Bell Mobility Response to Cottagers' Association Letter

Dear Rena Edwards,

Thank you once again for your comments below and attached – it will be considered during review of all correspondence during this consultation process. It has been brought to our attention, since we have commenced consultation, that many of the cottagers had an issue with the lighting proposed for the tower. After further correspondence with Transport Canada and a request to waive the lighting requirements, we have been successful. Therefore, lighting will no longer be required on the proposed tower.

The tower is being proposed on the Marina site which is a land use that is very much compatible with such tower facilities and will not detract much more from the lakes natural setting. The footprint of a self-support tower is very minimal compared to other structure types; the only disturbance to the environment will be during the construction phase (lasting 6-8 weeks) when contractors are out on-site to construct the tower and compound areas. Thereafter, there will be routine maintenance visits. In terms of the construction of the tower and the potential impacts thereof, Bell Mobility attests to complying with the Canadian Environmental Assessment Act (CEAA). The CEAA focuses on potential adverse effects to the environment; Bell takes environmental protection seriously and is committed to minimizing the impact that some of their activities may have on the environment. A Phase 1 Environmental Site Assessment is conducted for every site to determine specific characteristics of the land and provide recommendations where appropriate. It is more likely that the general traffic experienced at the Marina over the summer season would affect wildlife and the surrounding environment more than this tower proposal.

The tower was original proposed to be at 90m and then lowered to the minimum height (76m) required to provide the necessary wireless service. Unfortunately, there are very limited options at such heights to provide an aesthetically pleasing structure; a self-support tower would be standard. This is an inherent aspect of providing such valuable services to communities and will always seem to be an issue.

As you may know, radio-frequency (RF) engineers at Bell determine the location and height that is required for the proposed antenna system to service the target community. It is important to note that this tower is part of a program as directed by the CRTC to service about 112 communities with, specifically, high-speed wireless internet in addition to wireless voice technology. It is through this program that designated service areas were determined and a goal of providing high-quality voice and internet to these communities was established. The funds are coming from accounts which are due back to Bell’s own customers and not the nation’s taxpayers as a whole. With these parameters, RF engineers require specific locations within a confined search ring to propose a tower. These search rings are usually a kilometre in radius and the tower is required to be located within the ring to provide the necessary service to the target community. Locating a tower outside of the search ring may have quite a significant impact on the quality of the service being provided. The Rogers tower, being 4km away will not be able to meet the ideal objectives to provide high quality voice and high speed wireless internet to the designated service area (being Harris Lake and proximity as well as some areas of the Magnetawan River). It is planned to use the Rogers tower to provide better coverage around the highway corridor but not necessarily the lake/designated service area, being Harris Lake cottagers and residents. Every telecom proponent has their own objectives and network requirements; the area Rogers may target would not necessarily be the same area Bell Mobility needs to service. The tower is required to be close to the community it serves, especially since high speed wireless internet does not have the same range as the wireless voice service.

In remote locations such as these, real estate needs to be available to meet the deadlines of the 4 year program (these towers are required to be in operation in 2014 to meet the CRTC program deadlines). Unfortunately most of the lands in this area is Crown; the acquisition, consultation, permitting, approvals, and construction process for such developments can be very lengthy as it is and 2014 is a very tight timeline. Typically when private land is available in an area, crown land will not be pursued as these are areas of common use by all and usually do not have the necessary services to operate such systems (hydro, road access, etc.). Also, the possibility of future expansion is quite limited compared to private land. As the field of Telecommunications is evolving very quickly, Bell constantly adjusts the network to meet the client demand and as a result, has to make sure when a site is acquired there can be flexibility to change/add equipment or adjust the size of the compound to suit the actual and future needs of the network. There are cases where we have pursued crown land and have been required to justify why private land was not used; this is related to the complex and timely process which must be followed for any type of development on unpatented lands.

As per the meeting on August 4th with the cottagers, Bell will be reviewing alternate locations and a final decision will be made once all consultation periods come to an end.

