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ANC3F, on July 19, 1999, unanimously adopted the following resolution objecting to Senator Daschle's amendment to the District of Columbia Appropriations Act. The operative language (a) urges the Congress to delete the amendment and preserve the NCPC's jurisdiction to weigh and balance conflicting positions objectively, in harmony with both land-use and telecommunications laws, (b) urges the NCPC to expedite the independent study that will lead to resolution of this contentious dispute and (c) urges our Congresswoman and other Officials of the District of Columbia to continue to work for a sound and thoughtful resolution while vigorously resisting the Senate amendment.
ANC3F also approved the following letters to the National
Park Service and counsel for
Bell Atlantic Mobile seeking better analysis of
the asserted safety factors and technical backup.
ANC 3F RESOLUTION
WHEREAS, the United States Senate, by voice vote, added a rider regarding telecommunications antennae (Amendment No. 1223) to the District of Columbia Appropriations Bill (S. 1283) on motion of the Minority Leader, Senator Thomas A. Daschle, and this rider, if enacted, would (among other things) permanently alter the jurisdiction of the National Capital Planning Commission (NCPC) as respects any future proposal to locate wireless telecommunications facilities (towers, antennae and infrastructure on the ground) on Federal property anywhere in the District of Columbia as well as respecting two pending facilities; and
WHEREAS, Congress created the NCPC in 1924 to perform a vital function of providing a professional planning perspective in order to preserve the unique beauty of our Nation's Capital while encouraging orderly development and Congress should not undermine this important mission by removing monopoles or any other planning decision from NCPC jurisdiction; and
WHEREAS, a 1999 application by the National Park Service (NPS) to allow installation of two monopoles in Rock Creek Park by Bell Atlantic Mobile and their operation for five years is now pending before the NCPC, which has heard testimony favoring and opposing the monopoles or demanding regulatory conditions (such as mandating shared use of antennae so as to discourage proliferation of monopoles); and
WHEREAS, upon receipt of the NPS application the NCPC promptly scheduled a public hearing on April 8, 1999, at which NPS and Bell Atlantic chose not to testify, whereupon the NCPC declined to approve the application and requested further information from the applicant; and
WHEREAS, the NCPC again held a public hearing on July 1, 1999, and again declined to approve the application as submitted, tabling the application for further information and study and directing the NCPC staff to retain independent expertise to assess disputed issues (particularly the ability of technological alternatives to cover Rock Creek Park without either monopole, or with a minimum of monopoles) so that, with the benefit of such independent analysis, the NCPC may evaluate and judge the applications pursuant to the NCPC's statutory responsibility; and
WHEREAS, the Senate adopted Amendment No. 1223, which concerns the NPS and the NCPC, as a rider to the unrelated District of Columbia Appropriations Act on July 1, 1999;
NOW, THEREFORE, this Advisory Neighborhood Commission 3F
(a) urges Congress to delete the rider and preserve the NCPC's
jurisdiction to weigh and balance conflicting positions objectively, in
harmony with both land-use and telecommunications laws,
(b) urges the NCPC to expedite the independent study that will
lead to resolution of this contentious dispute and
(c) urges our Congresswoman and other Officials of the District
of Columbia to continue to work for a sound and thoughtful resolution while
vigorously resisting the Senate rider.
The foregoing was adopted by a vote of 5-0-0 on July 19, 1999,
a quorum being present..
David J. Bardin, ANC 3F04, Vice chair
* * * * * * * * * *
ANC 3F NORTH CLEVELAND PARK / FOREST HILLS
20 July 1999
Terry R. Carlstrom, Regional Director
National Capital Region, National Park Service
1100 Ohio Drive, S.W.
Washington, D.C. 20242
Re: Your letters of June 22 and June 1, 1999, to Executive Director, National Capital Planning Commission as to the Notice of Decision on Environmental Assessment for Bell Atlantic Mobile (BAM) Applications for Wireless Telecommunications Facilities Maintenance Yard and Tennis Center Rock Creek Park — Washington, D.C. [approved 4/7/99 by the Regional Director, National Capital Region, National Park Service] and accompanying Finding of No Significant Impact (FONSI) and Environmental Assessment (EA)
Dear Mr. Carlstrom:
ANC 3F requests breakdowns of general statistical information presented as "Public Safety Factors" in your referenced letters. The information requested has not been available to ANC 3F or the NCPC, to the best of our knowledge, in the past.
