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HomeMy WebLinkAboutEx 19 Comments April 1 to 30thDean Morgan 55 Seafarer Ln Port Ludlow, WA 98365 deandel@h.P!ma_il._co_m April 1, 2026 Jefferson County Department of Community Development Re: Horizon, Verizon, Mats Mats, Port Ludlow cell tower ZON 2024-11 Development Review Division 621 Sheridan Street Port Townsend, WA 98368 Email: planning@co.jefferson.wa.us Dear Jefferson County Department of Community Development, APR -E 2026 Jefferson County Community Development I am writing as a concerned resident regarding the proposed Wireless Communication Facility (WCF} at Parcel 821081015 off of Upper Fleet, Port Ludlow, WA, submitted by The North Group, Inc. on behalf of Horizon Tower and Verizon Wireless. It is my understanding that the applicant is obligated to provide full and truthful responses to all questions submitted by residents. I expect that my questions and concerns, along with those of other members of the community, will be addressed completely and transparently as part of the review process. My specific questions and concerns regarding this project include: Was Whidbey Island considered for the antenna placement? In summary, I am also interested in learning about what other locations were considered to put up a cell tower away from homes, impacts to roads, utilities, runoff into the Bay, health issues, environmental and historical implications, negative effects to the aesthetics mission of the County and Port Ludlow, and property value considerations. I strongly urge Jefferson County to conduct a thorough, transparent, and accountable review of this proposal. Thank you for your attention to this critical matter. I look forward to a detailed response to my specific questions that reflect the legitimate concerns of the community. EX 19- Public Comment 2026-04-01 April 2, 2026 Jefferson County Department of Community Development Development Review Division 621 Sheridan Street Port Townsend, WA 98368 Email: planning@co.jefferson.wa.us Re: ZON2025-00011-Jefferson County Public Notice of Type III Land Use Application Dear Department of Community Development, I am writing for your response to a pertinent historic and cultural preservation question related to SEPA and the NHPA. The question on the SEPA asks about any buildings, structures or sites, located on or near the site that are over 45 years old listed in or eligible for listing in national, state, or local preservation registers and the applicant was asked to “specifically describe.” The applicant listed, “none known.” The Swansonville Church is 102 years old, over twice the requirement of sites over 45 years old. In addition, the Forest Hill Cemetery is 280 feet from the proposed Cell Tower. There are currently 276 memorial records at the cemetery. The first settlers of Port Ludlow are buried in this sacred site. Not all sites have been identified. 1853 was the first settler. Question: When will the NHPA be reviewed and completed which is required by SEPA? What has been done to ensure that the applicant has complied with a review of historical sites, the cemetery National Register of Historic Place (NRHP#100006061), and any Native American burial sites in the immediate area? Another location for the cell tower facility could be found that does not impact nearby historical sites. Thank you for your response. Dianne Cooper 20 Keefe Lane, Port Ludlow, WA 98365 diannecooper@comcast.net EX 19- Public Comment 2026-04-02 (1) April 2, 2026 Jefferson County Department of Community Development Development Review Division 621 Sheridan Street Port Townsend, WA 9836 Email: planning@co.jefferson.wa.us Dear Jefferson County Department of Community Development, Re: ZON2025-00011 Jefferson County Public Notice of Type III Land Use Application I am writing as a Port Ludlow resident concerned about the proposed location of a Verizon Wireless cell tower within a neighborhood setting. I fully support the need for improved cell phone service in areas around Port Ludlow. However the proposed location is very problematic and I think could be resolved. The current proposed location is in a rural, quiet, beautiful residential area. Many of us relocated here because our homes are surrounded by natural beauty, trees, water, animals, and landscapes. In the Proposal submitted to Jefferson County it says that the monopole is engineered to support three future carriers in addition to Verizon Wireless. Indeed, this is a Wireless Communication Facility. I do not understand why a residential area has been selected when other locations appear to be available that would have far fewer impacts on surrounding homes? Clear cut areas, timberland, county and state land, utility areas and other non-residential areas should be available for the Facility. Please provide a full explanation of how the Applicant’s proposal meets local and county requirements for compatibility with surrounding land uses and protection of rural character. What specific alternative sites were evaluated, and what criteria were used to reject those locations in favor of this one? Please provide a transparent analysis of alternative sites that was conducted. Respectfully, Danne Cooper 20 Keefe Lane, Port Ludlow, WA 98365 diannecooper@comcast.net EX 19- Public Comment 2026-04-02 (2) April 3, 2026 Jefferson County Department of Community Development Re: Horizon, Verizon, Mats Mats, Port Ludlow cell tower ZON2025-00011 621 Sheridan Street Port Townsend, WA 98368 Dear Jefferson County Department of Community Development, I am a concerned resident of Port Ludlow writing about the proposed Wireless Communication Facility (WCF) aka Cell Tower at Parcel 821081015 off Upper Fleet Drive, Port Ludlow, WA, submitted by The North Group, Inc. on behalf of Horizon Tower and Verizon Wireless. It is my understanding that the applicant is obligated to provide full and truthful responses to all questions submitted by residents. I expect that my questions and concerns, along with those of other members of the community, will be addressed completely and transparently as part of the review process. My specific questions and concerns regarding this project include: Housing Values & the Cost to Homeowners: Questions: Will the applicant establish a study of the home and property values in Port Ludlow now and compare the loss of value if the cell tower is approved? Is the applicant planning on providing remuneration to home and property owners that lose value? What studies have been done to demonstrate that homes near the cell site won’t lose value? Reputable studies report that large towers could reduce buyer interest. Research shows that there is an estimated 2.9-20% decrease in property values ($17,400 to $120,000 on a $600,000 home.) Tree Line: The tree line on the proposed site does not match the 150-foot height of the tower. Questions: Why did the applicant say that this is a determination of non-significance, when the tower will be visually prominent over the top of the tree line? I would like to see a picture of the tower with the tree line. Please provide a 360-degree picture and diagram of the changes to the tree line. Health: Questions: What precautionary measures is Horizon proposing to implement beyond minimum federal compliance to address scientific uncertainty? What has been studied and is there a conclusion that meets with the County’s full knowledge of the effects of radio frequencies to humans and animals? What research has been considered regarding potential effects of radiofrequency exposure on vulnerable populations, including the elderly, children, pregnant women, and individuals with existing medical conditions, and how will Horizon address uncertainties identified in international literature? Aesthetics and Quality of Life: Questions: How has the impact of a 150-foot tower so visibly prominent been addressed? This is an urban eyesore in our forest community, “a village in the woods by the bay”, the beauty being an important attraction, and it could change the entire character of Port Ludlow. Will the site of the Tower not only negatively impact the residents, but also negatively impact and reduce visitors such as boaters, and guests at the Inn at Port Ludlow, the Beach Club, and restaurants nearby? Has there been a study of the effects of seeing a cell tower near a peaceful inlet? EX 19- Public Comment 2026-04-03 Alternative Locations: Questions: Have you spoken to other property owners and businesses that may allow a cell tower that is not in a residential neighborhood? Have you considered utility corridors, county owned shoulders of the roads in less populated areas, public works yards, or any commercial zone areas? Have you approached Pope Industries to put a tower on the clear cuts on top of their hills North of the proposed tower? I want to see this. Noise: Questions: What noise decibel study has been performed? At the property line? At the nearest residence? At night? What is the specific level of noise that is described as negligible by the applicant? There are homes less than 300 feet from the proposed tower, what is being done to shield the homes and families from the constant noise? Wildlife: The applicant’s response on the SEPA to this item is very inadequate. Questions: What is the impact on the many diverse birds and animals? Will the radio frequency drive this wildlife from their habitat? Migration Route: Port Ludlow lies within the Pacific Flyway, a major migratory corridor stretching from Alaska to Patagonia. Questions: Has the applicant