Dear Members of the ZBA,
Everybody who has attended any of the public meetings you have had regarding ATT's petition knows how diligently you have struggled to connect the seemingly contradictory words about ATT's "targeted coverage area" coming from both the written words of its original petition and from the spoken words of its professionals. [Alice: "I think I should understand that better, if I had written that down: but I can't quite follow it as you say it."]
On one side are the oft spoken words of its professionals, "ATT's targeted coverage area includes the population centers of Stoddard." On the other side are the written words of its petition, "[The targeted
coverage areas] ...include the surrounding residential areas in southern and central Stoddard
proximate to NH Routes 9 and 123." (Section 3, page 4of the ATT petition) [emphasis added] Those are two extremely different population areas unless you assume the simple reference to "the" population areas orally stated by ATT professionals means solely those population areas along Routes 9 and 123 proximate to NH Routes 9 and 123. You then make that assumption and you figure that is the simple answer. But, then you read in ATT's written petition (Section 3, page 5):
"There are three key objectives of the Stoddard [Melville Hill] site:
1) Provide competitive in-building wireless service to as many of our existing and future customers that live and work in Stoddard as possible." [emphasis added]
You then are back to a very comprehensive view of "targeted coverage area." But, you can parse that further if you are ATT: "as possible" means that with respect to Melville Hill, it is not "possible" technologically to cover any population area other than the population of the Village of Granite Lake (in Stoddard and Nelson).
[The Mock Turtle: "What is the use of repeating all that stuff, if you don't explain it as you go on? It's by far the most confusing thing I ever heard!"]
Let me try to explain it. Simply rephrase ATT's definition of "targeted coverage area" in terms of real people, not in terms of geographical area, and at the same time completely retain the meaning of ATT's "targeted area" as stated in its petition and confirmed publicly numerous times by its professionals:
TARGETED AREA: The commuters who travel Routes 9 and 123 PLUS about 75 of Stoddard's 1200 citizens PLUS about 50 of Nelson's 800 citizens at the PRICE of diminishing the environment and the aesthetics of one of the most scenic areas of the Towns of Stoddard AND Nelson. [Alice: "It would be so nice if something made sense for a change."] [The Duchess: Take care of the sense, and the sounds will take care of themselves"]
That re-stated "targeted coverage" area makes sense in terms of being enlightened about the actual "on the ground" effect of ATT's petition. From ATT's view the Duchess makes sense: "There's a large mustard-mine near here. And the moral of that is---The more there is of mine, the less there is of yours"]. But of course it's nonsense [The Mock Turtle: "Well, I never heard it before, but it sounds uncommon nonsense"] in terms of the Board's oft stated goal, most often stated by Fred Ward, of a win-win proposition for both ATT and the Town.
I submit , the "people coverage" of ATT's targeted coverage area is so insubstantial and the cost to the two towns of Stoddard and Nelson is so great as to make ATT's petition itself neither credible nor valid, i.e. the petition is not legally sufficient. As such, there is not any need to consider burden of proof, i.e. there is not any need to consider if virtual or computer RF propagation from Melville Hill I or Melville Hill II covers ATT's "targeted coverage areas". There isn't legally or reasonably sufficient "targeted coverage area" to begin with, period, exclamation point. On these grounds, ATT's petition should be rejected.
[Alice: "A cat may look at a king. I've read that in some book, but I don't remember where."
Respectfully submitted,
Richard (Nick) Nicoletti
Cc: Attorney Sam Bradley
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