Specifically, the statistical information compiled by the U.S. Park Police concerns all incidents that occurred in Rock Creek Park as a whole. This letter requests a geographic analysis (because BAM's applications are designed to affect only limited portions of the park) and analysis in terms of communications delays due to limited coverage of an area by BAM.
For the 40 months, January 1, 1995 through April 30, 1999, you report
348 "violent crimes,"
1,601 "criminal offenses," 1,664 "traffic incidents and motor vehicle
accidents" and 5,397 "other service incidents." Please divide each
of these categories
1) into four geographic areas: (a) north of Military Road; (b) downstream from the Taft Bridge; (c) Military Road to Tilden Street; and (d) Tilden Street to Taft Bridge; and
2) into those where limited coverage of an area by BAM delayed Park Police communications and those where no such delaying factors were reported.
Please also furnish the following information:
3) Dates and locations for all incidents which occurred during 1999 on or between Military Road and Tilden Street which you classify as "traffic incidents and motor vehicle accidents."
4) Dates, locations and nature of the crime for all incidents which occurred during 1999 on or between Military Road and Tilden Street which you classify as "violent crimes."
5) Dates, locations and nature of the crime for all incidents which occurred during 1999 on or between Military Road and Tilden Street which you classify as "criminal offenses."
Thank you for your assistance in providing this information in time for evaluation before the NCPC reschedules the referenced matters. ANC 3F approved this letter by a vote of 4-0-0.
Faithfully,
/s/ David J. Bardin
David J. Bardin, ANC 3F04
4701 Connecticut Avenue, NW
Washington, DC 20008
Phone: (202)966-7678; Fax: (202)966-2585
c: Honorable Harvey B. Gantt, FAIA, Chair, NCPC
Honorable Bruce Babbitt, Secretary of the Interior
Honorable Anthony A. Williams, Mayor, District of Columbia
Honorable Fred Thompson, Chair, Committee on Governmental Affairs,
U.S. Senate
Honorable Dan Burton, Chair, Committee on Government Reform
and Oversight, U.S. House of Representatives
Honorable Thomas A. Daschle, Minority Leader, U.S. Senate
Honorable Eleanor Holmes Norton, sole District of Columbia Representative
in Congress
* * * * * * *
ANC 3F NORTH CLEVELAND PARK / FOREST HILLS
20 July 1999
Whayne S. Quin, Esquire
Wilkes, Artis, Hedrick & Lane
1666 K Street, N.W. — Suite 1100
Washington, D.C. 20006-2897
Re: Notice of Decision on Environmental Assessment for Bell Atlantic Mobile Applications for Wireless Telecommunications Facilities Maintenance Yard and Tennis Center Rock Creek Park — Washington, D.C. [approved on 4/7/99 by the Regional Director, National Capital Region, National Park Service] and accompanying Finding of No Significant Impact (FONSI) and Environmental Assessment (EA)
Dear Mr. Quin:
ANC 3F makes two requests of your client, Bell Atlantic Mobile (BAM), for information which has not been available to ANC 3F or the NCPC, to the best of our knowledge, in the past:
1. Please provide copies of the reports summarizing surveys and tests of "acceptable" and "unacceptable" BAM coverage of various portions of Rock Creek Park.
2. How many reports has BAM received in 1999 and in 1998 of its customers' inability to notify 911 of an accident or a crime in the District of Columbia due to "unacceptable" BAM coverage of the area in question? Where did each of these incidents take place?