addressed the tower will be in a Migratory Corridor? If approved what studies and mitigation plans will be taken to ensure that the tower does not impact the Flyway? Alternative Locations: What about speaking to owners and businesses that may allow a cell tower that is not in a residential neighborhood? Questions: Have you considered utility corridors, county owned shoulders of the roads in less populated areas, public works yards, or any commercial zone areas? Have you approached Pope Industries to put a tower on the clear cuts on top of their hills North of the proposed tower? We want to see this. Erosion: Erosion is dismissed as “not significant” by the Applicant. Port Ludlow has significant drainage problems in our North Bay neighborhood already. Questions: Where will the water go? What stormwater modeling was conducted? What engineering analysis supports the claim that runoff will simply infiltrate onsite? What hydrology reports were conducted? I strongly urge Jefferson County to conduct a thorough, transparent, and accountable review of this proposal. Thank you for your attention to this critical matter and for your consideration of this development which could irreversibly and negatively impact the unique character of Port Ludlow. I look forward to a detailed response to my specific questions that reflect the legitimate concerns of the community. Sincerely, Kelly Robertson 100 Explorer Lane Port Ludlow, WA 98365 Colibris3@outlook.com EX 19- Public Comment 2026-04-03 Noura S. Yunker _______________________________________________________________________________________________________________________________________________ 230 Pioneer Dr | Port Ludlow Washington 98365 | Tel: (541)400-8955 | soundlaw@nwlink.com April 4, 2026 Jefferson County Department of Community Development Development Review Division 621 Sheridan Street Port Townsend, WA 98368 Email: planning@co.jefferson.wa.us VIA EMAIL ONLY Re: Horizon Tower Mats Mats Bay Reference Number ZON 2024-11 AND/OR ZON2025-00011 Dear DCD Representative, I am a resident of the Port Ludlow Master Planned Community. I am gravely concerned about the proposed construction of telecommunications facility in the Port Ludlow neighborhood. This letter addresses my concerns, and demonstrates why the conditional use permit should be denied. Horizon Tower/Verizon Wireless’s Application and SEPA Environmental Checklist reveal the following significant problems: A. Supplemental Application - Conditional Use: The County Should Deny the Application for the Following Reasons. 1. The Application is Incomplete. The Conditional Use application makes clear at the outset that no conditional use permit can be granted unless it is consistent with the performance standards of JCC 18.20, the development standards of JCC 18.30, the procedural requirements of JCC 18.40.280, the approval criteria of JCC 18.40.530, and unless any other applicable requirements of the UDC have been satisfied. Many of the responses in the Supplemental Application create an impression that the project meets certain requirements, but do not, in fact, directly answer the questions posed therein. Therefore, in order to grant the permit it is necessary to confirm the requisite standards, requirements, and criteria have been met. This necessitates additional information from the Applicant. EX 19- Public Comment 2026-04-04 Page 2 of 10 Because the application is incomplete the County should deny the permit. 2. The Application is Misleading. When asked to explain how the conditional use is harmonious and appropriate in design, character and appearance with the existing or intended character and quality of development in the vicinity, the Applicant responds to only one of the three requested criteria: a. The Applicant describes only the physical appearance of the project, without addressing its design or character; b. The Applicant mischaracterizes the surrounding lands as “rural, with scattered residential and undeveloped parcels” when they are instead designated “Rural Residential 1:5.” General Rural can include commercial or industrial zones or resource-based activities, whereas Rural Residential primarily supports single- family dwellings, home businesses, and small-scale agriculture; and c. The surrounding Rural Residential vicinity is actually an existing Master Planned Community of more than 1800 housing units (Port Ludlow Master Planned Resort Community). This misinformation and evasiveness necessitates additional information from the Applicant regarding the harmony and appropriateness of the project’s design and character. It also requires corrected information from the Applicant regarding the designation of the surrounding vicinity as RR 1:5 rather than Rural. Because the application is misleading, and because the Applicant fails to provide requested information, the County should deny the permit. 3. The Application Indicates An Associated Level of Potential Harm. When asked to describe the location, size, and height of signage, the Applicant indicates “required RF safety…signage” will be posted. The FCC mandates warning signs to identify areas where RF emissions exceed the general population or occupational exposure limits. In Category 1 areas where RF energy is below the General Population limit, the use of warning signage is optional or educational. Therefore the Applicant’s intent to post required signage clearly indicates that there will be instances in which the RF emissions exceed the Category 2, 3, or 4 exposure limits. This should preclude granting the permit, because by definition, required RF signage indicates a level of RF emissions exceeding the general population or occupational exposure limits. That the excessive emissions should occur only within the enclosure surrounding the facility is not determinative, because the vicinity is inhabited by families with children and animals. And signage is ineffective in keeping children and animals from enclosures or other attractive nuisances. EX 19- Public Comment 2026-04-04 Page 3 of 10 Because the application indicates there will be instances in which the RF emissions exceed the Category 2, 3, or 4 exposure limits, because children and animals reside in the vicinity, and because the facility will be an “attractive nuisance,” the County should deny the permit. 4. The Application Fails to Describe the Noise Associated with the Facility. When asked to describe “any noise…generated by the conditional use,” the Applicant states only that there is no significant noise associated with the facility. This requires the Examiner to accept the Applicant’s implied characterization of any noise as insignificant, thereby usurping the Examiner’s role in determining in advance what noise, exactly, will be generated, or whether such noise should preclude the granting of a permit. Because the application fails to describe the associated noise, the County should deny the permit. 5. The Application Fails to Address Significant Adverse Impacts. When asked if there are any significant adverse impacts on the human and natural environments, the Applicant states only that it does not anticipate any significant adverse impacts, and that minor impacts are mitigated through compliance with County standards. This does not address the following significant adverse impacts. a. The conditional use will significantly adversely impact the human environment by siting a 150’ high utility tower within a RR 1:5 rural residential zoned district consisting of residential housing with otherwise undegraded views of marine waters and significant open spaces. The 6-foot fence and vegetative screening will not rehabilitate the altered views. b. It will further significantly adversely impact the human environment by placing an admittedly dangerous utility structure in the midst of an existing community of children, adults, pets, and two small farms.1 c. It will significantly adversely impact the human environment by driving down residential property values in the surrounding vicinity. Statistics establish that property values decline anywhere from 2% to 20% in residential communities where new telecommunications facilities are constructed. 2 1 And if someone’s child gets hurt or killed, the County will likely be named in the ensuing lawsuit. 