ADIRONDACK COUNCIL
CALLS ON PARK AGENCY TO COMPEL TOWER PERMIT SEEKERS TO PROVE
THERE ARE NO ALTERNATIVES
Group Urges State to Keep Telecom Equipment
Close to Roads, Hamlets
For more information:
John F. Sheehan, Communications Director
518-432-1770 (w)
518-441-1340 (cell)
Released, Wednesday, June 15,
2005
RAY BROOK, N.Y. – The Adirondack
Council today called on the Adirondack Park Agency to adjust
its tower construction policy to require applicants to prove
there are no viable alternatives before the Agency even considers
the permit application to be complete.
In addition, the group called
on the APA to restrict all new telecommunications installations
to the major state highway corridors and communities, and keep
all new equipment out of the “forever wild” state Forest
Preserve. The Adirondack Council – the largest environmental
organization in the Park – today expressed its concerns
in a letter to APA Chairman Ross Whaley. (Letter follows press
release.)
“We understand the need
for effective communications in a remote area such as the Adirondack
Park, especially for emergency first-responders,” said Adirondack
Council Executive Director Brian L. Houseal. “But over the
past several years of working under the Agency’s policy
on tower construction, it has become abundantly clear that most
new, stand-alone communications towers are unneeded.
“Nearly every applicant
for stand-alone towers in recent years has claimed that there
were no alternatives,” Houseal said. “Only during the
permit review process did it become clear that alternatives abounded.
Applicants often simply ignored viable, less visible, options
to avoid the expense of investigating them. This practice has
been expensive for the Agency and for local opponents of proposed
towers -- people whose desire to protect their neighborhood’s
natural beauty and fragile habitats is very much in tune with
the Agency’s duty to protect the entire Park’s scenic
qualities.
“In short, the burden of
proof should instead rest with those who stand to gain financially
from the tower construction – the applicants – and
not with the public,” Houseal explained.
In his letter to Chairman Whaley,
Houseal noted: “With the Adirondack Park faced with the
potential proliferation of many cellular communications towers
we submit the following guidelines for consideration by the Adirondack
Park Agency for the design and construction of new wireless communication
infrastructure in the Park:
1. When planning for new wireless communication coverage
in the Adirondack Park, commercial or emergency, focus should
be directed toward principal road corridors including: Interstate
Highway 87 and NYS Routes 3, 28, 30, 8, and 9. In addition to
road corridors, hamlet areas and centers of development should
also be primary candidates for new coverage. These areas are
most in need of coverage as they are population centers or routes
traveled by the majority of the population. They also provide
excellent opportunities for communications development because
they have existing infrastructure on which new antennae and arrays
could be sited with less potential for undue, adverse impacts.
2. Designs for new infrastructure should exhaust every
possibility to collocate new infrastructure on existing towers
or other structures before suggesting the construction of new
towers. There have been many successful examples of collocation
of wireless infrastructure both in the Park and throughout the
nation. Communications providers are currently collocating wireless
antennae on churches, water towers, buildings, existing utility
structures, and existing towers. Some of these have simply entailed
attaching an antenna to the structure, while others have concealed
the technology as part of the building; such as a chimney. With
so many existing structures within the Park’s hamlets, towns,
villages, and also along roadways, it is feasible that wireless
coverage could be drastically increased without adding any new
towers that would obscure scenic vistas and diminish the Park’s
wild character.
3. With regard to private land not in hamlet areas,
including resource management lands, the Council urges the Adirondack
Park Agency to mandate that applicants demonstrate that they
have exhausted all opportunities for collocation before the Park
Agency deems any application for a new tower to be complete.
As stated above, there are many alternatives for antennae placement
rather than new tower construction. If collocation is not possible,
the applicants must comply with all provisions of the Adirondack
Park Agency towers policy. Additionally, these applications should
be reviewed to ensure the applicants have obtained all other
proper permits required outside of the APA’s review process,
including, but certainly not limited to, NYS DEC stormwater State
Pollutant Discharge Elimination System (SPDES) permits for pollution
created during and after construction.
4. While wireless coverage is important in population
centers and along road corridors, the Council does not believe
that wireless coverage in the Forest Preserve areas is necessary
or appropriate. The Forest Preserve is a place where many people
go to forget the cluttered landscapes found throughout the majority
of the United States. There are other alternatives for communications
in the backcountry for public health and safety, such as satellite
technology, and those alternatives should be considered before
ever constructing towers on the constitutionally protected Forest
Preserve.”
The Adirondack Council’s
mission is to ensure the ecological integrity and wild character
of the Adirondack Park. Founded in 1975, the Council is a privately
funded not-for-profit organization with 18,000 members. The Council
carries out its missions through research, education, advocacy
and legal action.