The EA states (at page 5) that BAM "has identified through transmission tests" that the Rock Creek Valley is an area lacking "acceptable" wireless telecommunications coverage by BAM. The EA there refers to a "detailed survey" by BAM of "the area" determining that "specifically most of the Rock Creek Valley south of Military Road to Tilden Street lacks acceptable cover age." The EA also states that BAM also "conducted transmission tests to verify existing and proposed cellular phone coverage" late in 1998. Then (following page 6) the EA reproduces in black-and-white "Bell Atlantic Mobile Wireless Telecommunications Coverage Maps of the Rock Creek Valley" (Maps). These Maps seem to indicate that BAM is now providing "unacceptable" coverage for its customers in much of Rock Creek Park and that installation and operation of the proposed monopoles will increase the areas of "acceptable" coverage in some parts of the Park, however it is not clear whether BAM has prepared composite maps or not. According to the Maps:
BAM now provides "unacceptable" coverage in most of the Park area between Military Road and Tilden Street but would provide "acceptable" coverage in most of that area (especially in winter) if it could install and operate the two monopoles; and
BAM now provides "acceptable" coverage in most of the Park area around the Zoo, between Tilden Street and the Taft Bridge; and
With or without the proposed new monopoles, BAM will provide "unacceptable" coverage in most of the Park north of Military Road and south of the Taft Bridge;
We lack information as to which engineers conducted and interpreted BAM's tests and surveys, what were their assignments (i.e., exactly what questions they tried to answer), what measuring equipment they used, whether their techniques where standard in the industry or innovative and what were the actual results for any of the various areas. Moreover, the Maps do not explain what the engineers meant to signify by the large and small dots (for "Roadways" and "Off Roadways" coverage, respectively).
The information requested should be available in time for independent professional evaluation by NCPC consultants before the NCPC reschedules the referenced matters. ANC 3F approved this letter by a vote of 4-0-0.
Faithfully,
/s/ David J. Bardin
David J. Bardin, ANC 3F04
4701 Connecticut Avenue, NW
Washington, DC 20008
Phone: (202)966-7678; Fax: (202)966-2585
c: Honorable Harvey B. Gantt, FAIA, Chair, NCPC
Honorable Bruce Babbitt, Secretary of the Interior
Terry R. Carlstrom, Regional Director, National Capital Region,
NPS
Honorable Anthony A. Williams, Mayor, District of Columbia
Honorable Fred Thompson, Chair, Committee on Governmental Affairs,
U.S. Senate
Honorable Dan Burton, Chair, Committee on Government Reform
and Oversight, U.S. House of Representatives
Honorable Thomas A. Daschle, Minority Leader, U.S. Senate
Honorable Eleanor Holmes Norton, sole District of Columbia Representative
in Congress
Attachment [excerpts from page 5 of EA]
Wireless Telecommunications and Coverage
Bell Atlantic Mobile has identified through transmission tests that the Rock Creek valley is an area lacking acceptable wireless telecommunications coverage. A detailed survey of the area was made by Bell Atlantic Mobile, and they determined that specifically most of the Rock Creek valley south of Military Road to Tilden Street lacks acceptable coverage. As a major provider in the telecommunications industry, the reliability standards which Bell Atlantic Mobile strives to meet for cellular coverage typically enable 98% or more of all attempted calls to be made without interruption. In major portions of Rock Creek Park, including the portions that would be serviced by these two proposed wireless telecommunications facilities, the current average reliability is such that about 33% of all calls do not go through. In addition, if the call does go through, there is currently a 15% chance that it will be dropped. Thus there is nearly a 50% chance that a cellular customer will experience a failure prior to completion of the call. Currently, within the above-described area, there are substantial portions of the park where virtually no calls go through. . . . .
Bell Atlantic Mobile conducted transmission tests to verify existing and proposed cellular phone coverage in October and December of 1998. The transmission tests were conducted in the following manner. At designated heights, transmitters that emitted a test signal were attached to a light pole at the tennis center and to a crane at the maintenance yard. Test [sic] for each of the sites were conducted separately. A specially equipped van drove throughout the park compiling data on what areas it could receive the signal and what areas it could not. . . . . These transmission tests were performed with the forest both in leaf and out of leaf because vegetation affects the signal strength. After comparing the levels of enhanced coverage at each height, Bell Atlantic Mobile selected a preferred height for each potential location and determined that antennas at those heights would provide acceptable coverage to the valley south of Military Road as depicted in the following maps.
. . . .