2 William Gati, New York Real Estate Journal, Sept. 2017; National Business Post, 2022 “Your new neighbor, a cell tower, may impact the value of your home” March 29, 2022; REALTOR Magazine, “Cell Towers, Antennas Problematic for Buyers” July 25, 2014; National Association of Realtors’ Magazine, “Homeowners Complain About ‘Ugly’ 5G Boxes in Their Yards” Jan. 27, 2021; Reply Comments of Smart Communities Siting Coalition, WT Docket No. 16-421; Report and Declaration of David E. Burgoyne, ASA, SR/WA “Impact of Communication Towers and Equipment on Nearby Property Values” in WT Docket No. 16-421; Katheryn E. Fletcher, Ph.D., “The Probable Economic Impact of the T-Mobile Cell Tower on the Residents and City of El Cerrito, California”; D. Rajapaksa et al., “The impact of cell phone towers on house prices: Evidence from Brisbane, Australia,” Environmental Economics and Policy Studies 2018; K. Cheruiyot et al, “Impact of proximity to cell phone tower base stations on residential property prices in the City of Johannesburg, South Africa,” International Journal of Housing Markets and Analysis, 2024; E. Affuso et al., “Wireless Towers and Home Values: An Alternative Valuation Approach Using a Spatial Econometric Analysis,” Journal of Real Estate Finance and Economics, 2018; S. Locke & G. EX 19- Public Comment 2026-04-04 Page 4 of 10 d. It may also significantly affect the human environment by invading Native American burial grounds. Because no studies have been done, it is unknown at this time whether there are artifacts or human remains in the area where the facility is to be sited. e. It will significantly impact the natural environment by releasing electromagnetic fields into the Pacific Flyway, an ecological corridor and established flight path that large numbers of birds use to travel between breeding and wintering grounds. Electromagnetic fields from cell towers have been proven to interfere with birds’ magnetoreception (their ability to navigate using the Earth’s magnetic field), leading to disorientation and reduced breeding.3 f. It will further significantly impact the natural environment by affecting the Northern Spotted Owl in particular, a threatened species native to this area.4 Each of these impacts are adverse. Each of these adverse impacts are significant. Therefore there are considerable significant adverse impacts on the human and natural environments. Significant adverse impacts do not cease to exist simply because the Applicant does not anticipate them. That the Applicant has arranged no mitigation efforts for these significant adverse impacts is indicative that the impacts cannot be mitigated. Because there are significant adverse impacts, and because the significant adverse impacts cannot be mitigated, the County should deny the permit. 6. The Application Fails to Describe How the Use Will Not Be Materially Detrimental to Uses or Property in the Vicinity. When asked to describe how granting the conditional use will not be materially detrimental to uses or property in the vicinity, the Applicant states only that it “will not impede neighboring uses.” This is a non-answer. Given the significant adverse impacts itemized above, together with the absence of mitigation efforts, the only conclusion that can rationally be drawn is that the conditional use will, in fact, be materially detrimental to uses or property in the vicinity, including by impeding views, endangering residents, driving down property values, potentially invading Native American burial grounds, and disrupting the flyway and native habitat of the Northern Spotted Owl. Because the conditional use will be materially detrimental to uses or property in the vicinity, the County should deny the permit. Blomquist, “The Cost of Convenience: Estimating the Economic Impact of Communication Antennas on Residential Property Values,” Land Economics, 2016; S. Bond, “The effect of distance to cell phone towers on house prices (Florida case study), The Appraisal Journal, 2007. 3 U.S. Fish and Wildlife Service, “Avoidance and Minimization Measures: Communication Towers,” www.fws.gov. 4 The Northern Spotted Owl is listed as “Threatened” (Federal, 1990). In 2020 the U.S. Fish and Wildlife Service determined a listing upgrade to “Endangered” was warranted, but was precluded by higher priority actions. Press Release, “Northern Spotted Owl’s Threatened Status to Remain Unchanged,” www.fws.gov, Dec 14, 2020. EX 19- Public Comment 2026-04-04 Page 5 of 10 7. The Application Fails to Establish The Use Will Not Be Substantially Detrimental to the Public Interest. When asked to describe how the conditional use will not be substantially detrimental to the public interest, the Applicant states categorically that “there is no adverse public detriment,” and describes instead how it will serve the public interest. Again, this is a non-answer. There is clearly a substantial public detriment in the danger to the residents, the danger to the natural fauna, and the destruction of existing views. Because the use is substantially detrimental to the public interest, the County should deny the permit. 8. The Application Fails to Establish the Use Complies with Applicable Criteria. When asked to describe how the conditional use complies with all other applicable criteria, standards and other law, the Applicant states only that it does comply. This answer is patently evasive. a. The application contains no description of how the use complies with the performance and use-specific standards of JCC 18.20.130, regulated under Chapter 18.42 JCC. These standards require the application to contain, among other things, a recorded survey, JCC 18.42.040(1)(c) (none is included); a vicinity map as articulated in JCC 18.42.040(1)(e) (the vicinity map provided is not to scale); an analysis by a qualified telecommunications engineer, JCC 18.42.040(1)(l) (no engineering credentials are included with Mr. North’s signature or signature block, nor on any analyses in the application package); a description of the good faith efforts and measures taken to secure a location where the facility would be permitted outright, how and why such efforts were unsuccessful, and how and why the proposed site is essential to meet service demands for the geographic service area, JCC 18.42.040(1)(l) (no such information is provided); and a demonstration, through appropriate analysis, that development on an alternative site within the service area is not feasible, JCC 18.42.090(2)(c)(3) (no such analysis is provided). b. Nor does the application describe how it complies with the development standards of JCC 18.30.160 regarding archaeological and historic resources, in an area that comprises traditional Chemakum and S’Klallam tribal lands, and includes an historic pioneer cemetery dating back to the late 19th/early 20th century. These are just two examples of code sections which the Applicant evades. Titles 18.20 JCC and 18.30 JCC are specifically referenced in the application, but there are many other applicable criteria, standards, and laws which the Applicant likewise fails to address. EX 19- Public Comment 2026-04-04 Page 6 of 10 Because the application fails to describe how the conditional use complies with all other applicable criteria, standards and other law, the County should deny the permit. 9. Conclusion: The County Should Deny the Permit. Under JCC 18.40.530, approval criteria for all conditional uses, the County may approve an application for a conditional use permit if all of the criteria in subsections (1)(a-l) are satisfied. JCC 18.40.530(1). However, in instances where all of these findings cannot be made, the application shall be denied. JCC 18.40.530(2). The word “may” indicates a use of discretion in making a decision, whereas the term “shall” is always mandatory. JCC 18.10.005(1). As demonstrated above, the criteria in subsection (1)(a), that the conditional use is harmonious and appropriate in character and appearance with the existing or intended character and quality of development in the vicinity; in subsection (1)(c), that the conditional use shall not be materially detrimental to uses or property in the vicinity; in subsection (1)(d), that the conditional use shall not introduce noise or other conditions or [sic] which unreasonably impact existing uses in the vicinity; in subsection (1)(i), that the conditional use shall not cause significant adverse impacts on the human or natural environments that cannot be mitigated; and in subsection (1)(l), that the public interest suffers no substantial detrimental effect, cannot be satisfied. Therefore such findings cannot be made. Because these findings cannot be made, the Examiner is directed by section 18.40.530(2) JCC to deny the application. Because these findings cannot be made, and because the Examiner is directed by section 18.40.530(2) to deny the application, the County should deny the permit. B. SEPA Environmental Checklist: The County Should Deny the Application for the Following Reasons. Many of the points in the SEPA Checklist touch on concerns raised in the supplemental application itself. 1. Section A1: The project is named “Horizon Tower Mats Mats Bay” but is to be located in the Port Ludlow community. This is deceptive because it leads Port Ludlow residents to believe the project will be sited in the Mats Mats Bay community, where it would not have significant adverse impacts on Port Ludlow homes. As a result, the Port Ludlow community may be lulled into complacency and miss entirely the opportunity to object and comment on the proposed tower. 2. Section A12: The proposed location is in Port Ludlow. However uninhabited utility corridors exist along Oak Bay Road and Beaver Valley Highway. Have any studies or other efforts been undertaken to determine whether and how the facility can be EX 19- Public Comment 2026-04-04 Page 7 of 10 located elsewhere? If so what are they? If so, please provide legible copies of such studies or other efforts. What other sites have been examined for feasibility? If there are other possibilities, have they been pursued? If not, why not? If so, please provide copies of the documentation and/or feasibility studies and their results. 3. Section A7: The checklist states “No future activity is included in the proposal or anticipated at this time.” However, the instructions to the checklist specifically state “[t]he checklist questions apply to all parts of your proposal, even if you plan to do them over a period of time or on different parcels of land.” (Emphasis in original.) This answer is non-committal at best, and disingenuous at worst, and it contradicts the stated intent to provide space for future carriers. What activity, specifically, is anticipated for the future? Why is this activity not included in the proposal? For each additional activity, please state with specificity how it will impact each topic addressed in the checklist. 