but it did strike me upon reading
the preamble to the [National
Antenna Tower Policy Review]
questionnaire that there was
an inappropriate lumping together
of cell/amateur towers."
(Local
Community Group)
Much of the discussion surrounded information that should be provided for high output and cellular towers. Basic information, as well as some technical information, were highlighted as important to educate the general public.
"For
high output transmitters there
is very little the public needs
to know if the antennae are
located in unpopulated areas
as mandated by the Radiocommunication
Act. In the rare and unavoidable
event that a populated site
is being considered, citizens
residing or working near the
proposed location must be informed
of the following: Authorities: Which
levels of government have the
authority to review site selection,
grant approval to construct,
conduct building inspections
and rectify interference problems? Alternate
sites: Why
is this site being considered?
What other sites were considered?
Was co-location considered?
Why were the other sites not
suitable (financial, access
coverage, etc.)? Health: What
levels of power output are planned
and what are the estimated/possible
thermal and non-thermal health
effects? How do these compare
to Health Canada's Safety
Code 6? Harmful
effects: What
electronic devices will be affected
and how these affects will be
remedied?"
(Local
Community Group)
"In
all cases (high output and cellular)
the public must be made aware
of the following: What sort
of tower set backs are being
considered? What are the anticipated
wind noise levels? What sorts
of structures are being placed
on the site and how will it
be landscaped? Will there be
noise from the on-site power
and generating equipment? Who
will pay for the loss in taxation
revenues and property values?"
(Local
Community Group)
"What are the thresholds of normal RF/EMF tolerance, how is it measured, how and who would a person contact to ask for a testing of an antenna installation, who is responsible for testing, and how long does it take between a request for testing and a response, and any subsequent action that might need to be taken?" (General Public)
"For
the higher power broadcast transmissions
there must be a regulatory requirement
to provide this information.
This regulation must require
the applicant do it through
public consultation, with Federal
and Municipal government representatives
in attendance, and with minutes
being taken. There should be
a simple and practical public
appeal process. This process
must have some clout and give
the public a fair opportunity
to review and overturn decisions."
(Local
Community Group)
Local community groups seemed concerned about the health effect of towers on wildlife, particularly migratory birds. Amateur radio operators seemed skeptical about any effects on birds, and seemed to believe that current guidelines are sufficient.
"The
current guidelines/rules are
plenty. They just have to be
followed correctly enforced
by both sides."
(Amateur
Radio Operator)
3. What means are available to readily identify whether proposed installations may create radio frequency fields in excess of established exposure limits in areas where people live and work?
Many of the radio operators who participated in the online discussion forum were convinced that cell sites are in compliance with, and generally below, Canada's Safety Code 6 limits. The general public, however, is still concerned about the inconclusive results of studies about health effects. They want more information about testing exposure levels and about EMF-sensitivity.
"It
seems premature to say that
there are no health risks. ...
The data seem far too inconclusive
to take a strong stand either
way, which does not seem to
have deterred the cell phone
companies and Cell Phone Canada
from doing so. There is a lot
of material on the web about
this. I don't know enough to
evaluate how good it is but
I found some of it to be informative
in raising some issues and possible
concerns to research further."
(General
Public)
"I
doubt that there are many who
are qualified enough, and have
researched it enough, to know
for a fact that absolutely no
one would be sensitive to EMF or
anything else. You know how
sensitive your skin gets after
a sunburn. Maybe there are person
specific situations that predispose
a person to be sensitive to
certain things."
(General
Public)
Some users also expressed concerns about the cumulative effects of towers.
"Another
question I would have is to
ask is if there are cumulative
effects from multiple antennas
on the same tower - I have heard
that antennas for different
uses can have different frequencies
so don't necessarily have cumulative
effects when placed next to
each other - I just want to
know that someone is actually
keeping track of this and that
there is a useful, responsible
and accountable process in place
that keeps it all in check -
what is the process and who
enforces it?"
(General
Public)
4. Can protocols be arranged between local land-use authorities and antenna proponents regarding the planning and siting of antenna structures, visual guidelines and dispute resolution mechanisms?
The telecommunications industry believes that municipal protocols can be beneficial, provided that municipalities recognize the limits of their protocols and respect the Federal Government's jurisdiction.
"Some
municipalities use their development
review processes for consultation,
understanding that they are
not enforceable. The answer
for others is a protocol created
in co-operation with
the proponents of antennae structures.
... A protocol can reduce controversy
by setting realistic expectations,
recognizing the Federal Government's
jurisdiction, and the balance
between the municipality's land
use objectives and the benefits
of wireless. The delegation
of commenting powers to municipal
staff based upon the protocol
reduces the burden on Council
agendas and municipal resources."
