1. In the first sentence of its May 31, 2021 application submission Rogers falsely asserted it had “completed the public consultation process, following the Islands Trust draft Model Public Consultation Protocol”.  Rogers did not fulfill this protocol’s requirements. There was no public information session. There was no pre-consultation with the LTC. With its proximity to homes and a nature preserve, this site is clearly identified as a “discouraged location” in the protocol. Rogers ignored this, along with other local preferences and requirements.

2. Rogers claimed the tower to be “well setback from surrounding residential properties”, implying it was in compliance with the 50 meter setback requirement when in truth the tower site is 42 meters from the nearest home.

3. In their application submission, the Proponents failed to inform the SS LTC about Covenant FB102667 which states that the land the site is on must not be built upon except in accordance with the Channel Ridge Master Development Plan. That Master Development Plan does not include the siting of a cell tower.

4. In its public consultation package, Rogers underplayed the tower’s impact by reporting only the initial number of antennas the tower would hold (9), not the number contained in the Engineer’s Plan. (23)

5. During the public consultation process, Rogers’ agent Cyprus was evasive, aloof, inconsistent, gave partial information only, and did not answer every question asked. When asked if the tower would be used for 5G, Roger’s agent told one member of the public “this proposed antenna installation in and of itself will not be supplying future 5G services to the island.” Cypress then wrote to another: “5G cellular may be deployed in the future” and to yet another: “Rogers will be deploying 5G services on this proposed installation.”

6. ISED requires proponents to discuss site options with the land use authority. Instead, Rogers signed the lease and drew up the site plan a year before they approached our local government. Rogers, and not the LTC, ruled out other siting options.

7. This site has been identified as archaeologically sensitive to First Nations. Rogers did not consult with First Nations as ISED requires.

8. The protocol that was actual policy at the time of this application  – Salt Spring’s 2001 Cellular Antenna Procedural Guideline – required that the cumulative radiation output of any cell site built within 500 meters of homes be measured, and be well below Health Canada’s requirements. This policy was, erroneously, not followed by our local government, Rogers or ISED and as a result, wellbeing has been compromised.