4. Section B4(c): The Northern Spotted Owl, a threatened species, is known by residents of the vicinity to be on or near the site. 5. Section B5(a): The Northern Spotted Owl has been observed and is known by residents to be on or near the site. 6. Section B5(b): Per the Washington Department of Fish and Wildlife Priority Habitats and Species report dated 7/29/2025, “the Priority Habitats and Species (PHS) datasets do not contain information for [the] project area. This does not mean that species and habitats do not occur in [the] project area. PHS data, points, lines and polygons are mapped only when occurrences of these species or habitats have been observed in the field. Unfortunately, we have not been able to comprehensively survey all sections in the state and therefore, it is important to note that priority species and habitats may occur in areas not currently known to the Department.” This is consistent with the local residents’ observations and knowledge of the Northern Spotted Owl in the project area. 7. Section B5(c): The Pacific Flyway is a major north-south migration corridor used by birds traveling between breeding and wintering grounds. The route follows the western coast of North America, encompassing a wide range of ecosystems that offer vital stopping points for resting, feeding, and nesting. The Washington coast is a key link in this chain, supporting species like waterfowl, shorebirds, raptors and songbirds.5 The Applicant’s reliance on the Washington Department of Fish and Wildlife Priority Habitats and Species report dated 7/29/2025 is misplaced, as it only confirms that priority species and habitats may occur in areas not currently known to the Department. (See #5 above.) 5 “The Pacific Flyway: Washington’s Vital Role in Bird Migration,” www.wildsprout.org. Wild Sprout is a 501(c)(3) Washington State public charity, whose findings are published free to the public. EX 19- Public Comment 2026-04-04 Page 8 of 10 8. Section B7(a): There is a substantial risk of fire and explosion. Fire hazards are created by the combination of high-powered electrical equipment, lithium-ion backup batteries, and densely packed electronics. Electrical faults such as arcing, overheating, insulation failure, and wiring defects can ignite fires inside equipment cabinets and at the base of towers. Electrical malfunctions are among the most frequently documented causes of tower-related fires worldwide.6 Further, fires involving energized tower equipment cannot be extinguished with water until the power is cut, which can take up to an hour, allowing fires to grow unchecked.7 9. Section B7(a)(3): Toxic or hazardous chemicals will be stored or used during development, construction or the operating life of the project. The applicant indicates there will be a diesel backup generator with a contained fuel system, but gives no indication of what kind of fuel, how much, or whether mitigation efforts are in place. These materials pose chemical and environmental hazards if damaged or improperly maintained. Backup power systems can include lead acid batteries and diesel fuel tanks, sometimes with over 180 gallons of fuel, 8 which can leak during equipment failure, accidents or natural disasters. Some county fire departments even register cell tower sites as HAZMAT sites because first responders must be prepared for risks such as battery acid exposure, fuel ignition, groundwater contamination, and toxic smoke if equipment burns.9 10. Section B8(a): The proposal will affect current land uses on nearby and adjacent properties because cell towers and 5G wireless facilities impact the aesthetic of the surrounding environment. They create visual clutter and can directly conflict with local design standards created to preserve architectural heritage, natural landscapes, and scenic vistas.10 Communities have the right to protect local aesthetics, especially in existing Master Planned Communities and near historic areas. Although the Applicant may envision the project as small, low-profile or minimal, the actual effect may be the opposite as networks become increasingly dense. Small cells include not only pole-top antennas, but large, boxy and visually intrusive cabinets at ground level, power supplies, cooling units and extensive cabling. Together this can overwhelm the landscape and clutter the area. Because 5G requires many nodes spaced a limited distance apart, the cumulative effect becomes a significant visual blight, fundamentally altering neighborhood character.11 6 “Top Ten Health, Safety and Liability Risks of Cell Towers Near Schools,” Environmental Health Sciences, www.ehsciences.org. 7 Id. 8 Id. 9 Id. In 2025 Verizon Wireless agreed to pay $7.7 million to settle a civil enforcement case in California after state and local prosecutors found the company violated environmental and hazardous-materials laws at its thousands of cell tower sites statewide. According to the Los Angeles, California DA, Verizon was found to have failed to comply with reporting and training requirements, inspections, and payments for hazardous materials permits at numerous cell sites. As reported by Westside Today on January 3, 2026, many of those sites store hazardous substances that can pose safety and environmental risks if not managed correctly, including the potential for fires, explosions, and the release of toxic air contaminants. Id. 10 Id. 11 Id. EX 19- Public Comment 2026-04-04 Page 9 of 10 11. Section B13(a): An historic cemetery is located near the site. It is over 45 years old and listed in or eligible for listing in national, state, or local preservation registers. 12. Section B13(b): The cemetery, ca. 1900, is a landmark and feature, and constitutes evidence of historic use. It contains the remains of early community settlers such as the Swansons, Bates, and Johnsons. No studies have been conducted to identify whether there is additional evidence, artifacts or areas of Native American or historic use or occupation, or areas of cultural importance, on or near the site. 13. Conclusion: The County should deny the permit. The applicant has failed to respond, or failed to respond accurately, to the SEPA inquiries whether there are any threatened species on or near the site; whether the site is part of a migration route; whether there are any environmental health hazards, including exposure to toxic chemicals, risk of fire and explosion, spill, or hazardous waste; whether the proposal will affect current land uses on nearby and adjacent properties; and whether there are any landmarks, features, or other evidence of Native American or historic use or occupation on or near the site. Because the Applicant has withheld or failed to provide this information, the Examiner has an inadequate basis on which to evaluate the effects of the proposed tower. Because the Examiner has an inadequate basis on which to evaluate the effects of the proposed tower, the County should deny the permit. In closing I make three final points. First, as of this writing no permit has been issued, but the Applicant has already begun work on the project. This is evidenced by paint markings recently placed on the residential road leading to the site, and by the sounds of brush clearing coming from the site. Unpermitted development activity violates JCC 18.05.020(3), and requires a strong enforcement response from the County at this time. If the County fails to enforce the Applicant’s code violations now, while on notice and while development continues unabated, and if the community subsequently prevails in a suit to enjoin the construction of the facility in this neighborhood, the County may be co- liable for damages accrued as a result of the Applicant’s unauthorized activities. This would, presumably, include the declining property values for homes in the vicinity. Second, the Applicant portrays the project as an existing tower, as detailed in its map of towers already in place in its territory.12 This inaccurate portrayal of the facility is misleading to the public, as it leads one to believe it is already too late to oppose the tower. Moreover, together with the premature development activity, the portrayal tends to support a conclusion that the County has already tacitly approved the requested permit. Third, the DCD has provided the community with two different reference numbers for this matter, and has not updated its web portal since March 3, 2026. The resulting confusion in 12 www.horizontower.com. EX 19- Public Comment 2026-04-04 Page 10 of 10 reference numbers and lack of a current repository precludes parties of record from accessing recent paperwork and developments occurring during the public comment period. Without correct and up-to-date information parties of record are unable to address the community’s concerns in an organized and timely manner, and are thereby denied their right to participate in the process in a meaningful way. This letter is far from comprehensive in its discussion. It introduces just a portion of my concerns, as the list of statutes, regulations and other applicable laws is far too long to address in a single writing. This is only a beginning point for exploration; suffice it to say a more thorough examination must be conducted by the County prior to issuing its decision. I look forward to being designated a party of record in this matter, and to receiving the Applicant’s responses to the concerns I’ve raised. Kindly update your web portal as new information arrives, and notify me of the date, time, and place of the public hearing when it is scheduled. Sincerely, Noura S. Yunker c: Port Ludlow Neighborhood Committee EX 19- Public Comment 2026-04-04 Noura S. Yunker _______________________________________________________________________________________________________________________________________________ 230 Pioneer Dr | Port Ludlow Washington 98365 | Tel: (541)400-8955 | soundlaw@nwlink.com April 7, 2026 Jefferson County Department of Community Development Development Review Division 621 Sheridan Street Port Townsend, WA 98368 Email: planning@co.jefferson.wa.us VIA EMAIL ONLY Re: Horizon Tower Mats Mats Bay Reference Number ZON2025-00011 Dear DCD Representative, I am a resident of the Port Ludlow Master Planned Community. I am gravely concerned about the proposed construction of telecommunications facility in the Port Ludlow neighborhood. This letter addresses my concerns, and demonstrates why the conditional use permit should be denied. Horizon Tower/Verizon Wireless’s Application and SEPA Environmental Checklist reveal the following significant problems: A. Supplemental Application - Conditional Use: The County Should Deny the Application for the Following Reasons. 