This reply marks the start of a 21-day final response period. Your response period will come to an end at close of business November 12th, 2013. We will try to respond to all your concerns within this period.

Best regards,

Haseeb Amirzada
CanACRE Ltd. on behalf of Bell Mobility

Email to Bell Mobility

Bell Mobility Inc. ℅ Haseeb Amirzada
P.O. Box 52429
524 Queen Street West,
Toronto, ON M5V 2B0
August 22,2013

Dear Haseeb,

I am writing to you as the secretary of the Harris Lake and South Magnetawan River Cottagers’ Association Inc.  Bell Mobility is planning on putting the above mentioned 76 meter tower approximately 50 meters from the Harris Lake shore on the property of the Harris Lake Marina. At our Annual General Meeting on August 4th, an overwhelming majority was strongly opposed to this location. The unsightly tower with both white and red flashing lights will be visible from most cottages and from almost anywhere on the lake. This area has been designated a” Government of Ontario Wilderness Canoe Route” and a tower in this location at the waters edge would detract very much from the natural wilderness aspect and beauty  of the lake. It would detract from the cottage experience at Harris Lake.

Other reasons to oppose the location:

• It has not been integrated into the environment.
• It would be in a campground just a few feet from campers and cottagers including children.
• No environmental assessment would be done although it borders on wetlands.

Rogers has a tower 4 kilometres from  Harris Lake just off the Harris Lake Road. This location is great. It is unobtrusive and close to invisible from the lake and cottages. Why can Bell not use the Rogers Tower or at least a similar location even if the tower has to be larger? Size  would not be an issue at this location .

John Woods of Bell Mobility was present at the General Meeting and he admitted that other locations further from the lake were a viable alternative. He promised to consider these alternatives and report back to us.

The association strongly urges you not to proceed with this location.

Thank you.

Sincerely,

Rena E. Edwards, Secretary
Harris Lake and South Magnetawan River Cottagers’ Association Inc
57 Acredale Drive,
Carlisle, ON L0R 1H

Questions Forwarded to CanACRE Regarding the Tower

Questions forwarded to CanACRE regarding the Tower

What is the effective range of the Proposed Tower at its current Height and Location?

1. Currently the furthest active cottage in the area from the proposed tower location is approximately 9.5 km with an average distance of 3.1 km to the 217 parcels on the lake and river system.
2.  Alternative Location 1 (45.69164, -80.384822): Locating the tower further back on the road near the ‘Public Landing and Docking’ area, puts the furthest active cottage at 10.5 km away with an average distance of 3.46 km to the 217 parcels on the lake and river system. The tower also gains approximately 20ft in elevation at this location over the marina location. The visual effects of having the tower are significantly mitigated, even if the tower requires some more height or lights.
3.  Alternative Location 2 (45.69442, -80.41338): Locating the tower further back near the logging or garbage dump road, puts the furthest active cottage at 11.5 km away, with an average distance of 5km to the 217 parcels on the lake and river system. The tower also gains approximately 10ft in elevation at this location over the marina location. The visual effects of the tower are nearly 99% mitigated, even if the tower requires more height or lights.

