Letter sent to Telus from Frank Mitchell -------------------------------------------------------------------------------- Dear Mr. Hird As a Metchosin resident, and current Telus subscriber (with two telephone lines), I am distressed at Telus's actions on the proposed Rocky Point Road antenna tower. I would urge Telus to re-examine this proposal, and to engage in a sincere and thorough public consultation process. I understand that Industry Canada requires tower proponents to engage in a 120 day public consultation process, and that the public should be informed, or given a chance to make representations about many criteria, including, most relevant in the present instance, * "Why is the use of an existing antenna system or structure not possible? * Why is an alternate site not possible? * What is the proponent doing to ensure that the antenna system is not accessible to the general public? * How is the proponent trying to integrate the antenna into the local surroundings?" Telus has not, in my view, complied with the consultation requirements or substantive tower issues in a satisfactory fashion. 1. Inadequate consultation period. Telus mailed immediate neighbours a notice which they received around September 5, and which required them to respond by September 30. I understand that the Local Land Use Authority (District of Metchosin in this instance) was not officially informed, but only copied the letter sent to residents. Does this mean the official consultation period has not commenced? If the rumour is true that Telus has signed a contract with the owner of the proposed site (as contrasted with having a tentative agreement pending consultations and evaluation of other sites and official approvals) this would indicate Telus is not engaged in good faith consultations. What is the situation? 2. Inadequate scope of consultation: The Industry Canada requirement (contact those within 3 tower heights of the tower) is grossly deficient if real public consultation is the aim. If it expects to retain public respect, Telus should consult with a wider population, given the sensitivity of relevant issues to residents much further from any tower than the Industry Canada requirement. Those issues include: (a) health: electronic emissions will affect many more homes, and in ways more complicated, than the IC standard. While health concerns are dealt with by the (totally unsatisfactory) Industry Canada standards and largely outside the scope of Telus's required consultation, health implications of emissions for residents are worrying most informed folks within 500 M of the site. Health considerations would imply more attention to alternative sites. Telus does its image no good by hiding behind minimal C regulations as a reason to ignore this matter in listening to the public and evaluating options; (b) aesthetic impacts affect a much larger population including users of this very busy road. Appropriate consultation would involve contacting the Metchosin public more generally through, for example, some notice in the press, or a mailout to all households. (The latter would cost less than $400 in Metchosin.) 3. Is another tower in Metchosin needed? The case for an additional tower, if there is one, has not been shared with the public. The existing tower at Neild Road serves most of Metchosin. The population density there is much lower (10 acre minimum lot sizes, some lots larger) than the Rocky Point site. Has Telus engaged in sincere negotiations with the owners of the Neild Road tower to locate the new transmitter there? We understand the present project has a capital cost of $500,000, plus continuing costs of maintenance and rent. Such numbers suggest plentiful scope for win-win joint siting on pure profit grounds alone. Have these opportunities been explored? 4. Why is this site better than others? Even if locating on the Neild Road tower proved impossible (for reasons which should be explained to the public), there are undoubtedly other sites which would provide the same or better service coverage of Metchosin, but with fewer immediate neighbours and fewer aesthetic concerns. At a minimum, Telus should provide evidence of having surveyed such sites, and provide information on their coverage and local population densities, to ensure an informed public. An informed public, approached by a responsible enterprise honestly seeking public views, might even make mutually beneficial suggestions. 5. Failure to consider long term economies (and profitability). Entry by new cell-phone operators can be expected in the near future. They will require transmitters, whether on existing or new towers. It is incumbent on any wise investor, including Telus, to take this into account in their benefit-cost calculations. The "business case" for a possibly slightly less accessible site (from the Telus point of view), but possibly with better coverage, and certainly with fewer health or aesthetic risks, which might be attractive for securing rentals from new entrants, should be examined and results shared with the public. It is in no-one's interest to cover cover the landscape with unnecessary and costly towers. 6. Accessibility risks not taken into account. Rocky Point is one of our busiest roads. It is automatically more accessible to the general public than a more remote and more sparsely inhabited site. (Accessibility is one of IC's criteria.) Not least Telus needs to consider the non-negligible risk that the tower will be hit by a speeding vehicle. (The police have so far been unable to control traffic speed on this road.) 7. Non-integration into local surroundings. The sole "concession" by Telus on this criterion is colour choice. This totally fails to take account of the widely-valued (not just by local residents) character of Metchosin as a rural community in a rapidlly urbanising region. Metchosin's viewscapes and rural facilities are increasingly enjoyed by residents of the rest of the region, who want to enjoy (and acquaint their children with) a more traditional landscape. This consideration is not esoteric. The homogenisation of landscape with such items as cell phone towers involves significant intangible costs, to a widely dispersed population. Other tower locations in Metchosin would not occasion such high costs to all regional residents. The relevant issue is not just what is best for Telus, but what is best for Telus, their subscribers, and the wider public. Everyone including Telus) knows that the Industry Canada health criteria are questionable -- and increasingly questioned. The public also values many things which may not be so easily quantified as short-term corporate profit and loss, but are nevertheless real. An approach which seeks only to meet minimal IC criteria does not connote corporate good will. An environment of increasing competition suggests that even "intangibles" have long-run implications for corporate bottom lines. Finally, I must tell you that the Telus proposal is leading me, for the first time, to investigate in some detail the benefits and costs of purchasing telephone service from another firm (one which already has coaxial cable to my home (versus the copper wire from Telus) and is soon to enter wireless as well). Narrow financial conditions imply the desirability of switching today. Non-financial considerations (including diversification of risks) have so far implied retaining Telus. If Telus persists in its inadequate and ostensibly arrogant approach to tower siting and community consultation, the balance will tip. I look forward to hearing that Telus is making a fresh start on this matter. In the meantime, I am copying this to others concerned with this issue for their information, and possible action. Yours truly Frank Mitchell 530 Witty Beach Road Metchosin (Victoria) BC V9C4H8 tel. 250-478-1671 fax. 250-478-1371