1. The Application is Incomplete. The Conditional Use application makes clear at the outset that no conditional use permit can be granted unless it is consistent with the performance standards of JCC 18.20, the development standards of JCC 18.30, the procedural requirements of JCC 18.40.280, the approval criteria of JCC 18.40.530, and unless any other applicable requirements of the UDC have been satisfied. Many of the responses in the Supplemental Application create an impression that the project meets certain requirements, but do not, in fact, directly answer the questions posed therein. Therefore, in order to grant the permit it is necessary to confirm the requisite standards, requirements, and criteria have been met. This necessitates additional information from the Applicant. EX 19- Public Comment 2026-04-07 Page 2 of 10 Because the application is incomplete the County should deny the permit. 2. The Application is Misleading. When asked to explain how the conditional use is harmonious and appropriate in design, character and appearance with the existing or intended character and quality of development in the vicinity, the Applicant responds to only one of the three requested criteria: a. The Applicant describes only the physical appearance of the project, without addressing its design or character; b. The Applicant mischaracterizes the surrounding lands as “rural, with scattered residential and undeveloped parcels” when they are instead designated “Rural Residential 1:5.” General Rural can include commercial or industrial zones or resource-based activities, whereas Rural Residential primarily supports single- family dwellings, home businesses, and small-scale agriculture; and c. The surrounding Rural Residential vicinity is actually an existing Master Planned Community of more than 1800 housing units (Port Ludlow Master Planned Resort Community). This misinformation and evasiveness necessitates additional information from the Applicant regarding the harmony and appropriateness of the project’s design and character. It also requires corrected information from the Applicant regarding the designation of the surrounding vicinity as RR 1:5 rather than Rural. Because the application is misleading, and because the Applicant fails to provide requested information, the County should deny the permit. 3. The Application Indicates An Associated Level of Potential Harm. When asked to describe the location, size, and height of signage, the Applicant indicates “required RF safety…signage” will be posted. The FCC mandates warning signs to identify areas where RF emissions exceed the general population or occupational exposure limits. In Category 1 areas where RF energy is below the General Population limit, the use of warning signage is optional or educational. Therefore the Applicant’s intent to post required signage clearly indicates that there will be instances in which the RF emissions exceed the Category 2, 3, or 4 exposure limits. This should preclude granting the permit, because by definition, required RF signage indicates a level of RF emissions exceeding the general population or occupational exposure limits. That the excessive emissions should occur only within the enclosure surrounding the facility is not determinative, because the vicinity is inhabited by families with children and animals. And signage is ineffective in keeping children and animals from enclosures or other attractive nuisances. EX 19- Public Comment 2026-04-07 Page 3 of 10 Because the application indicates there will be instances in which the RF emissions exceed the Category 2, 3, or 4 exposure limits, because children and animals reside in the vicinity, and because the facility will be an “attractive nuisance,” the County should deny the permit. 4. The Application Fails to Describe the Noise Associated with the Facility. When asked to describe “any noise…generated by the conditional use,” the Applicant states only that there is no significant noise associated with the facility. This requires the Examiner to accept the Applicant’s implied characterization of any noise as insignificant, thereby usurping the Examiner’s role in determining in advance what noise, exactly, will be generated, or whether such noise should preclude the granting of a permit. Because the application fails to describe the associated noise, the County should deny the permit. 5. The Application Fails to Address Significant Adverse Impacts. When asked if there are any significant adverse impacts on the human and natural environments, the Applicant states only that it does not anticipate any significant adverse impacts, and that minor impacts are mitigated through compliance with County standards. This does not address the following significant adverse impacts. a. The conditional use will significantly adversely impact the human environment by siting a 150’ high utility tower within a RR 1:5 rural residential zoned district consisting of residential housing with otherwise undegraded views of marine waters and significant open spaces. The 6-foot fence and vegetative screening will not rehabilitate the altered views. b. It will further significantly adversely impact the human environment by placing an admittedly dangerous utility structure in the midst of an existing community of children, adults, pets, and two small farms.1 c. It will significantly adversely impact the human environment by driving down residential property values in the surrounding vicinity. Statistics establish that property values decline anywhere from 2% to 20% in residential communities where new telecommunications facilities are constructed. 2 1 And if someone’s child gets hurt or killed, the County will likely be named in the ensuing lawsuit. 2 William Gati, New York Real Estate Journal, Sept. 2017; National Business Post, 2022 “Your new neighbor, a cell tower, may impact the value of your home” March 29, 2022; REALTOR Magazine, “Cell Towers, Antennas Problematic for Buyers” July 25, 2014; National Association of Realtors’ Magazine, “Homeowners Complain About ‘Ugly’ 5G Boxes in Their Yards” Jan. 27, 2021; Reply Comments of Smart Communities Siting Coalition, WT Docket No. 16-421; Report and Declaration of David E. Burgoyne, ASA, SR/WA “Impact of Communication Towers and Equipment on Nearby Property Values” in WT Docket No. 16-421; Katheryn E. Fletcher, Ph.D., “The Probable Economic Impact of the T-Mobile Cell Tower on the Residents and City of El Cerrito, California”; D. Rajapaksa et al., “The impact of cell phone towers on house prices: Evidence from Brisbane, Australia,” Environmental Economics and Policy Studies 2018; K. Cheruiyot et al, “Impact of proximity to cell phone tower base stations on residential property prices in the City of Johannesburg, South Africa,” International Journal of Housing Markets and Analysis, 2024; E. Affuso et al., “Wireless Towers and Home Values: An Alternative Valuation Approach Using a Spatial Econometric Analysis,” Journal of Real Estate Finance and Economics, 2018; S. Locke & G. EX 19- Public Comment 2026-04-07 Page 4 of 10 d. It may also significantly affect the human environment by invading Native American burial grounds. Because no studies have been done, it is unknown at this time whether there are artifacts or human remains in the area where the facility is to be sited. e. It will significantly impact the natural environment by releasing electromagnetic fields into the Pacific Flyway, an ecological corridor and established flight path that large numbers of birds use to travel between breeding and wintering grounds. Electromagnetic fields from cell towers have been proven to interfere with birds’ magnetoreception (their ability to navigate using the Earth’s magnetic field), leading to disorientation and reduced breeding.3 f. It will further significantly impact the natural environment by affecting the Northern Spotted Owl in particular, a threatened species native to this area.4 Each of these impacts are adverse. Each of these adverse impacts are significant. Therefore there are considerable significant adverse impacts on the human and natural environments. Significant adverse impacts do not cease to exist simply because the Applicant does not anticipate them. That the Applicant has arranged no mitigation efforts for these significant adverse impacts is indicative that the impacts cannot be mitigated. Because there are significant adverse impacts, and because the significant adverse impacts cannot be mitigated, the County should deny the permit. 