2nd Round of Comments from Idahoans for Safe Technology
On September 20, 2022 ITD had another rulemaking meeting. ITD presented their Utility Accommodation Policy Draft #2 to stakeholders. ITD has requested that comments or requested changes to the second draft of the policy be submitted to them on or before Sept 28th, 2022. Idahoans for Safe Technology has drafted the following comments IFST 9/27/22 Draft 2.1 Utility Accommodation Policy Comments. If you support our views please email ITD and tell them that you strongly support the recommendations from IFST.
- Ramon Hobdey-Sanchez: email@example.com
- Robert Beachler: firstname.lastname@example.org
- Colby Cameron: colby.cameron@itd.Idaho.gov
1st Round of Comments from Idahoans for Safe Technology
5G Wireless Broadband is attempting to take over the Idaho Highways under the guise of “Broadband Connectivity”. If allowed, this would be a massive overreach on behalf of ITD and strip local authority from our Cities and Towns. Among other Idaho cities, Eagle and Ammond, ID have already chosen Hardwire Fiber Broadband networks that will protect the safety of its citizens and meet the needs of the future. Hardwire fiber is the best choice for the citizens of Idaho. It’s 10-times Faster, Environmentally Safe, Secure, Less Expensive to our citizens. Our town does not want harmful, slow, outdated, unsecure wireless broadband from Verizon, T-Mobile & AT&T.
Idahoans For Safe Technology’s request to ITD:
Add or Remove the following language from ITD’s Utility Accommodation Policy and the Design Guidelines
- Add: All SWF (Small Wireless Facilities) and LWF (Large Wireless Facilities), installations in ITD’s ROW must adhere to local City and County Zoning Ordinances. Applicant must obtain and submit local municipality building permit prior to installation of “above” grounds structures.
- Remove: All SWF and LWF language from ITD’s Design Guidelines that conflict with local Wireless Zoning Ordinances such as those in Dalton Gardens, ID or Eagle, ID. This would include setbacks, zoning, and separation distances. Let’s avoid mission creep.
ITD’s mission statement is “YOUR Safety. YOUR Mobility. YOUR Economic Opportunity.”
Wireless Broadband is not environmentally and ecologically safe for humans and nature. Many local cities and towns in Idaho realize this and have taken steps to update their zoning ordinances to provide safe, fast, secure high speed internet to their citizens. ITD, please stay true to your mission statement and keep safe, do not put up accessibility barriers to citizens with EMF sensitivities.
When it comes to the safety of Wireless Broadband, please take some time to do your own research into the scientific facts. Do not listen to high paid lawyers and lobbyists from the Telecom Industry that say there is no proven evidence of harm. Below is a link to my story and the most current scientific information on the harmful effects from wireless radiation. I urge all ITD stakeholders to read the information on this link.
“Maintain local authority for closing the broadband gap. Any state action should still allow for municipalities to build out retail or wholesale models. (e.g. Muni broadband like Ammon, or partnerships like Sandpoint-Ting). Should also maintain tech neutrality, so local governments have the flexibility to meet needs cost effectively, so long as a common benchmark is attained (e.g. FCC definition of broadband)”
Cities and Counties across the state are choosing Hardwired Broadband vs Wireless Broadband (Ammond, ID, Eagle, ID, Dalton Gardens, ID). The current version on IDT’s Design Guidelines does not enforce local zoning ordinances. In fact it strips local authority away from local municipalities.
Small cell/5G attractiveness. Explore pre-emption and other measures that would make Idaho cities more attractive for 5G and enhanced LTE deployments. Raise the “broadband speed” benchmark to 100/10mps to encourage high speed deployment that brings Idaho to the forefront of the country. Idaho cities should be incentivized to build out local “low powered cellular radios” in preparation for 5G capacity, and should decrease barriers for companies interested in supporting that infrastructure
Wireless Broadband is not “pre-empted” by the 1996 Telecommunications Act (See Case No. 18-1051, Mozilla et al. v FCC) . Hardwire Fiber networks are 10x faster (1,000 Mbs vs Wireless 100 Mbs networks). Local government has 100% control over how it gets Broadband. For more info on the law see: Broadband Facts and Terminology.
Dig once. Require city coordination with ISPs and other utilities when there is an opportunity to deploy fiber. Also, require utilities to deploy city-owned fiber at cost during their construction projects. Enact “dig once” legislation to ensure that any road construction also places infrastructure for future broadband infrastructure. The Idaho Transportation Department is currently working on a major reconfigurement project at US-95 & ID-53 interchange. This two-year project will significantly improve traffic flow and enhance safety. As it relates to broadband service improvements in rural Kootenai county, this ITD project has incorporated conduit placement throughout the project area for future fiber optic and broadband services to this community. Joey Sprague with the ITD region 1 office confirmed the “Dig Once” initiative is part of this project.
Deployment of Hardwired Fiber is the key term that ITD should focus on. The bandwidth and speed of a fiber broadband networks offer 1,000 Mbs download speed. Wireless only offers speeds up to 100 Mbs download speed. Being that fiber is buried in the ground it’s naturally protected from forest fires.
Page 35. Idaho’s Broadband Task Force Recommendations to Governor Little. Research organizations such as Harvard University and the Benton Foundation have furnished research reports detailing the benefits of the Ammon Model’s open access marketplace to provide data to offset incumbent monopolistic lobbying:
Ammon Fiber Optic Utility Statistics:
- Started in 2011, some 30+ miles of backbone with access fiber to over 1,200 addresses by 2020.
- Local Improvement Districts are used to expand and pass approximately 500 properties per
- Ammon provides dark fiber leasing in support of national and regional wireless, academic and public safety connections.
- Over fifty 1Gbps contracted circuits are provided for $35 a month to eight separate providers in support of dedicated commercial services.
- Approximately 900 residential properties have access to the Ammon fiber optic utility today with some 600 properties receiving service.
- Ammon charges $16.50 on a resident’s monthly utility bill in support of operations.
- Service providers offer various packages in the marketplace starting at $0 for 15Mbps up to $10 – $25 monthly for 1Gbps service depending on the provider selected. Service costs are set and billed directly by the provider.
In the short and long run, Hardwired Fiber Broadband is better for Idaho communities. Federal broadband money should be spent on hardwired infrastructure rather than lining the pockets of the wireless industry.
Idaho Department of Transportation Broadband Design Info
- IDT’s SWF Infrastructure in Public Right-of-Way Design Guidelines
- IDT’s Guide for Utility Management (Jan. 2012)
- IDT’s Utility Accommodation Policy (2022)
- Map of IDT’s Upcoming Dig Once Road Projects
- IDT’s Broadband Contact: Ramon Sanchez
Idaho Broadband Bills
- HB640aaS-2022: Idaho Broadband Dig Once and Right-of-Way Act
- Idaho Broadband Advisory Board | HB127-2021
- Governor Little accepts Idaho Broadband Task Force recommendations (2019)