Radiocommunication antenna systems do not have a radial coverage area simply because it is a line-of-sight technology. If one can see the tower then you can expect good service. This line of sight is affected by many things including hills, trees, walls, etc. Because of the nature of this technology you might get coverage up to 10km in some areas and only 3-4km away in other areas. Due to the terrain and trees, and the fact that the tower height has been reduced (originally meant to be a 90m tower), there can be no exact figure and the above numbers give a general coverage potential.
Radio-frequency (RF) engineers at Bell determine the location and height that is required for the proposed antenna system to service the target community. It is important to note that this tower is part of a program as directed by the CRTC to service about 112 communities with high-speed wireless internet in addition to wireless voice technology. It is through this program that designated service areas were determined and a goal of providing high-quality voice and internet to these communities was established. With these parameters, RF engineers require specific locations within a confined search ring to propose a tower. In addition to that, especially in remote locations such as these, real estate needs to be available to meet the deadlines of the 4 year program (these towers are required to be in operation in 2014 to meet the CRTC program deadlines). Unfortunately most of the lands in this area is Crown; the acquisition, consultation, permitting, approvals, and construction process for such developments can be very lengthy as it is and 2014 is a very tight timeline. Typically when private land is available in an area, crown land will not be pursued as these are areas of common use by all and usually do not have the necessary services to operate such systems (hydro, road access, etc.). Also, the possibility of future expansion is quite limited compared to private land. As the field of Telecommunications is evolving very quickly, Bell constantly adjusts the network to meet the client demand and as a result, has to make sure when a site is acquired there can be flexibility to change/add equipment or adjust the size of the compound to suit the actual and future needs of the network. There are cases where we have pursued crown land and have been required to justify why private land was not used; this is related to the complex and timely process which must be followed for any type of development on unpatented lands.

Considered all of the above, distance to customers is not as relevant as having line-of-sight to them; if you can’t see the tower, you will not be receiving very good service. This is the nature of such technology and has to be considered when proposing the tower location (it is not only elevation that is important). Your alternate suggestions (being on Crown land), therefore, may not meet the coverage requirements as RF at Bell would like and will require going through this complex permitting process. These locations, however, will be kept on record to be considered at the end of consultation if an alternate site is brought into question. Please keep in mind that the goal of this tower is only to deliver the proposed wireless technology to the designated service area (Harris Lake) and not necessarily to cover the Highway.

Why was the cottagers association and relevant land owners within the specified vicinity notified after a lease agreement had been signed?

The tower siting process is as such: RF determines search ring for tower placement; a candidate is found and brought forward for approval by RF; Real Estate personnel at Bell, Construction Manager (to determine feasibility of construction on that property), and Transmission department (to ensure connectivity within the network and other services are available) are consulted and provide further approval. It is only after these internal approvals are obtained that consultation would commence. Therefore, an agreement must be in place with the landowner so that real estate is secured and then a proposal on those lands are put forward for public comment. Consultation would not start on a tower location unless it is determined that the lands are available for that tower to be placed (otherwise, time, effort, and capital, is spent for the consultation stage only to find that the landowner does not want the tower or real estate just isn’t feasible at the proposed location). A lease is signed for this reason; however, as you can see, the tower is a proposal and not the final location. Bell is able to remove itself from the lease at any point should it be deemed necessary.

Why does Bell not want to work in the best interest of its potential customers by locating a tower in a location that would not draw so much resistance?

As mentioned in the first point above: there is very limited private land in the area and with regards to the CRTC designated service area and timelines, the Marina lands was determined to be the most ideal location as approved by the many different departments at Bell. Cottage/Lake locations are always areas which receive opposition and support from the local residents. It has to be known that such towers need to be close to the people Bell is required to service and line-of-sight is very important. If you cannot see the tower, you will not be receiving the same quality service which does not meet Bell’s goals of providing high quality voice and high speed wireless internet.

Why was bell so slow to act to acquire rights to public lands at one of the two above-mentioned alternative locations (or others)? The impending deadline to locate the tower is not a Harris Lake & Magnetawan River problem.

Bell was required to service 112 communities according to the CRTC’s decision to be completed within 4 years. This location, among a few others, are the remaining towers which need to be constructed to service the communities which have marginal/non-existent access to such services. Subscriber feedback, network requirements, budgeting and internal resources determined the timeframe within which each site would be commenced and completed. This is why Harris Lake was started at this time and is set to be completed by next year.

What is Bell’s policy if a tower receives 0 use in the first year of use?

These towers do not follow the regular policies as it is the CRTC who directed Bell to provide the proposed services. It is to fulfill the intention of the four year program. The goal is to improve and provide the service where it is non-existent and where there is potential for use.

What is Bell’s & CRTC’s responsibility to the land owner if business is detrimentally effected by the locating of a tower on specified land?