6. The Application Fails to Describe How the Use Will Not Be Materially Detrimental to Uses or Property in the Vicinity. When asked to describe how granting the conditional use will not be materially detrimental to uses or property in the vicinity, the Applicant states only that it “will not impede neighboring uses.” This is a non-answer. Given the significant adverse impacts itemized above, together with the absence of mitigation efforts, the only conclusion that can rationally be drawn is that the conditional use will, in fact, be materially detrimental to uses or property in the vicinity, including by impeding views, endangering residents, driving down property values, potentially invading Native American burial grounds, and disrupting the flyway and native habitat of the Northern Spotted Owl. Because the conditional use will be materially detrimental to uses or property in the vicinity, the County should deny the permit. Blomquist, “The Cost of Convenience: Estimating the Economic Impact of Communication Antennas on Residential Property Values,” Land Economics, 2016; S. Bond, “The effect of distance to cell phone towers on house prices (Florida case study), The Appraisal Journal, 2007. 3 U.S. Fish and Wildlife Service, “Avoidance and Minimization Measures: Communication Towers,” www.fws.gov. 4 The Northern Spotted Owl is listed as “Threatened” (Federal, 1990). In 2020 the U.S. Fish and Wildlife Service determined a listing upgrade to “Endangered” was warranted, but was precluded by higher priority actions. Press Release, “Northern Spotted Owl’s Threatened Status to Remain Unchanged,” www.fws.gov, Dec 14, 2020. EX 19- Public Comment 2026-04-07 Page 5 of 10 7. The Application Fails to Establish The Use Will Not Be Substantially Detrimental to the Public Interest. When asked to describe how the conditional use will not be substantially detrimental to the public interest, the Applicant states categorically that “there is no adverse public detriment,” and describes instead how it will serve the public interest. Again, this is a non-answer. There is clearly a substantial public detriment in the danger to the residents, the danger to the natural fauna, and the destruction of existing views. Because the use is substantially detrimental to the public interest, the County should deny the permit. 8. The Application Fails to Establish the Use Complies with Applicable Criteria. When asked to describe how the conditional use complies with all other applicable criteria, standards and other law, the Applicant states only that it does comply. This answer is patently evasive. a. The application contains no description of how the use complies with the performance and use-specific standards of JCC 18.20.130, regulated under Chapter 18.42 JCC. These standards require the application to contain, among other things, a recorded survey, JCC 18.42.040(1)(c) (none is included); a vicinity map as articulated in JCC 18.42.040(1)(e) (the vicinity map provided is not to scale); an analysis by a qualified telecommunications engineer, JCC 18.42.040(1)(l) (no engineering credentials are included with Mr. North’s signature or signature block, nor on any analyses in the application package); a description of the good faith efforts and measures taken to secure a location where the facility would be permitted outright, how and why such efforts were unsuccessful, and how and why the proposed site is essential to meet service demands for the geographic service area, JCC 18.42.040(1)(l) (no such information is provided); and a demonstration, through appropriate analysis, that development on an alternative site within the service area is not feasible, JCC 18.42.090(2)(c)(3) (no such analysis is provided). b. Nor does the application describe how it complies with the development standards of JCC 18.30.160 regarding archaeological and historic resources, in an area that comprises traditional Chemakum and S’Klallam tribal lands, and includes an historic pioneer cemetery dating back to the late 19th/early 20th century. These are just two examples of code sections which the Applicant evades. Titles 18.20 JCC and 18.30 JCC are specifically referenced in the application, but there are many other applicable criteria, standards, and laws which the Applicant likewise fails to address. EX 19- Public Comment 2026-04-07 Page 6 of 10 Because the application fails to describe how the conditional use complies with all other applicable criteria, standards and other law, the County should deny the permit. 9. Conclusion: The County Should Deny the Permit. Under JCC 18.40.530, approval criteria for all conditional uses, the County may approve an application for a conditional use permit if all of the criteria in subsections (1)(a-l) are satisfied. JCC 18.40.530(1). However, in instances where all of these findings cannot be made, the application shall be denied. JCC 18.40.530(2). The word “may” indicates a use of discretion in making a decision, whereas the term “shall” is always mandatory. JCC 18.10.005(1). As demonstrated above, the criteria in subsection (1)(a), that the conditional use is harmonious and appropriate in character and appearance with the existing or intended character and quality of development in the vicinity; in subsection (1)(c), that the conditional use shall not be materially detrimental to uses or property in the vicinity; in subsection (1)(d), that the conditional use shall not introduce noise or other conditions or [sic] which unreasonably impact existing uses in the vicinity; in subsection (1)(i), that the conditional use shall not cause significant adverse impacts on the human or natural environments that cannot be mitigated; and in subsection (1)(l), that the public interest suffers no substantial detrimental effect, cannot be satisfied. Therefore such findings cannot be made. Because these findings cannot be made, the Examiner is directed by section 18.40.530(2) JCC to deny the application. Because these findings cannot be made, and because the Examiner is directed by section 18.40.530(2) to deny the application, the County should deny the permit. B. SEPA Environmental Checklist: The County Should Deny the Application for the Following Reasons. Many of the points in the SEPA Checklist touch on concerns raised in the supplemental application itself. 1. Section A1: The project is named “Horizon Tower Mats Mats Bay” but is to be located in the Port Ludlow community. This is deceptive because it leads Port Ludlow residents to believe the project will be sited in the Mats Mats Bay community, where it would not have significant adverse impacts on Port Ludlow homes. As a result, the Port Ludlow community may be lulled into complacency and miss entirely the opportunity to object and comment on the proposed tower. 2. Section A12: The proposed location is in Port Ludlow. However uninhabited utility corridors exist along Oak Bay Road and Beaver Valley Highway. Have any studies or other efforts been undertaken to determine whether and how the facility can be EX 19- Public Comment 2026-04-07 Page 7 of 10 located elsewhere? If so what are they? If so, please provide legible copies of such studies or other efforts. What other sites have been examined for feasibility? If there are other possibilities, have they been pursued? If not, why not? If so, please provide copies of the documentation and/or feasibility studies and their results. 3. Section A7: The checklist states “No future activity is included in the proposal or anticipated at this time.” However, the instructions to the checklist specifically state “[t]he checklist questions apply to all parts of your proposal, even if you plan to do them over a period of time or on different parcels of land.” (Emphasis in original.) This answer is non-committal at best, and disingenuous at worst, and it contradicts the stated intent to provide space for future carriers. What activity, specifically, is anticipated for the future? Why is this activity not included in the proposal? For each additional activity, please state with specificity how it will impact each topic addressed in the checklist. 4. Section B4(c): The Northern Spotted Owl, a threatened species, is known by residents of the vicinity to be on or near the site. 5. Section B5(a): The Northern Spotted Owl has been observed and is known by residents to be on or near the site. 6. Section B5(b): Per the Washington Department of Fish and Wildlife Priority Habitats and Species report dated 7/29/2025, “the Priority Habitats and Species (PHS) datasets do not contain information for [the] project area. This does not mean that species and habitats do not occur in [the] project area. PHS data, points, lines and polygons are mapped only when occurrences of these species or habitats have been observed in the field. Unfortunately, we have not been able to comprehensively survey all sections in the state and therefore, it is important to note that priority species and habitats may occur in areas not currently known to the Department.” This is consistent with the local residents’ observations and knowledge of the Northern Spotted Owl in the project area. 7. Section B5(c): The Pacific Flyway is a major north-south migration corridor used by birds traveling between breeding and wintering grounds. The route follows the western coast of North America, encompassing a wide range of ecosystems that offer vital stopping points for resting, feeding, and nesting. The Washington coast is a key link in this chain, supporting species like waterfowl, shorebirds, raptors and songbirds.5 The Applicant’s reliance on the Washington Department of Fish and Wildlife Priority Habitats and Species report dated 7/29/2025 is misplaced, as it only confirms that priority species and habitats may occur in areas not currently known to the Department. (See #5 above.) 