clearwood-send-general-omments | Stop5ginthebaldhill

Send your comments regarding the Clearwood 5G project tower

Dear Neighbor, Thurston county issued their notice of application and we have till the 29th of September to voice our concern to the county as part of the initial comment period of the application. This page is pre-filled so you can use it and modify the template to send an email to the Thurston County project manager responsible for recording the comments. Make your voice heard, this is critical that your comment is received by the county.

Once done, please go to this other page to send an other email for the environmental review (SEPA review)

Yelm Clear Lake / Clearwood
Project 2026101582 | Parcel 23505000000
SUP 26-107217 ZM | SEPA 26-107218 XA
RUE 26-114952 XI | Subtype: Hazardous Slope

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Dear Thurston County Planning Team,

Please include this comment in the record for Project 2026101582, the Yelm Clear Lake / Clearwood wireless communication facility, SUP 26-107217 ZM, and Reasonable Use Exception 26-114952 XI, subtype Hazardous Slope, on parcel 23505000000.

This comment addresses the August 31, 2026 revised submission, including the updated narrative, compliance statement, land-use plans, RUE application, steep-slope exhibit, and the August 27 geotechnical summary. Please enforce the applicable 50-foot landslide-hazard buffer unless all requirements for the requested exception are demonstrated.

1. Verify the entire development footprint and the requested buffer encroachment

The geotechnical summary states that steeper slopes begin approximately 52 feet from the tower. The RUE application separately places the compound within 27 feet of slopes exceeding 40% and acknowledges buffer impacts on its east side. Attachment 35 and plan A-1 also show a 23-foot slope-to-compound label and a 27-foot-2-inch dimension. Please reconcile these measurements, identify their endpoints, and show the closest distances from the delineated hazard boundary to the tower foundation, compound, equipment pads, landscaping, parking, access, utilities, and all construction disturbance.

I am not asserting that the tower center is inside the 50-foot buffer or that no slope exhibit has been provided. Please show the County-accepted hazard boundary, the buffer measured from that boundary, and the precise area and scope of the requested exception. The 50-foot radius from the tower and the separate 50-foot offset from the lease area should be clearly distinguished from the regulatory buffer.

2. Apply the property-wide reasonable-use criteria, not only an engineering safety test

The RUE form expressly invokes TCC 24.45.030. The revised narrative describes an approximately 532-acre property; the RUE response identifies existing timber harvesting and two water tanks serving the community. Please explain how maintaining the buffer would deny all reasonable use of the property as a whole, rather than simply limit the applicant's preferred compound location.

I acknowledge that Section 6 of the revised narrative discusses existing towers, water tanks, residences, utility poles, coverage objectives, and the search ring, and that the RUE response says adjustments to the compound were considered. Please provide the site-specific comparison of alternative locations and layouts on this parcel, including reductions in size, different uses, timing, and design. Identify the actual alternatives evaluated, their critical-area impacts, and why a reasonable use with less impact is not possible. The coverage and co-location analysis should not substitute for addressing each separate RUE criterion.

3. Demonstrate minimum necessary encroachment and supportable mitigation

The 50-by-50-foot compound reserves space for two future carriers in addition to AT&T. Please explain why this footprint and buffer encroachment are the minimum necessary, and compare smaller or reconfigured layouts, including moving equipment outside the buffer while keeping the tower location and meeting co-location requirements. Provide alternative drawings and impact quantities, or identify where that comparison is already submitted, rather than only citing the need for three-carrier space.

The August 27 engineer's letter supports a drilled-shaft foundation, recommends a 10-foot natural-slope setback, reports no instability features within 300 feet, and predicts no adverse slope-stability effect. I acknowledge Mark Biever's September 4, 2026 concurrence on slope stability for the tower and ancillary structures. It does not compare alternatives or establish why an exception is necessary. Please make separate findings on reasonable use, alternatives, safety, minimum encroachment, critical-area functions, mitigation, and species of concern. Identify the calculations, construction assumptions, drainage provisions, and enforceable mitigation for the entire footprint.