Letter to Chairman
of APA - Ross Whaley
June 15, 2005
Dr. Ross Whaley, Chairman
Adirondack Park Agency
PO Box 99
Ray Brook, NY 12977
Re: Telecommunication Towers
within the Adirondack Park
Dear Chairman Whaley:
Today, more than two-thirds of
Americans carry a wireless telephone. The exponential growth
in communications technology has transformed society, and it
is common to see people talking on their wireless phones nearly
everywhere, even on the tops of peaks in the middle of Adirondack
wilderness areas. While ‘cell phones’ provide numerous
benefits, especially for public safety and emergency first-responders,
their rapid proliferation requires an expanding network of transmission
technology. As we well know, wireless telecommunications towers
have significant impacts within the Adirondack Park. Problems
often arise when new towers, commonly over one hundred feet high,
are built with little consideration of the environmental impacts
of the roads and power infrastructure needed to service them,
or the visual impacts on historic sites, scenic rural areas,
on mountain tops, or in wilderness settings.
The Adirondack Council understands
that emergency wireless telecommunications coverage is vital
for public health and safety and is currently inadequate in many
populated sectors of the Park. Reliable wireless communication
systems should be provided along principal existing road corridors
and in the villages and hamlets to improve public safety by reducing
the response time needed by police, fire and emergency medical
services, as well as permitting simultaneous communications among
these first-responders. The Council believes that reliable emergency
wireless coverage and other private wireless uses can be achieved
while ensuring the environmental and scenic resources of the
Park, which serve as assets not only to the ecosystem but to
the regional economy, remain intact and reasonably undisturbed.
With the Adirondack Park faced
with the potential proliferation of many communications towers
we submit the following guidelines for consideration by the Adirondack
Park Agency for the design and construction of new wireless communication
infrastructure in the Park:
When planning for new emergency
or commercial wireless communication coverage in the Adirondack
Park, focus should be directed toward principal road corridors
including: Interstate Highway 87 and NYS Routes 3, 28, 30, 8,
and 9. In addition to road corridors, hamlet areas and centers
of development should also be primary candidates for new coverage.
These areas are most in need of coverage as they are population
centers or routes traveled by the majority of the population.
They also provide excellent opportunities for communications
development because they have existing infrastructure on which
new antennae and arrays could be sited with less potential for
undue, adverse impacts.
Designs for new infrastructure should exhaust every possibility
to collocate new infrastructure on existing towers or other structures
before suggesting the construction of new towers. There have
been many successful examples of collocation of wireless infrastructure
both in the Park and throughout the nation. Communications providers
are currently collocating wireless antenna on churches, water
towers, buildings, existing utility structures and towers. Some
of these have simply entailed attaching an antenna to the structure,
while others have concealed the technology as part of the building;
such as a chimney. With so many existing structures within the
Park’s hamlets, towns, villages, and also along roadways,
it is feasible that wireless coverage could be drastically increased
without adding any new towers that would obscure scenic vistas
and diminish the Park’s wild character.
With regard to private land not in hamlet areas, including resource
management lands, the Council urges the Adirondack Park Agency
to mandate that applicants demonstrate that they have exhausted
all opportunities for collocation before the Adirondack Park
Agency deems any applications for a new tower to be complete.
As stated above, there are many alternatives for antenna placement
rather than new tower construction and hence any application
for a new communications tower should show, in detail, that all
other alternatives were considered before the Agency even considers
an application complete. If collocation is not possible, the
applicants must comply with all provisions of the Adirondack
Park Agency towers policy. Additionally, these applications should
be reviewed to ensure the applicants have obtained all other
proper permits required outside of the APA’s review process.
While wireless coverage is important in population centers and
along road corridors, the Council does not believe that wireless
coverage in the Forest Preserve areas is necessary or appropriate.
The Forest Preserve is a place where many people go to forget
the cluttered landscapes found throughout the majority of the
United States. There are other alternatives for communications
in the backcountry for public health and safety, such as satellite
technology, and those alternatives should be considered before
ever constructing towers on the constitutionally protected Forest
Preserve.
The Adirondack Council believes that the Adirondack Park Agency
took the right step to develop the Tower’s Policy to protect
the Park’s resources; however the Agency should strengthen
the policy by requiring applicants to exhaust all other possible
alternatives for collocation before even considering the construction
of new communications towers.
We thank you for this opportunity
to comment on this important matter and we appreciate the Agency’s
consideration of these guidelines.
Sincerely, Brian L. Houseal
Executive Director
Cc:
Agency Commissioners
Dan Fitts
John Banta
Jim Connolly
Charles Fox
Matt Millea
James Walsh
Senator Elizabeth Little
Assemblyman Chris Ortloff
Assemblywoman Teresa Sayward
J.R. Risley
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