The CRTC and Bell Mobility are not typically liable for claims of lost revenue or perceived loss of property value to any land owner. Any potential tower landlord is responsible for assessing his or her costs and benefits with regards to accepting a tower lease. Although Bell Mobility indemnifies and saves harmless the landlord against litigation and claims of liability that may arise as a result of Bell’s activities on the property; these provisions do not include lost revenue claims where the landlord operates a business on the property

As per the public notification since Bell strongly supports co-location on existing towers, we are assuming that there will be no reason for Bell to object to the cottagers petitioning to have Telus and Rogers co-locate equipment on the Bell tower to offer adequate competition?

Industry Canada requires telecommunication proponents to consider co-location requests and also to determine feasibility of co-locating on other towers before proposing new structures. Therefore, Bell is always open to receiving requests from other proponents should they determine the space available on the tower is appropriate to service their customers.

Can you outline the endangered species at the Marina site that were investigated by Bell and associated regulatory agencies? Species known to the area that fall under the species of risk act include: Hog Nose Snakes, Fox Snakes, Blanding’s Turtles, Spotted Turtles

Bell Mobility attests to complying with the Canadian Environmental Assessment Act (CEAA). The CEAA focuses on potential adverse effects to the environment; Bell takes environmental protection seriously and is committed to minimizing the impact that some of their activities may have on the environment. The footprint of a self-support tower is very minimal compared to other structure types; the only disturbance to the environment will be during the construction phase (lasting 6-8 weeks) when contractors are out on-site to construct the tower and compound areas. Thereafter, there will be routine maintenance visits. It is likely that the general traffic experienced at the Marina over the summer season would affect wildlife and the surrounding environment more that this tower proposal. There are a number of site visits and studies conducted before construction starts (Phase 1 Environmental Site Assessment, Geotechnical Studies, etc.) and should an endangered species be spotted during these visits, the appropriate measures will be taken (contacting relevant authorities, retaining appropriate consultants, minimizing further disturbance, etc.)

Q/A Regarding Proposed Bell Communications Tower

How tall will the tower be?

The tower is planned to be 78 meters in height, approximately 250 feet.

What is the reason for the tower?

CRTC had mandated that Bell Canada had to provide service to Northern Ontario residents as a payback to Ontario citizens because of their long standing monopoly on communications and the amount of money collected by Bell over the years. Bell chose the areas to be served by high speed data, and the CRTC set the requirements.

Reason for the location?

The tower is to be placed as close to the water as possible to offer maximum coverage of services to the lake and river.  Secondly, the marina is a central location from which the majority of people access the lake and has serviceable access and power necessary to support a communications tower.  Bell has already signed a 10 year lease with the marina.

Is it possible to have the tower camouflaged as a tree as they do in other areas of the Muskoka’s?

Due to the towers height this is not possible.  Towers camouflaged as trees have a maximum height of 100 feet.

How will the tower be lit as to minimize glare to residents of the lake?

Lighting is dictated by Transport Canada, but the lights will be LED style lights, and the tower will use mirrored shields to deflect light upwards at a 60 degree angle.

Can the site of the existing Rogers tower near the highway be used?

Bell has made requests to co-locate a tower at this location but has never received a response.  Secondly, the tower type and location is not ideal for maximizing signal strength the the lake and river.

How are communication towers electricity requirements backed up, many old towers used diesel generators?

Today’s towers use portal battery back up generator which requires not fuel to be stored on site.

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The following are names and addresses of people and organizations you may with to contact to voice your concerns or opinions. Please note that you are calling in reference to the Proposed Bell Communications Tower and make sure to not the site code (W3446 Harris Lake) in your communications. 

• Industry Canada 
• Dan Duggan, District Manager for Parry Sound District Office of the Ontario Ministry of Natural Resources
• Jane Naworth, Secretary-Treasurer for the Archipelago Area Planning Board
• Bell Mobility, c/o Haseeb Amirzada
• Harris Lake Marina

Full Contact Information