HomeMy WebLinkAboutSupplemental Communication from Melanie Gotto1
Gloria Harper
From:Melanie D Gotto <melaniegotto@gmail.com>
Sent:Friday, April 03, 2020 5:42 PM
To:Gloria Harper
Subject:External Email : Stop Deployment of Wireless during Quarantine
Dear Ms. Harper,
Dear Mayor & City Council Member,
We ask that you impose a moratorium on “small cells” and other wireless infrastructure permits process and
deployment until the COVID-19 emergency is over.
The wireless providers are using the COVID-19 emergency as cover to expand and cement their rapid and
virtually unsupervised deployment of harmful wireless infrastructure. Our local leaders should not have to
dedicate time and resources to policing whether the wireless companies are following local and state law, they
have far more important things to do.
The FCC wireless permit rules allow emergency moratoria. Homeland Security guidelines emphasize that
maintenance of existing communications capability is the priority. New construction is not “essential.”
The COVID-19 emergency has led to a government shut down of non-essential activity. Hospitals, emergency
response and local officials are overwhelmed and they must be allowed to focus on what is indeed “essential”.
Now is not the time to be dedicating resources to expanding, rather than just maintaining, our networks.
The FCC has directly held a local jurisdiction can impose a temporary halt to deployment and permits during
emergencies. In the Matter of Accelerating Wireline Broadband Deployment by Removing Barriers, FCC 18-
111, 33 FCC Rcd 7705, 7784-7785, ¶157 (2018) (“We recognize that there may be limited situations in the case
of a natural disaster or other comparable emergency where an express or de facto moratoria that violates section
253(a) may nonetheless be ‘necessary’ to ‘protect the public safety and welfare’ or to ‘ensure the continued
quality of telecommunications services.’”)
Homeland Security has declared that local government is on the forefront and can take control over determining
whether to temporarily halt all non-essential activity. Homeland Security guidance documents prioritize
maintenance of existing Communications Systems, and do not support “essential” status for new construction.
See Homeland Security Cybersecurity & Infrastructure Security Agency, Identifying Critical Infrastructure
During COVID-19, https://www.cisa.gov/identifying-critical-infrastructure-during-covid-19 (local control); e-
Critical Infrastructure and Key Resources Support Annex, http://www.fema.gov/pdf/emergency/nrf/nrf-support-
cikr.pdf (focus on “protection, response, recovery, and restoration”). Homeland Security, like the FCC,
understands that it is essential in an emergency situations justify focusing on protecting, responding, recovering
and restoring of existing systems, but new communications facilities construction is and should be deemed
nonessential, and subject to lockdown for so long as we are under emergency conditions.
Cities can and should impose a moratorium on deployment in their local area and freeze the permit process until
the COVID-19 emergency is over.
Sincerely,
Melanie D Gotto
2
4280 Guava Ave
Seal Beach, CA 90740
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