4. Resolve inconsistencies before deciding the permits

The compliance statement still says the location is outside required buffers, although its later RUE section and the RUE application acknowledge compound encroachment. It also contains older administrative-review language while expressly acknowledging Hearing Examiner approval elsewhere. Please identify the controlling project description, the approval and hearing process for both the SUP and RUE, and the applicable notice procedures.

Please reconcile the SEPA checklist's approximately 247 square feet of impervious surface with the plan title sheet's approximately 2,500 square feet. The narrative lists Attachment 24, Stormwater Report; please identify its current version and confirm that it evaluates the final compound, roads, utilities, and slope-buffer impacts. I am not asserting that no stormwater report has been submitted.

The revised plans now include critical-area mapping and a four-foot-wide landscape strip. Please assess the adequacy of these measures and their relationship to the full development footprint, rather than treating their inclusion alone as proof of compliance.

Unless every applicable RUE criterion is supported, I request denial of the exception and a revised proposal that respects the buffer. Please make the supporting reports, alternatives, verified measurements, mitigation, and separate County findings available for public review.

5. RF exposure standards - background only, not a requested basis for denial

I recognize that 47 U.S.C. 332(c)(7)(B)(iv) prevents the County from regulating personal wireless facilities based on the environmental or health effects of RF emissions to the extent the facilities comply with FCC regulations. I am not asking the County to deny a compliant facility on that basis.

Nevertheless, I wish to record my concern that the FCC exposure limits at issue date from 1996 and their adequacy continues to be questioned. In Environmental Health Trust v. FCC, 9 F.4th 893 (D.C. Cir. 2021), the court found the FCC's 2019 decision inadequately explained its treatment of evidence concerning non-cancer health effects and environmental impacts, and remanded for further explanation. The ruling did not invalidate the exposure limits or decide the scientific debate over RF health effects.

Environmental Health Trust's September 11, 2026 report describes a new FCC request for public comments on the remanded issues in ET Docket 13-84. I raise this continuing federal debate for background only, not as a substitute for the separate land-use, critical-area, alternatives, and RUE findings requested above.

Please respond to these concerns, include this message in the project record, and add me as a party of record. Please send future notices, hearing information, decisions, and appeal information to the email address from which I submit this comment, and advise whether another step is required to receive notices.

Thank you.

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Dear Thurston County Planning Team,

Please include this comment in the record for Project 2026101582, the Yelm Clear Lake / Clearwood wireless communication facility, SUP 26-107217 ZM, and Reasonable Use Exception 26-114952 XI, subtype Hazardous Slope, on parcel 23505000000.

This comment addresses the August 31, 2026 revised submission, including the updated narrative, compliance statement, land-use plans, RUE application, steep-slope exhibit, and the August 27 geotechnical summary. Please enforce the applicable 50-foot landslide-hazard buffer unless all requirements for the requested exception are demonstrated.

1. Verify the entire development footprint and the requested buffer encroachment

The geotechnical summary states that steeper slopes begin approximately 52 feet from the tower. The RUE application separately places the compound within 27 feet of slopes exceeding 40% and acknowledges buffer impacts on its east side. Attachment 35 and plan A-1 also show a 23-foot slope-to-compound label and a 27-foot-2-inch dimension. Please reconcile these measurements, identify their endpoints, and show the closest distances from the delineated hazard boundary to the tower foundation, compound, equipment pads, landscaping, parking, access, utilities, and all construction disturbance.

I am not asserting that the tower center is inside the 50-foot buffer or that no slope exhibit has been provided. Please show the County-accepted hazard boundary, the buffer measured from that boundary, and the precise area and scope of the requested exception. The 50-foot radius from the tower and the separate 50-foot offset from the lease area should be clearly distinguished from the regulatory buffer.

2. Apply the property-wide reasonable-use criteria, not only an engineering safety test

The RUE form expressly invokes TCC 24.45.030. The revised narrative describes an approximately 532-acre property; the RUE response identifies existing timber harvesting and two water tanks serving the community. Please explain how maintaining the buffer would deny all reasonable use of the property as a whole, rather than simply limit the applicant's preferred compound location.