(Industry)
Radio amateurs want a clear legal distinction between towers used for commercial and personal use. These distinctions should be reflected in municipal protocols.
"There
needs to be a clear separation
of towers used for commercial
purposes and those used for ‘personal'
use... not only amateur radio,
but also citizen's band, and
receiving antennas for satellite
TV, and terrestrial radio and
TV signals."
(Amateur
Radio Operator)
"Amateur
radio operators are very concerned
about being ‘side-swiped'
by any new regulatory regime."
(Amateur
Radio Operator)
Radio amateurs talked at length about the community benefits of antennas, particularly amateur towers, for emergency services. They believe that in establishing local protocols, the potential for emergency services should be considered. (Also see question # 5)
"Our
community's ability to assist
in emergencies, such as the
BC forest fires, Ontario blackouts,
Ontario/Quebec ice storms, Manitoba
and Saguenay floods and the
Swissair crash at Peggy's Cove
all depend on being able to
properly function... which we
can't do with unreasonable tower
restrictions."
(Amateur
Radio Operator)
Local community groups see a need for tower approval methods that recognize the need for community involvement.
"They
key I believe is a community
review process that requires
technological systems to be
integrated into the built environment
and become part of the standard
community development approval
system. We can not isolate communication
towers from their impacts on
the community and the community
role in determining adequate
solutions to our landscape and
viewpoints. I believe that this
recognition will automatically
provide more creative and satisfactory
solutions to the implementation
of towers into community fabric."
(Local
Community Group)
Radio operators are concerned about visual guidelines in local protocols. (Also see question # 6)
"Opinions
of visual impact are hard to
legally define. I may not like
the look of a neighbor's shed
painted bright pink, but there
is nothing I can really do about
individual taste. The same with
a tower on private property.
Structural safety - yes, Safety
Code 6 - yes, but looks - no.
Opinions should not be allowed
to impede or affect any tower
review process, amateur or otherwise."
(Amateur
Radio Operator)
"I
don't like my neighbor's rusted
out cars, rental units, people
who paint their entire home
an awful orange colour (with
lime green trim on the windows),
wild parties, stereos at 3 AM,
etc. A free standing Trylon
(with mast) is more than reasonable."
(Amateur
Radio Operator)
5. How and to what extent can tower sharing be utilized in order to reduce the total number of towers?
Tower sharing and co-location for commercial towers is seen as desirable by most of the groups who participated in the online discussion forum.
"Few
would argue that towers are
not an eye-sore,
but they are a necessary evil
for delivering wireless services.
There are technical arguments
for certain mismatches of technologies
on a common tower, but for many
scenarios mixed technologies
and spectrum bands can coexist
on a common tower. Sharing of
towers can present both an economic
benefit to service providers
and reduce the negative aesthetic
impact of unnecessary towers.
... Any steps that can be taken
to reduce the number of towers
without undue negative impact
on open competition, yet maintaining
strict safety standards should
be welcomed."
(Other)
Negative financial burdens on the industry as a result of tower sharing were addressed, but many participants held the view that municipalities should erect towers themselves, and lease space to the industry.
"One
to two cell phone companies
may not want to spend huge money
on a tower designed for 4-6 antenna
arrays, then wait years on end
to see if other cell companies
decide to join in and pay their
share."
(Amateur
Radio Operator)
"Why
should the first cell company
pay all the start up costs for
an oversized tower that will
handle all of the competition?
Would you? I wouldn't."
(Amateur
Radio Operator)
"Either
get individual municipalities
to install, and pay for the
towers (and then lease space
on them), or [the federal government
can] change the tax write off
laws for the company that installs
an oversized tower first in
each area."
(Amateur
Radio Operator)
"The
municipalities can get into
the tube/tower business. If
tubes/towers are going be in
their backyards, they could
have complete control over ALL
of them, and make a ton of money
to boot. The least amount of
structures would result overall,
citizen's concerns would be
met
way beforehand, and the public
would benefit from maximum competition
being made available on each
site that they own." (Amateur
Radio Operator)
Amateur radio operators expressed the view that while co-location and tower sharing may be effective for commercial towers, it is generally not an option for amateur radio operators. Because it is a hobby, most amateur radio operators erect antennas on their residential property.
"In
the case of amateur radio, shared
towers are pretty much unworkable
unless the HAMs
happen to live on adjacent properties."
(Amateur
Radio Operator)
"From
a public service/disaster response
point of view, having many HAMs
with separate stations/towers
is a good thing. If ninety percent
of them are disabled by a disaster,
there are still plenty left
to keep communications going,
whereas other modes like telephone,
cell and public service radios
will be either disabled (likely)
or overloaded (certainly)."
(Amateur
Radio Operator)
Participants recognized that there may be several interpretations of co-location, and they would like to see co-location defined for clarity.
