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)