I acknowledge that Section 6 of the revised narrative discusses existing towers, water tanks, residences, utility poles, coverage objectives, and the search ring, and that the RUE response says adjustments to the compound were considered. Please provide the site-specific comparison of alternative locations and layouts on this parcel, including reductions in size, different uses, timing, and design. Identify the actual alternatives evaluated, their critical-area impacts, and why a reasonable use with less impact is not possible. The coverage and co-location analysis should not substitute for addressing each separate RUE criterion.

3. Demonstrate minimum necessary encroachment and supportable mitigation

The 50-by-50-foot compound reserves space for two future carriers in addition to AT&T. Please explain why this footprint and buffer encroachment are the minimum necessary, and compare smaller or reconfigured layouts, including moving equipment outside the buffer while keeping the tower location and meeting co-location requirements. Provide alternative drawings and impact quantities, or identify where that comparison is already submitted, rather than only citing the need for three-carrier space.

The August 27 engineer's letter supports a drilled-shaft foundation, recommends a 10-foot natural-slope setback, reports no instability features within 300 feet, and predicts no adverse slope-stability effect. I acknowledge Mark Biever's September 4, 2026 concurrence on slope stability for the tower and ancillary structures. It does not compare alternatives or establish why an exception is necessary. Please make separate findings on reasonable use, alternatives, safety, minimum encroachment, critical-area functions, mitigation, and species of concern. Identify the calculations, construction assumptions, drainage provisions, and enforceable mitigation for the entire footprint.

4. Resolve inconsistencies before deciding the permits

The compliance statement still says the location is outside required buffers, although its later RUE section and the RUE application acknowledge compound encroachment. It also contains older administrative-review language while expressly acknowledging Hearing Examiner approval elsewhere. Please identify the controlling project description, the approval and hearing process for both the SUP and RUE, and the applicable notice procedures.

Please reconcile the SEPA checklist's approximately 247 square feet of impervious surface with the plan title sheet's approximately 2,500 square feet. The narrative lists Attachment 24, Stormwater Report; please identify its current version and confirm that it evaluates the final compound, roads, utilities, and slope-buffer impacts. I am not asserting that no stormwater report has been submitted.

The revised plans now include critical-area mapping and a four-foot-wide landscape strip. Please assess the adequacy of these measures and their relationship to the full development footprint, rather than treating their inclusion alone as proof of compliance.

Unless every applicable RUE criterion is supported, I request denial of the exception and a revised proposal that respects the buffer. Please make the supporting reports, alternatives, verified measurements, mitigation, and separate County findings available for public review.

5. RF exposure standards - background only, not a requested basis for denial

I recognize that 47 U.S.C. 332(c)(7)(B)(iv) prevents the County from regulating personal wireless facilities based on the environmental or health effects of RF emissions to the extent the facilities comply with FCC regulations. I am not asking the County to deny a compliant facility on that basis.

Nevertheless, I wish to record my concern that the FCC exposure limits at issue date from 1996 and their adequacy continues to be questioned. In Environmental Health Trust v. FCC, 9 F.4th 893 (D.C. Cir. 2021), the court found the FCC's 2019 decision inadequately explained its treatment of evidence concerning non-cancer health effects and environmental impacts, and remanded for further explanation. The ruling did not invalidate the exposure limits or decide the scientific debate over RF health effects.

Environmental Health Trust's September 11, 2026 report describes a new FCC request for public comments on the remanded issues in ET Docket 13-84. I raise this continuing federal debate for background only, not as a substitute for the separate land-use, critical-area, alternatives, and RUE findings requested above.

Please respond to these concerns, include this message in the project record, and add me as a party of record. Please send future notices, hearing information, decisions, and appeal information to the email address from which I submit this comment, and advise whether another step is required to receive notices.

Thank you.

Sincerely,
[Your name]

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Send your comments regarding the Clearwood 5G project tower

Stop 5G in the bald hill