5 “The Pacific Flyway: Washington’s Vital Role in Bird Migration,” www.wildsprout.org. Wild Sprout is a 501(c)(3) Washington State public charity, whose findings are published free to the public. EX 19- Public Comment 2026-04-07 Page 8 of 10 8. Section B7(a): There is a substantial risk of fire and explosion. Fire hazards are created by the combination of high-powered electrical equipment, lithium-ion backup batteries, and densely packed electronics. Electrical faults such as arcing, overheating, insulation failure, and wiring defects can ignite fires inside equipment cabinets and at the base of towers. Electrical malfunctions are among the most frequently documented causes of tower-related fires worldwide.6 Further, fires involving energized tower equipment cannot be extinguished with water until the power is cut, which can take up to an hour, allowing fires to grow unchecked.7 9. Section B7(a)(3): Toxic or hazardous chemicals will be stored or used during development, construction or the operating life of the project. The applicant indicates there will be a diesel backup generator with a contained fuel system, but gives no indication of what kind of fuel, how much, or whether mitigation efforts are in place. These materials pose chemical and environmental hazards if damaged or improperly maintained. Backup power systems can include lead acid batteries and diesel fuel tanks, sometimes with over 180 gallons of fuel, 8 which can leak during equipment failure, accidents or natural disasters. Some county fire departments even register cell tower sites as HAZMAT sites because first responders must be prepared for risks such as battery acid exposure, fuel ignition, groundwater contamination, and toxic smoke if equipment burns.9 10. Section B8(a): The proposal will affect current land uses on nearby and adjacent properties because cell towers and 5G wireless facilities impact the aesthetic of the surrounding environment. They create visual clutter and can directly conflict with local design standards created to preserve architectural heritage, natural landscapes, and scenic vistas.10 Communities have the right to protect local aesthetics, especially in existing Master Planned Communities and near historic areas. Although the Applicant may envision the project as small, low-profile or minimal, the actual effect may be the opposite as networks become increasingly dense. Small cells include not only pole-top antennas, but large, boxy and visually intrusive cabinets at ground level, power supplies, cooling units and extensive cabling. Together this can overwhelm the landscape and clutter the area. Because 5G requires many nodes spaced a limited distance apart, the cumulative effect becomes a significant visual blight, fundamentally altering neighborhood character.11 6 “Top Ten Health, Safety and Liability Risks of Cell Towers Near Schools,” Environmental Health Sciences, www.ehsciences.org. 7 Id. 8 Id. 9 Id. In 2025 Verizon Wireless agreed to pay $7.7 million to settle a civil enforcement case in California after state and local prosecutors found the company violated environmental and hazardous-materials laws at its thousands of cell tower sites statewide. According to the Los Angeles, California DA, Verizon was found to have failed to comply with reporting and training requirements, inspections, and payments for hazardous materials permits at numerous cell sites. As reported by Westside Today on January 3, 2026, many of those sites store hazardous substances that can pose safety and environmental risks if not managed correctly, including the potential for fires, explosions, and the release of toxic air contaminants. Id. 10 Id. 11 Id. EX 19- Public Comment 2026-04-07 Page 9 of 10 11. Section B13(a): An historic cemetery is located near the site. It is over 45 years old and listed in or eligible for listing in national, state, or local preservation registers. 12. Section B13(b): The cemetery, ca. 1900, is a landmark and feature, and constitutes evidence of historic use. It contains the remains of early community settlers such as the Swansons, Bates, and Johnsons. No studies have been conducted to identify whether there is additional evidence, artifacts or areas of Native American or historic use or occupation, or areas of cultural importance, on or near the site. 13. Conclusion: The County should deny the permit. The applicant has failed to respond, or failed to respond accurately, to the SEPA inquiries whether there are any threatened species on or near the site; whether the site is part of a migration route; whether there are any environmental health hazards, including exposure to toxic chemicals, risk of fire and explosion, spill, or hazardous waste; whether the proposal will affect current land uses on nearby and adjacent properties; and whether there are any landmarks, features, or other evidence of Native American or historic use or occupation on or near the site. Because the Applicant has withheld or failed to provide this information, the Examiner has an inadequate basis on which to evaluate the effects of the proposed tower. Because the Examiner has an inadequate basis on which to evaluate the effects of the proposed tower, the County should deny the permit. In closing I make three final points. First, as of this writing no permit has been issued, but the Applicant has already begun work on the project. This is evidenced by paint markings recently placed on the residential road leading to the site, and by the sounds of brush clearing coming from the site. Unpermitted development activity violates JCC 18.05.020(3), and requires a strong enforcement response from the County at this time. If the County fails to enforce the Applicant’s code violations now, while on notice and while development continues unabated, and if the community subsequently prevails in a suit to enjoin the construction of the facility in this neighborhood, the County may be co- liable for damages accrued as a result of the Applicant’s unauthorized activities. This would, presumably, include the declining property values for homes in the vicinity. Second, the Applicant portrays the project as an existing tower, as detailed in its map of towers already in place in its territory.12 This inaccurate portrayal of the facility is misleading to the public, as it leads one to believe it is already too late to oppose the tower. Moreover, together with the premature development activity, the portrayal tends to support a conclusion that the County has already tacitly approved the requested permit. Third, the DCD has provided the community with two different reference numbers for this matter, and has not updated its web portal since March 3, 2026. The resulting confusion in 12 www.horizontower.com. EX 19- Public Comment 2026-04-07 Page 10 of 10 reference numbers and lack of a current repository precludes parties of record from accessing recent paperwork and developments occurring during the public comment period. Without correct and up-to-date information parties of record are unable to address the community’s concerns in an organized and timely manner, and are thereby denied their right to participate in the process in a meaningful way. This letter is far from comprehensive in its discussion. It introduces just a portion of my concerns, as the list of statutes, regulations and other applicable laws is far too long to address in a single writing. This is only a beginning point for exploration; suffice it to say a more thorough examination must be conducted by the County prior to issuing its decision. I look forward to being designated a party of record in this matter, and to receiving the Applicant’s responses to the concerns I’ve raised. Kindly update your web portal as new information arrives, and notify me of the date, time, and place of the public hearing when it is scheduled. Sincerely, Noura S. Yunker c: Port Ludlow Neighborhood Committee EX 19- Public Comment 2026-04-07 From:KJ Turley To:Planning Subject:SEPA Completeness and Neighborhood Impacts Date:Wednesday, April 8, 2026 0:18:40 ALERT: BE CAUTIOUS This email originated outside the organization. Do not open attachments or click on links if you are not expecting them. Dear Development Review Division, I am writing to request clarification regarding the SEPA review and siting decisions for this proposal. I support infrastructure where it is appropriately located. However, placing a large-scale facility in a neighborhood raises serious concerns about compatibility and long-term impacts. Several elements of the SEPA checklist raise questions about completeness and accuracy, including the identification of nearby surface water, wildlife presence, and the extent of vegetation removal. Please ensure that the Applicant fully discloses and explains to you and the Examiner how these conclusions were reached and whether independent verification has occurred. Please also explain how alternative locations were evaluated and why less