"There
appears to be several versions
of "co-location". Co-location could
mean several antenna arrays
sharing a common tower, OR it
could mean several broadcast
transmitters all sharing the
same antenna. This same concept
would work for other services
as well. OR, it could mean grouping
a bunch of towers all located
on one site, ie. 5 separate
towers all sharing the same
mountain top/access road/commercial AC power
etc."
(Amateur
Radio Operator)
6. What evidence exists that property values are impacted by the placement of antenna towers?
Participants were divided on the issue of property values.
"It
should be obvious that a high
degree of pleasure is gained
by the opportunity for a view,
and a premium is paid for land
and buildings providing this
view. It can easily be shown
that view lots with open views
of landscape have much higher
values than similar lots without
the views. Despoiling the view
by inappropriate construction
creates a loss of benefit and
value. The base issue is not
that value is lost, but that
value be saved or protected,
or alternatively that owners
be compensated for a loss of
view. The greater issue is the
loss of an attractive community
for all residents by wanton
disregard for landscape values
including views of the horizon.
It is interesting to note that
the Eiffel Tower in Paris was
initially considered to be an
abomination to the classic City
of Paris, but today is considered
an emblematic icon for Paris.
However, our urban forest of
electrical and telephone poles
have never been considered beautiful
and never will. So clearly there
needs to be public discussion
about the role, location, cost,
and nature of communication
towers."
(Local
Community Group)
"I
think that it's more of a perception
that a tower will reduce property
values. We have towers for water
and power and these seem to
be accepted (not much of a choice
really). Perhaps the benefits
of antenna towers need to be
enforced as it seems that people
just focus on the tower itself
rather than its purpose. Also,
any associated health risks
need to be addressed."
(General
Public)
"My
experience supports the idea
that any "despoiling
of the view" has
a negative effect on resale
values. This may not be so true
in an urbanized area where condos,
hydro lines, cell towers and
who knows what else are part
of the everyday landscape. ...
Now that I have a CB/HAM enthusiast
as a neighbour, who has erected
a 90 foot
tower, I am experiencing (along
with my neighbours) significant RF interference
for the first time – complete
cutouts on wireless phones and
on several broadcast TV signals.
We live in an area not served
by cable and rely on antenna
reception of TV and
recently of broadband internet
signals. This annoyance can
also affect the desirability
of living here, just as much
as regular loud parties and
properties strewn with junk."
(General
Public)
In general, amateur radio operators who participated in the online forum do not think that amateur towers would cause a significant decrease in property values, when compared with other eyesores.
"Amateur
radio towers are not for commercial
purposes and serve as a great
hobby and communications in
time of disaster. The tower
is generally taken down when
the Amateur operator moves or
dies. Most towers do not exceed
50 feet
in height; many trees exceed
that height. Property values
are affected more by a dirty,
sloppy yard/house on the street,
wrecked cars and trucks (in
various states of repair) parked
on the street and front lawn
and/or financial forces totally
beyond the control of any home
owner."
(Amateur
Radio Operator)
"Amateur
radio support structures are
small and temporary. When the HAM moves,
the tower is removed. Because
they are small they can often
be well disguised with the nearby
trees. Developers have built
and sold homes in close proximity
to such facilities, and while
any number of factors can affect
the value individual's place
on property, there is little
evidence that amateur radio
communication facilities cause
a decrease in the value of surrounding
properties. In addition, evidence
from tax assessors and real
estate specialists indicates
that there is no decline in
property values or tax assessment
solely due to the presence of
amateur radio communication
facilities in the area. In some
cases property values increase
as the proximity of the HAM increases
the resources in any emergency/disaster
situation, and the speed of
response if such occurs."
(Amateur
Radio Operator)
"One
could sit here all day debating
property values, and what causes
them to decrease. Everything
from high crime, certain population
groups, a major employer in
town folding up, lousy weather,
drinking water gone bad, forest
fires destroying the landscape,
and on and on."
(Amateur
Radio Operator)
Several members of the general public believe that an assessment of property values should be part of the review process, and possibly compensation for property owners, if a decrease in property value is shown.
"An
independent review and evaluation
should be required to assess
the impact of cell phone installations
on property values of individual
property owners affected. Where
property values diminish, cell
phone companies should provide
compensation to property owners
for their loss. It is ridiculous
to not recognize the possibility
that in some instances a tower
installation that is placed
adjacent to residential property
would significantly lower property
value. Assessment of the financial
impact on individual property
owners should be part of the
required review process. ...
An ombudsman who can represent
the rights of individual citizens
in these matters and has the
authority to order compensation
would make cell phone companies
much more sensitive to the financial
and other impacts of their placements
on individual property owners."
(General
Public)