impactful sites were not selected. A complete and accurate record is essential before any determination is made. Sincerely, KJ Turley 53 Keefe Ln Port Ludlow, WA 98365 EX 19- Public Comment 2026-04-08 (1) From:KJ Turley To:Planning Subject:ZON2025-00011 Mats Mats Proposed Cell Tower Date:Wednesday, April 8, 2026 0:18:04 ALERT: BE CAUTIOUS This email originated outside the organization. Do not open attachments or click on links if you are not expecting them. Dear Jefferson County Review Team, I am submitting this letter as a concerned citizen requesting clarification regarding the siting of the proposed wireless facility. I am not opposed to cell towers. I am opposed to placing one in a residential neighborhood when less intrusive options appear to exist. The current proposal, SEPA, renderings of site with cell tower, do not demonstrate that this site is the least impactful location. Please explain what evaluation has been conducted of alternative sites such as clear cuts, utility corridors, public lands, and other areas away from homes. In addition, please clarify how visual impacts, long-term buildout, and cumulative effects have been evaluated under SEPA. I request that the County ensure that all impacts are fully disclosed and that reasonable alternatives are carefully considered. Sincerely, KJ Turley 53 Keefe Ln Port Ludlow, WA 98365 EX 19- Public Comment 2026-04-08 (2) From:KJ Turley To:Planning Subject:ZON2025-00011 Compatibility and Alternative Siting Date:Wednesday, April 8, 2026 0:17:06 ALERT: BE CAUTIOUS This email originated outside the organization. Do not open attachments or click on links if you are not expecting them. To Whom It May Concern, Re: ZON2025-00011 Compatibility and Alternative Siting I am writing as a resident concerned about the proposed location of this tower within a neighborhood setting. While I understand the need for communication infrastructure, I do not understand why a residential area has been selected when other locations appear to be available that would have fewer impacts on surrounding home? Please provide a clear explanation of how the Applicant’s proposal meets local requirements for compatibility with surrounding land uses and protection of rural character. What specific alternative sites were evaluated, and what criteria were used to reject those locations in favor of this one? A complete and transparent alternatives analysis is essential. Respectfully, KJ Turley 53 Keefe Ln Port Ludlow, WA 98365 EX 19- Public Comment 2026-04-08 (3) From:KJ Turley To:Planning Subject:ZON2025-00011 Siting, Alternatives, and SEPA Review Date:Wednesday, April 8, 2026 0:16:23 ALERT: BE CAUTIOUS This email originated outside the organization. Do not open attachments or click on links if you are not expecting them. Dear Department of Community Development, I am writing as a concerned resident regarding the proposed wireless facility near Upper Fleet in Port Ludlow. I want to be clear that I am not opposed to cell towers or communication infrastructure. My concern is the placement of this facility within a residential neighborhood when other less impactful locations appear to be available. Please respond to the following: Property Values: Reputable studies report that large towers could reduce buyer interest. Research shows that there is an estimated 2.9-20% decrease in property values ($17,400 to $120,000 on a $600,000 home). · Will the applicant establish a study of the home and property values in Port Ludlow now and compare the loss of value if the cell tower is approved? · Is the applicant planning to provide remuneration to home and property owners that lose value? · What studies have been done to demonstrate that homes near the cell site will not lose their value? Alternative Sites: · SEPA requires a complete and accurate disclosure of environmental impacts and a meaningful consideration of alternatives. Please explain what analysis has been conducted to identify feasible alternative sites that would reduce impacts to nearby homes, including clear cut areas, public lands, and other non-residential locations. · What sites and landowners did the Applicant approach to achieve the goal of putting up a cell tower? I respectfully request a thorough and transparent review focused on avoiding and minimizing impacts to established neighborhoods. Sincerely, KJ Turley 53 Keefe Ln Port Ludlow, WA 98365 EX 19- Public Comment 2026-04-08 (4) From:KJ Turley To:Greg Ballard; Planning Subject:Incorrect ZON Number & Access to Community Comments & Questions Date:Wednesday, April 8, 2026 0:14:57 ALERT: BE CAUTIOUS This email originated outside the organization. Do not open attachments or click on links if you are not expecting them. Hello Mr. Ballard, I am writing this evening with concern on a few items and hope that you or someone on your team at the Jefferson County Development Department will respond to me. 1. Providing Incorrect ZON Number: I respect that mistakes can be made, and typos too, so I am hoping that this can be rectified. We found out that you provided the public in writing an incorrect ZON number for the proposed Mats Mats cell tower in Port Ludlow. The number you provided is ZON2024-00011. The press articles and communications went out of hundreds of the community providing them the with ZON2024-00011 to put on their communication to you and the county. And, we were also provided the number of ZON2025-11, which is not correct either as I understand it. We were alerted that the correct number is ZON2025-00011. May we have your assurance that any communication that you and the County receive with the incorrect ZON numbers based on this error, will be treated equally to the correct number? ZON2025-00011. 2. Keeping Comments Updated on the Customer Service Portal: Per your directions at the Town Hall in February, you said that anyone who sends comments and questions to the County is an Official Party of Record and we will be provided to access to the community's response. In addition, we received an email from you acknowledging that we are an Official Party of Record. I have not been provided any information to date with the exception of your email informing us that anyone who sends in communication is a Party of Record. I have checked the website for updates numerous times and the County's website only shows communications in one tab up to the date of 03/03/26 and another location with the last date of 02/27/26. I know for a fact that you have received a number of letters and am wondering when they will be posted? My husband and I live just down the hill from the proposed site. In addition to the markings on Fleet for upcoming construction and the markings of the utilities, brush is being removed from the site. How the County can allow this blatant violation of your regulations is unprecedented and I hope you agree with us and take action. Thank you for your response. My number is 503-332-3738. Regards. KJ Turley EX 19- Public Comment 2026-04-08 (5) From:KJ Turley To:Planning Subject:ZON2025-00011 Siting and Community Impact Concerns Date:Wednesday, April 8, 2026 0:19:20 ALERT: BE CAUTIOUS This email originated outside the organization. Do not open attachments or click on links if you are not expecting them. Dear Jefferson County Department of Community Development, Re: ZON2025-00011 Siting and Community Impact Concerns I am writing as a resident to express concern regarding the proposed location of this tower. I am not opposed to cell towers as infrastructure. My concern is with placing one in a residential neighborhood when other options may be available that would better protect community character and quality of life. 1. Has the Applicant fully researched the archaeological, historic, Native American and early settlers’ standing in this area and the closeness of their resting grounds near the proposed cell tower site? Show us. 2. Does the Applicant demonstrate that they have fully and completely accounted for the waterways nearby when they clearly state that Mats Mat is the closest waterway and the truth is that the Bay is closer? Have they fully disclosed that the porous concrete base under the tower will run through the neighborhood of Port Ludlow and into the Bay? 3. Does the State of Washington give way to a Cell Tower that will be built where a protected species is seen and heard and this is their habitat? 4. Have Micro Cell Towers been considered instead of a tower? If not, the County should demand that the Applicant provide a feasibility study for adding Micro Towers to the telephone poles down Oak Bay. 5. There are children that live in the home in the yard adjacent to the proposed cell tower. Has the Applicant designed the facility so that the noise (projected to be almost 5 times more than a regular air conditioner) and the RF will not harm the lives of the children? 6. How will the Applicant deal with any decommissioning of the cell tower, and has the County required this since wireless communication is going to be a dying communication tool in the future. What are plans and prepaid costs for decommissioning? 7. Does the Applicant clearly and with full consciousness take responsibility for these areas? In addition, please clarify how this proposal aligns with Jefferson County’s goals of preserving scenic character, environmental integrity, and rural quality of life. I respectfully request a careful and transparent review process. Respectfully, KJ Turley EX 19- Public Comment 2026-04-08 (6) 53 Keefe Ln Port Ludlow, WA 98365 EX 19- Public Comment 2026-04-08 (6)